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Diamond 'Head .oil, Refinery S1te,"

,", '.J . K'earny TOWIlship Htidson'County;~ N~w·J~r~¢~·

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United States Environmental Protection AgencyJ . .

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'Region II

September 2'009

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, \ DECLARATION STATEMENT

RECORD OF DECISION

SITE NAME AND LOCATION

Diamond Head Oil Superfund site (EPA ID# NJD092226000) Kearny Township, Hudson County, New Jersey opeFable;unit 1 - Light Nonaqueous Phase Liquid Source Area

, , STATEMENT OF BASIS AND PURPOSE

This decision document presents the Selected Remedy for the light nonaqueous-phase liquld (LNAPL) source area located on the D'iamond Head O'il Refinery site in Kearny, Hudson County, New

.Jersey. ,The Selected Remedy was chosen inac'cordance with· the Comprehensive" Environmental Response, Compensation and Liability

'Act (CERCLA), as amended, and to the extent practicable, the National Oil and HazardousSubstanc:es Pollution Contingency Plan (NCP)'. This decision is

\ based on the Administrative Record file

for the: site. '

The State 'of New Jersey concurs with the Selected Remedy. '

ASSESSMENT OF THE SITE

.' The response actions selected in this Record of Decision (ROD) are necessary to protect public health'or welfare or the environment· from actual or threatened releases of hazardous. .

substances from the si t.e into the environment.

DESCRIPTION OF THE SELECTED REMEDY

.ThE! response, action described in this document represents the first' phase" or operable unit, ·for the site. It addresses .the LNAPL'source area, and is considered an Inte+,im.Action for the

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site ..

The Selected Remedy described, in this document involves .the excavation of the LNAPL source areas., construction of an on-site biocell for:'treatment of wastes, and off-site disposal of .the most highly contaminated' areas within the excavated material. Specifically, the major components of the selected response action include:

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• Isolation of the remedial' ,target areas with iC\lt,-of,f ,walis, and excavatipn of,'th~principal threat LNAJ?L areas,-a:,total of approximately 45,82'5 cubic yards of material;

,. For the highly contaminated portion of the excavated' material that is not amenable to' Oh":'sid~treatrnent, transportation and off'-site disposal facility (with treatment as required to meet-land disposal req1lirements);

• FOr, the~iesser contaminated LNAPL'material amenable ,. to on­site, treatment" cqnstruction of a"bioceil within'the

,excavated area to facilitate biodegradation. of the LNAPL wastes, including the inEitcillation of piping for air and 'nutrient distribution and a coilec;:tion syste'm. for air and water that may accumulate ihthe bi~cell;

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• Introduction of nutrients and bUlking agents to the lesser contaminated LNAP_L material to e~hance permeability and the ~onditions for biological activity, followed by plac~men:t of _this augmented LNAPLm'ater~a:l in tlie~ biocell for treatment and capping,; ,and

Operation of the aeration, nutrientdi,st'ributi,on, and wa'ter• 601lection systems for the biocell 'for an estimated five­year per:t-od; and

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• Performance sampling and final confirmation sampling to demonstrate that the LNAPLwastes have been destroyed thioughbiological degradation, at which time the biocell

'components will be dismantled.

DECLARATION OF STATUTORY DETERMINATIONS

Part ,1: Statutory Requirements ,

This Interim ActiOn is protective of humanheal~h ahd the, environment in the'

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,short term and is intended to' provide adequate protection until. a final ROD is signed, complies with ­those federal ,and) state requirements that,are'applicable or relevant aQd appropriate for this limited-scope 'action, and is 'cost-eff~ctive. Although'this, interim action is not intended to address fully the statutory mandate for permanence and treatment to' 'the maximum extent practicable,o this interim action does utilize treatment and thus, supports that statutory mandate'.

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Part 2: statutok Preference .for Treatment

The SeleGted Remedy ~eets the statutory PJef~~ence for th~ use of remedies that involve t'reatment as a princip'al element."

Part 3: Five-Year Review Requirements

(Subsequent action~ are planned to address fully the thr~ats posed by conditions at this site. Because this'remedy will".result in

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hazardous "substances remaining on siteaoove"l]ealth­based levels, ~"review will. be conducted toen~ure thaf the remedy continues,to provide adequateJprotecfion bf human health and, the environment wi thinfive' years afte,r commencement. of the remedial action. Because this is an "Interim Action, review of this site and remedy will be ongoi~gas~EPA continues to dev~~op "remedial alternatives for the site.

ROD DATA CERTIFICATION "CHECKLIST

The following information is irlcluded in the Decision (Summary section of this ROD. Additional information cap be found in the Administrative Record file for the site.

Chemicals "" of concern" and their respective concentrations ) "

may be found in the "Site Char~cteristics""se~ti6n.

• Potential adverse effects associated-~ith exposure to LNAPL may be ,found in the "Sumrriary of Site ~isks" ,section.

• A discussion of cleanup levels for chemicals of concern may be found in the "Ref(ledial Action Objectives" section.

• A discussion of priricipal threat waste ~s 60ntained in the "Principal Threat Waste" section of this docu~ent. )

• Current and reasonably-anticipated future· land use assumptions are discussed in the "Current and Potential; . Future Si.te and Resource Uses" section.

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• A discussion of potential land useth~t will be available· at the sites as a result of the Selected Remedy is discuss~d in the "Remedial" Act~on Objec~ives" section.

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• Esti~ated capital,annual operation ,and maintenance (O&M), and total present worth co~ts are" discussed in the "Description of Alternatives" s~ctibn.

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• Key factors that ,led to selecting the remedy (i;e., how the Selected Remedy provides the best balance of tradeoffs with resp~ct to the bal'ilncing and modifying criteria, highlighting criteria key to the'decisions) may be fc:iund in the "Comparative Anaiysis of Alternatives" and "Statutory Determinations" sections'. '

'~' .·9!2-JlU>al' ',. ~,

Mugdan, Director, Date Eme~gency ahd Remedial Response Division EPA .'~ Region II

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·-Oec i s ion Summary i

Operable UQi t 1.·~ Light Nonaque_ous Phase Liquid Source Area

Diamond Head Oil Refinery Site,

Kearny, Township, Hudson County, New Jersey , I

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United States Environmental Protection Agency

Region!I

September 2009

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TABLE OF CqNTENTS PAGE

'SITE NAME, LOCATION AND BRIEF DESCRIPTION ............. 3

,SITE HISTORY AND 'ENFORCEMENT 'ACTIVITIES ............... 3

HIGHLIGHTS OF COMMUNITY, PARTICIPATION ........... ; ..... 5

SCOPE AND ROLE OF OPERABLE UNIT .......................5

SUMMARY ,OF BITE C~CTERISTICS ................ : ...... 6

CURRENT AND POTENTIAL FUTURE SITE AND RESouRcE USES .. 11

~SUMMARY OF SITE RISKS ... ~ .. , ........' .... !•• ~ •• ; •• _,' ••• 11'

REMEDIAL ACTION' OBJECTIVES ................... '" ... , .. 13

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REMEDIATION GOALS,.............................. , ..... 13 ,

DESCRIPTION OF ALTERNATIVES ..............' .. '.. 14c ••••••••

COMPARATIVE ANALYSIS OF ALTERNATIVES ....... '......... ~lc8 '

PRINCIPAL THREAT WASTE ............................... 24 ' "

SELECTED REMED~ .. :.~ ......................... ; ....... 24

STATUTORY DETERMINATIONS ..... '.......... : ....... ; ..... 26"

DOCUMENTATION OF SIGNIFICANT CHANGES ................. 28

APPENDICES

APPENDIX I FIGURES APPENDIX II TABLES

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~PPENDIX III ADMINISTRATIVE RECORD INDEX APPENDIX IV STATE LETTER

. APPENDIX V RESPONSIVENESS ,SUMMARY

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,", ' SI,TE NAME ,LOCATION ANDaRIEFDESCRl;PTION ~ ,

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The Diamond H~ad Oi+ ,Refinery site, 'located at 14 01 Harri's6li~' Avenue, "Kearny, New Jersey;' near >the 'Hacken$ac:k Meadowlands, is

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char~c,ter~zed by con.tam~nat'~on' from"aformer' waste 011 , reprocessing facility. Figure ,l':shows the site's .16cat:ion.:' The si'te is comprised of ,a IS-:-'ac:re''tlpoccupied parcel that in'eludes

) .', .." -' . .' . . . we,tli:md areas· and drainage ditches'~ ci',' small wetland/pond, a' vege'tat::ed landfiil area along, the western border', arid the 'remnants of the former Diamond HeadOil Refinery facility on/the eastern portion of the site. The parcel 'is ,bordered by Harrison' ,Avenue (also called the Newark,Turnpiket to the north, entra,nceJ;amp "M" of Interstate 280

. (I-280) to' the east,

I .' I-280 to the south; and

Call1Pbel'l Distribution FOljndry to the west. ,

The land use surrounding the si,te is industrial or open space/wetlands;' the neare§t.resident:ial' area is approximately ,a half -mile bo, the west. To "the south,', ,a Municipal Sanitary

,Landfill Authority (MSLA) laI1dft1l, identified as the "l-D La:q.dfill" is situated souchof I-280. '

The'lS-acre parcel is fenced. The prior site operations took , place on the eastern half of the parcel; ,the landfilled area was

once an access road to the I-D Landfill, and a land~illmound remains from those 'activities that rises 10 to IS ,feet ,above the

,rest of the site. Surface water drains through, a drairiageditch that' eventually discharges'to'Frank's Creek, which in turn, ' '~ischarges to the Passaic River.' '

SITE HISTORY AND ENFORCEMENT ACTIVITIES (

The oil rep~ocessing facility operated under several company 'names, includingPSCResources,Inc., Ag-Met Oil Service, Inc., and Newtown Refining Corporation, 'froJIl 1946 to, early 1979. 'All :of these companies' were owned by Mr. Robert Mahler., During fac'ility operations, multiple aboveground stor~ge tanks and possibly subsurface 'pits\ were useo.tC>,store' oily wastes. These was,tes were ,! ,

intermittently discharged directly ,to adjacent properties, to the east and the wetland area on the south side of the site, creating an "Oil Lake."

In 1976" the New Jersey Department of Transportation (NJDOT) purchased' severa110ts from PSC ,Resources;, Inc., as part of, its,,' ' plans for construction of 1-280.\ 'In 1977, NJDOT removed over 10 million gallons of oil and, oiL-contaminated liquid and over, ' 230,000 cubic yards of oily s'ludge from the area of the oiL Lake.

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The liquid wastes were shipped to waste-oil recycling facilities. The oil-:contaminated sludges ,from the bottom of the Oil Lake were excavated and placed in ,a series of disposal, cells, one atop the MSLA1-DLandfill, and a series of smaller cellswith~n ,the, righ~": of-way (ROW) to the highway, next to the then still-operating oil ­reprocessing facility. The details of these disposal efforts are not well documented, but a, simple liner and a clay::-based capping

,material were to be part of the disposal efforts for -the sludges.' While ,the surficial oil Lake was removed and filled, the NJ,DOT also 'reported finding an "underground lake," of oil-contaminated groundwater extending from the eastern t.imits of the 1-280 right­of,-way' to Frank's Creek, west of the site.

From thetlose of operations in 1979,until 1982~ the abandoned site was not completely fenced. In 1982, during the dismantling of the ,oil reprocessing facility, approximately 7,500 gallons of materials were apparently pumped out of the tank~ and disposed off site, and 27 ton~ of cbntaminatedsoil were reportedly removed from the site'. It was sampling"undertaken during this cleanup effort that first identified hazardous /substances, including polychlorinated biphenyls (PCBs) in waste material collected from the site. Aerial photographs, from 1982 show that the oil ' reprocessing facility infrastructure had been dismantled. The buildings and facilities ~ssociated with'previo)us site operations were constructed on the 'eastern haif oft}-{e site, and some remnant concrete, bui,lding and tank, foundations remain. In 1985, the refinery property was sold to Mimi UrbanDev~lopment Corporation, ,which subsequently changed its name to Hudson Meadows Urbari D~velopment Corporation.

The property sat idle for a numberqf years, ,at least, in part because of the, alleged contamination. EPA 'was asked by NJDEP to evaluate the site for inclusion on the National Priorities List (NPL) ,in 1999. The site was added'to the NPL in September 2002.

In 2002, EPA began, a remedial investigation and feasibility study ',', (RI/FS) to determine the nature and exten't of the problems posed

by the site. In addition to the LNAPL findings discussed below, the R~ found '-soil , groundwater, ,arid' sediment contamination attributable to the site. The RI also intluded a number of test trenches through the landfill portion of the site to assess the nature of the material buried there, and boring~ wer~ collec~ed along the 1-2,80 ~OW berms to confirm the presence of the buried sludges . ,Site studies are ongoing i (or example, new groundwater m'onitoring wells were installed earlier in 2009, on a number of neighboring properties to fully assess the extent of the groundwater problems ,posed by the site. Field investigations for the comprehensive remedial 'investigation of the site are expected

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to be 'complete in 2010, at which time EPA can 'proceed with evaluating remediai alternatives for the entire site. ,

'HIGHLIGHTS OF' COMMUNITY ":PARTICIPATION ,'. ,

Sin~e the Diamond Head' oii Refih~'ry sit'E~;~ placement'onth~ NPL i

public interest in the~ite:hasb'eeI1 i'ow'-',O'n j\lly14,'20'Q9c'EPA released the Proposed Plan 'and ~ilppor'tin~i'd~culTlentation for this Interim Action remedy (OU1),t6:the p iibfic for 60mtTI~nt. 'E·PA ma'qe these documents available "to' ,the" puplic' in ~he-ad~inistrCitiv~< record, repositories mairi1:ained at 'the Ep~'~e(:.#on :i:I office, (2QO Broadway, t:Jew York, New York 1,00(7)', 9,ndthe'Kearny ,Public Library \ . ", \ '.'" .. " '. \ . . 'Q18 Kearny Avenue, Kearny, New Jersey ,07032). ,EPA publi,shed a notice of availabiiity involving these documentSl in The Observer Newspaper, and opened' a public com~E:nt.p7riod, o~ ,the docurnen,ts

( , from uuly 14, 2009, to August 12,' ':iocEi. , ,

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'On July 22,' 2009, EPA, held 'a public meeting at (the K~ar~y Municipal Building, tb inform local officials and interest~d citizefis about the Supe~fGfid'pi6ces~, to'review ~he planned remedial activ'itiesat the Diamond H,ead' Oil 'Refinery s;ite, ,and to respond to'anyquestions fr'om area re's:id~~ts, arid other attendees.'

Re~sporises to the comments r~<;::eived at the J?ublic meeting are' included, in,the Responsiveness Summary ($eE: Appendix V)

SCOPE, AND ROLE'OF'OPERABLE~IT : _ 1

As with, many Superfund sites, ,the problems at ,the Diamond Head Oil Refinery site are complex. EPA has organized the work into two operable units (OUs):

Operable Unit 1: LNAPL Source Area. I

',; Operable Unit 2: Comprehensive' ,site remedy addressing contamina,t,edsoil, sediments and

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The first operable ,unit, the 8ubjecto,fthis ROD, addresses soils, . . ..

contaminated with,high concentrations of LNAPL'that const,itute, a ,principal threat' (" ...source' materials cortsidered to be highly' toxic or highly mobile that generally cannot be· rel'iably contained 'or·

. would present a significant risk to human hea'lth or the Emvirontnent should exposure occur"). This is considered an Interim Action 'to address these prin~i~al threat wastes at the

'site, and EPA expects to initiate this remedy while completing the.

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'. RI/FS that will assess other contamination problems attributable to the site.

The second opera,ble unit ~s expected to address remaining contamination problems for the site, including low~level ~hreat LNAPL (" ... materials that generally can be reliably contairiedand that would represent a low risk in the event ofa release") '. soil.· contamination, sedirilentsand groundwater, along with.addressing . response actions required for the on-site landfill mounds. To understand the difference between, the principal threat LNAPL,to be addressed in this action and the 'low level· threa.t· LNAPL to be., addressed in OU2, please refer to the "Nature and Extentof'LNAPL Source Material" Section on thi·s ROD, below. This. second operable

.unit is expected to be th~ final response action for this site.

SUMMARY OF SITE CHARACTERISTICS

Site Hydrology , j

The' nearest i3urface w~ter body is Frank '.S Creek, and as a result . of 1-280 's construction, all -drainage on the. north side of' the highway now travels by constructed·drainage swale about '600 feet to'the'creek, which in furn discharges to the Passaic River. Prior to the'1940s, the area south of Harrison Avenue was wetland .. Landfilling activities that st§ilrted. in the 1940s began to shrink and divide .the ~etland areas, and the Oil Lake, estimated in 1977 at between six.Jand seven acres,. appears ,to have formed in a remaining lowland area surrounded by properties filled fOr

. industrial, development and. by what wouldbecometl'ie MSLA 1-D ,Landfill. With the. construction of 1~2g0,including th~ placement .of the ROW berms-, an isolated wetlan.d, frequently ponded, rem'ains just south of the former OiamondHead Oil facility.

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Two factors have a significant iIlfluence on the water table at· the ·site. The first'is the presence of wetlands along the southern site boundary" that include areas of surface water, and the second is the presence ofanLNAPL plume· in the southeast corner of the site in the area of the former lagoon. Although lighter than . water, the density of the LNAPL has' the effect of depressing the water table"and ,influenci'rig groundwater flow. Excepting these areas, groundwater is- first encountered at the site under

. 'unconfined conditions at adepth·of one to two feet.belowthe ground, surface.

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SiteHydrogeolo,gy "".

'The strc~iigraphyatthe :sitec0nsists,:ofa~relativ~ly uniform vertical.sequehce of unconsolidated materials as. follows, from top ·to bottom: , ,"

• A highly variable· (inc6ntent~nd thickness) la.yer of anthropogeriic fill across the site, consisting of typical demolition-type debris, inc:luding .woO,d, brick, metal, glass, pJ,astic and concret,e:rn.l.xed.in,.3. matr~x of poorly sorted'fine to' coarse sand -a.nd. gravel' or silt, sand, and graveL - .

J • \ : .. " "C;... A sand unit: about. five.feet·, thick on the western side of the site and pin.ching out u..:nt}l it is not. present em' the eastern side of ~tl:1e site.

( • A siltyclay unit ,:up to el,ght. feet.., thick in sections of the site, . wh:L<;:h appears. to be. conti,nuous . throughout tlie study a:r;ea.

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• A distinctive p~atlayer ofJvarying tllickn!=ss'but consi!~ered continuous across the site.

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•. A si,lt and sand unit appr9ximately' 15 to 20 feet thick beneath, the peat ..

• Laminated silt and clay unit, the full thickness of which was not observed in any ·of the study borings .to datE: (as deep as 50. feet).

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•. Bedrock,· which also has' not been encoyntered t'o date, is reported to be between'114 ,to 138 feet below grade

Shallow .groundwater flow.direction. above the silty clay and peat layers. is consistent: wi th·. surface water . flow directions to the south and west. :tIi the.waterbearing unit below the peat, groundwater flows from northeast to'southwest, consist~nt with regional trends in groundwater flow.

The ongoing RI 'studies will result in a more comprehensive 'understanding of .stratigraphy'andgroundwater. '

Nature and Extent of LNAPL Source Material, /

The RI studies to date have outlined two area,s as potential' source areas where LNAPL maybe continuing to release contamination to the environment:

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'.the former oil reprocessing section of the site'l once containing two buildings, .mul tiple aboveground's'torage tanks (ASTs), drum storage areas, ~nd pos~ibly.underground'pits; and

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• r~mnants of the Oil Lake ,estimatedin 1977 to cover an area of six:to seven acres,located over the southe:r:n section of~ the site and Etxtending ou~side thesite's.fenced boundaries to the

· east and south. " ' .

Curr~ntlYi in the oilproc~s~ing section6f'the site, orily th~ foundations afone buildirtg and two ASTs are.visible. No re!llnants of the Oil Lake are visible , but hist'orical information ,shows that the lagoon occupied the southe~ster~ section of the._siteand \

. extended eastward. Figure 2 shows'theboundary of the Oil 'Lake compiled from historical'aerials of the site.

. -There is evidence of oil contamination in nearly every boring

. installed within th~ IS-acre fenced property and in many borings to the southeast. Because of thH:r "smea:r:'1 6f oil contamination

,across the site, the RI studiesperfO"rmed to date have used the following methods to q.ocumentthe nature and extent:. 6f th~ LNAPL, and to identify the more severely ,contaminated'are'as of the site:

• A geotechnical measurement tool called laser-induced fluorescence :(LIF) allowed for, the subsurface mapping of'borings that contain LNAPL. LIF cahraplaly identify an o~l "fingerprint," including both .extent arid'relative concentr.ation.

• Soil borings were c.ollected throughout the· site down,to ,the laminated silt and sand unit; as much as 50' feet deep, and the pre~ence o~ oil staining or s~parate-phase oil in the 'soil borings was 1. documented. These results were· compared with the LIF sample points to calibrate the LIF data to site-specific conditions.

• A number of monitoring w~lls, meant to measure groundwater · contamination, have th~cknesses offlQating product in the tops' of the wells, with as much as five feet of LNAPL floating in some wells.

'. Samples of contaminated soil, oily wastes and sludges were c611ected and sertt for laboratory analysis to ,identify potential contaminants of concern and to establish an analytical profile

. . . I . · of the LNAPL., '. ...., ..

~sing these methods, several' char'a'cteristics of the LNAPL were . established:

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.' The' LIFstudy' c6Ilcluded't:l1atLNAPL,is pres~,nt, in~the" subsur~ace throughout ,most: :01: the'inves:tigatedare:ai,'''t'hdughthe LIEI showed w~d,e v,ariatior1sin ,the, intens.i,t:.yo,fthe ..I..NA'PL.signal, indicating subs'dintHtivariati6n in concentr~tionacr.oss ,the site." ,',

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• LNAPI..was measure'd in welis in three' areas'ot'the site, one 'in the j fOrmer process area, and' tWo,:~~Ji.th'in the fobtprint of the Oil

, Lake. "These'areas( 'are 'iden'tifi~don 'Figure, 2.·,' " ,'l . .... .... . , .

• ' The :vertical occurrence of LNAPLcan: be further, separated into, t:.wo, depth intervals: (1) at, the wat.er,ta.hie· (approxi'tnately two feet below ground surfacer, 's6metim~s with anextendtid smea;r

. zone in,to~ the sadlrated f iIi - cont~iriii"g . ~aterL;~1ands9.i1 to' about 10 feet bel~w ground sur'face;, and (2) ,as a di!3·t.inct deeper int,erval at depths of 10 to 16 feet· below' ground ,surfac~ within the ·s·ilty/clayey soil. The bulk o~ LNAPL-contaij'ling; soiL is" , locat:.ednear the water table within 'the fill layer~ .

• LNAPL appears '. to contain Illore die~el range organics than ,gasoline rarigeorganics .••. The' following compounds or classes ,of

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, compounds' .were detected l.n, the LNAPL:· benzene. ; toluene, ' . ethyibenzene,andxylen~!3' as. we~las a) number of other volatile and semivolatile(organic compounds (VOCs and SVOCs) consiste~t ' with a petroleum matrix. In addition, two PCBs (Arochlor'-1232

\. and Aroch~or-:-l260)a:nd a variety of. metals, . i'ncluding, lead and " cyaniJde were also identified in ,LNAPL-·zone samples.

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• DespitetI:e large thickness,of LNAPL fQ~nd iri,somemonitoring wells and its relatively high saturation, LNAPL is'extrerriely 'viscous and is rel~tively immobile under ambient gradients.

'This, is indicative of a highly weathered LNAPL" where much of '. ,the, more mobile, components .of the' site releases have degraded or

. already traveled away from the'site, leaving the less mobile fractions. ' '

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• Within LNAPL,: there 'are 'pockets ,of less weathered LNAPL of high , saturation 'th;it present a leaching concern to groundwate'r. These are LNAPLareasthat may be considered 'to present a risk forfeaching contaminants' to groundwater. '

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Principal Thr4:!at.Evaluati9nof LNAilL

Based on the LNAPLstudies performed to date, portions of the LNAPL~re 'mqre mobile,' are like'ly to h?lvea higher, toxicity, and.

,are at a much greater concentration at the site. Thesehigh-level w~stestonrt the "'principcH threat" posed by the site: Having . developed an. understanding of· .the' nature and extent of· the LNAPL,

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the RI ~tudies fUrther identified chara~teristics for the principal threat LNAPL l consistent with EPA guidance.

EPA defines pripcipal threat wastes as ."those source materia.ls considered to' be highly toxic~o~~ighly mobile. that gen~rally cannot be r~liably cQntained or would present a ,significant risk to human health or the epvironment shpuld exposure occu,r. They include liquids qr other highly mob,ile, materials (e. g,~, solvents) or materials that have l1.ighconcentrat;:.ionsof toxic· compounds." By contrast"I--low-level thJ::'eat waptes are·definedCis "those' 'materials that generally call be reliably contained and that would represent a low risk in the event of a'rel~ase. They include materials that exhibit low toxicity, low mobility in the environment, or are near health-based· levels."

The foilowing lines of evidenc~.based onsite~specific data were used to interpret whether the LNAPL sourc~,material at the'Diamond Head site represents aprihc.='ipal and/or a low level threat:

• Assessment of thepresemce of LNAPL. in the' soil' column' through soil borings'and interpretation of LIF ~esults( placing , particular emphasis on LNAPLfound,at. or near the ground surface and, ,th~refore,. posing a direct-conta,ct t.hreat;

• Comparison of LIF results to areas where LNAPL was visually observed in the pore spaces of spil cores collected from soil. borings ,and to groundwater data ,to" indicate where the highest mass of wastes were located, arid where those high:"concentration . wastes. ,were aslsociat~d with elevated groundwater concentrations; and

/• Areas wh~re a measureable thickness of LNAPL was found in monitoring wells and piezometers d~ring RI studies.

Using these lines of evidence, LNAPL dete,cted at the site was separated into areas where LNAPL material is c(:msidered to represent a principal threat(,~ and areas, where. LNAPL can be considered to represent a 10wer~level threat,' arid for which appropriat~measures will be considered during £uture f~asibility

studies. . Figure 2 shows the.areasident~f,ied as a pr'incipal, . threat using these lines of evidence (shaded in orange). Th~

t6tal ~area is roughly 176,000 square feet. ,'ThiS area includes the two areas of the site where monitoring wells contain measurable thicknesses ()f LNAPL (shaded in yellow); The thicknesses of the principal threat LNJ\.PL varies .. ,Based,onan average depth of seven fee't below ground surface, a volume of 45,825 cubic yards, ."

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including2,593c::ubic yards whereLNAPL floating product is 'found in wells, constitutes the principal 'threat LNAPL (outlined in red on Figure 2) .

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A noricontiguous,areawithin cloverlea'f 'of I-280 (also identified' 'on Figu~e 2) appears to meet ;some of the' c~aracter'is~ic's of a principal threat' las described in the FFS, ',but i't' is 'not as' near the 'surface, and grouridw~ter contam:i,.natioriis not as clearly· attributable to this area. Thisarea'is not inc'luded"with:Ln the

,definition of>ct principal threat for this' Interim Adtibn; 'further /' s'tudies of this area 'will be' carried out as 'part. of' the site-~ide '

RI. \

While furthe'r' studiesof'\the (landfilled area D.f (the site are reqUired, the history of site' activities and the,tesi' trenches

" already installed support EPA 's conciusion that the landfil,l is not a' ' of' LNAPL. EPA~'will

, further evaluate the landf'ill

\source

.' as.. .

part of th~ site~wide RI. \

'CURRENT AND POTENTIAL, FUTURE, SITE AND RESOURCE USES " ,

I

Site Uses: The ,

site ,is abandoned aridfence'd off. The site is. included within the, Kearny Urban Enterprise, Zone and is slated for

'commercial/retailredeve'lopmen,t .'

Groundwater Uses: Groundwater underlyi~g the site is considered by , New Jersey to be Class II-'A,(asource of, potable water. EPA has identified groundwater contaminat,ion in shallow wells on and in the vicinity of the site; however, EPA has not found any potable wells or commercial production wel~s in the vicinity of the site. A, more comprehensiVei understanding', of~ grourtdwaterc,ontamination, problems is pa,rt of the ongoing R;r/FS for the, site.' Residences and businesses in the area are cut,rently us~nga municip\al water supply.

SUMMARY OF, SITE RISKS

The focus of this Interim Action is to address light nonaqUeous phaseliqu:id (LN~PL), that constitutes a principal threat at the' site. Theprincipal'threatLNAPL is physically similar to free oil product. Oil products aretoxic'to ecologic;al receptor-sand humans through di~ect contact,' incidental 'ingestion, and inhalation pathways. Potential exposure to'ecological receptors arid humans' from the high-concentration'WAPL that is'present at '

'the site could result in adverse health effects. It i's, . , therefore, important that steps be takem' to reduce or' eliminate the volume of LNAPLpresentat the site. Reducing 'or ,eliminating the LNAPL at the' site would reduce potential e'xposure to free product and is an important, early s,tep in managing thesi te risks; however, it iSI?-<?t expeGtedto, eliminate the overall risks and hazards, to ecological receptors ,or humans l::lecause of residual

11

contamination that would remain on the site. 'This residual' contamination will be addressed in subsequerit actions.and w~ll be accompanied by full, ecological and human health risk assessments.

For the Interim Action, the concentration of specific 'constituents ih the LNAPL were compared to human health and ecological screening criteria to demonstrate that e~posure to the LNAPL exs:eeds EPA's acceptable cancer risk range for human health and' exceeds EPA' s ,acceptable hazard index of 1 ,for human health and ecological receptors (Tables 1 and 2\.

Human Health For human 'h~alth, the tap water Regional Screening Levels (RSLs) that were 'used for the carcinogenic endpoints corr~spond to a target cancer risk of 10-4

., The tap water RSLsthat were used for the noncarcinogenic endpoints correspond toa target hazard

'quotient of 1. As shown in ,:[,able1, a comparison of the data to 'the R,SLs" 34 of the 4'1 compounds exceed the cancer or non-cancer screening criteria,.ofteh by orders of magnitude. Therefore; use of the LNAPL as a drinking ,water supply would ,result iri human health, risks and hazards_,that exceed theupper-:bound of the cancer riskrangecand/or the acceptable hazard, index of 1.

Ecoiogical· The evaluation for potential ecological impacts was completed by, comparing LNA,PL concent:.ratio~s, to the ecological screening vaiues

'that were used in the draft Diamond liead oii p~eliminary , Ecological Risk Assessment ,performed as part of the RI1. As shown in Table 2, the comparison of the'LNAPL concentrations to the ecological screening values indicates that all 6f the detected organic chemicals exceeded available screening ,values. 'A more limited number of inorganic chemicals (barium; chromium, copper, lead, mercury, and vanadium) also exceeded their screening values. These results-suggest that LNAPL could have the potential to adversely affect aquatic life if it should discharge to surface water.

In addition to removing thepotentlal ~xposu:r'e to LNAPL at the site, reducing or eliminating the LNAPL would also limit its pOtential migration, which would aid in'investigating arid selecting a remedy for the remainder of the site.

New J~rsey Guidarice f~r S~di~~nt Quality Evaluations and Water Quality , CriU!ria (NJDEP 1998), ,US Department of ,Energy Preliminary Remediation Goals (PRGs) (USDOE 1997) " ElJA Region III Screening Levels (EPA, 1995), EPA National Ambient Water Quality Cr'iteria (EPA, 2002).

12

1

'.Basedupen the 'results efthe site st;udies to Idate,' as well, as the streamlined cemparisen ef·, LNAPLcencentratiens toprotective human health ecelegical screeningva;Lues, EPA has determined that actual or threatened relea$es ef .>hazardeus substancesfrem the site, if not addressed by theSelectedRemedy,drene ef the other 'active

. measllrescensidere,d, maypr~seht a current er potemtial tl}reat to humap. health and the envireiIinent. .

/ REMEDIAL. ACTION' OBJECTIVES.,

The fellewing r.emedial actien ebj ectiyes (RAOs) fer' the' principal threat LNA~L wastes, address the human health' risks and envirenmental cencerns,atthe Diamend Head Oil site:

• Remeve er treat principal threats, censistent with the NCP, to' t:he'extent practic'able;

• Prevent current and ,future migrat'ien ef LNAPL and asseciated chemical contaminants to' the varieus media at the site includin~i greundwater and seeps, t~ sUl:"face water; and

• Prevent human expesure through·direct centact with the.principal threat LNAPL.

The first two. RAOs are intended to' address the principal threat LNAPL and the centaminatien that may be released frem this material. l'he third RAO is intended to' address risks t6petential future site werkers/users as a result of expesures to' this ' ,material.

REMEDIATION GOALS

This preposed action weuld addresF the principal threat wastes th~t have been identified to' date at the site, thereby,addressing the mest highly centaminated material that, witheut early attentien, weuld result in engeing centaminatien ef currently uncehtaminqted areas. The RAOs,weuld be achieved by attaining the remediatien geals ef no. measurable thickhessef LNAPL in , menitering wells, and no. petential fer LNAPL-centaminated 'seil to' l.each eiland grease to' greundwater, as measured by a synthetic ,pr~cipitate leachate precedure (SPLP) ercemparable test. Because there are nQ F~deral.er State cleanup. standards fer'LNAPL, EE'A

. e'stablished these remediatien geals b~sed upen the texicity and mebility and the principa'l threats to' address this centinuing seurce.

13

DESCRIPTION OF ALTERNATIVES

~ . .'

CERCLA .requires that each remedial .alternative be protective of human health and the environment, be cost effective,· comply with

'other'statutory laws, and'utilize permanent solutions and alternative treatment technologies and resource recovery technologies to the maximum extent practicable.' In.addition, the statute includes a preference for. the use of treatment as a principal element for the reduction of toxicity, mobility or volume of hazardous subsrtances. Remedial alternatives for the Diamond Head Oil Refinery site are presented below.

)

The RAOs identified above are primarily, focused on addressing the' . . I

.LNAPL mass and do not specifically address the co-located chemical contamination fnsoiJ- at the site. Some, though not all of this chemical contamination is associated with LNAPLitherefore, by "­reducing the mass of LNAPL, the Interim Action' would also reduce some,of the co-located chemical con~aminatiop. and,the unacceptable risks to potentiCilhuman and ecological receptors associated with both the. LNAPL and co-located chemical contamination at the site.

While the effects of the selected technologies on the co-located' chemical contamination cannot be quantifie9-at this time, the effectiveness of each alternative is presented in terms of LNAPL source reduction and the technology's potential to reduce concent~ations of othe~ chemicals present at the site.

The principal threat LNAPL to be addressed by this action encompasses two areas (outlined in red in Figure 2), and identified in the FFS report as the "remedial target area." .The thickness of the principal threat LNAPL varies from between six and 12 feet, and at its deepest, appears to have penetrated as much as six inches into the silty/clay layer that underlies the site. The total. volume' of these areas was estimated in the FFS at

J

45,82~ cubic yards.

The RIincluded several treatability studies of technologies that. are commonly used for petroleum-based LNAPL: in-situ air sparging and LNAPL pumping. 'For both technologie~, the viscosi~y of the

·LNAPL was an'impedimentto successful performance; Consequently, neither of these technologies was carried forward in the FFS, although the biodegradation treatment process at work'in air' spa~ging is present in Alternative 2. .

Detail,ed descriptions qf the remedial alternatives can be found in the FFS report.

( i

)

Alternative 1: No Action

, .

Esti~ated.Capit~1 Cost: $0 · Estimated Operation & M,aintenance(O&M) Cost: $0 Estimated Present Worth Cost: $0

)

'The,Super,fundprogram requires thai the "no-action" alternative be considered as a: baseline.for, comparison with the other ~lternati~es. The' no furthe~ ~ctitin alternative does notincl~de any physical remedial measures (beyond. those response actitins already' completed) that address the LNAPL·contamination at'the site.

I

"Because this alternati;~ .wou~d result in contaminants 'remai~ing on ,site above health-based levels,' CERCLA requires that the' site be reviewed every five years. \If justified by the review, re'mediai. actions may be implemented to remove or tre~t the wastes.

Alternative 2: 'On-Site Bio,cell

E'stimated CqpitalCost f $16,080,000 Estimated ~nual Bioceli Operatioris Estimated O&M Cost:

Cost: . $207,000 i $0

Estimated Present Worth . ·.1 ". .

C6St~ $17,340,000 ConstructionJTime: 1 .Year Re~ediation Tim~: 5 Years,

Under this alternative, .the I;'emedial target areas would be isolated with a sheet, pile wall, and the principal threat LNAPL ~reas excavated. Some ,of ~his ciaterial, as discussed more.fully below,_ would be removed~or off:"site disposal. The remaining . excava~ed material would be augmented with nutrients and .bulking agents tbenh.ance permeability and thecondit~ons for biological activity. The area within the ,sheet pile walls would be converted into a biocell by installing piping to supply air and, d,istribute nutrient additives, . along with a collectic;m system for 'air and, wate:;:- that'may accumulate'inthe'biocell. The. augmented LNAPL material would then be- placed in the biocell for treatm.ent, 'and

· capped.

,The b(iocell would require continued operation' of the aeration, nutrient distribu'tion, arid water ,collection syst"E:ms, including collecting and treating water accumulated in the biocell; and

· maintenance of th~ cover, until, the, remediation :goals are'. achieved. The FFS describes performance sampling and final confirmation sampling that would be rrquired Itq demonstrate. that the LNAPLwast'es have been destroyed through !biological.

\ 15 I,

degradation, 'at which'time thebiocell components would be dismantled. TheFFS est,imates that the biocell would require five years to achieve 'the remediation goals.

Areas where a measureable layer of flOating LNAPL product 'is 'found in monitoring ,wells may not'b~'amenable to treatment in the biocell, or may "extend the ,time frame requiied for tieatment beyond the projected five-year time period. Underthis altern~tive, the~e ar~as,would be ~xcavated and transported for off-site disp~sal. Th~se highly contaminate~ soils ,and sludges may need "treatment ~ia etabiliiation to allow for ,transportation. The quantity of material that would not be suitable, for the /biocell cannot b~ determined unti~ the remedial design sta~e; for cost~

-- estimating purposes" the FFS assumed, at a minimum, that the floating product area, approximately 2,600 cubic yards of the 4:;,825 cubic yards within the remedial target areas, 'would be di~posed of in this fashiori. Although addition~l treatability work during the remedial 9-esign will refine the amount of material to be shipped off site for disposal, the volume could be much larger than 2,660 c~bic yards; the effectiven~ss of the pr6cessin achieving cleanup goals within given time periods will be a major factor in this determination. For example, removing a larger volume of material for off -site disposal may r~duce ·the time to meet cleanup goals anti enable more rapid reuse 'of" the site.

Because this alternative would res~lt in contaminants remaining on site above health-based levels "CERCLA requires that the site be reviewed every five years. A, subsequent Record of Decision"will be 'required to "make a 'final determination about the underlying constituents that would remain within the treated soil. If justified by the RIfFS, additional remedial actions may be implemented to remove or treat such wastes.

Alternative 3: On-Site Soil Washing

Estimated Capital Cost: $18,:;60,000 Estimated O&M Cost: $0 Estimat'ed Present

\

"Worth Cost: $18,560,000 Const~uction Time: 1 Year

Under tl~~s alternative: ,the remedial ta~get ~reas would be isolated with a sheet pile wall, and 'the principal threat LN~PL areas excavated. The e'xcavated. material w6uldthen be treated on site using soil washing. The 'excavated soils and LNAPL wastes would be placed ina slprry reactor vessel and "combined with" a washing fluid, a combination of water, Burfactants and co-solvents that would "wash" (desorb or'dissolve) the LNAPL from the soil

, 16

/

"particles., This technologyrequires'-a 'water treatment facility to , trea,t theLNAPL and, contatninaIfts of concern in',the washing fluid

. \ . .' .. ' ",

so ,it cCin be reus'ed. Th~ separated 'wastes from' soil washing w~)Uld be, taken ot.f site for further treatm~ht, and disposal. The" treated soil material wo:uld be testedfo:rcompliance' with tlle cleanup' goals, and returned to 'the excavated areaS. ," " ','

"

TheFFS describes confirmatiori'samplihg required to:derrtonstrate that the LNAP:r., 'wastes have been,rembvedfrom'the treated :Soils'

,'prior to returning the material to the ; exCavation. 'The FFS ' ,estimates that s6il washing could be itnpleme:hted'in approximately one year.

! " I' :. ~

'As with Alternative ,,2, areas where floating LNAPL product is found may not be amenable to' ~()il wash'ing/arId t.his a~ternative ,assumes that these are,as would be excavated, ,treated as necessary ,and ,transported for off-site disposal. For cost-estimating purposes, the FFS assumed that, at a minimum'" the f,loating 'product area would. be addressed 'in this ,fashion.,. ;' ,

,

i , . " . .

BeCause, this alternative WOUld, result in contaminants remaining on site above health-based levels,CERCLA requires that the site be :reviewed every five years. A subsequent Record of Decision will be 'r~quired to make a finarde.termination,~bout ,th¢ underlying constituents that) would remain within the treated soil. If justified by 'the 'RI/FS, additional remedial acti'ons maybe, implemented to remove or treat such wastes. '

Alternative' 4: Excavation'and Off"'-Site Treatment/Pisposal. . \ " .

Estima(ed CCipital Cost: '$19,1450 ,000 Estimated O&M Cost: $0 j

, I /

Estimated Present Worth Cost: $'19,450-,000 .' ) I' .

~onstructlon Tlme: 1 Year "

Under this: alternative, the remedial target areas would ,be isolated) wi th, a sheet, pile wal/I., -anci the principal threat LNAPL areas excavated;' As with 'Al,ternative's 2 and '~, dewatering would be required prior to excavation, and the removed water would need to be tre1ated prior to discharge.' The' excavated material would ' then be stabilized o~ site to allow ~6rtran~portatiorrfor pff­site disposal. The excavated areaswouYd be 'backfilled with clean fiil;,' /

Sampling would be performed during the remedial design to delineat~ the, extent of the remediCil target areas, but no performance monitoring "WOUld be required.\ ,The, FFS estimat'es that this alternative could be implemen~ed' in "approximately ~:me year.

17 t', '

~' (

-Because this alternative would create a "~lean island" in the center of the site, the sheet pile wall would be left in place at the. end of the action .' The excavated area woul<;l be graded to '. create a recharge area that would maint~in a positiv~ gradient from within the' sheet piled areas to the outside tb prevent recontamination of the area by other contaminants of concern.

/

This alternative would not result in contaminant~\remaining-withih the remedial targe~ areas above' health-based levels,as any underlying constituents within the ~xcavate~ area 'would also be removed; however, because this alternative would result in' contaminants 'remaining on site above heal~h-based l~vels, CERCLA requires that the. site be .reviewed every five years. A subsequent Record of Decisioh will still be required to make a fina,l determination about the need for five-year reviews for other areas of the,site.

COMPARATIVE ANALYSIS OF ALTERNATIVES

\ !

In sele<::ting a remedy, ,EPA considered the factors set out il1 CERCLl\ §121., 42 U.S.C. '§9621, by conducting a detailed a~alysis of the viable remedial response measures pursuant to the NCP~ 40CFR. §300.430 (e),(9) andOSWER Directive 9355.3-01. The' detailed analysis consisted of an assess~ent of the individual response measure against each of nine 'evaluationcriteria and. a comparative analysis focusing upon the rE7lative performance of each response measure against the criteria~

\

Threshold Cri teria - The first· two cri teriaare known as "threshold criteria"b~cause they are the minimum requirements that each response measure must, meet "in order to be eligible for se1:ection as a remedy.

1. Overall Pro,tection o·f Hwnan. ,Health and the Environment Overall protection of ,human health and the environment addresses whether each' '.alternative provides adequate protecti,on of human heal th and the environment and describes how risks. posed through. each exposure pathway are. elilTli'nated, reduced, or c9ntrolled, through tr~atment~ engineering contrqls, and/or institutional controls. ' ,-(

Given the limited scope pf ~his action, theremedia~ action / , objectives only consider protect;Lvenes~ of ac;tiqns to address the

principal threatLNAPL \' Site-wide protectiveness will be considered in a subsequent decision document. The no action alternative is not co~side;red protective because it does nothing

18

(

. to mit,igatethe.LNAPL as' ac'ontimiing sourc!= qfcontamihationor , aSIa. direct,con,ta,ct ,threat' .....

, r' .. ! .:', ' ", \, 1 ".~. ~ j . "

A1tel;'n2!.tive I, the "No ,Action" alternative; is not protective 'of '., human,:health ,and the environment~ The retna:iningalt~rnatives are .co~~d.<iereci;<protective, because they remov~ the LNAPL through tr~~tment of off~sitedis1?dsal.,'·~ ,

2 . . 'c~mpliancewith appl.icable or r~levant and,appropriate requirements .(ARARs) . '" . '. '.

section J..21(d) of CERf:LA and NCP'.§300. 430 (f) (1) (ii) (E) requ~re that ,remedial' actions at;; CERCLA sites at least attain ,legally . . . applicable:· or. relevant. arid" appropria te 'Federal· and 'Statee., . req}lirernents, standards;' cri teria',and limi tationswhich aie' ' . 90iif;ct,ively refen::ed to as "ARARs,1/ unless such ARAR,sare )waived under CERCLA section 121 (d) (4). Applicable req]lireIllent:;s are those'. cleanup,standards, ,standards 'of control, and other substantive requirements, ..criteria, or limitations px:omulgatedunder Federal environmental or' Sta'teenvironmental or-facility siting laws that·· specifically addres~ a·.hazardous $ubstance, pollutant,' contaminant, ~emedial action, ,location, or other circumstance found at a CERCLA site. Only those State stanqards t'hatare iaentified; by a state in a 'ti;melymanner and that ar~ more . ·stringent~han,Federal) requirements may be·applicabie. Relevant and appropriate requirements are those cleanup standa;r(js" standards 6f control, and other substantive requir.ements." criteria, or limitations promulgated unde'r Federal environmental or State environmental or faci.lity f3i,ting laws that, while not

<"applicable" to a hazardous subs'tance, pollutant, contaminant, r'emedialaction,' location, or other circumstance at a CBRCM site address problems or sitlla'tions sufficiently 'similar to those encountered at the CERCLA site that their use is well-suited to \. the particular site. Only those ,State. standards that are i

identified ·in a timely manner and are more stringent 'than Federal requireme'ntsmay be relevant and appropriate: '

. ':1 .. " • ' ...... , " . ,

Compliance withARARs p.ddresses whether at remedy will ·meet all of ;the applicable or relevant;: and appropriate requirements of other Federal and State environmeptal ·statutesor provides a'basis for an ,inv~ki.ng wai ver.

Alternative .1 does riot comply with ARARs. A+ternatives 2, )'and 4 are expected to ,satisfy applicable or relevant and appropriate

'requirements (ARARs)· that pertain.' to the principal threat LNAPL 'and comply with the substantive requirements of 'the applicable, laws and regulations. EPA has developed site-specific remediation, goals that are ccn~istentwith' the expectations of the New Jersey

19

Technical Requirements for th~ remediation of fre~ product (N .J,.A. C7: 26E-1)' . The, Resource Conservation and, Recovery Act (RCRA) , 40 CFR 261, is applicable tor as'sessing the disposal requirements of potentially hazardous solid wastes, such as the LNAPL-contaminated soils. Based upon the available documentation,

\ '-- . . EPA has concluded that ,the LNAPL wastes are not listed hazardous

, waste, nor/ do they exhibit hazardous characteristics ithe.refore, they are not e~pected to require treatment to meet RCRA'Land DiSposal R~strictions.

It should be noted that the active alternatives require the' ':­disturbance of the on-site wetlands. Restoration of the wetlands. is not included in thesealternat±ves, as a significant full-scale remediation effort is expect?ed to follow this Interim Action. Therefore, wetland restoration will need to be considered as part of the overall remediala~tion for the site.

,Primary Balancing Criteria - The next'five criteria, criteria 3 through 7, are known as "primary balancing cri teria ". These,

,criteria are factors with' which tradeoffs between response' measu~es are assessed so, that the best option will be chosen, ; given site'-specific data' and' conditions.

3. Long-term effectiveness and permanence A similar degree of long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to maintain' reliable protection of 'human health and, the environment over time, once clean..:up levels,have been met. This cr:iterion includes the consideration of residual risk that will remain on-site following remediation'and the adequacy and reliability of controls.

The No. Action alternative offers no long-tepn effectiveness or permanence. For Alternatives 2 and 3, t.he potential risks from the principal threat LNAPt would be reduced, although both alternatives can ,be expected to ',leave some· residual LNAPL' in the remedial target areas~ Alternative 4 eliminate~principal threat LNAPL within the,remedial target areas.· As discussed earlier, this action only addresses LNAPL that is considered a principal threatiunder all'the ~~tive alt~rnatives,lower-Ievel thr~at LNAPL would remain on other areas of the site.

other than water from biocell dewatering during operation, no treatment 'residuals are expected froqi Alternative 2. Treatment residuals, in :addition to water from dewatering,' 'are expected from, Alternative 3i the concentrations of principal threat LNAPL and

20

r,

assoc,iatedc,contaminant's' are expect'edt'o' be high in these -residuals (e'. g. " fi1.,t~r cake a.nd;blo\'jdown water frOm soil, wash'ing). The residuals from Alternative 3 are assumed to reqUire 'off-site ,treatment' and,di,sposa:L.:' There are no treatment residuals' 'for Alternative 4,' as this alternative: involves the excavation and off~site ~isposa~'of,ali,thewaste.

'ForAlterna:tiv~s 2 qnd. 3, ;,~a:t tl;te-end~f theO

implementation:p~riod',.' "" : ',', ,'"1 . . . .' .-... "..-.

an isolation bar'rie~ would notpe needed around"the" treated soil, as 'the treated soil is 'expect~d'to be,qf similCir characteristics t,o the surrounding)30il, i,ncludipg some rE:!sidual LNAPL and some underlyingc'onsti tueritsthat wouid not be tr~ated.

,Under \ Alternative:4,'ahii301ationbarrier arou:nd th~ perimeteF of' the 'remedial 'target areas would'need'to'be maintained between the new backfill and· thesljrrouilding soil. This isolation barrier. would be needed as theremediatedarea is expected ,to coritain rio LNAPL and rio other contaminants compared to the surr6und~ng sOil. The surface would n~ed,J::o b~ graded, to drain clean surface water toward remediated soil,su..chthat ,there is a sl~ght positive gradient from withi~ther~media:l target areas 'to the outside. Thus ,,: while Alternative 4 prov.ides more long-term, permanence by ad?ressing'allthe ~LNAPL and all 'the ,underlying cons1?ituents not treated by Alternatives 2 and3~ it. achieves a level of ' remediation - a "clean island" in tbe ~iddle of still~contaminated soils -:- that requires more rigoroB-sefforts ',to maintain.

:4. Reciuction, of toxici ty I 'mobility I or volume Reduction of t'oxicity; mobility,. or volume through treatment refers to the anticipated perfo~mance of<t.het~eatment technologies that may ,be included as part of a,remedy.

,-Alternative 1 provides') no reduction in toxicity, mobility or. volume-.Alternatives 2 and 3 'WOUld reduce the toxicity,mobiiity and volume of ,the contaminants in the remedial target areas through treatment. For ,Alternatives 2 and 3, the treatment is permanent. '

Alternativ~ 4 does not use treatment - rather, the toxicity and vohime are transferred ,from the site through off-site disposal. However, the removed water" would need to be treated pt:lor to discharge, and the 'excavated material would then be; s'tabilized on site to allow for transportation for off-site disposal.,'

5. Short-Ter.m Effectiveness Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse impacts that maybe posed to

" 21

·workers, the community and the. environment during construction and operation of the remedy until cleanup levels are achieved.

There are no short-term effectiveness issues ·associa.ted with the ,No .Action alternative. Alternatives 2, 3 and 4 involve excavation, and would therefore present some short-term risks to the community (dust, emissions, soil 'erosion) ihowever, these risks can be controlled through engibeering controls such as soil erosion controls, dust suppressants, and'the implementation of' spill prevention andrespons~" procedures. Risks tp workers during, implementation also can.be controlled through' standard health and sai:etyproceciures and the use of personal'protection. As noted ea:rlier" there are no residences within half a mile of the site. Short-term conce'rI:1s would relate tb any potential adverse impacts t~ 'industriai and ,commercial I?-eighbo,rs. Given, the' setting,these effects should be very minimal.

Short-term'risks associated with Alternative 4 ,would be the greatest because of its larger transportation component (both contaminated soil and clean backfill need to .be transported from and to the site);' The short-term risks are expected, to. be the lowest for the biocell coqstruction and op~ration.

This Interim Action will be the first of se~er~l remedial actions for the sitei,therefore, one short-term consideration would be

·whether this action delays or otherwise limits future remedial '··decision-making, Alternative 2 appears to pose the highest likelihood of influencing future remedial planning because of i,ts

'\...

longer bperationa'l phase. ,The biocell'may also take additional .' time, beyond the projected five years in the FFS, .to reach the remediation go~ls, and a longer time pe~iod may interfere w~th other remedial planning or with the timely reuse of the property. A~ discussed above I 'under LoIig-Term Effectiven,ess and Permanence, Alternative 4 poses the plausible scenario'of a "clean island" within an area with a long hist6ryof industrial use, where a

. .'. . )

future remedy may need to choose to edtherto maintain this cleaner zone at high expense, or allow it to be recontaminated.

I

6~ Implementability Implementabilityaddre,sses thetechnica,1 and. administrative feasibili ty of a remedy from design through c:onstru'ction and operation. Factors such as availability of services and materials, administr~tive feasibility, and coordination with other governmental entities are also considered.

There are, no implementability issues associated 'with the No Action alternative. ,Alternatives 2, 3 and 4,are considered implementable from a constructability perspective. Possible challenges common to

22

all three, alternatives include the difficulty of' installiqg) ,sheet piles in clayey' 'soils', -excavation:dewatering and water treatment, phasing, cell constrllction, ,and uncertainties in the depth j:o, and variability of the native clay layer. .

. Because of the c()mple~ities of the equ.i.pmentand proc,ess, ,the soil' washing technology is expefted to have a' ,high~r potE!ntialfor delays associated with equipmehtproblems.Portions of the principal threat LNApL soils are clays ando~ly wastes,that will pose ~ignificant materialsh~ndl{qg challenges,; therefore, . 'preparation of. m~teriaJ.. fc:>r placement in the '. biocell and' fo!:" the feed, t6 the s6il washing proc'ess is. critical for both·

'alternatives, although ,probably more.so for the soil washing,~' ) ,

process. As described in Alternatives 2 and 3, the most highly concentrated areas of thes'ite,where floa,tingproduct is found, Gannot likely be tre~ted through either the biocell 6r through. soil washing, and.would·ne~d.to be transported 6ff site for disposal. .

Equipment and sp~cialists are commercially, available, and. . sufficieqtly proven for all three alternatives, although £ewer ,vendorsar~ avallable for competitive bidding· for the soil washing technology. .

None of the alternatives:present any administrative challenges.

Alternative 2 would require operation ove'r a longer period (five years of operation are es'timated) 'than.Alternatives 3 and 4. The remedial activities. needed for this alternative during ,the five­year operations period are routine, and failure of a component oe the alternative is not expected to result in arty significant threatstopublic'health or the environment.

. . .' "

7. Cost Includes estimated, capital and O&M costs, and net present worth

'value of capi tal .and O&M costs.

The estimated present worth costs of" Al ternatives 2, 3 and 4 are $11.3 million,. $18.4 million and'$19~5 million, respe~tively~ 1here are no costs associated-with Alternative 1.

Modifying Criteria'!:' The final two evaluation criteria,' criteria, 8 and 9, are called,' "modifying cri teria II because new information or .comments from, the state\ or the communi ty on the Proposed Plan may modify the .preferredresponse measure or cause another response measure to be considered.

23

8. State acceptance Indicates whether based on its review of the RI/FS reports and the Proposed Plan, the state supports, opposes, and/or has'identified any reservations ·with the selected response measure.

('

The State of New Jersey concurs with EPA's Selected Remedy in this Rec6rdol Decision.

9~ Community acceptance Summarizes the public's general response to the response measures described in the Proposed Plan and the RI/FS reports,. This assessment includes determining which of the response measures the corrununity supports, opposes, . and/or has reservations about. \

EPA solicited input from the community on ,the remedial response measures proposed for the site. Oral comments were recorded from attendees of the public meeting. No written comments were received. Appendix V, The Responsiveness Summary, addresses all the comments received.

f,

PRINCIPAL THREAT WASTE /

Contaminants fo be addressed by this ROD have b~en identified as "principal threat'.wastes" f6r reasons described in the "$lite Characteristics" section, above.

SELECTED REMEDY '~,

Based upon consideration of the results of the site investigation, the requirements' of CERCLA, the detailed I analysi's of the response measures, arid public comments, EPA has determined that Alternative 2, On-:-Site Biocell, satisfies the requirements of CERCLA§121 and the NCP's nine evaluation criteria for remedial alternatives, 40 CFR §3 00 .430 (e) (9). '

The. Selected Remedy described in this document involves the excavation'of the LNAPL source areas, and' construction of anbn­site biocell for. treatment of wastes, coupled with off":site disposal,of the most highly contaminated areas of the excavated material.

The maj or components of the . selected re'sponse measure include:

-Isolation 6fthe remedial target areas with cut-off walls, andexcavat'ion of the principal threat LNAPL areas, a total .of, approximately 45, $25 cubic yards of material i

24

(

\ )

• For the highly contaminated- portion of. the' excavated material that is not amenable tp on~site ~~eatmenti transportation a~d off '-site disposaL facility -:(with treatment.' as required to meet lal1d disposal requirements);

, ,

• For the lesser contamin'atedLNAPL material amenable to on­site treatm'ent, construction of a biocell within the

'excavated C;l.rea 'to facili tat~~ biodegradation ,of the LNAPL ' wastes, includi~g the ,i~stallationof piping/fci~ air and nut,rient "distribution and a collection syste'm for air and watei th~tmay accumulate in the biocell;

. J

\

• 'Introduction of nutrients· arid, bulking agents to the lesser ' contaminated ·LNAPL material to enhance permeability and the conditions for biological activity; followed by placement of this augmentedLNAPL,material in the'biocell for treatment and capP,ing; and

• Operation of the-aeration, nutrient distribution, and water ,collection I:!ystems for ·the hiocell for an eS.timatedfive-year period; and

.,Performance sampling 'and final confirmat'ion sampling to demonstrate that trie LNAPL wastes have been dest'royed through bio.logical degradation, at which time the biocell. components will be dismantled.'

The Selected (Remedy Was chosen over other' al ternatives because' it' is expected to achieve ,substantial and iong-t~rm risk reduction through on~sitebioremediation, and is expected to be consist~nt with the reasonably anticipated future'land use/ which:is commercial/retaiL The Selected Remedy reduces the risk within a. reasonable time frame,.,at a cost comparable to other alternatives and is reliable' over the long term.

l -'

T~e Selected Rem~dy will achieve the remediation'goals that,are protective fo;- the principal threat LNAPL, but a subsequent decision ,is .still necessary to address the, underlying ,constituents within this material'. Thus, the need for 'institutional controls.',.· , . ~' ..

such as a deed notice or covenant, would be determined as part of a future remedy.

Consistent with EPA Region 2's Clean and Green Policy, EPA will evaluate the use of sustainable technologies and practices with respect to anx- \remedial alternative selected for the site.

'25

/

STATUTORY DETERMINATIONS

As was previously noted, CERCLA § 121(b) (1) mandates that a remedial action must be protective of human health and the environment, cost-effective, and utilize permanent solutioI'l:S and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Section 121(b) {I) also establishes a preference for remedial actions which employ

. treatment to permanently and significantly reduce the volume, toxicity or mobility of the hazardous substances, pollutants, or con~aminants at a site. CERCLA § 121(d) further specifies that a remedial action must attain a degree of cleanup that satisfies

," . . ~

ARARsunder federal and·state· laws, unless a waiver -can be justified ;pursuant to CERCLA § 121 (d)· (4) ..

Protection of Human Health and the Environment

The Selected Remedy, Alternative 2, will be protective of human .. . . \ ­

health and the environment and is intended to provide adequate protection until a final ROD is signed through the remediation of .LNAPL source areas that constitute a princpal threat-waste and are both contact hazards and contribute to groundwater contamination.

Compliance with ARARs

·The ,remedial action will comply with all federal- and state requirements that are .applicable or relevant and appropriate"

( (ARAR) to i_ts implementation. A comprehenSive ARAR discussion is included in the FFS and a complete listing of ARARs is included in Appendix II, Table" 3 b~ this ROD. .

\ '

Chemical-Specific-:-ARARs There are no chemical-specific ARARs for the LNAPL ,source areas that are .the·subject of this action .

. I

A,ction-Specific ARARs Based upon the available documentation regarding the source of contaminatiorf and sediment testing, EPA has concluded that the LNAPL source areas are neither listed hazardous waste or eXhibit hazardous characteristics, 'and,· therefore, do' not require treatment to meet RCRA Land Disposal, Restrictions prior' to disposal in a RCRA-compliant unit. Further testing prior to land disposal is still required as part of.the

. remedial action ..

Action-specific ARARs will be achieved by conducting remediaY action activities in accordance with OSHA, RCRA, New Jersey hazardous waste regulations, Ne~ Jersey Soil .Erosion an.d Sediment Control Act regulations,

26

. :/.. ~. .' :" .... ..,!

Location-Specific ARARs Lecatien-specific ARARs "

will be achieved 'bycenducting 'remedial,' actien-activities ',in accordaI?-ce' wit'h the National Envirenmental- Pel icy: Act, specific'allywith regard to. carrying out Executive Orders 11988, (FloodplaiiiManagement) and ' 11990 (,pretectien'of Wetlands); amlN.ew Jersey stattibes' gov~rnihg'

"floedplains and,protectien ef •wetlands. "

. '. . ~ '. - .Cost Bffe~tivenes~

In'~ the lead ,agency's, judgment';, the Selected Remedy, is cest­ef(ectiiveand"represe,ntsa reasenable vallie fer the money' to be'

", spent:,.::i:n making this determinatien, thefollewing 'definit'len was used: "A r~medy shall pecest-effect'ive: if itsco,sts are " p~oportienal tejts everall effectiveness." (NCP §300. 430 (f) (1) (if) (D) ). ,EPA evaluated the "everall effectiveness" ef these alternatives that satisfied the thresheld criteria (i.e., were beth pretective ef human health and the 'env:j.ronmez:it 'and ARAR­cempliant}~, . Overalleffectivenesswas evaluated by aSE3essing' , three ef the fiv.e balancing criteria in combination (leng-term

,effectiveness' and permaneilce; reductie~,intexicity; mebility, and ,/

volume'threugh treatment; and shert-term, effectiveness)., Overall' ,effec,tiveness was then cempared to. cests to. determine ~eSt­ef;Eect,iveness. The estimated present, werth cost ef Alternative 2. is $17:3 million, fer Alternative 3· it is $18-.4millien, 'and fer Alterna~ive4 it i8$19.5 millien. "

For a detailed cost summaryef Alternative 2, see Appendix-II, T.able 4,'efthis decument.

Utilization of ,Permanent, Solutions and Alternative Treatment Te.chnologies

,\ Although thi~ interi~ action is net intended to. address full~ the statutery ~andate' for permane'nce ard treatment to. the m~imum extent practicable, this interim actien doe:,s 'utilize treatment and,' thus supports that statutory m~ndate. Of thesealt.ernatives that'·,

'are pretective ef human 'health and·the envirenment and cemply with ARARs to the extent practicable, EPA has determined that the Selected Remedy prevides the best balance'of trade-offs 'in terms ef the five balancing criteria, while also. censidering the statutery 'pref'erence fer treatment as a principal element" ,the bias against, off-site treatment and disposal, and State and communi ty acceptance. I-

I

27 '

J , )

Preference for Treatment as a Principal Element

The ,selected, Remedy meets the statutory preference for ~he' use of remedies that involve treatment as a principal element.

Five~Ye-ar 'Review Requirements'

, Subsequent acti<;:ms are planned to address -"

fully the threats posed' by conditions at this site. Because this remedy will result'in hazardous substances remaining on site a:pove health-based levels, /

a review will be conducted to ensure, that the r~medy continues to provide adequate protection of human health and the environment within five years after commencement of, the remedial action. ", Because this is an Interim Action, review of this site and remedy will be ongoing as EPA continues to develop remedial alternatives for the site.

DOCUMENTATION OF SIGNIFICANT CHANGES

The 'Proposed Plan for the Diamond Hea;d Oil Refinery site was released for public comment on JU'ly 14, 2009., The comment period closed on 'August 12, 2009.,

The Proposed Plan identified Alternative 2, on-site Biocell, as EPA's selected aJ,.ternative. EPA reviewed all verbal comments submitted during the public comment period. No written commeptswere received.

28

I,

APPENDIl<.I FIGURES

. \

Source: Ha9sti'om Union/Hudson/Essex County Atlas, 1990

Hudson County, Page 5, Grid C-7

t~

~ AA - ~ --- 4 '

_---­ -='--­ r ~- . -'~ ---­-

Figure 1 - Diamond Head Oil • Site Location Map Vacant lot Adjacent to 1235 Harrison Avenue Keamy~ NJ 07032 (Hudson County)

see AI$O: USGS 7.5' Quadrangle: Elizabeth, NJ: PIIo\Ofevlsed 1~1 400 44' SO" lat. 74° 01' 55 .9" long. (NAD 83)

o 87.5 175 350__c===____ Feet

Figure 2 Proposed Remedial Target Areas

Diamond Head RifFS Keamy, NJ

CH2MHILL

APPENDIX II TABLE$'

/

. ,.

\

. "

\.

'",

~Table 1 Comparison cif lNAPlCo~centr~tlonstoHuman Health Screening Level

.. Diamond H~ilaOIl RifFS· .

, )

(

)

Shadlng'indk:ates concentration exceeds screenitig value Data QuaUfiers and NOles on Data

U The compound. was not detected at the indicated concentration.

J Data incUeatss the presence ot a compound t~at meets the jdentifacation criteria. The re5uft Is Jess than the quantitatoo limit but greater ~an zero. The concatratton given is an approximate vatus. ' . B The analyte was !ouOO·\n the laboratory blank as weH as Ihe sample. This o Resutt is !,om diluted analysis

NA Noi analyzed. DllOOicates '8-analysis ,Iollowtng dillutlon Screenlno leyels and Notes Tap Water RSL is trom Regional Screening Level Tab)e, 5119/2009. RSl based on carcinogenic.endpotnts (c on table) adjusted to a target cancer.r:isk 0!10~ (by muttlplyi"g value on table by 100) .. n • noncancar c .. cancer c·;" cancer, where n Sl'< 100 X c SL NSV • nO screening value

Pyrena RSL used as surrogate tor acenaphthylehe and phenanthrene.

.l

Page 1·01 1

Table 2 Comparison of LNAPL Concentrations to-Ecological Screening Levels

Diamond Head Oil RI/FS

\

/

Shading indicates concentration exceeds screening value

Data qualifiers and Notes on Data

U The c.ompou~ w~ not detected at the indicated concentration.

J Data indicates the presence of a compound thai meets the identification criteria. The result Is less than the quarititation limit but greater tha~ zero. The concetration gtve~ is an approximate value.

possible laboratory contamination of the environmental sample.

D Result Is from diluted analysis

NA No1 analyzed. OL I~d!cates re-analysis followl~ dJllution

Screening levels aDd Notes • - New Jersey Guidance for Sodim&nt Quality ~valuation'lIfId Witar Quality Oiteria (NJDEP 1998)

b< US Oeprnant of Energy Preliminary Remediation' Go. {PRGa} (USDOE 1997) c: - U~EPA R~gion III Screening levels (USE~A, 1995)

d. USEPA Natiol\al Ambient Wotar Qu"'ty Crilllria (USEPA, 2002)

NSV - no saeenlng '1M

Page toll

j

\ Table 3 Potential Chemical-Specific Applicable or Relevan~ and Appropriate Requirements Diamond Head Oil Superfund Site, Kearny, New Jersey

-DIAMOND HEAD OPERABLE UNITfFOCUSED FEASIBIUTY STUDY

Act! Authority , Criteriallssues Citation Brief Description Applicability Comments Resource, Identification and 40 CFR 261 Defines those solid wastes which ARARfor wastes or,treatment Ap"plicaj)Ie,.'for'thed!sposiil.of Conservation and Recovery I\ct .

Listing of Hazardous Waste

art! subject to regulation as ,,' hazardous wastes under 40 CFR Parts 262~265 and 270. '

. ;'-, ",

residues which are hazardous as ,defined by RCRA and are to be disposed ofoff-site •

haiard6us'S()lid lNastes(lNAPl hnpa~tecl so"sr~nd LNA~!-i.npacted groundw~ter,or'groundwater that 'meets'thehaiardous:w'aste,

,characteristictlir~shoidS·. State of New Technical 7:26E-1 Require removal or treatment of A'RARfor the remediation of the Approvalfor the, onsite,~i6~~U '., Jersey requirements for recoverable lNAPl where lNAPl. alternathr.e requires.approy~ls I Statutes and remediation of ,free practicable; treatment oJ.residual coordiriation withNJ'sSite' " Rules product. LNAj)L'where practlcJlble; ,,' RerrieciiaiioiiProgi@1l1(SRP)~togain

containment ofpotentially mobile , ,approval to 4sethe .ons,!t~bi<>cell ' LNAPLwhere removal or treatment techrfology~~heeffectiven,essof ;the

, are not practicable; method must ~Ctemo'ristratedand docUment~d·fo.. th;e$RP. - -,

.': .': ~\, i~', ". ~ ..: , . . :."'

State of New J~rsey

Groundwater Quality'Standards

N;J~A.C. 7:9-6 Groundwater,

Establishes -standards for the protection of ambient,groundwater

ARAR for Class IIAaquifers. This' is~;{;" ttaiJy'~ctionfoC~~iCl9'OO add..e~s.ing·LNAPL..TheSe stllnchirds

Statutes and Quality quality. lJsect ast/Je primary basis woUIc:l)je-'applieable tothefinaf ", , Ruies' Standards' forseHing'numerical criteria for remedy for the, site. While there are

groundwater cleanups. no numeric soil criteria for LNAPL, :" these criteria were used to, develop PRGsJortheearlYaction.

Prohibition of ' Air Quality , N.J;A.C.7:27-5 Prohibits airpollytion and Potential ARARfor remedial, Provides the air-quality and odor Air Polmtion Standards' and establishes ambient air q'uality ahernatives which include standards associated with potential and Anlbient N.J.A.C.7:27-13, standards technologies that result In odors emissions from aeration activit/es Air Quality and air emissions; associated with the on site biocell Standards technology.

PAGE 1OF12

DIAMOND HEAD OPERABLE"UNIT 1FOCUSED FEASIBIUTY STUDY

Table ,3, Action-Specific Applicable'orRelevant and Appropriate Requirements Diamond Head Oil Superfund Site, Kearny, New Jersey

Act/Authority :-CriteriaJlssues' Citation Brief Description Applicability Comments Discharge of.Groundwater or Wastewater Federal Clean General Water Act Pretreatment

Regulations for Existing and New Sources of Pollution'

Water Treatment and Disposal Effluent Limitations

Toxic and Pretreatment Effluent Standards, New Jersey State of New Jersey Statutes and Rules

Kearny Municipal

, Utilities' ' , Authority

(MUA) Passaic Valley

, Sewerage' Authority (PVSC)

Discharge requirements

Pretreatment standards for discharge into 'POTWs.

Groundwater Quality Standards

Receives wastewater in South Kearny and the Meadowlands Area' Receives wastewaters from t~e Kearny·MUA

40 CFR 403

33 U.S,C. 1251 Section 301

33 U.S.C:1251 Section 307

N.J.A.C.7:9-6 Groundwater Quality'

, Standards

Local Limits

N.J.A.C.7:14A and PVSC Local Limits

Prohibits discharge of pollutants to a POTW which cause or may cause pass-through or interference with operations of the POTW.

Technology-based discharge' limitations for point sources of conventional, nonconventlonal, and toxic pollutants.

'Establishes \jstof toxic pollutants and promulgates pretreatment standards for discharge into POTWs.

Establishes standards lor the, ,protection of ambient groundwater quality;-Used as the primary basis for seHingnumerical criteria for groundwater cleanups and' discharges to'groundwater.

Establishes the standards for 'discharge of groundwatedhrough the MUA's sewage system to PVSC.

Establishes the standards for the, discharge of waters from the, Kearny MUA into their sewage system.

ARAR. Discharge of pollutants including those that could cause fire'or explosion or result in toxic vapors' or fumes to POTW.

ARAR for remedialactions which Include discharge of wastewater. '

ARAR tor remedial actions which include discharge ofwastewater

'toPOTW. '

ARAR if disposal of treated groundwater by reinjection is needed . .,lso ARAR, for, " groundwater quality at the site. TBC forthis early action.

,ARAR for. the discharge of groundwater to the PVSC.

ARARforthe disposal of groundwater to the POTW, received by direct discharge and by truck load.

POTW ARARs and thresholds supe~sede the Federal Standards.

ARAR requirements to be ' established through permit.

This is an early action focusing on addressing LNAPL. These standards would be applicable to the final remedy for the, site. While there are' nonumeric soil criteria for LNAPL, these criteria were considered to " develop PRGs for the ejlrly action. '

, All but the No Action alternative would require the management of groundwater generated during the

, implementation of the early action. Discharge to a POTWwas selected as the representative process option for managing the generated, ,groundwater. Discharge of the groundwater to the Passaic Valley Sewerage Commission (PVSC) treatment plarifwasconsidered in this FFS.

Discharge can be via a connection sewer or by trucking to PVSC. The nearest sewer .line where the

PAGE 2 OF 12

DIAMOND HEAD OPERABLE UNIT 1FOCUSED FEAS/BIUTY. STUDY

Act/Authority Criteria/Issues Citation Brief Description '. Applicability," , Commentsj

: .

( ...... ,­

connection can be made was identified at the intersection of Bergen Avenue and Harrison Avenue; this sewer line Is expected to be activated later this year. This sewer line Is operated by the Kearny Municipal Authority (MUA). "

A permit would need to be obtained that would specify the requirements, for discharging to PVSC. '\..'

PVSC has discharge limits for metals and oil and grease (average of <100 mgtl or maximum of 150 mgtl). The metal concentrations in groundwater , ,at the site are belowthe-PVSC limits. There is no data for;oiland " grease In groundwater at the site. Therefore, thisFFS assumes that ' some form of treatmi:mt,would be , needed to achieve the discharge limlts'for 011 and grease. The pre­'design Investlgatlon'would collect data on oil and grease and the design woulddetermil18 the need for

, and actual type of treatment for ,oil ' and grease.

While PVSC does not have discharge limits for Total Susper;'ldedSolids (TSS), the permit that would need to be obtain.ed for the discharge may specify alimit. We have assumed that treatment of the discharge for VOCs and other contaminants win not be required and that the permit "

will set the monitoring requirements. Thls,FFS assumes that monthly monitoring and reporting will be required. ' ,

, , <..

DIAMOND.HEAOOPERABU UNIT 1FOCUSED FEASIBIUTY STUDY

CommentsAct/Authority Criteria/Issues Citation Brief Description' . Applicability Worker and Protects workers P.L.1983c.315 Community and community .Y·L.1985c.543 Right to Know Executive Act .Order #161

}-" . - '

Disposal of Hazardous Waste Federal General Waste 40CFR 260 Resqui'ce . - ,Mana'gament Conservation Practices and Recovery

, Act' Federal, Identification and .40 CFR 261 Resource Listing of Conservation . Hazardous Waste ' and Recovery Act

Federal' Standards 40 CFR 262 Resource Applicable to Conservation Generators of ­and Recovery Hazardous Waste Act Federal Standards. . 40CFR 263 Resource ~ Applicable to, .

/ Conservation Transp~rters of . , and Recovery Hazardous Waste

Act Federal Standards 40 CFR 264 Resource Applicable to Conservation Owners and . and Recovery . Operators of Act Treatment,

Storage and Disposal Facilities

Federal' Interim Standards 40 CFR 265 Resource for Owners and ConserVation Operators of and Recovery Hazardous Waste Act Treatment, .

Storage, and Disposal Facilities

Notification of presence of hazardous substances to State Emergency Planning Commissions and to local Emergency Planning

. Committees. '

Estabiishes procedures anderiteria for modification or revocation of '. any provision in 40 CFR Part 260­265.

Identifies solid wastes which are , subject to regulation as .hazardous wastes. .

Establishes requirements (e.g., EPA 10 numbers and manifests) for generators of hazardous waste.

Establishe~standards which apply to persons transporting manifested

. hazardous waste.within the United States •

Establ.ishes the minimum national standards which define acceptable management of-hazardous waste.

Establishes minimum national standards that define the periods of interim status and until certification of final closure or If the facility is subjectto post-closure requirements, until post~losure responsibilities are fulfilled.

ARAR. Applies to all on-site treatment alternatives.

ARAR. Establishes general requirements for hazardous waste management.

- ARAR. Generation of a hazardous waste possibly including spent . carbon or contaminated soil • Hazardous waste must be handled and disposed of Inaccordance with RCRA. Chemical testing and characterizationof waste required; ARAR. Waste that Is. characterized as hazardous.

ARAR. Transport of waste that is. 'characterized as hazardous.

ARAR. Generation and 'storage of hazardous waste.,

, Potential ARAR since remedies should be consistent with the more stringent 40 CFR 264 standards, as these represent the ultimate RCRA compliance standards and are consistent· with CERCLA's goal'of long-term. protection of public health and

PAGE 4 OF 12

DIAMOND HEAD OPERABLE UNIT 1FOCUSED FEASIBIUTY STUDY

Act! Authority Criteria/Issues Citation BrletDescriptic)n Applicability' Comments

..j welfare and the environment:

Federal Resource Conservation. and Re~overy . Act

Federal Resource' . . Conservation, and Recovery Act . Federal

, Hazardous Material·

'Transportation . Act' '. . State ofNew

Jersey Statutes and Rules General' Remediation Comprehensive'

, Environmental .' Response;' .' Compensation, and LiabiliW Act of 1980 and Supertund Amendments and' . Reauthorization Act of 1986 (S~RA)

Land Disposal Restrictions'

, Ha;zard.ousWaste Permit Program

Hazardous Materials Transportation Regulations

Hazardous Waste

National Contlngenc:y Plan

.40 CFR 268

40CFR 270

49 CFR 107, 171-1n

N.J.A.C,7:26C Hazardous Waste

40CFR 300, Subpart E,

Identifies hazardous wastes which are r.e~tricted f~()m land disposal. All listed and characteristic hazardous waste or soil or debris contilminated_bya RCRA . hazaidous waste and removed from . a CERCLA site may. not be land disposed until treated as required byLDRs. . ' . Establishes provisions covering basic EPA permitting requirements •

Regulates transportation of hazardous materials.

, Establishes rLiles t.or the operation of hazardous waste facilities In the state, of New Jersey.

Outlines procedures for remedial actions and'for plsnnhlg and Implementing off-site removal, actions.

ARAR. Gener;;ated waste will need to meet LDRs for offsite disposal.

Potentlai ARAR. A permit Is not required for on-site CERCLA ' response actions. Substa{ltive . reqUirements are\added'in 40CFR 264; ARAR since response ~ction may involvetranspoi"tationof -, hazarc:j()~s materials.

Potential ARARdependlng on hazardous waste disposal location..

ARAR.

(

J .,,'

Provides the requirements for properly documenting al)cj manifesting hazardous and.non­hazardous waste shipments.

Provides the requirements for properly documenting, m~nifestlng, and packaging hazardous and non, hazardous waste s.hipments.

. Provides the requirements for. storing and handling ha~ardous ' waste onsite. '

PAGE 5 OF 12

.' DIAMOND HEAD OPERABLE UNIT 1FOCUSED i"EASIBIUTY STUDY

Act! Authority -Federal Occupational . Safe~yand H~alth Act

State of New Jersey Statutes

-"and Rules

State of Ne";" Jersey Statut.es and Rules.

State of New Jersey Statutes. and Rules

State Of New Jersey Statutes and Rules Stateof.New Jersey Statutes and Rules'

State. of, New· " Jersey Statutes and Rules

State of New Jersey Statutes and J~ules_ _ .

State of New Jersey Statutes and Rules

) . State of New Jersey Statutes and RLiles

.,

Criteria/Issues i

Worker Protection

Technical' Requirements for Site Remediation

Emergency Response Notice

"of Release of Hazardous Substance to Atmosphere Notification of Spills

Restrictions of . Noise .

Investigation . derived waste

management

Restrictions of Noise

General Requirements for Permitting Wells

Well Abandonment Procedures

Drilling Contractor Requirements

Citation 29 CFR"1904

N.JAC; 7:26E ..

NJSA 7:26,~ 26:2C-19

NJAC 7:21 (E)

NJSA 13:1G-l _ et.seq.

NJDEP's Guidance Document

NJAC 7:29-1

NJAC7:9-7

NJAC'7:9-9

NJSA 58:4A-5 et.seq.,

Brief Description Requirements for worker protection and for recording and reporting occ4pation injurie!tand illnesses.

Established minimum regulatory requirements for investigation and remediation of contaminated sites in New Jersey •. Control exposure to air pollution by, immediate notification to the department hotline of any air release incident.

. i

Immediate notification of any' spill of hazardous substances.

Prohibits and restricts noise which ui10ecessarily degrades' the quality

-of life . . Provides guidance on the disposition of lOW.

Sets maximum limits of sound from any industrial, commercial, public . service or communlty'servlce , facility. . . . . ' Regulates permit procedures, . general requirements {or drilling and instal/atianof wel/s, licensing of weJfdrlller and pump Installer, construction speCification, and well casing. General requirements for sealing of all wells (e.g., single cased, multiple cased, 'hand dug, test wells,' boreholes and monitoring wells, abandoned wells). Well drillers licensing, supervision, inspection and sampling ...

Applicability ARAR. Under 40 CFR 300.38, requir:ements of OSHA apply to all activitieswhich fall under. jurisdiction of the National Contingency, Plan. ARAR for all remedial ~ctions.

ARAR for any remedial alternative . having t/:'le potential to.result inan . air release. -I

ARAR for remedial alternatives having pote!'tial for a spill of a hazardOlJssubstance.

ARAR for aI/ remedial action.

ARAR. To be considered during investigation.

ARAR for all remedial actions.

ARAR when installing n~w wells or if ~xistlng wells should require modification.

ARAR if any existing wells need to be abandoned and sealed.

ARAR when additional wel/s are instal/ed. . ,

Comments ./

./J

PAGE 6OF 12

DIAMOND HEAD OPERABLE UNIT 1 FOCUSED FEASIBIUTY STUDY

Actl Authority· . Criteria/Issues Citation Brief Description ~\ , Applicability , Comments . State of New Groundwater Jersey Statutes Monitoring and Rules State of New NJDEP Standards

, Jersey Statutes ' for Soil Erosion and Rules and Sediment·

Control referenced at ,

State of New . Construction '. Jersey Statutes General Permit and Rules (NJG0088323) .

Off-Gas , ' Management·

Federal Clean National Primary Air Act . and Secondary

Ambient Air Quality Standards

Federal Clean Standards of Air Act' Performance for

New Stationary Sources

Federal Clean National Emission Air. Act Standards for

Hazardous Air Pollutants

State.ofNew Standards for Jersey Statutes Hazardous Air and Rules . Pollutants

State of New Permitting Jersey Statutes Conditions for air and-Rules pollution control

N.J.A.C. 7:26-9

N.J.A.C. 2:90

N~J.A.C. 7:14A

40CFR 50

40 CFR 60

40CFR 61

N.J.A.C. 7:27 . Air Pollution Control

N.J.A.C.7:27-8

N.J.A.C. 7:27­22

Groundwater monitoring system , requirements. '

The HUdson-Essex and Passaic Soil Conservation District governs all soil disturbances greater than 5000 tf. ,.

Administered by the Hudson-Essex and"Passaic Soil ConserVation District for soil disturbances greater than 5000 tf. . ,

Establishes emission limits for six , pollutants (S02, PM10, CO, 03, N02, ;ind Pb).

Provides emiSSions requirements for new stationary sources. '

Provides emission standards for 8 contaminants Including benzene and vinyl chloride. Identifies 25 additional contaminants, as having serious health. effects but does not provide emission standards for

, these contaminants. Rule that governs the emitting ~f,

. and such activities that result in, the introduction of contaminants into the ambient atmosphere. Establishes permit conditions for air pollution control apparatus, for minor facilities.

Establishes permit conditions for air pollution control apparatlis, for major facilities, and facilities with operating. permits.

ARAR for any remedial alternative ,requiring groundwater monitoring~ ,

ARAR for excavation activi~. A Soil Erosion and Sediment Control . /

, Plan.'ls required that will-describe the soil erosion controls. .

ARAR for excavati.on activity. Req~:iresthe submittal of a Request for Authority to Discharge Stormwater to Surface,water.

Emission of air pollutants may be Th~se requirements become ARARs , o( concern for some remedial if siteair,emlssions exceed the major technologies~ facility thresholds listed below. This

is not expectedforth'e developed . ARAR. alterl1atives. ., .. '.

• Carbon monoxide, particulate" , matter, Sulfur dioxides >=",100r··· ., •....tons/year ', .. ,. '. .' .....

ARAR. •.. f:,\itrous. Oxides, VOCs, Total' HAP~>=25,tons/year

, • .L.ead"AnyHAP >=10tons/year • , . All other contaminants,except

C02 >= 100 tons/year' "., '.

ARAR. NJAC7;27~8_establishes perlTlit conditions, for-minor facilities. ,The' airemissi~ns thresholds belo~, which. there are nopermiHing and air

ARARif remedial action includes emission controlsrequirement~are a technology that would result in identified ill ~.J.A.C. 7:~7-8,'Tables A··. air emissions. aridB. ,

~JAC 7:27-22establisti~s per~it conditions, for major facilities .. Emisslonsf~omthe ,early action are expected tel be beloW these . . v .

PAGE7 OF 12

-DIAMOND HEAD OPERABLE UNIT 1FOCUSED FEAS/BIUTY STUDY

Act! Authority . Criteria/Issues Citation Brief Description Applicability State of New Permitting N.J.A.C. 7:27- Controls and prohibits "air pollution, ARAR if remedial action Includes Jersey Statutes Conditions for air 11 and 17 particle emissions, and toxic VOC . a technology tha~ would result in and Rules pollution contra.! emissions. air emissions.

Comments ~ thresholds although-confirmatory calculations will be performed during the design phase. .

If emissions exceed the est~blished reporting thresholds for minor facilities, then the operation of the alternative must be permitted under N:J.A..C. 7:27-8. If the emissions further exceed the establishedSOTA threshold values, then emission controls would be required.

To determine If an air permit and emissions controls are required for each remedialalterriative, the· maximum potential emissions must be estiml!!ted @nd compared to the total and individual contaminants thresholds (reporting and SOTA)!n Tables A and B. " If .the emissions are below the reporting thresholds, then a Request for Determination c~ntaining the estimated emissions would-be submitted to the NJDEP to confirm that apermi~ is not required. If the emissions are above the reporting thresholds, then a " permit application must be submitted and the permit would establish the monitoring requirements as well as·needed emission controls for emissions greater than the SOTA thresholds.

Of note, comb~stion equipment less than 1 MM ·BtLiis not required to. be permitted but mustbe noted in the Request for Determination. For equipment greater 01' equal to 1 MM Btu, the emissions must be estimated and Included in the air

PAGEBOF12'

DIAMONDHEAD OPERABLE UNIT 1FOCUSED FfASIBILJTYJSTUDY

Act! Authority Criteria/Issues. . Citation Brief Description· Applicabiiity Comments

, .

.'

Permit appUcation, which will specify administrative as well as emission controls for emlssioils above the SOTA thresholds•.

(' Also of note, the emissions during , excavation and from the soil ' washing operation must also be estimated and included in the Request of Determination if found to be belOW the reportingthresholcis or in the perinlt application if estimated to be above these thr,esholds.

The air pollution control regulations do riot include specific monitoring requirements; the permit would establish the inonitorlng requirements. It is reasonable to, expect tliat monitoring frequency will be relat8d to the total emission's from the early action and how close they are to the reporting thresholds.

During the pilot test for air sparging conducted during the focused Phase 2 RI, It was determined that the emissions frorTI the test were below the reporting thresholds. Operation . of the biocell will Involve low, Injection rate of air sufficient only to maintain aerobic conditions. Backof the envelope calculations are . performed in this FFS to determine where.tliese·e~issions'iall~elati,v~ to the established ti1resholds. ,These . calculations willbe.ver.ified :d~ril')!r' • the design;Y,I~en~etalied emission cal~ulatioils~wlll.bep~rfor"'Etdand the requestfol'deteprlinatiOn ',ora' permit application (as.appllcable) would be prepared :~ndsUbmltted to'

PAGE~OF12

(

DIAMOND HEAD OPERABLE UNIT 1 FOCUSED FEASIBIUTY. STUDY

Acti Authority Criteria/Issues . Citation - Brief Description" Applicability . Comments·. the NJDEP. During the design,

. derailed emission calculations will 'also be performed for other compcinents()f the remedial alternatives that may release VOCs In order to determine the.neeCl for a permital'!demission controls.

PAGE 10 OF 12

DIAMOND HEAD OPERABLE UNIT 1FOCUSED FEAS/BIUTY STUDY

Table 3 Potential Location-Specific Applicable or Relevant and Appropriate Requirements Diamond Head Oil Superfund Site, Kearny, New Jersey ,

Act/Authority -Executive Order Floodplain Management,

Clean Water Act

, Policy, FloodplainslW etlands Assessment U.S. Army Corps of Engineers Nationwide Permit Program Executive Order Protecting Wetlands Flood Hazard Area Regulations -

Flood Hazard Area Control

. Criteria/Issues ' Floodplain Management

Prohibits, discharge of dredged or fill material info wetlands'

Floodplain assessment

Army Corp. of Engineers Permit, Program

Protectiortof Wetlands

Protection of floodplains

Delineates' flood' ha~ard areas

Citation Exec. Order No. 11988 40 ' CFR 2 6:302(b) and Appendix A

33 U.S.C.1251 , Section 404, 40 CFR 230, 231

EPA 1985 Statement

33 CFR 330

Executive Order No. 11990

N.J.A.C.7:13

N.J.S.A. 58: 16A~50

Brief Description' Requires federal agencies to evaluate the potential effects of actions they mllY take in a floodplain to avoid, to the maximum extent PQssible, the adverse Impacts associated with direct and Indirect development of a floodplain. Prohibits discharge of dredged or fill material Into wetlands without a -permit. Preserves and enhances wetlands. '

Provid,es federal policy for the assessment of floodplains and wetlands '

Prohibits activity that a~verSelY affects a ~etland if a practical­alternative that has less effect is available.

Requires Federal agencies to' minimize the destructiQn, loss, or degradation of all wetlands affected by Federal activities. ' '

, Protects flo~dplalns through " permitting requirements for con,struction and development activities

Delineates flood-hazard areas and regulates use. _' •

CommentsApplicability ARAR if remedial activities take place in or near a10D-year or50D­year floodplain.

ARAR for remedial alternatives which involve disturbance to '" ,wetlands.

'ARAR for remedial alternatives that affect wetlands and floodplains.

ARAR for remedial alternatives which havelhe potential to affect wetlands.,

ARAR for remedial alternatives which have the potential to affect, wetlands. '

ARAR If remedial activities a~e located in Or near a 10D- or 500­year floodplain;-

ARAR if remedial activities are In or near a 10D- or'50D-year

A section ofthe Northern portion of the site is within the 50D-year ' floodplain. If the RTA fallswithin this area, applicable requirements Will be met.,' ,

~The RTA encompasses a significant portion of the deli,:,eate,dwetland areas-at the site; This FFS assumeS that wetland areas that are remediated will be created at a different location by the owner of the Diamood Head property. Wetland

'restoration is not includedi., the FFS and if itwill not be undertaken ata different site by the property owner, maybe required and will become part of the final remedy for the site. Same as above

Please refer to comment above on approach to wetland restoration assumed ,in this FFS~ ..

Please refer to comment above on appi'oachto wetland restoration assumed in this FFS.

Ase~tlonoftheNo~hei'n 'portion of the site Is within the50D-year' \ floodplaln~ IUhe RTAfalls within this area, applicableirequlrement~will bernet. ",' '.,', " /, A section of theNorth~rn portion of the site is within the 50D-year

PAGE1fOF12

)

DIAMOND HEAD OPERABLE UNIT 1FOCUSED FEASIBILlTY STUDY

. Act! Authority Criteria/Issues' Citation Brief Description . Applicability Comments floodplain. floodplain. If the RTA falls within'

. , this area, applicable requirements -. will be met. .'.

Wetland .Act Establishes N.J.S.A. . Establishes listing and ' ARAR.Establishes listing and Please referto cominent above on approach to wetland restoration .of 1970 . wetland 13:9A-1 ' permi~ting requirements for. _ -permitting requirements for

.assumed in this FFS.regulated et.seq. ' regulated activities I regulated activities activities

Freshwater Establishes N.J.S.A. Establishes listings and Potential ARAR. Establishes Ple,ase refer to co~inent above on approach to wetland restoration Wetlands freshwater 13:98 ,permitting requirements fat listings and permitting assumed In this FE~.Protection wetlands regulated activities in state requirements for regulated

Act regulated freshwater wetlands activities in state freshwater ­activities wetlands

/.

r

PAGE 12 OF 12

. .'

\

TABLE.4Alteo:utivel . r . CONSTRUCTION AND OPERAnON OF ONSITE BIOCELL

. CO$T ESTIMATE Sm,1l\1;\RY

Site: LoOUon: ....., BueY_r: Date':

0;""""" Hewl 0;1 SupmiInd She

'Ktamy, ~cw!~Y .._:~<'. Fcuibility SNdy (-30% to +50%) :!009" ' JUf)C4 2009

Ahemalive 2 'consulS ofexcavation ell ~Iaminaac.d .uil. COOIItrucUon of an: onsiu: bi~lI, onsite bac:kfillin, ofa.mendcd soil, and opc:raLinn & nuriturinl 'ufthe Gl,]nsuuclc\l hioct.il. f..;.cl.vau:d p.lil from Ihe two areas ~ LNAPL it (uur..! in m-MlitonnllNClt.. wilt be: di.sposeo::I or at an '()If.~i~TsDF.~··nI: project tb"alKwi iJ·....u...;pa&cdLobc 6~. Capital COlts 0C4'Ur in Ycar().1. AnnualO&M Co.15 oa:ur in Years 1.6. PcriodX; emu OccUr in Year 6. .'

:

CAPITAL COSTS: ..

DESCRIPTION

1 MobiHiarionlDemobilization Construction Equipment &. Facilities Sub~iriaisllmplemeniatio'n Pl~s Tcmporm Facilities 'Po"s.t-ConslDJction Submittals SUBTOTAL

2. Pre-Remediation Site Work' Clearing and Grubbing Fencing/Signs/Gates

Con~tructi~~ 'of Se"wer Connection Construction of Wa~~ Connection

i.

Constructjon ofTcmpofary Ele<:tri.c Serrice ( Construction of Temporary Road! and Gravel Lay.Down SUBTOTAL .

.. 3 LNAPL Impacted Soil Excavation Sheel Pile Inslallation

ixcavation and Hauling Transp(irtation and Disposal

Characterization" sampling LNAPL Sheet Pile Removal SUBTOTAL

,4 Building Foundation Excavation Concrete Foundation Demolition Concrete Foundation and Rubb~.e ExcaYiHioo IlI\d Hauling

Transportation I Recycle Material SUBTOTAL

.. . ,5 Onsite Soil Berm Excavation

Excavation.and Hauling Stockpiling .

SUBTOTAL

(, Dewatering Dewatering .tL..eadiate Sump Pumps 2" HDPE Trenching and Piping

SUBTOTAL

7 Wastewater Treatment (for dewatering water) .. ~rchase Treatment System

Equipmeni Repair and pw'ts SUBTOTAL

8 ConstrUction of Bioremediation Cells :

1 I

Sheet Pile Design nnd Installation Excavation and Hauling of itTA SoU·

Stockpile RTA Soil 2" Air.Distribution Perforated Pipe 6" Air Disbibution Gravel Layer / ....

6" Air Distribution Sand L~yer Air Distribution Non-Woven GeotextiJe

, Add~tion of Wood chips (0 Treatment Soil and Place Into 2" Nutrie~t Delivery System Perforated Pipe . 12" Nutrient Deliyery System Sand Layer

~utrient Delivery Sys!C~ Non·Wo~en Geotextile

HOPE Liner Above Nutrient Delivery System Leacha~ Drainage Sand Layer Vegetative Support Layer Seed and Mulch· Mise Valves and Fittings SUBTOTAL

9 Bioremediation Delivery System From Treatment Building to CeUs Steel Building 24' x 24: . I·.

Concrete Slab 28' x 28'x 6" . Electric Installation (480V. 3P. 200A) Sanitation Plumbing Process Plumbing

QTY

11 440

750· 400

I ./

67.110

21.000

2.600 4.160

21,000

400 900

1.440

8.900 8.900

.1.

1.000

129.500 42.400

42.400 5.312 3,273 3.273

353.502

28.408 5.312 6.546

. 353,502

176.751 3.273 3.273

784

VNIT

LS

LS MO Ls

AC LF

LF LF LS SF

SF

CY TON

EA SF

CY CY

TON

CY CY

LS Ff

LS

LS

SF CY

CY Ff CY CY SF,

cY LF CY SF

SF CY CY AC LS

LS SF LS LS

LS

UNlTCOST TOTAL

580.000 580.000 515.000 515.000

5 i.ooo 512.000

515.000_--::75::-;15",.000= 5122.000

s:i.ooo. S33.000 520 58.800

595 571.250 565..... 526.000

525.000 525.000

50.90_..":::5",60",.3,,,99:;;. 5224.449

544

515. 582

5600 ·54

565 S25

516

I.

512 55

513.600 ·S18

5924.000

539.000 5339.456

51.800 584.000

51.388.256

526.000 522.500··

523.040 571.540

5106.800 544.500

5151.300

513.600 SI8.000

531.600

Work plan. health and safety plan, pmnill. cII;, ,;

OfficeIniIcn,~_r.ci~:~r1lcili~,

Su:~" , Auumes 10.. oftbc pc:rimI:ter of the site will require new.fencing. signs.

and~•....~ See~

Estimale '6 in dUck gnvel. ICC ~.

For"; i~~.pprcWnwc~ ft by js ft deep. Vemor quote from RauoComtructiOo. .

Vendor quote from LcwiI Envi:r~. <Bt inchJdcs price of .

stabila..uon.· \ '. . Vendor quoIe indi~ I COfT1KJ5ite 1lUTV1c Per I,~ toni

Sec &S$umpcions.

V~ quote from l...ewis fnvirOfUJEl\Lal.

See'AuumpUOI1I.

P...d.se ofsix sump purl1JJ ~RI AI. SO gpm

lOOO'ofleachaacpipin,. InctudcscQSI (a IrelJdtinSofpipc. MEANS cml..... . .

$44.100 $44.1.00 Vendor-qUOIt from Maple l.eafEnviromncnlal. J~tudes mobi1izaaioo CO&tS.

SIO,OOO_._..:;5,::1O~,OOO= 554,100

S44 55.698,000 j 515 S636.000

55 5212.000 528 5148.736. 530 598.195 520 565.463

SO.25 588,376

'S15 S426,I20 58 $42.496

$20 $3.273 SO.50 Si82;802

SO.80 S141.401 S20 565.463 S30 598.195

S2.500 510.000 . $10.000 SIO.OOO

S8.026.520

. 570.000 S70.000 S7 S5:488

S20.000 S20.000 510.000· SIO.OOO 525.000 S25.000

Sec~tiORl

Assum:$ RTA voJmnc minu:lLNAPL i~taI soils, buiJdin&: foondation. andcoocme rubble and 10. depth 011 ft bgs.

Sec ISSUJ'r1)Dons

Volume==RTA ~ with 0.5 ft Ihickness ofnweri,aI.

Volume==RTA un with 0.5 ft thickness 0( malCriai.

Assumes one la}U below and above ~b~ sandlgnvd la)lCr.MEANS Co.tDolL Assume • tuioo of3:2 (soil: ~I agent). ... .............. Vo~R.iAareawilh \ fithickneuofuaeria.!.

(. .' , . .~ one la)lCt below lind above nutr"ient delivery iystem sand 11)Cr.

Assurm:s enIire RTA to ~ covC:red. 60 millIDPB.

~ 6 in la)Uoveir RTA.

Assumc:s 6 in 1a)U ov~ RTA.

Seed and mulch OVICT ~ RTA.·

Insulalcdbuiktin&:.

W:zre aah ~nfcrced concrete

~ futimo<e

·V~qUOlt:I'rnm~lnfEn~.

Paget 014

TADLE 4 Altemallve 2 COST ESTIMATE SUMMARY CONSTRUCTION AND OPERAnON OF ONSITE DIOCELL Si\e-: Di~ Hclld Oi~ Superfund Siu: o..crl¢"', .. i\llL-maU~ 2 coosi~b nI' l:'l.caVaU4)(\~" coolamin.",",,-, $oil, C('IM~Uoo of IISl on...i\I: hn:..:I1. l)IU.ile b\"ll:t.fitUng of M'Endc:d J.Oit. and \~1n &. LoaiOop: 'K.c..-ny, NewJcr.ey mmiloriftl of the consuucled biocell. Eltalvalcd ~oiJ rrCl~ the two isrcu whL'I'C LNAPLis Ibond in n.HalOring wells will be di"post.-d arid an ,.....e< FclUoih.iliiy Sildy (.30% kI +~O%) otT-lite TSDF. 'n.;' project dunWon ill anticipalCd 10 be 6 )'C1lI'l. Capilal costs occur in Year 0-1. AMluJ O&:M COlts occUr in Ycar, '·6. O.aeYrIIr:" 2009 Period" ~tJ oo.:ur in Year 6. . 0.... June42009

Air Oclivery Blower System I LS 560.400 560,400 Vt.-ndor~ From M.ple ~·~virnnra~. Purc~

Air Delivery Piping, 2" SCH 40 PVC 1.850 LF 550 S92,500 Piping from tfcllUll:~ building to !he Marto(1he perfDrJllal pipm,. 2~ ft \ percell fa-.dc1imy, 670 1\ of,deliverypiprl.Osouthr:fn RTA; 1800. ID

no<1h<rn RTA. ! Nu1rienl Delivery Piping; 1" SCH 40 PVC· 1,850 LF 550 592,500 Same u. above ..

Nuuient Delivery Equipment I iLS . 56,600 ·S6,6OO 500 gallon polypropylene chemicaal (fertilizer) tank wi~ IRnsfer ptnp (10

g~ 40 psi). ~hued

Equipment Repair and Parts Allowance LS $10,000 510,000 Control System wi Switching Manifold LS .S8,OOO. S8,OOO Pl.C based conllill 5)'liccm wilh tclemtlr)'. pmgrammd

IMise Valves and Fittings LS 55,000 . S37,OOO' EIllimale

SUBTOTAL 5437,488

10 Soil Backfill and Compaction Backfill Amended Soil into Cells CY SIS70,800 5566,400 . · Includes emt cifmixlng ~ toil with clle&vlIlor.

19;640 SY Surface gradin,lO ochieve Bppmp'i* lhinage.~urf':lc~ Grading S2.oo S39,280 ~urnesRC-l'lace Excavated Berm 8,900 CY 57.00 562,300 soil reuse, no imported IoU

SUBTOTAL. 5667,980

.II Wastewater Disposal

Transportation I Recycle LNAPL 59,500 GAL SO.60 S35,7OO Vc~ quote from ~Envir~n1al.

PVSC Fee During Construction LS 116,13'1 SI6,m see:ass~tionI

KMUA Pee During'Construction I LS S96,058 S%,058 ,sc:ea.~tionI

Quarterly Analytical Sampling of Discharge Water 4 'EA ~2,OI6.oo 58,064 Assumes anaIy.iJlhroup nP. iwUnft qu.rierty ~linl rrxjuire. I day for 1 people..

Quarterly Report Preparation 4 EA S2,OI6.00 S8,064 AsSumes that it will ~ 24 hours tD prcpI1C:

SUBTOTAL 5164,017

12 Groundwater Monitoring"Welllns[allation 'Groundwater Wells 12 EA S3.000.00 536,000 See WU:UfIlPtions

Wasle.Disposal LS $,10,000 510,000 - SUDTOTAL ,S46,OOO

SUBTOTAL SII,385,250

Contin~ency 25% 52,846;312 Scnpe and bid contingency

SUBTOTAL S 14,231,562

Health and Safety 2% S284:63I' Project Management 5% S711,57~ "

J Construction Management 6% S853;894

Total Capital Costs 1 516,081,6651

Operation and MainteoafICe Costs 14 Biocell Operation

Addition of Nutrients 103,815 Gal S2.50 S259,538 As.Sumc5 20 full nucricna doses (4 lim::s per)al' ofoperasion). s.. assumplioas

Equipment Repair and Pans I LS SIO,OOO SIO,OOO Rental ofmonitorina equiprnml.

Utilities 60 MO S2,OOO SI20,OOO Vegetation mo~ng 30. MO SSSO 525,500 AuuJnes, 1{)1fI(;1UinncedpftmWinBwill~ 10bwrsBlS151hoor

(labbr and eqIlipm:nl) plUl SI00 ID mobillz.a DC' IOtaI S8S0hr0winr.

. Operations and Maintenance Labor 60 MO S8,064 5483,840 Auwnes 2 people. 12 hnI~k operu1ions std.

Monthly Perf~rmance Field Screening Labor 60 MO '$2,016 SI20,960 AswmcI ~ ~Ic. one I;! hr da~month. Annual Analytical Soi~ Gas Samples, 30 EA S250 S7,5OO As.suoa I Saf"I1Jlc from e-:b ofthc 6 cells for S )'CIn. awUl'l.es-s.arJ1lIina:

Clln be combined wi~ routine O&M -=tivities,

Annual Geoprobe Soil Sampling EA' S2,OOO SIO,OOO , ) Assumes on: day of geoprobc per saqtling ev~ assUmes sampling can be cumbined with rootinr: O&:.M activities.

Annual Analytical Soil Samples 30 E~ SI20 53:600 · 6 Saunples (1 fi'om each ceil) per)nl'" fOf analr-is ofSPLP exlnlcl for oil ·and grnse. As5una same (;051 for SP~ VOC anaI)'IiJ.

SUBTOTAL SI,040,938

15 WaStewater Treatment (for dewatering water) Quarterly Analytical SafI)Pling of Discharge Waler ' , 20 fA S2,OI6.00 $40.320 AssUme» a.p, USumel quarierlY,lampling lhtoughoUl opcrution.

Quarterly Repon. Preparation 20 . EA 52,016.00 $4:0.320 Assuna ~ jt will reqWn 24'~ 10 prq,are. PVSC Discharge Fee 'LS 546,276.000. 546,276 KMUA Discharge Fee I LS 5278.417.00 5278.417 Utilities . 60 MO 52,000 5120,000 SUDTOTAL $525,333

16 Verification Sampling " J

. Groundwater Sampling' 3- EVENT 58.064 S24,I92 As~umes Q.P lRal~iI.. '

Geoprobe Soil Sampling. EA. 52,000 S6,OOO As.sumcs one day o~JOOPrOOc per satJ1>1ina: evcPl, auwnes saunpling can he combined with ruullnr: O&M IICtivities. .

Analytical Soil Samples 18 EA SI20 52,160 · ~ume, 6 ~leS pO- event roc ariadyliJ ofSPLP e:tlracl few oil and gruse, Assumes same cost .. foc.SPI..P voc anal)'siJ.

Waste Disposal LS 5IO,OOO_-,S~IO~,~000~ SUDTOTAL 542,352

170osure'

Sheet Pi Ie Removal 129.500 SF S4 . Vendorquoce from R.uo Construclica.~518,OOO

Paga2of4, .

TABLE ~ Alternat.ive 1 . COSrES~ATESUMMARY CONSTRUCTION AND OPERATION OF ONSITE BIOCELL Site: LOO.IIoD:·

, . Diarwnd He.d Oil superfund Sile '··Kl:i.my.NeW~·

. ! Deoaipdon: _.' "Altrrnati\'e 2 consuts ofexcavaUoo u coo~ wiJ.. cmstruction of an Dfl!ili bioceU, oosik: backfilling of ~ IOiI, and operarioo &;

moniUl'ing~!he Coiuiiucted biocell. ExuvAud ~!tom!he IWO areu.·~ LNAPLis found in nnlilcring wells wiD.be disposed of it an PIW.: BueVear.

Feasibility Sltd}o(-3O'l. ID ...~(YI,)iOOsl . olf·site TSDF. ..-he pro;ec.lb-Ilionis Wic~lDbe.6)ar1. CapitaJCOlIJ occtr in Y~()'I. Anm.talO.iMcasu ocwrin Yea"ll~: '

PeriodiccOsll ec.a. in Yew 6. ' Date: Jtme4 2009

Sheel Pile Salvage , 129.500 -$11 . -51,424,500 ..V..... qui<e!roniR~C~ti~ (~~=il) SUBTOTAL -5906,500

SUBTOTAL $702,123

25%

SUBTOTAL (.

S877,653

Heallb and Safel)' Project Ma~age~nl Technical Support'

2% 6% 10%

S17,553 S52,659 S87,765

TotalS Year Operat1nc O&M C .... -' 51,035,631\

'. Periodic C .....

DESCRIPTION

Re~diaJ Action Report SUBTOTAL

Contingency

SUBTOTAL

YEAR QTY

I '.

25%

6%

UNIT

EA

UNITCOST

SI5,OOO

TOTAL

SI5,OOO 515,000

S3,750

518,750

SI,I25

Total Periodic Cos .. SI9,8751

Present Value Analysis

Cost Type

Capital C~st . Annual O&M Cost Periodic Cost

YEAR

o I-fl 6

TOTAL COST

S 16,081,665 SI.237,312

S19,875

NOTFS

TOTAL PRESENT VALUE OF AL TERNA TlVE DISCOUNT FACTOR (2,7%)'

1 517,338,8521

-Discou:nl Ftcla' based on OMB App C JO-)CS" far 2009

Assumptions: I 'Pre-Design Inves~g~~n .'

Assumes that the <:oJ1. ~iII be si~i11V lO the Ph~ 2 Rl casts. 3 Pre-Remediation Site Work

) Vegetalion wiU be cleared east and north of the landfill to accommodate site nperationtl,localing facilities, and constructing temporary access roads.

Sewer connection 10 KMUA/PVSC sewer is based on the: dis1ance ~m the imtnec\lon of HarriSon and Bergen Ave to me propolltd OJlSite waste water treatmenJ: facility h)Canon. AHumcs that KMUA will have compielCd the e:o~1JUction of their sewer line !O which the sewer from Diamooo.'Hcad will connect before the Itaffof ~ediaJ activmcs. Assumea a 4 f1 deep trench with pipe bedding mateiiaJ imported. &1irnlllQ:J length. of piping il750 ft. 8 in diameler, , .

An-umcs a waler connection to the 24 in water main running along the southern side of Harrison Ave, Estimated length of piping is 400 ft, 2 in'diamcleT.

Ass·umcs me northwest section of the sire will require a gravel layer to support onsitc equipment and vehicles, AssUmes a new tempoJ1U)' mad and tum around area wiD be requ~ed t~~Uow acceSJ!O aD cells (see site plain v~w figures). ,

4LNAPL Impacted Soil Exc-avation

The sheet pile waU for the ,two areas where LNAPL ~ found in monjtor~g wells is estimated to be approximately 600 ft by 35' ft deep, Assume. AZ36 Sheet Pile and A572 Grade 50 Steel will be used. Cost is lof single usC around these areas,

5 Building Foundation E~avation Assumes exisling building foundafloQ is 100ft x 50 ft x 2 ft, Also a:;sumes lbal brick and concrele rubble located in the 0-0:5 fr. bgs intervallhroughotll biangle Rl'A area will be removed.

A.ssumes excavation,;;\ and stockpiling can be comp~ted at a rate of I: ,()(x) CY per day.

6 Onsite Soil Berm Excavation

_ A$J>umes area of berm requiring remov.al is 24.000 SF with a height of fO ft,

7 Dewalering

Pumps arc al!Isumed to dcwacer excavation at the rate of 200 gpm.

8 Wa.!o'tewaler Tre.lment

Includcs the cost of purchase of the Ireatment systelJl, ~osts are based on vendOr quote for Mapple Leaf Environmental.

9 Consb'Uction of Bioremediation CeDs . . \.

Sheet pdc: waU covers perimeter of RTA and in~1udes fOQ.r panitians for a oo(S.llength. of 3,700 ft. Depth csuriatc:d at 35 ft. RTA divided into approlttInately 30,000 SF cells III &.bown in the plan view figUre. Assumes.

(AZ36 Sheet Pile and A572 Grade 50 Steel w~1J be used. Vendor quote from Rano Construction are for leaving the she~ pik: wall in place for 5 ye~l. 'Quote accounli for pulling of the sbeet pile and salvage value,

Air and nutrient perfora~d piping - 940 ft in ceO. I. 9(X) ft in cell 2. 808 ft in ceU 3, 1,040 ft in cell 4. 880 ft in ceO 5. 144 ft in ceU 6.

10 Bioremediation Delivery From Tn:atment Building to CeU,

LNAPL quantity assumes 2%. LNAPL in water from inilial dewat~ing oflbe RTA (3,418 miJlion gaOons).

12 and 15 Wa:uewaler Disposal

Refer to Table ~n Appendix'A for basis for LS.

13 Groundwater MonitorinB y..ren tnstaUation. 2" wells. 2 weDs in lhc: northern area, 10 wells in ~ southern area..

14 BioccU Opcntion

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TABLE 4 Allernative 2

CONSTRUCTION AND OPE~TlON OF ONSITE BIOCELL COST ESTIMATE SUMMARY

Site: 1..AicaOon:......., O"Vellr. Ibl.e:

Diarmmd Head Oil Superfund Site Kt:&my. New kney Feilllibilily Stwy (·30% to +50%) 2009 . \

Junc4 2009'

AItl."'I'nalive 2 COOJisQ of excavation oi conlaminatcd soil. consuuctioo of an onsitz! biocell. ,onsite backfilling of amended soll. and operation &. ~in8 of \he CUM~ biaccU. Exc.valid $Oil from lht lWllIf\:U ~ LNAPt... a foom in tOOni\orina wen, wiD be dUpotcd of III. v. off-lite TSOF. The Project WnWon is anticipau:d to be 6)aB. Capital COlts occur in Year 0-1. Annual O&M coalS occur in YCIIrJ 1-6. Periodic COSlJ occur in Year 6. ' ,

As!>umes the IIoddition by volume of the ,following nu~n\s: 0.01 S% N. 0,00 I % P. and O.OOOS% K. Assumesfour doslloges pel" year. Note: Estimated cOstS do not inchlde decommissioning of consuuctcd bioccll.

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(: APPENDIX III

·ADMINI.S~TRATIVE RECORD 0-

INDEX

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DIAMOND HEAD i .OIL REFINERY DIV. SITE \,. OPERABLE UNIT ONE· . ADMINl'STRATIVlf ~RECORD ,FILE

. INDEX OF 'DOCUMENTS' ,

·1.0 . SITE IDENTIFICAT.ION

1.2' . Notifica~ion/Site Inspection Repo~ts

P. 100001 Report: Hazard Ranking System'Documentation 100038 Package, Diamond Head oil Refinery Div., Kearny,

Hudson County,.· New,Jersey,Cerc! i'S\ Id No. NJD092226000, Volume 1 ofl, prepared by Region 2 Superfund Technical Assessment and Response Team, Roy R. Weston; Inc., prepared f6r U.S.

, Environmental P~otection Agency, Region 2, July 2000.

1.4 Site Investigation R,eports

P. ~00039~ Letter of Transmitt~l,to Mr. 'James A.Laridon, '100061 Architect, from Mr. John C.Mahle, Jr., P.E.,

Johnson Soils Engineering Company, re: Proposed Hotel Development, Harrison Avenue,' :r<;earny, New Jersey, June. 19,. 1981. (At·tachment.: Report:· Proposed Hotel Development, Harrison Avenue, Kearriy, New Jersey, Soils Investigation, submitted by Johnson Soils Engineering Company, Palisades Park, New Jersey, submitted to Mimi Development, Kearny, New Jersey, June 1981.)

P. 100062 ~ Report: Site Characteriz'at:Lon' Plan for the Former 100095. Diamond Head Oil Refinery Site,Hudson, Meadows.

Urban Renewal Developmept Corporation, Kearny" New Jersey, ..·prepared by Killam Associates , Inc.,

. Consulting Engineers, October, ,1988.

P. 100096 - Report:cReport for Harbor Consultants, Inc. to 100138 Conduct a Non-Tidal Wetland Delineation on a

Track Designated as: Block 294', Lots 3, 'IS and 14; .Kearny, New Jersey, prepared by Nova

Consul tants LTD., John F. Siczep-i;ulski, PHD" Principal Investigator/Preside!TIt, September 1990 ..

P. 100139 - Letter to Ms. Jeryl Turco-Maglio, Huds'on Meadows 100150 Urban Renewal Corp., from R. Brian Ellwood,

Ph.D.l, Vice _Pres,ident, and'Mr. Robert L. Zell~y, .,

CPG, Project Hydrogeologist, Converse Consultants" East, re:.J?,erialPhotograph Analysis; Hudson . Meadows - Diamond Head Oil, Block 285, Lot 3, 14,

. and 15, Kearny, New Jersey, (91-37238-01), November 12; 1991. (Attachments: Aerial

. Photograph Analysis, Block 285, Lots 2, 14, and 15, Kearny, New Jersey; April 28, 1947; Apr~l 16; 1959; January 14, 1963; March 23, 1969; April 9,

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1978; November 25, 1982, and March 8, 1990.) ~

3.0 REMEDIAL INVESTIGATION

3.3 Work Plans

P. 300001 - Report: Response Action Contract, United States 300162 -Environmental Protection Agency, Region 6,

Contract No. 6·8-W6 - 0036, Work Assignment No. '112­RICO-02KK DCN 02-4664, Revised Work, Plan, Diamond Head Oil; Remedial Investigation/Feasibility Study, Volume If of II,.prepa.redby CH2MHILL, Inc., prepared for q.S. Environmental Protection Agency, December 11-,' 2002. r

P. 300163 - Report: Final Phase 2 Focused 'Remedial 300205. Investigation/Feasibility Study, Contractor

Quality Control Plan for the DiamondHead Oil Supgrfund Site, Kearny, New Jersey, prepared by CH2MHILL, / prepared for U. S -.Environmental Protection Agency, Region. 2, December 2007.

P. 300206 - Report: Final Phase 2 Focused Remedial· 300413 Investigation Uniform Federc3.1 Policy, Quality

Assurance Project Plan.. (UFP - QAPP) for the _ \ DiamondHead Oil Superfund Site, Kearny, New jersey, prepared by CH2MHILL, prepared for U.S. Environment,al Protectio,n Agency, Region 2, December 2007.

P. 300414 - Report: Final Phase 2 Focused Remedial 300511 Investigation/Feasibility Study Health and

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Safety plan for ,the' Diamond Head Oil Superfund (. Sit.e, Kearny, 'New Jersey, prepared by,CH2MHILL,

prepared.for U.S. Environmental Protection Agency , Region 2, December, 2007" , (

P. 3005'12 - Report: Final PhasEi 2 Focuse9. Remedial 300667 InvestigatfonSampling and Analysis Plan Addendum

1 for the Diamqnd Head oil Superfund Site, Kearny, New Jersey ,prepared by CH2MHILL, , prepared for U.S. Environmental Protection Agency, Reg~on 2, December ,2007.

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P. 3006b8 - Report: Final Attathmemt A, Phase 2 Remedial 300690 Investigation Site Management plan ,for the

Diamond Head Oil Superfund Site, Kearny, N~w Jersey, prepared 'by'CH2MHILL, prepared for' U.S. Environmental Protection Agency, Region 2, December, 2007.'

3.4 Remedia1Invest!gationReports

P. 300691 - Report: Draft Phase 1 Remedial Investigation 301760 ,Technical Memorandum, Volume 2 Appendices, for

the Diamond Head Oil Superfund Site,:, Kearny, New Jersey, prepared byCH2MHILL, prepared for" U . S . Environmental Protection Agency~ Region 2, June 2004.

P. 301761 - Report: Final Phase l' Rernedial Investigation 302470 Technical Memorandum"Volume 1, for the Diamond

Head Oil Superfurid si te, Kearny, New Jersey,' prepared by CH2MHILL, prepared for U.S. Environmental , Protection Agency, Region 2, February 2005.

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P. 302471 -Report: Draft Phase\~ Focused Remedial 303104 Investigation Technical Memorandum, Volume 2

Appendices, for the Diamond Head Oil Superfund Site, Kearny, New Jersey, prepared by CH2MHILL, prepared forD.S. Environmental Protection Agency, Region 2, July 2008.

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P. 303105 Report: Final Phase 2 Focused Remedial 3032,93 Investigation Technical Memorandum, Volume 1, for

the Diamcind Head Oil Superfund Site, Kearny, New , Jersey, "prepared by CH2MHILL, prepared for U. S. : Environme'ntal Protect:i,on Agency, Region 2, February 2009.

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4.0 FEASIBILITY STUDY

4.3 Feasibility, Study Reports

rP. 400001- Report: Revised Draft Phase 2 Focused Feasibility' 400045 Study Technical Memorandum, LNAPL Interim

Remedial,Measure Technology Screening and Evaluation for the Diamond 'Head Oil Superfund Site, Kearny, New Jersey,prepa~ed by CH2MHILL, prepared for U. S.' Environmental Protection Agency, Region 2, February 2009.

P. 400046 - Report: Draft Final Op~rable Unit 1 Focused 400294 Feasibility Study for the LNAPL Source Area for

the Diamond Head Oil Superfund Site, Kearny, New Jersey, prepared by CH2MHILL, prepared for U.S. Environmental Protection Agency; Region 2, June 2009.

8. d HEALTH ASSES,SMENTS

8.'1 ATSDR Health Assessments

P. 800001 - Memorandum to Ms. Grisell Diaz-Cotto, ERRD/NJRB, 800036 U.S. Env{rpnmen~al,protection Agency, Region 2,

from MJ:'; Arthur Block, Sr. Regional Representative, Depardnent of Health &, Human Serv'ices ~ Public, Heal th Service, Agency for Toxic Substances and Dise~se Registr~, re: Final Public Health Assessment for Diamond Head Oil Refinery Diyision, Kearny, Hudson County, New Jersey, October 2, ,2002. (Attachment: Report: Public Health Assessment' for Diamond Head Oil Refinery Division, Kearny, Hridson County, New Jersey, EPA FacilityID: NJD092226000, prepared by U!S.' Department of Health and Human Services, Public Health Service, Agency for Toxic Substances arid 'Disease Registry, September 12, 2002.) .

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AP'PENDIX IV S~ATE·LET1;ER

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~tnf£ of ~£fu 3)e:r5£l;!' . DEPARTMBNTOf EN,VIRONMENTALPROTECTION

JON S. CORZINE MARKN. MAURIELLOGovernor.

Acting Co'mmi:rsioner

SEP22 2009 Mr. Walter Mugdan,Director . , Emetgency and Remedial Response Division U.s. Environmental Protection Agency Region II' 290 Broadway New York, NY 10007-1866

Re: . Diamond Head Oil. Superfund site Record Of Decision ..

.,DearMr.. Mugdan:

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The New Jersey Department of Environmerital Prote~tion (DJ~P) completed its- review of the "Record ofDecision, Operable Unit '1 - Light Nonaqueous Phase LIquid Source .

._Area, Diamond.Head Oil Superfund site, Kearny Township, Hudson County, New Jersey" prepared' by the U.•S. Environmental Protection Agency (EPA) Region II in 'Septemb;er 2009 and concurs wi·th its selected remedy to addtesstl1e light nonaqueous phase liquid (LNAPL) source area. _ ) >,

'. Th~'response action described for th,e LNAPL source area represents the first operabl~ unit for the site. It is considered an interim actio~withno operation and maintenance as

_defmed in the National Contingency Plan: '

The selected .remedy described in the Record of DeCision involves the excavation of the LNAPLsource ai'eas,construction of an on'~site biocell fortreatment ofwastes, and off­site disposal of the most highly contaminated areas within the excavated material. The. major components of the selected response actio,nthat DEP concurs wi~ include:

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• Isolation of the remedial target areas with. cut-off walls, and excavation of the principal threat LNAPL areas, a total of approximately 45,825 cubic yards of

'. material; . ' .

• For the highly contaminated portion of the excavated material' that is not amenable to on-site tre~trrient, transportation and off-site disposal facility (with treatment as required to meetland dispos<u requirements); .

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New lersey 1$ an Eq,u~1 Oppat/unitY Employer, Printed 011 Recycied Paper and ReCyclable

.• For the lesser contaminated U4A~ti:riaterial anieriableto on-site treatment, . construction of a biocell within the ~:xcavated areato 'faCilitate biodegradation of theLNAPL wastes, including tqe'insthllation of piping for-air and nutrient distribution and a collection systemfor air apdwater that may accumulate in the biocelF '., .. . .

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•. Introduction of nutri~nts and bulk:ing agents to the lesser contaminated LNAPL( material to,enrumce permeability and the conditions forbiological activity, followed by placement of$is augmented J:,-NAPkmaterialin;the biocell for'

. treatment:and'capping;and ., . .• ., ,J

• '. Operationof the aeration,~utnent ,,<Hstribution, and ~ater coliection systems for •• ,j .'. the biocell ~oi' an estimated ?ve-yea:r period; and,.: ' ) , , ..

), . " , ,. " "'" ,,. Performance sampling and final.confirmation sampling to demonstrate that the LNAPL wastes have been d~stroyed through biological degradation, atwhich timy the biocell components will,be dismantled.

,Thisihterim action is protectiveofhurrian healthandthe.~nvironnlent in the short term and is intended to provide adequate protection until 'a fiiuiI ROD is signed, camplieswith those federal and state req~irements that are applicable or rel~v8.Q.t and appropriate for, this liniited-scb~action, arid is cost-effective. Althoughthisiriterimaction is not, "

, intended to address fully thestat\itory mandate for peimanence andtr.eatrnent tothe . niaximumextent practicable, this interim action does utilize treatment and thus supports

that statutory mandate. The selected remedy also m~tS the'statutory, preference, for .the . use Of remedies that involve 'treatment as a principal element.' , .

DEPappreciatesthe opportunity to participate in the decision,making process to select an appropriate remedy and.is lookingforward to future cooperation with EPAin further

:remediaIworkat this site. . . . ' . . " .

If you have ~y questions; please call me at 609-984-3078., ..

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. Edward Putnam, Assistant Director Publicly Funded Remediation Element Site Remediation Program

c: .·Irene K.r-opp, Assistant Commissioner, Site Remediation Program:,DEP 'CarolePetersen, c:::hief; NewJersey Remediation Branch; EPA Region II

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·\ . ApPENDIX V

RESPONS.IVENESS SUMMARY

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Diamond Head Oil Superfund· site Kearny, New Jersey

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INTRODUCTION

This. Respon~iveIl:ess Summary provides a summary of the public's comments and concernsregardihg the Proposed Plan for the Diamond

" Head Oil Refinery site, and EPA' sresponses' to those comments. At the time of the public comment period, EPA,proposed'a pref"erred approach of, a first phase ,or operable unit, addressing' the, LNAPL

,soOrce are~, as an Inteiim Action for the site.

The Selected 'Remedy describ~d in thi$, documenti~volves the , excav\ation of the LNAPL' source areas, construction of an on-site biocell for treatm~nt of' wastes, and off - si'te disposal of the most· , highly corttaminated areas "within the excavated material.

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, All' comments', summarized iiI this') do6ument have' been considered in :EPA's final decision for the selection of the remedyifor the site.

This Responsiveness. Summary is divided'into the following sections :'

1. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This ,section pr6vides the history of community involvement and interests regarding the Diamond Head Oil Superfund site.

, , II ~COMPREHENSIVESUMMARY OF MAJOR .,QUESTIONS, COMMENTS, CONCERNS AND RESPONSES,: This section'contains sum~aries of oral comments received by. EPA at the public meeting and E;PA's reSponfiles to tliese comments.

The last section of ,this Responsiveness Stimmaryincludes attachments, which document public participation in the remedy selec~ion process for this ~ite. - They are as follows:

Attachment A contains the, Proposed Plan that was distributed to , ),the public for

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review and comments; .1'

Attachment B contains the public notice that appeared in The Observer; and

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Att,acbment C contains the ,transcripts, of the public meeting;' .- ,"i

EPA receivedno,writ.ten comments during the public comment,period.

, / .~I. BACKGRdUND ONCOMMUNI~ INVOLVEMENT AND CONCERNS

On July 14, 2009,' EPA 'released 'the Proposed' Plan and supporting documentation fQr the Interim Actiortto address'the light"'," '

'nonaqueous phase liquid (LNAPL) ,'source' area at th~ DiamondHead. Oil Refi,nerysi te; EPA made these documents available to the ' public \in: the Administ:rative Reco,rd repositories, maintained' at the

,EPA Region II office (290 Broadway ,'New, 'York; New' York) arid ,the ' Kearny Public Lipraiy (318 Kearny Avenue, 'Kearny, New Jersey:' 07032). EPA published a notice of availabilityinvolvihgthese documents in Th~ ObseJ::'Ver~newspaper, and ,opened a public comment period on,th,e' documents from' July: 14 , /200'9 to August 12, 200'.g,. 'bn July 22, 2009,' EPA held a public meeting at the main,council chalnbers in Kearny Town Hall, ,to inform local officials ,and interes,ted residents' about: the Superfuild process ,to present' the 'preferred remedial alternative for the site,' solicit oralcoinment, and respond to any questions.

,The ol!'al comments received from the pUblic'and EPA's,resporises can be found in the next sections of ';this summary. All recorded' comments', for the Diamond Head Oil site's propos)ed Pli3::q hav~ been

" included as 'an attachment to this Responsiveness Summary. For, readability and clarity, EPA'grouped, where possible, similar comments into,one general'comment; therefore, a'single response may answer several comments.' ' I,

II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS, AND RESPONSES

PARTl: Verbal Comments

A public meeting wa,E\ held on July 22, 2009,' at 6:00 P.M'.atthe main council chambers in Kearny (Town, Hall~ ,402 Kearny- Avenue', Kearny, New Jersey. Following a brief presentation of the;' , investigation findings" EPA presented the, Proposed plan for the site, received comments from meeting participants, and responded to questions regarding the remedy proposal under consideration.

Comment: A resident asked what are the areas that would be sent for off-site disi;osal.

Response: The 45,000 yards that were identified as the worst part of the site' would be subjected to bioremediation, which is a

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,I standard method 'of addressing petroleum-contaminated sites. About, 3,000 yards of soil containing free-'phase oil would be sent for off-site disposal.

Comment: ,The, same resident asked about what type of plac~ this waste would be sent to.

Response: The material would probably go to a hazardous .waste landfill. I'

Comment: The same resident asked if the material would" go to a TSDF (Treat~ent, Storage, and Disposal Facility)' first and then to a, .landfill ~ /

Response: 'It would probably go to a RCRA Subtitle Cfacility that ,could have the capabity to treat the material 'on premises, and then put it in the landfill~

Comment: The san\e resident asked if there was a concern'about metals with regardt6 disposal.

Response: ,The material 'will be'tested during remedial desig~ to determi,ne the proper disposal method. Based on EPA's knowledge of the site, lTIetals are not likely to'be a determining factor. \

Comment: The same resident' asked about the levels of PCBs' detected at the site.,

i Response: PCBs ,were detected at generally low conc::entrat'ions an¢! inv~ry few ~ocations -,less than ten, across the fifteen-acre. site, ranging in concentration from one to· less thanlDO parts per million'. '

Comment: The same resident aSked if soils at the site ,were TS'CA­regulated (Toxic Substances Co'ntrol Act) .

,Response:, Based' upon EPA"§! current ,knowledge o.f, the site, the soiis would not be TSCA-regulated. 'Samples collected in the early 1980sshowed elevated levels of PCBs (higher than 'we are seeing today) ; however, when the facility closed, tons'ofwastes were

,removed, most likely containing some of;the material with the \., "

higher PCB levels. . .

PART '2: Written Comments)'

N0 written comments were received from the public during the public comment period. \0­

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ATTACHMENT. A PROPqSED PLAN

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Superfund" Progral)'l U:S. Environmental Protection proP9sed 'Plan" Agency,' R~gidn 2 ." ~o S1: i./. '

"\ ' .v~6~~<S'·· .' Diamond Head Oil Refinery Superfund'Sitel ~: "%

Kearny, New..Jersey : \~Jt1..:~~ " '1?-4l PRO~&

July 2009

EPA ANNOUNCES PROPOS.ED PLAN

~ This Proposed Plan ide'ritifiesthe preferre~" . ~alternative'for an'Early Action to (j.ddress the 'light ,

nonaqueous pihase liquid (LNAPL) source area at theDiamorid Head Oil Refmery site,artdprovides the rationale fot that p~eference. for this action, "" alsoreferredto 'as Operable Drnt I (OUI), EPA is

, recommending) construction ofan on-site biocell to facilitate thebiodegradatioh of the LNAPL ~ource area; Not all the waStes are expected'tobe

, effectively treatedwithin the biocell, so this E~rly Action also includes'the excavation and off-site dispo'salofthe more highly contamiriated material within the LNAPLsotirce area. This action would

'be taken while remedial investigations to, determine' the full n~ture and extent of cOJ?tamination for the sit~ are completed.

This proposed plan summarizest4e data / considered"inmaking this early action ' recommendation. This docume~t is issued by . EP A, the lead agency for site activities. EPA, in I

consultation with the New Jersey Department of Environmental ,Protection (NJDEP), t~e support agency for site activities, will select the finalOUI remedy after reviewing and considering all "

" information submitted during it 30-day public' comment period. EPA, in consultation with NJDEP, may modify the preferred alternative or select another response action pre~ented in this

\ Proposed Plan base,don new information or public comments. Therefore, the public is encoUraged ,to review and comment on all the information '

.~presented in this Proposed Plan. '

EP A is issuing this Proposed Plan as. part of its c6tnmunity relations program under Section

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117(a) ofthe Comprehensive Environmental Response, Compensation and Liability Act " (CERCLA,or Superfund), and Sections 300.430 (f) and' 300.435(c) of the NationalOil and Hazardous Substances Pollution Contingency Plan (NCP). This Proposed Plan sUmnlarizes inf~rmation that can be found in greater detail in

'. several'reports, incluoed in the AdmInistrative Record, in particular, theJune 2009 report, Operable Unit 1 FocusedFeasibilityStudy for the LNAPL Source Area (FFSReport). EPAand

. NJDEP encourage the public to review these documents to gain a more comprehensive

under'standing of the site and Superfund activities aboveground storage tanks and possibly that have been,conducted there. subsurface pits were used to store oily wastes. , '

These wastes were intermittently discharged "­SITE DESCRIPTION directly to adjacent properties to the east, and the

wetland area'on the south side of the site, creating '. The Diamond Head site, listed as 1401 Harrison an "Oil Lake." Avenue, Kearny, New Jersey, is characterized by contamination from a former oil reprocessing In 1976, the New Jersey Department of facility loca~ed n~ar the Hackensack ,'Transportation (NIDOT) purchased several lots Meadowlands. Figure 1 shows the site loca~ion. from PSC ResQurces, Inc., as part of its plans for The site is comprised of a l5-acreunoccupled construction ofI-280. In 1977, NJDOT removed parcel that includes wetland areas and drainage. over 10 million gallons ofoil and gil-contaminated, ditches, a sinall wetland/pond, a vegetated landfill 'liqui4 and over 230,000 cubic yards ofoily sludge

. area along the western bor/der, and the remnants from the area of the Oil Lake. The liquid wastes of the former Diamond Head Oil R~finery ori the were shipped to waste-oil recycling facilities. The eastern portion of the site. The parcel is bordered oil-contaminated sludges from the bottom of the by Harrison Avenue (also called:the Newark Oil Lakewere excavated and placed iii a series of Turnpike}to the north, entrance ramp "M" of' disp~sal cells, one atop the MSLA 1 ~D Landfill, Interstate 280 (I~280) to the east, 1,.280 to the ancJ a series o(smaller cells-within the right-of­~outh, and Campbell Distribution Foundry to the way (ROW) to the highway, next to the then still­west. 'operating oil..:reprocessing facility. The details of ,

these disposal efforts are not well,documented, The land use surrounding the site is industrial or

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but a sunple liner and a Clay-based capping open space/wetlands;the n~arest residential area i~ materialwere to be part ofthe disposaLeffortsfora half-rrnle to the west. To the south, aMunicipal the sludges.' '

" ,Sanitary Landflll Authority (MSLA) landfill, , identified as the 1-0 Landfill, is situated south of While the surfiCial Oil Lake was removed and

1-280. filled, the NIDOT also reported finding an "underground lake',' ofoil-contamirlated

The I5-acre parcel is fenced. The prior site , ' groundwater extending from the eastern limits of

operations t06k place on the eastern half of the t!:te 1-280 right-of-way to Frank;s Creek; west of the site. .parcel; the landfilled area was once an access road

to the I-D Landfill, and a landfilJ,:mound remains , From the close ofoperations in 1979 until 1-982,from those activities,that rises 10 to 15' feet above the abandoned-site was not completely fet;lced. In the rest ofthe site. Surface water mains through a 1982, during the dismantling of the, oil - , drainage ditch that eventually discharges. to ' reprocessing facility, approximately 7,500 gallons ­Frank's Crt;!ek, which in turn,discharges to the ofmateiials were apparently pumped out ofthe Passaic River. tanks and disposed off site, and 27 tons of

contaminated soil were reportedly removed from SITEIDSTORY) the site,. It was sampling undertaken during this The oil reprocessing facility opera~ed under cleanup effort that first identified hazardous several company names, including PSC Resources; substances, including polychlorinated biphenyls Inc., Ag-Met Oil Service, Inc., and Newto\yl1 , (PCBs) inwaste material.collected from the site~ Refining Corporation, from 1946 to early 1979. , Aerial photographs,from 1982' show that the oil

'All of these companies were owned by Mr. Robert reprocessing facility infrastructure ha? been Mahler: During facility operation~, multiple ' dismantled. The'buildings and facilities assoCiated

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with pr(!vious site operations were constructed on the e~stem half of the site, and,some rernmint concrete buil9ing and tank foundations remain. In 1985, the refinery property was sold to "Mimi Urban Development Co'rporation,)Vhich subsequently changed its'riame to Hudson Meadows' Urban Development Corporation.

The property' sat idle fora number of years; at least in part because of the alleged contamination. EPA was asked by NJDEP to evaluate the site for

· inclusion on.the National Priorities List (NPL) in 1999. The site' \\fas added to the NPL. 0 f . Superfund sites in September 2002.

In 2002, . EPA began a re~ed,ialinvestigation' (Rl} . to determine the nature and extent of the problems posed by the site .. In addition to the LNAPL findings discu~sed below, theRI found soil, . groundwater, sediment and surface water cont~atlon attributable to the site. The RI. also included a number of test trenches through the

· landfill portion of the site to assess thena!ure of the material buried there, and has collected borings along the 1-280 ROW berms to confinn' the presence of the buried sludge~: Site studies

/ are ongoing; for example; new groundwater monitoring wells were installed earlier in 2009 on a number of neighboring properties to fully assess othe extent of the groundwater problems posed by . the site. Field investigations for the comprehensive remedial investigat~on ofthe site are expected to be complete in 2010, at which time EPA can proceed. with' evaluating remedial alternatives for the entire site.

SITE CHARACTERISTICS

Site Hydrology

The nearest surface water body is Frank's Creek, . and as a result ofl-280's construction, all drainage

on the northside of the highway now travels by a man-made drainage swale, a distance ofabout 600

· feet to the creek, which in tum discharges to the Passaic. River. Prior to the 1 940s, the area south of Harrison Avenue was wetlaild. Landfilling

.. acti\;jities that started in the 1940~ began to shrink' and divide the wetland areaS, andth~ eventual Oil'

.Lake, estiinated in 1977 at betweeh six and seven acres~ appears to have formed ,in a remaining lowland area. sur'roun~ed by p~operties filled' for industrial devdopment and by what would become . the MSLA I-DLandfill. With the construction of 1-280; including the placement ofthe ROW berms, an isolated wetland, frequently ponded, remains just south 6fthe former Diamond Head Oil . facility. .'

Two factors have a significant influence on the' water table at the site~ The first is the presence of wetlands along the southern site boundary that. include'areas ofsurface water; arid the secondjs

, the presence ofan LNAPL plume in the southeast , comer of.the site in the area of the former'lagoon. Although lighter than water, the density:ofthe LNAPL has tfteeffect of depressing the water table and influencing groundwater flow; Excepting' these areas, groundwater is mst encountered at the site under unconfinedqoriditionsat'a depth of one. to two feet below the ground surface.

Site Hydrogeology

The stratigraphy at the site corlsists ofa relatively unifonn vertical sequence ofuncons6lidated materialS as follows, from top to bottom:

• A highly variable (in content.and thickness) layer of anthropogenic fill across the site, consisting of typical demolition-type debris, including wood, brick, metal, glass, plastic and concrete mixed in a matrix ofpoorly sorted fine to coarse sand and gravel or silt, 'sand, and gravel.

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• A sand unit about five feet thick on the western'side of the site and pinching out until it is not present on the .eastern side ofthe site.

• A silty ci~y unit, up to eight feet thick in sections of the site, that appears to be continu~us throughout the s'tudyarea.

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lagoon occupied the southeastern' section 0 f the • .' A distinctive peat layer ofvarying thickness . site and extended eastward. Figure 2 s,hows the

but considered continuous across the site. bpundary. of the Oil-Lake compiled from historical aerials of the site. .

• A silt and sand unit approximately 15 to 20 . feet thickbeneaththe peat.

• Laminated silt and clay unit, the ~n thickness 'ot-which was not observed in any of the study borings to ~ate (as deep as 50 feet).

• Bedrock, which also has not- been encountered to date.

Shallow groundwater flow direction above the silty clay and peat layers is consistent with surface water flow directions, to the south and west. . In the waterbearing unit below the peat, groundwater flows from northeasfto south'Yest, consistent with . regional trends- in' groundwater flow. ­. -

The ongoing RI studies wilLresulfin a more comprehensive understanding of stratigraphy and groundwater:

. Nature and Extent of LNAPL Source Material

The RI studies to date have outlined two areas as potential source areas where LNAPL may be continuing to release contamination to the environment:

• the former oil reprocessing section·ofthe.site, once containing two buildings; multiple aboveground storage tanks (ASTs), drum . storage areas, and possibly undergrourid pits; and

• remnants of the Oil Lake, estimated in 1977 to cover an area ofsix to seven acres, located over the southern section of the site and

. extending outside the site's fenced boundaries to the east and south.

Currently, ill the oil processing section of the site, only the foundations ofone building and two' . ASTs are visible. No remnants of the Oil Lake are visible, but historiCal information shows that the . ,

There is evidence ofoil contamination in nearly every boring installed within the I5-acre fenced .

. property and in manyborings to the southeas.t. \ Because of this "smear" ofoil contamination .across the site, the RI studies performed to date have used the fo Ilowing methods to document the nature and extent of the l.NAPL, and to identify the more severely contaminated areas of the site:

• A geoteclmical measurement tool called laser­induced fluorescence (LIF) allowed' for the _ subs\lfface mapping ofhorings that contain

. LNAPL. LIF can rapidly identify an oil "fingerprint," including both extent and relative concentration .

• Soil borings were collected throughout the site down to the laminated silt and sand unit; as mu~h as 50 feet deep, and .the presence ofoil . staining or separate-phase oil in the soil borings was documented .. These results were compared with the LIF sample points to

.' 'calibrate the LIF data to site-specific conditions. ­

• A ilUmber of monitoring wells, meant to measure groundwater contamination, have thickIiessesoffloating product in the tops of the wells, with a~ much as five feet of LNAPL

. floating in some wells.

• Samples were collected ofcontaminated soil· and oily wastes and sludges and sent for laboratory analysis to identify potential contaminants of concern and to establish an analytical profile of the LNAPL

Using these methods: several characteristics 0 f the LNAPL were established: .

• The LIF study concluded that LNAPL is present in the subsurface throughout most of the investigated area, though the LIF showed wide variations in the inten~ity of the LNAPL .

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signal, indicating substantial variation in concentration across the site.

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.LNAPL. ~as measured in wellshl three areas of the site'~I1eip the f~rlner proc~s~ ar~a" and

. two withinthe footprmt of the OilLake. These areas are identified on Figure.2.

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• The vertical occurrence of LNAPL can be further separatedinto two' depth intervals:' (l)

- at ,the water table (approximatelytwofeet below ground surface),.sometimes wit~an extended smear zone,into the saturated fill­containing materialand soil to abound feet below ground surface; and (2) as adiStmct ' deeper interval at depthsoflO to 16 te~t below ground sUrface withitithe siltY/Clayey soil~ Thebulk ofLNAPL-containing soil is located near the water table within'the fill layer.

• LNAPL appears to contain more diesel range , organics than gasoline range 'organics. ,The followin.g compounds or classes of compounds were detected in th~ LNAPL:' benzene, ' toluene, ethylbenzene, andxylenes, as w,ellas

, a number ofother volatile andsemivolatile organic compounds (VOCS and SVOCs) consistent With a petroleum matrix. In additiOIi, two ,·PCBs (Arochlor-1232 and Arochlor':1260) and avatiety of metals, including lead and cyanIde were also identifi~d in LNAPL-zone samples.

• 'Despite the large thickness .of LNAPL found in, ~ome monitoring wells and its relatively.

<.. high sa~ation, LNAPL is extremely viscous, , arid is relatively ilnmobile under ambient gradients. This is indicative ofa highly weathered LNAPL, where much ofthe more ~obilecomponents of the site r.eleases· have ' degraded or already traveled away from the site, leaving the less,mobile fractions. '

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• Within LNAPL, there are pockets of less Weathered LNAPL of high saturation that present a leaching concern tOgToundwater. These are LNAPL areas that may be

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'considere~ to present a riskior leaching contammimtsto groUndwater.

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Principal Threa(Eva)uationofLNAPL ;,. '

Basedoll th~LNAPL studies perfo~edto date, portions'_of the LNAPL are more mobile, are likely to have a Ilighef toxicity,'tmd'are at ~i'much great~r 'concentration at the site. Tliese high-I~vel

. wastes forth' tlie"principal threat" 'posed by the site, I-Iaving developed an uriderstanding of'the

, natureartd extent of the LNAPL, the RI studies further identified characteristics for, the prin~ipal threat· LNAPL, consistent with EPA guidailce.

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EPA d~firies principle threat wastes as "those soytee l1laterials, considered to be 'highly toxi<; or . highly m<?bile thatgeneraUy cannot be reliably coritain~~orwQuldpresent a significant risk,to 'human health or the environment shOuld exposUre occUr. They include liqui(is or other highly moqile rnat~riaIS (e.g., solvents) or materials that have high,conctmtrations of toxic compounds.!' By co~tra~t, lo~~levelthreat wastes are defined as "t\lose materials that generally can be reliably contained andthat wouldrepresenta low risk in the event ofa release. They include materials that exhibit low toxicity, low mobility in the environrilent, or are near health1based levels."

The follo~g lines ofevidence based on 'site­, specific ,data ~were used to interpret. whether th~

LNAPL source matenal at the Diamo~dHead site represents ,a principal and/or a low level threat:

• 'AssessIl1ent of the preserice of LNAPL inthe soil column through soil borings and '" ..( : r

mterpretatlOn of LIF results, placing particular , emphasis on LNAPL fouridat or near the

ground surface and, therefore, posing adirect.: . contact threat; .

• Comparison of LIF results to areas where LNAPL was visually observed in the pore spaces of soil cores collected from soil borings, and to groundwater data to indicate where the highest mass ofwastes were : located, and where those high:·concentraiion '

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, ­ -wastes were associated with elevated , ("

, groundwater concentrations; and

• Areas where a measureable thickness of LNAPL-was fou~d in monitoring wells and piez~meters during RI studies. I ,

Using these lines of evidence, LNJ\PL detected at the si~e was separate~ into areas where LNAPL material is considered to represent a principal

, threat,and areas where, LNAPL can be considered ' lto represen,t a lower-level threat, and for which appropriate mea~ures will be consider6d during future feasibility studies. Figure 2 shows ,the areas, , ' ,

, identified as a principal threat using these lines of evidence (shaded in orange). The total area is rqughly 176,000 square feet. Th~s'area incl~des the- two areas of the site where monitoring well~ contain measurable thicknesses of LNAPL­(shaded iri yellow). The thicknessesdfthe prinCipal threat LNAPL varies. ' Based on an average depth of seven feet below ground surface, a volume of45,825 cubic yards, intluding2;593 yubicyards wheFe LNAPL floating product is

, found in wells, constituteS the principal threat , LNAPL (otitlined in red on Figure 2). '

,-A noncontiguous area withindoverleafofI-280 (also identified on Figure 2 ) appears to meet some of the characteristicsofa pnncipal threat as described in t~e FFS, but it is not as near the surface, and groundwater contamination is not as clearly attributable to this area. This area is not

, , included within the definition of a principalthreat , _ for this Early Action; further studies ofthis area

, will be carried out as part, of the site-wid~ RI. ( ­

, While further studies ofthe laridfilled area of the site are required, the hlstory ofsite activities- and the test trenches already installed support EPA's conclusion that the landfill is not a source of LNAPL. EPA will further evaluate the landfill as part ofa site-wide RI.

SCOPE AND ROLE OF ACTION

i~ order to remediate Superfund sites, work is o fien divided into remedial phases, also referr~d to

as operable units. This first operable unit has been, identified as an early action to address the, principal threat LNAPL. A secQnd operable unit

-'will address residual soil contamination " attributable to the site including lower-Ie'vel threat LNAPL, the on..,site landfilled area, the ROW' berms, and groundwater and sediment contarriination.

, ENFORCEMENT

[)jamondHead Oil R~finery, Inc., and its affiliated co~panies are n~ longer in business. Hudson Meadows Urban Development C<?rporation I

(HMl)DC) is the land owner for the former " DiamondHead Oil facility, and Kearhy Township , arid NJDOTretain ownership to the remaining' land'associated with the site., At the start of the RIIFS, EPA conclllded that HMUDC was not capable of funding the cost of, the necessary studies; the RIfFS has been federally funded.

SUMMARY OF RISKSATTRIBUT ABLE TO LNAPL SOURCE AREAS ' '

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The focus of this Early Action is to address light' ,!

nOl1aqueous ph~se liquid (LNAPL) that ­constitutes a principal threat at. the site. The principal threat LNAPL is physically similar to free~ilproduct. Oil products are toxic to

/ ecological receptors and humans through direct contact, incidental ingestion, and inhalation pathways. Potential exposure ,to ecologicaV receptors and humans 'from the high-concentration LNAPL that is pr:esent at, the site could reSult in adyerse health effects; !tis; therefore, important that steps _be takento reduce or eliminate the . volume ofLNAPL prbsent at the site. Reducing or eliminating the LNAPL at the site would reduce potential exposure to free product and is an important early Step in managing the site risks; however, it is not expected to elirriinate the overall risks and hazards to ecologicalreceptOfs or humims because ofresidual contamination that would remain on the site. This residual co~tarriination will b~ addressed·~ subsequent

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. actions and .will be accompaniedby,full ecological and human health risk assessment~.

[n addition to removing. the potential exposure to LNAPL at the site, reducing or eliminating tli~ . ." .. ',' .'. )

LNAPL would also iiniititspbtentialmigration, . . ~. .

which would aid in investigating and selecting a remedy for the remainder of the site ..

. A list of chemicals of potential concern identified to date can be found in Table I. Further. information about the nature and extent of contamination found at tne 'site is mclude~ in the' Achninistrative Record.

, Based upon the results of the site stUdies to date, . EPA has determined .that actual or threatened,'

releases of hazardous substances from the site, if not addressed by the 'preferred remedy or one of . the other. active, measures cohsidereq, may present a current or potential threat to human health an& the environment.

REMEDIAL ACTION OB,fECTIVES ' .

The following remedial action objec,tives for the priDcipal threat LNAPL/wastes address the human

. health fisks and environmental con<;:erns at the Diamond Head Oil site:.

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• Remove or treat priiicipal threats, consistent with the NCP,tothe extent practicable;

• Prevent current and future migration of LNAPL and associated chemical contaminants

.. to the various media at the 'site including,.. , groundWater and seeps to, surface water; and

• Prevent human exposure through 'direct contact with the principal threat LNAPL.

The frrst two RAOs are intended. to address the principal threat LNAPL>and the .contamination .. that may be released from this material. The third RAO is intendedJo address risks to lpotentiai' . future site workers/users as a result of exposures to this material

','; This proposed action w~uld :addi-ess the prinCipal thr~at'wastes that have heenjdentifiedto date at '. . '.' .", .. ·i· ." .' .'. , ........ ,.:., "

; the site~ thereby addreSSing the mosfhighly . - co~taminat~d m~terial that, ~ithou'tearIy . , attention; would result in ongoing contamination ofcurrently unc8ntammatedare~s~th~JiAOs would be achieved by atta~irt'g tl)e. ~em~diati()n goaIsofno measurable thickries'~ofLNAPLin

• monitoring wells, and nopotenti~(for LNAPL­contaminated soil to leach oil and 'grease to

'groundwater, as measured by ~s~t~etic' preciPitate leachate proced~te CSPLP) leaching test. Because there are no Fe:deralor State :

. .'\.' " .... . .'. cleanup standards for LNAPL, EPAestablished these remediation,goals based tiponthetoxicity

'. and mobility and the principal threats to address ~tllls continuing source.'

SUMMARy OF REMEDIAL ALTERNATIVES

The RAOs identified above are primarily focused on addressing the LNAPL mas~ and do not specifically address the co-located cherrucal

. contamination in soi,l at the site: Some, though not all of tHis chemical contamination is associated with LNAPL; therefore, by reducing the ~ss of" LNAPL, the Early Action ~ould also reduce some of the co-located chemical cO,ritamination and the unacceptable risks to potential human and ecological receptorsassociatedWitti both the .' LNAPL'and co-located chemical contamination at the site.'

While the effects of the selected technologies on ,the co-located chemical contamination cannot be quantified at this time, the effectiveness of each alternative is presented in terms of LNAPV source .

. , reduction and the tecnnology'spotential to reduce concentrations ofother chemicals present at the site.

. The principal threat LNAPL to be addI:essed by this proposed action encompasses two areas (outlined in red in Figure 2), and identified in the

,FFS report as the "remedial. target area." The thickness of the principal threat LNAPL varies

. from between six and 12 feet, and at its deepest,

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appears to have penetrated as much as six inches Alternative 2: On-Site Biocell into the silty/clay layer that underlies the site. ' The Capital Cost: , $16,080,000 total vplume of these areas was estimated in the FF~ at 45,825 cubic, yards. Annual Biocell Operations Cost: $207,000

Annual operation and maintenance $0The Ri"included several treatability studies of (O&M) Costs: technologies that are commonly used for

petroleum-based LNAPL: in-situ air sparging and Present-Worth Cost: $17,340,000 LNAPL pumping. For both technologies, the viscosity of the LNAPLwas 'an impediment to Construction Time: , 1 year successful performance. Consequently, neither of

, Remediation Time: 5 year;sthese technologies was carried forward in the FFS, although-the'biodegradation treatment process at

Under this alternative, the remedial target areas work in air sparging is present !tl Alternative 2. would be isolated with a sheet pile wa14 and the

, Detailed, descriptions of the remedial alternatives principal threat LNAPL areas excavated. Some of can be found in the FFS report. The alternatives this material, as discussed more fully below, , are: would'be removed for off-site disposal. The,

remaining excavated Ipaterial would be augmented , Alternative 1: No Action with nutrients, and bulking agents to enhance

'permeability and the conditions for biological Capital Cost: $0 activity. The area within the sheet pile walls

Annual O&M Cost: $0 , would be converted into, a biocell by installing " pipmg to supply air and distribute nutrient

$0 'Present-Worth Cost: , additives, along with a c911ectlon system for air and water that may accumulate in the biocell. TheGonstruction Time: ~A augmented LNAPL material would then be placed. in the biocell for treatment, and capped'. , The Superfund program requires that the "no­

action" alterriative be considered as a baseline for The biocell wouldtequire continued operation of comparison with the other alternatives. The no the aeration~ nutrient distribution, and water further action alternative does not include any collection systems, including collecting and physical remedial measures (beyond those, \ treating water accumulated in the biocel4 and response actions already completed) th~taddress maintenanceofthe cover, until the remediation the LNAPL contamination at the site. goalS are achieved. The FFS describes

, ,performance sampling and final confirmation Because this alternative would result in , ~mpling that would be required to demonstrate contaminants remaining onsite above health-based that, the LNAPL wastes -have been destroyed levels, CERCLA requires that the site be reviewed ' through biological degradation, at which time, the every five years. Ifjustified by the review, biocd,l components would be dismantled. The remedial actions may be implemented, to remove FFS estimates that the biocell would require five or treat the wastes. - years to achieve the remediation goals. '

Areas where a measure able layer of floating LNAPL product isToundin monitoringweIls may riot be amenable to effect treatment in the biocel~ or may extend the time frame required for

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treatmenfgeyond the pr6jected five'-ye,ar tune p~riod. Under this alternative, these areas would

" be excav~ted imd transported f~r ~ff-site dispo~al. ,These highly contaprinatedspils.~nd sludges rrniy need treatment via stabilization to allow for ' tnuisp~rt~tib~. The quantity of mat~ri~l' that' would not be suitable for the biocell cannot be

, determined until remedial design; for cost- ' estimatirig purposes, tne FFS assumed,' at minimum, that the floating product area; approximately2,600 cubic yards ofthe45,825

, cubic yards .. within the remedial target' ar~~s, would be disposed ofin this fashion. Although , additional.treatability work during remedial design will refuie the amount' of material to be shipped off ' site for disposa~ the volume coulfjbe much larger than 2,600 cubic yatds; the effectiveness of the processina.chieving cleanup goals within given time periods will be a·major factor in this determination. For exarriple, removing a larger volume of material foroff-sit~disposarmay reduce the time to meet cleanup goals arid enable more rapid reuse oftlIe site.'

While this alternative would result in contaminants 'remaming within the,remedial target areas above health-based levels, the action is expected to address the principal threa1 LNAPL as a final action: . A 'subsequent Record of Decision will be 'required to make a final detenninatio~ about the uncl~dying constituents that would remain within the treated soil; therefore, the need for a review of the site every ~ve years, as required by CERCLA If contaminants remain above health-based levels would be made at that .time. Ifjustified by the ' ' RIfFS,. remedial actions may be implemented ~o remove, or ~reat such wastes.

,_ Alte~ative 3:' ()n-Site SoilWashing">

",'. Capital Cost: ,f. $18,560,000 " ,,'..', ·'i':,,· "

"Annual O&M.Costs: $0

" Present:::WorthCosf:, $18,560,000

Constnictiop Time:" I year ,,'

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{lnder thisa:lternaiive, the remedial target areas would be isolated with a sheet pile wall, and the principalthn;at LNAPL areas excavated; The

, excavated material would th.eil be treated 'oil ~ite using soil'W3shing.The excavated s,oils and '

'LNAPL wastes would l~eplaced in a slurrY r~actor vessel and' c9mbined with a wishing fluid, a ' combination ofwater, smfactants and co-:-solvents

, thatwould "wash" (desorb or diSsolve) the', LN~L from the soil particles. Thistec;hJlology requires 'a water treatment facility to treat the / LNAPrJ and contaminants· of toricei-nin the " washing fluid so it' can be reused. The separated wastes from soil washing wouldbet~eil off'site for further treatmentand di;posal.The t;eated si>il material would be tested for ,compliance with the cleanup goals, and returned to the excav~ted areas.

The FFS describes confirniation sampling, required, ,to demonstrate that the LNAPL wastes have been removed from the treated soilS prior to returning , the material to the excavation. The FFS estimates' that soil *,ashlngcQuld be implemented in'­approximately one year., ' .

, As with Alternative 2, areas where a measureable layer of floating LNAPL product isfound in monitoring wells may not be amenable to soil' washing, and this 'alternative assumes that these' areas would be excavated, treated as necessarY, andtninsported for off-site disposal. For cost.;.

, estimating purposes, the fFS assumed that, at minimum, th~ floating product area would be ' addresse"d in this fashion. . ' ,

While this alternative would result in contaminants' remaining within the remedial target areas above health-based levels, the action Is expected to

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address the prindpal threat LNAPL as a fmar action. A subsequent Record of Decision will be ' required to make a final determination about the underlying constituents that would remain within' the treated soil; therefore, the need fo'r a review of

, ,

, ,the site every five years, as required by CERCLA ifcontaminants remain above health-based levels, woul~be made at that time. Ifjustified by the RIfFS, additional remedial actions may be implement,ed to remove or treat such wastes.

Alternative 4: Excavation and Off-Site Treatment/Disposal

Capital Cost: , $19,450,000

Annual O&M Costs: $0

Present-Worth Cost: $19,450;000

, Construction Time: 1 year

Under this alternative, the remedial target areas would be isolated with a sheet pile wall, and the principal threatLNAPL·areas excavated. As with Alternatives 2 and 3, dewatering would be , required prior to excavation, and the removed water would need to be treated prior to discharge. l1he excavated material would then be stabilized on site to allow for transportation for off-site disposal. The e~cavated areas would be backfilled with clean fill~ " '

, Sampling would be performed during remedial , design to delineate the extent of the reinedial

target areas, but no performance monitoring, , would be required. TheFFS estimates that this

, alternative could be implemented U; approximately one year.

, BecaiIse this alternative would create a "clean " isiand" in the ce~ter of the site, the sheet pile ~all ' would be left in place at the end of the action.

,The excavated area would be graded to create a recharge area that would maintain a positive gradient from within the sheet piled areas to the outside to prevent recontamination of the area by other'contaminants ofconcern. '

This alternative would not result in contaminants

remaining within the remedial target areas above health-bas~d levels, as any underlyillg constituents within the excavated area would also be removed. A subsequent Record of Decision will still'be required to make a' final determination 'about the need for five':'year reviews for other areas of the site.

EVALUATION OF ALTERNATIVES

, Nine criteria are used to evaluate the different reme,diatiol};alternatives individuall/and against. each other in ,order to select a remedy; (see Table above, "Evaluation Criteria for Superfund Remedial Alternatives"). TJUs section'ofthe Proposed Plan profiles the relative performance of each alternative against the nine criteria, noting how it ,compares to the other options under 'con~ideration. The nine evaluation criteria are discussed above. The "Detaile,d Analysis of Alternatives" can be found in the FFS.

1. Overall Protection of Human Health and t~e Environment

Given the limited scope of this early action, the remedial' action objectives oniy consider ' , protectiveness of actions to address the principal threat LNAPL. Site-wide protectiveness will be consid~red in a subsequent d~cision document.

( The no ,action alternative is not considered proteCtive because it does nothing t~ ffiitigate the LNAPL as a continuing source of co'ntarnination or as a direct cont~Ct threat. '

, Alternatiye 1, the ''No Action" alternative, is not protective of human health and the environment. The remaining alternatives are considered, protective, because they remove the LNAPL 'through treatment or off-site disposal.

2. ,Compliance with ARARs·

Alternatives 2, 3 and 4 are expected tp satisfy applicable or relevant and appropriate requirements (ARARs) that pertain to the

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. .EVALUAOON CRITERtI\ FOR SUPERFU~D,RE"'EDJAA:ALTERN"'rlVE.S.· .. ".", OveniUPiotectlVeness'ofHuman Health andtheEnvlionmentevallJateS~WhetherMdhow analterriatNei ....: .•...... erminates.; redUcestof. eontrolS threat&to pubik: health and.the envirOnmentthrougtllhStitutioriaicOntr61i. efiglri~> C()ntrt>Is;~r treatmen~, .' ".:.,. '. . ..... '., >' .

Compllan(:ewith ARARs.evaluates~ether.the alternative meets federaiand'st3teeiiVirOnmentai staiut~.,~, >. '.

regulatlO'ns; and other rtKiliiremerits .thatare leQaUY applicable; or teJeVant and appropnateto thesitel orWheth~ a.<,walwrls'jusptied> • if. '. ' ..' .' . . . ' •.'. . ,;;';,:. ..',d

. tongoterirJ EtfeClIV8nessi.iJcipermanMC860nsiders the ab"ityofan.aIt8lil~.forllairitainprotecti()n 6fHi.llnari-'L.j . healthang<~~.en~n~nto~ ~Et,.'.;i: .::1'.:,' . ..;. .: ::', .".,,;:~.; .••..,:' ,'".Y;,.:/,.;>,'::

3£i=~I~St~~;~;~~:~~::·~;~~l~ti~~~1#!~~~;~1~ ShOrt-term EffliCtlVenessconsiders the length'of time ne9dedtoiri1.lenlentariaitematlvearid:the risks .the atternatiVe. poses t!iworkerS; the. qOn'lrrrunit}t; ang:the'en~ilrnent durihg. !rripr~en_n';':>;"" ";.~;;' ." .'. :~'; " ",'i.' "..;' .••..><: .

.~~~~~:~ae;~ ...... "~~1~~~:f~~~~~O~;~~,t~~l~~Jr~.'~~~h~~~~~1·~:'· :i:"~~d~~I~S~;,.,,:.:~~~.,Ei~:~1&llm~~:·W.~b~;.illi~ ~.1tf'~l~~~~~\~~1~ti~~:~~p~~ml'" ,~,1;{~~K~~~~~~~~~~~t~lift'ifWii.&;;!~;~~~s'• .~.~.~~~~~~~~~~t~••~~.~~~;~I;;r;

.' principal threat LNAPL and comply witli the substantive requirements .of the applicable laws and.regulations, EPA has developed':site:-:specific rt!m~diation goal~ that an~ consistent with the expectations of the New Jersey Techni~al. Requirements fOr the reme,diationof free product (NJ.A.C 7:26E-I). The Resource Conservation and Recovery Act (RCRA), 40 CFR 261, is, applicable for assessing the disposal requirements of potentially hazardous solid wastes, such as the LNAPL-c~ntaminated soils: Based upon the available, documentation, EPA has concluded that' the LNAPL wastes are not listed hazardous waste,

, nor do they exhibit hazardous characteristics; therefore, they do not require treatment to meet . RcRA LandDisposal Restrictions.

It should be noted that the active alternatives require the disturl?ance oftheon-sitewetlands. Restoration of the wetlands is not included in< . these alternatives, asa significant full-scale remediation effort is expected to follow this Early Action. Therefore, wetland restoration will need to be considered as part of the overall remedial action for the site.

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3: Lon~-ternll):ffective,ness an(i. P;~rmanence

The, Nq Action alternative offers no long-:term effectiveness orpennanence.. For Alteniatives 2 andJ, the potet;ttial risks from!he principal threat LNAPL would be reduced, altho,pgh both

I alternatives can be expected to .leave some residual LNAPL in the remedial target areas, Alternative 4- eliminatesprincipa'l thieat LNAPL

. within the remedial target areas. As disc':lssed earlier,·this action only addfesses LNAPL that is considered a principal threat; under all the active

.alternatives, lower-level threat LNAPL would remain on other areas ofthe site.

Other than water from biocell dewateripg during operation, no treatment residuals are expected .

'. from Alternative 2:' Treatment residuals, in. addition to water from dewatering, are expected froIp Alternative 3; the conc~Iitrations ofprincipal threat LNAPL and associated contaminants are

. expected to be high in these residuals (e.g" filter .cake and blowdown water froJ!1soilwashmg). The residuals from Alternative 3 are assumed to' require 'off-site treatment anddispcisal. There are

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no treatment residuals for Alternative 4, as this alternative involves the excavation and Off-site disposal of all the waste.

For Alternatives 2 and 3, at the end of the implementation period; an isolation barrier would not be needed around the treated soil, as the

. treated soil is expected to be of similar characteristics to the surrounding soil, including some residual LNAPL and some underiyiJ:tg constituents that would riot be treated.

Unde~' Alternative 4, an isolation·barrier,.around the perimeter oft~e remedial target areas would need to be maintained between the new backfill and the surroilnding soil. . This isolation harrier would be needed as theremediateqarea is expected to contain no LNAPL and no other contaminants compared to' the surrounding soil. The surface would need to be graded to dram clean surface water toward remediated soil such

. that there is a slight positive gradient,from within the remedial target areas to the outside. Thus,

. while Alternative 4J)rovides more long-term perman'ence by addfessing all the LNAPL and all the underlying constituents not treated by Alternatives 2 and 3, it achieves a level of remediation - a "clean island" in the middle of still­contarriplated ,soils - that requires more rigorous '. efforts to maintain. .

4. Reduction of Toxicity, Mobility, or Volume I . . .

of Contaminants Through Treatment , > .

Alternative 1 provides no reduction in toxicity, mobility or volume. Alternatives 2 and 3 would reduce the toxicity, mobility and volume of the, contaminants in th~ remedial target areas through treatment. For Alternatives 2 ~nd 3, the treatment is permanent.

Alternative 4 does not use treatment - rather, the .' toxicity and volume are transferred from the site through off-site disposal.

5. Short-term Effectiveness

There are no short-term effective~ess issues

associated with the No Action alternative. _ Alternatives 2, 3 a~d 4 would present some short­

term risks to the community(dust, emissions, soil erosion.); however, these risks can be, controlled through engineering controls. Risks to workers during implementation also can beconirolle,d through ~afety procedures and the use ofpersonal protection. As noted earlier in this Proposed Plan, there are. no residences within half a mile ofthe

'site. Short-term conce,rns would relate to any potential impacts on industrial and commercial neighbors.

All ofihe alternatives involve exc,avation. Risks . . to commercial and indu~trial neighbors can be

controlled through engineeiing coht~o Is such as soil' erosion controls, dust suppressants, and the implementation of spill prevention and response procedures. Risks to workers 'also can be controlied by using safety procedures and protective equipment. ;

Short-term risks associated with Alternative 4 would be the greatest bedmse'ofits larger transportation component (both contaminated soil and clean backfill need to be transported from and to the site). The short-temirisks are expected to be the lowest for the biocell construction and operation.

This Early Action will be the first of several remedial actions for the site; therefore, one short- . term consideration would be whether thiS action ' . delays or otherwise,limits future remedial decision-making. Alternative 2 appears to. pose the highest likelihood ofconfounding future

... remedial planning because of its longer operational phase. Thebiocellmay also take additional time, beyond the projected five years in the FFS, to reach the remediation goals, and a longer time· period may interfere with o~her rellledial planning or with the timely reuse of the property. As discussed above, wider Long~Tenn Effectiveness aJ;1,d Permanence, Alternative 4 poses the plausible ,scenario of a "clean island'~ within an area with a long history of industrial use, where a future remedy may heed ,to choose to either to ~aintain

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. this cleaner zone at high expense, or allow it to be ~econtaminatdl.

6. Imple.mentabilitY

There are rio iinp lerheritability issues associated with the N.o ACtion.althriative.·· Alternatives 2,'3 .

. and 4 are considered implementabk~ from a . construct~bility-'perspective. PossIble challenges common to. allthree atternatives inClude the difficulty ofinstalling sheet piles iri Clayey soils, . excavation dewatering and water treatment, phasing cell construction,. and uricertamties in the

. depth to and variabilityofthe native clay layer.

Because of the complexities of the equipment and proce~s; the soil washing technology is expected· . to have a higher potential for delays associated with equipment problems; portions of the principal threat LNAPL soils are clays'and oily wastes that will pose significant materials handling challenges; therefore, preparation of material fof placement in the biocell and for the feed to the soil washing process is critical for both al~ernativ~s, . although probably more so for the soil washillg process; As described in Alternatives 2 and 3, the most highly concentrated areas of the site, where floating product is found, cannot likely be treated through either the bioceU or through· soil washing, and would need to' be transported off site for disposal.

Equipment ~d specialists arecornmercially available and sufficiently proven for aU three alternatives, although fewer vendors are available for competitive bidding for the 'soil washing technology.

Alternative 2 would require operation over a . longer period (five years ofoperations are

estimated) than Alternatives 3. imd 4. The O&M activities needed for this alternative are routine, and failure 0 f ~ component 0 f the alternative is not expected to result·in any significant threats to public health or the environment.

.,7. Cost

The estimated present wb~h cost~'of-Alternatives . 2, 3 and 4 are $17.3 million, $18.4 niillionan:d .. $19.5 million, respectively .. ' There are no costs

associated with Alternative 1.

8. State/Support Agen,cyA~ce~.t~nce

j The State ofNew Jersey cbnc~rs with EPA'~ preferred alternative in this Proposed Plan.

. , 9: Community Acceptance

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. Community acceptanceoftl1e p~efeired.altef!1ative "will be evaluated aft~r the public comment period ends and will be .described in the Record of Decision, the dQcumentthat fOfmalizes the

. selection of the remedy for the site; .'

PREFERRED AL TERl'JA TIVE .

Based on an evaluation of the various alternatives, EPA and NJDEP recommend Alternative 2, the on-site biocell along with excavation and oil·site disposal of the more highly contarni9ated material .

-as the preferred alternative to address the principal threat LNAPL. This alternati,:,e involves isolating the rem~dial target areas with sheet pile walls, and excavating the piuicipal threat LNAPL areas, a total of approximately 45,825 cubic yards of material. The more highly contaminated portion oHhis materia~ including aIiliquid LNAPL at a

.minimUII\ will be transported otrsi~e for disposal. The remaining excavated material wo.uld.then"be . augmented with riutrients and bulking ~gents to enhance permeability and the conditions for biological activity, and the area within the sheet

. pile walls would be converted into a biocell by installing piping for air and nutrient distribution and a collection system for air and water that may accumulate iIi the biocell. The augmented LNAPL material would then be placed in the . biocell for treatment, and capped.

Operation of tb~ aeration, nutrient distribution, and water collection'systems for the biocellwould

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be required for an estimated five-year period. Perfonnance sampling andfinal confirmation samplingwouldbeconducted to demonstrate that the LN APL wastes have been destroyed through biological degradation, at which time the biocell c~mponents would be dismantled ..

In addition,to liquid LNAPL, soils with LNAPL concentrations that are found during the remedial design to be unsuitable for treatment ill the biocell (based on factors including the effectiveness of the . technology to achieve cleanup goals, the projected time period to do so,engineering concerns, etc) would be excavated and treated via stabilization, if needed to allow for transportation, and transported for off-site disposal.

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The preferred alternative would achieve tl).e remediation goals that are protective for the principal threat LNAPL, but asubsequent'decision is still pecessary to address the underlying constituents within this material. Thus, the need for institutional controls, such as a deed. notice or covenant, would be determined as part ofa future remedy,

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The preferred alternative isbelieved to provide ,the best balance o ftrade-o ffs among the alternatives based on the information available to EPA at this time. EPA believes that the preferred alternative would be protective of human health and the environment, would comply with ARMs, would be cost-effective, and would utilize pennanent I

solutions and alternative treatment technologies to . 'the maximum extent practicable. The selected

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alternative can change in response to public coInIIient or new infonnation.

Consistent with EPA Region 2's Clean and Green Policy, EPA will evaluate the use of sustainable technologies and practices with respect to any . remedial alternative selected for the site. .

COMMUNITY PARTICIPATION

EP A encourages the public to gain a more comprehensive l,lnderstanding of the site and the

Superfund activities that have been conducted there;' '.

The dates for the public comment period, the date, . location and time of the public meeting, and the locations· of the Administrative Record . files, are provided on the front page of this Proposed Plan. Written comments on the Proposed Plan should be addres~ed to the Remedial Project Manager, .' Grisell V.Oiaz-Cotto, at the address below.

EP A Region 2 has designated a public liaison as a point-of-contact forthe com,nunity concerns and questions about the federal Superfund program in New York, New Jersey, 'Puerto Rico, and the U.S. Virg~ Islands. To support this effort, the ~gency has established a 24-hour, toll-free number that the public can call to requestinformatiqn, express concerns, or register complaints about Superfund.,.

For (urtller. iilform!ltion'oli ttie,Diamondbe1ld'site,;, please~p'ea~.~t"f;:'f'«' . . ,,::,,"», .,

.. , . ....

Gris~lrV.Df~~ort~; ·····'WandaA~~<.'L. '. ~e~~~p~o~~~.".';.·. '. CommUnity~datibDS.,

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NewY6rk,NewYorkIOO07~1866".: . ...,.·J.:..,:..,....."c. ."';' .. ,., ';",.,. .:, ·.:.... 0 ,.':!, .".''''::' .'

Writteiic~mD1ents'bDthis. propo8~d·pla~sb~ulclbe,

'~J.f~;~~~~~~i;"i~k RegiqnafpublicLiaison' .' ' .. ; . T()l1C~e(88,~):,28,3~7~:26 ':,>'. (7~2}371~662t;':: ";

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U.S;EPARegi~n4/i , : 2890W~ndgc:,Av(!IlUe; MS;.21i·· " Edison, New J~n-S ()8837~3679, '

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Source: Hagstrom Union/Hudson/Essex County Atlas, 1990

Hudson County, Page 5, Grid C-7

Figure 1 - Diamond Head Oil - Site Location Map Vacant Lot Adjacent to 1235 Harrison Avenue Kearny, NJ 07032 (Hudson County)

See Also: USGS 7.5' Quadrangle: Elizabeth, NJ: Photorevlsed 1981 4Q044' 50" lat. 74° 07' 55 .9"1000. (NAO 83)

o 87.5 175 350__===:::J____ Feet

Figure 2 Proposed Remedial Target Areas

Diamond Head RifFS Kearny, NJ

CH2MHILL

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, Table 1

Summary of Chemicals of Potential Concern for the HHRA

Diamond Head RifFS. Kearny. NJ

Subsurface 5011 (2 t~ 12 Surface 5011 (0 to 2 feet feet below ground

GroundwaterSurface Water tielow ground surface) surface)Sediment

Chlorobenzene Benzene Benzene' Benzene Benzene Chloroethane ' Chlorobenzene Oic'hloroblirizene-1,4 Ethylbenzene Bromomethane Dichlorobenzene-1.4 Chloroethane Ethylbenzene T etrach loroethylene Carbon tetrachloride Dichloroethane-1,2 Dichlorobenzene-1,3 Tetrachloroethylene Trichloroethylene Chloroform Dichloro~thylene-1 ,2 cis Dichlorobenzene-1.4 Trichloroethylene Xylenes. total Dibromoethane-1.2 Tetrachloroethylene ' Dichloroethene-1 ,2 trans Xylenes. total Acetophenone . Dichl.orobenzene-1,3 ! Trichloroethylene Dichloroethylene-1,2 cis Acetophenone Benzo(a)anthracene DichIOrobenzene-1.4 Vinyl chloride

."' Ethylbenzene Methyl isobutyl ketorie (4-methyl-2­

Benzo(a)anthracene Benzo(a)pyrene Dichloroethane-1,2 ' " r

Benzo(a)pyrene pentanone) Benzo{a )pyrene Benzo(b )fluoranthene Dichloroethylene-1 ,2 cis Benzo(b )fluorantl1ene Tetrachloroethane-1.1,2.2 Benzo(b )fluorantiiene Benzo(k)fluorarithene' Dichloropropane-1.2 BHC. beta' . Tetrachloroethylene Benzo{k)fluoranthene Dibenzo(a.h )anthracene ElhylbenzenJ

. Methyl isobutyl ketone (4-BHC. delta Trichloroethylene Cresol-p ~ Inderio(1,2.3-cd)pyrene methyl-2-pentanone) Barium Vinyl chloride Oibenzo(a.h )anthracene Methylnaphthalene-2 Tetrachl9roethylen'e. Beryllium Xylenes. total Indeno(1.2.3-cd)pyrene Naphthalene Trichlof98lhane-1,1.2 Cadmium Acetophenone Methylnaphthalene-2 Aldrin Trichloroetl)ylene Chromium Cresol-o Naphthalene BHC. alpha Vinyl chloride Iron Cresol-p Aldrin' - BHC. beta Xylenes, total

ead Cresol-parachloro-meta BHC. alpha Dieldrin Acetophenone Manganese DimethylpheI)01-2.4 ODT-4.4 Heptachlor Epoxide Benzo(a)anthracene Thalli~m Ett)er, bis-chloroisopropyl Dieldrin Pcb-aroclor 1016 Benzo(a)pyrene. '

Methylnaphthalene.2 Heptachlor Epoxide Pcb-aroclor 1242 Benzo(b )fluoranthene Naphthalene Pcb-aroclor'1242 Pcb-aroclor 1248, Benzo(k)fluoranthene Nitrophenol-4 Pcb-aroclor 1248 Pcb-aroclor 1260 Dibenzo(a.h)anthra~ene

, PCP (Pentachlorophenol) Pcb-aroclor 1260 Aluminum Indeno(1.2.3-cd)pyrene Phenol Aluminum Antimony Methyln'aphthalene-2 Phthalate. bis(2-ethylhexyl) (DEHP) Antimony Arsenic Naphthalene Trichlorophenol-2.4,6 Arsenic' Barium Aldrin DDD-4.4 Barium Cadmium BHt::. alpha Dieldrin Cadmium Chrbmium Dieldrin Heptachlor Epoxide Chromium· Copper Heptachlor Epoxide Aluminum Copper Iron Pcb-aroclor 1016 \

Antimony Iron 'lead Pcb-aroclor 1242 Arsenic lead Manganese Pcb-aroclor 1248 Barium • Manganese Mercury Pcb-aroclor 1254 Chromium Mercury Nickel Pcb-aroclor 1260 lead Silver Selenium Alu,minum Manganese Thallium Silver Antimony Nickel Vanadium Thallium Arsenic' Selenium Zinc Vanadium Barium Thallium' Zinc " Beryllium Vanadium I Cadmium,

Chromium Copper Iron lead Manganese Mercury Nickel Selenium Silver Thallium -

V,lOadium Zinc

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:. ATTACHMENT· B

'PUBLIC NOTICE

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.Kearny .Vice'Squad busy this·summer,drug'bustsabound FrORl the Desk. of ChiefJohn Dowie

.on five. separate' occa­ veillance ,.in 'the area of by the detectives, they sions d;.nng the month of Kearny and Belleville Pike found S2-small packages of

June and twice so far in and followed him to the area heroin. Both men were then

July, persons attempting to of Seeley arid Kearny Av~ placed under an arrest. ~ell drugs in the Town of enue where hi: met with an­ On June II at 5:30 p.m.,

Kearny were detected and other person operating a Officer Mike Andrews con­apprehended by members of vehicle with out-of~state fronted four men on 'Chesr­the, Kearny Police, Depart­ plates. nut Street after a call ment at various locations The detei:tives saw what' concerning possible drug throughout the tOwn; they believed to be a drug use in the area and saw a 20-

On June S, at 11.30 a.m., transaction taking pla.:e in year-old mail attempr to Oct. Sgt. John View, Oct.' the vehicle and approached conceal a plastic bag. \ Brian McGaiTy and Det. to conf'mn their suspicions. Officer An~ews took

Michael Gonzalez placed a On the Seat they saw a large control of the man and re'

sUspicious person iIildl:r sur- , plastic bag; Once recovered . covered the' plastic bag.

TbeSchool Business Admlnistrator/Board Secretary of the »arrison Board of Education, In the County of Hudson,'State of New JefSey, by autJiority of said Board, solicits sealed bids for student transporta-. .

'tion. Bids to be received at the Business Office of the HarrisoB Board of Education, located at 517 Hamilton Stre8t, up to 10:00 A.M; prevailing time. on July 28, 2009.

STUDENT TRANSPORTAnON SERVICES ' 2009-201 0 School Year

SpeclHcations are avillable upon request at the BuSiness Office of the, Harrison Board of Education; located at 517 Hamilton Street, Harrison, New Jersey, 07029.

.All bids must be submitted on the bid lorm contained in the specification,. Bids which are not submilled on such form may be rejected. , Bidders are required 10 comply with Ibe requirement of N.J.S:A. 10:5-31 ct seq. and ••J.A.C. 17:27 AffinDative Action. . lbe Board 01 Educatlon'reservesthe right to reject any or ali bids.,

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By order of th. Harrilon Board of Education. ' /

Date: July 6, 2009

."t"fJU.~

/~~.~ ." i '\;"("'u~e~

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY INVITES PUBLIC COMMENT ON THE PROPOSED REMEDY

FOR THE DIAMOND HEAD OIL SUPERFUND':SITE

The U.S. Envirorrnentai Protection Agf!N:f (EPA) wilt held a public meeting on JUly 22. 2009 at 6:00 pm at Kearny Town Hall. 402 Kearny Avenue. Kearny. New Jersey to dI,scuss the p<eferred remedy for the Diamond Head Oil Superfund Site and the basis lor !his p<eference. The p<eferred remedy. whiCh is desaibed in

. the Proposed Plan incfUdes.the consI1Uaion 01 an on-sita biocall to lacilitata the bi~~·1 of thttjj~ I')Q(I.~ Pi~i.Quia~(biAftla..

Bef0l'8 &electing the final remedy. EPA Will consider orai oommenlS presented at the public meeting and wrttwo comments received onCe bafOl'a August 170 2009.

Copias of the Proposed Plan and the MTlirisllliliva Record fOr the site are available ai the following focations:

Kearny Public Ubrary , US EPA Records Center 318 KOamy Avenue 290 Broadway. 18'" ROor Kearny. flU 07032 New Yol1<. New York 10007,1866 201-98&-2666 212-637-4308

(. By Appointment ~nIy Written convnents shoutd be sent to:

Grlsel; Oiaz-cotto Remedial Project Manager . U.S. EPA. Region 2 New York Ramediallon Branch, f9" Floor NewYorl<. NY 10007,1866 djaz-cottp.grise!t@epa.aoi (v) 212- 637-4430 (fax) 212-637-4429

For further iRfOlTllalion, please con!act Wanda Ayala. Community Involvement Coordinator at 212-637·3676"

which was found to contain men from thi: car and subse­ Strect after one showed

five smaller bags of maric quently seized sevenil bags sign. of being under the in­

juana - packaged for sale. of marijuana and numerous fluence ofan i.ntoxicant.

The man was placed under "EcstaSy" pills from the'trio. 'After confirming their arrest for possession with Dctective~ later searched . suspicions md confronting intent to distribute. 'a, Jersey City apartment the' two mcn. thl! officers'

'. 'On June 15 at 9 p.rii.. rented by rhe men and un­discovered that betwe"n

vice detective.' raid~d a covered a large amount'of them. the men had 14 pa~k'­Kearny r~>iden.:~ neM the E~::>tasy, cuw:aine, Ketaminc, ag~s tlf h~r(,in .:u.~J .....c\, ~B'Bell~\'illc Pik~ after rocci\'­ r.·)J111al..k~hy\'kt ;.t.•lJ ::".lks a~ Xanax pills. One man had'ing information 'regarding well as paCkaging materials.

drug-distribution opera­ On June 26 at II p.m .. five outstanding ''''.!Tant:;. ' tions. Det~~tives arrested a vice detectives' executed a On July 7 at 9.3u p.I'n:.· 20;year-old Kearny man searcb warrant at, 'a Prospect Officer Neil Nel.on ""';b "Ii

and recovered marijuana, a Place home and uncovered loor patrol 'in Ihe area vI' scale. packaging materials cocaine; steroi~. scales, Kearny and Johnston. ~t\v­and a handgun for which the packaging materials. hypo­ enu.i when he'saw an 18­

" suspect was charged. 'dermic need·les. currency ycar-old Newark man that

On June ~2, atll p.m. and a handgun. They arc he knew to be walllcd by police. . ' members of the vice unit rested thc 30-yliar-old resi­

placed a vehicle under sur­ dent of the home who has Officer Nel;"in placed veillance in the area ~r 8el­ an eXlensive criminal his­ the man undi:r arrest and

'grove Drive and saw what. tory: , conducted a ,,,arch. which' they believed to be drug ac-. ,On July 3. at 4:30 p.m.

produced a phislk bagtivity taking place in the ve- members of the Directed hicie. ' found to contain s""~n'Patrol, Unit pia~ed two

After confmning their kn.lwn drug offenders under ,smaller bags of marij uana

suspiCions. detectives or­ surveillance. in ihe area of pad;aged for sale. dered the three Jersc)' ('ity Kearny Avenue and Boyd

. .... .~. - .... ~, ,... ...,' . . . ..

"" '. ····/FiI'-Plarined Parenthooa' , 1(#. of Metropolitan New Jersey

ATTACHMENT C.· PUBLIC MEETING TRANSCRIPT

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,Page .1

UNITED S'rATES ENVIRONMENTAL PROTECTION AGENCY (PUBLIC MEETING i

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IN RE: " \

DIAMOND HEAD, OIL SUPERFuND SITE

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J~lY 22, 2009· 6:00 p.m.

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, Meeting held ,in the ~bove-entitl~d matter at

Ke.arny Town Hall, 402 Kearny. Avenue, Kearny, /

Ne~ Jersey, before Linda'A.· Marino, Registered

'Professional'Reporter, Certified Court

Reporter, artd Nbtary public within and forLthe " "

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State of New Jersey.

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Fink & Carney Reporting and Video Services 39 West 37th Street * New York. New York 100·18,. '(800) NYC-FINK *Fax: (112) 869-3063

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Pag.e 2

PRESENT:1 r

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WANDA AYALA, Co~unity Involvement Coo;r-dinator, EPA

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"-GRTSELL V. DTAZ~COTTO,

F.emedial Pr~ject Manager,~EPA 6

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8. OTHER REPRESENTATIVES:

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.ANDREW B.' JUDD, Hydrogedlogist, CH2M Hill

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11 CHUCK NACE,

12 Environmental Toxicoloist, EPA

13 JOHN PRINCE,(/( Section Chief, EPA\

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Fink & Carney Reporting and Video Services· .' 3t) West 37th Street * New York. New York IOOIH (XOO)NYC-FINK * fax: (212) X6l)~.~()h.1

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. MS; AYALA: 'Good evenlng. My ;

name. is Wanda" AY2ila; ,and I am' the

Cormnunity InvolvernentrCoordinator,\ . , ....'" ' ." .

assigned to the Diam~n:d Head Oil

;Superfund Si te. , I'm, here tonight wi th ' \. ' \. I'" John Pr'ince, OUlr Superfurid manager; wi th

Griseli Diaz~Cotto~.who is 'the remedial

project manager;. with Chuck Nace, who's

. an EPA risk assessor) , and wi th,Andy

.Judd, who 1 s' a contractor for the site.

'We're here to preseht the , (

proposed plan for the Diamond Heird Oil

site, to discuss the preferred remedy

,for the site,' to go over our

recommendati:onsfor addressing the

contamination, ana; to dj:scuss'our

rationalefor'this·reconunendation.

The public comment period for . , /'

this/pro~osed plan started on Jul~ i4~

and it's for thirty days and we are,

required to receive public conunents.,

All conunentswill be, duly noted tonight.

by our stenographer, Linda.'

It is important ,that everyone

here know that EPA's community

Fink & Carney Reporting and Video Services . , 39 West 37th Street'" NewYork. New York 1001 R " (ROO) NYC-FINK'" Fax: (212) X69-306.\

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involvement prqgram 1S committed to

prpmoting communication between the

public and the agency~ Activ~ public

involvement and transparency is crucial.

to the success of any public project,

and our community involvement activiti.es

at this site are designedto.inform you, ~.

involve you, .and include you in the

decision making proces~ since this is "

your community.

I'd like to thank you all for

being here tonight. .And I was going' to . . /" .

set some ground rules, but, since we have

a public of two, I ask that if ,you have

any questions, that you keep .them until '

the end of the pre~entation. And

whenever you ask a question, 'you need to \

state your name .because Linda needs to­

record it. Federa,l regu:lations reqUire

that we have·a transcript of this

meeting to help us' capture your input.

Now I'd lik~ to turn it ,over to

John, who will walk you through the (

Superfu.nd process and information about

the site:

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MR.' PRINCE:' Thank·you ,Wanda ..'

MS. AYALA: You're welcome;

MR. PRINCE:· So~-this firs~ slide

18 a summary of th~ whole. Superfund ­. , ) .

process, and we 'can getyou'a cut '6:£ ) .'

it . And I'm not going:to._ tryancl'-.gO

through aLl,' the pieces. be~a,use we don', t _',

need to talk about all" the pieces'. I 'm

going to hit. on some of the highlights ..

And . the print "is

; sm~ll anyway:.'- . too So,.

,'. we:11 not try and do any more thdriis

necessary .

. , So, let me, tell you.a little ,bit.

. about Superfund. Congress,' the U .,S . /

. Congress, created. the Superfund program \

in 1980 to deal with uncontrolled'

rele'ases of ha~ardous' substances 'at . many

sites that have been: identified in the

past, say, ten years. {;

, . Prior. - to tha.t, there were a

number of states,· including New Jersey,

that already had kind of an

i~fra~tructure for dea~ing wit~

hazardous waste sites, and J in fact, the

Stiperfundlaw .1:S modeled,' at least in

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part, ,on law that already existed 1n New , -'

, Jersey.

But that, certainly wasn't the

case across the country, so Congress

wrote an unified'set of instructions·for

EPA,to have resources, enforcement

authority, and expertise to s'tart·

addressing these sites around the

, country., And then EPA ramped up to. have

the skills over the follow~pg years; the ". ,-,

~kills to actually be able to address

these sites.

Superfund really has two

functions; an emergency response

. fun,etion, and a lcmg-)term cleanup

component. And we come in and address

sites when we,' re invi ted. ,In oth!:=r

-Words,. we don't make ,our own.decisions,

the states really say: Here's aproblern

that we>feel is large and complex and

maybe beyond our funding or staffing ,- .

abiii-ties.

And they invite US'ln.

For the Diamond Head site itself~

we did not have any emergency response

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rele. The site had been sitting idle1 , , '

',fer a· nuInbe'r efyearsbefo:te New Jerseyv 2

~~k~d ~PA tbc6nsider the site fer

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'list:in~r iIi'20D2.,',"

'No'w,'!'h~ving bee~ placed on the

Superfund list do.esn I t mean that there6

ne~ds to. be a cleanup, '. What it' means 1. s7

(that a !site is :-~' has, ~neu~h unJmewn'

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cemponen'ts and eneugh contamination that

mayor may net be, say ~ moving off of J

,~' the si'te; for EPA" to need to corrie and do

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a study.

And, so., 1.n :,this long'-term1J3

" cleanup phase, the firststag,e of bur14~i

. "t·

work is kind of an exhaustive study

'called the Remedial Investigation arid

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,Feasibility Study~ That looks at the , ,

nature and extento.f the contamination'

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and then evaluates remedial options for

cleaning it up.

21 I just want to touch on two other

22 parts 7 0f the Superfund program, as'

opposed to all of th~se'p~rts, and that2~3

is the enfo:rcement component' of the law)4 . \

,and then how we actually select a

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remedy.

Superfund has ver~ strong

enforcement components ,that allow us to

get information to id~ntify pot~ntially

responsible parties, -companies that·

might have done spilling or that sort \Of

thing, and also allow us to pursue land

. owners under certain circumstances to­

either reimburse EPA for the' cost of­

cleanup' or, ,in s6me cases: have parties I

rop~d into ~_ -~ some kind of ~n

enforceable agreement, -.whereby we would

oversee that party to actually perform

the work.

In this case, EPA -- the,'

companies, rather, that had created the (

site in the fi~st place were all out 6f I

business long before we got lnvolved,

and there real~y isn't an opprirtunityto

- that we know 'of there. And at the

beginning of our investigation st~g~,

'when the site was fir~tlisted, we

concluded that there really wasn't a

viable partythatcbuld step in and do

this work. ;So, the work's been done \

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federal funds .• ,,' "

Now how we, select a remedy, I'll

touch on that, describe ~ome details of

th~ site, little ,of the Bite· hi~tory~ . ( )

and thenwe~11 mo~e on~O Grisell's

por~ion of th~ preserttation.

Wh,en EPA feels ,it has enough

irtforination about a ,site to proceed to '., '. .

select a remedYi Congress actually put a

~heck on us; we can't just go and do ,

'that by ourselves,we, need to prepare

some'thing called a Feasibility Study,

which doesn't describe one option but

, ,actuallylobks at a variety of remedial'

choices for'cleaning u~ the ~ite.

Arid then we need to come and'

present that into a conununity ina , ,

written form -- that's the propos~d plan

-- and at a meeting like this sti that we

can get input~ We then get that:

feedback 'in writing or recorded tonight

and need to 'evaluate it.

'And, uSlng our preferred remedy , ,"

I ,

and that information, we make a finding,I

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something called a Record of Decision.

That is a written document that

memorializes the remedy for the site and

any responses to' the public's in.put that

might have affected the remedy or,you

know; our sort of response to that.

We do that in partnership with

. the State of New Jersey. They're our

sister agency·in.this case. So, they

have already seen and endorsed our \

preferred plan for the site.

So, let me switch gears.' We're,

gOlng to talk about the sit~ itself .. -)

I'm going t.O refer to so~e figures, and·

we will start by putting ourselves on

the street map.

This is -- Iwe'll get a better

resoluti'on in a minute, but this is

Harrison Avenue and this is Route 280

along the bottom, and we are lon a

section of.Kearnythat is very sparsely

populated ~ndthe nearest.homes are

probably about half a mile away.

This'is bringing us in·a little

clos·er. Again, here' sRoute 280 on the

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1 bottom, "here's Harrison Avenue, and'.the , , .

activities -":',which I ',11 bringuI=>

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anotherpictuieina minute ,the'. I

activi t'ies 'of t,he 'si te too.k place right4 1 '

here in th~ center'.

6 This/isanentranGe ramp for 280,

7 this is a'place' taIled 'the' Campbell

8 Foundry, andthi'i3 is the relatively new

9 Wal.:...Mart facility., Water, surface

water, drains this way' to s~mething j'

called Frank's Creek, which is right11 ,

her~, ~nd Frank's Creek discharges into

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the P~ssaic Riv~r~

14 Now, this land was marshlands: if r

L you go back maybe two hundred y,ears I .' and

16 it has slowly been filled over time,.

17 It's generally been used'as industrial \

proper~y, i~cludi~gthe facility that we

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are focussing on~ and then.landfills. , . ~

And'the orie other' f,eature' that T

.21 will 'pointout because we're going to '­

talk a~out it_a little lat~~ is this

.23

22

landfill here, which is called the 1-b

24 landfill. It's one of th~ MSLA

landfills. It's about: 95 acres, and

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'it's j~st across 280 from the" sit~. ,

Now we'll gg one ste~ closer and

we're on'to -- you canlookatthe~e

figures here or the figur~ up on the

board. This 1S a current photograph.

And by shqwing this pieGe, though, I \. ".'

don' t wan~ to mis~lead you; this' is

narro~ing into a little parcel, but I

(. . . .'dOh't want to glve the lmpreSSlon that

that's the ~holeofthe site,. That's

the'whole of the, subje9t of'tonight's

meeting, bui for reasons you'll se~ in a

'minute', our investigations have -gone

outside of this parcel.

This piece is about fi;fteEm acres

on the -- the facili ty sat right here"

on the sort, of eastern edge 6f the lot.

And there's a number 6f landfill pieces

that' .~- sort of' surrouridingthe edges of

it how. And we'Tl go through some

'history, an~ you'~l lea~n a little, bit

about those.

So"I im gOlng to talk about .:..­

with regard tQ site hi~tory~ I'll ju~t 'C

~a~k'about four t~ings:. I'll talk

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about, ,,' obviously, . Diamond 'Head oii

Refinery; the neighboring lartdfilling ,

businesses i,the construct.ion ofI-:-280';

and then sorLof the end of the Di;amond

He~a facili ty that took ,place in '7:,9.

So, Diamond Head Oil Refinery was

one of a number of companies ,that

operated up and down the eastern -"':')the r

.' : . .

East Coast\ of the United States that

were in the business of collecting waste \

oil fiom gas, stations and other places,

and then reprocessing it through.some , ,

magi~ into m~terial that they could

reuse .. 'lfud, they -- these variety of

co~panies, most of whlch were ,owned by

e~sentiallyone entity, would send this L

waste oil to f~cilities like this~

Anqhere is'an aerial photograph

from 1976, and Here is about a four..:...acre

piece of land that is just' a little bit

elevated that was, the Diamond Head

facility, whlch started operating in 'the

1940s and finished its run in 1979.

Now, the key feature from'th~

point of view of this facility i~i

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obviously, there's, lotsbf t~nks and

'businesses --.the'busiriess' pieces of - ,

equipment. They would bring in this _-­

waste oil and they w6uld re-refine it~

which is essentially, we think,' kind of

sending it back t6 the refinery to sort

it out into usable components. It f

seemed that most of it 'was going into a

kind oJ , he'ating 011 and then being

resold.

-But what I want to poiritout is

this black feature here, which runs

quite a bi t,off of that fi,fteen-acre, lot

,tha t ,yousee a?ove me. And it's

es~entially a mikture of oil and water.

We call this the oil Qake: It's about' I

it';s been e~timated that·itwasabout

six-to seven acres in size.

We don.' t know exactly how it got

th.ere, whethe~ they were actually

storing some of this w~ste oil.ln this . , '

sort of open water are~ behind the

facility or whether it was just sort of

running out of their facility because it

was sloppy or whether possibly they

Page 14

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'c6uld refin~ ceitain of their waste oils . .(', . .., , .

into reusable pr9duyts and then ,they

just' ended up with stuff" th~yhac1to get

rid 'bf and maybe that's, what, this is. . , '

We don't really know. ! But, ,obviously, . \/ - .', ..

it's .gone quite' a dis tance froTIt the

original land. I

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So, ,I'~ going to also ,point but

one' o-ther f,eature' here, and. that is this \

-- I'm going to run a line right down ,

, here, sort of top t,o bottom. This is '

that 1-ri Land,f i 11 that I mentioned' (

before,and this I.s,an access rca¢! to'

get up orito that landfill. There's

access roads on either end of it.

And,'~O, this end of that

fifteen-acreiot i~ ~ct~ally filled

sort of ~ long filled area~ and it's

pretty clear that this was -- it'was

filled wi ih municipal waste.~ We've done

so~e test pitting, and it 's p~etty clear '\ ,

i,t's filled prl.marily wi th municipa-l'

waste, and 'they built it up SD they

could have access tbthe landfill.

Now, starting in 1976 and ending

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,

a couple years later, r the ,New Jersey'

Department of Transportation began the /

construction of 1-280, which now fills

the southern end of ' our area of

interest.

In 1976, they got to this part of j ,

the site and concluded that they

actually owned quite a bit of t:Q.is land

where the oil lake was. They concluded

they couldn't build on the o~l lake.

They had to get rid of it, so they paid

to have it pumped .olit.

I ttook about, ~I think, ten J

months. It was somewhere in the

neighborhood of eleven million gallons­

of oil and water that were removed: It

was pumped into tan)<.er trucks and ta~en

to other taciliti~s that ~id this sort

of waste oil busines.s.

When they got 'the lake pumped

out, . there was a layer, of kind of a r

messy s~u'dge at the bo~tom, ancl they

concluded that they couldn't' build on

that, either. , , ,

So, that material was

scraped off .. It totalled approximately

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230,000 cubic yards, 6f mater'ial ~ 'And e f . •

- from, DOT's, records, from the t im~; '~they

redeposit~dit'i:n.the:ground'ina couple

of locations.

The largest piece :ts actually up

on top of ,the I-D'landfill. ~here are

several other I'll r~fer to this

finished pictureoverhere~Ther~ is , ,

this landfill ~iece t~atI mentioned,

before; there' may be, some of' that

.' material in here, although we ha\(en't,

seen i t-. And then there's something in

this right-of-way to the 'highway'that's

actually o'lll!Iled by D01' that's a mound,

" And we 've done some sampling' of

it, and there is something thai looks

like sl~dge in it, so that apparentlY,:ts r where a good portion of 'that material

, , ,

went as we'l~l.And we still have some'

investigations, of "that material to do of

our own to figure o'l:lt whether we need to (

take ~n action with,regard to that as

well.

One of the comments that we've

read :tn DOT's records con~emporaneous

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. with this actJvity was after the removal

of, .the oil lake and after the removal of. ,

the sludge, they indicated that there

was still a layer of this oily petroleum )

material ln the ground, and it's that

mat~erial that's really the focus of our

action that we're discussing tonight~

~hey saw ,it -- th~y called it the

. underground oil lake.. .So, that' sreally

wha~we're focllssing ln on with this

action.

That's. about all that I wanted· to ("

cover, . except that Diamond Head,_ the

company, closed down in. 1979. The owner .

had some legal. troubles about' the same . , I

.time ,and we t:hink tha.t there's some

connection between those twq; th~

closure and his legal tr~ubles. And the

'place'was actually demolished·a couple

years later, and during that -- it'was

really a cleanup,' the· first cleanup that

took place at the site.

And during that work, some

environmental samples were collected,

and those environmental' samples were the'

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1 first ~vidence th~t -~in the recoid ~ .f

that ,indicate' that " :In fact, what2 . .

·3 Diamond Head was bringing to: the si"te

wasn't just pet.roleum wCl.ste, it'was some4

other things, .~fi:. th PCB's and other

6 . volatile components! that were probably.

7 - .

getting mixed ,into his. produ~ts, and

8 some' of which, obviously, are -- have

ended up in· the' ground. '

So, we'~elo6king' at, as a

9

consequence,·thisrelativelY large area.

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.for the whole RI/FS. We're Jooking at

the groundwater .. We have, a lot .of'13

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I

information but need a'little bit more

. on .the .soils' in the' who.1e of this area'.

16 And then we need to really understand

17 about surface water ,moveme'nt of this

18 material. over' time, .and whether there's

19 a component.of that.

But that's to COme. Right now, -, . (

21 we're focuss1ng ortreally this one areaj

22 which Grisell is going to tell us about

23 by describing the details' of the RI/FS

24 to date and what we found and 'then what

oUr proposal is to ~ddress it. " ./-.

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MS. DIAZ-COTTO: Good ,eVening;

~I' m going. to give you a preview of what ,

I'll be pres~nting to you tonight. ,

The first thing I'll be

discJssing ~sthe Remedial Investigation

study to· date,. its findings and

conclusions. Then '1'11 provide you with

,information wi th regarding the priricipal

threat waste, the remedial.objectives

for this waste, a~d the risks

attributable tothe.site.

Following, I'll. explain the

rationale for the remedial/phases

approach that we are following for the

site. I will then p~oceed wit~ the

,presentation of the remedial

alternatives, the evaluation of these

al ternativep, .and,finally, ,wi th the

recommendation for the preferred

alternative.

Let me start, however,wit~ the

definition-of a term I'll,be using

,throughout m¥ presentation;·LNAPL.

LNAPL stands for Light Nonaqueous

Phase Liquids, which are 1 iquids that·

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, 1 'are sparingly soluble lri water:aridless, (

dense than water. For example,' oil, is2 , \ '

an LNAPI,. ,pecause,it" flows on' top ~of '3 . . .. ,

water "and, ,does not mix wi th water.',4"

In 2002, 'EPA began a Remedial

Investigation to determine the nature6 . ~., '. .' I

andextent'of the problems posed by the7

site. The Remedial Irivestigation8' } . . .

studies ,to date have outlined, in;9 1,

addition to all the findings that I'll'

11 b~ discllssinglater) two areas of

12 poten~ial 'source areas 'where LNAPLmay

13 be continuing t,o release <;:!ontamination

. i : 14" to the environment.

This area: is outlined in ied. . '

The processing ~ection,ofthe site, once'16

containing ,two buildings, multiple

18

17

above-ground storage tanks, 'as you can

19 see there, drum storage areas" and I

possibly un~ergroundfeeds'. And second; \ ,

therernnants of ,the, 011 'lake,' estimated

iti1977 took over an area of six to

seven acres, located over the southern

section of the site and ext~nding

21

outside the, site's fenced bound~ries to

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l' .the east and south. \

.) There ,is evidence of oil2

contam~nation in nearly every boring3 . .

installed withiQ thefi£te~n-acre fen~ed:4

5 property ~nd in \many borings to the

s'outheast. 'Becaus'e of this layer of' 6il '6

contamination across the site, the RI7 (

studies performed to date have used a8 . . .. \. " '

number of differentme.thods to document9

the nature and extent of the LNAPL and10

11 . . to identi fy' ,the. more' severely' . " )

contaminated areas of 'the site.12 ), '

"\

Using·these meters, 'several13

characteristics of the LNAPL were'14

es tablished. . Firs t, LNAPL is' present inis

the subsurface throughout most of the16

investigated area, albeit under17 (

~ substantial variation and con6~ritration(18

acro$s the site. '19

Second,LNAPL was measured ±~20

wells ,in three areas of the site; one'ln­21

the fo;rmer process area, and two.within22

the foo~print'oi the oil lake. T~is23

24 . means that when the well cap is moved,

·w.e find a thick layer of oil 'rather' than25

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water. ., l ' ..... ,

. Thir;d;, the vertical' distribution

of LNAPL 'existl at two' il1.tervals; first

at the water table ~pprbximately two

feet below ground surface, ahd, second,

as distinct deeper int.ernal depths at . .

ten. to sixteen feetbelo~ground surface.'

wi thin the silted. s'oil..Ho,wev'e'r ,the \,,' • / < I

bulk of LNAPL':"cbntaihing soil is loc~ted

near the water table within the filled

layer.

Many of those compounds were '(.

foul1d in' the LNAPL, including benzene

and other petroleum comp'ounds,' PCBs,and

a variety of metals. Within'the LNAPL,

th~re are pockets of less weathered

LNAPL of a high saturation that present

a leaching. concern to' groundwater.

These.are LNAPL areas that maybe

corisidered to present a r'isk for

leaching co~taminants to.groundwater.

This highly contaminated material is

what we. are focussing on with this

proposed action~

In addltionto the LNAPL findings

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1 disctissed before, the remedi~l

\ 2 investigation found soil, groundwater,­

3 sediment, and surf~ce water

4 . contamination attributable to the site.

Evidenc~ based on site-specific

6 data conclude9. that LNAPL .detected at

7 the si te was separated into areas ,where,

8 LNAPL material-is considered to

9 represent a principal threat and area~ \

where LNAPLcan be considered to be- a.

11

·12

\

lower level threat and for which I

appropriate measures will be considered

13 1n future feasibility studies.

14 I

The total area of the principal

threat of'LNAPL is ro~ghly176,000'

16 square ( . feet,' a

.

vol~eof 45,825 cubic

17 yards, including 2,593 cubic yards where

18 . LNAPL floating product 1S I '. , .

found in wells

19 constitutes the principal threat LNAPL.

, Remedial .action obj ectives, which.

21 are a general description of what the

22 .r~sponse actio~ is expected to

23 accomplish, were. developed for the

24 principal threat LNAPL wastes to address

'the human health risks \

and environmental

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concerns of the Di'amond' Head Oil Site.'

'The focus,of thi.sear:lyaction is

to address LNAPL that constittitesa , ' .

principal thre'atat the' s:Lte., The

prj,ncipal threat LNAPL is physically

similar to free oil' product,. Oil

products'are toxic to ecological

,receptors and hUmans 'through direct

contact, incidental in~estibn, 'and

i'nhala,tion pathways.

Potential exposure to ,ecological,',

, )

receptors and humahs. from'the high

concentration LNAPL that ,is present, at

the site could result in adverse health

effects .. It i is, therefore, important

that steps be taking taken to eli~inate

or'reduce t,he level 'of LNAPL at'the

site.,:

Reducing or eliminating the LNAPL

'at the 'site would· reduce potential

. exposure to free product, ,and that's an

important early step'ln managing the

si te risk. However'", it, is not expected

to eliminate ihe .overall ri~ks'and

hazards to ecologi~al receptors or

Page 25

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1 humans \

because of residual contamination

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that will remain on the ~it~. This

res'idual contamination will' be addressed

4 in subsequent actions and will be

accompanied byfuYl ec:ologi¢al and hUIt\an

6 health risk assessments.

7 In addition to remo~ingthe

8' potential exposure of LNAPL at the, site;

9 reducing or eliminating the ,LNAPL will

11 -,

also limit the potential migration,

--­which vyould aid in investigating anci

12 selecting a remedy fo,rthe rerilain~er of,

13 the .site.

14 The first operable unit has been

":identified as an early action to address

16 a principal threat LNAPL.' A second,

17 Operable Uni,t will address residual soil

18 contamination at,tributable to the site,

19 including lower level. threat, LNAPL, ''\

on-site landfilled area, th~ 1-280

the

21 right~of-way berms, and groundwater arid

22 sediment contamination.

23 Site 'studies a~e ongolng. For

24 example, ,new groundwater moni toring , , '

wells were installed earlier in 2009 on

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a number of n~ighboiing pro~er~ies to

fuliy ass'ess the extent of the

groundwater problems posed by. the site. ;

Field investigations for the

comprehemsiveRemedial ~n.ve·stigation of

the 'site are expected to be cpmplete. in.

2010 j at which time EPA can pr_oceed with

.evaluating remedi~l alternatives for the

(entire site.

While further studieso-f the

landfill site are required, the history

of,site activities arid the test trenches

already installeds~pport EPA's

cbnclusion that the lan~fill ,i~ riot a

$O,urce of LNAPL.

Now let's go to the remedial

alternatives for the site.

The Superfund program r~quires

that the' no action alternative be

considered as a baseline for comparlson

for th~ other alternatives. The no

further actionalternativ~ does not

. include-any physical'remedial measures

beyond those response actions. already

completed that address the LNAP;L

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'" contamination at th~ site.

2

1

Because this alternative will

3 xesult in. contaminants remaining on the

4 site above health-based level, CERCLA

requir·es that .the site be reviewed every

6 five years. If justified by the review,

7 remedial actions may be implemented to. I

8 remo~eor treat the wastes.

.9 The second alternative is on-site·

bio.cell.· Under this alternative, the

\11 remedial target areas would be 'isolated

12 with a sheet pile wall and the principal

13 threat LN~PL areas excavated. Some of

14 this material would be removed for

. ,off-site disposal. ,The remaining

16 excavated material would be augmented'

17 with nutrients and bulking agents to

18 enhance permeability and the conditions

for biol~gical activity.19. /.

The area within the sheetpil~ . \

walls would be converted into a biocell21 Ii

by installing piping to supply air and22 \..

distribtite nutrient a~ditives,along23

with a collection system for air and

water that mpyaccumulate ln the

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Page 28·

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.biocell. The aU9mente'd LNAPL material,

2

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woul'd be placed in the biocell tor

3 treatment~ndc~pped.

After performance sampling and

final confirmation sampling to

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4

demons'trate that the LNAPL ,wastes have

been destroyed through biological

8

7

degradation,' thebiocell components, will

be dismantled. Areas where a 'measurable9 I .

).ayer offloating'\ LNAPL produc:~ is found

11 in monito'I.-ing wells.may hot be amenable

12 to effect treatment in thelbiocell.

13 These are'as will, therefore, be' f!

excavated and transported for off-site -\:

14

disposal.

16 Soil washing. Under this

17 alternative, the remedial' targe,t areas·

18 would b,e' isolated wi th a sheet pile wall

1~ . and'principal threatLNAPL areas

.excavated. The' excavated material would'

21 then be treated~n site using soil

22 washing.

23 The excavated soils and LNAPL

24 wastes would be placed ina slurry

reactor vessel and combined with a

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washing' fluid that wb.uld wash the LNAPL

from the soil part~cles. This

technology' requires a water treatment . ,

facility to treat the LNAPL.and

contaminants of concern in the washing

fluid so it can be reused. Thetreated

soil material would be ,tested for

. compliance with the cleanup goals and

returned to' the excavated areas.

As w{th·Alternative.2,· areas

where a measurable layer()f floating

LNAPL product 1.S found in monitoring

wells may not be amenable- to soil

washing, and this 'alternative .assumes I.

t~at these areas will be excav~ied, \

treated as necessary, and transported

for off~site· disposal .

Whiie this alternative, 'like

Alternative 2, would result in

contaminants remaining wi thin .. the

remedial target areas above health-based

level, this action.is expected to.

. address the principalthreatLNAPL as a "­

final action. A subsequent Record. of

Decision. will be required to make a

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final'determination ab9ut t.:be underlying,~.. '

constituents that'lwill re,mairi within the

treated ,soil\. ­

,Therefore, the need fc,r" a review

bfth~ sit~ everY-fiv~years will be

made' at tha,t' time. If justified by the

Remedial Investigatfon, addi tional' I

remedial, actions may be implemented to-' j

remove or treat such'wastes.-

The fourth'alternati~e,

excavation,and off-site disposal.' Under

this'one,the remedial target areas

would be is6la~ed ~ith a sheet pile~wall, r '

and' the principal threat LNAPL, areas

-excavated.

As with Alternatives 2 and 3,

dewatering will be required prior to

excavation, and the removal water would

need to be tieated prior to dischaige'~

The excavated m~terialwill then-be

,stabili~ed on site to allow for

~transportation f~r oft-site disposal~ I ." '.,'

The excavated areas'wl11,then be

backfilled with clean flll.

Sampling would be performed

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during remediql design to delineat..e! the.

extent of the remedial. t,arget areas, .but

no-performance monitoring would be

required. ,The FE7~sil:;>,ility Study

estimates that this ~lternative co~ld be

implemented ln approximately one year.

Nine criteria, as you ~ee there~

Overall protectiveness of human health

and the environment; .long-:-term

·ef.fectiveness, short-term effectiveness;.' . , \ I

. . im~lemel.1.tabilitYi co~-t; and the. rest._

TheY're used to evaluate the differ~nt

. remediation alter:natives individuallyI .

and ag~inst each ~therin'order t6

select a remedy. They provide. prof-ile'

their relative performance of each

alternative.against ~henine crite~ia,

'noting how it compares to the other

options under consideration;

Once the alternatives have been

fully described and, ind'ivi'dually ) -,; ,

assessed against the nine criteria, a ,.). , (

comparative analysi$ is conducted to

evaluate the relativ.e performance of the •• J

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altei~atives in relation to- ~ach.

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1 specific evaluation crit~ria.

2 The purpose:qf this comparative

3 analysis is to ~aentify' theadvan.tages

4

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and disadvant'ages oL each aTternative ) , ,

relativetoohe another so th~ tradeoffs

6 that·will.h~ve.tobe balanC'ed \to . . -' .)

select

7 aremep.yarefullyunderstood.

8 The proposed plan that you have· a

9 copy of outliri~a ~his process,' the I

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process that

selecting an

we went ·through, in

alternativer however, a

12 full presentation of both :l.ndividual and

13 . comparative 'analysis of alternatives'ls

14 I included in the fea~ibility studies for

'15·' this site.

16 Based, on this evaluation of 'the

17 various.alternatives, EPA and the New

18 Jersey Department of Environmehtal·

19 )

20

Prote.ction re.comrnend Al ternative 2 f the" . \ .

on-site biocell along with excavation , }

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22

and off-site disposal

contaminated material

of

as

the more highl~ I.,

a preferred

.23 alternativ~ t~address the principal

24

25

) threat LNAPL.

I ,

I will ln a moment ask Anqrew

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Judd to present. you with the technical

details of the prefeired alternativ~.

However,· I would like to remind you that

" - \ although this first operable unit has

been identified as an early action to

address. the ,Principal threatL~APL, a

second operable unit for which studies

are ongoing will ad<:iress residual soil

~ontaminatiort attributed to the site,

including low~r level threat LNAPL, the

on-site landfill area, the crig~t~o~-way

berms, and groundwater and sediment

contamination.

MR. PRINCE:· Wanda, let's have

.any·parts 'of Andy's presentation that.

come up as response to questions, we'll

have him pres~nt that.

Why -don't we open the floor·?'

MS., AYALA: So, we'll open up the

floor to questions a,nd comments.

MR. BARONE: You said Alternative

2, right?

MS. AYALA: State your name.

MR. ·BARONE: My ·name is Joe

Barone.

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Just so I,UhdE:!.rstand, .. Alternative>' / !,",

2is ~n,on~site cleanqp? ""; ( !l. .'., ", ( . . t' . . -­

;MR. PEINCE;: "Yes .\, '

~~ . BARONE:' l,\nd-tl?:en you $aid (

there's some areas 'that you would send ) ,

fs_r outsicie disposal.

What are'aS would that pe? /

the 45,000 :y;ards.thatwe identified that

cons~itut~dthisso~t of worst part 'of '. , .

the site~therearecertain-sec~ions of

it that are essentially pure oil. ),

And bioremec:1iation.i~ kind 'of the

standard method 6f dealing. with

petroleum-c9ntaminated sites,. Even

though there are lots of contaminants on

this site, ,this .. action is primarily

focussing 1n ,on that flowing ~ateri~l or

that\mor~ highly contaminated material,

and it's a ,lot of petroleum. "

So, wet'hink that· bioremediation

or this biocell is the :best ,fit for the

site. ~ut becaus~ some 'of it is s6

heavily contaminated, we think, i twill,

actually .slow the .whole process down 'and

. \ .

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stretch it out a bit. 'So, as a way to

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sort of balan~ethat out, our plan is, to

pull the worst of it' out and then, -­

4

3

it's still a pretty large quantity,' but

a relatively l.arge quantity would then

6 be subject to thi~biocell treatment on

the site.

8

7

So, how much is 'that? 'It's i \ ,

,probably at least that 3,000 yards 6f

materialthat!s around those 60uple,of

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wells where there's" Ii tera,lly -- you

12, know, 'you open.., the w:ell cap and there is .

13 five .or six feet of oil and water

14 because' there's so,. much oil, J.D, the .)

ground there.

16 MR. 'BARONE: And what type of

17 place would you send it to, a landfill?

18 I MR. PRINCE: It would go to a

19 facility -- it would ne~dto be

solidified first; becau'se we couldn't

21 ship a liquid waste like that,ahd there

22 would be a component, of it that would be

23 liquid waste. 'And then EPA has

24 regulations governing the disposal 6f

that so:rt of materia:l.,

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Pa~e 37,>

"My guess 1.S th.at it might have to1 ) ~,

go to a hazardous waste landfill and may

3

2

requl.re treatment before it can even get ~-\ .

)

4; 'int:o that landfill. But we won I t know ..

.tha~. until we actually-~

MR. BARONE: So, a TSDR. first and6 ,/ .

then to a. landfill?7

MR. PRINCE: It would prbbablygo

9

8

to' Subtitle C facility that. could have.

the treatment comppnent right. there and

11 ther( put in the landfill. .We're not

12 certain -- there is some hot -- you seem . ,.

·to know 'something. about the structure

14

13

rc~nstruction of landfill.

MR. BARONE: A little bi t ... ,

16 MR. PRINCE: SO, let me speak to

17 that.

18 There is a possib{lity that you \

could take tJ:lis contaminated soil, ship·19 ;

,it .to a facility off the si'te:,' have it j'

treated, have it meet the standardsfo~21

22. putting it into a Subtitle D landfill,

23 but that would require us to find some

24 6ff-site treatment facility, ship.it

there, get it treated there, ftnd. ~hen

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Page 38 "

,send ~it to another place to have it1

2' dispQsed of,.

3 And our experience with that

'4 multiple step process 1S it makes more

sense to ju~t send it to a place where

6' r you could treat it and put it ,in the

7 ground right there. /

MR. BARONE: There'~ no c6n6ern8

'about metals?

'" MR. PRINCE: I suspec t that when'

9

we test this' material to determine what'11 (

to do, with it for off-site disposal,

13

12

metals will'p:robably not be a

14 determining factor.

MR. BARONE:, Thank you.

16, MS. "AYALA: Any other questions?

17 Comments?

18 MR. BARONE: You said something

19 about ,PCBs.

Wh<:=tt kind of levels are we

,talking about?21.

MR . PRINC,E : Andy,' wha t ' s ' the

23'

22

highest l'evel of PCBs ,we've seen?

24 MR. JUDb:Generally,l?~.

NUmerically, it's ln the less thq.na

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.1 hundred and tens range .

2 MR. BARONE: So, it's not TANSLA /

" )

'3 regulated? .\

4 MR.' PRINCE': No; for disposal, it

wouldn't 'be TANSLA regulated, and for

, managing the site it wouldn't requlre6

7 us ...

8 MR. JUDD: At very few locations

also across th~.fifteen acres w~'ve

evaluated; less than ten locations, I (

think less than five locations we have

12

9

found' PCBs.

13 MR. BARONE: All right.

14 MR. PRINCE: These earlier

samples that I mentioned collected in,

\ . . . the early eighties, when the faclllty16

came down, there's tons of wastes that

18

17·

were removed at the time, and quite a

19 bit of it had PCBs in it: ,

So,' it's possible that some of

21 them -- some of the higher level

22 material went off .at th~t time. We

23 don: t, know.

MR. BAij.ONE: That's it. That's

all I have.

24

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MS. AYALA: Any other questions? .'

Comments?

This concludes our public

meeting. Thank you for coming., Have a

good night.

(Time noted: 6 :48 . p . in. )

. , /

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C E R T IF I C A TE

STArE OF NEW__ YORK'

),ss'. :

COUNTY OF NEW YORK

'-I, LINDA A.~MAR.INO, a Registered

Pro~e~siohal Report~r, Certi~ied Court '; .

-' . ( '~ .

. Reporter, and Notary Public within and ,J'

/' for the State of New York do here:;!by

{:ertify: .

I reported the proceedings in the'

within-entitled matter to' the best: of my

a~ili ty, and that .the within transcript

isa true record of su~h p~oceedin~s. . !

I further certify that I am not·

related, by blood or marriage,· to any of

the parties in this matter and that I am

in no way interested .in the outcome,of

this matter.

IN WITNESS WHEREOF, I have "2 ,//)'

this../";] i',day 6fi

/;"

/~<l.~·

my hand

~009. / J ~

/ / .--~

\

LINDA A. MAR.INO, RPR, CCR

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