final! work plan remedial investigation/ feasibility study

EPA WORK ASSIGNMENT NUMBER: 226-2L91EPA CONTRACT NUMBER: 68-01-7250EBASCO SERVICES INCORPORATED

FINAL! _WORK PLAN

REMEDIAL INVESTIGATION/FEASIBILITY STUDYROEBLING STEEL SITE

FLORENCE TOWNSHIP, NEW JERSEY

MARCH 1989

NOTICE

This information in this document has been funded by the UnitedStates Environmental Protection Agency (USEPA) under REM IIIContract No. 68-01-7250 to Ebasco Servces, Inc. (Ebasco). Thisdocument has been formally released by Ebasco to the USEPA. Thisdocument does not represent, however, the USEPA position orpolicy, and has not been formally released by USEPA.

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Deisen05

Typewritten Text

DOC ID 63563

EPA WORK ASSIGNMENT NUMBER: 226-2L91EPA CONTRACT NUMBER: 68-01-7250EBASCO SERVICES INCORPORATED

FINAL DRAFTWORK PLAN FOR

REMEDIAL INVESTIGATION/FEASIBILITY STUDYROEBLING STEEL SITE

FLORENCE TOWNSHIP, NEW JERSEY

MARCH 1989

Prepared by: Approved By;

Stephen John SchmidSite ManagerEbasco Services Incorporated

Dev R. Sachdev, Ph.D., P.E.Regional Manager, Region IIEbasco Services Incorporated

8181b

000776

Mr. M. Shaheer AlviMs. Tamara Rossi

SUBJECT: WORK PLANROEBLING STEEL SITEFLORENCE TOWNSHIP, NEW JERSEYWORK ASSIGNMENT NUMBER: 226-2L91EPA CONTRACT NUMBER: 68-01-7250

ACKNOWLEDGEMENT OF RECEIPT

Please acknowledge receipt of the enclosure on the dupliate copyof this letter and return it to the sender at the above address.

DateM Shaheer Alvi, PERegional Project Officer

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¥

ROEBLING STEEL SITEREMEDIAL INVESTIGATION/FEASIBILITY STUDY

TABLE OF CONTENTS

Page

1.0 INTRODUCTION 1

1.1 OVERVIEW OF THE PROBLEM 1

1.2 APPROACH TO DEVELOPMENT OF THIS WORK PLAN 1

2.0 SITE BACKGROUND. SETTING AND CHARACTERISTICS 3

2.1 SITE LOCATION AND DESCRIPTION 3

2.2 Description and Use of Areas Adjacent to andNear the Site 3

2.3 Site History 4

2.4 Remedial Actions to Date 9

2.5 Current Conditions 13

2.6 SITE PHYSICAL CHARACTERISTICS 14

2.6.1 Hydrogeoloaic Characteristics 14

2.6.1.1 Regional Hydrogeology 14

2.6.1.2 Site Geology, Morphology and Hydrogeology 15

2.6.1.3 Site-Area Soils 15

2.6.1.4 Regional Groundwater Usage 15

2.6.2 Drainage and Surface Waters 16

2.6.3 Climate 16

2.7 SITE CHARACTERIZATION-CHEMICAL CONTAMINANTS 19

2.7.1 Sources of Contamination 19

2.7.2 Chemical Characteristics of Soils 26

2.7.3 Chemical Characteristics of Groundwater 32

2.7.4 Chemical Characteristics of Surface Waters 32

8181b000778


TABLE OF CONTENTS (Cont'd)

2.7

2.7

2.7

2.8

2.9

2.9

2.9

2.9

2.9

2.9

3.0

3.1

3.1

3.1

3.2

3.2

3.2

4.0

4.1

4.2

4.3

.5

.6

.7

.1

.2

.3

.3.1

.3.2

.1

.2

.1

.2

Chemical Characteristics of Sediments

Chemical Characteristics of Biota

Chemical Characteristics of Air

CONCEPTUAL SITE MODEL

APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARs)

Determination of ARARs

Consideration of the ARARs During the RI/FS

Preliminary Identification of ARARs forthe Roebling Steel Site

Potentially Applicable or Relevant andAppropriate Requirements

Potential "To Be Considered" Requirements

SCOPING THE REMEDIAL INVESTIGAITON/FEASIBILITYSTUDY' INITIAL EVALUATION AND DATA REQUIREMENTS

RISK ASSESSMENT

Preliminary Risk Assessment

Summary of Information Needs

SCOPING OF REMEDIAL ALTERNATIVES

Summary of Information Needed for the FS

Need for Treatability Studies

WORK PLAN OBJECTIVES

OBJECTIVES OF THE PROJECT

SUMMARY OF INFORMATION NEEDED

DATA QUALITY OBJECTIVES

Eaae34

34

34

35

36

36

37

38

38

41

43

43

43

47

47

56

56

57

57

57

58

0 0 0 7 7 98181b



5.0 TASK PLAN FOR REMEDIAL INVESTIGATION

5.1 TASK 1 - PROJECT PLANNING

5.2 TASK 2 - COMMUNITY RELATIONS

5.3 TASK 3 - FIELD INVESTIGATION

5.3.1 Objectives

5.3.2 Approach

5.3.3 Procurement and Mobilization

5.3.3.1 Sucontractor Procurement

5.3.3.2 Mobilizaton and Demobilization

5.3.4 Site Survey and Mapping

5.3.5 Soil Sampling

5.3.5.1 Surface Soil Sampling

5.3.5.2 Shallow Subsurface Soil Sampling

5.3.5.3 Deep Soil Boring Sampling

5.3.6 Hydrogeologic Program

5.3.7 Groundwater Monitoring Well Installation

5.3.8 Groundwater Sampling

5.3.8.1 On-site Groundwater Sampling

5.3.8.2 Off-site Groundwater Sampling (Tap Sampling)

5.3.9 Surface Water Sampling

5.3.10 Sediment Sampling

5.3.11 Air Sampling

Page

60

60

61

63

63

64

64

64

65

65

66

66

68

74

75

76

79

79

82

82

82

82

- 111 -

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Page5.3.12 Source Sampling 84

5.3.12.1 Building Sampling 85

5.3.12.2 Railroad Car Sampling 85

5.3.12.3 Tank Sampling 86

5.3.12.4 Pipe Insulation Sampling 86

5.3.12.5 Sludge Lagoon Sampling 86

5.3.12.6 Slag Pile and Slag Sampling 87

5.3.12.7 Landfill Sampling 87

5.3.12.8 Settling/Flocculation Tank Sampling 87

5.3.12.9 Waste Disposal 88

5.3.13 Environmental Sampling and Analysis 88

5.3.13.1 Aquatic Ecology 88

5.3.13.2 Ecological Surveys 93

5.3.13.3 Cultural Resources 94

5.3.14 Floodplain Assessment 96

5.3.15 Coastal Zone Management Requirements 96

5.4 TASK 4 - SAMPLE ANALYSES/VALIDATION 96

5.4.1 Laboratory Procurement 96

5.4.2 Sample Analysis 98

5.4.2.1 Soil Samples 98

5.4.2.2 Slag Pile/Sludge Lagoon/Landfill 98Samples

5.4.2.3 Building Dust and Wipe Samples 98

- iv -BlBlb ' 00078


TABLE OF CONTENTS (Confd)

Page

5.4.2.4 Insulation Samples 98

5.4.2.5 Transformer Oil Samples 98

5.4.2.6 Tank Samples 98

5.4.2.7 Residue/(Chemical) Waste Pile Samples 99

5.4.2.8 Pit/Sump/Basement Samples 99

5.4.2.9 Baghouse Dust Samples 99

5.4.2.10 Groundwater Samples 99

5.4.2.11 Air Samples 99

5.4.2.12 Railroad Car Samples 99

5.4.2.13 Field Quality Control 99

5.4.3 Documentation Procedures 100

5.4.4 Data Validation 100

5.5 TASK 5 - DATA EVALUATION 100

5.5.1 Data Reduction and Analysis 101

5.5.2 Environmental Fate and Transport Assessment 101

5.6 TASK 6 - ASSESSMENT OF RISK 102

5.6.1 Selection of Chemicals of Concern 103

5.6.2 Identification of Potential Exposure Pathways 103

5.6.3 Estimation of Exposure Point Concentrations 104

5.6.4 Comparison to ARARs 104

5.6.5 Quantitative Risk Characterization 105

5.7 TASK 7 - TREATABILITY STUDY/PILOT TEST 107

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00078?


TABLE OF CONTENTS (Confd)

Page

5.8 TASK 8 - REMEDIAL INVESTIGATION REPORT 109

6.0 TASK PLAN FOR FEASIBILITY STUDY 109

6.1 TASK 9 - REMEDIAL ALTERNATIVE SCREENING 110

6.1.1 Development of Remedial Response Objectivesand General Response Actions 110

6.1.2 Identification of Applicable Technologiesand Development of Alternatives 111

6.1.3 Screening of Remedial Alternatives 112

6.2 TASK 10 - DETAILED EVALUATION OF REMEDIALALTERNATIVES 113

6.3 TASK 11 - FEASIBILITY STUDY REPORT 117

6.4 TASK 12 - POST RI/FS REPORT 118

6.5 TASK 15 - EXPEDITED RESPONSE ACTION (ERA)PLANNING 119

6.5.1 Era for Drum Removal 119

6.5.2 Era - Specification Preparationfor Compressed Gas CylinderRemoval - (Optional) 121

6.6 TASK 20 FOCUSED FEASIBILITY STUDY (FFS) 121

7.0 RI/FS COST ESTIMATE 123

8.0 RI/FS SCHEDULE 123

9.0 PROJECT MANAGEMENT 124

9.1 KEY PERSONNEL AND ORGANIZATION 124

9.2 PROJECT COORDINATION 125

9.3 QUALITY ASSURANCE AND DOCUMENT CONTROL 126

REFERENCES 127

APPENDIX A •' 00078.-J

- vi -8181b

LIST OF TABLES

TABLENUMBER HILE PAGE

1 HISTORICAL SITE USE 5

2 NORMAL CLIMATOLOGICAL CONDITIONS 17

3 EXTREME CLIMATOLOGICAL CONDITIONS 18

4 REM II - SUMMARY OF DRUM INVENTORY 21

5 SUMMARY OF TANK INVENTORY 22

6 SUMMARY OF TRANSFORMER INVENTORY 23

7 SUMMARY OF PIT/SUMP INVENTORY 24

8 SUMMARY OF RAILROAD CAR INVENTORY 25

9 WASTES KNOWN OR SUSPECTED TO EXIST ON-SITEPRIOR TO PHASE 1 SITE CHARACTERIZATION 27

10 SELECTED MAXIMUM MEASURED CONCENTRATIONS(mg/kg) IN ON-SITE SOIL SAMPLES 30

11 SELECTED MAXIMUM MEASURED METAL CONCENTRATIONS(ug/1) IN ON-SITE UNFILTERED GROUNDWATERSAMPLES 33

12 PRELIMINARY IDENTIFICATION OF REMEDIALTECHNOLOGIES/ALTERNATIVES 49

13 SUMMARY OF PROPOSED FIELD SAMPLING ANDANALYTICAL PROGRAM 69

14 PROPOSED (ECOLOGICAL) RIVER SEDIMENT 92SAMPLING PROGRAM

15 DETAILED EVALUATION CRITERIA 114

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000784

LIST OF FIGURES

FIGURE FOLLOWINGNUMBER T_ITiE_ PAGE

1 SITE VICINITY MAP 3

2 DETAILED SITE MAP 3

3 GENERALIZED SITE STRATIGRAPHIC SECTION 15

4 INTERIOR DRUM INVENTORY 21

5 EXTERIOR DRUM INVENTORY 21

6 LOCATION OF REM II BORINGS/MONITOR WELLS 28

7 SITE SOILS SAMPLING GRID SYSTEM 29

8 LOCATION OF STORMWATER OUTFALLS 33

9 SITE CONCEPTUAL MODEL 35

10 PROPOSED SURFACE AND SHALLOW SOIL SAMPLINGLOCATIONS 66

11 EXISTING AND PROPOSED GROUNDWATER MONITORINGWELLS AND SOIL BORINGS 66

12 TYPICAL GROUNDWATER MONITORING WELLCONSTRUCTION 77

13 PROPOSED AIR MONITORING STATION AND 83SAMPLING LOCATIONS

14 PROPOSED CONTAMINATION SOURCE SAMPLING LOCATIONS 85

15 PROPOSED SEDIMENT AND SURFACE WATERSAMPLING LOCATIONS 90

16 PROJECT ORGANIZATION CHART 125

8181b- vin -

000785

LIST OF ABBREVIATIONS AND ACRONYMS USED IN THIS DOCUMENT

AsCdCECCLPCN-CrCuECRAEP Tox TestHgMnPbPCBppmPRPRASRCRARI/FSSASTALTCLTCLPTCDDTCDFTOCug/1VOAsSnWQCZn

ArsenicCadmiumCation Exchange CapacityContract Laboratory ProgramCyanideChromiumCopperEnvironmental Cleanup and Responsibility ActExtraction Procedure Toxicity TestMercuryManganeseLeadpolychlorinated biphenolsparts per millionPotentially Responsible PartyRoutine Analytical ServicesResource Conservation and Recovery ActRemedial Investigation/Feasibility StudySpecial Analytical ServicesTarget Analyte ListTarget Compound ListToxicity Characterization Leaching ProcedureTetrachlorinated DibenzodioxinTetrachloringated OibenzofuranTotal Organic Carbonmicrograms per literVolatile Organic AnalysesTinWater Qual i ty CriteriaZinc

8181b

- ix -000786

1.0 INTRODUCTION

Ebasco Services Incorporated (Ebasco) is submitting this WorkPlan to the U.S. Environmental Protection Agency (USEPA) inresponse to USEPA Work Assignment Number 226-2L91 dated March31, 1988. This work assignment is a turnover assignment fromREM II EPA Contract Number 68-01-6939.

This Work Plan presents a technical scope of work, as well as anestimated level of effort and schedule for completing theRemedial Investigation and Feasibility Study (RI/FS) initiatedby the REM II Contractor for the Roebling Steel Site in FlorenceTownship, Burlington County, New Jersey.

1.1 OVERVIEW OF THE PROBLEM

The Roebling Steel Site (Site) was actively used from 1906 to1985 for a variety of industrial purposes. The principalon-site use during this period was steel and cable production.During the latter portion of this period, the Site also servedvarious other industrial users, including a polymer reclamationfacility, a repair/refurbishing facility for refrigeratedtrailers and shipping containers, and an equipment storagefacility for a construction company. Over the past twenty yearsthere has been several official notices/complaints issuedregarding unpermitted contaminant releases to the environmentoriginating from the Site. More recently, investigation of theentire Site has revealed numerous sources of potentialcontamination sources that may be impacting environmentalresources in the vicinity of the Site. Thus, the objective ofthis RI/FS is to quantify these contamination sources, to assessthe potential risk to human health and the environment of boththe actual and potential releases of contaminants from thesesources and, as appropriate, determine the most cost effecitvesolution to remediate the Site and to reduce these releases toacceptable levels.

1.2 APPROACH TO DEVELOPMENT OF THIS WORK PLAN

Overall, the objective of this RI/FS is to obtain a sufficientquantity of the proper data that will provide requiredinformation to define the extent and type of potentialcontamination in each media as well as procure sufficient datato develop a risk assessment of actual and potential impacts andultimately to prepare a Feasibility Study to assess potentialremedial alternatives to control contaminant releases to theenvironment.

Essentially, this Work Plan represents both completion andrefinement of the implemented Work Plan for the Site developedand partially initiated by the REM II Contractor. To understandthe approach Ebasco proposes for the work effort at this Site,it is necessary to assess the present status of the REM IIinvestigations. The REM II Contractor had developed a threephase approach for conducting this RI/FS at this Site. Thesethree phases were comprised of:

8151b 000787

o Phase I - Preliminary Site investigation and assessmentof the problem;

o Phase II - Development of a Work Plan to perform adetailed RI/FS (dated May 1987); and

o Phase III - Implementation of the Phase II Work Plan.

Prior to termination of the REM II Contractor's effort, Phases Iand II had been completed, and a portion of the scope for PhaseIII was initiated. Ebasco has evaluated the results of Phases Iand II and reviewed the completion status of the Phase IIIeffort. This review did not attempt to evaluate thequality/quantity of the available data in developing this WorkPlan. Ebasco will essentially complete the RI initiated underREM II and evaluate all of the available data for RiskAssessment and the Feasibility Study.

This Work Plan was developed largely utilizing the scope of theoriginal REM II Work Plan. Where required, appropriatemodifications and additions have been added to the scope of thisWork Plan to improve data acquired and to comply with otherapplicable EPA guidance. Most of the proposed sampling mediaare the same as those of the initial Work Plan(i.e., Phase IIIof the 5/87 Work Plan) , with the addition of severalimprovements and recent guidance from the USEPA regardingassessment of environmental resources (USEPA 1988).

Due to the numerous potential sources of contamination that havebeen identified on-site, and the widespread nature of thiscontamination, this Work Plan proposes a program that basicallyassesses contamination on the entire Site area (over 200acres). To aid in definition of the sampling program, theprogram is broken down to the various sampling media at theSite, such as soils, lagoons, etc.

For the purposes of Work Plan development and ultimatelycompletion of the RI/FS, Ebasco assumes that REM II datacollected are valid and adequate with regard to satisfyingrequirements for chemical characterization data for a givenmedia. These assumptions on validity and adequacy (for RI/FSpurposes) are contingent upon a complete analysis of thevoluminous quantity of raw/unanalyzed data transmitted to Ebascoby the REM II Contractor. Obviously, if this assumption isincorrect, additional work effort, including resampling andanalysis, may be required.

8151b 000788

2.0 SITE BACKGROUND. SETTING AND CHARACTERISTICS

2.1 SITE LOCATION AND DESCRIPTION

The Roebling Steel Site is a 200-acre property in FlorenceTownship, Burlington County, New Jersey, located in the vicinityof 40° 07' 25" north latitude and 74° 46' 30" west longitude.The Site is located on the Bristol 7-1/2 minute USGS quadranglemap.

The Site, situated at 2nd Street and Hornberger Avenue, is inthe Roebling section of Florence Township. As shown in Figure1, the Site is bounded on the north and east by the DelawareRiver and Crafts Creek, respectively. The Village of Roeblingis located to the west and south of the Site. U.S. Route 130 isapproximately one-half mile south of the Site.

The Site has primarily been used since 1906 for production ofsteel products, but has also partially and intermitently beenused in recent years for various industrial operations. Thereare approximately 55 on-site buildings which occupy most of theSite, connected by a series of paved and unpaved access roads.Figure 2 illustrates the Site plan. Based on a preliminaryinspection, numerous potential sources of contamination exist atthe Site including 52 inactive railroad cars (both empty andfilled with wastes or products) and several above-ground storagetanks and transformers, drums scattered throughout the Site,wastewater treatment plant lagoons, an extensive slag disposalarea, and a landfill.

2.2 Description and Use of Areas Adjacent to and Near theSite

The Roebling Steel Site is the dominant land use in the Roeblingsection of Florence Township. To the west and southwest,residential lands occur at a zone density of approximately eightdwellings per acre. Most residential development adjacent tothe Site was originally undertaken by the founders of thefacility, and used to house plant employees. The nearestresidents to the Site are approximately 100 feet away fromproperty boundaries, or 250 feet from the slag pile and 1,200feet from the sludge lagoons and wastewater treatment plant. APenn Central (Conrail) track runs to the southeast of the Site(see Figure 1). Zoning for special manufacturing activities isfound on either side of this track. The major residential areaof Florence Township is one to two miles west of the Site. Thepopulation of Florence Township is 9,084 (1980 census).

Newbold Island (New Jersey) lies in the Delaware Riverimmediately north of the Site. This island, owned by PublicService Electric and Gas Company, covers an area ofapproximately 500 acres; and is largely undeveloped. Thechannel on either side of the island ranges from 400 to 1,000feet wide.

000789

\- -_ '^>USGS TOPOGRAPHIC 7% MINUTE SERIES QUADRANGLESTRENTON WEST.NJ. BR ISTOL.PA; TRENTON EAST.NJ; TRI

IOOC 7000 3000 4000 SOOC

SOURCE

USGS

looe

IADRANGLESEASTJU; TRENTON WEST^U.

IOOC 7000 3000 «000 MOC 6000 7000 f£Tt

; / "~ ~\ r\\ i \ ,. ENVIRONMENTAL PROTECTION

ACEMCVROEBLING STEEL SITE

FIGURE I

SITE VICINITY MAP

tfuscosryyicts i

000790

FIGURE 2

DETAILED SITE MAP

o•MCO

CIAICO If RVICEI INCOHrOHATID

O

O»o-JCDro

J

The Delaware River in the vicinity of the Site is designated asa Zone 2 Water Quality Zone (NJDEP, 1981). The criteria forZone 2 Water Quality include the following: be suitable foragricultural, industrial, and public water supplies afterreasonable treatment; be maintained in such a way as to allowfor wildlife, maintenance, and propagation of resident fish andother aquatic life, and for the passage of anadromous fish; andbe such as to allow for primary and secondary recreation andnavigation.

The City of Burlington, located approximately six milesdownstream from the Site, uses the Delaware River for its watersupply. The City obtains water both directly from the DelawareRiver and indirectly through shallow wells located on BurlingtonIsland. The river also supplies water to the City ofPhiladelphia, farther downstream.

The Delaware River provides primary and secondary recreationalactivities in the vicinity of the Site and is used for fishing.Crafts Creek, a tributary to the Delaware River, with headwatersin north-central Burlington County, comprises the easternboundary of the Site and forms a 40-acre pond south of theSite. Crafts Creek discharges to the Delaware River on theeastern boundary of the Site.

2.3 Site History

The steel mill was established in 1906 as the J. A. Roebling'sSons Company and was engaged in the fabrication of steel wireand cables from scrap steel and pig iron. The Site remained inthe Roebling family until 1952 when it was sold to the ColoradoFuel and Iron Company (CF&I). CF&I operated the facilities asits John A. Roebling's Sons division until its sale in June 1974to the Alpert Brothers Leasing Company (ABLC). ABLC formed theRoebling Steel and Wire Corporation and operated the facilitiesuntil May 1979.

In May 1979, the John A. Roebling Steel Company (JARSCO) wasformed through financial assistance provided by the U.S.Economic Development Administration, the New Jersey EconomicDevelopment Authority, and private funds. JARSCO ceasedoperations in June 1981 and leased portions of the Site. Anunrelated corporation (i.e., not engaged in steel production),the Roebling Wire Company (RWC), began operating on a leasedportion of the Site in January 1982. RWC closed theiroperations from June 30, 1983, to July 28, 1983 then filed aChapter XI petition for bankruptcy and continued to occupy theSite premises until October 1985 when RWC informed NJDEP that ithad ceased operations at the Roebling Steel Site and did notintend to resume them at that location. In addition to theaforementioned companies, there were various tenants to whomportions of the Site were leased. A chronological list ofnumerous on-site tenants is contained in Table 1, and a briefsummary of each tenant is presented below.

sisib 000793

Sheet 1 of 3

COMPANY

John A. Roebling SonsCompany (1906-1952)

John A. Roebling Sons(A Division of ColoradoFuel and Iron Co.(CF&I, 1952-1974))

TABLE 1

HISTORICAL SITE USE

ACTIVITIES

Production of wire/wire cable and cablefor suspension budgesfrom scrap & pig iron

Steel and wire productshigh carbon-wirewaste water treatmentplant

Roebling Steel & WireCorporation (formed asa subsidiary of AlpertBros Leasing Company,1974-1979, bankruptcyin 1975)

Roebling SteelCorporation (Jarsco -bought the premises fromRoeoimg Steel & WireCorporation, 1979-1982)

Roebling Wire Company(RWC - bought Wire Millequipment and leased theWire Mill premises fromJarsco,, Bldgs 8, 10, 13and 14, Jan 1982-Oct 1985

Steel billets and wireconstruction of wastewater treatment plant

Carbon and alloy steelbillets (only portionsof the plant and equip-ment needed for theirproducts; Wire MillFacilites idle): waste-water treatment plant

Wire production; wastewater treatment

SUSPECTED WASTES

Waste oil, heavy metals

Wastewater dischargeinto Delaware River,containing copper, zinc,and cadmium wastes,mineral acids, acidsolutions, sludges,waste oil, spentsolvents, baghouse dust

Sludges, waste oil,process wastewater,heavy metals, spentsolvents

Waste oil, furnace slag,baghouse dust, heavymetal sludges, waste-water discharge

Waste oil, heavy metalssludges, VQAs, waste-water discharges, acidsolutions

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Sheet 2 of 3

TABLE 1

HISTORICAL SITE USE

COMPANY ACTIVITIES SUSPECTED WASTES

M.A. Industries, Inc. Polymer reclaiming Lead, acid solutions(June 1, 1978-May 31,1983; operations - Plasticoccupied only Bldg 114) case recovery from lead

storage bacteries

Stauf fer Chemical Company Storage of vinyl products Unknown(1978-April 1, 1982)Bldg 77 - Wire Mill;Bldg 88 Copper Mill)

Joe Tiederman Truck N/A UnknownSpecialist (Startingin April 1980 - Bldg 80:Former scrap facility)

Project Packaging/ Inc. N/A Unknown(Starting April 1981as a one-year lease andthereafter on a month-to-month basis. Area used-not available

Orville Howard N/A UnknownTrucking Co.(June 1980 - ?Leased Bldg 80-Formerscrap facility)

Henkels & McCoy, Inc. Storage of Unknown(one year lease construction equipmentstarting in Oct 1982. office activitiesLeased a 45,000 ft2

parking lot areasouth of Bldg 19

Greentree, Inc.(1984 Container storage Unknownto ?) Bldg 97)

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Sheet 3 of 3

TABLE 1

HISTORICAL SITE USE

COMPANY ACTIVITIES SUSPECTED WASTES

Johns - Manville Insulation materials Unknown(Bldg 77 and office storagespace)

Midway Container Welding/container UnknownServices, Inc. reparation(Bldg 77)

Vanco, Inc. Trucking & mechanical Unknownrepair operations

8151b0 0 0 7 9 6

M.A. Industries. Inc..

M.A. Industries operated a polymer reclaiming business onSite from June 1, 1978 until May 31, 1983, under a leagreement with the Roebling Steel and Wire Corporation. M

thelease

. M.A.Industries occupied building 114 (See Figure 2), which hadformerly been used for wire storage. M.A. Industries reportedlyrecovered plastic cases from lead storage batteries.

o Stauffer Chemical Company

Stauffer Chemical Company held a lease for portions of the Sitefrom 1978 to April 1, 1982. The Stauffer Chemical Companyoccupied Building 77 (see Figure 2), which had formerly been apart of the wire mill, and a portion of building 88, which hadbeen the Copper Mill. According to Stauffer Chemical Company,this space was used for storage of vinyl products.

o Joe Tiederman Truck Specialist

Joe Tiederman Truck Specialist held a five-year lease forproperty on the Site beginning in April 1980. This companyoccupied a portion of building 80 (see Figure 2), which formerlywas the scrap building.

o Project Packaging. Inc

Project Packaging, Inc. held a one-year lease for property onthe Site beginning in April 1, 1981 (continuing thereafter as amonth-to-month oral lease).

o Orville Howard Trucking Company

Orville Howard Trucking Company held a lease for property on theSite beginning in June 1980. This company leased a portion ofbuilding 80 (see Figure 2), which had been the scrap building.

o Henkels and McCoy. Inc.

Henkels and McCoy, Inc., a construction company, held a one-yearlease beginning in October 1982. The company leased 45,000square feet of the parking lot for the storage of constructionequipment, as well as on-site office space.

o Greentree. Inc

Greentree, Inc., was alleged to be subleasing property (Building97, see Figure 2) from RWC during 1984 (in violation of NewJersey bankruptcy laws then affecting RWC), and had beenobserved to be housing several hundred containers on-site.

o Johns-Manville

Johns-Manville occupied office space on-site as well as Building77 (see Figure 2). Johns-Manville had used the building tostore insulation materials.

800079?

Midway Container Services. Inc

Inc. leased Building 77 (see Figurethe Stauffer Chemical Corporation.was engaged in welding/container

Midway Container Services,2), formerly occupied byMidway Container Servicesreparation.

o Vanco. Inc

Vanco, Inc., leased space on the Site for trucking andmechanical repair operations.

2.4 Remedial Actions to Date

The improper or lack of use of environmental control facilitiesat the Site over the last twenty five years resulted in severalregulatory agencies issuing notices of noncompliance to Siteowners. Following is a list of actions involving regulatoryagencies, including response and enforcement actions, taken todate at the Roebling Steel Site. These actions includenotations of violations, compliance orders, transmittal ofsample analyses, remedial action taken and interim Sitecharacterization (as adopted from the REM II Work Plan,confidential documents and the Site RAMP and other pertinentdocuments).

5/19/64

5/19/64

New Jersey Department of Health (NJDOH) recommendsthat CFI install waste water treatment facilities.

A Status Report prepared byoperations conducted at themillion gallons per day (MGD)into the Delaware River; 1

the NJDOH describedSite by CF&I: 15were being discharedMGD used for acid

5/31/68

1972

solutions and rinsing. These effluents did notundergo neutralization and were low in pH, highlevels of iron and other heavy metals, suspendedsolids and oil.

NJDOH ordered CF&I to cease polluting the DelawareRiver requiring the plant to construct a wastewatertreatment facility. A Permit to Operate the WWTP(S-4-603202) was issued by NJDOH. CF&I was issuedpermit NJ0005274 to discharge certain industrialwastewater to the Delaware River effective December31, 1974.

The wastewater treatment facility was completed andplaced into operation. It consisted of: a rawwaste pumping station, an acid neutralizationsystem, flocculation tanks, settling tanks, an oilcollection and reclamation system, sludge lagoons,and a plant control building and laboratory.Revisions to the plant sewer collection system werealso implemented.

8151b 000798

11/15/74

6/13/79

10/79

10/79

11/7/79

1/29/80

3/3/80

6/2/80

10/15/80

12/19/80

NJDEP meets with facility owners to discuss variousaspects of the facility operation including:lining of the sludge lagoons, groundwatercontamination, landfill operations, oil unloading,and transmission and storage operations.

JARSCO Site inspected by NJDEP and BurlingtonCounty Health Department. Six hundred 55-gallondrums containing waste oil were discoveredon-site. NJDEP requested that these drums beremoved.

NJDEP issued JARSCO permit SID-7-79-63 to constructand operate an industrial WWTP (the CF&I WWTP withimprovements; the sludge lagoons were not to beused). The permit required the installation ofmonitoring wells and bioassay monitoring beconducted.

Delaware River Basin Commission (DRBC) grantedapproval to JARSCO to withdraw surface water fromthe Delaware River and to discharge wastewater tothe Delaware River in compliance with DRBC qualitystandards.

JARSCO was requiredof permit NJ0005274for the discharge of

to apply topreviously

wastewater.

EPA for a renewalassigned to CF&I,

NJDEP issued a notification of violation to JARSCOfollowing the inspection of the site on June 13,1979. JARSCO was later cited for committing ahealth and safety violation as it attempted toremove the drums from the Site without completingthe special waste manifests required by theAdministrative Order of Removal.

NJDEP name JARSCO one of 38 hazardous waste sitesmost urgently needing cleanup in the State of NewJersey.

NJDEP inspects the Site and identifies the slagpile as a potential hazard. Approximately 100drums were added to the accumulation already notedon-site. PCS transformers, a tire pile, andabandoned oil and chemical storage tanks wereidentified as potential pollution sources.

JARSCO cited for storing baghouse dust on-sitewithout permit in violation of NJDEP regulations.

JARSCO supplies NJDEP with analyses of waste oiland slag.

Site inspected by NJDEP. Approximately 700 drumsof oil are located on-site. Dilapidated oil tankerat wastewater treatment plant identified as

108151b 000799

4/1981

5/11/81

6/3/81

7/22/81

12/22/81

2/1/82

6/8/82

6/20/82

7/82

potential pollution source. Also, NJDEP foundJARSCO in violation of New Jersey's solid andhazardous waste regulation for disposing of wasteoil from the WWTP at an unregistered facility.

JARSCO was cited for noncompliance with theconditions of the NPDES Permit for operation of itswastewater treatment plant and waste discharges(installation of monitoring wells, bioassaymonitoring, flow measurement and dischargemonitoring).

NJDEP issues Notice of Prosecution to JARSCOseeking the removal of oil drums and otherhazardous wastes stored on-site.

Resource Conservation andgenerator and treatment,facility (TSDF) inspectionJARSCO cited for storage ofpermit.

Recovery Act (RCRA)storage, and disposalof facility performed,baghouse dust without a

JARSCO removes 20,000 gallons of waste oil andcubic yards of contaminated soil from the Site.

60

NJDEP inspects and samples sludge lagoons. Sludgeis found to contain volatile organics and heavymetals.

JARSCO was issued a deadline for thecompliance plan which would addressof NPDES monitoring requirements.JARSCO plant had been closed sinceit did not and was not requireddeadline.

submittal of athe violationBecause the

November 1981,to meet the

NJDEP requires installation of two groundwatermonitoring wells downstream of lagoons, and onewell upstream from lagoons.

USEPA issues Complaint and Compliance Order toJARSCO related to the on-site storage of thebaghouse dust. JARSCO is directed to stop storagewithout permit, remove spilled dust and soilcontaminated by the dust, protect the pile fromprecipitation and run-on, and address the questionof contaminant migration.

NJDEP Division of Water Resources instructed RWC tosubmit applications for NPDES permits under its ownname (Permit was in JARSCO's name).'

8151b11

000800

8/9/82

9/16/82

11/09/82

EPA Site Inspection form completedDepartment of Water Resources.

by NJDEP

12/7/82

1/1/83

1/9/83

2/1/83

2/1/83

4/83

5/83

10/83

1/19/84

2/84

Mitre Model evaluation of the Site completed by EPARegion II.

RWC submitted applications for NPDES permits toinclude renewal application for wastewaterdivertion and a grade "S-In" license for theoperations of an industrial WWTP.

An acid cloud at the RWC Site was reported by theRoebling Fire Chief and inspected by NJDEP. Noviolations could be substantiated to explain theoccurrence.

JARSCO officially abandoned the Site withoutsufficiently addressing the permit noncompliancesfirst cited in April 1981.

Federal Economic Development Administration (USEDA)forecloses on JARSCO.

Site inspection by the EPA Field Investigation Team(FIT), including soil sampling.

NUS FIT-Region II inspects Site (Ford, 1983).USEPA Field Investigation Team (NUS FIT II)conducts Site inspection and prepares updated EPASite Inspection form.

NJDEP-Air Pollution Division inspected the Site andfound that permits and certificates were missingfor some of the RWC equipment. The equipmentincluded: the vapor return, conservation vent andsubmerged fill for a 4,000-gallon gasoline storagetank and the straight line cleaning house.

Compliance Evaluation Inspection by NJDEP-Divisionof Water Resources found "unacceptable" conditionsat the RWC site. These include the flow meter notworking, the pH level at 2.9 in violation of theNPDES; flights in the find tank not working causingexcessive sludge accumulation.

Completion of Remedial Action Master Plan (RAMP)for the Site by the REM Team.

NJDEP notifies Colorado Fuel that they must informthem of their former waste practices at the Site.

Sample collection from an oil tankEPA Technical Assistance Team (TAT).

trailer by the

8151b12 00080.1

8/14/84

12/84

5/85

5/85

12/85

9/85-5/86

5/87

8/87

Interim Site Characterization by the REM II Team.

Compliance Evaluation Inspection conducted by NJDEPfound concentrations of lead in the wastewater inexcess of NPDES limits, and a high level ofsuspended solids.

Work Plan for the performance of RI/FS by the REMII Team.

Project Operations Plan for Sampling and Analysisby the REM II Team.

NJDEP removed picric acid from one of the on-sitelaboratories and detonated it at Earle NavalWeapons Station.

Phase I of RI activities by the REM II Team,including all preliminary Site characterizationactivities.

REM II Team submitted a revised version of the WorkPlan.

REM II Team submitted a revised version of ProjectOperation Plan.

2.5 Current Conditions

The Site is presently inactive and under the control of the U.S.EPA, which maintains a security force at the Site. The securityforce is stationed at the main entrance of the Site (i.e., southof the Site at the intersection of Second Avenue and HorbergerAvenue). The Site is fenced on the entire south side and on thenorth and west is bordered by the Delaware River with no fenceand on the east by the Crafts Creek with no fence. Althoughthere is a 24-hour security force on-site, the Site can beaccessed from its north, west and east sides. EPA has postedsigns indicating that the Site is hazardous to restrict entry tothe property.

There are several buildings, abandoned trucks, above-groundtanks, railroad cars, pile of tires, slag piles and debristhroughout the Site. There is a potential risk of hazardoussubstances released into the environment as the material remainsuncontained. No remedial activities are presently occurring atthe Site.

There are indications that vandalism has occurred on the Site.Several buildings have been partially destroyed, a pile of oldtires was set on fire and a building housing a chemicallaboratory was destroyed by fire.

138151b 00080?

The Raritan and Magothy Formations dip to the southeast between10 and 100 feet per mile. Both formations thicken in a down dipdirection. According to Rush, the undifferentiated Raritan andMagothy Formations are about 250 feet thick in the vicinity ofthe Site. The Raritan Formation unconformably overlies themetamorphosed bedrock of the Wissahickon Formation.

A generalized Site stratigraphic section is shown in Figure 3.

2.6.1.2 Site Geology, Morphology and Hydrogeology

To date, available site-specific hydrogeologic data obtained bythe REM II Contractor has been reviewed, but not summarized andanalyzed. The following discussion is based on literatureinformation. According to Rush, "the undifferentiated Raritanand Magothy Formations contain the most important and productiveaquifers in Burlington County" (1968). In the vicinity of theSite, two water-bearing zones are generally found in theRaritan-Magothy. Rush (1968) describes an upper zone which istypically about 70 to 100 feet thick. This zone containsgroundwater under water table conditions. The lower zone isartesian, and is separated from the upper zone by the firstlocally significant clay beds in the formation. At the site,four potentially water bearing zones from deep wells drilled inthe area have been identified (instead of 2).

The direction of groundwater flow in the upper water table zoneis to the north towards the Delaware River, which is locally themajor groundwater discharge point. The direction of flow in thelower confined zone is thought to be towards the river as well;however, site-specific data are not available to verify this.The head difference (i.e., hydraulic gradient) between the watertable and artesian zones is not known.

2.6.1.3 Site Area Soils

Surface soil types at the Site are from the Galestown-KlejAssociation of sand, loamy sand, and man-made fill. The surfacesoils have a moderate to high infiltration rate.

2.6.1.4 Regional Groundwater Usage

Groundwater is the source of water supply in Roebling andthroughout Florence Township. Water is supplied by the FlorenceTownship Water Department (FTWD) which maintains three wells atthe following locations in Florence:

Well No. 2 - Summers and 8th StreetWell No. 3 - Spring and 8th StreetWell No. 4 - Broad and 8th Street

The EPA - TAT has recently inventoried and staged in an on-sitebuilding (building 22) about 50 percent (about 1200) of theabandoned drums located throughout the Site. Vandalism to theRemoval Contractors equipment/operations necessitated thecontractor to abandon the drum removal operation.

2.6 SITE PHYSICAL CHARACTERISTICS

2.6.1 Hvdrogeologic Characteristics

2.6.1.1 Regional Hydrogeology

The following section has been adapted from the Remedial ActionMaster Plan for the Site prepared by ERM, Inc in 1983.

The Site is located within the outcrop area of the Raritan andMagothy Formations. According to Owens and Minard (1964), theMagothy Formation outcrops over most of the Site with theunderlying Raritan Formation outcropping in a thin beltimmediately adjacent to the Delaware River. Because thelithology of the Raritan Formation is highly variable, it cannotbe subdivided into seven members as it is in Middlesex County(Rush, 1968). Rush (1968) also states that it is not possibleto completely differentiate between the Raritan and MagothyFormations because of lithologic similarities.

The Magothy Formation consists of an intercalated sequence ofsand and clay beds. The sand is typically very light gray fineto coarse quartz sand. The sand beds range in thickness fromseveral inches to several feet. The clay is dark gray andhighly micaceous. The clay beds also vary in thickness from afew inches to several feet.

The Raritan Formation is highly variable both horizontally andvertically. The formation consists primarily of thick beds oflight gray to white and medium- to coarse-grained quartz andinterbedded with white and red variegated clay. The red claybeds tend to be found near the top of the formation with whitesandy clay beds in lower sections.

148151b

000804

POTENTIALWATERBEARING SCHEMATIC

ZONES ALTITUDE (FT.) SECTION+20

DESCRIPTIONDOWN HOLE (FT.)

TENTATIVECORRELATION

f17242

-%''//V,%///%

\fi

STATIC

A LEVEL 0

(•SO)-75- — ------

MOO- — — — — -

•120-- — — - (-100)-130-- — - — - — .

155 - — —— —— — .

(-150 )•

(•200) J

230- — — — - ——— 1

(-250)1

ri'''':':'-'-ia i'-£i':'li::4^" ^^ ^^ ^^ ^M> •

-~ rC~u-3£

rv«« • fiftf . **M . •** • Ah • 4V . VM. •«* - b-.fab.' ."^rAfc'Ai»'.hW-' »' 'Jks*--:-»:*#!WSi3

k'.Ub'. W.- ,k*^ t•^^ • J-1* ' «M' . ••^•jlafi

P.'Arik'MMh' fc'.^^.*^Ak • A^ . M«L ' J~*~ • *t ;*!.:«. :+^?WM

:Sx:::::::::::::::H:S:

iiiiii

ty^tjrjffL^•j2 -|g,>g2<rs7SJv5<>

•

I */- FILL 0-81 — —• — — — — -_•_.4 (-10 » F)NE 8AND| lo-^o-)

CLAY (30*40')

. (.go')CLAY AND SILT

MO'-78')

1 COARSE SAND(TS'-IOO')

1.100').. -

CLAY (RED AND GRAY)(100'.120')

COARSE SAND |120'-130')

CLAY ORCLAY AND SAND

_(.150') (130MS6')

COARSE SAND(1B5'-230'|

-1-200')

SAND AND CLAY(230--246')

MICAEOUS SCHISTAND GNEISS

(246- )

T GROUND ——————— |T

CRETACEOUSMAOOTHY

(-40-) XVA \ S/NXN*

CRETACEOUSMARITAN

(246*) *+s*>r\r+v>f*

WISSAHICKOMSCHIST

WELLS-1907.1925,1945BORINGS-1963.1976. NO. 1.2,3.

LEGEND:

POTENTIAL WATER-BEARING ZONE

SAND |;:;:|i|a

CLAY ErOC

CLAY W/SAND AND/OR SILT g55^

CRYSTALLINE BEDROCK

U.S. ENVIRONMENTAL PROTECTION_____AfeENCY

ROEBLING STEEL SITE

FIGURE 3GENERALIZED SITE STRATIGRAPHIC SECTION

ROEBLING STEEL COMPANY SITE

EBASCO SERVICES INCORPORATED

00080

The wells are located approximately two miles west of the Siteand are approximate/ 130 feet deep. They tap the RaritanAquifer.

Residents located approximately 1500 feet from the Site south ofCrafts Creek use individual wells for their water supply.

2.6.2 Drainage and Surface Waters

The Site is located on the south bank of the Delaware River at apoint where the river is approximately 1,300 feet wide. CraftsCreek, a tributary to the Delaware River, with headwaters innorth-central Burlington County, comprises the eastern boundaryof the Site and forms a 40-acre pond immediately south of theSite. Crafts Creek discharges to the Delaware River on theeastern boundary of the Site. The topography on the easternside of the Site drops off abruptly to the banks of the DelawareRiver. The Site is generally above the 100-year flood plain ofthe Delaware River and exhibits minimal relief with surfaceelevations varying between 20 and 40 feet above mean sea level.Generally the Site slopes from the south to the river.

Storm water runoff is collected on-site in various stormwatercollection systems and is subsequently discharged into theDelaware River and Crafts Creek through four outfalls.

2.6.3 Climate

The climate of the Site is largely continental, chiefly as aresult of the predominance of winds from the interior of NorthAmerica. Temperature and precipitation data have been compiledfrom the Trenton, NJ Meteorological Station of the NationalWeather Service. Wind data were compiled from 5 years ofsurface observations from McGuire Air Force Base in Wrightstown,NJ. Due to the proximity of the Roebling Steel Site to Trentonand Wrightstown, and the similarities on settings (i.e.,proximity of prominent features such as the Atlantic Ocean andthe Appalachian Mountains), the climatological history compiledfor these stations can be applied to the Roebling Steel Site.

Normal climatological data are summarized in Table 2, extremesof data are presented in Table 3. Wind data are presented inAppendix A.

The climate of the Roebling Steel Site is influenced by theAppalachain Mountains to the west and the Atlantic Ocean to theeast. Average temperature is 54.0 degrees Fahrenheit (°F) withthe average hottest month being July (75.9°F) and the coldestbeing January (32.1°F). The record high temperature was 106°F,the record low was -14°F.

Precipitation is moderate and well distributed throughout theyear. Rainfall during summer months is only slightly higherthan that during winter. The average precipitation is 40.17inches and for the period 1942 to 1981 an average annual

16eisib 090806

PARAMETER

TEMPERATURE <°F)

DAILY MINIMUM (°F)

DAILY MAXIMUM (°F)

PRECIPITATION (MELTED) (IN)

SUNSHINE (PERCENT OF MAX)

MEAN DAYS WITH;PRECIPITATION OVER 0.01 (IN)SNOW OVER 0.01 (IN)THUNDERSTORMS DAYSTEMPERATURE OVER 90°FTEMPERATURE BELOW 32°F

TABLE 2NORMAL CLIMATOLOGICAL CONOTtONS

AT THEROEBLING STEEL SITE

JAN

32.1

25.3

38.0

2.76

51

1120024

FEB

33.4

26.1

40.6

2.70

56

10200

21

MAR

41.2

33.1

49.2

3.80

55

1111014

APR

52.2

42.5

61.8

3.15

58

110202

MAY

62.1

52.2

72.0

3.40

59

120510

JUN

71.3

61.6

80.9

3.21

62

100640

JUL

75.9

66.8

84.9

4.74

64

100870

AUG

73.9

65.0

82.8

4.17

62

100650

SEP

67.2

58.1

76.2

3.17

60

80310

OCT

57.2

48.2

66.2

2.53

59

80101

NOV

46.3

38.7

53.9

3.25

52

100007

DEC

34.9

28.3

41.5

3.28

49

1110020

ANNUAL

54.0

45.5

62.4

40.17

58

1217331787

BASED ON DATA COLLECTED FROM THE FEDERAL BUILDING LOCATION. TRENTON. NEW JERSEY. BASED ON RECORDS FROM 1941-1970 PERIOD.EXCEPT WIND DIRECTION WHICH IS BASED ON 1941-1964.

OOo00

TABLE 3EXTREME CLIMATOLOGICAl CONDITIONS*

AT THE_____ROEBLING STEEL SITE* .

PARAMETER JAN FEB MAR MAY JWL JUL. AUG SEP OCT NOV DEC ANNUAL

TEMPERATURE (°F)RECORD HIGHESTRECORD LOWEST

72-4

73-14

868

9324

9634

10043

10653

10048

10036

9427

S314

7212

106-14

PRECIPITATION (IN)MAXIMUM MONTHLYMINIMUM MONTHLYMAXIMUM 24-HRS

8.990.353.16

5.560.982.53

7.530.932.55

6.610.832.46

8.030.253.11

9.000.064.79

13.390.376.11

14.100.477.55

10.490.194.01

6.770.053.46

7.740.312.90

6.970.192.67

14.100.05

7.55

SNOWFALL (IN)MAXIMUM MONTHLYMAXIMUM 24-HRS

20.810.3

24.315.8

21.514.3

4.44.4

TRACETRACE

2.52.5

13.07.7

21.516.6

24.316.6

BASED ON DATA COLLECTED FROM THE FEDERAL BUIOLING, TRENTON, NEW JERSEY. BASED ON A 49 YEAR PERIOD OF DATA TO 1981. INCLUSIVE.

oo

8181b

OOOooOoc>

snowfall of 19.0 inches has been recorded. The most rain andsnow recorded in 24 hours was 7.55 inches and 16.6 inches,respectively.

Five years of surface wind data covering 1981 thru 1985 werecompiled from the McGuire Air Force Base in Wrightstown, NJ.The 43,000+ hours of observations were complied into 5 windroses (one annual and one for each season) that are presented on17 tables (one annual, one for each season and one for eachmonth) of the 5 year record. These tables are also in AppendixA.

On an annual basis, the mean wind speed at McGuire is 6.34 milesper hour (MPH). The most predominant direction is from the westthrough north quadrants. The least favorable wind is from theeast-southeast, southeast and south-southeast. Fifteen percentof observed winds were calm (below 0.5 mph).

During the winter, the primary winds are from the west throughnorthwest at speeds of 7-62 mph. The same conditionspredominate during the spring. During the summer months, thepredominant winds are from the south through west gradients atan average speed of 4.53 mph. With the exception of thesoutheastern quadrants, winds are more equally distributedduring the autumn, at an average speed of 5.61 mph. Calmconditions are most likely to occur during the autumn (19percent of observed winds) followed by the summer (17.7%),winter (13.3%) and spring (11.1%).

2.7 SITE CHARACTERIZATION - CHEMICAL CONTAMINANTS

2.7.1 Sources of Contamination

The Roebling Steel Site was used for the last 75 years for steelwire and cable production. More recently, portions of the Sitewere used for housing polymer reclamation operations, awarehouse for insulating products, refurbishing refrigeratedtrailers and shipping containers, and as a storage location forconstruction equipment. The waste products generated by thesevarious operations, along with raw materials and products,stored and/or buried in many different locations on-site, aresources of potential contaminantion.

Numerous potential contamination sources of hazardous wasteswere identified at the Site during previous investigationsconducted by the REM II Contractor (see Figure 2). Thesepotential sources include: two inactive wastewater treatmentplant lagoons which were found to be contaminated with lead,cadmium, copper, zinc and volatile compounds (NJDEP 1981);furnace slag disposal areas (slag could be a source of heavymetal contamination, as well as sulfur/ phosphorous and metaloxides); six wastewater treatment flocculation and settlingtanks containing vater with a pH of 2 (Ebasco 1988) and sludges;

198151b

000809

baghouse dust piles (RCRA-regulated waste designated number K061which are potential sources of chromium, lead and cadmium); 222transformers potentially containing contaminated PCB oils; 106abandoned tanks containing oils, chemical (piles) powders andunknown materials; 52 inactive railroad cars containing furnaceslag, ashes and sludges (potential sources of heavy metalcontamination); 2,621 drums (Weston 1987) containing all sortsof chemicals including cyanide, arsenic, cadmium, chromium,mercury, selenium, PCBs (ERM 1983) slag/dust, chemical powders,oils and liquid chemicals; pits/sumps and basements, within thebuildings, containing potentially contaminated liquids andprobably sludges; and a suspected landfill area containingbaghouse dust, drums, tires, shredded rubber, plastic andbuilding rubble. In addition, the buildings are consideredpotential sources of contamination.

Many of the drums were corroded and were leaking. The druminventory from this analysis is summarized in Table 4. Drumlocations inside and outside on-site buildings (as identified bythe REM II contractor) are indicated in Figures 4 and 5. Notethat recent activities have disposed of numerous empty drums,staged about 1,260 drums in Building 22 and left about 500-700drums scattered throughout the Site.

A summary of the tanks and transformers inventory is shown onTables 5 and 6, respectively. Many of the tanks were in poorcondition, with rusted walls, leaky valves, and open roofs(Weston 1987). Similarly, a summary of the pit/sump inventoryis contained in Table 7. A summary of the railroad carinventory is shown in Table 8.

The REM II Contractor reported that the Site also has fourchemical laboratories/storerooms. The chemicals found in theselaboratories included acids, bases, inorganic salts, alcohols,halogentated and non-halogenated organics. Picric acid wasfound on-site and was subsequently removed by NJDEP. Aninventory of the Site has shown that three of these laboratorieshave been dismantled and a fire consumed the fourth. It isbelieved that laboratory chemicals have been overpacked intodrums and still are located (albeit in a more secure fashion)on-site.

Other contamination sources on-site include two open platingbaths located in Building 8, which appeared to contain coppersulfate (Weston 1987). Insulation material, roost likely made ofasbestos containing materials, could be seen hanging from yardpiping. In addition, piles of discarded tires (50,000 to75,000) around Building 18 present a potential fire hazard.Furthermore, as described herein, surface and subsurface soilson-site are contaminated with metal pollutants and to a lesserextent with organic compounds. As such, soils could be viewedas a source of contaminants.

208151b

000810

TABLE 4

REM II

SUMMARY OF DRUM INVENTORY

Contents

Chemical Powders

Oils and Grease

Empty

Chemical Liquids

Slag/Dust

Unknown

Debris/Trash

TOTAL

Liquid

Solid

TOTAL

NUMBER OF DRUMSType ofMaterial Inside Outside Total

Solid 49B

Liquid 279

None 206

Liquid 279

Solid 224

Unknown 317

Solid 206

2,009

558

928

1,486

74

111

153

106

73

29

_6_6_

612

217

212

430

572

390

359

385

297

346

272

2,621

775

1.141

1,916

Percentageof Total

22

15

14

15

11

13

-Lfi

100

40

_6_D.

100

Source: Weston 1987

Note: Recent EPA estimates of drum quantities is: 1,260 stagedin Building 22 and 500-700 scattered throughout the Site.

218151b

000811

wve*ccO)

O* ON CMCMCM tlOMOt IMW

SOURCE: WESTON WORK PLAN

U.I. ENVIRONMENTAL PROTECTION_________ACEMCY___________

MOEILIMC tUEL SITE

FIGURE 4

INTERIOR DRUM INVENTORY

ElAfCO SERVICES INCOHPORATEO

ocoO

SOURCE: WESTON WOHK PLAN

U.S. ENVIHONMENTAI. mOTCCTIONAGCNCV

HOHLINO STEEL SITE

FIGURE 6

EXTERIOR DRUM INVENTORV

EIASCO SEHVICiS INCORPORATED

TABLE 5

SUMMARY OF TANK INVENTORY

CONTENTS

Unknown

Oils

Empty

Liquid*

Chemical Powders

NUMBER OF TANKS

Inside Outside Total

41 18 59

18 9 27

3 7 10

3 5 8

_i _fl _^

67 39 106

Percentageof Total

56

25

9

8

—L100

NOTE:

•Liquid - Based upon the visual inspection, these tanks mostlikely contain water.

Source: Weston 1987.

228151b

000814

TABLE 6

SUMMARY OF TRANSFORMER INVENTORY

LocationNumber of

TransformersOil Capacity

Range

Outside•% -

Inside

Total

78

144

222

60 to 1813 gal

34 to 1950 gal


238151b 000815

TABLE 7

SUMMARY OF PIT/SUMP INVENTORY

Location: Number ofBuilding Number Pits/Sumps

2371011132231507886114

431412211133

TOTAL 2 6


TABLE 8

SUMMARY OF RAILROAD CAR INVENTORY

Contents

NUMBER OF CARSPercentage

Total of Total

Slag

Empty

Fly/Bottom Ash

Debris/Trash

Dry Sludge

25

12

48

23

17

TOTAL 52 100

Source: Weston 1987,

8151b25

00081?

Potential subsurface contamination sources could also be presenton-site. Buried drums, partially exposed, were found west ofBuilding 88, south of the landfill, and west of the wastetreatment plant along the river bank. In addition, ageophysical survey conducted by the REM II Contractor hasidentified areas where unknown buried objects may be located.These areas are located around the wastewater treatmentfacility, the process buildings and lagoons, and southeast ofthe former N.A. Polymer building (i.e., Building 114).

Table 9 summarizes the wastes known or suspected to existon-site, and the known or suspected composition of the wastes.

2.7.2 Chemical Characteristics of Soil

As measured by the REM II Contractor, surface and subsurfacesoils are contaminated with elevated levels of metalcontaminants. Soils also contain high levels of organiccontaminants particularly semi-volatile compounds includingphthalates, pyrene, chrysene, anthracene, and fluoranthene(Weston 1987). To sample surface soils of the entire Site, a200' x 200' grid was layed out over the Site and compositedsamples were obtained from each grid and analyzed for EPToxicity constituents and petroleum hydrocarbons. Twenty-sixpercent of the 194 surface soil samples analyzed from the Siteexceeded RCRA EP toxicity limits. For example, lead levelsexceeding the 5 mg/1 allowable limits, in some cases by afactorof 10, were detected in 24 percent of the surface soils.Areas where lead concentrations have exceeded the allowablelimit were found along the west face of building 10, around thelandfill and between Buildings 114 and 13, and the area betweenbuildings 3 and 50 (Weston 1987). Petroleum hydrocarbons werepresent in all surface soil samples taken from the gridscovering the Site. This result is not surprising as oilshistorically were utilized on the Site for dust suppressionpurposes. The NJDEP allowable limit of 100 mg/g was exceeded,in some cases by a factor of 10, in 75 percent of the samples(Weston 1987) .

Preliminary review of available REM II sampling data hasindicated that the samples were analyzed for HSL compounds from19 surface soil locations (15 of them located on-site), 29boreholes, and 17 monitoring wells. The corresponding number ofsamples respectively are 19, 60, and 41 (excluding duplicates,composite samples, and trip and field blanks). At least asimilar number of analyses for HSL organics were traced.

Figure 6 shows the location of the boreholes and monitoringwells installed by the REM II Contractor. Soil samples fromthese locations were analyzed for HSL inorganic and organiccompounds.

268151b

000818

TABLE 9SHEET 1 OF 2

Ooo30

WASTES KNOWN OR SUSPECTED TO EXIST ON-SITEPRIOR TO PHASE 1 SITE CHARACTERIZATION (WESTON 1987)

Contained WastesWasteTvoe

Oiltanks

Oiltank

OilinTransformers

Slag inRR cars

NJ

Chemi calstoragetanks

Drums

PhysicalState

liquid& orsludge

blackviscousOil

liq.

solid

liq.

liq.

11,.

unknown

HazardousSubstancfs

unknown"residual oils"(possible PCBs)

trace PCBs(possible heavymetals)

possiblePCBs

possibletoxic metals

xylol

adds

sulfatetol uene

•eld

unknown

Location

embankmentWest of Bldg 88and other

100 yd'sfromDelaware River

Bldgs1. 22. 88

Northcenter

underground tankW of BLDG 14

tanksin BLDG 14

Bldg 10

variouslocations

Sourceunknown(7 tankbottom)

wastewatertreatmentPlant

dielectricfluid

steelMill

unknown

unknown

unknown

unknown

WasteQuantity

9partially-filledtanks S.OOO to

2000 gal

unknown

unknown

2000 gal

unknown

unknown

- >50- total number

not known

SamplingStatus

neversampled

Sampled 2/9/84Weston TAT IItrace of PCBs(0.5 ppm)

neversamples

sampled 1/1/76toxic metalsnot analyzed

never sampled

never sampled

never sampled

never sampled

Comments

- may be similar to oil indrums (see data from drumstorage area)

- Trailer is dilapidated

- other transformerspossible

- Composition highlyvariable

- active building

- active building

- drum contents assumedto be variable

- other drums possibleinside buildings

Trailers unknown unknown various Colorado unkno*Trucking Co.

never sampled abandoned trailer trucks- contents unknown

8151b

TABLE 9SHEET 2 OF 2

WASTES KNOW OR SUSPECTED TO EXIST ON-SITEPRIOR TO PHASE 1 SITE CHARACTERIZATION (WESTON 1987)

Contained Waste*WasteTvoe

Slagpile

Sludge

Baghousedust

OT Landfill

Oil-stainedsoil

Tirepile

Formerdrumstoragearea

Physi cal HazardousState Substances

solid possibletoxic netals

solid - Pb 500 ug/kg- Cd 400 ug/kg- vol. org. 100 ug/kg

solid K061 (RCRA)powdery typically high

Cr. Cd. Pb

Solid unknown

solid possible PCS,and heavy octal s

solid fire hazard

unknown unknown possiblePCBs and heavymetals

Location

along DelawareRiver NW site

NE sitealong DelawareRiver

W of 81 dg 88

W of Bldg 88

on embankmentnear oil tanks,W of Bldg 88

not specified

W part of siteW of residentialarea

WasteSource Quantity

steel 20,000mi 1 1 yd3

wastewater 6,300treatment yd3plant

steel mill 1,500 - ,15,000 ft.3

unknown unknown

oil tanks 21.000 ft.2

unknown unknown

unknown unknown

SamplingStatus

sampl ed10/4/76

sampled12/21/81NJDEP

never sampled

never sampled

never sampled

not applicable

not applicable

Comments- toxic metals not analyzed- slag used as road top

across site

- hi copper and zinc

- dust may be widespreadacross site

- appears to beconstruction debris

- 60 yds3 of soilremoved 7/81

- may have been drumsof oily wastes

- waste oil analysis4/80: Pb 17 mg/1 :Cr 1.98 mg/1 PCBs ,14 ppb, COO 2.3 x 106mg/T

Ooo00

\\

•OUNCE: WEITON WORK HAH

U.S. IMVmOMNMNTAL WOTECTIONAOENCV

NOE1LINO STEEL SITE

FIGURE •

LOCATION OF REM IIBORINGS/MONITOR WELLS

EIASCO SERVICE* INCORPORATED

o

Figure 7 shows the locations of the 194 surface soil samplestaken across the Site. These surface soil samples were analyzedfor EP Toxicity constituents and petroleum hydrocarbons. Aspreviously noted, nineteen surface soil samples and 46 deepborings (29 boreholes and 17 monitoring wells) were analyzed forHSL compounds.

Preliminary review of chemical analysis of these surface andsubsurface soil samples taken from various depths down to 40feet showed elevated metals concentrations for lead, cadmium,copper, arsenic, chromium, zinc, manganese, tin, cobolt, iron,mercury, nickel, and vanadium. Table 10 presents maximumconcentrations as measured by the REM II Team, the on-sitelocations and depths where they were detected. These locationsare keyed to the REM II alpha-numeric grid system developed forthe Site and presented on Figure 7. For illustrative purposes,the New Jersey Soil Cleanup Objectives for the metals in soilsis also shown for comparative purposes. In general, all surfacesoils showed metal concentrations exceeding these limits. Lead,copper and zinc were the highest measured at maximums of 20,200mg/kg, 1,700 mg/kg and 64,400 mg/kg, respectively. Metalsconcentrations in the subsurface were also high. For example,lead levels as high as 8,650 mg/kg were detected at a 10-12 footdepth in monitoring well MW-02 while copper levels as high as17,220 mg/kg were measured at a 4-6 foot depth in MW-09.

Several organic compounds, mostly semi-volatiles, also arepresent at the surface and subsurface soils. However, theextent of contamination has not been determined at this time.Preliminary evaluation of available data does indicatesignificant soils contamination across the Site.

In summary, the surface and subsurface soils of the RoeblingSteel Site are highly contaminated with metal pollutants.Numerous HSL organic compounds are present in the soils atelevated levels. Currently there are no data (mineralogy, grainsize, cation exchange capacity, binding characteristics, pH,metal speciation, and total organic carbon (TOC)) to evaluatethe nature of contamination. Thus it is not known how much ofthe total metals concentrations is in the toxic form. It isfelt that the distribution and use of material (for fillmaterial, etc.) may be the source of the metal contamination insoils throughout the Site resulting from metals leaching.Additionally, there are no soil chemical data taken at regularintervals to further evaluate contaminant transport and rate oftheir migration. This information will be needed to assess therisks associated with this contamination and to develop remedialdesigns. Also it will be necessary to study the organicanalyses of data already available to fully characterize thecontamination already measured.

29 C008228151b

Sheet 1 of 2TABLE 10

SELECTED MAXIMUM MEASURED METAL CONCENTRATIONS(mo/kg) IN ON-SITE SOIL.SAMPLES (f)

A. SURFACE SOILS

Constituent

Arsenic

Cadmium

Chromium

Cobalt

Copper

Iron

Lead

Manganese

Mercury

Nickel

Tin

Vanadium

Zinc

NJDEP SoilCleanupObjectives

20

--

100

--

170

--

100

--

—

--

--

--

350

Maximum Measured MetalConcentrations in Soil

59.8

132.0

440.0

63.2

1,700

295,000

20,200

17,600

0.79

694

394

169

64,400

Soil GridLocation

(SeeFigure 7)

C-09

C-09

M-10

D-05

D-04

D-05

F-ll

K-12

D-04

K-12

D-05

M-10

C-09

NOTES:

(1) Based on preliminary review of existing REM II soil analysisdata and a surface soil depth of 0-6*

30 0008238151b


SELECTED MAXIMUM

B . SUBSURFACE

Constituent

Arsenic

Cadmium

Chromium

Cobalt

Copper

Iron

Lead

Manganese

Mercury

Nickel

Tin

Vanadium

Zinc

(ma/ka) IN

SOILS

NJDEPSoilCleanupObjectives

20

—

100

--

170

—

100

--

--

--

--

--

350

MEASURED METAL CONCENTRATIONSON SITE SOIL

MaximumMeasuredMetalConcentration

112.9

40.8

1,210

35

17,220

146,023

26,557

27,145

0.4

82

224

309.7

18,190

SAMPLES (!)

Borehole (BH)MonitoringWell (MW)(See Figure 6)

BH-04

MW-10

BH-05

BH-17

MW-09

BH-4

MW-08

BH-05

BH-18

MW-08

MW-02

BH-04

MW-02

Depth(Feet)

2-4

4-6

4-6

18-20

4-6

2-4

0-6

4-6

6-8

0-6

4-6

2-4

4-6

NOTE:

(1) Based on preliminary review of existing REM II data onsubsurface soil analyses

318151b OQ08:

2.7.3 Chemical Characteristics of Groundwater

Analysis of total metals concentrations in unfiltered groundwatersamples collected from the 17 monitoring wells on the RoeblingSteel Site showed high concentrations of metal contaminants. Forcomparative purposes, measured contaminant levels are compared toWater Quality Criteria (WQC) and also to ECRA limits. Themaximum measured concentrations of metal contaminants in theunfiltered groundwater samples, WQC and ECRA are listed on Table11.

Unfiltered groundwater samples typically show higherconcentrations of metals than filtered portions of the samesample. However, analysis of the unfiltered samples from themonitoring wells on the Site showed much higher concentrationsthan expected as compared with their filtered equivalent. Forexample the unfiltered sample from well MW-09 showed 3590 ug/1lead where Pb was below detection limit in the filtered sample.A few unfiltered samples contained lead concentrations in therange of 53-65 ug/1. It is assumed that the REM III contractorfiltered the sample through a 0.45 u membrane (cellulose ester)filter following EPA recommended methods. However, the reasonfor the large differences in metal concentrations betweenfiltered and unfiltered samples could not be explained. No othermetal contaminants in the filtered samples exceeded WQC.

Low concentrations of methylene chloride, chloroform, acetone,2-butanone, toluene, butylbenzylphthalate, and bis(2-ethylhexyl)phthalate were detected in groundwater on-site. Most of thesedetections have uncertainties as flagged J (approximate) or B(present in blank samples). However, bis(2-ethylehexyl)phthalate was detected with certainty at 60 and 25 ug/1 at wellMW-05 and MW-08, respectively.

There is no information on the recharge rate, pH, Eh, dissolvedoxygen (D.O.), and TOC content to further characterize the fateof contaminants.

2.7.4 Chemical Characteristics of Surface Waters

Analysis of 14 surface water samples collected in the REM IIprogram did not show concentrations of major pollutants exceedingWQC. The exceptions were the samples collected next to the 24"storm water outlet and Crafts Creek near Rt. 130 bridge (Figure8). The first sample contained 480 ug/1 lead, and the secondcontained 1.88 ug/1 mercury compared with the WQC limits of 30ug/1 and 0.144 ug/1, respectively.

Currently there is no information on flow conditions and otherhydrologic parameters, water pH, Eh, and TOC to furthercharacterize the fate of contaminants and rate of accumulationand/or release to calculate the mass balance of the riversystem. These data will be needed for risk assessment purposesas well as for remediate design.

328151b

00082,

TABLE 11

SELECTED MAXIMUM MEASURED METAL CONCENTRATION(in ug/1) IN ON -SITE UNFILTERED GROUNDWATER SAMPLES(D

Constituents

Arsenic

Cadmium

Chromium Cr +6Cr +3Total

Copper

Iron

Lead

Manganese

Nickel

Zinc

MaximumConcentrationug/1

179

34

_—391

1,370

162,000

3,590

5,680

135

1,540

Location

MW-8

MW-8

MW-8

MW-8

MW-12

MW-9

MW-9

MW-8

MW-8

EPA AmbientWater QualityCriteria (WQC)Adjusted forDrinking WaterOnly(2)

0.025

10

50179,000

—

1,000

-

50

-

15.4

5,000

NJACGround-waterQualityStan-dards

50

10

_-50

1000

300

50

50

-

5000

(1) Based on preliminary review of existing data

(2) Superfund Public Health Evaluation Manual, EPA 540 1-86 060,Exhibit 4-6. (Note: the adjusted values are not officialEPA Ambient Water Quality Criteria, but may be appropriatefor Superfund Sites with contaminated groundwater.)

338151b

2.7.5 Chemical Characteristics of Sediments

Lead appears to be a major contaminant in all 14 sedimentsamples collected by the REM II Contractor. Lead concentrationsas high as 10,800 mg/kg were detected in the sediments collectednext to the 8" storm outlet. Measured lead concentrations inthe Delaware River sediments ranged between 17 to 330 mg/kg. Asediment sample from Crafts Creek contained 437 mg/kg Pb. Othermetal contaminants similar to those detected in the Site soilwere also present in the sediment samples. A preliminary reviewof collected data indicated that the range of concentrations ofthese metals in mg/kg is as follows: As: less than detection(ND) to 18.9, Cd: ND to 21.7, Cr: 6.7 to 86.9, Cu: 7.5 to 1220,Hg: ND to 0.55, and Zn: 69.6 to 4060. Metals content in severalof these sediment samples exceed ECRA limits.

Semivolatile organic compounds also were present in highconcentrations in the sediment samples. For examplebis(2-ethylhexyl) phthalate (dioctylphthalate) concentrationsreaching 7300 mg/kg were detected in the sediments near the 24"storm outlet. Other semivolatile compounds detected in severalsediment samples were phenanthrene, anthrancene,di-n-butylphthalate, fluoranthene, pyrene,butylbenzyl-phthalate, benzo-anthracene, chrysene, benzo(a)pyrene, benzo(b) fluoranthene, and benzo(h,i)pyrolene.Naphthalene, acenaphthylene, and fluorene were detected, howeverwith a sampling frequency of only one occurrence.

Low concentrations of volatile organics were detected in fewsediment samples. These compounds are methylene chloride,acetone, 1,1-dichloroethene, 1,1-dichloroethane, trans-1,2-dichloroethene, and toluene. Sediments did not containdetectable amounts of pesticides/PCBs.

There are no data to characterize suspended sediments forcontaminant mass balance determinations and risk assessmentcalculations. Similar to the discussion for watercharacterization, hydrological data and other chemicalparameters also will be needed to characterize the metalpollutants and the rate of accumulation and/or release ofpollutants.

2.7.6 Chemical Characteristics of Biota

No local biotic sampling has been performed in the vicinity ofthe Site and thus there is no Site specific information toreport.

2.T.I Chemical Characteristics of Air

No chemical analysis of the ambient air at the Site has beenperformed, and thus there is no Site specific information toreport.

00082734

8151b

2.8 Conceptual Site Model

As shown in Figure 9, there are a variety of potential sourcesof chemical contamination at the Roebling Steel Site, numerouspotential chemical migration mechanisms, and many potentialexposure pathways for both human and ecological receptors. Thedata collected as part of the Site RI will provide informationon the extent and magnitude of contamination at potentialsources and of chemical migration at and from the Site. Thisdata will be used to refine the identification of potentialexposure pathways for the Site and to identify potentialreceptors.

Specifically, a list of thirteen potential sources ofcontamination have been identified:

o Abandoned drums;o Baghouse dust;o Buildingso Contaminated soils;o Landfill area;o Potentially contaminated groundwater;o Transformers;o Lagoons;o Surface watero Sediments;o Tanks;o Railroad cars; ando Slag piles

Combined, these sources can affect on-site as well as off-sitereceptors through air and ground/surface water contaminanttransport mechanisms.

The potential for direct contact with on-site contaminatedmaterials exists among individuals who may trespass on the Siteand, potentially in the future among on-site workers ifbuildings or space on-site were leased for use to companies. Inaddition to possible exposures to contaminated surface materialson-site (e.g., surface soil, surfaces inside buildings),potential spills or leaks from containerized materials (e.g.,tanks, drums) remaining at the Site may pose risks to humanhealth. The entrainment of contaminated baghouse dust andsurface soil on-site via wind or mechanical disturbances (e.g.,vehicles) and possible volatilization of contaminants from soiland other source materials may also result in inhalationexposures.

Contaminants present on-site may migrate to off-site locationsvia surface water transport, groundwater transport, surface soilrun-off, and suspension of surface materials or volatilizationof chemicals into air and their subsequent transport. Themigration of contaminants off-site may result in exposures tonearby residents or workers.

000828

SOURCESRELEASE

MECHANISMSTRANSPORT

MECHANISMSTRANSPORTPATHWAYS

EXPOSUREPATHWAYS

BAGHOUSE DUST

BUILDINGS.INDOOR DRUMS.

TANKS. PITS

SURFACE SOIL

OUTDOORBURIED DRUMS.

TANKS.TRANSFORMERS

AIR

LAGOONS (DRV)SLAGS. RAILROADCARS (SLAGS)SUBSURFACE SOILS

^

DESORPTION/DISSOLUTION/

LEACHING/

DEPOSITIONINFILTRATIONPERCOLATIONSURFACE RUNOFF

OROUNDWATERSURFACE WATER

PARTICULATE

INHALATIONINCESTION

DERMAL CONTACT

• HUMAN HEALTHIMPACT

• ECOLOGICALIMPACT

SPILLS/LEAKS U.S. ENVIRONMENTAL PROTECTIONAGENCY

ROEBLING STEEL SITE

FIGURE 9

SITE CONCEPTUAL MODEL


The surface water pathway involves overland run-off and stormsewer discharge into the Delaware River and Crafts Creek.Preliminary information suggests that potentially affectedgroundwater beneath the Site is also discharged into theDelaware River. In addition, overland run-off of eroded surfacesoils may also transport on-site contaminants into adjacentsurface water bodies. Contaminants which enter Crafts Creek andthe Delaware River may pose risks to potential ecologicalreceptors (e.g., aquatic life). The Delaware River also servesas a drinking water source for Philadelphia and Burlington, anda recreational outlet for several miles downstream.

Contaminants transported via air may pose risks to nearbyresidents and individuals who may use the playgrounds locatedalong the site boundaries. Meteorological data collected at thePhiladelphia, PA airport (which may not be applicable to thisSite located on the bank of the Delaware River) suggest thatvolatilized or entrained contaminants could be transportedtowards the Village of Roebling and Florence Township Parkroughly 18 percent of the year. Contaminants which havemigrated into off-site soil may also pose risks amongindividuals via direct contact. Figure 9 presents a conceptualmodel of these potential pathway evaluations.

2.9 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

2.9.1 Determination of ARARs

The ARARs preliminarily identified below have been categorizedas "applicable or relevant and appropriate," and "to beconsidered." These listings are based upon EPA guidancepublished pursuant to Section 121 of CERCLA. Section 121 ofCERCLA requires that, subject to specified exceptions, remedialactions be undertaken in compliance with applicable or relevantand appropriate environmental requirements, both State andFederal. Thus, the selection from among remedial alternativesfrom the completed RI/FS must attain the ARARs set out below.The most recent EPA interim guidance discussing these principleswas published on August 27, 1987 (52 Federal Register 32496).

CERCLA defines ARARs as:

o Any standard, requirement, criterion, or limitationunder any federal environmental law; and

o Any promulgated standard, requirement, criterion, orlimitation under a state environmental or facilitysiting law that is more stringent than the relatedfederal standard, requirement, criterion, or limitation.

Although CERCLA limits ARARs to promulgated, or legallyenforceable standards, EPA guidance elevates nonpromulgatedguidance and advisories to ARAR status when ARARs do not exist

368151b

00083 0

for a particular situation or are otherwise not protective ofhuman health and the environment. In addition EPA guidancesegregates ARARs in accordance with the activity they areexpected to affect. ARARs that relate to the level ofsubstance, contaminant or pollutant allowed are calledcontaminant-specific; ARARs that relate to the characteristicsof the site are called location-specific; and ARARs that relateto a method of remedial response are called action-specific.

2.9.2 Consideration of ARARs During the RI/FS

As the RI/FS process continues, more ARARs, particularly whenguidance is provided by the State of New Jersey, will beconsidered and developed. Specifically, ARARs will beconsidered at six key intervals:

During scoping of the RI/FS, chemical/specific andlocation-specific ARARs may be identified on apreliminary basis.During the site characterization phase of the RemedialInvestigation, when the public health evaluation isconducted to assess risks at a site, thechemical-specific ARARs and advisories andlocation-specific ARARs are identified morecomprehensively and used to help determine the cleanupgoals.During development of remedial alternatives in theFeasibility Study, action-specific ARARs are identifiedfor each of the proposed alternatives and consideredalong with other ARARs and advisories.During detailed analysis of alternatives all the ARARsand advisories for each alternative are examined foreach alternative are examined as a package to determinewhat is needed to comply with other laws and beprotective.When an alternative is selected it must be able toattain all ARARs unless one of the six statutorywaivers is invoked.During remedial design the technical specifications ofconstruction must ensure attainment of ARARs.

The conclusions on ARARs reached at these intervals will be usedas a guide to evaluate the extent of Site cleanup required, toaid in scoping and formulating proposed treatment technologiesand to govern the implementation/operation of the selectedaction. As with the preliminary identification, ARAR's aredeveloped by taking into account the following:

o Contaminants suspected;

o Chemical analyses to be performed;

o Types of media to be sampled;

eisib 3? C00831

o Geology and other site characteristics;

o Use of the resource/media;

o Level of exposure and risk;

o Potential transport mechanisms;

o Purpose and application of the potential ARARs; and

o Remedial alternatives that will be considered for thesite.

2.9.3 Preliminary Identification of ARARs for the RoeblinySteel Site

2.9.3.1 Potentially Applicable or Relevant and AppropriateRequirements

The NCP and the EPA Interim Guidance define applicablerequirements as the Federal requirements for hazardoussubstances that specifically address Site circumstances, andthat would be legally applicable at the Site if this responsewere not undertaken under CERCLA. Relevant and appropriaterequirements are defined as those Federal requirements that,while not applicable, are designed to apply to similar problemsto those encountered at this Site. Requirements may be relevantand appropriate if they are applicable but for thejurisdictional prerequisites associated with the requirement.With respect to the selection of remedial alternatives, relevantand appropriate requirements are generally afforded the sameweight and consideration as applicable requirements. Thefollowing Federal and New Jersey regulatory requirements couldbe potentially applicable or relevant and appropriate to theRoebling Steel Site.

1) Contaminant-Specific

Contaminant specific requirements set health or risk-basedconcentration limits or discharge limitations in variousenvironmental media for specific hazardous substances. Theserequirements are generally protective cleanup levels forparameters of concern at a site.

Federal

o Safe Drinking Water Act-Maximum Contaminant Levels (MCLS)

o Clean Water Act - Water Quality Criteria

o Toxic Substance Control Act-PCB Cleanup levels

C0083238

8151b

New Jersey

o Groundwater Quality Standards

o Air Emission Standards for Toxic Substances

o NJPDES Values for Toxic Effluent Limitations

o New Jersey Surface Water Quality Criteria

2) Location-Specific

This section addresses ARARs which place restrictions on theconduct of activities in particular locations. Most of the sitereportedly is within the 100 year floodplain of the DelawareRiver and within an area of potential national historical orarchaeological significance. This necessitates execution ofCERCLA floodplain and cultural resource assessments.Location-specific ARARs which are expected to influence theRI/FS process are as follows:

Federal

Executive Order on Floodplain ManagementFloodplain assessment requirement;

(E.O. 11988) -

o Fish and Wildlife Coordination Act RequirementsCoordination with FWS, NOAA on effect or remedialalternatives with respect to wetlands, ecological resources;

o National Historic Preservation Act Requirements - Culturalresources review under CERCLA; and

o Coastal Zone Management Act - Assessment requirement.

New Jersey

o Flood Hazard Control Act Requirements (NJAC 7:8-3.15)Evaluation of remedial alternatives affecting 100 yearfloodplains, stream channels; and

o Coastal and Waterfront Development Act Requirements (NJSA12:5-3).

3) Action-Specific

This section addresses ARARs which set controls or restrictionsupon the particular remedial activities that may be selected toaccomplish a remedy. These ARARs address the broad range ofremedial strategies under consideration for the Roebling Steel

398151b

Site: source control, plume containment, and groundwatertreatment. For each ARAR the potential remedial activityaffected is noted.

Federal

o Safe Drinking Water Act Underground Injection Requirements- Reinjection of effluent to groundwater;

o Clean Water Act NPDES Stormwater Runoff RequirementsDischarge of effluent to storm sewer or surface water body;

o Clean Air Act NESHAPS Requirements - Discharge of air fromair stripper;

o RCRA Hazardous Waste Manifest Requirements - Off-sitetreatement and disposal;

o Clean Water Act Effluent Limitation Guidelines for Iron andSteel Manufacturing - Discharge of effluent;

o RCRA Hazardous Waste Treatment/Storage/Disposal FacilityStandards - On-site incineration and treatment;

o RCRA Subtitle C Waste Management Standards - On-sitecontainment of hazardous material;

o RCRA Subtitle D Waste Management Standards - On-Sitecontainment of non-hazardous debris; and

o Clean Water Act Section 404/Rivers and Harbors Act Section10 Requirements - Remediation activities in Crafts Creekand the Delaware River.

New Jersey

o NJPDES Discharge to Groundwater Requirements - Reinjectionof effluent to groundwater;

o NJPDES Discharge to Surface Water Requirements - Dischargeof effluent groundwater to storm sewer or surface waterbody;

o New Jersey Administrative Code 7:27, Air Pollution ControlRegulations - Discharge of air from air stripper;

o NJPDES/Burlington County Utilities Authority SewerCorrection, Pretreatment Requirements - Discharge ofeffluent to sanitary sewers;

o Water Supply Requirements - Discharge of effluent topotable water treatment system;

408151b f^noo{jJ0834

o Surface Water Quality Standards - Discharge of effluent tosurface water body;

o Underground Injection Control Requirements - Reinjection ofeffluent to groundwater;

o Flood Prone Area Construction Requirements - Constructionin a flood plain;

o Hazardous Waste Manifest Requirements - Off-Site treatmentand disposal of hazardous material;

o Solid Waste Management Requirements - On-Site containmentof non-hazardous debris;

o Soil Erosion and Sediment Control Act Requirements - Soildisturbance greater than 5,000 square feet of surface areaof land;

o NJDOT Restrictions on Transport of Hazardous Materials -Off-site disposal;

o Hazardous Waste Treatment/Storage/Disposal FacilityStandards - On-site incineration and treatment; and

o Hazardous Waste Management Requirements - On-sitecontainment of hazardous material.

2.9.3.2 Potential "To Be Considered" Requirements

When ARARs do not exist for a particular chemical or when theexisting ARARs are not protective of human health or theenvironment, other nonpromulgated standards or limitations maybe useful in developing a remedial alternative. Being non-promulgated they take the form of criteria, advisories andguidance developed by EPA, other Federal agencies and the Stateof New Jersey. The concepts and data underlying theserequirements may be used at the Site in an appropriate way. Thefollowing Federal and State of New Jersey regulatoryrequirements could be considered for the above listed actionlevels.

1) Contaminant - Specific

Federal

o Clean Water Act Water Quality Criteria;

o EPA Drinking Water Health Advisories - Suggested no adverseresponse levels (SNARLS);

o National Academy of Science Acceptable Daily Intake (ADI)Values; and

o Safe Drinking Water Act Maximum Contaminant Level Goal(MCLGs).

New Jersey

o New Jersey Interim Groundwater Cleanup Guidance (NJDEP2/19/87 ARAR Listing, Attachment 8);

o New Jersey Drinking Water Guidance (NJDEP 2/19/87 ARARListing, Attachment 7); and

o New Jersey Soil Cleanup Objectives

2) Location - Specific

None identified to date.

3) Action - Specific

None identified to date.

428151b C00836

3.0 SCOPING OF THE REMEDIAL INVESTIGATIOK/FEASIBILITY STUDY:INITIAL EVALUATION AND DATA REQUIREMENTS

3.1 RISK ASSESSMENT

To ensure that the sampling recommended in this RI will beadequate to develop a risk assessment, a preliminary riskassessment was prepared to determine the nature and extent ofthe potential threat to human health and the environment fromon-site contaminants. This preliminary assessment onlyqualitatively discusses the potential threat to human health andthe environment because available chemical data have not beensufficiently analyzed. However, based on available Siteinformation (e.g., past practices), it is assumed that the Sitemay be contaminated by a wide variety of inorganic and organicchemicals. One of the purposes of a preliminary risk assessmentis to identify potential exposure pathways and potentialreceptors. The results of this assessment can then help focusSite sampling efforts by identifying information needs.

A quantitative risk assessment will be performed as part of theRI/FS.

3.1.1 Preliminary Risk Assessment

This preliminary risk assessment is based on the information anddata generated during the preliminary Site characterization(Weston 1987). As mentioned above, the purpose of thisassessment is to identify potential exposure pathways andpotential receptors for the Site.

An exposure pathway is defined by four elements: (1) a sourceand mechanism of chemical release to the environment; (2) anenvironmental transport medium (e.g., air, groundwater) for thereleased chemical; (3) a point of potential contact of humans orbiota with the contaminated medium (the exposure point); and (4)an exposure route (e.g., drinking water or soil ingestion) atthe exposure point. All four of the elements must be presentfor an exposure pathway analysis to be considered "complete."In a risk assessment, only complete exposure pathways areevaluated.

As decribed earlier in this work plan, there are numerouspossible sources of contamination at the site including twoinactive wastewater treatment plant sludge lagoons, a slagdisposal area, baghouse dust area, electrical transformerspossibly containing PCB contaminated oils, an abandonedlandfill, and a variety of tanks and drums potentiallycontaining hazardous substances. Moreover, preliminary reviewof chemical analysis of Site soil boring results have identifiedhigh levels of lead (20,000 ppm) , zinc (65,000 ppm) , and cadmium(47 ppm) . Areas in which slag or sludge was disposed of maycontain a range of inorganic chemicals including lead, cadmium,copper, and zinc. Baghouse dust is also likely to contain avariety of inorganic chemicals of potential concern to human

Bisib 000837

health, including lead, chromium, and cadmium. Potentiallytoxic organic chemicals may be present in tank, tank trailer,and drum storage areas.

The following sections will discuss the potential for migrationof chemicals from the Site and the possible exposure pathwaysthat could subsequently occur. In each section where relevant,exposures to both human and environmental receptors will bediscussed and potential exposures under both present and futureSite and land use conditions will be addressed.

There are three principal pathways through which individuals maybe directly exposed to chemicals present in soil: (1) incidentalingestion of soil (2) dermal absorption from contacted soil, and(3) suspension of chemicals volatilized from soil into air andsubsequently inhaled. This inhalation route of exposure isdiscussed later in the inhalation section. Among the chemicalspossibly present at elevated levels at the Site, some are likelyto be potentially carcinogenic when ingested or absorbed (e.g.,PCBs) while others may produce noncarcinogenic effects (e.g.,lead).

Under present Site use conditions, individuals who trespass onor occassionally use the Site may be exposed to chemicals inon-site soil. The Site is partially fenced but due to theexpanse of the Site, entry (by trespassers) is not strictlylimited. Children in particular who may trespass on the Sitemay ride bikes or play on the Site are most likely to be exposedto chemicals that may be present in surface soils. Off-sitesoil near the Site (e.g., in nearby playgrounds) could alsocontain chemicals originating from the Site if chemicals havebeen transported via suspension into air and subsequentdeposition onto the ground. Thus children playing inpotentially contaminated nearby playgrounds or yards could alsobe exposed to site-related chemicals. Exposure to childrencould potentially involve all three pathways.

Under future Site land use conditions, it is possible that inthe absence of remediation it could be reused for industrial orcommercial purposes. In this case, potential exposures tosite-related chemicals could occur among workers employed at theSite. Employee exposures could occur not only as a result ofcontact with on-site soil but also dermal contact with interiorsurfaces in on-site buildings (e.g., walls) that may becontaminated.

Wildlife inhabiting the Roebling Steel Site area, includingwaterfowl and mammals, may also come into contact with chemicalsthat may be present in soil. Direct contact with contaminatedsoil and incidental ingestion could occur among burrowinganimals during construction of dens, or among dustbathinganimals, such as many bird species. Incidental ingestion ofsoil is also a possible exposure route for fastidious animals

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such as raccoons who may ingest soil while grooming, or forseed-eating bird species who may ingest soil while foraging forSeeds on the ground. Indirect exposure of animals tocontaminants in soil may occur via ingestion of grasses andother land plants which may have bioaccumulated contaminants.The importance of this exposure pathway varies from species tospecies because of behavioral differences.

o Groundwater

Available REM II groundwater quality data from unfilteredsamples show that groundwater contains site-relatedcontaminants. While the major direction of groundwater flow issuspected to be northwards towards the Delaware River, thepresence of four municipal wells 1.8 miles to the west of theSite in Florence Township may influence local flow patterns.Local components of groundwater could also discharge to CraftsCreek. Residents located 1,500 feet from the Site south ofCrafts Creek use private wells for their water supply and couldpotentially be exposed to chemicals which may migrate from theSite. The Delaware River is also a nearby source of publicwater supply to the cities of Burlington, New Jersey andPhiladelphia, Pennsylvania. Chemical releases to the DelawareRiver from the Site could potentially impact these drinkingwater supplies although the dilution capacity of the DelawareRiver and the treatment system used for the municipal watersupplies could mitigate potential impacts.

o Surface Water and Sediment

Chemicals from the Site could migrate to surface water andsediment (e.g., Crafts Creek and the Delaware River) viagroundwater discharge, and surface water and soil runoff.Individuals could be exposed to chemicals present in nearbysurface water as a result of incidental ingestion and dermalabsorption. In addition, indirect exposure pathways may alsoexist, for example, involving consumption of produce that hasbeen exposed via irrigation to contaminated surface water orconsumption of fish caught from Crafts Creek or the DelawareRiver containing chemicals from the Site. Individuals who maydirectly contact sediment in nearby surface water bodies (e.g.,children) may also be exposed to site-related chemicals. Underpresent Site use conditions, exposures to nearby residents,particularly children who may play in Crafts Creek orindividuals who may fish from Crafts Creek, are most likely tobe of concern if site-related chemicals are present in surfacewater and sediment.

Fish and other aquatic organisms may be constantly exposed tocontaminants originating from the Site and present in surfacewater and sediment. Additionally, most other environmentalreceptors also are dependent on surface water as a source ofdrinking water. Terrestrial animals who rely on Crafts Creek orthe Delaware River for drinking water may be exposed via

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ingestion to site-related chemicals present in surface water.If there are any mammals living in dens near the Site, theymight use a nearby surface water body as a major source ofdrinking water. Thus the surface water and sediment exposurepathways are potentially important pathways to consider. Amongbirds, chemical exposures due to ingestion of contaminated watercould occur, but this pathway is not believed to contributesignificantly to overall intake relative to intake via food formost chemicals.

In general, many chemicals in water are Known to bioconcentratedirectly in invertebrate organisms and in fish tissue via uptakethrough the gill membranes. Fish which may inhabit Crafts Creekand the Delaware River may therefore be exposed to chemicalsthat may be present in surface water. Omnivorous mammals suchas raccoons, or bird species such as ducks who may consume suchpreviously contaminated aquatic organisms, may be affectedbecause of biomagnification through the food chain. Likewiseplants may also bioaccumulate chemicals via uptake of surfacewater through the roots and translocation to various edibleportions of the plant. The chemicals may then be ingested byanimals higher up in the food chain. Exposure to chemicalspresent in sediments is another possible exposure pathway forecological receptors. In addition to benthic (bottom dwelling)aquatic organisms who may be continuously exposed tocontaminants in the sediment, wading birds or other animals mayalso be exposed to contaminants from direct contact withsediment while foraging for food.

o Air

Inhalation exposures may occur as a result of inhalation ofresuspended particulate matter from the Site and of chemicalsvolatilized from the Site. The soil on the Roebling Steel Siteis not very well vegetated (i.e., limited ground cover) and as aresult winds may suspend soil particles and transport themdownwind to off-site receptors. Vehicular traffic which mayoccur on Site on unpaved areas (e.g., particularly underpotential future Site use conditions) can stir up significantquantities of surface soils. Baghouse dust present at the Sitedue to the fine nature of the particulate may be more easilysuspended than soil particles. Chemicals which are adsorbed toairborne soil or baghouse dust particles are available forinhalation. Volatile chemicals may also be emitted into the airfrom contaminated source areas such as soil and then transporteddownwind to nearby receptors.

The potential magnitude of inhalation exposures to receptorswould depend upon chemical concentrations in volatile emissionsor in soil/dust emissions and other factors related to the typeof air emission source (e.g., size of contaminated area). Underpresent Site use conditions, residents living nearby, such as inRoebling, may be regularly exposed to chemicals potentiallyemitted from the Site. Under potential future Site use

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conditions, if the Site were reused as an industrial facility,on-site workers could also be exposed to airborne chemicals.

3.1.2 Summary of Information Needs

In order to evaluate the potential risks to human health and theenvironment associated with the potential exposure pathwaysdiscussed above, additional information is required. Samplingof each environmental media through which exposures couldpotentially occur (soil, surface water, sediment, groundwater,and air) needs to be conducted to identify the extent andmagnitude of Site contamination. In addition, backgroundsamples are required in order to identify Site-relatedcontamination.

To evaluate exposure pathways involving soil, chemicalconcentrations in surface soil and throughout the soil columnare needed (e.g., for the direct contact exposure pathway andfor volatilization modeling, respectively). To conductvolatilization and wind erosion modeling for the inhalationexposure pathway, additional environmental parameter informationis required, including surface soil and baghouse dust particlesize distribution, and the fraction of organic carbon in soil.In addition, if chromium is found to be present in on-sitesoils, speciation of chromium (CrIII and CrVI) will greatlyimprove inhalation risk estimates since CrIII is noncarcinogenicwhen inhaled whereas CrVI is carcinogenic when inhaled. Airsampling results will be useful to identify whether there is asignificant Site-related impact on chemical concentrations inambient air.

To evaluate exposure pathways involving surface water andsediment, both for human health and ecological impacts, samplingdata from these media are required. To predict discharges ofchemicals from groundwater into surface water, data that wouldbe needed would include chemical concentrations in groundwaterwhich potentially discharges into surface water, and groundwaterflow direction and rate.

Information on potential human and ecological receptors willneed to be obtained to evaluate potential exposure pathways.Human population activity patterns in the site area will beresearched based on information obtained from individualsfamiliar with the area (e.g., to what extent do individualscurrently trespass onto and use the site, or play in or fishfrom Crafts Creek). Information on potential ecologicalreceptors will be obtained from local and regional sources(e.g., U.S. Fish and Wildlife Service, nearby EnvironmentalResearch Centers) and based on information from individualsfamiliar with the Site area.

3.2 SCOPING OF REMEDIAL ALTERNATIVES

Although the existing data base is inadequate to define thethreat to public health and the environment, several preliminary

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remedial response objectives may be formulated from thepreliminary risk assessment and previous Site investigation.

After data are gathered and evaluated in Tasks 3 through 7,these objectives will be refined and developed or, asappropriate, eliminated. Attainment of the RI objectives willprovide a basis for evaluation of these preliminary remedialresponse objectives. For example, if the extent to whichnatural and manmade barriers contain contaminants and theadequacy of the barriers (i.e., cap) are assessed, the potentialfor direct contact with contaminants can also be assessed.Other RI objectives, including assessment of chemicaldistribution and migration, will also allow better definition ofthe risk associated with direct contact with Site relatedcontaminants.

On the basis of the existing data, five preliminary remedialresponse objectives were identified to mitigate risks associatedwith the Site. These objectives include:

1. Minimizing human exposure to contaminants that may bepresent in soil and groundwater;

2. Minimizing human exposure to structures, railraod cars,on-site sources, and transformers;

3. Minimizing human exposure to contaminants that may bepresent in air;

4. Protect environmental receptors (possibly surface waterand sediment); and

5. Assuring that site conditions and remedies meet theARARs.

To meet the above preliminary remedial response objectives, aset of general response actions were identified and arepresented in Table 12 by the following media:

SoilGroundwaterStructures (buildings, tanks, equipments, wastewatertreatment plant, sewers)DrumsAbandoned Railroad CarsOn-Site sources (landfill, sludge lagoons, baghousedust storage area, slag piles)TransformersAirSedimentSurface Water


PRELIMINARY IDENTIFICATION OF REMEDIALTECHNOLOGIES/ALTERNATIVES

GeneralResponseAction

SOIL

No Action

RemedialTechnology/Category

Monitoring (soil, groundwatersurface water and sediment)

- Public awareness program

- Restrict access and use

Containment - Capping/surface sealing

Excavation/Treatment/Disposal

GROUNDWATER

No Action

Containment

Collection/Treatment/Discharge

Excavationchemical fixation andsolidificationSolvent extractionKPEGSoil washingIncinerationConstruct landfillExisting landfill

Monitoring (groundwater,surface water and sediment)Public awareness programRestrict use of groundwater

Barriers (horizontal &vertical)PumpingChemical precipitationReverse osmosisIon exchangeAir strippingCarbon adsorption

DataRequired

Risk assessment

Geohydrologicaldata

Soil character-ization, BenchScale/Pilot PlantTreatabilityStudies

RegulatoryrequirementsAvailable landfillidentification

Risk assessment

GeohydrologicaldataGroundwatercharacterizstionand bench/pilottreatabilitystudies

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STRUCTURES(Buildings,Tanks,Equipment,WastewaterPlant,Sewers)

No Action

ContainmentExcavation/Demolition/Decontamin-ation/Disposal

Decontam-ination/Restoration

RemedialTechnologyCategory_____

Discharge to POTWDischarge to riverReinjectionPump to water supply system

DataRequired

Availability ofregulatory req-ment publicacceptance

MonitoringPublic awareness programRestrict access and use

EncapsulationExcavationDissmantlement/demolitionVacuumingGritblasting/hydroblastingSteam cleaning/solventWashingSurface sealingTreat decon waterDischarge to POTWConstruct landfillExisting landfill

VacuumingCleaning and washingPainting and coatingDismantlement/erection

Risk assessment

Characterizationof all structures

Regulatoryrequirement

Removal Off-site disposal

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BURIED DRUMS

No Action


Monitor (soil and drums)conditionRestrict access and use

Excavation/ - ExcavationRemoval Off-site disposal

ABANDONED RAILROAD CARS (ALL SOLID MATERIAL)

No Action - Monitor

Collection/ - Off-site disposalRemoval

ON-SITE SOURCES

(Landfill,sludge lagoons,baghouse duststorage)

No Action

Containment

- Monitoring

Capping/surface sealingHorizontal and verticalbarriers

Excavation/ - ExcavationTreatability/- Leachate collectionDisposal Extraction

Chemical fixation &solidificationVitrificationChemical precipitationLand treatment

- Construct landfill- Existing landfill

DataRequired

Risk assessment

Risk assessment

Risk assessment

Characterizationof on-site soils

Regulatoryrequirements

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Monitoring

Off-site disposal

TRANSFORMERS

No Action

Removal

AIR

No Action - Monitoring

Containment

DataRequired

Risk assessment

SEDIMENT

No Action

Containment

Excavation/Treatment/Disposal

Surface sealingEncapulationOther dust control

- Monitoring

Horizontal and verticalbarriersSediment excavationChemical excavationFixation and solidificationChemical precipitationBiodegradationLand treatment (Forming)Construct landfillExisting landfill

Risk assessment

SURFACE WATER

No Action

Treatment

Risk assessment

Monitoring

Physical/chemical treatment

Regulatoryrequirements

Risk assessment

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The general response actions for each media will fall into one,if not all of the following categories:

o No Actiono Containmento Excavation/Decontamination/Removal/Treatment/Restoration/

Disposal

A preliminary description of remedial technologies that addressthese general response actions are presented together with apreliminary evaluation of which media would be treated by eachremedial technology category, since most of the No Action,Containment, Treatment, Disposal technologies are common to oneor more operable units.

o No Action

The No Action category will be evaluated to provide acomparative basis for other remedial alternative evaluations.The No Action alternative means that no remedial actions(containment or treatment) will be designed and implemented fornone of the operable units and environmental evaluations(including risk assessment). Implementation of the No Actioncategory would require long-term monitoring, (e.g. air,groundwater and surface water etc.), and might includeinstitutional control (e.g., prohibit the use of private wellwater for drinking and irrigation purposes and the use ofland). The No Action category will be evaluated for each media.

o Containment

Containment alternatives would include: 1) utilization ofimpermeable barriers and caps to completely isolate thecontaminated soil/sediment from rainfall runoff, surface waterand groundwater; 2) re-containerization and centralized storageof all drums to completely prevent any release of contaminantsto the environment. Containment alternatives such as barrierwalls and capping would apply to groundwater and soil.

Encapsulation which applies to structures/buildings wouldinvolve creating a total enclosure to reduce contaminantmigration.

o Excavation/Decontamination/Removal/Treatment/Restoration/Disposal

Contaminated media (such as soils) at the Site can be handled byeither excavation and on-site or off-site treatment/disposal, orin-situ treatment. These remedial technologies includetreatment of contaminated media to reduce or eliminate potentialrisk to public health and the environment. Several processesare currently available to accomplish this as follows.

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Chemical fixation and solidification which may apply to soilsand sediments containing heavy metals involve the addition ofsiliceous material combined with setting agents such as lime orcement resulting in a stabilized and solidified product.Commercial proprietary fixation agents and processes can be usedfor both inorganic and organic contaminated soils/sediments.

Incineration is the destruction of organics in contaminated soiland wastes. Incineration may apply to contaminated soilcontaining petroleum hydrocarbons. Since the soil at the Sitealso contains heavy metals, technologies for air emissioncontrols and disposal of the treated soil would also need to beevaluated.

Solvent extraction which may apply to soils and sedimentscontaining organics consists of extraction oforganic contaminants by passing extractant (solvent) solutionsthrough the contaminated soil.

Removal of chlorinated organics can also be an effectiveremedial alternative. KPEG which utilizes potassiumpolyethylene glycol and alkali solution to remove chlorinatedorganics may apply for PCB contamiated soils and transformerfluid.

Soil washing involves chemical and physical processes toseparate contaminants adsorbed onto soils. The chemical processapplies solvent extraction methodologies to remove contaminants(metals and organics) from the soil. Physical processes mayinclude classification of the contaminated soil prior toextraction, removal of excess moisture from the treated soilafter extraction, and recovery of the spent solvent.

In-situ soil flushing is the in-place washing of contaminantsfrom the soil with a suitable solvent such as water, surfactant,or an acidic solution. The contaminated elutriate is pumped tothe surface for removal, resource recovery and recirculation, oron-site treatment and reinjection. This technology may beapplicable for contaminated soil containing volatile organicsand metals.

Chemical precipitation which applies to contaminated groundwaterand possibly stormwater runoff from the Site is a pH adjustmentprocess in which acid or base is added to a groundwater toadjust the pH to a level where the contaminants are leastsoluble. Metals can be precipitated from groundwater ashydroxides, sulfides, carbonates or other insoluble salts.

Reverse osmosis is a technology in which contaminants areremoved through a semipermeable membrane. This technology couldbe used for groundwater treatment to remove dissolved inorganiccontaminants.

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Ion exchange is a process whereby selective ions are removedfrom the aqueous phase and exchanged for less harmful ions heldby ion exchange resins. Ion exchange can also be used toremove metals from groundwater.

Air stripping which can be used to remove volatile organics fromthe groundwater is a mass transfer process in which volatileorganics are transferred to gaseous vapor phase and eitherreleased to the atmosphere in acceptable concentrations orremoved from the air stream by a treatment system if theconcentrations are high.

Carbon adsorption which can be used to remove organics fromgroundwater involves contacting a waste stream with the carbon,usually by flow through a series of packed bed reactors. Theactivated carbon selectively adsorbs hazardous constituents inthe waste by a surface attraction phenomenon in which theorganic molecules are attracted to the internal pores of thecarbon granules.

Vacuuming can be used to remove loose particulate contaminationsuch as asbestos from the surface of structures. Thistechnology is generally used in conjunction with otherdecontamination technologies and would be evaluated for thestructures/buildings.

Gritblasting is a surface removal technique in which an abrasivematerial is used for removal of contaminated surface layers frombuildings or tanks. Hydroblasting uses a high-pressure waterjet to remove contaminated debris from surfaces. Thesetechnologies would be evaluated for the structures/buildings andrailroad cars.

Solvent washing technology consists of pressure-sprayingfluorocarbon solvents (e.g. freon 113) onto contaminatedsurfaces followed by collection and purification of thesolvent. Steam cleaning uses steam in place of solvent toremove surface contamination only. Solvent washing would alsobe evaluated for decontamination of structures.

Surface sealing is essentially painting or coating surfaces tocontain contaminants within the structure using resins. Surfacesealing would also be evaluated for the structures.

In general, technologies will be screened by site-limitingcharacteristics, waste-limiting characteristics, and inherentlimitations of the technologies with respect to effectiveness,implementabilty and cost.

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3.2.1 Summary of Information Needed for the FS

Based on preliminary information available on the Roebling SteelSite and the preliminary scoping of Remedial Technologies andAlternatives (Table 8) the following list of information isneeded for the completion of screening and development ofremedial alternatives.

1. Characterize contaminated media at the Site(distribution and extent of contamination for each);

2. Geological data to completely characterize the soil atthe Site;

3. Hydrogeological information to characterize groundwatermovement;

4. Engineering data appropriate to each media forpreliminary remedial design; and

5. Treatability testing data for contaminated material(e.g. soil and groundwater, sediment, baghouse dustetc.)

3.2.2 Need for Treatability Studies

Two potentially contaminated media at the Site will requiretreatability studies: soils and groundwater.

For soil, treatability studies are needed to develop informationon chemical fixation of the metals in the soil. The effect ofthe presence of Petroleum Hydrocarbons on chemical fixation ofmetals needs to be evaluated to determine the feasibility ofthis technology. In addition, soil washing with acidic solutionwould be evaluated as an alternative to chemical fixation.

For groundwater, treatability studies are needed to evaluate theremoval of metals such as lead by technologies such as chemicalprecipitation, sedimentation and filtration. In addition,treatability tests are required to evaluate the treatmenttechnologies applicable to the wastewater generated from thedecontamination of the structures.

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4. 0 WORK PLAN OBJECTIVES

4.1 OBJECTIVES OF THE PROJECT

The principal objectives of the RI are to determine the natureand extent of contamination and provide sufficient data for theevaluation of remedial alternatives. In addition, theinformation obtained during the RI will be utilized fordeveloping a public health and environmental risk assessment,and for the scoping of treatability studies (if appropriate).

The RI will consist of determining the level of contamination inthe following environmental media:

o Surface and subsurface soils;o Surface water;o Sediments in surface water bodies;o Groundwater and air; ando In the following potential sources:

abandoned drums,buildings,baghouse dust pile,railroad cars,transformers,tanks,insulation materials,lagoons,slag piles,landfill area, andsettling and flocculation tanks (wastewatertreatment plant).

The objective of the FS is to evaluate potential remedialalternatives and ultimately provide information required by theUSEPA to select a cost-effective remedy which will adequatelyprotect human health and the environment.

4.2 SUMMARY OF INFORMATION NEEDED

Based on the objectives discussed in Section 4.1 and a review ofthe existing data base, the data needed for characterizingcontamination at the Site can be identified as follows:

o Define the overall Site hydrology and geologicstratigraphy;

o Quantify and identify surface water, groundwater, soil,sediment and air contamination at the Site andpotential off-site migration areas; and

o Identify and determine the extent and nature ofcontamination of all the on-site potential sources.

This information will be obtained during the implementation ofthe Remedial Investigation.

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4.3 DATA QUALITY OBJECTIVES (DQO)

DQO's are based on the concept that different data uses mayrequire different data quality. Data quality is defined as thedegree of certainty of a data set with respect to precision,accuracy, reproducibility, comparability, and completeness.DQO's are qualitative and quantitative statements specifying thequality of data required to support RI/FS activities includingsite screening, characterization and risk assessment, and tosupport engineering alternative evaluation and selectiondecisions. The five categories of data quality are as follows:

o Screening (DQO Level 1) provides the lowest dataquality but the most rapid results, and is used forpurposes of site health and safety monitoring,preliminary comparison to ARAR's and initial sitecharacterization to define areas for further study.The data generated indicates presence-absence ofcertain constituents and is generally qualitativerather than quantitative.

o Field Analysis (DQO Level 2), provides rapid resultsbut better quality data than DQO Level 1. Analysisincludes some mobile-lab generated data and datagenerated by use of analytical instrument which arecarried in the field. The data may be qualitative orquantitative.

o Engineering (DQO Level 3), provides an intermediatelevel of data quality and may be used for sitecharacterization or risk assessment. Engineeringanalysis includes mobile lab generated data andstandard commercial laboratory analyses without fullCLP documentation. These data are both qualitative andquantitative. The analysis conducted in support oftreatability studies will be performed to DQO Level 3.

o Confirmational (DQO Level 4), provides the highestlevel of data quality and is used for purposes of riskassessment, engineering design and cost recoverydocumentation. Conformation analyses require full CLPanalytical and data validation procedures.

o Non-Standard (Level 5) - This refers to analysis byNon-Standard procedures, for example, when exactingdetection limits are required, or analyses of anunusual chemical compound. These analyses oftenrequire method development or adoption.

For the Roebling Steel Site, DQOs have been established to meetinvestigative data needs. The review of Site data has shown

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that data deficiencies exist in the area of risk assessment asit relates to the No Action alternative, engineering design andprocess evaluation.

The presence of deficiencies in the available data indicatesthat data of DQO Level 3 or above are appropriate. DQO Level 4will be generated for the chosen analytes of interest for thosesamples sent to the CLP Laboratories as potentially responsibleparties (PRPs) are involved in this project.

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5.0 TASK PLAN FOR REMEDIAL INVESTIGATION

The tasks for the Site RI/FS correspond to the 15 tasksdescribed in the EPA Guidance for RI/FS Tasks for REMContractors (OSWER Directive 9242.3-7). Of these 15 tasks,eight are considered part of the RI, and the remaining areincluded in the FS. The order in which these tasks arepresented is the general order in which they will be performed;however, since some tasks (e.g., Community Relations andTreatability Study, Bench Scale Testing) occur throughout theduration of the RI/FS and during the field investigation, theorder of presentation gives only a general indication of theorder the tasks will follow.

The following tasks are considered to be part of the RI:

o Task 1-Project Planningo Task 2-Community Relationso Task 3-Field Investigationo Task 4-Sample Analyses/Validationo Task 5-Data Evaluationo Task 6-Risk Assessmento Task 7-Treatability Study/Bench Scale Testingo Task 8-Remedial Investigation Report

The following five tasks are considered to be part of the FS:

o Task 9-Remedial Alternatives Screeningo Task 10-Remedial Alternatives Evaluationo Task 11-Feasibility Study Reporto Task 12-Post RI/FS Supporto Task 15-ERA Planning

This section describes each of the eight tasks comprising theRI. Section 6.0 describes the five tasks comprising the FS.

5.1 TASK 1 - PROJECT PLANNING

This task involves several subtasks which must be performed inorder to produce the project planning documents and projectschedule necessary to execute the RI/FS. These subtasksinclude: a kick-off meeting; site visits; RI/FS brainstormingsessions; the evaluation of existing data; the preliminaryidentification of remedial alternatives; preparation of apreliminary risk assessment; data quality objectivedeterminations; determination of ARARs; and scoping of the RI.All these activities are required for the preparation of theproject plans.

The preparation of the project plans includes completion ofdraft and final versions of a Work Plan and a Field OperationsPlan (FOP). The FOP is further broken down into three plans:the Site Management Plan (SMP); the Field Sampling and AnalysisPlan (FSAP); and the Health and Safety Plan (HASP). Thecontents of these three plans are described as follows:

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o The SMP includes: a brief site description; anoperations plan outlining the site team organizationand responsibilities; and the field operationsschedule. This plan also addresses the site securityand control of access by unauthorized personnel to beimplemented at the site.

o The FSAP includes: sampling and analytical objectives;the number, type, and location of all samples to becollected during the field investigation; thesite-specific quality assurance requirements (whichwill be in accordance with the Quality AssuranceProject Plan for the REM III Program and Region IIEnvironmental Services Division requirements); thedetailed procedures for field activities; and datamanagement elements.

o The HASP includes: site-specific information; a hazardassessment; training requirements; monitoringprocedures for site operations; safety and disposalprocedures; and other requirements in accordance withthe HASP for the REM III Program.

The FSAP will be prepared after submittal of this Work Plan.

5.2 TASK 2 - COMMUNITY RELATIONS

REM III community relations staff will assist EPA in preparingand implementing the approved community relations plan for theRoebling Steel Site. Community relations implementationassistance will be provided as specifically requested by EPA andis expected to include the following:

Subtask 1: Preparation of a Community Relations Plan (CRP)

REM III Community Relations staff will prepare and submit adraft and final community relations plan to EPA. The communityrelations plan will include a site history, assess currentcommunity concerns, and identify specific community relationstechniques to be implemented at the site.

Subtask 2: Preparation of two updates; one at the initiation ofthe Remedial Investigation and Focused Feasibility Study

The first update will describe activities conducted ot plannedas part of the RI/FS and FFS. The other update will describethe results of the remedial investigation.

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Subtask 3: Coordination of property access for the RI/FS fieldactivities.

During the RI, EPA and REM III staff expect to conduct samplingon off-site areas the include private properties. At therequest of EPA, REM III community relations staff will assistEPA with obtaining access to private properties for samplingpurposes and informing property owners about the purpose andtest results of the sampling. This may include:

o Developing resident permission forms;

o Contacting residents to obtain completed permissionforms for allowing EPA access to residential properties;

o Scheduling appointments for REM III contractors withcommunity residents as needed; and

o Providing follow-up telephone calls to residents toensure that the sampling was completed and to respondto any question residents may have regarding EPAactivities.

Subtask 4: Providing meeting support and public meeting summaryfor public meeting.

REM III community relations staff will provide logisticalsupport and attend one meeting on the RI/FS and FFS work plan.A public meeting summary for the public meeting on the RI/FSwork plan will be prepared.

Subtask 5: Assistance to EPA with planning and implementationof one informal public availability session.

REM III community relations staff will assist EPA at one publicavailability session on the RI/FS and FFS workplan. The purposeof this session is to answer specific questions from residentsand local officials about the Roebling Steel Corporation site.REM III community relations staff will provide the followingsupport:

Arrange for public availability session location androom setup;

Provide information to EPA personnel about possiblequestions, issues, and concerns citizens have about theproject;

Provide a summary report of issued identified duringthe public availability session with an action list forappropriate EPA follow-up.

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Subtask 6: Establishing and updating a mailing list for this

Subtask 7: Seminar on sub-contracting procedures:

EPA staff will prepare and deliver a half-day seminar on theprocedures and requirements for bidding on Superfundsubcontracts. This task includes seminar logistics, preparationof materials, graphics and delivery of the seminar at onelocation in southern New Jersey.

Subtask 8: Providing coordination. planning and managementsupport .

REM III community relations staff will provide general planning,management, analytic and coordination support to EPA and REM IIItechnical support staff during the community relationsactivities at this site. This may include: meeting with EPA todiscuss planning and scheduling community relations activities;providing information and analysis about concerns expressed bylocal officials and residents in the area during the developmentof the community relations plan, and coordination with the REMIII staff.

All subtasks identified above have been proposed based onconversations with EPA staff. All work done on these tasks willbe initiated by the EPA Region II Superfund Community RelationsCoordinator and coordinated with the EPA Remedial ProjectManager, the REM III Technical Team, and the REM III CommunityRelations Manager.

5.3 TASK 3 - FIELD INVESTIGATION

5.3.1 Objectives

This task includes all efforts related to implement a fieldinvestigation at the Site. The objectives of the fieldinvestigation for the Roebling Steel Site are as follows:

o Delineate the areal and vertical extent of soilcontamination in Site soils, groundwater and riversediment;

o Delineate the areal and vertical extent of groundwatercontamination;

o Identify and characterize the potential sources (andtypes) of contamination;

o Gather data to evaluate remedial alternatives; and

o Gather data to support a risk assessment, and, asnecessary, treatability studies.

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5.3.2 Approach

The objectives of the field investigation will be accomplishedby performing the following subtasks:

1. Subcontracting2. Mobilization and Demobilization3. Soil Sampling

3a. Subsurface Soil Sampling3b. Surface Soil Sampling

4. Hydrogeologic Investigations5. Monitoring Well Installation6. Groundwater Sampling7. Building Investigation8. Baghouse Dust Sampling9. Railroad Car Sampling10. Transformer Sampling11. Tank Sampling12. Insulation Sampling13. Sludge Lagoon Sampling14. Slag Piles Sampling15. Landfill Assessment16. Air Sampling17. Water Treatment Plant Settling/Flocculation Tank

Sampling

5.3.3 Procurement and Mobilization

5.3.3.1 Subcontractor Procurement

This subtask will include the procurement of the subcontractorsto support conduct of the Field Investigation. The followingsubcontracts will be required to support the field investigation:

o A surveying subcontract for establishment of boundarylines (boundary survey); benchmarks/monuments forvertical and horizontal control and determining thephysical relief of the site (topographic survey); andfor the surveying of locations and elevations ofmonitoring wells, siting sampling points and all thefeatures at the Site such as buildings/foundations,roads, fences, manholes, railroad cars and above-groundtanks (location survey);

o A drilling subcontract for soil sampling, monitoringwell installation and development, and for digging testpits at the landfill;

o A subcontract for the man-lift to sample elevated pipeinsulation; and

o An electrical subcontract to ensure that the on-sitetransformers are not "live" with electrical current.

64 O O Q 8 5 88J51b

5.3.3.2 Mobilization and Demobilization

This subtask will consist of field personnel orientation,equipment mobilization, and the staking of sampling andmonitoring well locations.

Each field team member will attend an orientation meeting tobecome familiar with the history of the Site, health and safetyrequirements, and field procedures.

Equipment mobilization will entail the ordering, purchase, andif necessary, the fabrication of all sampling equipment neededfor the field investigation. A complete inventory of availableREM in equipment will be conducted and any additional equipmentrequired will be secured. Utility hookups and the set up of afield office in an on-site building will also be part of themobilization effort.

Locations for the soil borings, surface soil samples andgroundwater monitoring wells will be measured from existinglandmarks and located on a Site base map once the topographicsurvey is complete.

Demobilization will consist of equipment demobilization and willbe performed at the completion of each stage of field activitiesas necessary. Equipment demobilizaton may include but will notbe limited to sampling equipment, drilling subcontractorequipment, health and safety decontamination equipment, andfield office building vacancy and utility hook ups.

5.3.4 Site Survey and Mapping

The purpose of the Site survey is to develop a base map. Thebase map will serve as a basic tool during the RI/FS forestablishing well locations, siting sampling points, determiningcontaminant distribution, establishing a datum for subsurfaceinvestigations, and establishing the Site boundary and gradientrelative to runoff pathways. The base map will also assist theinvestigators in locating potential problems for the fieldinvestigation team, such as swampy areas at sampling locations,etc.

The Site survey will include a boundary survey, topographicsurvey and a location survey. The boundary survey will conformto New Jersey laws which cover the establishment of boundarylines between properties. The topographic survey will includethe establishment of two benchmarks/monuments on the Site forvertical and horizontal control plus it will determine thephysical relief of the Site. The location survey will locateall the facilities at the Site such as roads, fences,buildings/foundations, manholes, railroad cars and tanks.

The accuracy for horizontal and vertical control points will bethird order. The precision required for elevation measurementsshall be to one-hundredth (0.01) of a foot on firm surfaces(concrete, well casing, etc.) and to one-tenth (0.1) of a foot

658151b

000859

on ground shots. The precision for angle measurement will be totwenty (20) seconds and the precision for distance measurementwill be one-tenth (0.1) of a foot.

5.3.5 Soil Sampling

Soil samples for analytical testing or geologic characterizationwill be obtained from locations on the Site and in surroundingareas. The samples will be taken from the surface to depths ofapproximately 18 feet (two feet below the maximum estimateddepth to the water table on the Site). Data from the presentsoil sampling program and previous testing will be used toassess soil contamination at the Site. The purpose of the soilsampling is to determine the vertical and horizontal extent ofsoil contamination at the Site, and to determine the contaminanttypes and concentrations. Soil samples will be collected fromsurface (0-2H), shallow subsurface (2-24" and 24"-48") and deep(one sample approximately at water table and one fromapproximately 2 feet below the water table) locations. Thesesoil sampling locations can be characterized as:

o Surficial soil samples - will include surface samplesfrom 37 areas previously found to contain soilcontamination, three off-site background locations,thirteen proposed monitoring well locations, tenoff-site playground (to the southeast of the site)locations, and four deep soil boring locations for atotal of 67 locations;

o Shallow subsurface samples - will be collected at thesame locations as the surface samples except theplayground samples will consist of three locationsbeneath the water tower (in the playground area to thenorthwest) and one sample (2"-24" deep) will beobtained from the shallow cluster wells (MW-18s andMW-24s) for a total of 62 locations; and

o Deep soil samples - will be collected at four deepboring sites (DB-1 to DB-4), eight sites designated fornew monitoring wells and, four sites designated forwell clusters (MW-5, MW-8, MW-18, and MW-24) and at thedeep (100-125 feet depth) borehole location (MWD-1) fora total of 17 locations.

Soil sampling locations are shown on Figures 10 and 11.Additional information on the soil sampling program arepresented below.

5.3.5.1 Surface Soil Sampling

Ebasco has already conducted a sampling effort (on 12/14/88) inthe off-site playground area located adjacent to the northwestern Site boundary. Twenty eight surface soil samples (grab)were collected at depths of 0-2" including four samplesunderneath the water tower. These samples were sent to CLPlaboratories for TCL extractables and TCL metal analyses. No

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additional samples will be collected in this playground areaexcept for those to be collected underneath the water tower.

Surface soil samples will be collected from 67 proposed soilsampling locations within or surrounding the Site. The purposeof the surface soil sampling is to assess the extent, type, andconcentration of contamination in surface soils at the Site andsuspected adjacent areas. Sample depth is ground surface to twoinches and includes locations of deeper soil sampling. The 67surface soil sampling locations include:

o 37 areas where existing data indicate contamination ispresent (soil sampling locations, SB-1 to SB-37).Samples will be collected using stainless steel scoops;

19 samples in areas where previous REM II samplingshowed high concentrations of contaminants; and

18 samples in areas where limited data exist andpotential contaminant sources exist (e.g., oilsoaked area, areas of high EP toxicity results,etc.).

o The surface soil in the area penetrated by the newwells except MW-18(s) and MW-24(s). Samples (13) willbe collected using stainless steel scoops. Locationswere selected on the basis of:

- their proximity to source areas;- their location upgradient of the groundwater

flow; andtheir location in areas influenced by tidal

fluctuations;

o Four deep soil borings (DB-1 to DB-4) located in areaswhere high metal contamination was detected duringprevious investigations. Samples will be collected bythe split-spoon method;

o Three background areas (off-site) to assess the qualityof the soil that has not been subjected tocontamination by Site processes, BS-1 to BS-3. Sampleswill be collected using stainless steel scoops; and

o Ten off-site playground area samples from theplayground adjacent to the southern site boundary.

The analytical tests for the surface soil samples include TargetCompound List (TCL) and Petroleum Hydrocarbons. In addition,selected samples will be tested for cation exchange capacity(CEC), metal speciation (Cr+3, Cr*6), total organic carbon(TOC) and TCLP for the on-site, background, monitoring well andplayground sampling locations. The analyses proposed by Ebascoinclude the TCL which includes more parameters than previoussoil testing performed at the Site. The EP Toxicity andPetroleum Hydrocarbon testing performed earlier included onlyeight metals and total Petroleum Hydrocarbon, whereas the TCLincludes 150 priority pollutants. Furthermore, another major

678151b

difference is that the EP Toxicity Analysis tests the leachedcontaminants, whereas TCL tests for total soil contamination.The more rigorous program of testing will provide a greaterdegree of assurance that contaminants present are detectedduring the soil testing program. Table 13 presents a summary ofthe field sampling and analyses program.

5.3.5.2 Shallow Subsurface Soil Sampling

Shallow subsurface soil samples will be collected at 62locations. The localities are the same as the surface samplelocations (Section 5.3.1) excluding the 38 playground locations.

The basis for choosing the locations is the same as for thesurface soil sampling. The sample localities include the deepersoil boring locations and are in the following areas:

o 37 areas found to contain contaminants (samplescollected from deeper portions of the same borings aslocations in the surface soil sampling, SB-1 to SB-37),samples collected using stainless steel hand augers;

o Three background areas off-site to test the quality ofsoil not exposed to Site processes (samples collectedfrom the same locations as the background locationboreholes in the surface sampling, BS-1 to BS-3),samples collected using stainless steel hand augers;

o Eight proposed shallow (MW-19 to MW-23, and MW-25 toMW-27), four proposed well clusters (MW-5d and MW-8dand MW-18s and d, and MW-24s and d), one deepmonitoring well (MWD-1) and one sample from the shallowcluster well (MW-18s and MW-24s) locations. Sampleswill be collected using a split-spoon ahead of a hollowstem auger;

o Four deep soil borings designed to detect verticalextent of contaminant migration (DB-1 to DB-4). Thesesample locations are in areas where high concentrationsof metals were detected in previous investigations.Samples will be collected using a split spoon ahead ofa hallow stem auger; and

o Three off-site locations beneath the water towerlocated adjacent to the western site boundary (atdepths of 2"-24H and 24"-48"). Samples will becollected using a stainless steel hand auger.

Shallow subsurface soil samples from hand-augered boreholes willbe collected from two depth intervals: two to 24 inches and 24to 48 inches. Subsurface soil samples will be analyzed for allTCL parameters, Petroleum Hydrocarbons and selected samples willbe analyzed for TCLP, TOC and CEC.

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5.3.5.3 Deep Soil Boring Sampling

Deep soil borings include the drill holes for the eight proposedsingle groundwater monitoring wells (MW-19 to 23 and MW-25 to27), the four well clusters (MW-5d, MW-8d, MW-18s and d, MW-24sand d) the deep monitoring well (MWD-1) and four deep borings(DB-1 to DB-4). The purpose of soil sampling in the deep boringsis to determine the vertical extent of soil contamination.

Locations of the eight monitoring wells are chosen on the basisof the need to determine groundwater contamination downgradientof the identified potential source areas of contamination, aswell as to determine any soil contamination. (Locations of themonitoring wells are discussed further in Section 5.3.7 HellMonitoring Installation). Locations of the deep soil borings(without monitoring wells) are based only on the need forcollecting deeper soil samples in areas known to be contaminatedwith high levels of metals. The data about soil contaminationare from earlier investigations at the Site. The rationale forlocation of the deep borings (without monitoring wells) is:

o DB-1 Previous soil investigations show this area hadthe highest levels of lead contamination

o DB-2 Baghouse area, a known source of metalcontamination from baghouse dust (Cd, Cr, As, Pband Zn were high).

o DB-3 Previous soil investigations show this area hadthe highest levels of Zn contamination. Also,Pb, As, Cd, Cr, Mn and Cu were high.

o DB-4 Around Building 114-a potential source of metalcontamination. Previous soil investigationshows high levels of Cu, Pb, Mn, Cr, Zn, As, Sn,and Cd in this area.

The eight proposed shallow, the deep and the four well clustergroundwater monitoring wells will be installed as discussed inSection 5.3.7 - Monitoring Well Installation. The other deepborings without monitoring wells will be drilled by the use ofhollow stem auger drilling equipment in the same manner as theboreholes for the monitoring wells. In each type of boring,soil samples for detecting soil contamination will be collectedat:

o Ground surface to two inches of depth (Section5.3.5.1);

o Two inches to 24 inches of depth (Section 5.3.5.2);

o 24 inches to 48 inches of depth (Section 5.3.5.2);

o Approximately the water table;

74sisib C00871

o Approximately two feet below the water table; and

o Approximately two feet below grade and at the watertable (colocated samples will be obtained from shallowwells at clusters MW-18(s) and MW-24(s)>.

Soil samples will be collected by a three inch diametersplit-spoon and analyzed for all TCL parameters, PetroleumHydrocarbons and selected samples will be analyzed for CEC,metal speciation (Cr and As), TCLP and TOC.

5.3.6 Hydroaeologic Program

The purpose of the hydrogeologic program is to collect geologicand hydrologic data at the Site that will help to define thestratigraphy and groundwater regime and to evaluate contaminanttransport and the need for remediation and possible remedialalternatives. Contaminants, if detected in the groundwater, areexpected to be found in the shallow unconfined aquifer due topresence of a shallow confining layer at the Site. Therefore,the vertical extent of potential groundwater contamination isnot believed to be an important consideration, and the verticalextent of the hydrogeologic investigation can be restricted tothe unconfined aquifer and the unsaturated zone above it(although one deep well and four sets of well clusters will beinstalled to verify this assumption). The Hydrogeologic Programwill be comprised of determining water table gradients,characterizing Site soils, monitoring tidal effects on the watertable, and collecting other pertinent hydrogeologic data. Asummation of this program is presented below.

A water table contour map of the Site would provide informationnecessary to determine groundwater flow direction in theunconfined aquifer. Groundwater flow direction, in turn, isnecessary to properly locate the proposed groundwater monitoringwells discussed in Section 5.3.7 Monitoring Well Installation.The proposed monitoring wells and the four well clusters need tobe located either downgradient of potential source areas ofcontamination to detect groundwater contamination or upgradientof the Site to test the background quality of the groundwaterflowing into the Site.

Water levels measured from the 17 existing monitoring wells willbe collected, well elevations and locations will be surveyed,and a water table map constructed. Figure 11, shows thelocation of the 17 existing monitoring wells and approximatelocations of the proposed shallow wells, the well clusters andthe one proposed deep well. The approximate locations of theproposed shallow wells of the four well clusters are based onthe assumption that the water table is probably a subduedversion of the ground surface (topography) and on a preliminarywater table contour map prepared by the REM II Contractor.Further justification of the number and location of the proposedwells is presented in Section 5.3.8 Groundwater Sampling.

758151b

000372

Soil removed from the boreholes during drilling of the proposedmonitoring wells, the well clusters, the one deep well and thefour deep borings will be geologically logged by the Sitegeologist. Recorded geological data will include approximategrain size classification (e.g., silty sand, sandy clay, finesand, etc.), color, and other characteristics useful forcorrelating soil layers between boreholes. Soil samples will becollected by the split spoon method during the drillingprocess. Split-spoon sampling will be continuous to two feetbelow the water table and then at five foot intervals until theclay layer is encountered. At well cluster locations, where twowells are drilled, the deep well should be drilled first. Theshallow well may be sampled at five feet intervals over thelength of the boring. Soils from the shallow well shall besampled at five feet intervals over the length of the boring.Selected representative samples will be sent to a CLP laboratoryfor grain size analysis, bulk density, and moisture content.Atterberg limits will be determined for cohesive (silt or clay)soils. (In the deep well, no soil samples for laboratoryanalyses will be taken). These samples will help characterizethe geologic stratigraphy at the Site and provide an estimate ofhydraulic conductivity. These samples are also a part of thesampling program performed to detect contaminants in Site soilsas discussed in Section 5.3.5.3 Deep Soil Borings. The samplingwill be done by split spoon penetration method and the number ofblows required to take samples will be recorded to provideinformation about soil compaction. These data and data from thedrilling logs of existing wells will be used to constructstratigraphic cross sections (profiles) of the Site.

If contaminant testing of groundwater (see Section 5.3.8) showsthat groundwater is contaminated at levels above ARARs, aquiferpumping tests may be performed (optional task) on two monitoringwells. These pumping tests would be performed to developinformation on aquifer transmissivity needed to design andimplement groundwater pumping and treatment alternatives whichmay be considered. The tests will be designed to includesurrounding wells as observation wells, if possible, or twopiezometers will be installed near each well to be pumped.

5.3.7 Groundwater Monitoring Well Installation

Eight shallow, four well clusters, and one deep groundwatermonitoring well are proposed to supplement the 17 existingmonitoring wells. Each proposed well will be a separateinstallation. The wells will be installed in boreholes drilledby the hollow-stem auger method or air rotary in slag/fill areas(MW-19) if the auger method meets with refusal. Anotherpotential problem at the Site typical of unconsolidated sanddeposits is heaving conditions. Heaving sands which havepreviously been encountered at the Site may require the use ofcable tool drilling or mud rotary to maintain hole stability.

Boreholes are expected to penetrate the top of the clay layer atthe base of the Magothy Formation, at a depth of about 30 feetfrom the surface (see Figure 3). Drilling to the clay layer

768151b

000873

will accomplish two objectives. First, the level of the clay isan excellent marker bed for correlation of stratigraphy, andsecond the presence of the layer confirms the lateral continuityof the clay layer which is an important aquitard separating theunconfined aquifer from lower aquifers. Care will be taken toprevent complete penetration of this layer since penetrationthrough the layer could provide inter-aquifer communication. Inthe deep well, the boring will penetrate into the firstunderlying aquifer, or to a depth of 120 feet, whichever is less.

Each shallow well will have a 15 foot screen extending fromapproximately five feet above the water table as encounteredduring the boring process to 10 feet below it. This will helpensure that "floating" contaminants such as oil, could besampled within the wells. Figure 12 shows the generalconfiguration of the shallow monitoring wells to be installed.The well clusters will be comprised of a deeper well completedto sample the base of the upper aquifer. The screen for thisdeeper well will be 10 feet in length extending from the claylayer, to 10 feet above it. These will be constructed using thesame specification as shallow wells, except for the depth andlength of the well screen. Shallow well drilling will followthe same procedure specified for the other on-site shallowwells. Shallow wells for each cluster will be located nearbythe deep well.

The proposed program includes two new well clusters (MW-18 andMW-24 for total of four wells) and two deep wells added toexisting shallow wells to form two other well clusters (MW-5dand MW-8d).

In the one deep well, the screen will be ten feet in length,completed in the sand aquifer or at the bottom of the boring ifno clay is encountered. The deep well will be constructed usingdouble easing to minimize the possibility of cross contaminationof the aquifer in accordance with NJDEP requirements. Materialsto be used in well construction will include:

o Four inch stainless steel, wire-wound screen, 10 or 15ft in length, having a 0.20-inch-slot openings (withan appropriate slot size to retain about 90 percent ofthe filter pack) and flush-joint threads, and a fourinch Schedule 304 stainless-steel riser pipe;

o Graded, clean sand filter pack designed to retain roostof the formation material;

o Bentonite pellet seal;

o Bentonite-cement grout backfill; and

o Eight inch diameter security casing with locking cap.

77B151b

000874

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TYPICAL GROUNDWATERMONITORING

WELL CONSTRUCTION


The wells will be installed in accordance with the followinggeneral procedure (which may be modified by the Site geologistto accomodate field conditions):

(1) The Site geologist will determine monitoring well depthbased on the geologic log and depth of the clay layer atbase of the Magothy Formation. The wells will have a 15feet screen extending from approximately five feet abovethe water table to ten feet below it (Figure 12).

(2) The borehole will be drilled with a hollow-stem auger,cable tool, or air or mud rotary methods depending onconditions of the formation. The hollow-stem auger will beeight inches in diameter, whereas the other drillingmethods will use ten inch casing.

(3) The borehole will be backfilled from the bottom of theboring to five ft below the bottom of the well screen withbentonite-cement grout. From the top of the grout to twofeet below the well screen a bentonite seal will beplaced. In the deeper cluster wells, the grout andbentonite will not be required.

(4) The well screen will be installed two feet above thebentonite seal and have about ten feet below the watertable and five feet above it. (In the deep well the screenwill be 10 feet in length). Schedule 304 stainless steelriser pipe will be installed above the screen to reachapproximately two feet above the ground surface. (In thedeep cluster wells, the grout and bentonite will not berequired.)

(5) The annular space will be backfilled from the top of thelower bentonite seal to two feet above the top of thescreen with clean, sand filter pack. A bentonite sealthree feet thick will be placed on top of the filter pack,and the remainder of the annular space will be backfilledwith bentonite-cement grout.

(6) A steel security casing with locking steel cap will beinstalled in the top of each well. The cap will be locked.

(7) A three to four foot-diameter cement pad will beconstructed around the security casing and mounded in sucha way to direct surface runoff from the casing.

The monitoring well installation will not be considered completeuntil each well is properly developed. Hell development isintended to clear the well screen and filter pack of finematerial which may clog the screen, and to stabilize theformation material immediately surrounding the filter pack. Thewells will be developed by pumping and surging. Surging may be

788151b

000876

accomplished by periodically pumping, or with a surge block.This will help to avoid bridging of the formation materials andwill permit a more uniform flow through the well screen.

Each well will be developed to the satisfaction of the Sitegeologist who will monitor pumping rates, water color andturbidity, pH, and conductivity to determine the effectivenessof the development. Following installation of the proposedwells, the well elevations and locations will be surveyed.

The stage of the Delaware River at the Roebling Steel Site isinfluenced by tidal fluctuations. This rise and fall of theriver is believed to impact the water table elevation near theriver bank, but the distance beyond the river bank of the tidalinfluence is unknown. A minimum of two electronic water levelrecorders will be installed in monitoring wells that are closeto the Delaware River to record daily fluctuations in the watertable. The decision for choosing the wells for recorders shouldbe based on coarseness of soil grain size at levels in the wellsnear the water table, proximity to the river, as well as ease ininstallation. The recorders should remain in the wells for avariety of high and low tidal levels for a period ofapproximately two weeks. Additional recorders may be necessaryto determine the total distance from the river that groundwateris significantly influenced by tidal fluctuations.

More recorders may be necessary if initial water levelmeasurements suggest that there are water table fluctuations dueto aquifer pumping in surrounding areas. [Note: Large scalegroundwater pumping is reportedly occurring approximately 1.8miles west of the Site.]

5.3.8 Groundwater Sampling

Following the development of proposed groundwater monitoringwells, the water level will be measured and the well locationand elevation surveyed. These additional water level data willbe conducted concurrently with water level measurements ofexisting monitoring wells to construct an updated Site watertable contour map.

5.3.8.1 On-Site Groundwater Sampling

The purpose of the groundwater sampling program is to determinewhether contamination from the overlying soil has reached theunconfined aquifer and to determine the extent of anycontaminant plume(s). The contaminants of concern, whenreaching the water table, are expected to flow with thegroundwater in the unconfined aquifer. Hence, the well screensfor the shallow wells are installed only in the upper ten feetof the aquifer to allow sampling of the upper portions of thegroundwater regime (see Section 5.3.7, for well installationdetails).

?9 000877

The groundwater monitoring program at the Site, as previouslyconducted by the REM II Contractor, sampled one round ofgroundwater from the 17 existing groundwater monitoring wellsshown in Figure 6. Two sampling rounds were proposed. Theresults from the first round of sampling indicated thatconcentrations of the contaminants tested were generally low ornot detected. Installation of an additional eight monitoringwells (location unspecified) was proposed for the second roundof sampling to fill in data gaps.

Ebasco agrees that additional monitoring wells are needed forthe second round of sampling to adequately assess groundwater atthe Site, but, as requested by EPA and NJDEP, proposes fifteenadditional wells including well clusters instead of eight.Additionally, Ebasco is proposing that the REM III monitoringwell sampling program consist of two additional sampling roundsto ensure comparability in sampling data. Locations of theproposed wells are shown on Figure 11. The proposed shallowwells and well clusters are designed to detect contamination inareas immediately adjacent to or downgradient of known orsuspected contaminant source areas. One is the deeper aquifer.The other two monitoring wells and well clusters are designed totest the background quality of the groundwater in an area bothupgradient of the Site and influenced by tidal fluctuations.The following is a list of the proposed monitoring wells for thedetection of contaminants and the potential source areas theywill monitor:

o MWD-1 - To evaluate the deeper aquifer below the Site.

o MW-18 (s and d - well cluster) An area of potentialcontaminants such as volatile organic compounds andmetals

o MW-19 - Located on the river side (downgradient) of aslag/fill area,

o MW-20 - Downgradient of one of the landfill areas,

o MW-21 - Downgradient of the baghouse dust pile,

o MW-22 - Between existing tanks and a residential area,

o MW-23 - Located near the trailer rehabitation area, apotential source of volatile organic compounds, and

o MW-24 (s and d - well cluster) and 25 - River-side(downgradient) of the sludge lagoons (two lagoons).

The other two wells will measure background (off-site) waterquality and are:

o MW-26 - An area up-gradient of the Site,

808151b

: 000878

o MW-27 - Located in the area influenced by tidalfluctuations.

New wells MW-5d and MW-8d will be installed near the location ofthe existing wells to form new well clusters. The locations ofthe proposed monitoring wells (all except MW-22 and MW-27) relyon groundwater flow direction (either downgradient orupgradient). However, what is known about groundwater flowdirection is based on preliminary data and is not definitive.Therefore, before the proposed wells can be properly located, awater table contour map is required for the Site. To constructthe water table map, water levels will be measured in theexisting 17 groundwater monitoring wells, and the wells will besurveyed for location and elevation (see Section 5.3.4). Thelocations of the proposed groundwater monitoring wells shown onFigure 11, are tentative locations based on the assumption thatthe water table resembles the togography at the Site. That is,the net groundwater flow direction is generally from the southor west and enters the Delaware River by flowing north andnorthwest across the Site. However, heavy groundwater pumpingfor municipal supplies to the south may alter what is expectedto be the net groundwater flow direction.

Groundwater samples from the shallow wells collected during thesecond round of sampling (which includes samples from theproposed monitoring wells in addition to the existing 17 wells)will be tested for compounds in the EPA Target Compound List(TCL), total organic carbon (TOO), and total dissolved solids(TDS). Both filtered and non-filtered water samples from eachshallow well will be tested for metals to determine whethercontaminants are associated with sediments in the water. Thesamples are tested for the wide range of compounds in the TCLbecause the potential compounds associated with Sitecontamination are not known. Samples are tested for totalorganic carbon (TOC) because of the affinity of some organiccompounds for organic carbon. The total dissolved solids (TDS)analysis provides indications of the metals and other dissolvedmaterials in the water that are from off-site sources (somenaturally occurring and some not) and from potential on-sitecontaminant sources. The TDS also is helpful for groundwatertreatment alternative evaluation in the Feasibility Study.Other useful parameters, which will be tested in the field, arespecific conductance, DO, pH, and temperature. These parameterswill be measured as the samples are collected. Samples from thedeep wells will not be filtered and will be tested for the TCLcompounds only.

aisib 81 000879

Wells will be sampled no sooner than two weeks afterdevelopment, thus allowing the wells to stabilize. Three tofive well volumes will be purged from each well prior tosampling. During the well purging operation, pH, specificconductance, and temperature will be measured at the start ofthe purging operations and at the end of each purged wellvolume. Stabilization of these parameters from successivepurged volumes will indicate that the groundwater within thewell is at equilibrium with the aquifer background conditions.The purge water from all the wells will be containerized at thewell head, then stored prior to disposal as directed by theEPA. Wells will be purged with a teflon/ stainless steelsubmersible pump or bailer. Pumps will be decontaminated beforereusing in subsequent wells. Samples will be obtained with astainless steel or a teflon bailer.

5.3.8.2 Off-site Groundwater Sampling (Tap Sampling)

Based on the results of a survey to be conducted to locatenearby groundwater wells, groundwater samples will be collectedfrom up to five separate existing off-site wells. The purposeis to evaluate any transport of contamination off-site. Thewells sampled will be selected on the basis of their locationdowngradient from the Site, if possible, and the aquifer theypump. Off-site samples from wells pumping the unconfinedaquifer are most useful. Information about the well depth,interval screened, and any other pertinent informationconcerning the well will be collected. Only wells within 0.25miles of the Site (if any) will be included in the samplingprogram. Chemical analyses of the groundwater from tap sampleswill be the same as for the groundwater samples collected frommonitoring wells on-site, TCL, TOC, and TDS).

5.3.9 Surface Water Sampling

The REM II Contractor has completed this element of the RI/FS.Ebasco will review and evaluate the data collected and assessthe need for any additional data during the conduct of Task 5.

5.3.10 Sediment Sampling

The REM II Contractor has conducted this element of their RI/FSWork Plan for Site evaluation purposes. Ebasco will review andevaluate the data collected and assess the need for anyadditional Site evaluation data during the conduct of Task 5.The proposed assessment of aquatic biota in the vicinity of theSite, will, however, investigate the sediment in transectspositioned across the river.

5.3.11 Air Sampling

As part of the remedial investigation at the Roebling SteelSite, perimeter ambient air sampling will be performed. Thepurpose of this investigation will be to assess the type and

828151b 000880

magnitude of any contaminants migrating from the Site. Thisinformation will form the basis of a risk assessment todetermine if the Site, in its current state, poses significantrisks to the health of nearby populace and to adjacent ecology.The data collected as a result of this investigation will serveas an information base for future remedial work.

The Site history has been reviewed and certain gaseous andparticulate contaminants have been identified.

The particulates of concern are those containing heavy metalsand Petroleum Hydrocarbons. Gaseous contaminants includedvolatile organic compounds. Migration of these contaminantsoff-site to adjacent residential areas to the south andsouthwest, and to the aquatic ecological area to the north(Delaware River) and east (Crafts Creek) is suspected. In orderto determine if this migration exists, the following contaminantmonitoring plan is proposed.

Sampling for particulates and organic vapors will be performedfrom four fixed stations positioned at property line locationsas shown in Figure 13.

The rationale for each station is presented below;

Station 1 -

Station 2 -

Stations 3 -and 4

Station 5 -

To assess transport of Site airborne contaminantstoward the residential area between Riverside andHornberger Avenues, as well as the playgroundadjacent to Riverside Avenue,

To assess airborne contaminant transport towardthe playground and residential area south of theSite and south of the Conrail Railroad Tracks,

To assess impacts of potential airbornecontaminants on the aquatic ecology of CraftsCreek and the Delaware River which border the Siteto the north and east, and

To assess the impacts of potential airbornecontaminants on the playground and park areasadjacent to the western Site boundary.

The locations of the monitors were selectedparticulate transport as a result of theconditions that are likely to occur during thefield investigations.

to best assessmeteorologicalconduct of the

Particulates will be collected over a 24-hour sampling period,while organics will be collected for 8-hours. Station 2, shownin Figure 13, will have a co-located particulate sampler forquality assurance purposes as specified in USEPA monitoringguidance.

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Sampling for particulates containing heavy metals and petroleumhydrocarbons will be accomplished using Staples totalparticulate samplers. These units draw samples at volumes to1.7 cubic meters per minute (60 cubic feet per minute) onto 8 by10 inch glass fiber filters. These Staplez units are notsize-selective and all particulate sizes are collected.

Sampling for organic vapors will be performed with SKC portablefield pumps that draw flow to 5 liters per minute (0.18 cubicfeet per minute) with quad manifolds and sorbent traps forvolatile compound collection. Tenaz and charcoal are proposedas the sorbent media. When used in tandem, these sorbents arethe best at capturing those compounds considered "heavy" (lowvapor pressures) while charcoal is best for the "lighter"compounds (those with higher vapor pressures). A sample volumeof 20 liters is proposed over the eight hour sampling day.

Concurrent with the air sampling program, meteorological datawill be collected continuously onsite using a portablemeteorological station. Meteorological parameters to becollected include:

o Wind Speed - to indicate the degree of dust suspension,o Wind Direction - to indicate transport,o Precipitation - to assess soil moisture conditions,o Stability - to indicate on-site stability for

dispersion of contaminants, ando Barometric - to indicate corrections of flow rates to

Pressure Standard temperatures and pressure.

Meteorological data will be compiled on sampling days andcorrelated with particulate sampling results. The location ofthe meteorological station and rain gauge will be determinedupon review of the final Site layout.

The air monitoring program at the Roebling Steel Site isproposed to commence during late spring or early summer of1989. The colder termperature, rain and snow cover that wouldlikely occur during late fall and winter could suppress dustsuspension and volatilization of organic compounds. Under theseconditions, it is ununlikely that any particulates (fugitivedust) would be observed.

5.3.12 Source Sampling

As discussed in Section 2.7.1, there are many sources andpotential sources of contamination which have been identified atthe Roebling Steel Site. Each of these potential sources willbe chemically characterized to assess the actual or potentialthreat to human health and the environment, determine the extentof contamination (if any exists) and provide data needs to

000883848151b

support the evaluation of remedial alternatives. Six potentialcontamination sources will be investigated in a FocusedFeasibility Study. These sources are:

o Transformers;

o Tanker cars;

o Chemical piles;

o Compressed gas cyclinders;

o Baghouse dust piles; and

o On-site tank farm.

Task 20 (Section 6.6) details the investigation of these sixsources. The investigation of the on-site other potentialcontamination sources is identified below. Proposed source areasampling locations are shown in Figure 14.

5.3.12.1 Building Sampling-••""„.'•''

Four wipe samples (one per wall) will be collected from each ofthe fifty-five existing on-site buildings for a total oftwo-hundred-twenty samples. In addition to the wipe samples,fifty-eight floor dust samples will be collected from 22buildings. The exact sampling locations will be determined inthe field by the Field Operations Leader based on visual searchfor stains or other indications of potential contamination onthe walls and floors.

Additional potential sources of contamination inside thebuildings including sumps/pits and basements will also beinvestigated. Thirty water and twenty-six sludge/sedimentsamples will be collected from the sumps/pits. Thirteen waterand eleven sludge/sediment samples will be collected from thebasement areas, and sixteen and fifteen residue/wastes sampleswill be collected from waste piles and equipment, respectively.

Details of sample acquisition will be presented in the FSAP.

5.3.12.2 Railroad Car Sampling

All existing railroad cars (fifty-two were identified duringprevious investigations) will be sampled. Cars will beinspected and waste material found within them will be sampled.Cars containing no waste material will be characterized bycollecting wipe samples from the inside walls. Existing dataindicate that twenty-five cars contain slag, nine containfly/bottom ash, four contain debris/trash, two contain drysludge and twelve are empty. If during the investigations it isdetermined that the number of cars is different from the

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PROPOSED CONTAMINATION SOURCESAMPLING LOCATIONS

EIAICO fEHVICEl INCORPORATEDSOURCE: we«TON WORK PLAM

existing information, the number of samples will beincreased/decreased accordingly. It is assumed that forty wastesamples and twelve wipe samples will be collected from the cars.


5.3.12.3 Tank Sampling

One-hundred-six samples will be collected from the existingtanks (existing data from the REM II Contractor indicates thatthere are 106 tanks distributed as follows: 59 containingunknown waste; 27 containing oil; 10 empty; 10 containingprobably water; and 2 containing chemical powders). If thematerial contained within these tanks are found to be inseparated phases then each phase will be sampled. Empty tankswill be characterized by collecting wipe samples from the insidewalls. The tanks are located inside (67) and outside (39) thebuildings.

Details of wipe sample acquisition will be presented in the FSAP.

5.3.12.4 Pipe Insulation Sampling

An estimated two-hundred pipe insulation material samples willbe collected throughout the Site. This insulation material hasbeen observed in overhead pipes inside and outside the buildingsand in some areas it has deteriorated and fallen from thepipes. This insulation material appears to be asbestos.Separated insulation material will be sampled in the field forasbestos containing material. Sampling locations will beselected in the field based on accessibility and healthconsiderations.

Details of the pipe insulation material sample acquisition willbe presented in the FSAP.

5.3.12.5 Sludge Lagoon Sampling

Twelve sludge samples will be collected from the two existingsludge lagoons situated within the wastewater treatment plant.Location of the sludge lagoons is shown in Figure 2. From eachlagoon, six samples will be collected at three differentlocations within each lagoon, at two different depths. At eachlocation the first sample will be collected from the upper twofeet and the second sample will be collected at a depth justbelow the sludge/native soil contact zone. If fieldobservations indicate that contaminants may have migrated beyondthe contact zone, then additional samples would be takendeeper. Sampling locations will be selected based on safetyconsiderations (i.e., stability of lagoon surfaces).

Details of sludge lagoon sample acquisition will be presented inthe FSAP.

ee : 0008868151b

5.3.12.6 Slag Pile and Slag Sampling

Five slag pile samples will be collected from the two slag pileslocated on the north-east part of the Site a few feet away fromthe river bank. Sampling locations will be selected in thefield.

Slag

Additionally, slag samples were obtained from the western mostportion of the Site which abuts the Delaware River. Thissampling consisted of laying out a 200' z 200* grid over theapproximate 20 acre area (i.e., about 20 grids), taking fourgrab samples from each grid and compositing each grid sample.Composite samples will be analyzed for TCL metals andextractables.

Details of slag pile sample acquisition will be presented in theFSAP.

5.3.12.7 Landfill Sampling

Twenty samples will be collected from the suspected landfillarea. Ten test pits or trenches will be excavated to a depth of5 feet across the landfill area and two samples will be obtainedfrom each pit. If buried drums are encountered the operationswill halt until the drums are removed and the content of thedrums identified. Personnel monitoring equipment will be usedto screen the content of the drums. During these activitiesstrict adherancy to the health and safety protocols will be inforce. A backhoe is proposed for completion of the test pits.

Details of landfill sample acquisition will be presented in theFSAP.

5.3.12.8 Settling/Flocculation Tank Sampling

Six water and six sludge samples will be collected from theexisting settling/flocculation tanks of the wastewater treatmentplant. There are three settling and three flocculation tanks.From each tank two water and two sludge samples will beobtained. In addition, two samples will be collected from twotanks located inside the wastewater control building. These twotanks, a chemical feed and a mixer tank, were observed tocontain solid material (potentially solid waste from thechemical precipitation system). These tanks were all part ofthe wastewater treatment system.


00088787

8151b

5.3.12.9 Waste Disposal

All contaminated material generated during the fieldinvestigation including decontamination solutions, disposableequipment and clothing, soil cuttings, well development fluids,etc., will be containerized and stored on-site until finaldisposition is approved by EPA.

5.3.13 Environmental Sampling and Analysis

5.3.13.1 Aquatic Ecology

As previously noted, the Delaware River to the north and CraftsCreek to the east form the boundaries of the Roebling SteelSite. The Delaware River serves as a water source for thecities of Philadelphia, Pennsylvania and Burlington, New Jersey,in addition to being used as a recreational facility forresidents on both sides of the river. If contaminants were toenter the Delaware River watershed, they would pose potentialthreats to public health and the environment.

Public health could be impacted most directly via water qualitydeterioration and subsequent uptake by the downstream watersupply systems. The most significant effects on aquaticorganisms could occur during Site remediation activities. Inaddition, the potential impacts of remedial action will befocused on the adult shortnose sturgeon (Acipenser brevirostrum)an endangered species known to inhabit this secion of theriver. Shortnose sturgeon are most abundant in shallow water(2-10 m) during summer months. Therefore, by restrictingremediation activities to other seasons when shortnose sturgeonare less abundant will reduce the potential for adverse effectson the species. As a precaution, however, the National MarineFisheries Service and/or the Fish and Wildlife Service will becontacted for additional information on potential impacts of theproposed remedial activities. By scheduling remediationactivities to avoid critical life history phases (e.g., avoidingremediation during the early spring during spawning), it isbelieved that potential impacts can be minimized.

The endangered raptors found in the area, the bald eagle(Halialetus leucocephalus) and the American peregrine falcon(Falco pereorinus anatum). are also quite mobile, and areanticipated to avoid the area of remedial activities. However,because contamination via food may be of concern, the Fish andWildlife Service will be also contacted about any proposedremediation to confirm that these activities will not havenegative effects on these species.

In summation, no significant negative effects on endangeredspecies are anticipated from remedial actions at the RoeblingSteel Site and proper scheduling of remediation may totallynegate any potential effects. However appropriate agencies will

i00088888

8151b

be consulted to confirm this and ensure compliance with theEndangered Species Act. A net benefit can be expected fromremedial action, because toxic compounds will be removed fromthe environment of these endangered species.

Potential Contaminant Pathways

Contaminants may enter Crafts Creek and the Delaware River viaseveral pathways. Contaminated soils may be transported bysurface runoff and reach the Delaware River via overland flowand/or the six storm sewer outlets present at the Site.Contaminated groundwater may also discharge into the river.Fugitive dust (e.g., surface soil and baghouse dust) may beblown off-site by the wind and enter the river system. Slag wasreportedly used as fill on a large portion of the river-frontarea. If toxic metals are present in the slag, they couldpotentially leach into the river and groundwater systems. Thereis another slag disposal pile located along the northwest edgeof the Site. Additional risks of hazardous chemicals enteringthe Delawate River system as contaminated leachate may resultfrom the proximity of the two sludge lagoons (where lead,cadmium, and volatile organics were detected) in the northeastarea of the Site. There is also an oil tank trailer, in whichtrace levels of PCBs were detected, located about 100 yards fromthe river.

o River Sediments

Sediment sampled by the REN II Contractor in 1987 displayedelevated levels of several contaminants. Organic contaminationwas limited to base neutrals; primarily polynuclear hydrocarbons(e.g., fluoranthene, chrysene) detected at up to 6800 parts perbillion (ppb) and phthalates (e.g., bis(2-ethylhexyl)pthalateand butylbenzylphthalate) in concentrations up to 7300 ppb.Inorganic compounds detected at concentrations substantiallyabove normal background levels included lead (up to 10,800 partsper million (ppm)), zinc (up to 4060 ppm), chromium (up to 87ppm) and cadmium (up to 22 ppm) . To further investigate thepossibility of these contaminants migrating from the Site andpotentially effecting the aquatic ecology, as well as to definethe extent of contamination, additional sampling of riversediments is necessary.

Sediment core samples will be collected from locations adjacentto and as well as up-and downstream of the Site on the DelawareRiver and Crafts Creek. The main channel of the river hasundergone past dredging activities which may have releasedcontaminated sediments. Thus no samples will be obtained fromthis area. However, a long stretch of the river runs adjacentto the northeastern Site boundary and it is believed thisstretch is not dredged. Sediment sampling along these twostretches of the river will consist of two types of sampling toaccount for the dredging activity:

1. Nearshore and far shoreline sampling for the segmentsof the main channel which are actively dredged; and

89000889

2. Transect sampling in the segments not dredged.

Nearshore and farshore sediment core samples in the main channelof the river will be taken from 22 locations to obtaininformation on the amount and distribution of potentialcontaminants across the river. By using a piston corer orsimilar device to collect sediments, a preliminary verticalprofile of contamination in these sediments can be obtained bysampling at one or more intervals (depending on corerpenetration and compression of substrate) along the length ofthe core. Sediment core samples will be obtained from 11locations, having both nearshore and farshore sampling stations:

o Two locations at the Site boundary (see Figure 15),

o One location at the approximate mid-point of the Siteboundary,

o Two upstream locations at one and two tidal excursionsupstream of the Site; and

o At six locations downstream of the Site, two each atintervals of less than 1, 1 and 2 tidal excursions.

River sediment will also be sampled in the vicinity of the sixstorm drain outfalls (located along the branch of the river) tomonitor possible depositional areas. In order to obtain morerepresentative data regarding potential contaminant distributionacross the river, piston core sediment samples will also becollected at the opposite shore, as well as at the mid-point ofthe transverse section (Figure 15). This transect samplingdesign will also be used in collecting sediment from an upstreamlocation on the branch of the river 200 m from the Site boundarynear the existing Penn Central Railroad tracks. Sedimentdredging from the river's shipping channel most likely requiresanalysis of the sediment being dredged and since the river willbe dredged in the fall of 1988, Ebasco will inquire into theavailability of these data.

Four piston core sediment samples will also be collected inCrafts Creek. Crafts Creek is of particular interest because awetland is located on the eastern shore. Two storm outfalls atthe eastern Site boundary above Crafts Creek will also beinvestigated by nearshore core sampling. All river sedimentsand increments within corer will be analyzed for TCLextractables and metal compounds and TOC. Grain size will alsobe analyzed for selected sediment samples.

o River Surface Water

Surface water sampling has been performed by the REM IIContractor in 1987. One sample, taken near one of the stormdrains, detected 480 ug/1 of lead (the Maximum Contaminant Level- MCL - for lead is 50 ug/1). Zinc was also present at elevatedlevels. Since the Delaware River serves as a water source for

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WDHNENT SAMPLMO LOCATIONSSURFACE WATER SANVLINQ LOCATIONSSEDNMENT AND SURFACE WATER LOCATIONSNEAR THE BURLINGTON CITY (NJ)ANDPHILADELPHIA CITY PA) SURFACE WATERSUPPLY INLET NOT SHOWN(LOCATIONS NOT TO SCALE!

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U.S. ENVIRONMENTAL PROTECTIONAGENCY

ROEBLINQ STEEL SITEFIGURE 15

PROPOSED SEDIMENT ANDSURFACE WATER SAMPLING

LOCATIONSEBASCO SERVICES INCORPORATED

the cities of Philadelphia, Pennsylvania and Burlington, NewJersey; as well as a recreational resource for local residents,additional surface water from the river will be sampled toconfirm the presence of contamination. Surface water will becollected (as possible) at each outfall to investigate if Siterun-off is a river water source of contamination. Surface waterwill also be collected at Crafts Creek and the upstreamlocations where sediments will be sampled. In addition, riverwater will be collected at mid-point of the Site boundary (seeFigure 15), at 1 km downstream of the Site, and at the point ofintake for the downstream water supplies. The water sampleswill be analyzed for^TCL compounds. Table 14 summarizes thesediment sampling program.

o Additional Information

Because there has been dredging activity in the shipping channelof the Delaware River, past bioassay data on acute tozicity ofthe river sediment may already exist. A literature search willbe conducted to collect information on these past bioassaydata. If data are not available and chemical analyses of riversediment indicate substantial areas of elevated contaminantconcentrations, then several additional steps may (optional) bewarranted:

o If results of the chemical analyses of the riversediments indicate the presence of contaminants withsubstantial risks of bioaccumulation andbiomagnification in the food chain (e.g., PCBs andmercury) then additional biota sampling will beconducted. Actual contaminant concentrations inselected samples of fish tissue will be measured.

o If necessary (e.g., if dredging is required)bioaccumulation tests can also be performed. Forexample, solid phase bioassay benthic infauna will becollected or sediments obtained from "hot spot" areas.

o Wetland Delineation. Inventory, and Assessment

A wetland exists to the east of Crafts Creek. Wetlands providemany functions in an ecosystem including serving as a nurseryand spawning ground, nutrient removal and transformation,sediment stabilization, groundwater discharge and recharge, andfloodflow alteration. In order to determine the potentialimpacts of contamination and remedial action at the RoeblingSteel Site, a wetland assessment of the Site and adjacent areawill be conducted.

The information collected as part of the assessment will includeidentification of wetland boundaries utilizing the NationalWetland Inventory Naps and EPA's three parameter methodology(Sipple 1987), and an inventory of floral composition of thevarious types identified. Additional information necessary to

918151b

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TABLE 14

PROPOSED (ECOLOGICAL) RIVER SEDIMENT SAMPLING PROGRAM

NUMBER/LOCATION

I. DELAWARE RIVER BRANCH

NUMBER OF SAMPLES

4/Storm Drain Outfalls1/1-2 tidal excursions upstream of Site

(east of storm drain outfall)2/Storm drain outfalls -

(nearshore core samples-Eastern boundary)

24 (3 per location)6

II. MAIN CHANNEL DELAWARE RIVER

3/Core samples withinSite boundary

2/0-1 tidal excursions upstream2/1-2 tidal excursions upstream0-1 tidal excursions downstream1-2 tidal excustions downstream

(2)(2)(2)(2)

12

441212

III. CRAFTS CREEK

4/Crafts Creek

Total 86

Assuming two samples from each core.Nearshore and farshore samples for each location.

928151b

: 0 0 0 8 9

complete the wetland assessment will be obtained from othercomponents of Section 5.3.13 (Environmental Sampling andAnalysis). The River Sediments effort includes stations locatedin parts of the marsh associated with Crafts Creek. This willprovide . an indication whether potentially site-relatedcontaminants occur at elevated concentrations in wetlandcommunities. The River Inventory and Assessment effort willprovide information relating to utilization of wetlands by fishand other aquatic species; and the Terrestrial Ecology effort,will provide information relating to utilization by wildlife.

Data will be evaluated to: 1) determine the likelihood thatelevated concentrations of substances of concern occur in thesediment or water of the wetland communities; 2) determine, aspossible, the potential for elevated concentrations to affectterrestrial biota; 3) identify important ecological or societalfunctions that these wetlands may be performing (using the ACOEor Wetland Evaluation Technique (WET) program); and 4) determinethe need for additional analyses.

Simultaneously, an ecological inventory and wetland evaluationwill be done using the WET developed by the U.S. Army Corps ofEngineers (Oct 1987).

o River Inventory and Assessment

The Delaware River in the vicinity of the Roebling Steel Sitewill be examined to help determine whether contamination orremedial action would have adverse ecological effects on thisecosystem. A literature search of plants and animals found inthe area will be done to provide an assessment of organisms thatmay be at risk from toxic compounds present or released fromproposed remedial action.

5.3.13.2 Ecological Surveys

Seasonal use of the Site and environs may change dramaticallythroughout the year. Consequently, survey efforts forparticular species groups must be keyed to periods of peakabundance/ activity. Surveys should be conducted in the winterand late spring seasons.

The surveys will comprise two components: a reconaissance andcharacterization of site and off-site habitat; an observation ofsite and off-site occurrence of waterfowl and wading birds.

o Characterization of Site and Off-Site Habitat

Habitat occuring on-site and in adjacent undeveloped areas willbe mapped from available aerial photography, topographic maps,and field observations. The latter will include severaldominant plant species comprising ground and shrub strata, andevidence of stress from soil removal, drainage alteration andfine or toxic substances. Field operations and information

938151b

• 000894

collected from other sources will be incorporated into aqualitative evaluation of Site use and surrounding area use bywildlife including threatened or endangered species.

o Birds

Birds, particularly waterfowl or wading species, have thegreatest potential to receive and transport pollutants from theSite and adjacent areas.

Breeding birds will be surveyed during the spring breedingseason by walking the site and adjacent wetlands and mapping thelocation of breeding species.

Waterfowl are the principal species of concern at other seasonsof the year. Surveys will be conducted during the migration andwintering periods along the Delaware River shore and CraftsCreek to ascertain current waterfowl use. Data from thesesurveys and aquatic monitoring information will be used toevaluate potential usage of the Site vicinity by shorebirds,wading birds and water birds.

5.3.13.3 Cultural Resources

The key issues for consideration of cultural resources is thepotential impact of the proposed RI/FS activities on andidentification of historic properties (including botharchitectural and archeological properties) on, or nominated to,or potentially eligible for the National Register of HistoricPlaces (NRHP) and the New Jersey State Register of HistoricPlaces.

o Stage IA Survey

In order to establish the cultural resource sensitivity' of theprimary affected area (the Roebling Steel Site) and thesecondary affected area (the area surrounding the Site), a StageIA Literature Search will be conducted pursuant to theCERCLA/SARA Environmental Review Manual (January 1988). Thearea to be investigated will include approximately a one mileradius around the Roebling Steel Site.

Ebasco's cultural resources specialists will conduct a filesearch of: recorded significant and potentially significantproperties within the project area, National Register ofHistoric Places and State Register of Historic Places files atthe State Historic Preservation Office (SHPO) will be searched,as will SHPO files of on-site and nearby properties determinedeligible but not yet nominated to the National and StateRegisters. Architectural inventory files of potentiallysignificant structures will also be checked. At the New JerseyState Museum, Ebasco will search the archeological site filesfor any previously recorded cultural resources within the study

948151b 000895

area. In addition, historic cartographic sources will bechecked at the New Jersey State Library, the Burlington CountyHistorical Society, the New Jersey Historical Society, and theNew York Public Library for potential historic period culturalresources.

Preliminary inquiries to the SHPO have indicated that theRoebling Steel Site is immediately contiguous to the RoeblingHistoric District which consists of a residential and commericalarea where many of the Roebling Steel factory workers resided.Ebasco anticipates that the Roebling Steel Site itself may alsobe potentially eligible for nomination to both the New JerseyState and National Registers of Historic Places (based onpreliminary review of the background materials and conversationswith Terry Karschner, Office of New Jersey Heritage, New JerseyDepartment of Environmental Protection, SHPO). As such,Ebasco's preliminary evaluation is that the Roebling Steel Siteis a potentially significant historic period cultural resourcedue to its socioeconomic relationship with the Roebling HistoricDistrict area and its connection woth the Roebling wiremanufacturing dynasty. An historical architectural study of theextant structures may indicate that the site is also potentiallysignificant on architectural merits.

In addition, Ebasco will use the data collected to evaluate theprehistoric cultural resource sensitivity of the study area.The Site's location along the Delaware River and near atributary stream is typical of many of the Site locationsfavored by prehistoric populations. Ebasco anticipates thatthis area may contain remnants of prehistoric site occupation,though the remains may have become contaminated due to leachingof hazardous materials.

Ebasco will also examine available boring logs from previoussubsurface tests at Reobling and as-built drawings of theRoebling structures and subsurface utility lines, etc., todetermine the degree of ground disturbance which has occurredwithin the project area. This information will help todetermine the project Site's archeological potential for bothprehistoric and historic cultural resources. If extensiveground disturbance can be documented for most of the industrialSite, this will eliminate those areas from further considerationof potential archeological sensitivity. A report will bewritten which will summarize all of the data collected.

Ebasco will discuss the results of the Stage IA survey with theUSEPA to determine if apropriate additional investigation (i.e.,possibly a Stage Ib survey) is required pursuant to the REM IIICERCLA/SARA guidance manual (January 1988).

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5.3.14 Floodplain Assessment

A floodplain assessment for the Roebling Steel Site will beperformed. The assessment will include delineation and mappingof both the 100-year and 500-year floodplains, separatelyidentified, on a 1:24000 scale map of the Roebling Steel Site.Information for this mapping will be obtained from the FederalEmergency Management Agency (FEMA). Floodplains mapping will beconducted during the Remedial Investigation.

During the Feasibility Study the assessment will include adescription of the proposed RI/FS action designated (if any) tooccur within either the 100-year or 500-year floodplains, andthe effects of this action on the floodplains. A delineation ofmeasures to minimize adverse impacts on floodplains will beprovided. These measures will include those as defined in theCERCLA/SARA Environmental Review Manual, January 1988.

5.3.15 Coastal Zone Management Requirements

Section 301(c)(l) or (2) of the Coastal Zone Management Act (16USC 1451(c)(l) of (2)) requires the federal agency promoting afederal project that is in or affects the coastal zone to make aconsistency determination in accordance with the approved statecoastal zone management program. The Roebling Steel Site islocated within New Jersey's designated coastal zone (see SectionX.X.X). New Jersey's Coastal Zone Management Program receivedfederal approval in September 1980 and it identifies the typesof activities permitted in a coastal zone. The Jersey Rules onCoastal Zones and Development at NJAC 7:7E-1 et seg. constitutethe substantive core of this program. An assessment will beperformed during the RI stage to identify the types and kinds ofallowable activities that can be conducted at the Site to insureconsistency with the proposed remediation activity directed forthe Roebling Steel Site Cleanup wll be consistent with theseregulations. Pursuant to the National Oceanic and AtmosphericAdministration regulations at 15 CFR 930.34 that guide federalagency consisting determinations, documentation of positiveconsistency of proposed actions with these regulations will besubmitted to New Jersey.

5.4 TASK 4 - SAMPLE ANALYSES/VALIDATION

5.4.1 Laboratory Procurement

The analysis of all samples will be performed by laboratorieswhich participate in the EPA National Contract LaboratoryProgram (CLP) utilizing CLP analysis protocol. Table 13(Section 5.3.5.1) presents a summary of the planned analyticalprogram. No other laboratories are required for the proposedprogram except for metal speciation and analysis purposes.Because the holding time is short (24 hours), differentarrangements (to be discussed with EPA) may be required.

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Samples will be analyzed for volatile and semivolatile organics,inorganics (metals), pesticides/PCBs, and other parameters suchas TCLP, TOC, engineering properties, asbestos, petroleumhydrocarbons, PCBs, Diozin, soil pH, TDS, TSS, and otherparameters, using approved EPA methods for Superfund Sites.Analysis for organics and inorganics (TCL/TAL) will be conductedby the CLP laboratories using current methodologies, namely,Routine Analytical Services - RAS based on the following:Statement of Work for Organics Analysis Multi-Media,Multi-Concentration - CLP-SOW, Organics, 8-87; and Statement ofWork for Inorganics, Multi-Media Multi-Concentration - CLP-SOWInorganics, 12-87.

Special Analytical Services, SAS, will be performed according tothe CLP-SAS. These analyses include those not covered by theCLP-RAS such as Diozin, TOC/ TCLP, TDS, TSS, PCBs, engineeringproperties (i.e., bulk density, Atterberg limits, grain sizedistribution, RCRA characteristics - waste sources only - andmoisture content).

The DQO for CLP analysis have been selected to be confirmational(DQO Level 4). The DQO for documented field measurements willbe field analysis (DQO Level 2).

Sample management and data validation will be performed byEbasco utilizing the procedures and specifications contained in"Laboratory Data Validation - Function Guidelines for EvaluatingOrganic Analyses," Technical Directive Document No. HQ-8410-01,and "Laboratory Data Validation - Functional Guidelines forEvaluating Inorganic Analyses," Draft Technical Document.

Quality control during sample analyses is described in the EPA'sCLP program. Quality control for all other aspects of the taskare to be in accordance with the REM III Quality AssuranceProgram Plan.

Validation of measurements is a systematic process of reviewinga body of data to provide assurance that the data are adequatefor their intended use. The process includes the followingactivities:

o Auditing measurement system calibration, andcalibration verification;

o Auditing quality control activities;

o Screening data sets for outliers;

o Reviewing data for technical credibility with respectto the sample location;

o Chain-of-Custody review;

o Checking intermediate calculations; and

o Certifying the previous processes.97 ' 000398

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5.4.2 Sample Analysis

Table 13 summarizes the sample analyses to be performed on eachmedia. A brief discussion of these sample analyses is presentedbelow.

5.4.2.1 Soil Samples

Surface and subsurface soil samples will be collected at thesite and analyzed for full Target Compound List/Target AnalyteList (TCL/TAL) and TOC. Approximately 15 percent will beanalyzed for grain size distribution, bulk density, moisturecontent, Atterberg limits, cation exchange capacity, and TOC.All subsurface samples will be analyzed for petroleumhydrocarbons and selected samples will be analyzed for CEC andmetal speciation (Cr+6, Cr+3).

5.4.2.2 Slag Pile/Sludge Lagoon/Landfill Samples

All slag pile/lagoon/landfill samples will be analyzed forTCL/TAL including CN~ and TCLP. Soil samples from the testpits taken from the landfill will be analyzed for TCL/TAL, TCLPand petroleum hydrocarbons. Soil samples from the sludgelagoons will be analyzed for TCL/TAL, TOC and pH. Fifty percentof the lagoon samples will be subject to TCLP test.

5.4.2.3 Building Dust and Wipe Samples

Dust and wipe samples collected from the building floors andwalls will be analyzed for TCL/TAL.

5.4.2.4 Insulation Samples

Insulation material samples will be collected and analyzed forasbestos content.

5.4.2.5 Transformer Oil Samples

Transformer oil samples will be collected and analyzed for PCBs,BTU value, full scale of Dioxins, and and RCRA characteristics.

5.4.2.6 Tank Samples

Tank samples include wipe (from empty tanks) and contentsamples. Wipe samples will be analyzed for TCL/TAL. Tankcontent samples will be analyzed for TCL/TAL and Flash Point.The large on-site oil tank contents will also be analyzed forBTU value and RCRA characteristics.

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5.4.2.7 Residue/(Chemical) Waste Pile Samples

These samples will be collected from existing residue wastepiles inside the buildings and anlayzed for TCL(extractables)/TAL constituents, asbestos content, and RCRAcharacteristics.

5.4.2.8 Pit/Sump/Basement Samples

Samples from the pits and sumps will be analyzed for TCL/TAL andcyanide while samples from the basement will be analyzed forTCL/TAL constituents including CN~ (these samples will includewater and/or sludge/sediment).

5.4.2.9 Baghouse Dust Samples

These samples will be collected from the existing baghouse dustpile west of building 88 (see Figure 2) and be analyzed for TCL.metals constituents, metal speciation (Cr*6, Cr+3) and RCRAcharacteristics.

5.4.2.10 Groundwater Samples

Groundwater samples will be analyzed for TCL/TAL, TOC SASparameters (such as SO,}, N02/N03, acidity, TDS, SS,alkalinity, Cl~, F) and total suspended solids. In addition,pH, Eh, DO, conductivity and temperature will be measuredin-situ during sampling collection.

5.4.2.11 Air Samples

Air samples will be analyzed for TCL metals, petroleumhydrocarbons (samples collected in filters) and volatilecompounds (collected using Tenex tubes).

5.4.2.12 Railroad Car Samples

Railroad car samples will be analyzed for TCL/TAL andapproximately 20 percent for TCLP (slag metal) and wipe samplesfor TCL/TAL.

5.4.2.13 Field Quality Control

The proposed analytical program includes QA/QC samples.Duplicates samples will be collected from each media sampled ata frequency of approximately six percent to evaluate theprecision of the analytical methods used. Field blanks will becollected for each media at a frequency of one field blank perday per matrix (i.e., for each type of equipment used). Fieldblanks are collected to determine if cross-contamination hasoccurred due to the repeated use of the same samplingequipment. Trip blanks will be collected every day prior tocommencing sampling activities and will be placed within thecooler where samples will be stored during the samplingactivities.

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For every sample shipment, one trip blank will be also sent tothe laboratory. Trip blanks are collected and sent with thesamples to assess any cross-contamination during sample shipment.

5.4.3 Documentation Procedures

Samples sent to the CLP will be tracked by Ebasco to ensure thecontinuity and consistency of data and analyses throughout thesampling program. Tracking will include tabulating sampling andshipping dates; analyses performed; holding times; dates ofextraction; dates of analysis; and dates of validation. Thesite manager will be notified if problems develop with thesample analyses.

5.4.4 Data Validation

Data validation is performed by the USEPA Environmental ServiceDivision (BSD), Edison, NJ office. However, Ebasco will providesupport to USEPA-ESD for data validation up to the extent of 100percent of the effort in this task.

5.5 TASK 5 - DATA EVALUATION

This task includes efforts related to the analysis of data onceit has been verified that the data are acceptable. This taskincludes Ebasco's data review, data reduction, summary andevaluation effort.

All data collected will be analyzed to support a detailedevaluation of remedial alternatives. Site specificcharacteristics will be compiled, analyzed and mapped including:

o Comparison, concentration, and physical state ofcontamination;

o Area and volume of contaminated media;

o Soil engineering properties based on Unified SoilClassification System;

o Soil grain size, bulk density, moisture content; andAtterberg limits;

o Soil Chemistry - pH, organic matter content;

o Air contamination data;

o Contaminant profiles;

o Nature and extent of building contamination;

o Groundwater contour maps;

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o Geologic cross-sections; and

o Temperature, specific conductance, pH and TDS.

5.5.1 Data Reduction and Analysis

This task includes the data reduction and evaluation effort.Ebasco will develop the best means to organize, analyze,interpret, and present the data to support the RI and FSincluding:

o Preparation and interpretation of well logs anddefinition of stratigraphy;

o Identification of groundwater flow paths;

o Investigation of the correlation between air quality,soil contamination at the Site and groundwatercontaminant concentrations;

o Preparation of data summaries; and

o Presentation of the field data to develop a picture ofcontaminant distribution at the Site.

These analyses will provide information which will beincorporated in the screening of remedial alternatives and inthe detailed evaluation of remedial alternatives.

5.5.2 Environmental Fate and Transport Assessment

Contaminant concentrations in various media (soil andgroundwater) will be assessed. Computer models may be used tocharacterize contaminants in soil and their interactions withinfiltrating water and groundwater at the Site.

Groundwater, surface water and atmospheric transport will beconsidered as potential pathways for contaminant transport.Relationships between soils, sediments and water will beevaluated and potential contaminant sources, when possible, willbe identified. Computer modeling could be used to determine theextent and consequences of potential contaminant migrationand/or release into the groundwater and surface water.

If groundwater contamination at a level of concern in detected,a two-dimensional groundwater flow and contaminant transportmodel analysis will be utilized to generate appropriate data forsupport of the conceptual design and technical evaluation ofremedial alternatives. The information to be developed usingthe modeling analysis includes:

o Fate and plume migration of contaminants by naturalattenuation (no action);

101 00090?

o Pumping rate, boundary of plume migration andreinjection influence for groundwater gradient control(plume containment);

o Remediation rate (rate of restoration) and remediationlevel (cancer risk level) by pump and treat (activerestoration); and

o Modified performance goals (modifying decision) andcontinued operation (performance evaluation) of theremedial actions.

The models will utilize regional hydrologic data, as well as,site specific data and take into account retardation,adsorption, degradation, and dispersion. Models to be used willbe discussed with EPA prior to implementation.

These analyses will provide information to support the RI and FSand will be incorporated in the screening of remedialalternatives and in the detailed evaluation of remedialalternatives.

5.6 TASK 6.0 - ASSESSMENT OF RISKS

A Public Health Evaluation (PHE) will be conducted to determinethe extent to which contaminants present at the Roebling SteelSite may be released and may subsequently present risks topublic health or the environment. This quantitative assessmentwill evaluate conditions at the Site in the absence of anyfurther remedial actions, i.e., it will constitute an assessmentof the "No-Action" remedial alternative. Evaluation of theNo-Action alternative is required under Section 300.68(f)(v) ofthe National Contingency Plan (NCP). By conducting such anassessment, the Environmental Protection Acgency (EPA) will beable to determine if remedial actions are required for any areasof the Site. In addition, the baseline assessment will alsoprovide a basis for determining the reduction in risk resultingfrom remediation. The baseline assessment will be based on theRI environmental monitoring data and other information developedduring the RI (e.g., data from Phases I and III). The mainsteps in this assessment will be performed in accordance withthe latest EPA policy and guidance on risk assessment in general(EPA I986a,b,c) and for Superfund sites in particular (EPA19B6d).

The PHE will consist of the following five steps:1 Selection of chemicals of concern;

2 Identification of potential exposure pathways;

3 Estimation of concentrations of chemicals at potentialexposure points;

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4 Comparison of projected chemical concentrations toapplicable or relevant and appropriate federal andstate requirements, criteria, and guidelines (ARARs),and if ARARs are not available for all selectedcontaminants of concern; and

5 Conduct a quantitative risk characterization.

5.6.1 Selection of Chemicals of Concern

The first task in the PHE will be the selection of chemicalsconsidered most likely to pose risks to human health and theenvironment for detailed analysis in the risk assessment. Theselection process will include a review of historic and newenvironmental monitoring data for soil, baghouse dust,groundwater, surface water and sediment, and other potentialsource locations.

Factors that will be used in selecting constituents of concernwill include the presence of chemicals in background samples andin laboratory, field, and trip blanks, the extent ofcontamination (e.g., frequency of detection), the environmentalmobility and persistence of the chemicals, and their relativetozicities. A key element in this selection process is acomparison of Site concentrations to background levels inappropriate media; naturally occurring chemicals present atbackground concentrations will not be considered to beSite-related and will not be evaluated in the assessment. Inaddition, chemicals present in blanks at similar concentrations(i.e., laboratory and field contaminants) will not be selectedfor the detailed analysis. Depending upon the number ofchemicals detected at the Site, selection of a subset ofchemicals may not be necessary. If such a selection is needed,relative concentrations, mobility, persistence, and tozicity ofthe chemicals in the environmental samples taken at the Sitewill be considered.

5.6.2 Identification of Potential Exposure Pathways

In this step of the PHE, activity patterns near the RoeblingSteel Site will be qualitatively evaluated and combined withchemical source release, and transport media information toidentify potential exposure pathways under both present andfuture site and land use conditions.

An exposure pathway is defined by four elements: (1) a sourceand mechanism of chemical release to the environment; (2) anenvironmental transport media (e.g., air, groundwater) for thereleased chemical; (3) a point of potential contact of humans orbiota with the contaminated medium (the exposure point); and (4)an exposure route (e.g., drinking water or soil ingestion) atthe exposure point. All four of the elements must be presentfor an exposure pathway to be considered "complete." In thePHE, only complete exposure pathways are evaluated.

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The list of potential contaminant sources includes, but is notlimited to: soil contamination materials, baghouse dust; drumsor tanks of hazardous materials; soil contamination (possiblycaused by drum spillage, process spills, and/or sump pumpdischarge); former drum and tank storage areas; a landfill area;drainage ditches; and sludge lagoons. Contaminants from thesesources may migrate through the environment by infiltration,percolation, surface runoff and volatilization. For eachcombination of release source and transport medium, the locationof the point at which the highest individual exposure to a humanor ecological receptor may take place will be identified.Available information indicates that the following receptors andpoints of exposure may be the most likely to be important atthis site: users of the site (trespassers or potential futureon-site workers), nearby residents, users of surface water,aquatic life, and flora and fauna in the vicinity of the Site.

5.6.3 Estimation of Exposure Point Concentrations

After potential exposure pathways have been identified,concentrations for each constituent of concern will be estimatedat each of the exposure point locations. Annual averageconcentrations of substances will be estimated in eachenvironmental medium - air, surface water, groundwater, orsoil-through which potential exposures could occur.

Estimating concentrations at each exposure point will involvequantification of the amounts of chemicals that could bereleased to the environment over time by the various sourcesidentified in the exposure pathway analysis, prediction of theenvironmental transport and fate of each chemical of concern inthe identified medium of the exposure pathway, and derivation oftime-dependent concentrations at the points of exposure.Deriving these concentrations may involve the estimation ofpercolation through soils, volatilization from on-site soils,entrainment of contaminated on-site soil and dust, groundwaterflow, surface water flow, and/or sediment transport. Screeningor refined models will likely be used to characterize chemicalvolatilization from the Site and to predict off-site airconcentrations. Screening models will likely be used tocharacterize contaminant transport to surface water, to air viawind erosion, and to predict on-site air concentrations. Foreach chemical and each exposure pathway, the outcome of thissubtask will be a long-term environmental concentration at theexposure point.

5.6.4 Comparison to ARARs

EPA's guidelines indicate that the projected concentrations ofthe chemicals of concern at exposure points should be comparedto applicable or relevant and appropriate federal and statestandards, criteria, and guidelines (ARARs) to estimate thedegree and extent of risk to public health and the environment(including plants, animals, and ecosystems).

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At the present time, EPA considers the Safe Drinking Water Act,Maximum Contaminant Levels (MCLs) and Clean Air Act NationalAmbient Air Quality Standards (NAAQS) to be the onlyrelevant/applicable federal ambient health standards. Statewater quality standards promulgated under the Clean Water Actand state groundwater standards are also relevant andapplicable. Standards or guidelines promulgated by New Jersey,such as ECRA limits for soil, will also be considered as ARARs.In addition, for the purposes of the Superfund PHE process, EPAconsiders ARARs to include the Clean Water Act ambient waterquality criteria for the protection of human health and aquaticlife, and adjusted water quality criteria appropriate forcomparison to predicted concentrations if they are for the sameexposure route. Other guidelines that may be used are MaximumContaminant Level Goals (MCLGs) and the health advisories thatEPA's Office of Drinking Water has developed for numerouschemicals in drinking water. These health advisories recommendmaximum concentrations for three exposure periods of 1 day to alifetime, based on non-carcinogenic effects only.

5.6.5 Quantitative Risk Characterization

A quantitative risk characterization will be conducted for allthe selected chemicals of concern if, as is expected, ARARs arenot available for all of the selected contaminants in allrelevant environmental media.

To quantitatively assess the potential for adverse healtheffects associated with a Site, the magnitude of potential humanexposures to the selected contaminants of concern must beestimated. Intakes by potentially exposed populations (viainhalation, ingestion, or dermal absorption) will be calculatedseparately for each chemical in each environmental medium (e.g.,air, groundwater, surface water, biota, and soil) for allselected pathways of exposure. Chemical intakes for each humanexposure scenario will be estimated based on the frequency andduration of exposure and the rate of media intake (e.g., amountof water ingested per day). Intakes are expressed as the amountof a chemical taken into the body per unit body weight per day(mg/kg/day) and are referred to as chronic daily intakes(GDIs). The GDI is averaged over a lifetime (70 years) forcarcinogens (EPA 1986a) and over the exposure period fornoncarcinogens. The parameter values used to estimate GDIs willbe based on site-specific considerations where possible andinformation published in the scientific literature. Theassumptions used in these estimates will be stated clearly andthoroughly documented to the extent possible. The assumptionswill be selected to represent an "average exposure case" and a"plausible maximum exposure case." The exposure of nonhumanreceptors will be estimated based on the sampling results or, ifnecessary, on the use of appropriate models that have appearedin the scientific literature.

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Critical toxicity values (i.e., numerical values derived fromdose-response information for individual chemicals) will be usedin conjunction with the intake estimates to characterizepotential risks. EPA's Integrated Risk Information System(IRIS) will be used as the primary source of critical humantoxicity values. Four different types of critical toxicityvalues may be used:

1. Threshold limit values for any workers currently orpotentially on-site;

2. The reference dose for chronic exposure (RfD) toevaluate noncarcinogenic effects;

3. The carcinogenic potency factor to evaluatecarcinogenic effects; and

4. For environmental receptors, environmentalconcentrations that have been associated with adverseeffects in the field or laboratory studies will beidentified when available.

o Noncarcinogens

The RfD values represent levels of exposure below which adversehealth effects are unlikely to occur. They are derived byapplying safety factors to no-observed-effect levels from animalstudies and/or epidemiological studies.

To assess noncarcinogenic risks the GDI will be compared to theRfD. Where the GDI exceeds the RfD, an unacceptable publichealth risk will be assumed to exist. In accordance with EPAguidelines (EPA 1986d), a hazard index will be used to assessthe risks of exposure to multiple noncarcinogenic chemicals.This index sums the ratios of the GDI to the RfD over all theselected chemicals present. This assumes that the risks due toexposure to multiple chemicals are additive, an assumption thatis probably valid for compounds which have the same target organor cause the same effect. If the hazard index results in avalue greater than unity, the compounds in the mixture will beseparated by critical effect and separate hazard indices willthen be derived for each effect.

Throughout the PHE process, intakes and risks from oral, dermalabsorption, and inhalation exposure pathways will be estimatedseparately. However, the possible effects of multimediaexposure will be evaluated by summing the hazard indices acrossthose exposure pathways that could occur to the samepopulation. This will assure that acceptable levels are notbeing exceeded by combined intakes when multiple exposurepathways exist.

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o Potential Carcinogens

For potential carcinogens, the carcinogenic potency factor,defined as the slope of a calculated dose-response curve, willbe used to estimate excess lifetime cancer risks at low doselevels. This factor is estimated from the upper 95 percentconfidence limit of the slope of the dose-response curve derivedfrom a linearized extrapolation model. Risk will be directlyrelated to intake at low levels of exposure using the equation:

Risk - GDI x Carcinogenic Potency Factor

This equation is valid only for risks below 10~2 (one in onehundred) because of the assumption of low-dose linearity. Forsites where this model estimates excess carcinogenic risks of10-2 or higher, an alternative model may be considered. Itwill also be assumed that cancer risks for chemical mixtures areadditive, unless information is available that suggestsantagonism or synergism. Thus, the result of the assessmentwill be an upper 95 percent confidence level of the total excesslifetime carcinogenic risk for each exposure point. Cancerrisks will be summed across exposure pathways where relevant.

5.7 TASK 7 - TREATABILITY STUDY/PILOT TESTING

The preliminary scoping of remedial alternatives consideredcertain developed and innovative technologies for treatment ofthe contaminated soil and groundwater at the Site. Assumingthat some of these technologies meet remedial responseobjectives and that they pass the initial screening,treatability studies (laboratory or field) would be needed toevaluate their applicability to the Site and to develop costinformation for economical comparison among the technologies.

Ebasco proposes to perform a series of treatability studiesand/or pilot tests for removal of contaminants from variousmedia as follows:

Chemical fixationSoil washing with acidic solution

Groundwater

Physical chemical treatment (as appropriate)

Decontaminated Water from Structures

Physical chemical treatment (as appropriate).

Experiments representative of these studies are presented in thefollowing discussion. Experimental details will be developedafter review of pertinent field work data and the preparation ofthe experimental plan and bidding package.

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Chemical Fixation

The chemical fixation test consists of mixing fixation agentswith soil to bind the contaminant metals in the soil into aleach-resistant matrix. The mixture will then be analyzed forRCRA EP Toxicity and possible TCLP. These tests will provideinformation on whether fixation is a feasible remedialtechnology. Once the right formulation to fixate the soil isfound, the test will be duplicated to show reproducibility ofthe fixation process. If there are other contaminants ofconcern, those contaminants will also be analyzed.

Soil Washing With Acidic Solution

A soil washing test will be conducted on the contaminated soilto evaluate the leaching of metals with an acidic solution.Leaching agents such as hydrochloric acid, sulfuric acid andferrous sulfate will be tested at various pH levels. Severalleaching tests will be conducted to determine the feasibility ofsoil washing the leach metals from the soil. Batch and columnleaching tests will be considered.

Groundwater/Decontamination Water from Structures

Groundwater/decontamination water treatability studies will beconducted to determine the most applicable treatmenttechnologies and the most effective sequence of technologies toremove metals from contaminated groundwater. The treatedeffluent would be required to meet the applicable, or relevantand appropriate requirements (ARARs).

Based on the characteristics of contaminated groundwater/decon-tamination water, unit operations will be required to removemetals. Accordingly, physical-chemical treatment methods willbe investigated and will include the following treatabilitytests:

Chemical precipitation test;Filtration test;Sludge dewatering test.

These treatability tests will demonstrate the followingperformance:

Removal of any heavy metals through chemicalprecipitation, coagulation-flocculation andsedimentation;

Removal of suspended/colloidal matter through chemicalcoagulation-flocculation, sedimentation and filtration;

Volume reduction of waste by-product (sludge) byadvanced filtration technologies.

eieib108 ; 000909

Ebasco will prepare and issue a bid package and select aqualified testing facility to perform the groundwater treata-bility tests. The subcontractor will conduct laboratory-scaletests for chemical fixation, soil washing and physicaltreatment. More than one subcontractor may be required toperform these tests.

This Work Plan has considered only treatability studies forchemical fixation, soil washing and groundwater treatment.These are considered the roost applicable treatability tests forthe Site Feasibility Study.

5.8 TASK 8 - REMEDIAL INVESTIGATION REPORT

The Remedial Investigation Report will summarize the datacollected and the conclusions drawn from the fieldinvestigation. The report will be presented in the formatspecified in the draft EPA Guidance for Conducting RI/FS UnderCERCLA (March 1988} and will include the following information:

o An updated site description;o Site maps;o Field investigation results;o Chemical analyses results;o Evaluation of site hydrology; ando Results of the risk assessment.

Project status meetings are scheduled as part of Task 8following EPA review of the RI report.

6.0 TASK PLAN FOR FEASIBILITY STUDY fFS)

Based on the results of the Remedial Investigation, afeasibility study will be prepared for the Roebling Steel Site.This study will consist of four tasks:

Task 9 - Remedial Alternatives Screening;Task 10 - Remedial Alternatives Evaluation;Task 11 - Feasibility Study Report;Task 12 - Post RI/FS Support; andTask 15 - ERA Planning

In addition to these tasks, Task 2 - Community Relations, willbe continued during the FS. Community relations activities willbe extended through the public comment period and development ofthe RI/FS report and Record of Decision (ROD), and into the postRI/FS support task if required. Throughout the FS process,references including the following will be used: EPA Guidanceon Feasibility Studies Under CERCLA (1985). The National Oil andHazardous Substance Pollution Contingency Plan: Final Rule. NCP(1985). Compendium of Costs of Remedial Technologies atHazardous Waste Sites (EPA. 1988) and J.W. Porter's December1986 and July 1987 Memoranda on "Interim Guidance on Superfund

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Selection of Remedy", and EPA Guidance for Conducting RI/FSunder CERCLA (draft, March 1988), as well as technology-specificguidance and evaluation documents as appropriate.

The overall objective of the FS is to develop and evaluateremedial alternatives that allow the EPA to select a remedialaction that is:

o Protective of human health and the environment;o Cost effective;o In accordance with SARA; ando In accordance, to the extent practicable, with the NCP.

6.1 TASK 9 - REMEDIAL ALTERNATIVE SCREENING

Based on the results of the risk assessment (Task 6) and theestablished remedial response objectives, the initial screeningof remedial alternatives will be performed according to theprocedures recommended in the EPA's "Guidance on FeasibilityStudies under CERCLA (1985)," Porter's "Interim Guidance onSuperfund Selection of Remedy" (Dec. 1986) and (July 1987), andEPA's Guidance for Conducting RI/FS under CERCLA (draft, March1988). Potential remedial alternatives will be screened forboth the Focus Feasibility Study sources and the remainder ofthe Site contaminant sources and matrices.

According to later guidences (Porter, July 1987; EPA, March1988), development of alternatives will be initiated in a "PhaseI FS" which will be performed concurrent with the RI . This WorkPlan includes a preliminary identif icaton and discussion of suchalternatives, although the process of identifying and screeningpotential alternatives will be ongoing throughout the RI, as newtechnological and/or site-specific data emerge. These guidancesconcerning "Phase II FS", initial screening, is reflected inEbasco's task-activity decision points at the conclusion of theRI. The subtasks comprising Task 9 will accomplish thefollowing three objectives:

o Development of remedial response objectives andgeneral response actions;

o Identification and screening of remedial technologies;and

o Development and screening of remedial alternatives.

6.1.1 Development of Remedial Response Objectives and GeneralResponse Actions

Based on the data collected in this RI along with other existingdata, the remedial response objectives will be developed morefully. Prior to the development of these objectives,significant site problems and contaminant pathways will beidentified. Considering these problems and pathways, theremedial response objectives which would eliminate or minimize

Bieib ; 000911

substantial risks to public health and the environment will bedeveloped further, including a refinement of the ARARs withconsideration given to site-specific conditions. Based on theresponse objectives, general response actions will be delineatedto address each of the site problem areas and to meet the cleanup goals and objectives. These response actions will form thefoundation for the screening of remedial technologies. Generalresponse actions considered will include the "no action"alternative as a baseline against which all other alternativescan be compared.

6.1.2 Identification of Applicable Technologies andDevelopment of Alternatives

Based on the remedial response objectives and each identifiedgeneral response action, potential treatment technologies andtheir associated containment or disposal requirements will beidentified. A pre-screening of these potential treatmenttechnologies for suitability as part of a remedial alternativewill be conducted.

Technologies whiqh"-may prove extremely difficult to implement,may not achieve the remedial objective in a reasonable time, orare inapplicable and infeasible based on the Site conditions,will then be eliminated. A preliminary effort of this task hasbeen completed and the results can be found in Section 3.2 -Remediation Alternatives. However this preliminaryidentification will be finalized based on the results of the RIand the remedial response objectives. A revised list ofpotential remedial technologies/alternatives will be developed.

The development of alternatives requires combining appropriateremedial technologies such as those listed in Table 12 in amanner that will satisfy the site remediation strategies orresponse objectives established in Section 3.0 and refined basedon the results of the RI.

As required by SARA, treatment alternatives will be developed ineach of the following categories:

o An alternative for treatment that would eliminate, orminimize to the extent feasible, the need forlong-term management (including monitoring) at theSite;

o Alternatives that would use treatment as a primarycomponent of an alternative to address the principlethreats at the Site;

o An alternative that relies on containment, with littleor no treatment but protect human health and theenvironment by preventing potential exposure and/or byreducing mobility; and

o A No-Action alternative.

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000912

6.1.3 Screening of Remedial Alternatives

The list of potential remedial alternatives developed above willbe screened. The objectives of this effort is to reduce thenumber of technologies and alternatives for further analysiswhile preserving a range of options. This screening will beaccomplished by evaluating alternatives principally on the basisof effectiveness and implementability and cost as specified inEPA's Guidance for Conducting RI/FS under CERCLA (draft; March1988). These screening criteria are briefly described below:

o Effectiveness Evaluation

Effectiveness evaluation will consider the capabilityof each remedial alternative to protect human healthand the environment. Each alternative will beevaluated as to the protection it would provide, andthe reductions in toxicity, mobility or volume itwould achieve.

o Implementability Evaluation

Implementability evaluation will be used to measureboth the technical and administrative feasibility ofconstructing, operating and maintaining a remedialaction alternative. In addition, the availability ofthe technologies involved in a remedial alternativewill also be considered.

Innovative technologies will be considered throughoutthe screening process if there is a reasonable beliefthat they offer potential for better treatmentperformance or implementability, few or lesser adverseimpacts than other available approaches, or lowercosts than demonstrated technologies.

o Cost Evaluation

Cost evaluation will include estimtates of capitalcosts, annual operation and maintenance (O&M) cost,and present worth analysis. These conceptual costsestimates are order-of-magnitude estimates, and willbe prepared based on:

o Preliminary conceptual engineering for majorconstruction components;

o Unit costs of capital investment and generalannual operation and maintenance costs availablefrom EPA documents (Compendium of costs ofRemedial Technologies at Hazardous Wastes Sites,1985 and Handbook: Remedial Action At WasteDisposal sites, 1985) and from Ebasco in-housefiles.

At the end of Task 9 a meeting will be held with EPA and Stateof New Jersey to review the results of the Task 9 RemedialAlternative Screening and to decide on the list of remedialalternatives to be evaluated in detail in Task 10.

6.2 TASK 10 - DETAILED EVALUATION OF REMEDIAL ALTERNATIVES

The remedial alternatives which pass the initial screening willbe further evaluated. The evaluation will conform to therequirements of the NCP, in particular, Section 300.68 (h),Subpart F, and will consist of a technical, environmental andcost evaluation as well as an analysis of other factors, asappropriate. The detailed evaluation will follow the processspecified in the EPA Guidance on Feasibility Studies underCERCLA, and updated in J.W. Porter's December 1986 and July 1987Memoranda on "Interim Guidance on Superfund Selection of Remedyand EPA's Guidance for Conducting RI/FS under CERCLA (draft,March 1988).

In the latter guidances (Porter, July 1987; EPA, March 1988), aset of nine evaluation criteria have been developed to beapplied to each Remedial Alternative.

Table 15 presents the nine evaluation criteria and the factorsconsidered for each evaluation criteria. A brief description ofthese criteria is given as follows:

o Short-Term Effectiveness

This criterion addresses the effects of the alternative duringthe construction and implementation phase until the remedialactions have been completed and protection has been achieved.Each alternative is evaluated with respect to its effects on thecommunity, on-site workers, the environment, and time untilprotection is achieved.

o Long-Term Effectiveness

This criterion addresses the results of a remedial action interms of the risk remaining at the site after responseobjectives have been met. The primary focus of this evaluationis the extent and effectiveness of the contents that may berequired to manage the risk posed by treatment residual and/oruntreated wastes.

o Reduction of Toxicity. Mobility, and Volume

This criterion addresses the statutory preference for selectingremedial actions that employ treatment technologies thatpermanently and significantly reduce tozicity, mobility orvolume of the hazardous substances as their principal element.

113' 00091/1

Sheet 1 of 2Table 15

DETAILED EVALUATION CRITERIA

SHORT-TERM EFFECTIVENESS

Protection of community during remedial actionsProtection of workers during remedial actionsTime until remedial response objectives are achievedEnvironmental impacts

LONG-TERM EFFECTIVENESS

Magnitude of residual risksAdequacy of controlsReliability of controls

REDUCTION OF TOXICITY. MOBILITY AND VOLUME

Treatment process and remedyAmount of hazardous material destroyed or treatedReduction in toxicity, mobility or volumeIrreversibility of the treatmentType and quantity of treatment residuals

IMPLEMENTABILITY

Ability to construct technologyReliability of technologyEase of undertaking additional remedial action, ifnecessaryMonitoring considerationsCoordination with other agenciesAvailability of treatment, storage capacity, anddisposal servicesAvailability of necessary equipment and specialtistsAvailability of prospective technologies

COST

Capital costsAnnual operating and maintenance costsPresent worth analysis

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DETAILED EVALUATION CRITERIA

O COMPLIANCE WITH ARARs

Compliance with chemical-specific ARARsCompliance with action-specific ARARsCompliance with location-specific ARARs

- Compliance with appropriate criteria, advisories andguidances

O OVERALL PROTECTION OF HUMAN HEALTH AND ENVIRONMENT

O STATE ACCEPTANCE

O COMMUNITY ACCEPTANCE

C009it,

o Implement ability

This criterion addresses the technical and administrativefeasibility of implementing an alternative and the availabilityof various services and materials required during itsimplementation. Technical feasibility considers constructionaland operational difficulties and unknowns, reliability, ease ofundertaking additional remedial action, and the ability tomonitor the effectiveness. Administrative feasibility considersactivities needed to coordinate with other offices and agenciesin regards to obtaining permits for implementing remedialactions.

o Cost

This criterion addresses the capital costs, annual operation andmaintenance costs, and present worth analysis.

Capital cost consist of direct (construction) and indirect(nonconstruction and overhead) costs. Direct costs includeexpenditures for the equipment, labor, and material necessary toinstall remedial actions. Indirect costs include expendituresfor engineering, financial, and other services that are not partof actual installation activities but are required to completethe installation of remedial alternatives. Annual operation andmaintenance costs are post-construction costs necessary toensure the continued effectiveness of a remedial action. Thesecosts will be estimated to provide an accuracy of +50 percent to-30 percent.

A present worth analysis is used to evaluate expenditures thatoccur over different time periods by discounting all futurecosts to a common base year, usually the current year. Thisallows the cost of remedial action alternatives to be comparedon the basis of a single figure representing the amount of moneythat would be sufficient to cover all cost associated with theremedial action over its planned life. As suggested in theEPA's guidance (March 1988), a discount rate of 5 percent willbe considered unless the market values indicate otherwise duringthe performance of the FS.

o Compliance With ARARs

This criterion is used to determine how each alternativecomplies with applicable or relevant and appropriate Federal andState requirements, as defined in CERCLA Section 121.

o Overall Protection of Human Health and the Environment

This criterion provides a final check to assess whether eachalternative meets the requirement that it is protective of humanhealth and the environment. The overall assessment ofprotection is bssed on a composite of factors assessed under theevaluation criteria, especially long-term effectiveness andpermanence, short-term effectiveness, and compliance with ARARs.

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o State Acceptance

This criterion evaluates the technical and administrative issuesand concerns the state (or support agency) may have regardingeach of the alternatives.

o Community Acceptance

This criterion incorporates public comments into the evaluationof the remedial alternatives.

After each of the remedial alternatives has been assessedagainst the nine criteria, a comparative analysis will beperformed. This analysis will compare all the remedialalternatives against each other for each of the nine evaluationcriteria.

6.3 TASK 11 - FEASIBILITY STUDY (FS) REPORT

Two Feasibility Study reports will be prepared: (1) FocusFeasibility Study and (2) Feasibility Study for the remainder ofthe contaminant sources and environmental matrices. Bothstudies will essentially contain the same types of informationfor the contaminant sources and matrices investigated in each.An FS report will be prepared to summarize the activitiesperformed and to present the results and associated conclusionsfor Tasks 1 through 10. The report will include a summary oflaboratory treatability findings, a description of the initialscreening process and the detailed evaluations of the remedialalternatives studied. The FS report will be prepared andpresented in the following format as specified in the EPA"Guidance for Conducting RI/FS under CERCLA (draft, March 1988)."

The Feasibility Study Report will be comprised of an executivesummary and four sections. The executive summary will be abrief overview of the FS Study and the analysis underlying theremedial actions which were evaluated.

The FS will contain the following major components

o Site background;o Technology identification;o Remedial alternatives identification; ando Development of cost estimates.

A discussion of each component is presented below.

The introduction will provide background information regardingsite location, facility history and operation, and wastedischarges and regulatory actions. The nature of the problem,as identified through studies, will be presented. A summary ofgeohydrological conditions, remedial action objectives, andnature and extent of contamination addressed in RI Report willalso be provided.

1178181b

• C009J8

The feasible technologies for Site remediation will beidentified for general response actions, and the results of theremedial technonogy screening.

Remedial alternatives will . be developed by combining thetechnologies identified in the previous screening process. Theresults of initial screening of remedial alternatives, withrespect to effectiveness, implementability and cost, will bedescribed.

A detailed description of the cost and non-cost features of eachremedial action alternative passing the initial screening of theprevious section will be presented. The detailed evaluation ofeach remedial alternative with respect to ninecriteria, 1) short-term effectiveness, 2)effectiveness, 3) reduction of mobility, toxicity andimplementability, 5) cost, 6) compliance with ARARs,protection of human health and the environment,acceptance and 9) community acceptance will be presented.comparison of these alternatives will also be presented.

evaluationlong-term

volume, 4)7) overall8) state

A

Ebasco's FS Report will clearly establish the bases for EPA toselect the preferred remedial alternative.

The FS will also involve a communitycomprised of the following two elements:

relations element,

o Organize public meeting on the feasibility study.

REM III community relations staff will provide planning,coordination, logistical support and attendance to the publicmeeting onthe Fs. Staff will also prepare a public meetingsummary for the meeting.

o Prepare a final responsiveness summary prior to theapproval of the record of decision.

REM III community relations staff will compile and summarizepublic comments and EPA respondes to these comments in aresponsiveness summary concerning results of the draft FS report.

6.4 TASK 12 - POST RI/FS SUPPORT

Ebasco will provide support to the EPA for any requestedassistance over and above that funded for Task 2 in activitieswhich occur after the site's RI/FS is complete. The scope andbudget estimated for this effort, if needed, will be determinedin meetings with the EPA after the RI/FS report is approved andfollow-up actions are identified.

As part of Task 12, Post RI/FS Support, REM III CommunityRelations Staff will prepare a Draft and Final ResponsivenessSummary for the Public Comment Period on the FS. TheResponsiveness Summary will provide a record for the EPA of all

eieib118

C00919

issues identified during the public comment period and publicmeeting on the FS report. The REM III community relations staffwill assist the technical team in responding to written commentsand will produce a responsiveness summary of the major concernsidentified at the FS public meeting and during the publiccomment period.

6.5 TASK 15 - EXPEDITED RESPONSE ACTION (ERA) PLANNING(OPTIONAL)

6.5.1 ERA For Drum Removal

Ebasco will assist EPA in preparation of an ERA for the removalof the more than 1,200 on-site drums not presently stored inBuilding 22. This assistance would involve the followingefforts.

A. Plans - The plans will be developed by Ebasco to supportbidding for the Removal Contract, describe existing Siteconditions and remedial design requirements, determine thesuggested construction approach, and develop details of theaction.

B. Technical Specifications

Ebasco will prepare technical specifications in accordancewith the Construction Specifications Institute (CSI) formatfor drum removal. Determination of the ability to bulkdrums will be included.

Technical specifications necessary for the implementationof the selected remedies will be developed as an integralpart of the technical bid package. The technicalspecifications will include, as applicable, the followingitems:

o Scope of work;o Applicable codes and standards;o Material specifications; ando Technical requirements.

The scope of the technical specification will include thefollowing:

1. Site preparation;

o Support facilities;o Access roads;o Erosion and sediment control;

2. Site Specific Health and Safety Guidelines;

3. Site Security;

4. Site Specific Quality Control;

119BlBlb 0 0 0 9 2 0

o Organization;o Sampling protocol;

5. Drum Removal and Handling;

o Sampling;o Drum sampling facilities;o Analytical equipment;o Evidence documentation;o Drum removal equipment; '_o Waste analysis; ~ fi«.o Drum removal and staging plans;o Spill prevention and response; ando Drum preparation for off-site transportation.

C. Proposal Evaluation

Ebasco will prepare, as part of the bid document, Section00100, entitled "Instruction to Bidders". This sectionwill include the requirements for bid preparation, proposalformat, minimum bid requirements.

The section will also include the basis of award and theevaluation procedures and criteria.

The proposal will be evaluated using the One-Step method inwhich the bidders are required to submit their technicalproposals and their cost offers at the same time, in sealedpackages.

The technical proposals will be first evaluated by atechnical proposal evaluation committee. The technicalproposals will be evaluated without disclosure of thebidder's identity. Cost/price data will not be consideredduring this activity.

The culmination of the technical evaluation will be aclassification of each technical proposal as "acceptable",or "unacceptable". The acceptable proposals will beevaluated by the following criteria:

1. Management Plan2. Past Project Experience3. Material Handling Plan4. Off-Site Transportation5. Health and Safety Plan6. Chemical Quality Control Plan7. Quality Control Plan8. Site Work9. Construction Schedule

After completion of the technical evaluation, a cost/priceevaluation will be made for all bids classified as"acceptable". The evaluation rating for each proposal will be

120 C00921

divided into the dollar amount for that same proposal to arriveat a "dollar per points" value for a proposal. The proposalwith the lowest $/point value will be given the highest ranking.

The results of the bid evaluation will be given to the EPA fortheir determination of awarding the Contractor based on theirbest judgement.

6.5.2 ERA - Specification Preparation for Compressed GasCylinder Removal- (Optional)

If the results of the inventorying/owner identification effortof Task 20a does not ultimately result in the disposal and/orremoval of the on-site compressed gas cylinders, a specificationwill be prepared for their removal.

The specification shall state that the removal Contractor shallfurnish the personnel, services, materials and equipmentrequired for the disposal (EPA approved) of the compressed gascylinders found at the Roebling Steel Site.

Ebasco will prepare (as possible) the specification to includein the Contractor's Scope of Work the verification of thefollowing:

1. Condition of cylinder valves;2. Content of cylinders; and3. Suitability of the cylinders for transport.

The Contractor shall provide the cost of cylinder disposal foreach of the following conditions:

1. If a cylinder meets three conditions in thespecification;

2. If a cylinder will require remote sampling equipment toidentify content; and

3. If a cylinder has to be made suitable for transport.

6.6 TASK 20 FOCUSED FEASIBILITY STUDY (FFS)

Seven sources of potential contamination will be separatelyinvestigated in a Focused Feasibility Study. Essentially, thisFFS will be comprised of the same tasks as the primary FS,except that it will only evaluate six potential sources and thuscan be conducted in a shorter time frame and allow quickerimplementation of Remedial Actions. Determination of thesolution for disposal of these sources will involve analysis andperformance of each of Tasks 9, 10, 11 and 12 of the primaryFS. These sources are transformers, tanker cars, chemicalpiles, compressed gas cylinders, the baghouse dust pile and theon-site tank farm.

121sieib ; 00092?

The overall objective of the FFS is to develop and evaluateremedial alternatives that allow the EPA to select a remedialaction that is:

o Protective of human health and the environment;o Cost effective;o In accordance with SARA; ando In accordance, to the extent practicable, with the NCP.

Compressed Gas Cylinders (Task 20a). Reportedly, about 6-10compressed gas cylinders are located inside the buildings.Ebasco will inventory these cylinders to determine:

o Contents of cylinders (as possible);o Owner/manufacturer (if marked on cylinder); ando The condition of the cylinder and the valve.

Results of this inventory will be reported to the EPA.

If the results of inventorying the 6-10 on-site compressed gascylinders do not identify the owners of the tanks, or if theowners will not accept their cylinders, an optional effort toprepare a specification for their disposal will be prepared(Task 15b). A description of the work effort involved inpreparing this specification is described in Section 6.5.2.

o Baghouse Dust Pile Sampling (Task 20b)

Four baghouse dust samples will be collected from the existingbaghouse dust pile stored in a roofed area adjacent (west) tobuilding 88.

Details of baghouse dust sample acquisition will be presented inthe FSAP.

o Tanker Sampling (Task 20c)

Two tanker cars have been identified on-site. The contents ofthese tanker cars will be sampled to determine the chemicalcharacteristics of their contents.

Details of tanker car sample acquisition will be presented inthe FSAP.

o Residue/Waste Pile Sampling (Task 20d)

Residue/waste piles (i.e., chemical piles) have been noted inseveral of the on-site buildings. These chemical piles will besampled and analyzed to determine the type, if any, ofcontamination.

000923

Details of the chemical pile sampling will be presented in theFSAP.

o Tanker Farm Sampling (Task 20e)

Three large cylindrical tanks ezist near the western boundary ofthe Site. These tanks will be sampled to determine the contentsof each tank.

Details of tank sampling will be presented in the FSAP.

o Transformer Sampling (Task 20f)

Twenty four oil samples will be collected from the existingon-site transformers. These transformers are situated bothinside and outside of buildings. The REM II Contractor reportedthat their oil capacity ranged from thirty-four toone-thousand-nine-hundred-fifty gallons. It nay be necessary totest all the transformers, prior to sampling, to determine ifelectrical current exists inside them.

Details of transformer oil sample acquisition will be presentedin the FSAP.

7.0 RI/FS COST ESTIMATE

The estimated cost for the Site RI/FS is ________. Thesecosts include all workhours, other direct costs and subcontractcosts for the initial tasks and the tasks described in this WorkPlan. The estimated costs for treatability studies arepreliminary and will be finalized following availability ofrequisite information.

The cost estimate is based on the assumption that health andsafety personnel protective equipment requirements are Level D,C and B. If the level of protection has to be upgraded for alonger period of time, increased costs will be incurred. Costsassociated with the implementation of the Community RelationsPlan have been included in the amount of _____.

8.0 RI/FS SCHEDULE

The project schedule and critical path are shown on Plate A (inpocket). This plate also shows the tasks and activities for theRI/FS. The critical path has been highlighted and key milestonedates have been identified.

The schedule assumes ready access to the Site and thatsurrounding property owners (for the drilling of monitoringwells and boreholes, test pits, Site surveys and the collectionof samples) will not delay access to the Site. The schedulealso assumes that the health and safety personnel protectiverequirements are Level D, C and B dependent on the type of fieldactivities. The HASP will give details of the requirements.

eieib 000924

The schedule for the RI/FS is based on the conditions discussedin this Work Plan. It should be mentioned that the treatabilitystudies are included in the schedule shown on Plate A (inpocket).

9.0 PROJECT MANAGEMENT APPROACH

9.1 KEY PERSONNEL AND ORGANIZATION

The proposed project organization is shown on Figure 16. TheRegional Manager (RM), Dr. Dev. R Sachdev is responsible for thequality of all REN III work performed in Region II. He monitorsthe progress of each work assignment to ensure adequateresources are available and that major problems are prevented orminimized. Dr. Sachdev implements the program standard ofquality for work in the region and makes sure that the SiteManager meets that standard. The RM's review concentrates onthe technical quality, schedule, and cost for all workassignments.

The Site Manager (SM), Mr. Stephen John Schmid has primaryresponsibility and authority for implementing and executing theRI/FS. Supporting the SM are the RI Leader, Field OperationsLeader (FOL), FS Leader, and other staff. The RI Leader isresponsible for conduct of the RI and for the preparation of theRI Report. The FOL is responsible for on-site management forthe duration of all activities at the Site. The FS Leader isresponsible for the FS (including ensuring the RI obtains propercharacterization data) and for the preparation of the FSReport. Figure 16 presents the project organization chart.

The task numbering system for the RI/FS effort is a continuationof the task numbering system used for the initial tasks andactivities dscribed in this Work Plan. The Tasks are numberedas follows:

Task 1 Project PlanningTask 2 Community RelationsTask 3 Field InvestigationTask 4 Sample Analysis/ValidationTask 5 Data EvaluationTask 6 Assessment of RisksTask 7 Treatability Study/Pilot testingTask 8 Remedial Investigation ReportTask 9 Remedial Alternatives ScreeningTask 10 Remedial Alternatives EvaluationTask 11 Feasibility Study/RI/FS ReportsTask 12 Post RI/FS SupportTask 15 Expedited Response Action PlanningTask 20 Focused Feasibility Study

The task list, in addition to a project schedule and budget,comprises the baseline plans which form an integrated managementinformaton system against which work assignment progress can bemeasured. The baseline plans are a precise description of how

1248181b 000925

the Work Assignment will be executed in terms of work scope,schedule, staffing and cost. The project schedule is presentedin Section 8.0 and the cost estimate is presented under separatecover.

9.2 PROJECT COORDINATION

As depicted on the project organization chart, there are severalreporting mechanisms required to successfully implemented theWork Plan. A summary of these mechanisms is discussed below andshown on Figure 16.

The RM has overall responsibility for implementation and conductof this Work Plan in this role, he will keep the EPA- RPOapprised of status and major accomplishments/problemsencountered. As required he will also inform/discuss problemsand seek problem resolution with the EPA-RPM.

The SM is responsible for the daily conduct of the RI/FS. Inthis role, he informs the RM of project schedule, budget andmilestone status. The SM also maintains communications with theEPA-RPM regarding status and need for EPA guidance/assistance inimplementing elements of the Work Plan. The various projectleads report to and provide the SM with status of theirrespective responsible areas. The SM provides direction andcoordination to the project leads as well as resolution ofsignificant issues. The Health and Safety Officer also reportson site safety conditions during the conduct of Siteinvestigations to the SM.

The RI Leader is responsible for the implementation of the Siteinvestigation. He will coordinate the Ebasco staff and thesubcontractors assigned to the field investigation to ensurethat the proper resources are available on a timely basis.Also, he is responsible for preparation of the RI Report.

The FOL is responsible for conduct of the Site investigationactivities specified in this Work Plan. The FOL will be inconstant communications with the RI Lead to ensureefficient/effective implementation of the work plan. Except forthe health and safety officer, all site personnel wil report tothe FOL while on the site. The FOL will also be responsible forsubcontractors (e.g., drillers) while they are working on thesite.

The FS Leader will be responsible for the preparation of the FSreport. The responsibility includes assessment of the RI Fieldsampling program to make certain that the proper type andquantity samples are being obtained for the FS report.

The Communty Relations Leader will assist EPA in theimplementation of a site specific community relations program(CRP). In this role, theleader will take direction from the EPAcommunity relations coordinator based on this EPA site CRP andunderstanding of project status as provided by the SM.

125000926

FIGURE 16

ROEBLING STEEL SITEPROJECT ORGANIZATION CHART

REGIONALMANAGER

O. SACHDEV

SITEMANAGER

SJ. KHMID

COMMUNITYRELATIONS

LEADER

P. GUNTHER

RISKASSESSMENT

LEADER

S. FOSTER (ICF)

HEALTH ft SAFETYOFFICER

B.BLISS

SUBCONTRACTORS

• WELL DRILLING• SURVEYING• ELECTRICIAN• BACKHOE/CHERRY

PICKER

FIELDOPERATIONS

LEADER/GEOLOGIST

J. STRICKLAND

• GEOLOGIST• HEALTH AND

SAFETY OFFICER

REMEDIALINVESTIGATION

LEADERE.AOUADO

FEASIBILITYSTUDY

LEADERXCLEARY

OEOHYDROLOGISTTOXICOLOGIST/RISK ASSESS SPECIALISTENVIRONMENTAL/CHEMICAL ENOINEEM

• CHEMIST• GEOLOGIST• MODELER

• OEOTECT. ENOR• ENVIRON. ENOR• REGULATORY

SPECIALIST

ANALYTICALCHEMISTRY

COORDINATORJ. LORENZO

I________I

000927

9.3 QUALITY ASSURANCE AND DOCUMENT CONTROL

The site-specific quality assurance requirements will be inaccordance with the Quality Assurance Project Plan for the REMIII Program, as approved by EPA, and in accordance with theBrossman Guidance.

Document Control aspects of the program pertain to controllingand filing documents. Ebasco has developed a program filingsystem (Administrative Guideline Number PA-5) that conforms tothe requirements of the Environmental Protection Agency and theREM III Program to ensure that the documents are properly storedand filed. This guideline will be implemented to control andfile all documents associated with the Site's RI/FS. The systemincludes document receipt control procedures, a file review andinspection system, and security measures.

1268181b

REFERENCES

Dadswell. M.J. 1979. Biology and population characteristics ofthe shortnose sturgeon, Acipenser brevirostrum LeSuer 1818(Osteichthyies: Acipenseridae) in the Saint John Estuary,New Brunswick, Canada. Can. J. Zool. 5JZ: 2186-2210.

Ebasco 1988. Site Reconnaissance Survey. Roebling Steel Site.

Environmental Resources Management. October 1983. RemedialAction Master Plan (RAMP) for the John A. Roebling SteelCompany Site, Florence Township, Burlington County. NewJersey EPA Work Assignment: 01-2V910.

Hoff, J.G. 1965. Two shortnose sturgeon, Acipenserbrevirostrum from the Delaware River, Scudder's Falls, NewJersey. Bull. N.J. Acad, Sci. 1023.

NJDEP, 1981. Water Quality Criteria

Roy F. Weston, Inc. May 1987. Work Plan for Roebling SteelCompany Site, Burlington County, New Jersey. RemedialInvestigation/Feasibility Study: Volume I. Work AssignmentNo. 05-2L91.

Sipple, W.S. 1987. Wetland Identification and DelineationManual. Interim Final. USEPA.

Taubert, B.D. 1980. Description of some larval shortnosesturgeon (Acipenser brevirostrum) from Holyoke Pool,Connecticut River, Massachussetts, USA, and the Saint JohnRiver, New Brunswick, Canada. Can. J. Zool. 58: 1125-1128.

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA). 1986a. Guidelinesfor Estimating Exposures. Fed. Reg. 51:34042-34054

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA). 1986b. Guidelinesfor Carcinogen Risk Assessment. Fed. Reg. 51:33992-34003(September 24, 1986)

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA). 1986C. Guidelinesfor Assessing Chemical Mixtures. Fed. Reg. 51:34014-34025

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA). 19B6d. SuperfundPublic Health Evaluation Manual. Office of Emergency andRemedial Response. Washington, D.C. October 1986. EPA540/1-86/060

U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA). March 1988 Draft.Guidance for Conducting Remedial Investigations andFeasibility Studies under CERCLA.

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APPENDIX A

Me Guire AFB (Wrightstown, NJ) Meteorological Data,1981-1985

This Appendix presents a compilation of 5 years (1981-1986) ofmeteorological data from McGuire AFB for the annual and seasonalaveraging periods. The following information is presented:

o 5 Wind Roses (Annual, 4 Seasons)

o 12 Tables (Annual, 4 Seasons, 12 Months)

The wind roses are graphical depictions of the frequency of windspeed and direction for varying time periods for any observationstation.

Also presented are the same data in tabular format with theaddition of 12 monthly averaging periods.

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000930

MISCELLANEOUS INFORMATION

SCALING PARAMETERS . . . . . . . . . . . . . . . . . .5 30 70 120 180 240 320 9999DATE OF FIRST OBSERVATION . . . . . . . . . . . . . . .810101DATE OF LAST OBSERVATION . . . . . . . . . . . . . . .851231TOTAL NUMBER OF RECORDS READ FROM FILE 4 . . . . . . . 43823NUMBER OF DAYS REPRESENTED . . . . . . . . . . . . . . 1825TOTAL NUMBER OF VALID OBSERVATIONS . . . . . . . . . . 43823NUMBER OF INVALID OBSERVATIONS . . . . . . . . . . . . 1

8181b

000931

TABLE A-1

MCGUIRE AIR FORCE 3ASE

CARD IMAGE CO 144 DATA

JAMUARY 1981 - DECEMBER 1985

JANUARY FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

oo0U3COro

N

NNE

NE

ENE

E

ESE

SE

SSE

S

sswswwsuwtAMJWWW

NX

uuuflnW

CALN

TOTAL

8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

13.25

13.25

1.48

0.75

0.62

0.48

0.65

0.24

0.30

0.19

0.56

0.73

0.67

0.65

1.45

1.02

0.94

1.05

0.00

11.77

5.11

1.77

1.24

0.83

0.78

0.32

0.08

0.19

1.16

1.24

2.10

2.72

4.44

2.93

2.80

2.69

0.00

30.38

3.01

0.99

0.86

0.62

0.97

0.32

0.11

0.16

0.46

0.86

1.05

1.51

3.23

3.20

3.95

2.50

0.00

23.79

1.40

0.24

0.48

0.30

0.51

0.13

0.05

0.00

0.19

0.22

0.35

0.51

2.53

2.47

2.85

2.58

0.00

14.81

0.05

0.03

0.00

0.00

0.08

0.05

0.00

0.03

0.08

0.05

0.03

0.08

1.26

1.72

1.02

0.59

0.00

5.08

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.13

0.46

0.11

0.13

0.00

0.83

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.08

0.00

0.00

0.00

0.00

0.08

11.05

3.79

3.20

2.23

2.98

1.08

0.54

0.56

2.45

3.09

4.19

5.46

13.12

11.80

11.67

9.54

13.25

100.00

7.31

6.38

7.29

6.75

7.91

7.90

5.18

6.15

6.81

6.80

6.82

7.32

9.88

11.18

10.51

10.03

0.00

7.68

TABLE A-2

HCGUIRE AIR FORCE BASE

CARD IMAGE CD 144 DATA

JANUARY 1981 - DECEMBER 1985

FEBRUARY FREQUENCY DISTRIBUTION (IN PERCENT)

3384 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

OO0

COCO

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

swwswW» «»iWOl

NW

NNW

CALM

TOTAL

8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

12.44

12.44

1.63

0.47

0.50

0.59

0.62

0.68

0.56

0.62

0.95

0.74

0.89

0.62

0.83

0.53

0.71

0.71

0.00

11.64

4.02

2.63

1.36

1.15

2.69

0.83

0.80

0.77

1.51

1.65

2.33

1.83

2.39

2.45

2.48

1.95

0.00

30.85

2.33

0.95

1.27

0.83

1.42

0.47

0.53

0.44

1.06

1.12

1.21

1.18

1.71

2.84

3.81

2.01

0.00

23.20

1.83

0.09

0.47

0.80

0.59

0.15

0.24

0.27

0.59

0.27

0.33

0.95

1.09

1.86

3.07

1.92

0.00

14.51

0.30

0.09

0.24

0.33

0.12

0.06

0.03

0.06

0.35

0.15

0.09

0.00

0.53

1.65

1.48

0.62

0.00

6.09

0.00

0.03

0.03

0.03

0.06

0.00

0.00

0.00

0.06

0.00

0.00

0.00

0.03

0.74

0.27

0.00

0.00

1.24

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.03

10.11

4.26

3.87

3.72

5.50

2.19

2.16

2.16

4.52

3.93

4.85

4.58

6.59

10.08

11.85

7.21

12.44

100.00

7.89

6.73

8.58

9.44

7.70

6.30

6.57

6.68

8.40

7.00

6.53

7.98

8.82

12.40

11.53

10.03

0.00

7.87

TABLE A-3

MCGUIRE AIR FORCE BASE



MARCH FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

CALM .5-3 3 - 7 7 -1Z

WIND SPEED (MPH)

12-18 18-2424-32 >32 TOTAL AVERAGE

o0oCOCO

N

NNE

HE

ENE

E

ESE

SE

SSE

S

SSW

SW

wswW

MM

NW

UftMJnnw

CALN

TOTAL

8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

8.15

8.15

1.48

0.38

0.46

0.40

0.89

0.56

0.32

0.51

0.48

0.78

0.65

0.24

0.73

0.43

0.70

0.75

0.00

9.76

3.55

1.10

1.18

1.34

1.67

1.05

0.78

0.81

1.99

1.37

1.42

1.53

2.26

2.85

3.98

2.37

0.00

29.25

3.06

0.83

1.16

1.77

1.88

0.89

0.32

0.35

0.99

1.18

1.08

1.42

2.02

3.44

4.11

3.28

0.00

27.80

1.80

0.56

0.35

1.02

0.99

0.22

0.08

0.00

0.24

0.27

0.51

0.78

1.80

2.39

3.28

2.34

0.00

16.64

0.67

0.32

0.11

0.40

0.32

0.11

0.00

0.03

0.05

0.11

0.22

0.22

0.73

1.48

1.34

1.02

0.00

7.12

0.03

0.00

0.11

0.32

0.05

0.00

0.00

0.00

0.03

0.00

0.00

0.03

0.13

0.43

0.05

0.05

0.00

1.24

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.05

10.59

3.20

3.36

5.30

5.81

2.82

1.51

1.69

3.79

3.71

3.87

4.22

7.66

11.05

13.47

9.81

8.15

100.00

8.64

9.30

8.41

11.00

9.00

7.46

6.01

5.17

6.82

7.24

7.81

9.30

10.31

11.76

10.47

10.59

0.00

8.75

ooCO

8181b

CALM

TABLE A-4




APRIL FREQUENCY DISTRIBUTION (IN PERCENT)

3600 OBSERVATIONS

. 5 - 3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

sswSW

WSW

W

WNW

NW

NNW

CALM

TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

10.81

10.81

0.64

0.31

0.53

0.39

0.53

0.56

0.36

0.50

1.17

0.94

0.86

0.75

1.14

0.92

0.44

0.72

0.00

10.75

2.11

1.03

0.97

1.22

2.64

0.72

0.78

0.92

2.31

2.17

2.56

2.06

3.47

3.58

2.75

1.69

0.00

30.97

1.92

0.42

0.53

1.11

2.19

1.19

1.00

0.50

1.58

1.94

1.39

1.64

3.50

2.97

2.92

1.94

0.00

26.75

1.33

0.25

0.14

0.31

1.06

0.36

0.39

0.17

0.75

0.97

0.89

0.42

1.97

2.86

2.08

1.25

0.00

15.19

0.33

0.00

0.00

0.03

0. 14

0.03

0.00

0.00

0.14

0.28

0.36

0.11

0.56

1.08

1.36

0.28

0.00

4.69

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.03

0.00

0.03

0.31

0.22

0.14

0.00

0.78

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.03

0.00

0.00

0.06

6.36

2.00

2.17

3.06

6.56

2.86

2.53

2.08

5.97

6.31

6.08

4.97

10.67

11.75

9.81

6.03

10.81

100.00

9.38

7.19

6.07

7.51

8.47

7.81

8.07

6.24

7.67

8.21

8.25

7.34

9.04

10.62

11.20

9.70

0.00

7.95

TJBLE A-5




MAY FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

000936

N

NNE

NE

ENE

E

ESE

SE

SSE

S

sswswwswwiAHJwnw

NH

fc^M •Nlfw

CALM

TOTAL

8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

14.35

14.35

1.05

0.81

0.56

0.56

1.10

1.10

0.91

0.75

1.69

0.99

1.24

1.05

1.05

0.73

0.81

0.89

0.00

15.30

3.47

1.48

1.16

1.48

2.10

2.02

1.67

1.88

3.25

2.98

2.88

2.15

3.20

1.83

2.63

2.04

0.00

36.21

2.63

0.86

0.62

0.97

1.34

0.54

0.48

0.59

2.96

1.72

1.91

1.83

2.02

1.67

1.16

1.51

0.00

22.80

0.89

0.48

0.27

0.46

0.38

0.03

0.03

0.13

0.65

0.67

1.21

0.89

0.67

1.34

0.94

0.65

0.00

9.68

0.08

0.22

0.03

0.03

0.13

0.00

0.00

0.00

0.00

0.03

0.24

0.05

0.19

0.32

0.22

0.11

0.00

1.64

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

8.12

3.84

2.63

3.49

5.05

3.68

3.09

3.36

8.55

6.40

7.47

5.99

7.12

5.89

5.75

5.19

14.35

100.00

7.44

7.42

6.68

7.06

6.69

4.88

4.70

5.45

6.73

7.07

7.93

7.63

7.34

9.02

7.87

7.50

0.00

6.13

0 8181bo0

OCOCO

TABLE A-6




JUNE FREQUENCY DISTRIBUTION (IN PERCENT)

3599 OBSERVATIONS

WIND SPEED (MPH)

CALM .5-3 3-7 7-12 12-18 18-24 24-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

swWSW

W

MIUwmf

NW

UMUnnw

CALM

TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

14.84

14.84

1.22

0.69

0.78

0.81

1.03

1.22

1.22

1.14

1.94

1.92

1.S8

1.28

1.83

1.22

1.00

1.06

0.00

19.95

2.70

1.61

1.58

1.64

2.81

1.58

1.14

1.19

3.92

3.39

4.42

3.45

4.28

2.61

3.14

2.33

0.00

41.79

1.53

0.86

1.08

1.22

0.94

0.39

0.11

0.08

1.11

1.42

1.39

2.03

1.89

1.14

1.86

1.19

0.00

18.26

0.67

0.08

0.14

0.06

0. 14

0.00

0.00

0.00

0.11

0.03

0.31

0.58

0.67

0.72

0.61

0.47

0.00

4.58

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.06

0.14

0.22

0.14

0.03

0.00

0.58

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

6.11

3.25

3.58

3.72

4.92

3.20

2.47

2.42

7.09

6.75

7.70

7.39

8.81

5.92

6.75

5.08

14.84

100.00

6.80

5.77

6.28

6.07

5.51

4.29

3.56

3.55

5.04

5.02

5.53

6.75

6.39

7.12

7.13

6.64

0.00

5.06

TABLE A-7




JULY FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

CALM . 5 - 3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

H

1AIUWWW

HW

NNW

CALM

C5 TOTAL

ao 81816

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

19.22

19.22

1.26

0.54

0.73

0.54

1.05

0.67

0.91

1.40

2.53

2.39

1.72

1.32

1.64

1.24

1.21

1.51

0.00

20.65

3.68

1.21

1.18

0.67

1.26

0.75

1.37

1.34

4.22

4.01

4.68

4.46

4.68

3.01

2.63

2.69

0.00

41.85

1.51

0.62

0.32

0.24

0.54

0.35

0.38

0.46

1.26

1.51

1.64

1.21

1.99

1.51

1.24

0.91

0.00

15.67

0.16

0.08

0.00

0.00

0.00

0.00

0.05

0.03

0.13

0.27

0.30

0.24

0.35

0.22

0.22

0.27

0.00

2.31

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.05

0.05

0.00

0.00

0.00

0.08

0.05

0.00

0.27

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

6.64

2.45

2.23

1.45

2.85

1.77

2.72

3.23

8.15

8.23

8.39

7.26

8.66

5.97

5.38

5.43

19.22

100.00

5.79

6.12

4.76

4.73

4.61

4.38

4.80

4.32

4.83

5.47

5.74

5.81

5.92

6.08

6.07

5.52

0.00

4.44

00

oooCOOJCO

8181b

CALM

TABLE A-8




AUGUST FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

.5-3 3 - 7 7 -12

WIND SPEED (MPH)

12-18 18-24 24-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

IAHJmm

NW

mH |Nnw

CALM

TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

18.82

18.82

1.88

0.62

0.65

0.73

1.21

1.24

0.56

0.99

2.26

2.23

1.53

1.45

2.04

1.40

1.02

1.45

0.00

21.26

4.76

1.91

1.77

1.80

1.80

1.64

1.24

1.37

3.98

5.30

4.84

3.15

4.30

3.09

3.06

2.77

0.00

46.77

1.61

0.75

0.48

0.89

0.91

0.16

0.08

0.22

0.81

0.99

1.02

0.73

1.05

0.51

0.54

0.48

0.00

11.24

0.35

0.05

0.11

0.03

0.05

0.00

0.00

0.03

0.03

0.05

0.03

0.03

0.19

0.13

0.35

0.30

0.00

1.72

0.03

0.00

0.00

0.13

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.19

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

8.63

3.33

3.01

3.58

4.01

3.04

1.88

2.61

7.07

8.58

7.42

5.35

7.58

5.13

4.97

5.00

18.82

100.00

5.64

5.64

5.45

6.40

5.25

3.93

4.37

4.15

4.45

4.79

5.01

4.83

5.13

5.03

5.55

5.02

0.00

4.12

TABLE A-9

MCGUIRE AIR FORCE BASECARD IMAGE CO 144 DATA

JANUARY 1981 - DECEMBER 1985 .SEPTEMBER FREQUENCY DISTRIBUTION (IN PERCENT)

3600 OBSERVATIONS

WIND SPEED (MPHJCALM .5-3 3-7 7-12 12-18 18-24 24-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

wswW• miWlw

NW

uuuinvn

CALM

o TOTAL

OCO 8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

20.06

20.06

1.83

1.25

1.31

1.25

1.39

0.78

0.67

0.89

1.08

1.64

1.50

1.28

1.25

0.78

0.83

0.89

0.00

18.61

4.61

2.28

2.47

1.89

2.11

1.00

0.94

0.92

2.72

2.89

4.00

3.94

3.22

2.06

2.44

2.19

0.00

39.69

2.03

1.22

1.72

1.36

0.94

0.19

0.11

0.08

0.78

0.69

1.00

1.36

1.58

1.22

1.58

0.94

0.00

16.83

0.50

0.25

0.39

0.44

0.28

0.08

0.00

0.00

0.11

0.06

0.06

0.08

0.47

0.47

0.33

0.33

0.00

3.86

0.03

0.00

0.06

0.00

0.11

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.06

0.08

0.14

0.19

0.00

0.69

0.00

0.03

0.00

0.06

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.08

0.00

0.00

0.03

0.00

0.19

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.06

0.00

0.00

0.00

0.06

9.00

5.03

5.94

5.00

4.83

2.06

1.72

1.89

4.72

5.28

6.56

6.67

6.67

4.67

5.33

4.58

20.06

100.00

6.03

6.08

6.52

6.69

5.86

4.56

3.85

3.44

5.32

4.78

5.15

5.62

6.68

7.49

7.07

7.06

0.00

4.79

Oo

TABLE A-10

MCGUtRE AIR FORCE BASE



OCTOBER FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

HINO SPEED (MPH)


N

NNt

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

IAHJWWW

NW

MMUWHW

CALN

TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

20.73

20.73

1.40

0.89

1.21

0.67

0.59

0.73

0.59

0.78

1.51

0.94

0.99

1.24

1.26

0.54

0.83

0.78

0.00

14.95

4.11

2.90

2.66

1.69

1.64

0.83

0.86

1.05

2.82

2.72

3.17

2.39

3.49

1.77

1.34

1.67

0.00

35.13

1.40

1.99

2.69

1.34

1.45

0.19

0.05

0.19

1.24

0.81

1.77

1.51

1.53

1.32

1.72

1.13

0.00

20.32

0.54

0.46

1.08

0.54

0.38

0.00

0.00

0.03

0.13

0.11

0.54

0.65

0.54

0.81

1.16

0.67

0.00

7.61

0.05

0.22

0.11

0.03

0.03

0.03

0.00

0.00

0.00

0.00

0.11

0.08

0.11

0.30

0.05

0.13

0.00

1.24

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

7.50

6.45

7.74

4.27

4.09

1.77

1.51

2.04

5.70

4.57

6.59

5.86

6.94

4.76

5.11

4.38

20.73

100.00

6.19

7.34

7.82

7.46

7.13

4.55

3.82

4.46

5.47

5.55

6.81

6.91

6.47

8.79

8.60

7.79

0.00

5.45

8i8ib

TABLE A-11




NOVEMBER FREQUENCY DISTRIBUTION (IN PERCENT)

3600 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

00094?

N

NNE

ME

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

iAlUWWW

MW

Uiiuruin

CALM

TOTAL

8181b

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

16.19

16.19

1.25

0.58

0.44

0.50

0.69

0.33

0.33

0.67

1.22

1.25

1.22

0.92

1.81

0.83

0.78

0.94

0.00

13.78

3.61

1.08

1.56

1.33

1.31

0.86

0.50

0.61

2.67

2.03

2.11

2.53

3.44

3.00

2.69

1.81

0.00

31.14

2.72

1.08

1.53

1.58

1.61

0.64

0.39

0.39

0.64

0.75

0.86

1.50

2.92

3.31

3.11

1.72

0.00

24.75

0.92

0.53

0.50

0.61

0.61

0.11

0.06

0.03

0.28

0.72

0.36

0.14

1.64

2.28

1.36

0.94

0.00

11.08

0.08

0.03

0.03

0.03

0.31

0.00

0.00

0.00

0.08

0.06

0.11

0.17

0.50

0.69

0.53

0.22

0.00

2.83

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.06

0.00

0.03

0.06

0.06

0.03

0.00

0.22

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

8.58

3.31

4.06

4.06

4.53

1.94

1.28

1.69

4.89

4.81

4.72

5.25

10.33

10.17

8.53

5.67

16.19

100.00

7.29

7.84

7.72

8.16

8.78

6.77

6.02

5.03

5.69

6.56

6.41

6.71

8.24

9.84

9.24

8.44

0.00

6.59

TABLE A-t2

NCGUIRE AIR FORCE BASE



DECEMBER FREQUENCY DISTRIBUTION (IN PERCENT)

3720 OBSERVATIONS

WIND SPEED (MPH)


N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

uuvWWW

NW

UMUWJUn

CALM

TOTAL

O

^ 81816CO

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

14.09

14.09

1.18

0.83

0.78

0.51

0.73

0.27

0.43

0.65

0.70

0.83

1.10

1.13

1.18

0.97

0.89

0.83

0.00

13.01

2.47

2.07

1.75

0.91

1.26

0.67

0.54

0.56

1.72

2.39

2.72

2.04

3.95

3.33

2.58

2.10

0.00

31.08

2.04

0.81

0.83

0.46

0.67

0.46

0.24

0.13

0.78

1.34

1.94

1.88

3.52

3.33

2.96

1.42

0.00

22.82

1.05

0.27

0.30

0.11

0.40

0.32

0.03

0.08

0.30

0.40

0.91

1.13

2.45

2.98

1.96

0.62

0.00

13.31

0.13

0.03

0.00

0.03

0.03

0.03

0.00

0.00

0.05

0.05

0.35

0.30

0.75

1.72

0.51

0.40

0.00

4.38

0.03

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.03

0.00

0.00

0.03

0.35

0.59

0.11

0.05

0.00

1.18

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.05

0.08

0.00

0.00

0.00

0.13

6.91

4.01

3.66

2.02

3.09

1.75

1.24

1.42

3.58

5.03

7.02

6.51

12.26

13.01

9.01

5.43

14.09

100.00

7.98

6.24

6.28

5.91

6.72

7.84

5.00

4.41

6.60

6.79

7.95

8.49

9.71

11.57

9.63

8.29

0.00

7.32




ANNUAL FREQUENCY DISTRIBUTION (IN PERCENT)

43823 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-2424-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

sswSW

HSW

W

WNW

NW

UftlUpmw

CALM

O TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

15.26

15.26

1.36

0.68

0.71

0.62

0.87

0.70

0.60

0.76

1.34

1.28

1.16

0.99

1.35

0.89

0.85

0.97

0.00

15.14

3.69

1.75

1.57

1.33

1.83

1.02

0.89

0.97

2.69

2.69

3.11

2.69

3.60

2.71

2.71

2.20

0.00

35.46

2.15

0.95

1.09

1.03

1.24

0.48

0.31

0.30

1.14

1.20

1.36

1.48

2.25

2.20

2.40

1.59

0.00

21.16

0.95

0.28

0.35

0.39

0.45

0.12

0.08

0.06

0.29

0.34

0.48

0.53

1.20

1.54

1.51

1.02

0.00

9.58

0.15

0.08

0.05

0.08

0.11

0.03

0.00

0.01

0.06

0.06

0.13

0.09

0.40

0.77

0.57

0.30

0.00

2.88

0.01

0.00

0.01

0.03

0.01

0.00

0.00

0.00

0.01

0.00

0.01

0.01

0.07

0.21

0.07

0.04

0.00

0.48

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.01

0.02

0.00

0.00

0.00

0.03

8.29

3.74

3.79

3.48

4.50

2.35

1.88

2.10

5.55

5.57

6.25

5.80

8.88

8.34

8.11

6.11

15.26

100.00

7.21

6.84

7.00

7.60

7.13

5.73

5.17

4.83

5.97

6.12

6.58

6.96

8.04

9.93

9.31

8.41

0.00

6.34




SPRING FREQUENCY DISTRIBUTION (IN PERCENT)

11040 OBSERVATIONS

CALM .5-3 3 - 7

WIND SPEED (MPH)

7 -12 12-18 18-24 24-32 >32 TOTAL AVERAGE

N

HUE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

\rnniHUM

MW

NNW

CALH

-^ TOTAL

O 8181bCO

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

11.1111.11

1.06

0.50

0.52

0.45

0.84

0.74

0.53

0.59

1.11

0.91

0.91

0.68

0.97

0.69

0.65

0.79

0.00

11.95

3.05

1.20

1.11

1.35

2.13

1.27

1.08

1.20

2.52

2.17

2.28

1.91

2.97

2.74

3.13

2.04

0.00

32.16

2.55

0.71

0.77

1.29

1.80

0.87

0.60

0.48

1.85

1.61

1.46

1.63

2.50

2.69

2.73

2.25

0.00

25.77

1.34

0.43

0.25

0.60

0.81

0.20

0.16

0.10

0.54

0.63

0.87

0.70

1.48

2.19

2.10

1.41

0.00

13.82

0.36

0.18

0.05

0.15

0.20

0.05

0.00

0.01

0.06

0.14

0.27

0.13

0.49

0.96

0.97

0.47

0.00

4.48

0.02

0.00

0.04

0.11

0.02

0.00

0.00

0.00

0.02

0.00

0.01

0.02

0.05

0.24

0.09

0.06

0.00

0.68

0.00

0.00

0.00

0.01

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.02

0.01

0.00

0.00

0.04

8.38

3.03

2.73

3.96

5.80

3.13

2.37

2.38

6.11

5.46

5.81

5.06

8.46

9.54

9.67

7.02

11.11

100.00

8.43

8.04

7.24

8.95

8.13

6.54

6.15

5.61

7.05

7.54

8.01

8.00

8.94

10.73

10.19

9.57

0.00

7.61




SUMMER FREQUENCY DISTRIBUTION (IN PERCENT)

11039 OBSERVATIONS

CALM .5-3 3 - 7 7 -12

WIND SPEED (MPH)

12-18 18-2424-32 >32 TOTAL AVERAGE

0ooco

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

WSW

W

MNW

NM

NNW

CALH

TOTAL

81816

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

17.66

17.66

1.46

0.62

0.72

0.69

1.10

1.04

0.90

1.18

2.25

2.18

1.61

1.35

1.84

1.29

1.08

1.34

0.00

20.63

3.72

1.58

1.51

1.37

1.95

1.32

1.25

1.30

4.04

4.24

4.65

3.69

4.42

2.91

2.94

2.60

0.00

43.49

1.55

0.74

0.63

0.78

0.80

0.30

0.19

0.25

1.06

1.30

1.35

1.31

1.64

1.05

1.20

0.86

0.00

15.02

0.39

0.07

0.08

0.03

0.06

0.00

0.02

0.02

0.09

0.12

0.21

0.28

0.40

0.35

0.39

0.34

0.00

2.85

0.02

0.00

0.00

0.05

0.01

0.00

0.00

0.00

0.00

0.02

0.02

0.02

0.05

0.07

0.07

0.03

0.00

0.34

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.01

0.00

0.00

0.00

0.00

0.00

0.01

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

7.14

3.01

2.94

2.91

3.91

2.66

2.36

2.75

7.44

7.86

7.84

6.66

8.34

5.67

5.69

5.17

17.66

100.00

6.01

5.82

5.60

5.98

5.20

4.17

4.26

4.04

4.77

5.09

5.44

5.88

5.84

6.12

6.33

5.72

0.00

4.53




AUTUMN FREQUENCY DISTRIBUTION (IN PERCENT)

10920 OBSERVATIONS

WIND SPEED (MPH)

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

swwswwMNW

NWyucjIWfH

CALM

TOTAL

CALM===-3

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

19.01

19.01

. 5 - 3

1.49

0.91

0.99

0.81

0.89

0.61

0.53

0.78

1.27

1.27

1.24

1.14

1.44

0.71

0.82

0.87

0.00

15.77

3 - 7

4.11

2.10

2.23

1.64

1.68

0.90

0.77

0.86

2.74

2.55

3.10

2.95

3.39

2.27

2.15

1.89

0.00

35.32

7 -12

2.04

1.44

1.99

1.43

1.34

0.34

0.18

0.22

0.89

0.75

1.22

1.46

2.01

1.94

2.13

1.26

0.00

20.63

12-18

0.65

0.41

0.66

0.53

0.42

0.06

0.02

0.02

0.17

0.29

0.32

0.29

0.88

1.18

0.95

0.65

0.00

7.52

18-24

0.05

0.08

0.06

0.02

0.15

0.01

0.00

0.00

0.04

0.02

0.07

0.08

0.22

0.36

0.24

0.18

0.00

1.58

24-32

0.00

0.01

0.00

0.02

0.00

0.00

0.00

0.00

0.00

0.00

0.02

0.00

0.04

0.03

0.02

0.02

0.00

0.15

>32

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.02

0.00

0.00

0.00

0.02

TOTAL

8.35

4.95

5.93

4.44

4.48

1.92

1.50

1.88

5.11

4.88

5.96

5.92

7.97

6.51

6.31

4.87

19.01

100.00

AVERAGI

6.50

7.03

7.37

7.39

7.23

5.29

4.45

4.29

5.49

5.60

6.11

6.37

7.29

9.02

8.46

7.81

0.00

5.61

8181b




WINTER FREQUENCY DISTRIBUTION (IN PERCENT)

10824 OBSERVATIONS

CALM .5-3 3 - 7 7 -12

WIND SPEED (MPH)

12-18 18-24 24-32 >32 TOTAL AVERAGE

N

NNE

NE

ENE

E

ESE

SE

SSE

S

SSW

SW

wswW

1AMWWW

NW

MMU*1WW

g CALH

f5 TOTAL

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

13.29

13.29

1.42

0.69

0.64

0.53

0.67

0.39

0.42

0.48

0.73

0.77

0.89

0.80

1.16

0.85

0.85

0.87

0.00

12.16

3.86

2.14

1.45

0.96

1.54

0.60

0.46

0.50

1.46

1.76

2.38

2.21

3.63

2.92

2.62

2.25

0.00

30.76

2.47

0.91

0.98

0.6.1

1.01

0.42

0.29

0.24

0.76

1.11

1.40

1.53

2.85

3.13

3.57

1.98

0.00

23.27

1.41

0.20

0.42

0.39

0.50

0.20

0.10

0.11

0.35

0.30

0.54

0.86

2.05

2.46

2.61

1.70

0.00

14.20

0.16

0.05

0.07

0.11

0.07

0.05

0.01

0.03

0.16

0.08

0.16

0.13

0.86

1.70

0.99

0.54

0.00

5.16

0.01

0.01

0.01

0.01

0.02

0.00

0.00

0.00

0.03

0.00

0.00

0.01

0.18

0.59

0.16

0.06

0.00

1.08

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.05

0.03

0.01

0.00

0.00

0.08

9.33

4.01

3.57

2.62

3.81

1.65

1.28

1.36

3.48

4.02

5.37

5.54

10.78

11.68

10.81

7.40

13.29

100.00

7.68

6.45

7.37

7.72

7.49

7.22

5.85

5.79

7.38

6.86

7.25

7.96

9.61

11.66

10.61

9.59

0.00

7.62

8181b

AVERAGE WIND SPEED 6.34 (MPH)

N

WNW

wsw

NNW

SS

NNE

NE

ENE

ESE

SE

SSE

WIND SPEED CLASSES (MPH)13-18 >18

C 0 0 9 4 9

APPENDIX AMCGUIRE AFB 1981 - 1985

ANNUAL WIND ROSE


N

WNW

WSW

NNW

ss

NNE

NE

ENE

ESE

SE

SSE


000950


WIMDROSE FOR- SPRING


N

WNW

WSW

NW

NNW

ss

NNE

NE

SSE

WIND SPEED CLASSES (MPH)

EKE

. E

ESE

SE

C00951


WINDROSE FOR- SUMMER


N

WNW

wsw

NW

NNW

SS

NNE

NE

ENE

. E

ESE

SE

SSE


000952


WINDROSE FOR- AUTUMN

AVERAGE WIND SPEED 7.6Z (MPH)

N

NW

WNW

WSW

NNW

ss

NNE

NE

SSE

WIND SPEED CLASSES (UPH)

ENE

_ E

ESE

SE

000953


WINDROSE FOR- WINTER


N

NW

WNW

WSW

NNW NNE

SS

NE

3SE


% \ .5-3 *-7 8~12 13"M

EKE

ESE

SE

! 0 0 0 9 5 4


ANNUAL WIND ROSE


N

WNW

WSW

NNW NNE

SS

NE

ENE

ESE

SE

8SE


000955


WINDROSE FOR- SPRING


N

NW

WNW

WSW

NNW NNE

SS

NE

ENE

ESE

8SE

WIND SPEED CLASSES (IIPH)13-18 >18

' 0 0 0 9 5 6


WINDROSE FOR- SUMMER


N

WNW

wsw

NW

NNW

SS

NNE

NE

SSE


ENE

ESE

00095';


WINDROSE FOR- AUTUMN


N

WNW

wsw

NW

NNW

ss

NNE

NE

SSE


ENE

_ E

ESE

SE

C G 0 9 5 8


WINDROSE FOR- WINTER

final! work plan remedial investigation/ feasibility study

Documents