RECORD OF DECISION
Hercules, Inc. (Gibbstown Plant) Superfund Site
Operable Units One and Two
Gibbstown, Gloucester County, New Jersey
Former Hercules Plant, circa 1958
(Source: Feasibility Study, Former Hercules Higgins Plant, Gibbstown, New Jersey, CSI Environmental, LLC, July 2018)
United States Environmental Protection Agency
Region 2
New York, New York
September 2018
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Table of Contents
DECLARATION FOR THE RECORD OF DECISION i
SITE NAME, LOCATION, AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 3
SUMMARY OF SITE CHARACTERISTICS 4
Hydrogeology 4
Remedial Investigation 4
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 7
Land Use 7
Groundwater Use 7
SUMMARY OF SITE RISKS 8
Human Health Risk Assessment 8
Ecological Risk Assessment 14
Basis for Taking Action 15
REMEDIAL ACTION OBJECTIVES 15
DESCRIPTION OF REMEDIAL ALTERNATIVES 16
OU2 Soil Alternatives 18
OU2 Sediment Alternatives 21
OU1 Groundwater Alternatives 23
COMPARATIVE ANALYSIS OF ALTERNATIVES 24
Overall Protection of Human Health and the Environment 25
Compliance with ARARs 26
Long-Term Effectiveness and Permanence 27
Reduction in Toxicity, Mobility, or Volume Through Treatment 28
Short-Term Effectiveness 29
implementability 30
Cost 31
State Acceptance 31
Community Acceptance 31
PRINCIPAL THREAT WASTES 32
SELECTED REMEDY 32
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Summary of the Rationale for the Selected Remedy 32
Description of the Selected Remedy 33
Summary of the Estimated Selected Remedy Costs 37
Expected Outcomes of the Selected Remedy 37
STATUTORY DETERMINATIONS 37
Protection of Human Health and the Environment 38
Compliance with ARARs 38
Cost Effectiveness 38
Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to Maximum Extent Practicable 39
Preference for Treatment as a Principal Element 39
Five-Year Review Requirements 39
DOCUMENTATION OF SIGNIFICANT CHANGES 39
APPENDICES
APPENDIX I FIGURES
APPENDIX II TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV STATE OF NEW JERSEY CONCURRENCE LETTER
APPENDIX V RESPONSIVENESS SUMMARY
APPENDIX V-a: Proposed Plan
APPENDIX V-b: Public Notice - Commencement of Public Comment Period
APPENDIX V-c: Public Meeting Transcript
APPENDIX V-d: Written Comments Received During Public Comment Period
APPENDIX VI STATEMENT OF FINDINGS FLOODPLAINS AND WETLANDS
FIGURES
Figure 1: Site Location Map
Figure 2: Site Vicinity Map
Figure 3: Exposure Area Map
Figure 4: Areas Exceeding Rl Soil Screening Values
Figure 5: Areas Exceeding Rl Sediment Screening Value
Figure 6: Site Well Location Map
Figure 7: Conceptual Site Model
Figure 8: Soil and Sediment Remediation Areas
Figure 9: Conceptual Design of Selected Remedy Components
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TABLES
Table
1:
Table
2:
Table
3:
Table
4:
Table
5:
Table
6:
Table
7:
Table
8:
Table
9:
Table
10
Table
11
Table
12
Table
13
Table
14
Table
15
Table
16
Table
17
Table
18
Table
19
Table
20
Maximum Unsaturated Soil Concentrations
Maximum Saturated Soil Concentrations
Maximum Groundwater Concentrations
Summary of Chemicals of Concern
Selection of Exposure Pathways
Non-Cancer Toxicity Data Summary
Cancer Toxicity Data Summary
Risk Characterization Summary - Non-Carcinogens
Risk Characterization Summary - Carcinogens
Adult Lead Model
Remediation Goals for Saturated and Unsaturated Soil
Calculated and NJDEP Impact to Groundwater Soil Screening Levels
Remediation Goals for Groundwater
Cost Estimate for Soil Alternative S-3
Cost Estimate for Sediment Alternative SED-3
Cost Estimate for Groundwater Alternative GW-2
Engineered Soil Cover Cost Estimate for Alternatives S-3 and SED-3
Chemical-Specific ARARs, TBCs, and Other Guidelines
Action-Specific ARARs, TBCs, and Other Guidelines
Location-Specific ARARs, TBCs, and Other Guidelines
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Hercules, Inc. (Gibbstown Plant) Superfund Site
Gibbstown, Gloucester County, New Jersey
Superfund Site Identification Number: NJD002349058
Operable Unit(s): 01 and 02
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's
(EPA's) selection of a remedy for Operable Units one and two (OU1 and OU2) of the
Hercules, Inc. (Gibbstown Plant) Superfund Site (Site), in Gloucester County, New
Jersey, which was chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended, 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 OU1 and OU2 remedy. The attached index
(see Appendix III) 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 concurs with the
selected remedy (see Appendix IV).
SITE ASSESSMENT
Actual or threatened releases of hazardous substances from the Site, if not addressed by
the implementation of the response action selected in this ROD, may present an imminent
and substantial endangerment to public health and welfare and to the environment.
DESCRIPTION OF SELECTED REMEDY
The selected remedy addresses the contaminated groundwater in the Former Plant Area
of the Site (OU1) and the contaminated soil in the Former Plant Area, and the
contaminated sediment in Clonmell Creek and an on-Site storm water retention basin
referred to as the Stormwater Catchment Basin (OU2).
The major components of the selected remedy include:
excavation of lead-contaminated soil with off-Site disposal;
excavation of volatile organic compound (VOC)-contaminated soil located 0-4 feet
(ft.) below the ground surface (bgs) and on-Site treatment with ex-situ
bioremediation;
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in-situ treatment of VOC-contaminated soil situated below 4 ft. bgs with enhanced
biodegradation;
hydraulic dredging of contaminated sediment and on-Site treatment with
phytoremediation;
on-Site reuse of treated soil and sediment;
extraction of contaminated groundwater with on-Site treatment and discharge to
groundwater;
long-term groundwater monitoring; and
institutional controls (ICs) to restrict groundwater use, prevent soil disturbances in the
in-situ soil treatment areas, and require that future buildings on the Site either be
subject to a vapor intrusion evaluation or be built with vapor intrusion mitigation
systems until the remediation goals are met.
The soils in the Active Process Area, Chemical Landfill/Gravel Pit, Inactive Process Area,
Northern Chemical Landfill, Stormwater Catchment Basin and Tank Farm/Train Loading
Area exposure areas with contaminant of concern (COC) concentrations exceeding the
remediation goals will be excavated to a depth of 4 ft. bgs and treated with ex-situ
bioremediation. The soils situated below 4 ft. bgs in these exposure areas, with COC
concentrations exceeding the remediation goals, will be treated in-situ using enhanced
biodegradation.
Additional sampling will be conducted during the remedial design to confirm the complete
delineation of benzene, cumene and colocated COCs in the on-Site soils prior to
remediation and to verify that no COCs are present in off-Site soils above the NJDEP
residential direct contact soil remediation standards.
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. This will include consideration of green remediation technologies and practices.
The concentrations of benzene, cumene, and colocated COCs in the Site soils, either
adsorbed to soil particles or as non-aqueous phase liquid (NAPL), are an on-going source
of contamination to the groundwater and are considered to be principal threat wastes.
The selected remedy will address source materials constituting principal threats by
excavating and treating the VOC-contaminated soil from 0 to 4 ft. bgs and through in-situ
treatment of the VOC-contaminated soil situated below 4 ft. bgs, thereby satisfying the
preference for treatment.
DECLARATION OF STATUTORY DETERMINATION
The selected remedy meets the requirements for remedial actions set forth in Section 121
of CERCLA, 42 U.S.C. § 9621, because 1) it is protective of human health and the
environment; 2) it meets a level or standard of control of the hazardous substances,
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pollutants, and contaminants that at least attains the legally applicable or relevant and
appropriate requirements under federal and state laws unless a statutory waiver is
justified; 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, the selected remedy satisfies the Section 121 of CERCLA, 42 U.S.C. § 9621
preference for the use of treatment that permanently and significantly reduces the volume,
toxicity, or mobility of hazardous substances as a principal element.
Because the selected remedy will result in contaminants remaining above levels that
allow for unrestricted use and unlimited exposure, CERCLA requires that the Site be
reviewed at least once every five years.
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.
A discussion of the current nature and extent of contamination is included in the
"Summary of Site Characteristics" section.
The Site COCs and their respective concentrations are presented in the "Summary of
Site Characteristics" section.
A discussion of the potential adverse effects associated with exposure to Site COCs
is included in the "Summary of Site Risks" section.
The remediation goals for the Site COCs are presented in the "Remedial Action
Objectives" section and in Tables 11 through 13 of Appendix II.
A discussion of principle threat waste is included in the "Principal Threat Wastes"
section.
A discussion of the current and reasonably anticipated future land use assumptions is
included in the "Current and Potential Future Land and Resources Uses" section.
The estimated capital, operation and maintenance, and total present-worth costs are
presented in the "Description of Remedial Alternatives" section.
A discussion of the key factors that led to the selection of the remedy is included in
the "Comparative Analysis of Alternatives" and "Statutory Determinations" sections.
AUTHORIZING SIGNATURE
v i7 (. \ 9 Zo -ZB
Angela Carpenter, Acting Director Date
Emergency and Remedial Response Division
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site
Site name:
Site location:
HRS score:
Listed on the NPL:
Record of Decision
Date signed:
Selected remedy:
Capital cost:
Annual operation,
and maintenance cost:
Present-worth cost:
Lead
Hercules, Inc. (Gibbstown Plant) Site
Gibbstown, Gloucester County, New Jersey
40.36
September8, 1983
September 25, 2018
Excavation of lead-contaminated soil with off-Site disposal;
excavation of VOC-contaminated soil located 0-4 feet (ft.)
below the ground surface (bgs) and treatment with ex-situ
bioremediation followed by on-Site reuse; enhanced in-situ
biodegradation of VOC-contaminated soil situated below 4 ft.
bgs; hydraulic dredging of contaminated sediments with on-
Site phytoremediation and reuse; extraction of contaminated
groundwater with on-Site treatment and long-term monitoring;
and institutional controls
$7.5 million
$475,000
$11.3 million
EPA
Primary Contact:
Secondary Contact:
Main PRP
Patricia Pierre, Remedial Project Manager, (212) 637-3865
Joel Singerman, Chief, Central New York Remediation
Section, (212)637-4258
Hercules LLC
Waste
Waste type:
Waste origin:
Contaminated media:
Volatile organic compounds and lead
On-site waste disposal activities
Soil, sediment and groundwater
IV
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DECISION SUMMARY
Hercules, Inc. (Gibbstown Plant) Superfund Site
Operable Units One and Two
Gibbstown, Gloucester County, New Jersey
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SITE NAME, LOCATION, AND DESCRIPTION
The Hercules, Inc. (Gibbstown Plant) Superfund Site (Site), a former chemical
manufacturing facility, is situated on approximately 350 acres located off South Market
Street in Gibbstown, Gloucester County, New Jersey (See Figure 1 of Appendix I). The
Site is bounded to the east by Paulsboro Refining Company, LLC, to the west by open
land owned by E.I. du Pont de Nemours and Company (DuPont), to the north by the
Delaware River, and to the south and southwest by residences. Area homes are served
by municipal water supply wells. The selected remedy described herein addresses two
portions, or operable units, of the Site. Operable unit one (OU1) addresses the
contaminated groundwater in the Former Plant Area. OU2 addresses the contaminated
soil in the Former Plant Area and contaminated sediment in Clonmell Creek and the
Stormwater Catchment Basin.
Clonmell Creek flows northwest through the Site property toward the Delaware River. On
the Site property, the creek ranges from 75 to 120 feet (ft.) wide and 0.25 to 3 ft. deep
and separates the two primary areas of the Site the Solid Waste Disposal Area (SWDA)
located to the north and the Former Plant Area located to the south.
The SWDA is situated approximately 2,000 ft. north of Clonmell Creek and covers nearly
five acres. It is surrounded by wetlands and sits adjacent to the Delaware River. The
SWDA and adjacent wetlands have already been addressed as Operable Unit 3 (OU3)
of the Site
The Former Plant Area, the manufacturing portion of the facility during its operational
period, occupies approximately 80 acres. An unlined stormwater retention pond, referred
to as the "Stormwater Catchment Basin," is located within the Former Plant Area, about
600 ft. south of Clonmell Creek. The Stormwater Catchment Basin ranges in width from
approximately 64 ft. on its south end to 125 ft. on the north, and 0.25 to 3 ft. deep,
dependent upon precipitation levels. Historically, storm water collected in the area now
known as the "Stormwater Catchment Basin" and flowed through the 002 outfall, which
was a New Jersey Department of Environmental Protection (NJDEP)-permitted discharge
point, into an adjacent drainageway before discharging into Clonmell Creek (See Figure
2 of Appendix I). There has been no hydraulic connection between the Stormwater
Catchment Basin and Clonmell Creek since 1991.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Before the property was transferred to Hercules Incorporated (Hercules) in 1952, DuPont
reportedly used the area now designated as the SWDA and surrounding areas to dispose
of lead fragments and tar generated from the production of aniline. In 1952, Hercules
acquired title to the Site property from DuPont. Construction of the manufacturing plant
began in 1953 and the plant was fully operational by 1959. Phenol and acetone were
manufactured at the facility until 1970. After 1970, the plant produced three primary
productscumene hydroperoxide, diisopropylbenzene, and dicumyl peroxide, which are
compounds used in phenol and acetone production. Hercules used the SWDA from 1955
until 1974 to dispose of wastes generated from its manufacturing activities. In 2008,
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Ashland, LLC (Ashland), then known as Ashland, Inc., acquired Hercules, with Hercules
continuing to exist as a subsidiary of Ashland.
In 2010, Hercules decommissioned the plant and all the aboveground structures were
demolished, except for a groundwater treatment system, a former administration building,
and two surface impoundments. Significant subsurface sewer lines, process piping, and
utilities associated with the former manufacturing facility remain in portions of the Active
Process Area and Inactive Process Area. These structures were abandoned in place and
filled with concrete.
In 1981, the U.S. Geological Survey released a report documenting the detection of
benzene in a Site production well. Based upon this finding, Hercules, under NJDEP
oversight, conducted additional groundwater studies, which led to the discovery of other
Site-related chemicals in groundwater at the Site. Because of the contamination identified
in the groundwater and the tar and other debris disposed of in the SWDA, the Site was
added to the National Priorities List on September 8, 1983.
In 1984, as an interim remedy, Hercules installed a groundwater extraction and treatment
system to prevent contaminated groundwater from migrating off-property. The system
was upgraded in 2008 and continues to operate.1
In 1986, Hercules entered into an Administrative Consent Order with NJDEP to perform
a remedial investigation and feasibility study (RI/FS) in the SWDA and adjacent areas.
Based upon the results of the Rl, conducted between 1987 and 1993, NJDEP issued a
ROD in 1996, selecting a remedy for the SWDA and adjacent areas, which comprise OU3
of the Site. The major components of the remedy include consolidation of tar material
and miscellaneous solid wastes under an impermeable cap; implementation of
engineering controls and institutional controls (ICs)2, such as fencing and environmental
use restrictions, respectively; and the establishment of a Classification Exception Area
(CEA)/Well Restriction Area (WRA)3 for groundwater beneath and surrounding the
SWDA. The OU3 remedial action was completed in 2014. Routine maintenance of the
SWDA is performed by Hercules.
Under NJDEP oversight, Hercules initiated an RI/FS in 1987 to determine the nature and
extent of contamination associated with the first and second operable units (OU1 and
OU2). EPA assumed the lead for OU1 and OU2 in 2008. In 2009, EPA entered into an
Administrative Settlement Agreement and Order on Consent (AOC) with Hercules for the
completion of the RI/FS.
1 The system was to operate until a final OU1 groundwater remedy was selected.
2 ICs are non-engineered instruments, such as administrative and legal controls, that help to
minimize the potential for exposure to contamination and/or protect the integrity of a remedy.
3 A CEA/WRA serves as an IC by providing notice that there is ground water pollution in a localized
area caused by a discharge at a contaminated site and restricting well installation in the affected
aquifer.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
On July 30, 2018, EPA released the Proposed Plan for OU1 and OU2 to the public for
comment. Supporting documentation comprising the administrative record was made
available to the public at the information repositories maintained at the Greenwich
Township Branch of the Gloucester County Library System, 411 Swedesboro Road in
Gibbstown, New Jersey, the EPA Region 2 Superfund Records Center, 290 Broadway,
18th Floor, New York, New York; and EPA's website for the Site at
https://www.epa.gov/superfund/hercules-gibbstown.
EPA published notice of the start of the public comment period, which ran from July 30 to
August 28, 2018, and the availability of the above-referenced documents in the
Gloucester County Times on July 29, 2018. A news release announcing the Proposed
Plan, which included the public meeting date, time, and location, was issued to various
media outlets and posted on EPA's Region 2 website on July 27, 2018.
A public meeting was held on August 16, 2018 at the Municipal Court Meeting Room, 21
N. Walnut Street, Gibbstown, New Jersey, to discuss the alternatives presented in the
RI/FS, and to present EPA's preferred remedy for OU1 and OU2 to the community.
Approximately 30 people attended the public meeting, including residents, media, local
business people and local government officials. Public comments were related to remedy
details, the performance of the work at the Site, and public health concerns.
A copy of the public notice published in the Gloucester County Times, along with
responses to the questions and comments received at the public meeting and in writing
during the public comment period can be found in the attached Responsiveness
Summary (See Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The NCP, at 40 CFR Section 300.5, defines an operable unit as a discrete action that
comprises an incremental step toward comprehensively addressing site problems. A
discrete portion of a remedial response eliminates or mitigates a release, threat of a
release, or pathway of exposure. The cleanup of a site can be divided into several OUs,
depending on the complexity of the problems associated with the site.
The Site is being addressed in three OUs. OU3, which included the tar and mixed waste
in the SWDA, was the first OU to be addressed. A remedial action for OU3 was selected
by NJDEP in 1996, calling for waste consolidation and capping, long-term groundwater
monitoring, periodic inspections and ICs. The OU3 remedial action was completed in
2014 and maintenance of the cap is being performed by Hercules under NJDEP
oversight. EPA conducts five- year reviews (FYRs) to ensure that the OU3 remedy
continues to be protective of human health and the environment. The first FYR was
conducted in 2015.
The subjects of this ROD are contaminated groundwater in the Former Plant Area (OU1)
and contaminated soil in the Former Plant Area and contaminated sediment in Clonmell
Creek and the Stormwater Catchment Basin (OU2). The primary objectives of this action
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are to remediate the sources of groundwater, soil, and sediment contamination, minimize
the migration of contaminants, and minimize any potential future health and
environmental impacts.
SUMMARY OF SITE CHARACTERISTICS
Hydrogeology
The Site geology is characterized by the presence of thick unconsolidated sand, silt,
gravel, and clay layers. The regional aquifer system, supplying water resources to
Greenwich Township and the surrounding area, is generally considered to consist of three
aquifers (Upper Middle, Lower Middle and Lower), which are separated by two confining
units. At the Site, alluvial deposits overlie the regional aquifer. The shallow (A-level)
monitoring well network for the Site is screened into these deposits which range from 0
to 25 ft. bgs; the intermediate (B-level) monitoring well network is screened in the Upper
Middle aquifer, ranging from 25 to 75 ft. bgs; and the deep (C-level) monitoring wells are
screened in the Lower Middle aquifer, which ranges from 80 to 120 ft. bgs. The depth to
groundwater in the Former Plant Area ranges between 8 and 10 ft. bgs.
Regional groundwater (intermediate and deep depths) generally flows from north to
south, exhibiting some influence from conditions in the Delaware River. Groundwater at
the Site flows to the south and downward, which results in shallow aquifer groundwater
contamination flowing into the underlying intermediate aquifer and subsequently into the
deep aquifer. A network of groundwater recovery wells that pump from the shallow,
intermediate and deep aquifers currently maintains hydraulic containment of the
contaminated groundwater beneath the Site.
Remedial Investigation
The July 2018 Rl report provides the analytical results of the environmental
characterization activities conducted to determine the nature and extent of contamination
in the OU1/OU2 areas of the Site. Rl activities included the installation of monitoring wells
and collection of soil and groundwater samples from the Former Plant Area; collection of
sediment, surface water, pore water, and soil samples from the Stormwater Catchment
Basin, at the 002 outfall, in the adjacent drainageway, and in Clonmell Creek and its
associated wetlands; geological, hydrogeological and residential vapor intrusion
investigations; preparation of a numerical groundwater flow model; and human health and
ecological risk assessments.
Based upon the results of the Rl, EPA concluded that VOCs are the predominant
contaminants present in the Former Plant Area groundwater and soils and the Clonmell
Creek and Stormwater Catchment Basin sediments. The contaminants of concern
(COCs) identified for the Site include acetophenone, benzene, cumene, ethylbenzene,
lead, phenol, and toluene. Benzene and cumene were found to be the most prevalent of
the COCs present at the Site. Acetophenone, ethylbenzene, phenol, and toluene are
compounds typically associated with benzene and cumene and were only found to be
present at the Site colocated with benzene and cumene. Trichloroethylene (TCE) and
1,2-dichloroethane (DCA) were detected at concentrations exceeding the Rl screening
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values in the monitoring wells located in the downgradient areas of the property, in the
groundwater recovery wells associated with the extraction and treatment system and in
wells located off-property. Because these contaminants were not found to be present in
the Site soils, EPA determined that TCE and 1,2-DCA are not Site-related and, therefore,
are not COCs.4 Based upon these findings, the following discussion of the Rl results will
primarily focus on benzene and cumene.
The Former Plant Area was divided into the following Rl investigation areas, referred to
as exposure areas: Active Process Area; Area A/Open Area, Area B; Chemical
Landfill/Gravel Pit Area; Clonmell Creek and Wetlands; Inactive Process Area; Northern
Chemical Landfill Area; Northern Warehouse Area; Shooting Range;5 Stormwater
Catchment Basin Area; Tank Farm/Train Loading Area; and Township Refuse Area (See
Figure 3 of Appendix I).
Soil samples were collected in each of the exposure areas, both above (unsaturated) and
below (saturated) the water table. Benzene, cumene and colocated COCs were found to
be present at levels exceeding Rl screening values in the soils of the Active Process Area,
Chemical Landfill/Gravel Pit, Inactive Process Area, Northern Chemical Landfill,
Stormwater Catchment Basin and Tank Farm/Train Loading Area exposure areas.
However, the bulk of the contamination is present in the Active Process Area saturated
soils (to a depth of 17.5 ft.), either adsorbed to soil particles or as non-aqueous phase
liquid (NAPL).6 The maximum benzene and cumene concentrations detected in each of
these exposure areas are summarized in Tables 1 and 2 of Appendix II and the OU2
areas with COC concentrations exceeding the Rl soil screening values are depicted in
Figure 4 of Appendix I.
Rl sampling results indicate the presence of lead in the Township Refuse Area and
Shooting Range soils at concentrations as high as 2,300 milligrams per kilogram (mg/kg).
Additional delineation of the lead contamination in these exposure areas is needed.
Sediment
Sediment samples were collected throughout the Stormwater Catchment Basin (including
the adjacent drainageway) and within the on-Site reach of Clonmell Creek (including the
002 outfall area). Upstream and downstream sediment samples were also obtained from
Clonmell Creek. Samples were collected down to 3 ft. in the Stormwater Catchment
Basin, 0.5 ft. in the drainageway and 5 ft. in Clonmell Creek.
Cumene concentrations were detected throughout the Stormwater Catchment Basin,
ranging from 0.00059 to 710 mg/kg and extending down to 3 ft. in the central area of the
basin. Cumene was detected in on-Site Clonmell Creek sediment at depths ranging from
4 Although TCE and 1,2-DCA are not Site COCs, these contaminants are being treated by the
groundwater extraction and treatment system.
5 The Shooting Range exposure area is currently being used by the Township of Greenwich Police
Department as a shooting range.
6 NAPLs are liquid contaminants that do not easily mix with water and remain in a separate phase
in the subsurface.
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0.5 to greater than 4 ft., and at concentrations ranging from 0.0014 to 240,000 mg/kg.
Cumene was not detected at concentrations exceeding the screening value in
downgradient samples collected from Clonmell Creek on the adjacent DuPont property.
Based upon the Rl results, including the risk assessment (discussed below) EPA
determined that the sediments in the Stormwater Catchment Basin and on-Site reach of
Clonmell Creek would need to be addressed. The sediment remediation areas are
depicted in Figure 5 of Appendix I.
Surface Water
Surface water samples were collected throughout the Stormwater Catchment Basin
(including the adjacent drainageway) and within the on-Site reach of Clonmell Creek
(including the 002 outfall area). No COCs were detected above the Rl screening values.
The surface water sampling results for the Stormwater Catchment Basin and Clonmell
Creek can be found in Table 8-66 and Table 8-30, respectively, of the July 2018 Rl report.
Groundwater
Groundwater has been monitored both on and off the property since 1984. A total of 92
monitoring wells are sampled on an annual basis, with 28 of the 92 wells being sampled
quarterly. Figure 6 of Appendix I shows the locations of the OU1 groundwater monitoring
wells and extraction wells associated with the existing treatment system. Benzene and
cumene concentrations exceeding Rl screening values were detected in the shallow,
intermediate and deep aquifers. The most significant benzene and cumene detections
were in the shallow aquifer in the Active Process Area, Stormwater Catchment Basin and
Northern Chemical Landfill exposure areas. Maximum COC concentrations detected in
each of these exposure areas are presented in Table 3 of Appendix II.
Vapor Intrusion
Vapors released from VOC-contaminated groundwater and/or soil have the potential to
move through the soil (independently of groundwater) and seep through cracks in
basements, foundations, sewer lines, and other openings. The vapor intrusion pathway
is evaluated at a site when soils and/or groundwater are known or suspected to contain
VOCs. In 2011, vapor intrusion sampling was conducted in the residences situated
adjacent to the southern property boundary of the Site.
Thirteen soil gas samples, 12 sub-slab samples, one crawl space air sample, eight
ambient air samples, and 25 indoor air samples were obtained from 13 properties. Soil
gas, sub-slab and ambient air samples were compared against the EPA target shallow
gas concentration and the NJDEP residential soil gas screening level. Indoor air samples
were compared against the EPA target indoor air concentration (TIAC) and the NJDEP
residential indoor air screening level.7 Indoor air sampling results also were compared to
indoor air action levels, which are threshold levels that would trigger the need for further
action, if exceeded.
7 Sub-slab sampling results were multiplied by a factor of 10 to account for attenuation into indoor
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No Site-related compounds were measured at concentrations above applicable state or
federal screening criteria in the analytical results from any of the sub-slab samples.
Benzene was detected above the TIAC in the one crawl space sample, however, benzene
was not detected in the corresponding indoor air sample collected at this property.
Although no Site-related compounds were detected above screening criteria in any sub-
slab samples, benzene was detected above the TIAC in 10 indoor air samples from 6
properties. However, benzene was either not detected or detected below the screening
values in the sub-slab sampling results from these properties. This indicates that the
benzene detections in the indoor air were not the result of vapor intrusion and were likely
associated with indoor sources. Based upon these results, EPA determined that no
additional vapor intrusion monitoring was necessary. The report documenting the findings
of the 2011 vapor intrusion study, entitled Hercules Incorporated, Higgins Plant,
Gibbstown, NJ Sub-Slab, Soil Gas and Indoor Air Vapor Intrusion Investigation Report,
can be found in Appendix I of the July 2018 Rl report.
Contamination Fate and Transport
In general, the COCs that were detected in soil and groundwater samples at the Site are
understood to be the result of releases and fugitive emissions consistent with operation
of a large chemical manufacturing facility for more than 50 years. The location of the
COCs and their mass distribution correlate reasonably well to the location of the process
areas of the former Hercules plant. In addition, historical subsurface process sewers in
the former Active Process Area that were connected to a skimmer located along the
boundary of the Active Process Area and the Inactive Process Area likely also have
contributed to subsurface cumene releases. A conceptual Site model8 is depicted in
Figure 7 of Appendix I.
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Use
Gibbstown is an unincorporated community in Greenwich Township. It has an area of
about two square miles and a population of approximately 4000, according to the 2010
census report. The Site property is comprised of 350 acres of developed and
undeveloped land, currently zoned for commercial/industrial use. It is bordered to the
north by the Delaware River, to the south by a residential area of predominantly single-
family homes and to the east and west by industrial properties. EPA does not anticipate
that the land use designation will change in the foreseeable future.
The Shooting Range exposure area is currently being used by the Township of Greenwich
Police Department as a shooting range.
Groundwater Use
The Potomac-Raritan-Magothy Formation (PRM) constitutes the regional aquifer system
supplying water resources to Greenwich Township and the surrounding area. It is
8 A conceptual site model illustrates contaminant sources, release mechanisms, exposure
pathways, migration routes, and potential human and ecological receptors.
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generally considered to consist of three aquifers (Upper Middle, Lower Middle and
Lower), which are separated by two confining clay units. The municipal water supply
wells servicing the Gibbstown area are screened in the Lower Middle aquifer; two
municipal water supply wells are located near the Site. A network of groundwater
recovery wells currently pumps from the Upper Middle and Lower Middle aquifers to
maintain hydraulic containment of the contaminated groundwater beneath the Site.
SUMMARY OF SITE RISKS
A Baseline Human Health Risk Assessment (BHHRA) was conducted to estimate current
and future effects of contaminants on human health. A BHHRA is an analysis of the
potential adverse human health effects caused by hazardous substance exposure in the
absence of any actions to control or mitigate these exposures under current and future
site uses. It provides the basis for taking an action and identifies the contaminants and
exposure pathways that need to be addressed by the remedial action. Tables 4 through
10 of Appendix II provide a summary of relevant information from the BHHRA (i.e.
exposure pathways and chemicals found to pose unacceptable risk to human health).
A screening-level ecological risk assessment (SLERA) was also conducted to evaluate
the potential for adverse ecological effects from exposure to Site-related contamination.
Based on the findings of the SLERA, a baseline ecological risk assessment (BERA) was
conducted to further analyze the risk posed to ecological receptors.
The BHHRA report, entitled Baseline Human Health Risk Assessment for the Hercules
Incorporated Former Higgins Plant and dated June 2017 and the BERA report, entitled
Baseline Ecological Risk Assessment for the Hercules Incorporated Former Higgins Plant
and dated March 2017, are available in the Administrative Record file and site repository.
The BHHRA and BERA results are discussed below.
Human Health Risk Assessment
Summary of the Human Health Risk Assessment Process
A four-step process is utilized for assessing site-related human health risks for reasonable
maximum exposure scenarios is summarized below. Each step is summarized below.
Hazard Identification - uses the analytical data collected to identify the contaminants
of potential concern (COPCs) at the site for each medium, with consideration of a
number of factors explained below.
Exposure Assessment - estimates the magnitude of actual and/or potential human
exposures, the frequency and duration of these exposures, and the pathways (e.g.,
ingesting contaminated soil) by which humans are potentially exposed.
Toxicity Assessment - determ ines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure (dose) and
severity of effect (response).
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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 that exceed
acceptable levels, defined by the NCP as an excess lifetime cancer risk greater than
1 x 10~6 to 1 x 10~4 or a Hazard Index greater than 1.0; contaminants at these
concentrations are considered COCs and are typically those that will require
remediation at the site. Also included in this section is a discussion of the uncertainties
associated with these risks.
Hazard Identification
In this step, analytical data collected during the multi-phase Rl were used to identify
COPCs in the soil, sediment, surface water and groundwater at the Site based on factors
such as toxicity, frequency of occurrence, fate and transport of the contaminants in the
environment, concentrations of the contaminants as well as their mobility, and
persistence. Benzene and cumene were identified as the primary COCs for the Site. The
following exposure pathways resulted in unacceptable human health risk: current/future
outdoor industrial workers as a result of direct contact with/ingestion of benzene and
cumene in the Sitewide shallow (A-level) aquifer; future on-Site residents as a result of
direct contact with/ingestion of benzene and cumene in the intermediate (B-level)/deep
(C-level) aquifers in the Active Process Area (also phenol and 1,2-DCA), Northern
Chemical Landfill and Tank Farm/Train Loading Area (also phenol and TCE); and
construction/utility workers as a result of dermal contact with Sitewide shallow (A-level)
groundwater. In addition, modeled lead ingestion resulted in an unacceptable potential
exposure to outdoor industrial workers and construction/utility workers and the fetuses of
females in both groups in the Township Refuse Area and Shooting Range.
Groundwater monitoring data collected from 2013 through 2017 were evaluated as part
of the Rl and soil samples used to model lead uptake were most recently collected in
2015. Table 3 of Appendix II presents the OU1 maximum concentrations in the A-level
aquifer for benzene and cumene of 19,000 ng/L and 140,000 ng/L, respectively.
Maximum concentrations of benzene and cumene in B/C-level groundwater were were
22,000 ng/L and 47,000 ng/L in the Active Process Area; 190 ng/L and 27,000 ng/L in the
Northern Chemical Landfill; and 400 ng/L and 33,500 ng/L in the Tank Farm/Train
Loading Area, respectively. Maximum B/C-level groundwater concentrations of phenol in
the Active Process Area and Tank Farm/Train Loading Area were 120,000 ng/L and
59,000 ng/L, respectively. Maximum B/C-level groundwater concentrations of 1,2-DCA
in the Active Process Area and TCE in the Tank Farm/Train Loading Area were 620 ng/L
and 26 ng/L, respectively. Although 1,2-DCA is present in the Acitive Process Area and
TCE is present in Tank Farm/Train Loading Area groundwater at levels that pose a human
health exposure risk, EPA has determined that these contaminants are not Site-related,
and therefore, are not COCs. Maximum lead concentrations in soils of the Township
Refuse Area and Shooting Range9 were 2,300 mg/kg (mean: 758 mg/kg) and 1,620
mg/kg (mean: 1620 mg/kg), respectively. A comprehensive list of all Site COPCs can be
found in the Table 2 series of the June 2017 BHHRA report.
9 Only one test pit sample was collected because the Shooting Range is still active.
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Exposure Assessment
In this step, the different exposure scenarios and pathways through which people might
be exposed to the contaminants identified in the previous step were evaluated.
Consistent with Superfund policy and guidance, the BHHRA is a baseline risk assessment
and therefore 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 exposure assessment identified potential human receptors based on a review of
current and reasonably foreseeable future land use at the Site. The Site is 350 acres,
though the active plant operations occurred in approximately 80 acres in the southwest
portion of the property. A branch of Clonmell Creek courses through the Site, flowing
northwest into the Delaware River. Areas immediately surrounding Clonmell Creek and
to the north are undeveloped wetlands. A DuPont plant and a school athletic field border
the Site to the west. To the east is Paulsboro Refinery and to the south is a residential
neighborhood. Groundwater in the impacted shallow (A-level) and intermediate (B-level)
/deep (C-level) aquifers is not used as a source of domestic water in the study area and
is not anticipated to be used for potable purposes in the future. A confining clay layer
separates the A- and B/C-level groundwater from the deeper PRM unit which is used for
domestic purposes.
Several exposure scenarios for the Site were selected based on information gathered
during the Rl, such as zoning and demographic information. Based on current and future
land uses, the following exposure scenarios were evaluated: outdoor industrial workers
(adult and fetus - lead model), indoor workers (adult), construction/utility workers (adult
and fetus - lead model), trespassers (adult, youth 6-18), hypothetical on-Site residents
(adult/child 0-6), recreational users (youth 6-18), recreational hiker (adult), recreational
hunter (adult), recreational angler (adult), and off-Site resident (adult, youth 6-18 and child
0-6). Outdoor industrial workers, construction/utility workers and hypothetical on-Site
residents were the sensitive subpopulations identified for the Site.
Potential exposure routes for the Site varied by receptors and included incidental
ingestion of, dermal contact with, and inhalation of volatiles/particulates from soil
(including wetland soil), incidental ingestion of and dermal contact with sediment in
Clonmell Creek, the Inactive Process Area pond and the Stormwater Catchment Basin,
Sludge Drying Beds (located within the Stormwater Catchment Basin EA and associated
drainage way, inidental ingestion of, dermal contact with and inhalation of volatiles from
groundwater and surface water in Clonmell Creek, the Inactive Process Area pond and
the Stormwater Catchment Basin, Sludge Drying and associated drainage ways,
inhalation of volatiles in indoor air, and ingestion of game (deer, rabbits) and fish tissue.
Table 5 of Appendix II presents all exposure pathways considered in the BHHRA, and the
rationale for the selection or exclusion of each pathway.
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Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures
and the relationship between magnitude of exposure and severity of adverse health
effects were determined. Potential health effects are contaminant-specific and may
include the risk of developing cancer over a lifetime or other noncancer health effects,
such as changes in the normal functions of organs within the body (e.g., changes in the
effectiveness of the immune system). Some contaminants can cause both cancer and
noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncancer hazards
due to exposure to Site chemicals are considered separately. 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 non-carcinogens, respectively.
Toxicity data for the BHHRA come 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. Additional toxicity information for all COPCs is presented in
the Table 5 and 6 series of the June 2017 BHHRA.
Lead is not evaluated in the same manner as other non-carcinogenic contaminants. EPA
has not published conventional quantitative toxicity values for lead because available data
suggest a very low or possibly no threshold for adverse effects, even at exposure levels
that might be considered background. However, the toxicokinetics of lead are well
understood and, as a result, lead is regulated based on the blood lead concentration. In
lieu of evaluating current and future risks using typical intake calculations and toxicity
criteria, EPA developed models specifically to evaluate lead exposures. For this BHHRA,
blood lead concentrations were estimated using the Integrated Exposure Uptake
Biokinetic model (IEUBK) and the Adult Lead Model (ALM).
The BHHRA identified a potential for exposure to lead in the Township Refuse Area as
well as the Shooting Range to cause elevated blood lead levels in adult outdoor workers
and the fetuses of female workers. The projected blood lead levels from exposure of the
outdoor industrial workers at a 95th percentile were modeled as follows: Township Refuse
Area: 7.0 micrograms per deciliter (ng/dL); fetus: 6.3 ng/dL and Shooting Range: 13.2
ng/dL; fetus: 11.8 ng/dL. The projected blood lead levels from exposure of adult
construction workers and the fetuses of female workers were modeled as follows:
Township Refuse Area: 7.9 ng/dL; fetus: 8.8 ng/dL and Shooting Range: 19.1 ng/dL;
fetus: 17.2 ng/dL. A blood lead reference value of 10 ng/dL is no longer considered by
EPA to be protective to human health. In a recent directive (EPA OLEM Directive 9285.6-
52), EPA approved the use of 5 ng/dL as the accepted blood lead reference value. The
Site-specific risk reduction goal is to limit the probability of an individual's blood lead level
exceeding 5 |jg/dL to 5% of the population or less. Model input parameters are available
in the June 2017 BHHRA.
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Risk Characterization
In this step, the outputs of the exposure and toxicity assessments were summarized and
combined 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.
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); and
SF = cancer slope factor, expressed as [1/(mg/kg-day)]
The likelihood of an individual developing cancer is expressed as a probability that is
usually expressed in scientific notation (such as 1 x 10~4). For example, a 10~4 cancer risk
means a "one-in-ten-thousand excess cancer risk"; or one additional cancer may be seen
in a population of 10,000 people as a result of exposure to site contaminants under the
conditions explained in the Exposure Assessment. Current Superfund regulations and
guidelines for acceptable exposures are an individual lifetime excess cancer risk in the
range of 10~4 to 10~6 (corresponding to a one-in-ten-thousand to a one-in-a-million excess
cancer risk) with 10~6 being the point of departure.
For noncancer health effects, a hazard index (HI) is calculated. The HI is determined
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 hazard quotients for all compounds within a particular medium
that impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as below. The HQ for inhalation
exposures is calculated using a similar model that incorporates the RfC, rather than the
RfD.
HQ = Intake/RfD
Where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
RfD = reference dose (mg/kg-day)
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The intake and the RfD will represent the same exposure period (i.e., chronic, subchronic,
or acute).
The key concept for a noncancer HI is that a "threshold level" (measured as an HI of less
than 1) exists below which noncancer health effects are not expected to occur.
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 non-
carcinogenic health effects to occur due to 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 noncancer
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.
Noncancer hazards identified due to exposure to Site contamination and unacceptable
cancer risks are summarized in Table 8 and Table 9 of Appendix II, respectively.
Uncertainty in the Risk Assessment
The process of evaluating human health cancer risks and noncancer health hazards
involves multiple steps. Inherent in each step of the process are uncertainties that
ultimately affect the final risks and hazards. Important site-specific sources of uncertainty
are identified for each of the steps in the four-step risk process above.
Uncertainties in Hazard Identification
Uncertainty is always involved in the estimation of chemical concentrations. Errors in the
analytical data may stem from errors inherent in sampling and/or laboratory procedures.
While the datasets for the Site are robust, since environmental samples are variable, the
potential exists that these datasets might not accurately represent reasonable maximum
concentrations, which could result in either an underestimate or an overestimate of Site
risk.
If applicable screening levels were not available for a particular constituent, surrogate
screening values were selected based on constituents with structural and toxicological
similarity. The use of surrogate screening values could overestimate or underestimate
the actual toxicity of the contaminants and subsequently risk, though the approach is
more conservative than qualitatively evaluating contaminants without available toxicity
information.
Uncertainties in Exposure Assessment
There are two major areas of uncertainty associated with exposure parameter estimation.
The first relates to the estimation of EPCs. The second relates to parameter values used
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to estimate chemical intake (e.g., ingestion rate, exposure frequency). The following
reflects uncertainty related to chemical intake.
Recreational anglers and hunters were evaluated as part of the risk assessment;
however, biota samples were not collected. Instead, these pathways were modeled using
conservative assumptions regarding exposure frequencies, number of meals and size of
meals. Estimation of COPC concentrations in tissue were estimated using conservative
bioaccumulation factors. As a result, risks are likely overestimated for these exposure
pathways.
Uncertainties in Toxicity Assessment
A potentially large source of uncertainty is inherent in the derivation of the EPA toxicity
criteria (i.e., RfDs, RfCs, SFs). The use of a chronic RfD or RfC to evaluate subchronic
exposures may have overestimated the risk because typically, individuals (particularly
construction workers) can be exposed to higher concentrations over a shorter period.
Additionally, the use of surrogate toxicity values has the potential to overestimate or
underestimate actual risk depending on the actual toxicokinetics of the contaminant.
Uncertainties in Risk Characterization
When all the uncertainties from each of the previous three steps are added, uncertainties
are compounded. The uncertainties may have resulted in an underestimation or
overestimation of risk, though due to the conservative nature of many assumptions, the
overall risk assessment likely overestimates risks and hazards as a result of exposure to
Site contaminants.
Ecological Risk Assessment
Sediment, surface water, pore water and soil samples were collected as part of the
ecological risk assessment. The areas of the Site evaluated in the BERA include the
Stormwater Catchment Basin (including at the 002 outfall and within the adjacent
drainageway), Clonmell Creek and the adjacent wetland area. Aquatic plants, benthic
invertebrates and fish, and semi-aquatic mammals and birds were assessed in the
Stormwater Catchment Basin (including at the 002 outfall and within the adjacent
drainageway) and in Clonmell Creek. In the wetland area, terrestrial plants and
invertebrates along with terrestrial mammals and birds were evaluated. Toxicity testing
and macroinvertebrate surveys were also conducted to support the BERA.
Measurement endpoints consisted of a comparison of estimated or measured exposure
levels of contaminants to levels reported to cause adverse effects, evaluation of
macroinvertebrate community metrics, sediment toxicity testing results, and comparison
of observed effects at the Site with those observed at reference locations. The results for
each ecological area evaluated in the BERA are summarized below.
The results of the macroinvertebrate survey in the Stormwater Catchment Basin indicated
a slight to moderate impairment of the benthic community. Toxicity testing indicated a
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significant decrease in survival compared to the reference location. The potential for
adverse effects to semi-aquatic mammals and birds is negligible.
The results of the macroinvertebrate survey in the drainageway indicated the presence
of a slightly impaired benthic community with marginal habitat quality. No significant
toxicity was observed and risk to mammalian and avian receptors is considered
negligible.
The results of the macroinvertebrate survey in Clonmell Creek suggest a moderately
impaired benthic community at several locations and suboptimal habitat quality at most
locations. Toxicity testing results at several sampling locations indicated a significant
decrease in survival compared to the reference location. Unacceptable risk to
mammalian receptors was identified, primarily due to exposure to cumene.
In the Clonmell Creek Wetland Area, the likelihood of adverse effects to terrestrial plants
and invertebrates, mammals and birds exposed to contaminants in wetlands soils is
essentially non-existent.
The BERA concluded that there is a potential for adverse ecological effects associated
with Site contaminants in the sediments of the Stormwater Catchment Basin and in
Clonmell Creek, in the vicinity of the 002 outfall.
Basis for Taking Action
Based on the results of the OU1/OU2 RI/FS, including the risk assessments, EPA has
determined that the response action selected in this ROD is necessary to protect the
public health or welfare or the environment from actual or threatened releases of
hazardous substances into the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to protect human health and the
environment. These objectives are based on available information and standards, such
as applicable or relevant and appropriate requirements (ARARs), requirements to-be-
considered (TBCs)10, and Site-specific risk-based levels.
The following RAOs have been established for OU1 and OU2:
Protect human health by preventing exposure to contaminated groundwater, soil and
soil vapor;
Prevent off-Site migration of contaminated groundwater;
Minimize exposure of fish, biota and wildlife to contaminated sediments;
10 TBCs are advisories, criteria, or guidance that were developed by EPA, other federal agencies,
or states that may be useful in developing CERCLA remedies.
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Mitigate potential for contaminant migration from soils into groundwater and surface
water; and
Restore groundwater to levels that meet state and federal standards within a
reasonable time frame.
EPA and NJDEP have promulgated maximum contaminant limits (MCLs) and NJDEP has
promulgated groundwater quality standards (GWQSs) which are enforceable, health-
based, protective standards for various drinking water contaminants. In the Proposed
Plan, EPA selected the more stringent of the MCLs and GWQSs as the preliminary
remediation goals (PRGs) for the COCs in the Site groundwater. EPA used the more
stringent of the NJDEP nonresidential direct contact soil remediation standards
(NRDCSRSs) and the NJDEP impact to groundwater soil screening levels as the PRGs
for the unsaturated soils. Because there is no impact to groundwater screening level
established for cumene, a Site-specific PRG was developed using the NJDEP Soil-Water
Partition Equation Calculator (back calculated from either the MCL or GWQS). The
NJDEP NRDCSRSs were used as the PRGs for the saturated soils and, when no
NRDCSRS was available, the EPA Regional Screening Level (RSL) for industrial soil was
used.
PRGs become final remediation goals when EPA selects a remedy after taking into
consideration all public comments. EPA has selected the PRGs identified in the Proposed
Plan as the remediation goals for OU1 and OU2.
EPA has determined that the COCs acetophenone, ethylbenzene and toluene, which
were found at the Site colocated with the primary COCs (cumene and benzene) do not
pose a human health exposure risk at this Site. These contaminants are COCs because
they are present at concentrations that exceed ARARs. The remediation goals
established for the Site COCs are identified in Tables 11 through 13 of Appendix II.
Because there is no screening value available for cumene in sediment, a Site-specific
value of 120 mg/kg was developed for comparison with the Rl sampling results. In lieu
of developing a Site-specific sediment cleanup value for cumene, a mass-removal based
approach will be used to ensure that the RAO of minimizing exposure of fish, biota and
wildlife to contaminated sediments is achieved. The goal for cumene mass removal is
100% for the Stormwater Catchment Basin and 99% for Clonmell Creek.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions be
protective of human health and the environment, 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 permanently and
significantly reduce the volume, toxicity, or mobility of the hazardous substances,
pollutants and contaminants at a site. CERCLA Section 121(d), 42 U.S.C. § 9621(d),
further specifies that a remedial action must attain a level or standard of control of the
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hazardous substances, pollutants, and contaminants, which at least attains ARARs under
federal and state laws, unless a waiver can be justified pursuant to CERCLA Section
121(d)(4), 42 U.S.C. § 9621(d)(4). Detailed descriptions of the remedial alternatives for
addressing the contamination associated with OU1 and OU2 at the Site can be found in
the Feasibility Study (FS) report, dated July 2018.
Several studies were conducted during the Rl to evaluate the use of various treatment
techniques and processes and support the development of FS to address the
contamination associated with OU1 and OU2 at the Site. A treatability study was
conducted in the Active Process Area exposure area to evaluate the use of both
aerobically- and anaerobically-enhanced biodegradation to treat source-area soils.
Because the study results showed that anaerobically-enhanced biodegradation resulted
in greater cumene concentration reductions, only anaerobic processes were considered
for in-situ soil treatment.
An air sparging/soil vapor extraction pilot test was also performed in the Active Process
Area. Based upon the results of the study, it was concluded that the heterogeneity of the
soil conditions at the Site resulted in preferential flow paths in the subsurface lithology
that inhibited the effective treatment of air flow through the saturated soil. Because this
would likely limit the effectiveness of the treatment technology, this technology was
eliminated from further consideration.
In addition, a pilot study was conducted in Clonmell Creek to evaluate the use of hydraulic
dredging versus mechanical excavation for the removal of contaminated sediments.
Hydraulic dredging was determined to be the more suitable of the two removal techniques
because of its ability to target the unconsolidated sediments rather than the underlying
clay, its ability to minimize fugitive emissions and downstream sediment transport, and
the minimal impact that it has on the surrounding wetland area. Therefore, only hydraulic
dredging is considered for the sediment alternatives involving dredging.
Along with the pilot study, a 12-month treatability study was conducted on the dredged
material to evaluate the viability of utilizing phytoremediation11 for the treatment of the
cumene-contaminated sediments at the Site. Phytoremediation can occur through
several mechanisms, including stabilization, accumulation, volatilization, degradation,
and rhizosphere biodegradation. During the study period, plants were allowed to grow in
the dredged sediment. At the end of the study period, sediment and plant tissue samples
(above- and below-ground) were collected. The study results showed that the cumene in
the sediment was reduced from concentrations ranging from 18 to 98 mg/kg to
concentrations ranging from "non-detect" to 0.10 mg/kg. Cumene was not detected in
any of the plant tissue samples, indicating that the cumene was destroyed through
rhizosphere degradation, which is the breakdown of contaminants in the rhizosphere (soil
surrounding the roots of plants) through microbial activity that is enhanced by the
presence of plant roots. Based upon these results, it was determined that cumene-
contaminated sediments at the Site can effectively be treated using phytoremediation.
11 Phytoremediation is a process that uses living plants to remove, destroy or contain
contaminants in environmental media.
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As was noted above, for more than 30 years, a groundwater extraction and treatment
system has been operated at the Site as an interim action. This system has successfully
reduced contaminant concentrations in the groundwater and prevented contaminated
groundwater from migrating off-property. Because of the effectiveness of the existing
system and the anticipated removal of the contaminant source under an active soil
remedial alternative, additional groundwater alternatives to address this groundwater
contamination were not considered.
The OU1/OU2 remedial alternatives are summarized below. The construction time for
each alternative reflects only the time required to construct or implement the remedy and
does not include the time required to design the remedy, negotiate the performance of
the remedy with any potentially responsible parties, or procure contracts for design and
construction. The "no-action" alternative was evaluated for soil, sediment, and
groundwater because the Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison against other alternatives.
OU2 Soil Alternatives
Alternative S-1: No Action
Capital Cost:
$0
Annual Operation and
Maintenance (O&M) Cost:
$0
Total Present-Worth Cost:
$0
Construction Time:
0 months
The no-action remedial alternative for soil does not include any physical remedial
measures or controls to address the soil contamination at the Site.
Alternative S-2: Excavation with Off-Site Disposal and Enhanced In-Situ
Biodegradation
Capital Cost:
$11,183,360
Annual O&M Cost:
$248,181
Total Present-Worth Cost:
$12,191,308
Construction Time:
12 months
Under this alternative, the soils in the Chemical Landfill/Gravel Pit, Northern Chemical
Landfill, Stormwater Catchment Basin and Tank Farm/Train Loading Area exposure
areas with COC concentrations exceeding the remediation goals would be excavated to
a depth of 4 ft. bgs in preparation for the enhanced in-situ biodegradation process
discussed below. As noted above, significant subsurface structures remain in the Active
Process Area and Inactive Process Area. Because the presence of these structures
would make excavation impracticable, a limited volume (approximately 500 cubic yards
[CY]) of the soils in these exposure areas exceeding the remediation goals would be
treated in-situ rather than being excavated.
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The soil in the Township Refuse Area with lead concentrations exceeding the remediation
goals would be excavated. A Best Management Practices (BMP) plan would be
developed and implemented to manage lead and minimize contamination of the Shooting
Range exposure area while the shooting range continues to be used for its current
purpose. If the current use of the Shooting Range exposure area ends or changes,
delineation of the lead contamination would be performed and the soils the in the Shooting
Range exposure area with lead concentrations exceeding the remediation goals would
be excavated and disposed of off-Site.
An estimated 13,804 CY of contaminated soil would be excavated under this alternative,
consisting of 1,052 CY12 of lead-contaminated soil and 12,752 CY of soil contaminated
with benzene, cumene and colocated COCs.
The contaminated soil would be excavated using standard construction equipment, such
as backhoes and track excavators. The excavated soil would be placed directly onto a
dump truck and transported to an on-Site staging area. The staging area would be
designed with proper controls, including an impermeable liner, to maintain containment
of the excavated soils and prevent any impacts to the surrounding soil and groundwater.
The lead-contaminated soils would be segregated from other soils at the staging location
because they may require disposal at a different facility. The excavated soil would then
be sampled and transported off-Site for treatment and/or disposal at an appropriately
licensed off-Site treatment and/or disposal facility.
Post-excavation sampling would be conducted to identify/confirm the areas where the
remediation goals are exceeded in the soils situated below 4 ft. bgs. These soils
(saturated and unsaturated) would be treated using enhanced in-situ biodegradation.
Enhanced in-situ biodegradation would involve applying a magnesium sulfate solution to
the contaminated soils to stimulate activity and reproduction in naturally-occurring
anaerobic microorganisms. The microorganisms would then destroy or transform the
COCs into less toxic compounds by using them as a food and energy source. Because
the extent of the contamination is much greater and deeper in the Active Process Area
and Inactive Process Area than in the other exposure areas, application of the anaerobic
treatment solution in these exposure areas would be achieved using lateral infiltration
galleries, consisting of perforated piping installed at the base of the excavated areas. The
solution would be applied directly to the base of the excavations in the Chemical
Landfill/Gravel Pit, Northern Chemical Landfill, Stormwater Catchment Basin and Tank
Farm/Train Loading Area exposure areas. The final design criteria for the infiltration
galleries would be detailed in the remedial design.
Certified clean soil, meeting applicable state regulations, would be imported and used to
backfill excavated areas and construct an engineered soil cover in the Active Process
Area, Inactive Process Area and the Tank Farm/Train Loading Area to reduce infiltration
of surface water to the groundwater and control surface water runoff/drainage. Vegetation
would be placed in areas disturbed during excavation activities to stabilize the soil and
maintenance of the soil cover would be performed.
12 The estimated soil excavation volumes and associated costs do not include the lead-
contaminated soil in the Shooting Range exposure area.
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Performance and compliance monitoring would be conducted to determine residual
contaminant concentrations and assess the need for additional treatment. The estimated
time frame to achieve the RAOs and meet the remediation goals under this alternative is
10 years. An IC would be put in place to prevent intrusive activities in in-situ treatment
areas until the remediation goals are met.
Because this alternative would result in contaminants remaining above levels that allow
for unrestricted use and unlimited exposure, in accordance with CERCLA the Site would
be reviewed at least once every five years until the remediation goals are met.
Alternative S-3: Excavation with Off-Site Disposal, Ex-Situ Bioremediation/Reuse
and Enhanced In-Situ Biodegradation
Capital Cost:
$5,198,118
Annual O&M Cost:
$248,181
Total Present-Worth Cost:
$6,206,066
Construction Time:
18 months
Under this alternative, the contaminated soils would be excavated as detailed above for
Alternative S-2. The volumes and on-Site handling of excavated soils and the backfilling
of excavated areas with certified clean fill would be the same as for Alternative S-2, the
limited volume (approximately 500 cubic yards [CY]) of the soils in the Active Process
Area and Inactive Process Area exceeding the remediation goals would be treated in-
situ, rather than being excavated, and the lead-contaminated soil from the Township
Refuse Area would be transported to an appropriately licensed off-Site treatment and/or
disposal facility. This alternative would also include the development and implementation
of a BMP plan in the Shooting Range, as described in Alternative S-2.
The soils excavated from the Chemical Landfill/Gravel Pit, Northern Chemical Landfill,
Stormwater Catchment Basin and Tank Farm/Train Loading Area exposure areas would
be treated on-Site using ex-situ bioremediation instead of being transported of-Site for
treatment/disposal. Conventional methods of ex-situ bioremediation include
biopiles/composting, landfarming with tilling, phytoremediation or a combination of these
methods. All methods were evaluated in the FS and biopiles/composting was determined
to be the most suitable for application at the Site.
The excavated soil would be mixed with soil amendments, formed into piles and aerated,
either passively or actively (using blowers or vacuum pumps). As part of the remedial
design, an analysis would be performed to confirm that the average VOC concentrations
that may be generated and released from ex-situ treatment of the soils would not exceed
applicable state and federal air emissions standards. If air emissions controls are
determined to be necessary based upon these calculations, then those controls would
be detailed in the remedial design. In addition, vapors from the VOCs in the biopiles that
volatilize into the air would be monitored to protect Site workers and ensure that state
and federal air emission standards are not exceeded. Post-remedial sampling of the
treated soils would be conducted to ensure that the remediation goals are met.
The ex-situ-remediated soils would be reused on-Site as part of an engineered soil cover
in the Active Process Area, Inactive Process Area and the Tank Farm/Train Loading Area
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to reduce infiltration of surface water to the groundwater and control surface water
runoff/drainage. Vegetation would be placed in areas disturbed during excavation
activities to stabilize the soil, and maintenance of the soil cover would be performed for a
period of 15 years.
The contaminated soils situated below 4 ft. bgs in the excavated areas would be treated
using enhanced in-situ biodegradation, as described in Alternative S-2. The estimated
time frame to achieve the RAOs and meet the remediation goals under this alternative is
10 years. An IC would be put in place to prevent intrusive activities in in-situ treatment
areas until the remediation goals are met.
Because this alternative would result in contaminants remaining above levels that allow
for unrestricted use and unlimited exposure, in accordance with CERCLA the Site be
reviewed at least once every five years until the RAOs are met.
OU2 Sediment Alternatives
Alternative SED-1: No Action
Capital Cost:
$0
Annual O&M Cost:
$0
Total Present-Worth Cost:
$0
Construction Time:
0 months
The no-action remedial alternative for sediment does not include any physical remedial
measures or controls to address the sediment contamination at the Site.
Alternative SED-2: Hydraulic Dredging with Off-Site Disposal
Capital Cost:
$4,086,780
Annual O&M Cost:
$0
Total Present-Worth Cost:
$4,086,780
Construction Time:
12 months
Under this alternative, a hydraulic dredge would remove a mixture of contaminated
sediment and water (referred to as slurry) from the bottom surfaces of the Stormwater
Catchment Basin and Clonmell Creek. The work area would be enclosed with silt curtains
to prevent downstream migration of contaminated sediment during dredging activities.
Also, the surface water outside the work area would be monitored to ensure that
contaminated sediments are not being resuspended in the water column and transported
downstream.
The slurry would be transferred via pipeline into geotextile tubes (located in a staging
area) for dewatering. The staging area would be designed with proper controls, including
but not limited to an impermeable liner, to prevent any impacts to the surrounding soil and
groundwater and maintain containment of the dredged sediments and effluent water from
the geotextile tubes.
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The effluent would be sampled and, if necessary, treated on-Site before being discharged
to the Stormwater Catchment Basin in compliance with substantive New Jersey Pollutant
Discharge Elimination System (NJPDES) discharge to groundwater permit requirements.
The details of the effluent treatment system would be finalized during the remedial design.
Monitoring of groundwater wells around the Stormwater Catchment Basin would be
conducted to ensure compliance with substantive permit requirements. The dewatered
solids left in the geotextile tubes would be transported to an appropriately licensed off-
Site treatment and/or disposal facility.
As discussed above, because there is no screening value available for cumene in
sediment, a Site-specific value of 120 mg/kg was developed for comparison with the Rl
sampling results. In lieu of developing a Site-specific sediment cleanup value for cumene,
the volumes of sediment to be dredged were determined using a mass-removal approach.
It is estimated that 1,225 CY of sediment from the Stormwater Catchment Basin and 7,275
CY of sediment from Clonmell Creek would be dredged. These volumes represent
removal of 100 percent of the cumene mass in the Stormwater Catchment Basin sediment
and approximately 99 percent of the cumene mass within the Clonmell Creek sediment
and include all the sediment identified in the BERA as posing a risk to ecological
receptors. The estimated time frame to achieve RAOs under this alternative is 18 months.
Alternative SED-3: Hydraulic Dredging with On-Site Treatment/Reuse
Capital Cost:
$1,860,320
Annual O&M Cost:
$0
Total Present-Worth Cost:
$1,860,320
Construction Time:
24 months
This alternative is the same as Alternative SED-2, except instead of being transported
off-Site for treatment and/or disposal, the dredged sediments would be treated on-Site
using phytoremediation and, if necessary, ex-situ bioremediation.
Under this alternative, the geotextile tubes would be located in a treatment area,
designed with proper controls, including but not limited to an impermeable liner, to
maintain containment of the dredged sediments and prevent any impacts to the
surrounding soil and groundwater. Plants would be planted in the cumene-contaminated
sediment within the geotextile tubes for a pre-determined growth period.13
Based upon the results obtained during the phytoremediation pilot study, it is expected
that cumene concentrations in the sediment would be reduced to "non-detect." However,
if sampling results indicate that cumene concentrations remain above the remediation
goals14 at the end of the growth period, then ex-situ bioremediation, as described above
for Alternative S-3, would be used to further treat the sediments.
13 Additional studies would be conducted during the remedial design phase to refine plant species
selection and determine the optimal growth period.
14 Because the treated sediment would be reused on-Site in an engineered soil cover, the final
COC concentrations would need to meet the unsaturated soil remediation goals.
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The treated sediments would be reused on-Site as part of an engineered soil cover in
the Active Process Area, Inactive Process Area and the Tank Farm/Train Loading Area
to reduce infiltration of surface water to the groundwater and control surface water
runoff/drainage. The plant residuals would be harvested and composted on-Site. The
estimated time frame to achieve RAOs under this alternative is 18 months.
OU1 Groundwater Alternatives
Alternative GW-1: No Further Action
Capital Cost:
$0
Annual O&M Cost:
$0
Total Present-Worth Cost:
$0
Construction Time:
0 months
Under this remedial alternative, operation of the existing groundwater treatment system
would be discontinued, and no further remedial measures would be taken to address the
groundwater contamination at the Site.
Alternative GW-2: Extraction with On-Site Treatment and Long-Term Monitoring
Capital Cost:
$409,826
Annual O&M Cost:
$225,938
Total Present-Worth Cost:
$3,181,534
Construction Time:
12 months
As discussed above, as an interim remedy, operation of a groundwater extraction and
treatment system has been on-going at the Site since 1984. The current system consists
of extraction wells and subsurface pipelines that capture and carry contaminated
groundwater into a treatment unit (currently housed in an on-Site trailer), with a treatment
capacity of 125 gallons per minute (gpm). The treatment process consists of filtration
through sand units to reduce iron and suspended solids, followed by transmission through
a series of granular activated carbon (GAC) canisters to remove the COCs. The treated
groundwater is then pumped through a pipeline and discharged into the Delaware River
under a NJPDES discharge to surface water permit. Groundwater quality monitoring is
conducted on a quarterly basis to verify that the system continues to maintain hydraulic
control of the contaminated groundwater beneath the Site.
Under this alternative, a new treatment unit, with an approximate treatment capacity of
125 gpm, would be built to replace/upgrade the existing one and a small building would
be constructed in the Stormwater Catchment Basin exposure area to house the new
treatment unit. The extracted groundwater would be pumped from the existing extraction
well infrastructure into an equalization tank within the treatment building and then treated
with a polymer. The polymer would be combined with pH adjustment, if necessary, to
promote flocculation of iron and other solids in the groundwater.
The groundwater would then be pumped through conventional geotextile tubes followed
by GAC-impregnated geotextile tubes, if necessary, to remove iron and solids and treat
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the COCs. The flocculated iron and solids would be captured in the geotextile tubes. The
COCs would partition to the solids in the geotextile tubes where they would biodegrade.
The spent tubes would be transported off-Site to a permitted disposal facility. Treated
water would be discharged to the groundwater in compliance with substantive NJPDES
discharge to groundwater permit requirements (using the Stormwater Catchment Basin
as an infiltration point). Long-term groundwater monitoring would be continued until the
remediation goals are met.
It is estimated that, in combination with active treatment of source-area soils, it would take
10 years to remediate the contaminated groundwater to remediation goals under this
alternative. However, a conservative 15-year time frame is used for groundwater
monitoring to provide maximum protection of human health and the environment. The
groundwater monitoring timeline may be truncated if the remediation goals can be met in
a shorter time frame.
ICs would be put in place at the Site, including the establishment of a CEA/WRA to restrict
groundwater use and require that future buildings on the Site either be subject to a vapor
intrusion evaluation or be built with vapor intrusion mitigation systems until the
remediation goals are met.
Because this alternative would result in contaminants remaining on-Site above levels that
allow for unrestricted use and unlimited exposure, CERCLA requires that the Site be
reviewed at least once every five years.
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 pursuant to Section 300.430(e)(9) of the NCP, 40 C.F.R § 300.430(e)(9),
EPA's Guidance for Conducting Remedial Investigations and Feasibility Studies, OSWER
Directive 9355.3-01, and 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 against each of the nine evaluation criteria at 40 C.F.R. § 300.430(e)(9)(iii)
and a comparative analysis focusing upon the relative performance of each alternative
against those criteria. The evaluation criteria are described below.
Threshold Criteria - The first two criteria are known as "threshold criteria" because
they are the minimum requirements that each response measure must meet to be
eligible for selection as a remedy.
Overall protection of human health and the environment addresses whether a remedy
provides adequate protection and describes how risks posed through each exposure
pathway (based on a reasonable maximum exposure scenario) are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional
controls.
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Compliance with ARARs addresses whether a remedy will meet all the applicable or
relevant and appropriate requirements of other federal and state environmental
statutes and requirements or provide grounds for invoking a waiver.
Primary Balancing Criteria - The next five criteria are known as "primary balancing
criteria." These criteria are factors by which tradeoffs between response measures are
assessed so that the best options will be chosen, given site-specific data and conditions.
Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals
have been met. It also addresses the magnitude and effectiveness of the measures
that may be required to manage the risk posed by treatment residuals and/or
untreated wastes.
Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies, with respect to these parameters, which
a remedy may employ.
Short-term effectiveness addresses the period needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation period until cleanup goals are achieved.
Implementabilitv is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.
Cost includes estimated capital, O&M, and present-worth costs.
Modifying Criteria - The final two evaluation criteria 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 if, based on its review of the FS report and Proposed Plan,
the State concurs with the preferred remedy.
Community acceptance refers to the public's general response to the alternatives
described in the FS report and Proposed Plan.
A comparative analysis of these alternatives based upon the evaluation criteria noted
above follows.
Overall Protection of Human Health and the Environment
Alternative S-1 would not be protective of human health because it would not actively
address the contaminated soils, which are acting as a source of contamination to the
groundwater and pose a human health risk. Alternatives S-2 and S-3 would be protective
of human health, because these alternatives would employ a remedial strategy capable
of eliminating direct contact risk for soil and the impact to groundwater, removing/treating
the source of groundwater contamination and the threat to public health.
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Alternative SED-1 would not be protective of the environment because no action would
be taken to eliminate or mitigate ecological exposure to the contaminated sediments in
the Stormwater Catchment Basin and Clonmell Creek. Alternatives SED-2 and SED-3
would be protective of the environment because, under these alternatives, the
contaminated sediments posing an ecological risk in the Stormwater Catchment Basin
and Clonmell Creek would be removed.
Alternative GW-1 would not be protective of human health because it would not prevent
off-Site migration or actively treat the contaminated groundwater, which poses a human
health risk. Alternative GW-2 would be protective of human health because it would rely
upon groundwater extraction to prevent contamination from reaching downgradient
receptors and active treatment to restore groundwater quality to levels that meet state
and federal standards within a reasonable time frame. The ICs under Alternative GW-2
would provide protection of public health until groundwater standards are met.
Compliance with ARARs
Soil remediation goals for the Site were established based on NJDEP's NRDCSRSs
(chemical-specific ARARs) and TBC criteria, including NJDEP's impact to groundwater
screening levels and EPA's RSLs for industrial soil.
No action would be taken under Alternative S-1 to address contaminated soils. Therefore,
this alternative would not achieve the soil remediation goals. Alternatives S-2 and S-3
would comply with ARARs because both alternatives would actively remediate
contaminated soil to achieve the soil remediation goals.
Because Alternatives S-2 and S-3 would involve the excavation of contaminated soils,
these alternatives would require compliance with fugitive dust and VOC emission
regulations.
Both Alternatives S-2 and S-3 would be subject to state and federal regulations related to
the transportation and off-site treatment and/or disposal of wastes.
There are currently no federal or state promulgated standards for contaminant levels in
sediments. The New Jersey Ecological Screening Criteria (NJESC) are TBC criteria used
in the Rl and BERA to evaluate Site data. The primary location-specific ARARs for
sediment would be the Freshwater Wetlands Protection Act (NJSA 13:9B-1 et seq.) and
Flood Hazard Area Control Act Regulations (NJAC 7:13-10 and 11).
Alternatives SED-2 and SED-3 would result in minimal disturbance to the surrounding
area and would not likely involve replacing the dredged sediment, therefore, both
alternatives would comply with location-specific ARARs.
EPA and NJDEP have promulgated MCLs and NJDEP has promulgated GWQSs, which
are enforceable health-based, protective standards for various drinking water
contaminants (chemical-specific ARARs). Although the groundwater at the Site is not
presently being utilized as a potable water source, achieving MCLs in the groundwater is
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an applicable standard because the aquifer beneath the Site is designated as a Class II-
A potable water source.
No action would be taken under Alternative GW-1 to remediate the groundwater.
Therefore, this action would not achieve chemical-specific ARARs. Alternative GW-2
would be more effective in reducing groundwater contaminant concentrations below
MCLs and GWQSs, because it involves active remediation of the contaminated
groundwater. Alternative GW-2 would also be subject to discharge to groundwater
ARARs because treated water would be discharged to the groundwater using the
Stormwater Catchment Basin as an infiltration point.
The ICs included in Alternatives S-2, S-3 and GW-2 would be implemented consistent
with the provisions of State of New Jersey Administrative Requirements for the
Remediation of Contaminated Sites (N.J.A.C. 7:26C).
Long-Term Effectiveness and Permanence
Alternative S-1 would not involve any active remedial measures and, therefore, would not
be effective in preventing exposure to contaminants in the soil and would allow the
continued migration of contaminants from the soil to the groundwater. Alternatives S-2
and S-3 would both be effective in the long term and would provide permanent
remediation by removing contaminated soils (from 0-4 ft. bgs) in the Chemical
Landfill/Gravel Pit, Northern Chemical Landfill, Stormwater Catchment Basin, and Tank
Farm/Train Loading Area exposure areas and either treating them on-Site or
treating/disposing of them off-Site, and by treating the source-area soils in the Active
Process Area exposure area to achieve the remediation goals. Both Alternatives S-2 and
S-3 would rely on an IC to prevent intrusive activities in in-situ treatment areas until the
remediation goals are met and would maintain reliable protection of human health and
the environment over time.
Under Alternative S-2, lead-contaminated soils and VOC-contaminated soils (from 0 to 4
ft. bgs) would be disposed of off-Site, whereas Alternative S-3 would involve treating the
excavated VOC-contaminated soils on-Site and reusing the treated soils as part of an
engineered soil cover. Alternative S-2 would result in a more rapid reduction in risk,
because the contaminated soils would be removed from the Site. However, it is
anticipated that, under Alternative S-3, proper management and successful treatment of
VOCs in the soils would be achievable within a reasonable time frame using ex-situ
bioremediation. Therefore, on-Site reuse of the treated soils would not result in an
unacceptable exposure risk at the Site.
Alternative SED-1 would not involve any active remedial measures and, therefore, would
not be effective in minimizing the exposure of ecological receptors to contaminated
sediments. Alternatives SED-2 and SED-3 would be equally effective in the long term
and both would provide permanent remediation by removing the contaminated sediments
posing a risk to ecological receptors in the Stormwater Catchment Basin and Clonmell
Creek.
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Under Alternative SED-2, the contaminated sediments would be disposed of off-Site,
whereas Alternative SED-3 would involve treating the contaminated sediments on-Site
and reusing the treated sediments as part of an engineered soil cover. Alternative SED-
2 would result in a more rapid reduction in risk, because the contaminated sediments
would be removed from the Site. However, it is anticipated that, under Alternative SED-
3, proper management and successful remediation of cumene in the sediments (to non-
detectable concentrations) would be achievable within a reasonable time frame using
phytoremediation and, if necessary, ex-situ bioremediation. Therefore, on-Site reuse of
the treated sediments would not result in an unacceptable exposure risk at the Site.
Alternative GW-1 would be expected to have minimal long-term effectiveness and
permanence because it would rely upon natural processes to restore groundwater quality
and would not prevent off-Site migration of contaminated groundwater. Alternative GW-2
would provide long-term effectiveness and permanence because it would rely on
groundwater extraction and treatment and ICs (in combination with one of the action soil
alternatives) to achieve the PRGs, prevent off-Site migration of contaminants, and
prevent human exposure to contaminated groundwater and soil vapor.
Reduction in Toxicity, Mobility, or Volume Through Treatment
Alternative S-1 would involve no active remedial measures and, therefore, would provide
no reduction in toxicity, mobility, or volume through treatment. Alternative S-2 would
reduce the mobility of contaminants by removing the lead-contaminated soils and the
VOC-contaminated soils (from 0 to 4 ft. bgs) from the property and would reduce the
toxicity, mobility, and volume through in-situ treatment of the remaining source-area soils.
Alternative S-3 would reduce the mobility of the contaminants (though not through
treatment) by excavating the lead-contaminated soils and the VOC-contaminated soils
(from 0-4 ft. bgs) and removing the lead-contaminated soil from the property. The toxicity
and volume of the contaminants would be reduced through ex-situ treatment of the
excavated VOC-contaminated soils. The toxicity, mobility, and volume of the source-
area soils would be addressed through in-situ treatment.
Alternative SED-1 would involve no active remedial measures and, therefore, would
provide no reduction in toxicity, mobility, or volume through treatment. Both Alternatives
SED-2 and SED-3 would reduce the mobility of the contaminants (though not through
treatment) by removing the contaminated sediments posing a risk to ecological receptors
in the Stormwater Catchment Basin and Clonmell Creek. However, Alternative SED-3
would also provide a reduction in the toxicity and volume of the contaminated sediments
through on-Site treatment.
Alternative GW-1 would not effectively reduce the toxicity, mobility or volume of
contaminants in the groundwater through treatment, as it involves no active remedial
measures. Alternative GW-2, on the other hand, would reduce the toxicity, mobility, and
volume of contaminated groundwater through extraction and treatment in the on-Site
treatment system, thereby satisfying CERCLA's preference for treatment.
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Short-Term Effectiveness
Because no actions would be performed under Alternative S-1, there would be no
implementation time. The time frames for the excavation of the unsaturated soils (12
months) and in-situ treatment of the source-area soils (10 years) would be the same for
Alternatives S-2 and S-3. Ex-situ treatment of the excavated VOC-contaminated soils
under Alternative S-3 would take approximately 18 months.
Alternative S-1 would not include any physical construction measures in any areas of
contamination and, therefore, would not present any potential adverse impacts to
remediation workers or the community. Alternatives S-2 and S-3 could present some
limited adverse impacts to remediation workers through dermal contact and inhalation
related to the excavation of contaminated soils. The risks to remediation workers under
Alternatives S-2 and S-3 could be mitigated by following appropriate health and safety
protocols, by exercising sound engineering practices, and by utilizing proper protective
equipment.
Both Alternatives S-2 and S-3 would require the off-Site transport of contaminated soils,
which could potentially adversely affect local traffic. However, the volume transported
under Alternative S-2 (approximately 830 truckloads) would be significantly greater than
for Alternative S-3 (approximately 63 truckloads).
For Alternatives S-2 and S-3, there is a potential for increased storm water runoff and
erosion during construction and excavation activities that would have to be properly
managed to prevent or minimize any adverse impacts. For these alternatives, appropriate
measures would have to be taken during excavation activities to prevent transport of
fugitive dust and exposure of workers and downwind receptors to the VOCs in the Site
soils.
The installation of infiltration galleries and interim- and post-remediation soil sampling
activities, associated with the in-situ treatment of source-area soils under Alternatives S-
2 and S-3 would pose an additional risk to on-Site workers, because these activities would
be conducted within areas of potential soil and groundwater contamination.
Because no actions would be performed under Alternative SED-1, there would be no
implementation time. Both Alternatives SED-2 and SED-3 would require some
infrastructure construction, however, the infrastructure required to implement Alternative
SED-3 would be more extensive and, therefore, would require more time to complete. It
is estimated that it would take 12 months to implement Alternative SED-2 and 24 months
to implement Alternative SED-3.
Alternative SED-2 would require the off-Site transport of contaminated sediments
(approximately 550 truckloads), which has the potential to adversely affect local traffic.
Both Alternatives SED-2 and SED-3 would present some limited risk to remediation
workers through dermal contact and inhalation related to the handling of the dredged
sediments, however, this risk would be increased under Alternative SED-3 due to the
longer potential exposure time associated with on-Site treatment. The risks to
remediation workers under Alternatives SED-2 and SED-3 could be mitigated by following
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appropriate health and safety protocols, by exercising sound engineering practices, and
by utilizing proper protective equipment.
Because no actions would be performed under Alternative GW-1, there would be no
implementation time. It is estimated that, under Alternative GW-2, it would take 12 months
to complete the modifications to the existing underground piping, build the structure to
house the new treatment system and install the new treatment system. The overall time
to meet the remediation goals throughout the entire groundwater plume under Alternative
GW-2 (in combination with one of the action soil alternatives) is estimated to be 10 years.
Alternative GW-1 would have no short-term impact to remediation workers or the
community and would have no adverse environmental impacts from implementation,
because no actions would be taken under this alternative. Alternative GW-2 could
present some limited risk to remediation workers through dermal contact and inhalation
related to construction activities associated with the underground piping modifications,
building construction and periodic groundwater sampling activities. The risks to
remediation workers could be mitigated by following appropriate health and safety
protocols, exercising sound engineering practices and utilizing proper personal protective
equipment.
Implementability
Alternative S-1 would be the easiest soil alternative to implement because there are no
activities to undertake. Both Alternatives S-2 and S-3 would employ technologies known
to be reliable and that are readily implementable. The equipment, services and materials
needed to implement Alternatives S-2 and S-3 are readily available and the actions under
these alternatives would be administratively feasible.
Under Alternatives S-2 and S-3, real-time air quality monitoring for VOCs and dust during
excavation activities would need to be conducted to protect remediation workers and
downwind residents. Sufficient facilities are available for the treatment and disposal of
the excavated materials and determining the achievement of the soil remediation goals
could be easily accomplished through post-excavation soil sampling and analysis under
Alternatives S-2 and S-3.
Alternative SED-1 would be the easiest sediment alternative to implement because it
would not involve undertaking any actions. Alternatives SED-2 and SED-3 would employ
hydraulic dredging, which is a commonly-used technology proven to be effective in the
removal of contaminated sediments. Alternative SED-3 would involve on-Site treatment
of contaminated sediments through phytoremediation in geotextile tubes, which was
successfully demonstrated during the treatability study conducted on the Clonmell Creek
sediment during the Rl. The equipment, services and materials needed to implement
Alternatives SED-2 and SED-3 are readily available and the actions under these
alternatives would be administratively feasible.
Alternative GW-1 would be the easiest groundwater alternative to implement, because it
would not entail the performance of any activities. The equipment, services and materials
needed to implement Alternative GW-2 are readily available and the actions under this
30
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alternative would be administratively feasible. The existing extraction and treatment
system has been successful at maintaining hydraulic control and reducing COC
concentrations in the groundwater at the Site and the ICs under Alternative GW-2 would
be relatively easy to implement.
In accordance with CERCLA, no permits would be required for on-site work (although
such activities would comply with substantive requirements of otherwise required
permits). Permits would be obtained as needed for off-Site work.
Cost
Cost includes estimated capital and annual O&M 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.
This is a standard assumption in accordance with EPA guidance.
The estimated capital costs, O&M costs and present worth costs for the alternatives are
discussed in detail in the FS Report. The cost estimates are based on the best available
information. The present-worth costs for the soil alternatives were calculated using a
discount rate of 7 percent and a 15-year time frame for soil cap maintenance. The
present-worth cost for Alternative GW-2 was calculated using a discount rate of 7 percent
and a 10-year time interval for operation and maintenance of the treatment system (the
estimated time to meet the groundwater remediation goals) and a discount rate of 7
percent and a 15-year time interval for groundwater monitoring. The estimated costs for
the OU1 and OU2 remedial alternatives are summarized below.
Alternative
Capital
Annual O&M
Total Present Worth
S-1
$0
$0
$0
S-2
$11,183,360
$248,181
$12,191,308
S-3
$5,198,118
$248,181
$6,206,066
SED-1
$0
$0
$0
SED-2
$4,086,780
$0
$4,086,780
SED-3
$1,860,320
$0
$1,860,320
GW-1
$0
$0
$0
GW-2
$409,826
$225,938
$3,181,534
State Acceptance
NJDEP concurs with the selected remedy. A letter of concurrence is attached in Appendix
IV.
Community Acceptance
Comments received during the public comment period indicate that the public generally
supports the selected remedy. These comments are summarized and addressed in the
Responsiveness Summary, which is attached as Appendix V to this document.
31
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PRINCIPAL THREAT WASTES
The NCP establishes an expectation that the EPA will use treatment to address the
principal threats posed by a Site whenever practicable (NCP Section
300.430(a)(1)(iii)(A)). Identifying principal threat wastes combines concepts of both
hazard and risk. In general, principal threat wastes are those source materials considered
to be highly toxic or highly mobile that generally cannot be reliably contained or would
present a significant risk to human health or the environment in the event exposure should
occur. Non-principal threat wastes are those source materials that generally can be
reliably contained and that would present only a low risk in the event of exposure. The
decision to treat principal threat wastes is made on a site-specific basis through a detailed
analysis of alternatives, using the remedy selection criteria which are described above.
The manner in which principal threat wastes are addressed provides a basis for making
a statutory finding that the remedy employs treatment as a principal element.
The high concentrations of benzene, cumene, and colocated COCs in the Site soils, either
adsorbed to soil particles or as NAPL, are an on-going source of contamination to the
groundwater and are considered to be principal threat wastes. By utilizing treatment as a
significant component of the remedy for soil, the statutory preference for remedies that
employ treatment as a principal element is satisfied.
SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of the
alternatives, and public comments, EPA has determined that Alternative S-3, Alternative
SED-3 and Alternative GW-2 best satisfy the requirements of CERCLA Section 121, 42
U.S.C. §9621, to respectively address the soil, sediment and groundwater at the Site, and
provide the best balance of tradeoffs among the remedial alternatives with respect to the
NCP's nine evaluation criteria, 40 CFR § 300.430(e)(9).
Both Alternative S-2 and Alternative S-3 would address principal threat wastes through
excavation and treatment and effectively achieve the soil the remediation goals.
Alternative S-2 would meet the remediation goals in the soils from 0-4 ft. bgs more quickly
by removing the excavated soils from the property. However, Alternative S-3 will achieve
the remediation goals in these soils through treatment within a reasonable time frame
(12 months) and will provide a greater environmental benefit than Alternative S-2
because it will allow for on-Site reuse of the treated soils. Alternative S-2 would be
considerably more expensive to implement than Alternative S-3 because of the
significantly larger volumes of contaminated soil that would need to be transported off-
Site for treatment and/or disposal and clean fill that would need to be imported to backfill
the excavated areas and construct an engineered soil cap under Alternative S-2.
Therefore, EPA believes that Alternative S-3 will effectively address the soil
contamination at the Site while providing the best balance of tradeoffs with respect to the
evaluating criteria.
32
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Both Alternative SED-2 and Alternative SED-3 would effectively and permanently
eliminate the risk posed to environmental receptors by removing the contaminated
sediments from the Stormwater Catchment Basin and Clonmell Creek. Alternative SED-
2 would require less time and infrastructure construction to implement than Alternative
SED-3, however, Alternative SED-2 would be considerably more expensive to implement
than Alternative SED-3 because it would involve transporting the contaminated
sediments off-Site for treatment and/or disposal and would require a larger volume of
clean fill to be imported onto the Site. Alternative SED-3 will provide a greater
environmental benefit than Alternative SED-2 because it will allow for on-Site treatment
and reuse of the treated sediments as part of an engineered soil cover. EPA believes
Alternative SED-3 will effectively mitigate the threat to ecological receptors at the Site
while providing the best balance of tradeoffs with respect to the evaluating criteria.
For more than 30 years, a groundwater extraction and treatment system has been
operated at the Site as an interim action. This system has successfully reduced
contaminant concentrations in the groundwater and prevented contaminated
groundwater from migrating off-property. Because of the effectiveness of the existing
system and the anticipated removal of the contaminant source under the selected soil
alternative, EPA has selected Alternative GW-2 as the remedy for the OU1 groundwater.
EPA believes that the selected remedy will provide the greatest protection of human
health and the environment and long-term effectiveness, will achieve the ARARs more
quickly, or as quickly, as the other alternatives, and is cost effective. Therefore, the
selected remedy will provide the best balance of tradeoffs among alternatives with
respect to the evaluating criteria. EPA and NJDEP believe that the selected remedy will
address principal threat wastes, be protective of human health and the environment,
comply with ARARs, be cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent
practicable. The selected remedy also will meet the statutory preference for the use of
treatment as a principal element, as well as include consideration of EPA Region 2's
Clean and Green Energy Policy.15
Description of the Selected Remedy
Based upon an evaluation of the various alternatives, EPA, in consultation with NJDEP,
has selected Alternative S-3, Alternative SED-3 and Alternative GW-2 to respectively
address the contaminated soil, sediment and groundwater in the OU1 and OU2 areas of
the Site. Figure 8 of Appendix I shows the soil and sediment remediation areas and
Figure 9 of Appendix II depicts the conceptual layout of the selected remedy components
which include the following:
excavation of lead-contaminated soil with off-Site disposal;
excavation of VOC-contaminated soil located 0-4 ft. bgs and treatment with ex-situ
bioremediation;
15 See https://www.epa.gov/greenercleanups/epa-region-2-clean-and-green-policy.
33
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enhanced in-situ biodegradation of VOC-contaminated soil situated below 4 ft. bgs;
hydraulic dredging of contaminated sediment with on-Site phytoremediation
on-Site reuse of treated soil and sediment; and
extraction of contaminated groundwater with on-Site treatment and discharge to
groundwater;
long-term groundwater monitoring; and
ICs to restrict groundwater use, prevent soil disturbances in the in-situ soil treatment
areas, and require that future buildings on the Site either be subject to a vapor
intrusion evaluation or be built with vapor intrusion mitigation systems until the
remediation goals are met.
The soils in the Active Process Area, Chemical Landfill/Gravel Pit, Inactive Process Area,
Northern Chemical Landfill, Stormwater Catchment Basin and Tank Farm/Train Loading
Area exposure areas with COC concentrations exceeding the remediation goals will be
excavated to a depth of 4 ft. bgs and treated with ex-situ bioremediation.16 The soils
situated below 4 ft. bgs in these exposure areas with COC concentrations exceeding the
remediation goals will be treated in-situ using enhanced biodegradation.
Additional sampling will be conducted during the remedial design to confirm the complete
delineation of benzene, cumene and colocated COCs in the on-Site soils prior to
remediation and to verify that no COCs are present in off-Site soils above the NJDEP
residential direct contact soil remediation standards.
The soil in the Township Refuse Area with lead concentrations exceeding the cleanup
value will be excavated. Additional delineation of the lead contamination in this area will
be performed during the remedial design.
A BMP plan will be developed and implemented to manage lead and minimize
contamination of the Shooting Range exposure area while the Shooting Range exposure
area continues to be used for its current purpose. If the current use of shooting range
ends or changes, delineation of the lead contamination will be performed and the soils
the in the Shooting Range exposure area with lead concentrations exceeding the
remediation goals will be excavated and disposed of off-Site.
The excavation will be performed using standard construction equipment, such as
backhoes and track excavators. An estimated 13,804 CY of contaminated soil will be
excavated, consisting of 1,052 CY of lead-contaminated soil and 12,752 CY of soil
contaminated with benzene, cumene and colocated COCs will be excavated.
16 Approximately 500 CY of the soils in the Active Process Area and Inactive Process Area
exceeding the cleanup values will be treated using enhanced in-situ biodegradation rather than
being excavated, because the presence of structures would make excavation impracticable.
34
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The excavated lead-contaminated soil will be transported to an off-Site treatment and/or
disposal facility.
The excavated soil containing benzene, cumene and colocated COC concentrations
above the remediation goals will be treated on-Site using ex-situ bioremediation.
Specifically, these soils will be mixed with soil amendments, formed into piles and
aerated, either passively or actively (using blowers or vacuum pumps). As part of the
remedial design, an analysis will be performed to confirm that the average VOC
concentrations that may be released from ex-situ treatment of the soils will not exceed
applicable state and federal air emissions standards. If air emissions controls are
determined to be necessary based upon these calculations, then those controls will be
included in the remedial design. In addition, vapors from the VOCs in the biopiles that
volatilize into the air will be monitored to protect Site workers and ensure that state and
federal air emission standards are not exceeded, and post-remedial sampling will be
conducted to ensure that the remediation goals are met.
Post-excavation sampling will be conducted to identify/confirm the areas where the
remediation goals are exceeded in the soils situated below 4 ft. bgs. These soils
(saturated and unsaturated) will be treated using enhanced in-situ biodegradation.
Enhanced in-situ biodegradation will involve injecting a magnesium sulfate solution into
the contaminated soils to stimulate activity and reproduction of naturally-occurring
anaerobic microorganisms. The microorganisms will then destroy or transform COCs into
less toxic compounds by using them as a food and energy source. Application of the
anaerobic treatment solution will be achieved using lateral infiltration galleries consisting
of perforated piping installed in a series of shallow trenches. The solution would be
applied directly to the base of the excavations in the Chemical Landfill/Gravel Pit,
Northern Chemical Landfill, Stormwater Catchment Basin and Tank Farm/Train Loading
Area exposure areas. Performance and compliance monitoring will be conducted to
determine residual contaminant concentrations and assess the need for additional
treatment.
The ex-situ-remediated soils will be reused on-Site, along with imported, certified clean
soil, meeting applicable state regulations, to backfill excavated areas and construct an
engineered soil cover in the Active Process Area, Inactive Process Area and the Tank
Farm/Train Loading Area to reduce infiltration of surface water to the groundwater, and
control surface water runoff/drainage. Vegetation will be placed in areas disturbed during
excavation activities to stabilize the soil and maintenance of the soil cover will be
performed.
The remedy will also include hydraulic dredging to remove a mixture of contaminated
sediment and water (referred to as slurry) from the bottom surfaces of the Stormwater
Catchment Basin and Clonmell Creek. It is estimated that 8,500 CY of contaminated
sediment will be removed; 1,225 CY from the Stormwater Catchment Basin and 7,275
CY from Clonmell Creek. These volumes represent the removal of 100 percent of the
cumene mass in the Stormwater Catchment Basin and approximately 99 percent of the
cumene mass within the Clonmell Creek sediment and include all the sediment posing a
risk to ecological receptors.
35
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The work area will be enclosed with silt curtains to prevent downstream migration of
contaminated sediment during dredging activities. Also, the surface water outside the
work area will be monitored to control resuspension and prevent downstream
transportation of contaminated sediments in the water column.
The slurry will be transferred via pipeline into geotextile tubes (located in a treatment cell
within the Stormwater Catchment Basin exposure area) for dewatering. The staging area
will be designed with proper controls, including but not limited to an impermeable liner, to
prevent any impacts to the surrounding soil and groundwater and maintain containment
of the dredged sediments and effluent water from the geotextile tubes. The effluent water
will be sampled and, if necessary, treated on-Site before being discharged to the
Stormwater Catchment Basin in accordance with substantive NJPDES discharge to
groundwater permit requirements. The details of the effluent treatment system will be
finalized during the remedial design. Monitoring of groundwater wells around the
Stormwater Catchment Basin will be conducted to ensure compliance with substantive
permit requirements.
Plants will be planted in the cumene-contaminated sediment within geotextile tubes for
a pre-determined growth period.17 The treated sediments will be reused on-Site as part
of an engineered soil cover to reduce infiltration of surface water to the groundwater, and
control surface water runoff/drainage, and the plant residuals will be harvested and
composted on-Site.
Under the groundwater component of this remedy, a new treatment unit will be built to
replace/upgrade the existing one and a small building will be constructed in the
Stormwater Catchment Basin exposure area to house the new treatment unit. The
existing extraction wells and subsurface pipelines will to be used to capture and carry
contaminated groundwater to the new treatment unit.
The extracted groundwater will be pumped into an equalization tank within the treatment
building and then treated with a polymer. The polymer will be combined with pH
adjustment, if necessary, to promote flocculation of iron and other solids in the
groundwater. The groundwater will then be pumped through conventional geotextile tubes
followed by GAC-impregnated geotextile tubes, if necessary, to remove iron, solids, and
treat COCs. The solids, flocculated iron and other metals, will be captured in the geotextile
tubes. The COCs will partition to the solids in the geotextile tubes where they will
biodegrade. The spent tubes will be transported off-Site to a permitted disposal facility.
The new system will have an approximate treatment capacity of 125 gallons per minute.
Treated water will be discharged to the groundwater in compliance with substantive
NJPDES discharge to groundwater permit requirements (using the Stormwater
Catchment Basin as an infiltration point). Long-term groundwater monitoring will be
continued until the remediation goals are met.
17 Additional studies would be conducted during the remedial design to refine plant species
selection and determine the optimal growth period.
36
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A CEA/WRA will be established to restrict groundwater use, and other ICs will restrict soil
disturbances in the in-situ treatment areas and require that future buildings on the Site
either be subject to a vapor intrusion evaluation or be built with vapor intrusion mitigation
systems until the remediation goals are met.
EPA anticipates that the remedy selected to address the source area and enhance the
groundwater treatment system will further reduce concentrations of benzene, cumene
and phenol in Site-related groundwater. This will result in reduced VOC concentrations
in the shallow (A-level) as well as intermediate (B-level)/deep (C-level) groundwater so
that current/future outdoor workers and construction/utility workers will no longer be at
risk for dermal contact with the shallow groundwater, and future on-Site residents will no
longer be at risk for direct contact with, or ingestion of, the intermediate/deep
groundwater. Continued groundwater monitoring will determine when remediation goals
have been achieved and the CEA/WRA will prevent exposure until that time.
Summary of the Estimated Selected Remedy Costs
The estimated total present-worth costs for the three components of the selected remedy
is $11,247,920. The cost estimates are based on available information and are order-of-
magnitude engineering cost estimates that are expected between +50 to -30 percent of
the actual project cost. Changes to the cost estimate can occur as a result of new
information and data collected during the design of the remedy.
Cost estimates for the soil, sediment and groundwater components of the selected
remedy are presented in Appendix II, Tables 14 through 17 of Appendix II. Individual cost
estimates for each remedial alternative evaluated are provided in Tables 3-1 through 3-5
and Table 4-2 of the FS report.
Expected Outcomes of the Selected Remedy
The selected remedy actively addresses VOC and lead contamination in the OU1 and
OU2 areas of the Site. The results of the risk assessment indicate excess cancer risk
from direct contact with COCs in the Site groundwater, noncancer health hazards
associated with future human ingestion of groundwater, the potential for unacceptable
on-Site blood lead levels, and risk to ecological receptors in Clonmell Creek and the
Stormwater Catchment basin from exposure to contaminated sediments. The response
action selected in this ROD will address the contaminated Site soils and sediments, and,
thereby, will eliminate the risks associated with these exposure pathways, facilitate the
commercial/industrial use of the Site property, and restore the groundwater to levels that
meet state and federal standards within a reasonable time frame, allowing it to be used
without restriction in approximately 10 years.
Remediation goals for the OU1/OU2 COCs are presented in Tables 11 through 13 of
Appendix II.
STATUTORY DETERMINATIONS
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
37
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balance of tradeoffs among the alternatives with respect to the balancing and modifying
criteria. These provisions require the selection of remedies that are protective of human
health and the environment, comply with ARARs (or justify a waiver from such
requirements), are cost effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that employ
treatment that permanently and significantly reduces the toxicity, mobility and volume of
hazardous substances as a principal element (or justifies not satisfying the preference).
The following sections discuss how the selected remedy meets these statutory
requirements.
Protection of Human Health and the Environment
The selected remedy will protect human health and the environment because it will
prevent human exposure to contaminated groundwater, soil and soil vapor and minimize
exposure of biota to contaminated sediments in the short term. Over the long term, the
selected remedy will restore groundwater to levels that meet state and federal standards
within a reasonable time frame. In addition, ICs will protect human health over both the
short and long term by preventing groundwater use and the disturbance of in-situ soil
treatment areas until remediation goals are met, as well as requiring any new construction
consider the vapor intrusion pathway. This action will result in the reduction of exposure
risk to levels within EPA's generally acceptable risk range of 10~4 to 10~6for carcinogens
and below a HI of 1.0 for noncarcinogens. Implementation of the selected remedy will not
pose unacceptable short-term risks.
Compliance with ARARs
The selected remedy is expected to achieve meet the remediation goals for COCs in the
soils, developed based on NJDEP's NRDCSRSs (chemical-specific ARARs) for the
COCs in the soils, and federal MCLs or more stringent NJDEP GWQSs (chemical-specific
ARARs) for the COCs in the groundwater. The remedy will comply with location- and
action-specific ARARs.
A full list of the ARARs, TBCs, and other guidance related to implementation of the
selected remedy is presented in Tables 18, 19 and 20 of Appendix II.
Cost Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness
(40 C.F.R. § 300.430(f)(1)(ii)(D)). Overall effectiveness is based on the evaluations of
long-term effectiveness and permanence, reduction in toxicity, mobility, and volume
through treatment, and short-term effectiveness. 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 cost 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
38
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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 $11,247,920.
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)(1)(ii)(D)) and is the least-cost action which will achieve remediation goals in
the Site soils and restore groundwater to levels that meet state and federal standards
within a reasonable time frame. A 15-year time frame for soil cap maintenance and
groundwater monitoring and a 10-year time interval for operation and maintenance of the
groundwater treatment system (the estimated time to meet the groundwater remediation
goals) was used for planning and estimating purposes, although remediation time frames
could exceed these estimates.
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 because it represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a practicable manner to remediate
the OU1 and OU2 areas. The selected remedy satisfies the criteria for long-term
effectiveness and permanence by permanently reducing the mass of contaminants in the
Site soils, sediments and groundwater, thereby reducing the toxicity, mobility and volume
of contamination.
Preference for Treatment as a Principal Element
Using in-situ biodegradation and ex-situ bioremediation and phytoremediation processes,
in conjunction with an ex-situ groundwater extraction and treatment technology, the
selected remedy satisfies the statutory preference for remedies that employ treatment as
a principal element.
Five-Year Review Requirements
Because the selected remedy results in contaminants remaining above levels that allow
for unrestricted use and unlimited exposure, CERCLA requires that the site be reviewed
at least once every five years.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for OU1 and OU2 was released to the public on July 29, 2018. The
Proposed Plan identified Alternatives S-3, SED-3, and GW-2 as the preferred alternatives
for remediating the contaminated soil, sediment, and groundwater, respectively, in the
OU1 and OU2 areas of the Site. Based upon review of the written and verbal comments
submitted during the public comment period, EPA determined that no significant changes
to the remedy, as originally identified in the Proposed Plan, were necessary or
appropriate.
39
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APPENDIX I
FIGURES
-------
Newtown
I Upper
Darby
i lansdowne
Yeadon
JSwarthmore
Glern^
Prosuse^ *
V^*rarkr-e5
Wationtt Wwtvttt*
Park
y ;/
Ttwrofare-iCc (£1)
2^r>sn
o o d hufV^j
Brookhaven
:l br
Gibbsto'
Paulsboro
Bridjjepo
^ \\ wan^ooro^ jj \ Rjickwood^
ePau^ Fairviaw
_ V alt SeT^Grenloc*
i22>.- Jr^fsFVR 13 _ V\ ₯ *Hurffv,lle,
\ ^ BarnsborK \T44W
3 Jefferson \J\ Whitnr
, I.Mu||,co Hl" 3X \ * Pitman qu
NortonvMe
«^PCer
/ Squat*
Penns
Grove
Aubun
551 *¦"
Rtchwood
^fcwan
ipvwatei^
Sharptown
Clayton
Godstow
WhitrT
* Pitman qu
MAP SOURCE: RAND McNALLY ROAD ATLAS 1995
NEW JERSEY
SCALE: MILES
FIGURE
SITE LOCATION MAP
CSI Environmental, LLC
401 Headquarters Dr Suite 203
Millersvitle, MD 21108
443-688-6453
Hercules, Inc. (Gibbstown Plant)
Gibbstown, New Jersey
-------
Be I aware
River
Paulsboro
Refinery
Solid Wastes
Disposal Area
EiuRont
Former
A|tive Plant
Area
- r
Athletic
Legend
Former Active Plant Area
Property Boundary
Solid Waste Disposal Area
Gibbstown
Elementary
ifeSisholoJH
0 250 500 1,000 1,500 2,000
-------
Figure 3: Exposure^rea Map
002 Outfall
~ . a*.}] )¦
Drainageway
aKfSform water
El Catchment
jffim Basin^
002 Outfall
Clonmell
Creek
Exposure Area Key
Local Roads
1.
Active Process Area (APA)
mm 2.
Area A / Open Area
I I 3.
Area B
Chemical Landfill/Gravel Pit Area (CLF/GP)
V//Z\ 5.
Clonmell and Wetlands (CCW)
I 6.
Inactive Process Area (IPA)
I I 7-
Northern Chemical Landfill Area (NCL)
I I 8-
Nothern Warehouse Area (NW)
9
Solid Waste Disposal Area (SWDA)
10.
Shooting Range
I 11-
Stormwater Catchment Basin Area (SCB)
^12
Tank Farm/Train Loading Area (TF/TLA)
V///A is.
Township Refuse Area (TRA)
0 250 500
2,000
-------
Figure 4: Areas Exceeding Rl Soil Screening Values
Active Process Area (APA)
Chemical Landfill/Gravel Pit Area (CLF/GP)
Northern Chemical Landfill Area (NCL)
Stormwater Catchment Basin Area (SCB)
^ Tank Farm/Train Loading Area (TF/TLA)
^ Township Refuse Area (TRA)
S z
-------
Chemical Landfill/Gravel Pit Area (CLF/GP)
Clonmell and Wetlands (CCW)
Inactive Process Area (IPA)
Northern Chemical Landfill Area (NCL)
Nothern Warehouse Area (NW)
Stormwater Catchment Basin Area (SCB)
^ Township Refuse Area (TRA)
__
-------
MW-34B'
>MW-34C
Figure 6: Site Well Location Map
1
»MW-:
0°:
MW-25C
c>
AO
Legend
Monitoring Wells
4- Extraction Wells
Local Roads
0 187.5 375
750
1,125
1,500
Feet
muz
-------
SE
Figure 7: Conceptual Site Model
NW
off-site well cluster
Ground Surface
Trenton Gravel
(A-Level)
Local Clay
Site Boundary
Residential Area
J.
On Site Pumping
^ Well System
To Treatment
System
Low K Silt, Clay, and Peat
B-Level/C-Level Divide
Upper Middle
PRM (B-Level)
Lower Middle
PRM (C-Level)
Red Clay
Lower PRM
Bedrock
Delaware River
Alluvial
PRM
Bedrock
Residential Area
"Red" Clay Underlying C-Level
Local Clay
Shallow Soil Trenton Gravel
Alluvium - Interbedded Clay. Sand and Silt
Contaminated Groundwater & Soil
Finer Sands and Silts Lower K
Coarse Sands Higher K
Groundwater
-------
Figure 8: Soil and Sediment Remediation Areas
-------
Figure 9: Conceptual Layout of Selected Remedy
APPROXIMATE
EXISTING
ELEVATION
(TYPICAL)
POTENTIAL
LOCATION FOR
SOIL COVER.
(WITH ELEVATION
CONTOURS)
POTENTIAL
SURFACE
WATER
RUNOFF
INLET
GRATE
LEGEND
NOT TO SCALE
= Approx. location of 500 year floodplain
= Approx. location of 100 year floodplain
= Approx. locations for surface water drainage improvements
-------
APPENDIX II
TABLES
-------
Table 1: Maximum Unsaturated Soil Concentrations (mg/kg)
Exposure Area
Benzene
Cumene
Active Process Area
58
17,000
Chemical Landfill/Gravel Pit
80
11,000
Inactive Process Area
27
2,500
Northern Chemical Landfill
0.55
1,295
Stormwater Catchment Basin
831
2,200
Tank Farm/Train Loading Area
1,292
35,439
-------
Table 2: Maximum Saturated Soil Concentrations (mg/kg)
Exposure Area
Benzene
Cumene
Active Process Area
4.8
200,000
Inactive Process Area
0
5,500
Northern Chemical Landfill
0
460
Stormwater Catchment Basin
130
1,700
Tank Farm/Train Loading Area
0.3
2,400
-------
Table 3: Maximum Groundwater Concentrations (fxg/L)
Exposure Area
Benzene
Cumene
Active Process Area
35,000
47,000
Stormwater Catchment Basin
160
130
Northern Chemical Landfill
200
30,000
-------
i
iltli- 4
Sum in.ir\ u| < Ikiiiu.iIs h| < uikmii ,iimI
Mi'diiim S|u-ulir 1- \|h
Mill' I'ullll <
iKiiiir.iiiuiis
Scenario Timeframe: Current/Future
Medium: A-Level Groundwater (Sitewide)
Exposure Medium: Groundwater
Exposure
Chemical of
Concentration
Detected
Concentration
Frequency of
Exposure Point
Exposure Point
Concentration
Units
Statistical
Point
Concern
Min
Max
Units
Detection
Concentration
Measure
Groundwater
Benzene
0.3
19,000
Hg/L
67/146
8662
Hg/L
95% Adj. Gamma UCL
Cumene
0.13
140,000
Hg/L
103/146
53,455
Hg/L
95% Chebyshev (Mean, SD) UCL
1 .ihlr 4
Simim.ii'x u| < Ik iiiu.iIs h| < <»iK-«.-rii .iimI
Medium S|u-ulir 1- \|»<
Mill' I'ullll <
IKi'llll'.lllullS
Scenario Timeframe: Future
Medium: B/C-Level Groundwater
(Active Process Area)
Exposure
Chemical of
Concentration
Detected
Concentration
Frequency of
Exposure Point
Exposure Point
Concentration
Units
Statistical
Point
Concern
Min
Max
Units
Detection
Concentration
Measure
Groundwater
Benzene
12
22,000
Hg/L
20/29
10,632
Hg/L
95% Chebyshev (Mean, SD) UCL
Cumene
0.44 J
47,000
Hg/L
22/29
36,548
Hg/L
95% Student's-tUCL
Phenolics
0.76
120,000
Hg/L
14/15
66,945
Hg/L
95% Adj. Gamma UCL
1 .ihlr 4
Simim.ii'x u| < lii-mii.ils u| < uikuii ;iikI
Mi'tliiim S|u-rilir 1- \|n
Mill' I'ullll <
IKTIlll'.ll|u||\
Scenario Timeframe: Future
Medium: B/C-Level Groundwater
(Northern Chemical Landfill)
Exposure
Chemical of
Concentration
Detected
Concentration
Frequency of
Exposure Point
Exposure Point
Concentration
Units
Statistical
Point
Concern
Min
Max
Units
Detection
Concentration
Measure
Groundwater
Benzene
74 J
190 JD
fig/L
3/3
190
Hg/L
MAX
Cumene
13,000
27,000 D
27,000
MAX
Table 4
Summary of Chemicals of Concern and
Medium-Specific Exposure Point Concentrations
Scenario Timeframe: Future
Medium: B/C-Level Groundwater
(Tank Farm/Township Refuse Area)
Exposure
Chemical of
Concentration
Detected
Concent ratio
n
Units
Frequency
Exposure Point
Exposure Point
Concentration
Units
Statistical
Point
Concern
Min
Max
of Detection
Concentration
Measure
Groundwater
Benzene
0.69 J
400
mg/L
20/46
250
mg/L
95% KM(t) UCL
Cumene
0.43 J
33,500
mg/L
36/46
28,640
mg/L
95% Chebyshev (Mean, SD)
UCL
Key:
MAX: Too few data points were available to calculate a meaningful UCL, so the maximum concentration was used to calculate risk
-------
Table 5
Selection of Exposure Pathways
Scenario
Medium
Exposure
Exposure
Receptor
Receptor
Exposure
Type of
Rationale for Selection or Exclusion
Timeframe
Medium
Point
Population
Aae
Route
Analvsis
of Exposure Pathway
Current/Future
Soil
Surface Soil
All Upland Exposure Areas
Outdoor Industrial
Adult
Incidental Ingestion
Quantitative
0 to 2 feet
Worker
Dermal Contact
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
assessment.
Inhalation of Particulates
Quantitative
Indoor Worker
Adult
Incidental Ingestion
None
Dermal Contact
None
Pathway incomplete. Worker assumed to spend entire work day indoors.
Inhalation of Volatile Emissions (Ambient Air)
None
Inhalation of Particulates
None
Construction/Utility
Adult
Incidental Ingestion
Quant
tative
Worker
Dermal Contact
Quant
tative
Potentially complete exposure pathway that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quant
tative
assessment.
Inhalation of Particulates
Quant
tative
T respasser
Adult/Youth
Incidental Ingestion
Quant
tative
Dermal Contact
Quant
tative
Potentially complete exposure pathway that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quant
tative
assessment.
Inhalation of Particulates
Quant
tative
Subsurface Soil
All Upland Exposure Areas
Outdoor Industrial
Adult
Incidental Ingestion
None
Worker
Dermal Contact
None
Pathway incomplete. Worker assumed to be limited to surface activities only.
2 to 10 feet
Inhalation of Volatile Emissions (Ambient Air)
None
Inhalation of Particulates
None
Indoor Worker
Adult
Incidental Ingestion
None
Dermal Contact
None
Pathway incomplete. Worker assumed to spend entire work day indoors.
Inhalation of Volatile Emissions (Ambient Air)
None
Inhalation of Particulates
None
Construction/Utility
Adult
Incidental Ingestion
Quantitative
Worker
Dermal Contact
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
assessment.
Inhalation of Particulates
Quantitative
T respasser
Adult/Youth
Incidental Ingestion
None
Dermal Contact
None
Pathway incomplete. Trespasser assumed to be limited to surface activities
Inhalation of Volatile Emissions (Ambient Air)
None
only.
Inhalation of Particulates
None
-------
Table 5
Selection of Exposure Pathways
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Aae
Exposure
Route
Type of
Analvsis
Rationale for Selection or Exclusion
of Exposure Pathway
Current/Future
Groundwater
Shallow
All Upland Exposure Areas
Outdoor Industrial
Adult
Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment.
A-Level
Worker
Dermal Contact
Quantitative
Groundwater
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
Indoor Worker
Adult
Ingestion
None
Pathway incomplete. Worker assumed to spend entire work day indoors, and
groundwater is not used as a potable water source.
Dermal Contact
None
Inhalation of Volatile Emissions (Ambient Air)
None
Construction/Utility
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment.
Worker
Dermal Contact
Quantitative
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
T respasser
Adult/Youth
Ingestion
None
Pathway incomplete. Trespasser assumed to be limited to surface activities
only.
Dermal Contact
None
Inhalation of Volatile Emissions (Ambient Air)
None
Hypothetical
Adult/Child
Ingestion
None
Groundwater in the "A" Zone is too shallow to be used as a potable water
source.
Onsite
Dermal Contact
None
Resident
Inhalation of Volatile Emissions (Ambient Air)
None
Deep
All Upland Exposure Areas
Outdoor Industrial
Adult
Ingestion
None
Pathway incomplete. Direct contact unlikely due to depth of "B/C" zone
groundwater.
B/C-Level
Worker
Dermal Contact
None
Groundwater
Inhalation of Volatile Emissions (Ambient Air)
None
Indoor Worker
Adult
Ingestion
None
Pathway incomplete. Worker assumed to spend entire work day indoors, and
groundwater is not used as a potable water source.
Dermal Contact
None
Inhalation of Volatile Emissions (Ambient Air)
None
Construction/Utility
Adult
Incidental Ingestion
None
Pathway incomplete. Direct contact unlikely due to depth of "B/C" zone
groundwater.
Worker
Dermal Contact
None
Inhalation of Volatile Emissions (Ambient Air)
None
T respasser
Adult/Youth
Ingestion
None
Pathway incomplete. Trespasser assumed to be limited to surface activities
only.
Dermal Contact
None
Inhalation of Volatile Emissions (Ambient Air)
None
Hypothetical
Adult/Child
Ingestion
Quantitative
Hypothetical onsite adult/child resident is evaluated for a hypothetical drinking
water scenario only. The inhalation of volatiles from showering/bathing will be
discussed qualitatively. Acknowledgement will be made that if the ingestion
scenario is unacceptable, the shower scenario would also be unacceptable.
Onsite
Dermal Contact
Qualitative
Resident
Inhalation of Volatile Emissions (Ambient Air)
Qualitative
-------
Table 5
Selection of Exposure Pathways
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Aae
Exposure
Route
Type of
Analvsis
Rationale for Selection or Exclusion
of Exposure Pathway
Current/Future
Indoor Air
(Vapor Intrusion
from the
Subsurface)
Indoor Air
Area-Specific Buildings
Outdoor Industrial
Worker
Adult
Inhalation of Volatile Emissions (Indoor Air)
None
Pathway incomplete. Worker assumed to spend entire work day outdoors.
Indoor Worker
Adult
Inhalation of Volatile Emissions (Indoor Air)
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment.
Construction/Utility
Worker
Adult
Inhalation of Volatile Emissions (Indoor Air)
None
Pathway incomplete. Worker assumed to spend entire work day outdoors.
T respasser
Adult/Youth
Inhalation of Volatile Emissions (Indoor Air)
None
Pathway incomplete. Trespasser assumed to spend entire exposure duration
outdoors.
Surface
Surface Water
Inactive Process Area Pond
Outdoor Industrial
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment.
Water
Worker
Dermal Contact
Quantitative
SCB, SDB, and associated
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
drainage ways
Indoor Worker
Adult
Incidental Ingestion
None
Dermal Contact
None
Pathway incomplete. Worker assumed to spend entire work day indoors.
Inhalation of Volatile Emissions (Ambient Air)
None
Construction/Utility
Adult
Incidental Ingestion
None
Potentially complete exposure pathway that will not be quantitatively
Worker
Dermal Contact
None
evaluated in the risk assessment because a more frequently exposed receptor
(i.e., outdoor worker) is already being considered.
Inhalation of Volatile Emissions (Ambient Air)
None
T respasser
Adult/Youth
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
Sediment
Sediment
Inactive Process Area Pond
Outdoor Industrial
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
Worker
Dermal Contact
Quantitative
assessment.
SCB, SDB, and associated
Indoor Worker
Adult
Incidental Ingestion
None
Pathway incomplete. Worker assumed to spend entire work day indoors.
drainage ways
Dermal Contact
None
Construction/Utility
Adult
Incidental Ingestion
None
Potentially complete exposure pathway that will not be quantitatively
evaluated in the risk assessment because a more frequently exposed receptor
(i.e., outdoor worker) is already being considered.
Worker
Dermal Contact
None
T respasser
Adult/Youth
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
Dermal Contact
Quantitative
assessment.
Current/Future
Soil
Wetland Soil
Wetland Area
Recreational Youth
Youth
Incidental Ingestion
Quantitative
6 to 18
Dermal Contact
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
assessment.
Inhalation of Particulates
Quantitative
Adult Recreational
Adult
Incidental Ingestion
Quantitative
Hiker
Dermal Contact
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
assessment.
Inhalation of Particulates
Quantitative
T respasser
Adult
Incidental Ingestion
Quantitative
Youth (6 to 18)
Dermal Contact
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
assessment.
Inhalation of Particulates
Quantitative
Recreational Hunter
Adult
Incidental Ingestion
Qualitative
A qualitative assessment will be included in the risk assessment because the
adult recreational hiker; who has the same exposure pathways, is already
being considered.
Dermal Contact
Qualitative
Inhalation of Volatile Emissions (Ambient Air)
Qualitative
Inhalation of Particulates
Qualitative
-------
Table 5
Selection of Exposure Pathways
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Aae
Exposure
Route
Type of
Analvsis
Rationale for Selection or Exclusion
of Exposure Pathway
Recreational Angler
Adult
Incidental Ingestion
Qualitative
Potentially complete exposure pathways that will not be quantitatively
evaluated in the risk assessment. Since these individuals have to walk
through the wetlands to get to Clonmell Creek, storm water runoff and surface
water drainage to wetland soils will be evaluated qualitatively.
Dermal Contact
Qualitative
Inhalation of Volatile Emissions (Ambient Air)
Qualitative
Inhalation of Particulates
Qualitative
Surface
Water
Surface Water
Clonmell Creek
Recreational Youth
Youth
6 to 18
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
Adult Recreational
Hiker
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
T respasser
Adult
Youth (6 to 18)
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Inhalation of Volatile Emissions (Ambient Air)
Quantitative
Recreational
Angler
Adult
Incidental Ingestion
Qualitative
Potentially complete exposure pathways that will not be quantitatively
evaluated in the risk assessment because the adult recreational hiker; who
has the same exposure pathways, is already being considered.
Dermal Contact
Qualitative
Inhalation of Volatile Emissions (Ambient Air)
Qualitative
Current/Future
Sediment
Sediment
Clonmell Creek
Recreational Youth
6 through 18
Youth
6 to 18
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Adult Recreational
Hiker
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
T respasser
Adult
Youth (6 to 18)
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be evaluated in the risk
assessment.
Dermal Contact
Quantitative
Recreational
Angler
Adult
Incidental Ingestion
Qualitative
Potentially complete exposure pathways that will not be quantitatively
evaluated in the risk assessment because the adult recreational hiker; who
has the same exposure pathways, is already being considered.
Dermal Contact
Qualitative
Game
Game
(Deer, Rabbits)
Wetland Area
Recreational Hunter
Adult
Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment if bioaccumulative COC are identified.
Fish
Fish Tissue
Clonmell Creek
Recreational Angler
Adult
Ingestion
Quantitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment if bioaccumulative COC are identified.
Current/Future
Indoor Air
(Vapor Intrusion
from
Groundwater)
Indoor Air
Offsite Residence
Adult Resident
Adult
Inhalation of Volatile Emissions (Indoor Air)
None
Potential migration of groundwater offsite and subsequent vapor intrusion into
an offsite residence was addressed in a separate vapor intrusion investigation
which concluded that an unacceptable risk from exposure to site-related
volatile contaminants via this pathway does not exist.
Youth Resident
Youth
6 to 18
Inhalation of Volatile Emissions (Indoor Air)
None
Child Resident
Child
0 to 6
Inhalation of Volatile Emissions (Indoor Air)
None
Game
Game
(Deer, Rabbits)
Offsite Residents
Adult Resident
Adult
Ingestion
Qualitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment if bioaccumulative COC are identified. This is based on the
assumption that the adult hunter would provide recreationally caught meals to
their family. Only the child is evaluated quantitatively because a recreational
adult hunter is already evaluated for the Wetland Area.
Youth Resident
Youth
6 to 18
Ingestion
Qualitative
Child Resident
Child
0 to 6
Ingestion
Quantitative
Fish
Fish Tissue
Offsite Residents
Adult Resident
Adult
Ingestion
Qualitative
Potentially complete exposure pathway that will be evaluated in the risk
assessment if bioaccumulative COC are identified. This is based on the
assumption that the adult angler would provide recreationally caught meals to
their family. Only the child is evaluated quantitatively because a recreational
adult angler is already evaluated for Clonmell Creek.
Youth Resident
Youth
6 to 18
Ingestion
Qualitative
Child Resident
Child
0 to 6
Ingestion
Quantitative
-------
Table (>
\mi-C anier Ti>\ii il\ Diilii Siimman
Pathway: Dermal contact with A-Level Groundwater
Chemicals
of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Absorp.
Efficiency
(Dermal)
Adjusted
RfD
(Dermal)
Adj. Dermal
RfD Units
Primary
T arget
Organ
Combined
Uncertainty
/Modifying
Factors
Sources
of RfD Target
Organ
Dates of
RfD
Benzene
Chronic
4.00E-03
mg/kg-day
1
4.00E-03
mg/kg-day
blood, immune
system
300
IRIS
2015
Cumene
Chronic
0.1
mg/kg-day
1
0.1
mg/kg-day
kidney
1000
IRIS
2015
Pathway: Ingestion of B/C- Level groundwater as Drinking water
Chemicals
of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Absorp.
Efficiency
(Dermal)
Adjusted
RfD
(Dermal)
Adj. Dermal
RfD Units
Primary
T arget
Organ
Combined
Uncertainty
/Modifying
Factors
Sources
of RfD Target
Organ
Dates of
RfD
Benzene
Chronic
4.00E-03
mg/kg-day
1
4.00E-03
mg/kg-day
blood, immune
system
300
IRIS
2015
Cumene
Chronic
0.1
mg/kg-day
1
0.1
mg/kg-day
kidney
1000
IRIS
2015
Phenolics, Total Recoverable (1)
Chronic
0.3
mg/kg-day
1
0.3
mg/kg-day
whole body,
fetus
300
IRIS
2015
Key
mg/kg-day: milligram per kilogram-day
1. Toxicity values for total recoverable phenolics are based on the values for phenol.
-------
Table 7
Cancer Toxicity Data Summary
Pathway: Dermal Contact with A-Level Groundwater
Chemical of Concern
Oral Cancer
Slope Factor
Units
Adjusted
Cancer Slope
Factor
(for Dermal)
Slope Factor
Units
Weight of
Evidence/
Cancer
Guideline
Source
Date
Benzene
0.055
(mg/kg-dy1
0.055
(mg/kg-dy1
A
IRIS
2015
Pathway: Ingestion of B/C-Level Groundwater as Drinking Water
Chemical of Concern
Oral Cancer
Slope Factor
Units
Adjusted
Cancer Slope
Factor
(for Dermal)
Slope Factor
Units
Weight of
Evidence/
Cancer
Guideline
Source
Date
Benzene
0.055
(mg/kg-d)"1
0.055
(mg/kg-d)"1
A
IRIS
2015
Key:
1 per milligram per killigram-day or 1/(milligram per killigram-day)
IRIS: Integrated Risk Information System
Weight of Evidence definitions:
A: Human carcinogen
B1: Probable human carcinogen - Indicates that limited human data are available
B2: Probable human carcinogen - Indicates sufficient evidence in animals and inadequate or no evidence in humans
C: Possible human carcinogen
D: Not classifiable as a human carcinogen
E: Evidence of noncarcinogenicity
Cancer Toxicity Data Summary
While PCBs may be carcinogenic, they did not pose an unacceptable carcinogenic risk via any of the exposure pathways evaluated
-------
Table 8
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Outdoor Industrial Workers
Receptor Age: Adult
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Primary
target Organ
Non
-Carcinonenic Ha7ard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
A-Level Groundwater
(Sltewlde)
Groundwater
Groundwater
Benzene
Immunological
8.3E-01
8.8E-01
2.2
3.9
Cumene
Urinary
2.1E-01
3.9E-01
3.6
4.3
Scenario Timeframe: Current/Future
Receptor Population: Construction/Utility workers
Receptor Age: Adult
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Primary
target Organ
Non
-Carcinoa
nic Hazar
i Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
A-Level Groundwater
(Sltewlde)
Ggroundwater
Groundwater
Benzene
Immunological
1.5E-01
8.4E-01
3.9E-01
1.4
Cumene
Urinary
3.7E-02
3.1E-01
6.5E-01
1.0
Table 8
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: On-Slte residents
Receptor Age: Adult
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Primary
target Organ
Non
-Carcinonenic Ha7ard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
B/C-Level Groundwater
(Active Process Area)
Groundwater
Drinking Water
Benzene
Immunological
79.6
79.6
Cumene
Urinary
11
11
Phenolics
Other
(decreased
maternal
weight gain)
6.7
6.7
Scenario Timeframe: Future
Receptor Population: On-Site Residents
Receptor Age: Child (2 - <6)
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Primary
target Organ
Non
-Carcinoa
nic Hazar
i Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
B/C- Level groundwater
(Active Process Area)
Groundwater
Drinking Water
Benzene
Immunological
133
133
Cumene
Urinary
18.2
18.2
Phenolics
Other
(decreased
maternal
weight gain)
11.1
11.1
Table 8
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: On-Site Residents
Receptor Age: Child (0 - <2)
Medium
Exposure Medium
Exposure Point
Chemical Of
Concern
Primary
target Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
B/C-Level Groundwater
(Active Process Area)
Groundwater
Drinking Water
Benzene
Immunological
133
133
Cumene
Urinary
18.2
18.2
Phenolics
Other
(decreased
maternal
weiaht aain)
11.1
11.1
Key:
-: No available data
-------
Table 9
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Outdoor Industrial Workers
Receptor Age: Adult
Medium
Exposure Medium
Exposure Point
Chemical Of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure
Routes
A-Level Groundwater
(Sitewide)
Groundwater
Groundwater
Benzene
6.60E-05
7.40E-05
1.70E-04
3.10E-04
Scenario Timeframe: Future
Receptor Population: On-Site Residents
Receptor Age: Lifetime
Medium
Exposure Medium
Exposure Point
Chemical Of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure
Routes
B/C zone groundwater (Active
Process Area)
Groundwater
Drinking Water
Benzene
7.5E-03
-
-
7.5E-03
Scenario Timeframe: Future
Receptor Population: On-Site Residents
Receptor Age: Lifetime
Medium
Exposure Medium
Exposure Point
Chemical Of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure
Routes
B/C-Level Groundwater
(Northern Chemical Landfill)
Groundwater
Drinking Water
Benzene
1.3E-04
-
-
1.3E-04
Scenario Timeframe: Future
Receptor Population: On-Site Residents
Receptor Age: Lifetime
Medium
Exposure Medium
Exposure Point
Chemical Of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure
Routes
Total
B/C- Level Groundwater
(Tank Farm/
Township Refuse Area)
Groundwater
Drinking Water
Benzene
1.8E-04
-
-
1.8E-04
Key:
-: No available data
-------
Table 10
Adult Lead Model
Scenario Time
Frame
Receptor Population
Exposure Area
Model Output
Categories
Lead Concentration
Soil
(mg/kg)
Estimated Adult
Blood Lead
Concentrations
(ug/dL)1
Estimated Fetal
Blood
Concentrations
(^g/dL)1
Current/Future
Outdoor Industrial Worker
Shooting Range
Incidental
Ingestion of Soil
1620
13.2
11.8
Township Refuse
Area
Incidental
Ingestion of Soil
758
7.0
6.3
Current/Future
Construction/Utility
Worker
Shooting Range
Incidental
Ingestion of Soil
1620
19.1
17.2
Township Refuse
Area
Incidental
Ingestion of Soil
758
8.8
7.9
Key
mg/kg = milligram per kilogram
jjg/dL = microgram per deciliter
1 Target blood lead level of concern = 5 |jg/dl_
Bold indicates value exceeds 5 mg/dL
-------
Table 11: Remediation Goals for Saturated and Unsaturated Soil
COCs
Saturated Soil Remediation Goal1
(mg/kg)
Source1
Unsaturated Soil Remediation Goal2
(mg/kg)
Acetophenone
5
NJDEP NRDCSRS
3
Benzene
5
NJDEP NRDCSRS
0.005
Cumene
990
EPA RSL Industrial
28
Ethylbenzene
25
EPA RSL Industrial
13
Lead
800
NJDEP NRDCSRS
90
Phenol
25000
EPA RSL Industrial
8
Toluene
4700
EPA RSL Industrial
7
Notes:
1From Derivation of Screening Values Benchmark Table memo for the Former Hercules Higgins Plant. CSI Environmental, 2017.
The soil screening level represents the lowest of the EPA Regional Screening Level for Industrial Soil and the NJDEP NRDCSRS.
The screening levels utilize a cancer risk level of 10 s or noncancer Hl=0.1 to account for addictive effects to a target.
2See Table 12 for calculation details
EPA RSL Industrial = USEPA Regional Screening Level Summary Table, May 2016 (value for industrial soil)
NJDEP NRDCSRS = New Jersey DEP Non Residential Direct Contact Soil Remediation Standard, NJAC 7:26D Appendix 1 Soil
Remediation Standards Table
-------
Table 12: Calculated and NJDEP Impact to Groundwater Soil Screening Levels
COCs
Calculated IGW Soil
Remediation
Standard1 (mg/kg)
Health based Ground Water Quality
Criteria used to back calculate IGW
Soil Remediation Standard2 (ng/L)
Default IGW Soil
Remediation
Standard3 (mg/kg)
5
O)
o
Source
Acetophenone
3
700
NJDEP GW Quality criteria
3
Benzene
0.006
1
NJDEP GW Quality criteria
0.005*
Cumene
28
700
NJDEP GW Quality criteria
not listed
Ethylbenzene
13
700
EPA MCL
13
Lead
90
5
NJDEP GW Quality criteria
90
Phenol
8
2000
NJDEP GW Quality criteria
8
Toluene
11
600
NJDEP GW Quality criteria
7
Notes:
Calculated using NJDEP Soil Water Partition Equation Calculator v2.1, November 2013.
2 If USEPA National Primary Drinking Water Regulation Maximum Contaminant Level (MCL) was not available,
NJDEP ground water quality standard was used http://www.nj.gov/dep/srp/guidance/rs/partition_equation.xls
3Source: Guidance Document, Development of Impact to Ground Water Soil Remediation Standards Using the
Soil Water Partition Equation, NJDEP, 2013.
Default values are based on NJDEP GW Quality criteria. Cgw is groundwater concentration in the soil water partion equation.
Default dilution attenuation factor (DAF) = 20 was used in calculation.
*Remediation standard set to Practical Quantification Limit (PQL)
-------
Table 13 : Remediation Goals for Groundwater
COC
Remediation Goal2 (mg/L)
Source3
Acetophenone
700
NJDEP GWQS
Benzene
1
NJDEP GWQS
Cumene
700
NJDEP GWQS
Ethylbenzene
700
EPA MCL and NJDEP GWQS
Lead
5
NJDEP GWQS
Phenolics, Total Recoverable
2000
* NJDEP GWQS - Phenol
Toluene
600
NJDEP GWQS
Notes:
1. mg/L = micrograms per liter
2. From Derivation of Screening Values Benchmark Table memo for the Former Hercules Higgins Plant. CSI
Environmental, 2017. The groundwater screening level represents the lowest of the EPA MCL and the
NJDEP Groundwater Quality Standards. If no value could be found, a surrogate was selected and the
appropriate screening value was selected (see Derivation of Supplemental Screening Values Technical
Memo, RBR 2017).
3. * Value represents a surrogate screening level (see Derivation of Supplemental Screening Values
Technical Memo, RBR 2017)
-------
Table 14: Cost Estimate for Soil Alternative S-3
Excavation with Ex-situ Bioremediation/Reuse and Enhanced In-Situ Biodegradation
Item
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS (Ex-Situ Treatment)
Site Preparation
Mobilization
1.00
LS
$ 50,000
$ 50,000
Health and Safety Plan
1.00
LS
$ 5,000
$ 5,000
$ 55,000
Land clearing - Light vegetation
Clear And Grub Light Trees, Cut And Chip
3.48
acre
$ 5,000
$ 17,413
Haul to stockpile location onsite
557
loose CY
$4.00
$2,229
$ 19,642
Surveying
1
LS
$ 3,000
$ 3,000
$ 3,000
Sediment Control - Silt fencing
3,000
ft
$5.00
$ 15,000
$ 15,000
Excavate and Haul to Stockpile Onsite
Excavate and Load
13,804
bank CY
$4.00
$55,216
Haul to stockpile location onsite (2km, 26 CY Off
Highway Truck)
17,945
loose CY
$4.00
$71,781
$ 126,997
Backfill
Unclassified Fill dirt (delivered)
20,706
loose CY
$ 30.00
$621,180
Place fill dirt
20,706
loose CY
$3.00
$62,118
Grading, compaction
8,846
SY
$3.81
$ 33,705
Screened Topsoil (delivered)
1,917
loose CY
$ 35.00
$ 67,085
Spread Topsoil
1,917
loose CY
$6.00
$ 11,500
HydroSeeding/vegetation
79,617
SF
$0.15
$ 11,943
$ 807,530
Onsite Disposal of Soil - Biopiles/Landfarming
Biopile Treatment
16,578
loose CY
$ 65.00
$ 1,077,544
Landfarming
0
CY
$ 85.00
$0
$ 1,077,544
Onsite Disposal of Heavy Metals Soils
Phytoremediation
0
CY
$ 479.00
$0
$0
Offsite Disposal of Heavy Metals Soils
Loading (soils)
1,368
loose CY
$4.00
$ 5,470
Haul (6 miles; 16.5 CY trucks)
1,368
loose CY
$9.00
$ 12,308
Tipping fee, Hazardous Waste Landfill
2,031
ton
$ 240.00
$487,413
Laboratory analysis (landfill requirement)
1
LS
$ 1,000
$ 1,000
$ 506,191
TOTAL DIRECT CAPITAL COSTS
$2,610,904
INDIRECT CAPITAL COSTS
Contingency (10% +/-)
$261,090
Engineering (10% +/-)
$261,090
Administration (5% +/-)
$130,545
TOTAL INDIRECT CAPITAL COSTS
$652,726
TOTAL CAPITAL COSTS (Page 1)
$3,263,629.81
-------
Table 14: Cost Estimate for Soil Alternative S-3
Excavation with Ex-situ Bioremediation/Reuse and Enhanced In-Situ Biodegradation
Item
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS (Engineered Soil Cover)
Site Preparation
Mobilization
1
LS
$ 50,000
$ 50,000
Health and Safety Plan
1.00
LS
$ 5,000
$ 5,000
$ 55,000
Land Clearing - Light Vegetation
Clear And Grub Light Trees, Cut And Chip
15.00
acre
$ 10,000
$ 150,000
On-Site Composting
4
acre
$ 2,500
$ 10,000
$ 160,000
Surveying
1
LS
$ 7,500
$ 7,500
$ 7,500
Sediment Control - Silt Fencing
6,000
ft
$4.00
$ 24,000
Modify (Raise Well Infrastucture)
Grading, compaction, sump, gravity drain
1
LS
150,000
$ 150,000
$ 150,000
Excavate and Haul to Clean Soil Cover
Excavate and Load
14,000
solids CY
$3.00
$ 42,000
Haul to stockpile location onsite (2km, 26 CY Off Highway Truck)
14,000
solids CY
$3.00
$ 42,000
$ 84,000
Clean Soil Cover (Assume 25,000 CY)
Place Treated Solids
14,000
CY
$3.00
$ 42,000
Unclassified Fill dirt (delivered)
4,000
loose CY
$ 30.00
$ 120,000
Place fill dirt
4,000
loose CY
$3.00
$ 12,000
Grading, compaction (treated & fill dirt)
18,000
SY
$3.50
$ 63,000
Screened Topsoil (delivered)
7,000
loose CY
$ 50.00
$ 350,000
Spread Topsoil (as needed)
7,000
loose CY
$4.03
$28,210
HydroSeeding/vegetation (soil cover & excavation areas)
784,617
SF
$0.15
$ 117,693
$ 690,903
TOTAL DIRECT CAPITAL COSTS
$ 1,147,403
INDIRECT CAPITAL COSTS
Contingency (15% +/-)
$172,110
Engineering, assumed only grading needed for SW drainage improvements (20% +/-)
$229,481
Administration (5% +/-)
$57,370
TOTAL INDIRECT CAPITAL COSTS
$458,961
TOTAL CAPITAL COSTS (Page 2)
$ 1,606,364
-------
Table 14: Cost Estimate for Soil Alternative S-3
Excavation with Ex-situ Bioremediation/Reuse and Enhanced In-Situ Biodegradation
Item
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS (Anaerobic Injections)
Site Preparation
Mobilization/Site Preparation
1.00
LS
$7,500
$7,500
Health and Safety Plan
1.00
LS
$5,000
$5,000
Erosion/Sediment/Dust Control
1.00
LS
$5,000
$5,000
Clear and Grub
5.00
ACRE
$4,000
$20,000
Subtotal
$37,500
Trench Installation
Trench Installations
25.00
ea
$3,000
$75,000
Injection Permit
1.00
Is
$15,000
$15,000
$90,000
System Installation
Mixing Equipment and Vessels
1.00
Is
$15,000
$15,000
Transfer Equipment (pumps, hoses, etc)
1.00
Is
$10,000
$10,000
Trenching and Piping (with control valves)
1.00
Is
$60,000
$60,000
Utility Connections
1.00
Is
$50,000
$50,000
Subtotal
$135,000
TOTAL DIRECT CAPITAL COSTS
$262,500
INDIRECT CAPITAL COSTS
Contingency (10% +/-)
$26,250
Engineering (10% +/-)
$26,250
Administration (5% +/-)
$13,125
TOTAL INDIRECT CAPITAL COSTS
$65,625
CAPITAL COSTS SENA SUBTOTAL (Page 3)
$328,125
CAPITAL COSTS SUBTOTAL (Page 2)
$1,606,364
CAPITAL COSTS SUBTOTAL (Page 1)
$3,263,630
TOTAL CAPITAL COSTS
$5,198,118.56
ANNUAL O&M COSTS - Anaerobic Iniections
$185,300.00
Present Worth - 5 years at 7%
$759,766.58
ANNUAL O&M COSTS - ENG. SOIL COVER
$20,000.00
Present Worth - 30 years at 7%
$248,180.80
ANNUAL O&M COSTS - SOIL EXCAVATION & DISPOSAL
$0.00
Present Worth - N/A
$0.00
TOTAL O&M PRESENT WORTH COST
$1,007,947.38
TOTAL ESTIMATED REMEDIAL COST
$6,206,065.94
-------
Table 15: Cost Estimate for Sediment Alternative SED-3
Hydraulic Dredging with On Site Treatment/Reuse
Item
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS
Site Preparation
Mobilization
1.00
LS
$ 60,000
$60,000
Health and Safety Plan
1.00
LS
$5,000
$ 5,000
$ 65,000
Land Clearing - Light vegetation
3.50
acre
$5,000
$ 17,500
Topsoil and liqht vegetation composted
1.00
LS
$2,500
$ 2,500
$ 20,000
Surveying
1
LS
$3,000
$ 3,000
$ 3,000
Sediment Control - Silt fencing
4,000
ft
$4.00
$ 16,000
$ 16,000
Dewatering Cell Construct
Grading, compaction, sump, gravity drain
4
acre
7,500
$ 30,000
30 milliliter liner
2
acre
$60,000.00
$ 120,000
$ 150,000
Materials
Geotextile Tubes (100 ft x 90 ft)
18
Tube
$4,500
$81,000
Polymer + Coagulant
1
LS
$ 36,000.00
$ 36,000
Double wall HDPE Transmission Piping
1
LS
$ 64,800.00
$ 64,800
Fittings, Hardware, Valves, Fuel
1
LS
$ 64,500.00
$ 64,500
Hydraulically Dredge Sediments
Dredge SCB + Clonmell Triad Risk Seds
8,500
CY
$72.00
$612,000
Manage Dewatering Cell
8,500
CY
$4.00
$ 34,000
$ 892,300
OnSite Treatment of Sediments
Phytoremediation
1
LS
$ 150,000.00
$ 150,000
Phyto monitoring, nutrients augmentation
1
LS
$25,000.00
$25,000
Laboratory analysis (landfill requirement)
1
LS
$7,500
$ 7,500
$ 182,500
TOTAL DIRECT CAPITAL COSTS
$ 1,328,800
INDIRECT CAPITAL COSTS
Contingency (20% +/-) Reduce Contingency from
Pilot Test
$265,760
Engineering (15% +/-)
$199,320
Administration (5% +/-)
$66,440
TOTAL INDIRECT CAPITAL COSTS
$531,520
TOTAL CAPITAL COSTS
$ 1,860,320
-------
Table 16: Cost Estimate for Groundwater Alternative GW-2
Extraction with On-Site Treatment and Long-Term Monitoring
Item1
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS
Site Preparation
Mobilization/Site Preparation
1.00
LS
$2,500
$2,500
Health and Safety Plan
1.00
LS
$5,000
$5,000
Erosion/Sediment/Dust Control
1.00
LS
$5,000
$5,000
Clear and Grub (Already Incl.)
0.50
ACRE
$4,000
$2,000
Well Point System Startup-not required
1.00
LS
$0
$0
Subtotal
$14,500
Outfall Construction for:
1.00
LS
$75,000
$75,000
Discharge to Groundwater at SCB and Tube
La yd own
Subtotal
$75,000
Purchased Treatment Plant Equipment (E)
GW Recovery Pump (20 gpm)-existing wells
0.00
EA
$2,500
$0
Equalization Tank (1,000 gallons)
0.00
EA
$1,250
$0
Clarifier Feed Pump (25 gpm)
0.00
EA
$1,250
$0
Mix Tank (1000 gallons)
0.00
EA
$1,250
$0
Clarifier (50 gpm)-slant tray
0.00
EA
$9,500
$0
Lime Feed System
0.00
LS
$6,250
$0
Chemical Feed Systems
0.00
LS
$5,000
$0
Filter Feed Sump Tank (1000 gallons)
0.00
EA
$1,250
$0
Filter Feed Pump (50 gpm)
0.00
EA
$12,500
$0
Sand Filter Rehab
0.00
EA
$9,500
$0
Treated Water Tank (1000 gallons)
0.00
EA
$1,250
$0
Backwash Pump (100 gpm)
0.00
EA
$2,500
$0
Sludge Transfer System-not required
1.00
EA
$0
$0
Sludge Thickener-not required
1.00
EA
$0
$0
Decant Pump (50 gpm)-not required
1.00
EA
$0
$0
Filter Press (.5 ton/day)-not required
1.00
EA
$0
$0
Geotubes and Polymer
1.00
EA
$30,000
$30,000
Computerized/automated polymer system
1.00
EA
$50,000
$50,000
Pad/Building Construction
1.00
LS
$25,000
$25,000
Replenish Carbon for Existing Carbon Units
0.00
LS
$15,000
$0
Subtotal (E)
$105,000
Treatment Plant Components
% of(E)
Installation
15.00%
$15,750
Instrumentation and Controls
10.00%
$10,500
Piping
15.00%
$15,750
Electrical
20.00%
$21,000
Building and Site Improvements
15.00%
$15,750
Services/Utilities
10.00%
$10,500
Subtotal
$89,250
VOC Pretreatment (MW-11)
Recovery Well with pump
0.00
EA
$5,000
$0
Air Stripper with sump tank and pump
0.00
EA
$30,000
$0
Piping
0.00
LF
$30
$0
Electrical
0.00
LS
$5,000
$0
Pad/Building
0.00
LS
$25,000
$0
Subtotal
$0
-------
Table 16: Cost Estimate for Groundwater Alternative GW-2
Extraction with On-Site Treatment and Long-Term Monitoring
Item1
Quantity
Units
Unit Cost
Extended Cost
Total Cost
Discharge
Piping
800.00
FT
$30
$24,000
Earthwork
1.00
ACRE
$7,500
$7,500
Piping End Treatments-included
1.00
EA
$0
$0
Subtotal
$31,500
TOTAL DIRECT CAPITAL COSTS
$315,250
INDIRECT CAPITAL COSTS
Contingency (15% +/-)
$47,288
Engineering (10% +/-)
$31,525
Administration (5% +/-)
$15,763
TOTAL INDIRECT CAPITAL COSTS
$94,575
TOTAL CAPITAL COSTS
$409,826
ANNUAL OPERATION AND MAINTENANCE
COSTS
Treatment Plant Components
Operating Labor-N2 Operator
700.00
MANHR
$95
$66,500
Management/Support - Project Manager
250.00
MANHR
$125
$31,250
Maintenance (7% total capital) Reduced O&M
1.00
LS
$28,688
$28,688
System
Inspection and Maintenance
1.00
LS
$25,000
$25,000
Outfall Pipeline
Inspection and Maintenance
1.00
LS
$12,000
$12,000
Geotubesand Polymer - Annual Replacement
1.00
LS
$30,000
$30,000
Geotubes - Residual Solids Management
1.00
LS
$7,500
$7,500
Chemical Usage
0.00
LS
$17,500
$0
Carbon Rebedding
0.00
LS
$15,000
$0
Ion Exchange Regen.
$0
Water Disposal
0.00
GALLONS
$0.25
$0
Electrical Requirement
60000.00
KW
$0.15
$9,000
Quarterly Effluent Monitoring
4.00
EA
$4,000
$16,000
Subtotal
$225,938
Groundwater Monitoring Program
Present Worth for 15 yr LTM
1.00
LS
$1,184,815
$1,184,815
Present Worth for Groundwater Mon. O&M
$1,184,815
Present Worth of System O&M (10 years @
7%)
$1,586,892.70
Present Worth of 10 Years of 0&M/15 LTM
$2,771,708
TOTAL ESTIMATED REMEDIAL COST
$3,181,534
Notes:
1. The opinion of cost is based upon CSI experience operating the existing system at the Gibbstown site.
(assumes that carbon and sand filter units from existing system can be reused)
2. The opinion of cost is based upon the current groundwater treatment system flow rate of 125 gpm.
-------
Table 17: Engineered Soil Cover Cost Estimate for Alternatives S-3 and SED-3
Item
Quantity
Units
Unit Cost
Extended Cost
Total Cost
DIRECT CAPITAL COSTS
Site Preparation
Mobilization
1
LS
$ 50,000
$ 50,000
Health and Safety Plan
1.00
LS
$ 5,000
$ 5,000
$ 55.000
Land Clearinq - Light Veqetation
Clear And Grub Light Trees, Cut and Chip
15.00
acre
$ 10,000
$ 150,000
On-Site Composting
4
acre
$ 2,500
$ 10,000
$ 160.000
Survevinq
1
LS
$ 7,500
$ 7,500
$ 7,500
Sediment Control - Silt Fencinq
6,000
ft.
$4.00
$ 24,000
Modifv (Raise Well Infrastucture)
Grading, compaction, sump, gravity drain
1
LS
150,000
$ 150,000
$ 150.000
Excavate and Haul to Clean Soil Cover
Excavate and Load
14,000
solids CY
$3.00
$ 42,000
Haul to stockpile location onsite (2km, 26 CY Off
Highway Truck)
14,000
solids CY
$3.00
$ 42,000
$ 84.000
Clean Soil Cover (Assume 25.000 CY)
Place Treated Solids
14,000
CY
$3.00
$ 42,000
Unclassified Fill dirt (delivered)
4,000
loose CY
$ 30.00
$ 120,000
Place fill dirt
4,000
loose CY
$3.00
$ 12,000
Grading, compaction (treated & fill dirt)
18,000
SY
$3.50
$ 63,000
Screened Topsoil (delivered)
7,000
loose CY
$ 50.00
$ 350,000
Spread Topsoil (as needed)
7,000
loose CY
$4.03
$28,210
HydroSeeding/Vegetation (soil cover & excavation
areas)
784,617
SF
$0.15
$ 117,693
$ 690.903
TOTAL DIRECT CAPITAL COSTS
$ 1,147,403
INDIRECT CAPITAL COSTS
Contingency (15% +/-)
$172,110
Engineering, assumed only grading needed for SW drainage improvements (20% +/-)
$229,481
Administration (5% +/-)
$57,370
TOTAL INDIRECT CAPITAL COSTS
$458,961
TOTAL CAPITAL COSTS
$ 1.606.364
ANNUAL OPERATING COSTS
Stormwater & Soil Erosion Manaqement
Quarterly maintenance, inspections, repairs
4
QTR
$ 5,000
$ 20,000
$ 20.000
Present Worth of Soil Cover O&M (30 vears @ 5%)
$ 307,460
TOTAL ESTIMATED SOIL COVER COST
$ 1,913,824
Note: If treated soils are not included in soil cover clean fill by approximately $600,000.
-------
Table 18: Chemical-Specific ARARs. TBCs. and Other Guidelines
FEDERAL or STATE
REGULATORY/
REQUIREMENT
REGULATION/ CITATION
APPLICABILITY/ RELEVANCE
COMMENT
Federal
Safe Drinking Water Act
40 C.F.R. 141
Drinking water standards which apply to
specific contaminants determined to have an
adverse impact on human health
Relevant and appropriate for B- and C-level
groundwater, if needed
Clean Water Act
33 U.S.C. § 1251 etseq.
National policy for eliminating/mitigating
impacts to navigable waters, waters of the
contiguous zone and the oceans
ARAR for eliminating point source sources
for aquifers and surface water
RCRA Ground Water
Protection Standards
40 CFR§ 264.94
Provides guidance for setting concentration
limits for hazardous constituents at a particular
site
ARAR for groundwater concentration limits
Federal Water Quality Criteria
51 Federal Register 436665
Establishes recommended water quality
criteria for 157 different pollutants
TBC for groundwater
State
New Jersey Surface Water
Quality Standards
N.J.A.C. 7:9B
NJDEP sets standards for surface water based
on classes
ARAR for various contaminants
New Jersey Remediation
Standards
N.J.A.C. 7:26D
Sets minimum surface water and saturated soil
remediation standards, and requires
development of impact to groundwater soil
remediation standards
Applicable to ingestion/dermal soil
remediation standards; TBC for impact to
groundwater procedures
New Jersey Groundwater
Quality Standards
N.J.A.C. 7:9-6; N.J.A.C 7:9C
Sets minimum groundwater remediation
standards
Applicable to groundwater
New Jersey Pollutant
Discharge Elimination System
N.J.A.C. 7:9B-1.14
Sets permit limitations and effluent criteria for
groundwater treatment systems in the state of
New Jersey
Applicable to treatment and effluent criteria
for groundwater
NJDEP Ecological Screening
Criteria
Ecological Screening Criteria
March 10, 2009, not
promulgated
Ecological screening criteria in surface water,
sediment and soil
TBC for surface water, sediment and soil
-------
Table 19: Action-Specific ARARs TBCs. and Other Guidelines
FEDERAL or STATE
REGULATORY/
REQUIREMENT
REGULATION CITATION
APPLICABILITY/ RELEVANCE
COMMENT
Federal
Resource Conservation and
Recovery Act (RCRA)
40 C.F.R. §§ 262, 263,
264, 265
Hazardous waste handling, storage and
disposal
Applicable to on-Site treatment and storage
activities
Clean Air Act
40 C.F.R. Part 50
Particulate and fugitive dust emission
requirements
Applicable to on-Site activities with potential
to generate particulate and/or fugitive dust
emissions
Clean Water Act - NPDES
Permitting Requirements for
Discharge of Treatment
System Effluent
40 C.F.R. Parts 122-125
Provides guidelines for NPDES permitting
requirements for discharge of treatement
system effluent
Applicable to treatment system effluent; on-
Site discharges would comply with
substantive requirements of otherwise
required permits
Identification and Listing of,
specific Hazardous Waste
40 C.F.R. §§ 261.3,261.6,
261.10
Defines those wastes, which are subject to
regulation as hazardous wastes, and lists
specific chemical and industry-source wastes
Applicable to determine whether soil and/or
sediment meets requirements for
management as hazardous waste
Toxicity Characteristic
40 C.F.R. §261.24
Specifies TCLP constituent levels for
identifying wastes that exhibit toxicity
characteristics
Applicable to determine whetner soil and/or
sediment exhibits the characteristic of
toxicity.
State
Technical Requirements for
Site Remediation
N.J.A.C. 7:26E
Technical requirements for remediation of
contaminated sites under New Jersey cleanup
programs
Substantive technical reuqirements are
potentially relevant and appropriate.
NJPDES and Effluent
Limitations
N.J.A.C. 7:14A, et seq.
Provides guidance for operating treatment
systems and setting treatment system effluent
limitations in New Jersey
Applicable to treatment system design
NJDEP Guidance on Capping
of Sites Undergoing
Remediation
Version 1.0
July 14, 2014
Provides guidance for capping remediation
sites in New Jersey
TBC for soil cover design
NJDEP Guidance for
Beneficial Use of Soil and
Non-Soil Material in the
Remediation of Contaminated
Sites and Closure of Solid
Waste Landfills
June 2008
Provides guidance for the use of fill during
remediation at contaminated sites in New
Jersey
TBC for soil handling and on-Site
disposal/reuse
Standards Applicable to
Generators of Hazardous
Waste
N.J.A.C. 7:26G-6
Regulations guiding the handling and
disposal of hazardous waste in New Jersey
Applicable to the handling/disposal of
hazardous waste if generated during the
remedial action
Land Disposal Restrictions
N.J.A.C. 7:26G-11
Regulations regarding limitations on disposal
of particular pollutants in New Jersey
Potentially applicable if soil or sediment
requires management prior to disposal to
meet New Jersey requirements
Noise Control Act
N.J.S.A. 13:1G-1 etseq. and
N.J.A.C. 7:29-1.2
Requirements for controlling noise during
construction activities
Relevant and appropriate for implementation
of remedial actions at a site
Air Pollution Control Act
N.J.A.C. 7:27-8, 16
Requirements for limiting air emissions in
the state of New Jersey
Potentially applicable to implementation of
soil and sediment remedial actions
Soil Erosion and Sediment
Control
N.J.S.A. 4:24
Requirements for controlling erosion during
land disturbances over 5000 square feet
Applicable to soil/sediment excavation
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Table 20: Location-Specific ARARs, TBCs, and Other Guidelines
FEDERAL or STATE
REGULATORY/
REQUIREMENT
REGULATION/
CITATION
APPLICABILITY/ RELEVANCE
COMMENT
Federal
Fish and Wildlife
Coordination Act
16 U.S.C. § 662
Requires that the US Fish and Wildlife
Service and respective state fish and wildlife
agencies be consulted when a federal water
resource development project is being
implemented
Applicable to the extent that the sediment
remedy involves modification of a stream or
body of water
Clean Water Act
33CFR 330, 33 USC 1251
Section 404, 40 CFR 230, 231
Guidelines established criteria for evaluating
impacts to waters of the US (including
wetlands) and sets forth factors for
considering mitigation measures
Applicable to impacts/remedial action in
wetlands areas and buffer zones and streams
Executive Order 11988
"Floodplain Management"
Requires federal agencies to avoid to the
extent possible the long and short-term
adverse impacts associated with the
occupancy and modification of flood plains
and to avoid direct and indirect support of
floodplain development wherever there is a
practicable alternative
TBC for sediment remedy
Executive Order 11990
"Protection of Wetlands"
Statement of procedures on floodplain
management and wetlands protection
TBC for sediment remedy
State
New Jersey Coastal Zone
Management Rules
N.JA.C. 7:7-1.1, et seq.
Provides rules and standards for
devleopment, including sediment removal, at
or below the mean high tide line of coastal
and tidal waters of the State
ARAR for sediment remedy
Endangered Plant Species Act
N.J.S.A. 13: IB, et seq.
Regulation requiring a survey of endanged
plant species in a project area to prevent
impacts to these populations
Potentially applicable to sediment remedy
Soil Erosion and Sediment
Control Act
N.J.S.A. 4:24-39, et seq.
Regulates construction that will potentially
result in erosion of soils, requires soil erosion
and sediment control for certain projects in
the state of New Jersey
Applicable for Site activities involving
excavation, grading and other soil disturbance
actvities
Freshwater Wetlands
Protection Act Rules
N.J.A.C. 7:7A
Regulates all dredging and sediment
disturbance or removal activities in
freshwater wetlands
Substantive standards applicable to
disturbance of wetlands areas and buffer
zones
Flood Flazard Area Control
Act Rules
N.JA.C. 7:13-10,11
Regulates the disturbance, the placement of
fill, grading, excavation, or other disturbance
within the defined flood hazard area of
rivers/streams
Potentially applicable to impacts/remedial
action in floodplain areas; remedy will
comply with substantive requirements of
otherwise required permits
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APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/15/2018 REGION ID: 02
Site Name: HERCULES, INC. (GIBBSTOWN PLANT)
CERCLIS ID: NJD002349058
OUID: 01 and 02
SSID: 0259
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
510509
8/15/2018
ADMINISTRATIVE RECORD INDEX FOR OU1 AND OU2
FOR THE HERCULES INCORPORATED (GIBBSTOWN
PLANT) SITE
5
Administrative Record
Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
501255
05/23/2008
FOCUSED INVESTIGATION WORK PLAN FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
232
Work Plan
105750
09/10/2009
US EPA REGION II ADMINISTRATIVE SETTLEMENT
AGREEMENT AND ORDER ON CONSENT OF REMEDIAL
INVESTIGATION/FEASIBILITY STUDY - CERCLA DOCKET
NO. 02-2009-2034 FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
71
Legal Instrument
MUGDAN,WALTER,E (US ENVIRONMENTAL
PROTECTION AGENCY)
501242
02/10/2010
FEASIBILITY STUDY WORK PLAN FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
36
Work Plan
499911
07/30/2010
SUPPLEMENTAL VAPOR INTRUSION INVESTIGATION
REPORT FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
59
Report
(US ENVIRONMENTAL PROTECTION
AGENCY) | PIERRE,PATRICIA (US
ENVIRONMENTAL PROTECTION AGENCY)
(CONSTRUCTION SERVICES
INTERNATIONAL) | STEVENS,CRAIG
(CONSTRUCTION SERVICES
INTERNATIONAL)
501262
11/11/2010
SUPPLEMENTAL VAPOR INTRUSION DELINEATION
SAMPLING PLAN FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
16
Work Plan
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
FERRIS,J. DUSTIN (CSI ENVIRONMENTAL
LLC)
501263
11/11/2010
SUB-SLAB SOIL GAS AND INDOOR AIR SAMPLING
WORK PLAN FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
28
Work Plan
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
FERRIS,J. DUSTIN (CSI ENVIRONMENTAL
LLC)
Page 1 of 5
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/15/2018 REGION ID: 02
Site Name: HERCULES, INC. (GIBBSTOWN PLANT)
CERCLIS ID: NJD002349058
OUID: 01 and 02
SSID: 0259
Action:
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Title:
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501264
09/12/2011
SUB-SLAB SOIL GAS AND INDOOR AIR VAPOR
INTRUSION INVESTIGATION REPORT FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
48
Report
501265
09/12/2011
TRANSMITTAL OF THE SUB-SLAB SOIL GAS AND
INDOOR AIR VAPOR INTRUSION INVESTIGATION
REPORT FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
1
Letter
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
FERRIS,J. DUSTIN (CSI ENVIRONMENTAL
LLC)
501252
08/01/2013
BASELINE ECOLOGICAL RISK ASSESSMENT WORK
PLAN FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
358
Work Plan
501259
03/23/2015
ADDITIONAL REMEDIAL INVESTIGATION WORK PLAN
FOR THE HERCULES INCORPORATED (GIBBSTOWN
PLANT) SITE
35
Work Plan
501256
11/05/2015
ADDITIONAL REMEDIAL INVESTIGATION RESULTS
SUMMARY LETTER REPORT FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
73
Report
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501250
02/01/2016
RESIDUAL NON-AQUEOUS PHASE LIQUIDS MOBILITY
STUDY LETTER REPORT FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
8
Report
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501258
02/08/2016
ADDITIONAL REMEDIAL INVESTIGATION WORK PLAN
ADDENDUM FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
4
Work Plan
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501260
03/01/2016
CONCEPTUAL SITE MODEL FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
28
Report
Page 2 of 5
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/15/2018 REGION ID: 02
Site Name: HERCULES, INC. (GIBBSTOWN PLANT)
CERCLIS ID: NJD002349058
OUID: 01 and 02
SSID: 0259
Action:
DocID:
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Title:
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Count:
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Author Name/Organization:
501243
03/14/2016
BIOTREATABIUTY/BIOREMEDIATION WORK PLAN FOR
THE HERCULES INCORPORATED (GIBBSTOWN PLANT)
SITE
40
Work Plan
501248
03/31/2016
CLONMELL CREEK SEDIMENT TREATMENT PILOT
STUDY WORK PLAN FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
73
Work Plan
501257
05/04/2016
ADDITIONAL REMEDIAL INVESTIGATION LEAD
ADDENDUM RESULTS SUMMARY LETTER REPORT FOR
THE HERCULES INCORPORATED (GIBBSTOWN PLANT)
SITE
19
Report
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501249
08/03/2016
SITE-SPECIFIC CUMENE SOLUBILITY AND CHEMICAL
SATURATION VALUES LETTER REPORT FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
74
Report
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501245
09/14/2016
BIOTREATABIUTY/BIOREMEDIATION PROGRESS
REPORT FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
17
Report
501251
03/01/2017
BASELINE ECOLOGICAL RISK ASSESSMENT REPORT
FOR THE HERCULES INCORPORATED (GIBBSTOWN
PLANT) SITE
1203
Report
501254
04/20/2017
DERIVATION OF SCREENING VALUES BENCHMARK
TABLES FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
47
Report
PIERRE,PATRICIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(CSI ENVIRONMENTAL LLC)
501246
04/21/2017
CLONMELL CREEK SEDIMENT TREATMENT PILOT
DREDGING STUDY REPORT FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
60
Report
Page 3 of 5
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/15/2018 REGION ID: 02
Site Name: HERCULES, INC. (GIBBSTOWN PLANT)
CERCLIS ID: NJD002349058
OUID: 01 and 02
SSID: 0259
Action:
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501247
08/11/2017
CLONMELL CREEK SEDIMENT TREATMENT PILOT
PHYTOREMEDIATION STUDY REPORT FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
460
Report
501253
09/01/2017
BASELINE HUMAN HEALTH RISK ASSESSMENT FOR
THE HERCULES INCORPORATED (GIBBSTOWN PLANT)
SITE
3401
Report
501244
10/12/2017
BIOTREATABILITY/BIOREMEDIATION FINAL REPORT
FOR THE HERCULES INCORPORATED (GIBBSTOWN
PLANT) SITE
95
Report
501266
07/20/2018
NJDEP CONCURRENCE OF THE PROPOSED PLAN FOR
OU1 AND OU2 FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
1
Letter
PRINCE,JOHN (US ENVIRONMENTAL
PROTECTION AGENCY)
PEDERSON,MARK (NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL
PROTECTION)
501287
07/26/2018
REMEDIAL INVESTIGATION REPORT FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
279
Report
533968
7/26/2018
REMEDIAL INVESTIGATION REPORT - TABLES AND
FIGURES FOR THE HERCULES INCORPORATED
(GIBBSTOWN PLANT) SITE
753
Report
501288
07/26/2018
REMEDIAL INVESTIGATION REPORT APPENDICES A-T
FOR THE HERCULES INCORPORATED (GIBBSTOWN
PLANT) SITE
1445
Report
501289
07/26/2018
REMEDIAL INVESTIGATION REPORT APPENDIX U FOR
THE HERCULES INCORPORATED (GIBBSTOWN PLANT)
SITE
102
Report
501290
07/26/2018
FEASIBILITY STUDY REPORT FOR THE HERCULES
INCORPORATED (GIBBSTOWN PLANT) SITE
1566
Report
(CSI ENVIRONMENTAL LLC)
Page 4 of 5
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/15/2018 REGION ID: 02
Site Name: HERCULES, INC. (GIBBSTOWN PLANT)
CERCLIS ID: NJD002349058
OUID: 01 and 02
SSID: 0259
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
538260
07/27/2018
PROPOSED PLAN FOR OU1 AND OU2 FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
22
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
533989
8/3/2018
REVISED FEASIBILITY STUDY REPORT FOR THE
HERCULES INCORPORATED (GIBBSTOWN PLANT) SITE
1562
Report
(HERCULES INCORPORATED)
(CSI ENVIRONMENTAL LLC)
Page 5 of 5
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APPENDIX IV
STATE CONCURRENCE LETTER
-------
fits.it iif ^Neitr 3^rscg
Department of Environmental Protection
PHILIP D, MURPHY
Governor
Site Remediation and Waste Management Program
401 E. State Street
CATHERINE R. McCABE
Commissioner
SHEILA Y, OLIVER
Lt. Governor
PO Box 420, Mail Code 401-06
Trenton, New Jersey 08625
Tel: (609) 292-1250
Fax: (609) 777-1914
Angela Carpenter, Acting Director
September 20, 2018
Emergency and Remedial Response Division
USEPA Region 2
290 Broadway
New York, NY 10007-1866
RE: Hercules Inc Gibbstown Super fund Site - Record of Decision
Greenwich Twp, Gloucester County
Dear Ms, Carpenter:
The New Jersey Department of Environmental Protection (Department) has completed its review
of the Record of Decision for Operable Units 1 and 2 of the Hercules Gibbstown Superi'und Site.
The Department concurs with the selected remedial actions. The selected remedy, comprised of
Alternatives S-3, GW-2 and SED-3 in the Record of Decision, consists of the following:
Soils with lead contamination will be excavated and disposed off-site; soils with VOC
contamination will be treated on-site by bioremediation; a deed notice will be placed on the entire
site. Groundwater will be extracted through use of current pumping wells followed by on-site
treatment and establishment of a CI:A. Contaminated sediments will be dredged and treated on-
site via phytoremediation and ultimately used as on-site cover.
The selected remedy is protective of human health and the environment, complies with Federal
and State requirements that are applicable or relevant and appropriate to the remedial action, and
are cost effective.
The Department appreciates the opportunity to participate in the decision-making process to select
the appropriate remedies. If you have any questions, please call me at 609-292-1250.
The State of New Jersey is on equal opportunity employer. Printed on recycled and recyclable paper.
-------
APPENDIX V
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
RECORD OF DECISION
HERCULES, INC. SUPERFUND SITE
GIBBSTOWN, GLOUCESTER NEW JERSEY
INTRODUCTION
This Responsiveness Summary provides a summary of citizens' comments and concerns
received during the public comment period related to the Proposed Plan for operable units
one and two (OU1 and OU2) at the Hercules, Inc. Superfund Site (Site) and provides the
U.S. Environmental Protection Agency's (EPA's) responses to those comments and
concerns. All comments summarized in this document were considered in EPA's final
selection of a remedy to address the contamination at the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
Field investigations related to OU1 and OU2 were conducted at the Site from 1987
through 2018, which culminated in the completion of remedial investigation and feasibility
study (RI/FS)1 reports in July 2018. EPA's preferred remedy and the basis for that
preference were identified in a Proposed Plan.2 The Rl and FS reports and the Proposed
Plan were released to the public for comment on July 30, 2018. These documents were
made available to the public at information repositories maintained at the Gloucester
County Library System, Greenwich Township Branch, 411 Swedesboro Road,
Gibbstown, New Jersey and the EPA Region 2 office in New York City and on EPA's
website for the Site at https://www.epa.aov/superfund/hercules-gibbstown.
A notice of availability for the above-referenced documents was published in the
Gloucester County Times on July 29, 2018. The public comment period ran from July 30,
2018 to August 28, 2018. On August 16, 2018, EPA held a public meeting at the
Gibbstown Municipal Court Building to inform local officials and members of the
community about the Superfund process, present the Proposed Plan for the Site,
including the preferred remedy, and respond to questions and comments from
approximately 30 attendees (including residents, media, local business people and local
government officials). Based upon the comments received during the public comment
period, the public generally supports the selected remedy.
1 An Rl determines the nature and extent of the contamination at a site and evaluates the
associated human health and ecological risks and an FS identifies and evaluates remedial
alternatives to address the contamination.
2 A proposed plan describes the remedial alternatives considered for a site and identifies the
preferred remedy with the rationale for this preference.
V-1
-------
SUMMARY OF COMMENTS AND RESPONSES
Comments were received at the public meeting and in writing.
The transcript from the public meeting can be found in Appendix V-c.
Written comments were received from Jeff Tittel, Director, New Jersey Sierra Club, in a
letter, dated August 28, 2018. This letter can be found in Appendix V-d.
A summary of the comments provided at the public meeting and in writing, as well as
EPA's responses to those comments, are provided below.
Solid Waste Disposal Area
Comment #1: Two commenters expressed concern that because the selected remedy
does not address the tar and mixed waste located in the Solid Waste Disposal Area
(SWDA), contaminants leaching into the groundwater underlying the SWDA could
threaten local drinking water wells, contaminants could leach into the surrounding
wetlands and Clonmell Creek, and contaminants could migrate from Clonmell Creek to
the Delaware River. The commenters urged EPA to remove SWDA as part of the
selected remedy.
Response #1: The Site is being addressed in three OUs. The SWDA is associated with
OU3 and is being addressed under the New Jersey Department of Environmental
Protection's (NJDEP's) lead. A remedy for OU3 was selected by NJDEP, with EPA's
concurrence, in 1996, calling for consolidation of the waste, installation of an impermeable
cap, long-term groundwater monitoring, periodic inspections and institutional controls.
The remedial action for OU3 was completed in 2014 and maintenance of the cap is being
performed under NJDEP oversight. Quarterly groundwater samples are collected from
20 monitoring wells located in the vicinity of the SWDA. The results from this sampling
show minimal impacts to the groundwater in that area and diminishing contaminant
concentrations. A network of groundwater recovery wells maintains hydraulic
containment of the contaminated groundwater beneath the Site.
For remedial actions that result in any hazardous substances, pollutants, or contaminants
remaining above levels that allow for unlimited use and unrestricted exposure, five-year
reviews (FYRs) are conducted to evaluate the implementation and performance of a
remedy to determine if the remedy is and will continue to be protective of human health
and the environment. The first FYR for the Site, completed in 2015, concluded that the
remedial actions implemented in the SWDA continue to be protective of human health
and the environment. Therefore, EPA does not believe that further remedial action at the
SWDA is necessary.
V-2
-------
Capping
Comment #2: A commenter expressed concern about capping contaminated soils in a
flood-prone area.
Response #2: Capping contaminated soils is not a component of the selected remedy
for OU1 and OU2. The OU1/OU2 remedy calls for, among other things, excavation of
lead-contaminated soil with off-Site disposal, excavation of volatile organic compound
(VOC)-contaminated soil located 0-4 feet (ft.) below the ground surface (bgs) and
treatment with ex-situ bioremediation, enhanced in-situ biodegradation of VOC-
contaminated soil situated below 4 ft. bgs, and hydraulic dredging of contaminated
sediment with on-Site phytoremediation. The ex-situ-treated soils and sediments will be
reused on-Site as part of an engineered soil cover to reduce infiltration of surface water
to the groundwater and control surface water runoff/drainage. The soil cover is not
intended as a remedial cap to control direct contact with contaminated material, so the
protectiveness is not expected to be disrupted in the event of flood conditions. The soil
cover, and any aspect of the remedy that involves adding material in the floodplain, will
be implemented to meet the requirements of New Jersey's Flood Hazard Control Act.
Groundwater Contamination
Comment #3: A commenter inquired as to whether the monitoring wells that were
installed across the street from the Site are adequate to monitor the migration of
contamination.
Response #3: Groundwater has been monitored both on and off the property since 1984.
Ninety-two monitoring wells are sampled on an annual basis, with 28 of those wells being
sampled quarterly. EPA believes this monitoring well network is more than adequate to
monitor groundwater quality at the Site and in the surrounding neighborhoods.
Comment #4: A commenter indicated that his house was constructed into the water table
and that two sump pumps must continuously operate to keep his basement dry. He also
stated that the house has a bad odor. Because he was concerned that the odor was
attributable to contaminated groundwater emanating from the Site, he hired a contractor
to sample his property. He indicated that the sample results show elevated levels of
benzene in his house, which he attributes to groundwater contamination associated with
the Site.
Response #4: While benzene is present in the groundwater at the Site, a network of
groundwater recovery wells currently maintains hydraulic containment of the
contaminated groundwater beneath the Site. This has been confirmed by water level
measurements and analytical sample results.
No benzene has been detected off-property in the shallow aquifer. Benzene has been
sporadically detected off-property at low concentrations in the deep aquifer at a
monitoring well located (horizontally) approximately 200 ft. away from the commenter's
V-3
-------
residence and situated between the Site and the residence. However, no benzene has
been detected in the intermediate aquifer at this location. The aquifers are separated by
confining clay layers, which means there is a clean water zone, with no benzene
detections, between the residence and the deep aquifer, which is located (vertically) more
than 100 ft. below the residence. In 2010 and 2011, an extensive vapor intrusion
investigation was conducted in and around the 13 residences located adjacent to the Site
(between the Site and the commenter's house). Based upon the results of the study,
EPA determined that related vapor intrusion was not occurring in these homes and that
no further vapor intrusion assessment was warranted. In addition, a groundwater sample
was collected from the shallow aquifer beneath the commenter's property in 2015 and
analyzed for VOCs. No Site-related compounds were detected.
Based upon the extensive groundwater studies conducted at the Site and in the
surrounding neighborhood and the several lines of evidence which suggest no connection
between the benzene detections at the Site and in the off-property deep monitoring wells,
EPA has determined that any benzene present in the commenter's house is highly
unlikely to be related to the Site.
Land Use
Comment #5: A commenter inquired as to whether the property can be used for housing
or farmland once it is remediated. Another commenter asked why the Site is not going to
be cleaned up to residential levels.
Response #5: When EPA evaluates the need for a response action and selects a remedy,
it considers the current- and reasonably-anticipated future use. EPA considers several
factors, including the current use and zoning. The Site property, which is comprised of
developed and undeveloped land, is currently zoned for commercial/industrial use. Until
recently, it was an active industrial facility; EPA is not aware of any basis for the zoning
or land use to change. Therefore, commercial/industrial cleanup levels will be used for
the Site, so that once the Site is remediated, it can be used for commercial/industrial
purposes.
Property Ownership
Comment #6: A commenter asked about the Site property's ownership history.
Response #6: Hercules, Incorporated (Hercules) (now known as Hercules LLC) acquired
the property in 1952. Prior to that time, E. I. du Pont de Nemours and Company reportedly
used the SWDA to dispose of lead fragments and tar generated from the production of
aniline at a nearby facility. After acquiring the property, Hercules constructed and
operated a chemical manufacturing facility, producing organic peroxides, phenols, and
acetone. After 1970, Hercules, primarily produced cumene hydroperoxide, dicumyl
peroxide, and isopropylbenzene. Other specialty chemicals were also made at the facility.
In 2008, Ashland, Inc. (Ashland) acquired Hercules. In 2010, Hercules decommissioned
the plant and demolished most of the aboveground structures.
V-4
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Perceived Conflict of Interest
Comment #7: Several commenters opined that it is a conflict for the party that caused
the contamination problem at the Site to investigate and clean it up. Two commenters
suggested that either EPA or a third party should undertake the work and bill Ashland for
its costs.
Response #7: Under the Superfund law, EPA is authorized to compel the party or parties
that are responsible for the site to pay for or to conduct the necessary response actions.
The law also authorizes EPA to reach settlements under which potentially responsible
parties (PRPs) perform cleanups, with EPA overseeing the work. EPA follows an
enforcement-first policy, which calls for PRPs to conduct remedial actions whenever
possible. EPA, generally, performs work at Superfund sites using its own contractors only
if there are no viable PRPs or if the PRPs are unwilling or unable to perform the work.
Hercules performed the RI/FS under EPA oversight (with NJDEP's review and
concurrence) pursuant to a consent order with EPA. All the sampling procedures and
the analytical parameters, sampling locations and sampling depths were approved by
EPA and NJDEP. In addition, the analyses were performed at EPA-approved and
NJDEP-certified laboratories. Following the chemical analyses, the data were verified by
an independent third party.
Following the selection of a remedy for the Site, EPA expects to commence negotiations
with Hercules to seek its performance of the remedial design and implementation of the
selected remedy under EPA oversight. If the negotiations are successful and an
enforceable agreement is reached, design work will commence, followed by the remedial
action, both under EPA's oversight (with NJDEP's review and concurrence). If the
negotiations are not successful, EPA will evaluate its options, including issuing a
Unilateral Administrative Order to Hercules or seeking federal funding to perform the
work. If federal funds are expended, EPA could seek to recover its costs from Hercules.
Contaminated Soils
Comment #8: A commenter inquired about the potential disruption that will be caused
by transporting contaminated soils and sediments off-Site. Another commenter inquired
as to the volumes of contaminated soils and sediments that will be excavated.
Response #8: An estimated 14,000 cubic yards (CY) of contaminated soil will be
excavated under the selected remedy, consisting of approximately 1,000 CY of lead-
contaminated soil and 13,000 CY of soil contaminated with benzene, cumene and
colocated contaminants of concern. In addition, it is estimated that 8,500 CY of
contaminated sediments will be dredged. Only the lead-contaminated soils will be
transported off-Site; the other soils and the sediments will be treated on-Site. An
estimated 63 truckloads of lead-contaminated soil will be transported off-Site. Minimizing
the disruption of the community is one of the factors considered in EPA's decision to treat
most of the contaminated soils and sediments on-Site, rather than transporting them off-
Site.
V-5
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Comment #9: A commenter inquired whether the trucks would be covered and asked
what safety measures would be employed on-Site.
Response #9: Trucks carrying the contaminated soil will be covered. Prior to leaving the
Site, the trucks carrying the lead-contaminated soils will be decontaminated, if necessary,
to prevent tracking contaminated material onto the streets and the payloads will be
covered to prevent releases. A health and safety plan will be developed to protect on-
Site remediation workers and the public. In addition, air monitoring will be conducted on-
Site to ensure that unacceptable releases do not occur during remediation.
Comment #10: A commenter inquired as to where the lead-contaminated soil would be
disposed.
Response #10: The lead-contaminated soil would be transported to a licensed disposal
facility that will be selected during the design of the remedy.
Community Updates
Comment #11: A commenter asked whether EPA intends to let the public know what
will be going on before work starts at the Site.
Response #11: EPA intends to keep the public informed about the work planned at the
Site by keeping the EPA Site Profile Page on its website up-to-date, issuing fact sheets
and/or conducting public informational meetings.
Human Health Concerns
Comment #12: A commenter inquired as to the potential human health effects associated
with the contaminants of highest concern at the Site.
Response #12: Benzene is a known human carcinogen and may have immunological
effects. Exposure to cumene could affect the liver and urinary system. Both are volatile
organic compounds (VOCs). Exposure to lead is of highest concern to children, as it may
cause cognitive impairment.
Based on the data collected at the Site, contamination is not currently migrating off the
property via the groundwater or through surface water runoff.
Vapors released from VOC-contaminated groundwater and/or soil have the potential to
move through the soil (independently of groundwater) and seep through cracks in
basements, foundations, sewer lines, and other openings. Vapor intrusion sampling (soil
gas samples, sub-slab samples, indoor air, and ambient air samples) was conducted in
13 residences located adjacent to the southern property boundary of the Site. EPA did
not find a completed exposure pathway.
V-6
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While there are current and future unacceptable on-property exposure risks, EPA has not
identified any off-property impacts to the community.
Comment #13: A commenter inquired whether residents should drink bottled water and
whether a threat is posed to home gardeners.
Response #13: Ongoing groundwater monitoring associated with the Site, which includes
quarterly sampling of the nearby Township water supply wells, indicates that the public
water supply is not impacted by the contamination at the Site.
As long as gardening is not performed on the Site property, there is no threat posed by
Site-related contaminants. Because the property is zoned for commercial/industrial use,
it is unlikely that gardening will be performed on the property.
Remediation Timeframes
Comment #14: A commenter requested clarification regarding the 12-month, 18-month,
2-year, and 10-year timeframes related to the soil, sediment, and groundwater
alternatives.
Response #14: The 12-, 18- and 24-month timeframes are the estimated construction
times for the various soil, sediment, and groundwater alternatives. The construction
includes excavating contaminated soils, dredging contaminated sediments, setting up the
ex-situ treatment systems and building the groundwater treatment system. Following
construction, the estimated timeframe to achieve the remediation goal for the
contaminated sediments through phytoremediation is 12 months. The estimated
timeframe to achieve remediation goals for the ex-situ treated soil is 18 months; it will
take an estimated 10 years to reach cleanup levels for the in-situ treated soil and the
groundwater. In-situ treatment of source area soil also is expected to take 10 years to
achieve the remediation goals.
Extent of Remediation
Comment #15: A commenter inquired why remediation is planned for only 80 acres of
the 350-acre Site.
Response #15: A detailed RI/FS was conducted of the Site, including a risk assessment.
Based on the RI/FS and the record for the Site, EPA identified the eighty acres as the
area of the Former Plant Area where contamination is present that requires a response
at this time. As described above in Response #1, an action has already been completed
for the SWDA. EPA did not identify any other areas of the Site that require an action
under the Superfund program.
V-7
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Development of the Property
Comment #16: A commenter expressed concern that no entity would want to develop
the property knowing that it is a Superfund site with the possibility that there is
contamination remaining.
Response #16: During the Rl, more than 8,000 soil and sediment samples were collected
throughout the property. This intensive sampling clearly characterized the nature and
extent of the contamination. Several pilot-scale studies were conducted during the Rl to
evaluate the use of various soil and sediment treatment techniques and processes.
Based upon the results of these studies, EPA expects that the in-situ and ex-situ
treatment technologies that were selected for the Site will be effective in successfully
treating the contaminated soils and sediments. Because the in-situ treatment of the deep
contaminated soils will take approximately 10 years, there will be restrictions on
development in these areas until the cleanup objectives are met. Nevertheless, there are
areas of the Site that do not require an action under the Superfund program and may be
available for reuse. Whether a property is a candidate for development depends on many
factors, but the fact that it is part of a Superfund site does not prevent reuse. Many
Superfund sites, including sites in New Jersey, have been redeveloped.
In the Event of an Unsuccessful Remediation
Comment #17: A commenter expressed concern about the likelihood of further
remediation efforts if aspects of the remediation are not successful.
Response #17: As was noted in Response #1, FYRs are conducted at sites to evaluate
the implementation and performance of a remedy to determine if the remedy is and will
continue to be protective of human health and the environment. If a future FYR
determines that aspects of the implemented remedy are not performing as designed or
that the remedy is not protective of human health and the environment, the FYR would
recommend measures to be implemented to address issues identified.
Off-Property Contamination
Comment #18: A commenter asked whether the athletic fields that are located adjacent
to the Site were sampled, as benzene was detected in the underlying groundwater when
an irrigation system was installed several years ago.
Response #18: Sampling of the groundwater underlying the athletic fields or of the fields
themselves is not necessary. It is known that the groundwater is contaminated from the
Site, and the groundwater underlying the athletic fields is within the capture zone of the
Site groundwater extraction system. The irrigation well for the athletic fields was not used
after it was found to be contaminated. The soil in the athletic fields was not sampled
because Rl sampling results indicate that soil contamination is not present at the Site
property line.
V-8
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Ecological Impacts
Comment #19: A commenter asked whether risks to flora and fauna were evaluated.
Response #19: A baseline ecological risk assessment, which was performed as part of
the Rl, concluded that there is a potential for adverse ecological effects associated with
Site contaminants in the sediments of the Stormwater Catchment Basin and in Clonmell
Creek. Studies indicate impacts to the benthic communities in the Stormwater Catchment
Basin and Clonmell Creek, as well as unacceptable risks to mammalian receptors in
Clonmell Creek. These contaminated sediments will be addressed by the selected
remedy.
Other Sites in Gibbstown
Comment #20: A commenter asked whether there are any other National Priorities List
(NPL) sites in Gibbstown.
Response #20: The Site is the only site in Gibbstown that is on the NPL.
V-9
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APPENDIX V-a
Proposed Plan
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Hercules, Inc. (Gibbstown Plant) Superfund Site
I $321} Gibbstown, New Jersey
Superfund Proposed Plan July 2018
PURPOSE OF THIS DOCUMENT
This document describes the remedial alternatives considered
for the first and second operable units (OUs) of the Hercules, Inc.
(Gibbstown Plant) Superfund Site (Site) and identifies the
preferred remedy for those operable units, with the rationale for
this preference. This Proposed Plan was developed by the U.S.
Environmental Protection Agency (EPA) in consultation with the
New Jersey Department of Environmental Protection (NJDEP).
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 (CERCLA) of 1980, as amended, and Sections
300.430(f) and 300.435(c) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The nature and
extent of the contamination at the Site and the remedial
alternatives summarized in this Proposed Plan are described in
the July 2018 remedial investigation (Rl) report and feasibility
study (FS) report, respectively. EPA and NJDEP encourage the
public to review these documents to gain a more comprehensive
understanding of the site and the Superfund activities that have
been conducted at the Site.
This Proposed Plan is being provided as a supplement to the
RI/FS reports to inform the public of EPA's and NJDEP's
preferred remedy and to solicit public comments pertaining to all
the remedial alternatives evaluated, including the preferred
alternative. The preferred remedy consists of extraction of
contaminated groundwater with on-Site treatment and long-term
monitoring; excavation of lead-contaminated soil with off-Site
disposal; excavation of volatile organic compound (VOC)-
contaminated soil located 0-4 feet (ft.) below the ground surface
(bgs) and treatment with ex-situ bioremediation and on-Site
reuse; enhanced in-situ biodegradation of VOC-contaminated
soil situated below 4 ft. bgs; hydraulic dredging of contaminated
sediment with on-Site phytoremediation1 and reuse; and
institutional controls (ICs).2
The remedy described in this Proposed Plan is the preferred
remedy for the Site. Changes to the preferred remedy, or a
change from the preferred remedy to another remedy, may be
made if public comments or additional data indicate that such a
change will result in a more appropriate remedial action. The
final decision regarding the selected remedy will be made after
EPA has taken into consideration all public comments. EPA is
soliciting public comment on all the alternatives considered in the
Proposed Plan and in the detailed analysis section of the FS
report because EPA and NJDEP may select a remedy other than
the preferred remedy.
1 Phytoremediation is a process that uses living plants to remove, destroy
or contain contaminants in environmental media.
2 ICs are non-engineered controls, such as property or groundwater use
restrictions placed on real property by recorded instrument or by a
governmental body by law or regulatory activity for reducing or
eliminating the potential for human exposure to contamination and/or
Protecting the integrity of a remedy.
MARK YOUR CALENDAR
July 30, 2018 - August 28, 2018: Public comment
period related to this Proposed Plan.
August 16, 2018 at 7:00 p.m.: Public meeting at the
Municipal Court Meeting Room, 2nd Floor, 21 N. Walnut
Street, Gibbstown, NJ
Copies of supporting documentation are available at
the following information repositories:
Gloucester County Library System
Greenwich Township Branch
411 Swedesboro Road
Gibbstown, NJ 08027
856-423-0684
EPA-Region II
Superfund Records Center
290 Broadway, 18th Floor
New York, NY 10007-1866
212-637-4308
https://www.epa.gov/superfund/hercules-gibbstown
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NJDEP rely 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
Rl and FS reports and this Proposed Plan have been made
available to the public for a public comment period that
begins on July 30, 2018 and concludes on August 28,
2018.
A public meeting will be held during the public comment
period at the Municipal Court Meeting Room, 2nd Floor, 21
N. Walnut Street, Gibbstown, NJ on August 16, 2018 at
7:00 p.m. to present the conclusions of the RI/FS, to
elaborate further on the reasons for recommending the
preferred remedy and to receive public comments.
Comments received at the public meeting, as well as written
comments, will be documented in the Responsiveness
Summary section of the Record of Decision (ROD), the
document that formalizes the selection of the remedy.
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Written comments on the Proposed Plan should be
addressed to:
Patricia Simmons Pierre
Remedial Project Manager
Central New York Remediation Section
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
E-mail: pierre.patricia@epa.gov
SCOPE AND ROLE OF ACTION
Site remediation activities are sometimes segregated into
different phases, or OUs, so that remediation of different
aspects of a site can proceed separately, resulting in a
more expeditious cleanup of the entire site.
The Site is being addressed by the EPA in three OUs. This
Proposed Plan describes EPA's preferred remedial action
for OU1, which addresses contaminated groundwater in
the Former Plant Area, and for OU2, which addresses
contaminated soil in the Former Plant Area and
contaminated sediment in Clonmell Creek and the
Stormwater Catchment Basin. The primary objectives of
this action are to remediate the sources of groundwater,
soil, and sediment contamination, minimize the migration
of contaminants and minimize any potential future health
and environmental impacts.
The third OU (OU3) addresses tar and mixed waste in the
Solid Waste Disposal Area (SWDA). A remedial action for
OU3 was selected by NJDEP in 1996 and included waste
consolidation and capping, long-term groundwater
monitoring, periodic inspections and ICs. The OU3
remedial action was completed in 2014 and maintenance
of the cap is being performed under NJDEP oversight.
EPA is conducts five- year reviews (FYRs) to ensure that
the OU3 remedy continues to be protective of human
health and the environment. The first FYR was conducted
in 2015.
SITE BACKGROUND
Site Description
The Site, a former chemical manufacturing facility, is
situated on approximately 350 acres located off South
Market Street in Gibbstown, Gloucester County, New
Jersey. The Site is bounded to the east by Paulsboro
Refining Company, LLC, to the west by open land
historically owned by E.I. du Pont de Nemours and
Company (DuPont), to the north by the Delaware River,
and to the south and southwest by residences. Area
homes are served by municipal water supply wells.
Clonmell Creek flows northwest through the Site property
toward the Delaware River. On the Site property, the creek
ranges from 75 to 120 feet (ft.) wide and 0.25 to 3 ft. deep
and separates the two primary areas of the Site - the
SWDA located to the north and the Former Plant Area
located to the South.
The SWDA is situated approximately 2,000 ft. north of
Clonmell Creek and covers nearly five acres. It is
surrounded by wetlands and sits adjacent to the Delaware
River.
The "Former Plant Area," the manufacturing portion of the
facility during its operational period, occupies
approximately 80 acres. An unlined stormwater retention
pond, referred to as the "Stormwater Catchment Basin," is
located within the Former Plant Area, about 600 ft. south
of Clonmell Creek. The Stormwater Catchment Basin
ranges in width from approximately 64 ft. on its south end
to 125 ft. on the north, and 0.25. to 3 ft. deep, dependent
upon precipitation levels. Historically, stormwater
collected in the area now known as the Stormwater
Catchment Basin and flowed through the 002 outfall
(which was an NJDEP-permitted discharge point) into an
adjacent drainageway before discharging into Clonmell
Creek. However, there has been no connection between
the Stormwater Catchment Basin and Clonmell Creek
since 1991 (see Figure 1).
The Former Plant Area was divided into the following Rl
investigation areas, referred to as exposure areas: Active
Process Area, Area A/Open Area, Area B, Chemical
Landfill/Gravel Pit Area, Clonmell Creek and Wetlands,
Inactive Process Area, Northern Chemical Landfill Area,
Northern Warehouse Area, Shooting Range, Stormwater
Catchment Basin Area, Tank Farm/Train Loading Area,
and Township Refuse Area (see Figure 2). The Shooting
Range exposure area is currently being used by the
Township of Greenwich Police Department as a shooting
range.
Site History
Before the property was transferred to Hercules
Incorporated (Hercules) in 1952, DuPont reportedly used
the area now designated as the SWDA and surrounding
areas to dispose of lead fragments and tar generated from
the production of aniline. In 1952, Hercules acquired title
to the Site property from DuPont. Construction of the
manufacturing plant began in 1953 and the plant was fully
operational by 1959. Phenol and acetone were
manufactured at the facility until 1970. After 1970, the plant
produced three primary products cumene
hydroperoxide, diisopropylbenzene and dicumyl peroxide,
which are compounds used in phenol and acetone
production. Hercules used the SWDA from 1955 until 1974
to dispose of wastes generated from its manufacturing
activities.
In 2010, the plant was decommissioned and the above-
ground facility structures were demolished, except for a
groundwater treatment system, a former administrative
building and two surface impoundments. Significant
subsurface sewer lines, process piping, and utilities
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associated with the former manufacturing facility remain in
portions of the Active Process Area and Inactive Process
Area. These structures were abandoned in place and filled
with concrete.
In 1981, the U.S. Geological Survey released a report
documenting the detection of benzene in a Site production
well. Based upon this finding, Hercules, under NJDEP
oversight, conducted additional groundwater studies,
which led to the discovery of other Site-related chemicals
in groundwater at the Site. Because of the contamination
identified in the groundwater and the tar and other debris
disposed of in the SWDA, the Site was added to the
National Priorities List in December 1982.
In 1984, as an interim remedy, Hercules installed a
groundwater extraction and treatment system to prevent
contaminated groundwater from migrating off-property.
The system was upgraded in 2008. Operation of the
system is on-going and will continue until a final OU1
remedy is selected.
In 1986, Hercules entered into an Administrative Consent
Order with NJDEP to perform an RI/FS in the SWDA and
adjacent areas. Based upon the results of the OU3 Rl,
conducted between 1987 and 1993, NJDEP issued a ROD
in 1996, selecting a remedy for OU3. The major
components of the remedy include consolidation of tar
material and miscellaneous solid wastes under an
impermeable cap; implementation of engineering controls
and ICs, such as fencing and environmental use
restrictions; and the establishment of a Classification
Exception Area (CEA)3 for groundwater beneath and
surrounding the SWDA. The OU3 remedial action was
completed in 2014. Routine maintenance of the SWDA is
performed by Hercules.
Under NJDEP oversight, Hercules initiated an RI/FS in
1987 to determine the nature and extent of contamination
associated with OU1 and OU2. EPA assumed the
enforcement lead for OU1 and OU2 in 2008 and in 2009,
EPA entered into an AOC with Hercules for the completion
of the RI/FS. RI/FS activities included the installation of
monitoring wells and collection of soil and groundwater
samples from the Former Plant Area; sediment, surface
water, pore water and soil samples from the Stormwater
Catchment Basin, at the 002 outfall, in the adjacent
drainageway and in Clonmell Creek and its associated
wetlands; geological, hydrogeological and residential
vapor intrusion4 investigations; preparation of a numerical
groundwater flow model; human health and ecological risk
assessments; and various treatability studies.
3 A CEA serves as an IC by providing notice that there is ground
water pollution in a localized area caused by a discharge at a
contaminated site.
SITE HYDROGEOLOGY
Site Hydrogeology
The Site geology is characterized by the presence of thick
unconsolidated sand, silt, gravel, and clay layers. The
regional aquifer system, supplying water resources to
Greenwich Township and the surrounding area, is
generally considered to consist of three aquifers (Upper
Middle, Lower Middle and Lower), which are separated by
two confining units. At the Site, alluvial deposits overlie the
regional aquifer. The "shallow" monitoring well network is
screened into these deposits which range from 0 to 25 ft.
bgs; the "intermediate" monitoring well network is
screened in the Upper Middle aquifer, ranging from 25 to
75 ft. bgs; and the "deep" monitoring wells are screened in
the Lower Middle aquifer, which ranges from 80 to 120 ft.
bgs. The depth to groundwater in the Former Plant Area
ranges between 8 and 10 ft. bgs.
Regional groundwater (intermediate and deep depths)
generally flows from north to south, exhibiting some
influence from conditions in the Delaware River.
Groundwater at the Site flows to the south and downward,
which results in shallow aquifer groundwater
contamination flowing into the underlying intermediate
aquifer and subsequently into the deep aquifer. A network
of existing groundwater recovery wells that pump from the
shallow, intermediate and deep aquifers, currently
maintains hydraulic containment of the contaminated
groundwater beneath the Site.
RESULTS OF THE REMEDIAL INVESTIGATION
Based upon the results of the Rl, EPA has concluded that
VOCs are the predominant contaminants in the Former
Plant Area groundwater and soils and the Clonmell Creek
and Stormwater Catchment Basin sediments. The
contaminants of concern (COCs) identified for the Site are
listed below in Table 1.
Table 1: Site COCs
acetophenone
ethylbenzene
benzene
lead
cumene
phenol
toluene
Benzene and cumene were found to be the most
prevalent of the COCs present at the Site.
Acetophenone, ethylbenzene, phenol and toluene are
compounds typically associated with benzene and
cumene and were only found to be present at the Site
collocated with benzene and cumene. Trichloroethylene
4 Vapor intrusion is a process by which VOCs move from a source
below the ground surface (such as contaminated groundwater)
into the indoor air of overlying or nearby buildings.
3
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(TCE) and 1,2-dichloroethane (DCA) were detected at
concentrations exceeding the Rl screening values in the
monitoring wells located in the downgradient areas of the
property, in the groundwater recovery wells associated
with the extraction and treatment system and in wells
located off-property. EPA has determined, however, that
TCE and 1,2-DCA are not Site-related and, therefore, are
not COCs. Based upon these findings, the following
discussion of the Rl results will primarily focus on
benzene and cumene.
Soil
Soil samples were collected in each of the exposure areas,
both above (unsaturated) and below (saturated) the water
table. Benzene and cumene were found to be present at
levels exceeding Rl screening values in the soils of the
Active Process Area, Chemical Landfill/Gravel Pit, Inactive
Process Area, Northern Chemical Landfill, Stormwater
Catchment Basin and Tank Farm/Train Loading Area
exposure areas. However, the bulk of the cumene and
benzene is present in the Active Process Area saturated
soils (to a depth of 17.5 ft.), either adsorbed to soil particles
or as non-aqueous phase liquid (NAPL).5
The concentrations of benzene, cumene and collocated
COCs found in the Site soils are an on-going source of
contamination to the groundwater and are considered to
be principal threat wastes. Principal threat wastes are
materials that include or contain hazardous substances,
pollutants or contaminants that act as a reservoir for the
migration of contamination to groundwater, surface water
or air or act as a source for direct exposure. The cumene
and benzene sampling results for each of the exposure
areas are summarized below in Tables 2 and 3.
Table 2: Maximum Soil Concentrations (mg/kg)
Unsaturated
Benzene
Cumene
Active Process
Area
58
17,000
Chemical
Landfill/Gravel Pit
80
11,000
Inactive Process
Area
27
2,500
Northern Chemical
Landfill
0.55
1,295
Stormwater
Catchment Basin
831
2,200
Tank Farm/Train
Loading Area
1,292
35,439
Table 3: Maximum Soil Concentrations (mg/kg)
Saturated
Benzene
Cumene
Active Process
Area
4.8
200,000
Inactive Process
Area
0
5,500
Northern Chemical
Landfill
0
460
Stormwater
Catchment Basin
130
1,700
Tank Farm/Train
Loading Area
0.3
2,400
Rl sampling results indicate the presence of lead in the
Township Refuse Area and Shooting Range soils at
concentrations as high as 2,300 mg/kg. Additional
delineation of the lead contamination in these exposure
areas is needed.
Sediment
Because no ecological screening value is available for
cumene in sediment, a Site-specific value of 120 mg/kg
was calculated for the Rl. This value was developed
based on information obtained from several studies related
to cumene toxicity on aquatic organisms.
Sediment samples were collected throughout the
Stormwater Catchment Basin (including the adjacent
drainageway) and within the on-Site reach of Clonmell
Creek (including the 002 outfall area). Upstream and
downstream sediment samples were also obtained from
Clonmell Creek. Samples were collected down to 3 ft. in
the Stormwater Catchment Basin, 0.5 ft. in the
drainageway and 5 ft. in Clonmell Creek.
Cumene concentrations were detected throughout the
Stormwater Catchment Basin, ranging from 0.00059 to
710 mg/kg and extending down to 3 ft. in the central area
of the basin. Cumene was detected in on-Site Clonmell
Creek sediment at depths ranging from 0.5 to greater than
4 ft., and at concentrations ranging from 0.0014 to 240,000
mg/kg. Cumene was not detected at concentrations
exceeding the screening value in downgradient samples
collected from Clonmell Creek on the adjacent DuPont
property.
Surface Water
Surface water samples were collected throughout the
Stormwater Catchment Basin (including the adjacent
drainageway) and within the on-Site reach of Clonmell
Creek (including the 002 outfall area). No COCs were
detected above the Rl screening values.
5 NAPLs are liquid contaminants that do not easily mix with water potentially migrate independently of groundwater and remain
and remain in a separate phase in the subsurface. They can as a residual source of groundwater contamination.
4
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Groundwater
Groundwater has been monitored both on and off the
property since 1984. A total of 92 monitoring wells are
sampled on an annual basis, with 28 of the 92 wells being
sampled quarterly. Benzene and cumene concentrations
exceeding Rl screening values were detected in the
shallow, intermediate and deep aquifers. The most
significant benzene and cumene detections were in the
shallow aquifer in the Active Process Area, Stormwater
Catchment Basin and Northern Chemical Landfill
exposure areas. Maximum concentrations detected in
each of these exposure areas are presented in below in
Table 4.
Table 4: Maximum Groundwater Concentrations (ng/L)
Benzene
Cumene
Active Process
Area
35,000
47,000
Stormwater
Catchment Basin
160
130
Northern
Chemical Landfill
200
30,000
SITE RISKS
A baseline human health risk assessment (BHHRA) was
conducted to evaluate cancer risk and noncancer health
hazards posed by exposure to Site-related contamination
in the absence of any remedial action or controls (see the
"What is Human Health Risk and How is it Calculated?"
textbox, to the right).
A screening-level ecological risk assessment (SLERA)
was also conducted to evaluate the potential for adverse
ecological effects from exposure to Site-related
contamination. Based on the findings of the SLERA, a
baseline ecological risk assessment (BERA) was
conducted to further analyze the risk posed to ecological
receptors (see the "What is Ecological Risk and How is it
Calculated?" textbox, below). The BHHRA and BERA
results are discussed below.
Human Health Risk Assessment
The human health risk estimates summarized below are
based on current reasonable maximum exposure
scenarios and were developed by considering various
conservative estimates about the frequency and duration
of an individual's exposure to the COCs, as well as the
toxicity of these contaminants.
The Site property is currently zoned for
commercial/industrial use and it is not anticipated that the
land use designation will change in the future. The
baseline risk assessment identified the current and
potential future receptors that may be affected by
contamination at the Site, the pathways by which these
receptors may be exposed to Site contaminants in various
environmental media, and the parameters by which these
WHAT IS HUMAN HEALTH RISK AND HOW IS IT
CALCULATED?
A Superfund baseline human health risk assessment is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of
any actions to control or mitigate these under current- and
future-land uses. The following four-step process is utilized
for assessing site-related human health risks for reasonable
maximum exposure scenarios.
Hazard Identification: 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 fate
and transport of the contaminants in the environment,
concentrations of the contaminants in specific media,
mobility, persistence, and bioaccumulation.
Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants in air, water, soil, etc. identified in the previous
step are evaluated. Examples of exposure pathways include
incidental ingestion of and dermal contact with contaminated
soil and ingestion of and dermal contact with contaminated
groundwater. Factors relating to the exposure assessment
include, but are not limited to, the concentrations in specific
media that people might be exposed to and the frequency
and duration of that exposure. Using these factors, a
"reasonable maximum exposure" scenario, which portrays
the highest level of human exposure that could reasonably
be expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse
health effects associated with chemical exposures and the
relationship between magnitude of exposure and severity of
adverse effects are determined. Potential health effects are
chemical-specific and may include the risk of developing
cancer over a lifetime or other non-cancer health hazards,
such as changes in the normal functions of organs within the
body (e.g., changes in the effectiveness of the immune
system). Some chemicals can cause both cancer and non-
cancer health hazards.
Risk Characterization: This step summarizes and combines
outputs of the exposure and toxicity assessments to provide
a quantitative assessment of site risks for all COPCs.
Exposures are evaluated based on the potential risk of
developing cancer and the potential for non-cancer health
hazards. The likelihood of an individual developing cancer is
expressed as a probability. For example, a 1x10"4 cancer risk
means a "one in ten thousand excess cancer risk;" or one
additional cancer may be seen in a population of 10,000
people as a result of exposure to site contaminants under the
conditions identified in the Exposure Assessment. Current
Superfund regulations for exposures identify the range for
determining whether remedial action is necessary as an
individual excess lifetime cancer risk of 1x10-4 to 1 x10 6,
corresponding to a one in ten thousand to a one in a million-
excess cancer risk. For non-cancer health effects, a "hazard
index" (HI) is calculated. The key concept for a non-cancer
HI is that a threshold (measured as an HI ofless than or equal
to 1) exists below which non-cancer health hazards are not
expected to occur. The goal of protection is 10"6 for cancer
risk and an HI of 1 for a non-cancer health hazard. Chemicals
that exceed a 10"4 cancer risk or an HI of 1 are typically those
that will require remedial action at the site and are referred to
as COCs in the ROD.
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exposures and risks were quantified. The receptors
evaluated under the current/future scenarios included
outdoor industrial workers, construction/utility
workers,trespassers, residents (vapor intrusion),
recreational youth, recreational hikers, recreational
hunters and recreational anglers.6 Future scenarios also
considered the exposure of indoor workers and on- and
off-Site residents to groundwater as drinking water.
The risks associated with potential exposures to Site soils,
surface water, and sediments, as well as groundwater, on-
and off-property, were assessed. The area is served by
municipal water, therefore, it is not likely that the
groundwater underlying the Site will be used for potable
purposes in the foreseeable future. However, potential
exposure to groundwater was evaluated because regional
groundwater is designated as a drinking water source.
The potential for off-Site indoor air vapor intrusion into
nearby residences, was also evaluated by EPA and
determined not to warrant further assessment. However,
because no buildings were present on-Site at the time of
the vapor intrusion investigation and VOCs are present in
Site soils and groundwater above Rl screening values, a
deed notice will be placed on the property requiring that
future on-Site buildings either be constructed with a vapor
barrier or be evaluated for the vapor intrusion pathway
prior to occupancy and periodically (e.g., annually) until
EPA determines that the pathway is incomplete.
The following exposure pathways resulted in excess
lifetime cancer risks that exceed EPA's target risk range of
1x10 4 to 1x10 6: current/future outdoor industrial workers
(Sitewide: 3x10 4) as a result of direct contact with benzene
and cumene in the shallow aquifer and future on-Site
residents (Active Process Area: up to 8x10 3, Northern
Chemical Landfill Area: up to 2x10-4 and Tank Farm/Train
Loading Area: up to 2x10-4) as a result of direct contact
with benzene, cumene, phenol, TCE and 1,2-DCA in the
intermediate/deep aquifer.7
The following exposure pathways resulted in a noncancer
hazard index (HI) greater than the EPA threshold value of
one: future residents (Active Process Area: HI up to 168
for children) as a result of ingestion of benzene, cumene,
phenol and 1,2-DCA in the intermediate/deep aquifer,
current/future outdoor industrial workers (Sitewide: HI of
8.8 and Inactive Process Area: HI up to 11.6) and
current/future construction/utility workers (Sitewide: HI of
3.2, mainly resulting from exposure in the Inactive Process
Area) as a result of dermal contact with benzene and
cumene in the shallow aquifer.
6 Recreational anglers were evaluated because Clonmell Creek
is fishable, however, access controls are in-place to prevent
fishing on-Site.
7 Phenol is present in the Active Process Area and Tank
Farm/Train Loading Area groundwater at levels that pose a
6
The following modeled exposure pathways resulted in
elevated blood lead levels [over 5 migrograms per deciliter
(|u,g/dL)] as a result of direct contact with lead in soils:
outdoor industrial workers in the Shooting Range exposure
area (11.8 p.g/dL) and Township Refuse Area (6.3 p.g/dL)
and construction/utility workers in the Shooting Range
exposure area (17.2 p.g/dL) and Township Refuse Area
(7.9 |ag/dL).
Ecological Risk Assessment
Sediment, surface water, pore water and soil samples
were collected as part of the ecological risk assessment.
The areas of the Site evaluated in the BERA include the
Stormwater Catchment Basin (including at the 002 outfall
and within the adjacent drainageway), Clonmell Creek and
the adjacent wetland area. Aquatic plants, benthic
invertebrates and fish, and semi-aquatic mammals and
birds were assessed in the Stormwater Catchment Basin
(including at the 002 outfall and within the adjacent
drainageway) and in Clonmell Creek. In the wetland area,
terrestrial plants and invertebrates along with terrestrial
mammals and birds were evaluated. Toxicity testing and
macroinvertebrate surveys were also conducted to support
the BERA.
Measurement endpoints consisted of a comparison of
estimated or measured exposure levels of contaminants to
levels reported to cause adverse effects, evaluation of
macroinvertebrate community metrics, sediment toxicity
testing results, and comparison of observed effects at the
site with those observed at reference locations. The results
for each ecological area evaluated in the BERA are
summarized below.
The results of the macroinvertebrate survey in the
Stormwater Catchment Basin indicated a slight to
moderate impairment of the benthic community. Toxicity
testing indicated a significant decrease in survival
compared to the reference location. The potential for
adverse effects to semi-aquatic mammals and birds is
negligible.
The results of the macroinvertebrate survey in the
drainageway indicated the presence of a slightly impaired
benthic community with marginal habitat quality. No
significant toxicity was observed and risk to mammalian
and avian receptors is considered negligible.
The results of the macroinvertebrate survey in Clonmell
Creek suggest a moderately impaired benthic community
at several locations and suboptimal habitat quality at most
locations. Toxicity testing results at several sampling
human health exposure risk. Although TCE is present in the
Tank Farm/Train Loading Area groundwater and 1,2-DCA is
present in the Active Process Area groundwater at levels that
pose a human health exposure risk, EPA has determined that
these contaminants are not Site-related, and therefore, are not
COCs.
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locations indicated a significant decrease in survival
compared to the reference location. Unacceptable risk to
mammalian receptors was identified, primarily due to
exposure to cumene.
In the Clonmell Creek Wetland Area, the likelihood of
adverse effects to terrestrial plants and invertebrates,
mammals and birds exposed to contaminants in wetlands
soils is essentially non-existent.
The BERA concluded that there is a potential for adverse
ecological effects associated with Site contaminants in the
sediments of the Stormwater Catchment Basin and in
Clonmell Creek, in the vicinity of the 002 outfall.
Based upon the results of the Rl and risk assessments,
EPA has determined that actual or threatened releases of
hazardous substances from the Site, if not addressed by
the preferred remedy or one of the other active measures
considered, may present a current or potential threat to
human health and the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to
protect human health and the environment. These
objectives are based on available information and
standards, such as applicable or relevant and appropriate
requirements (ARARs), to-be-considered (TBC) guidance,
and site-specific risk-based levels.
The following RAOs were established for the Site:
Protect human health by preventing exposure to
contaminated groundwater, soil and soil vapor;
Prevent off-Site migration of contaminated
groundwater;
Minimize exposure of fish, biota and wildlife to
contaminated sediments;
Mitigate potential for contaminant migration from soils
into groundwater and surface water; and
Restore groundwater to levels that meet state and
federal standards within a reasonable time frame.
EPA and NJDEP have promulgated maximum
contaminant limits (MCLs) and NJDEP has promulgated
groundwater quality standards (GWQSs), which are
enforceable, health-based, protective standards for
various drinking water contaminants. The more stringent
of the MCLs and GWQSs will be used as the preliminary
remediation goals (PRGs) for the COCs in the Site
groundwater.
WHAT IS ECOLOGICAL RISK AND HOW IS IT
CALCULATED?
A Superfund baseline ecological risk assessment is an
analysis of the potential adverse health effects to biota
caused by hazardous substance releases from a site in the
absence of any actions to control or mitigate these under
current and future land and resource uses. The process used
for assessing site-related ecological risks includes:
Problem Formulation: In this step, the contaminants of
potential ecological concern (COPECs) at the site are
identified. Assessment endpoints are defined to determine
what ecological entities are important to protect. Then, the
specific attributes of the entities that are potentially at risk and
important to protect are determined. This provides a basis for
measurement in the risk assessment. Once assessment
endpoints are chosen, a conceptual model is developed to
provide a visual representation of hypothesized relationships
between ecological entities (receptors) and the stressors to
which they may be exposed.
Exposure Assessment: In this step, a quantitative
evaluation is made of what plants and animals are exposed
to and to what degree they are exposed. This estimation of
exposure point concentrations includes various parameters
to determine the levels of exposure to a chemical
contaminant by a selected plant or animal (receptor), such as
area use (how much of the site an animal typically uses
during normal activities); food ingestion rate (how much food
is consumed by an animal over a period of time);
bioaccumulation rates (the process by which chemicals are
taken up by a plant or animal either directly from exposure to
contaminated soil, sediment or water, or by eating
contaminated food); bioavailability (how easily a plant or
animal can take up a contaminant from the environment); and
life stage (e.g., juvenile, adult).
Ecological Effects Assessment: In this step, literature
reviews, field studies or toxicity tests are conducted to
describe the relationship between chemical contaminant
concentrations and their effects on ecological receptors, on a
media-, receptor- and chemical-specific basis. To provide
upper and lower bound estimates of risk, toxicological
benchmarks are identified to describe the level of
contamination below which adverse effects are unlikely to
occur and the level of contamination at which adverse effects
are more likely to occur.
Risk Characterization: In this step, the results of the
previous steps are used to estimate the risk posed to
ecological receptors. Individual risk estimates for a given
receptor for each chemical are calculated as a hazard
quotient (HQ), which is the ratio of contaminant concentration
to a given toxicological benchmark. In general, an HQ above
1 indicates the potential for unacceptable risk. The risk is
described, including the overall degree of confidence in the
risk estimates, summarizing uncertainties, citing evidence
supporting the risk estimates and interpreting the adversity of
ecological effects.
7
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The more stringent of the NJDEP nonresidential direct
contact soil remediation standards (NRDCSRSs) and the
NJDEP default impact to groundwater soil remediation
standards (IGWSRS) will be used as the Site PRGs for the
unsaturated soils. Because there is no default IGWSRS
established for cumene, a Site-specific value was
developed using the NJDEP Soil-Water Partition Equation
Calculator (back calculated from either the MCL or
GWQS). The NJDEP NRDCSRSs will be used as the Site
PRGs for the saturated soils. When no NRDCSRS is
available, the EPA RSL for industrial soil will be used.
As discussed above, because there is no screening value
available for cumene in sediment, a Site-specific value of
120 mg/kg was developed for comparison with the Rl
sampling results. In lieu of developing a Site-specific
sediment cleanup criterion for cumene, a mass-removal
based approach will be used to ensure that the RAO of
minimizing exposure of fish, biota and wildlife to
contaminated sediments is achieved. The goal for
cumene mass removal is 100% for the Stormwater
Catchment Basin and 99% for Clonmell Creek.
The PRGs established for the Site COCs are identified in
Table 5 below.
Table 5: Site PRGs
coc
Unsaturated
Soil
(mg/kg)
Saturated
Soil (mg/kg)
Groundwe
(mg/L)
acetophenone
3
5
700
benzene
0.005
5
1
cumene
28
990
700
ethylbenzene
13
25
700
lead
90
800
5
phenol
8
25,000
2,000
toluene
7
4,700
600
EPA has determined that the COCs acetophenone,
ethylbenzene and toluene, which were found at the Site
collocated with the primary COCs, cumene and benzene,
do not pose a human health exposure risk. These
contaminants are COCs because they are present at
concentrations that exceed the ARARs.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA §Section121 (b)(1), 42 U.S.C. § 9621(b)(1),
mandates that remedial actions must be protective of
human health and the environment, cost-effective, comply
with ARARs, and utilize permanent solutions and alterna-
tive 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
permanently and significantly reduce the volume, toxicity,
or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA Section§121(d), 42
U.S.C. § 9621(d), further specifies that a remedial action
must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants, which at least
attains ARARs under federal and state laws, unless a
waiver can be justified pursuant to CERCLA
Section§121 (d)(4), 42 U.S.C. § 9621(d)(4).
Detailed descriptions of the remedial alternatives for
addressing the contamination associated with the Site can
be found in the FS report. To facilitate the presentation
and evaluation of the alternatives, the FS report
alternatives were reorganized in this Proposed Plan to
formulate the remedial alternatives discussed below.
The construction time for each alternative reflects only the
time required to construct or implement the remedy and
does not include the time required to design the remedy,
negotiate the performance of the remedy with any
potentially responsible parties, or procure contracts for
design and construction.
A number of studies were conducted during the Rl to
evaluate the use of various treatment techniques and
processes to address the contamination at the Site. A
treatability study was conducted in the Active Process
Area exposure area to evaluate the use of both
aerobically- and anaerobically-enhanced biodegradation
to treat source-area soils. Because the study results
showed that anaerobically-enhanced biodegradation
resulted in greater cumene concentration reductions, only
anaerobic processes were considered for in-situ soil
treatment.
An air sparging/soil vapor extraction pilot test was also
performed in the Active Process Area. Based upon the
results of the study, it was concluded that the
heterogeneity of the soil conditions at the Site resulted in
preferential flow paths in the subsurface lithology that
inhibited the effective treatment of air flow through the
saturated soil. Because this would likely limit the
effectiveness of the treatment technology, this technology
was eliminated from further consideration.
In addition, a pilot study was conducted in Clonmell Creek
to evaluate the use of hydraulic dredging versus
mechanical excavation for the removal of contaminated
sediments. Hydraulic dredging was determined to be the
more suitable of the two removal techniques because of its
ability to target the unconsolidated sediments rather than
the underlying clay, its ability to minimize fugitive
emissions and downstream sediment transport, and the
minimal impact that it has on the surrounding wetland area.
Therefore, only hydraulic dredging is considered for the
sediment alternatives involving dredging.
8
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Along with the pilot study, a 12-month treatability study
was conducted on the dredged material to evaluate the
viability of utilizing phytoremediation for the treatment of
the cumene-contaminated sediments at the Site.
Phytoremediation can occur through several
mechanisms, including stabilization, accumulation,
volatilization, degradation, and rhizosphere
biodegradation. During the study period, plants were
allowed to grow in the dredged sediment. At the end of
the study period, sediment and plant tissue samples
(above- and below-ground) were collected. The study
results showed that the cumene in the sediment was
reduced from concentrations ranging from 18 to 98 mg/kg
to concentrations ranging from "non-detect" to 0.10
mg/kg. Cumene was not detected in any of the plant
tissue samples, indicating that the cumene was destroyed
through rhizosphere degradation, which is the breakdown
of contaminants in the rhizosphere (soil surrounding the
roots of plants) through microbial activity that is enhanced
by the presence of plant roots. Based upon these results,
it was determined that cumene-contaminated sediments
at the Site can effectively be treated using
phytoremediation.
As was noted above, for more than 30 years, a
groundwater extraction and treatment system has been
operated at the Site as an interim action. This system has
successfully reduced contaminant concentrations in the
groundwater and prevented contaminated groundwater
from migrating off-property. Because of the effectiveness
of the existing system and the anticipated removal of the
contaminant source under an active soil remedial
alternative, additional groundwater alternatives to address
this groundwater contamination were not considered. The
remedial alternatives are summarized below.
Soil Alternative S-1: No Action
Capital Cost:
$0
Annual OM&M Cost:
$0
Present-Worth Cost:
$0
Construction Time:
0 months
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison
with the other alternatives. The no-action remedial
alternative for soil does not include any physical remedial
measures that address the soil contamination at the Site.
Because this alternative would result in contaminants
remaining above levels that allow for unrestricted use and
unlimited exposure, CERCLA requires that the Site be
reviewed at least once every five years. If justified by the
review, remedial actions may be implemented to remove,
treat, or contain contaminated soils.
Soil Alternative S-2: Excavation with Off-Site Disposal
and Enhanced In-Situ Biodegradation
Capital Cost:
$11,183,360
Annual OM&M Cost:
$248,181
Present-Worth Cost:
$12,191,308
Construction Time:
12 months
Under this alternative, the soils in the Chemical
Landfill/Gravel Pit, Northern Chemical Landfill, Stormwater
Catchment Basin and Tank Farm/Train Loading Area
exposure areas with COC concentrations exceeding the
PRGs would be excavated to a depth of 4 ft. bgs in
preparation for the enhanced in-situ biodegradation
process discussed below. As noted above, significant
subsurface structures remain in the Active Process Area
and Inactive Process Area. Because the presence of
these structures would make excavation impracticable, a
limited volume [approximately 500 cubic yards (CY)] of the
soils in these exposure areas exceeding the PRGs would
be treated in-situ rather than being excavated.
The soil in the Township Refuse Area with lead
concentrations exceeding the PRGs would be excavated.
A Best Management Practices (BMP) plan would be
developed and implemented to manage lead and minimize
contamination of the Shooting Range exposure area while
the shooting range remains active. If the shooting range
becomes inactive, delineation of the lead contamination
would be performed and the soils the in the Shooting
Range exposure area with lead concentrations exceeding
the PRGs would be excavated and disposed of off-Site.
An estimated 13,804 CY of contaminated soil would be
excavated under this alternative, consisting of 1,052 CY8
of lead-contaminated soil and 12,752 CY of soil
contaminated with benzene, cumene and collocated
COCs.
The contaminated soil would be excavated using standard
construction equipment, such as backhoes and track
excavators. The excavated soil would be placed directly
onto a dump truck and transported to an on-Site staging
area. The staging area would be designed with proper
controls, including, but not limited to, an impermeable liner,
to maintain containment of the excavated soils and prevent
any impacts to the surrounding soil and groundwater. The
lead-contaminated soils would be segregated from other
soils at the staging location because they may require
disposal at a different facility. The excavated soil would
then be sampled and transported off-Site for treatment
and/or disposal at a Resource Conservation and Recovery
Act (RCRA)-compliant facility.
8 The estimated soil excavation volumes and associated costs do
not include the lead-contaminated soil in the Shooting Range
exposure area.
9
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Post-excavation sampling would be conducted to
identify/confirm the areas where the PRGs are exceeded
in the soils situated below 4 ft. bgs These soils (saturated
and unsaturated) would be treated using enhanced in-situ
biodegradation. Enhanced in-situ biodegradation would
involve applying a magnesium sulfate solution to the
contaminated soils to stimulate activity and reproduction in
naturally-occurring anaerobic microorganisms. The
microorganisms would then destroy or transform the
COCs into less toxic compounds by using them as a food
and energy source. Because the extent of the
contamination is much greater and deeper in the Active
Process Area and Inactive Process Area than in the other
exposure areas, application of the anaerobic treatment
solution would be achieved using lateral infiltration
galleries, consisting of perforated piping installed at the
base of the excavated areas. The solution would be
applied directly to the base of the excavations in the
Chemical Landfill/Gravel Pit, Northern Chemical Landfill,
Stormwater Catchment Basin and Tank Farm/Train
Loading Area exposure areas. The final design criteria for
the infiltration galleries would be detailed in the remedial
design.
Certified clean soil, meeting applicable state regulations,
would be imported and used to backfill excavated areas
and construct an engineered soil cover in the Active
Process Area, Inactive Process Area and the Tank
Farm/Train Loading Area to reduce infiltration of surface
water to the groundwater and control surface water
runoff/drainage. Vegetation would be placed in areas
disturbed during excavation activities to stabilize the soil
and maintenance of the soil cover would be performed.
Performance and compliance monitoring would be
conducted to determine residual contaminant
concentrations and assess the need for additional
treatment. The estimated timeframe to achieve the RAOs
and meet the PRGs under this alternative is 10 years. An
IC, in the form of a deed notice, would be put in place to
prevent intrusive activities in in-situ treatment areas until
the PRGs are met.
Soil Alternative S-3: Excavation with Off-Site Disposal,
Ex-Situ Bioremediation/Reuse and Enhanced In-Situ
Biodegradation
Capital Cost:
$5,198,118
Annual OM&M Cost:
$248,181
Present-Worth Cost:
$6,206,066
Construction Time:
18 months
Under this alternative, the contaminated soils would be
excavated as detailed above for Alternative S-2. The
volumes and on-Site handling of excavated soils and the
backfilling of excavated areas with certified clean fill would
be the same as for Alternative S-2, the lead-contaminated
soil from the Township Refuse Area would be transported
to an off-Site treatment and/or disposal facility. This
alternative would also include the development and
implementation of a BMP plan in the Shooting Range, as
described in Alternative S-2.
The soils excavated from the Chemical Landfill/Gravel Pit,
Northern Chemical Landfill, Stormwater Catchment Basin
and Tank Farm/Train Loading Area exposure areas would
be treated on-Site using ex-situ bioremediation instead of
being transported of-Site for treatment/disposal.
Conventional methods of ex-situ bioremediation include
biopiles/composting, landfarming with tilling,
phytoremediation or a combination of these methods. All
methods were evaluated in the FS and
biopiles/composting was determined to be the most
suitable for application at the Site.
The excavated soil would be mixed with soil amendments,
formed into piles and aerated, either passively or actively
(using blowers or vacuum pumps). As part of the remedial
design, an analysis would be performed to confirm that
the average VOC concentrations that may be generated
and released from ex-situ treatment of the soils would not
exceed applicable state and federal air emissions
standards. If air emissions controls are determined to be
necessary based upon these calculations, then those
controls would be detailed in the remedial design. In
addition, vapors from the VOCs in the biopiles that
volatilize into the air would be monitored to protect Site
workers and ensure that state and federal air emission
standards are not exceeded. Post-remedial sampling
would be conducted to ensure that the PRGs are met.
The ex-situ-remediated soils would be reused on-Site as
part of an engineered soil cover in the Active Process
Area, Inactive Process Area and the Tank Farm/Train
Loading Area to reduce infiltration of surface water to the
groundwater and control surface water runoff/drainage.
Vegetation would be placed in areas disturbed during
excavation activities to stabilize the soil and maintenance
of the soil cover would be performed for a period of 15
years.
The contaminated soils situated below 4 ft. bgs in the
excavated areas would be treated using enhanced in-situ
biodegradation, as described in Alternative S-2. The
estimated timeframe to achieve the RAOs and meet the
PRGs under this alternative is 10 years. An IC, in the form
of a deed notice, would be put in place to prevent intrusive
activities in in-situ treatment areas until the PRGs are met.
10
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Sediment Alternative SED-1: No Action
Capital Cost:
$0
Annual OM&M Cost:
$0
Present-Worth Cost:
$0
Construction Time:
0 months
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison
with the other alternatives. The no-action remedial
alternative for sediment does not include any physical
remedial measures that address the sediment contamina-
tion at the Site.
Because this alternative would result in cumene remaining
in the sediments above levels that allow for unrestricted
use and unlimited exposure, CERCLA requires that the
Site be reviewed at least once every five years. If justified
by the review, remedial actions may be implemented to
remove, treat, or contain contaminated sediments.
Sediment Alternative SED-2: Hydraulic Dredging with
Off-Site Disposal
Capital Cost:
$4,086,780
Annual OM&M Cost:
$0
Present-Worth Cost:
$4,086,780
Construction Time:
12 months
Under this alternative, a hydraulic dredge would remove a
mixture of contaminated sediment and water (referred to
as slurry) from the bottom surfaces of the Stormwater
Catchment Basin and Clonmell Creek. The work area
would be enclosed with silt curtains to prevent downstream
migration of contaminated sediment during dredging
activities. Also, the surface water outside the work area
would be monitored to ensure that contaminated
sediments are not being resuspended in the water column
and transported downstream.
The slurry would be transferred via pipeline into geotextile
tubes (located in a staging area) for dewatering. The
staging area would be designed with proper controls,
including but not limited to an impermeable liner, to prevent
any impacts to the surrounding soil and groundwater and
maintain containment of the dredged sediments and
effluent water from the geotextile tubes.
The effluent would be sampled and, if necessary, treated
on-Site before being discharged to the Stormwater
Catchment Basin in compliance with substantive New
Jersey Pollutant Discharge Elimination System (NJPDES)
discharge to groundwater permit requirements. The details
of the effluent treatment system would be finalized during
the remedial design. Monitoring of groundwater wells
around the Stormwater Catchment Basin would be
conducted to ensure compliance with substantive permit
requirements. The dewatered solids left in the geotextile
tubes would be transported off-Site to a RCRA-compliant
treatment and/or disposal facility.
As discussed above, because there is no screening value
available for cumene in sediment, a Site-specific value of
120 mg/kg was developed for comparison with the Rl
sampling results. In lieu of developing a Site-specific
sediment cleanup value for cumene, the volumes of
sediment to be dredged were determined using a mass-
removal approach. It is estimated that 1,225 CY of
sediment from the Stormwater Catchment Basin and 7,275
CY of sediment from Clonmell Creek would be dredged.
These volumes represent removal of 100 percent of the
cumene mass in the Stormwater Catchment Basin
sediment and approximately 99 percent of the cumene
mass within the Clonmell Creek sediment and include all
the sediment identified in the BERA as posing a risk to
ecological receptors. The estimated timeframe to achieve
RAOs under this alternative is 12 months.
Sediment Alternative SED-3: Hydraulic Dredging with
On-Site Treatment/Reuse
Capital Cost:
$1,860,320
Annual OM&M Cost:
$0
Present-Worth Cost:
$1,860,320
Construction Time:
24 months
This alternative is the same as Alternative SED-2, except
instead of being transported off-Site for treatment and/or
disposal, the dredged sediments would be treated on-Site
using phytoremediation and, if necessary, ex-situ
bioremediation.
Under this alternative, the geotextile tubes would be
located in a treatment area, designed with proper
controls, including but not limited to an impermeable liner,
to maintain containment of the dredged sediments and
prevent any impacts to the surrounding soil and
groundwater. Plants would be planted in the cumene-
contaminated sediment within the geotextile tubes for a
pre-determined growth period9.
Based upon the results obtained during the
phytoremediation pilot study, it is expected that cumene
concentrations in the sediment would be reduced to "non-
detect." However, if sampling results indicate that
cumene concentrations remain above the PRGs10 at the
end of the growth period, then ex-situ bioremediation, as
described above for Alternative S-3, would be used to
further treat the sediments.
9 Additional studies would be conducted during the remedial
design phase to refine plant species selection and determine
the optimal growth period.
11
10 Because the treated sediment would be reused on-Site in an
engineered soil cover, the final COC concentrations would
need to meet the unsaturated soil PRGs.
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The treated sediments would be reused on-Site as part of
an engineered soil cover in the Active Process Area,
Inactive Process Area and the Tank Farm/Train Loading
Area to reduce infiltration of surface water to the
groundwater and control surface water runoff/drainage.
The plant residuals would be harvested and composted
on-Site. The estimated timeframe to achieve RAOs under
this alternative is 18 months.
Groundwater Alternative GW-1: No Further Action
Capital Cost:
$0
Annual OM&M Cost:
$0
Present-Worth Cost:
$0
Construction Time:
0 months
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison
with the other alternatives. Underthis remedial alternative,
operation of the existing groundwater treatment system
would be discontinued and no further remedial measures
would be taken to address the groundwater contamination
at the Site.
Because this alternative would result in contaminants
remaining on-Site above levels that allow for unrestricted
use and unlimited exposure, CERCLA requires that the
Site be reviewed at least once every five years. If justified
by the review, remedial actions may be implemented to
treat the contaminated groundwater.
Groundwater Alternative GW-2: Extraction with On-
Site Treatment and Long-Term Monitoring
Capital Cost:
$409,826
Annual OM&M Cost:
$225,938
Present-Worth Cost:
$3,181,534
Construction Time:
12 months
As discussed above, as an interim remedy, operation of a
groundwater extraction and treatment system has been
on-going at the Site since 1984. The current system
consists of extraction wells and subsurface pipelines that
capture and carry contaminated groundwater into a
treatment unit (currently housed in an on-Site trailer), with
a treatment capacity of 125 gallons per minute (gpm). The
treatment process consists of filtration through sand units
to reduce iron and suspended solids, followed by
transmission through a series of granular activated carbon
(GAC) canisters to remove the COCs. The treated
groundwater is then pumped through a pipeline and
discharged into the Delaware River under a NJPDES
discharge to surface water permit. Groundwater quality
monitoring is conducted on a quarterly basis to verify that
the system continues to maintain hydraulic control of the
contaminated groundwater beneath the Site.
Under this alternative, a new treatment unit, with an
approximate treatment capacity of 125 gpm, would be built
to replace/upgrade the existing one and a small building
would be constructed in the Stormwater Catchment Basin
exposure area to house the new treatment unit. The
extracted groundwater would be pumped from the existing
extraction well infrastructure into an equalization tank
within the treatment building and then treated with a
polymer. The polymer would be combined with pH
adjustment, if necessary, to promote flocculation of iron
and other solids in the groundwater.
The groundwater would then be pumped through
conventional geotextile tubes followed by GAC-
impregnated geotextile tubes, if necessary, to remove iron
and solids and treat the COCs. The flocculated iron and
solids would be captured in the geotextile tubes. The
COCs would partition to the solids in the geotextile tubes
where they would biodegrade. The spent tubes would be
transported off-Site to a permitted disposal facility.
Treated water would be discharged to the groundwater in
compliance with substantive NJPDES discharge to
groundwater permit requirements (using the Stormwater
Catchment Basin as an infiltration point). Long-term
groundwater monitoring would be continued until the
PRGs are met.
It is estimated that, in combination with active treatment of
source-area soils, it would take 10 years to remediate the
contaminated groundwater to PRGs underthis alternative.
However, a conservative 15-year timeframe is used for
groundwater monitoring to provide maximum protection of
human health and the environment. The groundwater
monitoring timeline may be truncated if the PRGs can be
met in a shorter timeframe.
ICs would be put in place at the Site, including the
establishment of a CEA to prevent groundwater use and
the placement of a deed notice on the property, restricting
the land use to commercial/industrial and requiring that
future buildings on the Site either be subject to a vapor
intrusion evaluation or be built with vapor intrusion
mitigation systems until the PRGs are met.
Because this alternative would result in contaminants
remaining on-Site above levels that allow for unrestricted
use and unlimited exposure, CERCLA requires that the
Site be reviewed at least once every five years.
COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives,
each alternative is assessed against nine evaluation
criteria, namely, overall protection of human health and the
environment, compliance with applicable or relevant and
appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume
through treatment, short-term effectiveness,
implementability, cost, and state and community
acceptance. The evaluation criteria are described below.
12
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Overall protection of human health and the environment
addresses whether a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum
exposure scenario) are eliminated, reduced, or controlled
through treatment, engineering controls, or ICs.
Compliance with ARARs addresses whether a remedy
would meet all the applicable or relevant and appropriate
requirements of other federal and state environmental
statutes and requirements or provide grounds for invoking
a waiver.
Long-term effectiveness and permanence refers to the
ability of a remedy to maintain reliable protection of human
health and the environment overtime, once cleanup goals
have been met. It also addresses the magnitude and
effectiveness of the measures that may be required to
manage the risk posed by treatment residuals and/or
untreated wastes.
Reduction in toxicity, mobility, or volume through treatment
is the anticipated performance of the treatment
technologies, with respect to these parameters, a remedy
may employ.
Short-term effectiveness addresses the time needed to
achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup
goals are achieved.
Implementabilitv is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
Cost includes estimated capital and OM&M costs, and net
present-worth costs.
State acceptance indicates if, based on its review of the
RI/FS and Proposed Plan, the state concurs with the
preferred remedy at the present time.
Community acceptance will be assessed in the ROD and
refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports.
The following is a comparative analysis of these
alternatives, based upon the evaluation criteria noted
above.
Overall Protection of Human Health and the
Environment
because these alternatives would employ a remedial
strategy capable of removing/treating the source of
groundwater contamination and the threat to public
health.
Alternative SED-1 would not be protective of the
environment because no action would be taken to
eliminate or mitigate ecological exposure to the
contaminated sediments in the Stormwater Catchment
Basin and Clonmell Creek. Alternatives SED-2 and SED-
3 would be protective of the environment because, under
these alternatives, the contaminated sediments posing an
ecological risk in the Stormwater Catchment Basin and
Clonmell Creek would be removed.
Alternative GW-1 would not be protective of human health
because it would not prevent off-Site migration or actively
treat the contaminated groundwater, which poses a
human health risk. Alternative GW-2 would be protective
of human health because it would rely upon groundwater
extraction to prevent contamination from reaching
downgradient receptors and active treatment to restore
groundwater quality to levels that meet state and federal
standards within a reasonable time frame. The ICs under
Alternative GW-2 would provide protection of public
health until groundwater standards are met.
Compliance with ARARs
Soil PRGs forthe Site were established based on NJDEP's
NRDCSRSs and IGWSRS (chemical-specific ARARs) and
EPA's RSLs for industrial soil (TBC criteria).
No action would be taken under Alternative S-1 to
address contaminated soils. Therefore, this alternative
would not achieve the soil PRGs. Alternatives S-2 and S-
3 would comply with ARARs because both alternatives
would actively remediate contaminated soil to achieve the
soil PRGs.
Because Alternatives S-2 and S-3 would involve the
excavation of contaminated soils, these alternatives
would require compliance with fugitive dust and VOC
emission regulations.
Both Alternatives S-2 and S-3 would be subject to state
and federal regulations related to the transportation and
off-site treatment and/or disposal of wastes.
There are currently no federal or state promulgated
standards for contaminant levels in sediments. There are,
however, other federal or state advisories, criteria, or
guidance (which are used as TBC criteria). Specifically,
New Jersey Ecological Screening Criteria (NJESC) are
TBC criteria. The primary location-specific ARARs for
sediment would be the Freshwater Wetlands Protection
Act (NJSA 13:9B-1 et seq.) and Flood Hazard Area
Control Act Regulations (NJAC 7:13-10 and 11).
Alternative SED-1 would not take any action to address
contaminated sediments exceeding NJESC and,
Alternative S-1 would not be protective of human health
because it would not actively address the contaminated
soils, which are acting as a source of contamination to the
groundwater and pose a human health risk. Alternatives
S-2 and S-3 would be protective of human health,
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therefore, would not comply with this TBC criteria.
Alternatives SED-2 and SED-3 would comply with NJESC
because these alternatives would involve removing the
contaminated sediments posing a risk to ecological
receptors in the SCB and Clonmell Creek. Alternatives
SED-2 and SED-3 would result in minimal disturbance to
the surrounding area and would not likely involve
replacing the dredged sediment, therefore, both
alternatives would comply with location-specific ARARs.
EPA and NJDEP have promulgated MCLs and NJDEP
has promulgated GWQSs, which are enforceable health-
based, protective standards for various drinking water
contaminants (chemical-specific ARARs). Although the
groundwater at the Site is not presently being utilized as
a potable water source, achieving MCLs in the
groundwater is an applicable standard because the
aquifer beneath the Site is designated as a Class ll-A
potable water source.
Alternative GW-1 would not provide for any direct
remediation of groundwater and would, therefore, rely
upon natural processes to achieve chemical-specific
ARARs. Alternative GW-2 would be more effective in
reducing groundwater contaminant concentrations below
MCLs and GWQSs, because it involves active
remediation of the contaminated groundwater.
Alternative GW-2 would also be subject to discharge to
groundwater ARARs because treated water would be
discharged to the groundwater using the Stormwater
Catchment Basin as an infiltration point.
The provisions of State of New Jersey Administrative
Requirements for the Remediation of Contaminated Sites
(N.J.A.C. 7:26C) are applicable to the ICs included in
Alternatives S-2, S-3 and GW-2.
Long-Term Effectiveness and Permanence
Alternative S-1 would not involve any active remedial
measures and, therefore, would not be effective in
preventing exposure to contaminants in the soil and would
allow the continued migration of contaminants from the soil
to the groundwater. Alternatives S-2 and S-3 would both
be effective in the long term and would provide permanent
remediation by removing contaminated soils (from 0-4 ft.
bgs) in the Chemical Landfill/Gravel Pit, Northern
Chemical Landfill, Stormwater Catchment Basin, and Tank
Farm/Train Loading Area exposure areas and either
treating them on-Site or treating/disposing of them off-Site,
and by treating the source-area soils in the Active Process
Area exposure area to achieve the PRGs. Both
Alternatives S-2 and S-3 would rely on an IC, in the form
of a deed notice, to prevent intrusive activities in in-situ
treatment areas until the PRGs are met and would
maintain reliable protection of human health and the
environment over time.
of off-Site, whereas Alternative S-3 would involve treating
the excavated VOC-contaminated soils on-Site and
reusing the treated soils as part of an engineered soil
cover. Alternative S-2 would result in a more rapid
reduction in risk, because the contaminated soils would
be removed from the Site. However, it is anticipated that,
under Alternative S-3, proper management and
successful treatment of VOCs in the soils would be
achievable within a reasonable timeframe using ex-situ
bioremediation. Therefore, on-Site reuse of the treated
soils would not result in an unacceptable exposure risk at
the Site.
Alternative SED-1 would not involve any active remedial
measures and, therefore, would not be effective in
minimizing the exposure of ecological receptors to
contaminated sediments. Alternatives SED-2 and SED-3
would be equally effective in the long term and both would
provide permanent remediation by removing the
contaminated sediments posing a risk to ecological
receptors in the Stormwater Catchment Basin and
Clonmell Creek.
Under Alternative SED-2, the contaminated sediments
would be disposed of off-Site, whereas Alternative SED-
3 would involve treating the contaminated sediments on-
Site and reusing the treated sediments as part of an
engineered soil cover. Alternative SED-2 would result in
a more rapid reduction in risk, because the contaminated
sediments would be removed from the Site. However, it
is anticipated that, under Alternative SED-3, proper
management and successful remediation of cumene in
the sediments (to non-detectable concentrations) would
be achievable within a reasonable timeframe using
phytoremediation and, if necessary, ex-situ
bioremediation. Therefore, on-Site reuse of the treated
sediments would not result in an unacceptable exposure
risk at the Site.
Alternative GW-1 would be expected to have minimal long-
term effectiveness and permanence because it would rely
upon natural processes to restore groundwater quality and
would not prevent off-Site migration of contaminated
groundwater. Alternative GW-2 would provide long-term
effectiveness and permanence because it would rely on
groundwater extraction and treatment and ICs (in
combination with one of the action soil alternatives) to
achieve the PRGs, prevent off-Site migration of
contaminants, and prevent human exposure to
contaminated groundwater and soil vapor.
Reduction in Toxicity, Mobility or Volume Through
Treatment
Alternative S-1 would involve no active remedial measures
and, therefore, would provide no reduction in toxicity,
mobility, or volume. Alternative S-2 would reduce the
mobility of contaminants by removing the lead-
contaminated soils and the VOC-contaminated soils (from
0 to 4 ft. bgs) from the property and reduce the toxicity,
Under Alternative S-2, lead-contaminated soils and VOC-
contaminated soils (from 0 to 4 ft. bgs) would be disposed
14
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mobility, and volume through in-situ treatment of the
remaining source-area soils. Alternative S-3 would reduce
the mobility of the contaminants by excavating the lead-
contaminated soils and the VOC-contaminated soils (from
0-4 ft. bgs) and removing the lead-contaminated soil from
the property. The toxicity and volume of the contaminants
would be reduced through ex-situ treatment of the
excavated VOC-contaminated soils. The toxicity, mobility,
and volume of the source-area soils would be addressed
through in-situ treatment.
Alternative SED-1 would involve no active remedial
measures and, therefore, would provide no reduction in
toxicity, mobility, or volume. Both Alternatives SED-2 and
SED-3 would reduce the mobility of the contaminants by
removing the contaminated sediments posing a risk to
ecological receptors in the Stormwater Catchment Basin
and Clonmell Creek. However, Alternative SED-3 would
also provide a reduction in the toxicity and volume of the
contaminated sediments through on-Site treatment.
Alternative GW-1 would not effectively reduce the toxicity,
mobility or volume of contaminants in the groundwater,
because this alternative involves no active remedial
measures. Alternative GW-2, on the other hand, would
reduce the toxicity, mobility, and volume of contaminated
groundwater through extraction and treatment in the on-
Site treatment system, thereby satisfying CERCLA's
preference for treatment.
Short-Term Effectiveness
Because no actions would be performed under Alternative
S-1, there would be no implementation time. The
timeframes for the excavation of the unsaturated soils (12
months) and in-situ treatment of the source-area soils (10
years) would be the same for Alternatives S-2 and S-3. Ex-
situ treatment of the excavated VOC-contaminated soils
under Alternative S-3 would take approximately 18
months.
Alternative S-1 would not include any physical construction
measures in any areas of contamination and, therefore,
would not present any potential adverse impacts to
remediation workers or the community as a result of its
implementation. Alternatives S-2 and S-3 could present
some limited adverse impacts to remediation workers
through dermal contact and inhalation related to the
excavation of contaminated soils. The risks to remediation
workers under Alternatives S-2 and S-3 could be mitigated
by following appropriate health and safety protocols, by
exercising sound engineering practices, and by utilizing
proper protective equipment.
Both Alternatives S-2 and S-3 would require the off-Site
transport of contaminated soils, which could potentially
adversely affect local traffic and may pose the potential for
traffic accidents, which in turn could result in releases of
hazardous substances. However, the volume transported
under Alternative S-2 (approximately 830 truckloads)
would be significantly greater than for Alternative S-3
(approximately 63 truckloads).
For Alternatives S-2 and S-3, there is a potential for
increased stormwater runoff and erosion during
construction and excavation activities that would have to
be properly managed to prevent or minimize any adverse
impacts. For these alternatives, appropriate measures
would have to be taken during excavation activities to
prevent transport of fugitive dust and exposure of workers
and downwind receptors to the VOCs in the Site soils.
The installation of infiltration galleries and interim- and
post-remediation soil sampling activities, associated with
the in-situ treatment of source-area soils under
Alternatives S-2 and S-3, would pose an additional risk to
on-Site workers, because these activities would be
conducted within areas of potential soil and groundwater
contamination.
Because no actions would be performed under Alternative
SED-1, there would be no implementation time. Both
Alternatives SED-2 and SED-3 would require some
infrastructure construction, however, the infrastructure
required to implement Alternative SED-3 would be more
extensive and, therefore, would require more time to
complete. It is estimated that it would take 12 months to
implement Alternative SED-2 and 18 months to implement
Alternative SED-3.
Alternative SED-2 would require the off-Site transport of
contaminated sediments (approximately 550 truckloads),
which has the potential to adversely affect local traffic and
may pose the potential for traffic accidents, which in turn
could result in releases of hazardous substances. Both
Alternatives SED-2 and SED-3 would present some limited
risk to remediation workers through dermal contact and
inhalation related to the handling of the dredged
sediments, however, this risk would be increased under
Alternative SED-3 due to the longer potential exposure
time associated with on-Site treatment. The risks to
remediation workers under Alternatives SED-2 and SED-3
could be mitigated by following appropriate health and
safety protocols, by exercising sound engineering
practices, and by utilizing proper protective equipment.
Because no actions would be performed under Alternative
GW-1, there would be no implementation time. It is
estimated that, under Alternative GW-2, it would take 12
months to complete the modifications to the existing
underground piping, build the structure to house the new
treatment system and install the new treatment system.
The overall time to meet the PRGs throughout the entire
groundwater plume under Alternative GW-2 (in
combination with one of the action soil alternatives) is
estimated to be 10 years.
Alternative GW-1 would have no short-term impact to
remediation workers or the community and would have no
15
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adverse environmental impacts from implementation,
because no actions would be taken under this alternative.
Alternative GW-2 could present some limited risk to
remediation workers through dermal contact and
inhalation related to construction activities associated
with the underground piping modifications, building
construction and periodic groundwater sampling
activities. The risks to remediation workers could be
mitigated by following appropriate health and safety
protocols, exercising sound engineering practices and
utilizing proper personal protective equipment.
Implementability
Alternative S-1 would be the easiest soil alternative to
implement because there are no activities to undertake.
Both Alternatives S-2 and S-3 would employ technologies
known to be reliable and that are readily implementable.
The equipment, services and materials needed to
implement Alternatives S-2 and S-3 are readily available
and the actions under these alternatives would be
administratively feasible.
Under Alternatives S-2 and S-3, real-time air quality
monitoring for VOCs and dust during excavation activities
would need to be conducted to protect remediation
workers and downwind residents. Sufficient facilities are
available for the treatment and disposal of the excavated
materials and determining the achievement of the soil
PRGs could be easily accomplished through post-
excavation soil sampling and analysis, under Alternatives
S-2 and S-3.
Alternative SED-1 would be the easiest sediment
alternative to implement because it would not involve
undertaking any actions. Alternatives SED-2 and SED-3
would employ hydraulic dredging, which is a commonly-
used technology proven to be effective in the removal of
contaminated sediments. Alternative SED-3 would involve
on-Site treatment of contaminated sediments through
phytoremediation in geotextile tubes, which was
successfully demonstrated during the treatability study
conducted on the Clonmell Creek sediment during the Rl.
The equipment, services and materials needed to
implement Alternatives SED-2 and SED-3 are readily
available and the actions under these alternatives would
be administratively feasible.
Alternative GW-1 would be the easiest groundwater
alternative to implement, because it would not entail the
performance of any activities. The equipment, services
and materials needed to implement Alternative GW-2 are
readily available and the actions under this alternative
would be administratively feasible. The existing extraction
and treatment system has been successful at maintaining
hydraulic control and reducing COC concentrations in the
groundwater at the Site and the ICs under Alternative GW-
2 would be relatively easy to implement.
In accordance with CERCLA, no permits would be
required for on-site work (although such activities would
comply with substantive requirements of otherwise
required permits). Permits would be obtained as needed
for off-Site work.
Cost
The present-worth costs for the soil alternatives were
calculated using a discount rate of 7 percent and a 15-year
timeframe for soil cap maintenance. The present-worth
cost for Alternative GW-2 was calculated using a discount
rate of 7 percent and a 10-year time interval for operation
and maintenance of the treatment system (the estimated
time to meet the groundwater PRGs) and a discount rate
of 7 percent and a 15-year time interval for groundwater
monitoring.
The estimated capital, OM&M, and present-worth costs
are summarized below in Table 5.
Table 5: Summary of Alternative Costs
Alternative
Capital
Annual
OM&M
Total
Present
Worth
S-1
$0
$0
$0
S-2
$11,183,360
$248,181
$12,191,308
S-3
$5,198,118
$248,181
$6,206,066
SED-1
$0
$0
$0
SED-2
$4,086,780
$0
$4,086,780
SED-3
$1,860,320
$0
$1,860,320
GW-1
$0
$0
$0
GW-2
$409,826
$225,938
$3,181,534
State Acceptance
NJDEP concurs with the proposed remedy.
Community Acceptance
Community acceptance of the preferred alternative will be
addressed in the ROD following review of the public
comments received on this Proposed Plan.
PREFERRED REMEDY
Based upon an evaluation of the various alternatives, EPA,
in consultation with NJDEP, recommends Alternative S-3
(excavation of lead-contaminated soil with off-Site
disposal, excavation of VOC-contaminated soil located 0-
4 ft. bgs and treatment with ex-situ bioremediation,
followed by on-Site reuse, and enhanced in-situ
biodegradation of VOC-contaminated soil situated below 4
ft. bgs) as the preferred alternative to address the
contaminated soil at the Site; Alternative SED-3 (hydraulic
dredging of contaminated sediment with on-Site
phytoremediation and on-Site reuse) as the preferred
alternative to address the contaminated sediment at the
Site; and Alternative GW-2 (extraction of contaminated
16
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groundwater with on-Site treatment, long-term monitoring
and ICs) as the preferred alternative to address the
groundwater contamination at the Site. The proposed soil
and sediment remediation areas are shown in Figure 3.
The soils in the Active Process Area, Chemical
Landfill/Gravel Pit, Inactive Process Area, Northern
Chemical Landfill, Stormwater Catchment Basin and Tank
Farm/Train Loading Area exposure areas with COC
concentrations exceeding the PRGs would be excavated
to a depth of 4 ft. bgs11
The soil in the Township Refuse Area with lead
concentrations exceeding the PRGs would be excavated.
Additional delineation of the lead contamination in this
area would be performed during the remedial design.
A BMP plan would be developed and implemented to
manage lead and minimize contamination of the Shooting
Range exposure area while the shooting range remains
active. If the shooting range becomes inactive, delineation
of the lead contamination would be performed and the soils
the in the Shooting Range exposure area with lead
concentrations exceeding the PRGs would be excavated
and disposed of off-Site.
The excavation would be performed using standard
construction equipment, such as backhoes and track
excavators. An estimated 13,804 CY of contaminated soil
would be excavated, consisting of 1,052 CY of lead-
contaminated soil and 12,752 CY of soil contaminated with
benzene, cumene and collocated COCs would be
excavated.
The excavated lead-contaminated soil would be
transported to an off-Site treatment and/or disposal facility.
The excavated soil containing benzene, cumene and
collocated COC concentrations above the PRGs would be
treated on-Site using ex-situ bioremediation. Specifically,
these soils would be mixed with soil amendments, formed
into piles and aerated, either passively or actively (using
blowers or vacuum pumps). As part of the remedial
design, an analysis would be performed to confirm that the
average VOC concentrations that may be released from
ex-situ treatment of the soils would not exceed applicable
state and federal air emissions standards. If air emissions
controls are determined to be necessary based upon these
calculations, then those controls would be included in the
remedial design. In addition, vapors from the VOCs in the
biopiles that volatilize into the air would be monitored to
protect Site workers and ensure that state and federal air
emission standards are not exceeded and post-remedial
sampling would be conducted to ensure that the PRGs are
met.
11 Approximately 500 CY of the soils in the Active Process Area
and Inactive Process Area exceeding the PRGs would be
Post-excavation sampling would be conducted to
identify/confirm the areas where the PRGs are exceeded
in the soils situated below 4 ft. bgs. These soils (saturated
and unsaturated) would be treated using enhanced in-situ
biodegradation. Enhanced in-situ biodegradation would
involve injecting a magnesium sulfate solution into the
contaminated soils to stimulate activity and reproduction of
naturally-occurring anaerobic microorganisms. The
microorganisms would then destroy or transform COCs
into less toxic compounds by using them as a food and
energy source. Application of the anaerobic treatment
solution would be achieved using lateral infiltration
galleries consisting of perforated piping installed in a
series of shallow trenches. Performance and compliance
monitoring would be conducted to determine residual
contaminant concentrations and assess the need for
additional treatment.
The ex-situ-remediated soils would be reused on-Site,
along with imported, certified clean soil, meeting
applicable state regulations, to backfill excavated areas
and construct an engineered soil cover in the Active
Process Area, Inactive Process Area and the Tank
Farm/Train Loading Area to reduce infiltration of surface
water to the groundwater, and control surface water
runoff/drainage. Vegetation would be placed in areas
disturbed during excavation activities to stabilize the soil
and maintenance of the soil cover would be performed.
The remedy would also include hydraulic dredging to
remove a mixture of contaminated sediment and water
(referred to as slurry) from the bottom surfaces of the
Stormwater Catchment Basin and Clonmell Creek. It is
estimated that 8,500 CY of contaminated sediment would
be removed; 1,225 CY from the Stormwater Catchment
Basin and 7,275 CY from Clonmell Creek. These
volumes represent the removal of 100 percent of the
cumene mass in the Stormwater Catchment Basin and
approximately 99 percent of the cumene mass within the
Clonmell Creek sediment and include all the sediment
posing a risk to ecological receptors.
The work area would be enclosed with silt curtains to
prevent downstream migration of contaminated sediment
during dredging activities. Also, the surface water outside
the work area would be monitored to ensure that
contaminated sediments are not being resuspended in
the water column and transported downstream.
The slurry would be transferred via pipeline into geotextile
tubes (located in a treatment cell within the Stormwater
Catchment Basin exposure area) for dewatering. The
staging area would be designed with proper controls,
including but not limited to an impermeable liner, to prevent
any impacts to the surrounding soil and groundwater and
treated using enhanced in-situ biodegradation rather than
being excavated.
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maintain containment of the dredged sediments and
effluent water from the geotextile tubes. The effluent water
would be sampled and, if necessary, treated on-Site
before being discharged to the Stormwater Catchment
Basin in accordance with substantive NJPDES discharge
to groundwater permit requirements. The details of the
effluent treatment system would be finalized during the
remedial design. Monitoring of groundwater wells around
the Stormwater Catchment Basin would be conducted to
ensure compliance with permit requirements.
Plants would be planted in the cumene-contaminated
sediment within geotextile tubes for a pre-determined
growth period.12 The treated sediments would be reused
on-Site as part of an engineered soil cover to reduce
infiltration of surface water to the groundwater, and
control surface water runoff/drainage, and the plant
residuals would be harvested and composted on-Site.
Under the groundwater component of this remedy, a new
treatment unit would be built to replace/upgrade the
existing one and a small building would be constructed in
the Stormwater Catchment Basin exposure area to house
the new treatment unit. The existing extraction wells and
subsurface pipelines would to be used to capture and carry
contaminated groundwater to the new treatment unit.
The extracted groundwater would be pumped into an
equalization tank within the treatment building and then
treated with a polymer. The polymer would be combined
with pH adjustment, if necessary, to promote flocculation
of iron and other solids in the groundwater. The
groundwater would then be pumped through conventional
geotextile tubes followed by GAC-impregnated geotextile
tubes, if necessary, to remove iron, solids, and treat COCs.
The solids, flocculated iron and other metals, would be
captured in the geotextile tubes. The COCs would partition
to the solids in the geotextile tubes where they would
biodegrade. The spent tubes would be transported off-Site
to a permitted disposal facility.
The new system would have an approximate treatment
capacity of 125 gallons per minute. Treated water would
be discharged to the groundwater in compliance with
substantive NJPDES discharge to groundwater permit
requirements (using the Stormwater Catchment Basin as
an infiltration point). Long-term groundwater monitoring
would be continued until the PRGs are met.
ICs would be put in place at the Site, including the
establishment of a CEA to prevent groundwater use and
the placement of a deed notice on the property, restricting
the land use to commercial/industrial and requiring that
future buildings on the Site either be subject to a vapor
intrusion evaluation or be built with vapor intrusion
mitigation systems until the PRGs are met.
Because the proposed remedy would result in
contaminants remaining above levels that allow for
unrestricted use and unlimited exposure, CERCLA
requires that the site be reviewed at least once every five
years.
Basis for the Remedy Preference
Both Alternative S-2 and Alternative S-3 would address
principal threat wastes through excavation and treatment
and effectively achieve the soil the PRGs. Alternative S-
2 would meet the PRGs in the soils from 0-4 ft. bgs more
quickly by removing the excavated soils from the property.
However, Alternative S-3 would achieve the PRGs in
these soils through treatment within a reasonable
timeframe (12 months) and would provide a greater
environmental benefit than Alternative S-2 because it
would allow for on-Site reuse of the treated soils.
Alternative S-2 would be considerably more expensive to
implement than Alternative S-3 because of the
significantly larger volumes of contaminated soil that
would need to be transported off-Site for treatment and/or
disposal and clean fill that would need to be imported to
backfill the excavated areas and construct an engineered
soil cap under Alternative S-2. Therefore, EPA believes
that Alternative S-3 would effectively address the soil
contamination at the Site while providing the best balance
of tradeoffs with respect to the evaluating criteria.
Both Alternative SED-2 and Alternative SED-3 would
effectively and permanently eliminate the risk posed to
environmental receptors by removing the contaminated
sediments from the Stormwater Catchment Basin and
Clonmell Creek. Alternative SED-2 would require less
time and infrastructure construction to implement than
Alternative SED-3, however, Alternative SED-2 would be
considerably more expensive to implement than
Alternative SED-3 because it would involve transporting
the contaminated sediments off-Site for treatment and/or
disposal and would require a larger volume of clean fill to
be imported onto the Site. Alternative SED-3 would
provide a greater environmental benefit than Alternative
SED-2 because it would allow for on-Site treatment and
reuse of the treated sediments as part of an engineered
soil cover. EPA believes Alternative SED-3 would
effectively mitigate the threat to ecological receptors from
the Site while providing the best balance of tradeoffs with
respect to the evaluating criteria.
For more than 30 years, a groundwater extraction and
treatment system has been operated at the Site as an
interim action. This system has successfully reduced
contaminant concentrations in the groundwater and
12 Additional studies would be conducted during the remedial
design to refine plant species selection and determine the
optimal growth period.
18
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prevented contaminated groundwater from migrating off-
property. Because of the effectiveness of the existing
system and the anticipated removal of the contaminant
source under the preferred soil alternative, EPA has
identified Alternative GW-2 as its preferred groundwater
alternative.
The preferred remedy is believed to provide the greatest
protection of human health and the environment and long-
term effectiveness; will be able to achieve the ARARs
more quickly, or as quickly, as the other alternatives; upon
completion, will allow for commercial/industrial use of the
property; and, is cost effective. Therefore, the preferred
remedy will provide the best balance of tradeoffs among
alternatives with respect to the evaluating criteria. EPA
and NJDEP believe that the preferred remedy will address
principal threat wastes, be protective of human health and
the environment, comply with ARARs, be cost-effective,
and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable. The preferred remedy also
will meet the statutory preference for the use of treatment
as a principal element, as well as include consideration of
EPA Region 2's Clean and Green Energy Policy.13
13 See http://epa.qov/reqion2/superfund/qreen remediation and
http://vvww.dec.ny.gOv/docs/remediation_hudson_pdf/der31.p
df.
19
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Be I aware
River
Paulsboro
Solid Wastes
. DisposalArea
EtCjPont
Former
feJotiSffiiPlant
Athletic
Fields
Legend
Former Active Plant Area
Property Boundary
Solid Waste Disposal Area
Gibbstown
Elementary
<3V ' « £.'/
ifeSisholoJH
0 250 500 1,000 1,500 2,000
-------
Figure 2: Exposure Areas
002 Outfall
~ . a*.}] )¦
Drainageway
aKfSform water
El Catchment
jffim Basin^
002 Outfall
Clonmell
Creek
Exposure Area Key
Local Roads
1.
Active Process Area (APA)
mm 2.
Area A / Open Area
I I 3.
Area B
Chemical Landfill/Gravel Pit Area (CLF/GP)
V//Z\ 5.
Clonmell and Wetlands (CCW)
I 6.
Inactive Process Area (IPA)
I I 7-
Northern Chemical Landfill Area (NCL)
I I 8-
Nothern Warehouse Area (NW)
9
Solid Waste Disposal Area (SWDA)
10.
Shooting Range
I 11-
Stormwater Catchment Basin Area (SCB)
^12
Tank Farm/Train Loading Area (TF/TLA)
V///A is.
Township Refuse Area (TRA)
0 250 500
2,000
-------
Figure 3: Proposed Soil
& Sediment Remediation Areas
Legend
Pumping Well Location
Proposed Sediment Remediation Area
| Proposed Soil Remediation Area
0 125 250
-------
APPENDIX V-b
Public Notice Commencement of Public Comment Period
-------
SOUTH JERSEY TIMES, AFFILIATED WITH NJ.COM SUNDAY, JULY 29, 2018 B5
Health
STUDY
Does long life lead to a longer life?
New research: Mortality rates appear to accelerate to age 80 and then seem to plateau
QenGuarino Washington Post
Jeanne Louise Calment lived for 122 years
and 164 days, the oldest verified age of any
person, ever.
Her interviews revealed a portrait of the
centenarian in high spirits: "I've only ever
had one wrinkle, and I'm sitting on it," she
told reporters when she turned 110.
Calment died in 1997 in Aries, France,
where she spent much of her impressively
long life. No one else, according to accurate
records, has lived beyond 120 years.
Whether there's a limit to the human life
span is an age-old question. An actuary
named Benjamin Gompertz proposed in
1825 that mortality rates accelerate exponen-
tially as we grow older. Under what is known
as the Gompertz law, the odds of dying dou-
ble every eight years. That seems to be the
rule for people ages 30 to 80.
But researchers disagree about what hap-
pens to mortality rates very late in life. A
new study, published recently in the journal
Science, indicates that the Grim Reaper sud-
IN YOUR BASEMENT
TIMES n 1
T South
Jersey
denly eases off the accelerator.
"The aim was to settle a controversy about
whether human mortality has the same
shape as mortality in many other species,"
said study author Kenneth Wachter, profes-
sor emeritus of demography and statistics at
the University of California at Berkeley.
"We think we have settled it," he said.
Mortality rates accelerate to age 80, decel-
erate and then plateau between ages 105
to 110, the study authors concluded. The
Gompertz law, in this view, ends in a flat line.
To be very clear, we're talking about the
acceleration of mortality rates, not the odds
themselves. Those still aren't good.
> Only 2 in 100,000 women live to 110; for
men, the chances of becoming a super-
centenarian are 2 in 1,000,000.
> At age 105, according to the new study, the
odds of surviving to your 106th birthday
are in the ballpark of 50 percent.
> It's another 50-50 coin flip to 107, then
again to 108,109 and 110.
f 12 - t* all In the tsidit at a
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CALL OUR TOLL FREE NUMBER 1.800.360.3603
TO PLACE YOUR CLASSIFIED AD
EPA INVITES PUBLIC COMMENT ON THE PROPOSED
CLEANUP PLAN FORTHE HERCULES INC.
(GIBBSTOWN PLANT) SUPERFUND SITE
IN GLOUCESTER COUNTY, NEW JERSEY
The U.S. Environmental Protection Agency (EPA) announces
the opening of a 30-day comment period on the preferred
plan to address contaminated soil, sediment and
groundwater at the Hercules Inc. (Gibbstown Plant),
Gloucester County, NJ. The preferred remedy and other
alternatives are identified in the Proposed Plan.
The comment period begins on Monday, July 30, 2018 and
ends on Tuesday, August 28, 2018. As part of the public
comment period, EPA will hold a public meeting onThursday,
August 16, 2018 at 7 pm at the Municipal Court Meeting
Room, 2nd floor, 21 N. Walnut Street, Gibbstown, NJ.
The Proposed Plan is available electronically at the following
address: https://www.epa.gov/superfund/hercules-gibbstown
Written comments on the Proposed Plan, postmarked no later
than close of business August 28, 2018 may be emailed to
pierre.patricia@epa.gov or mailed to Patricia Simmons Pierre,
EPA, 290 Broadway, 20th Floor, New York, NY 10007-1866.
The Administrative Record files are available for public
review at the following information repositories:
Greenwich Public Library, 411 Swedesboro Road,
Gibbstown, NJ 08027 or at the EPA - Region 2 Superfund
Records Center, 290 Broadway, 19th Floor, New York, NY
10007-1866
For more information, please contact Pat Seppi, EPA's
Community Liaison, at 646.369.0068 or Seppi.pat@epa.gov
Led by Elisabetta Barbi of Sapienza Uni-
versity of Rome and experts at the Italian
National Institute of Statistics, the new
research tracked everyone in Italy born
between 1896 and 1910 who lived to age 105
or beyond. The data included 3,836 people,
of whom 3,373 were women and 463 were
men. Their registry requires yearly updates
from citizens and provides more informa-
tion than U.S. Social Security data.
Holger Rootzen at the Chalmers Univer-
sity of Technology called it a "very careful
and good analysis" that reveals a mortality
plateau between ages 105 and 110.
2 in 100,000
the chances, if you are female, that you will
I veto be 110
2 ill 1M
the chances that you will live until 110 if you
are male
Don't let a great
summer pass you by!
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ADOPT A ROAD SPOTLIGHT:
NJ-l HOGS AND HEROES FOUNDATION:
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The Hogs and Heroes Foundation is a community of motorcyclists who support
public safety, the U.S. Armed Forces, and Wounded Warriors. They perform
honor missions for fallen police officers, firefighters. EMTs. and members
of the armed forces. They plan and participate in fun rides and events and
participate in the fundraisers of other charitable organizations. In addition, they
strive to reflect good citizenship as an example to the youth of our nation.
In keeping with the mission of the Hogs and Heroes Foundation, when tragedy
struck the local chapter on June 24, 2017, they decided to give something
back. On the way home from an event, members Bradley Loveland and Tammy
Bailey were involved in an accident that took both of their lives. To honor their
memory and to try to make something good out of something bad. NJ-1 Hogs
and Heroes adopted a portion of Welchville Road in Mannington Township.
The Adopt-a-Road Program is a project funded by the Clean Communities
Grant, and it supports the ongoing efforts to beautify Salem County while
controlling litter on its 354 miles of roadways. Groups adopt a 1-mile stretch
of road and complete a litter pickup at least four times a year. All equipment
is provided free of charge to the group or family that adopts the road, as are
signs advising that the road has been adopted.
The Salem County Improvement Authority welcomes NJ-1 Hogs and Heroes
Foundation to the Adopt-a-Road family and thanks them for their dedication to
the community and those who serve.
There are many other roads in Salem County awaiting adoption. It's easy: Pick
a road from the list and complete an application.
For more information and an application, please contact
Florence Beckett at 856-935-7900 x 16 or at fbeckett@scianj.org
-------
APPENDIX V-c
Public Meeting Transcript
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Page 1
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
Region II
HERCULES SUPERFUND SITE
SUPERFUND SITE PUBLIC MEETING
Township Municipal Court
21 North Walnut Street, 2nd Floor Meeting Room
Gibbstown, NJ
August 16, 2 018
7:00 p.m.
PRESENT
PAT SEPPI, EPA, Community Involvement Coordinator
PATRICIA PIERRE, EPA, Remedial Project Manger
JOEL SINGERMAN, Superfund
DR. LORA SMITH, Human Health Risk Assessor
GWEN ZERVAS, Section Chief of NJ Department of
Environmental Protection
CRAIG STEVENS, CSI
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PROCEEDINGS
MS. SEPPI: I have a couple more people
signing in, but I'd like to get started on
time.
I really appreciate you being here on
time. And it seems like we have a really nice
turnout.
I wanted to thank the Mayor and Jeff for
letting us use this meeting room tonight. It
really worked out fine. We kind of messed them
up and moved things around. But we'll put it
back when we leave.
What I'd like to do first is have the
people who are associated with the Hercules
site introduce themselves.
My name is Pat Seppi. I'm with the EPA.
We're out of Region II. Our main office is in
New York City. And we cover New York, New
Jersey, Puerto Rico, and the Virgin Islands.
And we also have a satellite office in Edison,
New Jersey. And that's where our laboratory
is .
And again, I'm Pat Seppi, community
involvement coordinator for this site. And I'd
like to go around and have the other people who
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were involved introduce themselves and let you
know their role.
MR. SINGERMAN: Joel Singerman from the
Superfund program.
MS. PIERRE: My name is Patricia Pierre.
I'm the EPA remedial project manager for the
site.
DR. SMITH: I'm Dr. Lora Smith. I'm the
human health risk assessor for the site.
MS. ZERVAS: I'm Gwen Zervas, The Section
Chief of the New Jersey Department of
Environmental Protection.
MS. SEPPI: We have a couple other people
who I would like to have introduce themselves.
Maybe you can just speak loudly, so people can
hear you. You don't have to come all way up.
MR. STEVENS: Craig Stevens. I'm with CSI
principal working with Ashland and with EPA.
MR. FERRIS: Dustin Ferris environmental
scientist, project manager for remedial
investigation of the site.
MS. SEPPI: Thank you. So thank you for
coming out, again, to the meeting. The reason
we're here tonight is to present EPA's
preferred alternative for the cleanup for the
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Hercules site.
So I guess everybody that I've spoken to
has lived here for a long time, so you're very
familiar with it, with the site and what's
going on. And we're happy to be able to come
here tonight to give some good news and talk
about the cleanup.
So there's a comment period that goes
along with this meeting. And it ends on
August 28th.
So tonight, you notice we have a
stenographer here. Her name is Kathryn.
She'll be taking down all your comments. And
then what we'll do is after all those comments,
what happens after the end of the comment
period, is -- the next thing that comes along
is a legally binding document. It's called the
Record of Decision. We call it the ROD. And
that will set down in black and white what the
remedy is. That's why it's important for us to
have your comments, because it may change
things. It may reinforce the fact so people
agree with what we're doing. We definitely
want to hear your comments.
And then, again, we'll put them all
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together in what is called a responsive
summary. And that will be an attachment to
this Record of Decision when that comes out.
Now, after tonight's meeting and before
the close of business on August 28th, you're
certainly still welcome -- you may think of
something when you go home tonight and have a
comment about it. You can certainly either
email that to Patricia or send it to her. If
you need that information, I'm happy to send it
to you or give it to you. But it's also in the
proposed plan that's online. So hopefully some
of you have read it. It's a long document.
It's a little technical. But if you're able to
read even sections of it, I would suggest that
you do that.
As I said, we do have a stenographer. I
would ask that when you come up at the question
and answer session, if you -- we'll have a
microphone up here. If you can just state your
name so we make sure that we have it for the
record so we can respond to your comments.
And I would ask one other favor -- and I
know sometimes it's difficult -- if you could
hold your comments or your questions until the
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end of our presentation -- it's not a real long
presentation. It's just sometimes if we get
off track and start answering questions and
maybe your questions will be answered during
the presentation. So if you could do that, we
would all appreciate that.
I think that that's the most important
things that I wanted to tell you. If you
haven't signed in, I would ask that you do
that.
I'm going to turn this over to Joel. And
he's going to talk a little bit about the
Superfund process.
MR. SINGERMAN: Several well-publicized
toxic waste disposal disasters in the late
1970's shocked the nation and highlighted the
fact that past waste disposal practices were
not safe.
In 1980, Congress responded with the
creation of the Comprehensive Environmental
Response, Compensation, and Liability Act, more
commonly known as Superfund.
Superfund law provided a federal fund to
be used in the cleanup for uncontrolled and
abandoned hazardous waste sites and for
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responding to emergencies involving hazardous
substances.
In addition, EPA was empowered to compel
those parties that are responsible for these
sites to pay for or to conduct the necessary
response actions.
The work to remediate a site is usually
very complex and takes place in a number of
stages. Once a site is discovered, an
inspection further identifies the hazards and
contaminants.
A determination is then made whether to
include the site on the Superfund National
Priorities List, a list of nation's worst
hazardous waste sites.
The sites are placed on the National
Priorities List, primarily on the basis of
their scores obtained from the hazard ranking
system, which evaluates the threat posed by a
site.
Only sites on the National Priorities List
are eligible for remedial work financed by the
Superfund.
The selection of a remedy for the
Superfund site is based on two studies, a
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remedial investigation and a feasibility study.
The purposes of the remedial investigation
is to determine the nature and extent of the
contamination at and emanating from the site,
and the associated threat to public health and
the environment.
The purpose of the feasibility study is to
identify and evaluate ways to cleanup the site.
Public participation is a key feature of
the Superfund process. The public is invited
to participate in the decisions that will be
made at the site through the community
relations program. Public meetings, such as
this one, are held as necessary to keep the
public informed about what has happened and
what is planned for a site. The public is also
given the opportunity to ask questions about
the results of the investigations and studies
conducted at the site and to comment on the
proposed remedy.
After considering public comments on the
proposed remedy, a Record of Decision is
signed. A Record of Decision documents why a
particular remedy was chosen. The site then
enters the design phase where the plans
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associated with the implementation of the
selected remedy are developed.
The remedial action is the actual hands-on
work associated with cleaning up the site.
Following the completion of remedial
action, the site is monitored, if necessary.
And once that site no longer poses a threat to
the public health or the environment, it can be
deleted from the Superfund National Priorities
List.
Now, Patricia will talk about the remedial
design.
MS. PIERRE: So the Hercules Site is
located on North Market Street, here in
Gibbstown.
It's a former chemical manufacturing
facility built in the 1950's that produced
phenol, acetophenone, and cumene and benzene
compounds associated with that process.
Operations at the plant ceased in 2009.
And most of the aboveground structure was
subsequently demolished in 2010.
Hercules LLC, which is a subsidiary of
Ashland, LLC, owns the property and is
responsible for the plant.
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The site sits on 350 acres of developed
and undeveloped land near the Delaware River.
It's bordered to the north by the River, to the
south by a residential area, which is served by
municipal water, and to the east and west by
other industrial properties.
Clonmell Creek flows northwest through the
property towards the Delaware. And there's a
storm water retention basin on the site,
referred to as the Storm Water Catchment Basin.
The site is divided into two primary
areas. The former plant area is in the
southwest corner of the property, highlighted
in yellow in the bottom left-hand corner, is
the former plant area, which covers
approximately 80 acres.
And then the solid waste disposal area,
which covers about 5 acres, is located in the
northernmost portion of the property.
Remediation activities at a site are
sometimes divided into two different phases
called operable units, or OUs. This site has
three operable units.
OU3, which has already been addressed, is
associated with the solid waste disposal area.
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This area sits about 2,000 feet north of the
plant and is surrounded by wetlands.
The contamination in the solid waste
disposal area consists primarily of tar waste
and some lead fragments and construction
debris.
Hercules conducted a Remedial
Investigation and Feasibility Study, or RI/FS,
under NJDEP oversight. From the result, it was
determined that the soil and groundwater
required remediation. NJDEP signed a
recommended decision selecting an OU3 in 1996.
The remedy called for consolidation of the
waste to hinder any permeable path to restrict
access and prohibit groundwater in the area,
and long-term groundwater monitoring.
The OU3 remedial action was completed in
2014. The ground water is sampled on a
quarterly basis. And EPA reviews the remedy
every five years to ensure everything is
protected.
Operable Units 1 and 2 are essentially the
former plant area, and are the subject of
tonight's meeting.
OUl addresses the groundwater and the
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process in disposal areas. In the mid 1980's a
groundwater pump and treating system was
installed to prevent off-site migration of
contaminated groundwater. The system was
subsequently upgraded in 2008, and is still
being operated. A final groundwater remedy
will be selected with this.
As part of the groundwater monitoring
program, both on and off site monitoring wells
as well as the municipal water supplies wells
will be sampled on a quarterly basis
OU2 addresses the soil and the main
process in disposal areas. And the surface
water sedative in the Clonmell Creek and the
Storm Water Catcher basin.
The OUl, OU2 RI and FS were conducted by
CSI Environmental on behalf of Hercules.
Soil, groundwater, surface water, and
sediment samples were collected. And human
health and ecological risk assessments were
performed as part of the RI and FS. And on
site treatability studies were also performed
as part of RI FS.
So at this point, I'm going to ask Craig
Stevens from CSI to come up and discuss the
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details of the RIFS and I'll be back to you to
present the remaining alternatives.
MR. STEVENS: Good evening, everyone. I'm
going to briefly summarize the remedial
investigation, what was done, what we found,
and the highlights.
This is a figure showing the property
lines. The area in the color represents the
property, itself -- which you can see extensive
investigations have been done during the
history of the remedial investigation. All the
data points that have been collected, not just
on the site but throughout the Township, are
represented here. And to date, the soil and
sediment was looked at over 8,000 locations and
generated more than 500,000 data points to
understand and characterize the site.
Here's a little closer view focusing on
the groundwater monitoring that works
throughout the area. And again, not just on
the site, but throughout the Township. We have
approximately 8 0 permanent groundwater
monitoring wells that we sample on a
combination of annually and quarterly. So we
can understand groundwater flow as well as
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quality, what's at the site, the chemicals,
what are they doing, and where do they go.
Another important purpose is so that we
can study groundwater conditions throughout the
Township, itself, to ensure public safety.
As part of that, there are samples of the
two township falls TW4 and TW5 quarterly.
Focusing on the groundwater pumping
treating system, it is a critical element that
ties in with the groundwater monitoring.
Regional flow is in this direction towards the
Township and the former plant site.
We have a series of shallow and deep
pumping wells that are continuously operated
that create, what we call, a groundwater
capture zone, shown here, acts almost like a
groundwater fence, if you will, to prevent any
chemicals that are present on the site's
groundwater from infiltrating beneath the
Township.
The groundwater from these wells are then
pumped to a treatment plant towards the rear of
the former manufacturing plant where the
treatment occurs and then it's ultimately
discharged to the Delaware River via a
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permanent outfall.
So what's the essence of what we found on
this remedial investigation. The process,
itself, entails that we want to identify site
specific chemicals. We're looking at the right
place, the right speed of compounds. And then
we go through a process where we look at the
human health risk considerations, what's the
ecological considerations. And then all that
is compiled into a final study. We look at
applicable state and federal standards to come
up with remediation criteria.
At the end of the day here, we're then
able to plot that and look at areas that exceed
criteria or require further remediation.
And for soil, it's highlighted in this
darker color, reddish brown. Those two areas
we've identified where sediment remediation
will be required. One is a surface water body
and the other is a creek, Clonmell Creek, which
transects the back of the property, itself.
In addition, we still have the pumping
wells, which maintain the groundwater cap,
itself, to be protective of groundwater.
I mentioned the chemicals of concern for
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the site. Here's the list that's carried
forward into this process. It lists the
chemicals as well as each media or need further
effort.
The two that are highlighted are the two
compounds that are really driving a risk at
this site, warranting the remediation. And I
can say from all the work that we've done that
cumene is present most abundantly and has the
highest concentration.
So while we've been doing all these
studies and evaluating the site, we've also
gotten a head start at looking at what remedial
technologies are most favorable moving forward,
so we can keep the process moving efficiently.
This is under the former plan area, itself.
This is one of the areas that is requiring
shallow, storm, and groundwater remediation.
So we've done a series of tests starting
in 2010, where we injected chemicals to oxidize
the chemicals that are present in the saturated
faulty groundwater to restore them and remove
them from the subsurface.
In 2011, we did what is called air
sparging and soil vapor extraction test, where
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you inject air into the surface to try to strip
out the chemicals and then capture them in a
system.
Same here we also did some oxygen
injections called ISOC, where you try to
saturate it with oxygen to degrade what's
present.
For those first three we saw limited
success initially, but we were really hindered
by the complex site. So as a result in 2016,
2017, we moved forward with a different type of
microbial degradation testing to evaluate and
we can put nutrients in to stimulate what's
already there to break it down.
The results from that microbial study were
very favorable. This is approximately a one
year study. We saw really good decline over
that one year study.
I mentioned sediment -- areas where we had
to do sediment remediation. This is more of a
close up of Clonmell Creek to the back behind
the plant, it's the old waste water treatment
system. And what we did was we tested out
using a hydraulic dredge to pump the sediment
in this area which flows from through the
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system into specialty designed textile tubes to
restore and resurface for safety and
evaluation.
And these are just photos of the study
that was done showing different highlights
throughout the phase. Initially, when they're
pumped into these tubes that contain the
sediment and the chemicals that are within
them. And we measured all the media, not just
the sediment, the water, and the air to verify
what was going where.
In the second step, after we reviewed
water, we wanted to look at some natural
remediation. So we planted specific species of
vegetation, all part of remediation, which is a
fancy word for plants, in the soil to see what
that would do to help further treat the
sediments.
And you can see within six months how
successful that was and the type of growth that
we experienced.
Better yet, we saw excellent results with
the chemical data and the sampling from the GO
tubes, these are the initial concentrations.
And in less than six months, it went down to
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zero or close to zero. That's a very favorable
approach that we're look at that moving
forward.
Patricia?
MS. PIERRE: Okay. So based upon the
results of the RI and the risk assessments, EPA
has developed specific goals for the
remediation of the site designed to protect
human health, and the environment. These goals
are called Remedial Action.
And with these objectives in mind, the
remedial alternatives were developed to address
contaminated soil sediments and groundwater at
the site.
So the first soil alternative, which would
be alternative SI, would involve no action
being taken.
Soil alternative two would involve
excavation with off site disposal of the
contaminated soil from 0 to 4 feet deep, and
then treatment in place for the contaminated
soil that's deeper than 4 feet, using the
biodegradation that Craig just discussed.
Soil alternative three would also involve
the excavation of contaminated soil from 0 to 4
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feet, but only the lead contaminated soil would
be sent off site for disposal.
The excavated soil containing benzene and
cumene and other COCs found at the site would
be treated using bioremediation and then will
be used on site. And the soil deeper than 4
feet will still be treated in place using
biodegradation.
So for the sediment alternatives -- I
won't go over no action need. Alternative SED
2, which consists of removing the contaminated
sediments from Clonmell Creek and the storm
water catcher basin, and transporting them off
site for disposal.
And Alternative SED 3 would involve,
again, the removal of the contaminated
sediments in the creek and the storm water
catcher basin. But instead of being
transported off site for disposals, the
sediments will be treated on site using
bioremediation process that Craig just
discussed.
So as we stated earlier in our
presentation, many years of monitoring data
shows that the existing groundwater treatment
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system has been effective at preventing
contaminated groundwater from migrating off
site.
Because of the effectiveness of the system
or the existing system and the anticipated
removal of the source of the groundwater
contamination, either soil alternative S2 or S3
additional groundwater alternatives will not be
taken.
So what we have under alternative
alternative G2 is a new treatment unit that
will be able to replace the existing one. And
a small building to hold them.
The existing pipelines and pumping well
will continue to be used to extract the
contaminated groundwater and carry it to the
new treatment.
The preferred remedy for the site consists
of soil alternative S3, sediment alternative
SED 3, and groundwater alternative G2.
Just to recap, the soil remedy would
involve excavation, off site disposal of the
lead contaminated soil, excavation on site
treatment of the COC contaminated soils from 0
to 4 feet, and then enhanced biodegradation of
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the COC contaminated soils below 4 feet,
followed by on site reuse of the treated soils
and institutional controls, which would prevent
soil disturbance in the treatment areas until
the cleanup levels were met.
The sediment remedy would involve removing
of contaminated sediments and placing them into
GO textile treatments, dewatering the sediment,
and treating the extracted water on site, if
necessary. Final remediation of the soil on
site will be treated.
And again, the groundwater remedy will
involve constructing a new treatment in order
to replace the existing one and using the
existing wells and pipelines to carry the
contaminated ground water to the new treatment.
And this alternative will also involve
institutional control to prevent the use of the
groundwater until the cleanup is met.
So the construction time is estimated to
be two years time to meet cleanup levels. The
excavated soil that will be treated on site is
one year.
Time to meet the cleanup levels in the
soil that will be treated in place is 10 years.
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And the time to meet the cleanup levels in the
groundwater is 10 years, as well. The cost is
$11.3 million.
These are just some of the factors that
went in to selecting this particular remedy.
We believe that it will be moderately easy to
implement. And as Greg discussed, there was
positive soil and sediments treated during
studies.
It will remove the soil that is acting as
a source of contamination to the groundwater,
as well as permanently remove the sediment
poising as an ecological risk.
It will also allow for on-site treatment
and beneficial reuse of the soils and
sediments.
That's it.
MR. SINGERMAN: The final decision will
not be made until we consider all public
comments, questions, and concerns.
MS. SEPPI: We'll start some questions.
I just wanted to also let you know that if
you will take a look at the proposed plan, all
this information is in there, even in a lot
more detail. So it will certainly get into
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more -- if read more of the details. But we
would have you here for seven hours if we tried
to go through that whole plan.
So please, go ahead, it's on our web page.
And also, what we'll do is when I get this from
Patricia, this presentation, I'll make sure
that we post that on her web page, also. That
way, if you want to go back and take a look at
it and take some time, that will be available,
also. So just give me, probably -- I'd say you
can send it to me maybe tomorrow or Monday,
early next week it should be posted on our
page.
So now it's your to turn to come up and
ask questions or give comments. And I'm going
to put the mike up here. And Kathryn, our
stenographer, if we could just ask that when
you come up to give your comment or your
question, that you please state your name first
so she'll have it for the record. So let me
put this out here. And anybody with a question
or a comment, please come up.
PUBLIC COMMENT
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MR. MORLACHETTA: Good evening. My name
is Paul Morlachetta. And I reside at Holly
Place, here, in Gibbstown. I want to thank EPA
for their concise report.
What I have to report is some of the
things that have already been discussed. And I
don't see any harm in repeating some of those.
Some are questions, some are answers, some
are just statements. I'll start off -- why is
this proposed cleanup for the Hercules site
being proposed again, since it was done and
settled before? At that time, there were
several cleanup options considered, some
costing several million dollars. A greatly
reduced option with a considerably less cost
was selected. Is there something wrong with
the settlement?
Several test wells were installed on Holly
Place, where I live. And other members are
here from Holly Place and the area around.
We're right across Railroad Avenue, just across
the street from the site.
These water wells are sampled regularly.
Will these wells suffice? Or will more be
needed to monitor the groundwater?
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I think that a portion of DuPont property
was deeded over to Hercules. That area
contains several feet of sludge and tar-type
materials.
It also was covered with clean fill and a
non-porous material. That was an easy out at
that time.
While Hercules was operating, there was
always a very noticeable odor of cumene. Is
there any evidence remaining of cumene on or
under the surface? And you already took care
of that.
Asbestos-like material was located on a
pipe in the northwest area and was not sampled,
because the pipe could not be located. That I
received from a disk at the library.
Is asbestos an item of concern on the
current proposal? And that didn't seem to be
addressed.
And the disk I renewed at the library,
there was several mentions of red material
basin. What is a red material basin? Does
anybody have any information on that? It
showed up on the disk several times.
Apparently, at the time, it was an area of
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concern. And that's all the information I
could get at that time.
Again, in summation, what has happened to
reinstitute another proposed cleanup of the
Hercules site? Have there been different
things uncovered that should have been cared
for the first time? And has the time
predicated that another plan should be made?
That's all I have to say. But it's very
heartening to see so many people out here
tonight. The last public hearing that was held
for this site, there were two people here, me
and a representative from Hercules.
So again, thank you for your input and
thank you for everybody being here.
MS. SEPPI: Thank you. Those are
comments, and, of course, that will all be into
the record. Anything in particular you wanted
to respond to now?
MS. PIERRE: Yeah. There's one question
that I would like to address. And that is why
we're here tonight presenting another remedy
for the Hercules site.
And the answer to that is that a Record of
Decision was signed for the solid waste
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disposal area for OU3 in this portion of the
site. The subject of tonight's meeting, and
the remedy that's being proposed, is the former
plant area. So it's not a reopen, per se, of
the remedy that was selected. It's a remedy
being selected for a different portion of the
site.
MS. SEPPI: We appreciate that. That was
a lot of good comments. And we will make sure
they are addressed in the Response of Summary
that will come out with the Record of Decision.
So thank you for that.
Anybody else have any -- yes, sir.
MR. GENTILE: My name is Anthony Gentile,
56 South Orchard Street.
Back in 2014, we were having a house
built. The contractor built the house into the
water table. And we were dumping water
constantly, about 300 gallons an hour out of
the house. And it had a bad odor.
So during that process, I happened to see
a truck across the street from us with all
these hoses out of them and they were going to
test, which I found out. So I questioned that.
I called my lawyer and wanted to know what it
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was about.
I questioned the operator. He told me he
was working for Hercules and CSI. And I got
information. I got ahold of my lawyer and my
engineer. And I talked to a gentleman from
CSI. He, as a matter of fact, came to my house
and observed and did notice that there was a
smell.
To make a long story short, I had two
environmental people come in and did water
testing. And the test came out levels above
state levels of benzene in my house. Two
qualified people, one of them was off the state
contractors list, which I got from the State.
And we've been living in that fear, living in
benzene.
Mrs. Pierre came down. The County came
down. And all I asked them to do was Look, if
you don't think it's here, because that's what
I was getting, the song and the dance -- it's
not here. Our tests show it's not here. They
are below level. Well, I got two qualified
people saying it's above level.
I asked -- simply said, Well you do a test
then. They wouldn't do the test. I asked the
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County to do a test. They came down, too. A
lady came in with a clip board. She goes, I
don't see nothing here. Well, do a test. No,
we won't do a test. So they avoided the fact
that I spent probably 6, $7,000 getting these
tests done. And nobody wanted to acknowledge
it. Nobody wanted to come in and verify.
The contractor that did the test, he was
an environmental hygienist with a scientist's
degree. He wasn't a nobody that I got out of
the woods somewhere.
But he got his hands smacked and wouldn't
come to court and testify for me, because he
worked for the State.
So as it turns out, we're living in what
they were referring to as a house that is -- a
sick house. And we've both been sick from it.
And we got pushed into that house with 300
gallons of water coming out of it by the
township engineers and officials. Instead of
correcting the problem, they covered it up.
So I got reports here, many phone calls to
CSI, many phone calls with me and Mrs. Pierre,
many phone calls from the County, and we're
still living with that.
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And I see, they are still working on the
groundwater contamination. So there must be
some kind of problem going on in this town.
There's got to be.
So you're all going to be dying like some
of the other people that have been dying from
chemicals in this town. That's all I have to
say. And don't grin at me because it ain't
funny.
MS. SEPPI: Nobody would think it is
funny, believe me.
MR. GENTILE: He's laughing up there.
MS. SEPPI: We appreciate that. And it's
good to get that story out about what you've
been going through, but I don't want to take a
whole lot of time now for people to answer to
see if anything's changed. If you could stay a
little bit afterwards, maybe we could talk a
little bit more about your situation there.
MR. GENTILE: Sure.
MS. SEPPI: Thank you.
MS. MEEHAN: Hi Jennifer Meehan. And the
question that I have it's -- I guess it's
relevant to what he was mentioning, but it's a
more broad general question.
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In terms of -- what's the ultimate goal in
terms of the threshold of cleanup for this? Is
it to make sure that there's a certain lack of
contaminants that are outside? Is it focused
on internally here? Is there ever any intent
for this to be cleaned up enough that it could
actually be something other than a superfund
site where people could actually live or people
could spend time? What's the ultimate
threshold for this site and the surrounding
area?
I understand the little components to a
degree of what you're mentioning, but I don't
understand where that means ultimately in terms
of actually, really, a safe clean site and
surrounding it.
MS. SEPPI: Patricia, is that something
you can respond to?
MS. PIERRE: Yes. So as part of the RI
Process, we have developed preliminary
remediation goals. We call them PRGs. These
are cleanup numbers based on standards, state
and federal.
So this site will be cleaned up to
commercial, industrial levels, which will allow
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the site, ultimately, to be reviewed for that
purpose, commercial, industrial.
MS. MEEHAN: Is that a lower threshold? I
mean, I assume that it is then -- something
that could be housing or farmland, that's
impossible, that's never going to happen, given
the plans that are in place right now?
MS. PIERRE: Well, that's the current
zoning for the property. And our understanding
from the town is that it's not anticipated to
change. So that's how we selected the
remediation goals, based on the zoning.
MS. SEPPI: Cleaning up the residential,
that's not the way it's at right now. It would
have to be much lower in order to build houses.
But that's not our goal. It's to cleanup
commercial and not residential.
EPA is involved, too, and interested in
reuse and redevelopment. So we'll be here as
that work goes on, and work with the town to
help them develop what they want to see with
this site in the future.
MS. PIERRE: Also, I would like to
reiterate that we do have a groundwater
attraction and treatment system that is being
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operated at the site and has been operated for
many years. And the data has shown that it's
been effective at keeping the contamination in
the groundwater contained to the site.
And we also monitor groundwater wells off
property. And we are not seeing these site
contaminations outside of the property
boundary.
MS. SEPPI: I think that's a really good
point to make, too. I think, Craig, you said
that with all those wells -- some are tested
quarterly, some are tested annually. It sounds
like there's always testing going on out
there --
MR. STEVENS: Correct.
MS. SEPPI: -- and those results, I'm
sure, would be available. They must be public
if people wanted to see them.
MR. STEVENS: Yes.
MS. MEEHAN: Is all testing done through
EPA and the State? Is there any third party
that's not affiliated with EPA or with
Hercules ?
MS. SEPPI: Well, it's our contractors who
do the testing, so they are affiliated with
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EPA. I'm not aware of any third-party
contract.
MS. PIERRE: It's actually Hercules.
MS. SEPPI: Hercules. I'm sorry.
MS. PIERRE: CSI performs the testing at
the site, but there are no other parties at the
groundwater site.
MS. SEPPI: That's how it is with all the
sites. A superfund site that has a responsible
party, it's their contractor who does the
sampling and writes the report. But, of
course, it's an OPA oversight. So we look at
all those reports. And the State does, too.
Right, Gwen?
MS. ZERVAS: Yes.
MR. SINGERMAN: In addition, all the
laboratories they use are all approved
laboratories. They have to get the EPA's
approval before using those laboratories.
So again, all of this work is being done
by the responsible party's contractor under
EPA's oversight.
MR. STEVENS: And there's also independent
third party validation that goes on outside of
CSI that reviews all the lab data so that it's
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ready for distribution and use.
MS. SEPPI: So there is kind of indirectly
a third party out there --
MR. STEVENS: It's quality assurance.
MS. SEPPI: Right. And that's good to
know.
MS. GENTILE: Donna Gentile. I just
wanted to ask a question to the people from
EPA.
When you plan to take all this
contaminated soil out of the town, it's going
to disrupt things for the citizens here.
Did you plan on letting them know what
it's going to be like having trucks with all
these contaminants being taken out of the town,
probably right down Broad Street? I mean, it's
going to take, what, two years for all this?
Did you plan or did you let these people know
what's going to happen? That's my question.
MS. PIERRE: So we did look at that. And
that information, that evaluation, in
comparison, is in the proposed plan. But only
the lead contaminated soil, which is a very
limited amount, will be taken off site for
disposal. Because the preferred way would
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involve heating the excavated soil, benzene and
cumene and other COCs on site. We'll be using
that treated soil on the site.
MS. GENTILE: When you bring it out of the
town, will it be covered? How will it be
transported out?
MS. PIERRE: There will be safety measures
in place to ensure the protection of the
community while this work is being done. And
that will be part of a design plan that will
ultimately be developed.
MS. SEPPI: After the Record of Decision
is final, the next step, as Patricia mentioned,
is the remedial design. That's when you get
into kind of all the nuts and bolts of what's
going on. The transportation, dust control,
that kind of information. What kind of air
monitoring will be done. They are all separate
documents that have to be put into this design.
So sometimes these questions are a little
bit premature. But they will definitely all be
looked at during the design phase.
MR. SINGERMAN: One of the documents that
is prepared is called Health and Safety Plan.
That not only protects the workers who work on
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the site, but it also protects the people who
live around it.
So again, our objective is to clean up the
site, not to spread contamination around. So
it keeps contamination where it's supposed to
be. Whatever is excavated, we put in the
trucks to be transported so it's not spread
outside the boundary of the property.
And again, the air monitoring will be
performed during the excavation to make sure
there are no releases that are unacceptable.
And sometimes these things happen, sometimes
they have to measure -- for example, in case we
have a release on this property. They would
have to stop working and have to pause it. And
sometimes just spraying water on an excavation
can cause a problem.
Again, all of this will be part of the
Health and Safety Plan as part of our design to
make sure the workers and the community are
saf e.
MS. SEPPI: And releases don't happen very
often. They really don't. And the trucks that
usually go off site, I don't know if you've
seen them, we call them burrito trucks, because
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they actually fold over. So none of the
material that's inside the truck can be dumped
on the ground.
And usually when trucks are leaving the
site, they are decontaminated before they leave
the site, too, to make sure they are not
tracking any contaminated material out into the
streets. Those are all the types of things
that we look at in this design.
MR. SINGLETON: Eric Singleton. Just to
follow up on Donna's question, can you just
give us an idea of what sort of volume of
contaminated soil are we looking at excavating
and removing in terms of like dump truck fulls,
or train cars full? And where is that stuff
going to go? Like who are we dumping our
problem on?
MR. STEVENS: Most of it is treated on
site.
MS. SEPPI: Right.
MS. PIERRE: Again, it will only be the
lead contaminated soil that would be
transported off site. The volume is roughly
1,200 cubic yards. I don't know off hand what
that translates into, as far as truckloads are
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concerned. The information is in the proposed
plan, I just don't remember that figure off the
top of my head.
But again, the volume to be transported
offsite is very limited.
MS. SEPPI: Is it usually 20 cubic yard
trucks ?
MR. STEVENS: It depends. The 1,200 yards
could be 15, 16, 1,800 tons, and about 20, 25
tons per truck.
But as Patricia said, the rest of the soil
is going to remain on site and is going to be
treated on site.
MS. SEPPI: Right. Just the lead
contaminated is going off.
MR. STEVENS: And we looked at the
feasibility study that's transported through
town. We wanted to minimize that. That's one
of the considerations with treating it on site.
MR. SINGLETON: Where is that going to end
up?
MR. STEVENS: After all the treatment is
finished, it's going to be used in a clean soil
cover to lower the groundwater infiltration
rates driving the public treatment system.
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So it's, again, part of a holistic remedy
to be protective of human health and the
environment.
MS. SEPPI: I think he meant off site.
MR. STEVENS: Oh. You mean the lead?
That's going to be going to a certified
disposal plant. That hasn't been determined
yet. It will be a certified facility that's
permitted to accept that type of material.
MS. SEPPI: That's part of the design,
too. What type of landfill it would go to? We
don't know that yet. We won't know that until
later on.
MS. MCFARLAND: Hi. Taylor McFarland for
the New Jersey Sierra Club.
I do have a question. I don't know if
it's in the OU3 area, but if you're taking out
the tar pits, the contaminated tar pits, I'm
not sure that's specific to the Hercules site.
But we do want to know if the tar pits are
going to be removed.
And also, if there's any capping going on.
We're concerned -- especially, because it's in
a flood prone area -- that capping won't work.
The breakdown from storm sewers and flooding.
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We're specifically concerned, especially with
the weather that we've experienced this past
week where five counties were in a state of
emergency because of extremely high rainfall
and flooding.
So we were wondering if capping is
included in the proposal, and -- yeah. That's
it.
MS. PIERRE: Thank you for your question.
So the tar pits are part of OU3, the solid
waste disposal area. And a Record of Decision
was already signed for that portion of the
site. The remedy was conducted. And now that
site is in operation.
So to answer your question, those tar pits
won't be removed. The remedy was to cap them
into place.
The groundwater is monitored on a
quarterly basis. To show that, these orange
dots show the coverage that we have of the
capped area. And these groundwater wells are
monitored on a quarterly basis. We review the
data to ensure that the remedy remains
protected in those areas. And the levels are
continuing to decline.
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And we also looked at the remedy every
five years to ensure that it's protective of
human health and the environment. So that's
that part of the site.
The second part of your question is
capping being proposed for the OUl, OU2 area.
And the answer is no.
We would reuse the treated soil and
sediment on site in the OUl, OU2 area as a soil
cover, just for grading purposes -- right? For
grading purposes.
MR. STEVENS: Yes. That's right.
MS. PIERRE: But not as a cap.
MS. MEEHAN: Jennifer Meehan, again. I
actually wanted to ask the doctor that's here
representing human health concerns for the
contaminants that are highest here of biggest
concern, can you tell us a little bit more
about the health risk? I automatically think
about things like cancer. I feel like that's
an obvious one that everyone is always
concerned about.
What should we actually be aware of and
mindful of when we're thinking about the
contaminants that are here, and what they can
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do to us as people?
DR. SMITH: So there are various health
pinpoints that we look at for the different
contaminants at the site.
Benzene is a known human carcinogen.
Cumene, not so much. There are like kidney and
liver effects, things like that.
But, you know, based on the data that
we've seen, the contamination is pretty much --
it's contained on the property, itself. So we
have not seen the contamination in the
groundwater moving off property. And stuff
that's in the soil is not migrating.
So I don't think that anyone who's off
property -- we even looked -- we did in 2011,
along Railroad Avenue, the homes that are
closest down gradiant on the southern end of
the site, we did a vapor intrusion
investigation. We looked to see if the
contaminants in the groundwater could be
migrating up through the soil, collecting under
the homes, and then making their way inside the
homes.
And in that investigation, we did not find
that was a complete exposure pathway. We were
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not seeing anything in the groundwater. And we
weren't seeing anything getting from the
groundwater into the homes. So we continued
our investigation.
So I don't believe that there are any
impacts to the community, based on the data
that we have seen. And then this remedy will
make sure we don't see any impacts going
forward.
MS. MEEHAN: Just to recap, so benzene is
a carcinogen. And cumene is kidney and liver.
DR. SMITH: I believe so, yeah. I have
some sheets on the Agency for Toxic Substances
and Disease Registry, the CDC, they put up
these tox facts sheets, which are pretty easy
to understand. They are one or two pages. And
it goes over how you can be exposed and
different health effects to be aware of. I
have copies of some of those I can share with
you after the meeting.
MS. MEEHAN: And for people that live here
in Gibbstown that do have concerns, are there
recommendations that you have? Is it drink
bottled water and...
DR. SMITH: So your groundwater is the
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municipal supply water. So it actually comes
from a much deeper aquifer than where we see
contaminations on the site. So that goes to
municipal wells where it's treated. They test
it. You can get reports, annual reports, they
put out. They look for COC, which is
contaminants that we are mostly concerned with
here.
And so that information is available to
you. And they've been meeting all of the goals
the last time I checked. So groundwater should
not be an issue. These contaminants are in the
ground. I don't see them becoming volatile.
So I don't think there should be an issue --
MS. MEEHAN: What about home gardeners?
DR. SMITH: Well, the only contaminated
soil was found on the property. So there are
no residents on the property.
So that's why the site is zoned for
commercial, industrial. We'll make sure it
isn't used for residential purposes in the
future.
I mean, I always recommend that you have
your soil tested. And there are -- like
Rutgers has a center who will test your soil.
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And I'm sure there are other local places. But
you should always test your soil before you
grow a garden, I would say, especially in New
Jersey.
MS. SEPPI: And also, it's a good idea to
find out more about your water company. Do you
know which water company you have here? You
can go online. I'm sure they have a website.
They also have to send out a yearly report,
which I'm sure everybody gets. And they go
into a lot of detail. There's a lot of good
information. There are contact names and
numbers to call if you have any questions.
They have to report out if there are any
problems. So all that information is there.
So if you get it and you don't have a
chance to read it, just go online. And the
water company will go town by town where it
will have all your information. Is that
correct, Mayor, is that how it works?
DR. SMITH: I actually have a copy of the
Greenwich Township report with me.
MR. MORLACHETTA: A couple of the graphs I
looked at -- you show remediation programs for
80 acres, when the Hercules site is 350 acres.
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What happens to the rest of that? I don't know
if that was a misnomer or you're just
considering the areas where most of the
problems exist.
MS. PIERRE: So the 80 acres is the former
plant area. And that is where the
contamination is, and that's what we're
addressing.
The solid waste disposal area, which is a
another 5 acres. The rest of the site --
MR. MORLACHETTA: Clonmell Creek is not a
part of the 80 acers, right?
MS. PIERRE: Clonmell Creek is not part of
the 80 acres.
MR. MORLACHETTA: You're using that as a
remediation?
MS. PIERRE: We are remediating the
portion of Clonmell Creek that is on the site,
yes .
MR. MORLACHETTA: I can assume that you're
going to remediate more if it's necessary.
MS. PIERRE: Right. We've investigated
the entire site. And our findings are that the
area that we're proposing for remediation are
the areas that have the contamination.
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MR. MORLACHETTA: We're especially
concerned because we live so close to the site.
MS. PIERRE: Absolutely. Understood.
MR. MORLACHETTA: Thank you, again.
MR. SINGERMAN: I just want to add one
thing. The superfund finds the site as the
source of contamination and to where it's gone.
So any contamination that has migrated beyond
the creek would be addressed.
So if the creek is -- whatever is
contaminated in the creek, it's considered part
of the site.
And again, our objective is to clean up
all contamination.
MR. BRADY: Hi. My name is Tom Brady. I
live at 720 Washington Street. I have a
question for the EPA.
When you guys were mentioning things about
contracts, Hercules, are they associated to
Ashland Corporation?
MS. PIERRE: Yes.
MR. BRADY: Who originally owned the site
that's contaminated?
MS. PIERRE: Prior to Hercules?
MR. BRADY: Correct.
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MS. PIERRE: DuPont.
MR. BRADY: Okay. So we have the company
that's doing all the tests, that's the same
company that contaminated the site, originally?
MS. PIERRE: Right, meaning Hercules.
MR. BRADY: Okay. It's basically like if
I go in and shoot somebody and I'm doing
forensics on my own gun, isn't that a conflict
of interest?
MS. PIERRE: No. Because this is being
done with EPA oversight. So we are reviewing
all the data --
MR. BRADY: Well, to be honest with you,
that doesn't make me feel any better.
MR. SINGERMAN: Under the superfund law,
if there are liable parties out there, we
prefer they deal with it first, because the
Superfund is only --
MR. BRADY: If they obeyed the law first,
they wouldn't have contaminated the site. So
you really think that they care about the law
when they are evaluating their own site, they
are paying for their own site, and all you guys
are doing is just doing Jack in the Box.
You can say whatever you want about
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improved labs and whatever else, but I find
that to be a conflict of interest. I wasn't
born yesterday.
MR. SINGERMAN: Well, we signed an
agreement with Ashland. There are penalties.
They are required --
MR. BRADY: Penalties on a company that
has revenue of over $4 billon. And it only
cost them 12 million, so do that math. You
really think a little peasy couple million
dollars is going to hurt a company like that?
You really think they care about
Gibbstown? You really think they care that
it's going to take two years to do a minimum
cleanup for something that's been in place for
30 years and is going to take another decade to
make an assumption that it's going to be
cleared? Come on.
MR. SINGERMAN: Well, obviously they care,
because they entered into an agreement.
MR. BRADY: If they cared, as I said, they
wouldn't have allowed that to happen in the
first place.
MR. SINGERMAN: But the thing was many
companies didn't hold a standard of practice
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back in the day. It wasn't until -- a lot of
environmental regulations weren't in existence
at the time. That's one of the reasons why we
have Superfund. We have disposal practices
that occurred going back 70, 80 years and no
one cared.
For example, Love Canal, that was one of
the first steps -- I don't know if you've ever
heard of the site -- that basically triggered
an ultra fund program. It was a canal that was
never finished. They put chemical wastes in
there. They built a school on top of it. And
houses were built right next to it. And it
started leaking.
At the time, it wasn't necessarily that
chemical disposal had any intentions to hurt
anyone, that was the practice back then.
But we entered an agreement with Ashland
to do the work. It's under EPA oversight. And
our objective is to clean up the site. If we
have viable parties that are willing to do the
work, we have them do the work.
MR. BRADY: You're saying you're going to
help clean up the site, and I want it to be
approved to allow for residential and
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commercial. Because if I'm a business owner,
I'm not going to seek out to build on that
site. And I'm sure as hell not going to move
to Gibbstown as a resident to build on the
site.
So why don't you force them to clean it up
to a residential level and do it the right way?
Because right now, it seems to me like you're
just making excuses to cut corners just to do
the bare minimum.
MR. SINGERMAN: No. First of all, we look
at the zoning of the property. If there's no
plans to make it residential, then we clean it
up to the levels of what the current zoning is.
There are different levels based upon the use
of the property.
MR. BRADY: Well, to be honest with you I
don't look at it as Gibbstown, as I live here
and this is commercial. I look at all of
Gibbstown as my neighborhood. And I can live
anywhere or go anywhere in Gibbstown.
Gibbstown, to me, is my home.
MR. SINGERMAN: Right. And we're cleaning
this property up to commercial use, because --
commercial industrial use, that's what it's
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zoned for.
Once it's cleaned up, industrial and
commercial use can be used for that --
MR. BRADY: We have other property that's
zoned for commercial, nobody is building there.
Do you think anybody is going to select this
property any time soon and say, You know what?
I'm going to go build on that site. Knowing
this is part of a superfund site. And there's
a possibility that there's contamination left
in there?
MR. SINGERMAN: As it was indicated, there
were thousands of samples taken all over the
property. And that's why the study took so
long. We wanted to make sure that we did a
sufficient job to try to find the
contamination.
And we think the remedy that's proposed
will clean up contamination and make it safe
for commercial industrial use.
MR. BRADY: I'm still not satisfied with
your answer, but you're not going to please me,
honestly. I'm just calling BS on it. That's
the way I am.
Can you go to the slide that says how long
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the project might last, from two years to 10
years, please?
Can you explain the two years and the 10
year marker on that? Can you explain what that
actually means? What does that mean?
MS. PIERRE: So the two years is the
estimated construction time, that's the time
there will be activity at the site in terms of
excavating, building groundwater treatment
system, things of that nature.
In the time to meet the cleanup level and
the soil being treated after being excavated
and also the soils being treated in place,
that's what you're seeing in the other
timeframe, the one year and the 10 years. And
the same with the groundwater.
MR. BRADY: So you're saying it could take
up to 10 years now, correct?
MS. PIERRE: It could take up to 10 years
to meet the cleanup levels.
MR. BRADY: So the project is projected to
take 10 years.
MS. PIERRE: To meet the cleanup levels.
MR. BRADY: 10 years. It's a yes or no
question.
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MS. SEPPI: Yes.
MR. BRADY: So 10 years. So 10 years from
now, the site should be considered ready for
construction to build a factory, a warehouse,
whatever?
MS. PIERRE: That's the point I was
making. 10 years to meet the cleanup levels in
the media that's being treated below the
ground, so the deeper soils and the
groundwater.
But it will not take that long for the
site to be able to be redeveloped. Once we
meet the cleanup goals and treat the soils,
basically --
MR. BRADY: How long's that?
MS. PIERRE: Two year construction time.
MR. BRADY: Two year construction time,
but it's not going to be totally stamped for
approval for 10 years, right?
MS. PIERRE: No.
MR. BRADY: Am I missing something? To
me, it looks like it's going to take 10 years
still.
MS. PIERRE: Well, the deeper soils and
the groundwater can continue to be treated.
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And the site could potentially be used at the
same time.
MR. BRADY: Okay. So I come in to
Gibbstown and talk to Council, right? And I go
to my Mayor and say, I'm going to build a
warehouse here. It's going to cost me
$100 million. Like one town over, they just
built a brand new Amazon warehouse.
So I select this site. I build my
warehouse. You think I'm really going to build
my warehouse knowing that for another 10 years
I might have to have my soil tested? And what
if something's found?
So we want to talk about risk. Do you
really think that that's going to be something
a business or corporation is going to look at?
MR. SINGERMAN: Well, if you're building a
warehouse, it's most likely going to be on a
slab, right? It's not going to be a basement
in the warehouse, right? And all the soil
above 4 feet will be removed and replaced with
clean soil. So we're only talking about
treating for 10 years for soil that's below 4
feet.
So theoretically, a building could be
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built anywhere on the property, as long as we
still have access to the various areas still
being treated today.
In addition, there's only about 80 acres
that's contaminated. It's a 350 acre site. So
there's plenty room, although there are some
wetlands and other area designated that won't
be used.
But in addition to these areas that
surface soils will being cleaned up, there's
plenty of other area on the property.
So again, we're cleaning up the soil.
It's not going to be determined to build
something off site.
So again development should not be
hindered by the fact it's going to take 10
years to clean up soil 4 feet below the
surface.
MR. BRADY: All right. The other lady
also asked a question about -- and another
gentleman over here asked a question about
where does the material go? You guys couldn't
answer that because didn't select that. Where
do most other sites already dump their waste?
MR. SINGERMAN: All over the country there
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are disposal facilities. So during the design
process -- again, after we site the remedy, we
don't just go out and start building. We have
to design something. We have to do more
sampling to find boundaries. We have to design
the system that's being developed. We also
have to find appropriate disposal locations.
There are these facilities that sort of --
as part of that process, we'll go out and
solicit bids for approved facilities.
So again, we won't allow them to take any
materials to a facility that's not acceptable
in that way. We have this process in place
where an agency is divided by 10 regions across
the country. So each region has someone that's
responsible for making sure that all
facilities, disposal facilities, in that region
are in compliance. All the disposal facilities
that treat or accept hazardous waste have to be
in compliance with the environmental
regulations.
So we will not allow contractors to send
any foundation, like lead contaminated soils,
to any facility in this country that's not in
compliance, meaning they follow the appropriate
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regulations regarding how to process these
materials. It's most likely going to be taken
to hazardous place landfill somewhere in the
country.
MR. BRADY: Okay. And how will our town
be provided updates if this project moves
forward after decisions and final decisions are
made?
MR. SINGERMAN: After we finally select
the remedy, we will post online a Record of
Decision. And we will post the responses that
were addressed, all the questions and comments
presented today.
And we will, as necessary, keep updates on
treatments to keep the public informed. Before
work starts, we will let people know what's
going on.
We're not going to say Okay, good bye, see
you in 10 years. There's a whole process here,
where the objective is to keep the public
informed as to what's going on one way or
another. So whatever is appropriate.
And again, the website -- we will keep the
website up to date so you can always just go on
the website and see what's going on, because
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we'll post the status online.
MR. BRADY: Okay. Thank you for taking
your time.
I'd like to just take a minute to say
something to my fellow residents. If you guys
go and take a look just like I did, and you
look at this company that was once owned by
DuPont -- now it's Hercules, and then now it's
bought out by Ashland -- and don't you just
kind of think for yourselves it's kind of
coincidental that the same company that
polluted the ground is also the same company
that was awarded a federal contract to clean up
all their own problems? I find that still to
be a conflict of interest. And I'm not even
sure how that got past the Ethics Boards at the
EPA level. I would have done touch points
myself. And I would have looked at it and saw
it to be a conflict of interest.
Just like me, if I have a contract and I
go to the town, don't you think that someone
from a review board is going to look at it and
say maybe we should look at it a little more
deeper because he has a particular interest in
this? And if you look at it, also, do your own
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information on Google.
$12 million is a drop in the bucket for a
corporation that is making 4 billion a year,
not 100 million, not 400 million, 4 billion in
a year is their net revenue. Think about that.
And it's going to take up to 10 years for
us, another two year effort up to 10 years for
the soil possibly -- it's not even guaranteed.
We're not even guaranteed it.
So what's going to happen in another 10
years? You think the Federal Government is
going to come back in and say, Yeah, we made a
mistake and we're going to clean it up again?
This is my personal opinion, I think this is
all just smoke screen. Thank you.
MR. SINGERMAN: Just to clarify a few
things. First of all, EPA does not have a
contractural relationship with the contractor.
We entered an agreement with Ashland. And it's
their contract.
And we have not no contractural
relationship with CSI. They've been working
for Ashland under EPA's oversight.
In addition, once the record is
implemented, as noted by Patricia earlier,
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every five years we do what's called a five
year review. Where we look at the data, we
reassess whether or not the remedy is
protected. So from this point, once -- going
forward, we will, every five years, assess the
data and what's going on to make sure it's
still protected.
Because again, our purposes here is to
clean up the site and make sure it's protected
from this point going forward.
And the thing is -- the fact that Ashland
makes a lot of money, that's a good thing
because they have the money to pay for the
cleanup. And they have to money to pay for the
investigation.
And again, as I said, we entered an
agreement with them. And they agreed to do the
work. If they don't do the work, they pay
penalties. But they are cooperating.
And again, the important thing about
Superfund is that it's only used -- federal
funding is only used if the responsible party
is not willing or not able to do the work. And
that's when EPA hires contractors to do the
work.
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In this case, we have a viable party. And
they are willing to do the right thing by doing
the work.
DR. SMITH: I just would like to make a
little clarification that even though Hercules
is paying for the contract and is collecting
the samples, EPA is overseeing all of it. And
I can tell you that I've been involved on the
site for nine years. And I have told them
where to collect samples, how to do the
samples, how deep to collect the samples. I
told them we need more samples in this area. I
oversee all of it.
And the labs that they use are EPA
accredited labs. They go through a vigorous
process to be approved to take these samples.
And they go through a quality assurance and
quality control process. These samples are --
we can trust these samples.
I can tell you I've been involved in this
site. I care about this site. I have a cousin
who lives in this town, so I've been intimately
involved in this site. And I can tell you that
this is good data. We have a ton of samples
here. We don't often get sites where we can
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collect this many samples. So this is amazing
to have this much data to inform our decisions
here.
So I understand your frustration. I
understand maybe this is your first experience
with the Superfund process. It's a long
process. And I apologize for that. There's a
lot of legal stuff that goes on with that. But
I can tell you that we are doing the right
thing at this site. That's all I wanted to
clarify.
MS. SEPPI: And again, thank you for your
comments. Because, believe me, we hear that
many times in a lot of our sites. They are
being taken care of by responsible parties.
The one thing that Joel said that is true,
if we didn't have a responsible party and we
had to rely on federal funding, this -- I'm
telling you, this would take much, much longer
because we only have a limited amount of
funding. So we have to prioritize the sites
that are out there. And maybe this site would
be a priority, maybe not. I don't know.
So we feel that we're fortunate to have a
company that's cooperative and willing to pay.
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MR. BRADY: Please don't act like you're
doing us any favors at this point. At this
point, we're way past that. Don't --
MS. SEPPI: I'm sorry. I don't know what
you mean by that statement.
MR. BRADY: You're trying to pitch it to
us like we should be fortunate. We should be
glad they stepped up. You think we really care
about that? They've already did their damage.
So let's not try to power coat the real issue.
They done wrong. They got caught. And
you guys are stepping in because that's your
job as the EPA.
MS. SEPPI: That's fine.
MR. BRADY: I don't want to hear the spiel
like, you know, we should be fortunate and
happy.
Just like 10, 15, 20 years ago companies
that made cigarettes used to do their own
scientific things saying smoking doesn't kill.
We saw where that went.
You have a company that is hiring a third
party contractor to do their own assessment,
that's where I got a problem. It's a conflict
of interest. There's thousands of companies in
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this country, thousands. And they are all
equally able to bid on government contracts,
okay? It's just coincidental that -- it's so
ironic to me that the company won their very
own cleanup contract. That just blows my mind.
MR. SINGERMAN: This is not a government
contract. This is a private contract.
MR. BRADY: It's a private contract that
you put out for bid for a company to clean up
their own cleanup.
MR. SINGERMAN: We entered an agreement
with Ashland to do the work.
MR. BRADY: Right. Well, why don't you
bill Ashland or whatever the hell they're
called today, have them refund you. EPA can go
hire their own contract company to clean up the
site?
Why did you go through the same company
that contaminated the site to clean up their
own mess? Doesn't that sound kind of stupid?
MR. SINGERMAN: That is the process. The
parties that are responsible --
MR. BRADY: Well, maybe you need to change
your process. If this ain't the first rodeo
that you've been through -- when people ask you
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the same question, maybe you need to sit down
with your book and look at your policies and
procedures and decide maybe we shouldn't allow
people to pay us to clean up their own mess.
Maybe we should bill them. And then, if not,
we sue their ass.
MR. SINGERMAN: We do bill them for our
time. The time we spend overseeing the work --
MR. BRADY: I'm totally sure that you
probably have a nice working relationship with
Ashland on this site and everything else.
MR. SINGERMAN: We do. They have been
very cooperative.
MR. BRADY: I'm sure.
DR. SMITH: I just want to make one more
clarification. Hercules is the company that --
DuPont originally owned the site. Hercules
bought it from DuPont.
MR. BRADY: And now Hercules is owned by
Ashland.
DR. SMITH: Hercules contaminated the
site. Ashland came in and bought out Hercules
and the --
MR. BRADY: But they are all linked
together --
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DR. SMITH: They bought the liability --
MR. BRADY: They are all linked together.
AUDIENCE MEMBER: Can you please allow her
to finish?
MR. BRADY: Don't be trying to make
excuses.
DR. SMITH: I'm just trying to clarify so
you understand the line of succession at the
site.
So Ashland came in and bought the
liability of the Hercules site. So they are
coming in and cleaning it up, because Hercules
didn't.
MS. SEPPI: It's not only the company that
actually did the contaminating of the site, but
it's a successor coming in who probably had
nothing to do with the actual contamination.
But when they bought the company, they assumed
their assets as well as their liabilities. And
that's what happened in this case.
So that's why we feel that we have a
responsible party here who didn't necessarily
contaminate the site themselves, but when they
took over Hercules, they became responsible for
cleaning the site.
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MR. BRADY: When you buy a company, you
also buy their debt, you buy their problems --
MS. SEPPI: Absolutely. That's correct.
MR. BRADY: So they're responsible for
this .
MS. SEPPI: I'm sure they knew that when
they took the company over.
MR. BRADY: Maybe they did, maybe they
didn't.
MS. SEPPI: That's possible, too. I have
no idea.
But thank you for your comment. We
appreciate that. We do.
Any other questions?
MR. CAMPBELL: How you doing? Lee
Campbell.
The athletic fields that are neighboring
the Hercules fund site, was there testing done
on them athletic fields where our youth kids
play sports? Do you know if -- was there any
type of testing?
Because I do know, probably, 10, 15 years
ago Hercules was on supply, a water supply, for
a sprinkler system. And in that far corner, I
don't know what corner it is, the far corner of
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Page 71
the property away from the river, they drilled
down. They drilled for water. And they did
hit benzene.
So that property being there, was there
testing done on them athletic fields?
MS. PIERRE: Craig, can you speak to that?
MR. STEVENS: The site's been
delineated --
MR. CAMPBELL: I know there's multiple
sites all -- you said throughout the town. I
was just wondering if that property right next
to it was tested.
MR. STEVENS: The testing went up to the
property line and right in that area. And
reached the EPA required goal, so there's no
need to do other testing. The groundwater
containment system, the capture zone is along
here. Hercules didn't install that. That was
done without their knowledge. And testings was
done on that well.
So the irrigation wells that you're
referring to was installed by someone else in
that area. And then it was tested. And you're
right. It's within the capture zone. We could
predict that deep, not shallow, deep. We're
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talking 100 feet below the ground surface.
There's going to be low levels of impact from
the site that would be all within the capture
zone. So that irrigation well was never used
after that. So does that answer the question?
MR. CAMPBELL: Yeah. I just wanted to
know if there was testing actually on them
athletic fields. So I guess your answer is
there wasn't testing because it didn't go on
the outside.
MR. STEVENS: Right. We have delineation
along the property boundary in that direction.
So there's no need to step out to prove it
extends beyond that.
MR. CAMPBELL: What do we have to do to
get that -- the EPA, what do we have to do to
get them fields tested? Because I'm sure that
probably reached over a little bit. What's the
chances of getting them fields tested?
MS. PIERRE: Are you referring to the
soil?
MR. CAMPBELL: Yes.
MS. PIERRE: So, again, our data does not
indicate that the soil contamination extends
off the site property. So we do have samples
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up to the property boundary to show us that the
soil contamination does not extend beyond the
property boundary.
MR. CAMPBELL: Okay. Thank you.
MS. COLLINS: Pat Collins. 107 West Broad
Street. I'm the branch manager at the library.
I wanted to invite you to over to review some
of the material that Mr. Morlachetta looked at.
We have disks and we have flash drives and we
have information. Also there are some books
going back several years. And they were
checked every year during this site work.
Also, my dad worked at Hercules. So it's
interesting to listen to this.
But do come over and spend some time in
looking at all of the maps. One of the things
that was on the report were the floor of the
fauna. Was anything done with that in your
newer reports? You know, the animals that
lived there and the plants that lived there?
MS. PIERRE: Yes. We did conduct an
ecological risk assessment as part of the RI.
So that information would be in the RI report.
MS. COLLINS: That information would be in
the RI. So that information would be
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comparable to what was there before?
MS. PIERRE: Yes.
MS. COLLINS: Thank you.
MS. SEPPI: RI is remedial investigation,
so if you wanted to look up any information --
thank you, Pat. It's nice to know the library
is available for anyone who wanted to take a
look at it.
Anymore questions?
MS. MEEHAN: I just have one last --
Jennifer Meehan, again. I just have one last
comment or question since I know I have a
little bit of concern about the whole who's
paying for it, and third parties, and the
neutral party.
Even though Hercules or the new former
Ashland is paying for all this, if there are
EPA funds that otherwise would have to be
allocated if there wasn't an owner paying for
things, could there be an additional fund set
aside to have some kind of neutral, outside
party that's not involved with the company
that's paying for it to do some periodic
testing to let residents feel a little bit more
confident about what the results actually are?
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MR. SINGERMAN: Again, as I said earlier,
because of the fact we have liable parties to
do the work at our oversight, we're overseeing
the work, making sure it's being done properly.
The laboratories they all go through are
approved EPA laboratories. And there is a
third party ensuring that the data is valid.
So we have no reason to believe that we need to
spend additional funds or government funds to
conduct an independent investigation.
Sometimes if we have problems with
responsible parties that require the work, we
will split samples with them and make sure that
we agree with the results.
But in this case, we think that we have a
party that's doing an appropriate job. And we
don't see a need for samples. We think what's
being done, that data they are generating is
appropriate and is correct.
And again, as I cited earlier, we think
it's a good thing that the responsible party is
willing to do the work. Because as I sited in
my section, there are no viable parties and
sometimes you have to wait several years,
depending on how much money, you have to wait
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Page 7 6
for the money.
So if this was a fund financed activity,
it's possible that there may be several years
before we were able to start. Here, we have a
viable party that wants to finish the design.
Once they finish the design, they'll be able to
go out there and start the work, as opposed to
a fund financed effort that could be three,
seven years before we actually get the money,
because we have limited funding. And we have
many sites across the country. There's just
not enough budget for this area. It's all 50
states.
MS. SEPPI: It sounds like it's a good
idea. We just don't have that kind of money to
set aside funding. Any money that we have is
trying to be used to clean up the sites that's
not being taken care of by the party.
Joel is absolutely right. I mean, I have
about 30 sites. There are many of them just
kind of sitting out there in limbo because they
haven't prioritized them to start receiving
money.
So it's a difficult situation if it's a
funded site by the EPA. You might have to
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wait, like Joel said, quite a long time. So at
least here we feel like we're moving ahead. It
would be nice if we have had that kind of
funding that we could give to something.
MS. PIERRE: Just to piggyback on what
Joel and Pat said, we do not have the ability
to just decide which sites will be funded,
where superfund moneys are used for the
cleanup, versus a responsible party.
If we have a viable, responsible party,
who is willing to do the work, able to do the
work, then we have to follow our process, which
is to allow them to do the work under our
oversight. We don't really have, you know, the
authority to change the process.
MR. SINGERMAN: Also, sometimes, you know,
other sites we have parties that were
responsible, but they are not willing to do the
work. Sometimes we have to force them to do
the work. In a case like that, perhaps we have
to do work, those oversights, sampling. We
can't necessarily trust them.
Or if they are not willing to do the work,
then what we need to -- we can do the work and
then we would bill them. But in this case, we
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have a liable party, which makes the process go
much more quickly because the fact they are
doing it at their expense. And we don't have
to go through the process of obtaining money to
do the work.
We think it's a good thing that we have a
responsible party, that's being responsible,
that's stepped up to the plate and is doing the
work.
Again, it's under EPA's oversight. We're
not letting them lose to do whatever they want.
They have to develop sampling plants, they have
develop quality assurance plans. There's a
whole process they have to go through before
they can take any samples.
So we have all these people that review
these reports and they are experts in the field
to make sure that the processing they are using
is acceptable, the laboratories they are using
are acceptable. We have very close supervision
of what's going on.
And like we said, Ashland is being very
responsible. And Lora mentioned the fact that
she went out to the field and pointed out get a
sample from here, there, and there, they
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Page 7 9
weren't happy about it, but they did it.
MS. SEPPI: Sometimes, too, we'll have a
responsible property who is not cooperative and
refuses to do the work -- and I have a couple
sites right now, where they go to court and it
comes up in litigation. So in the meantime,
that site is kind of sitting there waiting for
something to happen. We feel sorry for the
people who are living on or near that site,
because it's tied up in the courts.
As Joel said, sometimes after awhile we
have to step in and just say all right. This
is going nowhere. We'll fund the money to
clean the site and then we'll collect it from
you later. There's a lot of different ways
this can happen.
Anymore questions?
MR. BRADY: Are there any other sites that
have been identified that've not been dealt
with yet in Gibbstown?
MS. SEPPI: I'm not aware of...
MR. SINGERMAN: This is the only National
Priorities List site that's in Gibbstown.
MR. BRADY: Say that one more time. I
didn't understand.
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MR. SINGERMAN: National Priorities --
Superfund sites are put on what's called a
National Priorities List. The Hercules site is
the only site in Gibbstown that's on the
National Priorities List.
There are other sites in other cities in
New Jersey, but this is the only one that's in
Gibbstown.
MS. SEPPI: Actually, an interesting fact
is there's about nationwide approximately 1,400
sites, 1350. New Jersey has approximately 115.
New Jersey has more Superfund sites than any
state in this country.
And a couple reasons, mainly it's because
they are highly industrial. One of the reasons
is because we have very strict environmental
laws. But I always find it interesting for
such a small state, you know, we have that many
sites.
MR. STEWART: My name is Doug Stewart.
I'm the environmental consultant for Greenwich
Township. And I've been reviewing this case
for some matter of years. I was involved with
the vapor intrusion. We also did check the
soil data when the ball fields got flooded
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Page 81
about five or six years ago, so we did kind of
do that.
And a little different than -- maybe what
a lot of these folks can tell you, this isn't
really their decision. Yes, it's presented by
Ashland. Yes, Ashland pays. But we have been
inconsistent at times. And I can say this, I
don't work for any of the agencies anymore. I
did at one time.
You have federal rules based on federal
laws. You have New Jersey laws and New Jersey
rules. New Jersey rules, sorry guys, we're
better for public health and the community in
my view. I worked for the state agency. I
gave $200,000 a year, $200 million, a year for
cleanups. Over four years, 2,000 cases. And
the case where the responsible parties would
not do the work, went to, what's called,
publicly funded. That's your contract sport.
And those are the worst cases.
The contractors change. The contracts are
only for so long. And even a case like this,
for the amount of time that it's taken, will
take longer. Everything is about the contract.
Getting back to -- I couldn't help
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anymore -- the number of cases, sites, in New
Jersey, and particularly this site, was in
1982 -- EPA had a clear authorization and a
track to handle these kind of cases. The EPA
didn't have that many employees. The State
didn't have that many employees. It took a
group of employees who looked at these worst
cases and there was a numerical ranking system.
And if New Jersey could get the ranking
system high enough to get on the national
priority list, it was punted to EPA. And so
whether there were more sites actually in New
Jersey or New Jersey was just more proactive
because the funding wasn't there for the State
to do it. The same cases that I have private
parties give $200 million a year, the State
could have never paid for that.
So that's one of the reasons, quite
frankly, I believe, why things take a little
longer. At some point, EPA took care of it and
they gave some money to the DEP. The DEP
helped them along. And DEP did it for a while.
It's not a great system. I'm sure there's
other states where you guys just do it and the
State is not involved with it.
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Page 83
That's the history of where all these
sites come from. And to make different
decisions relative to residential or the level
of cleanup and things like that, it's specified
not just in the laws, but, quite frankly, in
the rules sometimes.
The New Jersey rules in 1993 were only
slightly modified. The state legislature said,
You don't have to clean up if it's costs too
much. If you can cap it in place if it's not
getting in groundwater or if it's not getting
into the air. So things like capping are
approvable in DEP to modify legislatively a few
times.
These guys, they are working in the
confines of law. The question that you would
like to live anywhere you want in town and it
should be cleaned up to that, in North Jersey
if you're willing to pay $450,000 for a one
bedroom condo and a car park to live on a site
like that, I have news for you. You cannot
plant a tomato plant. You cannot dig through
the liner of your yard. So yes, you can have
residential on the property if the market will
bear it to have residential from all the
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Page 84
environmental controls you have in place.
I just think that's important background
on that. And I think, also, that I've been
doing this for 36 years. I was both an agency
person, briefly a contractor, if anything now,
I'm almost an anti-contractor. I do test
everybody's paperwork, their samples, their
maps, their end points. And it has been done
here.
And as far as the future of this property
to be put back in productive use, which is, I
believe, one of the objectives of the Township,
I think this is how we're going to get there
for a more productive use.
If anyone has any other questions, I'll
stay a little after.
AUDIENCE MEMBER: How did you resolve the
vapor intrusion by just capping DuPont?
MR. STEWART: Capping DuPont?
AUDIENCE MEMBER: They went in there and
just capped it.
MR. STEWART: Do you mean Hercules?
AUDIENCE MEMBER: No, DuPont.
MR. STEWART: I'm not familiar with vapor
intrusion on off site in the residential. But
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vapor intrusion can be on a residential
property or a commercial property if you build
the structure to handle it.
In some ways, it's no different than
radon. If you have radon in your house and you
put in an passive venting system on an active
venting system, if you're stuck with
contamination, it can't be addressed.
AUDIENCE MEMBER: My question was DuPont
had several instances --
MR. STEWART: I'm not familiar with an
unknown vapor intrusion coming off the
properties.
AUDIENCE MEMBER: But they are about to
cap something that's 200 some acres of
contaminated soil. How do you stop vapor
intrusion from coming through that cap?
MR. STEWART: The allowable levels of
capping, as far as the soil removal, and I said
it before about capping for residential,
nonresidential use, it cannot contribute to
groundwater contamination or surface water.
And it can't be released to vapor intrusion.
So the things that are being capped are
really the things that you can't come in
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Page 86
contact with that you can't eat and you can't
get on your skin. But they shouldn't be in
groundwater. And that's the quantum leap on
this basis. They are getting more source
control of the contaminants.
And in fact, in this case, a major leap
forward is whether or not anyone here wanted
are to -- they are using the DEP standards,
which are definitely more stringent, the impact
of groundwater on this are more stringent than
what affects would necessarily apply if it was
just their decision.
So New Jersey is looking out for you
legislatively as best they can. These guys are
stuck with a whole lot of cases because the
State of New Jersey couldn't punt the ball to
get rid of these cases. They had no money and
they had no staff.
So like I said, I'll be here afterwards.
I shouldn't have taken any questions from these
guys .
MS. SEPPI: No, that's fine.
MR. SINGERMAN: Just to clarify, when the
State has a more stringent standard, we always
pick more stringent standards.
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MR. STEWART: We're not going to have that
discussion.
MR. SINGERMAN: We always pick the more
stringent standard.
MS. SEPPI: Okay. Anybody else have a
question? Sir?
MR. RIDINGER: The tar pits
MS. SEPPI: Could you come up here,
please?
MR. RIDINGER: Ken Ridinger. The tar pits
that were mentioned earlier, is that natural
tar or is that just a sludge? I mean, what
kind of tar are you talking about? Is that
like a hotspot of chemicals that were put in
the ground?
MS. PIERRE: Our understanding is that the
tar pits are bi-product of animal reproduction,
the process that DuPont used --
MR. RIDINGER: Still bodies?
MS. PIERRE: Still bodies, correct.
MR. RIDINGER: Is it hazardous?
MS. PIERRE: It is hazardous.
MR. RIDINGER: Okay. Is it lime?
MS. PIERRE: There's a thin permeable cap
that does not allow infiltration into the
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waste.
MR. RIDINGER: I'm not worried about the
cap. I'm concerned about the cap, because she
talked about the floodplain and the fact that
the cap might be an easy way out. Can this --
is this sludge going to go permeate into the
ground continually year, after year, after
year?
Down the highway, we had the Bridgeport
Rentals. They had a sludge pit. That was a
Superfund site, I guess you know already. And
I'm thinking of the same thing. And isn't it
kind of -- I don't know. It's kind of an
oxymoron to put a cap on it and walk away from
it. I think. Is it a money issue?
MS. PIERRE: It's definitely not a money
issue. We certainly haven't walked away from
it. The remedy was capping, but we also
included groundwater monitoring.
Now, as part of the OU3 remedial
investigation, many groundwater samples were
collected. And what we saw is that there is
really minimal impact to the groundwater in
that area.
But for the contaminants that we did see,
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we are monitoring on a quarterly basis.
MR. RIDINGER: This is oil-based, right?
MS. PIERRE: Yes.
MR. RIDINGER: So you're saying it's never
going to make its way down into the water?
MS. PIERRE: What we have seen based on
the samples that we've collected during the
remedial investigation, also as part of the
long-term monitoring, is that there are minimal
impacts to the groundwater in that area.
MR. RIDINGER: I would feel better if it
got pumped out, or -- you can't get a liner in
there now. If it doesn't have a liner, capping
it worries me. I just want to make that point.
If you have a few extra bucks, get it out of
there. That's what I want to say. Thanks.
MR. SINGERMAN: The fact that it has
internal memory means that water cannot
infiltrate through. So as a result, it's
basically no -- water is not getting into it.
There's no migrate.
And the fact that groundwater samples are
collected around it quarterly, and we don't
find anything in the groundwater, that's an
indication that it's working.
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But again, if something is detected, and
in the future -- that's one of the reasons we
do five year reviews. We look at the data. If
it shows that levels are going up, then we have
to reconsider the remedy. At this point, it
appears that it's working because the levels
are going down.
And the thing is, there was no liner
placed there because I believe it was a
wetland. So they didn't put a liner down. So
it's not reaching as you go off the water
that's going through.
MS. SEPPI: Any questions?
(No response.)
MS. SEPPI: I thank you all for coming.
It was a very lively discussion. And we
appreciate that.
And as I said, early next week, if you're
interested in seeing this, I will post it
online on our web page. And the proposed plan
is already up on the web page if you want to go
through. There's a lot particular information.
And you have mine and Pat's information.
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The press will release the notice that went
out. It's on the web page, also. So don't
hesitate to call us at any time. We'll be
happy to answer any of your questions and
answer your calls.
Does everyone know what our web page is?
WWW.DPA.gov/Superfund/Hercules-Gibbstown.
Or an easy thing, go to Google. Google
Hercules superfund site. It will take you
there, too. Any other questions?
MS. COLLINS: Can you send that to me,
too, so I can put it on our web address? Thank
you.
You have two weeks to put your comments
it?
MS. SEPPI: Well, they have until
August 28th. Then it will take some time to
put the Responsive Summary together. And then
we have to get the transcript from Kathryn.
And that will have all the questions and
comments on it. We'll work on putting those
together.
And once the Record of Decision is ready,
probably towards the end of September, that's
our goal, that will be put online. I'll let
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people know and make it easier. We have our
email list. And you can go on there to see
what their decision is and also the response
will be answers to your comments. Thank you
again.
Whereupon the meeting concluded at 8:48 p.m.
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CERTIFICATION
I, hereby certify that the
proceedings and evidence noted are
contained fully and accurately in the
stenographic notes taken by me in the
foregoing matter, and that this is a
correct transcript of the same.
Kathryn Doyle
Court Reporter - Notary Public
(The foregoing certification of
this transcript does not apply to any
reproduction of the same by any means,
unless under the direct control/or
supervision of the certifying reporter.)
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APPENDIX V-d
Written Comments Received During Public Comment Period
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Sierra
NEW JERSEY CHAPTER
Club
145 West Hanover St., Trenton, NJ 08618
TEL: [609] 656-7612 FAX: [609] 656-7618
www.SierraClub.org/NJ
FOUNDED 1892
Patricia Simmons Pierre, Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor, N.Y., N.Y., 10007
pierre.patricia@epa.gov
Re: Hercules, Inc. Superfund site in Gibbstown, N.J.
Dear Ms. Pierre,
The Hercules, Inc. Superfund Site cleanup up plan with a cap and continued pump and treat is an
interim cleanup and not a long-term decision. Based on your own guidance, we
the preferred cleanup plan should be a full cleanup plan because it is the only real way to ensure
the public health is protected. These methods of institutional controls will fail at some point. We
believe the record of decision should call for a complete cleanup plant or remove the tar pits and
toxic chemicals underneath it like lead and benzene. This is one of the worst Superfund sites in
New Jersey and under the EPA Priority List, it should be treated as such.
We support the remediation plan that includes the removal of contaminated soil on the site and
continuing pump and treat of ground water. But we are concerned that it will not fix the
underlying problem which are the tar pits. The EPA pumped out 2 billion gallons of
contaminated groundwater for the site, but it will continue as long as the tar pit is still
there. Pumping is an interim solution, not a full remedy. Toxic chemicals such as benzene and
lead are located under the tar pits and pose a serious threat to the community and the
environment. Benzene can affect people's immune system, increase their chance of infection,
and even cause cancer. Lead can also cause illness and even in small amounts can lead to brain
damage and learning disabilities.
We are concerned that contamination off the site could migrate. If the contamination in the
aquifer migrates, local wells may be threatened. Pollutants can leach from the disposal area into
the surrounding wetlands or Clonmell Creek and impact wildlife. Toxic chemicals can also
spread into the Delaware River because the Clonmell Creek feeds into the river.
The other issue is that the cleanup plan includes capping in a flood prone area. We believe that
simply capping over the contaminated soil is not the best action for the environment or the
people of Gibbstown. There are other options that could work to better remove and store the
contaminated materials until they can be completely removed from the area. Storing them
elsewhere rather than capping them keeps the contamination out of the floodplain in the
meantime. All of the metals, VOCs, and lead have to be removed from the system because
institutional controls will not work here in the long term. We have seen institutional controls
damaged or knocked out during floods, releasing toxic water into the nearby water sources.
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Sierra
NEW JERSEY CHAPTER
Club
145 West Hanover St., Trenton, NJ 08618
TEL: [609] 656-7612 FAX: [609] 656-7618
www.SierraClub.org/NJ
FOUNDED 1892
We are urging the EPA to make sure that the tar pits are removed in their clean up plan for the
Hercules- Gibbstown Superfund site. Capping the contaminated soil will not effectively contain
the toxic materials that can leach out into the community and environment. Caps will not address
the contaminated soil, they will fail and undo all of the progress of getting rid of the
contamination on this site.
If you have any questions or would like to discuss this matter further, please feel free to call me at
(609) 558-9100.
Sincerely,
Jeff Tittel
Director, New Jersey Sierra Club
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APPENDIX VI
STATEMENT OF FINDINGS FLOODPLAINS AND WETLANDS
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STATEMENT OF FINDINGS FLOODPLAINS AND WETLANDS
Need to Affect Floodplains and Wetlands
Approximately 218 acres of a 100-year floodplain and an additional 43 acres of a 500-
year floodplain are located within the Hercules, Inc. site boundary. The floodplain is
associated with the Delaware River and Clonmell Creek and is present, primarily, in the
northern portion of the 350-acre site.
In 2007, a wetlands letter of interpretation/line verification was submitted to and approved
by the New Jersey Department of Environmental Protection (NJDEP). As part of this
effort, the wetlands at the site were mapped and surveyed. The resulting maps indicate
that approximately 168 acres of wetlands are present within the site boundary. These
mapped wetlands primarily consist of palustrine forested wetland, with palustrine scrub-
shrub/emergent wetlands, palustrine emergent wetlands, and open water/emergent
wetlands also being present. These wetlands are located to the north and south of
Clonmell Creek, from the western to the eastern Site boundary. Clonmell Creek and four
small areas located between Clonmell Creek and the on-site Gravel Pit Area are classified
as open water/emergent wetlands. Some scrub-shrub/emergent wetland areas are also
located in the area between Clonmell Creek and the Gravel Pit Area.
Soils in portions of the floodplain within the site property boundary, sediments in a portion
of Clonmell Creek, and sediments in the Stormwater Catchment Basin contain elevated
concentrations of contaminants of concern (COCs) that exceed site remediation goals.
The March 2017 baseline ecological risk assessment (BERA) determined that the
sediments within the Stormwater Catchment Basin and a portion of Clonmell Creek pose
a risk to ecological receptors. The results of the June 2017 baseline human health risk
assessment indicated that the contaminated site soils do not pose an unacceptable risk
to human health, however, the concentrations of benzene, cumene, and collocated COCs
in the shallow groundwater in portions of the site pose a direct contact exposure risk to
human health. Because the benzene, cumene, and collocated COCs are present in site
soils at concentrations that exceed applicable New Jersey nonresidential direct contact
soil remediation standards and are acting as a source of contamination to the
groundwater, and because site sediments are associated with unacceptable ecological
risk, remedial action alternatives were developed in the feasibility study (FS) to address
the soils and sediments in portions of the wetland and floodplain areas at the site.
The selected soil and sediment alternatives, Alternatives S-3 and SED-3 include the
excavation and hydraulic dredging of contaminated soils and sediments, respectively,
from portions of the on-site floodplain area. Impacts to wetlands, if any, will be associated
with the launching and recovery of the hydraulic dredge to remove sediments and are
anticipated to be minimal and temporary. Because the Stormwater Catchment Basin was
historically a functional stormwater management feature, its associated wetlands have
been classified as a poor habitat. The resulting modifications to the Stormwater
Catchment Basin area are anticipated to improve the wetland habitat in this area following
completion of the selected remedy.
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Installation of the soil cover associated with the Alternative S-3 soil remedy is estimated
to impact approximately 1.2 acres of the 100-year floodplain and 12.5 acres of the 500-
year floodplain in the Tank Farm/Train Loading and Active Process Areas. Although the
floodplain will be modified in this area, the soil cover will alleviate ponding in the Tank
Farm/Train Loading Area, which currently causes increased recharge to the shallow
groundwater table. Minimizing groundwater recharge in this area will decrease
groundwater seepage velocities, thereby improving stormwater drainage in the southern
portion of the site, increasing the protectiveness of the groundwater remedy. Temporary
disturbance of approximately 2.9 acres of the 100-year floodplain and 0.7 acres of 500-
year floodplain is expected to occur in the Stormwater Catchment Basin and Northern
Chemical Landfill Areas where the dredged sediments and the hydraulic dredge will be
staged, respectively. Approximately 1.6 acres of the 100-year floodplain are anticipated
to be temporarily disturbed as part of the expansion of the Stormwater Catchment Basin
area to improve storm water drainage in this area over the long term.
In addition to the selected soil and sediment alternatives, the FS considered no-action
alternatives, Alternatives S-1 and SED-1, which would not entail excavation of
contaminated wetlands/floodplains soils and sediments. Under Alternatives S-1 and SED-
1, the contaminated soils and sediments would have remained in-place, posing a risk to
on-site ecological receptors, and would have continued to act as a source of
contamination to the groundwater. Thus, the no-action soil and sediment alternatives
would not be protective of human or ecological receptors. The implementation of any of
the action alternatives developed in the FS would be more protective of human health
and the environment than the no-action alternatives, because they would meet the
remedial action objectives and remediation goals for the site and would result in less
residual risks than the no-action alternatives.
EPA and NJDEP have determined that there is no practicable alternative that would be
sufficiently protective of human health and the environment that would not result in the
excavation of the soils and sediments located in the floodplain and wetlands areas.
Consequently, any remedial action that might be taken would affect the floodplain and
wetlands associated with the site.
Effects of Proposed Action on the Natural and Beneficial Values of Floodplains and
Wetlands
Excavation of contaminated sediments and soils in the wetlands and floodplain will result
in temporary, localized disturbance to the on-site wetlands and floodplain. The estimated
construction timeframe for the selected remedy is 12 months. It is not anticipated that
implementation of the selected remedy will result in any significant alteration of the
existing site hydrology.
The primary benefit of the selected remedy will be the removal of the soil- and sediment-
bound contaminant mass from the floodplains in several portions of the site and the
wetland areas associated with the Stormwater Catchment Basin. The contaminated
sediments will be removed from the floodplains and will no longer function as a source of
contamination for the downstream areas or pose risk to ecological receptors. In this
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context, the selected remedy will have a substantial positive impact on both the natural
and beneficial values of the floodplain and wetlands.
Compliance with Applicable State or Local Floodplain Protection Standards
All remedial work in the wetlands and floodplain bed will need to comply with the
substantive requirements of the New Jersey Rules on Coastal Resources and
Development (7:7E-1.1 et seq.), Freshwater Wetlands Protection Act (NJSA 13:9B-1 et
sea), Flood Hazard Area Control Act Regulations (NJAC 7:13-10,11) Soil Erosion and
Sediment Control Act (NJDA 4:24-39 et seq.)jas well as Executive Order 11988,
Executive Order 11990, 40 CFR Part 6 Appendix A, "Statement of Procedures on
Floodplains Management & Wetlands Protection," and Section 404 of the Clean Water
Act.
Measures to Mitigate Potential Harm to the Floodplains and Wetlands
Mitigation measures will be undertaken to reduce impacts on floodplains and wetlands,
including:
application of engineering procedures to the wetlands {e.g., berms, silt curtains, etc.)
during remediation to prevent spreading of contaminated sediments particularly during
a flood event;
restoration of the disturbed remediated wetlands and floodplain soils, if necessary;
restoring the existing floodplain resources affected by the selected remedial action;
development of a five-year wetland restoration monitoring plan during the remedial
design to ensure that the restoration achieves the desired result and to protect against
the establishment of unwanted invasive plant species; and
routine inspection of the restored wetlands and replanting to ensure adequate survival
of the planted vegetation.
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