Final

OU2 Feasibility Study Report

Pohatcong Valley Groundwater Contamination Superfund Site Franklin and Greenwich Townships Warren County, New Jersey

Prepared for United States Environmental Protection Agency Region 2

New York, New York

April 2010 Revised July 2010

1717 Arch Street Suite 4400 Philadelphia, PA 19103

400098

Pohatcong Valley Groundwater Contamination Superfund Site OU2 Feasibility Study Errata to Address Omitted Pages

This errata documents changes to the Operable Unit 2 (OU2) Final Feasibility Study (FS) Report, dated April 2010. The changes noted below have been incorporated into the revised Final FS Report. The specific pages of the FS Report that have changed are attached to this errata and may be used as replacements for their respective pages in the April 2010 version of this report. Appendix A of the April 2010 version of the FS Report presented only the Potential Chemical- Specific ARARs. The Potential Action-Specific and Potential Location-Specific ARARs were prepared for the April 2010 version, but were inadvertently omitted during production of the report. This errata provides the full set of Potential ARARs for Appendix A.

Cover Page Added: “Revised July 2010”

Page x, Appendixes A Potential Location-Specific Applicable or Relevant and Appropriate Requirements Changed to: A Potential Applicable or Relevant and Appropriate Requirements

Flysheet, Appendix A Potential Location-Specific Applicable or Relevant and Appropriate Requirements Changed to: Potential Applicable or Relevant and Appropriate Requirements

Appendix A Replaced all pages

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Executive Summary

This Feasibility Study (FS) Report documents the development and evaluation of remedial action alternatives by the U.S. Environmental Protection Agency, Region 2 (EPA) for Operable Unit 2 (OU2) of the Pohatcong Valley Groundwater Contamination Site (PVGCS). The PVGCS (or Site) involves primarily trichloroethylene (TCE), and perchloroethylene (PCE), contamination of the Kittatinny Limestone Aquifer underlying the Pohatcong Valley. The Site includes portions of Washington Borough, Washington Township, Franklin Township, and Greenwich Township, in Warren County (Figure 1-1). Pohatcong Valley is a northeast-southwest trending valley that is bounded by mountains, is part of the Delaware River watershed, and is drained by Pohatcong Creek and associated tributaries. The aquifer serves as the sole source of drinking water for public water systems and private parties in the area. The entire Site area, comprising both Operable Units 1 and 2, is approximately 10 miles long by approximately 1.5 miles wide. Site Responsibility: This site is being addressed through federal, state, and county actions. The detected concentrations of chlorinated volatile organic compounds (CVOCs), specifically, TCE and PCE, in the groundwater at two public water supply wells prompted the EPA to assign the PVGCS to the National Priority List in March 1989. The PVGCS lies within Warren County, New Jersey, and consists of rural, industrial, municipal, and residential land located within the Pohatcong Valley. The site includes most of the Borough of Washington, and Washington, Franklin, and Greenwich Townships, in Warren County. Due to its size and complexity, EPA has divided the Site into three Operable Unit Study Areas, referred to as OU1, OU2, and OU3. The Operable Unit 1 (OU1) Study Area includes portions of the Borough of Washington, and Washington and Franklin Townships, with the western Study Area boundary at Asbury-Broadway Road in the Village of Broadway. As a result of detected concentrations of CVOCs in the groundwater downgradient of the original PVGCS boundary, the EPA added a second Operable Unit (OU2) to the PVGCS. This Remedial Investigation (RI) Report concerns the OU2 Study Area. The OU1 Study Area consists of approximately 8.75 square miles (5,600 acres). The OU2 Study Area, begins at the western terminus of OU1 and continues westward through portions of Franklin and Greenwich Townships. The Operable Unit 2 (OU2) Study Area consists of approximately 6.5 square miles (4,200 acres). Combined, OU1 and OU2 encompass about 15 square miles, or 9,800 acres. A third operable unit, OU3, was added to the PVGCS to fully delineate the nature and extent of contamination at the former American National Can facility, now owned by Pechiney Plastics Packaging Inc., and adjacent areas within the Borough of Washington. The OU1 RI identified source areas having contaminated soils and groundwater with elevated TCE concentrations, and groundwater with elevated PCE concentrations within

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Washington Borough. The TCE source area was identified as a former manufacturing facility known in the OU1 RI Report as American National Can. The PCE source areas were identified as two dry cleaning businesses and a former manufacturing facility, known in the OU1 RI Report as L&L Dry Cleaners, Modern Valet Service, and Tung-Sol Tubing, respectively. These source areas are contributing contaminants to the groundwater, which continue to migrate through the OU1 and OU2 Study Areas. For the most part, it appears that use of contaminated private wells was discontinued within the OU1 Study Area, and affected residences are currently connected to a public water supply. The New Jersey American Water Company owns and operates the public water supply system within the OU1 Study Area. New Jersey American Water Company treats contaminated groundwater to meet drinking water standards before it is used for the public supply. A well survey is currently underway to identify remaining residents with open residential wells within the OU1 Study Area. If any are found, EPA will assess the best method of addressing them, including connection to public water and sealing the open wells. EPA completed an OU1 RI/FS in 2005 and released the results to the public in July 2005 (CH2M HILL, 2005a and 2005b). In August 2005, EPA issued a Proposed Plan to address groundwater and source area contamination within the OU1 Study Area. EPA provided a public comment period for the Plan and subsequently issued a Record of Decision (ROD), selecting the groundwater portion of the remedy for OU1 on July 13, 2006. The selected groundwater remedy for the OU1 Study Area was documented in the OU1 ROD. The OU1 remedy outlines the treatment of contaminated groundwater in TCE and PCE hot spot areas via pumping, treatment to health based standards, and reinjection of the treated groundwater back to the aquifer. Also included is the connection of residences and businesses identified to be on private wells to the public water supply, and the sealing of open private wells. Monitored natural attenuation (MNA) will be implemented to restore the aquifer outside of the areas that are to be restored by active pumping and treatment to health based standards. The remedial designs of the OU1 ROD remedy pertaining to the OU1 PCE and TCE groundwater contamination areas were initiated in September 2006, and in September 2007, respectively. EPA is financing the PCE remedial design because no financially viable potentially responsible party is available to do the work for the PCE area. This work is being conducted by EPA with the assistance of the U.S. Army Corps of Engineers, Kansas City District. The TCE remedial design is being conducted by Pechiney Plastics Packaging Inc., under a Unilateral Administrative Order, with EPA overseeing the work with the assistance of the U.S. Army Corps of Engineers, Kansas City District. In March 2008, EPA initiated enforcement negotiations with the PRP for the conduct of the OU3 RI/FS. The purpose of the RI/FS is to fully assess the nature and extent of TCE contaminated source material and to select an appropriate remedial action in an OU3 ROD. These negotiations were terminated in September 2008, and EPA initiated a federal lead RI/FS, the first phase of which involves development of the RI/FS work plan. OU3 fieldwork is scheduled to begin in 2010. Currently, the public water supply line ends near to the western boundary of the OU1 Study Area, and the New Jersey Department of Environmental Protection (NJDEP) has provided individual point of entry treatment systems (POETS) to residences where TCE concentrations have been detected above the State drinking water standard of 1 part per

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC III 400101 EXECUTIVE SUMMARY billion (ppb). The NJDEP recommends that residents on private wells should sample their wells once a year; however, it is not clear that all residents do so. Between 2002 and 2003, the NJDEP sampled more than approximately 80 residential wells in the OU2 Study Area, downgradient of EPA's OU1 Study Area. This sampling revealed low concentrations of TCE detected above the NJDEP’s drinking water standard of 1 microgram per liter (μg/L), or ppb, in a significant number of the tested wells. Because currently the public water supply does not extend into the impacted area, the NJDEP has provided individual POETS to residences where TCE concentrations have been detected above the State drinking water standard of 1 ppb. Because of these findings, EPA initiated an OU2 RI and FS for the impacted area. Between 2006 and 2009, EPA conducted an RI in the OU2 Study Area to assess the following, and support the development of a FS and ROD:

• Nature and extent of Site related contamination in groundwater downgradient of the OU1 Study Area

• Hydraulic gradient and hydrogeologic connectivity from the OU1 to OU2 Study Areas

• Potential human health and ecological risks based on the occurrence and distribution of Site related contamination in sediment, surface water, and groundwater

• Potential sources of groundwater contamination Monitoring well drilling, and groundwater, sediment, and surface water sampling were conducted between August 14, 2007 and January 22, 2008. The specific field activities completed at the PVGCS during the OU2 Study Area investigation include potentially impacted area site visits, surface and borehole geophysical surveys, monitoring well installation and testing, groundwater sampling, surface water and sediment sampling, packer testing, as well as vapor intrusion sampling, and potable residential well water sampling, conducted by the EPA. Supporting activities included surveying, management of investigation-derived waste, management of analytical data, and landscape restoration. As part of the OU2 RI, EPA performed the following:

• Installed seven new groundwater monitoring wells

• Drilled 105 feet of overburden and 906 feet of bedrock

• Completed 2,640 feet of surface geophysics and 735 feet of subsurface geophysics

• Packer tested 12 bedrock zones;

• Collected 29 groundwater samples from monitoring wells and 204 groundwater samples from residential wells, for a total of 233 groundwater samples

• Collected approximately 23 sub-slab soil gas and 37 direct air samples from nine residences and two public buildings, including a school

• Collected six sediment and nine surface water samples

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• Disposed of 70,000 gallons of waste water and 35 drums of investigation derived solid waste

• Incorporated 667 groundwater samples collected by the NJDEP and Warren County Department of Health

• Completed removal actions at two properties to address vapor intrusion issues A surface geophysical, reflection seismic survey was performed perpendicular to the long axis of Pohatcong Valley at the OU1-OU2 Study Area boundary. This 0.5-mile-long survey included a crossing of Pohatcong Creek. The survey confirmed the location of the Karrsville Thrust Fault that had been mapped in the area by the U. S. Geologic Survey (CH2M HILL, 2009). The orientation of the Karrsville fault is sub-parallel to the Pohatcong Valley and Pohatcong Creek, and its trace is projected to extend northeastward through the OU2 Study Area and the OU1 Study Area. Within the OU1 Study Area, the fault is mapped as passing through the location of the New Jersey American Water Company Dale Avenue public supply well and along the northern border of Washington Borough. A major identified source of TCE to the regional aquifer, the former American National Can facility, is located hydraulically upgradient of the fault in the OU1 Study Area. Drilling and groundwater flow/quality testing through the fault zone at the OU1-OU2 boundary (Asbury-Broadway Road) revealed a permeable water-bearing zone that promotes migration of contaminated groundwater along the hydraulic gradient from the OU1 to OU2 Study Areas. TCE concentrations in groundwater, collected during packer testing and monitoring well sampling, reached 31 μg/L at this OU1-OU2 Study Area boundary. Groundwater flow in the OU2 Study Area portion of the regional aquifer is generally to the southwest, sub-parallel to the orientation of the Pohatcong Valley and the Karrsville fault, under a hydraulic gradient of about 0.003 feet per foot. Results of the OU2 investigation concluded that no groundwater sources were identified in the OU2 Study Area and that the Karrsville fault is the main conduit for migration of TCE from the OU1 to the OU2 Study Area. Specific concentrations of TCE within the plume immediately upgradient of the OU2 Study Area have not significantly changed between two sampling events separated by five years. This constancy of TCE concentrations confirms that the OU1/OU2 TCE plume is at or near steady-state conditions, which indicates that the attenuation rate equals the migration rate. This means that the TCE plume is not expected to significantly migrate beyond the current limits and is not expected to significantly affect additional non-impacted areas. However, it is noted that groundwater flow fluctuates on a local scale, due to natural and artificial influences, such as geology, seasonal variations in rainfall, groundwater levels, surface water, and the pumping of wells. The OU1 and OU2 RI field activities and studies encountered numerous fractures, void spaces, and cavities in the subsurface, that serve as preferential groundwater flow paths as well, which are expected to affect groundwater and contaminant migration on the local scale. Therefore, while the overall plume is at or near steady state, it is not possible to accurately predict potential future contaminant impacts to individual wells at the local level. Based on sampling conducted by the NJDEP and EPA in the OU1 and OU2 areas, involving hundreds of residential wells over several years,

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC V 400103 EXECUTIVE SUMMARY impacted wells are found immediately next to wells that are not impacted, and the groundwater flow pattern changes over time. Changes in the amount of groundwater withdrawn from the aquifer by current or new users will also locally influence the TCE migration flow path and behavior on a local scale. Changes in surface water discharge and groundwater withdrawal will similarly affect the TCE migration flow path, and on the local level may induce TCE to migrate to areas where it had previously not been detected. Therefore, due to fluctuating groundwater conditions, residents in the OU2 Study Area are either currently impacted or considered to be at risk of exposure to Site-related contaminants through contaminated well water. Ongoing sampling will need to be performed to confirm that the TCE groundwater concentrations remain at steady state conditions, and to assess impacts at the local level, over time. In March 2008, as part of the OU2 RI, EPA also performed a groundwater sampling event for residential water supply wells. The EPA collected 37 samples from 22 residential wells. Based on the results, EPA expanded the residential well sampling in 2009 to a comprehensive sampling of all residential wells in the OU2 Study Area that were not connected to NJDEP POET systems, and for which property owners granted EPA access to sample their wells. EPA mailed approximately 650 access request letters to property owners, along with Site fact sheets updating specific Site and residential sampling activities. In March 2009, 112 residential wells were sampled. An additional 61 residential wells were sampled in May 2009. Additional sampling was conducted at nine residential wells in August 2009. In total, 204 residential wells were sampled. Residential sampling is ongoing. The analytical results of both EPA’s OU2 residential sampling program, as well as residential sampling conducted by the NJDEP and Warren County Department of Health reveal that a total of approximately 100 residential water supply wells in the OU2 Study Area contain TCE concentrations above the Groundwater Quality Standard (GWQS) of 1 μg/L. Residential properties that were impacted by site contaminants above standards were referred to the NJDEP for further evaluation, which included confirmation sampling as well as the installation of POETS by the NJDEP, until EPA selects a remedy for the OU2 Study Area. Analytical results from sediment samples taken from various locations in the PVGCS area show that there were no detected concentrations of CVOCs. One detected concentration of TCE was identified in the surface water in Pohatcong Creek immediately downgradient from the Edison Quarry discharge outlet; this detection did not exceed any ecological risk screening criteria. EPA has also been concurrently conducting phased vapor intrusion evaluations at selected buildings, houses, and schools within both the OU1 and OU2 Study Areas. Vapor intrusion sampling was conducted in multiple phases to assess the potential that CVOCs in the groundwater contaminant plume are volatilizing into the soil gas and migrating to the ground surface or potentially accumulating under or in buildings. The vapor intrusion sampling was conducted in multiple phases, and is still ongoing. Sub-slab and indoor air samples were collected in select public and private buildings. The analytical results were screened against the EPA’s draft interim soil gas values developed for TCE and PCE, of 5 μg/m3 and 100 μg/m3, respectively in the OU2 Study Area. For one public school and two residential structures, a number of the sub-slab and several of the indoor air sample results exceeded EPA’s draft criteria for TCE, a Site related volatile organic compound (VOC).

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As a result, the buildings were remediated to address the volatile vapors through three removal actions, where EPA installed vapor mitigation systems. EPA will perform specific human health risk assessments (HHRAs) in the future, on a case-by-case basis as well, for all three Site operable units, on an ongoing basis. The HHRA evaluated the hazards and risks associated with exposures to groundwater, surface water, and sediment. The following conclusions were reached. The HHRA identified a cancer risk from exposure to site-related contaminants of TCE and PCE in the groundwater exceeded the lower end of the acceptable risk range of 10-6, which is also known as the “point of departure”; however, the cancer risks were below the upper- bound of the acceptable EPA risk range of 10-4. In cases where exposures exceed the point of departure, additional information can be evaluated to determine if a remedial action is warranted. For OU2 at Pohatcong Valley, the concentrations associated with the groundwater plume exceed the NJDEP GWQS, which would be considered applicable or relevant and appropriate requirements (ARARs) for the site. In this case, TCE concentrations were detected in domestic drinking water wells at concentrations above the NJDEP GWQS of 1 μg/L. Given that the point of departure is exceeded, as well as state promulgated criteria, a remedial action was deemed to be warranted to reduce the potential risks and hazards from drinking water contaminated with site-related compounds above acceptable drinking water criteria. These findings indicate that action is necessary by EPA to undertake remedial measures to reduce the risks associated with the site-related contamination in groundwater and restore the groundwater to beneficial use. Non-cancer risks were also identified in the HHRA, but are associated with non site-related naturally occurring inorganics, such as iron. These results are summarized in the HHRA, which is part of the RI report. The RI Report has been used to develop remedial alternatives for impacted groundwater within the OU2 Study Area. The FS focused on identifying remedial technologies and alternatives to mitigate the on-going groundwater source and continued degradation of the TCE groundwater plume. Based on the TCE detected in groundwater, remedial action objectives (RAOs) were developed for protecting human health and the environment and the currently and potentially threatened resources. For groundwater, the RAOs are as follows. 1. Prevent or minimize the current and future human exposures, including ingestion of groundwater, from Site related VOCs in groundwater that present a risk to public health and the environment. 2. Minimize the further migration of Site related VOCs in groundwater. 3. Restore the aquifer to meet drinking water standards within a reasonable timeframe. To meet the RAOs for the OU2 Study Area, ARARs were developed to aid in defining the extent of contaminated media requiring remedial action. The ARARs were used to establish media-specific concentrations of TCE that will pose no unacceptable risk to human health and the environment. After an evaluation of applicable cleanup standards and potential risk pathways of contamination in groundwater, EPA has chosen 1 μg/L (1 ppb) for TCE. This is consistent with the NJDEP standards, specifically the GWQS for groundwater.

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The area of groundwater contamination with TCE exceeding 1 μg/L (1 ppb) encompasses about 2,050 acres and extends approximately 28,000 feet downgradient from the OU1/OU2 Study Area boundary. At the upgradient edge of the OU2 Study Area, the depth to the regional water table is approximately 30 feet below ground surface. Viable remedial technologies and process options for groundwater were screened to assemble a large range of remedial alternatives. A series of five groundwater alternatives (plus the no further action alternative) were initially developed and screened for overall implementability, effectiveness, and cost. After the initial screening, five groundwater alternatives were retained for a detailed evaluation against the seven National Contingency Plan (NCP) evaluation criteria. An additional groundwater alternative, Entire Plume Collection and Treatment, was developed, but screened out since it was considered to be potentially ineffective, impractical, or not cost-effective during implementation. The Entire Plume Collection and Treatment Alternative (Alternative 4), which included high-yield pumping wells over the length of the OU2 Study Area, was determined to be ineffective due to potential natural resource injury to local water bodies, potential short-term impacts to private wells, the effectiveness of capture of the entire groundwater impact, and the high cost for implementation, operations, and maintenance of the treatment system. The following remedial alternatives for groundwater were retained for evaluation in the FS:

• 1 – No Action • 2a –MNA, Institutional Controls, and Private Well Head Treatment • 2b - MNA, Institutional Controls, and Public Water Supply Connection • 3a - In Situ Treatment, Private Well Head Treatment, and MNA • 3b - In Situ Treatment, Public Water Supply Connection, and MNA The NCP evaluation criteria were used to evaluate the retained groundwater alternatives. The evaluation criteria are:

• Overall protection of human health and the environment • Compliance with ARARs • Long-term effectiveness and permanence • Reduction of toxicity, mobility, or volume through treatment • Short-term effectiveness • Implementability • Cost The additional two modifying criteria (Community Acceptance and State Acceptance) are to be evaluated following public comment period and may be used to change the selection of the recommended alternative. Ultimately, the EPA, in consultation with the NJDEP and with input from the public, will use this information to select a remedial action alternative for the OU2 Study Area. The selected alternative will be formally defined in a ROD document in accordance with the NCP.

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Contents

1.0 Introduction ...... 1-1 1.1 Purpose and Organization of Report ...... 1-1 1.2 Site Description ...... 1-2 1.3 Site Geology and Hydrogeology ...... 1-3 1.4 Groundwater Use ...... 1-4 1.5 Nature and Extent of Contamination ...... 1-4 1.6 Contaminant Fate and Transport ...... 1-6 1.7 Ecological and Human Health Risk Assessments ...... 1-7 1.7.1 Ecological Risk Assessment Conclusions ...... 1-7 1.7.2 Human Health Risk Assessment Conclusions ...... 1-7 1.8 Conceptual Site Model ...... 1-8 2.0 Development and Identification of ARARs and RAOs ...... 2-1 2.1 Summary of Applicable or Relevant and Appropriate Requirements ...... 2-1 2.1.1 Chemical Specific ARARs ...... 2-2 2.1.2 Action Specific ARARs ...... 2-2 2.1.3 Location Specific ARARs ...... 2-3 2.2 Remedial Action Objectives ...... 2-3 2.2.1 RAOs for Groundwater ...... 2-3 2.3 Site-Specific ARARs ...... 2-4 2.4 Contaminated Media Exceeding ARARs ...... 2-4 2.4.1 Groundwater ...... 2-4 3.0 Identification and Screening of Technologies ...... 3-1 3.1 General Response Actions ...... 3-1 3.1.1 General Response Actions for Groundwater ...... 3-1 3.2 Technology Screening Methodology ...... 3-3 3.3 Technology Screening for Groundwater Media ...... 3-4 4.0 Development of Alternatives ...... 4-1 4.1 Development of Groundwater Media Remedial Alternatives ...... 4-1 4.1.1 Description of Alternatives ...... 4-1 4.2 Initial Screening of Alternatives ...... 4-10 4.2.1 Initial Screening of Groundwater Alternatives ...... 4-10 5.0 Detailed Analysis of Alternatives ...... 5-1 5.1 Introduction ...... 5-1 5.2 Evaluation Criteria ...... 5-1 5.2.1 Threshold Criteria ...... 5-2 5.2.2 Balancing Criteria ...... 5-3 5.3 Detailed Analysis of Groundwater Media Alternatives ...... 5-4 5.3.1 Detailed Evaluation ...... 5-4 5.3.2 Comparative Analysis ...... 5-5 6.0 References ...... 6-1

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Tables 3-1 Identification of General Response Actions for Groundwater 3-2 Technology/Process Option Evaluation - Groundwater 4-1 Groundwater Remedial Alternatives Retained for Further Evaluation 5-1 Detailed Evaluation of Groundwater Media Alternatives Figures 1-1 Location of the OU1/OU2 Study Areas 1-2 OU2 Study Area 2-1 Trichloroethene Plume Map 4-1 POET Diagram 4-2 Alternative 2a - MNA, Institutional Controls, and Private Well Head Treatment 4-3 Alternative 2b - MNA, Institutional Controls, and Public Water Supply Connection 4-4 Alternative 3a - In Situ Treatment, Private Well Head Treatment, and MNA 4-5 Alternative 3b – In Situ Treatment, Public Water Supply Connections, and MNA 4-6 Ex-Situ Treatment Components Appendixes A Potential Applicable or Relevant and Appropriate Requirements B Natural Attenuation Calculations C Rough Order of Magnitude Costs – Groundwater Alternative 4 D Detailed Cost Tables of Remedial Alternatives

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Acronyms and Abbreviations

ARAR applicable or relevant and appropriate requirement bgs below ground surface CEA Classification Exception Area CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CVOC chlorinated volatile organic compound EPA U.S. Environmental Protection Agency EQU Edison Quarry FS Feasibility Study gpm gallons per minute GWQS groundwater quality standard HHRA human health risk assessment ISO in situ oxidation μg/L microgram per liter μg/m3 microgram per cubic meter MNA monitored natural attenuation NCP National Contingency Plan NJDEP New Jersey Department of Environmental Protection O&M operation and maintenance OU1 Operable Unit 1 OU2 Operable Unit 2 OU3 Operable Unit 3 PCE perchloroethylene POETS point of entry treatment system POTW publicly owned treatment works ppb parts per billion PSA potential source area PVGCS Pohatcong Valley Groundwater Contamination Site QUA Quarry Road RAO remedial action objective RCRA Resource Conservation and Recovery Act RI Remedial Investigation ROD Record of Decision TBC to be considered

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TCE trichloroethylene TMV toxicity, mobility or volume USGS U. S. Geologic Survey VOC volatile organic compound WRA well restriction area

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1.0 Introduction

1.1 Purpose and Organization of Report This Feasibility Study (FS) Report documents the development and evaluation of remedial action alternatives for Operable Unit 2 (OU2) of the Pohatcong Valley Groundwater Contamination Site (PVGCS), Figures 1-1 and 1-2. OU2 for the PVGCS, also known as the OU2 Study Area, has been defined as the spatial area with the groundwater contaminant trichloroethylene (TCE) in excess of the federal maximum contaminant limit of 5 micrograms per liter (μg/L) and the New Jersey Department of Environmental Protection (NJDEP) Groundwater Quality Standards (GWQS) of 1 μg/L. This FS was prepared for the U.S. Environmental Protection Agency (EPA) in accordance with Work Assignment No. 937-RI-CO-023J under RAC Contract Number 68-W6-0036. The EPA, in consultation with the NJDEP, and with public input, will use this information to select a remedial action alternative in its Record of Decision (ROD) in accordance with the National Contingency Plan (NCP). The criteria for remedy selections under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) require that Superfund remedial actions satisfy the following requirements.

• Protect human health and the environment;

• Comply with applicable or relevant and appropriate requirements (ARARs) of federal and state environmental laws within a reasonable time frame;

• Be cost-effective;

• Use permanent solutions and alternative treatment technologies to the maximum extent practicable; and

• Satisfy the preference for treatment that reduces contaminant toxicity, mobility, or volume (TMV). As described in the EPA Remedial Investigation/Feasibility Study (RI/FS) guidance document (EPA, 1988a) and in the National Oil and Hazardous Substances Contingency Plan (EPA, 1990), the FS consists of three phases: the development of remedial alternatives, the screening of alternatives, and the detailed analysis of selected alternatives. The following steps were used in developing the remedial alternatives for the PVGCS.

• Identify ARARs • Develop remedial action objectives (RAOs) • Define remedial action goals, including: − Developing chemical-specific ARARs and human health- and ecological-based risk levels

− Identifying areas of contamination exceeding ARARs

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• Develop general response actions • Identify and screen technologies (including innovative technologies) • Identify and evaluate technology process options • Assemble remaining process options into remedial alternatives • Evaluate the remedial alternatives in accordance with the NCP This report consists of six sections. Section 1 provides an introduction and summarizes background information, such as site physical description, site geology and hydrogeology, nature and extent of contamination, contaminant fate and transport, summary of human health and ecological risks, and an overall conceptual site model. The ARARs and RAOs that are intended to provide adequate protection of human health and the environment are discussed in Section 2. Chemical-specific remedial goals were developed for groundwater based on: 1) the risk associated with the various concentrations of contaminants in those media, 2) ARARs, and 3) background concentrations, where applicable. Section 3 presents the developed general response actions that address remedial action goals and introduces the identification and screening of the technology types and process options. Remedial technologies were screened to reduce the number of technologies considered in the detailed alternatives. Section 4 presents the assembly of the remaining technologies into groundwater remedial action alternatives that achieve some or all of the remedial action goals, and provide a range of levels of remediation and a corresponding range of costs. Section 4 also includes an initial screening of alternatives for general effectiveness, practicability, and cost-effectiveness during implementation. A detailed analysis of these groundwater alternatives retained after the initial screening is presented in Section 5. Section 6 includes references used during the preparation of this FS.

1.2 Site Description The Pohatcong Valley is located in the New Jersey Highlands Physiographic Province and is one of a series of northeast/southwest trending valleys in the area that are separated by similarly trending mountains. In the overall Study Area (OU1 and OU2), the Pohatcong Valley is bounded by the Scotts, Oxford, and County House Mountain chain on the northwest side and by the Pohatcong and Upper Pohatcong Mountain chain on the southeastern side. The northeastern portion of the valley terminates about 5 miles northeast of Washington Borough where Upper Pohatcong Mountain joins with County House Mountain. The southwestern portion of Pohatcong Valley extends about 15 miles from Washington Borough to the Delaware River. Approximately 8 miles along this route to the Delaware River, the carbonate bedrock of the Pohatcong Valley, the Lopatcong Valley, and the Musconetcong Valley are in contact with each other. The ground surface of the Pohatcong Valley slopes to the southwest. The elevation of the Valley floor ranges from about 520 feet in the northeastern portion of the site to about 300 feet in the southwestern portion of the site. The surrounding mountains rise dramatically from the Valley floor to elevations greater than 800 feet for Pohatcong Mountain and greater than 1,000 feet for Scott Mountain. The Pohatcong Creek and its tributaries are the main surface water features that drain surface water from the valley. The Pohatcong Creek originates near Karrsville, New Jersey and flows to the southwest, ultimately discharging to the Delaware River. Tributaries

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1.3 Site Geology and Hydrogeology The geology across the PVGCS is highly variable given the nature of the overburden deposits and the bedrock, and the large areal extent over which the RI activities were conducted. Given this variability across the site, the site geology is summarized from information gathered from the surface geophysical survey, monitoring well installations, a review of the regional geologic information, and the OU1 Study Area and presented below as a general overview of the geologic conditions. The generalized geology at the PVGCS consists of overburden deposits and bedrock. A geophysical seismic survey was conducted along the Asbury-Broadway Road (ABR) in the upgradient portion of the OU2 Study Area to confirm the location and nature of the Karrsville fault, which was mapped along the center of Pohatcong Valley. The results from the geophysical survey confirms that there is a fault that dips to the southeast and that the near surface expression of the fault was coincident with the location of Pohatcong Creek, suggesting that the creek may be roughly following the fault trace in the OU2 Study Area. The fault is not one, single feature, but is comprised of several parallel and sub-parallel fractures and faults that create a fracture zone in the bedrock. Preferential dissolution of the limestone and dolomite bedrock in this fracture zone would create local subsidence of the overburden, which may influence the course of a surface water feature, such as Pohatcong Creek. This preferential dissolution would also create a highly permeable groundwater conduit connecting the OU1 Study Area and the Dale Avenue public water supply well with other downgradient areas in the OU2 Study Area.

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Groundwater was encountered primarily in the bedrock at the OU2 Study Area, while overburden groundwater was encountered in some localized areas such as PVABR02. Regional groundwater is generally encountered in the overburden and bedrock at a depth of approximately 100 feet below ground surface (bgs) in the OU1 source area (at facilities in Washington Borough) and at a depth of approximately 30 feet bgs in the upgradient portion of the OU2 Study Area. Groundwater in the regional aquifer generally flows to the southwest. Potable water supplies in the PVGCS are derived from the regional bedrock aquifer. A more detailed summary of the site geology and hydrogeology for the OU2 Study Area is included in the Operable Unit 2 (OU2) Remedial Investigation Report (CH2M HILL, 2009).

1.4 Groundwater Use Groundwater in the Pohatcong Valley occurs mainly in the sedimentary limestone and dolomite (carbonate) rocks underlying the Valley. Karstic development in these carbonate rocks increases the porosity and permeability of the aquifer beneath the Valley. The groundwater in the Valley is used by residential and commercial properties as a source of potable drinking water and by industrial facilities as a source of cooling and process water. A majority of the potable water supply in the OU2 Study Area is supplied through private residential wells. After identification of contaminated groundwater in the OU1 Study Area, the residences within Washington Borough were required to connect to public water and to abandon their residential wells. Based on the potential extent of groundwater impacts, as defined by the NJDEP Well Restriction Area, the public water line was extended from Washington Borough to the village of Broadway. Broadway represents only a small upgradient portion of the OU2 Study Area, the remaining portion of OU2 is not connected to the public water supply. Through 2008, approximately 180 private wells in the OU2 Study Area have been sampled by the NJDEP and 84 found to be contaminated with TCE in excess of the NJDEP GWQS. NJDEP installed point of entry treatment systems (POETS) at private wells found with TCE exceedances. The EPA conducted residential sampling in March 2008 (22 residential wells), March 2009 (112 residential wells), May 2009 (61 residential wells), and August 2009 (9 residential wells) in the OU2 Study Area, and continue to conduct residential well sampling.

1.5 Nature and Extent of Contamination Remedial investigation activities in the OU2 Study Area were conducted:

• To evaluate the nature and extent of Site related contamination in groundwater downgradient of the OU1 Study Area;

• To assess the hydraulic gradient and hydrogeologic connectivity from the OU1 to OU2 Study Areas;

• To estimate the potential human health and ecological risks based on the occurrence and distribution of Site related contamination in sediment, surface water, and groundwater; and

• To identify and investigate potential sources of groundwater contamination.

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As most of the land use in the OU2 Study Area is agricultural and residential, there were a limited number of industrial and commercial sites compared to the OU1 Study Area. A thorough search for potential source areas (PSAs) in Pohatcong Valley was conducted during the planning stages of the OU1 RI, including areas with the OU2 Study Area. Two PSAs (Victaulic Corporation of America [VCA] and the former Edison Quarry [EQU]) were identified in the OU2 Study Area and were investigated during the OU1 RI. Of these, the OU1 RI identified VCA as a potential contributor of TCE and other chlorinated volatile organic compounds (CVOCs) to the regional groundwater, and therefore required subsequent follow-up investigation activities. Two groundwater samples collected from the VCA property had TCE groundwater concentrations ranging from 5 to 8 μg/L. In addition, two soil samples collected from the VCA property had CVOCs at concentrations 15,000 times below the NJDEP Soil Cleanup Criteria; however, TCE was not detected in the soil samples. As part of the OU2 RI planning phase, one additional PSA was identified for investigation during OU2 RI activities. This PSA, known as the T&M Pallet Company (TPC), is located immediately adjacent to the VCA property. The OU2 RI fieldwork utilized a phased approach, with the installation of one groundwater monitoring well located hydraulically downgradient of both the VCA and the TPC properties to assess if these PSAs were contributing CVOC contamination to the regional aquifer. The groundwater monitoring well installed hydraulically downgradient from these PSAs in the OU2 Study Area did not contain TCE or other CVOCs, eliminating the potential that they are major TCE sources within the OU2 Study Area. As a result of this phased approach, follow-up investigations, soil borings, and soil samples were not collected from identified PSAs during the OU2 RI. The Karrsville fault was identified as a permeable conduit for migration of groundwater containing TCE from the upgradient OU1 Study Area through the OU2 Study Area. The fault trace intersects the Dale Avenue public water supply well, which continues to be contaminated with TCE above the NJDEP GWQS, and extends toward near the former American National Can facility, which was identified as the source area for TCE groundwater contamination in the OU1 Study Area. Monitoring wells and residential water supply wells located close to the fault trace have a higher likelihood of containing TCE than wells installed further away from the fault trace. The relationship between location relative to the fault trace and the TCE concentrations is also noted in the vapor intrusion sampling results. Vertically, TCE concentrations show some variability based on interconnection of the fractures in the fault zone. Based on the ABR wells, some fracture zones that are not actively pumped have no TCE while these same fracture zones show TCE when actively pumped. For zones that are actively pumped, the TCE concentrations were consistent and no vertical trend in concentration was noted. This vertical distribution of TCE concentrations and the interconnectedness of the fractures explains the analytical results from the residential water supply wells where one well may have TCE concentrations and an adjacent well may have lower (or no) TCE concentrations. Analytical results from the Quarry Road (QUA) well appear to confirm that the VCA facility, a former PSA in the OU2 Study Area, is no longer suspected of contributing TCE to the regional groundwater.

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Concentrations of volatile organic compounds (VOCs) decreasing over distance downgradient of the OU1 Study Area indicates that there are most likely no other source areas in the OU2 Study Area, and that CVOCs in groundwater in the OU2 Study Area migrated from the OU1 Study Area. Surface water and sediment samples were also collected from along Pohatcong Creek during the OU2 RI activities and the results indicate that no TCE was detected in the sediment. One detection of TCE was identified in the surface water in Pohatcong Creek immediately downgradient from the EQU discharge outlet, at 1.2 μg/L.

1.6 Contaminant Fate and Transport A fate and transport analysis of contaminants was conducted to evaluate how the identified contaminants degrade and where these contaminants may travel. The fate and transport analysis focused on discussing the contaminant characteristics, including natural attenuation mechanisms, and evaluating potential routes of migration along with the anticipated duration of the contamination in the environment. Details of the contaminant fate and transport within the OU2 Study Area are also included in the OU2 Remedial Investigation Report (CH2M HILL, 2009). The focus of the OU2 RI was to evaluate if the presence of TCE in groundwater at the OU2 Study Area stems from a separate source than the OU1 Study Area or to evaluate if chlorinated solvents from the OU1 Study Area migrated downgradient to the OU2 Study Area. The following conclusions regarding the fate and transport of TCE in groundwater can be made based on the results of the OU2 RI:

• TCE is the contaminant of potential concern at the OU2 Study Area;

• Dissolved concentrations of TCE migrated in groundwater to the OU2 Study Area from a TCE source in the OU1 Study Area;

• The OU2 TCE plume exhibits Type III behavior in that the aquifer receives recharge from meteoric waters and concentrations of dissolved oxygen are near saturation conditions (i.e., aerobic). Under aerobic conditions, reductive dechlorination will not occur, or is relatively inefficient. Additionally, chlorinated transformation products such as cis-1,2 dichloroethene and trans 1,2 dichloroethene are either absent or are present at isolated locations such as PVABR01 and PVABR03;

• A comparison of analytical results from 2002 to 2007 indicate that the TCE plume is at a steady state for this five year period;

• Based on an evaluation of geochemical parameters and the lack of chlorinated transformation products, natural attenuation is not occurring through chemical or biochemical processes in the OU2 Study Area, but rather through advection, dispersion, and sorption.

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1.7 Ecological and Human Health Risk Assessments

1.7.1 Ecological Risk Assessment Conclusions The Ecological Risk Assessment focused on further evaluating risks associated with CVOCs in the OU2 Study Area of the PVGCS. The following conclusions were derived from the conduct of this ERA:

• Potentially complete exposure pathways exist at this site for benthic macroinvertebrates and aquatic life.

• TCE was the only CVOC detected in Pohatcong Creek surface water, but the detected concentrations remained below the ecological screening values for this chemical. It is therefore concluded there is no current potential for adverse effect to aquatic life from the presence of CVOCs in Pohatcong Creek.

• VOCs in the groundwater do not present a potential risk to aquatic life if they should discharge to surface water.

1.7.2 Human Health Risk Assessment Conclusions The Human Health Risk Assessment (HHRA) evaluated the hazards and risks associated with exposures to groundwater, surface water, and sediment at the PVGCS OU2. Exposure to surface water and sediment in Pohatcong Creek, Merrill Creek, and EQU while wading by current/future recreational youth and adults would result in noncarcinogenic hazards and carcinogenic risks within EPA’s target levels. Non-carcinogenic hazards associated with potable use of the regional aquifer groundwater for the residential and industrial scenarios exceed EPA target risk levels. The non- carcinogenic hazard to the adult and child resident, and industrial worker is primarily associated with ingestion of thallium, which contributes a hazard quotient above 1 for the child and adult resident. For the child resident, ingestion of arsenic, cobalt, iron, and manganese also contribute hazard quotients above 1. The central tendency exposure noncarcinogenic hazard to the adult and child resident and industrial worker also exceed EPA’s target levels. Comparison of residential well data to state standards showed that TCE concentrations in approximately 100 residential wells exceeded the NJDEP GWQS of 1 μg/L. The HHRA identified a cancer risk from exposure to site-related contaminants of TCE and perchloroethylene (PCE) in the groundwater that were below the upper-bound of the acceptable EPA risk range of 10-4, however, the cancer risks exceeded the lower end of the acceptable risk range of 10-6, which is also known as the “point of departure”. In cases where exposures exceed the point of departure, additional information can be evaluated to determine if a remedial action is warranted. For OU2 at Pohatcong Valley, the concentrations associated with the groundwater plume exceed both the state and federal maximum contaminant limits, which would be considered ARARs for the site. In this case, TCE concentrations were detected in domestic drinking water wells at concentrations above the NJDEP GWQS of 1 μg/L.

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Given that the point of departure is exceeded, as well as state promulgated criteria, a remedial action was deemed to be warranted to reduce the potential risks and hazards from drinking water contaminated with site-related compounds above acceptable drinking water criteria. These findings indicate that action is necessary by EPA to undertake remedial measures to reduce the risks associated with the site-related contamination in groundwater and restore the groundwater to beneficial use. Non-cancer risks were also identified in the HHRA, but are associated with non site-related naturally occurring inorganics, such as iron, and these risks are not considered to be the risk drivers for the site.

1.8 Conceptual Site Model Trichloroethene groundwater concentrations are found throughout the OU2 Study Area and are detected at higher concentrations in wells installed close to the trace of the Karrsville fault. The Karrsville fault is roughly parallel to the trend of Pohatcong Valley and extends from the OU1 Study Area, where it runs near the identified OU1 TCE source area and intersects the Dale Avenue public water supply well, through the OU2 Study Area. Multiple fractures and small faults associated with the Karrsville fault create a permeable conduit that allows for the preferential migration of groundwater and TCE groundwater concentrations from the OU1 Study Area to the OU2 Study Area. Natural attenuation of the TCE groundwater concentrations through physical attenuation act to degrade and disperse the TCE concentrations. When operating, public and private water supply wells (e.g., Dale Avenue Well and multiple domestic wells) installed in the regional aquifer recover a portion of the TCE-contaminated groundwater, resulting in TCE detections in the wells. Volatilization of TCE in the groundwater can result in TCE vapors migrating to the ground surface and, where there are buildings, accumulating under concrete building slabs and in basements. Direct correlation of locations with elevated TCE groundwater concentrations and elevated TCE soil vapor concentrations in the OU2 Study Area were confirmed based on sampling data. There is also a migration potential from the groundwater in the OU2 Study Area to be discharged to the surface water (e.g., Pohatcong Creek and EQU).

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2.0 Development and Identification of ARARs and RAOs

2.1 Summary of Applicable or Relevant and Appropriate Requirements Remedial actions must be protective of public health and the environment. Section 121 of CERCLA requires that primary consideration be given to remedial alternatives that attain or exceed ARARs. The purpose of this requirement is to make CERCLA response actions consistent with other pertinent federal and state environmental requirements, as well as to adequately protect public health and the environment. Definitions of the ARARs and the “to be considered” (TBC) criteria are given below:

• Applicable requirements are those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that directly and fully address a hazardous substance, pollutant, contaminant, environmental action, location, or other circumstance at a CERCLA site.

• Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law, which while not “applicable,” address problems or situations sufficiently similar (relevant) to those encountered at a CERCLA site, that their use is well suited (appropriate) to the particular site.

• TBC criteria are non-promulgated, non-enforceable guidelines or criteria that may be useful for developing an interim remedial action, or are necessary for evaluating what is protective to human health and/or the environment. Examples of TBC criteria include the NJDEP GWQS, defined as N.J.A.C. 7:9C, as well as the EPA Drinking Water Health Advisories, Reference Doses, and Cancer Slope Factors. Another factor in determining which requirements must be addressed is whether the requirement is substantive or administrative. “Onsite” CERCLA response actions must comply with the substantive requirements but not with the administrative requirements of environmental laws and regulations as specified in the NCP, 40 CFR 300.5, definitions of ARARs and as discussed in 55 FR 8756. Substantive requirements are those pertaining directly to actions or conditions in the environment. Administrative requirements are mechanisms that facilitate the implementation of the substantive requirements of an environmental law or regulation. In general, administrative requirements prescribe methods and procedures (e.g., fees, permitting, inspection, and reporting requirements) by which substantive requirements are made effective for the purposes of a particular environmental or public health program.

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ARARs are grouped into three types: chemical-specific, location-specific, and action-specific. Included in Appendix A are the chemical-specific, action-specific, and location-specific ARARs for the PVGCS OU2 Study Area.

2.1.1 Chemical Specific ARARs Chemical-specific ARARs include laws and requirements that establish health- or risk- based numerical values or methodologies for environmental contaminant concentrations or discharge. The chemical-specific ARARs for the OU2 Study Area can be classified into two categories: 1. Residual concentrations of compounds that can remain at the site after treatment without presenting a threat to human health and the environment; and 2. Land disposal restriction concentrations that must be achieved if the contaminated media that either is a characteristic hazardous waste or contains a listed hazardous waste is excavated or extracted and later land disposed. In addition, effluent concentrations that must be achieved in treatment of groundwater for discharge are also considered as chemical-specific ARARs.

2.1.1.1 Cleanup Standards Potential ARARs or TBC for groundwater include, the Safe Drinking Water Act maximum contaminant limits, the NJDEP GWQS (N.J.A.C. 7:9-6), and the New Jersey Secondary Drinking Water Standards (N.J.A.C. 7:10-7).

2.1.1.2 Land Disposal Restriction Concentrations The Resource Conservation and Recovery Act (RCRA) land disposal restrictions would apply to remedial actions performed at the site if waste generated by the remedial action (e.g., spend carbon used for groundwater treatment) contains a RCRA hazardous waste. Listed hazardous wastes as defined by RCRA regulation are not known to have been released at the site. As a result, any media used to treat contaminated groundwater would not be required to be managed as listed hazardous wastes. Generated materials that exceed the Toxicity Characteristic Leaching Procedure limit must be managed as a hazardous waste and must meet the Land Disposal Restriction Treatment Standards (40 CFR 268.49). The treatment standard is the higher value of a 90 percent reduction in constituent concentrations or 10 times the Universal Treatment Standards. Treatment is required for the constituent (such as TCE) for which the material is a characteristic hazardous waste as well as other “underlying hazardous constituents”. Generators can apply reasonable knowledge of the likely contaminants present to select constituents for monitoring (EPA, 1998a).

2.1.2 Action Specific ARARs Action-specific ARARs regulate the specific type of action or technology under consideration, or the management of regulated materials. The most important action- specific ARARs that may affect the RAOs and the development of remedial action alternatives for the OU2 Study Area is the Clean Water Act and NJDEP regulations. Any remedial alternative that generates contaminated groundwater will need to be treated and

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2.1.3 Location Specific ARARs Location-specific ARARs are requirements that relate to the geographical position of the site. State and federal laws and regulations that apply to the protection of wetlands, construction in floodplains, and protection of endangered species in streams or rivers are examples of location-specific ARARs.

2.2 Remedial Action Objectives The EPA Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites (EPA, 1988b) and the NCP define RAOs as medium-specific or site-specific goals for protecting human health and the environment. These goals are established based on the nature and extent of the contamination, the resources that are currently and potentially threatened, and the potential for human and environmental exposure. Remediation goals are site-specific, quantitative goals that define the extent of cleanup required to achieve the RAOs. In this section, the RAOs have been developed for impacted groundwater within the OU2 Study Area. RAOs have been based on the exposure pathways found to present unacceptable risks during the HHRA.

2.2.1 RAOs for Groundwater Based on data collected during the OU2 RI, the compound that is the focus of the OU2 FS is the TCE detected in groundwater. The TCE plume extends southwestward from the OU1 Study Area into the OU2 Study Area near ABR. The highest concentration of TCE in the OU2 Study Area is 31μg/L at the ABR well location. The focus will be to reduce risks in the OU2 Study Area and residential homes using groundwater for potable purposes. The RAOs for remediation of groundwater at OU2 include the following:

• Prevent or minimize the current and future human exposures, including ingestion of groundwater, from Site related VOCs in groundwater that present a risk to public health and the environment;

• Minimize the further migration of Site related VOCs in groundwater; and

• Restore the aquifer to meet drinking water standards within a reasonable timeframe.

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2.3 Site-Specific ARARs To meet the RAOs for the OU2 Study Area, ARARs utilized within this FS are the NJDEP GWQS. For this site, EPA has selected the GWQS of 1 μg/L (1 part per billion [ppb]) for TCE to be used as an ARAR.

2.4 Contaminated Media Exceeding ARARs Below is a discussion of the areas of groundwater exceeding the ARARs within the OU2 Study Area.

2.4.1 Groundwater Figure 2-1 depicts the area within the OU2 Study Area with TCE concentrations exceeding the NJDEP GWQS. This area encompasses approximately 2,050 acres and extends approximately 28,000 feet downgradient from the OU1/OU2 Study Area boundary. The ABR site was selected to evaluate the presence of the Karrsville Thrust Fault. A monitoring well (PVABR01) was installed in a highly fractured portion of the bedrock near the Karrsville Thrust Fault based on USGS mapping information, an evaluation of the RI seismic reflection survey, and well installation boring logs. The exceedance of TCE in this monitoring well along with the fact that there are no likely source areas near the well confirms that the Karrsville Thrust Fault is serving as a preferential pathway for contaminants to migrate from source areas in the OU1 Study Area to the OU2 Study Area.

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3.0 Identification and Screening of Technologies

3.1 General Response Actions Identifying general response actions - basic actions that might be undertaken to remediate a site - is the first step in the alternatives analysis process. For each general response action, several possible remedial technologies may exist and can be further broken down into a number of process options. These technologies and process options are then screened based on several criteria. Technologies and process options remaining after screening are assembled into alternatives in Section 4. The following sections present general response actions that may be applicable to the OU2 Study Area.

3.1.1 General Response Actions for Groundwater The general response actions applicable to groundwater contaminated with CVOCs above ARARs are:

• No Action • Monitoring • Institutional Controls • Private Well Treatment or Public Water Supply Connection • Monitored Natural Attenuation (MNA) • Containment • In Situ Treatment • Extraction, Treatment, and Discharge Table 3-1 lists general response actions applicable to the contaminated groundwater and provides a brief evaluation of each. The following sections describe general response actions that may be applicable to the OU2 Study Area. Each general response action is discussed below along with an overview of associated remedial technologies and process options that are representative of the response action.

3.1.1.1 No Action The no action response includes no action for groundwater. This alternative is retained through the FS process as a basis of comparison in accordance with the NCP. 3.1.1.2 Monitoring Monitoring can be implemented in combination with other general response actions such as containment or treatment to monitor the effectiveness of the chosen remedial action over the course of time. Long-term monitoring is also an important component of the MNA response action to document concentration reductions over time. Monitoring may include inspections as well as sampling and analysis of groundwater.

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3.1.1.3 Institutional Controls Institutional controls for groundwater include restrictive covenants that limit the potential future use of impacted groundwater. In New Jersey, the restrictive covenants are referred to as a Classification Exception Area (CEA). The CEA must include the area of impacted groundwater, the potential area of groundwater that may be impacted before completion of remedial actions, the contaminants and concentrations within the area, and an estimated duration of the CEA. Continued groundwater monitoring may also be necessary to track the direction and rate of movement of the groundwater contaminant plume as part of the institutional controls. Other institutional controls include measures such as local ordinances, building permits, and state registries of contaminated sites. The institutional controls would specify the nature and extent of the groundwater contamination and prevent use until the groundwater contamination returns to drinking water standards.

3.1.1.4 Private Well Treatment or Public Water Supply Connection This general response action is either providing treatment of existing privately owned wells in the OU2 Study Area or providing a public water supply connection to homes within the OU2 Study Area.

3.1.1.5 Monitored Natural Attenuation Natural attenuation is the process by which contaminant concentrations are reduced by various naturally occurring physical, chemical, and biological processes. The main processes include biodegradation, dispersion, dilution, sorption, volatilization, and chemical or biological stabilization, transformation, or destruction of contaminants, which occur to varying degrees at every site affected, especially at sites with chlorinated solvents. These processes occur naturally, in situ, and act to decrease the mass or concentration of contaminants in the subsurface. Only non-augmented natural processes are relied upon under this general response action. Augmentation through addition of electron acceptors or nutrients is considered an in situ treatment technology. The natural attenuation mechanisms in the OU2 Study Area were evaluated (EPA, 1998b).

3.1.1.6 Containment Containment refers to minimizing the spread of groundwater contaminants through passive hydraulic gradient controls. Passive gradient control can be achieved using a slurry, sheet- pile walls, or passive pumping to control hydraulic gradients. Containment of groundwater can be effective in preventing the release of contaminants from the source areas and their subsequent migration.

3.1.1.7 In Situ Treatment In situ treatment of groundwater entails treating the groundwater in the aquifer, which can be achieved by applying physical/chemical, biological, or thermal techniques. Examples of possible approaches to in situ treatment include chemical oxidation, permeable treatment beds, air sparging, and biological treatment technologies. For the OU2 Study Area, contaminated groundwater will continue to migrate from the OU1 Study Area for approximately 60 years, while it is addressed through extraction, treatment, and natural

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 3-2 400124 SECTION 3 - IDENTIFICATION AND SCREENING OF TECHNOLOGIES attenuation as part of the OU1 selected remedy. The OU1 Study Area is immediately upgradient of the OU2 Study Area.

3.1.1.8 Extraction, Treatment, and Discharge In this response action, groundwater is collected using pumping wells, treated using physical, chemical, or biological treatment methods to remove the contaminants, and then discharged. The treated groundwater can be discharged by surface infiltration, by subsurface injection, or to surface water or publicly owned treatment works. The collection, treatment, and discharge response action also controls migration of impacted groundwater.

3.2 Technology Screening Methodology In subsequent sections, the technology types and process options available for remediation of soil and groundwater are presented and screened. Screening of technology methods begins with development of an inventory of technology types and process options based on professional experience, published sources, computer databases, the results of the OU1 FS, and other available documentation for the general response actions identified in Section 3.1. Each technology type and process option retained after the screening is either a demonstrated, proven process, or a potential process that has undergone laboratory trials or bench-scale testing. The initial screening of technology types and process options is based on technical implementability. The factors included in this evaluation include the following: the state of technology development, site conditions, waste characteristics, the nature and extent of contamination, and the presence of constituents that could limit the effectiveness of the technology. Entire technologies or individual process options may be screened from further consideration based on technical implementability. Process options that remain after the initial screening are further evaluated using a qualitative comparison based on effectiveness, implementability, and cost. Effectiveness is the ability of the process option to perform as part of a comprehensive remedial plan to meet RAOs under the conditions and limitations present at the site. Additionally, the NCP defines effectiveness as the “degree to which an alternative reduces TMV through treatment, minimizes residual risk, affords long-term protection, complies with ARARs, minimizes short-term impacts, and how quickly it achieves protection.” This is a relative measure to compare process options that perform the same or similar functions. Implementability refers to the relative degree of difficulty anticipated in implementing a particular process option under regulatory, technical, and schedule constraints posed at the site. At this point, the cost criterion is comparative only and, similar to the effectiveness criterion, it is used to preclude further evaluation of process options that are very costly if there are other choices that perform similar functions with similar effectiveness. The cost criterion includes costs of construction and long-term costs to operate and maintain technologies that are part of an alternative. Following the qualitative screening, those remedial technology types and process options that are considered viable for remediating the media at the site are carried forward for incorporation into alternatives.

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3.3 Technology Screening for Groundwater Media Using the same methodology described in the preceding section, Table 3-2 presents the results of the screening of technology types and process options available for groundwater remediation. The general response actions, remedial technologies, and associated process options that were retained after screening include the following.

• Groundwater Sampling – This technology includes sampling and analysis of groundwater samples to monitor the progress of any remedial action taken. • Pre-Design Investigations – Pre-design investigations include the collection of groundwater samples to further refine the groundwater target cleanup areas, or the collection of data for bench-scale or pilot testing. • Groundwater Use Restrictions- Institutional controls, in accordance with the NJDEP regulations (N.J.A.C. 7:26E-8.4) and designated as a CEA, are the applicable groundwater use restrictions for the site. The components of the CEA include the location of the restriction (which includes the potential migration locations before degradation reduces to below applicable cleanup criteria), the compounds detected over the applicable cleanup criteria within the restricted area, and the proposed duration of the restriction. This control will eliminate future use of the groundwater within this area and will restrict the installation of wells over the duration of the CEA. • Public Water Supply Connection - This includes the connection of public water to homes within the OU2 Study Area. This technology provides protection of human receptors within the area of impacted groundwater. • Point of Entry Treatment Systems (POETS) – This commonly used technology is the typical method of private wellhead treatment and involves the installation of a treatment system at a building’s point of entry for the pipeline from a private well. The treatment systems typically consist of two granular activated carbon units connected in series, and preceded by a bag filter and a UV light reactor. Water pumped from the well will enter the building through an existing pipe and flow through the treatment system before exiting into the water supply lines for the remainder of the building. These treatment systems must be periodically tested and replaced as needed to maintain the protection of the water users. As stated above, this technology was also evaluated in conjunction with the public water supply connections for outlying locations in the OU2 Study Area. • Monitored Natural Attenuation (MNA) –MNA is the process by which contaminant concentrations are reduced by various naturally occurring physical, chemical, and biological processes. The main processes include dilution, biodegradation, and retardation of impacted groundwater. Only non-augmented natural processes are considered under this technology. Based on the evaluation of geochemical parameters presented in both the OU1 and OU2 RI Reports, the lack of chlorinated transformation products demonstrates that natural attenuation is not occurring in the OU2 Study Area through chemical or biochemical processes. Natural attenuation is occurring through

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advection, dispersion, and sorption. The progress of natural attenuation is monitored through periodic groundwater sampling and laboratory analyses.

• In Situ Oxidation (ISO) –ISO is a treatment technology that involves addition of an oxidant, such as potassium permanganate, into the subsurface to chemically oxidize TCE to carbon dioxide and water. ISO would be used at the upgradient end of the OU2 Study Area where contaminated groundwater will continue to migrate into OU2 from the OU1 Study Area. • Extraction – This technology involves extraction of groundwater for ex situ treatment and ultimate disposal. This technology is usually coupled with other treatment and discharge options (as discussed below) and can be utilized for either hydraulic controls or active treatment of groundwater. • Adsorption – This technology involves adsorbing contaminants to granular activated carbon for disposal. • Discharge – This technology involves discharge of impacted groundwater after treatment. Several groundwater discharge options are available for treated groundwater, such as reinjection of treated groundwater back into the unconfined aquifer, discharge to the publicly owned treatment works, and discharge to surface water. Treatment requirements will be based on the selected discharge location and any applicable permitting requirements.

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4.0 Development of Alternatives

The remedial technologies and process options that remained after screening were assembled into a range of alternatives. The specific details of the remedial components discussed for each alternative are intended to serve as representative examples to allow order-of-magnitude cost estimates. Other viable process options within the same remedial technology that achieve the same objectives may be evaluated during remedial design activities for the site. Four groundwater media alternatives were initially developed based on the technologies retained from screening (in Section 3) to create a range of remedial actions and include each of the remaining technologies into at least one alternative. Note that two of the four alternatives developed were also separated into sub-alternatives (a and b) due to many similarities with these remedial process options. Table 4-1 present matrixes of technologies that were used to develop the groundwater alternatives for initial screening. The assumptions, estimates of impacted media volumes, and treatment process conceptual design components within this FS were generated for cost estimating purposes as part of the FS.

4.1 Development of Groundwater Media Remedial Alternatives The following section provides a summary of the alternatives developed for groundwater within the OU2 Study Area with concentrations of CVOCs over the ARARs.

4.1.1 Description of Alternatives The RAOs for the groundwater alternatives are:

• Prevent or minimize the current and future human exposures, including ingestion of groundwater, from Site related VOCs in groundwater that present a risk to public health and the environment;

• Minimize the further migration of Site related VOCs in groundwater; and

• Restore the aquifer to meet drinking water standards within a reasonable time-frame

4.1.1.1 Alternative 1 - No Action The objective of Alternative 1 is to provide a baseline for comparison to other alternatives, as required by the NCP. Alternative 1 does not include further remedial action for groundwater. It does not include monitoring or institutional controls.

4.1.1.2 Alternative 2a - MNA, Institutional Controls, and Private Well Head Treatment Alternative 2a relies on natural attenuation for the groundwater plumes while placing use restrictions on the areas of groundwater exceeding ARARs until groundwater returns naturally to concentrations below the ARARs. Private wells within the OU2 Study Area that

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 4-1 400128 SECTION 4 - DEVELOPMENT OF ALTERNATIVES currently do not have POETS, would be treated as part of this alternative using POETS, as shown on Figure 4-1. Figure 4-2 shows the area where POETS may be installed, if required. The main remedial components of Alternative 2a are:

• Groundwater Sampling • Groundwater Use Restrictions • Installation of POETS • MNA This alternative will meet the long-term RAOs for restoration of the groundwater at the site, prevention of ingestion of impacted groundwater, and eventually returning groundwater to drinking water quality. Groundwater Sampling Throughout the natural attenuation process, groundwater sampling will be conducted to monitor the progress of MNA, as discussed below. It is anticipated for costing purposes that the alternative would include the sampling of 21 monitoring wells throughout the OU2 Study Area. This sampling program would include the installation of 14 new monitoring wells within the OU2 Study Area. The groundwater sampling component of natural attenuation is included as part of the MNA component, which includes documentation of remedial progress to EPA and the NJDEP. For the purposes of the FS, it has been assumed that sampling to monitor progress of physical natural attenuation will be completed on all 21 wells every two years. While the project duration for MNA was calculated at 67 years (as discussed below), costs for groundwater sampling for this alternative were completed for 30 years. Exact well locations, frequencies, and laboratory analysis will be evaluated during the remedial design effort. Note that the time of remediation for the OU1 Study Area was calculated at 55 years, whereas for the OU2 Study Area, the time of remediation was calculated at 67 years. The times of remediation were estimated using an analytical solution for a natural attenuation model that uses simplifying assumptions for groundwater flow and contaminant decay rates and requires a variety of site-specific input parameters, such as plume width, concentration gradient, and TCE starting concentrations, to generate the time estimates. Uncertainties in the time estimates arise from the simplifying assumptions of the model and in the site-specific input parameter estimates. For the model, the simplifying assumptions made across the modeled area include uniform groundwater flow conditions (direction and velocity), uniform aquifer permeability, consistent retardation coefficients that act to inhibit migration of contaminants, and uniform plume dispersion/decay rates. The groundwater flow conditions noted in the modeled OU1 and OU2 Study Areas RI vary across the areas based on non-uniform aquifer permeability and seasonal fluctuations in groundwater recharge. In addition, the fractured and karstic nature of the aquifer acts to vary the plume dispersion in the aquifer and allows for variation in the retardation coefficients. For the site-specific input parameters, the plume characteristics (i.e., plume width, concentration gradient, and TCE starting concentrations) are different between the OU1 and OU2 Study Areas. The accuracy of the plume characteristics are also limited by the number and distribution of monitoring wells installed at the site since these parameters are

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 4-2 400129 SECTION 4 - DEVELOPMENT OF ALTERNATIVES interpolated between monitoring well sampling points. These assumptions and uncertainties are discussed in more detail in Appendix B. Also, note that there may be some residences within the OU2 Study Area that are not impacted by the groundwater contamination, and not immediately threatened. These residences may be will be monitored and may only receive POETS after an impact has been identified during monitoring. Groundwater Use Restrictions Groundwater institutional controls, designated as a CEA by the NJDEP, are the restrictive covenant used by the NJDEP to eliminate access to impacted groundwater by restricting use of the aquifer and preventing the installation of wells during the lifetime of the restriction. The CEA includes the area of impacted groundwater, the potential area of groundwater that may be impacted before completion of remedial actions (through migration), the contaminants and concentrations within the area, and an estimated duration of the restriction. Institutional controls related to groundwater use restrictions also include well drilling restrictions, designated as well restriction areas (WRAs) by the NJDEP, to prevent exposure to contaminated groundwater. For the purposes of costing in this FS, it has been assumed that a CEA will be established and that the groundwater sampling components of this alternative will be used to collect data to document the status and long-term reporting requirements of the CEA. Point of Entry Treatment Systems This component includes the installation of POETS at each individual private well within OU2 Study Area. Based on a review of aerial photographs, there are roughly 420 homes in the OU2 Study Area. The NJDEP currently is maintaining about 80 POETS in the OU2 Study Area and an additional 20 wells are likely to requiring ongoing monitoring prior to the installation of the POETS, as they are located at some distance from the contaminant plume. Therefore, for the purposes of the FS, it is estimated that 320 POETS will be installed in the OU2 Study Area, the 80 existing POETS will be maintained, and 20 homes are in outlying areas (as discussed above) that will only require monitoring. Each POET will consist of two granular carbon units connected in series preceded by a bag filter and a UV light reactor (Figure 4-1). Each house will be evaluated for pumping requirements and pumps will be upgraded if necessary to ensure appropriate hydraulic head for proper water distribution at each house. This component provides protection of receptors within the area of impacted groundwater. For the cost purposes of the FS, it has been assumed that each POET system will be sampled and the carbon replaced every 2 years for a total of 30 years. Monitored Natural Attenuation Natural attenuation is the process by which contaminant concentrations are reduced by processes such as volatilization, dispersion, adsorption, and biodegradation. Based on the site groundwater data, aerobic conditions are present in the groundwater throughout the valley. These conditions are not conducive to biological degradation of TCE. However, other natural attenuation mechanisms such as advection and dispersion will result in declining concentrations over time. Based on long-term monitoring of the Dale Avenue well within OU1, concentrations of TCE in groundwater showed slight decreases over time, but have generally remained stable. When considering the flux of TCE from the source area within the OU3 Study Area and that concentrations have not increased in the

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OU1 and OU2 Study Areas over time suggests that natural attenuation via dispersion and adsorption is occurring. It is expected that active treatment of the OU3 source areas will reduce the continuing source and will allow natural attenuation processes to further reduce the concentrations of TCE in the downgradient plume over time. Further, MNA is expected to be successful in the OU2 Study Area. There are no identified sources of TCE contamination within the OU2 Study Area. The TCE contamination within the OU2 Study Area has and continues to migrate from the OU1 Study Area. The remedy selected in the OU1 Study Area includes active extraction and treatment of the most contamination areas of TCE groundwater contamination and MNA for the remainder of the plume. By addressing the hot spot groundwater contamination in the OU1 Study Area, the OU1 remedy, once implemented, will have a positive impact on the OU2 Study Area, as it will remove source contamination that otherwise would continue to migrate to the OU2 Study Area. A groundwater model known as the Natural Attenuation Software (NAS), developed by the Naval Facilities Engineering Command - Southern Division, Virginia Tech, and USGS, was utilized for calculating the time or remediation (TOR) for MNA for this alternative. Details of the calculations for MNA of the OU2 Study Area plume are included in Appendix B. Assumptions on the geology, hydrogeology, and oxidation/reduction potential were used from the OU1 investigation data. The OU2 plume was evaluated independently, assuming the “source area” of the OU2 plume is the highest concentrations seen at the OU1/OU2 boundary (a TCE concentration of 31 μg/L). Average concentrations from the homeowner wells in each area along the fault line were used for concentrations downgradient and to identify the point of compliance. Based on the results of the model run for MNA, the TOR for this alternative is 67 years. This MNA timeframe is similar to the timeframe for the OU1 TCE plume, which is expected because the OU2 TCE plume is an extension of the OU1 TCE plume. One condition of the model is that it assumes steady state conditions, and that no additional mass flux will move into the area. Because the OU1 TCE plume will continue to migrate into this area over time, it is probable that the actual time of remediation could be longer than 67 years.

4.1.1.3 Alternative 2b - MNA, Institutional Controls, and Public Water Supply Connection Alternative 2b relies on natural attenuation for the groundwater plumes while placing use restrictions on the areas of groundwater exceeding ARARs until groundwater returns naturally to concentrations below the ARARs. This option is different from Alternative 2a in that homes within the immediate area of the valley will be connected to the public water supply and private wells at outlying locations will be treated by POETS (if needed) see Figure 4-3. The main remedial components of Alternative 2b are:

• Groundwater Sampling • Groundwater Use Restrictions • Public Water Supply Connections • POETS (if necessary for outlying areas) • MNA This alternative will meet the long-term RAOs for restoration of the groundwater at the site, prevention of ingestion of impacted groundwater, and eventually returning groundwater to drinking water quality.

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Groundwater Sampling The groundwater sampling, to monitor natural attenuation of the plume over time, is the same as described in Alternative 2a. Groundwater Use Restrictions The institutional controls (CEA and WRA, as required by NJDEP) are the same as described in Alternative 2a. Public Water Supply Connection This component includes the connection of a public water supply to homes within the immediate OU2 Study Area (within the valley). This component provides protection of receptors within the area of impacted groundwater. Based on a review of aerial photographs, there are roughly 420 homes in the OU2 Study Area. The NJDEP is currently maintaining about 80 POETS in the OU2 Study Area and an additional 20 wells are currently located outside of the contaminant plume. It is assumed that these 80 POETS will been maintained for the approximate 3-year time period while design, permitting, and construction of the water supply line occurs. It is also assumed that 20 of the 420 homes within the OU2 Study Area are remotely located and will not be connected to the public water supply line. These homes will instead receive POETS for private wellhead treatment and they will be continually operated and maintained for 30 years. It has been assumed for costing purposes that 320 homes within OU2 will be connected to the public water supply line. It is assumed that the water line will be extended into OU2 from existing public water supply lines located at the southwest end of OU2 and/or at the northeast portion of OU2, near the OU1-OU2 Study Area boundary. Approximately 10 miles of water supply line will be installed within OU2. In addition, it is assumed that all of the homes where public supply service will be installed will require a service line connection of approximately 100 feet from the supply line to the home (Figure 4-3). For installation of the public supply, it could take up to three years to design, permit, and install the connections to homes. For the purposes of the FS, it has been assumed that all costs for payment of water bills after connection will be the responsibility of the homeowners. For the purposes of the FS, it has been assumed that the 80 homes with POETS will be maintained until the public water supply line is installed, and there are 20 outlying homes that monitoring will be completed to verify these homes do not need POETS. Groundwater monitoring will be conducted in the 20 properties located in the outlying areas for 30 years. In addition, it has been assumed for costing purposes that existing domestic wells at the 320 homes will be grouted closed by a New Jersey licensed drilling contractor. Monitored Natural Attenuation The MNA component for this alternative is the same as in Alternative 2a, with an estimated time of remediation of 67 years based on the NAS model.

4.1.1.4 Alternative 3a - In Situ Treatment, Private Well Head Treatment, and MNA Alternative 3a provides an ISO alternative to treat TCE-impacted groundwater in the upgradient portion of the OU2 Study Area and private wellhead treatment using POETS. The in-situ alternative includes the injection of a chemical oxidant to degrade the TCE at the ABR site. The ABR site is the furthest upgradient area in the OU2 Study Area and is contiguous with the southwestern end of the OU1 Study Area. This area lies within a

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 4-5 400132 SECTION 4 - DEVELOPMENT OF ALTERNATIVES geologic fault zone that is parallel to the trend of the Pohatcong Valley and conducts groundwater flow from OU1 to OU2. The objective of the alternative is to remove TCE mass that is passing through the OU1/OU2 Study Area boundary and actively reduce the TCE concentrations in the OU2 Study Area compared to Alternatives 2a and 2b. The main remedial components of Alternative 3a are:

• ISO injection at the ABR Site • Pre-Design Investigations • Groundwater Use Restrictions • Private Well Head Treatment using POETS • Groundwater Sampling • MNA It is assumed for cost estimating purposes that the ISO system will operate for 1.5 months to complete one round of oxidant injection in the treatment area (Figure 4-4) and that natural attenuation processes will further remediate the treatment area as well as the remainder of groundwater contamination within the OU2 Study Area exceeding ARARs. Multiple rounds of ISO injections would not be cost-effective, and would increase the potential of downgradient migration of un-reacted oxidant that would adversely affect the groundwater quality and potable wells. This alternative would meet the long-term RAOs for restoration of the groundwater at the site, prevent ingestion of impacted groundwater by wellhead treatment, and eventually return groundwater to drinking water quality. In Situ Oxidation Injection The ISO treatment area is selected to be at the ABR site (Figure 4-4), which is located approximately 1,100 feet south-southeast of the intersection of Route 57 and Asbury- Broadway Road in Franklin Township, New Jersey. The site is accessed from Asbury- Broadway Road approximately 450 feet to the southwest and is bound by Pohatcong Creek to the northwest and farm fields to the east, west, and south. The ABR site is located at the southwest portion of the OU1 Study Area and was selected for the OU2 RI since it is located at the boundary between the OU1 and OU2 Study Areas. The area of highest TCE concentrations (about 30 μg/L) is approximately 8.32 acres and would be the target application area for in situ treatment. This zone is estimated to extend between 40 feet bgs to 150 feet bgs. ISO involves the addition of an oxidant to chemically oxidize TCE to carbon dioxide and water. As assumed for costing purposes, the oxidant will be injected into the groundwater through three injection wells located along the upgradient perimeter of the target area, as shown in Figure 4-4. Details of the exact locations and required number of injection points would be assessed during remedial design. ISO application to the aquifer to treat the relatively low TCE concentrations (generally below 30 μg/L) in the ABR area will require a relatively small amount of oxidant. However, to evenly distribute the oxidant and create an effective radius of influence in the highly fractured area adjacent to the Karrsville Fault, the flow rate of injection needs to be on the order of 100 to 200 gallons per minute (gpm). To generate the large volume of water needed for injection and to capture potential un-reacted oxidant in the groundwater, extraction wells may be installed downgradient of the injection area. Groundwater generated from the extraction wells will be mixed with the oxidant and immediately re-injected in the upgradient treatment area (Figure 4-4). A treatment building may be required to house the

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 4-6 400133 SECTION 4 - DEVELOPMENT OF ALTERNATIVES piping and equipment to effectively mix the oxidant with the extracted groundwater and re- inject the oxidant-laden water into the aquifer. This system of groundwater extraction, oxidant mixing, and injection would operate up to 1.5 months until the estimated volume of oxidant needed to treat the TCE concentrations is injected into the aquifer. The highly fractured nature of the bedrock close to the Karrsville Fault would make implementation of the treatment method difficult for injecting the oxidant into fractures with varying permeability. In addition, the dispersed nature of TCE within the fractured bedrock would decrease the oxidant contact effectiveness. For cost estimating purposes, it has been assumed that the necessary piping between the extraction and injection target areas will be run along existing street or utility right-of-ways, eliminating the need to lease additional land. The exact location of the treatment building, piping, and any other infrastructure necessary for the system will be evaluated during remedial design. The main assumptions used to estimate the cost of this alternative are:

• Target cleanup area of approximately 8.32 acres • Three injection wells injecting approximately 100 to 200 gpm • Oxidant dosage of 10 times the stoichiometric requirement for TCE oxidation • Total required oxidant mass is 1,200 pounds • Pore volume flush rate of 42 days Pre-Design Investigations It is assumed for costing purposes that pre-design investigations will also be conducted to delineate the horizontal and vertical extent of TCE contamination more precisely and to assess the occurrence and nature of fractures in the bedrock. Delineation of the downgradient extent of the TCE concentrations in the proposed treatment area will be a focus of the investigation. It is anticipated for costing purposes that the alternative would include the sampling of 21 monitoring wells throughout the OU2 Study Area. This sampling program would include the installation of 14 new monitoring wells within the OU2 Study Area. VOC concentrations and natural attenuation parameters will be evaluated at these wells. As with groundwater sampling, details of the exact number of locations to be sampled, sampling frequency, and laboratory analytical parameters will be evaluated during the remedial design effort. Groundwater Use Restrictions The institutional controls (CEA and WRA, as required by NJDEP) are the same as described in Alternative 2a. Point of Entry Treatment Systems The POETS are as described in Alternative 2a. Groundwater Sampling For Alternative 3a, there are two components to groundwater sampling; 1) confirmation sampling to verify the effectiveness of the ISO process during active treatment of the source area, and 2) long-term MNA monitoring for the duration of the remediation.

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A confirmation sampling program will be conducted to verify the effectiveness of the remedy in the treatment area. For costing purposes, it has been assumed that 13 monitoring wells will be sampled on a monthly basis for one year to evaluate treatment performance and to assess potential downgradient migration of un-reacted oxidant. Samples will be analyzed for field parameters, VOCs, and metals. Details of the exact number of locations to be sampled, sampling frequency, and laboratory analytical parameters will be evaluated during the remedial design effort. Results will be summarized and submitted to EPA and the NJDEP. It is assumed for cost estimating purposes that the monitoring for the oxidant injection will be completed within 1 year. Groundwater samples will also be used to estimate the oxidant demand and allow the proper dosage of oxidant material (assumed to be potassium permanganate) to be calculated. Alternate oxidants such as sodium permanganate and persulfate in addition to potassium permanganate will be evaluated in bench-scale tests conducted during pre- design investigations. It is assumed for costing purposes that a pilot test of the selected oxidant material will be conducted to verify effectiveness and access the potential effects of the oxidant on the aquifer. After the monthly sampling for one year is completed to verify the effectiveness of the in ISO, the other component of groundwater sampling, to monitor the effectiveness of MNA, will be completed as presented in Alternative 2a. Monitored Natural Attenuation The mechanisms of natural attenuation described in Alternatives 2a and 2b are assumed to be the same for costing purposes in this alternative. While it is expected that the ISO will reduce the TCE concentrations at the upgradient portion of the OU2 Study Area, residual impacted groundwater from OU1 is expected to continue migrating into the OU2 Study Area, which will cause remedial timeframes to be extended until groundwater conditions are below the NJDEP GWQS. In addition, when considering that ISO may not significantly reduce the concentrations in the OU2 treatment area because of the low concentrations already present, the TOR is not significantly different from MNA alternatives (2a and 2b).

4.1.1.5 Alternative 3b – In Situ Treatment, Public Water Supply Connection and MNA This alternative is the same as Alternative 3a except that instead of installation of POETS throughout the entire OU2 Study Area, the interior areas within the OU2 Study Area that exhibit a higher home density will be connected to the public water supply as described in Alternative 2b (Figure 4-5). The main remedial components of Alternative 3b, also described for Alternatives 3a and 2b, are:

• ISO injection at the ABR Site • Pre-design Investigations • Groundwater Use Restrictions • Public Water Supply Connection • Groundwater Sampling • MNA This alternative will meet the long-term RAOs for restoration of the groundwater at the site, prevention of ingestion of impacted groundwater, and eventually returning groundwater to drinking water quality.

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The components of Alternative 3b are similar to the components described in Alternative 3a, with the difference that homes within the more densely populated central area of the valley will be connected to the public water supply. Activities related to the oxidant injection, pre-design investigations, groundwater sampling, and MNA are as described in Alternative 3a. Activities related to the public water supply connection are as described in Alternative 2b and the activities related to the groundwater use restrictions are as described in Alternative 2a.

4.1.1.6 Alternative 4– Entire Plume Extraction, Treatment, and Reinjection Alternative 4 would meet ARARs through the extraction, treatment, and reinjection of the entire OU2 groundwater plume. This alternative would protect human health and the environment within OU2 by removing the contaminated groundwater from the regional aquifer. It complies with ARARs and would be effective in the long-term. The main remedial components of Alternative 4 are as follows.

• Groundwater Sampling • Pre-Design Investigations • Groundwater Use Restrictions • POETS (if necessary for outlying areas) • Public Water Supply Connection • Groundwater Extraction, Treatment, and Reinjection This alternative would meet the short and long-term RAOs for restoration of the groundwater at the site, prevention of ingestion of impacted groundwater, and eventually returning groundwater to drinking water quality. The pre-design investigation, groundwater sampling, groundwater use restrictions, public well connection, and POETS for outlying areas, are assumed for costing purposes to be the same as described for Alternative 2b. Groundwater Extraction, Treatment, and Reinjection This alternative includes entire plume extraction and treatment (Figure 4-6). Based on OU1 Study Area assumptions for large scale pumping, a conceptual plan of this type of pumping system would require six sets of five extraction wells (30 wells total) oriented perpendicular to the migration of the plume, with each set spaced approximately 4,000 feet along the longitudinal extent of the OU2 plume. To capture the TCE plume under this pumping scenario, an estimated minimum of 1,500 gpm needs to be pumped at each set of extraction wells. This extraction system will produce a total of 9,000 gpm (or nearly 13 million gallons per day). Assuming the maximum TCE concentration found in the OU2 Study Area (31 μg/L) to be the influent concentration of the treatment system and assuming a first order reaction for the degradation of TCE , the estimated time of operation for the treatment system to meet the ARARs will be 30 years. The treatment building is assumed for costing purposes to be located on leased industrial property. The size of the required property is assumed to be 40,000 square feet, for cost estimating purposes. Piping between extraction and injection wells and the treatment building will be run along existing street or utility right-of-ways to eliminate the need to lease additional land. Because active remediation is expected to have been completed after 30 years, leasing costs for the property are included in the cost estimate for 30 years.

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Note that the plan for pumping, as presented in this FS above, is based solely on information provided in the OU1 Study Area FS. Because this alternative was a qualitative evaluation of a pumping scenario, no design or groundwater modeling was completed for the system. The exact flow rates, influent TCE concentrations, number, and locations of extraction and injection wells, treatment system components, and the locations of systems and infrastructure would be determined during remedial design. In addition, costs for this alternative (as discussed below) were rough order of magnitude based on assumptions used in the OU1 Study Area FS.

4.2 Initial Screening of Alternatives A preliminary evaluation of the groundwater remedial alternatives was completed to access whether alternatives could be initially screened out prior to the detailed evaluation presented in Section 5.

4.2.1 Initial Screening of Groundwater Alternatives The six groundwater alternatives (including No Action) were initially evaluated based on implementability, effectiveness, and cost-effectiveness. Alternative 4 was considered impractical and not cost-effective1. The following section provides a summary of the screening-level evaluation for this alternative and why it was eliminated.

4.2.1.1 Alternative 4 – Entire Plume Extraction, Treatment, and Reinjection Alternative 4 involves the collection of groundwater within the entire OU2 Study Area for treatment. While Alternative 4 would protect human health and the environment through active treatment of impacted groundwater, is not considered feasible because the groundwater elevation within OU2 is close to the streams and thus water in the streams is recharged by groundwater. The large volume of pumping at OU2 may damage natural resources such as the streams and wetlands along Pohatcong Creek, since there is a potential for significant dewatering which would affect the habitats in these areas. In addition, the high-volume of pumping needed to capture the plume may draw down the groundwater sufficiently to impact the private homeowner wells within the OU2 Study Area. Due to the complex hydrogeology at the Site, complete extraction and reinjection of the large volume of the impacted groundwater may be difficult. Water production, treatment, and reinjection of these volumes will require extension operations and maintenance (O&M) during pumping, thus increasing both capital and long-term O&M costs. The time until remedial objectives are attained is an estimated 14 years based on estimated pumping rates and assumed pore-water volumes, and assuming clean water is recharging the aquifer. However, the TCE impacted groundwater from the OU1 Study Area will continue to migrate into the OU2 Study Area and will re-contaminate the groundwater. Therefore, the time until remedial objectives are attained in the OU2 Study Area is based on the timeframe for the TCE plume in the OU1 Study Area to reach remedial objectives, which is 55 years.

1 Note that Groundwater Alternative 1 (No Action) was also considered impractical and does not achieve any ARARs or RAOs. However, it was retained in the detailed screening of alternatives for comparison purposes.

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Based on the OU1 Study Area FS, a rough order of magnitude cost to remediate the OU2 Study Area using this alternative was prepared (Appendix C). The rough order of magnitude cost (present worth) is based on a 30-year timeframe and is approximately $46,610,000. While this cost is a rough order of magnitude, this alterative is much more costly than the other five alternatives evaluated in detail in Section 5, due to the high capital cost for a number of treatment systems that would be required to handle the large volumes of water, and the extensive operational time and power consumption of the systems. The implementability of this alternative is also considered poor because the treatment system would be very large and would require multiple operators and high-yield extraction and injection wells. Because of the large scale of the treatment system, the fact that this alternative does not protect public supply wells, and that there would be extensive intrusive activities during the construction and operation of a treatment system of this size, community and state acceptance may be difficult to obtain. In summary, this groundwater alternative has significant disadvantages relative to potential natural resources damages, time until remedial objectives are met, the high cost for installation and operations of treatment systems, and implementability concerns. As a result, it will not be considered further within this FS.

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5.0 Detailed Analysis of Alternatives

5.1 Introduction The detailed analysis of alternatives presents the relevant information needed to compare the remedial alternatives assembled for the OU2 Study Area of the PVGCS. The detailed analysis of alternatives follows the development of alternatives, and precedes the selection of a final remedy. Screening of alternatives was not needed because the number of alternatives was not excessive for detailed evaluation. The extent to which alternatives are fully evaluated during the detailed analysis is influenced by the available data and the number and types of alternatives being analyzed. Detailed analysis of alternatives consists a detailed evaluation of each alternative against seven of the nine NCP evaluation criteria (the final two criteria of Community Acceptance and State Acceptance are completed after public comment); and 5.2 Evaluation Criteria In accordance with the NCP, remedial actions must:

• Be protective of human health and the environment;

• Attain ARARs or provide grounds for invoking a waiver of ARARs that cannot be achieved;

• Be cost-effective;

• Utilize permanent solutions and alternative treatment technologies or resource-recovery technologies to the maximum extent practicable; and

• Satisfy the preference for treatment that reduces TMV as a principal element. In addition, the NCP emphasizes long-term effectiveness and related considerations including: • The long-term uncertainties associated with land disposal;

• The goals, objectives, and requirements of the Solid Waste Disposal Act;

• The persistence, toxicity, and mobility of hazardous substances and their constituents, and their propensity to bio-accumulate;

• The short- and long-term potential for adverse health effects from human exposure;

• Long-term maintenance costs;

• The potential for future remedial action costs if the selected remedial action fails; and

• The potential threat to human health and the environment associated with excavation, transportation, disposal, or containment.

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Provisions of the NCP require that each alternative be evaluated against nine criteria listed in 40 CFR 300.430(e)(9). These criteria were published in the March 8, 1990 Federal Register (55 FR 8666) to provide grounds for comparison of the relative performance of the alternatives and to identify their advantages and disadvantages. This approach is intended to provide sufficient information to adequately compare the alternatives and to select the most appropriate alternative for implementation at the site as a remedial action. The criteria are divided into three groups: threshold, balancing, and modifying criteria. Threshold criteria must be met by a particular alternative for it to be eligible for selection as a remedial action. There is little flexibility in meeting the threshold criteria. Either they are met by a particular alternative or that alternative is not considered acceptable. The two threshold criteria are overall protection of human health and the environment and compliance with ARARs. If ARARs cannot be met, a waiver may be obtained in situations where one of the six exceptions listed in the NCP occur (40 CFR 300.430 (f)(1)(ii)(C)(1 to 6)). Unlike the threshold criteria, the five balancing criteria weigh the tradeoffs between alternatives. A low rating on one balancing criterion can be compensated by a high rating on another. The five balancing criteria include: 1. Long-term effectiveness and permanence 2. Reduction of TMV through treatment 3. Short-term effectiveness 4. Implementability 5. Cost The two modifying criteria are evaluated following public comment and are used to change the selection of the recommended alternative. The modifying criteria are Community Acceptance and State Acceptance.

5.2.1 Threshold Criteria To be eligible for selection, an alternative must meet the two threshold criteria, or if an ARAR is not met, justify that a waiver is appropriate.

5.2.1.1 Overall Protection of Human Health and the Environment Protection is the primary requirement that remedial actions must meet under CERCLA. A remedy is protective if it adequately eliminates, reduces, or controls all current and potential risks posed by the site through pathways. The assessment against this criterion describes how the alternative achieves and maintains protection of human health and the environment.

5.2.1.2 Compliance with ARARs Compliance with ARARs is one of the statutory requirements of remedy selection. ARARs are cleanup standards, standards of control, and other substantive environmental statutes or regulations which are either “applicable” or “relevant and appropriate” to the CERCLA cleanup action (42 USC 9621[d][2]). ARARs are listed in Appendix A of this report. Applicable requirements address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstances at a CERCLA site. Relevant and appropriate

\\CASTOR\PROJ\US EPA REGION 2\322118_POHATCONG OU2\OU 2 FS\JAN10_FINAL_FS\TEXT\PVGCSFS_04072010_FINAL.DOC 5-2 400140 SECTION 5 - DETAILED ANALYSIS OF ALTERNATIVES requirements are those that while not applicable, address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to environmental or technical factors at a particular site. The assessment against this criterion describes how the alternative complies with ARARs or presents the rationale for waiving an ARAR. ARARs can be grouped into three categories:

• Chemical-specific: ARARs are health- or risk-based numerical values or methodologies which, when applied to site-specific conditions, establish the amount or concentration of a chemical that may remain in or be discharged to the environment.

• Location-specific: ARARs restrict the concentration of hazardous substances or the conduct of activities solely because they are in specific locations, such as flood plains, wetlands, historic places, and sensitive ecosystems or habitats.

• Action-specific: ARARs include technology- or activity-based requirements that set controls, limits, or restrictions on design performance of remedial actions or management of hazardous constituents.

5.2.2 Balancing Criteria The five criteria listed below are used to weigh the tradeoffs between alternatives.

5.2.2.1 Long-Term Effectiveness and Permanence This criterion reflects CERCLA's emphasis on implementing remedies that will ensure protection of human health and the environment in the long term as well as in the short term. The assessment of alternatives against this criterion evaluates the residual risks at a site after completing a remedial action or enacting a no action alternative and includes evaluation of the adequacy and reliability of controls.

5.2.2.2 Reduction of TMV through Treatment This criterion addresses the statutory preference for remedies that employ treatment as a principal element. The assessment against this criterion evaluates the anticipated performance of the specific treatment technologies an alternative may employ. The criterion is specific to evaluating only how treatment reduces TMV and does not address containment actions such as capping.

5.2.2.3 Short-Term Effectiveness This criterion addresses short-term impacts of the alternatives. The assessment against this criterion examines the effectiveness of alternatives in protecting human health and the environment (i.e., minimizing any risks associated with an alternative) during the construction and implementation of a remedy until the response objectives have been met.

5.2.2.4 Implementability The assessment against this criterion evaluates the technical and administrative feasibility of the alternative and the availability of the goods and services needed to implement it.

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5.2.2.5 Cost Cost encompasses all engineering, construction, and O&M costs incurred over the life of the project. The assessment against this criterion is based on the estimated present worth of these costs for each alternative. Present worth is a method of evaluating expenditures such as construction and O&M that occur over different lengths of time. This allows costs for remedial alternatives to be compared by discounting all costs to the year that the alternative is implemented. The present worth of a project represents the amount of money, which if invested in the initial year of the remedy and disbursed as needed, would be sufficient to cover all costs associated with the remedial action. Note that five-year review costs, which are considered periodic costs, are not included in the alternative costs. As stated in the RI/FS guidance (EPA, 2000), these estimated costs are expected to provide an accuracy of minus 30 percent to plus 50 percent. Appendix D provides a breakdown of the cost estimate for each of the retained alternatives. The level of detail required to analyze each alternative against these evaluation criteria depends on the nature and complexity of the site, the types of technologies and alternatives being considered, and other project-specific considerations. The analysis is conducted in sufficient detail to understand the significant aspects of each alternative and to identify the uncertainties associated with the evaluation. The cost estimates presented below have been developed strictly for comparing the alternatives. The final costs of the project and the resulting feasibility will depend on actual labor and material costs, competitive market conditions, actual site conditions, final project scope, the implementation schedule, the firm selected for final engineering design, and other variables. Therefore, final project costs will vary from the cost estimates. Because of these factors, project feasibility and funding needs must be reviewed carefully before specific financial decisions are made or project budgets are established to help access proper project evaluation and adequate funding. The cost estimates are order-of-magnitude estimates having an intended accuracy range of -30 to +50 percent. The range applies only to the alternatives as they are defined in Section 4 and do not account for changes in the scope of the alternatives. Selection of specific technologies or processes to configure remedial alternatives is not intended to limit flexibility during remedial design, but to provide a basis for preparing cost estimates. The specific details of remedial actions and cost estimates would be refined during final design.

5.3 Detailed Analysis of Groundwater Media Alternatives

5.3.1 Detailed Evaluation The following alternatives for groundwater were retained following alternative screening:

• Alternative 1 – No Action • Alternative 2a - MNA, Institutional Controls, and Private Well Head Treatment • Alternative 2b - MNA and Institutional Controls, and Public Water Supply Connection • Alternative 3a - In Situ Treatment, Private Well Head Treatment, and MNA • Alternative 3b – In Situ Treatment, Public Water Supply Connection, and MNA.

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These five alternatives were evaluated in detail using the seven evaluation criteria described in Section 5.1. The detailed evaluations for these groundwater media alternatives are presented in Table 5-1.

5.3.2 Comparative Analysis 5.3.2.1 Overall Protection of Human Health and the Environment The groundwater RAOs are as follows:

• Prevent or minimize the current and future human exposures, including ingestion of groundwater, from Site related VOCs in groundwater that present a risk to public health and the environment;

• Minimize the further migration of Site related VOCs in groundwater; and

• Restore the aquifer to meet drinking water standards within a reasonable timeframe. The considered alternatives (with the exception of No Action) prevent human exposures to groundwater by private wellhead treatment or public water supply. The No Action alternative is not considered protective because it does not prevent the current or future use of contaminated groundwater, does not include groundwater monitoring or institutional controls to prevent access to contaminated groundwater. The remaining alternatives are considered protective. The groundwater alternatives that have public water supply connections (Alternatives 2b and 3b) are more protective of human health, as they completely eliminate the potential for ingestion of impacted groundwater, as opposed to Alternatives 2a and 3a, which just treat the contamination prior to ingestion. Either breakthrough of the POETS adsorptive material over time or lack of long-term maintenance of the POETS could cause a reduction in the effectiveness of the carbon, allowing for the potential ingestion of impacted groundwater. When comparing the alternatives that include ISO treatment (Alternatives 3a and 3b) versus alternatives that only utilize MNA (Alternatives 2a and 2b), the alternatives that include ISO treatment to address TCE concentration near the border of the OU1 and OU2 Study Areas are not more protective of human health than the alternatives that do not include active treatment. This is due to the continual migration of residual groundwater contaminants from the OU1 Study Area into the OU2 Study Area. The ISO alternatives (Alternatives 3a and 3b) would not provide any significant difference in the long–term protection of human health and the environment over Alternatives 2a and 2b, which employ MNA alone to address the plume. This is because they would not result in addressing the overall OU2 groundwater contamination appreciably faster than the alternatives that do not include this treatment option. All of the alternatives (excluding No Action), have a component of MNA, which is also protective of human health, due to the dispersion and dilution of the plume throughout the OU2 Study Area. Because the plume has shown only slight decreases and remained stable over time, even with the OU1 Study Area, by addressing the source area(as covered under the OU1 ROD and a future OU3 ROD), MNA is a viable remedy that will be protective of human health, when coupled with an alternative water supply.

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5.3.2.2 Compliance with ARARs Appendix A presents a compilation of all the state and federal chemical-specific, location- specific, and action-specific ARARs considered for the PVGCS. All of the alternatives would eventually meet the chemical-specific ARARs in the aquifer. The no action alternative (Alternative 1) would not assure that residential drinking water met the ARAR for TCE in the short-term. Alternatives 2b and 3b are more compliant with the chemical-specific ARARs because connection to a public water supply line would eliminate the need to test new and existing private wells for potential POETS. All of the alternatives would be able to comply with location and action specific ARARs, such as the Freshwater Wetlands Protection Act and the Federal Clean Water Act. 5.3.2.3 Long-Term Effectiveness and Permanence All alternatives would be effective in the long-term and would be permanent. Through active source removal (as part of other operable units) and continued long-term monitoring of plume stability and decreasing concentrations, the MNA component of all alternatives is effective and permanent. When comparing the alternatives that include POETS (Alternatives 2a and 3a) versus alternatives that include public supply connections (Alternatives 2b and 3b), the alternatives that include public supply connections are more effective in the long term and are more permanent solutions. There are extensive O&M requirements that are needed with the POETS to ensure that they are properly operating over time to limit the long-term effectiveness. Providing homes with a public water supply is a more permanent solution over POETS. In general, alternatives that include active reduction of contaminant concentrations (such as Alternatives 3a and 3b) would be more effective in the long-term than options that only rely on MNA (such as Alternatives 2a and 2b). However, due to the continued migration of contaminated groundwater from the OU1 Study Area, there is no significant difference in the long-term effectiveness of the active treatment options versus MNA options. Because of the potential for contaminated groundwater to migrate into the OU2 Study Area after ISO treatment at the ABR area, additional dosing may be required, which would limit the effectiveness and permanence of the remedy, along with significantly increasing costs. In addition, significant continued injection of oxidant into the aquifer beyond the estimated 1-year timeframe may begin to cause detrimental impacts to the aquifer, such as the presence of unreacted oxidant. 5.3.2.4 Reduction of Toxicity, Mobility, and Volume through Treatment All alternatives would have a similar degree of reduction of TMV of the TCE in groundwater through natural attenuation processes. Alternatives 3a and 3b are the best alternatives for the reduction of TMV since they would rely on active treatment processes to remove and treat the TCE migrating into the OU2 Study Area from the OU1 Study Area. However, there is recontamination of groundwater in the OU2 Study area due to the continuing migration of impacted groundwater from the OU1 area. Recontamination of groundwater in the OU2 Study Area would continue until the TCE from the OU1 Study Area reached the ARARs, which is estimated to be 55 years. It is noted that the oxidant injected under Alternatives 3a and 3b would potentially react with non-TCE chemicals/analytes in the aquifer or the aquifer matrix, and that these reactions may leave

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5.3.2.5 Short-term Effectiveness All alternatives have minimal impacts with respect to the protection of workers during remedial construction, protection of community during remedial action, and environmental impacts of remedial action. The No Action alternative has no construction-related impacts because it involves no remedial action. Alternatives 2a and 3a would require about 1 year to complete the installation of the POETS. Alternatives 2b and 3b take longer to implement that 2a and 3a, as the construction of the waterline would be more involved than the installation of the POETS. Installation of POETS throughout the OU2 Study Area (Alternatives 2a and 3a) would require about 1 year to complete this would cause short–term disruption to numerous property owners as it would involve working within numerous impacted and threatened homes and buildings. Construction of the public water supply line would require about 2 years to complete. Approximately 10 miles of water line would need to be constructed, cause disruption of the local community. This work would likely be phased to minimize disruption. During the time to complete the public water supply line, existing POETS would be maintained for short-term effectiveness. When comparing alternatives that include ISO treatment (Alternatives 3a and 3b) versus alternatives with only MNA (Alternatives 2a and 2b), there is no difference in short term effectiveness, as the ISO treatment options (Alternatives 3a and 3b) will not protect groundwater receptors any sooner than the MNA alternatives alone. In addition, the migration of contaminated groundwater from the OU1 Study Area into the OU2 Study Area, there will be no benefit to ISO treatment, as it is no more effective in the short-term than MNA alone. 5.3.2.6 Implementability All options can be implemented with available equipment and technology. There are significant implementability issues for the alternatives that include ISO treatment (Alternatives 3a and 3b), due to permitting, siting if required treatment plants, long-term access to these areas, potential impacts to private wells, and difficulties with injection and contaminant-contact of the oxidant material. When considering construction, providing POETS would be easier to implement compared to the construction of waterlines. However, installation of both POETs and waterlines would require entry and construction work within numerous homes and residential properties. Construction of the waterlines would require disruption of the community, but it is a common type of construction and could be performed in a phased approach to limit impacts to the local community. Construction of waterlines would not involve any contact with contaminated groundwater, so no other additional measures or precautions would be needed beyond standard construction health and safety measures. All retained alternatives can be implemented with available equipment and technology. However, permitting and access to private property will be required for Alternatives 2a, 2b,

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3a, and 3b. Alternatives 3a and 3b require land to construct the treatment buildings and for installation of extraction and reinjection wells and piping. In addition, the performance of ISO injection may would have difficulty in adequately contacting TCE in groundwater because of the complex bedrock geology and the uncertainty that sufficient chemical reagent will reach the targeted TCE plume. In addition, there would be the potential that unreacted oxidant would migrate downgradient and pose a risk to private wells. For these reasons, Alternatives 3a and 3b would be more difficult to implement than Alternatives 2a and 2b. The public water supply connection component of Alternatives 2b and 3b would be more difficult to implement initially than Alternatives 2a and 3a, which rely on POETS, based on the type and amount of design, permitting, and construction required. These difficulties would include the short-term disruption of the community due to the length and geographic extent of the construction efforts associated with the installation of public water supply lines. Alternatives 2a and 3a would be easier to implement initially, but would require significant ongoing efforts associated with the sampling, installation and long-term operation and maintenance of POETS. In addition, new construction within the impacted groundwater portion of OU2 would have to be identified and the new private wells sampled and fitted with POETS on a timely basis, which could delay their use.

5.3.2.7 Cost A summary of the estimated costs for each of the groundwater remedial alternatives is presented in the first table of Appendix D. The table breaks down the estimated capital, operations and maintenance, and present net worth cost. Although the time of remediation for Alternatives 2a, 2b, 3a, and 3b was estimated to be 67 years, the present-worth costs for these alternatives are based on a 30-year timeframe. It is recognized that Alternatives 2a and 3a will require ongoing O&M for the POETS for the entire 67-year duration, but these costs are not included in the following 30-year cost basis analysis. The present-worth costs were also calculated using a 7 percent discount rate per EPA guidelines. The costs for Alternative 4 are also included as a basis of comparison.

Remedial Alternative Present-Worth Cost

Alternative 1 - No Action $0

Alternative 2a (POETS, MNA) $6,640,000

Alternative 2b (Public Well Connection, MNA) $15,040,000

Alternative 3a (ISO Treatment, POETS, MNA) $8,200,000

Alternative 3b (ISO Treatment, Public Well Connection, MNA) $16,590,000

The alternatives that include POETS (Alternatives 2a and 3a) are less costly than alternatives with public water supply connections, due to the higher capital cost for installation of the infrastructure to convey water to the homes. However, while the capital costs for these alternatives are higher initially, the long-term maintenance costs for these alternatives are much lower than the alternatives with POETS because of the significant reduction in cost to maintain POETS. The cost estimates presented above have been developed strictly for comparing the alternatives. The final costs of the project and the resulting feasibility will depend on actual labor and material costs, competitive market conditions, actual site conditions, final project

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6.0 References

CH2M HILL. 2005a. Final PVGCS OU1 Remedial Investigation Report for the Pohatcong Valley Groundwater Contamination Site. Prepared for EPA Region 2. June. CH2M HILL. 2005b. Final PVGCS OU1 Feasibility Study Report for the Pohatcong Valley Groundwater Contamination Site. Prepared for EPA Region 2. June. CH2M HILL. 2009. Final PVGCS OU2 Remedial Investigation Report for the Pohatcong Valley Groundwater Contamination Site. Prepared for EPA Region 2. June. U.S. Environmental Protection Agency (EPA). 1988a. Remedial Investigation/Feasibility Study Guidance Document. EPA. 1988b. Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites. EPA. 1990. National Oil and Hazardous Substances Contingency Plan. EPA. 1998a. Management of Remediation Waste under RCRA, EPA530-F-98-026. October 1998. EPA. 1998b. Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Ground Water EPA. 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002.

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TABLE 3-1 Identification of General Response Actions for Groundwater PVGCS OU2 Study Area Feasibility Study General Response Evaluation Action

No Action Required by the NCP for comparison to other actions.

Monitoring Used to monitor effectiveness of other general response actions. Retained for use in conjunction with other general response actions.

Institutional Controls Eliminates ingestion of impacted groundwater by restricting groundwater use. Retained for use in conjunction with other general response actions.

Private Well Treatment Eliminates exposure to impacted water by homeowners not currently connected to or Alternate Water municipal water supply or treatment of the privately owned wells. Retained. Supply

Monitored Natural Reduction of COCs by various naturally occurring physical, chemical, and biological Attenuation processes. Retained.

In Situ Treatment Reduces mobility, toxicity, or volume of contaminated media in place using proven technologies. Retained.

Collection Involves removal of all impacted groundwater via pumping. Retained.

Treatment Involves the treatment of groundwater, ex situ, by conventional groundwater treatment methods. Retained.

Discharge Involves discharge of treated groundwater via surface water, groundwater, or sewer system. Retained.

400149

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

No Action No Further None No action May result in exposure of future Action groundwater users; does not meet RAOs; required for comparison by NCP.

Monitoring Groundwater Continued Monitoring of Technically Not Applicable Good Low/Low Potentially applicable in Sampling groundwater contaminant trends implementable conjunction with other sampling and and fate and transport technologies. laboratory over time. analysis

Monitoring Pre-Design Groundwater Collection of additional Technically Not Applicable Good Low/Low Potentially applicable in Investigations collection groundwater data to implementable conjunction with other and determine the potential technologies. laboratory effectiveness of analysis options for bench-scale testing.

Institutional Groundwater Access Property in the Technically Demonstrated Good Low/Low Potentially applicable in Controls Use restrictions to Classification implementable conjunction with other Restrictions groundwater Exception Area (CEA) technologies. impacted by contaminated groundwater would require restrictions on groundwater use.

Alternate Municipal Connection Involves connecting Technically Demonstrated Good Medium/Low Potentially applicable in Water Supply Supply Well to public homes within the OU2 implementable conjunction with other Connection water supply Study Area to technologies. Also considered in system. municipal water and conjunction with private well abandoning existing head treatment, depending on private wells. location and access to municipal supply.

PAGE 1 OF 6 400150

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

Private Well Point Of Treats Treatment of private Technically Demonstrated Good Low/Low Potentially applicable in Treatment Entry private wells wells prior to onsite implementable conjunction with other Treatment at the well use. technologies. Also considered in Systems head conjunction with municipal supply well connections, depending on location and access to municipal supply.

Monitored Monitored Monitored Use of naturally Technically Demonstrated Good Low/Low Potentially feasible either as Natural Natural natural occurring physical, implementable stand-alone remedy or in Attenuation Attenuation attenuation of chemical and biological conjunction with other (MNA) groundwater. processes such as technologies. dispersion, biodegra- dation and retardation to reduce concentrations of contaminants.

Containment Passive Slurry or Physical barrier to Not technically Demonstrated Poor Moderate/ It is not feasible to install Hydraulic Sheet-pile groundwater implementable Low containment walls into Controls Wall migration. bedrock and there is no low permeability layer to key into.

Containment Vertical Grout Create subsurface Not technically Fair Poor High/NA Not sufficiently effective or Subsurface Curtain barrier to horizontal implementable cost competitive for depths Barriers GW flow by grout required. injection.

Containment Pumping Passive Use of low-volume Not technically Fair Poor Medium/ Not applicable for the OU2 pumping to pumping to control implementable High Study Area; the entire control hydraulic gradients for OU2. impacted plume in the OU2 groundwater and limit source Study Area is at low gradients migration. concentrations and has no defined source.

PAGE 2 OF 6 400151

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

In Situ In Situ Oxidation Inject/extract oxidants Technically Demonstrated Fair. High/Low Potentially feasible for TCE. Treatment Oxidation to degrade implementable in high Would require treatability testing. contaminants. Typical permeability May be difficult to implement oxidants include aquifers. because of 1) limited delivery ozone, hydrogen options in fractured bedrock, and peroxide, potassium 2) potential to degrade the water permanganate, sodium quality of the aquifer by permanganate and increasing chromium sodium persulfate. concentration. Also may be difficult due to low concentrations seen in OU2 Study Area (effectiveness of in situ options decrease with lower concentrations).

In Situ Physical- Air Sparging Inject air into Technically Potential Fair Moderate/ Depth of contamination and Treatment Chemical groundwater implementable Moderate media (fractured bedrock) may cause problems for implementation and ensure capture of vapors.

In Situ Physical- Reduction Degrade Technically Demonstrated Poor High/High Not feasible due to high cost Treatment Chemical contaminants by implementable. in high and potential degradation of chemical reduction. permeability groundwater quality. Typical Addition of reducing aquifers. zero valent iron dosage is agents such as zero 0.5% of soil mass. This valent iron (ZVI) to dosage results in very high generate hydrogen cost. Also ZVI results in used in the reductive reducing conditions and dechlorination of elevated dissolved iron that TCE. will degrade the quality of the groundwater used as a drinking water source.

PAGE 3 OF 6 400152

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

In Situ Biological Enhanced Degrade Technically Demonstrated Poor High/High Not feasible. The large amount Treatment Reductive contaminants by implementable. in high of substrate required to result Dechlorinati stimulating biological permeability in reducing conditions makes on growth through aquifers. this a very expensive addition of an technology for unsaturated organic substrate zone soil. Also the reducing such as edible oil, or conditions cause elevated lactate. The dissolved iron that will biodegradation of the degrade the quality of the substrate liberates groundwater. hydrogen, which is then used as the electron donor in reductive dechlorination of TCE.

In Situ Biological Permeable Install downgradient Very difficult to Potential Poor High/High Wall would have to be Treatment Treatment treatment trenches to implement. constructed to a depth in Beds remove or degrade excess of 200 feet, the last 100 contaminants. feet through bedrock. This is not reasonably achievable with existing trench excavation technology.

In Situ Biological Air Sparging Inject air into Not technically NA NA NA Not applicable to compounds Treatment groundwater implementable such as TCE because they are for TCE and PCE poorly degradable under because they do aerobic conditions that would not degrade be present aboveground. adequately under aerobic conditions.

PAGE 4 OF 6 400153

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

In Situ Thermal Steam Inject steam, Technically Poor Poor High/High Not cost effective for low Treatment Injection/ collect/treat, implementable effectiveness concentration VOCs. SVE gases/liquids in fractured bedrock.

Collection Extraction Wells Install wells to extract Technically Demonstrated Good Moderate/ Feasible. contaminated implementable Low groundwater. Can be utilized as either active treatment or passive hydraulic controls.

Treatment Physical- Air Stripping Phase separation by Technically Demonstrated Good Low/ Feasible. Chemical forced air implementable Moderate

Treatment Physical- Steam Phase separation by Technically Potential Fair High/High Not cost effective for low Chemical Stripping steam and forced air implementable concentration VOCs.

Treatment Physical- Adsorption Treat with GAC or Technically Demonstrated Good Moderate/ Cost effective for vapor-phase Chemical other adsorptive media implementable Low treatment, if used in conjunction with air stripping.

Treatment Physical- Oxidation Chemical, photo, or Technically Potential Good Moderate/ Not cost effective compared to Chemical other oxidation implementable High air stripping for low concentration VOCs.

Treatment Physical- Ion Treat with selected Technically Potential Fair High/High Treatability testing required; Chemical Exchange resins implementable more costly than GAC.

Treatment Physical- Reverse Remove Difficult Potential Poor High/High Costly technology when Chemical Osmosis contaminants by operation, not compared to other options. forcing water through effective for High O&M costs related to high pressure organics system operations. membrane

PAGE 5 OF 6 400154

TABLE 3-2 Technology/Process Option Evaluation—Groundwater PVGCS OU2 Study Area Feasibility Study Technologies in bold have been determined to be impractical remediation options and were not retained for inclusion in remedial alternatives.

Technical General Implementability Technical and Response Remedial Process Screening Administrative Capital/ O&M Action Technology Options Description Comments Effectiveness Implementability Cost Screening Comments

Treatment Physical- Liquid/Liqui Extract contaminants Very high Potential Poor High/High Costly technology when Chemical d Extraction based on solubility concentrations compared to other options. required High O&M costs related to system operations.

Treatment Biological Aerobic Degrade Technically Potential Good High/High TCE and PCE do not contaminants using implementable sufficiently degrade aerobic microbes aerobically. However treatment in a biological treatment POTW can be effective because removals are achieved through volatilization and adsorption on sludge.

Discharge Surface Storm Sewer Discharge treated Technically Demonstrated Fair Moderate/ Potentially feasible although System water to Storm Sewer implementable Moderate treated water needs to be System injected into aquifer to maintain available water supply.

Discharge Sewer Publicly Discharge untreated Technically Demonstrated Fair Low/Low Potentially feasible although Owned water to POTW implementable treated water needs to be Treatment injected into aquifer to maintain Works available water supply. (POTW)

Discharge Subsurface Injection Pump treated Technically Demonstrated Good Moderate/ Potentially feasible. Would Wells groundwater back into implementable High require permitting. subsurface

Discharge Subsurface Infiltration Discharge treated Technically Demonstrated Fair Moderate/ Not feasible. Low permeability groundwater into implementable High soils do not allow sufficient infiltration basins/ infiltration to accept high flow trenches rates.

PAGE 6 OF 6 400155 TABLE 4-1 Groundwater Remedial Alternatives Developed for Screening PVGCS OU2 Study Area Feasibility Study Groundwater Groundwater Groundwater Alternative Groundwater Alternative Groundwater Groundwater Alternative 4 Alternative 1 Alternative 2a 2b 3a Alternative 3b

No Action Monitored Natural MNA, Institutional In Situ Upgradient In Situ Upgradient Entire Plume Collection and Attenuation (MNA), Controls, and Public Treatment, Private Well Treatment, Public Treatment (Evaluated for Institutional Water Supply Head Treatment, and Water Supply OU1) Controls, and Private Connection MNA Connection, and MNA Well Head Treatment

Elements involved: Elements involved: Elements involved: Elements involved: Elements involved:

• Groundwater • Groundwater • Groundwater • Groundwater • Groundwater Sampling Sampling Sampling Sampling Sampling • Pre-Design Investigations • Groundwater Use • Groundwater Use • Pre-Design • Pre-Design Restrictions Restrictions Investigations Investigations • Groundwater Use Restrictions • Point of Entry • Public Water Supply • Groundwater Use • Groundwater Use Treatment Connection Restrictions Restrictions • Public Water Supply Well Systems (POETS) Connection • POETS for outlying • POETS • Public Water Supply • MNA areas (if needed) Connection • POETS for outlying areas • In Situ Oxidation (if needed) • MNA (ISO) in localized, • ISO in localized, upgradient area (i.e., upgradient area (i.e., • Groundwater Collection, Fault zone) Fault zone) Treatment and Discharge

• MNA • POETS for outlying • This is a qualitative areas (if needed) assessment relying on OU1 assessment • MNA

400156

TABLE 5-1 Detailed Evaluation of Groundwater Media Alternatives PVGCS OU2 Study Area Feasibility Study Criterion Groundwater Alternative Groundwater Alternative 2a Groundwater Alternative 2b Groundwater Alternative 3a Groundwater Alternative 3b No Further Action Monitored Natural Attenuation, Institutional Monitored Natural Attenuation and Institutional Controls, and In Situ Upgradient Treatment, Private Well In Situ Upgradient Treatment, Public Water Controls, and Private Well Head Treatment Public Water Supply Connection Head Treatment, and MNA Supply Connection and MNA • TCE are expected to persist in • Human health is protected by this alternative • Human health is protected by this alternative by connecting homes • This alternative actively reduces the • This alternative reduces the concentrations of groundwater at concentrations by POETS. within the OU2 Study Area to the municipal water system. concentrations of TCE at the OU1/OU2 TCE in groundwater at the OU1/OU2 boundary; exceeding the NJ GWQS decades. boundary; while this active reduction will aid in while this active reduction will aid in overall • This alternative reduces the concentrations • This alternative reduces the concentrations of TCE in groundwater However, because monitoring is not overall groundwater conditions, the timeframe groundwater conditions, the timeframe to meet of TCE in groundwater through MNA, thus through MNA, thus reducing the timeframe until the NJ GWQS are included in this alternative, it will be to meet the NJ GWQS is assumed to be 67 the NJ GWQS is assumed to be 67 years due to reducing the timeframe until the NJ GWQS met to about 67 years. impossible to tell when GWQS are years due to impacts from the OU1 Study impacts from the OU1 Study Area migrating into are met. Based on MNA modeling, this will met. • The potential for human exposure to contaminated groundwater will Area migrating into the OU2 Study Area. the OU2 Study Area. occur in approximately 67 years. be minimized through public water supply connections and • There is a potential for human • The potential for human exposure to • The potential for human exposure to • The potential for human exposure to institutional controls for groundwater. exposure to contaminated contaminated groundwater will be minimized contaminated groundwater will be minimized contaminated groundwater will be minimized groundwater under this alternative through POET installation and institutional through public water supply connections and through POET installation and institutional because some homeowners are controls for groundwater. institutional controls. controls for groundwater. currently using groundwater for potable purposes. Would meet ARARs when TCE Would meet ARARs when the NJ GWQS are Would meet ARARs when the NJ GWQS are met. Under this alternative, • Would meet ARARs when the NJ GWQS are • Would meet ARARs when the NJ GWQS are concentration in groundwater does not met. Under this alternative, this would take 67 this would take approximately 67 years for downgradient portion of met. Under this alternative, this would take met. Under this alternative, this would take 67 exceed NJ GWQS, which could take years for downgradient portion of plume. plume. approximately67 years, due to the potential years for downgradient portion of plume, due to decades. for impacts migrating from the OU1 Study the potential for impacts migrating from the OU1 Area. Study Area. • Action-specific ARARs (permitting) would • Action-specific ARARs would need to be need to be considered for injection of oxidant considered for injection of oxidant materials at materials at the OU1/OU2 boundaries. the OU1/OU2 boundaries. (a) Magnitude of No significant change in risk because no Residual risks will be eliminated by eliminating Residual risks will be eliminated by eliminating exposure to contaminated Residual risks will be eliminated by eliminating Residual risks will be eliminated by eliminating residual risks action taken. Reduction in risk relating to exposure to contaminated water through POETS. water through public water supply. exposure to contaminated water through POETS. exposure to contaminated water either through TCE contamination in groundwater public water supply. exceeding groundwater GWQS would occur slowly, and may take decades. (b) Adequacy and Not applicable. Requires reliance on institutional controls for Requires reliance on institutional controls for groundwater. These Requires reliance on institutional controls for Requires reliance on institutional controls for reliability of groundwater. These controls will be necessary controls will be necessary for decades under this alternative. groundwater during remedial actions. These groundwater. These controls will be necessary for controls for decades under this alternative. Effectiveness Effectiveness will depend on all homeowners agreeing to connect to controls will be necessary for decades under this decades under this alternative. Effectiveness will will depend on all homeowners agreeing to install municipal water supply. alternative. Effectiveness will depend on all depend on all homeowners agreeing to connect to and maintain POETS. homeowners agreeing to install and maintain public water supply. POETS. (c) Treatment None. None. None. While reduction will occur through in situ While reduction will occur through in situ treatment, process used treatment, potential impacts from the OU1 Study potential impacts from the OU1 Study Area are may Area are may migrate into the OU2 Study Area, migrate into the OU2 Study Area, thus reducing the thus reducing the overall reduction of overall reduction of contaminants. contaminants. (d) Degree and The NJ GWQS would eventually be met The NJ GWQS would eventually be met through The NJ GWQS would eventually be met through natural attenuation, Groundwater treatment should reduce the highest Groundwater treatment should reduce the highest quantity of TMV through natural attenuation, although the natural attenuation, although the process may although the process may take over 67 years. groundwater TCE concentration of 31 µg/L initially groundwater TCE concentration of 31 µg/L initially reduction process may take decades to occur. take over 67 years. after treatment. However, given the likelihood of after treatment. However, given the likelihood of further loadings from other sources, treatment further loadings from other sources, treatment may may continue for decades (assumed in this FS for continue for decades (assumed in this FS for 67 67 years). years). (e) Irreversibility of Natural degradation of the plume is Natural degradation of the plume is irreversible. Natural degradation of the plume is irreversible. • Treatment is irreversible. Contaminants • Treatment is irreversible. Contaminants TMV reduction irreversible. oxidized would be removed irreversibly during oxidized would be removed irreversibly during treatment. treatment. • Natural degradation of the remainder of the • Natural degradation of the remainder of the plume is irreversible. plume is irreversible. (f) Type and None. None. None. None. None. quantity of treatment residuals

PAGE 1 OF 2 400157

TABLE 5-1 Detailed Evaluation of Groundwater Media Alternatives PVGCS OU2 Study Area Feasibility Study Criterion Groundwater Alternative Groundwater Alternative 2a Groundwater Alternative 2b Groundwater Alternative 3a Groundwater Alternative 3b No Further Action Monitored Natural Attenuation, Institutional Monitored Natural Attenuation and Institutional Controls, and In Situ Upgradient Treatment, Private Well In Situ Upgradient Treatment, Public Water Controls, and Private Well Head Treatment Public Water Supply Connection Head Treatment, and MNA Supply Connection and MNA (g) Statutory Preference not met for groundwater Preference not met for groundwater because no Preference not met for groundwater because no treatment beyond Preference met for groundwater. • Preference met for groundwater source areas. preference for because no treatment beyond natural treatment beyond natural attenuation would natural attenuation would occur. • Preference not met for remainder of plume treatment as a attenuation would occur. occur. because no treatment beyond natural primary element attenuation would occur. (h) Protection of No remedial construction, so no risks to • Risks to workers can be minimized if proper • Risks to workers can be minimized if proper health and safety • Risks to workers can be minimized if proper • Risks to workers can be minimized if proper workers during workers. health and safety procedures are followed. procedures are followed. During remedial construction, workers health and safety procedures are followed. health and safety procedures are followed. remedial action During remedial construction, workers must must adhere to the health and safety plan to minimize exposure to During remedial construction, workers must During remedial construction, workers must adhere to the health and safety plan to groundwater contaminants during public water supply connections. adhere to the health and safety plan to adhere to the health and safety plan to minimize minimize exposure to groundwater minimize exposure to soil contaminants during exposure to contaminants during well • During remedial operations, risks to workers are limited to normal contaminants during POET installation. POET installation. installation. safety related risks related to treatment operations. • During remedial operations, risks to workers • During remedial operations, risks to workers • During remedial operations, risks to workers are are limited to normal safety related risks are limited to normal safety related risks limited to normal safety related risks related to related to treatment operations. related to treatment operations. treatment operations. (i) Protection of No remedial construction, so no short- • Health- and safety-related risks to community • Health- and safety-related risks to community are expected to be • Health- and safety-related risks to community • Health- and safety-related risks to community community term risks to community. are expected to be minimal. Treatment minimal. Treatment equipment will be designed to meet required are expected to be minimal. Treatment are expected to be minimal. Treatment during remedial equipment will be designed to meet required noise levels. equipment will be designed to meet required equipment will be designed to meet required action noise levels. noise levels. noise levels. • Safety-related risks to community during remedial operations may be • Safety-related risks to community during posed because of truck traffic to transport activated carbon. • Safety-related risks to community during • If poorly designed, the volume of water remedial operations may be posed because remedial operations may be posed because of generated by the public water supply may be • If poorly designed, the volume of water generated by the public of truck traffic to transport activated carbon. truck traffic to transport activated carbon. reduced. water supply may be reduced. (j) Environmental None. None. None. Environmental impacts during remedial operations Environmental impacts during remedial operations impacts of are limited to the minor truck traffic. This impact are limited to the minor truck remedial action should be minimal with appropriate air emission controls. (k) Time until RAOs • Attainment of NJ GWQS will take • Attainment of NJ GWQS will take • Attainment of NJ GWQS will take approximately 67 years. NJ GWQS would be met after approximately67 NJ GWQS would be met in source areas after are achieved decades, and will not be measurable approximately 67 years. years of operations, mainly due to the potential for approximately 67 years for TCE, mainly due to the • RAOs for the protection of human health will not be met until the NJ due to the lack of a monitoring impacts in the OU1 Study Area to migrate into the potential for impacts in the OU1 Study Area to • RAOs for the protection of human health will GWQS are achieved. program. OU2 Study Area. migrate into the OU2 Study Area. not be met until the NJ GWQS are achieved. • RAOs for the protection of human health will not be met until the NJ GWQS are achieved. (l) Technical No impediments. No impediments. No impediments. No impediments. No impediments. feasibility (m) Administrative No impediments. No impediments. No impediments. Will require permitting for in situ injection. Siting Will require local POTW to design and maintain feasibility the treatment facility may present challenges. larger public water supply system. (n) Availability of None needed. • Necessary engineering services and • Necessary engineering services and materials are readily available • Necessary engineering services and materials • Necessary engineering services and materials services and materials are readily available for installation for installation of the public supply wells. readily available for installation and operation readily available for installation of system. materials and operation of POETS. of system. • Resources are available to design and build the infrastructure and • Resources are available to design system • Resources are available to design and build connecting homes to the public supply well system. • Resources are available to design and build upgrades. the POET treatment system. the treatment system, although siting the plant may present challenges. Capital Cost $0 $2,344,000 $13,992,000 $3,644,000 $15,292,000 O&M Cost $0 $339,000 $77,000 $615,000 $352,000 Total Present Worth $0 $6,640,000 $15,040,000 $8,200,000 $16,590,000 Cost

PAGE 2 OF 2 400158 PHL \\CASTOR\PROJ\POHATCONG\GIS\ARCGIS\LAYOUTS\OU2 LAYOUTS\OU2_RI\FIGURE 1-1_FS.MXD IZMUDZIN 6/24/09

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Legend Figure 1-1 Location of the OU1/OU2/OU3 Study Areas Road Centerlines Franklin Township Pohatcong Valley Waterways Washington Borough Groundwater Contamination Site USEPA Pohatcong OU1 Study Area Washington Township OU-2 Feasibility Study Pohatcong Valley, NJ Approximate USEPA Pohatcong OU2 Study Area Greenwich Township Approximate USEPA Pohatcong OU3 Study Area 00.5 1 2 Miles

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Legend Figure 1-2 OU2 Study Area Greenwich Township Franklin Township Pohatcong Valley NJDEP Well Restriction Boundary Washington Borough Groundwater Contamination Site USEPA Pohatcong OU1 Study Area Washington Township OU-2 Feasibility Study ´ Pohatcong Valley, NJ Approximate USEPA Pohatcong OU2 Study Area Road Centerlines Waterways 0 0.25 0.5 1 Miles

400160 PHL \\CASTOR\PROJ\US EPA REGION 2\164440_POHATCONG OU1\USGS FIGURE UPDATES\OU2_FIGURE1_2B_10April10.MXD JGOULD 4/10/10 .. 1 2 3

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Sample9.5 Number TCE (ug/m3) PCE (ug/m3) .. 192-0034 0.3U 1.28 34 8 192-0035 0.28U 0.36

192-0036 0.28U 0.36 5 .. Sample Number TCE (ug/m3) PCE (ug/m3) Sample Number TCE (ug/m3) PCE (ug/m3) 192-0009 70.82 2.93J 192-0019 7.8 7.9

192-0015 920 31 2 192-0024 18 12 *# .. 31

1.3 192-0016 11 0.63 *#3 192-0025 0.17U 0.21U

192-0017 9 0.48 192-0018 0.18U 0.23U .. *#20 ABR 20 Sample Number TCE (ug/m3) PCE (ug/m3) *#

25.1 2.0 HARMONY TWP 192-0032 0.34U 30 .. # 2.4 AL * Sample Number TCE (ug/m3) PCE (ug/m3) 2.1 N 6 A 192-0023 340 16 C *# 15.8

IS 4.6 192-0027 2.2 0.44U R Sample Number TCE (ug/m3).. PCE (ug/m3) R 5.9 O 192-0028 0.32U 0.4 3.3 M 192-0020 110 6.6 R 192-0029 1.18U 0.38U E 2.1

M 192-0021 0.27 0.54 0.9 R .. 192-0030 680 30 FO 192-0022 57 11 9.5

192-0028a 63.6 11.9 P .. 192-0029a 0.411J 0.309J 15 W 9.3 T P 192-0030a 0.335 0.561 57 Y W 16

N T E 192-0031a 0.485 0.222J

O T IN R .. ND - Note: Well sampled several times M L 192-0032a 122 6.67 R K with ND Result. A one-time A N 192-0033a 1.82 1.64 H A R sample result of 216 ug/L was

F 192-0034a 2.79 0.185J .. unconfirmed. 192-0035a 2.78 0.301J 2.5 192-0036a 0.342 0.160J

1.33 192-0037a 0.285 0.262J 0.7 .. 192-0038a 1.08 0.249J 192-0039a 3 0.355 1.09 1.44

192-0040a 1.3 0.292J HARM 1 .. ONY T 0.76 WP 0.66 1.2 192-0058 21 0.48U G 1.1 REENW 0.63 ICH TWP 1.55 2.7 192-0059 0.2J 0.2J 1.2 ND

1.5 0.52 192-0060 0.3 0.3J 1.8 0.77 .. 1.32 192-0061 28 4.4 1 ND 2.1 0.89 1.4 2.9 192-0062 0.5 0.3J

0.41 .. 192-0063 0.2J 0.2J 1.8 ND 0.97 1.1 0.99 192-0064 0.269U 0.2J 2.1 11 192-0065 0.5 0.7

ND ND *#4.94 .. MWO 192-0066 0.2J 0.3J Sample Number TCE (ug/m3) PCE (ug/m3) 1.14 5.52 12.8 9.01 ND 192-0067 0.37U 0.6 ND 192-0001 4.67U 1.99J ND 4.05 ND 192-0068 0.43 0.46 ND

7.86 *# 11 ND 11.4 .. ND

Sample Number TCE (ug/m3) PCE (ug/m3) 192-0007 8.58U 10.9U .. 192-0008 4.08U 5.17U 11.4

4 0.54 5.9 .. ND 10.9 ND 1.1 ND 0.65 ND ND 4.2 10.84

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1.61 0.3 ND ND LOPATCONG TWP 0.76 .. 1.9 ND 6.9 Sample Number TCE (ug/m3) PCE (ug/m3) 8

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Sample Number TCE (ug/m3) PCE (ug/m3) 2.1 1.6 ND 0.88 1.6 .. 1.9 192-0011 4.08U 5.17J *# 3.59 0.58 3.8 ND 0.52 3.8 ND ND 0.76 2.8 *# 3 3.48 2 ND 0.7 2.5 2.5

3.1 0.25 0.74 .. Sample Number TCE (ug/m3) PCE (ug/m3) ND ND 0.78 ND ND 192-0003 4.24J 1.36J 1.6 0.54 1.1 192-0004 4.08U 5.17U ND 0.37 ND ND 2.4 ND 0.22

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Legend Notes regarding Data Sources, Data Quality, and Sample Locations: Figure 2-1 All TCE concentrations in micrograms per liter (ug/L). NJDEP Data: Trichloroethene Plume Map *# Sub-Slab Vapor Intrusion Sample Location .. Karrsville Thrust Fault Pohatcong OU1 Study Area If multiple samples were taken from the same location, 1995-2008: Data collected by NJDEP for various studies in the highest TCE concentration detected was reported. Pohatcong Valley. These data were obtained by various Table Highlights OU2 Feasibility Report Well Sampled by USEPA OU2 Remedial Investigation (2005 - 2008) Streams Approximate Pohatcong OU2 Study Area Unless specifically defined, it is unknown if QA/QC branches of the NJDEP, including the Bureau of Groundwater Pohatcong Valley, NJ samples were collected or analytical data were validated. Pollution Abatement (1997-1998), the Bureau of Site Management Also, sample locations were either defined through Global (1997-1998), and the Office of Wellfield Remediation (2002-2003). Well sampled by USEPA OU1 Remedial Investigation (1999-2002) Former Morris Canal Waterbodies Positioning System (GPS) survey or estimated using block/lot of TCETCE Yellow >2 . 7 ug / m3 Yellow >5 ug/m3 property and digital aerial photos. Warren County Health Dept: Well sampled by Warren County Health Dept. (1984-2005) Pohatcong and Merrill Creeks Township Boundaries 1984-2005: Specific sources and collection dates of USEPA Data: data uncertain. ´ Well sampled by NJDEP (1995-2008) Roads 1999 to 2002: Data collected by USEPA for Pohatcong Valley

Groundwater Contamination Superfund Site Remedial Investigation. PCETCE R ed >50 ug/m3 Red >100 ug/m3 0.5 0.25 0 0.5 Miles 5 ug/L TCE Isoconcentration Contour (Approximate Location) NJ State Route 57 QA/QC samples were collected and all analytical data were validated. T = Trichloroethene Sample locations defined through GPS survey. P = Tetrachloroethene 5 ppb U = Flag used for Not Detected. Method Detection Limit shown. J = Flag used for detection of compound at an estimate value between 1 ppb the Method Detection Limit and the Reporting Limit 400161 400162 n PHL \\CASTOR\PROJ\POHATCONG\GIS\ARCGIS\LAYOUTS\OU2 LAYOUTS\OU2_RI\FIGURE 2-1.MXD JGOULD 12/10/2008 16:29:30 ntai Mou

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Legend Figure 4-2 Alternative 2a Greenwich Township Franklin Township MNA, Institutional Controls, and Private Well Head Treatment NJDEP Well Restriction Boundary Washington Borough OU2 Study Area Pohatcong Valley Area to Install POETs as Required Washington Township ´ Groundwater Contamination Site USEPA Pohatcong OU1 Study Area Waterways OU-2 Feasibility Study 0 0.25 0.5 1 Pohatcong Valley, NJ Approximate USEPA Pohatcong OU2 Study Area Road Centerlines Miles

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Sp l ne Good w r e od v o Vie le PVRHR01 G n Rache tai Wil A! ove Rd.Wil un Cana Gr o Willo w lo M w Grove o w Grove As l l l n Iron oo to Wil h b ple Herle Fran Sc ury Ma ing M Arbo man Wo g Debr ill in a klin t Inscho

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Figure 4-3 Legend Alternative 2b A! MNA, Institutional Controls, and Alternate Public New Well Locations USEPA Pohatcong OU1 Study Area Water Supply/Municipal Well Connection Road Centerlines Approximate USEPA Pohatcong OU2 Study Area OU2 Feasibility Report Waterways Proposed Extent of New Water Main Pipeline ´ Pohatacong Valley, NJ 0 0.25 0.5 1 Miles

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Legend Figure 4-4 USEPA Pohatcong OU1 Study Area Alternative 3a Approximate USEPA Pohatcong OU2 Study Area In Situ Upgradient Hotspot Treatment, Road Centerlines Private Well Head Treatment, and MNA Upgradient Hot Spot OU2 Feasibility Report Waterways Greenwich Township Pohatcong Valley, NJ Franklin Township ´ Washington Borough Washington Township 0 0.5 1 2 Miles

400165 PHL \\CASTOR\PROJ\POHATCONG\GIS\ARCGIS\LAYOUTS\OU2 LAYOUTS\FIGURE _-_ ALTERNATIVE 2B - FS.MXD JGOULD 12/10/2008 16:04:11 n A sbur Area to be Treated Using ISCO ountai Warren

County e Whi y Broadw Washington ag Washington te cong M Township Vill s OU1 Borough Canal PVABR03 A! ohat Franklin is A! PVABR02 P Greenwich Township A! Township orr M PVABR01 ay mer Rd. or F Fou New Jersey Tha rth Cole rd PVMWO07 rm tche Thi A! r Fox Fa Lau As 7 ren Edi h n bu s ry Bro e Hwy 5 o Stat n E Hoffma e di adwa y 57 rtsvill son Rd. ay fside ClifQ ow Stewa u ll arr

Highw y tate Lows Ho S Rd. Richli A! ton ing PVQUA01 Edi ne n Wash s ings Hil o r n Bea OU2 l Sp Kitche Hulshizer erson c Richli gs son o Plane And Edi n rin

Sp l ne Good w r e od v o Vie le PVRHR01 G n Rache tai Wil A! ove Rd.Wil un Cana Gr o Willo w lo M w Grove o w Grove As l l l n Iron oo to Wil h b ple Herle Fran Sc ury Ma ing M Arbo man Wo g Debr ill in a klin t Inscho

s

Wash lf as CarlBril r m Adri r e ue Tho l m

an Ful Peq ne wich A! n en Price re rga s o ry G PVSMS01 M e Ga Tyler m Lin a coln J

Revere Woo own Jackson nt M Hamilt e ga WynhFan h lvert n Lea Unio on ni M ain on Yv el am Fang Dumon Cook MillDori ury o Dani b nn t oms e rm Blo

Legend Figure 4-5 Alternative 3b A! New Well Locations USEPA Pohatcong OU1 Study Area In Situ Upgradient Hotspot Treatment, Alternate Public Upgradient Hot Spot Approximate USEPA Pohatcong OU2 Study Area Water Supply/Municipal Well Connection, and MNA Road Centerlines Proposed Extent of New Water Main Pipeline OU2 Feasibility Report Waterways ´ Pohatacong Valley, NJ 0 0.25 0.5 1 Miles

400166 400167

Appendix A Potential Applicable or Relevant and Appropriate Requirements

400168 Appendix A Potential Chemical-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Resource Conservation Identification and Listing of 40 CFR 261 Defines those solid wastes which are subject to ARAR for wastes or treatment and Recovery Act Hazardous Waste regulation as hazardous wastes under 40 CFR Parts residues which are hazardous as 262-265 and 270. defined by RCRA and are to be disposed of off-site.

Federal Safe Drinking National Primary Drinking Water 40 CFR 141 Establishes health-based standards for public ARAR because the site groundwater Water Act Standards - Maximum drinking water systems. Also establishes drinking aquifer is classified as a Class IIA Contaminant Level Goals water quality goals set at levels at which no adverse Source of Drinking Water. The MCLs (MCLGs) and Maximum health effects are anticipated, with an adequate have been applied to the remediation Contaminant Levels (MCLs) margin of safety. The NCP specifically states that of groundwater. MCLs will be used as ARARs for useable aquifers rather than the more stringent MCLGs.

Federal Safe Drinking National Secondary Drinking 40 CFR 143 Establishes standards for public drinking water To Be Considered (TBC). Secondary Water Act Water Standards-Secondary systems for those contaminants which impact the MCLs are based on aesthetic criteria MCLs aesthetic qualities of drinking water (secondary and do not reflect public health MCL). concerns. They are considered TBC and will be attained where possible.

Quality Criteria for Water Water Quality Criteria 40 CFR 131 Sets criteria for water quality based on toxicity to TBC. Water is discharged to surface Quality Criteria aquatic organisms and human health. water, these are used in setting for Water, 1976, effluent discharge limits. 1980, and 1986

Federal Clean Water Act; Toxic Pollutant Effluent 40 CFR 129 Establishes effluent standards or prohibitions for ARAR if toxic pollutants are in National Pollution Standards certain toxic pollutants; I.e., aldrin/dieldrin, DDT, groundwater requiring treatment. Discharge Elimination DDD, DDE, endrin, toxaphene, benzideine, and System (NPDES) PCBs.

National Ambient Air Ambient Air Quality Standards 40 CFR 50 Defines air quality levels adequate to protect public Potential ARAR for remedial Quality Standards health/welfare. Defines emissions limitations for alternatives resulting in air emissions (NAAQS) sulfur oxides, particulate matter, carbon monoxide, if these toxic polluntants are present. ozone, nitrogen oxide, and lead.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA from a site in Manville, New Jersey (June 2003). Page 1 of 13

400169 Appendix A Potential Chemical-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Federal Resource Groundwater Protection 40 CFR 264, Establishes standards for groundwater protection for ARAR. These maximum Conservation and Standards and Maximum Subpart F several metals and pesticides. concentration limits are applicable to Recovery Act Concentration Limits RCRA regulated units and are considered relevant and appropriate.

State of New Jersey Groundwater Quality Standards N.J.A.C. 7:9-6 Establishes standards for the protection of ambient ARAR for Class IIA aquifers. Statutes and Rules Groundwater groundwater quality. Used as the primary basis for Quality setting numerical criteria for groundwater cleanups. Standards

Safe Drinking Water Act Maximum Contaminant Levels A-280 Establishes State criteria for drinking water. Potential ARAR is State MCLs are (SDWA) Maximum Amendments more stringent than Federal MCLs. Contaminant Levels (MCLs)

State of New Jersey Groundwater Quality Standards N.J.A.C. 7:9-6 Establishes standards for the protection of ambient ARAR. Statutes and Rules Groundwater groundwater quality. Used as the primary basis for Quality setting numerical criteria for groundwater cleanups Standards and discharges to groundwater.

State of New Jersey Drinking Water Standards- N.J.A.C. 7:10 Establishes MCLs that are generally equal to or more ARAR. The Site aquifer is a drinking Statutes and Rules Maximum Contaminant Levels Safe Drinking stringent the SDWA MCLs. water supply source. (MCLs) Water Act

State of New Jersey National Secondary Drinking N.J.A.C. 7:10-7 Establishes standards for public drinking water TBC. Secondary MCLs are based on Statutes and Rules Water Standards-Secondary Safe Drinking systems for those contaminants which impact the aesthetic criteria and do not reflect MCLs Water Act aesthetic qualities of drinking water. public health concerns. They are considered TBCs in that they will be attained where possible.

New Jersey Pollutant Surface Water Discharge N.J.A.C. 7:14a Establishes discharge standards when written into Potential ARAR if treated water is Discharge Elimination Criteria permits. discharged to surface water. System (NJPDES)

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA from a site in Manville, New Jersey (June 2003). Page 2 of 13

400170 Appendix A Potential Chemical-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability New Jersey Pollutant Permitting for discharge of N.J.A.C. 7:14a General Permit for Ground Water Petroleum Product Potential ARAR if treated water is Discharge Elimination treated Groundwater to Surface Clean Up Discharge (B4B) discharged to surface water. System (NJPDES) Water

Surface Water Criteria New Jersey Criteria for Surface N.J.A.C. 7:9-4 Criteria for surface water classes Potential ARAR if treated water is Water Quality discharged to surface waters.

New Jersey Pollutant Permitting for discharge of N.J.A.C. 7:14a Individual NJPDES Discharge to Groundwater Potential ARAR if treated water is Discharge Elimination treated Groundwater to Permit (DGW) discharged to ground water. System (NJPDES) groundwater

New Jersey Pollutant Discharge to Local Publicly N.J.A.C. 7:14a Discharge standards, and POTW acceptance Potential ARAR if treated water is Discharge Elimination Owned Treatment Works and criteria. discharged to the local POTW.. System (NJPDES) (POTW) POTW Regulations

Prohibition of Air Air Quality Standards N.J.A.C. 7:27-5 Prohibits air pollution and establishes ambient air Potential ARAR for remedial Pollution and Ambient Air and quality standards alternatives which include Quality Standards N.J.A.C.7:27-13 technologies that result in air emissions.

Prohibition of Air Air Permitting Regulations N.J.A.C. 7:27-8 Air permit requirements for Minor Facilities (and Potential ARAR for remedial Pollution and Ambient Air and Major Facilities without an Operating Permit), and alternatives which include Quality Standards N.J.A.C.7:27-22 Major Facilities with an Operating Permit. technologies that result in air emissions.

N.J.E.P. Division of Water Supply Allocation Rules N.J.A.C. 7:19 Regulates new water supply connections and Potential ARAR for Alternate Public Water Supply extensions, responsible for managing New Jersey’s Water Supply/Municipal Well water supply Connection

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA from a site in Manville, New Jersey (June 2003). Page 3 of 13

400171 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Discharge of Groundwater or Wastewater

Federal Clean Water Act National Pollution Discharge 40 CFR 122 Issues permits for discharge into navigable waters. ARAR, although state ARAR takes Elimination System (NPDES) and 125 Establishes criteria and standards for imposing precedence for discharge permit. treatment requirements on permits. Disposal of groundwater to the surface water. NPDES permit may not be required since New Jersey has an approved SPDES permit program (NJDPES).

Federal Clean Water Act General Pretreatment 40 CFR 403 Prohibits discharge of pollutants to a POTW which ARAR. Discharge of pollutants Regulations for Existing and New cause or may cause pass-through or interference including those that could cause fire Sources of Pollution with operations of the POTW. or explosion or result in toxic vapors or fumes to POTW.

Federal Clean Water Act Effluent Guidelines and 40 CFR 414 Requires specific effluent characteristics for ARAR, although state ARAR takes Standards for the Point Source discharge under NPDES permits. precedence for discharge permit. Category Disposal of groundwater to the surface water. NPDES permit may not be required since New Jersey has an approved SPDES permit program (NJDPES).

Federal Safe Drinking Underground Injection Control 40 CFR 144 Establishes performance standards, well Potential ARAR if remedial alternative Water Act Program requirements, and permitting requirements for includes discharge of treated groundwater re-injection wells. groundwater to potable water supply aquifer. May also apply to the injection of surfactants or oxidants into the aquifer.

Federal Clean Water Act Ambient Water Quality Criteria 40 CFR 131.36 Establishes criteria for surface water quality based Potential ARAR if remedial alternative on toxicity to aquatic organisms and human health. includes groundwater discharge to surface water. Federally-approved New Jersey groundwater and surface water standards take precedence over the Federal criteria.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 4 of 13 400172 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Federal Clean Water Act Water Quality Criteria Summary Includes non-promulgated guidance values for Potential ARAR if remedial alternative surface water based on toxicity to aquatic organisms includes groundwater discharge to and human health. Issued by the EPA office of surface water. Supplements above- Science and Technology, Health and Ecological referenced Ambient Water Criteria. Criteria Division.

Water Pollution Control Protection of water 33 U.S.C. 1251 Protects and maintains the chemical, physical, and Potential ARAR for remedial actions Act biological integrity of the nation's water. which may affect water quality.

Water Treatment and Disposal

Effluent Limitations Discharge requirements 33 U.S.C. 1251 Technology-based discharge limitations for point Potential ARAR for remedial actions Section 301 sources of conventional, nonconventional, and toxic which include discharge of pollutants. wastewater.

Water Quality Related Discharge requirements 33 U.S.C. 1251 Protection of intended uses of receiving waters (e.g., Potential ARAR for remedial actions Effluent Limitations Section 302 public water supply, recreations uses). which include discharge of wastewater.

Toxic and Pretreatment Pretreatment standards for 33 U.S.C. 1251 Establishes list of toxic pollutants and promulgates Potential ARAR for remedial actions Effluent Standards discharge into POTWs. Section 307 pretreatment standards for discharge into POTWs. which include discharge of wastewater.

National Pollutant Permitting for discharge into 33 U.S.C. 1251 Issues permits for discharge into navigable waters. Potential ARAR for remedial actions Discharge Elimination navigable waters. involving discharge to surface water. System (NPDES)

Disposal of Dredged and Requires permitting of discharges 33 U.S.C. 1251 Requires permitting of discharges of dredged and fill Potential ARAR for remedial Fill Material of dredged and fill material to Section 404 material to navigable waters. alternatives which require discharge navigable waters. of dredged and fill material to navigable waters.

State of New Jersey The New Jersey Pollutant N.J.A.C. 7:14A Establishes standards for discharge of pollutants to ARAR. New Jersey has a state Statutes and Rules Discharge Elimination System surface and groundwaters. approved program. Disposal of treated groundwater to surface water.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 5 of 13 400173 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability State of New Jersey Groundwater Quality Standards N.J.A.C. 7:9-6 Establishes standards for the protection of ambient ARAR. Disposal of treated Statutes and Rules Groundwater groundwater quality. Used as the primary basis for groundwater by reinjection. Quality setting numerical criteria for groundwater cleanups Standards and discharges to groundwater.

New Jersey Pollutant Permitting for discharge of N.J.A.C. 7:14a Individual NJPDES Discharge to Groundwater Potential ARAR if treated water is Discharge Elimination treated Groundwater to Permit (DGW) discharged to ground water. System (NJPDES) groundwater

State of New Jersey Surface Water Quality Standards N.J.A.C. 7:9B Establishes standards for the protection and ARAR. Disposal of treated Statutes and Rules Surface Water enhancement of surface water resources. groundwater by discharge to surface Quality water. Standards

New Jersey Pollutant Permitting for discharge of N.J.A.C. 7:14a General Permit for Ground Water Petroleum Product Potential ARAR if treated water is Discharge Elimination treated Groundwater to Surface Clean Up Discharge (B4B) discharged to surface water. System (NJPDES) Water

Wastewater Discharge Wastewater discharge N.J.A.C. 7:9-5.1 Minimum treatment requirements and effluent Potential ARAR if waters generated Requirements requirements standards for discharge to surface water. by treatment technology are discharged to surface water.

Worker and Community Protects workers and community P.L. 1983c.315 Notification of presence of hazardous substances to ARAR. Applies to all on-site treatment Right to Know Act P.L. 1985c.543 State Emergency Planning Commissions and to local alternatives. Executive Order Emergency Planning Committees. #161

Safe Drinking Water Protects public water supply wells N.J.S.A. 58:12A Regulates periodic testing of Public Community ARAR. Periodic water supply Water Systems. monitoring may be part of the remediation alternatives.

Interim Safe Drinking Protects public water supply wells N.J.A.C. 7:10- Requires periodic testing, analysis, and reporting for ARAR. Periodic water supply Water Testing Schedule 14.1 et.seq. Public Community Water Systems. monitoring may be part of the remediation alternatives.

New Jersey Safe Protects public water supply wells N.J.A.C. 7:10 Sets standards for drinking water including MCLs, Potential ARAR if criteria are more Drinking Water Act disinfecting requirements, secondary drinking water stringent than the Federal MCLs. regulations, and monitoring requirements.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 6 of 13 400174 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability New Jersey Pollutant Discharge to Local Publicly N.J.A.C. 7:14a Discharge standards, and POTW acceptance Potential ARAR if treated water is Discharge Elimination Owned Treatment Works and criteria. discharged to the local POTW.. System (NJPDES) (POTW) POTW Regulations

Prohibition of Air Air Permitting Regulations N.J.A.C. 7:27-8 Air permit requirements for Minor Facilities (and Potential ARAR for remedial Pollution and Ambient Air and Major Facilities without an Operating Permit), and alternatives which include Quality Standards N.J.A.C.7:27-22 Major Facilities with an Operating Permit. technologies that result in air emissions.

General Remediation

Comprehensive National Contingency Plan 40 CFR 300, Outlines procedures for remedial actions and for ARAR. Environmental Subpart E planning and implementing off-site removal actions. Response, Compensation, and Liability Act of 1980 and Superfund Amendments and Reauthorization Act of 1986 (SARA)

State of New Jersey Technical Requirements for Site N.J.A.C. 7:26E Established minimum regulatory requirements for ARAR. Statutes and Rules Remediation investigation and remediation of contaminated sites in New Jersey.

Federal Occupational Worker Protection 29 CFR 1904 Requirements for recording and reporting occupation ARAR. Under 40 CFR 300.38, Safety and Health Act injuries and illnesses requirements of OSHA apply to all activities which fall under jurisdiction of the National Contingency Plan.

Emergency Response Notification of Air Releases NJSA 7:26, Control exposure to air pollution by immediate Potential ARAR for any remedial Notice of Release of 26:2C-19 notification to the department hotline of any air alternative having the potential to Hazardous Substance to release incident. result in an air release. Atmosphere

Water Pollution Control Notification of Spills NJAC 7:21(E) Immediate notification of any spill of hazardous Potential ARAR for remedial substances. alternatives having potential for a spill of a hazardous substance.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 7 of 13 400175 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Noise Control Act Restrictions of Noise NJSA 13:1G-1 Prohibits and restricts noise which unnecessarily Potential ARAR for all remedial et.seq. degrades the quality of life. action.

Disposition of Material Investigation derived waste NJDEP's Provides guidance on the disposition of IDW. Potential ARAR. To be considered Generated During Site management Guidance during investigation. Investigations (NJDEP) Document

Noise Pollution Restrictions of Noise NJAC 7:29-1 Sets maximum limits of sound from any industrial, Potential ARAR for all remedial commercial, public service or community service actions. facility.

Federal Occupational Worker Protection 29 CFR 1904 Worker Protection ARAR. Under 40 CFR 300.38, Safety and Health Act requirements of OSHA apply to all activities which fall under jurisdiction of the National Contingency Plan.

General Requirements Well Permitting NJAC 7:9-7 Regulates permit procedures, general requirements Potential ARAR when installing new for Permitting Wells for drilling and installation of wells, licensing of well wells or if existing wells should driller and pump installer, construction specification, require modification. and well casing.

Sealing of Abandoned Well Abandonment Procedures NJAC 7:9-9 General requirements for sealing of all wells (e.g., Potential ARAR if any existing wells Wells single cased, multiple cased, hand dug, test wells, need to be abandoned and sealed. boreholes and monitoring wells, abandoned wells).

Well Drillers and Pump Drilling Contractor Requirements NJSA 58:4A-5 Well drillers licensing, supervision, inspection and Potential ARAR when additional wells Installers Act et.seq. sampling. are installed.

Requirement for Groundwater Monitoring N.J.A.C. 7:26-9 Groundwater monitoring system requirements. Potential ARAR for any remedial Groundwater Monitoring alternative requiring groundwater monitoring.

Off-Gas Management

Federal Clean Air Act National Primary and Secondary 40 CFR 50 Establishes emission limits for six pollutants (SO2, Emission of air polluntants may be of Ambient Air Quality Standards PM10, CO, O3, NO2, and Pb). concern for some remedial technologies.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 8 of 13 400176 Appendix A Potential Action-Specific Applicable or Relevant and Appropiate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Permitting Requirements Permtting Conditions for air N.J.A.C. 7:27-8 Establishes permit conditions for air pollution control ARAR if remedial action includes a pollution control and apparatus, and processes that generate air technology that would result in air N.J.A.C.7:27-22 emisssions. emissions.

Air Pollution Control Permtting Conditions for air N.J.A.C. 7:27- Controls and prohibits air pollution, particle Potential ARAR if remedial action pollution control 11 and 17 emissions, and toxic VOC emissions. includes a technology that would result in air emissions.

Operating Standards for Incineration Requirements N.J.A.C. 7:26- Specifies maximum air contaminant emissions rates, Potential ARAR if remedial alternative Hazardous Waste 10 testing requirements, and minimum design includes incineration. Incinerators standards.

Interim Standards for Incineration Requirements N.J.A.C. 7:26- Specifies maximum air containment emission rates, Potential ARAR if remedial alternative Hazardous Waste 11 testing requirement, and minimum design standards includes incineration. Incinerators. during interim status.

Incinerator Permit Incinerator Permitting N.J.A.C. 7:26- Delineates the information needs to be submitted in Potential ARAR if remedial alternative Regulations 12 Part A and B of the permit application. includes incineration.

Federal Clean Air Act Standards of Performance for 40 CFR 60 Provides emissions requirements for new stationary ARAR. New Stationary Sources sources.

Federal Clean Air Act National Emission Standards for 40 CFR 61 Provides emission standards for 8 contaminants ARAR. Hazardous Air Pollutants including benzene and vinyl chloride. Identifies 25 additional contaminants, as having serious health effects but does not provide emission standards for these contaminants.

State of New Jersey Standards for Hazardous Air N.J.A.C. 7:27 Rule that governs the emitting of, and such activities ARAR. Statutes and Rules Pollutants Air Pollution that result in, the introduction of contaminants into Control the ambient atmosphere.

Establishment of New Water Supply

State of New Jersey Water Supply Allocation Rules N.J.A.C. 7:19 Regulates new water supply connections and Potential ARAR for Alternate Public Division of Water Supply extensions, responsible for managing New Jersey’s Water Supply/Municipal Well water supply Connection

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 9 of 13 400177 Appendix A Potential Location-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Executive Order Floodplain Management Exec. Order No. Requires federal agencies to evaluate the potential Potential ARAR if remedial activities Floodplain Management 11988 40 CFR effects of actions they may take in a floodplain to take place in or near a 100-year or 2 6:302(b) and avoid, to the maximum extent possible, the adverse 500-year floodplain. Appendix A impacts associated with direct and indirect development of a floodplain.

Federal Flood Plains Regulatory Requirements (RCRA Location This regulation outlines the requirements for Potential ARAR if remedial Regulatory Standards (40 constructing a RCRA facility on a 100-year flood alternatives include construction in or Requirements CFR 264.18) plain. near a 100-year floodplain.

New Jersey Department Permitting Requirements N.J.A.C. 7:7A Regulates the soil disturbance activities within Potential ARAR if investigation of Environmental and N.J.A.C. wetlands, wetland transition zones and flood hazard activities will be completed within Protection Division of 7:13 zones wetlands, wetland transition areas or Land Use Program flood hazard zones.

National Wildlife System Protects national wildlife 16 U.S.C. 668 Restricts activities within a National Wildlife Refuge. Potential ARAR if site is on or 50 CFR 27 adjacent to a wildlife refuge.

Wild and Scenic Rivers Prohibits adverse effects on 16 U.S.C. 1274 Prohibits adverse effects on scenic rivers. Potential ARAR for remedial Act scenic rivers. 40 CFR 6:302 alternatives which may impact rivers.

Clean Water Act Prohibits discharge of dredged or 33 U.S.C. 1251 Prohibits discharge of dredged or fill material into Potential ARAR for remedial fill material into wetlands Section 404, 40 wetlands without a permit. Preserves and enhances alternatives which involve disturbance CFR 230, 231 wetlands. to wetlands.

Endangered Species Act Protects endangered species 16 U.S.C. 1531 Restricts activities where endangered species may Potential ARAR if endangered be present. species are observed at the site during ecological site assessments.

Policy Floodplain assessment EPA 1985 Provides federal policy for the assessment of Potential ARAR for remedial Floodplains/Wetlands Statement floodplains and wetlands alternatives that affect wetlands and Assessment floodplains.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 10 of 13 400178 Appendix A Potential Location-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability Farmland Protection Protects farmland from 7 U.S.C. 4201 Instructs the Department of Agriculture, in Potential ARAR for remedial Policy Act (FPPA) of nonagricultural uses et seq cooperation with other agencies and other units of alternatives that affect farmlands 1980 and 1995 the Federal government, to develop criteria for within the site. identifying the effects of Federal programs on the conversion of farmland to nonagricultural uses. It does not provide a basis for any action.

National Historic Protects historic places 16 U.S.C. 470 Requires federal agencies to take into account the ARAR since source areas are Preservation Act effect of any federally-assisted undertaking or included or eligible for inclusion in the licensing on any district, site, building, structure, or National Register of Historic Places. object that is included in or is eligible for inclusion in the National Register of Historic Places.

U.S. Army Corps of Army Corp. of Engineers Permit 33 CFR 330 Prohibits activity that adversely affects a wetland if a Potential ARAR for remedial Engineers Nationwide Program practical alternative that has less effect is available. alternatives which have the potential Permit Program to affect wetlands.

Historic Sites, Buildings Protects national landmarks 16 U.S.C. ss Requires federal agencies to consider the existence Potential ARAR if source areas are and Antiquities Act 461-457 and location of landmarks on the National Registry of included on the National Registry of Natural Landmarks to avoid undesirable impacts on Natural Landmarks. such landmarks.

Rivers and Harbors Act Army Corp. of Engineers Permit 33 CFR 320- Establishes a COE permit program for dams, dikes, Potential ARAR if remedial actions of 1899 Program 330 dredging, and other construction in navigable waters occur on Federal Property. of the U.S.

Executive Order Protection of Wetlands Executive Order Requires Federal agencies to minimize the Potential ARAR for remedial Protecting Wetlands No. 11990 destruction, loss, or degradation of all wetlands alternatives which have the potential affected by Federal activities. to affect wetlands.

Fish and Wildlife Requires approval for 16 U.S.C. 661 Requires consultation with the U.S. Fish and Wildlife Potential ARAR since any Coordination Act modification of water body 40 CFR 2 Services when a Federal department or agency disturbance and restoration or 6:302(g) proposes or authorizes any modification of any replacement of wetlands must be stream or other water body, and adequate provision coordinated with the Fish and Wildlife for protection of fish and wildlife resources. Service.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 11 of 13 400179 Appendix A Potential Location-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability National Ambient Air Air Quality Standards 40 CFR 50 Establishes non-attainment zones with respect to Potential ARAR for remedial activities Quality Standards health-based criteria. which emit restricted contaminants (NAAQS) into the atmosphere.

Federal Endangered and Protection of threatened and N.J.S.A. 23:2A- Standards for the protection of threatened and Not an ARAR because no listed Non-Game Species Act endangered species 1 endangered species. species identified at the site.

Flood Hazard Area Protection of floodplains N.J.A.C. 7:13 Protects floodplains through permitting requirements Potential ARAR if remedial activities Regulations for construction and development activities are located in or near a 100- or 500- year floodplain.

Flood Hazard Area Delineates flood hazard areas N.J.S.A. 58: Delineates flood hazard areas and regulates use. Potential ARAR if remedial activities Control Act 16A-50 are in or near a 100- or 500-year floodplain.

Wetland Act of 1970 Establishes wetland regulated N.J.S.A. 13:9A- Establishes listing and permitting requirements for Potential ARAR. Establishes listing activities 1 et. seq. regulated activities and permitting requirements for regulated activities

Freshwater Wetlands Establishes freshwater wetlands N.J.S.A. 13:9B Establishes listings and permitting requirements for Potential ARAR. Establishes listings Protection Act regulated activities regulated activities in state freshwater wetlands and permitting requirements for regulated activities in state freshwater wetlands

Open Lands Considers recreational projects N.J.A.C. 7:2- Considers impact of remedial actions on recreational Potential ARAR for remedial actions Management during remediation 12.1 et. seq. projects funded by Open Lands Management Grants. on recreational projects funded by Open Lands Management Grants.

Natural Areas System Protects natural area sites N.J.A.C. 7:2-11 Protects natural area sites listed under the Natural Potential ARAR if remedial actions Areas Register. occur on natural area sites listed under the Natural Areas Register.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 12 of 13 400180 Appendix A Potential Location-Specific Applicable or Relevant and Appropriate Requirements PVGCS Feasibility Study

Act/Authority Criteria/Issues Citation Brief Description Applicability State Trails System Protects state trails N.J.S.A. 13:8- Requires that use of trail does not interfere with Potential ARAR. Requires that use of 30 et. seq. nature; maintains natural and scenic qualities. trail does not interfere with nature; maintains natural and scenic qualities.

New Jersey Wild and Protects Scenic River systems N.J.S.A. 13:8- Governs component river area, flood hazard area, or Potential ARAR. Governs component Scenic Rivers System 45 et. seq. part of state park, wildlife refuge or similar area. river area, flood hazard area, or part of state park, wildlife refuge or similar area.

New Jersey Threatened Lists threatened plant species. New Jersey's Lists threatened plant species. Potential ARAR if remedial actions Plant Species Threatened impact threatened plant species. Plan Species

Endangered Lists threatened habitats where New Jersey's Lists threatened habitats where endangered species Potential ARAR. Lists threatened Plant/Animal Species endangered species occur. Endangered occur. habitats where endangered species Habitats Species Act occur.

ARARs are combined from the USEPA Statement of Work (May 1999) and ARARs supplied by USEPA for a site in Manville, New Jersey (June 2003). Page 13 of 13 400181

Appendix B Natural Attenuation Calculations

400182 NAS - Natural Attenuation Model Data

Introduction This appendix presents the results of the evaluation of the time of remediation (TOR) for the groundwater remedial alternatives for the PVGCS OU2 Study Area TCE plume. This evaluation is for the OU2 portion of the plume only and does not take into consideration migration of contaminants from the OU1 Study Area. The primary tool used for estimating time for remediation is the Natural Attenuation Software (NAS) developed by the Naval Facilities Engineering Command - Southern Division, Virginia Tech, and USGS. Software can be downloaded from the URL http://www.cee.vt.edu/nas/. The Natural Attenuation Software User’s Guide provides information on how to set up and use the software (Brauner et al., 2001) and the article Methodology for Estimating Times of Remediation Associated with Monitored Natural Attenuation (Chapelle, et al., 2003) provides the background documentation of the approach and equations used in the natural attenuation calculations.

Modeling The NAS is used to estimate the TOR under the basic assumption that the current groundwater contaminant plume is at steady state conditions. This is believed to be the case for the OU2 TCE plume as discussed in the PVGCS Feasibility Study (FS). It is based on many simplifying assumptions and is intended as a tool to assist in making TOR estimates. NAS uses an analytical solution that incorporates the groundwater velocity, contaminant retardation, dispersion and an estimated decay rate to calculate the TOR. The decay rate is based on the steady state assumption and user input concentration data along the centerline of the plume. The decay rate calculated by the model represents the decline in user input groundwater concentrations over distance from the source area and assuming model- specified dispersion coefficients. Although the actual biological degradation rate is believed to be minimal because of the oxic conditions present in the plume (TCE degrades very slowly under oxic conditions), the decay rate used by the model does not introduce significant error because it is counterbalanced by a lower-model assumed dispersivity. In essence, the model assigned decay rate represents the actual observed decay but assigns more of the decline in concentrations to biological decay than to dispersivity. Other limitations to the NAS model are that it assumes simple groundwater flow conditions; it is highly sensitive to estimates of the retardation coefficient of the chlorinated VOCs, it only approximates complex processes that occur in the field; and it assumes steady state conditions. The TOR estimates should be viewed as general order-of-magnitude estimates that are useful for comparing alternatives, but should not be viewed as definitive estimates of the actual time to achieve drinking water maximum contaminant limits (MCLs). Often a tailing

B-1 400183 NAS - NATURAL ATTENUATION MODEL DATA effect happens because of slow diffusion out of low permeability zones. As a result, actual times to achieve MCLs may be longer than those estimated in this appendix.

Model Input Assumptions The initial input parameters are presented in Table B-1. Natural attenuation data was also input into the model although the model only uses the data to interpret redox conditions of various portions of the plume. The data is not used in estimating decay rates.

TABLE B-1 NAS Input Parameters PVGCS Feasibility Study Input Value Source

Hydraulic Conductivity (K) 33 ft/day Permeability used in the groundwater flow model.

Hydraulic Gradient 0.0067 ft/ft Overall gradient in plume.

Porosity 0.15 Value used in groundwater flow model.

Fraction Organic Carbon 0.00025 Estimated based on travel distance of plume over 50 years elapsed since potential TCE source release.

Retardation Factor (Rf) 1.47 Calculated using Koc x fraction of organic carbon (foc): TCE TCE Koc = 126 L/kg.

Longitudinal Dispersivity 72.5 Assigned by model based on plume length.

Source Width 650 ft Estimated based on Groundwater RI data (from monitoring well with 31 µg/L of TCE to OU1/OU2 boundary.

An important model assumption is that further mass flux from soil to groundwater is not occurring following site remediation. This is because without control of additional leaching of chlorinated VOCs from soil to groundwater, the mass flux may continue unabated for decades. If this occurs, groundwater concentrations would not begin declining until the source is removed or the mass flux controlled. Modeling Procedure The alternatives with MNA and the main component (Groundwater Alternatives 2A and 2B) were modeled. It was assumed that the highest concentration at the upgradient portion of the OU2 plume was 31 μg/L. The TOR is based on meeting the New Jersey Groundwater Water Quality Standard of 1 μg/L for TCE. NAS calculates the TOR for a selected point along the plume centerline assuming the mass flux from the source area has either been eliminated or reduced to a concentration such that the target concentration (in our case, 1 μg/L) is met at the specified location. Various distances along the plume centerline are input until the highest TOR value is found. The average concentrations of TCE results detected in homeowner wells along the length of the plume were used as the concentrations at specific locations downgradient of the plume. This location then is the point at which the TOR is chosen as representative of the alternative.

B-2 400184 NAS - NATURAL ATTENUATION MODEL DATA

Groundwater Alternatives 2A and 2B As shown in Table B-2, the TOR for the TCE in the OU2 Study Area for Groundwater Alternatives 2A and 2B is approximately 67 years. The results of this model run are similar to the TOR for the OU1 Study Area TCE plume (59 years).

Groundwater Alternatives 3A and 3B Due to the site conditions and the likelihood of impacted groundwater from the OU1 Study Area to impact groundwater within in the OU2 Study Area, a model run for Groundwater Alternatives 3A and 3B was not completed. Due to the potential for contaminants to migrate back into the OU2 Study Area after the in situ oxidation, concentrations are not expected to be significantly reduced at the OU1/OU2 boundary after treatment. Therefore, the time for MNA is not expected to be significantly different than that of just the MNA remedy alone. While there will be an area within the plume that will have been treated utilizing in situ oxidation, the remainder of the plume will attenuate as modeled in Groundwater Alternatives 2A and 2B. As attenuation of the OU1 plume continues over time, the concentrations within the OU1/OU2 boundary (which for the purposes of the model is defined as the “source area”) will decrease. However, one limitation of the model, as stated above, is that it assumes steady-state conditions and that no continued impacts will occur. Because of this, it was assumed as a conservative assumption that the TOR for Groundwater Alternatives 3A and 3B will be 67 years, the same as the alternatives with MNA only.

Overall Model Limitations While the calculations for the two remedial alternatives completed is assumed in the FS as 67 years, one limitation of the model is that it does not take into consideration the potential for continuing mass flux into the plume. Because impacts from the OU1 Study Area will continue to migrate into the OU2 Study Area over time, it is expected that the actual time of remediation for the combined OU1/OU2 TCE plume will be longer than 60-70 years.

References Brauner, Steven, M. Widdowson, F. Chapelle, E. Mendez, and C.C. Casey. Natural Attenuation Software (NAS) User’s Guide. 2001. Chapelle, F.H., M.A. Woodson, J.S. Brauner, E. Mendez, and C.C. Casey. Methodology for Estimating Times of Remediation Associated with Monitored Natural Attenuation. U.S. Geological Survey Water Resources Investigations Report 03- 4057. 2003.

B-3 400185 TABLE B-2 Summary of NAS Model Calculations Facility Name: Pohatcong Superfund Site Length: feet Site Name: TCE Plume Time: years Additional Description: OU2 TCE Plume - MNA Only Mass: pounds

Hydrogeologic Data and Contaminant Transport Calculations Maximum Average Minimum NAPL Source Hydr. Conductivity [ft/yr] 12400.0 12400.0 12400.0 NAPL Source Length [ft] 650.0 Hydraulic Gradient [ft/ft] 0.0067 0.0067 0.0067 NAPL Source Width [ft] 2500.0 Total Porosity [-] 0.15 Contaminated Aquifer Thickness [ft] 20.0 Effective Porosity [-] 0.15 Groundwater Vel. [ft/yr] 553.867 553.867 553.867

Contaminant Source Specifications Conc NAPL Source Component Profile Constituent Total Chl. Eth. True True TCE True True cis-DCE True True Vinyl Chl. True False Ethene False False Chloride False False

Dispersion Parameters Estimated Plume Length [ft] 19920.4 Longitudinal Dispersivity [ft] 67.62 Dispersivity Ratio [-] 20.0 Transverse Dispersivity [ft] 3.38

Sorption Parameters Fraction Org. Carbon [-] Maximum 0.0003 Average 0.0003 Minimum 0.0003

Total Chl. Eth. TCE cis-DCE Vinyl Chl. Koc [L/kg] 126 126 24 57 Retardation Factor [-] Maximum 1.47 1.47 1.09 1.21 Average 1.47 1.47 1.09 1.21 Minimum 1.47 1.47 1.09 1.21

400186 TABLE B-2 Summary of NAS Model Calculations Facility Name: Pohatcong Superfund Site Length: feet Site Name: TCE Plume Time: years Additional Description: OU2 TCE Plume - MNA Only Mass: pounds

Contaminant Concentration Profiles (6/16/2008) Distance Total Chl. Eth. TCE cis-DCE Vinyl Chl. [ft] [µg/L] [µg/L] [µg/L] [µg/L] Source 0 31. 31. BD BD OU1/OU2 650 20. 20. BD BD Wash Average 9500 3.6 3.6 BD BD Wash 1 Average 21000 1. 1. BD BD

Redox Indicator Concentration Profiles (2/1/2002) Distance Oxygen Nitrate Iron(II) Sulfate Sulfide Methane Redox [ft] [mg/L] [mg/L] [mg/L] [mg/L] [mg/L] [mg/L] Condition VTC15 0 6.67 1.7 BD BD BD 0.24 Oxic FCC12 5520 11. 5.15 BD 15.5 BD BD Oxic BMC01 10500 3.1 3.1 BD 43.2 BD 0.14 Oxic WCV05 14800 11.4 4.9 BD 20.1 BD BD Oxic WCC15 19500 2.1 3.64 BD 26.3 BD BD Oxic

Attenuation Rates Total Chl. Eth. TCE cis-DCE Vinyl Chl. NAC (Single Zone) [1/ft] 0.0002 0.0002 N/A N/A Decay Rate [1/yr] Maximum 0.0889 0.0889 N/A N/A Average 0.0889 0.0889 N/A N/A Minimum 0.0889 0.0889 N/A N/A

Time of Stabilization (TOS) and Max Source Conc. Calculations Distance to POC [ft] 21000.0 Time of Source Stabilization Reduction [years] Time to RCC Conc [µg/L] Breakthrough Equilibrium Contaminant [µg/L] Well Current Target Maximum Time Average Minimum Maximum Average Minimum Total Chl. Eth. 1.0 1 31 28 54.7 54.7 54.7 66.9 66.9 66.9 TCE 1 31 cis-DCE Insufficient Data Vinyl Chl. Insufficient Data

400187 TABLE B-2 Summary of NAS Model Calculations Facility Name: Pohatcong Superfund Site Length: feet Site Name: TCE Plume Time: years Additional Description: OU2 TCE Plume - MNA Only Mass: pounds

Time of Remediation (TOR) Calculations Mass Solubility Molecular NAPL Component Fraction[-] [mg/L] Wght [g/mole] Total Chl. Eth. 0.00 0.0 0.0 TCE 0.50 1100.0 131.5 cis-DCE 0.00 800.0 97.0 Vinyl Chl. 0.00 2670.0 62.5

Max Time of Analysis [yr] 1 Removal Plan SCC Mass No Removal [µg/L] [lb] MNA Total Chl. Eth. 1 TCE 1 cis-DCE 1 Vinyl Chl. 1

400188

Appendix C Rough Order of Magnitude Costs Groundwater Alternative 4

400189 Alternative: Groundwater Alternative 4 COST ESTIMATE SUMMARY Name: Entire Plume Extraction, Treatment, and Reinjection

Site: PVGCS OU2 Study Area Description: Entire TCE plume collection through Location: Groundwater Media series of 5 extraction wells per treatment system Phase: Feasibility Study Total flow of 9000 gpm. Base Year: 2008 Assumes six treatment systems operating for 30 years (cost purposes). Date: 12/16/2009 0:00 CAPITAL COSTS DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES Groundwater Use Restrictions 1 LS $15,000 $15,000 Pre-Design Investigations Install New Monitoring Wells Mobilization/Demobilization 1 LS $25,000 $25,000 Soil Borings 1,750 FT $47 $82,250 Miller Drilling Quote. 2" Well Casing 1,750 FT $15 $26,250 33-23-0101 2" Well Screen 1,750 FT $25 $43,750 33-23-0256 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $190,050 Contingency 30% $57,015 10% Scope + 20% Bid SUBTOTAL $247,065 Sample Existing and New Wells Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Samping Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $2,000 $2,000 CH2M HILL Estimate Consumables 1 LS $400 $400 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $11,285 Allowance for Misc. Items 20% $2,257 SUBTOTAL $13,542 Contingency 30% $4,063 10% Scope + 20% Bid SUBTOTAL $17,605 Site Preparation Site Preparation 1 LS $10,000 $10,000 Silt Fencing and Erosion Controls (Temp.) 1 LS $500 $500 Surveying 1 LS $1,000 $1,000 SUBTOTAL $11,500 General Work for Replacement of Existing Private Wells Door-to-Door Survey 400 HR $80 $32,000 Home Well Abandonment 25,000 LF $10 $250,000 Contractor Estimate SUBTOTAL $282,000 Water Supply Connection New Water Main Pipeline 52,800 LF $150 $7,920,000 10 miles Connection to Municipal Supply System(100') 320 EA $3,000 $960,000 Connection home to water main Water Meter Installation 320 EA $200 $64,000 Unit cost from Aqua SUBTOTAL $8,944,000 ANC Production Well Treatment Shallow Tray Air Stripper 0 EA $105,000 $0 Contractor Estimate Miscellenous Piping and Fittings 0 LS $2,000 $0 SUBTOTAL $0 Groundwater Extraction/Injection Systems Mobilization 6 EA $50,000 $300,000 scaleup from 1 to 6 systems 12-inch Borehole 10,200 LF $70 $714,000 scaleup from 5 to 30 wells 8-inch Well Casing 10,200 LF $35 $357,000 scaleup from 5 to 30 wells Well Grout Seal 10,200 LF $20 $204,000 scaleup from 5 to 30 wells 8-inch Borehole 16,320 LF $25 $408,000 scaleup from 8 to 48 wells Well Development 2,496 HR $250 $624,000 scaleup from 1 to 6 systems 35-Horsepower Pump and Motor 30 EA $25,000 $750,000 scaleup from 5 to 30 wells Wellhead Piping, Vault, etc. 78 LS $10,000 $780,000 scaleup from 1 to 6 systems Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $4,149,800 Groundwater Treatment Systems Excavation for Building Foundation 1 LS $60,000 $60,000 Concrete Building Foundation 1 LS $90,000 $90,000 Concrete Footer 1 LS $90,000 $90,000 GW Treatment Building 1 LS $1,200,000 $1,200,000 Miscellaneous (Construction) 6 EA $5,000 $30,000 CH2M HILL Estimate + scaleup Paved Access Road 125 TONS $130 $16,250 Underground Utilities 1 LS $50,000 $50,000 Utility Tie-ins 1 LS $20,000 $20,000 Yard Piping 1 LS $40,000 $40,000 10,000 gal EqualizationTank 6 EA $8,726 $52,356 33-10-9662 Bag Filteration (2 filters/system) 12 EA $4,334 $52,008 33-13-0117 Air Stripper 0 EA $135,000 $0 Contractor Estimate + scaleup Activated Carbon 12 EA $2,000 $24,000 33-13-1942 4" Venturi Flow Meter 12 EA $4,000 $48,000 CH2M HILL Estimate + scaleup 4" Steel Pipe (Exposed) 12,000 LF $13 $150,960 33-26-0104 4" Steel Fittings (Exposed) 60 EA $119 $7,140 33-27-0534/0552/0562 4" Check Valve 30 EA $292 $8,760 33-27-0404 4" Butterfly Valve 30 EA $544 $16,310 33-27-0424 Pressure Gauge Assembly 12 EA $276 $3,312 Contractor Estimate + scaleup Effluent Tank (Gravity Feed) 6 EA $8,726 $52,356 33-10-9662 Gravity Discharge Piping (8" HDPE) 600 LF $8 $4,638 33-26-0514 Air Stripper Drain Line (4" HDPE) 0 LF $4 $0 33-26-0512 Misc. (pipe stands, brackets, etc.) 1 LS $100,000 $100,000 CH2M HILL Estimate + scaleup Misc Plant Piping 1 LS $35,000 $35,000 Allowance Instumentation 1 LS $200,000 $200,000 Allowance Electrical 1 LS $70,000 $70,000 Allowance SCADA/computer control system 1 LS $350,000 $350,000 OMI Estimate SUBTOTAL $2,771,090 Electrical Service (GW Treatment Systems and Wells) Electrical Service 1 LS $60,000 $60,000 CH2M HILL Estimate SUBTOTAL $60,000 SUBTOTAL $16,218,390 Contingency 25% $4,054,598 10% Scope + 15% Bid SUBTOTAL $20,272,988 SUBTOTAL - CAPITAL COSTS $20,552,657 Project Management 5% $1,027,633 USEPA 2000, p. 5-13, >$10MM Engineering Design and Planning 6% $1,233,159 USEPA 2000, p. 5-13, >$10MM Construction Management 6% $1,233,159 USEPA 2000, p. 5-13, >$10MM Permitting (Air and Re-Injection) 1 LS $7,500 $7,500 CH2M HILL Estimate Operations and Maintenance Manual 1 LS $7,500 $7,500 CH2M HILL Estimate Procurement 1 LS $2,500 $2,500 CH2M HILL Estimate Construction Completion and QA/QC Report 1 LS $8,000 $8,000 CH2M HILL Estimate TOTAL CAPITAL COST $24,072,000

Sheet 1 of 2 400190 Alternative: Groundwater Alternative 4 COST ESTIMATE SUMMARY Name: Entire Plume Extraction, Treatment, and Reinjection

OPERATIONS AND MAINTENANCE COST DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES Groundwater Monitoring (20 Outlying Homes) Groundwater Samples 20 LS $110 $2,200 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 12 HRS $80 $960 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,420 Allowance for Misc. Items 20% $1,884 SUBTOTAL $11,304 POETS System Maintenance O&M Staff (labor, overheads, vehicles, etc) 1 LS $7,000 $7,000 Carbon Usage 80 EA $732 $58,560 1 change-out/yr (including existing) SUBTOTAL $65,560 Treatment Building Property Leasing Property Leasing for Treatment Building 40,000 SF $7 $280,000 OMI Estimate Inspection and Monitoring Monthly Site Visits Labor for Visit/Compliance Sampling 96 HR $80 $7,680 CH2M HILL Estimate - 1 person/mth Effluent Sampling (GW) 12 LS $110 $1,320 Contractor Estimate VOC Analysis (Method TO-14) - Offgas 4 LS $150 $600 Contractor Estimate Reporting (Quarterly) 4 LS $8,000 $32,000 CH2M HILL Estimate Other Expenses (Shipping, supplies, etc.) 1 LS $1,000 $1,000 CH2M HILL Estimate SUBTOTAL $42,600 Allowance for Misc. Items 20% $8,520 SUBTOTAL $51,120 Contingency 30% $15,336 Treatment System Maintenance and Electrical O&M Staff (labor, overheads, vehicles, etc) 12 EA $10,000 $120,000 OMI Estimate - 12 people Carbon Usage 1 LS $100,000 $100,000 OMI Estimate Line and Pump Acid Cleaning 1 LS $80,000 $80,000 OMI Estimate Pump Rebuilds 1 LS $50,000 $50,000 OMI Estimate Electrical Costs (assumes $0.15 per Kwh for 30 x 35 HP pumps) $1,029,256 JCP&L Estimate 1/11/10

Vannatta Street, and Dale Avenue Sampling Monthly Site Visits Labor for Visit/Compliance Sampling 48 HR $80 $3,840 CH2M HILL Estimate - 1 person/mth Effluent Sampling (GW) 24 LS $110 $2,640 Contractor Estimate

SUBTOTAL (SYSTEM O&M) $1,452,192

TOTAL ANNUAL O&M COST $1,809,000

PERIODIC COSTS DESCRIPTION YEAR QTY UNIT UNIT COST TOTAL NOTES Groundwater Sampling Every 2 years 2 Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Groundwater Sampling, Level D Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 13 HRS $80 $1,000 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,570 Allowance for Misc. Items 20% $1,914 SUBTOTAL $11,484 Contingency 30% $3,445 10% Scope + 20% Bid SUBTOTAL $15,000

PRESENT VALUE ANALYSIS Discount Rate = 7.0% TOTAL TOTAL COST DISCOUNT PRESENT COST TYPE YEAR COST PER YEAR FACTOR VALUE NOTES

CAPITAL COST 0 $24,072,000 $24,072,000 1.000 $24,072,000 O&M COST PROPERTY LEASING 1 to 30 $8,400,000 $280,000 12.409 $3,474,532 GW MONITOR (20 OUTLYING HOMES) COST 1 to 30 $339,120 $11,304 12.409 $140,272 POETS O&M COST 1 to 30 $1,966,800 $65,560 12.409 $813,537 SYSTEM Monitoring O&M COSTS 1 to 30 $43,565,766 $1,452,192 12.409 $18,020,313 PERIODIC COST 2 $15,000 $15,000 0.87 $13,102 PERIODIC COST 4 $15,000 $15,000 0.76 $11,443 PERIODIC COST 6 $15,000 $15,000 0.67 $9,995 PERIODIC COST 8 $15,000 $15,000 0.58 $8,730 PERIODIC COST 10 $15,000 $15,000 0.51 $7,625 PERIODIC COST 12 $15,000 $15,000 0.44 $6,660 PERIODIC COST 14 $15,000 $15,000 0.39 $5,817 PERIODIC COST 16 $15,000 $15,000 0.34 $5,081 PERIODIC COST 18 $15,000 $15,000 0.30 $4,438 PERIODIC COST 20 $15,000 $15,000 0.26 $3,876 PERIODIC COST 22 $15,000 $15,000 0.23 $3,386 PERIODIC COST 24 $15,000 $15,000 0.20 $2,957 PERIODIC COST 26 $15,000 $15,000 0.17 $2,583 PERIODIC COST 28 $15,000 $15,000 0.15 $2,256 PERIODIC COST 30 $15,000 $15,000 0.13 $1,971 $78,568,686 $46,610,573

TOTAL PRESENT VALUE OF ALTERNATIVE $46,610,000

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

400191 Sheet 2 of 2

Appendix D Detailed Cost Tables of Remedial Alternatives

400192 COMPARISON OF TOTAL COST OF REMEDIAL ALTERNATIVES

Site: PVGCS OU2 Study Area Base Year: 2009 Location: Groundwater Media Date: Dec-09 Phase: Feasibility Study

Groundwater Groundwater Groundwater Groundwater Groundwater Alternative 1 Alternative 2a Alternative 2b Alternative 3a Alternative 3b Monitored Natural Monitored Natural Insitu Upgradient Insitu Upgradient Attenuation, Attenuation, Treatment, Treatment, Public Institutional Institutional No Action Private Well Water Supply Controls, and Controls, and Head Treatment, Connection, and Private Well Head Public Water and MNA MNA Treatment Supply Connection

Total Project Duration (Years) 67 67 67 67 67

Capital Cost $0 $2,344,000 $13,992,000 $3,644,000 $15,292,000 Annual O&M Cost $0 $339,000 $77,000 $615,000 $352,000 Total Periodic Cost $0 $15,000 $15,000 $15,000 $15,000

Total Present Value of Alternative $0 $6,640,000 $15,040,000 $8,200,000 $16,590,000

Notes: While time of remediation for most alternatives are above 30 years, present worth costs were prepared for 30 years. * Groundwater Alternative 4 was not retained for detailed evaluation and the costs were rough order of magnitude only. They were included here for comparison purposes only.

The information in this cost estimate is based on the best available information regarding the anticipated scope of the remedial alternatives. Disclaimer: Changes in the cost estimates are likely to occur as a result of new information and data collected during the engineering design of the remedial alternatives. This is an order-of-magnitude cost estimate that is expected to be within -30 to +50 percent of the actual project costs.

Sheet 1 of 13 400193 Alternative: Groundwater Alternative 1 COST ESTIMATE SUMMARY Name: No Action

Site: PVGCS OU1 Study Area Description: No action taken. Location: Groundwater Media Phase: Feasibility Study Base Year: 2009 Date: 12/1/2009

CAPITAL COSTS DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES None TOTAL CAPITAL COST $0

OPERATIONS AND MAINTENANCE COST DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES None 0 LS $5,000 $0 TOTAL ANNUAL O&M COST $0

PERIODIC COSTS DESCRIPTION YEAR QTY UNIT UNIT COST TOTAL NOTES None 0 LS $0 $0 TOTAL PERIODIC COST $0

PRESENT VALUE ANALYSIS Discount Rate = 7.0% http://www.whitehouse.gov/omb/circulars/a094/a94_appx-c.html TOTAL COST DISCOUNT PRESENT COST TYPE YEAR TOTAL COST PER YEAR FACTOR (7%) VALUE NOTES CAPITAL COST 0 $0 $0 1.000 $0 ANNUAL O&M COST 1 to 30 $0 $0 12.41 $0 $0 $0 TOTAL PRESENT VALUE OF ALTERNATIVE $0

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

Sheet 2 of 13 400194 Alternative: Groundwater Alternative 2a COST ESTIMATE SUMMARY Name: Monitored Natural Attenuation, Institutional Controls, and Private Well Head Treatment

Site: PVGCS OU2 Study Area Description: Location: Groundwater Media Installation of Point of entry treatment (POETS) for private wells throughout OU2 Phase: Feasibility Study Base Year: 2009 Date: 12/1/2009

CAPITAL COSTS DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES

Groundwater Use Restrictions 1 LS $15,000 $15,000

Pre-Design Investigations Install New Monitoring Wells Mobilization/Demobilization 1 LS $25,000 $25,000 Soil Borings 1,750 FT $47 $82,250 Miller Drilling Quote. 2" Well Casing 1,750 FT $15 $26,250 33-23-0101 2" Well Screen 1,750 FT $25 $43,750 33-23-0256 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $190,050 Contingency 30% $57,015 10% Scope + 20% Bid SUBTOTAL $247,065 Sample Existing and New Wells Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Samping Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $2,000 $2,000 CH2M HILL Estimate Consumables 1 LS $400 $400 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $11,285 Allowance for Misc. Items 20% $2,257 SUBTOTAL $13,542 Contingency 30% $4,063 10% Scope + 20% Bid SUBTOTAL $17,605 General Work for Existing Private Wells Door-to-Door Survey 420 HR $80 $33,600 SUBTOTAL $33,600 POET Installation Private homes 320 EA $3,464 $1,108,480 Vendor's Quote Installation Cost 320 EA $640 $204,800 SUBTOTAL $1,313,280 Contingency 25% $328,320 10% Scope + 15% Bid SUBTOTAL $1,641,600

SUBTOTAL - CAPITAL COSTS $1,954,870

Project Management 5% $97,743 USEPA 2000, p. 5-13, $2MM-$10MM Engineering Design and Planning 8% $156,390 USEPA 2000, p. 5-13, $2MM-$10MM Construction Management 6% $117,292 USEPA 2000, p. 5-13, $2MM-$10MM Operations and Maintenance Manual 1 LS $7,500 $7,500 CH2M HILL Estimate Procurement 1 LS $2,500 $2,500 CH2M HILL Estimate Construction Completion and QA/QC Report 1 LS $8,000 $8,000 CH2M HILL Estimate

TOTAL CAPITAL COST $2,344,000

OPERATIONS AND MAINTENANCE COST DESCRIPTION QTY UNIT UNIT COST TOTAL NOTES Groundwater Monitoring (20 Outlying Homes) Groundwater Samples 20 LS $110 $2,200 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 12 HRS $80 $960 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,420 Allowance for Misc. Items 20% $1,884 SUBTOTAL $11,304

POETS System Maintenance O&M Staff (labor, overheads, vehicles, etc) 1 LS $35,000 $35,000 Carbon Usage 400 EA $732 $292,800 1 change-out/yr (including existing) SUBTOTAL $327,800

ANNUAL O&M COST $339,000

PERIODIC COSTS DESCRIPTION YEAR QTY UNIT UNIT COST TOTAL NOTES Groundwater Sampling Every 2 years 2 Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Groundwater Sampling, Level D Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,585 Allowance for Misc. Items 20% $1,917 SUBTOTAL $11,502 Contingency 30% $3,451 10% Scope + 20% Bid SUBTOTAL (ANNUAL) $15,000

400195 Sheet 3 of 13 Alternative: Groundwater Alternative 2a COST ESTIMATE SUMMARY Name: Monitored Natural Attenuation, Institutional Controls, and Private Well Head Treatment

PRESENT VALUE ANALYSIS Discount Rate = 7.0% TOTAL TOTAL COST DISCOUNT PRESENT COST TYPE YEAR COST PER YEAR FACTOR (7%) VALUE NOTES

CAPITAL COST 0 $2,344,000 $2,344,000 1.000 $2,344,000 O&M COST GW MONITOR (20 OUTLYING HOMES) COST 1 to 30 $339,120 $11,304 12.409 $140,272 POETS O&M COST 1 to 30 ` $327,800 12.409 $4,067,684 PERIODIC COST 2 $15,000 $15,000 0.87 $13,102 PERIODIC COST 4 $15,000 $15,000 0.76 $11,443 PERIODIC COST 6 $15,000 $15,000 0.67 $9,995 PERIODIC COST 8 $15,000 $15,000 0.58 $8,730 PERIODIC COST 10 $15,000 $15,000 0.51 $7,625 PERIODIC COST 12 $15,000 $15,000 0.44 $6,660 PERIODIC COST 14 $15,000 $15,000 0.39 $5,817 PERIODIC COST 16 $15,000 $15,000 0.34 $5,081 PERIODIC COST 18 $15,000 $15,000 0.30 $4,438 PERIODIC COST 20 $15,000 $15,000 0.26 $3,876 PERIODIC COST 22 $15,000 $15,000 0.23 $3,386 PERIODIC COST 24 $15,000 $15,000 0.20 $2,957 PERIODIC COST 26 $15,000 $15,000 0.17 $2,583 PERIODIC COST 28 $15,000 $15,000 0.15 $2,256 PERIODIC COST 30 $15,000 $15,000 0.13 $1,971 $2,908,120 $6,641,876

TOTAL PRESENT VALUE OF ALTERNATIVE $6,640,000

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

400196 Sheet 4 of 13 Alternative: Groundwater Alternative 2b COST ESTIMATE SUMMARY Name: Monitored Natural Attenuation, Institutional Controls, and Public Water Supply Connection

Site: PVGCS OU2 Study Area Description: Location: Groundwater Media Installation of Point of entry treatment (POETS) for private wells in the outlying areas Phase: Feasibility Study Connection to Public Water Supply for homes in the interior of OU-2 Base Year: 2009 Date: 12/1/2009

CAPITAL COSTS UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES

Groundwater Use Restrictions 1 LS $15,000 $15,000

Pre-Design Investigations Install New Monitoring Wells Mobilization/Demobilization 1 LS $25,000 $25,000 Soil Borings 1,750 FT $47 $82,250 Miller Drilling Quote. 2" Well Casing 1,750 FT $15 $26,250 33-23-0101 2" Well Screen 1,750 FT $25 $43,750 33-23-0256 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $190,050 Contingency 30% $57,015 10% Scope + 20% Bid SUBTOTAL $247,065 Sample Existing and New Wells Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Samping Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $2,000 $2,000 CH2M HILL Estimate Consumables 1 LS $400 $400 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $11,285 Allowance for Misc. Items 20% $2,257 SUBTOTAL $13,542 Contingency 30% $4,063 10% Scope + 20% Bid SUBTOTAL $17,605 General Work for Replacement of Existing Private Wells Door-to-Door Survey 420 HR $80 $33,600 Home Well Abandonment 25,000 LF $10 $250,000 Contractor Estimate SUBTOTAL $283,600 Water Supply Connection New Water Main Pipeline 52,800 LF $150 $7,920,000 10 miles Connection to Municipal Supply System(100') 320 EA $3,000 $960,000 Connection home to water main Water Meter Installation 320 EA $200 $64,000 Unit cost from Aqua SUBTOTAL $8,944,000 Contingency 25% $2,236,000 10% Scope + 15% Bid SUBTOTAL $11,180,000

SUBTOTAL - CAPITAL COSTS $11,743,270

Project Management 5% $587,163 USEPA 2000, p. 5-13, $2MM-$10MM Engineering Design and Planning 8% $939,462 USEPA 2000, p. 5-13, $2MM-$10MM Construction Management 6% $704,596 USEPA 2000, p. 5-13, $2MM-$10MM Operations and Maintenance Manual 1 LS $7,500 $7,500 CH2M HILL Estimate Procurement 1 LS $2,500 $2,500 CH2M HILL Estimate Construction Completion and QA/QC Report 1 LS $8,000 $8,000 CH2M HILL Estimate

TOTAL CAPITAL COST $13,992,000

OPERATIONS AND MAINTENANCE COST UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES Groundwater Monitoring (20 Outlying Homes) Groundwater Samples 20 LS $110 $2,200 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 12 HRS $80 $960 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,420 Allowance for Misc. Items 20% $1,884 SUBTOTAL $11,304

POETS System Maintenance O&M Staff (labor, overheads, vehicles, etc) 1 LS $7,000 $7,000 Carbon Usage 80 EA $732 $58,560 1 change-out/yr (including existing) SUBTOTAL $65,560

ANNUAL O&M COST $77,000

PERIODIC COSTS UNIT DESCRIPTION YEAR QTY UNIT COST TOTAL NOTES Groundwater Sampling Every 2 years 2 Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Groundwater Sampling, Level D Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 13 HRS $80 $1,000 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,570 Allowance for Misc. Items 20% $1,914 SUBTOTAL $11,484 Contingency 30% $3,445 10% Scope + 20% Bid SUBTOTAL (ANNUAL) $15,000

Sheet 5 of 13 400197 Alternative: Groundwater Alternative 2b COST ESTIMATE SUMMARY Name: Monitored Natural Attenuation, Institutional Controls, and Public Water Supply Connection

PRESENT VALUE ANALYSIS Discount Rate = 7.0% TOTAL TOTAL COST DISCOUNT PRESENT COST TYPE YEAR COST PER YEAR FACTOR (7%) VALUE NOTES

CAPITAL COST 0 $13,992,000 $13,992,000 1.000 $13,992,000 O&M COST GW MONITOR (20 OUTLYING HOMES) COST 1 to 30 $339,120 $11,304 12.409 $140,272 POETS O&M COST 1 to 30 $1,966,800 $65,560 12.409 $813,537 PERIODIC COST 2 $15,000 $15,000 0.87 $13,102 PERIODIC COST 4 $15,000 $15,000 0.76 $11,443 PERIODIC COST 6 $15,000 $15,000 0.67 $9,995 PERIODIC COST 8 $15,000 $15,000 0.58 $8,730 PERIODIC COST 10 $15,000 $15,000 0.51 $7,625 PERIODIC COST 12 $15,000 $15,000 0.44 $6,660 PERIODIC COST 14 $15,000 $15,000 0.39 $5,817 PERIODIC COST 16 $15,000 $15,000 0.34 $5,081 PERIODIC COST 18 $15,000 $15,000 0.30 $4,438 PERIODIC COST 20 $15,000 $15,000 0.26 $3,876 PERIODIC COST 22 $15,000 $15,000 0.23 $3,386 PERIODIC COST 24 $15,000 $15,000 0.20 $2,957 PERIODIC COST 26 $15,000 $15,000 0.17 $2,583 PERIODIC COST 28 $15,000 $15,000 0.15 $2,256 PERIODIC COST 30 $15,000 $15,000 0.13 $1,971 $16,522,920 $15,035,729

TOTAL PRESENT VALUE OF ALTERNATIVE $15,040,000

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

400198 Sheet 6 of 13 Alternative: Groundwater Alternative 3a COST ESTIMATE SUMMARY Name: Insitu Upgradient Treatment, Private Well Head Treatment, and MNA

Site: PVGCS OU2 Study Area Description: Location: Groundwater Media Insitu Oxidation of Upgradient Hotspot Phase: Feasibility Study Installation of Point of entry treatment (POETS) for private wells throughout OU2 Base Year: 2009 Date: 12/1/2009

CAPITAL COSTS UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES

Groundwater Use Restrictions 1 LS $15,000 $15,000

Pre-Design Investigations Install New Monitoring Wells Mobilization/Demobilization 1 LS $25,000 $25,000 Soil Borings 1,750 FT $47 $82,250 Miller Drilling Quote. 2" Well Casing 1,750 FT $15 $26,250 33-23-0101 2" Well Screen 1,750 FT $25 $43,750 33-23-0256 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $190,050 10% Scope + 20% Contingency 30% $57,015 Bid SUBTOTAL $247,065 Sample Existing and New Wells Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Samping Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $2,000 $2,000 CH2M HILL Estimate Consumables 1 LS $400 $400 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $11,285 Allowance for Misc. Items 20% $2,257 SUBTOTAL $13,542 10% Scope + 20% Contingency 30% $4,063 Bid SUBTOTAL $17,605 General Work for Existing Private Wells Door-to-Door Survey 420 HR $80 $33,600 SUBTOTAL $33,600 POET Installation Private homes 320 EA $3,464 $1,108,480 Vendor's Quote Installation Cost 320 EA $640 $204,800 SUBTOTAL $1,313,280 Contingency 25% $328,320 10% Scope + 15% Bid SUBTOTAL $1,641,600 Site Preparation Site Preparation 1 LS $10,000 $10,000 Silt Fencing and Erosion Controls (Temp.) 1 LS $500 $500 Surveying 1 LS $1,000 $1,000 SUBTOTAL $11,500 Injection Wells Mobilization 1 LS $25,000 $25,000 12-inch Borehole 900 LF $70 $63,000 8-inch Well Casing 900 LF $35 $31,500 Well Grout Seal 900 LF $20 $18,000 Well Development 224 HR $250 $56,000 Wellhead Piping, Vault, etc. 6 EA $15,000 $90,000 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $296,300 Groundwater Treatment Systems Excavation for Building Foundation 1 LS $20,000 $20,000 Contractor Estimate Concrete Building Foundation 1 LS $30,000 $30,000 Contractor Estimate Concrete Footer 1 LS $30,000 $30,000 Contractor Estimate GW Treatment Building 1 LS $70,000 $70,000 Contractor Estimate Miscellaneous (Construction) 1 LS $5,000 $5,000 CH2M HILL Estimate Paved Access Road 125 TONS $130 $16,250 CH2M HILL Estimate Underground Utilities 1 LS $50,000 $50,000 Utility Tie-ins 1 LS $20,000 $20,000 Yard Piping 1 LS $40,000 $40,000 10,000 gal EqualizationTank 2 EA $8,726 $17,452 33-10-9662 4" Venturi Flow Meter 4 EA $4,000 $16,000 CH2M HILL Estimate 4" Steel Pipe (Exposed) 4,000 LF $13 $50,320 33-26-0104 4" Steel Fittings (Exposed) 20 EA $119 $2,380 33-27-0534/0552/0562 4" Check Valve 10 EA $292 $2,920 33-27-0404 4" Butterfly Valve 10 EA $544 $5,437 33-27-0424 Misc Plant Piping 1 LS $35,000 $35,000 Allowance Instumentation 1 LS $20,000 $20,000 Allowance Electrical 1 LS $50,000 $50,000 Allowance Pressure Gauge Assembly 4 EA $276 $1,104 Grainger Estimate Misc. (pipe stands, brackets, etc.) 1 LS $50,000 $50,000 CH2M HILL Estimate SUBTOTAL $531,863 Oxidant Materials Oxidant 1200 LBS 3.2 $3,780 Regenisis - includes materials and shipping Electrical Service (GW Treatment Systems and Wells) Electrical service 1 LS $10,000 $10,000 CH2M HILL Estimate SUBTOTAL $10,000 SUBTOTAL (In Situ System) $853,443 Contingency 25% $213,361 10% Scope + 15% Bid SUBTOTAL (System) $1,066,803

SUBTOTAL - CAPITAL COSTS $3,021,673

Project Management 5% $151,084 USEPA 2000, p. 5-13, $2MM-$10MM Engineering Design and Planning 8% $241,734 USEPA 2000, p. 5-13, $2MM-$10MM Construction Management 6% $181,300 USEPA 2000, p. 5-13, $2MM-$10MM Permitting (Injection) 1 LS $30,000 $30,000 CH2M HILL Estimate Operations and Maintenance Manual 1 LS $7,500 $7,500 CH2M HILL Estimate Procurement 1 LS $2,500 $2,500 CH2M HILL Estimate Construction Completion and QA/QC Report 1 LS $8,000 $8,000 CH2M HILL Estimate

TOTAL CAPITAL COST $3,644,000

Sheet 7 of 13 400199 Alternative: Groundwater Alternative 3a COST ESTIMATE SUMMARY Name: Insitu Upgradient Treatment, Private Well Head Treatment, and MNA

OPERATIONS AND MAINTENANCE COST UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES Groundwater Monitoring (20 Outlying Homes) Groundwater Samples 20 LS $110 $2,200 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 12 HRS $80 $960 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,420 Allowance for Misc. Items 20% $1,884 SUBTOTAL $11,304

POETS System Maintenance O&M Staff (labor, overheads, vehicles, etc) 1 LS $35,000 $35,000 Carbon Usage 400 EA $732 $292,800 1 change-out/yr (including existing) SUBTOTAL $327,800 Treatment Building Property Leasing Property Leasing for TCE Treatment Building 30,000 SF $7 $210,000 Estimate from OMI

Inspection and Monitoring Monthly Site Visits Labor for Visit/Compliance Sampling 96 HR $80 $7,680 CH2M HILL Estimate - 1 person/mth Effluent Sampling (GW) 12 LS $110 $1,320 Contractor Estimate Reporting (Quarterly) 4 LS $8,000 $32,000 CH2M HILL Estimate Other Expenses (Shipping, supplies, etc.) 1 LS $1,000 $1,000 CH2M HILL Estimate SUBTOTAL $42,000 Allowance for Misc. Items 20% $8,400 SUBTOTAL $50,400 Contingency 30% $15,120 SUBTOTAL $65,520

ANNUAL O&M COST $615,000

PERIODIC COSTS UNIT DESCRIPTION YEAR QTY UNIT COST TOTAL NOTES Groundwater Sampling Every 5 years 5 Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Groundwater Sampling, Level D Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 13 HRS $80 $1,000 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,570 Allowance for Misc. Items 20% $1,914 SUBTOTAL $11,484 Contingency 30% $3,445 10% Scope + 20% Bid SUBTOTAL (ANNUAL) $15,000

PRESENT VALUE ANALYSIS Discount Rate = 7.0% TOTAL TOTAL COST DISCOUNT PRESENT COST TYPE YEAR COST PER YEAR FACTOR (7%) VALUE NOTES

CAPITAL COST 0 $3,644,000 $3,644,000 1.000 $3,644,000 O&M COST PROPERTY LEASING 1 $210,000 $210,000 0.935 $196,262 GW MONITOR (20 OUTLYING HOMES) COST 1 to 30 $339,120 $11,304 12.409 $140,272 POETS O&M COST 1 to 30 $9,834,000 $327,800 12.409 $4,067,684 SYSTEM Monitoring O&M COSTS 1 $65,520 $65,520 0.935 $61,234 PERIODIC COST 2 $15,000 $15,000 0.87 $13,102 PERIODIC COST 4 $15,000 $15,000 0.76 $11,443 PERIODIC COST 6 $15,000 $15,000 0.67 $9,995 PERIODIC COST 8 $15,000 $15,000 0.58 $8,730 PERIODIC COST 10 $15,000 $15,000 0.51 $7,625 PERIODIC COST 12 $15,000 $15,000 0.44 $6,660 PERIODIC COST 14 $15,000 $15,000 0.39 $5,817 PERIODIC COST 16 $15,000 $15,000 0.34 $5,081 PERIODIC COST 18 $15,000 $15,000 0.30 $4,438 PERIODIC COST 20 $15,000 $15,000 0.26 $3,876 PERIODIC COST 22 $15,000 $15,000 0.23 $3,386 PERIODIC COST 24 $15,000 $15,000 0.20 $2,957 PERIODIC COST 26 $15,000 $15,000 0.17 $2,583 PERIODIC COST 28 $15,000 $15,000 0.15 $2,256 PERIODIC COST 30 $15,000 $15,000 0.13 $1,971 ######### $8,199,371

TOTAL PRESENT VALUE OF ALTERNATIVE $8,200,000

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

Sheet 8 of 13 400200 Alternative: Groundwater Alternative 3b COST ESTIMATE SUMMARY Name: Insitu Upgradient Treatment, Public Water Supply Connection, and MNA

Site: PVGCS OU2 Study Area Description: Location: Groundwater Media Insitu Oxidation of Upgradient Area Phase: Feasibility Study Installation of Point of entry treatment (POETS) for private wells in the outlying areas Base Year: 2009 Connection to Public Water Supply for homes in the interior of OU-2 Date: 12/1/2009

CAPITAL COSTS UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES

Groundwater Use Restrictions 1 LS $15,000 $15,000

Pre-Design Investigations Install New Monitoring Wells Mobilization/Demobilization 1 LS $25,000 $25,000 Soil Borings 1,750 FT $47 $82,250 Miller Drilling Quote. 2" Well Casing 1,750 FT $15 $26,250 33-23-0101 2" Well Screen 1,750 FT $25 $43,750 33-23-0256 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $190,050 Contingency 30% $57,015 10% Scope + 20% Bid SUBTOTAL $247,065 Sample Existing and New Wells Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $451 Contractor Estimate Samping Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $2,000 $2,000 CH2M HILL Estimate Consumables 1 LS $400 $400 CH2M HILL Estimate Data Validation 13 HRS $80 $1,004 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $11,285 Allowance for Misc. Items 20% $2,257 SUBTOTAL $13,542 Contingency 30% $4,063 10% Scope + 20% Bid SUBTOTAL $17,605 General Work for Replacement of Existing Private Wells Door-to-Door Survey 420 HR $80 $33,600 Home Well Abandonment 25,000 LF $10 $250,000 Contractor Estimate SUBTOTAL $283,600 Water Supply Connection New Water Main Pipeline 52,800 LF $150 $7,920,000 10 miles Connection to Municipal Supply System(100') 320 EA $3,000 $960,000 Water Meter Installation 320 EA $200 $64,000 Unit cost from Aqua SUBTOTAL $8,944,000 Contingency 25% $2,236,000 10% Scope + 15% Bid SUBTOTAL $11,180,000 Site Preparation Site Preparation 1 LS $10,000 $10,000 Silt Fencing and Erosion Controls (Temp.) 1 LS $500 $500 Surveying 1 LS $1,000 $1,000 SUBTOTAL $11,500 Injection Wells Mobilization 1 LS $25,000 $25,000 12-inch Borehole 900 LF $70 $63,000 8-inch Well Casing 900 LF $35 $31,500 Well Grout Seal 900 LF $20 $18,000 Well Development 224 HR $250 $56,000 Wellhead Piping, Vault, etc. 6 EA $15,000 $90,000 Installation Oversight Labor 160 HR $80 $12,800 CH2M HILL Estimate SUBTOTAL $296,300 Groundwater Treatment Systems Excavation for Building Foundation 1 LS $20,000 $20,000 Contractor Estimate Concrete Building Foundation 1 LS $30,000 $30,000 Contractor Estimate Concrete Footer 1 LS $30,000 $30,000 Contractor Estimate GW Treatment Building 1 LS $70,000 $70,000 Contractor Estimate Miscellaneous (Construction) 1 LS $5,000 $5,000 CH2M HILL Estimate Paved Access Road 125 TONS $130 $16,250 CH2M HILL Estimate Underground Utilities 1 LS $50,000 $50,000 Utility Tie-ins 1 LS $20,000 $20,000 Yard Piping 1 LS $40,000 $40,000 10,000 gal EqualizationTank 2 EA $8,726 $17,452 33-10-9662 4" Venturi Flow Meter 4 EA $4,000 $16,000 CH2M HILL Estimate 4" Steel Pipe (Exposed) 4,000 LF $13 $50,320 33-26-0104 4" Steel Fittings (Exposed) 20 EA $119 $2,380 33-27-0534/0552/0562 4" Check Valve 10 EA $292 $2,920 33-27-0404 4" Butterfly Valve 10 EA $544 $5,437 33-27-0424 Misc Plant Piping 1 LS $35,000 $35,000 Allowance Instumentation 1 LS $20,000 $20,000 Allowance Electrical 1 LS $50,000 $50,000 Allowance Pressure Gauge Assembly 4 EA $276 $1,104 Grainger Estimate Misc. (pipe stands, brackets, etc.) 1 LS $50,000 $50,000 CH2M HILL Estimate SUBTOTAL $531,863 Oxidant Materials Oxidant 1200 LBS 3.2 $3,840 Regenisis - includes materials and shipping Electrical Service (GW Treatment Systems and Wells) Electrical service 1 LS $10,000 $10,000 CH2M HILL Estimate SUBTOTAL $10,000 SUBTOTAL (In Situ System) $853,503 Contingency 25% $213,376 10% Scope + 15% Bid SUBTOTAL (System) $1,066,878

SUBTOTAL - CAPITAL COSTS $12,810,148

Project Management 5% $640,507 USEPA 2000, p. 5-13, $2MM-$10MM Engineering Design and Planning 8% $1,024,812 USEPA 2000, p. 5-13, $2MM-$10MM Construction Management 6% $768,609 USEPA 2000, p. 5-13, $2MM-$10MM Permitting (Injection) 1 LS $30,000 $30,000 CH2M HILL Estimate Operations and Maintenance Manual 1 LS $7,500 $7,500 CH2M HILL Estimate Procurement 1 LS $2,500 $2,500 CH2M HILL Estimate Construction Completion and QA/QC Report 1 LS $8,000 $8,000 CH2M HILL Estimate

TOTAL CAPITAL COST $15,292,000

Sheet 9 of 13 400201 Alternative: Groundwater Alternative 3b COST ESTIMATE SUMMARY Name: Insitu Upgradient Treatment, Public Water Supply Connection, and MNA

OPERATIONS AND MAINTENANCE COST UNIT DESCRIPTION QTY UNIT COST TOTAL NOTES Groundwater Monitoring (20 Outlying Homes) Groundwater Samples 20 LS $110 $2,200 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 12 HRS $80 $960 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,420 Allowance for Misc. Items 20% $1,884 SUBTOTAL $11,304

POETS System Maintenance O&M Staff (labor, overheads, vehicles, etc) 1 LS $7,000 $7,000 Carbon Usage 80 EA $732 $58,560 1 change-out/yr (including existing) SUBTOTAL $65,560 Treatment Building Property Leasing Property Leasing for TCE Treatment Building 30,000 SF $7 $210,000 Estimate from OMI

Inspection and Monitoring Monthly Site Visits Labor for Visit/Compliance Sampling 96 HR $80 $7,680 CH2M HILL Estimate - 1 person/mth Effluent Sampling (GW) 12 LS $110 $1,320 Contractor Estimate Reporting (Quarterly) 4 LS $8,000 $32,000 CH2M HILL Estimate Other Expenses (Shipping, supplies, etc.) 1 LS $1,000 $1,000 CH2M HILL Estimate SUBTOTAL $42,000 Allowance for Misc. Items 20% $8,400 SUBTOTAL $50,400 Contingency 30% $15,120 SUBTOTAL (SYSTEM O&M) $65,520

ANNUAL O&M COST $352,000

PERIODIC COSTS UNIT DESCRIPTION YEAR QTY UNIT COST TOTAL NOTES Groundwater Sampling Every 5 years 5 Groundwater Samples 21 LS $110 $2,310 Contractor Estimate QC Samples 4 LS $110 $440 Contractor Estimate Groundwater Sampling, Level D Labor 48 HRS $80 $3,840 CH2M HILL Estimate - 2 persons Equipment - meters 1 LS $500 $500 CH2M HILL Estimate Consumables 1 LS $200 $200 CH2M HILL Estimate Data Validation 13 HRS $80 $1,000 CH2M HILL Estimate Reporting 16 HRS $80 $1,280 CH2M HILL Estimate SUBTOTAL $9,570 Allowance for Misc. Items 20% $1,914 SUBTOTAL $11,484 Contingency 30% $3,445 10% Scope + 20% Bid SUBTOTAL (ANNUAL) $15,000

PRESENT VALUE ANALYSIS Discount Rate = 7.0% TOTAL TOTAL COST DISCOUNT PRESENT COST TYPE YEAR COST PER YEAR FACTOR (7%) VALUE NOTES

CAPITAL COST 0 $15,292,000 $15,292,000 1.000 $15,292,000 O&M COST PROPERTY LEASING 1 $210,000 $210,000 0.935 $196,262 GW MONITOR (20 OUTLYING HOMES) COST 1 to 30 $339,120 $11,304 12.409 $140,272 POETS O&M COST 1 to 30 $1,966,800 $65,560 12.409 $813,537 SYSTEM Monitoring O&M COSTS 1 $65,520 $65,520 0.935 $61,234 PERIODIC COST 2 $15,000 $15,000 0.87 $13,102 PERIODIC COST 4 $15,000 $15,000 0.76 $11,443 PERIODIC COST 6 $15,000 $15,000 0.67 $9,995 PERIODIC COST 8 $15,000 $15,000 0.58 $8,730 PERIODIC COST 10 $15,000 $15,000 0.51 $7,625 PERIODIC COST 12 $15,000 $15,000 0.44 $6,660 PERIODIC COST 14 $15,000 $15,000 0.39 $5,817 PERIODIC COST 16 $15,000 $15,000 0.34 $5,081 PERIODIC COST 18 $15,000 $15,000 0.30 $4,438 PERIODIC COST 20 $15,000 $15,000 0.26 $3,876 PERIODIC COST 22 $15,000 $15,000 0.23 $3,386 PERIODIC COST 24 $15,000 $15,000 0.20 $2,957 PERIODIC COST 26 $15,000 $15,000 0.17 $2,583 PERIODIC COST 28 $15,000 $15,000 0.15 $2,256 PERIODIC COST 30 $15,000 $15,000 0.13 $1,971 $18,098,440 $16,593,224

TOTAL PRESENT VALUE OF ALTERNATIVE $16,590,000

SOURCE INFORMATION

1. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

400202 Sheet 10 of 13 TABLE D-3 Estimated Quantities Calculations PVGCS OU2 Study Area Groundwater Media Feasibility Study

Description of Quantity

Estimated Quantities for:Alternatives 2-4 Domestic Well Abandonment

Home Well Abandonment 25,000 LF Assume 100 domestic wells approximately 250 feet deep. Assume an additional 10% contingency. CT&E estimate of $10 per foot. Connection to Municipal Supply System(1000') 100 LS Quote from Courageous Plumbing & Heating. Price includes excavation, materials, connections, testing, repair of sidewalk/asphalt. Does not include permit.

Sheet 11 of 13 400203 TABLE D-4 Unit Costs Derived from Means Unit Prices - Alt. G3 Pohatcong Valley Groundwater Contamination Site, N. J. Groundwater Feasibility Study

Labor Equipment Estimated Means Unadjusted Unadjusted Materials Unit Category Description Units Cost Cost Cost Cost ENVIRONMENTAL REMEDIATION COST DATA - UNIT PRICE (Ref. 1) 17-01-0106 Clear and Grub Heavy brush and Light Trees AC $2,729.00 $2,485.00 $0.00 $8,066 17-03-0101 Rough Grading SY $0.95 $2.55 $0.00 $5 17-03-0201 Excavation, Spoil to Side CY $0.43 $0.41 $0.00 $1 17-03-0276 Excavation, 1 Cy Hydraulic Excavator, CY $1.52 $2.14 $0.00 $6 17-03-0202 Trenching, 1 CY Gradall, Light Soil, 95 CY per hour CY $1.71 $2.99 $0.00 $7 17-03-0401 Trench Backfill, 3 CY, 950 CY $0.45 $0.66 $0.00 $2 17-03-0415 Backfill with excavated material CY $2.43 $0.81 $0.33 $6 17-03-0423 Backfill with Offsite Borrow, 6" Lifts, Spreading, Compaction CY $1.00 $2.10 $5.63 $12 18-01-0102 Gravel, Delivered & Dumped CY $1.78 $1.62 $21.11 $35 18-01-0105 Asphalt, Stabilized Base Course CY $0.61 $1.28 $32.38 $48 18-02-0101 Gravel, Delivered and Dumped CY $1.78 $1.62 $21.11 $35 18-02-0312 Asphalt Wearing Course TN $14.26 $14.24 $30.98 $87 18-05-0206 Silt Fence LF $1.41 $0.00 $0.70 $3 18-05-0302 Deliver and Spread Topsoil CY $4.06 $2.89 $20 $39 18-05-0402 Hydroseeding and Watering ACRE $67.71 $52.39 $3,491 $5,031 33-02-1705 TCLP VOC Analysis EA $0.00 $0.00 $144.34 $200 33-02-0508 VOC Analysis EA $0.00 $0.00 $166.00 $230 33-08--0508 Geocomposit Membrane Liner SF $0.09 $0.07 $0.53 $1 33-10- 9660 5,000 Gallon Above-Ground Tank EA $1,087.00 $156.87 $4,250.00 $7,954 33-12-9905 Chemical Feeder EA $631.75 $0.00 $1,463.00 $3,099 33-13-0117 50-100 gpm cartridge Filter EA $46.04 $0.00 $4,567.00 $6,415 33-18-0571 40 Mil HDPE Liner SF $0.90 $0.16 $0.30 $2 33-19-0210 Dump Truck Transportation HW, 200-299 Miles MI $0.00 $0.00 $2.32 $3 33-19-0217 Dump Truck Transportation HW, 900-999 Miles MI $0.00 $0.00 $2.00 $3 33-19-7264 Landfill HW Disposal CY $0.00 $0.00 $148.00 $205 33-23-0101 2" PVC, Schedule 40, Well Casing LF $2.34 $6.67 $1.15 $15 33-23-0103 6" PVC, Schedule 40, Well Casing LF $3.37 $9.60 $4.03 $25 33-23-0203 6" PVC, Schedule 40, Well Screen LF $5.61 $16.00 $9.17 $44 33-23-0256 2" PVC, Schedule 40, Well Screen LF $3.92 $11.18 $2.07 $25 33-23-0555 4" Submersible Pump, 56-95 gpm, 41'

NOTES:

(a) Productivity factor of 82% applied to labor unit costs where applicable. See Ref. 1 for details. (b) Local cost factor of 1.11 applied for the Warren County, New Jersey. See Ref. 1 for details. (c) Subcontractor overhead (15%) and profit (10%) included in unit cost were applicable. See Ref 2 for details. REFERENCES: 1. R.S. Means Company. 2008. Environmental Remediation Cost Data - Unit Price, 10th Edition. R.S. Means Company and Talisman Partners, Ltd. Kingston, MA. 2. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

Additional Unit Cost Information Description Units Unit Cost Soil Borings/Wells LF $47 Subtiltle D Landfill Transport and Disposal CY $100 POET Cost GAC 2x55-GAL Drum $732 Bag Filter with housing 1 $1,400 Miscellaneous Parts LS $600 SUBTOTAL $3,464

Sheet 12 of 13 400204 TABLE D-5 Unit Costs Derived from Means Unit Prices PVGCS OU2 Study Area Groundwater Media Feasibility Study

Labor Equipment Materials Local Contractor Estimated Means Unadjusted Productivity Adjusted Unadjusted Productivity Adjusted Cost Cost Mark-Up Unit Category Description Units Cost Factor (a) Cost Cost Factor Cost Subtotal Factor (b) Subtotal Overhead Profit Cost ENVIRONMENTAL REMEDIATION COST DATA - UNIT PRICE (Ref. 1) 17-03-0101 Rough Grading SY $0.95 82% $1.16 $2.55 100% $2.55 $0.00 $3.71 1.11 $4.12 15% 10% $5.00 17-03-0201 Excavation, Spoil to Side CY $0.43 82% $0.52 $0.41 100% $0.41 $0.00 $0.93 1.11 $1.04 15% 10% $1.00 17-03-0202 Trenching, 1 CY Gradall, Light Soil, 95 CY per hour CY $1.71 82% $2.09 $2.99 100% $2.99 $0.00 $5.08 1.11 $5.63 15% 10% $7.00 17-03-0401 Trench Backfill, 3 CY, 950 CY $0.45 82% $0.55 $0.66 100% $0.66 $0.00 $1.21 1.11 $1.34 15% 10% $2.00 17-03-0415 Backfill with excavated material CY $2.43 82% $2.96 $0.81 100% $0.81 $0.33 $4.10 1.11 $4.55 15% 10% $6.00 17-03-0423 Backfill with Offsite Borrow, 6" Lifts, Spreading, Compaction CY $1.00 82% $1.22 $2.10 100% $2.10 $5.63 $8.95 1.11 $9.93 15% 10% $12.00 17-03-0517 Spread/Compact Lg. Areas, 6" Lifts, D8 and Towed Sheepsfoot CY $0.22 82% $0.27 $0.48 100% $0.48 $0.00 $0.75 1.11 $0.83 15% 10% $1.00 18-01-0102 Gravel, Delivered & Dumped CY $1.78 82% $2.17 $1.62 100% $1.62 $21.11 $24.90 1.11 $27.64 15% 10% $35.00 18-01-0105 Asphalt, Stabilized Base Course CY $0.61 82% $0.74 $1.28 100% $1.28 $32.38 $34.40 1.11 $38.19 15% 10% $48.00 18-02-0312 Asphalt Wearing Course TN $14.26 82% $17.39 $14.24 100% $14.24 $30.98 $62.61 1.11 $69.50 15% 10% $87.00 33-02-1806 VOC Analysis (Method TO-14) - Offgas EA $0.00 82% $0.00 $0.00 100% $0.00 $144.34 $144.34 1.11 $160 15% 10% $200.00 33-02-0508 VOC Analysis EA $0.00 82% $0.00 $0.00 100% $0.00 $166.00 $166.00 1.11 $184 15% 10% $230.00 33-19-0210 Dump Truck Transportation HW, 200-299 Miles MI $0.00 82% $0.00 $0.00 100% $0.00 $2.32 $2.32 1.11 $2.58 15% 10% $3.00 33-19-0217 Dump Truck Transportation HW, 900-999 Miles MI $0.00 82% $0.00 $0.00 100% $0.00 $2.00 $2.00 1.11 $2.22 15% 10% $3.00 33-19-7264 Landfill HW Disposal CY $0.00 82% $0.00 $0.00 100% $0.00 $148.00 $148.00 1.11 $164.28 15% 10% $205.00 33-19-7270 Landfill Solid Waste Disposal CY $0.00 82% $0.00 $0.00 100% $0.00 $93.50 $93.50 1.11 $103.79 15% 10% $130.00 33-23-0101 2" PVC, Schedule 40, Well Casing LF $2.34 82% $2.85 $6.67 100% $6.67 $1.15 $10.67 1.11 $12 15% 10% $15.00 33-23-0256 2" PVC, Schedule 40, Well Screen LF $3.92 82% $4.78 $11.18 100% $11.18 $2.07 $18.03 1.11 $20 15% 10% $25.00 33-23-0555 4" Submersible Pump, 56-95 gpm, 41'

NOTES: (a) Productivity factor of 82% applied to labor unit costs where applicable. See Ref. 1 for details. (b) Local cost factor of 1.11 applied for the Warren County, New Jersey. See Ref. 1 for details. (c) Subcontractor overhead (15%) and profit (10%) included in unit cost were applicable. See Ref 2 for details.

REFERENCES: 1. R.S. Means Company. 2008. Environmental Remediation Cost Data - Unit Price, 10th Edition. R.S. Means Company and Talisman Partners, Ltd. Kingston, MA. 2. United States Environmental Protection Agency. July 2000. A Guide to Preparing and Documenting Cost Estimates During the Feasibility Study. EPA 540-R-00-002. (USEPA, 2000).

Sheet 13 of 13 400205