RECORD OF DECISION

Maywood Chemical Company Superfund Site Operable Unit 1

Non-FUSRAP Soil and Source Areas

Boroughs of Maywood & Lodi and Township of Rochelle Park Bergen County, New Jersey

United States Environmental Protection Agency Region 2

New York, New York

September 2014

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DECLARATION STATEMENT

RECORD OF DECISION - OPERABLE UNIT 1 Non-FUSRAP Soil and Source Areas

Maywood Chemical Company Superfund Site

SITE NAME AND LOCATION Maywood Chemical Company Superfund Site Boroughs of Maywood & Lodi and Township of Rochelle Park, Bergen County, New Jersey EPA ID# NJD980529762 Operable Unit 1: Non-FUSRAP Soil and Source Areas STATEMENT OF BASIS AND PURPOSE This decision document presents the Selected Remedy for the Maywood Chemical Company Superfund Site (Site) Operable Unit 1 (OU1), Non-FUSRAP Soil and Source Areas, which was chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 as amended, and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 Code of Federal Regulations (CFR) Part 300. This decision is based on the Administrative Record (AR) file for the Site. The attached index (see Appendix III) identifies the items that comprise the AR, upon which the selection of the remedial action is based. New Jersey Department of Environmental Protection (NJDEP) concurs with the Selected Remedy (see Appendix IV). ASSESSMENT OF THE SITE The response action selected in this Record of Decision (ROD) is necessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances from the Site into the environment. DESCRIPTION OF THE SELECTED REMEDY The remedy described in this document addresses OU1, consisting of chemically-contaminated soil and buried waste at the Site. Three properties, known as Stepan, Sears and DeSaussure, require cleanup. Soil at the Site is contaminated with a variety of chemicals and waste materials, including metals, volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs) from past chemical manufacturing and ore processing activities conducted at the former Maywood Chemical Works. Due to the extent, volume, complexity and nature of contamination at the Site, soil and buried waste at the three properties are further divided into five distinct Areas of Concern (AOCs), referred to as the Buried Container Area, Gypsum Material Area, Leather Materials Area, Former Aromatics Area and Central Tank Farm Area.

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The remedy presented in this OU1 ROD combines the five AOCs into one response action that includes soil excavation with off-site disposal, soil vapor extraction, institutional controls to prevent exposure to and disturbance of residual contamination and site restoration. The Site encompasses 88 properties, including three properties that are being cleaned up as part of this OU1 remedy. The U.S. Army Corps of Engineers (USACE) is implementing remedial actions at the Site with continuing Congressional appropriations under the Formerly Utilized Sites Remedial Action Program (FUSRAP). Parts of the Site are being addressed by USACE through remedies selected in two separate RODs for the Site: a 2003 OU2 ROD for radiologically-contaminated soil and building materials; and a 2012 OU3 ROD for groundwater contamination associated with the 11.7-acre government-owned Maywood Interim Storage Site (MISS). USACE’s FUSRAP cleanup work primarily addresses radiological contamination on the 88 properties, but also addresses chemical contamination where it is co-located with radiological contamination, and at the MISS. A future OU4 ROD will address the non-radiological groundwater contamination associated with the former Maywood Chemical Works operations that is not located on the MISS. The Selected Remedy for OU1 includes the following components:

Excavation and off-site disposal of an estimated 29,100 cubic yards of soil and waste material contaminated with metals, VOCs and SVOCs at an approved off-site disposal facility;

In situ soil vapor extraction and treatment of an estimated 3,220 cubic yards of VOC-contaminated soil; and

The establishment of institutional controls (ICs), such as deed notices, easements or restrictive covenants to: maintain the long-term protectiveness of the remedy; ensure that future use remains commercial/industrial; and prevent future land uses that interfere with the implementation or protectiveness of the Selected Remedy.

Furthermore, as described in the 2003 OU2 ROD, areas of the Sears and DeSaussure properties where occupied buildings are currently situated are known to contain radiologically-contaminated soil that will be addressed under the OU2 remedy, but this soil is currently inaccessible. As this soil becomes accessible in the future (e.g., due to renovation or demolition activities), this OU1 remedy will address any chemically-contaminated soil under the buildings. 

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STATUTORY DETERMINATIONS Part 1: Statutory Requirements The Selected Remedy is protective of human health and the environment, complies with federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment or resource recovery technologies to the maximum extent practicable. Part 2: Statutory Preference for Treatment The Selected Remedy satisfies the statutory preference for treatment as a principal element of the remedy (i.e., reduces toxicity, mobility or volume of hazardous substances, pollutants or contaminants as a principal element through treatment). Part 3: Five-Year Review Requirements The Selected Remedy will result in hazardous substances, pollutants or contaminants remaining at the Maywood Chemical Company Site above levels that would allow for unlimited use and unrestricted exposure. Pursuant to Section 121(c) of CERCLA, a statutory review will be conducted within five years after initiation of the selected remedial action and no less often than once every five years thereafter to assure that human health and the environment are being protected by the Selected Remedy. ROD DATA CERTIFICATION CHECKLIST The ROD contains the remedy selection information listed below. More details may be found in the AR file supporting this ROD.

Contaminants of concern and their respective concentrations are in the “Summary of Site Characteristics” section. Potential adverse effects associated with exposure to Site contaminants may be found in the “Summary of Site Risks” section.

Remediation goals established for contaminants of concern and the basis for these goals are in the "Remedial Action Objectives" section.

A discussion of contamination constituting principal threats is in the "Principal Threat

Wastes" section.

Current and reasonably-anticipated future land use assumptions are in the "Current and Potential Future Site and Resource Uses" section.

Estimated capital, annual operation and maintenance (O&M) and total present worth

costs, discount rate and the number of years over which the remedy cost estimates are projected are in the "Description of Alternatives" section.

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Key factor(s) that led to selecting the remedy (Le., how the Selected Remedy provides the best balance of tradeoffs with respect to the bdancing and modifying criteria, highlighting criteria key to the decision) may be found in the "Comparative Analysis of Alternatives" and "Statutory Determinations" sections.

AUTHORIZING SIGNATURE

Walter E. Mugdan, Director Date Emergency and Remedial Response Division U.S. EPA Region 2

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DECISION SUMMARY

Maywood Chemical Company Superfund Site Operable Unit 1

Non-FUSRAP Soil and Source Areas

Boroughs of Maywood & Lodi and Township of Rochelle Park Bergen County, New Jersey

United States Environmental Protection Agency Region 2

New York, New York

September 2014

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TABLE OF CONTENTS

SITE NAME, LOCATION AND DESCRIPTION ........................................................................ 1 

SITE HISTORY AND ENFORCEMENT ACTIVITIES .............................................................. 1 

HIGHLIGHTS OF COMMUNITY PARTICIPATION ................................................................. 2 

SCOPE AND ROLE OF OPERABLE UNIT 1 REMEDY ............................................................ 3 

SUMMARY OF SITE CHARACTERISTICS ............................................................................... 4 

CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES ............................... 15 

SUMMARY OF SITE RISKS ...................................................................................................... 16 

REMEDIAL ACTION OBJECTIVES ......................................................................................... 18 

REMEDIATION GOALS ............................................................................................................ 19 

DESCRIPTION OF REMEDIAL ALTERNATIVES .................................................................. 20 

COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES FOR EACH AOC ............ 43 

PRINCIPAL THREAT WASTE .................................................................................................. 53 

SELECTED REMEDY ................................................................................................................. 53 

DOCUMENTATION OF SIGNIFICANT CHANGES ............................................................... 59 

    

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APPENDICES APPENDIX I FIGURES APPENDIX II TABLES APPENDIX III ADMINISTRATIVE RECORD INDEX APPENDIX IV STATE LETTER OF CONCURRENCE APPENDIX V RESPONSIVENESS SUMMARY

ATTACHMENTS TO RESPONSIVENESS SUMMARY

A PROPOSED PLAN B PUBLIC NOTICE - COMMENT PERIOD C TRANSCRIPT OF PUBLIC MEETING D PUBLIC COMMENTS

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SITE NAME, LOCATION AND DESCRIPTION The Maywood Chemical Company Site (Site), CERCLIS ID NJD980529762, is located in Maywood, Rochelle Park and Lodi, Bergen County, New Jersey, along the New Jersey State Route 17 corridor (see Figure 1). The Site is located approximately twelve miles northwest of New York City. The Site is surrounded by a heavily urbanized area of industrial, commercial and residential use. Properties, formerly owned by the Maywood Chemical Works, are the subject of the remedial activities described in this ROD for OU1. The Site is on the U.S. Environmental Protection Agency’s (EPA’s) National Priorities List (NPL). EPA is the lead agency and NJDEP is the support agency for OU1. The Site encompasses 88 properties, including three properties that are being cleaned up as part of this OU1 remedy. USACE is implementing remedial actions for OU2 and OU3 at the Site as the lead agency, with EPA and NJDEP support. The OU2 and OU3 work is funded by continuing Congressional appropriations under the Formerly Utilized Sites Remedial Action Program (FUSRAP). The 88 properties and FUSRAP groundwater contamination are being addressed through remedies selected in two separate RODs for the Site: a 2003 OU2 ROD for radiologically-contaminated soil and buildings; and a 2012 OU3 ROD for groundwater contamination associated with the government-owned Maywood Interim Storage Site (MISS). The FUSRAP cleanup work addresses radiological contamination on the 88 properties and radiological and chemical contamination at the 11.7-acre government-owned MISS. EPA is also the lead agency for OU4, a future action to address non-radiological groundwater contamination that is not located on or emanating from the MISS. SITE HISTORY AND ENFORCEMENT ACTIVITIES The Maywood Chemical Works was founded in 1895 and manufactured a wide variety of chemical additives and products with operations located on 63 acres. Initial operations included a "standard essence" operation involving cerium, as well as extraction of protein from leather, production of aroma compounds called ionones, caffeine extraction, and production of lithium tablets. Operations from 1916 to 1955 involved processing radioactive thorium from monazite sands. The process resulted in thorium waste that, while known to be radioactive, was not considered particularly dangerous at that time. Other processing operations generated various types of waste products such as lanthanum, lithium compounds, detergents, alkaloids, essential oils, and products from tea and cocoa leaves. The waste material may have been used as fill in nearby areas (on the 88 properties noted above), and subsequently as fill on adjacent properties in Rochelle Park and on nearby properties in Maywood and Lodi during the construction of Route 17 in the 1930s. The Stepan Company (Stepan) purchased its property in 1959 and began to clean up thorium wastes on the property in 1963. Stepan is currently the owner and operator of a portion of the original Maywood Chemical Works property. Many of Maywood Chemical Works’ operations were discontinued in the 1960s. Stepan currently focuses on the production of specialty chemicals.

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In October 1980, NJDEP investigated a citizen complaint about radioactive contamination at an area near Route 17 in Maywood and Rochelle Park, New Jersey. From 1980 through 1983, radiological surveys and sampling were performed in the area by NJDEP, EPA and U.S. Department of Energy (DOE). These studies revealed extensive radionuclide contamination and were the basis for the Site being included on the NPL in 1983. From 1984 through 1986, DOE, acting under its FUSRAP authority through the 1984 Energy and Water Appropriations Act (PL 98-50) which specifically addressed the Maywood Site, investigated and removed over 35,000 cubic yards of radioactively contaminated soil and debris from nearby properties. This material was stockpiled and secured at the MISS property, owned by the federal government and located on 11.7 acres of Site land acquired from Stepan. In 1986, in conjunction with DOE’s radiological characterization of the “Sears and adjacent” properties (portions of the Site not currently owned or operated by Stepan), EPA performed a preliminary study of chemical, non-radioactive pollutants. EPA’s study indicated the presence of elevated concentrations of VOCs, SVOCs, metals, pesticides and other hazardous substances. In 1987 and 1988, in conjunction with DOE’s studies and investigation, EPA collected samples of soil on the Stepan property itself. The data from that sampling indicated the presence of both radiological and non-radiological contaminants in the soil. Chemical, non-radioactive contamination was found on three properties: (1) the Stepan property; (2) the Sears Logistics Center; and (3) the DeSaussure Equipment Corporation/Maywood Furniture Corporation property. Enforcement Activities In 1987, Stepan entered into an Administrative Order on Consent with EPA to perform a Remedial Investigation and Feasibility Study (RI/FS) on the Sears and adjacent properties, focusing on chemical, non-radiological contamination. In 1989, EPA requested Stepan to expand the scope of the investigation described in the consent order to include an investigation on its own property as well. Stepan declined to do so voluntarily, and in June 1991, Stepan was ordered to perform RI/FS activities on its own property through an EPA Unilateral Administrative Order. Field activities for the expanded chemical investigation on the Sears and adjacent properties and the Stepan property began in late 1991. The RI/FS reports that serve as the basis for this remedy were prepared under these orders. HIGHLIGHTS OF COMMUNITY PARTICIPATION EPA has encouraged and received public involvement throughout the Site’s history. Some of the more notable efforts include the formation and interaction of EPA, DOE and USACE with several community groups formed to help increase communication and facilitate the transfer of technical information for the Site. In 1985, the Concerned Citizens of Maywood (CCM), comprised of local residents, was formed to monitor activities at the Site. In 1988, the CCM was granted official advisory group status from the Maywood mayor and council and provided input and recommendations to the mayor and council on Site activities; the group was awarded a grant

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from EPA to hire a technical advisor to help interpret Site information. In 1997, the Cooperative Guidance Group, a second citizen advisory group, was formed to provide community input to the USACE on cleanup decisions. A third community organization, the Communications Working Group, was established 1998 and also worked to increase communications between the USACE and stakeholders. A Community Relations Plan (CRP) was established in 1995 by DOE, with updates by USACE. The CRP served as a guide for sharing information and obtaining public input on the OU1 remedy selection process. EPA and USACE maintain websites dedicated to the Maywood Chemical Superfund Site cleanup project at http://www.epa.gov/region2/superfund/npl/maywood/ and http://fusrapmaywood.com/index.asp, respectively. EPA’s Proposed Plan for OU1 Non-FUSRAP Soil and Source Areas remedial action was released to the public for comment on August 23, 2013. A copy of the Proposed Plan, risk assessment, RI sampling reports, FS with remedial alternatives and other supporting documents which comprise the AR file were made available to the public in the Site AR repositories maintained at the EPA Region 2 office (290 Broadway, New York, New York) and the Maywood Public Library (459 Maywood Avenue, Maywood, New Jersey). EPA posted the Proposed Plan on the Region 2 website and notices about the release of the Proposed Plan were sent to local stakeholders. A copy of the Proposed Plan can be found in Appendix V, Attachment A. A public notice published in The Record on August 23, 2013 advised the public of the availability of the Proposed Plan and invited interested parties to attend a September 9, 2013, public meeting. (See Appendix V, Attachment B.) This notice also announced the opening of the 30-day public comment period, from August 23, 2013, to September 23, 2013. EPA issued a press release announcing the Proposed Plan’s release to the public, encouraging the public to attend the September 9th public meeting and to comment on EPA’s Proposed Plan. At this meeting, representatives from EPA received comments and answered questions about the Proposed Plan. At Stepan’s request, EPA extended the comment period until December 5, 2013. EPA announced a first extension at the September 9th public meeting and press releases were also issued by EPA to announce the extensions. (See Appendix V, Attachment B.) EPA’s response to the comments received from August 23 to December 5, 2013, is included in the Responsiveness Summary in Appendix V. SCOPE AND ROLE OF OPERABLE UNIT 1 REMEDY The contamination sources and cleanup responsibilities at the Maywood Chemical Company Superfund Site are complex. Site cleanup responsibilities are divided between USACE and the sole identified potentially responsible party (PRP) for the Site, Stepan, based on area and contamination source, as described in the “Site History” section. EPA has organized the project into four phases or operable units (OUs) to make the remedial work more manageable, as follows:

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Operable Unit 1: Non-FUSRAP Soil and Source Areas; Operable Unit 2: FUSRAP Soil and Buildings; Operable Unit 3: FUSRAP Groundwater; and Operable Unit 4: Non-FUSRAP Groundwater. The actions described in this OU1 ROD are for the remediation of chemically-contaminated soil and buried waste at the Site for the protection of human health and the environment at three of the 88 properties that are being addressed as part of the Site. These actions are in addition to, but separate from, those being undertaken by the USACE for addressing radiological contamination on these three properties: of necessity, the OU2 remedy addresses non-radiological contamination where it is co-located with radiological contamination1. Under several administrative orders issued by EPA, Stepan has conducted an investigation of chemical contamination at the Site, excluding the MISS. Remedial activities for chemical contamination described in this OU1 ROD will be addressed in coordination with the ongoing remedial activities being performed by USACE pursuant to the OU2 ROD, as necessary. The OU2 ROD selected an excavation and off-site disposal remedy for radiological contamination at all 88 properties. Soil associated with OU1 containing VOCs, SVOCs, inorganic compounds and buried wastes is being addressed because it may be a potential source of contamination to groundwater or because it exceeds non-residential direct contact standards. Chemically-contaminated groundwater associated with these soil areas will be addressed by a future ROD for OU4 (Non-FUSRAP groundwater). Additional remedial investigation work is being undertaken to characterize the nature and extent of groundwater to be included in the OU4 remedy. This groundwater contamination is separate from the groundwater contamination being addressed by the USACE pursuant to the 2012 OU3 FUSRAP groundwater ROD. The OU3 ROD is now in the remedial design stage. Although designated by the State as a Class IIA potable water supply, groundwater at the Site is not known to be used as a drinking water source in the area. SUMMARY OF SITE CHARACTERISTICS Geology and Hydrogeology The following is an overview of the regional and Site geology and hydrogeology. A detailed description of the geology and hydrogeology for the study area is presented in the RI Report. Additional groundwater investigation work is underway and will be incorporated in the future OU4 Non-FUSRAP Groundwater ROD. The Site bedrock is primarily composed of sedimentary rock with some igneous intrusions. The upper portion of the bedrock ranges from 0.5 to 15 feet thick (approximately 12 to 27 feet below grade) and is moderately to severely weathered. The overburden is divided into two deposits: the

                                                            1 The 2003 ROD, issued jointly by EPA and USACE to address radiologically contaminated soils at the Site, is identified in that document as the first operable unit of the Site. Subsequent Site documentation has described the 2003 ROD it as “OU2,” as it is identified here.

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man-made fill and recent age deposits. The latter consist of stratified glacial deposits, unstratified glacial deposits and residual soil. The overburden thickness varies from two to 15 feet at the Site. Surface Water The Lodi Brook originates on the 149-151 Maywood Avenue (Sears) property in a low marshy area and flows approximately 1,400 feet as an open channel through the 149-151 Maywood Avenue property to Route 17. Lodi Brook is a continuously-fed, or perennial, stream, with an estimated base flow of two cubic feet per second. Lodi Brook is fed by shallow groundwater at the two headwater tributaries that originate in wetlands; however, the main channel does not appear to be a major groundwater discharge point. Lodi Brook also receives intermittent storm water runoff. At Route 17, Lodi Brook is routed into a culvert pipe. It surfaces again briefly just north of I-80 and flows south to the Saddle River. Topography and Drainage The topography of the study area varies from more than 70 feet above mean sea level at the northernmost portion of the Stepan property to less than 45 feet on the Sears property. South of the Stepan property line with Sears, the surface elevations drop by about 11 feet. Natural Site drainage is generally to the south. Storm water runoff at Stepan is directed to a network of storm water collection drains throughout the paved surface area. The southwestern portion of the Stepan property is covered in crushed stone and surface water runoffs are directed to the catch basins along the southwestern property boundary. Some of the runoff drains into the natural ground or flows toward areas of lower topography. Most surface water runoff from the Sears property and adjacent properties is directed to a network of storm water collection drains. Some of the runoff drains into the wetlands areas east of the Sears building. The wetlands area is drained by a single culvert which runs underneath the Sears access road, between Sunoco, Federal Express, and AMP and toward Route 17, where it is joined on the Sears property by another culvert which runs from Maywood Avenue between the Federal Express and the DeSaussure properties. These culverts are identified as narrow wetlands, on the wetlands boundary map delineated in 1992 and found in the RI report. Soil The Site’s OU1 properties cover a total area of approximately 63 acres where former Maywood Chemical Works operations were located, excluding the government-owned MISS. Chemical, non-radiological contamination was identified in soil and buried waste at the Stepan, Sears and DeSaussure properties. Investigation findings did not identify chemical contamination that required further action at five other properties also investigated as part of the OU1 RI. Due to the nature, extent and location of distinct contamination areas, five separate Areas of Concern (AOCs) were identified and are referred to as the Buried Container Area (AOC1-BCA), Gypsum Material Area (AOC2-GA), Leather Materials Area (AOC3-LMA), Former Aromatics Area (AOC4-FAA) and Central Tank Farm Area (AOC5-CTFA). The five AOCs addressed in this OU1 ROD are located on properties associated with the former Maywood Chemical Works operations (see Figure 2). Brief summaries of the surface features and land use for these three

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properties are presented below. A more detailed discussion of the physical characteristics of the Site study area is provided in the RI report. Stepan Three AOCs, AOC3-LMA, AOC4-FAA and AOC5-CTFA, are located on the Stepan property. The Stepan property is an active chemical manufacturing plant that produces specialty chemicals for various industries. Approximately half of the 19-acre Stepan property is covered with structures, the foundations of former structures, aboveground tank farms, and asphalt or concrete paving. The remaining portions of the property are vegetated or covered with crushed stone or non-vegetated soil. As discussed, the OU2 ROD addresses radiological contaminants on the Stepan property. Three former low-level radiological burial pits, licensed by the Nuclear Regulatory Commission (NRC) were on the Stepan property: Burial Pit No. 1 was covered by grass in the front lawn of the Stepan administration building; Burial Pit No. 2 was beneath a paved parking lot; and Burial Pit No. 3 was located beneath the former warehouse concrete slab. All three burial pits have been remediated under the FUSRAP project. In addition, several other areas of the Stepan property contain radiologically-impacted soil, which USACE is in the process of remediating under FUSRAP to meet a restricted-access, commercial/industrial-use cleanup criteria as established in the 2003 OU2 ROD. Any commingled, non-radiological soil contaminants that coincide with the FUSRAP remediation are also being addressed under this action. The OU2 remedial action is ongoing at the Stepan property. The entire property is fenced except for the parking lot and the front lawn of the Stepan administration building. Sears AOC1-BCA is located over a large portion of the Sears property. The Sears property is an active warehouse facility for the temporary storage of finished goods and is currently Sears' largest distribution facility in northeastern United States. Sears leases the property from Kin Properties. Of the 27.4-acre property, the warehouse covers 7.3 acres, approximately 10 acres are paved and 10 acres are vegetated, including a 3-acre wetland area located on the east side of the warehouse. The low-lying area between the Sears and Stepan properties is also classified as wetlands. Radiologically-contaminated soil is present throughout much of the Sears property, and USACE is in the process of remediating radiologically-impacted soil in accordance with the OU2 ROD. This remediation includes the excavation and disposal of non-radiological soil contaminants that are commingled with the radiologically-impacted soil to meet a restricted, commercial/industrial use cleanup criteria, as established in the OU2 ROD. Remediation of radiologically-impacted soil at the Sears property is ongoing. Inaccessible radiological contamination remains under the building and, in accordance with the OU2 ROD, it will be remediated by USACE at a future time when, through changes in use initiated by the owner (such as redevelopment or demolition), allows access to material under the building. The OU2 ROD requires land use restrictions, such as deed notices, until the remaining radiological contamination is removed from this property.

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DeSaussure AOC2–GA is found on the DeSaussure property, where an active office equipment and furniture wholesaler is located. A parking lot and an approximately 52,000 square-foot office/warehouse cover approximately 45 percent of the 3.6-acre property. The remaining portions of the property are wooded or covered with grass and include a 0.4-acre wetland area to the north of the developed portions. As with the Stepan and Sears parcels, radiologically-contaminated soil was identified on much of DeSaussure property. USACE completed FUSRAP excavation of the radiologically-impacted soil that is accessible and not located beneath the building. This remediation included the excavation and disposal of non-radiological soil contaminants that were commingled with the radiologically-impacted soil. Similar to the Sears parcel, inaccessible radiological contamination remains under the building and, in accordance with the OU2 ROD, it will be remediated by USACE at a future time when, through changes in use initiated by the owner (such as redevelopment or demolition), allows access to material under the building. The OU2 ROD requires land use restrictions, such as deed notices, until the remaining radiological contamination is removed from this property. Investigation Summary Chronology of Investigations and Studies Remedial investigation (RI) activities were conducted to determine the nature and extent of chemical contamination on the Stepan property, the DeSaussure property and the Sears and adjacent properties so that remedial actions could be planned and implemented. In 1986, EPA began to characterize chemical, non-radiological contamination on the Stepan property and surrounding areas. Through the issuance of an AOC in 1987 and UAO in 1991, Stepan began investigations of OU1 properties. The RI for these properties was conducted from August 1991 through November 1992. In June 1993, EPA completed a baseline risk assessment for the Site based on the RI findings. Additional investigations included a 1994 investigation of leather waste and chromium-contaminated soil on the Stepan property. The RI report was completed in November 1994. Additional groundwater testing, pilot tests and treatability studies were conducted from 1997 to 2006. Feasibility Studies (FS) to identify and evaluate remedial alternatives began in 1995 and the OU1 FS was completed in August 2013. Results of soil sampling and test pit analyses performed during the RI identified waste materials as potential sources of groundwater contamination. Well locations were selected during the RI to assess the degree of groundwater impacts from these sources. Fifteen overburden monitoring wells (three on Stepan and 12 on Sears and adjacent properties) and 17 bedrock monitoring wells (five on Stepan and 12 on Sears and adjacent properties) were installed for the initial RI work. Additional wells were installed during subsequent focused investigations, and now there are more than 50 wells to monitor Site groundwater conditions (see Figure 2A). Results from several rounds of groundwater samples demonstrated that groundwater is being impacted from sources in the five AOCs. Groundwater data were compared to EPA and NJDEP Maximum Contaminant

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Levels (MCLs) for drinking water and NJDEP Groundwater Quality Standards (GWQS) for Class IIA aquifers. The groundwater underlying the Site is classified as Class IIA, which means it is designated by NJDEP for existing or potential potable water supply. NJDEP soil cleanup guidelines that were in place at the time the RI was performed and EPA’s baseline risk assessment findings were used to evaluate analytical results. The 1993 baseline risk assessment (discussed in further detail in the “Summary of Site Risks” section) assumed that the future use of the Stepan property would remain commercial and the future use of the Sears and adjacent properties would be commercial or potentially residential. These assumptions were revisited for the August 2013 FS and this ROD and, in keeping with local land use trends and plans and to be consistent with the future land use assumptions in the 2003 OU2 ROD for FUSRAP soil and buildings, future land use is assumed to be commercial for properties included in OU1. The August 2013 FS compared the soil results to the December 2008 NJDEP default impact-to-groundwater screening levels and NJDEP Non-Residential Direct Contact Soil Remediation Standards (NJAC 7:26D). Nature And Extent Of Contamination Investigation activities conducted during the RI included surface geophysical investigations, soil borings, test pits, soil gas investigation, soil, sediment, surface water and groundwater sampling. The initial RI work was conducted on a Site-wide basis for buried, intact waste materials and contaminated soil. Once investigations characterized Site conditions in more detail, five AOCs were established based on the nature and location of contamination areas. The following paragraphs briefly summarize the results of the sampling conducted during the Site investigation. Buried Waste Materials Buried waste materials identified and sampled during the RI soil and test pit investigations included gypsum waste on the DeSaussure property, buried drums and waste located predominantly on the Sears property and leather wastes and chromium-contaminated soil located on the Stepan property. During the RI, 129 test pits were excavated. Of these, 19 (three on Stepan, two on DeSaussure, and 14 on Sears) were found to contain crushed drums or drum remains with no contents. An additional 16 test pits excavated on the Sears property contained drums with waste contents. Twenty test pit samples, plus three duplicate samples, were collected and analyzed. Samples were collected from drum contents and test pit soil. The waste samples collected from the test pit program showed elevated concentrations of VOCs above NJDEP and EPA risk-based criteria. All samples with concentrations of VOCs exceeding NJDEP criteria were collected from sludges within drums, with the exception of one sample collected from soil associated with a crushed drum on the Sears property. Soil The objective of the RI soil boring and sampling program was to identify and characterize existing sources of chemical, non-radiological contamination in the overburden soil. During this investigation, 44 soil bore holes were installed throughout the Site and 126 soil samples were

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collected and analyzed. Several VOCs were detected at concentrations exceeding NJDEP impact-to-groundwater cleanup guidelines. Based on the RI results, which included groundwater monitoring wells that were found to contain contaminants above NJDEP MCLs for drinking water, a soil gas investigation and soil boring sampling program were conducted to determine if the soil in the CTFA and in the FAA (both on the Stepan property) were a likely source of VOC contamination in groundwater. Benzene, toluene, ethylbenzene and xylene (BTEX) were detected at concentrations exceeding NJDEP MCLs. During the RI, a review of current plant operations was conducted to determine if there was a continuing source of soil contamination impacting groundwater. Based on the types of raw materials, intermediates, products and by-products being handled in the CTFA, a continuing source of VOC contamination to soil from ongoing activities does not appear to be present, although residual soil contamination may continue to contribute to groundwater contamination. Buried Container Area of Concern (AOC1-BCA) The BCA is located in the southern portion of the Sears property. The BCA is approximately 20.6 acres and is adjacent to the Sears Logistics Building. Figure 3 shows a location map with the BCA boundaries in green. Buried material is likely to be present in the area beneath the Sears Logistics Building (7.3 acres); as described earlier, the material is currently inaccessible, and will be remediated under the OU2 ROD at a future date once the material becomes accessible. It is expected that chemical contamination will be commingled with the FUSRAP waste beneath the building. Once the FUSRAP excavations are complete, confirmatory sampling will be conducted to determine if non-FUSRAP contamination is present under the building (as it typically was throughout the rest of the BCA), and if so, this non-FUSRAP contamination will be addressed as part of this OU. BCA materials have been identified at four feet below the ground surface with one exception noted below. The BCA was undeveloped, wooded and open land until the 1950s. By 1970 the property was completely developed. Organic residues from industrial production activities at the Maywood Chemical Works included resins and oily materials. These residues included solvents and degreasers, both halogenated and non-halogenated organic compounds, which were placed in drums and buried in various locations on the Sears property, later to be covered with pavement or by other construction activities. The exact dates of the burial of the drums in the BCA are unknown, but based on land use activities, the drums were probably buried at some time between 1960 and 1970. The media of concern associated with the AOC1-BCA includes buried containers and associated liquid/solid waste materials (contents in buried containers) and soil contaminated above the remediation goals. Test pits on the Sears property contained drums with residual contents which were sampled during the RI. During the RI, 20 borings and 32 test pits were excavated on the Sears Property. Borings were installed to depths of approximately eight feet below ground surface (bgs) and test pits were excavated to depths of six feet bgs. Test pits were excavated to investigate magnetic anomalies

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identified during the magnetometer survey completed during the RI. Buried containers were generally observed in the upper four feet of overburden. Based on the results of the test pit program and magnetometer survey, Roux Associates, Inc. (Stepan’s environmental consultant), estimated that there were upwards of 600 buried containers in AOC1. Of the test pits and borings completed on the Sears Property, all but one boring (C-36) has or will be disturbed during the FUSRAP excavation work. Soil samples collected across AOC1 in the upper four feet of overburden had concentrations of metals greater than the remediation goals, which were established based on exposure to soil or impact to groundwater. Elevated concentrations (i.e., greater than the remediation goal) in the upper four feet of soil ranged from 66.5 milligram per kilogram (mg/kg) to 337 mg/kg for lead, 250 mg/kg to 540 mg/kg for chromium, 255 mg/kg to 810 mg/kg for lithium and 20.8 mg/kg to 53.3 mg/kg for arsenic. Samples with elevated concentrations were generally located to the southern and western portions of AOC1. Concentrations of metals greater than or equal to the remediation goals were noted in the upper two feet at boring C-36, which will be undisturbed by the FUSRAP excavations. Concentrations of metals greater than or equal to the remediation goals at this boring location were arsenic (26.8 mg/kg) and chromium (242 mg/kg). In general, concentrations of metals exceeding the remediation goals were less than four feet bgs, with the exception of boring C-07. At this location, an elevated concentration of chromium at more than four feet bgs was observed. The concentration of chromium at this location was 402 mg/kg at a depth of seven to eight feet bgs. Because the elevated concentration of chromium at this location was one or two orders of magnitude greater than the surrounding soil sample concentrations, this area was assumed to be a possible “hot spot.” Boring locations with the greatest concentrations of metals in soil were C-07, C-09 and C-16. All of these locations will or have been remediated during the FUSRAP excavations, with the exception of C-07 which has elevated concentrations of chromium deeper than four feet bgs and was assumed to be left in place after the FUSRAP excavations were complete. Samples were also collected from 11 of the 32 test pits excavated during the RI. Samples were collected of both soil and material contents from buried containers. TP-106 located in the south portion of AOC1 had elevated concentrations of 14 VOCs such as acetone and benzene above the remediation goals. This and all other samples collected from test pits are assumed to be removed during excavations completed under the FUSRAP program because samples were collected within the upper four feet of overburden. Since the OU1 RI work was completed, USACE has been excavating radiologically-contaminated soil in AOC1 and the surrounding areas. The areal extent of excavations completed under the FUSRAP program covers approximately 12.2 acres of the 20.6 acre BCA, with an additional area of about 7 acres under the warehouse designated to be excavated in the future. The FUSRAP remediation uses post-excavation sampling to confirm that the bottom of each excavated area is free of radiological contamination, Final status reports are prepared at the completion of the OU2 remedial activities for each property. Excavation work is still underway at Sears property and therefore the property’s final excavation drawings with depths were not available at the time of the FS. It is estimated that these excavations extended to four feet bgs based on visual observations. Areas outside of the work completed or proposed under the FUSRAP program consists of 12 discrete areas in the BCA, totaling approximately 2.2 acres (see Figure 8). Groundwater samples at the

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BCA taken from 10 overburden wells with a maximum depth of 16 feet bgs have exhibited concentrations in excess of NJDEP GWQS or MCLs for VOCs and metals. Groundwater investigation data can be found in the AR. It is important to note that USACE is remediating accessible FUSRAP waste on the Sears property. More than 70 percent of the BCA has already been remediated by USACE. FUSRAP waste excavation depths are typically four feet deep in this AOC, because the man-made fill is found to this depth. It is estimated that a total area of approximately 2.2 acres remains unremediated today because no FUSRAP cleanup was called for; this area contains 14,600 cubic yards of contamination, from the surface to approximately four feet bgs. An additional area would also be addressed with this action, a “hot spot” location in the parking lot to the south of the warehouse (see Figure 8) where contamination is located at four to eight feet bgs. Gypsum Area of Concern (AOC2-GA) The GA is located on the northern and northeastern portions of the DeSaussure property (see Figure 4). The GA is approximately 1.5 acres, with gypsum material found to a depth of four feet bgs. Maywood Chemical Works operations included caffeine extraction from tea leaf waste. Gypsum sulfate (calcium sulfate) was used as a filter aid during the caffeine extraction process. As much as 600 tons of gypsum material from these processes, which contained contaminants such as cyanide and metals, were reportedly disposed of within the boundaries of the present-day DeSaussure property. Exact dates of the gypsum disposal are unknown. The gypsum material is typically identified visually by its blue color. USACE removed FUSRAP waste from this area and it is estimated that 6,250 cubic yards of gypsum waste material remain on the GA. SVOCs were also found in this soil. It is expected that chemical contamination will be commingled with the FUSRAP waste below the building (as it typically was throughout the rest of the GA). Confirmatory sampling would be conducted to determine if non-FUSRAP contamination is present under the building after the FUSRAP excavations are complete, any non-FUSRAP contamination would be addressed as part of this OU. The media of concern associated with the AOC2-GA includes gypsum material that contains cyanide and metals, and soil with levels of contaminants greater than the NJDEP’s impact-to-groundwater criteria or non-residential direct-contact soil cleanup criteria (NRDSCC). The areal extent and depth of the gypsum material was determined during the RI and was based on field observations from test pits and borings. Based on these observations, Roux Associates, Inc., estimated that the gypsum waste extended to approximately four feet bgs over an area of 1.5 acres, a volume of 9,778 cubic yards. Samples of blue silty gypsum material taken during the RI revealed concentrations of barium, chromium, cyanide, lead and mercury above NJDEP impact-to-groundwater levels. In addition to samples of the gypsum material, soil samples were collected from three borings installed on the property. Sample depths ranged from the surface to eight feet bgs. Soil sample results indicated concentrations of metals exceeding remediation goals to be generally co-located with the gypsum material. Soil sample results for SVOCs (benzo(a)anthracene, benzo(a)pyrene, benzo(a)fluoranthene, dibenzo(a,h)anthracene, indeno(1,2,3-cd)pyrene) chromium and lead exceeded the NJDEP NRDSCC levels. Lead ranged

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from 2.7 to 452 mg/kg. Soil sample results above these criteria were found above four feet bgs in AOC2. Of the sample results collected during the RI the only samples removed during the FUSRAP excavations are BM-1, which had concentrations of cyanide at 3.6 mg/kg and lead at 263 mg/kg, and BM-3 with concentrations of cyanide at 157 mg/kg, lead at 480 mg/kg and barium at 1,670 mg/kg. One groundwater monitoring well is located in the GA overburden at a depth of 16 feet bgs. Three rounds of samples were collected from this well and NJDEP MCL or GWQS exceedances were observed for metals. Since the OU1 RI was completed, portions of the GA have been remediated for radiological contamination under the OU2 remedy. OU2 excavation depths of work performed to date ranged from one to eight feet bgs. Upon completion of excavations, areas were backfilled with clean soil and restored with vegetation. USACE has provided maps of the areal extent of excavations completed up to January 2006, which were used in the OU1 FS to provide a reasonably conservative estimate of the remaining gypsum material and contaminated soil. Based upon the work documented to date, an estimated 3,528 cubic yards of gypsum material and contaminated soil has been removed under the OU2 (FUSRAP) program. The remaining gypsum material and contaminated soil to be removed under the OU1 remedy is estimated at approximately 6,250 cubic yards and is shown on Figure 9. Leather Material Area of Concern (AOC3-LMA) The LMA is located on the northwestern portion of the Site on the Stepan property, and consists of approximately 3.4 acres where leather material was identified during the 1992 RI and the July 1994 focused investigation (see Figure 5). Test pit investigations on the Stepan property found tanned leather waste material in both the surface and the subsurface. This material consisted of purple fibrous material, assumed to be the by-product of former protein extraction operations. The LMA consists of leather material (raw leather material, residual tanned leather, or filter cake from leather digestion) located in two separate areas on the Stepan property. One area is located west of Stepan Building 67 and is approximately 95,000 square feet (designated as LMA-A). The second area (designated as LMA-B) is located south of LMA-A and southwest of the Former Aromatics Area and is approximately 35,000 square feet in area. The leather material extends to approximately two feet bgs with one hot spot at four feet bgs. Leather processing methods at the Maywood facility suggest that the predominant form of chromium in the solids filter cake is expected to be chromium hydroxide. Chromium was detected in the leather waste and soil at concentrations in excess of NJDEP’s NRDCSS remediation standard. Results of investigations indicate that, although the soil contains high levels of total chromium, it is primarily in the immobile and less toxic trivalent form of chromium, and the more mobile and toxic hexavalent form is found in very low concentrations. Raw leather material was observed during the RI and focused investigation and exists in localized areas at shallow depths from zero to two feet bgs. These areas were identified in the western quadrant of LMA-A and the southwestern quadrant of LMA-B. RI and focused investigation results detected chromium in test pits and hand auger samples in the leather

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digestion areas, specifically the southern portion of LMA-A and the east-southeastern quadrant of LMA-B. The total chromium concentrations in LMA-A ranged from 16 mg/kg to 117,000 mg/kg and the total chromium concentrations in LMA-B ranged from 390 mg/kg to 27,500 mg/kg. Chromium concentrations exceeding NJDEP NRDSCC in shallow soil samples analyzed in LMA were generally at depths of less than two feet bgs except for the sample from TP-13, located in the central quadrant of LMA-A. Since the highest chromium concentration of 117,000 mg/kg was detected at a depth of four feet bgs as compared to other sampled areas in LMA, the TP-13 location is considered as a “hot spot” area. Benzo(a)pyrene and pentachlorophenol (SVOCs) and arsenic in soil also exceeded the NJDEP NRDSCC. Benzo(a)anthracene, benzo(a)pyrene and pentachlorophenol, arsenic and lead exceeded the NJDEP impact-to-groundwater screening levels and are considered potential sources of groundwater contamination. LMA groundwater is monitored using three overburden wells. More than five rounds of groundwater sampling data have shown NJDEP GWQS exceedances for metals. Areas in LMA-A and LMA-B were also radiologically-impacted, resulting in the need to coordinate remedy implementation with USACE remediation under OU2. Between 2007 and 2010, USACE excavated approximately 2,599 cubic yards of the leather material, which was commingled with radiologically-impacted material to a depth of two feet bgs, at LMA-A. In 2010, USACE excavated approximately 2,511 cubic yards of the leather material (also commingled with radiologically-impacted material) at LMA-B to a depth of two feet bgs. USACE backfilled the excavated areas with clean fill. Excavated areas were restored, paved with asphalt on LMA-A and with a vegetated cover on LMA-B. Conservative areal estimates were calculated by Stepan’s environmental consultant and for the 2013 FS. The areas identified in Figure 10 are the areas remaining which require remedial action and are estimated to include 6,089 cubic yards of leather material in LMA-A and 465 cubic yards of leather material in LMA-B. The “hot spot” area at TP-13, contaminated to a depth of four feet bgs in LMA-A is included in the volumes noted above. Because areas in LMA-A and LMA-B were not fully delineated during the RI investigations, there is potential for chromium to be present at elevated concentrations at depths deeper than two feet bgs in areas previously remediated by USACE as part of OU2. These volume estimates assume that some component of these deeper soils may also need to be addressed by an OU1 remedy. It is estimated that a total of approximately 6,550 cubic yards of material exceed New Jersey direct-contact or impact-to-groundwater criteria in the LMA. Former Aromatics Area of Concern (AOC4-FAA) The FAA is located to the west of Building 10 in the southwestern portion of the Stepan property (see Figure 6). The FAA is approximately 0.37 acres in area. The FAA formerly contained a number of buildings related to the production of essential oils and aromatic chemicals. These buildings were removed in the late 1960s. Underground utilities corridors for storm sewer, sanitary sewer and water lines are located within the FAA. VOCs including benzene and xylene were found in the soil and are attributed to former underground storage tanks.

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Elevated benzene (44 mg/kg maximum) and xylene (62 mg/kg maximum) concentrations are identified as risk drivers in either a direct contact or impact-to-groundwater exposure pathway. Soil borings during the RI were installed to a maximum depth of eight feet bgs, and the shallow water table was encountered at approximately six to seven feet bgs. Soil samples at a depth of three to five feet bgs from soil borings SG-5, SG-6, and SG-8 (located in the northern portion of the AOC) and SG-15 (located to the south) had concentrations of contaminants that exceeded remediation goals. Based on soil boring logs provided in the RI report, no free product/staining was observed in any of the soil samples and therefore non aqueous phase liquid (NAPL) is not anticipated at the FAA . FAA groundwater is monitored using 13 overburden wells. Extensive groundwater sampling events for more than 10 years have identified concentrations of VOC and metals in excess of NJDEP GWQS at the FAA. An in situ biological treatment test was performed in 1999 and 2000 for contaminated soil within the FAA, utilizing augmented bacteria to degrade BTEX compounds on approximately 8,500 square feet of vadose zone soil to a depth of approximately six feet bgs. No treatment was performed for soil in the subsurface utility lanes. Post-treatment samples collected in June 2000 to a depth of five feet bgs indicated that a significant amount of BTEX mass had been removed in the FAA. The remaining soil that needs to be addressed by the OU1 remedy in these areas is approximately 2,650 cubic yards to a depth of six feet bgs. Additionally, the RI identified BTEX-contaminated soil was present to a depth of 15 feet bgs, and the impacted area was defined by the extent of the benzene one microgram per liter (µg/l) isocontour in groundwater. The depth to water was assumed to vary from approximately six to eleven feet bgs. For the OU1 FS, BTEX–contaminated soil to the depth of the groundwater surface was assumed to be the soil targeted for remediation; the FS assumed that deeper saturated soil would be remediated using groundwater remedial technologies, to be addressed separately in OU4. USACE has completed remediation of radiologically-impacted soil along the eastern border of the FAA. The area of contamination in the FAA is delineated and confined to a limited area, as depicted on Figure 11. The OU1 FAA contamination includes the unsaturated (not below the groundwater table) soil that remains after the pilot study and areas around subsurface utilities and is estimated to include approximately 3,220 cubic yards of soil. Central Tank Farm Area of Concern (AOC5-CTFA) The CTFA is located adjacent to the north and west of Building 10 in the central portion of the Stepan property (see Figure 7). The CTFA is approximately 0.20 acres in area and formerly contained a number of petroleum and solvent underground storage tanks that were removed around 1991. A lane of underground utilities for storm sewer and sanitary sewer are located within the CTFA. Approximately 800 cubic yards of soil have elevated levels of acetone, benzene, toluene and xylene that exceed NRDCSS or impact–to-groundwater criteria. The FS indicates that soil contamination is found to a depth of seven feet below the surface.

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Elevated benzene (estimated at a maximum concentration of 12 mg/kg), toluene (estimated at a maximum concentration of 130 mg/kg) and xylene (estimated at a maximum concentration of 130 mg/kg total xylene) concentrations are attributed to the presence of former USTs located in the CTFA. Acetone was identified at a maximum concentration of 22 mg/kg in soil, which exceeds the NJDEP impact-to-groundwater screening level and is considered a potential source for groundwater contamination. Soil borings during the RI were installed to a maximum depth of seven feet bgs. The groundwater table was encountered at a depth of six to seven feet bgs. Two soil samples from soil borings SG-10 and SG-18, located to the northeast and west, respectively, in the CTFA, exceeded screening criteria; detections of BTEX compounds in other borings in the CTFA were below screening criteria. In addition to the analytical data, soil boring logs provided in the RI report, noted that free product/staining was observed in soil samples from SG-17, and SG-18, located to the west of Building 10, suggestive of the presence of NAPL. It is assumed that NAPL is bound in the soil matrix and not migrating. Groundwater at the CTFA is monitored using six overburden wells. Concentrations in excess of NJDEP GWQS for VOCs have been observed during sampling events for more than 10 years. Areas in the CTFA were also radiologically-impacted, resulting in cleanup work under the OU2 remedy. USACE excavated approximately 2,599 cubic yards of soil to a depth of 15 feet bgs between 2007 and 2010. USACE backfilled the excavated area with clean fill and paved it with asphalt; this area is currently used as an access road. Based on data presented in the RI it was assumed that BTEX-contaminated soil was present to a depth of 15 feet bgs and the impacted area was defined by the extent of the benzene one µg/L isocontour in groundwater. Also, the depth to water was assumed to be approximately ten feet bgs. Saturated soil below ten feet would be included in OU4. Thus, the contamination to be addressed in the CTFA as part of OU1 is confined to a limited area of unsaturated soil. Areas defined in Figure 12 depict the remaining contamination in the AOC and are estimated to include approximately 800 cubic yards of unsaturated soil. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES Land Uses: The Site properties subject to this remedy have active businesses and are located in a densely populated area, in close proximity to several transportation infrastructure modes. This area is zoned for limited light industrial activities in the Borough of Maywood and for industrial use in the Township of Rochelle Park. Recent demographic information indicates this industrial/commercial area has one of lowest vacancy rates in the nation; therefore, future land use is anticipated to be the same as current land use. Groundwater and Surface Water Uses: Groundwater underlying the Site is considered by the state of New Jersey to be Class IIA, a source of potable water. As presented previously, groundwater data collected during RI activities identified the presence of contaminants at levels above MCLs, GWQS and health-based criteria. Several well searches have been conducted for the Site and the most recent search conducted in 2005 did not identify any private or public supply drinking water wells in use within the five-mile radius search area. Publicly supplied potable water is available in this area, which is treated to assure all drinking water standards are

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met. Surface water at the Site is intermittent and it is conveyed through drainage ditches and culverts on private properties. SUMMARY OF SITE RISKS Baseline Risk Assessment The baseline risk assessment estimates the potential human health and ecological risks the Site poses if no action were taken for current and future Site conditions. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. This section summarizes the results of the baseline risk assessment for this Site. Human Health Risk Assessment A four-step process is utilized for assessing site-related human health risks for a reasonable maximum exposure scenario. The first step, Hazard Identification, identifies the contaminants of concern based on factors such as toxicity, frequency of occurrence, and concentration. The second step, Exposure Assessment, estimates the magnitude of actual and potential human exposures, the frequency and duration of these exposures, and the pathways by which humans are potentially exposed (e.g., by ingesting contaminated well water). The third step, Toxicity Assessment, determines the types of adverse health effects associated with chemical exposures and the relationship between the magnitude of exposure (dose) and severity of adverse effects (response). The fourth step, Risk Characterization, summarizes and combines outputs of the exposure and toxicity assessment to provide a quantitative assessment of site-related risks. The baseline human health risk assessment was conducted in 1993 and evaluated potential risks under both current and reasonably anticipated future use scenarios. Current use scenarios focused on commercial/industrial land use. However, because future land use was thought to vary for different parts of the Site, the Sears and adjacent commercial properties were evaluated separately. The Final Risk Assessment divided the Site into two distinct future potential use categories: (1) industrial use for the Stepan property and (2) residential use for the Sears and adjacent commercial properties. Information and data used in the risk assessment can be found in the tables in Appendix II. The exposure point concentrations are presented in Table 1, while the non-carcinogenic and carcinogenic toxicity values can be found in Tables 2 and 3, respectively. The results of the baseline risk assessment indicate that the future ingestion of contaminated soil at the Site poses an unacceptable risk to human health. The possible ingestion of soil on the Sears property and adjacent properties by children under the future residential use scenario was found to have an estimated Hazard Index (HI) equal to 2, which exceeds the acceptable level of 1 and an excess lifetime cancer risk of 2 x 10-4, which slightly exceeds the acceptable risk range of 10-6

to 10-4. Arsenic was identified as the risk driver for the hazard quotient, while PAHs, including benzo(a)pyrene, were identified as carcinogenic risk drivers in surface and subsurface soil. The summary of the non-cancer hazards is shown in Table 4 of Appendix II and the summary of the excess lifetime cancer risks are presented in Table 5.

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Surface water and sediment samples were collected from the Site wetland areas as part of the RI and the risk assessment evaluated a youth wetlands trespasser scenario for these samples and found no risk drivers present and no unacceptable cancer risks or non-cancer health hazards. As part of the FS, an updated risk screening evaluation was performed, in order to ensure that updated toxicity information for site-related chemicals would be considered in the identification of chemicals of potential concern (COPCs). Additionally, future land use was reevaluated. In keeping with the local land use trends and plans and to be consistent with the future land-use assumptions made in the 2003 OU2 ROD for FUSRAP soil and buildings, a future commercial land-use scenario was assumed for all properties. The OU2 ROD requires deed notices to be placed on the Stepan and Sears properties restricting the properties to non-residential use. The assumption of continued non-residential use is also consistent with current surrounding property uses. The updated risk-screening evaluation compared the maximum detected concentrations of chemicals detected in each of the five areas to NJDEP non-residential direct contact soil remediation standards, EPA risk-based screening levels for commercial/industrial land use. In addition, this evaluation also included a comparison of the maximum detected concentrations in each area to NJDEP impact-to-groundwater soil screening levels, in order to identify in the soil any contamination with potential to migrate to groundwater. A summary of the soil COCs is presented in Table 6 of Appendix II. The following chemicals were identified as COCs in soil or waste material for each AOC; PAHs were identified as human-health risk drivers, while all other contaminants were identified at concentrations above impact-to-groundwater criteria: AOC1 – BCA

VOCs (1,1,1-trichloroethane, acetone, benzene, chloroform, ethylbenzene, methylene chloride, toluene, TCE and xylene);

SVOCs (benzo(a)anthracene and benzo(a)pyrene); and Metals (arsenic, chromium, lead and lithium).

AOC2 – GA SVOCs (benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,

dibenzo(a,h)anthracene and indeno(1,2,3-cd)pyrene); and Metals (arsenic, barium, chromium, cyanide, lead and mercury).

AOC3 – LMA SVOCs (benzo(a)anthracene, benzo(a)pyrene and pentachlorophenol); and Metals (arsenic, chromium and lead).

AOC4 – FAA VOCs (benzene and xylene); and

AOC5 – CTFA VOCs (acetone, benzene, toluene and xylene).

Ecological Risk Assessment A four-step process is used to assess site-related ecological risk for a reasonable maximum exposure scenario. The first step, Problem Formulation, is a qualitative evaluation of contaminant release, migration, and fate; identification of contaminants of concern, receptors,

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exposure pathways, and known ecological effects of the contaminants; and selection of endpoints for further study. Exposure Assessment, the second step, is a quantitative evaluation of contaminant release, migration, and fate; characterization of exposure pathways and receptors; and measurements or estimation of exposure point concentrations. The third step, Ecological Effects Assessment, consists of literature reviews, field studies, and toxicity tests, linking contaminant concentrations to effects on ecological receptors. The last step, Risk Characterization, comprises measurement or estimation of both current and future adverse effects. The ecological risk assessment began with evaluating the contaminants associated with the Site in conjunction with site-specific biological species and habitat information. Receptor species may inhabit the culverts and wetlands near the entrance to the Sears property and on the DeSaussure property; as previously described, these wetlands are associated with man-made drainage culverts and disturbed areas. Due to the extensive development of the Site and surrounding areas, receptor species that may visit the Site are generally expected to be limited. Surface water at the Site is intermittent and typically only present during storm events when precipitation drains into the culverts. The habitat area is small and not particularly attractive due to industrial and commercial activities. In addition, because of these factors the ecological community is not robust. The results of the ecological risk assessment indicated that the contaminated surface water and sediment at the Site may pose unacceptable risk to ecological receptors, primarily due to PAHs, barium, lead, and cyanide. A table of the hazard indices associated with these contaminants can be found in Table 6A. Risk Assessment Summary Actual or threatened releases of hazardous substances from this Site, if not addressed by the preferred alternative or other active remedial alternatives considered here, may present a current or potential threat to public health, welfare or the environment. REMEDIAL ACTION OBJECTIVES Remedial Action Objectives (RAOs) are specific goals established to protect human health and the environment. The following RAOs address human health risks, environmental concerns, contaminants of concern, exposure routes, receptors and acceptable contaminant levels for each exposure route at the Site. To attain these objectives, the Selected Remedy must meet promulgated, enforceable federal or more stringent state “applicable or relevant and appropriate requirements” (ARARs). EPA must further consider standards provided by other advisories, criteria and guidance which EPA deems necessary to protect human health and the environment and risk-based remediation goals established in the risk assessment. The OU1 RAOs are listed below:

Prevent direct contact with contaminated soil above levels that are protective of human health;

Prevent the migration of contaminated soil; and Prevent contaminated soil from impacting groundwater quality.

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REMEDIATION GOALS The remediation goals for specific contaminants that must be met in order to achieve these RAOs, were developed for each area of the Site by considering, among other things, the risk levels identified in the risk assessment as well as New Jersey soil remediation standards for direct contact and New Jersey impact-to-groundwater soil screening levels. A summary of the chemicals of concern in each of the source areas is presented in the following table.

Contaminants of Concern (COCs)

Soil Remediation Goals (mg/kg)

Basis for the Remediation Goal  

Acetone 12 NJDEP Impact-to-Groundwater  

Benzene 0.005 (PQL) NJDEP Impact-to-Groundwater/PQL

Chloroform 0.2 NJDEP Impact-to-Groundwater

Ethylbenzene 8 NJDEP Impact-to-Groundwater

Methylene Chloride 0.007 NJDEP Impact-to-Groundwater

Toluene 4 NJDEP Impact-to-Groundwater

1,1,1-Trichloroethane 0.2 NJDEP Impact-to-Groundwater

Trichloroethene 0.007 NJDEP Impact-to-Groundwater

Total Xylenes 12 NJDEP Impact-to-Groundwater

Benzo(a)anthracene 0.5 NJDEP Impact-to-Groundwater

Benzo(b)fluoranthene 2 NJDEP Non-Residential Direct

Contact Soil Remediation Standard

Benzo(a)pyrene 0.2 (PQL) NJDEP Non-Residential Direct

Contact Soil Remediation Standard

Dibenzo(a,h)anthracene 0.2 NJDEP Non-Residential Direct

Contact Soil Remediation Standard

Indeno(1,2,3-cd)pyrene 2 NJDEP Non-Residential Direct

Contact Soil Remediation Standard Pentachlorophenol 0.3 (PQL) NJDEP Impact-to-Groundwater/PQL

Arsenic 19a Background

Barium 1,300 NJDEP Impact-to-Groundwater

Chromium (total) 242b Site-specific Impact-to-Groundwater

Cyanide 13 NJDEP Impact-to-Groundwater

Lead 59 NJDEP Impact-to-Groundwater

Lithium 194b Site-specific Impact-to-Groundwater

Mercury 0.1 (PQL) NJDEP Impact-to-Groundwater/PQL

Notes: Remediation goals were selected for each soil COC based on the lowest of EPA risk-based Industrial use Regional Screening Level value (10-6, or 1 target hazard quotient), the NJDEP Non-Residential Direct Contact Soil Remediation Standards, and NJDEP Default Impact-to-Groundwater Soil Screening Level or a site-specific impact-to-groundwater value calculated according to NJDEP guidance, if a NJDEP impact-to-groundwater level has not been established for the COC. PQL indicates screening level set at practical quantitation limit. a. The impact-to-groundwater or health-based level defaults to background. b. Site-specific impact-to-groundwater values used for chromium and lithium.

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DESCRIPTION OF REMEDIAL ALTERNATIVES The 2013 FS report describes the remedial alternatives developed and screened for each of the five AOCs, as presented in the table below. The Selected Remedy for each area of concern is in bold text. BCA GA LMA FAA CTFA 1. No Action 1. No Action 1. No Action 1. No Action 1. No Action 2. ICs 2. ICs 2. ICs 2. ICs 2. ICs 3. In Situ Solidification & ICs

3. In Situ Solidification & ICs

3. Capping & ICs

3. Excavation, Off-Site Disposal & ICs

3. Excavation, Off-Site Disposal & ICs

4. Excavation, Off-Site Disposal & ICs

4. Excavation, Off-Site Disposal & ICs

4. Excavation, Off-Site Disposal & ICs

4. Enhanced Fluid Recovery, Excavation & ICs

4. Enhanced Fluid Recovery, Excavation & ICs

5. Soil Vapor Extraction, Excavation & ICs

5. Soil Vapor Extraction, Excavation & ICs

Common Elements for All AOCs Many of these alternatives include common components. CERCLA requires that each selected site remedy be protective of human health and the environment, be cost effective, comply with other statutory laws, and utilize permanent solutions and alternative treatment technologies and resource recovery alternatives to the maximum extent practicable. In addition, the statute includes a preference for the use of treatment as a principal element for the reduction of toxicity, mobility, or volume of hazardous substances. If the selected remedial alternative would result in some contaminants remaining at the Site above levels that would allow for unrestricted use, a review of the remedy is required to be conducted at least once every five years. Pre-Design Investigation (PDI) - All alternatives, except the no action alternatives, would require further characterization in the form of pre-design investigation (PDI) work to delineate the horizontal and vertical extent of the remaining accessible contamination in the unsaturated soil subject to this OU1 remedy. Samples would be collected across all AOCs and analyzed for VOCs, SVOCs and metals. Soil samples would also be collected from within the estimated excavation areas for waste characterization, such as the Toxic Characteristic Leaching Procedure (TCLP) and radiological contamination analysis for use in the remedial design (RD). PDI sample results would be compared to OU1 remediation goals to determine the extent of contamination requiring remediation or institutional controls (ICs).

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Remedial Design (RD) - All alternatives, except the no action and IC only alternatives, would require an RD to provide prescriptive and/or performance-based requirements and estimate costs for the remedial action. The results from the PDI would be used for the RD. The RD would estimate volumes requiring remediation (excavation, treatment or containment), identify details of the remedial components including construction specifications; waste characterization for disposal requirements; post-excavation sampling; restoration specifications; and identify permit requirements. Institutional Controls (ICs) ‐ For all AOC alternatives except the no action alternative, institutional controls such as deed notices, easements or restrictive covenants would be required to: maintain the long-term protectiveness of the remedy; ensure that future use remains commercial/industrial; and prevent future land uses that interfere with the implementation or protectiveness of the remedy. Deed notices would be established pursuant to NJDEP Technical Requirements for Site Remediation N.J.A.C. 7:26E; specific language for deed notice can be found in Administrative Requirements for the Remediation of Contaminated Sites (ARRCS) Rules, N.J.A.C. 7:26C. Monitoring - To ensure the effectiveness of the remedy, including ICs, monitoring is a component of each alternative except the no action alternative. Five-Year Reviews – All AOC alternatives would result in hazardous substances, pollutants or contaminants remaining at the Maywood Chemical Company Site above levels that would allow for unlimited use and unrestricted exposure. Pursuant to Section 121(c) of CERCLA, a statutory review will be conducted within five years after initiation of the selected remedial action and no less often than once every five years thereafter to assure that human health and the environment are being protected by the remedy. AOC1 - Alternatives for Buried Container Area (See Figure 8) BCA Common Elements Chromium Sampling - Sampling data from historical investigations indicate that hexavalent chromium may be present in soil and waste material. PDI soil samples would be analyzed for trivalent chromium and hexavalent chromium to fill RI data gaps in this AOC where chromium is a COC. Potential for Inaccessible Contamination - As discussed previously and as with the OU2 (FUSRAP) remedy, this AOC assumes that contaminated material beneath the occupied warehouse would be addressed at a future time, when the land owner can provide access.

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Alternative BCA-1 – No Action The NCP requires that a “No Action” alternative be developed as a baseline for comparing other remedial alternatives. Under this alternative, there would be no actions conducted at the Site to control, remove, treat or prevent exposures to Site contaminants. This alternative would not result in long-term protection of public health and the environment. The purpose of Alternative BCA-1 is to evaluate the environmental and public health risks posed by the Site if no further remedial actions were taken. No permitting or institutional controls are associated with BCA-1. Because this is a no action alternative, capital, operation and maintenance (O&M), and net present value (NPV) costs are estimated to be $0. No time is needed to implement this alternative.

Alternative BCA-2 – Institutional Controls (ICs) BCA-2 consists of implementing ICs, as described in the Common Elements for All AOCs above. RAOs would be met once ICs are in place. The key components of the IC remedy include the following:

Annual Site inspections to determine whether the remedy is protective of human health and the environment or needs to be modified;

The ICs for the AOC are to be developed and implemented with consideration to those required at the Site under the OU2 remedy, with biennial certification required by NJDEP Technical Requirements for Site Remediation;

Cost: $559,000NPV -- includes investigation to delineate IC areas and assumes 30 years of inspections and certifications; and

Time estimated to establish institutional controls - two years. Alternative BCA-3 – In Situ Solidification (ISS), Buried Container Excavation, Capping and ICs

BCA-3 consists of ISS, excavation of buried containers, capping and ICs. ISS would be used to immobilize a hot spot with elevated chromium concentrations in the vicinity of boring C-07 that is at or below the groundwater table. Buried containers would be removed from the Site. An asphalt or soil cap would be installed to prevent exposure to soil contaminated above remediation goals that are left in place. ICs would be established to prevent exposure to remaining contamination and to protect the engineered remedial components (solidified soil and cap).

The key components for BCA-3 include: ISS -- bench scale testing followed by field implementation; Excavation of buried container materials and VOC-contaminated soil with off-site

disposal; Capping; ICs for solidified materials and cap; Long-term inspection and maintenance of cap;

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Cost: $2,809,000 NPV -- includes investigation to delineate IC areas and assumes 30 years of inspections, maintenance and certifications; and

10 weeks construction.

ISS - Bench Scale Testing – Prior to implementing ISS in the field, a bench scale test would be necessary to identify mixtures of reagents that would effectively stabilize soil contamination and minimize the potential for existing contamination to impact groundwater. The bench scale test would include collecting representative bulk samples of soil on AOC1, applying reagents using variable mixing ratios, and conducting necessary physical and chemical testing of the soil. Samples would be collected from one test pit in the area of C-07 that would be advanced from four to eight feet bgs which would be below the groundwater table (approximately five feet bgs). As a result, dewatering may be necessary during bench scale sample collection. It is assumed that groundwater removed during test pit activities would be collected, characterized, and disposed of off-site at a permitted disposal or treatment facility. Based on the results of the bench scale test, a suitable reagent mixing ratio would be specified. No pilot test is assumed for this BCA-3, since the area requiring ISS is relatively small in area (approximately 2,500 square feet).

ISS – Material requiring solidification is anticipated to range from four to eight feet bgs and is assumed to be approximately 400 cubic yards. Material requiring solidification would be beneath a clean layer of backfill that would need to be removed and stockpiled to expose the material for in situ treatment. For cost estimating, it was assumed that solidification agents would be added at the following weight ratios to stabilize the metals: 20 percent Portland cement and five percent sodium silicate. Actual reagents and weight percentages would be determined during the bench scale test and RD. To account for the increase in volume of solidified materials and provide a cover over solidified materials, the cost estimate assumes that a portion of excess material would need to be disposed off-site. Because excess material would likely be the clean stockpiled soil above the contaminated soil, materials identified for off-site disposal were assumed to be non-hazardous.

Existing pavement above the area to be solidified would be saw cut, removed and shipped off-site for disposal to prepare the area for in situ solidification. Clean backfill (upper four feet of soil) placed as part of the OU2 remedy over contaminated soil would be removed and stockpiled to expose the contaminated soil beneath. Stockpiles would be located in areas acceptable to the property owner and would be encircled with silt fence and covered with plastic when not in use. After solidification, the area would be backfilled with the stockpiled soil and repaved.

Several techniques are available for mixing solidification reagents with the contaminated materials. Shallow Soil Mixing technique is one method for mixing reagents at shallow depths. In situ excavator mixing is also technically feasible, but may be less effective at achieving consistent treatment. In situ rotary mixing and in-situ hollow stem auger methods are also possible techniques for use at this Site. The cost estimate assumes the contaminated soil would be exposed before proceeding with in-situ solidification; however the actual technique implemented would depend on Site conditions and would be determined during the RD.

Excavation of Buried Container Materials and VOC-Contaminated Soil – Buried containers are assumed to remain in areas left undisturbed during OU2 remedy excavations completed. Prior to beginning excavation activities for removal of buried containers, a magnetometer survey would

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be used to confirm/identify remaining buried. Areas identified with anomalies would be excavated to investigate the anomalies and remove buried containers discovered during the excavation activities.

Buried containers (e.g., 55-gallon drums) uncovered during the excavation activities would be removed from the excavation and staged in a designated area. Prior to removing buried containers, an attempt would be made to determine if a container has any chemical or material contents and, if present, the phase of the contents. Drums that are not empty would be carefully removed and staged in an area with secondary containment to contain spills or leaks. Drums containing liquid or solid wastes would be placed in over-pack containers and shipped off-site for disposal. Empty drums would be crushed and sent off-site.

Soil removed to expose buried containers would be stockpiled in designated areas on a plastic liner, encircled with silt fence and covered with plastic when not in use. This soil would also be characterized to determine if it would be suitable for backfill in the open excavations after removing all buried containers or would require off-site disposal.

Off-Site Disposal – All materials removed from the AOC would be disposed of or treated at a facility approved by EPA in accordance with EPA’s “Off-Site Rule” and all other applicable requirements. Soil and waste material would be characterized using TCLP to determine if they would meet RCRA Land Disposal Restrictions (LDR). If concentrations of contaminants are above LDRs, the material would be shipped off-site to a RCRA treatment facility for immobilization treatment (ex situ solidification) prior to final disposal in the landfill. For cost-estimating purposes, it was assumed that 30 buried containers would require removal and off-site disposal, with 20 percent empty, 25 percent containing oil/resin-like fluids, and the remaining 55 percent containing soil or solid waste. It was also assumed that none of the soil in the BCA would be radiologically contaminated because the USACE FUSRAP work completed to date at this AOC has met the unrestricted use cleanup criteria.

Dewatering would likely be needed during excavations conducted in the wetland and surrounding area. For cost estimating it was assumed that a well point or sump dewatering system would be used to lower the water table during removal of buried containers. Water generated would be temporarily stored in tanks before being disposed off-site or treated onsite and discharged to surface water. Prior to disposal or discharge, samples would be collected to characterize the water generated. For cost estimating purposes, it was assumed that construction water generated at the Site would be classified as non-hazardous in character.

Capping – Approximately 2.2 acres of AOC1 would be capped with either an asphalt or soil cover. This includes areas in AOC1 that would be excavated to four feet bgs to remove buried containers. For cost estimating purposes, it was assumed that the asphalt cap would consist of six inches of asphalt and be load bearing. The vegetated area and wetland would be capped using a two-foot soil cover. Excess soil would be disposed off-site to allow construction of the cap to meet existing grades. The two-foot soil cover in the vegetated area outside the wetland would consist of 18 inches clean imported backfill, six inches of topsoil and seed. In the wetland, the soil cap would consist of 12 inches of clean imported backfill and 12 inches of clay or hydric soil with similar physical and geochemical properties to the existing soil. The wetland area would

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then be planted with species of plants similar to the current vegetation growing in the wetland. Both caps would reduce the potential for human contact with remaining contaminated soil left in place beneath the caps.

ICs –ICs, as described in in the Common Elements for All AOCs section, would be implemented under this alternative. In addition the ICs would protect solidified materials left in place and the cap.

Long-Term Inspection and Maintenance – Long term maintenance of the cap would include annual inspections and planning for corrective actions (such as patching and repair of compromised asphalt and that may periodically be needed to maintain the integrity of the cap and prevent exposure to stabilized contaminants). It is assumed that the paved areas would be re-sealed at a frequency of every two years. The asphalt cap is anticipated to last a minimum of 15 years. For cost estimating purposes, it was assumed that after 15 years the asphalt cap would need to be resurfaced. The restored wetland and vegetated area would be inspected to verify no intrusive activities have occurred that could expose remaining contaminated soil beneath the soil cover. The wetland would also be inspected to determine the overall health of the restored wetland area for a period of 10 years. Wetland inspections would include both qualitative and quantitative monitoring to ensure the overall health of the restored wetland and to identify maintenance needs. The time required to implement the ISS and capping under this BCA-3 is assumed to be 10 weeks. RAOs would be met once the remedy is constructed and ICs are in place.

Alternative BCA-4 – Excavation, Off-Site Disposal, ICs BCA-4 consists of excavation and off-site disposal of remaining buried containers, associated waste materials and soil that is contaminated at concentrations greater than remediation goals. The key components for BCA-4 include:

Excavation; Off-site disposal; Restoration; Long-term inspection and maintenance; Cost: $7,254,000 NPV – includes investigation to delineate IC areas and assumes 30

years of inspections, maintenance and certifications; and 22 weeks construction.

Excavation– Approximately 14,600 cubic yards of contaminated soil and buried containers would be excavated and disposed off-site. Areas to be excavated are would encompass a total area of approximately 2.2 acres. Excavation depths would be to four feet bgs at all locations except for the area designated as a “hot spot.” Contaminated soil in the “hot spot” area exists from four to eight feet bgs and would require the removal and temporary stockpiling of the upper four feet of clean backfill installed during the OU2 remedy. After removing the contaminated soil beneath the clean/approved backfill, the stockpiled soil would be used to backfill the open excavation at this location. Stockpiled material would be located in an area acceptable to the

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property owner and tenant and would be placed on plastic sheeting, secured, encircled with silt fencing and covered with plastic when not in use. Initial excavation activities would include removal of asphalt in paved areas of the AOC that are designated for soil and buried container removal. Excavations in the main access road and parking area would require coordination with the property owner and tenant since excavation work may impede access to the warehouse and affect the traffic patterns. Traffic signage, concrete barriers, temporary fencing, orange cones or other measures would need to be used during this work. Areas directly adjacent to the building would also require coordination with Site operations. Because the warehouse is active, BCA-4 would potentially require multiple mobilizations and demobilizations in order to complete excavation activities. Dewatering would likely be needed during excavations conducted in the wetland and for the “hotspot” excavation at boring C-07, which would be below the groundwater table. For cost-estimating purposes, it was assumed that a well point or sump dewatering system would be used to lower the water table during removal of contaminated materials. Water generated would be temporarily stored in tanks before being disposed off-site or treated on-site and discharged to surface water. Prior to disposal or discharge, samples would be collected to characterize the water generated. For cost-estimating purposes, it was assumed that construction water generated at the Site would be classified as non-hazardous. During excavation, continuous air monitoring within the work area and perimeter dust monitoring would be conducted. The excavation would only be conducted in accessible areas and would not occur beneath the warehouse at this time. Off-Site Disposal – Contaminated soil would be temporarily stockpiled on plastic sheeting or directly loaded into trucks for off-site disposal. Prior to disposing of contaminated soil waste characterization sampling would be completed, as described in Alternative BCA-3. For cost-estimating purposes, soil disposed off-site was assumed to be 10 percent hazardous and the remaining 90 percent non-hazardous. Buried containers (e.g., 55-gallon drums) uncovered during the excavation activities would also be handled as described in Alternative BCA-3. Restoration – After excavation and removal of buried containers and contaminated soil, confirmatory samples would be collected. Samples would be analyzed for VOCs, SVOCs and metals. The actual number of confirmatory samples would be determined during the RD and would be based on actual Site conditions. Based on laboratory data and comparison with the Site remediation goals, additional excavation may be required. Once final excavation work is completed, the excavation would be backfilled with clean stockpiled soil and/or clean fill material imported to the Site. Paved areas would be restored with asphalt, and unpaved areas would be restored with six inches of topsoil and seed. The thickness of base course and pavement would be restored in kind. The wetland area would be restored with vegetation and soil having similar properties as the existing wetland, to allow for the wetland to recover to its original condition. Actual materials and vegetation required for wetland restoration would be determined during the RD. The FS assumed that the wetland restoration would include re-grading of the area to maintain the existing grades and drainage patterns that existed prior to disturbing the area. After grading, a minimum of 12 inches of clay or hydric soil with similar physical and geochemical properties to

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the existing soil would be placed. The wetland would then be planted with species of vegetation similar to the current vegetation growing in the wetland. Long-Term Inspections and Maintenance – Annual inspections would be conducted to assess the protectiveness of the remedy. Observations made during these inspections would be used to determine whether additional measures are needed to provide continued protection of human health and the environment. The wetland would also be inspected to determine the overall health of the restored wetland area for a period of 10 years, as described in BCA-3. The time required to implement BCA-4 is assumed to be 22 weeks. RAOs would be met once the remedy is constructed and ICs are in place. Alternatives for Gypsum Area of Concern (See Figure 9) GA Common Elements Chromium Sampling - Sampling data from historical investigations indicate that hexavalent chromium may be present in soil and waste material. PDI soil samples would be analyzed for trivalent chromium and hexavalent chromium to fill RI data gaps in this AOC where chromium is a COC. Potential for Inaccessible Contamination - As discussed previously and as with the OU2 (FUSRAP) remedy, this AOC assumes that contaminated material beneath the occupied building would be addressed at a future time, when the land owner can provide access.

Alternative GA-1 – No Action See BCA-1 No Action description.

Alternative GA-2 – ICs GA-2 consists of implementing ICs as described in the Common Elements for All AOCs above. This alternative has the same components and time frames as the BCA-2 alternative with a cost estimate of $378,000 NPV. RAOs would be met once ICs are in place.

Alternative GA-3 – ISS, ICs

GA-3 consists of ISS and capping. ISS is intended to decrease the mobility of the metals and cyanide in the gypsum material and contaminated soil. Reagents used for stabilizing contaminated materials can include Portland cement, slag cement, fly ash or bentonite. The key components for GA-3 include:

ISS -- pilot test followed by field implementation; Restoration; ICs for stabilized materials; Long-term Inspection and Maintenance;

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Cost: $2,084,000 NPV -includes investigation to delineate IC areas and assumes 30 years of inspections, maintenance and certifications; and

18 weeks construction. Pilot Test – Prior to implementing ISS, a pilot test would be necessary to identify mixtures of reagents that would minimize the potential for existing contamination to impact groundwater and prevent future exposure to contaminated materials. An excavator would be used for the pilot test. For cost estimating it was assumed that a 15 foot by 15 foot by four feet deep area would be solidified during the pilot test. After completing the test, the solidified material would be tested to evaluate the hydraulic conductivity and potential for future leaching of solidified contaminants. Based on the results of the pilot test a suitable reagent mixing ratio would be selected. After receiving sufficient results as determined during the RD, the full scale remedial action (RA) would be implemented.

ISS –Material requiring solidification is anticipated to range from the surface to four feet below grade and is assumed to be approximately 6,250 cubic yards. In areas where FUSRAP excavations were less than four feet bgs, material requiring solidification would be beneath a clean layer of backfill that would need to be removed and stockpiled to expose the material for in situ treatment. For cost estimating it was assumed that solidification agents would be added at the following weight ratios to solidify the cyanide and metals: 20 percent Portland cement and five percent sodium silicate. Actual reagents and weight percentages would be determined during the pilot test completed during the RD. To account for the increase in volume of solidified materials and provide a cover over solidified materials, the cost estimate assumes that a portion of excess material would need to be disposed off-site. Materials identified for off-site disposal were assumed to be 10 percent hazardous and 90 percent non-hazardous. The area to be solidified would be cleared and grubbed to prepare the area for ISS. In areas where OU2 excavations were less than four feet bgs, clean backfill placed by USACE over the remaining contaminated soil and gypsum material would be removed and stockpiled to expose the contaminated soil and gypsum material beneath. After solidification, stockpiled soil would be reused to backfill the solidified mass. Stockpiles would be located in areas acceptable to the property owner and would be encircled with silt fence and covered with plastic when not in use. Several techniques are available for mixing solidification reagents with the contaminated materials and are described for BCA-3.

Restoration – After stabilizing the material the area would be backfilled where appropriate, and restored with six inches of topsoil and seed. The wetland area would be restored, as described for BCA-4 restoration above, except that vegetation would be limited to plants having root zones less than eight inches to protect the solidified materials below the wetland. The final cover would protect the stabilized material from weathering and human contact.

Institutional Controls – ICs as described in the Common Elements for All AOCs and to protect the stabilized materials and associated cover would be implemented under GA-3.

Long-Term Inspection and Maintenance – Operation and maintenance for GA-3 would include long term monitoring of groundwater to verify whether subsurface contaminants continue to leach into the groundwater. Groundwater samples would be collected from the existing on-site monitoring well twice per year. Samples would be analyzed for metals and cyanide. Inspections

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and certifications described under GA-2 for ICs would also be required under GA-3. In addition to inspecting the Site for continued compliance with the ICs, the restored area would be inspected to verify no intrusive activities have occurred that could potentially impact solidified materials. The wetland would also be inspected for a period of 10 years to determine whether the existence of solidified waste materials beneath the wetland has had an impact on the water level and vegetation and overall health of the restored wetland area to ensure the overall health of the restored wetland and to identify maintenance needs.

The time anticipated to implement GA-3 is assumed to be 18 weeks. This includes time to conduct the pilot study. RAOs would be met once the remedy is constructed and ICs are in place.

Alternative GA-4 – Excavation, Off-Site Disposal, ICs GA-4 consists of excavation and off-site disposal of remaining gypsum material and soil contaminated above remediation goals. The key components for GA-4 include:

Excavation of gypsum material and impacted soil with ex situ stabilization, if needed for off-site disposal;

Off-site disposal; Restoration; Long-term inspection and maintenance; Cost: $3,866,000 NPV – includes investigation to delineate IC areas and assumes 30 years

of inspections, maintenance and certifications; and 10 weeks construction.

Excavation – Excavation would be performed to remove contaminated soil to meet remediation goals. Prior to excavating, the area would be cleared and grubbed and erosion and sediment controls installed. Areas previously remediated as part of the OU2 remedy would be excavated to access any contaminated soil and gypsum material that may remain beneath, and the clean soil would be stockpiled for use as backfill in the area. Dewatering would likely be needed for excavations completed in the wetland and surrounding area. Water generated would be temporarily stored in tanks before being disposed off-site or treated on-site and discharged to surface water. Prior to disposal or discharge, samples would be collected to characterize the water generated. Waste characterization testing would include radiological sample analysis. For cost estimating it was assumed that waste water generated at the Site would be non-hazardous. It is estimated that 6,250 cubic yards of gypsum material and contaminated soil would require removal and off-site disposal. Excavation activities would need to be completed in stages due to space limitations and considering that stockpiling of clean soil for backfill would be necessary. Contaminated soil and gypsum material would also be temporarily stockpiled before disposing off-site. Stockpiled material would be located in an area acceptable to the property owner and would be placed on plastic sheeting, secured, encircled with silt fencing, and covered with plastic when not in use. Contaminated material stockpiles would be located in areas outside natural drainage ways and away from the building and residential properties east of the Site.

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Off-Site Disposal – Waste materials would be characterized and disposed of as described in BCA-3. In addition, waste would be sampled and analyzed for radiological impacts since radiological soil remediated in this area was completed (except under the existing building) in accordance with the OU2 ROD. Radiological waste disposal would comply with all applicable requirements. For cost-estimating purposes, in the FS it was assumed that 10 percent would be radiologically-impacted, 10 percent would be hazardous and the remaining 80 percent would be non-hazardous. Restoration – Confirmatory samples would be collected prior to backfilling the excavations. Once sample results meet the cleanup objectives the area would be backfilled with clean imported and onsite soil. After backfilling the excavation area, six inches of topsoil would be applied and seeded. Excavation in the wetland would be restored to original conditions with vegetation and soil having similar properties to the existing wetland, as described in the BCA-4 restoration section above. Long-term Inspection and Maintenance –The wetland would be inspected to determine the overall health of the restored wetland area for a period of 10 years as described in GA-3 long-term inspection and maintenance section above. The time required to implement GA-4 is assumed to be 10 weeks. RAOs would be met once the remedy is constructed and ICs were in place. Alternatives for Leather Material Area of Concern (See Figure 10) LMA Common Element Chromium Sampling - Sampling data from historical investigations indicate that hexavalent chromium may be present in soil and waste material. PDI soil samples would be analyzed for trivalent chromium and hexavalent chromium to fill RI data gaps for the RD.

Alternative LMA-1 – No Action

See BCA-1 No Action description.

Alternative LMA-2 – ICs LMA-2 consists of implementing ICs, as described in Common Elements for All AOCs above. This alternative has the same components and time frames as the BCA-2 alternative with a cost estimate of $129,000 NPV. RAOs would be met once ICs are in place.

Alternative LMA-3 – Capping, ICs To limit the potential for contact with the leather material and to minimize the potential for impact-to-groundwater, LMA-3 would include placing a cap over the contaminated leather material and soil present in LMA-A and LMA-B, in areas where no OU2 work was needed. Due to the potential for chromium to be present at concentrations exceeding remediation goals at

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depths deeper than two feet bgs in OU2-remediated areas, maintenance of the existing cap and cover material would be included within this Alternative. The key components for LMA-3 include:

Construction of cap; Restoration; ICs to protect the cap and cover material; Long-term inspection and maintenance; Cost: $884,000 NPV – includes investigation to delineate IC areas and assumes 30 years

of inspections, cap maintenance and NJDEP certifications; and Four weeks construction.

Construction of Cap and Restoration – Construction debris and vegetation on the surface that are not amendable to capping would be removed and transported to an off-site disposal facility, if necessary. The cap could be constructed of various materials (including soil, geomembrane, multi-layer/composite materials, concrete or asphalt) long as the cap effectively eliminates the potential for contact with the subsurface leather material. Due to Site conditions and the potential impact-to-groundwater from chromium, for the purposes of this cost estimate, placement of an asphalt cap has been assumed for the contaminated areas in LMA-A and LMA-B. A cap would be placed on top of the contaminated materials in LMA-A to eliminate the exposure pathway to human health and the environment. It is estimated that approximately 82,283 square feet of contaminated leather material (at levels exceeding remediation goals) would remain after the OU2 excavation was completed in LMA-A at a depth of two feet, although the PDI would be used to determine the actual cap location. For cost-estimating purposes, the cap would consist of three inches of asphalt placed on the ground surface. The asphalt cap would be graded to promote positive drainage and to match the existing topography. A cap would also be placed on top of the contaminated materials in LMA-B to eliminate potential exposure pathways. It is estimated that approximately 6,284 square feet of contaminated leather material (at levels exceeding remediation goals) would remain after the OU2 excavation was completed in LMA-B at a depth of two feet, although the PDI would be used to determine the actual cap location. For cost-estimating purposes, the cap would consist of three inches of asphalt placed on the ground surface. The cap would be graded to promote positive drainage and to match the existing topography. ICs – ICs as described in the Common Elements for All AOCs and to protect the cap and cover material would be implemented under LMA-3. Long-term Inspection and Maintenance – Signs and fencing may be placed in the vicinity of the capped area to provide warning and prevent intrusive activities that may compromise the cap at LMA-A and LMA-B. Both LMA-A and LMA-B would be inspected periodically to evaluate if the cap has eroded to the extent that may impact the effectiveness of the cap. If severe erosion is observed, the cap would be repaired with asphalt.

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The time required to implement the cap remedy under LMA-3 is assumed to be four weeks. This includes time for coordinating the work with active operations on and around the LMA. RAOs would be met once the remedy is constructed and ICs are in place.

Alternative LMA-4 – Excavation and Off-Site Disposal, ICs

To limit the potential for contact with the leather material and to reduce potential impacts to groundwater, LMA-4 would include the excavation and off-site disposal of contaminated leather material to two feet bgs in LMA and from the “hot spot” in LMA-A to four feet bgs. Due to the potential for chromium to be present at concentrations exceeding remediation goals at depths greater than two feet bgs in OU2-remediated areas ICs may be required. Long-term inspection and maintenance of the existing asphalt and cover material installed by USACE for OU2 would be included with this Alternative. The key components for LMA-4 include:

Excavation; Off-site disposal; Restoration; Long-term Inspection and Maintenance of the existing asphalt and cover material to

reduce the potential for leaching of chromium at deeper depths into groundwater; Cost: $3,318,000 NPV – includes investigation to establish extent of ICs and 30 years

inspection, maintenance and NJDEP certifications; and Four weeks construction.

Excavation – It is estimated that approximately 6,089 cubic yards and approximately 465 cubic yards of leather material and associated soil from LMA-A and LMA-B, respectively would be excavated to two feet bgs. It is estimated that approximately five cubic yards of leather material would be excavated from the “hot spot” in LMA-A at four feet bgs. The excavation would be conducted in sections, concurrent with backfill activities. Contaminated soil and leather material would be temporarily stockpiled on plastic sheeting or directly loaded into trucks for off-site disposal. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described in Alternative GA-4. Restoration – After excavation and removal of contaminated leather material and soil, confirmatory post excavation samples would be collected. Samples would be analyzed for SVOCs and metals. Based on laboratory data and comparison with the Site remediation goals, additional excavation may be required. Once final excavation work is completed, the excavation in LMA-A and LMA-B would be backfilled to grade with clean fill and covered with three inches of asphalt and graded to match the topography of surrounding areas. Long-term Inspection and Maintenance – Due to the potential for chromium to be present at depths greater than two feet bgs in OU2-remediated areas at concentrations exceeding remediation goals, long-term inspection and maintenance of the asphalt and cover at LMA-A and LMA-B would be implemented to ensure that the cap provides continuous protection of human

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health and the environment. Both LMA-A and LMA-B would be inspected annually and after each major storm event to evaluate if the capping has been damaged to the extent that may impact the effectiveness of the cap. If severe cap erosion is observed, the cap would be repaired. The time required to implement the excavation and off-site disposal under LMA-4 is assumed to be six weeks. This includes time for coordinating the work around ongoing operations at the LMA. RAOs would be met once the remedy is constructed and ICs, are in place. Alternatives for Former Aromatics Area of Concern (See Figure 11)

Alternative FAA-1 - No Action See BCA-1 No Action description.

Alternative FAA-2 - ICs FAA-2 consists of implementing ICs, as described in the Common Elements for All AOCs above. This alternative has the same components and time frames as the BCA-2 alternative with a cost estimate of $116,000 NPV. RAOs would be met once ICs are in place.

Alternative FAA-3 – Excavation and Off-Site Disposal

FAA-3 includes the excavation and off-site disposal of the contaminated soil from zero to six feet bgs in the FAA AOC The key components for FAA-3 include:

Excavation; Off-site disposal; Restoration; Cost: $1,805,000; and Four to six weeks construction.

Excavation – The remaining contaminated area in the FAA AOC would be excavated to the water table which is at approximately six feet bgs. It is estimated that approximately 3,220 cubic yards of unsaturated contaminated soil would be excavated from the AOC. This estimate also includes excavation of contaminated soil from the vicinity of subsurface utilities and/or structures. The excavation would be conducted in sections, concurrent with backfill activities. Excavation methods would be chosen based on the clearance of utilities, and subsurface obstructions in the proposed excavation area. The FAA is currently an unused open area covered with crushed stone or vegetated soil. Vegetated soil and debris, if any, would be removed initially using suitable equipment. Crushed stone would be removed using suitable excavation equipment and stockpiled in an area free of remedial activities, possibly to the north of the FAA AOC, and may be used as backfill if suitable. Subsurface soil in the vicinity of utilities or structures would be removed by “air-knife” or vacuum excavation (or other suitable excavation method, such as hand-digging). Vacuum excavation uses a high velocity air lance to inject the air stream into the pores and fissures of the soil which then blows the soil particles apart. A

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powerful vacuum hose follows the air lance and vacuums up the soil particles, and cleans out the hole for visual inspection. All of the spoils are vacuumed and are deposited into a holding tank. Conventional excavation methods and equipment will be used to remove soil in areas free of subsurface obstructions in the FAA. Dewatering is not anticipated and has not been included in cost estimates. Off-Site Disposal – Waste characterization sampling will be completed to satisfy disposal facility requirements, as described in Alternative GA-4. In addition the spoils from the holding tank would be disposed of at an off-site disposal facility based on the waste characterization results. Restoration – After excavation and removal of contaminated soil, confirmatory post-excavation samples would be collected and analyzed for VOCs. Based on laboratory data and comparison with the Site remediation goals, additional excavation may be required. Once final excavation work is confirmed, the excavation in FAA would be backfilled with clean fill and either covered with three inches of asphalt and or restored with topsoil and vegetation in keeping with pre-construction conditions. FAA-3 is estimated to be completed in approximately four to six weeks. RAOs would be met once construction is completed.

Alternative FAA-4 – In Situ Enhanced Fluid Recovery (EFR) and Excavation with Off-Site Disposal

To reduce the mass of BTEX contaminants in the unsaturated soil, FAA-4 would include enhanced fluid recovery (EFR) that would extract soil vapor from the unsaturated zone (zero to five feet bgs) via newly installed wells in the FAA. EFR is typically used for dual phase recovery of contaminated groundwater or free product and soil vapor; in this alternative, the media of concern is the unsaturated soil. Groundwater and saturated soil would be addressed in OU4. The installation of the EFR wells may be difficult in the vicinity of utilities, and the presence of utilities may create a short circuit in the vacuum making EFR less effective; therefore, excavation, as described in the Alternative FAA-3, would be applied in the vicinity of subsurface utilities located in the northwestern and southern quadrants of the remediation area and in the vicinity of a concrete pit located in the western quadrant of the FAA. It is assumed that the presence of utilities in the remaining areas of the AOC would not significantly affect the implementability of EFR. The key components for FAA-4 include:

Pilot Study; Excavation and off-site disposal of soil in the vicinity of utilities; EFR installation of 110 shallow wells and operation of EFR for a period of approximately

five years; Restoration; Long-term inspection and maintenance; Cost: $3,440,000 – includes 5 years of monthly operation and evaluation; and Three months construction

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Pilot Study – A pilot study would be conducted to obtain design parameters for the EFR including but not limited to, radius of influence, number of wells, wellhead vacuum, extraction flow rate, discharge limitations and off-gas treatment requirements, if any. The pilot study would also attempt to evaluate the feasibility and effectiveness of this technology to treat unsaturated soil alone. Excavation – It is estimated that approximately 900 cubic yards of BTEX-contaminated soil would be excavated from the vicinity of subsurface utilities and a concrete pit to a depth of six feet bgs. The excavation would be conducted in sections, concurrent with backfill activities. Excavation methods would be chosen based on the clearance of utilities and subsurface obstructions in the proposed excavation area. The FAA is currently an unused open area covered with crushed stone or vegetated soil. Vegetated soil and debris, if any, would be removed initially using conventional equipment. Crushed stone would be removed using suitable excavation equipment and stockpiled in an area free of remedial activities, possibly to the north of the FAA AOC, and maybe used as backfill if suitable. Dewatering is not anticipated and has not been included in cost estimates. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described for Alternative FAA-3 EFR –EFR is a portable system that would extract soil vapor from designated extraction wells installed in selected areas of the FAA. Existing monitoring wells would not be used. FAA-4 would include the installation of an estimated 110 extraction wells, each to a depth of five feet bgs and placed every 10 feet on center spacing. The actual number of EFR wells and well spacing would be determined during the design and remedial action phases. Since the EFR is a portable system, no above-ground piping would need to be installed. A surface seal consisting of an asphalt cover would be installed during Site restoration to prevent surface water infiltration that can reduce air flow rates, reduce emissions of fugitive vapors, prevent vertical short-circuiting of air flow or increase the design radius of influence. For cost-estimating purposes, asphalt paving is assumed. It is also assumed that the Site would be inspected annually to evaluate the integrity of the asphalt cover. If cracks in the cover are observed, asphalt may be brought to the Site to repair the cover. These costs are considered as operational costs and are included as such in the cost estimates. No dewatering would be performed and is not considered in the cost estimates. The well head of each extraction point would be sealed, and an applied vacuum ranging from approximately 15 to 20 inches of mercury would be applied to extract soil vapors on a monthly basis for a period of five years Extracted vapors would be treated on-site in accordance with NJDEP and EPA requirements prior to release to the atmosphere. Vacuum readings would be collected throughout the duration of each EFR event to determine the vapor extraction capture zone. In addition, the vapor effluent would be field-monitored to

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confirm that hydrocarbons are being extracted from the subsurface, with periodic laboratory testing to evaluate the performance of the system. Due to potential vapor intrusion issues and for cost-estimating purposes, soil gas and indoor air samples would be collected inside Building 67 prior to implementation of the EFR to determine any impacts, and on an annual basis thereafter to evaluate the indoor air quality and thereby the effectiveness of the EFR. Restoration – For cost-estimating purposes, it is assumed that the utility areas that require excavation would be backfilled to grade with clean fill and the entire FAA area would be covered with three inches of asphalt to provide a surface seal for the EFR, and graded to promote positive drainage and to match the existing topography. After implementation of the alternative is completed, confirmatory soil samples would be collected to evaluate the effectiveness of the excavation and EFR remedy. Samples would be analyzed for VOCs. Long-term Inspection and Maintenance –The conventional construction work is assumed to take approximately three months. A long-term inspection, operation, maintenance and evaluation program would be established. The Site would be inspected annually to evaluate the integrity of the asphalt cover. If cracks in the cover are observed, asphalt may be brought to the Site to repair the cover. RAOs would be met once the excavation and EFR treatment are complete.

Alternative FAA-5 – In Situ Soil Vapor Extraction (SVE), Excavation with Off-Site Disposal, ICs

To reduce the mass of BTEX contaminants in the unsaturated soil, FAA-5 would include the installation of a SVE system that would extract soil vapor from the unsaturated zone via select extraction wells in the FAA. As with Alternative FAA-4, limited effectiveness of SVE near subsurface structures would result in excavation in the vicinity of subsurface utilities located in the northwestern and southern quadrants of the remediation area and in the vicinity of a concrete pit located in the western quadrant of the FAA. It is assumed that the presence of utilities in the remaining areas of the AOC would not significantly affect the implementability of the SVE. The key components for FAA-5 include:

Pilot Study; Excavation and off-site disposal of soil in the vicinity of utilities; SVE - installation of 13 shallow horizontal wells and installation and operation of a vapor

collection/treatment system; Restoration; Long-term Inspection and Maintenance; Cost: $1,793,000 -- includes 5 years SVE operation, maintenance and evaluation; and Three months construction.

Pilot Study – A pilot study would be conducted to obtain design parameters for the SVE including but not limited to, radius of influence, number of wells, wellhead vacuum, extraction flow rate, discharge limitations and off gas treatment requirements, if any. If the pilot study does

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not demonstrate that SVE technology is feasible for the Site conditions, the FAA-3 excavation alternative would be implemented. Excavation – It is estimated that approximately 900 cubic yards of BTEX-contaminated soil would be excavated to a depth of six feet bgs from the vicinity of subsurface utilities and a concrete pit, as described for FAA-4. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described for Alternative FAA-3 SVE – SVE is an in situ remedial technology that reduces VOC concentrations adsorbed to soil in the unsaturated zone through designated extraction trenches or wells installed in selected areas of the FAA. The extracted vapors are then treated, as necessary, and discharged to the atmosphere. Groundwater is anticipated at six feet bgs. The depth to groundwater in the overburden has historically ranged from 5.5 to 10.4 feet bgs with seasonal fluctuations generally within one foot. For areas with shallow groundwater tables, SVE trenches are generally preferable to wells due to less potential for groundwater table upwelling and increased area of influence. However, horizontally drilled extraction wells are more efficient and are also less likely to short-circuit to the atmosphere than those installed by trenching, since the soil column is not disturbed during the installation process. For this reason, horizontal extraction wells have been considered for the Site. For cost estimating purposes, the SVE would focus on a treatment zone of zero to four feet bgs based upon the depth of water anticipated for the FAA and accounting for seasonal fluctuations. FAA-5 would include the installation of 13 horizontal extraction wells at approximately four feet bgs so that normal groundwater table fluctuations do not submerge a portion of the extraction well screen, making it unavailable for air flow. The horizontal extraction wells would consist of slotted polyvinyl chloride (PVC) piping and would be installed using horizontal directional drilling. Each extraction well would be placed every ten feet on center spacing. This ten-foot spacing, which assumes a five-foot radius of influence, is based on the silty to clayey nature of the Site soil as well as communication with vendors. The actual number of SVE wells, and the well spacing would be better determined during the design and remedial action phases. Vacuum pressures would be monitored via performance monitoring points. Manifold piping would connect the extraction wells to an extraction blower. Piping is assumed to be placed below grade. A surface seal consisting of an asphalt cover would be installed during Site restoration to prevent surface water infiltration that can reduce air flow rates, reduce emissions of fugitive vapors, prevent vertical short-circuiting of air flow, or increase the design radius of influence. For cost-estimating purposes, asphalt paving is assumed. It is also assumed that the Site would be inspected to evaluate the integrity of the asphalt cover, and that the cover would be repaired as necessary. These costs are considered as operational costs and are included as such in the cost estimates. No dewatering would be performed and is not considered in the cost estimates. The well head of each extraction point would be sealed, and a vacuum would be applied to extract soil vapors continuously. It is assumed that the extracted vapors would require treatment

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prior to discharge to the atmosphere. The vapor treatment system considered for cost estimates is a granular activated carbon (GAC) unit. The treated vapors would be vented to the atmosphere with an air permit, if required. Monitoring the performance of the SVE system in reducing contaminant concentrations in soil is necessary to determine if remedial progress is proceeding as anticipated. For cost-estimating purposes, it is assumed that vapor effluent samples would be collected from the system on a monthly basis and analyzed for VOCs to monitor off-gas concentrations. Due to potential vapor intrusion issues and for cost purposes, soil gas and indoor air samples would be collected inside Building 67 prior to implementation of the SVE to determine any impacts and periodically thereafter to evaluate the indoor air quality and thereby the effectiveness of the SVE system. Restoration – For cost-estimating purposes it is assumed that the excavated areas would be backfilled to grade with clean common fill and the entire FAA area would be covered with three inches of asphalt to provide a surface seal for the SVE, and graded to promote positive drainage and to match the existing topography. After implementation of the alternative is completed, confirmatory soil samples would be collected to evaluate the effectiveness of the excavation and SVE remedy. Samples would be analyzed for VOCs. Long-term Inspection and Maintenance –The conventional construction work is assumed to take approximately three months. The goal of the treatment system is to reduce unsaturated soil concentrations to below the remediation goals, and it has been estimated that the SVE system would need to operate for about five years to achieve this. A long-term inspection and maintenance program would be established. The Site would be inspected annually to evaluate the integrity of the asphalt cover. If cracks in the cover are observed, asphalt may be brought to the Site to repair the cover. RAOs would be met once the excavation and SVE treatment are complete. Alternatives for Central Tank Farm Area of Concern (See Figure 12) CTFA Common Element If product is detected, soil samples would also be collected for Total Petroleum Hydrocarbon (TPH) analysis.

Alternative CTFA-1 - No Action See BCA-1 No Action description.

Alternative CTFA-2 - ICs See FAA-2 ICs description.

Alternative CTFA-3 – Excavation and Off-Site Disposal, ICs

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CTFA-3 would include the excavation and off-site disposal of the contaminated soil a depth of seven feet bgs in the CTFA AOC. The key components for CTFA-3 include:

Excavation and off-site disposal; Restoration; ICs if contamination remains near Building 10; Long-term inspection and maintenance; Cost: $1,017,000 NPV –includes 30 years of inspection and NJDEP certification; and Two to three weeks construction.

Excavation – The contaminated area in the CTFA AOC would be excavated to the water table which is at approximately seven feet bgs. It is estimated that approximately 800 cubic yards of BTEX-contaminated soil from the AOC would be excavated. This estimate also includes contaminated soil from the vicinity of subsurface utilities and/or structures. Due to the proximity of the CTFA AOC to Building 10, shoring would be provided along the excavation. The excavation would be conducted in sections, concurrent with backfill activities. Excavation methods would be chosen based on the clearance of utilities, and subsurface obstructions in the proposed excavation area. Considerations would need to be made for interruption of facility operations in the CTFA, and temporary facilities may be required depending upon plant and remedial schedules. Debris and pavement, if present, would be removed initially using suitable excavation equipment. Subsurface soil in the vicinity of utilities would be removed using techniques described for FAA-3. Conventional excavation methods and equipment would be used to remove soil in areas free of subsurface obstructions in the CTFA. The excavated soil would be directly loaded to lined trucks for off-site disposal. Dewatering is not anticipated and has not been included in cost estimates. Any free product encountered during excavation to the water table would be removed and disposed off-site. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described in Alternative FAA-3. Site Restoration – After excavation and removal of contaminated soil, confirmatory post-excavation samples would be collected and analyzed for VOCs. Based on laboratory data and comparison with the Site remediation goals, additional excavation may be required. Once final excavation work is completed, the excavation in CTFA would be backfilled to grade with clean fill and covered with three inches of asphalt and graded to match the topography of surrounding areas. Institutional Controls –Excavation near Building 10 may be limited due to structural integrity concerns and it is possible that contaminated soil in the immediate vicinity of Building 10 exceeding remediation goals would remain in place. Restricting land use from any intrusive activities would be necessary. A deed notice would be placed on the CTFA residual

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contamination area to restrict future intrusive activities that would disturb the cover and expose construction workers or future land users to contaminants at levels that may pose human health risks. Long-term Inspection and Maintenance – The conventional construction work is estimated to take approximately two to three weeks. A long-term inspection and maintenance program would be established if contaminated material is left in place near Building 10. The Site would be inspected annually to evaluate the integrity of the protective cover. RAOs would be met once the construction is completed and the IC is in place, if needed.

Alternative CTFA-4 – In Situ Enhanced Fluid Recovery (EFR) and Excavation with Off-Site Disposal, ICs

To reduce the mass of BTEX contaminants in the unsaturated soil, CTFA-4 would include a portable EFR system that would extract soil vapor from the unsaturated zone (zero to six feet bgs) via newly installed vertical wells in the CTFA. The EFR technology is described for Alternative FAA-4. The presence of utilities may create a short circuit in the vacuum and as such it is unlikely that the EFR would be effective in achieving a large enough radius of influence to extend around utilities. Therefore, it is proposed that vacuum excavation be applied in the vicinity of subsurface utilities and/or structures located in the north-northeastern quadrants of the remediation area in CTFA, as described for Alternative FAA-3. It is assumed that the presence of utilities in the remaining areas of the AOC would not significantly affect the implementability of the EFR. The key components for CTFA-4 include:

Pilot Study; Excavation and off-site disposal of soil in the vicinity of utilities; EFR – 32 new shallow extraction wells; Restoration; Long-term Inspection, maintenance and evaluation; Cost: $ 1,548,000 NPV – includes an estimated five years of monthly EFR events; and 10 weeks construction.

Pilot Study – A pilot study would be conducted to obtain design parameters for the EFR, as described for FAA-4. Excavation – The contaminated soil in the north-northeastern quadrant of the remaining contaminated area in the CTFA AOC would be excavated to the water table which is anticipated at seven feet bgs. It is conservatively estimated that approximately 500 cubic yards of BTEX-contaminated soil would be excavated from the vicinity of utilities/subsurface structures as described for FAA-3. The excavation would be conducted in sections, concurrent with backfill activities. Excavation methods would be chosen based on the clearance of utilities, and subsurface obstructions in the proposed excavation area. Considerations would need to be made for interruption of facility operations in the CTFA, and temporary facilities may be required depending upon plant and remedial schedules. Debris and pavement, if present, would be

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removed initially using suitable excavation equipment. Dewatering is not anticipated and has not been included in cost estimates. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described for Alternative FAA-3. EFR –. The EFR is a portable system that would extract soil vapor from designated wells installed in selected areas of the CTFA, this technology is described for FAA-4. CTFA-4 would include the installation of 32 vertical extraction wells, each to a depth of six feet bgs and placed every ten feet on center spacing. Due to potential vapor intrusion issues and for cost purposes, soil gas and indoor air samples will be collected using Summa canisters inside Building 10 prior to implementation of the EFR to determine any impacts and on an annual basis thereafter to evaluate the indoor air quality and thereby the effectiveness of the EFR. Restoration – As a portion of the CTFA is currently asphalt, for cost purposes, it is assumed that the excavated areas would be backfilled to grade with clean fill and covered with three inches of asphalt, and graded to promote positive drainage and to match the existing topography. After implementation of the alternative is completed, confirmatory soil samples would be collected to evaluate the effectiveness of the excavation and EFR remedy. Samples would be analyzed for VOCs. Long-term Inspection and Maintenance – Since contamination in soil where the EFR alone is implemented, may still pose human health risks until remediation goals are met, a land use restrictions would restrict any intrusive activities. Conventional construction work is assumed to take approximately ten weeks. A long-term inspection and maintenance program would be established. The Site would be inspected annually to evaluate the integrity of the asphalt cover. If cracks in the cover are observed, asphalt may be brought to the Site to repair the cover. RAOs would be met once the EFR treatment is completed.

Alternative CTFA-5 – In Situ Soil Vapor Extraction (SVE) and Excavation with Off-Site disposal, ICs

To reduce the mass of BTEX contaminants in the unsaturated soil, CTFA-5 would include the installation of a SVE system that would extract soil vapor from the unsaturated zone via select extraction wells in the CTFA, this technology is described for FAA-5. Due to technical difficulties with installing SVE components in the vicinity of utilities, excavation would be implemented in the vicinity of subsurface utilities and/or structures located in the north-northeastern quadrants of the remediation area in the CTFA, as described for FAA-3. It is assumed that the presence of utilities in the remaining areas of the AOC would not significantly affect the implementability of the SVE. The key components for CTFA-5 include:

Pilot Study; Excavation and off-site disposal of soil in the vicinity of utilities;

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SVE – installation of three shallow horizontal wells; Restoration; Long-term inspection and maintenance; Cost: $ 1,220,000 NPV – estimated five years of SVE operation; and 10 weeks construction.

Pilot Study – A pilot study would be conducted to obtain design parameters for the SVE, as described for FAA-5. Excavation – The contaminated soil in the CTFA would be excavated as described for CTFA-4. Off-Site Disposal – Waste characterization sampling would be completed to satisfy disposal facility requirements, as described for FAA-3. SVE – SVE is an in situ remedial technology that reduces VOC concentrations adsorbed to soil in the unsaturated zone through designated extraction wells installed in selected areas of the CTFA. The extracted vapors are then treated, as necessary, and discharged to the atmosphere. Groundwater is at approximately seven feet bgs. Due to a shallow vadose zone, horizontal wells or trenches would be used instead of vertical wells. CTFA-5 would include the installation of three horizontal extraction wells at approximately five feet bgs so that normal groundwater table fluctuations do not submerge a portion of the extraction well screen, making it unavailable for air flow. The SVE technology, construction, operation and maintenance are described for FAA-5. Due to potential vapor intrusion issues and for cost purposes, soil gas and indoor air samples would be collected using Summa canisters inside Building 10 prior to implementation of the SVE to determine any impacts and on an annual basis thereafter to evaluate the indoor air quality and thereby the effectiveness of the SVE system. Restoration – See CTFA-4. As a portion of the CTFA is currently asphalt, for cost purposes, it is assumed that the excavated areas would be backfilled to grade with clean fill and covered with three inches of asphalt, and graded to promote positive drainage and to match the existing topography. After implementation of the alternative is completed, confirmatory soil samples would be collected to evaluate the effectiveness of the excavation and SVE remedy. Samples would be analyzed for VOCs. Long-term Inspection and Maintenance – Since contamination in areas where the SVE alone is implemented may still pose human health risks, a land use restriction would be required to restrict any intrusive activities. Conventional construction work is assumed to take approximately ten weeks. A long-term inspection and maintenance program would be established. The Site would be inspected annually to evaluate the integrity of the asphalt cover. If cracks in the cover are observed, asphalt may be brought to the Site to repair the cover. RAOs would be met once the SVE treatment is completed.  

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COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES FOR EACH AOC  

In selecting a remedy, EPA considered the factors set out in CERCLA §121, 42 U.S.C. §9621, by conducting a detailed analysis of the viable remedial response measures pursuant to the NCP, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual response measure using the nine evaluation criteria set forth under 40 CFR §300.430(e)(9) and (f)(1) and in the FS report. This section profiles the relative performance of each alternative against the nine criteria, noting how it compares to the other alternatives under consideration. A summary of this comparative analysis for each source area is presented in Tables 7 through 11. Threshold Criteria - The first two criteria are known as "threshold criteria" because they are the minimum requirements that each response measure must meet to be eligible for selection as a remedy. 1. Overall Protection of Human Health and the Environment Overall protection of human health and the environment addresses whether each alternative provides adequate protection of human health and the environment and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and/or institutional controls. Buried Container Area- All of the alternatives except BCA-1 and BCA-2 protect human health and the environment. Potential risks from direct contact, inhalation and migration of soil contaminants, including impacts to groundwater, are addressed by BCA-3 and BCA-4. Alternatives, BCA-2, BCA-3 and BCA-4, all include implementation of ICs to restrict future development of the Site to non-residential uses. However, BCA-2 would not address potential impacts to groundwater. Under BCA-4, buried containers and contaminated soil would be removed, thus eliminating the potential source of the contamination. Gypsum Area - All of the alternatives except the no action alternative (GA-1) provide protection of human health and the environment. Risks from direct contact of contaminated soil and gypsum material are addressed by the institutional controls alternative (GA-2), but this alternative does not address potential impacts to groundwater, and would not be protective in the long-term. Impacts from direct contact and migration of contaminants to groundwater from the gypsum material are addressed by GA-3 and GA-4. Exposure risks are slightly lower under GA-4 compared to GA-3 because the gypsum material and contaminated soil would be permanently removed from the Site. Both the GA-3 and GA-4 alternatives include implementation of institutional controls to restrict future development of the Site to non-residential uses. Under GA-4, the gypsum material and contaminated soil would be removed, eliminating the source of cyanide leaching into the groundwater and protect the environment.

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Leather Materials Area - LMA-1 would not protect human health and the environment. LMA-2 does not address potential impacts to groundwater and would not be protective in the long-term. LMA-3, capping, would provide human health and the environment than LMA-2. LMA-4 would provide overall protection of human health and the environment, with the removal of the remaining contaminated leather material and soil. Former Aromatics Area - FAA-1 would not protect human health and the environment. FAA-2 would provide short-term protection to human health but would not achieve the RAOs and does not address potential impacts to groundwater, therefore it is not protective over the long-term. FAA-3 would provide overall protection of human health and the environment via removal of contaminated soil from the FAA AOC. FAA-4 and FAA-5 would also provide overall protection of human health and the environment through a combination of contaminated soil treatment and removal.  

Central Tank Farm Area - CTFA-1 would not protect human health and the environment and would not meet the RAOs. CTFA-2 would provide protection of human health but would not achieve the RAOs for impacts to groundwater. CTFA-3 would provide overall protection of human health and the environment via removal of contaminated soil from the CTFA AOC. CTFA-4 and CTFA-5 would also provide overall protection of human health and the environment through a combination of contaminated soil treatment and removal. 2. Compliance with ARARs Section 121 (d) of CERCLA and NCP §300.430(f)(1)(ii)(B) require that remedial actions at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State requirements, standards, criteria, and limitations which are collectively referred to as "ARARs," unless such ARARs are waived under CERCLA section 121(d)(4). Applicable requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site. Only those State standards identified by a state in a timely manner and that are more stringent than Federal requirements may be applicable. Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well-suited to the particular site. Only those State standards that are identified in a timely manner and are more stringent than Federal requirements may be relevant and appropriate. Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and State environmental statutes or provides a basis for invoking a waiver.

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Buried Container Area - The no action BCA-1 alternative would not comply with ARARs. The institutional control BCA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs the New Jersey Non-Residential Direct Contact Soil Remediation Standards (N.J.A.C.7:26D). The in situ solidification BCA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through stabilization and capping with ICs to protect the cap and stabilized material. BCA-3 would also prevent contaminant migration and satisfy NJDEP’s impact-to-groundwater criteria. The excavation and disposal BCA-4 alternative would comply with ARARs by removing contaminated soil. The BCA-3 and BCA-4 alternatives would comply with location-specific New Jersey wetlands requirements. A list of ARARs for the Site can be found in Table 12. Gypsum Area- The no action GA-1 alternative would not comply with ARARs. The institutional control GA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The in situ solidification GA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through stabilization and capping with ICs to protect the cap and stabilized material. GA-3 would also prevent contaminant migration and impacts to groundwater. The excavation and disposal GA-4 alternative would comply with ARARs by removing contaminated soil. The GA-3 and GA-4 alternatives would also comply with location-specific New Jersey wetlands requirements. Leather Materials Area - The no action LMA-1 alternative would not comply with ARARs. The institutional control LMA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The in situ solidification LMA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through capping with ICs to protect the cap and leather material. LMA-3 would also prevent contaminant migration and impacts to groundwater. The excavation and disposal LMA-4 alternative would comply with ARARs by removing contaminated soil. The LMA-3 and LMA-4 alternatives would also comply with location-specific New Jersey wetlands requirements. Former Aromatics Area - The no action, FAA-1 alternative would not comply with ARARs. The institutional control FAA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The FAA-3 excavation and disposal alternative would comply with ARARs by excavating the contaminated soil down to the water table and disposing of this material off site. The FAA-4 and FAA-5 vapor treatment alternatives would also comply with ARARs for VOCs in soil and impacts to groundwater. FAA-3 through FAA-5 would meet the action-specific ARARs by following waste handling and disposal regulations, as applicable. Central Tank Farm Area - CTFA-1 would not comply with the ARARs and does not address potential impacts to groundwater. CTFA-2 would not meet chemical-specific ARARs, although it would prevent future residential-use soil exposure since currently most of the CTFA contamination is located beneath asphalt which acts as a cap. CTFA-3 would comply with

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ARARs by removing contaminated soil above the water table. CTFA-4 and CTFA-5 would comply with ARARs direct contact with VOCs in soil and impact-to-groundwater criteria. CTFA-3, CTFA-4 and CTFA-5 would comply with the action-specific ARARs by following the waste handling and disposal regulations.

Primary Balancing Criteria - The next five criteria, criteria 3 through 7, are known as "primary balancing criteria." These criteria are factors with which tradeoffs between response measures are assessed so that the best option will be chosen, given site-specific data and conditions. 3. Long-Term Effectiveness and Permanence Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once clean-up levels have been met. This criterion includes the consideration of residual risk that will remain on site following remediation and the adequacy and reliability of controls. Buried Container Area - BCA-4 would provide the highest degree of long-term effectiveness and permanence. Under BCA-4, buried containers, associated waste materials and contaminated soil would be permanently removed from the Site. BCA-3 provides the next highest degree of long-term effectiveness. Under BCA-3, buried containers and contaminated materials would be removed from the Site and all other remaining contaminated soil would be either solidified in place or capped. Remaining contaminated soil above the groundwater table would be covered with a cap which would effectively prevent human exposure and minimize infiltration. Remaining contaminated soil in proximity to or below the groundwater table would be treated with in situ solidification. In situ solidification would immobilize contaminants in the soil which would reduce the material’s permeability and its potential for leaching contaminants into the groundwater. The long-term effectiveness and permanence of in situ solidification is dependent on the proper selection of reagents and mixing ratios. If proper mixing during installation does not occur, this may affect the long-term effectiveness and permanence of the treatment. The long-term effectiveness and permanence of the cap is directly related to the inspection and maintenance program. Annual inspections would be a key component of the alternatives to verify the continued integrity of the cap and ensure defects are repaired as needed to maintain an effective barrier to underlying soil. BCA-1 would provide the lowest and BCA-2 would provide the next lowest long-term effectiveness since BCA-1 would not prevent exposures to soil contaminants in the vegetated area east of the building. Gypsum Area - GA-4 would provide the highest degree of long-term effectiveness and permanence. Under GA-4, gypsum material and contaminated soil would be permanently removed from the Site. GA-3 provides the next highest degree of long-term effectiveness. Under this alternative, the gypsum material would be solidified, which reduces potential leaching of contaminants to groundwater. The solidified material would be protected with a soil cap and institutional controls would be implemented to prevent human contact with the solidified material. The long-term effectiveness and permanence of the in situ solidified material is dependent on the proper selection of reagents and mixing ratios. If proper mixing during installation does not occur, this could affect the long-term effectiveness and permanence of the treatment. Routine maintenance of the cover would be necessary to provide continued protection

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of the solidified material from weathering and human activities. GA-1 and GA-2 would not provide for long-term effectiveness or permanence. Leather Materials Area - LMA-1 would not be effective in the long term since no remedial action would be performed. LMA-4 provides the highest degree of long-term effectiveness and permanence because the impacted leather material and soil would be permanently removed from the Site. LMA-3 would provide long-term effectiveness if the asphalt and soil cap are maintained. Institutional controls, long-term inspection and maintenance would need to be implemented and enforced to ensure continued protection of human health and the environment under LMA-2, LMA-3 and LMA-4. Former Aromatics Area - FAA-1 would not be effective in the long term since no remedial action would be performed. FAA-2 would effectively reduce the longer term risks by eliminating the potential for direct contact by restricting land use, if institutional controls are maintained and enforced. However, impacts to groundwater would not be addressed. FAA-3 would permanently remove contaminants in soil to groundwater surface and is therefore most effective. FAA-4 and FAA-5 would permanently remove BTEX contamination and are estimated to achieve the RAOs. FAA-5’s SVE technology is used for unsaturated soil, while FAA-4’s EFR technology is typically used in dual phase remediation and may not be as effective as SVE. Institutional controls and long-term inspection and maintenance would ensure continued protection of human health and the environment under FAA-2 through FAA-5. Central Tank Farm Area - The no action CTFA-1 alternative would not be effective in the long term, because contamination could be exposed to receptors, migrate and impact groundwater. CTFA-2 would effectively reduce the longer term risks by eliminating the potential for direct contact by restricting land use, if institutional controls are maintained and enforced. However, impacts to groundwater would not be addressed. CTFA-3 would permanently remove contaminants in soil to the top of the water table and therefore provides the greatest degree of long-term effectiveness. CTFA-4 and CTFA-5 would permanently remove BTEX contamination; but the time to implement the remedy would be longer in comparison with CTFA-3. Institutional controls and long-term inspection and maintenance would ensure continued protection of human health and the environment in the long term under CTFA-2 through CTFA-5. 4. Reduction of Toxicity, Mobility, Volume of Contamination through Treatment  

Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the treatment technologies that may be included as part of a remedy. Buried Container Area - BCA-3 is the only alternative that would provide a reduction in mobility of the contaminants through treatment by solidifying contaminated soil located in proximity to, or below, the groundwater table. BCA-3 and BCA-4 may require ex situ treatment if contents of buried containers and associated contaminated soil are determined to be hazardous and do not meet Land Disposal Restriction (LDR) requirements. This could potentially reduce contaminant mobility, but would not reduce toxicity or volume of contamination. BCA-2 and BCA-1 provide no reduction of toxicity, mobility, or volume of contamination through treatment.

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Gypsum Area - GA-3 is the only alternative that would provide a reduction in mobility and toxicity of the hazardous constituents through treatment by solidifying the gypsum material and contaminated soil. GA-4 would not provide reduction of toxicity and volume of the contaminated materials through treatment but simply would move the materials from the AOC to a facility where mobility would be reduced. GA-4 may provide some reduction in toxicity and mobility through treatment if it is determined through waste characterization sampling that the gypsum material requires treatment prior to disposal. GA-2 and GA-1 provide no reduction of toxicity, mobility, or volume of contamination through treatment. Leather Materials Area - LMA-1 and LMA-2 would not address toxicity, mobility, and volume of the contaminated area through treatment. LMA-3 would reduce the mobility, but would not reduce the toxicity or volume of source areas through treatment. LMA-4 would not provide reduction of toxicity and volume of the contaminated materials through treatment, but simply would move the materials from the AOC to a facility where mobility would be reduced. Former Aromatics Area - FAA-1 and FAA-2 would not address contaminant toxicity, mobility and volume of source areas through treatment. Excavation under FAA-3 through FAA-5 would not provide reduction of toxicity and volume of the contaminated soil through treatment but simply would move the materials from the AOC to a facility where mobility would be reduced. FAA-4 and FAA-5 would provide a reduction in BTEX contaminated soil during the five years of active vapor treatment. Central Tank Farm Area - CTFA-1 and CTFA-2 would not address toxicity, mobility, and volume of source areas through treatment, although natural degradation could potentially reduce contaminant toxicity and volume over time. Excavation under CTFA-3 through CTFA-5 would not provide reduction of toxicity and volume of the contaminated soil through treatment but would move the materials from the AOC to a facility where mobility would be reduced. CTFA-4 and CTFA-5 would provide a reduction in BTEX-contaminated soil during the five years of active vapor treatment.

5. Short-Term Impacts and Effectiveness Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse impacts that may be posed to workers, the community and the environment during construction and operation of the remedy until remediation goals are achieved. Buried Container Area - BCA-3 and BCA-4 would result in some disruption to the Site during remedy implementation. During implementation of either of these alternatives dust control and air monitoring programs would be required to address potential exposures to commercial workers and the surrounding community resulting from extensive soil handling and temporary storage (i.e. temporary stockpiling, sifting for buried containers) which has the greatest potential to generate dust. Of these two alternatives, BCA-4 would have the highest short-term impacts since this alternative is assumed to take the longest to implement and has the potential to generate the most amount of traffic. Under BCA-4, if direct loading (placing excavated materials directly into a shipping container) of contaminated materials is possible, the impacts may be slightly lowered since direct loading could eliminate the need to temporarily stockpile

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contaminated soil on Site; this would be evaluated during the remedial design. Under BCA-3 temporary stockpiling of contaminated soil would be required in order to remove buried containers from the excavated areas. BCA-2 would have minimal impacts compared to BCA-3 and BCA-4. Potential impacts and mitigation measures would be identified during design. BCA-1 would have no short-term impacts. Gypsum Area - GA-4 would have the highest short-term impacts since this alternative has the highest potential to generate dust which could increase contaminant exposure to workers, the community and surrounding properties. The volume of material requiring off-site disposal would generate vehicle movement and truck traffic for a majority of the duration of construction, estimated to take one to two months. GA-3 would also present short-term impacts, but not to the degree of those in GA-4, since solidification would be in situ. Also, contaminated materials and reagents used in GA-3 would be moist, which could reduce the potential to generate dust and airborne particles during remedy implementation. Truck traffic would not be as significant under GA-3 as under GA-4, since less material would require off-site disposal. Both GA-3 and GA-4 would have short-term impacts to the wetland and would, therefore, require restoration or mitigation. Impacts associated with GA-3 may be greater since placement of stabilized materials having lower hydraulic conductivities than that of existing soil would reduce infiltration and potentially cause water levels in the wetland to rise, resulting in impacts to existing vegetation and wildlife. Both GA-3 and GA-4 would be effective at reducing potential human health exposure to contaminated media and impacts to groundwater. GA-4 would have the highest degree of effectiveness since this alternative would remove the gypsum material which is the source of cyanide contamination. GA-2 would have minimal impacts compared to GA-3 and GA-4, consisting only of sampling necessary to delineate the IC area, while GA-3 and GA-4 would have construction impacts. GA-1 would have no short-term impacts.

Leather Materials Area - LMA-1 and LMA-2 would not have short-term impacts since no intrusive action would be implemented. LMA-3 and LMA-4 would have some impacts to the community and workers during the construction period. LMA-4 would have a greater impact to the community compared to LMA-3 due to the larger amount of truck traffic needed for off-site disposal of contaminated materials. Former Aromatics Area - FAA-1 and FAA-2 would not have any short-term impacts because no intrusive actions would be implemented. FAA-3 through FAA-5 would have some impacts to the community and workers during the construction period. FAA-3 would have a greater impact to the community compared to FAA-4 and FAA-5 due to the larger amount of truck traffic needed for off-site disposal of contaminated materials and import of clean fill. However, FAA-4 and FAA-5 would impact the Stepan facility over a longer period of time due to operation and maintenance of the treatment systems. Central Tank Farm - CTFA-1 and CTFA-2 would not have short-term impacts because no intrusive action would be implemented. CTFA-3 through CTFA-5 would have some impacts to the community and workers during the construction period. CTFA-2 would not meet chemical-specific ARARs, but it would prevent residential use soil exposures. CTFA-3 would have a potentially greater impact to the community compared to CTFA-4 and CTFA-5 due to the larger amount of truck traffic for off-site disposal of contaminated materials and import of clean fill.

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However, CTFA-4 and CTFA-5 would impact the Stepan facility over a longer period of time due to long-term operation and maintenance of the systems. 6. Implementability  

Implementability addresses the technical and administrative feasibility of a remedy from design through construction and operation. Factors such as availability of services and materials, administrative feasibility, and coordination with other governmental entities are also considered. Buried Container Area - In general, all of the AOC1-BCA alternatives are readily implementable and none require special equipment. BCA-3 and BCA-4 may be the most difficult to implement without interrupting the warehouse’s operations and would require coordination with the property owner and tenant. In situ solidification as proposed under BCA-3 may be difficult to implement due to the high groundwater table, which may cause difficulty in providing the correct reagent-to-water mix ratio. Gypsum Area - All the alternatives are easily implementable and none of them require any special materials or equipment. Excavation under GA-3 would be implementable, but the potential for some soil to also have low-level radiological contamination would complicate off-site disposal requirements. GA-3 may be the most difficult to implement due to the high groundwater table in the designated wetlands area. This could cause difficulty in providing the correct reagent-to-water mix ratios during implementation, thereby reducing the effectiveness of the treatment. Leather Materials Area - All four alternatives are implementable. LMA-1 would be the easiest to implement since no action would be taken, followed by LMA-2. Implementation of LMA-4 entails some complexity related to off-site disposal of potential radiologically-impacted soil (soil that has chemical contamination commingled with material that has residual radioactivity below levels addressed by USACE). LMA-3 is implementable, but long-term inspection and maintenance to maintain the integrity of the caps would be required. Former Aromatics Area - All five alternatives are implementable. The no action FAA-1 alternative requires no implementation. FAA-2 is implementable. Excavation under FAA-3 through FAA-5 would be implementable, but the potential for some soil to also have low-level radiological contamination would complicate off-site disposal requirements. Excavation in the vicinity of utility lines might present some technical challenges for implementation of FAA-3 through FAA-5. FAA-4 would be implementable to construct, but requires over 100 wells to be in place for an extended period of time (estimated at five years), so it may be difficult to implement on an actively used property during that extended period. Both FAA-4 and FAA-5 may face implementability issues related to soil permeability; if soil permeability in this area is low it could reduce vapor extraction potential and require additional extraction efforts, such as installation of more extraction wells, to achieve remediation goals. Long-term inspection and maintenance would be required to maintain the integrity of the cover in alternatives FAA-3 through FAA-5.

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Central Tank Farm - All five alternatives are implementable. Excavation under CTFA-3 through CTFA-5 would be implementable, but the potential for some soil to also have low-level radiological contamination would complicate off-site disposal requirements. (As noted above, soil is contaminated with Site-related chemicals and may be commingled with low-level radiological waste.) Excavation near utility lines might add some technical challenges for CTFA-3 through CTFA-5. In addition, active operations are ongoing at the CTFA, which is part of the Stepan facility, which would render EFR (CFTA-4) or SVE (CFTA-5) operations difficult to implement. CTFA-4 and CTFA-5 may also face implementability issues related to soil permeability; if soil permeability in this area is low it could reduce vapor extraction potential and require additional extraction efforts, such as installation of more extraction wells, to achieve remediation goals. Because excavation could pose structural concerns in implementing CTFA-3 through CTFA-5, long-term inspection and maintenance would be required for those alternatives to maintain the integrity of the cover in the immediate vicinity of Building 10. 7. Cost Total net present value includes estimated capital and 30 years of operations and maintenance (O&M) costs, please see Tables 13 through 29 for additional cost estimate details. The information in the cost estimate is based on the best available information regarding the anticipated scope of the remedial alternative. Changes in cost estimates are likely to occur as a result of new information and data collected during the engineering design for the selected remedial alternative. The engineering cost estimates provided below are expected to be within +50% -30% of the actual project cost. Major changes to the Selected Remedy cost estimates may be documented through a memorandum to the Administrative Record file, Explanation of Significant Differences, or ROD Amendment. Alternative Capital Cost Annual O&M Total Present Value BCA-1 No Action $0 $0 $0 BCA-2 ICs $455,000 $1,725 $559,000 BCA-3 In situ solidification, excavation with off-site disposal of buried containers, cap, ICs

$2,256,000 $3,500 $2,809,000

BCA-4 Excavation with off-site disposal

$7,131,000 $2,900 $7,254,000

Alternative Capital Cost Annual O&M Total Present Value GA-1 No Action $0 $0 $0 GA-2 ICs $308,000 $1,150 $378,000 GA-3 In situ solidification, cap, ICs

$1,901,000 $6,700 $2,084,000

GA-4 Excavation with off-site disposal, ICs

$3,767,000 $2,300 $3,866,000

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Alternative Capital Cost Annual O&M Total Present Value LMA-1 No Action $0 $0 $0 LMA-2 ICs $15,000 $2,300 $129,000 LMA-3 Capping with asphalt and topsoil

$739,000 $4,025 $884,000

LMA-4 Excavation with off-site disposal

$3,173,000 $4,025 $3,318,000

Alternative Capital Cost Annual O&M Total Present Value FAA-1 No Action $0 $0 $0 FAA-2 ICs $12,100 $1,725 $116,000 FAA-3 Excavation with off-site disposal

$1,805,000 $0 $1,805,000

FAA-4 In Situ Enhanced Fluid Recovery (EFR) and Excavation with off-site disposal

$1,257,000 $2,183,000 $3,440,000

FAA-5 In Situ Soil Vapor Extraction (SVE) and Excavation with off-site disposal

$1,573,000 $220,000 $1,793,000

Alternative Capital Cost Annual O&M Total Present Value CTFA-1 No Action $0 $0 $0 CTFA-2 ICs $12,000 $1,725 $116,000 CTFA-3 Excavation with off-site disposal

$893,000 $2,875 $1,017,000

CTFA-4 In Situ Enhanced Fluid Recovery (EFR) and Excavation with off-site disposal

$814,000 $734,000 $1,548,000

CTFA-5 In Situ Soil Vapor Extraction (SVE) and Excavation with off-site disposal

$994,000 $226,000 $1,220,000

Modifying Criteria - The final two evaluation criteria, criteria 8 and 9, are called "modifying criteria" because new information or comments from the state or the community on the Proposed Plan may modify the preferred response measure or cause another response measure to be considered.

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8. State Acceptance Indicates whether based on its review of the RI/FS reports and the Proposed Plan, the state supports, opposes and/or has identified any reservations with the selected response measure. NJDEP concurs with the Selected Remedy. 9. Community Acceptance Summarizes the public's general response to the response measures described in the Proposed Plan and the RI/FS reports. This assessment includes determining which of the response measures the community supports, opposes, and/or has reservations about. EPA solicited comment from the community on the remedial alternatives proposed for the Site. Stepan provided extensive comments. The local community and government officials were generally supportive of EPA’s Proposed Plan. Appendix V, The Responsiveness Summary, addresses the comments received at the public meeting and written comments received during the public comment period. PRINCIPAL THREAT WASTE Principal threat wastes are source materials that contain hazardous substances that act as a reservoir for the migration of contamination to groundwater, surface water, or air, or act as a source for direct exposure. These materials are considered to be highly toxic or highly mobile and, generally, cannot be reliably contained. Principal threat waste was not identified in the contaminated soil and waste material at the Site. SELECTED REMEDY Based upon consideration of the results of the Site investigation, the requirements of CERCLA, the detailed analysis of the response measures, and public comments, EPA has determined that excavation and off-site disposal of soil and waste material, as well as soil vapor extraction are the appropriate response actions for addressing the Site. These measures satisfy the requirements of CERCLA §121 and the NCP's nine evaluation criteria for remedial alternatives, 40 CFR §300.430(e)(9). The Selected Remedy for OU1 includes the following components:

Excavation and off-site disposal of an estimated 29,100 cubic yards of soil and waste material contaminated with metals, VOCs and SVOCs at an approved off-site disposal facility;

In situ soil vapor extraction and treatment of an estimated 3,220 cubic yards of VOC-contaminated soil; and

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The establishment of institutional controls (ICs), such as deed notices, easements or restrictive covenants to: maintain the long-term protectiveness of the remedy; ensure that future use remains commercial/industrial; and prevent future land uses that interfere with the implementation or protectiveness of the Selected Remedy.

Furthermore, as described in the 2003 OU2 ROD, areas of the Sears and DeSaussure properties where occupied buildings are currently situated are known to contain radiologically-contaminated soil that will be addressed under the OU2 remedy, but this soil is currently inaccessible. As this soil becomes accessible in the future (e.g., due to renovation or demolition activities), this OU1 remedy will address any chemically-contaminated soil under the buildings.  EPA’s remedy for chemical contamination in soil includes actions for each of the five AOCs as summarized below:

AOC1 - Buried Container Area The BCA-4 cleanup alternative consists of soil excavation and off-site disposal of soil, remaining buried containers and associated waste materials contaminated at concentrations greater than remediation goals. The key components of BCA-4 include: pre-design investigation; remedial design; excavation with dewatering in wetlands; off-site soil and waste material disposal at a regulated facility; Site restoration including wetlands; and ICs to ensure that future use remains commercial/industrial. It is expected that approximately 2.2 acres would require excavation up to four feet below ground surface, with one location requiring excavation up to eight feet below the ground surface. The FS estimates that excavation of 14,600 cubic yards of contaminated soil, containers and waste materials would be required.

AOC2 - Gypsum Material Area The GA-4 cleanup alternative consists of soil excavation and off-site disposal of soil and remaining gypsum material that is contaminated at concentrations greater than the remediation goals. The key components of GA-4 include: pre-design investigation; remedial design; excavation with dewatering in wetlands; off-site disposal of soil and waste material at a regulated facility; Site restoration including wetlands; and ICs to ensure that future use remains commercial/industrial. It is estimated that approximately 6,250 cubic yards of gypsum material and soil would require excavation up to four feet below the surface.

AOC3 - Leather Material Area The LMA-4 cleanup alternative consists of excavation and off-site disposal of remaining contaminated leather material and soil with concentrations greater than remediation goals. The key components of LMA-4 include: pre-design investigation; remedial design; excavation; off-site disposal of soil and waste material at a regulated facility; Site restoration; and ICs to ensure that future use remains commercial/industrial. LMA-4 also includes a contingency for ICs to prevent future disturbance of or exposure to chromium

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contamination, if it is identified during the pre-design investigation at locations where remediation of radiological contamination by USACE under FUSRAP (OU2) has been completed. It is expected that approximately 6,550 cubic yards of leather material and soil would require excavation up to two feet below the ground surface, with one location requiring extraction up to four feet below the surface.

AOC4 - Former Aromatics Area The FAA-5 cleanup alternative includes the installation of a SVE system to extract and treat contaminated soil vapor from the unsaturated zone (from zero to four feet below the surface) through shallow horizontal wells; contaminated soil in the saturated zone would be addressed in the future groundwater ROD. It would also include excavation of about 900 cubic yards of contaminated soil around utilities and subsurface structures, with off-site disposal. The key components of FAA-5 include: pre-design investigation; pilot study; remedial design; installation of the SVE system; excavation of contaminated soil around utilities and subsurface structures, with off-site disposal. The pilot study would be necessary to demonstrate that the technology is viable for Site-specific conditions and to size and configure remedial components. Horizontal SVE extraction wells are expected to be located approximately four feet below the ground surface, so normal groundwater table fluctuations would not affect the wells. The well locations would be determined during design based on pre-design investigation and pilot study information. Location and spacing would be dependent on Site soil conditions for optimum vapor removal. Underground piping would connect the extraction wells to a blower, and the ground surface sealed to prevent water infiltration, fugitive vapors or short-circuiting of air flow. Extracted vapors may require treatment prior to discharge to the air. It is assumed that such treatment would consist of a GAC unit, which may require an air permit. The SVE system would require periodic monitoring to gauge remedial progress. The FS report estimated that it would take approximately five years of SVE system operation to achieve the remediation goals. It is estimated that approximately 3,220 cubic yards of soil would require treatment or excavation and disposal.

If the pilot study cannot demonstrate the effectiveness of SVE to address contaminated soil in the FAA, all the contaminated soil would be excavated for off-site disposal.

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AOC5 - Central Tank Farm Area The CTFA-3 cleanup alternative consists of excavation and off-site disposal of contaminated soil in the unsaturated zone from zero to seven feet below the surface. Contaminated soil in the saturated zone would be addressed in the future groundwater ROD. The key components of CTFA-3 include: pre-design investigation; remedial design; excavation of contaminated soil to the groundwater table, which is approximately seven feet below the surface, including around utilities and subsurface structures; off-site soil disposal at a regulated facility; Site restoration; ICs to ensure that future use remains commercial/industrial and ICs to restrict intrusive activities below seven feet to prevent exposure to contaminated soil during seasonally low groundwater conditions. Excavation near Building 10 may be limited due to structural integrity concerns and any contaminated soil in the immediate vicinity of Building 10 would remain in place and also require ICs. It is estimated that approximately 800 cubic yards of contaminated soil would require excavation.

Consistent with EPA Region 2’s Clean and Green policy, EPA will evaluate the use of sustainable technologies and practices with respect to implementation of the Selected Remedy. Excavation and disposal of contaminated soil at the BCA, GA, LMA and CTFA are the most appropriate remedy for these AOCs based on the comparative analysis. While SVE with soil excavation around utilities is an appropriate remedy for the FAA, because contamination is located in an open area and would be better suited to SVE operations to treat VOC-contaminated soil. While the contaminants at the FAA, which are primarily VOCs, are similar to those identified at the CTFA, different remedies are proposed for these two areas due to significant differences in existing Site conditions. Active operations are ongoing at the CTFA, which is part of the Stepan facility, which renders SVE operations very difficult to implement, compounded by surface, subsurface and overhead utilities. The conditions at the FAA, as explained above, make this a suitable candidate for SVE. However, if FAA SVE pilot test results do not indicate that SVE would meet the remediation goals, based on specific performance standards developed to ensure adequate treatment, the excavation and disposal alternative FAA-3 would be implemented as a contingency remedy. The FAA-3 alternative has been comparatively evaluated in the FS and the Proposed Plan and is an appropriate remedial alternative. Based on all available information, EPA believes the Selected Remedy provides the best balance of trade-offs among the response measures with respect to the nine evaluation criteria. EPA believes that the Selected Remedy will be protective of human health and the environment, will comply with ARARs, will be cost effective, and will utilize permanent solutions and alternative treatment technologies to the maximum extent practicable.  

Cost Estimate for Selected Remedy The total estimated cost for the Selected Remedy is $17,248,000.

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Expected Outcomes of Selected Remedy The Selected Remedy would be protective of human health and the environment. Risks to human health due to direct contact, ingestion and inhalation would be eliminated since soil contamination would be removed from the Site, or in one area treated on Site, to meet cleanup goals. Impacts to groundwater would be eliminated by removing contaminated soil source areas through excavation and treatment. The Selected Remedy alternatives would provide long-term effectiveness and permanence since the contaminated materials would be removed and disposed at off-site facilities. The Selected Remedy would not alter the current land use at the Site, which includes active commercial businesses. The ecological benefits of the Selected Remedy would include removal of contaminated soil and wetlands restoration, thus improving the existing wetlands conditions. The anticipated environmental benefits may be enhanced by implementing sustainable technologies and practices in accordance with EPA Region 2’s Clean and Green Energy Policy.  

STATUTORY DETERMINATIONS Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial actions that achieve adequate protection of human health and the environment. In addition, Section 121 of CERCLA establishes other statutory requirements and preferences. These specify that, when complete, the selected remedial action for a site must comply with applicable or relevant and appropriate environmental standards established under federal and state environmental laws unless a statutory waiver is justified. The selected remedy also must be cost-effective and utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Finally, the statute includes a preference for remedies that employ treatment that permanently and significantly reduces the volume, toxicity or mobility of hazardous wastes as its principal element. The following sections discuss how the Selected Remedy meets these statutory requirements. Protection of Human Health and the Environment The Selected Remedy will adequately protect human health and the environment by eliminating the direct contact exposure pathway risk to human and environmental receptors. In addition, the remedy will minimize the possibility of contaminants spreading to the groundwater, surface water bodies or soil in the future. This action will result in the reduction of exposure levels to levels within EPA’s generally acceptable risk range of 10-4 to 10-6 for carcinogens and at or below a HI of 1 for noncarcinogens. Implementation of the Selected Remedy will not pose unacceptable short-term risks or adverse cross-media impacts. Compliance with Applicable or Relevant and Appropriate Requirements The excavation remedial action will comply with all federal and state requirements that are ARARs. A comprehensive ARAR discussion is included in the FS and a listing of ARARs is included in Table 12 of this ROD. The Selected Remedy will meet the chemical-specific ARARs, including NJDEP Non-Residential Direct Contact Soil Remediation.

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Location-specific ARARs would apply to wetlands protection due to excavation activities causing the disruption of an existing wetland. When work is required within a wetland, regulations generally favor actions that minimize ecosystem disturbance, and then expect restoration efforts to attain similar, or where possible improved ecosystem conditions, post-action. Cost Effectiveness EPA has determined that the Selected Remedy is cost-effective; that is its costs are proportional to its overall effectiveness. (See NCP §300.430(f)(1)(ii)(D)). Overall effectiveness was evaluated by assessing three of the five balancing criteria in combination (long-term effectiveness and permanence; reduction in toxicity, mobility and volume through treatment; and short-term effectiveness). Overall effectiveness was then compared to costs to determine cost-effectiveness. The overall effectiveness of the Selected Remedy has been determined to be proportional to the costs, and therefore the Selected Remedy represents reasonable value for the money to be spent. Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable EPA has determined that the Selected Remedy represents the maximum extent to which permanent solutions and treatment technologies can be utilized in a practicable manner at the Site. EPA has determined that the Selected Remedy is protective of human health and the environment, meets ARARs, and provides the better balance of trade-offs with respect to the five balancing criteria. The Selected Remedy satisfies the criteria for long-term effectiveness and permanence by removing the primary COCs. Preference for Treatment as a Principal Element On-site treatment will be used to address VOC contamination at the FAA AOC and satisfies EPA’s preference for treatment; for other AOCs, alternatives that rely on on-site treatment have implementability limitations when compared to the other alternatives. While treatment of some wastes sent off-site may be required prior to land disposal, the requirement for treatment would be governed by the requirements of the receiving facility and would not be a “principal element” of the Selected Remedy; therefore, it would not satisfy this criterion. Given the nature of the wastes, EPA has concluded that further efforts at off-site treatment independent of those required prior to land disposal would not be practicable. Five-Year Review Requirements The current land use is light industrial/industrial (as defined by a local zoning ordinance). Neither of these land uses are considered “unrestricted,” and the selected remediation goals are protective for these plausible future uses. Thus, the remedy is protective as long as the land use is not changed to one that would allow for unlimited use and unrestricted exposure. Because this remedy results in hazardous substances, pollutants, or contaminants remaining on the Site above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within five years of the initiation of the remedial action for this operable unit, and no

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less than every five years thereafter, to ensure that the remedy remains protective of human health and environment, unless determined otherwise at the completion of the remedial action. DOCUMENTATION OF SIGNIFICANT CHANGES  

The Proposed Plan for this ROD for the Maywood Chemical Company Site was released for public comment on August 23, 2013. The comment period closed on December 5, 2013. All oral and written comments submitted during the public comment period were reviewed by EPA. Upon review of the comments, it was determined that no significant changes to the remedy, as originally identified in the Proposed Plan, are necessary.

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R2-0000396

FIGURE

DATE

SITE LOCATION MAPMAYWOOD CHEMICAL COMPANY SUPERFUND SITE

MAYWOOD AND ROCHELLE PARKBERGEN COUNTY, NEW JERSEY 1

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2

R2-0000398

LEGEND oeM»-i3 OVERBURDEN MONITORING WEU. LOCATION AND

® lOENTinCATlON

BRM«-8 BEDROCK MONITOWNC mL LOCATION AND ® IDENTIFICATION

NOTES 1.) BASE MAP SHOWN HEREON DIGITIZED FORM A PLAN

ENTITLED, "PLAN SHOWING TQPOGRAPHICFEATURES,' PREPARED BY T&M ASSOOATES, DATED JANUARY 14. 1994 DRAWNG No. CSTIL0180.

2.) MISS AND ACOE OFF-PROPERTY WELL LOCATIONS PROVIDED BY SHAW GROUP 6/03.

3.) OB-SERIES mi LOCATIONS PROVIOED BY VAROO ASSOOATES 5/03.

WELL LOCATION PLAN

MATWOOD, NEW JERSEY

MAYWOOD CHEMICAL COMPANY SITE

1 UH!D CompM by: KH

Preportd by: J5G

Dote: 06/03/03

Seal*: AS SHOWN

nOURE

ROUX ASSOCIATES, INC. Projwt Mgr. Offica: NJ

nOURE

1 * Uonoge^l nia No: 51202217 Projact 51202J

nOURE

R2-0000399

3

R2-0000400

4

R2-0000401

5

R2-0000402

�

R2-0000403

7

R2-0000404

8

R2-0000405

�

R2-0000406

10

AOC3-LMA AREA TO BE REMEDIATED

R2-0000407

11

AOC4-FAA AREA TO BE REMEDIATED

R2-0000408

12

AOC5-CTFA AREA TO BE REMEDIATED

R2-0000409

Min Max

Arsenic 0.78 105 mg/kg 28/29 35 mg/kg 95% UCL

Benz(a)anthracene 0.044 3.4 mg/kg 13/29 3.4 mg/kg Max

Benzo(a)pyrene 0.046 3.1 mg/kg 17/29 3.1 mg/kg Max

Benzo(b)fluoranthene 0.048 3.5 mg/kg 13/23 3.5 mg/kg Max

Benzo(k)fluoranthene 4.1 4.1 mg/kg 1/22 4.1 mg/kg Max

Dibenz(ah)anthracene 0.056 1.2 mg/kg 7/29 1.2 mg/kg Max

Indeno(1,2,3-cd)pyrene 0.039 2.9 mg/kg 10/29 2.9 mg/kg MaxDefinitions:mg/kg = Milligrams per kilogram

Surface Soil: Sears and adjacent properties

Statistical Measure

Table 1Summary of Chemicals of Concern and

Medium-Specific Exposure Point Concentrations

Scenario Timeframe: Future Medium: SoilExposure Medium: Surface Soil

Concentration DetectedExposure Point

Chemical of Concern

Concentration Units

Frequency of Detection

Exposure Point

Concentration

(EPC)1,2

EPC Units

R2-0000410

Chemicals of Concern

Chronic/Subchronic

Oral RfDValue

Oral RfD Units

Absorp.Efficiency

(Dermal)1

Primary Target Organ

CombinedUncertainty/Modifying

Factors

Sources of RfD Target

Organ

Dates ofRfD

Arsenic Chronic 3.0E-04 mg/kg-day 1 Skin 3 IRIS 1993

Benz(a)anthracene Chronic NA mg/kg-day NA IRIS 1993

Benzo(a)pyrene Chronic NA mg/kg-day NA IRIS 1993

Benzo(b)fluoranthene Chronic NA mg/kg-day NA IRIS 1993

Benzo(k)fluoranthene Chronic NA mg/kg-day NA IRIS 1993

Dibenz(ah)anthracene Chronic NA mg/kg-day NA IRIS 1993

Indeno(1,2,3-cd)pyrene Chronic NA mg/kg-day NA IRIS 1993

Definitions: NA=Not AvailableIRIS=Integrated Risk Information Systemmg/kg-day=Milligrams per kilogram per day

Pathway: Ingestion/Dermal

Table 2 Non-Cancer Toxicity Summary

R2-0000411

Chemical of Concern OralCancer

Slope Factor

Units Adjusted Cancer Slope

Factor(for Dermal)

Slope FactorUnits

Weight ofEvidence/

Cancer

Guideline1

Source Date

Arsenic 1.7E+00 (mg/kg-day)-1 1.7E+00 (mg/kg-day)-1 A IRIS 1993

Benz(a)anthracene 7.3E-01 (mg/kg-day)-1 7.3E-01 (mg/kg-day)-1 B2 IRIS 1993

Benzo(a)pyrene 7.3E+00 (mg/kg-day)-1 7.3E+00 (mg/kg-day)-1 B2 IRIS 1993

Benzo(b)fluoranthene 7.3E-01 (mg/kg-day)-1 7.3E-01 (mg/kg-day)-1 B2 IRIS 1993

Benzo(k)fluoranthene 7.3E-01 (mg/kg-day)-1 7.3E-01 (mg/kg-day)-1 B2 IRIS 1993

Dibenz(ah)anthracene 7.3E+00 (mg/kg-day)-1 7.3E+00 (mg/kg-day)-1 B2 IRIS 1993

Indeno(1,2,3-cd)pyrene 7.3E-01 (mg/kg-day)-1 7.3E-01 (mg/kg-day)-1 B2 IRIS 1993

Table 3 Cancer Toxicity Data Summary

Pathway: Ingestion/ Dermal

Footnotes:(1) Weight of evidence information obtained from IRIS. Categories are as follows:A=Known human carcinogenB2=Probable human carcinogen based on sufficient evidence of carcinogenicity in animalsC=Possible human carcinogenD=Not classifiable due to lack of animal bioassays and human studiesNA=Not available

Definitions: NA=Not availableIRIS=Integrated Risk Information System(mg/kg-day)-1=Per milligrams per kilogram per day

R2-0000412

Ingestion Inhalation Dermal Exposure Routes Total

Arsenic Skin 0.2 NA NA 0.2

Benz(a)anthracene NA NA NA NA

Benzo(a)pyrene NA NA NA NA

Benzo(b)fluoranthene NA NA NA NA

Benzo(k)fluoranthene NA NA NA NA

Dibenz(ah)anthracene NA NA NA NA

Indeno(1,2,3-cd)pyrene NA NA NA NA

Total Hazard = 0.2

Ingestion Inhalation Dermal Exposure Routes Total

Arsenic Skin 1 NA NA 1

Benz(a)anthracene NA NA NA NA

Benzo(a)pyrene NA NA NA NA

Benzo(b)fluoranthene NA NA NA NA

Benzo(k)fluoranthene NA NA NA NA

Dibenz(ah)anthracene NA NA NA NA

Indeno(1,2,3-cd)pyrene NA NA NA NA

Total Hazard = 2

Non-Carcinogenic Hazard Quotient

Definitions:NA=Not available

Surface Soil - Sears and Adjacent Properties

Surface Soil Surface Soil

Medium Exposure Medium

Exposure Point Chemical Of Concern

Primary Target Organ

Surface Soil - Sears and Adjacent Properties

Surface Soil Surface Soil

Scenario Timeframe: Future Receptor Population: ResidentReceptor Age: Child

Table 4Risk Characterization Summary - Non-Carcinogens

Scenario Timeframe: FutureReceptor Population: ResidentReceptor Age: Adult

Medium Exposure Medium

Exposure Point Chemical Of Concern

Primary Target Organ Non-Carcinogenic Hazard Quotient

R2-0000413

Ingestion Inhalation Dermal Exposure RoutesTotal

Arsenic 3.0E-05 NA NA 3.0E-05

Benz(a)anthracene 1.0E-06 NA NA 1.0E-06

Benzo(a)pyrene 1.0E-05 NA NA 1.0E-05

Benzo(b)fluoranthene 1.0E-06 NA NA 1.0E-06

Benzo(k)fluoranthene 1.0E-06 NA NA 1.0E-06

Dibenz(ah)anthracene 4.0E-06 NA NA 4.0E-06

Indeno(1,2,3-cd)pyrene 1.0E-06 NA NA 1.0E-06

Ingestion Inhalation Dermal Exposure RoutesTotal

Arsenic 7.0E-05 NA NA 7.0E-05

Benz(a)anthracene 3.0E-06 NA NA 3.0E-06

Benzo(a)pyrene 2.0E-05 NA NA 2.0E-05

Benzo(b)fluoranthene 3.0E-06 NA NA 3.0E-06

Benzo(k)fluoranthene 3.0E-06 NA NA 3.0E-06

Dibenz(ah)anthracene 1.0E-05 NA NA 1.0E-05

Indeno(1,2,3-cd)pyrene 2.0E-06 NA NA 2.0E-06

2E-04

Surface Soil - Sears and Adjacent Properties

Definitions:NA=Not available

Chemical Of Concern Carcinogenic Risk

Total Risk=

Surface Soil Surface Soil

Scenario Timeframe: Future Receptor Population: ResidentReceptor Age: Child

Medium Exposure Medium

Surface Soil - Sears and Adjacent Properties

Table 5Risk Characterization Summary - Carcinogens

Scenario Timeframe: FutureReceptor Population: ResidentReceptor Age: Adult

Medium Exposure Medium

Exposure Point Chemical Of Concern Carcinogenic Risk

Exposure Point

Surface Soil Surface Soil

R2-0000414

Table 6Summary of Soil Contaminants of Concern

Maywood Chemical Company Superfund Site

Page 1 of 1

Parameter NameBuried

Container Area

Gypsum Area

Leather Material

Area

Former Aromatics

Area

Central Tank Farm

VOCsAcetone X XBenzene X X XChloroform XEthylbenzene XMethylene Chloride XToluene X X1,1,1-Trichloroethane XTrichloroethene XXylenes X X XSVOCsBenzo(a)anthracene X X XBenzo(a)pyrene X X XBenzo(b)fluoranthene XDibenzo(a,h)anthracene XIndeno(1,2,3-cd)pyrene XPentachlorophenol XMetalsArsenic X X XBarium XChromium X X XCyanide XLead X X XLithium XMercury X

Feasibility Study025-RICO-0219

R2-0000415

Exposure Medium: Sediment

Chemical of Concern

Average Concentration

(mg/kg)

Maximum Concentration

(mg/kg)ER-M Based Risk Indices -

AverageER-M Based Risk Indices -

MaxmiumBenzo(a)anthracene 3.47 5.1 2 3

Benzo(a)pyrene 3.51 5.4 1 2Dibenz(ah)anthracene 2.82 2.82 10 10

Barium 295 1670 5 30Cyanide 45.8 157 200 600

Lead 243 645 2 6

Table 6AOccurrence, Distribution and Selection of Chemicals of Ecological Concern

R2-0000416

Table 7 Comparative Analysis of Alternatives: AOC1 - BCA

Maywood Chemical Company Superfund Site Page 1 of 5  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

1 BCA-1: No Action

Provides no control of exposure to contaminated soil and no reduction in risk to human health and environmental impacts.

No ARARs are met.

Does not provide long-term effectiveness or permanence.

Provides no reduction in the toxicity, mobility or volume of the contamination.

Does not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or environment.

No implementability concerns.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$0

$0

$0

2 BCA -2: Institutional Controls (ICs)

Provides some control of exposure to buried container contents and contaminated soil by restricting future use of the property to nonresidential and limiting activities that could result in contact with contaminated materials. Does

No ARARs are met.

Provides long term effectiveness and permanence for the protection of human health, but will not provide long term effectiveness for minimizing leaching of contaminants into the groundwater.

Provides no reduction in toxicity, mobility or volume of the contamination.

Will result in minor disruptions to the Site and exposure to contaminants during PDI activities.

Easily implemented.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$455,000

$1,725

$559,000

R2-0000417

Table 7 Comparative Analysis of Alternatives: AOC1 - BCA

Maywood Chemical Company Superfund Site Page 2 of 5  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

not provide protection of the environment since buried containers and contaminated soil will remain in place with no controls to prevent or reduce leaching of contaminants into groundwater.

Effectiveness is dependent on implementation and enforcement by the regulating agency, property owner and tenants.

3 BCA -3: In Situ Solidification, Excavation of Buried Containers, Capping, and ICs

Provides overall protection of human health and the environment by reducing mobility of contaminants in the soil below the groundwater table, removing buried containers, and

Complies with applicable ARARs.

Air monitoring will be conducted during implementation to verify compliance with health and safety

Provides a moderate degree of long term effectiveness and permanence. Some factors that may affect this include the selection and weight ratios of reagent

Provides a reduction in mobility of contaminants in soils contaminated above PRGs in the groundwater table. Overall volume of stabilized material will increase.

Will result in disruption to the Site and exposure of contaminants to the community and workers during stabilization and excavation of buried containers.

Will require the use of mixing equipment to provide consistent mixing of reagent materials. A bench scale test will be necessary to determine proper mixing reagents and ratios. The Site has a high

Capital Cost:

Average Annual O&M:

Total Present Worth:

$2,256,000

$3,500

$2,809,000

R2-0000418

Table 7 Comparative Analysis of Alternatives: AOC1 - BCA

Maywood Chemical Company Superfund Site Page 3 of 5  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

capping soils above the groundwater table having contaminant concentrations greater than PRGs.

Caps (asphalt and soil) and implementation of ICs will further prevent human contact with solidified soil and contaminated soil above PRGs that will remain on site.

The asphalt cap and in situ solidification will reduce the potential for contaminants to

requirements.

Wetland excavations and restoration will comply with wetland disturbance and restoration regulations or equivalencies.

materials and proper mixing during implementation. Over time stabilized materials may degrade due to the high groundwater table.

Excavation of buried containers will permanently remove this potential source of contamination.

Long term effectiveness and permanence of asphalt and soil cap is dependent on the maintenance

Removal of buried containers will require temporary stockpiling of contaminated soils to access drums. Stockpiled material will be covered and contained with a temporary berm to prevent migration and reduce exposure to employees, workers and the community.

Time to implement remedy is assumed to take 10 weeks.

groundwater table which may make implementation difficult to obtain required consistency of stabilization material.

Dewatering may be necessary during excavation of buried containers in the wetland.

R2-0000419

Table 7 Comparative Analysis of Alternatives: AOC1 - BCA

Maywood Chemical Company Superfund Site Page 4 of 5  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

leach into groundwater. Removal of buried containers eliminates a continued source of groundwater contamination.

and inspections of the caps.

Effectiveness of ICs is dependent on implementation and enforcement by the regulating agency, property owner and tenants.

4 BCA -4: Excavation, Off Site Disposal, and ICs

Provides overall protection of human health and the environment.

The buried containers and soil contaminated above PRGs will be permanently removed from the site.

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials for off site

Provides a high degree of long term effectiveness and permanence.

The buried containers and soil contaminated above PRGs will be permanently removed from

Provides no reduction in toxicity, mobility or volume of contamination.

Contents of buried containers, if determined to be hazardous and exceeding LDRs will be sent to a RCRA treatment facility for incineration or

Will result in the high short term impacts and high degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated

Easily implemented. No special construction equipment is necessary.

Dewatering may be necessary during excavation of buried containers in the wetland.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$7,131,000

$2,900

$7,254,000

R2-0000420

Table 7 Comparative Analysis of Alternatives: AOC1 - BCA

Maywood Chemical Company Superfund Site Page 5 of 5  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

Exposure to remaining contaminated soils will be limited by the implementation of ICs.

disposal.

Dust and air monitoring will be conducted to verify compliance with air emission and health and safety regulations.

the site. immobilization of hazardous constituents prior to placing in the landfill. Treatment of the waste for compliance with LDRs will reduce the toxicity and mobility of the gypsum material, but will not reduce the volume.

during excavation activities. Will result in high degree of traffic due to the volume of material requiring off site disposal.

Excavation activities are estimated to take 22 weeks.

R2-0000421

Table 8 Comparative Analysis of Alternatives: AOC2 - GA

Maywood Chemical Company Superfund Site Page 1 of 4

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

1 GA-1: No Action

Provides no control of exposure to contaminated soil and no reduction in risk to human health and environmental impacts.

No ARARs are met.

Does not provide long-term effectiveness or permanence.

Provides no reduction in the toxicity, mobility or volume of the contamination.

Does not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or environment.

No implementability concerns.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$0

$0

$0

2 GA-2: Institutional Controls (ICs)

Provides some control of exposure to gypsum material and contaminated soil by restricting future use of the property to nonresidential and limiting activities that could result in contact with contaminated materials. Does not provide protection of the

No ARARs are met.

Provides long term effectiveness and permanence for the protection of human health, but will not provide long term effectiveness for minimizing leaching of contaminants into the groundwater.

Provides no reduction in toxicity, mobility or volume of the contamination.

Will result in minor disruptions to the Site and exposure to contaminants during PDI activities.

Easily implemented.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$308,000

$1,150

$378,000

R2-0000422

Table 8 Comparative Analysis of Alternatives: AOC2 - GA

Maywood Chemical Company Superfund Site Page 2 of 4

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

environment since gypsum material will remain in place with no controls to prevent or reduce infiltration.

Effectiveness is dependent on implementation and enforcement by the regulating agency, property owner and tenants.

3 GA-3: In Situ Solidification and ICs

Provides overall protection of human health and the environment by reducing mobility of contaminants in the gypsum material. Uses ICs to prevent human contact with stabilized waste material that will remain on site.

Complies with applicable ARARs.

Air monitoring will be conducted during implementation to verify compliance with health and safety requirements.

Provides a moderate degree of long term effectiveness and permanence. Some factors that may affect this include the selection and weight ratios of reagent materials and proper mixing during implementation. Over time stabilized materials may

Provides a reduction in toxicity and mobility of hazardous constituents in the gypsum material. Overall volume of stabilized gypsum material will increase.

Will result in disruption to the Site and moderate exposure of contaminants to the community and workers during stabilization.

RA is expected to take approximately 6 weeks.

Moderately implementable. Will require the use of mixing equipment to provide consistent mixing of reagent materials. A bench scale test and treatability study will be necessary to determine proper mixing reagents and ratios. The Site has a high groundwater table

Capital Cost:

Average Annual O&M:

Total Present Worth:

$1,901,000

$6,700

$2,084,000

R2-0000423

Table 8 Comparative Analysis of Alternatives: AOC2 - GA

Maywood Chemical Company Superfund Site Page 3 of 4

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

degrade due to the high groundwater table.

Requires long term monitoring of groundwater to determine the effectiveness of the remedy.

which may make implementation difficult to obtain required consistency of stabilization material.

4 GA-4: Excavation, Off Site Disposal, and ICs

Provides overall protection of human health and the environment.

The gypsum material and soil contaminated above the cleanup objectives will be permanently removed from the site. Exposure to remaining

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance

Provides a high degree of long term effectiveness and permanence.

The gypsum material and soil contaminated above the cleanup objectives will be permanently removed from

Provides no reduction in toxicity, mobility or volume of contamination.

Excavated gypsum material, if determined to be hazardous and exceeding LDRs will be

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation

Easily implemented. No special construction equipment is necessary.

Dewatering may be necessary during excavation activities in the wetland.

Some coordination will

Capital Cost:

Average Annual O&M:

Total Present Worth:

$3,767,000

$2,300

$3,866,000

R2-0000424

Table 8 Comparative Analysis of Alternatives: AOC2 - GA

Maywood Chemical Company Superfund Site Page 4 of 4

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and the

Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

contaminated soils will be limited by the implementation of ICs.

with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety regulations.

the site. sent to a RCRA treatment facility for immobilization of hazardous constituents (ex situ stabilization) prior to placing in the landfill. Treatment of the gypsum material for compliance with LDRs will reduce the toxicity and mobility of the gypsum material, but will not reduce the volume.

activities. Will result in the highest degree of traffic due to the volume of material requiring disposal off site.

Excavation activities are estimated to take 10 weeks.

be required with the property owner.

R2-0000425

Table 9 Comparative Analysis of Alternatives: AOC3 – LMA

Maywood Chemical Company Superfund Site Page 1 of 4  

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with

ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

1 LMA-1: No Action

Provides no control of exposure to contaminated soil and no reduction in risk to human health impacts.

No ARARs are met.

Does not provide long-term effectiveness or permanence.

Provides no reduction in the toxicity, mobility or volume of the contamination.

Does not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or environment.

No implementability concerns.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$0

$0

$0

2 LMA-2: Institutional Controls (ICs)

Provides protection of human health and the environment by restricting land use.

No ARARs are met.

Provides long term effectiveness and permanence for the protection of human health.

Effectiveness is dependent on implementation and enforcement by the regulating agency, property owner

Provides no reduction in toxicity, mobility or volume of the contamination.

Will not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or the environment as no remedial actions will occur.

May be difficult to enforce by local government, which may have limited resources.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$15,000

$2,300

$129,000

R2-0000426

Table 9 Comparative Analysis of Alternatives: AOC3 – LMA

Maywood Chemical Company Superfund Site Page 2 of 4  

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with

ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

and tenants.

3 LMA-3: Capping, and ICs

Provides overall protection of human health and the environment by reducing mobility of hazardous constituents. Uses ICs to prevent human contact with waste material that will remain on site.

Complies with applicable ARARs.

Provides a moderate degree of long term effectiveness and permanence. Some factors that may affect this include the integrity of the cap. Over time the cap may degrade.

Requires a long term maintenance program to determine the effectiveness of the remedy.

Provides limited reduction of mobility. The volume and toxicity of contaminated leather material would not be reduced, but simply covered by a cap.

Will result in some disruption to the Site and moderate exposure of contaminants to the community and workers during capping.

Easily implemented.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$739,000

$4,025

$884,000

R2-0000427

Table 9 Comparative Analysis of Alternatives: AOC3 – LMA

Maywood Chemical Company Superfund Site Page 3 of 4  

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with

ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

4 LMA-4: Excavation, Off Site Disposal, and ICs

Provides overall protection of human health and the environment.

The leather material and soil in the shallow zone and “hot spot” contaminated above the cleanup objectives will be permanently removed from the site. Due to the potential for chromium to be present in deeper soils

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety

Provides a high degree of long term effectiveness and permanence.

The leather material and soil contaminated above the cleanup objectives will be permanently removed from the site.

The ICs and a long-term inspection and maintenance program would be in place to ensure continued protection of

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would be reduced.

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material requiring disposal off site.

Excavation activities are estimated to take 30 days.

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$3,173,000

$4,025

$3,318,000

R2-0000428

Table 9 Comparative Analysis of Alternatives: AOC3 – LMA

Maywood Chemical Company Superfund Site Page 4 of 4  

Feasibility Study 025-RICO-0219

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with

ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

that remain on site and at concentrations that may impact groundwater, ICs and a long-term inspection and maintenance program will be implemented for the cover that will reduce the potential for leaching of chromium into the groundwater.

regulations. human health and the environment from chromium that maybe present in deeper existing soils at concentrations exceeding PRGs and RAOs.

R2-0000429

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 1 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

1 FAA-1: No Action

Provides no control of exposure to contaminated soil and no reduction in risk to human health impacts.

No ARARs are met.

Does not provide long-term effectiveness or permanence.

Provides no reduction in the toxicity, mobility or volume of the contamination.

Does not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or environment.

No implementability concerns.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$0

$0

$0

2 FAA-2: Institutional Controls (ICs)

Provides protection of human health by restricting land use. Will not achieve RAOs.

No ARARs are met.

Provides long term effectiveness and permanence for the protection of human health.

Effectiveness is dependent on implementation and enforcement by the regulating agency, property owner and tenants.

Provides no reduction in toxicity, mobility or volume of the contamination.

Will not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or the environment as no remedial actions will occur.

May be difficult to enforce by local government, which may have limited resources.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$12,100

$1,725

$116,000

R2-0000430

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 2 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

3 FAA-3: Excavation, Off Site Disposal, and ICs

Provides overall protection of human health and the environment.

The soils contaminated above the cleanup objectives will be permanently removed down to the water table from the Site.

Complies with applicable ARARs.

Soils removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety regulations.

Provides a high degree of long term effectiveness and permanence.

The unsaturated soil contaminated above the cleanup objectives will be permanently removed from the Site.

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would be reduced.

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material requiring disposal off site.

Excavation activities are estimated to take 30 days.

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$1,805,000

$0

$1,805,000

R2-0000431

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 3 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

4 FAA-4: Enhanced fluid recovery (EFR), Excavation, and ICs

Provides overall protection of human health and the environment.

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety regulations.

Excavation and EFR would significantly reduce BTEX concentrations in the treatment area. Long-term effectiveness of the EFR largely relies on the effectiveness of the technology in the unsaturated zone alone.

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would be reduced.

Vapor extraction wells

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material requiring disposal off site.

Excavation activities by air knife or vacuum are estimated to

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$1,257,000

$0

$3,440,000

R2-0000432

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 4 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

installed as part of the EFR would potentially capture and remove BTEX in the soil if determined to be effective in vadose soils, thus reducing the mobility, toxicity, and the source of the BTEX compounds in shallow overburden groundwater. Extracted vapor would be treated for BTEX removal.

take 10 days.

EFR will be implemented monthly.

R2-0000433

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 5 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

5 FAA-5: Soil Vapor Extraction (SVE), Excavation, and ICs

Provides overall protection of human health and the environment.

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety regulations.

Excavation and SVE would significantly reduce BTEX concentrations in the treatment area. Horizontal SVE wells would provide minimal disruption of operations..

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would be reduced.

SVE would reduce the

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material requiring disposal off site.

Excavation activities by air knife or vacuum are estimated to

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$1,573,000

$0

$1,793,000

R2-0000434

Table 10 Comparative Analysis of Alternatives: AOC4 - FAA

Maywood Chemical Company Superfund Site Page 6 of 6

Feasibility Study 025-RICO-0219 

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

toxicity, mobility, and volume of VOCs in soils.

take 10 days.

SVE will be implemented continuously.

R2-0000435

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 1 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

1 CTFA-1: No Action

Provides no control of exposure to contaminated soil and no reduction in risk to human health impacts.

No ARARs are met.

Does not provide long-term effectiveness or permanence.

Provides no reduction in the toxicity, mobility or volume of the contamination.

Does not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or environment.

No implementability concerns.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$0

$0

$0

2 CTFA -2: Institutional Controls (ICs)

Provides protection of human health and the environment by restricting land use.

No ARARs are met.

Provides long term effectiveness and permanence for the protection of human health.

Effectiveness is dependent on implementation and enforcement by the regulating agency, property owner

Provides no reduction in toxicity, mobility or volume of the contamination.

Will not result in disruption of the Site and therefore no additional risks are posed to the community, workers, or the environment as no remedial actions will occur.

May be difficult to enforce by local government, which may have limited resources.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$12,100

$1,725

$116,000

R2-0000436

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 2 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

and tenants.

3 CTFA -3: Excavation, Off Site Disposal, and ICs

Provides overall protection of human health and the environment.

The soils contaminated above the cleanup objectives will be permanently removed to the water table from the site. Exposure to remaining contaminated soils near Building 10 will be limited by the implementation

Complies with applicable ARARs.

Soils removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and safety

Provides a high degree of long term effectiveness and permanence.

The unsaturated soil contaminated above the cleanup objectives will be permanently removed from the site.

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material requiring

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$893,000

$2,875

$1,017,000

R2-0000437

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 3 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

of ICs. regulations. be reduced. disposal off site.

Excavation activities are estimated to take 30 days.

4 CTFA -4: Enhanced fluid recovery (EFR), Excavation, and ICs

Provides overall protection of human health and the environment.

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance

Excavation and EFR would significantly reduce BTEX concentrations in the treatment area. Long-term effectiveness of the EFR largely relies on the effectiveness of the technology in the unsaturated zone alone.

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$814,000

$0

$1,548,000

R2-0000438

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 4 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

with air emission and health and safety regulations.

the AOC to a facility where mobility would be reduced.

Vapor extraction wells installed as part of the EFR would potentially capture and remove BTEX in the soil if determined to be effective in vadose soils, thus reducing the mobility, toxicity, and the source of the BTEX compounds in shallow overburden groundwater. Extracted vapor

of traffic due to the volume of material requiring disposal off site.

Excavation activities by air knife or vacuum are estimated to take 10 days.

EFR will be implemented monthly.

R2-0000439

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 5 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

would be treated for BTEX removal.

5 CTFA -5: Soil Vapor Extraction (SVE), Excavation, and ICs

Provides overall protection of human health and the environment.

Complies with applicable ARARs.

Waste removed will be chemically tested to properly characterize contaminated materials and verify compliance with LDRs. Dust and air monitoring will be conducted to verify compliance with air emission and health and

Excavation and SVE would significantly reduce BTEX concentrations in the treatment area. Horizontal SVE wells would provide minimal disruption of operations.

Provides limited reduction of toxicity by treatment of soils exceeding the TCLP requirements. Toxicity of untreated soils will not reduce. It would not provide reduction of volume of the contaminated materials but simply would move the materials from the AOC to a facility where mobility would

Will result in the highest short term impacts and highest degree of exposure to contaminated materials during implementation. Workers and community will be exposed to contaminants from dust generated during excavation activities. Will result in the highest degree of traffic due to the volume of material

Easily implemented. No special construction equipment is necessary.

Some coordination will be required with the property owner.

Capital Cost:

Average Annual O&M:

Total Present Worth:

$994,000

$0

$1,220,000

R2-0000440

Table 11 Comparative Analysis of Alternatives: AOC5 - CTFA

Maywood Chemical Company Superfund Site Page 6 of 6  

Feasibility Study 025-RICO-0219  

Alt. No.

Alternative Name

Overall Protection of

Human Health and

the Environment

Compliance with ARARs

Long Term Effectiveness

and Permanence

Reduction of Toxicity,

Mobility or Volume of

Contamination thru

Treatment

Short Term Impact and

Effectiveness Implementability Cost Effectiveness

safety regulations.

be reduced.

SVE would reduce the toxicity, mobility, and volume of VOCs in soils.

requiring disposal off site.

Excavation activities by air knife or vacuum are estimated to take 10 days.

SVE will be implemented continuously.

R2-0000441

Table 12 List of ARARs and TBCs

Maywood Chemical Company Superfund Site Page 1 of 1  

Feasibility Study 025-RICO-0219  

Applicable or Relevant and Appropriate Requirements (ARARs)

New Jersey Non-Residential Direct Contact Soil Cleanup Criteria (N.J.A.C. 7:26D)

The Remediation Standards rules (N.J.A.C. 7:26D-1.1)

The Technical Requirements for Site Remediation (N.J.A.C. 7:26E-1.3)

RCRA Standards Applicable to Generators of Hazardous Waste (40 CFR 262)

RCRA Standards Applicable to Characterization of Hazardous Waste (40 CFR 262.11)

RCRA Land Disposal Restrictions (40 CFR 268)

RCRA Prohibition on Storage of Restricted Waste (40 CFR 268 E)

RCRA Hazardous Waste Management Standards (40 CFR 264 & 265)

Release of Toxic Substance to Atmosphere (N.J.A.C. 7:27-17)

Release of VOCs to Atmosphere, (N.J.A.C. 7:27-16)

New Jersey Requirements for Erosion and Sedimentation Controls (N.J.S.A. 4:24-39)

Freshwater Wetlands Protection Area (N.J.A.C. 7:7A)

Protection of Wetlands (N.J.A.C. 7:7A)

To Be Considered (TBCs)

New Jersey Impact to Groundwater Soil Cleanup Criteria

EPA Regional Screening Levels (RSLs). November 2012 Tables

R2-0000442

Table 13Cost Estimate for Alternative BCA-2

AOC1-Buried Container Area

Pages 1 of 2

Buried Container Area

Institutional Controls

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 5,500$ 5,500$ 20.6 acre site

Sub-Total 5,500$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 60,000$ 60,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 25 Day 1,500$ 37,500$ Assumes 100 borings, 8 ft deep; 4 borings/day2.4 Steam Clean Equipment 25 Day 350$ 8,750$ inc. daily rental for steam cleaner and 2 hr/day for decon

2.5 Collect Soil Sample 485 EA 3$ 1,455$ 10 borings - 8 samples, 90 borings - 4 samples; inc. QC

2.6 Sample Analysis 485 EA 300$ 145,500$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 200 MH 150$ 30,000$ 2.8 H&S Monitoring 5 Week 300$ 1,500$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 316,705$

3 Reporting and Institutional Controls3.1 Site Management Plan 1 LS 5,000$ 5,000$ 3.2 Deed Restriction 1 LS 3,000$ 3,000$

Sub-Total 8,000$

Sub-Total 330,205$ Sub-Total All Construction Costs

Contingency 25% 83,000$ 10% scope + 15% bid

Sub-Total 413,205$

Project Management 10% 41,321$

TOTAL CAPITAL COST 455,000$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$

Sub-Total 1,500$

Sub-Total 1,500$ Contingency 15% 225$ Sub-Total 1,725$

TOTAL ANNUAL O&M COST 1,725$

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

Feasibility Study025-RICO-0219

R2-0000443

Table 13Cost Estimate for Alternative BCA-2

AOC1-Buried Container Area

Pages 2 of 2

Buried Container Area

Institutional Controls

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 455,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 1,725 30,000$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$ 3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 559,000$

Feasibility Study025-RICO-0219

R2-0000444

Table 14Cost Estimate for Alternative BCA-3

AOC1-Buried Container Area

Pages 1 of 5

Buried Container Area

In Situ Solidification, Excavation, Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 5,500$ 5,500$ 14.6 acre site

Sub-Total 5,500$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 60,000$ 60,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$

2.3 Direct Push Geoprobe Borings 25 Day 1,500$ 37,500$ Assumes 100 borings, 8 ft deep; 4 borings/day

2.4 Steam Clean Equipment 25 Day 350$ 8,750$ inc. daily rental for steam cleaner and 2 hr/day for decon equipment

2.5 Collect Soil Sample 485 EA 3$ 1,455$ 10 borings - 8 samples, 90 borings - 4 samples; inc. QC

2.6 Sample Analysis 485 EA 300$ 145,500$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 200 MH 150$ 30,000$ 2.8 H&S Monitoring 5 Week 300$ 1,500$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 316,705$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 50,000$ 50,000$ 3.2 Submittals/Implementation Plans 1 LS 30,000$ 30,000$ 3.3 Post Construction Submittals 1 LS 30,000$ 30,000$ 3.4 Decontamination Station 1 LS 3,500$ 3,500$ Portable decontamination pad/truck tire 3.5 Traffic Control 1 LS 2,000$ 2,000$

Sub-Total 115,500$

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ solidification of soil contaminated above PRGs in the groundwater table, excavation and off site disposal of buried containers and capping of contaminated soils above PRGs with an asphalt cap. Stabilized areas will also be capped with an asphalt cap.

Feasibility Study025-RICO-0219

R2-0000445

Table 14Cost Estimate for Alternative BCA-3

AOC1-Buried Container Area

Pages 2 of 5

Buried Container Area

In Situ Solidification, Excavation, Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ solidification of soil contaminated above PRGs in the groundwater table, excavation and off site disposal of buried containers and capping of contaminated soils above PRGs with an asphalt cap. Stabilized areas will also be capped with an asphalt cap.

4 Buried Containers4.1 Clearing and Grubbing 1 Acre 1,250$ 1,250$ wetland and surrounding area4.2 Strip Existing Pavement 5,137 SY 5$ 25,683$ 4.3 Perimeter Air Monitoring 6 Week 1,200$ 7,200$ 4.4 H&S Monitoring 6 Week 300$ 1,800$ 4.5 PPE and Field Supplies 1 LS 1,000$ 1,000$ 4.6 Magnetometer Survey 1 LS 20,000$ 20,000$

4.7 Excavate and Stockpile 14,373 CY 10$ 143,730$ Excavate buried containers & soil to 4 ft bgs

4.8 Stockpile Area - Dirty 12 EA 780$ 9,360$ Assumes liner underneath and covered with plastic anchored with sand bags

4.9 Dewatering 60,000 Gal 0.55$ $ 33,000

4.10 Water Waste Characterization Sampling 3 EA 1,000$ $ 3,000 TCLP/TAL/TCL/RAD for every 20,000 gal

4.11 Confirmatory Sampling 103 EA 300$ 31,020$ Total VOCs, SVOCs, and metals, inc. QC samples

4.12 Drum Staging Area 3 EA 2,000$ 6,000$

4.13 Waste Characterization Sampling 13 EA 950$ 12,350$

TCLP/TAL/TCL for 13 drums with liquid or solids

4.14 Over pack Container 13 EA 178$ 2,314$ for drums containing liquids/solids4.15 T&D of Over pack Container 13 EA 50$ 650$ for drums containing liquids/solids4.16 Empty Drum Disposal 17 EA 170$ 2,890$ 4.17 Hazardous Material Disposal 140 Ton 200$ 28,000$ Assumes 1.8 ton/cy;

4.18 Asphalt Disposal/Recycle 1,027 Ton 70$ 71,911$

Assumes 1 ton of asphalt covers 18SY, 1 inch thick

4.19 Oversight 6 Week 5,000$ 30,000$ 1 person full time oversight

Sub-Total 431,158$

5 Wetland Restoration & Soil Cap5.1 Permitting 1 LS 1,500$ 1,500$ state and federal permits5.2 Wetland Mitigation/Restoration 1 Acre 100,000$ 50,000$

5.3 Placement of Stockpiled Backfill 1,613 CY 10$ 16,133$ placement of onsite soil from 2-4 ft bgs. inc. compaction

5.4 Imported Backfill 1,210 CY 30$ 36,300$ inc. compaction; 2 ft cover

5.5 Backfill Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

5.6 Topsoil 403 CY 35$ 14,117$ 6 inches in vegetated areas

5.7 Topsoil Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

5.8 Hydro-seed 21,780 SF 0.12$ $ 2,614 5.9 Nonhazardous Disposal 2,904 Ton 100$ 290,400$ excess material to allow for 2 ft cap

Sub-Total 412,564$

Feasibility Study025-RICO-0219

R2-0000446

Table 14Cost Estimate for Alternative BCA-3

AOC1-Buried Container Area

Pages 3 of 5

Buried Container Area

In Situ Solidification, Excavation, Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ solidification of soil contaminated above PRGs in the groundwater table, excavation and off site disposal of buried containers and capping of contaminated soils above PRGs with an asphalt cap. Stabilized areas will also be capped with an asphalt cap.

6 In Situ Solidification6.1 Bench Scale Test 1 LS 8,500$ 8,500$ materials6.2 Strip Existing Pavement 306 SY 5$ 1,528$

6.3 Asphalt Disposal/Recycle 51 Ton 70$ 3,565$ Assumes 1 ton of asphalt covers 18SY, 1 inch thick

6.4 Excavate and Stockpile 400 CY 10$ 4,000$ excavate top 4 feet of overburden6.5 Placement of Stockpiled Backfill 400 CY 10$ 4,000$ inc. placement and compaction6.6 Portland Cement ( 20% by weight) 120 Ton 150$ 18,000$ 6.7 Sodium Silicate (5% by weight) 30 Ton 200$ 6,000$ 6.8 Mixing 4 to 8 feet bg 400 CY 5$ 2,000$ ~50 x 50 ft area6.9 Oversight 4 Week 5,000$ 20,000$ 1 person full time oversight

6.10 Nonhazardous Disposal 72 Ton 100$ 7,200$

accounts for expansion of stabilized soil assumes 10% shipped off site

Sub-Total 74,793$

7 Asphalt Cover

7.1 6" Asphalt 1,561 Ton 68$ 106,145$ Assumes 1 ton of asphalt covers 18SY, 1 inch thick

Sub-Total 106,145$

8 Reporting and Institutional Controls8.1 Remedial Action Report 1 LS 50,000$ 50,000$ 8.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$ 8.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 80,000$

Sub-Total 1,542,365$ Sub-Total All Construction Costs

Contingency 25% 386,000$ 10% scope + 15% bid

Sub-Total 1,928,365$

Project Management 5% 96,418$ Remedial Design 6% 115,702$ Construction Management 6% 115,702$

TOTAL CAPITAL COST 2,256,000$

Feasibility Study025-RICO-0219

R2-0000447

Table 14Cost Estimate for Alternative BCA-3

AOC1-Buried Container Area

Pages 4 of 5

Buried Container Area

In Situ Solidification, Excavation, Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ solidification of soil contaminated above PRGs in the groundwater table, excavation and off site disposal of buried containers and capping of contaminated soils above PRGs with an asphalt cap. Stabilized areas will also be capped with an asphalt cap.

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 2,000$ 2,000$ Inspect surface for cracks.

Sub-Total 2,000$

2 Wetland Maintenance & Inspections2.1 Wetland Inspections 1 LS 2,000$ 2,000$ 2.2 Wetland Maintenance 1 LS 1,000$ 1,000$

Sub-Total 3,000$

Sub-Total 5,000$ Contingency 15% 750$ Sub-Total 5,750$

TOTAL ANNUAL O&M COST (Years 1-10) 5,750$

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 2,000$ 2,000$ Inspect surface for cracks.

Sub-Total 2,000$

Sub-Total 2,000$ Contingency 15% 300$ Sub-Total 2,300$

TOTAL ANNUAL O&M COST (Years 11-30) 2,300$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification & Periodic Maintenance1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.1.2 Seal, Patch, & Repair Cracks 2 5,566 SY 2.50$ 13,915$ Assumes 10% of entire paved area

Sub-Total 16,915$

Annual Costs Years 1 - 10

Annual Costs Years 11 - 30

Feasibility Study025-RICO-0219

R2-0000448

Table 14Cost Estimate for Alternative BCA-3

AOC1-Buried Container Area

Pages 5 of 5

Buried Container Area

In Situ Solidification, Excavation, Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ solidification of soil contaminated above PRGs in the groundwater table, excavation and off site disposal of buried containers and capping of contaminated soils above PRGs with an asphalt cap. Stabilized areas will also be capped with an asphalt cap.

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

3 Resurface Asphalt3.1 Resurface Asphalt 15 55,660 SY 6.00$ 333,960$ Every 15 years through year 30.

Sub-Total 333,960$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 2,256,000$ 2 Annual O&M Cost

2.1 Years 1 - 10 1-10 5,800 47,000$ 2.2 Years 11 - 30 11-30 2,300 22,000$

3 Periodic Costs3.1 Year 2 2 16,915 15,674$ 3.2 Year 4 4 16,915 14,524$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 16,915 13,458$ 3.5 Year 8 8 16,915 12,471$ 3.6 Year 10 10 31,915 21,804$ 3.7 Year 12 12 16,915 10,708$ 3.8 Year 14 14 16,915 9,922$ 3.9 Year 15 15 348,960 197,050$ 3.10 Year 16 16 16,915 9,194$ 3.11 Year 18 18 16,915 8,520$ 3.12 Year 20 20 31,915 14,896$ 3.13 Year 22 22 16,915 7,316$ 3.14 Year 24 24 16,915 6,779$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 16,915 6,281$ 3.17 Year 28 28 16,915 5,821$ 3.18 Year 30 30 348,960 111,270$

Sub-Total 484,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 2,809,000$

Feasibility Study025-RICO-0219

R2-0000449

Table 15Cost Estimate for Alternative BCA-4

AOC1-Buried Container Area

Pages 1 of 4

Buried Container Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 5,500$ 5,500$ 20.6 acres

Sub-Total 5,500$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 60,000$ 60,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 25 Day 1,500$ 37,500$ Assumes 100 borings, 8 ft deep; 4 borings/day2.4 Steam Clean Equipment 25 Day 350$ 8,750$ inc. daily rental for steam cleaner and 2 hr/day for

2.5 Collect Soil Sample 485 EA 3$ 1,455$ 10 borings - 8 samples, 90 borings - 4 samples; inc. QC

2.6 Sample Analysis 485 EA 300$ 145,500$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 200 MH 150$ 30,000$ 2.8 H&S Monitoring 5 Week 300$ 1,500$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 316,705$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 50,000$ 50,000$ 3.2 Submittals/Implementation Plans 1 LS 30,000$ 30,000$ 3.3 Post Construction Submittals 1 LS 30,000$ 30,000$ 3.4 Decontamination Station 1 LS 3,500$ 3,500$ Portable decontamination pad/truck tire wash

Sub-Total 113,500$

4 Buried Containers4.1 Clearing and Grubbing 1 Acre 1,250$ 1,250$ wetland and surrounding area4.2 Strip Existing Pavement 5,137 SY 5$ 25,683$ 4.3 Perimeter Air Monitoring 6 Week 1,200$ 7,200$ 4.4 H&S Monitoring 6 Week 300$ 1,800$ 4.5 PPE and Field Supplies 1 LS 1,000$ 1,000$ 4.6 Magnetometer Survey 1 LS 20,000$ 20,000$ 4.7 Stockpile Area - Dirty 12 EA 780$ 9,360$ Assumes liner underneath and covered with plastic 4.8 Dewatering 60,000 Gal 0.55$ $ 33,000 4.9 Water Waste Characterization Sampling 3 EA 1,000$ $ 3,000 TCLP/TAL/TCL/RAD for every 20,000 gal

4.10 Confirmatory Sampling 103 EA 300$ 31,020$ Total VOCs, SVOCs, and metals, inc. QC samples4.11 Drum Staging Area 3 EA 2,000$ 6,000$ 4.12 Waste Characterization Sampling 13 EA 950$ 12,350$ TCLP/TAL/TCL for 13 drums with liquid or solids4.13 Over pack Container 13 EA 178$ 2,314$ for drums containing liquids4.14 T&D of Over pack Container 13 EA 50$ 650$ for drums containing liquids4.15 Empty Drum Disposal 17 EA 170$ 2,890$ 4.16 Hazardous Material Disposal 140 Ton 200$ 28,000$ Assumes 1.8 ton/cy4.17 Asphalt Disposal/Recycle 685 Ton 70$ 47,941$ Assumes 1 ton of asphalt covers 18SY, 1 inch thick4.18 Oversight 6 Week 5,000$ 30,000$ 1 person full time oversight

Sub-Total 263,457$

5 Wetland Restoration5.1 Permitting 1 LS 1,500$ 1,500$ state and federal permits5.2 Wetland Mitigation/Restoration 1.0 Acre 100,000$ 100,000$ inc. 2 ft hydric/clay soils for restoration & vegetation5.3 Imported Backfill 3,227 CY 30$ 96,800$ includes placement and compaction from 2-4 ft bgs

5.4 Backfill Source Sampling 6 EA 750$ 4,840$ PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 500 cy

Sub-Total 203,140$

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of soils contaminated above PRGs and buried containers.

Feasibility Study

025‐RICO‐0219

R2-0000450

Table 15Cost Estimate for Alternative BCA-4

AOC1-Buried Container Area

Pages 2 of 4

Buried Container Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of soils contaminated above PRGs and buried containers.

6 Excavation and Off Site Disposal6.1 Strip Existing Pavement 15 SY 5$ 75$ 6.2 Perimeter Air Monitoring 16 Week 1,200$ 19,200$ inc. monitoring for drum removal6.3 H&S Monitoring 16 Week 300$ 4,800$ inc. monitoring for drum removal6.4 PPE and Field Supplies 1 LS 1,000$ 1,000$

6.5 Excavate and Loadout 14,600 CY 10$ 146,000$ contaminated soils; inc. soil from buried container excavations

6.6 Excavate and Stockpile 400 CY 10$ 4,000$ clean backfill6.7 Stockpile Area - Dirty 1 EA 780$ 780$ Assumes liner underneath and covered with plastic 6.8 Confirmatory Sampling 5 EA 300$ 1,500$ Total VOCs, SVOCs, and metals, inc. QC samples6.9 Base Course 780 CY 55$ 42,926$ 6" base; inc. placement, material, compaction

6.10 6 inches Asphalt 1,561 Ton 68$ 106,145$ Assumes 1 ton of asphalt covers 18SY, 1 inch thick6.11 Imported Backfill 14,200 CY 30$ 426,000$ inc. placement and compaction6.12 Existing Clean Backfill 400 CY 10$ 4,000$ inc. placement and compaction

6.13 Backfill Source Sampling 28 EA 750$ 21,300$ PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 500 cy

6.14 Waste Characterization Sampling 15 EA 950$ 13,870$ TCLP/TAL/TCL for every 1000 cy6.15 Non-hazardous, Non-Radiological Disposal 23,652 Ton 100$ 2,365,200$ Assumes 1.8 ton/cy6.16 Hazardous, Non-Radiological Disposal 2,628 Ton 250$ 657,000$ Assumes 10% to be hazardous6.17 Asphalt Disposal/Recycle 3 Ton 70$ 175$ Assumes 1 ton of asphalt covers 18SY, 1 inch thick6.18 Oversight 16 Week 5,000$ 80,000$ 1 person full time oversight

Sub-Total 3,893,972$

7 Reporting and Institutional Controls7.1 Remedial Action Report 1 LS 50,000$ 50,000$ 7.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$ 7.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 80,000$

Sub-Total 4,876,274$ Sub-Total All Construction Costs

Contingency 25% 1,219,000$ 10% scope + 15% bid

Sub-Total 6,095,274$

Project Management 5% 304,764$ Remedial Design 6% 365,716$ Construction Management 6% 365,716$

TOTAL CAPITAL COST 7,131,000$

Feasibility Study

025‐RICO‐0219

R2-0000451

Table 15Cost Estimate for Alternative BCA-4

AOC1-Buried Container Area

Pages 3 of 4

Buried Container Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of soils contaminated above PRGs and buried containers.

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$

Sub-Total 1,500$

2 Wetland Maintenance & Inspections2.1 Wetland Inspections 1 LS 2,000$ 2,000$ 2.2 Wetland Maintenance 1 LS 1,000$ 1,000$

Sub-Total 3,000$

Sub-Total 4,500$ Contingency 15% 675$ Sub-Total 5,175$

TOTAL ANNUAL O&M COST (Years 1-10) 5,175$

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$

Sub-Total 1,500$

Sub-Total 1,500$ Contingency 15% 225$ Sub-Total 1,725$

TOTAL ANNUAL O&M COST (Years 11-30) 1,725$

Annual Costs Years 1 - 10

Annual Costs Years 11 - 30

Feasibility Study

025‐RICO‐0219

R2-0000452

Table 15Cost Estimate for Alternative BCA-4

AOC1-Buried Container Area

Pages 4 of 4

Buried Container Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of soils contaminated above PRGs and buried containers.

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 7,131,000$ 2 Annual O&M Cost

2.1 Years 1 - 10 1-10 5,200 42,000$ 2.2 Years 11 - 30 11-30 1,700 16,000$

3 Periodic Costs3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 2,576$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$ 3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 65,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 7,254,000$

Feasibility Study

025‐RICO‐0219

R2-0000453

Table 16Cost Estimate for Alternative GA-2

AOC2-Gypsum Area

Pages 1 of 2

AOC2 - Gypsum Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ 1.5 acre site

Sub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 20 Day 1,500$ 30,000$ Assumes 100 borings, 4 ft deep2.4 Steam Clean Equipment 20 Day 350$ 7,000$ inc. daily rental for steam cleaner and 2 hr/day for decon 2.5 Collect Soil Sample 400 EA 3$ 1,200$ collect samples at 1 ft intervals to 4 ft bgs2.6 Sample Analysis 400 EA 300$ 120,000$ VOCs, SVOCs, TAL inorganics2.7 Radiological Sampling 400 EA 15$ $ 6,000 2.8 Field Work Oversight 160 MH 150$ 24,000$ 2.9 H&S Monitoring 4 Week 300$ 1,200$

2.10 Pre-Design Report 1 LS 15,000$ 15,000$ Sub-Total 216,400$

3 Reporting and Institutional Controls3.1 Site Management Plan 1 LS 3,000$ 3,000$ 3.2 Deed Restriction 1 LS 3,200$ 3,200$

Sub-Total 6,200$

Sub-Total 223,600$ Sub-Total All Construction Costs

Contingency 25% 56,000$ 10% scope + 15% bid

Sub-Total 279,600$

Project Management 10% 27,960$

TOTAL CAPITAL COST 308,000$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,000$ 1,000$

Sub-Total 1,000$

Sub-Total 1,000$ Contingency 15% 150$ Sub-Total 1,150$

TOTAL ANNUAL O&M COST 1,150$

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

Feasibility Study025-RICO-0219

R2-0000454

Table 16Cost Estimate for Alternative GA-2

AOC2-Gypsum Area

Pages 2 of 2

AOC2 - Gypsum Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 7,500$ 7,500$ Every 5 years through year 30.

Sub-Total 7,500$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 308,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 1,150 20,170$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 7,500 6,199$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 10,500 7,173$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 7,500 4,235$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 10,500 4,901$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 7,500 2,893$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 10,500 3,348$

Sub-Total 50,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 378,000$

Feasibility Study025-RICO-0219

R2-0000455

Table 17Cost Estimate for Alternative GA-3

AOC2 - Gypsum Area

Pages 1 of 4

AOC2 - Gypsum Area

In Situ Solidification and Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ 1.5 acre site

Sub-Total 1,000$

2 Pre-Design Investigation

2.1 Investigation Work Plan 1 LS 10,000$ 10,000$

2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$

2.3 Direct Push Geoprobe Borings 20 Day 1,500$ 30,000$ Assumes 100 borings, 4 ft deep

2.4 Steam Clean Equipment 20 Day 350$ 7,000$ inc. daily rental for steam cleaner and 2 hr/day for decon equipment

2.5 Collect Soil Sample 400 EA 3$ 1,200$ collect samples at 1 ft intervals to 4 ft bgs

2.6 Sample Analysis 400 EA 300$ 120,000$ VOCs, SVOCs, TAL inorganics

2.7 Radiological Sampling 400 EA 15$ $ 6,000

2.8 Field Work Oversight 160 MH 150$ 24,000$ 2.9 H&S Monitoring 4 Week 300$ 1,200$

2.10 Pre-Design Report 1 LS 15,000$ 15,000$ Sub-Total 216,400$

3 Pilot Study3.1 Pilot Study 1 LS 70,000$ 70,000$ assumes test area of 15 x 15 feet

Sub-Total 70,000$

4 Site Mobilization/Demobilization4.1 Construction Equipment 1 LS 30,000$ $ 30,000.00 4.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000.00 4.3 Post Construction Submittals 1 LS 25,000$ $ 25,000.00 4.4 Decontamination Station 1 LS 500$ $ 500 Portable decontamination pad/truck tire wash

Sub-Total 80,500$

5 Health and Safety5.1 Perimeter Air Monitoring 3 Week 1,200$ $ 3,600 5.2 H&S Monitoring 3 Week 300$ $ 900 5.3 PPE and Field Supplies 1 LS 2,000$ $ 2,000

Sub-Total 6,500$

6 Site Preparation6.1 Temporary Security Fence 600 LF 30$ $ 18,000 6.2 Clearing and Grubbing 1.2 Acre 1,250$ $ 1,500 6.3 Excavate/Stockpile Clean Soil 3,528 CY 10$ $ 35,280 includes stockpile of clean backfill/topsoil

Sub-Total 54,780$

7 In Situ Solidification7.1 Portland Cement ( 20% by weight) 2,250 Ton 150$ $ 337,500 7.2 Sodium Silicate (5% by weight) 560 Ton 200$ $ 112,000 7.3 Mixing 0.5 to 4 feet 6,250 CY 5$ $ 31,250 7.4 Oversight 15 Day 1,000$ $ 15,000 1 person full time oversight

Sub-Total 495,750$

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ soldification and restoration with topsoil and grass, and institutional controls

Feasibility Study025-RICO-0219

R2-0000456

Table 17Cost Estimate for Alternative GA-3

AOC2 - Gypsum Area

Pages 2 of 4

AOC2 - Gypsum Area

In Situ Solidification and Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ soldification and restoration with topsoil and grass, and institutional controls

8 Restoration

8.1 Stockpiled Backfill 3,528 CY 10$ $ 35,280 Reuse onsite clean backfill; inc. compaction and placement

8.2 Imported Topsoil 770 CY 35$ $ 26,950 Assumes reuse of topsoil placed under FUSRAP remediation

8.3 Topsoil Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

8.4 Hydro-seed 52,272 SF 0.12$ $ 6,273 8.5 Wetland Mitigation 0.5 Acre 100,000$ $ 50,000

Sub-Total 119,253$

9 Offsite Disposal

9.1 Non-hazardous, Non-Radiological Disposal 1,125 Ton 100$ $ 112,500 Assumes 1.8 ton/cy ; excess material to account for expansion of stabilized waste and placement of cover soil

Sub-Total 112,500$

10 Reporting and Institutional Controls10.1 Remedial Action Report 1 LS 30,000$ 30,000$ 10.2 O&M/Site Management Plan 1 LS 15,000$ 15,000$ 10.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 50,000$

Sub-Total 1,206,683$ Sub-Total All Construction Costs

Contingency 25% 302,000$ 10% scope + 15% bid

Sub-Total 1,508,683$

Project Management 6% 90,521$ Remedial Design 12% 181,042$ Construction Management 8% 120,695$

TOTAL CAPITAL COST 1,901,000$

Feasibility Study025-RICO-0219

R2-0000457

Table 17Cost Estimate for Alternative GA-3

AOC2 - Gypsum Area

Pages 3 of 4

AOC2 - Gypsum Area

In Situ Solidification and Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ soldification and restoration with topsoil and grass, and institutional controls

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$ Inspect surface integrity; document results

Sub-Total 1,500$

2 Performance Monitoring2.1 Collect Groundwater Samples 1 LS 1,000$ 1,000$ Collect samples 2x / year

2.2 Sample Analysis 6 EA 300$ 1,800$ SVOCs, VOCs, Metals & cyanide, inc. QC samples

2.3 Data Evaluation 1 LS 500$ 500$ Sub-Total 3,300$

3 Wetland Maintenance & Inspections3.1 Wetland Inspections 1 LS 2,000$ 2,000$ 3.2 Wetland Maintenance 1 LS 1,000$ 1,000$

Sub-Total 3,000$

Sub-Total 7,800$ Contingency 15% 1,170$ Sub-Total 8,970$

TOTAL ANNUAL O&M COST (Years 1-10) 8,970$

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$ Inspect surface integrity; document results

Sub-Total 1,500$

2 Performance Monitoring2.1 Collect Groundwater Samples 1 LS 1,000$ 1,000$ Collect samples 2x / year

2.2 Sample Analysis 6 EA 300$ 1,800$ SVOCs, VOCs, Metals & cyanide, inc. QC samples

2.3 Data Evaluation 1 LS 500$ 500$ Sub-Total 3,300$

Sub-Total 4,800$ Contingency 15% 720$ Sub-Total 5,520$

TOTAL ANNUAL O&M COST (Years 11-30) 5,520$

Annual Costs Years 1 - 10

Annual Costs Years 11 - 30

Feasibility Study025-RICO-0219

R2-0000458

Table 17Cost Estimate for Alternative GA-3

AOC2 - Gypsum Area

Pages 4 of 4

AOC2 - Gypsum Area

In Situ Solidification and Capping

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of in situ soldification and restoration with topsoil and grass, and institutional controls

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification & Periodic Maintenance1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 10,000$ 10,000$ Every 5 years through year 30.

Sub-Total 10,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year

Total Cost Present Value Notes

1 Capital Cost 0 1,901,000$ 2 Annual O&M Cost

2.1 Years 1 - 10 1-10 9,000 73,000$ 2.2 Years 11 - 30 11-30 5,500 52,000$

3 Periodic Costs3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 10,000 8,265$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 13,000 8,881$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 10,000 5,647$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 13,000 6,068$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 10,000 3,858$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 13,000 4,145$

Sub-Total 58,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 2,084,000$

Feasibility Study025-RICO-0219

R2-0000459

Table 18Cost Estimate for Alternative GA-4

AOC2 - Gypsum Area

Pages 1 of 4

AOC2 - Gypsum Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ 1.5 acre site

Sub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 20 Day 1,500$ 30,000$ Assumes 100 borings, 4 ft deep

2.4 Steam Clean Equipment 20 Day 350$ 7,000$ inc. daily rental for steam cleaner and 2 hr/day for decon equipment

2.5 Collect Soil Sample 400 EA 3$ 1,200$ collect samples at 1 ft intervals to 4 ft bgs2.6 Sample Analysis 400 EA 300$ 120,000$ VOCs, SVOCs, TAL inorganics2.7 Radiological Sampling 400 EA 15$ $ 6,000 2.8 Field Work Oversight 160 MH 150$ 24,000$ 2.9 H&S Monitoring 4 Week 300$ 1,200$

2.10 Pre-Design Report 1 LS 15,000$ 15,000$ Sub-Total 216,400$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 QAPP, HASP, shop dwgs and work plans3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 6 Week 1,200$ $ 7,200 4.2 H&S Monitoring 6 Week 300$ $ 1,800 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 12,000$

5 Site Preparation5.1 Temporary Security Fence 600 LF 30$ $ 18,000 Temporary fence around AOC boundary5.2 Silt Fence 600 LF 3$ $ 1,800 Install silt fence around perimeter5.3 Clearing and Grubbing 1.2 Acre 1,250$ $ 1,500

Sub-Total 21,300$

6 Excavation6.1 Excavation and Loadout 8,125 CY 10$ $ 81,250 excavate contaminated soils

6.2 Stockpile Area - Dirty 2 EA 780$ $ 1,560 Assumes liner underneath and covered with plastic anchored with sand bags

6.3 Excavation and Stockpile Clean Soil 3,528 CY 10$ $ 35,280 includes stockpile of clean backfill6.4 Dewatering 60,000 Gal 0.55$ $ 33,000 6.5 Water Waste Characterization Sampling 3 EA 1,000$ $ 3,000 TCLP/TAL/TCL/RAD for every 20,000 gal6.6 Confirmatory Sampling 132 EA 300$ $ 39,600 Total VOCs, SVOCs, and metals6.7 Waste Characterization Sampling 12 EA 950$ $ 11,400 every 500 cy6.8 Radiological Sampling 12 EA 15$ $ 180 Every 500 cy

Sub-Total 205,270$

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal and institutional controls.

Feasibility Study025-RICO-0219

R2-0000460

Table 18Cost Estimate for Alternative GA-4

AOC2 - Gypsum Area

Pages 2 of 4

AOC2 - Gypsum Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal and institutional controls.

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 11,700 Ton 100$ $ 1,170,000.00 Assumes 1.8 ton/cy; assumes 80% 7.2 Hazardous, Non-Radiological Disposal 1,463 Ton 250$ $ 365,625.00 Assumes 10% 7.3 Low Level Radiological Disposal 54 Ton 47$ 2,546$ Assumes 10%

Sub-Total 1,538,171$

8 Site Restoration8.1 Imported Backfill 8,125 CY 30$ $ 243,750 inc. placement and compaction

8.2 Stockpiled Backfill 3,528 CY 10$ $ 35,280 Reuse onsite clean backfill; inc. compaction and placement

8.3 Backfill Source Sampling 8 EA 750$ $ 6,000 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

8.4 Topsoil 944 CY 35$ $ 33,040 Restore site not previously remediated under FUSRAP

8.5 Topsoil Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

8.6 Hydro-seed 50,995 SF 0.12$ $ 6,119 8.7 Wetland Restoration 0.5 Acre 100,000$ $ 50,000

Sub-Total 374,939$

9 Reporting and Institutional Controls9.1 Remedial Action Report 1 LS 50,000$ 50,000$ 9.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$ 9.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 80,000$

Sub-Total 2,532,580$ Sub-Total All Construction Costs

Contingency 25% 633,000$ 10% scope + 15% bid

Sub-Total 3,165,580$

Project Management 5% 158,279$ Remedial Design 8% 253,246$ Construction Management 6% 189,935$

TOTAL CAPITAL COST 3,767,000$

Feasibility Study025-RICO-0219

R2-0000461

Table 18Cost Estimate for Alternative GA-4

AOC2 - Gypsum Area

Pages 3 of 4

AOC2 - Gypsum Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal and institutional controls.

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,000$ 1,000$

Sub-Total 1,000$

2 Wetland Maintenance & Inspections2.1 Wetland Inspections 1 LS 2,000$ 2,000$ 2.2 Wetland Maintenance 1 LS 1,000$ 1,000$

Sub-Total 3,000$

Sub-Total 4,000$ Contingency 15% 600$ Sub-Total 4,600$

TOTAL ANNUAL O&M COST (Years 1-10) 4,600$

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,000$ 1,000$

Sub-Total 1,000$

Sub-Total 1,000$ Contingency 15% 150$ Sub-Total 1,150$

TOTAL ANNUAL O&M COST (Years 11-30) 1,150$

Annual Costs Years 1 - 10

Annual Costs Years 11 - 30

Feasibility Study025-RICO-0219

R2-0000462

Table 18Cost Estimate for Alternative GA-4

AOC2 - Gypsum Area

Pages 4 of 4

AOC2 - Gypsum Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal and institutional controls.

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 7,500$ 7,500$ Every 5 years through year 30.

Sub-Total 7,500$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 3,767,000$ 2 Annual O&M Cost

2.1 Years 1 - 10 1-10 4,600 38,000$ 2.2 Years 11 - 30 11-30 1,200 11,000$

3 Periodic Costs3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 7,500 6,199$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 10,500 7,173$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 7,500 4,235$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 10,500 4,901$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 7,500 2,893$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 10,500 3,348$

Sub-Total 50,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 3,866,000$

Feasibility Study025-RICO-0219

R2-0000463

Table 19Cost Estimate for Alternative LMA-2

AOC3 - Leather Material Area

Pages 1 of 2

AOC3 - Leather Material Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 2,500$ 2,500$ 3.35 acre site

Sub-Total 2,500$

2 Reporting and Institutional Controls2.1 Site Management Plan 1 LS 5,000$ 5,000$ 2.2 Deed Restriction 1 LS 3,000$ 3,000$

Sub-Total 8,000$

Sub-Total 10,500$

Contingency 25% 3,000$ 10% scope + 15% bid

Sub-Total 13,500$

Project Management 10% 1,350$

TOTAL CAPITAL COST 15,000$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

3 Annual Site Inspection3.1 Annual Site Inspection 1 LS 2,000$ 2,000$ 3.35 acre site

Sub-Total 2,000$

Contingency 15% 300$

TOTAL ANNUAL O&M COST 2,300$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

TOTAL PERIODIC COST 18,000$

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction on LMA-A and LMA-B

Feasibility Study025-RICO-0219

R2-0000464

Table 19Cost Estimate for Alternative LMA-2

AOC3 - Leather Material Area

Pages 2 of 2

AOC3 - Leather Material Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction on LMA-A and LMA-B

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 15,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 2,300 40,340$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 129,000$

Feasibility Study025-RICO-0219

R2-0000465

Table 20Cost Estimate for Alternative LMA-3

AOC3 - Leather Material Area

Pages 1 of 3

AOC3 - Leather Material Area

Capping

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 2,500$ 2,500$ 3.5 acre site

Sub-Total 2,500$

2 Pre-Design Investigation

2.1 Investigation Work Plan 1 LS 10,000$ 10,000$

2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$

2.3 Direct Push Geoprobe Borings 10 Day 1,500$ 15,000$ Assumes 40 borings, 12 ft deep; 4 borings/day

2.4 Steam Clean Equipment 10 Day 350$ 3,500$ inc. daily rental for steam cleaner and 2 hr/day for decon equipment

2.5 Collect Soil Sample 480 EA 3$ 1,440$ collect samples at 1 ft intervals from 0 - 12 ft bgs

2.6 Sample Analysis 480 EA 250$ 120,000$ TAL inorganics

2.7 Field Work Oversight 100 MH 150$ 15,000$ 2.8 H&S Monitoring 2 Week 300$ 600$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 197,540$

4 Site Mobilization/Demobilization4.1 Construction Equipment 1 LS 30,000$ $ 30,000 4.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 4.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 4.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

5 Health and Safety5.1 Perimeter Air Monitoring 2 Week 1,200$ $ 2,400 5.2 H&S Monitoring 2 Week 300$ $ 600 5.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 6,000$

6 Site Preparation6.1 Temporary Security Fence 1,766 LF 30$ $ 52,980 Temporary fence around AOC boundary6.2 Silt Fence 1,766 LF 3$ $ 5,298 Install silt fence around perimeter

Sub-Total 58,278$

7 Construction of Cap and Site Restoration

7.1 3 inches of Asphalt 1,640 TON 68$ $ 111,520 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer

Sub-Total 111,520$

COST ESTIMATE SUMMARY

Alternative 3 consists of capping LMA-A with asphalt and LMA-B with topsoil and grass, and institutional controls

Feasibility Study025-RICO-0219

R2-0000466

Table 20Cost Estimate for Alternative LMA-3

AOC3 - Leather Material Area

Pages 2 of 3

AOC3 - Leather Material Area

Capping

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of capping LMA-A with asphalt and LMA-B with topsoil and grass, and institutional controls

8 Reporting and Institutional Controls8.1 Remedial Action Report 1 LS 30,000$ 30,000$ 8.2 O&M/Site Management Plan 1 LS 5,000$ 5,000$ 8.3 Deed Restriction 1 LS 3,000$ 3,000$

Sub-Total 38,000$

Sub-Total 497,338$ Sub-Total All Construction Costs

Contingency 25% 124,000$ 10% scope + 15% bid

Sub-Total 621,338$

Project Management 5% 31,067$ Remedial Design 8% 49,707$ Construction Management 6% 37,280$

TOTAL CAPITAL COST 739,000$

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$ 1.2 Maintenance of Cap 1 LS 2,000$ 2,000$

Sub-Total 3,500$

Contingency 15% 525$ Sub-Total 525$

TOTAL ANNUAL O&M COST 4,025$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification & Periodic Maintenance1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

Feasibility Study025-RICO-0219

R2-0000467

Table 20Cost Estimate for Alternative LMA-3

AOC3 - Leather Material Area

Pages 3 of 3

AOC3 - Leather Material Area

Capping

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of capping LMA-A with asphalt and LMA-B with topsoil and grass, and institutional controls

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 739,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 4,025 70,596$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$ 3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 884,000$

Feasibility Study025-RICO-0219

R2-0000468

Table 21Cost Estimate for Alternative LMA-4

AOC3 - Leather Material Area

Pages 1 of 3

AOC3 - Leather Material Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 2,500$ 2,500$ 3.5 acre site

Sub-Total 2,500$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 10 Day 1,500$ 15,000$ Assumes 40 borings, 12 ft deep; 4 borings/day

2.4 Steam Clean Equipment 10 Day 350$ 3,500$ inc. daily rental for steam cleaner and 2 hr/day for decon equipment

2.5 Collect Soil Sample 480 EA 3$ 1,440$ collect samples at 1 ft intervals from 0 - 12 ft bgs2.6 Sample Analysis 480 EA 250$ 120,000$ TAL inorganics2.7 Field Work Oversight 100 MH 150$ 15,000$ 2.8 H&S Monitoring 2 Week 300$ 600$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 197,540$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 QAPP, HASP, shop dwgs and work plans3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 2 Week 1,200$ $ 2,400 4.2 H&S Monitoring 2 Week 300$ $ 600 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 6,000$

5 Site Preparation5.1 Temporary Security Fence 1,766 LF 30$ $ 52,980 Temporary fence around AOC boundary5.2 Silt Fence 1,766 LF 3$ $ 5,298 Install silt fence around perimeter

Sub-Total 58,278$

6 Excavation

6.1 Excavation6,559 CY 10$ $ 65,590

Excavate 6,089 CY of soils from LMA-A, 5 CY from hot spot, 465 CY from LMA-B

6.3 Stockpile Area - Dirty 3 EA 780$ $ 2,340 Assumes liner underneath and covered with plastic 6.4 Confirmatory Sampling 146 EA 300$ $ 43,800 Total VOCs, SVOCs, and metals

6.5 Waste Characterization Sampling13 EA 950$ $ 12,350

TCLP/TAL/TCL for every 500 CY. Total 6,559 CY anticipated.

6.6 Radiological Sampling 13 EA 15$ $ 195 RAD parameters

Sub-Total 124,275$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 9,269 Ton 100$ $ 926,928 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 1,159 Ton 250$ $ 289,665 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 1,159 Ton 47$ $ 54,457 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 1,271,050$

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of remaining contaminated materials in LMA-A and LMA-B and the "hot spot" in LMA-A and institutional controls.

Feasibility Study025-RICO-0219

R2-0000469

Table 21Cost Estimate for Alternative LMA-4

AOC3 - Leather Material Area

Pages 2 of 3

AOC3 - Leather Material Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of remaining contaminated materials in LMA-A and LMA-B and the "hot spot" in LMA-A and institutional controls.

8 Site Restoration8.1 Imported Backfill 6,437 CY 30$ $ 193,110 Assumes LMA-A and LMA-B backfilled to grade

8.2 Backfill Source Sampling 7 EA 750$ $ 5,250 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

8.3 3 inches of Asphalt 1,640 TON 68$ $ 111,520 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer

Sub-Total 309,880$

9 Reporting and Institutional Controls9.1 Remedial Action Report 1 LS 50,000$ 50,000$ 9.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$ 9.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 80,000$

Sub-Total 2,133,023$

Contingency 25% 533,000$ 10% scope + 15% bid

Sub-Total 2,666,023$

Project Management 5% 133,301$ Remedial Design 8% 213,282$ Construction Management 6% 159,961$

TOTAL CAPITAL COST 3,173,000$

ANNUAL O&M COST:No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$ 1.2 Maintenance of Cap 1 LS 2,000$ 2,000$

Sub-Total 3,500$

Contingency 15% 525$ Sub-Total 525$

TOTAL ANNUAL O&M COST 4,025$

Feasibility Study025-RICO-0219

R2-0000470

Table 21Cost Estimate for Alternative LMA-4

AOC3 - Leather Material Area

Pages 3 of 3

AOC3 - Leather Material Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of excavation and off site disposal of remaining contaminated materials in LMA-A and LMA-B and the "hot spot" in LMA-A and institutional controls.

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 3,173,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 4,025 70,596$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 3,318,000$

Feasibility Study025-RICO-0219

R2-0000471

Table 22Cost Estimate for Alternative FAA-2

AOC4 - Former Aromatics Area

Pages 1 of 2

AOC4 - Former Aromatics Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acre site

Sub-Total 1,000$

2 Reporting and Institutional Controls2.1 Site Management Plan 1 LS 5,000$ 5,000$ 2.2 Deed Restriction 1 LS 3,000$ 3,000$

Sub-Total 8,000$

Sub-Total 9,000$

Contingency 25% 2,000$ 10% scope + 15% bid

Sub-Total 11,000$

Project Management 10% 1,100$

TOTAL CAPITAL COST 12,100$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$

Sub-Total 1,500$

Contingency 15% 225$

TOTAL ANNUAL O&M COST 1,725$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

TOTAL PERIODIC COST 18,000$

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

Feasibility Study025-RICO-0219

R2-0000472

Table 22Cost Estimate for Alternative FAA-2

AOC4 - Former Aromatics Area

Pages 2 of 2

AOC4 - Former Aromatics Area

Institutional Controls

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 12,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 1,725 30,000$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 116,000$

Feasibility Study025-RICO-0219

R2-0000473

Table 23Cost Estimate for Alternative FAA-3

AOC4 - Former Aromatics Area

Pages 1 of 2

AOC4 - Former Aromatics Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acres

Sub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 10 Day 1,500$ 15,000$ Assumes 40 borings, 12 ft deep; 4 borings/day2.4 Steam Clean Equipment 10 Day 350$ 3,500$ inc. daily rental for steam cleaner and 2 hr/day for 2.5 Collect Soil Sample 480 EA 3$ 1,440$ collect samples at 1 ft intervals from 0 - 12 ft bgs2.6 Sample Analysis 480 EA 300$ 144,000$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 100 MH 150$ 15,000$ 2.8 H&S Monitoring 2 Week 300$ 600$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 221,540$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 4 Week 1,200$ $ 4,800 4.2 H&S Monitoring 4 Week 300$ $ 1,200 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 9,000$

5 Site Preparation5.1 Temporary Security Fence 540 LF 30$ $ 16,200 Temporary fence around AOC boundary5.2 Silt Fence 540 LF 3$ $ 1,620 Install silt fence around perimeter

Sub-Total 17,820$

6 Excavation

6.1 Excavation- Non utility areas2,320 CY 10$ $ 23,200

Excavate 2,320 CY of soils using conventional equipment from non-utility areas

6.2 Vacuum Excavation/Air knife- Utility areas

10 day 2,420$ $ 24,200

Excavate 900 CY of soils from utility areas by vacuum excavation/air knife. Assumes 90 CY removed per day. So, 900/90 = approx 10 days to complete

6.3 Stockpile Area - Dirty 3 EA 780$ $ 2,340 Assumes liner underneath and covered with plastic anchored with sand bags

6.4 Confirmatory Sampling 73 EA 300$ $ 21,900 Total VOCs, SVOCs, and metals6.5 Waste Characterization Sampling 6 EA 950$ $ 5,700 TCLP/TAL/TCL for every 500 cy6.6 Radiological Sampling 6 EA 15$ $ 90 RAD parameters

Sub-Total 77,430$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 4,637 Ton 100$ $ 463,700 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 580 Ton 250$ $ 145,000 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 580 Ton 47$ $ 27,260 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 635,960$

COST ESTIMATE SUMMARY

Alternative 3 consists of excavation and off site disposal.

Feasibility Study025-RICO-0219

R2-0000474

Table 23Cost Estimate for Alternative FAA-3

AOC4 - Former Aromatics Area

Pages 2 of 2

AOC4 - Former Aromatics Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of excavation and off site disposal.

8 Site Restoration

8.1 Imported Backfill to grade 3,220 CY 30$ $ 96,600 inc. utility areas, non utility areas, placement and compaction

8.2 Backfill Source Sampling 3 EA 750$ $ 2,250 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

8.3 3 inches of Asphalt 271Ton

68$ $ 18,428 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer

Sub-Total 117,278$

9 Reporting 9.1 Remedial Action Report 1 LS 50,000$ 50,000$

Sub-Total 50,000$

Sub-Total Capital costs 1,213,528$

Contingency 25% 303,000$ 10% scope + 15% bid

Sub-Total 1,516,528$

Project Management 5% 75,826$ Remedial Design 8% 121,322$ Construction Management 6% 90,992$

TOTAL CAPITAL COST 1,805,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 1,805,000$ 2 Annual O&M Cost $03 Periodic Costs $0

TOTAL PRESENT VALUE OF ALTERNATIVE 1,805,000$

Feasibility Study025-RICO-0219

R2-0000475

Table 24Cost Estimate for Alternative FAA-4

AOC4 - Former Aromatics Area

Page 1 of 3

AOC4 - Former Aromatics AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acresSub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 10 Day 1,500$ 15,000$ Assumes 40 borings, 12 ft deep; 4 borings/day2.4 Steam Clean Equipment 10 Day 350$ 3,500$ inc. daily rental for steam cleaner and 2 hr/day 2.5 Collect Soil Sample 480 EA 3$ 1,440$ collect samples at 1 ft intervals from 0 - 12 ft 2.6 Sample Analysis 480 EA 300$ 144,000$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 100 MH 150$ 15,000$ 2.8 H&S Monitoring 2 Week 300$ 600$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 221,540$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 4 Week 1,200$ $ 4,800 4.2 H&S Monitoring 4 Week 300$ $ 1,200 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 9,000$

5 Site Preparation5.1 Temporary Security Fence 540 LF 30$ $ 16,200 Temporary fence around AOC boundary5.2 Silt Fence 540 LF 3$ $ 1,620 Install silt fence around perimeter

Sub-Total 17,820$

6 Excavation in utility areas6.1 Vacuum Excavation/Air knife- Utility areas 10 day 2,420$ $ 24,200 Excavate 900 CY of soils from utility areas by

vacuum excavation/air knife. Assumes 90 CY removed per day. So, 900/90 = approx 10 days to complete

6.2 Stockpile Area - Dirty 2 EA 780$ $ 1,560 Assumes liner underneath and covered with plastic anchored with sand bags

6.3 Confirmatory Sampling 60 EA 300$ $ 18,000 Total VOCs, SVOCs, and metals6.4 Waste Characterization Sampling 2 EA 950$ $ 1,900 TCLP/TAL/TCL for every 500 CY. Total 900

CY anticipated from utility areas.6.5 Radiological Sampling 2 EA 15$ $ 30 RAD parameters

Sub-Total 45,690$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 1,296 Ton 100$ $ 129,600 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 162 Ton 250$ $ 40,500 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 162 Ton 47$ $ 7,614 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 177,714$

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal.

Feasibility Study025-RICO-0219

R2-0000476

Table 24Cost Estimate for Alternative FAA-4

AOC4 - Former Aromatics Area

Page 2 of 3

AOC4 - Former Aromatics AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal.

8 EFR in non utility areas8.1 Pilot Study 1 LS 25,000$ 25,000$ 8.2 Pre-EFR Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 67 prior to

implementation of EFR to determine impacts8.3 Installation of EFR wells 111 EA 1,000$ 111,000$ Assuming effective radius of 5 feet8.4 IDW (Soil Non-hazardous) 1 LS 5,000$ 5,000$ From EFR well installation8.5 Remedial Action Work Plan/Permitting 1 LS 20,000$ 20,000$ 8.6 Liquid disposal (if encountered) 1 EA 5,000$ 5,000$ Depth of wells will be determined during pilot

test to avoid extraction of liquid8.7 Waste Characterization Sampling of liquid 1 EA 950$ 950$ Assumed once only

Sub-Total 168,150$

9 Site Restoration9.1 Imported Backfill to grade 900 CY 30$ $ 27,000 inc. utility areas, placement and compaction

9.2 Backfill Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

9.3 3 inches of Asphalt 270 TON 68$ $ 18,360 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer, includes surface seal for EFR

Sub-Total 46,110$

10 Reporting and Institutional Controls10.1 Remedial Action Report 1 LS 50,000$ 50,000$ 10.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$

Sub-Total 75,000$

Sub-Total Capital costs 845,524$

Contingency 25% 211,000$ 10% scope + 15% bidSub-Total 1,056,524$

Project Management 5% 52,826$ Remedial Design 8% 84,522$ Construction Management 6% 63,391$

TOTAL CAPITAL COST 1,257,000$

Feasibility Study025-RICO-0219

R2-0000477

Table 24Cost Estimate for Alternative FAA-4

AOC4 - Former Aromatics Area

Page 3 of 3

AOC4 - Former Aromatics AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal.

PERIODIC COSTS:Item No.

Description Year Quantity Unit Unit Cost Total Notes

1 Operations Costs 1 Every year through year 5.1.1 Monthly EFR event including emission control 1,332 per hour 350$ 466,200$ Assumes 1 hour per well, total 111 hours in the

month1.2 Annual Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 67 annually1.3 Monthly Vapor Effluent Sample 12 EA 300$ 3,600$ 1.4 Air sample collection (labor and equipment) 1 LS 2,500$ 2,500$ 1.5 Maintenance of Asphalt Seal 1 LS 1,000$ 1,000$ 1.6 Yearly Report 1 LS 10,000$ 10,000$ 1.7 Project Management 1 LS 5,000$ 5,000$ 1.8 Technical Support 1 LS 5,000$ 5,000$

Sub-Total 494,500$

2 Five Year Review 3.1 Five Year Review 5 1 LS 15,000$ 15,000$ End of 5 years.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No.

Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 1,257,000$ 2 Annual O&M Cost $03 Periodic Costs

3.1 Year 1 1 494,500 458,219$ 3.2 Year 2 2 494,500 441,089$ 3.3 Year 3 3 494,500 421,125$ 3.4 Year 4 4 494,500 441,089$ 3.5 Year 5 5 509,500 421,125$

Sub-Total 2,183,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 3,440,000$

Feasibility Study025-RICO-0219

R2-0000478

Table 25Cost Estimate for Alternative FAA-5

AOC4 - Former Aromatics Area

Page 1 of 3

AOC4 - Former Aromatics AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acresSub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 10 Day 1,500$ 15,000$ Assumes 40 borings, 12 ft deep; 4 borings/day2.4 Steam Clean Equipment 10 Day 350$ 3,500$ inc. daily rental for steam cleaner and 2 hr/day 2.5 Collect Soil Sample 480 EA 3$ 1,440$ collect samples at 1 ft intervals from 0 - 12 ft 2.6 Sample Analysis 480 EA 300$ 144,000$ VOCs, SVOCs, TAL inorganics2.7 Field Work Oversight 100 MH 150$ 15,000$ 2.8 H&S Monitoring 2 Week 300$ 600$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 221,540$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 4 Week 1,200$ $ 4,800 4.2 H&S Monitoring 4 Week 300$ $ 1,200 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 9,000$

5 Site Preparation5.1 Temporary Security Fence 540 LF 30$ $ 16,200 Temporary fence around AOC boundary5.2 Silt Fence 540 LF 3$ $ 1,620 Install silt fence around perimeter

Sub-Total 17,820$

6 Excavation in utility areas6.1 Vacuum Excavation/Air knife- Utility areas 10 day 2,420$ $ 24,200 Excavate 900 CY of soils from utility areas by

vacuum excavation/air knife. Assumes 90 CY removed per day. So, 900/90 = approx 10 days to complete

6.2 Stockpile Area - Dirty 2 EA 780$ $ 1,560 Assumes liner underneath and covered with plastic anchored with sand bags

6.3 Confirmatory Sampling 60 EA 300$ $ 18,000 Total VOCs, SVOCs, and metals6.4 Waste Characterization Sampling 2 EA 950$ $ 1,900 TCLP/TAL/TCL for every 500 CY. Total 900

CY anticipated from utility areas.6.5 Radiological Sampling 2 EA 15$ $ 30 RAD parameters

Sub-Total 45,690$

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, excavation and off site disposal, and institutional controls.

Feasibility Study025-RICO-0219

R2-0000479

Table 25Cost Estimate for Alternative FAA-5

AOC4 - Former Aromatics Area

Page 2 of 3

AOC4 - Former Aromatics AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, excavation and off site disposal, and institutional controls.

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 1,296 Ton 100$ $ 129,600 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 162 Ton 250$ $ 40,500 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 162 Ton 47$ $ 7,614 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 177,714$

8 SVE in non utility areas8.1 Pilot Test Work Plan 1 LS 15,000$ 15,000$ 8.2 Pilot Test

Mobilization/Demobilization 1 LS 7,150$ 7,150$ 50 FT 121$ $ 6,050 Assuming the well is 50 feet long

Well development 1 EA 1,650$ $ 1,650 Assuming 1 well for pilot testInstallation of performance monitoring points 4 EA 1,500$ 6,000$ Assuming 4 locationsTrailer with Blower and Treatment System Rental 1 LS 8,000$ 8,000$ Field Testing 1 LS 10,000$ 10,000$ Pre-SVE Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 67 prior to

implementation of SVE to determine impactsAir Sampling (equipment and labor) 1 LS 5,000$ 5,000$ Data Reduction/Evaluation and Reporting 1 LS 7,500$ 7,500$

8.3 Remedial Action Work Plan/Permitting 1 LS 20,000$ 20,000$ 8.4 Contractor Mobilization/Demobilization 1 LS 30,000$ 30,000$ 8.5 System Construction

Well design 1 LS 22,000$ $ 22,000 950 FT 121$ $ 114,950 Assuming each well is 50 to 100 feet long

Well development 12 EA 1,650$ $ 19,800 Remaining wellsIDW (Soil Non-hazardous) 1 LS 5,000$ 5,000$ From SVE well installationTransmission piping and trenching 300 LF 40$ 12,000$ Treatment Building/Shed 1 LS 15,000$ 15,000$ Condensate Knockout Tank 1 LS 3,000$ 3,000$ Condensate Pump 1 LS 1,500$ 1,500$ Vapor Phase GAC Vessels 2 EA 10,000$ 20,000$ Two 2,000 lb GAC vesselsPiping, instrumentation and valves 1 LS 10,000$ 10,000$ HVAC Systems 1 LS 3,000$ 3,000$ Electrical Control Panel and Wiring 1 LS 3,500$ 3,500$ Electrical Service Drop 1 LS 3,000$ 3,000$ System Assembly 1 LS 10,000$ 10,000$ Auto Dialer 1 LS 5,000$ 5,000$

8.6 System Startup 1 LS 10,000$ 10,000$ 8.7 Air permitting 1 LS 5,000$ 5,000$

Sub-Total 380,300$

9 Site Restoration9.1 Imported Backfill to grade 900 CY 30$ $ 27,000 inc. utility areas, placement and compaction

9.2 Backfill Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals analysis, every 1,000 cy

9.3 3 inches of Asphalt 270 TON 68$ $ 18,360 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer, includes surface seal for SVE

Sub-Total 46,110$

Installation of horizontal wells via directional drilling

Installation of one horizontal well via directional drilling

Feasibility Study025-RICO-0219

R2-0000480

Table 25Cost Estimate for Alternative FAA-5

AOC4 - Former Aromatics Area

Page 3 of 3

AOC4 - Former Aromatics AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, excavation and off site disposal, and institutional controls.

10 Reporting and Institutional Controls10.1 Remedial Action Report 1 LS 50,000$ 50,000$ 10.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$

Sub-Total 75,000$

Sub-Total Capital costs 1,057,674$

Contingency 25% 264,000$ 10% scope + 15% bidSub-Total 1,321,674$

Project Management 5% 66,084$ Remedial Design 8% 105,734$ Construction Management 6% 79,300$

TOTAL CAPITAL COST 1,573,000$

PERIODIC COSTS:Item No.

Description Year Quantity Unit Unit Cost Total Notes

1 Operations Costs 1 Every year through year 5.1.1 Annual Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 67 annually1.2 Performance monitoring sampling (labor and equipment) 2 EA 1,000$ 2,000$ Assumes twice a year1.3 Monthly Vapor Effluent Sample 12 EA 300$ 3,600$ 1.4 Air sample collection (labor and equipment) 1 LS 2,500$ 2,500$ 1.5 Maintenance of Asphalt Seal 1 LS 1,000$ 1,000$ 1.6 Yearly Report 1 LS 10,000$ 10,000$ 1.7 Electrical Usage 60,000 Kw 0.15$ 9,000$ 1.8 Vapor Carbon Change out 2,000 LB 3.30$ 6,600$ change out lead vessels 1x per year1.9 Maintenance of SVE system 1 LS 2,000$ 2,000$

1.10 Project Management 1 LS 5,000$ 5,000$ 1.11 Technical Support 1 LS 5,000$ 5,000$

Sub-Total 47,900$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ End of 5 years.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No.

Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 1,573,000$

2 Annual O&M Cost $0.003 Periodic Costs

3.1 Year 1 1 47,900 44,386$ 3.2 Year 2 2 47,900 41,129$ 3.3 Year 3 3 47,900 41,129$ 3.4 Year 4 4 47,900 41,129$ 3.5 Year 5 5 62,900 51,990$

Sub-Total 220,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 1,793,000$

Feasibility Study025-RICO-0219

R2-0000481

Table 26Cost Estimate for Alternative CTFA-2

AOC5 - Central Tank Farm Area

Pages 1 of 2

AOC5 - Central Tank Farm Area

Institutional Controls

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.07 acre site

Sub-Total 1,000$

2 Reporting and Institutional Controls3.1 Site Management Plan 1 LS 5,000$ 5,000$ 3.2 Deed Restriction 1 LS 3,000$ 3,000$

Sub-Total 8,000$

Sub-Total 9,000$

Contingency 25% 2,000$ 10% scope + 15% bid

Sub-Total 11,000$

Project Management 10% 1,100$

TOTAL CAPITAL COST 12,100$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

3 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$

Sub-Total 1,500$

Contingency 15% 225$

TOTAL ANNUAL O&M COST 1,725$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

TOTAL PERIODIC COST 18,000$

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

Feasibility Study025-RICO-0219

R2-0000482

Table 26Cost Estimate for Alternative CTFA-2

AOC5 - Central Tank Farm Area

Pages 2 of 2

AOC5 - Central Tank Farm Area

Institutional Controls

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 2 consists of institutional controls in the form of a deed restriction

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 12,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 1,725 30,000$ 3 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$ 3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 116,000$

Feasibility Study025-RICO-0219

R2-0000483

Table 27Cost Estimate for Alternative CTFA-3

AOC5 - Central Tank Farm Area

Pages 1 of 3

AOC5 - Central Tank Farm Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.07 acres

Sub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 4 Day 1,500$ 6,000$ Assumes 15 borings, 12 ft deep; 4 borings/day2.4 Steam Clean Equipment 4 Day 350$ 1,400$ inc. daily rental for steam cleaner and 2 hr/day for 2.5 Collect Soil Sample 180 EA 3$ 540$ collect samples at 1 ft intervals from 0 - 12 ft bgs

2.6 Sample Analysis 180 EA 450$ 81,000$ VOCs, SVOCs, TAL inorganics, TPH if product observed

2.7 Field Work Oversight 40 MH 150$ 6,000$ 2.8 H&S Monitoring 1 Week 300$ 300$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 137,240$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire wash

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 2 Week 1,200$ $ 2,400 4.2 H&S Monitoring 2 Week 300$ $ 600 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 6,000$

5 Site Preparation5.1 Temporary Security Fence 350 LF 30$ $ 10,500 Temporary fence around AOC boundary5.2 Silt Fence 350 LF 3$ $ 1,050 Install silt fence around perimeter

Sub-Total 11,550$

6 Excavation6.1 Shoring 1,600 SF 36$ $ 57,600

6.2 Excavation- Non utility areas300 CY 10$ $ 3,000

Excavate 300 CY of soils using conventional equipment from non-utility areas

6.3 Vacuum Excavation/Air knife- Utility areas

6 day 2,420$ $ 14,520

Excavate 500 CY of soils from utility areas by vacuum excavation/air knife. Assumes 90 CY removed per day. So, 500/90 = approx 6 days to complete

6.4 Stockpile Area - Dirty 2 EA 780$ $ 1,560 Assumes liner underneath and covered with plastic anchored with sand bags

6.5 Confirmatory Sampling 52 EA 300$ $ 15,600 Total VOCs, SVOCs, and metals

6.6 Waste Characterization Sampling2 EA 950$ $ 1,900

TCLP/TAL/TCL for every 500 CY. Total 800 CY anticipated.

6.7 Radiological Sampling 2 EA 15$ $ 30 RAD parametersSub-Total 94,210$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 1,152 Ton 100$ $ 115,200 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 144 Ton 250$ $ 36,000 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 144 Ton 47$ $ 6,768 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 157,968$

COST ESTIMATE SUMMARY

Alternative 3 consists of excavation and off site disposal and institutional controls.

Feasibility Study025-RICO-0219

R2-0000484

Table 27Cost Estimate for Alternative CTFA-3

AOC5 - Central Tank Farm Area

Pages 2 of 3

AOC5 - Central Tank Farm Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of excavation and off site disposal and institutional controls.

8 Site Restoration

8.1 Imported Backfill to grade 800 CY 30$ $ 24,000 inc. utility areas, non utility areas, placement and compaction

8.3 Backfill Source Sampling 1 EA 750$ $ 750 1,000 cy

8.4 3 inches of Asphalt 60 TON 68$ $ 4,080 Assumes 1 ton of asphalt covers 18 SY, 1 inch thick layer

Sub-Total 28,830$

9 Reporting and Institutional Controls9.1 Remedial Action Report 1 LS 50,000$ 50,000$ 9.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$ 9.3 Deed Restriction 1 LS 5,000$ 5,000$

Sub-Total 80,000$

Sub-Total Capital costs 600,298$

Contingency 25% 150,000$ 10% scope + 15% bid

Sub-Total 750,298$

Project Management 5% 37,515$ Remedial Design 8% 60,024$ Construction Management 6% 45,018$

TOTAL CAPITAL COST 893,000$

ANNUAL O&M COST:Item No. Description Quantity Unit Unit Cost Total Notes

1 Annual Site Inspection1.1 Annual Site Inspection 1 LS 1,500$ 1,500$ 1.2 Maintenance of Asphalt 1 LS 1,000$ 1,000$

Sub-Total 2,500$

Contingency 15% 375$ Sub-Total 375$

TOTAL ANNUAL O&M COST 2,875$

PERIODIC COSTS:Item No. Description Year Quantity Unit Unit Cost Total Notes

1 Deed Restriction Certification1.1 Biennial deed restriction certification 2 1 LS 3,000$ 3,000$ Every 2 years through year 30.

Sub-Total 3,000$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ Every 5 years through year 30.

Sub-Total 15,000$

Feasibility Study025-RICO-0219

R2-0000485

Table 27Cost Estimate for Alternative CTFA-3

AOC5 - Central Tank Farm Area

Pages 3 of 3

AOC5 - Central Tank Farm Area

Excavation and Offsite Disposal

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: May 16, 2013

Item No. Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 3 consists of excavation and off site disposal and institutional controls.

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No. Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 893,000$ 2 Annual O&M Cost

2.1 Years 1 - 30 1-30 2,875 $50,0003 Periodic Costs

3.1 Year 2 2 3,000 2,780$ 3.2 Year 4 4 3,000 2,576$ 3.3 Year 5 5 15,000 12,398$ 3.4 Year 6 6 3,000 2,387$ 3.5 Year 8 8 3,000 2,212$ 3.6 Year 10 10 18,000 12,297$ 3.7 Year 12 12 3,000 1,899$ 3.8 Year 14 14 3,000 1,760$ 3.9 Year 15 15 15,000 8,470$

3.10 Year 16 16 3,000 1,631$ 3.11 Year 18 18 3,000 1,511$ 3.12 Year 20 20 18,000 8,401$ 3.13 Year 22 22 3,000 1,297$ 3.14 Year 24 24 3,000 1,202$ 3.15 Year 25 25 15,000 5,787$ 3.16 Year 26 26 3,000 1,114$ 3.17 Year 28 28 3,000 1,032$ 3.18 Year 30 30 18,000 5,740$

Sub-Total 74,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 1,017,000$

Feasibility Study025-RICO-0219

R2-0000486

Table 28Cost Estimate for Alternative CTFA-4

AOC5 - Central Tank Farm Area

Page 1 of 3

AOC5 - Central Tank Farm AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acresSub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization for PDI 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 4 Day 1,500$ 6,000$ Assumes 15 borings, 12 ft deep; 4 2.4 Steam Clean Equipment 4 Day 350$ 1,400$ inc. daily rental for steam cleaner and 2 2.5 Collect Soil Sample 180 EA 3$ 540$ collect samples at 1 ft intervals from 0 - 2.6 Sample Analysis 180 EA 450$ 81,000$ VOCs, SVOCs, TAL inorganics, TPH if

product observed2.7 Field Work Oversight 40 MH 150$ 6,000$ 2.8 H&S Monitoring 1 Week 300$ 300$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 137,240$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 2 Week 1,200$ $ 2,400 4.2 H&S Monitoring 2 Week 300$ $ 600 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 6,000$

5 Preparation5.1 Temporary Security Fence 350 LF 30$ $ 10,500 Temporary fence around AOC

boundary5.2 Silt Fence 350 LF 3$ $ 1,050 Install silt fence around perimeter

Sub-Total 11,550$

6 Excavation in utility areas6.1 Vacuum Excavation/Air knife- Utility areas 6 day 2,420$ $ 14,520 Excavate 500 CY of soils from utility

areas by vacuum excavation/air knife. Assumes 90 CY removed per day. So, 500/90 = approx 6 days to complete

6.2 Stockpile Area - Dirty 1 EA 780$ $ 780 Assumes liner underneath and covered with plastic anchored with sand bags

6.3 Confirmatory Sampling 35 EA 300$ $ 10,500 Total VOCs, SVOCs, and metals6.4 Waste Characterization Sampling 1 EA 950$ $ 950 TCLP/TAL/TCL for every 500 CY.

Total 500 CY anticipated from utility 6.5 Radiological Sampling 1 EA 15$ $ 15 RAD parameters

Sub-Total 26,765$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 720 Ton 100$ $ 72,000 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 90 Ton 250$ $ 22,500 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 90 Ton 47$ $ 4,230 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 98,730$

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal

Feasibility Study025-RICO-0219

R2-0000487

Table 28Cost Estimate for Alternative CTFA-4

AOC5 - Central Tank Farm Area

Page 2 of 3

AOC5 - Central Tank Farm AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal

8 EFR in non utility areas8.1 Pilot Study 1 LS 25,000$ 25,000$ 8.2 Pre-EFR Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 10

prior to implementation of EFR to determine impacts

8.3 Installation of EFR wells 32 EA 1,000$ $ 32,000 Assuming effective radius of 5 feet8.4 IDW (Soil Non-hazardous) 1 LS 5,000$ $ 5,000 From EFR well installation8.5 Remedial Action Work Plan/Permitting 1 LS 20,000$ $ 20,000 8.6 Liquid disposal (if encountered) 1 EA 5,000$ $ 5,000 Depth of wells will be determined

during pilot test to avoid extraction of 8.7 Waste Characterization Sampling of liquid 1 EA 950$ $ 950 Assumed once only

Sub-Total 89,150$

9 Site Restoration9.1 Imported Backfill to grade 500 CY 30$ $ 15,000 inc. utility areas, non utility areas,

placement and compaction9.2 Backfill Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs,

metals analysis, every 1,000 cy9.3 3 inches of Asphalt 40 TON 68$ $ 2,720 Assumes 1 ton of asphalt covers 18 SY,

1 inch thick layerSub-Total 18,470$

10 Reporting and Institutional Controls10.1 Remedial Action Report 1 LS 50,000$ 50,000$ 10.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$

Sub-Total 75,000$

Sub-Total Capital costs 547,405$

Contingency 25% 137,000$ 10% scope + 15% bidSub-Total 684,405$

Project Management 5% 34,220$ Remedial Design 8% 54,752$ Construction Management 6% 41,064$

TOTAL CAPITAL COST 814,000$

Feasibility Study025-RICO-0219

R2-0000488

Table 28Cost Estimate for Alternative CTFA-4

AOC5 - Central Tank Farm Area

Page 3 of 3

AOC5 - Central Tank Farm AreaIn Situ Enhanced Fluid Recovery/Excavation

Site: Maywood Chemical Company Superfund Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 4 consists of EFR, and excavation and off site disposal

PERIODIC COSTS:Item No.

Description Year Quantity Unit Unit Cost Total Notes

1 Yearly Operations Costs 1 Every year through year 5.1.1 Monthly EFR event including emission control 384 per hour 350$ 134,400$ Assumes 1 hour per well, total 32 hours

1.2 Annual Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 10 annually

1.3 Monthly Vapor Effluent Sample 12 EA 300$ 3,600$ 1.4 Air sample collection (labor and equipment) 1 LS 2,500$ 2,500$ 1.5 Maintenance of Asphalt Seal 1 LS 1,000$ 1,000$ 1.6 Yearly Report 1 LS 10,000$ 10,000$ 1.7 Project Management 1 LS 5,000$ 5,000$ 1.8 Technical Support 1 LS 5,000$ 5,000$

Sub-Total 162,700$

2 Five Year Review 2.1 Five Year Review 5 1 LS 15,000$ 15,000$ End of 5 years.

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No.

Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 814,000$ 2 Annual Maintenance Cost $0.003 Periodic Costs

3.1 Year 1 1 162,700 156,618$ 3.1 Year 2 2 162,700 150,763$ 3.1 Year 3 3 162,700 139,702$ 3.2 Year 4 4 162,700 139,702$ 3.3 Year 5 5 177,700 146,877$

Sub-Total 734,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 1,548,000$

Feasibility Study025-RICO-0219

R2-0000489

Table 29Cost Estimate for Alternative CTFA-5

AOC5 - Central Tank Farm Area

Page 1 of 3

AOC5 - Central Tank Farm AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

CAPITAL COSTS:1 Site Survey

1.1 Survey 1 LS 1,000$ 1,000$ approx 0.3 acresSub-Total 1,000$

2 Pre-Design Investigation2.1 Investigation Work Plan 1 LS 10,000$ 10,000$ 2.2 Geoprobe Mobilization 1 LS 2,000$ 2,000$ 2.3 Direct Push Geoprobe Borings 4 Day 1,500$ 6,000$ Assumes 15 borings, 12 ft deep; 4 2.4 Steam Clean Equipment 4 Day 350$ 1,400$ inc. daily rental for steam cleaner and 2 2.5 Collect Soil Sample 180 EA 3$ 540$ collect samples at 1 ft intervals from 0 - 2.6 Sample Analysis 180 EA 450$ 81,000$ VOCs, SVOCs, TAL inorganics, TPH if 2.7 Field Work Oversight 40 MH 150$ 6,000$ 2.8 H&S Monitoring 1 Week 300$ 300$ 2.9 Pre-Design Report 1 LS 30,000$ 30,000$

Sub-Total 137,240$

3 Site Mobilization/Demobilization3.1 Construction Equipment 1 LS 30,000$ $ 30,000 3.2 Submittals/Implementation Plans 1 LS 25,000$ $ 25,000 3.3 Post Construction Submittals 1 LS 25,000$ $ 25,000 3.4 Decontamination Station 1 LS 3,500$ $ 3,500 Portable decontamination pad/truck tire

Sub-Total 83,500$

4 Health and Safety4.1 Perimeter Air Monitoring 2 Week 1,200$ $ 2,400 4.2 H&S Monitoring 2 Week 300$ $ 600 4.3 PPE and Field Supplies 1 LS 3,000$ $ 3,000

Sub-Total 6,000$

5 Site Preparation5.1 Temporary Security Fence 350 LF 30$ $ 10,500 Temporary fence around AOC boundary

5.2 Silt Fence 350 LF 3$ $ 1,050 Install silt fence around perimeterSub-Total 11,550$

6 Excavation in utility areas6.1 Vacuum Excavation/Air knife- Utility areas 6 day 2,420$ $ 14,520 Excavate 500 CY of soils from utility

areas by vacuum excavation/air knife. Assumes 90 CY removed per day. So, 500/90 = approx 6 days to complete

6.2 Stockpile Area - Dirty 1 EA 780$ $ 780 Assumes liner underneath and covered with plastic anchored with sand bags

6.3 Confirmatory Sampling 35 EA 300$ $ 10,500 Total VOCs, SVOCs, and metals6.4 Waste Characterization Sampling 1 EA 950$ $ 950 TCLP/TAL/TCL for every 500 CY. Total 6.5 Radiological Sampling 1 EA 15$ $ 15 RAD parameters

Sub-Total 26,765$

7 Offsite Disposal7.1 Non-hazardous, Non-Radiological Disposal 720 Ton 100$ $ 72,000 Assumes 1.8 ton/cy; 80% nonhazardous7.2 Hazardous, Non-Radiological Disposal 90 Ton 250$ $ 22,500 Assumes 1.8 ton/cy; 10% hazardous7.3 Radiological Disposal 90 Ton 47$ $ 4,230 Assumes 1.8 ton/cy; 10% radiological

Sub-Total 98,730$

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, and excavation and off site disposal

Feasibility Study025-RICO-0219

R2-0000490

Table 29Cost Estimate for Alternative CTFA-5

AOC5 - Central Tank Farm Area

Page 2 of 3

AOC5 - Central Tank Farm AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, and excavation and off site disposal

8 SVE in non utility areas8.1 Pilot Test Work Plan 1 LS 7,500$ 7,500$ 8.2 Pilot Test

Mobilization/Demobilization 1 LS 7,150$ 7,150$ 40 FT 121$ $ 4,840 Assuming the well is 40 feet long

Well development 1 EA 1,650$ $ 1,650 Assuming 1 well for pilot testInstallation of performance monitoring points 4 EA 1,500$ 6,000$ Assuming 4 locationsTrailer with Blower and Treatment System Rental 1 LS 8,000$ 8,000$ Field Testing 1 LS 10,000$ 10,000$ Pre-SVE Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 10 prior to

implementation of SVE to determine impacts

Air Sampling (equipment and labor) 1 LS 5,000$ 5,000$ Data Reduction/Evaluation and Reporting 1 LS 7,500$ 7,500$

8.3 Remedial Action Work Plan/Permitting 1 LS 10,000$ 10,000$ 8.4 Contractor Mobilization/Demobilization 1 LS 15,000$ 15,000$ 8.5 System Construction

Well design 1 LS 6,600$ $ 6,600 160 FT 121$ $ 19,360 Assuming each well is max 80 feet long

Well development 2 EA 1,650$ $ 3,300 IDW (Soil Non-hazardous) 1 LS 5,000$ 5,000$ From SVE well installationTransmission piping and trenching 200 LF 40$ 8,000$ Treatment Building/Shed 1 LS 15,000$ 15,000$ Condensate Knockout Tank 1 LS 3,000$ 3,000$ Condensate Pump 1 LS 1,500$ 1,500$ Vapor Phase GAC Vessels 2 EA 10,000$ 20,000$ Two 2,000 lb GAC vesselsPiping, instrumentation and valves 1 LS 10,000$ 10,000$ HVAC Systems 1 LS 3,000$ 3,000$ Electrical Control Panel and Wiring 1 LS 3,500$ 3,500$ Electrical Service Drop 1 LS 3,000$ 3,000$ System Assembly 1 LS 10,000$ 10,000$ Auto Dialer 1 LS 5,000$ 5,000$

8.6 System Startup 1 LS 5,000$ 5,000$ 8.7 Air permitting 1 LS 5,000$ 5,000$

Sub-Total 210,100$

9 Site Restoration9.1 Imported Backfill to grade 500 CY 30$ $ 15,000 inc. utility areas, non utility areas,

placement and compaction9.2 Backfill Source Sampling 1 EA 750$ $ 750 PCBs/Pesticides, VOCs, SVOCs, metals

analysis, every 1,000 cy9.3 3 inches of Asphalt 40 TON 68$ $ 2,720 Assumes 1 ton of asphalt covers 18 SY, 1

inch thick layerSub-Total 18,470$

Installation of one horizontal well via directional drilling

Installation of remaining horizontal wells via directional drill

Feasibility Study025-RICO-0219

R2-0000491

Table 29Cost Estimate for Alternative CTFA-5

AOC5 - Central Tank Farm Area

Page 3 of 3

AOC5 - Central Tank Farm AreaIn Situ Soil Vapor Extraction/Excavation

Site: Maywood Chemical Company Site Description: Location: Maywood, New JerseyPhase: Feasibility Study (-30% - +50%)Base Year: 2013Date: April 17, 2013

Item No.

Description Quantity Unit Unit Cost Total Notes

COST ESTIMATE SUMMARY

Alternative 5 consists of SVE, and excavation and off site disposal

10 Reporting and Institutional Controls10.1 Remedial Action Report 1 LS 50,000$ 50,000$ 10.2 O&M/Site Management Plan 1 LS 25,000$ 25,000$

Sub-Total 75,000$

Sub-Total Capital costs 668,355$

Contingency 25% 167,000$ 10% scope + 15% bidSub-Total 835,355$

Project Management 5% 41,768$ Remedial Design 8% 66,828$ Construction Management 6% 50,121$

TOTAL CAPITAL COST 994,000$

PERIODIC COSTS:Item No.

Description Year Quantity Unit Unit Cost Total Notes

1 Operations Costs 1 Every year through year 5.1.1 Annual Sub Slab Sampling Event 4 EA 300$ 1,200$ Assumes 4 samples in Building 10

annually1.2 Performance monitoring sampling (labor and equipment) 2 EA 1,000$ 2,000$ Assumes twice a year1.3 Monthly Vapor Effluent Sample 12 EA 300$ 3,600$ 1.4 Air sample collection (labor and equipment) 1 LS 2,500$ 2,500$ 1.5 Maintenance of Asphalt Seal 1 LS 1,000$ 1,000$ 1.6 Yearly Report 1 LS 10,000$ 10,000$ 1.7 Electrical Usage 60,000 Kw 0.15$ 9,000$ 1.8 Vapor Carbon Change out 2,000 LB 3.30$ 6,600$ change out lead vessels 1x per year1.9 Maintenance of SVE system 1 LS 2,000$ 2,000$

1.10 Project Management 1 LS 5,000$ 5,000$ 1.11 Technical Support 1 LS 5,000$ 5,000$

Sub-Total 47,900$

2 Five Year Review 3.1 Five Year Review 5 1 LS 15,000$ 15,000$ End of 5 years

Sub-Total 15,000$

PRESENT VALUE ANALYSIS: Rate of Return: 7% Inflation Rate: 3%Item No.

Cost Type Year Total Cost Present Value Notes

1 Capital Cost 0 994,000$ 2 Annual O&M Cost $0.003 Periodic Costs

3.1 Year 1 1 47,900 46,109$ 3.1 Year 2 2 47,900 44,386$ 3.1 Year 3 3 47,900 42,726$ 3.2 Year 4 4 47,900 41,129$ 3.3 Year 5 5 62,900 51,990$

Sub-Total 226,000$

TOTAL PRESENT VALUE OF ALTERNATIVE 1,220,000$

Feasibility Study025-RICO-0219

R2-0000492

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

DocID: Doc Date: Title:Image Count: Doc Type: Beginning Bates: Ending Bates: Addressee Name: Addressee Organization: Author Name: Author Organization:

684535 08/22/2013 COMPREHENSIVE ADMINISTRATIVE RECORD INDEX FOR OU1 FOR THE MAYWOOD CHEMICAL COMPANY SITE

12 [INDEX] [] [] [, ] [US ENVIRONMENTAL PROTECTION AGENCY]

101286 01/01/1111 MAYWOOD CHEMICAL SITE, ADMINISTRATIVE RECORD FILE, INDEX OF DOCUMENTS.

12 [INDEX] [] [] [NOT AVAILABLE, NOT AVAILABLE ]

[EPA, REGION 2]

101287 01/01/1111 MAYWOOD CHEMICAL SITE, ADMINISTRATIVE RECORD FILE UPDATE, INDEX OF DOCUMENTS.

1 [INDEX] [] [] [NOT AVAILABLE, NOT AVAILABLE ]

[EPA, REGION 2]

101288 01/01/1111 MAYWOOD CHEMICAL SITE, ADMINISTRATIVE RECORD FILE UPDATE #2, INDEX OF DOCUMENTS.

2 [INDEX] [] [] [NOT AVAILABLE, NOT AVAILABLE ]

[EPA, REGION 2]

49388 10/07/1980 Report: Site Inspection Report, prepared by Mr. Thomas Brady, Principal Environmental Technician, New Jersey Department of Environmental Protection, October 7, 1980.

10 [REPORT] 100001 100010 [] [] [BRADY, THOMAS ] [NJ DEPT OF ENVIRONMENTAL PROTECTION]

49389 05/01/1984 Report: Site Analysis, Maywood Chemical Sites, Maywood and Rochelle Park, New Jersey, prepared for United States Environmental Protection Agency, prepared by Mr. Larry Mata, Imagery Analyst, The Bionetics Corporation, May, 1984.

31 [REPORT] 100011 100041 [, ] [EPA, REGION 2] [MATA, LARRY ] [BIONETICS CORP]

49391 07/22/1981 Letter to Ms. Myu Campbell, United States Nuclear Regulatory Commission, from Mr. Francis T. Brezenski, Laboratory Director, United States Environmental Protection Agency, Region II, re: Reviewed Analytical Results from Various Sediment Samples, ...

3 [LETTER] 100042 100044 [CAMPBELL, MYU ] [US NUCLEAR REGULATORY COMMISSION]

[BREZENSKI, FRANCIS T] [EPA]

49398 08/01/1986 Plan: Field Sampling and Analysis Plan and Health and Safety Plan for the Maywood Vicinity Sites, Maywood, New Jersey, prepared for United States Environmental Protection Agency, prepared by Ebasco Services, August, 1986.

31 [LETTER, REPORT] 300001 300031 [ALVI, M SHAHEER , FELDMAN, JOYCE ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

COMPREHENSIVE ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

FINAL08/22/2013

Page 1 of 12

R2-0000493

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

DocID: Doc Date: Title:Image Count: Doc Type: Beginning Bates: Ending Bates: Addressee Name: Addressee Organization: Author Name: Author Organization:

COMPREHENSIVE ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

FINAL08/22/2013

49406 07/01/1993 Plan: Revised Remedial Investigation Workplan Amendment, Stepan Company Property, Administrative Order (Index No. II - CERCLA - 10105), Sears and Adjacent Properties, Administrative Order on Consent (Index No. II - CERCLA - 70104), prepared for ...

50 [LETTER, REPORT] 300032 300081 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49407 06/14/1991 Plan: Stepan Company Property, Remedial Investigation and Feasibility Study, Site Health and Safety Plan, Quality Assurance Project Plan, and Remedial Investigation Project Schedule, prepared for Stepan Company under Unilateral Administrative Order by ...

91 [LETTER, REPORT] 300082 300172 [, ] [EPA, STEPAN CHEMICAL CO]

[MANTO, MARY S] [CH2M HILL]

49408 10/21/1986 Plan: Final Work Plan for the Maywood Vicinity Sites, prepared for United States Environmental Protection Agency, prepared by Ebasco Services, Inc., October 21, 1986. (Note: Pages 300180 and 300192 of this document are CONFIDENTIAL. They are located ...

22 [LETTER, REPORT] 300173 300194 [ALVI, M SHAHEER , FELDMAN, JOYCE ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

49409 01/01/1111 Plan: RI/FS Work Plan and RI Operations Plan for the Stepan Co. Property, Appendix 1.

101 [REPORT] 300195 300295 [] [] [] []

49410 01/01/1111 Plan: RI/FS Work Plan and RI Operations Plan for the Sears and Adjacent Properties, Attachment A.

208 [REPORT] 300296 300503 [] [] [] []

49411 01/01/1111 Plan: RI/FS Work Plan and RI Operations Plan for the Sears and Adjacent Properties, Attachment B.

84 [REPORT] 300504 300587 [] [] [] []

49412 12/03/1992 Report: Wetlands Delineation Technical Memorandum, prepared for Stepan Company, Maywood, New Jersey, prepared by CH2M Hill, Parsippany, New Jersey, December, 1992.

34 [MAP, MEMORANDUM,

REPORT]

300588 300621 [, ] [STEPAN CHEMICAL CO] [ILIFF, KERRY , LONGO, JOHN ]

[CH2M HILL]

Page 2 of 12

R2-0000494

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

DocID: Doc Date: Title:Image Count: Doc Type: Beginning Bates: Ending Bates: Addressee Name: Addressee Organization: Author Name: Author Organization:

COMPREHENSIVE ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

FINAL08/22/2013

49413 02/01/1987 Report: Final Report for the Maywood Chemical Company Site, Sears and Vicinity Properties, Maywood, New Jersey, prepared for United States Environmental Protection Agency, prepared by Mr. Joseph Porrovecchio, Site Manager, Ebasco ...

111 [REPORT] 300622 300732 [, ] [EPA] [PORROVECCHIO, J , SACHDEV, DEV R]

[EBASCO SERVICES INC]

49414 11/01/1983 Report: Radiological Study of Maywood Chemical, Maywood, New Jersey, prepared for Surveillance and Analysis Division, United States Environmental Protection Agency, submitted by Mr. Jerry Cirilli, Project Manager, NUS Corporation, ...

164 [CHART / TABLE, MAP, REPORT]

300733 300896 [, ] [EPA] [CIRILLI, JERRY , FRANCONERI, PETER ]

[N U S CORP]

49415 07/13/1992 Memo to Mr. Jeff Gratz, United States Environmental Protection Agency, Mr. Tom Bryan, Alliance, and Messrs. Jeff Bartlett and Rodger Julin, Stepan Co., from Mr. John Longo, CH2M Hill, re: Approximate Extent and Thickness of Blue Material ...

31 [CHART / TABLE, MEMORANDUM]

300897 300927 [BARTLETT, JEFF , BRYAN, TIMOTHY M, GRATZ, JEFFREY , JULIN, RODGER , MANTO, MARY S, VOZZA, SCOTT ]

[ALLIANCE TECHNOLOGIES CORP, CH2M HILL, EPA, STEPAN CHEMICAL CO]

[LONGO, JOHN ] [CH2M HILL]

49416 07/07/1992 Memo to Mr. Jeff Gratz, Environmental Protection Agency, from Ms. Laura Gavin, CH2M Hill, re: Lithium Analysis of Samples from the Stepan Co. and Sears and Adjacent Properties Remedial Investigation, July 7, 1992.

1 [CHART / TABLE, MAP,

MEMORANDUM]

300928 300928 [GRATZ, JEFFREY ] [EPA] [GAVIN, LAURA ] [CH2M HILL]

49417 07/01/1992 Letter to Mr. Jeffrey Gratz, United States Environmental Protection Agency, from Ms. Mary K. Dwyer, Geophysics Task Manager, CH2M Hill re: Maywood Chemical Company Site, Maywood, Bergen County, New Jersey, Administrative Order on Consent ...

7 [CHART / TABLE, LETTER]

300929 300935 [GRATZ, JEFFREY ] [EPA] [DWYER, MARY K] [CH2M HILL]

Page 3 of 12

R2-0000495

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49418 04/27/1992 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager, CH2M Hill, re: Maywood Chemical Site, Maywood, Bergen County, New Jersey, Administrative Order on Consent ...

110 [CHART / TABLE, LETTER, MAP,

MEMORANDUM, REPORT]

300936 301045 [BARTLETT, JEFF , GRATZ, JEFFREY , JULIN, RODGER , RAMUGLIA, RICK ]

[ALLIANCE TECHNOLOGIES CORP, EPA, STEPAN CHEMICAL CO]

[JOHNSON, DON , MANTO, MARY S]

[CH2M HILL]

49438 04/21/1992 Letter to Ms. Mary S. Manto, Project Manager, CH2M Hill, from Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, Federal Facilities Section, re: Modifications to Test Pitting Program (Test Pit Deletion Rationale) ...

2 [LETTER] 301046 301047 [MANTO, MARY S] [CH2M HILL] [GRATZ, JEFFREY ] [EPA]

49439 03/31/1992 Letter to Ms. Mary S. Manto, Project Manager, CH2M Hill, from Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, Federal Facilities Section, re: 1. Surface Geophysics Reports for the Amended Stepan Property ...

2 [LETTER] 301048 301049 [MANTO, MARY S] [CH2M HILL] [GRATZ, JEFFREY ] [EPA]

49440 03/04/1992 Technical Memorandum prepared for Mr. Jeffrey Gratz, United States Environmental Protection Agency, prepared by Ms. Mary Kate Dwyer, CH2M Hill, re: Surface Geophysics Investigation - Amended Stepan Property, March 4, 1992.

60 [CHART / TABLE, MAP,

MEMORANDUM, REPORT]

301050 301109 [BARTLETT, JEFF , GRATZ, JEFFREY , JULIN, RODGER , KIELBASA, TED , RAMUGLIA, RICK ]

[ALLIANCE TECHNOLOGIES CORP, EPA, STEPAN CHEMICAL CO]

[DWYER, MARY K] [CH2M HILL]

49441 02/24/1992 Letter to Mr. George Nieves, Chief, Western Permits Section, United States Army Corps of Engineers, from Mr. Tom Norris, Environmental Scientist, CH2M Hill, re: CERCLA 121(e) Notification, February 24, 1992. (Attachments: Duplicate Memos to ...

19 [LETTER, MAP, REPORT]

301110 301128 [BLAKE, LYNN , CLERK, BOROUGH , NIEVES, GEORGE ]

[MAYWOOD BOROUGH OF, NJ DEPT OF ENVIRONMENTAL PROTECTION AND ENERGY, US ARMY CORPS OF ENGINEERS]

[NORRIS, TOM ] [CH2M HILL]

Page 4 of 12

R2-0000496

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49442 02/11/1992 Letter to Ms. Mary Manto, Project Manager, CH2M Hill, from Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, Federal Facilities Section, re: 1. Surface Geophysics Report for Adjacent Properties, 2. Well Rehabilitation ...

1 [LETTER] 301129 301129 [MANTO, MARY S] [CH2M HILL] [GRATZ, JEFFREY ] [EPA]

49443 01/17/1992 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Maywood Chemical Company Site, Administrative Order Index No. II - CERCLA - 10105; Sears and ...

4 [CHART / TABLE, LETTER]

301130 301133 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49444 01/07/1992 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Maywood Chemical Company Site, Administrative Order Index No. II - CERCLA - 10105; Sears and Adjacent ...

10 [LETTER, MAP, REPORT]

301134 301143 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49445 12/10/1991 Technical Memorandum prepared for Mr. Jeffrey Gratz, United States Environmental Protection Agency, prepared by Ms. Mary Kate Dwyer, CH2M Hill, re: Surface Geophysics Investigation - Vicinity Properties, December 10, 1991.

183 [CHART / TABLE, MAP,

MEMORANDUM, REPORT]

301144 301326 [BARTLETT, JEFF , GRATZ, JEFFREY , RAMUGLIA, RICK ]

[ALLIANCE TECHNOLOGIES CORP, EPA, STEPAN CHEMICAL CO]

[DWYER, MARY K] [CH2M HILL]

49446 11/08/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Items Requested by United States Environmental Protection Agency - November 1, 1991 Meeting, ...

35 [CHART / TABLE, LETTER, MAP,

REPORT]

301327 301361 [GRATZ, JEFFREY ] [EPA] [DWYER, MARY K, MANTO, MARY S]

[CH2M HILL]

Page 5 of 12

R2-0000497

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49447 10/28/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Technical Memorandum, Surface Geophysical Survey, Stepan Company Property, Maywood Chemical Company ...

183 [CHART / TABLE, LETTER, MAP,

REPORT]

301362 301544 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49448 10/25/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Maywood Chemical Company Site, Administrative Order Index No. II - CERCLA - 10105; Sears and Adjacent ...

4 [CHART / TABLE, LETTER]

301545 301548 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49449 07/19/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Maywood Chemical Company Site, Maywood, Bergen County, New Jersey, Administrative Order Index ...

2 [CHART / TABLE, LETTER]

301549 301550 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49450 07/16/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Sears and Adjacent Properties, Maywood, Bergen County, New Jersey, Revised Schedule, July ...

2 [CHART / TABLE, LETTER]

301551 301552 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

49451 08/15/1991 Letter to Mr. Jeffrey Gratz, Project Manager, United States Environmental Protection Agency, from Ms. Mary Manto, Project Manager CH2M Hill, re: Maywood Chemical Company Site, Maywood, Bergen County, New Jersey, Administrative Order ...

2 [LETTER] 301553 301554 [GRATZ, JEFFREY ] [EPA] [MANTO, MARY S] [CH2M HILL]

Page 6 of 12

R2-0000498

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49452 11/26/1990 Letter to Mr. Don Downing, Bechtel National, Inc., from Messrs. Daniel J. Delea and Mark Blackey, Weston Geophysical Corporation, re: Results from Ground Penetrating Radar Survey, Stepan Chemical Company and Muscurelle Sites, Maywood, New Jersey ...

18 [LETTER, REPORT] 301555 301572 [DOWNING, DON ] [BECHTEL NATIONAL INC] [BLACKEY, MARK , DELEA, DANIEL J]

[WESTON GEOPHYSICAL CORP]

49453 06/02/1989 Letter to Mr. Pat Evangelista, United States Environmental Protection Agency, from Mr. Bruce W. Clemens, Project Manager - FUSRAP, re: Monitoring Well Construction Logs and the Geologic Drill Logs for the Maywood Interim Storage Site, Stepan ...

94 [LETTER, REPORT] 301573 301666 [EVANGELISTA, PAT ] [EPA] [CLEMENS, BRUCE W] [BECHTEL NATIONAL INC]

49454 10/21/1988 Letter to Mr. Pat Evangelista, Remedial Project Manager, United States Environmental Protection Agency, from Les Skoski, Ph.D., Site Manager, re: Draft Report on the Investigation of Soils and Water at the Maywood Chemical Company Site ...

31 [LETTER, REPORT] 301667 301697 [EVANGELISTA, PAT ] [EPA] [SKOSKI, LES ] [EBASCO SERVICES INC]

49455 03/17/1988 Letter to Mr. Pat Evangelista, Remedial Project Manager, United States Environmental Protection Agency, from Ms. Alison D. Krafft, re: Brossman Short Form, 3/31/88 - 4/1/88, Groundwater Sampling, Maywood Chemical Company Site, ...

9 [LETTER, REPORT] 301698 301706 [EVANGELISTA, PAT ] [EPA] [KRAFFT, ALISON D] [EBASCO SERVICES INC]

49456 03/04/1988 Letter to Mr. M. Shaheer Alvi, P.E., Regional Project Officer, United States Environmental Protection Agency, and Mr. P. Evangelista, Remedial Project Manager, United States Environmental Protection Agency, from Dev R. Sachdev, ...

27 [LETTER, REPORT] 301707 301733 [ALVI, M SHAHEER , EVANGELISTA, PAT ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

Page 7 of 12

R2-0000499

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49457 09/23/1987 Letter to Mr. M. Shaheer Alvix. P.E., Regional Project Officer, United States Environmental Protection Agency, and Mr. P. Evangelista, Remedial Project Manager, United States Environmental Protection Agency, from Dev R. Sachdev, ...

14 [LETTER, REPORT] 301734 301747 [ALVI, M SHAHEER , EVANGELISTA, PAT ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

49458 09/04/1987 Letter to Mr. M. Shaheer Alvi, P.E., Regional Project Officer, United States Environmental Protection Agency, and Mr. P. Evangelista, Remedial Project Manager, United States Environmental Protection Agency, from Dev R. Sachdev, ...

12 [LETTER, REPORT] 301748 301759 [ALVI, M SHAHEER , EVANGELISTA, PAT ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

49459 02/05/1987 Letter to Mr. M. Shaheer Alvi, P.E., Regional Project Officer, United States Environmental Protection Agency, and Ms. Joyce Feldman, Regional Site Project Officer, United States Environmental Protection Agency, from Dev R. Sachdev, ...

16 [LETTER, MAP, REPORT]

301760 301775 [ALVI, M SHAHEER , FELDMAN, JOYCE ]

[EPA] [SACHDEV, DEV R] [EBASCO SERVICES INC]

49460 08/05/1986 Letter to Mr. William J. Librizzi, United States Environmental Protection Agency, from S.W. Ahrends, Director, Technical Services Division, Department of Energy, re: Buried Container at the Maywood Project, Sears Property, ...

1 [LETTER] 301776 301776 [LIBRIZZI, WILLIAM ] [EPA] [AHRENDS, S W] [US DEPT OF ENERGY]

49461 07/31/1986 Letter to Mr. William J. Librizzi, Director, Emergency and Remedial Response Division, United States Environmental Protection Agency, from S.W. Ahrends, Director, Technical Services Division, Department of Energy, re: Buried Hazardous Waste ...

5 [LETTER] 301777 301781 [LIBRIZZI, WILLIAM ] [EPA] [AHRENDS, S W] [US DEPT OF ENERGY]

49463 10/07/1991 Letter to Mr. Edgar Kaup, Case Manager, Bureau of Federal Case Management, Division of Hazardous Waste Management, New Jersey Department of Environmental Protection and Energy, from Mr. Jeffrey Gratz, Project Manager, United States ...

1 [LETTER] 600001 600001 [KAUP, EDGAR G] [NJ DEPT OF ENVIRONMENTAL PROTECTION]

[GRATZ, JEFFREY ] [EPA]

Page 8 of 12

R2-0000500

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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COMPREHENSIVE ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

FINAL08/22/2013

49549 05/02/1991 Administrative Order: Administrative Order in the Matter of Stepan Company, Respondent, Index No. II - CERCLA - 10105, May 2, 1991.

23 [LEGAL DOCUMENT] 700001 700023 [, ] [STEPAN CHEMICAL CO] [SIDAMON-ERISTOFF, CONSTANTINE ]

[EPA]

49551 08/24/1987 Administrative Order: Administrative Order on Consent in the Matter of Stepan Company, Respondent, Index No. II - CERCLA - 70104, August 21, 1987. (Attachment: Plan: Statement of Work, Remedial Investigation/Feasibility Study, Maywood Chemical ...

27 [LEGAL DOCUMENT] 700024 700050 [, ] [STEPAN CHEMICAL CO] [DAGGETT, CHRISTOPHER J]

[EPA]

49553 07/30/1991 Letter to Jeffrey Bartlett, Esq., General Counsel, Stepan Company, from Mr. Vincent Pitruzzello, Chief., Program Support Branch, United States Environmental Protection Agency, re: Maywood Chemical Company Site, Maywood, Bergen County, New ...

4 [LETTER] 700051 700054 [BARTLETT, JEFF ] [STEPAN CHEMICAL CO] [PITRUZZELLO, VINCENT ] [EPA]

49554 07/30/1991 Letter to Jeffrey Bartlett, Esq., General Counsel, Stepan Company, from Mr. Vincent Pitruzzello, Chief, Program Support Branch, United States Environmental Protection Agency, re: Maywood Chemical Company Site, Maywood, Bergen County, ...

5 [LETTER] 700055 700059 [BARTLETT, JEFF ] [STEPAN CHEMICAL CO] [PITRUZZELLO, VINCENT ] [EPA]

49555 06/06/1991 Letter to Chief, Program Support Branch, Emergency and Remedial Response Division, United States Environmental Protection Agency, from Mr. Percy L. Angelo, Mayer, Brown & Platt, re: Maywood Chemical Company Site, Maywood, Bergen County, New ...

6 [LETTER] 700060 700060 [, ] [EPA] [ANGELO, PERCY L] [MAYER BROWN & PLATT]

Page 9 of 12

R2-0000501

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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FINAL08/22/2013

49556 06/18/1992 Letter to Ms. Mary Manto, Project Manager, CH2M Hill, from Mr. Jeffrey Gratz, Project Manager, Federal Facilities Section, United States Environmental Protection Agency, re: Additional Work - Maywood Chemical Company Site, ...

2 [LETTER] 700066 700067 [MANTO, MARY S] [CH2M HILL] [GRATZ, JEFFREY ] [EPA]

49557 05/03/1991 Letter to Jeffrey Bartlett, Esq., General Counsel, Stepan Company, from Ms. Kathleen Callahan, Director, Emergency and Remedial Response Division, United States Environmental Protection Agency, re: Maywood Chemical Company Site, ...

3 [LETTER] 700068 700070 [BARTLETT, JEFF ] [STEPAN CHEMICAL CO] [CALLAHAN, KATHLEEN ] [EPA, REGION 2]

49558 05/26/1993 Risk Assessment: Final Risk Assessment, Stepan Company and Adjacent Properties Site (Part of the Maywood Chemical Company Site), Maywood, New Jersey, prepared for United States Environmental Protection Agency, prepared by ...

486 [REPORT] 800001 800486 [, ] [EPA, REGION 2] [, ] [TRC ENVIRONMENTAL CORP]

49566 06/27/1993 Letter to William J. Muszynski, P.E., Acting Regional Administrator, United States Environmental Protection Agency, Region II, from Mr. Michael J. Nolan, Concerned Citizens of Maywood, re: Reminder of the Modifying Criteria in the EPA Quick Reference ...

45 [ARTICLE, LETTER, REPORT]

1000001 1000045 [MUSZYNSKI, WILLIAM J] [EPA] [NOLAN, MICHAEL J] [CONCERNED CITIZENS OF MAYWOOD]

49568 11/01/1989 Plan: Community Relations Plan for the Maywood Chemical Company and Vicinity Properties Site, Maywood, Bergen County, New Jersey, prepared for United States Environmental Protection Agency, prepared by EBASCO Services Incorporated, ...

31 [REPORT] 1000046 1000076 [, ] [EPA, REGION 2] [, ] [EBASCO SERVICES INC]

Page 10 of 12

R2-0000502

REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

OUID: 01SSID: 0219

Action:

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COMPREHENSIVE ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

FINAL08/22/2013

49570 10/28/1991 Notice: Representatives from the United States Environmental Protection Agency Invite You to Attend a Public Availability Session on the Maywood Chemical Company Site, Monday, October 28, 1991 and Tuesday, October 29, 1991, by Pat Seppi, ...

1 [OTHER] 1000077 1000077 [] [] [SEPPI, P ] [EPA]

49571 10/28/1991 Attendance List: Sign in Sheet for the Maywood Chemical Company Site Public Availability Session, October 28, 1991, and October 29, 1991.

3 [OTHER] 1000078 1000080 [] [] [] []

49574 06/03/1983 Statement: Statement of F. Quinn Stepan, President, Stepan Chemical Company, Before the Subcommittee on Natural Resources, Agricultural Research and the Environment of the House Committee on Science and Technology, June 3, 1983.

5 [REPORT] 1000081 1000085 [, ] [HOUSE COMMITTEE ON SCIENCE AND TECHNOLOGY]

[STEPAN, F QUINN ] [STEPAN CHEMICAL CO]

49575 10/01/1991 Superfund Update: EPA to Oversee Investigation at the Maywood Chemical Company Site, Maywood, New Jersey, October, 1991.

3 [ARTICLE] 1000086 1000088 [] [] [, ] [EPA]

49583 11/01/1994 Report: Final Remedial Investigation Report, Stepan Company Property, Administrative Order (Index No. II - CERCLA - 10105), Sears and Adjacent Properties, Administrative Order On Consent (Index No. II - CERCLA -70104) , prepared for U.S. EPA, ...

492 [CHART / TABLE, MAP, REPORT]

301782 302273 [, ] [EPA, REGION 2] [, ] [CH2M HILL]

49584 11/01/1994 Report: Final Remedial Investigation Report, Appendices - Stepan Company Property, Administrative Order (Index No. II - CERCLA -10105), Volume I, Sears and Adjacent Properties, Administrative Order On Consent (Index No. II - CERCLA -70104), prepared ...

777 [CHART / TABLE, MAP, REPORT]

302274 303045 [, ] [EPA] [, ] [CH2M HILL]

Page 11 of 12

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REGION ID: 02Site Name: MAYWOOD CHEMICAL CO.CERCLIS ID: NJD980529762

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Action:

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FINAL08/22/2013

49585 11/01/1994 Report: Final Remedial Investigation Report, Appendices - Stepan Company Property, Administrative Order (Index No. II - CERCLA -10105), Volume II, Sears and Adjacent Properties, Administrative Order On Consent (Index No. II - CERCLA -70104), prepared ...

1033 [CHART / TABLE, MAP, REPORT]

303046 304077 [, ] [EPA] [, ] [CH2M HILL]

49586 07/20/1994 Memorandum to Site Remediation Program Staff, from Mr. Richard Gimello, Assistant Commissioner, Site Remediation Program, State of New Jersey, Department of Environmental Protection and Energy, re: New Soil Cleanup Criterion for Lead - ...

2 [MEMORANDUM] 304078 304079 [] [] [GIMELLO, RICHARD ] [NJ DEPT OF ENVIRONMENTAL PROTECTION AND ENERGY]

49587 11/08/1994 Letter to Ms. Angela Carpenter, Project Manager, U.S. EPA, Region II, Federal Facilities Section, from Ms. Mary S. Manto, Project Manager, CH2M Hill, re: Maywood Chemical Company Site, Maywood, Bergen County, New Jersey: Administrative Order ...

4 [LETTER, MEMORANDUM]

700071 700074 [CARPENTER, ANGELA ] [EPA] [MANTO, MARY S] [CH2M HILL]

49588 10/17/1994 Letter to Ms. Angela Carpenter-, Project Manager, U.S. EPA, Region II, Federal Facilities Section, from Ms. Mary S. Manto, Project Manager, CH2M Hill, re: Maywood Chemical Company site, Maywood, Bergen County, New Jersey. Administrative Order ...

16 [LETTER, MEMORANDUM]

700075 700090 [CARPENTER, ANGELA ] [EPA] [MANTO, MARY S] [CH2M HILL]

215314 08/01/2013 FEASIBILITY STUDY REPORT FOR OU1 FOR THE MAYWOOD CHEMICAL COMPANY SITE

307 [REPORT] R2-0000001 R2-0000307 [, ] [US ENVIRONMENTAL PROTECTION AGENCY]

[MC COLLUM , RICHARD , MUSSO, MICHAEL , WILLIAMS , BRADLEY ]

[HDR]

689188 08/21/2013 PROPOSED PLAN FOR THE MAYWOOD CHEMICAL COMPANY SITE

21 [PLAN] R2-0000308 R2-0000328 [] [] [, ] [US ENVIRONMENTAL PROTECTION AGENCY]

Page 12 of 12

R2-0000504

CHRIS C HRISTI E Governor

KIM GUADAGNO Lt. Governor

~tate of ~ .efu W.ers.e14 DEPARTMENT OF ENVIRONMENTAL PROTECTION

Site Remediation Program Mai l Code 40 l -406

P.O. Box 420 Trenton, New Jersey 08625-0420

Telephone: 609-292-1250

BOB MARTIJ'\ Commissioner

Walter Mug dan, Director SEP - 3 2014 Emergency and Remedial Response Division U.S. Environmental Protection Agency Region II 290 Broadway New York, NY 10007-1 866

RE: Maywood Chemical Company Superfund Site 100 W Hunter A venue Boroughs of Maywood and Lodi and Township of Rochelle Park, Bergen County

·PI #011050 Activity Number RPC000001

Dear Mr. Mugdan:

The New Jersey Department of Environmental Protection (Department) has completed its review ofthe Record ofDecision (ROD) for Operable Unit 1 (OUl ), which addresses chemically­contaminated, non-radiological soil and source areas, prepared by the U.S. Enviromnental Protection Agency (EPA) Region II. The Department concurs with the selected remedy, namely excavation of chemically-contaminated, non-radiological soil and source areas plus soil vapor extraction in the one area of concern, with the following clarifications.

The Department recognizes that EPA's impact to ground water remediation goal for lithium of 194 mg/kg is slight! y higher than the impact to ground water soil remediation standard of 13 8 mg/kg that the Department developed. Per discussions with EPA, the Department understands that implementation of the remedy, which involves excavation of soils and wastes comingled with several other contaminants of concern, will also address soils above the Department's cleanup goal of 138 mglkg, and that this will be verified by post-excavation sampling and compliance averaging in accordance with Department guidance.

The Department also notes that EPA will require hexavalent chromium sampling during the pre­design investigation, and that any hexavalent chromium soil contamination identified above 20 parts per million will be evaluated in accordance with EPA and Department standards and guidance and, if necessary, addressed in the future OU4 ROD or as an amendment to this OU! remedy.

The selected remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, and, to the extent practicable, the

New Jersey is an Equal Opportunity Employer Recycled Paper

R2-0000505

National Oil and Hazardous Substances Pollution Contingency Plan. This decision is based on the Administrative Record file for this site. The response action selected in this Record of Decision (ROD) is necessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances into the enviromnent.

The selected remedy with clarifications is protective of human health and the environment, complies with Federal and State requirements that are applicable or relevant and appropriate to the remedial action, is cost effective, and uses permanent solutions and treatment technologies to the maximum extent practicable.

DEP appreciates the opportunity to participate in the decision making process to select an appropriate remedy. If you have any questions, please call me at 609-292-1250.

sswner S · e Remediati n Program

c:

Donna Gafftgan Case Manager, BCM

New Jersey is an Equal Opportunity Employer Recycled Paper

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1  

Maywood Chemical Company Superfund Site Operable Unit 1 - Non-FUSRAP Soil and Source Areas

Record of Decision

APPENDIX V

RESPONSIVENESS SUMMARY

R2-0000507

2  

I. INTRODUCTION This Responsiveness Summary is Appendix V of the Record of Decision (ROD) for Maywood Chemical Company Superfund Site Operable Unit 1 (OU1): Non-Formerly Utilized Site Remedial Action Program (FUSRAP) Soil and Source Areas, located in the Boroughs of Maywood & Lodi and Township of Rochelle Park, Bergen County, New Jersey. It provides a summary of community relations activities related to the Site and a summary of all public comments received during the public comment period related to the Proposed Plan for OU1: Non-FUSRAP Soil and Source Areas as well as the U.S. Environmental Protection Agency’s (EPA’s) responses to those comments. The Responsiveness Summary includes four attachments that document public participation, as follows:

Attachment A – August 2013 Proposed Plan; Attachment B – Public Notice published in The Record; Attachment C – Transcript of the September 9, 2013, Public Meeting; and Attachment D – Copies of written public comments received.

All comments summarized in this document have been considered in EPA’s final decision in the selection of a remedy to address the contamination associated with OU1 Non-FUSRAP Soil and Source Areas. II. COMMUNITY RELATIONS ACTIVITIES EPA’s Proposed Plan for OU1: Non-FUSRAP Soil and Source Areas was released to the public for comment on August 23, 2013. A copy of the Proposed Plan, risk assessment, remedial investigation (RI) sampling reports, feasibility study (FS) with remedial alternatives and other supporting documents that comprise the Administrative Record (AR) file were made available to the public in the Site AR repositories maintained at the Maywood Public Library located at 459 Maywood Avenue, Maywood, New Jersey and at EPA Region 2 Record Center located at 290 Broadway, New York, New York. A copy of the Proposed Plan can be found in Attachment A. A public notice was published in The Record on August 23, 2013. The public notice advised the public of the availability of the Proposed Plan and invited interested parties to attend a public meeting to be held at the Maywood Public Library on September 9, 2013 at 7:00 pm. This public notice also announced the opening of the 30-day public comment period on August 23, 2013. A copy of the public notice can be found in Attachment B. The public meeting held on September 9, 2013 was recorded by a stenographer. Following a presentation by EPA, the public was invited to provide oral comments on the Proposed Plan and supporting documents. A copy of the meeting transcript can be found in Attachment C. EPA received three requests from the Stepan Company, a potentially responsible party, to extend the 30-day public comment period. EPA announced the first extension at the public meeting on

R2-0000508

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September 9 and announced the two subsequent extensions in press releases. EPA ultimately extended the 30-day public comment period for an additional 73 days, for a total of 103 days. During the public comment period from August 23 to December 5, 2013, EPA received comments in writing on the Proposed Plan and supporting documents. Copies of those written comments can be found in Attachment D. III. SUMMARY OF COMMENTS AND EPA RESPONSES

A. Public Meeting Comments This section summarizes public comments made following EPA’s presentation at the September 9, 2013 public meeting held at 7:00 pm in the Maywood Public Library. EPA presented the preferred remedial alternatives, received comments from meeting participants and responded to questions regarding the remedial alternatives under consideration. Attachment C is the transcript of the public meeting. Future Route 17 Expansion

A commenter noted that there is a state and county project to expand Route 17 to three lanes, which was not considered in the Proposed Plan and needs to be addressed. EPA Response: Two of the three properties subject to the OU1 remedy, the Stepan property and the Sears property, border on the existing Route 17. The Route 17 expansion project is in the planning stages and has not begun construction. EPA will coordinate with the appropriate county and state representatives on the expansion project.

Culverts

A commenter noted that the culverts surrounding the properties subject to the proposed cleanup are clogged up and should be cleaned out as part of the remedy to avoid secondary contamination. EPA Response: Sediments were sampled as part of the RI. The Selected Remedy includes measures to remediate sediments in existing and former drainage channels on the five areas of concern (AOCs) and thus contamination in these locations will be addressed by the remedy.

County Population and Land Use

A commenter noted the FS report erroneously states that the county population is decreasing and further noted that the vacancy rate on Route 17 is among the lowest in the United States. EPA Response: According to the U.S. Census for 2010-2012 (http://quickfacts.census.gov\qfd/states/34/33003.html), the population in Bergen County

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is increasing, and the reasonably anticipated future land use considered this information when concluding that commercial/industrial land use was the most likely future scenario. The FS statement was based on information available at the time it was prepared and future land use assumptions in this ROD reflect current land use trends.

Contamination at DeSaussure A commenter asked why the gypsum was not addressed originally, when the Army Corps

of Engineers was digging soils in this area. The commenter indicated that the gypsum material also should have been taken care of at this time.

EPA Response: The blue gypsum waste material was uncovered when the radiological

soil was excavated and removed from the property in 2006 by the U.S. Army Corps of Engineers (USACE) as part of the OU2 remedy that addresses FUSRAP radioactively-contaminated soils. The FS estimated that 6,250 cubic yards of gypsum waste material which is not commingled with radiological wastes remains in the Gypsum Area (GA). The OU1 remedy includes excavation and removal of gypsum materials that contain semi –volatile organic compounds (SVOCs) and/or metals above acceptable levels. The precise extent of gypsum materials to be excavated and removed from the GA will be delineated during remedial design. USACE was not responsible for removing this chemically-contaminated soil as part of the OU2 remedy.

B. Written Comments This section summarizes public comments submitted to EPA during the public comment period related to the Proposed Plan for OU1: Non-FUSRAP Soil and Source Areas as well as EPA’s responses to those comments. During this period, EPA received comments from the PRP, one elected official and four members of the community. Attachment D contains copies of written public comments received. Maywood Swim Club

A commenter asked whether the Maywood Swim Club was tested and if it is downgradient from the Superfund Site.

EPA Response: The Maywood pool property located on Brook Avenue is north of the former Maywood Chemical Works property and is considered upstream/upgradient of the site, because surface water and groundwater in the area typically flow to the south/ southwest. The Maywood Chemical Works did not operate on the pool property. The Maywood pool property was tested by U.S. Department of Energy (DOE) in 1987 and no evidence of radioactive contamination was found. Based on test results and the upstream/upgradient location of the property, no further investigation was warranted in relation to the Superfund Site.

Residential Property Investigations

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A commenter asked about the status of soil investigation work at nearby residential properties.

EPA Response: The site cleanup work is being done in phases and other cleanup plans for the site include additional properties, both residential and commercial, in Maywood, Rochelle Park and Lodi; the U.S. Army Corps of Engineers currently manages those plans. A number of residential properties have been investigated and some required cleanup work. More information on that work can be found at the USACE Maywood website http://fusrapmaywood.com/index.asp and there is an information center located in Maywood (details are also on the website).

A commenter contacted EPA about potential contamination on a residential property, because sometime in the 1960s a landscaping company stated that they delivered tea leaf mulch from the Maywood Chemical plant to the property.

EPA Response: EPA conducted a radiation survey at the property and collected two soil samples which were analyzed for potential site contamination. None of the investigation findings identified site related contamination.

Schedule and Cost of Cleanup

A commenter asked why it has taken 17 years for EPA to begin the cleanup at the former Maywood Chemical Site and if $17 million was a “fairly staggering” cost for the cleanup. Another commenter welcomed the EPA’s $17 million investment in cleaning the Site, stated appreciation for the work that already has taken place and asked when the project would be completed. EPA Response: The Maywood Chemical Company Site was listed on the National Priorities List in 1983. With respect to FUSRAP-funded remediation at the Site (OUs 2 and 3), cleanup work began by DOE in 1984 and has been managed since 1997 by USACE. FUSRAP soil remediation is ongoing and expected to continue for another ten years. To date, more than 400,000 cubic yards of radiologically-contaminated soil have been removed and disposed of in regulated landfills, at a cost of more than $500 million. Non-FUSRAP contamination is being addressed by EPA under OUs 1 and 4. EPA believes that the $17 million cost of the remedy is appropriate. Once constructed, the cleanup for the SVE system at the FAA is estimated to take five years to achieve the remedial action objectives for the site. Furthermore, as described in the 2003 ROD for FUSRAP soils (OU2), areas of the Sears and DeSaussure properties where occupied buildings are currently situated are known to contain radiologically-contaminated soils that will be addressed under the OU2 remedy, but these soils are currently inaccessible. As these soils become accessible in the future (e.g., due to renovation or demolition activities), this OU1 remedy will address chemically-contaminated soils if identified under the buildings after the OU2 ROD excavation remedy is completed for those inaccessible soils, in order to satisfy the remedial action objectives .

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Emergency Situations

A commenter inquired about how EPA would respond in possible emergency situations, such as a water main break or sewage line problem to ensure that contamination stays contained and possible problems are mitigated.

EPA Response: During the remedial design, EPA would be communicating and coordinating with local officials, including emergency responders so that all necessary personnel are aware of EPA’s activities. Additionally, EPA would be develop all appropriate documents, including a health and safety plan, to identify how to respond to any emergencies that may develop.

Waste Disposal

A commenter stated that the proposed plan fails to properly classify soil for disposal, based on the current license issued by the Nuclear Regulatory Commission (NRC) for the Stepan Company. This material is classified as 11e(2) byproduct material and should be disposed at a facility licensed to accept such material, which the proposed plan does not address. The commenter also suggests that by not considering the 11e(2) classification, and, therefore, the disposal requirements at an appropriate facility, EPA did not consider environmental impacts related to trucking waste to the facility. The same commenter stated that EPA failed to consider the volume of 11e(2) radioactive soil, which would more than triple the cost of removal and disposal.

EPA Response: For all areas except for AOC1-BCA (which to date, has been remediated to the unrestricted level for radioactivity under the implementation of the OU2 FUSRAP soils remedy), it was assumed that ten percent of excavated soil would be disposed of as low-level radioactive waste. The actual volume that would need to be addressed as an 11e(2) waste stream will be confirmed based on waste classification testing during remedy design and implementation. The disposal costs of $84.50 per cubic yard for radiologically-impacted soil presented in the FS were based on the current disposal cost from the ongoing FUSRAP soil remediation, and truck traffic to one type of facility or another would not affect the local community differently. Truck traffic was evaluated as a short-term impact for all alternatives. Transportation and disposal options will be identified in the remedial design. The FUSRAP soil remediation project transports its radioactive soil to disposal facilities by rail and this mode of transportation would be considered a viable waste transportation option with fewer environmental impacts than truck transportation. As part of the comparison of alternatives for the selection criteria, EPA did evaluate the potential environmental impacts of off-site disposal of this material at appropriate disposal facilities. After careful consideration of all alternatives to the selection criteria, EPA selected off-site disposal as the remedy for excavated soils.

Impact to Groundwater

A commenter stated that the proposed plan identifies soil remediation methods based on concerns about groundwater contamination without considering Site-specific

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groundwater criteria and data, as well as Site history. The commenter stated that factors such as groundwater data and historical contamination should also be considered in the decision to remediate soils based on potential impacts to groundwater,

EPA Response: When evaluating data generated during the remedial investigation, EPA identified results from groundwater samples collected at the Site with concentrations in excess of federal and state maximum contaminant levels (MCLs), which served as the basis for concluding that contaminants at the Site were causing groundwater contamination. As the FS was being developed and remediation goals were considered, EPA evaluated remediation goals based on protection of human health, ecological receptors and protection of groundwater. When developing remediation goals based on protection of groundwater, EPA considered, among other factors discussed in the FS, New Jersey Department of Environmental Protection (NJDEP) guidance for selection of the impact to groundwater values for soil (http://www.nj.gov/dep/srp/guidance/rs/igw_intro.htm). The default values listed in the NJDEP guidance document, “Development of Impact to Ground Water Soil Remediation Standards Using the Soil-Water Partition Equation” , were selected, since EPA determined that the default input values that were used in developing these criteria were representative of Site conditions. Site-specific criteria were developed for contaminants that had no criteria in the guidance (i.e., chromium and lithium). For these chemicals, the impact to groundwater remediation goals were selected for the Site. A commenter stated that the FS identifies remediation goals for several chemicals based on the impact to groundwater, but questions the basis for using this pathway to identify COCs and to develop remediation goals.

EPA Response: It is common for EPA to evaluate soils as a potential source of contamination for groundwater, and this approach was included in the OU2 FUSRAP soils ROD. As stated previously, data collected during the RI for OU1 identified contaminants in groundwater at concentrations in excess of federal and state MCLs. Upon further review of the soils data collected during the RI, it was concluded that contaminant concentrations in soils exceeded soil concentrations developed to be protective of impacts to groundwater. Therefore, as part of the action to address contamination in soils, EPA has included in the OU1 remedy actions to protect groundwater over the long term.

Historical Sampling

A commenter stated that the proposed plan includes pre-design investigations for each of the areas and does not consider the hundreds of samples collected and over one hundred test pits investigated as part of the EPA-approved RI report.

EPA Response: EPA utilized the sampling data collected during the remedial investigation to assist in the delineation of contamination. When evaluating alternatives and selecting a remedy, EPA is including additional sampling to supplement the existing data and further refine the areas requiring remedial action. Pre-design investigations are necessary to delineate the soil contamination for

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excavation, treatment and land use control purposes. Because the RI data were collected prior to 1994 and extensive FUSRAP excavation work has taken place at all AOCs since that time, the 2013 FS and proposed plan made conservative assumptions on the volumes of soil to be remediated in each of the source areas and recognized that these volumes would require refinement during the pre-design investigation work. Work plans will be prepared and reviewed by EPA prior to sampling. EPA is ready to consider a more streamlined, yet thorough approach during the remedial design planning stages. Pre-design investigation work could result in lower actual remedial costs at all AOCs and could be considered a cost savings.

Off-site Disposal vs. On-site Remedies

A commenter stated that the proposed plan improperly balanced the human health and environmental impacts of off-site versus on-site remedies for the Leather Materials Area (LMA) and the GA resulting in over-conservative remedy selection.

EPA Response: A detailed analysis was performed for each alternative for all AOCs, including the LMA and the GA. The detailed analysis consisted of an assessment of the individual alternative against each of nine evaluation criteria set forth in 40 C.F.R. Section 300.430(e)(9)(iii) and (f)(1)(i).A comparative analysis of all alternatives for each AOC, focusing upon the relative performance of each response measure against the criteria, including overall protection of human health and the environment was also performed. The comparative evaluation included an assessment of the potential human health and environmental impacts associated with off-site disposal compared with on-site remedies. Off-site disposal alternatives would permanently remove contamination and would result in lower exposure and impact-to-ground water risk when compared to on-site alternatives. EPA determined that, based on the outcome of these analyses, LMA-4 (Excavation, Off-Site Disposal and ICs) and GA-4 (Excavation, Off-Site Disposal and ICs) achieved the best balance for all criteria and the selected remedies for the Site.

Groundwater

A commenter stated that it is not technically defensible to address soil contamination separate from groundwater contamination in the CTFA and the FAA.

EPA Response: EPA often addresses soil and source areas prior to addressing groundwater in the Superfund program. The Agency has concluded that at this Site it is important to move forward with selecting and implementing a remedy for soils which addresses, in addition to reducing direct contact health risks, ongoing sources of contamination to groundwater. It is also agency policy to address sources of groundwater contamination earlier in the cleanup process, where practicable. Additionally, source areas must be addressed when

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considering certain groundwater remedies, such as monitored natural attenuation, so it is especially important to take action on soils early so that all potential groundwater remedies can be considered.

Administrative Record

A commenter stated that the administrative record, which forms the basis for the selection of a response action, does not contain the relevant information required to make a defensible remedy selection, specifically with regard to ongoing remedial work being performed on FUSRAP soils, which impacts the volumes of soils to be addressed under the remedy selected for OU1. The commenter objects that EPA has failed to follow principles of administrative law which require the agency to engage in “reasoned decision-making.” The commenter’s principal objection is that the Administrative Record does not contain relevant information, specifically contemporaneous data concerning the status of the ongoing Corps remediation of radioactive and certain mixed waste associated with the OU2 remedy for FUSRAP soils. Essentially, the commenter is making an argument that the Administrative Record should be supplemented with data obtained after the FS and PRAP were completed, that is, after EPA’s selection process is completed pending public notice and comment.

EPA Response: The Commenter’s complaint is that the administrative record is incomplete because it does not contain “up-to-date” data on the progress of the Corps’ ongoing soil removal efforts. However, in the CERCLA context the federal courts have consistently held that “as a general rule, information created or discovered after an agency has made a decision” will not be considered as part of the administrative record. U.S. v. Iron Mountain Mines, Inc.,987 F.Supp. 1250, 1260 (E.D. Cal. 1997). Under § 300.435(c) (“community relations”) of the NCP, EPA is only required to supplement the administrative record where “significant” information is presented or discovered which would “significantly” change “the basic features of the remedy…such that the remedy significantly differs from the original proposal.” § 300.435(c) provides that in such an instance EPA must issue an explanation of significant differences (“ESD”) or ROD amendment and include such additional information in the administrative record. This is the only instance where post-decision information is required to be included in the administrative record by the NCP.

The USACE work is ongoing; should EPA be required to supplement the record with incremental aggregations of data being obtained on a daily or weekly basis, as a practical matter EPA’s remedial decision concerning non-radiological waste at the Site would have to be indefinitely postponed until completion of all radiological work at this large and complex Site. EPA’s statutory obligation to protect human health and the environment precludes such a dilatory approach. However, EPA has acknowledged that additional data will be collected during the pre-design investigation, to further refine areas that require remediation, and that the on-going FUSRAP remedial work is one of the reasons for this additional delineation; therefore, although the volume of soils to be addressed under this action may change, the remedy will not change. That being the case, no new information is required to be included in the administrative record as being so “significant” that it would change the “basic features” of the selected remedy.

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Risk Assessment

A commenter stated that the 1993 risk assessment conducted for the Site addressed chemical contamination in groundwater, soils, sediments and surface water, and it considered both ecological and human health risk. The commenter indicated that the findings from the ecological risk assessment concluded that, due to the industrial setting, there are limited receptor species and very little risk and the human health risk assessment identified unacceptable risk under future residential condition, although, as noted in the FS, the AOCs and adjacent areas are currently zoned Industrial and Commercial and, more importantly, the FUSRAP ROD already requires deed notices restricting the Stepan and Sears properties to non-residential use. The commenter also stated that the human health risks identified were primarily related to groundwater use, even though there is no current or future groundwater use expected in the vicinity of the Site.

EPA Response: The human health and ecological risk assessment identified the need for remedial action, due to risks that are above acceptable levels, based on the reasonably anticipated future use of land and groundwater at the time. As part of the FS, an updated risk screening evaluation was performed, in order to ensure that updated toxicity information for Site-related chemicals would be considered in the identification of chemicals of potential concern (COPCs). Additionally, future land use was reevaluated. In keeping with the local land use trends and plans and to be consistent with the future land-use assumptions made in USACE 2003 OU2 FUSRAP Soils and Buildings ROD, a future commercial land-use scenario was assumed for all properties. The OU2 FUSRAP Soils and Buildings ROD requires deed notices to be placed on the Stepan and Sears properties restricting the properties to non-residential use. The assumption of continued non-residential use is also consistent with current surrounding property uses. The updated risk-screening evaluation compared the maximum concentrations of chemicals detected in each of the five areas to NJDEP non-residential direct contact soil remediation standards, EPA risk-based screening levels for commercial/industrial land use. In addition, this evaluation also included a comparison of the maximum detected concentrations in each area to NJDEP impact to groundwater soil screening levels, in order to identify in the soils any contamination with potential to migrate to groundwater. It should be noted that the groundwater at the Site is designated as a Class IIA aquifer by NJDEP; this designation is not dependent on current land use. See N.J.A.C. 7:9C-1.5 (“Ground water classification system and designated uses”) (“Classifications are regional in nature and do not reflect localized infringements on designated uses due to natural quality or pollution incidents.”) The conclusions of the risk-screening confirmed the conclusions of the human health risk assessment, and supported the need to take action at the Site.

 

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EPA ANNOUNCES PROPOSED PLAN This Proposed Plan identifies cleanup alternatives for addressing chemically-contaminated soil and buried waste at various locations at the Maywood Chemical Company Superfund Site (Site), selects a preferred remedy from those alternatives and provides the rationale for this preference. Soil at the Site is contaminated with a variety of chemicals and waste materials, including metals, volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs), from past chemical manufacturing and ore processing activities. The U.S. Environmental Protection Agency (EPA) is recommending a remedy that includes soil excavation with off-site disposal, soil vapor extraction, institutional controls and site restoration (see pages 17-20 below). This Proposed Plan is issued by EPA, the lead agency for Site activities. EPA, in consultation with the New Jersey Department of Environmental Protection (NJDEP), the support agency for Site activities, will select the final remedy for the Site after reviewing and considering all information regarding the Proposed Plan submitted during a 30-day public comment period. EPA, in consultation with NJDEP, may modify the preferred alternative or select another response action presented in this Proposed Plan based on new information or public comments. Therefore, the public is encouraged to review and comment on all the information presented in this Proposed Plan. EPA is issuing this Proposed Plan as part of its community relations program under Section 117(a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, or Superfund). This Proposed Plan summarizes information that can be found in greater detail in several reports included in the Administrative Record. SITE DESCRIPTION The properties addressed by this Proposed Plan include eight separate commercial parcels formerly owned by the Maywood Chemical Company. These properties are located in Maywood and Rochelle Park, Bergen County, New Jersey and cover a total area of approximately 63 acres.

Three of the eight properties will require cleanup. These

Superfund Program U.S. Environmental Protection Agency Proposed Plan Region 2

Maywood Chemical Company Superfund Site Borough of Maywood & Township of Rochelle Park, New Jersey August 2013

MARK YOUR CALENDAR PUBLIC COMMENT PERIOD: August 23, 2013 - September 23, 2013, U.S. EPA will accept written comments on the Proposed Plan during the public comment period.

PUBLIC MEETING: September 9, 2013, at 7:00 P.M. U.S. EPA will hold a public meeting to explain the Proposed Plan and the Feasibility Study. Oral and written comments will also be accepted at the meeting. The meeting will be held at the: Maywood Public Library Trinka Hall (Lower Level) 459 Maywood Avenue Maywood, NJ 07607 For more information, see the Administrative Record at the following locations: Maywood Public Library 459 Maywood Avenue Maywood, NJ 07607 U.S. EPA Records Center, Region 2 290 Broadway, 18th Floor New York, New York 10007-1866 (212) 637-4308 Hours: Monday-Friday, 9 AM to 5 PM U.S. EPA Website http://www.epa.gov/region2/superfund/npl/maywood/

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three properties are further divided into five distinct Areas of Concern (AOCs) which are described in more detail in the “Nature and Extent of Contamination” Section below. Also see Figure 1 - Site Map. Although this Proposed Plan addresses soil contamination, a future Proposed Plan will address groundwater contamination associated with these AOCs. The Site also includes 88 additional properties which are being cleaned up by the U.S. Army Corps of Engineers (USACE) with continuing Congressional appropriations under the Formerly Utilized Sites Remediation Program (FUSRAP). These properties are being addressed through remedies selected in two separate Records of Decision (RODs) for the Site: a 2003 FUSRAP Soils and Buildings ROD and a 2012 Groundwater ROD. The FUSRAP cleanup work primarily addresses radiological contamination on the 88 properties, but also addresses chemical contamination at the government-owned Maywood Interim Storage Site (MISS). More information about the USACE FUSRAP Project can be found at: FUSRAP Public Information Center 75A West Pleasant Avenue Maywood, NJ 07607 Telephone: (201) 843-7466 Hours: Monday and Wednesday 9:00 AM – 4:00 PM Friday 9:00 AM – 3:00 PM http://fusrapmaywood.com/index.asp

SITE HISTORY The original Maywood Chemical Works owned and operated by Maywood Chemical Company was founded in 1895 and manufactured a wide variety of chemical additives and products. Initial operations included processing of monazite sand to extract thorium and rare earth minerals for use in manufacturing industrial products such as mantles for gas lanterns. Monazite sand is a naturally-occurring ore that contains thorium, a radioactive material. It is found in many parts of the world, including some beaches. The origin of the monazite sand processed at the Maywood Site is not known. The manufacturing process resulted in tailings with residual radioactive thorium waste. Other processing operations generated various types of waste products such as lanthanum, lithium compounds, detergents, alkaloids, essential oils and products from tea and cocoa leaves. Waste from thorium processing operations was used as fill at the Maywood Chemical Company property and subsequently on adjacent properties in Rochelle Park, Maywood and Lodi during the construction of Route 17 in 1932.

Stepan Company purchased the Maywood Chemical Company property in 1959 and is currently the owner and operator of a 19-acre portion of the original Maywood Chemical Works. Many of Maywood Chemical Company’s operations were discontinued in the 1960s. Stepan currently produces specialty chemicals. In October 1980, the NJDEP investigated a citizen complaint about radioactive contamination at an area near Route 17 in Maywood and Rochelle Park, NJ. From 1980 through 1983, radiological surveys and sampling were performed in the area by NJDEP, EPA and the U.S, Department of Energy (DOE). These studies revealed extensive radionuclide contamination and were the basis for the Site being included on the National Priorities List (NPL) in 1983. From 1984 through 1986, DOE, acting under its FUSRAP authority through the 1984 Energy and Water Appropriations Act (PL 98-50) which specifically addressed the Maywood Site, investigated and removed over 35,000 cubic yards of radioactively-contaminated soil and debris from nearby residential properties. This material was stockpiled and secured at the MISS property, owned by the federal government and located on 11.7 acres of Site land acquired from Stepan Company. In 1986, in conjunction with DOE’s radiological characterization of the “Sears and adjacent” properties (portions of the Site not currently owned or operated by Stepan), EPA performed a preliminary study of chemical, non-radioactive pollutants. EPA’s study indicated the presence of elevated concentrations of volatile organics, base/neutral acid extractables, metals, pesticides, and other hazardous substances. In 1987 and 1988, in conjunction with DOE’s studies and investigation, EPA collected samples of soil on the Stepan property itself. The data from that sampling indicated the presence of both radiological and non-radiological contaminants in the soil. Therefore, the Site is contaminated with both radionuclides and non-radioactive chemicals. Chemical, non-radioactive contamination was found on the Stepan Company property, the Sears Logistics Center and the DeSaussure Equipment Corporation/Maywood Furniture Corporation property. Coordination with Radiological Investigations & Cleanup The Energy and Water Appropriations Act of 1998 (PL 105-62) provided appropriations for the USACE to take over FUSRAP, formerly administered by DOE. Responsibility for the cleanup of the Maywood Site was therefore effectively transferred from DOE to USACE by Congress in October 1997. The USACE is responsible for remediation of site-wide

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radiological contamination. Chemical, non-radioactive contamination is also USACE’s responsibility, but only if the contamination is on federally-owned property (i.e., the MISS) or is mixed or commingled with radiological contamination that exceeds the radiological cleanup levels established in the 2003 FUSRAP Soils and Buildings ROD. EPA is responsible for oversight of both the USACE’s and Stepan’s cleanup activities. This Proposed plan addresses all areas of chemical contamination associated with the former Maywood Chemical Company that are not part of the FUSRAP actions SITE CHARACTERISTICS Surface Features and Land Use Brief summaries of the surface features and current land use for each property with AOCs requiring cleanup are presented below. A more detailed discussion of the physical characteristics of the Site study area is provided in the remedial investigation (RI) report (CH2M HILL, 1994). Stepan The Stepan property has an active chemical manufacturing plant which produces specialty chemicals for various industries. Half of Stepan’s 19 acres are covered with structures, foundations of former structures, above-ground tank farms, asphalt and concrete. The remaining portions of the property are vegetated, covered in crushed stone or non-vegetated soil. The entire property is fenced except for the parking lot and lawn in front of the administration building. Three AOCs, the Leather Material Area (LMA), Former Aromatics Area (FAA) and Central Tank Farm Area (CTFA), are located on the Stepan property. Sears The Sears property is 20.6 acres and has an active warehouse facility for the temporary storage of appliances. The warehouse covers 6.5 acres and is Sears’ largest distribution facility in the northeast. Eleven acres are paved and the remaining area is vegetated. A three-acre wetland area is located to the east of the warehouse. A low-lying area along a rail spur is also classified as a wetland. The Buried Container Area (BCA) is located on the Sears property. DeSaussure The DeSaussure property has an active office equipment and furniture wholesale business. The property has a 52,000 square foot office/warehouse and asphalt parking area that covers almost half of the 3.6-acre property. The remaining portions of the property are wooded, covered with

vegetation and include a 0.4-acre wetland. The Gypsum Area (GA) is located on the DeSaussure property. Geology and Hydrogeology The following is an overview of the regional and Site geology and hydrogeology. A detailed description of the geology and hydrogeology for the study area is presented in the RI Report (CH2M Hill, 1994). Additional groundwater investigation work is underway and will be incorporated in the future groundwater ROD. The Site bedrock is primarily composed of sedimentary rock with some igneous intrusions. The upper portion of the bedrock ranges from 0.5 to 15 feet thick (approximately 12 to 27 feet below grade) and is moderately to severely weathered. The overburden is divided into two deposits: the fill and recent age deposits. The latter consist of stratified glacial deposits, unstratified glacial deposits and residual soil. The overburden thickness varies from two to 15 feet at the Site. Surface Water The Lodi Brook originates on the 149-151 Maywood Avenue (Sears) property in a low marshy area and flows approximately 1,400 feet as an open channel through the 149-151 Maywood Avenue property to NJ State Route 17. Lodi Brook is a continuously-fed, or perennial, stream, with an estimated base flow of 410.06 cubic meters per second (m3/s) (2 cubic feet per second [cfs] (DOE), 1992). Lodi Brook is fed by shallow groundwater at the two headwater tributaries that originate in wetlands; however, the main channel does not appear to be a major groundwater discharge point. Lodi Brook also receives intermittent storm water runoff. At NJ State Route 17, Lodi Brook is routed into a culvert pipe and flows south to the Saddle River. INVESTIGATIONS SUMMARY

Chronology of Investigations and Studies Remedial investigation (RI) activities were conducted to determine the nature and extent of chemical contamination on the Stepan property, the DeSaussure property and the Sears and adjacent properties so that remedial actions could be planned and implemented. The RI for these properties was conducted from August 1991 through November 1992. In June 1993, EPA completed a Site baseline risk assessment based on the RI findings. Additional investigations included a 1994 investigation of leather waste and chromium contaminated soil on the Stepan property. The RI report was completed in November 1994. Additional groundwater testing, pilot tests and treatability studies were conducted from 1997 to 2006. Feasibility

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Studies (FS) to identify and evaluate remedial alternatives began in 1995 and the final soil and source areas FS was completed in August 2013. NJDEP soil cleanup guidelines that were in place at the time the RI was performed and EPA’s baseline risk assessment findings were used as points of reference for evaluating analytical results. The baseline risk assessment (discussed in further detail in the “Summary of Site Risk” section) assumed that the future use of the Stepan portion of the Site would remain commercial but the future use of the Sears and adjacent properties would be both commercial and potentially residential. However, in keeping with local land-use trends and plans, and to be consistent with the future land-use assumptions in the 2003 ROD for FUSRAP Soils and Buildings, a future commercial land-use scenario was considered for all properties in the August 2013 FS and this Proposed Plan. The August 2013 FS therefore compares the soil results to the more recent December 2008 NJDEP default impact-to-groundwater screening levels, as well as the NJDEP Non-Residential Direct Contact Soil Remediation Standards (NJAC 7:26D). NATURE AND EXTENT OF CONTAMINATION Several distinct investigation activities were conducted during the RI and included surface geophysical investigations, soil borings, test pits and sampling. The following paragraphs briefly summarize the results of the sampling conducted during the Site investigations. Buried Waste Materials Buried waste materials identified and sampled during the RI soil and test pit investigations included: gypsum waste on the DeSaussure property; buried drums and waste located primarily on the Sears property; and leather wastes and chromium-contaminated soil located on the Stepan property. During the RI, 129 test pits were excavated. Of these, 19 (three on Stepan, two on DeSaussure, and 14 on Sears) were found to contain crushed drums or drum remains with no contents; however, an additional 16 test pits excavated on the Sears property contained drums with waste contents. Twenty test pit samples, plus three duplicate samples, were collected and analyzed. Samples were collected from drum contents and test pit soil. The waste samples collected from the test pit program showed elevated concentrations of VOCs. All samples which had concentrations of VOCs exceeding NJDEP guidelines were collected from sludges within drums, with one exception: a sample collected from soil associated with a crushed drum on the Sears property

Test pit investigations on the Stepan property found tanned leather waste material in both the surface and the subsurface of an area now known as the LMA. This material consisted of purple fibrous material, assumed to be the by-product of former protein extraction operations. Chromium was detected in the leather waste and soil at concentrations in excess of the NJDEP non-residential direct contact soil remediation standard. The results of the investigation indicate that, although the soil contains high levels of total chromium, the more mobile hexavalent form is found in very low concentrations. Samples of blue, silty material taken from the G A, found on the DeSaussure property, showed cyanide concentrations which exceeded the NJDEP impact-to groundwater screening level. Soil The objective of the RI soil boring and sampling program was to identify and characterize existing sources of chemical, non-radiological contamination in the overburden soil. During this investigation, 44 soil bore holes were installed throughout the Site and 126 soil samples were collected and analyzed. Several VOCs were detected at concentrations exceeding the NJDEP impact-to-groundwater cleanup guidelines. Based on the RI results, a soil gas investigation and soil boring sampling program was conducted to determine if the soil in the CTFA and in the FAA (both on Stepan’s property) are likely a source of VOC contamination in groundwater. Benzene, toluene, ethylbenzene, and xylene (BTEX) were detected at concentrations exceeding NJDEP guidelines. Acetone was also found in the CTFA in concentrations exceeding the impact-to-groundwater screening level. During the RI, a review of existing plant operations was conducted to determine if there was a continuing source of soil contamination impacting groundwater. Based on the types of raw materials, intermediates, products and by-products currently handled in the CTFA, a continuing source of VOC contamination to soil from current activities does not appear to be present, although residual soil contamination may continue to contribute to groundwater contamination. Arsenic and several other inorganic contaminants were detected in soil at concentrations exceeding the NJDEP direct contact soil cleanup guidelines.

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SCOPE AND ROLE OF ACTION The actions described in this Proposed Plan are for the remediation of chemically-contaminated soil and buried waste at the Site for the protection of human health and the environment. These actions are in addition to, but separate from, those being undertaken by the USACE primarily addressing radiological contamination. Under several administrative orders issued by EPA, Stepan has conducted an investigation of chemical contamination at the Site, excluding the MISS. Remedial activities for the chemical contamination described in this Proposed Plan that will be undertaken in areas potentially radiologically contaminated will be addressed in coordination with the USACE, as necessary. Soils containing VOCs, SVOCs, inorganic compounds and buried wastes are being addressed because they may be potential sources of contamination to groundwater or pose a threat due to exceeding non-residential direct contact standards. However, chemically-contaminated groundwater associated with these soil areas will be addressed by a future remedial action. This groundwater contamination is separate from the groundwater contamination addressed by the USACE 2012 Groundwater ROD. Site cleanup responsibilities are divided between USACE and Stepan, based primarily on area and contamination source, as described in the SITE HISTORY section. ENFORCEMENT In 1987, Stepan Company entered into an Administrative Order on Consent with EPA to perform an RI/FS on the Sears and adjacent properties, focusing on chemical, non-radiological contamination. In 1989, EPA requested Stepan Company to expand the scope of the investigation described in the consent order to include an investigation on its own property as well. However, because EPA and Stepan could not agree upon the scope of the project, in June 1991, Stepan Company was ordered to perform RI/FS activities on its own property through an EPA Unilateral Administrative Order. Field activities for the expanded chemical investigation on the Sears and adjacent properties and the Stepan Company property began in late 1991.

SUMMARY OF SITE RISKS Baseline Risk Assessment A baseline risk assessment was conducted to determine the risks associated with current and future Site conditions. The baseline risk assessment evaluates the human health and ecological risks which could potentially result from the contamination at the Site if no remedial action were taken. Human Health Risk Assessment A four-step process is utilized for assessing site-related human health risks for a reasonable maximum exposure scenario. The first step, Hazard Identification, identifies the contaminants of concern based on factors such as toxicity, frequency of occurrence, and concentration. The second step, Exposure Assessment, estimates the magnitude of actual and potential human exposures, the frequency and duration of these exposures, and the pathways by which humans are potentially exposed (e.g., by ingesting contaminated well water). The third step, Toxicity Assessment, determines the types of adverse health effects associated with chemical exposures and the relationship between the magnitude of exposure (dose) and severity of adverse effects (response). The fourth step, Risk Characterization, summarizes and combines outputs of the exposure and toxicity assessment to provide a quantitative assessment of site-related risks. The baseline human health risk assessment was conducted in 1993 and evaluated potential risks under both current and likely future use scenarios. Current use scenarios focused on commercial/industrial land use. However, because future land use was thought to vary for different parts of the Site, the Sears and adjacent commercial properties and the Stepan property were evaluated separately. The Final Risk Assessment divided the Site into two distinct future potential use categories: (1) industrial use for the Stepan property, and (2) residential use for the Sears and adjacent commercial properties. The results of the baseline risk assessment indicate that the future ingestion of contaminated surface soil at the Site poses an unacceptable risk to human health. The possible ingestion of arsenic-contaminated surface soil on the Sears property by children in the future residential use scenario was found to have an estimated Hazard Index (HI) equal to 2, which exceeds the guideline of 1.0. However the carcinogenic risk due to ingestion of the surface soils did not exceed the risk range. PAHs, including benzo(a)pyrene, were identified as risk drivers due to human ingestion exposure pathways for surface and subsurface soils.

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Surface water and sediment samples were collected from the Site wetland areas as part of the RI and the risk assessment evaluated a youth wetlands trespasser scenario for these samples and found no risk drivers present. As part of the FS, an updated risk screening evaluation was performed, in order to ensure that updated toxicity information for site-related chemicals would be considered in the identification of chemicals of potential concern (COPCs). Additionally, future land use was reevaluated. In keeping with the local land use trends and plans and to be consistent with the future land-use assumptions made in the USACE 2003 ROD for FUSRAP Soil and Buildings, a future commercial land-use scenario was assumed for all properties. The FUSRAP Soils and Buildings ROD already requires deed notices restricting the Stepan and Sears properties to non-residential use. The assumption of continued non-residential use is also consistent with current surrounding property uses. The updated risk-screening evaluation compared the maximum detected concentrations of chemicals detected in each of the five areas to current NJDEP soil remediation standards, EPA risk-based screening levels for commercial/industrial land use and NJDEP impact-to-groundwater soil screening levels. The following chemicals were identified as COPCs in soil or waste material for each AOC: AOC1 – BCA

• VOCs (1,1,1-trichloroethane, acetone, benzene, chloroform, ethylbenzene, methylene chloride, toluene, TCE and xylenes)

• SVOCs (benzo(a)anthracene and benzo(a)pyrene) • Metals (arsenic, chromium, lead and lithium)

AOC2 – GA

• SVOCs (benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene and indeno(1,2,3-cd)pyrene)

• Metals (arsenic, barium, chromium, cyanide, lead and mercury)

AOC3 – LMA • SVOCs (benzo(a)anthracene, benzo(a)pyrene and

pentachlorophenol) • Metals (arsenic, chromium and lead)

AOC4 – FAA

• VOCs (benzene and xylenes)

AOC5 – CTFA • VOCs (acetone, benzene, toluene and xylenes)

Ecological Risk Assessment A four-step process is used to assess site-related ecological risk for a reasonable maximum exposure scenario. The first step, Problem Formulation, is a qualitative evaluation of contaminant release, migration, and fate; identification of contaminants of concern, receptors, exposure pathways, and known ecological effects of the contaminants; and selection of endpoints for further study. Exposure Assessment, the second step, is a quantitative evaluation of contaminant release, migration, and fate; characterization of exposure pathways and receptors; and measurements or estimation of exposure point concentrations. The third step, Ecological Effects Assessment, consists of literature reviews, field studies, and toxicity tests, linking contaminant concentrations to effects on ecological receptors. The last step, Risk Characterization, comprises measurement or estimation of both current and future adverse effects. The ecological risk assessment began with evaluating the contaminants associated with the Site in conjunction with site-specific biological species and habitat information. Receptor species may inhabit the wetlands near the entrance to the Sears property. However, due to the extensive development of the Site and surrounding areas, receptor species that may visit the Site are generally expected to be limited. Surface water at the Site is intermittent, the habitat area is small and not particularly attractive due to industrial and commercial activities and because of these factors the ecological community is not robust. The results of the ecological risk assessment indicated that the contaminated surface water and sediment at the Site may pose limited risk to aquatic receptors. Actual or threatened releases of hazardous substances from this Site, if not addressed by the preferred alternative or other active remedial alternatives considered here, may present a current or potential threat to public health, welfare or the environment.

WHAT IS RISK AND HOW IS IT CALCULATED? A Superfund baseline human health risk assessment is an analysis of the potential adverse health effects caused by hazardous substance releases from a site in the absence of any actions to control or mitigate these under current and future land uses. A four-step process is utilized for assessing site-related human health risks for reasonable maximum exposure scenarios. Hazard Identification: In this step, the chemicals of potential concern (COPCs) at the site in various media (i.e., soil, groundwater, surface water, and air) are identified based on such factors as toxicity, frequency of occurrence, fate and transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility, persistence, and bioaccumulation.

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Toxicity Assessment: In this step, the types of adverse health effects associated with chemical exposures, and the relationship between magnitude of exposure and severity of adverse effects are determined. Potential health effects are chemical-specific and may include the risk of developing cancer over a lifetime or other noncancer health hazards, such as changes in the normal functions of organs within the body (e.g., changes in the effectiveness of the immune system). Some chemicals are capable of causing both cancer and noncancer health hazards. Risk Characterization: This step summarizes and combines outputs of the exposure and toxicity assessments to provide a quantitative assessment of site risks for all COPCs. Exposures are evaluated based on the potential risk of developing cancer and the potential for noncancer health hazards. The likelihood of an individual developing cancer is expressed as a probability. For example, a 10-4 cancer risk means a “one in ten thousand excess cancer risk”; or one additional cancer may be seen in a population of 10,000 people as a result of exposure to site contaminants under the conditions identified in the Exposure Assessment. Current Superfund regulations for exposures identify the range for determining whether remedial action is necessary as an individual excess lifetime cancer risk of 10-4 to 10-6, corresponding to a one in ten thousand to a one in a million excess cancer risk. For noncancer health effects, a “hazard index” (HI) is calculated. The key concept for a noncancer HI is that a “threshold” (measured as an HI of less than or equal to 1) exists below which noncancer health hazards are not expected to occur. The goal of protection is 10-6 for cancer risk and an HI of 1 for a noncancer health hazard. Chemicals that exceed a 10-4 cancer risk or an HI of 1 are typically those that will require remedial action at the Site.

REMEDIAL ACTION OBJECTIVES Remedial Action Objectives (RAOs) are specific goals established to protect human health and the environment. The following RAOs address human health risks, environmental concerns, contaminants of concern, exposure routes, receptors and acceptable contaminant levels for each exposure route at the Site. To attain these objectives, the selected remedy must meet promulgated, enforceable federal or more stringent state “applicable or relevant and appropriate requirements” (ARARs). EPA must further consider standards provided by other advisories, criteria and guidance which EPA deems necessary to protect human health and the environment and risk-based cleanup levels established in the risk assessment. The RAOs are listed below:

• Prevent ingestion of/direct contact with contaminated soil above levels that are protective of human health.

• Prevent inhalation of or exposure to contaminants volatilizing from contaminated soil above levels that are protective of human health.

• Prevent the off-site migration of contaminated soil.

• Prevent impacts to groundwater resulting from contaminated soil.

The remedial action levels for specific contaminants which must be met in order to achieve these objectives were developed for each area of the Site by considering, among other things, the risk levels identified in the risk assessment as well as New Jersey soil remediation standards for direct contact, New Jersey impact to groundwater soil screening levels and vapor intrusion. Please see Table 1 for a list of Preliminary Remediation Goals (PRGs). SUMMARY OF REMEDIAL ALTERNATIVES Common Elements The 2013 FS report describes the remedial alternatives developed and screened for each AOC. Many of these alternatives include common components. For example, CERCLA requires that each selected site remedy: be protective of human health and the environment; be cost effective; comply with other statutory laws; and utilize permanent solutions and alternative treatment technologies and resource recovery alternatives to the maximum extent practicable. In addition, the statute includes a preference for the use of treatment as a principal element for the reduction of toxicity, mobility, or volume of hazardous substances. If the selected remedial alternative would result in some contaminants remaining at the Site above levels that would allow for unrestricted use, a review of the remedy would be conducted every five years, at minimum. Institutional Controls (IC), including but not limited to a deed notice, would be required to maintain the long-term protectiveness of the implemented remedy by ensuring that future use remains commercial/industrial. Other IC measures such as a restrictive covenant and easement may also be required. Monitoring to ensure the effectiveness of the remedy, including ICs, is a component of each alternative except the “no-action” alternative. Alternatives with excavation components would require backfilling with certified clean fill as part of the restoration. Three AOCs have alternatives which include a capping component, to prevent direct contact with residual contaminated soil or to protect solidified contamination. These alternatives would be supplemented with ICs to ensure the integrity of the cap by preventing intrusive activities. ICs would require periodic inspections and reporting. Buried Container Area of Concern The BCA is located in the southern portion of the Sears property. The BCA is approximately 20.6 acres and is adjacent to the Sears Logistics Building. Figure 1 shows a location map with the BCA boundaries. This Proposed Plan does not address the inaccessible area beneath the Sears Logistics Building which will be remediated under the

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FUSRAP project once the material becomes accessible. BCA materials have been identified at four feet below the ground surface with one exception noted below. The BCA was undeveloped, wooded and open land until the 1950’s. By 1970 the property was completely developed. Organic residues from industrial production activities at the Maywood Chemical Company included resins and oily materials. Solvents and degreasers, both halogenated and non-halogenated organic compounds, were detected in these residues, which were placed in drums in various locations on the Sears property and were covered with pavement or by other construction activities. The exact dates of the burial of the drums in the BCA are unknown, but based on land use activities, the drums were probably buried at some time between 1960 and 1970. Thirty test pits on the Sears property contained drums with residual contents sampled during the RI. Elevated concentrations of several VOCs, SVOCs and metals were identified in BCA soils and waste materials and are considered contaminants of concern (COCs). These COCs are considered risks to human health by direct contact exposure, potential future vapor intrusion pathways and impact to groundwater. It is important to note, that USACE is remediating accessible FUSRAP waste on the Sears property. More than 70% of the BCA has been remediated by the USACE at this time. FUSRAP waste excavation depths are typically four feet deep in this AOC, because the man-made fill is found to this depth. It is estimated that a total area of approximately 2.2 acres where no FUSRAP cleanup is required, containing 14,600 cubic yards of contamination, will require remedial action to depths of approximately four feet below the ground surface, except in one “hot spot” location where contamination is located at four to eight feet below the surface. BCA-1 – No Action The NCP requires that a “No Action” alternative be developed as a baseline for comparing other remedial alternatives. Under this alternative, there would be no actions conducted at the Site to control, remove, treat or prevent exposures to Site contaminants. This alternative may not result in long-term protection of public health and the environment. BCA-2 – Institutional Controls (ICs)

• ICs to restrict land use to non-residential activities and to prevent activities that would allow contaminant exposure and migration

• Inspections

• Cost: $559,000 net present value (NPV)--includes investigation to delineate IC areas

BCA-3 – In Situ Solidification, Buried Container Excavation and Capping, ICs

• In Situ solidification of contaminated soil o Bench Scale Testing o In Situ Solidification Field Implementation

• Excavation of buried container materials and VOC-contaminated soil with off-site disposal

• Backfilling of excavated areas with certified fill • Capping (such as asphalt or similar material in

active areas, soil in vegetated areas) to protect solidified material

• ICs • Long-term Inspection and Maintenance • Cost: $2,809,000 NPV • Ten weeks construction

BCA-4 – Excavation, Off-site Disposal, ICs

• Excavation of buried container materials and VOC-contaminated soil at depths to four feet below the surface, with off-site disposal

• ICs • Long-term Inspection and Maintenance • Cost: $7,254,000 NPV • 22 weeks construction

What is Soil Solidification? Alternatives BCA-3 and GA-3 include a technology called soil solidification. Solidification refers to cleanup methods that prevent or slow the release of harmful chemicals from wastes such as contaminated soil, sediment, and sludge. These methods usually do not destroy the contaminants. Instead, they keep them from "leaching" above safe levels into the surrounding environment. Solidification binds the waste in a solid block of material and traps it in place. This block is also less permeable to water than the waste. Solidification involves mixing a waste with a binding agent, which is a substance that makes loose materials stick together. Common binding agents include cement, asphalt, fly ash, and clay. Water must be added to most mixtures for binding to occur; then the mixture is allowed to dry and harden to form a solid block. Additives can be mixed into the waste while still in the ground (often referred to as "in situ"). This usually involves drilling holes using cranes with large mixers or augers, which both inject the additives underground and mix them with the waste. Alternatively, when the waste is shallow enough, the contaminated soil or waste is excavated and additives are mixed with it above ground (often referred to as "ex situ"). Solidified or stabilized waste mixed above ground is either used to fill in the excavation or transported to a landfill for disposal.

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Gypsum Area of Concern The GA is located on the northern and northeastern portions of the DeSaussure property at 23 Howcroft Road. The GA is approximately 1.5 acres with gypsum material found at depths of four feet below ground surface. Gypsum sulfate (calcium sulfate) was used as a filter aid during caffeine extraction from tea waste. As much as 600 tons of gypsum material from these processes, which also contained cyanide and metals, were reportedly disposed of within the boundaries of the present-day DeSaussure property. Exact dates of the gypsum disposal are unknown. The gypsum material is typically identified visually by its blue color. USACE removed FUSRAP waste from this area and it is estimated that 6,250 cubic yards of gypsum waste material remain on the GA. SVOCs and metals were identified as COCs and the risk indicated that cyanide within the GA could be a soil impact-to-groundwater risk. GA-1 – No Action (BCA-1) GA-2 – Institutional Controls

• ICs to restrict land use to non-residential activities and to prevent activities that would allow contaminant exposure and migration

• Inspections • Cost: $378,000 NPV

GA-3 – In Situ Solidification, ICs, In Situ solidification of gypsum material and impacted soil with stabilizing agent (e.g., cement) and capping

o Pilot Test o In Situ Solidification Field Implementation

• ICs • Long-term Inspection and Maintenance • Cost: $2,084,000 NPV • 18 weeks construction

GA-4 – Excavation, Off-site Disposal, ICs

• Excavation of gypsum material and impacted soil with ex situ stabilization, if needed for off-site disposal

• ICs • Inspections • Five-year reviews • Cost: $3,866,000 NPV • 10 weeks construction

Leather Material Area of Concern The LMA is located within the northwestern portion of the Site on the Stepan property and is approximately 3.4 acres in area. The LMA consists of leather material (raw leather material, residual tanned leather, or filter cake from leather digestion) located in two separate areas on the northwestern

portion of the Stepan property. One area is located west of Stepan Building 67 and is approximately 95,000 sq ft (designated as LMA-A). The second area (designated as LMA-B) is located south of LMA-A and southwest of the Former Aromatics Area and is approximately 35,000 sq ft in area. The leather material reportedly extends to approximately two feet below ground surface with one hot spot at four feet below ground surface. It is estimated that about 6,550 cubic yards of material would require remedial action. This area has a direct contact risk associated with chromium in the soil and leather waste material. SVOCs and metals were identified as COCs, based on direct contact risk and impact-to-groundwater. LMA-1 – No Action (See BCA-1) LMA-2 – Institutional Controls

• ICs to restrict land use to non-residential activities and to prevent activities that would allow contaminant exposure and migration

• Inspections • Cost: $129,000 NPV

LMA-3 – Capping

• Cap consisting of asphalt or similar material in LMA-A and six inches of soil in LMA-B to prevent contaminant exposure and migration

• ICs • Long-term inspection and maintenance • Cost: $884,000 NPV • Four weeks construction

LMA-4 – Excavation and Off-site Disposal, ICs

• Excavation of remaining contaminated material with off-site disposal

• ICs • Long-term inspection and maintenance • Cost: $3,318,000 NPV • Six weeks construction

Former Aromatics Area of Concern The FAA is located to the west of Building 10 in the southwestern portion of the Stepan property. The FAA is approximately 0.37 acres in area. The FAA formerly contained a number of buildings related to the production of essential oils and aromatic chemicals. These buildings were removed in the late 1960s. Underground utilities corridors for storm sewer, sanitary sewer and water lines are located within the FAA. VOCs including benzene and xylene were found in the soil and are attributed to former underground storage tanks. Approximately 3,220 cubic yards of contamination from zero to six feet below the surface will require remedial action due to direct contact and impact-

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to-groundwater risks associated with benzene and total xylenes in soil. FAA-1 - No Action (See BCA-1) FAA-2 - Institutional Controls

• ICs to restrict land use to non-residential activities and to prevent activities that would allow contaminant exposure and migration

• Inspections • Cost: $116,000 NPV

FAA-3 – Excavation and Off-site Disposal, ICs

• Excavation of remaining contaminated material with off-site disposal

• ICs • Cost: $1,805,000 NPV • Four to six weeks construction

FAA-4 – In Situ Enhanced Fluid Recovery (EFR) and Excavation with Off-site disposal

• Pilot Study • Extraction of contaminated soil vapors from 111

new shallow extraction wells in the FAA • Excavation via “air knife” or vacuum excavation of

soil in utility areas with off-site disposal • ICs • Long-term Inspections and Maintenance • Five-year reviews • Cost: $3,440,000 NPV • Three months construction • Estimated five years of monthly EFR events

FAA-5 – In Situ Soil Vapor Extraction (SVE) and Excavation with Off-site Disposal, ICs

• Pilot Study • Extraction of contaminated soil vapors from 13 new

horizontal extraction wells • Excavation via “air knife” or vacuum excavation of

soil in utility areas with off-site disposal • ICs • Five-year reviews • Cost: $1,793,000 NPV • Three months construction • Estimated five years SVE operation

What is Soil Vapor Extraction? Alternatives FAA-4, FAA-5, CTFA-4 and CTFA-5 all propose some form of soil vapor extraction or "SVE". SVE is a technology that extracts (removes) contaminant vapors from below ground for treatment above ground. Vapors are the gases that form when chemicals evaporate. SVE extracts vapors from the soil above the water table by applying a vacuum to pull the vapors out. SVE involves drilling one or more extraction wells into the contaminated soil to a depth above the water table. Attached to the wells is equipment (such as a blower or vacuum pump) that creates a vacuum. The vacuum pulls air and vapors through the soil and up the well to the ground surface for treatment. Extracted air and contaminant vapors, sometimes referred to as "off-gases," are treated to remove any harmful levels of contaminants. The off-gases are first piped from the extraction wells to an air-water separator to remove moisture, which interferes with treatment. The vapors are then separated from the air, usually by pumping them through containers of activated carbon. The chemicals are captured by the carbon while clean air exits to the atmosphere. Soil vapor extraction methods can help clean up contamination under buildings, and cause little disruption to nearby activities when in full operation. What is Air Knife Extraction? The air knife excavation method uses a high velocity air lance to inject an air stream into the pores and fissures of the soil to blast the compacted soil apart. A powerful vacuum hose follows the air lance to vacuum the soil and clean out the hole for visual inspection. The soil is deposited in a holding tank and characterized for proper disposal.

Central Tank Farm Area of Concern The CTFA is located adjacent to the north and west of Building 10 in the central portion of the Stepan property. The CTFA is approximately 0.20 acres in area and formerly contained a number of petroleum and solvent underground storage tanks that were removed around 1991. Underground utilities lane areas for storm sewer and sanitary sewer are located within the CTFA. Approximately 800 cubic yards of soil will require remedial action due to direct contact risks and impacts to groundwater associated with acetone, benzene, toluene and total xylenes in soil. The FS indicates that soil contamination to a depth of seven feet below the surface requires cleanup. CTFA-1 - No Action (See BCA-1) CTFA-2 - Institutional Controls

• ICs to restrict land use and subsurface activities • Monitoring • Cost: $ 116,000 NPV

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CTFA-3 – Excavation and Off-site Disposal, ICs • Excavation of remaining contaminated material

with off-site disposal • ICs • Long-term inspections and maintenance • Five-year reviews • Cost: $ 1,017,000 NPV • Two to three weeks construction

CTFA-4 – In Situ Enhanced Fluid Recovery (EFR) and Excavation with Off-site disposal, ICs

• Pilot Study • Extraction of contaminated soil vapors from 32 new

shallow extraction wells in the FAA • Excavation via “air knife” or vacuum excavation of

soil in utility areas with off-site disposal • ICs • Long-term inspections and maintenance • Five-year reviews • Cost: $ 1,548,000 NPV • 10 weeks construction • Estimated five years of monthly EFR events

CTFA-5 – In Situ Soil Vapor Extraction (SVE) and Excavation with Off-site disposal, ICs

• Pilot Study • Extraction of contaminated soil vapors from three

new horizontal extraction wells • Excavation via “air knife” or vacuum excavation of

soil in utility areas with off-site disposal • ICs • Long-term inspections and maintenance • Five-year reviews • Cost: $ 1,220,000 NPV • 10 weeks construction • Estimated five years of SVE operation

THE NINE SUPERFUND EVALUATION CRITERIA 1. Overall Protectiveness of Human Health and the Environment evaluates whether and how an alternative eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or treatment. 2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) evaluates whether the alternative meets federal and state environmental statutes, regulations, and other requirements that pertain to the Site, or whether a waiver is justified. 3. Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the environment over time.

4. Reduction of Toxicity, Mobility, or Volume (TMV) of Contaminants through Treatment evaluates an alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the amount of contamination present. 5. Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to workers, the community, and the environment during implementation. 6. Implementability considers the technical and administrative feasibility of implementing the alternative, including factors such as the relative availability of goods and services. 7. Cost includes estimated capital and annual operations and maintenance costs, as well as present worth cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are expected to be accurate within a range of +50 to -30 percent. 8. State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses and recommendations, as described in the RI/FS and Proposed Plan. 9. Community Acceptance considers whether the local community agrees with EPA's analyses and preferred alternative. Comments received on the Proposed Plan are an important indicator of community acceptance.

COMPARATIVE EVALUATION OF REMEDIAL ALTERNATIVES FOR EACH AOC

Comparison of Remedial Alternatives - AOC1-Buried Container Area

A comparative analysis was conducted under which the alternatives were compared using the nine NCP evaluation criteria. The purpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

1. Overall Protection of Human Health and the Environment

All of the alternatives except BCA-1 and BCA-2 protect human health and the environment. Potential risks from direct contact, inhalation and migration of soil contaminants, including impacts to groundwater, are addressed by BCA-3 and BCA-4. Alternatives, BCA-2, BCA-3 and BCA-4, all include implementation of ICs to restrict future development of the Site to non-residential uses. However, BCA-2 would not address potential impacts to groundwater. Under BCA-4, buried containers and contaminated soils would be removed, thus eliminating the potential source of the contamination.

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2. Compliance with ARARs

The No Action BCA-1 alternative would not comply with ARARs. The institutional control BCA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs the New Jersey Non-Residential Direct Contact Soil Remediation Standards (N.J.A.C.7:26D). The in situ solidification BCA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through stabilization and capping with ICs to protect the cap and stabilized material. BCA-3 would also prevent contaminant migration and impacts to groundwater. The excavation and disposal BCA-4 alternative would comply with ARARs by removing contaminated soil. The BCA-3 and BCA-4 alternatives would also comply with location-specific NJ wetlands requirements.

3. Long-Term Effectiveness and Permanence

BCA-4 would provide the highest degree of long-term effectiveness and permanence. Under BCA-4, buried containers, associated waste materials and contaminated soil would be permanently removed from the Site. BCA-3 provides the next highest degree of long-term effectiveness. Under BCA-3 buried containers and contaminated materials would be removed from the Site and all other remaining contaminated soils would be either solidified in place or capped. Remaining contaminated soil above the groundwater table would be covered with a cap which would effectively prevent human exposure and minimize infiltration. Remaining contaminated soil in proximity to or below the groundwater table would be treated with in situ solidification. In situ solidification would immobilize contaminants in the soil which would reduce the material’s permeability and its potential for leaching contaminants into the groundwater. The long-term effectiveness and permanence of in situ solidification is dependent on the proper selection of reagents and mixing ratios. If proper mixing during installation does not occur, this may affect the long-term effectiveness and permanence of the treatment. The long-term effectiveness and permanence of the cap is directly related to the inspection and maintenance program. Annual inspections would be a key component of the alternatives to verify the continued integrity of the cap and ensure defects are repaired as needed to maintain an effective barrier to underlying soils. BCA-1 would provide the lowest and BCA-2 would provide the next lowest long-term effectiveness since BCA-1 would not prevent exposures to soil contaminants in the vegetated area east of the building.

4. Reduction of Toxicity, Mobility, Volume of Contamination through Treatment

BCA-3 is the only alternative that will provide a reduction in mobility of the contaminants through treatment by solidifying contaminated soil located in proximity to, or below, the groundwater table. BCA-3 and BCA-4 may require ex situ treatment if contents of buried containers and associated contaminated soils are determined to be hazardous and do not meet Land Disposal Restriction (LDR) requirements. This could potentially reduce contaminant mobility, but would not reduce toxicity or volume of contamination. BCA-2 and BCA-1 provide no reduction of toxicity, mobility, or volume of contamination through treatment

5. Short-Term Impacts and Effectiveness

BCA-3 and BCA-4 will result in some disruption to the Site during remedy implementation. During implementation of either of these alternatives dust control and air monitoring programs would be required to address potential exposures to commercial workers and the surrounding community resulting from extensive soils handling and temporary storage (i.e. temporary stockpiling, sifting for buried containers) which has the greatest potential to generate dust. Of these two alternatives, BCA-4 would have the highest short-term impacts since this alternative is assumed to take the longest to implement and has the potential to generate the most amount of traffic. Under BCA-4 if direct loading (placing excavated materials directly into a shipping container) of contaminated materials is possible, the impacts may be slightly lowered since direct loading could eliminate the need to temporarily stockpile contaminated soil on Site; this would be evaluated during the remedial design. Under BCA-3 temporary stockpiling of contaminated soils will be required in order to remove buried containers from the excavated areas.

BCA-2 would have minimal impacts compared to BCA-3 and BCA-4. Potential impacts and mitigation measures would be identified during design. BCA-1 will have no short-term impacts.

6. Implementability

In general, all of the AOC1-BCA alternatives evaluated in this FS are readily implementable and none require specialty equipment. BCA-3 and BCA-4 may be the most difficult to implement without interrupting the warehouse’s operations and would require coordination with the property owner and tenant. In situ solidification as proposed under BCA-3 may be difficult to implement due to the high

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groundwater table which may cause difficulty in providing the correct reagent-to-water mix ratio.

7. Relative Cost

Alternative Total Present Value BCA-1 No Action 0 BCA-2 ICs $559,000 BCA-3 In situ solidification, excavation & off-site disposal of buried containers, and cap

$2,809,000

BCA-4 Excavation and off-site disposal

$7,263,000

Comparison of Remedial Alternatives – AOC2-Gypsum Area

A comparative analysis was conducted under which the alternatives were compared using the nine NCP evaluation criteria. The purpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

1. Overall Protection of Human Health and the Environment

All of the alternatives except the no action alternative (GA-1) provide protection of human health and the environment. Risks from direct contact of contaminated soil and gypsum material are addressed by the institutional controls alternative (GA-2), but this alternative does not address potential impacts to groundwater, and would not be protective in the long-term. Impacts from direct contact and migration of contaminants to groundwater from the gypsum material are addressed by GA-3 and GA-4. Exposure risks are slightly lower under GA-4 compared to GA-3 because the gypsum material and contaminated soil would be permanently removed from the Site. Both the GA-3 and GA-4 alternatives include implementation of institutional controls to restrict future development of the Site to non-residential uses. Under GA-4, the gypsum material and contaminated soil would be removed, eliminating the source of cyanide leaching into the groundwater and protect the environment.

2. Compliance with ARARs

The No Action GA-1 alternative would not comply with ARARs. The institutional control GA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The in situ solidification GA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through stabilization and capping with ICs to

protect the cap and stabilized material. GA-3 would also prevent contaminant migration and impacts to groundwater. The excavation and disposal GA-4 alternative would comply with ARARs by removing contaminated soil. The GA-3 and GA-4 alternatives would also comply with location-specific NJ wetlands requirements.

3. Long-Term Effectiveness and Permanence

GA-4 would provide the highest degree of long-term effectiveness and permanence. Under GA-4, gypsum material and contaminated soil would be permanently removed from the Site. GA-3 provides the next highest degree of long-term effectiveness. Under this alternative, the gypsum material would be solidified, which reduces potential leaching of contaminants to groundwater. The solidified material would be protected with a soil cap and institutional controls would be implemented to prevent human contact with the solidified material. The long-term effectiveness and permanence of the in situ solidified material is dependent on the proper selection of reagents and mixing ratios. If proper mixing during installation does not occur, this could affect the long-term effectiveness and permanence of the treatment. Routine maintenance of the cover will be necessary to provide continued protection of the solidified material from weathering and human activities. GA-1 and GA-2 would not provide for long-term effectiveness or permanence.

4. Reduction of Toxicity, Mobility, Volume of Contamination through Treatment

GA-3 is the only alternative that would provide a reduction in mobility and toxicity of the hazardous constituents through treatment by solidifying the gypsum material and contaminated soil. GA-4 would not provide reduction of toxicity and volume of the contaminated materials through treatment but simply would move the materials from the AOC to a facility where mobility would be reduced. GA-4 may provide some reduction in toxicity and mobility through treatment if it is determined through waste characterization sampling that the gypsum material requires treatment prior to disposal. GA-2 and GA-1 provide no reduction of toxicity, mobility, or volume of contamination through treatment.

5. Short-Term Impacts and Effectiveness

GA-4 would have the highest short-term impacts since this alternative has the highest potential to generate dust which could increase contaminant exposure to workers, the community and surrounding properties. The volume of material requiring off-site disposal would generate vehicle movement and truck traffic for a majority of the duration of

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construction, estimated to take one to two months. GA-3 would also present short-term impacts, but not to the degree of those in GA-4, since solidification will be in situ. Also, contaminated materials and reagents used in GA-3 would be moist, which could reduce the potential to generate dust and airborne particles during remedy implementation. Truck traffic would not be as significant under GA-3 as under GA-4, since little if any materials would require off-site disposal. Both GA-3 and GA-4 would have short-term impacts to the wetland and would therefore require restoration or mitigation. Impacts associated with GA-3 may be greater since placement of stabilized materials having lower hydraulic conductivities than that of existing soil would reduce infiltration and potentially cause water levels in the wetland to rise, resulting in impacts to existing vegetation and wildlife. Both GA-3 and GA-4 would be effective at reducing potential human health exposure to contaminated media and impacts to groundwater. GA-4 would have the highest degree of effectiveness since this alternative would remove the gypsum material which is the source of cyanide contamination. GA-2 would have minimal impacts compared to GA-3 and GA-4, consisting only of sampling necessary to delineate the IC area, while GA-3 and GA-4 would have construction impacts. GA-1 would have no short-term impacts.

6. Implementability

All the alternatives are easily implementable and none of them require any special materials or equipment. GA-3 may be the most difficult to implement due to the high groundwater table in the designated wetlands area. This could cause difficulty in providing the correct reagent-to-water mix ratios during implementation, thereby reducing the effectiveness of the treatment.

7. Relative Cost

Alternative Total

Present Value

GA-1 No Action 0 GA-2 ICs $378,000 GA-3 In situ solidification, cap, ICs $2,084,000 GA-4 Excavation with off-site disposal, ICs $3,866,000

Comparison of Remedial Alternatives - AOC3-Leather Material Areas

A comparative analysis was conducted under which the alternatives were compared using the nine NCP evaluation criteria. The purpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

1. Overall Protection of Human Health and the Environment

LMA-1 would not protect human health and the environment. LMA-3, capping, would provide human health and the environment than LMA-2. LMA-2 does not address potential impacts to groundwater and would not be protective in the long-term. LMA-4 would provide overall protection of human health and the environment, with the removal of the remaining contaminated leather material and soil.

2. Compliance with ARARs

The No Action LMA-1 alternative would not comply with ARARs. The institutional control LMA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The in situ solidification LMA-3 alternative would also eliminate exposure to contaminants that exceed chemical-specific ARARs through capping with ICs to protect the cap and leather material. LMA-3 would also prevent contaminant migration and impacts to groundwater. The excavation and disposal LMA-4 alternative would comply with ARARs by removing contaminated soil. The LMA-3 and LMA-4 alternatives would also comply with location-specific NJ wetlands requirements.

3. Long-Term Effectiveness and Permanence

LMA-1 would not be effective in the long term since no remedial action would be performed. LMA-4 provides the highest degree of long-term effectiveness and permanence because the impacted leather material and soil will be permanently removed from the Site. LMA-3 would provide long-term effectiveness if the asphalt and soil cap are maintained. Institutional controls, long-term inspection and maintenance would need to be implemented and enforced to ensure continued protection of human health and the environment under LMA-2, LMA-3 and LMA-4.

4. Reduction of Toxicity, Mobility, Volume of Contamination through Treatment

LMA-1 and LMA-2 would not address toxicity, mobility, and volume of the contaminated area through treatment. LMA-3 would reduce the mobility, but would not reduce the toxicity or volume of source areas through treatment. LMA-4 would not provide reduction of toxicity and volume of the contaminated materials through treatment, but simply would move the materials from the AOC to a facility where mobility would be reduced.

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5. Short-Term Impacts and Effectiveness

LMA-1 and LMA-2 would not have short-term impacts since no intrusive action would be implemented. LMA-3 and LMA-4 would have some impacts to the community and workers during the construction period. LMA-4 would have a greater impact to the community compared to LMA-3 due to the larger amount of truck traffic needed for off-site disposal of contaminated materials.

6. Implementability

All four alternatives are implementable. LMA-1 would be the easiest to implement since no action would be taken, followed by LMA-2. Implementation of LMA-4 entails some complexity related to off-site disposal of potential radiologically-impacted soil (soils that have chemical contamination co-mingled with material that has residual radioactivity below levels addressed by the USACE). LMA-3 is implementable, but long-term inspection and maintenance to maintain the integrity of the caps would be required.

7. Relative Cost

Alternative Total

Present Value

LMA-1 No Action 0 LMA-2 ICs $129,000 LMA-3 Capping with asphalt and topsoil

$884,000

LMA-4 Excavation and off-site disposal

$3,318,000

Comparison of Remedial Alternatives – AOC4-Former Aromatics Areas

A comparative analysis was conducted under which the alternatives were compared using the nine NCP evaluation criteria. The purpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

1. Overall Protection of Human Health and the Environment

FAA-1 would not protect human health and the environment. FAA-2 would provide short-term protection to human health but would not achieve the RAOs and does not address potential impacts to groundwater, therefore it is not protective over the long-term. FAA-3 would provide overall protection of human health and the environment via removal of contaminated soils from the FAA AOC. FAA-4 and FAA-5 would also provide overall protection of human

health and the environment through a combination of

contaminated soil treatment and removal.

2. Compliance with ARARs

The no action FAA-1 alternative would not comply with ARARs. The institutional control FAA-2 alternative would implement ICs to prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemical-specific ARARs. The FAA-3 excavation and disposal alternative would meet ARARs by excavating the contaminated soils down to the water table and disposing this material off site. The FAA-4 and FAA-5 vapor treatment alternatives would also meet ARARs for VOCs in soil and impacts to groundwater. FAA-3 through FAA-5 would meet the action-specific ARARs by following waste handling and disposal regulations, as applicable.

3. Long-Term Effectiveness and Permanence

FAA-1 would not be effective in the long term since no remedial action would be performed. FAA-2 would effectively reduce the longer term risks by eliminating the potential for direct contact by restricting land use, if institutional controls are maintained and enforced. However, impacts to groundwater would not be addressed. FAA-3 would permanently remove contaminants in soil to groundwater surface and is therefore most effective. FAA-4 and FAA-5 would permanently remove BTEX contamination and are estimated to take longer to complete remediation. Institutional controls and long-term inspection and maintenance would ensure continued protection of human health and the environment under FAA-2 through FAA-5.

4. Reduction of Toxicity, Mobility, Volume of Contamination Through Treatment

FAA-1 and FAA-2 would not address contaminant toxicity, mobility and volume of source areas through treatment. Excavation under FAA-3 through FAA-5 would not provide reduction of toxicity and volume of the contaminated soils through treatment but simply would move the materials from the AOC to a facility where mobility would be reduced. FAA-4 and FAA-5 would provide a reduction in BTEX contaminated soil during the five years of active vapor treatment.

5. Short-Term Impacts and Effectiveness

FAA-1 and FAA-2 would not have any short-term impacts because no intrusive actions would be implemented. FAA-3

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through FAA-5 would have some impacts to the community and workers during the construction period. FAA-3 would have a greater impact to the community compared to FAA-4 and FAA-5 due to the larger amount of truck traffic needed for off-site disposal of contaminated materials and import of certified clean fill. However, FAA-4 and FAA-5 will impact the Stepan facility over a longer period of time due to five years operation and maintenance of the treatment systems.

6. Implementability

All five alternatives are implementable. The no action FAA-1 alternative requires no implementation. FAA-2 is implementable. Excavation under FAA-3 through FAA-5 would be implementable, but the potential for some soil to also have low-level radiological contamination would complicate off-site disposal requirements. (As noted above, soils are contaminated with Site-related chemicals and may be co-mingled with low-level radiological waste. This low-level radiological waste was not addressed by the FUSRAP cleanup because it is below levels that are protective for current and future non-residential land use. ) Excavation in the vicinity of utility lines might present some technical challenges for implementation of FAA-3 through FAA-5. FAA-4 would be implementable; FAA-5 may face implementability issues related to soil permeability; if soil permeability in this area is low it could reduce vapor extraction potential and require additional extraction efforts, such as installation of more extraction wells, to achieve PRGs. Long-term inspection and maintenance would be required to maintain the integrity of the cover in alternatives FAA-3 through FAA-5.

7. Relative Cost

Alternative Total

Present Value

FAA-1 No Action 0 FAA-2 ICs $116,000 FAA-3 Excavation & off-site disposal $1,805,000 FAA-4 In Situ Enhanced Fluid Recovery (EFR) and Excavation with off-site disposal

$3,440,000

FAA-5 In Situ Soil Vapor Extraction (SVE) and Excavation with off-site disposal

$1,793,000

Comparison of Remedial Alternatives - AOC5-Central Tank Farm Area

A comparative analysis was conducted under which the alternatives were compared using the nine NCP

evaluation criteria. The purpose of this analysis is to identify the relative advantages and disadvantages of each alternative.

1. Overall Protection of Human Health and the Environment

CTFA-1 would not protect human health and the environment and would not meet the RAOs. CTFA-2 would provide protection of human health but would not achieve the RAOs for impacts to groundwater. CTFA-3 would provide overall protection of human health and the environment via removal of contaminated soils from the CTFA AOC. CTFA-4 and CTFA-5 would also provide overall protection of human health and the environment through a combination of contaminated soil treatment and removal.

2. Compliance with ARARs

CTFA-1 would not comply with the ARARs and does not address potential impacts to groundwater. CTFA-2 would not meet chemical-specific ARARs, although it would prevent future residential-use soil exposure since currently most of the CTFA contamination is located beneath asphalt which acts as a cap. CTFA-3 would meet ARARs by removing contaminated soils above the water table. CTFA-4 and CTFA-5 would meet ARARs for VOCs in soil and impact to groundwater. CTFA-3, CTFA-4 and CTFA-5 would meet the action-specific ARARs by following the waste handling and disposal regulations.

3. Long-Term Effectiveness and Permanence

The no action CTFA-1 alternative would not be effective in the long term, because contamination could be exposed to receptors, migrate and impact groundwater. CTFA-2 would effectively reduce the longer term risks by eliminating the potential for direct contact by restricting land use, if institutional controls are maintained and enforced. However, impacts to groundwater will not be addressed. CTFA-3 will permanently remove contaminants in soil to the top of the water table and therefore provides the greatest degree of long-term effectiveness. CTFA-4 and CTFA-5 would permanently remove BTEX contamination; but the time to implement the remedy would be longer in comparison with CTFA-3. Institutional controls and long-term inspection and maintenance would ensure continued protection of human health and the environment in the long term under CTFA-2 through CTFA-5.

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4. Reduction of Toxicity, Mobility, Volume of Contamination Through Treatment

CTFA-1 and CTFA-2 would not address toxicity, mobility, and volume of source areas through treatment, although natural degradation could potentially reduce contaminant toxicity and volume over time. Excavation under CTFA-3 through CTFA-5 would not provide reduction of toxicity and volume of the contaminated soils through treatment but would move the materials from the AOC to a facility where mobility would be reduced. CTFA-4 and CTFA-5 would provide a reduction in BTEX contaminated soil during the five years of active vapor treatment.

5. Short-Term Impacts and Effectiveness

CTFA-1 and CTFA-2 would not have short-term impacts because no intrusive action would be implemented. CTFA-3 through CTFA-5 would have some impacts to the community and workers during the construction period. CTFA-2 would not meet chemical-specific ARARs, but it would prevent residential use soil exposures. CTFA-3 would have a potentially greater impact to the community compared to CTFA-4 and CTFA-5 due to the larger amount of truck traffic for off-site disposal of contaminated materials and import of certified clean fill. However, CTFA-4 and CTFA-5 will impact the Stepan facility over a longer period of time due to long-term operation and maintenance of the systems.

6. Implementability

All five alternatives are implementable. Excavation under CTFA-3 through CTFA-5 would be implementable, but the potential for some soil to also have low-level radiological contamination would complicate off-site disposal requirements. (As noted above, soils are contaminated with Site-related chemicals and may be co-mingled with low-level radiological waste.) Excavation near utility lines might add some technical challenges for CTFA-3 through CTFA-5. CTFA-5 may face implementability issues related to soil permeability; if soil permeability in this area is low it could reduce vapor extraction potential and require additional extraction efforts, such as installation of more extraction wells, to achieve PRGs. Because excavation could pose structural concerns in implementing CTFA-3 through CTFA-5, long-term inspection and maintenance would be required for those alternatives to maintain the integrity of the cover in the immediate vicinity of Building 10.

7. Relative Cost

Alternative Total Present Value

CTFA-1 No Action 0 CTFA-2 ICs $116,000 CTFA-3 Excavation & off-site disposal $1,017,000 CTFA-4 In Situ Enhanced Fluid Recovery (EFR) and Excavation with off-site disposal

$1,548,000

CTFA-5 In Situ Soil Vapor Extraction (SVE) and Excavation with off-site disposal

$1,220,000

PREFERRED ALTERNATIVES EPA’s preferred remedy for chemical contamination in soil would include actions for each of the five AOCs as summarized below: AOC1. Buried Container Area The BCA-4 cleanup alternative consists of soil excavation and off-site disposal of soils, remaining buried containers and associated waste materials contaminated at concentrations greater than PRGs. The key components of BCA-4 include: pre-design investigation; remedial design; excavation with dewatering in wetlands; off-site soil and waste material disposal at a regulated facility; Site restoration including wetlands; and ICs to ensure that future use remains commercial/industrial. It is expected that approximately 2.2 acres would require excavation up to four feet below ground surface, with one location requiring excavation up to eight feet below the ground surface. The FS estimates that excavation of 14,600 cubic yards of contaminated soil, containers and waste materials would be required. AOC2. Gypsum Material Area The GA-4 cleanup alternative consists of soil excavation and off-site disposal of soils and remaining gypsum material that is contaminated at concentrations greater than the PRGs identified in Table 1. The key components of GA-4 include: pre-design investigation; remedial design; excavation with dewatering in wetlands; off-site disposal of soil and waste material at a regulated facility; Site restoration including wetlands; and ICs to ensure that future use remains commercial/industrial. It is estimated that approximately 6,250 cubic yards of gypsum material and soil would require excavation up to four feet below the surface. AOC3. Leather Material Area The LMA-4 cleanup alternative consists of excavation and off-site disposal of remaining contaminated leather material and soil with concentrations greater than PRGs. The key components of LMA-4 include: pre-design investigation;

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remedial design; excavation; off-site disposal of soil and waste material at a regulated facility; Site restoration; and ICs to ensure that future use remains commercial/industrial. LMA-4 also includes a contingency for ICs to prevent future disturbance of or exposure to chromium contamination, if identified during the pre-design investigation at locations where remediation of radiological contamination by the USACE under FUSRAP has been completed. It is expected that approximately 6,550 cubic yards of leather material and soil would require excavation up to two feet below the ground surface, with one location requiring extraction up to four feet below the surface. AOC4. Former Aromatics Area The FAA-5 cleanup alternative would include the installation of a SVE system to extract and treat contaminated soil vapor from the unsaturated zone (from zero to four feet below the surface) through shallow horizontal wells. It would also include excavation of about 900 cubic yards of contaminated soil around utilities and subsurface structures, with off-site disposal. The key components of FAA-5 include: pre-design investigation; pilot study; remedial design; installation of the SVE system; excavation of contaminated soil around utilities and subsurface structures using “air knife” or vacuum excavation, with off-site disposal. Horizontal SVE extraction wells would be located approximately four feet below the ground surface, so normal groundwater table fluctuations would not affect the well. The groundwater table in this area has historically ranged from five and a half feet to 10.4 feet below the surface in the FAA. The well locations would be determined during design based on pre-design investigation and pilot study information. Location and spacing would be dependent on Site soil conditions for optimum vapor removal. Underground piping would connect the extraction wells to a blower, and the surface would be sealed to prevent water infiltration, fugitive vapors or short-circuiting of air flow. Extracted vapors may require treatment prior to discharge to the air. It is assumed that such treatment would consist of a granulated activated carbon unit which may require an air permit. The SVE system would require monthly monitoring to gauge remedial progress. It is estimated that approximately 3,220 cubic yards of soil would require treatment or excavation and disposal.

AOC5. Central Tank Farm Area The CTFA-3 cleanup alternative consists of excavation and off-site disposal of contaminated soil in the unsaturated zone from zero to seven feet below the surface. Contaminated soil in the saturated zone will be addressed in the future groundwater ROD. The key components of CTFA-3 include: pre-design investigation; remedial design; conventional excavation of contaminated soil to the groundwater table which is approximately seven feet below the surface; “air knife” or vacuum excavation around utilities and subsurface structures; off-site soil disposal at a regulated facility; Site restoration; ICs to ensure that future use remains commercial/industrial and ICs to restrict intrusive activities below seven feet to prevent exposure to contaminated soil during seasonally low groundwater conditions. Excavation near Building 10 may be limited due to structural integrity concerns and any contaminated soil in the immediate vicinity of Building 10 would remain in place and also require ICs. It is estimated that approximately 800 cubic yards of contaminated soil would require excavation. RATIONALE FOR SELECTION OF PREFERRED ALTERNATIVE The preferred alternative is selected by evaluating remedial alternatives using the nine criteria specified in the NCP. NJDEP is completing the process of evaluating EPA’s preferred remedy as presented in this Proposed Plan. Community acceptance of the preferred remedial alternative will be determined after the public comment period ends and will be documented in the ROD. Based on information currently available, EPA believes the preferred alternative meets the threshold criteria and provides the best balance among the other balancing and modifying criteria of 40 C.F.R. Section 300.430. The preferred alternative also satisfies the statutory requirements of CERCLA Section 121(b). The preferred alternative is protective of human health and environment. Risk is reduced through removal or treatment of soil contamination at the five AOCs. The preferred alternative is technically feasible and implementable. It is EPA’s current judgment that the Preferred Alternative identified in this Proposed Plan is necessary to protect public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment. Consistent with EPA Region 2’s Clean and Green policy, EPA will evaluate the use of sustainable technologies and practices with respect to implementation of the selected remedy.

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Excavation and disposal of contaminated soil at the BCA, GA, LMA and CTFA are the most appropriate remedy for these AOCs based on the comparative analysis. While SVE with soil excavation around utilities is an appropriate remedy for the FAA because contamination is located in an open area and would be better suited to SVE operations to treat VOC contaminated soil. While the contaminants at the FAA, which are primarily VOCs, are similar to those identified at the CTFA, different remedies are proposed for these two areas due to significant differences in existing site conditions. Active operations are ongoing at the CTFA, which is part of the Stepan facility, which renders SVE operations very difficult to implement due to surface, subsurface and overhead utilities. The conditions at the FAA, as explained above, make this a suitable candidate for SVE. However, if FAA SVE pilot test results do not indicate that SVE would meet the remediation goals, based on specific performance standards developed to ensure adequate treatment, the excavation and disposal alternative FAA-3 would be implemented as a contingency remedy. The FAA-3 alternative has been comparatively evaluated in the FS and this Proposed Plan and is an appropriate remedial alternative. COMMUNITY PARTICIPATION EPA and NJDEP rely on public input to ensure that the concerns of the community are considered in selecting an effective remedy for each Superfund site. Therefore, EPA and NJDEP encourage the public to gain a comprehensive understanding of the Site and the Superfund activities that have been conducted there. The inclusive dates for the public comment period, the date, location and time of the public meeting, and the locations of the Administrative Record files are provided on the front page of this Proposed Plan. Written comments on the Proposed Plan should be addressed to the Remedial Project Manager or Community Involvement Coordinator. EPA Region 2 has designated a Regional Public Liaison as a point of contact for community concerns and questions about the federal Superfund program in New York, New Jersey, Puerto Rico, and the U.S. Virgin Islands. To support this effort, the Agency has established a 24-hour, toll-free number that the public can call to request information, express their concerns, or register complaints about the Site. Comments made at the public meeting, as well as written comments, will be documented in the Responsiveness Summary Section of the ROD, the document which formalizes the selection of the remedy.

For further information on the Maywood Chemical Company Superfund Site, please contact: Betsy Donovan Wanda Ayala Remedial Project Manager Community Involvement Coordinator (212) 637-4369 (212) 637-3676 donovan.betsy@epa.gov ayala.wanda@epa.gov Written comments on this Proposed Plan should be mailed to Ms. Donovan at the address below or sent via email: U.S. EPA 290 Broadway, 19th Floor New York, New York 10007-1866 The public liaison for EPA’s Region 2 Office is: George H. Zachos Regional Public Liaison Toll-free (888) 283-7626 (732) 321-6621 U.S. EPA Region 2 2890 Woodbridge Avenue, MS-211 Edison, New Jersey 08837-3679

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Table 1 - Preliminary Remediation Goals

Contaminants of Concern (COCs) Preliminary Remediation Goals (PRGs) (mg/kg)

Acetone 12

Benzene 0.005 (PQL)

Chloroform 0.2

Ethylbenzene 8

Methylene Chloride 0.007

Toluene 4

1,1,1-Trichloroethane 0.2

Trichloroethene 0.007

Total Xylenes 12

Benzo(a)anthracene 0.5

Benzo(b)fluoranthene 2

Benzo(a)pyrene 0.2 (PQL)

Dibenzo(a,h)anthracene 0.2

Indeno(1,2,3-cd)pyrene 2 Pentachlorophenol 0.3 (PQL)

Arsenic 19a

Barium 1,300

Chromium 242b

Cyanide 13

Lead 59

Lithium 194b

Mercury 0.1 (PQL) Notes: PRGs were selected for each soil COC based on the lower of EPA risk-based Industrial use RSL values (10-6 to 10-4 target cancer risk, or 0.1 target hazard quotient), NJDEP Non-Residential Direct Contact Soil Remediation Standards and NJDEP Default Impact-to-Groundwater Soil Screening Levels or site-specific, impact-to-groundwater values, which are calculated according to NJDEP guidance if NJDEP impact-to-groundwater levels have not been established. PQL indicates screening level set at practical quantitation limit. a. The impact-to-groundwater or health-based level defaults to background. b. Site-specific, impact-to-groundwater values used for chromium and lithium.

R2-0000536

R2-0000537

L.JQVIU L..o '-""'''"-

Freeholder Chairman August 23, 2013-fee:$89.78 (96)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY INVITES PUBUC COMMENT

ON THE PROPOSED REMEDY FOR THE

MAYWOOD CHEMICAL COMPANY

SUPERFUND SITE

3549330

The U.S. Environmental Protection Agency (EPA) and the New Jersey Department of Environmental Protection

(NJDEP) will hold a public meeting on September 9, 2013 at the Maywood Public Library, Trinka Hall (lower level)

459 Maywood Avenue, MaywoOd, NJ 07607 from 7:00 to 9 pm to discuss the preferred remedy for the Maywood

Chemical Company Superfund site and the basis for this preference. The preferred remedy, which is described in

the proposed plan, includes soil excavatton with off-site soil disposal and vapor extraction to treat soli and institutional controls to restrict land use.

Before selecting the final remedy, EPA will consider oral comments presented at the public meeting and written

comments received on or before September 23, 2013.

Copies of the Proposed Plan and Administrative Record for the site are available at the following locations:

Maywood Public library

459 Maywood Avenue

Maywood, New Jersey 07607

Written comments should be sent to:

Betsy Donovan

Remedial Project Manager

U.S. EPA, Region 2 290 Broadway, 19!;1> Floor

New York, NY 10007-1866

donovan betsy@epa goy

(2121637-4369/fax (2121637-4439

US EPA Records Center

290 Broadway, 181~ Floor

New York. New York 10007·1866

212-637-4308

By Appointment Only

·For further information, please contact Wanda Ayala, Community Involvement Coordinator at (212) 637-3676 or

toll free at 8Q0.346-S009 or visit our website atwww gpa.gov/regjon02/suoerfuod/no!lmaywood/

August 23, 2013-Fee:$113.40 (120) 3549264

SUPERIOR COURT OF NEW JERSEY COMBINED PLANNING/ZONING BOARD LAW DIVISION: BERGEN COUNTY BOROUGH OF LITTLE FERRY

Docket No.: BER-L-297-13 Civil Action PUBLIC NOTICE is hereby given to all per-

ORDER TO POSTPONE OR VACATE sons that, at a public hearing held on July DISMISSAL PURSUANT TO R.1:13-7 AND 17, 2013 the Zoning Board of Adjustment

FOR SUBSTITUTED SERVICE made the following decision: PURSUANT TOR. 4:4-4(b)(3)

This matter having been brought before the GRANTED the Zoning Application of Mr. & Court by the Law Offices of Jan Meyer & As- Mrs. Dermot Moran. Also known as 101 __ ..,___o_e,_ ___ "'-....-.. _,.,..,_~\..J.nUtt(a'\._'o.., __ t..A.,.h..-hni; Rn~d. A.qp_lL~~ number Q019-S-

Grants Appropriated: N/ A Section 20 Costs: Not to exceed $500,000 Useful Life: 40 years

Diane Thornley, Clerk This Notice is published pursuant to </

N.J.S.A. 40A:2-17. August 23, 2013-Fee: $49.14 (52) 3549014

~ BOROUGH OF SADDLE RIVER r

ORO. N0.13-879-M ~I

NOTICE OF PENDING BOND ORDINANCE l ; AND SUMMARY r

The bond ordinance, the summary terms of which are included herein, was Introduced L · and passed upon first reading at a meeting ) 1 of the Borough Council of the Borough of 1 Saddle River, in the County of Bergen, State > of New Jersey, on August 19, 2013. It will be > r further considered for final passage, after J ' public hearing thereon, at a meeting of the J Borough Council to be held in the Municipal ) Building, 100 E. Allendale Road, Saddle Riv-er, New Jersey, on September 16, 2013 at 7:15P.M. Dunng the week prior to and up to and including the date of such meeting cop-ies of the full ordinance will be available, at

rh~ ~l~r~·~do~r~~n?o~~~~~~eb~g~r~s~f 7~~rse~~ ' eral public who shall request the same. ~he ~ summary of the terms of such bond ordi- 1 · nance follows:

ORDINANCE NO. 13-879-M I BOND ORDINANCE TO AUTHORIZE THE

1

UNDERTAKING OF VARIOUS IMPROVE- l MENTS TO RINDLAUB PARK IN, BY AND FOR THE BOROUGH OF SADDLE RIVER, ! IN THE COUNTY OF BERGEN, STATE OF , NEW JERSEY, TO APPROPRIATE THE SUM OF- $250,000 TO PAY THE COST THEREOF, TO MAKE A DOWN PAYMENT, TO AUTHORIZE THE ISSUANCE OF BONDS TO FINANCE SUCH APPROPRIA­TION AND TO PROVIDE FOR THE ISSU­ANCE OF BOND ANTICIPATION NOTES IN ANTICIPATION OF THE ISSUANCE OF SUCH BONDS.

Purpose(s): Undertaking of various improve­ments to Rindlaub Park in, by and for the Borough consisting of (A) ingress and egress safety improvements and (B) construction of a parking lot.

Appropriation: $250,000 Bonds/Notes Authorized: $235,000 Grants (if any) Appropriated: $ -0-Section 20 Costs: $10,000 Useful Life: 10 years

This Notice is published pursuant to N.J.S.A. 40A:2-17.

Borough Clerk Borough of Saddle River

County of Bergen State of New Jersey

August 23, 2013-fee:$56.59 (62) 3548769

DOAO_UQ_H O,F_~~IRVIEW ___ ~

R2-0000538

September 9, 2013

VIA EMAIL (jmcgahren@morganlewis.com) AND FIRST CLASS MAIL

Mr. John McGahren Morgan, Lewis & Bockius LLP 502 Carnegie Center Princeton, NJ 08540

Re: Maywood Chemical Company Superfund Site August 2013 Proposed Plan

Dear Mr. McGahren:

The U.S. Environmental Protection Agency (EPA) received your September 4, 2013 letter, in which you request that the EPA extend the Maywood Chemical Company Superfund Site August 2013 Proposed Plan comment period for sixty days. EPA considered you request and in accordance with 40 CFR 300.430(f)(3)(C) will grant an additional 30 days to the original 30 day comment period which began on August 23, 2013. The revised comment period deadline will now be October 22, 2013.

Sincerely yours,

Betsy Donovalf/ Project Manager

cc: Michael Sivak, EPA Angela Carpenter, EPA William Tucker, EPA Wanda Ayala, EPA Mark Stanek, Stepan Company (via email only) Christina K. Loundy, Stepan Company (via email only)

R2-0000539

UNITED STATES ENVIRON ENTAL PROTECTION AGENCY REGION2

October 17 2013

Mr. John McGahren Morgan, Lewis & Bockius LLP 502 Carnegie ent r Prin eton J 08540

290 BROADWAY NEWYORK, NY 10007-1 868

Re: Ma ood Chemical Company uperfund ite ugu t 2013 Propo ed Plan

Dear Mr. McGahren:

The U .. Environmental Protection Agency (EPA) received your letter dated 0 tober 1 20 13 in which you request that the EPA extend the Maywood Chemical ompany uperfund ite August 2013 Propo ed Plan comment period for an additional thirty days. Plea e note that the letter wa received October 3rd by email during the federal government hut down l hich ended on October Jf/11.

EPA considered your r qu t and will grant an additional 30 days to the comm nt period which began on ugust 23 2013 and was previously extended by 30 days by EPA. The revi ed comm nt deadline is no o ember 21 , 2013.

incerely yours

B t y D novan Project Manager

cc: Michael Sivak, EPA Angela Carpenter, EPA William Tucker, EPA Wanda Ayala, EPA Mark Stanek, Stepan Company (via email only) Christina K. Loundy, Stepan Company (via email only)

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed with Vegetable 011 Based Inks on Recy~ Paper (Minimum SO"k Postconsumer content)

R2-0000540

UNITED STATES ENVIRON ENTAL PROTECTION AGENCY REGION 2

ovember 15 2013

Mr. John McGahren Morgan Lewis & Beckius LLP 502 Cam gie Center Princeton J 08540

290 BROADWAY NEW YORK, NY 10007-1866

Re: Ma ood Chemical Company uperfund ite ugu t 2013 Propo ed Plan

Dar Mr. McGahr n:

The . . Environm ntal Pr tection gency (EPA recei ed your o ember 12 20 13 letter in which you request that the EPA extend the Maywood hemical Company uperfund ite August 2013 Propo ed Plan comm nt period for an additional thirty days. The EPA con id r d your r qu t and as a court y i willing to allow an additional two-week extension, for reasons de cribed in more detail bela .

Your letter indicates that you are a aiting information from EP and U C nee s ary for tepan to adequately valuat EP s Propo d Plan. Howe er, as you are no doubt aware,

pursuant to 40 C.F.R Part 300, ubpart 1 EPA maintains an dministrative Record forth selection of the remedial action as set forth in the Propo ed Plan. n er 40 C.F.R. ec. 300.815, since the date of issuance of the Proposed Plan that dministrative Record has en a ailable for public inspection at ral r positories specified in tb Plan. You, alongwith the general public ha e had ample opportunity t inspect that record which forms th basis for PA s remedial deci ion. In fact, any judicial review of EPA s remedial decision would be limited to the Admini trative Record under CER LA ec. 1130 (1 , and EP s de i ion is ubj ct to chall nge only if the party objecting can how that decision was 'arbitrary and capricious ' based on the Administrative Record pursuant to ec. 1130 2). Giv n the ready availability of the

dministrative R cord during the entire comment peri d it i not neces ary for tepan to have ry pie of data in P A' and the rmy Corp ' pos e ion in order to comment on the

Propo d Plan. That aid, given tepan s role as the primary re ponsible party for this Site as a courtesy EPA is willing to entertain yet another additional extension of tim for comment.

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable •Printed with Vegetable 011 Based Inks on Recycled Paper {Minimum SO% Postconsumer content)

R2-0000541

With re pect to your information reque ts PA i a are of two separate OIA requ sts one submitted to th U. . Army orps of Engineers A E) by l tter dat d August 29 2013 and another submitted to the PA Region 2 s Freedom of Information Officer by 1 tter dat d ctober 2 2013 recei d by fax during the fi deral govemm nt shutdown. Both r que ts are forth arne

A E FU RAP excavation information at three propertie with five areas of cone m, that ar the ubject the ugu t 20 13 Pr posed Plan. The AC re ponded to your information requ on ctober 17111 and 30111 with all the information readily availabl for th U E FU RAP e ca ation work at th se locations. The P re ponded to your information r qu st on

ovember 15111 but please be a war that EP doe not have any information be ond what the bas already pro id d to you.

I rec ntJy learned that an additional email inquiry ent to U from John Garge for one pecific drawing in uto ADD format was made last we k. The U E oofirmed that this

drawing was transmitted by email on o ember 15th. EP therefor i willing to grant tepan an additional two week for comm nt on th Propo ed Plan. ot that EP has already granted sixty additional days allowing a total of ninety days for comment in resp ns to your two pr viou e tension r ues . An addjtional two we ks will be add d to the comment period and it will close on December 5 2013. An ext nsion of the comment period ofthi extent is unusual and i being made solely as a courtesy to tepan. Please be ad i ed that no further xten ions will be granted and plan a cording) .

the attorn y currently as ign d to this 637-3139.

incerely yours

Betsy Donovan Project Manager

cc: - Micha l 'ivak EP Angela arpenter EP William Tucker, EP Wanda yala, EPA Mark tan k tepan ompany (via emaB only) Chri tina K. Loundy, Stepan Company ia mail only)

2

R2-0000542

Press Advisory

Region 2 - New Jersey, New York, Puerto Rico and the U.S. Virgin Islands

EPA Extends Public Comment Period on Cleanup Plan for Maywood Chemical Company Superfund Site in Maywood and

Rochelle Park, New Jersey

Contact: Elias Rodriguez, (212) 637-3664, rodriguez.elias@epa.gov

(New York, N.Y. – September 18, 2013) On August 23, 2013, the U.S. Environmental

Protection Agency announced a proposed cleanup plan to address contaminated soil at the

Maywood Chemical Company Superfund site in Maywood and Rochelle Park, New Jersey.

Previous industrial activity at the site resulted in contamination of the soil and ground water

with volatile organic compounds, radioactive waste and metals. The EPA proposal calls for a

combination of removing and treating contaminated soil. The EPA held a public meeting on

September 9, 2013 to explain the proposed plan.

The agency is extending the public comment period, which was set to end on September 23

to a new deadline for public comments of October 22.

Written comments may be mailed or emailed to:

Betsy Donovan

Remedial Project Manager

290 Broadway, 19th Floor

New York, New York 10007-1866

(212) 637-4369

donovan.betsy@epa.gov

To review the plan for the Maywood Chemical Company Superfund site, please visit:

http://epa.gov/region02/superfund/npl/maywood.

R2-0000543

13-000

R2-0000544

News Advisory

Region 2 - New Jersey, New York, Puerto Rico and the U.S. Virgin Islands

EPA Extends Public Comment Period on Cleanup Plan for Maywood Chemical Company Superfund Site in Maywood and

Rochelle Park, New Jersey

Contact: Elias Rodriguez, (212) 637-3664, rodriguez.elias@epa.gov

(New York, N.Y. – Oct. 29, 2013) On August 23, 2013, the U.S. Environmental Protection

Agency announced a proposed cleanup plan to address contaminated soil at the Maywood

Chemical Company Superfund site in Maywood and Rochelle Park, New Jersey. Previous

industrial activity at the site resulted in contamination of the soil and ground water with

volatile organic compounds, radioactive waste and metals. The EPA proposal calls for a

combination of removing and treating contaminated soil. The EPA held a public meeting on

September 9, 2013 to explain the proposed plan.

The agency is extending the public comment period, which was set to end on October 22 to

a new deadline for public comments of November 21.

Written comments may be mailed or emailed to:

Betsy Donovan

Remedial Project Manager

290 Broadway, 19th Floor

New York, New York 10007-1866

(212) 637-4369

donovan.betsy@epa.gov

To review the plan for the Maywood Chemical Company Superfund site, please visit:

http://epa.gov/region02/superfund/npl/maywood.

R2-0000545

13-000

R2-0000546

1 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2 2 - - - - - - - - - - - - - - - - - - - - - - - - - -x 3 MAYWOOD CHEMICAL COMPANY SUPERFUND SITE 4 PUBLIC MEETING 5 - - - - - - - - - - - - - - - - - - - - - - - - - -x 6 7 Maywood Public Library 459 Maywood Avenue 8 Maywood, New Jersey 9 September 9, 2013 7:03 p.m. 10 11 12 P R E S E N T: 13 WANDA AYALA, 14 EPA Community Involvement Coordinator 15 BETSY DONOVAN, EPA Remedial Project Manager 16 DONNA GAFFIGAN, 17 NJDEP Case Manager 18 STEPHANIE SESSOMS-MIDGETT, EPA, Remedial Project Manager 19 MICHAEL SIVAK, 20 EPA Section Chief 21 22 23 24 25

R2-0000547

2 1 MS. AYALA: Good evening, 2 and thank you all for coming out 3 tonight. 4 My name is Wanda Ayala, and 5 I'm the Community Involvement 6 Coordinator for the Maywood 7 Chemical Superfund Site. I'm here 8 tonight with a group with EPA to 9 talk to you about our Proposed 10 Remedial Action Plan for soil 11 contamination at the Maywood 12 Chemical Company Superfund Site. 13 Just a couple of ground 14 rules. If you didn't sign in on 15 the way in, you can sign in on the 16 way out. 17 We have a stenographer here 18 because we're required by law to 19 have an official transcript of 20 this meeting. So, our 21 stenographer, Linda, is 22 accompanying us here tonight. 23 Also, if you have cell 24 phones, if you could put them on 25 vibrate to be less disruptive.

R2-0000548

3 1 Also, I ask that you keep 2 your questions until the end since 3 Linda has to transcribe 4 everything. That way, it's easier 5 for her to just do the 6 presentation as we present it. 7 The EPA team, Betsy Donovan, 8 who's the Project Manager; 9 Stephanie Sessoms-Midgett, she's 10 also a Project Manager; and 11 Michael Sivak, who's Section Chief 12 in our Megaprojects section, also 13 a Risk Assessor. 14 We have Donna Gaffigan from 15 New Jersey DEP in the audience 16 here tonight. 17 Like I said, we're meeting 18 here tonight to discuss the 19 Proposed Plan and to accept public 20 comments. The public comment 21 period was extended until October 22 22. Originally, it was to end on 23 September 23, but we got a request 24 for an extension and it was 25 granted.

R2-0000549

4 1 And EPA will address all 2 comments in the Record of Decision 3 Responsiveness Summary. And you 4 guys got a copy of the agenda 5 also. 6 I'm just going to turn it 7 over to Betsy. 8 MS. DONOVAN: Actually, 9 Michael is going to start us off. 10 (Pause in proceedings) 11 MS. AYALA: I'm sorry, Mayor 12 Padovano. 13 I want to acknowledge we 14 have the Mayor of Maywood here in 15 the audience. 16 MR. SIVAK: While we're 17 rebooting, I'm going to start the 18 process to keep us moving along 19 here. If I go too quickly -- 20 because I have a habit of speaking 21 quickly -- please let me know, and 22 I will slow down. 23 Our meeting agenda tonight, 24 I think you all have it. It's in 25 the presentation.

R2-0000550

5 1 I'm going to start out with 2 giving an overview of the whole 3 Superfund process; and then Betsy 4 is going to take you through sort 5 of our Site Investigation history, 6 the sampling we've been conducting 7 here over the last several years; 8 it's going to come back to me to 9 present the conclusions of our 10 human health and ecological risk 11 assessments; and then Betsy will 12 take us through all the remedial 13 alternatives that we've 14 considered, what our preferred 15 remedy for the site is, we're 16 going to talk about that preferred 17 remedy identified in the Proposed 18 Plan; and then, as Wanda said, 19 we're going to open it up for 20 public comments. 21 So, we're here tonight 22 because the Maywood Chemical 23 Company site is a Superfund site. 24 Superfund is a federal 25 regulation that was passed in 1980

R2-0000551

6 1 in response to some environmental 2 disasters for which there was no 3 federal mechanism to identify a 4 response. 5 Love Canal and the Valley of 6 the Drums were two of the main 7 sites, two of the big sites, that 8 came about in the late seventies, 9 early eighties for which the 10 federal government had no way to 11 respond to those disasters. 12 So, that prompted the 13 passage of the Comprehensive 14 Environmental Response 15 Compensation and Liability Act. 16 We call that CERCLA, which is 17 written up here. It's also known 18 as Superfund. 19 This law created a tax at 20 the time that was levied on 21 industries, on chemical -- 22 hazardous waste chemical 23 industries, and that was called 24 the Superfund. So, the law is 25 either known as CERCLA or

R2-0000552

7 1 Superfund. We typically call it 2 Superfund. 3 The law allows for the 4 federal government to have several 5 options available to it if a site 6 is identified as a Superfund site: 7 It provides federal funds for 8 cleanup of hazardous waste sites; 9 it allows EPA to respond to 10 emergencies; and it empowers EPA 11 to compel responsible parties that 12 have been identified to pay for or 13 conduct the necessary response 14 actions to address immediate 15 threats to public health as well 16 as long-term threats to public 17 health and the environment. 18 Now, the Superfund remedial 19 process, which is the process 20 we're engaged in right now, is a 21 pretty lengthy process. There are 22 many steps. We've identified some 23 of the more significant steps here 24 on the slide. 25 It begins with site

R2-0000553

8 1 discovery. Betsy is going to talk 2 about the site discovery of this 3 particular site. 4 Once a site is brought to 5 EPA's attention or to the State's 6 attention, we enter into what's 7 called a Preliminary Assessment/ 8 Site Inspection, and we call that 9 a PASI. 10 That's where we collect some 11 initial data to run the site 12 through what we call the Hazard 13 Ranking System, which is a 14 numerical equation that helps to 15 take all the data we know about a 16 site and develop a number. 17 If that number is high 18 enough based on what Congress has 19 determined, then the site is 20 placed on the National Priorities 21 List, or the NPL, and it becomes a 22 Superfund site. We're placing it 23 on the Superfund list. 24 Once it's on the Superfund 25 list, we begin our Remedial

R2-0000554

9 1 Investigation/Feasibility Study. 2 Now, the purpose of the 3 Remedial Investigation is to 4 define the nature and the extent 5 of contamination at the site, 6 meaning we're looking for what 7 chemicals have been released from 8 the site and where are those 9 chemicals. 10 So, we look at things like 11 soil and groundwater, air, surface 12 water, sediments, things like 13 that. We look to see where has 14 that release come to be. That's 15 the Remedial Investigation. 16 As part of the Remedial 17 Investigation, we conduct both a 18 human health and an ecological 19 risk assessment. And the goals of 20 both those two studies is to 21 identify what are the human health 22 risks now and in the future if no 23 action is taken, and what are the 24 ecological risks as well. 25 And we'll talk more about

R2-0000555

10 1 those. I'll actually come back in 2 a little bit and talk more about 3 what the conclusions of those 4 studies were. 5 The Feasibility Study is an 6 evaluation of all the technologies 7 that exist and which ones are most 8 appropriate for consideration at 9 this particular site. 10 So, once we identify what 11 the contamination is and where is 12 that contamination, we can then 13 start to look at what technologies 14 are available for us to consider 15 using to address that 16 contamination and clean it up. 17 That's what the purpose of 18 the Feasibility Study is. It 19 looks at all the different 20 technologies and evaluates them 21 against each other so that EPA can 22 make the decision on what is the 23 most appropriate technology that 24 can work at the particular site. 25 That results in the

R2-0000556

11 1 identification of a Proposed 2 Remedy, which we're here tonight 3 to discuss. We identify our 4 Proposed Remedy in what we call a 5 Proposed Remedial Action Plan that 6 was sent out, that was released to 7 the public. We're here tonight to 8 talk about that. 9 We have a 30-day public 10 comment period, which, as Wanda 11 indicated, has been extended to a 12 60-day public comment period, at 13 which time, once that comment 14 period closes, we will look at all 15 the comments that we receive, we 16 will evaluate all the data that 17 exists for the site, we will 18 select a final cleanup plan for 19 this operable unit of the site -- 20 for the soils at the Stepan 21 properties, and we will 22 memorialize that decision in a 23 Record of Decision. 24 We will memorialize what we 25 believe is the best remedy for the

R2-0000557

12 1 site in a Record of Decision. 2 That document will also contain a 3 Responsiveness Summary, which is a 4 list of all the comments that we 5 receive as well as EPA's responses 6 to all of the comments and the 7 questions. 8 Once we select the Record of 9 Decision, we will then initiate 10 negotiations with the responsible 11 party to begin work on the 12 Remedial Design and the Remedial 13 Action. 14 We will design the remedy. 15 That includes things like figuring 16 out if we're going to excavate 17 soils, what's the most appropriate 18 way to excavate the soils that is 19 safe for the community, that 20 results in minimal disruption to 21 the community. 22 That will also include 23 things like predesign 24 investigation, redefining where 25 are the extent of materials that

R2-0000558

13 1 need to be excavated from a 2 property. 3 So, those are some of the 4 activities that we would include 5 in the remedial design, and then 6 we would implement the action. 7 Finally, once we've 8 implemented the action, all of our 9 goals for that action have been 10 met, we can move the site forward 11 towards deletion. That's going to 12 be many, many years in the future. 13 But that's kind of a summary 14 of where we are now. So, now I'm 15 going to turn it back over to 16 Betsy to give you a little bit of 17 a history of the operations at the 18 site. 19 MS. DONOVAN: Thanks, 20 Michael. 21 I'm Betsy Donovan, Project 22 Manager. I've been at EPA for 23 about twenty years, and I'm going 24 to give you a little background, 25 brief overview, on the Maywood

R2-0000559

14 1 Chemical Company site and some of 2 the history. 3 First of all, we'll show you 4 where we are. I think everybody 5 probably knows, but we're up here 6 at the library and the site is 7 down here at this location. So, 8 it's about a half mile to the 9 south and southeast of right where 10 we are now. 11 So, Maywood Chemical was 12 founded in 1895 and began 13 manufacturing a wide variety of 14 chemical additives and products. 15 And then from 1916 to 1959, 16 thorium ore processing at the site 17 generated residual radioactive 18 waste. 19 Other chemical manufacturing 20 operations generated various waste 21 products, including lithium 22 compounds, leather, tea, and cocoa 23 leaf processing waste. 24 Waste from operations was 25 used as fill on Maywood Chemical

R2-0000560

15 1 Company property, adjacent 2 properties, and even during the 3 construction of Route 17 in the 4 1932 time frame. 5 In 1959, Stepan Company 6 purchased the Maywood Chemical 7 Company and discontinued many of 8 their operations. 9 Then in October of 1980, the 10 State of New Jersey investigated a 11 complaint from a citizen about 12 radioactive contamination near 13 Route 17 in Maywood and Rochelle 14 Park, New Jersey. 15 This complaint triggered a 16 number of radiological surveys and 17 sampling by EPA, Department of 18 Energy, and New Jersey, and they 19 were conducted from 1980 to 1983. 20 And then in 1983, Maywood 21 Chemical Company was listed on 22 EPA's National Priorities List. 23 That's our Superfund list. 24 I'm going to try to 25 explain -- this site is a unique

R2-0000561

16 1 and complex project. We have two 2 separate entities doing cleanup 3 here and it's under one big 4 Superfund site umbrella. 5 So, today we have the United 6 States Army Corps of Engineers. 7 We have Jim Moore tonight with us, 8 he's project manager. 9 Army Corps is managing the 10 radiological contamination 11 associated with the Maywood 12 Chemical Company and all 13 contamination at the site -- 14 that's the chemical and 15 radiological -- at the 11-acre 16 government-owned property. 17 And that work is being done 18 under the Formerly Utilized Sites 19 Remedial Action Program. We tend 20 to call it FUSRAP, and I'm going 21 to use that acronym a bit today. 22 So, you'll hear it again. 23 Radioactive soil cleanup 24 work began in 1984 and is ongoing 25 today. You've probably seen a lot

R2-0000562

17 1 of construction activity, and the 2 Army Corps has been in the 3 community doing cleanup work for 4 some time. 5 Then we have the Stepan 6 Company responsible for the 7 chemical contamination. As 8 Michael mentioned, we have a 9 potentially responsible party. 10 We've noticed Stepan Company that 11 they would be responsible for 12 performing the Remedial 13 Investigation and Feasibility 14 Study for the chemical 15 contamination. 16 At EPA, we refer to this 17 site as a hybrid federal facility 18 PRP site. It is unique. I don't 19 think there's another site in the 20 nation quite like it, where we 21 have a federal facility and a PRP 22 cleanup going on simultaneously 23 under one site name, one site 24 umbrella. 25 Tonight's presentation is

R2-0000563

18 1 about the EPA's plan to address 2 the nonFUSRAP, the chemical 3 contamination component, of the 4 site. So, we're going to kind of 5 forget about the Army Corps for a 6 little while and talk about all 7 this chemical contamination that 8 we're going to go after. 9 So, Remedial Investigation 10 testing was conducted. We're 11 looking for the source of the 12 contamination, the contaminants of 13 potential concern, pathways of 14 contaminant migration, 15 concentration of contaminants and 16 exposure points. 17 There's been a number of 18 sampling events and testing at the 19 site. We have soil and waste 20 material sampling, geophysical -- 21 that's like magnetic testing over 22 the ground surface to see if 23 there's any metal. Typically, we 24 were looking for drums, I believe, 25 in the early days to find out

R2-0000564

19 1 where they would be located. 2 Soil gas investigations, 3 test pits, focused investigations 4 for special waste types that were 5 identified, additional 6 investigations for groundwater and 7 soil source area or material 8 impact to that groundwater were 9 conducted. 10 Now, this just gives you an 11 idea -- I'm sorry the quality is 12 not so great, but every little 13 spot on that map shows, 14 identifies, a location of a soil 15 boring. 16 A soil boring is just a tube 17 that gets drilled into the ground 18 and then you can pull it up and 19 take a sample from a discrete 20 location, analyze it for 21 contamination at depth. 22 And test pits. Test pits, I 23 think the previous slide said 24 there's 129 test pits. Those are 25 big. They're several feet.

R2-0000565

20 1 Probably a backhoe would dig a big 2 hole, and then you could actually 3 see what's underground instead of 4 using the bore hole, which is just 5 kind of a very discrete pinhole 6 look at what's underneath the 7 ground. 8 So, after all these 9 investigations were started, five 10 areas of contamination were 11 identified, and we have named them 12 based on contaminant source or 13 location. They're located on 14 three properties. We're going to 15 refer to them as Sears, Maywood 16 Furniture, and Stepan properties. 17 That map has the better 18 colors, the paper map. Somehow, I 19 don't know, the colors got washed 20 out. So, I'm going to talk to 21 this map while I describe. I'll 22 give you a little more detail on 23 each area of concern. 24 The green represents the 25 buried container area. That's on

R2-0000566

21 1 the Sears property. That green 2 area represents about 14 total 3 acres, and it was a former drum 4 disposal location. The area was 5 open and undeveloped until the 6 1970s when it became developed. 7 The Feasibility Study 8 estimated that about two acres are 9 contaminated with volatile organic 10 compounds and semi-volatile 11 compounds and metals. 12 The Army Corps FUSRAP 13 cleanup has or will excavate 14 radiologically-contaminated soil 15 in more than seventy percent of 16 this green area. 17 Much of that waste is 18 comingled with the chemical, the 19 chemical and the radioactive 20 wastes are comingled, so that's 21 where we have to coordinate our 22 efforts and maybe do follow-up 23 additional excavation areas where 24 the chemical contamination 25 remains.

R2-0000567

22 1 The pink -- I call that 2 pink, it's probably like a salmon 3 color, but this over here 4 represents the gypsum area. It's 5 about one and a half acres on the 6 Maywood Furniture property. 7 Gypsum sulfate and metals, 8 including cyanide, were found in a 9 blue-colored waste material on 10 this property. The waste was from 11 caffeine extraction. 12 And over here, this blue 13 color identifies the leather 14 material areas on the Stepan 15 property. It's about three acres 16 total where leather processing 17 wastes from protein extraction 18 were found. 19 The waste in these areas -- 20 actually, if you look at the waste 21 in this area under the ground, it 22 looks kind of purple in color. 23 And over here in the gypsum 24 area -- it's like color-coded 25 waste, but it's blue in color

R2-0000568

23 1 because of the cyanide, I believe. 2 Then we have the former 3 aromatics area that's represented 4 by this brown, this smaller area. 5 It's on the Stepan property. It's 6 less than half an acre in size. 7 Essential oils and aromatic 8 chemicals were once produced in 9 buildings there that have since 10 been torn down, and there were 11 tanks as well that have been 12 removed. 13 VOCs were found in the soil. 14 Those are volatile organic 15 compounds. The former storage 16 tanks are possible sources of that 17 contamination. 18 We have this small purple 19 area. This is kind of an open 20 area. There's not a lot of 21 buildings now in this area since 22 they've been torn down. 23 But this area, called the 24 central tank farm area, it's 25 rather small. It's in the center

R2-0000569

24 1 of the Stepan property. It's 2 directly adjacent to an active 3 manufacturing building with 4 overhead and underground 5 utilities. 6 This area of concern is 7 about two-tenths of an acre, and 8 VOCs, again, were found here, and 9 tanks, again, are considered a 10 possible source of this 11 contamination. 12 I'm going to hand off the 13 risk assessment to Michael. 14 MR. SIVAK: Thank you. 15 As I said earlier, the 16 Remedial Investigation process 17 includes an evaluation of both the 18 potential human health risk as 19 well as the ecological risk. I'm 20 going to walk you through the 21 process that we followed for both 22 of those investigations. 23 The Human Health Risk 24 Assessment -- which is kind of my 25 background, so I can talk a little

R2-0000570

25 1 bit more thoroughly about that -- 2 has four main steps to it. 3 The first part is we want to 4 figure out what chemicals are we 5 most concerned about at the site. 6 For a site like this that's been 7 industrial for such a long time, 8 and there have been so many 9 different types of activities 10 going on on all these various 11 properties, we identified a lot of 12 chemicals during our remedial 13 investigation. 14 But sometimes we're not as 15 concerned about all those 16 chemicals, we're only concerned 17 about a subset of those chemicals. 18 So, we really want to focus our 19 efforts on those chemicals that 20 are the most toxic, the most 21 commonly found, and that we're 22 most concerned about. 23 So, that's the purpose of 24 the Hazard Identification, to 25 really kind of help focus our

R2-0000571

26 1 assessment of potential risks on 2 those chemicals that are likely to 3 be the biggest risks to public 4 health and the environment. 5 The exposure assessment 6 looks at how people might be 7 exposed at the site. We look at 8 current land use, then we look at 9 potential future land use at the 10 site. 11 Current land use is easy. 12 We go out there and look at what's 13 happening on the site right now. 14 Is it residential? Is it 15 commercial? Who's out there being 16 exposed? Are there children? Are 17 there adults? Are people being 18 exposed under occupational 19 scenarios? Are they being exposed 20 under recreational scenarios? 21 That's really easy. 22 The future use is a little 23 bit more complicated because we 24 don't know what is going to happen 25 in the future. So, we look at

R2-0000572

27 1 things like historical land use, 2 we look at things like surrounding 3 land use, existing institutional 4 controls like deed restrictions, 5 town master plans, current zoning, 6 things like that. So, we take all 7 that into account in the exposure 8 assessment. 9 The toxicity assessment 10 evaluates how toxic is the 11 chemical, what are the health 12 effects we expect to see, at what 13 levels would we see those health 14 effect. 15 Then we kind of wrap it all 16 up in the risk characterization, 17 and that's when we'll talk about 18 what the risk might be under 19 current and potential future use. 20 The ecological risk 21 assessment kind of follows the 22 same process. The words are a 23 little bit different, the steps 24 are slightly different, but it 25 basically does the same thing; it

R2-0000573

28 1 focuses our investigation on those 2 chemicals of most concern, what 3 types of ecological receptors 4 might we see out there, what type 5 of habitat exists for those 6 receptors, what kind of chemicals 7 and what kind of toxic effects 8 would we see from those chemicals 9 in the ecological community, and 10 then we kind of wrap it all up in 11 an overall conclusion. 12 With the Human Health Risk 13 Assessment, our goal is to protect 14 the reasonable maximum-exposed 15 individual. And that's exactly 16 what it is. What it is is exactly 17 what it sounds like. We look at 18 the maximum exposure reasonably 19 expected to occur at a site. 20 So, we look at things like 21 if it's an occupational exposure, 22 if people are exposed while 23 they're at a commercial or 24 industrial facility, how might 25 they be exposed under a reasonable

R2-0000574

29 1 maximum exposure scenario? 2 So, we assume that people 3 are exposed, for example, up to 50 4 weeks a year while they're at 5 work. 6 And then we also look at 7 exposures evaluated in the absence 8 of institutional controls, such as 9 land use ordinances, environmental 10 easements, things like that. 11 So, I mentioned earlier that 12 when we're looking at future land 13 use, we do look at things like 14 zoning and surrounding land use 15 and things like that. But we have 16 to evaluate that to say that if 17 the zoning is part of kind of the 18 town or the county or even a state 19 sort of designation, there are 20 ways that we can factor that into 21 our evaluation. 22 If it is simply -- if a land 23 use is simply based on what's 24 operating there now, we don't take 25 that into account as far as what

R2-0000575

30 1 could be there in the future. 2 Now, for current use, we 3 looked at commercial and 4 industrial properties -- I'm 5 sorry, commercial and industrial 6 receptors for all of the 7 properties. So, we looked at 8 adult workers, mainly, in all of 9 the different areas that were 10 under investigation in the 11 remedial investigation. 12 Again, when we get to 13 potential future use, it becomes a 14 little bit more complicated. 15 In the original risk 16 assessment that was performed for 17 EPA, it was determined that there 18 was a potential for the Sears 19 property and some of the adjacent 20 properties to have a potential 21 future residential land use. 22 That would be these 23 properties along here. There 24 would be a potential for 25 residential land use in those

R2-0000576

31 1 areas. So, the risk assessment 2 considered that. 3 Back in the day when the 4 original risk assessment was 5 performed, the Stepan property was 6 considered to be future 7 commercial/industrial use, just 8 the way it is currently. 9 So, we really didn't expect 10 a land use change for the Stepan 11 property. But for the other 12 properties that were under 13 investigation, there was potential 14 for future residential use. 15 Then we also looked at 16 excavation, construction, and 17 utility workers under a potential 18 future use as well. 19 As far as the toxicity 20 evaluation, we did obtain our 21 toxicity information for all these 22 chemicals from a variety of EPA- 23 approved toxicity databases. 24 The primary database that we 25 reference is a database that EPA

R2-0000577

32 1 itself develops. It's called the 2 IRIS database. It is a globally- 3 accessed database that is kind of 4 a gold standard around the world 5 for this type of information. 6 If we had chemicals that we 7 were concerned about that were not 8 found in this database, we went to 9 other EPA-approved sources to get 10 that specific information on what 11 the health effects of these 12 chemicals were. 13 We look at two different 14 types of health effects when we 15 are considering the toxicity. 16 Certain chemicals are known 17 to be associated or thought to be 18 associated with carcinogenicity. 19 For those chemicals, we do look at 20 that health end point. 21 And if chemicals have not 22 been identified as having a 23 carcinogenic end point, there are 24 other health effects that we 25 consider. We call those

R2-0000578

33 1 noncarcinogenic effects, and those 2 include all other type of health 3 effects. 4 They include things like 5 nervous system effects, 6 reproductive effects, 7 gastrointestinal effects, things 8 like that. The only thing that 9 does not result in carcinogenicity 10 is characterized under this 11 umbrella of noncarcinogenic 12 effect. 13 The conclusions of the Human 14 Health Risk Assessment indicated 15 that we did have unacceptable 16 human health risks for potential 17 future uses from exposure to 18 soils. So, that was kind of the 19 overall conclusion of the Human 20 Health Risk Assessment. 21 From that, we went back and 22 we looked at each area. Betsy 23 identified five areas, and they're 24 talked about in the Proposed Plan. 25 And we went back and looked at all

R2-0000579

34 1 the chemicals that were identified 2 through all of those samples that 3 Betsy pointed out in the earlier 4 slide. And from that, we 5 identified which chemicals are we 6 most concerned about. 7 So, again, Betsy talked 8 about volatile organic chemicals. 9 That's this group up here. 10 Volatile organic chemicals are 11 those chemicals that even though 12 they're present as a liquid, they 13 kind of like to be found in the 14 air. 15 A really good example of 16 that is nail polish remover. If 17 you've ever opened a bottle of 18 nail polish remover, you notice 19 how that volatilizes very quickly. 20 Or perhaps a better example 21 is if you're fueling up your car, 22 or in New Jersey somebody else is 23 fueling up your car, and you look 24 at kind of those vapors that are 25 coming off your gas tank, those

R2-0000580

35 1 are volatile organic chemicals. 2 They're present as a liquid but 3 they really prefer to be present 4 in the air. 5 We identified VOCs at the 6 buried container area. We also 7 identified a group of chemicals, a 8 couple of chemicals, that are 9 called semi-volatile organic 10 chemicals. 11 These chemicals are 12 chemicals that there's a volatile 13 component to them but they 14 actually prefer to stay in a solid 15 form and they also like to bind 16 very nicely, especially these ones 17 found here, they tend to bond very 18 nicely to soil. So, they don't 19 migrate a whole lot down into the 20 water columns. 21 And then we did find some 22 metals as well in the buried 23 container area. 24 In the gypsum area Betsy 25 mentioned earlier, we identified

R2-0000581

36 1 some semi-volatiles. We also 2 identified metals. 3 We found similar types of 4 chemicals in the leather materials 5 area. 6 And then, as Betsy 7 mentioned, the former aromatics 8 area and the central tank farm 9 area, our chemicals of potential 10 concern are limited to these 11 volatile organic chemicals. 12 In the Ecological Risk 13 Assessment, the conclusions 14 basically read exactly what we 15 have up here. It's a very 16 industrial property. There's not 17 a lot of ecological habitat 18 present in this area. We don't 19 have a lot of ecological 20 receptors. 21 There's a little bit of 22 surface water at the site. It's 23 intermittent. The habitat 24 associated with that is relatively 25 small.

R2-0000582

37 1 The Ecological Risk 2 Assessment did conclude that even 3 in these limited areas, there may 4 be a limited risk to aquatic 5 receptors. 6 So, now we're finishing up 7 the Remedial Investigation. We've 8 concluded what are our chemicals 9 of concern, what are our media of 10 concern. We know we need to 11 address soils, so we're going to 12 start to look at what technologies 13 are available. 14 Before we do that, we have 15 to figure out what is our goal? 16 What are the objectives of any 17 action at the site? 18 So, we identify what we call 19 Remedial Action Objectives. You 20 may see them referred to in the 21 Proposed Plan as RAOs. What we 22 identified as the goals of any 23 action that we take at this site 24 would be to prevent ingestion or 25 direct contact with some of this

R2-0000583

38 1 contaminated soil we've 2 identified; prevent inhalation of 3 or exposure to contaminants 4 volatilizing from these soils -- 5 we talked about these chemicals 6 that we found that like to be in 7 the air and volatilize up -- we 8 want to prevent offsite migration 9 of contaminated soil, and we want 10 to prevent impacts to groundwater 11 resulting from the contaminated 12 soil. 13 Not only do these volatile 14 chemicals like to go in the air, 15 they also tend to migrate down 16 again into the groundwater as 17 well, and we want to stop that 18 from happening. And metals as 19 well can migrate down into the 20 groundwater. 21 Now that we know what the 22 goals of our action will be, we 23 want to figure out what levels do 24 we need to achieve in order to 25 complete those goals, in order to

R2-0000584

39 1 achieve those goals. So, we call 2 those preliminary remediation 3 goals. 4 The way we identified these 5 was we looked at New Jersey 6 Department of Environmental 7 Protection Promulgated 8 Nonresidential Soil Standards, 9 which means these are laws that we 10 need to follow. We looked at EPA 11 commercial/industrial risk-based 12 screening levels. 13 At this point, we have a 14 much higher level of confidence 15 that all of these properties that 16 we're investigating will remain 17 commercial in the future, so we've 18 looked at these as a possible 19 preliminary remediation goal. 20 And we also looked at impact 21 to groundwater screening levels as 22 well because, again, we want to 23 make sure that as we clean up the 24 site, we're not leaving anything 25 behind that can continue to impact

R2-0000585

40 1 groundwater. 2 So, those are the criteria 3 that we're going to try to achieve 4 in order to successfully meet our 5 cleanup objectives. 6 And we're going to turn this 7 back over to Betsy to walk through 8 some of the technologies that we 9 evaluated in the Feasibility 10 Study. 11 MS. DONOVAN: So, after 12 we've identified all the 13 contamination and assessed the 14 risk, we go into Feasibility Study 15 mode. It's the basis of our 16 Proposed Plan that we're 17 presenting tonight. 18 The Feasibility Study was 19 conducted to identify remedial 20 alternatives based on site- 21 specific conditions and sampling 22 results to eliminate, reduce, or 23 control unacceptable risk to human 24 health and the environment. 25 Many remedial technologies

R2-0000586

41 1 are screened for inclusion in the 2 final list of potential remedial 3 alternatives for each area of 4 concern. 5 Alternatives were initially 6 screened against effectiveness, 7 feasibility, and cost. Site- 8 specific characteristics were used 9 to develop alternatives that were 10 appropriate for further detailed 11 evaluation. 12 I'm going to get right into 13 the alternatives, and I'll go area 14 by area. First, we'll start with 15 the buried container area. 16 The buried container area 17 was a former drum disposal 18 location. Again, the green area 19 here on this map. The feasibility 20 study estimated about 14,000 cubic 21 yards of contaminated soil with 22 VOCs, SVOCs, and metals. It's 23 found mostly within the first four 24 feet below the ground and 25 coincides with the depth of fill

R2-0000587

42 1 material. 2 Additional predesign 3 investigation work is included in 4 all the alternatives for all the 5 areas except the no action, of 6 course. These predesign 7 investigations will give us a much 8 better estimate of the volume of 9 contamination that will require 10 remediation. 11 So, I'll run through the 12 alternatives here for the buried 13 containers. 14 Alternative 1 -- you're 15 going to see this in every other 16 area -- no action. We have to use 17 this as a basis of comparison. 18 It's part of the Superfund 19 process. 20 Alternative 2 looked at 21 institutional controls. They're 22 administrative and legal controls 23 that help minimize the potential 24 for human exposure to 25 contamination.

R2-0000588

43 1 Alternative 3 looked at in- 2 situ solidification as well as a 3 little excavation. If we 4 encounter a buried container, we'd 5 like to move that material off the 6 site because it wouldn't solidify 7 very nicely. 8 The solidification 9 technology, it binds the 10 contamination in place by mixing 11 clay, cement, or other additive 12 into the soil in place to prevent 13 contamination from spreading. 14 Because the contaminant remains in 15 place, it would require land 16 restrictions and monitoring 17 indefinitely. 18 Alternative 4 looked at the 19 excavation and disposal of all the 20 contamination with land use 21 restrictions, if necessary, for 22 any residual contamination that 23 would prevent unrestricted uses. 24 Next, we'll look at the 25 gypsum area alternatives. The

R2-0000589

44 1 gypsum area, again, to give you 2 references here, on this property 3 it's in the kind of pink color. 4 The study estimated about 6,250 5 cubic yards of nonFUSRAP material 6 that would require remediation for 7 semi-volatiles and metals from the 8 surface to about four feet below 9 ground. Again, we do predesign 10 investigations to nail down that 11 volume. 12 The rest of these remedial 13 alternatives are virtually the 14 same. We have looked at in-situ 15 solidification and excavation with 16 offsite disposal. 17 Next up we have the leather 18 material areas. The leather 19 material areas, I'll refer to them 20 again here on the poster. That's 21 these blue areas on the Stepan 22 property. It's estimated about 23 6,550 cubic yards of soil is 24 contaminated with SVOCs and metals 25 and would require remedial action.

R2-0000590

45 1 Then, again, all the 2 alternatives we looked at for this 3 particular area are the same as 4 the previous two areas. We looked 5 at -- with the exception, sorry, 6 that we looked at capping as 7 Alternative 3. 8 Capping would essentially 9 cover the contamination with 10 asphalt or a similar material and 11 would also require indefinite land 12 restrictions and monitoring to 13 prevent the contaminant exposures 14 from spreading. 15 And then we have the former 16 aromatics area. That's the brown 17 area here on the Stepan property. 18 This is in more of an open 19 location on the property. It's 20 less than half an acre in size. 21 The study estimated 3,220 22 cubic yards of VOC-contaminated 23 soil will require remedial action, 24 which will be further defined in 25 the predesign investigation phase.

R2-0000591

46 1 As we mentioned, this 2 contamination is rather volatile 3 in nature. It likes to go into 4 the vapor phase. So, for this 5 area and the next area, we looked 6 at two additional treatment 7 alternatives that are suitable for 8 this type of chemical contaminant 9 that likes to go into the air. 10 So, we looked at the same 11 old no action, institutional 12 controls, and excavation, but then 13 we add these other two 14 technologies. 15 So, Alternative 4 is in-situ 16 enhanced fluid recovery, or EFR. 17 This is a technology that's been 18 used at gas station cleanups. In 19 this alternative, we use a high 20 vacuum extraction on wells to pull 21 volatile contamination from the 22 soil. Vapors removed from the 23 soil would require treatment. EFR 24 would operate for an extended 25 period of time, until soil

R2-0000592

47 1 concentrations met their cleanup 2 goals. 3 And then for Alternative 5, 4 soil vapor extraction was another 5 technology we looked at. It's 6 rather similar to EFR, but this 7 alternative would use subsurface 8 horizontal porous piping rather 9 than vertical wells. It's 10 feasible here because the soil 11 contamination is located close to 12 the surface. 13 It would require the same 14 vapor treatment and operate over a 15 similar timeframe as EFR. 16 And those alternatives -- we 17 mentioned this in the Proposed 18 Plan -- both Alternatives 4 and 5 19 call for excavation of 20 contaminated soil around the 21 utilities and buildings and 22 below-ground structures using air 23 knife technology. This is where 24 air is blasted into the soil to 25 loosen it, followed by a powerful

R2-0000593

48 1 vacuum to remove the soil. The 2 soil would then be collected and 3 characterized for disposal. 4 It's easier to work around 5 utilities. I think you see it -- 6 probably if you're in New York 7 City, street excavation work, 8 you've probably seen it. I 9 thought that air knife technology 10 sounded interesting, something I 11 had never heard of, but apparently 12 it's common. 13 And then we'll go to the 14 central tank farm area, that 15 little purple spot here in the 16 center. It's directly adjacent to 17 an active building on the Stepan 18 property. There's, like I 19 mentioned, underground and 20 overhead utilities. The study 21 estimated about 800 cubic yards of 22 soil in this area has VOC 23 contamination. 24 The alternatives considered 25 for the central tank farm area are

R2-0000594

49 1 the same as our previous areas. 2 We have Alternative 1, no further 3 action; Alternative 2, 4 institutional controls; 5 Alternative 3, excavation with 6 offsite disposal; Alternative 4, 7 EFR; and Alternative 5, SVE. 8 So, once we looked at all 9 the alternatives, we had to 10 evaluate them. And now I'll 11 summarize. 12 We had to look at nine 13 evaluation criteria that EPA has, 14 and we use these evaluation 15 criteria to select the preferred 16 remedial alternatives for the 17 areas. 18 So, we'll start off here. 19 In order to be considered, a 20 remedial alternative must meet 21 these two threshold criteria: 22 Overall protection of human health 23 and the environment; and 24 compliance with applicable or 25 relevant and appropriate

R2-0000595

50 1 requirements. 2 In other words, will the 3 alternative meet promulgated 4 federal and state environmental 5 regulations? 6 Then we have five balancing 7 criteria. All the alternatives 8 were evaluated against these 9 criteria: Long-term 10 effectiveness; reduction in 11 toxicity, mobility, or volume 12 through treatment; short-term 13 effectiveness; implementability, 14 is it going to work; and cost. 15 Our final two criteria are 16 the modifying criteria, and that's 17 state and community acceptance. 18 These will be addressed in our 19 final Record of Decision. 20 When the comment period 21 closes, we'll address all the 22 comments in the Record of 23 Decision. So, we'll take those 24 into consideration when selecting 25 the final remedy in the Record of

R2-0000596

51 1 Decision. 2 We understand from New 3 Jersey that they are evaluating 4 the preferred remedy and have 5 indicated they agree with our 6 approach. We expect to get a 7 letter at some point during the 8 comment period. 9 And, of course, we're here 10 tonight to hear your comments on 11 our Proposed Plan. 12 So, the moment we've been 13 waiting for, I guess, the 14 preferred remedy. After all that 15 evaluation, the detailed 16 evaluation of all the remedial 17 alternatives, EPA's preferred 18 remedy includes soil excavation at 19 the buried container area, gypsum 20 area, leather material area, and 21 central tank farm area with 22 offsite soil disposal; and soil 23 vapor extraction at the former 24 aromatics area. 25 Institutional controls would

R2-0000597

52 1 be part of the remedy for 2 locations where residual 3 contamination requires land use 4 restrictions. 5 So, that's the preferred 6 remedy. 7 What happens next, I think 8 we've been through this process a 9 few times. We described that 10 we'll have a Record of Decision 11 with the final remedial action 12 spelled out and cleanup goals, 13 we'll begin negotiations for the 14 remedial design or remedial 15 action, and, then, finally, the 16 remedy will be implemented or 17 constructed. 18 So, with that, I thank you 19 for your attention, and we will 20 take comments from the audience. 21 Wanda? 22 MS. AYALA: I just want to 23 facilitate a little bit. It's 24 important when you get up and make 25 a statement or comment, that you

R2-0000598

53 1 state your name for the 2 stenographer. 3 Questions? Comments? 4 MR. KORTRIGHT: I'll make a 5 comment. 6 MS. AYALA: Your name? 7 MR. KORTRIGHT: Peter 8 Kortright, Department of Planning 9 with the County of Bergen. 10 There are several comments 11 or questions that I think should 12 be considered at least from the 13 perspective of the County. 14 One, there is a current 15 project with the State, along with 16 the County, to expand Route 17 to 17 three lanes. 18 I didn't really see that in 19 the consideration or the plan 20 evaluation for the terms of land 21 use restrictions. I just think 22 that needs to be addressed more 23 thoroughly. 24 MR. SIVAK: Sure. 25 MS. DONOVAN: Thank you.

R2-0000599

54 1 MR. KORTRIGHT: We reviewed 2 the plan, and we don't see 3 anything to that effect. 4 More to that effect, we 5 don't know the alternatives to the 6 line men, which could affect the 7 possible effects of your criteria 8 in terms of the different uses of 9 contamination. 10 Second is I think in terms 11 of the remedy that you've 12 outlined, you may want to also 13 consider to incorporate the 14 possible surrounding cleaning up 15 of culverts -- our understanding 16 is that we've looked at culverts 17 from the surrounding areas that 18 are pretty much clogged up -- so 19 you don't get secondary type of 20 contamination. 21 For instance, let's say you 22 do proceed with your alternatives. 23 You still may get contamination 24 from pipes that have not been 25 replaced in a hundred years.

R2-0000600

55 1 So, that's maybe something 2 that could be incorporated or as 3 part of the agreement with a 4 potential developer. Just 5 something that should be 6 considered. 7 MR. SIVAK: Thank you. 8 MR. KORTRIGHT: Number 9 three, on Page 28 of the report -- 10 and this is a small technicality, 11 but I think we still need to look 12 at it. 13 It says on Page 28 under 14 population, Maywood and Rochelle 15 Park, it says that the population 16 is decreasing. Well, that might 17 be true. 18 And then it goes to, in 19 conclusion, that the population of 20 the County is decreasing. That's 21 actually not true. The population 22 of the County is increasing. 23 Meaning that when you're 24 looking for potential land use 25 occupants, the vacancy rate on

R2-0000601

56 1 Routes 17 and 4 is among the 2 lowest in the United States. So, 3 if you're going to attract 4 someone, it's not a place where 5 it's declining, it's actually 6 inclining. 7 So, you may not want to say 8 that in a report. You could say, 9 you know, 1990, but if you look at 10 2000, 2010, those numbers are 11 actually increasing. So, I think 12 that's important to look at. 13 MR. SIVAK: Thank you. 14 MR. KORTRIGHT: I just 15 wanted you to take that in your 16 consideration. 17 MS. DONOVAN: Thank you. 18 MR. KORTRIGHT: Thank you so 19 much. 20 MS. AYALA: Thank you. 21 Anyone else? 22 MS. BROAD: I would like to 23 say something. 24 MS. AYALA: Your name, 25 please?

R2-0000602

57 1 MS. BROAD: My name is 2 Heather Broad. I live on 275 3 Eccleston Place, Maywood. 4 There's a pile of dirt that 5 is above the level of the 6 railroad. 7 Is that clean? 8 It's not culvert. 9 Is that a health risk? 10 I live very close to that 11 area. 12 MR. SIVAK: I'm not quite 13 sure -- 14 MS. DONOVAN: I'm not 15 familiar with that specific 16 address location, but none of the 17 dirt -- 18 MS. BROAD: Do you know 19 Central Avenue? 20 MS. DONOVAN: Yes. 21 MS. BROAD: Do you know the 22 pool? 23 MS. DONOVAN: Sorry. 24 MS. BROAD: Well, it's not 25 quite Rochelle Park, but it's --

R2-0000603

58 1 you know how to get onto Route 17 2 from Central Avenue? 3 MS. DONOVAN: Yes. 4 MS. BROAD: You do. 5 Say you go from Maywood 6 Avenue. There's Ramapo and 7 Eccleston, and the next turn right 8 is to get onto 17 North. 9 Does that give you -- help 10 you? 11 It's just a small street 12 with ten houses. I can see the 13 railroad tracks from my house. 14 MR. SIVAK: I would suggest 15 that we talk to you after the 16 meeting and you can give us more 17 details on this. 18 If it is soil that is 19 associated with any of the 20 activities at the Stepan site or 21 with the Maywood remediation, then 22 we should have some information 23 for you. 24 If it's not associated with 25 any of the activities at the site,

R2-0000604

59 1 I'm not sure that we can help you, 2 but maybe we can follow up or we 3 can work with you to speak with 4 someone, maybe from the Town, to 5 try to figure out where, in fact, 6 the soil may be -- 7 MS. BROAD: It's on your 8 site. It's definitely on your 9 site. 10 MR. SIVAK: Okay. So, let's 11 talk to you after the meeting, and 12 maybe we can meet with the 13 representatives of the Corps as 14 well to try to figure out exactly 15 what this might be. 16 MS. BROAD: Okay. Thank 17 you. 18 MS. AYALA: Any other 19 questions? Comments? 20 MR. DeSAUSSURE: My name is 21 Bill DeSaussure, 23 West Howcroft 22 Road, Maywood Furniture property 23 as well. 24 With the gypsum, our 25 property, we thought, already had

R2-0000605

60 1 a clean bill of health. And they 2 knew the gypsum was there; they've 3 done quite a bit of excavating and 4 carting off dirt. 5 So, is this gypsum problem 6 an afterthought? 7 MS. DONOVAN: No. 8 MR. DeSAUSSURE: Why wasn't 9 it addressed originally when they 10 were doing all the digging? 11 MS. DONOVAN: Like I showed 12 you on the other slide, there are 13 two separate cleanup activities 14 going on simultaneously 15 separately. 16 The Army Corps, the FUSRAP 17 radiological contamination, 18 they're allowed to take the 19 radiological contamination. They 20 got their radiological 21 contamination, and then there was 22 some gypsum material left. 23 There was visible blue -- 24 MR. DeSAUSSURE: So, this is 25 the other phase.

R2-0000606

61 1 MS. DONOVAN: This is the 2 other part of the cleanup. 3 We could see that blue color 4 at the bottom of the dig after the 5 FUSRAP work was completed. So, we 6 want to go investigate and make 7 sure we know what we're after, if 8 it's, in fact, there. 9 MR. DeSAUSSURE: Thank you. 10 MS. AYALA: Any other 11 questions? Concerns? 12 Okay. We'll wrap it up with 13 the comment period is open until 14 October 22. If you guys think of 15 anything that you want to share 16 with us, you have Betsy's e-mail 17 contact right here. 18 You could fax it to her or 19 e-mail it to her or mail it to her 20 as long as it's postdated by 21 October 22. 22 And with that, we'd like to 23 thank you for taking the time to 24 come out and be here. We'll be 25 around a little while if you guys

R2-0000607

62 1 want to talk on the side. 2 Thank you. 3 MR. SIVAK: Thank you. 4 (Time noted: 7:54 p.m.) 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

R2-0000608

63 1 C E R T I F I C A T E 2 STATE OF NEW JERSEY) 3 ) ss. 4 COUNTY OF HUDSON ) 5 I, LINDA A. MARINO, RPR, 6 CCR, a Shorthand (Stenotype) 7 Reporter and Notary Public of the 8 State of New Jersey, do hereby 9 certify that the foregoing 10 transcription of the public meeting 11 held at the time and place aforesaid 12 is a true and correct transcription 13 of my shorthand notes. 14 I further certify that I am 15 neither counsel for nor related to 16 any party to said action, nor in any 17 way interested in the result or 18 outcome thereof. 19 IN WITNESS WHEREOF, I have 20 hereunto set my hand this 19th day 21 of September, 2013. 22 23 ________________________________ LINDA A. MARINO, RPR, CCR 24 25

R2-0000609

sr."'"" Morgan Lewis Fax' 609 919 6701 Pennsylxanta Litnited Liability Partnership

www.morgan!ewis.com RANDALL B. SUNBERG Partner-in-Charge

John McGahren Partner 609.919.6641 jmchagrcn@morganlewis.com

December 4, 2013

VIA FEDERAL EXPRESS AND EMAIL (donovan. hetsy@epa.gov)

Ms. Betsy Donovan Remedial Project Manager U.S. Environmental Protection Agency 290 Broadway, 19th Floor New York, NY 10007-1866

Re: Comments on Feasibility Study Report and Proposed Plan Maywood Chemical Company Superfund Site CERCLIS Operable Unit 1: Non-FUSRAP Soil and Source Areas

Dear Ms. Donovan:

Enclosed are comments prepared on behalf of Stepan Company regarding the Feasibility Study and Proposed Plan for the Maywood Chemical Company Superfund Site, CERCLIS Operable Unit 1.

Sincerely,

John McGahren

Enclosures

cc: Christina K. Loundy, Esq., Stepan Company Wanda Ayala, EPA (via email - ayala.wanda@epa.gov) George 11. Zachos, EPA (via lirst-class mail only)

081/76842915.1

R2-0000610

COMMENTS ON

FEASIBILITY STUDY REPORT AND PROPOSED PLAN MAYWOOD CHEMICAL COMPANY SUPERFUND SITE

CERCLIS OPERABLE UNIT 1: NON-FUSRAP SOIL AND SOURCE AREAS MAYWOOD AND ROCHELLE PARK, BERGEN COUNTY, NEW JERSEY

Submitted on behalf of Stcpan Company

December 4, 2013

R2-0000611

1. INTRODUCTION 1

1.1 Background 1

1.2 Summary of Position 2

1.2.1 Major Deficiencies of the Proposed Plan 2

1.2.1.1 Failure to consider current data and infoiTnation from the PUS RAP program 2

1.2.1.2 Failure to properly classify soil for disposal 3

1.2.1.3 Failure to consider Site-specific data 4

1.2.2 Other deficiencies in the Proposed Plan 4

1.3 Legal Framework 4

2. COM.MENTS REOARDING the PROPOSED PLAN'S FAILURE TO CONSIDER ALL RELEVANT DATA 6

2.1 The Proposed Plan's admitted failure to incorporate up-to-date excavation and sampling data from the FUSRAP program renders its remedy selection arbitrary and capricious 6

2.1.1 Background ....6

2.1.2 Impact 7

2.1.3 Due Process 8

2.2 The reliance on generic impact-to-groundwater standards to justify remedial alternatives is contrary to both the cited ARAR and site-specific data, resulting in the selection of remedies that are over-conservative 9

3. COMMENTS REGARDING INCONSISTENCY WITH NCP REMEDY EVALUATION CRITERIA 10

3.1 The failure to properly consider the impact of NRC soil classification as 1 le.(2) byproduct material renders the Proposed Plan's costs estimates inaccurate and significantly understated 10

3.1.1 Background 10

3.1.2 Cost Impact 12

3.1.3 Consistency with the NCP 13

4. COMMEN TS REGARDING EPA'S FAILURE TO PROVIDE A RATIONAL CONNECTION BETWEEN THE FACTS AND ITS DECISION 15

4.1 The inclusion of extensive pre-design investigations for each and every remedy proposed is not rational given the amount of currently available data and the nature of the remedies proposed 15

4.2 The Proposed Plan improperly balances the environmental impacts of off-site versus on-site remedies for the GA and LMA 16

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4.2.1 Background 16

4.2.2 Risk Assessment 16

4.2.3 Gypsum Area 17

4.2.4 leather Material Area 18

4.3 It is not technically defensible to address soil contamination separate from groundwater contamination in the CTFA and FA A 19

4.3.1 Background 19

4.3.2 Technical Justification 20

4.3.3 Consistency with NCP 20

4.4 There is no rational purpose for air knife excavation 21

5. CONCLUSION 22

It

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1. INTRODUCTION

I.l Background

The Maywood Chemical Company Superfund Site ("Site") has been the subject of multiple Remedial Investigations and Feasibility Studies over a period of more than 30 years. 'Iliese studies deal with historical contamination from operations of the Maywood Chemical Company — prior to the time Stepan Company ("Stepan") acquired the portion of the Site owned by Maywood Chemical Company in 1959 - and Citro Chemical Company. Consequently, in many cases, the contamination has been present at the Site for more than a century.

The Remedial Inve,stigation.s and Feasibility Studies address radiological contamination, chemical contamination and co-mingled contamination. Radiological and co-mingled radiological and chemical contamination are the responsibility of the United States and are being remediated under the Formerly Utilized Sites Remedial Action Program ("FUSRAP"), which is currently implemented by the Army Corps of Engineers (tire "Corps"). The United States has already conducted extensive clean-up on the Site, including excavating well over half a million cubic yards of soil over the last 28 years. This amount of soil already excavated from the site is enough to fill almost 4,000 rail cars which, if joined together in a single line, would extend from the site to the Connecticut border. Or put another way, the amount of already-excavated soil would be enough to fill a football stadium 300 feet high.

Remediation of chemical contamination is being directed by the United States Environmental Protection Agency ("EPA") under the Superfund program. Over the last 25 years, Stepan, in cooperation widi EPA, has completed a Remedial Investigation (the "Rl") and drafted five Feasibility Study reports addressing chemical contamination in soil and groundwater, and remains ready and willing to undertake appropriate remediation of the Site, in cooperation with the EPA and other Potentially Responsible Parlies. Earlier this year, EPA decided to take over the preparation of the Feasibility Study for Site soil.

On August 23, 2013, EPA issued a Final Feasibility Study for the Maywood Chemical Company Superfund Site, Operable Unit 1 ("OU-l") for non-radiological soil and source areas, dated August 2013 (the "FS"), prepared by Uenningson, Durham & Richardson Architecture and Engineering, P.C. (under contract with EPA). The FS includes a presentation of the results of the RI and an identification, screening, and evaluation of remedial allemativcs. Based on the FS, EPA also issued a Proposed Plan for OU-l on August 23,2013 ("Proposed Plan"). The Proposed Plan recommends preferred remedial alternatives to address five areas of concern ("AOCs") at the Site: Buried Container Area ("BCA"); Gypsum Area ("G.A"); Leather Material Area ("LMA"); Central Tank Farm Area ("CTFA"); and Former Aromatics Area ("FAA"). Public comments on the FS and Proposed Plan are due December 5,2013.

This document provides comments on behalf of Stepan on the FS and Proposed Plan. In accordance with the National Oil and Hazardous Substances Pollution Contingency Plan

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("NCP"), 40 C.F.R. Part 300, and principles of administrative law, the comments presented below support re-evaluation of the proposed remedies based on Proposed Plan's failure to consider key facts, data and information. Failure to re-evaluate the remedies would render the selection of the proposed remedies in a subsequent Record of Decision ("ROD") arbitrarv- and capriciou-s.

1.2 Summary of Position

The Proposed Plan is deficient, and cannot lawfully be adopted, because of three major deficiencies, as well as a number of other deficiencies specific to certain AOCs,

1.2.1 Major Deficiencies of the Proposed Plan

1.2.1.1 Failure to consider current data and information from the FUSRAP program.

As set forth above, the FUSRAP cleanup is extensive. It has impacted all five of the AOCs subject to the Proposed Plan. Accordingly, in preparing its prior drafts of the FS, Stepan consistently analyzed up-to-date data and information from the FUSRAP remediation in its evaluation of remedial alternatives and made continued efforts to obtain updated information to be able to do so. After EPA took over the preparation of the FS for the Site earlier this year, Stepan surmised—as it now realizes was incorrect—^that the EPA had current FUSRAP cleanup data and information and would, as both law and logic would dictate, consider such information in determining the appropriate remedies and associated remedial costs. Stepan was surprised, in reviewing the Proposed Plan, to find that EPA had not obtained or considered this highly relevant current FUSRAP data in its evaluation of remedial alternatives, ignoring llie effects of-and even the quantity of—the Corps' extensive excavations in the AOCs. This was particularly surprising since EPA adopted a "dig and haul" remedy for four of the five AOCs and the remaining AOC has a dig and haul component and significant quantities of soil identified by EPA as requiring remediation already have been removed.

Upon this realization when reviewing the FS and Proposed Plan, Stepan immediately requested, under a Freedom of Information Act ("FOIA") request, the relevant FUSRAP data and information from the Corps. While Stepan was initially told that this information would be made available promptly, the Corps later indicated there would be a significant delay at substantial cost to provide the requested information. After several back-and-forth communications, Stepaii received some of this information—and only within the last month— from the Coips. After the initial difficulties in obtaining this crucicd information from the Corps, Stepan decided that, although it appeared this vital infonnation was not part of the EPA's record upon which the Proposed Plan was based, if EPA had otherwise obtained this information from the Corps, it would be readily available from EPA. Therefore, to avoid unneces-sarily delaying its comments, Stepan also sought this information from EPA. From that request, Stepan discovered that EPA - by its own admission—did not obtain current FUSRAP data trnd

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information in preparing its Proposed Flan, after it decided earlier this year thai it would take over the preparation of the FS.'

Because the EPA administrative record did not include, and therefore could not have considered, rcleviuil and critical information about the FUSRAP remediation, any selection of the proposed remedies in a future ROD would be arbitrary and capricious. The FUSRAP remediation hiis impacted all five of the AOCs, which in turn impacts the protectiveness, cost, implementability, and effectiveness of the remedial alternatives.^ The only way that EPA can adopt tire proposed remedies would be for it to conclude that the FUSRAP remediation conducted since 2010 would have no effect on the remaining chemical remediation. The Proposed Plan did not even attempt to do so, and the EPA has now admitted that it did not do so. For that reason alone, the Proposed Plan cannot lawfully stand.

1.2.1.2 Failure to properly clas.sify soil for disposal.

Since 1954, the Nuclear Regulatory Commission ("NRC") has licensed radiological activity at the Site, and Stepan currently holds an NRC license for the possession of radiological material in three burial pits. While the Corps is responsible for remediation of the burial pits as wells as otlier radiological wastes, the license remains operative and, accordingly, NRC governs classification of residual soil removed from the Site. NRC has classified all residual soil from lite Site as 1 le.(2) byproduct material. Tlie practical result of that classification is that any waste from the Site that has radiological concentrations above background must be disposed of as 1 le.(2) byproduct material at the single facility prc.sently licensed to accept it - Envirocare of Utah - at significant cost and with significant transportation and handling impacts. Because of the extensive radiological contamination at the Site, one can reasonably as.sume any and till excavated material will be classified as 1 le.(2) material as long as the license remains operative.

The Proposed Plan is deficient because it failed to consider the euiTcnl soil classification at the Site, which would more than triple the cost of removal of that soil, as well as affecting other factors EPA is required to consider under the NCP. Simply put, without considering the true cost of such removal, EP.A could not have done the appropriate remedial alternatives evaluation it was required to do by the NCP, as the large difference in cost would necessarily influence the evaluation of the other criteria. It is fundamental logic that one cannot balance these criteria if

In re.sponse to Stepan's FOIA request, EPA idenlillect only one responsive document, the Post Remedial Action Repon for 23 Howcraft Road, stating that EPA only ha.s data from properties where FUSRAP remediation is complete and tiic remediation of the Stepan and Sears property remained ongoing. This, however, contradicts the FS, which included FUSRAP data, but not current data, for both the Stepan and Sears properly. ' Perhaps EPA recognized this deficiency, by proposing an extensive he-Design Investigation ("PDI") for the Site. However, as demonstrated below: (t) doing a PDI does not relieve EPA of its obligation to consider the current data from the FUSRAP remediation and (2) doing a PDI cannot be a post hoc substitute for doing the appropriate FS/RI in the first place, t he Proposed Plan cannot have it both ways: if the data needs to be supplemented in such an c.\tensive manner, it cannot be sufficient to support a remedy selection before that data is obtained.

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only a fraction of the appropriate costs and no consideration of transportation impacts are used in such an analysis.

1.2.1.3 Failure to consider Sitc-spcciiic data."

Further, the Proposed Plan is deficient because it adopts soil remediation methods based on concerns about groundwater contamin^ion without considering Site-specific groundwater criteria and data as well as Site history. The Proposed Plan's logic is essentially this: because generic impact-to-ground water criteria suggest potential groundwater effects, it is necessary to remove the soil above the groundwater. The Proposed Plan, however, relies on an initial false premise: rather than using generic impact-to-groundwater criteria, the IiP.4 must consider Site-specific criteria, as required by regulatory requirements and, correspondingly, the NCP. And, equally important, rather than using the generic impact-to-groundwater criteria as its sole basis to predict potential groundwater impacts, EPA logically should consider the actual impacts at this Site. The soil contamination in many areas on the Site has been present, in some cases, for more than a century. Certainly, considering the impacts, if any, to groundwater during this e.xtensivc, real-lite time frame is relevant and demonstrates that the chemicals of concern are not pervasive in groundwater even alter their presence in soil for more than a century.

1.2.2 Other deficiencies in the Proposed Plan

The Proposed Plan includes extensive pre-design investigations for each and every remedy proposed even though there were hundreds of samples collected and over one hundred test pits investigated as part of the EPA-approved RJ. The remedies proposed by EPA in the Proposed Plan do not require intense prc-dcsign investigation.

The Proposed Plan improperly balanced the human health and environmental impacts of off-site versus on-site remedies for the LMA and OA resulting in over-conservative remedy selection.

It is not technically defensible to address soil contamination separate from groundwater contamination in the CTFA and the FAA.

The Proposed Plan's inclusion of the air knife excavation with Soil Vapor Extraction ("SVE") and Enhanced Fluid Recovery ("EFR") has no rational purpose because the SVE and EFR technologies can be designed to remediate areas identified for air knife extraction successfully without the additional cost and increased risks to human health that would result from implementing air knife excavation.

1.3 Legal Framework

According to the NCP, which governs the remedy selection process, the Rl/FS is used to assess site conditions and evaluate alternatives to llie extent necessary to select a remedy. 40 C.F.R. §300.430(a)(2). More particularly, the RI "provides information to assess the risks to human

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heaJlh and the environment and to support the development, evaluation, and selection of appropriate response alternatives." 40 C.F.R. §300.430 (d)(1). "The primary objective of the [FS] is to ensure that appropriate remedial altematives are developed mid evaluated such tliat relevant information concerning the remedial action options can be presented to a decision­maker and an appropriate remedy selected." 40 C.F.R. §300.430(e)(l).

Similarly, principles of administrative law require the agency to "engage in 'reasoned decisionmaking.'" United Slates v. Garner, 767 F.2d 104, 1 IS (5*'' Cir. 1985). To that end, when making a decision, mi agency must consider ail relevant facts, information and altematives. Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402, 416, and adequately explain its decisions by providing a rational connection between the facts and the resultant decision. Sierra Club V. United States Army Corps of Engineers, 112 F.2d 1043, 1051 (2'"' Cir. 1985). As summarized by the Supreme Court:

|T]he agency must examine the relevant data and articulate a satisfactory explanation for its action including a 'rational connection between the facts found and the choice made.'... In reviewing that explanation, we must 'consider whether the decision was based on a consideration of the relevant factors and whether there has been a clear error of judgment.... Normally, an agency mlc would be arbitrary and capricious if the agency has relied on factors which Congress has not intended it to consider, entirely failed to consider an important aspect of the problem, offered an explanation for its decision that runs counter to the evidence before the agency, or is so implausible that it could not be ascribed to a dilTcrcnce in view or the product of agency expertise.

Motor Vehicle Manufacturers Ass'n v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29,43 (1983) (citations omitted).

ITie FS and Proposed Plan satisfy neither tlie requirements of the NOP nor tire dictates of administrative law. The information upon which the alternatives have been developed and evaluated is deficient in many regards, because the Proposed Plan failed to consider several important aspects of the problem. Further, EPA failed to provide a "rational connection" between certain of its decisions and the facts. Because the administrative record "fomrs the basis for the selection of a response action," 40 C.F.R. §300.800(a), and the admini.strative record for the Site does not contain the "relevant infonnation" required to make a defensible remedy selection, EPA must reconsider determinations made in the Prtrposed Plan.

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2. COMMENTS REGARDING THE PROPOSED PLAN'S FAILURE TO CONSIDER ALL RELEVANT DATA

2.1 The Proposed Plan's admitted failure to incorporate up-to-date excavation and sampling data from the FUSRAP program renders its remedy selection arbitrary and capricious.

2.1.1 Background

As previously discussed, all five AOCs that are the subject of the Proposed Plan are also subject to remediation under FUSRAP. The FUSRAP remedial action is massive, and has been underway for many years. As of September 30, 2012, 577,302 cubic yards of soil have been excavated under the FUSRAP program. United States Army Corps of Engineers, New York. District, FUSRAP Update, The Maywood Project Site (October 2012) (available at http://www.fusrapmavwood.com/doc.s/Mavwood%20Site%20News]etter-%200ctober%202012.pdD. Since the Record of Decision was issued in August 2003, the Corps has been actively excavating and continues to excavate areas on the Stepan and Sears properties, including in the areas of the AOCs. In addition, the Corps reportedly completed the excavation work at the DeSaussure property in 2008, including excavation in the location of the GA, and issued its Post Remedial Action Report for 23 West I lowcroft Road, Block 124, Lot 17, Maywood, New Jersey in May 2011.

Because the FUSRAP excavations have changed the featui'es of the AOCs, Stepan, in preptrring prior versions of the FS for the Site, repeatedly requested from the Corps sampling data and infonnation regarding the extent and deptli of excavations in the AOCs and also sought assistance from EPA to obtain the data. Accordingly, Stepan requested up-to-date data from the Corps when it prepared its 2010 Draft FS so the evaluation of alternatives would reflect actual conditions at the Site and all relevant available data. EPA's 2013 FS and Proposed Plan, however, do not do the same. The Proposed Plan states in FS Sections 1.0 and 1.1 that it received updated information from the Corps regarding the progress on the FUSRAP remediation (as .shown on Figure 1-1, dated May 21, 2012). However, based on Stepan's review of the 2013 FS and comparison to the 2010 Draft FS, EPA's 2013 FS figures regarding areas to be remediated (Figures 6-4, 6-8, 6-10, 6-11, and 6-14) reference 2010 sources and no new information from the Corps is referenced or considered, including lateral and vertical excavation data. Further, even if EPA had used the data from May 2012, some of those data are out-of-date since the FS and Proposed Plan were published more than a year later. Stepan was able to obtain current information from the Coq5S, through a FOIA request, in less than three montlis. Certainly, EPA could have also obttuned current FUSRAP data from the Corps.

Stepan also submitted a FOIA request to EPA to detcnnine what information from the FUSRAP remedial action EPA did consider. EPA's response staled that the only responsive document it has is the Post Remedial Action Report for 23 West Howcroft Road, Block 124, Lot 17,

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Maywcx>d, New Jersey - May 2011. EPA did not reference or produce the May 2012 map or any related documents.

Without considering cuiTcnt data from the FUSRAP remedy, one cannot truly assess the scope of the required remedies and, accordingly, cannot make a reasoned decision regarding appropriate remedial actions. If EPA did not consider tlie most current data, which it apparently did not. the appropriateness of EPA's decision is called into question as all relevant data were not evaluated as required by the NCP and principles of administrative law. To the c.xtcnt that EPA hiis relied upon the FUSRAP excavation data to determine tlte necessity of further excavation to meet CERCLA criteria, EPA has not made those data available to the public, which is inconsistent with public information and community relations requirements of the NCP.

2.1.2 Impact

The FUSRAP remediation is unquestionably a significant factor in the Superfund remedy selection process. The Corps has effectively remediated all or portions of all five of the AOCs. The failure to consider up-to-date data from the FUSRAP remedial action has an enormous impact on many aspects of the alternatives and, correspondingly, an enormous impact on the ailcmatives evaluation and entire remedy selection process.

These impacts are clearly demonstrated by reviewing the attached figures. Figure 1 presents a summary regarding excavations completed (green) and to be completed (brown) as provided by the Corps in November 2013 (source of data is August 1,2013). Figure 2 presents the areas excavated (green) and to be excavated (brown) as provided by the Corps in September 2010. Comparison of Figures I and 2 reveals two critical points; (1) significant excavation work was completed by the Corps over the intervening three year period, including excavations in the Superfund AOCs, and (2) the Corps has excavated or plans to excavate areas that were not anticipated for excavation in 2010, including additional portions of the Superfund AOCs.

For example, the information received from the Corps in response to Stepan's FOIA request indicates that the Corps has excavated or plans to excavate up to 50% more of the area of both lire LMA-A and FA A than planned in 2010, but such excavations have not been considered in the FS or Proposed Plan. Further, comparison of Figures 1 and 2 shows that EPA has assumed that 97,590 square feet (-2.24 acres) ofthc BCA needs to be excavated, while estimates based on current infonnation show that only 65,475 square feet (-1.50 acres) would need to be excavated under this remedial alternative. Thi.s is a reduction of 33% (32,115 square feet or 0.74 acres) of the area and associated volurac. Interestingly, these excavation estimates for the BCA match the information provided for 2012, but EPA did not u.se that information, relying instead on data from 2010. Further, EPA assumed that a portion of the BCA to be remediated under this scenario is wetland, but comparison ofthc figures shows that considerably less area to be excavated is within the wctkind area. Certainly, these significant differences in area of excavation in thra of the four areas where excavation is the proposed remedy are relevant data

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thai must be considered. The changes as a result of using accurate up-to-date Corps data will significantly impact what remedial alternatives are feasible and their cost and, ultimately, what alternatives are reasonable.

Cost is obviously impacted by EPA's failure to consider actual Site conditions and all relevant data. The FS acknowledges a lack of data that causes an uncertainty in volumes to be handled and disposed of to be incorrect from -30 to +50%. See, e.g., FS at 6-40, 6-54, and 6-74. When that is considered with the fact that FS cost estimates already have an accuracy of only +50% to -30% {see EPA, A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, EPA 540-R-00-002, OSWER 9455.0-75 (July 2000)), EPA's cost estimates become meaningless and, correspondingly, the decision-making process essentially random. As discussed in further detail below in connection with the 1 le.(2) classification, such large dilTerences in cost can be expected to change the balance of the alternatives evaluation.

Other impacts include whether data relied upon to justify the need for remedial action remains valid. For example, 32 test pits were excavated to investigate anomalies identified by a magnetometer survey of the Sears Property during the RI and 20 soil borings were advanced and sampled over the 20.6 acres of accessible property. Using 2010 data, the FS states that approximately 12.2 acres of that area had been excavated under the FUSRAP program and an additional 6.2 acres were designated for future FUSRAP excavations. Therefore, even using the earlier data, EPA documents that the FUSRAP response action has removed contaminants (and presumably drums identified during the Rl) from nearly 90% of the BCA to depths that "'were not provided." FS at p. 6-6. Of the 52 test pit and boring locations, all but one was removed as part of the FUSRAP remediation. FS at p. 6-5. Despite clean magnetometer survey data from the remaining 10% of the area, and without final information from the FUSRAP program as to the surface areas and soil depths actually excavated, it was "assumed" that buried containers and contaminated soils remain in small areas of the BCA, and that approximately 12,400 cubic yards of additional material must be removed. FS at p. 6-17. These arbitrary assumptions have resulted in a preferred remedy for the BCA estimated to cost over $7 million. Based upon the RI survey data and the data readily available from the FUSR,A.P program depicting excavation of approximately 33% additional area of this AOC, it is much more reasonable to assume tliat no further action is necessary in the BCA.

2.1.3 Due Process

Substantive due process requires the ability to review the full administrative record, including all relevant facts and documents. Because EPA did not consider up-to-date hUSlCAP data, EPA s administrative record is defective. Correspondingly, the public is not able to as.sess the proposed remedies as there is insufficient information presented to understand the decision-making process and the information that is presented is inaccurate or incomplete, thwarting the public

participation requirements of the NCP.

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The NCP requires that EPA "establish an administrative record tliat contains the documents that form the basis for the selection of a response action." 40 CFR §300.800.

[The administrative record] generally reflects the infonnation EPA has considered in connection witli cleanup decisions at a site and includes the ultimate decisions regarding the response(s). The documents that EPA places in the administrative record should fully explain and support this process, and should therefore include all nondeliberative documents/information that EPA considered or relied upon in selecting the response action, including information that was considered but ultimately not adopted by the Agency. EPA, Revised Guidance on Compiling Administrative Records for CERCLA Response Actions (September 2010) (available at http://www.epa.gov/compliance/resources/policies/cleanup/superfund/admiti-record-mem-rev.pdf).

Among these documents are data, which includes data collected for previous actions at a site. Id. at 11. While the administrative record does not generally include draft documents, "[wjhere a draft contains unique factual information that is considered or relied upon in a response action decision, tliat information should be extracted and placed into a nondeliberative document." Id. at 15. EPA shall, in turn, make the "supporting analysis and information available in the administrative record" to the public. 40 CFR § 300.430(f)(3)(B).

If the Corps data is not part of the administrative record, then the remedy selection is deficient in not considering all relevant data.^ Indeed, not only did EPA fail to consider the most recent data readily available from the Corps, but it didn't even consider the 2012 data which was included in the FS. 'Ihe failure to consider all relevant data renders the EPA decision arbitrary. If the Corps data is part of the administrative record, then that data must be made available to the public to satisfy the NCP. Accordingly, EPA must provide the data and re-examine the remedial alternative evaluation as consideration of up-to-date FUSIC\P data is necessary to support any remedy decision in these AOCs where the FUSRAP remedial action has substantial impacts.

2,2 The reliance on generic Inipact-to-groundwater standards to justify remedial alternatives is contrary to both the cited ARAR and site-specific data, resulting in the selection of remedies that are over-conservative.

As noted in FS Section 3.1.3, the following is an ARAR:

Soil Cleanup Criteria - Impact-to-Groundwater: The Remediation Standards rules, N.J.A.C. 7:26D-1.1 and the Technical Requirements for Site Remediation,

In a letter dated November 15,2013 to John McGahren of Morgan, Lewis & Bockius LLP, BPA states that "judicial review of EPA'.s remedial decision would be limited to the Adminbtrative Record, pursuant to Sec. 1130)(2)" (emphasis in the original) and that Stepan has no need to consider FUSRAP data not in the Record. While judicial review is limited to the Administrative Record, that maxim of administrative law does not relieve the EPA from including all relevant infonnation in Uie Record. See, e.g.. Motor Vehicle Manufacturers Ass'n v. State Farm Mutual Automobile Insurance Co.. 463 U.S. 29 (1983 ,• American Min. Canvre.ss v Thomas 772 F 2d 617 (10th Cir. 1985).

9

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N.J.A.C. 7:26K-L3 require tlie person responsible for conducting the remediation to develop site-specific soil remediation standards that are protective of groundwater. . . , The purpose of the site-specific impact-to-groundwater soil remediation standards is to prevent unacceptable risk to human health from the ingestion of contaminated groundwater, caused by the migration of contaminants from the unsaturated soil zone to the groundwater. The standard is developed to protect against future contamination of groundwater....

FS Table 4-1 shows that the Preliminary Remediation Goals ("PRGs") are the lower of several criteria, which are always tlic NJDEP impact-to-groundwater generic criteria (never the other applicable criteria including the NJDEP direct contact or EPA RSLs). llie EPA then uses the PRGs as the basis for the Remedial Action Objectives ("RAOs"). Tlius, EPA is proposing dig-and-haul remedies for the AOCs primarily due to exccedanccs of generic irapact-to-groundwatcr criteria.

Site groundwater data, however, does not support an effect on groundwater from these areas. The soil contamination in these areas has been present for, in some cases, over a century. Certainly, the Site groundwater data would demonstrate the presence of these constituents from the soil contamination after this length of time if there was to be one, but the data do not. Accordingly, the 2010 FS noted that, although some constituents in soil were above the generic NJDEP impact-to-groundwalcr criteria, these chemicals were not pervasive in groundwater. Therefore, the primary driver for selecting a soil remedy should be a current and future industrial use (direct contact pathway).

To the extent EPA maintains tliat impact-to-groundwater criteria should be used, then EPA must make full application of the ARAR noted above and establish site-specific impact-to-groundwater for all criteria, not just some of them.^ The EPA must perform this analysis for all chemicals of concern ("COCs) in order to develop true risk-based criteria that reflect site-specific conditions.

3. COMMENTS REGARDING INCONSISTENCY WITH NCP REMEDY EVALIJ.ATION CRITERIA

3.1 The failure to properly consider the impact of NRC soil classification as lle.(2) byproduct material renders the Proposed Plan's costs estimates inaccurate and significantly understated.

3.1.1 Background

Ifte Site is contaminated with both radiological and chemical contaminants. Fhe Corps, under FUSRAP, is responsible for remediation of areas impacted by radiological material above

* The Proposed Plan does this for chromium and lithium, but not for the other parametcr.s such as arsenic, where the PRC was ba.sed upon a default to background. Sec Proposed I'lan at 20.

10

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cleanup levels and for all contamination on the Maywood Interim Storage Site ("MISS"). Specifically, "FUSRAP Waste" is defined as:

- All contamination, both radiological and chemical, whether mixed together or not, on the MISS; All radiological contamination above cleanup levels related to past thorium processing from the Maywood Chemical Works (MCW) occurring on any of the Vicinity Properties^ and

- Any chemical or non-radiological contamination on Vicinity Properties tiiat would satisfy either of the following requirements: 1. The chemical or non-radiological contaminants which arc mixed or commingled with radiological contamination above cleanup levels; or, 2. The chemical or non-radiological contiiminants which originated at the MISS or were associated with the specific thorium manufacturing or processing activities at the MCW which resulted in the radiological contamination.

United States Department of Energy and United States Environmental Protection Agency, Federal Facilities Agreement, Maywood Interim Storage Site, Docket No. II, CERCLA-FFA-00101, September 17, 1990.

A ROD for FUSRAP soils and building was signed in August 2003.^ The remedy, in general, addresses FUSRAP soils through excavation, removal and off-site disposal. The remedy also includes the use of institutional controls and land use controls on properties that will be remediated to non-residential criteria; namely, the Stepan property, the Sears property and the MISS. On these properties, the radiological cleanup criteria is 15 pCi/g combined raciiuni-226 and lhorium-232 above background. The radiological cleanup criteria on the DeSaussure property is 5 pCi/g combined radium-226 and thoriuin-232 above background.

Because Steprm holds an NRC license for the possession of radiological material in three burial pits on the Site, NRC License STC-1333, the classification of radioactive waste for disposal at the Site is governed by the Atomic Energy Act ori954 ("AEA"), 42 U.S.C. §§ 2011 et seq., as amended by the LIMTRCA, 42 U.S.C. §§ 7901 el seq. In 1978, Congress enacted the UMTRCA, which amended the definition of "byproduct material" under Section I Ic.(2) of the AHA to include mill tailings and authorized NRC to regulate tailings at licensed sites. By letter dated September 20, 2001 from NRC to Envirocare of Utah, NRC classified all tailings at the Site as I le.(2) byproduct material. While Stepan does not believe that this decision is supported by law,' as a result of it, while the license applies to the Site,^ any and all material having any

^ The properties subject to the Proposed Plan are among the Vicinity Properties. ® The Corps issued a ROD addrc.ssing hUSRAP groundwater contamination in July 2012.

This decision was cantraiy to prior NRC decision.s and is unsupported by taw. NRC previously and consistently had stated that its jurisdiction over byproduct material extended only to byproduct produced from an activity liccn.sed by NRC at the time UMTRC.^ was enacted in 1978. See United Slates Army Corps of Engineers. DD-99-7, 49 NRC 299 (NRC Director's Decision, March 26, 1999); In the Matter of Envirocare of Utah and Snake River Alliance, DD-00-06 (NRC Director's Decision, December 13, 2000), Applied to the Site, this means that only the

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radiological concentration will need to be disposed of, at significant cost, at the single facility licensed to accept it, even if it is below FUSRAP cleanup criteria.

3.1.2 Cost Impact

Because I le.(2) classification is based on the genesis of the material, not its concentration or physical characteristics, the 1 le.(2) classification will apply to soil with essentially any level of radioactivity above background. The five AOCs that are the subject of the Proposed Plan are also subject to remediation under FUSRAP, Accordingly, it is reasonable to believe that, indeed likely that, literally all of tire soil excavated will have some level of radiological contamination and, consequently, will need to be disposed of as 11 e.(2) material.

Currently, there is only a single facility licensed to accept 1 le.(2) byproduct material for disposal: Envirocarc of Utah. Disposal fees at Envirocare have been recently quoted as $500/ton, well in excess of the disposal costs used in the FS cost estimates. In addition, tiiere will be significant transportation costs. Because the disposal option is limited to one facility in Utah, the soils must be transported over 2,000 miles from the Site to the Envirocare facility.

The following table presents a comparison of the EPA's estimated cost for offsite disposal compared to the estimated costs if the material is 1 le.(2).

AOC EPA Cost Estimate

Cost if lle2 Difference

BCA $3,022,200 $13,140,000 $10,117,800

GA $1,538,171 $6,608,500 $5,070,329

LMA $1,271,050 $5,793,500 $4,522,450

FAA $177,714 $810,000 $632,286

CTFA $157,968 $720,000 $562,032

Total $6,167,103 $27,072,000 $20,904,897

material in the licensed burial pits is I le.(2) material. Despite the prior decisions, Envirocare of Utah, which is the only facility licensed to accept ne.{2) waste, sought clarification from NRC regarding the specific status of the material outside the burial pits at the Site. Consistent with earlier decisions, NRC responded that waste outside the burial pits is not 1 le.(2) waste and, therefore, not subject to NRC jurisdiction. See Michael F. Weber to Envirocare of Utah, January 26, 2001. Subsequently, without any public notice or opportunity to comment, NRC completely reversed itself in a September 20,2001 letter to Envirocare, classifying all tailings at the Site as 11 e.(2) byproduct material. NRC's reversal is inconsistent with the statutory language and legislative history oFUMTRCA, inconsistent with NRC's carefully reasoned prior interpretations, and contrary to fundamental principles ol' administrative law and due process. ' mile the Corps has remediated the burial pits that are the subject of the license, an agreement between the Corps and Stcpan states, "Stepan shall not request termination of the most recently issued NRC storage license for radioactive waste until after the Corps has completed its remedial activities on Stepan's Maywood property." Stepan has requested the Corps to acknowledge that this provision applies to the licensed burial pits and that Stepan may seek tennination, but, to date, tlte Corps maintains its position that its remedial activities are not complete and, consequently, the ne.(2) classification remains.

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It is abundantly clear that the disposal costs estimated in the FS are significantly understated given the 11 e.(2) classification presently applicable to the Site, even when not considering the significant transportation costs, to an amount of almost $21 million. Even if only 50% of the soil required disposal under an 1 le.(2) classification, a very low estimate based on the extensive radiological impacts in the AOCs, the disposal costs would still be more than two times EPA's estimated cost. Moreover, this accounts only for the disposal costs. There would also be significant increases in transportation costs and increased material handling costs.

3.1.3 Consistency with the NCP

EPA noted in the FS that:

Radiologicxil impacts are present in portions of the Site above background levels, but below the FUSRAP elcanup criteria of 15 pCi/g. Soils in portions of the AOCs that are being addressed in this FS may exhibit radiological impacts at these levels. Radiological impacts may have a significant impact on effectiveness, implemcntability, and cost of remedial alternatives because radiological materia! from the Site has the potential to be classified as 1 le{2) byproduct (mill tailings; disposal options for such materials are very limited). FS at p.6-3 to 6-4.

EPA, however, failed to consider such classification in its cost estimates and remedy selection. Instead, EPA generally estimated a small percentage (10%) of soil would require disposal as radiological-impacted, and estimated the cost of that disposal at $47/ton, incorrectly assuming that after the FUSRy\P remediation, "no special radiological handling or disposal requirements are expected." See, e.g., FS at p.6-7. Consequently, not only is the amount of radiological-impacted material likely grossly understated based on an apparent misunderstairding of the prcsentl le,(2) classification applicable to the Site, but even the material that was estimated to need disposal as radiological impacted wtrste was incorrectly classified.

In choosing "dig-and-haul" remedies for the BCA, GA, LMA and CTFA and including an unneces.sary excavation component for the FA A, but not considering the impact of the 1 le.(2) classification, EPA has failed to consider the real costs and impacts of the remedy selection. Consequently, EPA's evaluation of altern.atives and balancing of the remedy selection criteria is flawed.

The NCP provides nine criteria for evaluating individual alternatives: protection of human health and the environment; compliance with Applicable or Relevant and Appropriate Requirements ("ARARs"); long term effectiveness and permanence; reduction of toxicity, mobility or volume; short-term effectiveness; implcmentability; cost; State acceptance; and community acceptance.

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The evaluation of these criteria for the alternatives changes considerably when the impact of the disposal classification is taken into account correctly. Indeed, EPA acknowledged in the FS, "[r]adiologlcal impacts may have a significant impact on effectiveness, implementability, and cost of remedial alternatives." FS at p.6-3 to 6-4.

A.S described above, the actual remedial costs of the proposed remedies undoubtedly will be well in excess of what EPA estimated. EPA guidance states that cost estimates at the detailed analysis stage should capture all remedial costs and, whenever possible, should provide an accuracy of+50 percent to -30 percent. EPA, J Guide to Developing and Documenting Cost Estimates During the Feasibility Study, EPA 540-R-00-002, OSWER 9455.0-75 (July 2000). Because the soils were not considered 1 le.(2) material, EPA's cost estimates have not been prepared in accordance with its own guidance, and it is improper for EPA to base a remedy decision on its grossly inaccurate estimates.

Furthermore, there are significant implementability issues posed by the proposed remedies. Most significant are issues associated with the administrative feasibility and the limited availability of disposal options and capacity, as described above. See 40 C.F.R. §300.430(e)(9)(ii)(F). In addition, the Site is comprised of active manufacturing and commercial facilities. The FS acknowledges that available areas for equipment staging, temporary stockpiling of soils, treatment vessels, and other materials may be limited and states that its goal is to minimize interruptions of existing commercial and industrial activities during the remedial activities. By selecting dig-and-haul remedies for each area, however, EPA did not fully consider these implementability issues.

By failing to properly classify the material, EPA correspondingly failed to consider various components of the proposed remedies' effectiveness. See 40 C.F.R §300.430(e)(9){ji)(E). For example, EPA did not consider the impacts of transportation when assessing the remedy selection criteria and, therefore, did not consider the additional environmental impacts (e.g., air pollution, global wanning) and risk potential in transporting tliis large quantity of soil through the middle of Maywood and over 2,000 miles to the Envirocare disposal site. Nationwide, two-thirds of the carbon monoxide emissions come from transportation sources, witii the largest contribution coming from highway motor vehicles. See USEPA, Fact Sheet OMS-3, Automobiles and Carbon Monoxide, EPA 400-F-92-005, Januar>' 1993. Furthermore, carbon dioxide is the primar>' greenhouse ga.s that is contributing to recent climate change. The combustion of fossil fuels such as gasoline and dicscl for transportation accounted for about 31% of total U.S. carbon dioxide emissions and 26% of total US greenhouse gas emission.s in 2011. b>ee http://www.epa.gov/climalcchange/ghgemissions/gases/co2.html.

The excavation remedies also have greater risks from direct contact and inlialation to workers completing the remediation, and migration of soil contaminants during implementation., further, there is also an increased potential exposure to the public primarily due to the large number of

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trucks that will be required to transport the excavated material off-Site. The remedies also will unnecessai-ily impact wetlands.

When considering the effectiveness, cost and implementability impacts, the balance of the remedy selection criteria shifts considerably toward on-site remedies. Accordingly, EPA's proposed remedies cannot be supported.

4. COMMENTS REGARDING EPA'S FAILURE TO PROVIDE A RATIONAL CONNECTION BETWEEN THE FACTS AND ITS DECISION

4,1 The inclusion of extensive prc-design investigations for each and every remedy propo.sed is not rational given the amount of currently available data and the nature of the remedies proposed.

A complete RI was conducted at the Site, in accordance with the NCP and with the oversight and approval of EPA, and the AOCs have been subject to investigation and remediation by the Corps, yet the proposed remedial actions require the conduct of exhaustive pre-design investigations ("PDI"). The EPA cannot have it both ways: if the data needs to be supplemented in such a thorough manner, then it cannot be sufficient to support tlie selection of remedial alternatives, furthermore, the nature of the proposed remedies certainly does not require an intensive PDI. Rather, sampling during and post-excavation is the proper manner by which to confirm removal to cleanup criteria for a dig-and-haul remedy.

EPA's FS acknowledges that significant and comprehensive investigations have been completed at the Site, repeatedly documenting the comprehensive knowledge of impacts in the AOCs. See, e.g., FS at Section 2.5.3.1 RI Data Summary (A0C3-LMA) ("As noted significant and comprehensive investigation was completed."); FS at Section 2.5.4.1 RI Data Summary (A0C4-FAA) ("The results of these investigations defined the extent of BITIX compounds in soil (and also in overburden groundwater) in AOC 4") FS at Section 2.5.5.1 RI Data Summary (A0C5-CTFA) ("The results of these investigations indicated that BTEX compounds were detected in localized overburden soils and groundwater in the CTFA."); FS at Section 6.4.1 Identification of Area and Volumes (" The area of contamination in the FAA is delineated and confined to a limited area."). Indeed, dozens of borings, dozens of monitoring wells and over 100 test pits were completed during the RI from which hundreds of soil and groundwater samples were collected and analyzed. Therefore, the Proposed Plan's proposal for significant pre-design data collection is unnecessai-y and inappropriate. The PDI is excessive in many ways. The number of samples is excessive given the amount of existing RI data. EPA's PDI includes completion of 295 borings and collection and analysis of 2,025 samples at a cost of over $1 million. The depth of sampling in .several areas is considerably deeper than required based on the RI data and knowledge from past operations which already has delineated the vertical extent of COCs. The identified analytes are not limited to COCs that were defined during the RI or the FS. In short, EPA is essentially requiring an updated RI but, if one is needed, and Stepan does not believe it is, then EPA should not now be selecting remedial actions for the Site.

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Further, if EPA requires the exterisive PDI, then why are post-excavation samples required? See, e.g., Section 6.L3.5. Such sampling would be duplicative.

In short, the PDI requirements are unnecessarily broad and the Proposed Plan provides no rational explanation as to why such extensive sampling is required. The Proposed Plan has failed to consider the many years of environmental investigations to produce the supporting data for 13 years of FS evaluations, including data produced by the Corps under FUSRAP, and has proposed to start the RI process over as part of remedy design.

4.2 The Proposed Plan improperly balances the environmental impacts of off-site versus on-site remedies for the GA and LMA.

4.2.1 Background

As discussed in Section 3.1, the failure to classify excavated soil as 1 ]e.(2) alone is sufficient to support the selection of on-site alternatives across the Site; however, there are additional factors supporting selection of on-site remedies for the GA and LMA. EPA's risk assessment, the future use of the properties, and groundwater conditions strongly indicate that the waste present in the GA and LMA pose a low long-term threat. ThcNCP states a bias against ofT-sile disposal of untreated waste and states that engineering controls, such as containment, should be used for waste that poses a relatively low long-term tlireat. 40 C.F.R §300.430(a)(l )(iii)(B). Based on the low long-term threat from tlte material in the GA and the LMA, the NCP supports selection of on-site remedies, not excavation and off-site disposal.

422.2 Risk A.ssessmcnt

The risk assessment conducted for the Site addressed chemical contamination in groundwater, soils, sediments, and surface water (Final Risk Assessment, TRC, 1993). The risk assessment considered both ecological and human health risk. Findings from the ecological risk assessment concluded that, due to the industrial setting, there are limited receptor species and de minimis risk. Witli respect to human health, EPA acknowledges that there arc no principal threat wastes at the Site. FS at p. 3-7. The human health risk assessment concluded that under current industrial conditions, chemical contaminants in Site media do not pose a risk to human health. Although some risks were elevated above de minimis levels for residential future use scenarios, future use at the Site is anticipated to be industrial only. In fact, as noted in the FS, the AOCs and adjacent areas are currently zoned Industrial and Commercial and, more importantly, the FUSRAP ROD already requires deed notices re.stricting the Stepan and Sears properties to non­

residential use.

Further, Uie human health risks identified were primarily related to groundwater use. There is no cuixent or future groundwater use expected in the vicinity of the Site. Potable water to the Site and surrounding area, including businesse.s and residents, is supplied by the United Water of

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New Jersey. No one in the vicinity of the Site uses groundwater as a drinking water source. Further, the Corps' ROD for FUSRAP groundwater requires groundwater use restrictions.

4.2,3 Gypsum Area

The FS identifies the following COCs for the GA: benzo(a)anlltracene, bcnzo(a)pyrene, benzo(a)fluoroanthcne, dibcnzo(a,h)anthrdcene, indcno(l,2,3-cd)pyrenc. lead, mercury, arsenic, barium, chromium, and cyanide. EPA based its RAOs on tlie impact to groundwater by the COCs. However, there is no basis to identify any COCs in groundwater at the GA and further no basis to identify some of these COCs in soil either.

- Benzo(a)antliraccne, benzo(a)pyrene, benzo(a)tluoroanthene, diben7.o(a,h)anthracenc, indeno(l,2,3-cd)pyrene and lead are routinely associated with fill material placed in the region, were not detected in any groundwater samples, and are not associated with the gypsum material.

- Mercury is retained as COC based on an "estimated" detection in one sample. The exceedanee is minimal, its concentration can only be estimated, and the single detection indicates that mercury is not a significant contaminant. Mercury is not even associated with the gypsum material. Accordingly, like EPA's treatment of mercury in the CTFA, mercury should not be retained as a COC in the GA.

- Arsenic, barium, and chromium, are commonly found in fill material in New Jersey, and none of these metals were detected above MCLs in groundwater samples.

- Cyanide is the identified contaminant associated with the gypsum waste; consequently, its potential migration was extensively evaluated as part of the groundwater R1 and FS. Data developed in that evaluation demonstrated that residual cyanide in the waste material is not mobile and does not present a risk to groundwater, human health or the environment. In fact, groundwater samples collected in 1993 and 2006 show cyanide concentrations below the NJDEP Class II aquifer criterion and the EPA MCL,

While the exact date when the materiiil at issue in the GA was deposited is not known, the operations of Citro Chemical Company that generated the material date back to the first half of the last century {i.e., prior to 1950).® Nevertheless, there is no demonstrated impact from this material to groundwater over all that time. Accordingly, since site-specific data support that there is no impact to groundwater from the material, the remedial action objective for the G.A should be to eliminate the direct contact pathway, which can be accomplished through implementation of institutional controLs, alternative GA-2.

Moreover, contrary to the FS statement, ICs to be implemented under GA-2 would meet ARARs. The gypsum material has been in place for decades and is not a source of groundwater contamination. Groundwater results for all COCs identified by EPA are below the NJDEP Class

® As the Proposed Plan notes, contamination in this area is the responsibility oF other parties.

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II aquifer criteria and EPA MCLs. Therefore, there is no technical or scientific basis for the statement that the gypsum material will continue to potentially leach contaminants into the groundwater. ICs, enacted under GA-2, would prohibit residential use and intrusive activities and would therefore eliminate exposure to contaminants that exceed chemicaJ-specific ARARs.

In addition, the presence of wetland on the DcSaussure property furtlicr supports the selection of alternative GA-2. The FS states that wetlands may be disturbed during soil remediation of llie GA. EPA should consider the negative effects of remediating the wetlands versus leaving them in place based on the minor impacts that have been identified.

4.2.4 Leather Material Area

The FS concludes that capping the LMA witli ICs, LM A-3, provides protection of human health and the environment and addresses the risk of impact to groundwater.

LMA-3 [capping] provides overall protection of human health by providing a cover that will eliminate direct contact of leather material and soils contaminated above PRGs. An asphalt cap will be used to reduce infiltration in tueas of LMA-A and LMA-B where contaminated soil will remain above the groundwater table. This will reduce tlic potential for leaching contaminants from these areas into the groundwater. Because contaminated soils will remain on Site, institutional controls will be implemented to restrict future development of the Site to non­residential uses and limit activities in the area where contaminated soil and material remains.

ITiis is the same basis for no further action (except for cap inspection and maintenance) proposed in Alternative LMA-4 for the 29% of LMA-A and 78% of LMA-B that were partially excavated and capped as part of the FUSRAP remedy. The same logic should apply to the remainder of the LMA. It is unnecessary and inconsistent to require removal of the materials remaining in areas of the LMA which were not subject to FUSRAP remediation.

On page 6-43 of the FS, reference is made to historical data which "indicate that hexavalent chromium may be present" in the LMA. The chromium associated with the leather material (leather scrap and filter cake) is in its trivalent fonn, which exhibits low toxicity (NJDEP residential soil cleanup criterion of 120,000 mg/kg) and is not water soluble. The more toxic atid soluble hexavalent form of chromium was only reported as "estimated," below the method detection limit in three soil samples from the LMA, ranging from 0.30 to 0.52 mg/kg. These J-flaggcd (estimated) values are well below any NJDEP soil cleanup criteria (lowest value 20 mgd<g), and there is no basis to anticipate

that any chromium PRG is exceeded in the LM.A.

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Further, Maywood Chemical Company initiated the Lameponc process for extracting wetting agents gentle to the skin from leather scrap around 1938. Alter 75 years of process residues being present at the Site, there is no identified impact of concern to groundwater at the LMA in either overburden or bedrock monitoring wells. The overburden groundwater analytical results for the LMA indicate that no chromium is present at levels exceeding groundwater NJDEP and EPA MCLs of 70 and 100 ug/L., respectively. Only one overburden well at the site, OBMW-iS, exhibited a concentration above the drinking water standards; this well is not located near the LMA and is hydraulically upgradient. The bedrock groundwater analytical results for the LMA also indicate that no chromium is present at levels exceeding groundwater NJDEP and EPA MCLs. Three bedrock wells at the site, B38W05B, BRMW-6, and BRMW-9, exhibited concentrations above the drinking water standards; these wells are not located near the LMA. Based on the most recent overburden and bedrock gi-oundwater sample results, tiicrc is no currcni groundwater risk from chromium. Tlie remaining inorganic compounds detected above MCLs are not associated with tlie leather material raw material or processing and are not a)n.sidercd risk drivers in tlie LMA.

In the Comparison of Remedial Alternatives section of the FS for the LMA, there are no substantive differences identified between capping (LMA-3) and excavation (LMA-4) except that excavation would have the greatest impact to workers and the community and cost nearly four times that of the capping alternative. FS pages 6-52 and 6-53 and Table 6-9. Nevertheless, excavation was inexplicably selected as the preferred aJtemalive. ITiis selection is inconsistent with the application of the criteria for remedy selection in the NCP. The proper application of NCP criteria favors the selection of LMA-3.

4.3 It is not technically defensible to address soil contamination separate from groundwater contamination in the CTFA and FAA.

4.3.1 Background

The COCs in the soils and overburden groundwater in the CTFA and FAA are identical, and are limited to BTEX compounds. Groundwater within the overburden material at the Site is generally 5 to 10 feet below grade. Given these circumstances, it does not make sense and is impracticable to address only soil while not addressing groundwater simply because EPA has separated the FS into two parts - soil and groundwater. In fact, if EPA is separating the FS into two operable units, to be practical, EPA should consider soil and overburden groundwater in one FS and bedrock groundwater in the second FS.

Over the years, Siepan has submitted a number of FS reports to EPA. In October 2000, Stepan submitted its first FS, which addressed both soil and groundwater. In June 2001, EPA asked Stepan to divide the FS into two operable units: soil and groundwater. Stepan submitted FS drafts addressing soil in September 2001, January 2002, and September 2002. Stepan submitted

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its FS for groundwater in June 2003. In March 2008, EPA requested that Stepan recombine the FS into one document for soil and groundwater. Stepan did so, and submitted the combined draft FS in 2010. In January 2013, EPA advised Stepan it was again separating the FS into two operable units. In doing so, EPA has not appropriately considered that, because of the nature of the contamination in the CI'FA and FAA and the geology and hydrogeology at the Site, it is technically impracticable to address tJie .soil and groundwater separately in the CTFA and FAA, and the division into operable units is unjustified at this Site.

4.3.2 TcchniealJustification

The sources of contamination in the FAA and CTFA have been removed, and no significant ongoing sources to groundwater remain. Further, BTEX readily degrades through natuial attenuation in both soil and groundwater. In fact, a comparison of the historical and recent groundwater data in FAA and CTFA overburden wells indicates that, with a single exception, VOC concentrations in the overburden groundwater are diminishing. Therefore, there is no need to rush to address tlie soil before groundwater in citlier the FAA or the CTFA.

Furtlier, the proposed remedy for the FAA is not practical. SVE is generally not appropriate for sites with a groundwater table located near the land surface. See EPA, How to Evaluate Alternative Cleanup Technologies for Underground Storage Tank Sites: A Guide for Corrective Action Plan Reviewers (EPA 510-B-95-007), at Il-l 0, available at http://www.eDa.eQv/oust/cat/sve 1 .htm. Special considerations must be taken for sites with a groundwater table located less tlian 10 feet below the land surface because groundwater upvvelling can occur within SVE wells under vacuum pressures, potentially occluding well screens and reducing or eliminating vacuum-induced soil vapor flow. See id. .Many of the technologies typically considered for a combination of shallow soil and groundwater impacts, e.g., Enhmced Fluid Recovery (EFR) and Dual Phase Vacuum Extraction, are designed for exactly this type of situation. See id.

In addition, the CTFA and FAA are located witliin the operating footprint of the Stepan lacility. While Stepan acknowledges that its operations will need to accommodate the remedial actions in these areas, to address soils now and potentially later install another sy.stcm to address groundwater will be doubly disruptive. This is particularly true where, as set forth above, there is no technical reason to remediate soil and groundwater separately, but, rather, reasons to remediation tlicm together.

4.3.3 Consistency with NCP

The NCP recognizes that sites should be remediated in operable units when early actions are necessary or appropriate to quickly achieve significant risk reduction, when phased analysis and response is necessary or appropriate given the size or complexity of the site, or to expedite completion of total site cleanup. 40 C.F.R. §300.430(a)9(l)(ii)(A). None of these conditions are present here. 'Hie R1 was completed almo.st 20 years ago. Certainly EPA cannot maintain that it

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is seeking early action. The site is not large or complex. The CTFA and FAA ai'C small geographically. The remedies are simple: excavation is simply mechanical and SVE is an EPA presumptive remedy'®. Further, not combining the soil pd groundwater remedies delays total site cleanup rather than expedites it. Accordingly, not addressing both the soil and groundwater concurrently in tliese two AOCs is inconsistent with the NCP and the extensive information available both thimigh the Record and otiierwise in dhs proceeding.

4.4 There is no rational purpose for air knife excavation.

EPA's inclusion of air knife excavation in connection with the in-situ ERF and SVE remedies in the FAA and CTFA is unnecessary. EPA contends that air knife excavation is required to ensure remediation of soil around utilities. In reality, however, the in-situ technologies will likely be very effective around utilities, and the air knife technique is likely to cause increased exposure risk.

Utilities typically arc embedded in material that is more permeable than the surrounding native soil. This more permeable material will more readily tran.smit soil vapors to the extraction points, making that material amenable to remediation by either SVE or EFR, If the concern is that the more permeable material will short-circuit the system and detrimentally impact treatment of other areas, air knife excavation is not the solution. SVE systems are regularly designed to avoid the short-circuiting that can be caused by low-resi.stance pathways. See, e.g., USEPA, Engineering Forum Issue Paper: Soil Vapor Extraction Implementation Experiences, EPA 540/F-95/030 (January 1997), available at http://www.ena.gov/supcrfimd/remedvtech/tst3/download/svcissue.pdf. Further, excavation and backfill would provide additional low resistance patliways as more soil will be non-native and non-homogeneous. It is, therefore, more sensible to conduct the in-situ remedy without excavation. At a minimum, pilot testing should be completed first. Excavation should be included, if at all, as a contingency remedy.

In addition, the air knife technique is inappropriate to u.se for soil contaminated with volatile organic compounds at an active facility. "The air knife excavation method uses a high velocity air lance to inject an air stream into the pores and fissures of the soils to blast the compacted soil apart." See Proposed Plan at 10. In addition to loosening the soil for removal, the intended re.sult, it will also volatilize the contaminants, resulting in increased risk to remedial action contractors and Stepan employees. The presence of this increased risk further undermines EPA's

See USEPA, Presumptive Remedies: Policies and Procedures, available at http://wwvv.epa.aov/superriind/policv/rcmedv/presuinp/pol.htiTi ("Presumptive Remedies are preferred technologies for common categories of sites, based on historical patterns of remedy selection and EPA's scientific and engineering evaluation of performance data on technology implementation. EPA has evaluated technologies that have been consi.stently selected at past sites using the remedy selection criteria set out in tiie [NCP); reviewed currently available performance data on the application of these technologies; and has determined that a particular remedy, or set of remedies, is presumptively the most appropriate for addressing specific types of sites.").

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inclusion of the air knife method in the remedies evaluated for the FA A and CFTA, and the preferred remedy for the FAA.

5. CONCLUSION

As detailed above, EPA's FS and Proposed Plan improperly characterize various aspects of the remedies considered, fail to evaluate alt relevant data, and do not provide a rational connection between the facts and the remedies proposed. These substantial flaws have resulted in the proposal of remedies that are inconsistent with the NCP and enviromnental conditions at the Site. Accordingly, tire proposed remedial actions must be reconsidered in accordance with the comments presented herein.

Stepan respectfully requests that EPA re-evaluate its proposed remedies to take into account the extensive remediation the Corps has already completed. Both the cost estimates and specific remedy selection merit further consideration. Stepan believes that the relevant data and information from that remediation supports tlie remedies that Stepan has previously proposed. Stepan also believes it is important for it to work with the relevant government agencies to permit termination of the NRC license at the Site, which would reduce community and environmental impacts from appropriately adopted remediation methods. Absent such termination, the current status of the license must remain an important factor in remedy selection. Finally, the EPA should review the other issues raised in Stepan's comments so that the remedies selected will best comply with applicable law and regulatory standards.

DB1/76842102.1

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1

From: Donovan, BetsySent: Wednesday, September 04, 2013 12:41 PMTo: 'Brian Mascis'Cc: 'Gaffigan, Donna'Subject: RE: maywood superfund siteAttachments: M-0226 (2).pdf

Dear Mr. Mascis, Donna Gaffigan sent me the following message. In response, I have attached the report which includes the investigation work conducted at the Maywood Municipal Pool as part of Maywood Chemical Company Superfund site. The report found no evidence of radioactive contamination associated with the Maywood Chemical Company Superfund site at the pool property. As I mentioned, this report also has information about 19 other municipal properties. If you have any additional questions, please contact me. Thank you, Betsy Donovan Project Manager

From: Gaffigan, Donna [mailto:Donna.Gaffigan@dep.state.nj.us] Sent: Friday, August 30, 2013 5:15 PM To: 'Brian Mascis' Cc: Donovan, Betsy Subject: RE: maywood superfund site Dear Mr. Mascis, Thank you for your questions regarding the Maywood Chemical Superfund Site. The Department works closely with the United States Environmental Protection Agency on the investigation and cleanup of Superfund Sites. By copy of this email, I will request that Ms. Donovan forward the report that includes the data she cited. The Department agreed that no further investigation was warranted for the Maywood Municipal Swim Pool in relation to the Maywood Chemical Co. Superfund Site. If you have any additional questions, please feel free to contact me. -D Donna L Gaffigan, Case Manager NJDEP, Bureau of Case Management Mail Code 401-05F P O Box 420 (US Mail) 401 East State Street, 5th floor (Package Delivery) Trenton, NJ 08625-0420 609 633 1494 

From: Brian Mascis [mailto:bmascis1@optonline.net] Sent: Tuesday, August 27, 2013 5:51 PM To: Gaffigan, Donna Subject: Fwd: maywood superfund site Hi - i wrote to Ms. Donovan regarding the superfund site. I have some concerns given time my family and I spent at the maywood municipal pool in the 1980s. Should I have any concerns? Can we see the results of the

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tests that were performed as well as the testing locations in relation to the site? I assume that is public information. Is your understanding of the results consistent with Ms. Donovan's? Sincerely, Brian Mascis Sent from my iPhone Begin forwarded message:

From: "Donovan, Betsy" <Donovan.Betsy@epa.gov> Date: August 27, 2013, 4:04:32 PM EDT To: Brian Mascis <bmascis1@optonline.net> Subject: RE: maywood superfund site

Dear Mr. Mascis, Thank you for your inquiry about the Maywood Chemical Co. Superfund site. The Maywood Municipal Pool property was tested in 1987 and no evidence of radioactive contamination was found. This property and 19 other municipal properties were investigated by the US Department of Energy as part of the Maywood Superfund site investigation work. The pool property located on Brook Avenue is north of the former Maywood Chemical Works property and would be considered up gradient, because surface and groundwater in the area typically flow to the south/southwest. Based on test results and the geographic location of the property, no further investigation was warranted in relation to the Maywood Chemical Co. Superfund site. The New Jersey Department of Environmental Protection (NJDEP) has the lead role at other sites in the area and you may want to contact my NJDEP counterpart Donna Gaffigan at 201-633- 1494 or Donna.Gaffigan@dep.state.nj.us Sincerely, Betsy Donovan -----Original Message----- From: Brian Mascis [mailto:bmascis1@optonline.net] Sent: Friday, August 23, 2013 7:37 PM To: Donovan, Betsy; oneillj@northjersey.com Subject: maywood superfund site I was recently reading an article in bergen record about this ("Maywood_Chemical_Co_Superfund_site_to_get_17_million_cleanup"). In the 1980s, my family belonged to the Maywood Swim Club for several years. I believe the swim club was and/or is adjacent to this site. Has anyone ever tested the swim club area? Was it down gradient from the superfund site? Should there be any concerns about being exposed? Thanks Brian Mascis

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- Formerly Utilized Sites Remedial Action .Program (FUSRAP)

- ABMIN ISTR

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- for Maywood, New Jersey

U.S. Department of Energy

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OAK RIDGE NATIONAL LABORATORY

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ORIWRASA-!W4

RESULT OF RADIOLOGICAL SURVEYS OF.20

BOROUGH-OWNED PROPERTIES MAYWOOD, NEW JERSEY

(MJOSO)

R. D. Foley R. F. Carrier

OPERATED BY MARTIN MARIETTA ENERGY SYSTEMS, INC.

t FOR THE UNITED STATES

. . DEPARTMENT OF ENERGY

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ORNURASA-!W4

HEALTH AND SAFETY RESEARCH DMSION

Waste Management Research and Development Programs (Activity No. AH 10 05 00 0; NEAHOOl)

RESULT’S OF RADIOLOGICAL SURVEYS OF 20 BOROUGH-OWNED PROPERTIES

MAYWOOD, NEWJERSEY @JO%)

R. D. Foley and R. F. Carrier

Date of issue - August 1990

Investigation Team

R. E. Swaja - Measurement Applications and Development Manager W. D. Cottrell - FUSRAP Project Director

R. D. Foley - Survey Team Leader

Work performed by the MEASUREMENT APPLJCATIONS AND DEVELOPMENT GROUP

Prepared by the OAK RIDGE NATIONAL LABORATORY

Oak Ridge, Tennessee 378316285 operated by

MARTIN MAREITA ENERGY SYSTEMS, INC. for the

U. S. DECPARTAENT OF ENERGY under contract DE-ACO5840R21400

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COIvTENls

LISTOFFIGURES ............................................. .

LISTOFTABLES .............................................. .

ACKNOWLEDGMENTS ........................................ vii

ABSTRACT .................................................. ix

INTRODUCTION .............................................. .

SURVEYMETHODS ........................................... .

SURVEYREWJLTS ............................................ .

SIGNIFICANCE OF FINDINGS .................................. .2

REFERENCES.. ............................................... .

. . . 111

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LIST OF FIGURES

1 Diagram showing locations of 20 borough-owned properties, Maywood,NewJersey.............................................4

LIST OF TABLES

1 Results of gamma exposure rate measurements at 20 borough- owned properties in Maywood, New Jersey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

V

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ACKNOWLEDGhENTS

Research for this project was sponsored by the U. S. Department of Energy’s Office of Environmental Restoration under contract DE-AC05-S40R21400 with Martin Marietta Energy Systems, Inc. The authors wish to acknowledge the contributions of D. A Roberts and P. F. Tiner of the Measurement Applications and Development Croup, and A C. Butler and M. E. Ward of D. R. Stone & Associates, Inc. for their participation in the collection, analyses, and reporting of data for this survey.

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A

Maywood Chemical Works (MCW) of Maywood, New Jersey, generated process wastes and residues associated with the production and refining of thorium and thorium compounds from monazite ores from 1916 to 1956. MCW supplied rare earth metals and thorium compounds to the Atomic Energy Commission and various other government agencies from the late 1940s to the mid-1950s. Area residents used the sandlike waste from this thorium extraction process mixed with tea and cocoa leaves as mulch in their yards. Some of these contaminated wastes were also eroded from the site into Lodi Brook. At the request of the U.S. Department of Energy (DOE), a group from Oak Ridge National Laboratory conducts investigative radiological surveys of properties in the vicinity of MCW to determine whether a property is contaminated with radioactive residues, principally =%h, derived from the MCW site. The survey typically includes direct measurement of gamma radiation levels and soil sampling for radionuclide analyses. The survey of these 20 borough-owned properties Maywood, New Jersey, was conducted during 1987.

Survey measurements indicate that none of the properties contained radioactive contamination. Slightly elevated gamma exposure rates in several areas were related to the presence of ashes or to natural materials used in the construction of buildings and asphalt surfaces.

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RESULTS OF RADIOLLKXAL, SURVJZYS OF 20 BOROUGH-OWNED PROPERTIES, MAYWOOD, NEW JERSEY (M.l050)*

From 1916 to 1956, process wastes and residues associated with the production and refining of thorium and thorium compounds from monazite ores were generated by the Maywood Chemical Works (MCW), Maywood, New Jersey. During the latter part of this period, MCW supplied rare earth metals and thorium compounds to various government agencies. In the 1940s and 195Os, MCW produced thorium and lithium, under contract, for the Atomic Energy Commission (AEC). These activities ceased in 1956, and approximately three years later the 30 acres of real estate was purchased by the Stepan Company. The property is located at 100 Hunter Avenue in a highly developed area in Maywood and Rochelle Park, Bergen County, New Jersey.

During the early years of operation, MCW stored wastes and residues in low-lying areas west of the processing facilities. In the early 193Ck, these areas were separated from the rest of the property by the construction of New Jersey State Highway 17. The Stepan property, including the interim storage facility, and several vicinity properties have been designated for remedial action by the Department of Energy (DOE).

The waste produced by the thorium extraction process was asandlike material containing residual amounts of thorium and its decay products, with smaller quantities of uranium and its decay products. During the years 1928 and 1944 to 1946, area residents used these process wastes mixed with tea and cocoa leaves as mulch in their lawns and gardens. In addition, some of the contaminated wastes were apparently eroded from the site into Lodi Brook and carried downstream.

As a result of the Energy and Water Appropriations Act of Fiscal Year 1984, the properties discussed in this report and properties in their vicinity contaminated with residues from the former MCW, were included as a decontamination research and development project under the DOE Formerly Utilized Sites Remedial Action Program. As part of this project, DOE is conducting radiological surveys in the vicinity of the site to identify properties contaminated with residues derived from MCW. The principal radionuclide of concern is 2%X. The radiological surveys discussed in this report are part of that effort and were conducted, at the request of DOE, by members of the Measurement Applications and Development Group of the Oak Ridge National Laboratory.

This report describes the results of surveys conducted in April 1987 of 20 public properties owned by the Borough of Maywood. Two other properties owned by the Borough, the West Hunter Avenue Firehall and Grant Avenue Memorial Park, were also surveyed. The results are reported elsewhere.lm2

*The survey was performed by members of the Measurement Applications and Development Group of the Health and Safety Research Division of Oak Ridge National Laboratory under DOE contract DE-ACO54340R21400.

1

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SURVEY MEXHODS

The radiological survey consisted of a gamma scan at the ground surface over the entire outdoor property using a portable gamma scintillation meter. No indoor survey measurements were performed. The survey procedures followed a plan proposed in 19&L3 A comprehen- sive description of the survey methods and instrumentation has been presented in another reporL4

_

SURVEY REsJLx4 --*

Figure 1 shows the locations of the borough-owned properties, each of which was arbitrarily assigned a number from 1 to 20 as shown in Table 1.

The gamma exposure rates measured during the surveys of the 20 properties ranged from 4 to 20 @/h (Table 1). Slightly elevated measurements were observed in small, localized areas on most of the properties. In every case, these anomalies were associated either with an ashy material apparently derived from coal or with brick or asphalt surfaces. The maximum gamma exposure rate found during the surveys, 20 $X/h, was measured near the surface of an asphalt parking lot (property 14). These anomalies do not appear to be caused by material from the MCW site. Rather, they may be attributed to naturally occurring radioactive substances present in both the ashes and the construction materials used for brick and asphalt structures. Coal ashes often contain elevated radiation levels due to concentra- tion of naturally radioactive materials in coal during combustion. Many natural substances such as these typically exhibit elevated gamma exposure rates when compared to surrounding soils.

SIGNIFICANCE OF FINDINGS

No evidence for radioactive contamination was discovered on any of the 20 borough+xvned properties. Slightly elevated gamma exposure rates in several areas were related to the presence of ashes or to natural materials used in the construction of buildings and asphalt surfaces.

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REFERENCES

1. R. D. Foley and L. M. Floyd, Results of the Radiological Survey at West Hunter Avenue Firehall, Maywood, New Jersey (MJO37), 0 RNIdRASA48l32 (M.JO27).

2. R. D. Foley, J. W. Crutcher, R. F. Carrier, and L. M. Floyd, Results of the-Radiological Survey at Grant Avenue Memorial Park (MJO28), Maywood, New Jersey, ORNLIRASA- 88/Z (February 1989).

3. W. D. Cottrell, ORAL, to A. J. Whitman, DOE/HQ, correspondence, “Radiological Survey of Private Properties in Lodi, New Jersey” (August 15,1984).

4. T. E. Myrick, B. A. Berven, W. D. Cottrell, W. A. Goldsmith, and F. F. Haywood, Procedures Manual for the ORNL Radiological Survey Activities (RASA) Program, Oak Ridge National Laboratory, ORNLKM-8600 (April 1987).

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Table 1. Results of gamma exposure rate measurements at 20 borough-owned properties in Maywood, New Jersey

Location Property/ (Fie. 1) Address

Range of gamma Average and/or exposure rates anomalous gamma

found during scan exposure rates ww .(Pw

1

2

Pumping Station Spring Valley Ave.

(Block 1, Lot 6)

Memorial School 764 Grant Ave.

(Block 43, Lot 1)

5-15

5-12

Property averaged 5-10; maximum of 15 found on steps due to bricks that often show slightly elevated levels from naturally radioactive constituents

Property averaged S-10; maximum of 12 on bldg. brick; all readings within typical background for the area

5

Public Library/ Municipal Office

459 Maywood Ave. (Block 144, Lots 5-12,23-29)

Maywood Avenue School 425 Maywood Ave. (Block 145, Lot 1)

Municipal Pool-Brook Ave. (Block 160, Lot 1)

6-12

S-15

5-11

6 Public Safety Bldg. & Parking areas 5-12 All readings within typical 15 Park Ave. background for the area

(Block 101, Lots lo-13,20-22)

Dept. of Public Works Garage 205 E. Hunter Ave. (Block 187, Lot 4)

Pistol Range - E. Hunter Ave. (Block 187B, Lot 3)

5-10

7-18

Property averaged 5-10; all readings within typical background for the area

Property averaged 7-12; localized coal ashes at maxi- mum gamma

Property averaged 6-10; maximum of 12 on bldg.brick; all readings within typical background for the area

Property averaged 5-12; 15 on bldg. brick

Pool area, including play area outside fence at entrance averaged 5-10; average for parking lot serving pool was 7-10; all readings within typi- cal background for the area

i \-

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Table 1 (continued)

mtion Property/ (Fig. 1) Address

Range of gamma Average and/or exposure rates anomalous gamma

found during scan exposure rates ww (PEW

9

10

11

12 Duvier Park - Duvier Place (Block 163, Lots 13-19)

13 Parking Lot - Albert St. (Block 108, Lots 30,32,34)

14 Parking Lot Maywood Ave. & Passaic St.

(Block 117, Lots 1,5, 6, 7, 61)

15 Vacant Land Thoma Ave. & Maple Lane

(Block 150, Lots 1,3,4,5)

16 Vacant Land

17

18

Playground & School Parking Lot, Fairmount Ave. (Block 46A-47A, Lot l-1A)

Fetzer Park Cedar & Locust Awes.

(Block 15, Lot 10)

Grove Avenue Park Grove Ave.

(Block 100, Lots 13-19)

Brook Ave. & Magnolia lane (Block 169, Lots 6-9, 12-15)

Vacant Land Duvier Place & Magnolia Lane (Block 169A, Lots 2-5&4,5B)

Vacant Land (off Frontage) Central Ave. & Hergesell

(Block 174, Lots 13B,l4B,15B,16B,17B,lSC)

4-10

5-10

5-15

7-11

5-11

5-20

7-15

6-11

6-14

7-17

Property, including parking lot averaged 4-10; playground ball field averaged 5-10; all readings within typical background for the area

Property averaged 5-10; all readings within typical background for the area

Property averaged 5-11; evidence of coal ashes in 3 locations

Property averaged 7-9; all readings within typical background for the area

Property averaged 5-6; 11 on asphalt patch

4

3.

Property averaged 5-6; spots of 20 at coal ashes

3:

Property averaged 7-15; maximum at coal ashes in several areas

Property averaged 6-9; all levels within typical back- ground for the area -.

Property averaged 6-10; one spot of 14

Property averaged 7-10; several areas at maximum had coal ashes; large areas inaccessible due to trash

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Table 1 (continued)

Location 0%. 1)

19

Property/ Address

Vacant Land - Ward St. (Block 202, Lot 9)

Range of gamma Average and/or exposure rates anomalous gamma

found during scan exposure rates ww ww 5-10 Property averaged 5-10; all

readings within typical background for the area

20 Vacant Land - Brookdale St. (Block 202, Lot 25)

6-14 Property averaged 6-10; maximum of 14 on bank of Cole’s Brook

i.

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1. B. A. Berven 2-4. R. F. Carrier

5. W. D. Cottrell 6. A. G. Croff 7. J. W. Crutcher

8-12. R. D. Foley 13. L. M. Floyd

INTERNALDISTRIBUTION

14. S. V. Kaye 15. P. T. Owen

16-18. R. E. Swaja 19. J. K. Williams 20. Laboratory Records - RC 21. Central Research Library 22. Y-12 Technical Library

l3XTERNAL DISTRII3UTION

23. J. D. Berger, Oak Ridge Associated Universities, E/SH Division, Environmental survey and Site Assessment Program, P.O. Box 117, Oak Ridge, TN 37831

24. R. W. Doane, TMA/Eberline, Inc., 795A Oak Ridge Turnpike, Oak Ridge, TN 37831

25-27. J. J. Fiore, U.S. Department of Energy, Office of Environmental Restoration Br Waste Management, Decontamination and Decom- missioning Division (EM-423), Washington DC 20545

28-30. G. K Hovey, Bechtel National, Inc., 800 Oak Ridge Turnpike, P-0. Box 350, Oak Ridge, TN 37831

31. L.. R. Levis, Roy F. Weston, Inc.,‘20030 Century Blvd., Germantown, MD 20874

32-34. L. K Price, U.S. Department of Energy, Technical Services Division, Oak Ridge Operations, Bldg. 2714H, Oak Ridge, Tennessee 37831

35. J. W. Wagoner, U.S. Department of Energy, Office of Environmen- tal Restoration & Waste Management, Decontamination and Decommissioning Division (EM-423), Washington DC 20545

36. Office of Assistant Manager, Energy Research and Development, Oak Ridge Operations Office, P.O. Box 2001, Oak Ridge, TN 37831-8600

37-38. Office of Scientific and Technical Information, DOE, P.O. Box 62, Oak Ridge, TN 37831

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From: Donovan, BetsySent: Wednesday, August 28, 2013 10:14 AMTo: 'Shatin, Dianne'Cc: 'Donna.Gaffigan@dep.state.nj.us'Subject: RE: Maywood Chemical Cleanup, Superfund Site

Dear Ms. Shatin, Thank you for your message regarding the Maywood Chemical Co. Superfund site. The site was listed on EPA’s National Priorities List in 1983. Site cleanup work began in 1984 by the U.S. Department of Energy (DOE) and continues today, under the U.S. Army Corps of Engineers (USACE) management. Congress assigned responsibility for the site cleanup to DOE in 1984 and then transferred management of the site cleanup to the USACE in 1997. A chemical company is also responsible for specific chemical contamination that is attributed to former manufacturing activities at the site. All cleanup work is being implemented under EPA and NJDEP oversight, pursuant to the Comprehensive Environmental Response, Compensation and Liability Act or Superfund. To date, remedies have been selected for the soils and groundwater that address contamination associated with DOE activities and more than 400,000 cubic yards of radiologically-contaminated soil have been removed from the site for disposal in regulated landfills, at a cost of more than $500 million. The proposed plan issued on Friday August 23rd is one of several cleanup plans that address a variety of both chemical and radiological contamination at the site. The USACE has a website with a great deal of information about this project at http://fusrapmaywood.com/whatsnew.htm and EPA also has a website with project information at http://epa.gov/region02/superfund/npl/maywood/ Donna Gaffigan, one your colleagues at NJDEP’s Bureau of Case Management, is the case manager and has overseen the site for many years. You may want to contact Donna at Donna.Gaffigan@dep.state.nj.us or 201-633-1494 for further information. Please feel free to contact me with any questions. Sincerely, Betsy Donovan Project Manager

From: Shatin, Dianne [mailto:Dianne.Shatin@dep.state.nj.us] Sent: Monday, August 26, 2013 3:41 PM To: Donovan, Betsy Cc: Shatin, Dianne Subject: Maywood Chemical Cleanup, Superfund Site Ms. Donovan~ I am a staff person at NJDEP and interested to find out why it has taken 17 years for USEPA begin the site cleanup at the former Maywood Chemical site. Isn’t $17 million a fairly staggering figure for the cleanup? I do understand the complexities and time involved as well as the inordinate number of sites the agency is charged with cleaning up, however, given the high population density, contamination of ground water, and presence of radioactive isotopes at the old Maywood site, is there another reason that might explain why it has taken so long to get to the Maywood Chemical cleanup?

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Thank you so much. D. Shatin DianneShatin,EnvironmentalScientist2NewJerseyDepartmentofEnvironmentalProtectionDivisionofWaterMonitoringandStandardsBureauofEnvironmentalAnalysisandRestoration401EastStateSt.P.O.Box401‐04iTrenton,NJ08625‐0420TelephoneNo.:(609)777‐1405Fax:(609)984‐6505Dianne.Shatin@dep.state.nj.us

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From: Donovan, BetsySent: Wednesday, September 25, 2013 11:41 AMTo: 'Mignano, Tom'Cc: 'Moore, James T NAN02'; 'William.Kollar@CBIFederalServices.com'Subject: RE: EPA Proposes Plan to Address Contaminated Soils and Ground Water at Maywood

Chemical Company Superfund Site in Maywood and Rochelle Park, New Jersey

Hi Tom,  Thank you for your inquiry about the Maywood Chemical Company Superfund Site. The Proposed Plan recently released by EPA for part of the Maywood Chemical Company Superfund Site addresses soil contamination on several commercial properties in Maywood and Rochelle Park.  The site cleanup work is being done in phases and other cleanup plans for the site include additional properties, both residential and commercial, in Maywood, Rochelle Park and Lodi; the U.S. Army Corps of Engineers currently  manages those plans.  A number of residential properties have been investigated and some required cleanup work. More information on that work can be found at the USACE Maywood website http://fusrapmaywood.com/index.asp and there is an information center located in Maywood (details are also on the website). The USACE project manager is Jim Moore James.T.Moore@usace.army.mil and the Community Relations contact person is Bill Kollar ‐ William.Kollar@CBIFederalServices.com .  Please feel free to contact them with your questions about a particular residential property. If you have any questions about the recently released Proposed Plan please contact me.  Sincerely, Betsy Donovan Project Manager    

From: Mignano, Tom [mailto:TMignano@sca.shiseido.com] Sent: Wednesday, September 11, 2013 1:19 PM To: Donovan, Betsy Subject: EPA Proposes Plan to Address Contaminated Soils and Ground Water at Maywood Chemical Company Superfund Site in Maywood and Rochelle Park, New Jersey  Hi Betsy,  I got your name from an email with a similar subject.  I am a Maywood resident living close to the site and have lived here for about 10 years.  What has been done about checking the soil in the homes  surrounding the area. Are there reports available for that?    Thanks  Tom  

Thomas L Mignano Director ‐ Enterprise Reporting and Helpdesk Shiseido Americas Corporation 178 Bauer Drive Oakland, NJ 07436  Phone: 212 805 2351  Cell: 201 927 7052 tmignano@sca.shiseido.com 

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From: Eustace, Asm. D.O. <AsmEustace@njleg.org>Sent: Friday, November 22, 2013 4:50 PMTo: Donovan, BetsySubject: Maywood Company Superfund siteAttachments: Superfund Site Letter.docx

Follow Up Flag: Follow upFlag Status: Flagged

Betsy Donovan Remedial Project Manager 290 Broadway, 19th Floor New York, New York 10007-1866 November 15, 2013 Dear Ms. Donovan, RE: Maywood Chemical Company Superfund Site Thank you for allowing the public to comment on a project that will have many benefits to the Borough of Maywood and the surrounding area. I welcome the EPA’s $17 million investment in cleaning the Maywood Chemical Company Superfund Site and we greatly appreciate the work that has been already completed. However, the underutilization of this area is a burden for taxpayers. I believe it would be a great service for my neighbors to know when this project will be completed. This area has been a blight for long enough and after 30 years we need to know that there is light at the end of the tunnel. In addition, concerns have been brought to my attention regarding possible emergency situations. In such cases like water main breaks or sewage line problems how will the EPA respond. It is my hope that there are emergency precautions in place so that contamination stays contained and possible problems are mitigated. I look forward to your response. Respectfully,

Dr. Timothy J. Eustace, DC Assemblyman, 38th District

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Betsy Donovan Remedial Project Manager 290 Broadway, 19th Floor New York, New York 10007-1866 November 15, 2013 Dear Ms. Donovan, RE: Maywood Chemical Company Superfund Site Thank you for allowing the public to comment on a project that will have many benefits to the Borough of Maywood and the surrounding area. I welcome the EPA’s $17 million investment in cleaning the Maywood Chemical Company Superfund Site and we greatly appreciate the work that has been already completed. However, the underutilization of this area is a burden for taxpayers. I believe it would be a great service for my neighbors to know when this project will be completed. This area has been a blight for long enough and after 30 years we need to know that there is light at the end of the tunnel. In addition, concerns have been brought to my attention regarding possible emergency situations. In such cases like water main breaks or sewage line problems how will the EPA respond. It is my hope that there are emergency precautions in place so that contamination stays contained and possible problems are mitigated. I look forward to your response. Respectfully, Dr. Timothy J. Eustace, DC Assemblyman, 38th District

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D c mb r4 2013

UNITED STATES ENVIRON ENTAL PROTECTION AGENCY REGION2

290 BROADWAY EWYORK, NY 10007-1866

LA MAIL

The Honorable Timoth I. u tace A emblyman 38111 District 205 Robin Road

uite 216 Paramus, J 07652

Re: Ma ood hemical Compan uperfund ite

Dear Dr. ustace:

hank you for your letter about the Ma~ ood hemical ompany uperfund ite. ln lat ugu t, the U .. En ironmental Protection Agen y EPA) released a Propo ed Plan for one of e eral cleanup action at th site and in ited the public to pro ide comment . This Plane aluat cleanup option for ch mica! contamination at three propertie : ears tepan and Maywood Furniture. All thr of the propertie ha e acti e bu ines e on the premi es. This cleanup" ork ill be undertaken after a final remedy i elected and detailed d igns are prepared during th next year.

Thi ite is undergoing a major en ironmental cleanup under the uperfund pr s at more than 88 propertie and this important work i being done in eral phase . The . . Army orps of ngineers

C ) has the lead rol for much of the cl an up ork currently being carried out under the Form rly tilized ite Remedial ction Program U RAP . The FU RAP cleanup" rk addre radioa ti

contamination " ith funding from ongre ional appropriations. This cleanup v ork represents a ignificant public benefit to the urrounding community through permanent remo al of radi acti el -

contaminated oil. It i estimated that thi work ill tak e eral more ears to complete and is d pend nt on federal funding and acce to contamination \ hich is complicated when th contamination is located under buildings and infrastructure.

Your letter mention qon tituent concerns about ad uat precautions for em rg n ituation such a wat r r er lin break . W as ure you that all cleanup con truction ork i don with extreme care and consideration ofth local community. Emergenc health and saf1 ty and monitoring plan are required to be in pia prior to and during an con truction work to en ure that contamination d not pread. ln addition cleanup contra ts require coordination and communi ation v ith appropriate local

em rgency responder o they ha e kno ledge of the ongoing work and would be prepared to respond in the e ent of an emergency.

(URL) ht!p:J/www. .gov Reeyeled/Recyelable • P 011 ecyded Pap« content)

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appr iate your int re t in the cleanup project and loo forward to continuing this ery important wor to i succ ful completion. If you ha e any qu tion please contact me at dono an.betsv@epa.go or 212-637-4369.

incerely

(;f. B Dono an Project Manager

cc: Michael

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