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
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.
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