Superfund Proposed PlanK

SDMS Document

111868

Evesham Township, Burlington County May 1992

Introduction

This Proposed Plan identifies the preferred reme­dial alternatives for the cleanup of contaminated soil and ground water at the Ellis Property Superfund Site located primarily in Evesham Township, Burlington County, New Jersey. In addition, the Plan includes summaries of other remedial alternatives analyzed for this site. This document was developed by the New Jersey Department of Environmental Protection and Energy (NJDEPE), the lead agency for site activities, with support from the U.S. Environ­mental Protection Agency (EPA). NJDEPE, in consultation with EPA. will select a final remedy for this site only after public comments have been reviewed and considered.

NJDEPE is issuing the Proposed Plan as part of its public participation responsibilities under Section 117(a) of the Comprehensive Environmental Re­sponse, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amend­ments and Reauthorization Act (SARA) of 1986. This document summahzes>information that can be found in greater detail in the Remedial Investigation (RI) and Feasibility Study (FS) reports, and other documents contained in the Administrative Record for this site. The NJDEPE and EPA encourage the public to review all documents to gain a more com­prehensive understanding of the site and the activi­ties conducted there. The Administrative Record contains the information upon which the selected response action will be based. It is available at the following locations:

Evesham Township Municipal Building 125 East Main Street

Marlton, New Jersey 08053 Phone (609) 983-2900

U.S. EPA Region II 26 Federal Plaza, Room 29-100

New York, New York 10278 Phone (212) 264-8770

New Jersey Department of Environmental Protection and Energy

401 East State Street, ON 413 Trenton, New Jersey 08625-0413

Phone (609) 984-3081

Dates to Remember

Friday, May 1,1992 through Saturday, May 30,1992

Public comment period on remedial alternatives

Wednesday, May 13,1992 Public meeting at the

Evesham Township Municipal Building 125 East Main Street, Marlton, New Jersey

at 7:00 p.m.

Community Role in the Selection Process

The NJDEPE actively solicits input from the community on the cleanup methods proposed for each Superfund response action. Public input is an important part of the remedy selection process NJDEPE has established a public comment period of 30 days, from May 1 through May 30,1992, to encourage public participation in the selection process. The comment period includes a public meeting at which NJDEPE will present the RI/FS findings and the Proposed Plan, answer questions, and accept both oral and written comments.

Site Remedlattoe Program (609) 984-3081 ° Bmsm of Community Relations

Printed on recycled paper

R2-0003195

Ellis Propeny Proposed Plan

• The public meeting is scheduled for Wednesday, May 13, 1992 at 7:00 p.m., and will be held at the Evesham Township Municipal Building. Comments on the RI and FS reports, the remedial alternatives, and this Proposed Plan will be welcome through May 30,1992. Comments will be summarized and responses provided in the Responsiveness Summary section of the Record of Decision (ROD). The ROD is the EPA document that presents the final selection of the cleanup alternatives for the site.

Written comments and requests for further information should be directed to:

Grace Singer, Chief Bureau of Community Relations

Department of Environmental Protection and Energy

CN 413, 401 E. State Street, 6th Floor

Trenton, New Jersey 08625 (609) 984-3081

Based on new information or public comments received during the public comment period, NJDEPE in consultation with EPA, may modify the preferred alternative or select another response action pre- ' sented in this Plan and the RI/FS reports. The public is therefore encouraged to review and comment on all of the alternatives described in this Proposed Plan.

Site Background

The Ellis Property site is located in Burlington County, east of Sharp Road and about 2,000 feet north of Evesboro-Medford Road in Evesham Township, New Jersey (see Figure 1). The site is surrounded by farmland and wooded lots and is about one and a half miles from the nearest residen­tial area. The property was used as a dairy farm and is designated as Block 14, Lot 4 on the Evesham Township tax map. It comprises approximately 36 acres of land; 24 acres are located in Evesham Township and the remainder in Medford Township.

In 1968, In/ing and Reba Ellis purchased the property and used part of it as a dmm storage and reconditioning (drum cleaning) operation. Approxi­mately 4 acres of the 36-acre tract were involved with this operation. The reconditioning operation ceased in 1978, after a fire damaged some of the buildings. However, storage of dmms at the site

continued into the 1980s. In addition, In/ing Ellis allowed his brother, Charles Ellis, who also had a drum reconditioning business, to bring drums and containers to the site.

In September 1980, the NJDEPE investigated the site due to an anonymous complaint. The site consisted of a two-story building, housing several washing tanks with troughs, three sheds, a storage area, and a boiler. The building contained 50-75 dnjms, many of which were full of unknown liquids. The three sheds also contained various-sized drums and chemical containers, many of which contained unknown substances. The area near the sheds was completely without any plant growth. A natural swale and several man-made ditches lead into a wetland, located approximately 700 feet east of Sharp Road. The troughs inside the larger building drained into one of these ditches. Sediments and surface water runoff enter the wetlands from the drainage ways.

Hundreds of drums and containers were spread haphazardly around the site. Some of these drums were found to contain oils, grease, acids, and various organic compounds. There was evidence of spills from past operations at the site. Several drums were corroded and the contents leaking onto the ground. A soil sample taken near a leaking drum was found to contain oil and grease. Subsequent inspections by the NJDEPE indicated that chemical spills onto the ground had occurred in several areas.

In April 1981, NJDEPE issued a Directive Letter to Mr. Ellis, instaicting him to remove and dispose of the drums and contaminated soil from the site. NJDEPE made numerous attempts to persuade Mr. Ellis to accept responsibility for the contamination on his property. In September 1982, the Evesham Municipal Utilities Authority filed a civil action against Irving and Reba Ellis for the illegal storage of drums containing hazardous substances. In December 1982, NJDEPE filed a Civil Action Complaint due to Mr. Ellis's failure to comply with the Directive Letter and the continued use of the site for the storage of dmms. A potable well survey was conducted in January 1983 by the Burlington County Health Department. The survey found that ten potable wells were completed in the Wenonah-Mount Laurel Aquifer, and that the site had not impacted potable water supplies in the area.

6

In March 1983. under the New Jersey Spill Com­pensation Fund, NJDEPE removed approximately

R2-0003196

Ellis Property Proposed Plan

100 drums containing acids and disposed of them at an approved off-site facility. Containerized solids and flammable liquids were also removed and disposed of, along with contaminated soils and sludges. In the acid spill area, the highly acidic surface soils were removed, and lime was tilled into the soil to neutralize the acid. The large building and sheds were demolished at that time because they were structurally unsafe. The site was included on the National Priorities List (NPL) on September 1, 1983. In June 1984, the court ordered Mr. Ellis to pay over $100,000 in fines and forbade him to store, discharge, and spill hazardous substances at the site.

In February 1989, NJDEPE requested that EPA conduct a drum removal action at the site. Dnjms containing hazardous substances were removed by EPA and disposed at an approved off-site facility. In April 1990, EPA completed the removal of the remaining drums.

Mr. Irving Ellis was offered the opportunity to undertake a Remedial Investigation and Feasibility Study (RI/FS) at the site, but declined. The RI/FS was initiated by the NJDEPE through a Cooperative Agreement with the EPA. In November 1985, Roy F. Weston, Inc. (WESTON) was selected to character­ize the geology and hydrology at the site, and to identify the contaminants in the ground water, surface water, soils, and sediments. The investiga­tion consisted of soil borings, a geophysical survey, monitoring wells. Soil, sediment, ground water, and surface water samples were collected and analyzed.

WESTON performed an FS to identify and screen remedial technologies to address and evaluate the potential risks to the public and the environment. , The FS was based on information obtained during the RI and was completed in April 1992.

Remedial Investigation Summary

The Ellis Property is situated in the central portion of the Atlantic Coastal Plain, which extends from the fail line located west of the Delaware River to the Atlantic Ocean. The Coastal Plain regionally slopes gently to the southeast. The topography is generally flat in the area. The site consists of silty sand with clay lenses, and is underlain by the Homerstown Fomnation, a shallow aquifer comprised of silty sand

and clay lenses. Underlying this shallow aquifer is the Navesink aquifer, which is interbedded with glauco-nitic clay and sand. At the base of this formation is a prominent shell zone. This formation is just above the Wenonah-Mount Laurel aquifer, which is a major source of water for domestic wells in the vicinity of the Ellis Property site. Based on available informa­tion, the deeper aquifers do not appear to be im­pacted at present by the contaminants in the shallow aquifer. A Burlington County Health Department survey found that private wells near the site are not located in the shallow aquifer, although there are no restrictions on well locations to prevent its use as a domestic water supply. While the shallow aquifer is not currently used as a source of drinking water, it is a potential source of recharge for the underlying aquifers at the site.

The RI identified contaminants in the soil, sedi­ment, and ground water. The predominant soil contaminants and the respective range of concentra­tion, in parts per million (ppm), detected at the Ellis Property site are: arsenic (1.4-31.8 ppm), lead (2.2-3790 ppm), total polychlorinated biphenyls (PCBs) (0.31-23.1), and bis (2-ethylhexyl) phthalate, a base neutral/acid extractable (BNA) compound, (0.045-2.3 ppm). Approximately 690 cubic yards (yd )̂ of soil are contaminated with metals, 60 yd^ with PCBs, and 10 yd' with BNA compounds.

Sediments and surface water in the wetlands at the Ellis Property site show elevated levels of lead. chromium, zinc, and trichloroethene (TCE).

Ground-water contamination appears to be limited to the shallow aquifer. The predominant contami­nants and the respective range of concentrations, in parts per billion (ppb), detected at the site are. arsenic (15.8-91 ppb), TCE (11-24,000 ppb), tetrachloroethene or PCE (760-33,000 ppb), total chromium (12-404 ppb), nickel (10.9-147 ppb), and lead (5-71 ppb).

Summary of Site Rislu

Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks associated with current and future site conditions. The baseline risk assessment estimates the human health and environmental risk which could result from tfte contamination at the site if no remedial action were taken.

R2-0003197

Ellis Property Proposed Plan 4

Human Health RiskAssessment

A four-step process is used for assessing site-related human health risks for a reasonable maxi­mum exposure scenario.

Hazard Identification—identifies the contaminants of concern at the site based on several factors such as toxicity, frequency of occurrence, and concentration.

E.xposure Assessment—estimates the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and the pathways (e.g., ingesting contaminated ground water) by which humans are potentially exposed.

Toxicity Assessment—determines the types of adverse health effects associated with chemical exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects (response).

Risk Characterization—summarizes and combines outputs of the exposure and toxicity assessments to provide a quantitative (e.g.. one-in-a-million excess cancer risk) assessment of site-related risks.

The baseline risk assessment began with selecting contaminants of concern that are representative of site risks. Chemicals of concern were identified for the surface soil, sediments, surface water, and ground water beneath the site. These contaminants include acetone, PCBs. pesticides, polynuclear aromatic hydrocaribons (PAHs). BNA compounds, PCE, 1,2-dichloroethylene. TCE. arsenic, cadmium, chromium, and lead.

The baseline risk assessment evaluated the health effects, which could result from exposure to contami­nation at the site, under current and future land-use scenarios. Under cun-ent land use conditions, access to the site is limited to trespassers. The most likely trespasser is an adult hunter/recreational user. The adult trespasser was considered to be on-site for three hours per exposure event and exposed to on-site surface soils, surface water, and sediments in the drainage ways and wetlands. A higher number of exposure events was assumed to occur during the warmer months than in the colder months. Unre­stricted residential land use was considered for the

future land use scenario. Two age groups were evaluated for the future resident—a child aged 1 -6 years and an adult.

The potential exposure pathways of concern for current land use include, incidental ingestion of, and dermal contact with, chemicals in the soil and sediments; inhalation of wind-blown dust; and dermal contact with surface water. Exposure to ground water was not evaluated because there are no residents on-site and, based on available information, the shallow aquifer is not used as a source "of drink­ing water by residents within a 1-mile radius. The potential exposure pathways of concern for future land use include those for current land use as well as the following: ingestion of chemicals in ground water, dermal contact with chemicals in ground water, inhalation of volatile organic chemicals in ground water during showering and bathing, and consump­tion of home-grown fruits and vegetables.

For carcinogens, risk is represented-in terms of an individual's likelihood of developing cancer as a result of exposure to a carcinogenic chemical present in the exposure media. For example, a cancer risk level of 1x10-' indicates that an individual has a one in a thousand chance of developing cancer during their lifetime. Or, such a risk may be interpreted as representing one additional case of cancer in an exposed population of one thousand people. EPA s acceptable cancer risk range is 1x10-" to ix io-^ or a one in ten thousand to a one in a million increased chance of developing cancer as a result of a site-related exposure to a carcinogen over a 70-year lifetime. Generally, if the lifetime excess cancer nsK exceeds 1x10-*. the contamination is of sufficient concern to consider a remedial action. If the excess cancer risk falls between 1x10-* and 1x10-', the need for a remedial action is evaluated on a site-specific basis. Finally, where the calculated lifetime excess cancer risk is below 1x10-*, no remedial action is generally required.

To assess the overall potential for ndn-carcmo genie effects posed by more than one contaminant EPA developed the hazard index (HI). This index measures the assumed simultaneous subthreshold exposures to several chemicals, which could result m an adverse health effect. When the HI exceeds i 0. there may be concern for potential non-carcinogenic health effects.

The results of the baseline risk assessment indicate that under the current-use scenario, non-

R2-0003198

Ellis Property Proposed Plan

carcinogenic health effects are not likely, based on the potential exposure pathways and routes evalu­ated for trespassers. The calculated HI for this scenario was less than 1.0. Similarly, the estimated carcinogenic risk was found be within EPA's accept­able cancer risk range. Under the future-use sce­nario, carcinogenic and non-carcinogenic health effects are likely based on the potential exposure pathways and routes evaluated for a future resident. The carcinogenic risk was calculated to be 1.26x10-^ The calculated His for the future child and adult resident exceed 1.0. The exposure pathways with the greatest potential risk (carcinogenic and non-carcinogenic) for the future resident are ingestion of home-grown produce, ingestion of chemicals in the ground water, and non-ingestion uses of ground water (i.e., bathing). There are no restrictions on future land-use which prohibit the use of the shallow aquifer as a source of potable water supply. Conse­quently, in the worst case scenario, the risk assess­ment assumes that future residents might use the shallow aquifer as an untreated source of potable water.

Health risks associated with sediments and surface water in the wetlands were evaluated for both the current and future-use scenarios. The pathways analyzed include incidental ingestion of sediment in the wetlands and drainage ditches, and dermal contact with sediments and,surface water in the wetlands and drainage ditches. In both the current-use and future-use scenarios, the carcinogenic health risk associated with these pathways was found to range from IxlO-Mo 1x10-'", which does not exceed the acceptable risk range of 1x10-* and 1x10-*. Similarly, non-carcinogenic His for both scenarios were found to be substantially less than 1.0. Therefore, these pathways do not pose signifi­cant health concerns.

Ecological RiskAssessment

The ecological risk assessment evaluated potential impacts associated with the contaminants at the site. The assessment focused on the potential impacts of contaminants of concern found in the soil, and surface water and sediments in the wetlands, to terrestrial and aquatic flora and fauna that inhabit, or are potential inhabitants, of the site. The contami­nants of concern included pesticides, PCBs, lead, cadmium, and chromium. The ecological receptors that were considered are: white-tailed deer, wood­cock, red-tailed hawk, aquatic organisms, and terrestrial plants. The results indicated that the

contaminated soils would pose a significant risk to white-tailed deer and woodcock. Contaminated sediments and surface water in the wetlands posed a low risk for potential adverse effects to aquatic and sediment-dwelling organisms. The assessment showed no significant impacts to the red-tailed hawk and terrestrial plants.

If the soil contaminants were left untreated, white-tailed deer and woodcock populations could poten­tially be impacted. However, these potential risks would be mitigated by reducing soil contaminants.

While sediments and surface water in the wetlands are contaminated with site pollutants, impacts to flora and fauna are considered low. Excavation of con­taminated sediments from the wetlands would likely cause irreparable damage. Sediment and surface water contamination appears to be the result of surface soil erosion from the site. The remediation of soil contamination would reduce further degradation of the wetlands by eliminating the soil erosion pathway.

Scope and Role of Response Action

This Proposed Plan addresses remediation of the contaminated media at the Ellis Property site. It includes remedial alternatives to address contami­nated soil and ground water, and focuses on the protection of human health and the environment Specific remedial action objectives are as follows:

Soils

• Prevent contact with contaminated soils, which represent an unacceptable risk.

• Reduce contaminant concentrations m the soil below risk-based levels.

• Prevent further migration of contaminants mto the ground water.

• Prevent migration of contaminated soils, ott site

Ground Water ^

• Prevent the migration of contaminated ground water off-site.

• Prevent the migration of contaminated ground water into the underiying aquifers.

R2-0003199

Ellis Property Proposed Plan 6

Ground Water (continued)

• Reduce contaminant concentrations in the shallow ground water to promulgated Federal and State Primary Drinking Water Standards.

Actual or threatened releases of hazardous sub­stances from the site, if not addressed by the pre­ferred alternative or one of the other active measures considered, may present an imminent and substan­tial endangerment to the public health, welfare, or the

nvironment.

Summary of Remedial Alternatives

Remedial alternatives were developed and evalu­ated for soil and ground water. The Baseline Risk Assessment found that sediments in the wetlands do not pose a significant risk to human health, and only a conservative marginal risk to the ecosystem. Therefore, remedial alternatives for the sediments are not included. The remedial alternatives for soil address sediment contamination by reducing or eliminating the potential for surface soil erosion. The remediation of soil contamination would reduce further degradation of the wetlands by eliminating the soil erosion pathway. Adetailed discussion of all of the alternatives may be found in Section 5, Detailed Analysis of Remedial Action Alternatives, of the FS report.

The estimated capital cost, operation and mainte­nance costs, and net present worth costs of each alternative discussed below are provided for compari­son.

An estimated implementation time frame is given for each remedial alternative described below. It refers to the time required to implement the alterna­tive, including constnjction and operation and mainte­nance.

Soil Alternatives

The FS considered the following general response actions for the contaminated soil at the Ellis Property site: no action, institutional controls, excavation with treatment and disposal, and capping. Those alterna­tives which passed the screening process are summarized below.

Alternative SS-3. which consists of excavation of surface soils, on-site treatment, and on-site disposal,

was analyzed in the FS. It did not pass the screening process because the relatively small volume of contaminated soil did not justify the construction of an on-site treatment system; therefore, this alterna­tive is not included below.

Alternative SS-1: No Action

Estimated Capital Cost: 0 Estimated Annual Operation & Maintenance (O&M) Cost: $42,000 Estimated Net Present Worth Cost: $117,000 Estimated Implementation Time Frame: None

CERCLA requires that a No Action alternative be evaluated at every site to establish a baseline for comparison to the other alternatives. Under this alternative, EPA and NJDEPE would take no further action at the site.

Because this alternative would result in contami­nants remaining on site, CERCLA requires that the site be reviewed at least every five years. If justified by the review, remedial actions would be.evaluated at that time to address the contamination! The cost estimates above include the cost to perform this review.

Alternative SS-2: Institutional Controls

Estimated Capital Cost: $40,000 Estimated Annual O&M Cost: $25,000 Estimated Net Present Worth Cost: $110,000 Estimated Implementation Time Frame: 6 months

This alternative would include the construction of a fence around the perimeter of the site and placement of warning signs to restrict access. Deeds would be modified to restrict site development. As'in the No Action alternative above, the site would be reviewed. at least every five years. The cost estimates above include the cost to perform this review.

Alternative SS4: Excavation/Off-^ite Disposal

Estimated CapKal Cost: $560,000 Estimated Annual O&M Cost: $188,200 (1 year only) Estimated Net Present Worth Cost: $739,000 Estimated Implementation Time Frame: 1 year

Alternative SS-4 would include excavation of contaminated soil, and treatment and/or disposal at

R2-0003200

Ellis Property Proposed Plan

an approved off-site landfill or incinerator. The soils may require stabilization on site or off site, prior to disposal off site. The excavated area would be back-filled with clean fill. Under this alternative, soil contaminants would be remediated to risk-based levels.

The O&M and net present worth costs include the cost of treatment or stabilization of the soils prior to disposal.

Alternative SS-5: Capping of Surface Soils

Estimated Capital Cost: $630,000 Estimated Annual O&M Cost: $100,800 Estimated Net Present Worth Cost: $2,180,000 Estimated Implementation Time Frame: 2 years

Under Alternative SS-5, surface soils above risk-based cleanup levels would be covered with an impermeable multi-layer cap. This would prevent exposure to the contaminants, and prevent migration of contaminants off site and into the ground water through infiltration. The cap would be designed to meet the Federal and State of New Jersey require­ments for hazardous waste disposal facilities. A vegetative cover would be placed on top to minimize erosion and promote drainage off the cap.

As in the No Action alternative above, the site would be reviewed at least every five years. The cost estimates above include the cost to perform this review.

Ground Water Alternatives

The following general response actions were considered in the FS for contaminated ground water: no action, institutional controls, and extraction and treatment. Below are summaries of the ground­water alternatives. A detailed discussion of the ground-water alternatives is presented in Section 5. Detailed Analysis of Remedial Action Alternatives, of the FS report.

Alternative GW-1: No Action

Estimated Capital Cost: $30,000 Estimated Annual O&M Cost: $.61.000 Estimated Net Present Worth Cost: $200,000 Estimated Implementation Time Frame: None

Under this alternative, EPA and NJDEPE would take no further action at the site. Because this alternative would result in contaminants remaining on site, CERCLA requires that the site be reviewed at least every five years. If justified by the review, remedial actions would be evaluated at that time to address the contamination. The above cost esti­mates include the cost to perform this review.

Alternative GW-2: Institutional Controls

Estimated Capital Cost: $74,000 Estimated Annual O&M Cost: $180,000 Estimated Net Present Worth Cost: $575,000 Estimated Implementation Time Frame: 6 months

Alternative GW.-2 would include the implementation of deed restrictions and well restrictions to reduce the potential for exposure to ground-water contaminants. These restrictions may completely restrict the installation of wells in a particular area, or they may establish well construction specifications and the minimum depth to which wells must be installed.

As in the No Action alternative above, the site would be reviewed every five years. The cost estimates above include the cost to perform this review.

Alternative GW-3: Extraction and Treat­ment of Contaminated Groundwater

Estimated Capital Cost: $1,340,000 Estimated Annual O&M Cost:

$365,000 years 1-3; $283,000 years 4-30

Estimated Net Present Worth Cost; $5,914,000 Estimated Implementation Time Frame: 30 years

Under this alternative, an interceptor trench and extraction wells would be installed to collect shallow ground water. The exact number and precise location of the extraction wells would be determined during design. The contaminated ground water would be pumped to an on-site treatment system that would remove metals by precipitation and ultrafiltra­tion, and remove volatile organic compounds (VOCs) by air stripping. Further treatment of the air stream may be required to remove VOCs before venting it to the atmosphere. The treated ground water would be reinjected. Appropriate measures would be taken to prevent human contact with the contaminated ground

R2-0003201

Ellis Property Proposed Plan S

water during the remediation. Ground-water monitor­ing would be performed during and following active remediation.

The installation of an interceptor trench and extraction wells may affect the natural flow of ground water and surface water to the wetlands. The ground-water extraction system may affect the hydrology of the wetlands. To the maximum extent practicable, the interceptor trench and extraction wells would be placed in locations that avoid or minimize any impacts.

If it is determined during design that hydrological impacts to the wetlands are significant, a portion of the treated ground water would be discharged into the nearby swale which drains into the wetlands to minimize any hydrological impacts.

It is anticipated that half as many ground-water samples would be required in years 4-30 than in the first 3 years because the contaminant concentrations would be expected to decline through the extraction and treatment of the ground water. This is reflected in the annual O&M costs for this alternative.

Evaluation Criteria

During the detailed evaluation of remedial alterna­tives, each alternative is assessed against nine evaluation criteria, namely, overall protection of human health and environment, compliance with applicable or relevant and appropriate requirements (ARARs), long-term effectiveness and permanence, reduction of toxicity, mobility or volume, short-term effectiveness, implementability, cost, and state and community acceptance. The evaluation criteria are described below.

Overall protection of human health and the environment addresses whether a remedy provides adequate protection of human health and the envi­ronment and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

Compliance with applicable or relevant and appropriate requirements addresses whether a remedy will meet all of the ARARs under Federal and State environmental laws and/or provides grounds for invoking a waiver.

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 cleanup goals have been met.

Reduction of toxicity, mobilitv or volume addresses the statutory preference for selecting remedial actions that employ treatment technologies that permanently and significantly reduce toxicity, mobility or volume of the hazardous substances as a principal element.

Short-term effectiveness addresses the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implemen­tation period, until cleanup goals are achieved.

Implementability is the technical and administra­tive feasibility of a remedy, including the availability of materials and services needed to implement a particular option.

Cost includes estimated capital costs, operation and maintenance costs, and net present worth costs.

State acceptance indicates whether, based on review of the RI/FS reports and the Proposed Plan, the State concurs with, opposes, or has ho comment on the preferred alternative.

Community acceptance of the preferred alterna­tive will be assessed in the Record of Decision (ROD) following review of the public comments summarizes the public's general response to the alternatives described in the Proposed Plan and in the RI/FS. based on public comments received. This will be assessed in the ROD.

Evaluation of Alternatives and the Preferred Alternatives

NJDEPE, together with EPA. is requiredto select the remedial alternative which offers the best balance of trade-offs among alternatives with respect to the evaluating criteria. At a minimum, the selected remedy must meet two criteria, protection of human health and the environment and compliance with ARARs (unless a waiver for an ARAR is granted).

R2-0003202

Ellis Propeny Proposed Plan

Evaluation of Alternatives

Seven of the nine criteria will be discussed below in the evaluation of the alternatives. State and commu­nity acceptance will be evaluated upon completion of the public comment period and summarized in the Record of Decision. Since the Baseline Risk Assess­ment found that the sedimerits in the wetlands would not pose a significant health concern, no remedial action is necessary. Therefore, remedial alternatives for sediments are not included in the evaluation of alternatives. However, the wetlands will be exam­ined as part of the site review conducted at least every five years, as required by CERCLA. If neces­sary, remedial actions would be evaluated at that time to address any problems identified with the wetlands. Below is a comparative analysis of the remedial alternatives.

Overall Protection of Human Health and the Environment

Risks to human health and the environment would not be eliminated through the No Action alternatives. Institutional Controls alternatives, or Alternative SS-5. The No Action alternatives, SS-1 and GW-1, would not provide long-term protection of human health and environment because the contaminants would remain on site and will continue to degrade the ground water. The Institutional Controls alternatives, SS-2 and GW-2, would not reduce soil contaminants or prevent off-site migration, but would reduce the potential for on-site contact through the installation of a fence around the site, and will continue to degrade the ground water. Alternative SS-5, capping, would reduce the potential for contact with the contami­nated soil. In addition, deed restrictions would need to be placed on the property to restrict future land use to reduce potential contact with the contaminated soils.

Alternative SS-4 would remove contaminants from the soils and prevent further migration of contami­nants into the ground water. Alternative GW-3 would eliminate risk by removing the contaminants from the ground water and prevent migration. Potential impacts to the hydrology of the wetlands by the extraction of ground water will be mitigated by surface water discharge. Therefore, alternatives SS-4, SS-5. and GW-3 would be protective of human health and the environment.

Compliance with ARARs

Contaminated soils would be cleaned up to risk-based levels. The ground water ARARs are the promulgated Federal and New Jersey Safe Drinking Water Act Maximum Contaminant Levels (MCLs), and/or New Jersey Ground Water Quality Standards. The promulgated New Jersey Surface Water Quality Standards would apply to surface discharge of treated ground water. The contaminated ground water would be treated to comply with these ARARs.

Alternatives SS-1, SS-2, and SS-5 would not attain risk-based soil cleanup levels because contaminant concentrations would not be reduced. Alternatives GW-1 and GW-2 would not comply with ground­water ARARs because contaminants would remain on site.

Alternative GW-3, extraction and treatment of ground water, alone would not comply with the ARARs in the long term because soil contaminants would continue to infiltrate into the ground water. Alternative SS-4, excavation and off-site disposal, together with Alternative GW-3, would be necessary to achieve ground-water ARARs in the long term.

Short-term Effectiveness

The No Action alternatives (SS-1 and GW-1) and the Institutional Controls alternatives (SS-2 and GW-2) will result in few, if any, additional short-term risks from the site. The on-site activities would be performed in a manner which minimizes the generation of dust. Alternative SS-5 would generate some dust during construction of the cap; Alternative SS-4, excavation and removal of the contaminated soils, has the potential to generate a significant amount of dust. These activities will require the use of dust suppression measures to prevent off-site migration of dust and to minimize health effects to workers on site.

The installation and operation of extraction wells will involve risks similar to those encountered during the RI. which are primarily exposure to VOCs. A health and safety plan would be implemented to address and minimize those risks.

Long-term Eflectlveness

The No Action alternatives (SS-1 and GW-1), the InstKutional Controls alternatives (SS-2 and GW-2),

R2-0003203

Ellis Property Proposed Plan 10

and Alternative SS-5 do not provide long-term protection because contaminants would remain on site. Alternatives SS-4 and GW-3 would provide long-term effectiveness because the contaminants would be removed.

Reduction of Toxicity, Mobility, and Volume

The No Action alternatives (SS-1 and GW-1) and the Institutional Controls alternatives (SS-2 and GW-2) would not reduce the toxicity, mobility, and volume of contaminated material. Fencing of the site and deed restrictions would only limit contact with the contaminated media at the site. Alternative SS-5. capping, would reduce the mobility of contaminants, but volume and toxicity remain unchanged. Alterna­tive SS-4, excavation and off-site disposal, would reduce the mobility and volume of contaminants because it would remove the contaminated soil. Toxicity would be reduced by treatment and disposal of the soil. Mobility and volume of contaminants would be reduced by Alternative GW-3 because it would collect the contaminated ground water and prevent migration. Treatment of the collected ground water would reduce toxicity.

Implementability

There are no difficulties with respect to implement­ing the No Action alternatives (SS-1 and GW-1). as it would not involve any action. Implementation of the Institutional Controls alternatives (SS-2 and GW-2) would not be a problem because the construction of fences and placement of deed restrictions by the State of New Jersey can be accomplished without difficulty.

Alternative SS-4, excavation and off-site disposal, may require the development of adequate excavation and transportation plans. Selection of a disposal facility is not expected to pose a problem due to the small quantity of contaminated soil.

Impermeable multi-layer caps, as described in Alternative SS-5. are a proven technology. Installa­tion of a cap would involve readily available materials and would be easily implementable.

The on-site ground-water extraction and treatment system in Alternative GW-3 would be easily implementable. Precipitation, ultrafiltration, and air stripping are proven technologies and are readily available. There is sufficient property on site to

construct a treatment system and install extraction and reinjection wells.

The Preferred Alternatives

After careful consideration of the remedial alterna­tives. NJDEPE and EPA have preliminarily selected a prefenred alternative for ground-water and soil remediation. The rationale for selecting these alternatives is described in the section that follows. Community comment and acceptance are being solicited at this time. The RI/FS reports should be consulted for more information on the remedial alternatives.

The preferred alternatives to remediate the Ellis Property site are:

SS-4 - Excavation of site soils and off-site disposal, and

GW-3 - Extraction and treatment of ground water.

Based on current information, these alternatives appear to provide the best balance of trade-offs among the alternatives with respect to the criteria used to evaluate alternatives. The preferred alterna­tives would provide overall protection of health and the environment and comply with ARARs. Detailed technical specifications will be developed during the design phase of the remedy; the precise sizing and sequence of treatment components will be ad­dressed at that time.

Promulgated Federal and New Jersey Safe Drink­ing Water Act Maximum Contaminant Levels, and/or New Jersey Ground Water Quality Standards will dictate cleanup levels for the ground-water remediation. The promulgated New Jersey Surface Water Quality Standards dictate the levels for surface water discharge of the treated ground water.

The NJDEPE and EPA have agreed that site-specific risk-based cleanup levels will be used for soil remediation. EPA recognizes NJDEPE's request " that soil and ground water be cleaned to the levels specified in its Proposed Cleanup Standards for Contaminated Sites fFebman/ 1992i. and has deter­mined that this additional action would not conflict, or be inconsistent, with the preferred remedial alterna­tive. The NJDEPE has agreed to fund the incremen­tal cost associated with this additional action.

R2-0003204

Ellis Property Proposed Plan

Summary of the Preferred Alternatives

In summary, the preferred alternatives would provide overall protection of human health and the environment by excavating contaminated soils for off-site treatment and disposal, and extracting and treating contaminated ground water in the shallow aquifer.

Alternatives SS-4 and GW-3 would prevent further contamination of the ground water and reduce the risk of migration into the underlying aquifers. Therefore, the preferred alternatives are believed to provide the best balance of trade-offs among alternatives with respect to the criteria used to

evaluate the remedies. Based on the information available at this time, the EPA and the State of New Jersey believe the preferred alternatives would protect human health and the environment, would comply with ARARs, would be cost-effective, and would utilize permanent solutions to the maximum extent practicable. Alternatives SS-4 and GW-3 would also address the major ecological risks identi­fied in the risk assessment. NJDEPE and EPA have determined that remediation of the sediments in the wetlands would be more detrimental than beneficial. Because the preferred alternatives would involve treatment of contaminated soil and ground water, the remedy would also fulfill the statutory preference for treatment as a principal element.

R2-0003205

Ellis Property Proposed Plan

Evesham Township, Burlington County May 1992

Summary of Alternatives Considered in the Feasibility Study

Soil Remediation

Alternative Description Estimated Costs Time to Complete

SS-1: No Action Soil and surface water monitoring Site review every five years

Capital: $0 "Annual O&M: $42,000

Present Worth: $117,000

0 months

SS-2: Institutional Controls

Fencing Deed restrictions Soil and surface water monitoring Site review every five years

Capital: $40,000 •Annual O&M: $25,000 Present Worth: $110,000

6 months

*SS-4: Excavation/Off-Site Disposal

SS-5: Capping of Surface Soils Clearing/Grubbing

Clearing/Grubbing Installation of surface water runon/runoff controls Excavation of contaminated soil Air/dust monitoring during excavation activities Backfilling/regrading/ revegetation Off-site treatment/ disposal at approved facilities

Installation of runon/ runoff controls Capping of contaminated soil with impermeable multi­layer cap Regrading/ revegetation Soil and surface water monrtoring Site review every five years

Capital: $560,000 Annual O&M: $188,200

(1 year only) Present Worth: $739,000

1 year

Capital: $630,000 "Annual O&M: $100,800

Present Worth: $2,180,000

2 years

Preferred Alternative O&M - 30 years

R2-0003206

i^Ellis PropeilyPropiWsed'B^

Evesham Township, Burlington County May 1992

emmary of Alternatives Coesidered • 1 011 o

Ground Water Remediatioe

Alternative

GW-1: No Action

^̂

DescriptDon

• Contaminants remain on site, therefore potential site hazards are not reduced

• Site review every five years

- Installation of additional monitoring wells

- Ground water sampling

Estimated Costs

Capital: $30,000 "Annual O&M: $61,000

Present Worth: $200,000

Time to Complete

0 months

GW-2: Institutional Controls

Installation of additional monitoring wells Ground water sampling Deed and well restrictions Contingency Plan Site review every five years

Capital: $74,000 •Annual O&M: $180,000 Present Worth: $ 575,000

6 months

*GW-3: Extraction and Treatment of Contaminated Ground Water

Extraction of shallow ground water using trenches and/or recovery wells Treatment system consisting of precipita­tion and ultrafiltration for removal of metals and air stripping for removal of volatiles Discharge of treated water to either: Local municipal treatment plant; off-site surface water; groundwater via trenches, spray irrigation or reinjection wells; on-site surface water (wetland) Ground water monitoring

Capital: $ 1,340,000 Annual O&M:

$365,000 (years 1-3) $283,000 (years 4-30)

Present Worth:$5.914,000

30 years

" O&M - 30 years

R2-0003207

Uf.tmj'm'm^'arttmi'iaiiUsm ^••-Lm^MHM,J^--^-.i..A. i . 1 . ^ . . , . . ... ...»t.J^.V4J^^itXtt.y,,...,., j ., j ,.^J;,,,,,.;. j j , ^ | , i | . . ^ , , j t . j ^ . . ^ l J t . l l ^ .L»JU. , . , , , i ^ . )

The terms and abbreviations contained in this glossary are defined here in the context of site remediation and apply specifically to work performed under the Superfund program at the Ellis Property. These terms may have other meanings when used in a different context.

Ac id : An acid is a substance that hias a pH of less than 7.0. High concentra­tions of acids can be very corrosive and react with many inorganic and organic substances. These reactions can create toxic compounds or release heavy metal contaminants that remain in the environment long after the acid is neutralized.

Air St r ipp ing: A process whereby volatile organic chemicals are removed from contaminated material by forcing a stream of air through the material in a pressurized vessel. The contami­nants are evaporated into the air stream. The air may be further treated before it is released into the atmo­sphere.

Aquifer: An underground layer of rock, sand, or gravel capable of storing water within cracks and pore spaces, or between grains. When water contained within an aquifer is of sufficient quantity and quality, it can be tapped and used for drinking or other purposes. The water contained in the aquifer is called ground water.

ARARs: Acronym for Applicable or Relevant and Appropriate Require­ments. ARARs are the Federal and State environmental laws and regula­tions that apply to a site cleanup.

Back Fi l l : To refill an excavated area with soil or stone; or the material itself that is used to refill an excavated area.

Base: A base is a substance that has a pH greater than 7.0 that has corro­sive properties. When bases are mixed with acids, they neutralize each other, forming salts.

Cap: A layer of material, such as clay cr a synthetic material, used to prevent rain water from penetrating and spreading contaminated materials. The surface of the cap is generally mounded or sloped so water will drain off.

Carcinogen: A substance that produces cancer.

CERCLA: Comprehensive Environ­mental Response, Connpensation and Liability Act (see Superfund below).

Cooperative Agreement: A contract between EPA and a state wherein the State agrees to manage or monitor certain site investigation and/or cleanup responsibilities and other activities on a cost-sharing basis.

Extract ion Wel l : A well from which contaminated ground water or contami­nant vapors are pumped.

Ground Water: Water contained in the saturated zones of subsurface geological formations.

Hydrogeology: The geology of ground water, with particular emphasis on the chemistry and movement of water.

Interceptor Trench: A stone-filled trench that collects contaminated water.

Moni tor ing Wel l : A well installed under strict design specifications that, when sampled, will yield hydrogeologic data at its point of installation. Monitor­ing wells are installed at predetermined locations, usually in groups, to obtain information of site conditions such as the extent and type of ground water contamination, soil types, depth to ground water and direction of ground water flow.

National Priorities List (NPL): The list of the hazardous sites deter­mined by the federal government to have the highest priority based upon a hazard ranking system. A site listed on the NPL is eligible for federal funding under CERCLA. Published by the USEPA, the NPL is updated periodi­cally. Sites on the NPL are commonly called Superfund sites.

Neutrals: Organic compounds that have a relatively neutral pH, complex structure and, due to their organic bases, are easily absorbed into the environment. Naphthalene, pyrene, and trichlorobenzene are examples of neutrals.

NJDEPE: New Jersey Department of Environmental Protection and Energy.

Parts Per Million (ppm): A unit of concentration equivalent to one ten thousandth of a percent.

(over)

New Jersey Department of EmiviroEmeBitsii Site

(609) 984-3081 ° Bmnssm. of Comm' 5/92 Printed on recycled paper

R2-0003208

Glossary for Proposed Plan

Polychlor inated Biphenyls (PCBs): A group of toxic chemicals used for a variety of purposes including electrical applications, carbonless copy paper, adhesives, hydraulic fluids, microscope emersion oils, and caulking compounds. PCBs are also produced in certain combustion processes. PCBs are extremely persistent in the environment because they are very stable, non-reactive, and highly heat resistant. Burning them produces even more toxins. Chronic exposure to PCBs is believed to cause liver damage. II is also known to bioaccumulate in fatty tissues. PCB use and sale was banned in 1979 with the passage of the Toxic Substances Control Act.

Polycycl ic Aromatic Hydrocar­bons or Polyaromatic Hydrocar­bons (PAHs): PAHsfsuch as pyrene, are a group of highly reactive organic compounds found in motor oil. They are common components of creosotes and can cause cancer.

Potable Wel l : A well that provides water for drinking and cooking pur­poses. May also be referred to as a domestic well, private well, or residen­tial well.

Precipi tat ion: A process by which a soluble substance becomes insoluble, causing the substance to separate out from the solution.

Record of Decis ion (ROD): A fomnal record documenting the reasons and process of selecting a federal Superfund-financed rennedy for a Superfund site.

Remedial . Investigation/Feasibi l­ity Study (RI/FS): The Remedial Investigation (RI) entails gathering the data necessary to determine the nature and extent of problems at the site, establishing the remedial response criteria and identifying remedial action alternatives. The Feasibility Study (FS) involves evaluating alternative remedial actions from a technical, environmen­tal, and cost perspective, recommend­ing the most effective remedy for

adequate protection of human health and the environment, and preparation of a conceptual design, cost estimates and a preliminary implementation schedule.

SARA: Superfund Amendment and Reauthorization Act, passed in October 1986 amending CERCLA.

Sediment: The layer of soil and minerals at the bottom of surface waters, such as strean^, lakes, and rivers that absorb contaminants.

Sludges: Semi-solid residues from industrial or water treatment processes that may be contaminated with hazardous materials.

Spil l Compensat ion Fund: The j New Jersey Spill Compensation Fund ! was created with the enactment of the

Spill Compensation and Control Act which became effective on April 1, 1977. It provides compensation to qualified individuals and businesses that have suffered damages as a result of a discharge of hazardous sub­stances for which they were not responsible.

Stabi l izat ion: The process of changing an active substance to inert, harmless material; or physical activities at a site that act to limit the further spread of contamination without actual reduction of toxicity.

S t r ipp ing: A process used to remove volatile contaminants from a substance (see Air Stripping).

Super fund: The common name for the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) enacted by Congress in December 1980 and amended in October 1986 by the Superfund Amendment and Reauthorization Act (SARA). CERCLA authorized the USEPA to provide long-term remedies at hazardous waste sites and estab­lished a fund of special taxes and general revenues to clean up these sites.

Tr ichloroethylene (TCE): A stable colorless, liquid with a low boiling point. TCE has many industrial applications, including use as a solvent and as a metal degreasing agent. TCE may be toxic to people when inhaled, ingested, or through skin contact and can damage vital organs, especially the liver [see also Volatile Organic Com­pounds). J-

USEPA: United States Environmental Protection Agency.

Vegefated Soi l Cap: A cap con­structed with graded soils and seed for vegetative growth to prevent erosion (see Cap).

Volati le Organic Compounds (VOCs): VOCs are chemicals that readily volatilize or evaporate. They include light alcohols, acetone, trichlo­roethylene, perchloroethylene, dichloroethylene. benzene, vinyl chloride, toluene, and methylene chloride. These potentially toxic chemicals are used as solvents, degreasers, paints, thinners, and fuels. Because of their volatile nature, they readily evaporate into the air, increas­ing the potential exposure to humans. Due to their low water solubility, environmental persistence, and widespread industrial use, they are commonly found in soil and ground water.

Wet land: An area that is regularly saturated by surface or ground water and. under normal circumstances. capable of supporting vegetation typically adapted for life in saturated soil conditions. Wetlands are cntical to sustaining many species of fish and wildlife. Wetlands generally include swaops, marshes, and bogs. Wet­lands may be either coastal or inland. Coastal wetlands have salt or brackish (a mixture of salt and fresh) water, and nnost have tides, while inland wetlands are non-tidal and freshwater. Coastal wetlands are an integral component of estuaries.

R2-0003209