RECORD OF DECISION
Cinnaminson Groundwater Contamination Superfund Site
OU4
Cinnaminson and Delran, Burlington County, New Jersey
United States Environmental Protection Agency
Region 2
New York, New York
June 2021
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US EPA
Cinnaminson Groundwater Contamination Site OU4 ROD
Table of Contents
PART 1 DECLARATION i
PART 2 DECISION SUMMARY 1
I. SITE NAME, LOCATION, AND DESCRIPTION 1
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
4. SCOPE AND ROLE OF RESPONSE ACTION 5
5. SUMMARY 01 SITE CI IARAC ITRISTICS 5
Physical Setting 5
Summary of the 0U4 Remedial Investigation 7
6. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 12
7. SUMMARY OF SITE RISKS 13
8. REMEDIAL ACTION OBJECTIVES 18
9. DESCRIPTION OF REMEDIAL ALTERNATIVES 19
10. COMPARATIVE ANALYSIS OF ALTERNATIVES 25
Overall Protection of Human Health and the Environment 25
PRINCIPAL THREAT WASTES 30
SELECTED REMEDY 30
Description of the Selected Remedy 30
Expected Outcomes of the Selected Remedy 32
STATUTORY DETERMINATIONS 33
Protection of Human Health and the Environment 33
Compliance with ARARs 33
Cost Effectiveness 34
Utilization of Permanent Solutions and Alternative Treatment 35
(or Resource Recovery) Technologies to Maximum Extent Practicable 35
Five-Year Review Requirements 35
II. DOCUMENTATION OF SIGNIFICANT CHANGES 35
The Responsiveness Summary is provided as a separate attachment to this Record of Decision.
APPENDIX I: FIGURES
APPENDIX II: TABLES
APPENDIX III: ADMINISTRATIVE RECORD INDEX
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US EPA
Cinnaminson Groundwater Contamination Site OU4 ROD
APPENDIX IV: NEW JERSEY STATE CONCURRENCE LETTER
APPENDIX V: RESPONSIVENESS SUMMARY
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US EPA
Cinnaminson Groundwater Contamination Site OU4 ROD
APPENDIX V ATTACHMENTS:
Attachment A - Proposed Plan
Attachment B - Public Notice "Tear Sheets"
Attachment C - Public Meeting Transcript
Attachment D - Written Comments Submitted During Public Comment Period
LIST OF FIGURES
Figure 1
Site Location Map
Figure 2
Site Plan OU4
Figure 3
Hydropunch® Locations
Figure 4
Geoprobe® Locations
Figure 5
Monitoring Well Locations
Figure 6
Hydropunch® Results
Figure 7
Geoprobe® Results
Figure 8
Monitoring Well Results
Figure 9
VOC Plume
Figure 10
Groundwater Remedy
Figure 11
Groundwater Treatment Process Flow Diagram
LIST OF TABLES:
Table 1: Summary of Chemicals of Concern and Exposure Point Concentrations
Table 2: Selection of Exposure Pathways
Table 3: Non-Carcinogenic Toxicity Data Summary
Table 4: Cancer Toxicity Data Summary
Table 5: Risk Characterization Summary - Non-Carcinogens
Table 6: Risk Characterization Summary - Carcinogens
Table 7: Remediation Goals for Groundwater
Table 8: Comparative Cost Estimate Summary for Each Alternative
Table 9: Chemical-Specific ARARs, TBCs, and Other Guidance
Table 10: Location-Specific ARARs, TBCs, and Other Guidance
Table 11: Action-Specific ARARs, TBCs, and Other Guidance
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PART 1 DECLARATION
SITE NAME AND LOCATION
Cinnaminson Groundwater Contamination Superfund Site, Operable Unit 4 (OU4)
Cinnaminson and Delran, Burlington County, New Jersey
Superfund Site Identification Number: NJD980785638
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S Environmental Protection Agency's (EPA's)
selection of a remedy for OU4 of the Cinnaminson Groundwater Contamination Superfund Site
(Site), in Burlington County, New Jersey, which was selected in accordance with the requirements
of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA), 42 U.S.C. §§ 9601-9675, and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. This decision document explains the
factual and legal basis for selecting the remedy. Appendix III (see attached) identifies the items
that comprise the administrative record upon which the selected remedy is based.
The New Jersey Department of Environmental Protection (NJDEP) was consulted in accordance
with Section 121(f) of CERCLA, 42 U.S.C. § 9621(f), and defers concurrence with the selected
remedy.
ASSESSMENT OF THE SITE
The response action selected in this ROD 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
The major components of the OU4 selected remedy include the following:
• Groundwater extraction and treatment in portions of the OU4 contaminated groundwater
plume with the highest levels of contamination, located downgradient, but in close
proximity to, identified source areas;
• Construction of a centralized groundwater treatment plant which may include the following
components, as necessary: metals removal system, air stripping, vapor phase granular
activated carbon (GAC) adsorption, liquid phase GAC adsorption, 1,4-dioxane treatment
and advanced oxidation processes (AOP);
• Discharge of treated groundwater to surface water at Pompeston Creek or reinjection of
treated water into the aquifer;
• Institutional Controls (ICs) and Long-term Monitoring (LTM) until the OU4 aquifer is
restored.
A pre-design investigation (PDI) will be conducted in order to collect additional data needed to
implement the remedy.
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Active remediation elements will be designed to achieve the RAOs to reduce or eliminate further
migration of groundwater containing Site-related contaminants at concentrations greater than
federal and state standards, preventing future exposure (via ingestion, dermal contact, and
inhalation) to Site-related contaminants in groundwater at concentrations greater than federal and
state standards, and, restoring the impacted aquifer to its most beneficial use as a source of drinking
water by reducing Site-related contaminant levels to the most stringent of federal and state
standards.
The extraction and treatment system will operate until remediation goals (RGs) are attained. The
exact number and placement of recovery well(s), pumping rates, and treatment processes, the
location of the treatment plant, and the method for discharge of the treated groundwater will be
determined during the remedial design.
An LTM program will be implemented to track and monitor changes in the OU4 groundwater and
surface water contamination to ensure the RGs are attained. The results from the LTM program
will be used to evaluate the migration and changes in Site-related contaminants of concern (COCs)
for OU4 over time. ICs will be implemented to ensure that the remedy remains protective of
human health until RGs are achieved for protection of human health over the long term.
The total estimated, present-worth cost for the selected remedy is $22,366,000. Further details of
the cost are presented in Appendix F of the Feasibility Study (FS) Report. 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.
Consistent with EPA Region 2's Clean and Green policy, EPA will evaluate the use of sustainable
technologies and practices with respect to the remedial alternative selected for OU4.1—This will
include green remediation technologies and practices.
DECLARATION OF STATUTORY DETERMINATIONS
Part 1: Statutory Requirements
The selected remedy meets the requirements for remedial actions set forth in Section 121 of
CERCLA, 42 U.S.C. § 9621, because it meets the following requirements: 1) it is protective of
human health and the environment; 2) it meets a level or standard of control of the hazardous
substances, pollutants, and contaminants that at least attains the legally applicable or relevant and
appropriate requirements (ARARs) under federal and state laws; 3) it is cost-effective; and 4) it
utilizes permanent solutions and alternative treatment or resource recovery technologies to the
maximum extent practicable. In addition, Section 121 of CERCLA includes a preference for
remedies that employ treatment that permanently and significantly reduces the volume, toxicity,
or mobility of hazardous substances as a principal element.
See https://www.epa.gov/greenercleanups/epa-region-2-clean-and-green-policY.
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Part 2: Statutory Preference for Treatment
The selected remedy complies with the statutory mandate to utilize permanent solutions,
alternative treatment technologies, and resource recovery alternatives to the maximum extent
practicable. Of the 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 provides the best balance of tradeoffs among the alternatives with respect to
the balancing criteria set forth in the Section 300.430(f)(l)(i)(B) of the NCP and represents the
maximum extent to which permanent solutions and treatment technologies can be utilized in a
practicable manner at the Site. The selected remedy satisfies the criteria for long-term effectiveness
and permanence by permanently reducing the mass of contaminants in the groundwater at the Site,
thereby reducing the toxicity, mobility, and volume of contamination.
Part 3: Five-Year Review Requirements
Because this remedy will not result in hazardous substances, pollutants, or contaminants remaining
above levels that allow for unlimited use and unrestricted exposure, EPA anticipates that a
statutory five-year review will not be required for groundwater. However, because it may take
more than five years to attain the RAOs and cleanup levels for the groundwater, policy reviews
will be conducted until the RGs are met to ensure that the remedy is, or will be, protective of
human health and the environment.
ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the administrative record file for this action.
•S A discussion of the current nature and extent of contamination is included in the "Summary
of Site Characteristics" section.
•S COCs and their respective concentrations may be found in the "Summary of Site
Characteristics" section.
•S Potential adverse effects associated with exposure to Site contaminants may be found in
the "Summary of Site Risks" section.
•S A discussion of groundwater remediation goals for COCs may be found in the "Remedial
Action Objectives" section and in Table 7 in Appendix II.
•S A discussion of principle threat waste is contained in the "Principle Threat Wastes" section.
•S Current and reasonably anticipated future land use assumptions are presented in the
"Current and Potential Future Land Uses" section.
•S Estimated capital, operation and maintenance, and total present-worth costs are discussed
in the "Description of Remedial Alternatives" section.
•S Key factors that led to selecting the remedy (i.e., how the selected remedy provides the
best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting
criteria key to the decision) may be found in the "Comparative Analysis of Alternatives"
and "Statutory Determinations" sections.
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AUTHORIZING SIGNATURE
P\/annolicta Digitally signed by
E-VcJI lyCIISlcJ, Evangelista, Pat
O_i. Date: 2021.06.30 17:45:53 > »r\ r\r\r\ a
Pat -04W June 30,2021
Pat Evangelista, Director Date
Superfund Emergency and Management Division
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PART 2 DECISION SUMMARY
1. SITE NAME, LOCATION, AND DESCRIPTION
The Cinnaminson Groundwater Contamination Site covers approximately 400 acres. The Site is
located in the townships of Cinnaminson and Delran, Burlington County, New Jersey, and includes
properties bounded by Union Landing Road, U.S. Route 130, River Road and Taylors Lane. The
Site includes the two closed Sanitary Landfill, Inc. (SLI) Landfills, residential properties and light
to heavy industrial properties including the Messer LLC (Messer) property and the Detrex
Corporation (Detrex) property. The Delaware River is located northwest of the Site and U.S.
Route 130 passes southeast of the Site. Two small streams, Pompeston Creek and Swedes Run,
receive run-off from the Site and discharge into the Delaware River.
The Site cleanup is being addressed in four phases, or Operable Units (OUs). (See Figure 1). The
Operable Unit 1 (OU1) Record of Decision (ROD) was issued by EPA on September 28, 1990,
and addressed contaminated groundwater primarily associated with the SLI Landfills. The
Operable Unit 2 (OU2) ROD was issued by EPA on July 31,2014, and addressed the SLI Landfills,
which is a source of contamination at the Site. Operable Unit 3 (OU3) is addressing contamination
associated with the Messer property located in Cinnaminson Township, another identified source
area of groundwater contamination. EPA is overseeing the ongoing Remedial
Investigation/Feasibility Study (RI/FS) for the OU3 portion of the Site. Operable Unit 4 (OU4)
is the subject of this ROD. (See Figure 2).
OU4 includes contaminated groundwater underlying residential, commercial, and industrial
properties. The OU4 study area is bounded to the southwest by Pompeston Creek, to the northwest
by the Delaware River, to the northeast by Swedes Run, and to the southeast by New Jersey
American Water (NJAW) New Albany Road water supply wells. This OU4 remedy addresses
Site-related groundwater contamination emanating from three major identified sources in a
comingled plume. The current land use in OU4 ranges from industrial and commercial to
residential. There are wetlands along Pompeston Creek and Swede Run, both of which are
influenced by the Delaware River tidal fluctuations. According to the U.S. Fish and Wildlife
Service, there are no threatened, endangered and candidate species or no critical habitat at the Site.
2. SITE HISTORY
Groundwater contamination at the Site was discovered in the early 1980s by the New Jersey
Department of Environmental Protection (NJDEP) through the review of groundwater monitoring
data collected as part of the closure plan for the SLI Landfills located between Union Landing
Road and Taylors Lane. Hazardous substances were reportedly deposited in these landfills.
Contaminants including tetrachloroethene (PCE), trichloroethylene (TCE), cis-1,2-
dichloroethylene (cis-l,2-DCE), vinyl chloride (VC), 1,2-dichloroethane (1,2-DCA), benzene and
arsenic were detected in the groundwater, soil and/or soil vapor. Based on this information, in
June 1986, the EPA placed the Site on the National Priorities List of Superfund Sites.
QUI
The two SLI landfills, originally owned by Lockhart Construction Company, were operated as
sand and gravel mines. The mining operations were terminated in the late 1960s.
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The 0U1 RI/FS was performed by EPA from 1985 to 1989. The study primarily focused on
groundwater contamination emanating from the two former SLI Landfills.
On September 28, 1990, EPA issued the OU1 ROD. The selected remedy included the following
actions: extraction and treatment of contaminated groundwater primarily emanating from the SLI
Landfills; reinjection of the treated groundwater; and installation and monitoring of additional
wells to ensure the effectiveness of the remedy.
After the engineering design of the remedy was completed, construction of the treatment plant and
installation of the extraction, treatment and reinjection system was completed in January 2000.
The system began operating and treating contaminated groundwater in May 2000.
In May 2013, SC Holdings, Inc. (SCH), a wholly owned subsidiary of Waste Management, Inc.
and the current owner of the landfills, submitted a request to perform a "pump and treat system
monitoring assessment/shutdown test" (also known as a "Shutdown Study") since groundwater
quality had improved. The purpose of the proposed two-year Shutdown Study was to evaluate if
the groundwater contaminant levels would increase if the groundwater treatment plant operation
was temporarily shut down. EPA reviewed and evaluated the results of the two-year Shutdown
Study. As a result, in 2016, a long-term monitoring plan (LTMP) was developed to monitor
groundwater to ensure contaminant levels continue to improve. This LTMP will continue while
the temporary shutdown remains in place.
OU2
The OU2 ROD addressed the source area contamination at the SLI landfills. Landfill caps had
been previously constructed in 1987 pursuant to a NJDEP Administrative Consent Order (ACO)
dated October 1984.
After SCH's design, construction and monitoring of an enhanced landfill gas management system
and drainage improvements, the OU2 ROD was issued on July 31, 2014. The ROD determined
that no further remedial action was necessary for OU2 to ensure protection of human health and
the environment. SCH maintains the landfill caps with oversight by the regulatory agencies.
OU3
Messer LLC (Messer), formerly Linde LLC (Linde), and before that BOC Gases, formerly a
division of The BOC Group, Inc. which became Linde, Inc. by name change, operated a facility
located on River Road (also called Broad Street). In 2008, EPA and Linde, Inc. entered into an
Administrative Order on Consent (AOC) for the performance of a RI/FS and a removal action to
address soil and groundwater contamination that is located on or migrating from the Messer
property. The results of prior sampling data, as well as RI investigations conducted during the OU3
RI/FS field investigations, showed that groundwater is impacted by volatile organic compounds
(VOCs), primarily chlorinated solvents. TCE, cis-l,2-DCE, and VC were consistently detected in
groundwater samples both on and off and downgradient of the Messer property. The distribution
of the VOCs show source(s) of VOCs in the OU3 area, and groundwater containing VOCs flows
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both to the northwest (beneath Inman Street, Kern Street, and Zeisner Street in Cinnaminson)
where it potentially discharges to the Delaware River, and the southeast, where it mixes with VOCs
from OU1 and other sources. Groundwater contamination migrating northwest will be addressed
as part of OU3, while contamination migrating to the southeast is included as part of OU4.
Vapor Intrusion
In conjunction with the OU3 RI/FS, a vapor intrusion (VI) investigation/mitigation of nearby
residential properties has been ongoing since March 2009. To date, EPA has tested 73
homes/businesses and has installed 10 treatment systems. All residential VI investigation activities
are associated with the OU3 RI/FS and are not included as part of the OU4 remedy.
A previous OU3 VI study was also conducted in 2009 of a neighborhood downgradient of the
Messer property located near the Detrex property. There were no issues found with VI in this
neighborhood, and thus no additional sampling events have been conducted in that location.
OU4
OU4 addresses groundwater contamination within the Site that is not currently being addressed by
OU1, OU2, or OU3. The SLI Landfills (described above), the Detrex property and the Messer
property (described above) are the primary identified sources of the OU4 groundwater
contamination.
A summary of additional potential major source area properties investigated under the OU4 RI
includes the following:
Detrex Corporation
The Detrex property at 835 Industrial Highway, Cinnaminson, New Jersey was first developed in
1972 by Whitesell Construction Corporation as a multi-tenant industrial/commercial center.
Detrex began operations in 1972 as a storage, distribution, and transportation facility for solvents
used in degreasers within an 8,000 square foot leasehold of the property. From 1987 to 2006,
Detrex operated as a storage and transfer facility for wastes containing chlorinated solvents,
including PCE, TCE, 1,1,1-trichloroethane (1,1,1-TCA), methylene chloride, and
trichlorotrifluoroethane. By 1990, Detrex handled wastes containing poly chlorinated biphenols
(PCBs), herbicides, and other chemicals. In June 2002, Detrex sold the solvent distribution portion
of the business and limited assets to Parts Cleaning Technologies (PCT).
Multiple investigations have been performed under NJDEP oversight at the Detrex property since
July 2001 and are ongoing. These investigations show that there is an uncontrolled release of TCE,
as well as other contaminants, at the Detrex property which impacts soil and groundwater on and
underlying the property, downgradient groundwater, and downgradient soil gas. This facility is a
significant source of OU4 groundwater contamination. Currently investigations are ongoing under
NJDEP authority at this portion of the Site.
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Sea Box Landfill
The Sea Box Landfill (formerly owned by the Hoeganaes Corporation and now owned by 1001
Taylors Lane LLC, a subsidiary of Sea Box, Inc.) is located between the intersection of River
Road, Union Landing Road, and the Delaware River, approximately one-half mile southwest of
the main Sea Box, Inc. manufacturing facility. The approximate 400 feet by 2,300 feet (35 acres)
landfill was constructed on land surface and partially on Delaware River dredge spoils material.
Prior to 1975, the material disposed of at the landfill reportedly consisted of wastes comprised of
coke/lime iron oxide powder, and slag. From 1975 until 1985, coke/lime slurry, iron dust, slag,
and electric arc furnace (EAF) dust was disposed of in the landfill. Reportedly, slag has not been
disposed of in the landfill since 1982, and EAF dust has not been disposed of in the landfill since
1985. From 1982 through December 2000, slag generated from the EAF process was handled in
the south area of the Sea Box property by International Mill Services, Inc. for metals reclamation
and beneficial reuse.
TCE has been detected in groundwater samples collected at the Sea Box landfill since 1984. The
highest TCE concentration of 130 micrograms per liter (j_ig/l) (November 1988) was detected in a
monitoring well located along the southern property line of the landfill. Groundwater samples
collected by Linde, Inc. on April 28, 2004 show TCE was not detected from a groundwater sample
collected at the water table, and TCE was detected at 120 jag/1 in a groundwater sample collected
from a zone above the clayey saprolite. TCE was detected in groundwater samples collected from
monitoring wells on the Sea Box Landfill property at concentrations ranging from below the limit
of detection to 36 jag/1.
Although low concentrations of VOC contamination occur in groundwater at this landfill, it was
not found to be as a significant source of OU4 groundwater contamination.
3. HIGHLIGHTS OF COMMUNITY PARTICIPATION
On September 17, 2020, EPA released a Proposed Plan for the cleanup of OU4 contaminated
groundwater to the public for comment. The Proposed Plan and supporting documentation
comprising the administrative record were made available to the public at EPA's website for the
Site at https://www.epa.gov/superfund/cinnaminson. EPA published notice of the start of the
public comment period and the availability of the above-referenced documents in the Burlington
County Times on September 17, 2020. A copy of the public notice published in the Burlington
County Times can be found in Appendix V. EPA established the public comment period on the
Proposed Plan from September 17, 2020 through October 16, 2020. A request for an extension to
the public comment period was received by EPA, and a 30-day extension was granted. The public
comment period ended on November 16, 2020.
On October 1, 2020, EPA held a virtual public meeting to inform officials and community
members about the Superfund process, to present the Proposed Plan for the cleanup of
contaminated groundwater at OU4, including EPA's preferred remedial alternative and the other
alternatives, and to respond to questions and comments from the attendees. Responses to the
questions and comments received at the public meeting and in writing during the public comment
period are included in an attached Responsiveness Summary (See Appendix V).
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4.
SCOPE AND ROLE OF RESPONSE ACTION
EPA is addressing the cleanup of the Site in four phases or OUs, which address source areas and
groundwater contamination that originated from contributing source areas. This ROD is for OU4
which addresses groundwater contamination within the Site that is not currently being addressed
in other OUs. OU1, in accordance with the September 1990 Record of Decision, consisted of
remediating contaminated groundwater primarily emanating from the SLI Landfills. OU1 is
currently undergoing long-term monitoring. OU2 addressed the source area contamination at the
SLI landfills. After SCH's design, construction and monitoring of an enhanced landfill gas
management system and drainage improvements, the OU2 ROD was issued in July 2014. The
ROD determined that no further remedial action was necessary for OU2 to ensure protection of
human health and the environment. OU3 is currently undergoing an RI/FS by the PRP, Messer
(formerly Linde). Previous investigations showed that groundwater is impacted by VOCs, which
were consistently detected in groundwater samples both on, off, and downgradient of the Messer
property. The distribution of the VOCs show source(s) of VOCs in the OU3 area, and groundwater
containing VOCs flows both to the northwest, where it potentially discharges to the Delaware
River, and the southeast, where it mixes with VOCs from OU1 and other sources. Groundwater
contamination migrating northwest will be addressed as part of OU3, while contamination
migrating to the southeast is included as part of OU4.
This ROD is expected to be the final action for OU4.
The primary objectives of the action set forth in this ROD are to prevent or minimize exposure to
the contaminated groundwater, to restore the groundwater to its most beneficial use by reducing
contaminants to meet remedial goals, and to minimize the migration of contaminants.
5. SUMMARY OF SITE CHARACTERISTICS
Physical Setting
Based on the 2010 U.S. Census data, there were 15,569 and 16,896 people living in Cinnaminson
and Delran Townships, respectively. The Site is bounded by undeveloped land, a light industrial
area and Taylors Lane to the north, Union Landing Road to the south, a wooded and light industrial
area to the east and a heavy industrial area to the west. The surrounding area consists of a mixture
of retail, residential and light-to-heavy industrial properties. The land use in the OU4 study area is
predominantly used for residential, industrial/commercial, transportation and recreational
purposes.
The highest elevation in the OU4 study area is in the vicinity of Taylors Lane and U.S. Route 130
(approximately 90 feet above mean sea level (msl)), and the lowest elevation in the OU4 study
area is near the Delaware River (approximately 5 feet above msl). Overland runoff during
precipitation events is generally directed radially away from the topographic high at U.S. Route
130 with runoff flowing towards Pompeston Creek, Swedes Run, and the Delaware River.
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Site Geology/Hydrogeology
The Site is located within the Coastal Plain physiographic province in New Jersey. Most of the
OU4 study area is underlain by the Potomac Raritan and Magothy (PRM) Formation which
overlies the Wissahickon Formation (bedrock) in the south and eastern portion of OU1 and OU3.
The PRM Formation forms a southeasterly sloping wedge of sediments that extends from land
surface to over 375 feet deep at the downgradient southwest end of the OU4 study area. No
regionally extensive clay layers were encountered during drilling of the OU4 RI borings that
extended to bedrock. The unconsolidated sediments of the Pennsauken Formation are present in
the north and western portion of the OU3 area. The thickness of the Pennsauken Formation ranges
from a few feet to approximately 30 feet at the OU3 area along Union Landing Road.
Hydrogeology - The two unconsolidated geologic formations, PRM and Pennsauken, described
above, are water saturated forming one hydraulically connected aquifer called the PRM aquifer.
Groundwater level measurements and the distribution of groundwater contaminants show
groundwater in the Pennsauken and PRM Formations are hydraulically connected, allowing
groundwater and groundwater contaminants to migrate from the Pennsauken Formation into the
PRM Formation. NJDEP classifies the PRM/Pennsauken aquifer as Class IIA, meaning it is a
potential drinking water aquifer and/or is currently used as a drinking water supply. The
PRM/Pennsauken aquifer is also within an NJDEP Critical Water Supply Area meaning that the
amount of groundwater that can be withdrawn is regulated by the NJDEP due to pumping of the
aquifer for municipal, commercial and agricultural purposes. The impact of the pumping is
apparent considering that the natural hydraulic gradient within OU4 was historically from
southeast to northwest with groundwater ultimately discharging to the Delaware River. This is
evident in the United States Geological Survey's pre-pumping groundwater potentiometric surface
map from 1900. However, groundwater pumping in the area has reversed the natural groundwater
flow direction, causing groundwater to migrate predominately from the northwest to the southeast
towards municipal, industrial and irrigation wells as indicated in water elevations collected during
the OU4 RI.
Surface Water- OU4 lies within the Delaware River, Pompeston Creek, and Swedes Run
watersheds. The section of the Delaware River at OU4 lies to the northwest of the Site and flows
in a northeast to southwest direction. Pompeston Creek has two branches (East and West) whose
headwaters both begin in Moorestown, NJ and flow northwest through Cinnaminson and Riverton,
NJ to the Delaware River. Swedes Run is located north of the OU4 study area and drains an area
approximately 3.6 square miles from Moorestown in a southeast to northwest direction into the
Delaware River. Swedes Lake is located to the northeast of the Site.
NJDEP classifies the entire length of Pompeston Creek as fresh water, non-trout waters (FW2-
NT), with the exception of the tidal marsh portion from the U.S. Route 130 Bridge to Broad Street
Bridge in Riverton Township. This tidal marsh is classified as a Category 1 water body (FW2-
NT(C1).
The wetland near Pompeston Creek varies in width from 20 to over 800 feet. The water in the
wetland is greatly influenced by Delaware River tidal fluctuations. The Swedes Run wetland
habitat varies in width from 100 to over 600 feet. Similar to Pompeston Creek, the water in the
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Swedes Run wetland area is influenced by the Delaware River tide fluctuations. Based on a
consultation from United States Fish & Wildlife Service (USFWS), there are no threatened,
endangered, and candidate species and no critical habitat identified at the Site.
Summary of the OU4 Remedial Investigation
The OU4 RI included the following work:
Installation of Temporary Well Points
In 2014, 20 Hydropunch® groundwater samples were collected from 20 boring locations as a part
of the OU4 RI (see Figure 3).
In 2019, 72 groundwater samples were collected from 13 Geoprobe® borings between River Road
and the Delaware River (see Figure 4). Groundwater samples were collected at five-foot intervals
from the water table to weathered bedrock (saprolite) from each boring and analyzed for VOCs.
The purpose of the investigation was to further evaluate the contributing sources to groundwater
contamination north of the Messer property including the residential area where VI is also under
investigation/mitigation as part of OU3.
Groundwater Monitoring Well Installation
Sixty-one groundwater samples were collected from 45 monitoring wells as part of the OU4 RI.
(See Figure 5) These monitoring wells were located across the OU4 study area. Additional
groundwater samples were collected from 16 of the 45 monitoring wells to support contaminant
characterization. The data collected from this sampling, in addition to historic data, were used to
determine the nature and extent of OU4 groundwater contamination and evaluate the contribution
from sources associated with OU4.
Soil Samples - Sixty-one soil samples were collected from the unsaturated (vadose) and saturated
zone and analyzed for VOCs during monitoring well installation. Thirty-eight of the 61 samples
were from the unsaturated zone and 23 samples were collected from the saturated zone. These
samples were collected to determine if groundwater monitoring well installation locations were
source areas or not.
Sediments - Ten samples were collected to characterize the sediments in Pompeston Creek and
Swedes Run. The sediment samples were collected to determine if sediment was contaminated by
discharge of groundwater to surface water.
Surface Water Samples -Nine surface water samples were collected to characterize surface water
at the Site and to determine if the OU4 contaminated groundwater is discharging to surface water.
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NATURE AND EXTENT OF CONTAMINATION
Hydropunch®/Geoprobe® Groundwater Sample Results
Twenty groundwater samples were collected using a Hydropunch® sampler in 2014. (See Figure
6) These groundwater samples showed benzene was detected at a level of 6.2 jag/1, which exceeds
its chemical-specific screening level (SSL) of 1 [j.g/1 at a depth of200 feet in one of the 20 samples.
PCE was detected at a concentration of 6.6 jag/1, exceeding its SSL of 1 [j.g/1 at a depth of 41 feet
in only one of the 20 samples. TCE was detected in six of the 20 samples collected exceeding its
SSL of 1 [j.g/1 at concentrations ranging from 5.1 j_ig/l to 62 j_ig/l.
Seventy-two groundwater samples were collected using a Geoprobe® sampler in 2019. This
groundwater sampling data indicates that 36 groundwater samples contained VOCs above their
respective SSLs. The concentration of TCE ranged from nondetect (ND) to 220 |ig/l. The
distribution of TCE in groundwater collected from these borings shows the TCE present in
groundwater located north of the Messer property (OU3) is coming from the Messer facility. (See
Figure 7)
Groundwater Monitoring Well Sampling Results
Volatile Organic Contaminants - VOCs were detected in groundwater samples collected from 41
of the 45 monitoring wells (55 of 61 groundwater samples) during the May 2017 sampling event.
VOCs were detected at concentrations above the SSLs in 25 out of the 45 monitoring wells (36 of
61 samples) during that sampling event.
Below is a summary of the eight most frequently detected VOCs in groundwater:
TCE was detected in 48 out of the 61 groundwater samples and exceeded its SSL of 1 (_ig/l in 33
samples. The concentrations of TCE detected in the samples range from 0.2J to 760 jag/l.
PCE was detected in 40 out of the 61 groundwater samples and exceeded its SSL of 1 (_ig/l in 22
samples. The concentrations of PCE detected in the samples range from 0.2J to 20 jag/l.
cis-l,2-DCE was detected in 42 out of the 61 groundwater samples and exceeded its SSL of 70
[j.g/1 in only one sample. The concentrations of cis-l,2-DCE detected in the samples range from
0.17J to 200 j_ig/l.
VC was detected in 28 out of the 61 groundwater samples and exceeded its SSL of 1 (_ig/l in 10
samples. The concentration of VC detected in the samples range from 0.14 to 5.6 jag/l.
1.1-DCE was detected in 25 out of the 61 groundwater samples and exceeded its SSL of 1 (J.g/1 in
10 samples. The concentrations of 1,1- DCE detected in the samples range from 0.18J to 64 jag/l.
1.2-dichloropropane was detected in 21 out of the 61 groundwater samples and exceeded its SSL
of 1 [j,g/l in five samples. The concentrations of 1,2- dichloropropane detected in the samples range
from 0.16 to 2.2 j_ig/l.
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1,2-DCA was detected in 20 out of the 61 groundwater samples and exceeded its SSL of 2 jag/1 in
eight samples. The concentrations of 1,2- DC A detected in the samples range from 0.24 to 7.1 jag/1.
Chloroethane was detected in 11 out of the 61 groundwater samples and exceeded its SSL of 5
[j.g/1 in only one sample. The concentrations of chloroethane detected in the samples range from
0.15 to 7.8 [j,g/l.
These data show that TCE and PCE are the most significant groundwater contaminants detected
within the OU4 study area. The majority of the remaining VOCs detected (e.g., cis-l,2-DCE, 1,1-
DCE, and VC) in groundwater are likely the direct or indirect result of degradation of TCE/PCE
resulting from the contaminated groundwater interacting with septic waste or landfill conditions
that result in biotic and/or abiotic degradation. Some of the source areas of TCE and PCE also
contain other contaminants (e.g., benzene, methylene chloride, chloroform, and 1,2-
dichloropropane), which have contributed to groundwater contamination.
Semi-Volatile Organic Compounds - Sixty-one groundwater samples, collected from 45
monitoring wells, were analyzed for SVOCs. Only one SVOC contaminant, 1,4-dioxane, was
detected in 22 of 45 monitoring wells or 38 of 61 samples. 1,4- dioxane was detected in 17 samples
above its SSL of 0.4 jag/l. The highest concentration of 1,4- dioxane was detected in EPAC-6S at
120J (j,g/l. Although detected in 17 samples above its SSL, the mean concentration is
approximately 10 j_ig/l and the median concentration is approximately 1 |ig/l, indicating that there
is not a large 1,4-dioxane plume present. 1,4-dioxane is considered a Site-related contaminant as
it is often used as a solvent (PCE/TCE) stabilizer.
Pesticides/PCBs -Two pesticides (Beta BHC and Dieldrin) were detected above their SSLs.
Dieldrin was present in two of the 61 samples. Dieldrin was detected in the two samples collected
from OU4 MW-2S at concentrations of 0.045 |ig/l and 0.046 |ig/l, slightly, above its SSL of 0.03
|ig/l. Beta BHC was detected at 0.15J |ig/l in one sample. These pesticides are not considered Site-
related contaminants as they were not detected in groundwater samples collected from the source
areas, and the detection at a single location above the SSLs is not indicative of a significant point
source of contamination. No PCBs were detected in any of the groundwater samples collected
from monitoring wells above their SSL.
Metals - Aluminum, sodium, manganese, and iron were detected across OU4 in groundwater at
concentrations that exceeded their respective SSLs. Aluminum was detected in 59 of the 61
groundwater samples collected during the OU4 RI. The concentration of aluminum ranged from
ND to 1,300 |ig/l. Sodium was detected in all 61 groundwater samples collected during the OU4
RI. The concentration of sodium ranged from 4,100 to 230,000 jj.g/1. Manganese was detected in
all 61 groundwater samples collected during the OU4 RI. The concentration of manganese ranged
from 19 to 5,800 jj.g/1. Iron was detected in 57 of the 61 groundwater samples collected during the
OU4 RI. The concentration of iron ranged from ND to 69,000 jj.g/1. These metals are regulated as
secondary taste and quality contaminants and are generally considered to be naturally occurring.
Antimony, barium, cadmium, calcium, chromium, copper, lead, magnesium, mercury, potassium,
selenium, silver, thallium, vanadium, and zinc were not detected above their respective SSLs.
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Antimony, cadmium, selenium, and thallium were not detected in any of the 61 groundwater
samples collected as part of the OU4 RI.
Arsenic was detected in 9 of the 61 groundwater samples at concentrations that range from 1 to 38
ug/1. The concentration of arsenic exceeded its SSL of 3 |ig/l in 1 groundwater sample. Beryllium
was detected in 12 of the 61 groundwater samples at concentrations that ranged from 1.1 to 3.8
(a,g/l. The concentration of beryllium exceeded its SSL of 1 (_ig/l in all 12 of the groundwater
samples. Cobalt was detected in 60 of the 61 groundwater samples at concentrations ranging from
1.2 to 190 [j.g/1; however, only one sample contained cobalt above its SSL of 100 jag/1. Arsenic and
cobalt were detected above their respective SSLs in one groundwater sample.
Soil Sample Results
Soil samples were collected from the unsaturated (vadose) and saturated zones during the OU4 RI.
Sixty-one soil samples were analyzed for VOCs. Thirty-eight samples were collected from the
unsaturated zone and 23 samples were collected from the saturated zone.
Soil sample analytical results confirmed that wells were not placed in contaminated soil that could
have caused false positive groundwater contamination results. No additional soil source areas were
discovered during this soil sampling throughout the plume area. The three identified source areas
have been or will be addressed as part of separate actions.
Sediment Sample Results
Ten samples were taken to characterize the sediments in Pompeston Creek and Swedes Run. A
number of SVOCs and metals that were detected in these samples are not Site-related and are likely
the result of runoff. This is supported by the fact that the concentrations of SVOCs and metals in
the continuous portion of Pompeston Creek are similar to the concentrations of SVOCs and metals
in the intermittent portions of Pompeston Creek. No VOCs were detected above their SSLs in any
of the 10 sediment samples.
Surface Water Sample Results
VOCs - VOCs (TCE and cis-l,2-DCE) were detected in one surface water sample. TCE was
detected at 14 |ig/l which exceeds its SSL of 1 |ig/l. Cis-1,2-DCE was detected at 8.1 J jj.g/1.
SVOCs - One SVOC, (bis(2-ethylhexyl)phthalate), was detected in one of the eight surface water
samples analyzed for SVOCs. Bis(2-ethylhexyl) phthalate was detected at 2 J |ig/l, which is above
its SSL of 1 |ig/l. The surface water samples were not analyzed for pesticides or PCBs.
Metals- Metals were detected in all nine surface water samples collected from locations within
Pompeston Creek and Swedes Run. Metals detected were arsenic (4.8 - 20.2 ju.g/1), barium (20.3
- 630 ju.g/1), cadmium (0.63 - 4.6 ju.g/1), total chromium (0.62 - 101 ju.g/1), cobalt (4 - 46.4 ju.g/1),
lead (31.9 - 326 ju.g/1), mercury (0.063 - 0.54 ju.g/1), and vanadium (128 ju.g/1). Metals detected in
these samples are not Site-related and are the result of runoff. This is supported by the fact that the
concentration of metals in the surface water and/or sediment in the continuous portion of
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Pompeston Creek are similar to the concentration of metals in the intermittent portions of
Pompeston Creek.
Groundwater Impacts to Surface Water - The OU4 RI results show groundwater containing low
concentrations of PCE and TCE (for example, a PCE level of 1.7 |ig/l at OU4 MW-3I and a TCE
level of 1.6 jj.g/1 at OU4 MW-8D) is migrating with groundwater flow from the Messer and Detrex
properties towards and potentially discharging to Pompeston Creek
OU4 RI Major Conclusions
• Soil samples collected during OU1 and OU3 RI activities, as well as from sampling at the
Detrex property conducted under NJDEP programs, and groundwater samples collected
during the OU4 RI and during OU1, OU3 and Detrex sampling activities, indicate VOCs
were released to the unconsolidated soils at the three identified source areas and have
impacted underlying groundwater. The three properties identified as primary source areas
for the Site (and for OU4) are: the SLI Landfills, the Messer property, and the Detrex
property. These data also show each of the three primary source areas has contributed to a
large comingled groundwater plume comprised of elevated levels of VOCs.
• Groundwater in the Pennsauken/PRM aquifer historically flowed to the northwest
discharging to the Delaware River. However, pumping of groundwater by municipal,
industrial, and irrigation wells has reversed the regional groundwater flow direction to the
southeast.
• Groundwater in the northern/northwestern portion of OU3 flows towards the
northwest and potentially discharges to the Delaware River in a similar manner as
historical groundwater flow.
• Some shallow groundwater at the Detrex property and in the western portion of the
Messer property flows towards the west and potentially discharges to Pompeston Creek.
(See Figure 8)
• Groundwater beneath the SLI Landfills, the central and southern portions of the Messer
property and the Detrex property flows to the southeast.
• Groundwater containing VOC contamination migrates from the identified source areas to
the southeast and forms a comingled plume, creating a roughly 2-mile long plume of
contaminated groundwater. As the soluble contaminants move from source areas
downgradient, the elevated levels of contamination go deeper into the aquifer to depths of
up to 375 feet below ground surface. (See Figure 8)
• At this time, all active supply wells in the vicinity of the Site are treated to meet federal
and state drinking water standards before distribution due to the regional groundwater
contamination.
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• Surface water containing VOCs poses no elevated risk to human health or ecological
receptors. Elevated SVOCs and metals in surface water and sediment are not Site-related.
These contaminants are common in runoff in suburban settings.
• While unsaturated soils sampled as part of OU4 contain SVOCs and metals above the
SSLs, these contaminants were not detected at source areas and therefore are not
considered related to the Site.
6. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Use
The Site is bounded by undeveloped land, a light industrial area and Taylors Lane to the north,
Union Landing Road to the south, a wooded and light industrial area to the east and a heavy
industrial area to the west. The surrounding area consists of a mixture of retail, residential and
light-to-heavy industrial properties. The land in the OU4 study area is predominantly used for
residential, industrial/commercial, transportation and recreational purposes.
EPA anticipates that the future land use will not change from its present scenario.
Groundwater Use
Groundwater in OU4 is identified as Class IIAby theNJDEP. Class IIA groundwater is typically
used for drinking water with conventional water supply treatment. OU4 is also within NJDEP
Water Supply Critical Area No. 2. This designation is given to portions of the aquifer where
additional aquifer withdrawals are not allowed, except in accordance with the Water Supply
Management Act.
A well search was completed with the NJDEP to locate municipal, industrial, and irrigation wells
within a one-mile radius of OU4. The results include wells with a permitted capacity of 50 gallons
per minute (gpm) or greater.
NJAW owns 13 water supply wells within a one-mile radius of the Site. There are nine irrigation
wells within a one-mile radius that have a permitted capacity of 50 gpm or greater. There are 4
industrial wells within a one-mile radius of OU4 with a permitted capacity of 50 gpm or greater.
Groundwater analytical data (raw water) collected from January 2014 to September 2016, obtained
from NJAW for Pomona Road Well No. 12 located near the Site, show the presence of PCE, TCE,
and 1,1-DCE in concentrations above either the state or federal drinking water standards. No
groundwater results were available for the New Albany Road well(s) that are no longer in
operation. Groundwater analytical results are provided in the OU4 RI Report. All public supply
wells with exceedances of standards are treated to drinking water quality prior to distribution.
Because the aquifer has a special designation as a NJ Critical Water Supply Area, that status has
been part of the decision-making regarding the remediation at the Site.
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There are nine additional municipal water supply wells located downgradient and potentially
threatened by OU4 groundwater contamination. These wells include: Maple Shade Wells 2, 8A,
9, 10, & 11; Moorestown Wells 3, 5, & 6; and Mount Laurel MUA Well 6.
7. SUMMARY OF SITE RISKS
As part of the RI/FS, EPA conducted a baseline risk assessment to estimate the current and future
effects of contaminants on human health and the environment. A baseline risk assessment is an
analysis of the potential adverse human health and ecological effects of releases of hazardous
substances from a site in the absence of any actions or controls to mitigate such releases, under
current and future land uses. The baseline risk assessment includes a human health risk assessment
(BHHRA) and an ecological risk assessment (BERA). It provides the basis for taking action and
identifies the contaminants and exposure pathways that need to be addressed by the remedial
action. This section of the ROD summarizes the results of the baseline risk assessment for OU4.
Human Health Risk Assessment
A four-step process is utilized for assessing Site-related human health risks for a reasonable
maximum exposure scenario:
• Hazard Identification - uses the analytical data collected to identify the contaminants of
potential concern (COPC) 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 by which
humans are potentially exposed;
• 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 acceptable
levels, defined by the NCP as an excess lifetime cancer risk greater than 1 x 10"6 - 1 x 10"
4 or a Hazard Index greater than 1; contaminants at these concentrations are considered
contaminants 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, COPCs in each medium were identified based on such factors as toxicity, frequency
of occurrence, fate and transport of the contaminants in the environment, concentrations, mobility,
persistence and bioaccumulation. The BHHRA began with selecting COPCs in various media
(i.e., groundwater, soil, sediment and surface water) that could potentially cause adverse effects in
exposed populations. COPCs are selected by comparing the maximum detected concentrations of
each chemical identified with state and federal risk-based screening values. The COPC screening
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conducted in the BHHRA identified 42 COPCs, including VOCs, SVOCs, pesticides, PCBs and
inorganics. COPCs not considered to be Site related or at concentrations similar to background are
carried through the quantitative portion of the BHHRA but not identified as primary COPCs (i.e.,
COCs) for the Site. A comprehensive list of all COPCs can be found in the BHHRA in the
administrative record. Only Site-related chemicals exceeding risk and hazard thresholds, known
as COCs, are included in Table 1.
Exposure Assessment
Consistent with Superfund policy and guidance, the BHHRA assumes no remediation or
institutional controls to mitigate or remove hazardous substance releases. Cancer risks and
noncancer hazard indices were calculated based on an estimate of the reasonable maximum
exposure (RME) expected to occur under current and future conditions at the Site. The RME is
defined as the highest exposure that is reasonably expected to occur at a site.
The Site, which covers approximately 400 acres, includes residential, commercial and industrial
properties. It is bounded to the southwest by Pompeston Creek which can be used for recreational
activities such as swimming or wading. Based on the current zoning and land use, the BHHRA
evaluated residential, commercial and recreational uses of the Site.
Based on the current and anticipated future land uses described above, the following exposure
populations and pathways were evaluated under the current and future land use scenarios:
Residents (child [0-6 years]/adult): ingestion, dermal contact and inhalation of
groundwater while showering/bathing and for surface soil, ingestion, dermal contact and
inhalation of volatilized constituents and particulates in air.
Worker (adult): ingestion and dermal contact with groundwater and for surface soils,
ingestion, dermal contact and inhalation of volatilized constituents and particulates in air.
Recreator (child [0-6 years]/adult): ingestion and dermal contact with surface water and
sediment while visiting Pompeston Creek.
A summary of all the exposure pathways considered in the BHHRA can be found in Table 2.
Typically, exposures are evaluated using a statistical estimate of the exposure point concentration,
which is usually an upper bound estimate of the average concentration for each contaminant, but
in some cases may be the maximum detected concentration. A summary of the exposure point
concentrations for the COCs in groundwater can be found in Table 1, while a comprehensive list
of the exposure point concentrations for all COPCs can be found in the BHHRA.
The potential for VI is being investigated as part of OU3 of the Site, and, hence, VI was not
addressed in the BHHRA for OU4.
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
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developing cancer over a lifetime or other noncancer health effects, such as changes in the normal
functions of organs within the body (e.g., changes in the effectiveness of the immune system).
Some contaminants are capable of causing both cancer and noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncarcinogenic hazards
due to exposure to site chemicals are considered separately. Consistent with current EPA policy,
it was assumed that the toxic effects of the Site-related chemicals would be additive. Thus, cancer
and noncancer risks associated with exposures to individual COPCs were summed to indicate the
potential risks and hazards associated with mixtures of potential carcinogens and noncarcinogens,
respectively.
Toxicity data for the human health risk assessment were obtained from the Integrated Risk
Information System (IRIS) database, the Provisional Peer Reviewed Toxicity Database (PPRTV),
or another source that is identified as an appropriate reference for toxicity values consistent with
EPA's directive on toxicity values. This information is presented in Table 3 (noncarcinogenic
toxicity data summary) and Table 4 (cancer toxicity data summary). Additional toxicity
information for all COPCs is presented in the BHHRA.
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 estimated intake of chemicals identified in
environmental media (e.g., the amount of a chemical ingested from contaminated drinking water)
is compared to the RfD or the RfC to derive the hazard quotient (HQ) for the contaminant in the
particular medium. The HI is obtained by adding the HQs for all compounds within a particular
medium that impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as below. The HQ for inhalation exposures is
calculated using a similar model that incorporates the RfC, rather than the RfD.
HQ = Intake/RfD
Where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period (i.e., chronic, subchronic, or
acute).
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As previously stated, the HI is calculated by summing the HQs for all chemicals for likely exposure
scenarios for a specific population. An HI greater than 1 indicates that the potential exists for
noncarcinogenic health effects to occur as a result of Site-related exposures, with the potential for
health effects increasing as the HI increases. When the HI calculated for all chemicals for a
specific population exceeds 1, separate HI values are then calculated for those chemicals which
are known to act on the same target organ. These discrete HI values are then compared to the
acceptable limit of 1 to evaluate the potential for noncarcinogenic health effects on a specific target
organ. The HI provides a useful reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
A summary of the noncarcinogenic hazards associated with those receptors that exceeded the
threshold value of 1 are shown in Table 5. The hazard index for the child resident (42), adult
resident (39) and adult site worker (3.9) exceeded 1. Exposure to TCE in groundwater contributed
to the majority of the hazard.
For carcinogens, risks are generally expressed as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to a carcinogen, using the cancer slope
factor (SF) for oral and dermal exposures and the inhalation unit risk (IUR) for inhalation
exposures. Excess lifetime cancer risk for oral and dermal exposures is calculated from the
following equation, while the equation for inhalation exposures uses the IUR, rather than the SF:
Risk = LADD x SF
Where: Risk = a unitless probability (1 x 10"6) of an individual developing cancer
LADD = lifetime average daily dose averaged over 70 years (mg/kg-day)
SF = cancer slope factor, expressed as [1/(mg/kg-day)]
These risks are probabilities that are usually expressed in scientific notation (such as 1 x 10"4). An
excess lifetime cancer risk of 1 x 10"4 indicates that one additional incidence of cancer may occur
in a population of 10,000 people who are exposed under the conditions identified in the assessment.
As stated in the NCP, the acceptable risk range for site-related exposure is 10"6 to 10"4.
As shown in Table 6, the estimated cancer risk for the child/adult resident of 8.5xl0"4 exceeded
the upper-bound of EPA's threshold criteria of lxlO"6 to lxlO"4, predominantly attributable to
exposure to TCE and chloroform in groundwater. In addition, estimated cancer risks for the
child/adult recreator of 7xl0"4 exceeded EPA's threshold criteria. This risk was driven by exposure
to chromium in surface water which was conservatively evaluated as hexavalent chromium in the
BHHRA. Chromium was not retained as a COC as it is not believed to be Site-related. In addition,
cancer risks estimated for the adult site workers were within the acceptable risk range established
by the NCP.
In summary, the results of the BHHRA indicated that potable use of groundwater at the Site would
result in exceedances of EPA's target threshold values due to the presence of elevated levels of
VOCs (namely TCE and chloroform) in groundwater. The presence of elevated metals, such as
arsenic, chromium, and cobalt in groundwater, however, is unrelated to the Site. Therefore, TCE
and chloroform in groundwater are the primary Site-related chemicals contributing to elevated risk
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and hazard in 0U4. The were no unacceptable risks or hazards from exposure to OU4 soils.
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.
Uncertainties in the exposure assessment are related to estimates of how often an individual would
actually come in contact with the COCs, the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the contaminants of concern at the point
of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from
high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture
of chemicals. These uncertainties are addressed by making conservative assumptions concerning
risk and exposure parameters throughout the assessment. As a result, the risk assessment provides
upper-bound estimates of the risks to populations near the Site and is highly unlikely to
underestimate actual risks related to the Site.
More specific information concerning public health risks, including a quantitative evaluation of
the degree of risk associated with various exposure pathways, is presented in the risk assessment
report.
Screening Level Ecological Risk Assessment
A Screening Level Ecological Risk Assessment (SLERA) was prepared to evaluate potential risks
to aquatic and terrestrial ecological receptors from exposure to contaminants in soil, sediment,
surface water and groundwater (for surface water impacts). COPC screening identified a total of
40 COPCs, including those in soil, surface water, sediment and groundwater. The potential
ecological exposure scenarios considered in the SLERA included ingestion or dermal contact with
surface water (also evaluated through groundwater), as well as incidental ingestion or dermal
contact with surface soil and sediment.
The SLERA evaluated risk to ecological receptors exposed to the maximum concentration of all
detected compounds. With the exception of cis-l,2-DCE, none of the VOCs were identified as
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COPCs because the concentrations in groundwater, sediment soil and surface water are ND or
below the ecological screening criteria. Cis-1,2- DCE in surface water and groundwater is a COPC
only because no screening criteria are available; however, its concentrations of 8.1 |ig/L in surface
water and 1.4 |ig/L in groundwater are well below the trans-l,2-DCE criterion of 970 |ig/L. The
volatility of cis-l,2-DCE and limited potential to bioaccumulate indicate it likely does not pose a
substantial ecological hazard.
The SLERA indicated a potential ecological risk from exposure to SVOCs and inorganics in
surface soil, sediment, surface water and groundwater. However, these substances are not
considered to be Site-related. Based on the above information, there are no ecological-based COCs
identified for OU4.
Basis for Taking Action
Based on the results of the RI/FS and the risk assessment, EPA has determined that the response
action selected in this ROD is necessary to protect the public health, welfare and the environment
from actual or threatened releases of hazardous substances into the environment.
8. REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to protect human health and the
environment. They serve as the basis for developing remedial action alternatives and specify what
the cleanup action will accomplish. These objectives are based on available information and
standards, such as Applicable or Relevant and Appropriate Requirements (ARARs), requirements
to-be-considered (TBC), and site-specific, risk-based levels established using the risk assessments
described above. The process of identifying the RAOs follows the identification of affected media
and contaminant characteristics, evaluation of exposure pathways, contaminant migration
pathways and exposure limits to receptors.
The following RAOs have been developed for OU4:
• Reduce or eliminate further migration of groundwater containing Site-related contaminants
at concentrations greater than federal and state standards;
• Prevent future exposure (via ingestion, dermal contact, and inhalation) to Site-related
contaminants in groundwater at concentrations greater than federal and state standards; and
• Restore the impacted aquifer to its most beneficial use as a source of drinking water by
reducing Site-related contaminant levels to the most stringent of federal and state standards.
Remediation Goals
The remediation goals (RGs) for groundwater were developed for the COCs identified for OU4 at
the Site to aid in defining the extent of the contaminated media requiring remedial action, and to
assure that RAOs are met. RGs are generally chemical-specific goals for each medium and/or
exposure route that are established to protect human health and the environment. They can be
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derived from ARARs, risk-based levels (human health and ecological), and from comparison to
background concentrations, where applicable. The preliminary remediation goals (PRGs)
developed for OU4 for this Site were presented in the Proposed Plan issued in September 2020.
The PRGs, presented in the OU4 Proposed Plan, were based on the lowest of the relevant federal
MCLs, NJDEP MCLs, and NJDEP GWQS and are considered protective of the potential human
exposures associated with OU4. In addition to TCE and chloroform identified in the risk
assessment, the following contaminants are considered COCs because they exceed drinking water
standards and are site-related: 1,1- dichloroethane, 1,2-dichloroethane, 1,4-dichlorobenzene, 1,4-
dioxane, benzene, tetrachloroethene and vinyl chloride.
PRGs become final RGs when EPA selects a remedy, after taking into consideration all public
comments. EPA has selected the PRGs identified in the Proposed Plan as the RGs for OU4. These
RGs can be found in Appendix 2, Table 7.
9. DESCRIPTION OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9121(b)(1), mandates that remedial actions must be
protective of human health and the environment, cost-effective, and utilize permanent solutions
and 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 permanently and significantly at a site. Section 121(d)
further specifies that a remedial action must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants that at least meets ARARs under federal and state laws,
unless a waiver can be justified pursuant to Section 121(d)(4) CERCLA, 42 U.S.C. §9621(d)(4).
Detailed descriptions of the remedial alternatives presented in this ROD can be found in the FS
Report, dated September 4, 2020.
The construction time provided for each alternative presented below reflects only the time required
to construct or implement the remedy and does not include the time required to design the remedy,
negotiate the performance of the remedy with any potentially responsible parties, procure contracts
for design and construction, or operation and maintenance.
Alternative 1 - No Action
The No Action alternative is required by the NCP to be carried through the screening process.
Under this alternative, no action would be taken to remediate the contaminated groundwater. This
alternative would also not include Institutional Controls (ICs). Contaminants present in the
groundwater would remain in place.
The No Action alternative provides a baseline for comparison with other active remedial
alternatives. Because no remedial activities would be implemented under the No Action
alternative, long term human health and environmental risks would remain the same as those
identified in the BHHRA. There are no capital, operations/maintenance, or monitoring costs and
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no permitting or institutional legal restrictions needed, but this alternative will not meet the RAOs
established for groundwater.
Total Capital Cost $0
Total O&M Cost $0
Total Periodic Cost $0
Total Present Value $0
Time to Construct N/A
Alternative 2 - Institutional Controls
ICs, such as a Classification Exception Area/Well Restriction Area (CEA/WRA), would restrict
groundwater uses or activities which could result in direct contact with contaminated
groundwater. Due to the presence of contaminated groundwater, a NJDEP CEA/WRA would be
placed on OU4 impacted groundwater to restrict future groundwater use activities that would
expose users to contaminants at levels that may pose human health risk. A Pre-Design
Investigation (PDI) would be conducted to determine the area requiring the CEA/WRA. Long
Term Monitoring (LTM) would also be used as a basis for evaluating the terms of the CEA/WRA.
Although LTM of groundwater would be required until the aquifer was restored, for cost
estimating purposes, 30 years of groundwater sampling was used. Empirical groundwater flow
and solute transport data collected in the OU1 and OU4 studies/investigations were used in
analytical models (aquifer flushing and first-order decay) to estimate the period of performance
of each remedial alternative. The results of this effort indicated that for Alternative 2, the COCs
in the plume will continue to attenuate but concentrations are estimated to remain above RGs for
approximately 125 years. As a result of actions taken as part of other OUs, including a pump and
treat system (OU1), a landfill cap (OU2), future source control remediation at OU3, and future
Detrex source control remediation under NJDEP oversight, as well as the continuing attenuation,
this alternative would restore the aquifer to beneficial use in approximately 125 years. Five-Year
Reviews would be conducted until aquifer restoration is achieved.
Total Capital Cost $854,000
Total O&M Cost $2,293,000
Total Periodic Cost $504,000
Total Present Value $3,651,000
Time to Construct N/A
Timeframe 125 years
Common Elements for Active Remedial Action Alternatives 3 through 6
Alternatives 3 through 6 each include extraction and treatment of contaminated groundwater;
however, the design of each would use different extraction locations and groundwater extraction
volumes as described below. Each of these alternatives include ICs and LTM, as described in
Alternative 2 above. Alternatives 3 through 6 would require the performance of Five-Year
Reviews until aquifer restoration is achieved. In addition, Alternatives 3 through 6 have the
following common elements:
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Pre-Design Investigation (PDI)
Alternatives 3 through 6 each include a PDI. A PDI would typically include groundwater
screening, well installation and, as necessary, hydraulic testing, and sampling. Data collected
during the PDI would be used to better define the geochemistry and volumes of groundwater
needing treatment and help in the development of a remedial design of the remedy.
Treatment Process
The contaminated groundwater from each extraction well would be treated at one or more
treatment plants. It is assumed that land acquisition would be required for the construction of any
treatment plant. Although the ex-situ treatment options are similar for Alternatives 3 through 6,
treatment units would be sized depending on the total influent flow rate and water chemistry at
each treatment plant. The typical treatment process would likely include metals removal, removal
of VOCs by air strippers, vapor-phase Granulated Activated Carbon (GAC), advanced oxidation
processes (AOP), liquid-phase GAC, and 1,4-dioxane treatment.
The treatment process anticipated for purposes of costing is described below; however, treatment
requirements would be more fully determined during the remedial design. After treatment,
groundwater would be discharged to surface water. During remedial design, consideration would
also be given to reinjection of some or all of the treated groundwater into the underlying aquifer
if feasible. In addition, for Alternatives 3 through 6, operation and maintenance of the extraction
and treatment system would be performed for the life of the remedy.
Alternative 3 - Downgradient Hydraulic Capture and Discharge of Treated Water to
Surface Water
Alternative 3 includes hydraulic containment of the OU4 contaminated groundwater plume above
the RGs using pump and treat. The major components of Alternative 3 are:
•Installation of groundwater extraction wells at the distal end (furthest downgradient extent) of
the OU4 contaminated groundwater plume to establish hydraulic control;
•Centralized treatment plant with metals removal system, air stripping, vapor phase GAC
adsorption, liquid phase GAC adsorption, and 1,4-dioxane treatment; and
•Discharge of treated water to surface water in the vicinity of Burlington Pike and Palmyra Bridge
Rd.
Alternative 3 includes the installation of 3 extraction wells. The extraction wells would be
installed to a depth determined during the PDI and estimated to be approximately 300 feet below
ground surface (bgs). Each groundwater extraction well is estimated to remove approximately
600 gpm for a total of 1,800 gpm of groundwater. The final flow rate would be determined during
the PDI. The contaminated groundwater from each extraction well would be pumped to a single
centralized treatment plant. The treated water from the treatment plant would be discharged to
surface water in the vicinity of Burlington Pike and Palmyra Bridge Rd. It is estimated that the
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extraction and treatment system would be operated for a period of 100 years to meet groundwater
restoration goals. ICs and LTM would be implemented as part of this alternative.
Total Capital Cost $16,061,000
Total O&M Cost $31,799,000
Total Periodic Cost $1,796,000
Total Present Value $49,660,000
Time to Construct 2 years
Timeframe 100 years
The area treated would reach RGs in approximately 100 years and the downgradient area not
captured and treated by the extraction and treatment system would concurrently attain goals in
approximately 10 years. Therefore, the total remediation time is estimated to be 100 years.
Alternative 4 - Mid-Plume Groundwater Remediation and Discharge of Treated Water to
Surface Water
Alternative 4 includes extraction, treatment, and discharge of groundwater at the midpoint
(midway between the source areas and the furthest downgradient contaminated wells) of the OU4
contaminated groundwater plume and at the distal end of the plume to shorten the period of
performance of the remedy compared to Alternative 3. The major components of Alternative 4
are:
• Installation of groundwater extraction wells at the distal end of the OU4 contaminated
groundwater plume for hydraulic control;
• Installation of groundwater extraction wells at the mid-point of the OU4 contaminated
groundwater plume to shorten the period of performance of the remedy;
• Two treatment plants with metals removal system, air stripping, vapor phase GAC adsorption,
liquid phase GAC adsorption, and 1,4-dioxane treatment.
• The two treatment plants would be constructed near the extraction wells for the mid-point and
distal end of the OU4 contaminated groundwater plume;
• Discharge of treated water to surface water in the vicinity of Burlington Pike and Palmyra Bridge
Rd.
Alternative 4 includes the installation of 6 extraction wells. The extraction wells would be
installed to a depth determined during the remedial design which is estimated to be approximately
300 to 450 feet bgs. Each groundwater extraction well is estimated to remove approximately 600
gpm for a total extraction rate of 3,600 gpm. The final flow rate would be determined during the
remedial design. The treated water from the treatment plant would be discharged to surface water
in the vicinity of Burlington Pike and Palmyra Bridge Rd. It is estimated that the pump and treat
system would be operated for a period of 50 years to restore the aquifer. Extracted groundwater
would be conveyed via underground piping to the centralized treatment plants and from the
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treatment plants to the discharge location or locations. For cost estimating purposes, it is estimated
that approximately 26,100 linear feet of double-walled high-density polyethylene (HDPE) piping
and approximately 16,100 linear feet of single-walled HDPE piping would be required for
conveyance of the groundwater. It is estimated that two booster pump stations and one concrete
junction vault would be needed for discharging the treated water. ICs and LTM would be
implemented.
Total Capital Cost $30,382,000
Total O&M Cost $59,511,000
Total Periodic Cost $4,523,000
Total Present Value $94,416,000
Time to Construct 2-3 years
Timeframe 50 years
The area treated would reach RGs in approximately 50 years, and the downgradient area not
treated by the extraction and treatment system would concurrently attain goals in approximately
10 years. Therefore, the total remediation time is estimated to be 50 years.
Alternative 5 -Remediation of Higher-Concentrations (Core of the Plume) of the
Downgradient Plume and Discharge of Treated Water to Surface Water
Alternative 5 includes groundwater extraction and treatment in the higher concentration of the
downgradient portions (i.e., would not include installing groundwater recovery wells in the SLI
Landfills, Messer, and Detrex source areas) of the OU4 contaminated groundwater plume.
The major components of Alternative 5 are:
• Installation of groundwater extraction wells in the higher concentration of the
downgradient portions of the OU4 contaminated groundwater plume;
• Construction of a centralized treatment plant with metals removal system, air stripping,
vapor phase GAC adsorption, liquid phase GAC adsorption, and 1,4-dioxane treatment;
and,
• Discharge of treated water to surface water in the vicinity of Burlington Pike and Palmyra
Bridge Rd.
Alternative 5 includes the installation of an estimated 3 extraction wells. The extraction wells
would be installed to a depth determined during the remedial design, estimated to be
approximately 375 to 450 feet bgs. Each groundwater extraction well is estimated to remove
approximately 600 gpm for a total extraction rate of 1,800 gpm. The final flow rate would be
determined during the remedial design. The treated water from the treatment plant would be
discharged to surface water in the vicinity of Burlington Pike and Palmyra Bridge Rd. To meet
remediation goals, it is assumed that the extraction and treatment system would be operated for a
period of 75 years to restore the aquifer.
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Extracted groundwater would be conveyed via underground piping to the centralized treatment
plant and from the treatment plant to the discharge location. It is assumed that approximately
9,900 linear feet of double-walled HDPE piping and approximately 9,000 linear feet of single-
walled HDPE piping would be required for conveyance of the groundwater. Based on the
conceptual piping design for Alternative 5, one booster pump station would be needed for
discharging the treated water.
The extraction and treatment system would capture the higher concentration of the downgradient
plume. Further downgradient portions of the plume would not be captured and would be
sampled/analyzed to monitor reductions over time. ICs and LTM would be implemented.
Total Capital Cost $14,482,000
Total O&M Cost $31,799,000
Total Periodic Cost $1,796,
Total Present Value $48,077,000
Time to Construct 2 years
Timeframe 75 years
The area treated would reach RGs in approximately 75 years and the downgradient area not treated
by the extraction and treatment system would concurrently attain goals in approximately 10 years.
Therefore, the total remediation time is estimated to be 75 years.
Alternative 6 - Groundwater Remediation Near Source Areas and Discharge of Treated
Water to Surface Water
Alternative 6 includes groundwater remediation in the area of highest concentration of
groundwater contamination, located downgradient, and in close proximity of the groundwater
contaminant sources at the Messer and Detrex properties using extraction and treatment. The
groundwater in close proximity to the SLI Landfills is primarily being addressed in OU1. The
major components of Alternative 6 are:
• Installation of groundwater extraction wells near the OU4 contaminated groundwater
plume source areas;
• Construction of a centralized treatment plant with metals removal, air stripping, vapor
phase GAC adsorption, liquid phase GAC adsorption, and 1,4-dioxane treatment; and
• Discharge to surface water at Pompeston Creek.
Alternative 6 includes the installation of 4 extraction wells. (See Figure 9) The extraction wells
would be installed to a depth determined during the design estimated to be approximately 200 feet
bgs. Each groundwater extraction well is estimated to remove approximately 50 gpm, for an
estimated total extraction rate of 200 gpm. The final number, placement, and flow rate of
extraction wells would be determined during the remedial design. It is estimated that the extraction
and treatment system would be operated for 25 years. At that time, it is estimated that
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contaminated groundwater within the capture zone of Alternative 6 would have reached RGs.
Groundwater outside of the capture zone would reach RGs in approximately 65 years.
Extracted groundwater would be conveyed via underground piping to the centralized treatment
plant and from the treatment plant to the discharge location. For the purpose of estimating cost, it
is assumed that approximately 3,900 linear feet of double-walled HDPE piping and approximately
430 linear feet of single-walled HDPE piping would be required for conveyance of the
groundwater. (See Figure 10) The extraction and treatment system would capture the most highly
contaminated part of the groundwater plume, and the downgradient portion of the plume would
continue to migrate, and contaminant concentrations would reduce over time. ICs and LTM would
be implemented in the dilute, downgradient portion of the plume.
Total Capital Cost $6,595,000
Total O&M Cost $14,160,000
Total Periodic Cost $1,611,000
Total Present Value $22,366,000
Time to Construct 1-2 years
Timeframe 65 years
It is estimated the area treated will reach RGs in approximately 25 years and the downgradient
area not treated by the extraction and treatment system will concurrently attain goals in
approximately 65 years. Therefore, the total remediation time is approximately 65 years.
10. COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy for a site, EPA considers the factors set forth in Section 121 of CERCLA,
42 U.S.C. § 9621, and conducts a detailed analysis of the viable remedial alternatives in accordance
with the NCP, 40 C.F.R Section 300.430(e)(9), the EPA's Guidance for Conducting Remedial
Investigations and Feasibility Studies, OSWER Directive 9355.3-01, and the EPA's A Guide to
Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision
Documents, OSWER 9200.1-23.P. The detailed analysis consists of an assessment of the
individual alternatives set forth in the FS against each of the nine evaluation criteria set forth at
Section 300.430(e)(9)(iii) of the NCP and a comparative analysis focusing upon the relative
performance of each alternative against those criteria.
A comparative analysis of these alternatives, based upon the nine evaluation criteria noted below,
follows.
Threshold Criteria - The first two remedy selection 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.
Overall Protection of Human Health and the Environment
"Overall Protection of Human Health and the Environment" determines whether an alternative
eliminates, reduces, or controls threats to public health and the environment through institutional
controls, engineering controls, or treatment.
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Alternative 1 (No Action) would not meet the RAOs and would not be protective of human health
and the environment since no action would be taken.
Alternatives 2, 3, 4, 5, and 6 would provide protection of human health because the exposure
pathways to human receptors would be eliminated by restrictions placed on the use of groundwater
within the area of groundwater contamination. However, the different alternatives (Alternatives 2
through 6) would restore the aquifer in different timeframes. Empirical groundwater flow and
solute transport data collected in the OU1 and OU4 investigations were used in analytical models
(aquifer flushing and first-order decay) to estimate the period of performance of each remedial
alternative.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), and Section 300.430(j)(l)(ii)(B) oftheNCP, 40
C.F.R. § 300.430(j)(l)(ii)(B), require that remedial actions at CERCLA sites at least attain legally
applicable or relevant and appropriate federal and state requirements, standards, criteria, and
limitations, collectively referred to as "ARARs, " unless such ARARs are waived under Section
121(d)(4) of CERCLA. "Compliance with ARARs" addresses whether a remedy will meet all
ARARs or whether there is a basis for invoking a waiver.
Actions taken at any Superfund site must meet all ARARs under federal and state laws or provide
grounds for invoking a waiver of those requirements.
Alternative 1 would not comply with ARARs. Alternatives 3, 4, 5 and 6 are expected to be able to
meet action- and location-specific ARARs. Under Alternative 2, chemical-specific ARARs would
ultimately be achieved as a result of actions taken as part of other OUs, as well as attenuation.
Under Alternatives 3, 4, 5, and 6, chemical-specific capture and treatment of contaminated
groundwater would contribute to achieving chemical-specific ARARs in varying timeframes. In
the interim, the exposure pathways to human receptors would be eliminated by restrictions placed
on the use of groundwater within the area of groundwater contamination. Chemical-specific
ARARs for the COCs would be met under varying timeframes under each alternative, ranging
from 125 years for Alternative 2 to 50 years for Alternative 4. (See Tables 9, 10, 11)
Balancing Criteria
The next five criteria, criteria 3 through 7, ae 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.
Long-Term Effectiveness and Permanence
Long-term effectiveness andpermanence refer 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.
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Alternative 1 would not provide long-term effectiveness and permanence since groundwater
contamination would not be actively addressed. Alternative 2 would take approximately 125 year
to reach RGs, the longest timeframe of all the protective alternatives.
Groundwater extraction and ex-situ treatment under each of the Alternatives 3, 4, 5, and 6 is
considered an effective technology for addressing groundwater contaminated with COCs.
Alternatives 4 and 6 would provide the most long term effectiveness and permanence as they
would restore the aquifer faster than the other alternatives, in approximately 50 and 65 years,
respectively. Alternatives 3 and 5 have recovery wells located further from the source areas than
Alternative 6 and would result in longer times to restore the aquifer of 100 years and 75 years,
respectively.
Reduction of Toxicity, Mobility, or Volume (TMV) 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 1 (No Action) and Alternative 2 do not address the contamination through treatment,
so there would be no reduction in TMV. Alternatives 3, 4, 5, and 6 would reduce the TMV of
contaminants in the aquifer by using extraction wells to remove contaminated groundwater and by
treatment through air stripping, granulated active carbon, and AOP technologies.
Alternative 6 would target the portions of the plume with the highest COC concentrations and
would remove the largest amount of COCs for the least amount of groundwater pumping. In
addition, it would have the largest reduction in TMV measured as a percent of total mass reduction
of COCs. Alternatives 4 and 5 would remove the next largest amount of COCs for the amount of
groundwater pumped and would have the next largest reduction in TMV measured as a percent of
total mass reduction of COCs. Alternative 3 would remove the smallest amount of COCs and
would have the lowest reduction in TMV measured as a percent/ratio of total mass reduction
compared to the amount of groundwater removed as it targets the low COC concentrations at the
distal end of the plume. The reduction of toxicity and volume will be achieved by the treatment
processes and the destructive irreversibility of the treatment would be the same for Alternatives 3,
4, 5, and 6. Each of the Alternatives 3, 4, 5, and 6 rely on commonly used treatment technologies
to permanently destroy the contaminants once withdrawn from the aquifer.
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 1 would not have any short-term effectiveness or impacts since no action would be
implemented. Alternative 2 would result in the minimal short-term impacts, as it involves only
administrative work and no physical construction. Alternative 6 would have the least short-term
impacts to the local communities of the active treatment alternatives (Alternatives 3 through 6)
since the length of underground piping is the least and size of the treatment plant is the smallest.
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Alternatives 3 and 5 would have more short-term impacts to the local communities compared to
Alternative 6, as they involve construction of a larger treatment system and handling more
groundwater. Alternative 4 would have the greatest short-term impacts to the local communities
as this alternative has the most wells, longest underground piping, and two treatment plants.
Groundwater extraction systems would induce a hydraulic gradient and begin to capture COCs
within days or weeks of system startup. With the drilling of extraction wells, installation of
underground conveyance piping, construction of treatment plants, and development of discharge
locations, each of Alternatives 3 through 6 would have some short-term impacts on the community.
However, these disruptions could be minimized through noise and traffic control plans, as well as
community air monitoring programs during construction, to minimize and address any potential
impacts to the community, remediation workers, and the environment.
Implementability
Implementability addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and materials,
administrative feasibility, and coordination with other governmental entities are also considered.
While each of the remedial alternatives are technically feasible and implementable, the degree of
difficulty is determined by specific construction activities that will need to occur in heavily
developed areas. Each active alternative, Alternatives 3, 4, 5 and 6, involves drilling of extraction
wells, installation of varying lengths of underground piping, and construction of treatment plant(s)
and would present varying challenges in implementation in the heavily developed areas near the
Site.
Alternative 1 involves no action and thus, no implementation. Alternative 2 would be the next
easiest alternative to implement as there is no physical construction of a remedial system, and
establishment of institutional controls is an administrative task. Alternative 6 would be the next
easiest to implement as it involves the least amount of piping and the smallest treatment plant. It
requires the potential acquisition of land in the vicinity of the Pompeston Creek for the construction
of a treatment plant and street opening permits for the installation of extraction wells. Alternatives
3, 4, and 5, with centralized treatment plants and surface water disposal/discharge options, would
be more difficult to implement as the acquisition of land to build each treatment plant in highly
developed areas would be necessary. These alternatives would also cause disruptions to traffic
within several areas to install significant amounts of underground conveyance piping between the
extraction wells and the centralized treatment plant, and from the treatment plant to the surface
water discharge location. The most disruptive of these alternatives will be Alternative 4 due to
higher number of wells, the need for the construction of two separate treatment plants, and longer
length of pipe required to be installed.
Further, Alternative 6 would have significantly less negative impact on this protected aquifer as it
includes significantly less extraction of contaminated groundwater compared to Alternatives 3, 4
and 5. This is an important consideration for this aquifer, which is designated as NJDEP Critical
water Supply Area 2.
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10.7 Cost
Includes estimated capital and O&M costs, and net present worth value of capital and O&M costs.
A comparative summary of the cost estimates for each alternative is presented below.
Table 8
Alternative
Capital Cost
Total O&M
Cost
Total
Present-
Worth Cost
1
$0
$0
SO
2
$854,000
S2.797.000
S3,651.000
3
$16,061,000
S33.595.000
S49.656.000
4
$30,382,000
S64.043.000
$94,425,00(1
5
S 14,482.00
S3 3.595.000
S48.077.000
6
S6.595.000
SI 5,771.000
$22,366,000
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.
State Acceptance
Indicates whether based on its review of the RI/FS reports and the Proposed Plan, the state
supports, opposes, and/or has identified any reservations with the selected response measure.
The State of New Jersey has deferred concurrence on this Record of Decision until additional pre-
design and design data are collected and analyzed.
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Community Acceptance
Summarizes the public's general response to the response measures described in the Proposed
Plan and the RI/FS reports. This assessment includes determining which of the response measures
the community supports, opposes, and/or has reservations about.
EPA solicited input from the community on the remedial alternatives proposed for OU4 of the
Site. Verbal comments received from community members during the October 1, 2020 virtual
public meeting did not specifically support or oppose the preferred alternative. Comments
generally included inquiries about the nature and extent of contamination at the Site and public
health and safety. During the comment period, which ran from September 17, 2020 to November
16, 2020, two comment letters were received. Copies of the comment letters are provided as
Attachment D to Appendix V. A summary of significant comments contained in the letters and the
comments received at the public meeting, as well as EPA's responses to those comments, are
provided in the Responsiveness Summary (Appendix V).
PRINCIPAL THREAT WASTES
The NCP establishes an expectation that the EPA will use treatment to address the principal threats
posed by a site wherever practicable (40 C.F.R. § 300.430(a)(l)(iii)(A)). Identified principal threat
waste combines concepts of both hazard and risk. Principal threat wastes are considered source
materials, i.e., materials that contain hazardous substances, pollutants or contaminants that act as
a reservoir for migration of contamination to groundwater, surface water, or as a source for direct
exposure. Contaminated groundwater is generally not considered to be source material. Since OU4
addresses contaminated groundwater, no principal threat wastes are addressed in this ROD.
SELECTED REMEDY
Based upon considerations of the results of the Site investigations, the requirements of
CERCLA, the detailed analysis of the response measures, and public comments, EPA has
determined that Alternative 6, Groundwater Remediation Near Source Areas, is the appropriate
remedy for the contamination found at OU4 of the Cinnaminson Groundwater Contamination
Site.
Description of the Selected Remedy
The major components of the selected remedy at OU4 of the Site include the following:
• Groundwater extraction and treatment in portions of the OU4 contaminated groundwater
plume with the highest levels of contamination, located downgradient, but in close
proximity to, identified source areas;
• Construction of a centralized groundwater treatment plant which may include the following
components, as necessary: metals removal system, air stripping, vapor phase GAC
adsorption, liquid phase GAC adsorption, 1,4-dioxane treatment and AOP;
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• Discharge to surface water at Pompeston Creek or reinjection of treated water into the
aquifer;
• ICs and LTM until the OU4 aquifer is restored.
A pre-design investigation (PDI) will be conducted in order to collect additional data needed to
implement the remedy.
Active remediation elements will be designed to achieve the RAOs to reduce or eliminate further
migration of groundwater containing Site related contaminants at concentrations greater than
federal and state standards, preventing future exposure (via ingestion, dermal contact, and
inhalation) to Site related contaminants in groundwater at concentrations greater than federal and
state standards, and, restoring the impacted aquifer to its most beneficial use as a source of drinking
water by reducing Site related contaminant levels to the most stringent of federal and state
standards.
The extraction and treatment system will operate until RGs are attained in the targeted area. The
selected remedy will include extraction and treatment of approximately 200 gpm of the most
contaminated groundwater in the OU4 study area. The exact number and placement of extraction
wells, pumping rates, and treatment processes, as well as the location of the treatment plant will
be determined during the remedial design. In addition, the discharge of treated groundwater,
whether to surface water or reinjected to the aquifer, will be explored and determined during the
remedial design.
A long-term groundwater monitoring program will be implemented to track and monitor changes
in the groundwater contamination to ensure the RGs are attained throughout the OU4 plume. The
results from the LTM program will be used to evaluate the migration of contaminants and changes
in Site-related COCs over time. ICs in the form of a CEA/WRA will be established to ensure that
the remedy remains protective until RAOs are achieved for protection of human health over the
long term.
The environmental benefits of the selected remedy could be enhanced by giving consideration,
during the remedial design, to technologies and practices that are sustainable in accordance with
EPA Region 2's Clean and Green Energy Policy. This would include green remediation
technologies and practices.
The total estimated, present-worth cost for the selected remedy is $22,366,000. (See Table 8)
Further details of the cost are presented in the OU4 FS Report. 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.
Summary of the Rationale for the Selected Groundwater Remedy
The selected remedy, Alternative 6, Groundwater Remediation Near Source Areas, uses proven
technologies which have been demonstrated to be effective at reducing contaminant mass to
achieve cleanup standards for VOC-contaminated groundwater. The Site lies within the NJ Critical
Water Supply Protection Area No. 2. Groundwater extraction in this portion of the aquifer
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currently exceeds the safe yield of this aquifer, which is heavily relied upon as a potable water
source. The selected remedy (Alternative 6), by extracting groundwater close to the source areas,
will extract much less water than other active alternatives and achieve the desired results of treating
the areas of most contamination, while minimizing negative impacts to this critical aquifer.
Although the densely populated residential area poses logistical challenges to the implementation
of each active remedial alternative, EPA believes that the selected remedy (Alternative 6) will be
significantly less disruptive to residents than the other alternatives since significantly less
infrastructure (such as piping or the number of required treatment plants) will need to be
constructed and maintained compared to the other active alternatives. The selected remedy is cost
effective since capture of the most contaminated groundwater with the lowest volume of aquifer
pumping will occur with the lowest cost compared with the other active Alternatives 3, 4 and 5.
Alternative 6 will result in attainment of RGs in 25 years within the targeted capture zone. Even
with the considerable challenges associated with the aquifer designation as a NJ Critical Water
Supply Protection Area, the OU4 portion of the contaminated aquifer will be fully restored in the
reasonable timeframe of 65 years. The concentrations of contaminants in the portion of the plume
that will not be captured are generally dilute. This dilute part of the plume will over time meet RGs
through natural processes. All public supply wells in the area employ treatment to meet federal
and state drinking water standards before distribution.
Expected Outcomes of the Selected Remedy
The selected remedy actively addresses the area of highest contamination identified in the OU4
groundwater. The overall expected outcome of the selected remedy is to meet the Site RAOs of:
1) preventing or minimizing current and future exposure (via ingestion, dermal contact and
inhalation) to Site-related contaminants at concentrations greater than federal and state standards;
2) restoring the impacted aquifer to its most beneficial use as a source of drinking water by
reducing Site-related contaminant levels to the most stringent of federal and state standards; and
3) minimizing the potential for further migration of groundwater containing Site-related
contaminants at concentrations greater than federal and state standards.
Remediation of the sources of groundwater contamination under separate federal and/or state
authorities have addressed and will address source materials including any principal threat waste
material which acts as a reservoir for continued contamination of the groundwater. The selected
remedy will restore the aquifer at the Site, attaining RGs within the capture zone within 25 years,
and within the OU4-impacted aquifer, within 60 years. Additionally, ongoing and anticipated
remediation of the soils and groundwater in the source areas will be beneficial to the selected
remedy since that remediation will eliminate the continuing sources of contamination to the
aquifer. The response action selected in this ROD will eliminate risks associated with OU4
groundwater, and upon completion, is expected to allow for unrestricted use and unlimited
exposure to groundwater. Groundwater RGs for the COCs at OU4 are presented in Appendix II
Table 7. Achieving the RGs will restore the OU4 aquifer to its beneficial use.
32
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Green Remediation
Consistent with EPA Region 2's Clean and Green policy, EPA will evaluate the use of sustainable
technologies and practices with respect the remedial alternative selected for the Site.2 This will
include green remediation technologies and practices.
STATUTORY DETERMINATIONS
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
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 reduce the volume, toxicity or mobility of the
hazardous substances, pollutants, or contaminants permanently and significantly at a Site. Section
121(d) of CERCLA, 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 Section 121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
EPA has determined that the selected remedy 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 meets those statutory requirements.
Protection of Human Health and the Environment
The selected remedy will provide protection of human health because the exposure pathways to
human receptors will be eliminated by restrictions (institutional controls) placed on the use of
groundwater within the area of OU4 groundwater contamination. The selected remedy will protect
human health and the environment over the long-term once it is completed and in conjunction with
the completion of the other Site OU response actions that address the sources of groundwater
contamination. Groundwater quality at OU4 of the Site will be restored to drinking-water
standards.
Compliance with ARARs
The selected remedy complies with chemical-specific, location-specific and action-specific
ARARs. A complete list of the ARARs and TBCs for the selected remedy is presented in Tables
9, 10 and 11.
Highlights of chemical-, action-, and location- specific ARARs are:
Chemical-Specific
• New Jersey Ground Water Quality Standards (NJGWQS) Class IIA (N.J.A.C. 7:9C),
December 30, 2015 and MCLs.
2 See https://www.epa.gov/greenercleanups/epa-region-2-clean-and-green-policY.
33
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• Federal Safe Drinking Water Act (40 CFR 141.11-141.16) Lists Federal drinking water
standards. Establishes MCLs for public drinking water supplies.
Location-Specific
• Federal Clean Water Act, Section 404 (33 U.S.C. §1344); Provides protection to
maintain the chemical, physical, and biological integrity of the nation's waters
• New Jersey Water Supply Management Act: (N.J.S.A. 58:1A et. seq., Water Supply
Allocation permits, N.J.A.C. 7:19, and Water Supply Critical Area II N.J.A.C. 7:19-8.5)
Action-Specific
• New Jersey Technical Requirements for Site Remediation (N.J.A.C. 7:26E) Specifies
requirements for remedial activities pursuant to New Jersey authorities. Substantive
requirements may be relevant and appropriate.
• New Jersey Well Construction and Maintenance, Sealing of Abandoned Wells (N.J.A.C.
7:9D) Specifies requirements for installation and abandonment of wells. Ambient Air
Quality Standards (N.J.A.C. 7:27-13).
• Federal Clean Air Act (42 U.S.C 7401, Section 112) Establishes air quality standards for
the protection of public health and the preservation of ambient air quality.
Cost Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness (40 C.F.R.
§ 300.430(f)(l)(ii)(D)). Overall effectiveness was evaluated by assessing three of the five
balancing criteria in combination (long-term effectiveness and permanence, reduction in 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 underwent a detailed cost analysis. In that analysis, capital and annual
O&M costs were estimated and used to develop present-worth costs. In the present-worth cost
analysis, annual O&M costs were calculated for the estimated life of each alternative. The total
estimated present worth cost for implementing the selected remedy is $22,366,000.
Based on the comparison of overall effectiveness to cost, the selected remedy meets the statutory
requirement that Superfund remedies be cost effective (40 C.F.R. § 300.430(f)(l)(ii)(D)) in that it
represents reasonable value for the money to be spent. The overall effectiveness of the selected
remedy has been determined to be proportional to the costs, and the selected remedy therefore
represents reasonable value for the money to be spent.
34
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Utilization of Permanent Solutions and Alternative Treatment
(or Resource Recovery) Technologies to Maximum Extent Practicable
The selected remedy complies with the statutory mandate to utilize permanent solutions,
alternative treatment technologies, and resource recovery alternatives to the maximum extent
practicable. Of the 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 provides the best balance of tradeoffs among the alternatives with respect to
the balancing criteria set forth in Section 300.430(f)(l)(i)(B) of the NCP and represents the
maximum extent to which permanent solutions and treatment technologies can be utilized in a
practicable manner at the Site. The selected remedy satisfies the criteria for long-term effectiveness
and permanence by permanently reducing the mass of contaminants in the groundwater at OU4 of
the Site, thereby reducing the toxicity, mobility, and volume of contamination.
Five-Year Review Requirements
While this remedy will not result in hazardous substances, pollutants, or contaminants remaining
on Site above levels that allow for unlimited use and unrestricted exposure, it will take more than
five years to attain the RGs. EPA will conduct a review within five years of construction
completion for the OU4 selected remedy to ensure that the remedy is, or will be, protective of
human health and the environment.
11. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released on September 17, 2020. The Proposed Plan identified
Alternative 6 as the preferred alternative for remediating contaminated groundwater at OU4 of the
Site. The 30-day comment period was scheduled to end on October 16, 2020, but, based upon a
request from the public, the comment period was extended an additional 30 days until November
16, 2020.
EPA considered all comments provided at the public meeting on October 1, 2020, and reviewed
all written comments (including electronic formats, such as e-mail) received during the public
comment period and has determined that no significant changes to the remedy, as originally
identified in the Proposed Plan, are necessary or appropriate.
35
-------
APPENDIX I
FIGURES
36
-------
Figure 1
37
-------
NEW Y0RK.
KRENN'SYiS/ANI
Levittown
Bemalem
nFI AWARF
, Monhtosi
Phiiodilptuo
\ Attorn
otii MMyiui i
Cheltenham
tnaminsl
Philadelphia
Pennwuken
Maple 5hade
C&ilmgswood
¦ ! H-MirlAn
I i v *
I Haddonfield
/E\ \ V
rls \ ^
"30-34^
Bell maw "
v^'x YVj
Newtown
pa * 13
/V~^
i° Florence
r\
/T^< A f ^
Site Location
PA 309
Willlngbord
US 130
Mount Hoi
Moorestown
Liimhf>rfon
'J?'
Mount Laurel South ferity
Krgionol
Atrwn
Medford
CR 541
Voorhees
10
¦ Miles
Serves _ayer create: C upensreewap '.araj corrrtirtan;, cc-s r-SA
SITF I r>OATir>M MAP
38
-------
Figure 2
0U4 SITE VICINITY
CINNAMINSON GROUNDWATER CONTAMINATION SITE OU4
BURLINGTON COUNTY. NEW JERSEY
LEGEND
__J Industrial Properties
Roads
¦ Streams
Cinnaminson Groundwater Contamination
Del Val Ink qelRANTTVP
39
-------
Figure 3
HYDROPUNCH™ LOCATIONS
CINNAMINSON GROUNDWATER CONTAMINATION SITE OU4
BURLINGTON COUNTY. NEW JERSEY
FIGURE 3
LEGEND
^j3 Surface Water Elevation
$ Public Water Supply Wells
A Soil Borings
Soil Borings with Hydropunch
Surface Water & Sediment
| Industrial Properties
| 1 Cinnaminson Groundwater Contamination
I 1 OU4 Study Area
ios Alamos Tecnnica Associates I nc. Data Evaluation
Report Sir sue cmnarrtlnson GrounOwaer Contamination
Site (OU4). July «. 2015
K)3 AEPA
m-
40
-------
0-J4VPE-12
0-
OW*B-10
'.
-------
LEGEND
HOR-lnstalled OU4 Wells
m
LATA-lnstalled OU4 Wells
A
LINDE Wells
o
SU Wells
~
Public Water Supply Wells
A
Industrial Wells
S
Irrigation Wells
| Industrial Properties
I |C
I Is .
A
103 AEPA
MONITORING WELL LOCATIONS
CINNAMINSON GROUNDWATER CONTAMINATION SITE OU4
BURLINGTON COUNTY, NEW JERSEY
Figure 5
42
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Figure 6
0 Hydropunch Locations
[industrial Properties
| iGnndminson Groundwa®;
• I Contamination <*M Study Area
HYDROPUNCH™ RESULTS
CINNAMNSON GROUNDWATER CONTAMINATION SITE OU4
BURLINGTON COUNTY, NEW JERSEY
43
-------
Figure 7
12/9/2019
US
12/9/2019
»5fl
-------
Figure 8
HDR Geoprobe®
x
OU4VPB-7 0U4VPB-4 °U4^PB"2
214.11 182.06
For Geoprobe® and HydroPunch results, only the interval
with the highest total su
LATA HydroPunch™
VOC PLUME
CINNAMINSON GROUNDWATER CONTAMINATION SITE OU4
BURLINGTON COUNTY. NEW JERSEY
O LATA HydroPunch™
• HDR Geoprobe®
Ql Monitoring Wells
Public Water Supply Wells
A Industrial Wets
£ Irrigation Wells
Ato cc Concentration of Total
Ethenes/Ethanes (ugfl)
2017 GW Isoconcentrations. dashed
where inferred
Line of EquaJ Water Level Elevation {ft
msl) (Dashed where inferred)
~ Direction of Groundwater Flow
Plume
| Industrial Properties
Cinnaminson Groundwater
Contamination OU4 Study Area
Numbers «n red are the sum of total etfienes and
total ethanes in ugfl. Mutole values per well
correspond to multiple sampfes per screen ntetval.
k
I03
45
-------
Figure 9
Y07 sepaz--
¦M5I3L
^ Extraction Wells
I Treatment Building
Pipelines
2017 GW Total Ethenes and
Ethanes ! so concentrations.
dashed where inferred
Plume Extent
\
Discharge to v
HOrtlptiSlOn Crook
46
-------
Figure 10
| NsjQH
KK
CINMAMINSON GROUNDWATER CONTAMINATION SITE OU4
GROUNDWATER TREATMENT
PROCESS FLOW DIAGRAM
47
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APPENDIX II
TABLES
Table 1
Summary of Chemicals of Concern and
Medium-Specific Exposure Point Concentrations
Scenmio Timeframe: Current/Future
Medium: Groundwater
h \pos»re Medium: Groundwater
Exposure
Point
Chemical of
Concern
Concentration Detected
Concentration
Units
Frequency of
Detection
Exposure Point
Concentration
(EPC)1
EPC
Units
Statistical
Measure
Mid
Mas
; Groundwater
TCE
0.2J
760
pg..i
48 61
108.5
jig/L
95% KM (Cliebysliev) UCL
; Groundwater
Chloroform
0.16J
170.T+
W'L
31 61
24.85
I'gL
95% KM (Chebyshev) UCL
[Fwblutp*-:
posure point concentration (EPC) is the 95% upper confidence iitnit (UCL) of the arithmetic mean. When the UCL is greater than the maximum detected concentration or ProUCL did not calculate an UC'L. the maximum
detected concentration is chosen.
D-finrtioiii:
UC L= upper confidence limit
Max ~ a aximum detected concentration
kM = kiplaa-Meier
(.15 kg = microgram per kilogram
zrogram pa- iter
I = quaMler for estimated value
T = qualifier for tentatively identified and estimated value
48
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; ¦»
j Table 2
j Selection of Exposure Pathways
I Scenario
j Timeframe
Me n
Exposure
Medium
Exposure Point
lap Water
Receptor
Population
Receptor (Age)
Exposure
Route
Ingestion
Type of
Analysis
Quantitative
Rationale for Selection ot Exclusion of Exposure
Pnthn as
! Current/Future
Groundwater
Groundwater
Resident
Adult and Child "M>
%eais old
"po urt- to --uita e njlaremofp
^o er ah e_ *nai i* thai what "ould >°a i iablv
be expected tor a recreator.
Dermal
Qualitative
Outdoor Air
Inhalation
Qualitative
! Cufrent;Future
Surface Water
Surface Water
Surface Water
Recreator
Adult and Child (0-6
years old)
Ingestion
Qualitative
P? Tpatoi 11 u ng---tt h ~au;htt o i pe^ton
{ int;k The pi tarv con tituent- ot tPie-.taie
olatilp- and oi do utlto^ umulatn and ai* unlikely to
l>- pre pi tin i_riifi-it i ton >-ntiation mfi h
tl k e oi* tin-- j.atl \ i pi all at into lO it.j t nth iedinicnt hile
itin- oipenxnt. eel -o hildi^n it »a^ le
portion^ ot wtu h that at* halh w
Dermal
Qualitative
i Definitions;
j CE A = Classification Exception Area
49
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Table 3
Xon-Carcinogeoic Toxicity Data Summary
Pathway: Ingestion/Dernial
Chemicals
of Concern
Chronic.'
Subchronic
OralRfD
Valne
Oral RIB
Units
Absorp.
Efficiency
(Dermal)
Adjusted RfD
(Dermal)
Adj. Dermal
RfD Units
Primary
Target
Organ
Combined
Uncertain ty
/Modifying
Factors
Sources
of RfD Target
Organ
Dates of
RfD
TCE
Chronic
0.0005
mg kg-day
0.0005
mg kg-day
Developmental,
Lymphatic,
Nervous, Hepatic,
Renal
Reproductive
100.1000.10
multiple studies
IRIS
9/28'2011
Chloroform
Chronic
0.01
mg kg-day
1
0.01
mgkg-day
Hepatic
1000 /1
IRIS
10/19/2001
Pathway: Inhalation
Chemicals
of Concern
Chronic/
Subchronic
Inhalation
RfC
Inhalation
RiC Units
Primary
Target Organ
Combined
Uncertainty
/Modifying
Factor?
Sources
of RfD Target
Organ
Dates of RfC
TCE
Chronic
0,002
mg'm3
Develop i n ai h patic \aial,
N "cu-> -Miphw
100,10 multiple
studies
IRIS
9/28/2011
Chloroform
Chronic
0.098
mg'nr
Hepatic
30
ATSDR
9/14997
Footnotes:
The otaiRfDs are taken from the USEPA Regional Screening .Levels (RSLs) table, which gathers toxicity reference values from multiple sources using an established hierarchy.
The absorbed R£D for dermal is calculated by the following equation: RiD-oral x GLASS.
The lhalationRfCs are taken from the USEPA Regional Screening Levels (RSLs) table, which gathers toxicity reference values from multiple sources using an established hierarchy.
Definitions:
GLASS = Gastrointestinal absoiption factor
IRIS - Integrated Risk Information System
nig fee-day = milligrams per kilogram per day
NA = not available
RfC = teference concentration
PiD = fefet^nce dose
50
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Table 4
Cancer Toxicity Data Summary
Pathway: Ingestion/ Dermal
Oral
Cancer
Slope Factor
Adjusted
Chemical of Concern
Units
Cancer Slope
Factor
(for Dermal)
Slope Factor
Units
Weight of Evidence/Cancer
Guideline1
Source
Date
TCE
0.046
(mg'kg-day)"1
0.046
(mg'kg-day)"1
Carcinogenic to humans
IRIS
9/28/2011
Chloroform
0.031
(mg'kg-day)"1
0.031
(mg'kg-day)"1
Group 2B IARC GroupB2 USEPA
CalEPA
1/20/2011
Pathway: Inhalation
Chemical of Concern
Unit Risk
Units
Inhalation
Cancer Slope
Factor
Slope Factor
Units
Weight of Evidence/Cancer
Guideline1
Source
Date
TCE
0.0000041
(jig/m3)*1
NA
NA
Carcinogenic to humans
IRIS
9/28/2011
Likely to be carcinogenic to humans
Chloroform
0.000023
Oig'm3)"1
NA
NA
under
high-exposure conditions
IRIS
10/19/2001
Footnotes:
(1) Weight of evidence information obtained from IRIS. Categories are as follows:
A = Known human carcinogen
B1 = Probable human carcinogen-indicates that limited human data are available
B2 = Probable human carcinogen based on sufficient evidence of carcinogenicity in animals
C = Possible human carcinogen
D = Not classifiable due to lack of animal bioassays and human studies
Definitions:
IRIS = Integrated Risk Information System
:IUR = inhalation unit risk
[NA = Not available
(mg'kg-day)-1 = per milligrams per kilogram per day
(jig'm")~1 = per micrograms per cubic meter
i SF = slope factor
51
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Table 5
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Worker
Receptor Age: Adult
Chemical Of
Concern
Non-Carcinogenic Hazard Quotient
Medinm
Exposure Medium
Exposure Point
Primary Target Organ(s)
Ingestion
Dermal
Contact
Inhalation
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
TCE
Hepatic
2.3
0.16
NA
2.5
Total Hazard Index (HI) Across Ail Media1=
3.9
Hepatic HI Across All Media1=
2.5
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Chemical Of
Concern
Non-Carcinogenic Hazard Quotient
Medinm
Exposure Medium
Exposure Point
Primary Target Organ(s)
Ingestion
Dermal
Contact
Inhalation
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
TCE
Hepatic
6.5
1.0
26
34 *
Total Hazard Index (HI) Across All Media1=
39
Hepatic HI Across All Media1=
34
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child (0-6 years)
Chemical Of
Concern
Non-Carcinogenic Hazard Quotient
Medinm
Exposure Medium
Exposure Point
Primary Target Organ(s)
Ingestion
Dermal
Contact
Inhalation
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
TCE
Hepatic
a *
1.6
22
35
Total Hazard Index (HI) Across All Media1=
42
Hepatic HI Across All Media1=
35
Footnotes:
(1) The HI represents the summed HQs for all chemicals of potential concern at the site, not just those requiring remedial action (i.e.. the chemicals of concern [COCs]) which are shown in this table.
Definitions:
NA = not available
Table 6
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Worker
Receptor Age: Adult
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
TCE
1.9E-05
NA
1.3E-06
2.0E-05
Exposure Medium Total1=
7.3E-05
Total Excess Cancer Risk Across All Media=
7.6E-05
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child Adult Lifetime
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Groundwater
Tap W ater
TCE
1.2E-04
2.1E-04
1.6E-05
3.5E-04
Chloroform
1.2E-05
1.0E-Q4
9.2E-07
1.1E-04
Exposure Medium Total1=
8.5E-04
Total Excess Cancer Risk Across All Media=
9.2E-04
i Footnotes:
(1) The carcinogenic risk represents the summed carcinogenic for all chemicals of potential concern at the site, not just those requiring remedial
action (i.e.: the chemicals of concern [COCs]) which are shown in this table.
Definitions:
NA = not available
52
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Table 7
Remediation Goals for Groundwater
Cinnaminson Groundwater Contamination Site OU4
Bui hn^ton County, New Jersey
CtintdiniiMnl^ nf Cmnrrn
CAS
Number
N.DfcP GWOS
iWs/U
FcdPMl
MCL
NjDtP
Drinking
Water MCLs
(WlAj
i
Rvi;i!'Lfl.i!i:;n Csns3l
!ngA) |
I
VOLATIl.t ORGANIC COMPOUND I'VOC.-;]
1,1-Dichioroethdne
75-34-3
SO
SO
50 [
1,2-Dichloroethane
107-06-2
2
5
2
2
l,4»DichIorobenzene
106-46-7
75
75 ll>
75
75
1,4-Dioxane
123-91-1
0,4
_
_
0.4
Benzene
71-43-2
1
5
1
1
Chloroform
67-66-3
70
SO'1'
80
70
Tetrachloroethylene (PCE)
127-18-4
1
5
1
1
Trichloroethylerie (TCE)
79-01-6
1
5
1
1
Vinyl chloride
75-01-4
1
2
2
1 1
Notes:
The Remediation Goal is the minimum of the individual listed criteria.
[J! Criterion value is for total.
Abb revis! ions;
CAS = Chemical Abstracts Service
MCL = Maximum Contaminant level (NJDEP 2009a, EPA 2009)
NJDEP GWQS = New Jersey Department of Environmental Protection (NJDEP) Groundwater Quality Standard (GWQS,2018}
pg/l = micrograms per liter
53
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Table 9
Chemical-Specific ARARs and TBCs
Media
Authority
Requirement
Description
Status
Groundwater
Federal
Safe Drinking
Water Act
(40 CFR 141.11-
141.16)
Lists Federal drinking
water standards.
Relevant and
appropriate for
establishing
groundwater
remediation goals in
Appendix II Table 7,
which are based on the
lowest of the relevant
federal MCLs, NJDEP
MCLs, and NJDEP
GWQS.
ARAR
Groundwater
State of New
Jersey
Groundwater
Quality Standards
(NJAC 7:9C)
Lists groundwater
quality standards in
New Jersey.
Applicable to
establishing
groundwater
remediation goals in
Appendix II Table 7 ,
which are based on the
lowest of the relevant
federal MCLs, NJDEP
MCLs, and NJDEP
GWQS.
ARAR
Groundwater
State of New
Jersey
Drinking Water
Standards
(NJAC 7:10-1)
Lists drinking water
standards in New
Jersey. Relevant and
appropriate for
establishing
groundwater
remediation goals in
Appendix II Table 7,
which are based on the
lowest of the relevant
federal MCLs, NJDEP
MCLs, and NJDEP
GWQS.
ARAR
54
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Table 10
Location-Specific ARARs and TBCs
Authority
Requirement | Description
Status
Federal
Sole Source Aquifer
Sole Source Aquifer
Designation
(42 U.S.C 300h-3e and
300h-6 and 40 C.F.R 149)
Provides protection to sole
source of drinking water
ARAR
Wetlands
Executive Order
No. 11990 - Protection of
Wetlands
Requires Federal agencies
to take action to avoid
adversely impacting
wetlands wherever possible
and to minimize wetlands
destruction.
TBC
Clean Water Act
33 U.S.C 1344 (Section
404)
40 C.F.R Part 230
Provides protection to
maintain the chemical,
physical, and biological
integrity of the nation's
waters
ARAR
OSWER 9280.0-03
Guidance for
Implementing EO 11990
TBC
Wetland Permits
(40 C.F.R 230-233)
Provides substantive
requirements for actions in
and around wetlands and
waters of the United States.
ARAR
State of
New Jersey
Wetlands
Freshwater Wetland
Protection Act Rules
(N.J.S.A 13:9B-, N.J.A.C
7:7 A)
Establishes requirements
for the protection of
freshwater wetlands.
ARAR
New Jersey Water Supply
Management Act,
N.J.S.A. 58:lAet. seq.,
Water Supply Allocation
permits, N.J.A.C. 7:19,
and Water Supply Critical
Area II (N.J.A.C. 7:19-
8.5)
Establishes requirements
and limitations within a
Water Supply Critical
Area. Applicable as the
PRM aquifer system was
designated by NJ as a
Water Supply Critical Area
II on January 15, 1993.
ARAR
55
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Table 11
Action-Specific ARARs and TBCs
Authority
Requirement
Description
Status
Federal
Clean Air Act
(42 U.S.C. 7401,
Section 112)
Establishes limits on
emissions to atmosphere
from industrial and
commercial activities.
Relevant and appropriate to
the construction of the
groundwater treatment plant.
ARAR
National Pollutant
Discharge Elimination
System (40 C.F.R. 122
and 40 C.F.R. 131)
Surface water quality
requirements for discharges
of pollutants to waters of the
United States and to the
waters of the State of NJ and
provides substantive
requirements for the
discharge of pollutants from
any point source into waters
of the United States.
Discharge of treated
groundwater to
surface water and/or waters
of the United States will
comply
with substantive
requirements.
ARAR
National Emission
Standards for
Hazardous Air
Pollutants
(40 C.F.R. Part 61, 63)
Establishes limits on
hazardous emissions to the
atmosphere. Relevant and
appropriate to the
construction of the
groundwater treatment plant.
ARAR
National Ambient Air
Quality Standards
(NAAQS)
(40 C.F.R. Part 50)
Establishes emissions limits
for primary and secondary
NAAQS. Relevant and
appropriate to the
construction of the
groundwater treatment plant.
ARAR
Standards of
Performance for New
Stationary Sources (40
C.F.R. Part 60)
Establishes emissions
requirements for new
stationary sources. Relevant
and appropriate to the
construction of the
ARAR
56
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groundwater treatment plant.
Resource Conservation
and Recovery Act
(42 U.S.C. 6921 et
seq.)
Established to provide
structure for the
management of hazardous
and non-hazardous solid
waste. Applicable to the
extent any remediation
waste requires management
as a hazardous waste.
ARAR
General Hazardous
Waste Management
System Regulations
(40 C.F.R. Part 260)
Provides definitions of terms
and general standards
applicable to hazardous
waste management system
regulations. Applicable to
the extent any remediation
waste requires management
as hazardous waste.
ARAR
Transportation of
Hazardous Wastes
(40 C.F.R. 263 and
49 CFR 107, 171-180)
Established standards for the
transportation of hazardous
wastes and/or materials.
Applicable to the extent any
remediation waste requires
management as hazardous
waste.
ARAR
Generators of
Hazardous Waste
(40 C.F.R. 262)
Establishes requirements for
generators of hazardous
waste (EPA ID numbers and
manifests). Applicable to the
extent any remediation
waste requires management
as hazardous waste.
ARAR
Standards for Owners
and Operators of
Hazardous Waste
Treatment, Storage,
and Disposal Facilities
(40 C.F.R. 264)
Establishes the minimum
standards for the
management of hazardous
waste and includes
regulations for land disposal
units. Applicable to the
extent any remediation
waste requires management
as hazardous waste.
ARAR
57
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Table 11
Action-Specific ARARs and TBCs
Authority
Requirement
Description
Status
State of
New Jersey
Transportation of
Hazardous Materials
(N.J.AC. 16:49)
Regulates shipping/transport
of hazardous materials.
Applicable to the extent any
remediation waste requires
transport as hazardous waste.
ARAR
Solid Waste
Regulations
(N.J.A.C 7:26)
Regulates non-hazardous
waste management.
Applicable for the disposal of
any non-hazardous
remediation waste.
ARAR
Storm Water
Management
(N.J.A.C. 7:8)
Establishes requirements for
managing and controlling
storm water from the Site.
Applicable for establishing the
design and performance
standards at the groundwater
treatment plant.
ARAR
New Jersey Soil
Erosion and Sediment
Control Act, N.J.S.A.
4:24-39,
N.J.A.C. 2:90
Requires controls for erosion
and sediment transport.
Applicable to the construction
of the groundwater treatment
plant.
ARAR
Noise Control
(N.J.S.A., § 13:lg-1 et
seq., N.J.A.C. 7:29)
Limits the noise generated
from any industrial,
commercial, public service or
community service facility.
Relevant and appropriate for
establishing allowable noise
levels during remediation.
ARAR
Technical
Requirements for Site
Remediation
(N.J.A.C. 7:26E)
Specifies requirements for
remedial activities pursuant to
New Jersey authorities.
Substantive requirements may
be relevant and appropriate.
ARAR
Well Construction and
Maintenance, Sealing
of Abandoned Wells
(N.J.A.C. 7:9D)
Specifies requirements for
installation and abandonment
of wells. Applicable to the
installation of the groundwater
extraction wells.
ARAR
Ambient Air Quality
Establishes air quality
ARAR
58
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Standards
(New Jersey Air
Pollution Control Act,
N.J.S.A. § 26:2C et
seq., N.J.A.C. 7:27)
standards for the protection of
public health and the
preservation of ambient air
quality. Potentially applicable
to the groundwater treatment
plant.
New Jersey Pollutant
Discharge Elimination
System Rules
(N.J.A.C 7:14A)
Establishes standards for
surface water discharge for
site remediation projects.
Applicable to the discharges
from the groundwater
treatment plant.
ARAR
Standards for Owners
and Operators of
Hazardous Waste
Treatment, Storage
and Disposal Facilities
(NJAC 7:26G-8)
Establishes substantive
requirements and construction
and operations standards.
Applicable to the disposal of
any hazardous remediation
waste.
ARAR
New Jersey Water
Supply Management
Act, N.J.S.A. 58:1 A
et. seq., Water Supply
Allocation permits,
N.J.A.C. 7:19, and
Water Supply Critical
Area II (N.J.A.C. 7:19-
8.5)
Establishes requirements and
limitations within a Water
Supply Critical Area.
Applicable as the PRM
aquifer system was designated
by NJ as a Water Supply
Critical Area II on January 15,
1993.
ARAR
59
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APPENDIX III
ADMINISTRATIVE RECORD
60
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ADMINISTRATIVE RECORD INDE
FINAL
09/17/2020 REGION ID: 02
Site Name: CINNAMINSON TOWNSHIP (BLOCK 702) GROUND WATER CONTAMINATION
CERCLIS ID: NJD980785638
OUID: 04
SSID: 02F7
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
615363
9/17/2020
ADMINISTRATIVE RECORD INDEX FOR OU4 FOR THE
CINNAMINSON TOWNSHIP (BLOCK 702) GROUND
WATER CONTAMINATION SITE
1
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
598800
08/01/2020
FINAL REMEDIAL INVESTIGATION REPORT FOR OU4
FORTHE CINNAMINSON TOWNSHIP (BLOCK 702)
GROUND WATER CONTAMINATION SITE
4856
Report
(HDR)
598801
09/04/2020
FINAL FEASIBILITY STUDY REPORT FOR OU4 FOR THE
CINNAMINSON TOWNSHIP (BLOCK 702) GROUND
WATER CONTAMINATION SITE
160
Report
(HDR)
615637
9/16/2020
PROPOSED PLAN FOR OU4 FOR THE CINNAMINSON
TOWNSHIP (BLOCK 702) GROUND WATER
CONTAMINATION SITE
28
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 1 of 1
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APPENDIX IV
NEW JERSEY CONCURRENCE
m
JStafe of ^N?iu |}»rgey
Department of Environmental Protection
Site Remediation and Waste Management Program
401 East State Street
PHI1.JP l>. MURPHY f;°- Box 420, Mail Cx^'iOl-06 SHAWN M. LATOURETTIS
Governor Trenton, New Jersey 08625-0420 Aal commissioner
Tel. (609)292-1250 •Fa* (609)777-1914 s
SHF.II.A Y. OI.IVF.R im*Eov/dse
Ta. Governor
May 21, 2021
Pat Evangelisla, Director
Superfund and Emergency Management Division
United States Environmental Protection Agency
Region II
290 Broadway
New York, New York 10007-1866
Re: Record of Decision Deferred Concurrence Letter
Cinnaminson Landfill Groundwater Contamination Superfund Site
Ckmaininson Township, Burlington County
DEP/SRP PI#G000005321
Dear Mr. Evangelista
The New Jersey Department of Environmental Protection (DEP) has reviewed the draft Record
of Decision (ROD) for Operable Unit 4 (OU4) of the Cinnaminson Landfill Groundwater
Contamination Superfund (Cinnaminson) site and defers concurrence with tine selected remedy
for groundwater contamination emanating from three major sources in a comingled plume until
substantial progress is achieved with the remedial actions noted below.
More specifically, DEP believes it does not have sufficient information at this time to make a
final determination on the selected OU4 remedy for the ROD at two of the three primary source
sites, Messer/Linde and Detrex. However, DEP is committed to working with the IJ.S.
Environmental Protection Agency (EPA) during development of a pre-design investigation (PDI)
that will be conducted to collect additional data needed to implement a Remedial Design for the
OU4 remedy. This includes developing specific design elements for the proposed extraction
locations and treatment system technologies for the various site-related contaminants and
handling of the resulting effluent discharge. DEP does, however, acknowledge the vast amount
of data collected and analyzed during the OU4 Remedial Investigation and Feasibility Study for
this significant groundwater case and appreciates our past discussions with you and your staff to
move cleanup actions forward.
OU4 included a review of site-related groundwater contamination from three major sources,
which includes the SLI Landfills as the third source in addition to the Messer/Linde and Detrex
sites. The contribution from the three individual sources and the commingled pluinc arc at
various remedial stages under both federal and state cleanup programs, and this presents several
New Jersey is an Equal Opportunity Employer. Printed art Recycled Paper and Recyclable.
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May 21, 2021
Page 2 of 3
challenges to our agencies to effect successful cleanup actions. As potential responsible parties
have performed some; remedial work involved with the Cinnaminson site, along with Fund-lead
work by EPA with public funding, additional engagement of these private parties during future
remedial actions also will be part of our ongoing site discussions.
DEP understands that additional treatment of groundwater adjacent to the Messer/Linde and
Detrex source areas of the Cinnaminson site may be warranted as selected in the OU4 ROD for
the site. However, DEP recommends postponing the finalr/alion and implementation of the OU4
active groundwater extraction and treatment remedy until after the following actions are
conducted:
1. Delineate DNAPL and develop a remedial plan for source areas identified at the
Messer/Linde and Detrex sites. Furtherance of this effort will serve to reduce the duration of
pumping from the critically over-pumped Potomac Raritan and Magothy Formation (PRM),
which DEP has already expressed as a primary concern. OU3 is underway and addresses
contamination associated with the Messer/Linde facility, and a Proposed Plan is scheduled for
Federal Fiscal Year 2021. Detrex is proceeding under state oversight and discussions arc
underway about the site proceeding under EPA's cleanup authority to ensure remediation of the
encompassing Cinnaminson site proceeds in a coordinated and comprehensive manner under the
Superfund program.
2. Due to the duration of ground water pumping for the selected remedy and the enormous
volume that will eventually be pumped from the PRM, consider a Technical Impracticability
Waiver as efforts continue at the aforementioned DiN Al'L source areas progress. Also, as
groundwater pump and treat remain the selected remedy for OU4, include a groundwater
rcinjcction option for the selected remedy during Remedial Design development to reduce water
supply impacts in the PRM. While a groundwater treatment plant operated at the former SIJ
Landfills source site for more than 10 years extracting approximately 200 gallons per minute
with discharge to a local surface water body, DEP's preference for reinjection of treated
groundwater in this critical aquifer is essential.
3. Expand monitoring and investigation of contaminants of emerging concern, especially
PFAS. Landfills are wel 1 -documented sources of PFAS and 1,4-dioxane and Detrex's
contamination indicates 1,2,3-TCP may also be present. As you are aware, DEP has already
adopted Ground Water Quality and Drinking Water Standards for these compounds, therefore,
treatment for these compounds should be included in any remedy for the Cinnaminson site, if
identified as contaminants of concern.
DEP has deferred concurrence previously on Records of Decision for other NPL sites. Most
recently in 2018, when DEP deferred concurrence on the Combe Fill South Landfill OU2 ROD
until treatment technologies were further evaluated by EPA and DBF tor 1,4-dioxane
contamination in ground water. After appropriate review during development of a Remedial
Design for the selected treatment technology, DEP now plans to concur with the selected remedy
and is working on a formal concurrence for this ROD with EPA.
I-few Jersey Department of Environmental Protection
AW* Jersey is an liquat Oppori"»>ry Fjnjifaycr. Printed on Rrtyrtcd Paper ami Rvcychiblc.
62
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May 21, 2021
Page 3 of 3
For the Cinnaminson site, the OUl ROO was issued in September 19.90 and addressed
groundwater contamination associated with the SL.I Landfills. The remedy was a groundwater
action in shallow and deep aquifers oil site to prevent further migration and contamination of
municipal supply wells, which was performed under LvPA oversight by SC Holding, a wholly
owned subsidiary of Waste Management Inc. As the UU4 selected remedy seeks fo address
groundwater contamination adjacent to the other source sites Messer<'T inde and Detrex to
prevent further off-site migration and contamination of municipal supply wells, DCP lias
ongoing concerns about public water supplies in the area that may have been contaminated from
the Cimianiinson site and now require treatment for continued potable use. DEP requests HP A
continue to coordinate outreach to potentially impacted public water purveyors, so they remain
aware and current about ongoing remedial work related to the Cinnaminson site and the
opportunity to pursue compensation for past injuries.
I would like lo reiterate that HHP appreciates the opportunity to paiticipate in the decision-
making process. As we continue to work with you and your staff, DEP looks forward to
implementing appropriate remedial measures necessary lo ensure protection of the Stale's
groundwater resources and public drinking water supplies.
If you have any questions, please do not hesitate to call me at (609) 292-1250.
Sincerely.
Mark J. Pcdersen
Assistant Commissioner
Kenneth J, Kloo. Director, DEP, Division of Remediation Management
Wayne How itz. Assistant Director. DCP, Publicly Funded Response Flement
Frederick A. JVlumford. Chief. DFP, Bureau of Site Management. PFRli
Kim O'ConnelL Chief. KPA Region 11, New Jersey Branch
Joseph Roto la. Chief, JiPA Region II. Removal Action Branch
'New Jersey Department of Environmental i*ko i bction
Netv Jersey is f'l tefitat Oppvrtuniry Employer, fritiliti wi Recycled Ftiprr wtt.t
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APPENDIX V
RESPONSIVENESS SUMMARY
64
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INTRODUCTION
This Responsiveness Summary provides a summary of the significant comments and concerns submitted
by the public on the September 2020 Proposed Plan for Operable Unit 4 (OU4) of the Cinnaminson
Groundwater Contamination Superfund Site (Site) and EPA's responses to those comments and
concerns. All comments summarized in this document have been considered in EPA's final decision for
the selection of a remedy to address contamination in OU4 of the Site.
This Responsiveness Summary is divided into the following sections:
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This section provides the
history of community involvement and concerns regarding the Site.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS AND
RESPONSES: This section includes summaries of comments received by EPA during the October 1,
2020 public meeting and in writing during the public comment period, as well as EPA's responses to
these comments.
The Responsiveness Summary includes attachments which document public participation in the remedy
selection process for OU4 of the Site. These attachments are as follows:
Attachment A - September 2020 Proposed Plan for the Cinnaminson Groundwater Contamination
Superfund Site - OU4.
Attachment B - Public Notice published in Burlington County Times and on EPA web site, on
September 17, 2020 and Notice to Extend Public Comment Period published in Burlington County
Times and EPA web site on October 25, 2020.
Attachment C - Transcript of the October 1, 2020 Virtual Public Meeting; and
Attachment D - Written comments received by EPA during the public comment period.
I BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
EPA's Proposed Plan for cleanup of OU4 of the Cinnaminson Groundwater Contamination Superfund
Site, as well as supporting documentation, were released to the public for comment on September 17,
2020. These documents were made available to the public in the administrative record file maintained at
the Cinnaminson Public Library, located at 1619 Riverton Road, Cinnaminson, New Jersey and in the
EPA Region II Records Center at 290 Broadway, New York City and at EPA's website for the Site,
https://www.epa.gov/superfund/cinnaminson. Furthermore, a notice of availability of the above-
referenced documents was published in the Burlington County Times on September 17, 2020.
On September 17, 2020, EPA opened a thirty-day public comment period on the Proposed Plan which
was originally scheduled to extend through October 16, 2020. However, EPA received a request from
the public to extend the public comment period to allow adequate time for consideration of and
comment on the Proposed Plan. In response to this request, the EPA provided an extension to the public
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comment period, which resulted in a public comment period that extended from September 17, 2020
through November 16, 2020. In addition, EPA held a virtual public meeting on October 1, 2020 at 6:00
pm to present the findings of the OU4 Remedial Investigation/Feasibility Study (RI/FS) and EPA's
Proposed Plan to the community and local officials. At this meeting, representatives of the EPA listened
to and answered questions concerning the remedial alternatives developed as part of the RI/FS.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
CONCERNS AND RESPONSES
A number of groups and individuals provided comments during the public comment period. Comment
letters were received by EPA via the U.S. Postal Service and electronic mail during the public comment
period, which are included in Attachment D. The following is a summary of the significant comments
contained in these letters and during the public meeting held on October 1, 2020 and EPA's responses to
these comments. Additionally, Messer LLC (Messer), requested certain data and information in
conjunction with its request for an extension of the public comment period. In EPA's October 16, 2020
press release extending the public comment period to November 16, 2020, EPA noted that it included all
of the data from the OU4 RI/FS in an alternative format in the Administrative Record. Additionally, via
email dated November 12, 2020, EPA responded to some of Messer's comments in conjunction with its
request for an extension of the public comment period. These comments and the responses are also
included below.
The entire transcript for the public meeting is attached (Attachment C) to this document. A copy of the
transcript of the public meeting is also available in the Administrative Record, which is available in the
above-referenced information repositories.
A summary of comments/questions from the public meeting is provided below with EPA's responses.
Following the public meeting comments section are EPA's responses to written comments submitted
during the public comment period.
Verbal and Virtual "Chat" Comments from the 10/01/2020 Public Meeting
Public Comment #1: A commenter requested clarification regarding the elevation of the groundwater
table determined in the OU4 study area. Specifically, the commenter asked if the water table elevation
was lower than the historical water table elevation.
EPA Response #1: Yes, the OU4 RI did determine that the groundwater table elevation is now lower
than the historical water table elevation.
Public Comment #2: Has EPA implemented any of the alternatives presented during the public
meeting?
EPA Response #2: At the public meeting, EPA explained that a remedial alternative had not been
implemented. The purpose of the public meeting was to explain the alternatives and present the option
EPA is proposing, and comments on the Proposed Plan were accepted during the public comment
period. EPA has evaluated all the public comments received at the meeting and during the public
comment period and issued an OU4 Record of Decision choosing Alternative 6 as the selected remedy.
3
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Following a remedial design, the selected remedy will be implemented.
3) Public Comment #3: Has EPA selected a proposed alternative?
EPA Response #3: Yes, the selected remedy is Alternative 6 from the OU4 Proposed Plan.
Public Comment #4: Have any health risk studies been completed?
EPA Response#4: Yes. both a human health risk assessment and a Screening Level Ecological Risk
Assessment were completed and are summarized in Section 7 of the OU4 RI, and the assessments are
provided as appendices in the OU4 RI.
Public Comment #5: Have OU4 cost recovery actions occurred to date?
EPA Response#5: No. OU4 cost recovery actions have not occurred to date.
Public Comment #6: Will the treated water be used?
EPA Response #6: The alternatives evaluated would result in treated water being discharged to surface
water or reinjected back to the aquifer.
Public Comment #7: Does anyone drink untreated groundwater in the OU4 area?
EPA Response #7: No. Drinking water in the area is treated and distributed by municipal or private
water utilities. The public drinking water supply meets federal and state drinking water standards.
Written Comments Received During the Public Comment Period
EPA received written comments only from Messer. The comments and responses are arranged with the
Messer's Executive Summary Comments and corresponding Technical Comments, and EPA's responses
to the Executive Summary and Technical Comments first, followed by Messer's General Comments and
EPA responses to the General Comments. The Messer written comments submitted to EPA during the
Public Comment Period are provided in Attachment D to this document. Note: Exhibits 1-8 in the
following EPA responses to Messer's comments are figures taken directly from Messer's submitted
written comments, unedited by EPA, and are presented as an aid in understanding the written text below.
4
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Messer's Executive Summary Comments and Technical Comments
• Executive Summary Comment: EPA compares 20-year old data with data generated in the
last three years to characterize the chemical signature of the groundwater. But available
contemporaneous data shows lower CVOC [chlorinated volatile organic compounds]
concentrations at 0U3 (upgradient) and higher concentrations downgradient at
monitoring well SL-4D, undermining EPA 's conclusion of OU3 as an upgradient source of
the high CVOC concentrations detected in 0U4.
1. Comparing 20-year old data from an unidentified sampling location at 0U3 to samples
collectedfrom 0U4 in the past three years does not support accurate and reliable scientific
conclusions. EPA should develop and compare a chemical signature analysis with
contemporaneous data from 0U3 and 0U4 before selecting and documenting a remedial
alternative in a ROD.
EPA states in the 0U4 RI that "[t]he groundwater results outlined in the 1999 [0U3] RI
can be used to characterize the chemical signature of the groundwater contamination in
0U3. " and that "groundwater in this area contains TCE and cis-l,2-DCE which is
consistent with potential sources of TCE in 0U3 as defined by groundwater samples
collectedfrom B-l1" [Emphasis added by Messer], EPA also claims that "Groundwater
results outlined in the Remedial Investigation Report BOC Gases submitted to the NJDEP
in April 1999 and discussed in Section 1.4 of this 0U4 RI (Figure 1-4) can be used to
characterize the chemical signature of the groundwater contamination in 0U3. "2
First, there is no sampling location B-14 related to the Former BOC Property (0U3).
Second, Figure 1-4 shows groundwater contours at 0U3 and does not show sampling
results from which chemical signatures can be deduced. Third, there is no data analysis
provided by the 0U4 RI report to characterize the chemical signature of the groundwater
contamination in 0U3. Fourth, detections of TCE and cis-l,2-DCE in 0U4 is not evidence
that 0U3 is the source of these compounds. In this regard, there are several known sources
of TCE in groundwater at the Cinnaminson Groundwater Contamination Site including the
former Hoeganaes Landfill, Detrex, former SLILandfills, and 0U3.
Technical comments below will provide evidence that Detrex is a more likely source of
TCE, PCE, and breakdown products cis-l,2-DCE and VC that has impacted 0U4
groundwater.
Regardless, the use of a Geoprobe® groundwater samples from 1999 is not representative
of current groundwater conditions at 0U3, and thus cannot be comparedto 0U4 data
collected in the past three years to assess chemical signatures. TCE concentrations will
change significantly over twenty years and assuming a typical TCE half-life of 8-10 years,
the TCE concentrations at 'B-14' would be 75% lower now than in 1999. Given the relative
proximity of SL-4D to 0U3 (less than 500ft), for the purpose of comparing TCE and cis-
1,2-DCE concentrations, EPA should use contemporaneous data sets and should not rely
on data sets created almost 20 years apart. As discussed below, TCE and cis-l,2-DCE
concentrations at 0U3 wells (and additional 0U3 delineation well BOCMW-14) are lower
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than concentrations at 0U4 downgradient SL- 4D, indicating there is another source of
TCE and cis-l,2-DCE to SL-4D.
EPA Response:
The chemical characteristics of the OU4 groundwater plume indicate that OU3 which addresses
contamination associated with the Messer property, is one of the major sources. Higher concentrations
of contaminants currently detected at monitoring well SL-4D do not alter or undermine EPA's
conclusion that OU3 is an upgradient source of the high CVOC concentrations detected inOU4 for
numerous reasons described in the RI Report. Both older and newer groundwater data from the OU3
investigation history was used to determine potential sources of contamination at OU4.
Selection of a groundwater remedy at this Site does not require that EPA develop groundwater chemical
signature data. There are sufficient data from numerous Site investigations conducted for each operable
unit, as well as NJDEP reports and information over time, for EPA to determine the nature and extent of
OU4 groundwater contamination, and to identify the major sources of the OU4 groundwater
contamination. As indicated in the OU4 RI Report, the Site characterization model includes the
following with respect to OU3: "Groundwater sampling results show TCE, cis-1,2 DCE, and VC were
consistently detected in on-site and off-site groundwater samples. Groundwater containing VOCs flows
to the west where it turns to the southwest, flows across Union Landing Road, and continues to turn to
the southeast migrating towards Route 130."
The relative percent of each CVOC is a tool to assist in characterizing the nature of the contamination
within a plume. Over time, it is possible for that characterization to change, but often it does not.
Therefore, it is appropriate to use available data to support the conclusion that OU3 is a source of the
OU4 plume. In addition, as the OU4 RI Report explains with respect to flow from OU3:
"In a similar manner, groundwater containing TCE at Messer migrates near or beneath a septic leach
field (or other anthropogenic factors that could create reducing groundwater conditions) that drives the
aquifer from aerobic to anaerobic condition, resulting in a small amount of reductive dechlorination
(TCE and cis-l,2-DCE) in groundwater migrating to the northwest and a large amount of reductive
dechlorination of PCE and TCE to cis-l,2-DCE, 1,1-DCE, and VC (monitoring wells OU4 MW-7S/I/D,
SIMW-2D, SIMW-3D, SIMW-4S, SIMW-19MZD, SL-4D, SL-7RP, and Figures 4-3, 4-4, and 4-7)
migrating to the southeast.
The data from AFGMW-14 collected in OU3 was used (along with other OU3 monitoring well data
collected since 1999) to assess the nature of the OU3 groundwater contamination. AFGMW-14 is
located in the OU3 - Area of Concern named the "Railroad Spur". Details of the groundwater
monitoring are provided in Appendix A of the OU4 RI. Characteristic CVOCs in groundwater at Messer
are shown on Figure 6.8-3 of the 1999 Remedial Investigation Report BOC Gases, Riverton Facility,
Riverton New Jersey prepared for BOC Gases Murray Hill, New Jersey (Atlantic, 1999) presented as
Figure 1-5 in the OU4 RI. The location of the septic system at Messer is shown on Figure 5.4-1 of the
1999 Remedial Investigation Report BOC Gases, Riverton Facility, Riverton New Jersey prepared for
BOC Gases Murray Hill, New Jersey (Atlantic, 1999) presented as Figure 1-6 in this OU4 RI. (RI
Report, p. 59)."
EPA has utilized the data from AFGMW-14 collected as part of the OU3 investigation, in part to
6
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assess the nature of the OU3 groundwater contamination and its affect on OU4. Other more recent
data was also used. The robust groundwater monitoring network provided the data required to support
EPA's conclusion that OU3 source areas contribute to the OU4 groundwater plume. (Note that a
typographic error in the OU4 RI Report reported this well as B-14.)
Executive Summary Comment: EPA disregards its own guidance regarding the presence of
Dense Non-Aqueous Phase Liquid ("DNAPL "), as well as clear evidence from prior
investigations, that DNAPLis present at the Detrex property. EPA thus fails to identify
Detrex as the largest and most likely source of contamination to OU4. EPA should require
Detrex to address the DNAPL to prevent the spread of contamination downgradient.
DNAPL at Detrex is likely the largest source of groundwater contamination to OU4and
must be addressed before implementing a "pump and treat" system to contain the spread
of contamination downgradient.
EPA states in the OU4 RI that "[t]here is insufficient information to determine if DNAPL
potentially exists at Detrex3. " This statement is not supported by existing data and EPA
guidance. Figure 1-8presents the 2011 Groundwater Exceedances for the Detrex site. MW-
5 was reported with 81,800 ug/L of TCE, 19,200 ug/L of 1,1,1-TCA, and 699 ug/L ofPCE.
Per EPA guidance document 542-R-04-106 (DNAPL Remediation: Selected Projects
Approaching Regulatory Closure), " ...it is difficult to verify the presence ofDNAPLs
through direct observation. Generally, its presence is indirectly estimated. One approach is
based on ground water concentration data and the 7 percent of solubility' rule-of-thumb
(EPA 1992). Under this approach, DNAPL is suspected to be present when the
concentration of a chemical in ground water is greater than 1 percent of its pure-phase
solubility Per Appendix B of this EPA document, 1% of aqueous solubility for TCE is
14,720 ug/L, for 1,1,1-TCA is 13,340 ug/L andfor PCE is 2,000 ug/L. Therefore, based on
EPA 's guidance and the available data, DNAPL is likely present at Detrex for both TCE
and 1,1,1-TCA. In addition, the 2012 Remedial Action Report (Appendix A in the OU4 RI)
noted DNAPL at the Detrex site based on the 1% solubility rule as well as positive
hydrophobic dye tests conducted on soil samples collected at thesite. These concentrations
and documented findings indicate that Detrex is the largest source of TCE, 1,1,1-TCA and
PCE (due to DNAPL) to groundwater in OU4. The effectson DNAPL and the increased
downgradient dissolved phase CVOC concentrations froma groundwater "pump and treat"
system were not considered in the FS. Therefore, before implementing a downgradient
"pump and treat" system, the DNAPL at Detrex should be further investigated and
addressed.
EPA Response:
EPA did not disregard its guidance. Rather, EPA considered the OU4 data in conjunction with its
guidance including "DNAPL Site Characterization, September 1994, EPA/540/F-94/049". This
guidance identifies many other considerations in addition to the 1% solubility of contaminants to
evaluate the status of DNAPL, such as chemical distribution and changes in concentration over time.
The OU4 RI Report (page 66) indicates "The groundwater results from MW-5 are characteristic of the
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groundwater contamination (potentially DNAPL) near the source area. Groundwater samples collected
from MW-5 contained TCE, 1,1,1-TCA, 1,1-DCE, and PCE with lesser concentrations of other
chlorinated ethenes and ethanes."
Moreover, EPA has identified the Detrex property as a significant contributing source of groundwater
contamination to OU4. While DNAPL is not specifically discussed in the ROD, EPA agrees that
DNAPL is present at the Detrex property. Since the completion of the OU4 RI/FS and issuance of the
OU4 Proposed Plan, EPA has confirmed with NJDEP that DNAPL is present at the Detrex facility.
NJDEP, under its authority, is currently overseeing response actions at the Detrex facility.
• Executive Summary Comment: EPA suggests that OU3 might be a source of DNAPL. Yet
the available data and EPA's own guidance conclusively establish that no DNAPL is
present at OU3, making it an unlikely source for the two-mile-long plume at OU4.
3. DNAPL is not present at OU3, making it an unlikely source for the two-mile-long
plume at OU4.
The OU4 RL also states that "[d]ata collected at OU3 shows there may potentially be or
may have been a pool of DNAPL at OU3 (Atlantic, 2005) " and "[t]he distribution of the
CVOCs show DNAPL is potentially present on top of the bedrock saprolite or diffused
into the saprolite diffusing or back-diffusing CVOCs to groundwater. "4 This statement is
not supported by existing data and EPA guidance. Rather, groundwater monitoring data
and additional site characterization data generated since 2005 (which was provided to
EPA in the 2020 OU3 Site Characterization Summary Report ("SCSR")) indicate no
DNAPL is present at OU3. While initial investigations performed in 2005 suggested the
potential for DNAPL (based on elevated TCE in turbid and limited direct-push
groundwater samples), monitoring wells installed to delineate TCE impacts have
confirmed concentrations are below 1 percent solubility for TCE (14,720 ug/L). In
addition, the concentrations reportedfor TCE in monitoring wells from 1991 through
2015 across OU3 have been well below the 1 percent solubility rule (aside from an
anomalous concentration reported at AFGMW-10 on 10/23/97 and not confirmed by
follow-up sampling on 11/6/97). Thus, DNAPL is not present at OU3 for TCE, PCE, or
1,1,1-TCA and therefore it does not support OU3 as the source of the high CVOC
concentrations detected in the two-mile-longplume at OU4.
EPA Response:
Groundwater contamination has been documented at OU3. The results of the OU3 Site Characterization
Summary Report and the OU4 RI Report indicate that there is groundwater contamination at OU3, and it
contributed to the groundwater contamination plume detected in OU4. As explained in Section 6.2.9 of
the OU4 RI Report, "[d]ata collected at OU3 shows there may potentially be or may have been a pool
of DNAPL at OU3. (Atlantic, 2005)." The absence of DNAPL, or the dissolution of existing DNAPL,
does not eliminate the possibility of a significant groundwater contamination plume in an
unconsolidated aquifer especially if a release has occurred over a long time period.
Although several documents submitted to EPA more recently with respect to OU3, including the OU3
Site Characterization Summary Report, and the draft OU3 RI Report, both prepared on behalf of Messer,
8
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do not indicate the presence of DNAPL at OU3, the OU3 RI/FS is still underway. EPA notes, however,
that it would be very unusual for a DNAPL source to attenuate without active treatment. If EPA
identifies, as a result of the ongoing OU3 RI/FS, that DNAPL is present at the Messer property, the OU3
remedy selection process will evaluate remedial alternatives to address the DNAPL, such as a source
control measure. EPA does not anticipate that this would impact the ability to design and implement the
OU4 remedy.
As described in the OU4 Proposed Plan and in the ROD, EPA has identified several sources
contributing to the OU4 groundwater contamination; these sources are being or will be remediated
under separate actions. Both EPA and NJDEP are working toward achieving cleanup plans for all
major sources of groundwater contamination at the Site.
• Executive Summary Comment: EPA concludes that CVOC concentrations in groundwater
at SL-4D are from OU3. But a monitoring well installed upgradient of SL-4D reported
CVOC concentrations of approximately 10 ug/L, while the total CVOC concentrations at
downgradient SL-4D are over 422 ug/L. This points to a contamination source other than
OU3.
4. The CVOC concentrations in monitoring well BOCMW-14 do not support OU3 as asource
of the high CVOC concentrations observed in SL-4D. Further investigation
is needed to identify other sources of CVOCs to SL-4D.
The OU4 RI suggests that CVOC concentrations in groundwater at SL-4D are from OU3.5
This statement is not supported by existing data. SL-4D cannot be used to assessOU3
chemical signature as it is located outside the Former BOC Property boundary (Figure 1-2
of the OU4 RI report). BOCMW-14 was installed upgradient ofSL-4D to assess whether
there might be a connection between OU3 impacts andSL-4D. The totalCVOC
concentrations reported in BOC-MW14 were approximately 10 ug/L while the SL-4D total
CVOC concentration is over 422 ug/L. This indicates that SL-4D has been affected by other
sources of CVOCs. As shown in Exhibit 1 (Figure 4.3-6 in the 2020 OU3 SCSR), there is a
significant increase in CVOC concentrations between the lower concentrations detected at
the onsite OU3 monitoring wells (PZ-4A, SIP-2D andPZ-A5) and the higher concentrations
detected at downgradient SL-4D. BOCMW-14 confirms the break in the lower CVOC
concentrations at OU3 to the higher CVOC concentrations at SL-4D. Additional
investigation is needed to locate the source of CVOCs to SL-4D.
9
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Exhibit 1 - Locations of SL-4D, OU-3 and BOCMW-14
Green Line -
OU3 Boundary
BOCMW-L4_
Atlantic
Environmental Consulting Sen-ices. LLC.
20152016 TCE Isopie® Map (Above Saprolitei
EPA Response:
Groundwater contamination has been documented at OU3. The OU3 Site Characterization Summary
Report and the OU4 RI Report both show that groundwater contamination at OU3 has contributed to the
groundwater contamination detected in OU4. The potential OU3 source areas include past and or
present DNAPL releases as discussed in Section 6.2.9 of the OU4 RI Report, which states that "[d]ata
collected at OU3 shows there may potentially be or may have been a pool of DNAPL at OU3. (Atlantic,
2005)." The potential contemporary absence of DNAPL, where DNAPL was previously identified, does
not eliminate the possibility of a significant contribution to the groundwater contamination plume in an
unconsolidated aquifer over long time periods. The current data collected from well SL-4D indicate that
OU3 source material is present in SL-4D. As indicated above, the chemical characteristics of
groundwater at OU3 have not changed significantly over the life cycle of the investigation activities. In
summary, source material from OU3 has contributed to the OU4 groundwater plume. Contaminated
groundwater flows from source areas west and then south/south-east commingling with other sources
area to form the OU4 plume. This was determined by analysis of a robust data set from numerous
groundwater samples collected from a large number of wells from the area-wide monitoring well
network that exists due to investigation and/or cleanup activities at OU1, OU3, OU4 and the Detrex
property.
• Executive Summary Comment: EPA 's shallow contour map for OU4 is inaccurate,
ignoring the existing Detrex groundwater contour maps (included as an appendix to the
OU4 RI report) that show a north east groundwater flow direction in the shallow and
intermediate portion of the aquifer. This shows that impacts to SL-4D (as well as the area
further downgradient) are likely from Detrex.
5. The OU4 shallow contour map is not consistent with other groundwater contourmaps
from the Detrex site that show shallow groundwater flow northeast toward
SL-4D. Additional data analyses are necessary to provide comprehensive groundwater
10
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flow contour maps.
The 0U4 RI 's shallow potentiometric surface map6 relied solely on existing 0U4
monitoring wells for the groundwater contour maps to depict the shallow and deep aquifers
of the P-R-M, which only show a southerly groundwater flow direction south of Oil'3 in the
shallow and deep portions of the aquifer. In developing the 0U4 RI, the EPAdid not
consider the existing Detrex groundwater contour maps for the shallow and intermediate
portions of the P-R-M aquifer that show a northeast groundwater flow direction. For the
0U4 RI groundwater contour maps to be complete, the shallower groundwater contours as
provided in the 2012 Langan report for the Detrex site (included as Appendix A in the 0U4
RI) would need to be added. The area to be included is shown in Exhibit 2. Due to the
blown semi-confining units in the P-R-M aquifer, there are varying groiindwater f/ow
directions in the intermediate and deeper portions (separated by semi-confining units) of
the aquifer. Exhibits 3 and 4 depict the groundwater direction in the intermediate
(northeast and not south) and the deeper (south consistent with Figure 3-5 of the 0U4 RI)
portions of the P-R-M at the Detrex facility. This defined groundwater flow direction near
0U3 and Detrex indicating that impacts to SL-4D andfurther dow ngradient are likely from
Detrex. Additional data analysis is required to produce comprehensive groundwater flow
maps.
Exhibit 2 -Area of OV4 to Include Shallow Groundwater Contours from Detrex Reports
11
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Exhibit 3 - Intermediate Depth Groundwater P-R-M Contours from Detrex (Figure 19b)
Red Arrow is interpreted
groundwater flow direction
from the groundwater
contour map (Northeast)
* wKr 1M
i^EESw-4D
SB-28
SCALE IN FEET
12
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Exhibit 4 - Deep Groundwater P-R-M Contours from Detrex (Figure 19b)
EPA Response:
As indicated in the Detrex 2012 investigation report, which is included as Appendix A to the OU4 RI
Report, the upper water bearing zone at the Detrex property is a perched water zone. The Detrex 2012
investigation indicates that the perched water table has little regional significance and that the
groundwater plume from the Detrex property flows consistent with the regional groundwater flow
direction (southeast flow). As discussed in EPA's response to comments above, this has been
identified as a source to, and part of, the OU4 contamination plume. The combined Site remedies
(OUs 1, 2, 3 and 4) will require that source control be effective over the long term with capture of
contaminated groundwater flow that contributes to the OU4 groundwater plume, and Site source
control measures including at the Detrex property will also be put in place under the oversight of
NJDEP.
• Executive Summary Comment: EPA 's OU4 RI geologic cross-sections contain no
concentration isocontouring or hydrogeologic unit interpretation, leading to an
oversimplified representation of the subsurface. Thus, the remediation evaluated in the
RI/FS may miss the portions of the plume requiring treatment and prevent a groundwater
remedy that effectively targets and treats the contamination.
13
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6. The 0U4 RI geologic cross-sections are not sufficiently detailed to fully understand the
nature and extent of contamination in a complicated hydrogeologic setting, which
interferes with identifying cost-effective groundwater remedies in the 0U4 FS. Detailed
geologic cross sections in the 0V4 RI are needed to address any data gaps identified.
The EPA geologic cross-section figures 4-7, 4-8 and 4-9 of the 0U4 RI do not provide the
identified nature and extent of CVOC contamination in the P-R-M aquifer relative to the
sub-aquifer units. No concentration isocontouring or hydrogeologic unit interpretationis
are provided. See Exhibit 5 below:
Exhibit 5 - Representative 0U4 Cross-Section of P-R-M
B
¦B^L
soo isao isao row 750:
t>j4 ww-;'3
GU« MW-71
OW IfW-ID
Tttmaiorewm <.»S6)
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• Cm: wiTfllr*ni)pSrr^-l «i MfflpteQ
cchiUo «i 'Air 2Di 7 ui -muitta iim Ktt9tofl wsw« are in uj<
~ GHMflilMMf (Kit AM
GiTOfffrwtw Etwairri Etafxe
£rouM*ai& Eavau'i in smai
-- Orwind S'J'br';
9X*
U - nix a»KKO aswa 7i« quamuton knt
J • £SB1BM41 Hit CffPIlM
103 SEF%
DISTRIBUTION OF VOCS IN HVDROGEOLOGtC CROSS-SECTION B-B'
CINNAMWSON GROUNDWATER CONTAMINATION SITE OU*
As is discussed further below, a review of the P-R-M aquifer cross-sections developed at
other contamination sites demonstrates that there is preferential contaminant flow in more
permeable portions of the aquifer and vertical migration of contaminants when semi-
confining units are absent. The absence of hydrogeologic and contaminant interpretation in
EPA's cross-sections provides an oversimplified representation of the subsurface which
does not allow for a full analysis of contaminant location and transport. This in turn has led
EPA to develop and propose remedies in the FS that can miss optimal contamination
capture and may result in a remedy that is neither cost-effective nor remediates the bulk of
the contaminant mass.
There are two excellent examples available to EPA of cross-sections of the P-R-M aquifer
with the technical details described above: the 2012 Lcmgan report for the Detrexsite
14
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(included in the 0U4 RI Appendix) and the remedial investigation report for the nearby
Puchack Wellfield Superfund Site.
The 2012 Langan report correlated the various more permeable aquifer units with semi-
confining units above and below the more permeable aquifers (Exhibit 6) in the P-R-M. The
figure shows the plumes migrating within each of the aquifer subunits with differential
velocities (and potentially different flow directions) due to geologic layering. The 2012
Langan cross-section figure below demonstrates that contamination is most extensive in the
middle aquifer portion of the P-R-M and not at the base (near the bedrock) due to localized
semi-confining units. This could mean that contamination (andpreferential flow paths)
could be missed if the full vertical section from the water table tothe saprolite (i.e.
weathered bedrock) is not fully characterized. Therefore, the remediation planned in the
0U4 FS could be missing portions of the plume requiring treatment, thereby incorrectly
selecting "pump and treat" as the remedy and underestimating the costs and timeframe
requiredfor remediation. Conversely, better delineation is more likely to lead to a refined
groundwater treatment remedy that effectively treats the contamination, especially when
considering that 90% of the contamination flows through 10% of the aquifer system.
Figure 6 Fly drogeologic Cross-Section of P-R-M with Concentration Contours
15
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The Puchack Wellfield Superfund Site, located about five miles southwest, similarly
addresses groundwater contamination within the P-R-M aquifers and has taken extensive
efforts to correlate the aquifer units in order to ensure an effective and efficient remedy. An
example of the hydrogeologic understanding for remedial action planning/implementation
at that site is in Exhibit 7. Barringer, J.L., Walker, R.L., Jacobsen E., and Jankowski, P.,
2011, Hydrostratigraphy, soil/sediment chemistry, and water quality, Potomac-Raritan-
Magothy aquifer system, Puchack Well Field Superfund site and vicinity, Pennsauken
Township, Camden County, New Jersey, 1997-2001: U.S. Geological Survey Scientific
Investigations Report 2009-5179, p 109.
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Exhibit 7 Geologic Cross-Section of the P-R-M from Puchack Well Field Superfund Site
^gr~~ar~LJ
» i ? 1 1 , v s . i ^ '"I-—- -*¦ -< T\ J ' _ <• * ~*—TT
v— s ^ ' ' \— \
s * — ¦ S \ * - s * *" ¦
EXPLANATION
- Wd! bcabcn shown n
hydrostrahgraphfc section
¦ Wai s croon. Top lumber a weQ n,
number is tho tctai chromium cor
, _ , &. Bottom
' numbers tho tctai draniim cdcortraban.
Bctd number hriicaixa chromium concsnlrarinr
cxcoodinc New Jsreoyr madmum canljfnnant level
oi TOO microgram! per liter (1999 - 3001 daaal.
Number in parenthesis is pctentiomotric head,
in feet Datum is ssa level.
Puchack
- PotantksTiBtric contour - Shows altitude at which water
would have stood in tightly cased wells, 2DQ1- Contour
interval 1 foot Datum b see levei
Arrows show General dracbon of groundwater flow.
Hydrostrnbgraphy o# the Potomoc-Raritan-Magothy aquifer system
in the Pennssuken Township and vicinity
layer Unit
A-l Upper aquifer
C-l Upper/Middc confining unit
A-2a Middle aqufar, upper and
A-2C1 Mi ddte aquifer, intarbedded confining unit
A-2b Middle aqufer, Icwer sand
C 3a Middkv'lower cor firing unit,, upper cccfnhg unrt
C-2AI Middki'Lower confining unit, intermediate sand
C 2b Middles/Lower confining unit, lower confining unit
A-la Lower aquiar. uppor icno
A-lb Lotwr aqufor, miadw zone
A Jc Lower aqufcfer, lower lone
C-3 Basal confining unit
GAMMA LOG
hcraasmg raSatlcn
Nate: Line of section shown on Plate 2 in Final Operable Unit 1 Remedial Investigation Report by CDM Federal
Programs Corporation dated June 22,20G5, Figure prepared by the USG5 Figure 0111 00-2
The Langan and Puchack cross sections consider these more permeable units and semi-confining units
in the interpretation of contamination extent and modes of transport. For the OU4RJ cross-sections to
accurately reflect the effects of the hydrogeologic system on contaminant transport, the cross-sections
must correlate the various aquifer units and evaluate the differential groundwater flow directions and
transport times within each aquifer to determine the extent of the contamination (horizontally and the
source(s) of the contamination. For all the reasons discussed\ refined hydrogeologic cross-sections are
most important in the area south of Union Landing Road to the south of O U3 and to the east of 'Delrex.
EPA should provide detailed geologic cross sections in the OU4 Rl. These refined hydrogeologic cross-
sections will allow for a full understanding of the location of the impacts and geologic pathways of the
contaminant transport, which will lead to a targeted and more cost-effective remediation.
EPA Response:
17
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The geologic cross sections developed by EPA and included in the OU4 RI and FS Reports provide
the level of detail necessary for the completion of the OU4 RI/FS, Proposed Plan and ROD. They
reflect the geologic nature of the subsurface aquifer lithology and provide detailed data regarding
water levels, depth to groundwater and contaminant concentration data that is used to evaluate plume
conditions. The OU4 groundwater data set is robust and the resulting site-conceptual model reflects
the large number of groundwater analyses collected from an area-wide monitoring well array. A
more detailed correlation of aquifer units can be conducted during the pre-design investigation for
the selected remedy, in order to ensure that the optimal placement of recovery wells occurs.
The geologic cross sections in the OU4 RI Report are similar in detail to the SCSR submitted to
EPA by Messer as a part of the OU3 RI/FS. (See Figure 3-2 through Figure 3-5).
In addition, the data-based conceptual site models developed using data from OU4 major source
areas including the OU1 area, the Detrex investigation and OU3 are very similar to each other (and
similar to the conceptual site models for other sites with a CVOC plume in unconsolidated aquifers).
Specifically, CVOC contamination tends to form a relatively narrow high-concentration plume
preferential path (as indicated by the large OU4 plume that has developed over time) that travels
with advective flow and disperses laterally while continuing to flow downgradient. (See OU4 RI
Report, Sections 5 and 6).
At the Puchack Site, the detailed specific cross-section provided with the Messer comment letter was
developed to support an in-situ groundwater remedy for a chromium-contaminated aquifer and the
source of the figure is not the Puchack Site RI/FS but a USGS regional groundwater study. The citation
is: Barringer, J.L., Walker, R.L., Jacobsen E., and Jankowski, P., 2011, Hydrostratigraphy,
soil/sediment chemistry, and water quality, Potomac-Raritan-Magothy aquifer system, Puchack Well
Field Superfund site and vicinity, Pennsauken Township, Camden County, New Jersey, 1997-2001:
U.S. Geological Survey Scientific Investigations Report 2009-5179, p 109. The Puchack Site cross
sections developed in the Puchack RI/FS are similar in detail to the OU4 Cinnaminson RI/FS geologic
cross section. (See Final Remedial Investigation Report, Vol.1 Puchack Well Field Site OU2
Pennsauken Twp. NJ (Figs. 4-4a, 4-4b and 4-4c.). https://semspub.epa.gov/work/02/109575.pdf
The Detrex figures provide useful information regarding the aquifer and were submitted on behalf of
Detrex, by Langan, Inc., the New Jersey Licensed Site Remediation Professional for the Detrex
property, to NJDEP for review and approval. Figures 23-a, 23-b, 23-c, 23-d and 23-e, which are plane
view figures and cross sections indicating the groundwater plume, show that the contamination from the
Detrex property flows in a southeast or southern direction in accordance with the regional groundwater
flow conditions.
• Executive Summary Comment: EPA collected insufficient groundwater samples
(horizontally or vertically) to delineate groundwater impacts and identify source areas in
the area north of SL-4D, east of Detrex, and south of OU3 to support the conclusions
depicted in the OU4 RI Figure 4-6.
18
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7. Horizontal and vertical groundwater samples are insufficient to delineate groundwater
impacts and identify source areas in the areas north of SL-4D, east of Detrex, and
south of 0U3 and, further, do not support EPA's conclusions in OU4 RI Figure 4-6.
The 0U4 RI is missing detailed geologic cross sections.
EPA's Figure 4-6 (Distribution of Total Ethenes/Ethane) depicts 0U3 as the primary
source of CVOC impacts to SL-4D (Exhibit 8). As explained in previous comments, SL-4D
has likely been affected by other sources of CVOCs and groundwater flow direction in the
P-R-M shallow and intermediate zones is northeast from Detrex toward SL-4D.
EPA's Figure 4-6 shows a disconnect between the CVOC source at Detrex and SL-4D.
Figure 4-6 appears to consider the 2014 LATA hydropunch sample locations to delineate
the horizontal extent of the impacts in this area. Groundwater was only sampledfrom one
interval in the aquifer per each 2014 LATA sampling location, however, and vertical
impacts were not delineated. EPA 's interpretation of groundwater impacts and the
separation of contamination between the Detrex and 0U3 sites may be due to LATA
hydropunch sampling location 547. The depth of SL-4D is 120-125ft below ground surface
while hydropunch sampling location 547 is 61 ft below ground surface.
Therefore, the 60 ft of aquifer below this groundwater sampling point where contamination
could be flowing towards SL-4D were not characterized. As a result, there cannot be solid
line demarcation contours on Figure 4-6 near SL-4D. EPA should provide detailed geologic
cross sections in the 0U4 RI.
Exhibit 8 - Additional Analysis Considerations for Figure 4-6 from 0U4 RI Report
19
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EPA Response:
Groundwater level measurements and groundwater analytical samples collected during the OU4
RI, in combination with data collected at the Detrex property, OU3, and the SLI Landfills, support
the identification of these properties as source areas to the OU4 plume. In 2014, twenty
Hydropunch® groundwater samples were collected from 20 boring locations as a part of the OU4
RI. In 2019, seventy-two groundwater samples were collected from 13 Geoprobe® borings
between River Road and the Delaware River.Groundwater samples were collected at five-foot
intervals from the water table to weathered bedrock (saprolite) from each boring and analyzed for
CVOCs. In addition, 61 groundwater samples were collected from 45 monitoring wells as part of
the OU4 RI. Additional groundwater samples were collected from 16 of 45 monitoring wells to
support contaminant characterization. The data collected from these sampling events, in addition
to historic data, results in thousands of contaminant analyses that were used in the determination of
the nature and extent of contamination and identification of source areas associated with the OU4
groundwater contamination.
• Executive Summary Comment: The chemical signature of upgradient SL-4D is not similar
to downgradient monitoring wells OU4 MW-7S TD, undermining EPA's conclusion that
OU3 is a source of the high CVOC concentrations detected in the two-mile-long plume.
8. The chemical signature of upgradient SL-4D is different from downgradient OV4 MW-
7S/I/D and do not support the conclusion that OU3 is a source of a two-mile-long
plume.
20
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The 0U4R1 concludes that, "Groundwater samples collected at 0U4 MW-7S/I/D show a
similar chemical signature as the CVOCs in groundwater at 0U3 (SL-4D). "7 This
statement is not supported by existing data. The chemical signature for SL-4D (at the head
end of 0U4) and 0U4 MW-7S/I/D (located downgradient) are not similar. The sample from
SL-4D contains approximately 50% TCE and 50% cis-1,2-DCE. By contrast, samples from
downgradient OU4-MW-7/S/I contain about 62% TCE and 30% cis-1,2-DCE. SL-4D has
less TCE as a percentage than MW-7S11). EPA has acknowledged that dilution and
dispersion (and potential biode gradation) of TCE from a source would cause TCE
concentrations to decrease as the plume migrates downgradient8. Therefore, TCE
concentrations would not increase as groundwater travels downgradient, contradicting the
conclusion that 0U3 is a source of an approximately two-mile-long plume. The increasing
TCE concentrations are more likely due to another TCE source that is not associated with
SL-4D or 0U3. In addition, no groundwater modeling or other data that provides a
definitive link between 0U3 and the down gradient areas from SL-4D have been provided.
If this information has been developed it should be presented in the 0U4 RI/FS. No firm
conclusions can be drawn until additional lines of evidence are developed including 1)
more detailed hydrologic analysis of the area south of Union Landing Road and north of
SL-4D and 2) additional chemical signature analysis such as compound specific isotope
analysis to fingerprint the sources and the downgradient portion of the 0U4 in this area
(SL-4D to 0U4MW- 7S/I/D).
EPA Response:
The contamination detected at MW-7S/I/D is sufficiently similar to the contamination detected at SL-
4D to support the conclusion that CVOCs detected at MW-7S/I/D and SL-4D are part of the OU4
plume. (See Exhibit 8 for locations of MW-7S/I/D and SL4-D). However, as indicated in the OU4 RI
and in the OU4 Proposed Plan at page 10, as contaminated groundwater migrates from source areas it
commingles within the OU4 plume. The fate and transport of the groundwater contamination from
Messer is summarized in the OU4 RI Report (Section 6.3.4), which states: "TCE at Messer migrates
beneath a septic leach field that drives the aquifer from aerobic to anaerobic conditions resulting in a
large amount of reductive dechlorination of PCE and TCE to cis-DCE, 1,1-DCE, and VC (monitoring
wells OU4 MW-7S/I/D, SIMW-2D, SIMW-3D, SIMW-4S, SIMW-19M/D, SL-4D, SL-7RP, and
Figures 4-3, 4-6, and 4-8). As the CVOCs migrate away from OU1 and OU3, the infiltration of
oxygen rich precipitation likely returns the aquifer to its natural aerobic conditions reducing the
potential for continued reductive dechlorination as the CVOCs migrate away from the source areas.
TCE/PCE released into the aerobic aquifer at Detrex are not being reductively dechlorinated,
resulting in very little cis-DCE, 1,1-DCE, and VC (monitoring wells OU4 MW-2I/D, OU4 MW-9D,
and Figures 4-3, 4-6, and 4-7)." In addition, geologic cross sections in Figure 3.3 and Figures 4.1.27-
4.1.28 of the Messer Site Characterization Summary Report are consistent with Messer as an
upgradient source to contaminated groundwater within OU4.
• Executive Summary Comment: PCE concentrations are at higher concentrations in
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samples from SL-4D versus concentrations in upgradient 0U3 wells. Again, this suggests
another source of CVOCcontamination impacting both SL-4D and the area further
downgradient of that well.
9. PCE concentrations are higher in samples from SL-4D versus upgradient 0U3
wells, strongly suggesting the existence of another source of CVOC contamination
impacting SL-4D and the area further downgradient.
0U4 RI concludes that "groundwater containing a unique CVOC chemical signature
associated with 0U3 and potentially 1,4-dioxane migrates to the southeast creating a
roughly two-mile-long plume of contaminated groundwater. "9 EPA contends that there is a
> 50 ug/L total CVOC plume originating from 0U3. To support this contention, EPA
connects SL-4D and SL-7RP on Figure 4-6. But as is described above, there is a break in
the lower CVOC concentrations at 0U3 to the higher CVOC concentrations at SL-4D. To
examine the possibility of another source of CVOCs to SL-4D, Messer reviewed the PCE
data from SL-4D. PCE has been reported at concentrations between 2 and 10 ug/L
since1998 (4 ug/L in May 2017). The highest PCE concentration in monitoring wells on the
Former BOC Property in 2015 was 1.3 ug/L. Because SL-4D is downgradient of 0U3
monitoring wells, it is improbable that downgradient concentrations of PCE at SL-4D
would be higher than 0U3 PCE monitoring well concentrations if the flow paths in fact
connected 0U3 to SL-4D. Additionally, the 0U4 RI states that reductive dechlorination in
the flow path between 0U3 and SL-4D has reduced the CVOCs from PCE/TCE to daughter
products like 1,2 cis-DCE, and vinyl chloride. Reductive dechlorination wouldfurther
reduce PCE concentrations as the PCE travels downgradient. The 0U4R1 does not explain
how - if there is reductive dechlorination and attenuation - PCE can be in 0U3 source well
locations at low concentrations and in SL-4D downgradient at higher concentrations.
Therefore, the conclusion that 0U3 is the source of a two-mile-long plume that reaches the
Albany Road production wells is not supported. A more detailed hydrogeologic analysis is
required of the area south of Union Landing Road and north ofSL-4D, along with additional
chemical signature analysis such as compound specific isotope analysis.
EPA Response:
The OU4 plume fate and transport of the groundwater contamination from OU3, including
MW-7S/I/D, SL-7RP and SL-4D, (see Exhibit 8 for locations of MW-7S/I/D, SL-7RP and
SL4-D) and leading to the large comingled plume is summarized in the OU4 RI Report
(Section 6.3.4) as "TCE at Messer migrates beneath a septic leach field that drives the
aquifer from aerobic to anaerobic conditions resulting in a large amount of reductive
dechlorination of PCE and TCE to cis-DCE, 1,1-DCE, and VC (monitoring wells OU4
MW-7S/I/D, SIMW-2D, SIMW-3D, SIMW-4S, SIMW-19M/D, SL-4D, SL-7RP, and
Figures 4-3, 4-6, and 4-8)". A review of the OU4 RI indicates that all three monitoring
wells MW-7S/I/D, SL-7RP and SL-4D have relative contaminant proportions that are
similar to the relative contaminant proportions found at the OU3 source areas in that the
degradation profile is alike. Section 6.3.4 of the OU4 RI further indicates "As the CVOCs
migrate away from OU1 and OU3, the infiltration of oxygen rich precipitation likely returns
22
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the aquifer to its natural aerobic conditions reducing the potential for continued reductive
dechlorination as the CVOCs migrate away from the source areas.
Conversely, TCE released into the aerobic aquifer at Detrex is not being reductively
dechlorinated, resulting in very little cis-DCE, 1,1-DCE, and VC (monitoring wells OU4
MW-2I/D, OU4 MW-9D, and Figures 4-3, 4-6, and 4-7)." The contaminant profiles in
monitoring wells downgradient of Detrex reflect the fact that limited dechlorination
occurred. In addition, geologic cross sections in Figure 3.3, and Figures 4.1.27-4.1.28 of the
Messer Site Characterization Report are consistent with Messer as an upgradient source to
contaminated groundwater in OU4.
Groundwater Modeling
• Executive Summary Comment: None of the modeling allegedly performed by EPA is
included in the RI/FS. Absent full groundwater modeling, there is nothing in the OU4 RI or
FS to support remediation effectiveness, remediation timeframe and cost analyses.
10. Full groundwater modeling needs to be provided in the OU4 RI or FS to support
remediation effectiveness, remediation timeframe, and cost analyses.
EPA states in the OU4 FS that "empirical groundwater flow and solute transport data
collected in the OU1 and OU4 studies/investigations were used in analytical models
(aquifer flushing andfirst-order decay) to estimate the period ofperformance of each
remedial alternative. "I0 This modeling was not included in the OU4 RI or FS. The
modeling results must be provided in the OU4 RI or FS to determine the accuracy of the
remediation timeframe estimates, detail the expected lifespan of the full remediation for
each alternative, and to ensure full capture of the contamination without migration of
contamination into new areas in OU4. If there are excessive overall active remediation
timeframes, the remedial alternatives currently analyzed may not be the most cost-
effective. limited modeling cannot result in the selection of remedial alternatives that
are efficient and effective, as required by CERCIA.
EPA Response:
Modeling was completed to support EPA's calculation of the remediation time frames of the OU4 plume
as described in the OU4 RI and FS Reports. All of the data needed to complete the analytical modeling
are presented in the OU4 RI and FS Reports, and citations were provided to identify the methods used to
create the "batch flushing" analytical model and complete the first-order decay analyses. Additionally,
upon request from Messer, EPA provided the data used in the modeling performed for the OU4 RI/FS in
an alternate format (EXCEL file) and included it in the Administrative Record.
The methodology used for the flushing model and first-order decay are referenced in the OU4 RI/FS
Reports and can be found in:
• Mark Brusseau, 1996, Evaluation of Simple Methods for Estimating Contaminant Removal by Flushing,
Groundwater, Vol. 34, No. 1.
• C. J. Newell, et al, 2002, Calculation and Use of First-Order Rate Constants for Monitored Natural
23
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Attenuation Studies, Unites States Environmental Protection Agency, Ground Water Issue, National
Risk Management Research Laboratory, Cincinnati, Ohio.
The results of the flushing model are presented in the OU4 FS Report. The purpose of the modeling is to
develop estimated time frames for remediation to achieve remediation goals. The data used, where
appropriate, included current and historical groundwater contaminant concentrations collected in areas
of the plume that have undergone many years of remediation (under OU1) as well as first order decay
rate input using standard values for COCs.
The results of the modeling are summarized in the OU4 Proposed Plan and they are consistent with the
empirical observations and data that have been collected during Site investigations and remedial actions
conducted at the Site.
• Executive Summary Comment: The EPA OU4 FS rejects in-situ enhanced reductive
dechlorination or passive/reactivetreatment technologies, even though the "pump and
treat" alternatives also require trenching and plumbing.
11. The OU4 FS should not eliminate in-situ enhanced reductive dechlorination or
passive/reactive treatment technologies, as these are proven, efficient and cost-effective
remedies.
The OU4 FS eliminates in-situ enhanced reductive dechlorination or passive/reactive
treatment technologies from further consideration in the remedial alternatives, and states
that "[t]he density of buildings, roads, and subsurface utilities within the footprint of the
groundwater plume would also make the implementation of PRE impractical. " However, the
"pump and treat" alternatives include approximately eight miles of trenching and plumbing
across the same residential neighborhoods with the same infrastructure concerns.
Eliminating these proven technologies from consideration as remedial alternatives is
premature and fails to ensure that any required remediation is conducted in the most
efficient and effective manner, as required by CERCLA.
EPA Response:
As indicated on page 6-10 and 6-11 of the OU4 FS Report, the highly developed commercial/residential
nature of the area would make it difficult to achieve the necessary injection density and result in
significant costs/delays and implementation issues for the in-situ enhanced reductive dechlorination
technology; therefore, this technology was not retained for further evaluation. The trenching and
plumbing required for the extraction and treatment alternatives can normally be conducted along public
roadways and rights-of-way that are less disruptive and more implementable than the need to place long-
term in-situ injection points on numerous private properties given the magnitude of the contaminant
plume.
Messer's General Comments
1. The Proposed Plan states that "[a] previous vapor intrusion study was also conducted in
2009 of a neighborhood to the south of the Messer property, located near the Detrex
Corporation (Detrex) property. There were no issues found with vapor intrusion in this
24
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neighborhood, and thus no additional sampling events have been conducted in that
location. " The Proposed Plan also states that "Groundwater contamination migrating
northwest will be addressed as part of 0U3, while contamination migrating to the
southeast is included as part of the 0U4 Proposed Plan. "
a. The VI data and the risk assessment/conclusions for the neighborhood to the south of the
"Former BOC Property" should be included in the 0U4 RI and summarized again in the
Proposed Plan in the "Human Health Risk Assessment" section for completeness.
b. The Proposed Plan should be updated to state that "Groundwater contamination migrating
northwest and to the east of the former Hoeganaes current Seabox Landfill will be addressed as
part of the OU3... ".
EPA Response:
VI investigation/mitigation is being conducted by EPA as an OU3 Time-critical Removal Action, and
therefore the OU4 risk assessment did not include VI human health risk assessment, and VI data are not
included in the OU4 RI Report. As indicated in the OU4 RI Report, in conjunction with the OU3 RI/FS
being implemented by Messer, EPA initiated a VI investigation/mitigation of nearby residential
properties in March 2009. The VI investigation revealed vapors in excess of EPA screening level values
from CVOCs, including TCE, associated with contaminated groundwater in sub-slab soil gas, and
indoor air at several residential properties. At the time of the OU4 RI, EPA had tested 18
homes/businesses and had installed 6 treatment systems, and the OU4 RI Report included a brief
summary of that work, explaining that the work is being conducted as a part of the OU3 response.
Additional investigation/mitigation has occurred since that time. All VI investigation/mitigation
activities are associated with OU3 and will be documented and discussed in the OU3 remedy selection
process; thus, there is no reason to update the OU4 Proposed Plan or OU4 human health risk assessment.
2. The OU4 Rl/FS/Proposed Plan repeatedly refers to OU3 as the "Messerproperty. " This is
somewhat misleading. Messer does not own the 74-acre property. Rather, Messer is responsible
for OU3 as the legal successor to The BOC Group, Inc., its prior owner, which sold the property
over 16years ago. For accuracy, Messer suggests that EPA refer to OU3 as the "Former BOC
Property" in the text and in allfigures.
EPA acknowledges the comment regarding the current ownership of the OU3 property. For consistency,
the ROD continues to refer to the property as the Messer property, but also indicates the relationship of
Messer, formerly Linde LLC, to The BOC Group, Inc. .
3. The OU4 RI states that " 1,4-dioxane is considered a Site-related contaminant as it is often used as
a solvent (PCE/TCE) stabilizer detected in the three potential source areas. " This is misleading,
as 1,4 dioxane is expected to co-occur with chlorinated solvents based on its uses as a stabilizer
for 1.1.1-TCA. Per the EPA Technical Fact Sheet dated November 2017, "Historically, the main
use (90 percent) of 1,4-dioxane was as a stabilizer of chlorinated solvents such as TCA. " Please
consider revising.
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EPA Response:
1,4-dioxane as an industrial product has primarily been used as a solvent stabilizer. As indicated in the
Messer comment, 1,4-dioxane is often used as a solvent stabilizer and is referenced by EPA in its 2017
Technical Fact Sheet as a "... stabilizer of chlorinated solvents such as TCA." Studies, including that
performed by Anderson et al. (2012) reported an important association between 1,4-dioxane and various
chlorinated solvents where approximately 94% of groundwater monitoring wells (evaluated in that
study) with detectable levels of 1,4- dioxane also contained TCA and/or trichloroethylene (TCE). While
1,4-dioxane was initially used as a stabilizer for TCA, but not for TCE in the records (Mohr, 2010), 64%
of 1,4-dioxane detections in monitoring wells were independent of TCA. Co-occurrence of 1,4-dioxane
with trichloroethylene in chlorinated solvent groundwater plumes at US Air Force installations: Fact or
fiction. October 2012 ¦ Integrated Environmental Assessment and Management 8(4) :7 31-7 DOI:
10.1002/ieam. 1306 Source ¦ PubMed. Authors: RichardH Anderson Janet K Anderson Paul A Bower). It
has been widely observed that the use of 1,4 dioxane in both commercial/industrial applications and
retail commercial applications, combined with improper storage and disposal of 1,4 dioxane-containing
solvent wastes and products, has resulted in 1,4-dioxane contamination mixing with other common
environmental pollutants in groundwater and industrial wastewater. As stated in the OU4 RI Report,
EPA considers the 1,4 dioxane to be Site-related. EPA anticipates that more data will be collected
during the pre-design investigation for the OU4 remedy.
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ATTACHMENT A - Proposed Plan
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Superfund Program
U.S. Environmental Protection Agency
Region 2
Proposed Plan
§ r>M|^7 lli Cinnaminson Groundwater Contamination Site
^ Operable Unit (OU) 4
Cinnaminson and Delran Townships, New Jersey
pRCf^
September 2020
MARK YOUR CALENDAR
Public Comment Period:
September 17,2020 - October 16,2020
EPA will accept written comments on the Proposed Plan
during the public comment period.
Virtual Public Meeting
EPA will hold a Virtual Public Meeting on Thursday,
October 1,2020 from 6:00pm-8:00pm EST to explain the
Proposed Plan and the other alternatives presented in the
Feasibility Study. To register for the public meeting,
visit https://cinnaminson-superfund.eventbrite.com
To learn more about the public meeting,
visit https://www.epa.gov/superfund/cinnaminson or contact
Natalie Loney, Community Involvement Coordinator
at lonev.nataiie@epa.gov or (212) 637-3639.
Anyone interested in receiving materials for the public meeting
in hard copy should either email or call Ms. Loney with such a
request by Friday, September 25.
The Administrative Record file containing the documents
used on in developing the alternatives and preferred cleanup
plan is available for public review at
https://www.epa.gov/superfund/cinnaminson
EPA's website for the Cinnaminson Groundwater
Contamination Site:
https://www.epa.gov/superfund/cinnaminson
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the remedial
alternatives that the United States Environmental
Protection Agency (EPA) considered to remediate
contaminated groundwater at the Cinnaminson
Groundwater Contamination Superfund Site (Site),
located in the Townships of Cinnaminson and
Delran, Burlington County, New Jersey, and
identifies EPA's preferred alternative, along with
the reasons for this preference.
The Site cleanup is being addressed in four phases
or Operable Units (OUs). The Operable Unit 1
(OU1) Record of Decision (ROD) was issued
September 1990 and addressed site-wide
groundwater primarily associated with the Sanitary
Landfill, Inc. (SLI) Landfills. The Operable Unit 2
(OU2) ROD was issued in July 2014 and addressed
capping of the SLI Landfills. Operable Unit 3
(OU3) addresses contamination associated with the
Messer, LLC (Messer) property located in
Cinnaminson Township, and a ROD is scheduled
for fiscal year 2021. Operable Unit 4 (OU4),
which is the subject of this Proposed Plan,
addresses other groundwater contamination outside
of areas already under remediation or
investigation. The Preferred Alternative,
Alternative 6, described in this Proposed Plan
includes groundwater remediation using pumping
and treatment near source areas and discharge of
treated water to surface water.
This Proposed Plan was developed by EPA, the
lead agency for the Site, in consultation with the
New Jersey Department of Environmental
Protection (NJDEP), the support agency. EPA is
issuing this Proposed Plan as part of its public
participation responsibilities under Section 117(a)
of the Comprehensive Environmental
Response, Compensation, and Liability Act of
1980, as amended (CERCLA or Superfund). EPA
will select a final remedy for contaminated
groundwater at OU4 after reviewing and
considering all information submitted during the
30-day public comment period.
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Community Role in Selection Process
EPA relies on public input to ensure that the
concerns of the community are considered in
selecting an effective remedy for each Superfund
site. To this end, the Feasibility Study (FS) report
and this Proposed Plan have been made available
to the public for a public comment period that
begins on September 17, 2020 and concludes on
October 16, 2020. A virtual public meeting will be
held via webinar and telephone conference on
October 1, 2020 at 6:00 PM to present the
conclusions of the Remedial Investigation (RI), to
elaborate further on the reasons for recommending
the preferred alternative, and to receive public
comments. Written comments on the Proposed
Plan should be addressed to: Alida Karas,
Remedial Project Manager, NJ Remediation
Branch, U.S. Environmental Protection Agency,
290 Broadway, 19th floor, New York, NY 10007 or
via e-mail karas.alida@epa.gov. Comments
received at the public meeting, as well as written
comments, will be documented in the
Responsiveness Summary Section of the ROD, the
document that formalizes the selection of the
remedy.
EPA 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 all the alternatives
presented in this Proposed Plan. This Proposed
Plan summarizes information that can be found in
greater detail in the final RI Report and final FS
Report and other documents contained in the
administrative record file for this Site.
Site Description
The Cinnaminson Groundwater Contamination
Site covers approximately 400 acres. The Site is
located in the townships of Cinnaminson and
Delran, Burlington County, New Jersey and
includes properties bounded by Union Landing
Road, U.S. Route 130, River Road and Taylors
Lane. The Site includes two closed landfills (SLI
Landfills) known as the northwest and southeast
landfills, along with residential and light to heavy
industrial properties. The Delaware River is
located northwest of the Site and U.S. Route 130
passes southeast of the Site. Two small streams,
Pompeston Creek and Swedes Run, receive run-off
from the Site and discharge into the Delaware
River. See Figure 1.
OU4 includes contaminated groundwater
underlying residential, commercial, and industrial
properties bounded to the southwest by Pompeston
Creek, to the northwest by the Delaware River, to
northeast by Swedes Run, and to the southeast by
New Jersey American Water (NJAW) New Albany
Road water supply wells. OU4 covers site-related
groundwater contamination from three major
sources and includes the contribution from the
individual sources and the commingled plume that
are being addressed by both federal and state
cleanup programs. The current land use at OU4
and the surrounding area ranges from industrial
and commercial to residential. Figure 2.
Groundwater contamination at the Site was
discovered in the early 1980s by the
NJDEP through the review of groundwater
monitoring data collected as part of the closure
plan for the SLI Landfills located between Union
Landing Road and Taylors Lane. Hazardous
substances were reportedly deposited in these
landfills. Contaminants including tetrachloroethene
(PCE), trichloroethylene (TCE), cis-1,2-
dichloroethylene (cis-l,2-DCE), vinyl chloride
(VC), 1,2-dichloroethane (1,2-DCA), benzene, and
arsenic were detected in the groundwater, soil, and
soil vapor. Based on this information, in June
1986, the EPA placed the Site on the National
Priorities List of Superfund Sites.
Operable Units and Contaminant Sources
OU1
2
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The two SLI landfills, originally owned by
Lockhart Construction Company, were operated as
sand and gravel mines. The mining operations
were terminated in the late 1960s.
The OU1 Remedial Investigation and Feasibility
Study (RI/FS) was performed by EPA from 1985
to 1989. The study primarily focused on
groundwater contamination emanating from the
two former SLI Landfills.
In September 1990, EPA issued the OU1 ROD.
The selected remedy included the following
actions: extraction and treatment of contaminated
groundwater primarily emanating from the SLI
Landfills; reinjection of the treated groundwater;
and installation and monitoring of additional wells
to ensure the effectiveness of the remedy.
After the design was completed, construction of
the treatment plant and installation of the
extraction, treatment, and reinjection system was
completed in January 2000. The system began
treating contaminated groundwater in May 2000.
In May 2013, SC Holdings, Inc. (SCH), a wholly
owned subsidiary of Waste Management Inc. and
the current owner of the landfills, submitted a
request to perform a "pump and treat system
monitoring assessment/shutdown test" (also known
as a Shutdown Study) since groundwater quality
had improved. The purpose of the proposed two-
year Shutdown Study was to evaluate if the
groundwater would be re-contaminated if the
treatment plant operation was temporarily shut
down. EPA reviewed and evaluated the results of
the two-year Shutdown Study. As a result, in 2016
a long-term monitoring plan (LTMP) was
developed to monitor groundwater to ensure
contaminant levels continue to improve. This
LTMP will continue while the temporary shutdown
remains in place.
OU2
3
OU2 addressed the source area contamination at
the SLI landfills. Landfill caps had been
previously constructed in 1987 pursuant to a
NJDEP Administrative Consent Order (ACO)
dated October 1984.
After SCH's design, construction and monitoring
of an enhanced landfill gas management system
and drainage improvements, the OU2 ROD was
issued in July 2014. The ROD determined that no
further remedial action was necessary for OU2 to
ensure protection of human health and the
environment. SCH maintains the landfill caps with
oversight by the regulatory agencies.
OU3
Messer LLC (Messer), formerly Linde LLC
(Linde), and before that BOC Gases, formerly a
division of The BOC Group, Inc which became
Linde, Inc. by name change, operated a facility
located on River Road (also called Broad Street).
In 2008, EPA and Linde, Inc. entered into an
Administrative Order on Consent (AOC) with EPA
for the performance of a RI/FS and a removal
action to address soil and groundwater
contamination that is located on or migrating from
the Messer property.
The results of prior sampling data, as well as RI
investigations conducted during the OU3 RI/FS
field investigations, showed that groundwater is
impacted by volatile organic compounds (VOCs),
primarily chlorinated solvents.
TCE, cis-l,2-DCE, and VC were consistently
detected in groundwater samples both on and off
the Messer property. The distribution of the VOCs
show source(s) of VOCs in the OU3 area, and
groundwater containing VOCs flows both to the
northwest (beneath Inman Street, Kern Street, and
Zeisner Street in Cinnaminson) where it potentially
discharges to the Delaware River, and the
southeast, where is mixes with VOCs from OU1
and other sources. Groundwater contamination
migrating northwest will be addressed as part of
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0U3, while contamination migrating to the
southeast is included as part of the OU4 Proposed
Plan.
Vapor Intrusion
In conjunction with the OU3 RI/FS, a vapor
intrusion (VI) investigation/mitigation of nearby
residential properties has been ongoing since
March 2009. To date, EPA has tested 18
homes/businesses and has installed 6 treatment
systems. All VI investigation activities are
associated with OU3 and are not included as part
of OU4.
A previous vapor intrusion study was also
conducted in 2009 of a neighborhood to the south
of the Messer property, located near the Detrex
Corporation (Detrex) property. There were no
issues found with vapor intrusion in this
neighborhood, and thus no additional sampling
events have been conducted in that location.
OU4
OU4 addresses groundwater contamination within
the Site that is not currently being addressed by
OU1, OU2, or OU3. The SLI Landfills, the Messer
property and Detrex property are the primary
identified sources of the OU4 groundwater
contamination.
A brief description of each source area property is
provided above for SLI Landfills and below for
additional sources.
Detrex Corporation
The Detrex property at 835 Industrial Highway,
Cinnaminson, New Jersey was first developed in
1972 by Whitesell Construction Corporation as a
multi-tenant industrial/commercial center. Detrex
began operations in 1972 as a storage, distribution,
and transportation facility for solvents used in
degreasers within an 8,000 square foot leasehold of
the property. From 1987 to 2006, Detrex operated
as a storage and transfer facility for wastes
4
containing chlorinated solvents, including PCE,
TCE, 1,1,1-trichloroethane (1,1,1-TCA),
methylene chloride, and trichlorotrifluoroethane.
By 1990, Detrex handled wastes containing PCBs,
herbicides, and other chemicals. In June 2002,
Detrex sold the solvent distribution portion of the
business and limited assets to Parts Cleaning
Technologies (PCT).
Multiple investigations have been performed under
NJDEP oversight at the Detrex property since July
2001 and are ongoing. These results show there is
an uncontrolled release of TCE, as well as other
contaminants, at the Detrex property impacting on-
Site soil and groundwater, downgradient
groundwater, and downgradient soil gas (Langan,
2012). This facility is a significant source of OU4
groundwater contamination. NJDEP expects to
require remediation of this source area under state
cleanup authorities, not as part of the federal
Superfund cleanup.
Messer
The Messer property is located at the intersection
of River Road (also called Broad Street) and Union
Landing Road. An investigation of the Messer
property was started in 1988 and showed that
groundwater had been impacted by VOCs
(primarily chlorinated solvents). Groundwater
samples collected during a RI/FS completed in
1999 show TCE, cis-1,2 DCE, and VC were
consistently detected in on-site monitoring wells
and that a source of TCE was located on the
Messer property. Groundwater samples collected
during the 1999 RI/FS also show TCE, cis-1,2
DCE, and VC had migrated downgradient with
groundwater to the south-southeast of the facility.
As mentioned above, the Messer property is being
addressed under OU3.
Sea Box Landfill
The Sea Box Landfill (formerly owned by the
Hoeganaes Corporation and now owned by 1001
Taylors Lane LLC, a subsidiary of Sea Box, Inc.)
is located between the intersection of River Road,
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Union Landing Road, and the Delaware River,
approximately one-half mile southwest of the main
Sea Box, Inc. manufacturing facility. The
approximate 400 feet by 2,300 feet (35 acres)
landfill was constructed on land surface and
partially on Delaware River dredge spoils material.
Prior to 1975, the material disposed of reportedly
consisted of wastes comprised of coke/lime dust,
iron oxide powder, and slag. From 1975 until
1985, coke/lime slurry, iron dust, slag, and electric
arc furnace (EAF) dust was disposed of in the
landfill. Reportedly, slag has not been disposed of
in the landfill since 1982, and EAF dust has not
been disposed of in the landfill since 1985. From
1982 through December 2000, slag generated from
the EAF process was handled in the south area of
the Sea Box property by International Mill
Services, Inc. for metals reclamation and beneficial
reuse.
TCE has been detected in groundwater samples
collected at the Sea Box landfill since 1984. The
highest TCE concentration of 130 micrograms per
liter ((J.g/1) (November 1988) was detected in a
monitoring well located along the southern
property line of the landfill. Groundwater samples
collected by Linde, Inc. on April 28, 2004 show
TCE was not detected from a groundwater sample
collected at the water table and TCE was detected
at 120 [j,g/l in a groundwater sample collected from
a zone above the clayey saprolite. TCE was
detected in groundwater samples collected from
monitoring wells on the Sea Box Landfill property
at concentrations ranging from below the limit of
detection to 36 jag/l.
Although very low concentrations of VOC
contamination occur in groundwater at this landfill,
it was not found to be as a significant source of
OU4 groundwater contamination as compared to
the Messer and Detrex properties.
SITE CHARACTERISTICS
Physical Setting
Based on the 2010 U.S. Census data, there were
15,569 and 16,896 people living in Cinnaminson
and Delran Townships, respectively. The Site is
bounded by undeveloped land, a light industrial
area and Taylors Lane to the north, Union Landing
Road to the south, a wooded and light
industrial area to the east and a heavy industrial
area to the west. The surrounding area consists
of a mixture of retail, residential and light-to-heavy
industrial properties. The land use in the area
of OU4 is predominantly used for residential,
industrial/commercial, transportation and
recreational purposes.
The highest elevation in OU4 is in the vicinity of
Taylors Lane and U.S. Route 130 (approximately
90 feet above mean sea level (msl)), and the lowest
elevation in OU4 is near the Delaware River
(approximately 5 feet above msl). Overland runoff
during precipitation events is generally directed
radially away from the topographic high at U.S.
Route 130 with runoff flowing towards Pompeston
Creek, Swedes Run, and the Delaware River.
Site Geology/Hydrogeology
The Site is located within the Coastal Plain
physiographic province in New Jersey. Most of the
OU4 study area is underlain by the Potomac
Raritan and Magothy (PRM) Formation which
overlies the Wissahickon Formation (bedrock) in
the south and eastern portion of OU1 and OU3.
The PRM Formation forms a southeasterly sloping
wedge of sediments that extend from land surface
to over 375 feet deep at the down gradient
southwest end of OU4. No regionally extensive
clay layers were encountered during drilling of the
OU4 RI borings that extended to bedrock. The
unconsolidated sediments of the Pennsauken
Formation are present in the north and western
portion of the OU3 area. The thickness of the
Pennsauken Formation ranges from a few feet to
approximately 30 feet at OU3 along Union
Landing Road.
5
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Hydrogeology - The two unconsolidated geologic
formations, PRM and Pennsauken described
above, are water saturated forming one
hydraulically connected aquifer called the PRM
aquifer. Groundwater level measurements and the
distribution of groundwater contaminants show
groundwater in the Pennsauken and PRM
Formations are hydraulically connected allowing
groundwater and groundwater contaminants to
migrate from the Pennsauken Formation into the
PRM Formation.
NJDEP classifies the PRM and Pennsauken aquifer
as a Class Ha, meaning it is a potential drinking
water aquifer and/or is currently used as a drinking
water supply. The PRM/Pennsauken aquifer is
also within an NJDEP Critical Water Supply Area
meaning that the amount of groundwater that can
be withdrawn is regulated by the NJDEP due to
over-pumping of the aquifer for municipal,
commercial and agricultural purposes.
The impact of the over pumping is apparent
considering that the natural hydraulic gradient
within the OU4 a was historically from southeast
to northwest with groundwater ultimately
discharging to the Delaware River. This is evident
in the USGS's pre-pumping groundwater
potentiometric surface map from 1900. However,
groundwater pumping in the area has reversed the
natural groundwater flow direction, causing
groundwater to migrate predominately from the
northwest to the southeast towards municipal,
industrial and irrigation wells as indicated in water
elevations collected during the OU4 RI.
Surface Water- OU4 lies within the Delaware
River, Pompeston Creek, and Swedes Run
watersheds. The section of the Delaware River at
OU4 lies to the northwest of the Site and flows in a
northeast to southwest direction. Pompeston Creek
has two branches (East and West) whose
headwaters both begin in Moorestown, NJ and
flow northwest through Cinnaminson and
Riverton, NJ to the Delaware River. Swedes Run is
located north of OU4 and drains an area
6
approximately 3.6 square miles from Moorestown
in a southeast to northwest direction into the
Delaware River. Swedes Lake is located to the
northeast of the Site.
NJDEP classifies the entire length of Pompeston
Creek as fresh water, non-trout waters (FW2-NT),
with the exception of the tidal marsh portion from
the U.S. Route 130 Bridge to Broad Street Bridge
in Riverton Township. This tidal marsh is
classified as a Category 1 water body [FW2-
NT(C1).
The wetland near Pompeston Creek varies in width
from 20 to over 800 feet. The water in the wetland
is greatly influenced by Delaware River tidal
fluctuations.
The Swedes Run wetland habitat varies in width
from 100 to over 600 feet. Similar to Pompeston
Creek, the water in the Swedes Run wetland area is
influenced by the Delaware River tide
fluctuations. Based on a consultation from United
States Fish & Wildlife Service (USFWS), there are
no threatened, endangered, and candidate species
and no critical habitat at the Site.
SUMMARY OF THE OU4 REMEDIAL
INVESTIGATION
The OU4 RI included the following work:
Installation of Temporary Well Points
In 2014, twenty Hydropunch® groundwater
samples were collected from 20 boring locations as
a part of the OU4 RI. See Figure 3.
In 2019, seventy-two groundwater samples were
collected from 13 Geoprobe® borings between
River Road and the Delaware River. See Figure 3.
Groundwater samples were collected at five-foot
intervals from the water table to weathered
bedrock (saprolite) from each boring and analyzed
for VOCs. The purpose of the investigation was to
further evaluate the contributing sources to
groundwater contamination north of the Messer
-------
property including the residential area where VI is
also under investigation/mitigation as part of OU3.
Groundwater Monitoring Well Installation
Sixty-one groundwater samples were collected
from 45 monitoring wells as part of the OU4 RI.
Additional groundwater samples were collected
from 16 of the 45 monitoring wells to support
contaminant characterization. The data collected
from this sampling, in addition to historic data, was
used in the determination of the nature and extent
of contamination and the contribution from the
various sources associated with OU4.
Soil Samples - Sixty-one soil samples were
collected from the unsaturated (vadose) and
saturated zone and analyzed for VOCs. Thirty-
eight of the 61 samples were from the unsaturated
zone and 23 samples were collected from the
saturated zone. These samples were collected to
determine if groundwater monitoring well
installation locations were also source areas or not.
Sediments - Ten samples were collected to
characterize the sediments in Pompeston Creek and
Swedes Run. The sediment samples were collected
to determine if sediment was contaminated by
discharge of groundwater to surface water.
Surface Water Samples -Nine surface water
samples from X, Y, Z were collected to
characterize surface water at the Site and to
determine if OU4 sources of groundwater
contamination are discharging to surface water.
NATURE AND EXTENT OF
CONTAMINATION
Hydropunch®/Geoprobe® Groundwater
Samnle Results
The 2014 Hydropunch® groundwater samples
showed benzene was detected (6.2 micrograms per
liter ((J.g/1)) at a concentration exceeding the site-
specific screening levels (SSL) of 1 (_ig/l at a depth
of 200 feet in one of the 20 samples. PCE was
7
detected (6.6 jag/1) at a concentration exceeding its
SSL of 1 [j.g/1 at a depth of 41 feet in only one of
the 20 samples. TCE was detected in six of the 20
samples collected exceeding the SSL of 1 [j.g/1 at
concentrations ranging from 5.1 j_ig/l to 62 j_ig/l.
The Geoprobe® groundwater sampling data from
2019 indicates that 36 groundwater samples
contained VOCs above the SSLs. The
concentration of TCE ranged from non-detect to
220 micrograms per liter (|ig/l). The distribution of
TCE in groundwater collected from these borings
shows the TCE present in groundwater located
north of the Messer property is coming from the
Messer facility on the property. Figure 3.
Groundwater Monitoring Well Sampling
Results
Volatile Organic Contaminants - VOCs were
detected in groundwater samples collected from 41
of the 45 monitoring wells (55 of 61 groundwater
samples) during the May 2017 sampling event.
VOCs were detected at concentrations above the
SSLs in 25 out of the 45 monitoring wells (36 of
61 samples) during that sampling event.
Below is a summary of the eight most frequently
detected VOCs in groundwater:
TCE was detected in 48 out of the 61 groundwater
samples and exceeded its SSL of 1 (_ig/l in 33
samples. The concentrations of TCE detected in
the samples range from 0.2J to 760 j_ig/l.
PCE was detected in 40 out of the 61 groundwater
samples and exceeded its SSL of 1 (_ig/l in 22
samples. The concentrations of PCE detected in the
samples range from 0.2J to 20 j_ig/l.
cis-l,2-DCE was detected in 42 out of the 61
groundwater samples and exceeded its SSL of 70
[j.g/1 in only one sample. The concentrations of cis-
1,2-DCE detected in the samples range from 0.17J
to 200 jag/l.
VC was detected in 28 out of the 61 groundwater
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samples and exceeded its SSL of 1 [j.g/1 in 10
samples. The concentration of VC detected in the
samples range from 0.14 to 5.6 j_ig/l.
1.1-DCE was detected in 25 out of the 61
groundwater samples and exceeded its SSL of
1 jag/l in 10 samples. The concentrations of 1,1-
DCE detected in the samples range from 0.18J to
64 [j.g/1.
1.2-dichloropropane was detected in 21 out of the
61 groundwater samples and exceeded its SSL of 1
[j.g/1 in five samples. The concentrations of 1,2-
dichloropropane detected in the samples range
from 0.16 to 2.2 j_ig/l.
1,2-DCA was detected in 20 out of the 61
groundwater samples and exceeded its SSL of 2
[j.g/1 in eight samples. The concentrations of 1,2-
DCA detected in the samples range from 0.24 to
7.1 ng/1.
Chloroethane was detected in 11 out of the 61
groundwater samples, and exceeded its
SSL of 5 [j.g/1 in only one sample. The
concentrations of chloroethane detected in the
samples range from 0.15 to 7.8 j_ig/l.
These data show that TCE and PCE are the most
significant groundwater contaminants detected
within OU4. However, the majority of the
remaining VOCs detected (e.g., cis-l,2-DCE, 1,1-
DCE, and VC) in groundwater are the direct or
indirect result of anthropogenic biotic and/or
abiotic degradation of TCE/PCE resulting from the
contaminated groundwater interacting with septic
waste or landfill conditions that result in biotic
and/or abiotic degradation. Some of the source
areas of TCE and PCE also contain other
contaminants (e.g., benzene, methylene chloride,
chloroform, and 1,2-dichloropropane), which have
contributed to groundwater contamination.
Semi-Volatile Organic Compounds - Sixty-one
groundwater samples, collected from 45
monitoring wells, were analyzed for SVOCs. Only
8
one contaminant (1,4-dioxane) was detected in 22
of 45 monitoring wells or 38 of 61 samples. 1,4-
dioxane was detected in 17 samples above its SSL
of 0.4 [j,g/l. The highest concentration of 1,4-
dioxane was detected in EPAC-6S at 120J jag/l.
Although detected in 17 samples above its SSL,
the mean concentration is approximately 10 j_ig/l
and the median concentration is approximately 1
jo,g/l, indicating that there is not a large 1,4-dioxane
plume present. 1,4-dioxane is considered a Site-
related contaminant as it is often used as a solvent
(PCE/TCE) stabilizer.
Pesticides/PCBs -Two pesticides (Beta BHC and
Dieldrin) were detected above their SSLs. Dieldrin
was present in two of the 61 samples. Dieldrin
was detected in the two samples collected from
OU4 MW-2S at concentrations of 0.045 |ig/l and
0.046 jj.g/1, slightly, above its SSL of 0.03 (j.g/1.
Beta BHC was detected at 0.15J (j.g/1 in one
sample. These pesticides are not considered site-
related contaminants as they were not detected in
groundwater samples collected from the source
areas and the detection at a single location above
the SSLs is not indicative of a significant point-
source of contamination. No PCBs were detected
in any of the groundwater samples collected from
monitoring wells above its SSL.
Metals - Aluminum, sodium, manganese, and iron
were detected across OU4 in groundwater at
concentrations that exceeded their respective SSLs.
Aluminum was detected in 59 of the 61
groundwater samples collected during the OU4 RI.
The concentration of aluminum ranged from non-
detect (ND) to 1,300 |ig/l. Sodium was detected in
all 61 groundwater samples collected during the
OU4 RI. The concentration of sodium ranged
from 4,100 to 230,000 (j.g/1. Manganese was
detected in all 61 groundwater samples collected
during the OU4 RI. The concentration of
manganese ranged from 19 to 5,800 (j.g/1. Iron was
detected in 57 of the 61 groundwater samples
collected during the OU4 RI. The concentration of
iron ranged from ND to 69,000 (j.g/1. These metals
are regulated as secondary taste and quality
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contaminants and are generally considered to be
naturally occurring.
Antimony, barium, cadmium, calcium, chromium,
copper, lead, magnesium, mercury, potassium,
selenium, silver, thallium, vanadium, and zinc
were not detected above their respective SSLs.
Antimony, cadmium, selenium, and thallium were
not detected in any of the 61 groundwater samples
collected as part of the OU4 RI.
Arsenic was detected in 9 of the 61 groundwater
samples at concentrations that range from 1
to 38 ug/1. The concentration of arsenic exceeded
its SSL of 3 [j.g/1 in 1 groundwater sample.
Beryllium was detected in 12 of the 61
groundwater samples at concentrations that ranged
from 1.1 to 3.8 j_ig/l. The concentration of
beryllium exceeded its SSL of 1 (_ig/l for all 12 of
the groundwater samples Cobalt was detected in 60
of the 61 groundwater samples at concentrations
ranging from 1.2 to 190 j_ig/l; however, only one
sample contained cobalt above its SSL of 100 jag/l.
Arsenic and cobalt were detected above their
respective SSLs in one groundwater sample.
Soil Sample Results
Soil samples were collected from the unsaturated
(vadose) and saturated zone during the OU4 RI.
Sixty-one soil samples were analyzed for VOCs.
Thirty-eight samples were collected from the
unsaturated zone and 23 samples were collected
from the saturated zone.
Soil sample analytical results confirmed that wells
were not placed in contaminated soil that could
have caused false positive groundwater
contamination results.
Sediment Sample Results
VOCs - No VOCs were detected above their SSLs
in any of the 10 sediment samples.
Ten samples were taken to characterize the
sediments in Pompeston Creek and Swedes's Run.
9
A number of SVOCs and metals that were detected
in these samples are not site-related and are likely
the result of runoff. This is supported by the fact
that the concentration of SVOCs and metals in the
continuous portion of Pompeston Creek are similar
to the concentration of SVOCs and metals in the
intermittent portions of Pompeston Creek.
Surface Water Sample Results
VOCs -_VOCs (TCE and cis-l,2-DCE) were
detected in one surface water sample. TCE was
detected at 14 |ig/l which exceeds its SSL of 1
|ig/l. Cis-1,2-DCE was detected at 8.1 J jj.g/1.
SVOCs - One SVOC, (bis(2-ethylhexyl)phthalate),
was detected in one of the eight surface water
samples analyzed for SVOCs. Bis(2-ethylhexyl)
phthalate was detected at 2 J |ig/l, which is above
its SSL of 1 |ig/l. The surface water samples were
not analyzed for pesticides or PCBs.
Metals- Metals were detected in all nine surface
water samples collected from locations within
Pompeston Creek and Swedes Run. Metals
detected were arsenic (4.8 - 20.2 ju.g/1), barium
(20.3 - 630 ju.g/1), cadmium (0.63-4.6 ju.g/1), total
chromium (0.62 - 101 ju.g/1), cobalt (4 - 46.4 ju.g/1),
lead (31.9 - 326 ju.g/1), mercury (0.063 - 0.54 ju.g/1),
and vanadium (128 ju.g/1). Metals detected in these
samples are not Site-related and are the result of
runoff. This is supported by the fact that the
concentration of metals in the surface water and/or
sediment in the continuous portion of Pompeston
Creek are similar to the concentration of metals in
the intermittent portions of Pompeston Creek.
Groundwater Impacts to Surface Water - The OU4
RI results show groundwater containing low
concentrations of PCE and TCE (for example, a
PCE level of 1.7 |ig/l at OU4 MW-3I and a TCE
level of 1.6 |ig/l at OU4 MW-8D) is migrating
with groundwater flow from the Messer and
Detrex properties towards and potentially
discharging to Pompeston Creek
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OU4 RI Major Conclusions
• Soil samples collected during OU1 and
OU3 RI activities, as well as from sampling
at the Detrex property conducted under
NJDEP programs, and groundwater
samples collected during the OU4 RI and
during OU1, OU3 and Detrex sampling
activities indicate VOCs were released to
the unconsolidated soils at the three
identified source areas and have impacted
underlying groundwater. The three
properties identified as primary source
areas for the Site are: the SLI Landfills, the
Messer property, and the Detrex property.
These data also show each of the three
primary source areas has contributed to a
large comingled groundwater plume
comprised of elevated levels of VOCs.
• Groundwater in the Pennsauken/PRM
aquifer historically flowed to the northwest
discharging to the Delaware River.
• However, over-pumping of groundwater by
municipal, industrial, and irrigation wells
has reversed the groundwater flow
direction to the southeast.
o Groundwater in the
northern/northwestern portion of OU3
flows towards to the northwest and
potentially discharges to the Delaware
River in a similar manner as historical
groundwater flow.
o Groundwater at the Detrex property and
in the western portion of the Messer
property flows towards the west and
potentially discharges to Pompeston
Creek.
o Groundwater beneath the SLI Landfills,
the central and southern portions of the
Messer property and the Detrex
property flows to the southeast.
• Groundwater containing VOC
contamination migrates from the identified
source areas to the southeast, creating a
roughly 2-mile long plume of contaminated
groundwater. As the soluble contaminants
move from source areas downgradient, the
contamination, that is at levels of up to 700
times the drinking water standard, goes
deeper into the aquifer to depths of 375 feet
below ground surface. Figure 3.
• Groundwater containing VOCs from one or
more VOC source areas (SLI Landfills,
Messer property, and Detrex property)
potentially contributes to impacted
municipal water supply well contamination.
However, at this time, all active supply
wells are treated to meet federal and state
drinking water standards before
distribution.
• Surface water contains VOCs, SVOCs, and
metals above SSLs. Sediment collected
from Pompeston Creek contains SVOCs
and metals above SSLs. Surface water
containing VOCs pose no risk to Human
Health or ecological receptors. Elevated
SVOCs and metals in surface water and
sediment are not site-related. These
contaminants are common in runoff in sub-
urban settings.
• While unsaturated soils contain SVOCs and
metals above the SSLs, these contaminants
were not detected at source areas and
therefore are not considered related to the
Site.
RISK SUMMARY
As part of the OU4 RI/FS, EPA conducted a
baseline risk assessment to estimate the current and
future effects of contaminants on human health and
the environment. A baseline risk assessment is an
analysis of the potential adverse human health and
ecological effects of releases of hazardous
substances from a site if no actions to mitigate
such releases are taken, under current and future
groundwater, soil, sediment and surface water
uses. The baseline risk assessment includes a
human health risk assessment (HHRA) and a
10
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Screening Level Ecological Risk Assessment *
(SLERA).
HUMAN HEALTH RISK ASSESSMENT
EPA conducted a four-step HHRA to assess Site- •
related cancer risks and noncancer health hazards •
in the absence of any remedial action. The four-
step process is comprised of: Hazard Identification,
Exposure Assessment, Toxicity Assessment and
Risk Characterization (refer to the text box "What •
is Human Health Risk and How is it Calculated").
The baseline human health risk assessment began
with selecting chemicals of potential concern
(COPCs) in the various media (i.e., groundwater,
soil, sediment and surface water) that could
potentially cause adverse health effects in exposed
populations. COPCs are selected by comparing the
maximum detected concentrations of each
chemical identified with state and federal risk-
based screening values.
The COPC screening conducted in the HHRA
identified 30 COPCs, including VOCs, SVOCs,
pesticides, PCBs and inorganics. COPCs not
considered to be Site-related or at concentrations
similar to background are carried through the
quantitative portion of the HHRA but not
identified as primary COPCs for OU4.
The exposure assessment identified potential
human receptors based on a review of current and
reasonably foreseeable future land use at the Site.
The Site, which covers approximately 400 acres,
includes residential, commercial and industrial
properties. It is bounded to the southwest by
Pompeston Creek which can be used for
recreational activities such as swimming or
wading. Based on the current zoning and land use,
the HHRA evaluated residential, commercial and
recreational uses of the Site.
The current and future land use scenarios evaluated
in the HHRA included the following exposure
pathways and populations:
Resident (child/adult): ingestion, dermal contact
and inhalation of groundwater while
showering/bathing and for surface soil, ingestion,
dermal contact and inhalation of volatilized
constituents and particulates in air.
Worker (adult): ingestion and dermal contact with
groundwater and for surface soils, ingestion,
dermal contact and inhalation of volatilized
constituents and particulates in air.
• Recreator (adult and child): ingestion and
dermal contact with surface water and
sediment while visiting Pompeston Creek.
In this assessment, exposure point concentrations
were estimated using either the maximum detected
concentration of a contaminant or the 95% upper-
confidence limit (UCL) of the average
concentration. Chronic daily intakes were
calculated based on the reasonable maximum
exposure (RME), which is the highest exposure
reasonably anticipated to occur at the Site. The
RME is intended to estimate a conservative
exposure scenario that is still within the range of
possible exposures. A complete summary of all
exposure scenarios can be found in the baseline
human health risk assessment which can be found
in the administrative record for the Site.
In the risk assessment, two types of toxic health
effects were evaluated for COPCs: cancer risk and
noncancer hazard. Calculated cancer risk estimates
for each receptor were compared to EPA's target
risk range of lxlO"6 (one-in-one million) to lxlO"4
(one-in-ten thousand). The calculated noncancer
hazard index (HI) estimates were compared to
EPA's target threshold value of 1. The following
sections provide an overview of the cancer risks
and noncancer hazard associated with exposure to
the following media at OU4: groundwater, surface
soil, sediment and surface water.
11
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All VI investigations are being conducted under
OU3 of the Site and hence VI was not addressed in
the HHRA.
Groundwater
Cancer risks and noncancer hazards were evaluated
for current and future exposure to sitewide
groundwater. The populations of interest
evaluated were child/adult residents and adult
workers. As shown in Table 1, the estimated
cancer risk for the adult/child resident of 8.5xl0"4
exceeded the upper-bound of EPA's threshold
criteria of lxlO"6 to lxlO"4 Additionally, the
hazard index for the child resident, adult resident
and adult Site worker exceeded 1. The
contaminants of concern (COCs), or those
chemicals that contributed the majority of Site risk
included TCE and chloroform. Although risk and
hazard from several metals including arsenic,
chromium and cobalt exceeded the hazard index of
1 or cancer risk of lxlO"4, these metals were
determined to be comparable to background
concentrations and hence not retained as site-
related COCs.
Table 1: Summary of cancer risk and
Receptor
Cancer
Risk*
Hazard
Index*
Resident-
Child
8.5 x 10 4
42
Resident-
Adult
39
Worker-
Adult
7.3 x 10"5
3.9
*Bold indicates value above the acceptable
risk range or value.
Site-related COCs include: TCE and
chloroform
Surface Soil
Cancer risks and noncancer hazards were evaluated
for current and future exposure to surface soil. The
WHAT IS RISK AM) MOW IS I I ( Al.( l I ATI! 1)7
A Superfund baseline human health risk assessment is an analysis of
the potential adverse health elleels caused by hazardous substance
releases from a site in the absence of any actions to control or mitigate
these undercurrent- and future-land uses. A four-step process is
utilized for assessing site-related human health risks for reasonable
maximum exposure scenarios.
Hazard IJc/iiificaiio/i: In this step, the chemicals of potential concern
(COPCs) at the site in various media (i.e.. soil, groundwater, surface
water, and air) are identified based on such factors as toxicity,
frequency of occurrence, and late and transport of the contaminants in
the environment, concentrations of the contaminants in specific media,
mobility, persistence, and bioaccumulalion.
I-'.xposurc /is.sessmciii: In this step, the different exposure pathways
through which people might be exposed to the contaminants identified
in the previous step are evaluated. Fxamples 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.
I sing 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 .issc.s.sniem: In this step, the types of adverse health effects
associated \\ilh chemical exposures, and the relationship between
magnitude of exposure and severity of adverse effects are determined.
Potential health effects are chemical-specific and may include the risk
of developing cancer over a lifetime or other noncancer health hazards,
such as changes in the normal functions of organs within the body (e.g..
changes in the ellectiveness of the immune system). Some chemicals
are capable of causing both cancer and noncancer health hazards.
Risk (haracicrizaiioii: This step summarizes and combines outputs of
the exposure and toxicity assessments to provide a quantitative
assessment of site risks for all COPCs. Exposures are evaluated based
on the potential risk of developing cancer and the potential for
noncancer health hazards. The likelihood of an individual developing
cancer is expressed as a probability, l-'or example, a 10"' 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"' to 10'°. corresponding
to a one in ten thousand to a one in a million excess cancer risk. For
noncancer health elleels. a "hazard index" (III) is calculated. The key
concept for a noncancer III is that a "threshold" (measured as an III of
less than or equal to 1) exists below which noncancer health hazards are
not expected to occur. The goal of protection is 10 " for cancer risk and
an III of 1 for a noncancer health hazard. Chemicals that exceed a 10"'
cancer risk or an III of 1 arc typically those that will require
remedial action at the site.
12
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populations of interest were child/adult residents
and adult workers. The hazard indexes and cancer
risks from all the populations evaluated were
below or within EPA's threshold values; hence, no
COCs were identified for surface soil (Table 2).
Sediment
Cancer risks and noncancer hazards were
evaluated for current and future exposure to
sediments in Pompeston Creek. The populations
of interest evaluated were adult and child
recreators. The hazard indexes and cancer risks for
the recreator populations evaluated were below or
within EPA's threshold criteria; hence, there were
no COCs identified in sediments.
Surface water
Cancer risks and noncancer hazards were evaluated
for current and future exposure to surface water in
Pompeston Creek. The populations of interest
evaluated were adult and child recreators. The
estimated cancer risk of 7.0xl0"4 was driven by
exposure to chromium which was conservatively
evaluated as hexavalent chromium in the HHRA.
Chromium was not retained as a COC as it is not
believed to be Site-related. The hazard index for
the child recreator of 1.8 did not exceed 1 when
separated by target organ/effect. Based on these
considerations there were no COCs identified in
surface water (Table 4).
Summary of Human Health Risks
In summary, the HHRA concluded that potable use
of groundwater at the Site would result in
exceedances of EPA's target threshold values due
to the presence of elevated levels of VOCs in
groundwater. Based on the results of the human
health risk assessment, a remedial action is
necessary to protect public health, welfare and the
environment from actual or threatened releases of
hazardous substances.
SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT
A Screening Level Ecological Risk Assessment
(SLERA) was prepared to evaluate potential risks
to aquatic and terrestrial ecological receptors from
exposure to contaminants in soil, sediment, surface
water and groundwater (for surface water impacts).
COPC screening identified a total of 40 COPCs,
including those in soil, surface water, sediment and
groundwater. The potential ecological exposure
scenarios considered in the SLERA included
ingestion or dermal contact with surface water
(also evaluated through groundwater), as well as
incidental ingestion or dermal contact with surface
soil and sediment.
The SLERA evaluated risk to ecological receptors
exposed to the maximum concentration of all
detected compounds. With the exception of cis-
1,2-DCE, none of the VOCs were identified as
COPCs because the concentrations in groundwater,
sediment soil and surface water are non-detect or
below the ecological screening criteria. Cis-1,2-
DCE in surface water and groundwater is a COPC
only because no screening criteria are available;
however, its concentrations of 8.1 |ig/L in surface
water and 1.4 |ig/L in groundwater are well below
the trans-l,2-DCE criterion of 970 |ig/L. The
volatility of cis-l,2-DCE and limited potential to
bioaccumulate indicate it likely does not pose a
substantial ecological hazard.
The SLERA indicated a potential ecological risk
from exposure to SVOCs and inorganics in surface
soil, sediment, surface water and groundwater.
However, these substances are not considered to be
site-related. Based on the above information, there
are no ecological-based COCs identified for OU4.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are media-
specific goals for protecting human health and the
environment. They serve as the basis for
developing remedial action alternatives and specify
what the cleanup action will accomplish. The
13
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process of identifying the RAOs follows the
identification of affected media and contaminant
characteristics; evaluation of exposure pathways,
contaminant migration pathways and exposure
limits to receptors.
The following RAOs have been developed for the
OU4 groundwater:
• Reduce or eliminate further migration of
groundwater containing site-related
contaminants at concentrations greater than
federal and state standards;
• Prevent future exposure (via ingestion,
dermal contact, and inhalation) to site-
related contaminants in groundwater at
concentrations greater than federal and
state standards; and
• Restore the impacted aquifer to its most
beneficial use as a source of drinking water
by reducing site-related contaminant levels
to the most stringent of federal and state
standards.
Remediation Goals
The preliminary remediation goals (PRGs) for
groundwater are developed for the COCs identified
in this document to aid in defining the extent of the
contaminated media requiring remedial action.
PRGs are generally chemical-specific remediation
goals for each medium and/or exposure route that
are established to protect human health and the
environment. They can be derived from applicable
or relevant and appropriate requirements (ARARs),
risk-based levels (human health and ecological),
and from comparison to background
concentrations, where available.
See Appendix 1 - PRG Table
The lowest of the relevant federal MCLs, New
Jersey State (NJDEP) MCLs, and NJDEP GWQS
were used to develop the PRGs.
Principal Threat Waste
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 groundwater, surface water or air,
or acts as a source for direct exposure.
Contaminated groundwater generally is not
considered to be a source material. Since OU4
addresses contaminated groundwater, no principal
threat wastes are addressed in this Proposed Plan.
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 and
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).
Detailed descriptions of the remedial alternatives
summarized in this Proposed Plan for addressing
site-wide groundwater contamination are provided
in the OU4 FS Report.
14
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Alternative l - INo Action
The No Action alternative is required by the NCP
to be carried through the screening process. Under
this alternative, no action would be taken to
remediate the contaminated groundwater. This
alternative would also not include Institutional
Controls (ICs). Contaminants present in the
groundwater would remain in place.
The No Action alternative provides a baseline for
comparison with other active remedial alternatives.
Because no remedial activities would be
implemented under the No Action alternative, long
term human health and environmental risks would
remain the same as those identified in the HHRA.
There are no capital, operations /maintenance, or
monitoring costs and no permitting or institutional
legal restrictions needed, but this alternative will
not meet all of the RAOs established for
groundwater.
Total Capital Cost
$0
Total O&M Cost
$0
Total Periodic Cost
$0
Total Present Value
$0
Time to Construct
N/A
Alternative 2 - Institutional Controls
ICs, such as a Classification Exception Area/Well
Restriction Area (CEAs/WRA), would restrict
groundwater uses or activities which could result
in direct contact with contaminated groundwater.
The migration and environmental impact of the
contaminated groundwater would not be
significantly reduced. Due to the contaminated
groundwater, a NJDEP CEA/WRA would be
placed on OU4 to restrict future groundwater use
activities that would expose users to contaminants
at levels that may pose human health risk. A pre-
design investigation would be conducted to
determine the area requiring the CEA/WRA, Long
Term Monitoring (LTM) would also be used as a
basis for evaluating the terms of the CEA/WRA.
For cost estimating purposes, it is assumed that
monitoring to evaluate contaminant levels will be
conducted for a period of 30 years. Empirical
groundwater flow and solute transport data
collected in the OU1 and OU4 studies/
investigations were used in analytical models
(aquifer flushing and first-order decay) to estimate
the period of performance of each remedial
alternative. The results of using the empirical
groundwater flow and solute transport data
collected during OU1 and OU4 and the analytical
models (aquifer flushing and first-order decay)
indicated that for Alternative 2 the plume will
continue to attenuate but is estimated to remain
above cleanup levels for approximately 125 years.
This alternative result in restoring the aquifer to its
beneficial use. Five- year reviews would be
conducted.
Total Capital Cost
Total O&M Cost
Total Periodic Cost
Total Present Value
Time to Construct
Timeframe
$854,000
$2,293,000
$504,000
$3,651,000
N/A
125 years
Common Elements for Active Remedial Action
Alternatives 3 through 6
Alternatives 3 through 6 each include extraction
and treatment of contaminated groundwater;
however, the design of each would use different
extraction locations and groundwater extraction
volumes as described below. Each of these
alternatives include ICs and LTM, as described in
Alternative 2, above. Alternatives 3-6 would
require the performance of Five-Year Reviews
until restoration is achieved. In addition,
Alternatives 3 through 6 have the following
common elements:
Pre-Design Investigation (PDI)
Alternatives 3 through 6 each include a PDI. A
PDI would typically include groundwater
screening, well installation and, as necessary,
hydraulic testing, and sampling. Data collected
15
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during the PDI would be used to better define the
geochemistry and volumes of groundwater needing
treatment and help in the development of a
remedial design of the remedy.
Treatment Process
• Centralized treatment plant with metals
removal system, air stripping, vapor phase
GAC adsorption, liquid phase GAC
adsorption, and 1,4-dioxane treatment; and
• Discharge to surface water in the vicinity of
Burlington Pike and Palmyra Bridge Rd.
The contaminated groundwater from each
extraction well would be treated at one or more
treatment plants. It is assumed that land acquisition
would be required for the construction of any
treatment plant. Although the ex-situ treatment
options are similar for Alternatives 3 to 6,
treatment units would be sized depending on the
total influent flow rate and water chemistry at each
treatment plant. The typical treatment process
would include metals removal, removal of VOCs
by air strippers, vapor-phase GAC, liquid-phase
GAC, and 1,4-dioxane treatment.
The treatment process anticipated for purposes of
costing is described below; however, treatment
requirements would be more fully determined
during the remedial design. After treatment,
groundwater would be discharged to surface water.
During remedial design, consideration would also
be given to reinjection of some or all of the treated
groundwater into the underlying aquifer. In
addition, for Alternatives 3 through 6, operation
and maintenance of the extraction and treatment
system would be performed for the life of the
operation.
Alternative 3 - Downgradient Hydraulic
Capture and Discharge of Treated Water to
Surface Water
Alternative 3 includes hydraulic containment of the
OU4 contaminated groundwater plume above the
PRGs using pump and treat. The major
components of Alternative 3 are:
• Installation of groundwater extraction wells
at the distal end (furthest downgradient
extent) of the OU4 contaminated
groundwater plume to establish hydraulic
control;
Alternative 3 includes the installation of 3
extraction wells. The extraction wells would be
installed to a depth determined during the design
and estimated to be approximately 300 feet below
ground surface. Each groundwater extraction well
is estimated to remove approximately 600 gpm for
a total of 1,800 gpm. The final flow rate would be
determined during the design phase. The
contaminated groundwater from each extraction
well would be pumped to a single centralized
treatment plant. The treated water from the
treatment plant would be discharged to surface
water in the vicinity of Burlington Pike and
Palmyra Bridge Rd. It is estimated that the pump
and treat system would be operated for a period of
100 years to meet groundwater restoration goals.
ICs and LTM would be implemented as part of this
alternative.
Total Capital Cost
Total O&M Cost
Total Periodic Cost
Total Present Value
Time to Construct
Timeframe
$16,061,000
$31,799,000
$1,796,000
$49,660,000
2 years
100 years
The area treated would reach cleanup goals in 100
years and the downgradient area not treated by the
pump and treatment system would concurrently
attain goals in 10 years. Therefore, the total
remediation time is 100 years.
Alternative 4 - Mid-Plume Groundwater
Remediation and Discharge of Treated Water to
Surface Water
Alternative 4 includes hydraulic capture of the
OU4 contaminated groundwater plume above the
PRGs using pump and treat. Alternative 4 also
16
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includes extraction, treatment, and discharge of
groundwater at the midpoint (midway between the
source areas and the furthest downgradient
contaminated wells) of the OU4 contaminated
groundwater plume and at the distal end of the
plume to shorten the period of performance of the
remedy compared to Alternative 3. The major
components of Alternative 4 are:
• Installation of groundwater extraction wells
at the distal end of the OU4 contaminated
groundwater plume for hydraulic control;
• Installation of groundwater extraction wells
at the mid-point of the OU4 contaminated
groundwater plume to shorten the period of
performance of the remedy;
• Two treatment plants with metals removal
system, air stripping, vapor phase GAC
adsorption, liquid phase GAC adsorption,
and 1,4-dioxane treatment.
• The two treatment plants will be
constructed near the extraction wells for the
mid-point and distal end of the OU4
contaminated groundwater plume;
• Discharge to surface water in the vicinity of
Burlington Pike and Palmyra Bridge Rd.
Alternative 4 includes the installation of 6
extraction wells. The extraction wells would be
installed to a depth determined during the remedial
design which is estimated to be approximately 300
to 450 feet bgs. Each groundwater extraction well
is estimated to remove approximately 600 gpm for
a total extraction rate of 3,600 gpm. The final flow
rate would be determined during the design. The
treated water from the treatment plant would be
discharged to surface water in the vicinity of
Burlington Pike and Palmyra Bridge Rd. It is
estimated that the pump and treat system would be
operated for a period of 50 years to restore the
aquifer. Extracted groundwater would be conveyed
via underground piping to the centralized treatment
plants and from the treatment plants to the
discharge location or locations. For cost estimating
purposes, it is estimated that approximately 26,100
linear feet of double-walled high-density
polyethylene (HDPE) piping and approximately
16,100 linear feet of single-walled HDPE piping
would be required for conveyance of the
groundwater. It is estimated that two booster pump
stations and one concrete junction vault would be
needed for discharging the treated water. ICs and
LTM would be implemented.
Total Capital Cost
Total O&M Cost
Total Periodic Cost
Total Present Value
Time to Construct
Timeframe
$30,382,000
$59,511,000
$4,523,000
$94,416,000
2-3 years
50 years
The area treated would reach cleanup goals in 50
years and the downgradient area not treated by the
pump and treatment system would concurrently
attain goals in 10 years. Therefore, the total
remediation time is 50 years.
Alternative 5 - Core of Plume Remediation and
Discharge of Treated Water to Surface Water
Alternative 5 includes groundwater extraction and
treatment in the higher concentration of the down-
gradient portions (i.e., would not include installing
groundwater recovery wells in the SLI Landfills,
Messer, and Detrex source areas) of the OU4
contaminated groundwater plume (i.e., called
herein Core of Plume). The major components of
Alternative 5 are:
• Installation of groundwater extraction wells
in the higher concentration of the down-
gradient portions (i.e., not including the
Messer and Detrex properties which will be
remediated as described earlier) of the OU4
contaminated groundwater plume;
• Construction of a centralized treatment plant
with metals removal system, air stripping,
vapor phase GAC adsorption, liquid phase
GAC adsorption, and 1,4-dioxane treatment;
and,
• Discharge to surface water in the vicinity of
Burlington Pike and Palmyra Bridge Rd.
17
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Alternative 5 includes the installation of 3
extraction wells. The extraction wells would be
installed to a depth determined during the remedial
design, estimated to be approximately 375 to 450
feet bgs. Each groundwater extraction well is
estimated to remove approximately 600 gpm for a
total extraction rate of 1,800 gpm. The final flow
rate would be determined during the remedial
design. The treated water from the treatment plant
would be discharged to surface water in the
vicinity of Burlington Pike and Palmyra Bridge
Rd. To meet RAOs, it is assumed that the pump
and treat system would be operated for a period of
75 years to restore the aquifer.
Extracted groundwater would be conveyed via
underground piping to the centralized treatment
plant and from the treatment plant to the discharge
location. It is assumed that approximately 9,900
linear feet of double-walled HDPE piping and
approximately 9,000 linear feet of single-walled
HDPE piping would be required for conveyance of
the groundwater. Based on the conceptual piping
design for Alternative 5, one booster pump station
would be needed for discharging the treated water.
The pump and treat system would capture the Core
of the Plume. Further downgradient portions of the
plume would not be captured and would be
sampled/analyzed to monitor reductions over time.
ICs and LTM would be implemented.
Total Capital Cost
Total O&M Cost
Total Periodic Cost
Total Present Value
Time to Construct
Timeframe
$14,482,000
$31,799,000
$1,796,000
$48,077,000
2 years
75 years
The area treated would reach cleanup goals in 75
years and the downgradient area not treated by the
pump and treatment system would concurrently
attain goals in 10 years. Therefore, the total
remediation time is 75 years.
Alternative 6 - Groundwater Remediation near
Source Areas and Discharge of Treated Water to
Surface Water
Alternative 6 includes groundwater remediation in
the area of highest concentration of groundwater
contamination, located just downgradient of the
groundwater sources (i.e., Messer and Detrex
properties) using pump and treat. The groundwater
in close proximity to the SLI Landfills are being
addressed in OU1. The major components of
Alternative 6 are:
• Installation of groundwater extraction wells
near the OU4 contaminated groundwater
plume source areas (i.e., Messer and Detrex
properties);
• Construction of a centralized treatment plant
with metals removal system, air stripping,
vapor phase GAC adsorption, liquid phase
GAC adsorption, and 1,4-dioxane treatment;
and
• Discharge to surface water at Pompeston
Creek.
Alternative 6 includes the installation of 4
extraction wells. The extraction wells would be
installed to a depth determined during the design
estimated to be approximately 200 feet bgs. Each
groundwater extraction well is estimated to remove
approximately 50 gpm, for an estimated total
extraction rate of 200 gpm. The final flow rate will
be determined during the design. It is estimated
that the pump and treat system would be operated
for 25 years where at that time contaminated
groundwater within the capture zone of Alternative
6 would have reached cleanup goals. Groundwater
outside of the capture zone would reach cleanup
objectives in approximately 65 years.
Extracted groundwater would be conveyed via
underground piping to the centralized treatment
plant and from the treatment plant to the discharge
location. For the purpose of estimating cost, it is
assumed that approximately 3,900 linear feet of
double-walled HDPE piping and approximately
430 linear feet of single-walled HDPE piping
18
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would be required for conveyance of the
groundwater.
The pump and treat system would capture the most
highly contaminated part of the groundwater
plume, and the downgradient portion of the plume
would continue to migrate. ICs and LTM would
be implemented in the dilute, downgradient portion
of the plume.
Total Capital Cost
Total O&M Cost
Total Periodic Cost
Total Present Value
Time to Construct
Timeframe
$6,595,000
$14,160,000
$1,611,000
$22,366,000
1-2 years
65 years
The area treated would reach cleanup goals in 25
years and the downgradient area not treated by the
pump and treatment system would concurrently
attain goals in 65 years. Therefore, the total
remediation time is 65 years.
EVALUATION OF ALTERNATIVES
In evaluating the remedial alternatives, each
alternative is assessed against nine evaluation
criteria set forth in the NCP, namely overall
protection of human health and the environment;
compliance with ARARs; long-term effectiveness
and permanence; reduction of toxicity; mobility, or
volume through treatment; short-term
effectiveness; implementability; cost; and state and
community acceptance. See box entitled "The Nine
Superfund Evaluation Criteria" for a more detailed
description of these evaluation criteria.
This section of the Proposed Plan evaluates the
relative performance of each alternative against the
nine criteria, noting how each alternative compares
to the other options under consideration. A more
detailed analysis of alternatives can be found in the
OU4 FS report.
Till1', NINK Sl I'KRl IM) l.VAU ATION ( RITKRIA
1. Overall Protectiveness of Human Health and the Environment
evaluates whether an alternative eliminates, reduces, or controls threats to
public health and the environment through institutional controls, engineering
controls, or treatment.
2. Compliance with Applicable or Relevant mid Appropriate
Requirements (ARARs) evaluates whether the alternative meets federal and
state environmental statutes, regulations, mid other requirements that pertain
to the site, or whether a waiver is justified.
3. Long-term Effectiveness and Permanence considers llic ability of an
alternative to maintain protection of human health and the environment over
time.
4. Reduction of Toxicity. Mobility, or Volume (TiVIY) of (ontaminants
through Treatment evaluates an alternative's use of treatment to reduce the
harmful effects of principal contaminants, their ability to move in the
environment, and the amount of contamination present.
5. Short-term Effectiveness considers the length of time needed to
implement an alternative and the risks the alternative poses to workers, the
community, and the environment during implementation.
6. Implementability considers the technical and administrative feasibility of
implementing the alternative, including factors such as the relative availability
of goods and services.
7. Cost includes estimated capital and annual operations and maintenance
costs, as well as present worth cost. Present worth cost is the total cost of an
alternative over time in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -30 percent.
8. State/Support Agency Acceptance considers whether the State agrees
with the EPA's analyses and recommendations, as described in the RI/FS and
Proposed Plan.
9. Community Acceptance considers whether the local community agrees
with EPA's analyses and preferred alternative. Comments received on the
Proposed Plan are an important indicator of community acceptance.
Threshold Criteria
Overall Protection of Human Health and the
Environment
Alternative 1 (No Action) would not meet the
RAOs and would not be protective of human
health and the environment since no action would
be taken. Alternatives 2, 3, 4, 5, and 6 would
provide protection of human health because the
exposure pathways to human receptors would be
eliminated by restrictions placed on the use of
groundwater within the area of groundwater
contamination, and through treatment and testing
of municipal water supplies required by State and
Federal drinking water programs. However, the
19
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different alternatives (Alternatives 2 through 6)
would restore the aquifer in different timeframes.
Empirical groundwater flow and solute transport
data collected in the OU1 and OU4 studies/
investigations were used in analytical models
(aquifer flushing and first-order decay) to estimate
the period of performance of each remedial
alternative.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
Actions taken at any Superfund site must meet all
ARARs under federal and state laws or provide
grounds for invoking a waiver of those
requirements.
Alternative 1 would not comply with ARARs.
Alternatives 3, 4, 5 and 6 are expected to be able to
meet action- and location-specific ARARs. Under
Alternatives 2, chemical-specific ARARs would
ultimately be achieved as a result of actions taken
as part of other OUs. Under Alternatives 3, 4, 5,
and 6 chemical-specific ARARs treatment would
contribute to achieving chemical-specific ARARs.
In the interim, the exposure pathways to human
receptors would be eliminated by restrictions
placed on the use of groundwater within the area of
groundwater contamination. Chemical-specific
ARARs for the COCs would be met under varying
timeframes under each alternative, ranging from
125 years for Alternative 2 to 50 years for
Alternative 5.
Balancing Criteria
Long-Term Effectiveness and Permanence
Alternative 1 and Alternative 2 would not provide
long-term effectiveness and permanence
(especially if reliable source control measures
cannot be put in place) since groundwater
contamination would not be addressed.
Groundwater extraction and ex-situ treatment
under each of the Alternatives 3, 4, 5, and 6 is
considered an effective technology for addressing
groundwater contaminated with COCs.
Alternatives 4 and 6 would provide the most long-
term effectiveness and permanence as they would
restore the aquifer faster than the other alternatives,
in approximately 50 and 65 years, respectively.
Alternatives 3, and 5 have recovery wells located
further from the source areas than Alternative 6
and would result in longer times to restore the
aquifer of 100 years and 75 years, respectively.
Reduction of Toxicity, Mobility, or Volume
(TMV) through Treatment
Alternative 1 (No Action) and Alternative 2 do not
address the contamination through treatment, so
there would be no reduction in TMV. Alternatives
3, 4, 5, and 6 would reduce the TMV of
contaminants in the aquifer by using extraction
wells to remove contaminated groundwater and by
treatment through air stripping, granulated active
carbon, and advanced oxidation processes (AOP)
technologies.
Alternative 6 would remove the largest amount of
COCs for the least amount of groundwater
pumping and would have the largest reduction in
TMV measured as a percent of total mass
reduction of COCs as it would target the portions
of the plume with the highest COC concentrations.
Alternatives 4 and 5 would remove the next largest
amount of COCs for the amount of groundwater
pumped, would have the next largest reduction in
TMV measured as a percent of total mass
reduction of COCs. Alternative 3 would remove
the smallest amount of COCs, would have the
lowest reduction in TMV measured as a
percent/ratio of total mass reduction compared to
the amount of groundwater removed as it targets
the low COC concentrations at the distal end of the
plume. The reduction of toxicity and volume will
be achieved by the treatment processes and the
destructive irreversibility of the treatment would be
the same for Alternatives 3, 4, 5, and 6. Each of the
Alternatives 3, 4, 5, and 6 rely on commonly used
treatment technologies to permanently destroy the
contaminants once withdrawn from the aquifer.
20
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Short-Term Effectiveness
Alternative 1 would not have any short-term
effectiveness or impacts since no action would be
implemented. Alternative 2 would result in the
least amount of short-term impacts due to no
physical construction compared to Alternatives 3
through 6. Alternative 6 would have the least
short-term impacts to the local communities of the
active treatment alternatives, since the length of
underground piping is the least and size of the
treatment plant is the smallest. Alternatives 3 and 5
would have the next least short-term impacts to the
local communities. Alternative 4 would have the
greatest short-term impacts to the local
communities as this alternative has the most wells,
longest underground piping, and two treatment
plants.
Groundwater extraction systems would induce a
hydraulic gradient and begin to capture COCs
within days or weeks of system startup. With the
drilling of extraction wells, installation of
underground conveyance piping, construction of
treatment plants, and development of discharge
locations, each of the active alternatives would
have short-term impacts on the community. While
each of the active alternatives would have short-
term impacts on the local communities, these
disruptions would be minimized through noise and
traffic control plans, as well as community air
monitoring programs during construction to
minimize and address any potential impacts to the
community, remediation workers, and the
environment.
Implementability
While each of the remedial alternatives are
technically feasible and implementable, the degree
of difficulty is determined by specific construction
activities that will need to occur in heavily
developed areas. Each active alternative,
Alternatives 3, 4, 5 and 6, involves drilling of
extraction wells, installation of underground
piping, and construction of treatment plant(s) and
21
would present varying challenges in
implementation in the heavily developed areas near
the Site.
Alternative 1 involves no action and thus, no
implementation. Alternative 2 would be the easiest
alternative to implement as there is no physical
construction of a remedial system associated with
these alternatives. Alternative 6 would be the next
easiest to implement as it involves the least amount
of piping and the smallest treatment plant. It
requires the potential acquisition of land in the
vicinity of the Pompeston Creek for the
construction of a treatment plant and street opening
permits for the installation of extraction wells.
Alternatives 3, 4, and 5, with centralized treatment
plants and surface water disposal/discharge
options, would be more difficult to implement as
the acquisition of land to build each treatment plant
in highly developed areas would be necessary.
These alternatives would also cause disruptions to
traffic within several areas to install underground
conveyance piping between the extraction wells
and the centralized treatment plant, and from the
treatment plant to the surface water discharge
location. The most disruptive of these alternatives
will be Alternative 4 due to higher number of
wells, the need for two separate treatment plants,
and longer length of pipe required to be installed.
Further, Alternative 6 would have significantly less
negative impact on this protected aquifer as it
includes significantly less extraction of
contaminated groundwater compared to
Alternatives 3, 4 and 5. This is an important
consideration for this aquifer, which is designated
as NJDEP Critical water Supply Area 2.
Cost
A comparative summary of the cost estimates for
each alternative is presented below.
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Alternative
Capital Cost
Total O&M
Cost
Total
Present-
Worth Cost
1
$0
$0
$0
2
$854,000
$2,797,000
$3,651,000
3
$16,061,000
$33,595,000
$49,656,000
4
$30,382,000
$64,043,000
$94,425,000
5
$14,482,00
$33,595,000
$48,077,000
6
$6,595,000
$15,771,000
$22,366,000
Modifying Criteria
State Acceptance
The State of New Jersey has deferred concurrence
on this Proposed Plan until additional pre-design
and design data are collected and analyzed.
Community Acceptance
Community acceptance of the Preferred Alternative
will be evaluated after the public comment period
ends and all comments are reviewed. Comments
received during the public comment period will be
addressed in the Responsiveness Summary section
of the Record of Decision (ROD). The ROD is the
document in which EPA will select the remedy for
OU4 of the Site.
PREFERRED ALTERNATIVE
Based upon an evaluation of the remedial
alternatives, EPA proposes Alternative 6,
Groundwater Remediation near Source Areas, as
the preferred remedial alternative for OU4 of the
Cinnaminson Groundwater Contamination Site.
Alternative 6 has the following key components:
• Groundwater extraction and treatment in
portions of the OU4 contaminated
groundwater plume with the highest levels
of contamination, located downgradient, but
in close proximity to, identified source
areas;
• Construction of a centralized groundwater
treatment plant with metals removal system,
air stripping, vapor phase GAC adsorption,
liquid phase GAC adsorption, and 1,4-
dioxane treatment;
• Discharge to surface water at Pompeston
Creek; and
• ICs and LTM until the aquifer is restored.
Active remediation elements would be designed to
achieve the RAOs by establishing restoration of
groundwater. The extraction and treatment system
would operate until remediation goals are attained
in the targeted area. It is estimated that
approximately 200 gpm of OU4's most
contaminated groundwater would be extracted and
treated under this Alternative. The exact placement
of wells, pumping rates, and treatment processes,
as well as the location of the treatment plant and
discharge of the treated groundwater would be
determined during the remedial design.
A long-term groundwater monitoring program
would be implemented to track and monitor
changes in the groundwater contamination to
ensure the RAOs/PRGs are attained throughout the
plume. The results from the long-term monitoring
program would be used to evaluate the migration
of contaminants and changes in site-related COCs
over time.
ICs in the form of a CEA/WRA would be
established to ensure that the remedy remains
protective until RAOs are achieved for protection
of human health over the long term.
The environmental benefits of the preferred
alternative could be enhanced by giving
consideration, during the remedial design, to
technologies and practices that are sustainable in
accordance with EPA Region 2's Clean and Green
22
-------
Energy Policy. This would include green
remediation technologies and practices.
The total estimated, present-worth cost for the
preferred alternative is $22,366,000. Further details
of the cost are presented in the OU4 FS Report.
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.
While this alternative would ultimately result in a
reduction of contaminant levels in groundwater, it
would take longer than five years to achieve these
levels. As a result, in accordance with CERCLA,
the OU4 remedy will be reviewed at least once
every five years until remediation goals are
achieved, which is estimated to take 25 years in the
most highly contaminated area of the plume which
will be extracted and treated, and 65 years for all
other areas of the plume.
Basis for the Remedy Preference
Alternative 6, Groundwater Remediation near
Source Areas, uses proven technologies which
have been demonstrated to be effective at reducing
contaminant mass to achieve cleanup standards for
VOC-contaminated groundwater. The Site lies
within the NJ Critical Water Supply Protection
Area No. 2. Groundwater extraction in this portion
of the aquifer currently exceeds the safe yield of
this aquifer, which is heavily relied upon as a
potable water source. Alternative 6, by extracting
close to the source areas, will pump much less
water than other active alternatives and achieve the
desired results of treating the areas of most
contamination, while minimizing negative impacts
to this critical aquifer.
Although the densely populated residential area
poses logistical challenges to the implementation
of each active remedial alternative, EPA believes
that Alternative 6 would be significantly less
disruptive to residents than the other alternatives
since significantly less infrastructure (such as
piping or the number of required treatment plants)
would need to be constructed and maintained
compared to the other active alternatives.
Alternative 6 is cost effective since capture of the
most contaminated groundwater with the lowest
volume of aquifer pumping would occur with the
lowest cost compared with the other active
Alternatives 3, 4 and 5. Alternative 6 would result
in attainment of remediation goals in 25 years
within the Alternative 6 capture zone. Given the
considerable challenges associated with the aquifer
designation as a NJ Critical Water Supply
Protection Area, the entire site-related portion of
the contaminated aquifer would be fully restored in
the reasonable timeframe of 65 years. The
concentrations in the portion of the plume that
would not be captured are very dilute, ranging
from < 1 to 760 |ig/L for TCE and <1 to 13 |ig/L
for PCE. All public supply wells in the area are
already treated to meet federal and state drinking
water standards before distribution.
Based upon the information currently available,
EPA believes the preferred alternative meets the
threshold criteria (protection of human health and
the environment and compliance with ARARs) and
provides the best balance of tradeoffs among the
other alternatives with respect to the balancing
criteria. The preferred alternative satisfies the
following statutory requirements of CERCLA: 1)
the proposed remedy is protective of human health
and the environment; 2) it complies with ARARs;
3) it is cost effective; 4) it utilizes permanent
solutions and alternative treatment technologies or
resource recovery technologies to the maximum
extent practicable; and 5) it satisfies the preference
for treatment as a principal element. Long-term
monitoring would be performed to assure the
protectiveness of the remedy. With respect to the
two modifying criteria of the comparative analysis
{state acceptance and community acceptance),
NJDEP has deferred concurrence on this Proposed
Plan until additional pre-design and design data are
collected and analyzed.
23
-------
COMMUNITY PARTICIPATION
EPA and NJDEP provided information regarding
the cleanup of OU4 of the Cinnaminson
Groundwater Contamination Site to the public
through meetings, the Administrative Record file
for the Site, and announcements published in the
Burlington County Times. EPA and NJDEP
encourage the public to gain a more
comprehensive understanding of the Site and the
Superfund activities that have been conducted. The
dates for the public comment period, the date,
location and time of the public meeting, and the
locations of the administrative record file, are
provided on the front page of this Proposed Plan.
For further information on the Cinnaminson Groundwater
Contamination Superfund Site, please contact:
Alida Karas Natalie Loney
Remedial Project Manager Community Involvement Coordinator
(212) 637-4276 (212) 637- 3639
karas.alida@epa.gov lonev.natalie@epa.gov
Written comments on this Proposed Plan should he submitted
on or before October 16, 2020, to Alida Karas at the address or
email below.
U.S. EPA
290 Broadway, 19«> Floor
New York, New York 10007-1866
karas.alida@epa.gov
The public liaison for EPA's Region 2 is:
George H. Zachos
Regional Public Liaison
Toll-free (888)283-7626
(732)321-6621
U.S. EPA Region 2
2890 Woodbridge Avenue, MS-211
Edison, New Jersey 08837-3679
24
-------
Appendix 1
Table
Primary Remediation Goals for Groundwater
Cinnaminson Groundwater Contamination Site OU4
Burlington County, New Jersey
Compounds of Concern
CAS
Number
NJDEP GWQS
(Hg/L)
Federal
MCL
(|xg/L)
NJDEP
Drinking
Water MCLs
(|Ag/L)
Primary
Remediation Goal
{|xg/L)
VOLATILE ORGANIC COMPOUNDS (VOCs)
1,1-Dichloroethane
75-34-3
50
-
50
50
1,2-Dichloroethane
107-06-2
2
5
2
2
1,4-Dichlorobenzene
106-46-7
75
75 l1'
75
75
1,4-Dioxane
123-91-1
0.4
-
-
0.4
Benzene
71-43-2
1
5
1
1
Chloroform
67-66-3
70
80 li'
80 u'
70
Tetrachloroethylene (PCE)
127-18-4
1
5
1
1
Trichloroethylene (TCE)
79-01-6
1
5
1
1
Vinyl chloride
75-01-4
1
2
2
1
Notes:
The Primary Remediation Goal is the minimum of the individual listed criteria.
ll) Criterion value is for total.
Abbreviations:
CAS = Chemical Abstracts Service
MCL = Maximum Contaminant Level (NJDEP 2009a, EPA 2009)
NJDEP GWQS = New Jersey Department of Environmental Protection (NJDEP) Groundwater Quality Standard (GWQS, 2018)
Hg/L = micrograms per liter
1 of 1
-------
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SITE LOCATION MAP
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FIGURE 1
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-------
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-------
ATTACHEMENT B - Public Notice
-------
A United States
Environmental Protection
#m Agency
EPA Invites Public Comment on a Proposed Cleanup Plan
for the Cinnaminson Groundwater Contamination Superfund Site
in Cinnaminson and Delran, New Jersey
The U.S. Environmental Protection Agency (EPA) issued a Proposed Plan to address
Operable Unit 4 (OU4) of the Cinnaminson Groundwater Contamination Superfund site
on September 17, 2020. The Proposed Plan is available electronically at
www.epa.gov/superfund/cinnaminson.
EPA's preferred cleanup plan for the site, described in this Proposed Plan, consists of
groundwater remediation using pumping and treatment near source areas, and discharge
of the treated water to surface water.
A 30-day public comment period for the Proposed Plan will run from September 17,
2020 to October 16, 2020. The plan identifies the preferred cleanup options considered
by the EPA. To address public questions and concerns about the proposed cleanup plan,
EPA will host a Virtual Public Meeting on Thursday, October 1, 2020 from 6:00pm-
8:00pm EST. To register for the public meeting, visit https://cinnaminson-
superfund.eventbrite.com. To learn more about the public meeting,
visit www.epa.gov/superflmd/cimiamiiisoii or contact Natalie Loney
at lonev.iiatalie@epa.gov or (212) 637-3639.
Anyone interested in receiving materials for the public meeting in hard copy should
either email or call Ms. Loney with such a request by Friday, September 25.
Relevant stakeholders are encouraged to review the Proposed Plan, attend the Public
Meeting, and comment on the remedial alternatives. Written comments should be
postmarked by October 16, 2020 at 5:00pm EST and emailed to Alida Karas,
Remedial Project Manager, at karas.alida@epa.gov. The Administrative Record file
containing the documents used on in developing the alternatives and preferred cleanup
plan is available for public review at www.epa.gov/superfund/cinnaminson
-------
Experts cite 'crimes against
humanity' in Maduro's Venezuela
Burlington county Times Thureday, September 17,2020 A
PAID ADVERTISEMENT
New $2 Joint Pill Could Put
Pennsylvania Surgeons
Out Of Work By 2022
Studies show active ingredient relieves joint pain
in 7 days without dangerous side effects or surgery.
Approved by top doctors nationwide. Relieves joint
stiffness. Increases joint mobility and freedom.
Elaine Williams' surgeon reschedules her knee-replacement
surgery until further notice after tests and x-rays show
noticeable improvement in her once-painful joint Patients who
have trialed the new $2 joint pill called FlexJointPlus notice a
significant Improvement in joint pain In just days.
By Jamey Keaten
The Associated Press
GENEVA - Independent
experts for the U.N.'s
top human rights body
accused the government
of Venezuelan President
Nicolas Maduro on
Wednesday of crimes
against humanity, high-
lighting grisly cases
of torture and killings
allegedly carried out by
security forces who used
techniques like electric
shocks, genital mutilation
and asphyxiation.
In a scathing, in-depth
report commissioned
by the Human Rights
Council, the experts said
the people responsible for
extrajudicial executions,
enforced disappearances,
arbitrary detentions and
other crimes must be held
to account to provide jus -
tice for untold thousands
of victims and to ensure
such crimes don't happen
again.
The findings of the
report are likely to ratchet
up pressure on Maduro's
government, which has
overseen a country in
tatters with run away infla -
tion, a violent crackdown
and an exodus of millions
of Venezuelans who have
fled to neighboring coun-
tries to escape the turmoil
since he took power in
2013.
The experts delved into
nearly 3,000 cases, looked
at more than 5,000 kill-
ings and concluded that
Maduro and his defense
and interior ministers
were aware of the crimes
committed by Venezuelan
security forces and intel-
ligence agencies.
They further alleged
that high-level authori-
ties had both power and
oversight over the forces
and agencies, making the
top officials responsible.
Venezuelan authorities
were not immediately
available for comment.
Critics have already
accused Maduro's gov-
ernment of crimes against
humanity. But the 411-
page report represents
one of the most exten-
sive looks at recent rights
abuses in Venezuela,
drawing upon interviews
with victims, relatives,
witnesses, police, offi-
cials and judges, plus
videos, satellite imagery
and social media content.
The authors said they did
not receive responses from
the government.
The experts - Marta
Valinas of Portugal,
Francisco Cox Vial of
Chile, and Paul Seils of
Britain - worked under a
fact-finding mission that
the 47-nation Human
Rights Council, theU.N.'s
top human rights body, set
up in September to inves -
tig ate alleged acts of cruel,
inhumane or degrad-
ing treatment and other
human rights violations in
Venezuela since 2014.
"These acts were com -
mitted pursuant to two
state policies, one to quash
opposition to the gov-
ernment and another to
combat crime, including
by eliminating individuals
perceived as criminals,"
Valinas told reporters.
"We also consider that
the documented crimes
were committed as part
of a widespread and sys-
tematic attack against the
civilian population."
Imagine a pill that can
start helping you get
around more easily in just
a matter of days.
Then think of how great
it would be for your jjoints
to begin feeling better too.
Well there's no need
to imagine. A team of
scientists have delivered
an amazing new joint
pill thafs been clinically
shown to improve mobility
and relieve joint pain.
Now. after years of
development and testing,
it's now available to joint
sufferers across the U.S.
Patients who have
trialed the patented new
breakthrough found
in FlexjointPlus have
reported a huge reduction
in pain and a new lease on
life.
Sufferers currently rely
on prescription drugs or
costly injections, which
have dangerous side
effects.
But Upstate New York
senior Paul Sansbury says
his knee pain has gone
from 8 out of 10 to zero
after just 7 days, and no
longer needs a cane.
"I needed a left knee
replacement, but since
using FlexJointPlus, I have
less pain. I can walk...I
feel much comfort...and 1
ditched my cane. I am 82
years old," he says.
WHAT SCIENTISTS
DISCOVERED
FlexJointPlus contains an
amazing compound with
a known ability to rebuild
damaged cartilage and
ligaments associated with
joint pain.
This compound is
not a drug. It is the
active ingredient in
FlexJointPlus.
Studies show it naturally
reduces inflammation
while repairing bone and
cartilage in the joint.
Many joint pain sufferers
see an increase in
flexibility and mobility.
Others are able to get back
their daily routines.
They were only told to
take FlexJointPlus' active
ingredient every day.
The results were
incredible.
Taking FlexJointPlus'
active ingredient just
once daily significantly
reduced both joint pain
and stiffness compared to
placebo at 7, 30, and 60
days.
In fact, many patients
experienced greater than
50% reduction in pain and
stiffness at 60 days.
They also enjoyed an
improvement in stiffness
when first getting out of
the bed in the morning,
and an improvement in
pain when doing tight
household chores.
With these studies medical
doctors and researchers
have now proven the
active ingredients in
FlexJointPlus to be
a clinically effective
treatment for reducing
pain and stiffness
associated with joint
and connective tissue
disorders, especially
osteoarthritis.
The findings are
no adverse side effects
reported with the use of
NEM".
This is a bonus for
arthritis sufferers
who have been taking
prescription and over the
counter medications that
can cause severe gastric
irritation over time, like
NSAIDs.
This seems to be another
reason why FlexJointPlus'
release has triggered such
a frenzy of sales.
RECOMMENDED
BY U.S. MEDICAL
DOCTORS
"Based on my 20 years
of experience treating
people with osteoarthritis,
FlexJointPlus receives my
highest recommendation
to any person suffering
from joint pain and
stiffness," said Dr. David
Vallance, Rheumatologist
from Ann Arbor, Ml.
"One of my patients taking
FlexJointPlus has reported
a significant decrease in
pain when going up or
down stairs, sitting with
legs bent for an extended
period of time, and even
getting up from a seated
position," said Dr. Richard
f.ihrnn AirAnri^nr fmm
A mA United States
Environmental Protection
VLI Agency
EPA Invites Public Comment on a Proposed
Cleanup Plan for the Cinnaminson
Groundwater Contamination Superfund Site in
Cinnaminson and Delran, New jersey
The U.S. Environmental Protection Agency (EPA) issued a Proposed
Plan 10 address Operable Unit 4 (0U4)of live Cinnaminson Groundwater
Contamination Superfund site on September 17,2020.lite Proposed Plan
is available electronically at www.epa.gov,'superfimd/tirinaminsoo.
EI'A's preferred cleanup plan for the site, described in this Proposed Plan,
consists of groundwater remediation using pumping and treatment near
source areas, and discharge of the treated water to surface water.
A 30-day public comment period for the Proposed Plan will run from
September 17,2020 to October 16,2020.The plan identifies the preferred
cleanup options considered by the EPA. To address public questions
and concerns about the proposed cleanup plan, EPA will host a Virtual
Public Meeting on Thursday, October 1,2020 from 6:0l)pro-«:
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
NEWS RELEASE
WWW.EPA.GOV/NEW5ROOM
frogtKt Im q S&ongw Future
EPA Proposes Cleanup Plan to Address Groundwater Contamination in the Townships
of Cinnaminson and Delran, Burlington County, New Jersey
Contact: Stephen McBay, (212) 637-3672, mcbay.stephen@epa.gov
New York (September 17, 2020) - The U.S. Environmental Protection Agency (EPA) is proposing a
cleanup plan to address groundwater contamination in Cinnaminson and Delran. This proposal includes
groundwater remediation using pump, treat, and discharge methods that will capture groundwater
contamination that can pose serious health risks. Long-term monitoring of the groundwater in addition
to other protective measures will be conducted.
"EPA is working with the New Jersey Department of Environmental Protection and the Townships of
Cinnaminson and Delran to ensure proper treatment of these organic compounds in the groundwater,"
said EPA Regional Administrator Pete Lopez. "EPA has protected local residents by selecting remedies
that call for installation of vapor recovery systems at impacted properties, a groundwater pump and
treatment system and landfill caps and will continue its important work of protecting human health
and the environment."
Because of the nature and complexity of the contamination at the Cinnaminson Groundwater
Contamination Superfund Site, the investigations and cleanup of the site have been conducted in four
Operable Units (OUs). This proposed plan focuses on Operable Unit 4 which addresses groundwater
contamination outside of areas already under remediation or investigation as part of OUs 1, 2, and 3.
The SLI Landfills, Messer LLC (formerly Linde LLC and BOC Gases) and Detrex Corporation properties
are the primary identified sources of the groundwater contamination.
Under the proposed cleanup plan announced today, EPA is proposing to target highly concentrated
portions of the contaminated groundwater near the source areas by using a pump and treat remedy.
EPA will implement institutional controls such as restricting the use of groundwater from the site and
long-term monitoring to prevent and reduce human exposure to contaminated groundwater until the
cleanup goals are met. Furthermore, EPA is requiring periodic collection and analysis of groundwater
samples to verify that the level and extent of contaminants are declining.
In 2009, EPA began investigating whether vapors from the groundwater contamination in the area
were getting into nearby homes. Approximately 60 properties were sampled and several
mitigation systems to vent the contaminated vapors were required. These systems have been
installed or are currently scheduled to be installed. This vapor intrusion investigation and
mitigation continues under OU3.
A 30-day public comment period for the proposed plan will occur from September 17 to October
16. EPA will host a Virtual Public Meeting on October 1 at 6:00 p.m. To register for the public
meeting, visit https://cinnaminson-superfund.eventbrite.com.To learn more about the public
meeting, visit www.epa.gov/superfund/cinnaminson or contact Natalie Loney at
loney.natalie@epa.gov or (212) 637-3639.
v>EPA
epa. gov/50
#EPAat50
-------
Written comments on EPA's proposed plan may be mailed or emailed to Alida Karas, Remedial Project
Manager, U.S. Environmental Protection Agency, 290 Broadway, 19th Floor, New York, New York
10007-1866 or karas.alida@epa.gov. Comments postmarked on or before October 16th, will be
accepted.
EPA's proposed plan for the site will be made available at www.epa.gov/superfund/cinnaminson.
Follow EPA Region 2 on Twitter at http://twitter.com/eparegion2 and visit our Facebook page,
http://facebook.com/eparegion2
20-062
Burlington county Time Sunday, October 25,2020 B5
California utility may cut power to 1 million people
The Associated Press
SAN FRANCISCO -
Pacific Gas & Electric
may cut power to over l
million people on Sunday
to prevent the chance
of sparking wildfires as
extreme fire weather
returns to the region, the
utility announced Friday.
The nation's largest util -
ity said it could black out
customers in 38 counties
- including most of the
San Francisco Bay Area -
as weather forecasts called
for a return of bone-dry,
gusty weather that carries
the threat of downing or
fouling po wer lines or other
equipment that in recent
years have been blamed
for igniting massive and
deadly blazes in central and
Northern California.
The safety shutoffs were
expected to begin as early
as Sunday morning and
last into Tuesday, affect-
ing 466,000 homes and
businesses, or more than
1 million residents assum -
ing between two and three
people per home or busi-
ness customer.
Cuts are predicted to
encompass parts of the
Sacramento Valley, the
northern and central Sierra
Nevada, upper eleva-
tions of the San Francisco
Bay Area, the Santa Cruz
Mountains, the Central
Coast and portions of
southern Kern County.
The projected shutoffs
included 19,000 customers
in parts of Butte County,
where a 2018 blaze ignited
by PG&E equipment
destroyed much of the
town of Paradise and killed
85 people.
Forecasts call for the
"the driest humidity levels
and the strongest winds of
the wildfire season thus
far," a PG&E statement
said.
The National Weather
Pacific Gas & Electric said it could black out customers in 38 counties -
the San Francisco Bay Area, [jeff chiu/associated press file photo]
Service issued red flag
warnings for many areas,
predicting winds of 35 mph
or higher in San Francisco
and lower elevations and
up to 70 mph (113 kph)
in some mountains. The
concern is that any spark
could be blown into flames
sweeping through tinder-
dry brush and f orestland.
"On a scale of 1 to 10,
this event is a 9," Craig
Clements, director of San
Jose State University's
Fire Weather Lab, told
the Bay Area News Group.
"Historically our biggest
fires are in October. We are
in a critical period."
The National Weather
Service said the condi-
tions could equal those
during devastating fires
in California's wind coun-
try in 2017 and last year's
KincadeFire.
Fire officials said PG&E
transmission lines sparked
that Sonoma County
fire last October, which
destroyed hundreds of
homes and caused nearly
100,000 people to flee.
The public safety power
shutoff, orPSPS, would be
the fifth this year, including
one that began Wednesday
including meat of
215-946-30971
extreme dry fuels due to
the hottest average tem-
peratures over the last
six months according to
records that go back 126
years, and extreme drought
across the territory given
lack of rainfall," he said in
a statement.
Southern California,
meanwhile, continued to
cool down with patchy
drizzle. Forecasters said
light rain was expected
Saturday night through
early Monday, with light
mountain snow possible
Sunday night, followed by
Santa Ana winds.
Eight of the 10 deadliest
fires in California history
have occurred in October
or November. Some of the
largest also have occurred
since August of this year.
The California
Department of Forestry
and Fire Protection, known
as Cal Fire, said 5,Soo
firefighters were work-
ing Friday to fully contain
19 wildfires. Two-dozen
new fires were contained
Thursday despite red flag
conditions. Numerous
studies have linked bigger
wildfires in America to
climate change from the
burning of coal, oil and gas.
Scientists say climate
change has made California
much drier, meaning trees
and other plants are more
flammable.
More 8,600 wildfires
have scorched well over
6,400 square miles and
destroyed about 9,200
buildings in California this
year. There have been 31
deaths.
All of the huge fires have
been fully or significantly
contained, but more than
6,000 firefighters remain
committed to 19 blazes,
including a dozen major
incidents, Cal Fire said.
BONDED & INSURED
COMPETITIVE PRICING
United States
Environmental Protection
Agency
EPA Extends the Public Comment Period
on a Proposed Cleanup Plan for the
Cinnamtnson Groundwater Contamination
Superfund Site in Cinnaminson and
Delran, New Jersey
The U.S. Environmental Protection Agency (EPA) issued a
Proposed Plan to address Operable Unit 4 (OU4) of the
Cinnaminson Groundwater Contamination Superfund site
on September 17, 2020. The Proposed Plan is available
electronically at www.epa.gov/superfund/clnnamlnson.
EPA's preferred cleanup plan for the site, described in this
Proposed Plan, consists of groundwater remediation using
pumping and treatment near source areas, and discharge of
the treated water to surface water.
The 30-day public comment period for the Proposed
Plan which began September 17, 2020 has been
extended by 30 days and will end on November 16, 2020.
The plan identifies Hie preferred cleanup options considered
by the EPA.
Relevant stakeholders are encouraged to review the Proposed
Plan and comment on the remedial alternatives. Written
comments should be postmarked by November 16,
2020 at 5:00pm EST and emailed to Alida Karas, Remedial
Project Manager, at karas.alida@epa.gov. The Administrative
Record file containing the documents used in developing the
alternatives and preferred cleanup plan is available for public
review at www.epa.gov/superfund/cinnaminson kminimum.
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From: Maiette. Yolanda
Subject; PRESS RELEASE: EPA Provides Additional Time for Public Review of Proposed Cleanup Plan to Address
Groundwater Contamination in the Townships of Cinnaminson and Delran, Burlington County, New Jersey
Date: Friday, October 16, 2020 11:03:56 AM
U.S. ENVIRONMENTAL PROTECTION AGENCY
NEWS RELEASE
WWW.EPA.GOV/NEWSROOM
hegre» b g Skoego future
EPA Provides Additional Time for Public Review of Proposed Cleanup Plan to Address
Groundwater Contamination in the Townships of Cinnaminson and Delran, Burlington
County, New Jersey
Contact: Stephen McBay, (212) 637-3672, mcbav.stephen@epa.gov
New York (October 16, 2020) - The U.S. Environmental Protection Agency (EPA) has
extended the public comment period to November 16, 2020 for its proposed cleanup plan to
address groundwater contamination in Cinnaminson and Delran, New Jersey. This 30-day
extension to November 16, 2020, along with the 30 days already provided for public review,
will give the community an extended opportunity to review the proposed plan.
EPA's proposed plan is to target highly concentrated portions of the contaminated
groundwater near the source areas by using a pump and treat remedy. EPA will implement
institutional controls such as restricting the use of groundwater from the Cinnaminson
Groundwater Contamination Superfund Site and long-term monitoring to prevent and reduce
human exposure to contaminated groundwater until the cleanup goals are met. Furthermore,
EPA is requiring periodic collection and analysis of groundwater samples to verify that the
level and extent of contaminants are declining.
Because of the nature and complexity of the contamination at the site, the investigations and
cleanup of the site have been conducted in four Operable Units (OUs). This proposed plan
focuses on Operable Unit 4 which addresses groundwater contamination outside of areas
already under remediation or investigation as part of OUs 1, 2, and 3. The SLI Landfills,
Messer LLC (formerly Linde LLC and BOC Gases) and Detrex Corporation properties are the
primary identified sources of the groundwater contamination.
EPA released the plan for public review on September 17, 2020 and held a public
meeting to explain and receive comments on the proposed plan on October 1, 2020.
Written comments on EPA's proposed plan, postmarked no later than close of business
November 16, 2020, may be mailed or emailed to: Alida Karas, Remedial Project Manager,
U.S. Environmental Protection Agency, 290 Broadway, 19lil Floor, New York, New York
10007-1866, Email: karas.alida@epa.gov.
EPA has included in the existing Administrative Record file all the RI/FS data in an
alternative format.
To view the EPA's proposed plan for the site, please visit
www.epa.gov/superfund/cinnaminson.
Follow EPA Region 2 on Twitter at http://twitter.com/eparegion2 and visit our Facebook page,
http: //faceb ook. com/epare gi on2
20-076
*615637*
615637
-------
ATTACHMENT C - Public Meeting Transcript
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
VIRTUAL PUBLIC MEETING FOR PROPOSED PLAN FOR OU4
Thursday, October 1, 2 02 0
6:03 p.m. - 6:42 p.m.
PRESENTED BY:
REPORTED BY:
Natalie Loney
Dan St. Germain
Shereen Kandil
Jeff Josephson
Elizabeth Tiedemann,
Registered Professional Reporter
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 2
1
INDEX OF MEETING
2
PAGE
3
OPENING COMMENTS
4
By Ms. Loney
3
5
TECHNICAL PRESENTATION
6
By Mr. St. Germain
6
7
QUESTION AND ANSWER SESSION
19
8
CLOSING COMMENTS and ADDITIONAL QUESTIONS
24
9
CERTIFICATE OF REPORTER
28
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 MS. LONEY: Okay. It looks like the log-ons
2 have slowed down a bit, so we' re going to get
3 started. My name is Natalie Loney. I'm a
4 Community Involvement Coordinator with EPA
5 Region 2 . And this is the virtual public meeting
6 for the Cinnaminson Groundwater Contamination
7 Superfund Site.
8 Before we actually start the presentation,
9 we' re going to kind of go over the Skype -- thank
10 you -- the Skype meeting controls . We ask that all
11 attendees: Please mute your speakers. Mute your
12 microphones, rather . And I ' m just going to go over
13 for -- some of you, you may be familiar with this,
14 but for those who are not, I just wanted to go over
15 the Skype meeting controls that you should be
16 seeing on your computer screen.
17 The two -- probably the two most important
18 controls are on the bottom of your screen. To the
19 left-hand corner, the -- what looks like a thought
20 bubble, that is if you want to ask a question or
21 share a comment. You can -- you can start there.
22 The microphone at the bottom of the screen, which
23 is kind of the center of the image, please make
24 sure that' s muted. The - - at the top of the
25 screen, if you'd like to enlarge the meeting,
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1 there's a double arrow. So you can expand the
2 slide presentation to the maximum size your
3 computer screen allows. And if you'd like to
4 change the actual layout of the slide presentation,
5 you can click on the box the arrow is pointing to.
6 If you can go to the next slide, please .
7 Two other things that I need to let you know.
8 This is a public meeting. Even though it' s in
9 virtual form, all of the protocols that we would
10 normally implement in a live meeting we will be
11 doing. You can ask questions or make comments in
12 two ways during the course of the meeting. One is
13 through the Skype box. There' s a Skype chat box
14 that you can enter your questions or comments to.
15 You can submit your questions via the chat box at
16 the end of the presentation.
17 When we unmute the lines during the Q and A
18 portion, Shereen Kandil, who is another CIC with
19 EPA, will be facilitating the questions by category
20 and in alphabetical order. So please wait to hear
21 your category. For example, if you're a resident
22 or an elected official or a business owner, then we
23 will ask that you - - we will be going by order of
24 your last name. This - - as I said, this is a
25 recorded presentation. In addition, there is a
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1 stenographer present. So we ask that: When you
2 ask your question, please begin by stating and
3 spelling your name and affiliation.
4 And finally - - if you can, go back to the
5 previous slide for a moment. If you run into
6 technical difficulties during the course of the
7 presentation, we do have technical support
8 available. You can e-mail Jas, or
9 JonathanSandlin@epa.gov, and he should be able to
10 help you with any of the issues you may have.
11 In addition, we do have -- this meeting is
12 being transcribed, and there is a closed captioning
13 link and instructions on how to access that
14 information. That is available in the chat box,
15 and we will be referring to that periodically over
16 the course of the evening.
17 So now I ' m going to turn the -- go to the
18 next slide.
19 So now I ' m going to turn the stage over to
20 Dan St. Germain. He will be doing the
21 presentation. At the end of Dan's presentation
22 when we open the Q and As, we will first be looking
23 at the chat box to get those questions and
24 comments, and then we will be opening the
25 microphones for verbal comments.
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1 At the end of the presentation, I'll be going
2 over again the comment period with you if you are
3 unable or you' d like to take a little bit more time
4 to compile your comment or question. You can
5 submit it to the RPM for the site, and all of that
6 detailed information will be presented again at the
7 end of the presentation. So Dan, take it away.
8 MR. ST. GERMAIN: Great. Thank you, Natalie.
9 So let' s get started. I' d like to start by
10 introducing our team. Natalie Loney, as she's been
11 speaking for the last five or ten minutes, is our
12 EPA Community Involvement Coordinator. Alida Karas
13 is our EPA Remedial Project Manager. Jeff
14 Josephson is our EPA Section Chief . Chuck Nace and
15 Ula Filipowicz are our EPA Risk Assessors. Liana
16 Agrios is our EPA hydrogeologist. 0'shea Smith is
17 our EPA Government Information Specialist. And
18 Shereen Kandil is our EPA Community Affairs person.
19 The next subj ect on our agenda is the
20 Superfund process. The federal Superfund law is
21 officially known as the Comprehensive Environmental
22 Response, Compensation, and Liability Act of 1980,
23 also called CERCLA. The federal Superfund program,
24 administered by the U.S. EPA, is designed to
25 investigate and clean up sites contaminated with
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1 hazardous substances. Sites managed under this
2 program are referred to as "Superfund" sites.
3 This is a description of the overall
4 Superfund process. The Cinnaminson site has
5 multiple Operable Units, or manageable pieces, and
6 this presentation is going to focus on Operable
7 Unit Number 4 . We will discuss each of the four
8 Operable Units later in this presentation. The
9 first step is to assess if there is a problem.
10 Groundwater samples collected in the 1980s show the
11 groundwater was contaminated with chlorinated
12 solvents.
13 The second step is to answer the question:
14 What and where is the risk? The EPA completed a
15 remedial investigation and a risk assessment. The
16 results will be shown in this presentation.
17 The third step is to devise a way to clean up
18 the contamination. The results are presented in a
19 Feasibility Study. That will also be discussed in
20 this presentation.
21 The fourth step is to select the solution and
22 present it to the public in this proposed plan and
23 ask for comments . The last step in this portion of
24 the Superfund process is to document how the site
25 will be cleaned up in what is called a Record of
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1 Decision.
2 We already talked about the first four
3 bullets on this slide, but the Superfund process
4 doesn't end there. After the Record of Decision,
5 the EPA will complete an engineering design of the
6 remedy. The EPA will construct the remedy, and the
7 EPA will conduct operation and maintenance and
8 long-term monitoring of the remedy to make sure it
9 completes the EPA goals.
10 Now, let's talk about the site. The
11 Cinnaminson Groundwater Contamination Site is in
12 Cinnaminson and Delran, New Jersey. It's located
13 about 10 miles north of Philadelphia as shown on
14 this map.
15 The EPA placed the site on the NPL in 1986,
16 dividing it into four distinct and manageable
17 pieces called Operable Units. Operable Unit 1
18 includes the groundwater contamination at the SLI
19 landfills now owned by Waste Management.
20 Operable Unit 2 focuses on capping the
21 landfills.
22 Operable Unit 3 is associated with
23 contamination at Messer, formerly Linde and BOC
24 Gases.
25 Operable Unit 4, the subj ect of this
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1 presentation, focuses on groundwater contamination
2 not addressed by the first three Operable Units.
3 There are three sources of groundwater
4 contamination. The first is the SLI landfills.
5 The landfills were capped in 1981. A groundwater
6 pump and treat system operated from 2000 to 2018.
7 The system was temporarily shut down because of
8 improved groundwater quality conditions and is
9 currently being evaluated with long-term
10 monitoring.
11 Groundwater contamination has been
12 characterized to include industrial solvents. It
13 is important to understand that we will discuss
14 three sources, and all three have released similar
15 industrial solvents that include: perchloroethene,
16 also called PCE; trichloroethene, also called TCE;
17 dichloroethane, also called DCE; and vinyl
18 chloride, to name a few.
19 Even though the same group of industrial
20 solvents were released at all three sources, there
21 are differences between the groundwater
22 contamination that allows us to track the
23 contamination at each site. Groundwater at the SLI
24 landfills contains mainly PCE and TCE with minor
25 amounts of DCE and vinyl chloride.
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1 The colorful pie diagram on this slide shows
2 the relative percent of each compound in a
3 groundwater sample collected near the source area.
4 PCE is shown in blue. TCE is shown in red. DCE is
5 in green. And vinyl chloride is in orange.
6 The second source of groundwater
7 contamination is Messer. Groundwater contamination
8 is mainly TCE and DCE with minor amounts of vinyl
9 chloride. You can see that the colors in the pie
10 diagram have changed from mainly blue, or PCE, to
11 mainly red and green, TCE and DCE.
12 The third source of groundwater contamination
13 is Detrex. The site was used as a industrial
14 solvent storage facility. Groundwater
15 contamination is mainly TCE and a smaller amount of
16 DCE and PCE. However, the colors on the pie
17 diagram have changed again from red and green on
18 the last slide to mostly red, or TCE, with no
19 green.
20 The next step for our team was to complete a
21 remedial investigation where we collect a lot of
22 groundwater, surface water, soil, and river
23 sediment samples.
24 To do this, we have to understand the geology
25 and the aquifers in the area. In this part of New
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
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1 Jersey, we have four geologic formations that form
2 two aquifers. First is the Pennsauken Formation
3 which forms the Pennsauken aquifer. It is very
4 small in that it extends from the Messer property
5 to the Delaware River. Potomack, Raritan, and
6 Magothy formations form what is called PRM aquifer.
7 It's a very large, wedge-shaped aquifer extending
8 from this area to the Atlantic Ocean and beyond.
9 The bottom of the RPM here is roughly a hundred
10 feet deep. The bottom of the RPM at the New Jersey
11 shore is over a thousand feet deep.
12 This is a groundwater map from 1900 . You can
13 see that historically groundwater was about 10 feet
14 above sea level near the site, and groundwater
15 migrates towards and discharges to the Delaware
16 River.
17 As I said, our team drilled borings and
18 wells. We collected groundwater, soil, surface
19 water, and sediment samples. We also measured the
20 elevation of the water in the aquifers. And we
21 used this information to understand groundwater
22 flow, and we used this information to assess
23 contamination.
24 There are a few streams near our site. They
25 include the Delaware River, Pompeston Creek, and
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
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1 Swede Run.
2 This map shows the elevation of groundwater
3 in the aquifers . You can see on the map that
4 groundwater is lower than it was in 1900 .
5 Groundwater ranges from a few feet above sea level
6 to a few feet below sea level today. Whereas, in
7 1900 it was about 10 feet above sea level. And
8 groundwater is not flowing towards the Delaware
9 River. Groundwater is actually flowing away from
10 the Delaware River to the southeast of the site.
11 Groundwater flow has changed since the 1900s in
12 order to meet increasing demand to provide drinking
13 water to the region.
14 All of this information has been pulled
15 together and here are the major findings.
16 Groundwater mainly flows southeast away from the
17 Delaware River due to increased demand for
18 municipal water supply. Chlorinated solvents were
19 identified to have been released in three
20 facilities: SLI Landfills, Messer, and Detrex.
21 Each source has a unique chemical signature.
22 Groundwater containing industrial solvents are
23 migrating to the southeast. Chemical signatures
24 were used to define three distinct and commingled
25 plumes . Each plume is roughly 2x/2 miles long, a
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1 half-mile wide, 100 to 150 feet thick, and is up to
2 3 00 feet at the far end of the plume.
3 The next step in our process is to evaluate
4 the data in a human health and ecological risk
5 assessment. The results of the human health risk
6 assessment show drinking water -- let me say that
7 again. The results show that groundwater with
8 industrial solvents would pose a risk to human
9 health. Therefore, remedial action is necessary.
10 Even though a few chemicals were detected in soil,
11 surface water, and sediment that could pose a risk
12 to the ecological habitat, these chemicals are not
13 related to the site.
14 So now we know we have groundwater
15 contamination, that it poses a risk to human
16 health, and remedial action is required. So let's
17 now talk about how we evaluate what to do. This
18 process is called a Feasibility Study.
19 A Feasibility Study generally serves as the
20 principal technical basis for the proposed remedy.
21 The Feasibility Study includes a detailed
22 evaluation of engineering solutions called remedial
23 alternatives. A Feasibility Study provides the
24 technical basis for EPA's selection of which
25 remedial action will be implemented. A Feasibility
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1 Study supports the development of a Record of
2 Decision, which is a legal decision document.
3 One of the first things we do in a
4 Feasibility Study is define our obj ectives. The
5 first obj ective is to minimize migration of
6 groundwater contamination. The second obj ective is
7 to prevent or minimize exposure to groundwater
8 contamination. The third obj ective is to restore
9 the aquifer so the aquifer can be used for drinking
10 water again.
11 The next thing we need to do is define our
12 preliminary remediation goals, also called PRGs,
13 for each chemical detected in groundwater. The
14 PRGs have been defined as the lowest of the Federal
15 and State Maximum Contaminant Levels and the New
16 Jersey Groundwater Quality Standards. PRGs allow
17 us to define what portion of groundwater needs to
18 be remediated.
19 We talked before about the fact that
20 groundwater is overpumped for municipal water
21 supply in this part of New Jersey so much so that
22 the groundwater is flowing away from its natural
23 discharge, the Delaware River. The State of New
24 Jersey recognized this issue many years ago and
25 established water supply critical areas where
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1 additional municipal withdrawals are not allowed in
2 accordance with the Water Supply Management Act.
3 Now that we understand our goals, what
4 portion of the aquifer we need to clean up, and
5 that additional aquifer withdrawals would make a
6 groundwater supply challenge even worse, our next
7 step is to evaluate technologies that can achieve
8 these goals . Our team screened a lot of different
9 engineering technologies and developed a list of
10 these options. Let's go through this list.
11 First on the list is no action, which is
12 required by law for us to evaluate. Second is
13 institutional controls. Third is long-term
14 monitoring. Fourth is containment and hydraulic
15 barrier and groundwater pumping where
16 groundwater -- where all of the contaminated
17 groundwater would be removed from the aquifer.
18 Next is treatment using an absorption, oxidation,
19 or air stripping to remove the chemicals from
20 groundwater. Next is: How are we going to get rid
21 of the groundwater? It could be discharged to
22 surface water. It could be inj ected into
23 groundwater, or it could be disposed in a POTW, or
24 Publicly Owned Treatment Works.
25 Let's look at how these technologies have
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1 been combined into remedial alternatives. These
2 might all look very similar, but I'11 explain each
3 one in detail over the next few slides .
4 This is just as it sounds. Nothing
5 additional will be done with Operable Unit 4 that
6 isn ' t done today . This is required by law.
7 Alternative 2 is called Institutional
8 Controls and Long-Term Monitoring. An example of
9 institutional controls is a classification
10 exemption area, also called a CEA. This is an area
11 where no new withdrawals of groundwater are
12 allowed. The long-term monitoring includes the
13 collection of groundwater samples for many years to
14 monitor or track the groundwater contamination.
15 The total cost of this alternative is estimated to
16 be $3.65 million.
17 Alternative 3 is hydraulic containment. This
18 approach captures all of the groundwater-containing
19 contaminants above the PRGs or maximum State MCLs
20 or New Jersey groundwater quality standards. For
21 this scenario, three wells would be installed.
22 Groundwater would be extracted at 2.6 million
23 gallons a day, or roughly 1800 gallons a minute.
24 The water would be treated to remove solids,
25 metals, and volatile organic compounds. The
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1 treated water would be conveyed and discharged to
2 Pennsauken Creek. The total estimated cost is
3 $4 9.66 million. The amount of time estimated to
4 clean up this groundwater would be about a hundred
5 years.
6 Alternative 4, Groundwater Remediation. This
7 approach captures all of the groundwater-containing
8 contaminates above the PRGs. However, this
9 approach has an additional set of wells in the
10 middle of the plume to reduce the cleanup time.
11 For this scenario, six wells would be installed, up
12 to 5.2 million gallons a day, or about 3200 gallons
13 a minute. The water would be treated to remove
14 solids, metals, and volatile organic compounds.
15 The treated water would be conveyed and discharged
16 to Pennsauken Creek. The estimated cost is
17 $94.416 million. The estimated cleanup time is
18 approximately 50 years.
19 Alternative 5 is called Core of Plume
20 Remediation. This approach includes three wells
21 that pump groundwater from the core or the most
22 contaminated portions of the three plumes. It
23 includes three wells, pumping 2.6 million gallons a
24 day, or 1800 gallons a minute. The water would be
25 treated to remove solids, metals, and volatile
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1 organic components. Treated water would be
2 conveyed and discharged to Pennsauken Creek. Total
3 estimated cost is $48,077 million. Cleanup time
4 has been estimated to be 75 years .
5 Our last approach called Hydraulic
6 Containment of Principal Source is an approach that
7 targets the core of the Detrex and Messer plumes
8 near the source area. As you can see on this
9 figure, we're no longer pumping groundwater from
10 the far end of the plume. We' re now pumping
11 groundwater up close near Messer and where Detrex
12 is. This alternative includes four wells
13 extracting groundwater at 0.3 million gallons a
14 day, or about 200 gallons a minute. The water
15 would be treated for solids, metals, and VOCs.
16 Treated water would be conveyed and discharged to
17 Pompeston Creek. Total estimated cost is
18 $22,366 million, and the estimated cleanup time is
19 25 years.
20 The portion of the plume above the PRGs but
21 not remediated by this approach would be monitored
22 using long-term monitoring to make sure it does not
23 pose a risk to human health.
24 Each of these approaches were compared and
25 contrasted to select the preferred alternative.
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1 Each approach was evaluated using these nine
2 criteria. The first two are threshold criteria and
3 must be met for the alternative to move forward.
4 The next six are balancing criteria used to compare
5 and contrast the different approaches. The last
6 two are modifying criteria. It's the reason why we
7 hold a public meeting and a comment period, to
8 seek -- to seek feedback from the community.
9 After completing the evaluation, the EPA
10 selected Alternative 6 as the proposed alternative.
11 It includes the hydraulic containment of the
12 principal source of the plume, centralized
13 treatment, surface water discharge. Groundwater
14 discharge using injection wells will be evaluated
15 during the remedial design.
16 This completes the technical portion of this
17 presentation, and I'11 hand this presentation back
18 to Natalie.
19 MS. LONEY: Thank you. Thank you, Dan.
20 So we' re going to first go to the chat box to
21 see if there are any questions or comments.
22 Shereen?
23 MS. KANDIL: Hi, Natalie . Thanks . At this
24 time, there are no questions or comments, but we'11
25 check back in after the phone lines.
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1 MS. LONEY: Thank you, Shereen. I just muted
2 myself. So now we're going to ask people to unmute
3 their mics based on the protocol that I had
4 mentioned earlier. We're going to ask that if
5 there are any representatives or elected officials,
6 representatives of elected officials and they'd
7 like to ask a question, you can unmute your line
8 now. Please, for the record, state your first and
9 last name and spell it, ask your question, and we
10 will respond.
11 MR. RADAY: Hi. This is Joe Raday with
12 Cinnaminson Township. I'm the township engineer.
13 MS. LONEY: Yes.
14 MR. RADAY: I had a question about the
15 groundwater work that you did. So if I --if I was
16 listening correctly, they said based on history the
17 groundwater has actually lowered in this area. Did
18 I hear that correctly?
19 MR. ST. GERMAIN: That's correct.
20 MR. RADAY: Okay. That was all I had. Thank
21 you.
22 MS . LONEY: Thank you. Are there any other
23 elected officials or elected official
24 representatives?
25 Not hearing any, I ' m going to open the
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 21
1 microphones for residents or business owners,
2 starting the -- your last name starting from A
3 through L. You can unmute your mic and ask your
4 question or state your comment.
5 Okay. Not hearing any questions - - it looks
6 like we just received a statement in the chat box.
7 Shereen?
8 MS. KANDIL: Yes, from Joshua Vrancik. Sorry
9 if I pronounced your last name wrong.
10 "Have any of these alternatives been
11 implemented, or is that the purpose of this
12 discussion?"
13 MS . LONEY: Any member of the EPA team would
14 like to respond to that question?
15 MR. ST. GERMAIN: This is Dan. None of these
16 have been implemented yet. The purpose of today is
17 to present the options to you and to communicate to
18 you which option EPA has selected to implement.
19 MR. VRANCIK: Hi .
20 MS. LONEY: Yes. Someone has a comment?
21 MR. VRANCIK: Hi . This is Josh Vrancik. The
22 question was: Which one did you guys select? It
23 wasn't exactly -- I don' t know if I missed it in
24 the session or...
25 MR. ST. GERMAIN: The EPA selected
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 22
1 Alternative Number 6, which is to install four
2 wells up near where Messer and Detrex properties
3 are, extract groundwater at 200 gallons a minute,
4 treat the groundwater, and discharge it to
5 Pompeston Creek.
6 MR. VRANCIK: Okay. Has there been any study
7 on the health risks
8 MR. ST. GERMAIN: Yes.
9 PUBLIC PARTICIPANT: -- associated?
10 MR. ST. GERMAIN: Yes . A human health risk
11 assessment is an integral part of the EPA Superfund
12 process . So EPA did a - - a human health risk
13 assessment was completed for this proj ect and was
14 considered throughout the entire proj ect and the
15 process.
16 MR. VRANCIK: Thank you.
17 MS . LONEY: The human health risk assessor is
18 also on the line if you have a specific question
19 for him and her.
20 Shereen, I see there's another question in
21 the chat box.
22 MS . KANDIL : Yes . So this question comes in
23 Robert Carter.
24 "Has EPA started cost recovery from the
25 responsibility parties for 0U4?"
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 23
1 MR. JOSEPHSON: This is Jeff Josephson from
2 EPA. And no, not at this time, we have not. We
3 will select a final remedy, and after that point,
4 we will look at options for funding the selected
5 remedy.
6 MS. LONEY: Thank you. So now we ' re going
7 to -- it looks like we have another question in the
8 chat box.
9 MS. KANDIL : Yes . This comes from Kathy.
10 "Is there any way to use" -- oh, I ' m sorry.
11 "Is there any way to use the cursor on any of the
12 plume drawings to indicate Route 13 0? It's hard to
13 get my bearings on how far the plume traveled."
14 So Kathy, we're turning back to the slides.
15 Dan, you' re unmuted, so if you want to just talk
16 through your cursor and just indicate where it is.
17 MR. ST. GERMAIN: The cursor -- this is
18 Route 13 0 here. The plumes are about 2x/2 miles
19 long. So Route 13 0 is about the middle mark of the
20 plumes.
21 MS. LONEY: Thank you, Dan. Seeing no
22 further comments in the -- spoke too soon. I
23 see
24 MS . KANDIL: Sorry. Yeah, Joseph Raday asks
25 if we can obtain a PDF copy of this report. Are
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 24
1 you talking about the presentation? Yeah. Sure.
2 I just added the link, but we will be sending a
3 follow-up e-mail with further information about the
4 site and a link to the EPA site. But I ' m sending a
5 link that brings you directly to the presentation
6 in the chat box.
7 MS. LONEY: Thank you, Shereen. So back to
8 the microphone. For those who would like to make a
9 verbal comment or ask a question, for those whose
10 last names start with - - I think we ended at L. So
11 for last names starting from M through Z, the
12 mic -- you can open your mic and ask your question.
13 Okay. It appears that there are no more
14 questions coming in over the microphone. Shereen,
15 do we have any further comments in the chat box?
16 MS. KANDIL : Not at this time .
17 MS. LONEY: All right. So Dan, could you
18 scroll to the last slides of the presentation?
19 Next. Thank you.
20 So given that there are no more questions via
21 the chat box or via the microphone, we're going to
22 be closing out this public meeting. So if you did
23 not get an opportunity to present your question or
24 your comment and you have thought of something
25 after the meeting, you can send your question,
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Virtual Public Meeting on 10/01/2020 Page 25
1 comment, or concern by e-mail, by phone, or by mail
2 through the end of the comment period.
3 The comment period for this proposed plan
4 ends on October 16th, and the questions and
5 comments should be sent to Alida Karas, who is the
6 proj ect manager for this site. Her contact
7 information is on your screen. Please make sure
8 that your questions or comments are postmarked by
9 5:00 p.m. That, of course, would be via e-mail.
10 We would be accepting snail mail, or regular mail,
11 obviously with just the October 16th postmarked
12 date.
13 In addition, this presentation is available
14 on-line. If you look in the chat box, Shereen has
15 provided the link to the presentation. If you have
16 additional questions or concerns, if you'd like a
17 hard copy -- an electronic copy, rather, of the
18 presentation or any of the site-related documents,
19 you can contact me. My contact information is also
20 on the screen. Again, you don' t have to worry
21 about copying down any of this information. You
22 can go on to the Cinnaminson web page. All of the
23 site-related documents, along with this
24 presentation, is available.
25 It looks like we've got one more question.
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020
Page 26
1
Kathy: "Does any of the options include
2 using the aquifer again?"
3
MR. ST. GERMAIN: The options are designed to
4 extract the contaminated groundwater and remove the
5 contaminants from the groundwater in an attempt to
6 try to restore the aquifer so it can be used in the
7 future as a drinking -- this portion of the aquifer
8 as a drinking water source. The options considered
9 by the EPA are not designed to actually use it
10 right now, this portion of the plume right now, as
11 a drinking water source.
12 MS. LONEY: Thank you, Dan. Just want to
13 give people an opportunity before we close out this
14 meeting. Any last questions, comments, concerns,
15 either via the microphone or through the chat box?
16 MS. KANDIL: Natalie, we have another
17 question in the chat box. This is coming in from
18 Joshua.
19 "Has there been an impact to the drinking
20 water in the plume areas?"
21 MR. JOSEPHSON: This is Jeff from EPA. All
22 water that's consumed in the area is treated by
23 your local municipal water provider, and so no one
24 is drinking contaminated water within the area.
25 MS . LONEY: Thank you, Jeff . I ' 11 give you
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 27
1
folks another minute, 30 seconds to a minute, for
2
any last-minute questions or comments. I don't
3
want to close out the meeting without giving
4
everyone an opportunity.
5
Okay. So thank you, everyone, for
6
participating in the Cinnaminson Virtual Public
7
Meeting. The presentation, again, will be
8
available on the Cinnaminson web page. You have
9
until October 16th, which is the end of the
10
comment period, to submit your comments, questions.
11
All of that information is available on the EPA web
12
page for Cinnaminson, and my contact information is
13
available there as well, should you have any
14
questions. Thank you again for participating.
15
Have a good night.
16
(Meeting adjourned at 6:42 p.m.)
17
18
19
20
21
22
23
24
25
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Page 28
1 CERTIFICATE OF REPORTER
2 STATE OF FLORIDA )
3 COUNTY OF SAINT JOHNS )
4
5 I, Elizabeth Tiedemann, Registered
6 Professional Reporter, do hereby certify that I was
7 authorized to and did stenographically report the
8 foregoing meeting, and that the transcript is a true
9 record of the meeting proceedings.
10 I further certify that I am not a relative,
11 employee, attorney, or counsel of any of the parties or
12 participants, nor am I a relative or employee of any of
13 the parties' attorney or counsel connected with the
14 action, nor am I financially interested in this action.
15 Done and dated this 1st day of October, 2020
16 at Saint Johns County, Florida.
17
18 -Oirfft IT-r Xb
19
ELIZABETH TIEDEMANN
20 Registered Professional Reporter
21
22
23
24
25
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
$22.366
18 : 18
$3.65 16:16
$48,077 18 : 3
$49.66 17 : 3
$94,416
17 : 17
0.3 18 : 13
1 8 : 17
10 8:13
11:13 12 : 7
100 13 : 1
130 23:12,
18, 19
150 13 : 1
16th 25:4,
Virtual Public Meeting on 10/01/2020
1981 9 : 5
1986 8 : 15
3 8 : 22
16 : 17
30 27:1
300 13 : 2
3200 17:12
50 17:18
5:00 25 : 9
2 3 : 5 8:20
16 : 7
2.6 16 : 22
17 : 23
200 18:14
22 : 3
2000 9 : 6
2018 9 : 6
25 18:19
2y2 12 : 25
23 : 18
6 19 : 10
22 : 1
6:42 27:16
75 18 : 4
absorption
15 : 18
accepting
25 : 10
access 5 : 13
accordance
15 : 2
achieve 15:7
Act 6:22
15 : 2
Index: $22.366..amount
15 : 1,5
16 : 5 17 : 9
25 : 16
addressed
9 : 2
adjourned
27 : 16
administered
6 : 24
Affairs 6:18
affiliation
5 : 3
agenda 6:19
Agrios 6:16
air 15:19
Alida 6:12
25 : 5
allowed 15:1
16 : 12
alphabetical
4 : 20
alternative
16:7,15,17
11 27:9
1800 16:23
17 : 24
1900 11:12
12:4,7
4 7:7 8:25
16:5 17:6
action 13 : 9
16, 25
15 : 11
actual 4 : 4
added 24:2
17:6,19
18:12,25
19:3,10
22 : 1
alternatives
13 : 23 16 : 1
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
1900s 12:11 5 addition 21:10
4:25 5:11
1980 6:22 5 17:19 - - - - amount 10:15
25 : 13
1980s 7:10 5 2 17-12 jj ¦ i_ ¦ n
o.z ±/.±a additional
17:3
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Index: amounts.xhloride
amounts 9:25
10 : 8
appears
24 : 13
approach
16 : 18
17:7,9,20
18:5,6,21
19 : 1
approaches
18:24 19:5
approximately
17 : 18
assessment
7:15 13:5,
6 22:11,13
assessor
22 : 17
Assessors
6 : 15
Atlantic
11 : 8
attempt 2 6:5
attendees
3 : 11
aquifer
11:3,6,7
14:9 15 : 4
back 5 : 4
borings
11 : 17
bottom 3:18,
22 11:9,10
box 4:5,13,
15 5:14,23
19:20 21:6
22 : 21 23:8
24:6,15,21
25 : 14
26 : 15,17
brings 24:5
bubble 3:20
bullets 8 : 3
business
4 : 22 21 : 1
category
4:19,21
CEA 16:10
center 3:23
centralized
19 : 12
CERCLA 6 : 23
challenge
15 : 6
change 4 : 4
changed
10:10,17
12 : 11
characterized
9 : 12
5,17 26:2,
19:17,25
chat 4:13
6, 7
aquifers
10 : 25
11:2,20
12 : 3
area 10:3,
25 11 : 8
16 : 10 18:8
20:17
26:22,24
areas 14:25
26:20
arrow 4:1,5
asks 23:24
assess 7 : 9
11 : 22
23 : 14 24 : 7
balancing
19 : 4
barrier
15 : 15
based 20:3,
16
basis 13:2 0,
24
bearings
23 : 13
begin 5 : 2
bit 3 : 2 6 : 3
blue 10:4,
10
BOC 8:23
called 6:23
7 : 25 8 : 17
9:16,17
11 : 6
13:18,22
14 : 12
16:7,10
17 : 19 18:5
capped 9 : 5
capping 8:20
captioning
5 : 12
captures
16 : 18 17:7
Carter 2 2:23
15 5:14,23
19:20 21:6
22 : 21 23:8
24:6,15,21
25 : 14
26 : 15,17
check 19:25
chemical
12 : 21,23
14 : 13
chemicals
13:10,12
15 : 19
Chief 6:14
chloride
9:18,25
10:5,9
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Index: chlorinated.xontrols
chlorinated
7:11 12:18
Chuck 6:14
CIC 4:18
Cinnaminson
3:6 7:4
8:11,12
20:12
25 : 22
27 : 6,8,12
classification
16 : 9
clean 6:25
7:17 15 :4
17 : 4
cleaned 7:25
cleanup
17:10,17
18:3,18
click 4 : 5
close 18:11
26 : 13 27:3
closed 5:12
closing
24 : 22
collect
10 : 21
collected
7 : 10 10:3
11 : 18
collection
16 : 13
colorful
10 : 1
colors 10:9,
16
combined
16 : 1
comment 3:21
6:2,4 19:7
21:4,20
24:9,24
25:1,2,3
27 : 10
comments
4:11,14
5:24,25
7 : 23
19:21,24
23 : 22
24 : 15
2 5:5,8
26 : 14
27:2,10
commingled
12 : 24
communicate
21 : 17
community
3:4 6 : 12,
18 19:8
compare 19:4
compared
18 : 24
Compensation
6 : 22
compile 6 : 4
complete 8 : 5
10:20
completed
7:14 22 : 13
completes
8:9 19:16
completing
19 : 9
components
18 : 1
compound
10 : 2
compounds
16 : 25
17 : 14
Comprehensive
6 : 21
computer
3:16 4 : 3
concern 25:1
concerns
25 : 16
26 : 14
conditions
9 : 8
conduct 8 : 7
considered
22 : 14 26 : 8
construct
8 : 6
consumed
26 : 22
contact
25:6,19
27 : 12
containment
15 : 14
16 : 17 18:6
19 : 11
Contaminant
14 : 15
contaminants
16 : 19 26:5
contaminated
6 : 25 7 : 11
15 : 16
17 : 22
26 :4,24
contaminates
17 : 8
contamination
3:6 7:18
8:11,18,23
9:1,4,11,
22 , 23
10:7,12,15
11 : 23
13 : 15
14:6,8
16 : 14
contrast
19 : 5
contrasted
18 : 25
controls
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Index: conveyecL.drinking
3:10,15,18
15 : 13
16:8,9
conveyed
17:1,15
18:2,16
Coordinator
3:4 6 : 12
copy 23:25
25 : 17
copying
25 : 21
core 17:19,
21 18:7
corner 3:19
correct
20:19
correctly
20:16,18
cost 16:15
17:2,16
18:3,17
22 : 24
Creek 11:25
17:2,16
18:2,17
22 : 5
criteria
19:2,4,6
critical
14 : 25
cursor
23:11,16,
17
Dan 5:20
6 : 7 19:19
21 : 15
23 : 15,21
24 : 17
26 : 12
Dan1s 5:21
data 13:4
date 25:12
day 16:23
17:12,24
18 : 14
DCE 9:17,25
10:4,8,11,
16
decision
8:1,4 14 : 2
deep 11:10,
11
define 12:24
14:4,11,17
defined
14 : 14
Delaware
11:5,15,25
12:8,10,17
14 : 23
Delran 8 : 12
demand
12:12,17
description
7 : 3
design 8 : 5
19 : 15
designed
6 : 24 2 6:3,
9
detail 16 : 3
detailed 6 : 6
13 : 21
detected
13 : 10
14 : 13
Detrex 10:13
12 : 20
18:7,11
22 : 2
developed
15 : 9
development
14 : 1
devise 7:17
diagram
10:1,10,17
dichloroethane
9 : 17
differences
9 : 21
difficulties
5 : 6
directly
24 : 5
discharge
14 : 23
19:13,14
22 : 4
discharged
15 : 21
17:1,15
18:2,16
discharges
11 : 15
discuss 7 : 7
9 : 13
discussed
7 : 19
discussion
21 : 12
disposed
15 : 23
distinct
8:16 12 : 24
dividing
8 : 16
document
7 : 24 14 : 2
documents
25:18,23
double 4 : 1
drawings
23 : 12
drilled
11 : 17
drinking
12:12 13 : 6
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Index: due..fornis
14:9 26:7,
Environmental
explain 16:2
19 : 8
8,11,19,24
6 : 21
exposure
feet 11:10,
due 12:17
EPA 3 : 4
14 : 7
11, 13
4:19 6 : 12,
extending
12:5,6,7
E
13,14,15,
11 : 7
13:1,2
e-mail 5 : 8
16,17,18,
24 7:14
extends 11:4
figure 18:9
24 : 3 25:1,
8:5,6,7,9,
extract 22:3
Filipowicz
9
15 19 : 9
26:4
6 : 15
earlier 2 0:4
21:13,18,
extracted
final 2 3:3
25 22:11,
16 : 22
ecological
12,24 23 : 2
finally 5 : 4
13:4,12
24:4 26:9,
extracting
findings
elected 4:22
21 27:11
18 : 13
12 : 15
20:5,6,23
EPA11 s 13 : 24
flow 11:22
electronic
established
F
12 : 11
25 : 17
14 : 25
facilitating
flowing
elevation
estimated
4 : 19
12 : 8,9
14 : 22
11:20 12:2
16 : 15
facilities
end 4:16
17:2,3,16,
12 : 20
flows 12:16
5 : 21 6:1,7
17 18:3,4,
facility
focus 7 : 6
8:4 13 : 2
17, 18
10 : 14
18:10 25 : 2
focuses 8:20
evaluate
27:9
fact 14:19
9 : 1
13:3,17
ended 24:10
15:7,12
familiar
folks 27:1
ends 25:4
3 : 13
follow-up
evaluated
engineer
20 : 12
9:9 19:1,
Feasibility
24:3
14
7 : 19
13 : 18,19,
form 4 : 9
11:1,6
engineering
evaluation
21,23,25
Formation
8:5 13:22
13 : 22 19:9
14 : 4
15 : 9
11 : 2
evening 5:16
federal
enlarge 3:25
6:2 0,2 3
formations
exemption
11:1,6
enter 4:14
16:10
14 : 14
expand 4 : 1
forms 11:3
entire 22:14
feedback
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CINNAMINSON GROUDWATER CONTAMINATION SUPERFUND SITE
Virtual Public Meeting on 10/01/2020 Index: forward.industrial
forward 19:3
fourth 7:21
15 : 14
funding 23:4
future 2 6:7
gallons
16 : 23
17:12,23,
24 18:13,
14 22 : 3
Gases 8:24
generally
13 : 19
geologic
11 : 1
geology
10 : 24
Germain 5:20
6 : 8 20:19
21 : 15,25
22:8,10
23 : 17 26:3
give 2 6:13,
25
giving 2 7:3
goals 8 : 9
14 : 12
15:3,8
good 2 7:15
Government
6 : 17
Great 6 : 8
green 10:5,
11,17,19
groundwater
3:6 7:10,
11 8:11,18
9:1,3,5,8,
11,21,23
10:3,6,7,
12.14.22
11:12,13,
14.18.21
12:2,4,5,
8,9,11,16,
22 13:7,14
14:6,7,13,
16,17,20,
22 15:6,
15,16,17,
20.21.23
16:11,13,
14.20.22
17:4,6,21
18:9,11,13
19 : 13
20 : 15,17
22:3,4
26:4,5
groundwater-
containing
16 : 18 17:7
group 9:19
2«"i <"¦**» <"¦**»
1:22
habitat
13 : 12
half-mile
13 : 1
hand 19:17
hard 23:12
25 : 17
hazardous
7 : 1
health 13:4,
5,9,16
18 : 23
22:7,10,
12 , 17
hear 4:20
20 : 18
hearing
20:25 21:5
historically
11 : 13
history
20 : 16
hold 19:7
human 13:4,
5,8,15
18 : 23
22:10,12,
17
15 : 14
16 : 17 18:5
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ATTACHMENT D - Written Comments
-------
From: Karas, Alida
To: David Sordi
Cc: Philipp Sieber; Hertz, Michael; Marcum, Anna-Lisa; Richard Lingg; Drummond, Jesse; "Thomas Hundt";
Josephson, Jeff
Subject: RE: Cinnaminson Follow-up - documents/data
Date: Friday, September 18, 2020 11:47:35 AM
Attachments: imageOOl.png
image002.png
image004.png
* This message originated from outside of BSI. Please treat hyperlinks, attachments and instructions in this
email with caution. *
Hi Dave,
The link below will take you to the Administrative Record for the Cinnaminson Groundwater
Contamination Superfund Site OU4. The Administrative Record contains the Remedial Investigation
report and the Feasibility Study report as well as the Proposed Plan. These reports contain the data
that you are looking for.
https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?
fuseaction=second.ars&id=0200995&doc=Y&colid=66416®ion=02&type=AR
If there is anything else you need, please feel free to let me know.
Thank you,
Alida Karas
Remedial Project Manager
NJ Remediation Branch
U.S. EPA Region 2
290 Broadway
New York, NY 10007
From: David Sordi
Sent: Friday, September 18, 2020 11:12 AM
To: Karas, Alida ; Josephson, Jeff
Cc: Philipp Sieber ; Hertz, Michael ; Marcum,
Anna-Lisa ; Richard Lingg ; Drummond,
Jesse ; 'Thomas Hundt' trhffiatlanticecs.com
Subject: Cinnaminson Follow-up
Alida and Jeff,
Messer had an internal call today to discuss our next steps to review the information EPA published
yesterday for Cinnaminson OU-4 and determine how it relates to and/or impacts our strategy for
Cinnaminson OU-3. We expect to have our review done by mid-October, therefore I will be
rescheduling our joint call to October 15th.
-------
In the meantime, can you forward us the Excel or Access database for the data included in the OU-4
RIR and any GIS files? This will help us accelerate the evaluation we need to complete.
Thanks.
Dave Sordi, PE
Senior Project Manager
T: +603 941 0132
PO Box 389, Center Conway, NH 03813
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Messer LLC.
200 Somerset Corporate Blvd, Suite 7000, Bridgewater, NJ 08807
Phone 1-800-755-9277, www.messer-us.com Page | 1
COMMUNICATED VIA E-MAIL AND EXPRESS MAIL
October 6, 2020
Ms. Alida Karas
Remedial Project Manager
United States Environmental Protection Agency
Region 2
NJ Remediation Branch
290 Broadway
New York, NY 10007
RE: CINNAMINSON OPERABLE UNIT 4 (OU4) PROPOSED REMEDIATION PLAN —REQUEST FOR EXTENSION
OF TIME
Dear Ms. Karas,
Messer LLC (Messer) hereby requests a 60-day extension beyond the currently published public comment
period of September 17, 2020 to October 16, 2020 (for a total 90-day comment public period), to submit
comments to the recently published United States Environmental Protection Agency's (EPA's) OU4
Proposed Remediation Plan (hereinafter referred to as the "Plan"). Anything less than a 60-day extension
will deprive Messer of the opportunity to provide informed comments. Even such an extension could be
inadequate without a full disclosure of the technical information upon which EPA relied in preparing the
Proposed Plan. In addition, material technical data was not made publicly available which should be
posted on EPA's website for the benefit of the public to allow informed comments to be made. Messer
has previously requested this information and is submitting a further request for the information
simultaneously with this extension request. The specific reasons for Messer's extension request are as
follows:
1) Pursuant to the 1999 EPA Guidance (EPA 540-R-98-031) on preparing Superfund Proposed Plans and
Records of Decisions, a 30-day public comment period is the minimum duration. Given the complexity
of the Remedial Investigation and Feasibility Study (RI/FS) that involves the alleged contribution of
groundwater contamination by multiple parties, a 90-day comment period is necessary and warranted
for a comprehensive technical review and preparation of comments. The Cinnaminson area is notably
challenging (as acknowledged in the Rl) with several parties (known and possibly unknown) potentially
responsible for the groundwater contamination; varied groundwater flow direction based on changes
in groundwater pumping for both industrial, agricultural, and domestic use; and limited temporal
analyses of contaminants of concern in the OU4 monitoring wells.
Also pursuant to EPA's guidance, "CERCLA §117(a)(2) also requires the lead agency to provide the
public with a reasonable opportunity to submit written and oral comments on the Proposed Plan. NCP
§300.430(f)(3)(i) requires the lead agency to allow the public a minimum of 30 days to comment on
Messer LLC.
200 Somerset Corporate Blvd, Suite 7000, Bridgewater, NJ 08807
Phone 1-800-755-9277, www.messer-us.com
-------
Page | 2
the information contained in the RI/FS and Proposed Plan (including any proposed waivers relating to
ARARs). In addition, the lead agency must extend the comment period by a minimum of 30
additional days, upon timely request." In this case we are requesting an additional 60 days for a 90-
day total public comment period, with comments due to the EPA by December 15, 2020.
2) The OU4 Rl consists of over 4,800 pages and presents information from OU4 and three alleged
contamination sources including soil, groundwater, sediment, surface water, vapor intrusion,
remediation system results, and geologic data from five consultants generated over a span of more
than 20 years. The Feasibility Study report (FS) consists of over 190 pages and out of the universe of
potential remediation technologies, primarily relies on groundwater pump and treat as the primary
remedy. In addition, as discussed below, the Rl refers to and relies upon information not with the Rl
posted on EPA's website. The extension is necessary and warranted to adequately review and analyze
all the data and for Messer to be able to provide informed comments.
3) The FS states "empirical groundwater flow and solute transport data collected in the OU1 and OU4
studies/investigations were used in analytical models (aquifer flushing and first-order decay) to
estimate the period of performance of each remedial alternative." This modeling was not included in
the Rl or FS. Additionally, Figure 1-9 of the Rl illustrates monitoring well locations and sample results
from a 2018 investigation related to the Detrex site. This figure appears to be from a 2018 report by
Roux Associates that is not included with historical reports in Appendix A. Therefore, we request a
copy of the model methodology/results and a copy of the 2018 Roux Associates report used by EPA
to generate Figure 1-9 of the Rl. Obtaining this information is essential to providing informed
comments. Thus, the extension is necessary and warranted to review the highly complex groundwater
model and to make informed comments on the proposed alternative
4) Figure 3-5 of the OU4 depicts generalized groundwater flow directions in the shallow and deeper
portions of the unconsolidated aquifer beneath the demarcated area labelled "Messer." These
generalized groundwater flow directions appear to be based on Figures 1-4 (from an Atlantic
Environmental Consulting Services, LLC report dated April 1999). Within Appendix A of the OU4 Rl, a
2012 Rl report for the Detrex facility demonstrates shallow and intermediate groundwater flow to the
northeast from the reported source area. This flow direction in the shallower portion of the Detrex
site is not reflected on Figure 3-5 of the OU4 Rl. Again, the extension is required to assess this
northeasterly groundwater flow direction with respect to potential impacts on groundwater
monitoring well SL-4D, implications for the conceptual site model of OU4, and conclusions drawn on
the source(s) of the contamination identified in SL-4D.
5) Figure 4-6 illustrates a plume migrating from the "Messer" demarcated area toward SL-4D. However,
the OU4 Rl does not consider any of the recent OU3 data provided to EPA associated with OU3 (i.e.
Site Characterization Summary Report) including the results of the deep groundwater well BOCMW-
14, located hydraulically between the "Messer" demarcated area and monitoring well SL-4D. To
adequately assess the conclusions of the OU4 Rl report with respect to the OU3 data provided to EPA,
the requested additional time is necessary.
-------
MESSER (1}
Gases for Life
6) Regarding items 3, 4, and S above, Messer attempted to obtain for review the New Jersey Department
of Environmental Protection (NJDEP) case files for the Detrex facility and the Hoeganaes Landfill (i.e
. Seabox Landfill) through a NJDEP FOIA submission on 24 June 2020. According to the NJDEP,
due to the pandemic, onsite file reviews are not available and onsite copying by employees is not
being conducted either.
Because these sites were investigated by EPA as part of the OU4 Rl and the pandemic prevented
FOIA request compliance prior to EPA's release of the RI/FS and Plan, more time is needed to
review and analyze the information.
7) The Plan details that vapor intrusion (VI) activities are included as part of OU3 and not OU4. VI
activities, analyses, findings, and mitigation/remediation for areas outside of OUI, OU2, and OU3
have been developed/produced by EPA since 2009.
Because these sites were investigated by EPA as part of the OU4 Rl, and the related documents
have not been made available to date, the requested extension is warranted for this additional
review. It is also noted that the review of these VI findings/results need to be considered in
any future investigation activities (as necessary) for OU3.
In general, Messer has significant concerns with the RI/FS and Plan and needs the requested additional
time to fully and completely review the sizeable supporting information published by the EPA along with
the Plan, as well as the information yet to be provided.
If you have any questions, please feel free to contact me at (848)702-8769 or at philipp.sieber@messer-
us.com.
Sincerely,
Philipp Sieber
Director of Environment a I Management
Cc: J. Josephson, EPA (electronic only)
J. Brister, Messer (electronic only)
D. Sardi, BSI (electronic only)
T. Hundt, Atlantic (electronic only)
M. Hertz, EA (electronic only)
A. M arcum, EA (electronic only)
J. Drummond, EA (electronic only)
Messer LLC
-------
200 Somerset Corporate Blvd, Suite 7000, Bridge water, NJ 08807
Phone 1-800-755 -9277, www,rnesser-us,corn
-------
Gases for Life
COMMUNICATED VIA E-MAIL AND EXPRESS MAIL
October 6, 2020
Ms. Alida Karas
Remedial Project Manager
United States Environmental Protection Agency
Region 2
NJ Remediation Branch
290 Broadway
New York, NY 10007
RE: CINNAMINSON OPERABLE UNIT 4 (OU4) REQUEST FOR SUPPORTING DATA AND NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION (NJDEP) FOIA REQUEST
Dear Ms. Karas,
By E-mail to you dated September 18, 2020 Dave Sordi (on behalf of Messer LLC) ("Messer") requested
the Excel and/or Access database(s) and any GIS files that were used to prepare the Remedial Investigation
and Feasibility Study (RI/FS) and Proposed Remediation Plan (Plan) for OU-4 to Messer) to assist in its
review and preparation of comments. On September 21, 2020, you responded that you were checking on
the requested information. On September 27, 2020, Mr. Sordi requested an update on your progressin
providing the requested information. To date, no response has been received and thus the requested
information has not been provided. As set forth in Messer's request for extension of time to provide
comments on the Plan, the information is critical to Messer's timely review of the RI/FS and Plan for the
Cinnaminson OU-4. Please therefore provide this information as soon as possible.
Messer has also submitted a FOIA request to the New Jersey Department of Environmental Protection
(NJDEP) for data related to the Detrex site that was referenced in the RI/FS and Plan. EPA therefore has
the Detrex site data and other information in its possession. Due to COVID restrictions, Messer has been
unable to access that information. Messer requests that you provide us with whatever data EPA has
available and relied upon in preparing the Plan from the NJDEP files for the Detrex site and also your
assistance in contacting the NJDEP to expedite their granting Messer access to obtain the Detrex data.
This information is critical to Messer's timely review and commenting of the RI/FS and Plan.
Messer LLC.
200 Somerset Corporate Blvd, Suite 7000, Bridgewater, NJ 08807
Phone 1-800-755-9277, www.messer-us.com
Page | 1
-------
M ESSER{I)
Gas< Life
Thank you for your assistance. If you have any questions, please feel free to contact me at (848)702-8769
or at philipp.sieber@messer-us.com.
Philipp Sieber
Director of En vironmental Management
Cc: J. Josephson, EPA (electronic only)
J. Brister, Messer (electronic only)
D. Sardi , BSI (electronic only)
T. Hundt, Atlantic (electronic only)
M. Hert z, EA (electronic only)
A. M arc urn, EA (electronic only)
J. Drummond, EA (electronic only)
Messer LLC.
200 Somerset Corporate Blvel, Suite 7000, Bridgewater, NJ 08807
Phone 1-800-766-9277, www.messer-us.com Page I 2
Sincerely,
-------
From: Philipp Sieber
To: Josephson, Jeff
Cc: David.Sordi@bsigroup.com; Karas, Alida
Subject: RE: Extension Request
Date: Thursday, October 15, 2020 2:24:00 PM
Attachments: imageOOl.png
Thank you very much Mr. Josephson. Much appreciated.
Sincerely,
Philipp Sieber
Director of Environmental Management
Messer Americas
200 Somerset Corporate Blvd., Suite 7000
Bridgewater, NJ 08807, USA
Office: +1 (908) 508-3143
Mobile: +1 (848) 702-8769
Philipp.sieber@messer-us.com
http://www.messer-us.com
Please note my new Messer email address.
As a member of the wider society, we are committed to protecting the environment. Please consider if you need to print.
From: Josephson, Jeff
Sent: Thursday, October 15, 2020 2:22 PM
To: Philipp Sieber
Cc: David.Sordi@bsigroup.com; Karas, Alida
Subject: Extension Request
CAUTION: The identity of the sender of this message could not be verified as it originates from the Internet. Please
pay attention!
Mr. Sieber,
As a courtesy I wanted to let you know that based on public input including Messer, EPA is in the
process of approval to provide a 30-day extension to the public comment period for the
Cinnaminson OU 4 public comment period. Therefore, the public comment period will run until
November 16, 2020. In addition, EPA will place an EXCEL file with all the data contained in the OU4
RI/FS into the administrative record file which can be accessed on line. That file should be available
tomorrow, October 16, 2020. EPA will address comments raised in the October 6,2020 Messer
request for extension of the public comment period in the responsiveness summary along with any
other comments from Messer and other members of the public received during the public comment
period.
Thank You,
Jeff Josephson, Chief
New Jersey Projects State Coordination Section
(212) 637-4404
The information contained in this email and any attachments may be confidential and is
provided solely for the use of the intended recipient(s). If you are not the intended recipient,
you are hereby notified that any disclosure, distribution, or use of this e-mail, its attachments
or any information contained therein is unauthorized and prohibited. If you have received this
in error, please contact the sender immediately and delete this e-mail and any attachments. No
responsibility is accepted for any virus or defect that might arise from opening this e-mail or
attachments, whether or not it has been checked by anti-virus software...
-------
From: David Sordi
To: Karas, Alida
Cc: Richard Lingg; Hertz, Michael; Marcum, Anna-Lisa; Drummond, Jesse; Philipp Sieber
Subject: Cinnaminson OU-4 Information Request
Date: Tuesday, November 3, 2020 10:24:06 AM
Attachments: imageOOl.png
image002.png
image004.png
RE Cinnaminson Follow-up - documentsdata.msg
Cinnaminson Data Request Letter - 100620.pdf
Dear Alida,
Messer has been able to obtain the Excel files for Cinnaminson Operable Unit 4 (OU4) that EPA
uploaded to the OU4 website, however some information Messer requested in my e-mail to you
dated September 18, 2020 (see attached) and Mr. Philipp Sieber's letter to you dated October 6,
2020 (see attached) has still not been uploaded to the website or forwarded to Messer.
In particular, the following are critical to Messer's review of the OU4 Remedial Investigation (Rl),
Feasibility Study (FS) and Proposed Remediation Plan:
• Any GIS files that were used to prepare the RI/FS and Proposed Remediation Plan;
• The LATA 2015 investigation referenced in the OU-4 Rl report. Specifically, this report is
listed in the OU4 Rl, Section 9 and is referenced as LATA, 2015, Data Evaluation Report
for the Cinnaminson Groundwater Contamination Site OU-4, Cinnaminson, New Jersey.
United States Environmental Protection Agency; EPA Work Assignment Number: 005-
RICO-02F7, EPA Contract Number: EP-W-10-007. Part of the report was included in the
OU4 Rl Appendix C, but the report's appendices were not fully included. Specifically, the
boring logs from completed locations are needed to evaluate the significance of the data
gaps resultant from their collection of only one groundwater sample interval per
hydropunch location and to evaluate the correlatability of the hydrostratigraphic units of
the PRM aquifer.
• The Roux Site Remedial Investigation Work Plan,2018/2019, Trex Properties, 835
Industrial Hwy, Unit 1, Cinnaminson, Burlington County, New Jersey was not included in
the OU4 Rl Appendix A or listed in Section 9 - References, but a figure from it (Figure 2 -
Nov. 2018 Groundwater Analytical Results) was presented as Figure 1-9. It should be
noted that the actual name of the report is uncertain because Figure 1-9 incorrectly
attributes the source of the content to a report that was included in Appendix A: Langan,
2012, Site Investigation/Remedial Investigation Report/Remedial Investigation Workplan,
Detrex Corporation, Cinnaminson, Burlington County, New Jersey.
Thank you for your prompt attention to this request.
Dave Sordi, PE
Senior Project Manager
T: +603 941 0132
PO Box 389, Center Conway, NH 03813
bsigroup.com | Linkedln
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-------
From: Karas, Alida
To: David Sordi
Cc: Josephson, Jeff; Raut, Leena; Mellott, Deborah; Richard Lingg; Hertz, Michael; Marcum, Anna-Lisa;
Drummond,
Jesse; Philipp Sieber
Subject: Cinnaminson OU4 Information Request
Date: Thursday, November 12, 2020 6:48:00 PM
Dave:
I am writing in response to your email message of November 3, 2020. In this email, you indicated
that you had obtained the Excel file that we added into the Administrative Record in response to
your request. You also identified additional information that Messer LLC is seeking relating to GIS
files and soil boring logs. Regarding your request for GIS file, the Excel file contains the
latitude/longitude and sampling data that Messer LLC can use to create GIS files itself. Regarding the
soil borings, EPA does not have the logs for the soil borings referenced in the OU4 RI Report. EPA
did not rely on the logs in preparation of the Proposed Plan. The chemical contaminant data
collected from the soil borings is included in the OU4 RI Report and in the Excel file. Lastly, thank
you for noting that a figure in the report is mislabeled.
Please let me know if you have any further questions.
Alida Karas
-------
o
Gases for Life
November 16, 2020
BY E-MAIL AND EXPRESS MAIL
Alida Karas (karas.alida@epa.gov)
Remedial Project Manager
United States Environmental Protection Agency
Region 2
NJ Remediation Branch
290 Broadway
New York, NY 10007
RE: Operable Unit 4 of the Cinnaminson Groundwater Contamination Superfund Site
Messer LLC's Comments on Proposed Remediation Plan
Dear Ms. Karas:
This letter provides Messer LLC's (Messer's) technical comments on the September 17, 2020
Proposed Plan identifying the preferred remedial alternative of the US Environmental Protection
Agency ("EPA") for Operable Unit 4 ("OU4") of the Cinnaminson Groundwater Contamination
Superfund Site. As Messer explains below, the remedial investigation/feasibility study ("RI/FS")
that provides the basis for the Proposed Plan contains unsupported conclusions and material
data gaps. Until these conclusions are examined critically and the data gaps are closed, it would
be premature for EPA to select a remedial alternative and issue an OU4 Record of Decision
("ROD").
Executive Summary
Before determining or documenting a remedy, EPA should consider and address the following
material errors and data gaps in the RI/FS:
• EPA compares 20-year old data with data generated in the last three years to
characterize the chemical signature of the groundwater. But available
contemporaneous data shows lower CVOC concentrations at OU3 (upgradient) and
higher concentrations downgradient at monitoring well SL-4D, undermining EPA's
conclusion of OU3 as an upgradient source of the high CVOC concentrations detected
in OU4.
• EPA disregards its own guidance regarding the presence of Dense Non-Aqueous
Phase Liquid ("DNAPL"), as well as clear evidence from prior investigations that DNAPL
is present at the Detrex property. EPA thus fails to identify Detrex as the largest and
most likely source of contamination to OU4. EPA should require Detrex to address the
DNAPL to prevent the spread of contamination downgradient.
Messer LLC
200 Somerset Corporate Blvd, Suite 7000, Bridgewater, New Jersey 08807
Phone 1-800-755 9277 | www.messer-us.com
-------
Alida Karas
November 16, 2020
Page 2
• EPA suggests that OU3 might be a source of DNAPL. Yet the available data and EPA's
own guidance conclusively establish that no DNAPL is present at OU3, making it an
unlikely source for the two-mile-long plume at OU4.
• EPA concludes that CVOC concentrations in groundwater at SL-4D are from OU3. But
a monitoring well installed upgradient of SL-4D reported CVOC concentrations of
approximately 10 ug/L, while the total CVOC concentrations at downgradient SL-4D are
over 422 ug/L. This points to a contamination source other than OU3.
• EPA's shallow contour map for OU4 is inaccurate, ignoring the existing Detrex
groundwater contour maps (included as an appendix to the OU4 Rl report) that show a
northeast groundwater flow direction in the shallow and intermediate portion of the
aquifer. This shows that impacts to SL-4D (as well as the area further downgradient)
are likely from Detrex.
• EPA's OU4 Rl geologic cross-sections contain no concentration isocontouring or
hydrogeologic unit interpretation, leading to an oversimplified representation of the
subsurface. Thus, the remediation evaluated in the RI/FS may miss the portions of the
plume requiring treatment and prevent a groundwater remedy that effectively targets
and treats the contamination.
• EPA collected insufficient groundwater samples (horizontally or vertically) to delineate
groundwater impacts and identify source areas in the area north of SL-4D, east of
Detrex, and south of OU3 to support the conclusions depicted in the OU4 Rl Figure 4-6.
• The chemical signature of upgradient SL-4D is not similar to downgradient monitoring
wells OU4 MW-7S/I/D, undermining EPA's conclusion that OU3 is a source of the high
CVOC concentrations detected in the two-mile-long plume.
• PCE concentrations are at higher concentrations in samples from SL-4D versus
concentrations in upgradient OU3 wells. Again, this suggests another source of CVOC
contamination impacting both SL-4D and the area further downgradient of that well.
• None of the modeling allegedly performed by EPA is included in the RI/FS. Absent full
groundwater modeling, there is nothing in the OU4 Rl or FS to support remediation
effectiveness, remediation timeframe and cost analyses.
• The EPA OU4 FS rejects in-situ enhanced reductive dechlorination or passive/reactive
treatment technologies, even though the "pump and treat" alternatives also require
trenching and plumbing.
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Alida Karas
November 16, 2020
Page 3
Messer's Technical Comments
9. Comparing 20-year old data from an unidentified sampling location at OU3 to
samples collected from OU4 in the past three years does not support accurate and
reliable scientific conclusions. EPA should develop and compare a chemical
signature analysis with contemporaneous data from OU3 and OU4 before
selecting and documenting a remedial alternative in a ROD.
EPA states in the OU4 Rl that "[t]he groundwater results outlined in the 1999 [OU3] Rl
can be used to characterize the chemical signature of the groundwater contamination in
OU3." and that "groundwater in this area contains TCE and cis-1,2-DCE which is
consistent with potential sources of TCE in OU3 as defined by groundwater samples
collected from B-14'1 EPA also claims that "Groundwater results outlined in the
Remedial Investigation Report BOC Gases submitted to the NJDEP in April 1999 and
discussed in Section 1.4 of this OU4 Rl (Figure 1-4) can be used to characterize the
chemical signature of the groundwater contamination in OU3."2
First, there is no sampling location B-14 related to the Former BOC Property (OU3).
Second, Figure 1-4 shows groundwater contours at OU3 and does not show sampling
results from which chemical signatures can be deduced. Third, there is no data analysis
provided by the OU4 Rl report to characterize the chemical signature of the groundwater
contamination in OU3. Fourth, detections of TCE and cis-1,2-DCE in OU4 is not
evidence that OU3 is the source of these compounds. In this regard, there are several
known sources of TCE in groundwater at the Cinnaminson Groundwater Contamination
Site including the former Hoeganaes Landfill, Detrex, former SLI Landfills, and OU3.
Technical comments below will provide evidence that Detrex is a more likely source of
TCE, PCE, and breakdown products cis-1,2-DCE and VC that has impacted OU4
groundwater.
Regardless, the use of a Geoprobe® groundwater samples from 1999 is not
representative of current groundwater conditions at OU3, and thus cannot be compared
to OU4 data collected in the past three years to assess chemical signatures. TCE
concentrations will change significantly over twenty years and assuming a typical TCE
half-life of 8-10 years, the TCE concentrations at 'B-14' would be 75% lower now than in
1999. Given the relative proximity of SL-4D to OU3 (less than 500 ft), for the purpose of
comparing TCE and cis-1,2-DCE concentrations, EPA should use contemporaneous
data sets and should not rely on data sets created almost 20 years apart. As discussed
below, TCE and cis-1,2-DCE concentrations at OU3 wells (and additional OU3
delineation well BOCMW-14) are lower than concentrations at OU4 downgradient SL-
4D, indicating there is another source of TCE and cis-1,2-DCE to SL-4D.
1 Final Remedial Investigation Report, Cinnaminson Groundwater Contamination Site - Operable Unit 4, Page 10,
Section 1.4.2.
2 Id., Page 66, Section 6.3.3.
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Alida Karas
November 16, 2020
Page 4
10. DNAPL at Detrex is likely the largest source of groundwater contamination to OU4
and must be addressed before implementing a "pump and treat" system to
contain the spread of contamination downgradient.
EPA states in the OU4 Rl that "[tjhere is insufficient information to determine if DNAPL
potentially exists at Detrex3." This statement is not supported by existing data and EPA
guidance. Figure 1-8 presents the 2011 Groundwater Exceedances for the Detrex site.
MW-5 was reported with 81,800 ug/L of TCE, 19,200 ug/L of 1,1,1-TCA, and 699 ug/L of
PCE. Per EPA guidance document 542-R-04-106 (DNAPL Remediation: Selected
Projects Approaching Regulatory Closure), "...it is difficult to verify the presence of
DNAPLs through direct observation. Generally, its presence is indirectly estimated. One
approach is based on ground water concentration data and the '1 percent of solubility'
rule-of-thumb (EPA 1992). Under this approach, DNAPL is suspected to be present
when the concentration of a chemical in ground water is greater than 1 percent of its
pure-phase solubility". Per Appendix B of this EPA document, 1% of aqueous solubility
for TCE is 14,720 ug/L, for 1,1,1-TCA is 13,340 ug/L and for PCE is 2,000 ug/L.
Therefore, based on EPA's guidance and the available data, DNAPL is likely present at
Detrex for both TCE and 1,1,1-TCA. In addition, the 2012 Remedial Action Report
(Appendix A in the OU4 Rl) noted DNAPL at the Detrex site based on the 1% solubility
rule as well as positive hydrophobic dye tests conducted on soil samples collected at the
site. These concentrations and documented findings indicate that Detrex is the largest
source of TCE, 1,1,1-TCA and PCE (due to DNAPL) to groundwater in OU4. The effects
on DNAPL and the increased downgradient dissolved phase CVOC concentrations from
a groundwater "pump and treat" system were not considered in the FS. Therefore,
before implementing a downgradient "pump and treat" system, the DNAPL at Detrex
should be further investigated and addressed.
11. DNAPL is not present at OU3, making it an unlikely source for the two-mile-long
plume at OU4.
The OU4 Rl also states that "[d]ata collected at OU3 shows there may potentially be or
may have been a pool of DNAPL at OU3 (Atlantic, 2005)" and "[t]he distribution of the
CVOCs show DNAPL is potentially present on top of the bedrock saprolite or diffused
into the saprolite diffusing or back-diffusing CVOCs to groundwater."4 This statement is
not supported by existing data and EPA guidance. Rather, groundwater monitoring data
and additional site characterization data generated since 2005 (which was provided to
EPA in the 2020 OU3 Site Characterization Summary Report ("SCSR")) indicate no
DNAPL is present at OU3. While initial investigations performed in 2005 suggested the
potential for DNAPL (based on elevated TCE in turbid and limited direct-push
groundwater samples), monitoring wells installed to delineate TCE impacts have
confirmed concentrations are below 1 percent solubility for TCE (14,720 ug/L). In
addition, the concentrations reported for TCE in monitoring wells from 1991 through
3 Id., Page 63, Section 6.2.9.
4 Id., Page 63, Section 6.2.9, first sentence and Section 6.3.3, second paragraph.
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Alida Karas
November 16, 2020
Page 5
2015 across OU3 have been well below the 1 percent solubility rule (aside from an
anomalous concentration reported at AFGMW-10 on 10/23/97 and not confirmed by
follow-up sampling on 11/6/97). Thus, DNAPL is not present at OU3 for TCE, PCE, or
1,1,1-TCA and therefore it does not support OU3 as the source of the high CVOC
concentrations detected in the two-mile-long plume at OU4.
12. The CVOC concentrations in monitoring well BOCMW-14 do not support OU3 as a
source of the high CVOC concentrations observed in SL-4D, Further investigation
is needed to identify other sources of CVOCs to SL-4D.
The OU4 Rl suggests that CVOC concentrations in groundwater at SL-4D are from
OU3.5 This statement is not supported by existing data. SL-4D cannot be used to assess
OU3 chemical signature as it is located outside the Former BOC Property boundary
(Figure 1-2 of the OU4 Rl report). BOCMW-14 was installed upgradient of SL-4D to
assess whether there might be a connection between OU3 impacts and SL-4D. The total
CVOC concentrations reported in BOC-MW14 were approximately 10 ug/L while the SL-
4D total CVOC concentration is over 422 ug/L. This indicates that SL-4D has been
affected by other sources of CVOCs. As shown in Exhibit 1 (Figure 4.3-6 in the 2020
OU3 SCSR), there is a significant increase in CVOC concentrations between the lower
concentrations detected at the onsite OU3 monitoring wells (PZ-4A, SIP-2D and PZ-A5)
and the higher concentrations detected at downgradient SL-4D. BOCMW-14 confirms
the break in the lower CVOC concentrations at OU3 to the higher CVOC concentrations
at SL-4D. Additional investigation is needed to locate the source of CVOCs to SL-4D.
Exhibit 1 - Locations of SL-4D, OU-3 and BOCMW-14
Green Line -
OU3 Boundary
BOCV1W-14 ..
OU3 onsite wells PZ-
4A, SIP-2D and PZ-A5
Atlantic
Environmental Consulting Sen-ices. LLC.
20152016 TCE Isopteft Map (Abow Saprolitei
5 Id., Page 67, Section 6.3.5, second paragraph.
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Alida Karas
November 16, 2020
Page 6
13. The OU4 shallow contour map is not consistent with other groundwater contour
maps from the Detrex site that show shallow groundwater flow northeast toward
SL-4D. Additional data analyses are necessary to provide comprehensive
groundwater flow contour maps.
The OU4 Rl's shallow potentiometric surface map6 relied solely on existing OU4
monitoring wells for the groundwater contour maps to depict the shallow and deep
aquifers of the P-R-M, which only show a southerly groundwater flow direction south of
OU3 in the shallow and deep portions of the aquifer. In developing the OU4 Rl, the EPA
did not consider the existing Detrex groundwater contour maps for the shallow and
intermediate portions of the P-R-M aquifer that show a northeast groundwater flow
direction. For the OU4 Rl groundwater contour maps to be complete, the shallower
groundwater contours as provided in the 2012 Langan report for the Detrex site
(included as Appendix A in the OU4 Rl) would need to be added. The area to be
included is shown in Exhibit 2 Due to the known semi-confining units in the P-R-M
aquifer, there are varying groundwater flow directions in the intermediate and deeper
portions (separated by semi-confining units) of the aquifer. Exhibits 3 and 4 depict the
groundwater direction in the intermediate (northeast and not south) and the deeper
(south consistent with Figure 3-5 of the OU4 Rl) portions of the P-R-M at the Detrex
facility. This defined groundwater flow direction near OU3 and Detrex indicating that
impacts to SL-4D and further downgradient are likely from Detrex. Additional data
analysis is required to produce comprehensive groundwater flow maps.
Exhibit 2 - Area of OU4 to Include Shallow Groundwater Contours from Detrex Reports
POTENTIOMETRIC SURFACE OF SHALLOW POTOMAC-RARITAN-MAGOTHY AQUIFER - MAY 2017
K)3 SEPA P.MMW CINNAMINSON GROUDNWATER CONTAMINATION SITE OU4
AaM:y BURLINGTON COUMTY. NEW JERSEY
flSUWW
Area where groundwater
flow direction needs to be
updated in the shallow
aquifer to east-northeast
versus due south
0 Id., Figure 3-5 (Potentiometric Surface Map of Shallow P-R-M Aquifer).
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Alida Karas
November 16, 2020
Page 7
Exhibit 3 - Intermediate Depth Groundwater P-R-M Contours from Detrex (Figure 19b)
Red Arrow is interpreted
groundwater flow direction
from the groundwater
contour map (Northeast)
INSET MAP
SCALE IN FEET
Exhibit 4 - Deep Groundwater P-R-M Contours from Detrex (Figure 19b)
Red Arrow is interpreted
groundwater flow direction
from the groundwater
contour map (South)
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14. The OU4 Rl geologic cross-sections are not sufficiently detailed to fully
understand the nature and extent of contamination in a complicated
hydrogeologic setting, which interferes with identifying cost-effective
groundwater remedies in the OU4 FS. Detailed geologic cross sections in the OU4
Rl are needed to address any data gaps identified.
The EPA geologic cross-section figures 4-7, 4-8 and 4-9 of the OU4 Rl do not provide
the identified nature and extent of CVOC contamination in the P-R-M aquifer relative to
the sub-aquifer units. No concentration isocontouring or hydrogeologic unit interpretation
is provided. See Exhibit 5 below:
Exhibit 5 - Reprentative OU4 Cross-Section of P-R-M
B
qwmw-«s
OU* MW-?1
OW UM-TO
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HOD t»0 70W 7301 MOS
4SM mm tio: mm ibod twii ?5M iodj
Distance Along Transect
»4dd p:qp bwo ^ocj (
~ GILUiidMltn rw^lt i »«1(l JSji
— — — i3rpjw»«3l*f Sulfate
GrouM*aur Ekm\t amai
-Ground SMfftcp
Qua»n»r»
LI - £or*llijW» fi« 9HUM 3Ctr*i 3W iJiicYSUi ji it
J • €ssma3«f t mc tmtim
E
K>3 flBftS5-
DISTRIBUTION OF VOCS IN HYDROGEOLOGIC CROSS-SECTION B-B"
CINNAMWSOk GROUNDWATER CONTAW NATION BITE OU*
BUfc-»GTC* COCMTV, MIM JCHJC-
f mTJNfe 4-B
As is discussed further below, a review of the P-R-M aquifer cross-sections developed at
other contamination sites demonstrates that there is preferential contaminant flow in
more permeable portions of the aquifer and vertical migration of contaminants when
semi-confining units are absent. The absence of hydrogeologic and contaminant
interpretation in EPA's cross-sections provides an oversimplified representation of the
subsurface which does not allow for a full analysis of contaminant location and transport.
This in turn has led EPA to develop and propose remedies in the FS that can miss
optimal contamination capture and may result in a remedy that is neither cost-effective
nor remediates the bulk of the contaminant mass.
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There are two excellent examples available to EPA of cross-sections of the P-R-M
aquifer with the technical details described above: the 2012 Langan report for the Detrex
site (included in the OU4 Rl Appendix) and the remedial investigation report for the
nearby Puchack Wellfield Superfund Site.
The 2012 Langan report correlated the various more permeable aquifer units with semi-
confining units above and below the more permeable aquifers (Exhibit 6) in the P-R-M.
The figure shows the plumes migrating within each of the aquifer subunits with
differential velocities (and potentially different flow directions) due to geologic layering.
The 2012 Langan cross-section figure below demonstrates that contamination is most
extensive in the middle aquifer portion of the P-R-M and not at the base (near the
bedrock) due to localized semi-confining units. This could mean that contamination (and
preferential flow paths) could be missed if the full vertical section from the water table to
the saprolite (i.e. weathered bedrock) is not fully characterized. Therefore, the
remediation planned in the OU4 FS could be missing portions of the plume requiring
treatment, thereby incorrectly selecting "pump and treat" as the remedy and
underestimating the costs and timeframe required for remediation. Conversely, better
delineation is more likely to lead to a refined groundwater treatment remedy that
effectively treats the contamination, especially when considering that 90% of the
contamination flows through 10% of the aquifer system.
Exhibit 6 - Detailed Hydrogeologic Cross-Section of P-R-M with Concentration
Contours
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The Puchack Wellfield Superfund Site, located about five miles southwest, similarly
addresses groundwater contamination within the P-R-M aquifers and has taken
extensive efforts to correlate the aquifer units in order to ensure an effective and efficient
remedy. An example of the hydrogeologic understanding for remedial action
planning/implementation at that site is in Exhibit 7.
Exhibit 7 - Detailed Hydrogeologic Cross-Section of P-R-M from Puchack Wellfield
Superfund Site
EXPLANATION
+• Wail location shewn in
hydtatratrgraphic section
6dd numbor hdicates chromium conwilrSiinr
Breeding New Jersey maximum contairtnarrt lew)
of 100 microgram! per liter (1999 - 3001 data].
Number in parenthesis is pctantiomtstic head,
in fast Datum is sea level.
Puchack
> Pctentkmetri: contour - Shows altrtude at whkh water
ivDuld have stood in tightly ca»d wails, JD01 Contour
interval 1 foot. Datum ss s« level
Arrows show oaosra! droctcn of groundwater flaw
Hydrostratigrapfiyaf the PotDrnoc-Rarrtan-Magothy aquifer system
in the Peonsauken Township and vicinity
layer Unit
A-1 Upper aquifer
C-l Uppsr/Midda confining uri
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and the source(s) of the contamination. For all the reasons discussed, refined
hydrogeologic cross-sections are most important in the area south of Union Landing
Road to the south of OU3 and to the east of Detrex. EPA should provide detailed
geologic cross sections in the OU4 Rl. These refined hydrogeologic cross-sections will
allow for a full understanding of the location of the impacts and geologic pathways of the
contaminant transport, which will lead to a targeted and more cost-effective remediation.
15. Horizontal and vertical groundwater samples are insufficient to delineate
groundwater impacts and identify source areas in the areas north of SL-4D, east
of Detrex, and south of OU3 and, further, do not support EPA's conclusions in
OU4 Rl Figure 4-6. The OU4 Rl is missing detailed geologic cross sections.
EPA's Figure 4-6 (Distribution of Total Ethenes/Ethane) depicts OU3 as the primary
source of CVOC impacts to SL-4D (Exhibit 8). As explained in previous comments, SL-
4D has likely been affected by other sources of CVOCs and groundwater flow direction
in the P-R-M shallow and intermediate zones is northeast from Detrex toward SL-4D.
EPA's Figure 4-6 shows a disconnect between the CVOC source at Detrex and SL-4D.
Figure 4-6 appears to consider the 2014 l_ATA hydropunch sample locations to delineate
the horizontal extent of the impacts in this area. Groundwater was only sampled from
one interval aquifer per each 2014 LATA sampling location, however, and vertical
impacts were not delineated. EPA's interpretation of groundwater impacts and the
separation of contamination between the Detrex and OU3 sites may be due to LATA
hydropunch sampling location 547. The depth of SL-4D is 120-125 ft below ground
surface while hydropunch sampling location 547 is 61 ft below ground surface.
Therefore, the 60 ft of aquifer below this groundwater sampling point where
contamination could be flowing towards SL-4D were not characterized. As a result, there
cannot be solid line demarcation contours on Figure 4-6 near SL-4D. EPA should
provide detailed geologic cross sections in the OU4 Rl.
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Exhibit 8 - Additional Analysis Considerations for Figure 4-6 from OU4 Rl Report
16. The chemical signature of upgradient SL-4D is different from downgradient OU4
MW-7S/I/D and do not support the conclusion that OU3 is a source of a two-mile-
long plume.
The OU4 Rl concludes that, "Groundwater samples collected at OU4 MW-7S/I/D show a
similar chemical signature as the CVOCs in groundwater at OU3 (SL-4D)."7 This
statement is not supported by existing data. The chemical signature for SL-4D (at the
head end of OU4) and OU4 MW-7S/I/D (located downgradient) are not similar. The
sample from SL-4D contains approximately 50% TCE and 50% cis-1,2-DCE. By
contrast, samples from downgradient OU4-MW-7/S/I contain about 62% TCE and 30%
cis-1,2-DCE. SL-4D has less TCE as a percentage than MW-7S/I/D. EPA has
acknowledged that dilution and dispersion (and potential biodegradation) of TCE from a
source would cause TCE concentrations to decrease as the plume migrates
downgradient8. Therefore, TCE concentrations would not increase as groundwater
travels downgradient, contradicting the conclusion that OU3 is a source of an
approximately two-mile-long plume. The increasing TCE concentrations are more likely
due to another TCE source that is not associated with SL-4D or OU3. In addition, no
groundwater modeling or other data that provides a definitive link between OU-3 and the
7 Id., Executive Summary (Page 2) and Section 6.3.5, second paragraph (Page 67).
8 Id., Section 5.2 (Pages 50 - 60)
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down gradient areas from SL-4D have been provided. If this information has been
developed it should be presented in the OU4 RI/FS. No firm conclusions can be drawn
until additional lines of evidence are developed including 1) more detailed hydrogeologic
analysis of the area south of Union Landing Road and north of SL-4D and 2) additional
chemical signature analysis such as compound specific isotope analysis to fingerprint
the sources and the downgradient portion of the OU4 in this area (SL-4D to OU4MW-
7S/I/D).
17. PCE concentrations are higher in samples from SL-4D versus upgradient OU3
wells, strongly suggesting the existence of another source of CVOC
contamination impacting SL-4D and the area further downgradient.
OU4 Rl concludes that "groundwater containing a unique CVOC chemical signature
associated with OU3 and potentially 1,4-dioxane migrates to the southeast creating a
roughly two-mile-long plume of contaminated groundwater."9 EPA contends that there is
a > 50 ug/L total CVOC plume originating from OU3. To support this contention, EPA
connects SL-4D and SL-7RP on Figure 4-6. But as is described above, there is a break
in the lower CVOC concentrations at OU3 to the higher CVOC concentrations at SL-4D.
To examine the possibility of another source of CVOCs to SL-4D, Messer reviewed the
PCE data from SL-4D. PCE has been reported at concentrations between 2 and 10 ug/L
since 1998 (4 ug/L in May 2017). The highest PCE concentration in monitoring wells on
the Former BOC Property in 2015 was 1.3 ug/L. Because SL-4D is downgradient of OU3
monitoring wells, it is improbable that downgradient concentrations of PCE at SL-4D
would be higher than OU3 PCE monitoring well concentrations if the flow paths in fact
connected OU3 to SL-4D. Additionally, the OU4 Rl states that reductive dechlorination in
the flow path between OU3 and SL-4D has reduced the CVOCs from PCE/TCE to
daughter products like 1,2 cis-DCE, and vinyl chloride. Reductive dechlorination would
further reduce PCE concentrations as the PCE travels downgradient. The OU4 Rl does
not explain how - if there is reductive dechlorination and attenuation - PCE can be in
OU3 source well locations at low concentrations and in SL-4D downgradient at higher
concentrations. Therefore, the conclusion that OU3 is the source of a two-mile-long
plume that reaches the Albany Road production wells is not supported. A more detailed
hydrogeologic analysis is required of the area south of Union Landing Road and north of
SL-4D, along with additional chemical signature analysis such as compound specific
isotope analysis.
18. Full groundwater modeling needs to be provided in the OU4 Rl or FS to support
remediation effectiveness, remediation timeframe, and cost analyses.
EPA states in the OU4 FS that "empirical groundwater flow and solute transport data
collected in the OU1 and OU4 studies/investigations were used in analytical models
(aquifer flushing and first-order decay) to estimate the period of performance of each
9 Id., Section 8, Third bullet (Page 71)
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remedial alternative."10 This modeling was not included in the OU4 Rl or FS. The
modeling results must be provided in the OU4 Rl or FS to determine the accuracy of the
remediation timeframe estimates, detail the expected lifespan of the full remediation for
each alternative, and to ensure full capture of the contamination without migration of
contamination into new areas in OU4. If there are excessive overall active remediation
timeframes, the remedial alternatives currently analyzed may not be the most cost-
effective. Limited modeling cannot result in the selection of remedial alternatives that are
efficient and effective, as required by CERCLA.
19. The OU4 FS should not eliminate in-situ enhanced reductive dechlorination or
passive/reactive treatment technologies, as these are proven, efficient and cost-
effective remedies.
The OU4 FS eliminates in-situ enhanced reductive dechlorination or passive/reactive
treatment technologies from further consideration in the remedial alternatives, and states
that "[t]he density of buildings, roads, and subsurface utilities within the footprint of the
groundwater plume would also make the implementation ofPRB impractical." However,
the "pump and treat" alternatives include approximately eight miles of trenching and
plumbing across the same residential neighborhoods with the same infrastructure
concerns. Eliminating these proven technologies from consideration as remedial
alternatives is premature and fails to ensure that any required remediation is conducted
in the most efficient and effective manner, as required by CERCLA
Messer's General Comments
In addition to the above Technical Comments, Messer submits the following General Comments
to inform EPA's approach to the OU4 Proposed Plan.
4. The Proposed Plan states that "[a] previous vapor intrusion study was also conducted in
2009 of a neighborhood to the south of the Messer property, located near the Detrex
Corporation (Detrex) property. There were no issues found with vapor intrusion in this
neighborhood, and thus no additional sampling events have been conducted in that
location." The Proposed Plan also states that "Groundwater contamination migrating
northwest will be addressed as part of OU3, while contamination migrating to the
southeast is included as part of the OU4 Proposed Plan."
a. The VI data and the risk assessment/conclusions for the neighborhood to the
south of the "Former BOC Property" should be included in the OU4 Rl and
summarized again in the Proposed Plan in the "Human Health Risk
Assessment" section for completeness.
10 Id., Section 8.1.2, 2nd paragraph (Page 8-2)
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