DECISION DOCUMENT, PULVERIZING SERVICES SITE ...

SDMS Document

•100025

DECISION DOCUMENT

Pulverizing Services Site

Moorestown, Burlington County, New'Jersey

United States Environmental Protection AgencyRegion II

New York, New York

500001

DECLARATION STATEMENT

DECISION DOCUMENTI

SITE NAME AND LOCATION

Pulverizing Services SiteMoorestown, Burlington County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Decision Document memorializes the U.S. EnvironmentalProtection Agency's selection of the response measure to addresssoil contamination at the Pulverizing Services site, in accor-dance with the requirements of the Comprehensive EnvironmentalResponse, Compensation and Liability Act of 1980, as amended(CERCLA) 42 U.S.C. §9601 et seq. and to the extent practicable,the National Oil and Hazardous Substances Pollution ContingencyPlan, as amended, 40 CFR Part 300 et seq. This Decision Documentexplains the factual and legal basis for selecting the responsemeasure at this site. The information supporting this responsemeasure is contained in the administrative record for the site,the index of which can be found in appendix III to this document.

The New Jersey Department of Environmental Protection has electednot to review documents or provide any state oversight for thePulverizing Services site.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from thePulverizing Services Superfund site, if not addressed byimplementing the response measure selected in this DecisionDocument, may present an imminent and substantial endangerment topublic health, welfare, or the environment.

DESCRIPTION OF THE SELECTED RESPONSE MEASURE

The selected response measure is the final action for addressingthe soil contamination at the site. Additional actions will benecessary to investigate the extent of groundwater and surfacewater contamination remaining at the site. The major componentsof the selected response measure include:

• Excavation and transportation to an off-site disposalfacility of approximately 13,100 cubic yards ofcontaminated soils determined to be above 0.34 parts permillion (ppm) of aldrin, 0.36 ppm of dieldrin, or 17.0ppm of 4,4'-DDT;

• Disposal of the excavated soils that are below the

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treatment level of 1,000 ppm of chlorinated pesticides,and are not hazardous waste pursuant to the ResourceConservation and Recovery Act (RCRA), at an appropriateoff-site landfill;'

• Treatment, by off-site thermal desorption, of allcontaminated soil above the 1,000 ppm treatment level,that is determined to be treatable by thermal desorption(any contaminated soil above the treatment level thatcannot be treated by thermal desorption, and any soilsthat are deemed RCRA hazardous waste, will be sent to anoff-site permitted incinerator for treatment); and

• Backfilling of the excavated areas with clean fill froman off-site location, covering these areas with topsoil,and seeding.

The preferred remedy would allow for future commercial use of thesite. This response measure contemplates institutional controls,such as a deed restriction, to ensure that the future land useremains commercial.

DECLARATION OF STATUTORY DETERMINATIONS

The selected response measure meets the requirements set forth inCERCLA §121 in that it: (1) is protective of human health andthe environment; (2) complies with federal and state requirements

. that are legally applicable or relevant and appropriate; (3) is* cost-effective; (4) utilizes alternative treatment (or resource

recovery) technologies to the maximum extent practicable; and (5)satisfies the statutory preference for remedies that employtreatment to reduce the toxicity, mobility, or volume of thehazardous substances, pollutants or contaminants"at the site.

Because this remedy will result in hazardous substances remainingon the site above levels that will not allow for unrestricteduse, a review will be conducted within five years after thecommencement of this response measure to ensure that it continuesto provide adequate protection of human health and theenvironment.

Jeanne M. Fox, R^ifofunr^dministrator ' DateU.S. Environmental Pr^fe^ction AgencyRegion II /

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DECISION DOCUMENTDecision Summary


Moorestown, Burlington County, New Jersey

United States Environmental Protection AgencyRegion II

New York, New YorkJuly 1999

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TABLE OF CONTENTSPAGE

SITE NAME, LOCATION AND DESCRIPTION ' 1

SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . 1

HIGHLIGHTS OF COMMUNITY PARTICIPATION . . 4

SCOPE AND ROLE OF. OPERABLE UNIT 5

SITE CHARACTERISTICS 5

SUMMARY. OF SITE RISKS . . • 8

RESPONSE MEASURE OBJECTIVES - . - . . . . 14

DESCRIPTION OF ALTERNATIVES '. • 14

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . 21

SELECTED REMEDY 32

STATUTORY DETERMINATIONS 33

APPENDICES

APPENDIX I FIGURESAPPENDIX II TABLESAPPENDIX III ADMINISTRATIVE RECORD INDEXAPPENDIX IV RESPONSIVENESS SUMMARY

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SITE NAME. LOCATION AND DESCRIPTION

The Pulverizing Services site-is located on approximately 24acres in an industrial park at 332 New Albany Road in Moorestqwn,Burlington County, New Jersey. The site is located 3/4-mile eastof the North Branch of the Pennsauken Creek and 3/4-mile west ofan unnamed creek. Land use in the vicinity of the site consistsof commercial, light industrial, and residential areas.

The site is bounded to the northwest by Crider Avenue, acrosswhich is located a manufacturing facility. Railroad tracks andseveral residences are located southeast of the site.Residential, commercial, and industrial properties are locatedsouthwest of the site. Northeast of the site are commercial andindustrial facilities. A site location map is presented asFigure 1.

Based on land use and location, the entire site has beensubdivided into three areas referred to as areas A, B, and C.New Albany Road, a major roadway, separates Area B from Areas Aand C. Area A, > the former main processing area including thetrench area, contains most of the contamination. Area B containsa two-story house and a garage that were used as an office and aquality control lab, respectively. A railroad spur originates inArea A and runs along the north-eastern side of Area B; theremaining portion of Area B and all of Area C have been leftunused since the time that these properties were farmland. Thesoutheastern portion of Area B, adjacent to the railroad tracks,contains wetlands which drain to the west along the tracks intothe Pennsauken River. No private wells are found within aquarter mile of the site, and no public wells are within a mile.No federal or state listed, proposed, threatened, or endangeredspecies were found at the site. A site layout map is presentedas Figure 2.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The site is an inactive pesticide formulating facility. Asummary of site ownership is presented below:

• 1935 to 1946 - The plant was operated by theInternational Pulverizing Company

• 1946 to 1948 - The plant was owned and operated byMicronizer Company, a subsidiary of Freeport SulfurCompany

• 1948 to 1963 - The plant was owned and operated by PPGIndustries, Inc.

• 1963 to 1979 - The plant was owned and operated by

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Pulverizing Services, Inc., until plant operations ceasedin 1979

• 1979 to Present - The plant remains inactive andunoccupied

During the operating period of the plant, operations wereprimarily limited to Area A and involved the grinding,micronizing, and blending of pesticides. According to historicalreports, operations were initially limited to formulation ofinorganic pesticides such as lead arsenate, calcium arsenate,sulfur, and tetrasodium pyrbphosphate. In later years, syntheticorganic pesticides such as dichlorodiphenyltrichloroethene (DDT),aldrin, malathion, dieldrin, lindane, rotenone, and n-methylcarbamate (Sevin or Carbaryl) were reportedly formulated. Theactive pesticide ingredients were not'manufactured at the site,but were imported to the site then ground, blended, and packagedfor distribution under various labels.

Historical records of Pulverizing Services, Inc., indicated thatsince 1935, only dry chemical processing was conducted at thesite. Formulating activities included the grinding (using fluidenergy such as compressed air), densifying, packaging,warehousing, and distributing of products to support industriessuch as plastics, Pharmaceuticals, and pesticides.

During the 1950s and early 1960s, waste material was reportedlydisposed of in several trenches north of the main productionbuildings. In addition, historical project files indicate thatash and debris from a 1964 fire was reportedly placed in a trenchnorth of the main production buildings in Area A.

In 197.9, commercial operations at the plant ceased. In 1983, the'former plant production facilities within Area A weredecommissioned (by removing some interior facilities) and boardedshut. The building structures of the production facilitiesremain at the site.

On June 12, 1985, in response to allegations of improper wastedisposal, the New Jersey Department of Environmental Protection(NJDEP) performed a site inspection. This inspection revealedthat waste material (drummed and loose) remained on site, in andaround the buildings, and also appeared to be buried at the northend of Area A. In April 1986, NJDEP sampled Area A anddetermined that the trench area was contaminated with pesticides(DDT and its decomposition products, DDD and DDE).

In October 1987, after a request by NJDEP to take the lead forthe site, the EPA Technical Assistance Team conducted aninvestigation at the site. Samples were collected from soil,

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sediment, surface water, former plant structures and air. Thisinvestigation confirmed the findings of the NJDEP investigationand further determined that the contamination was not limited tothe trench areas, but could also be found in Areas B and C. InDecember 1981, the EPA Environmental 'Response Team conducted aninvestigation at the site. A ground penetrating radar survey wasused to identify several subsurface anomalies in Area A. Sampleswere also taken of surface and subsurface soils within Areas A,B, and C. In addition to DDT, ODD, and DDE, arsenic was alsodetected in on-site soils. After voluntarily entering into anorder with EPA in May 1988, PPG Industries (PPG), a formerowner/operator of the facility, installed security fencing aroundAreas A and C. These areas were chosen to be fenced because theycontained the main processing area and could serve as a stagingarea for future cleanup work.

In 1989, EPA entered into negotiations with the PotentiallyResponsible Parties (PRPs) for the site. PPG agreed to performthe necessary investigations at the site with the remaining PRPsagreeing to perform a removal action to clean up the material inand around the buildings. The other PRPs were companies thatsent pesticides to the site to be formulated, retaining ownershipof the pesticides throughout the process, and the current ownerof the site.

The Phase I Site Investigation was conducted from December 1989to January 1990, by Paul C. Rizzo Associates, Inc., undercontract with PPG. During the investigation, 20 soil boringswere completed, and six monitoring wells were installed withinArea A. Several soil samples (both surface and subsurface) werecollected from each boring. In addition, four surface soilsamples were collected from the vicinity of the garage in Area B,and one sediment sample was collected from the drainage ditchnorthwest of Area A. Samples were analyzed for volatile organiccompounds (VOCs), semi-voltatile organic compounds (SVOCs),pesticides, and herbicides. A magnetometer and electricconductivity survey were also performed in Area C. A draftreport was submitted to EPA on May 25, 1990.

In September 1990, the building cleanup began under the directionof EPA. As part of this cleanup, approximately 600 drums and 580cubic yards of waste materials were shipped off-site. Theinteriors of the buildings were then power washed and secured.

The Phase I Site Investigation Report was revised and resubmittedin April 1993. In addition, the discovery of contaminated soilin Area B prompted PPG to install security fencing around Area Bin the Spring of 1993.

Results of the previous EPA and NJDEP sampling events and the

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Phase I Site Investigation were used to focus the Phase IIsampling activities. The Phase II Site Investigation wasperformed between October 1994 and May 1995. The goal of theinvestigation was to further characterize the nature and extentof contamination on and in the immediate vicinity of the site,gather data to support the development of Preliminary RemediationGoals (Cleanup Goals) and provide the necessary data to preparethe Response Measures Evaluation Report (RME). The RMEidentified viable cleanup technologies for the contaminants ofconcern and evaluated the most appropriate cleanup alternativefor the site. The Phase II Site Investigation Report and the RMEwere finalized in November 1995 and December 1997, respectively.

In the Spring and Fall of 1996, two removal actions wereperformed to remove contaminated surface soils from two adjacentproperties that were identified during the Phase IIinvestigation. Soils removed during these activities were stagedon site in Building 29 for subsequent disposal.

In December 1998, a third removal action was performed, to removeapproximately 3,460 cubic yards of contaminated surface soil froman adjacent property.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The investigation reports, Response Measure Evaluation Report,Proposed Plan and supporting documentation were made available tothe public in the administrative record file at the SuperfundDocument Center in EPA Region II, 290 Broadway, New York, NewYork, and the information repository at the Burlington CountyLibrary, 5 Pioneer Boulevard, Westampton, New Jersey. The noticeof availability for the above-referenced documents was publishedin the Burlington County Times on January 17,1999. The publiccomment period which related to these documents was held fromJanuary 19, 1999 to February 19, 1999.

On January 27, 1999, EPA conducted a public meeting in the courtroom at 11 West Street in Moorestown, New Jersey. The purpose ofthe meeting was to inform local officials and interested citizensabout the Superfund process, present the conclusions of the siteInvestigation, elaborate further on the recommended and preferredremedial response measure, receive public comments, and respondto questions from area residents and other interested parties.Responses to the comments received at the public meeting and inwriting during the public comment period are included in theResponsiveness Summary of this Decision Document.

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SCOPE AND ROLE OF OPERABLE UNIT

This action is the first operable unit or phase taken to addressthe site. This action will address contaminated soil within thePulverizing Services property boundaries. The second operableunit will address groundwater, surface water, and sediment.

SITE CHARACTERISTICS

Phase I Investigation Summary

The Phase I Site Investigation primarily focused on thecollection of samples from soil borings, sediments, andgroundwater in Area A. A limited investigation was performed inArea B, which included the installation of one boring and thecollection of four surface soil samples. Since this operableunit only addresses the contaminated site soils, the followingsummary will only provide the findings of the surface andsubsurface soil portions of the Phase I Site Investigation.

Area A SoilsSoil samples were collected from 19 borings in Area A.Surface soil samples were obtained from the 0-2 footinterval. Subsurface soils were obtained from the 5 to 7foot and the 10 to'12 foot interval. The samples wereanalyzed for inorganics, VOCs, SVOCs, and pesticides.

Analysis of the soil boring samples revealed that inorganicswere detected at concentrations within expected backgroundranges. The concentrations of lead and arsenic variedbetween 2.4 and 22.9 parts per million (ppm) and <1.0 and 17ppm, respectively. Volatile and semi-volatile organiccompounds were detected in low concentrations atintermittent locations in the surface and subsurface.

Surface Soil Pesticide ResultsSix shallow soil boring samples were submitted forlaboratory analysis. Measurable levels of dieldrin andcombined DDD, DDE, and DDT concentrations within thosesamples ranged from 0.25 to 270 ppm and 0.04 to 4.1 ppm,respectively. Aldrin was not detected in the shallow boringsamples. Borings located near the northeastern perimeterfence and Building 29 contained the greatest concentrationsof pesticides.

Subsurface Soil Pesticide ResultsThirty-eight subsurface samples were submitted forlaboratory analysis. Dieldrin and combined DDD, DDE, andDDT concentrations within those samples ranged from 0.019 to63.9 ppm and 0.030 to 470 ppm, respectively. Aldrin was

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detected in the 5-7 foot interval only, at concentrationsranging from 0.022 to 6.9 ppm. Constituents detected in thesubsurface soil boring samples were primarily located .within

6 the area of the former disposal trench.

Area B SoilsSurface Soil ResultsFour surface soil samples were collected from Area B in thevicinity of the garage. DDT was detected at levels ranginafrom 2.71 to 27,200 ppm.

Subsurface Soil ResultsTwo subsurface soil samples were collected from one soilboring in Area B. Dieldrin and combined ODD, DDE, and DDTconcentrations were reported as non-detect (ND) and 0.227 to2.92 ppm, respectively. Aldrin was not detected in thesamples.

Phase II Site Investigation Summary

The Phase II Site Investigation revealed that pesticides (mostlyDDT, DDT breakdown products and some dieldrin) were foundthroughout the site. The highest concentrations of pesticideswere within the vicinity of the former disposal trench, along thenortheast perimeter fence, and in Area A. The report alsoindicated that inorganics were present in soils within Area A,but only in the areas where elevated levels of pesticide

• contaminants were detected. Detectable concentrations of SVOCswere primarily restricted to three boring locations in Area A.Volatile organic compounds were only detected at lowconcentrations. The following summaries provide further detailof the constituents detected in Areas A, B, and C at the site.

Area ASurface Soil ResultsAreas of surface soil contamination in Area A are locatedwithin the former disposal trench and along the northeasternperimeter fence. Dieldrin and 4,4-DDT were present at theselocations in concentrations ranging from 0.750 to 2,200 ppmand 2.5 to 6,800 ppm, respectively. Sampling locationswithin or near the former disposal trench contained thegreatest contaminant concentrations.

Arsenic, lead, and chromium concentrations ranged from 2.2to 132.0 ppm, 17.6 to 480.5 ppm, and-5.3 to 96,5 ppm,respectively. These metals were primarily found withinisolated surface soil sampling locations within or near theformer disposal trench, and near the southwestern perimeterfence.

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Subsurface Soil ResultsPesticide-containing subsurface- soils in Area A areprimarily located within the former disposal trench, inareas immediately east of the disposal trench near Building29, and near the drainage ditch outfall pipe.Concentrations of dieldrin and DDT range from 0.022 to 63.9ppm and 0.030 to 442.0 ppm, respectively. Arsenic, lead,and chromium concentrations ranged from 3.1 to 24.8 ppm, 2.4to 124 ppm, and 4.0 to 47.0 ppm, respectively.

Area BSurface Soil ResultsDDT was detected in Area B surface soils at concentrationsranging from 0.190 to 280 ppm. Contamination primarilyappears to be limited to areas immediately surrounding soilborings SB-54 and SB-19, located approximately'250 feetsoutheast of New Albany Road, and within the debris areanear the eastern corner of the region. Inorganics in Area Bsurface soils were detected within background levels.

Elevated levels of SVOCs in Area B surface soils weredetected in one boring installed adjacent to the railroadtracks.

Subsurface Soil ResultsOnly low concentrations of pesticides were detected in thesubsurface soils within Area B. Combined ODD, DDE, and DDTconcentrations in samples below the surface soil "hot spots"located southeast of New Albany Road were less than 2 ppm.1

Combined DDD, DDE, and DDT concentrations up to 65 ppm weredetected in the subsurface soils of the debris area locatedin the eastern corner of the region.

Area CSurface Soil ResultsData from surface samples collected within Area C do notindicate the presence of pesticides at elevatedconcentrations. DDT was detected at concentrations rangingfrom 0.022 to 3.8 ppm.

Data indicates the presence of arsenic at levels rangingfrom non-detect(ND) to 88 ppm.

a"Hot spots" for this site were determined to be all soilsabove 1,000 ppm total chlorinated pesticides (treatment level).

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SUMMARY OF SITE RISKS

, Based upon the results of the RI, a baseline risk assessment wasv conducted to estimate the risks associated with current and

future site conditions. The baseline risk assessment estimatesthe human, health and ecological risk which could result from thecontamination at the site if no response measure were taken.

Human Health Risk Assessment

To perform a Human Health Risk Assessment, a reasonable maximumhuman exposure is evaluated. The following four-step process isthen utilized for assessing site-related human health risks for areasonable maximum exposure scenario:

1. Hazard Identification — identifies the chemicals ofpotential concern at the site based on several factors suchas toxicity, frequency of occurrence, and concentration.

2. Exposure Assessment — estimates the magnitude of iactualand/or potential human exposures, the frequency and durationof these exposures, and the pathways (e.g., ingestingcontaminated well-water) by which humans are potentiallyexposed.

3. Toxicity Assessment -- determines the types of adverse^ health effects associated with chemical exposures, and the

relationship between magnitude of exposure (dose) andseverity of adverse effects (response).

4. Risk Characterization -- summarizes and combines outputsof the exposure and toxicity assessments to provide aquantitative (e.g., one-in-a-million excess cancer risk)assessment of site-related risks.

The baseline risk assessment began with selecting chemicals ofpotential concern which would be representative of thecontamination found in various media (surface soil, subsurfacesoil, surface water, sediment, and groundwater) at the site.This Operable Unit only addresses the surface and subsurfacesoil; therefore, only contaminants present in said media wereaddressed. Because of the large number of chemicals detected atthe site, only those chemicals which pose the highest risk (basedon factors such as .frequency of detection and 'concentrationdetected) were retained as chemicals of potential concern. Table1 provides a comprehensive list of the chemicals of potentialconcern in the surface and subsurface and the concentrations atwhich they were detected.

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Several of the contaminants of concern- are known or suspectedcarcinogens: arsenic, beryllium, benzo(a)pyrene, aldrin,dieldrin, DDT, DDD, and DDE.

An important factor which drives the risk assessment is theassumed future use of the site. Based on discussions withMoorestown Officials and the fact that the site is currentlyzoned for commercial and light industrial use, EPA assumed thatthe most probable future use of the site would be for continuedcommercial and industrial development. Under the current landuse of the property, the site contaminants have the potential toimpact Trespassers. In the future, it is possible that potentialhuman receptors would include Trespassers, Site Workers(employees of a potential future company located on site, thatwould have limited exposure to surface soils over long periods oftime), and Construction Workers (a person such as a utilityworker that may have a short duration exposure to larger amountsof surface soil as well as subsurface soils). This Operable Unitfocuses on surface and subsurface soil pathways.

Pathways of exposure evaluated for the site include thefollowing:

1) sediment and soil ingestion;2) dermal contact with soil and sediment;3) ingestion -of contaminated groundwater and surface

water;4) dermal- contact with surface water; and5) inhalation of VOCs and particulates.

Because EPA assumed a future commercial and industrial land useof the site, the list of possible human receptors identified inthe exposure assessment included Trespassers, Site Workers, andConstruction Workers. Chronic daily intake doses (CDIs) werecalculated for each receptor for all pathways considered. TheGDI is the reasonable maximum daily exposure to a particularchemical based on site conditions.

Potential carcinogenic risks were evaluated using the cancerslope factors developed by EPA for the contaminants of concern.Slope factors have been developed by EPA's Carcinogenic RiskAssessment Verification Endeavor for estimating excess lifetimecancer risks associated-with exposure to potentially carcinogenicchemicals. Slope factors, which are expressed in units of(mg/kg-day) "1, were multiplied by the estimated chronic dailyintake of a potential carcinogen, in mg/kg-day, to generate an"upper-bound" estimate of the excess lifetime cancer risk

2Contaminants .of concern are listed in bold type on Table 1.

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associated with exposure to the compound at that intake level.The term "upper-bound" reflects a conservative estimate of therisks calculated from the Slope Factor. Use of this approach

\_ makes underestimation of the actual cancer risk highly unlikely.A mathematical representation for calculating the excess lifetimecancer risk is as follows:

Risk = CDI x Sfwhere:

Risk = probability (e.g., 2 x 10'5) of an individualdeveloping cancer; "upper-bound"

CDI = chronic daily intake averaged over 70 years (mg/kg-day)

Sf = slope-factor, expressed as (mg/kg-day) ~:

These risks are probabilities that are generally expressed inscientific notation. EPA's acceptable cancer risk range is 10"4

to 10 "6 which can be interpreted to mean that an individual mayhave a 1 in 10,000 to 1 in 1,000,000 increased chance ofdeveloping cancer as a result of site-related exposure to acarcinogen over a 70-year lifetime under the specific exposureconditions at the site. The state of New Jersey's acceptablerisk standard is one in one million (10 ~6) .

EPA found the levels of contaminants found in some.of the surfacesoil samples in Area A at the site posed an unacceptable totalcancer risk to Trespassers and future Site Workers through

* '' ingestion and inhalation. Dieldrin, DDT and aldrin are thepredominant contributors to the estimated cancer risk. The otherreceptors/exposure routes have estimated cancer risks within orbelow EPA's acceptable risk range. A complete list of thecombined carcinogenic risks associated with each pathway can befound in Table 2.

Non-carcinogenic risks were assessed using a hazard index (HI)approach, based on a comparison of expected contaminant intakesand safe levels of intake (Reference Doses). Reference Doses(RfDs) have been developed by EPA for indicating the potentialfor adverse health effects. RfDs, which are expressed in units ofmilligrams per kilogram per day (mg/kg-day), are estimates oflifetime daily exposure levels for humans, including sensitiveindividuals. Estimated intakes of chemicals from environmentalmedia (e.g., the amount of a chemical ingested from contaminateddrinking water) are compared to the RfD to derive the hazardquotient (HQ) for the contaminant in the particular medium. TheHQ represents the ratio of exposure to toxicity. By adding thehazard quotients for all compounds within a particular mediumthat impact a particular receptor population the HI is obtained.An HI greater than 1.0 indicates that the potential exists fornon-carcinogenic health effects to occur as a result of site-

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related exposures. The HI provides a useful reference point forgauging'the potential significance of multiple contaminant'exposures within a single medium or across media. A mathematicalrepresentation of the hazard index approach follows:

HI = £ HQHQ = GDI / RfD

where:HI = Hazard Index; HI > 1.0 potential for non-carcinogenichealth effects to occur£ = Sum of sign GDI = Chronic Daily IntakeRfD = Reference Dose

GDI and RfD are expressed in the same units and represent thesame exposure period

With regard to non-carcinogenic effects,- based on the calculatedHis, EPA found that several potential exposure pathways couldhave unacceptable health effects including: .

• Ingestion of Area A surface soil by Trespassers(HI=23)

• Ingestion of Area A surface soil by Site Workers(HI=29)

• Ingestion of Area A subsurface soils byConstruction Workers (HI=1.3)

• Ingestion of Area B subsurface soils byConstruction Workers (HI=3.0)

The calculated His for the combined non-carcinogenic riskassociated with each pathway is provided in Table 3.

In summary, the Human Health Risk Assessment concluded thatexposure to surface soil and subsurface soils, if not addressedby the response measure selected in this Decision Document, maypresent a current or potential threat to public health.

The assessment determined the Cleanup Goals based on the 10'6

Site Worker exposure, and the 10"6 Construction Worker exposure,should be the following:

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Soil Cleanup Goals

Parameter

Aldrin

Dieldrin

4, 4 '-DDT

SiteWorker

0.34ppm

0.36ppm

17.0ppm

Construction

Worker

3.3' ppm

3 . 5 ppm

165.0 ppm

Although the Site Trespasser scenario did pose a risk, a CleanupGoal based on the Site Worker was more conservative. Therefore,the Site Worker Cleanup Goal was used. EPA estimates thatapproximately 13,100 tons of soil exceed the Site Worker cleanupgoal, and 4,300 tons exceed the Construction Worker Cleanup Goal.A total of 8,800 tons of contaminated soil, fall between the SiteWorker and Construction Worker Cleanup Goals.

Ecological Risk Assessment

The Ecological Risk Assessment involves a qualitative and/orsemi-quantitative appraisal- of the actual or potential effects ofa hazardous waste site on plants and animals. A four-stepprocess is utilized for assessing site-related ecological risks:

1. Problem Formulation - a qualitative evaluation ofcontaminant release, migration, and fate; identificationof contaminants of concern, receptors, exposure pathways,.and known ecological effects of the contaminants; andselection of endpoints for further study

2. Exposure Assessment - a quantitative evaluation of con-taminant release, migration, and fate; characterizationof exposure pathways and receptors; and measurement orestimation of exposure point concentrations

3. Ecological Effects Assessment - literature reviews,field studies, and toxicity tests, linking contaminantconcentrations to effects on ecological receptors

4. Risk Characterization - measurement or estimation ofboth current and future adverse effects

The RI Report identified several pesticides and metals in surfacesoils at the site. The qualitative .ecological risk assessment

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began with the identification of flora and fauna that couldpotentially come into contact with the contaminants in the soil.No federal or state listed, proposed, threatened or endangeredflora or fauna are known to occur at or near, the site; however,evidence of small mammals and terrestrial receptors such asrabbits and birds were observed. Potential exposure pathwaysthat exist for these terrestrial receptors are ingestion,inhalation, and dermal contact with the contaminants.

A conservative food chain exposure model was conducted todetermine if the Preliminary Remediation Goal for 4-4'-DDT wouldbe protective of the ecological receptors. The results of thismodel indicated that there may be potential risks to ecologicalreceptors associated with exposure to this pesticide. However,the potential risks would be minimal, based on the site-specificcharacteristics such as the small size of the site, the fact thatthe property is expected to remain zoned as commercial, the lackof sensitive populations, and the potential for furtherdevelopment and increased human activity (which may furtherreduce the amount of habitat on the site). Furthermore, 'theproposed remediation of soils to human health-based Cleanup Goalswould decrease the amount of soil containing contaminantconcentrations that would pose a risk to ecological receptors.

Uncertainties

The procedures and estimates used to assess risks, as in all suchassessments, are subject to a wide variety of uncertainties. Ingeneral, the main sources of uncertainty include:

. • environmental chemistry sampling and analysis;• matrix characteristics;• exposure parameter estimation; and• toxicological data.

Uncertainty in environmental sampling arises in part from thepotentially uneven distribution of chemicals in the mediasampled. Consequently, there is significant uncertainty as tothe actual levels present. Environmental chemistry analysiserror can stem from several sources, including the errorsinherent in the analytical methods and characteristics of thematrix being sampled.

Uncertainties in the exposure assessment are related to estimatesof how often an individual would actually come in contact withthe chemicals of concern, the period of time over which suchexposure would occur, and in the models used to estimate theconcentrations of the chemicals of concern at the point, ofexposure. Uncertainties in toxicological data occur inextrapolating both from animals to humans and from high to low

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doses of exposure, as well as from the difficulties in assessingthe toxicity of a mixture of chemicals. These uncertainties are

, addressed by making conservative assumptions concerning risk andv_ exposure parameters throughout the assessment. As a result, the

baseline risk assessment provides "upper-bound" estimates of therisks to populations near the site, and it is highly unlikely tounderestimate actual risks related to the site.

More specific information concerning public health risks,including a quantitative evaluation of the degree of riskassociated with various exposure pathways, is presented in the RIreport.

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response actionselected in this Decision Document, may present an imminent andsubstantial endangerment to public health, welfare, or theenvironment.

RESPONSE MEASURE OBJECTIVES

Response measure objectives are specific goals to protect humanhealth and the environment. These objectives are based onavailable information and standards such as applicable orrelevant and appropriate requirements (ARARs) and risk-basedlevels established in the Risk Assessment.

The following objectives were established for the site:

e Mitigate potential routes of human health andenvironmental exposure to contaminated soils;

8 Restore the soil at the site to levels which would allowfor commercial reuse of the property;

e Treat and/or dispose of soils excavated from off-site. properties, and stockpiled in Building 29;

8 Remediate all on site soils above the Site Worker Cleanup: Goals provided by the Risk Assessment;

e Treat soils above 1,000 ppm total chlorinated pesticides(treatment level). The estimated volume of affected soil'above 1,000 ppm is between 1,300 and 4,000 tons; and

e Comply with ARARs, or provide grounds for invoking awaiver.

DESCRIPTION OF ALTERNATIVES

CERCLA 512Kb) (l)f 42 U.S.C. §9621(b)(l) mandates that a remedialaction must be protective of human health and the environment,cost-effective, and utilize permanent solutions and alternativetreatment technologies or resource recovery technologies to themaximum extent practicable. Section 121(b)(l) also establishes a

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preference for remedial actions which employ, as a principalelement, treatment which permanently and significantly reducesthe volume, toxicity, or mobility of the hazardous substances,pollutants and contaminants at a site. CERCLA §121(d), 42 U.S.C.§9621(d), further specifies that a remedial actions must attaina level or standard of control of the hazardous substances,pollutants, and contaminants, which at least attains ARARs underfederal and state laws, unless a waiver can be justified pursuantto CERCLA §121(d) (4),42 U.S.C. §9621(d) (4). While the responsemeasure selected in this document falls within the category ofremoval action, it is the permanent remedy selected for the soilsat the site. As such, it.is appropriate to apply the criterialisted in CERCLA Section 121 to the response measure."

EPA's RME evaluated, in detail, eight response measures foraddressing soil contamination at the site. Cost and constructiontime, among other criteria, were evaluated for each responsemeasure. The time to implement a response measure reflects theestimated time required to construct the remedy. The estimatesdo not include the time, to negotiate with the PotentiallyResponsible Parties, prepare design documents, or procurecontracts. Because each response measure is based on a futureindustrial/commercial land use of the site, each would requireinstitutional controls (i.e., deed restrictions or zoningrestrictions) to restrict non-commercial uses of the site, and,in some cases, to protect waste caps from being breached. Inaddition, all alternatives' considered would require five yearreviews. When estimating capital costs and total present worthvalue, a range is reported since the actual cost is dependent onthe relative amount of high and low concentration wastes. Theeight response measures evaluated are as follows:

Response Measure 1: No Further Action

Estimated Capital Costs: $ 0Estimated O&M Costs (30 years): $ 0Estimated Total Present Worth Value: $ 0Estimated Implementation Period: No implementation

necessary

The Superfund Program requires that the "No-Action" responsemeasure be considered as a baseline for comparison of othersoil response measures. Under this response measure, EPAwould take no action at the site.

Response Measure 2: Selective Excavation, Consolidation, andCapping

Estimated Capital Cost: $ 1,339,000Estimated O&M Costs (30 years): $ 184,000

• "-15-

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Estimated Total Present Worth Value: $ 1,523,000Estimated Implementation Period: 8 months*This estimate is for the soil/membrane cap, an additional$250,000 is estimated for the asphalt cap

Under Response Measure 2, all site soils and former disposaltrench materials containing contaminant concentrations inexcess of the Site Worker Cleanup Goals would be excavated.Excavated soil that is in excess of the Construction WorkerCleanup Goals would be consolidated within part of thetrench area along with any materials determined to be ahazardous waste. These materials would be covered with aResource Conservation and Recovery Act (RCRA) quality cap.The remaining soils containing concentrations in excess ofthe Site Worker Cleanup Goals, and have levels ofcontamination below the Construction Worker Cleanup Goals,would also be consolidated within the trench area. Thisportion of the trench would then be covered using a soilcover with an impermeable geomembrane, or an asphalt cap, tobe determined during design. A cap would reduce thepotential for direct contact with contaminated media andminimize infiltration of storm water into the underlyingsoils. Excavated areas would then be backfilled with cleanfill. Operation and maintenance (O&M) would include bi-monthly inspections, mowing and watering, regrading and

' revegatation.

Response Measure 3A: Excavation; On-Site Ex-situ AnaerobicBiotreatment; Off-Site Landfilling/Incineration

Estimated Capital Costs: $ 3,024,000 toi $ 5,113,000

Estimated O&M Costs (30 years): $ 22,000Estimated Total Present Worth Value: $ 3,046,000 to

$ 5,135,000Estimated Implementation Period: 34 months

Under Response Measure 3A, all site soils and formerdisposal trench materials that contain concentrations of thechemicals of concern in excess of the Site Worker Cleanup

; Goals would be excavated. Excavated soils that aredetermined to be non-RCRA hazardous and have levels ofcontamination below the 1,000 ppm treatment level, would besent to an off-site landfill. The remaining soil would betested to determine which soils are treatable withbioremediation. Treatable soils would be treated on-site,

: and the remaining soils would be treated at a permitted off-site incinerator. Soils treated on-site would be backfilled

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into the previously excavated areas. A bench-scaletreatability study and a pilot-scale field test would be

. required to determine whether, biotreatment will reduce thelevel of contaminants in site soils to below the Site WorkerCleanup Goals. The off-site incinerator would also providea contingency measure in the event that the biotreatmentprocess proves ineffective. Excavated areas would then bebackfilled with clean fill.

Response Measure 3B: Excavation; On-site Ex-situ AnaerobicBiotreatment; Off-site Landfilling/Incineration and Capping

Estimated Capital Costs: $ 2,414,000 to$ 4,177,000

Estimated O&M Costs (30 years): $ 236,000*Estimated Total Present Worth Value: $ 2,650,000 to

$ 4,414,000Estimated Implementation Period: . 36 months*This estimate is for the soil/membrane cap, an additional$250,000 is estimated for the asphalt cap

Under Response Measure 3B, all site soils and formerdisposal trench materials containing contaminants greaterthan the Site Worker Cleanup Goals would be excavated.Excavated soil which is determined to be non-RCRA hazardous,and contains contaminants at levels less than theConstruction Worker Cleanup Goals, would be consolidatedwithin the excavated former disposal trench area and coveredwith either a soil and impermeable membrane cap or asphaltcap,' to be determined during design. Excavated soils andtrench materials that are determined to be treatable withbiotreatment and contain concentrations of the chemical's ofconcern in excess of the Construction Worker Cleanup Goalsor are determined to be non-RCRA hazardous would be treatedby on-site anaerobic bioremediation. The remainder of thesehigher level wastes which cannot be bioremediated would besent to a permitted off-site incinerator. Soils and mediatreated via bioremediation would be backfilled into thepreviously excavated areas. A bench-scale treatabilitystudy and a pilot-scale field test would be required todetermine whether biotreatment will reduce the level ofcontaminants in site soils to below the Site Worker CleanupGoals. The off-site incinerator would also provide acontingency measure in the event that the treatment processproves ineffective. Since the Construction Worker CleanupGoals are lower than the New Jersey Impact to GroundwaterCleanup Criteria, backfilling and capping of soils that .exhibit.contaminant concentrations less than the

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\

Construction Worker Cleanup Goals would help to ensuregroundwater is protected in the event of a breach in thecap. The unfilled portions of the excavated areas wouldthen be backfilled with clean fill. O&M would include bi-monthly inspections, mowing and watering, regrading andrevegatation.

Response Measure 4A: Excavation; Off -site Low-TemperatureThermal Desorption; Off -site Landfilling/Incineration



; $ 4,701,000Estimated Implementation Period: 8 months

Under Response Measure 4A, all site soils and formerdisposal trench materials that contain concentrations of thechemicals of concern in excess of the Site Worker CleanupGoals would be excavated. Excavated soils that aredetermined to contain levels of contaminants less than the1,000 ppm treatment level and are not RCRA hazardous waste,would be sent to an off-site landfill. Excavated soils thatare determined to be non-RCRA hazardous and morecontaminated than the 1,000 ppm treatment level, but remainless contaminated than the treatment ceilings for the lowtemperature thermal desorption (LTTD) facilities, would besent off-site for LTTD treatment. The remaining soils,those containing levels of contaminants above the 1,000 ppmtreatment level and the LTTD ceiling and/or deemed RCRAhazardous wastes, would be sent to a RCRA permitted off-siteincinerator. Following treatment at the LTTD facility,soils may be transported back to the site for use asbackfill providing the contaminant levels in the treatedsoils are less than the Site Worker Cleanup Goals and thereare no aesthetic problems (i.e., odor, unwanted debrisetc.). This response measure would require pilot-scaletreatability studies at selected off-site LTTD facilities todetermine if LTTD will reduce the level of contaminants insite soils to below the Site Worker Cleanup Goals. The off-site incinerator would also provide a contingency measureshould the LTTD technology prove to be limited ineffectiveness. Excavated areas would then be backfilledwith clean. fill.

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Response Measure 4B: Excavation; Off-site Low-Temperaturei Thermal Desorption; Off-site Landfilling and Incineration of

Soils In Excess of the Construction Worker Cleanup Goals;Consolidation and Capping of Remaining On-site Soils Greater ThanThe Site Worker Cleanup Goals



$ 4,066,000Estimated Implementation Period: 10 months*This estimate is for the soil/membrane cap, an additional$250,000 is estimated for the asphalt cap

Under Response Measure 4B, all site soils and formerdisposal trench materials that contain concentrations of thechemicals of concern in excess of the Site Worker CleanupGoals would be excavated. Excavated soils that aredetermined to be non-RCRA hazardous and contain contaminantsless than the Construction Worker Cleanup Goals would beconsolidated within the former trench area and covered witheither an asphalt cap or a soil and impermeable membranecap. Excavated soils that are determined to be non-RCRA.hazardous and contain contaminants greater than the

\ Consrruction Worker Cleanup Goals, but remain below- 1,000ppm treatment level, would be sent to an off-site landfill.Excavated soils that are determined to be non-RCRAhazardous, and contain contaminants greater than 1,000 ppmtreatment level, but remain below the treatment ceiling ofthe LTTD facility, would be sent off-site for LTTDtreatment. The remaining soils, those containing levels ofcontaminants above the 1,000 ppm treatment level and theLTTD ceiling and/or deemed RCRA hazardous wastes, would besent to a RCRA permitted off-site incinerator. Followingtreatment at the LTTD facility, soils may be transportedback to the site for use as backfill providing thecontaminant levels in the treated soils are less than theSite Worker Cleanup Goals and there are no aestheticproblems (i.e., odor, unwanted debris etc.). Thisalternative would require pilot-scale treatability studiesat selected off-site LTTD facilities to determine if LTTDwill reduce the level of contaminants in site soils to belowthe Site Worker Cleanup Goals. The off-site incineratorwould also provide a contingency measure should the LTTDtechnology prove to be limited in effectiveness. Since theConstruction Worker Cleanup Goals are lower than the NewJersey Impact to Groundwater Cleanup Criteria, backfilling

( • -19-

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and capping o.f only soils that exhibit contaminantconcentrations less than the Construction Worker CleanupGoals would help to ensure groundwater is protected in theevent of a breach in the cap. The remaining unfilledportions of the excavated areas would then be backfilledwith clean fill. O&M would include bi-monthly inspections,mowing and watering, regrading and revegatation.

Response Measure 5A: Excavation; Off-site Incineration; Off-siteLandfilling

Estimated Capital Costs: - $ 2,811,000 to$ 5,251,000


$ 5,273,000Estimated Implementation Period: 6 months

Under Response Measure 5A, all site soils and formerdisposal trench.materials that contain concentrations of thechemicals of concern in excess of the Site Worker CleanupGoals would be excavated. Non-hazardous soils containingchemicals of concern in concentrations less than the 1,000ppm treatment level would be sent for disposal at apermitted off-site landfill. The remaining soils above the1,000 ppm treatment level and RCRA hazardous wastes (ifencountered) would be incinerated at a permitted off-sitefacility. Excavated areas would then be backfilled withclean fill.

Response Measure 5B: Excavation; Off-site Incineration andLandfilling of Soils In Excess of the Construction Worker CleanupGoals; and Consolidation and Covering of Remaining On-site SoilsGreater Than the Site Worker Cleanup Goals



$ 4,419,000Estimated Implementation Period: 8 months*This estimate is for the soil/membrane cap, an additional$250,000 is estimated for the asphalt cap

Under Response Measure 5B, all site soils and formerdisposal trench materials that contain concentrations ofthe chemicals of concern in excess of the Site WorkerCleanup Goals would be excavated. Non-RCRA hazardous

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waste's that contain contaminant levels below the/ Construction Worker Cleanup Goals.would be consolidated.v within the former trench area and covered with either an

asphalt cap or a soil and impermeable membrane cap.Non-RCRA hazardous wastes containing more than theConstruction Worker Cleanup Goals, but less than the1,000.ppm treatment level would be sent to a permittedoff-site landfill. The remaining soils, thosecontaining levels of contaminants above the 1,000 ppmtreatment level and/or RCRA hazardous wastes, would besent to a RCRA-permitted off-site incinerator. Sincethe Construction Worker Cleanup Goals are lower than theNew Jersey Impact to Groundwater site Cleanup Criteria,backfilling and capping of only soils that exhibitcontaminant concentrations less than the ConstructionWorker Cleanup Goals would help to ensure groundwater isprotected in the event of a breach in the cap.Excavated areas would then be backfilled with cleanfill. O&M would include bi-monthly inspections, mowingand watering, regrading and revegatation..

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out inCERCLA §121, 42 U.S.C. §9621, by conducting a detailed analysis

; of the viable remedial response measures pursuant to the NCP, 40CFR §300.430(e) (9) and OSWER Directive 9355.3-01. The detailedanalysis consisted of an assessment of the individual responsemeasure against each of nine evaluation criteria and acomparative analysis focusing upon the relative performance ofeach response measure against the criteria.

The first two criteria are known as "threshold criteria" becausethey are the minimum requirements that each response measure mustmeet in order to be eligible for selection as a remedy:

1. Overall Protection of Human Health and the Environment- Addresses whether a response measure provides adequateprotection of human health and the environment fromunacceptable risks posed by hazardous substance, pollutants, orcontaminants present at the site by eliminating, reducing, orcontrolling exposures through treatment, engineering, orinstitutional controls.

2. Compliance with applicable or relevant and appropriaterequirements (ARARs)

- Addresses whether the response measure meets all theapplicable (legally enforceable), or relevant and

( -21-

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appropriate (pertaining to situations sufficiently similarto those encountered at a Superfund site such that their usei-s well suited to the. site) requirements Federalenvironmental laws or state environment or facility-sitinglaws or provides the grounds for invoking one of the sixARAR waivers stated in the NCP.

The next five criteria, criteria 3 through 7, are known as"primary balancing criteria". These criteria are factors withwhich tradeoffs between response measures are assessed so thatthe best option will be chosen, given site-specific data andconditions.

3. Long-term effectiveness and permanence- Refers to the ability of a response measure to maintainreliable protection of human health and the environment overtime, once remedial action goals have been met. Permanencefor this criterion is viewed along a continuum, and analternative can be described as offering a greater or lesserdegree of permanence.

4. Reduction of toxicity, mobility, or volume- Assesses the relative performance of a response measuretechnology's expected ability to reduce the toxicity,mobility or volume of hazardous substances, pollutants orcontaminants at the site.

5. Short-Term Effectiveness- Addresses the adverse impacts on human health and theenvironment -that may be posed in the time it takes toimplement the response measure and achieve the desiredremediation goals.

6. Implementability- Looks at the technical and administrative feasibility ofthe response measure, including the availability ofmaterials and services needed to implement each component ofthe option in question.

7. Cost- Includes estimated capital and O&M costs, and net presentworth value of capital and O&M costs.

The final two evaluation criteria, criteria 8 and 9, are called"modifying criteria" because new information or comments from thestate or the community on the Proposed Plan may modify thepreferred response measure or cause another response measure tobe considered. These last criteria are:

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8. State acceptance- Indicates whether based on its review of the RI/FS reports

V. and the Proposed Plan, the state supports, opposes, and/orhas identified any reservations with the selected responsemeasure.

9. Community acceptance- Summarizes the public's general response to the responsemeasures described in the Proposed Plan and the RI/FSreports. This assessment includes determining which of theresponse measures the community supports, opposes, and/orhas reservations about.

A comparative analysis of the response measures based upon thesenine evaluation criteria is presented below:

Overall Protection of Human Health and the Environment

Response Measure 1: No Action would not be protective ofhuman health and the environment because the site wouldremain in its current condition. The soils would continueto pose a threat to Trespassers and future Site Workers.Therefore, Response Measure 1 has been eliminated fromconsideration and will not be discussed further.

; Response Measure 2: Selective Excavation, Consolidation, andCapping relies completely on containment and institutionalcontrols to provide protection over time. Deed restrictionswould have to be enforced to ensure that the cap is notbreached in the future in order for this response measure tobe protective.

Response Measure 3A: Excavation; On-site, Ex-situ AnaerobicBiotreatment; Off-site Landfilling /Incineration wouldeliminate all significant risk to human health and theenvironment from site contaminants through off-site removal

. or treatment of contaminated soils that are found to beabove the 10"6 Site Worker criterion.

Response Measure 3B: Excavation; On-site, Ex-situ AnaerobicBiotreatment; Off-site Landfilling/Incineration and Cappingrelies partially on containment and institutional controlsto provide protection over time. Deed restrictions wouldhave to be enforced to ensure that the cap is not breachedin the future in order for this response measure to beprotective. The most contaminated soils would be removed ortreated, leaving only lower level soils to be capped.

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Response Measure 4A: Excavation; Off-site Low Temperature/- Thermal Desorption; Off-site Landf illing/Incineration wouldv eliminate all significant risk to human health and the

environment from site contaminants through off-site removalor treatment of contaminated soils that-are found to beabove the 10 ~fc Site Worker criterion.

Response Measure 4B: Excavation; Off-site Low TemperatureThermal Desorption; Off-site Landfilling and Incineration;Consolidation and Capping relies partially on containmentand institutional controls to provide protection over time.Deed restrictions would have to be enforced to ensure thatthe cap is not breached in the future in order for thisresponse measure to be protective. The most contaminatedsoils would be removed or treated, leaving only lower levelsoils' to be capped.

Response Measure 5A: Excavation; Off-site Incineration;Off-site Landfilling would eliminate all significant riskto human health and the environment from site contaminantsthrough off-site removal of contaminated soils that arefound to be above the 10 "6 site worker criterion.

Response Measure SB: Excavation; Off-site Incineration andLandfilling; and Consolidation and Capping relies partially

•< on containment and institutional controls to provideprotection over time. Deed restrictions would have to beenforced to ensure that the cap is not breached in thefuture in order for this response measure to be protective.The most contaminated soils would be removed or treated,

. leaving only lower level soils to be capped.

Compliance with ARARs

Actions taken at any Superfund site must meet all applicableor relevant and appropriate requirements of federal andstate law or provide-grounds for invoking a waiver of theserequirements. There are several types of ARARs: chemical-specific, location-specific, and action-specific. Chemical-specific ARARs are usually numerical values which establishthe amount or concentrations of a chemical that may be foundin, or discharged to, the ambient environment. Location-specific ARARs are restrictions placed on the concentrationsof hazardous substances or the conduct of activities solely

i because they occur in a special location. Action-specificARARs are technology or activity-specific requirements orlimitations related to various activities. Below is a

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discussion of some of the major ARARs for the Pulverizing/ Services site; a full list can be found in the RME.

Chemical-Specific ARARs

There are no federal or state promulgated soil cleanupstandards. None of the response measures evaluated meet thestate soil cleanup criteria for unrestricted use which,while not legally applicable, were considered by EPA. Ifthe state soil criteria are not met, institutional controlscould be required by the state. Certain of the wastes on-site may be determined to be hazardous waste, as defined inthe Resource Conservation and Recovery Act (RCRA).Therefore, the regulations regarding identification andlisting of hazardous waste at 40 CFR 'Part -261 may also applyif RCRA wastes are found in the trenches during excavation.

Each response measure that includes on-site treatment mayresult in air emissions. If so, these treatment processeswould be subject to federal Clean Air Act requirements,'which would regulate emissions from the treatment system.

Location-Specific ARARs

Because a portion of the site is classified as wetlands, allI response measures would need to comply with Section 404 of" the Clean Water Act and Federal Executive Order 11990

(wetlands protection) which requires federal agencies totake actions to minimize the destruction, loss, ordegradation of wetlands and to preserve and enhance thenatural and beneficial values of wetlands. Any actionswhich disturb or impact wetlands would require developmentof a wetlands mitigation plan. The site is not located in aflood plain and no endangered species have been observed atthe si.te. The cultural resource survey, dated February 1998,determined that there are no historically significantresources at the s.ite.

Action-Specific ARARs

The major action-specific requirements, for the variousresponse measures include RCRA requirements, which controlthe transportation and disposal of hazardous waste (ifhazardous waste is determined to be on site) and theNational Ambient Air Quality Standards. For example,Response Measure 2 includes excavation and capping ofcontaminated soil. This response measure would trigger RCRAcontainment requirements in 40 CFR Part 264. Response

{ .' -25-

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Measures 3A, 3B, 4A, and 4B include on- and off-site, treatment. Therefore, these response measures would trigaerv RCRA treatment requirements in 40 CFR Part 264 and RCRA

transporter requirements in 40 CFR Part 263. Any responsemeasure that may result in air emissions would be subject tothe federal Clean Air Act requirements which would regulateemissions from the treatment system.

During excavation of waste from the trenches on site, EPAwould determine whether the waste is a RCRA-listed hazardouswaste. The hazardous waste listings are found in 40 CFRPart 261. Any waste which is determined to be a RCRA-listedhazardous waste, in addition to the other requirementsmentioned above, would be subject to the RCRA land disposalrestrictions in 40 CFR Part 268. These restrictionsprohibit land disposal of certain listed wastes withoutprior treatment.

Long-Term Effectiveness and Permanence

Response Measure 2: Selective Excavation, Consolidation,and Capping would provide the least amount of long-termeffectiveness and permanence. Under this alternative,contaminated soils would remain on site. In addition,institutional controls would need to be employed and

/ enforced in order to ensure that the cap was not breached*• and rendered ineffective.

Response Measure 3A: Excavation; On-site, Ex-situ AnaerobicBiotreatment; Off-site Landfilling /Incineration provides ahigh degree of long-term effectiveness by destroying and/orremoving waste from the site, but only provides a moderatedegree of permanence since some waste may not be destroyedbut only contained off site.

Response Measure 3B: Excavation; On-site, Ex-situ AnaerobicBiotreatment; Off-site Landfilling/Incineration and Cappingprovides a moderate degree of long-term effectiveness bydestroying and/or removing the most contaminated waste fromthe site, but only provides a moderate to low degree ofpermanence since some waste (possibly some highlycontaminated waste) would not be destroyed but onlycontained both on and off site. Wastes .contained on sitewould require institutional controls to be employed andenforced in order to ensure the that the cap was notbreached and/or rendered ineffective.

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Response Measure 4A: Excavation; Off-site Low TemperatureThermal Desorption; Off-site Landfilling/Incinerationprovides a high degree of long-term effectiveness byremoving and/or destroying the most contaminated waste fromthe site, but only provides a moderate to high degree ofpermanence since some lesser contaminated waste would not bedestroyed but only contained off site.

Response Measure 4B: Excavation; Off-site Low TemperatureThermal Desorption; Off-site Landfilling and Incineration;Consolidation and Capping provides a moderate degree oflong-term effectiveness by destroying and/or removing theroost contaminated waste from the site, but only provides amoderate degree of permanence since some of the low levelwaste would not be destroyed but only contained on site.Wastes contained on site would require institutionalcontrols to be employed and enforced in order to ensure thethat the cap was not breached and therefore renderedineffective.

Response Measure 5A: Excavation; Off-site Incineration;Off-site Landfilling provides a high degree of long-termeffectiveness by removing all contaminated waste from thesite, but only provides a moderate to high degree ofpermanence since some lesser contaminated waste would not bedestroyed but only contained off site.

Response Measure SB: Excavation; Off-site Incineration andLandfilling; and Consolidation and Capping provides amoderate degree of long-term effectiveness by removing the.most contaminated waste from the site, and only provides amoderate to degree of permanence since some lessercontaminated waste would be contained on site.

Short-Term Effectiveness

Response Measure 2: Selective Excavation, Consolidation, andCapping can be implemented in approximately 8 months whichwould greatly reduce the short-term risks. Excavation andconstruction of the cap would require handling ofcontaminated soils and dust generation, but these can becontrolled through the use of protective equipment, goodconstruction practice and dust suppression. No off-sitetruck traffic would be required.

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Response Measure 3A: Excavation; On-site, Ex-situ AnaerobicBio treatment; Off -site Landfilling /Incineration can beimplemented in approximately 34 months and would requireextensive material handling and a long on-site constructionphase. Although the contaminant exposures can be reducedthrough the use of protective equipment, good constructionpractice and dust suppression, there is also the possibilityof a failure in the off-gas collection system. A moderateamount of truck traffic would be required to takecontaminated soils to off-site facilities.

Response Measure 3B: Excavation; On-site, Ex-situ AnaerobicBiotreatment ; Off -site Landf illing/Incineration; and Cappingcan be implemented in approximately. 36 'months and wouldrequire the most material handling and the longest on-siteconstruction phase. The contaminant exposures can bereduced through the use of protective equipment, goodconstruction practice and dust suppression. A minimumamount of truck traffic would be required to takecontaminated soils to off-site facilities.

Response Measure 4A: Excavation; Off -site Low TemperatureThermal Desorption; Off -site Landf illing/Incineration can beimplemented in approximately 8 months which would greatlyreduce the short-term risks. Excavation would requirehandling of contaminated soils and dust generation, butthese can be controlled through the use of protectiveequipment, good construction practice and dust suppression.-A large amount of truck traffic would be required to takecontaminated soils to off-site facilities.

Response Measure 4B: Excavation; Off -site Low TemperatureThermal Desorption; Off -site Landfilling and Incineration;Consolidation and Capping can be implemented inapproximately 10 months, which would help reduce the short-term risks. Excavation and construction of the cap wouldrequire handling of contaminated soils and dust generation,but these can be controlled through the use of protectiveequipment, good construction practice and dust suppression.A moderate amount of truck traffic would be required to takecontaminated soils to off-site facilities.

Response Measure 5A: Excavation; Off -site Incineration;Off-site Landfilling can be implemented in approximately 6months, which would greatly reduce the short-term risks.Excavation would require handling of contaminated soils anddust generation, but these can be controlled through the use

500033

of protective equipment, good construction practice and dustsuppression.- A relatively large amount of truck trafficwould be required to take contaminated soils to off-sitefacilities.

Response Measure 5B: Excavation; Off-site Incineration andLandfilling; and Consolidation and Capping can beimplemented in approximately 8 months, which would greatlyreduce the short term risks. Excavation and construction ofthe cap would require handling of contaminated soils anddust generation, but these can be controlled through the useof protective equipment, good construction practice and dustsuppression. A moderate amount of truck traffic would berequired to take contaminated soils to off-site facilities.

Reduction of Toxicitv, Mobility or Volume Through Treatment

Response Measure 2: Selective Excavation, Consolidation, andCapping achieves risk reduction without treatment, entirelyby reducing the mobility of the contaminants. The toxicityand volume of the•contaminants remain unchanged.

Response Measures 3A, 3B, 4A, 4B, 5A, and SB: Theseresponses use some type of treatment to destroy thecontaminants in the highly contaminated soils (those soilsabove the 1,000 ppm treatment level) and use on-site cappingor off-site landfilling to reduce the contaminant mobilityof the remaining soils. There is no difference in theamount of material destroyed among these options.

Implementabilitv

All of the services and materials needed to implement theseresponse measures are readily available commercially. Eachresponse measure utilizes standard technologies forexcavation, capping and transportation of soils. With theexception of 3A and 3B (which require treatability studiesto determine if they would work on the site soils), all theresponse measures are technically feasible. ResponseMeasures 3A and 3B will require an on-site treatabilitystudy (requiring about 12 months), while Response Measures4A and 4B require pilot-scale treatability studies(requiring about 2 months) at selected off-site facilitiesto obtain design parameters for the full-scale system.Response Measures 3A and 3B have complex administrativeissues because of the quantity of equipment, that needs to be

: setup at the site and the need to provide substantivecompliance with state air emissions regulatory requirements.

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Response Measures 2 and 5B are easily implementable usingstandard excavation technology. Response Measure 5A is theeasiest of the response measures to implement.

Cost

The capital, operation and maintenance, and present worthcosts are presented below for each response measure. A 5%interest rate and a 30-year O&M period was assumed tocalculate the present worth costs for Response Measures 2,3B, 4B, 5B. For the present worth cost of Response Measures3A, 4A, 5A, a five percent interest rate and a two-year O&Mperiod was assumed.

Response Measure 2: Selective Excavation, Consolidation, andCapping

Estimated Capital Costs: $ 1,339,000•Estimated O&M Costs (30 years): $ 184,000Estimated Total Present Worth Value: $ 1,523,000

Response Measure 3A: Excavation; On-site Ex-situ AnaerobicBio treatment ; Off-site Landf illing/Incineration



$ 5,135,000

Response Measure 3B: Excavation; On-site Ex-situ AnaerobicBio treatment ; Off -site Landf illing/Incineration; and Capping



$ 4,414,000

Response Measure 4A: Excavation; Off -site Low TemperatureThermal Desorption; Off -site Landf illing/Incineration



$ 4,701,000

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Response Measure 4B: Excavation; Off-site Low TemperatureThermal Desorption; Off-site Landfilling and Incineration;Consolidation and Capping



. $ 4,066,000

Response Measure 5A: Excavation; Off-site Incineration;Off-site Landfilling

Estimated Capital Costs: • $ 2,811,000 to$ 5,251,000


$ 5,273,000

Response Measure 5B: Excavation; Off-site Incineration andLandfilling; and Consolidation and Capping



$ 4,419,000

State Acceptance

The New Jersey Department of Environmental Protection has electednot to review documents or provide any state oversight .for thePulverizing Services site.

Community Acceptance

EPA solicited input from the Community on the remedialresponse measures proposed for the site. The attachedResponsiveness Summary addresses the comments received by theCommunity. The community is supportive of EPA's preferredremedial response measure.

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SELECTED REMEDY

V Based upon consideration of the results of the siteinvestigation, the requirements of CERCLA, the detailed analysisof the response measures, and public comments, EPA has determined

: that Response Measure 4A is the appropriate remedy for addressingthe contaminated soil at the site. Response Measure 4A satisfiesthe requirements of CERCLA §121 and the NCP's nine evaluationcriteria for remedial alternatives, 40 CFR §300.430(e) (9).Response Measure 4A is comprised of the following components:

° Excavation and transportation to an off-site disposalfacility •of approximately 13,100 cubic yards ofcontaminated soils determined to be above 0.34 partsper" million (ppm) of aldrin, 0.36 ppm of dieldrin, or17.0 ppm of 4,4'-DDT;

° Disposal of the excavated soils that are below thetreatment level of 1,000 ppm chlorinated pesticides,and are not hazardous waste pursuant to the ResourceConservation and Recovery Act (RCRA), at -an appropriateoff-site landfill;

° Treatment, by off-site thermal desorption, of allcontaminated -soil above the 1,000 ppm treatment level,that is determined to be treatable by thermal

\ desorption (any contaminated soil above the treatmentlevel that cannot be treated by thermal desorption, andany soils that are deemed RCRA hazardous waste, will besent to an off-site permitted incinerator fortreatment); and

° Backfilling of the excavated areas with clean fill froman off-site location, covering these areas withtopsoil, and seeding.

The preferred remedy would allow for future commercial use of thesite. ' This response measure contemplates institutional controls,such as a deed restriction, to ensure that the future land useremains commercial.

EPA selected Response Measure 4A over Response Measures 2, 3B, 4Band 5B because it would remove all contaminated soils from theproperty and not leave a cap that would further restrict use ofthe site and require constant maintenance. Response Measure 3Arelies on biotreatment technology that has not yet been proven'effective on site soils, and at best would require a long periodof treatability testing and design. The cost for the Response

{ • -32-

500037

Measure 4A is estimated to be between $2,600,000 and $4,700,000.Although the implementation time for Response Measure 4A is twomonths longer than Response Measure 5A, Response Measure 4Aprovides an equivalent level of protection at a savings ofbetween $200,000 and $500,000 when compared to the cost forResponse Measure 5A, and for this reason, Response Measure 4A ispreferred over Response Measure 5A., Response Measure 4A meetsall ARARs.

The selection of Response Measure 4A provides the best balance oftrade-offs among response measures with respect to the nineevaluation criteria. EPA believes that Response Measure 4A wouldbe protective of human health and the environment, would be costeffective, and would utilize permanent solutions and alternativetreatment technologies or resource recovery technologies to themaximum extent practicable.

STATUTORY DETERMINATIONS

As was previously noted, CERCLA §121(b)(1} mandates that aremedial action must be protective of human health and theenvironment, cost-effective, and utilize permanent solutions andalternative treatment technologies or resource recoverytechnologies to the maximum extent practicable. -Section121(b)(1) also establishes a preference for remedial actionswhich employ treatment to permanently and significantly reducethe volume, toxicity or mobility of the hazardous substances,pollutants, or'contaminants at a site. CERCLA §121(d) furtherspecifies that a remedial action must attain a degree of cleanupthat satisfies ARARs under federal and state laws, unless awaiver can be justified pursuant to CERCLA §121(d)(4).

As mentioned in the "Description of Alternatives" section,because the Pulverizing Services site has not been placed on theNPL, the response measure selected in this document falls withinthe category of a removal action. However, the selected responsemeasure is the permanent remedy selected for the soils at thesite, and as such, it is appropriate to apply the criteria listedin CERCLA Section 121 to the response measure. For the reasonsdiscussed below, EPA has determined that the selected responsemeasure meets the requirements of CERCLA §121.

Protection of Human Health and the Environment.

;Response Measure 4A would eliminate all significant risk to humanhealth and the environment from site contaminants through off-site removal or treatment of contaminated soils that are found tobe above the 10 "6 Site Worker criterion.

-33-

500038

/ Compliance with ARARs

Chemical-specific ARARS: There are no federal or statepromulgated soil cleanup standards. This response measure willnot meet the state soil cleanup criteria for unrestricted usewhich, while not legally applicable, were considered by EPA. Ifthe state soil criteria are not met, institutional controls couldbe required by the state. Certain of the wastes on site may bedetermined to be hazardous waste, as defined in the ResourceConservation and Recovery Act (RCRA). If RCRA wastes areencountered in the trenches during excavation, they will be sentto a RCRA-permitted incinerator.

Location-specific ARARs: Since a portion of the site isclassified as wetlands, the soil remedy needs to comply withSection 404 of the Clean Water Act and Federal Executive Order11990 which requires federal agencies to take actions to minimizethe destruction, loss, or degradation of wetlands and to preserveand enhance the natural and beneficial values of wetlands. Anyactions which disturb or impact wetlands would requiredevelopment of a wetland mitigation plan. The site is notlocated in a flood plain and no endangered species have beenobserved at the site. A cultural resource survey determined thatthere are no historically significant resources at the site.

Action-specific ARARs: Portions of the Resource Conservation andRecovery Act and its implementing regulations. Specifically, thetreatment requirements in 40 CFR Part 261 and the transportrequirements. In addition, the land disposal restrictions of 40CFR Part 263 may prove to be applicable based on sitediscoveries.

Cost Effectiveness

The total present worth for Response Measure 4A is estimated tobe between $2,600,000 and $4,700,000. When looking at theresponse measures that would not leave contaminants above theSite Worker Cleanup Goals on site, which EPA has determined to bepreferable, Response Measure 4A is estimated to be the leastexpensive. In addition, it is only moderately more expensivethan those alternatives that leave contaminants on site to becapped. Therefore, the selected response measure is costeffective as it has been determined to provide the greatestoverall long and short term protectiveness for its present worthcosts.

-34-

500039

Utilization of Permanent Solutions and Alternative TreatmentTechnologies

Response Measure 4A provides a permanent solution by removing allcontaminants above the Site Worker Cleanup Goals from the site.Therefore, there are no concerns that containment options mightfail and release contaminants at a future date. While ResponseMeasure 4A does not use alternative treatment technologies,several alternative treatment technologies were screened. Noneof the alternative treatment technologies that were screenedproved feasible for use at the site. Therefore, the selectedresponse measure represents the maximum/ extent to which permanentsolutions and alternative treatment technologies can be utilizedin a cost effective manner for the Pulverizing Services site.

Preference for Treatment as a Principal Element

The selected response measure satisfies the statutory preferencefor treatment as a principal element. Response Measure 4Autilizes both thermal desorption and incineration to destroy themost highly contaminated waste (soils containing greater than1,000 ppm total chlorinated pesticides) from the site.Furthermore, Response Measure 4A provides the best balance oftradeoffs with respect to the nine evaluation criteria.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the site was released to the public inJanuary 1999. The Proposed Plan identified Response Measure 4Aas the preferred alternative to address the soil contamination atthe Pulverizing Services site. Upon review of all commentssubmitted, EPA determined that no significant changes werenecessary to the selected response measure, as it was presentedin the Proposed Plan.

-35-

500040

cAPPENDIX I FIGURES

500041

Figure 1 - Site Location Map

Evergreenhome lor trie Aged /. .

M - . - . O -./• V

:'-J - '>if':"xVIM -teitr * * * .1^ 'Vr. -\

SCALE 1:24000o 1 MIU

1000 3000 4000 MOO 6000 7000 FtCT

I KILOMETER

CONTOUR INTERVAL 10 FEET

Referenced U.S.G.S. MapMoorestown, N]USGS7.5Min. 1965Photo Revised 1986

NIW

QUADKANOLI LOCATION

500042

„ ADJOINING FOOD1PROCESSINC FACiLinr

FENCE

RAILROAD

WOODED AREA

PROPERTY LINE

SEPARATION OF AREA A AND AREA C

APROXIUAIE LIMITS OFDISPOSAL 1RENCH

oooLO

WINSTEAO VILLAGECONDOMINIUMS

MScrvficcs Sntc, New Jersey

200

SCALE IN FEET

4002 Sfidc Layouift Msup

Figure taken from the Feasibility Study Report

APPENDIX II TABLES

500044

Table 1-la. Summary of ChemicalsArea A: Surface Soils

Parameters

SVOCs (ue/kelPhenol

HexachlorobenzeneDi-N-Butylphthalate

Pesticides / PCBs Cue/kg)Lindane, Total

AldrinEndosulfan I

Dieldrin4, 4' -DDE

Endrin, Total4, 4' - ODD4, 4' - DDT

MethoxychlorEndrin Ketone

SevinMalathion

Inorsanic Analvtes (mg/ks)Aluminum

ArsenicBarium

BerylliumCadmiumCalcium

ChromiumHexavalent Chromium

CobaltIronLead

MagnesiumManganese

MercuryNickel

PotassiumSeleniumSodium

ThalliumVanadium

Zinc

Dioxin (ug/kg)Octachlorodibenzo-P-Dio

Freq of I # ofDetects / Samples

3 / 1 42 / 1 41 /14

1 / 1 41/141 / 1 46/13

1 1 / 1 41 / 1 4

11/1414/141 / 1 41 /145 / 1 43 / 1 4

9 / 1 215/158 / 1 22 / 1 24 / 1 59 / 1 2

15/152 / 1 45 / 1 29 / 1 2

15/159 / 1 26 /126/127 /129/124 /129/123/129/129/12

4 / 4

Detected SamplesMinimum, units - Maximum, units

410-36000310 J- 200000 D

312.50 B- 312.50 B

33000 J - 33000 J69000 J - 69000 J

43.75-43.75750 J - 2200000

280 - 24000 J355 X- 355 X

350 JN - 360000 JN2500 D - 6800000 D

4900 X - 4900 X80000 J - 80000 J

41-51023 P - 260 P

2345-123002.20-132.00

38.80 B - 79.000.36 B- 1.80

1.60-6.3079.80 B - 96005.30-96.50

1.15 J- 2.20 J2.00 B - 4.90 B9430 - 62200

17.60- 480.50 J197.50 B- 5140.00

32.60-331.000.13-0.94

5.00 B - 9.80 B442 B- 1070 B0.72 B- 15.20169 B- 375 B0.95 B - 2.3010.10 B- 33.88.85 - 88.50

2.70 J- 12.00

Bolded parameters were chosen as "chemicals of concern" in EPA's Risk Assessment.

-1-

500045

Table 1-lb. Summary of ChemicalsArea A: Subsurface Soils

Parameters

VOCs (ug/kg)Methylene Chloride'

. AcetoneToluene

SVOCs (us/kg)Phenol

Di-N-Butylphthalate

Pesticides / PCBs (ua/kg)Alpha - BHCBeta - BHCDelta - BHC

Lindane, TotalAldrin

Endosulfan IDieldrin

4, 4' - DDE4, 4' -ODD4, 4' - DDT

SevinMalathion

Inorganic Analvtes (ms/kg)Aluminum

ArsenicBarium

BerylliumCalcium

ChromiumCobaltCopper

IronLead

MagnesiumManganese

MercuryNickel


VanadiumZinc

Freq o f / # ofDetects / Samples

5 / 1 57 / 1 51/15

2 / 1 51 / 1 5

17/464/468/46

12/462 / 4 63/468/466 /4612/4629/4619/46

1 /46

8 /139/147 / 1 32 / 1 38 /13

16/161 / 1 361 78 / 1 316/168/138/131 / 1 34 / 1 38/131/132/137 /138 /13


9.00-110.0010.50 B- 95.00

7.00 - 7.00

410-8104200 B - 4200 B

12-1470020 - 230010- 290 J

9.00 - 6000.0022 - 690017-230

22 - 6390035 - 8200

27 CJN - 2200030 - 442000100-230000

70-70

2570- 109003.10-24.80

30-700.70- 1.0030-610

4.00 - 47.007.00 - 7.00

3.00 - 23.003450- 17600

2.40-1 24.00 J70 - 840

6.00 - 184.000.12-0.12

5.00- 11.00130- 1420

0.90 B - 0.90 B80- 168 B

9.00-41.006.00 - 90.00


-2-

500046

Table l-2a. Summary of ChemicalsArea B: Surface Soils

Parameters

SVOCs (ug/ke)Fluoranthene

PyreneBenzo(a)anthracene

ChryseneBenzo(b)fluorantheneBenzo(k)fluoranthene

Benzo(a)pyreneIndeno(l, 2, 3-CD)pyrene

Benzo(g, h, Operylene

Pesticides / PCBs (us/kg)Beta - BHCEndosulfan I4, 4' -DDE4, 4' - ODD4, 4' - DDT

SevinMalathion

Inorganic Analvtes (ma/kg1)Aluminum

ArsenicBariumCalcium


CobaltIronLead

MagnesiumManganese

MercuryNickel


VanadiumZinc


Freqof/#ofDetects / Samples

/ 7/ 7/ 7/ 7

21 7/ 7/ 7/ 7/ 7

I / 7I / 77/ 76/ 77/ 72/ 721 1

21 67/ 72 / 62/ 67/ 73/ 72/ 621 67/ 72/ 62 / 62/ 62/ 621 6I / 621 621 62 / 6 -

3/3


3550-35502950 - 29502050 - 20503000 - 3000360 - 48501700- 17001300 - 1300975 - 975

547.50-547.50

305 - 305417.50-417.50

150 - 20000150JN-15000JN

190- 280000 D227.50-4212.50

18.25- 19.00 P

7770- 112003.95 - 15.2560.00-63.10313B- 13109.10-22.30

0.80 J- 3.10 J2.50 B - 3.60 B12700- 1550028.90 J- 88. 10858 B- 1070 B

131 - 1590.19-1.10

6.50 B - 8.60 B683 B - 833 B1.10B- 1.10B189B-213B22.60 - 29.3032.60 -69.60

1.10 J- 11.00


-3-

500047

Table l-2b. Summary of ChemicalsArea B: Subsurface Soils

Parameters

VOCs (ug/kelAcetone

SVOCs Cue/kE)Burylbenzylphthalate

Bis(2-EthylhexyI)phthalate

Pesticides / PCBs (ug/kg)Alpha - BHCBeta - BHC4, 4' - DDE4, 4' - ODD4, 4'- DDT

Inorganic Analvtes (mg/kg)Aluminum

ArsenicBerylliumCalcium

ChromiumCopper

IronLead

MagnesiumManganese

MercuryNickel

PotassiumVanadium

Zinc

Freqof /#ofDetects / Samples

\ l 3

I / 2I / 2

1 / 72 / 72 / 73 / 76 / 7

I / 2I/ 21 / 2I / 22/ 2

/ 1]/ 22/ 2I / 2

/ 2/ 2/ 2/ 2/ 2/ 2


46.00 - 46.00

1000 J- 1000 J1400 J- 1400 J

12-1224-180

720 - 22600031 - 1940

196-1240000

10800- 108003.60 - 3.600.80-0.80

20-2014.10-17.00

25-2521100-211004.50 - 5.60 J

370 - 37063-63

0.08 - 0.086.00 - 6.00350-35026-2614- 14


-4-

500048

Table l-3a. Summary of ChemicalsArea C: Surface Soils

Parameters

SVOCs (ug/kg)Di-N-Butylphthalate

Pesticides / PCBs fug/kg)4, 4' - DDE4,4'-DDD4, 4' - DDT

Inorganic Analytes (mg/kg)Aluminum

ArsenicBarium

BerylliumCalcium


CobaltIronLead

MagnesiumManganese

NickelPotassiumSeleniumSodium

VanadiumZinc



' 3/ 7

6/ 74/ 77/ 7

21 611 71 / 6I/ 621 611 71 / 721 621 66/ 72/ 62/ 621 62 / 6I / 621 62/ 62/ 6

3/3


470 B - 2205

37 -1200 CD16JN-500J22 B - 3800 J

5850 - 70905.10-22.70

36.50 B- 36.50 B0.34 B - 0.34 B431 B-466B10.90- 16.901.40 J- 1.40 J

3.40 B- 4.50 B10100-1620016.90-59.00

651 B- 829 B246 - 285

6.70 B - 8.30 B530B-816B

0.99 B - 0.99 B153 B- 209 B19.80-46.4033.90-51.30

12- 14


-5-

500049

Table 1-4. Summary of ChemicalsArea A & C: Combined Surface Soils

Parameters

SVOCs fug/kg")Phenol

HexachlorobenzeneDi-N-Butylphthalate

Pesticides / PCBs fug/kg)Lindane, Total

AldrinEndosulfan I

Dieldrin4, 4' - DDE

Endrin, Total4, 4' - ODD4, 4' - DDT

MethoxychlorEndrin Ketone

SevinMalathion

Inorganic Analvtes (mg/kg)Aluminum

Arsenic .Barium

BerylliumCadmiumCalcium


CobaltIronLead

MagnesiumManganese

MercuryNickel


ThalliumVanadium

Zinc

Dioxin fug/kg)Octachlorodibenzd-P-Dio


37 2121 214/ 21

I / 2 1I/ 21\ t 2161 20

177 21I / 21

15/ 21217 21

17 2117 2157 2137 21

11 7182272297183 /184 /22

117182272237217 / 1 8

11 /182172211 /188/186 /189/18

11/185 /18

11 /'183/18

11/1811/18

7 / 7


410-36000310 J- 200000 D

3 12.50 B- 2205.00

33000 J - 33000 J69000 J - 69000 J

43.75-43.75750 J - 2200000

37 - 24000 J355 X- 355 X

16JN-360000JN22 B - 6800000 D4900 X - 4900 X80000 J - 80000 J

41 -51023 P - 260 P

2345 - 123002.20-132.00

36.50 B - 79.000.34 B- 1.80

1.60-6.3079.80 B - 9600.00

5.30 - 96.501.15 J- 2.20 J

2.00 B - 4.90 B9430 - 62200

16.90- 480.50 J197.50 B- 5140.00

32.60-331.000.13-0.94

5.00 B - 9.80442 B - 1070 B0.72 B- 15.20153 B- 375 B0.95 B - 2.30

10.10 B- 46.408.85 - 88.50

2.70 J- 14.00


-6-

500050

Table 2-1. Combined Carcinogenic RiskSurface Soil Pathways

AreaSurface

Soil

Area A

Area B

AreaC

Areas A & C

Area B

Area A

AreaB

AreaC

ReceptorPopulation

Area Residents /Trespassers: Children

(12-17yrs. old)


(12 -17 yrs. old)


(12- 17yrs. old)

Residents: Adults

Children(0 - 6 yrs. old)

Residents: Adults

Children(0-6 yrs. old)

Site Workers /Employees



ExposureRoute

IngestionInhalation of Particulates

Total Carcinogenic Risk =

IngestionDermal Contact









Inhalation of ParticulatesTotal Carcinogenic Risk =









IndividualCancer

Risk

1.3E-033.7E-071.3E-03

4.9E-062.5E-084.9E-06

1.3E-063.2E-081.3E-06

1.8E-024.8E-051.8E-02

4.2E-024.0E-054.2E-02

6.9E-054.5E-073.9E-077.0E-05

1.6E-041.3E-073.3E-071.6E-04

6.8E-031.6E-056.8E-03

2.6E-051.4E-071.3E-072.6E-05

7.0E-061.8E-071.3E-077.3E-06

Chemicals Contributingthe Greatest Amount to

Risk

Dieldrin

Dieldrin

--

~ "

Aldrin, Dieldrin, 4,4'-DDT

Dieldrin, 4,4'-DDT



--

--



--

--

-- '

--

-7-

500051

Table 2-2. Combined Carcinogenic RiskSubsurface Soil Pathways

AreaSubsurface

Soil

Area A

AreaB

ReceptorPopulation

ConstructionWorkers

ConstructionWorkers

ExposureRoute


Total Carcinogenic Risk =.

IngestionInhalation of Particuiates


IndividualCancer

Risk

4.0E-061.8E-094.0E-03

8.8E-062.0E-098.8E-06


Risk

--

--

--

-8-

500052

Table 3-1. Combined Non-Carcinogenic Hazard Index ValuesSurface Soil Pathways

AreaSurface

Soil

Area A

AreaB

AreaC

Areas A & C

AreaB

Area A

AreaB

AreaC

ReceptorPopulation


(12-17yrs. old)


(12-17yrs.old)


(12- 17yrs. old)

Residents: Adults


Residents: Adults





ExposureRoute





















HazardIndex

2.3E+01MA

2.3E+01

2.5E-01MA

2.5E-01

5.4E-02MA

5.4E-02

8.2E+01MA

8.2E+01

7.7E+02NA

7.7E+02

8.8E-01NA

4.1E-029.2E-01

8.2E+00NA

1.4E-018.3E+00

2.9E+01NA

2.9E+01

3.1E-01NA

1.3E-023.2E-01

6.8E-02NA

2.3E-029.1E-02


Hazard Index Values

Dieldrin. 4, 4'-DDT

Dieldrin, 4. 4'-DDT

• ~

;;Aldrin, Dieldrin, 4,4'-DDT




--

4, 4'-DDT

4, 4'-DDT



--

--

-9-

500053

Table 3-2. Combined Non-Carcinogenic Hazard Index ValuesSubsurface Soil Pathways

AreaSubsurface

Soil

Area A

AreaB

ReceptorPopulation

ConstructionWorkers

ConstructionWorkers

ExposureRoute





HazardIndex

1.3E+00NA

1.3E+00

3.0E+00NA

3.00E+00


Hazard Index Values

4, 4-DDT

4. 4'-DDT

4,4'-DDT

4,4'-DDT

-10-

500054

APPENDIX IIIADMINISTRATIVE RECORD

INDEX

500055

PULVERIZING SERVICES SITEADMINISTRATIVE RECORD FILE

INDEX OF DOCUMENTS

2.0 HEMOVAL RESPONSE

2.1 Sasipling and Analysis Plans

P. 200001- Letter report to Mr. John Osolin, Remedial Project200023 Manager, U.S. EPA, Region II, from Mr. Peter L.

Sudano, PG, CHMM, Senior Project Manager, ERM-EnviroClean, Inc., re: Work Plan for Off-SiteContaminated Soil Removal, "Pulverizing ServicesSite, Moorestown, New Jersey, July 17, 1995.

2.2 Sasnpling and Analysis Data

Report : On Scene Coordinator's Report. PulverizingServices Removal Action, Moorestown, BurlingtonCounty, New Jersey, prepared for Mr. EugeneDominach, Site Mitigation Section, Removal ActionBranch, U.S. EPA Region II, prepared by Mr. JeffM. Bechtel, Technical Assistance Team, Roy F.Weston, Inc., February 13, 1989. (Note: Thisdocument is located in the Removal AdministrativeRecord, USEPA Removal Records Center, 2890Woodbridge Avenue, Edison, New Jersey.)

Report 5 Site Clean-Tip Report s Pulverising 5er"vH e^sTnp . r Moorestown,. New Jersey^ Volump f . preparedfor U.S. EPA, Region II, prepared by Clean HarborsEnvironmental Services Companies, Inc., December6, 1991. (Notes This document is located in theRemoval Administrative Record, USEPA RemovalRecords Center, 2890 Woodbridge Avenue, Edison,New Jersey.)

200024- Report: Site. Cl e an -Up Report s PulverlzJLng S200288 Inc.. Moorestownf New Jersey j Volume TT. prepared

for U.S. EPA, Region II, prepared by Clean HarborsEnvironmental Services Companies, Inc., December6, 1991.

500056

P. 200289- Letter report to Mr. John Osolin, Remedial Project200387 Manager, U.S. EPA, Region II, from Mr. Daniel L.

Bonk, P.E., Baker Environmental, Inc. re: Resultsof Soil Excavation and Confirmation Sampling atthe Adjoining Winstead Village CondominiumProperty Pulverizing Services Site, Moorestown,New Jersey, January 29, 1997.

2.7 Correspondence

P. 200388- Letter to Mr. John Osolin,- U.S. EPA, Region II,200553 from Mr. A. Douglas Weeks, Jr., Project Manager,

and Mr. Daniel J. Welshons, Safety and HealthManager, ICF Kaiser, re: Response to Comments -Pulverizing Services Site Health and Safety Plan,Pulverizing Services Site, Moorestown, New Jersey,November 30, 1998. (Attachment ; Heal£h and Sa_fe±yPlan Addendum . PnlveyiTT S&rvlgps 5^.Moorgstown New Jersey^ November 30. 199R.)

3.0 REMEDIAL INVESTIGATION

3.1 Sampling and Analysis Plans

P. 300001- Report: field Summary Rppqrt Oversight Of Sampling300017 Activities. October 26 & 27f 1994 , Pulverizing

Services 5 it e . Moorestowrij New Jersey, preparedfor U.S. Environmental Protection Agency, Officeof Waste Programs Enforcement, prepared by CDMFederal Programs, November 1, 1994.

P. 300018- Report: Field SuTrrmary Report Oversight Of Sampljjig300043 Activities^ December 3-7. 1994.

P 300044300072

Services Site. Moorestown, New Jersey, preparedfor U.S. Environmental Protection Agency, Officeof Waste Programs Enforcement, prepared by CDMFederal Programs, December 12, 1994.

Reports Fi*»Activities.

f3 Summary Report Oversight. Of SamplingDegember 12-16 f 1994

Site. Moorestown. New preparedfor U.S. Environmental Protection Agency, Officeof Waste Programs Enforcement, prepared by CDMFederal Programs, December 20, 1994.

500057

p.

p.

300073-300085

300086-300093

Report : Field Summary Report: Oversight OfMo;niiflnr;i.nig Well Instja.XJ.fllr- ion Activities.24-26r 1995. Phase . H_Site Investigation.

n Services 5ite Moorestovm. New Jerseprepared for U.S. Environmental Protection Agency,Office of Waste Programs Enforcement, prepared byCDM Federal Programs, January 27, 1995.

Summar Reort. OversitReport : FJ-eSoil Screenin And Samlin. Marc> "14 and 15

IT Site Tnvestigg^, j,npLl P\^lverJ, ?;ingSite, Moorestown. New Jersey, prepared for U.S.Environmental Protection Agency, Office of WastePrograms Enforcement, prepared by CDM FederalPrograms, March 23, 1995.

3.3 Work Plans

300094-300141

Plan: HorJsLJPlan Supplemental Phase _II Siteon. prepared by McLaren/Hart, April 8,

1996.

3.4 Remedial Investigation Reports

P. 300142- Plan: Final Quality As.suranee/ Quality Control300239 Plan, Phase T Study Area Investigation.

Pulverizing Services Site, Moorestown. New Jersey,prepared by Paul C. Rizzo Associates, Inc.,January 1990.

P.

P.

300240-300453

300454-301589

Report:T Text.

phase I Site Investigation Report ,Tables Figures and Append! <-eg &. fh-rough D.

phase I Study Area Invest 1 gat ion , Pulverizingggrv^f^pq Sitej Moorestovmf New Jersey n preparedfor PPG Industries, Inc., Pittsburgh, Pennsylvaniaprepared by Paul C. Rizzo Associates, Inc., April1993.

Report: phase I Site Investigation Report. VolumeJ I Appendices E through f?f Phase T Study Area^nvestigationf Pulverizing Servires Sifct*.,Moorej-stown. New Jersey prepared for PPGIndustries, Inc., Pittsburgh, Pennsylvaniaprepared by Paul C. Rizzo Associates, Inc. April1993.

500058

P. 301590302272

P. 302273302938

Report: Phase TT Site Invest igat ion. WorkQuality &gg\irancWQua1 -i ty Control Plan,Safety Plan, prepared for PPG Pulverizing ServicesFacility, Moorestown, New Jersey, prepared byMcLaren/Hart Environmental EngineeringCorporation, August 1994. (Note: Pages 301742-301914 of this document are CONFIDENTIAL. They arelocated at the U.S. EPA Superfund Records Center,290 Broadway, 18th Fl., N.Y., N.Y. 10007-1866.)

Report: Phase TT Site Investiga±_jpn_RepOJCtL<Pulverising Services Site. Mooregtowrij Newprepared for PPG Industries, Inc., Pittsburgh,Pennsylvania, prepared by McLaren/HartEnvironmental Engineering Corporation, May l,1995.

P. 302939-302966

Report:Report ,

Wetlands Evaluation and_Habi£a±PPG Pulverizin Services Sitg

Survey

New, -Jersey prepared for PPG Industries, Inc.,prepared by McLaren/Hart Environmental EngineeringCorporation, July 16, 1996.

3 . 5 Correspondence

P. 302967- . Letter to Mr. John Osolin, U.S. EPA, . Region II,302989 from Mr. Daniel L. Bonk, P.E., Baker

Environmental, -.Inc. , re: Off-Site Water WellSurvey, Pulverizing Services Sites, Moorestown,New Jersey, January 10, 1996. (Not/e: Pages 302969-302979 of this document are CONFIDENTIAL. They are.located at the U.S. EPA Superfund Records Ceoter,290 Broadway, 18th Fl., N.Y., N.Y. 10007-1866.)

'4.0 FEASIBILITY

Feasibility Study Repes-fe

P. 400001° Reports Response Measures -Evaluation Report:.400146 pulverJ.2J.nQ Services Site, Moorestown. New

prepared for PPG Industries, Inc., prepared by ICFKaiser Engineers, Inc., December 15, 1997.

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7.0 SNFORCSMEHT

7.2 Sndangerment Assessments

P.

P.

P.

P.

700001-700281

700282-700478

700479-700778

700779700790

Report: Final EndangermentServices 5iter Moorestown. New Jersey. T nfJLUU. prepared for U.S. EPA, prepared by CDMFederal Programs Corporation, February 2, 1996.

Report : Final Endangerment Assessment r Pulver jy.Sr^Services. S Lte. M' town New Jerse. Volume TT

TIT, prepared for U.S. EPA, prepared by CDMFederal Programs Corporation, February 2, 1996.

Report : Final Endangerment Assessment .Sf rvJees, _Site . Moorgstovsm, New Jersey. Volume TT'Tof prepared for U.S. EPA, prepared by CDMFederal Programs Corporation, February 2, 1996.

. Mark Austin, ARCS II Regional

. EPA Region II, from Mr. Robert D.ARCS II Program Manager, re: AddendumEndangerment Assessment, Document7720-064-RA-CNSZ, August 19, 1997.Addendum To The Final Endangerme^Pulverizing Services Site. Moorestown.

New Jersey. August 19s 1997.)

Letter to MrOfficer, U.SGoltz, P.E.,to the FinalControl No.:(Attachment:

10.0 PUBLIC PARTS CIPATIOS?

10.2 CoHcnuaity Relations Plan®

delations Plan. PulverizingP. 10.00001 Plan:10.00007 Servicee Site, Mooreet'ovmf New Jersey, prepared by

U.S. EPA Region II, August 1998.

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APPENDIX IVRESPONSIVENESS SUMMARY

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DECISION DOCUMENTResponsiveness Summary


Moorestown, Burlington County, New Jersey

As part of its public participation responsibilities, the U.S.Environmental Protection Agency (EPA) held a public commentperiod from January 19, 1999 through February 18, 1999, forinterested parties to comment on EPA's Proposed Plan for thePulverizing Services site in Moorestown, New Jersey. TheProposed Plan described the alternatives that EPA considered forremediating the contaminated soils at the site.

On January 27, 1999, EPA conducted a public .meeting in the courtroom at 11 West Street in Moorestown, New Jersey. During thepublic meeting, representatives from EPA discussed the preferredresponse measure, answered questions, and received oral andwritten comments on the response measure recommended in theProposed Plan and other remedial response measures underconsideration.

In addition to comments received during the public meeting, EPAreceived written comments throughout the public comment period.EPA's responses to significant comments, both oral and written,received during the public meeting and public comment period, aresummarized in this Responsiveness Summary. All commentssummarized in this document were factored into EPA's finaldetermination of a remedial response measure for cleaning up thesite. EPA's selected response measure for the site is describedin the Decision Summary of the Decision Document.

This Responsiveness Summa-ry is divided into the followingsections.

o Overview: This section discusses EPA's preferredresponse measure.

o Background: This section briefly describes communityrelation activities for the Pulverizing Services site.

o Response to Written Comments from PotentiallyResponsible Parties: This section provides responses tocomments received from the Pulverizing Services sitePotentially Responsible Parties (PRP) Group during thepublic comment period.

o Public Meeting Comments and EPA's Responses: Thissection provides summary of commenters' major issuesand concerns, and expressly acknowledges and respondsto all significant comments raised at the January 27,1999, public meeting.

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o Response to Written Comments: This section provides asummary of, and responses to, comments received inwriting during the public comment period.

Appendix A: Transcript of the January 27, 1999, publicmeeting.

Appendix B: Written comments received by EPA during thepublic comment period.

Appendix C: Proposed Plan.Appendix -D: Public Notice printed in the January 17,

1999, Burlington County Times.

I . Overview

At the initiation of the public comment period on January 17,1999, EPA presented its preferred response measure for thePulverizing Services site. The proposed plan identified thepreferred remedy as Response Measure 4A. Response Measure 4A iscomprised of the following components:

° Excavation and transportation to an off-site disposalfacility of approximately 13,100 cubic yards ofcontaminated soils determined to be above 0.34 partsper million (ppm) of aldrin, 0.36 ppm of dieldrin, or17.0 ppm of 4, 4 '-DDT;

° Disposal of the .excavated soils that are below thetreatment level of 1,000 ppm chlorinated pesticides,and are not hazardous waste pursuant to the ResourceConservation and Recovery Act (RCRA) , at an appropriateoff-site landfill;

0 Treatment, by off-site thermal desorption, of allcontaminated soil above the 1,000 ppm treatment level,that is determined to be treatable by thermaldesorption (any contaminated soil above the treatmentlevel that cannot be treated by thermal desorption, andany soils that are deemed RCRA hazardous waste, will besent to an off-site permitted incinerator fortreatment) ; and

° Backfilling of the excavated areas with clean fill froman off-site location, covering these areas withtppsoil, and seeding.

Response Measure 4A would allow for future commercial use of thesite. This response measure contemplates institutional controls,such as a deed restriction, to ensure that the future land use

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remains commercial./ The preferred remedy, Response Measure 4A, is identical to thev response measure selected by EPA for this site.

II. Background

The Site Investigation reports, the .Response Measures Evaluationreport, the Proposed Plan and other supporting documentation were"made available to the public in the administrative record file atthe Superfund Document Center in EPA Region II, 290 Broadway, NewYork, New York, and the information repository at the BurlingtonCounty Library, 5 Pioneer Boulevard, Westampton, New Jersey. Thenotice of availability for the above-referenced documents waspublished in the Burlington County Times; on January 17,1999. Thepublic was given the opportunity to comment on the preferredresponse measure during the"public comment period which was heldfrom January 19, 1999, to February 19, 1999. In addition, onJanuary 27, 1999," EPA held a public meeting in the court room at11 West Street in Moorestown, New Jersey. At this meeting,representatives from EPA and PPG answered questions concerningthe site and the remedial response measures under consideration.

III. Responses to Written Comments from Potentially ResponsibleParties

$1. A PRP commented that the remedy should allow for the use of

two thermal desorption facilities, if necessary, to maximizethe range of material that could be treated.

EPA's Response: EPA agrees with this approach, and hasmodified the Decision Document to reflect PPG's comment.

2. A PRP indicated that the disposition of high level wastesshould not be restricted to incineration, but the DecisionDocument should instead state that an off-site Treatment,Storage and Disposal Facility (TSD) would be used to handlehigh level wastes.

EPA's Response: EPA disagrees with this approach because theterm TSD might" include several technologies that EPAconsiders inappropriate for treating these wastes. EPAintends for the high level or "principle threat" wastes tobe destroyed. The Decision Document states that

: incineration will be used for high level wastes nottreatable by thermal desorption. Incineration offers thebest assurance, of currently available technologies, that

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these high level- wastes will be destroyed. If a differenttreatment technology can be identified that has-a similarlevel of performance to incineration, EPA would consider itssubstitution, providing the cleanup schedule is not delayed.

IV. Public Meeting Comments and EPA's Responses

1. A local resident expressed concern as to what extent an off-site investigation had been conducted. According to theresident, the former activities at the site generated atremendous amount dust, which may have spread contamination.

EPA's Response: An extensive soil investigation covered allareas of the site. If soil contamination was found at thesite perimeter, then further sampling outside the propertyboundaries was conducted. Soil sampling continued untilcontamination levels were found to be below residential orcommercial cleanup criteria, depending on zoningrestrictions. Soils above their respective cleanup criteriawere subsequently removed. Some of this contamination mayhave been deposited as a windblown dust, however, EPA isconfident that previous removal actions have alreadyaddressed contaminated soils found off the site.

2. Several residents expressed concern with the use of water tominimize dust production. Because of the already low watersupply in their community, they questioned the volume ofwater that will be required, and where the water will comefrom. They also wanted to know if the surrounding watertable be affected by remedial activities.

EPA's Response: During the remedial process, a fine mist ofwater may be needed to suppress the dust generation. Theamount of water used would not be more than a few hundredgallons-per-day, not thousands of gallons per day. However,EPA will coordinate with-the local fire department regardingwater shortages and, if necessary, a water tanker truck willbe brought from outside the area to provide the necessarywater supply. The surrounding water table is not expectedto be affected by the remedial activities because of the lowvolume of water required by the clean up.

3. Mention of the dust control generated additional concernfrom the audience. Specifically, what action levels wouldbe used and what air monitoring measures would beimplemented. Also, in the event of an emergency, how wouldthe neighboring homes be notified.

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£ EPA's Response.: Air monitoring action levels will bedetermined before construction activities commence andrecorded in the site's health and safety plan. Based on thepre-determined action levels and the results at eachmonitoring location, EPA will determine the necessaryactions to be implemented to ensure contamination iscontained. If necessary, the work will be stopped until thedust levels are brought to within the acceptable range. Theaction levels will be extremely conservative to ensure thatdangerous levels of dust will never be generated. Althoughthere is little risk of site emergencies affecting off-siteareas, the Police and Fire Departments will be notified inthe event of any.emergency. The departments will assistsite personnel with implementing the necessary contingencyactions and, if needed, notifying neighboring homes andbusinesses.

4. A resident asked : Does EPA have •the PRP's support toproceed with the Preferred Response Measure (4A)?

EPA's Response: The PRP has verbally committed to EPA thatit will implement Response Measure 4A.

5. A local resident inquired about the time required tocomplete remediation. This resident also inquired whetherEPA expects to have a saleable commercial property when theclean up is complete, and if so, how long before such atransaction is able to take place.

EPA's Response: EPA estimates that the work can be completedwithin eight months of start of construction. EPA presumesthat the property could be sold after the soil is cleanedup. While there is some further work to be done on the site(Groundwater, Surface Water and Sediment), EPA does notbelieve that this would hinder.development of the majorityof the property. The time frame for such a transaction totake place is not known.

6.. A resident asked whether further monitoring or testing onadjacent properties will be conducted after the remediationis completed.

EPA's Response: EPA believes that the characterization ofthe extent of contamination in soil is complete andadditional sampling of adjacent properties is probably notnecessary. If sampling during the remediation work suggests

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otherwise, additional investigations will be performed.

7 . A resident asked if the property will be reseeded uponcompletion of remedial activities .

EPA' a Response: The property will at a minimum be reseededaccording to the state of New Jersey's reseedingrequirements. .

8. A resident asked what steps will be taken to preventadjacent properties and roads from becoming contaminated.

EPA's Response: When remediation activities begin, therewill be real time monitoring of the ambient air andcontingencies to address elevated levels should they arise.Preventive measures such as the use of a tarp and/or lightwater misting will be utilized to suppress the production ofairborne particulates from exposed soil. In addition,trucks that leave the site will be kept from driving throughcontaminated areas, and their loads will be tarped toprevent material from blowing off the trucks.

9. A resident asked what the typical work hours will be whenconstruction activities begin.

EPA' s Response: Generally, personnel will assembly at thesite around 6 a.m. with intrusive activities (e.g., use ofheavy machinery) starting around 7 a.m. Typically,activities conclude around 5 or 6 p.m. Weekends are notscheduled for this project. However, if delays areexperienced, then an occasional work weekend might beutilized to maintain the project schedule.

10. A resident asked to what extent in-situ bioremediation wasconsidered, and why bioremediation was not considered areliable remedy for this site.

SPA's Response: During, the feasibility study, severaltechnologies were qualitatively evaluated by EPA. - Based onthe site characteristics such as high clay content and thepresence of chlorinated pesticides, it was concluded thatin-situ bioremediation would not be a feasible technologyfor remediating the site. Thus, in-situ bioremediation wasnot presented as a remedial response measure in the ProposedPlan.-

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11. A resident asked what type of investigation was conductedi along the railroad tracks.

EPA's Response: The PRP took soil samples in the woods onthe southern-most portion of the site, and surface water andsediment_samples in the wetland area along the railroadtracks. With the exception of a localized area in whichsome material was dumped on the surface, soil was clean inthis area. This surface pile will be cleaned up as part ofthis action. Surface water and sediment samples taken inthe wetland area showed some slightly elevated levels insediment. These elevated levels are most likely related tothe aforementioned surface pile. After the site soils havebeen cleaned up, EPA intends to further investigate thesurface water and sediment in this area. No samples weretaken across the tracks from the site because of the lack ofsite-related activities associated with this area, and thebarrier to site runoff posed by the tracks themselves.

12. A resident asked what measures will be taken to secure theproperty at the end of the day.

EPA's Response: The security fencing around the perimeter ofthe site will be secured and locked. Any excavated soil andexposed holes will be clearly identified, covered, andsecured.

13. A resident wanted to know what testing of residential soilsand water has been performed in the area down behind theHolly building, and between the Holly building and WinsteadVillage. Be also wanted to know if any contamination wasfound there. He mentioned that at one time (pre 1993), theEPA had planned to test the soil and water on the propertiesnear Crider Avenue. He wanted to know if that testing hadoccurred.

EPA's Response: The PRP, with EPA oversight, has tested thesoils on the Holly property and determined that thecontaminant levels in the soils are below commercial health-based levels. Based on the results of the adjacent property(Winstead Apartments), where the. soils were tested toresidential health-based levels, EPA is confident thatcontaminants above the residential level are limited to asmall area within the Holly property and have not reachedthe residential areas. However, EPA will perform furthertesting in that area during the initial stages of thecleanup to confirm these findings. Current groundwater

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monitoring data from that area does not indicate that the/ groundwater has been impacted by site contaminants. InV addition, town records indicate that there are no private

wells within a 1/4 mile of the site.

14. A resident was concerned about impact to the roadwaysurfaces and trucking disturbing residential areas. Thesuggestion was made to go up Church and down to 130 to avoidthese neighborhoods.

EPA's Response: No decision regarding truck routes has beenmade at this time. Every effort will be made to minimize 'truck traffic in the adjacent residential neighborhoods.E'PA will contact town officials and neighbors to solicittheir input on this matter.

/

15. A resident asked what would happen if a spill occurredduring transport of the contaminated soil.

EPA's Response: EPA will take every precaution to ensurethat spills during off-site*transport do not occur.However, if a spill does occur, EPA will have contingencymeasures in place to respond quickly and efficiently. Inaddition, the material being removed from the site will notpose an immediate threat in the event of a spill and could

1 - be easily contained without any major impact to the area.

16. A resident asked what landfill will be receiving the soil?

EPA's Response: Currently, EPA does not know which landfillwill be receiving site materials. This will be determinedduring the design phase of the cleanup.

V. Response to Written Comments

The following concerns were expressed in letters from localresidents.

1. A local resident inquired about the local storm sewer thatruns under Crider Avenue and discharges to a stream nearLenola Road. The resident was concerned that groundwaterrunoff from the site could have contaminated this stream.

SPA's Response: The remedial investigation showed low levelsof contamination in the on-site channel that drains intothat storm sewer. Based on the previous investigation

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results, EPA does not expect to find significant levels offsite. EPA will continue to investigate this area' in theupcoming sediment investigation.

A neighboring resident to the site expressed concern thatdeed restrictions would not control the transport ofairborne particulates off site. Thus, the site wouldcontinue to pose a risk to the adjacent residentialproperties, because the site remediation calls for cleanupto commercial standards.

EPA's Response: When the site is .remediated to a commercialstandard, the levels remaining at" the site will not pose anairborne dust threat. EPA evaluated how much dust wouldhave to become airborne to present an inhalation hazard,using the highest levels currently found in the surfacesoils (pre-cleanup conditions). Based on this evaluation,EPA determined that the amount of dust would have to be onthe order of a dust storm that would partially obscurevision, in order that health-based levels were exceeded.The post cleanup conditions will be much cleaner than thoseevaluated. In addition, a vegetative cover will be placedon-site to minimize dust. Therefore, in addition to thereduction of contaminant levels, the potential for theairborne transport of these contaminants will be greatlyreduced.

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