U8KHSBS TO MJOCT't OOWOim 0*DIAMOND SHAMtOCX CHEMICALS COMPACT

SO USTOt AVOIUBPBASIBIUTT STUDY

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INTIODUCTIOM

Thii document prcttncs «n item-by-ittm response to New Jersey Department ofenvironment*!. Protection's (NJDCP) cements on Dianond Shamrock ChesucalCompany's SO Lister Avenue Feasibility Study. Each of the coawents containedin NJDCP's April 23, 1986 transaittal have been addressed sequentially as theyappeared in that cooBunication.

The cosBMnts, along with their numerical designation, were transcribed to thisdocument and are followed by individual responses.

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Comment 1-2: It does not appear that the extent r f ground water contaminatonh» been defined, as evidenced in Table 2.2-6 and Figure 2.1-14showing contamination of the outermost wells.

Response! Tables 1-2-1 through 1-2-3 present the results of ground wateranalyses for the off-site wells and the nearest upgradient on-site monitoring well. Each table has been divided into threesections that show organic compounds present in both wells, onlyon-site wells, and only off-site wells. The chemicals found inthe off-site wells do not correspond either in species orconcentration to those found on site. Neither do these off-sitechemicals correspond to the feed stock or finished productchemicals used or produced at the facility. Host significantly,aniline, which was never detected in any on-site well is presentat very high concentrations in HU-10A. If 80 Lister Avenue wasindeed the source of these other chemicals, they would have beendetected in much higher concentrations in the upgradient, on-site veils. The data strongly indicate off-site sources arepresent in the highly industrialised vicinity of toe site.

TABLE 1-2-1COMPOUNDS PUSENT IN SHALLOW OPF-SITB MONITOR UK WELL 10A

AND NEAREST ON-SITB MONITORING WELL 6A

MONITORING WELL AND SAMPLING DATE

BenteneChlorobenzeneNethyltne Chloride1,2-Dichlorobeniene1,4-Dichlorobenxene

Total XylenetPluoranthene2-ChloronaphthaleaePhcnanthrenePyrene4,4'-DOT*,*'-DDe4,4'-ODD

AcetoneAniline

MW-6A10-30-84

U|/l

10*7*4*3*6*

139*5*•*17*330143)

NT) (10)NO (2)

MW-10A12-14-84

ug/l

2001,600640260*810

NO (10)NO (80)ND (80)NO (80)ID (80)NO (0.1)ND (0.1)NO (0.1)

500*9,300

MW-lOA1-8-8SU|/l

160370170

NO (200)(«)ND (200)

ND (10)NO (200)NO (200)ND (200)ND (200)NO (0.1)ND (0.1)ND (0.1)

ND (100)18,000

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*teported value it ••tinetedt the compound ncecs identificationcriteria but the result if leit than the detection li«it butgreater than aero.

(a)CoHpouad not detected at the indicated detection lime.

TABL8 1-2-2COMPOUNDS PRESENT IN INTERMEDIATE OFF-SITE MONITORING HELL 108

AND NEAREST OH-SITE MONITORING HELL 78

MONITORING WELL AND SAMPLING DATE

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247201205

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2

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ND(IOO)m><2.0)

ND(20)ND<20)H0(20)

MD(O.OS)ND(O.OS)

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ND(30)(a)3505J5*6*18

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MIX 20)ND(20)ND(20)

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ND(0.05)HD(O.OS)

10812-14-84

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4,700ND(40)

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NIK 40)HD(40)

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2.05.2

HD(l.OOO)¥0(2.0)N0(2.0)ND(2.0)

»:12K0(2.0)MD(O.S)MD(0.5)

Bcnxen*ChlorobcnzciMMethylene Chloride1.2-Dichlorobcnzen*1.3-Dichlorobenz*n«1.4-Dichlorotxnzcn*Bi*(2-ethylhezrl)phch«Lat«4,4'-DDT4,4'-ODD«-BHC2,*,5-T2,4-D

Acetone2,4-DichlorophcaolBenzole AcidDichloroprop

2-ChlorOphcnol1,2,4-TrichlorobcnzeneAnilio*o-BHC8-8MC

Reported value is eitiMted! the compound *eetf identification criteria but the resulti* left than th« detection liait but greater than zero.

"Detected and quant i tared by CC, but detected below CC/MS detection level. CC/MSconfirmation umi not atteaipted. Dual coluan CC confirmation hat been performed.

(a)Compound not detected at the indicated detiction limit.

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TABU 1-2-3CONFOUND PRESENT in DEEP OCR-SITE HONITORINC WELL IOD

AMD DEAREST ON-SITB NONITMIHC WELL 70

MONITORING WELL AND SAMPLING DATE7D 70 IOD IOD

7-lS-BS 8-5-85 6-5-85 7-15-85UK/I UB/I

ChlorobensenaHethjrlene ChlorideAcetone2,4-DDalapon

Trans-l,2-Dichlorethene1,2,4-Trichlorobenxene1 ,2-Dichloro benzene1 , 3-Dichlorobenxene1 ,4-DichlorobenzeneBii(2-ethyLhexvl )phthalate4,*'-DDDB-BSC•-BHC<-BHC2,4,5-T

TolueneDicaefca

Reported value it ettiaiated;the remit it lets than the

Detected and quantitated by

1,100 920 4 ND(S.OKa)950 360 40 75190 ND ND(10) 127.5 2.39 2 ND(l.O)2.16 ND(2.0) 8 ND(2.0)

22* IS* ND(S.O) ND(5.0)3 2* ND(20) ND(20)3* 13* ND(20) ND(20)3* 2 ND(20) ND(20)IS 17 ND(20) ND(20)2 NIK 20) ND{ 20) ND(20>

0.81** 0."!! KKO.l) NDCO.l)0.46 0.46 VD(O.OS) ND(O.OS)0.34** ».S1*I ND<0.05) ND(O.OS)0.65 0.56 «)(0.05) ND(O.OS)2.5 1.0 ND(l.O) ND(l.O)

ND(SO) ND(30) 1* ND(S.O)•0(1.0) ND(l.O) 1 ND(l.O)

the compound meet* identification criteria butdetection limit but greater than zero.

CC, but detected below CC/MS detection level.CC/MS confirmation wae not attempted. Dual column CC confirmation has bceaperformed.

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(a}Co*p«und not detected at the indicated detection limt.

Cement 1-3) Disposal of drums not containing or contaminated with TOO oasit* is unacceptable to NJDCP.

Response: Drums proven not to contain dioxin at levels of less thaa !.•ppb will be disposed of at appropriate off-site facilities.

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Comment 1-4: NJDEP has not yet received analytical result* from deeper wellsfrom August 1985 sampling round.

Response! These analyses were provided to HJDEP in the "Site EvaluationAddendum: 80 and 120 Lister Avenue," February 1986. Resultsfro* wells located on 80 Lister Avenue and Shervin William* mayb« found in Chapter I, Appendix F. Kesults from wells locatedat 120 Lister Avenue may b« found in Chapter II, Appendix E.

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Comment 1-5: There is an indication of TCDD solubility in ground watersimples where other contaminants have been found. There shouldbe further discussion and clarification of this issue in the fS.

Response: The levels of dioxin in the ground water may be attributable tosuspended solids in the samples. Laboratory protocols requirethe analysis be performed on unfiltered ground water.Laboratory personnel have reported that water samples wereshaken to resuspend settled sediment prior to removal ofaliquots for extraction and analysis. The high partitioncoefficient of dioxin for suspended organic natter would resultin elevated dioxin levels in the extract.

In order to evaluate the possibility of increased dioxinsolubility in ground water as a function of other contaminants,a linear regression analysis was performed on the eight groundwater samples from the fill where volatile, acid andbase/neutral priority pollutant data were available and theconcentration of dioxin was greater thaa or eqval to 0.2 ppb,the solubility of dioxin in pure water. A study by L. Marple etal. presented in Environmental Science and Technology (February,1966; Vol. 20, pp. 180-182) indicates the solubility of dioxinis 0.02 ug/l. Because the risk assessment is based upon0.2 ug/l, the more conservative value was used in thestatistical analysis.

For the variables total organic priority pollutants (minus PCB'sand pesticides) and dioxin, the Pearson correlation coefficient,r, is 0.05, the coefficient of determination, rj, is 0.0023 andthe slope of the regression line, is 5.1 x 10 . Therefore, nocorrelation appears to exist between concentrations of organiccontaminants and increased dioxin solubility in the groundwaters. Also, a non-aqueous phase Liquid (HAPL) was neverobserved in any of the samples analyted to date.

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Comment 1-6: Inconsistencies relative to monitoring well ground waterelevations must be clarified. Possible tidal influence* in deepmonitoring wells should be further investigated.

Response: ' Table 2.1-8 from the 80 Lister Feasibility Study which list*(round water elevations in Monitoring, wells at the site is inerror. Survey measurements shown for top of riser elevations•nd all ground water elevation* in figures are actually top ofouter protective casing. Table 5.6.1-3 presented in the SiteEvaluation Addendum (February 1986) has been corrected and allelevations are based on top of P.V.C. riser pipe.

In order to evaluate the magnitude of tidal influence on groundwater levels at the site, a water level survey conducted at peakhigh tide and low tide was conducted on February 2 and 3. 19M•t Monitoring Hell 2B located adjacent to the river. A HERMITautomatic water level recorder was used to record tbe waterlevel measurement* in tbe well. The Passaic liver Stage wascalculated based on automatic water level readings taken with aStevens data logger at the Passaic River gauge. The results arepresented in Figure 1-6. Slight change* of less than 0.) feetin ground water elevation appear to be in response to rivertidal effects.

Oa February 3, 1986 Monitoring Well* *B and 108 were manuallymonitored for approximately seven hour*. Only very (lightchange* in ground water elevation were noted. !**-*• showedchange* of less than 0.2S feet. Off-site Monitoring Well MW-108water elevations remained essentially constant during the sametime period.

Including the more recent data taken from the "I" level well*.finished In the glaciofluvial sand below the silt layer andaccompanying this data with that obtained and reported earlier

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TABLE 1-6-1

COMPARISON OF TOTAL CHANCEIN RIVER AND GROUND HATERLEVELS OVER A TIDAL CYCLE

MONITORINGWELL 1.0.

TOTALFLUCTUATION

(FT.)

CORRESPONDINGRIVER LEVELFLUCTUATION

(FT.)

MW-2AKH-2BMU-4AMW-4B

MW-10B

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Comment 1-7: Data froa Table 2.1-8 doit not appear to support the contentionthat the potentioiMtric head in the glaciofluvial tend it fivefeet Leu than the fill. Details relative to calculation! ofdirection and velocity of {round water flow need to b«

• pretented.

Responses In ennitoring NW-4, KW-7, and HW-10, the weter levels in thefill and land differ by as. leatt five feet bated on existingdata (Table J.6.1-3 for Ju! • 3 and July 8, 198$; Site EvaluationAddendum). In Monitoring well MW-2, the head in the land itapproximately two to three feet below that in the fill. Thissuy be dun to the increased depth of fill/depth to tilt causingthe water table in the fill to slope downward to the north,decreasing the apparent head differential.

Direction* and velocities of ground water flow were calculated•sing permeabilities fro* tlug test data and surveyed wetertable gradientt as described in Section 6.5.4 ef the M LitterSite Evaluation Addendum.

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nt 1-8: Assumed values of silt layer hydraulic conductivity areunacceptable for the purposes of the FS. Organic content andgrain tiie distribution should be included.

Response! ' Two tilt samples from borings on the 120 Lister Avenue siteunderwent laboratory permeability testing. The results arepresented in attached Table 1-8-1. Hydraulic conductivities atthree confining pressures were measured in one sample fromBoring 1010, located adjacent to the proposed slurry wall, andone sample from Boring 1020. Hydraulic conductivities rangedfrom 1.0 x 10"' cm/sec to 0.22 * 10"' cm/sec in Boring 1010.Boring 1020 yielded conductivities of 1.0 x 10 cm/tec to 0.37x 10"' cm/sec.

Grain sice analyses were performed on two samples from Boring1010 and five samples from Boring 1020. A* shown in theattached table, lilt is the predominant site fractie* im ellsamples except 1020 (8.J to 10.I feet) where the clay sicefraction is slightly predominant.

Atterberg limits were also performed on four samples. Basedupon the liquid and plastic limits, the soils were classified ashighly plastic organic silts (USCS Designation OH).

Creer Engineering performed a consolidation test during a siteinvestigation study in June 1940, on a silt layer sampleobtained from a depth'of approximately 18 feet on 80 ListerAvenue. A value of permeability was calculated from theconsolidation test data which was approximately 10*' cm/sec, or100 times less than the value obtained from the direct testprocedure. This indirectly obtained value is not considered tobe as representative of the material's in situ permeability asvelue* obtained directly from the permeability test*. Table I-9-2 contains the results of the Creer Engineering Study.

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Comment 1-9: The dilution factor, as calculated in Appendix A, may not bevalid, based on demonstrated aniiotropy of the BrunswickFormation in the vicinity of the site, and underestimation ofthe aquifer saturated thickness.

Response) ' The dilution factor calculated in Appendix A was based upon theprobability of the site being within the radius of influence ofa pimping receptor well and geometric considerations.

The selection of Receptor Well Ho. 9 for the risk analysis wasbased in part on its location in relation to the site. Hater inthe Brunswick Formation moves more readily along joints andfractures which strike parallel to the strike of the bedding(H30*C). Hell Ho. 9 lies in direction of preferential flewapproximately 1,800 feet southwest of the sice. Radius ofinfluence calculations based upon a saturated thickness of200 feet indicated the site was well within the well'sinfluence. Ic would be necessary to increase the saturatedthickness te approximately 4, MO feet for the site t* be outsidethe influence of the well.

The geometric considerations upon which the dilution factor wascalculated included:

o The thickness of the saturated fill on site

o The thickness of the water column at the receptorwell

« The horizontal angle subtended by the site from thereceptor well.

Underestimation of the thickness of the water column wealdresult i« an increased dilution factor since more water would beavailable in the greater volume. Consequently, the calculations•resented in Appendix A result in a more health-protective veluefor the dilution fector.

19

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RISK ASSESSMENT COMMENTS

Overview Response:

The risk assessment performed for the 80 Lister Avenue site began ia March198) and utilised the latest available guidance from the U.S. CM (Morgan et.al.t 1984, in Management of Uncontrolled Hazardous Haste Sites. HazardousMaterials Control Research Institute, Silver Spring, Maryland). This documentwas the basis for the more recently developed methodologies that are still indraft status. According to the guidance, a risk assesiment is performed tomeet two objectives: "to better define the risk of harm and consider optionsto respond to the entire problem." In other words, the conclusions of a riskassessment not only define potential risks, but also provide urnsdial actionobjectives for the engineering tasks of a feasibility study. Therefore, arisk assessment unifies the process of site investigation and remedial actionby assuring that all concerns are addressed in determining the bestremediation for the sit*.

The risk assessment for the 80 Lister Avenue Feasibility Study was undertakento define the incremental risk associated with the site as it exists today.The "no-action" alternative was evaluated for the purpose of assessingpotential long-term risks for the site. The risk assessment adequatelyencompasses the exposure estimates and scenarios pertinent for the site. Onceit became obvious that the no-action alternative was net viable for a givenpathway or class of chemicals, the risk assessment process continued to ensurethat the second objective of "providing guidance for remedial alternativeselection" (Morgan et. al., 1984) was met. Therefore, this risk assessmentfulfills the objectives stated in the U.S. CPA guidance.

~s •»•?«73«

Comment II-l: Maximum storm intensity should be used to determine if surfacerunoff is a migratory pathway. Data from Newark Airport may be•ore representative of site conditions.

Responsei The data selected to represent the average storm intensity andsubsequent dilution was considered to be most appropriate forlong term health protection on a daily basis. Catastrophicevents (such as a 100-year runoff event) do not reflect normal,long-term conditions. Regardless, estimation of surface runoffhas been recalculated using extreme event parameters aod ispresented below. The calculations generally follow the sicerunoff methodologies used in Section 3.3.2.1 (surface runoff)in the Feasibility Study report. Runoff and dilution by thePassaic River is calculated for the pervious and imperviousscenarios using parameters representing the 100-year rainfallevent for the site area and the flow of record for the LittleFall* Station (USCS) upstream of the site. For the extremelyunusual event postulated here, these data would represent theminimum amount of dilution due to runoff.

100-year rainfall event for Newark Area • 7.J inchesof rain over a 24 hour period (average • 0.312S in/br)

Flow of record at Little Falls Station (USCS) onPassaic River • 31,700 cubic feet per second (cfs)

Site area • 3.4 acres

Pervious Surface Scenario

Soil infiltration rate • 0.24 in/hr (U.S. Bureau ofReclamation, 1974)

Average rainfall for 100-year event • 0.112$ in/hr

Met RuMff • (0.312) in/hr) - (0.24 in/hr) « 0.07 in/hr• 0.24 cfs

Dilution Factor • (0.24 cfs)/(31,700 cfs) « 7.4 x 10~*

21

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Impervioui Surface Scenario

o Assunes all rain-fall i« converted to runoff.

Runoff • 0.312* in/hr• 1.07 eft

Dilution Factor (using flow of record)• (1.07 cfs)/(31,700 cfs) " 3.4 • 10"5

The dilution factor using the 100-year event is three civethigher than the long term factor calculated using site specifichealth protective assumptions. The concentrations of indicatorebeaucala calculated using these dilution factors as listed inTables 3.3.3 and 3.3.4 are, therefore, three tisws lower. Thisanalysis shows that the assumptions used in the risk assessmentof average rainfall and site specific dilation afford thegreater health protective benefit.

22

Comment II-2: The methodology employed in the selection of "indicator"chemicals is inappropriate. All carcinogenic contaminants mustbe evaluated, as well as noncarcinogens exhibiting a specificacute or chronic toxicity, and those which bioaccumulate or arepersistent in the environment. Observed concentration enddistribution should be considered in the selection process.Potential exposure pathways for other chemicals in water andair need to be evaluated.

Response! The approach used in the risk assessment presented in theFeasibility Study for 10 Lister Avenue is biased towards healthprotection. The screening process used to select suitablechemical indicators was a multistep process. Chemicals weredivided into 16 different classes which reflect their chemicalstructure. Within each class, chemicals were reviewed in arigorous manner for their overall toxicity. First, suspect orknown carcinogens were identified; them, in groups where nocarcinogenic compounds were found, the overall toxicity of thevarious chemicals was examined. Third, all these factors wereweighed against the quantities detected on sit*.

Within groups in which carcinogens were identified, theirrelative patency was compared and concentrations were factoredto reach a decision em the appropriate indicator. In groups inwhich.no carcinogens were found, overall toxicity was used toselect the indicator chemical with quantity present being asecondary factor. This gives the swat health protectiveapproach.

At a meeting on April 29, IM* the HJOCF presented a list ofchemicals that it felt should have been included in theindicator liat for establishing remediation objectives. Thelist of chemicals wast

23

o Benzo(b)fluorantheneo Benzo(«)pyreneo Berylliuao Cadmiumo Chromium VIo 2,4-Do 4,4'DDO

4,4'DOCDibenzofuran!ndeno(l,2,J-CD)pyreneHethyltnc chloridaNickelTetrachlorocthan*Trichloroetbene

All of these chemicals were evaluated in the risk assessmentprocess. The folloving examples demonstrate that the approachtaken in the Feasibility Study is s»re than adequate to protectpublic health and the environment.

Polyaromatic HydrocarbonsWithin the group of polyaromatic hydrocarbonsbenco(a)anthracene was selected as the indicator chemical. Inthe soil the concentrations of ben«o(a)antbracene andbenxo(a)pyrene were approximately the same while benzo(b)-fluoranthene was at slightly higher concentrations andind«no(l,2(3-CO)pyren« had lower recorded value*. Of the**fear chemicals ben«o(a)anthracene was the only erne chat wasdetected in ground water, thus indicating a higher potentialfor human exposure because of distribution into this medium.

Structural similarity and on-site distribution has thus shownthat benso(a)antbracene is an appropriate indicator ofmigration potential for this class of chemicals, lowever,ben*o(a)pyrene has a carcinogenic potency approximately 2itime* greater than ben*o(a)amthracewe. In keeping with thehealth protective approach of the risk assessment, the higher

• b*nao(a)pyrene potency factor was used in our calculation* ofrisk to potential benxo(a)anthracen* exposure. The net effectis an exaggeration of potential risks since off-site transportwas estimated using data on the more wide-spreadb*neo(a)enthracene, but the resulting risk was calculated as ifthis material was the more potent benco(a)pyren*. This in turnled to more stringent remedial objectives.

24

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Dichlorodiphenyl Ethane* (DPT, ODD, DDE)The selection of DDT at the indicator chemical wa* based on therelative carcinogenic potency and acute tozicity of the threecompounds of concern and their relative concentration* on the•ite. Although there are inadequate data to classify thisgroup a* a huatan carcinogen, IARC hat classified then all intoit* Croup 2B. Relative potency factors applied are S.60 forDOT, 3.80 for DM, and 0.1 for ODD. DOT i* the matt potent.In other word*, a lower dose of DDT is required to cause acarcinogenic effect. For ezaatple, a dose of ODD would need tobe 56 tines higher than a given dose of DDT to cause the *aiMlevel of concern. Similarly, DDT ha* a «ore potent acutetoxicity. The LDjg value* of the three chesncals are 113 "g/kgfor DDT, 217 ng/kg for DDE, end 4SO nc/kg for DDD. Thus intenet of both carcinogenic potency and acute tosicity DDT i*the swre potent of the three coatpound*. The site-specific data•how that in the near turface soils (0 to 6 inches) there we*•bout 3S tiaw* e»re DOT than DM and about 270 tisw* e»re DOTthan 000. In the lower layer of Mil (12 to 24 inches) therewe* • ratio ef 31:1 for DDTtOOD and 137:1 for DDT:DOE. Thehigher relative concentration* end the highercarcinogenic/toxicity potency of DDT sake the choice of DDT atthe indicator ehcaucal for this group appropriate, andillustrates that the risk from exposure to these ether twocheatical* i* one to three order* of Magnitude lower.

MetalsIn contidering a suitable indicator swtal the background range*ef endogeneou* toil concentrations were taken into account •«that a health protective rick a**e*satent cen be based onrealistic value*. Table I1-2-1 showt level* of the variouspotentially carcinogenic petal* (arsenic, beryllium, cadtunn.chreeUtM and nickel) found at the Diaannd Shaavock site alongwith concentration ranges in the earth'* crust and the averagebackground level* Measured In Newark.

23

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Of the metals found on site during screening analyse*, choseconsidered as being potentially above background levels aadthus candidates for inclusion as indicator chemicals werearsenic, cadmium, and nickel. The average concentration ofarsenic found in Newark was 7.9 ppm compared to *.S ppm onsite, for cadmium was 2.3 ppm compared to <0.t>5 ppm oa sice.and for nickel was 48 ppn compared Co 25.7 ppm oa sice.Table II-2-2 shows the data for the incidence aad concentrationof arsenic and cadmium on sice. All three octal• areconsidered to be human carcinogens; however, there issufficient evidence for classifying only arseaie as sach.Furthermore, arsenic compounds are Che only ones that arcclassified in lARC's Croup 1. The highesc potency factorsattributed to compounds for each metal are 130 for arsenic, 60for cadmiua, and 1.1 for nickel. Arsenic was chosen because ofits potency, its human carcinogen classification scatvs. aadbecause arsenic has been demonstrated to be carcinogenic vaeningested while cadaium has only been shown to be carcinogenicwhen inhaled. Since the risk assessment process iho»tdcontamination of ground water as the primary exposure coacernfor the general population and the environment, the choice ofarsenic as the indicator sweat derives the aaTiaam healthprotective benefits.

Volatile Chlorinated OrganicsOf the four volatile chlorinated organics identified at the80 Lister Avenue site, chloroform was selected as the indicatorchemical. Both chloroform and Crichloroetheae are kaown animalcarcinogens. In addition, chloroform is a suspect mommacarcinogen whereas there is no comparable evidence for tri-chloroechene. The potency factor for chloroform is more thanthree times higher than that for trichloroetbene. thepotential carcinogenicity of methylene chloride is cnrremtlyunder review by the regulatory agencies. It does mot ae*t theestablished guidelines and U.S. EPA criteria fer • class 21carcinogen, owing to conflicting results in long term aaiaal

27

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studies and design flows in epidemiological studies. Tbecurrent value for methylene chloride's cancer potency show alower factor than chloroform and are currently undergoingtechnical review by the USEPA as part of the process forevaluating regulatory alternatives. The occurrence ofaiethylene chloride was ubiquitous in the shallow soil saaples.although only 5 of 42 sample* exceeded 180 ppb. While thepresence of elevated levels of nethylene chloride suy be due tooccurrence on the site, low levels of nethylene chloride inenvironmental analyses are often traced to the laboratorynanipulationt of the sample, as sMthylene chloride is awidespread laboratory solvent. No evidence has been found tosuggest that tetrachloroethane is carcinogenic.

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In tenas of acute toiicity (LOjg), chloroform if significantly(6 tines) BOre toxic than the other carcinogen,trichloroethene. Furthenxire, the range of level• ofchlorofona in both toil and ground water wert considerablyhigher than the corresponding levels for trichloroethene.Thus, with the data available, chloroform is clearly theindicator of choice for Mxiouai health protectioa.

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TABLE I 1-2-280 LISTEt AVENUE - NEAR

(PF-)• ARSENIC

STATION NO.t

' A-2-C1 • A-4-P

I A-S-CB-2-N

1; C-6-8

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0.3018

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Ev«lu«tion, 1983.

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CADMIUM NICKEL0-6" 12-24" 0-6"

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The hydraulic conductivity (permeability) is a function of theintrinsic permeability (k), the density (o), and the viscosityof the fluid (u), and gravity (g).

«c • * (-**-)

Since the fluid phase contains only a small fraction ofdissolved organic chemicals, neither the density nor theviscosity of the fluid phase will be significantly differentfrom water. Therefore, the measured permeability factors forpure water applies to this phase. In addition, a oonaqueousphase liquid, which could potentially have significantlydifferent fluid properties, was never observed in any groundweter sample.

30

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Conrnenc II-3: The permeability factor of 10~3 foot per day to water does notapply to all organic chemicals on lite.

Response: As discussed in Section 3.3.3.1 (vertical Migration analysis),the organic silt layer nay serve as a barrier or constraint OBvertical migration because of its low permeability of10~3 ft/day. As described in Comment 1-8, tilt samples fromBorings MW-101D and MW-102D underwent permeability testing iaFebruary, 1986. Resulting values ranged from0.2 x 10"' cm/s to 1 « 10"' cm/s (or approximately3 i 10~* ft/day). The health-protective value of 10"' ft/dayassigned to the silt layer permeability for tbe purpose of thisrisk assessment, is almost an order of magnitude bigber (orfaster) than the values derived from the laboratory tests.

I"

The intrinsic permeability is a function of the aquifermaterial and is assumed to be relatively constant over the sitearea. Gravity also remains constant. The only properties thatmay change significantly to affect the conductivity are thosethat apply to the fluid phase, which is predominantly water.

Oo

Some ground water analyses from the fill zone indicate veryhigh concentration of various organic constituents, in somecases exceeding their solubility in water. However, analyticalprotocols required that all organic analyses be performed onunfiltered samples. Therefore, the samples contained suspendedmaterial from the fill -hich has been shown to contain organicmatter capable of adsorbing chemicals such as dioxin, DOT,pesticides, and other organic hydrophobic chemicals (Umbreitet. al., 1986, Science 232:497-499; Jackson et. al., 1985. inLand Disposal of Hazardous Haste. Proceeding* of the llthAnnual Research Symposium at Cincinnati, Ohio, April 29-Nay 1,1985, CPA/600/9-8S/013).

Based upon available octanol-vater partition coefficients, itappears that large quantities of the organic substance analyzedhave been extracted from the suspended material in thesamples. Only • very small fraction of the fluid phase iscomprised of organic chemicals. Therefore, the healthprotective permeability factor of 10"3 ft/day is appropriatefor vertical water movement with associated organic chemicals.

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Comment II-4: The PTDIS atmospheric dispersion model employed may not be asappropriate as others developed.

Response: The air dispersion pathway using the PTDIS model was analyzedusing extremely conservative health-protective assumptions foremission and dispersion parameters. The health-protectiveassumptions and parameters overestimate projectedconcentrations that would mos: likely occur. These parametersand assumptions are described below.

o The PTDIS model utilizes a point sourceconfiguration for Caussian dispersion. The exposedportion of the site is approximately 1.74 acres.Maximum jnd mid-range downwind concentrations wereestimated using soil concentrations within thisexposed area. It was assumed that the siteemissions of chemicals were at a fixed continuousrate indefinitely, so that the exposureconcentrations could represent long term values. lareality, the mass of contaminants on-site isfinite, and exposure concentrations would decreaseover time.

o Another health-protective assumption was that thecontaminants were conservative; that is, nodegradation of the contaminants, such asphotolysis, would occur.

o The site was modeled as a point source with PTDIS,as opposed to an area source. This scenario isalso health-protective, as predicted concentrationswould tend to be higher when using a point sourcescenario instead of an area source. Most airdispersion models, such as the Texas ClimatologicalModel (TOO, VALLEY, or Industrial Source ComplexModel (ISC), define a "virtual" point source upwindof the site when the source is larger than a stackor point source. This virtual point source is thenused in the Caussian dispersion equations. Thevirtual point source is defined as the point upwindof the site a distance equal to that which gives aplume width equal to the width of the area sourceat the actual location of the spill site. Thewidth of the spill area is equivalent to thediameter of the spill area, assuming a circular ~ *configuration. Typically, distances to receptorsare increased to reflect the distance between themand the virtual source. This incremental distanceis equivalent to the distance between the site andthe point source. Given the steady-utate emission

32

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source term and meteorological parameters used,predicted exposure concentrations at the adjustedreceptor distance will be lower because thereceptors are modeled to be farther downwind. Inour simulations, no adjustment was made for thevirtual point source, to the calculatedconcentrations at the receptor location are higherthan an equivalent calculation using an areasource.

o In utilizing PTDIS, we assumed that the terrain vatflat and transport of contaminants was controlledby Cautsian dispersion. This is a valid assumptionin view of the fact that the exposed site area isflat with relatively few buildings on it, and thatthe receptors were assumed to be very close to thesite, approximately 200 yards away. Urban areaturbulence was considered to have a minor effect ondispersioo.

=- g -y:s

In conclusion, we believe the modeling exercise employed it aconservative screening application, and is appropriate forworst-case project assessment for this site.

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Consent II-5: The off-site exposure for the air pathway should includepotential occupational exposure.

Response: Potential on-site occupational exposure was addressed inSection 3.4.3.4 (pp. 3-23) of the Feasibility Study and thepotential air concentrations estisuted were three to fiveorders of magnitude lower than the occupational criteria.Potential off-site occupational exposure estimates would beeven lower due to lower concentrations from increaseddispersion. Both the occupational and residential populationsare in close proximity to the site. However, the generaloccupational exposure is -for only 8 hours per day, S days purweek, versus a potential 24 hours per day, 7 days per week forresidents. Also, the average occupational lifetime is only afraction of one's total life expectancy. These factors lowerthe total exposure potential for the occupational populationrelative to the general population in close proximity to80 Lister Avenue.

t» 2

Excavation of the site is the only scenario which ispotentially significant for air emissions. Dust release can becontrolled by such means as wetting the soil. However,emissions of volatile* are more difficult to control during theexcavation and movement of the soil.

The remedial alternative recommended in the Feasibility Studyinclude* extensive capping of the site's surface which willreduce potential vapor emissions to negligible levels andeffectively eliminate significant health risk concern*associated with the air pathway.

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34

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nt II-6: The incremental lifetime riik utilized by NJDEP in thealternative selection process is 1 x 10~6, not 1 x 10"*, asindicated in the FS.

Response! The alternative selected in the Feasibility Study is judged toreduce potential risks to a level that is negligible, and infact is lower than the 10~* level that NJDEP dtsires andcertainly lower than 10* . This question focuses on only oneelement of the risk assessment process, when indeed there are•any elements that comprehensively affect the calculation ofrisk levels. Major considerations include the toxicities ofthe chemicals of concern; release or source termcharacterization; identification of critical receptor groups;characterization of environmental transport and fate;estimation of dosages; and estimation of risk, includingrecommendation of an acceptable risk level. Parameter range*are identified for each element in the risk assessmentprocess. In our endangerment assessment, parameters for eachelement were defined using the most health-protectiveassumptions that could be realistically assigned for thesite. Viewed collectively, risk calculations performed usingthese assumptions include conservative elements that mostlikely exceed the ten-fold difference in acceptable risk levelof 10"5 vs. 10~6. The 10~5 risk level, then, should be viewedas a risk assessment element with a site-specific, health-protective value assigned to it that exceeds a factor of teafor 80 Lister Avenue.

The health protective assumptions utilized in the riskassessment are listed in Table 3.1-1 in the Feasibility Studyreport. Specific assumptions that are extremely health-protective are discussed briefly below.

3)

Oo

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o Ground Water Exposure

(1) The nearest well was assumed to be used fordrinking water even though this is anindustrial well and not permitted fordrinking water use (nor are any wells in thevicinity permitted for drinking water). Thequality of this water is also poor fordrinking water purposes, as there is saltintrusion into the glaciofluvial sand lyitemfrom the Passaic River.

(2) The parameters for estimating dosage werealso health-protective. Receptors wereassumed to consume one liter per day of thiswater for the occupational lifetime. It ishighly unlikely this scenario would ever berealized as this is an industrial and not aresidental well, and as pointed out above,the water is not suitable for drinking.

(3) Factors chat may dilute the chemicals throughbiological or physicochemical reactions werenot taken into account. These factors wouldtend to reduce any calculated risk associatedwith the chemicals. For example, retardationof contaminants was not considered whencalculating exposure. Hydrophobic chemicalssuch as DOT and TCDO have very lowsolubilities and high affinities foradsorption onto soil particles, making themrelatively immobile in soil-ground watersystems. The calculated retardation factorsfor TCDO and DOT were 340,000 and 38,000respectively. The travel time to the nearestreceptor well, then, will be 4-5 orders ofmagnitude lower than the time it would takeground water from under the site to reach areceptor well.

(4) The subsurface layers in the glaciofluvialsands which are discontinuous and would beobstacles to the downward migration ofchemicals from the surface are ignored forthe purpose of the calculations (even thoughdioxin and DOT have not been detected in thedeep wells). In fact, the mean and maximumconcentrations detected in the shallow on-lit* well samples were employed for makingthe exposure estimates. Under this assump-tion, the d i l u t i o n factor is underestimatedwhich results in the overestimation of . •exposure.

36

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Estimate* of exposure are based on a site that isassumed to contain an ongoing source (stillproducing) whereas, in reality, the site isinactive with a finite amount of chemicalsavailable for potential off-site transport.

Combining all of these factors, including overestimation ofexposures, the actual recommended risk criteria is most likelylower than 10" . Futhernore, the risk calculations performedin the endangerment assessment focused on the no-actionalternative as a baseline case. All types of potential oractual risk, including those arising in tht long term, wereevaluated. The risk criteria were used to evaluate "noaction", but the no-action alternative was identified as notbeing viable from a risk standpoint. Therefore, even in lightof the health protective assumptions utilized in the no-actionanalysis, the no-action alternative was rejected as posingunacceptable risk. Remedial action alternative Number } wasselected in the Feasibility Study as the best alternative thatwould meet the remedial objectives. The effectiveness of thisoption shows that future risks are negligible (See FS Table8.2-1). In other words, potential future risks are far lowerthan 10"* after completion of the proposed action.

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Comment II-?: The use of Ambient Water Quality criteria for noncarcinogens,but not for carcinogens must be clarified.For example:

benzene - calculated in F5 - 36 ug/L.AWQC - 0.66 ug/L.HCL (proposed) - 5 ug/L.

Response: For compounds for which a carcinogenic potency factor iiavailablef recommended exposure criteria were derived usingsite-specific assumptions. Noncarcinogens have no carcinogenicpotency slop*. Therefore, ambient water quality criteria weredetermined to be the best available information on which todevelop acceptable concentrations for these compounds.

The carcinogenic potency slope for benzene is 5.26 x 10(mg/kg/day) and is based on data from human occupationalexposure. Proposed maximum contaminant levels (MCLs) have beenset at the limit of analytical detection for the concentration*of volatile organic carbon contaminant* in drinking water,after critical evaluation of the same data on carcinogenicityon compounds like benzene that we evaluated in the presentFeasibility Study. HCL rulemaking is required by law to takeinto consideration the feasibility of controlling thecontaminants (SO FR 46902, November 13, 1985), rather thanstrictly using health effects information and risk levelsestimated from animal studies.

The recommended criteria used in this Feasibility Study werederived in a manner conceptually similar to this, but site-specific considerations were applied. These are described inthe answer to Comment II-2.

38

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Comment 11-8; NJDEP and USEPA consider carcinogenic doses to be additive.The FS does not evaluate this potential effect.

Additive cancer risk! are discussed in a separate subsection ofthe risk assessment on page 3-24 of the Feasibility Study. Theadditivity of cancer risks has a questionable theoretical basisand is scientifically reasonable only with chemicals consideredto have sinilar mechanisms of action on the saate targetorgan(s) in a scenario representing a contained exposure.Combining this with the complexities of environmental transportpathways analyses and exposure assessment make theuncertainties associated with adding cancer risks impossible toquantify.

Chemicals and radionuclides that initiate cancer comprise thetheoretical basis for all quantitative cancer riskassessment. Current knowledge limits the scientificfeasibility of adding potential cancer risks to thesematerials, and even their mechanisms of action are not wellunderstood. Cocarcinogens and promoter* are less understoodand the use of quantitative risk assessment for such materialsis not recommended (Stara et. al., 1983, Environmental HealthPerspectives 50:359-368). Dioxin acts much more like apromoter than it does an initiator (Kimbrough et. al., 1984,Journal of Toxicology and Environmental Health 12:47-93) Thisis true of other chlorinated hydrocarbons as well.

Mditivity is only one fora of chemical interaction. Others' include antagonism which applies to chemical* that decrease thetoxicity of other chemicals in a combined exposure. Examplesof chemicals that depress the carcinogenic action of otherchemicals exist and this is presently a very active area ofresearch. Under such circumstances, risk estimates could bereduced rather than added.

39

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Setting all uncertainties aside and adding the potential cancerrisks estimated for no-action on 80 Lister Avenue shows thatthe risk associated with dioxin by the ground water pathway ispotentially on* to six orders of magnitude higher than allother estimated risks (Table 3.4-4). For this site, risk,addition only affects numbers to the right of the decimal.Independent of ground water, the total air pathway risk changesby about 151 after addition. In other words, the conclusionsof the risk assessment are unaltered by risk addition, and theproposed remedial action practically eliminates the potentialrisks.

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Comment III-l: The FS doei not consider alternatives that conbine viabletechnologic*. Consideration should be given to some for* ofsegregation and off-site disposal of highly contaminatedwastes in conjunction with various on-site containmentalternatives. Spatial constraint* do not excuse a thoroughinvestigation of off-site option*. The PS iihould discuss therequirements that would Bake off-site disposal possible,regardless of the difficulties that would be encountered, anddetail those difficulties.

Response: The result* of the Site Evaluation indicate chat only Terrsmall volume* of material do not contain dioxin. A* stated iathe Feasibility Study, wherever possible, segregation ofwaites will be done. Drums not containing dioxin will bedisposed off site at approved facilities and structural steel,container*, and tank* will be decontaminated wherever possibleand moved off site. However, dirt, brick, wood, concrete, andliquid and (olid wastes containing dioxia stored oa licecomprise the greatest volume of material aad cannot be rtmendfrom the site.

Although we are obligeted to point out that constructibilic*restraint* for the on-site disposal options would bedifficult, regulatory constraint*, not spatial constraint*,make off-site disposal of dioxin-containing materialinfeatible. It i* physically impoiiible to separate dioxiafrom other chemical* in the various matrices present at 80Lister Avenue. While treatment facilities and technologic*are permitted to treat the various other chemical compound*that are present in the soils, water, and building material*.the pretence of dioxin make* commercial treatment impossibleunder present technology and regulatory constraints. Teobtain a permit to treat a waatc stream, the technology m»itbe permitted to treat all contaminant* contained im thematerial. Because no technology or facility i* permitted to

41

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III-I (Continued)

handle dioxin containing wastes, partial treataent isprohibited.

Th« Feasibility Study wa* pcrforaed within the framework oftxiiting ttatt and federal regulations. A total of tevea (7)hazardous waste firas that operate 21 landfills or haveincineration capabilities were contacted in Juae 1985. HOD*were permitted to accept or treat dioxin containing wastes.Recent contacts with these facilities have shown that the haaagainst dioxin wastes still exists. Response III-3 addressesdisposal outside of the United States.

Off-site disposal and/or treataent of dioxin containing wastewould require one of two aajor developaents. Cithersignificant technological advancements in dioxin destructionor treataent aust be aade in order to Beet currently proposedstandards, or proposed and current regulatory contraints austb* relaxed to permit either land disposal or treataent withexisting technology.

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42

Comment III-2: The screening process does not address obvious aeasures thatcould be initiated to aitigate difficulties associated withcertain alternatives. For exaaple, dust suppression aeasurescould be easily instituted to ainiaize aigration risks.special construction methods could be instituted to makerejected alternatives (i.e., excavation) more viable thanindicated.

Response: Dust was not a major factor in the alternative selectionprocess, however, dust concerns were considered equally forall alternatives. The overriding evaluation was geared to:

(1)Satisfy the objective* of the AGO(2)Satisfy the objective* of the Risk Assessment

by considering the following Evaluation Criteria:

- Performance (effectiveness, useful life)- Reliability (operation* and maintenance requirements,

demonstrated performance)- laplementability (constructability, time requirements)- Safety, Public Health, Environmental, Institutional aadCost.

Construction methods required for alternative* * to *included deep excavation of all soil to J ppb diosiaconcentrations in various levels of staging, rehaadling. aihauling. This includes placing contaminated material* amclean area*.

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Comment HI-2 (Continued)

Natural events beyond our control such as hurricanes,floods, and major storm events have a higher probability ofoccurring during the extended construction period forexcavation alternatives (9 to 10 years). The adverseenviroi.*-*nt*l impact such an event would have on the areamake the increased risks unacceptable when the selectedalternative will satisfy the objectives of the riskassessment and the requirements of the ACO.

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Comment HI-3: It appears that the PS has not sufficiently investigatedpotential disposal outside the United States or adequatelyaddressed incineration technology.

Response: Dr. Johnsson of Kali and Sail, AC in West Germany wascontacted regarding the potential disposal of wastes fro*the 80 Lister Avenue site. Previous communications betweenMr. Frank Sudol of the Newark Department of Engineering andDr. Hartmut Uiedemann of the Umveltbundesamt, the FederalRepublic of Germany environmental agency, indicated Kali andSalz might accept dioxin wastes. However, Dr. Johnssonindicated that the political and public opinion problemwould make disposal of the material "impossible" and,further, that the shaft capacity to handle the materials didnot exist. A written response has been requested and willbe submitted to MJDEP upon its receipt.

Mr. Paul Desrosiers of the U.S. CPA Dioxin Disposal AdvisoryCroup was contacted regarding the) status of commercialincinerator permitting within the United States. TheFebruary 1986 issue of "Pollution Engineering" incorrectlystated that the J. H. Huber Corporation had been issued acommercial permit to incinerate dioxin containing wastes.The Huber Corporation has an RtD permit on a two-inch-diameter unit. In addition, to be effective the particlefeed sixe must be 200 mesh or smeller and have a moisturecontent of less than 1 percent. A larger fo<ir-iach-diameterunit is still in the RID stage of development and Huber hasstopped development of a full-scale unit.

Hr. Desrosiers also indicated that the EPA's mobileincinerator is now down due to the status of CERCLA funds.If CERCLA is reauthorized they will not be able to operatedue to the extremely low dioxin requirement on (crabberwater for discharge.

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Comment 111-41

Responses

fThe ranking system employed nay be considered extremelysubjective. Justification as opposed to other evaluativetools need to be addressed.

The ranking process was conducted in accordance withpreviously established, clearly defined ground rulesdetailed in the Feasibility Study by professionalsknowledgeable in each area, i.e., specialists ingeotechnical engineering, incineration, chemical treatment,etc. The result* of the screening vere then subjected topeer review by experts in the various fields.

Criteria established for the ranking systen are issues thatare critical for the selection process. For example, two ofthe Bain criteria werel is the technology proven for thedestruction or imobilization of diozin, and is commercialscale operation of that technology a reaility.

Clot* examination of the final score* reveal no arbitrarycutoffs were performed to bias final selection to anyparticular technology. Clear, distinct differences exist inthe final scores. For each group of technologiesconsidered, there are clear distinctions in numericalratings indicating that certain technologies are expected toperform better than others.

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Com«nc IV-l-A:

Response!

How would ground water analyses be accomplished? Wouldstorage capabilities be necessary? What capacity?

For Alternative 3, a ground water withdrawal rate not toexceed approximately 20 gallons per minute (gp«) will becontinually naincained to reverse flow inwardly to thecontained area* Crab sample* of the ground water withdrawnwill be analyted both before and after activated carbontreatment using the following procedures:

o Collect periodic grab samples (through tapoutlets in the transfer line) in clean SOO-ml•ample bottles clearly labeled with the pointand time of collection.

o Transfer the samples through a controlledchain-of-custody to a nearby EnvironmentalProtection Agency (ERA) certified laboratoryfor analysis of all substances to be controlledon the NJOPES permit to be issued at a laterdate.

If requiredt treated water will be stored, analyzed, andbatch discharged.

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Conment 1V-1-B: How would the inue of saltwater degradation of tlurry wallsbe cddreiied?

1 )'•

Rciponiet For each conceptual design in the feasibility study, asoil/bentonite slurry wall was proposed and used to approxi-mate construction costs. The study objectives did notwarrant a detailed evaluation of all external factors which•ay affect the wall's performance such as saltwater contact.

tor an actual design, however, this level of detail andbeyond would be addressed. A wall mixture would bedeveloped which would be minimally affected by saltwatercontact. To accomplish this, laboratory mincrologicalevaluation of various clays would be coupled with bench-scale testing to obtain a suitable mix. Alternative claytypes, such as attupulgite, would be evaluated in the eventbentonitc was determined unsuitable.

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Comment 1V-1-C:

Responsei

What neasure* would be t«ken to protect the lite from the100-year flood?

Referring to the conceptual design presented in Figure 7.2-4of the Feasibility Study report, it if seen that the capover the site has its top located at approximately El. U.5feet and it* toe ac yard elevation. El 8.0 feet. The 100-year flood elevation is EL. 10.2 feet. Therefore, duringthe 100-year flood, the cap nay experience subnet-fence ofits bottom 2.2 feet.

The containment facility will be specifically designed towithstand the 100-year flood event. Conceptually therecommended alternative includes a new bulkhead andreinforced high strength concrete cap or equivalent forerosion protection. As stated in Response VII-1 thebulkhead could be designed a* part of the Passaic Riverflood control project to protect the sic* freej the 100-yearflood.

50

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Comment IV-l-D: What type of ground water treatment would be necessary?Effectiveness? Treatnent goals? What would happen tosludge generated?

Response! The design of a treatment system has not yet been finalizedand any proposed system will be tested on a bench scale inthe laboratory so that its operational performance can bedetermined prior to field installation. One possibletreatment scheme for the treatment of ground water wouldconsist of a flocculation 'step, pH adjustment tank, and adual container carbon treatment system with prefilters. ThepH adjustment is used to raise or lower the ground water pHto levels which optimizes carbon absorption of the organicsof concern. The dual container carbon system would beconnected in parallel and valved so that a fresh unit iaoperable while the spent unit is replaced. The prefilterswould be employed to remove any paniculate matter from theground water stream prior to entrance into the carbonunit*. The treatment train could be modified withadditional treatment units, if necessary, to obtainacceptable effluent which is in compliance with the HewJersey Pollutant Discharge Elimination System (MJPDCS)discharge application.

In this sytem, the pH adjustment unit would be a cone-bottomtank with the effluent withdrawn from the bottom of thecone. As a result, no settled solids accumulate in thisunit. The solid waste products associated with thetreatment train include the spent prefilters and the spentcarbon. If possible, these wastes would be transported off

; site to an acceptable disposal facility or properly disposedof on site.

51

OO

Comment IV-l-E: Are there anticipated structure! problems associated withany of the on-tite alternatives? What would be the approachto their resolution?

Response: Structural problems anticipated in the design of thealternatives are naturally inherent to this type of site. Alarge percentage of the anticipated problem will beeliminated by a proper bulkhead wall design. The knowledgeand information gained by the in-depth Monitoring prograxestablished at 120 Lister Avenue to aeaiure settlement willpave the way for proper design. In the cappingalternatives, the clay cap is protected from erosion by aconcrete cover properly designed, hater stopped, jointed,and sealed.

With regard to Alternatives 4 and 5, both of which requiremajor excavation, consideration would nave to be given tosupporting adjacent structures. If the site were excavated,• structural diaphrasi wall, or suitable alternative, wouldhave to be installed so that excavation could be conductedto the limit of the property. Such a wall would requireeither tiebacks or cantilevering. Installing tiebacks wouldrequire cooperation frori adjacent property owners so thatexisting foundations or utilities were not disturbed. Acantilevered wall, on the other hand, would require afoundation footer that would have to extend below theconfining silt layer and well into the underlying sands andgravels. Such an installation would produce new andsignificant pathways for the downward migration of both on-and off-site chemicals. The problems associated withexcavation are avoided by using the recommended slurrywall/bulkhead combination while meeting project objectives.

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Comment IV-l-F: How would the structural integrity of a shallow slurry wallbe ensured in view of the fact that it would be "tied into'the silt layer? Would there be back-up systems installed ascontingency for failure? What would that entailT

Response! The tieing of the slurry wall into the silt layer isirrelevant to the containment system's structural integrityas long as the site is not excavated. The keying of theslurry wall into the silt layer is only a method ofconnecting the containment structure's bottom to its sidesand preventing leakage under the slurry wall.

Th'j contingency plan for the proposed containment willincludei

o Ground water withdrawal system which maintainsan inward gradient

o Continued interior and exterior contairstructure ground water monitoring

ent

o Rapid remedial response to repair wall, ifnecessary.

As part of the final design of the recommended slurry wall,a survey of adjacent outside structures will be conducted,as well as consolidation or triaxial tests of the soils topredict the effects of anticipated loads. Considering thatthe slurry wall itself is composed of compatible materialsas the existing surrounding materials, the slurry wallcannot be so deformable that it will be "squeezed" byadjacent lateral loads. Along the river, the new bulkheadwill provide the structural integrity of the slurry wall inthat segment.

Coonent IV-l-C:

tetponti)

Detaili pertaining to the necessity of the slurry will needto be elaborated upon. Compare hydraulics with and withouta slurry wall.

The incorporation of a slurry wall into the containmentstructure conceptual design was for the following reasons:

o To keep site source chemicals within tb« sit*boundaries

o To keep off-site other source chemicals to theexterior of the site boundaries, because the(round water gradient will be coward the sit*and the water withdrawn will be treated

o To minimile the quantity of water which must bewithdrawn to maintain an inward (round watergradient.

A preliminary review of the site hydrology indicated thatthe volume of water required to be withdrawn in order tomaintain an inward gradient with and without a slurry wallwill vary by an order of magnitude.

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Comnent IV-2: Essentially this section is a unit process study. Yec, nographics, flow charts, equipment required, or mass balancesare presented.

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Response: The Feasibility Study presented the conceptual design ofseveral potentially viable alternatives, the primaryobjective being to present the concept of each withoutdeveloping specific engineering design details.Alternative* did include estimated equipment, materials, andlabor requirements for the implementation of each.Similarly, conceptual design drawings were provided for eachalternative. Presentation of graphics, flow charts, andmass balance* at this point, before one concept is chosen,i* not a feasibility study level objective.

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Comment IV-3: Risks associated with transporting hazardous wastes exist;however, this must not be used as an argument against off-site disposal. HJDEP does not evaluate this type of riskwhen transporting hazardous materials. Bather, reliance isplaced on risk, to human health as the controlling criteria.

3~^=r

Response: Risks associated with off-site transportation were not usedto accept or reject any concept. Knowledge of trans-portation risks would be useful in deciding between optionswhich demonstrate identical acceptability in all otherregards. However, all off-site alternacives were rejeccedon the basis of other criteria.

All alternatives were evaluated wich regard co the followingtechnical criteria:

A. Performance

1. Effectiveness2. Useful life

B. Reliability

1. Operation and maintenance requirements2. Demonstrated performance

C. Implement ability

1. Constructability2. Time Requirements

D. Safety

ooIn addition, public health, environmental, cost, andinstitutional issues were also incorporated into theevaluation.

Comment V-l: Based upon existing ground water elevations and boring logs,the head in the glaciofluvial sand is in the silt unit. There-fore, it appears that gradient reversal would require dewater-ing of the fill and silt, and not achieve stated objectives.More detail is, therefore, necessary to examine and resolve theassertions indicated in the PS.

Response! The piezoaetric surface of the sand unit is relatively flat andis generally at an elevation of about -1 to-3 feet. Thepiezoaetrie surface of the sand is near the fill/silt interfacein the southern areas of the site mainly because the siltsurface is topographically higher toward the south. In thenorthern areas, the hydraulic head of the sand unit is in thefill material.

By strategically placing recovery wells near the northernperisMter of the site, a greater saturated thickness of fillMy be drained. By lowering the piexometric surface of thefill to near the fill/silt interface in this area of the site,the piesometric surface will be below the fill and into thesilt in the remainder of the site. General ground water flowover the majority of the site will then be to the north in boththe fill and silt layers. The head in the sand unit will thenbe above the new, induced piexometric surface and gradientreversal will occur.

Dewatering of the fill Material with concurrent lowering of thewater table surface in the fill will serve two purposes. Firstand foremost, dewatering will remove the lateral transport

j Mechanise) for the contained wastes, i.e., the chemicals, willremain bound to the soil materials. Secondly, lowering of thewater table surface will reverse vertical hydraulic gradientsthrough the confining silt layer, thus further enhancing thecontainment.

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Comment VI-1: The Feasibility Study does not adquately or systematicallydiscuss the alternative considered relative to State andFederal law. For example, the alternative considered appearto be intended to prevent further contaminant release, but donot consider or address RCRA ground water protection standards.

Response! The Feasibility Study is an engineering document and was indeedprepared with due consideration being given to applicable stateand federal laws and regulation*. Further, the FeasibilityStudy was conducted in conformance with the various guidancedocuments issued by U.S. EPA under CUCLA. The designscontained in the feasibility study are conceptual only. In thefinal design stage applicable state and federal requirementswill be met by the selected alternative.

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Comment VII-1: The FS must evaluate the potential impact of the PatiaicRiver flood control project.

Retponiei Review of currently available information on the PasiaicRiver flood control project indicate* conitruction of a leveeor flood wall to withitand the 100-year flood i» planned forthe area of the site. The preferred alternative of theFeasibility Study require! conttruction of • new bulkhead.Provided that plani for the flood control project are at asufficiently advanced stage of development at the tisiebulkhead construction begins, our barrier could be designedto serve as part of the flood control syite*.

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Comment VII-2: More details relative to Coat Analysis for alternatives needto be provided. The information as presented is subjectiveand unverif iable.

S ?Is

Response: The purpose of this discussion is to present sufficientinformation so that the validity of the total cost can b«reviewed. In reviewing the costs, it is noted that they werecomputed considering the USCPA guidance document requirementsfor accuracy. The costs were not prepared to the level ofdetail required for a final construction estimate. OnlyRemedial Alternatives 2 through 6 are discussed herein.Remedial Alternative 1, the no action alternative, is notconsidered responsive to the site conditions and, therefore,is not discussed. Table VII-2. 1 presents an overview summaryof the costs. The alternatives as numbered in tbeFeasibility Study arel

ALTERMATIVE DESCRIPTION

2 Insitu Containment3 Insitu Containment plus Pump/Treat4 On-Site Thermal TreatmentJ On-Site Vault6A Off-Site Landfill Disposal68 Off-Site Thermal Treatment

The items for remediation are numbered on Table VII-2.1 forconvenience of this discussion and are not related to anynumbering in the Feasibility Study. All remedial items forall alternatives are listed in the table; therefore, eachitem does not apply to each alternative.

The emphasis in the following discussion is upon differencesin cost between the alternatives. Therefore, if the cost isthe same for each alternative, or very similar, so that thetotals are relatively unaffected, the discussion islimited. The discussion is concentrated towards major itemswhich strongly influence the totals.

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The discussion is preienced as • seriei of notes inaccordance with the item numbers. Hot all items areincluded.

MOTE3 TO TABLE VI 1-2. I

(Item I) The primary difference in security costs is due tothe estimated time required for remediation. For thisestimate, the following time periods of on-site work wereusedl Alternatives 2 and 3, 2.S yearsi Alternatives 4, 6A,and 68, S years I and Alternative 5, 4.5 years.

(Item ?) The bulkhead cost was based on 400 lineal feet ofwall at $l«l)0 per lineal foot.

(Item 4) Alternatives 2 and 3 include costs for completelygrouting the on-site conduits. For Alternatives 4, 5, 6A,and 6b, it would only be necessary to seal the conduits wherethey leave the site because the conduits would be removedwhen the site wae excavated. Thus, it is estimated thatAlternatives 2 and 3 will cost an additional $30,000.

(Item 5) The majority of the cost for all alternatives isbased on an estimated quantity of 5,300 cubic yards ofbuilding demolition at a cost of $100 per cubic yard fordemolition. This results in $530,000 of the total for eachalternative. The differences in alternative cost beyond thisare primarily due to the need for and expected difficulty ofspreading and compacting the rubble in Alternatives 2 and 3.

(Item 6) The estimated costs for transporting and handlingthe containers stored at 120 Lister Avenue are based on 84}containers) which were stored at the time the FeasibilityStudy was prepared. Common to Alternatives 2 through 5 arethe decontamination, wipe testing, and salvage value. Theseare I

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Alternatives 4, S, 6A, and 68 would involve excavation of thesite to a maximum level of dioxin concentration of 7 ppb. Todo this, it is probable that a structural wall would berequired so that excavation could be Bade to the wall and sothat adjacent buildings would be adequately supported. Usingthe same dimensions for the vail as for Alternatives 2 and 3and a unit cost increase of $4} per square foot to constructa structural wall results in an increased cost of $1,215,000for a total of $1,565,000.

The alternatives considering excavation night additionallyrequire an increased depth of cutoff wall along the river todecrease inflow fro* the river to the site; however, thiscote addition has not been included.

(Item 9) Alternatives 2, 3, 4, and S consider a one-footchick concrete cover over the sit* area. For Alternative S,the vault would be build over this one-foot concrete cover.Considering aa area of approxiaateljr 178,000 square feet anda unit cost of $250 per cubic yard for structural concreteresults in a cost of $1,650,000 for concrete (Alternative Scost for concrete is $1,625,000 due to a slightly satallerarea). The remaining costs are for liner systems, flow tone,etc. The difference between Alternatives 2, 3, and 4 andAlternative 5 ($186,000) is due to design differences betweena containment cap and the base for a vault, such as theslightly smaller volume of concrete. Also, a perimeter drainwould not be included at this point for a vault and the tie-ill to the slurry wall would be differenc.

It is noted chat including a cap cost for Alternative 4assumes chat the materials resulting from the thermaltreatment cannot be delisced and, thus, would have to becontained.

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(Item 20) The co»c for v«ult construction would be inaddition to that shown in Item 9 for Alternative 5. This isessentially the cost of constructing the vault over the vaultconcrete bottom priced in I ten 9. (See Figure 7.2-8 of theFeasibility Study.) The cost estimate for the vault wasbased on a four-acre plan area, 175,000 square feet. Thecoat itests art:

o A concrete cover 1.5-feet chick, resulting in9,722 cubic yards at $250 per cubic yard •$2,430,000

o Filter fabric at $0.10 per square foot •$18,000

e Concrete sealer at $0.0) per square fooc «$9,000

e Two 40 mil synthetic liners at $0.75 persquare foot " $262,000

o DIM foot of sand for a leachate detectioncone and one foot of sand for a leachatecollection tone, resulting in 22,000 tons ofsand at $12 per ton - $264,000

o Lcachate detection piping, 1,500 linear feetat $10 per foot • $15,000

o Leachat* collection piping, 3,000 linear feetat $10 per foot • $30,000

o Eight aanholes for the leachate collectionand detection tones at $3,000 each " $24,000

o This totals to $3,052,000.

(Iteei 21) For the postulated off-site alternatives, 6A and6B, the total nueiber of truck loads was estiewted at 5,362.This results froai

o 845 trips for the containers - It was assumedthat th* containers could be loaded "as is"onto flatbed* for transport

o 17 loadi for the druȤ on site

68

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(Item 22) For the postulated off-site di»poi«l in either •

Undfill or thermal treatment:, a unit coat for the diipoaalof TCDD watte wai not available. Therefore, it wat estimatedthat the coat would be at least 30 percent greater than thatcharted for PCB waite.

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The cost for landfill disposal was quoted at $150 per ton forPCB waste. Using an average density of l.S ton* per cubicyard for all wastes results in 105,000 tons for disposal at aunit price of $195 per ton, resulting in • landfill disposalcharge of $20,475,000. (Mote: For the on-site thermaltreatment, the higher average unit of l.S tons/yd weight wasasiuawd resull ing in a total of 132,000 tons. The actualaverage unit weight is not known but is probably closer tothe 1.8 value. The value of l.S ton* per cubic yard i*representative for soils (50,000 cubic yards) but i* low forbrick and concrete (about 2.0 ton* per cubic yard). Thus,the estimated tonnage for off-site treatment is probably toolow, which would result in higher cost! for Alternatives 6A•ad 61 than are reported.)

(Itea 23) As stated in Itesi 22, the estimated thermaltreatment cost was based on 105,000 tons requiring treatmentand a unit price 30 percent greater than PCB wastetreatment. The quoted price for thermal treatment was $0.70per pound. With the assumed increase for TCDO treatment,this is $1,&20 per ton. The total thermal treatment costwould be $191,100,000.

(Item 2t) The additional item* included in the costcttimate* include site supervision, ongoing engineering,subsistence, site trailers and vehicles, mobilisation anddemobilization, and health and safety. With the esception ofthe health and safety costs, the other costs vary primarilybetween alternatives due to the length of time estimated tocomplete each alternative. The health and safety costs were

70

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StandardAdainistrativeCosts

Health andSafety Costs

estimated at 10 percenc of (he total remediation cottt. Tb«followini givet a curtory breakdown.

ALTE8IUTIVE

2 3 4 5 6 A 6 8

$1,190,000 $1.190,000 $2,002.000 $1.823.000 $1.803.000 $ 1.843.000

760,000 767,000 5,495,000 1.566,000 4,693,000 22.S44.000

Total Additional 1.950,000 1,957,000 7,497,000 3.389,000 4,49*.000 24.343.000Costs

Using a blanket estisMte for health and tafety cottt of10 percent of the total cost rewlts in high estiaatedlcosts for Alternatives 4, 6A, tmt 61, which have highremediation costs due to treatawnt/disposal charges. Ikeactual health and safety costs coald be less, particularlyfor Alternative 68 which thovld aot exceed 4A. Tke healthand safety cost for Alternative 4 should he greater thanAlternative 6A because of the ev-tite monitoring whichwould be required. Alto, Alternative* 4, 5, 4A, and 6Bwould require extentive tite ewtitoring due to potentialexcavation esiittioni. However, even though the health andsafety cottt awy be disproportionate for Altermativet 4,6A, and 68 this cott doet not chaage the relative overallranking of all of the alternatives.

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