Embed Size (px)
Citation preview
oo jp I
;
h—-
r
FINAL WORK PLANREMEDIAL INVESTIGATION AND
FEASIBILITY STUDY
EWAN PROPERTY SITEBURLINGTON COUNTY,
NEW JERSEY
DECEMBER 21, 1987W.A. NO. 130-2LA5
DECEMBER 21, 1987
FINAL WORK PLANREMEDIAL INVESTIGATION AND FEASIBILITY STUDY
EWAN PROPERTY SITEBURLINGTON COUNTY, NEW JERSEY
EPA WORK ASSIGNMENT NUMBER 130-2LA5UNDER
CONTRACT NUMBER 68-01-7250
PREPARED BY:NUS CORPORATION
PITTSBURGH, PENNSYLVANIA
APPROVED BY:EBASCO SERVICES INCORPORATED
LYNDHURST, NEW JERSEY
PREPARED BY: APPROVED BY:
DEBRA M WROBLEWSKISITE MANAGERNUS CORPORATION
DEV R SACHDEV, Ph.D., P.E.REGIONAL MANAGER, REGION IIEBASCO SERVICES INCORPORATED C5
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION 1
2.0 SUMMARY OF EXISTING DATA 2
2.1 SITE HISTORY 2
2.2 SITE DESCRIPTION 2
2.2.1 Geology and Soils 2
2.2.2 Nature and Extent of the Problem 4
3.0 SCOPING THE ACTIVITIES FOR THE EWAN PROPERTY SITE 20
3.1 RI/FS OBJECTIVES 20
3.2 PRELIMINARY SCOPING OF REMEDIAL TECHNOLOGIES 21
3.3 IDENTIFICATION OF DATA REQUIREMENTS 24
3.3.1 Determination of ARARs 24
3.3.2 Consideration of ARARs During the RI/FS 25
3.3.3 Preliminary Identification of ARARs 26for the Ewan Property
4.0 TASK PLAN FOR REMEDIAL INVESTIGATION/ 33FEASIBILITY STUDY
4.1 STATUS OF REM/FIT TASKS 33
4.1.1 Task 1 - Remedial Investigation/ 33Feasibility Study Work Plan MemorandumPreparation
4.1.2 Task 2 - Project Management 33
4.1.3 Task 3 - Collection and Evaluation 33of Existing Information
4.1.4 Task 4 - Site Inspection 34
4.1.5 Task 5 - Preliminary Remedial Measures 34Screening
OCO
ii
TABLE OF CONTENTS (Continued)
SECTION PAGE
[4.1.6 Task 6 - Pre-Work Plan Review Meeting 34
4.1.7 Task 7 - Work Plan Preparation 34
4.1.8 Task 8 - Permits, Rights of Entry, and 34n Other Authorizations
'* 4.1.9 Task 9 - Subcontract Procurement 34
f 4.1.10 Task 10 - Site-Specific Plans 35
4.1.11 Task 11 - Topographic Mapping and 35Grid Surveying
4.1.12 Task 12 - Geophysics Study 35
I 4.1.13 Task 13 - Soil Gas Screening 35iI
4.1.14 Task 14 - Community Relations Support 35T
j 4.1.15 Task 15 - Subsurface Investigation 36
; 4.1.16 Task 16 - Monitoring Well Sampling 361 4.1.17 Task 17 - Surface Water and Sediment 37
and Sampling
4.1.18 Task 18 - Soil Sampling 37
4.1.19 Task 19 - Test Pit Excavation 38
4.1.20 Task 20 - Treatability Studies 394.1.21 Task 21 - Remedial Investigation 39
Report Preparation
4.1.22 Task 22 - Feasibility Study 39
4.2 REM III TASK PLAN FOR THE RI/FS 39
4.2.1 Task 1 - Project Planning 40
4.2.2 Task 2 - Community Relations 40O4.2.3 Task 3 - Field Investigation 41 ^C5GO
111
TABLE OF CONTENTS (Continued)
SECTION
4.2.4 Task 4 - Sample Analysis/Validation
4.2.5 Task 5 - Data Evaluation
4.2.6 Task 6 - Risk Assessment
PAGE
41
41
42
4.2.7 Task 7 - Treatability Study/Pilot Testing 42
4.2.8 Task 8 - Remedial Investigation Report 43
4.2.9 Task 9 - Remedial Alternatives Screening 45
4.2.10 Task 10 - Remedial AlternativesEvaluation
4.2.11 Task 11 - Feasibility Study Reports
4.2.12 Task 12 - Post RI/FS Support
5.0 PROJECT MANAGEMENT APPROACH
5.1 ORGANIZATION AND APPROVAL
5.2 QUALITY ASSURANCE AND DATA MANAGEMENT
5.3 PROJECT SCHEDULE
REFERENCES
GLOSSARY OF ABBREVIATIONS
47
51
52
53
53
53
53
57
59
OtoCD
TABLES
NUMBER PAGE
2-1 NJDEP GROUNDWATER ANALYSES 8
2-2 EPA TAT GROUNDWATER ANALYSES (ppb) 10
2-3 NJDEP SOIL/DRUM ANALYTICAL DATA (ppb) 13
3-1 POTENTIAL REMEDIAL MEASURES 23
FIGURES
NUMBER PAGE
2-1 SITE LOCATION MAP 3
2-2 GENERAL SITE ARRANGEMENT 5
2-3 SUMMARY OF SAMPLE LOCATIONS 7
2-4 SITE PLAN SHOWING GEOPHYSICAL SURVEY 17
2-5 AREA A GEOPHYSICAL INVESTIGATION RESULTS BASED 18ON COMPOSITE OF MAGNETOMETER, GRADIOMETER ANDSOIL GAS TESTING RESULTS
2-6 AREA B GEOPHYSICAL INVESTIGATION RESULTS BASED ON 19COMPOSITE OF MAGNETOMETER, GRADIOMETER AND SOILGAS TESTING RESULTS
5-1 PROJECT ORGANIZATION 54
5-2 PROJECT SCHEDULE 55
oCO
t 0371
1.0 INTRODUCTION
NUS ' Corporation (NUS) under contract to Ebasco Services,Incorporated (Ebasco), is submitting this Final Work Plan forthe Ewan Property Site to the U.S. Environmental ProtectionAgency (EPA) in response to Work Assignment Number 130-2LA5under Contract Number 68-01-7250 (REM III).
The Remedial Investigation/Feasibility Study (RI/FS) activitieswere initiated by NUS under EPA Contract Number 68-01-6699(REM/FIT) that expired September 30, 1986. The balance ofactivities will be completed by NUS under the REM III contract.This Work Plan presents the technical scope of work as well asan estimated level of effort and schedule of activities for theEwan Property Site in Shamong Township, Burlington County,New Jersey.
The overall objectives of the RI/FS are to determine the natureand extent of the threat to public health and the environmentpresented by the release of hazardous substances from the siteand to evaluate proposed remedies. This document presents theplan to be implemented to attain these objectives. This WorkPlan contains five sections: 1.0 Introduction; 2.0 Summary ofExisting Data; 3.0 Scoping of Activities for the Ewan PropertySite; 4.0 Task Plan for the Remedial Investigation/FeasibilityStudy; and 5.0 Project Management Approach.
05
-i-
0
a
7
a
.1•IJJJJJ
JJ
f
r
11IC
2.0 SUMMARY OF EXISTING DATA
2.1 SITE HISTORY
The Ewan Property Site consists of a 43-acre tract of landlocated in Shamong Township, Burlington County, New Jersey. Thesite is identified as Block 23, lots 32 and 32A, on local taxmaps. Portions of the property were used, or were suspected ofbeing used, for the disposal of drums and/or bulk liquid waste.The site is located south of Tuckerton Road, as shown onFigure 2-1, and is accessible via a private dirt road. The siteconsists of two individual areas, Area A and Area B, both shownon Figure 2-1.
The site is located approximately 25 miles southeast of Camdenin the northwest corner of the New Jersey Pinelands. TheWharton State Forest is located approximately 2 miles south ofthe site. Land use within 1-1/4 miles of the site is generallyfarmland or forest. Located north and east of the site areseveral recent residential developments.
Prior to the RI field activities, two areas on the property,indicated on Figure 2-1 as Areas A and B, were identified asknown or suspected disposal areas. Both of these areas wereinvestigated during the field activities. Area A, approximately9 acres in size, is a known disposal area of buried drums. Theestimated number of buried drums ranges from 500 to 8,000.Disposal reportedly occurred in 1976 and 1977, involving trenchexcavation and subsequent burial of the drums. Areas A and Bare covered with thick brush, numerous small (5- to 10-foothigh) pine trees, and some larger trees. Area B, approximately5 acres in size, was a suspected disposal area. No drums thatcontained industrial-type wastes were located in Area B duringthe RI field activities. No evidence of bulk liquid wastedisposal was found in either area. Additional information andconclusions regarding the nature and extent of the contaminationin Areas A and B will be presented in the RI and FS Reports.
2.2 SITE DESCRIPTION
The following subsections provide the reader with summarizeddescriptions of the environmental setting at the site. A moredetailed description of all activities performed by NUS underthe REM/FIT contract will be included in the RI Report.
2.2.1 Geology and Soils
T The following information is based on regional geology and has' been supplemented, where noted, by information obtained by NUS
during the REM/FIT contract.
The Ewan Property Site is in the Atlantic Coastal Plainphysiographic province. Burlington County is underlain bycoastal plain deposits of Quaternary, Tertiary, and Cretaceousage, which are composed of alternating clay, silt, sand, and
i:rcirf!i:
i -2-
T// r-
x x/;;APPROXIMATE EWANPROPERTY BOUNDARY
RESIDENTIALDEVELOPMENT* »!.• N v SCALE IN FiET
3ASE MAPISAPORTIONOFTHEU.S.G.S. SOUTHWEST INDIAN MILLS, NJ QUADRANGLE(7.5 MINUTE SERIES. 1957.>HOTOINSPECTED 1972, CONTOUR INTERVAL 10 FEET). EWAN PROPERY LOCATION IS APPROXIMATE.
FIGURE 2-1
SITE LOCATION MAPEWAN PROPERTY SITE. SHAMONG TWR. NJ
-3-
gravel strata. These sedimentary deposits are underlain bycrystalline rocks of Early Paleozoic or Precambrian age. TheCoastal Plain deposits in Burlington County range in thicknessfrom less than 500 feet in the northern portion of the county,to greater than 3,500 feet in the extreme southeastern tip ofthe county. The pre-Quaternary deposits dip gently to thesoutheast. There are no in-place residual soils within thecounty. The soils present are weathering products of the marinesand and silt deposits (Rhodehamel, 1973).
* For the purpose of this study, bedrock was not furtherI considered, since the depth to top of rock is approximately*' 2,100 feet in the study area {Rhodehamel, 1973).
f
t; In 1983, the New Jersey Department of Environmental Protection(NJDEP) installed five monitoring wells to a maximum depth of25 feet. The NJDEP wells are identified as EP-1 through EP-5(see Figure 2-2). The boring logs indicate that these wellsencountered varying amounts of sand, silt, and gravel (DiamondDrilling Co., Inc., 1983). One well, EP-3, encountered a thin,apparently discontinuous, clay layer. The local domestic wellrecords do not indicate a continuous clay layer.
In 1986, NUS determined that the upper aquifer at the site' location, the Cohansey Sand, has a thickness ranging betweeni 76 and 87 feet in the study area. The Cohansey is a yellow,
coarse to fine, quartz sand containing minor amounts of gravel,' silt, and sand, and interbedded clay lenses. The average strike< of the Cohansey Sand is N 73:E. It dips gently, 10 feet
per mile, to the southeast. According to Rhodehamel (1973), the^^ Cohansey contains massive to laminated, carbonaceous, clayI layers to a thickness of 24 feet. This type of clay layer was4 not encountered during the field activities conducted by NUS
in 1986.I
The unit underlying the Cohansey Sand is the Kirkwood Formation,having an estimated thickness of 85 feet in the area surroundingthe site. The Kirkwood, which consists of interbedded clays,sands, and gravels, is reported to be hydraulically linked tothe above-lying Cohansey Sand (Farlekas, 1976). The hydraulic
f connection between the Cohansey and Kirkwood formations wasj illustrated during aquifer testing activities conducted by NUSI in 1986.
1 2.2.2 Nature and Extent of. the Problem
Previous site investigations have revealed the existence ofburied drums in Area A. Soil and groundwater data indicatecontamination by volatile organics, base/neutral extractable
L organics, and heavy metals. Offsite groundwater contaminationhas not yet been detected, although a plume is thought to extendsouthwest from Area A.
c:-4-
WM»ll Will SOU INED »f:TC-IO»Of(OMANUTK • IOITOM Of COHANUVIK IO» CHUM WOOD
FIGURE 2-2
GENERAL SITE ARRANGEMENTEWAN PROPERTY SITE.SHAMONG TWR. NJ KALI H fill
PRIMUS_L_ CX3RPOFUXnQN
oCO
r
rf
The results of the REM/FIT field investigation will be detailedin the RI Report. Figure 2-3 provides a summary of samplelocations (excluding domestic wells) from the REM/FIT study.
2.2.2.1 Monitoring Well Sampling Results
Five monitoring wells (EP-1 through EP-5) were installed inArea A by the NJDEP on September 16, 1983. The monitoring wellsare constructed of 2-inch-diameter PVC and monitor the upperportion of the Cohansey Sand. The NJDEP sampled these wells onSeptember 23, 1983. All samples were sent to a laboratory forpriority pollutant analysis. The detected contaminants arelisted in Table 2-1. These data indicate significant levels ofpriority pollutant compounds in the groundwater on site,particularly volatile organic and heavy metal contamination.
The data from Table 2-1 indicate that monitoring wells EP-3* and EP-4, located in the south and southwest portions of Area A,
respectively, have the highest levels. This pattern ofgroundwater contamination is consistent with the southerly
r groundwater flow direction measured by the NJDEP onOctober 4, 1983 (Sadat, 1983). The priority pollutant organicsdetected at the highest concentrations in wells EP-3 and EP-4included methylene chloride, toluene, n-butylbenzene,
f o-dichlorobenzene, p-dichlprobenzene, and 1,2,4-tri-chloro-1 benzene. The only priority pollutant organic detected in
wells EP-1 and EP-5 was methylene chloride (48 and 92 parts perbillion [ppb], respectively). Methylene chloride (1,860 ppb),
; chloroform (23 ppb), and 2,4-dichlorophenol (7 ppb) were theonly organics detected in well EP-2. Priority pollutant
.^_y inorganics that appeared to be present at elevated levels abovebackground included arsenic, chromium, lead, and zinc.
On September 4, 1984, the five NJDEP monitoring wells weresampled by the EPA Technical Assistance Team (TAT) contractor.The analytical results are presented in Table 2-2. The samepattern of Priority Pollutant List compounds was evident, withwells EP-3 and EP-4 again showing the highest levels of prioritypollutant organic contamination. The organics detected athighest concentrations included toluene, ethylbenzene, andacenaphthene. Priority pollutant inorganics detected atelevated levels included arsenic, chromium, copper, lead,mercury, and zinc.
Between July and September 1986, eighteen monitoring wells wereinstalled by NUS under the REM/FIT contract (Figures 2-2 and2-3). These wells are constructed of 4-inch, Type 304,stainless steel. Each well contains a 4-inch-diameter, 20-slot,wire-wrapped screen constructed of Type 304 stainless steelwhich is 10 feet in length and contains a threaded cap on thebottom. The riser pipe for each well is 4-inches in diameter,schedule 5, threaded, flush joint, and stainless steel. Thesewells are labeled TC, BC, and TK numbers 1 through 18. Theletters indicated that the screened interval is top of the O
CO*J
^ CO
-6-
•C-17
LEGENDEXISTING UOMTCMINC «CUS:
• BOTTOM OF COHAMSEY FORMAlKM•-•• TOP Of COHANSCV FORMAlKM
• TOP OF KMXMDOO FORMATION»•*HOLS
,.-»•—^
A SURFACE wkiDt/saMonB TEST PIT
• SOIL SAMPLE
A STAFF CAUCC
•AWO-007NOTE' SAMPLE LOCATIONS ARC APPROXIMATE SW/SO-OOf
SUMMARY OF SAMPLE LOCATIONS(EXCLUDING DOMESTIC WELLS)
EWAN PROPERTY SITE. SHAMONG TWP.. NJ KAUHflll
FIGURE 2-3
IMUS'ORATOM
TABLE 2-1
NJDEP GROUNDWATER ANALYSES (ppb)*EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
SEPTEMBER 23, 1983
Parameter
OrqanicsMethylene chlorideChloroformTolueneo-Xylenem-Xylenep-XyleneEthylbenzenetrans-1, 2-Dichloroethene1,1-DichloroethaneCumen1,3, 5-Tr imethylbenzene1,2, 4-Tr imethylbenzeneCyclopropylbenzeneBenzeneo-Chlorotoluene2,3-Benzofurann-Butylbenzeneo-Dichlorobenzenep-Dichlorobenzene1,2, 3-Trichlorobenzene1,2, 4-Trichlorobenzene2 , 4-Dichlorophenol2-NitrophenolButyl benzyl phthalate
WellEP-1
48-----------------------
WellEP-2
1,860
23--
-
--
--
-
--
-
---
---
--
7--
WellEP-3
1,500-
5,50054220-
7550
713882
27122-
-
-
-
-
-
-
-
WellEP-4
760-
3580-
8830-
-
13
47--
14
135-
1,7002,4209,600
400
5,600-
9085
WellEP-5
92-----------------------
FieldBlank
3-----------------------
CO00
-8-
rrI!r
TABLE 2-1NJDEP GROUNDWATER ANALYSES (ppb)*EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEYSEPTEMBER 23, 1983PAGE TWO
Parameter
InorqanicsArsenicCadmiumChromium (Total)CopperLeadNickelZinc
WellEP-1
5-
88656523139
WellEP-2
64-
1321007360537
WellEP-3
31-
161691134604
WellEP-4
361
264
200
4571
1,062
WellEP-5
-
-
5730620108
FieldBlank
------5
Source: J Buttich, Chain of Custody - NJDEP Sample AnalysisSheets, 9/23/83All data expressed in ppb* Only quantifiable data presented; samples analyzed for
Priority Pollutant List compounds- Not detected
CO00
-9-
TABLE 2-2
EPA TAT GROUNDWATER ANALYSES (ppb)*EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
SEPTEMBER 4, 1984
Ir
IIr
Parameter
OrganicsChloroformTolueneEthylbenzenet rans-1 , 2-Dichloroethene1 , 1-Dichloroethane1 , 2-DichloroethaneTrichloroetheneTetrachloroetheneAcenaphtheneAnthraceneButyl benzyl phthalateBis ( 2-ethylhexyl )phthalateDi-n-butyl phthalateDiethyl phthalateDimethyl phthalateInorganicsAntimonyArsenicBerylliumChromiumCopperLeadMercurySeleniumZinc
WellEP-1
---------------
5.45.8-
20J3320J0.3J
-120
WellEP-2
2.8--------------
2.0J--
20J4720J
0.4J4J93
WellEP-3
-86017027-
4.4---------
4.0J285J
130170662.54J
3,000
WellEP-4
-340470----166102592100---
4.0J2.0J
-20J72-
0.7J4J89
WellEP-5
--
2.5-----21-
4.221134.52
9.03.0J
-722909J
0.6J-87
TravelBlank
25---2-
2.4--------
16--
10J-9J---
Source: "Preliminary Field 'Investigations at Ewan Property DumpSite," Weston/SPER Division, Edison, NJ (not dated)
J = estimated valueAll data expressed in ppb* Only quantifiable data above method detection limit
presented; samples analyzed for Priority Pollutant Listcompounds
OCO
-10-
I Cohansey (TC), bottom of the Cohansey (BC), and top of theKirkwood (TK).
In September 1986, NUS conducted two rounds of monitoring wellw^ sampling (September 2-5, 1986 and September 15-19, 1986). The•^ 18 newly installed wells and the 5 NJDEP wells were sampled
during both rounds. All samples were analyzed for the completer Target Compound List (TCL) of organic and inorganic compounds.All samples that were analyzed for the full TCL, also included alibrary search of tentatively identified compounds. The TCL
f organic compounds detected are primarily located in wells onsitein Area A (NJDEP wells EP-2, EP-3, and EP-4). Outside ofArea A, well TC-19 demonstrates the greatest indication of
_ contamination. This well is approximately 350 feet downgradientF of well EP-2 and demonstrates low levels of some of the same•* organic TCL compounds, as well as low levels of other compounds
detected in wells EP-3 and EP-4. TCL inorganic compounds follow( a pattern similar to the TCL organic compounds. Concentrations
of iron are generally high site-wide. However, this isparticularly true for the NJDEP wells. Also consistent with the
i' pattern of organic contamination, well TC-19 demonstrated anI elevated level of iron. Other TCL inorganic compounds that are
elevated in relation to drinking water standards includechromium (EP-3, EP-4, and EP-5), manganese (EP-2, EP-3, EP-4,
I; and EP-5), and barium (EP-5).li
The data collected for the hydrogeologic investigation conducted(T during July through September of 1986 indicate that groundwateri flows from north to south across the site. Additional details
will be presented in the RI Report.T! 2.2.2.2 Domestic Well Sampling Results
Offsite domestic wells were sampled by the EPA FieldInvestigation Team (FIT) contractor on April 10, 1984. No TCLorganics were detected above quantitation limits. Inorganicswere within the National Interim Primary Drinking WaterStandards and National Secondary Drinking Water Standards(except for two wells, which contained iron at concentrationsgreater than the secondary standard of 300 ppb). The elevatedlevels of iron are probably caused by naturally occurring ironor by aged well casing and piping (NUS FIT, 1984).
Offsite domestic wells were sampled on October 24, 1984, byEPA's Technical Assistance Team (TAT) contractor. Low levels ofseveral pesticides were detected in two wells, and 50 ppb ofmethylene chloride was also detected in one of these wells. Noother organics were detected above guantitation limits.Priority pollutant inorganics were below National InterimPrimary and National Secondary Standards (Weston/SPER Division,not dated).
One round of domestic well sampling was performed by NUSin 1986. Eleven samples were obtained and analyzed for the fullTCL of organic and inorganic compounds. One TCL organic
-11-
fI
f
I
riiI!itf!
compound (benzene) was reported as an estimated value for 'two domestic well samples; both at values below the laboratorydetection limits and well within the drinking water standards.One TCL inorganic compound (copper) was detected at asignificant level. Copper values were not elevated elsewhere,therefore no association with the site can be made. The copperconcentration may possibly be attributed to copper piping andthe naturally occurring low pH of the area groundwater. Basedon the results of the groundwater analyses to date, includingthe results of the REM/FIT study, migration of contamination offsite to potable wells has not yet occurred at the Ewan PropertySite.
2.2.2.3 Surface Water and Sediment Sampling Results
The EPA FIT contractor sampled the farm pond west of Area A andthe marshy area south of Area A. Neither area showed signs ofpriority pollutant organic or inorganic contamination (NUSFIT, 1984).
The EPA TAT contractor sampled five surface-water locations onSeptember 4 and October 24, 1984. The small stream that flowsbetween Areas A and B, the same stream downstream from the siteat the Route 206 culvert, and the pond on site north of Area Awere not contaminated. The farm pond to the west of Area Acontained methylene chloride (22 ppb). The marsh locatednorthwest of Area A was sampled on both occasions. Di-n-octylphthalate (23 ppb) and bis-2-ethylhexyl phthalate (22 ppb) weredetected on September 4, 1984, while methylene chloride (34 ppb)was detected on October 24, 1984 (Weston/SPER Division, notdated).
The EPA FIT and TAT contractors' data indicated little, if any,surface water priority pollutant contamination on and off site.
Both surface water and sediment samples were obtained by NUSduring the REM/FIT study in 1986. Three surface water andseven sediment samples were collected and analyzed for the fullTCL. A review of the data indicates that pesticides are foundin sediments upgradient of Area A and in the northern portion ofArea B. Other TCL organic contaminants were detected in some ofthe surface water/sediment samples and aluminum and iron weredetected in most of the samples. The data from the REM/FITstudy will be fully evaluated in the RI Report.
2.2.2.4 Soil/Drum Sampling Results
NJDEP collected drum and soil samples on July 6, 1983(Weiss, 1983). All samples were analyzed for Priority PollutantList compounds. Analytical data for the four samples arepresented in Table 2-3 (Zachowski, 1983). As indicated, thedrums and soil sampled contain numerous volatile andbase/neutral extractable organics and heavy metals. Pesticidesand PCBs were not detected. Common contaminants detected in Oboth the drums, soil, and onsite groundwater include toluene, CO
00tffc
-12-
frr
TABLE 2-3
NJDEP SOIL/DRUM ANALYTICAL DATA (ppb)*EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
JULY 6, 1983
Parameter
OrganicsMethylene ChlorideTetrachloroetheneTolueneBenzeneo-Xylenem-Xylenep-Xylene1 , 2-Dichloroethene1 , 2-Dicholoroethaneo-DichlorobenzeneEthylbenzeneNaphthalenePhenanthrene/anthracenePyreneChryseneAcenaphthyleneBenzo(a)anthracene/chryseneHexachlorobutadieneStyrene1, 2, 4-Tr imethylbenzene1,3, 5-Tr imethylbenzenePhenol4-Nitrophenolsec-Butylbenzene4-Chlorophenyl phenyl ether
ES-1
----
225115-
-
250
415--
800200-------
11,200-
--
ES-2
825
100
29511,800
4085,7632,685
145--
2,630
1,585----
14,000--
---
-
-
25,000
ES-3
-
145---
185----------------
61,000--
ES-4
-
-
285,00030,60026,300
43,10017,100
--
415-
400,000
227,000--
385,000-
9806,80020,1008,300
--
385-
COGO
-13-
r
rrrcrI!
11f!
TABLE 2-3NJDEP SOIL/DRUM ANALYTICAL DATA (ppb)*EWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEYJULY 6, 1983PAGE TWO
Parameter
Orqanics - Continuedo-ChlorotolueneN-propylbenzenebis(2-ethylhexyl)phthalateDi-n-butylphthalateDiethyl phthalateInorganicsAntimonyArsenicCadmiumChromium (Total)CopperLeadMercuryNickelSeleniumSilverZinc
ES-1
-----
--
1,99029,4002,4608,810
-
8,230-
1,6503,120
ES-2
-
--
-
-
188468-
2,190-
-
46
993--
9,360
ES-3
-
----
1264,933
-
1,320
1,050-
682,080
--
55,600
ES-4
3,3003,200
300,000190,000205,080
-
501,920
-
10,6003,490
-
7,100134
1,220135,000
All data expressed at ppbSample Description:
ES-1- Brown liquid from buried, 5-gal., plastic-linedmetal container. Near grid marker 6C2
ES-2- Dark stained soil. Near grid marker 5A1ES-3- Wet soil near buried drum. Near grid marker 1B4ES-4- Reddish liquid from punctured drum. Near grid
marker 2B2Source: Zachowski, M., Chain of Custody-NJDEP sample analysis
sheets, 7/6/83* Only quantifiable data presented; samples analyzed for
Priority Pollutant List CompoundsOCO00c:
-14-
r[fc
ethylbenzene, tetrachloroethene, acenaphthene, anthracene,several phthalate esters, chromium, lead, mercury, and zinc.
In 1986, a series of sixteen test pits were excavated by NUS.These test pits were located based on the results of the soilgas screenings and geophysical surveys. The locations of thetest pits are indicated in Figure 2-3. Seven test pits wereexcavated in Area B. Metallic debris, domestic trash, one metaldrum that contained domestic trash, and bog iron wereencountered in these test pits. Nine test pits were located inArea A. Drums were encountered in four of the test pits(10, 13, 15, and 16); rusted metal shards in one test pit (11),and bog iron or no visible contamination was found in four testpits (8, 9, 12, and 14).
Samples were taken of source materials, soils, and groundwater.All samples were analyzed for full TCL compounds. The results
( indicate that contamination may be localized near or immediatelydowngradient of the trenches that contain drums. Details ofthese activities will be provided in the RI Report.
2.2.2.5 Air Quality Survey
NJDEP performed an air quality survey on September 21, 1983,I using an organic vapor analyzer (OVA). Readings at the well* heads with the caps closed ranged from not detected at
wells EP-1, EP-2, and EP-5 to greater than 1,000 ppm atf well EP-3. Readings in the vicinity of drums reached a maximum| of 200 ppm (Zachowski, 1984).
**~^ During monitoring well sampling by EPA's TAT contractor in; September 1984, OVA readings in the breathing zone were1 generally within background levels of 0-2 ppm, except at
well EP-3 during bailing, where the readings were 10 to 20 ppm.
Ambient air readings were measured with a photoionizationdetector (PID) during the initial site visit conducted by NUS onJuly 23, 1985. No readings above background were detected inthe ambient air. Subsequently, air monitoring was conducted byNUS during the REM/FIT field activities. These results will bepresented in the RI Report.
2.2.2.6 Geophysical Surveys
An electromagnetic (EM) conductivity study was conducted by theNJDEP on Area A in April 1983. Several areas of highconductivity were identified on site and were thought to beassociated with buried drums. A plume-like anomaly trending tothe north from the southern portion of Area A and identified byNJDEP as a potential groundwater contaminant plume is apparentlyalso associated with buried drums, as indicated by the resultsof the magnetometer survey (Andres, 1983). Although it waslater determined that the groundwater flow direction is in thesoutherly direction, the anomaly identified by NJDEP wasconfirmed by a study conducted by EPA's TAT contractor. ^
^^ 00
-15-
I EPA's TAT contractor conducted a limited magnetometer survey onSeptember 19, 1984, at Area A {Weston/SPER Division, not dated).The survey consisted of data points along the access road
N—<•" surrounding Area A and one traverse through Area A. The resultsI of the survey indicate the presence of buried ferromagnetic
material on several portions of Area A. Figure 2-4 is ar reproduction of Figure 3 from the TAT contractors' report. Thisfigure depicts the site plan showing the geophysical surveyresults. The anomaly identified by NJDEP in 1983 was confirmed
,r by a similar anomaly identified by TAT which was located along[ magnetometer stations 43 through 49A.t.
Under the REM/FIT contract, NUS conducted an extensive7 magnetometer survey and an electromagnetic conductivity studyi over the site. The results of the magnetometer, gradiometer,
and soil gas testing were summarized and are presented inFigures 2-5 and 2-6 (Areas A and B, respectively). The detailsof the surveys will be presented in the appropriate section ofthe RI report.
cCO
-16-
EW 3
AREA O*" STRONG POSITIVE MAGNETIC ANOMALY (TAT. 1984)
AREA OF WEAK POSITIVE MAGNETIC ANOMALY (TAT. 1»8«>
AREA OF nOOERATE ELECTROMAGNETIC CONDUCTIVITYANOMALY (NJDEP. 198)1
AREA OF WEAK ELECTROMAGNETIC CONDUCTIVITY ANOMALY(NJDEP, 1983)
APPROXIMATE LINE OF TRAVERSE FOR ELECTROMAGNETICCONDUCTIVITY SURVEY (NJDEP. USD
LOCATION AND NUMBERING Of MAGNETOMETER STATIONS(TAT. I»S«>
LOCATION OF CXISTINC MONITORING WELL
AREA OF VISUALLY OBSERVED EXPOSED
WO•CALC
SITE PLAN SHOWING GEOPHYSICAL SURVEYopriocoTv eirr CHAMOMA TWO N.I -17-
FICURE 2-4
JIMUSICX3RPQRA71OM
LEGEND
/ ( J———* MMOICS MUr -* flft^cn. BM«
S MCA STMMLY ftJVCCtTO Vouccis, MCOUKM MM or MOMH.V
or V——4 OfNOlUMUl
. N -' oa«cn,ftwi
MOT£' ADDITIONAL INFORMATION ON THE GEOPHYSICALINVESTIGATION CAN 8t rOUNO IN THE FINAL »TEOPERATIONS PLAN1NUS. !*•«).
AREA A GEOPHYSICAL INVESTIGATION RESULTSBASED ON COMPOSITE OF MAGNETOMETER. GRADIOMETER
AND SOIL GAS TESTING RESULTSEWAN PROPERTY SITE. SHAMONG TWP.. NJ
FIGURE 2-5
IMUSCQRPQRATON
LEGEND
•1 OCNOTC3 MCA inOMiLY auSKCro OF GMTAIWC tUttO FfNMMoaccn. W9CO artu MAMIUK OF AHOMAUT (ratw MAMCTOCIU
•2 OCNOTCS MCA SIMMLT SUSFtCTtO OF OONTAHHC IUFICO FCmoutnjccrs, MKO am «HAF< or AMMAU IFWW HAWCTDUCIUISOFUTH MAPI.
•3 DUOTCS AIICA inKMOLr SJWCCTCO OF COHTAMIM iUMCO FCMQU>0&CCTS, IASCOUF<M MASMTUOC OF AMOMAU IFffOM CHAaOMITCHDATA OOfUTH MAF).
OCNOICSMCA STDOMCUr SUJMOIO OF CONIAMM UfKO FUKKAogjccn. KUCO UPON JHAPC OF A«OM>I» VMM MAMHCK*
ocwmt MCA tnoMu maxciie OF OMUMM VCLATILI
MOTE. AOCHTIOtlAL INfOIUUTION ON THE OCOPHTSICAL IMVCSTIOATIOMCAN K FOUNOM THE FlNM. IITE OKIUTION1 POM MUS, IM«I.
tttyf
AREA B GEOPHYSICAL INVESTIGATION RESULTSBASED ON COMPOSITE OF MAGNETOMETER. GRADIOMETER
AND SOIL GAS TESTING RESULTSEWAN PROPERTY SITE. SHAMONG TWP.. NJ
MO
FIGURE 2-6
IMUSCCDRPORATiaN
0392
ririirif^ii
f!
3.0 SCOPING THE ACTIVITIES FOR THE EWAN PROPERTY SITE
The remedial investigation and feasibility study (RI/FS) for theEwan Property Site was initiated by NUS under the REM/FITcontract which expired at the end of September 1986. TheREM III scope of work involves concluding the RI by preparing anRI Report, conducting treatability studies (if necessary),conducting the FS, and providing support to the EPA duringpreparation of the Record of Decision. A major factor affectingthis study involves evaluating the impacts SARA has had on theproject, since all field activities were performed prior to itsenactment.
The following subsections identify the objectives for the EwanProperty Site Study, identify Preliminary Remedial Technologiesand provide a discussion on Applicable or Relevant andAppropriate Requirements (ARARs).
3.1 RI/FS OBJECTIVES
The three primary objectives identified for the Ewan PropertySite involve (1) ensuring compliance with SARA, (2) providingthe data base and technical understanding needed to complete afeasibility study (FS), and (3) evaluating the remedial actions.
The remedial investigation (RI) field activities for this sitewere conducted prior to the enactment of SARA(October 17, 1986). The additional requirements of SARA on theoverall study will be identified and any additional datacollected.
The results of the RI field activities must be reviewed andevaluated to determine if the specific objective of the RI havebeen attained. The items that are to be performed in order toachieve the main objective of the RI include:
• Characterize the nature and the horizontal and verticalextent of onsite soil contamination in Areas A and B.
• Characterize the hydraulic properties of the shallowaquifer in the near vicinity of the site (depth to watertable, hydraulic gradient, aquifer thickness,permeability, flow direction, flow velocity, groundwaterdischarge and recharge).
• Determine the nature and extent of site-related chemicalcontamination within the shallow aquifer system (Cohanseyand Kirkwood Formations).
• Determine the potential for the shallow aquifer to behydraulically connected to deeper aquifers.
• Determine the nature and extent of site-related chemical Ocontamination in surface water and sediments. CO
COCC
-20-
• Compile a data base that will support an evaluation of 'public health and environmental concerns.
• Compile the site-specific ARARs.
• Conduct an evaluation of public health and environmentalconcerns, including evaluation of the following:
Nature and extent of contaminant source- Existing and potential pathways for contaminant
transportLocation of existing and potential receptorsRisk to receptors associated with existing orpotential exposures to site-related contaminantsDegree to which site contaminants exceed ARARs
• Compile a data base that will support a feasibility study(FS) of remedial alternatives. The list of remedialalternatives and approach to evaluation of thealternatives must be in compliance with the requirementsof SARA.
Based on the results obtained from the RI, an evaluation ofremedial actions at the site will be conducted during the FS.The specific items that will be completed in order to performthis evaluation will include:
• Determination of the need for source control actions.
• Determination of the need for management of migration ofcontaminated groundwater.
• Identification of source control and management ofmigration technologies appropriate to the siteconditions, particularly those alternatives that wouldoffer a permanent solution or reduction in wastetoxicity, mobility, or volume.
• Identification of additional data required to developalternatives.
• Development and evaluation of appropriate source controland management of migration technologies, as well as thenoaction alternative, for the Ewan Property Site.
3.2 PRELIMINARY SCOPING OF REMEDIAL TECHNOLOGIES
To meet the objectives developed, a set of general responseactions were identified. These general response actions fallinto the following categories:
• Containment• Treatment O• No action CO
CC
-21-
( Remedial technologies that address these actions are discussedin the following paragraphs. Technologies will be screened indetail during the FS. In general/ technologies will be screenedby site-limiting characteristics/ waste-limiting character-istics/ and inherent limitations of the technology. Thetechnologies that remain after screening will be developed intoalternatives. A preliminary list of potential remedial measuresis presented as Table 3-1. A document will be developed thatpresents the preliminary screening of alternatives. Thisdocument will be submitted to the EPA and will be used to focusin on the potential treatability studies.
Containment
Source control (containment) remedies prevent or minimizemigration of hazardous substances from the source material.Such measures may assist in the attainment of preliminaryresponse objectives by minimizing the volatilization ofcontaminants/ preventing direct contact with wastes andcontaminated soil, minimizing the amount of contaminantsleaching to groundwater, and reducing contamination in surfacerunoff.
Treatment
Ail potentially applicable remedial action alternatives will beidentified. Several technologies, used alone or in combination,may effectively control the level of contamination in variousmedia. Treatability studies may be conducted to determine if analternative that has passed the screening process is trulyfeasible.
No Action
The no-action alternative generally consists of site fencing andgroundwater monitoring. The NCP requires that the no-actionalternative be considered in the remedy selection process.During this selection process/ an assessment of the degree towhich remedial response objectives are met will be made. Ifpotential public health or environmental impacts are indicatedor if ARARs will not be met, the no-action alternative will notmeet response objectives. If these objectives are not met, theno-action alternative may not be applicable to the Ewan PropertySite.
OCOCOcr*
-22-
TABLE 3-1
III;
POTENTIAL REMEDIAL MEASURESEWAN PROPERTY SITE, SHAMONG TOWNSHIP, NEW JERSEY
Containment
Barrier WallsFrench DrainsCappingLandfill DisposalExtraction WellsEtc.
Treatment
Source: Total or Partial Excavation and SubsequentTreatment
IncinerationSolidificationFixationStabilizationEtc.
Management of Migration: Pump and Treat
OrganicsActivated CarbonAdsorptionAir StrippingEtc.
InorganicsOxidation/ReductionPrecipitationFlocculationClarification/FiltrationEtc.
No Action
COCOc:
-23-
3.3 IDENTIFICATION OF DATA REQUIREMENTS
3.3.1 Determination of ARARs
SARA, defines ARARs as:
• Any standard requirements, criteria, or limitation underany Federal environmental law.
• Any promulgated standard, requirements, criteria, orlimitation under a state environmental or facility sitinglaw that is more stringent than any Federal standard,requirements, criteria, or limitation.
Under this requirement, many state and Federal environmentalrequirements must be considered. These requirements includeARARs which govern the extent of site cleanup; ARARs whichpertain to existing site features; ARARs which pertain toproposed site remedies; and ARARs which govern implementation ofthe selected site remedy.
ARARs which govern the extent of site cleanup may provide eitheractual cleanup levels or a basis for calculating such levels.For instance, groundwater and surface water criteria andstandards as well as air standards may provide necessary cleanupgoals for the Ewan Property site.
Site features which may be governed by ARARs may include naturalfeatures such as wetlands and floodplains as well as manmadefeatures such as existing landfills or disposal area. SuchARARs can provide a basis for assessing existing site conditionsand can later aid in assessing potential remedies.
ARARs which govern extent of cleanup and existing features areused to develop remedial response objectives and alternatives.After alternatives are developed, ARARs which pertain toproposed site remedies can provide a basis for assessing thefeasibility and effectiveness of the remedy. Such ARARs mayinclude hazardous waste transportation and handlingrequirements, air and water emissions standards, and RCRAlandfilling requirements. Section 121 of CERCLA generallydirects EPA to select remedies that attain ARARs.
ARARs pertaining to implementation of the site remedy can governdesign, construction, and operation of the remedy. ARARsconsidered during the development and evaluation of remedieswould be implemented. Such ARARs might include hazardous wastemanifesting, groundwater monitoring, and worker safetyrequirements.
In SARA, a need to inventory these ARARs of state and Federallaw was identified. Some preliminary ARARs have beeninventoried in Section 3.3.3. As the RI/FS process continues,more ARARs will be considered and developed. These ARARs willbe grouped based on specific categories (i.e., action specific,
-24-
I location specific, and contaminant specific). These ARARs mustbe used as a guide in evaluating the appropriate extent of sitecleanup, to aid in scoping and formulating remedial actionalternatives, and to govern the implementation/operation of the
fc —- selected action. The purpose of this requirement is to make1 CERCLA responses consistent with other pertinent Federal and
state environmental requirements.
[ In order to properly consider ARARs and, more importantly, toclarify their function in the FS and remedial responseprocesses, the KCP defines two ARARs components. Thesedefinitions have been revised to incorporate applicable portionsof SARA; they are discussed in the following paragraphs.
Applicable Requirements - Those Federal and state requirementsthat would be legally applicable to the response action if thataction were not taken pursuant to Sections 104 and 106 ofCERCLA. Requirements that are deemed to be applicable and havejurisdiction in the given situation are considered to beapplicable requirements.
Relevant and Appropriate Requirements - Those Federal and staterequirements that, while not applicable, are designed to applyto problems sufficiently similar to those encountered at CERCLAsites so that their application is appropriate. Relevant andappropriate requirements are intended to have the same weightand consideration as applicable requirements. The term"relevant" was included so requirements that were initiallyscreened as nonapplicable because of jurisdictional restrictions
v_/ would be reconsidered and, if appropriate, included as arelevant and appropriate requirement.
3.3.2 Consideration of ARARs During the RI/F5
ARARs will be considered at five decision points during theRI/FS for the Ewan Property Site. Specifically:
1.Task 6 - Public Health Evaluation (Section 4.2):Consider ARARs during the analysis of risk to publichealth and the environment.
2. Task 9 - Development of Remedial Objectives(Section 4.2): Compare site data base to ARARs.
3. Task 9 - Identification of Applicable Technologies andAssembly of Alternatives (Section 4.2): Utilize ARARsspecific to site conditions for development of actionlevels, specific response objectives, and remedialalternatives relative to criteria defined in40 CFR 300.68(f). Also, identify ARARs that apply to theformulated alternatives.
OCOCO00
-25-
4. Task 9 - Screening of Remedial Technologies/Alternatives(Section 4.2): Consider ARARs when assessing theeffectiveness of an alternative, as defined in40 CFR 300.68(g)(3).
5. Task 10 - Remedial Alternatives Evaluation (Section 4.2):Evaluate each alternative to the extent it attains or
T exceeds ARARs, as defined in 40 CFR 300.68-(h)(2)(iv).
It is also a requirement that ARARs be considered whenr determining data to be collected during the field investigation.[ If additional field activities are scoped, ARARs will play a key
factor in determining the data to be obtained.
f 3.3.3 Preliminary Identification of ARARs'' for the Ewan Property
f* In the discussion that follows, preliminary ARARs are identified1. for the Ewan Property Site. These ARARs were developed by
taking into account the following factors:
J • Chemicals suspected or known to be at the site.• Types of media in which contaminants are present.
fr • Potential transport mechanisms.; • Remedial alternatives that will be considered for the
'•' site.
JT The ARARs identified herein will continue to be refined and' revised to take site conditions and potential remedial actions\**s into consideration. A preliminary list of ARARs is discussed in?T the following paragraphs. Additional ARARs provided as guidancejl issued by EPA will be incorporated into this list as they are
made available. In addition, ARARs that apply to proposed)T treatment technologies will be considered as the technologiesjf are evaluated.
Federal Regulations
li • Clean Water Act of 1948 (Amended 1972) - Governs point-source discharge through the National Pollutant DischargeElimination System (NPDES), discharge of dredge or fill
r materials, and oil and hazardous spills to U.S. waters.
Water quality criteria were developed for 64 pollutantsin 1980 (45 FR 231) pursuant to Section 304(a)(l) of theClean Water Act. In 1983, EPA revised nine criteriapreviously published in the "Red Book" (Quality Criteriafor Water, 1976) and in the 1980 criteria documents.These criteria are not legally enforceable, but statestandards developed using the Federal criteria areenforceable.
• Clean Air Act of 1967 - Governs air emissions resultingfrom remedial actions. The Clean Air Act promulgated theNational Ambient Air Quality Standards (NAAQS). NAAQS °
COC£
-26-
fI
[[
are available for six chemicals or groups of chemicalsand for airborne particulates. The sources of thecontaminant and the route of exposure were considered inthe formulation of the standards. These standards do notconsider the costs of achievement or the feasibility ofimplementation. The NAAQS allow for a margin of safetyto account for unidentified hazards and effects.
• Resource Conservation and Recovery Act (RCRA) of 1976(Amended 1984) - Governs generation, transportation,storage, and disposal of hazardous wastes.
RCRA 40 CFR 264 standards are used for remedial actionsincluding offsite hauling and disposal of hazardouswastes, onsite capping and landfilling, and groundwatermonitoring.
• Groundwater Protection Strategy
EPA's policy is to protect groundwater for its highestpresent or potential beneficial use. This policy will beincorporated into future regulatory amendments. Thestrategy designates three categories of groundwater:
Class 1 - Special Groundwaters - Waters that arehighly vulnerable to contamination are eitherirreplaceable or an ecologically vital source ofdrinking water.
Class 2 - Current and Potential Sources of DrinkingWater and Waters Having Other Beneficial Uses - Watersthat are currently used or that are potentiallyavailable.
Class 3 - Groundwater Not a Potential Source ofDrinking Water and of Limited Beneficial Use - Class 3groundwater units are further subdivided into twosubclasses.
- Subclass 3A includes groundwater units that arehighly to intermediately interconnected to adjacentgroundwater units of a higher class and/or surfacewaters. These may, as a result, be contributing tothe degradation of the adjacent waters. They maybe managed at a similar level as Class 2groundwaters depending upon the potential forproducing adverse effects on the quality ofadjacent waters.
- Subclass 3B is restricted to ground-units char-acterized by a low degree of inter-connection toadjacent surface waters or other groundwater unitsof a higher class within the Classification ReviewArea. These groundwaters are naturally isolatedfrom sources of drinking waters in such a way that
-27-
T{ there is little potential for producing adverse
effects on quality. They have low resource valuesoutside of mining or waste disposal.
rv • Comprehensive Environmental Response, Compensation, and•*"""' Liability Act of 1980 (CERCLA, or Superfund Legis-
lation) - Governs identification of uncontrolledf hazardous waste disposal sites and specifies a logicalI process for their assessment and the remediation of
impacts to public health and the environment.
• Superfund Amendments and Reauthorization Act of 1986 andInterim Guidance on Superfund Selection of Remedy (OSWERDirective 9355.0-19, December 24, 1986) - The interimguidance requires that remedies be protective of humanhealth and the environment. Remedies must meet or exceedARARs or clean-up levels established via risk assessment.Remedies must utilize permanent solutions and alternativetreatment technologies or resource recovery technologiesto the maximum extent practicable.
• Toxic Substances Control Act of 1976 (TSCA) - Providesauthority to require testing of chemical substancesentering the environment and to regulate them, wherenecessary. PCS regulation and enforcement are animportant aspect of TSCA.
• Federal Floodplain Executive Order No. 11988 and WetlandsExecutive Order No. 11990 - This Executive Order is to beconsidered as implemented by EPA's August 6, 1985, Policyon Floodplains and Wetlands Assessments for CERCLAactions (CERCLA Compliance Policy).
IfI!
New Jersey Regulations
• New Jersey Hazardous Waste Management Regulations
Subchapter 10 of the New Jersey Administrative Codei (NJAC 7:26) presents operations and design standards for
hazardous waste facilities. It is divided into a numberr of sections that roughly correspond to those in RCRA.i
1 • New Jersey Water Pollution Control Laws
j NJSA 58:10 prohibits the discharge of hazardous1 substances. In the event of such a discharge, prompt
containment and removal is required. The act also• provides a Spill Compensation Fund for compensation to• businesses and other people damaged by a discharge. The
fund consists of per-barrel taxes levied on owners or, operators of major facilities (refineries, storage
facilities, pipelines, platforms, or deep-water ports)for petroleum or petroleum products.
-28-
rcr
i
f
This act (NJSA 58:10A) also empowers the state withadministration of the state's water pollution controlprogram, in particular, the New Jersey PollutantDischarge Elimination System (NJPDES).
• New Jersey Water Quality Planning Act
The objective of this act (NJSA 58:11) is to restore andmaintain the chemical, physical, and biological integrityof the state's waters, including groundwaters. It alsopromotes the area-wide waste treatment management plansto assure control of sources of water pollutants.
• New Jersey Hazardous Discharges Law
This act (NJSA 13:1 K) provides for reporting require-ments and penalties for release of hazardous substances.
• New Jersey Water Pollution Control Regulations
I' These regulations (NJAC 7:1E) cover every discharge ofpetroleum and other hazardous substances except those incompliance with a valid state or Federal permit. Theypresent guidelines to be followed in the event of a
IP spill, as well as reporting, design, and maintenance'! requirements for facilities that handle hazardous
substances.
Any discharge of a substance in a quantity or^__, concentration that may be harmful or that poses a
foreseeable risk must be reported to the Department ofI Environmental Protection. Facility owners or operators
must take containment measures. Facilities must file aDischarge Prevention Containment or Countermeasure (DPCC)
[ Plan and a Discharge Cleanup and Removal (DCR) Plan withi the state.
In most cases, facilities will be required to havej observation wells at a density of either one per acre or
one per source, whichever is less. These wells shall beI sampled and analyzed quarterly for parameters that are
acceptable to the state. Background levels must also be' determined.
• Pinelands Regulations
These regulations (NJAC 7:50-6) address cleanup tobackground concentrations or remediation to non-detectable levels.
-29-
• New Jersey Pollutant Discharge Elimination System(NJPDES) Regulations
It is the intent of the NJPDES (NJAC 7:14A) program toregulate
- Discharge of pollutants to surface waters andgroundwaters.
- Industrial discharges to municipal or privately ownedtreatment works.
- Land application of residuals and wastewaters(Subchapter 4).
- Discharge of leachate to surface waters orgroundwaters (Subchapters 3 and 4).
- Discharge of pollutants into wells.
Treatment/storage/disposal of hazardous wastes (thosenot regulated by NJAC 7:26).
Discharges to Groundwater
Regulated under NJAC 7:14A-6 are permitted hazardous wastefacilities such as surface impoundments or landfills, landapplications facilities, and infiltration lagoons. Thefollowing groundwater parameters must be analyzed:
1. Arsenic, barium, cadmium, chromium, fluoride, lead,mercury, nitrate, ammonia, selenium, silver, iron,manganese, sodium, sulfate, and chloride.
2 . Phenols
3. Lindane; methoxychlor ; toxaphene; 2 ,4-D; 2 ,4 ,5-TP Silvex;and endrin.
4. Radium, gross alpha, and gross beta.
5. Turbidity and coliform bacteria.
6. pH, TOC, TOX, and TDS.
7. Other organics as required.
Initial background levels must be established, or all parametersmust be measured monthly for 1 year. At least four replicatesamples must be collected monthly for items (6) and (7) above.After the first year, (1) through (5) must be analyzed monthly;(6) and (7) must be measured at least monthly; and static waterelevation must be determined.
-30-
ff
r
• New Jersey Surface Water Quality Standards
These standards (NJAC 7:9-4) are used to regulate theintroduction of toxic substances into surface waters.
• New Jersey Groundwater Protection Standards
New Jersey groundwater protection standards are to beconsidered in planning remedial alternatives.Additionally, if remedial alternatives involve surface
r water and/or groundwater treatment and discharge, theJ^ NJPDES regulations would apply.
ff • New Jersey Soil Erosion and Sediment Control ActStandards
uNew Jersey State vegetation and engineering standards for
* soil erosion and sediment control are to be consideredfor remedial alternatives which involve more than5,000 square feet of land surface area (NJAC 2:90-1.1).
r
• New Jersey Environmental CleanupResponsibility Act (ECRA) Standards
. The ECRA law, regulations, and materials provide guidanceon making a determination that a site is not contaminatedby hazardous materials. The ECRA regulations are foundat NJAC 7:1-3. Note that ECRA requires that minimumstandards be established for soil, groundwater, and
\^/ surface water quality for detoxification of the site ofj certain industrial establishments. In view of the fact
that state soil cleanup criteria have not been1 established, ECRA cleanup levels will be considered.
* • New Jersey Air Pollution Control Standardsi
New Jersey's air quality protection requirements deriveprimarily from the enclosed New Jersey Air Pollution
* Control Laws (New Jersey Revised Statutes, Title 26).Included in these is New Jersey's air pollution control
, law on permits (c. 106, P.L. 1967 [Title 26, 2C.-9.21]).; An important clause is contained in paragraph (c) of the
law on permits:
! "No operating certificate...required by this act, shallbe issued by the department unless the applicant showsto the satisfaction of the department that...theequipment incorporates advances in the art of airpollution control developed for the kind and amount ofair contaminant emitted by the applicant's equipment."
This clause is often referred to as the state-of-the-artrequirement.
-31-
f
1
New Jersey has promulgated 18 regulations based on theseAir Pollution Control Laws. The impact these regulationshave on hazardous waste site mitigation can be consideredin three categories: Prohibition of Air Pollution,standards for new and altered equipment, and otherrequirements specific to the Remedial Alternativeselected.
• New Jersey Interim Groundwater Cleanup Guidance(April 1987)
Volatile Organic Toxic Pollutants as defined inNJAC 7:14 A-l.l et sea.. Appendix B, can be reasonablydivided into two classes: (A) carcinogens and (B) non-carcinogens. Corrective action criteria is provided inthis guidance and must be considered for remedialalternatives regarding groundwater.
• New Jersey Summary of Approaches to Soil Cleanup Levels
NJDEP has investigated many possible approaches toestablishing cleanup objectives for contaminated soil.This summary of approaches will be considered forremedial alternatives that involve the cleanup ofcontaminated soils.
O**O
-32-
040U
4.0 TASK PLAN FOR REMEDIAL INVESTIGATION/FEASIBILITY STUDY
This section is divided into two subsections. Subsection 4.1provides a list of all of the tasks under the REM/FIT ContractNo. 68-01-6699 and the status of each task. Tasks 1-19 havebeen completed. Subsection 4.2 provides a list of the standardtasks required by OSWER Directive 9242.3-7. These are thestandard tasks that will be followed for conducting the RI/FSwork by REM III under Contract No. 68-01-7250.
4.1 STATUS OF REM/FIT TASKS
This section provides a brief status of the tasks that wereperformed for the Ewan Property Site under the REM/FIT contract.All field activities that were performed will be detailed in theRI Report; only a brief overview is provided in this Work Plan.
4.1.1 Task 1 - Remedial Investigation/FeasibilityStudy Work Plan Memorandum Preparation
REM/FIT prepared a Work Plan Memorandum, which provided a scopeof work, a schedule of deliverables, an estimate of labor hours,and a proposed budget, as required for the preparation of theRI/FS Work Plan and other initial activities. No additionalactivity is required for this task.
4.1.2 Task 2 - Project Management
The REM/FIT Project Manager provided technical and adminis-trative coordination for all aspects of the Ewan Property Siteunder this task. Project management activities will continuethroughout the REM III project; however, costs will be chargedto the task for which project management is being provided.
4.1.3 Task 3 - Collection and Evaluationof Existing Information
The data/literature collected for preparation of the REM/FITWork Plan included the following:
• EPA Region II - Emergency and Remedial Response Division(New York) files
• EPA Region II - Emergency and Remedial Response Division(Edison) files
• NJDEP - Hazardous Site Mitigation Administration (HSMA)files
• NJDEP - Division of Water Resources files
• Burlington County Health. Department files
• NUS Region II Field Investigation Team (FIT) filesO
-33-
[[
No additional data/literature searches are planned by REM III.
4.1.4 Task 4 - Site Inspection
Prior to the beginning of onsite activities, a REM/FITinvestigative team conducted a reconnaissance. An additionalsite inspection visit is planned by REM III. This visit willoccur under REM III Task 1 (see Section 4.2.1).
4.1.5 Task 5 - Preliminary Remedial Measures Screening
Based upon evaluation of available site data, a preliminary listof potential remedial measures was developed by the REM/FITcontractor.
This list was developed to help identify data that needed to becollected during the RI so that the remedial measures could besufficiently evaluated during the FS. Additional remedialmeasures screening will be performed by REM III under revisedTask 9 (Section 4.2.9). A brief discussion of remedial measuresis included in this Work Plan, Section 3.2.
4.1.6 Task 6 - Pre-Work Plan Review Meeting
For the REM/FIT contract/ a Pre-Work Plan review meeting washeld with representatives of the EPA and the NJDEP. The purposeof the meeting was to review the existing site information, topresent and discuss a preliminary scope of work for the RI/FS,and to agree on a general scope of work for the RI/FS. Apre-Work Plan meeting was conducted by REM III under Task 1(Section 4.2.1).
4.1.7 Task 7 - Work Plan Preparation
The REM/FIT Final Work Plan was submitted during April 1986.This REM III Work Plan was prepared under the current workassignment Task 1 (Section 4.2.1).
4.1.8 Task 8 - Permits, Rights of Entry,and Other Authorizations
Based on available tax records and maps, the ownership ofproperties surrounding the Ewan Property Site was identified forpurposes of securing access to work areas. The necessary rightsof entry were identified to the EPA. No additional permits orother authorizations have been planned for the REM IIIactivities.
4.1.9 Task 9 - Subcontract Procurement
Specifications for each subcontracting item were prepared aspart of this task under the REM/FIT contract. Subcontractactivities, if required by REM III, will be tracked on a task bytask basis.
-34-Occ
rirI!ITi:i,
4.1.10 Task 10 - Site-Specific Plans
Prior to all site activities, a health and safety plan wasdeveloped that addressed site conditions as they relate to theparticular task. A Site Operations Plan was also developed toserve as a detailed guide for all activities to be conducted atthe site. The plan incorporated the site-specific health andsafety and quality assurance requirements and included detailedprocedures for sampling various media expected to be found bothon site and off site. At the present time, no additionalsite-specific plans are scoped for the REM III portion of thisstudy.
4.1.11 Task 11 - Topographic Mapping and Grid Surveying
A topographic map of the site and surrounding areas was preparedusing aerial photography. Topographic map preparation wasperformed by a subcontractor to the U.S. Army Corps ofEngineers, St. Louis District. The topographic map includes thesite and sufficient offsite areas to include potentialmonitoring well locations. This area is estimated to be480 acres. Ground control survey activities were performed bythe REM FIT contractor. All information was supplied to theCorps at the end of the REM/FIT contract; the topographic maphas not yet been received. No additional topographic mapping orgrid survey is planned for the REM III activities.
4.1.12 Task 12 - Geophysics Study
The objective of the surface geophysical investigation at theEwan Property Site was to provide an assessment of the potentialhazardous waste disposal in Area B and to determine the possiblelocations of buried drums and the delineation of any potentialcontaminant plumes in Area A. Magnetometer and electromagneticconductivity surveys were completed. The results of this taskwere summarized in the Site Operations Plan and were used toselect future sampling locations. At the present time, noadditional geophysics is planned by REM III.
4.1.13 Task 13 - Soil Gas Screening
Soil gas analysis was used as a screening technique to help1 determine areas of soil and/or groundwater contamination.Analyses were performed in Areas A and B. Comparison of data
', points on each grid allowed the determination of suspected areasof contamination. Data from this task were used to optimize thesoil sampling program. Results of the soil gas screening task
' were summarized in the Site Operation Plan. No additional soil< gas screening is planned by REM III.
4.1.14 Task 14 - Community Relations Support
Community relations support provided under the REM/FIT contractincluded participation in a public meeting and preparation of a
-35-
I{ Community Relations Plan (CRP). Community relations support
will be provided by REM III under Task 2 (4.2.2).
4.1.15 Task 15 - Subsurface Investigation
• The objective of the REM/FIT subsurface investigation was toobtain the data necessary to determine:
[ • Potential sources of groundwater contamination in Area B.
( • The horizontal and vertical extent of the contaminantplume originating in Area A.
• The lithology and stratigraphy of subsurface depositsp within the area of investigation.It
• The direction and rate of groundwater movement.
| • Other hydraulic properties of the Cohansey Sand andKirkwood Formation.
*
The work performed during the subsurface investigation included
• Installation of monitoring wells.T • In-situ hydraulic conductivity testing and water-level! measurement.
• Subsurface soil sampling and geotechnical analysis.
At the present time, no additional subsurface investigation isplanned by REM III.
I 4.1.16 Task 16 - Monitoring Well Sampling
Eighteen monitoring wells were installed during the REM/FIT RIT activities. Two rounds of monitoring well sampling were, performed after all wells had been installed and developed.
Existing NJDEP monitoring wells were sampled along with theRZM/FIT monitoring wells during both rounds of sampling. Thesedata were in addition to the quick-turnaround analyses obtained
1 immediately after development of the individual wells.
Groundwater samples were analyzed for the following parametersi by an EPA/Contract Laboratory Program (CLP) laboratory:
| • HSL volatile organicsi• HSL base/neutral extractable organics
T
• HSL acid extractable organics4
• HSL pesticides/PCBs
• HSL metals (samples filtered)
-36-
IIE
f:
• Chloride, sulfate, fluoride, nitrate, carbonate/bicarbonate, sulfide, conductivity, pH, Eh, TDS
• COD, TOC, BOD5
The following parameters were measured in the field:
• pH• Specific conductance• Temperature
Residential wells previously sampled by the EPA FieldInvestigation Team (FIT) contractor were sampled during theinitial monitoring well sampling round.
No additional monitoring well or residential well sampling isscoped in this Work Plan.
4.1.17 Task 17 - Surface Water and Sediment Sampling
One round of surface water and sediment sampling was performed.Because of the intermittent nature of flow in the stream onsite, site conditions prevented some of the surface watersamples from being obtained. A total of three surface water andseven sediment samples were taken.
Sediment samples were analyzed for all TCL parameters whichinclude:
TCL volatile organicsTCL base/neutral extractable organicsTCL and extractable organicsTCL pesticides/PCBsTCL metals
Surface water samples were analyzed for the TCL parameterspreviously listed plus the following:
• Chloride, sulfate, fluoride, nitrate, carbonate/bicarbonate, sulfide, conductivity, pH, EH, TDS
The following field measurements were also made:
• pH• Specific conductance• Temperature
No additional surface water and sediment sampling is presentlyscoped for the REM III activities.
4.1.18 Task 18 - Soil Sampling
Because of the nature of the drum disposal methods practiced atthe Ewan Property Site (i.e., random trench excavation for drumburial) and the limited analytical data available, an extensive
-37-
f
II
scil sampling program was necessary to attempt to define theextent of contamination for the purpose of evaluating remedialalternatives. The objective of the REM/FIT program was todetermine the levels and extent of migration of contaminantsboth horizontally and vertically in the disposal areas.
To accomplish this, surface and subsurface soil samples weretaken in and around selected disposal areas identified duringthe geophysical survey and/or the soil gas survey. Samplingpoints radiated outward from the disposal areas to determinehorizontal migration of contamination. Samples were collectedat approximately 1-1/2-foot-depth intervals to the water tableto help determine the vertical migration of contaminants. Asurface soil sample was collected at each sampling location.All sampling locations were tied into the grid used forsurveying.
In order to reduce the number of samples analyzed through theCLP, soil samples were screened in the field for TCL organiccompounds known to be on site. All samples were prescreened forvolatile organics using an OVA. Negative prescreened sampleswere screened further using field GC screening analysis. FieldGC screening for volatile organics and base/neutral extractableorganics was performed. Those samples which screened positiveand one third of those which screened negative using the fieldGC were sent to an EPA CLP laboratory for the followinganalyses:
TCL volatile organicsTCL base/neutral extractable organicsTCL acid extractable organicTCL pesticides/PCBsTCL metals
Sampling began on the outer edges of the disposal areas andprogressed toward the center of the areas. This method was usedto allow definition of the outer limits of soil contaminationbefore any samples within the areas were taken.
Samples were collected off site in order to get an indication ofbackground contaminant levels.
A complete description of the strategy of this soil samplingprogram is provided in the Final Site Operations Plan(NUSf 1986). The results will be discussed in the Final RIReport.
No additional soil sampling is presently scoped for the REM IIIactivities.
4.1.19 Task 19 - Test Pit Excavation
A series of sixteen test pits were excavated at the EwanProperty Site. The purpose of the test pits were to determinewhether drums are located below the water table, to verify
-38-
findings of the magnetometer survey, to explore areas ofsuspected bulk waste disposal, to determine if buriedwastes/drums exist in Area B, to obtain soil and groundwatersamples from below buried drums, and to determine the physicalcondition of buried drums. Additional test pits are not scopedfor the REM III portion of this study.
4.1.20 Task 20 - Treatabilitv Studies
Several treatability studies were scoped to provide data for theevaluation of alternatives during the FS. This task was notperformed by the REM/FIT contractor due to the time constraintsimposed by the end of the contract. Treatability studies willbe conducted, if necessary, by REM III under Task 7(Section 4.2.7) .
4.1.21 Task 21 - Remedial Investigation Report Preparation
After completion of the field investigations, all pertinentfield and laboratory data was to be assembled into a detailedreport of the remedial investigation. Due to the expiration ofthe REM/FIT Contract, this task was not initiated. REM III willprepare the RI report. Related tasks include Tasks 5, 6, and 8(Sections 4.2.5, 4.2.6, and 4.2.8).
4.1.22 Task 22 - Feasibility Study
From data collected during the remedial investigation, theextent of contamination was to be assessed and potentialremedial actions identified. A feasibility study was to havebeen conducted to evaluate viable remedial action alternativesand to generate a Feasibility Study (FS) Report. This task wasnot initiated by REM/FIT. REM III will conduct the FS. Relatedtasks include Tasks 9, 10, and 11 (Sections 4.2.9, 4.2.10,and 4.2.11).
4.2 REM III TASK PLAN FOR THE RI/FS
The tasks for the Ewan Property Site have been adjusted tocorrespond to the twelve tasks described in the EPA Guidance forRI/FS Tasks for REM Contractors dated November 13, 1986 (OSWERDirective 9242.3-7) .
The following tasks are considered to be parts of the RI:
Task 1 - Project PlanningTask 2 - Community RelationsTask 3 - Field Investigation (completed)Task 4 - Sample Analysis/Validation (completed)Task 5 - Data EvaluationTask 6 - Risk AssessmentTask 7 - Treatability Study/Pilot TestingTask 8 - Remedial Investigation Reports
-39-
ff
r
The remaining tasks are considered to be parts of the FS:
• Task 9 - Remedial Alternatives Screening• Task 10 - Remedial Alternatives Evaluation• Task 11 - Feasibility Study Reports• Task 12 - Post RI/FS Support
Other guidance and directives are also referenced whenconducting an RI/FS. These include, but are not limited to,Guidance on Remedial Investigations Under CERCLA (1985),Guidance on Feasibility Studies under CERCLA (1985), DataQuality Objectives (1987) and RI/FS Improvement Analysis (1987).
This following subsections describe in detail the ten taskscomprising the balance of activities required by the REM IIITeam to complete the RI/FS.
4.2.1 Task 1 - Project Planning
The project planning task is composed of various subtasks; akick-off meeting, a site visit, preparation of this Work Plan,and the preparation of the Field Operations Plan associated withthe treatability study.
On April 13, 1987, a kick-off meeting was held at the EPA officein New York.
On June 4, 1987, a site visit was conducted at the EwanProperty Site to familiarize the project team with the sitelayout. The general information gathered during this siteinspection is vital to the team's understanding of the situationat the site. This firsthand understanding will enhance thequality of the project deliverables.
The preparation of the Draft Work Plan and this Final Work Planis included under this task. The Work Plan presents theapproach to completing the study at the Ewan Property Site.
A Field Operations Plan (FOP) associated with any treatabilitystudy field activities that are to be performed will be preparedunder this task. This FOP will be comprised of a SiteManagement Plan, Field Sampling and Analysis Plan, and a Healthand Safety Plan. A treatability study Scope of Work will beprepared under Task 7.
4.2.2 Task 2 - Community Relations
REM III community relations staff will assist EPA Region II inimplementing the community relations plan previously developedfor this site. This assistance will be provided as specificallyrequested by EPA and is expected to include the following:
• Providing planning, coordination, logistical support, andattending the public meeting for this Work Plan (ifrequested by the EPA).
-40-
• Preparing a public meeting summary for and attending thepublic meeting associated with the FS.
• Preparing two updates during the RI/FS.
• Updating the mailing list for this site.
• Conducting REM III administrative tasks necessary forproviding community relations assistance at this site(e.g., attending EPA meetings and preparing monthlyreports and budget updates for EPA).
Thus far, no public meetings have been held under the REM IIIcontract. As indicated above, two meetings have been budgeted;they will be held when requested by the EPA.
4.2.3 Task 3 - Field Investigation
The REM/FIT field investigation was completed. No additionalfield investigation activities have been scoped, at the presenttime, for this project.
4.2.4 Task 4 - Sample Analysis/Validation
The sample analysis/validation activities task for the RI/FSstudy were completed. Any analytical results that are generatedby the treatability study or by any additional sampling effortsmay need to be validated. Validation will be performed by EPAESD. Validation support is also available through the REM IIITeam.
4.2.5 Task 5 - Data Evaluation
The purposes of data evaluation are to assure that analyticaldata are accurate and consistent with project objectives. Thistask also involves reviewing all of the available analyticaldata, including that obtained during previous investigations(NJDEP, TAT, etc.).
All analytical data that had been obtained by NUS during thefield investigation in 1986 has been tabulated and placed into acomputer data base for ease of manipulation. Anomalies withinthe analytical data will be identified and explained. Theseresults have been correlated with sample locations and media topresent data summaries for evaluating site conditions.Summaries include site maps with contaminants by media,groundwater contour maps (plume identification), geologiccross-section, and a fate/transport model.
This data evaluation has been performed by the REM III Team.Presently the results are in draft form. The final results ofthis evaluation will be included in the RI Report.
OlU
-41-
I[[
4.2.6 Task 6 - Risk Assessment
Using the information generated by the field investigation andcompiled in Task 5/ a draft risk assessment has been performed
V—-- to identify the threats to public health or the environment that• may be posed by the Ewan Property Site. The risk assessment is
presently in draft form. The ultimate results of thisf assessment will be presented in the RI Report.
After the data was evaluated and the data base established, apreliminary baseline Public Health Evaluation (PHE) wasperformed. The purpose of this PHE is to develop a well-documented, qualitative, and, if possible, quantitativecharacterization of the risk associated with human exposure tohazardous constituents present in various media at andassociated with the site.
Subtask 6.1 - Characterization of Potential Exposure Pathways
The first subtask in the Public Health Evaluation is thecharacterization of potential exposure pathways. Potentialexposure points and population and environmental resources atrisk of exposure have been identified, and "complete" exposurepathways have been identified.
i Subtask 6.2 - Toxicological Exposure/Risk Characterization
[ The concentrations of the contaminants in environmental media atthe exposure points were then estimated from the monitoring
, _ data, using environmental site and transport models asj~^ appropriate. Physical/Chemical characteristics, such as soilI mobility, solubility, and adsorption, were evaluated. The
estimated concentrations were then compared to ARARs andcriteria.
For chemicals for which no applicable or relevant standardsexist, acceptable daily intakes (for noncarcinogens) andon target risk levels (for carcinogens) were developed. Theprimary sources of toxicologic data used in this analysis wereAppendix C of the Superfund Risk Assessment Manual, EPA's HealthEffects Analyses (HEAs), and EPA Water and Air Quality Criteria
j Documents. As the toxicological exposure/risk characterization' is presently in the draft stage, target risk levels for
carcinogens will ultimately be determined after consultationT with USEPA and New Jersey Department of Environmental Protection1 (NJDEP); USEPA and NJDEP will also be consulted if it is felt
that there are good technical reasons for selecting toxicityvalues other than those found in the references cited above.
4.2.7 Task 7 - Treatability Study/Pilot Testing
The analytical and site data obtained during all fieldactivities will be evaluated to determine the necessity fortreatability studies and pilot testing. REM III will makerecommendations for such tests in a memorandum to the EPA. EPA
c:-42-
TIfr
Region II and NJDEP will be consulted to determine iftreatability studies will be performed, and, if so, whichstudies. The nature of onsite contamination was determined inTask 5 where the evaluation of analytical results on samplesobtained during the field investigations was performed. Apreliminary assessment of the environmental and health riskspresent at the site was determined in Task 6 and is based uponthe distribution/mobility of the contaminants, likely exposureroutes, and potential receptors.
After the above activities have been completed and potentialremedial technologies have been identified to reduce the riskspresent at the site, the identified technologies will bepreliminarily screened to determine those technologies thatmight be part of the final remedial action for the site. Thiswill occur under Task 9. Based upon this initial screening,treatability studies/pilot testing will be proposed for thosetechnologies that are highly dependent on the waste stream.These tests will determine the suitability of the technologiesand, in addition, obtain operational data to evaluate thetechnology during the feasibility study.
If treatability studies are performed, samples of the onsitewastes and contaminated media will be required and aspecification for the work will be developed. The requirementfor treatability studies will entail remobilizing field samplingpersonnel and possibly obtaining subcontractor services toperform the treatability studies, if they cannot be performed bythe REM III Team or through the CLP.
A limited FOP will be generated as a guideline for the fieldsampling personnel. This FOP will be prepared under the ProjectPlanning task (Task 1).
Treatability study specifications will be prepared. Thisdocument will define the objectives and provide, at the minimum,an outline of and schedule for the activities, the minimum QA/QCrequirements, the analytical procedures required to confirm theresults, and reporting requirements. Cost estimates will bedeveloped but not included in the specification.
Following the conclusion of the treatability studies, a reportexplaining the results will be issued and may be included as anaddendum to the RI Report.
4.2.8 Task 8 - Remedial Investigation Report
A Draft RI Report was prepared as described below to summarizethe data collected and conclusions drawn during the remedialinvestigation process.
Section 1.0, Introduction, will address four major areas:(1) Site Background Information; (2) The Nature and Extent ofContamination Problems at the Site; (3) Investigation ObjectivesContamination and Activities; and (4) An Overview of the
-43-
Report's Contents. The introduction to the Draft RI Report was >prepared according to Section 9.2.2 of the EPA RI Guidance(USEPA, 1985).
Section 2.0, Site Features Investigation, was prepared accordingto Section 9.2.3 of the EPA RI guidance. It presents sitefeature data on demography, land use, natural resources,climatology, and water resources.
Section 3.0, Hazardous Substances Investigation, was preparedaccording to Section 9.2.4 of the EPA RI Guidance. This sectionaddresses waste quantities, location, components, containment,composition, and summarizes the results of the investigations ofwaste component characteristics.
Section 4.0, Hydrogeologic Investigation, was prepared inaccordance with Section 9.2.5 of the EPA RI Guidance. Thissection includes discussions on soils, geology, and groundwater.Additional sections were included to present hydrogeologic andcontamination problems at the site. A technical summary wasalso included to conclude the section.
Section 5.0, Surface Water Investigation, was prepared accordingto Section 9.2.6 of the EPA RI Guidance. This section includesdiscussions on surface water bodies, sediments, flood potential,and drainage.
Section 6.0, Air Investigation, was prepared in accordance withSection 9.2.7 of the EPA RI Guidance. A technical summary willbe included in the Final RI Report.
Section 7.0, Bench and Pilot Tests, will be prepared accordingto Section 9.2.9 of the EPA RI Guidance. As no treatabilitytests have been performed to date, the results of thetreatability studies/pilot tests that are planned under thisphase of activities will be presented as an addendum to theFinal RI Report.
Section 8.0, Potential Health and Environmental Concerns, wasprepared according to Section 9.2.10 of the EPA RI Guidance.Potential receptors were identified, public health andenvironmental impacts were discussed, and the results of therisk assessment and environmental assessments were presented inthe subsection on considerations for remedial alternatives.This subtask also includes the preparation of an appendix topresent the details of the risk assessment pathway analysis,models and computer output, and sediments.
A Draft RI report was issued to the EPA Region II onAugust 21, 1987.
A draft Final RI Report will be prepared to incorporate EPARegion II, NJDEP, and U.S. Corps of Engineers comments to theDraft RI Report. An addendum to the draft Final RI report will ^
•UH*00
-44-
be prepared to include the results of the treatability studies.Once this is completed the report will be considered final.
4.2.9 Task 9 - Remedial Alternatives Screening
This step in the RI/FS process is conducted following the datavalidation, reduction, and evaluation effort (Tasks 4 and 5) andafter risk assessment (Task 6) efforts have been initiated. Theobjective of this task is to refine the range of responseactions developed during the scoping process. This task willemploy the data collected during the site investigation and theresults of the risk assessment (Task 6). The subtaskscomprising Task 9 will accomplish the following objectives:
F • Development of remedial response objectives and. general" response actions.
f[
i:
i:IT
response actions.
• Identification of applicable technologies and assembly ofalternatives.
• Scoping of applicable TS activities.
• Screening of remedial technologies/alternatives.
• Scoping of the Phase II field investigation, if required.
The screening of remedial alternatives will be partiallycompleted prior to scoping the Phase II field investigation, ifneeded. In this way, data needed to complete the development ofremedial alternatives can be collected during Phase II if datagaps exist.
4.2.9.1 Development of Remedial Response Objectivesand Response Actions
Based on the data collected in the RI, the remedial responseobjectives will be developed more fully. Prior to thedevelopment of these objectives, significant site problems and
. contaminant pathways and ARARs will be identified during the RIReport preparation process. Considering these problems and
, pathways, the remedial response objectives will be developedj which address the substantial risks to public health and the* environment and the ARARs with consideration given to
site-specific conditions. Based on the response objectives,J general response actions will be delineated to address each of1 the site problem areas. These response actions will form the
foundation for the technology screening.
[ During the development of remedial response objectives andresponse actions, a project review meeting will be held with EPAto scope the FS approach, in detail, considering the data
! developed during the RI.
lUH*C£
-45-
fI
4.2.9.2 Identification of Applicable Technologiesand Development of Alternatives
Based on the remedial response objectives and general responseactions, a list of applicable technologies will be identified.During the identification of these technologies, the need forsource control measures will be assessed. If needed,technologies which will achieve these source control measureswill be identified in addition to technologies necessary for themanagement of migration from the site.
After potential remedial technologies have been chosen, operableunits will be defined for each site condition requiringremediation. Each operable unit should meet at least oneresponse objective. After these operable units have beencompiled, any appropriate phasing of them will be considered.Depending on site conditions and the adequacy of RI results, aphased approach may be desirable.
Operable units are being considered for this site. Operableunit One would be for source materials, including contaminatedsoils and drums. Operable unit Two would be for groundwaterremediation.
After operable units have been further defined, remedialalternatives will be identified. Each remedial alternative willbe an overall site remedy. The no-action alternative will beconsidered as a baseline against which the other alternativescan be evaluated. Alternatives which can be classified in eachof the classes of alternatives required by the NCP will beidentified to the extent possible.
CERCLA, as amended by SARA, states that, to the maximum extentpracticable, remedial actions that utilize permanent solutionsand alternative treatment technologies or resource recoverytechnologies must be selected. Therefore, remedial actions thatuse these technologies will be considered. In accordance withboth CERCLA, as amended by SARA, and the NCP, alternativesdeveloped will include, but not be limited to, treatment,containment, and no-action technologies. To the extentpossible, treatment options will range from alternatives thateliminate the need for long-term management at the site toalternatives involving treatment that would reduce toxicity,mobility, and volume as a principal goal.
4.2.9.3 Scoping of Applicable Treatability Study Activities
As the need arises, treatability study activities will bescoped. This will be performed under Task 7.
4.2.9.4 Screening of Remedial Technologies/Alternatives
The technologies and alternatives discussed previously will bescreened. The objective of this effort is to eliminate fromfurther consideration any technologies and alternatives that
-46-
f
[[
have undesirable results regarding costs, implementability, andeffectiveness. The list of alternatives being considered willbe narrowed by eliminating the following:
• Alternatives/technologies which are not implementable orare technically inapplicable.
• Alternatives/technologies which are not effective becausethey have adverse environmental impacts, do not provideadequate protection of public health, or will not attainARARs.
• Alternatives/technologies which are more costly thanr other alternatives/technologies but do not provide
greater environmental or public health benefits,' reliability, or a more permanent solution. Costs will
not be used to discriminate among treatment technologiesand nontreatment technologies.
Reasons for elimination of any alternatives at this stage willbe documented in the FS report. A meeting with EPA will be heldfollowing the screening of remedial technologies/alternatives topresent the results of the screening and obtain input from EPA
r before proceeding with the remedial alternatives evaluation.
4.2.9.5 Scoping of Remedial Investigation Phase IITechnical Direction Memorandum (if needed)
i The scope of this effort, if required, will be determined by thes^, outcome of Tasks 3 through 6 and the results of the screening of""" alternatives. This phase, if necessary, will consist ofj additional work to address data gaps identified in Phase I. If
it is determined that a Phase II site investigation or, laboratory/bench scale studies are required, a technical' direction memorandum (TDM) will be prepared. The TDM will be
used to document completion of the first phase of the RI andwill provide a mechanism for changing the authorized ceilingwith respect to the obligated funding level for the workassignment (if necessary). Accompanying the TDM will be arevision to the Work Plan documenting the scoping, scheduling,
i and budgeting requirements of the proposed subsequent phase. Atthe present time, no Phase II activities are planned.
4.2.10 Task 10 - Remedial Alternatives Evaluation
' Remedial alternatives which pass the initial screening process(see Task 9) will be further evaluated and compared as requiredin the NCP and in CERCLA as amended by SARA. As in the initial
, screening process, effectiveness, implementability, and costwill be considered. As part of the effectiveness evaluation,several factors, including protectiveness, technicalreliability, and attainment of ARARs reduction of toxicity,mobility, or volume will be considered. As part of thisevaluation process, SARA Subsection 121(b)(l) requires thatwaste, site, and inherent limitations, as well as the ability of
-47-
([
each alternative to meet ARARs be taken into account. Factorsthat should receive special consideration include:
• The long-term uncertainties of land disposal.
• The goals and requirements of the Solid Waste DisposalAct.
• The persistence, toxicity, mobility, and bioaccumulationof contaminants at the site.
• The short- and long-term potential for adverse humanhealth effects.
• The long-term maintenance costs.
• The potential for future remedial action costs if theremedy fails.
• The potential threat to human health and the environmentfrom the excavation, transportation, and redisposal orcontainment of hazardous substances, pollutants, orcontaminants.
Both short- and long-term effects for each of these factors willbe assessed. To the extent possible, remedial alternatives thatuse permanent solutions and alternative treatment technologiesor resource recovery technologies will be considered.
During Task 10, two project review meetings will be scheduledwith EPA to present the work to date and solicit input on theremedial alternatives evaluation.
Implementability Evaluation
Each alternative will be evaluated for technical feasibility,administrative feasibility, and availability of the technology.Performance will be evaluated in terms of efficiency and usefullife. Feasibility will be evaluated based on operation andmaintenance requirements and on the demonstrated performance ofthe remedial technologies involved. However, innovativetreatment technologies or technologies achieving permanentsolutions will not be eliminated because they have not beenproven. During the analysis of technical feasibility,conditions onsite and external to the site will be considered.An estimate of the time required to implement the alternative aswell as the time required to achieve beneficial results will beanalyzed. Safety evaluations will include both the short-termand long-term threats to the safety of nearby communities andenvironments and of workers onsite. To the extent possible,special consideration will be given to technologies that providetreatment, resource recovery, or permanent solutions. Thelong-term uncertainties will be carefully considered.
-48-
ri
r
Effectiveness Evaluation
Public Health Evaluation - A baseline PHE will be conducted aspart of Task 6 - Risk Assessment. This baseline assessment,which is an evaluation of the site without further remedialaction, is also a detailed evaluation of the no-actionalternative. The remaining alternatives must be evaluated in atwo-step process. The first step is the development of targetchemical concentrations. These target concentrations arenumerical criteria which are used to judge conformance withARARs which do not define specific levels. The targetconcentrations or action levels help to define design goals forthe remedial action and are used as points of comparison to the
, baseline evaluation. The second step of evaluation is the: assessment and comparison of the short- and long-term risks to1 public health and the environment caused by implementation of
each alternative. In this step, the degree to which eachalternative meets ARARs will be assessed. Steps similar tothose discussed for the baseline will be used in theseevaluations. In the selection of target chemicalconcentrations, these steps will include selection of indicatorchemicals, identification of exposure pathways, and thenselection of the target concentrations. Selection of target
T concentrations will be based on ARARs if they are available, or; calculated using toxicity and chemical intake data developed
during the baseline assessment. These target chemicalconcentrations, in conjunction with environmental fate and
• transport models, will then be used to back calculated allowableJ release rates of chemicals at exposure points and action levels
for removal or control. If offsite land disposal or containment^ is considered, the potential threat to human health and the
environment from the excavation, transportation, and redisposalor containment of hazardous contaminants will be assessed.
I Environmental Assessment
The environmental evaluation will focus on the site problems andpathways of contamination actually addressed by the alternative.This assessment will determine to what degree the alternativewill protect and improve the environment. Adverse environmental
. impacts of implementation of the alternatives will be fullyj described. Known environmental problems not addressed by the; alternative will be described.
; The level of detail in the environmental assessments will dependon the degree of actual or potential damage to the environmentbeing evaluated. A detailed assessment will be performed forthe no-action alternative. This assessment will identify theextent of currently or potentially contaminated areas, identifypossible environmental impacts, and evaluate the significance ofsuch impacts. Other alternatives will be assessed in detail ifadverse effects on the environment are expected to occur as aresult of the response action. Because wetlands areenvironmentally sensitive areas, a wetlands and floodplain ^assessment will also be performed, and responses which have ^
CC-49-
T{
[[r
potential to impact the wetland systems will be evaluated. The *effects of alternatives on the wetlands will be described interms of the habitat values developed.
Attainment of ARARs
ARARs must be considered during the detailed evaluation ofalternatives. Prior to the ARAR conformance evaluation, site-specific and alternative-specific ARARs will have been defined.For site-specific ARAR evaluation, action levels developed willbe set to provide specific numerical criteria if possible.During the detailed analysis step, each alternative must beevaluated on the extent to which it attains or exceeds ARARs.Special considerations will be given to the goals andrequirements of the Solid Waste Disposal Act.
In addition to an analysis of compliance with ARARs,coordination with other affected Federal and state agencies willbe implemented as required for specific alternatives.
Cost Evaluation
A detailed cost analysis will be performed for each alternativeand will consist of the following steps:
• Estimate capital and operation and maintenance costs(including long-term maintenance costs).
• Calculate annual costs and present worth.
• Evaluate the sensitivity of cost estimates to changes inkey parameters such as discount rates, design, oreffective life.
• Estimate 5-year evaluation costs.
• Assess the potential for future remedial action costs ifthe remedy fails (replacement costs).
For each alternative the cost will be estimated within a rangeof -30 percent to +50 percent. The cost analysis will includeseparate evaluation of capital and operation and maintenancecosts. Capital costs will consist of short-term installationcosts such as engineering/design fees, materials and equipment,construction, and offsite treatment or disposal. Operation andmaintenance costs will consist of long-term costs associatedwith operating and monitoring the remedial actions such as agroundwater extraction and treatment plant or groundwatermonitoring programs. Capital and annual operation andmaintenance costs will be based on the anticipated timenecessary for the alternative to achieve cleanup criteria.
A discount rate of 10 percent will be assumed for all presentworth calculations. Cost estimates will be prepared using data ^from project files, the current EPA Remedial Action Costing ^
rolU
-50-
Procedures Manual, USEPA technical reports, and quotations fromequipment vendors. Equipment replacement costs will be includedwhen the required performance period exceeds equipment designlife.
4.2.11 Task 11 - Feasibility Study Reports
At the present time it is planned that an FS Report will begenerated for Operable Unit One - source remediation and forOperable Unit Two - groundwater remediation. This approach willexpedite the removal of the source materials from the site.Once the FS for Operable Unit One is complete the FS addressinggroundwater remediation will be prepared.
Task 11 will consist of the following subtasks:
• Summarize each alternative in terms of effectivenessimplementability, and cost.
• Compare the remedial alternatives.
• Prepare the FS Reports.
Each FS Report will include an executive summary, anintroduction, and a description of the screening and evaluationprocess. Each FS Report will be presented in the formatpresented in the EPA FS Guidance. Each FS Report will include asummary of the detailed technical and cost evaluations and acomparative evaluation of the remedial alternatives. Thissummary will be presented as table matrices. Backup informationand calculations will be included as appendices.
The results of any treatability study that is performed willalso be included in the FS report. Because of the scheduleneeds for completing the treatability study (TS) task, completeincorporation of the results into the Draft FS Report may not bepossible. If this is the case, the results would subsequentlybe incorporated into the FS that is presented to the public.
If Task 12 is requested as a component of the RI/FS, the finalFS report will include a responsiveness summary and the selectedremedy.
To inform the EPA of progress and results, Technical Memorandawill be issued at the following points during the FS:
• Completion of development of remedial responseobjectives.
• Completion of development of alternatives.
• Completion of initial screening of alternatives.
O
ro
-51-
Two project review meetings are scheduled with EPA duringTask 11; one to present the proposed format of the FS Report,and another to discuss EPA comments on the draft FS Report.
4.2.12 Task 12 - Post RI/FS Support
NUS will provide support to EPA for requested assistance inactivities which occur after the Ewan RI/FS is completed. Thescope and budget estimated for this effort will be preparedfollowing meetings with EPA after the RI/FS Report is approvedand follow-up actions are identified. Such support couldinclude community relations and assistance to theU.S. Army Corps of Engineers or other parties involved in theremedial design/remedial action. REM III community relationsstaff will prepare a responsiveness summary for the publiccomment period on the FS. The responsiveness summary willprovide a record for EPA of all issues identified during thepublic comment period on the FS Report.
Ort*10
-52- «
T t
J
J
j
[f
5.0 PROJECT MANAGEMENT APPROACH
The following subsections present the project organization,quality assurance and data management requirements and projectschedule for the Ewan Property Site.
5.1 ORGANIZATION AND APPROVAL
The proposed project organization for the Ewan Property Site isshown on Figure 5-1. The Regional Manager (RM),Dr. Dev Sachdev, is responsible for the quality of all REM IIIwork performed in Region II. He monitors the progress of eachwork assignment to ensure adequate resources are available andthat major problems are prevented or minimized. Dr. Sachdevimplements the program standard of quality for work in theregion and makes sure that the Site Manager (SM) meets thatstandard. The RM's review of deliverables concentrates ontechnical quality, schedule, and cost for all work assignments.
The SM, Ms. Debra M. Wroblewski, has primary responsibility andauthority for implementing and executing the RI/FS. She willprovide day-to-day direction of the project and perform specifictechnical activities and will be assisted by key members of thetechnical staff. Support will be obtained from other members ofthe REM III staff that are familiar with the site, on anas-needed basis.
5.2 QUALITY ASSURANCE AND DATA MANAGEMENT
The site-specific quality assurance requirements will be inaccordance with the Quality Assurance Project Plan (QAPP) forthe REM III program. The REM III QAPP provides general guidanceon the following subjects:
• Project organization and responsibility.
• QA objectives for measurement data in terms of precision,accuracy, completeness, representativeness, andcomparability.
Data management aspects of the program pertain to controllingand filing documents. REM III has developed a program filingsystem (Administrative Guideline Number PA-5) that conforms tothe requirements of the EPA to ensure that the integrity of thedocuments is safeguarded. This guideline will be implemented tocontrol and file all documents associated with the Ewan PropertySite. The system includes document receipt control procedures,a file review and inspection system, and security measures to befollowed.
5.3 PROJECT SCHEDULE
The project schedule illustrated in Figure 5-2 shows the tasksand activities for the Ewan Property Site. This scheduleassumes that no additional field activities will be required. ^
rooc-53-
[
C
EPARPO
M S ALVI
REM IIIREGIONAL MANAGER
D SACHDEV
NJDEPSITE MANAGER
M BORLINGAME
EPARPM
C OeBIASE
RI/PS TEAM
CIVILENGINEERING:
P ALESSIO
CHEMISTRY/TOXICOLOGY:
H ROPPMANA HUBBARD
GEOLOGY:
R BETHEL
REM III SITEMANAGER
D WROBLEWSKI
COMMUNITYRELATIONS
S CONWAY
PIGURE 5-1PROJECT ORGANIZATION
EHAN PROPERTY SITE, SBAMONG TOWNSHIP, NEW JERSEY
roCC
-54-
-55-
r
r
This schedule also assumes that the Operable Unit approach willbe taken. An adjustment to project approach that does notrequire an increase in budget can be addressed in a technicaldirection memorandum. This memorandum, if necessary, will beprepared by the REM III Team at the request of the EPARegion II. EPA approval of such a memorandum must be obtainedprior to adjusting the direction of the project.
The schedule included in this Work Plan presents projectdeliverables, task milestones, tentative meeting dates, agencyreview, and task interdependencies.
O
-56-
REFER
ENC
ES
0432
[[II
REFERENCES
Andres, Kari, 1983, Memo on Electromagnetic Conductivity Survey/NJDEP, Trenton, NJ.
Buttich, J., 1983. Chain of Custody - NJDEP Sample AnalysisSheets, Sample Nos. 00251, 00252, 00254, 00256, 00258, 00260,NJDEP, Trenton, NJ.
Diamond Drilling Co., Inc., 1983. Boring logs. Permits31-20636-1, 31-20637-9, 31-20638-7, 31-20639-5, and 31-20640-9,Job No. 8297 for NJDEP, Trenton, NJ.
Farlekas, Nemickas, and Gill, 1976. U.S. Geological Survey WaterResources Investigations. NJDEP, Division of Water Resources,Trenton, NJ.
NUS Corporation, 1986. Final Site Operations Plan. R-33-5-6-6,USEPA, Washington, D.C.
NUS FIT Office (Werbin, D.), 1984. Site Inspection Report. TDDI No. 02-8403-111A, USEPA, Washington, D.C.
OWSER Directive 9242.3-7, 1986, EPA Guidance for RI/FS tasks forj REM Contractors, Washington, D.C.i
Rhodehamel B.C., 1973. Geology and Water Resources of theN«--/ Wharter Tract and the Mullica River Basin in Southern NewI Jersey, NJDEP, Special Report No. 36.
Sadat, P.E., Dr. Marwan M., 1983. Hazard Ranking System Report.• NJDEP, Trenton, NJ.i>
U.S. EPA, 1985. Guidance on Remedial Investigations UnderCERCLA. EPA/540/G-85/002, OSWER, Washington, D.C.
U.S. EPA, 1985, Guidance on Feasibility Studies Under CERCLA,, EPA/540/G-85/003, Washington, D.C.
' U.S. EPA, 1987, Data Quality Objectives for Remedial ResponseActivities, EPA 540/G-87/003A, OSWER Directive 9335.0-7B,
j Washington, D.C.i
U.S. EPA, 1987, RI/FS Improvement Analysis, OSWER Directive; 9355.0-20, Washington, D.C..
Weiss, George, 1983. Ewan Property, Shamonq Township - ChemicalSampling, letter, NJDEP, Trenton, NJ.
Weston/SPER Division, not dated. Preliminary FieldInvestigations at Ewan Property pump Site. Report, EPA TATContract, Edison, NJ. ^
^ **CO
-57- «
Zachowski, M., 1983. Chain of Custody - NJDEP Sample AnalysisSheets. Sample Nos. ES-1, ES-2, ES-3, and ES-4, NJDEP, Trenton,NJ.
Zachowski, M., 1984, OVA Survey, Ewan Property, ShamongTownship, letter, NJDEP, Trenton, NJ.
CO-58-
ff
fnr
fl
0
I!
GLOSSARY OF ABBREVIATIONS
*~^ ARAR Applicable or Relevant and Appropriate Requirements,the set of regulatory requirements that must be
[ considered in determining the extent of remedy ("howclean is clean") and risk assessments.
CERCLA Comprehensive Environmental Response, Compensation,and Liability Act of 1980, the Superfund statute.
CLP Contract Laboratory Program, run by the HazardousResponse Support Division (a unit of OERR).
CRP Community Relations Plan.
CWA Clean Water Act, also known as the Federal WaterPollution Control Act (FWPCA).
DQO Data Quality Objectives, the guidelines governinglaboratory analytical protocols used for RI data.
[I EPA U.S. Environmental Protection Agency.i
EPIC Environmental Photographic Interpretation Center, then EPA ORD unit performing research on aerial photography(• and remote sensing with many applications at hazardous
waste sites.
I t ERA Expedited Response Action, an immediate, quick,4 limited remedy without a full RI/FS.
ESD Environmental Services Division, the regionalorganization responsible for sampling, QA, andregional laboratories.
FIT Field Investigation Team, the contractors who performPreliminary Assessments/Site Inspections. (For thisproject NUS Corporation under the REM/FIT Contract.)
FOP Field Operations Plan, which accompanies the work planand includes the SMP, FSAP, and HSAP.
FS Feasibility Study.
FSAP Field Sampling and Analysis Plan, the part of the FOPdiscussing sampling locations and procedures,analytical protocols and laboratories used, andappropriate QA and data validation procedures.
^i HASP Health and Safety Plan, one of the three parts of theFOP.^ s
01-59-
LOE Level of Effort, the contract category of hours spenton RI/FS and other non-administrative assignments.
MCL Maximum Contaminant Level, the recommended standardfor drinking water contaminants at the tap.
NCP Oil and Hazardous Substances National Contingency Plan(revised November 21, 1985). The blueprint forSuperfund responses.
NPL National Priorities List, the list of sites to beremedied.
OERR Office of Emergency and Remedial Response, responsiblefor Superfund within OSWER.
OSW Office of Solid waste", responsible for RCTA withinOSWER.
OSWER Office of Solid Waste and Emergency Response,responsible for EPA hazardous waste programs.
PARCC Precision, Accuracy, Representativeness, Completeness,and Comparability, the criteria for choosinganalytical protocols for la-boratory samples in the DQOprocess.
RA Risk Assessment, the process of evaluating the publichealth consequences of various FS alternatives.
RCRA Resource Conservation and Recovery Act, the lawgoverning treatment, storage, and disposal ofhazardous waste.
REM III Present contract. NUS Corporation is performing siteactivities as a contractor for Ebasco Services Inc.
REM/FIT Sometimes referred to as REM I. NUS Corporationperformed activities for this project under thiscontract in 1985-1986.
RI Remedial Investigation.
RI/FS Remedial Investigation and Feasibility Study.
ROD Record of Decision, the document summarizing the FSfindings and recommending a design for the siteremedy.
RPM Remedial Project Manager, the EPA site manager.
RPO Regional Project Officer, the EPA manager whosupervises the RPMs and REM contract work in theregion.
-60-
OtffcCOc?
SAS Special Analytic Services, a CLP mechanism to orderquick-turnaround or other non-Standard laboratoryanalysis.
SDWA Safe Drinking Water Act.
SM Site Manager/ the REM contractor responsible for aRI/FS at a site.
SMP Site Management Plant, part of the FOP describingoperations, schedule, and responsibilities.
TAT Technical Assistance Team, the emergency responsecontractors in the regions. (For this project,Weston/SPER Division, was the TAT contractor.)
TDM Technical Direction memorandum, the documentsummarizing changes in scope of work due to newinformation in a phased RI/FS.
Oifc>CO
-61-
JOOCO
oO
