11.0 CERCLA Overview - Superfund Process

11.0 CERCLA Overview

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, came into being on December 11, 1980 (EPA, 2011).  CERCLA endowed a federal tax unto chemical and petroleum industries, which monitored their direct and/or threat of direct releases of hazardous substances into the environment.  Over a duration period spanning five years, $1.6 billion dollars was allocated from these induced taxes.  This money was set aside to be used for the clean up of abandoned or uncontrolled hazardous waste sites (EPA, 2011).

Through CERCLA, the Environmental Protection Agency (EPA) was given the power to seek out the responsible parties of these contaminated sites and assure their cooperation under their remediation guidelines.  In cases where a responsible party cannot be identified or located, or if they fail to remediate the site to standard, the EPA will then obtain a private party cleanup through orders, consent decrees, and other party settlements (EPA, 2011). 

CERCLA authorizes two kinds of response actions, short-term removals as well as long-term removals.  In short-term removals action needs to be taken promptly in order to address releases or the threat of releases to humans and the environment.  Long-term remedial response actions are put into place to permanently and significantly reduce the dangers associated with releases or threats of releases that are serious, but not immediately life threatening (EPA, 2011).  Actions of the long-term remedial response can only be conducted at sites listed on the EPA's National Priorities List (NPL).  Sites are proposed to the NPL in the Federal Register, and are listed on the NPL after completion of the Hazard Ranking System (HRS). 

The HRS is the principal mechanism used by EPA to place waste sites on the National Priorities List.  HRS scores are based on four pathways, groundwater migration, surface water migration, soil exposure, and air migration.  These scores are numerical and given after a preliminary assessment and site inspection is done at the site.

The preliminary assessment (PA) is the first step for determining whether a hazardous site poses a potential risk to human health and the environment.  The EPA publication Guidance for Performing Preliminary Assessments Under CERCLA, September 1991, gives a more detailed account on the format of the Preliminary Assessment.  If the PA investigation warrants further investigations, a Site Inspection (SI) is performed.  It is during the SI that the site enters the NPL Site Listing Process, and data granted from the Site Investigations is used to gain a HRS score.  The EPA publication Guidance for Performing Site Inspections Under CERCLA; Interim Final, September 1992, gives a more detailed account on the format of the Site Investigation process.  Sites with a Hazardous Ranking Scores of 28.50 or greater are eligible for listing on the National Priorities List.

10.0 Current Status of the Roebling Steel Mill Superfund Site

10.0 Current Status of the Roebling Steel Mill Superfund Site

May 2010 – Community Update

Document: Included in Additional Links

Dredging of Crafts Creek and Delaware River Back Channel sediments is currently underway.  There is a temporary staging area near Crafts Creek for dewatering and a water collection system for the removal of excess water from dredged sediments.  The area also includes a decontamination pad, allowing vehicles to decontaminate before leaving the staging area.  The Slag Area, has been subgraded, and currently is receiving dredged materials from Crafts Creek and the Delaware River Back Channel.  93,000 cubic yards of sediments are being dredged from Crafts Creek and the Back Channel using mechanical dredging equipment, such as long stick excavator for near shore sediments and a barge for off-shore sediments.  The excavated sediments are then being transported by barge to the dewatering staging area.  The dewatered sediments are being transported in water-tight trucks using Route 130 and Hornberger Avenue.  Air monitoring and turbidity controls are in place to monitor activities on Site.  After placement of Sediments onto the Slag Area is complete, a two-foot soil cap consisting of 18-inches of common fill and 6-inches topsoil and vegetation will be placed atop to support vegetation.  A permeable liner will be placed beneath the cap to act as a visible marker to minimize direct contact should the overlying cap be breeched.  The area will then be utilized for passive recreation.  A map depicting future land use is depicted below:

10.1  Community Interviews

A few e-mails were sent to Case Management Tamara Rossi with direct questions relating to the Roebling Steel Mill Site.  To date a response from Ms. Rossi has not been obtained.  All documentation used to fulfill this project was found at the Florence Township Library, located in Roebling, New Jersey.  Residents were questioned from the town of Roebling, and questions were asked by myself, Trisha Muni.  Being a resident of Florence Township for twenty three years I also used myself as a reference in dealing with this Superfund Site.  When asking residents questions about the details of the Roebling Steel Mill, I got a concept of overall understanding and involvement to be low.  Residents felt ill informed and uninvolved in the process that was unfolding in their town.  I had known the Steel Mill was a Site of contamination, but the whole picture was not clear to me until I started working on this project.  While I make my blog for this course, I will also perfect it and condense it for community access.  I feel it is my duty to inform my fellow townspeople of the tasks that are ongoing on the 200-acre Roebling Steel Mill Site.  This Steel Mill was a source of pride for this town, and now it is but a vacant land, roped off by a chain link fence.  The town of Roebling is seeing a glimpse of hope through the building of the Lightrail throughout Roebling and Florence Township, and is hoping to see more changes in the future as OU-3 and OU-5 operations near completion.  EPA is working with Roebling to remediate the Site and bring back this sense of pride to Florence Township, this steps are unfolding and we are beginning to see the outcome of EPAs hard work.  Soon this abandoned Site will once again be in use, while protecting human health and the environment amongst it.

9.0 Fourth Record of Decision (ROD): 2003

9.0 Fourth Record of Decision (ROD): 2003

Record of Decision:  September 30, 2003

Document: Located under Record of Decision Links

The fourth ROD was signed on September 30, 2003 in order to address remediation of site-wide soil, sediments in the Delaware River and Crafts Creek, and groundwater.  It also amended the Record of Decision for OU-3, the slag area.

9.1 Areas of Concern (OU-5):

• Soils
• Sediments
• Groundwater

9.2 Human Health Risk Assessment/Environmental Risk Assessment:

For the soil and sediment component of OU-5, the remedial action needed to prevent human exposure to the site-wide soils, sediments and slag material based on current and future uses.  The remedy needed to reduce risk to ecological receptors from exposure to contaminated soils and sediments. As well as minimize migration from soil, sediments, and slag material to the groundwater and surface waters.  The groundwater needed to be restored to the drinking water standard within a reasonable time frame.  EPA Region 2 has determined that it is technically impracticable to restore groundwater to meet ARARs and invoked a Technical Impracticability waiver for the Site.

9.3 Description of Alternatives

Soils

• Alternative SL1: No Action
• Alternative SL2: Limited Action
• Alternative SL3: Containment
• Alternative SL4: Source Removal/Off-Site Disposal
• Alternative SL5: Excavation/Soil Washing/On-Site Backfill
• Alternative SL6: In Situ Stabilization/Containment

Sediments

• Alternative SD1: No Action
• Alternative SD2: Limited Action
• Alternative SD3: Containment
• Alternative SD4: Dredging/Dewatering/Off-Site Disposal
• Alternative SD5: Dredging/Dewatering/On-Site Backfill

Groundwater

• Alternative GW1: No Action
• Alternative GW2: Limited Action
• Alternative GW3: Containment via Barrier Walls
• Alternative GW4: Restoration (Extraction Wells for Pump-and-Treat)
• Option (a): with source removal
• Option (b): without source removal

9.4 Selected Remedy

OU-5 (Taking into consideration the amendment of the OU-3 Remedy):

The selected remedies for OU-5, included SL3, SD5, and GW2. 

Soils:

• Capping of site-wide contaminated soil (includes both the slag area and main plant area) with storm water management system and erosion controls along the shoreline
• Dredging the contaminated sediments in the Back Channel and Crafts Creek,
• Implementation of a long-term maintenance and monitoring program to ensure integrity of the capped areas
• Institutional controls to restrict the future excavations through the soil cap and limit future land uses

Sediments:

• Dredging of the contaminated sediments in the Delaware River and Crafts Creek
• Dewatering and capping of the dredged on-site sediments
• Backfill by placement of a sandy loan soil with organic matter and restoration of dredges areas by re-establishing wetlands

Groundwater:

• Implementation of a long-term groundwater sampling and analysis program to monitor the contaminant concentrations at the Site, and assess migration and attenuation of contaminants over time
• Institutional controls to restrict the installation of wells and use of contaminated groundwater in the vicinity of the Site

9.5 Construction Completion/Underway:

Operable Unit 5 (OU-5):

The soil component of the remedial action for OU-5 has been completed.  Soil capping of 5 acres and construction of the New Jersey Transit River Line station stop at Roebling was completed in 2005.  A deed notice was placed on NJ Transit River Line station stop portion of the Site to limit any alteration, improvement, or disturbance of Site soils. 

Ongoing activities include:

• Construction at Isolated Parcel:
• Soil capping and shoreline stabilization of the isolated parcel (area east of Crafts Creek).  Construction activities are underway.
• Design of Sediment Dredging:
• Dredging of approximately 240,000 cubic yards of contaminated sediments is currently underway, and may take several years.  Once complete the slag area will be capped with a soil cover
• Groundwater Pre-design Investigation:
• Is currently underway to develop a groundwater baseline for assessing potential groundwater impacts to surface water and identify future monitoring needs.

Operable Unit 3 (OU-3):

Final Design:

Passive recreation:

• All graded areas will receive a loam and seed cover
• 12 foot wide sidewalk has been provided along the Delaware River side of the site, which also provides maintenance access to storm water bioretention basin
• 2 walkways provide linkage to adjacent neighborhoods, one from end of Ninth Avenue, the other at the intersection of Riverside Avenue and 5th avenue
• Walkway at 9th ave. 12feet wide and provides additional potential vehicular maintenance.

Drainage:

• Includes water quality improvements for offsite runoff from the residential area south of OU3 site, as well as on-site runoff
• Design includes off-site drainage collection and storm water management facilities needs to be compatible with and allow room for sediment placement

8.0 Third Record of Decision (ROD): 1996

8.0 Third Record of Decision (ROD): 1996

Record of Decision:  March 30, 1996

Document: Locatated under Record of Decision Links

This Record of Decision focused on the remediation of 70 abandoned buildings throughout the Site containing processed dusts, residues, underground and aboveground tanks, pits and sumps, underground piping systems, and damaged friable asbestos (OU-4).  This required a supplemental remedial investigation (RI) for selected area on the Site.  The RI was completed in May 1995, and included underground utility surveys, asbestos determinations, building sampling, tank sampling in order to characterize wastes, and treatability studies to evaluate building decontamination procedures. 

8.1 Areas of Concern (OU-4):

• Underground Piping Systems
• Exhibited moderate levels of metal contaminants
• Tank Contents
• Over 100 tanks, both within buildings and exterior underground storage tanks (USTs)
• Samples showed at least one exceedance of a characteristic hazardous waste for barium, lead, or cadmium
• UST samples showed concentrations of toluene, ethylbenzene, and xylenes, as well as acetone, 1,2-dichloroethane, and benzene. One UST also contained PCBs, Aroclor 1248 was detected at 25.8ppm
• Interior tanks contained PAHs and low concentrations of volatile organics
• Buildings
• Chip, dust, pit and sump samples were collected
• Exceedances for lead, inorganics, carcinogenic PAHs and PCBs were present
• Asbestos
• 244,000 sq. feet and 44,000 linear feet of friable asbestos material was identified throughout the facility.
• Insulation material around pipes, showed friable asbestos present in every building

8.2 Human Health Risk Assessment/Environmental Risk Assessment:

The presence of hazardous substances with the tanks, pits and sumps, and underground piping is a concern.  Trespassers or those working on Site may be exposed to these hazardous materials.  Tanks, pits and sumps, and piping has the potential to deteriorate and leak with time, causing a release of hazardous material into the environment, including the surface water and ground water.  Building collapse has the potential to release friable asbestos.  

Exposure assessments identified health effects that could result from inadvertant ingestion, dermal contact, and inhalation.  The likelihood of noncarcinogenic risks were assessed using the hazard index (HI), for OU-4, the Site was given an HI of 1.5.  Based on the calculated HI, there is modest potential for non-carcinogenic effects under the reasonable maximum exposure scenario.  Actual or threatened releases of hazardous substances from the Site, if not addressed by implementing the response selected within this ROD, may present current or potential threat to public health, welfare, or the environment.   

8.3 Description of Alternatives:

On-Site Areas of Concern:

Buildings:

Buildings were separated into three groups based on the extent of their contamination and their structural stability:

• Building Group A:  Contaminated buildings, structurally unsound.
• Building Group B:  Contaminated buildings, structurally sound.
• Building Group C:  Buildings with no significant chemical contamination, except asbestos.

Buildings within Group A, had limited or no reuse potential, due to lack of sound structure and contamination.  These buildings needed to be decontaminated to minimum levels for demolition and then demolished.  Buildings within Group B, were given a risk-based remediation goal to address the contamination risk.  Building within Group C, remediation options, except for asbestos removal, were not considered.  Treatabililty studies were conducted to determine if decontamination methods would achieve remediation goals.  The study concluded that vacuuming, followed by pressure washing with water was the most effective method.  Buildings with high concentrations of lead were slated for demolition, treatability studies found that it would be difficult or infeasible to decontaminate these buildings (Group A) to risk-based levels.   

Alternative 1: No Further Action with Institutional Controls

Estimated Cost: $39,900

Implementation Period: 1 Year

No active remediation or containment of any contamination associated with the buildings would be performed, Institutional controls such as fence repair and deed restrictions would be put into place.  Periodic inspections would be limited to assess potential migration of contaminants.  After five years a review would be made, if necessary action would be considered. 

Alternative 2: Contaminated Underground Tanks Closure/Underground Piping Drainage/Asbestos Abatement for All Buildings/Institutional Controls

Estimated Cost: $9,875,084

Implementation Period: 18 months    

Final closure of contaminated USTs, drainage of underground piping systems, and abatement of friable asbestos.  This alternative does not address chemical contamination.  Alternative includes removal of 11 contaminated USTs, and all tank contents associated.  Each excavated area will be backfilled, and tanks will be properly disposed of.  Removal of piping is not included.  Asbestos abatement is included in this alternative.  Focus on Main Gate House for historic preservation mitigation plan.  Institutional controls would also be put into place on Site.  

Alternative 3: Contaminated Underground Tanks Closure/Underground Piping Drainage/Asbestos Abatement for All Buildings and Building Group A: Gross Decontamination/ Demolition, and on-site management of selected demolition debris, Building Group B: Decontamination, Building Group C: No Further Action

Estimated Cost: $38,800,442

Implementation Period: 2 Years

Alternative 3 involves basic components of Alternative 2, in terms of USTs, piping drainage, and friable asbestos abatement.  This alternative also addresses primary decontamination and demolition of buildings in each group.  Equipment and loose debris from buildings would be removed and properly disposed of off-site.  All accumulated liquid wastes and sludges from tanks, pits, and sumps would also be properly characterized and disposed of off-site.  Historic preservation activities would also be done.             

Alternative 4: Contaminated Underground Tanks Closure/Underground Piping Drainage/Asbestos Abatement for All Buildings and Building Group A: Gross Decontamination/ Demolition, and off-site management of selected demolition debris, Building Group B: Decontamination, Building Group C: No Further Action

Estimated Cost: $40,743,154

Implementation Period: 2 Years

Alternative 4 incorporates the basic components from Alternative 2, in terms of UST closure, underground pipe drainage, and asbestos abatement.  Alternative 4 is also identical to Alternative 3 in dealing with Building decontamination, except for the management of demolition debris corresponding to Group A Buildings.  Under this alternative metal debris would still be salvaged, the remaining debris would be containerized and sent to an off-site landfill.    

Alternative 5: Contaminated Underground Tanks Closure/Underground Piping Drainage/Asbestos Abatement for All Buildings and Building Group A and B: Gross Decontamination/ Demolition, and on-site management of selected demolition debris, Building Group C: No Further Action

Estimated Cost: $40,935,836

Implementation Period: 3 Years

Alternative 5 is consistent with Alternative 3, while expanding with respect to the way Group B Buildings are addressed.  Under Alternative 5, Group B Buildings would be decontaminated to demolition standards only; no secondary vacuuming or power washing would be preformed.  All equipment within Group B buildings would be decontaminated and possibly salvaged.  The amount of building demolition is greater in their alternative.

Alternative 6: Contaminated Underground Tanks Closure/Underground Piping Drainage/Asbestos Abatement for All Buildings and Building Group A and B: Gross Decontamination/ Demolition, and off-site management of selected demolition debris, Building Group C: No Further Action

Estimated Cost: $44,925,665

Implementation Period: 3 Years

This alternative parallels Alternative 4 in the abatement of asbestos, closure of USTs, pipe drainage systems, and primary decontamination of buildings in Group A and B.  All debris of Buildings would be disposed/recycled of off-site in this alternative. 

8.4 Selected Alternative:

EPA and NJDEP, through reviewing public comment and all alternatives, chose Alternative 3 to achieve the best balance of overall tradeoffs.  This includes closure of USTs, removal of all underground piping, asbestos abatement in all buildings, demolition of buildings in Group A and Group B, and decontamination of equipment and tanks.  Non-hazardous building material would be decontaminated and sent off-site for recycling or landfill disposal.  All asbestos, process dust, UST contents, pits/sumps contents, and underground piping would be disposed of off-site.  Decontamination of building interiors will remove contaminants through pressure washing and transfer them to residues and wastewater, hazardous wastewater will be containerized for off-site treatment and disposal, nonhazardous wastewater will be discharged to the local sewer system following any pretreatment needed.  The selected remedy will generate less demolition debris, allowing for on-site management of materials and impose the least amount of impact on the community.    

8.5 Completion:

Operable Unit 4 (OU-4):

Remedial design activities were initiated in June 1997.  Design documents for asbestos abatement/building demolition, and building decontamination were completed in March 1999 and June 2000.  The remedial action for OU-4 began in June 1999 and in near completion.  Construction work of the Main Gate House began in December 2005 and is complete. Currently this section of the Site is fenced off from the remainder of the contaminated area, and is operating as a Museum, which is open Wednesday through Sunday, 11am-5pm.

7.0 Second Record of Decision (ROD): 1991

7.0 Second Record of Decision (ROD): 1991

Record of Decision: September 26, 1991

Document: Located in Record of Decision Links

During the issuance of this second Record of Decision (ROD), the first ROD, signed in 1990, had resulted in a Remedial Action (RA) in September 1990.  The RA was nearing completion during the signing of this second ROD on September 26, 1991. 

Concurrent with the RA, a Focused Feasibility Study (FFS) and proposed plan were being prepared to address the remediation of the 34-acre slag area (OU-3) and the southeast park (OU-2).  Principle threats were contaminated slag and soil containing elevated concentrations of heavy metals and polycyclic aromatic hydrocarbons. 

7.1 Areas of Concern (OU-2) and (OU-3):

OU-2 Contained:

Southeast Park:

• Surface soil samples detected volatile and semi-volatile organic contaminants at low levels, except for PAHs in one sample.
• Chromium, lead, and zinc exceeded the State’s interim soil action levels and nearby background soil levels

OU-3 Contained:

Slag Area:

• 34 acres
• Ranging in thickness from several inches to 30 feet, thickest deposits were along the Delaware River along the Site’s northwestern edge
• Estimated volume of Slag material is approximately 1,458,000 cubic yards
• Material consists of very coarse soils, primarily comprised of residues from high temperature processing iron ore
• Slag fill contains numerous fissures and voids, allowing water infiltration
• Slag material contaminants included volatile and semi-volatile organic contaminants at low levels, except for acetone, 2-butanone, PAHs, and methylene chloride, which were above standard in the samples
• Inorganic contaminants were also detected at high levels, including, antimony, arsenic, barium, cadmium, chromium, copper, iron, lead, magnesium, manganese, mercury, nickel, selenium, silver, thallium, vanadium, and zinc.
• Detectable levels of lead in the leachate from two samples
• Estimated slag material needing treatment – 30,000 cubic yards

7.2 Human Health Risk Assessment/Environmental Risk Assessment:

Contaminants of concern for OU-2 and OU-3 were addressed separately.  Heavy metals and polycyclic aromatic hydrocarbons were the most significant contaminants within the slag area, and to a lesser degree within the southeast park area.  Lead was detected in the slag area at a maximum concentration level of 10,400 ppm (health based cleanup criteria in an industrial zone is 1,000ppm).  Lead was detected in park soils at a maximum concentration of 261ppm (NJDEP Soil Cleanup Criteria in a residential area is 250ppm).

Exposure pathways for the public presented a potential risk for inadvertent ingestion and dermal contact with surface soil during recreational activities, as well as inhalation of suspended soils.  During this time the Site was fenced off in order to restrict entrance to contaminated areas, signs of vandalism and trespassing were observed in these areas.  Under the EPA guidelines the likelihood of carcinogenic and noncarcinogenic effects due to exposure of Site chemicals are obtained by adding the hazard quotients for all compounds across all media.  A HI is determined, if the HI is greater than 1 it indicates a potential exists for noncarcinogenic effects to occur as a result of site-related exposure.  The slag area, showed a noncarcinogenic HI of 27, therefore there was potential risk for noncarcinogenic adverse human health-effects, such as vital organ damage.  For the southeast park area, the HI was less than 1, therefore the noncarcinogenic adverse health effects for this area is unlikely.   

A baseline ecological risk assessment was conducted to assess the potential impacts to wildlife.  Since both the slag area, and Southeast Park are highly disturbed areas, and lack substantial vegetative cover, neither provides significant habitat for wildlife species.  The vegetative growth is limited to a strip of growth on the inland hill. Although wildlife species in the area are limited, some species may be adversely affected by elevated levels of certain contaminants. 

7.3 Description of Alternatives:

Technologies eliminated included: incineration, superficial fluid extraction, biodegradation, washing and extraction, in-situ flushing, in-situ vitrification, in-situ solidification, stabilization of the entire slag area, off-site disposal.  The reasoning for deleting these alternatives included incompatible treatment processes, and technical infeasibility. 

Slag Area (OU-3) Remedial Alternatives:

Alternative SA-1: No Action

Estimated Cost: $31,600

Implementation Period: 2 Months

Annual inspection of monitoring equipment, as well as sampling and testing air and groundwater for 30 years.

Alternative SA-2: Limited Action

Estimated Cost: $72,100

Implementation Period: 4 Months

Maintaining a fence and warning sign along the slag area, long-term monitoring program, and public awareness.  30 years of monitoring, institutional controls on land and groundwater use would also be implemented under this alternative, and would include a deed restriction and groundwater use restriction. 

Alternative SA-3: Treatment of Hot-spots and Soil Cover

Estimated Cost: $6,758,900

Implementation Period: 1 Year

Construction of a soil cover over the slag area to contain the contaminated slag material, the cap would be sloped to allow precipitation to flow easily into a drainage system that would runoff into the river, restrict runoff coming from adjacent areas, and minimize erosion. Cap would consist of a 2 foot deep, vegetated top soil layer that would extend to the side slopes.  Riprap would be provided along the river shoreline to minimize erosion.  Long-term groundwater monitoring and a 5 year review.  Areas leaching contaminants would be excavated and treated on-site using a mobile treatment unit.  A treatability study would be performed during the remedial design process.  If contaminated material (slag that fails TCLP test) is found below water table, dewatering may be necessary during its excavation.  Extracted water would be collected, treated, and disposed.  The treated slag would be returned to an area above the water table to prevent placement in a wet location, which could affect the stabilized slag.  Solidified slag would have to pass the TCLP test before it could be redeposited on site. 

Alternative SA-4:  Multimedia RCRA Cap

Estimated Cost: $11,597,700

Implementation Period: 1 Year

Capping requirement set forth by Federal and State Law.  A small portion of slag area that is in the 100-year flood plain area would be graded above the flood plain.  Multi-layer RCRA cap would be installed over entire area. The cap would be sloped to allow precipitation to flow easily into a drainage system that would runoff into the river, restrict runoff coming from adjacent areas, and minimize erosion.  Cap would consist of: 2 foot clay layer with a permeability less than 10 centimeters per second, 20 millimeters high density polyethylene membrane, 12 inch sand layer for drainage, geotextile filter fabric layer, and 2 foot deep vegetative top soil layer.  Riprap would be provided along the river shoreline to minimize erosion. 

Southeast Park (OU-2) Remedial Alternatives: 

Alternative PS-1: No Further Action

Estimated Cost: $0

Implementation Period: 2 Months

No action alternative consists of a long-term monitoring program to assess the migration of park soil contaminants.  This action would involve soil sampling for 30 years.  A review would be completed after 5 years, determining whether the remedy was still protective.

Alternative PS-2:  Limited Action

Estimated Cost: $59,500

Implementation Period: 4 Months

No active remediation.  Installing fence and warning signs.  Public awareness program.  Monitoring program would continue for 30 years.

Alternative PS-3: Excavation and off-site Disposal of Contaminated Soil

Estimated Cost: $114,500

Implementation Period: 1 Year

Contaminated soil excavated and transported off-site.  Estimated volume based on soil exceedances.  Excavated area backfilled with clean soil and re-vegetated.  Additionally soil sampling would be performed during design phase to confirm extent of contamination. 

7.4 Selected Remedy:

The selected remedy for the slag area was SA-3, this alternative was selected for its ability of treat highly contaminated areas and contains the entirety of the slag area with a soil cover.  The alternative provided a high level of protection by reducing risks associated with exposure to slag contaminants and reducing migration to the environment.  The alternative for the southeast park was PS-3, this alternative was selected for its ability to remove contaminated park soil to an off-site facility and remediate contaminated soil, eliminating potential risks of exposure. 

7.5 Completion:

Operable Unit 2 (OU-2):

The remedy selected for the Southeast playground (OU-2), which included excavating contaminated soil hotspots, off-site treatment of contaminated soils, and disposal at the appropriate facility, was conducted by the Region II Removal Action Branch of the EPA.  The COE submitted the final design to the EPA, in the Fall of 1994.  Remedial Action was completed in March 1995.  Approximately 640 cubic yards of contaminated park soil was excavated and restored with clean soil and vegetation.  Since all contamination associated with OU-2 ROD was removed, a five-year review is not required for this remedy.

Operable Unit 3 (OU-3):

The remedy selected for the Slag Area, which included treating hotspots (defined as highly contaminated slag material that fails the RCRA Toxic Compound Leaching Procedure test), and then covering the entire 34-acre slag area with a soil cover and vegetation, was amended in 2003, the original remedy selected for the OU-3 was modified.

Design and construction activities are ongoing for OU-3.  Design and construction activities for the shoreline stabilization component were completed in July 2006 and November 2006.  These included grading shoreline slopes, placement of geotextile fabric and placement of riprap rock to construct the revetment.  Installation of 3,000 linear feet of shoreline revetment stabilized the Slag area and better prepared the Slag area to receive the dredged sediments in November 2006.  The Slag area is currently receiving dredged sediments.

6.0 First Record of Decision (ROD): 1990

6.0 First Record of Decision (ROD): 1990

Record of Decision: March 29, 1990

Document:  Located under Record of Decision Links

During this time the Site was inactive and under the control of the EPA (Environment Protection Agency), their personnel maintained a 24-hour security at the Site.  The North and South portions of the Roebling Steel Mill Site were fenced off, the Western portion, bordered by the Delaware River, as well as the Eastern portion, bordered by Crafts Creek, were not fenced in during this time.  Posted signs indicating the presence of hazardous materials located on the property grounds were visible to the public.  Ebasco Services Incorporated was performing remedial activities for the ongoing Remedial Investigation/Feasibility Study on Site during this time, the study was addressing the remaining contamination on the property. 

This ROD focused on hazards at the Site which required immediate attention; following the previous removals conducted in 1985 by the NJDEP and in 1987 by the EPA.  These removal actions are detailed in the Preliminary Assessment/Site Investigation of this report.  This ROD was the first of four, and outlined Operable Unit 01 (OU-1).  OU-1 addressed areas on-site that posed a significant hazard to human health and the environment, but were too complex or expensive to address during the initial removal actions in 1985 and 1987. 

6.1 OU-1 contained the following:

• 757 drums, containing a variety of organic and inorganic liquids and solids
• 183 transformers containing oil contaminated with Polychlorinated Biphenyls (PCBs), showing high concentrations of Arochlor 1242 and 1260
• 9 exterior tanks ranging in size from 100 to 8,000 gallons, containing oil, acids, and sludges
• 530 cubic yards of baghouse dust stored in a roofed area adjacent to Building 88 that had high concentrations of metal contaminants (cadmium, chromium, arsenic, lead, and zinc).  Cadmium, chromium, and lead levels in the TCLP leachate metals analysis also exceeded the land disposal restrictions treatment standards
• Chemical piles on-site consisting of powders and unknown materials, showing high concentrations of most metal contaminants
• 10,000 (approximate) discarded tires on-site, which presented a fire hazard
• 120 cubic yards of surface soil under the water tower in the Roebling Park, contaminated with elevated levels of lead

Additional Operable Units Identified within the ROD:

• 90 additional tanks, 6 wastewater treatment flocculation and settling tanks - containing acidic water and sludges
• 2 inactive wastewater treatment plant lagoons, contaminated with lead, cadmium, copper, zinc, and volatile compounds
• Furnace slag disposal areas covering 20 acres, source of heavy metal contamination, as well as sulfur, phosphorous, and metal oxides
• An on-site landfill full of rubble and debris
• 52 inactive railroad cars, containing furnace slag, ashes, and sludge
• 55 buildings containing physical hazards, as well as water filled basements, and hidden pits and sumps containing liquids and sludges
• Loose friable asbestos insulation was also found throughout buildings and overhanging pipes

The RI/FS, which was going on at the Site during the issuance of this ROD, examined soils, surface water, groundwater, sediment, air, lagoons, and other areas of contamination, in a search to define additional Operable Units (OUs).  The ROD also identified contamination as migrating into soil, water, sediments, and air.  Both soil and groundwater samples showed high concentrations of metal pollutants.  Numerous organic compounds were also present in surface soils.  Surface water analysis did not show high concentrations of pollutants, but sediment samples detected high levels of metal contamination as well as semi-volatile organic compounds and low concentrations of volatile organics.  These issues were said to be addressed in future RODs. 

6.2 Human Health Hazard Risk Assessment:

The ROD discussed potential for human health hazards pertaining to each area listed above.  The potential for inhalation and dermal contact was considered high for trespassers onto the Site, if they were to tamper or approach drums, transformers or tanks they could come into contact with hazardous materials.  The areas containing chemical piles and baghouse dust was also considered an area of high human health hazard, due to the presence of several heavy metal contaminants (many carcinogenic).  At that time there was a cover on the baghouse dust which was temporarily providing protection for the public and environment.  The hazardous constituents within the baghouse dust did have the potential to migrate via air suspension or leaching into the environment, therefore posing a risk through direct exposure.  The tire pile was a risk if accidental or purposeful igniting was to happen, therefore releasing hazardous constituents into the air, such as polynuclear aromatic hydrocarbons.  The most significant exposure, within OU-1 was the incidental ingestion of contaminated soil by young children in the playground area.  Surface soils underneath of the water tower were exhibiting high levels of lead, as well as low levels of PCBs.      

6.3 Summary of Alternatives:

No Action:

No effort would be put forth to change or maintain the current status of the Site.  Drums, transformers, tanks, baghouse dust pile, chemical piles and tires would remain on-site, potentially degrading or leaking hazardous substances.  Under the No Action remedial alternative, contaminated soils under the water tower would remain and there would be no technology put into place to eliminate the health risk posed. 

On-site Areas of Concern:

Drums/Drum Contents

Estimated Cost: $869,000

Implementation Period: within one year

Action:  Remove drums from the site and properly dispose of them. 

Transformers/Transformer Contents

Estimated Cost: $1,840,000

Implementation Period: within one year

Action: Consolidation of the contents of individual transformers into a tanker and shipment off-site for incineration.  Testing done before incineration to ensure materials are treated appropriately.

Tank Contents

Estimated Costs: $1, 480, 00

Implementation Period: within on year

Action:  Removal of contaminated material from exterior tanks and shipment. Tanks themselves decontaminated and removed from Site.

Baghouse Dust

Estimated Costs: $405,000

Implementation Period: Within one year

Action:  Removal of 530 cubic yards of baghouse dusts. 

Chemical Piles

Estimated Costs: $21,000

Implementation Period: Within one year

Action: Off-site treatment and disposal of 24 tons of material from 79 chemical piles throughout the Site.

Tires Piles:

Estimated Costs: $12,000

Implementation Period: Within one year

Action:  Removal offsite of 10,000 tires and burnt rubber

Water Tower Soil:

Estimated Costs: $64,800

Implementation Period: Within one year

Action:  Excavate soils to a depth of 6 inches.  Area will be backfilled with uncontaminated soil and revegetated.  

6.4 Selected Remedy:

After a review and evaluation of the alternatives presented in the Focused Feasibility Study (FFS), the EPA presented the following remedies for OU-1.  Over packing of drums and off-site disposal (DR-2), transformer shipment en mass (TR-2), bulking of tank contents and disposal of chemical piles (CP-1), off-site disposal of tires (TP-1), and excavation, treatment, and disposal of water tower soil (WT-3).  Public comments, via the public meeting held on January 18, 1990, did not necessitate changes in the remedial approach proposed for the Site.  The estimated cost for all tasks selected above for OU-1 is $5,003,400. 

6.5 Construction Completion:

The remedial action resulting from this ROD was the first of several.  It included the removal and off-site treatment and disposal of drums, transformers containing oil contaminated PCBs, contents of exterior abandoned tanks, a baghouse dust pile, chemical piles, and tire piles.  The remedial actions were completed in September 1991. Since all contamination associated with OU-1 ROD was removed, a five-year review is not required for this remedy.