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3 «• =- — o> =r ;- 3 3 Part I: Client Documents BATCH NTXBER Site Ka»e Site Number 542-0! Client Contact EPA or State Date Received front Client Received by ZM Date Returned to Client. Returned by______ Part II: Microfilm Blovbacks Copy Set Kunber (Circle One)_ I 2_ t 3 QC of Copies by______Date o Part III: Coding Coded by_ _Date_ QC by_ _ Date Edit QC/Cnanges by_ Date_ Edit QC/Cnanges by_ _Dat«_ Edit QC/Cbanges by_ Date NOTICE: if the film Image is less clear than this notice, it Is due to the quality of the document being filmed DIA 002 %^^Sl3MiSll '.> ? E •i o*> \ 3 a o O(< =0 u £ ff\ 8° •o »t 11 c ft <£-|8 (0 &_X k. ti - •o • .C >» • * H? O 4J U b W • -.4 E 1 C - a. • 3*1 >T ' ••* ••* u <|) b W /v - * u a. u « ^33 5 j-a • •••» u M 4 U S 0 O 1 •H M 9S i £ u A o 4J ^V ») c M O 1 f-i B v ^^^ 5r~s u -o • 0 ^v \>vS 0 p (3 •H n '•*• 2 IM •*84 ^V^V \\ 7 • He ai • \ y< ^* t '•C* >Xv '*•• a£ IM Q Xb • H /i ^n/ j o1 u1. j1? •2 0.0 ?£•=< o _»«< . • DEPARTMENT Of HCALTH t, HUMAN SERVICES Hctlth S»rvi» '(A r OIMIM Memorandum °o » Review of 2,3,7,8-Tetraehlorodlbenzodloxln (TCDD) contamination In the 'Ironbound District' of Newark, New Jersey Dear the Diamond-Shamrock facility, 80 Lister Avenue, Newark, New Jersey. A request for a review of available information regarding the remediation of off-site 2.3,7.8-tetrachlorodibenzodloxln (TCDD) contamination in community accessible areas of Newark. New Jersey, known as the Ironbound District (Figure 1), was submitted to the Chronic Diseases Division of the Center for Environmental Health for review by R. Spear. Chief of the Surveillance and Monitoring Branch of the EPA (Environmental Protection Agency) Iteglon II In Edison, New Jersey. The EPA requested a review of their remedial activities strategy plan for possible public health significance. This plan does not outline their remedial action activities, but rather defines the community areas of identified contamination and describes whether remedial activities, additional sampling, or no additional work la planned. The Diamond-Shanrocfc/Diamond Alkali site (henceforth to be called 80 Lister Avenue) is an old 2.4,5-T production facility located at 80 Lister Avenue wblch is on the Passalc River in an Industrialized area of Newark. NJ. This •lie was evaluated for TCDD contamination by the New Jersey Department of Environmental Protection in May 1983. This on-slte sampling revealed TCDD O contamination of up to 60 parts per billion (pbb) at the South gate and 5100U ppb under a storage tank. Subsequently, the site was designated for remedial O work by the EPA. Extensive EPA sampling has occurred throughout the area to ro determine the extent and levels of contamination. The EPA found an extensive amount of contamination near Lockwood Avenue and Euclid Avenue. This contamination was suspected to have occurred because reaction vessels anJ oil .tanks were, at a previous time, removed from the 80 Lister Avenue facility and dismantled at Brady Iron and Metal Works located at the Lockwood Avenue and Euclid Avenue Intersection. It is presumed that contaminated dirt and soil found in close proximity to the Brady Iron Works was due to wind and water dissemination from the Brady site. Tbe EPA has developed a remedial action plan which will address specifically defined sones within the Ironbound District. They developed the plan bated upon Information contained in a CDC document entitled ~Uc*lth Implication* oi • CO Page 2 - Stephen Kargolli, Ph.D. 2,3,7,8-Tetrachlorodlbenzo-p-dioxln (TCUD) Contamination of Retldentlal Soil". and based upon the CDC developed risk assessment for TCDD In residential aotl. The Ironbound District (study area) was defined as tb« areas bordered by the Paasalc liver on the North and Northwest, the Nev Jersey Turnpike on the East, and the Pulaski Skyway on the South. The area was divided Into 8 zones, eacU classified as residential or commercial. The total study srss and zones are depicted on Figure 2. IPA KISK MANAGEMENT STRATEGY The EPA risk management strategy proposes different plans for residential sad commercial cones. Toe proposed plan for residential zones would "pose s level of concern sad renedlatlon or further sampling' ct 0.78 ppb TCDD. This Is the level st which they would have a 951 confidence that the value was not actually greater than 1 ppb. In commercial cones, the KPA Region II. following the CDC guidance (Klmbrough et.al.) which suggested that a level of concern may not necessarily be reached unless levels are several fold or more above 1 ppb, determined that a level of 5 to 7 ppb TCDD sstlsfactorily met this criteria for the commercial areas around the 80 Lister Avenue site. The ETA legion II developed the following commercial cone guidelines} 1. Soil concentrstlons below 5 ppb TCDD, where movements of soil or dust is mot a problem, indicate no further action Is necessary. 2. Soil concentrations between 5 ppb and 7 ppb, where movement vf soil or dust is not a problem, ere of concern when geographically grouped temples indicate an area has an average soil TCUD concentration greater than 5 ppb. 3. Soil concentration between 7 ppb and 100 ppb TCDD are high and dial action Is Indicated. k A. Soil concentration above 100 ppb TCDD are very high and extensive dlation is required. BESIDEKTIAL ZONES O TCDD values in residential zones 2, the Roosevelt Homes Housing Project, and o 4, the HawkIns Street School area, were all reported to be below the CDC 10 action level of 1 ppb for residential property (0.78 ppb statistical level). The areas of concern in residential cone 1, along Joseph and Esther Streets and oo the block of Albert Avenue between these two streets, are 1) the area around M Joseph Street; 2) the parkwaya on either side of Albert Avenue between Joseph and Esther Streets; 3) the psrkwsy on Lockvood Street near the coraer of Albert Avenue; and 4) the area extending from the yerd at 22 Joseph Street to the parkways on both sides of Esther Streets. For these four sites of contamination, remedial activities srs planned. The EPA also identified one sample in parkway soil with TCDD contamination of 1.2 ppb with multiple surrounding sanples with no dloxin detected. They speculate that the contamination was probably due to the sprsad of contaminated dust, recommend no further action. « c o » 5 [=Q -?•«——• O ZJ§ J^ • 2>«< * » m| 2. »* 5" "> „. Page 3 - Stephen Margolls, Ph.D. The EPA identified no sress of concern in residential sone 3. the Hayea Park East area, but they did have three samples above the statistical limit of 0.78 ppb. One sweep saaple wss 0.78 ppb, and no further action va« suggested. Uns i e» ? — parkway soil saaple, on the cornar of Raymond Blvd. sad Foundry Street, contained 1.1 ppb TCDD. They sgsln speculate that the contamination is the result of scattered contaminated dust, aad rscoamsnd no further action. Th« third contaminated location was a soil sampls taksn between 114 and 118 Waydell Street. Since surrounding samples contain no detectlble dloxln, they suggest no further action; but they suggest that additional sampling might be useful* COMMERCIAL ZONES The commercial areas surrounding the 00 Lister Avenue alee have been divided into 4 tones. Commercial cone 1 consists of the 80 Lister Avenue site aad propertiea bordering the site that were also highly contaminated; cone 2 consists of the Brady Iron and Metal property and the area iaiMdlately surrounding this property which includes the Hlldemana property, the old Morris Canal Bed, the Pulaski Skyway reap parkway, aad extends East to Lockwood Street and North to Euclid Avtaue; sone 3 consists of the commercial and industrial properties bordering Lockwood Street, extending fro* Albert Avenue oo the North to KayBond Boulevard on the South which Includes part of the Pulaski Skyway off-ramp; and, cone 4 consists of all remaining commercial and industrial properties In the study area not defined in xonea 1,2, or 3. Commercial zone 1 has had extensive temporary remedial actions conducted which Included a cover on the entire ground surface of the 80 Lister Avenue site. Two soil samples were identified, both composite samples with concentrations of 5 ppb. In both situations, geographically grouped soil samples from the area show an average TCDD concentration of less than 5 ppb* They have recommended no further sampling or remediation for this area. Commercial cone 2 has also had extensive remedial activity, but twenty-one •oil samples continue to have TCDD concentrations st or above 5 ppb. Seven samples have concentrations above 100 ppb, seven have concentrations between 7 ppb and 100 ppb. and seven have concentrations between 5 ppb and 7 ppb. The o EPA has subdivided the contaminated areas of this cone into 4 areas. The area South of the Brady property has seventeen samples with TCDD concentrations o between 5.6 ppb and 750 ppb. The second consists of two samples with concentration* of 9.4 ppb and 5.6 ppb located outside the Northeast corner of the Brady property. They believe that this contamination represents spread from the Brady property aad will Include both areas in their extensive remedial action plan. Two samples, oae of 7.4 ppb on the West parkway of Lockwood Street and one with 6.5 ppb on the Northern parkway of tuclld Avenue are the final two areas of concent. The EPA suggests further sampling or remediation of these areas. Commercial SOB* 3 contains three samplss above 5 ppb. On* sweep sample, containing 6.0 ppb is locsted on Lockwood Street in front of the Brady property. Because the contamination Is a swssp ssmple taken from a paved Page 4 - Stephen Kargolls, Ph.D. * commercial street, they recooaend no remediation. One sample at the Newark Box Board Company lot on Lockwood Street between Albert and Euclid Streets contained 6.1 ppb. They report that two other aoil cacplea taken from thla parking lot have level* of 2.1 ppb aad 1.7 ppb. One aaaple at the corner of Raymond Boulevard and Lockwood Street contained 5.3 ppb. A repeat aample at this site contained 3.7 ppb and two samples nearby contained 2.6 ppb and 1.4 ppb. The EPA feela that because the contamination probably caae froa the Biady property vhlch la now contained and because geographically grouped soil aaaplea demonstrate an average of TC2D contamination below 5 ppb, remediation is not required for these areas. Commercial ion* 4 did not have any lea vhlch contained above 5 ppb of TCOO. DISCUSSION AND RECOtMENDATIONS For land where the use is going to be other than residential, a cleanup standard different from one ppb may be appropriate. In evaluating auch non-residential areas judgment must be used as to the likelihood of significant exposure, eaplclally to children, occurring. For example, non-residential areas such as playgrounds, parks, day-care centers, horse arenas or other settings where significant exposure to aoll occur* should have limits similar to residential area*. The EPA Region II ha* satisfactorily divided the areas Into four residential and four commercial zones. They have appropriately Included In the residential zones not only where homes are located, but alao where people congregate for leisure activities, le. the Uayea Park swlmalng pool. Residential zones 2 and 4 are free of contamination above 0.78 ppb. Of the areas of concern In residential area*, all have been recommended for further •tudy, sampling or remediation except one parkway sample In zone one and two parkway sample* in zone three. The EPA abould be very conservative about releasing these sites and do so only with very strong evidence that they represent no threat since these are surface samples la zone* that the KPA o labeled as residential. o The levels proposed by the EPA Regloa II of 5 ppb, or la some situations aa 10 •verage less than 5 ppb, with a celling of 7 ppb seem reasonable for commerclsl zones. The recommended level* are based upon the commercial area* being predominantly industrial with no residential use for leisure activities. •uch aa children playing on the etreets, and that the TOXD contamination resulted from soil spread from other area*, 80 Lister Avenue and the Brady property, resulting In only surface contamination. The surface contamination would be more superficial and transient than soil* contaminated by direct application of oil* which would contaminate deeper soil layer*..This surtace contamination would be expected to present • less chronic exposure threat to the public. It should be, however, the responsibility of the EPA to insure that * new evaluation of the residual TCVO be performed should the lend use la this study area change in the future. This not only include* the change to residential use, but alao leisure usage such as vacant lot* u*ed a* makeshift » c o C 2-5 ^= . ?" •S" p ? 5" 2. S: 2. - Page 5 - Stephen Kargolle, Ph.D playgrounds. These guideline* have been followed In their pl»n"where all areas with contaalnatlon above 7 ppb have been recoanended lor further study » " p> or remediation. However, one area of concern exists. The Newark Carvers' Market was Included In coamerclal sone 4. Since food Is handled and displayed in an open air Banner In this area, the Fanners' Market area of coaaerclal cone 4 should be reviewed with core stringent criteria than other commercial •ress. Areas where food Is prepared, consumed, handled, or stored In an unpack*£ed manner should be considered at least as stringently aa residential areas and levels below 1 ppb may be considered since lnge*tlon of materials contaminated with TCOO may be the largest aourceof exposure. D > O O v^t'aiaatfAa^ai^ftr'feSfaiaSBflffBaJBaeK^^^