FIVE-YEAR REVIEW REPORT

Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Performed by

U. S. Environmental Protection Agency Region 2

SEPTEMBER 2009

With technical assistance from

COM Federal Programs Corporation Under Contract with U.s. Army Corps of Engineers Kansas City District Contents

Executive Summary and Five-Year Review Summary Form ...... E-l Section 1 Introduction ...... 1-1 1.1 Purpose of the Report ...... 1-1 1.2 Site Status...... 1-2 1.3 Organization of the Report ...... 1-4 Section 2 Site Chronology ...... 2-1 Section 3 Background ...... 3-1 3.1 Physical Characteristics ...... 3-1 3.1.1 Site Location and Description ...... 3-1 3.1.1.1 MISS ...... 3-1 3.1.1.2 Stepan Company ...... 3-1 3.1.1.3 Residential Vicinity Properties ...... 3-2 3.1.1.4 Commercial and Government Vicinity Properties ...... 3-2 3.1.2 Geology/Soils ...... 3-2 3.1.3 Topography, Drainage, and Surface Water ...... 3-3 3.2 Land and Resource Use ...... 3-4 3.2.1 Current Land Use ...... 3-4 3.2.1.1 Borough of Maywood ...... 3-4 3.2.1.2 Borough of Lodi ...... 3·5 3.2.1.3 Township of Rochelle Park...... :J..5 3.2.2 Future Land Use ...... 3-5 3.2.2.1 Borough of Maywood ...... 3-6 3.2.2.2 Borough of Lodi ...... 3-6 3.2.2.3 Township of Rochelle Park...... 3·7 3.2.2.4 Reasonably AntiCipated Future Land Use and Selection of Cleanup Criteria ...... 3·7 3.2.3 Surface Water and Groundwater Uses ...... 3·7 3.3 History of Contamination...... :J..8 3.4 Initial Response ...... 3-10 3.5 Basis for Taking Action ...... 3-11 Section 4 Remedial Actions ...... 4-1 4.1 Remedy Selection and Cleanup Criteria ...... 4-1 4.1.1 Remediation Completed During 1984-1985 ...... 4-1 4.1.2 Remediation Completed During 1995-1999 ...... 4-1 4.1.3 Remediation Completed for Properties in the 2003 Record of Decision ...... 4-2 4.1.4 Background Levels of Radionuclides ...... 4-5 4.2 Remedy Implementation ...... 4·6 4.2.1 Remediation Completed During 1984 and 1985 ...... 4-6 4.2.2 Remediation Completed During 1995·1999 ...... 4-7 4.2.3 Remediation Completed for Properties in the 2003 Record of Decision ...... 4-9

ii Table of Contents

4.3 System Operation/Operation and Maintenance ...... 4-11 Section 5 Progress Since Last Review ...... 5-1 Section 6 Five-Year Review Process ...... 6-1 6.1 Administrative Components...... 6-1 6.2 Community In volvement ...... 6-1 6.3 Document Review ...... 6-2 6.4 Data Review ...... 6-2 6.5 Site Inspection and Interview ...... 6-2 Section 7 Technical Assessment ...... 7-1 7.1 Approach of the Technical Assessment...... 7-1 7.1 .1 Radionuclides in 50il...... 7-2 7.1.2 Gamma Exposure ...... 7-3 7.1.3 Radon and Radon Decay Products in 5tructure ...... 7-3 7.2 Phase I Properties Remediated During1984-1985 ...... 7-4 7.3 Phase I Properties Remediated During 1995-1999 ...... 7-5 7.4 Properties in the 2003 Record of Decision ...... 7-6 7.5 Summary of Technical Assessment...... 7-8 Section 8 Issues ...... 8-1 8.1 Phase I Properties Remedia ted During 1984-1985 ...... 8-1 8.2 Phase I Properties Remediated During 1995-1999 ...... 8-1 8.3 Properties in the 2003 Record of Decision ...... 8-2 Section 9 Recommendations and Follow-up Actions ...... 9-1 9.1 Phase I Properties Remediated During 1984-1985 ...... 9-1 9.2 Phase I Properties Remediated During 1995-1999 ...... 9-1 9.3 Properties in the 2003 Record of Decision ...... 9-2 Section 10 Protectiveness Statement ...... 10-1 10.1 Phase I Properties Remediated During 1984-1985 ...... 10-1 10.2 Phase I Properties Remediated During 1995-1999 ...... 10-1 10.3 Properties in the 2003 Record of Decision ...... l0-1 Section 11 Next Review ...... 11-1

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List of Tables

1-1 Property List 4-1 Cleanup Criteria for Phase I Properties -1984 to 1985 4-2 Cleanup Criteria for Phase I Properties - 1995 to 1999 4-3 Cleanup Criteria in 2003 Record of Decision 7-1 Summary of Reviews for Phase I Properties - 1984 to 1985 7-2 Summary of Reviews for Phase I Properties -1995 to 1999 7-3 Summary of Reviews for 2003 ROD Properties 8-1 Summary of Issues for Phase I Properties - 1984 to 1985 8-2 Summary of Issues for Phase I Properties -1995 to 1999 8-3 Summary of Issues for 2003 ROD Properties 9-1 Recommendations and Follow-Up Actions for Phase I Properties - 1984 to 1985 9-2 Recommendations and Follow-Up Actions for Phase I Properties - 1995 to 1999 9-3 Recommendations and Follow-Up Actions for 2003 ROD Properties List of Figures

1-1 Site Map 3-1 Site Location Map 3-2 Land Use Map 3-3 Buildings/Structures, Burial Pits, and Retention Pond Locations 4-1 Phase I Properties Remediated During 1984-1985 4-2 Phase I Properties Remediated During 1995-1999 4-3 Properties in 2003 Record of Decision

List of Appendices

Appendix A Public Notice of Five-Year Review Appendix B List of Reference Documents Reviewed/ Reference Appendix C Post-Remedial Action Data (Provided on DVD only) Appendix D Radiological Survey Reports, Radiological Characterization Reports, Results of the Independent Radiological Verification Survey Post-Remedial Action Reports, and 2007 Annual Monitoring Report (Provided on DVD only) Appendix E Five-Year Review Site Inspection/ Interview Meeting Minutes Appendix F USACE Correspondences to Owners of ROD OU2 Properties Regarding Construction Notification Requests AppendixG Draft USACE Technical Memorandum for Initial Listed Properties Assessment AppendiX H Memorandum of Understanding between USACE and NJDOT aune 9, 2000)

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"_~Co.s.-turoI_,.-...v .. _ .. _ Table of Contents

Acronyms and Abbreviations

AEC Atomic Energy Commission ALARA As Low As Reasonably Achievable ARARs Applicable or Relevant and Appropriate Requirements BNL Bechtel National, me. CDM COM Federal Programs Corporation CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations cae Contaminant of Concern DCGL Derived Concentration Guideline Level DGl'S Differential Global Positioning System DOE U.S. Department of Energy EE/CA Engineering Evaluation/Cost Analysis EPA U.s. Environmental Protection Agency FMSS FUSRAP Maywood Superfund Site FS Feasibility Study FUSRAP Formerly Utilized Sites Remedial Action Program GWS Gamma Walkover Survey lYC Independent Verification Contractor WClP Land Use Control Implementation Plan MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual MCLs Maximum Contaminant Levels MCW Maywood Chemical Works MSL Mean Sea Level MISS Maywood Interim Storage Site NJ New Jersey NJAC New Jersey Administrative Code NJDEP New Jersey Department of Environmental Protection NPL National Priorities List NRC Nuclear Regulatory Commission O&M Operation and Maintenance ORNL Oak Ridge National Laboratory OSWER Office of Solid Waste and Emergency Response OU Operable Unit PIC Pressurized Ionization Chamber POTW Publicly Owned Treatment Works PRAR Post-Remedial Action Report Ra-226 Radium-226 RI Remedial Investigation Rn-222 Radon-222 RAOs Remedial Action Objectives ROD Record of Decision Site FUSRAP Maywood Superfund Site CDM Table of Contents

SU Survey Unit Th-232 Thorium-232 U-238 Uraruum-238 UMTRCA Uranium Mill Tailings Radiation Control Act USACE U.S. Army Corps of Engineers WRS Wilcoxon Rank Sum

Units of Measurement cpm count per minute cy cubic yard It feet in inches mrem/yr millirem per year pCi/g picoCuries per gram pCi/L picoCuries per liter ~R/ h microRoentgen per hour WL working level yd yard Executive Summary and Five-Year Review Summary Form

A five-year review has been performed for the Maywood Chemical Co. Superfund Site (hereafter referred to as the "Site") located in Bergen County, New Jersey (NJ), approximately 12 miles north-northwest of New York City and 13 miles northeast of Newark, NJ. The CERCLIS EPA ID for the Site is NJD980529762. This is the first five­ year review completed for the Maywood Site. The triggering action for the review was the May 5, 2004 initiation of on-site remedial construction activities associated with the Operable Unit 2 (OU2) Soils and Buildings at the Site, as established in the 2003 Record of Decision (ROD). Although the 2003 ROD covers only 24 properties, the U.s. Environmental Protection Agency (EPA) determined that this five-year review should include an evaluation of alI 88 designated properties at the Site, including the 24 OU2 properties and the previously remediated 64 designated properties (hereinafter referred to as "Phase I properties"). The evaluation described herein assesses the protectiveness of the selected remedy for human health and environment. Other OUs for the Site include: OU1 - Stepan Company property and adjoining properties formerly owned by Maywood Chemical Company Works with chemical contamination in soil and groundwater; and OU3 - Groundwater contamination associated with the Maywood Interim Storage Site (MISS) and groundwater contamination associated with thorium processing waste throughout the Site. These two OUs are currently under study and will be evaluated in future five-year reviews.

The Site was added to EPA's Superfund National Priorities List (NFL) on September 8, 1983. The site-specific contaminants of concern include the radionuclides thorium- 232 (Th-232), radium-226 (Ra-226) and uranium-238 (U-238). Contaminated media consist of soil, buried bulk wastes (including the Nuclear Regulatory Commission [NRq-licensed burial pits), and buildings (all contaminated buildings are located on the Stepan property and the MISS), as a result of the former thorium processing activities at the Site. In late 1983, Congress assigned the U.s. Department of Energy (WE) a research and development project to clean up the radioactive wastes at the Site via the FY84 Energy and Water Appropriations Act. Subsequent to the investigation at the Site and surrounding area during 1983, DOE assigned the Site to the Formerly Utilized Sites Remedial Action Program (FUSRAP) in 1984.

DOE, as the lead agency fo r federal actions at the Site, cleaned up 26 Phase I properties during 1984 and 1985. Due to the limited commercial disposal capacity for radiological wastes at the time, the excavated materials from these cleanups were stored on the MISS, which was a part of the original Maywood Chemical Works (MCW) but acquired by OOE in 1985. Additional cleanup activities were performed at the remaining 38 Phase I properties (34 residential properties and four municipal properties), and the previously stored excavated materials on the MISS were transported for off-site disposal during 1995-1999. These interim property cleanups were implemented as removal actions as proposed in OOE's September 1995 Engineering Evaluation/Cost Analysis (EE/CA) under the Comprehensive

CDM E-l Executive Summary

Environmental Response, Compensation, and Liability Act (CERCLA). The interim cleanup actions were completed by the u.s. Army Corps of Engineers (U5ACE) in 2000, who assumed the responsibilities from DOE as lead agency for remedial action at the Site in 1997.

On September 22, 2003, a ROD entitled "Record of Decision for Soils and Buildings at the FUSRAP Maywood Superfund Site" was Signed by EPA, to address contaminated soils and/ or buildings for the remaining 24 designated properties at the Site that had not yet been remediated. The 2003 ROD cleanup criteria in some instances are more stringent than the applicable cleanup criteria for the Phase I properties.

The remedial action objectives for the Site, a5 defined in the 2003 ROD, are to prevent or mitigate further release of FUSRAP waste to the surrounding environment, and to meet the established cleanup criteria and comply with applicable or relevant and appropriate requirements. Of the 24 properties, remedial action has been completed at 18 properties, is ongoing at four other properties, and yet to be addressed at two properties.

The remedial approach used by DOE and later USACE has involved excavation, transportation and off-site disposal of contaminated materials. The remedial actions completed at the Site were documented in post-remedial action reports, which together with the 2003 ROD have been primarily used in this five-year review.

Protectiveness of Remedy

The remedy implemented at those OU2 properties where the cleanup effort achieved the unrestricted use criteria is considered protective of human health and the environment. The remedy being implemented at the OU2 properties is considered protective of human health and the environment in the short-term. The OU2 remedy is expected to be protective of human health and the environment once fully implemented; however, long-term protectiveness of the remedy will require institutional controls for any property where radioactivity remains above the unrestricted use cleanup criteria for soil identified in the 2003 ROO or where remediation of inaccessible soil is deferred until it is rendered accessible in the future. In the interim, protectiveness is being achieved through access controls, property owner notifications, monitoring, existing zoning ordinances, and communication with local officials.

Remedial actions were undertaken by DOE and USACE prior to the 2003 OU2 ROO, utilizing cleanup criteria that in some cases were less stringent than the 2003 ROD criteria. All properties which were not addressed in the 2003 OU2 ROD will be included in a future CERCLA decision document and will be subject to future five­ year reviews.

CDM E-2 Executive Summary

Five-Year Review Summary Form

SITE /DENTIFICA TlON

Site name (from WasteLANJ : Mavwood Chemical Co. SUDerfund Site EPA 10 (from WasteLAN):NJ0980529762 . . k/B . C

SITE STATUS

Ii

o Stale 0 Tri be X Other Federal Agency U.S. Army Corp of Engineers

: EPA 2 with assistance from Kansas District

of site Type of review: X Post-SARA 0 Pre-SARA 0 NPL-Removal only o Non·NPL Remedial Action Site 0 NPl StatefTribe-lead I

Triggering action: X Actual RA On-site Construction at au #_2_ o Actual RA Start at OU# __ o Construction Completion o Previous Five-Year Review Report

Due date

CDM E·3

~ CI>omocaI Co. So-""" Silo "",.v ___ Aopott Executive Summary

Five-Year Review Summary Form, cont'd.

Issues:

- The selected remedyfor soils and buildings as outlined in the 2003 OU2 ROD has not been fully implemented: additional remedial actions and institutionaL controls are needed.

- Remedial actions were undertaken by DOE and USACE prior to the 2003 OU2 ROD, utilizing cleanup criteria that in some instances were less stringent than the 2003 OU2 ROD criteria.

Recommendations and Follow-up Actions:

- Implement Land Use Control Implementation Plan to fulfill the institutional control requirements for any property where radioactivity remains above the 2003 OU2 ROD unrestricted use cleanup criteria for soil or where inaccessible soil contamination remains in place .

• Include properties that were /Wt addressed in the 2003 OU2 ROD in afuture CERCLA decision document. Complete additional property evaluations. as recommended in this Five-Year Review Report, for six Phase I properties.

Protectiveness Statement(s):

_ The remedy implemented at the OU2 properties where the cleanup achieved the unrestricted use criteria is considered protective of human health and the environment.

- The remedy being implemented at the OU2 properties is considered protective of human health and the environment in the short-term.

- The OU2 remedy is expected to be protective of human health and the environment once fully implemented: however, long-tenn protectiveness of the remedy will require institutional controls for any property where radioactivity remains above the 2003 ROD unrestricted use cleanup criteria/or soil or where remediation of inaccessible soil is deferred until it is rendered accessible in the future. In the interim, protectiveness is being achieved through access controls, property owner notifications, monitoring, existing zoning ordinances, and communication with local officials.

Other Comments:

None.

E-4 Section 1 Introduction The United States Environmental Protection Agency (EPA) - Region 2 performed a five-year review of the remedial actions implemented at the Maywood Chemicl't( Co. Superfund Site (hereafter referred to as the "Site"), located in Bergen County, New Jersey (NJ). According to the 1991 Federal Facility Agreement (FFA) fo r the Site, "EPA shall review tire Remedial Action to assure tlml human health and the environment are being protected by the Remedial Action implemented." CDM Federal Programs Corporation (CDM), under Contract No. W912DQ-08-D-0018, with the U.s. Army Corps of Engineers (USACE) - Kansas City District, conducted a detailed technical evaluation and prepared a report in support of this five-year review. 1.1 Purpose of the Report The purpose of the Five-Year Review Report is to document the five-year review processes performed for the Site, as required by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) §121, and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) due to the presence of contaminants remaining at the Site above levels that allow fo r unlimited land use and unrestricted exposure. CERCLA §121 states:

If the President selects a remedial action tltat results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often tlllIn each five years after tire initiation of such remedial action to assure tJllIt humn.n health and tlte environment are being protected by the remedial action being implemented. Tn addition, if Ilpon such review, it is tire judgment of tire President tlmt action is appropriate at such site in accordnnce with section {1041 or (106] of tire NCP, the President shall take or require such action. TIre President slzall report to Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

The U.s. Env ironmental Protection Agency (EPA) interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR) §300.430(f)(4)(ii) states:

If a remedial action is selected that results in Imzardous substances, pollutants, or contaminants remaining at the site above levels tlmt allow for unlimited use and unrestricted exposure, tile lead agency shall review such action no less often than even) five years after tile initiation of the selected remedial action.

This five-year review is considered as a "statutory" review, and is the first five-year review completed for the Site. The triggering action for the review was the May 5, 2004 initiation of Remedial Action construction activities associated with Operable Unit 2 (OU2) of the Site, as established in the September 22, 2003 Record of Decision (ROD). This five-year review evaluates whether threats to human health and the ,., Section 1 Introduction

environment have been addressed through the implementation of the selected remedy, and if specific elements of the remedy are functioning and/ or performing as intended. This Five-Year Review Report will be available for review in the information repositories established for the Site.

The Site consists of a total of 88 designated industriaL residential, commercial, and government properties (refer to Table 1-1). The remedial action for the 2003 ROD does not address the previously remediated 64 designated properties (hereinafter referred to as "Phase I properties"), cleaned up under actions taken by the U.s. Department of Energy (DOE) and USACE. However, this five-year review also includes an evaluation of the actions taken at Phase I properties to help determine whether those properties are still protective of human health and environment based on the 2003 ROD cleanup criteria which, in some cases, are more stringent than the cleanup criteria used by OOE and USACE .. All Phase I properties will be included in a future CERCLA decision document; this Five-Year Review Report will provide the basis for this future decision document.

The property list for the 88 designated properties of the Site is included in Table 1-1 and shown in Figure 1-1. It is important to note that the numerical count of 88 designated properties provided in the 2003 ROD and discussed throughout this Five­ Year Review Report does not include six properties addressed by removal actions due to the incidental discovery of contamination during the remedial action taken at the adjacent designated properties. These six properties have also been addressed in this Five-Year Review Report. 1.2 Site Status The Maywood Site was listed on EPA's National Priorities List (NPL) of Superfund sites on September 8, 1983; EPA Region 2 is the support agency with regulatory oversight responsibilities for the Site. In late 1983, Congress assigned OOE a research and development project to clean up the radioactive wastes at the Site (via the FY84 Energy and Water Appropriations Act). OOE, as the lead agency for federal actions at the Site, began investigating the Site and surrounding area in 1983. As a result of this investigation, OOE assigned the Site to the Formerly Utilized Sites Remedial Action Program (FUSRAP) in 1984. In 1997, the FY98 Energy and Water Development Appropriations Act transferred responsibility for the execution and administration of FUSRAP from DOE to USACE. During 1999, the USACE took over as lead agency for federal actions at the Site, and began naming the project site the "FUSRAP Maywood Superfund Site" or "FMSS."

During 1984 to 1985, DOE completed removal actions at 26 designated properties (25 residential properties and a portion of commerCially zoned property). Removal actions at the remaining 38 designated Phase I properties were initiated in 1995, according to DOE's September 1995 Engineering Evaluation/Cost Analysis (EE/CA) under CERCLA. These interim cleanup actions were completed in 2000 by USACE. In 2001, the USACE initiated work under another EE/CA for a Removal Action in

COM 1-2 Section 1 Introduction

Support of New Jersey Department of Transportation (NJOOn Roadway Improvement Projects at the Site.

EPA is addressing the remediation of the Site in a phased approach under separate Operable Units (OUs) according to the following:

• OU1 - Stepan Company property and adjoining properties formerly owned by Maywood Chemical Company Works (MCW) with non-FUSRAP related chemical contamination in soil and groundwater. The Stepan Company, a responsible party, is currently preparing a Feasibility Study under both an administrative order on consent and an administrative order for OU1 soil and groundwater.

• OU2 - The remediation of contaminated soil, debris (e.g., buried drums), and building materials as defined as FUSRAP waste in the FF A at the former MCW and commercial/ government properties in the vicinity of the former MCW, including but not limited to the Stepan Company burial pits that are licensed and regulated by the Nuclear Regu latory Commission (NRC).

• OU3 - Groundwater contamination associated with the MISS and groundwater contamination associated with FUSRAP waste (as defined in the 1991 FAA) throughout the Site. USACE is currently preparing a Feasibility Study and Proposed Plan for this OU.

Although the USACE and Stepan Company are independently preparing decision documents under CERCLA, EPA is overseeing and coordinating actions for all three Operable Units.

In September 2003, EPA signed the OU2 ROD for Soils and Buildings, addressing the 24 remaining designated properties. USACE, as lead agency for federal actions at the Site, is implementing the remedial action for the OU2 properties. These properties include the Maywood mterim Storage Site (MISS), Stepan Company, and 22 commercial and government properties. Included in the remediation are the contaminated buildings on the Stepan Company property and the MISS that meet the definition of FUSRAP waste. Several of these properties are known or suspected to have contaminated soils under permanent structures such as buildings; therefore, these soils are considered inaccessible and will be addressed at a later time when the property owners make these soils accessible. Of the 24 properties, remedial action has been completed at 18 properties, is ongoing at four other properties, and yet to be addressed at two properties. Current work is being executed under the 2003 ROD with close coordination with EPA and the New Jersey Department of Environmental Protection (NJDEP) and extensive public review and comment.

The 2003 ROD addresses the radiologically and chemically contaminated wastes in soils and buildings, as defined as FUSRAP waste. Under the terms of the FFA, FUSRAP waste consists of:

1-3 Section 1 Introduction

• All contamination, both radiological and chemical, whether mixed or not, on the Maywood mterim Storage Site. The MISS is the 11.7-acre property acquired by DOE to store excavated materials due to the limited commercial disposal capacity for radiological wastes at the time.

• All radiological contamination above cleanup levels related to past thorium processing from the Maywood Chemical Works occurring on any of the vicinity properties.

• Any chemical or non-radiological contamination on vicinity properties that would satisfy either of the following requirements:

The chemical or non-radiological contaminants that are mixed or commingled with radiological contamination above cleanup levels.

The chemical or non-radiological contaminants that originated at the MISS or were associated with the specific thorium manufacturing or processing activities at the MCW that resulted in the radiological contamination. 1.3 Organization of the Report This Five-Year Review Report has been prepared in accordance with the Comprehensive Five-Year Review Guidance, Office of Solid Waste and Emergency Response (OSWER) Directive 933S.7-03B-P, dated June 2001. The report is comprised of ten sections as described below.

Section 1 - Introduction provides a summary of the purpose of the review; the party who conducted the review; when the review was initiated and completed; whether it is the first review or a subsequent review at the Site; and the Site status including the different OUs and remedial actions completed.

Section 2 - Site Chronology provides a chronology of the major historical investigations and removal! remedial actions completed at the Site.

Section 3 - Background provides a summary of Site background information including the Site location and description, physical characteristics, land and resource use, history, initial response, and summary of basis for taking action.

Section 4 - Remedial Actions present a summary of remedy selection and implementation, as well as system operations! operation & maintenance (O&M), if any.

Section 5 - Progress Since Last Review presents a summary of the progress made since the last review conducted for the Site, if applicable.

Section 6 - Five-Year Review Process presents various aspects of the review process, including administrative components, community involvement, document review, data review, Site inspection, and Site interviews.

'·4 Section 1 Introduction

Section 7 - Technical Assessment provides an evaluation of the current Site status with respect to whether or not (1) the remedy is functioning as intended by the decision documents, (2) exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy are still valid, and (3) any other information has come to light that could call into question the protectiveness of the remedy.

Section 8 - Issues present a summary of the issues identified as a result of the five­ year review and evaluation of respective impacts on current or future protectiveness.

Section 9 - Recommendation and Follow-up Actions include recommendations for future actions, and identifies follow-up actions to ensure protectiveness, parties responsible for implementation, agencies with oversight authority, and schedule for completion.

Section 10 - Protectiveness Statement presents the conclusion as to the protectiveness assessment of the Site.

Section 11- Next Review provides a schedule when the next five-year review is to be completed.

COM '-5

_C_Co . ~SiIIo,..,.y ... __ Section 2 Site Chronology The Maywood Site has been the subject of numerous environmental investigations and remediation work dating back to early 19605, as a result of the inspections performed by the Atomic Energy Commission (AEC), the predecessor agency to NRC, related to the property west of NJ State Route 17 (now known as the % Parkway property).

A brief description of the historical investigation/remediation progress and chronology is presented as follows.

• 1954 - Maywood Chemical Works receives Atomic Energy Commission License R- 103 for thorium possession, processing, and fe-sale.

• 1956 - Processing of monazite sands for rare earths and thorium ceases.

• 1957 - AEC License R-I03 expires.

• 1959 - Stepan Chemical Company buys MeW and applies for AEC license " to cover OUf operations as processors and exporters of source material." Application states "active manufacturing in the Thorium Plant is at a stand still."

• 1%3 - Stepan was issued an AEC radioactive materials license in 1961, and on the basis of AEC inspections and information related to the property west of NJ State Route 17, Stepan agreed to take certain corrective actions and began to clean up residual thorium wastes in 1%3, partially stabilizing residues and tailings.

• 1966 through 1968 - Stepan removed a total of approximately 19,100 cubic yards (cy) of contaminated soils from the property west of NJ State Route 17 and buried them in three burial pits (1, 2 & 3) on the Stepan property.

• 1968 - The property west of NJ State Route 17 was surveyed and certified by AEC for use without radiolOgical restriction, and eventually sold to Ballod Associates. However, AEC was apparently not aware of the presence of contaminated waste materials in the northeastern corner of the property at the time of the survey.

• 1980 - The presence of contaminated waste materials in the northeastern corner of the Ballod property was revealed by the New Jersey Department of Environmental Protection, and the contaminants were identified as thorium-232 (Ih-232) and radium-226 (Ra-226). The NRC was notified of the findings and hence undertook additional surveys from November 1980 to January 1981, which confirmed high concentrations of Th-232 in soil samples collected from both the Stepan and Ballod properties.

• January 1981- At the request of NRC, an aerial radiological survey of the Stepan property and surrounding properties, covering an area of 3.9 square miles, was

CDM 2·' Section 2 Site Chronology

conducted by EG&G Energy Measurements Group. The survey indicated that contamination was present not only on the Stepan and Ballod properties, but also in areas north and south of the BaUod property.

• 1981 - A survey program was implemented by Oak Ridge National Laboratory (ORNL) in the vicinity of the Stepan property. The surveyed properties were along Davison Avenue and Latham Street. Based on the survey results, seven of the surveyed properties were designated the same year for remedial action, with one additional property on Davison Avenue designated in 1986 (refer to Table 1-1).

• September 1983 - EPA added the Site to the Superfund National Priorities List. In late 1983, Congress assigned DOE a research and development project to clean up the radioactive wastes at the Site (via the FY84 Energy and Water Appropriations Act).

• 1983 to 1984 - ooE began investigating the Site and surrounding area. Vicinity properties on Grove A venue and Parkway in Rochelle Park were surveyed in late 1983, and nine of the surveyed properties were designated for remedial action as a result (refer to Table 1-1). In addition, a "drive-by" survey followed by ground surveys that included limited sampling was completed for properties in Lodi.

• 1983 - ooE assigned the Site to FUSRAP; the Site consists of a total of 88 designated industrial, residential, commercial, and government properties (refer to Table 1-1).

• 1984 to 1985 - Approximately 35,000 cy of contaminated materials were removed from the Ballod property and from 17 vicinity properties on Davison Avenue, Latham Street, Grove A venue, and Parkway in Maywood and Rochelle Park. An additional 500 cy of contaminated materials were removed from eight vicinity properties located on Avenue C, Avenue F, Hancock Street, and Trudy Drive in Lodi, and another portion of the Ballod property in Rochelle Park. The removed materials were stored in a protective enclosure cell in 100 West Hunter Avenue (now known as the MISS) which OOE acquired in 1985 to expedite cleanup of the vicinity properties. Refer to Table 1-1 for the detail of the properties that were involved.

• 1991 - A time-critical removal action was undertaken by OOE to decontaminate one additional residential property in Lodi (90 Avenue C) due to the significantly elevated Gamma exposure rates measured inside the residence.

• December 1992 - DOE issued Remedial Investigation Report for the Maywood Site.

• 1994 to 1995 - Additional cleanup criteria for the radionuclide contamination in soil at the Site were established (in 1(94). ooE implemented interim property cleanups as removal actions as proposed in the September 1995 Engineering Evaluation/Cost Analysis (EE/CA) for the Cleanup of Residential and Municipal Vicinity Properties at the Maywood Site, Bergen County, New Jersey under CERCLA.

CDM 2-2 Section 2 Site Chronology

• 1995 to 1997 ~ The cleanup of the fourteen residential properties, four municipal properties (three parks and a fire station), and one commercially zoned property (96 Parkway) was initiated. Previously stored excavated materials were removed from the MISS and sent to a permanent, off~site commercial disposal facility.

• 1997 ~ The FY98 Energy and Water Development Appropriations Act transferred responsibility for the execution and administration of FUSRAP from DOE to U5ACE. The inclusion of chemical contaminants under the site definition of FUSRAP waste is limited to chemicals on the MISS or chemicals on vicinity properties that are commingled with or related to the radioactive waste, chemicals associated with thorium processing at the Site, and chemicals on or migrating from the MISS.

• 1997 through 1999 ~ USACE performed remediation of the remaining 2'3 vicinity properties (refer to Table 1~ 1). During these cleanup actions, an additional five properties in Lodi and Maywood were remediated as the contamination extended onto adjacent undesigrtated properties.

• 2000 ~ A time critical removal action was completed by USACE during the winter of 2000 to remove contaminated sediments from portions of Lodi Brook and a swale located at the terminus of West Howcroft Road. The removal action re~established the hydraulic grade of the brook and swale, prevented additional flooding, and prevented the transport or migration of contaminated soil by flooding water.

• November 2001 ~ USACE issued Engineering Evaluation/Cost Analysis for a Removal Action in Support ofNJDOT Roadway Improvement Projects at the FUSRAP Maywood Superfund Site (FMSS).

• August 2002 ~ The Feasibility Study for Soils and Buildings at the FUSRAP Maywood Superfund Site was completed and submitted for public comment along with the Proposed Plan for Soils and Bui/dings at the FUSRAP Maywood Superfund Site.

• September 2003 - EPA signed the ROD for OU2 that addresses contaminated soils and buildings at the 24 remaining properties of the original 88 designated properties (refer to Table 1-1).

2-3 Section 3 Background 3.1 Physical Characteristics 3.1.1 Site Location and Description The Maywood Site consists of 88 designated industrial, residential, commercial, and government properties contaminated by former thorium processing activities at the Site. The properties are located in a highly developed area of northeastern NJ in the Boroughs of Maywood and Lodi and the Township of Rochelle Park. The Site is located approximately 12 miles north-northwest of New York City and 13 miles northeast of Newark, NJ (Figure 3-1). A site map is shown on Figure 1-1. The Remedial Investigation divided the Site into four property units based on land use:

• Maywood Interim storage Site

• Stepan Company

• Residential vicinity properties

• Commercial and government vicinity properties

3.1.1.1 Maywood Interim Storage Site The MISS is an 11.7-acre fenced lot that was previously part of a 3D-acre property owned by the Stepan Company (Figure 1-1). The federal government acquired the MISS from the Stepan Company in 1985. The MISS contains two buildings (Building 76 and a Pump House), temporary office trailers, a water reservoir, and two railroad spurs. The water reservoir and Pump House are still in use by Stepan. It is bounded on the west by NJ State Route 17; on the north by a New York, Susquehanna, and Western Railway line; and on the south and east by Stepan Company property. Residential vicinity properties are located north of the railroad line and within 300 yards (yd) to the north of the MISS. The topography of the MISS ranges in elevation from approximately 51 to 67 feet (ft) above mean sea level (msl). The highest elevations are in the northeastern portion of the property. A chain-link fence encloses the property. Access is restricted within the fenced area.

3.1.1.2 Stepan Company The Stepan Company, a pharmaceutical and chemical manufacturer that purchased the former Maywood Chemical Works property in 1959, is located at 100 West Hunter Avenue in the Borough of Maywood (Figure 1-1). The property covers 18.2 acres. The topography of the property has been modified into a series of terraces to accommodate construction of the operating facility. Topographic relief from the highest terrace at the north side to the lowest terrace at the south side of the property is about 25 f1. Approximately two-thirds of the property contains buildings. Former thorium processing buildings were located on the present-day MISS. The Stepan property contains the three NRC-licensed burial pits. A chain-link fence encloses the property (excluding the main office and parking area) and access is restricted within

CDM 3-1 Section 3 Site Background

the fenced area. West Hunter Avenue is lined with small businesses, as is a portion of nearby Maywood Avenue. The area east of Maywood Avenue from the Stepan property is predominantly residential. To the north and northeast, a New York, Susquehanna, and Western Railway line and numerous residential vicinity properties border the property. Various commercial properties border the Stepan Company property to the south and southwest. The MISS adjoins the Stepan property on the west and northwest.

The OU2 ROD identified two buildings on the Stepan property (Buildings 1 and 78) and one on the MISS (Building 76) which will require remediation and several which require additional characterization. In all contaminated buildings, the radioactivity is fixed in place and is not transferabl/i!. The primary route of exposure for fixed contamination is direct exposure to gamma radiation. Environmental monitoring is being undertaken to ensure that workers and the surrounding community are protected.

3.1.1.3 Residential Vicinity Properties Fifty·nine designated residential vicinity properties at the Site are located in the Boroughs of Maywood and Lodi, and the Township of Rochelle Park (Figure 1.1). OOE identified these properties through surveys performed by Oak Ridge National Laboratory (ORNL) (ORNL 1984). The residential vicinity properties were contaminated by transport of soil by surface water runoff along former stream channels or by use of contaminated material as fill and mulch.

3.1.1.4 Commercial and Government Vicinity Properties Commercialj government vicinity properties are comprised of 27 properties, located in the Boroughs of Maywood and Lodi, and the Township of Rochelle Park (Figure 1· 1). Of these 27 properties, 20 are commercial properties, four are municipal properties (three parks and a fire station), and the remaining three are State· and Federally. owned properties (right-{)f-way and an embankment for Interstate 80, a NJ State Route 17 embankment, and a New Jersey Vehicle Inspection Station).

Two of the commercial properties (96 Parkway and 149-151 Maywood Avenue) and one government property (NJ State Route 17) were originally part of MCW and were used for waste storage and burial. The remaining commercial and all government properties were believed to have been contaminated by transport of soil by surface water runoff along former stream channels or by use of contaminated material as fill and mulch. The majority of the contaminated material is soil; however, there are isolated areas where stream or wetlands sediments were contaminated.

3.1.2 Geology/Soils The bedrock underlying the Site is divided into two distinct units· bedrock composed of the Triassic- to Jurassic-age Passaic Formation, and overburden of unconsolidated glacial till. The Passaic Formation, which reaches a maximum thickness in excess of 8,000 ft, is part of a 33,800 ft sequence of sediments deposited in the Newark Basin

CDM 3·2 Section 3 Site Background

during the Triassic and Jurassic time periods. The Passaic Formation consists of inter layered dark to moderate red-brown, fine-grained sandstones and siltstones. Beds exhibit a monoclinal dip of 10 to 15 degrees northwest and contain shallow open folds.

The northeast-trending Ramapo Fault that marks the westerly margin of the Newark Basin bound minor north-trending fau lts in the Triassic formations to the northwest. The Ramapo Fault at its nearest location is about 13 miles west-northwest of the Site. Minor faults, fractures, and join ts are prevalent throughout the Newark Group. A prominent set of joints parallels the strike of beds and dips steeply; another less prominent set parallels the northwest direction of dip. Bedrock topographic lows at the Site show alignment to northwest and northeasterly trends that are prol;>ably the result of bedrock weakness caused by joining in the Triassic Formations. At the Site, beds of the Passaic Formation also exhibit extensive weathering, and horizontal jointing in this formation is probably related to weathering.

Unconsolidated material overlying the weathered bedrock consists of sands, silts, and clays deposited as a result of glaciating during the Pleistocene time period. The thickness of unconsolidated sediments varies over the Site. Bedrock is within six inches (in) of the surface near the northern end of the Stepan property where there is a pronounced bedrock high. The overburden reaches a maximum thickness of over 25 ft in a downcut channel on the MISS property.

Unconsolidated deposits are loosely divided into three groups at the Site - a lower unit of fine grained sands and silts with occasional coarse gravels and sands, a middle unit of clays and silts with occasional organic-rich soil horizons, and an upper unit of undifferentiated sands and silts, which is much disturbed by urban development. Erosional lows that downcut into bedrock contain sands and gravels are probably of fluvial origin. This sequence of deposits is interpreted as being deposited from streams and lakes that originated from glaciers to the north. Periodically, during the advance and retreat of glaciers, the environments of deposition would change, which has resulted in the glacial sediments exhibiting a high degree of lithologic variability, both vertically and hOrizontally. In some cases, streams originating from glaciers cut valleys into existing sediments. The location and orientation of these valleys were probably controlled by weaknesses in the bedrock geology.

Historically, the glacial deposits of the Maywood area were capped with a well­ developed deciduous forest soil. Extensive agricultural and urban development has destroyed or disturbed much of the original soil and most of the current soil cover is classified as urban fill.

3.1.3 Topography, Drainage, and Surface Water The Site is located in the glaciated section of the Piedmont Plateau of north-central NJ. The terrain is generally level, with highs and lows created by occasional low mounds and shallow ditches. Elevation ranges from 51 to 67 ft above ms!. The surface slopes gently to the west and is poorly drained.

3-3 Section 3 Site Background

The Site lies primarily within the Saddle River drainage basin. The MISS is located about 0.5 mile east of the Saddle River, which is a tributary of the Passaic River, and about one mile west of the drainage divide of the Hackensack River basin. Rainwater runoff from most of the MISS empties into the Saddle Ri ver through Westerly Brook, which flows under the property and under NJ State Route 17 through a concrete culvert. It eventually empties into the Saddle River. Neither the Saddle River nor Westerly Brook is used as a source of potable water.

Another pereJUlial stream on the Site, LOOi Brook, originates as two branches on the 149-151 Maywood Avenue property. Because of construction, most of the original stream channel has been replaced by a storm drain system beneath the surface. The original stream channel has been determined from old photographs and maps. The former channel pathways basically match the distribution of contaminated materials in the Borough of Lodi. Contaminated materials were transported from the MISS via sediment deposition. A structure and parking lot at 149-151 Maywood Avenue currently cover the western branch of Lodi Brook. The easternmost branch drains the surface area outside the fence on this property and then flows underground for most of its route to the Saddle River. Some surface runoff from the MISS moves parallel to NJ State Route 17 and drains into Lodi Brook. LOOi Brook empties into the Saddle River, downstream of the Westerly Brook confluence with the Saddle River. The 111 Essex Street property lies adjacent to Coles Brook. Coles Brook flows north-northeast and is part of the Hackensack River basin. 3.2 Land and Resource Use The Site is located in three communities - the Borough of Maywood, the Borough of Lcdi, and the Township of Rochelle Park. Figure 3-2 shows the land use for the Site properties. 3.2.1 Current Land Use Land use planning is guided principally by Municipal Land Use Law (Chapter 291, Laws of New Jersey, 1976) which requires municipalities to re-examine and update their Master Plans and development regulations every six years. It establishes rules, regulations, and procedures for creating municipal planning and zoning boards. It also provides these boards with guidelines for creating zoning ordinances, master plans, and other planning tools. The Borough of Maywood Master Plan was last revised in 1995; the Borough of Lodi Master Plan was last revised in 1994; and the Township of Rochelle Park Master Plan was last revised in 1997.

3.2.1.1 Borough of Maywood Land use at the MISS, Stepan Company, and the 14 commercial and government vicinity properties located in the Borough of Maywood is currently zoned for limited light industrial activities. Most of the Borough of Maywood, including the 10 residential vicinity properties, is zoned for residential use. Industrial land uses comprise about nine percent of the total land area of the Borough of Maywood. This

CDM 3·4 Section 3 Site Background

classification permits light manufacturing operations as well as the related functions of processing, wholesaling, warehousing, and storage of goods.

3.2.1.2 Borough of Lodi Land use on the eight commercial and government vicinity properties located in the Borough of Lodi is currently zoned for commercial and industrial use. Most of the Borough of Lodi, including the 44 residential vicinity properties, is zoned for residential use. Commercial and industrial land uses comprise about 15% and 13%, respectively, of the total area of the Borough of Lodi. These commercialj government properties are contained within defined commercial and industrial land use areas. However, many properties are located immediately adjacent to residential or recreational use areas. The commercial use classification in Lodi permits smaller commercial buildings, convenience stations, planned shopping centers, auto-related establishments, retail stores, and restaurants. The industrial use classification permits food processing and manufacturing, automotive-related uses, communications, and a variety of light manufacturing, office, and warehouse uses.

3.2.1.3 Township of Rochelle Park Land use for the portion of the MISS, Stepan Company, and the 149-151 Maywood Avenue property that are located in the Township of Rochelle Park are currently zoned for industrial use. One other commercial property, 96 Parkway, is also currently zoned for industrial use. Most of the Township of Rochelle Park, including the nine residential vicinity properties, is zoned for residential use. The commercial and industrial land uses comprise about 17% of the total land area of the Township of Rochelle Park. This classification permits retail trade and service establishments, eating and drinking establishments, business and professional facilities, banks and financial institutions, municipal buildings and facilities, child-care centers, storage, warehouses, truck terminals, and light manufacturing. 3.2.2 Future Land Use Reasonably anticipated future use of the land at the Site is an important consideration in determining the appropriate extent of remediation. Future use of the land will affect the types and the frequency of exposures that may occur from any residual contamination remaining on the Site, which in turn affects the nature of the remedy chosen. The factors used to determine the reasonably anticipated future land use were as follows:

• Current land use

• Reasonable foreseeable future land use

• Comprehensive community master plans

• Population growth patterns and projections (e.g., Bureau of Census projections)

• Institutional controls currently in place

COM 3·5 Section 3 Site Background

• Site location in relation to urban, residential, commercial, industrial, agricultural, and recreational areas

• Federal/State/local land use designation

• Historical development patterns

These criteria were used to evaluate the properties in the Boroughs of Maywood and Lodi and the Township of Rochelle Park as discussed below.

3.2.2.1 Borough of Maywood Historically, the southern area of the Borough of Maywood has been zoned for light industrial use, and continues to experience an increase in population. The Maywood Master Plan has a well-defined industrial development area and the properties addressed by the 2003 ROD are all located within that zone. The New York, Susquehanna, and Western Railway separate this light industrial area from a mixture of residential. commercial, and light industrial properties to the north, Interstate 80 to the west, Essex Street to the south, and Maywood Avenue to the east. The Maywood Master Plan recommends maintaining the light industrial zoning classification for all properties except for the MISS, where a commercial, high-rise zoning designation has been recommended.

From 1970 to 1990, the total population in the Borough of Maywood, and Bergen County as a whole, declined, and then experienced a slight population increase from 1990 to 2000. This 20-year period of population loss has been attributed to a decrease in household size rather than emigration. The Borough of Maywood is a community that is 98 % developed, with very little vacant or unused land. However, there is vacant land in other parts of Bergen County, allowing for some growth in the county. A review of population characteristics and development projects within the area has indicated a generally stable Borough population through 2000. The July 1998 Census Bureau population estimate for Bergen County is 858,529, a 4 % increase since 1990. This same report estimates the population for the Borough of Maywood at 9,694, a 1.7% increase since 1990. Because of this, no major increase in demand for additional housing is anticipated.

No cultural resources, environmental justice issues, wetlands, floodplains, or critical habitats of endangered or threatened species have been identified that would impact the current limited light industrial zoning.

3.2.2.2 Borough of Lodi The remaining Borough of Lodi contaminated vicinity properties have historically been zoned commercial and ind ustrial. The Borough of Lodi Master Plan has well­ defined commercial and industrial development areas. The Master Plan recommends maintaining the current land uses for all properties.

3·6

_.. - Section 3 Site Background

From 1970 to 1990, the total population in the Borough of Lodi, and Bergen County as a whole, declined, and then experienced a slight population increase from 1990 to 2000. According to the 2000 Decennial Census, population for the Borough of Lodi is 23,971, a 7.2% increase from the 1990 figure of 22,355 (www.census.gov). Because the population of much of the surrounding area is expected to remain stable, no major increase in demand for additional housing is anticipated.

No cultural resources, environmental justice issues, wetlands, floodplains, or critical habitats of endangered or threatened species have been identified that would impact the current commercial or industrial zoning.

3.2.2.3 Township of Rochelle Park The Township of Rochelle Park Master Plan has well-defined commercial and industrial development areas. The Master Plan recommends maintaining the current land uses for all site properties.

From 1970 to 1990, the total population in the Township of Rochelle Park, and Bergen County as a whole, declined. According to the 2000 Decennial Census, the population of the Township of Rochelle Park is 5,528, a 1.1 % decrease from the 1990 figure of 5,587 (www.census.gov). Because the population of much of the surrounding area is expected to remain stable, no major increase in demand for additional housing is expected.

No cultural resources, environmental justice issues, wetlands, floodplain, or critical habitats of endangered or threatened species have been identified that would impact the current industrial zoning.

3.2.2.4 Reasonably Anticipated Future Land Use and Selection of Cleanup Criteria Reasonably anticipated future land use and cleanup criteria to be used for individual properties are listed on Table 1·1. 3.2.3 Surface Water and Groundwater Uses Much of the former surface water drainage patterns responsible for the spread of contamination at the Site have now been re·channeled and placed in culverts. Rainwater runoff from most of the MISS empties into the Saddle River via Westerly Brook, which flows under the property and under NJ State Route 17 through a concrete culvert. It eventually empties into the Saddle River. Neither the Saddle River nor Westerly Brook is used as a source of potable water.

Another perennial stream on the Site, Lodi Brook, originates as two branches on the 149·151 Maywood Avenue property. Because of construction, most of the original stream chaMel has been replaced by a storm drain system beneath the surface. The original stream channel has been determined from old photographs and maps. The former channel pathways match the distribution of contaminated materials in the Borough of Lodi. A structure and parking lot at 149·151 Maywood Avenue currently

CDM 3·7 Section 3 Site Background

cover the western branch of Lodi Brook. The easternmost branch drains the surface area outside the fence on this property and then flows underground for most of its route to the Saddle River. Some surface runoff from the MISS moves parallel to NJ State Route 17 and drains into Lodi Brook. Lodi Brook empties into the Saddle River downstream of Westerly Brook's confluence with the Saddle River. The 111 Essex Street property lies adjacent to Coles Brook. Coles Brook flows north-northeast and is part of the Hackensack River basin.

Surface water at the Site is not currently impacted by Site radiological contaminants, nor is a future impact expected. This is due to the relatively inunobile nature of the contaminants and the stable configuration of the contaminated soils (areas are either paved, grassed, wooded, or covered by buildings and other structures that limit the transport of contaminated soils by surface waters). Current surface water use is not projected to change significantly in the furore.

Groundwater at the Site occurs in both the bedrock Passaic Formation and the unconsolidated glaCial deposits. The Passaic Formation, classified as Class II, is a productive aquifer that is a major source of water for publiC and industrial use. However, groundwater is generally not used for municipal water supply in the lower Saddle River Basin, and the bedrock aquifer in the vicinity of the Site is not currently used for drinking water or other domestic use.

Groundwater is outside the scope of this five-year review. Additional characterization and studies are underway to determine potential remedies for groundwater contamination in connection with the other OUs. Future five-year reviews will evaluate groundwater conditions at the Site. 3.3 History of Contamination The original plant, which became known as the Maywood Chemical Works after incorporation on December 24, 1918 under the laws of the State of New Jersey, was constructed in 1895. The principal products manufactured by MCW included chemicals used in the pharmaceutical, food, glass, soap, and metals industries (Barnum 1942). Starting in 1916, the plant was used to extract thorium and rare earth metals from monazite sands for use in manufacturing industrial products, such as mantles for gas lanterns. Thorium and rare earth metals were extracted from the monazite sands using an acidic separation process. The wastes from this process were pumped as slurry to holding ponds. Wastes from these ponds were later transferred into Burial Pits 1 and 2. The liquid portions of the ponds containing the thorium and rare earth metals were separated from the tailings, and thorium was separated from the rare earth metals. Some concentrated thorium residues were pumped into a holding pond where the thorium portion of the residues was precipitated as a phosphate. Wastes from this holding pond were later transferred into Burial Pit 3. The approximate locations of these holding ponds and burial pits are depicted on Figure 3-3.

3-8

"oyvox:dC_eo -.... SIlo ~.y ___ ~ Section 3 Site Background

Process wastes from the thorium extraction operations were pumped into two areas surrounded by earthen dikes on property west of the plant. In 1932, the disposal areas were partially covered by the construction of NJ State Route 17. Waste retention ponds existed on portions of MeW that now comprise % Parkway, the MISS, and 149·151 Maywood Avenue. MeW also produced detergents, alkaloids, essential oils, and lithia ted compounds, including lithium chloride and lithium hydroxide. MeW owned and operated mining properties in the vicinity of Keystone, South Dakota, which produced lithium ore that was transported to the Maywood facility and processed. Lithium wastes were believed to have been disposed in diked areas on the MeW property. Protein extraction from leather digestion was also carried out by MeW. Leather wastes are believed to have been buried in two primary shallow disposal areas on Stepan, just east of the MISS property boundary.

According to a 1942 memorandum, the products manufactured by MCW could be broken down into six major groups - aromatics, flavorings, lithium metal and salts, pharmaceuticals, rare earth salts, and miscellaneous products.

• The principal products of the aromatic group are Ionone and Iraldiene (methylated Ionone) and were used mainly in the soap industry. The raw material, for the most part, consisted of lemongrass oil imported from India.

• The principal products of the flavorings group were Coumarin (manufactured by MeW as a coal tar derivative), and Vanillin, which is a synthetic vanilla made from cloves imported by Mew from Zanzibar. Vanillin was also synthesized from orthoanisidene and para-phenetidene.

• Lithium was manufactured by MeW in at least 30 forms. Spodumene ore was brought from mines owned and operated by the company in South Dakota; lithium was then extracted. from the ore at MeW. Lithium was used for the purification of other metals, for the manufacture of storage batteries, and for military purposes.

• The principal pharmaceuticals manufactured by MCW were quinine, cocaine, theobromine, acetanilid, and caffeine.

• Rare earth salts were derived from monazite sands that MeW imported, primarily from India. The most important rare earths manufactured by MCW were cerium, lanthanum and neodymium. These products were used, for the most part, by the glass industry. Thorium was also derived from the monazite sands, and sold for use in the manufacturing of thorium mantles for lanterns. Cerium was also used as an important ingredient in gas mantle coatings.

Process wastes from these manufacturing processes were generally stored in open piles and retention ponds on the MeW property. Some of the process wastes were removed for use as mulch and fill on nearby properties, thereby contaminating those properties with radioactive thorium. Although the fill consisted primarily of tea and

3-9 Section 3 Site Background

coca leaves from other Mew processes, these materials were apparently contaminated with the thorium-processing wastes.

Additional waste migrated off the property via natural drainage associated with the former Lodi Brook. Historical photographs and maps indicate that the former course of the brook, which originated on the MeW property in the area that is now 149-151 Maywood A venue, generally coincides with the distribution of contaminated properties in the Borough of Lodi. Most of the open stream channel in Lodi was replaced by a storm-drain system in the 1%05.

Mew ceased thorium extraction in 1956, after approximately 40 years of production. The property was subsequently sold to the Stepan Company in 1959. 3.4 Initial Response As Section 2 already provides a brief description of the historical investigation, remediation progress and chronology of actions undertaken at the Site, this section w ill focus only on critical events that are associated with initial response.

In 1961, the Stepan Company was issued an AEC radioactive materials storage license. (The AEC was a predecessor agency to the NRC.) This was based on AEC inspections and information related to the property on the west side of NJ State Route 17 (known currently as the % Parkway property which was also referred to as the Ballad property). Stepan subsequently began cleaning up the residual thorium wastes. From 1966 through 1968, Stepan removed residues and tailings from the area east of NJ State Route 17 and the 96 Parkway property, and reburied them on the Stepan property in Burial Pits 1, 2, and 3. In 1968, AEC conducted a survey of the area west of NJ State Route 17 and certified it for use without radioactive restrictions. At the time of the survey, AEC apparently was not aware of waste materials still present on the property. The Stepan property west of NJ State Route 17 was sold in the same year to a private citizen who later sold it to Ballad Associates in the 1970s.

The presence of radioactive materials in the northeast corner of the % Parkway property was discovered in 1980, after a private citizen reported the presence of radioactivity near NJ State Route 17 to the New Jersey Department of Environmental Protection. A survey of the area (NT State Route 17, % Parkway property, and Stepan property) conducted by NJDEP found thoriurn-232 (Th-232) and radium-226 (Ra-226). NRC was notified of the results and additional surveys were completed from November 1980 to January 1981. These surveys confirmed high concentrations of Th- 232 in soil samples collected from both the Stepan and % Parkway properties. Accordingly, NRC requested a comprehensive survey of the area. NRC was notified because of its involvement with Stepan's licensed thorium activities and AEC's previous release of the area west of NJ State Route 17 for use without radiological restrictions.

In January 1981, NRC arranged for an aerial radiological survey of the Stepan property and surrounding properties. The survey, which covered a 3.9-square mile

COM 3-10 Sectioll3 Site Background

area, indicated the presence of radioactivity not only on the Stepan and 96 Parkway properties, but also in areas to the north and south of the 96 Parkway property. During February 1981, NRC also performed a separate radiological ground survey of the % Parkway property, the results of which evenrually led to its designation for remedial action under FUSRAP. An additional radiological survey of the Stepan and 96 Parkway properties, commissioned by the Stepan Company, produced similar findings.

By enacting a provision of the fiscal year 1984 Energy and Water Development Appropriations Act, Congress authorized OOE to undertake a decontamination research and development project at the Site in late 1983. Accordingly, a portion of the Site was assigned to FUSRAP, and OOE obtained access to an l1.7·acre portion of the Stepan property for use as an interim storage facility for materials that were to be removed from vicinity properties. This area is now known as the MISS. In late 1983, DOE began surveys of properties in the vicinity of the former MCW plant.

In 1984 and 1985, DOE conducted removal actions at 25 properties and placed the waste in a temporary storage pile on the MISS. At that time, commercial disposal facilities were not available for the volume of radioactive waste generated by the cleanup. In September 1985, ownership of the MISS was transferred to the federal government. By September 1994, commercial disposal facilities became available, and DOE released an EE/CA evaluating several potential removal alternatives. DOE then selected a non·time critical removal action in an Action Memorandum for the removal of the interim waste storage pile to such a faCility. This removal was initiated in 1994, and completed in 1996. In September 1995, DOE released an EE/CA evaluating removal alternatives for the remaining residential, one commercial, and four municipal properties. This action was initiated in 1995, and was completed in 2000. 3.5 Basis for Taking Action EPA added the Site to the NPL on September 8, 1983. The inclusion of chemical contaminants under the definition of FUSRAP waste is limited to chemicals on the MISS or chemicals on vicinity properties that are COmmingled with or related to the radioactive waste, chemicals associated with thorium processing at MCW, and chemicals on or migrating from the MISS. EPA is overseeing the remedial investigation and feaSibility study (RI/FS) by the Stepan Company and, further, is coordinating that RI/FS and associated cleanup activity, with USACE's feasibility srudy and Proposed Plan and other USACE actions related to environmental cleanup at the Site.

Previous characterizations have determined that the properties comprising the Site are contaminated with FUSRAP waste in surface and subsurface soils. The Feasibilih) Study for Soils and Buildings at the FUSRAP lvtaywood Superfund Site was completed and submitted for public comment along with the Proposed Plnn for Soils and Buildings at the FUSRAP Maywood Superfund Site in August 2002, and a ROD was issued in September 2003 to address the contaminated soils on the properties that had not yet been remediated.

3·11 Section 4 Remedial Actions 4.1 Remedy Selection and Cleanup Criteria The Maywood Site consists of 88 designated industrial, residential, commercial, and government properties contaminated by former thorium processing activities. The general remedial approach has been to excavate and dispose of the contaminated soils off-site, and to remove and dispose of the contaminated building materials. Throughout the removal/ remedial actions, the cleanup criteria have changed; the original criteria and subsequent modifications are described in detail below.

4.1.1 Remediation Completed During 1984-1985 The contaminated materials at 26 Phase I properties remediated during 1984-1985 (see Figure 4-1) were excavated, transported and stored at the MISS. The cleanup criteria .set by OOE and applied to these 26 properties are summarized in Table 4-1. DOE's cleanup criteria for these initial property cleanups were based on EPA's 40 CFR 192 Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA).

Background levels of the radionuclides used in evaluating soil analytical results are discussed in Section 4.1.4 below.

4.1.2 Remediation Completed During 1995-1999 In 1993, EPA and DOE disagreed on the soil cleanup criteria that should be applied to the radioactive materials remaining at the Site. Therefore, EPA and DOE entered into a dispute resolution process. This disagreement was resolved in 1994 in a document known as the "Dispute Resolution" with site-specific cleanup criteria established at an average of 5 picoCuries per gram (pCi! g) combined radium-226 and radium-228, above background, for residential properties. For commercial properties, a higher cleanup criteria of an average of 15 pCij g combined radium-226 and radium-228, above background, with an "as low as reasonably achievable" (ALARA) goal of 5 pCi/ g, was established. USACE has determined that attainment of these cleanup levels will assure compliance with the relevant and substantive requirements of the State of New Jersey radiation dose standards for the remediation of radioactive contaminated properties. Note that the quantity of thorium-232, the principal radioactive contaminant at the Site, is estimated by measuring radium-228, which is in the thorium-232 decay chain. The Dispute Resolution soil cleanup criteria were used for the properties remediated from 1995 to 1999.

The contaminated materials at 38 Phase I properties remediated during 1995-1999 (see Figure 4-2) were excavated, transported and disposed of at an off-site commercial disposal faci lity. The cleanup criteria applied to these 38 properties are summarized in Table 4-2.

The notable changes in the cleanup criteria from previously remediated properties (1984-1985) were:

CDM 4-1 Section 4 Remedial Actions

• Reduction of Ra-226 and Th-232 criteria for subsurface soil from 15 pCi/ g to 5 pCi/g .

• Introduction of "Hot Spot Criterion" (DOE Order 5400.5), established for the cleanup of a localized area exceeding the Site cleanup criteria of 5 pCi/ g for Ra-226 and Th-232.

Hot spots refer to small areas that have levels of residual radioactive material that are above the levels in the surrounding area. Residual concentrations of radioactive material in soil are defined as those in excess of background concentrations averaged over an area of 100 square meters (m2). Criteria for hot spots were applicable if the average concentration in any surface or below-surface area less than or equal to 25 m2 (269 square feet (ft2» exceeds the limit or guideline by a factor of (100/ A)l/l, where A is the area in square meters of the region in which concentrations are elevated.

Procedures for calculating these hot spot limits, which depend on the extent of the elevated local concentrations, are given in the supplement - "A Manual for Implementing Residual Radioactive Material Guidelines - A Supplement to U.s. Department of Energy Guidelines for Residual Radioactive Material at Formerly Utilized Sites Remedial Action Program and Surplus Facilities Management Program Sites" (DOE 1989). In addition, the standard requires that every reasonable effort be made to remove any source of radionuclides that exceeds 30 times the appropriate limit for soil, irrespective of the average concentration in the soiL

In situations where limited areas of soil contaminated above the cleanup criteria were present only as subsurface lenses beneath a much larger layer of clean soil or beneath building foundations or mature trees (e.g., Lodi Municipal Park), detailed property­ specific "Hazard Assessments" were developed to evaluate the potential for leaving these materials in place, with the use of appropriate exposure pathway modeling (refer to DOE Residual Radioactive Material Guidelines [RESRAD]). The application of the hazard assessment was limited to areas of contamination located where no Significant exposures or health risks were possible, and the drawbacks of cleanup (e.g., increased risks to workers or the public, environmental damage, or unreasonably high costs) outweighed the benefits of achieving the cleanup standard. The purpose of the hazard assessment was to demonstrate that the limited quantities of residual contamination posed no unacceptable risks under current or future use scenarios (Le., excess cancer risk below EPA's target risk of 1(}6 to 1Q-4). Background levels of the radionuclides used in evaluating soil analytical results are discussed in Section 4.1.4 below.

4_1.3 Remediation Completed for Properties in the 2003 Record of Decision As depicted on Figure 4-3, 24 commercial and government properties are addressed under the 2003 ROD. Based on the historical commercial/industrial use of the Site, the proximity of heavily used transportation corridors (e. g., NJ State Route 17, 1-80), and the well-defined commercial/industrial districts, the use of the restricted use

4·2 Section 4 Remedial Actions

cleanup criteria were justified for and applied to select commercial and government vicinity properties. For the remaining properties, cleanup to the WU'estricted use criteria is considered more appropriate since they are located within a less defined commercial district with encroaching residential developments on three sides. The general RAOs for the Site, as defined in the 2003 ROD, are to prevent or mitigate the further release of FUSRAP waste to the surrounding environment, and to meet the established cleanup criteria and comply with applicable or relevant and appropriate requirements (ARARs). Note that the USACE initiated work for some of these properties in accordance with a 2001 EE/CA for a Removal Action in Support of NJDOT Roadway Improvement Projects at the Site.

The 2003 ROD addresses the radiologically and chemically contaminated wastes in soils and buildings, as defined as FUSRAP waste. Under the terms of the FFA, FUSRAP waste consists of:

• All contamination, both radiological and chemical, whether mixed or not, on the Maywood lnterim Storage Site. The MISS is the 11.7-acre property acquired by OOE to store excavated materials due to the limited commercial disposal capacity for radiological wastes.

• All radiological contamination above cleanup levels related to past thorium processing from the Maywood Chemical Works occurring on any of the vicinity properties.

• Any chemical or non-radiological contamination on vicinity properties that would satisfy either of the following requirements:

The chemical or non-radiological contaminants that are mixed or commingled with radiological contamination above cleanup levels.

The chemical or non-radiological contaminants that originated at the MISS or were associated with the specific thorium manufacruring or processing activities at MCW that resulted in the radiological contamination.

The cleanup criteria established in the 2003 ROD for the radioactive contamination at the Site are summarized in Table 4-3.

A notable change in the cleanup criteria from previously remediated properties (1995- 1999) was:

• 15 millirem per year (mrem/ yr) above background dose limit specified in the New Jersey Administrative Code (NJAC) 7:28-12.8(a)1 for all properties addressed in the 2003 ROD.

The 15 mrem/yr requirement as specified by NJAC 7:28-12.8(a)1 is considered an ARAR for the remediation of the NRC-licensed burial pits on the Stepan Company property (see Figure 3-3), which also needs to meet NRC regulations at 10 Code of Federal Regulations (CFR) 20.1402 (25 mrem/yr).

CDM 4·3 Section 4 Remedial Actions

In addition, the 2003 ROD cleanup criteria also specify the following:

• Any Site remediation-derived water discharged to a Publicly Owned Treatment Works (POTW) is required to meet or exceed the POTW's designated pretreatment standards prior to discharge.

• Any Site remediation-derived water discharged from a point source to a surface water body or groundwater is required to comply with the relevant and appropriate promulgated State and Federal standards for the site-specific contaminants of concern (COCs). In the absence of specific discharge limitations, point source discharges are required to meet or exceed federal maximum contaminant levels for each COCo

The determination of background levels of the radionuclides used in evaluating soil samples is discussed in Section 4.1.4 below.

The major components of the selected remedy under the 2003 ROD consist of:

• Excavation of accessible soils to meet ARARs and soil cleanup criteria for either restricted or unrestricted use as discussed above for each property using federally accepted averaging methods (e.g., Multi-Agency Radiation Survey and Site Investigation Manual [MARSSIM]) to demonstrate compliance with the criteria.

• Physical separation, using backhoes or other heavy construction equipment, of a portion of the excavated material to sort boulders and rocks, waste potentially requiring disposal as mixed waste (radioactive and hazardous waste), and bulk waste such as building rubble.

• Remediation of contaminated buildings/structures (or demolition and disposal as deemed appropriate at the time of work) in consultation with the property owners, as necessary to achieve the criteria of 15 mrem/ yr above background as specified in NJAC 7:28-12.8(a) I and the 3 picoCuries per liter (pCi/L) radon-222 (Rn-222) limit in NJAC 7:28-12.8(a) 2.

• Excavation of inaccessible soils to meet ARARs and cleanup criteria fo r either restricted or unrestricted use as discussed above if the landowners make them accessible during remediation; otherwise, inaccessible soils currently located under buildings and roadways would be excavated and disposed off-site as they become accessible in the futu.re (e.g., due to renovation or demolition activities).

• Demolition and d isposal of structures on the MISS to access contaminated soils.

• Off-site disposal of all materials above the cleanup criteria at facilities authorized to accept radioactive waste in accordance with applicable regulations.

• Five-year reviews in accordance with CERCLA 121 (c) and 300.430(f)(4)(ii).

CDM 4·4 Section 4 Remedial Actions

• Requesting notification of the USACE and EPA by local municipalities of any land use changes involving those properties where radioactivity remains above an average of 5 pCi/ g of Ra~226 and Th~232 combined above background concentrations in soils.

• Periodic Rn~222 monitoring of structures over inaccessible soils to ensure that the structures continue to provide adequate protection from these soils; mitigation of Rn-222 (e.g., sealing foundation cracks, supplementing existing ventilation systems, etc.) would be performed if indoor air levels exceed 3 pCi/ L above background.

• Working with local authorities and landowners to implement land use controls (e.g., deed notices, easements, covenants, zoning controls, etc.) on a property by property basis, as necessary, for those properties where radioactivity remains above an average 5 pO/ g of Ra~226 and Th~232 combined above background concentrations in soils and/ or due to the presence of inaccessible soil. Objectives of the institutional controls would be to restrict land use to commercial/industria!, prohibit residential or unrestricted use, and prohibit excavation into deSignated restricted areas. Institutional controls would remain in place as long as Site contaminants remain above levels that allow for unrestricted use.

4.1.4 Background Levels of Radionuclides The soil cleanup guidelines are based on levels above natural background levels; therefore, it was important to establish such levels in soils near the Site. Background data served as a frame of reference for evaluating analytical data from the vicinity properties because they represented conditions typical of the areas unaffected by former MCW activities. As discussed below, background levels of radionuclides were analyzed in a series of sampling events that occurred prior to, during, and after the 1992 Rl.

• Pre·RI: background soil samples were obtained from the Rochelle Park area. The sampling locations were selected on the basis of their proximity to the Site, the relative independence from potential influence of the Site, and representativeness of area land uses. The average concentration of Th-232 in the background samples was 0.9 pCi/ g, with concentrations ranging from 0.31 to 1.5 pCi/ g. The average background concentration of Ra-226 was 0.87 pCi/ g, with concentrations ranging from 0.24 to 1.4 pCi/g. The average background concentration of Uranium-238 (U- 238) was 0.86 pCi/g, with concentrations ranging from 0.13 to 1.5 pO/g. The average background external radiation exposure rate was determined to be 100 mrem/ yr. These background levels were used for evaluation of samples during cleanups performed in 1984-1985.

• 1992 RI: background soil samples were obtained from three background locations in the general area of the vicinity properties. The average concentration of Th-232 in these samples was 1.0 pCi/g, with concentrations ranging from 0.9 to 1.1 pei/g. The average background concentration of Ra-226 was 0.7 pCi/ g, with concentrations ranging from 0.5 to 0.8 pCi/ g. The average background

4·5 Section 4 Remedial Actions

concentration of U-238 was 2.9 pOI g, with concentrations ranging from 2.4 to 3.5 pCi/g (Bechtel National, Inc. [BNI] 1992). The average background external radiation exposure rate was determined to be 9.0 microRoentgen/hour (pR/h). These background levels were used for evaluation of samples during cleanups completed from 1995-1999 .

• Post-RI: a Background Study Investigation Report (USACE 2004d) was prepared in May 2004 to provide average background levels in soils near the Site. The background levels were established to serve as a reference for evaluating analytical data in achieving the RAOs and to provide suitable data to perform the non­ parametric statistical test established in MARSSIM (EPA 2000). The background level for Ra-226+Th-232 was 1.64 pOI g, with a 95th Upper Confidence Limit (UCL) of 2.76 pCi/g. The background concentration of U-238 was 1.33 pCi/g, with a 95th UCL of 2.64 pCij g. Similar to the residential vicinity properties, remedial actions for some of the commercial and government vicinity properties were performed prior to development of these background levels. The protectiveness of these properties (specifically, four muniCipal properties and one commercial property) was actually based on the background values established in the 1992 RI. The remaining cleanups were based on the average background levels in the Background Study Investigation Report. 4.2 Remedy Implementation 4.2.1 Remediation Completed During 1984 and 1985 Between 1984 and 1985, remedial actions were undertaken at 26 Phase I properties, which were designated by DOE based on the results of the 1981 radiological survey of these properties. The property owners were notified, and DOE started engineering design work and related activities to hire a local subcontractor for the actual cleanup effort. After the design work was completed and access agreement secured from the property owners, excavation was performed on the basis of the excavation limit shown on the design drawings. Excavation cut lines were based on soil sample results, and walkover gamma and downhole gamma logging surveys. The surface and subsurface readings cutoff of 11,000 and 40,000 counts per minute (cpm) were used as a correlation to 5 pCi! g and 15 pCiI g, respectively, for Th-232. The excavated soils were then transported to the MISS for storage.

Post-remedial action sampling at the remediated properties included:

• Surface gamma radiation scan - Two types of gamma radiation scans were performed to help determine all radioactively impacted soils were removed. The first scan was a walkover scan in which a technician held a radiation detector a few inches above the surface and moved slowly from side to side across the excavation area. The second gamma radiation scan was performed after all contamination identified during the walkover scan was removed. The second scan was completed using a lead-shielded detector to ensure that the only radiation detected was coming from the ground under the detector. Measurements were collected at 10- foot intervals on each property. Additional soils were removed if either of these

4-6 Section 4 Remedial Actions

two scans detected contamination in excess of DOE guidelines, and the survey process was then repeated until the DOE guidelines were met.

• Soil sampling - The primary method of determining whether the DOE guidelines were met was to collect soil samples for laboratory analyses of Ra·226, Th-232, and U-238. SoH samples were generally cotlected from the bottom of excavation, and in some cases from the sidewall of excavation. It should be noted that even though the soil samples were analyzed for U-23S, there appears to be no established criteria for uranium in the post-remedial action report (PRAR) involving any of these 26 Phase I properties. Rather, the PRARs only stated that soil guidelines were to be calculated on a site-specific basis using the DOE manual developed for the Site for radionucHdes other than radium and thorium .

• Exposure rate measurement - Pressurized Ionization Chamber (PIC) readings were taken within the excavation, to measure the gamma radiation exposure rate after the removal of soil contamination. Gamma radiation exposure rate w~s also measured using the thermoluminescent dosimeters placed at select properties. PIC readings were compared with the OOE radiation protection standard of 100 mrem/yr above the background radiation level (100 mrem/ yr).

With the exception of 96 Parkway, Rochelle Park property, an independent review of the remedial actions performed at each of the other 25 properties was conducted to (1) verify the data in support of adequacy of the remedial action, and (2) to confirm compliance with the applicable cleanup criteria.

According to the post-remedial action report, these properties were deemed to have been remediated to the satisfaction of the applicable DOE radiological guidelines established for unrestricted use. In a 1994 letter from EPA Region 2 to OOE, EPA presented its poSition on the Dispute Regarding Cleanup Levels for Radionuclide Contamination at the Maywood Chemical Company Superfund Site for incorporation into a final Proposed Plan. The EPA position stated the following: "At tile 26 residential properties previously remediated at tile Maywood site, post-remediation veriftcatiotl data show that, although DOE utilized a 15pCi/g cleanup criterion, measured concentrations of the thorium-232 jollowing the remediation were below 5 pCi/g above background in over 95 % of samples, and radium-226 and uranium concentrations were generally at or near background levels. Subsurface cleanup is therejore expected to attain the subsurface A LARA goal in most cases consistent with previous removal actions."

4.2.2 Remediation Completed During 1995-1999 As discussed earlier, the USACE assumed responsibilities from DOE as lead agency for remedial action at the Site in 1997. However, the cleanup criteria and remedial approach taken remained the same for the 38 Phase I properties where remediation was completed between 1995 and 1999.

Generally, pre-remediation work activities consisted of documentation of existing conditions and preparation of the property for remedial action. This included performance of inspections, preparation of videotapes, and evaluation of building

COM 4·7 Section 4 Remedial Actions

material for lead paint or asbestos content. Prior to remediation, the results of earlier characterization investigations were used to plan remediation activities. The property was again surveyed immediately before remediation to more accurately define the boundaries of radioactive contamination. At properties where contamination was present below structural items such as houses and garages, underpins for wall footings of the structure were installed to support the structure and to facilitate removal of contaminated materials thereof. Excavated material was transported to the MISS, where it was loaded into railcars and shipped to the Envirocare of Utah disposal facility in Clive, Utah.

Post-remedial action sampling completed at the remediated properties consisted of:

• Surface gamma radiation scan - As excavation proceeded, surface gamma scans of the excavation area were conducted to identify and remove the contaminated soil above the cleanup criteria. The area was scanned after each lift of soil was removed to verify that the contamination had been removed.

• Soil sampling - The primary method of determining whether the cleanup criteria have been met was to coHect soil samples for laboratory gamma spectroscopy analysis. Composite soil samples were collected (from a depth of a to 6 in) from each remediated grid (generally 100 m2 or 1,076 ft2) by taking individual samples [at a frequency of 25 per 100 m2 (1,076 ft2)] from each sample grid and compositing these individual samples into one sample for that grid. A bias sample was also collected from the bottom of the excavation at an area exhibiting the highest gamma reading for that grid. For underpins which were used at properties where remediation underneath a building or structure was undertaken, bias samples were collected from the floor of each underpin at areas exhibiting the highest gamma reading, and a composite sample for underpins was obtained by mixing six-inch plugs collected systematically from all underpins. In addition, bias samples for inaccessible soil, beneath the Lodi Brook pipeline and trees, were collected.

• Exposure rate measurement - PIC readings were taken, at 1 meter (3 ft) above the ground surface in each open excavation prior to backfilling with clean fill. PIC readings were then compared with the remedial action level of 100 mrem/ yr above background.

The post-remedial action data were provided to an independent verification contractor (IYC) for review to determine whether remediated areas were in compliance with the cleanup criteria. The IYC verification included a Type A verification or a Type B verification. Type A verification consisted of reviewing the existing post-remedial action survey results. After review of the results, the IYC determined if there was a need to collect additional samples from the location(s) listed in the survey results. In performing Type B verification review, the IYC conducted a survey of the Site that included direct radiological measurements, review of the post­ remedial action survey methods and results, sampling, and laboratory analysis of separate soil samples. Upon receipt of IYC verbal approval, the excavated areas were

4-8

O,j_CI>omoeaICo ~_F"... Y ___ _ Section 4 Remedial Actions

then backfilled and remediated areas restored. The IVC verification procedure and results were documented in IVC verification reports for these properties.

According to the PRARs, these properties were deemed to have been remediated to the satisfaction of applicable cleanup guidelines for radioactive contamination.

4.2.3 Remediation Completed for Properties in the 2003 Record of Decision Remedial actions have been undertaken or are underway at 22 of the 24 designated properties included in the 2003 ROD (see Table 1-1 for current property status).

Generally, pre-remediation work activities consisted of documentation of existing conditions and preparation of the property for remedial action. These included: verification that all additional applicable permits, notifications and approvals had been obtained; completion of radiological surveys to establish radiological posting requirements and worker protective measures; performance of construction surveys to layout limits of excavation, and establish survey controls, existing conditions and topography; and other common mobilization and site preparation activities. Prior to remediation, the radiological data collected during previous investigations were used to plan remediation activities. Excavation was performed based on the excavation limit depicted on the design drawings showing the extent of contamination at each of these properties. Excavated materials were transported to the MISS for temporary storage, and subsequently transported off-site via rail at a faCility authorized to accept radioactive waste in accordance with applicable regulations.

Post-remedial action sampling at the remediated properties was conducted utilizing a MARSSIM-based approach. The sampling consisted of the following components:

• Gamma walkover survey (GWS) - The purpose of the GWS was to identify within 100% of accessible areas any potential areas of elevated radioactivity, which may not be detected by the statistically located systematic sample grid. Remediated excavation slopes and side walls were also scanned during the GWS. Data, recorded in counts per minute, were logged automatically from the scaler­ ratemeter into the Differential Global POSitioning System (DGPS) unit every second. The data downloaded from the DGPS unit were used in the geospatial software program to plot the results .

• Soil sampling - The primary method of determining whether the cleanup criteria were met was to collect surface and subsurface soil samples for laboratory gamma spectroscopy analysis. Surface samples were collected both within the limits of (at the bottom of the excavation) and outside the excavation (from grade to six inches below ground surface (bgs». In accordance with MARSSIM, survey units (SUs) were established and soil sampling was conducted to meet the site-specific derived concentration guideline level (OCGL). Subsurface sampling was performed in areas outside of remedial excavations to verify that residual radioactivity in the soil meets the Site cleanup criteria. In addition, a minimum of one bias sample was

COM 4·9

"'~ChomIcIICo ~SIIoI'lo.Y,, _ _ Section 4 Remedial Actions

collected in each SU from the location corresponding to the maximum GWS measurement. Additional bias samples were collected, as necessary, to address GWS measurements exceeding a Z-score of three (Le., readings greater than three standard deviations above the mean).

The post-remedial action data were evaluated to determine the residual radioactivity status of the remediated properties. Specifically, GWS and bias sample data were evaluated to resolve identified areas of potentially elevated radioactivity, while systematic soil sampling data were evaluated using the non-parametric statistical methods established in MARSSIM. The goal was to establish whether the "Null Hypothesis:' which states "the median concentration in the SU exceeds the median concentration in the reference area by more than the derived concentration guideline level" can be accepted or rejected for a particular SUo The Null Hypothesis is an assumption that the SU exceeds the release criteria. There are two methods for rejecting the Null Hypothesis:

• If all systematic sample results are less than the DCGL, the Null Hypothesis is automatically rejected .

• [f any systematic sample result exceeds the DCGL by more than the lowest background reference area measurement result, the non-parametric Wilcoxon Rank Sum (WRS) Test is required to be performed. WRS is used in situations where the contaminant is present in background and establishes with sufficient statistical probability that the median concentration in the SU does not exceed the DCGL. The WRS Test outcome must exceed the "critical value" to reject the Null Hypothesis and release the SUo

Based on the available PRARs, all the remediated properties were deemed to have met the respective cleanup criteria for restricted use or unrestricted use, as specified in the 2003 ROD with the exception of only five properties where inaccessible contamination was present (Le., 167 State Route 17, Maywood; 80 Industrial Road, Lodi; 80 Hancock Street, Lodi; 100 Hancock Street, Lodi; and 23 West Howcroft Road, Maywood). At these five properties, due to safety concerns and structural stability issues, contaminated soils could not be removed from areas underneath and immediately adjacent to permanent structure such as buildings, pump station, sewer force main, natural gas pipeline, and/or utility poles. As such, rather than the unrestricted use originally specified in the 2003 ROD, these five properties have restricted use designations, with proposed implementation of institutional controls (Le., administrative, legal, and/ or physical measures that control potential or actual human health risks), whereas the specific types of institutional controls are yet to be determined. Contaminated soil which is considered inaccessible will be addressed in the future when it is made accessible by property owners.

Following verification that cleanup criteria had been met, excavated areas were either backfilled with clean fill purchased from a vendor or with clean soil, Le., overburden soil removed from other properties in the vicinity. Radiological results for the backfill were compared to applicable guidelines. Chemical results were compared to

CDM 4·10 Section 4 Remedial Actions

applicable New Jersey soil cleanup criteria/background concentrations (NJDEP 19%, BNIl992). The backfill and clean overburden soil results were below applicable regulatory criteria. Upon completion of the remedial actions, the property was restored to its original condition. 4.3 System Operation/Operation and Maintenance The remedial activities completed for Phase I properties allowed an unrestricted use designation; therefore, operation and maintenance activities were not required at these properties. For OU2 properties, inaccessible soils underneath permanent structures are known to be present at four properties which were designated for restricted use. For the latter OU2 properties, post-remediation radon testing was performed from October 2008 to January 2009, and interior gamma survey and inspection for any cracks in basement slabs were also completed during the same event. According to the USACE - New York District, periodic radon monitoring at these properties is included in the Land Use Control Implementation Plan (LUCIP) that is currently under revision.

Additionally, in accordance with the requirements of the General Environmental Protection Plan, FUSRAP Maywood Superfund Site, Maywood, New Jersey, November 24, 1999 (USACE 1999), an Environmental Monitoring Program (EMP) was established for the Site. One of the main objectives of the EMP is to ensure that the public and the environment are adequately protected from FUSRAP contaminants present at the Site. This is accomplished through annual monitOring of the air, surface water, sediment, and groundwater. The results of the EMP are documented in an Annual Monitoring Report for each calendar year. The Annual Monitoring Report included in this Five­ Year Review Report is that prepared for the calendar year 2007 (refer to Appendix D). Prior to the establishment of the USACE EMP, OOE conducted a site-wide environmental surveillance program to monitor conditions at the Site.

COM 4-11 Section 5 Progress Since Last Review Not applicable as this is the first five-year review conducted for the Maywood Site.

5·1 Section 6 Five-Year Review Process 6.1 Administrative Components This is the first five-year review for the Maywood Site. The five-year review team consisted of representatives from EPA and USACE. From December 200S to June 2009, the review team established the review schedule whose components included:

• Community Involvement

• Document Review

• Data Review

• Si te Inspection

• Site Interviews

• Five-Year Review Report Development and Review 6.2 Community Involvement EPA published newspaper notices announcing that the five-year process was underway for the Maywood Chemical Site. Notices about the five-year review were published in the following local newspapers: The Record and The Herald News on August 7, 2009 and OUT Town on August 13, 2009. Copies of the notices are included in Appendix A. In addition, a notice announcing the five-year review was posted on the USACE project website at http://fusrapmaywood.com/ whatsnew.htm. The notices stated that the review would be completed by October 2009 and the report available at the information repositories for the Site located in Maywood, New Jersey and at the EPA Region 2 Records Center in New York City. The notices included contact information for EPA's Remedial Project Manager and Community Involvement Coordinator.

As the lead federal agency, DOE and its successor, USACE, established and maintained an extensive community involvement program. EPA has coordinated with the lead federal agencies throughout the project to ensure that the local community is kept well informed of cleanup activities. Communications with the property owners, surrounding community and local government officials is an ongoing and critical component of the remedial work. A Public Information Center with project records was established in the business district of Maywood, New Jersey. Project updates are prepared and sent out to the local community on a routine basis. USACE maintains a project website at http:// www.fusrapmaywood.com/index.asp; the website includes project documents, maps, notices and updates. The nature of the work requires constant communication with property owners where cleanup is required from initial investigations until final property status reporting.

6-1 Section 6 Five -Year Review Process 6.3 Document Review The relevant documents which were reviewed in completing this five-year review include the 2003 ROD, EE/CA. RI/FS, PRARs, Radiological Characterization Reports, Independent Radiological Verification Reports, 2007 Annual Monitoring Report, and FUSRAP newsletters_ A list of the documents is identified in Appendix B. 6.4 Data Review Data were collected as part of the PRAR for each remedial action. The pertinent data are provided in electronic format (on DVD) as Appendix C. In addition, characterization data from the radiological characterization reports and other Site investigation reports, alongside the full content of the PRARs and the 2007 Annual Monitoring Report, are also provided in electronic format (on DVD) as Appendix D. 6.5 Site Inspection and Interview To help assess the protectiveness of the remedy, an inspection/interview was performed at the Site on May 19, 2009. This consisted of:

• An interview of the USACE Maywood FUSRAP project team members by the five­ year review team, and discussion of the preliminary five-year review findings such as gamma exposure rate measurements, radon results, institutional controls/land use, and inaccessible contaminated soil near Lodi Brook Pipeline (LBP) and roadway right-oE-way parcels .

• A tour of the MISS stockpile, railroad used for transportation of waste for off-site disposal, active construction area, and two of the properties that have inaccessible ~~ntamination underneath buildings (23 West Howcroft Road, Maywood and 80 Hancock Street, Lodi).

The meeting minutes documenting the findings of the Site inspection/ interview are included in Appendix E.

6-2 Section 7 Technical Assessment A technical assessment has been performed to assess the protectiveness of the remedy by evaluating potential risks to human health and environment associated with the residual radionuclide contamination at the Maywood Site. As discussed in Section 1.0, even though this five-year review is triggered by the initiation of on-site remedial action construction activities associated with OU2 properties, the purpose of this five­ year review is to provide an evaluation of both the Phase I and the OU2 properties.

This technical assessment of the 88 designated properties is divided into three groups:

• Twenty-six Phase I properties remediated during 1984-1985,

• Thirty-eight Phase I properties remediated during 1995-1999,

• Twenty-four OU2 properties included in the 2003 ROD although remedial actions at some of the OU2 properties (e.g., Interstate 80) actually started prior to the 2003 ROD.

As reasonably expected, the applicable cleanup criteria differ among these three groups, and generally become more stringent over the course of the remedial actions taken at the Site.

The documentation primarily used for the technical assessment consists of the 2003 ROD and the PRARs. For Phase I properties, additional documents including the Radiological Surveys, the Radiological Characterization Reports, and the Results of the Independent Radiological Verification Survey were also reviewed.

It should be noted that right-of-way parcels and inaccessible streets were not addressed in the 2003 OU2 ROD and will be part of a future CERCLA decision document, which will include a thorough evaluation of these properties. 7.1 Approach of the Technical Assessment The technical assessment is performed in a manner consistent with the requirements of EPA guidance for Comprehensive Five-Year Review, by addressing the following three questions:

• Is the remedy functioning as intended by the decision documents?

• Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy still valid?

• Has any other information come to light that could call into question the protectiveness of the remedy?

CDM 7-1 Section 7 Technical Assessment

The DOE guidelines (refer to Tables 4-1 and 4-2 for cleanup level) were followed to implement the remedial actions at the Phase 1 properties, whereas the decision document directing the cleanup for the OU2 properties is the 2003 ROD (refer to Table 4-3 for cleanup level). As previously noted, USACE initiated work at some of the OU2 properties under the 2001 EE/CA for a Removal Action in Support of NJDOT Roadway Improvement Projects at the Site, but this removal action was transitioned into the remedial action as specified in the 2003 ROD.

Therefore, to address whether the remedy is functioning as intended by the decision documents (Question A below), the results for the Phase 1 and OU2 properties are evaluated in this section utilizing the cleanup criteria at the time of remedial action (i.e., the DOE guidelines for Phase I properties and the 2003 ROD cleanup criteria for OU2 properties). However, a detailed evaluation of the results for the Phase I properties compared to the 2003 ROD cleanup criteria is included in Sections 7.1 and 7.2.

This technical assessment focuses primarily on determination of the current and future protectiveness of the remedy. The current cleanup levels used to make protectiveness determinations are those set forth in the 2003 ROD, which were developed to address the radionuclide contamination in soils and buildings at the OU2 properties. To facilitate the protectiveness determination, the cleanup criteria in the 2003 ROD and some related technical background will be discussed in more detail below.

7.1.1 Radionudides in Soil After the establishment of the Dispute Resolution cleanup criteria between EPA and DOE in 1994 (refer to Appendix D of the FS), the State of New Jersey promulgated NJAC 7:28-12 Remediation Standards for Radioactive Materials in August 2000. This regulation establishes minimum standards for the remediation of real property located within the State of New Jersey contaminated by radioactive materials, i.e., dose of 15 mrem/ yr above background (specified in NJAC 7:28-12.8(a)1).

As indicated in the 2003 ROD, a baseline risk assessment (BRA) was prepared to evaluate risk to human health and environment from the radioactive and chemical constituents at the Site. Radiological exposure rates and doses were calculated using the RESidual RADiation computer modeling system (RESRAD) computer code. Inhalation of radon progeny was estimated using the methodology of United Nations Scientific Committee on the Effects of Atomic Radiation. Doses from measured radon and gamma levels were substituted for modeled doses where available, and surface soil statistical data were used as the exposure point concentrations for all scenarios. The BRA concluded that the exposure to Site constituents under current and hypothetical future land use scenarios may result in unacceptable risks to human and ecological receptors, causing cancer risks above the CERCLA target risk range of lQ-t to 10-.6, unless remedial action is taken. The estimated radiological risks and radiological doses for the remedy selected in the 2003 ROD demonstrated compliance with State of New Jersey radiation dose standards for the remediation of radioactive

7·2 Section 7 Technical Assessment

contaminated properties (Le., 15 mrem/ yr above background dose limit) and the CERCLA target risk range of 1{)-4 to 1{)-6, respectively (refer to the Tables 6 and 7 in the 2003 ROD).

The soil cleanup criteria used to evaluate the Phase I properties and OU2 properties are as follows .

• Phase I properties remediated during 1984-1985, and 1995-1999 are all unrestricted use properties. An average of 5 pCi! g of Ra-226 and Th-232 combined above background, as well as an average of 100 pCi/ g of total uranium which equates to approximately 50 pCiI g of V-238, are used to evaluate the post-remedial action soil sample results for these properties .

• OU2 properties consist of a mix of unrestricted use and restricted use properties. Correspondingly, when evaluating the post-remedial action soil sample results, an average of 5 pCi/ g of Ra-226 and Th-232 combined above background is used for unrestricted use properties; an average of 15 pei/ g of Ra-226 and Th-232 combined above background in subsurface soils with an ALARA goal of 5pCij g is used for restricted use properties; and an average of 100 pCi/ g of total uranium which equates to approximately 50 pCi/ g of U-238 is used for all OU2 properties.

7.1.2 Gamma Exposure The 2003 ROD requires that soil and building remediation, including the remediation of the Stepan Company NRC-licensed burial pits and the remediation of contaminated buildings/structures (or demolition and disposal as deemed appropriate at the time of work), comply with the 15 mrem/ yr above background dose limit specified in NJAC 7:28-12.8(a)1.

USACE has determined that attainment of the 2003 ROD soil cleanup levels will assure compliance with the relevant and substantive requirements of the State of New Jersey radiation dose standards for the remediation of radioactive contaminated properties, i.e., 15 mrem/yr. Therefore, even though Gamma walkover surveys were conducted for the 2003 ROD properties, no post-remedial action gamma exposure rate measurements were obtained, unless inaccessible soils were left in place at these properties. Consequently, Gamma exposure will not be retained for further consideration in this report.

7.1.3 Radon and Radon Decay Products in Structure The 2003 ROD requires that indoor radon air concentration meet the 3 picoCuries per liter Rn-222 limit specified in the NJAC 7:28-12.8(a)2. Periodic Rn-222 monitoring of structures over inaccessible soils are specified to ensure that the structure continues to provide adequate protection from these soils, and mitigation measures (e.g., sealing foundation cracks, supplementing existing ventilation systems etc.) would be performed if indoor radon air concentrations exceed 3 pCi/L above background.

CDM 7-3 Section 7 Technical Assessment

Specifically, the indoor radon air concentrations for the Phase I properties and OU2 properties are evaluated based on the following approach.

• Phase r properties remediated during 1984-1985: post-remedial action radon sampling was conducted at approximately half of the 26 properties, for which a direct comparison with the indoor radon air concentration specified in the 2003 ROD has been completed. For those properties lacking post-remedial action radon sample data, the post-remediation soil sample results, especially for Ra-226 (whose decay product is Rn-222), were evaluated. It has been determined that soils remediated below the site cleanup criteria will meet the indoor radon air concentration of less than 3.0 pCi/L above background as specified in the 2003 ROD, based on correlation and evaluation with the 40 CFR 192 UMTRCA standards.

• Phase I properties remediated during 1995-1999: post-remedial action radon sampling was not conducted at any of these 38 properties. Therefore, the pre­ remedial action radon data, whenever available, were used in the evaluation as they would most likely provide a worst-case scenario. For those properties lacking pre- or post-remediation radon sample data, the post-remedial action soil sample results, especially for Ra-226, were evaluated. It has been determined that soils remediated below the site cleanup criteria will meet the indoor radon air concentration of less than 3.0 pCijL above background as specified in the 2003 ROD, based on the 40 CFR 192 UMTRCA standards.

• OU2 properties: initial radon testing was performed at these properties and all results were below the 2003 ROD criteria of 3.0 pCijL Therefore, post-remedial action radon testing was not performed at OU2 properties with the exception of properties containing inaccessible soils. It has been determined that soils remediated below the site cleanup criteria will meet the indoor radon air concentration of less than 3.0 pCi! L above background as specified in the 2003 ROD, based on the 40 CFR 192 UMTRCA standards. 7.2 Phase I Properties Remediated During 1984-1985 Table 7-1 summarizes the review findings for the 26 Phase I properties remediated during 1984-1985. A brief discussion of these findings, as related to addreSSing the following three questions, is presented below.

Question A: Is the remedy functioning as intended by the decision documents?

Answer A: Partially. The remedial action at tire Phase I properties remediated du.ring 1984- 1985 was generally completed in accordance with the DOE guidelines (summarized in Table 4-1). The exceptions are identified as follows.

The remedy for the 96 Parkway, Rochelle Park property is not functioning as intended based on the DOE guidelines. This property does not meet the unrestricted use criteria. Several post-remedial action soil sample results exceeded the DOE cleanup

COM 7·4 Section 7 Technical Assessment

criteria; however, it was stated in the PRAR that the unrestricted use cleanup criteria had been met for the property.

Another 12 properties did not have post-remedial action radon/ radon decay product in building testing data, as required by the OOE guidelines, at the time of remedial action. Rather, the post-remedial action soil sample results were evaluated. Of the 12 properties, compliance with the OOE cleanup criteria at the 468 Davison Street, Maywood property cannot be evaluated until further radon testing results become available (refer to Table 7-1 for more details). This property had a pre-remediation radon decay product result of 0.06 working level (WL), far exceeding the DOE cleanup criteria of 0.02 WL. Moreover, the pre-construction maximum gamma exposure rate, which occurred in the basement. was reported to be 33 ~R/hr. In the PRAR, the source of elevated gamma exposure rate in the basement was attributed to exterior soil contamination. However, there was no post-remedial action radon testing or interior radiological investigation completed to confirm that gamma exposure and radon levels meet the cleanup criteria.

Note that the results for the Phase I properties remediated during 1984-1985 are also evaluated against the 2003 ROD cleanup criteria, and the findings are presented in Section 8.1.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time ofthe remedy still valid?

No. The cleanup criteria have c1umged since the completion of tlte remedial actions undertaken during 1984-1985. The current cleanup criteria being implemented at tIre Site are specified in the 2003 ROD.

Question C: Has any other infonnation come to light that could call into question tlte protectiveness of the remedy?

Tile site inspection/interviews completed in May 2009 did not provide additiorJal information tlUit calls into question the protectiveness of the remedy at these properties. 7.3 Phase I Properties Remediated During 1995-1999 Table 7-2 summarizes the findings of the review on the historical data for the 38 Phase [properties remediated during 1995-1999. A brief discussion of these findings, as related to addreSSing the following three questions, is presented below.

Question A: Is tile remedy functioning as intended by tire decision documents?

Answer: Partially. The remedial action at the Phase I properties remediated during 1995-1999 was generally completed in accordance with the 1995 EE/CA cleanup criteria (sum marized in Table 4-2), but tJre exceptions are identified as follows.

7-5 Section 7 Technical Assessment

The remedy for two Lcdi properties, 2 Branca Court and 11 Branca Court, is not functioning as intended based on the 1995 EEjCA cleanup criteria. The PRARs for these two properties indicate that areas along the Lcdi Brook Pipeline were not remediated, and the biased sample collected from inaccessible soils below the LBP revealed radionuclide activity in excess of the 1995 EEjCA cleanup criteria (the inaccessible soil area did not meet the hot spot criteria).

In addition, for the Lcdi Municipal Park property, compliance with the 1995 EEjCA cleanup criteria cannot be evaluated due to insufficient or lack of post-remedial action soil sample results.

Note that the results for the Phase I properties remediated during 1995-1999 are also evaluated against the 2003 ROD cleanup criteria, and the findings are presented in Section 8.2.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?

No. Tile cleanup criterin have changed since tile completion of tile remedial actions undertaken during 1995-1999. Tile current cleanup criteria being implemented at tile Site are specified in tlze 2003 ROD.

Question C: Has any other infonnalion come to light that could call into question the protectiveness ofthe remedy?

TIle site inspection/interviews completed in May 2009 did not provide additional infonnation that calls into question the protectiveness of the remedy at tlle5e properties. 7.4 Properties in the 2003 Record of Decision Table 7-3 summarizes the findings of the review of the historical data for the 240U2 properties in the 2003 ROD. Remedial actions have been completed at 17 properties to date, but post-remedial action data are only available for 11 of the 17 properties at this time. A brief discussion of these findings, as related to addressing the following three questions, is presented below.

Question A: Is the remedy functioning as inte"ded by the decision documents?

Answer: Yes, the remedy is functioning as intended by the 2003 ROD in tile sllort-tenn. However, Jor tIle remedy to junction as intended in tIle long niH, institutional controls need to be in effect Jor properties where radioactivity remains above 5 pei/g of Ra-226 and Th-232 combined above background concentrations for soil (OU2 properties with inaccessible soils: 80 Industrial Road, Lad;; 80 Han cock Street, Ladi; 100 Hancock Street, Lodi; 23 West Howcroft, Maywood; and 167 NI State Route 17, Maywood).

CDM 7-6 Section 7 Technical Assessment

Remedial Action Performance and Monitoring Results

At the OU2 properties, the past and present excavation and off-site disposal of the accessible soils above the 2003 ROO cleanup criteria are being implemented. To achieve the 2003 ROD cleanup criteria, the volume of impacted soils excavated was generally much greater than the volumes estimated in the 2003 ROD and, in some cases, reflected significant increase from the volume estimated in the remedial design. For example, at the 80 Industrial Road, Lodi property, the volume of accessible soil to be excavated was estimated to be 690 cy and 6,260 cy in the 2003 ROD and the 2004 remedial design, respectively, as compared to the actual excavation volume of 14,056 cy. The change in volumes, however, did not affect the protectiveness of the remedial action.

System OperationsjO&M

The past and current operations maintain the effectiveness of the remedial actions undertaken at the OU2 properties.

In addition, an annual Environmental Monitoring Program has been implemented for the Site to ensure that the public and the environment are adequately protected from FUSRAP contaminants, through annual monitoring of the air, surface, sediment, and groundwater at the Site. Based on the 2007 Annual Monitoring Report, the monitoring results were within the historical ranges and comparable to those reported in previous years. The surface water and sediment concentrations for contaminants of concern along Lodi Brook are trending downward over time, which can be attributed to the previous and ongoing remedial actions along Lodi Brook.

Opportunities for Optimization

Opportunities for optimization were not identified in this five-year review.

Early Indicators of Potential Remedy Problems

Early indicators of potential remedy problems were not identified in this five-year review.

Implementation of Institutional Controls and Other Measures

Per the 2003 ROD, institutional controls are required for properties with inaccessible soils or properties exhibiting residual radioactivity in soil above an unrestricted use cleanup criteria (i.e., an average of 5 pCi! g of Ra-226 and Th-232 combined above background). No long-term, project specific institutional controls have been implemented at the Site to date. USACE has drafted a LUCIP which is currently under revision; in the interim, USACE is negotiating land use controls with some property owners.

COM 7-7

IoI_CIwnocIIICo_~SIo~.Y,,_""" Section 7 Technical Assessment

Exposures at the MISS, Stepan and OU2 properties with ongoing remedial action, which could potentially result in unacceptable risks, are being controlled through access controls, work place management practices, property owner notifications, monitoring, existing zoning ordinances, and communication with local officials.

In addition, properties with inaccessible contamination are routinely monitored for gamma exposure rates and radon in buildings. In all cases, the measurements have not required further actions and meet applicable gamma dose and radon levels.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (MOs) used at the time of the remedy still valid?

Yes. The cleanup is currently being perfonned in accordance with the 2003 ROD. The remedial actions hnve met the 2003 ROD cleanup criteria thus far, although the initial volume of soil to be excavated was apparently underestimated which resulted in the slower progress for tlte remedy than originally anticipated (the completion time was estimated to be six years in tIre 2003 ROD, including one year for remedial design and five years of excavation, disposal and site restoration).

Question C: Has any other infonnation come to li~ht that could call into question the protectiveness of the remedy?

Based on the site inspection/interviews completed in May 2009, letters were sent out annually to owners of tIre 24 OU2 properties included in 2003 ROD, emphnsizing tire need a/keeping soils undisturbed (refer to Appendix F). However, there is currently no permanent institutional or engineering control for properties containing inaccessible contamination present generally underneath buildings or in tire immediate Vicinity of utility corridor (e.g., high-pressure gas line). USACE has drafted a LUCIP which is currently under review. 7.5 Summary of Technical Assessment In summary, cleanup guidelines that were applicable during remedial action were generalty followed, with the following exceptions:

• Phase I properties remediated during 1984 -1985: 96 Parkway, Rochelle Park (south of railroad track) property, and 468 Davison Street, Maywood property.

• Phase I properties remediated during 1995 -1999: 112 Avenue E, Lodi property, 9 Hancock Street, Lodi property, and the Lodi Municipal Park, Lodi property.

• OU2 properties: the six properties where radioactivity remains above the 2003 ROO unrestricted use cleanup criteria for soil but there are currently no existing institutional controls being implemented, including the Interstate 80 east right-of­ way and beneath road west right-of-way in Lodi; the 80 Industrial Road, Lodi property; 80 Hancock Street, Maywood property; 100 Hancock Street, Lodi property; 23 West Howcroft, Maywood property; and 167 NJ State Route 17, Maywood property.

7-8 Section 8 Issues Remedial actions were undertaken for Phase I properties, by the DOE and USACE, prior to the 2003 aU2 ROD, utilizing cleanup criteria that were in some instances (Le., cleanup criteria prior to 1995 EE/CA) less stringent than the 2003 aU2 ROD criteria. This five-year review identified some Phase I properties (see below and Tables 7-1 & 7-2) where the 2003 OU2 ROD criteria were not met.

For properties included in the 2003 ROD, long-term, project specific institutional controls have not yet been established for the remediated properties with inaccessible soils in excess of the 2003 ROD cleanup criteria. 8.1 Phase I Properties Remediated During 1984-1985 A total of three properties are identified that do not demonstrate the compliance with the 2003 ROD cleanup criteria (refer to Table 7-1 and Appendix G for more details).

The two properties with exceedances of the 2003 ROD soil cleanup criteria are as follows:

• 58 Trudy Drive, Lodi

• 96 Parkway, Rochelle Park (south of railroad track)

In addition, the 468 Davison Street, Maywood property had a pre-remedial action radon result of 8.9 pCi/ L which exceeded the 2003 ROD cleanup criteria for radon. No post-remedial action radon testing was performed to confirm that the current radon level meets the 2003 ROD cleanup criteria. In addition" elevated gamma exposure rates (16 to 31 uRI hr in the backyard over the asphalt area) and high gamma counts (82,000 cpm at approximately six feet bgs in boring MJC43) were reported, whereas no further investigation/cleanup was undertaken as a result of these findings.

The remediated areas are considered still in compliance involving the remaining 23 Phase I properties remediated during 1984-1985. The remaining portion of the 96 Parkway property (north of railroad and beneath the railroad) remediated in 2000 is in compliance with the 2003 ROD criteria.

These issues, together with their impact on current/future protectiveness, are summarized in Table 8-1 . 8.2 Phase I Properties Remediated During 1995-1999 A total of three properties are identified that do not demonstrate compliance with the 2003 ROD cleanup criteria (refer to Table 7-2 and Appendix G for more details).

8-1 Section 8 Issues

The 112 Avenue E, Lodi property was identified as the only property exceeding the 2003 ROD soil cleanup criteria, while compliance with the 2003 ROD cleanup criteria cannot be evaluated for the 9 Hancock Street, Lodi property and the Lodi Municipal Park property, due to insufficient investigation and/or remedial action (refer to Table 7-2 for more details):

• The pre-remedial action investigation data at 9 Hancock Street shows possible soil contamination beneath the basement and north side of the house; however, no excavation or investigations were completed in these areas to evaluate compliance with the ROD criteria. Note that 9 Hancock Street is not a designated property and the remedial action taken there was due to the contamination unexpectedly revealed during the remedial a,ction at the adjacent designated property at 7 Hancock Street, Lodi.

• The PRAR for the Lodi Municipal Park property indicates soil beneath the LBP is potentially contaminated; this area was considered inaccessible because of a compromise of structural integrity. However, no post-excavation biased samples were collected within this area to evaluate the residual radiochemical concentrations.

The remediated areas are considered still in compliance for the remaining 36 Phase I properties remediated during 1995-1999 (note that the 9 Hancock Street, Lodi property is not an originally designated property and thus excluded from the property count).

These issues, together with their impact on current/ future protectiveness, are summarized in Table 8-2. 8.3 Properties in the 2003 Record of Decision Six properties contain inaccessible soils that exceeded the 2003 ROO cleanup criteria (refer to Table 7-3 and Appendix G for more details):

• Interstate 80, Lodi (east right-of-way and beneath road west right-of-way)

• 80 Industrial Road, Lodi

• 80 Hancock Street, Maywood

• 100 Hancock Street, Lodi

• 23 West Howcroft, Maywood

• 167 NJ State Route 17, Maywood

The latter five properties (all commercial properties) were designated for restricted use rather than the originally intended unrestricted use.

COM 8-2 Section 8 Issues

USACE has drafted a LUCIP which is currently under revision; in the interim, USACE is negotiating land use controls with several property owners. In addition, a Memorandum of Understanding, dated June 9, 2000, between the USACE - New York District and the State of New Jersey Department of Transportation, as provided in Appendix H, is in effect for future work to be performed at highway projects involving removal of soil potentially contaminated with radioactive substances. However, institutional controls are not in place at any of the above six properties, as required by the 2003 ROD for the presence of inaccessible soils.

These issues, together with their impact on current/future protectiveness, are summarized in Table 8-3.

COM 8·3 Section 9 Recommendations and Follow-up Actions Tables 9-1 through 9-3 present a listing of recommendations and follow-up actions for individual properties where issues have been discussed in Section 7. The lists do not include those OU2 properties where remediation has been completed but no post­ remediation data have been presented, or where remediation is still ongoing or yet to be implemented. 9.1 Phase I Properties Remediated During 1984-1985 For the three properties that have been identified with open issues, the following steps are recommended (refer to Table 9-1 for specific steps for individual property).

• For the 468 Davison Street, Maywood property - perform radon testing; additional investigations are warranted to locate the source of elevated radon levels if the 2003 ROD ctiteria for radon concentrations are not met. Conduct data evaluation/ investigations of the area exhibiting high gamma exposure rate and downhole gamma counts, in accordance with MARSSIM guidance. Complete property remediation if needed.

• For the 58 Trudy Drive, Lodi property - conduct data evaluation/investigations of the area exhibiting radionuclide activity above the 2003 ROD soil cleanup criteria, in accordance with MARSSIM guidance. U the Uunrestricted use" criteria are not met, additional remedial action may be required at the property.

• For the 96 Parkway, Rochelle Park property - conduct additional data evaluation/ investigations in accordance with MARSSlM guidance, and complete remedial action as necessary if the 2003 ROD unrestricted use criteria are not met.

Properties which were not addressed in the 2003 OU2 ROD will be included in a future CERCLA decision document. Additional property evaluations, as recommended in this Five-Year Review Report, for six Phase I properties wiIl be performed as part of the future decision document. USACE will undertake these recommendations, as lead federal agency, with EPA oversight prior to the next five­ year review. 9.2 Phase I Properties Remediated During 1995-1999 For the two originally designated properties and one added property (9 Hancock Street, Lodi), which have been identified with open issues, the following steps are recommended (refer to Table 9-2 for specific steps for individual property).

• For the 112 Avenue E, Loch property - conduct investigations for areas exhibiting radionuclide activity above the 2003 ROD soil cleanup criteria, in accordance with MARSSIM guidance. U the "unrestricted use" criteria are not met, additional remedial action may be required at this property.

CDM 9-1 Section 9 Recommendations and FoIlow·up Actions

• For the 9 Hancock Street, Lodi property - conduct investigations for the interior and exterior areas that are suspected to have contamination but were not remediated during the Phase I cleanup effort. Complete property remediation if contaminated soil above the 2003 ROD soil cleanup criteria is identified.

• Implement LUCIP at the Ladt Municipal Park, Lodi property.

Properties which were not addressed in the 2003 OU2 ROD will be included in a future CERCLA decision document. Additional property evaluations, as recommended in this Five-Year Revie\y Report, for six Phase I properties will be performed as part of the future decision document. USACE wilt undertake these recommendations, as lead federal agency, with EPA oversight prior to the next five· year review. 9.3 Properties in the 2003 Record of Decision For the six properties that have been identified w ith open issues, the following steps are recommended (refer to Table 9-3 for specific steps for individual property).

• For the Lnterstate 80, Lodi (1) east right-of-way and (2) beneath road west right-of­ way property - implement the LUCIP and coordinate with NJOOT for future work to be performed at the highway to remove the inaccessible soil.

• For the other five properties - implement the LUCIP and continue performing O&M, including radon testing and inspections, at the properties; complete removal action of the inaccessible soil when rendered accessible in the future by the property owners.

U5ACE, as lead federal agency, will implement the recommended land use controls and monitoring to ensure long-term protectiveness, with EPA oversight prior to the next five-year review.

CDM 9·' Section 10 Protectiveness Statement The remedy implemented at the aU2 properties where the cleanup achieved the unrestricted use criteria is considered protective of human health and the environment. The remedy being implemented at the OU2 properties is considered protective of human health and the environment in the short-term. The aU2 remedy is expected to be protective of human health and the environment once fully implemented; however, long-term protectiveness of the remedy will require institutional controls for any property where radioactivity remains above the 2003 ROD unrestricted use cleanup criteria for soil or where the remediation of inaccessible soil is deferred until it is rendered accessible in the future. In the interim, protectiveness is being achieved through access controls, property owner notifications, mOnitoring, existing zoning ordinances, and communication with local officials.

The protectiveness of the three groups of properties is further discussed below. 10.1 Phase I Properties Remediated During 1984-1985 Based on the available data, the remedy implemented is considered protective of human health and the environment at 23 of the 26 Phase I properties remediated during 1984-1985. For the remaining three properties, additional data evaluation! investigation as discussed in Section 8.1 may be required to determine whether the remedy is protective of human health and the environment. In addition, all properties which were not addressed in the 2003 OU2 ROD will be included in a future CERCLA decision document. 10.2 Phase I Properties Remediated During 1995-1999 Based on the available data to date, the remedy implemented is considered protective of human health and the environment at 36 of the 38 Phase I properties remediated during 1995-1999. For the remaining two properties and the one added property (9 Hancock Street, Lodi), additional data evaluation! investigation as discussed in Section 8.2 may be required to determine whether the remedy is protective of human health and the environment. In addition, all properties which were not addressed in the 2003 OU2 ROD will be included in a future CERCLA decision document. 10.3 Properties in the 2003 Record of Decision The remedy being implemented at the OU2 properties is considered protective of human health and the environment in the short-term based on:

• All accessible soils in excess of 2003 ROD cleanup criteria at a remediated OU2 property have been removed for off-site disposal.

• In the interim, exposures at the MISS, Stepan and OU2 properties with ongOing remedial action, which could result in unacceptable risks, are being controlled

10·1 Section 10 Protectiveness Statement

through access controls, work place management practices, property owner notifications, monitoring, existing zoning ordinances, and communication with local officials .

• Properties with inaccessible contamination are routinely monitored for gamma exposure rates and radon in buildings. In all cases, the measurements have not required further actions and meet applicable gamma dose and radon levels, demonstrating short-term protectiveness.

However, to be protective of human health and the environment in the future, any property where radioactivity remains above 5 pei/ g of Ra-226 and Th-232 combined above background concentrations for soil will require institutional controls to limit land use. This will be achieved by implementing the LUCIP and removal of the inaccessible soils when rendered accessible in the future.

CDM

"'-CO'IomoaICo ~s..F~.Y ___ _ ..... _.- ...... _...... _...•.... _.. ------.... "

Section 11 Next Review A Five-Year Review should be conducted. every five years when hazardous substances, pollutants, or contaminants remain at a site above levels that allow for unlimited use and unrestricted exposure in accordance with Section 121 (c) of CERCLA and 40 CFR 300.430(f)(4)(ii). The Army Corps of Engineers is still in the process of remediating the OU2 properties. Therefore, the next five-year review for the Maywood Site will be completed by September 2014.

Walter E. Mugdan, irector Emergency & Remedial Response Division U.S. EPA - Region 2

(

11·1 Table 1-1 Property List Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Originally Property Addressed in Year Property Address Type of Property Included in Cleanup Criteria Remedial Action Status ID ROD Completed FMSS 26 properties remediated during 1984-1985 #1 454 Davison Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #2 459 Davison Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #3 460 Davison Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #4 464 Davison Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #5 468 Davison Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #6 459 Latham Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #7 461 Latham Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #8 467 Latham Street, Maywood Residential No Yes Unrestricted Use Remediated 1984-1985 #9 10 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #10 22 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #11 26 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #12 30 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #13 34 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #14 38 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #15 42 Grove Avenue, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #16 86 Parkway, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #17 90 Parkway, Rochelle Park Residential No Yes Unrestricted Use Remediated 1984-1985 #18 59 Avenue C, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #19 121 Avenue F, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #20 123 Avenue F, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #21 58 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #22 59 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #23 61 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #24 64 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #25 3 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1984-1985 #26 96 Parkway, Rochelle Park (Ballod Property) (1) Commercial No Yes Unrestricted Use Remediated 1984-1985, 2000 38 properties remediated during 1995-1999 #27 90 Avenue C, Lodi Residential No Yes Unrestricted Use Remediated 1993 & 1995 #28 79 Avenue B, Lodi Residential No Yes Unrestricted Use Remediated 1995 #29 108 Avenue E, Lodi Residential No Yes Unrestricted Use Remediated 1995 #30 112 Avenue E, Lodi Residential No Yes Unrestricted Use Remediated 1995 #31 113 Avenue E, Lodi Residential No Yes Unrestricted Use Remediated 1995 #32 7 Branca Court, Lodi Residential No Yes Unrestricted Use Remediated 1996 #33 16 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996 #34 18 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996

A Page 1 of 3 Table 1-1 Property List Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Originally Property Addressed in Year Property Address Type of Property Included in Cleanup Criteria Remedial Action Status ID ROD Completed FMSS

#35 20 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996 #36 22 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996 #37 24 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996 #38 26 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1996 #39 11 Redstone Lane, Lodi Residential No Yes Unrestricted Use Remediated 1996 #40 34 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1997 #41 5 Shady Lane, Lodi Residential No Yes Unrestricted Use Remediated 1997 #42 7 Shady Lane, Lodi Residential No Yes Unrestricted Use Remediated 1997-1998 #43 136 West Central Avenue, Maywood Residential No Yes Unrestricted Use Remediated 1998-1999 #43A 142* West Central Avenue, Maywood Residential No No Unrestricted Use Remediated 1998-1999 #44 200 Brookdale Street, Maywood Residential No Yes Unrestricted Use Remediated 1998 #45 60 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1998-1999 #46 62 Trudy Drive, Lodi Residential No Yes Unrestricted Use Remediated 1998-1999 #47 4 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #48 5 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #48A 46* Long Valley Road, Lodi Residential No No Unrestricted Use Remediated 1998 #49 6 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #50 7 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #50A 9* Hancock Street, Lodi Residential No No Unrestricted Use Remediated 1998 #51 8 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #52 10 Hancock Street, Lodi Residential No Yes Unrestricted Use Remediated 1998 #53 2 Branca Court, Lodi Residential No Yes Unrestricted Use Remediated 1999 #54 4 Branca Court, Lodi Residential No Yes Unrestricted Use Remediated 1998 #54A 28* Long Valley Road, Lodi Residential No No Unrestricted Use Remediated 1998 #55 6 Branca Court, Lodi Residential No Yes Unrestricted Use Remediated 1998 #56 11 Branca Court, Lodi Residential No Yes Unrestricted Use Remediated 1997-1999 #57 14 Long Valley Road, Lodi Residential No Yes Unrestricted Use Remediated 1998 #58 17 Redstone Lane, Lodi Residential No Yes Unrestricted Use Remediated 1998 #58A 19* Redstone Lane, Lodi Residential No No Unrestricted Use Remediated 1998 #59 106 Columbia Lane, Lodi Residential No Yes Unrestricted Use Remediated 1998-1999 #60 99 Garibaldi Avenue, Lodi Residential No Yes Unrestricted Use Remediated 1999 #61 Lodi Municipal Park, Lodi Municipal No Yes Unrestricted Use Remediated 1999 #62 Fire Station No. 2, Lodi Municipal No Yes Unrestricted Use Remediated 1998-1999 #63 Fireman’s Memorial Park, Lodi Municipal No Yes Unrestricted Use Remediated 1997-1999 #64 John F. Kennedy Municipal Park, Lodi Municipal No Yes Unrestricted Use Remediated 1998-1999

A Page 2 of 3 Table 1-1 Property List Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Originally Property Addressed in Year Property Address Type of Property Included in Cleanup Criteria Remedial Action Status ID ROD Completed FMSS

24 properties included in 2003 Record of Decision #65 Interstate 80, Lodi: (1) east right-of-way and (2) beneath road State Yes Yes Restricted Use Remediated (1) 2002-2003 west right-of-way (2) 1996-1998 #65A 150* Essex Street, Lodi Commercial Yes No Unrestricted Use Remediated 2003 #66 160, 174 Essex Street, Lodi Commercial Yes Yes Unrestricted Use Remediated 2003 #67 72 Sidney Street (a.k.a. 88 Money Street), Lodi Commercial Yes Yes Unrestricted Use Remediated 2002 #68 170 Gregg Street, Lodi Commercial Yes Yes Unrestricted Use Remediated 2004 #69 80 Industrial Road, Lodi Commercial Yes Yes Unrestricted Use Remediated 2007 #70 80 Hancock Street, Lodi Commercial Yes Yes Unrestricted Use Remediated 2006 #71 100 Hancock Street, Lodi Commercial Yes Yes Unrestricted Use Remediated 2005-2006 #72 23 West Howcroft, Maywood Commercial Yes Yes Unrestricted Use Remediated 2006 #73 85, 87, 99–101 NJ State Route 17, Maywood Commercial Yes Yes Unrestricted Use Remediated 2004-2006 #74 167 NJ State Route 17, Maywood Commercial Yes Yes Unrestricted Use Remediated 2003-2008 #75 137 State Route 17, Maywood Commercial Yes Yes Unrestricted Use Remediated 2006 #76 200 NJ State Route 17, Maywood Commercial Yes Yes Unrestricted Use Remediated 2006 #77 239 NJ State Route 17, Maywood Commercial Yes Yes Unrestricted Use Remediated 2007 #78 99 Essex Street, Maywood Commercial Yes Yes Unrestricted Use Remediated 2007 #79 113 Essex Street, Maywood Commercial Yes Yes Unrestricted Use Remediated 2007 #80 8 Mill Street, Lodi State Yes Yes Unrestricted Use Remediated 2007 #81 100 West Hunter Avenue, Maywood and Rochelle Park (MISS) Federal Yes Yes Restricted Use Active Remediation Ongoing #82 100 West Hunter Avenue, Maywood (Stepan Company) Commercial Yes Yes Restricted Use Active Remediation Ongoing #83 149-151 Maywood Avenue, Maywood Commercial Yes Yes Restricted Use Active Remediation Ongoing #84 50 and 61 West Hunter Avenue, and 205 Maywood Avenue, Commercial Yes Yes Unrestricted Use Active Remediation Ongoing Maywood #85 Lodi Industrial Railroad, Maywood Commercial Yes Yes Restricted Use Scheduled for Remediation - #86 111 Essex Street, Maywood Commercial Yes Yes Unrestricted Use Scheduled for Remediation - #87 New York, Susquehanna, & Western Railway Commercial Yes Yes Restricted Use Inaccessible - #88 NJ State Route 17, Maywood and Rochelle Park State Yes Yes Restricted Use Inaccessible -

* = Identifies property addresses that were not originally designated, but where contamination was found to extend to the properties from adjacent desiganted properties where cleanup activities were undertaken. These 6 properties are in addition to the 88 originally designated properties at the FMSS. (1) Removal action completed during 1984-1985 occurred from the parcels south of the railroad track at the 96 Parkway, Rochelle Park property (Ballod property), while the remedial action undertaken at the area north of the railroad track was completed in 2000.

A Page 3 of 3 Table 4-1 Cleanup Criteria for Phase I Properties - 1984 to 1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

FMSS COCs Cleanup Criteria Ra-226 Ra-228 Unrestricted Use: an average of 5 pCi/g above background in the first 15 cm of soil below surface, and 15 a,b,c Th-230 pCi/g above background level in any subsequent 15-cm layer Radionuclides in Soil Th-232 Other DOE guideline indicated that a site-specific soil guideline would be calculated using the DOE manual Radionuclides developed for FMSS site, however, no such values were specified in the PRARs Gamma Exposure Rate 100 millirem per year (mrem/yr) above background, for which a 100 mrem/yr value was used In any occupied or habitable building, an annual average (or equivalent) radon decay product concentration Airborne Radon Decay Products in Structure (including background) shall not exceed 0.02 working level (WL) a - In the event of occurrence of mixtures of radionuclides, the fraction contributed by each radionuclide to its limit shall be determined, and the sum of these fractions shall not exceed 1. b - The cleanup criteria represent unrestricted-use residual concentrations above background averaged across any 15-cm thick layer to any depth and over any contiguous 100-m2 surface area. c - Localized concentrations in excess of these limits are allowable provided that the average over 100 m2 is not exceeded.

A Page 1 of 1 Table 4-2 Cleanup Criteria for Phase I Properties - 1995 to 1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

FMSS COCs Cleanup Criteria Ra-226 Ra-228 An average of 5 pCi/g above background over any 15-cm (6-in)-thick layer of soil regardless of depth a,b,c Radionuclides in Soil Th-230 Th-232 U-238 100 pCi/g total uranium, 50 pCi/g U-238 100 mrem/yr. In implementing this limit, as-low-as-reasonably-achievable (ALARA) principles were applied to Gamma Exposure Rate set site-specific guidelines

Radon and Radon Decay Products in Structure N/A a - The cleanup criteria takes into account ingrowth of Ra-226 from Th-230 and of Ra-228 from Th-232, assuming secular equilibrium. If either Th-230 and Ra-226 or Th-232 and Ra-228 are both present, not in secular equilibrium, the criteria apply to the higher concentrations. If other mixtures of radionuclides occur, the concentrations of individual radionuclides must be reduced so that (1) the dose for the mixtures will not exceed the basic dose limit, or (2) the sum of the soil concentrations of each radionuclide to the allowable limit for the radionuclide will not exceed 1. b - The cleanup criteria represented residual concentrations above background averaged across any 15-cm thick layer to any depth and over any contiguous 100-m 2 surface area. c - Hot Spot Criteria was used, if the average concentration in any surface or below-surface area less than or equal to 25 m2 (269 ft2) exceeds the authorized limit or guideline by a factor of (100/A)1/2, where A is the area of the elevated region in square meters. In addition, every reasonable effort shall be made to remove any source of radionuclide that exceeds 30 times the appropriate limit for soil, regardless the average concentration in the soil.

A Page 1 of 1 Table 4-3 Cleanup Criteria in 2003 Record of Decision Maywood Chemical Co. Superfund Site Bergen County, New Jersey

FMSS COCs Cleanup Criteria

Unrestricted use properties: an average of 5 pCi/g Ra-226 and Th-232 combined above background Ra-226 Restricted use properties: an average of 15 pCi/g Ra-226 and Th-232 combined above background for Radionuclides in Soil Th-232 subsurface soils with an ALARA goal of 5 pCi/g

U-238 100 pCi/g total uranium, 50 pCi/g U-238 Exposure Dose Limit 15 mrem/yr above background dose limit specified in NJAC 7:28-12.8(a)1

Radon and Radon Decay Products in Structure Indoor radon air concentration: 3 pCi/L radon-222 (Ra-222) limit specified in the NJAC 7:28-12.8(a)2

ALARA - as low as reasonably achievable

A Page 1 of 1 Table 7-1 Summary of Reviews for Phase I Properties - 1984 to 1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Post-Remediation Resultsa DOE Criteria Metb 2003 ROD Criteria Metb

Structure Excavation Max. Ra-226+Th-232 Radon Decay Product ID Property Address Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Radon Above Comment Type Area Above Background Above Background Soil Activity Radon Soil Activity Radon Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/L) (pCi/g)c (WL)

Residential Properties (Cleanup Criteria - Unrestricted Use)

#1 454 Davison Street, Maywood Not Known Exterior 0 0 0.3 0 NA NA Yes Not Yes Not A contaminated area less than 10 m2 in the backyard was excavated. Applicable Applicable The contaminated area was part of a large contiguous deposit on the adjacent property at 460 Davison. Based on the extent of contamination and radon results at adjacent property, radon testing is not warranted at this property. #2 459 Davison Street, Maywood Basement Exterior 0.93 1.9 0.34 2.63 1.3 <0.006 Yes Yes Yes Yes Acceptable for unrestricted use. #3 460 Davison Street, Maywood Basement Exterior 2.43 4.6 1.34 7.03 1.8 <0.006 Yes Yes Yes Yes One post-excavation sample (sample number 22, collected at approximately 4 feet bgs) exceeded the combined Ra-226 and Th- 232 criteria of 5 pCi/g (2003 ROD criteria). The IVC report also indicate exceedance of 2003 ROD criteria for sample collected in the same area (location 4L Ra-226: 2.8 pCi/g & Th-232: 5.1 pCi/g). Additional sample (sample number 27) collected in the vicinity of exceedance area was below the 2003 ROD criteria. This area met the

DCGLEMC criteria for the Site (see Appendix G).

#4 464 Davison Street, Maywood Basement Exterior & 2.23 2.2 0.44 2.73 1.4 0.011 Yes Yes Yes Yes Acceptable for unrestricted use. Interior #5 468 Davison Street, Maywood Basement Exterior 0.43 4 1.34 4.43 Pre-Exc 8.9 Pre-Exc 0.06 Yes Unknown Not Unknown a) Pre-construction maximum gamma exposure rate of 33 uR/hr and Demonstrated radon concentration of 8.9 pCi/L noted in the basement exceeded the 2003 ROD criteria. The source of high gamma exposure rate in the basement was attributed to exterior soil contamination. However, there were no post-remediation radon measurements or interior radiological investigation completed to confirm that gamma exposure and radon levels are below the 2003 ROD criteria. b) Pre-remediation Radiological Survey Report indicates elevated gamma exposure rates (16 to 31 uR/hr) in the backyard over the asphalt area; however, no investigation was completed in this area to identify the source of elevated gamma readings. In addition, this report also indicate high gamma count of 82,000 cpm at approximately 6 feet bgs in boring MJC43; however, the PRAR shows excavation depth of 1 foot in this area.

#6 459 Latham Street, Maywood Not Known Exterior 0 0 0 0 0.8 <0.006 Yes Yes Yes Yes Acceptable for unrestricted use. #7 461 Latham Street, Maywood Basement Exterior 1.13 4.9 0.84 5.93 0.7 <0.006 Yes Yes Yes Yes One post-excavation sample (sample number 15, collected at approximately 2 feet bgs) exceeded the combined Ra-226 and Th- 232 criteria of 5 pCi/g (2003 ROD criteria). The IVC report also indicates exceedance of 2003 ROD criteria for sample collected in the same area (location 4L Ra-226: 1.1 pCi/L & Th-232:4.4 pCi/L). This

area met the DCGLEMC criteria for the Site (see Appendix G).

#8 467 Latham Street, Maywood Basement Exterior 0 0.4 0 0.33 1.5 <0.006 Yes Yes Yes Yes Acceptable for unrestricted use.

#9 10 Grove Avenue, Rochelle Park Not Known Exterior 0.53 4.6 0 5.13 0.9 NA Yes Yes Yes Yes One post-excavation sample (sample number 2, collected at approximately 1 foot bgs) collected from an isolated excavation area of less than 5 m2 exceeded the combined Ra-226 and Th-232 criteria

of 5 pCi/g (2003 ROD criteria). This area met the DCGLEMC criteria for the Site (see Appendix G). #10 22 Grove Avenue, Rochelle Park Not Known Exterior 0.53 4.4 0.54 4.93 NA <0.005 Yes Yes Yes Yes Acceptable for unrestricted use.

#11 26 Grove Avenue, Rochelle Park Not Known Exterior 0 0.2 0 0 NA <0.005 Yes Yes Yes Yes Acceptable for unrestricted use.

#12 30 Grove Avenue, Rochelle Park Not Known Exterior 0 0.2 0.24 0.03 NA <0.005 Yes Yes Yes Yes Acceptable for unrestricted use.

#13 34 Grove Avenue, Rochelle Park Not Known Exterior 0.13 2.9 0 3.03 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. #14 38 Grove Avenue, Rochelle Park Not Known Exterior 1.43 13.2 0 14.63 NA 0.008 Yes Yes Yes Yes One post-excavation sample (sample location 6, collected at approximately 2 feet bgs) exceeded the combined Ra-226 and Th- 232 criteria of 5 pCi/g (2003 ROD criteria). IVC sample collected in the approximate vicinity of sample location 6 also exceeded the 2003

ROD criteria. This area met the DCGLEMC criteria for the Site (see Appendix G). #15 42 Grove Avenue, Rochelle Park Not Known Exterior 0.03 3 0 3.03 NA <0.005 Yes Yes Yes Yes Acceptable for unrestricted use.

#16 86 Parkway, Rochelle Park Not Known Exterior 0.23 2.6 0.94 2.83 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. #17 90 Parkway, Rochelle Park Not Known Exterior 0.23 1.8 0.24 1.53 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

A Page 1 of 8 Table 7-1 Summary of Reviews for Phase I Properties - 1984 to 1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Post-Remediation Resultsa DOE Criteria Metb 2003 ROD Criteria Metb

Structure Excavation Max. Ra-226+Th-232 Radon Decay Product ID Property Address Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Radon Above Comment Type Area Above Background Above Background Soil Activity Radon Soil Activity Radon Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/L) (pCi/g)c (WL)

Residential#18 59 Avenue Properties C, Lodi (Cleanup CriteriaNot - Unrestricted Known Exterior Use) 0.13 4.1 1.54 4.23 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. #19 121 Avenue F, Lodi 2 Story Exterior 0.33 2.1 2.04 2.33 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. #20 123 Avenue F, Lodi 2 Story Exterior 0 1.8 1.64 1.73 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. #21 58 Trudy Drive, Lodi Not Known Exterior 1.63 8.2 4.14 9.83 NA NA Yes Yes Not Yes a) Two post-excavation samples 12 and 13 (sample number 12: Ra- Demonstrated 226 1.63 pCi/g and Th-232 8.2 pCi/g; sample number 13: Ra-226 1.13 pCi/g and Th-232 6.9 pCi/g) collected in the backyard at 0.5-foot depth exceeded the combined Ra-226 and Th-232 criteria of 5 pCi/g (2003 ROD criteria). Pre-construction survey shows contamination above the ROD criteria at BH-6 (front yard) and BH-20 (back yard) to 1 foot. The excavation depth was 0.5-foot based on DOE subsurface criteria of 15 pCi/g. b) No radon monitoring results are available. However, based on residual Ra-226 concentration, radon concentration is estimated to be below the 2003 ROD criteria. #22 59 Trudy Drive, Lodi Not Known Exterior 0.33 2.7 2.64 3.03 NA NA Yes Yes Yes Yes No radon monitoring results are available. However, based on residual Ra-226 concentration, radon concentration is estimated to be below the 2003 ROD criteria. #23 61 Trudy Drive, Lodi Not Known Exterior 1.33 4.5 2.04 5.13 NA NA Yes Yes Yes Yes a) One post-excavation sample (sample number 13) exceeded the combined Ra-226 and Th-232 criteria of 5 pCi/g. Sample number 13 was collected with sample number 12 (combined net activity of 3.2 pCi/g) and was bounded with clean samples. The average activity (3.7 pCi/g) of the hot spot area is less than than the 2003 ROD criteria. b) No radon monitoring results are available. However, based on residual Ra-226 concentration, radon concentration is estimated to be below the 2003 ROD criteria.

#24 64 Trudy Drive, Lodi Not Known Exterior 0.43 2.3 4.34 2.73 NA NA Yes Yes Yes Yes a) No radon monitoring results are available. However, based on residual Ra-226 concentration, radon concentration is estimated to be below the 2003 ROD criteria. b) In 2005, additional excavation was completed in the backyard of the property during 100 Hancock Street remediation. In total 120 CY of contaminated soil was removed from 64 Trudy Avenue in 2005.

#25 3 Hancock Street, Lodi Not Known Exterior 0 1.3 0.74 1.03 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background. Commercial Properties (Cleanup Criteria - Unrestricted Use) #26 96 Parkway, Rochelle Park None Not 2.93 24.1 14.74 26.5 Not Applicable Not Applicable Not Not Not Not The site do not meet the unrestrictive use criteria. Several post (South of railroad track) Applicable Demonstrated Applicable Demonstrated Applicable excavation sample results and gamma exposure dose rate were above the cleanup criteria. NA - Not Available a - Post-excavation results reported are levels above background values for Ra-226 of 0.87 pCi/g, Th-232 of 0.9 pCi/g, U-238 of 0.86 pCi/g, Gamma Exposure Dose of 100 mrem/yr, Rn-222 of 0.5 pCi/L and radon decay product of 0.005 WL. b - DOE and ROD cleanup criteria are shown in Table 4-1. c - Bold values exceed the ROD cleanup criteria. Compliance with DOE and/or ROD cleanup criteria not demonstrated. Compliance with the ROD cleanup criteria cannot be evaluated since no post-remediation radon data is present.

A Page 2 of 8 Table 7-2 Summary of Reviews for Phase I Properties - 1995 to1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Pre-Remediation Post Remediation Resultsa Results DOE Criteria Metb 2003 ROD Criteria Metb Structure Excavation Composite Soil Sample Biased Soil Sample ID Property Address Radon Comment Type Area Max. Ra-226+Th-232 Max. Ra-226+Th-232 Radon Decay Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Soil Activity Radon Soil Activity Radon Above Background Above Background (pCi/L) Product Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) (pCi/g) (pCi/g)c (WL)

Residential Properties (Cleanup Criteria - Unrestricted Use) #27 90 Avenue C, Lodi Basement Exterior 0 0.22 0 0 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#28 79 Avenue B, Lodi 2 Story Exterior 0 2.85 0 2.67 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#29 108 Avenue E, Lodi 2 Story Exterior 0 2.48 1.99 2.29 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#30 112 Avenue E, Lodi 1 1/2 Story Exterior 0 2.06 0 1.94 0.23 8.56 6.21 8.79 NA NA Yes Yes Not Yes a) An inaccessible area (2.5 m in diameter) beneath the tree in the backyard Demonstrated could not be excavated without uprooting the tree. Four samples collected from the inaccessible area had Th-232 concentration from 4.62 to 16.3 pCi/g (avg 9.56 pCi/g). This area meets the Hot Spot criteria established in DOE Order

5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G). b) Radiological investigations (1992 RI) showed soil surface sample results at location R416 and south of R416 above the 2003 ROD criteria; however, the PRAR showed no excavation was performed in this area. c) No radon monitoring results are available. However, based on residual Ra- 226 concentration, radon concentration is estimated to be below the 2003 ROD criteria.

#31 113 Avenue E, Lodi 1 Story Exterior 0 2.45 0 2.36 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#32 7 Branca Court, Lodi Not Known Exterior 0 1.2 0 1.11 ------<0.2 0.003 Yes Yes Yes Yes Acceptable for unrestricted use. #33 16 Long Valley Road, Lodi Not Known Exterior 0.05 1.05 0 1.05 ------<0.2 0.002 Yes Yes Yes Yes Acceptable for unrestricted use. #34 18 Long Valley Road, Lodi Not Known Exterior 0.37 2.08 0 2.03 ------<0.1 0.002 Yes Yes Yes Yes Acceptable for unrestricted use. #35 20 Long Valley Road, Lodi Not Known Exterior 0.02 0.76 0 0.66 ------<0.14 0.002 Yes Yes Yes Yes Acceptable for unrestricted use. #36 22 Long Valley Road, Lodi Not Known Exterior 0.06 1.39 0 1.26 0.29 7.57 0 7.86 <0.5 0.003 Yes Yes Yes Yes Area O, approximately 10 m2 at the back of the property was not remediated. Seven samples were collected from the bank to delineate the area of remaining contamination. Six of the samples had Th-232 concentrations ranging from 0.67-3.0 pCi/g. One sample was above the criteria with maximum Th-232 concentration of 8.57 pCi/g. This area meets the Hot Spot criteria established in DOE Order 5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G). #37 24 Long Valley Road, Lodi Not Known Exterior 0 0.57 0 0.44 ------<2 0.003 Yes Yes Yes Yes Acceptable for unrestricted use. #38 26 Long Valley Road, Lodi Not Known Exterior 0 0.65 0 0.56 ------<0.3 0.003 Yes Yes Yes Yes Acceptable for unrestricted use. #39 11 Redstone Lane, Lodi Not Known Exterior 0 0.3 0 0.17 0.88 10.52 0 11.4 0.1 0.001 Yes Yes Yes Yes Area D, approximately 3 m2 beneath the concrete driveway was not remediated. The maximum Th-232 concentration of 11.52 pCi/g was noted in this area. This area meets the Hot Spot criteria established in DOE Order 5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G).

#40 34 Long Valley Road, Lodi 2 Story Exterior 0 0 0 0 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#41 5 Shady Lane, Lodi 1 Story Exterior 1.01 0.34 0 1.35 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#42 7 Shady Lane, Lodi 1 Story Exterior 1.42 0.75 0 2.17 ------NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#43 136 West Central Avenue, Basement Exterior & 0 0.16 0 0.09 0.45 2.38 0 1.4 NA 0.0009 Yes Yes Yes Yes Acceptable for unrestricted use. Maywood Interior #43A 142* West Central Avenue, Basement Exterior 0.28 1.08 0 1.36 0.26 2 0 2.26 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Maywood Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#44 200 Brookdale Street, Not Known Exterior 0.69 1.48 35.68 1.62 2.41 1.52 55.4 2.03 NA NA Yes Yes Yes Yes a) One biased sample (MVP0257) exceeded the ROD criteria for U-238. This Maywood area meets the Hot Spot criteria established in DOE Order 5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G). b) No radon monitoring results are available. However, based on residual Ra- 226 concentration, radon concentration is estimated to be below the 2003 ROD criteria. #45 60 Trudy Drive, Lodi Basement Exterior & 0 0.3 0 0.3 0.08 4.36 0 4.44 1.3 0.001 Yes Yes Yes Yes The Lodi Brook Pipeline (LBP) runs across the property in the front yard. Interior Excavation along the LBP was approximately 5 to 9 feet deep below ground surface. The biased sample collected along the pipeline and from underpin shows the radionuclides activity to be below the 2003 ROD criteria.

#46 62 Trudy Drive, Lodi Basement Exterior 0 0.17 0 0 0.44 3.25 1.46 3.69 NA NA Yes Yes Yes Yes No radon or radon decay product testing was performed. However, per Site Inspection/Interview Meeting Minutes for the Five Year Review, soil remediated to below the site cleanup criteria will meet the 2003 ROD criteria for indoor radon air concentration of less than 3.0 pCi/L above background.

#47 4 Hancock Street, Lodi Basement Exterior & 0 0.04 0 0 0.31 1.27 0 1.58

A Page 3 of 8 Table 7-2 Summary of Reviews for Phase I Properties - 1995 to1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Pre-Remediation Post Remediation Resultsa Results DOE Criteria Metb 2003 ROD Criteria Metb Structure Excavation Composite Soil Sample Biased Soil Sample ID Property Address Radon Comment Type Area Max. Ra-226+Th-232 Max. Ra-226+Th-232 Radon Decay Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Soil Activity Radon Soil Activity Radon Above Background Above Background (pCi/L) Product Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) (pCi/g) (pCi/g)c (WL)

Residential#48A 46* Properties Long Valley (Cleanup Road, Lodi Criteria Not - KnownUnrestrictedExterior Use) 0 0.03 0 0 1.38 4.81 0 4.93 NA NA Yes N/A Yes N/A A small contaminated area in the backyard was excavated. The contaminated area was part of large contiguous deposit on the adjacent properties at 5 and 7 Hancock Street. Based on the extent of contamination and adjacent property radon results, radon testing at this property is not warranted.

#49 6 Hancock Street, Lodi Basement Exterior & 0.01 0.25 1.27 0.1 0.71 4.42 0 4.28 0.3 0.006 Yes Yes Yes Yes The LBP runs in the ROW of Hancock Street. The maximum excavation depth Interior along the LBP line was approximately 2 feet below ground surface. Based on excavation depth, it is assumed that no contamination exists below the LBP.

#50 7 Hancock Street, Lodi Basement Exterior & 0.44 0.33 0 0.77 0.23 2.99 0 3.22 0.4 0.004 Yes Yes Yes Yes Acceptable for unrestricted use. Interior #51 8 Hancock Street, Lodi Basement Exterior & 0.52 0.87 0 1.04 3.16 12.8 4.32 15.96 0.6 0.003 Yes Yes Yes Yes a) One biased sample (MVP0347), collected from underpin #9, exceeded the Interior 2003 ROD criteria. The sample location is part of a composite sample grid block and the average combined composite sample activity was 2.0 pCi/g. This area meets the Hot Spot criteria established in DOE Order 5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G). b) The LBP runs along the northeast corner of the property in the ROW of Hancock Street. The maximum excavation depth along the LBP line was approximately 2 to 3 feet below ground surface. Based on excavation depth, it is assumed that no contamination exists below the LBP.

#50A 9* Hancock Street, Lodi Basement Exterior 0.85 0.42 0 1.27 0.48 4.48 0 4.78 0.9 0.008 Yes Yes Unknown Yes a) The Radiological Characterization Report (RCR) indicates high gamma count of 28,000 to 32,000 counts per minute from 3.5 to 4 feet bgs in boring 560R. Only surface soil samples up to 1 foot bgs were collected from this location. The PRAR shows no excavation around boring 560R (north side of the house). Based on the gamma reading, suspect soil contamination to be above the ROD criteria. b) The RCR indicates contamination below basement slab based on exterior borings/samples. The PRAR states that contamination was not suspected beneath the basement because the basement is deeper than the depth of excavation (4 feet). However, no interior investigation was completed after remediation to rule out interior contamination. #52 10 Hancock Street, Lodi Not Known Exterior & 0.3 0.18 0 0.42 0.45 2.62 2.25 2.4 0.6 0.005 Yes Yes Yes Yes The LBP runs across the property in the front yard. Excavation along the LBP Interior was approximately 7 to 9 feet deep below ground surface. The PRAR does not indicate any inaccessible soil below the LBP line. Therefore, it is assumed that all the contaminated material below the LBP line was removed.

#53 2 Branca Court, Lodi 2-Story, Slab Exterior & 0 0.31 0 0.31 1.94 30.57 6.21 32.51 <0.8 0.002 Not Yes Yes Yes The PRAR indicates that excavation in the vicinity of the LBP line was on Grade Interior Demonstrated approximately 7 to 8 feet below ground surface and the area along the LBP was not remediated. The biased sample collected from inaccessible soil below LBP shows the radionuclide activity to be above the DOE and 2003 ROD criteria and inaccessible soil area did not meet the hot spot criteria (DOE Order 5400.5). This area met the DCGLEMC criteria for the Site (see Appendix G). #54 4 Branca Court, Lodi Basement Exterior & 0 0.53 0 0.35 0.49 2.18 10.63 2.16 0.2 0.003 Yes Yes Yes Yes Acceptable for unrestricted use. Interior #54A 28* Long Valley Road, Lodi Not Known Exterior ------0.49 0.86 10.01 1.35 NA NA Yes NA Yes NA A small contaminated area less than 3 m2 was excavated along the back of the property line. The contaminated area was part of large contiguous deposit on the adjacent property at 4 Branca Court. Based on the extent of contamination and adjacent property radon results, radon testing at this property is not warranted. Two biased samples collected from the excavation were below the 2003 ROD criteria. #55 6 Branca Court, Lodi Basement Exterior & 0 0.04 0 0 0.23 6.06 0 6.29 4 0.007 Yes Yes Yes Yes a) One biased sample (MVP1234) collected from underpin exceeded the 2003 Interior ROD criteria. This biased sample area meets the Hot Spot criteria established in DOE Order 5400.5. This area also met the DCGLEMC criteria for the Site (see Appendix G). b) Pre-remediation radon concentration was equal to the ROD criteria, and no post-remediation radon test was performed. However, based on residual Ra- 226 concentration, radon concentration is estimated to be below the 2003 ROD criteria. #56 11 Branca Court, Lodi 2-Story, Slab Exterior & 0 0.23 0 Data not available due to problems with electronic file. <0.8 0.004 Not Yes Yes Yes The PRAR indicates that area along the LBP was not remediated. The biased on Grade Interior Demonstrated sample collected along the pipeline (inaccessible soil) shows the radionuclide activity to be above the cleanup criteria and inaccessible soil area did not meet the hot spot criteria (DOE Order 5400.5). This area met the DCGLEMC criteria for the Site (see Appendix G). #57 14 Long Valley Road, Lodi Not Known Exterior 0 0 0 0 0 1.12 0 1.06 NA NA Yes Yes Yes Yes Per Five Year Review Site Inspection/Interview Meeting Minutes, soil remediation to below the site cleanup criteria will meet the 2003 ROD remedial action objectives for indoor radon air concentration of less than 3.0 picocuries per liter (pCi/L) above background. #58 17 Redstone Lane, Lodi Basement Exterior 0 0.14 0 0 0 4.7 0 4.7 0.5 0.002 Yes Yes Yes Yes Acceptable for unrestricted use. #58A 19* Redstone Lane, Lodi Not Known Exterior 0 0.15 0 0 0.08 2.05 4.05 2.05 ND 0.003 Yes Yes Yes Yes Acceptable for unrestricted use. #59 106 Columbia Lane, Lodi Basement Exterior & 0 0.63 0 0.71 0.08 2.9 0 2.98 NA NA Yes Yes Yes Yes The LBP runs across the property in the side yard along Brook Street. Interior Excavation along the LBP was approximately 6 feet bgs. The biased sample collected along the pipeline and from underpin shows the radionuclides activity to be below the 2003 ROD criteria. #60 99 Garibaldi Avenue, Lodi Basement Exterior 0 1.4 0 1.24 0 4.08 0 3.9 NA NA Yes Yes Yes Yes Acceptable for unrestricted use. Commercial and Municipal Properties (Cleanup Criteria - Unrestricted Use) #61 Lodi Municipal Park, Lodi None N/A 0.46 4.22 4.13 4.33 0.74 1.61 0.29 2.24 N/A N/A Unknown N/A Unknown N/A a) The PRAR indicates that soil beneath the LBP is potentially contaminated, and this area was considered inaccessible because the structural integrity of the pipe was compromised. No post-excavation biased sample data in this area was collected to evaluate the residual radiochemical concentrations. b) The PRAR indicates that two large areas containing several trees are in an area of radiological contamination. The surface contamination was removed to a depth of 1 foot from this area and backfilled with clean soil. The hazard assessment found that excess cancer risk is conservatively estimated to be within EPA's target risk of 10-6 to 10-4.

#62 Fire Station No. 2, Lodi 1 1/2 Story Exterior & 0 0.12 0 0 0.15 9.87 3.34 10 <0.4-0.8 NA Yes Yes Yes Yes a) Acceptable for unrestricted use. Interior b) The LBP runs across the property along Brook Street and was outside the excavation limit. #63 Fireman’s Memorial Park, None N/A 0 0 0.29 0 0 2.36 0 2 N/A N/A Yes N/A Yes N/A a) Acceptable for unrestricted use. Lodi b) The LBP runs across the property along Brook Street. Excavation along the LBP was approximately 3 to 6 feet bgs. The PRAR does not indicate any inaccessible soil below the LBP line and therefore, it is assumed that all the contaminated material below the LBP line was removed.

A Page 4 of 8 Table 7-2 Summary of Reviews for Phase I Properties - 1995 to1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Pre-Remediation Post Remediation Resultsa Results DOE Criteria Metb 2003 ROD Criteria Metb Structure Excavation Composite Soil Sample Biased Soil Sample ID Property Address Radon Comment Type Area Max. Ra-226+Th-232 Max. Ra-226+Th-232 Radon Decay Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Max. Ra-226 Above Max. Th-232 Above Max. U-238 Above Soil Activity Radon Soil Activity Radon Above Background Above Background (pCi/L) Product Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) Background (pCi/g) (pCi/g) (pCi/g)c (WL)

Residential#64 John Properties F. Kennedy (Cleanup Municipal Criteria 1 -Story UnrestrictedExterior Use) 0 0.75 0 0.45 0.01 4.28 0 4.23 0.6-1.1 NA Yes Yes Yes Yes a) Acceptable for unrestricted use. Park, Lodi b) The LBP runs across the property along Money Street. Excavation along the LBP was approximately 6 to 8 feet deep below ground surface. The biased sample collected from inaccessible soil below LBP line shows the radionuclides activity to be below the 2003 ROD criteria. NA - Not Available; N/A - Not Applicable a - Post-excavation results reported are levels above background values for Ra-226 of 0.7 pCi/g, Th-232 of 1.0 pCi/g and U-238 of 2.9. b - DOE and ROD cleanup criteria are shown in Table 4-2. c - Bold value exceed the ROD cleanup criteria. Compliance with ROD cleanup criteria not demonstrated. Compliance with the ROD cleanup criteria cannot be evaluated due to radionuclide activity above the cleanup criteria or as noted in the comment section. * = Identifies property addresses that were not originally designated, but where contamination that extended onto adjacent properties was remediated during other cleanup activities. These properties are in addition to the 88 originally designated properties at the Site.

A Page 5 of 8 Table 7-3 Summary of Reviews for 2003 ROD Properties Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Post Remediation Resultsa Inaccessible or Outside Excavation 2003 ROD Criteria Metc Area Soil Sample Resultsa Systematic Soil Sample Biased Soil Sample Radon Above Structure Excavation ID Property Address Backgroundb Comment Type Area Max. Ra-226 + Th- Max. Ra-226 + Th- Max. Ra-226 + Th- Max. U-238 Above (pCi/L) Max. U-238 Above Max. U-238 Above 232 Above 232 Above 232 Above Background Soil Activity Radon Background (pCi/g) Background (pCi/g) Background Background (pCi/g) Background (pCi/g) (pCi/g)d (pCi/g)d State Property (Cleanup Criteria - Restricted Use) #65 Interstate 80, Lodi: (1) east right-of- None N/A 4.161 3.62 0.16 4.75 2.17 34.36 N/A Not N/A a) The accessible area of the property met the unrestricted use way and (2) beneath road west right- Demonstrated cleanup criteria as set forth in the ROD. of-way b) Contaminated soils left in place along the eastbound and westbound sides of the I-80 ROW have been classified as inaccessible due to the proximity of the contamination with respect to I-80. Samples collected along inaccessible portion of the I-80 ROW eastbound meet the cleanup criterion of 15 pCi/g (restrictive use); however, samples collected along the inaccessible portion of the I-80 ROW westbound were above the cleanup criteria.

Commercial Properties (Cleanup Criteria - Unrestricted Use) #65A 150* Essex Street, Lodi Slab on Grade Exterior 2.47 0.17 0 0.23 -- -- NA Yes Yes Acceptable for unrestricted use based on the radon results at the vicinity properties 160 and 174 Essex Street and residual soil activity to be below the 2003 ROD criteria. #66 160, 174 Essex Street, Lodi Slab on Grade Exterior 4.23 1.14 2.57 2.98 5.621 8.1 <0.2-0.6 Yes Yes One boring (04A-005) outside the excavation area completed after excavation had combined activity of 9.74 pCi/g including background. Additional investigative samples were collected at depth in the vicinity of this boring and the average concentration (2.03 pCi/g including background) in the survey unit was below the combined criteria. Wilcoxon Rank Sum (WRS) test showed Elevated Measurement Comparison (EMC) value of 0.89 that is less than 1. Therefore, the total dose from within the Survey Unit is within the release criteria.

#67 72 Sidney Street (a.k.a. 88 Money None N/A 1.07 1.33 2.47 2.88 0.87 1.97 N/A Yes N/A Acceptable for unrestricted use. Street), Lodi #68 170 Gregg Street, Lodi Slab on Grade Exterior 5.58 2.15 3.65 3.29 1.25 2.32 <0.2-0.4 Yes Yes Acceptable for unrestricted use.

#69 80 Industrial Road, Lodi Slab on Grade Exterior 0.541 1.263 5.165 2.348 147.89 121.88 <0.3-0.5 Not Yes a) The accessible area of the property met the unrestricted use Demonstrated cleanup criteria as set forth in the ROD. b) Due to safety and structural stability concerns, contaminated soils were not removed from areas underneath and immediately adjacent to the building, a small area adjacent to Industrial Road, and the pump station located on the property, which were classified as inaccessible.

#70 80 Hancock Street, Lodi Slab on Grade Exterior 6.9 1.88 13.95 2.48 243.13 208.82 <0.2-0.4 Not Yes a) The accessible area of the property met the unrestricted use Demonstrated cleanup criteria as set forth in the ROD. b) Due to safety and structural stability concerns, contaminated soils were not removed from underneath and along the perimeter of the one story building, sewer force main, and utility pole located at the property, which were classified as inaccessible. A total of 22 of the 56 samples collected from the inaccessible soil exceeded the combined Ra-226 and Th-232 criteria of 5 pCi/g (2003 ROD criteria)

#71 100 Hancock Street, Lodi Slab on Grade Exterior 3 2.35 9.62 1.79 107.42 235.48 <0.4-0.5 Not Yes a) The accessible area of the property met the unrestricted use Demonstrated cleanup criteria as set forth in the ROD. b) Due to safety and structural stability concerns, contaminated soils were not removed from areas underneath and immediately adjacent to the building, the Lodi Brook drain line culvert, and the utility pole located on the property. These areas were classified as inaccessible. Contaminated soil from the inaccessible area were excavated down to a depth from 4 to 5 feet bgs and replaced with clean backfill. The vertical extent of remaining contamination is approximately from 5 feet to 10 feet bgs in an isolated spot. A total of 52 of the 71 samples collected from the inaccessible soil the combined Ra-226 and Th-232 criteria of 5 pCi/g (2003 ROD criteria).

#72 23 West Howcroft, Maywood Slab on Grade Exterior 5.99 2.7 1.74 4.3 23.68 152.32 <0.2-0.4 Not Yes a) The accessible area of the property met the unrestricted use Demonstrated cleanup criteria as set forth in the ROD. b) Due to safety and structural stability concerns, contaminated soils were not removed from areas underneath the building along the western side. It is estimated that contamination extends approximately 35 ft from the west wall, underneath the building, to a depth of 7.5 ft below the building floor slab. The area was classified as inaccessible.

#73 85, 87, 99–101 NJ State Route 17, Exterior 0 0.43 0.92 1.43 1.89 2.85 <0.2-0.3 Yes Yes Acceptable for unrestricted use. Slab on Grade Maywood

A Page 6 of 8 Table 7-3 Summary of Reviews for 2003 ROD Properties Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Post Remediation Resultsa Inaccessible or Outside Excavation 2003 ROD Criteria Metc Area Soil Sample Resultsa Systematic Soil Sample Biased Soil Sample Radon Above Structure Excavation ID Property Address Backgroundb Comment Type Area Max. Ra-226 + Th- Max. Ra-226 + Th- Max. Ra-226 + Th- Max. U-238 Above (pCi/L) Max. U-238 Above Max. U-238 Above 232 Above 232 Above 232 Above Background Soil Activity Radon Background (pCi/g) Background (pCi/g) Background Background (pCi/g) Background (pCi/g) (pCi/g)d (pCi/g)d State#74 Property167 NJ (CleanupState Route Criteria 17, Maywood - Restricted SlabUse) on Grade Exterior 2.29 1.98 4.04 3.08 66.06 662.47 <0.4-0.5 Not Yes a) The accessible area of the property met the unrestricted use Demonstrated cleanup criteria as set forth in the ROD. b) Due to safety and structural stability concerns, contaminated soils were not removed from underneath the 30-inch HP gas line and 16- inch sanitary sewer located on the property. These areas were classified as inaccessible. The vertical extent of the remaining contamination is approximately 7.5 feet bgs to 11 feet bgs. A total of 28 of the 43 samples collected from the inaccessible soil exceeded the combined Ra-226 and Th-232 criteria of 5 pCi/g (2003 ROD criteria).

Commercial Property (Cleanup Criteria - Unrestricted Use) - Phase I Property Remediated following MARSSIM Guidance and ROD Criteria #26 96 Parkway, Rochelle Park (north of None N/A 1.87 1.47 1.92 1.46 N/A N/A N/A Yes N/A The property met the unrestricted use criteria for all areas with the railroad track) exception of New Jersey Route 17 North easement of Block 20.02, Lot 1. #88 NJ State Route 17, Maywood and Rochelle Park

#76 200 NJ State Route 17, Maywood #75 137 State Route 17, Maywood Property evaluation not completed because Post-Remedial Action Reports are not available #77 239 NJ State Route 17, Maywood #80 8 Mill Street, Lodi #81 100 West Hunter Avenue, Maywood and Rochelle Park (MISS)

A Page 7 of 8 Table 7-3 Summary of Reviews for 2003 ROD Properties Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Post Remediation Resultsa Inaccessible or Outside Excavation 2003 ROD Criteria Metc Area Soil Sample Resultsa Systematic Soil Sample Biased Soil Sample Radon Above Structure Excavation ID Property Address Backgroundb Comment Type Area Max. Ra-226 + Th- Max. Ra-226 + Th- Max. Ra-226 + Th- Max. U-238 Above (pCi/L) Max. U-238 Above Max. U-238 Above 232 Above 232 Above 232 Above Background Soil Activity Radon Background (pCi/g) Background (pCi/g) Background Background (pCi/g) Background (pCi/g) (pCi/g)d (pCi/g)d State#82 Property100 West (Cleanup Hunter Avenue,Criteria Maywood- Restricted Use) (Stepan Company) #83 149-151 Maywood Avenue, Maywood

#86 111 Essex Street, Maywood #85 Lodi Industrial Railroad, Maywood #78 99 Essex Street, Maywood Property Remediation Ongoing or To be Addressed #79 113 Essex Street, Maywood #87 New York, Susquehanna, & Western Railway #84 50 and 61 West Hunter Avenue, and 205 Maywood Avenue, Maywood

NA - Not Available; N/A - Not Applicable a - Post-excavation results reported are levels above background values for Ra-226 + Th-232 of 1.64 pCi/g and U-238 of 1.33. b - Pre-Remediation radon results. c - ROD cleanup criteria are shown in Table 4-3. d - Bold value exceed the ROD cleanup criteria. Compliance with ROD cleanup criteria not demonstrated. Property evaluation not completed because Post-Remedial Action Reports are not available or remediation is not completed. * = Identifies property addresses that were not originally designated, but where contamination that extended onto adjacent properties was remediated during other cleanup activities. These properties are in addition to the 88 originally designated properties at the Site.

A Page 8 of 8 Table 8-1 Summary of Issues for Phase I Properties - 1984 to 1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Is Protectiveness Affected? (Y/N) ID Property Address Issues Current Future

Residential Properties (Cleanup Criteria - Unrestricted Use) #5 468 Davison Street, Maywood a) Pre-construction interior gamma exposure dose rate and Unknown - No interior data available Yes - Failure to evaluate/investigate radon readings were above the ROD Criteria. However, post- to conclude that the source of high the source of high radon reading, remediation radiological investigations and radon testing were radon results and gamma exposure gamma exposure and downhole not performed. dose rate were from exterior soil. It is gamma counts may result in future b) Pre-remediation Radiological Survey Report indicates uncertain if contaminated material risk to the resident. elevated gamma exposure rates (16 to 31 uR/hr) in the exceeding the 2003 ROD criteria backyard over the asphalt area; however, no investigation was exists below the paved area and completed in this area to identify the source of elevated around boring MJC43. gamma readings. In addition, this report also indicate high gamma count of 82,000 cpm at approximately 6 feet bgs in boring MJC43. Based on this gamma reading, suspect soil contamination above the ROD criteria. However, the PRAR shows excavation depth of 1 foot in this area. #21 58 Trudy Drive, Lodi Two post-excavation samples (sample numbers 12 and 13) No - Clean fill material provides Yes - Failure to evaluate the soil exceeded the 2003 ROD Criteria. An evaluation of data points sufficient protectiveness for the exceedance data may result in for small areas of elevated activity cannot be performed for underlying contaminated soil. inadequate understanding of the the hot spot area because sample number 13 was collected at future risk to the residents and/or the corner of excavation, and the hot spot area is not bounded workers posed by the residual by clean samples. contamination.

Commercial Property (Cleanup Criteria - Unrestricted Use)

#26 96 Park Way, Rochelle Park The site does not meet the unrestricted use criteria. Several No - Clean fill material provides Yes - Failure to remediate the site to (South of railroad track) post excavation sample results and gamma exposure dose sufficient protectiveness for the unrestricted use criteria may result in rates were above the 2003 ROD cleanup criteria. underlying contaminated soil. future risk to the construction worker or any future use of the property

A Page 1 of 3 Table 8-2 Summary of Issues for Phase I Properties - 1995 to 1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Is Protectiveness Affected? (Y/N) ID Property Address Issues Current Future

Residential Properties (Cleanup Criteria - Unrestricted Use) #30 112 Avenue E, Lodi Radiological investigations (1992 RI) showed soil surface No - The pre-remediation exterior Yes - Failure to investigate/remediate sample results at R416 and south of R416 along the north gamma exposure rate (maximum 19 the north side of the residence may side of the residence above the 2003 ROD criteria. However, uR/hr including background) in the result in future risk to the home the PRAR showed no excavation was performed in this area. area not remediated was below the owner. 40 CFR 192.12 standard of 20 uR/hr above background. #50A 9 Hancock Street, Lodi a) The Radiological Characterization Report (RCR) indicates Unknown - It is uncertain if Yes - Failure to investigate and if high gamma count of 28,000 to 32,000 counts per minute from contaminated material exceeding the necessary remediate the property 3.5 to 4 feet bgs in boring 560R. Only surface soil samples up 2003 ROD criteria exists below the may results in future risk to the to 1 foot bgs were collected from this location. The PRAR basement slab and in the north side resident. shows no excavation around boring 560R (north side of the of the residence. house). Based on this gamma reading, suspect soil contamination to be above the ROD criteria. b) The RCR indicates contamination below basement slab based on exterior borings/samples. The PRAR states that contamination was not suspected beneath the basement because the basement is deeper than the depth of excavation (4 feet). However, no interior investigation was completed to rule out interior contamination.

Commercial and Municipal Properties (Cleanup Criteria - Unrestricted Use) #61 Lodi Municipal Park, Lodi Inaccessible soil under the LBP is potentially contaminated No - Clean fill material provides Yes - Failure to implement the LUCIP and no post-excavation sample data was collected from the sufficient protectiveness for the may result in inadequate land use contaminated area to evaluate the residual radiochemical underlying contaminated soil. controls for inaccessible soil. concentrations. USACE has drafted a LUCIP which is currently under revision.

A Page 2 of 3 Table 8-3 Summary of Issues for 2003 ROD Properties Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Is Protectiveness Affected? (Y/N) ID Property Address Issues Current Future

State Property (Cleanup Criteria - Restricted Use) #65 Interstate 80, Lodi: (1) east right- Contaminated soils left in place underneath I-80, along the No. Existing land use controls Yes - Failure to implement the LUCIP of-way and (2) beneath road west eastbound and westbound sides of the I-80 ROW have been provide sufficient protectiveness. may result in inadequate land use right-of-way classified as inaccessible and do not meet the "Restricted controls for inaccessible soil. Use" cleanup criteria. USACE has drafted a LUCIP which is currently under revision. A Memorandum of Understanding (MOU) dated June 9, 2000 between the U.S. Army Corps of Engineers, New York District (USACE) and the State of New Jersey Department of Transportation (NJDOT) is in effect for future work to be performed at highway projects involving removal of soil potentially contaminated with radioactive substances. Commercial Properties (Cleanup Criteria - Unrestricted Use) #69 80 Industrial Road, Lodi Contaminated soil left in place underneath the building and/or No. Existing land use controls Yes - Failure to implement the LUCIP utility corridor have been classified as inaccessible and do not provide sufficient protectiveness. may result in inadequate land use #70 80 Hancock Street, Lodi meet the "Unrestricted Use" cleanup criteria.These properties controls for inaccessible soil. are considered as "in remedial action" and inaccessible soil #72 23 West Howcroft, Maywood above the Site cleanup criteria will be addressed at such time in future as the property owners make the soil accessible. #71 100 Hancock Street, Lodi USACE has drafted a LUCIP which is currently under revision. #74 167 NJ State Route 17, Maywood

A Page 3 of 3 Table 9-1 Recommendations and Follow Up Actions for Phase I Properties - 1984 to 1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Lead Oversight ID Property Address Issues Recommendation/Follow Up Action Agency Agency

Residential properties (Cleanup Criteria - Unrestricted Use) #5 468 Davison Street, Maywood a) Pre-construction interior gamma exposure dose rate and a) Perform radon testing at the property. If the USACE EPA radon readings were above the ROD Criteria. However, post- 2003 ROD criteria for radon concentrations are remediation radiological investigations and radon testing were not met, perform investigations to find the not performed. source for elevated radon levels. If necessary, b) Pre-remediation Radiological Survey Report indicates complete property remediation and restoration. elevated gamma exposure rates (16 to 31 uR/hr) in the b) Perform data evaluation/investigations of the backyard over the asphalt area; however, no investigation was area showing high gamma exposure rate and completed in this area to identify the source of elevated downhole gamma counts at the property in gamma readings. In addition, this report also indicate high accordance with MARSSIM Guidance. If the gamma count of 82,000 cpm at approximately 6 feet bgs in "unrestricted use" criteria for the property is not boring MJC43. Based on this gamma reading, suspect soil met, complete property remediation and contamination above the ROD criteria. However, the PRAR restoration. shows excavation depth of 1 foot in this area. c) Include property in future CERCLA decision document.

#21 58 Trudy Drive, Lodi Two post-excavation samples (sample numbers 12 and 13) a) Perform data evaluation/investigations of the USACE EPA exceeded the 2003 ROD Criteria. An evaluation of data points area showing radionuclide activity above the for small areas of elevated activity cannot be performed for soil cleanup criteria in accordance with the hot spot area because sample number 13 was collected at MARSSIM Guidance. If the "unrestricted use" the corner of excavation, and the hot spot area is not bounded criteria for the property is not met, complete by clean samples. property remediation/restoration. b) Include property in future CERCLA decision document.

Commercial property (Cleanup Criteria - Unrestricted Use) #26 96 Park Way, Rochelle Park The site does not meet the unrestricted use criteria. Several a) Perform data evaluation/investigations and USACE EPA (South of railroad track) post excavation sample results and gamma exposure dose complete excavation/restoration of the property rates were above the 2003 ROD cleanup criteria. to meet the 2003 ROD unrestricted use criteria. b) Include property in future CERCLA decision document.

A Page 1 of 3 Table 9-2 Recommendations and Follow Up Actions for Phase I Properties - 1995 to 1999 Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Lead Oversight ID Property Address Issues Recommendation/Follow Up Action Agency Agency

Residential properties (Cleanup Criteria - Unrestricted Use) #30 112 Avenue E, Lodi Radiological investigations (1992 RI) showed soil surface a) Perform investigations of area showing USACE EPA sample results at R416 and south of R416 along the north radionuclide activity above the soil cleanup criteria side of the house above the 2003 ROD criteria. However, the in accordance with MARSSIM Guidance. If the PRAR showed no excavation was performed in this area. "unrestricted use" criteria for the property is not met, complete property remediation and restoration. b) Include property in future CERCLA decision document.

#50A 9 Hancock Street, Lodi a) The Radiological Characterization Report (RCR) indicates a) Perform data evaluation and investigations of USACE EPA high gamma count of 28,000 to 32,000 counts per minute interior and exterior areas not remediated during from 3.5 to 4 feet bgs in boring 560R. Only surface soil Phase I. Conduct property remediation for samples up to 1 foot bgs were collected from this location. contaminated soil above the 2003 ROD criteria and The PRAR shows no excavation around boring 560R (north complete site restoration activities. side of the residence). Based on this gamma reading, suspect b) Include property in future CERCLA decision soil contamination to be above the ROD criteria. document. b) The RCR indicates contamination below basement slab based on exterior borings/samples. The PRAR states that contamination was not suspected to beneath the basement because the basement is deeper than the depth of excavation (4 feet). However, no interior investigation was completed to rule out interior contamination.

Commercial and Municipal Properties (Cleanup Criteria - Unrestricted Use) #61 Lodi Municipal Park, Lodi Inaccessible soil under the LBP is potentially contaminated a) Implement LUCIP. USACE EPA and no post-excavation sample data was collected from the b) Include property in future CERCLA decision contaminated area to evaluate the residual radiochemical document. concentrations. USACE has drafted a LUCIP which is currently under review.

LUCIP - Land Use Implementation Control Plan

A Page 2 of 3 Table 9-3 Recommendations and Follow Up Actions for 2003 ROD Properties Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Lead Oversight ID Property Address Issues Recommendation/Follow Up Action Agency Agency State Property (Cleanup Criteria - Restricted Use) #65 Interstate 80, Lodi: (1) east right- Contaminated soils left in place underneath I-80, along the Implement LUCIP and coordinate with USACE EPA of-way and (2) beneath road west eastbound and westbound sides of the I-80 ROW have been NJDOT for future work to be performed at right-of-way classified as inaccessible and do not meet the "Restricted the interstate. Use" cleanup criteria. USACE has drafted a LUCIP which is currently under review. A Memorandum of Understanding (MOU) dated June 9, 2000 between the U.S. Army Corps of Engineers, New York District (USACE) and the State of New Jersey Department of Transportation (NJDOT) is in effect for future work to be performed at three highway projects involving removal of soil potentially contaminated with radioactive substances. Commercial Properties (Cleanup Criteria - Unrestricted Use) #69 80 Industrial Road, Lodi Contaminated soil left in place underneath the building and/or Implement LUCIP and continue performing USACE EPA utility corridor have been classified as inaccessible and do not O&M, including radon testing and site #70 80 Hancock Street, Lodi meet the "Unrestricted Use" cleanup criteria.These properties inspections, at the properties. Complete are considered as "in remedial action" and inaccessible soil removal action of the inaccessible soil at #72 23 West Howcroft, Maywood above the Site cleanup criteria will be addressed at such time such time in future as the property owners in future as the property owners make the soil accessible. make the soil accessible. #71 100 Hancock Street, Lodi USACE has drafted a LUCIP which is currently under review.

#74 167 NJ State Route 17, Maywood

LUCIP - Land Use Implementation Control Plan

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E E S

R SA

O A

IC

O

V L

P 1

K E ST

7

A

N

V

U

F

D E

N A

E

A L I

P R

R D T

H W

U R M O

A

D L M O I Y A A

V E K

E H

A L V

A I E V A

E W V

E E

E L V M

A

K S O T O R B H E R LE G L N ROCHELLE E P O SEL X

R A A L E V M I E AV V E U

D Y ED WO G E P

L OD A PARK C

E

W A VE S E MAYWOOD IN S L T N P IG E N R O P T L S W E EST L C C

E G

New York, O

L

PAR M H F

K WA A Y A R

G T

NJ State Route 17

N W

O I A

Sus E LI C V A H V

C A E E O ST S que NT P T R A

A M A L

P h A

N N

K AR a R R nna O

A M L P V A

MISS , E IN A

W E

& J ACE

A

Wester E AV Y

G E

E

R S

A T WESTERLY BROOK n Railway VE

I - M 8

A 0

I N 100 West Hunter Avenue

S GR PL T OV N R O E R E AV Y C Stepan Company B O E E NC T O RD DR BEC WE ST H K E R A UN TE VE R

T M A S G MA N O ND L E DIS I ON A ST A E A V V E W E

LE X ET IN EA S GT RE T O T N A S VE

H EA S T HIG N C E E N TR A W L AV E H U J N E TE R R

S E

Y

ET S E R T ESS A T H ST S ANS T EN E IE O X R ST E C S ND SAL H TR O A AV R E LA R R D EE P L T O MID T L S L

U IS

A E M S U O T

O T L S R Y E G E V

UNT WO HER E L

1 C OD N 7 A LU V C I LLE R B E T E S C AV O H E

E V A S A

W T WIL VE N SON D O R T S IN T L C

E T V S A D D H R R A E M A L M W A E D L K E P O V L O A R B

E

L

G O H W D N

I O E G W

N I G I R C

V R V E R

L R U E O

E F A L E F E T

C V B

I N R R

R L D

N A D W

A

V L A D E L E L M E A R C Y E T S T R P W L D H D I R TE O R AK D D

R d

B a

R

A

A o

N

N r

C

N l

A

E

T

LODI T E R E Rai

D ES

T

C i

A S

E

T

L

R T S R

O O

L N E N

E E X

N

G S

E Lod

TR K R G E O E O & T L N N YBR A ck

E M

V S W H

A I

A

L -

D

L 8

Y

E

L

0 J Y

N E ackensa TR R U D H Y S D

E R L IV Y E O R

A E S V L E

N T E U I T E E

E A

R T

E

F T Y

R T S O

L E

A

N

D A R AV K

E C

N O P O U C L E N A P U E H E

A T

R L E

A

V C E T 1 N U E 7 A VEN D U E C

T E E R T S Legend: AVEN

U K E C B O C C O N IN L A A D U V H U Properties Addressed in Record of Decision E M N S B U T IA E R L IA N L T S A

G MISS A R IB A L R D O I A D A Stepan Company V E Commercial/Government LODI BROOK T S C G O G L E U R M G L B L K IA Phase I Properties Addressed by Prior Action O R O O B S R IN T B S G O A N RI R B D A Residential LDI

LN D A N V R E E R Commercial/Government Y T S S I K D Y E O T E N L N N O E D & M Y

K C D A N S L R N E K C

A

H 0 250 500 1,000

C

T I feet S T

R O Y T IC V Source: Modified from FUSRAP website (www.fusrapmaywood.com, 3/4/2009) Figure 1-1 Site Map Maywood Chemical Co. Superfund Site Bergen County, New Jersey New York Connecticut Maywood Site

New York Pennsylvania

New Jersey

Maryland

Delaware

20 10 0 20 miles

Figure 3-1 Site Location Map Maywood Chemical Co. Superfund Site Bergen County, New Jersey Legend: Borough of Township of Land Use Type Rochelle Maywood Park Commercial Industrial Residential

Other

Borough of Lodi

0 1,500 3,000 feet

Figure 3-2 Land Use Map Maywood Chemical Co. Superfund Site Bergen County, New Jersey NEW YORK, SUSQUEHANNA, & WESTERN RAILROAD

MISS STEPAN COMPANY BALLOD PROPERTY

SEARS NEW JERSEY STATE ROUTE 17 DeSAUSSURE PROPERTY

Legend: Retention Pond Retention Pond Inferred from Subsurface Data Burial Pit

0 150 300 feet

Source: Figure adapted from Remedial Invetigation Report for the Maywood Site, New Jersey , December 1992 Figure 3-3 Buildings/Structures, Burial Pits, and Retention Pond Locations Maywood Chemical Co. Superfund Site Bergen County, New Jersey

Y O R

V B

A Y

A

E M

V A

NC D

O T

L R R

S

N E

T

L

AVE M F L

L

I

A O H P AVE R C IA W A E L O M V A O H O N H

T X G

O A

T T

M

S N MA

E Y E

M L WO E

A OD Property Addresses:

H L T

L

A P TR P L E

AVE T S

M V

L A S E

H R E L

I R EX

W E AV

TE A S

O M 467 P

A E ES

M D

T 461 UN 454 Davison Street, Maywood A

S

R H

N 4 459 T

O 468 S

S 6

0 E ST

I

AV 4 6 N 459 Davison Street, Maywood D O 4 T E WE S V EST 454 A T W 460 Davison Street, Maywood C 7 E 1 P E S T

459 O U

R L L O 464 Davison Street, Maywood

P

R

P A R

E E

I R

E T

V

V T

L A U

A

P T

D N

S

N E

E 468 Davison Street, Maywood

O

E C Y

V T

C E

A S

N S

E

E

E L R R

L C E

C J

W P E

A 459 Latham Street, Maywood

L A EW

M N

E

V

A

461 Latham Street, Maywood

K

O

O R

B 467 Latham Street, Maywood 10 Grove Avenue, Rochelle Park T S BR E OO W K AVE 22 Grove Avenue, Rochelle Park

AVE Stepan Company

L 26 Grove Avenue, Rochelle Park L E S W 0 E RO 8 G I- 30 Grove Avenue, Rochelle Park R 17 E E H UT RO 34 Grove Avenue, Rochelle Park ATE ST SEY 38 Grove Avenue, Rochelle Park JER NEW 42 Grove Avenue, Rochelle Park NEW JERSE 86 Parkway, Rochelle Park Y STA TE MISS EARL T RO P S U C 90 Parkway, Rochelle Park

TE T

S 1 I 7 ET

D T E L S R

O 59 Avenue C, Lodi S

U ST

N

I LINC

R OLN D

A N YO

L AND 121 Avenue F, Lodi

A M L

N A L

O

E D P

MID C R S

V IV H L N A E

I N A L B 123 Avenue F, Lodi L D RA Y NC Ballod A L

N

L C P T 58 Trudy Drive, Lodi

LOREL

L EI E

Property ET

V P E

A N T E T RE E

S 4 E O R 59 Trudy Drive, Lodi

V

A E D 2 T T T S S

R N 96 Park Way 3

A RD D

O R 8 E AV

EE L Y E U E

F 3 O ALL R D

H NG V 61 Trudy Drive, Lodi E 4

3 OV TR

A NN G

0 HI S

A GR VE 6

H 2 61

E 6 EX 4 U 64 Trudy Drive, Lodi

T 2 R A

S Q

S 2

U KE ESS S LO 3

NUT E N H

T E V 3 Hancock Street, Lodi

T G A

S E V A E 59 N

E BEC

E A V E C R

IV O

H T E A DR C 0 S R 6 R

C C 6 0 5 K D V D 8 96 Parkway, Rochelle Park - Ballod Property 1 A 9 G AW LL 123 8 9 ON REENL E RRA Y E T Y 121 S T DIS T F C D R PARK E U E (south of railroad) WAY MA VE R R E

N L E T T

E DA A

N A L D R L R L

O I E

C N F

T U E

M GT L GR A S

I E

L R U

L IN

I D

N N

E

W

G E

D

I V

R E

ST ST LEX A

E E

U

L OAK D

B E W E T A E I N ST H N U

ANN PL W E ACE E T

V T VEN Y A E T A E D E R V A E K WA L U

A N

E

R AR W E

I V

L

T V

P A

R

N E

L SE

V

I

E O

R C T R S

N

E

E C

R

S V ROCH T A ELLE A E VENUE N S H A E T U H N N

AIN STREET E M U N

I 5 V

V

G L 9 A N A O C

S

L I

W

0 250 500 1,000 feet I-80

Source: Modified from FUSRAP website (www.fusrapmaywood.com, 3/4/2009).

Legend: Residential Property Commercial Property Figure 4-1 Phase I Properties Remediated During 1984-1985 Maywood Chemical Co. Superfund Site Bergen County, New Jersey B GOL R E R 200 L T D O P F V O S A K R D V E D E R A L A G AVE O A L Property Addresses: A E I C R N N I O L T C O N E

H N E V

IC L G C A P A

W M

T N T

E O R R S

V Y A B A 90 Avenue C, Lodi H A E S T

E IN 79 Avenue B, Lodi A M O

R

T 108 Avenue E, Lodi

S

D

R A

W 112 Avenue E, Lodi

L

P E 113 Avenue E, Lodi

V

D A R

JA E R N

T A O

E T

G N H N

E I

R U C L H R C 7 Branca Court, Lodi

S

T O

T

S

E EV

L 16 Long Valley Road, Lodi

R

C

D

N

A V

VE 18 Long Valley Road, Lodi

T

S 20 Long Valley Road, Lodi

S

I

U

O T L S H 22 Long Valley Road, Lodi C T E S E

A B

E T

S L

E P

I 24 Long Valley Road, Lodi

L

L SA

O

R

MME K

A O

E H O

R 26 Long Valley Road, Lodi

V B

A Y A

M 11 Redstone Lane, Lodi

D R A

T F 34 Long Valley Road, Lodi O R C IA W L O O H 5 Shady Lane, Lodi N G A T M MAY E WOOD E 7 Shady Lane, Lodi L TR E A P V VE T S

A S

R E

E

V 136 West Central Avenue, Maywood

R EX

A

A

O TE

M P

A E ESS

M UN D

A R 142* West Central Avenue, Maywood D ST H R E N T O W S 200 Brookdale Street, Maywood IN B O 17 R TE OU 60 Trudy Drive, Lodi L R A E

R T

T A

P N T

S 62 Trudy Drive, Lodi N E O Y

C SE T ES

L R

C E C J

E EW 4 Hancock Street, Lodi 1 N 14236 5 Hancock Street, Lodi 46* Long Valley Road, Lodi

T S 6 Hancock Street, Lodi E

W T

S 7 Hancock Street, Lodi W 0 RO 8 9* Hancock Street, Lodi 17 I- UTE Stepan Company RO 8 Hancock Street, Lodi ATE ST SEY 10 Hancock Street, Lodi JER

NEW 2 Branca Court, Lodi N

MISS L 4 Branca Court, Lodi E ARL

P C G

T G

E ET

R

E 28* Long Valley Road, Lodi

G R

T S

7

D 6 Branca Court, Lodi

N YOL A

A ND 1 L A

D

1 A

P D T E

MI S L A H M 11 Branca Court, Lodi N A O B L D R RA Y 1 2 N CA L 1 8 2 6 N 4

4 C 1 14 Long Valley Road, Lodi 2 2 T R

5 LO 7

REL R

EI 0 4 L ET 9 7 Ballod 6 M

8 1 E odi T 2 1

N I 1 E R E 2 E 6 R

2 u

O D 17 Redstone Lane, Lodi

V T

1 O

T n 0 L

T S A S L

E RD D IA 8

i

E 1

Property E L LEY E c R

V ON AL R 6 T

H V P

G i S & 4

O

TR 4 a p U 19* Redstone Lane, Lodi

G

HI S a D 3

r

GR VE IN

X k l K E 9 C

7 5 R A S 6 A

E 2 S 106 Columbia Lane, Lodi (Remediated in 2000) K ES

LO 6 N

N 0 KE

G 6 C

E A BEC E H

4 H V A IV 99 Garibaldi Avenue, Lodi A R N R D R C D O G AW VALL C ON REENL EY K D T Y Lodi Municipal Park, Lodi DIS F C D PARK WA E U S Y MA VE R R TR

N L E T E

E DA A E

N A L D R T L R Fire Station No. 2, Lodi I LE 1

C N F 1

T U E 3

GTO L GR S N

E L

IN R U

D

N N 1

E 1 Fireman’s Memorial Park, Lodi

G E LODI BROOK

D

I AK D V 2 R

E ST ST LEX A 1

E E

U 08

L O

B E W E IT A E John F. Kennedy Municipal Park, Lodi H N U

ST N H

ANN PL W E A

ACE E T

V T VEN N Y A E C T A O D C E K E R V IA A E B K WA E U M V Note:

S U

T L A

AR W

R T

E

I VEN O

S

L E

V

P

L A C

R E

R E

E T

S O V

I

O

T R

R 9

C

T 0 DI I V * Additional Phase I Property S L 7 A 9 R N RIB

E

E C 2

R

S V T A GA E B N S 106 # D H E A E Y T U D H U e k

N N N E

AIN STREET E N M U N E r

I V 9 V N

V T

G L A S 9 N

A A a E y Legend: C K O

S d P d

L I

K k W A n

O 's

WESTERLY BROOK WESTERLY r

ehouO as R

ir B n nne Residential Property E a e U F m l Pa VEN A e ir ipa F Additional Residential Property SADDLE RIVER0

-8 E unic

I N ohn F. K L V T

A J

S

IA M Y

B E

M N O Commercial/Municipal Property

U I L D M O L C A IB R A G T

T S S Source: Modified from FUSRAP website (www.fusrapmaywood.com, 3/4/2009) Figure 4-2 Phase I Properties Remediated During 1995-1999 0 250 500 1,000 feet Maywood Chemical Co. Superfund Site Bergen County, New Jersey

S H N E

V E

C L

I G C A L P

A A

W

D N M

T T K

E O

R R S O

V Y B A A O

A E H R B

E IN A M O H

R a

T

S ckensa

D

R

A W 1 Property Addresses:

L 1

P E 1 V

D A ck

R

JA E R N E T A O

E T

G N H N

E I s

R U C L C & S H R s

T O e 100 West Hunter Avenue, Maywood and

T S

Lod x

E

EV S

L

R

C

D

t Rochelle Park (MISS) N

A r V i eet Rai AVE 100 West Hunter Avenue, Maywood

l

T

S r

S

I o (Stepan Company) U

O T L S a H d C T E 23 West Howcroft, Maywood S E

A B

E T

S L

E P I L

E

L SA 149-151 Maywood Avenue, Maywood

O M

R

M K

A O

E H O R

V B

A Y

A C 50 and 61 West Hunter Avenue, and M IT Y O F2 H05 Maywood Avenue, Maywood D R A C T F KEN O R 137 State Route 17, Maywood C S A I nu e W AC L O O H e K N G

v 167 NJ State Route 17, Maywood A e T M MAY t u A WOOD EE

5 n L TR E s t P 200 NJ State Route 17, Maywood AVE S V e 0 A e s nue

R t EST X

E f v 2

V E e e R E A

W A S O T

v M P A

o

ood 239 NJ State Route 17, Maywood

A W E ES d

M UN D r

A A 1 r es t R a 6 e w 0 r c t D ST H R y 5 W e o 85, 87, 99–101 NJ State Route 17, Maywood N

n t T w O

S WE a S

E u n R 3 IN W u o B

M O H 2 99 Essex Street, Maywood 7 R

H H E 1

T T OU S L R A E Lodi Industrial Railroad, Maywood

R T

T L A

P N T

S N E

e O Y

C SE

T ES 111 Essex Street, Maywood u

L R

C E

C J E 1 n W 7 NE 0 e 113 Essex Street, Maywood 1 1 v

Western Railway - T A 5

& nu e

, New York, Susquehanna, & Western Railway

r R 8 e 7

e

v 1

t NJ State Route 17, Maywood and T 7

S T nna A n E 3

W 15 1 a R

7 1 u

T h S Rochelle Park 7 1 H

6

49 - T ood

1 8 Mill Street, Lodi 7 que 1 W 0

R O

9 8 w

1 R - es t 7 I E 1 3

y V t TE Interstate 8A 0, Lodi - east right-of-way and A

T I 2

a U e

W B

O sex Sus R M

e U

R E T s L M

A r O T C

Stepan Company beneath road west right-of-way S t E 7 00

Y t t

E S g S S 0 1 1

R e e 9

E 0 J g

ee t 0 150* Essex Street, Lodi e

W e 9 r T

E 7 e r N 2 r t r Essex t 1 t

R

MI S N S L 17 4 160, 174 Essex Street, Lodi S G S EARL

13 P

d C G

T G 1

60 /

E 170 Gregg Street, Lodi

New York, ET

R

1 G E R t

ssex

T

S e boun 80 Industrial Road, Lodi

E ssex e

D

N YOL AN NJ State Route 17 r D

LA A E

t A

East P D T 8E 0 Hancock Street, Lodi D

MI S L A H O M S 0 N A

ROW BR L D R

A Y T

8 NC L C 50

- A D

I N R

100 Hancock Street, LA odi

1 bound C H

C

T L R

OREL R O

EI T

S

ET est E T

R N I

E

E R ER D 72 Sidney Street (a.k.a. 88 Money Street), O

V T

T L O

ST W S

A A L

RD D I

E T

EE ROW L Y E R

LE R

V O AL R T

O

H N V

G S &

O 80 Lodi H

TR U

- k S

G

HI S I D

GR VE IN X t K

E c T

R A C e C SA

o

0 N

KE ESS E

L e O K C c

N 0

G r C

k

A Note:

E A

t D I BE E H 1 n V A IV t A R c R D R a D D S VA e G AW L L o ON REENL EY * Additional Property in Record of Decison H 0 e

T Y c

DIS r C 8

F H l t PAR E A n K WAY MA VE RUD R E T N

ND L C a E A a

A O S i

N A L D R C t IL R L K 6

E F r

C N d

H 4 l

T e U E t

S GTO L GR N

E a

0 L D R

IN U S e

N D T

8

E R

X r o

8

G E

D

I VEN E

AK t R T Mi l

ST E ST LE A E

E E

U R

L O

B T E W E S IT A E N U U

ST H N ndu s 0 250 500 1,000

ANN PL W E I ACE E T O

V T VEN Y A E T A R D feet E E R V IA A E B K WA E U M .

U V

L A S

AR W T .

E

I 1 inch = 600 feet

VEN O

S L

V

P

L A C R

R E

E U

S O V

I

O

T R

R

C

T DI I S V AL R N RIB

E

E C R

S V T A E B GA N S D H E A E Y T U H U D

EET N N N E Legend:

AIN STR E N U

M N E

I V

V N

V T

G L A

N S A A E C K O

WESTERLY BROOK WESTERLY S

L

I Property in Record of Decision - Remediated

W A K

O

O

R B E LODI BROOK U Additional Property in Record of Decision VEN

SADDLE RIVER A T

S Property in Record of Decision - Active Remediation

D

Y

O 0 B

-8 E

I N

L V T

A

S

IA Y Property in Record of Decision - Scheduled for Remediation

y

t B E

M N CT O E

U I

e T L D M A O L G 2 C A e T IB S r Property in Record of Decision - Inaccessible for Remediation A R 7

dn e E

A t

G i

T S T S S S T

S Y

E E N P Source: Modified from FUSRAP website (www.fusrapmaywood.com, 3/4/2009) Figure 4-3 Properties in Record of Decision Maywood Chemical Co. Superfund Site Bergen County, New Jersey