DECLARATION STATEMENT

RECORD OF DECISION

NASCOLITE CORPORATION SITE

SITE NAME AND LOCATION Nascolite Corporation Doris Avenue, Cities of Millville and Vineland Cumberland County, New Jersey ——:———————

STATEMENT OF BASIS AND PURPOSE This decision document presents the selected, remedial action for the Nascolite Corporation site, which was chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 .(CERCLA) , as amended by the~ Superfund Amendments and Reauthorization Act of .1.986. (SARA) , and :to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan. This decision document summarizes the factual and legal bases for selecting the remedy for the site. The attached index identifies the items that • comprise the administrative record for the site, upon which this decision is based. . . 'The State of New Jersey concurs with the'remedy selected in this document. " ,•_.•.,.

ASSESSMENT OF THE SITE . . Actual or threatened releases of hazardous substances from the site, if not addressed by implementing the response action selected in this Record of Decision, may"present an imminent and substantial endangerment to public health, welfare or the environment.

DESCRIPTION OF THE SELECTED REMEDY The remedial alternative described in this document represents the second of two planned operable units for the Nascolite site. It will address unsaturated soil and wetlands contamination at the site. The first operable unit, which addresses the groundwater contamination, was the subject of a previous Record of Decision. No further remedial actions are planned for the Nascolite.site.

The selected-remedy includes the following components: o Structure demolition including asbestos abatement with appropriate disposal; :.: • ; -

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o V VO o Excavation and solidification/stabilization of unsaturated and wetlands soils contaminated above cleanup standards; o Replacement of solidified soils on the site; o Restoration of affected wetlands; and o Appropriate environmental monitoring to ensure the effectiveness of the remedy.

STATUTORY DETERMINATIONS The selected remedy is protective of human health and the environment, complies with Federal and State requirements that are legally applicable or relevant and appropriate to-'the remedial action and is cost effective. This remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable, and it satisfies the statutory preference for remedies that employ treatment that reduce toxicity, mobility, or volume as their principal element. The remedy, when completed, will achieve applicable or relevant and appropriate requirements related to this site. Pursuant to Section 121(c) of CERCLA, as amended by SARA, if a remedial action is selected in which any hazardous substance remains at the site, a five year review of the site is required to assure protection of human health and the environment. EPA will conduct a five year review after commencement of the remedial action because the selected remedy will not allow unrestricted use of the site.

onstantine Sidamon-Eristoff / / Dayef Regional Administrator /^ S-—— / U.S. EPA Region II / / I

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NJ O 00 O DECISION SUMMARY

KASCOLITE CORPORATION SITE CITIES OF MILLVILLE AMD VINELAND, NEW JERSEY

SITE LOCATION AND DESCRIPTION The Nascolite site is located on Doris Avenue in the cities of Millville and Vineland, Cumberland County, New Jersey (see Figure 1) . The site is situated near the intersection of U.S. Route 55 and Wheaton Avenue. The Nascolite property is delineated as Lots 60 and 61 of Block 234 in Millville and Lot 2 of Block 1121 in Vineland. These parcels of land cover an area of about 17.5 acres, of which over half is wooded. During its operation, the Nascolite Corporation was a manufacturer of polymethyl methacrylate (poly- MMA) sheets, commonly known as acrylic or plexiglass. Approximately seven acres of the property were used for manufacturing and supporting activities. Six buildings on the site served as the production facility, laboratory and offices for the company (see Figure 2) . The area surrounding the Nascolite site is zoned for both residential and industrial use. Approximately 1,500 feet to the east and southeast of the site, several homes are located along Wheaton and Doris Avenues . An apartment complex borders the southern property line at approximately 1,000 feet. The home of the site owner is located within the site boundaries. Conrail railroad tracks lie on the site's western border, and a scrap metal yard, the Cumberland Recycling Corporation, lies on the western side of these tracks. This scrap yard was incorporated into the study area. A cement casting company is located to the northwest of the Nascolite site. There is a drainage ditch located east of and parallel to the Conrail tracks which received wastewater from the manufacturing process. Groundwater in the area generally flows in a southwesterly direction and is used as a source of potable water. The nearest downgradient potable well is Millville 's municipal supply well, which is approximately two miles from the site. Remediation of the contaminated groundwater has been addressed in the March 1988 Record of Decision (ROD) for the first operable unit at the site.

SITE HISTORY The Nascolite Corporation plant was constructed in 1952 and was operated between 1953 and 1980. In its production of poly-MMA, Nascolite used both scrap acrylic and liquid MMA monomer. The scrap material was reclaimed through a depolymerization process, which included several distillation steps. Waste, residues from distillation were found in several previously buried tanks in the north plant area during site investigations. Perforations in one

o 00 of the excavated tanks indicated the likelihood of liquid waste leaking into the soils. The New Jersey Department of Environmental Protection (NJDEP) issued an Administrative Order to Nascolite Corporation in February 1980, requiring it to stop discharging wastewaters into the ditch located at the site. In September 1981, an Administrative Consent Order (AGO) was entered into by NJDEP and Nascolite Corporation, and the NJDEP Division of Water Resources (DWR) began in-depth investigations at the Nascolite site. Under the AGO, three groundwater monitoring wells were installed and subsequently NJDEP collected and analyzed groundwater samples. The wells were installed in November 1981, and groundwater samples were collected for analyses in the fall of 1981, and again in February of 1983. Both analyses showed significant concentrations of volatile organic chemicals in all three wells. Individual volatile organic compounds (except MMA) were found at maximum concentrations of 22 to 7,700 micrograms/liter (ug/1) in the groundwater samples. During the second sampling effort, a strong "sweet" odor emanated from the northernmost well. In addition, the aqueous sample contained a red plastic material which hardened after being extracted from the well. A strong fuel-like odor was evident in the other two wells. In September 1983, the site was placed on EPA's National Priorities List (NPL). In November 1984, TRC Consultants Inc. (TRC), under contract to NJDEP, began a remedial investigation and feasibility study (RI/FS), The RI/FS was conducted in accordance with 40 CFR 330.69 with funds provided by the Environmental Protection Agency (EPA) through a cooperative agreement. The objectives of the RI/FS were to delineate the nature and extent of contamination at the site and to develop and evaluate remedial alternatives to determine the most appropriate remedial action to be taken. NJDEP identified over one hundred 55-gallon drums and several underground storage tanks buried on the site. At the initiation of the remedial investigation, Nascolite Corporation removed some of the buried drums and debris pursuant to the AGO. The remaining drums were subsequently removed by EPA during a Removal Action . performed from November 1987 to March 1988 at the request of NJDEP. On November 20, 1987, NJDEP requested that EPA assume the role of lead agency for the site. Soil sampling performed during the removal action in 1987 indicated the presence of up to 41,800 parts per million (ppm) of lead in unsaturated soils. EPA's removal action also included the erection of a fence around the on-site buildings and the North Plant area, and the placement of a plastic tarpaulin over soils contaminated with inorganic compounds. In addition, waste material storage tanks were cleaned and cut into scrap metal. Twenty cubic yards of MMA contaminated soil were excavated from the site and thirty cubic yards of asbestos f5 insulation were removed from the site buildings. The wastes in ^ tanks and remaining drums on-site were sampled, bulked into 1,825 0 o 2 10 o 00 to gallons of corrosive/ ignitable liquid and 134 cubic yards of solidified solvent sludge, and shipped for proper disposal off- site. The remedial investigation activities at the Nascolite site were conducted during several separate investigative phases beginning in February 1985. The first phase of the investigation, performed by NJDEP between February and April 1985, included the installation of twelve monitoring wells. Sampling and analysis was performed on these wells, in addition to seven privately owned wells, the City of Millville's well, waste material on-site, and site soils. Analysis of samples taken from monitoring wells showed significant levels of contamination, and that additional monitoring wells were needed to delineate the extent of the contamination. Seven additional wells were installed and sampled in November and December 1985. In February 1987, nine private potable wells near the site were sampled. In June 1987, several on-site monitoring wells were sampled for the purpose of conducting radiation analyses. At the conclusion of the initial phase of the RI/FS, both EPA and NJDEP determined that sufficient information was available to support a decision to address the contaminated groundwater, however, additional data were necessary to assess remedial options for contaminated soil. Consequently, the site remediation was divided into operable units. The First Operable Unit (FOU) addresses contaminated groundwater. On March 31, 1988, EPA issued a Record of Decision which embodied EPA's remedy selection process for the FOU. The ROD required the following actions: 1. Groundwater extraction with on-site treatment and rein j ection ; 2. Provision for an alternate water supply to potentially affected residents; and 3 . Performance of additional studies to determine appropriate remedial measures for contaminated soil and on-site buildings. The alternate water supply, which provides public water to residences on Doris Avenue, was constructed by two Potentially Responsible Parties (PRPs) under an Administrative Order on Consent with EPA. The design of the groundwater remediation for the FOU was initially undertaken and funded by EPA. Treatability studies, which were conducted as part of the remedial design, indicated that other treatment options should be explored. The design and remedial action is being conducted by PRPs under a Unilateral Administrative Order with EPA oversight. The final design which will include additional site characterization work and comprehensive treatability studies is expected to be completed in

to o 00 January 1993 since it will involve a complicated treatment process including a series of treatment technologies.

ENFORCEMENT Initial enforcement investigations identified the site owner and operator, the Nascolite Corporation, as a PRPs. Subsequent to the FOU ROD, EPA has identified additional PRPs to whom Special Notice Letters were sent pursuant to Section 122 (e) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA) . These PRPs sent hazardous substances to the site. A group of PRPs are currently performing the FOU remedial design under a Unilateral Administrative Order (UAO) . EPA is presently investigating other potential PRPs believed to have generated hazardous substances including, but not limited to, ^.ead, found in site soils. These parties are being investigated based on business records provided to EPA.

SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY The Nascolite site has been divided into two operable units: the first operable unit addresses the contaminated groundwater and the second operable unit addresses other contaminated source areas, such as buildings, soil and debris. A ROD was issued for the FOU in March 1988; a description of the selected remedy for groundwater contamination can be found in the "Site History" section above. The remedy selected in this ROD .addresses contaminated soil. Although buildings and debris are not believed to be a source of soil and groundwater contamination, they do pose a number of worker health and safety hazards and obstruct conduct of work at the site. Furthermore, on-site buildings are considered a source of asbestos contamination. Therefore, a strategy for building demolition and debris management is also contained in this ROD. For the second operable unit, contaminated soil poses the principal threat at the site, particularly in the area north of the manufacturing building and in the northern section of the wetland (see Figure 3) . Concentrations of lead in the soil exceed EPA's recommended cleanup range of 500 to 1,000 ppm as per the Office of Solid Waste and Emergency Response (OSWER) Directive # 9355.4-02 for industrial properties. Lead levels as high as 41,800 ppm have been detected in soil at the site. Currently, approximately 8,000 cubic yards of soil exceed the remediation goal for lead of 500 ppm. MMA was detected in soil, but generally in concentrations which were below health-based levels. Soils were also sampled for volatile organic compounds (VOCs) and semi-volatile organic o o

to o 00 compounds (semi-VOCs) . Both VOCs and semi-VOCs were detected in several soil borings on-site. However, levels of these compounds detected do not represent an unacceptable human health risk for the exposure pathways analyzed. The response action described in this ROD addresses soil contamination at the site and is the final action contemplated for the Nascolite site.

COMMUNITY RELATIONS HISTORY The history of community relations activities for the FOU are summarized in the March 1988 ROD. On March 1, 1991, EPA presented its Proposed Plan for the second operable unit remedy (addressing soils, wetlands, buildings and debris) to the public. A public meeting was held on March 14, 1991 to present the results of the supplemental RI/FS and EPA's preferred remedy. The /Proposed Plan and other information related to the Nascolite supplemental RI/FS activities were distributed to the public on March 1, 1991 and the public comment period ran from then until April 15, 1991. Responses to all public comments received during the comment period are included in the Responsiveness Summary, which is an attachment to this document. The Responsiveness Summary includes EPA's responses to questions/ concerns raised at the March 14, 1991 public meeting and all supplemental written comments received. An Administrative Record which contains documents supporting EPA's decision on site remediation has been made available for public review.

SUMMARY OF SITE CHARACTERIZATION

1. Site Geology The Nascolite Corporation site is located in the New Jersey Coastal Plain which is underlain by a wedge-shaped mass of unconsolidated sediments composed of clay, silt, sand and gravel layers. The entire sediment wedge is considered an independent and isolated hydrologic system, bounded by the Atlantic Ocean, the Delaware River, and the rocky Appalachian Highlands of Northern New Jersey. The geologic formation encountered during the RI at the site is a Late Miocene-age Cohansey Sand, which is the predominant surf icial formation in Cumberland County, New Jersey. Beds of gravel are present throughout the unit and generally found near the base of well defined channel deposits. The Nascolite site is underlain by Cohansey sediments that are gray to reddish-yellow, fine to very coarse sands with occasional lenses of silt and/or clay and a few discontinuous clay-rich layers. a

to o 00 Ul Lying conformably beneath the Cohansey Sand are the dark grey upper sands of the Kirkwood Formation. The middle Miocene-aged Kirkwood Formation, which eventually grades into a. silty clay, is present over most of southern New Jersey. The permeable sands of the Kirkwood and the Cohansey Sand together comprise a water table aquifer that underlies approximately 3,000 square miles of the New Jersey Coastal Plain. The hydraulic gradient at the site has been determined to have substantial vertical downward as well as horizontal flow components. This indicates that the site may be situated within a groundwater recharge zone. The water table is variable at 10 to 15 feet below ground surface due to seasonal changes and the general groundwater flow direction is to the southwest, with a small northwestern flow component. The site covers an area of about 17.5 acres, of which over half is wooded. Topographic relief at the Nascolite site and the surrounding areas is slight. The site area is relatively flat with land surface elevations varying between 48 and 58 feet above mean sea level (MSL) . Within a one-mile radius of the site, elevations range from about 40 feet south of the site to about 90 feet MSL in the northern part of the site. Within a two-mile radius, the topography varies from about 10 feet MSL south of the site to about 100 feet MSL to the north. The only surface drainage feature in the immediate area is a drainage ditch which runs parallel to and on the east side of the Conrail tracks. A portion of the site to the southwest is comprised of wetlands. 2. Groundwater Contamination (FOIH MMA, a major groundwater contaminant at this site, was found in groundwater extracted from two of the monitoring wells, MW-12S and MW-8S, at concentrations of 400 and 7,400 ppm, respectively. The ground water from these two monitoring wells also contained bis (2- ethylhexyl) phthalate and di-n-butyl phthalate as well as concentrations of several volatile organic compounds including benzene, toluene, ethylbenzene and trichloroethylene (TCE) . These and several other monitoring well samples had an odor characteristic of MMA. However, no MMA was detected in any other monitoring well. Samples from wells MW-5S ("S" indicating a shallow well) and MW-10S wells contained bis(2-ethylhexyl) phthalate. The MW-11S sample was contaminated with several volatile organic compounds, including ethylbenzene, benzene, toluene and 1,1,1-trichloroethane and at lower levels with bis (2- ethylhexyl) phthalate and di-n-butyl phthalate. The samples from MW-7D ("D" indicating a deep well), which is downgradient of MW- 11S, contained bis(2-ethylhexyl) phthalate, vinyl chloride, 1,2- dichloroethane, ethylbenzene and benzene. Samples from MW-4S and MW-4D, MW-17S and MW-17D, MW-15D, MW-9S and MW-9D as well as MW^- t- 16S, MW-6S, MW-13S and MW-14S contained no detectable organic ^ o o

to o 00 cc.iapcu.nds except methylene chloride (a common laboratory contaminant) and only a few metals at background levels. Seven off-site and one on-site drinking water wells were sampled for inorganic and organic contaminants as part of the Nascolite field investigation. The nearest downgradient potable well that could potentially be impacted by contamination from Nascolite is Millville's municipal supply well (WP-8) . This well was sampled during the 1986 investigation and is approximately two miles from the site. The results of a sample obtained from this well indicated no contamination. None of the off -site potable wells contained any detectable organic chemicals except methylene chloride, which is a common laboratory contaminant. All but one well, WP-6, contained metal concentrations within the federal drinking water standards. However, preliminary findings of the FOU KI indicated that the contamination found in this well cannot be attributed to Nascolite, since it is located one mile upgradient of the site. Additional site characterization work underway as part of the second operable unit treatment design will provide additional information on the groundwater flow gradient and contaminant source areas. There is one on-site potable well, WP- 10, that supplied water to the former Nascolite office building. A sample from that well was contaminated with several volatile organic compounds including benzene, ethylbenzene, toluene, trichloroethylene and MMA. The Cumberland County Health Department has notified the owners of wells WP-6 and WP-10 not to use them for potable purposes. 3- Preliminary Findings on Soil Contamination fFOU) During the FOU RI, 15 test pits were excavated and 19 soil borings, which were later completed as monitoring wells, were drilled to characterize the subsurface soils. The drilling program included both shallow and deep borings. The water table at the site varies from approximately 10 to 15 feet below the ground surface due to seasonal changes. All subsurface soil samples collected during the FOU soil boring program were saturated and located within the water table. The 14 shallow borings were advanced approximately 10 to 15 feet below the water table to a depth of 30 feet below surface. Four of the deep borings, 7D, 9D, 15D and 17D, were approximately 60 feet deep, and boring 4D was 57 feet deep. Contamination, which primarily consisted of base/neutrals, volatile organics and MMA, was found in the one-acre north plant area and at two smaller areas. This contamination, found below the water table, is addressed in the FOU ROD. Four surface soil samples were collected from zero to six inches in depth during the remedial investigation in 1985. Samples SS1, SS2 and SS3 were taken from .the ditch between the plant and the

o 00 -J time held a pipe that conveyed process cooling water into a swimming pool at the home of the site owner. All surface soil samples contained high metal concentrations, primarily in samples SS1, SS2 and SS3. The ditch samples all contained lead concentrations greater than 14,000 ppm. Some organic compounds were also detected in the soils. In November 1987, EPA tested the soils and found 41,800 ppm lead in one surface soil sample adjacent to the loading dock. 4. Supplemental Remedial Investigation and Feasibility Study A supplemental RI/FS was initiated by EPA in March 1988, subsequent to the ROD for the FOU. EPA conducted the supplemental RI to achieve the following objectives: to determine the nature and extent of hazardous substances, pollutants, or contaminants in soil, debris and buildings at the site; to determine the impact of these hazardous substances on public health, welfare and the environment; to determine the extent to which sources of contaminants can be adequately identified and characterized;,to gather sufficient information to determine the appropriate remedial action; and to provide data in order to evaluate and estimate costs during the FS for selected remedial alternatives. The purpose of the FS was to develop a range of remedial alternatives. These alternatives were evaluated based on protection of human health and the environment; compliance with ARARs; reduction of toxicity, mobility and volume; long and short- term effectiveness; implementability; cost; and State and community acceptance. The supplemental RI/FS included additional field activities to complete site characterization and the identification and evaluation of remedial alternatives for the soil and structures. Remedial alternatives were developed for each area of concern. Field activities included initial soil gas surveys in December 1988 to evaluate the extent of volatile organic compounds in the soil matrix. In May 1989, an X-Ray Fluorescence survey was performed to evaluate the extent of surface and near surface soil contamination for lead. Split-spoon, hand-auger and deep soil sampling was conducted in December 1988 and April 1989 as part of the geological investigation for the unsaturated soils (0-15 feet), saturated soils (deeper than 15 feet) and wetlands soils. A building survey was also conducted at the Nascolite site consisting of wipe sampling of building surfaces and bulk sampling of debris contained in the buildings. At the conclusion of all soil sampling, a location survey was conducted so that elevations of all boring locations could be accurately determined. The location survey was conducted in October 1989. In April 1991, Toxicity Characteristic Leaching Procedure (TCLP) testing was performed on soil samples from four site locations where high lead contaminations had been detected. A summary of all findings follows: jp3

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to O 00 CO 4a. Organic Contamination in Unsaturated Soils Unsaturated soils are located above the water table to a depth of approximately 10 to 15 feet from the ground surface. Volatile and semi-volatile organic contaminants, including MMA, were detected in Unsaturated soils between three and ten feet. • However, concentrations of MMA in Unsaturated soils were below the health- based level of 5 ppm. An area containing 630 ppm of total semi- volatile organic contaminants was identified in the North Plant area (SB-3D) at a depth of three feet. Another area containing 450 ppm of total semi-VOCs was identified in the wetlands, at boring SB-5H, at a depth of zero to two feet. Total VOCs were generally detected a levels below 1 ppm in soils between three and ten feet. However, at a depth of 3-5 feet, 79 ppm total VOCs were detected in SB-US and 10 ppm total VOCs were detected in boring SB-7S. Tables 1 and 2 contain the sampling results for organic contaminants found in surficial soils. / 4b. Inorganic Contamination in Unsaturated Soils High levels of inorganic contaminants have been detected in soils within the North Plant area and south of the main processing plant (i.e., up to 41,800 ppm lead detected during FOU investigations) as shown in Table 3. During the second operable unit (SOU) investigation, lead was detected at levels of up to 10,700 ppm. Inorganic contaminants detected include cadmium, copper, lead, zinc, mercury and selenium. However, lead was the primary inorganic contaminant detected at concentrations in excess of< action levels. Vertical migration of inorganic contaminants does not occur beyond 3 feet below the ground surface except for lead, which was found above the action level of 500 ppm down to a depth of 15 feet just north of the cracker house and in the area of the former loading dock. Extraction Procedure (EP) Toxicity testing was performed on soil ssr.ples to determine leachability characteristics and whether contaminated soil should be classified as hazardous waste subject to the Resource Conservation and Recovery Act (RCRA) . The test results revealed non-detectable levels of metals in the leachate, indicating that the soil was not EP toxic. In April 1991, TCLP testing was performed on site soils to confirm the EP Toxicity test results. Eight samples from four locations with suspected high lead concentrations were sampled at depths of 1-2 feet and 2-3 feet. The TCLP test results did not confirm the EP Toxicity test results, but demonstrated that site soils comprise a RCRA characteristic waste, since lead levels above 5 ppm were detected in leachate in six samples. In addition, in two samples, cadmium was detected at levels above TCLP regulatory levels.

10 o 00 4c. Wetlands Soils Inorganic contaminants (i.e., lead and cadmium) were detected in the ditch along the southwestern edge of the site and along the western edge of the wetland, to a maximum depth of five feet. Contamination decreased to low or background levels toward the southern edge of the wetland. There was no evidence of contaminant migration toward Petticoat Stream. Lead and cadmium, which appear to have migrated through surface water transport and sediment erosion from the drainage ditch, were detected at concentrations of 1,420 ppm and 57.7 ppm, respectively at a depth of zero to two feet. Table 4 shows the levels of these contaminants in the wetlands. An area containing 450 ppm of total semi-volatile organic contaminants was identified in the wetlands (boring SB-5H) at a depth of zero to two feet. Sampling results/ for organic contaminants are presented in Tables 5 and 6. 4d. Structures and Debris On-site structures from the facility's operational period have been poorly maintained and are in a dilapidated state. Roofs on several of the buildings have partially collapsed, leaving the remaining roofing material in danger of collapse. These conditions would pose a worker health and safety hazard during the conduct of any remedial activities. Portions of the existing structures are contaminated with asbestos. Asbestos contaminated materials were observed to be in a friable state and the maximum detected concentration was 40 percent asbestos. Table 7 presents the results of asbestos sampling conducted in the building bulk and debris. MMA was detected in soil and debris samples, however, these levels were similar to those found in blanks. Therefore, results on MMA contamination in building bulk and debris are inconclusive. Tables 8 and 9 present the results of MMA and metals analysis "in the building bulk and debris sample data, respectively.

4e. Saturated Soils Saturated soil samples were also collected during the supplemental RI. Saturated soil contamination at the site consists of volatile and semi-volatile organic contamination including MMA, which begins at the water table; at approximately 10 to 15 feet below ground level, and extends down to 30 feet below the water table. Sampling results for organic contaminants are shown in Tables 10 and 11. Contamination assessment studies have identified a downward s1-s 3 vertical gradient, which would tend to carry contamination from the o o 10 M

N> O VO O water table down deeper into the aquifer. At approximately 35 feet below the surface, the organic contamination zone extends northwest and southeast over the main plant area. This contamination is in the saturated zone and will not be addressed in this operable unit. However, the contamination will be addressed in the implementation of the FOU since the contamintion is within the groundwater zone. This information regarding organic contamination in saturated soils may be useful in the design of the groundwater treatment system to be constructed as part of the first operable unit remedy. Although lead was detected to a depth of 15 feet in soils near the North Plant area, no inorganic contamination was detected in saturated soils or in the groundwater in this area, as shown in Table 12 . It can be concluded that inorganic contaminants in the unsaturated soil have not leached into the groundwater.

SITE CHARACTERIZATION In summary, inorganic soil contamination in the unsaturated zone and wetland soil are of concern. Specifically, lead contamination in soil exceeds the EPA cleanup level of 500 ppm and is the primary contaminant of concern. Lead concentrations of up to 10,700 ppm were detected during the SOU at the site. Wetland areas on the site contain lead concentrations of up to 1,420 ppm. The lateral extent of lead contamination is depicted in Figure 3. Vertically, lead contamination does not appear to occur below three feet, except in the area of the former loading dock and just north of the cracker house (see Figure 3). Approximately 8,000 cubic yards of soil are contaminated above the cleanup level for lead. With several exceptions, volatile and semi-volatile organic contaminants were detected at relatively low levels in unsaturated soil. In many instances, at the same soil boring location, organics were detected in higher levels in saturated soils than in unsaturated soils. This may indicate that the soils have been substantially depleted as a source of organic groundwater contamination. Based on the data, it can be concluded that inorganic contaminants in the unsaturated zone have not at this time migrated into the groundwater. Results of TCLP testing have indicated, however, that site soils have substantial potential to leach lead. The primary migratory routes which are of concern include rainwater runoff and soil erosion, which may expand the area of contamination and further impact the wetland. Lead at the surface of the site could be contacted by trespassers and wildlife and could be taken up by wetland vegetation. The "SUMMARY OF SITE RISKS" section below, presents further information on exposure routes and the risk posed by the site.

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to o SUMMARY OF SITE RISKS EPA has previously conducted a baseline Risk Assessment (RA) evaluating risks posed by contaminated groundwater at the site. The findings of that RA are contained in the RI report for the FOU and are summarized in EPA's March 1988 ROD. EPA conducted a baseline RA for the "No Action" Alternative for the SOU to evaluate the potential risks to human health and the environment associated with the Nascolite site in its current state. The RA for the SOU focuses on risks posed by contaminants detected in the unsaturated soils. The RA is available for review in the information repositories established for this site. The following discussion summarizes the findings of the RA. Although the surrounding properties are zoned for residential use, the land comprising the site is zoned as industrial. In the future, the site could potentially be developed for industrial purposes. Currently, approximately sixty residential homes, including apartments, are located within one-half mile of the site. Several homes are located immediately east and southeast of the site along Wheaton and Doris Avenues. The Cumberland Greens Apartment Complex borders the southern property boundary of the site. EPA's RA identified several potential exposure pathways by which the public may be exposed to contaminant releases at the site under current and future land-use scenarios (Table 13) . Although the site is fenced to restrict access, signs of vandalism and trespassing have been observed. Adolescent and adult trespassers were identified as potential receptors for contaminants in surface soil under current land-use conditions. The future land-use exposure scenario assumed a short-term construction project involving excavation at the site. Under this scenario, construction workers and nearby residents were identified as potential receptors for contaminants present in surface and subsurface soil at the site. Contaminants of concern (COCs) were selected by applying the EPA- recommended criteria. Table 14 lists these contaminants along with the range of concentrations of these contaminants detected in site soils. Non-carcinogenic risks are assessed using a hazard index (MHIM) approach, based on a comparison of expected contaminant intakes and safe levels of intake (Reference Doses) . Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health effects. RfDs, which are expressed in units of ing/kg/day, are estimates of daily exposure levels for humans which are thought to be safe over a lifetime (including sensitive individuals) . EPA verified RfDs are not available for all COCs, (i.e., lead) and therefore, risks associated with some of these chemicals could not

12

NJ O VO NJ ire quantitatively assessed. In this RA, risks associated with lead were assessed qualitatively due to a lack of EPA-verified toxicity values. The reference doses for the COCs at the Nascolite site are presented in Table 15. Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from contaminated soil) are compared with the RfD to derive the hazard quotient for the contaminant in the particular media. The hazard index is obtained by adding the hazard quotients for all contaminants across all media. A HI greater than 1 indicates that the potential exists for non- carcinogenic health effects to occur as a result of site-related exposures. The HI provides a useful reference point for gauging the potential significance of multiple contaminant exposures within a single medium or across media. His were calculated for the exposure scenarios assessed and are presented in Table 16. Since these His are less than 1, non-carcinogenic adverse health effects are unlikely for contaminants that were quantitatively assessed for all exposures routes considered. Potential carcinogenic risks were evaluated using the cancer potency factors developed by EPA for the compounds of concern. Cancer slope factors (SFs) have been developed by EPA's Carcinogenic Risk Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. SFs, which are expressed in units of (mg/kg/day)'1, are multiplied by the estimated intake of a potential carcinogen, in mg/kg/day, to generate an upper-bound exposure to the compound at that intake level. The term "upper bound" reflects the conservative estimate of the risks calculated from the SF. Use of this approach makes the underestimation of the risk highly unlikely. The SFs for the COCs are presented in Table 17. For known or suspected carcinogens, EFA considers excess upper bound individual lifetime cancer risks of between 10"4 to 10"* to be acceptable. This level indicates that an individual has not greater than a one in ten thousand to one in a million chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year period under specific exposure conditions at the site. The potential cancer risks associated with the site are presented in Table 18. The greatest potential cancer risk for the site was calculated for a trespasser under current and/or future land-use conditions. The maximum cancer risk for an adult trespasser from surface soil is 2.38 x 10'7. In summary, the quantitative risk characterization suggests no unacceptable non- carcinogenic or carcinogenic risks under current or future land-use conditions for contaminants of concern quantitatively evaluated. Note that the calculated non-carcinogenic and carcinogenic risks do g not include the potential current and future risks posed by lead >-3 o o 13 M to o «3 Ul contamination since EPA verified toxicity values are not available to quantitatively assess lead exposure. Exposure to lead has been associated with non-carcinogenic and carcinogenic effects. The major adverse non-carcinogenic effects in humans caused by lead include alterations in the hematopoietic and nervous systems. The toxic effects are generally related to the concentration of this metal in blood. High blood levels can cause severe irreversible brain damage and possible death. EPA has classified lead as a probable human carcinogen (B2 category). This category indicates that there is sufficient evidence from laboratory studies of carcinogenicity in animals. Lead contamination is of particular concern at the Nascolite site because it was detected at high concentrations in many areas of the site. In lieu of performing a quantitative RA for lead, EPA performed a qualitative assessment. Lead has been detected in soils at a maximum concentration of 41,800 ppm, which is significantly higher than EPA's recommended soil cleanup range of 500-1,000 ppm. EPA guidance recommends using the soil cleanup range for lead until toxicity values are established which would enable the performance of a quantitative risk assessment. Based on the detected levels of lead on site, current/potential risks pose an imminent and substantial endangerment to public health, welfare or the environment. Risks posed by all contaminants for which EPA performed a quantitative assessment, including organic compounds, fall within an acceptable range, and do not warrant an action. However, at the Nascolite Corporation Site, the risk assessment did not quantitate lead exposure risks because of a lack of toxicity values. Therefore, the quantitative risk value potentially underestimates overall site risks. Risks posed by lead contamination were qualitatively determined to be unacceptable. More specific information concerning public health risks, including quantitative evaluation of the degree of risk associated with various exposure pathways is presented in the RI report. Actual or threatened releases of hazardous substances from this site, if not addressed by the preferred alternative or one of the other active remedial measures considered may present a current or potential threat to the public health, welfare, and the environment through the continued presence of contaminants in the soil.

Uncertainties The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to a wide variety of uncertainties. In general, the main sources of uncertainty include:

to o IO environmental chemistry sampling and analysis environmental parameter measurement fate and transport modeling exposure parameter estimation - toxicological data Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual levels present. Environmental chemistry analysis error can stem from several sources including the errors inherent in the analytical methods and characteristics of the matrix being sampled. Uncertainties in the exposure assessment are related to estimates of how often an individual would actually come in contact with the chemicals of concern , the period of time over which such exposure would occur, and in the models used to estimate the concentrations of the chemicals of concern at the point of exposure. Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals. These uncertainties are addressed by making conservative assumptions concerning risk and exposure parameters throughout the assessment. As a result, the RA provides upper bound estimates of the risks to populations near the site for the COCs quantitatively assessed.

Environmental /Ecological Assessment An environmental assessment of the site was based on limited information available or gathered on site-specific aquatic life, terrestrial animals, and plant species. Since no permanent water bodies are located on the site, adverse effects of site contaminants on aquatic life, if any, are considered minimal. Metal contaminants in surface soil do pose an .undetermined risk to burrowing animals such as squirrels and rabbits. No signs of dead animals or stressed vegetation were apparent at the site. However, the possibility of metal uptake by plants on the contaminated areas or on their periphery cannot be ruled out. These effects, however, are likely to be restricted to a limited area on the site.

SCREENING OF REMEDIAL TECHNOLOGIES AND ALTERNATIVES The feasibility study process involves, as a first step, selecting technologies that are appropriate for addressing the public health and environmental concerns associated with a particular site. In the case of the Nascolite site, the remedial objectives focus on controlling migration of lead contaminated soil, reducing exposure ^ >-3

15 o

O vo (Jt to surficial soils contaminated with lead, and protecting the sensitive environment of the wetlands. The remedial measures evaluated were designed to alleviate the potential public health risks and environmental impacts associated with buildings and debris and contaminated soils present at the Nascolite site. The alternatives that are presented in this document are those that passed the initial screening as presented in the Evaluation of Alternatives section of the Feasibility Study report. Further evaluation of these alternatives is presented in the next section. The remedial action objectives focus on reducing exposure to the inorganic contamination in soils and the wetlands to an acceptable level. Stated time frames for achieving remedial action objectives refer to actual implementation times once all equipment is mobilized and operational. In addition, this ROD, by necessity, addresses the need to reduce the physical hazards posed by the dilapidated buildings and structures on-site. Data from the FOU RI has been considered in the development of alternatives for this operable unit. In particular, the finding during the FOU RI that inorganic contamination was not detected in the groundwater. The dilapidated condition of on-site buildings and structures are a major concern, since portions of most of the structures have either collapsed or could potentially collapse. Friable asbestos has been detected in these on-site buildings. Consequently, these conditions potentially endanger personnel involved in on-site activities. Asbestos abatement and demolition of the buildings and structures, therefore, is warranted from a worker safety perspective. In addition, the presence of buildings, structures and debris at the site may physically hinder the implementation of any soil or groundwater remediation effort. Buildings and structures currently occupy approximately one fourth of the manufacturing area. More than half of the manufacturing area is either occupied by buildings or contaminated soil which require remediation. Debris, such as broken glass plates used in the manufacturing process, covers nearly the entire exposed surface of the manufacturing area. An estimated 4,800 tons of rubble would be generated as a result of the demolition operations. Building rubble and debris will be sampled and segregated according to disposal requirements (i.e., testing for asbestos containing material, RCRA waste and solid waste) on-site prior to disposal. If necessary, some debris may be decontaminated on-site prior to disposal. In addition, some debris (e.g., large metal I-beams) may be recycled. If found to be cost- effective, some of the debris could be pulverized and treated consistent with the alternative selected for contaminated soils. All demolition activities will be conducted in compliance with relevant asbestos regulations and will employ appropriate air emissions control. The cost and duration of the remedial action

16 to o vo will vary depending on sampling results and requisite disposal requirements. The supplemental FS evaluated potential remedial alternatives to address soj.1 contamination in the unsaturated soil and wetlands. The various treatment technologies considered included Solidification/Stabilization of contaminated soils, soil washing and the No Action alternative. During the FS, a treatability study was performed to test the applicability of the soil washing technology. A literature search was conducted for Solidification/Stabilization treatment. The Solidification/Stabilization technology immobilizes contaminants, changing the constituents into immobile, insoluble or non-hazardous forms by binding them into an immobile, insoluble matrix. Solidification/ Stabilization technology options can be implemented on-site, either ex-situ (i.e., excavated and treated) or in-situ (i.e., treated in-place) or at an off-site facility. Solidification/Stabilization is a proven technology for the treatment of inorganic contaminants in soil. Review of case studies utilizing Solidification/Stabilization treatment indicated that inorganic contaminants present in site soil can be successfully solidified. Soil washing involves the use of a solvent to solubilize organic and inorganic contaminants attached to soil particles. It is performed by batch treatment, and mixing is used to contact the soil with the solvent. Soil washing is an effective means of extracting metals from soil. Results from soil washing studies conducted during the FS indicated that inorganic contaminants of concern can be effectively washed under proper operating conditions. Biotreatment of process residuals was found effective in further reducing the concentration of contaminants. Asbestos abatement was evaluated for the demolition of on-site structures and debris. Potential remedial measures include removal of the asbestos prior to demolition and enclosure during removal or demolition.

SUMMARY OF REMEDIAL ALTERNATIVES CERCLA, as amended, requires each selected site remedy to be protective of human health and the environment, cost effective, and in accordance with statutory requirements. Permanent solutions to hazardous waste contamination problems are to be achieved wherever possible, while treating wastes on-site and applying alternative or innovative technologies are preferred. The remedial alternatives evaluated during the feasibility study are briefly described belowr

17

to o ID Alternative 1: Mo Action Capital Cost $ 0* Annual Operation & Maintenance (O & M) Cost $ 0* Present Worth Cost $ 0* Months to Achieve Remedial Action Objectives NA The National Contingency Plan requires that the "No Action" Alternative be evaluated. As part of a No Action Alternative, the following activities implemented for the groundwater operable unit would be continued: - groundwater monitoring; - monitoring of surface water runoff at the 'ditch leaving the site; - limitations on the use of groundwater in the site vicinity; and a deed restriction on future use of the property. Monitoring costs associated with these actions are included in the costs of the FOU selected remedy. The No Action Alternative has been developed to provide a baseline analysis of threats which would be posed by site contamination if no remedial action is taken. The FOU groundwater and surface runoff monitoring program would be continued and the deed restriction would limit future use of the property. This alternative does not address the overall protection of public health and the environment. The toxic ity, mobility and volume of the contamination would not be reduced. The contamination source would remain and continue to pose unacceptable risks. Alternative 2: Soil Washing Capital Cost $ 2,627,000 Annual O & M Cost $ 0 Present Worth Cost $ 2,627,000 Months to Achieve Remedial Action Objectives 11 Under this alternative, soil washing would be used to remove inorganics from the unsaturated soil. Using a cleanup action level of 500 ppm for lead, the estimated total volume of unsaturated soil

18

NJ O requiring treatment is approximately 8,000 cubic yards (CY). This alternative also includes remedial measures for cleanup and restoration of the wetlands. Approximately 2,000 CY of soil from the wetlands in addition to 6,000 CY of non-wetland soil is contaminated with lead above the 500 ppm level and requires treatment. Contaminated soil above the action level of 500 ppm for lead would be excavated and separated to remove materials which are not amenable to treatment by soil washing, such as any buried refuse or debris, plant matter or humic material. The side stream of separated materials would be classified for disposal at an off-site RCRA Subtitle C (i.e., hazardous solid waste) landfill facility or placed back in the excavated area if sampling results disclose uncontaminated material. Approximately 10 percent of the total volume of the unsaturated soil may be separated out in the staging area. / A typical process train for a soil washing treatment system would include particle size separation, rapid mixing of soil and solvent in an extractor, solvent recovery, particle settling and waste stream treatment. Solvent recovery for recycle and reuse generates a sludge which would be treated and disposed of at an off-site RCRA facility. During the particle settling stage, soils would be separated from liquids. The liquid waste stream containing metals and residual solvent would require treatment. Treatment would include precipitation and some form of filtration. Additional pilot-scale studies may be required in conjunction with treatability studies performed on the FOU to address treatment of residual solvents from the soil washing process. The treated soil from the particle settling stage which was determined to be below health-based levels would be backfilled on- site. Treated wetlands soil will be placed on-site in non-wetland areas. The excavated wetland area would be backfilled with virgin, naturally occurring type soil to ensure restoration of the wetlands. A wetland delineation and functional values assessment will be completed prior to implementing the proposed remediation. The wetland restoration plan will ensure that appropriate wetland functions and values are reestablished following remediation. Soil washing treatability studies were conducted on site soils to determine if lead could be flushed out using a suitable extractant and to establish removal efficiencies. Other objectives included determination of the appropriate extractant, the optimum concentrations, characterization of residuals from soil flushing, and evaluation of biotreatment as a suitable residual treatment methodology for residual liquid effluent. The bench-scale 2| treatability study indicated that soil washing using water and 1-3 o o 19 ^-1

NJ O surfactant solution is a viable process to remove lead and cadmium from site soils. The treatability study results indicated that lead and cadmium can be effectively flushed from the soil using a 12% EDTA solution. Water could only remove a maximum of 40 to 50% of the extractable lead and cadmium in 37 extractions. Three additional extractions with 12% EDTA solution removed equivalent quantities of lead and cadmium that had been removed in 37 extractions of water and surfactant solution. After 37 extractions of either water or surfactant, followed by three rinses with 12% EDTA solution, a 76% (using water) and a 84% (using surfactant) reduction in soil lead concentration was obtained. For on-site washing of soils, the surfactant solution is recommended. Both lead and cadmium can be removed 40-50% with surfactant, and the rest can be washed with EDTA. It is expected that this technology would be able to achieve the cleanup level for lead of 500 ppm for most contaminated areas on-site. •' Alternative 3: Solidification/Stabilization Treatment Capital Cost $ 1,790,000 Annual O & M Cost $ 31,00.0 Present Worth Cost $ 2,273,000 Months to Achieve ^smedial Action Objectives 8 In the aspects of site preparation and structure demolition, this alternative is similar to Alternative 2, however, Solidifica- tion/Stabilization of soil would be performed in place of soil washing. This technology immobilizes contaminants by binding them into an insoluble matrix. Operation and maintenance costs for this alternative would include long-term groundwater sampling and analysis at a rate of once per year, and a public health assessment to be conducted once every five years on the treated material. All unsaturated soils contaminated with lead above the action level (500 ppm) would be excavated, and subsequently undergo Solidification/Stabilization on-site. The solidified material would be tested to assure that RCRA regulatory levels are met. TCLP testing on the solidified/stabilized material would be performed to determine the RCRA characteristic status of the material. Except for the wetlands portion of the site, all treated soil that is no longer RCRA characteristic waste will be backfilled to the area from which it was excavated. Any material from which contaminants would leach above acceptable RCRA regulatory levels, as determined by TCLP testing, will be disposed of off-site in a RCRA Subtitle C landfill. It is expected that the majority of site ^ soils will meet RCRA regulatory levels after treatment. ^

o . ' o l-l 20 to M O O The exception to this procedure are the wetland areas which would be backfilled with fresh organic soil. Contaminated wetland soils would undergo on-site Stabilization/Solidification and be replaced after treatment in former non-wetlands areas of contamination. The volume of wetlands soils not amenable to Solidification/Stabiliza- tion will be determined during field activities and will be transported for appropriate off -site treatment and disposal. In addition, localized areas of soil contaminated with organic compounds may be excavated and disposed of off-site at an appropriate facility if determined to interfere with or be unaffected by the solidification/stabilization process. A soil volume increase of 10 to 30 percent would be expected due to the addition and hydration of pozzolanic materials. The site has the capacity of accepting the additional material and would be appropriately backfilled and graded to account for the volume increase. The cost estimation includes provision for a flexible membrane as well as vegetation atop a one foot layer, of soil. For cost estimation purposes, it was estimated that 10 percent of soils would not be amenable to Solidification/ Stabilization treatment, and would have to be disposed of off -site. Proper disposal would take place in accordance with appropriate State and Federal regulations. No treatability studies were performed for the Solidification/ Stabilization Alternative. In lieu of a treatability study, a literature review of Superfund Innovative Technology Evaluation (SITE) programs was conducted regarding Solidification/ Stabilization. Results of four case studies presented in the report showed the following: 1. Cement-based or Pozzolan-based Solidification/Stabilization can successfully immobilize inorganics and semi-volatile organics. 2. A lime/flyash additive with a binder-to-soil ratio of 1:3 was recommended as the starting ratio. 3. Volume changes of 32 to 120 percent have been reported in the literature. Significant volume change may occur depending on the binding agent. 4. Cement-based and Pozzolan-based processes generate heat while mixing, and would tend to drive off volatile organics. 5. Costs from the literature ranged from $100 to $194 per ton. Cost for Solidification/Stabilization treatment of soil at the Nascolite site is expected to be lower, because a large proportion of the inorganic contaminated soil is between the ground surface and a depth of three

to l-> o feet. Deeper inorganic contamination is only found at in area northwest of the loading dock. Additional studies on the Solidification/Stabilization technology would be performed in the initial phase of the design of the treatment system in order to accurately define the necessary design parameters.

EVALUATION OP ALTERNATIVES This section describes the requirements of CERCLA in the remedy selection process. Remedial treatment alternatives are evaluated against the following nine criteria: o Overall Protection of Human Health and the Environment; This criterion addresses whether or not a remedy provides adequate protection and describes how risks posed through, each pathway are eliminated, reduced or controlled through treatment, engineering controls or institutional controls. o Compliance with ARARs; This criterion addresses whether or not a remedy will meet all of the applicable or relevant and appropriate requirements of Federal and State environmental statutes (other than CERCLA) and/or provide grounds for invoking a waiver. There are several types of ARARs: action- specific, chemical-specific, and location-specific. Action- specific ARARs are technology or activity-specific requirements or limitations related to various activities. Chemical-specific ARARs are usually numerical values which establish the amount or concentration of a chemical that may be found in, or discharged to, the ambient environment. Location-specific requirements are restrictions placed on the concentrations of hazardous substances or the conduct of activities solely because they occur in a special location. o Long-term Effectiveness; This criterion refers to the magnitude of residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once cleanup goals have been met. o Reduction of Toxicitv. Mobility or Volume; This criterion addresses the degree to which a remedy utilizes treatment to reduce the toxicity, mobility, or volume of contaminants at the site. o Short-term Effectiveness; This criterion refers to the time in which the remedy achieves protection, as well as the remedy's potential to create adverse impacts on human health and the environment that may result during the construction and implementation period. f •-3 22 o o I-*

O to o Implementability; Implementability is the technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement the selected alternative. o Cost: Cost includes capital and operation and maintenance (O & M) costs. o State Acceptance; This criterion indicates whether, based on its review of the RI/FS, the Proposed Plan and the ROD, the State concurs with, opposes, or has no comment on the preferred alternative. This criterion is satisfied since the State concurs with the preferred alternative. o Community Acceptance; This criterion will be assessed following a review of the public comments received on the RI/FS reports and the Proposed Plan. / Overall Protection of Human Health and the Environment The No Action Alternative for the Nascolite site consists of continued monitoring of the groundwater as part of the FOU remedy and limited ground water use in the vicinity of the site. This alternative would not provide remedial measures to protect human health or the environment with respect to soil contamination and it would not meet remedial action objectives. The source of soil contamination would remain and could be contacted by humans. Soil washing (Alternative 2) and Solidification/Stabiliza-tion (Alternative 3) would both meet the remedial action objective of reducing exposure to' surficial soils contaminated with lead to acceptable levels. Soil washing will remove inorganic contamination from soils to acceptable levels, while Solidification/Stabilization will immobilize the contaminants by binding them in an insoluble matrix which would then be covered by top soil. Accordingly, both alternatives would be protective of human health and the environment by reducing the risk of exposure through direct contact. Compliance with ARARs Both on-site soil washing (Alternative 2) and Solidification/ Stabilization (Alternative 3) would be conducted in compliance with State and Federal ARARs. Lead contaminated soils would be remediated to the cleanup action level of 500 ppm. Since TCLP sampling results have shown the soils to be a RCRA characteristic waste, RCRA is identified as an ARAR. Alternative 3, Solidification/Stabilization would comply with RCRA requirements by rendering the soil non-characteristic waste through treatment. For Alternative 3, lead would be immobilized in an 3 insoluble matrix. TCLP testing would be performed on samples of £3

23 i—§i

to I—I o OJ the solidified material to assure that the treated soils meet RCRA regulatory levels. It is expected that Solidification/Stabiliza- tion will treat the soil to such a degree that it is no longer RCRA characteristic waste. The material would then be backfilled and graded on-site. Any material which does not meet RCRA regulatory levels after treatment would be disposed of at an appropriate off- site facility. Alternative 2, soil washing would also comply with RCRA requirements by rendering the soil non-characteristic waste through treatment. After treatment, TCLP testing would be performed on the treated material, as described above for Alternative 3, to determine that RCRA regulatory levels were met, and the soil was not characterized .as hazardous waste. Any material which does not meet RCRA standards after treatment would be disposed of at an appropriate off-site facility. In addition, solvents generated during soil washing would be subject to RCRA handling, storage and disposal requirements. RCRA Part 264 standards will be applicable to the on-site storage of the excavated soil and waste material if storage exceeds 90 days. Alternatively, Part 265, Subpart I and Subpart J, container and tank standards will be applicable if storage of waste on-site is less than 90 days. The date marking the initiation of waste accumulation will be clearly indicated on each tank/ container. 40 CFR Part 264, Subpart L standards will be applicable to the placement of demolition material in waste piles to segregate contaminated from clean materials prior to disposal. Off -site treatment/disposal would be performed according to RCRA Part 262 standards specifying manifesting procedures, transport and record keeping requirements. The shipment of hazardous wastes off -site to a treatment facility will be consistent with OSWER Off-Site Policy Directive Number 9834.11 which became effective November 13, 1987. This Directive is intended to ensure that facilities authorized to accept CERCLA generated wastes will be in compliance with RCRA operating standards. 40 CFR 264, Subpart X standards are applicable to the on-site Solidification/ Stabilization process used for the contaminated debris and soil. The site is some distance from habitats that are known to be used by the National Oceanic and Atmospheric Association (NOAA) resources and the data indicate that the levels of persistent contaminants are marginally elevated and may be diluted substantially during transport from the site. Both Alternatives 2 and 3 will involve partial destruction of the wetlands through excavation of inorganic contaminated soils. A wetlands restoration plan would therefore be developed under both alternatives to ensure that wetland functions and values are reestablished following remediation. The plan would also include maintenance and monitoring, to assure the long-term success of the restored wetland. •

24 §

to t-t o Provisions of the plan to restore wetlands would include compliance with ARARs pertaining to the protection of wetlands and f loodplains including: The Fish and Wildlife Coordination Act of 1958 (FWCA) (16 USC 661) and the Endangered Species Act of 1973 requiring federal agencies to give wildlife conservation equal consideration with other features during planning and decision-making processes that may impact water bodies (including wetlands); Section 404 of the Clean Hater Act (1972), as amended (33 USC 466) and the State of New Jersey Fresh Water Wetlands Protection Act of 1987; and Executive Order No. 11990 directing federal agencies to take actions to minimize the destruction, loss, or degradation of wetlands and to preserve and enhance the natural and beneficial values of wetlands in carrying out the agencies' responsibilities. Additionally, this Executive Order requires the agencies to consider factors relevant to a proposal's effect on the survival and quality of the wetlands.

Long-term Effectiveness ' The No Action Alternative would not provide an effective remedy for the long-term. Both Alternatives 2 and 3 will achieve long-term reliable protection of human health and the environment. Soil washing is advantageous in that contamination above the action level would be removed from the site. Generally, Solidification/Stabilization raises some long-term uncertainties regarding the integrity of the stabilized mass, particularly with regard to leaching of contaminants into the ground water. However, the solidified mass will undergo TCLP testing to assure that unacceptable levels of lead would not leach from the treated soils. Since both alternatives treat soil which is contaminated above health-based levels, the residual risk associated with the site after implementation would be acceptable. Institutional controls will be required in conjunction with Alternative 3 to avoid activities that may result in disruption of the solidified mass.

The No Action Alternative would not contain, treat or destroy the contaminated materials associated with the site. The greatest reduction of volume of contaminated soils would be achieved by soil washing through the physical removal of contaminants above the action. Solidification/Stabilization will result in a net increase in the volume (approximately a 30% increase) of treated material. Both Solidification/Stabilization and soil washing significantly reduce the mobility of contaminants in soils. Solidifica- tion/Stabilization does not remove contaminants from the soil but relies on immobilization of the waste in an insoluble matrix, making contaminants inaccessible to the environment. Soil washing reduces the mobility of contaminants by removing them from the site. However, this alternative requires further treatment of the a: removed contaminants and other process waste generated in the soil ^ 25 o o

O Ul washing process. Because soil washing removes contaminants from the site, a significant reduction in toxicity is achieved. Solidification/Stabilization does not remove contaminants from the site, but renders them immobile and, therefore, toxicity from exposure would be considerably reduced. Short-term Effectiveness In terms of short-term effectiveness, the No Action Alternative would have no additional environmental impacts beyond the present situation, however, this alternative would leave the current risks unaddressed. For Alternatives 2 and 3, in terms of short-term effectiveness, human health risks due to direct contact and/or inhalation resulting from on-site work would be controlled through air monitoring, dust control measures and appropriate personal protective equipment. Both alternatives can be implemented in a manner whereby similar adequate protection to human health and the environment would be provided upon implementation of the remedy. Solidification/Stabilization would achieve protect.iveness in a shorter period of time than soil washing (8 months vs. 11 months), since it employs a less complex treatment process and does not involve the handling of hazardous chemicals. Soil washing would involve a more complex treatment process utilizing solvents to extract lead from the soil matrix. The solvents used to extract the lead would then be washed from the treated soil. This process generates a contaminated liquid effluent, increasing the potential for spillage and release into the environment and the need for proper decontamination and treatment. Wastewater treatment from the soil washing process would be achieved on-site through the proposed FOU groundwater treatment system. Consequently, implementation of the soil washing alternative would need to await the construction of the groundwater treatment system. Furthermore, soil washing may require pilot studies to address any uncertainties regarding the ability of the groundwater treatment system to treat soil washing wastewater to meet groundwater reinjection standards. Solidification/Stabiliza- tion could be implemented independent of and would be coordinated as necessary with the FOU remedy. Implementability The No Action Alternative does not pose any implementation problems, since no activities would be conducted. Both soil washing and Solidification/Stabilization are proven technologies and could be implemented at the site. Solidification/ Stabilization would be relatively simple to implement since it employs a one-step mixing and placement process. As discussed above, soil washing involves a more complex treatment and verification monitoring process. Actual field conditions could warrant the washing of soils multiple times to meet the required ^ soil cleanup levels. In addition, on-site treatment of the ^

26 t-oj

IVJ generated wastewater would be delayed until the implementation of the FOU remedy. Processing equipment for soil washing must be custom designed according to unique site specifications, whereas Solidification/ Stabilization units and equipment are readily available for immediate usage. Therefore, the Stabiliza- tion/Solidification alternative is more easily implemented than soil washing. Sampling of treated waste is necessary for both alternatives, however, the sampling requirements for soil washing are more extensive due to the use of solvents in the treatment process. Considerable sampling of treated soil would be required to ensure that it is free from residual solvent contamination prior to its placement back on-site. Cost As presented in the cost comparison table, Table 19, Alternatives 1, 2 and 3 have an estimated present worth cost of $0, $2,627,000 and $2,273,000, respectively. Soil washing involves a greater degree of uncertainty compared to Solidification/Stabilization in meeting soil cleanup levels. If additional treatment is required in the field, the costs will escalate. Given the site conditions, Solidification/ Stabilization offers greater certainty for the treatment of contaminated soils present at the site. Accordingly, efficacy standards should be readily achievable after Solidification/Stabilization has further immobilized the waste. State and Community Acceptance A review of the State and public comments received on the RI/FS reports and the Proposed Plan indicates that both the State and the community concur with the selected remedy. Details of these comments are presented in the Responsiveness Summary Attachment to this document.

SELECTED REMEDY Based on the results of the RI/FS, and after careful consideration of all reasonable alternatives, EPA and NJDEP presented Alternative 3, Solidification/Stabilization as the preferred treatment technology for addressing the Nascolite site soils at the public meeting held on March 14, 1991. After considering public comments, the selected alternative is the implementation of Alternative 3, in conjunction with structure and building decontamination and demolition activities. Site risks have been identified as being primarily due to direct contact with and ingestion of contaminated soils. The Solidification/Stabilization technology will be effective in reducing the direct contact risk to an acceptable level. EPA believes that the selected remedy reduces the threat to public health and the environment by binding hazardous substances in site

27 10 \-« o soils within an insoluble matrix, thereby eliminating the exposure pathway involving direct contact to the contaminated material. The selected alternative will meet the statutory requirements in CERCLA Section 121 (b): 1) to protect human health and the environment; 2) to comply with ARARs; and 3) to be cost-effective. Tha selected alternative utilizes permanent solutions and alternative technologies to the maximum extent practicable and satisfies the statutory preference for treatment as a principal element. The selected alternative uses Stabilization/Solidification as the primary treatment technology. Samples of the stabilized/ solidified mass will be analyzed using TCLP testing to ensure that soils have been treated appropriately and are not characterized as RCRA hazardous waste. This test will establish that RCRA regulatory levels are met. Since all soils above the action level for lead of 500 ppm will be treated, the residual risk associated with the site will be reduced to an acceptable level. However, institutional controls are needed to ensure that the solidified mass is not disturbed. In order to provide an overall picture for site-wide remediation, activities associated with building demolition have been integrated into the preferred alternative. The general sequence of activities in this alternative are presented below. Some of these activities may be performed concurrently. 1. Demolition of structures in accordance with asbestos regulations. 2. Consolidation of debris from structures. 3. Sampling, separation and stockpiling of debris for decontamination, on-site Solidification/Stabilization treatment, recycle and/or appropriate off -site disposal. 4 . Excavation of contaminated soil in the wetlands and unsaturated zone (three feet below ground surface in most areas, and up to 15 feet near the loading dock area, for a total of 8,000 CY) and stockpiling of these soils for on-site Solidification/Stabilization. Areas of high lead contamination, highly humic wetland soils, and organic contamination will be tested to determine if Solidifica- tion/Stabilization will appropriately treat these areas. If soils in these areas cannot be appropriately treated, these soils may be disposed of off-site at an appropriate disposal facility. 5. On-site Solidification/Stabilization- of unsaturated soil, wetlands soil. Although this would result in a volume increase of approximately 30% in the treated material, sufficient area is available for replacement of the solidified

278

o o

O 00 mass qn-site in the former areas of contamination. The site would be appropriately graded and covered with a soil cover. Solidified wetlands soils will be placed in former non-wetland areas of contamination. 6. Restoration of wetlands would include backfill of virgin, organic soil into the excavated area. The total present worth cost of this alternative is estimated to be $4,165,000 which includes asbestos abatement, demolition, debris handling, segregation and sampling, excavation of unsaturated and wetland soils, on-site Solidification/Stabilization, backfill of excavated areas and off-site disposal in an appropriate facility. The capital cost is estimated to be $3,682,000. Annual Operation and Maintenance costs are estimated to be $31,000. The actual cost may vary due to a number of factors including the uncertainty in the amount of material that is amenable to the Solidification/Stabilization technology, therefore requiring off- site transportation and disposal.

STATUTORY DETERMINATIONS Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial actions that achieve adequate protection of human health and the environment. In addition, Section 121 of the Comprehensive Environmental Response, Compensation and Liability Act establishes several other statutory requirements and preferences. These specify that, when complete, the selected remedial action for a site must comply with applicable or relevant and appropriate environmental standards established and Federal and State environmental laws unless a statutory waiver is justified. The selected remedy must also be cost effective and utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. Finally, the statute includes .a preference for remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous substances as their principal element. The following sections discuss how the selected remedy meets these statutory requirements.

Protection of Human Health and the Environment The selected remedy, which includes structure demolition, excavation and on-site Stabilization/Solidification, provides for protection of human health and the environment by removing the immediate and future risks posed by the presence of asbestos- containing structures and lead contaminated soil on-site. Contaminated soils will be excavated and treated on-site. The [i? solidified matrix will then be replaced back on-site in non-wetland ^

29 § M

NJ h-" O areas and the wetland areas will be backfilled with fresh organic soil. The selected remedy will significan-tly reduce the mobility of contaminants in the soils and will directly result in the reduction of risks posed by the presence of contaminants at the site. Demolition of the dilapidated structures and buildings will further reduce the potential health and safety hazards associated with the implementation of this remedy. There will be no unacceptable short-term risks caused by implementation of this remedy. Compliance with Applicable or Relevant and Appropriate Requirements Alternative 3, excavation with on-site Solidification/ Stabilization, will comply with all Federal and State requirements which are applicable or relevant and appropriate to its implementation.

Cost Effectiveness / The selected remedy is cost effective and it has been determined to provide greater overall effectiveness in reducing the risk to human health and the environment in both the long term and short term compared to the other alternatives evaluated. This alternative is also effective in reducing the mobility of contaminants.

Utilization of Permanent Solutions and Alternative Treatment for resource recovery) Technologies to the Maximum Extent Practicable The selected remedy, Alternative 3, provides the best balance among the alternatives with respect to the evaluation criteria. In particular, the selected alternative is able to maintain reliable protection of human health and the environment over the long-term, once cleanup levels have been met. This technology will reduce the mobility of the contaminants through the soil and underlying ground water without any adverse impacts on human health and the environment during the construction and implementation period. Services and material needed for the implementation of the selected alternative are readily available and no technical or administrative difficulties are foreseen with the implementation of the remedy. The State and community concur with the selected alternative, and it meets the statutory requirements to utilize permanent solutions and treatment technologies to the maximum extent practicable. The selected remedy meets the statutory requirements to utilize permanent solutions and treatment technologies to the maximum extent practicable.

30 o o

to M l-« O Documentation of Significant Changes Subsequent to the issuance of the Proposed Plan for the site, EPA performed TCLP testing on site soils, as described in the Proposed Plan. The purpose of the TCLP testing was to confirm EP Toxicity testing results previously performed at the site. The EP Toxicity results indicated that very low levels of lead were leaching from site soils, and therefore site soils were not classified as RCRA characteristic waste and not subject to the requirements of RCRA. Results of TCLP testing, as described previously in this document, were contrary to the EP Toxicity testing results and indicate that significant levels of lead are leaching from soils, and therefore, soils are RCRA characteristic waste subject to the applicable provisions of RCRA. Therefore, after treatment, site soils must meet RCRA regulatory levels established for TCLP testing. While this information was not known by EPA at the time of the Proposed Plan, it does not significantly change EPA's selected remedy because the March 1991 Proposed Plan anticipated the need for off-site disposal. The selected remedy, Solidification/ Stabilization, is expected to meet applicable RCRA standards for the majority of site soils. Any areas of soil contamination for which these standards cannot be met, will be disposed of off-site at an appropriate facility.

31 o o

NJ

FROM WILLVILLE, NJ 7 1/2* BOOO FT USQS TOPOGRAPHIC MAP SCALE

FIGURE 1 SITE LOCATION MAP NLT 001 2113

FIGURE 2 LOCATION OF NASCOLITI SITE NA6COLITE CORP., MILLVILLE, NJ CUMBERLAND RECYCLING CORP

LABORATORY BUILDING

^ MAIN PROCESSING PLANT SB-5S \\

— ~~ ""

> 90Om«/M LEAD FROM 0 TO 3 FEET BELOW OMOUNO SURFACE. > 90Om«/K« LCAO FKOM 3 TO 19 FECT •CLOW aROUNO SURFACE.

——— — — >IOOOin»/k« LEAD FROM 0*3 FEET •CLOW 9ROUNO SURFACE. 0-10 FEET, TOTAL SEMIVOLATIES

O-IOFEET, TOTAL VOLATIES>l»«fl/li«. 1 0-10 FtET, TOTAL VOLATIE3>lm«/l«; o-___ipo TOTAL SEMIVOLATIES >IO •«/»«. SCALE IN FEET SCALE . REM III AS SHOWN NASCOLITE CORPORATION SITE DATE MILLVILLE, NJ JAN. 1991 COm"AM!NATION IN SURFACE SOILS C.C.JOHNSON & MALHOTRA.P.C. NLT 001 2115

T.ilill- 1

Unit, il in .iti'J Suitari! So i 1 Uoi inij ll.il.i MMft .mil Vol.il ill.' Hi ij.inn ii

N.tncol i ttf Cor|H>t al lull Silti;

I.All NUHIUill: -I'M 7II I, I KAMI'LK LOCATION: MI-U1II 111 :.ii-lilll Olli Ml ll.'ll D1U :.ll-() III III SII-OliM-01 SII-02U-UI DATi: SAMI'LKUi lU/12/U'J lll/12/U'J UI/12/ll'J 1U/12/UV IO/12/B'J 10/12/BV DtHTII (ft)t 0-2 0-2 0-2 0-2 0-2 0-2

Huthyl HuLliacrylalu (ug/ky)

LAII NIIMIIKK: HI II-311 s. liril I'l in.-11-4 I IH'll-'l1. lii'H-41 IH'II-<|; Bi.M-ni SAMPLE LOCATION: Sb-Ulll-Ul .'.U-OIII-OIU UII-UJII-Ol LU-U^II-OIU bll-OJII-Ol SU-Obll-01 SU-02U-01

VOLATILE OHUANCICS (ug/kg)

Motliylone

Acetund

Carbua DlBulfLUe

1, 1-Dlclilorouthane

1, 2-Dicliloroethune

Chloi'of orm /

2-Butanonu

1,1,1-TrLchloroethanu 1J U 2J Carbon Tatrachloride 2J

Trlchloroatllena

Benzene 2J 1J J.I 1J 2J TutrachloroeLhena

Toluvna EthyIbuntene

Styrenu Xylenes (Total)

TOTAL VOLATILE OHUANIC NLT 001 2116

I (mill'd)

nltd :>urUi.e Juil Uorlntj • MMA Ji«l Volatile.' Ui./jiil<-

Corpontiun Site

(All NUMIIIII: 4'M/H 41 4'M/II 1.) 4'M/II Ul 4'M/II 1)1 4'I4/II u; 4'M/II ID 4'1/IUI M S/UII'U IOCAIION: Sll IIJII Ul Ml U'jS Ul Ml OdS III Ml U/', III Ml Ull'j Ul !,ll ll'lb III SII-IUS 01 IJAIl SAMIMIU: IU/UVtH 'I/W/U'J ll'(/?''/U9 ll'J/^//U'J U'V2//U'J U'J//U/U'J lU/Ob/U'J UIPIII (11): 02 02 U •! U I U-2 0 2 0 2

Mulh/l Hetlucr/UU luy/ky) 12 IJ

(All tlUMHIR II/-UU llll.l It, n/ i;'i 1111.1 LI, inij i,<> iiiu ; i HIII I) iAHPU IUIAIIUN: SU UJl^OI SU U'jVOl ill Obi-01 Ml O/i Ul !>U UUU 01 Ml U'Jj-OI iU-lUb 01

VUlAIILt UHCANICS (uy/ky)

Hulli/lvne Chloride /,)

Aivtunc 2faJ

Urbuii Uilulfldn

1,1 Uitliluroethine

1.2-Uichluroclhene (lolil)

Llilurufuini

2-Uuliiione

1,1,1-lrltliluroclhine 20 tJrbon Utrjchlui ide

Ifichluroulhvne 14

Otnlvnt 11

letrichloroelhcne 12

toluene JS

llhyl benzene 14 4J

Sl/rene IS t

Xylcnei (lolal) IUU

IUIAI VUIAI1U OHUAIIIC COIICIHIKAI lull

Ul NLT 001 2117

Idhle I (tiint'ii) llir,jlui jlucl Surfatu boil llurliuj ll.ila HA jcul VuUtilf lli<|.iin>

ILmulltl! I.UI|H)l'illlUII bill'

IAII NUHIIIII: 4'H/II 41 VM/II JH b/MII'Lt UllAIIOM: Ml lib 01 Ml I IS III I1AII SAMI'UU: III/UO/U'J lU/Ui./U'J IHPIII (II): U /' U I

Hulhyl HothJcrylalu (ug/lwj)

IAII NUMIIIK: Mill II Hill :'/ SAMI'll lUCAIIDH: MlllbUl MI I IS 01

VUIAIIIE URCANICS (uij/kij) S

Mi'lhylune Chlorido Aci'lone Idibun UisulliJf

1.1-Dkliloruulhdiie

1.2-Dichlorucllieiie (luUl)

Chlurufurni

2 HuUnuiie I, I, I - h lUilurueUuiiu C

IHIAL VUIAIILL OHGANIC CUNCtHIHAIIUHS

U 001 2118

Ijlik J

UnsjturjU'il ^ui'ljte JIM I Urn in<) llJU Vwi Volalili' I|M|.IIIM-,

NjuuliU* loipurilioii Situ

I/Ml HUMUIH: HIM til III II J'J III II -M In II V, In II 41 III I'M/ llll.l III B/IJO SAHPU I OLA 11 UN: Ml UIM HI SM Ulll Dill Ml O.'ll IJI Ml ll.'ll III MID/II 1)111 ill 0111 01 SIIOljII III SII-01II 01 IWH SAMI'll: IU/IZ/09 lU/l^/U'J Kl/l.'/U'J lU/U/U'J lU/U/lf) IU/I//IW M/ll/0') 10/0»/B4 UtlPM(lt): 0 ^ U/ U<> U <• 0 / 02 02 0-2 itHI VOIAIIU OHl,«NRS (u.j/k,j)

Phenol

4 H«th

I S0|iliuione

Uenioic ic id • - . . .

Niphlhaluiic - -

2 MetliylnJphtluU'nc - - ...-.-

Uibenzofunn - UU.I I UielhylphlhiUte ......

fluorenc - . . -

N-Hitroiudi|iln!nyUniinc - ....

I'lieninlhrenc ... • -

Anthracene .....-•-

Ui-n-butylphtilile - >J4J - 22UU 7bJ llurjnlhene - - - . - ;jj

Pyrene - - - - ;/J

Bulylbtn/lphlhililt ......

HGnxo(a)Anlhracenc ... . .

Lhrysen* - .

bis (2 Uhyhe«yl)phthiUte ... . . 63000UBJ

Oi-n octylphliUie - . .

UvH2o(l>)f luurintlitne • . .

Uirn/o(i)Pyrvm*

IUIAL SIMI VOIAIIU OHUAIMC CUNCtNIMAl I UN

0 % U II 2JJII 2/0 0 610000 I Jill.' 1 (lUlllM) 001 2119

Uiisjlui Jlr.l bull 11,11 |u.| lutj Srini VuUlllu^ Hi i|,inu.i lljitullli* Corporation %ile

I All miMllllt. Illl.I /i, II,' I.", Illl.I 1,1, Illl I '-I Hill .'I UN 14 Hill 14 Hill .'M SAHl'U nii.AllUN: SH u'i', ill MI in,', ni MI or. ill MI »ir. in MI in, nl Mil'r. ni MI US ni Ml I)'. ill IIAIl S AMI'11 (}: O'J/i'U/BV H'J/i'O/U'J ti'l/ll/tt'i d'l/fl/U'l H'l/.'tt/m III/US/U'J HI/Oo/U'J IO/0«i/B9 U1PIII (II): O-IV U i 0 t 0 .' II I U t U 2 0-2

SlHI VUIAIIU OIIGAMICi (u.j/k.j)

I'heiiol 2JU.I

4-XuUiylpheiiul

Isopliorune

2.4-Oimelhytiiliunol

Ut'ii/ult if id I'JOOJ bJOJ

2 H«lliylii4|>hllulent!

I/UJ

4J.I

Uilieniudurin

f lurenc S2J N IlllrosoOlpheiiyUmlni'

Phenanlhrcne 560 - Anthriccne SW -

01 -n-butylphilite IIOOU 4900 -

Huortnthene 3/OJ -

Pyrcne 470 -

Uulhlkt!n

bh(2-(lhylhi!i

(li-n-oclylphtlitlite I100J 280J Ucnio(b)Fluor

I DIAL ilMI VIII All! L UllUANIt COHI.I Hill Al Hill

20133 9/0 001 2120

Mill! j

Uir..ilut ulril SuiUcu Su 11 HiiriMij DjlJ lul.ll Mil.il, N,muliU> lorpuritiun Site

I All NUHIIIK: HIIAH 1 7 HIIAK II) MIIAII ,'J HIIAK 24 HIIAK .'0 HIIAK 27 HHV 616 HUK-647 SAHPll IOCAIIUN: Sll 01 II 01 Sll OKI Oil) Sll 0211 01 Sll 0211 Oil) Sll 0311 01 Sll 01,11 01 Sll 021) 01 Sll 031) 01 OAK SAHCIll): 10/12/89 10/12/09 10/12/09 ID/ I.1/ 09 10/12/119 10/12/09 09/29/89 10/09/89 W.PIII (It): 02 02 02 0 2 0 2 02 0 2 02

IHOKGAHCIS (my/ky)

Aluminum 2760.0 2bbO.O 11)00.0 2100.0 3240.0 2100.1) 4240.0 4(160. 01 J

Antimony - s.. - - 28.0HJ

Arsenic I.9II.I 1.21! I.JII 1 711 0.6IIJ I.OII 2.8

bar i urn 9. Ill 0.9U /.bit 7. Illl 12.111 IS.JII 15.78 176.0.)

Uery Ilium - - 0.558

Cadmium 0.4311 1.50 30.5

Calcium 56.311 64.011 37.311 3'j.'jll 2'Ju.OU 39b.OH 26600 . 0 2390.0J

Chromium 4.7 3.8 J.S 4.1 b.2 3.6 5.2 7.7J

Cobalt - - - 0.748

Cupper 4.011 2.411 1 . 'Ill b.a 2.611 34.7

Iron 2(140 0 2640.0 26')0.0 ,'IIIU (1 2190.0 1390.0 4340.0 b'J60.0

lead 4.6 9.2.1 4. IS 4.1)', 36.0 22.0 7.8 10/00. OS

Magnesium 129.011 lib. Oil 111.61) 9/. 411 100. Oil 82.0 107000. OJ 1040. OOJ

Hamjanese 11.11 12.0 10.3 6.4 6.6 10.1 42. Z 26. IJ

Mercury - • - . .

Nickel 2. 58 1.1)11 U.9II I.OII I.JII 1.21) 2.5U 2.58

Potassium "• - - 322.08 130.08

Selenium - 5.7SNJ

Silver - 0.6R

Sud i uill 17.711 Ml. 411 III). 'Ill till. Ill 23.1111 33.01! 81.28

Vanadium 5. 211 b.2ll 4.611 4 Illl U.90 3.911 ' 8.011 9.511

line 7.6 6.7 Lull 1 . Illl 13.714.0 13. OJ 860.0 ? 001 2121

uiiiu 3 (miir.i) llii>.il mallei bur I. HO bo lloriii.j ll.il.i hit.il Hi-l.il1.

luipui'iit lun

IAII NUMIIIR: MIIY (ill HIIW 409 MIIY 1,01 Mil* l>04 MIIY (.01) MIIY bib MIIY 642 SAMI'll' lOlAIIUM: Sll -ObS 01 Ml ObS 01 Sll 01'., Ill Ml Oil1) 111 Ml O'JS 01 Ml IDS 01 suns 01 l)Alf SAHIMIU: 09/211/119 0'.l/?b/U9 09/27/ll'J 112/27/119 it'J/29/l)9 10/0b/ll9 IO/Ob/119 Ull'lll (It): 0 2 0 .' 02 0 ,' 02 0 2 0 2

IHOKC.ANKS (mij/k.j)

Aluminum U63V OU 3b40.00 21'IU.DU II.'OU.OO 31)10.00 0220.0 2020.0

Antimony • - 3 . / 1111,1

Arsenic 2.11 1.311 llai ium ID. 3011 b.-IUII 12.0011 211.0011 11.3011 22. III! J lb.7UI.J

Uuryll ium

Cadmium 0.//U 0. •!'<)) 2.20

Calcium IbU.OOU 41.1011 'jll'j.Oull 2'j 1.00(1 b2b.OU.I 70.911.1 llirumium 13.30J 11.20,)' b.70' 12. 10.1 7.110 7.1 2.7

Calbalt O.UOII 0.1)1)11 - 1.1)011 3.011 1.611

Cupper 9.00 4J)OU b.bOJ 12.110 3. 1011 S.bJ , 3.9UJ

Iron IbbOO.OO MOOO.OO' 3/UO.OO* llbOO.OO bUbO.OO 7100.0' 3740.0 lead 235.00 3.20* bl.bO Ib90.00 11.10 6.2J 20. 4S

Haynesium 174.001IJ bZ.bOIIJ 1411.001),) 372.00UJ 240.00UJ 4I9.0IUJ Ub.OULJ

Manyanese 17.30 7.70 12.40 22. bO 19.20 29. 3 J 16. 6J

Mercury ' - -

Nickel Z.50U 2. 301) 2. boil 1. BOD 4.4UJ 2.7UJ

Potassium 221.0011 101. OOb 4U.70U 2/!>.OOl) 192 .0011 24bOil . 90. IU

Selenium

Silver

Sodium 22. DO 24 10 2l.bOU 29.bll 23.011

Vanadium 24.00 1J.10 9.401) 19.20 II. 'jO I4.:i.l 0.9IU

Zinc 2l.bO.) 3.2011,1 Ib./O II) 1 O.I 'J .Oil III U.3J 001 2122 Ulilu 4

Wi'lUmh iurljte Soil Iliiriinj l(jU luljl Hul.il-,

Nocullli* LIII porjt IUM SiU'

I/Ml NUHUIH: HIIAK II / HHAH III Ml*. ii; 1 1 SAMI'lt IOIAIIUN: Sll 114 •> III Sll iMIl III Ml n'.ll 01 HAH SAMCLID: 10/IO/U'J IU.II/U9 MI/II/ID UIPIII (It): U J U / U .'

IHOHGAHIlS (nj/k

Aluninuii 3JU:OI.I UJU.UIJ 41/0 01. 1

An 1 i atony

Arsenic O.u'jll 1 Ml

Barium 23.bUJ iriiu 24 I.U.I

Uurylliim U bill 0.4 III! U . III!

UUrniun 0 . boll 'il ./U.I

1 1 \ c i urn I64.0UJ III.OHJ 3/3 OU

CliruiiiiM 2.SJ I.4IIJ II. /

tulull

topper U.I 2.011 1/4. U

Iron 2U303 0 4S2 0 JUUU.U

le*U bO.9 14. OS 14,'U.U

NtWetlM IU4.UIIJ 9/./IIJ IbVOIIJ

H.n.j4..e>e /.DJ 4.JII' II. OJ

Hercury - I.I

Nickel 1.1 U 411

PuUsviun 133.011 03.911 130 Oil

Se 1 vii i un b.bllJ

Silver

So J i UK I'j /ll V.'JII i;. mi

V-M,a,U. ) 411 l.bU 41, . U

Zinc 22.1 14.4 104 0 NLT 001 2123

I .litI.' 'j

HulUiith bin I J> i! Soil lluniiij l).ita KMA ,in.l Vul.ilili' II, <|.in. i. lljscolilu Corpurjtation Site

IAII HUHIIIK: 4'H/II VI 4'H/II >jl 4/-VI/II Ml SAMI'll IUCAIION: Sll ()•!•. 01 Ml 0111 ill Sll (IMI III IIAH SAMI'lt: 10/IO/U'J 10/11/UV III/II/IM UtPIII (H): 0-2 02 0 /

Hclhyl HellMcryUU lu.j/k.j) IJU

IAII NUHIIIK: Hill 711 III II 11 In H M bAHI'Lt LOCAIIOH: Ml u,|S 01 SU 0411 01 MIO'jll 01

VUlAIILt OHGANICS lu

Helhllene ChloriOe Acelone Carbon Otsull iilu

1,1 UlLllloiOfUUMl!

1,2-Uithlurovlhaue llolal) Chloroform - • U.I 2-Uutanone - I, I, l-lrkhloroelhane

Carbon Ivlrar.liloriUe

Irithloreulliiinc - - JJ Ik'cuiMie

letrachloroetheni! - . 4,)

loluene - . /j

[thy 1 benzene - - jj

Slurtne . .

Xyltnes (loUl)

IUIAI VOLAHLt ORGANIC CUIIC1N1I1AI |UH

0 U NLT 001 2124 I .ill 11! b •

Ui-tl'liili Vlilair bull Mm lily U.il4 JIIMI Viil.ilili> (Iti)JMH'.

N4Mulile lurpunliun bill!

Mil NUMIIIH: Hill .'II Hill II It'll l< SAHI'U IIHAIIUN: Sll HIS HI Ml "HI Dl SIHIMI HI I I/Ml SAMI'Ill): III. ID/Ill III/II/U'J IU. II/IW 1)1 HIII (II): U / 0 / U •' ilMI-VOlAUU OKGAHILi (uy/k.j)

Pile no 1 4/uuJ

4 Me Ih I phenol

Uophorone

^,4-Uioethylphenul UiiUJ

Uvntuic aclU )luuuj

Haplillialenc HJUJ

2 Mvlhylniphlhilene I'JUOJ UimelhrlphlliiUte I20J Acvn^plithvne

Ilibenzalur^n UielhylphlluUle

Fluorinlhene N-llilruswIipheiiyUnine

Pheninlhrene 4BJ 2SOOJ

Anthracene 4UO.I

Ui-n-butylphthalile 230UU.) I luoranlhene

Pyrnee ."jUII.I

UulylbentylphllMltle H.IUII.I

ttenio(a)Anlhracene

Uirysene I'JUUJ

IJUJ jbUUUUJ

Ui-n-octjrlphlhalale 1,400.1

Beniu(b)riuuranlhene I2UU.I

Hvii

IUIAL SLMI VOLAtllt OKUANIC LIIHCINIHAI HIM

411 441' 001 2125

TAIH.K /

Building Bulk end Debrii Sample Oil* • A»l>mlo» Hucolll* Corporation Sit*

(PA SAMPLE NO: 4B36II-101 4036B-10/ 4B5t.ll 101 40160-104 40H.B-105 4B36B-106 48368-107 483bB-10B LOCAIIOH ID: DII-01 80-02 III) -03 HI) 04 BD-05 BD-Ob BD-07 BO 08 DAK SAMPLED: 10/19/89 10/19/89 1II/19/IW 10/19/09 10/19/89 10/19/89 10/19/89 10/19/89

ASBESIOS MINERALS U)

1. Chryiollle. ?0 30 30 2. ABoille

30 Aibeilos lotel 30

HON-ASBESIOS FIBROUS MATERIAL (X)

1. Fiberglett 20 25 2. Celluloie 10 15 1. Miner.I Wool JO 4. Synthetic Fibers

Hon-Aibettoi Fibrous lotel 25

MOH-FIBROUS MA1ERIALS (X) i ' 1. Binder 50 4'j 80 70 70 75 2. Celrlle 20 ]. Gypiua-. 20 4. Orgenle Fngaenls 10 5. Celclle 6. Ouerti

Non-Fibrou* lolel 90 7'j 55 80 70 70 75

1DIAL 100 Kl'l '.00 10') 100 100 100 10(1 NLT 001 2126

unit ill MI) Bulk «nd Dilirti Som|il« Dili • Hitcotll* Corporal Ion Sit*

IPA SAMPLE HO: 4BJM1-109 4B36II-110 4IUMI-1M 403611-112 4BJ6B-11J tBJ6B-m 4B 568-115 LOCATION ID: BO-09 nu- in un 11 im-1? BI1-1J BII-K BO-15 DATE .SAMPLED: 10/19/09^ 10/19/89 10/19/119' 10/19/B9 10/19/B9 10/19/B9 10/19/89

ASBESTOS MINERALS (X) t. Chrytolllt ."Ml SO 2. Anoill* .'0

AiLxaloi Total 20

NON-ASBESTOS FIBROUS MATERIAL (X)

t. flbarglaii 2. Ctlluloia J. Hlntrtl Wool 4. Synlhtllc Flbtri 5 5

Hon-Aibattoi Flbrout Total 20 5 5

NON-FIBROUS MATERIALS (X) i • 1. Binder 60 70 6(1 80 BO 70 U) 2. Ctlrlt. 3. Gyptut 10 4. Orginlc Frtgntntl 5. Ctloltt 15 6. Outrti 15 15 • - - i Hon-Flbrom lot it 60 95 1,0 95 95 70 <0

T01AL 100 100 inn inn 10(1 100 100 NLT 001 2127

Table 8

Building Bulk ind D.brij S*apl« D«li - HMA (Utcolil* Corporal ion Silt

(PA SAMPLE NO: 4947B-J01 -. 4947B-J02 4947B 303 49478-304 49*78-305 49471-306 49478-307 IOCAIIUN ID: BO-01 BO-01 BO 03 BU-04 BO-05 BO-06 BO-07 DAIE SAMPLED: 10/19/89 10/19/H9 10/19/09 10/19/H9 10/19/09 10/19/09 10/19/89

M.thyl Hcthwrylit* (ug/kg) 2SOOOOO B 33000 U J300UO II 3ROOOO B 46000 B 5600000 490000 B

{PA SAMPLE NO: 4947B-JOB 49478-309 49470-310 4947B-J11 4947B-J12 49478-313 4947B 314 49478 315 L OCA 11 OH ID: BD-OB BO-09 BD-11) BU-11 BO-12 BO-13 BO-14 80 15 DAIE SAMPLED: 10/19/89 10/19/89 10/19/U9 10/1-//89 10/19/89 10/19/89 10/19/89 10/19/89

Methyl HithtcryUl* (ug/lig) 9900000 B 460000 B 6800MOO II 20(HKHI B 600000 B 310000 B 2500000 B 5700000 B 2128

TAKI.K 'J

Building Bulk »nd Dibrii Snmplo Data • Hoi all Hticolil* Corportt ion-Sit*

EPA SAMPLE NO: 50J7K-201 503/11-20;' 50J70-2IM 501711-204 5037B-205 50J7B 206 50378-207 50 J/B ?OH LOCAIIOH ID: DD 01 110 02 III) 01 III) 04 BII-05 BO -06 HI) -07 BO UO DAIE SAHPLtD: 10/19/09 10/19/09 Ul/ 19/89 10/19/09 10/19/89 10/19/09 10/19/09 10/19/09

INORGANICS (rig/ky)

Aluminum 125000 • 1620 • 4B.'0 " 4690 • 555 * 3290 • 2340 • 1090 • Ant inony - - 8.1 II" 19 • 150 • 603 • - 14.7 B' Arsenic 3.7 44.4 10.9 62.3 S 36.5 11.2 23.44 J 87 Ber ium 94.3 196 50.' 356 915 335 160 51.2 Beryl I iun - 0.66 j - Cedmiu* 2.3 J 10.0 107 42.9 391 90.4 17.6 127 Celcium 1790 31140 VfllO 74900 2710 3190 6250 J5JO Chromium 45 H"J 42.2 H'J 71.1. H'J 154 N"J 108 N"J 51 N«J 40.7 H'J 29. J H'J Cobtll 7.1 4.9 II 7.6 B 37.9 6.4 B 12. J 2.1 B Copper 26.8 179 79! 529 1010 218 202 60.3 Iron 1040 103000 9 141 III 911 101) 466000 1241X11) J 40400 64600 Letd 78.5 " 953 • 4490 " 10400 • 28900 • 79900 • 1100 • 23/d • Htgneiiun 350 B 2470 D 1740 39700 969 B 2160 4990 867 B Hangtnese 18.7 896 522 615 2470 700 282 227 Hercury 1.3 1.4 1.5 3..' 0.14 0.38 1.8 0.71 H|ek«l - 145 111.' 115 450 J 61.2 54.3 46.2 Pottniu* " 324 B 55'. II 25 «) 372 B 153 B 548 B 1 Seleniun 3.3 BW - 4.; -j 2.8 S 20.8 11.2 1.2 S 2 B Silver - 6.2 HJ 9. i HJ 5.1 HJ 4.8 HJ - - Sodiun 48.9 B OH. 2 0 250 II 17.'0 697 B 93.8 B 92.2 B 252 B Ventdiun 13.8 450 85.. • 419 50.5 80.7 24 28.1 Zinc 119 1960 6250 4010 1930 1400 3260 4050 f

IK (O/ 9Z» fit IIMIl U/91 tn r - n 9-* Vbl roi . a / b a b in f 61 fl o S a 9'z» I Z'96 009/9 00019 n <.iu R rz/ 96* •nipos - - TH Z'Z ntO 9/'ll - - - - s V19 r« vo» Z'l - - 1 UZ B bbr a zi9 II S"»l a ;9i - • 8*99 /'9/ /•«'/ H'/V roz - a 90*o »ro 9 ( a no o Z'O a eo'o Z'/» 0811 m zi» (•>-> fHl BT» B /M 6/1 B /I9 B f99 Q l>Wc' a H69 a /bi . /9Z . 91Z . 0001 f. . h.VUl . .'it . ^rb . b9l Ob9» 00068C OOOflOl OIHKiOl (IIIIKM ooobr 00901 UOJ| 9 Zl /•(.a I.O/ (,fiV /.'I /.'I T/I . 11 B C9 R «••> II 1, IU r ft vu r 9'i •01

B I '01 B Vft W «fc R W 8-19 a 9*ii "°M»B (60 ' 191 Z'99 *.">9 d IIV S 6'fl b'O 3lu*>jy AUOIII iuy eaz W mil c'VU

bB/bi/Ul 1,8/61/01 bfl/M/Ul dfl/M /Ol Mi/M/ot . <,a/bi/oi :nn.iHvs ma S 91 UB M 08 n mi i-l UH n mi 01 OB (,O-OB :QI NOIIVDOI r 41Z »IZ B/I09 n

• US ooi )*Jodjo3 »ll |O3t(||

100 NLT 001 2130 ' 10

ii I jo' Suit Uurini| II.ilc - MMA .m>l Vul.ilili- OMJ.HIH .

H.I Mill III! iUI (101 Jt lull Sill!

I AM NUMIIIH- 4-.H/I1 ."> 4'M,'II .'li -I'M,'II .'/ 4tl4

Hulhyl HvthdiryUte (mj/kij) • U'uuuuil.l / IUUUU • b.)

IAII MUHHIK: Ull.l ')/ IIII.I 'Jil HM.I 'J'J llll.l (III IIIU H'J llll.l 9II Hill (IJ bAMI'll IOLAIIUN: Ml OIS 0^ Ml UIS U4 Ml UIS U/ bll Ull) «<• Ml OIU-U/ Sll Ultl l^ SU-02S-02 st VOlAlllt OIIUANICS (uy/kij)

t! Chloride /III

AtL'ltlML' bbOJ I/UI)

101 bun UiiulliUe

1.1-Die hi oroe lliane

1.2-Uicliloruothene (toUl) ,'.'0.1

Chloroform

1,1,1-Iricliloroulhant.' IUOO

Carbun' (elractiloride liithloroethene muo - - Benzene 2bOO .....

k'lrachloroelhene

loluene 6b I30UO llhylbtiuene 300 2GOU .....

Styrene 42U ("WOO ..... Xylenees (lotal) 2'M luuou .....

IOIAI VULAfILt OHCAHK IUNUNIKAI IOH

IMJ'j NLT 001 2131 l.ililc ID (mill '.I)

'nili-.iirl.li f JIM I llui'tii'i ll.ilj • MMA mil Vul.ilil,. III.|.IMII .

NJ'.I ul lie Cut |iui Jl lull bill'

Mil MllMWII 4'1-l/H ."I 4'14/H III 4'14/H HI 4i4,'l, |'i I'll/M ,'il 4'M/ii IS bAMI'll lUtAUUN: SIMi,". 114 Ml II.", ll/ Ml U.'ll il/ Ml u.'ll I.' Mi 11/11 k'll Ml or, ll/ DAM bAHCI I: IU/IM/U') lu/n-l/U'* ll'i/."l/'U4 d'l ."I/II'J U'l/,"l/U't UtIPlI (fl): lU I.' ZS // /b .'/ Ml W bU b

I All NOMHIK: Hill ll'l Hill U'j IIH.I I'..' hh.l Ml IIH.I 114 Hill I') bAMI'U LOIAIIUII: bll U/'j U4 bll-U/b-0/ Ml U.'ll 01 Ml U.'ll I.' Ml u.'lll/ll Mi UJV VOlAlIll ORGANIC* (uy/kg)

Hi.'lhylcnc Lhluride VIH

Atelone IUUIU IU.I IIIJ l.jrbun Uliull iJe

1,1-Uichlurui'lhJne 111

1,2 Oichloroclhene (loUl)

Lhlorufurm bJ

? DuUnone I,l,l-trlchloroclli4ne

(.jrbun I(lr4chloridv JJ

Irkhlorethvne

Ucnlcne 01

K'lrichloroelhene J/UU .'U J/0

llhyltxiiiiene /IUUO

Slyrenc 3/0

Xylenes (lalil)

IUIAI VOIAIIU URCANIC CUNllll IHAI11 III

3U/ .' U' I 3/U NLT 001 2132

I jlil i! lu (lonl'il)

SuljMii I JLII bull Uuriin) Da 1.1 MMA dinl Vnl.it ilr UMJ.IMH ,

Njiiuhle torpur.ition Site

I AM NUHIIIH: 4'M/H .'b 4'10/H :)/ l'M/jl-44 4-14 ;il 4'i SAMI'U KltAIION: Sll I) IS 04 •ill I) Pi il / Ml Hill 114 Sll Illll Illl Ml Illll U' IIAII SAMI'US: 10/IIS/H'J lll/US/U'J 10/U't/ll'J lu/iri/u-j ID.-IM/U'J 1)1 I'll! (II): IU U' •"i 21 IN \l •jl) b^

MntlutryUtu (uy/ku.) 2J 4,1 'jJUUUU.I UOU

I All NIIMIIIK: Illll Illll ,M ll/l U II/ I I.1 Il/ 111 SAMI'lt LUlAIIOH: O.IS-04 ill UJS U/ ill U.lll U4 Sll U III UU Sll UJI)

VULAIIU Old, AN I IS (mj/k.j)

Hethylvni! Chluride

Acelouu 24UIIJ .MUD.I I,'U.I Carbon Uisull idt* I , I •IlK.hluroelltdnt! » 1,? Uichloroelhune (lotal)

th 1 010 form

2-Uuldminu

1 , 1 , 1 - Irithloi oulhjne

Carvon K'tr at

Irichloraelhene II UU

li'UU

Ivlrachloruetheni; 1'JOJ Toluene MM Ethyl birn/enu )!>UU Styrene UJUU Xyluiit!* (total) •IliUU

1U1AL VDLAIItt OHCANIC CONCtHIIlAt Hit)

.' I UU NLT 001 2133

IU (mill ,|)

rl.ui' Suil llni iin| ll.ll.i MMA .mil Viil.itllf lln|.inii .

lilv tur|iurjl tun bllu

1 I AH HUMHIH: 4'M/ll 4')4/ll Sn ' 4'il/ll II 4'14/H I . 4-(4/h il.' SAMI'll I (II. All UN: Ml (Ms lib Ml Il4\ II/ Ml OS', nb Ml IIV. 01 Ml Otr. ilb DAM. SAHI'liO: 10,'ld/u'J MVIU/H'J ITi.VH/iW tl'i.VH./ll'J ll'l/.'l,, D'J 1)1 I I'll (It): ib i/ /b » is i/ ;'b ;•/ 111 .'ii

Helhyl M.'lliacrylile (iiij/k'j) tl.l

(All NUMIIIU. mil ,"i inn 111 mi i •// i:iu /ii H/ i.-i, SAHIM.I IULAIION: Ml (M> (I!) ill U4'., I)/ Ml I):.S Ub Ml U!.'.> O/ Ml UlA Ub

VIII Al HI OIICAHICS (u

Hi! I hy I one Chloride

Atelunn 14,1 I-I.I tarbun Uiiull ule (j.l

1.1-Uichluroelhane

1.2-Ukhluroethene

Lhloiufonn IU

2-Uiitaiioiiu

I, I, I • IrithliiiOL'lhdii

Ljrbon Ic'tratliluriilu

Irichlornelhene

Uviuene

letrahluruelhene I.I luluene 1J tthylbuniene 410 Slyrene Xylunus

IIIIAL VOLAIlLt ORGANIC UlNUNIHAI HIM

14 410 /<>(«„•

imnvMinMtn nun/nun IIIIVIOA ivmi

rnnn nor. i rnnr rnnnr.i ronoi

rnnn rn rnr,s nw ro» rni/ rnnn POOJZ rnocs

cm/ W61 wifin.injn|i(ji Jl- • |' |' | aiiouring-;

»uai|ian.io|ipin Z'l r./ rii !•/ f.r rnr unqif i rn-ir rnrn rn/i nvi

SIIHVnHO MIIVinA fio-sno-iK in snn ns oo s/o us ;n-s/n us M sih-ns I/CMH HI run id run /" niu /<•> /n IIVI rnrinti,- i mi',/ nnnn/r /r-sr ,•; II.- w i,' s t /i r,f IM\ M 1,1 in MI//.'.'MI MI///./MI cn//("r.n :(11MHV<; II VII MI Min IP; in sun ir. w s/n us ?n s;n nr. MI s'w us n.iwvs no n/n> 'HI H/H.V >,n H/H,» 10 IIVI

•UK, uni )r mil 10 |

01 •M"pl TOO NLT 001 2135

I able 10 (aiiit'd) Siibsurt jiu Soil llurhii) Data • HHA jnil ViiLitili1 Un|

(All NUMIHH: 4')4/M II 4'I4/II I,' 4'14/lt 11 4114 .'|i 14 SAMI'U IOCAIIUN: Ml 0'IS O'j Ml 0')') II'J Sll III', (I/ Sll lil'i (III DAM. SAMI'llI): IO/IIS/U9 III/IIVU'J UIPIH (fl): Ib I/ .'b ?/ 3U 3.!

Helhyl Melhatrylatc (uy/kij) UoUUUUJ 2IIUUO.I 1 'JUU1IUO Uuutl

I AH NUMUIR: (III.) 74 Mil.) I'j HIM l!i Mill I / SAMI'U IUCAIIUN: SU-O'JS 0 Sll U'IS-09 Sill US U/ SU I OS OU VULAIILl ORGANICS (u

Hiilhylene Chloride Aiutone Carbon Uisulfide 1,1 Uichloroelhdne (loldl) 1.I Uichloroelhene (total) thloruform Z-Bulanone 1,1,1-Iriihloroellune n

Carbon lulrachloride

Irichloroelhvne 2bO 2/0 lelrichloroelhcne 3!)

luluene 630 31 [ thylbenzene I BO Slyrene 1300 Aylvnes (lolal) 610

1UIAL VULAIILL UIIGAHIC CUHCtNlKAl ION NLT 001 2136

I ah 1 1- 10 (mill M)

Vilr,iil I j. f Joil Uui i in) ILilJ MMA V.i I. ill 1 1- Hi .(.HIM .

MdioiullU' luipmjl inn bill'

(All WJHHIH: 4S4/II 4.' 4'I4/II bl 4')4/ll V -I'l-l/ll SI 4'14/M I'l 4'14/U 40 SAMI'LI IIK.AIIUN: Ml MS il,' Sll l.'s U/ Sll 1,'S il-l Sll 1,'S ll/ Sll Mb Ub Sll US Ob IIAII SAMI'll U: 10,'Ub/U'J HI/IO/U9 In/lll/H'l HI, hi/ll'J ID/OI./U9 lU/Oli/H'J UIPIII (ft): ) 'j J b 10 k' /i // Ib I/ id I.'

Helhyl HvllilcryUlt (u.j/luj) ?bUU.I H K •

IAII NUHIIIH: VI \/i\ ll/ IJIi ll/ 1 I/ ll/ Illl Hill .'4 Mill 31 SAHI'Lt LULAIIUN: Sll US 0.! Sll l?b O/ bit I2S 04 Sll l/b U/ MllJbOS Sll US Ob

VIII Al III OMtAMItb (iu|A

Mulhylvne Ihluride

Ate tune WOO.) J4.I

Ctrbon ui&ulliile

1, l-Uichli)roelhine

I.Z-Dithlorelhene (loUl)

Uiloroforn

2-BuUnone

1 , 1, l-Irkhloruelhjin!

tjrbun lelrichloriile

Trichloroethene

Bcniene IOOOJ ....

letrichlorethene

lolucne

(Ihylbeniene 6/000 9 JbOO l?00 Stryrene

(ylvnes (lotil) JbOO

lUlAL VULAIIU OHI.ANIL CONUNIHAII OH

7BUUO 4J JbUO l.'UII 001 2137 I .ill I r IU (iulll.1) NLT iulnui I jiv ioil Iliirin.) ll.i 1.1 HHA 411.1 Vulalil.- ih.|.ini

Cui purjl lun Silv

I All VI4/II 1,'j 4'M/II /| SAHHI IOIA1IUN: Ml OIIMI4 Sll ll.'ll U/ DA 11 SAMI'lll): ID/li'/tt'l III.'I.'IH III Pill (II): IU I/ I 'j

Me thy I Hvllucrylalu

I All NOMHIH: III II 41) III II In SAMPU LOUUION: Ml 0111 (M Ml (Ml U2

VOIAIIU UKGANICS (uyAy)

MulhUiif Clilurlde An-loiie

UrUon Utsulfidu

I, l-Uichluroethiiie

1,2-Uichloroclhine

thlurulom

I, I, I • Irithloruellune

Ijibun

Irichloroelhvne

IJ 2.1

leli wcliloroelhene

loluene

llhylbeniene

Slyrene

Xylvnes (luUI)

IUIAL VUIAIIU UKGANIt COHI'UIWI Kill

I I 001 2138 TSiLT

I.ljllf 10 (.illlIM)

ViliMll I ail- Soil HIM in.) ll.il.i • MMA Jliil Vul.illli- lli.|,iilli

II.iii ill III' I'.IH |iurat inn 'nli1

(All miMHIK: I'M/ H i..1 •I'll,'I I 1,11 4'H/ll '.M •I'l'l/ll V/ • 4'14/H ill SAMI'll lUlAIIUH: Ml (MM i),1 MI mil n4 Ml (MM ol Ml ll'lll ill Ml IIMI U) HAIL SAMI'llll: IO'1?/U'J III/ 1.'/ II') HI/II/U'J IO/II,H'J III/ 11/119 IU 1,' 1 'i J i / 1)1 I'll! (11): 3 b ' '

HiHhyl Mt'lhitiylaltf (mj/M|l ) b

1 All NUMHIII: lil II 4/ Hill 41 Hill ).' III II II III II li> SAHI'U LUIAIIUH: SII-OJII W Sll OJII-04 Sll 0411 Of Sll U4II OJ SU-Ubll OJ . V VUIIIAU OUGANICS (u>.|/k>j 1

Hulhylvne Lhlori.lu Atelone

Larbun Uisulfidu

1,1 Uichloraotliane 1,? Oidiloroelhene

Chlorofurn

2-Uuldnoiiu

I, I, I-Iricliloroethane

Carbon letrachloride

li'iihloroelhcne Hellene

letrjthuroethune

loluene 3J tthy I benzene

Styrene

Xykilos (lutal)

IUIAL VOIA?IU OHGAHIC CUNCtNIIIAI KIN

0 NLT 001 2139

bull MM I d< L' bull UMI III.| II.11.1 • MMA .mil V.il.ililf lhi|.iMM .

Nj^iullli* l.ui pnrjl HIM Silr

I All NUMIIIII: ^'14/11 ii.' 4'H/II l\ -I'U/li /I SAMI'll HX.AIIUN: Sll ll'jll U4 Ml (Hill lH Ml Ui.ll 04 IMII SAMI'lll): lll/ll/U'J \\f'tt/lM UI.'I.VH'I III Pill (II): IU IU I.'

Mt!lhyl

I All HUHMI II : lii II lii III II 411 III II 4'i SAHPll UHAIIUH: ili Ubll 04 Ml UUll OJ bUUl.ll U4

VUlAIILt OHUANICi (u.j/Kij)

i'liu LhluriOe

Ac v tone

Cailion UiMilfide

1,1-Uitliluruellune

I.M)ichluioelheno

ChlorufurM

2-OuUnunt'

tjrbun Irichlurovlliene Benjenc Itrtrichluroethene luluvne lthylb«niene Slyrene Xyluneni (lulilj

IUIAI VUlAIILt ORUANIL CWItlHIKAl lull

U NLT I ,!,!.• II 001 2140

'ulltMII I ,M I' Stilt l(llllll>| ll.ll.l 'i-llll Vlll.llllr Dt |.lllli .

fl.l'.i 1)1 t It' I.til pill ,ll 11)11 Jllf

I All NUMIIIK: ll|:| nil Mill ,t| |;i I u' |-,i.l ';.• |,i;.i .) | |i||,| 'M hill III, S

4 Melhl/pliiMiul

I '. /uuu.l 'jini HIMI/OK it i (I

Naphthalene

2 Hulhylnaphthaleiii!

UincUiylphthdlate J1U.I

Dilii'M/olui an

Uiethylphlhalate I luorene

H llilrosdiplii'nylaniiiit!

I'ht'nanlhrtiiu Anthracene

Ui-n-bulylphthaUle

I tuuranthiMio

I'yriMie

Butyllu-n/ylplillidlalR iyouo.1

llen;u(a)Antlirateiie

7/uuii ibiiuuu

Ui-ii octylphthalate

Ucn/o(l)|l luuranthuni!

llun;u( Jjl'yruin'

IUIAI. SIHI-VOIAIIU. UHLAHIC (.UMII UIIIAI lull

IIOOO lU'JJIiOU 220 001 2141

it (tuiii'ii)

r I ji.1' Soil Um'iMtj Data • St;mi Vul.ililr OI>|.IIIM\

lilt.' Ittrpurjl ion Sill'

I All NUMIIIH: Mill I)/ Mill III! HIM II.' IIII.I III llll.l 114 Hill .'U SAHI'll IIIIAIIUN: Sll U.". 04 Sll II.'S HI Sll il.'ll 117 Ml ll.'ll I.' Ml ll.'ll Sll (US 01 DA It SAHPlll): 10/1)4/1)9 IO/04/U'J Wl'lll (It): 10 I.' ,"> ,'/

SIHI VUIAIIU UKUAIIItb (u

Hi'diylphiMiul

2,4-OinielhylpliLMiol

UlMI/UIC 4ClU

N.iph'lh J k'riL'

J-Hulhyliuphthaleiie

Uimethylphlhalene

Acenjphlhene

Oibviuufuran

IJUJ

F luorene N-llilrusidiphenylamuie

Plienanlhrene Anthracene

Dl-n-bulylphlhalale 2UUUO 490 Fluoranthene Pyrene

Uulylbenzylphllialale 99UUJ llirysene

4bU

Di-n-oclyphthalale IbOOOO Hezu(b)riuoranthene

llun/o(ajPyrene

IOIAL S'HI-VULAIILl UIIGANIC Ci'NtlNIHAI Hill NLT 001 2142

I Hi. I.' || (.Ulll'll)

Siilisiii I JU! Soil Dm 1 1. '( lUlj • Svmi Vnl.ililf (lii|.inii •

NJX ill ill* C»|iur4l inn Sili!

I All NUHHIK: Mill .'.' HIM .'•! H: i ii ii. 11.' n/ in NAMI'I I IIKAIIUN: Sll UIS 114 Ml ill'. HI Ml II III n-l Ml 'I HI (II) Sll 11.111 11* HAH SAMI'll: lO.'ll'j/U'J fn/U'i/U'J in/u-vii') lo/U'i/m io/iiM/119 III I' I II ((1): 10 I? J'j /I ID \2 III ).' bU ',1

MMI VUIAIIU UKCAMUi lu.j/k,j)

Hlenol MUUJ I4IIUI

4 HvlhylphtMiul 9tiUJ IUUUJ

1 soplioi one

/,4 Dimvllijrphenul /i'OO IIUU.I

Hvn/oii. iciil 4'jilll.l

Hjphtlulvnv MUUJ

2 Heth/lniphthiltn« SJUJ

UimelliylphUuUU 1'iOOJ 'jiau.i

Oibeniofuran

UielhylphthaUle JUUOJ I/UU.I

I luiircne

N • N 1 1 1 ututl i|>hvnjr I Mine

Phenjnlliren*

Anthnccne

Dl-n-bulylphiUte 7bUUUII.I J'JUJ

f luorinlhen*

Pyrene

ButylbvntylphthaUle I60J 4UUUJ

Benzol i (Anthriteno

Ihcyvene

bis(? Llhylhe«yl)|ilillulilu lUUDUll.l

Ui n oct/lphlhjlile 2/OJ

Bcn/o(b)l luorinthene

Beiiio(i)l'/rcne

IUIAL SIMI-VOlAIILt ONUANIL IUHI.INIHAI ION

4JU NLT 001 I .,!,!,. II (umlM)

Sulfur! .it i' bull Uurinij Diila • Sfitn Vul.ilili* Oi*|.un<

Ntisuililu lupuraliun Situ

I A!) NUHIIIII: 11(11 .") Ill II II) 1(11.1 // Hill /H It/ l.'i, SAMI'll' IIH.AIiUN: Ml IMS' OS SM IMS il/ Ml II Vi US Ml US'. ll/ Sll Dr.'. US DAM SANI'ltU: lU/IU/ll'J ln/10/HV U'V/H/U1' U'l//ll/U'J U'J llll'lll (II): l!> I/ /S .'/ l!> I/ ?!• .'/ IH .'"

SLMI-VUIAIIU UltliANlLS (uij/kij)

Phi'iiul

4 Helhylphenul

I iupliui unu

^,4-Uimelliylphcnol l)i>no

2-HoUiyliidphUMk'iiu

UiinelhylphlliaUte

Acviuphlhene

Dibeiuofuran

UivthylplithaUte

f I uiiriMiB

N-Hitrosudiplicnylanmine

Phimanthrtme

Anthracene

Ui-n-bulylphthalatu 4/J

f luoranlhene

Pyrene

HiMi/o(a)Anlhratcno

Llirysene

bi!,(2-Uliyllic/yl)|ilithalati! 1)0,1

Ui -n-actylphtalalu

Uvii2ii(b)MuuranalhiMiu

Benio(a)Pyren<>

IOIAI StHI-VIIIAIIU UKbANIt lUNlltllllAI ION NLT 001 2144

Ic II (mill fd)

ml I 41 e SIM I Uui IM.J ll.ilj Vim Vul.il ill- Hi <|.inii •.

Unpur.il inn 5>iti-

(All NUHMIK: ll/ I.'/ (Ill I i,/ llll.l i,M Mil.I /il till.) /I S.WI'll lill.AIIUH: Ml ill,', U'| Ml il/-. il/ Ml II/', Hi, Ml ill! . lid Ml Ilir. ll.MI SAMIMIU: U'l/.'b/US il'r.'/'H'J U'l/V'/H'J ll'l/.',' II'* ll'|.'.'//ll III I'll! (II): 3b I/ IS' .'1 i>b /il .'.' J'i I/

SIHI VUIAIIU ONCANIti (uij/ki))

riii'iiul ISuU 4-HelhyliHii'Mol

I suphoi une

?.4 -Uiiwlhylpliciiiil

Ui'ii/iiic acid Muil.l JIU.I II/U.I

I .'Oil

I9U.I

Dlmi.'tliyl|iluUle IbUJ

Uilivn/ulur^n

UiulhylphlhiUlc I'JU.I

tluurcne

Il-Nulruiudiphcnylamintf

Hhvninlhi ene ZIUJ

Anlhrjcene

Ui-n-butylphlliaUle I3UU I JUDO MOOJ

I luorinlhune /I U.I

Pyrene IIIU.I

BulylteiuyphlhiUte IIUU J4U.I JJUJ

Uen/u(i)Anlhr*ccii«

Ihryieni!

bisl? •ilhylhuxyMphlluUle b'JUU 1,41111 .'/IIU.I

Bi'iuo (b) M uor4nl IIIMII!

IUIAI Sini VULAIIll UHbAIIII limit NIHAI HIM NLT 001 2145

I.llilc' II (.-Hill M)

SuliMirliiiu Soil hen HII) lljlj bcini Viil.il I li; UI<|.IIIM'.

II.1^1 III 111' l.lll |MII ,ll lull bill!

I All WIMIIIII' Mil.) II Hll.l /'. III:! In l:hl l.i •iflHI'll lut.AIIUH: Mi U'r, lib Ml iris UM Ml Ins il/ Ml Mr. im OAll SAHI'IIU: 0'V?I1/U9 1)')/,'!|/D9 lll/US/H'J IJ/UVU9 UtPIII (II): |'j I/ J'j J/ /i .'/ :iu J/ blHI-VUIAI III UKUANItS (ii'

I'hiMinl UHO t/n,l . 44IIU

4 -Methyl phenol • 31U.I

liophorunc - • lii.l

2,4 UimeUiylphiTiol /.'U

lli.'iunic 01 id • • liiio.l

lUphlhalunv UUU .'III.)

2-Hethylnd|>lilhaleiie MUD lu 141)11 SDU

U'JJ

Uibeiuofiiran •

Uiethylphthdldte I^UJ

Plienanthreiie 2IUJ

Anthrict'iie - -

Oi-n-bulyphthaUte 2«UU -

f luoranlhene -

Pyrune

UutylUuiuylplithdlale /|OU

Ueii£u(a)Anthracene ..

thrysene - •

bn(? llliyllM'xylJphlhjIjlo nuuuu J/UJ

Ui-n-uctyplilhdlatv JOUJ

8en

1UIAL SIMI VOIAIUIl UllUnit CUNLINIKAIIOII

144/99 490 II. l.illll' II (lOMl'll) 2146 billmirlJir bull lloi 11«| ll.il.l Vim Vul.ilil.' lli<|.iiiu .

Njsciilili! I oipiii dl ion bill'

(All NUHIIIU- II/ l."l li.' I Hi I'/ M'' M/ I HI IIIH I" Hill I.' bAMI'll HH.AIIUN: Ml II1. Il/ Ml I,". Il/ Ml I.'. Ill M. I.", 0-1 Ml If. Ob Ml II'. llu DAII SAHI'lll): HVOii/ll'J lU'lll'll'J lll/lll/U'l |ii/|il/ll'j lll/Oi./lll lll/IHi/U'J llll'lll (It): J b J b III I/ ."j II IS I/ /I) ,',' • blHI VUIAIIII Ulll.AIIHb (inj/kij)

Phi-no I

4 Mulkylplicnul

Isuphui one

2,4 Uiinolhylph(.'nol

llvn/ulc

JUMI.I

I 'jU(ll).)

Ai rniplilhi'iiu '1,'U.I

Uibvn/ofurjn 4IU.I

I JIIU.I 1,111

Huorvne HUUJ

N NltrosodiplienyU«me l?uuj

Pheiunlhrvne JUUUJ

Anlhrictne

IIUUJ J/UUIHI.I

Fluorintliene 4JUJ Pyrenc 4'JO.I 4'U

Uulylbcntylplilh.il4tt! ItiUUJ •J/U

Ihryscnv

IIIUUUII.I

Ui-n SJUUJ

Uen

IOIAI MMI VUIA III OH Will ' NLT 001 2147 Nlili? II (ciml'd)

Sulisurljci: bull Boimy l)

Njstolilc Corporaliun Site

I All NUHIIIH: Dill 40 III II 41. SAMI'lf IIMAIIOH: Ml (Mil U4 SI) U/ll OJ HAH SAW) ID: IU/I//09 IO/I?/U'J ULPIH (II): 10 1Z J S

SlHI-VUlAIIlt OHbAHICb (ucj/ky)

I'hviiul

4 Me thy I phenol Isuphorunc 2,4 Uinclhylphtlulene Uen/uic «c Id N<|ihllulene

? Melli/linphthilenc Uinclh/lplilhallle

Acen^phthcne 0\\>enio(ur*n Oieth/lphlhiliU r luortnc

H Milrosodiphen/linlne

Phenanthrcne

Anlhncene

Ui-n-bulylphthaUte

Fluoranthene

Pyreot

Uulylb(n

Benio(<) Anthracene

Chryitnc

Di-n-oclylphlhalate

Ben/o(b)F1uarantliene

1UIAI SlHI-VOLAIILt UHbAMIC CONttNIRAIION

0 0 NLT l-ll.lf II (lUlll'J) 2148 buli^nrl.ii-1.- bull Ilin• 111*1 IMU

N*i*,iulile Curpur.il tun bile

(All HUHIIIH: III II 4.' III II •.AMI'11 IIM.AIIUN: Ml DIM II / Ml II III 114 Ml II4II II.' Ml Mill III Ml u'.ll (IJ HAIL SAHI'UU: III/U/U'J MI/I.'/U'J IU/II/H'J Ul/ll/H'J IU.'I|/IW Ull'lll (II): 1 b IU I,' 1 'j '.< I <, I ilHI VOIAIIU UKLANIlb

I'livnol

4 Me I liy I phono I

Isuplioroiie

llfiuulc 'JO,I

2 MelhlniphUnlciie

Uimelhylphlhilile

Acenaphlhcne

Dielh/lphlhilite

Fluor me

N-HitruiocJiplienyl«ine

Phenanilhrenc

Anthracene

Ut-n-bulylplilluUU &40J I4UJ 4bU.I

f luorinlhene Pyrene

Uulylbnuylphlhilile IIU.I

Beniu(i)Anthracen

Chrysene

bis(2 llhylhe»/l)phthiUle /(..I IUII.I 4VIIUJ

Din ot.tyluhlhalale Benio(b)f luorinlhene

H«niu(a)Pyrene

(DIAL SlHI VUIAIIU OHGANR tOHttHIHAI lull

&4U 0 &4/U NLT 001 2149

Mill- II (lUMl'd)

Siih-.ul Ucc bull bur I HIJ Ua I d - bcni -Vul Jl I lir lln|,inn-.

MjMitlilc l.iH'piirjt IIJM Silt*

I AH MUHMIH: III II li> III II -HI Hill -VI SAHI'M HIIAIIUN: Ml IIMI 1)4 Ml Hull U) Ml Ui.ll 114 IIAli bAMfllU: IO/II/II'J I()/I.'/M'J KI/h'/B'J 1)11'III (It): 10 12 S / ID U'

SLHI VIII Al III UHl.ALNKb

I'liiMiul • "'

4-Hi-thy I phenol

Isophurane

2,4 Uimethyl phenol

Uviituic 41. id

Ntphllulene

2-Helhyln

UiMth/lphlhaUle

AcviMphlhene

Diben/ufuriM

OielhylphaUte

I luorene N Hitruioiliphenyl<*inK

PluMunthrene Anthracene Oi-n-butyphthaUte ;/0

rluoranlhene

Pyrene

Bulylbentylophlhalate Benio(a)Anthracene Lhrytene

bis(2-Uhylhe

Oi-n-oclylphthalale

Bvn«o(b)Flooranthene

IUIAL UMI VUUIIU ORGANIC LUHLINIHAIIUN

1110 I. Ill 1 1- I.' 001 2150

u bull Uui iiuj ll.it j • liil.il

Lippui Jt ion bilv

(All NIIHIIIM: HIIV h/l HIN i..'ll HIK n.' 1 HIIV h,'4 HIIV ii.'b HIIV bill SAHI'IIH IIMAIION: Sll IMS I)/ Ml III'. 114 Ml (MS I)/ sii inn U2 Ml Hill I)/ Ml Hill 12 Sll 0/S 02 IIAII SAHfllU: IU/U4/U9 MI/IH/II'J Ki/114/ll') HI/Ul/ll'l 1(1/01/1)9 III/III/II9 IO/04/B9 Illl' III (11): 3 b IU 1,' /'• 11 J b 2b 11 bU b2 3 b

IIMIUkANIlS (mj/kijl

A 1 ui« i num Iblio.O* B.'/ 0- tibJ.U* 'Jb/.U' IlibO.O* SOO.O' 73S.O*

Ant imony 3.2MII.I J/.BIIJ 3.IUNJ

Ar^enc ic 1 . bllW U 911 I.I II 30 l.bll U.UJU lljrium b.JUU 1 4111 I.SIII 2 . 'Jill .1 4.6UIJ 2 2UL I.9UL

Beryllium - -

1 4il« i urn -

(.dlcium 4J UUJ 2J /IU 32.2U-I 114. UUJ /b.bUJ I94.0UJ 70.IOJ

Chromium b.O 1.411 I/. 4 2.UII 13.2 -

UI..U I.UU I.UU I.UU 0,/,'H 2.IU LIB I.IU

Cupper 2.IUJ 1 . 4IIJ 3.2IIJ 3 . 4IIJ 4.9UJ 2.4UJ 2.3UJ

hun 2IZO.O* IBJU.O* II/IU.O* bM.O* 9940.0*' 2730.0' 1160.0* l«d ' I.3J II.) l.bJ O.U2 l.7b 0 . bull.) O.B3J

Maynesium IIO.OUU 26. Jill J IJ./IIL IIJ.OUU S7.2BU 4b.2UU 67.3BIJ

Hayanese b./J 1 Bll U.U3II 2.4U 3.0U b.JJ 4.4J

Mercury •

Nickel I./UJ I.IUJ 1 . blU O.UIIU I.UUJ I.7BJ I.6BJ

Potassium IIO.UU 44. OB UU.IU b4.lll 33/.OU 90. 2U 60. IU

b« 1 en i urn

S i 1 ver

Sodium 22.111 29.011 4U.^II Id.. 'II 4U.3II IbU.OB 31.40

V and i urn I'J.UJ Mill /./U.I 1 'Jll 20 . b.l l./ll 2.bU

/I IIC 4.4J / blU 2 . 911.1 1 UHJ .' . bll.l 4 . bll.l B.bJ IV '••> « n |'i IV WZ r/1* mi; p ni> •> mn iir,-z »'ii rr ,r rrni «nc|,,uM

nr. n/ nn nn un nn IIMIM nn m in 6d iun,pns

mrnn no'iiM no in c nn • not no (-si •nmrio,) rnrt - nn z rnt z

- SI 0

rz'o rs ffl B't r/'/ ro'9 rinn-niz rne ZB arts nm'/ni nno >si nno-9ni

S'M 01 «C 1 «/ Z <;> 9 rs z

.O'O/BI o-onzt n'n/is n'nnzni .n'nn/oz .O'onioi uoj| rns'9 ns'i n nz z rt'6 rnt s mil v r nt'z

IT IS 9 ft Z-SI s tz B / rnn'irz no nnz nn niz no nn r«» Z9 rim 99

rmz-fz ns > nrr IIH » rm/ n nn9 9 nn i r / iirz

n nn/t n nn n sts n n/ni •'.o'on/» in'iins^., uniniuniy

ns r<\ np /z sz /z sz zi-oi :(u) iiidin f.n/(,//i.ii MiA,;/(,n f,n/Ki/ni fin/vn/m 'OHinv; MVO zo sin us nzi n/n ir. /I n,-n ir. /n n/n IK /n ',,'n IP, m s.-n us :Hnnv'nii II.IHVS HI') >IIH r.l'i AHU III'' UIH /I" IIIH .'I') MIH ll'i MIH ^HIHHON IIVI

•Mi"; uni |r.im|jn-| ,i|i|ni<.r)|

s|r|.-iH |r|ii| r|r(| fiiiunn |in<; .n.ir|.nni|m;

|P.1»<") i'l a Ml'I

TOO NLT 001 2152 labli- I/ (iiiii'l)

Siilmirl

Njnolili' lurpuriliuii

(All NIIHUIH: MM! I, I'l Hill I.IU HIIK Mil MIIK 1,-l'J HIIK l.'.U iAMI'Ll IUCAIIUN: ill or, 04 siinr, ()/ sii u in D- Ml II111 Illl Ml (Jill li> DAIl SAMPUU: IO/OS/U9 IU/O'j/09 1 0/1)9/1)9 lll/U'l/U'J III/OS/U9 Ulflll (11): 10 12 2'j 21 10 12 3U V SU-S2

IIKWCAHllS l»J/ky)

A 1 am > nun UO'jO.O* lu/0.0* j/bO.OI.I /S'JU.UIJ Jbl.OIJ

Aiilimuny J.UIIII.I /.III

Arsenic 1.911 l.bll b 2UJ 4.0. 4.2 liar ium II.2III.I IO.SIIIJ 11.4 I.IU

Utfiyl 1 ium 0/91) - O.,,4i. U. b'Jh U.WU

Cadmium O.H/II

Calnum 2bU.OUJ 3U.OU.I b4.JIU ;/ 4iiJ

(In on ium 19 1 Ih.S II / 14.9 J.7

Cobalt 1. 91) 2. ll| U.b/ll

Cupper U.1J B.OJ 2./II J./U

Iruii I4J.OO.O* 12000.0* ()U/0.0 I//UU.U 1090.0 load 5.7J 4.1.1 I/.) l.i I.I

Haynesium I!>/.OIUJ 204.0UI.I 119 UUJ 91 JUJ /.JU

Hamjanese U.2J 2. Ml b.OJ 0.131)

Mercury

Nukcl 2.IIII.I 2.bll.l

PoliiSlum Jb/.OII S9I.OII 29 J. Oil 412.OU bl.bll

Selenium

Silvvr

SuU 1 urn 31 411 40. .'II //'j.UII /IIII.U bl.i

VantUdium 20. 4 J 2'j./,l /ill / 911 l.btl

Unc. 1.2 J.I NLT 001 2153

Lllllr I.' (L.lllt'd)

Siiliiurlaiv boil llui uiij Data luljl

Naiciilili* Corporal ion bile

I All NMWIII: NtlAK Illl HIIAU il-l Mill nl,' Mill nl.) MIW 4IU SAMPll IDlAllUN: ill fl^S Ub Ml UV, I)/ Ml ll'iS Ob Sll UV, 07 Sll Ui.S Ob IIAIt SAHPLtD: III/IU/H9 111/10/89 1)1 PIII ((I): Ib I/ Ib I/ 2b 27 III 20

INUHCANICS (my/liy)

X, Alum mm 3V.bO.Ul.) Vbb.UIJ 2H/U.UU ///O.UU IUJO.OO

An I imony

Arseim. J 2 2.7

Barium b . bllJ 1 211 j . 7UII b.lUU 1 . 4011

llvryl 1 ium U . bllll O.b/l)

Ljdmium

Calcium bU.7UJ 14.91) 2U.2UII 2U.9UU U.bO

Lhromium 12.7 21.4 12 10 2I.VU.I IU..UU.I

Cuba It U.bll

Cupper 3.JII I.UU 4 4UII 17. IU 4.IU

Iron 9UUU.O IU4UUU.O 'JIIIU.UII I4IOU.UU /bbU.OU'

Lead J.I l.b 4.IU 4.7U 1.10* Miynesium 137. OUJ 8.91) U0.2UU

Manuinese 2. 411 1 . UUII 1 . 4UII 2.bOII

Mercury

Nickel 2.2UII

Pulasstum 326. (IU 3lb HUH bb/.UUII 209. UUII

Selenium

Silver I.4UII

Sodium Ib 2U 6 Ull 27. IUII lib. 'JUII

\Unadium 9.bll Itt.U H JUII I..' 7ull IU.IUU

7. me b.4U Ib.bll J.2UIIJ Ijlll.' \l (Mill I'll) NLT 001 2154 biilisurlaiv Soil Um IIKJ lljtj • liil.il Mrl.il'.

lUsiulite lurpufil iun bill!

I All WIHIMK Hl>» I,'In Hill hi!.' Hill i.ill Mill Ml', Hll< i.ill, SAMI'll IWAIIUN: Ml Hi,', 09 Ml /'. il,1 Ml O/i in, Ml inr, In, Ml Ilir, li'l (Mil SAMI'UU; ll'l/?li/IM U'r/7/rt'l tt'l/'/l/U'l U'l/.'/XUV U'J/?'/U9 infill (II): 3b j; j 'j n i<3 w n 3b-j/ IMOKUAMIIS (mj/kij)

Aluminum 3t>bO.OO 2b/O.OU II4U.OU I GUI) 00 AnliMuny

Ar si'ii ic

tin tun 4. bull U.SUII I . /OH 4. /UU

Ucryll i urn

CiOmium U . bill!

tllcium 4/.4UU Ib.ZUII 94.UUU 49.90B

Chrumium 24.8UJ' IO.bU.1* 7.70* B.IO I2.IOJ Cuball o.nu

Cupper II.90J b.bU J.4UII 2.00U 3 . bUU

Iron IbOOO.UU* OHO. 00' bJbO.OO' 7190.00 8100.00

b.bO* IU.JU" |.?u« 1.00 2. Ill) 9b.VUUJ bl.bUlU 14. BUD ro.iuii J4.20U

Hinganese 2.IOU 6. 10 2.4011 2 UOU I.7UU

Mercury

Nickel

PoUssiuin bU.UOII I3II.UOIIU I24.0UII 2UI.OOK JUb.OOU Selenium Silver Sudium : : 34.bOU

11. OU 10 MO b.bOll U.OOII I'J 00

ttnt /./UIU J.'JOlt.l 4.tiOII.I 3.'JU 2./OU 001 2155 I.'

Sulmirlaii! bull HIII mi) ll.ilj

Mastolite tur|iural IUM Sile

(All NUMIIIII: Hilt ii09 Mlh lil II Mil* 1,10 MIIT lil/ SAMI'U MICA) ION: bll-0'IS Ob Ml II'IS 119 SM HIS II') Ml ins nil DAM SAHPIIU: 0'I/2B/U9 O'J/.'H/U'J HI/llb/U9 IH/OS/U9 Ull'lll (11): IS I/ .IS »/ 30 3.'

INUKliANICS (wj/ku.)

Aluminum 2SbO.UO 3/iiO.OO 3//0.0* 12111. 0'

An I inuny

Arsenic 3.b 1 III!

Uarium 2 . /OU 4 . 4011 I2.bll|j 1,' <•«(,!

Beryllium II 3311

Cadmium

Calcium 311. 9011 211.0011 IUO.OII.I IOU.OIIJ

Chromium !2.bOJ / bO •11. b 411. B

Cuba It 2.911 1, 311

Cooper 3.0011 10.1,1 M.4,1

Iron 10300.00 6010.00 IblOO.O* 43100.0*

Lead 3.00 I./O ' 4 . b,l MJ

Magnesium 40.201) 49.90U I04.0UIJ Ib/.OULJ

Hanyanete MOU 700 4.b J.bll

Mercury 0.32J

Nickel 2 . OIIJ 3. OIIJ

Potassium 30b.OOU 293.0011 SUO.OII b9b.OU

Selenium

Si Iver

Sudium llb.OOU /H.OII 4/.IU

Vanadium 7 401) 9.40U 9 auj 23. IJ

/mi 4.40 10.10,' 411,1 II M I ..III,- I.' (lOlll'il) NLT 001 2156

Sulnurlacc bull Bin IIM| H.ilj loUl

Nasiuliti* Corporal inn Silt*

I All IIIIHIHK: Milt 1.11, HI'.AM II,' HIlAII III HIlAII 114 Hilt I.I I HIIY Ii44 SAMI'll I III Al ION: Ml II'. II.' Ml I/I. Hi! Ml I.". ll Ml I.". I!/ Ml I r, (I'j Mil r. mi IIAIl SAMPIIU: III/UO/U9 I'l/IU/U'J lll/lll/ll'J 'III/HI/119 IU/IIII/U9 HI/III,/1)9 UlCIII (It): J !> J !i IU I.' <"., .'/ IS II 70 .'/

INORGANICS

A 1 um i nun JuViO.O* J'jUU (11,1 31/u lll.l /HiU.UlJ I'JIO.U1 l//0:0«

Antimony

Arsenic 1 III U.IIMI /III /.Jill 1 .Oil 1.411

Barium IS.IMIJ 1 1. Mil.) 'j III.) li./ll.l 2. Hill .1 2.4BI

Beryl 1 ium O.bll U.i, -I u./ll

Cjdmium

Calcium b/.'JIIJ Mb.OUJ IJb.Oll.l SJ.UOUJ I/.BU 10.011

Chromium J.7 vij u.; i/./ 13.0 10. B

Cuba It 2 HI) 0.b4B LIB 2.IU I.9B

Copper 3.MIJ I.9B 2.4II b Oil 4 . 7IIJ 3.6BJ

Iron 3blO.O" 4I40.0 S9/II 0 Ib200.0 I2000.b* /92U.O*

lead 3.7J 2.3 4.9 b.2 2.IJ I.BJ

Hague stum 2IO.OBU 23H.OBJ 7U.IBJ UJ.4UJ 47.IUU S0.4UU

Manganese B.BJ 2B.2 4.0J 3. II) l.ul I.3B

Mercury -

Nickel S.6BJ I.9BU I.7UJ

Potassium 1/2. OH 9U.2U 2UI.UII J4I.OB 2JO.OU 211. Oil

Selenium

Silver

Sodium 2b.OB 11. /U 44 /U 1/3. (IB 2'J.tB 14. 2B

Vanadlom / . JB.I b./ll 10.111 11.1)11 9. JIM 24.9.1

Zinc ID. 7.1 J KM 2 UIIJ UulH U (cunfd) NLT 001 2157 billliiii Nitf Soil llm lii-i lUla lutjl Mi>Ul>,

Ndiiulllf Cui pin al lull Sill*

I All NUHUIK: HIIAK I'I MlllAK ."> MIIAK .'I MIIAK .'.' MilAH 1 1 bAMI'UII IUTAIIUN: Ml IHII 114 Ml ll.'ll Of Ml lllll ".' Ml Dill 114. Ml (MM II.' OAll SAmil): III/I7/B9 IU/I2/U9 IO/12/U'l ID/I//'JU IU/II/II9 ULPIII (It): 10 3b 3 b III 12 3 S

INOHtiANICS

AllMIIM 3V4..U ll'jU.U UU9U.U <"jbU.U l/(,U.Ol.l

Antimony •

Arsenic i.ju i in j < .1 ;•

Uiriun 4.SH 4.JII ll.'jll j.dll V . DIM

Beryl Him 0 bll

Cadmium

Cilciim 46 6U 24 UH I'JU Oil /I Ml bU./UJ

Chromium 6.0 3.3 IB.i Ib 4 I.UIIJ

tuba) I l.lll

Cooper 2.0U - 2.

Iron 46UU.O • I2uu0 U IUIUU.U bill 0

tejd i.?S i.b IJ.'Ji 4./S 4.b Haynesium 46.311 72. 3D IbS Oil 74. Ill 141. OUJ Hanginses S.S 9.6 S.O 2./ 4.6J

Mercury •

Nickel lull I./U l.bll (.HI . PoUsslua IUV.UU 206. UU /2.U Selenium

Silver

Sod i urn l« "I 2.911 J0.2U )u bll / 311 Vjmdium '.9U I.4U Jit, IU.9II.UII I /inc 1 411 I.9H / 4 r S /I (o t n , » mi; nt r IK » n frz iis'fl no r •inipniFA r nn nz nt ro n , q iif.ii nn / wnipos

fin Oil 116 Ik «tn|??rioj nri HI z

nft-z rn HO z nt r/'» n9 <>/ fli'% riM9R rno/ti rns-s/ •nifaufirH T/'Z 591 /'H SO fll SIB P'»1 o'orni n noil n nnM o'or/i o'szv unj| <;•/ n/'z nrz

9 t / r 8'6 ro ? rs'Z n/'no nn %» izv<; niz'qi rnr.o z> •nO|fl

HnmipFi nn'.'o nf,r. o nr<; o 1 (10 > urn i mi n rim / CUB i •nij»fl ni/ o HI") r r IK i

no'oro no or.nt no o//e •Mill I wn |V

i\ ni / •, j-i in / s i T> (11) ma in 11VII MI//i/ni1 MI//I. m MI/I i.'ni fin/ii/n1i f,n/n/oi MI iioo H ; in ii'in ii'. in ii'.ii n', in ii'.n ii . rn inn us I MMVS I.,' IIVIIH II/ HV.IH M IIIMM M IIVHH ,'I IIVIIM MIIIHOH IIVI Table 13

£UMMA=iY OF HUMAN EXPOSURE PATHWAYS NASCCLITE CORPORATION SiTE

PATHWAY SURE FCTE.V FCTE\T;A_ CGMFLETEN EXPOS'. RECEPTORS RE.MAF.KS

r.ra.2'cr: c* vca:e ccru-r:i-ar:t£ released Yes r.ear-sjrace sc.:s.

j lr..~.a:et:cr. cf vcic!:ie F_:jr= Site Us=: ccr:a.—irar.ts :=:=as=c Exccs^re tc cc.-si^cticn Yes frcir, excavated s-rr'ace =r,c SUt-SLffeCS SCliS.

Inhaiaticn cftLCJtr^e Future Site Use: dus: frcrr, excavated SLrface Excess tc ccrsvucticn Yes and sut-surfacssciis. • wcrkers.

Cer-a! contact and Current S.te Use: incidental incesticr cf Expcs'jre tc trespsssers. Yes ccntan-.inatsd surface sciis. Future Sire Use:' (C-2 feet) Exccsure tc trespassers. Yes

Dermal ccnta-ct and incidental FutLire Site Use: incesticn of ccntamir.ated Expcsure tc ccr.srjcticn Yes excavated surface and sufcs^rfaca workers. scii.

o o

cn vo Table 14 Contaminants of Concern

Contaminants of Concern in Surface Coil (0-2 Ft)

fi.lc1 5'le Ciii^lCH I'e9.er.cy tl le«(e Contaminants of Concern in Burfaee and Cubsurface Boll (0-52 Ft) Detect ion lleok |e<-ti)-...nil <»,/..) l,,.;/l) ("9/1 i 1

I'll: D'iJiKS n •„ •>,.,t;M'«.^f 7"7 47-7«.onn NR «1'1 ciUHirAi Prefviency af le^e Field Site Detection II. "k lerkfroiixd

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CllfHIOl ol lenoe k'M VJO-'.tOO HO HI ?.t-Ul»Hhylp*ie>»'l • lend lecli|r»mlithel •*"' ft (U,/.,) .* H»lltyln4|^l>>el»ne 0/1.4 vni-M.nno » "• 11/1.4 I.'II-S.IOO HO HI |li««lhylplilhet ele 71/fci 4; 7».nr-n HO «111 0. n t..l/11-Mliel*" VOI'MIU MMMICS |i|l/ll»>ilyl|.hlhelel> 14/b4 MO tl.CKMl DO <311 7H/M 76-4W.OOO HO «.lll Helhyl Hethecryl ete T/'n \-i.un 5 Ol rt t> I /(phtltel Hi e It ictiloi o«lhe«t« 7/'n i- u »n «l 1 Henirne l/1\ 1 I.IWIO 1 • i * l»iiiir.iHir', lelrechloroethene 2/AO t 1? 7 • C 1 Her .... 7/M 1-7,0110 NH .0 loluen* 44/64 fl.t-Jtl.o ir t „, llhylb«nl*n« I/V) J 67.01)0 NO nil 1,.., ••-'»« o.i-,.-., ,t HI Mylenef ( lol el 1 4/V) 1IKI 1.M10 HI) *-•»' «.> o inirm i,-| „ 1 f>4t| 6-.f.i 0 •>(. II' .TO <, t ,, „ NO: N>ii Oeterleil ll>: Not lf|xii i»J HII : s,ti p*.* i - i

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0912 100 J.7N risks associated with lead were assessed qualitatively due to a lack of EPA-verified toxicity values. The reference doses for the COCs at the Nascolite site are presented in Table 15. Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from contaminated soil) are compared with the RfD to derive the hazard quotient for the contaminant in the particular media. The hazard index is obtained by adding the hazard quotients for all contaminants across all media. A El greater than 1 indicates that the potential exists for non- carcinogenic health effects to occur as a result cf site-related exposures. The HI provides a useful reference point for gauging the potential significance of multiple contaminant exposures within a single medium or across media. His were calculated for the exposure scenarios assessed and are presented in Table 16. Since these Els are less than 1, non-carcinogenic adverse health effects are unlikely for contaminants that were quantitatively assessed for all exposures routes considered. Potential carcinogenic risks were evaluated using the cancer potency factors developed by EFA for the compounds cf concern. Cancer slope factors (SFs) have been developed by EFA's Carcinogenic Risk Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. SFs, which are expressed in units cf (mg/kg/day): , are multiplied by the estimated intake of a potential carcinogen, in Kg/kg/day, tc generate an upper-bound exposure tc the ccr.pound at that intake level. The term "upper bound" reflects the conservative estimate of the risks calculated frcn the SF. Use of this approach makes the underestimation cf the risk highly unlikely. The SFs for the COCs are presented in Tables 17. Fcr known or suspected carcinogens, E?A considers excess upper bound individual lifetime cancer risks of between 10"4 to 10"* to be acceptable. This level indicates that an individual has not greater than a one in ten thousand to one in a million chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year period under specific exposure conditions at the site. The potential cancer risks associated with the site are presented in Table 13. The greatest potential cancer risk for the site was calculated for a trespasser under current and/or future land-use conditions. The maximum cancer risk for an adult trespasser from surface soil is 2.38 x 1CT. In surjnary, the quantitative risk characterization suggests no unacceptable non-carcinogenic or carcinogenic risks under current or future land-use conditions for contaminants of concern quantitatively evaluated. Note that the calculated non-carcinogenic and carcinogenic risks do not include the potential current and future risks posed by lead contamination since EPA verified toxicity values are not available to quantitatively assess lead exposure. Exposure to

to oral I'D Table 15 Non-Cancer Toxicity Values r.r-.c-] («) Soc-c. (tl

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tnc.-«s«^;ai Carc»- But EitiBatc Nasislit* Cs-pc.-ation Sit»

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•• Sep'ese-.ts n:r.-ispl icaC;« e»3cs»r« roclss.

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ro M O> Ul TABLE 19 CAPITAL COSTS. OPERATION AND MAINTENANCE COSTS. AND PRESENT WORTH COSTS

Annual Capital Operation & Present Cost Maintenance Worth Alternat ive (SI No Action

Soil Washing 2,627,000 2,627,000

Stabilization/ 1,790,000 31,000 2,273,000 Solidification

o o EPA WORK ASSIGNMENT NUMBER: 044-2LC6 EPA CONTRACT NUMBER: 68-W8-0110 EBASCO SERVICES INCORPORATED ARCS II PROGRAM

FINAL RESPONSIVENESS SUMMARY FOR THE NASCOLITE CORPORATION SITE MILLVILLE, CUMBERLAND COUNTY NEW JERSEY

JUNE 1991

NOTICE The information in this document has been funded by the United States Environmental Protection Agency (USEPA) under ARCS II a Contract No. 68-W8-0110 to Ebasco Services Incorporated r (Ebasco). This document has been formally released by Ebasco to EPA. This document does not represent; however, the USEPA 0 position or policy, and has not been formally released by the ° USEPA. to i-1 4412K -» TABLE OF CONTENTS

Ease. Introduction 1 I. Responsiveness Summary Overview 3 Public Meeting and Site History 3 II. Background and Community Involvement and Concerns 6 III. Summary of Major Questions and Comments Received During the Public Comment Period and EPA Responses to Those Comments 8 A. Verbal Comments Received at the Public Meeting 8 B. Written Comments Received During the Comment 13 Period Estimated Costs Table 1 Alternative 2 Table 2 Alternative 3 Table 3 Combined Alternative

LIST OF APPENDICES

Appendix A: Public Meeting Agenda Appendix B: Superfund Proposed Plan Appendix C: Public Meeting Sign-In Street

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10 *• 4412K FINAL RESPONS IVENESS SUMMARY NASCOLITE CORPORATION SITE MILLVILLE, CUMBERLAND COUNTY, NEW JERSEY

INTRODUCTION This Responsiveness Summary provides a summary of the public's comments and concerns and the U.S. Environmental Protection Agency's (EPA's) response to those comments regarding the Proposed Plan for the Nascolite Corporation site. At the time of the public comment period, EPA had selected a preferred alternative for the cleanup of contaminated soil at the site. EPA held a public comment period from March 1, 1991 through April 15, 1991 to provide interested parties with the opportunity to comment on the Proposed Plan for the Nascolite site. The required comment period would have closed on March 31/ 1991; however, at the request of the Potentially Responsible Parties (PRPs), EPA extended the comment period an additional 15 days. EPA held a public information meeting to present EPA's Preferred Remedial Alternative for controlling soil contamination at the Nascolite site. The meeting was held at the Millville Municipal Building, Millville, New Jersey on March 14, 1991 at 7:00 p.m. Judging from the comments received during the public comment period, the residents and Town Council of Millville, and the New Jersey Department of Environmental Protection (NJDEP) were responsive to the Proposed Plan and would support the preferred alternative for the cleanup of contaminated soils. No objections to the Proposed Plan or preferred alternatives were raised at the public meeting. A responsiveness summary is required for the purpose of providing the public with a summary of citizens comments and concerns about the site raised during the public comment period and EPA's responses to those concerns. All comments summarized in this document will be considered in EPA's- final decision for selection of the remedial alternative for cleanup of the site. The responsiveness summary is organized into the following sections: I. Responsiveness Summary Overview. This section briefly describes the public meeting held on March 14, 1991 and includes historical information about the Nascolite Corporation site along with the proposed remedial alternatives to clean up the site. II. Background on Community Involvement and Concerns. This section provides a brief history of community interest and concerns regarding the Nascolite Corporation site.

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4412K III. Summary of Major Questions and Comments Received During the Public Comment Period and EPA's Responses to Comments. This section summarizes verbal and written comments submitted to EPA at the public meeting and during the public comment period and provides EPA's responses to these comments. Attached to this responsiveness summary are three appendices: Appendix A is EPA's agenda for the public meeting; Appendix B is EPA's Proposed Plan for the Nascolite Corporation site; and Appendix C is the public meeting sign-in sheet.

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to -J o 4412K I. RESPONSIVENESS SUMMARY OVERVIEW

A. Public Meeting and Site History The public meeting for the Nascolite Corporation site began at approximately 7:30 p.m. on March 14, 1991 at the Millviiie Municipal Building, Millviiie, 'New Jersey. The meeting started with presentations by EPA and was followed by a question and answer session. The meeting was attended by approximately 15 residents and local officials. Nicoletta DiForte, Chief, Northern New Jersey Superfund Section; Farnaz Saghafi, Remedial Project Manager; and Steve Katz, Region II Community Relations Coordinator represented EPA at the meeting. EPA contractor personnel included Gerry Zanzalari, Community Relations Manager, and Gerry Pfeffer, Community Relations Specialist of Ebasco Services Incorporated. Mr. Katz opened the meeting and explained that the purpose of the meeting was to present and discuss the Proposed Plan for the cleanup of soils and wetlands at the Nascolite Corporation site. The public was encouraged to engage EPA in a two-way dialogue regarding the Proposed Plan and EPA's Preferred Alternative for cleaning up the site for inclusion into EPA's final Record of Decision (ROD) for the Nascolite Corporation site. The audience was informed that EPA would be accepting public comments on the site until March 31, 1991, and that affected community groups may be eligible to receive up to $50,000 in federal funds through EPA's Technical Assistance Grant (TAG) Program to hire a technical consultant to aid in interpreting technical, site-related documents. Mr. Katz then introduced Ms. Nicoletta DiForte. Ms. DiForte presented an overview of the Superfund Program and explained how sites get placed on EPA's National Priorities List (NPL) of hazardous waste sites. Placement on the NPL makes a site eligible for federal funding for site remediation. She explained that the Superfund Program was established in 1980 as an outgrowth . of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). It was emphasized that the PRPs are encouraged to assume responsibility for site cleanup but are not required to. EPA, through the Superfund Program, funds the project initially then attempts to recover funds expended through settlement discussions or litigation with the PRPs. Ms. DiForte explained that the initial phase of site work is called a Remedial Investigation (RI). The RI examines the nature and extent of contamination at a site by analyzing samples of soil, surface water, air, sediment, and/or groundwater. Along with the RI, a risk assessment is conducted to. dete-rmine the 2: potential risks posed by the. site to human health and the ^ environment. The information is the basis for a Feasibility o i-o« 3 4412K Study (FS) that provides an engineering analysis of possible alternatives to clean up the site. After the RI/FS, a Proposed Plan describing EPA's Preferred Alternative for cleaning up the site is presented to public for comment. At the conclusion of the public comment period, EPA considers comments it has received and factors them into the final remedy for the site. A Responsiveness Summary presents the public concerns for incorporation into the ROD. When a final decision on a plan of action is reached, EPA issues the ROD containing all technical justification for selecting the chosen alternative. Following the ROD, the remedial design and construction of the site remedy are initiated. After design and construction, there is a period of operation and maintenance (or closure) to ensure that the remedy is in place and working properly. After her presentation, Ms. DiForte introduced Ms. Farnaz Saghafi. Ms. Saghafi provided a brief history of the site and a description of past investigative activities .conducted at the site. The Nascolite Corporation site is situated on the municipal border line of the Cities of Millville ,and Vineland, Cumberland County, New Jersey. The area surrounding the site is zoned for both residential and industrial use. From 1953 to 1980, the Nascolite Corporation manufactured polymethyl methacrylate (poly MMA) plastic sheets, commonly known as acrylic, Plexiglass or lucite. Waste residues from various distillation processes were stored in several buried tanks in the area north of the main plant. Wastewater streams from the manufacturing process and other on-site sources were discharged to a ditch which flows into the wetland area, southwest of the plant, along and parallel to Conrail tracks. The site was placed on the NPL in September 1983. In 1986, an RI/FS was completed by NJDEP in order to define the nature and extent of contamination at the site and to develop and evaluate alternatives to determine the most appropriate remedial action •for the site. In summary, the findings revealed that the groundwater is contaminated with MMA, and the soils are contaminated with volatile, semi-volatile and inorganic compounds (lead in particular). The Nascolite site has since been divided into two operable units: the first operable unit addresses groundwater and the second operable unit addresses other contaminated source areas, such as buildings, soil and debris. A ROD was issued for the First Operable Unit (FOU) in March 1988. The Second Operable Unit (SOU) addresses contaminated on-site and wetland soil. Although buildings and debris are not believed to be a source of soil and groundwater contamination, they do pose a number of g worker health and safety hazards and may obstruct conduct of work ^ at the site. Therefore, a strategy for building demolition and debris management was also included in the proposed remedy. o Moreover, on-site buildings are a source of asbestos 2 contamination. K) M 4 " 4412K Contaminated soil poses the principal threat at the site, particularly in the area north of the manufacturing building an9 in the northern section of the wetlands. Concentrations of lead in the soil exceed EPA's recommended cleanup range of 500 to 1,000 parts per million (ppm) as per the Office of Solid Waste and Emergency Response (OSWER) Directive #9355.4-02 for industrial properties. This guidance has been set forth for total lead by the Office of Emergency and Remedial Response (OERR) and the Office of Waste Programs Enforcement (OWPE). Lead \ levels as high as 41,800 ppm have been detected in soil at the site. Currently, approximately 8,000 cubic yards of soil exceed the remediation goal of 500 ppm. MMA was detected in soil but in concentrations which were below health-based levels. Soils were also sampled for volatile organic compounds (VOCs) and semi volatile organic compounds (semi-VOCs), and the detected levels were also below health-based action levels with the exception of two areas: one in the North Plant area and another in the wetlands. The concentrations of semi-VOCs in these two areas were 630 ppm and 450 ppm, respectively. These levels exceed NJDEPs' interim soil action level of 10 ppm for semi-VOCs. The response action described in the proposed plan addressed soil contamination at the site and is the final action contemplated for the Nascolite Corporation site.

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4412K II. BACKGROUND AND COMMUNITY INVOLVEMENT AND CONCERNS In the late 1970 's, the residents of Millville notified municipal and county officials about a strong sulfur odor in the vicinity of the Nascolite site. In response to complaints made to the Cumberland County Department of Health, NJDEP sent field investigators to identify the source of the odor. These investigations determined that the Nascolite Corporation was the source of the odor. Subsequently, NJDEP implemented measures to stop the odor-producing industrial practices at Nascolite, which resulted in immediate odor reductions. Newspaper articles reported the listing of Nascolite on the NPL in September 1983. Little community involvement followed this announcement until a public meeting was held by NJDEP on August 18, 1986. The meeting presented results of the RI/FS and information concerning the preferred remedy. Informational materials related to the Nascolite RI/FS activities were also distributed to the public at this time. The preferred remedy presented at the meeting addressed contaminated soils and their removal and transportation to a landfill. Subsequent to this, the Superfund Amendments and Reauthorization Act of 1986 (SARA) was passed, which recommended more permanent remedial measures. Consequently, it was necessary to reevaluate the proposed alternatives at the Nascolite site. A second public meeting was held on March 7, 1988 by EPA to present the new preferred clean-up alternative and to explain progress at the site since the last public meeting. This public meeting was held before issuance of the ROD. At the meeting, local citizens residing along Doris Avenue expressed concerns about the potential for groundwater contaminants to affect their drinking water. In response to these concerns, EPA included a provision for the design and construction of a waterline extension to residences on Doris Avenue. A public availability session was held by EPA on January 26, 1988 at the outset of the waterline extension project. Also discussed at this session were the upcoming Supplemental RI/FS to investigate potential soil contamination and the .general physical condition of the site. EPA solicited public concerns, which primarily focused on contaminant migration via grcundwater, the schedule for remedial activities, potential negative impacts of site remediation on property values, and any future plans to sample private wells. EPA held a third public meeting on March 14, 1991. Findings of the Supplemental RI/FS were presented at the meeting. Also presented was EPA's Proposed Plan for remediation of contaminated soils and wetlands at the Nascolite site, included herein as Appendix B. o o

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4412K The residents most concerned with contamination at the Nascolite site are those living on Doris Avenue. Their primary concern is the potential for groundwater contamination and the potential impacts site-related contamination may have on their health. Other Millville residents have expressed concern over a variety of issues and wish to be informed of all EPA findings at the site. Based on community interviews and other public input, the following community concerns have been identified for the Nascolite Corporation site: groundwater contamination; potential public health risks; extent of contamination; clean-up schedule; site security; remedial construction-related impacts; and information dissemination.

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N) 7 • • '• . 5 4412K "i III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THOSE COMMENTS A. Verbal Comments Received at the Public Meeting Issues and questions raised at the March 14, 1991 public meeting on the Nascolite site are summarized below and are organized into the following categories: 1. " Cleanup Funding and Schedule 2. Site History and Conditions 3. Contaminants 4. PRP Issues 5. Technical Issues/Other Concerns 1. CLEANUP FUNDING AND SCHEDULE a. COMMENT: A resident inquired about who has assumed financial responsibility for remedial activities performed at the Nascolite site. EPA RESPONSE: Financial responsibility for the initial site investigations performed between 1980 and 1983 was assumed by the Nascolite Corporation. Following the site's listing on the NPL in August 1983, EPA and NJDEP cooperatively conducted site activities, with funding provided by the federal Superfund program. In 1988, EPA assumed responsibility for cleanup of the Nascolite site, with continued funding from Superfund. Following the release of the EPA Record of Decision addressing groundwater contamination at the site, negotiations were initiated with the PRPs regarding funding of the groundwater treatment system design work. Two of the parties funded a public waterline extension onto Doris Avenue and are currently assuming financial responsibility for the design phase of the groundwater remediation. Similar negotiations will, be initiated with the PRPs following release of the ROD for the second Operable Unit, dealing with soil contamination and on-site structures. b. COMMENT: A resident expressed concern that cleanup remedies are still being evaluated nearly 11 years after the initial site investigations conducted by NJDEP. EPA RESPONSE: EPA shares the concern of residents regarding the time required to complete remediation of the Nascolite site. However, the Nascolite site presents a challenging and complex set of contaminants and conditions ^ for which no simple remedial technology would be t? appropriate or effective. While data is being collected and analyzed to help select an appropriate remedy, removal 0 actions have been conducted by EPA to address immediate o health risks associated with the site. In addition, other to M 8 <* 4412K requirements built into the Su-perfund program, such as PRP negotiations and enforcement procedures, potentially serve to lengthen the overall remediation process. c. COMMENT: A resident asked when actual site remediation work on soil contamination would begin. EPA RESPONSE: Following the release of the ROD which formalizes the selection of the remedial alternative for the Nascolite site, negotiations with the PRPs will begin as mandated by the Special Notice Procedure section of Superfund legislation. This procedure allows for a 120 day period for EPA and the PRPs to reach a settlement regarding responsibility for cleanup costs. This period would be followed by the remedial design phase and equipment mobilization, after which site work can actually begin. EPA estimates that the entire process may take between 12 and 18 months following issuance of the ROD.

2. SITE HISTORY AND CONDITIONS a. COMMENT: A resident asked about the reasons for shutdown of manufacturing operations at the Nascolite site in 1980. EPA RESPONSE: EPA was not involved with the Nascolite site at that time. However, site closure was not due to violations or consequent enforcement actions by state or local authorities. NJDEP initiated site investigations at the site in 1981 in response to reports of acrid odors emanating from the plant. Following a preliminary site assessment, NJDEP entered into an Administrative Consent Order (AGO) with Nascolite regarding further site investigations and sampling activities. b. COMMENT: A resident asked if the site currently represents a risk to the health of area residents. EPA RESPONSE: There are potential health risks associated with conditions at the Nascolite site,, but these risks .focus primarily on direct human contact with site contaminants, e.g., lead-contaminated surface soils, or contact with physical hazards existing on-site, e.g., dilapidated buildings and structures. A fence has been erected around the site to restrict unauthorized access; however, this measure has not completely secured the site from" trespassers and vandals. c. COMMENT: A resident related instances of trespassing on the site property and expressed concern that site security measures were inadequate. "

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4412K EPA RESPONSE: EPA has no evidence of squatters on the site, as reported by some residents, although some evidence of unauthorized access has been observed on the site. Security measures will be reviewed to ensure that such unauthorized access is minimized. This will include contacting local law enforcement authorities regarding increased patrols in the area. d. COMMENT: A resident asked if, based on available information, it is safe for anyone to live inside the fence-enclosed manufacturing area of the Nascolite site. EPA RESPONSE: Based on the results of the Risk Assessment performed for the site, individuals residing within the fenced area could be exposed to site contaminants through direct contact with soil or building debris and would therefore be at some risk. However, EPA is not aware of anyone residing in this area.

3 . CONTAMINANTS a. COMMENT: A resident asked if surface soil contamination may have migrated off-site through rainwater runoff. EPA RESPONSE: EPA conducted a removal action in 1987 during which a plastic tarpaulin was placed over an area of lead-contaminated surface soils. An additional tarp was subsequently placed over this area to further retard contaminant migration. Subsequent sampling conducted during the RI indicated minimal migration of these surface soil contaminants. b. COMMENT: A resident asked if lead was the primary contaminant of concern found on the site. EPA RESPONSE: Elevated levels of lead have been detected in surface soils and in wetland areas adjacent ~to the site. However, various levels of other inorganic contaminants such as cadmium, copper, zinc, mercury and selenium, have also been detected in. surface soils. In addition, MMA contamination has been detected in subsurface soils (between three and 52 feet below grade). Since these subsurface soils come into contact with groundwater underlying the site, MMA contamination in subsurface soils will be addressed in conjunction with groundwater remediation efforts.

4. PRP ISSUES a. COMMENT: A resident asked who the PRPs for the Nascolite site are and what procedures EPA follows to have the PRPs assume financial responsibility for site cleanup. o o

10 !d 4412K » EPA RESPONSE: Ten PRPs have been identified for the Nascolite site. They are as follows: American Cyanamid Company; American Optical Company; CYRO Industries, Incorporated; Dentsply, Incorporated;- E.I. DuPont De Nemours and Company; B. Jadow and Sons, Incorporated; Monsanto Company; Nascolite Corporation; Polycast Technologies Corporation; and Rohm GMBH. Some of these parties have previously, and are currently, funding groundwater remediation activities for the site. EPA intends to pursue all available enforcement procedures to recover costs associated with remediation of the soil contamination as well. These channels will include negotiations with the PRPs regarding cost recovery . settlements. EPA cannot conclusively state what the outcome of these negotiations will be, and, therefore, cannot project what specific enforcement procedures may follow. b. COMMENT: A resident asked how Superfund, monies are generated and appropriated for a given site. EPA RESPONSE: Superfund monies are collected through a tax levied on the chemical and petroleum industries. If these funds are expended at a given site, every effort is made by EPA for reimbursement from the parties identified as potentially responsible for site-related costs. If these efforts are successful, recovered funds go back into the Superfund program.

5. TECHNICAL ISSUES/OTHER CONCERNS a. COMMENT: A resident asked if buried drums were found on the Nascolite site. EPA RESPONSE: No buried drums were found on the Nascolite site during EPA investigations. Drums containing process waste residues were stored above-ground on the northern portion of the site and were removed by EPA in 1987 and 1988. At this, time, underground storage tanks, containing waste materials and located in the same area as the drums, were excavated and removed from the site. b. COMMENT: A resident commented that there have been four EPA project managers assigned to the Nascolite site during the nine years of agency involvement and that such turnover was counter-productive to the timely remediation of the site. EPA RESPONSE: Although the listing of the Nascolite site on the NPL occurred in 1983, EPA first initiated field z; work in 1986. EPA acknowledges that staff attrition has ^ been a problem at the Nascolite site. However, each project manager assigned to the site has been experienced o in these types of hazardous waste remedial projects and 3 their efforts reflect EPA's commitment to a complete and effective remediation of the Nascolite site. to -j 11 « 4412K c. COMMENT: A resident asked for clarification as to how MMA contamination will be addressed. EPA RESPONSE: An explanation of . the technologies evaluated for the Nascolite site « well as a detailed description of the preferred alternative, is presented in Section I of this Responsiveness Summary.

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12 co o 4412K B. Written Comments Received Purina the Comrngmt: Period EPA received the two sets of written comments on the Proposed Plan for the Nascolite site (the site) located in Millville, Cumberland County, New Jersey. These comments are summarized below and EPA responses immediately follow the comment. COMMENT: No scientific or technical rationale was presented in the Proposed Plan or the supporting documentation for the selection of 500 ppm as the cleanup level for lead. EPA RESPONSE: The commentor has correctly indicated that currently there are no available toxicity values for lead. The proposed lead cleanup level of 500 ppm for the site was based on EPA's Office of Solid Waste and Emergency Response (OSWER) Directive #9355.4-02. Currently, this interim directive is applicable. This document sets £he soil lead range as 500-1000 ppm when the land use at the site is characterized as industrial. For sites where risks to young children are quantified, EPA uses the lead Uptake/Biokinetic (UBK) Model to assess total lead exposure and determine soil lead cleanup levels. The draft model by the Society for Environmental Geochemistry and Health referenced and discussed bv the commentor, is not consistent with EPA policy and cannot be used to set a soil lead cleanup level for the Nascolite site. COMMENT: The risk assessment approach as well as the data base for determining concentrations of lead in surface soils for purposes of risk assessment was questioned. EPA RESPONSE: The Superfund program has been designed to protect human health and the environment from current and potential threats from uncontrolled releases or hazardous substances from sites. To achieve this purpose, EPA's Office of Emergency and Remedial Response (OERR) has developed guidance on the human health evaluation process. Tne Risk Assessment Guidance for Superfund (RAGS, EPA/540/1-89), is the guidance document EPA adheres to in developing the human health risk assessment conducted as part of the RI/FS process. The exposure assessment component of the RAGS provides the specific equations and parameters values for common Superfund site exposure pathways. It outlines the revised National Contingency Plan's Reasonable Maximum Exposure 3 (RME) concept under both current and future land-use t? conditions. The RME is defined as the highest exposure that could reasonably be expected to occur at a site. The 0 guidance clearly outlines several of the assumptions that £J should be considered in calculating the RME. Furthermore, to t-» CO 13 i- 4412K the guidance defines the concentration value used to calculate the RME as the 95th upper confidence limit fUCL) on the arithmetic mean concentration contacted—Over the exposure period, rather than the mean itself. The risk assessment completed for the Nascolite site did adhere to the RAGS. The calculation of the C-mean was based on the 95th UCL on tha arithmetic mean. COMMENT: The inclusion of the maximum lead concentration detected on site is inappropriate and misleading, since the contaminated material has been removed. EPA RESPONSE: The Proposed Plan states that 41,800 ppm of lead was the maximum lead concentration detected on-site, not that it is a representative contaminant concentration. Although the material was removed from the site during the 1987 removal action, the possibility of similar lead concentrations existing on-site cannot be ruled out. Lead was detected in high levels, -up to 10,700, ppm throughout the site in the second operable unit RI activities. All levels are clearly presented in the RI report which is part of the administrative record established for the site. COMMENT: On-site or off-site landfilling of lead-contaminated soils was proposed by the commentor as a more effective and implementable remedy than EPA's selected alternative. EPA RESPONSE: Cn-site or off-site disposal of contaminated soils and waste materials would include the removal of contamination from the site and replacement of contaminated soils in an approved landfill. Landfilling site soils, which are characteristic waste as per the Resource Conservation and Recovery Act (RCRA), without appropriate treatment, is prohibited by RCRA. In addition, EPA's preference in the cleanup of contaminated sites is the utilization of permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Since the selected remedy uses treatment to address the principal threats posed by conditions present at the site, it is the preferred choice as opposed to a non-treatment alternative, such as on-site or off-site landfilling. The selected remedy will reduce and control risks posed through the exposure pathways (as identified in the sites's Risk Assessment) to the exposed population through treatment to ensure adequate protection of human health and the environment. No unacceptable short-term risks of cross-media impacts will be caused by implementation of the remedy. Further, the selected remedy

to V-* CD

14 441 will comply with site-specific Applicable or Relevant and Appropriate Requirements (ARARs) and provide overall effectiveness proportionate to its cost, representing a reasonable value. COMMENT: If Solidification/Stabilization is the chosen alternative, certain design and cost considerations should be made.

EPA RESPONSE: a. The Solidification/Stabilization treatment technology will not interfere with the implementation of the FOU groundwater remedy since appropriate coordination will be made between the two treatment options to ensure that the solidified mass will not constitute an impediment to groundwater recirculation in areas where groundwater treatment would be warranted. Further, since the solidified materials would be primarily located in the top 3 feet of the vadose zone, and groundwater is located at least 10 feet below the ground surface, the solidified mass should not interfere with groundwater recirculation. The location of extraction and injection wells must be accurately identified so that excavation of contaminated soil and backfilling of treated soil can be done with caution in these locations. With proper coordination and field techniques, Solidification/Stabilization should not interfere with groundwater remedy. b. Costs for the Solidification/Stabilization treatment were obtained from vendors (Environmental Innovations and Geocon) and include mobilization/demobilization, pilot-scale testing, size separation, treatment processing and Quality Assurance Testing for an estimated unit cost of $37/cy. The cost for a binder was estimated to be $100/ton as taken from the "Handbook for Stabilization/Solidification of Hazardous Waste" EPA/540/2-86/001, June 1986. This was a conservative estimate because the type of binder is not known at this time and will be determined in the remedial design phase of the project. When the estimated treatment cost ($37/cy) and binder costs ($100/ton) are combined, a total unit cost of $58/ton results for Solidification/Stabilization treatment. The 15% volume increase estimated for Solidification/ Stabilization was based on conversations with the vendor (Environmental Innovations), and the use of pozzolanic binders. The 15% value was used due to the presence of sandy soil with high porosity at the site'. A further review of the literature "Superfund Innovative Technology Evaluation Program, November 1989" and discussions with

15 4412K vendors indicate that the likely volume increase would range from 15% to 50%. This range can alternatively be used in the given estimates. The actual volume increase cannot be predicted until the specific binder is selected in the design phase. The actual volume change may not be critical in the calculation of the cleanup cost of the remedy for this site because of the relatively small volume of soil involved (8,000 CY). A volume increase would result in a higher elevation of treated material and may increase backfilling costs slightly. *n addition, it is anticipated that the size of the site will be sufficient to accomodate the estimated volume increase.

c. The Solidification/Stabilization treatment by itself would meet the objective of reducing the potential for contaminated soil migration from the site. Although a soil cover is not included for Solidification/Stabilization treatment, the treatment by itself should be sufficient to reduce the potent'al to ingest, inhale or come in direct contact with lead contaminated scil. A thin, vegetated soil cover may be added for a nominal cost.

COMMENT: The Proposed ^lan and . the supporting documentation does not address the statutory limitations on response provided by Section 104(a)(3)(B) of CERCLA prohibiting removal or remedial action is response to a release or threat of release from products which are a part of the structure of, and result from exposure within residential buildings or community structures. EPA RESPONSE: It is not necessary for EPA to invoke the 104(a)(4) exception to the 104(a)(3)(B) limitation because the limitation does not apply in this instance. The 104(a)(3)(B) limitation addresses removals and remedial actions "within" residential buildings or business or community structures. The propo'sed remedial action will not be taking place within the buildings and structures. Rather, the purpose of selecting demolition and disposal of buildings and debris is to ensure that a safe and adequate soil and groundwater remediation can be carried out. The buildings and debris contain asbestos and therefore must be removed in accordance with all ARARs concerning asbestos. COMMENT: The Proposed Plan is not clear with respect to the demolition and disposal of buildings and debris. EPA RESPONSE: As stated in the description of the selected remedy, asbestos-containing material found in ^ on-site buildings and structures would be removed and the t? structures would then undergo demolition. The rubble and debris would be segregated for disposal according to 0 findings: non-hazardous material would be decontaminated ° and sent for • off-site disposal; and recyclable material to 16 £ 4412K *• would appropriately recycled and hazardous material (determined through sampling) would be transported off-site for appropriate disposal. Non-hazardous building rubble and debris may not undergo solidification/stabilization. COMMENT: On-site storage of soils and debris need not comply with 40 CFR Parts 262, 264 and 265. A site-specific Health and Safety plan would be sufficient in the safe handling of these materials. EPA RESPONSE: Prior to the commencement of field activities and the actual sampling of building rubble and debris, it cannot be determined whether the material constitutes a short-term health and safety hazard to workers and the surrounding environment. Thus it is appropriate to comply with 40 CFR Parts 262, 264 and 265 during on-site storage of rubble, soils and debris until a determination can be made to the contrary. COMMENT: Detailed cost estimates presented in Appendix D of the draft FS did not agree with the Proposed Plan or the text of the draft FS. EPA RESPONSE: The FS was revised after the September 1990 draft version. The final version of the FS is dated February 1991 and was placed in the information repositories established for the site as a part of the Administrative Record. This volume of the FS reflected new costs for the remediation of the second operable unit since a new soil cleanup action level was chosen and the volumes of soil and waste requiring treatment were changed. The new volume estimates and respective - costs were then correctly reported in the Proposed Plan. COMMENT: Community involvement in the RI/FS and Proposed Plan process is confusing since the RI/FS should have been available for public comment prior to the Proposed Plan. EPA RESPONSE: The RI/FS was finalized in February 1991 and has been available for public review in the local repositories since that time. On March 1, 1991, the public comment period officially began and lasted until April 15, 1991. During this period, the public was afforded the opportunity to review and comment orally or in writing on all documents. COMMENT: A detailed cost estimate for each remedial alternative was requested listing all assumptions included in the cost estimate. EFA RESPONSE: See Tables 1, 2 and 3 for a breakdown of costs -3 and respective assumptions as related to each alternative.

10 17 S 4412K COMMENT: A conunentor asked several questions regarding the Solidification/Stabilization technology including: Does the Solidification/Stabilization alternative cost include addressing volatile organics since soil vapor extraction is no longer included in the alternative? Hot spot semi-volatiles were found at the North Plant area at SB-US. What is the selected binder and what was the criteria for selection since there was no treatability study done? EPA RESPONSE: The Solidification/Stabilization cost does not include treatment of volatile organics. While VOC and semi-VOC contamination was detected on the site, EPA investigations have revealed that any risk posed by these contaminants is within EPA-established risks for evaluated exposure pathways. Therefore, EPA has focused its remediation efforts on lead, which has been determined as the contaminant of primary concern at the site., The FS has recommended using pozzolanic materials as binders. This group of binders include fly ash, cement kiln dust, furnace slag and lime. The selection of the pozzolanic group of materials is based on treatment of metals, primarily lead, in sandy soil and is supported by the "Handbook of Remedial Action at Waste Disposal Sites" and the "Survey of Solidification/Stabilization Technology for Hazardous Industrial Wastes. Selection of the specific binder will be made during the design phase of the Nascolite project. At that time, results of the Solidification/Stabilization treatability study, which should address binder selection, will be available. In many cases, Solidification/Stabilization contractors select 'the binder based on a sample obtained from the site and may add their own proprietary reagents. COMMENT: A corranentor requested EPA to specify the volume of soil which will require off-site disposal as well.as the assumptions used for this estimate and the criteria for requiring off-site disposal. EPA RESPONSE: Site soils which may require off-site disposal consist of high organic-content wetlands soils if found to interfere with the Solidification/Stabilization technology and certain areas that may exhibit increased lead concentrations if it is determined that treatment cannot achieve established RCRA standards. However, it is expected that RCRA standards can be achieved for the majority of site soils. At this time it is estimated that. 10% of the excavated material (800 cy)"would require off-site disposal.

00 CM 18 4412K COMMENT: What is the number of soil washings assumed? EPA RESPONSE: The exact number of soil washings required was not specified during the treatability studies. Instead, Biotrol Inc., a soil washing vendor, estimated a processing rate of 20 tons of soil per hour. COMMENT: What are the assumptions regarding the costs of treatment for the liquid waste stream generated? EPA RESPONSE: Liquid waste stream treatment costs are based on the use of precipitation and filtration to remove metals from the liquid wastes. Cost data were based on a flow of 8 gallons per minute and taken from the "Handbook of Remedial Action at Waste Disposal Sites." A low flow rate was assumed because it is assumed that most of the liquid stream can be recycled through the soil washer prior to discharge. COMMENT: What are the assumptions regarding ' placement of the treated soil back onto the site including .addressing any time delays or coordination with the groundwater remediation, particularly, any possible Soil Vapor Extraction (SVE) treatment? EPA RESPONSE: Placement of treated soil back into the area of excavation should not delay or interfere with the groundwater remediation system if SVE were implemented. COMMENT: List any other assumptions used in the development of the soil washing alternative. EPA RESPONSE: The following remaining assumptions were based on results of th Ml washing treatability study conducted by the New Jer - hute of Technology (NJIT) . o Lead and cadmium ' effectively with a v 12% EDTA solution. cV.-> , * o The ratio of -».o<» ^ jn to soil is approximately 10 ^ w-€>S) COMMENT: Based on pre. ions regarding the appropriateness of using the „ . .jad cleanup objective in an industrial setting versus residential setting, this remedial objective can onj.y be endorsed by restrictions being imposed on any future development of the manufacturing facility property. EPA RESPONSE: The lead cleanup level was selected based on ^ the current industrial zoning of the site. EPA has no *-3 information in its possession which indicates that the site ^ may be rezoned for residential use in the future. The 500 0

}->(O 1-, n9 °-°j 4412K ppm cleanup level for lead is in accordance with EPA guidance for lead contaminated soils in an industrial setting, and is an appropriate cleanup level for the Nascolite site. It is the present intention of the EPA to ensure necessary deed restrictions to provide for the effectiveness of the selected remedy at the site.

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20 10 V1 CD CO ESTIMATED COSTS

TMl£ 1

ALTESMATIVE 2: EXCAVATION. SOIL MASKING, BACKFILL EXCAVATION WIT*. TREATS) SOIL

ITEM DESCRIPTION UNITS OUWfTITT UNIT PRICE TOTAL COST S

SITE PREPARATION Clearing acre * S3,800 $15,200 Utilities year 1 $10,000 $10,000 Temporary Facilities lump sun 1 $5,000 $5,000

EARTHWORK Excavation cu. yds. 8,000 S3 $24,000 Sampling During Excavation Imp sun 1 $13,300 S13.300 Backfill (Cameo Fill) cu. yds. 600 $7 $5,600 Backfill (Treated Material) cu. yds. 7,200 $2 $14,400

SOIL WASHING Mobilization/Demobilization lump sun 1 $50,000 $50,000 Pilot-scale Testing lunp sum 1 $150,000 SI50,000 Pre-screening Soil cu. yds. 8,000 $5 $40,000 Treatment Costs (includes ton 10,800 $60 648,000 Equipment Leasing, Power, Labor, Maintenance) Uastewater Treatment luap sum 1 $92,000 $92,000 Solvents (EDTA) Ibs. 10,800 S13 $140,400 Makeup Water 1000 gal 100 $6 $600 QA Testing sample 100 $500 $54,000 OFF-SITE DISPOSAL Transportation (20 ton/trip, mi. 27,000 S3 $81,000 450 Mi ./trip) Disposal ton 1,200 $300 $360.000 HI Baseline Monitoring luap sum $15,000 $15,000 Decor Facilities luap sum $10,000 $10,000 Air Monitoring years $5,000 $5,000

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ALTERNATIVE 2: EXCAVATION. SOIL DASHING. BACKFILL EXCAVATION WITH TREATED SOIL

ITEM DESCRIPTION UNITS CUAHTCT UNIT PRICE TOTAL COST * *

Subtotal - Capital Cost $1.734,000 Legal Fees, License I Permits - 10X of Capital Cost $173,000 Engineering I Administrative - 10% of Capital Cost $173,000 Level C Protection - 25X of Capital Cost for: Excavation, and Soil Washing $308,000 Subtotal $2,388,000 Contingency - Cost Based on 10X of Subtotal $239.000 Total Construction Cost $2,627,000 TOTAL PRESSTT UORTH COST $2,627,000

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ALTBUMTIVE 3: EXCAVATION, SOLIDIFICATION/STABILIZATION, BACKFILL EXCAVATION WITH HEATH) SOIL

ITEM OESOtlPTICM UNITS QUANTITY UNIT PRICE TOTAL COST S *

SITE PREPARATION Clearing acre 4 S3,800 $15,200 Utilities year 1 $10,000 $10,000 Temporary Facilities limp tun 1 $5,000 $5,000

EARTHWORK Excavation cu. yds. 8,000 S3 $24,000 Sampling During Excavation limp sun 1 $13,300 $13,300 Backfill (Cannon Fill) cu. yds. 2,000 S7 $14.000 Backfill (Treatment Material) cu. yds. 8,280 $2 $16,600 ON SITE S/S Mobilization/Demobilization limp sum 1 $30,000 $30,000 Pilot-scale Testing limp sun 1 $60,000 $60,000 Size Separation cu. yds. 8,000 $5 $40,000 Treatment Processing cu. yds. 7,200 S12 $86,400 Reagent (Pozzolan a S63/ton) ton 3,600 S100 $360,000 QA Testing lump sum 1 $50,000 $50,000 OFF-SITE DISPOSAL Transportation (20 ton/trip. Hi. 27,000 S3 $81,000 450 mi./trip) Disposal ton 1,200S300 $360,000 MISCELLANEOUS Baseline Monitoring lump sum 1 $15,000 $15,000 Decon Facilities lump sum 1 $10,000 $10,000 Air Monitoring years 4 $5,000 $20,000

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ALTERNATIVE 3: EXCAVATION. SOLIDIFICATION/STABILIZATION, BAOJILL EXCAVATION UITN TREATS) SOIL

ITBI DESCRIPTION UNITS OUANTOT UNIT PIICE TOTAL COST s s

SITE PREPARATION Subtotal • Capital Cost $1,211,000 Legal Fees. License ft Permits - 10X of Capital Cost $121,000 Engineering I Administrative - 10X of Capital Cost $121,000 Level C Protection - 25X of Costs for: Excavation, and On-site S/S $174.000 Subtotal $1,627.000 Contingency - Cost Based on 10X of Subtotal $163,000 Total Construction Cost $1,5^0,000 Present Worth of Ott Costs , $483,000 TOTAL PRESENT UORTH COST $2,273,000

OPERATION ft MAINTENANCE COSTS

ALTERNATIVE 3: EXCAVATION, SOLIDIFICATION/STABILIZATION, BACKFILL EXCAVATION UITH TREATED SOIL

QUAN- UNIT ANNUAL TIME START PRESENT DESCRIPTION UNITS TITY PIICE * COST * TEARS TEAR UORTN 8

LONG TERM MONITORING Labor (annual) •t-hrs. 48 S50 ._ $2,400 30 1 $37,000 Laboratory Analyses each 15 $1,600 $24,000 30 1 $369.000 (Water) Reporting *-hrs. 24 $50 $1,200 30 $18,000 PUB. HEALTH ASSESSMENT (EVERT FIVE TEARS) Sanpling hours 40 $50 $400 30 1 $6,000 Laboratory sanple 10 $1,600 $3,200 30 1 $49,000 Report preparation hours 24 $50 $240 30 1 $4,000

2 TOTAL $31,440 $483,000 f

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SJ l-« vo TABLE 3

1MB) ALTERNATIVE: ASBESTOS ABATEMENT, DEMOLITION. SOLIDIFICATION/STABILIZATION OFF-SITE DISPOSAL » ROW SUBTITLE C LMBFILL

ITBI DESCRIPTION UNITS OUAMTITY UNIT PtICE TOTAL COST * S

ASBESTOS ABATEMENT Mobilization lump su» 1 $1,300 $1,300 Removal aq. ft. 2,000 $15 $30,000 Air Monitoring luap *w» 1 $1,300 $1,300 Disposal cu. yds. 12 $51 S610

STRUCTURE DEMOLITION Roofing (corrugated awtal (CM)) 10sq.ft. 2,240 $5 $11,200 Walls (Block I CM) cu. yds. 1,020 $5 $5,100 Steel Framing lin. ft. 1,656 $4 $6,720 Torch cutting (1" steel plate) lin. ft. 414 $3 $1.240 Pulverization lump sun 1 $10,000 $10,000

DEBRIS HANDLING Glass ton 83 S10 $830 Plastic ton 10 $3 $30 Concrete Rubble ton 60 S3 $184 Lab Piles ton 520 $3 $1,560 Drums ton 83 $10 $830 Tanks ton 12 $10 $120 Process Equipment ton 2,040 $10 $20,400 Lead ton 4 $20 $80 SAMPLING Sample Collection hours 80 $50 $4,000 Analysis samples 40 $1,600 $64,000

OFF-SITE DISPOSAL Transportation (20 ton/trip, «i. 69,700 S3 $209,100 450 iii./trip) _ Disposal (Haz. Waste Landfill) ton 3,100 $300 $930,000

SOLIDIFICATION/STABILIZATION Size Separation cu. yds. 1,400 $2 S2.800 Treatment Processing cu. yds. 1,400 $12 $16,800 Reagent (Pozzolan) cu. yds. 1,400 $19 $26,600 QA/OC Testing lump sum 1 $50,000 $50,000 Consolidation (Backfill) cu. yds. 1,600 $3 $4,800

Subtotal - Capital Cost $1,399,600 Legal Fees, License t Permits - 10X of Capital Costs $140,000 Engineering t Administrative - 10X of Capital Costs $140,000 Level C Protection - 25X of Costs for: Asbestos Abatement, $40,000 Debris Handling, and Structure Demolition Subtotal $1,719,000 Contingency - Cost Based on 10X of Subtotal $172.000 Total Construction Cost $1,091,600 TOTAL PRESENT WORTH COST $1,892,000 o o

vo U) APPENDIX A

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VO *». I +S(sj\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 32 V^•t HO?*^ JACOB K. jAvrr•*»«s FEDCRA• L BUCDING ' YOflK. NEW YORK 10278

AGENDA Public Meeting at the Nascolite Corporation Superfund Site Millville, New Jersey

Thursday March 14, 1990 7:00 P.M.

I. Welcome & Introduction Steve Katz Community Relations Coordinator U.S. EPA Region 2

II. Overview of Superfund Nicki DiForte Process Section Chief, Branch 2 Northern New Jersey U.S. EPA Region 2

III. Site History with Farnaz Saghafi Presentation of Remedial Remedial Project Manager Investigation and Nascolite Superfund Site Feasibility Study and U.S. EPA Region 2 Preferred Alternative

IV. Questions & Answers 3 f t-3

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U1

PRINTED ON RECYCLED PAPER APPENDIX B

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to Superfund Proposed Plan ——______Nascolite Corporation Superfund Site ^ -„. Millville, New Jersey xz crA Region 2 ______March 1991

PURPOSE OF PROPOSED PLAN:

EPA ANNOUNCES PROPOSED PLAN Supplemental Remedial Investigation and Feasibility Study (Rl/FS) reports and other This Proposed Plan describes the preferred documents contained in the administrative alternative for addressing soil and wetland record for this site. EPA and NJDEP contamination, as weU as the final encourage the public to review these disposition of buildings and debris at the documents in order to gain a more Nascolite Corporation site (the site). comprehensive understanding of the site and Superfund activities that have been This document is issued by the United States conducted there. The administrative record Environmental Protection Agency (EPA), the contains the information upon which the lead agency for site activities, and the New selection of the response action will be jersey Department of Environmental based. The record is available at the Protection (NjDEP), the support agency for following locations: this response action. EPA, in consultation with NJDEP, will select a remedy for the Millville City Library site only after the public comment period 210 Buck Street has ended and the information submitted Millville, New Jersey 08332 during this time has been reviewed and considered. This Proposed Plan outlines all Hours: Mon, Wed, Thurs 9:00am-9:00pm of the remedial alternatives evaluated for Tues, Fri 9:00am-5:00pm addressing the surface soil and wetland Sat 10:00am-4:00pm contamination and provides the rationale used to determine EPA's preferred U.S. Environmental Protection Agency alternative. Emergency & Remedial Response Division File Room 26 Federal Plaza, 29th Floor THE COMMUNITY'.* New York, New York 10278 Hours: Mon-Fri 9:00am-5:00pm EPA is issuing this Proposed Plan as part of its public participation responsibilities under EPA, in consultation with NJDEP may Section H7(a) of the Comprehensive modify the preferred alternative or select Environmental Response, Compensation and another response action presented in this Liability Act of 1980, as amended (CERCLA). Plan based on new information or public comments. Therefore, the public is o This Proposed Plan summarizes information encouraged to review and comment on all of o that can be found in greater detail in the the alternatives identified here.

vo vj EPA solicits input from the community on The area surrounding the site is zoned for the cleanup methods proposed for each both residential and industrial use. Several Superfund response action. EPA has homes are located east and southeast of the established a public comment period from site along Wheaton and Doris Avenues. The March 1 to March 31, 1991, to encourage Cumberland Greens Apartment Complex public participation in the selection of a borders the southern property line. The remedy for the Nascolite site. The comment Consolidated Rail Corporation (Conrail) period includes a public meeting at which owns and operates a switching facility and EPA will discuss the supplemental RI/FS two separate railroad track spurs on the report and the Proposed Plan, answer western border of the Nascolite site. The questions, and accept both oral and written Cumberland Recycling Corporation is comments. located immediately west of these tracks. The E.P. Henry Corporation, a concrete The public meeting for the Nascolite site is casting company, and High Industries are scheduled for March 14, 1991 from 7:00 pm located to the northwest of the Nascolite until 9:00 pm, and will be held at the site. Millville Municipal Building on Doris Avenue in Millville, Cumberland County. From 1953 to 1980, the Nascolite Corporation manufactured polym ethyl Comments will be summarized and responses methacrylate (MMA) plastic sheets, provided in the Responsiveness Summary commonly known as acrylic, Plexiglass or section of the Record of Decision (ROD). Lucite. Waste residues from various The ROD is the document that presents distillation processes were stored in several EPA's final selection for response action. buried tanks in the area north of the main Written comments on this Proposed Plan plant. Wastewater streams from the should be sent by close of business March 31, manufacturing process and other on-site 1991 to: sources were discharged to a ditch which flows into the wetland area, southwest of Famaz Saghafi the plant, along and parallel to the Conrail Project Manager tracks. U.S. Environmental Protection Agency - Region II In September 1983, the site was placed on Emergency & Remedial Response EPA's National Priorities List (NPL). In Division 1986, an RI/FS was completed by NJDEP 26 Federal Plaza, Room 13-100 with funds provided by EPA through a New York, New York 10278 cooperative agreement. The RI/FS was performed in order to define the nature and extent of contamination at the rite and to SITE BACKGROUND develop and evaluate remedial alternatives to determine the most appropriate remedial The Nascolite Corporation site is situated on action for the rite. the municipal bonier line of the cities of Millville and Vineland, Cumberland County, EPA conducted a removal action at the New Jersey. The site is situated west of the request of NJDEP from November 1987 to intersection of U.S. Route 65 and Wheaton March 1988, during which time drums were Avenue on Doris Avenue. The Maurice River removed, a fence was erected around the is located approximately one mile to the entire manufacturing area, and a tarpaulin southwest of the site. The river runs north was placed over areas where soil was heavily to south, draining and feeding the manmade contaminated with inorganic compounds, fa Union Lake. Petticoat Stream, located addition, waste material storage tanks were approxi- mately 600 feet west of the cleaned and cut into scrap metal, 20 cubic railroad tracks on the western border of the yards of MMA contaminated soil were Nascolite rite, flows during the spring and is excavated from the rite and 30 cubic yards o dry throughout most of the remainder of the of asbestos fri«»i»tinn were removed from o year. This stream flows south and drains rite buildings. into the Maurice River. VO 00 SCOPE AND ROLE OF OPERABLE UNIT The detailed results of the RI can be found in the supplemental RI Report, contained in At the conclusion of the initial Rl/FS, both the administrative record noted above. The EPA and NJDEP determined that additional results of the investigation which are data were necessary to assess remedial summarized in the following sections options for contaminated soil However, identify the principal threats (areas of sufficient information was available to significant contamination) posed by the site. support a decision to address contaminated Figure l depicts the location of the groundwater. Consequently, the site contaminated areas described below. remediation was divided into operable units. The First Operable Unit (FOU) addressed contaminated groundwater. On March 31, 1988, EPA issued a ROD which embodied EPA's remedy selection process for the FOU. The ROD required the following actions: 1. Groundwater extraction with on-site treatment and reinjection; 2. Provision of an alternate water supply to potentially affected residents; and 3. Performance of additional studies to determine appropriate remedial measures for contaminated soil and on-site buildings. The alternate water supply, which provides public water to residences on Doris Avenue, was provided by two of the Potentially Responsible Parties (PRPs) under an Administrative Consent Order with EPA. The design of the groundwater remediation for the FOU was initially funded by EPA. Treatability studies, which were conducted es part of the remedial design, indicated that other treatment options should be explored. Consequently, EPA approached the PRPs to undertake remedial design and remedial construction activities. The design is being conducted by the PRPs under a Unilateral Administrative Order with EPA oversight. The final design which will include additional site characterization work The soil underlying the site consists of fine and comprehensive treatability studies is to coarse grained sand with some clay and expected to be completed in January 1903. silt. Several sandy to ailty clay layers have been noted within the unit at varying A supplemental RI/FS to ___add _ depths. At least one layer has been found to contaminated soil, debris and buildings on be semi-continuous over a large geographic the site was initiated by EPA in March 1988. area.

•** 1 Trn UNSAJT ? ^T SOIL CONTAMINATION along the western edge of the wetland, t0 a maximum depth of five feet. Contamination S fo-3 ftl decreased to low or background levels toward the southern edge of the wetland Organic Contamination where there was no evidence of contaminant migration toward Petticoat Stream. Concentrations of MMA in surface soils were below the health-based level, i.e., 5 parts Lead and cadmium which appear to have per million (ppm). migrated through surface water transport and sediment erosion from the drainage An area containing 630 ppm of total ditch were detected at concentrations of semi-volatile organic contaminants was 1420 ppm and 57.7 ppm, respectively. identified in the North plant area (soil boring - 3D) at a depth of 3 feet. An area containing 450 ppm of total semi-volatile organic contaminants and 1420 Inorganic Contamination ppm of lead was identified in the wetland (soil boring - 5H) at a depth of 0 to 2 feet. High levels of inorganic contaminants were detected in surficial soil within the North Plant area and south of the main processing STRUCT! TRFS >NT> plant. The inorganic contaminants include cadmium, copper, lead, zinc, mercury and On-site structures from the facility's selenium, with lead concentrations in excess operational period have been poorly of action levels (see Summary of Site maintained and are in a dilapidated state. Risks). Vertical migration of inorganic Roofs on several of the buildings have contaminants does not appear to occur partially collapsed, leaving the remaining beyond 3 feet below the ground surface roofing material in danger1 of collapse. except for lead, which was found at levels These conditions pose a worker health and above 500 ppm (i.e., the action level) down safety hazard in conducting any remedial to a depth of 15 feet just north of the activities. Portions of the existing cracker house and in the area of the former structures are contaminated with asbestos. loading dock. Asbestos contaminated materials were observed to be in a friable state and the Extraction Procedure (EP) Toxicity tests maximum detected concentration was 40 were also conducted for eight selected percent. metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver) to determine teachability and whether SHBS1JRFACE snnjg f3-S2 fti contaminated soil should be classified as RCRA characteristic waste. Hie test Elevated levels of volatile and semi-volatile results revealed nondetectable levels of organic contaminants including MMA were these contaminants in the leachate, detected in unsaturated soils between 3 and indicating that the soil is not EPA toxic. 12 feet in the North Plant area (i.e., north of Lead contaminated surface soils, therefore, the main processing plant) and the area would not be classified as RCRA adjacent to the laboratory building (Figure 1). characteristic waste. Further Toxic Characteristic Leaching Procedure (TCLP) Saturated soil samples were also collected testing will be conducted to verify these during the supplemental RI. Saturated soil results. contamination at the site consists of volatile o and semi-volatile organic contamination o WETLAND CONTAMINATION including MMA which begins at the water table, at approximately 15 feet below ground NJ Inorganic contamination (i.e., lead and level, and extends down to 30 feet below the to o cadmium) was detected in the ditch along water table. Contamination assessment o the southwestern edge of the site and studies have identified a downward vertical gradient, which would tend to carry present in site soil can be successfully contamination from the water table down solidified. deeper into the aquifer. At approximately 35 feet below the surface, the organic Soil washing involves the use of a solvent to contamination zone'extends northwest and solubilize organic and inorganic southeast over the main plant area. This contaminants attached to soil particles. It is contamination is in the saturated zone and performed by batch treatment and mixing is will not be addressed in this proposed used to contact the soil with the solvent. remedy. However, this information will be Soil washing is an effective means of considered in the design of the first operable extracting metals and some organic* from unit, since it may be useful in reducing the soil. Results from soil washing studies time and cost associated with operating the conducted during the FS indicated that groundwater treatment system. Inorganic volatile organic and metal contaminants of contamination (lead and cadmium) was not concern can be effectively washed under detected in saturated soils or in the proper operating conditions. Biotreatment groundwater. It can be concluded that of process residuals was found effective in inorganic contaminants in the unsaturated further reducing the concentration of surface soils are not leaching into the contaminants. groundwater. / Asbestos abatement was considered for the demolition of on-site structures and debris. FKAJgHTTJTY STUDY Potential remedial measures include removal of the asbestos prior to demolition and The supplemental FS has evaluated potential enclosure during removal or demolition. remedial alternatives to address soil contamination in the surface soil and wetlands. The various treatment technol- SUMMARY OF SITE RISKS ogies considered included solidification/ stabilization of contaminated soils, soil A baseline risk assessment was conducted by washing and a No Action alternative. EPA through its contractor during the supplemental RI/FS to evaluate the potential During the FS, treat ability studies were human health and environmental risks that performed to test the applicability of could result from soil contamination at the several treatment methods for on-aite soil. Nascolite site. The evaluated technologies included soil flushing and vacuum extraction (for EPA uses reference doses (RfDs) and slope subsurface soil). A literature search was factors to calculate the non-carcinogenic conducted for Solidification/Stabilization. and carcinogenic risk attributable to a particular contaminant. An RID is an Solidification/stabilization technologies estimate of t daily exposure level that is not immobilize contaminants by either changing likely to result in say appreciable risk of the constituents into immobile, insoluble or deleterious effects during a person's non-hazardous forms by binding them in an lifetime. A slope factor establishes the immobile, insoluble matrix or a combination between the dose of a chemical of the two. Solidification/Stabilization sod the response and is commonly expressed technology options can be implemented as a probability of a response per unit intake on-site, either ex-si tu (i.e., excavated and of a chemical over a lifetime. Both RfDs treated) or in-situ (i.e., treated in-place) or and slope factors must undergo extensive at an off-site facility. Solidification/ review and are verified by EPA before they are published. Although EPA has established Stabilization treatment indicated that o inorganic and semi-volatile contaminants RfDs end slope factors for many chemicals, o there are chemicals that currently do not recommended soil cleanup level of 500-1000 have RfDs slope factors or similarly ppm. (EPA guidance recommends using the accepted lexicological parameters. soil cleanup range for lead until RfDs and Consequently, the risk due to such slope factors are established). contaminants cannot be quantified. This is of particular significance at the Nascolite The high concentrations of lead in surface site, since lead, the main contaminant of soil are a matter of concern at the Nascolite concern, does not have an RfD or slope site. Although a quantitative estimation of factor. carcinogenic and non-carcinogenic risks attributable to lead could not be made, it is Non-carcinogenic adverse health effects are evident by the extremely high concen- unlikely for all exposure routes considered trations detected, that the surface soils at under current conditions. There is however, the site pose an unacceptable risk. The potential noncarcinogenic risk associated potential exposure route identified for the with the future on-site residential exposure site included ingestion of, and dermal to children. This is based on exposures to contact with surface soil. Although the site noncarcinogenic contaminants exceeding is fenced, there are signs of vandalism and EPA's Reference Dose which is an estimate trespassing. of a daily exposure level for the human population including sensitive Approximately 60 residences are located subpopulalion's that is likely to be without within one-half mile of the site. Several an appreciable risk of deleterious effects homes are located immediately east and during a lifetime. EPA has considered all of southeast of the site along Wheaton and the site data and available toxiciological Doris Avenues. The Cumberland Greens data and finds that the current site Apartment Complex borders the southern conditions are not protective. Provided property boundary of the site. Considering below is a qualitative discussion supporting the sensitivity of the neighboring population EPA's conclusion that the current site (school children and residents in proximity to conditions are not protective of human the site), the extremely high concentrations health. of lead end the known health effects attributable to lead, the lower end of EPA's Lead, which has no RfD, was present in the soil cleanup level (i.e., 500 ppm) should be soil at a maximum concentration of 41,800 applied at this site. ppm. Exposure to lead has been associated with human non-carcinogenic effects. The Concentrations of organics in the major adverse effects in humans caused by unsaturated zone did not present an lead include alterations in Red Blood Cell unacceptable risk to human health and production and the nervous system. The therefore will not require remediation. toxic effects are generally related to the However, treatment of organics may concentration of this metal in blood. High enhance remediation times for the FOU blood concentration levels can cause severe groundwater remedy. Accordingly, the soil irreversible brain damage and possible vapor extraction treatability study results death. Furthermore, EPA has classified lead presented in the FS will be considered during as a 62 carcinogen. This category generally the groundwater remedial design under the indicates that there is sufficient evidence FOU. from laboratory studies of caxcinogenecity in animals. SUMMARY OF ALTERNATIVES Lead, is present in surface soils at a The following remedial alternatives were maximum concentration of 41,800 ppm developed to meet t remedial action o which is significantly higher than the EPA's objectives. The objectives focus on reducing o

O CO 6 exposure to inorganic contamination in the taminated on-site prior to disposal at a surface soil and in the wetland. Stated time RCRA Subtitle D (i.e., nonhazardous solid periods for achieving remedial action waste) landfill. In addition, some debris objectives refer to actual implementation (e.g., large metal I-beams) may be recycled. times once all equipment is mobilized and If found to be cost-effective, some of the operational. In addition, this Proposed Plan, debris could be pulverized and treated by necessity, addresses the need to reduce consistent with the alternative selected for the physical hazards posed by the dilapidated contaminated soils. All demolition activities buildings and structures on-site. Data from will be conducted in compliance with the FOU RI has been considered in the relevant asbestos regulations and development of alternatives for this appropriate air emissions control. The cost operable unit. In particular, inorganic for building demolition and disposal is contamination was not detected in the estimated to be between $1,351,000 and groundwater and subsequent EP toxicity $2,409,000 and the respective imple- testing of inorganic contaminated soil has mentation times for the selected remedy are shown the potential teachability of metals estimated to be 8 months and 5 months. The into the groundwater as highly unlikely. cost and duration of the remedial action will vary depending on sampling results and The dilapidated condition of on-site requisite disposal requirements. buildings and structures are a major concern, since portions of most of the structures have either collapsed or threaten to collapse. Friable asbestos has also been detected in UNSATURATED SOIL AND WETLANDS these on-site buildings. Consequently, these renditions potentially endanger personnel involved in on-site activities. Asbestos Alternative 1: No Action abatement and demolition of the buildings and structures is, therefore, warranted from Capital Cost $0 a worker safety perspective. In addition, the Annual O4M Cost $0 presence of buildings, structures and debris Present Worth $0 at the site may physically hinder the Months to Achieve implementation of any soil or groundwater Remedial Action Objectives NA remediation effort. Buildings and structures currently occupy approximately one fourth of the manufacturing area. More than half Under this alternative, no activities would of the manufacturing area is either occupied be implemented and the existing site by buildings or covered with contaminated conditions would remain. Site monitoring surface soil at the surface which requires and maintenance would continue under the remediation. Debris, such as broken glass remedial action for the FOU. Consequently, plates used in the manufacturing process, there are no OAM costs associated with the covers nearly the entire exposed surface of No Action Alternative. the manufacturing area. An estimated 4,800 tons of rubble would be Alternative 2: Soil generated as a result of the demolition operations. Building rubble and debris will Capital Cost $2,627,000 be sampled and segregated according to Annual OAM Cost $0 disposal requirements (i.e., testing for Present Worth $2,627,000 asbestos containing material, RCRA waste Months to Achieve and solid waste) on-site prior to disposal If Remedial Action necessary, some debris may be decon- Objectives o o

to to o u> Under this alternative, soil washing would be with virgin, naturally occurring type soil to used to remove inorganics from the surface ensure the full restoration of the wetlands. soil. Using a cleanup action level of 500 A wetland delineation and functional values ppm for lead, the estimated volume of assessment will be completed prior to surface soil requiring treatment is implementing the proposed remediation. approximately 6000 cubic yards (CY). This The wetland restoration plan will ensure that alternative also includes remedial measures appropriate wetland functions and values are for cleanup and restoration of the wetland. re-established following remediation. Approximately 2000 CY of soil from the wetland is contaminated with lead above the 500 ppm level and would require treatment. Alternative 3: Solidification/Stabilization Treatment Contaminated soil above the action level would be excavated and separated to remove Capital Cost $1,790,000 materials which are not amenable to Annual O&M Cost $31,000 treatment by soil washing such as, any Present Worth $2,273,000 buried refuse or debris, plant matter or humic material. The side stream of Months to Achieve / separated materials would be classified for Remedial Action Objectives disposal at an off-site RCRA Subtitle C (i.e., hazardous solid waste) landfill facility or placed back in the excavated area if This alternative is similar to Alternative 2 sampling results disclose, unconlaminated except that Solidification/ Stabilization of material. Approximately 10 percent of the soil would be performed in place of soil cct&l volume of the surface soil may be washing. This technology immobilizes separated out in the staging area. contaminants by binding them into an insoluble matrix. A typical process train for a soil washing treatment system would include particle size In addition, areas of highly contaminated soil separation, rapid mixing of soil and solvent (e.g., cracker house and loading dock) will be in an extractor, solvent recovery, particle excavated and transported for off-site settling and waste stream treatment. disposal at a RCRA Subtitle C landfill facility. Solvent recovery for recycle and reuse generates a sludge which would be treated The composite treated solidified material and disposed of at an off-site RCRA would be backfilled on the Nascolite facility. During the particle settling stage, property into the previously contaminated soils would be separated from liquids. The areas. A volume increase of 10 to 30 liquid waste stream containing metals and percent would be expected due to the residual solvent would require treatment. addition and hydration of pozzolanic Treatment would include precipitation and materials, e.g., sand, lime, ash, required to some form of filtration and would be complete the stabilization process. The site implemented on site. Additional pilot-scale would be appropriately backfilled and graded studies may be required in conjunction with to account for the volume increase. treatability studies performed on the FOU to address treatment of residual solvent from For cost estimation purposes, it is assumed the soil washing process. that 10 percent of the wetland material is not amenable to Solidification/Stabilization The treated soil from the particle settling treatment due to high organic content and stage would be backfilled on site. The would have to be disposed of off site. It is o excavated wetland area would be backfilled assumed that this material could be o

to to o landfilled in a RCRA Subtitle C landfill or remedy to maintain reliable protection placed back in the excavated area if found of human health and the environment to be unconlaminated. over time, once cleanup goals have been met. EVALUATION CRITERIA Reduction of Toxicitv. Mobility nr Volume: This criterion addresses the This action describes the requirements of degree to which a remedy utilizes CERCLA in the remedy selection process. treatment to reduce the toxicity, Remedial treatment alternatives are mobility, or volume of contaminants at evaluated against the following nine criteria: the site. o Overall Projection of Human Health Short-Term Effectiveness: This and the Environment: This criterion criterion refers to the time in which addresses whether or not a remedy the remedy achieves protection, as provides adequate protection and well as the remedy's potential to describes how risks posed through each create adverse impacts on human pathway are eliminated, reduced or health and the environment that may controlled through treatment, result during the construction and engineering controls or institutional implementation period. controls. Implement ability: Implement ability is Compliance with ARARsi This the technical and administrative criterion addresses whether or not a feasibility of a remedy, including the remedy will meet all of the Applicable availability of materials and services or Relevant and Appropriate needed to implement the selected Requirements (ARARs) of federal and alternative. state environmental statutes (other than CERCLA) and/or provide grounds Cost: Cost includes capital and for invoking a waiver. operation and maintenance (O&M) costs. There are several types of ARARs: State Acceptance: This criterion action-specific; chemical specific; and indicates whether, based on its review location-specific. of the RI/FS and the Proposed Plan, the state concurs with, opposes, or has Action-specific ARARs are technology or no comment on the preferred activity-specific requirements or limitations alternative. This criterion is satisfied related to various activities. Chemical- since the state concurs with the specific ARARs are usually numerical values preferred alternative. which establish the amount or concentrations of a chemical that may be ______Acceptance_ : This found in, or discharged to, the ambient criterion will be assessed in the ROD environment. Location-specific require- following a review of the public ments are restrictions placed on the comments received on the RI/FS concentrations of hazardous substances or reports and the Proposed Plan. the conduct of activities solely because they occur in a special location. COMPARATIVE ANALYSIS OF ALTER- NATIVES Lone—ter______ism Fffvrtnri : This o criterion refers to the magnitude of This section provides a summary of the o residual risk and the ability of a evaluation of each alternative against the ro o Ul 0 first scv en C ERG LA criteria described x solidification/stabilization raises some above. This analysis addresses lead long-term uncertainties regarding the contamination in surface soils. State and integrity of the stabilized mass, particularly community acceptance will be evaluated with regard to leaching of contaminants into upon completion of the public comment the groundwater. However, site-specific period. conditions (i.e., lack of inorganic contam- inants in the groundwater) should alleviate these concerns since solidification/ Alternative 1: No Action stabilization will further inhibit the leaching Alternative 2: Soil Washing of contaminants into the groundwater. Alternative 3: Solidification/ Stabilization The greatest reduction of volume of contaminated soils would be achieved by soil washing through the physical removal of Alternative 1 would not provide remedial contaminants above the action level from measures to protect human health or the the soil. This process actually increases the environment and it would not meet any of mobility of contaminants. However, the the remedial action objectives. Alternative more mobile contaminants are removed. 1 would provide no effective remedies for Solidification/stabilization does not remove the long-term nor any reductions of toxicity, contaminants from the soil but relies in mobility and volume of contaminants. In immobilization of the waste in an insoluble tsrrns of short-term effectiveness, matrix, making contaminants inaccessible to Alternative 1 would have no additional the environment. This alternative achieves environmental impacts beyond the present the greatest reduction in mobility. situation, however this alternative would Solidification/stabilization will result in a leave the current risks unaddressed. This net increase in the volume of treated alternative has a total present worth of $0. material A significant reduction in toxicity is not expected from either alternative. Alternatives 2 (soil washing) and 3 ^solidification/stabilization) would meet the Both alternatives can be implemented in a remedial action objective of reducing manner whereby similar adequate protection exposure to surficial soils contaminated with to human health and the environment would lead, to terms of short-term effectiveness, be provided upon implementation of the emissions and airborne concentrations remedy. Solidification/stabilization would estimates will be developed in simulate achieve protectiveness in a shorter period of 6xc&v«ttion activities. These concentrations time, since it employs a less complex will be used to quantify human health risks treatment process and does not involve the resulting from on-site work. This will assist of hazardous chemicals. Soil in determining the appropriate control. washing, CD the other hand, would involve a strategy, in addition to on-«ite air more complex treatment train utilizing monitoring for worker health and safety, will solvents to extract lead from the soil be required during the excavation. matrix. The solvents used to extract the lead would then be washed from the treated Both alternatives will achieve long-term soil This process generates a highly reliable protection of human health and the contaminated liquid effluent, increasing the environment. Soil washing will remove potential for spillage and release into the inorganic contamination from soils to environment and the need for proper acceptable levels, while solidification/ decontamination and treatment. Waste- stabilization will immobilize the water from the soil washing treatment contaminants by binding them in an insoluble system would be achieved on-jite through matrix. Soil washing is advantageous in that the proposed FOU groundwater treatment contamination above the action level would system. Consequently, implementation of be removed from the site. Generally, the soil washing alternative would be to [O o 10 delayed pending construction of the degree of uncertainty in meeting soil gnnmdwater remedy. Solidification/ cleanup level. If additional treatment is stabilization could be implemented required in the field, the costs will escalate. independent of the FOU remedy. Given site conditions, solidification/ Furthermore, soil washing may require pilot stabilization offers greater certainty for the studies to address any uncertainties contaminated soils present at the site. regarding the ability of the groundwater Accordingly, efficacy standards should be treatment system to treat soil washing readily achievable after solidification/ wastewater to meet groundwater reinjection stabilization has further immobilized the standards. waste. Sampling of treated waste is necessary for Both on-site soil washing (in Alternative 2) both alternatives, however, the sampling and solidification/stabilization (in Alterna- requirements for soil washing are more tive 3) would be conducted in compliance extensive due to the use of solvents in the with state and federal ARARs. RCRA Part treatment process. Considerable sampling 264 standards will be applicable to the of treated soil would be required to ensure on-site storage of the excavated soil and that it is free from residual solvent waste material if storage exceeds 90 days. contamination prior to its redeposition on site. Alternatively, Part 265, Subpart I and Subpart J, container and tank standards will Both soil washing and solidification are be applicable if storage of waste on-site is proven technologies and can be implemented less than 90 days. The data marking the at the site. Solidification/ stabilization initiation of waste accumulation will be should be relatively simple to implement clearly indicated on each tank/container. 40 since it employs a one-step mixing and CFR 264, Subpart L standards will be placement process. Soil washing involves a applicable* to the placement of demolition more complex treatment and verification material in waste piles to segregate monitoring process. Actual field conditions contaminated from clean materials prior to may warrant the washing of soils more than disposal Although EP toxicity testing on once to meet the required soil cleanup site soils have shown them not to be RCRA levels. The failure of inorganics to leach characteristics wastes, further TCLP tests from the soil may impede the removal will be performed to verify these results. process through soil washing. This would EPA does not anticipate' any changes in the increase the cost and time necessary for proposed remedy as a consequence of the completing the remedy. additional testing. Off-site treatment/ disposal would be performed according to Processing equipment for soil washing must RCRA part 262 standards specifying be custom designed according to unique site manifesting procedures, transport and record specifications, whereas solidification/stabil- keeping requirements. The shipment of ization units and equipment are readily hazardous waste off-site to a treatment available for immediate usage. Therefore, facility win be consistent with OSWER the accessibility of equipment and Off-Site Policy Directive Number 9834.11 contractors to implement the stabil- which became effective November 13, 1987. ization/solidification technology is believed This Directive is intended to ensure that to be greater. facilities authorized to accept CERCLA generated wastes will be in compliance with Alternatives 2 and 3 have an estimated RCRA operating standards 40 CFR 264, present worth of $2,627,000 and $2,273,000, Subpart X standards are applicable to the respectively. Soil washing involves a greater on-site solidification/stabilization process

K) O •vj 11 used for the contaminated debris and soLL 3. Sampling, separation and stockpiling of Deed restrictions associated with future site debris for decontamination, on-site use would be placed on the site with the solidification/stabilization treatment, implementation of both alternatives. recycle and/or off-site disposal to a RCRA Subtitle D or C landfill The preferred alternative is the imple- mentation of Alternative 3. Site risks have 4. Contaminated soil in the wetlands and been quantified to be primarily of surface soil (3 feet below ground contaminated soils. The solidification/ surface in most areas, and up to 15 stabilization technology will be effective in feet near the loading dock area, for a reducing the direct contact risk. This total of 8000 CY) would be excavated alternative appears to provide the best and stockpiled for on-site balance of trade offs among the three solidification/stabilization. Localized alternatives with respect to criteria that areas of surface soils contaminated EPA uses to evaluate alternatives. with VOCs may be excavated and disposed of off-site at a RCRA Subtitle C landfill if determined to SUMMARY OF THE PREFERRED ALTER- interfere with or be unaffected by the NATIVE solidification/stabilization process. The top six inches of soil in the The preferred alternative presents the best wetlands may be highly humic in balance of tradeoffs with respect to the nature, and may have to be disposed of evaluation criteria and it will meet the off-site at a RCRA Subtitle C landfill. statutory requirements in CERCLA section I2i(b): i) to protect human health and the 5. On-site solidification/stabilization of environment; 2) to comply with ARARs; and surface soil, wetlands and pulverized 3) to be cost-effective. The preferred debris with subsequent on-site backfill alternative utilizes permanent solutions and in the formerly contaminated regions. alternative technologies to the maximum extent practicable end satisfies the 6. Restoration of wetlands would include statutory preference for treatment as a backfill of virgin, organic soil into the principal element. excavated area. The preferred alternative uses stabilization/ The total cost of this site-wide alternative solidification as the primary treatment is estimated to be between $3,593,000 and technology. In order to provide an overall $4,164,000. picture for site-wide remediation, activities associated with building demolition have been integrated into the preferred alternative. The general sequence of activities in this alternative are presented below. Some of these activities may be performed concurrently. 1. Demolition of structures in accordance with asbestos regulations. r 2. Consolidation of debris from structures. ••a

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10 o 00 12 APPENDIX C

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10 to