FINAL DRAFT OU1 FOCUSED FEASIBILITY STUDY REPORTFINAL DRAFT OU1 Focused Feasibility Study – March...

Index Number CERCLA 02-2010-2017

FINAL DRAFT

OU1 FOCUSED FEASIBILITY STUDY REPORT

SHIELDALLOY METALLURGICAL SUPERFUND SITE NEWFIELD, NEW JERSEY

TRC Job No. 112434ES

Prepared by:

TRC Environmental, Inc. 1601 Market Street, Suite 2555

Philadelphia, PA 19103

March 2015

FINAL DRAFT OU1 Focused Feasibility Study – March 2015

TABLE OF CONTENTS

SECTION PAGE 1. INTRODUCTION .................................................................................................................... 1

1.1 Regulatory Background and Site Location ......................................................................1 1.2 Report Purpose and Organization ....................................................................................2

2. SITE DESCRIPTION AND ENVIRONMENTAL HISTORY ........................................... 3

2.1 Site Description ................................................................................................................3 2.2 Summary of Historical Environmental Site Activities ....................................................4

2.2.1 Pump and Treat .....................................................................................................4 2.2.2 In Situ Remediation (ISR) ....................................................................................6

2.3 Summary of OU1 Site Investigations ..............................................................................8 2.4 Conceptual Site Model (CSM).........................................................................................9

2.4.1 Geology .................................................................................................................9 2.4.2 Hydrogeology .......................................................................................................9 2.4.3 Basic Geochemistry ............................................................................................10

2.5 Nature and Extent of Contamination .............................................................................11 2.5.1 Chromium in Groundwater .................................................................................11 2.5.2 Other Metals .......................................................................................................12 2.5.3 TCE .....................................................................................................................13 2.5.4 Other VOCs ........................................................................................................14

2.6 Summary of Baseline Risk Assessment Findings ..........................................................15 2.6.1 COPCs/Exposure Assessment ............................................................................15 2.6.2 Toxicity Assessment ...........................................................................................15 2.6.3 Risk Characterization ..........................................................................................16

2.7 Fate and Transport .........................................................................................................18

3. RAOs, ARARs, AND PRGs .................................................................................................. 20 3.1 RAOs..............................................................................................................................20 3.2 ARARs and TBC ...........................................................................................................20

3.2.1 Definition of ARARs ..........................................................................................20 3.2.2 Potential ARARs.................................................................................................22

3.2.2.1 Federal Contaminant-Specific ARARs/TBCs ...................................22 3.2.2.2 Potential State (New Jersey) Chemical-Specific ARARs/TBCs .......23

3.3 Development of Remediation Goals ..............................................................................23

i


4. GRAs, AND IDENTIFICATION AND SCREENING OF CANDIDATE REMEDIAL

TECHNOLOGIES ................................................................................................................. 24 4.1 GRAs..............................................................................................................................24 4.2 Identification of Candidate Remedial Technologies ......................................................25

4.2.1 Institutional Controls—Groundwater Use and Well Restrictions ......................26 4.2.2 Containment—Pumping .....................................................................................26 4.2.3 Removal/Treatment ............................................................................................26 4.2.4 In Situ Processes (Injections/MNA) ...................................................................26

4.3 Assumptions Affecting Remedial Alternatives .............................................................28 4.4 Screening of Candidate Remedial Technologies ...........................................................28

4.4.1 Institutional Control (CEA/WRA) ......................................................................29 4.4.2 Containment (Pumping) ......................................................................................29 4.4.3 Removal/Treatment (P&T) .................................................................................29 4.4.4 In Situ Processes (Injections/MNA) ...................................................................30

5. DEVELOPMENT, SCREENING, AND DETAILED ANALYSIS OF REMEDIAL ACTION ALTERNATIVES ................................................................................................. 31 5.1 Summary of Remedial Action Alternatives ...................................................................31

5.1.1 Alternative #1- No Action ..................................................................................32 5.1.2 Alternative #2- P&T ...........................................................................................32 5.1.3 Alternative #3- In Situ Processes (Injections/MNA) ..........................................32

5.2 Remedial Alternative Screening, Retained Remedial Alternatives ...............................36 5.3 Detailed Analysis of Remedial Alternatives ..................................................................36

5.3.1 Superfund Evaluation Criteria ............................................................................37 5.3.2 Individual Analysis of Remedial Alternatives ....................................................40

5.3.2.1 Alternative # 2– P&T .........................................................................40 5.3.2.2 Alternative # 3- In Situ Processes (Injections/MNA) ........................41

5.3.3 Comparative Analysis .........................................................................................42 5.3.3.1 Overall Protection of Human Health and the Environment ...............42 5.3.3.2 Compliance with ARARs ..................................................................42 5.3.3.3 Long Term Effectiveness ...................................................................42 5.3.3.4 Reduction in Toxicity, Mobility or Volume ......................................43 5.3.3.5 Short-Term Effectiveness ..................................................................43 5.3.3.6 Implementability ................................................................................43 5.3.3.7 Cost ....................................................................................................43

5.4 Green Remediation Principles .......................................................................................43

6. CONCLUSIONS .................................................................................................................... 45

7. REFERENCES ....................................................................................................................... 46

ii


LIST OF FIGURES

Figure No. Title

1 Site Location Map 2 Upper Total Chromium Groundwater Plume Map 3 Lower Total Chromium Groundwater Plume Map 4 Upper TCE Groundwater Plume Map 5 Lower TCE Groundwater Plume Map 6 Conceptual CPS Injection Approach

LIST OF TABLES Table No. Title

1 Detailed Analyses of Remedial Alternatives 2 Remedial Alternative #2 Cost—Pump and Treat

2a Pump and Treat NPV Analysis 3. Remedial Alternative #3 Cost—In Situ Remediation 3a In Situ Remediation NPV Analysis

iii


Index Number CERCLA 02-200-2017

FINAL DRAFT OU1 FOCUSED FEASIBILITY STUDY

SHIELDALLOY METALLURGICAL SUPERFUND SITE NEWFIELD, NEW JERSEY

1. INTRODUCTION

1.1 Regulatory Background and Site Location TRC Environmental Corporation (TRC) has prepared this Final Draft Operable Unit 1 (OU1) Focused Feasibility Study (FSS) for the Shieldalloy Metallurgical Corporation (SMC) Superfund Site (Site), located at 35 South West Boulevard, Newfield, New Jersey (Figure 1), reflective of EPA’s November 2014 Comments on the June Draft OU1 FFS, and EPA’s input to the Final Draft OU1 FFS, from January to March, 2015. A 1988 New Jersey Department of Environmental Protection (NJDEP) Administrative Consent Order (ACO) indicated that a five recovery well pump and treat system be installed and operated. A 1996 Record of Decision (ROD), discussed in more detail in Section 2.2.1, further specified the non-perchlorate groundwater remedy to be pump and treat (P&T). TRC Companies, Inc. and SMC executed the Administrative Order on Consent (AOC) for the Site with the U.S. Environmental Protection Agency (EPA) on April 28, 2010 in Newfield, New Jersey. The 2010 AOC defines OU1 as non-perchlorate (and non-radiological) groundwater, prescribes that an OU1 Optimization Study be performed and encourages pilot studies and activities to optimize contaminant treatment. TRC assumed the responsibility of completing the components of the AOC related to OU1. The November 2010 OU1 Optimization Study, approved by EPA in February 2011, concluded that “…the pace of cleanup associated with P&T is slow (and getting slower), and that the unit cost of treatment is high and getting higher. Further, the current treatment system is highly energy intensive.” More specifically, the study found that groundwater concentrations had been operating at asymptotic levels (not progressing toward cleanup goals) for over 10 years. These findings prompted the 2011 construction of a new treatment plant (using ion exchange to improve operating efficiencies) and the advancement of pilot programs (up to the writing of this document) to evaluate the efficacy of in situ remediation (ISR) technologies to expedite aquifer cleanup. The in situ pilot program has included extensive studies, small scale injections, large scale injections (an active remedy), evaluation of monitored natural attenuation (MNA), the generation of many documents and an abundance of data. Most recently, the March 2014 In Situ Pilot Program Progress and Evaluation Report summarized the progress and accomplishments of the program.

1


1.2 Report Purpose and Organization This Final Draft OU1 FFS was prepared at the direction of the EPA. The purpose of the OU1 FFS is to screen and evaluate two primary Remedial Alternatives for OU1, namely:

• Pump and ex situ treatment (the remedy prescribed in the 1996 AOC); and • In situ remediation (with monitored natural attenuation, MNA, for polishing).

The OU1 FFS was prepared in accordance with the provisions of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA, also known as Superfund), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), in compliance with the requirements of the National Contingency Plan (NCP: 40 CFR 300) and in compliance with the EPA Office of Solid Waste and Emergency Response (OSWER), Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (OSWER Directive 9355.3-01, EPA, 1988a) herein referred to as “RI/FS Guidance”. This OU1 FFS is organized as follows:

• Section 1 presents introductory information. • Section 2 presents Site descriptions, environmental history, nature and extent of

contamination, fate and transport and summary of baseline risk assessment. • Section 3 summarizes the Remedial Action Objectives (RAOs), applicable or relevant

and appropriate (ARARs) standards and development of preliminary remedial goals (PRGs).

• Section 4 identifies and screens candidate remedial technologies. • Section 5 develops, screens, and evaluates the Remedial Alternatives. • Section 6 presents conclusions. • Section 7 presents references

Supporting figures and tables are also included.

2


2. SITE DESCRIPTION AND ENVIRONMENTAL HISTORY The following topics are discussed in the following subsections:

• Site description; • Summary of historical environmental Site activities; • Summary of OU1 Site investigations; • Conceptual Site Model; • Nature and extent of contamination; • Summary of Baseline Risk Assessment; and • Fate and transport.

2.1 Site Description The SMC Facility (“Facility”) is located at 35 South West Boulevard, primarily in the Borough of Newfield, Gloucester County, New Jersey. A small portion of the southwest corner of the Facility is located in the City of Vineland, Cumberland County, New Jersey. A Site location map is provided on Figure 1. The Facility comprises approximately 67.7 acres. The approximate center of the Facility is located at latitude 39°32’27.6”N and longitude 75°01’06.7”W. SMC also owns an additional 19.8 acres of farmland, referred to as the “Farm Parcel,” located in Vineland, approximately 2,000 feet southwest of the Facility. SMC purchased the Farm Parcel to facilitate the installation and operation of a pumping well, which is part of a groundwater pump and treat remediation system. This Farm Parcel has never been used for manufacturing or related activities. The SMC Site is comprised of the SMC Facility and the Farm Parcel. The Facility is currently used as office space and is sublet as warehousing for construction companies and the Newfield Borough. The Facility is bordered as follows:

• To the north by a former rail spur and a former landfill; • To the west by Conrail rail lines, South West Boulevard and various light

industries and residences; • To the east by a wooded area, residences and small businesses; and • To the south by the Hudson Branch stream and the residences located along

Weymouth Road.

3


The Facility is secured by a perimeter chain link fence. The Facility parking lot along the western property boundary lies outside of the chain link fence to allow visitor and administrative access. Currently, approximately 100 groundwater monitoring wells and approximately 107 injection wells exist throughout and downgradient of the Site.

2.2 Summary of Historical Environmental Site Activities Extensive environmental activities have been occurring at the Site continually from the early 1970’s to the present. Some of the major activities include:

• 1970’s o Began environmental investigations; o Installed public water supply to area users; o Began operation of the pump and treat system;

• 1980s o Ongoing groundwater studies and operation of pump and treat system;

• 1990s o Closed and remediated the former lagoons (the primary source of

chromium contamination to groundwater) including excavation/disposal; o Installed the (9.65 acres) vegetated caps (part of the Natural Restoration

regulatory process); • 2000s

o Ongoing groundwater studies and operation of pump and treat system; o OU1 Optimization Study o Progressive OU1 In Situ Remediation Pilot Program; o Constructed a modernized treatment plant; o Deactivated the pump and treat system (April 2013) to allow more

thorough study of in-situ technologies and MNA.

2.2.1 Pump and Treat A focused pump and treat system began operating in 1979, pumping from W8 (a well at the south west corner of the Facility), and treating the groundwater via an old ion exchange system. Groundwater recovery was switched from well W8 to well W9 to obtain more appropriate hydraulic control (which is part of the enduring system) in 1983. Treated water was discharged into an on-site, unnamed tributary of the Hudson Branch

4


stream, under a New Jersey Pollution Discharge Elimination System (NJPDES) permit. In order to allow clear evaluation of the in situ pilot work, the pump and treat system was deactivated in April 2013. The NJPDES permit and Water Allocation permit were deactivated May 2014. The 1988 ACO indicated that a five recovery well pump and treat system be installed and operated. In 1989, four recovery wells were added to the pump-and-treat system to better capture the chromium plume, which included the following wells: Layne, RW6S and RW6D (the “carwash” wells on Weymouth Road); and RIW2 (at the Farm Parcel). Also, in 1989, SMC expanded the treatment system to include an air stripper, to address the secondary contaminant of concern, trichloroethene (TCE), which also exists in the groundwater. The chromium-treatment portion of the system was changed to electrochemical precipitation in 1991. The P&T system had been in continual operation since 1989 (until 2014, as discussed below). The major components of the 1996 ROD are as follows:

• Modify the Ground Water Extraction System (using five extraction wells) to optimize the capture of contaminated ground water;

• Air Stripping to remove volatile organic compounds from the recovered ground water;

• Electrochemical Treatment with Supplemental Treatment (as required) to remove inorganic contaminants, especially metals, from the recovered ground water; and

• Discharge of treated ground water to surface waters of the Hudson Branch of the Maurice River.

At the time of the 1996 ROD development, pump and treat remedies were the presumptive remedy for groundwater contamination; in situ remediation, relative to the Site contaminants, was an emerging technology at that time. The November 2010 OU1 Optimization Study cited above, concluded that P&T was slow, inefficient and not cost effective. These findings prompted the 2011 construction of a new treatment plant (using ion exchange), with USEPA and NJDEP approval. Further, the OU1 Optimization Study prompted the advancement of pilot programs to evaluate the efficacy of in situ remedial technologies to expedite aquifer cleanup. The in situ program is discussed in the subsection that follows. In order to facilitate in situ program studies, the pump and treat was systematically deactivated from 2011 to 2013.

5


NJPDES and Water Allocation permits related to the pump and treat system ceased in May 2014.

2.2.2 In Situ Remediation (ISR) EPA and the scientific community indicate that ISR is an effective strategy for the remediation of chromium and TCE in groundwater (EPA, 1997a/b; EPA, 1999; EPA, 2000a; EPA, 2000b; IETEG, 2005; ITRC, 1998). The in situ remediation pilot remediation program has been progressive and aggressive. The ISR pilot program started with white paper studies and jar studies in 2007 and evolved to more extensive bench-scale tests, trying a variety of injection materials and combinations through 2010. Results indicated that calcium polysulfide (CPS) would be an effective amendment to treat chromium-impacted groundwater. CPS fosters chemical transformation by reducing the valence state of chromium from hexavalent to trivalent (the less toxic and less mobile form) and simultaneously shifting geochemical conditions to precipitate the chromium out of solution. Treatability testing results also showed that emulsified vegetable oil (EVO) would be an effective amendment for TCE, the secondary groundwater contaminant. EVO fosters biological transformation by providing microbes a carbon “food source” and an electron donor for respiration of TCE. EVO fosters microbial growth, and specialized microbes reductively dechlorinate TCE to harmless end products (e.g., ethene and/or CO2). Following the April 2010 execution of the AOC, the ISR pilot program goals were established. These goals were to validate laboratory studies with progressively larger-scale field injections in order to validate the ISR technology, reduce concentrations, reduce the time to cleanup and foster natural attenuation. CPS and EVO injection tests targeting “single well” areas were conducted in 2010. Years 2011, 2012, and 2013 included broader-scale and iterative CPS pilot test injections. Also, EVO injections to address TCE were performed in 2011. The conceptual remedial scheme for chromium treatment included the installation of rows of injection wells perpendicular to groundwater flow (see Figure 6). The distance between injection rows was modeled for effective treatment of chromium between injection rows. CPS injected into the wells create an immediate reactive zone in and around the injection wells, and then CPS and geochemical changes “sweep” through downgradient aquifer treatment zones. This process is designed to dramatically shift the

6


subsurface environment to both reduce dissolved chromium concentrations and foster long-term reductions in concentration via enhanced and natural attenuation. Geochemical adjustments include creating favorable oxidation-reduction potential (ORP), favorable pH and dissolved oxygen (DO) conditions. CPS injection also releases naturally-occurring iron into the groundwater from the aquifer matrix (high concentrations naturally available), which can further accelerate the reduction and precipitation of chromium. The CPS remains reactive for chromium remediation for a number of years. The ISR Pilot Program includes analysis of how long the CPS remains active in the subsurface, and at what point after injection this “active remediation” would begin to shift to natural attenuation. It is noted that this process is a continuum, versus a sharp start/stop point. To date, approximately 94 tanker trucks (~3.9 million lbs) of 29% CPS solution have been injected into a network of 107 injection wells with a monitoring network of approximately 100 monitoring wells. Much of the plume is still under active remediation as a result of these injections. Additionally, targeted CPS injections were performed at the Farm Parcel in June 2014. Additionally in 2011, an EVO injection and a bioaugmentation pilot program remediated the on-site source zone area for TCE near SC-20S and the former degreasing unit. Where the CPS is best injected in a line of wells perpendicular to groundwater flow, EVO injections work best to address the Site source area via injection of a grid of temporary well points. Similar to CPS, the EVO creates a reactive and reducing zone where degradation of contaminants may be fostered for several years. The in situ pilot program has included extensive studies, small scale injections, large scale injections (an active remedy), evaluation of monitored natural attenuation (MNA), and, the generation of many documents and an abundance of data. The laboratory/jar studies, treatability studies, pilot tests and pilot program completed to date included extensive evaluation of various amendments, amendment loading rates, amendment distribution, remediation efficacy and treatment longevity/stability factors, each building upon the information learned in prior steps. The March 2014 In Situ Pilot Program Progress and Evaluation Report (Evaluation Report) summarized, in a comprehensive manner, the progress and accomplishments of the program. The Evaluation Report cited over 30 project documents that were prepared to summarize the work and findings of the In Situ Pilot Program. The Evaluation Report concluded that, based on the broad base of knowledge for the Site, the in situ program has successfully reduced contaminant concentrations significantly, has done so in a relatively short time frame, that the

7


improvements are expected to be enduring, that active remediation from the injections will continue (in situ) for approximately a decade), and that MNA is viable moving forward.

2.3 Summary of OU1 Site Investigations OU1 has been extensively investigated and sampled since contamination was first discovered in 1972. Many rounds of sampling have occurred since that time, progressively building the body of knowledge on OU1. Currently, there are approximately 200 wells that help to define and study OU1.

The key Site activities that have collectively helped to define and summarize OU1 conditions include:

• 1972-1992: The 1992 Remedial Investigation Report (RIR) (TRC, 1992) whose purpose relative to groundwater, was to characterize the hexavalent chromium plume based on the progressive sampling and investigations over the previous 20 years, to confirm or deny the presence of other contaminants and to understand aquifer transmissive properties. The RIR included the installation of 19 additional wells and included the sampling of over 50 wells (two sampling events).

• 1992-2000: OU1 activities focused on pump and treat system operation and refinement, including quarterly groundwater monitoring (summarized in annual reports).

• 2000-2011: The 2011 OU1 Supplemental Remedial Design Investigation Report (TRC, 2011) summarized progressive delineation and OU1 investigations (including progress reports from 2004 and 2006). The EPA-approved 2011 Report concluded that delineation and characterization was complete.

• 2007-2014: The ISR studies, discussed in Section 2.2.2, were conducted, including detailed characterization of subsurface conditions for OU1. It was during this timeframe that regulatory oversight transitioned from NJDEP to EPA.

• Annual groundwater reports have been prepared and submitted for decades. It is estimated that there are close to 100 events of ground water data for the Site.

8


There is an abundance of OU1 data and a great deal known about OU1. The nature and extent of contamination in OU1 is discussed in Section 2.5.

2.4 Conceptual Site Model (CSM) The CSM, which is comprised of geology, hydrogeology and basic geochemistry is discussed in the subsections below.

2.4.1 Geology The Site is underlain by the Kirkwood-Cohansey aquifer system. The surficial soil is comprised of the Bridgeton Formation, which consists mainly of brown sands with a thickness that increases in a westerly direction from approximately 0 to 30 feet. Underlying the Bridgeton Formation is the Cohansey Formation, which is the primary formation regarding OU1. The total thickness of the Cohansey Formation under the Site is approximately 120 to 130 feet. The saturated thickness of the Cohansey Formation at the Site is approximately 100 feet. The Cohansey consists of light-colored (tan to pink, orange, brown and red), fine to coarse-grained sand and some gravel and silt with discontinuous layers and stringers of sandy clay and silt. The soil grain size within this formation is heterogeneous both vertically and horizontally. The Cohansey Formation is composed predominantly of quartz. Secondary minerals are aluminum oxides and iron-containing minerals (e.g., illites, kaolinite, and pyrite). These minerals play a major role in the fate, transport and natural attenuation of contaminants in this aquifer. The Kirkwood Formation, consisting of gray silts and clays, underlies the Site and serves as an aquitard. The depth to the Kirkwood Formation at the Site varies between approximately 120 and 140 feet below ground surface (bgs). Geological surveys suggest that the Kirkwood Formation is approximately 100 feet thick in the vicinity of the Site.

2.4.2 Hydrogeology The Cohansey sand, which dips southeast approximately 0.2%, is the principal aquifer in the region. The underlying Kirkwood Formation acts as a confining layer and restricts the downward flow of groundwater from the Cohansey Sand. Hydraulically, the Cohansey Formation behaves as a single heterogeneous, water table aquifer. For the purposes of ISR designs, two injection zones were considered:

9


• Upper Zone: The treatment interval for the Farm Parcel ranges between 45 feet

bgs and 65 feet bgs. The treatment interval for the Car Wash ranges between 50 feet bgs and 75 feet bgs.

• Lower Zone: The treatment thickness for the Farm Parcel averages 30 feet with the intervals ranging from 80 to 95 feet bgs and from 95 to 110 feet bgs. For the Car Wash, the proposed treatment thickness is 30 feet ranging between 90 and 120 feet bgs (above the top of the Kirkwood clay).

The ISR CPS injections, discussed in Section 2.2.2 occurred in both zones, appropriate to the location and nature of the chromium contamination. The ISR EVO injections, also discussed in Section 2.2.2 occurred in the Upper Zone, appropriate to the location and nature of the TCE contamination. The depth to groundwater within the aquifer ranges throughout the areas of interest:

• Approximately 4 feet bgs in the southern portion of the Facility; • Approximately 16 feet bgs in the northern portion of the Facility. • Approximately 4 feet bgs near the Car Wash. • Approximately 4 feet near the Farm Parcel.

Seasonal fluctuations in the water table elevations are in the range of a few feet. The groundwater flow direction within the Cohansey aquifer at the Site is to the west-southwest along the Hudson Branch. A downward vertical hydraulic gradient exists across the Facility.

2.4.3 Basic Geochemistry Aerobic and oxidizing conditions prevail throughout the aquifer with dissolved oxygen (DO) levels often greater than 2 mg/L. Localized zones of depressed DO levels below 1 mg/L were occasionally observed, which are usually coincident with areas of higher organic content (e.g., wetlands) or higher dissolved iron content. These conditions have not been affected by the in situ injections. Background groundwater pH ranges between relatively acidic to near neutral levels of 4.4 to 8 standard units (s.u.). Soil pH is mostly near neutral but varies between moderately acidic to slightly alkaline. pH within CPS-treatment zones is relatively alkaline, post-treatment.

10


The in situ pilot program has shifted certain geochemical parameters, to accelerate attenuation, which is discussed in more detail in the OU1 In Situ Pilot Program Evaluation Report.

2.5 Nature and Extent of Contamination Extensive investigations for OU1 have been performed for 30 years, which have generated a robust body of data. The RI identifies chromium as the primary constituent of concern and TCE as the secondary constituent of concern. The nature and extent of these parameters are discussed in the subsections below. Also, for completeness, the status of other metals and other VOCs identified in OU1 are discussed.

2.5.1 Chromium in Groundwater Chromium has been detected in OU1 groundwater extending from the Facility, past the Car Wash, to the Farm Parcel in both hexavalent (Cr(VI)) and trivalent (Cr(III)) forms. NJDEP cleanup standards (70 µg/L) and EPA cleanup standards (100 µg/L) are based on total chromium. The chromium plume is ½ mile long and 100-300 feet wide, on average. The chromium plume was generally broader at the Facility (because of the former sources), and narrower at the Farm Parcel (generally consistent with the fate and transport nature in a sandy aquifer). The Risk Assessment (1995) identifies that total chromium concentrations as high as 88,000 µg/L. Prior to ISR activities (2010), chromium concentrations ranged between Not-Detected (ND) and 30,000 µg/L at the Facility and between ND and 18,000 µg/L at the Farm Parcel. The speciation of Cr(III) and Cr(VI) differs between the Facility and the Farm Parcel as observed by the ratio of Total Cr and Cr(VI) concentrations. The chromium detected in groundwater at the Facility portion of the plume has widely varied ratios of Total Cr and Cr(VI), whereas chromium in the Farm Parcel groundwater is primarily in the form of Cr(VI). The OU1 Optimization Study indicates that chromium concentrations from the pumping wells have been asymptotic at approximately 1,000 µg/L for nearly 10 years. The asymptotic conditions appear to be sustained by defined zones containing higher residual chromium concentrations. Chromium isopleths for both the upper and lower aquifer zones are included as Figures 2 and 3, respectively.

11


Reporting for Operable Unit 2 (OU2), Site soil/sediment/surface-water, summarizes that the lagoons (the historic source of OU1 chromium contamination) were properly closed, which included excavation and off-site disposal of soil and extensive post-excavation soil sampling. The OU2 reporting indicates that only 2 out of 220 soil sample results exceed risk levels and identifies these two exceedances as deminimus. The OU2 RI concluded that metals contamination in soils does not act as a source of contamination to groundwater. However, metals will continue to be monitored as part of the OU1 remedy to confirm that they do not impact the ground water or that they naturally attenuate in groundwater.

2.5.2 Other Metals The OU2 RI studied Impact to Groundwater (IGW) values for ten metals: arsenic, cadmium, lead, mercury, silver, beryllium, nickel, manganese, aluminum, and antimony. The comparison indicates that the concentrations of all ten metals exceeded the IGW values. Five metals in facility soils (arsenic, cadmium, lead, mercury, and silver) are not adversely currently impacting groundwater. The remaining five metals (beryllium, nickel, manganese, aluminum, and antimony) are affecting groundwater locally near the facility; however, data collected at the site upgradient of the farm parcel shows that concentrations in groundwater of four of the five metals (beryllium, nickel, manganese, and aluminum) are below the New Jersey Ground Water Quality Standards (NJGWQS), New Jersey Administrative Code (NJAC) 7:9C indicating that they may be naturally attenuating. The remaining metal, antimony, exceeded NJDEP’s IGW value in some samples. The OU2 RI evaluated the potential for antimony in soil to act as a source of local groundwater contamination. The remedial investigation concluded that elevated levels of antimony in soil are not associated or co-located with elevated levels of antimony in groundwater, suggesting that natural soil constituents such as iron and aluminum oxide are assisting in the natural attenuation of antimony. Vanadium does not have an NJDEP IGW value; however, the potential for vanadium to migrate through soil and into groundwater was also evaluated, due to the presence of vanadium in site soils and elevated concentrations of vanadium historically detected in groundwater in localized areas beneath the facility. Recent sampling data shows that vanadium in shallow groundwater immediately downgradient of the facility was either

12


not detected or was present at concentrations below the EPA tap water screening levels for vanadium compounds1. The original OU1 ROD also discussed cyanide, boron, selenium, and nitrate. Currently, these four parameters do not present appreciable risk. More specifically, cyanide was analyzed (in 2004) in 32 wells and was ND in all but one well. The one well detection for cyanide was 78.9 µg/L; which is less than the NJ GWQS (100 µg/L), so this parameter has achieved cleanup standards; no additional sampling/action is necessary. Since the original OU1 ROD, both the EPA and the NJDEP have modified their approach to regulating boron in groundwatere. Specifically, there is no NJ GWQS for boron and no MCL for boron, per the EPA ruling in July 2008, so there is no exceedance and no sampling/action is necessary. Selenium was measured in 42 wells with the highest detection of 16.8 µg/L; when compared to the NJGWQS (40 µg/L) and the MCL (50 µg/L), there is no exceedance for selenium, so no additional sampling/action is necessary. Nitrate was analyzed in 11 wells in 2012, with an average concentration concentrations of 6,6oo µg/L ; when compared to the MCL/NJGWQS of 10,000 µg/L that there is no significant exceedance. One well was somewhat higher than the MCL (11,700 µg/L versus 10,000 µg/L). Nitrate is a key constituent in fertilizer. The one exceedance was detected at the Farm Parcel, down and side gradient to farming interests in the area. Nitrate is not a Site constituent, and does not present an appreciable risk. As stated previously, VOCs were not detected in facility soils and it was concluded that OU2 soils are not a continuing source of VOCs in groundwater. In summary the OU2 RI concluded that metals contamination in soils does not act as a source of contamination to groundwater, but they will continue to be monitored as part of the OU1 remedy for confirmation purposes.

2.5.3 TCE TRC’s January 2011 Pre Design Investigation Report, approved by EPA in February 2014, studied TCE in detail, both on the Facility and off-site. That report concluded that only a small “source” area of groundwater existed at a location where solvents were used

1 The EPA tap water screening number for vanadium compounds is lower (more conservative) than the screening number of vanadium pentoxide, so the analysis was based on vanadium compounds, to be conservative.

13


in the north/central part of the Facility. It is noted that the OU2 RIR concluded that there were no detections of VOCs in Facility Soil (including the solvent use area) and that the only “source” was in groundwater. In situ injections of EVO, plus focused additives, were injected into groundwater at the Facility location in 2011. Sample results in 2012 demonstrated that the TCE concentrations at this location are non-detect. Sample results in 2013 demonstrated that the TCE concentrations at this location continue to be non-detect. The results indicate that no future remedial activities are warranted at the Facility for TCE. Residual dissolved TCE concentrations were detected in wells at the southwest property corner in 2013 at concentrations (10-15 µg/L) consistent with 2011/2012 results. It is concluded that the residual TCE concentrations are stable, and expected to further decrease over time. The OU1 Pre Design Investigation Report concluded that off-site TCE concentrations namely, those downgradient of the Farm Parcel, were properly delineated and further, that MNA is viable and appropriate to TCE. The OU1 Pre Design Investigation Report also concluded that other sources of chlorinated volatile organic compounds (CVOCs) exist at one or more non-SMC sources, specifically immediately downgradient of the SMC Facility. These sources have released TCE, as well as, perchlorethylene (PCE) and other CVOCs and daughter products to the environment. It is noted that TCE is a breakdown product of PCE. It is also noted that SMC/TRC is not responsible for cleaning up, or further studying, contamination from other sources. The TCE isopleths for the upper and lower zones are shown in Figures 4 and 5, respectively.

2.5.4 Other VOCs The 2011 Pre Design Investigation Report, approved by EPA on March 14, 2014, also concluded that up to five non-SMC sources of CVOCs exist, specifically immediately downgradient of the SMC Facility. Four out of five of these CVOC sources have documented PCE releases. It is noted that SMC never used PCE and that PCE was never detected at the Facility. Therefore, PCE detections are indicative of non-SMC sources. NJDEP’s GWQS for PCE is 1 µg/L. The fifth off-site source has a documented TCE

14


release. Therefore, detections of TCE downgradient of the off-site sources (from the Car Wash, southwesterly) is likely a product of off-site CVOC sources. It is also noted that SMC/TRC is not responsible for cleaning up, or further studying, contamination from other sources. The 2011 Pre Design Investigation report noted PCE concentrations throughout the footprint of the TCE plume downgradient of the off-site sources, ranging from non-detect to 38 µg/L. OU1 program monitoring can include these other VOCs to provide ongoing data relative to the non-SMC sources.

2.6 Summary of Baseline Risk Assessment Findings The Human Health Risk Assessment (HHRA, TRC, 1995), approved by the NJDEP and EPA, evaluated potential risk associated with the Site. The Constituents of Potential Concern (COPCs), exposure assessment, toxicity assessment and risk characterization are discussed in the subsections below.

2.6.1 COPCs/Exposure Assessment The HHRA assumed that a human receptor could ingest water from OU1, although it was noted that current groundwater use restrictions limit that practical possibility. The proposed OU1 remedy includes a Classification Exception Area (CEA)/Well Restriction Area (WRA), which will provide an additional protective use restriction. The HHRA estimated exposure intakes and exposure parameters consistent with EPA guidance using maximum detected concentrations.

2.6.2 Toxicity Assessment Both cancer (e.g., arsenic, beryllium and TCE) and non-cancer health effects (e.g., chromium,-trivalent and hexavalent, vanadium, antimony, beryllium, boron, cyanide, and managanese) associated with the identified COPCs were obtained from appropriate sources, consistent with EPA policy (OSWER Directive 9285.7-53) and guidance.

15


2.6.3 Risk Characterization The results of the quantitative HHRA are presented in two forms. In the case of human health effects associated with exposure to potential carcinogens, risk estimates incorporate age-dependent adjustment factors and are expressed as the lifetime probability of additional cancer risk associated with the given exposure. The cancer risk estimates are calculated as the cancer-based exposure intake (mg/kg-d) times the slope factor [(mg/kg-d)-1]. In numerical terms, these risk estimates are presented in scientific notation in this report. The estimated cancer risks are compared to risk values presented in the NCP (EPA, 1990). Specifically, for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an additional cancer risk to a Reasonable Maximum Exposure (RME) individual of between 10-4 (one in ten thousand) and 10-6 (one in one million; i.e., EPA’s acceptable risk range). For estimating risks to individual non-carcinogens, the Hazard Quotient (HQ) is used. The HQ is calculated as the non-cancer exposure intake (mg/kg-d) divided by the Reference Dose (RfD) (mg/kg-d). Chronic RfDs are used for scenarios involving long-term exposures (i.e., industrial and residential). The HQs are summed across chemicals to calculate a Hazard Index (HI) for each pathway in each scenario. HIs that exceed available regulatory guidelines will be further evaluated by target organ and systemic effects. The estimated non-cancer HIs are compared to available regulatory guidelines. Regarding non-carcinogenic health hazards, (EPA 1989) states that:

“When the total hazard index for an exposed individual or group of individuals exceeds unity, there may be concern for potential non-cancer health effects.”

Therefore, regarding non-carcinogenic health hazards, a HI equal to or less than one is within EPA’s acceptable range (EPA 1989). The State of New Jersey has set acceptable non-carcinogenic risk for any given effect to a value not ·to exceed a HI of 1.0. These established acceptable risk values are for any particular discrete contaminant and not for the cumulative effects of more than one contaminant [New Jersey Public Law P.L., 1993, c. 139 (NJSA58:10B)]. Calculated cancer risk for groundwater ingestion was calculated as 7E-03 (deep) and 4E-02 (shallow), which both exceeded established EPA guidelines (>1E-06). Ingestion of arsenic and beryllium accounted for the majority of this risk. Inhalation of TCE from

16


deep groundwater was also associated with an elevated cancer risk value (2E-06), which exceeded established EPA guidelines. Calculated HIs were 8E+03 (deep) and 6E+02 (shallow), each of which exceeded an HI=1. The elevated HI was associated with antimony, arsenic, beryllium, boron, cyanide, Cr(III) and Cr(VI), manganese and vanadium. Therefore, the HHRA concludes that OU1 human health risks exceed EPA’s acceptable range. It is noted that the current groundwater concentrations are considerably less that the concentrations used in the risk characterization, so the associated calculated risk would be lower. Because there are no exposure scenarios for ecological receptors, OU1 presents no complete exposure pathway, so no ecological risk is expected. At the time of the 1995 risk assessment, EPA did not classify hexavalent chromium as a potential oral carcinogen; however, it is now considered a potential oral carcinogen. Conversely, EPA classified beryllium as a potential oral carcinogen at the time the risk assessment was performed, but no longer does. TRC provided updated risk calculations (December 2014) to reflect the fact that EPA changed their policy. The updated calculations concluded that, for the shallow aquifer, the HQs for boron and vanadium have decreased since the 1995 risk analysis. Based upon the change in RfD and updated risk calculations, the 2014 HQ for beryllium increased by ~7 fold. This is primarily due to current EPA methodology to evaluate a child receptor and evaluate dermal exposure to metals in ground water (the 1995 risk assessment did not calculate dermal risk). The 2014 HQs for chromium and hexavalent chromium are slightly higher than 1995 risk which is due to an “apparent” increase in the ground water concentration, due to calculation method. This “apparent” increase adds some uncertainty, because of the limited number of wells available in 1995, versus the robust network of wells currently available. Other analyses, provided as part of the OU1 In Situ Program, have demonstrated that the shallow (and deep) chromium plumes have actually been decreased significantly, both in footprint and concentrations, between 1995 and 2014. The cancer risk for chromium (hexavalent) was calculated to be 4E-04, based on EPA’s current considerations of this potential carcinogen.

This risk calculation update refers to the results using 1995 data (with its inherent uncertainty) to make a consistent comparison to the former calculations. For the deep

17


aquifer, updated risk calculations indicate that the HQs for boron, chromium (as trivalent), chromium (hexavalent) and vanadium have decreased since the 1995 risk analysis. Based upon the change in RfD and updated risk calculations, the 2014 HQ for beryllium increased by ~7 fold. This is primarily due to current EPA methodology to evaluate a child receptor and evaluate dermal exposure to metals in ground water (the 1995 risk assessment did not calculate dermal risk). The cancer risk for chromium (hexavalent) was calculated to be 6E-03, based on EPA’s current considerations of this potential carcinogen.

It is noted that the deep aquifer 95% UCL concentration of chromium (as trivalent) has decreased from 88 mg/l in 1995 to 1.08 mg/l in 2014, and that the chromium (hexavalent) 95% UCL concentration has decreased significantly from 1,400 mg/l in 1995 to 0.98 mg/l in 2014. These positive results are a reflection of the success of in situ remediation activities. Additionally, a well restriction area exists over much of the area, and EPA is pursuing additional institutional controls, so, although the cancer risk exceeds EPA’s risk level of 1E-04, actual exposure is extremely unlikely.

2.7 Fate and Transport The OU1 fate and transport mechanisms have been studied both as part of the HHRA and the OU1 In Situ Pilot Program. The CSM is discussed in Section 2.4. The distribution and configuration of groundwater contaminants are discussed in Section 2.5. The HHRA is discussed in Section 2.6. The OU1 Optimization Study considered the contamination concentrations and distribution over time, and concluded that key constituents had achieved asymptotic concentrations, marking key limitation of the pump and treat system to further reduce contamination. The OU1 In Situ Pilot Program Evaluation Report studied the contamination migration over time (subsequent to ISR injections) including modeling of the fate and transport of the key constituents (chromium and TCE) to understand the potential for further attenuation and reduction. Studies included the evaluation of subsurface pH, oxidation-reduction potential (ORP), dissolved oxygen (DO), and an EPA-supported analytical solute transport model designed to simulate advection, dispersion, adsorption, and decay (biotic and abiotic) using site-specific input parameters (based on extensive laboratory and field testing). The study suitably accounted for geo-spatial variations in

18


contamination and subsurface conditions. The model included multiple conservative assumptions to provide safe and conservative results. Additionally, lines of evidence were considered, in a manner consistent with EPA protocols, to evaluate the efficacy and suitability of Monitored Natural Attenuation (MNA) for the Site. The modeling and studies concluded that MNA is both viable and appropriate for the Site, that regulatory concentration goals (e.g., 70 µg/L for chromium) will be maintained at sentinel wells, and that former source area target concentrations (for chromium in the upper zone allowable concentrations up to 750 µg/L, with localized average high of 1,000 µg/L, and for the lower zone, 1,250 µg/L with localized average high of 2,700 µg/L) are expected to be achieved. Further, the evaluations concluded that ISR (including MNA) would achieve cleanup goals many times faster than pump and treat. These analyses have concluded that the limits of the contaminant plumes are well delineated, are stable and are undergoing natural attenuation processes. The body of the plume has been greatly reduced by ISR activities and continues to undergo active ISR from injected material continuing to decrease plume concentrations. Ongoing monitoring will continue to be performed to confirm these findings.

19


3. RAOs, ARARs, AND PRGs The RAOs, ARARs, General Response Actions (GRAs), and some PRGs are discussed in the subsections below.

3.1 RAOs RAOs for OU1 are identified in this section. RAOs are site-specific statements that convey the goals for minimizing or eliminating substantial risks to public health and the environment as identified in the risk assessments. The process of identifying RAOs follows the identification of Site COCs and ARARs/to be considered (TBCs), and development of remediation goals. The RAOs identified in the 1994 FFS, which are still appropriate, are identified below:

• Prevent exposure due to groundwater ingestion to groundwater contaminants attributable to the SMC Facility which have been detected at levels exceeding acceptable ARARs/TBCs, as indicated;

• Minimize migration of groundwater contaminants; and • Remediate the groundwater contamination attributable to the SMC Facility to

achieve ARARs/TBCs. The GRAs to help achieve these RAOs are discussed in Section 4.1.

3.2 ARARs and TBC This section provides a summary of the regulations that are considered ARARs to remediation of OU1. Both Federal and State environmental and public health requirements are considered.

3.2.1 Definition of ARARs The statutory requirements that are directly relevant to the remediation of the SMC Site are identified and discussed using the framework and terminology of CERCLA, as amended by SARA. These Acts specify that Superfund remedial actions must comply with the requirements and standards of both federal and state environmental laws. The EPA defines applicable requirements as “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

20


circumstance at a CERCLA site.” An applicable requirement must directly and fully address the situation at the Site. The EPA defines relevant and appropriate requirements as “those cleanup standards, standards of control, or 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.” Actions must comply with state ARARs that are more stringent than federal ARARs. State ARARs are also used in the absence of a federal ARAR, or where a state ARAR is broader in scope than the federal ARAR. ARARs are not currently available for every chemical, location, or action that may be encountered. When ARARs are not available, remediation goals may be based upon other federal or state criteria, advisories and guidance, or local ordinances. In the development of remedial action alternatives, the information derived from these sources is termed “To Be Considered,” or TBCs. Remedial actions performed under Superfund authority must comply with ARARs except in the following circumstances: (1) the remedial action is an interim measure or a portion of the total remedy that will attain the standard upon completion; (2) compliance with the requirement could result in greater risk to human health and the environment than alternative options; (3) compliance is technically impractical from an engineering perspective; (4) the remedial action will attain an equivalent standard of performance; (5) the requirement has been promulgated by the State, but has not been consistently applied in similar circumstances; or (6) the remedial action would disrupt fund balancing. ARARs and TBCs are classified as chemical-, action-, or location-specific. Chemical-specific ARARs or TBCs are usually health- or risk-based concentrations in environmental media (e.g., air, soil, water), or methodologies that when applied to site-specific conditions, result in the establishment concentrations of a chemical that may be found in, or discharged to, the ambient environment. Location-specific ARARs or TBCs generally are restrictions imposed when remedial activities are performed in an environmentally sensitive area or special location. Some examples of special locations

21


include floodplains, wetlands, historic places, and sensitive ecosystems or habitats. Action-specific ARARs or TBCs are restrictions placed on particular treatment or disposal technologies. Examples of action-specific ARARs are effluent discharge limits and hazardous waste manifest requirements. As specified in the 1988 Guidance (EPA, 1988), the preliminary identification of ARARs and TBC can assist in planning RI activities and performing certain data screening. The Baseline Ecological Risk Assessment (BERA) and the Baseline Human Health Risk Assessment (BHHRA) each has rigorous EPA policies and procedures which must be followed, including initial screening and more detailed analysis of RI data.

3.2.2 Potential ARARs 3.2.2.1 Federal Contaminant-Specific ARARs/TBCs Chemical-specific ARARs can define acceptable exposure levels and be used in establishing preliminary cleanup goals. Chemical-specific ARARs/TBCs, which may be applicable to the development of cleanup goals for OU1 media at the Site, are addressed below. Maximum Contaminant Levels (MCLs) published under the Safe Drinking Water Act (40 CFR 141.11-16 and 141.60-63) may be relevant and appropriate to groundwater remediation. For example, the MCL for total chromium is 100 µg/L. There is no separate MCL for hexavalent chromium. It is noted that, in order to ensure that the greatest potential risk is addressed, EPA’s regulation assumes that a measurement of total chromium is 100 percent hexavalent chromium, the more toxic form. The MCL for TCE is 5 µg/L. Maximum Contaminant Level Goals (MCLGs), also published under the Safe Drinking Water Act (40 CFR 141.50-52) represent non-enforceable health goals for public water supply systems. Under the NCP, non-zero MCLGs are to be used as remedial goals for current or potential sources of drinking water. While groundwater is not a current source of drinking water at the SMC Site, MCLGs, may be relevant and appropriate to groundwater remediation. The MCLG for total chromium is also 100 µg/L. The EPA published the Regional Risk Levels (RSLs) tables to provide generic concentrations in the absence of site-specific exposure assessments. Because site-specific risk was considered, the RSLs are not ARARs for this Site.

22


3.2.2.2 Potential State (New Jersey) Chemical-Specific ARARs/TBCs Potential chemical-specific ARARs for groundwater in New Jersey includes the New Jersey GWQS (NJAC 7:9C). Groundwater at the Site is classified as Class II. The GWQS for total chromium is 70 µg/L and the GWQS for TCE is 1 µg/L.

3.3 Development of Remediation Goals Based on the ARARs discussed in Section 3.2, the most stringent ARARs appropriate to Site contaminants would apply. In the case of chromium and TCE, the NJGWQS are the most stringent and will apply. So, the Site groundwater cleanup goals are 70 µg/L for chromium and 1 µg/L for TCE.

23


4. GRAs, AND IDENTIFICATION AND SCREENING OF CANDIDATE

REMEDIAL TECHNOLOGIES Candidate technologies are specific remedial processes, systems or methods that could potentially, alone or in combination with other technologies, comprise a GRA. Candidate technologies considered below include processes demonstrated to be potentially capable of mitigating potential human health or environmental impacts from OU1 and/or addressing the RAOs. Following the development of RAOs, medium specific candidate remedial technologies and process options are identified and are subsequently combined into alternatives to satisfy RAOs. The first step in identifying candidate remedial technologies and process options is the development of GRAs, which are categories of measures that can be applicable to accomplish the Site’s RAOs. Superfund requires that an array of actions be considered for subject media. GRAs describe broad classes of actions that satisfy the RAOs and form the foundation for the identification and screening of remedial technologies and alternatives. The list of technologies and representative process options are narrowed down through screening and evaluation to a shorter list that will be appropriate for inclusion in Remedial Alternatives for the Site. This section presents the GRAs, identification of candidate remedial technologies and process options for Site media of concern and documents the screening and evaluation of technologies and process options.

4.1 GRAs The GRAs that are applicable to achieve the RAOs for OU1 at this point in time are:

• No Action; • Institutional Controls; • Containment; • Removal/Treatment; and • In situ process, including MNA processes.

The “No Action” GRA is required by CERCLA to be included to provide a baseline comparison. Institutional controls are non-engineered instruments, such as administrative and legal controls, that help minimize the potential for human exposure to contamination and/or

24


protect the integrity of the remedy. A common example of such controls include groundwater use restrictions. Containment includes controls that limit contact with contaminants and may potentially limit contaminant transport, as necessary. A common example of such controls is pumping to provide some hydraulic control. Removal includes the physical process of taking the contaminated material from where it currently exists. An applicable example of removal is pumping. Treatment includes any process which may alter the characteristics of the contaminated media. Examples include the electrochemical precipitation and air stripping treatment system that was operated for 20 years or the ion exchange treatment system that started in 2011. In situ processes include technologies that address contaminants “in place”. In the case of OU1, this means in the aquifer. An example of in situ processes is the injection of a chemical to reduce contaminant mass. In situ processes can also be natural processes that can decrease the mobility, toxicity or volume of contaminated media over time. Appropriate monitoring is an integral element of these natural processes. Technologies associated with these GRAs are described in Section 4.2.

4.2 Identification of Candidate Remedial Technologies Candidate Remedial Technologies associated with the GRAs presented in Section 4.1 include:

GRA Candidate Technologies No action No technology associated with this GRA Institutional Controls Groundwater use or well restrictions Containment Pumping Removal/treatment Pumping/ion exchange or electrochemical

precipitation, air stripping In Situ Processes • Injections

• MNA These candidate technologies are discussed in the subsections below. “No action” is not discussed because there is no technology associated with this GRA.

25


4.2.1 Institutional Controls—Groundwater Use and Well Restrictions Groundwater use and/or well restrictions is an institutional control that is applicable to OU1. Currently, the City of Vineland has a WRA that is protective of the majority of the OU1 plume (the portion of OU1 in Newfield is not addressed by this control). The NJDEP can impose a CEA/WRA, pursuant to 7:26C-7.3, which limits groundwater use in a defined area. An application was submitted to the NJDEP in 2001, but never enacted. A completed CEA/WRA would be an applicable institutional control for OU1.

4.2.2 Containment—Pumping Pumping provides containment by creating an area of lower hydraulic potential, which draws groundwater towards the pumping well(s). The OU1 P&T included five pumping wells (two at the Facility, two at the Car Wash, and one at the Farm Parcel) which could pump up to 400 gallons per minute. Decades of operation indicate that the P&T achieved reasonable containment.

4.2.3 Removal/Treatment Removal/treatment refers to the physical process of taking contaminated material out of its current location and treating it above-ground (ex situ). The OU1 P&T that operated for decades included pumping (for removal) and electrochemical precipitation (for metals treatment) up to 2011. The OU1 Optimization Study determined that electrochemical precipitation was not as effective or sustainable as ion exchange for metals treatment. The treatment plant was rebuilt to use ion exchange in 2011. Air stripping was used for VOC treatment with both metals-treatment processes.

4.2.4 In Situ Processes (Injections/MNA) ISR is recognized by EPA and the scientific community as an effective strategy for the remediation of chromium and TCE in groundwater (USEPA, 1997a/b; USEPA, 1999; USEPA, 2000a; USEPA, 2000b; IETEG, 2005; ITRC, 1998). Site specific and iterative studies were performed from 2007-2010, including beaker studies, benchscale tests, exhaustive sampling/testing to evaluate the efficacy of using in situ processes to expedite aquifer remediation and to select candidate injection materials and methods. These studies concluded that in situ processes are viable for OU1. In fact, the studies showed that in situ processes have the potential of accelerating aquifer cleanup. In 2010, on-site, focused injections were performed to further evaluate in situ

26


materials and methods. In 2011, larger scale pilot injections were performed at the Facility to investigate the ability to accelerate the cleanup of OU1, namely, chromium and TCE. Calcium polysulfide (CPS) was selected as the optimum injectant for chromium. CPS provides a chemical process by which hexavalent chromium’s valence state is changed, converting the chromium to the trivalent form. Further, CPS modifies subsurface environments to convert trivalent chromium to the precipitant form, taking the chromium out of its dissolved state in the groundwater. Because the mass of the metals is small (i.e., in the parts per million) relative to the combined mass of the groundwater and soils matrix the precipitant does not substantively affect aquifer hydraulic properties. CPS is injected into the appropriate aquifer zones via injection wells. The injection wells are placed in a series of lines perpendicular to groundwater flow to create a “reaction zone”. After initial injection, the CPS is carried downgradient with groundwater flow. This “sweeping” action spreads the CPS and continues the active reactions Larger scale CPS injections occurred at the Facility and the Farm Parcel in 2012 and at the Farm Parcel and the Car Wash in 2013 and was performed at the Farm Parcel in 2014. Site-specific studies have demonstrated that the dissolved mass reduction is enduring (it is extremely unlikely that re-dissolution could occur under normal circumstances). Further, site-specific studies included in the Draft OU1 In Situ Remediation Pilot Program Evaluation Report, dated March 2014, have also demonstrated that CPS is estimated to remain active in OU1 for 5-10 years in the upper zone and 20-35 years in the lower zone. The injectant selected for a pilot study to accelerate the cleanup of TCE was EVO, which provides a biological process to break down TCE. A pilot study targeting the “source” area at the Facility was performed in 2011. Site-specific studies show that the TCE has been reduced to ND levels at the source area. MNA includes employing naturally occurring processes to contain or reduce the bioavailability or toxicity including, but not limited to sorption, exposure reduction, biotransformation, diffusion, dilution and chemical destruction. Monitoring is an integral part of the process option. Monitoring can include the sampling of soil (or its vegetation, if available) to determine contaminant concentrations and concentrations of helpful benchmark parameters (e.g., carbon content).

27


4.3 Assumptions Affecting Remedial Alternatives OU1 has been extensively studied. Certain assumptions were made during fate and transport modeling in a conservative manner, which would underestimate remedial capability. Therefore, these assumptions are not believed to materially impact conclusions of this FFS. Similarly, where modeling compared the two Remedial Alternatives, many assumptions or estimates for parameters were the same for each remedy. So, these assumptions are also not believed to materially impact the conclusions of the FFS.

4.4 Screening of Candidate Remedial Technologies The candidate technologies are identified and screened for OU1 in the subsections below. The technology screening approach is based on procedures outlined in Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA 1988). The evaluation process employs three criteria: Effectiveness, Implementability and Relative Cost. The effectiveness criterion outweighs the implementability and relative cost criteria. These criteria are described below: Effectiveness: The evaluation criterion focuses on the effectiveness of process options to reduce toxicity, mobility or volume of contamination for long-term protection and in complying with RAOs and PRGs. The criterion also evaluates potential impacts to human health and the environment during construction and implementation, as well as how proven and reliable the process is with regards to site-specific conditions. Implementability: This criterion takes in both the technical and administrative feasibility of the technology or process option and includes evaluation of pretreatment requirements, residual management and the relative ease or difficulty in performing the operation, maintenance and monitoring (OM&M) requirements. Process options that are ineffective or unworkable at the Site are eliminated by this criterion. Relative Cost: In this criterion, both capital and OM&M costs are evaluated. The cost analysis is based on engineering judgment; each process being evaluated as to whether costs are low, moderate or high relative to other options of similar technology type. In general, cost analysis has a limited role in the screening process.

28


4.4.1 Institutional Control (CEA/WRA) The GRA of Institutional Control for OU1 is comprised of the technology/process option of a CEA/WRA.

• Effectiveness: This process option is effective at restricting human contact, but does not address the RAO of remediating groundwater contamination.

• Implementability: This process option is readily implemented and

administratively feasible.

• Cost: This process option has low capital and OM&M cost.

• Conclusion: Institutional controls (CEA/WRA) is retained for further evaluation, as a component to an overall remedy.

4.4.2 Containment (Pumping) The GRA of containment is comprised of the remedial technology/process option of pumping.

• Effectiveness: Pumping alone would not achieve the RAOs. It is only effective in containing OU1 contaminants.

• Implementability: This process option is technically and administratively

feasible (it was performed for decades at the Site).

• Cost: This process option has moderate capital cost and very high OM&M cost.

• Conclusion: Containment (pumping) is retained for further evaluation.

4.4.3 Removal/Treatment (P&T) The GRA of Removal/Treatment for OU1 is comprised of the remedial technology of pumping and treating (via ion exchange for metals and air stripping for VOCs).

• Effectiveness: P&T is effective at containing, can effectively remove some mass, and can achieve discharge criteria. The OU1 Optimization Study concluded that

29


it is not highly effective because P&T would take an extremely long time to achieve RAOs.

• Implementability: P&T is technically and administratively feasible.

• Cost: This process option has low capital cost (because the system is in place)

and very high OM&M cost.

• Conclusion: P&T is retained for further evaluation because it meets the three screening criteria and could achieve the RAOs.

4.4.4 In Situ Processes (Injections/MNA) The GRA of in situ processes for OU1 is comprised of the process of injections and MNA.

• Effectiveness: Extensive and site-specific pilot studies have demonstrated that injections are effective in reducing dissolved contaminant mass and MNA is an effective polishing process. In situ processes would achieve RAOs; it would reduce the mobility, volume and toxicity of contamination.

• Implementability: Injections/MNA is highly implementable.

• Cost: Injections had high capital costs (this work is completed, under the pilot

program). MNA has relatively low OM&M cost.

• Conclusion: Injections/MNA is retained for further evaluation because it meets the three screening criteria and could achieve the RAOs.

30


5. DEVELOPMENT, SCREENING, AND DETAILED ANALYSIS OF

REMEDIAL ACTION ALTERNATIVES Remedial Alternatives have been assembled, working from the technology/process options retained from the screening discussed in Section 4.4, to provide an array of approaches. Remedial Alternatives have been developed, screened, and evaluated for OU1, as discussed in the subsection below.

5.1 Summary of Remedial Action Alternatives The Alternatives for OU1 include:

• Alternative #1- No Action; • Alternative #2- P&T; • Alternative #3-In Situ Processes (Injections/MNA).

Each of these Alternatives is described in the subsections below. Common Components A common component of Alternatives #2 and #3 is the institutional control of a CEA/WRA. A CEA/WRA would:

• Protect human health exposure by informing the public of Site conditions and protecting OU1 from well use; and

• Preserving and maintaining this institutional control (CEA/WRA) over time. A CEA/WRA was required by the initial ROD. TRC submitted the CEA application to NJDEP, but the CEA was not reviewed/implemented. Completion of this task now would satisfy the ROD conditions. For any Superfund site that does not immediately achieve ARAR’s, EPA requires 5-year project reviews. Because potential Remedial Alternatives are not expected to immediately achieve ARAR’s, each of the OU1 Alternatives includes a 5-year review cycle.

31


5.1.1 Alternative #1- No Action The “no action” alternative serves as the baseline for comparison with other alternatives and is required by the NCP and by CERCLA/Superfund guidance. In this alternative, no additional remedial action is taken beyond actions already taken, so pre-existing conditions would remain unaddressed. No action would include no institutional controls.

5.1.2 Alternative #2- P&T Alternative #2, P&T, in accordance with the ROD, includes:

• Using five extraction wells to capture of contaminated ground water; • Using air Stripping to remove volatile organic compounds from the recovered

ground water; • Using electrochemical precipitation treatment (more recently modified to ion

exchange) to remove inorganic contaminants, especially metals, from the recovered ground water;

• Discharge of treated ground water to surface waters of the Hudson Branch of the Maurice River;

• Monitoring; and • Implementation of a CEA/WRA.

For purposes of alternative planning and evaluation, it is assumed that pumping rates will be consistent with the rates required in the ROD. It is possible that pumping rates could be reduced, or that the system could be operated in a pulsed-manner (which could reduce O&M costs, to a degree) but there is no data available to select an alternative rate as a basis for cost estimation. The total present value project costs for this Alternative are $19,450,000. For planning purposes, 30 years of P&T operation is assumed (although studies show that P&T would not achieve targets in 30 years).

5.1.3 Alternative #3- In Situ Processes (Injections/MNA) The in situ processes alternative include both active in situ remediation (ISR) and Monitored Natural Attenuation (MNA). As discussed in Section 2.2.2, and 4.2.4, the active ISR included:

32


• injecting calcium polysulfide (CPS) into the target portions of the aquifer to

improve chromium concentrations; and, • injecting emulsified vegetable oil (EVO) into a targeted aquifer zone on the

Facility to improve localized TCE concentrations; • MNA; • Implementation of a CEA/WRA.

CPS injection fosters chemical transformation by reducing the electron valence state of chromium from hexavalent to trivalent (the less toxic and less mobile form) and simultaneously shifting geochemical conditions to precipitate the chromium out of solution. Over the course of four years, CPS was injected to the targeted zones of the aquifer under the Facility, Car Wash, and Farm Parcel. The conceptual remedial scheme for chromium treatment included the installation of rows of injection wells perpendicular to groundwater flow (see Figure 6). CPS injected into the wells create an immediate reactive zone in and around the injection wells, and then CPS and geochemical changes “sweep” through downgradient aquifer treatment zones. This process is designed to dramatically shift the subsurface environment to both reduce dissolved chromium concentrations and foster long-term reductions in concentration via enhanced and natural attenuation. Geochemical adjustments include creating favorable oxidation-reduction potential (ORP), favorable pH and dissolved oxygen (DO) conditions. CPS injection also releases naturally-occurring iron into the groundwater from the aquifer matrix (high concentrations naturally available), which can further accelerate the reduction and precipitation of chromium. The CPS remains reactive for chromium remediation for generally 10 or more years. As the reactive stage decreases, the MNA mechanisms would continue to decrease contaminant concentrations. It is noted that this process is a continuum, versus a sharp start/stop point. Approximately 94 tanker trucks (~4.2 million lbs) of 29% CPS solution have been injected into a network of over 100 injection wells with a monitoring network of approximately 100 monitoring wells. Much of the plume is still under active remediation as a result of these injections. EVO injection fosters biological transformation by providing microbes a carbon “food source” and an electron donor for respiration of TCE. EVO fosters microbial growth, and specialized microbes reductively dechlorinate TCE, first to TCE’s daughter product (vinyl chloride), then to harmless end products (e.g., ethene and/or CO2). EVO injections to address TCE via bioaugmentation were performed in 2011. EVO injection and a bioaugmentation pilot program remediated the on-site source zone area for TCE near SC-20S and the former degreasing unit. Where the CPS is best injected in a line of wells

33


perpendicular to groundwater flow, EVO injections work best to address the Site source area via injection of a grid of temporary well points. Similar to CPS, the EVO creates a reactive and reducing zone where degradation of contaminants may be fostered for several years. The EVO injections effectively reduced localized TCE concentrations to regulatory targets (1 µg/L). The ISR has included extensive studies, small scale injections, large scale injections (an active remedy), evaluation of monitored natural attenuation (MNA), and, the generation of many documents and an abundance of data.

MNA includes employing naturally occurring processes to contain or reduce the bioavailability or toxicity including, but not limited to sorption, exposure reduction, biotransformation, diffusion, dilution and chemical destruction. Consistent with EPA protocols, a systematic and thorough analysis of the efficacy of MNA for the Site was conducted. The EPA protocol outlines a 4-tier line of evidence to prove MNA, as follows:

• Tier I: Demonstration of Plume Stability and Attenuation • Tier II: Determination of the mechanism and rate • Tier III: Determination of the capacity and stability of the removal mechanisms • Tier IV: Implementation of a long-term performance monitoring program.

Tier I Plume stability is evaluated, per EPA procedures, by using the Mann-Kendall Statistical Test for Trend for groundwater data over time. This evaluation showed that the Site plume is stable (or shrinking), which is supportive of MNA efficacy. Plume attenuation is evaluated, per EPA procedures, with evidence that the aquifer conditions are conducive. Potential mechanisms for metals include reduction by ferrous iron, co-precipitation, and sorption onto iron oxide (ferric oxide – Fe2O3) and hydroxide complexes, and clay minerals. EPA approved studies have analyzed these mechanisms, and concluded that the primary attenuation processes for metals are sorption onto iron (and potentially clay minerals) and reduction/precipitation reactions with native iron. The primary mechanisms for chlorinated volatile organic compounds (CVOCs) are biodedgradation, sorption, and dispersion. The site specific assessment confirmed that reductants and sorbents that facilitate contaminant attenuation are present in the aquifer, supporting the viability of MNA for the Site.

34


Tier II Based on laboratory treatability studies, comparison of co-located soil and water samples, and groundwater concentrations along flowpaths, the mechanism for attenuation was confirmed, and the rates were estimated, consistent with EPA procedures. EPA suggests that the rate of attenuation be estimated via a process to calculate the MNA bulk attenuation rate. The site-specific bulk attenuation rates were calculated to range from 0.004 day-1 to 0.023 day-1 (a half-life of 0.5 year to 0.1 year) for the upper zone, and from 0.0005 day-1 to 0.0025 day-1 (a half-life of 4 years to 0.8 year) for the lower zone. This analysis suitably finds the mechanism and rate of MNA at the Site, and supports the viability of MNA. Tier III The Site’s capacity for attenuation was calculated by two methods, namely, mass balance and mineralogy (natural reactive iron). These calculations demonstrate that the aquifer has adequate capacity to attenuate the remaining dissolved material. Site stability was evaluated based on both stability during treatability testing and Site aquifer geochemistry. This evaluation concluded that there is sufficient stability to support MNA for the Site. Tier IV Monitoring is an integral part of this alternative. A monitoring plan, consistent with the Tier IV requirements, conditionally approved by the EPA, was submitted in August 2014, which detailed the network of monitoring wells, analytes, sampling and analysis frequency and methods, and reporting. Further, the monitoring plan will evaluate ground water data over time. In the event that concentrations trends are inconsistent with the project concentrations (discussed in Section 2.7) or with regulatory goals at sentinel wells, the monitoring report would include suggestions for additional steps (such as additional sampling, pilot studies or modeling).

35


The work completed to date included extensive evaluation of various amendments, amendment loading rates, amendment distribution, remediation efficacy, and treatment longevity/stability factors, each building upon the information learned in prior steps. Most recently, the March 2014 In Situ Pilot Program Progress and Evaluation Report (Evaluation Report) summarized, in a comprehensive manner, the progress and accomplishments of the program. The Evaluation Report concluded that the in situ program has successfully reduced contaminant concentrations significantly, has done so in a relatively short time frame, that the improvements are expected to be enduring, that active remediation from the injections will continue (in situ) for approximately a decade), and that MNA is viable moving forward, inclusive of a robust monitoring program. A proposed CEA/WRA/deed notice would also be implemented as part of Alternative 3. The total present value project costs for this Alternative are $9,125,000. As of June 2014, the injections are complete. Monitoring associated with this remedy will continue. For planning purposes, 30 years of monitoring is assumed. A Draft Monitoring Plan was submitted in August 2014, which was conditionally approved by the EPA.

5.2 Remedial Alternative Screening, Retained Remedial Alternatives In general, the purpose of screening remedial alternatives is to improve the quality of the Remedial Alternatives by narrowing down the number to include only the more robust choices. Alternative #1, No Action, is not a viable Remedial Alternative because it is not effective and does not satisfy the RAOs. Alternative #1 is NOT retained for detailed analysis. Alternatives #2 and #3 are retained for detailed analysis.

5.3 Detailed Analysis of Remedial Alternatives The Detailed Analysis of Remedial Alternatives was conducted in accordance with Superfund requirements in order to provide the synthesis of information needed to select the Site remedy. The evaluation process and comparative analysis of Alternatives are described in the following sections and in referenced Figures and Tables.

36


5.3.1 Superfund Evaluation Criteria In order to conduct a comprehensive, detailed analysis of the Remedial Alternatives, the RI/FS Guidance requires that each of the proposed Remedial Alternatives be assessed against the evaluation criteria that have been developed to address the statutory considerations listed under CERCLA. The nine criteria used to assess the Remedial Alternatives are listed below, including a brief description of each.

Threshold Criteria 1. Overall Protection of Human Health and the Environment;

• This criterion addresses whether each Alternative provides adequate protection of human health and the environment and describes how risk posed through each exposure pathway are eliminated, reduced or controlled through treatment, engineering controls and/or institutional controls.

2. Compliance with ARARs; • This criterion is used to determine how each Alternative complies with

applicable or relevant and appropriate Federal and State requirements, as determined in CERCLA Section 121.

Balancing Criteria 3. Long-Term Effectiveness and Permanence;

• This criterion addresses the results of a remedial action in terms of the risk remaining at the Site after the remedial action objectives have been met. The primary focus of this evaluation is to determine the extent and effectiveness of the controls that may be required to manage the risk posed by residual contamination. The factors to be evaluated include the magnitude of risk remaining at the end of the remedial activities; and the adequacy and reliability of controls used to manage remaining waste (untreated waste and treatment residuals over the long-term).

4. Reduction in Toxicity, Mobility, and Volume;

• This criterion addresses the statutory preference for selecting remedial actions that employs treatment to reduce the toxicity, mobility or volume of the contamination. The factors to be evaluated include the remediation process employed, the amount of hazardous material destroyed or treated, the degree of reduction expected in toxicity, mobility or volume and the type and quantity of residuals.

37


5. Short-Term Effectiveness;

• This criterion addresses the effects of the Alternative during the construction and implementation phase until the remedial actions have been completed and the selected level of protection has been achieved. Each Alternative is evaluated with respect to its effect on the community and on-site workers, environmental impacts resulting from implementation and the amount of time until protection is achieved.

6. Implementability; • This criterion addresses the technical and administrative feasibility of

implementing an Alternative and the availability of various services and materials required during its implementation. Technical feasibility considers construction and operational difficulties, reliability, ease of undertaking additional remedial action (if required) and the ability to monitor its effectiveness. Administrative feasibility considers activities needed to coordinate with other agencies (e.g., State and local) in regard to obtaining permits or approvals for implementing remedial actions, during the construction and implementation phase until the remedial actions have been completed and the selected level of protection has been achieved. Each Alternative is evaluated with respect to its effect on the community and on-site workers, environmental impacts resulting from implementation and the amount of time until protection is achieved.

7. Cost; • This criterion addresses the capital costs, annual operation and

maintenance costs, and present worth analysis. Capital costs consist of direct (construction) and indirect (non-construction and overhead) costs. Direct costs include expenditures for equipment, labor and material necessary to perform remedial actions. Indirect costs include expenditures for engineering, financial and other services that are not part of actual installation activities, but are required to complete the installation of Remedial Alternatives. Annual O&M costs are post-construction costs necessary to ensure the continued effectiveness of a remedial action.

All costs will be targeted toward an estimated accuracy of ±30 percent in 2015 dollars. Construction costs do not include legal, accounting, insurance or interest and financing charges that may be incurred in connection with the construction unless otherwise specified. Competitive bidding or market conditions may impact the costs. Estimates of

38


construction cost are made based on TRC’s experience and qualifications, vendor quotes and standard reference sources. There is no guarantee that proposals, bids, or actual project cost will not vary from the estimates presented herein.

A present worth analysis is used to evaluate expenditures that occur over different time periods by discounting all future costs to the current base year. This allows the cost of remedial action Alternatives to be compared on a common basis representing the amount of money that would be sufficient to cover all costs associated with the remedial action over its planned life. Unless otherwise stated, a discount rate of 5 percent before taxes and after inflation is assumed, with a maximum period of performance of 30 years.

Modifying Criteria (considered further after the public comment period) 8. State Acceptance;

• This criterion evaluates the technical and administrative issues and concerns the State of New Jersey may have regarding each of the Alternatives. The factors to be evaluated include those features of Alternatives that the state supports, reservations of the state, and opposition of the state. The NJDEP and the New Jersey Department of Health are the two primary State agencies expected to provide input to remedy acceptability. This criterion will be assessed following submittal of the draft FFS report based on input from these agencies during the regulatory review period.

9. Community Acceptance. • This criterion incorporates public concerns into the evaluation of the

Remedial Alternatives. Typically, community (and also state) acceptance cannot be determined during development of the RI/FS. Accordingly, evaluation of these criteria is postponed until the RI/FS is released for state and public review. These criteria are then addressed in the ROD and the responsiveness summary.

The first two criteria are considered threshold criteria and relate to the statutory requirements that the Alternative should satisfy. The next five criteria are considered balancing criteria, which are technical in nature and are used as the primary basis for evaluation. The final two are considered modifying criteria and are assembled formally

39


after the public comment period. Therefore, the last two criteria are not further discussed in this OU1 FFS evaluation. The Cost criterion warrants additional discussion, to facilitate analysis review, because regulation and EPA practice and guidance devotes specific references to this topic. However, it is noted that cost is only one of the nine criteria. The NCP dictates in 40 CFR 300.430(f)(1)(ii)(D) that remedial costs should be “proportional to its overall effectiveness.” In fact, the preamble to the NCP states that if “remedies examined are equally feasible, reliable, and provide the same level of protection, the agency will select the least expensive remedy” [underlining added]. The NCP notes in 40 CFR 300.430(e)(7)(iii) that alternatives may be screened out if costs are grossly excessive compared to their overall effectiveness. EPA’s Guidance to Conducting RI/FS Under Superfund precludes the selection of a higher cost Remedial Alternative where there is no proportional value. EPA’s Role of Cost in the Superfund Remedy Selection Process indicates that “cost is a central factor in all Superfund selection decisions.”

5.3.2 Individual Analysis of Remedial Alternatives The individual analyses of the Alternatives are summarized in Table 1 and are described in the following sections. The conceptual cost estimates for Remedial Alternative #2, P&T, is presented in Table 2. The summary of conceptual cost estimates for Remedial Alternative #3, ISR, is provided in Table 3.

5.3.2.1 Alternative # 2– P&T Alternative #2 would involve operation of the existing P&T system until such time as ARAR’s were achieved. Institutional controls would include a CEA/WRA.

Overall Protection of Human Health and the Environment –The CEA/WRA would protect human health by preventing exposure. No ecological risks exist. Compliance with ARARs – The chemical-specific ARARs would be met by this Alternative (though it would take many times longer than Alternative #3). Long-Term Effectiveness and Permanence – The CEA/WRA would prevent human exposure, which would be effective in the long term. Reduction of Toxicity, Mobility, or Volume – P&T would eventually reduce the toxicity, mobility or volume of OU1 constituents. Short-Term Effectiveness – There would be no substantial risks posed to the community or the environment associated with implementation of this Alternative.

40


Implementability – No technical implementability issues are associated with this Alternative. Implementability issues may include administrative delays in placing CEAs/WRAs. Cost – The estimated capital cost for this Alternative is $1,600,000. Annual OM&M costs for P&T are estimated to be $25,450,000, resulting in an estimated 30-year present worth cost of $27,050,000.

5.3.2.2 Alternative # 3- In Situ Processes (Injections/MNA) The completed injections have reduced mass and shifted geochemical conditions to favorable values. The ongoing MNA would provide the monitoring and synthesis to validate and confirm that RAO’s are being achieved. This Alternative includes establishment of a CEA/WRA.

Overall Protection of Human Health and the Environment – This Alternative addresses the RAOs by preventing direct exposure to human receptors via the CEA/WRA. Compliance with ARARs – This Alternative would comply with chemical specific ARARs by eliminating the potential for human exposure and reducing dissolved concentrations to ARARs. Long-Term Effectiveness and Permanence – The CEA/WRA will provide permanent protection and the injections have been demonstrated to be stable, so this Alternative is effective. Reduction of Toxicity, Mobility, or Volume– This Alternative does involves active and ongoing in situ treatment and therefore, there is reduction of toxicity, mobility or volume. Short-Term Effectiveness – Workers would likely be required to wear personal protective equipment (PPE) during the sampling associated with MNA monitoring to prevent direct contact. No significant risks to the community or the environment are anticipated under this Alternative. The RAOs would be achieved. Implementability – No significant technical implementability issues are associated with this Alternative. No action-specific administrative implementability issues are associated with this Alternative. Cost – The estimated capital cost for this Alternative is $8,800,000. Annual OM&M costs for groundwater monitoring, etc. are estimated to be $490,000, resulting in an estimated 30-year present worth cost of $9,125,000.

41


5.3.3 Comparative Analysis The Remedial Alternatives for OU1 are discussed in the subsection below. The results of the detailed evaluation were used in this section to conduct a comparative analysis of Alternatives to identify the relative advantages and disadvantages of each. The results of this analysis could be used as a basis for recommending Remedial Alternatives. There are two Remedial Alternatives retained in the evaluation discussed in Sections 4.4 and 5.2, namely:

• Alternative #2- P&T • Alternative #3- In Situ Processes (Injections/MNA)

These Alternatives are compared to each other, per each of the nine criteria, in the following subsections.

5.3.3.1 Overall Protection of Human Health and the Environment The goal of this criterion is to either eliminate the toxicity of the chromium and TCE concentrations in groundwater or to prevent exposure by human receptors. Alternatives #2 and #3 can both achieve this criterion. Both Alternatives #2 and #3 would prevent exposure by a CEA/WRA.

5.3.3.2 Compliance with ARARs Both Alternatives #2 and #3 fully comply with ARARs, though Alternative #3 would achieve ARARs significantly faster.

5.3.3.3 Long Term Effectiveness Alternative #2 achieves long term effectiveness primarily by prevention of exposure via the CEA/WRA. Alternative #3 achieves additional long term effectiveness because it allows ongoing active in situ remediation to continue, which expedites the cleanup time. The CEA/WRA for Alternative #3 is also effective in the short term by preventing exposure.

42


5.3.3.4 Reduction in Toxicity, Mobility or Volume Alternative #2 would provide some treatment, ex situ, but would treat less volume. In fact, Alternative #2 would reverse the positive effects of injections, to date, by removing the injectant from the aquifer. Alternative #3 has achieved the greatest reduction in toxicity, mobility and volume via the active remediation processes associated with the injections. These reductions will continue, while additional reductions are achieved through MNA.

5.3.3.5 Short-Term Effectiveness There would be no substantial risks to the community or the environment associated with implementation of Alternatives #2 or #3. Workers running the treatment plant have the potential for longer term exposures associated with the operations of Alternative #2. Workers performing MNA sampling/monitoring of Alternative #3 have the potential to be temporarily exposed to contaminants, but this risk is minimized by the use of PPE and protective measures.

5.3.3.6 Implementability No significant technical implementability issues are associated with Alternatives #2 and #3. Alternative #2 has the greatest implementability challenges associated with running a 24/7 P&T operation.

5.3.3.7 Cost The conceptual cost estimate for Remedial Alternative #2, P&T, is included as Table 2. The conceptual cost estimates for Remedial Alternative #3, In Situ, is included as Table 3.

• Alternative #2—P&T has the highest cost due to long term OM&M. Total Present Value Project Costs are $19,450,000.

• Alternative #3— In Situ Processes (Injections/MNA) has a moderate cost. Total Present Value Project Costs are $9,125,000.

5.4 Green Remediation Principles The EPA is fostering “Green Remediation” principles for Site cleanups. Although not specifically required in feasibility studies by statute, the discussion of Green Remediation principles promotes sustainable site management ideals. Specifically, EPA has issued a

43


Green Remediation Strategy encouraging, where possible, the incorporation of options into remedies that minimize the environmental footprint of cleanup actions. EPA, particularly Region 2, advocates for the implementation of Green Remediation principles. The EPA outlines key Green Remediation principles in EPA’s Superfund Green Remediation Strategy, as follows:

1. Minimize Total Energy Use 2. Minimize Air Pollutants and Greenhouse Gas Emissions

• Minimize the generation of greenhouse gases • Minimize generation and transport of airborne contaminants and dust • Sequester carbon on-site (e.g., soil amendments, re-vegetate)

3. Minimize Water Use and Impacts to Water Resources • Minimize water demand for re-vegetation (e.g. native species) • Employ best management practices for stormwater

4. Reduce, Reuse and Recycle Material and Waste • Minimize consumption of virgin materials • Minimize waste generation • Use recycled products and local materials • Beneficially reuse waste materials • Segregate and reuse or recycle materials, products, and infrastructure (e.g.

soil) 5. Protect Land and Ecosystems, including

• Minimize areas requiring activity or use limitations (e.g., destroy or remove contaminant sources) and

• Minimize unnecessary soil and habitat disturbance or destruction For OU1, Alternative #3, ISR, better supports the Green Remediation Principles because it uses less energy, minimizes air emissions, minimizes water use, generates less waste and is protective of the land and eco system.

44


6. CONCLUSIONS This FFS identifies and evaluates two Remedial Alternatives to clean up OU1 groundwater in a manner suitable to support the selection of an Amended Proposed Plan.

45


7. REFERENCES

January 2011(TRC): Human Health Risk Assessment (HHRA, TRC, 1995);

Pre Design Investigation Report (TRC, 2011);

(2. USEPA, 1997a/b); USEPA. Innovative Measures for Subsurface Chromium Remediation: Source Zone, Concentrated Plume, and Dilute Plume. Environmental Research Brief by D. A. Sabatini, R. C. Knox, E. E. Tucker, and R. W. Puls. EPA/600/S-97/005; 1997b.;

USEPA. Engineered Approaches to In Situ Bioremediation of Chlorinated Solvents: Fundamentals and Field Applications. EPA 542-R-00-008; July 2000a. (USEPA, 2000a); USEPA. In Situ Treatment of Soil and Ground water Contaminated with Chromium. Technical Resource Guide: EPA/625/R-00/005; October 2000b. (USEPA, 2000b); Independent Environmental Technical Evaluation Group (IETEG). Chromium(VI) Handbook. 2005. CRC Press. (IETEG, 2005); Interstate Technology & Regulatory Cooperation (ITRC). Technical and Regulatory Requirements of In-Situ Bioremediation of Chlorinated Solvents in Ground water. December 1998. (ITRC, 1998);

1992 Remedial Investigation Report (RIR) (TRC, 1992);

February 14, 2013 (TRC): Memorandum on EPA Procedural Assessment of MNA of Chromium in Groundwater at the Shieldalloy Corporation Superfund Site, Newfield, New Jersey (TRC, 2013);

March 6, 2013 (TRC): OU1 In-Situ Remediation Pilot Program Progress Report (TRC, 2013);

May 24, 2013 (TRC): Memorandum on SMC MNA Model (TRC, 2013);

March 2014. Draft OU1 In Situ Remediation Pilot Program Evaluation Report (TRC);

USEPA, 2007. BIOSCREEN Model Release (USEPA, 2007); (OSWER), Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (OSWER Directive 9355.3-01, EPA, 1988a) herein referred to as “RI/FS Guidance”Palmers & Puls, 1994;

OSWER Directive 9285.7-53;

(Palmer & Puls, 1994);

46


Freedman, D.L. and Verce, M.F. The Effect of Chemically Reducing Chromium(VI) with Polysulfides on Reductive Dechlorination of PCE. In Situ and On-Site Bioremediation: 7th International Symposium-Battelle, June 2003. Orlando, Florida. (Freedman and Verce, 2003); Jung, Y.J. and Lee. W. The Reduction Kinetics of Hexavalent Chromium by Soluble Fe(II) and Magnetite. European Geosciences Union 2005, Geophysical Research Abstracts, Vol. 7 (SRef-ID: 1607-7962/gra/EGU05-A-04530). (Jung and Lee, 2005); Kolstad, D.C., Quast, C.L. and Richard D.E. In Situ Remediation of Hexavalent Chromium Contaminated Soil with Calcium Polysulfide Solution. 3rd International Conference on Oxidation and Reduction Technologies for In-Situ Treatment of Soil and Ground water, October 2004, San Diego, California. (Kolstad et al., 2004); Loeper, J.M., R.A. Brown, and D. Robinson. Bench Scale Evaluation of Chemical Reduction as a Treatment Technology for Hexavalent Chromium. 2nd International Conference on Oxidation and Reduction Technologies for In-Situ Treatment of Soil and Ground water, November 2002, Toronto, Canada. (Loeper et al., 2002); (37. Murt et al., 2010a&b)

Murt, V., Yun, K., Tsang, F., Olsen, R., and Cutt, D. A Comparative In Situ Pilot Study of Lactate and Calcium Polysulfide for Geochemical Fixation of Hexavalent Chromium in Groundwater. Battelle 7th Int. Conference on Remediation of Chlorinated Compounds and Recalcitrant Compounds (ISBN 978-0-9819730-2-9), May 2010a, Monterey, CA. (Murt et al., 2010a&b); Murt, V.K., Olsen, R., Burgesser, T. and Cutt, D. A Comparative Bench-Scale Study of Five Reducing Agents for In Situ Geochemical Fixation of Hexavalent Chromium in Groundwater. Battelle 7th International Conference on Remediation of Chlorinated Compounds and Recalcitrant Compounds, May 2010b Monterey, CA. (Murt et al., 2010a&b);

Storch, P., Messer, A., Palmer, D., and Pyrih, R. In-Situ Geochemical Fixation of Chromium (VI) Using Calcium Polysulfide; Part I: Vadose Zone Pilot Test. National Ground Water Association: Southwest Focus Conference: Water Supply and Emerging Contaminants, Phoenix, Arizona; February 2003. (Storch et al., 2003); Tremaine, J. and Keel, N.L. In-Situ Remediation of Hexavalent Chromium in Ground water: Practical Implementation. Abiotic In Situ Technologies for Ground water Remediation Conference Proceedings, Dallas, Texas (September 1999). EPA/625/R-99/012; August 2000. (Tremain and Keel, 2000); US Department of Energy (USDOE). Treatability Test Report for Calcium Polysulfide in the 100-K Area. DOE/ERL-2006-17; Feb 2006. (USDOE, 2006); Wazne, M., Jagupilla, S.C. Moon, D.H. Jagupilla, S.C. Christodoulatos, C., and Kim, M.G. Assessment of Calcium Polysulfide for the Remediation of Hexavalent Chromium

47


in Chromite Ore processing Residue (COPR). Journal of Hazardous materials, 2007. 143(3):620-8. (Wazne et al., 2007); Zawislanski, P.T., Beatty, J.J., and Carson, W. L. Long-Term Stability of Metals Following In-Situ Treatment of Acidic Ground water Using Calcium Polysulfide. 3rd International Conference on Oxidation and Reduction Technologies for In-Situ Treatment of Soil and Ground water, San Diego, California. October 2004. (Zawislanski et al., 2004);

Wiedemeier, T.H., M.A. Swanson, D.E. Moutoux, E.K. Gordon, J.T. Wilson, B.H. Wilson, D.H. Kampbell, P.E. Haas, R.N. Miller, J.E. Hansen, and F.E. Chapelle, 1998. Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Groundwater. United States Department of Environmental Protection National Risk Management Research Laboratory, Cincinnati, Ohio. (EPA, 1998);

Sims, J.L., J.M. Sulflita, and H.H. Russell, 1989. “In-Situ Bioremediation of Contaminated Groundwater”. EPA/540/S-92/003. Technical Publication of U.S. Environmental Protection Agency, R.S. Kerr Environmental Research Laboratory, Ada, Oklahoma. (EPA, 1989);

Lawrence, S.J., 2006. Description, Properties, and Degradation of Selected Volatile Organic Compounds Detected in Groundwater-A Review of Selected Literature. US Geological Survey Open-File Report 2006-1338. (Lawrence, 2006);

Gelhar, L. W. and J.L. Wilson, 1974. Ground-water quality modeling. Ground Water. V. 12, no.6, pp. 399-408;

USEPA, 1988. Guidance on Remedial Actions for Ground Water at Superfund Sites. EPA/540/G-88/003. OSWER Directive 9283.1-2, December 1988;

Driscoll, F.A., 1986. Groundwater and Wells. The Johnson Division, St. Paul, MN;

Walton, W.C., 1991. Principles of Groundwater Engineering. Lewis Publishers, Boca Raton;

Howard, P.H., Boethling, R.S. Jarvis W.F., Meylan, W.M., and Michalenko, E.M., 1991. Handbook of Environmental Degradation Rates. Lewis Publishers;

March 20, 2014 (TRC): OU1 In-Situ Remediation Pilot Program Progress Report (TRC, 2014);

June 2010 (TRC): Annual Groundwater Monitoring Report (TRC, 2010);

January 2015 (TRC); OU1 Risk Calculation Update.

48

FIGURES

TRC ENVIRONMENTAL CORP.

57 East Willow Street

Millburn, New Jersey 07041

phansen

Text Box

MARCH 2015


41 Spring Street New

Providence, NJ 07974










CPS "SWEEPING"

TREATMENT ZONE

G

R

O

U

N

D

W

A

T

E

R

F

L

O

W

D

I

R

E

C

T

I

O

N

UPW-6

UPW-5

UPW-2

UPW-4

UPW-3

UPW-1

UPW-7

U1-B

U2-A

U2-C

U3-C

U5-B

U2-B

U2-D

U1-A

U1-C

U3-D

U3-B

U3-A

U4-A

U4-B

U4-C

U5-A

U5-C

ROWS OF UPPER

ZONE INJECTION

WELLS CREATE CPS

REACTIVE ZONE


57 East Willow Street

Millburn, New Jersey 07041

UPW-1

U2-A

GROUND WATER

FLOW DIRECTION

INJECTION

WELLS

KIRKWOOD CLAY

CPS REACTIVE

ZONE

GROUND SURFACE

CONCEPTUAL CROSS SECTION FOR UPPER AND LOWER ZONES

N.T.S.

UP

PE

R T

RE

AT

ME

NT

Z

ON

E

GROUND WATER

FLOW DIRECTION

LO

WE

R T

RE

AT

ME

NT

Z

ON

E

CPS "SWEEPING"

TREATMENT ZONE

ZO

NE

M

IN

IM

AL

LY

IM

PA

CT

ED

PHansen

Text Box

6

PHansen

Text Box

5

phansen

Text Box

TABLES

2335/FS Technical Memo 2011/SMC OU1 FS Table 1 - Detailed Analysis of Remedial Alternatives Page 1 of 1

Injections for in situ treatment

Monitored Natural AttenuationCEA/WRA

High 3 Moderate 2

In Situ/MNA would protect human health by accelerating cleanup of the

aquifer

P&T would protect human health by containing plume

High 3 Moderate 2

In Situ/MNA would achieve ARARs several times faster than P&T P&T would eventually achieve ARARs

High 3 Moderate 2

In Situ/MNA is effective in the long term, and is permanent. In Situ/MNA is

far "greener", which makes it more effective also.

P&T is reliant on mechanical items, which has some degree of

ineffectiveness

High 3 Moderate 3

Both alternative provides treatment (one ex situ, one in

situ).

In Situ/MNA has greatly reduced plume toxicity and mobility and volume.

P&T reduces toxicity of water after it is pumped from the aquifer.

High 3 High 3

In the short term, the community and workers are not effected (injections have

been completed without incident).

In the short term, the community is not effected. Site workers at the WWTP

have some exposures, but are protected by health and safety protocols.

High 3 Moderate 2

Implementation is straightforward. Implementation is straightforward, but is labor and equipment intensive.

Moderate 2 Highest 1

High capital cost, but moderate O&M. High capital and high O&M costs.

20 15

Notes: Color codes reflect total scores as shown below

Scores from 0 to 15 Scores from 15 to 18 Scores 19 and up

High 3 Low 1

Very green, and environmentally friendly.

High energy usage, water resource waste.

Cost Capital and O&M

Green Remediation

Table 1Detailed Analysis of OU1 FFS Alternatives

Shieldalloy Metallurgical Corporation Superfund SiteNewfield, NJ

Total Score

In Situ/MNA

Overall protection of human health and the

environment

ImplementabilityConstructability/

Reliability

Compliance with ARARs

REMEDIAL ALTERNATIVES

2

Pump and Treat

Reduction in toxicity, mobility, volume through

treatment

Short-term effectivenessFor community and

workers

CEA/WRAEx situ treatment/discharge

NJDEP GWQS

Long-term effectiveness and permanence

Scale of risk reduction and

reliability of control

1

Extraction wells

C:\Users\phansen\Documents\Shield\OU1 FFS\March 2015\shield OU1 FFS Cost Estimates Page 1 of 1

CAPITAL COST

Item Estimated Quantity

Units Unit Price Total Cost (rounded)

WWTP construction (ion exchange) 1 LS 1,000,000$ 1,000,000$

Subtotal Direct Construction Costs 1,000,000$

Contingency 20% 200,000$ Project Management 10% 100,000$

Remedial Design 10% 100,000$ Engineering and Construction Management 10% 100,000$

Legal and Administrative 5% 50,000$ EPA Oversight Fees 5% 50,000$

TOTAL CONSTRUCTION COSTS (rounded) 1,600,000$ O&M Costs

Item Frequency Quantity Units Rate/Cost Per Event

Total Cost (rounded)

WWTP operation annual 30 LS $ 500,000 $ 15,000,000 Discharge monitoring annual 30 LS 20,000$ 600,000$ Groundwater monitoring--years 1 and 2 semiannual 4 LS 15,000$ 60,000$ Groundwater monitoring--years 3-5 annual 3 LS 15,000$ 45,000$ Groundwater monitoring--6-10 biennual 5 LS 15,000$ 75,000$ Groundwater monitoring--years 11-30 every 5 years 5 LS 15,000$ 75,000$ 5-year review every 5 years 5 LS 10,000$ 50,000$

Sub-Total OM&M (30 Years): 15,905,000$

Contingency 20% 3,181,000$ Project Management 10% 1,591,000$

Remedial Design 10% 1,591,000$ Construction Management 10% 1,591,000$ Legal and Administrative 5% 795,000$

EPA Oversight Fees 5% 795,000$

TOTAL OM&M COSTS (rounded): 25,450,000$

TOTAL PROJECT COSTS (UNADJUSTED For NPV): 27,050,000$

NPV ANALYSISSub-Total OM&M (30 Years from next table): 6,655,800$

O&M COST MARKUPSContingency 20% 1,331,160$

Project Management 10% 665,580$ Remedial Design 10% 665,580$

Construction Management 10% 665,580$ Legal and Administrative 5% 332,790$


TOTAL OM&M COSTS (rounded): 10,650,000$

TOTAL PRESENT VALUE PROJECT COSTS: 12,250,000$

Table 2Conceptual Cost Estimate

OU1 FFS Remedial Alternative #2: Pump and TreatShieldalloy Metallurgical Superfund Site; Newfield, NJ

Remedial Alternative Description: Pumping and treating ex situ. Ground water monitoring and discharge monitoring. WWTP operation. CEA/WR.


CAPITAL COST

Monitoring WWTP O&M Discharge Monitoring Monitoring 5-year review PRESENT VALUE

(AT 7% DISCOUNT RATE)

0 8,800,000$ 8,800,000$ 1 15,000$ 500,000$ 20,000$ 45,000$ 580,000$ $542,0562 15,000$ 500,000$ 20,000$ 45,000$ 580,000$ $506,5943 15,000$ 500,000$ 20,000$ 535,000$ $436,7194 15,000$ 500,000$ 20,000$ 535,000$ $408,1495 15,000$ 500,000$ 20,000$ 10,000$ 545,000$ $388,5776 500,000$ 20,000$ 520,000$ $346,4987 15,000$ 500,000$ 20,000$ 535,000$ $333,1718 500,000$ 20,000$ 520,000$ $302,6459 15,000$ 500,000$ 20,000$ 535,000$ $291,005

10 500,000$ 20,000$ 10,000$ 530,000$ $269,42511 15,000$ 500,000$ 20,000$ 535,000$ $254,17512 500,000$ 20,000$ 520,000$ $230,88613 500,000$ 20,000$ 520,000$ $215,78214 500,000$ 20,000$ 520,000$ $201,66515 15,000$ 500,000$ 20,000$ -$ 10,000$ 545,000$ $197,53316 500,000$ 20,000$ 520,000$ $176,14217 500,000$ 20,000$ 520,000$ $164,61918 500,000$ 20,000$ 520,000$ $153,84919 500,000$ 20,000$ 520,000$ $143,78420 15,000$ 500,000$ 20,000$ -$ 10,000$ 545,000$ $140,83821 500,000$ 20,000$ 520,000$ $125,58722 500,000$ 20,000$ 520,000$ $117,37123 500,000$ 20,000$ 520,000$ $109,69224 500,000$ 20,000$ 520,000$ $102,51625 15,000$ 500,000$ 20,000$ -$ 10,000$ 545,000$ $100,41626 500,000$ 20,000$ 520,000$ $89,54227 500,000$ 20,000$ 520,000$ $83,68428 500,000$ 20,000$ 520,000$ $78,20929 500,000$ 20,000$ 520,000$ $73,09330 15,000$ 500,000$ 20,000$ -$ 10,000$ 545,000$ $71,595

7% Discount Factor Total Unadjusted Costs: 15,930,000$ Total Discounted OM&M Costs (rounded): $6,655,800

Table 2aConceptual Cost Estimate

OU1 FFS Remedial Alternative #2: P&T, NPVShieldalloy Metallurgical Superfund Site; Newfield, NJ

YEAR

OM&M COSTS (W/CONTINGENCY)

Total Annual Cost

(Rounded, Not Adjusted

for Inflation)

Annual OM&M Periodic OM&M


CAPITAL COST

Item Estimated Quantity

Units Unit Price Total Cost (rounded)

Injections 1.0 LS 5,500,000$ 5,500,000$

Subtotal Direct Construction Costs 5,500,000$

Contingency 20% 1,100,000$ Project Management 10% 550,000$

Remedial Design 10% 550,000$ Engineering and Construction Management 10% 550,000$

Legal and Administrative 5% 275,000$ EPA Oversight Fees 5% 275,000$

TOTAL CONSTRUCTION COSTS (rounded) 8,800,000$ O&M Costs

Item Frequency Quantity Units Rate/Cost Per Event

Total Cost (rounded)

Groundwater monitoring--years 1 and 2 semiannual 4 LS 15,000$ 60,000$ Groundwater monitoring--years 3-5 annual 3 LS 15,000$ 45,000$ Groundwater monitoring--6-10 biennual 5 LS 15,000$ 75,000$ Groundwater monitoring--years 11-30 every 5 years 5 LS 15,000$ 75,000$ 5-year review every 5 years 5 LS 10,000$ 50,000$

Sub-Total OM&M (30 Years): 305,000$

Contingency 20% 61,000$ Project Management 10% 31,000$

Remedial Design 10% 31,000$ Construction Management 10% 31,000$ Legal and Administrative 5% 15,000$


TOTAL OM&M COSTS (rounded): 490,000$

TOTAL PROJECT COSTS (UNADJUSTED For NPV): 9,290,000$

NPV ANALYSISSub-Total OM&M (30 Years from next table): 203,100$

O&M COST MARKUPSContingency 20% 40,620$

Project Management 10% 20,310$ Remedial Design 10% 20,310$

Construction Management 10% 20,310$ Legal and Administrative 5% 10,155$


TOTAL OM&M COSTS (rounded): 325,000$

TOTAL PRESENT VALUE PROJECT COSTS: 9,125,000$

Table 3Conceptual Cost Estimate

OU1 FFS Remedial Alternative #1: In Situ RemediationShieldalloy Metallurgical Superfund Site; Newfield, NJ

Remedial Alternative Description: Injections to treat in situ. Monitoring to confirm active treatment, then confirm ongoing natural attenuation. CEA/WR.


CAPITAL COST

Monitoring Monitoring 5-year review PRESENT VALUE(AT 7%

DISCOUNT RATE)

0 8,800,000$ -$ -$ 8,800,000$ 1 15,000$ 45,000$ 60,000$ $56,0752 15,000$ 45,000$ 60,000$ $52,4063 15,000$ 15,000$ $12,2444 15,000$ 15,000$ $11,4435 15,000$ 10,000$ 25,000$ $17,8256 -$ $07 15,000$ 15,000$ $9,3418 -$ $09 15,000$ 15,000$ $8,159

10 10,000$ 10,000$ $5,08311 15,000$ 15,000$ $7,12612 -$ $013 -$ $014 -$ $015 15,000$ -$ 10,000$ 25,000$ $9,06116 -$ $017 -$ $018 -$ $019 -$ $020 15,000$ -$ 10,000$ 25,000$ $6,46021 -$ $022 -$ $023 -$ $024 -$ $025 15,000$ -$ 10,000$ 25,000$ $4,60626 -$ $027 -$ $028 -$ $029 -$ $030 15,000$ -$ 10,000$ 25,000$ $3,284

7% Discount Factor Total Unadjusted Costs: 330,000$ Total Discounted OM&M Costs (rounded): $203,100

Table 3aConceptual Cost Estimate

YEAR

OM&M COSTS (W/CONTINGENCY)

Total Annual Cost

(Rounded, Not Adjusted

for Inflation)

Annual OM&M Periodic OM&M

OU1 FFS Remedial Alternative #1: In Situ, NPVShieldalloy Metallurgical Superfund Site; Newfield, NJ

Date post:	06-Oct-2020
Category:	Documents
Upload:	others
View:	1 times
Download:	0 times