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.