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EXECUTIVE SUMMARY

1. Throughout the draft report, the terms "Operable Unit 2" and"Operable Unit II" are used interchangeably. Forconsistency, the operable unit should be denoted as"Operable Unit 2" throughout the report. Likewise, the term"Operable Unit 1" (not "Operable Unit I") should be usedconsistently throughout the report.

2. Page ES-1, second paragraph. Clarify that the leachatecollected and disposed of off-site is done so through aremoval action performed by Respondents with oversightprovided by the U.S. Environmental Protection Agency (EPA).

3. Page ES-1, second paragraph. Clarify the description of thesite and the description of the Operable Unit 1 and OperableUnit 2 study areas. The Edmonds Creek and Martins/MillCreek marsh areas should be included in the description ofthe Operable Unit 2 study area.

4. Page ES-l, third paragraph. A more detailed description ofEPA's selected remedy for Operable Unit 1 should bepresented.

5. Page ES-1, fourth paragraph. The Raritan River is listed asan area included as part of the Operable Unit 2investigations. Although some sampling was performed at themouths of Edmonds and Martins Creeks at the Raritan River,the river proper was not intensively studied as part of thisRemedial Investigation (RI). In addition, the Low-Lyingarea located between the Kin-Buc I mound and Edison Landfill(Low-Lying area) should be included in a description of theOperable Unit 2 study area, as well as the area incorrectlydescribed throughout this document as "Control Creek." Thiscreek should be referred to as "Unnamed Creek."

6. Page ES-2, first sentence. This sentence should beclarified. The term "groundwater quality in both operableunits" is unclear.

7. Page ES-2, second bullet. Referring to the refuse unit,this bullet states, "This unit is hydraulically isolatedfrom the sand and gravel unit by the low permeability meadowmat, which is continuous throughout the Operable Unit 2study area." However, the meadow mat has not beendemonstrated to be continuous throughout the Operable Unit 2study area. The refuse unit is not hvdraulically isolatedfrom the sand and gravel unit by the meadow mat. The datacollected during this study does not substantiate thisfinding and this statement must be removed from the RIreport.

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The last statement in this bullet indicates that groundwaterin the refuse unit flows toward Pool C and the RaritanRiver. This statement must be clarified. Since the RaritanRiver flows around the site, groundwater flow directionsshould be clearly identified. In addition, it is unclearwhether groundwater in the refuse unit of Mound B flows inthe same direction as groundwater in the refuse unitunderlying the Kin-Buc I and II mounds, or the refuse unitunderlying the Low-Lying area.

8. Page ES-2, third bullet. The term "low permeabilitybedrock" is also misleading and inappropriate. The bedrockunderlying the site is fractured bedrock and should bedescribed as such. Fractured bedrock is permeable.

9. Page ES-3, second bullet. This bullet states, "Thepredominant constituents associated with industrial wastedisposal at the site in terms of concentration anddistribution, are aromatic VOCs and BNAs." The informationupon which this statement is based must be provided. Thedraft RI Report presents findings of elevated PCB and metalsconcentrations, as well as VOCs and BNAs concentrationsthroughout the study area.

The last sentence in this bullet states, "These constituentsappear to have originated from within Operable Unit 1 andhave migrated toward Mound B and the Raritan." The term"within Operable Unit 1" should be clarified. There is arefuse unit located in the Kin-Buc I and II mounds, the Low-Lying area, and Mound B. The separate refuse units anddirection of groundwater flow within each refuse unit shouldbe clearly differentiated.

10. Page ES-3, third bullet, first sentence. Remove the word"much."

The second sentence states that site hydraulics suggest thatcontaminants have potentially migrated from the EdisonLandfill toward Mound B and the Raritan. This statementcannot be substantiated based on data collected during theOperable Unit 2 RI and should be deleted from this report.

11. Page ES-3, fourth bullet. Remove the statement regardingthe contribution to groundwater contamination from EdisonLandfill. As described in Comment 11, above, this statementcannot be substantiated.

12. Page ES-3 - ES-4, fifth bullet. Provide the criteria usedto support the statement that VOCs were detected in "tracelevels" in the Pool C connecting channel to Edmonds Creekand that the VOCs wdo not appear to alter the water quality

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in Edmonds Creek." Since the VOCs detected are notnaturally occurring chemical substances in the connectingchannel, their presence, in any amount, indicates that waterquality has been altered. Therefore, this conclusion mustbe removed from the report.

Clarify what is meant by the statement, "Other intermittentsurface water discharges are more diverse, consisting ofoverland runoff to the Raritan River and tributaries."

13. Page ES-4, first bullet. This bullet includes thestatement, "Attributability of metals detected in sedimentsto Pool C or Kin-Buc I was not confirmed." EPA does notagree with this statement. Metals were detected in elevatedlevels in sediment and biota sampled in the EdmondsCreek/Marsh area. Therefore, this statement is notconsistent with the findings of the study. A more accurateconclusion should be formed based on the findings.

14. Page ES-4, second bullet. This bullet states, "Sediments inMill Brook/Martins Creek do not exhibit evidence ofcontamination attributable to the Kin-Buc site, althoughthere is evidence of PAH deposition at the mouth of thiscreek from its urban and industrial watershed." PAHs weredetected in sediment and groundwater throughout the Kin-Bucstudy area. This conclusion is not supportable based on thefinding of the RI, and therefore, should be modified, orremoved from the report.

15. Page ES-4, third bullet. Respondents have been informed byEPA, on multiple occasions, that the so called "ControlCreek" is not a "control" creek, as it is locateddowngradient of the site, and may be subject to site relatedcontamination. Respondents have been instructed to refer tothis portion of the study area as "Unnamed Creek." EPAtakes exception to Respondents failure to incorporate thiscomment which has been made in writing as well as verballyby EPA. All references to "Control Creek" made throughoutthis report must be changed to "Unnamed Creek."

The "Control Creek" should be referred to as a referencesite. The use of the term "background" infers thatsufficient data exists to determine that this location isrepresentative of uncontaminated conditions in the RaritanRiver basin. It has not been demonstrated that "background"data exists or has been collected. To do so would require •*basin wide sampling. n

This bullet further states, "Only the PCBs detected in biota gfrom the Edmonds Creek/Marsh demonstrate any attributability ^to PCBs in sediments, indicating that there are othersources of PCBs in the Raritan River watershed." The manner °too

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in which the biota study was performed limits theconclusions which can be reached. No basis has beenprovided to support this statement. A clarification isrequired.

16. Page ES-4, fourth bullet. This bullet states, "Additional[sic] background sources of PCBs in the water and diet aresuggested by the widespread occurrence of PCBs in biotacollected from non-impacted areas.1* Specify these "non-impacted areas." Since the Operable Unit 2 RI did notcontain a control area, this conclusion is unfounded.

17. Page ES-4, fifth bullet. This bullet states, "PCB levels inbiological tissue are not directly related to sediment PCBconcentrations in the study area." Respondents study wasnot performed in such a manner as to support thisconclusion. Quality assurance considerations, which wererelayed in detail to Respondents in EPA's November 9, 1990letter, must be included in the RI report. Theseconsiderations must be taken into account in formingconclusions with respect to the biota portion of theOperable Unit 2 RI.

This finding also states that, "Most of the PCB mass load in IEdmonds Creek/Marsh is effectively bound to sediment organicjcarbon, thereby eliminating bioavailability." Many factorslimit bioavailability, but all of these factors are subjectto change. The concentrations detected at the site are suchthat a portion of the PCBs are bioavailable, as demonstratedvery conclusively by the biota data collected. Thesediments will continually serve as a source ofcontamination to biota.

18. Page ES-4, sixth bullet. The conclusion presented in thisbullet, that four metals (cadmium, chromium, lead andmercury) sampled for in biological tissue did notdemonstrate attributability to site derived sedimentcontamination is unfounded. This statement must be removedfrom the report.

CHAPTER 1.0 INTRODUCTION

19. Page 1-1, first paragraph, first sentence. "Amended Order"should be "Administrative Order, Docket No. II-CERCLA-30102, amended March 28, 1986 and September 21, 1990, DocketNo. II-CERCLA-60105 and Index No. II-CERCLA-00114 , arespectively." °

Remove the second sentence. o

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1.1 Purpose

20. Pages 1-1 - 1-2. The study areas in the two operable unitRIs should be further clarified. For example, groundwaterunderlying the site was studied as part of the Operable Unit1 RI and further studied in the Operable Unit 2 RI. Inaddition, the Low-Lying Area was studied in the OperableUnit 2 RI, but is not listed as such in this section.

1.2 Site Background

21. Page 1-2, Section 1.2.1, Site Description, second paragraph.The term "cap elevation" is used to describe the elevationof Mound B, but not the elevation of Kin-Buc I or Kin-BucII. The difference between the "cap elevation" and the"maximum elevation" should be clarified.

22. Page 1-2, Section 1.2.1, third paragraph. "Lagoons A, B,and C" should be referred to as "Pits A, B, and C," as theyare referred to in the Operable Unit 1 ROD.

Replace "tide" with "tidal."

23. Page 1-3, Section 1.2.2, Site History, third paragraph,third sentence. Provide the name of the entity that filedthe mentioned lawsuit.

Third paragraph, fourth sentence. Provide the depth of theclay caps on both Kin-Buc I and Kin-Buc II.

24. Pages 1-3, Section 1.2.2, fourth paragraph (continued onpage 1-4), fourth sentence. State that the removal actionis ongoing and is currently performed by Respondents underEPA oversight.

Page 1-4, first sentence. Replace the phrase, "issued aunilateral CERCLA order against," with "issued a unilateraladministrative order pursuant to the ComprehensiveEnvironmental Response, Compensation and Liability Act of1980 (CERCLA) to..."

25. Page 1-4, Section 1.2.2, first full paragraph, secondsentence. Clarify that EPA's unilateral order was issued to ^twelve potentially responsible parties, not only Kin-Buc, CDInc. and SCA Services, Inc. °

Third sentence. Note that the ROD was signed by EPA in oSeptember 1988. M

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1.3 Report Organization

26. Page 1-5, seventh sentence. The Endangerment Assessmentwill be conducted by EPA. The contractor performing thistask for EPA need not be noted in this section. Inaddition, Chapter 7 should not be set aside for insertion ofthe Endangerment Assessment. Rather than inserting theEndangerment Assessment as Chapter 7, it will remain aseparate document that is only referred to in the RI Report.

CHAPTER 2.0 PHYSICAL CHARACTERISTICS OF THE STUDY AREA

2.1 Surface Features

27. Page 2-1, first paragraph. In addition to Kin-Buc I, Kin-Buc II and Mound B, there is also refuse underlying the Low-Lying area. This should be added to this section.

28. Page 2-1, second paragraph, first sentence. It is statedthat an above ground tank farm at the site was "previouslyreferred to as the EPA facility.11 On all the mapspresented in this report, an area located between Kin-Buc Iand Edison Landfill is referred to as "EPA Facility.11Respondents incorrectly state that they have "previously"referred to this area as "EPA Facility" while they arecurrently referring to the area in that manner. Moreimportantly, EPA does not currently operate any facility onthe site. Therefore, all maps, as well as text, included inthe RI Report must be revised to denote this area in a moreaccurate manner.

Second sentence. Remove the word "natural."

29. Page 2-1, third paragraph, second sentence. See the abovecomment referring to the use of the term "Control Creek."

30. Page 2-2, Mound B. Describe the current condition of theexisting cap on Mound B. Recently, representatives of EPAand the New Jersey Department of Environmental Protection

. (NJDEP) have observed exposed refuse along significantportions of the sideslope of Mound B along the RaritanRiver. Further, some of the exposed refuse surface appearedto be below the high water mark for the river. This shouldbe discussed in the description of Mound B. ^

o31. Page 2-2, Low-Lying Area. This section states, "The natureof the refuse material is unknown." The RI report does not 0give the history, or even state that this area is known to ohave been used for landfilling. Additional background M

information regarding waste disposal in the Low-Lying area 0to

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should be provided.

32. Page 2-2, Mill Brook/Martins Creek. Tidal influences onthis stream system should be described.

Also, it is stated that no direct leachate seeps visiblyemanate from any landfilled areas into Mill Brook/MartinsCreek. While this may be currently true, it must be notedthat leachate seeps were identified in the past from thesite into Mill Brook/Martins Creek.

33. Page 2-3, Wetlands. The term "mosquito channels" should bechanged to "drainage channels" throughout the report forconsistency.

2.2 Surface Water and Drainage

34. Page 2-3, second paragraph, third sentence. Describe wherethe "toe" of the Edison Landfill is located.

2.3 Land Use and Demography

35. Page 2-4, second paragraph, first sentence. It should benoted that the ILR Landfill is not currently in operation.

Second paragraph, third sentence. The direction of EdgeboroLandfill with respect to the site should be given.

>\Jtv'v/w' jV*̂ , This section should characterize human populationsO^ t*^ potentially exposed to contaminants released from the site.

^'^ \v Information should include location and use of surface^..^^ waters (i.e. drinking water intakes, distribution and

L> recreational areas) and local groundwater use.

2.4 Environmental Setting

36. Page 2-4. This section is inadequate as it is only a surveyand not an assessment. The introductory statement shouldreference Appendix A, the Ecological Inventory Report. Itshould be noted that Terrestrial Environmental Specialists,Inc. (TES) performed activities at the site undersubcontract to Wehran Engineering, Inc.

37. Page 2-5 - 2-6, Section 2.4.1, Vegetation, EmergentWetlands. It is reported in the Draft RI Report that bigcordgrass (Spartina cynosuroidesl replaces common reedfPhraomites australis) in several locations near the edges j*of Edmonds Creek. Field verification of this statement was nmade during the January 1991 sampling in the EdmondsCreek/Marsh area. In some locations, big cordgrass is the gdominant plant, but in others it mixes with narrowleaf )->cattail. It was observed that big cordgrass occurred in

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Edmonds Creek to just past the discharge to Pool C. In thelower reaches of Edmonds Creek, smooth cordgrass (Soartinaalterniflora) was observed to form a thin vegetative linealong the marsh bank just below the Phragmites.

During the January 1991 field investigations, it was alsoobserved that the lower elevation areas of upper EdmondsCreek are dominated by narrowleaf cattail (Typhaanoustifolia). Several smaller areas of narrowleaf cattailwere observed adjacent to the banks of Edmonds Creek,including one area above where the discharge from Pool Centers Edmonds Creek.

Based on these observations, Figure 2-1, Vegetative CoverTypes should be revised.

38. .Page 2-6, Section 2.4.2, Wildlife, Invertebrates. Thisj? section states that blue crabs were not abundant and that no

, - ic* grass shrimp were caught in the Martins Creek area. TheseVfT ̂ statements are misleading. In fact, August is a time of"* "-V^Apeak abundance for blue crabs and the Raritan River is

•^A heavily utilized by this species. Due to the time of year; that the sampling was performed and the limited sampling

effort, these statements cannot be substantiated and shouldbe removed or qualified by providing the time of year ofsampling and the frequency of sampling events.

Similarly, mummichogs were reported to be the mostfrequently caught fish. However, it is not stated if anyother capture techniques besides minnow traps wereattempted. If this was the only equipment utilized todetermine which fish species inhabit the study area,additional information needs to be supplied to support theconclusion made.

39. Page 2-9, Section 2.4.2, Wildlife, Birds. This section ismisleading in that it appears to minimize the study area'shabitat value to birds. Considering the minimal level ofsampling effort put forth in this survey, the statement,"The dominance of Phraomites in some areas does, however,reduce the value of the wetlands to birds.1* cannot besubstantiated.

40. Table 2-2, Avifauna Observed in the Study Area.

a. Omissions and inaccuracies exist in Table 2-2. The ™Table appears to have been adapted from a tableprovided in Appendix A of the Draft RI Report, "An oEcological Inventory of the Kin-Buc Site," prepared by 3TES for Wehran. The table as it appears in Appendix A,has a column for birds observed at Kin-Buc I and Kin- oBuc II. Table 2-2 does not have this column. Fourteen £

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species were observed at Kin-Buc I and Kin-Buc II, ofwhich the following were noted to breed: mallard, ring-necked pheasant, song sparrow and red-winged blackbird.Of particular concern is the column in Table 2-2entitled "Emergent Wetland," which is believed to bethe Edmonds Creek/Marsh ecosystem, does not listspecies observed by TES as noted in an August 30, 1989letter to EPA from Wehran. Twenty bird species wereincluded in that letter which are not listed on Table2-2. All omitted species must be included on thistable. Also of concern, is that representatives of theU.S. Fish and Wildlife Service (FWS), during onlycursory visits to the site, observed the followingbirds: osprey in the Edmonds Creek/Marsh area, andmallard, mourning dove, and belted kingfisher in theMartins Creek area.

b. Page 2-10, first full paragraph. This paragraph statesthat there is an absence of certain ground-nestingwetland species on site. The paragraph further statesthat this is due to predator activity of rats, cats,dogs, and skunk. No supporting information is givenfor this conclusion. Supporting information must besupplied, especially in view of the statement on page19 of Appendix A, indicating that ring-necked pheasantsare ground-nesting in the area between Kin-Buc I andKin-Buc II.

The revised RI Report should note the followingwildlife resources observed utilizing the EdmondsCreek/Marsh and adjacent areas during the January 1991marsh sampling event:

- mergansers, species unknown (but probably commonmerganser), were observed diving in the RaritanRiver from the area of Mound B around to the mouthof Edmonds Creek;

three red-tailed hawks were perched in the treeson the berm adjacent to the Unnamed Ditch, and twowere hunting in the grassy area of Mound B;

one marsh hawk was hunting the marsh between theEdison Township Landfill and the Raritan River;

?3five mallards or black ducks were observed briefly toin the Unnamed Ditch; and n

a belted kingfisher was observed flying over the oEdmonds Creek/Marsh area heading toward the bermadjacent to the Unnamed Ditch. o

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41. Page 2-14, Section 2.4.3, Critical Wildlife of SpecialAreas, and Threatened or Endangered Species. This sectionshould be revised to include a discussion of federalendangered or threatened species and critical habitats, andshould make clear the distinction between federal and stateconcerns. Documentation from both state and federalagencies establishing the presence or absence of suchspecies should be included in the report.

42. Page 2-15, Section 2.4.4, Wetlands. The use of the NationalWetlands Inventory (NWI) maps is not sufficient for wetlandsdelineation. NWI maps can only be used as baseline

<° information in determining the extent of wetland areas. Aj. wetlands delineation of the entire site must be performed^ sT using the approved methodology in the "Federal Manual forv v Identifying and Delineating Jurisdictional Wetlands"// (January 1989). In addition, a wetland functional value/ assessment employing the Corps of Engineers Wetland

Evaluation Technique (WET) should be done. Areas that maybe impacted by remedial actions should also be included inthe delineation. An analysis of impacts to the wetland fromthe site should be developed and included in the text.

43. Page 2-15, Section 2.4.5, Floodplains. Figure 2-3 and thetext on page 2-15 delineate the 100-year floodplain.However, the 500-year floodplain is of concern. Respondentsmust delineate the 500-year floodplain. In addition, afloodplain assessment which addresses impact from the sitemust be performed. The 500-year floodplain delineation andassessment must be included in this section.

Please note that an analyses of impacts on the wetlands and500-year floodplains from remedial alternatives should bepresented in the feasibility study to be prepared byRespondents.

44. Appendix A should contained detailed, large-scale maps thatadequately delineate the various habitats, including allwetland areas, and the distribution of the various wildlifespecies. The existing maps are not adequate.

CHAPTER 3.0 REMEDIAL INVESTIGATION ACTIVITIES

3.1 Hvdroaeoloaic Investigation

45. Page 3-5, Section 3.1.3, Existing Monitoring Well Inventory,paragraph three. This paragraph states that Appendix Bcontains the existing well inventory along with conclusionsand recommendations. Appendix B lists specifications forthe existing wells. The depths of the wells recorded by

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Wehran and GeoEngineering are comparable, however, theelevations differ significantly. The reference point forelevations of the GeoEngineering wells should be noted.

46. Table 3-3, Summary of Drilling Activities Performed underOperable Unit 1 RD/RA. Samples from the top and bottomdeposits of the meadow mat were collected from borings HE-A-32E, WE-A-35-E, and WE-A-36-E. These samples are notrepresentative of the entire meadow mat. The meadow mat isa heterogeneous unit, with varying composition. Theanalytical parameters for which these boring samples wereanalyzed are not specified here. Conclusions regarding thecontinuity of the meadow mat cannot be made based on thisinformation.

47. Page 3-13, Section, 3.1.5.1, Test Borings, second fullparagraph. A summary of HNu readings and/or headspaceanalysis does not appear in Appendix D, as stated in thisparagraph.

48. Page 3-16, Section 3.1.5.2, Monitoring Well Installation,first paragraph. The text states that the refuse wells weresecured using 8-inch ID steel protective casings. However,Figure 3-7 indicates that 4 or 6 inch steel protectivecasings were used. This discrepancy must be addressed.

49. Table 3-4. The monitoring well WE-7S screened intervaldepth should read 24.0-29.0.

50. Page 3-17, Section 3.1.5.3, Decontamination. Thedecontamination pads are not located on the base map (Sheet1 of 5), as stated in this section. The map must be revisedto include the decontamination pads.

51. Page 3-25, Section 3.1.9, Surface Water Gauge Installation.It should be noted in this section that the stream gaugesand pressure transducers in Mill Brook/Martins Creek andEdmonds Creek had to be reestablished on at least oneoccasion due to flooding.

3.2 Sampling and Analysis

52. Page 3-31, Section 3.2.1, Sediment. The pH values for theRaritan River water samples were not provided in the data.These pH levels should be compared to the pH levels in the „Edmonds Creek/Marsh area. Changes in the pH levels at the DOmouth of Edmonds Creek may influence metals concentrationsin the sediment. Sediment samples collected at the mouth of 0Edmonds Creek indicate that metal (as well as PCB) oconcentrations are higher on the downstream side (location l~lRR3) at the mouth of Edmonds Creek compared to the upstream oside (location RR4). These results do not exclude Pool C co

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and the Edmonds Creek/Marsh area as sources of metalscontamination at the mouth of Edmonds Creek. The highermetals concentrations at the mouth of Edmonds Creek may alsoresult from a decrease in stream velocity at this point,which could allow more suspended sediments to settle out.The report should address these possible scenarios.

53. Page 3-32, Section 3.2.1, Sediment, first paragraph. Itmust be noted that samples collected for VOC analysis werecollected prior to homogenization.

-54. Page 3-33, Section 3.2.3, Biota. This section must discussproblems encountered with respect to Respondents performanceof the biota study as specified in EPA's November 9, 1990letter, as well as other letters to Respondents. It muststate that in December 1990 and January 1991, EPA performedadditional biota studies which will be used to fully assessimpact on site contamination on biota, and be incorporatedin to the FS.

55. Page 3-33, Section 3.2.3.1, Breeding Bird Study. Thissection should present or reference the details and findingsof the Breeding Bird Study performed.

56. Page 3-34, Section 3.2.3.2, Specimen Collection, FiddlerCrab. This section should discuss that sampling of fiddlercrab was attempted in Fall 1989 in Mill Brook/Martins Creek,but the species was not observed at that time. In June1990, EPA observed that fiddler crabs were abundant in thisarea. Based on that observation, fiddler crabs were sampledby both EPA and Respondents in July 1990. The results ofthat sampling event must be presented in this report. Inaddition, the further fiddler crab sampling should beindicated on Figure 3-14.

57. Page 3-36, Section 3.2,3.3, Tissue Analysis.

The three goals of this aspect of the study, listed on page3-36, were not adequately met. The shortcomings of thetissue analysis performed by Respondents, as specified inEPA's November 9, 1990 letter and prior letters toRespondents, must be discussed in this section.

08First full paragraph on page 3-36, first sentence. This osentence states, "All species were analyzed for PCBs, whichare the contaminants of primary concern in the study area." °It is inappropriate for Respondents to make this Mdetermination at this time. The contaminants of "primaryconcern" will be determined by EPA in the Risk Assessment °for the site based on the data collected. EPA is concerned Mnot only with PCBs in biota, but also metals and PAHs, which ^were detected in sediment throughout the study area. This

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statement should be removed from the text.

The last paragraph in this section is incorrect and must beclarified. EPA recommended that tissue analysis includevarious metals as parameters based on their detectionthroughout the study area.

58. Page 3-36, Section 3.2.3.3, Tissue Analysis, Fiddler Crabs.The text should include a discussion of the problemsidentified by EPA with respect to the fiddler crab sampling,including the large study areas and the fact that biotaresults could not be tied into sediment results as thesampling took place at different times and the study areaswere so large.

This section states that fiddler crabs were not found inMartins Creek/Mill Brook. This is not correct. Crabs werefound and samples collected by both EPA and Respondents inthis area in July 1990.

59. Page 3-37, Section 3.2.3.3, Tissue Analysis, Muskrat.Compositing procedures were inadequate. Additional detailsregarding the tissue analysis on muskrat samples must beadded to this section including, but not limited to, therationale for the compositing of tissue, holdings timeswhich were exceeded, and other issues discussed in EPA'sNovember 9, 1990 letter to Respondents as well as priorcorrespondence regarding the biota study.

60. Page 3-39, Section 3.2.4, Groundwater, second paragraph,first sentence. This sentence mentions samples split with"COM." It should be clarified that CDM-FPC, Inc. is EPA'soversight contractor for the project.

61. Page 3-41, Section 3.2.5, Meadow Mat. As stated above, thesix split spoon samples from three borings in the meadow matunderlying the site are not sufficient to form a conclusionwith respect to the continuity and capacity for confining ofthe meadow mat throughout the study area.

CHAPTER 4.0 HYDROGEOLOGY

4.1 Site Geology——— ——— --T ^

(a62. Table 4-1, Summary of Laboratory Test Results of Selected n

Soil Samples. oo

a. Page 1 of 8. The table should clearly differentiate "-1samples which were not tested for Atterberg limits fromsamples that were tested and found to be non-plastic. °

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b. Page 2 of 8. Meadow mat samples from boring WE-6R arenot reported. This table must be amended to add thissample.

c. Page 4 of 8. Clarify why two samples were collectedfor analysis at an interval of 24.5-26.5 feet (samplesare designated as A and B) . This should be explainedon the table, in the logs and in the text.

d. Page 7 of 8. The description of the meadow mat samplescollected from WE -A borings, located adjacent to Kin-Buc I, are consistently more clay-rich than othermeadow mat samples analyzed. The meadow mat appears tobe more diverse in Mound B and the Low-Lying area thanat the toe of Kin-buc I. Therefore, the WE -A boringdescriptions may not be representative of the OperableUnit 2 study area. For example, the meadow mat isdescribed as "peat" in WE-3R, "sand" in WE-7S and"silty sand with gravel" in WE-7s at a lower depth.

e. The Appendix D test borings and monitoring wellconstruction diagrams were reviewed with this table.Many logs do not indicate where samples were collectedfrom the split spoon for laboratory analysis. Explainwhether the selection was performed subsequent to thedrilling. Not all split spoons appear to be describedin the logs (i.e. gaps in the log for WE-7R) . Inaddition, many logs were illegible.

63. Page 4-3, Section 4.1.1, Stratigraphy. The three "majorOperable Unit 2 component study areas" are listed as MoundB, Low- Lying area, and Pool C areas. Describe what is meantby the term, "component study areas."

64. Page 4-3, Section 4.1.1, Stratigraphy, Cover Soils.

It should be noted that during Operable Unit 2 fieldactivities, EPA's oversight contractor, CDM-FPC observedrefuse at the surface of the Low-Lying area. Therefore, thesoil cover is not ubiquitous.

Page 4-4, the first paragraph states, "This difference incover soil material has been attributed to the use of sandyloam as cover on the Edison Landfill property while clayfill was mainly used as cover on the Kin-Buc property (AGES1983)." Provide the basis of this statement. Explain howRespondents arrived at the conclusion that loam from theEdison Landfill is present over "much of the low-lyingarea . "

65. Page 4-7, Section 4.1.1, Stratigraphy, Meadow Mat Deposits.o(O

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COM. Page 4-7, second full paragraph, last sentence. It isstated that "It is not uncommon to find a foreign piece ofrefuse at depth within the "undisturbed" meadow matdeposits... " This statement, in addition to the fact thatthe meadow mat is not continuous under the site, is contraryto the characterization of the meadow mat throughout thisreport as "confining," "semi-confining," "undisturbed," etc.These characterizations are incorrect and must be removedfrom each section of the report where they have beenapplied. Information regarding the meadow mat and itsproperties should be presented in this section of thereport. In other sections of the report, the meadow matshould simply be referred to as the "meadow mat" withoutfurther description.

66. Page 4-12, Section 4.1.2, Stratigraphic Correlation. Thereis insufficient data to support the contention that meadowmat materials completely cover the sand and gravel unitthroughout the site. It is true that a meadow mat layer wasencountered in all boreholes in the Mound B and Low-Lyingareas but there is no data for the area where these unitssupposedly pinch out against bedrock (somewhere under theKin-Buc I mound). The logs for the GV wells in Appendix Dare illegible and do not add any information. Although thecontour and isopach maps in the report show the meadow matextending further north than the sand and gravel unit, andtherefore essentially sealing it from the refuse, thesecontours are based on minimal data and are subjectivelyplaced. As the dashed lines on cross section F-F show,there is no available data on the subsurface geology underthe Kin-Buc I mound, neither for the meadow mat and sand andgravel units nor the residual soils overlying the bedrock.Therefore, it cannot be concluded that under the Kin-Buc Imound, the refuse is always underlain by bedrock and theresidual soil/clay of the meadow mat. This must be madevery clear in the report.

67. Page 4-13, Section 4.1.3, Spacial Variation of StratigraphicUnits, Refuse Unit. Provide the status of the "1990 aerialsurvey" which will be used in the development of a new basemap for the site.

This section states that the isopach contours were developedsolely from the Operable Unit 2 RI data. However, Note 1 onFigure 4-4 indicates that Wehran used data from gGeoEngineering's 1984 draft RI report. Clarify this odiscrepancy.

oIn addition, this section also states (page 4-14, first 2paragraph, last sentence) that "Exposures of refuse alongthe banks of Mill Brook/Martins Creek and the Raritan River oindicate that the areas north and south of Mound B also £2

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received refuse to some extent." This sentence seems toimply that refuse is found outside the "boundary" of MoundB. Specify how the "boundary" of Mound B was originallydelineated. These areas north and south of Mound B whichhave received refuse should be considered part of Mound B.

68. Page 4-15, Section 4.1.3, Spacial Variation of StratigraphicUnits, Meadow Mat Deposits, second and third fullparagraphs. The second full paragraph states that thethickness of the meadow mat underneath Kin-Buc I wasinferred from the structural contour maps, cross sectionsand data points measured outside the mound area. There isnot enough data to "infer" the thickness of the meadow matunderlying the Kin-Buc I mound. There are only two datapoints (GEI-8R and GEI-9R) between the Low-Lying area to thesouth and Kin-Buc II to the north. There is only one datapoint to the north (OU2 wells) . Therefore, this portion ofthe isopach maps is largely speculative. This must beclarified in the text.

The third full paragraph on Page 4-15 states that the meadowmat unit appears to be continuous beneath the Operable Unit2 study area. Regardless of this conclusion, the meadow mathas been demonstrated to be discontinuous beneath the entiresite and it therefore, does not act as a confining unit inany way. The use of the term "semi-confining unit" todescribe the meadow mat is misleading. If a unit is notcompletely a confining unit, unconfined conditions exist andthere may be transport of contaminants between units. Thestudy of the meadow mat along with the results ofgroundwater analysis in the different units underlying thesite, demonstrate clearly that the meadow mat is not aconfining unit, and groundwater contamination continues tomigrate downward from the refuse unit to the sand and gravelunit and to the bedrock unit.

4.2 Hvdroaeoloaic Conditions

69. Page 4-20, third paragraph, Section 4.2.1, GroundwaterOccurrence and Movement. The meadow mat unit is describedas "confining/semi confining." Please refer to commentslisted above regarding the meadow mat. In light of thosecomments, the meadow mat is not considered "confining" bythe Agency. The term "semi-confining" is misleading. Aunit which is not truly confining should not be described as"semi confining."

70. Section 4.2.1, Groundwater Occurrence and Movement, RefuseHydrostratigraphic Unit.

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a. Page 4-22, third paragraph. Conclusions are made herewith respect to flow from Edison Landfill. There areno wells on Edison Landfill. In addition, thesubsurface geology and groundwater elevations and flowpatterns underlying Edison Landfill have not beenstudied. These statements are unfounded and must beeliminated from the text.

b. Page 4-23, second paragraph. This paragraph statesthat the meadow mat is "probably continuous" beneaththe refuse unit. From the water level measurementscollected during the study, it appears that the refuseunit is separated from the underlying units throughoutthe area influenced by tidal effects in portions ofMound B, Pool C and the Low-Lying area. This does notinfer that the meadow mat is continuous in other areas,such as in the vicinity of the southern portion of Kin-Buc I.

c. This section states that the groundwater moves eithereast toward Pool C or west toward the Raritan River,creating a groundwater divide which suggests that theremay be a potential for stagnation or "no flow" zones toexist in portions of the Low-Lying area. There arehowever, other potential scenarios for groundwater flowbeneath the Low-Lying area. The 12 foot contour, asdepicted in Figure 4-7 could just as easily been drawnjoined under the Edison Landfill, thus extending thegroundwater mound and the potential for radial flowsouth (in the direction of Edison Landfill) .

71. Section 4.2.1, Groundwater Occurrence and Movement, MeadowMat Hydrostratigraphic Unit.

a. Page 4-23, first paragraph. See the above commentsregarding the meadow mat.

b. Page 4-24, second paragraph. This paragraph states "Infine-grained low permeable deposits such as the meadowmat, groundwater typically exhibits high verticalgradients (downward) . " A basis for this statementshould be provided. In addition, it should be notedthat in the areas where the meadow mat is thin, andwhere refuse is present in the meadow mat, there ispotential for downward migration of contaminants.

72. Section 4.2.1, Groundwater Occurrence and Movement, Bedrock ^Hydrostratigraphic Unit. 0

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Page 4-27, second paragraph. This paragraph states, "Thebedrock aquifer is primarily confined or semi-confined." OnPage 4-28, the first paragraph states, "...the bedrock isunconfined in the northwest portion of the site..." Theterm "semi-confined" is unclear and should be furtherexplained. In addition, the areas of the site which areconfined and unconfined should be clearly indicated.

73. Table 4-6, Summary of Laboratory Permeability Test Results.No samples of the more "peat-like" meadow mat were testedfor permeability. Samples listed in this table reflect themore clay-rich and sand/clay meadow mat. As notedpreviously, the meadow mat is heterogeneous. Therefore, thedata presented on this table may not be representative ofthe entire meadow mat. This should be noted in this sectionof the report.

74. Page 4-33, Section 4.2.3, Tidal Effects, Refuse. Thissection concludes that the lack of tidal influence in therefuse unit suggests that the meadow mat is an aguitard andis continuous in the Operable Unit 2 study area. Thisstatement cannot be completely substantiated based on thedata collected during the Operable Unit 2 RI, and should beremoved from the report.

75. Page 4-35, second paragraph, Section 4.2.3, Tidal Effects,Surface Water. This section states that Edmonds Creek isnot in hydraulic connection with the refuse or the sand andgravel aquifers due to the presence of the meadow mat. Thisstatement is not adequately supported. Additionalinformation must be presented to support this conclusion.

76. Page 4-36, Section 4.2.4, Vertical Flow Components,Refuse/Sand and Gravel Aquifer Systems. It states here thata substantial downward vertical gradient exists betweenthese two units indicating the potential for downwardgroundwater flow. Note that this conclusion is consistentwith the groundwater analysis which indicates similar typesof contaminants in these two units.

The last paragraph in this section (Page 4-37) makesunacceptable statements regarding the meadow mat. Pleaserevise this paragraph in accordance with the above-listedcomments relating to the meadow mat.

77. Page 4-38, Section 4.2.4, Vertical Flow Components, Sand andGrave I/ Bedrock Aquifer Systems. The last sentence in thelast paragraph in this section states, "Although minor, theupward flow component will impede vertical migration ofcontaminants providing a safeguard for the bedrock aquifersystem from contamination associated with the sand andgravel." This statement is unclear. Provide further

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support and clarification.

78. Page 4-39, Section 4.2,5, Conceptual Model of GroundwaterFlow, Refuse Aquifer. Remove the word "indirectly" in thesecond paragraph, third sentence.

79. Page 4-40, first paragraph, Section 4.2,5, Conceptual Modelof Groundwater Flow, Sand and Gravel Aquifer. Thisparagraph states, "The sand and gravel aquifer also receivesminor recharge from the meadow mat aquitard which acts as aleaky confining layer slowly recharging the sand and gravelover a long time period." This statement is contrary toprevious statements made in which the meadow mat isdescribed as a confining unit. Please refer to above listedcomments regarding the meadow mat in revising thisstatement.

CHAPTER 5.0 NATURE AND EXTENT OF CONTAMINATION

5.1 Source Characterization

80. Page 5-1.

a. It is incorrectly stated that sediments, the Low-Lyingarea and Edison Landfill were studied as part of theOperable Unit 1 RI.

b. Paragraph 2. The cap over Kin-Buc I and the "lowpermeability cover materials" over Kin-Buc II arediscussed. The years that these features were placedon the mounds should be specified. The last sentencein this paragraph is not complete. Kin-Buc I was notonly identified in the Operable Unit 1 RI to be thesource of volatile contamination, but also a source ofother types of contamination including metals and PCBs.

5.2 Background Environmental Quality

81. Page 5-2, Section 5.2.1, Groundwater. This paragraph statesthat determining background water quality at the Kin-Bucsite would be difficult to accomplish. EPA agrees, however,it is further stated that groundwater in the refuse unitwould be equivalent to landfill leachate even in the absenceof the Kin-Buc landfills. This statement is without basis, xand must be removed from the report. o

PZ-5 is a piezometer, not a well. The report must note thatone upgradient piezometer is not sufficient to fullycharacterize the upgradient groundwater quality at thissite.

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82. Page 5-3, third paragraph, Section 5.2.2, Surface Water andSediments. Sampling data collected from sediment and biotain the "Control Creek" area was not intended to be used todefine background conditions. Respondents have beendirected that contaminant levels in the Kin-Buc study areamay be compared to levels detected in "Control Creek," butnot the "Control Creek" data may not be used to representbackground conditions. Control Creek is locateddowngradient of the Kin-Buc site and is potentially subjectto the influence of the site.

Samples collected from the Unnamed Ditch cannot beconsidered as background samples. The statements whichcontend that the samples collected in the Unnamed Ditch arebackground samples must be deleted.

Additional sources which should have been utilized forinformation on levels of contaminants in the Raritan Riversystem are: the New Jersey Department of EnvironmentalProtection, the National Oceanic and AtmosphericAdministration, Rutgers University and other colleges.

5.3 Groundwater

83. Section 5.3.1.1, Refuse Wells, Organics.

a. Page 5-4, second paragraph. The text states thatmethylene chloride, acetone and 2-butanone were foundin associated blanks and therefore, not attributable tothe site. Values for these parameters are presented inthe data tables. Table 5-1 indicates that acetone and2-butanone were detected in samples in severalinstances where there was no qualifier indicating blankcontamination. This is inconsistent with the text.This discrepancy must be addressed. Further, theanalytical results of blanks samples must be includedin Table 5-1, as well as in all other applicabletables.

b. Page 5-5. First full paragraph. Remove the term "EPAfacility." Replace this term with a more accurateterm, such as "storage facility."

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84. Figure 5-2. The total VOC data should be presented in the wtables for each unit. This would allow for easy reference °to Figures 5-2, 5-3, and 5-4. 0

o5.4 Meadow Mat ^

85. Page 5-9. Clarify that this sampling was performed as part 5of Operable Unit 1 RD/RA activities. £

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86. Page 5-10, Section 5.4.1, Organic Compounds, secondparagraph. This paragraph states, "Base-neutral/acidextractable (BNA) compounds (Table 5-18) did not exhibitsignificant buildup in the meadow mat with depth. Adecrease in concentration between top and bottom samples atMM-A35 was evident for 1,4-dichlorobenzene (from 1,800 to3,70 ug/Kg)." This paragraph is misleading and must berewritten. The example given to support the conclusion thatBNAs did not exhibit buildup of BNA concentrations withdepth does not accurately represent the findings aspresented in Table 5-18. In the top and bottom samplesanalyzed at three locations in the meadow mat, all threesamples had one or more BNA compounds detected in higherconcentrations in the bottom sample compared to the topsample. The findings as presented in Table 5-18 must bemore accurately discussed in the text.

5.5 Surface Water

87. Page 5-11. This section should include a comparison betweenthe surface water results and the Federal Ambient WaterQuality Criteria.

88. Section 5.5.1, Organic Compounds.

a. Page 5-11. This section states that Pool C is a"negligible source1* of surface water contamination.This statement is not supported by the data collectedand must be removed.

This section also states, "With the exception of xylene(600 ug/1) and chlorobenzene (310 ug/1), individualVOCs in SW-M24 were less than 100 ug/1." Thisstatement is incorrect, and must be removed. Table 5-21 indicates that two additional VOCs were detected atlevels of 57 ppb (benzene) and 53 ppb (ethylbenzene).

b. Page 5-12, paragraphs one and two. The text statesthat several compounds were detected in surface watersamples and in associated blanks. The analyticalresults of the blank samples must be presented in Table5-21.

c. Page 5-12, fourth paragraph. This paragraph states, j£"Collectively, none of the organic data suggests that othe Pool C discharge is adversely affecting waterquality in Edmonds Creek." EPA disagrees with this gconclusion. The data demonstrates that surface water i-*quality has been impacted by the site. Station SW-M24located in the Pool C connecting channel near the gconfluence of Edmonds Creek had over 1 ppm total VOCs. to

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This is a significant finding and it demonstrates thatEdmonds Creek is impacted. This paragraph must bemodified to more accurately describe the findings ofsurface water sampling.

5.6 Sediments

89. Page 5-13. It should be noted in this section thatRespondents were required to collect additionalsediment/surface soil samples in the Edmonds Creek/Marsharea by EPA. Details and findings of the additionalsampling and analysis activities that Respondents performedin January 1991 should be included in the revised RI Report.

Information to be provided in the revised RI Reportincludes:

a map indicating the transects selected (Transects 1,2a, 2b, etc.) and the sampling locations located oneach transect;

the observation made during the field work that waterfrom Edmonds Creek, particularly during high tide, canflow in to the unnamed creek located in the northernhalf of Transect 2b and then drain northeast into theUnnamed Ditch. It appears that the low area in upperEdmonds Creek, where Transects 2a and 2b cross, drainsboth to Edmonds Creek and this unnamed creek; and

the bottom of the Unnamed Ditch from the area of thesouthern end of Transect 2b northward (upstream) totransect 4 is firm and consists primarily of sand.

90. Section 5.6.1, Organic Compounds, Polychlorinated Biphenyls(PCBs)

a. Page 5-14, second paragraph. It is stated that thehighest concentrations of PCBs were detected in thePool C area, "with concentrations above 100 ppm." Thisstatement should be changed to indicate that PCBs weredetected at levels of up to 730 ppm in the Pool C areaas specified on Table 5-26 (Page 13 of 16).

b. Page 5-14, third paragraph. It is stated in thisparagraph that, "A consistent decline in PCBs with *increasing distance from the Pool C area is <~>evident,..." This statement does not accuratelydescribe the findings of the sediment sampling program. §Several areas in the Edmonds Creek/Marsh demonstrated >-*notably high levels of PCBs. This section must moreaccurately describe the findings of the sediment °sampling program. w

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c. Page 5-15, first paragraph. The one-time, limitedsampling event in the Raritan River cannot be used tosupport the conclusion that the sampling program hasdelineated the "extent of impact."

In addition, this paragraph also discusses PCB samplingresults from the Unnamed Ditch. It concludes that"contamination does not extend beyond the mosquitochannels." There is inadequate evidence to supportthis conclusion. EPA required Respondents to performadditional sampling in the Edmonds Creek/Marsh area inorder to characterize contamination in areas beyond themosquito channels on the surface of the marsh. PAHcontamination was detected in the Unnamed Ditch, andtherefore, it can not be concluded that the site hasnot impacted this area, or that contamination does notspread beyond this ditch.

91. Table 5-22. BNA Compounds Detected in Surface WaterSamples. The results of BNA analysis of surface watersamples SW-CD1, SW-CD2 and SW-CD3 are not presented in Table5-22. This table should be revised to include theseresults.

92. Figure 5-5. This figure is difficult to read. It must becolor-coded or enlarged so that the different areas ofcontamination are more clearly depicted.

93. Table 5-27, Polycyclic Aromatic Hydrocarbons Detected inSediment Samples. This table (page 8 of 8) indicates thatChrysene was undetected in samples UD1 and UD2 in theUnnamed Ditch. The preliminary data (March 1990) indicatesthat "200JB" was detected in UD1 and "430 JB" was detectedin UD2. Please explain this discrepancy.

94. The PCB data for the "mosquito channels" should be presentedas data for "drainage channels." The data is presented forchannels one through four. Figure 5-5 should indicate whichchannel is referred to as "first mosquito channel," "secondmosquito channel," etc.

95. Page 5-16, last paragraph, Section 5.6.1, Organic Compounds,Polycyclic Aromatic Hydrocarbons (PAHs). PAH values arehigh in the Pool C area and elevated in the Edmonds Creek/Marsh area and in Edmonds Creek to the Raritan River. The §§Mill Brook/Martins Creek system also exhibits elevated <~>concentrations. These concentrations are above thosecollected in the reference site ("Control Creek"). This §paragraph states that urban stormwater may account for the ^PAH loading of Mill Brook/Martins Creek, but this statementis not substantiated by any data. From the data presented °

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in the RI report, it is reasonable to conclude that the PAHsin the Edmonds Creek system and the Mill Brook/Martins Creeksystem have originated from the Kin-Buc site. Theconclusions regarding the origins of the PAHs detected insediment must be revised.

96. Page 5-17, Section 5.6.1, Organic Compounds, Other Organics.

a. While the majority of contaminants detected in sedimentat the site are PCBs, PAHs and metals, some VOCs levelsdetected should be addressed in this section. VOCconcentrations of 16 ppm for ethylbenzene and 16 ppmfor total xylene at M25-C in the Low-Lying area arenoteworthy exceptions to the trend of low VOCs in thesediment.

b. Regarding phthalates detected in laboratory blanks, thesecond paragraph in this section states, "On thisbasis, it is likely that even reported concentrationswhich were not classified as non-detect by strictvalidation criteria are largely a function oflaboratory contamination. It is impossible, therefore,to quantify the presence of phthalates in the studyarea sediments." However, concentrations as high as3,542 ppm in the Pool C area, 448 ppm downstream ofPool C, and 71 ppm in a mosquito ditch were detected.There were no detectable concentrations in the three"Control Creek" samples. This data indicates that PoolC is a source of phthalate contamination in the EdmondsCreek system. This section must be revisedaccordingly.

c. The last sentence in the first paragraph in thissection must be removed. The absence of anycontaminant in the Pool C area currently does notindicate that it is not attributable to the site. Thiscomment applies to the last sentence in the thirdparagraph of this section as well.

97. Table 5-29.

a. Page 6 of 8. Sample M25C is listed in "Control Creek"instead of the Low-Lying area.

b. Page 7 of 8. Samples SD6, SD7 and SD8 are listed underthe Raritan River instead of Edmonds Creek (north). *

nc. Page 8 of 8. Samples SD9, SD10 and SD11 are listed

under the Raritan River instead of Edmonds Creek g(north). M

d. In addition, Table 5-29, as well as all other data °to00

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tables, should list the results of analyses onlaboratory blanks.

98. Section 5.6.2, Inorganic Compounds,

a. Page 5-18.

a. Paragraph 1, last sentence. This sentence statesthat there is "no notable difference between on-site metal concentrations and upstream riverconcentrations." This statement cannot besupported by the data presented in this report andmust be removed. The data indicate that the Kin-Buc site is a contributing source of severalmetals detected in the study area. This should bestated in the text.

b. Provide the rationale for including profiles ofthe four metals, arsenic, copper, lead andmercury, in Figures 5-7, 5-8 and 5-9 in sediments.Additional metals of concern to EPA in sedimentsinclude, but may not be limited to: antimony,cadmium, chromium, nickel, silver, and zinc.Please note that additional metals of concern havebeen identified to be of potential concern inother media.

c. EPA strongly disagrees with the basis for thedistribution profiles presented in Figures 5-7through 5-10. Samples GDI, CD2, CD3. UD1 and UD2do not represent background conditions, and areused improperly in the development of thesefigures. These figures are misleading and must beremoved from this report. Actual contaminationprofiles should be developed for the metals ofconcern in sediments at the site based on the datacollected. All relevant text in Section 5.6.2should be revised according to this comment.

*

99. Page 5-22, first full paragraph, Section 5.6.2, InorganicCompounds, Discussion. This paragraph states, "The EdmondsCreek/marsh system does not appear to be contaminated withmetals when viewed as part of the Raritan River system."This statement is contrary to the data presented in thissection and on Figures 5-7, 5-8 and 5-9 which indicate manyareas of the study area in which metals were detected atlevels of up to 5 and 10 times greater than levelsconsidered by Respondents to be "background" levels detectedin the Raritan River. Therefore, the conclusions presented iin this paragraph must be removed from the text.

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5.7 PCS Residues in Aquatic and Terrestrial Biota

100. Reference should be made to figures 3-13 through 3-16 forlocations of biota sampling.

101. Page 5-22. The limitations of the biota study, as describedin detail in EPA's November 9, 1990 letter to Respondentsmust be summarized in this section. In addition, thissection must reference the additional biota study performedby EPA in December 1990 and January 1991.

Second paragraph, last sentence. In EPA's November 9, 1990letter, EPA informed Respondents that the biota and sedimentdata could not be related to each other due to the fact that1) the biota samples were not collected at the same time asthe sediment samples, and 2) the sediment and biota samplingwas not performed in such a manner that they can be comparedto each other.

This section describes the occurrence of PCBs in eachspecies, with reference to sediment concentrations in theareas where the species were collected. As stated above,the study was not performed in a manner which would allowmeaningful reference of biota to sediment data. Sedimentswere not collected concurrently with biota samples and mostareas from which biota were collected were too disperse tocorrelate with one discreet sediment sample. The datacollected does indicate that bioaccumulation is higher inthe Edmonds Creek system compared to the reference site("Control Creek"). However, the biota data cannot becorrelated with sediment data. This section must be revisedso that such reference is not presented including the term"PCB tissue-to-sediment ratio."

In addition, when discussing the PCB concentrations inbiota, lipid corrected values should also be included.

Page 5-23, first full paragraph, last sentence. Thisconclusion, that there is a "baseline regional contribution"of PCBs from water and diet cannot be substantiated, andshould be removed from the text.

102. Page 5-24, Section 5.7.2, PCBs in Mummichog. All textrelating biota to sediment data should be removed forreasons described in prior comments. >j

DO103. Table 5-35, PCB Concentrations in Muskrat Liver Tissue °

Samples. Results should be reported with the whole body 0weights, tissue weights and sex of the animals. <=>

5.8 Metals in Biological Tissue SamplesOJo

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104. Page 5-26. The limitations of the data presented in thissection were described to Respondents in EPA's November 9,1990 letter. The limitations of the data must be describedin the beginning of this section. As you are aware, EPAperformed additional metals analyses on biota tissue. Thisfact should be mentioned in this section.

CHAPTER 6.0 FATE AND TRANSPORT

6.1 Contaminants of Interest

105. Page 6-1, Section 6.1.1, Groundwater, second paragraph. Theconclusion that "BNAs did not exhibit evidence of extensivemigration from Kin-Buc I" in groundwater is notsubstantiated based on the data. PAHs were detected ingroundwater throughout the study area.

106. Page 6-2, Section 6.1.2, Meadow Mat. The findings of theBNA analysis in this unit should be summarized in thissection.

107. Section 6.1.4, Sediments.

a. Page 6-2, second paragraph. Sediment contamination iscompared to "background" contamination. Since nobackground contamination levels have been established,this statement cannot be substantiated and must beremoved from the text.

b. Page 6-3, first paragraph. The statements made in thisparagraph regarding inorganics are not substantiated bythe data and must be removed from the report.

108. Page 6-3, Section 6.1.5, Biota. The last sentence in thissection states that metals were detected in biologicaltissue but "there was no demonstrated attributibility tosediments as a primary source." As stated above, the biotaand sediment sampling programs were performed in such a waythat it is not appropriate to correlate the biota andsediment data.

Properties of Contaminants-of-Interest

109. Page 6-3, Section 6.2.1, Physical and Chemical Properties,VOCs. This section states that the physical and chemicalproperties of the five VOCs most prevalent at the site are ^presented on Table 6-1. The text should specify which media »these contaminants are present in.

Page 6-6. The second and third paragraphs should be removed ofrom this report. """

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111. Page 6-13, first full paragraph. This paragraph states,"the most probable source of aromatic VOCs throughout thestudy area is waste oil deposition." This is not supportedby the record. Large volumes of many types of liquidhazardous waste were disposed of at the site. It is likelythat wastes other than "waste oil" are a source for VOCcontamination. The statement is incorrect and should beremoved from the text.

6.4 Contaminant Fate and Transport in Groundwater

112. Pages 6-12 - 6-13, Section 6.4.1, Refuse Migration Pathway.This section states that the Mound B cap is 2 to 3 feetthick and that it is possible that the sideslope cap acts asa barrier to horizontal groundwater discharge along theMound B interface with the Raritan River. During recentsite visits by representatives of EPA and NJDEP, exposedrefuse was observed in significant portions of the sideslopeof Mound B along the Raritan River. Further, some of theexposed refuse surface appeared to be below the high watermark for the river. It is likely that contaminatedgroundwater discharges at these locations. In addition, thelower contaminant concentrations in refuse wells GEI-7G andGEI-6G as compared to GEI-5G may be due to dilution ofcontaminants by the influx of tidal river water through theeroded sideslopes of Mound B. These issues should bediscussed in the text.

113. Page 6-13, Section 6.4.2, Sand and Gravel Migration Pathway.

a. As discussed in above comments, there is no evidencethat the sand and gravel unit is confined by the meadowmat. The apparent change in the flow direction withinthe sand and gravel unit may be due to a decrease inthe water table mound resulting from the capping of theKin-Buc I mound. Although there may be a flowcomponent from the Edison Landfill in the sand andgravel unit, it is clear that the majority of thecontamination within the sand and gravel unit hasemanated from the site, prior to the new flow regime.The text should make this clear. 5*5

DOO

b. Page 6-13, second paragraph. The date listed for the gGeoEngineering Final Remedial Investigation Report is MFebruary 1990. This date is incorrect. The correctdate for this report should be provided.

c. Page 6-17, last paragraph. This section states that itis possible that tet rachl or oe thene and trichloroethene

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entered the sand and gravel unit under the EdisonTownship Landfill, and their more soluble degradationproducts migrated to Mound B. No reasonable basis forthis statement is presented in the report, and thisstatement must be removed.

114. Page 6-18, Section 6.4.3, Bedrock Migration Pathway,paragraph 1. The tidal influence on flow direction in thebedrock aquifer would be east and west. This would may theEdison Landfill out of the zone of influence. This shouldbe discussed.

6.5 Contaminant Fate and Transport in Sediments

115. Page 6-21, Section 6.5.2, Biological Uptake, firstparagraph. This paragraph states, "Because a pattern ofbiological uptake of metals was not demonstrated, thisdiscussion will focus on the uptake of PCBs." The uptake ofmetals is of concern to EPA and Respondents have notpresented any reasonable basis for disregarding the uptakeof metals by biota. A thorough discussion of the findingsregarding the uptake of metals by biota must be presented.

116. Pages 6-25 - 6-26, Section 6.6.2, Mummichog. This sectionshould indicate, as shown on Table 6-11, that the mean PCBconcentrations detected in mummichog in each area of thesite is greater with respect to both wet weight and lipidweight levels than the nationwide post 1980 levels reported.

In addition, the conclusions presented in the last paragraphin this section on page 6-26 cannot be substantiated. Asdiscussed in comments listed above, the sampling program wasnot performed in such a way that sediment and biota data canbe appropriately correlated.

6.6 PCBs in Resident Biota

117. Page 6-27, first paragraph, Section 6.6.3, Muskrats. Thissection states, "The similarity of the tissue levels despitevarying environmental contaminations suggests the existencein muskrats, as in other species, of a steady stateconcentration which is independent of sediment PCB levels.*1As stated in previous comments, sediment and biota datacannot be used to form such conclusions. This conclusion 73must be removes from the report. ^

CHAPTER 7.0 oo

118. The Table of Contents indicated that Chapter 7, the *"*Endangerment Assessment if to be inserted. It is 0appropriate to state that the Endangerment Assessment is £>being performed by EPA, but it should not be inserted into w

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Respondents' final RI Report. Accordingly, Chapters 8, 9and 10 should be renamed Chapters 7, 8, and 9 respectively.

CHAPTER 8.0 SUMMARY

8.1 Site Background

119. Page 8-1, second paragraph. The Low-Lying area should beincluded in the list of Operable Unit 2 components.

8.2 Physical Characteristics of the Study Area

120. In general, the summary section must be amended to addressall relevant comments listed above.

121. Page 8-1. In addition to Kin-Buc I, Kin-Buc II and Mound B,the Low-Lying area also was used for landfilling. Thisshould be clarified in this section. Operable Unit 2included investigations of the Low-Lying area, in additionto Mound B.

122. Page 8-3 - 8-5, Section 8.2.2, Wildlife. See relevantcomments regarding section 2.4.2, listed above.

8.3 Remedial Investigation Activities

123. Page 8-9, first paragraph. Additional details regarding thescope and number of samples collected and analyzed as partof the biota study should be provided in this section.

8.5 Nature and Extent of Contamination

124. Page 8-13, Section 8.5.1, Source Characterization. Removethe last sentence in this section regarding Edison Landfillacting as a source of contamination at the site.

125. Page 8-14, second paragraph, last sentence, Section 8.5.2,Background Environmental Quality. This section states,"Available data on metals in the Raritan sediments indicatea significant background contribution in the vicinity of thesite." This conclusions has not been supported in thereport and must be removed from the report.

126. Page 8-14, Section 8.5.3, Groundwater. ^

a. First paragraph, last sentence. Clarify what is meant 0by the phrase, "...within Operable Unit 1 than in °Operable Unit 2."

ob. Second paragraph, first sentence. Remove the word £>

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"must."

127. Page 8-15, Section 8.5.4, Meadow Mat. See above listedcomments regarding the meadow mat.

128. Page 8-15 - 8-16, Section 8.5.6, Sediments.

a. First paragraph. This section should state thefindings more clearly. Several different areas in themarsh exhibited PCB levels above 10 ppm. In addition,it is unclear why Respondents have designated 10 ppm asa noteworthy criteria in discussing the PCB findings.It is stated in this section that, "PCB concentrationsin the immediate Pool C area were generally greaterthan 100 ppm." It is unclear why 100 ppm was noted indescribing the contamination. In light of the factthat up to 730 ppm PCBs have been detected in thesediment in the Pool C area, merely stating that PCBswere generally greater that 100 ppm is misleading.

b. First full paragraph, page 8-16. EPA does not agreewith the following statements regarding PAHcontamination, and they must be removed from thereport:

"The extent of contamination potentiallyattributable to Kin-Buc is not as well defined asfor the PCBs, owning to contribution frombackground,..."

"In Mill Brook/Martins Creek, the PAHs detectedappear to reflect the net deposition of backgroundinputs from the Mill Brook watershed."

c. Page 8-18, second full paragraph. EPA disagrees withthe conclusions made regarding metals. Theseconclusions must be revised in accordance with allrelevant above listed comments.

129. Page 8-16 - 8-17, Section 8.5.7, PCBs in Aquatic andTerrestrial Biota. As stated in previous comments, listedabove, it is unacceptable to correlate sediment and biotadata. This section must be revised accordingly. Further, ^the conclusions regarding metals in biota must be revised in <~>accordance with all relevant comments listed above.

oo8.6 Fate and Transport Mo

130. Page 8-18 - 8-19, Section 8.6.1, Contaminant Fate and u>Transport in Groundwater. Last paragraph on page 8-18. The *""scenario that Edison Landfill is a possible source of

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contamination in Mound B is not substantiated. Otherscenarios exist. Since Mound B contains refuse, it ispossible that the contamination found at the southwestcorner of Mound B originated from the refuse disposed ofthere. There are other possible scenarios. EPA does notagree with Respondents statements regarding Edison Landfillas a source of contamination at the Kin-Buc site.

131. Page 8-20, first paragraph, last sentence. Clarify what ismeant by "baseline conditions."

CHAPTER 9.0 CONCLUSIONS

9.1 Site Hydrocreolocry

132. Page 9-1, first paragraph. The description of thegroundwater flow in the sand and gravel unit underlying thesite is not complete. The last sentence in this paragraphis misleading. The meadow mat is not continuous beneath theentire site, as evidenced in its absence at the Kin-Buc IImound.

9.2 Extent of Contamination

133. Page 9-2, first paragraph, first sentence. Since noinformation regarding the disposal of "volatile and semi-volatile chemical constituents" at Edison Landfill isavailable, the statement that these constituents werepossibly derived from Edison Landfill cannot besubstantiated and must be removed from the report.

134. Page 9-2, second paragraph. EPA does not agree with thestatements made in the second and third sentences in thisparagraph. These conclusions will be modified byRespondents in accordance with comments presented above.

135. Page 9-2, third paragraph. EPA does not agree that waterquality in Edmonds Creek has not been altered due to thesites influences.

136. Page 9-2, fourth paragraph. EPA does not agree with thecorrelation of sediment and biota data as discussed in ^previous comments. The conclusions presented in this »paragraph must be modified based on all applicable commentspresented above. 0

o9.2 Data Limitations and Additional Studies '""'

o137. Page 9-2 - 9-3. Additional studies beyond those reported in N>the RI Report have been performed. EPA has collected and £analyzed additional biota samples in December 1990 andJanuary 1991. The data from this sampling event is not

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final, but upon the completion of the QA/QC review of thisdata, EPA will make it available to Respondents. Thisadditional study should be referred to in this section.

In addition, in January 1991, Respondents performedadditional sampling of soils/sediments in the EdmondsCreek/Marsh area. This data is also currently undergoingQA/QC review by the Respondents. This data will either beincorporated into the final RI Report upon completion ofdata validation, or, it will be presented in a supplement tothe RI Report. This information should be presented in thissection.

138. The following typos should be corrected in the revised RIreport:

Page ES-4, fourth bullet. "additional" should be"additional."

Page 2-3, Section 2.2, "eventualy" should be "eventually"

Page 3-29, first sentence, remove the word "was."

Page 5-9, Section 5.4, "RDRA" should be "RD/RA."

Table 5-27, footnote "B." "sam" should be "sample."

Page 6-2, Section 6.1.3. "now" should be "not."

Page 6-10, Section 6.4, third paragraph, fourth sentence,"does" should be "do."

Page 6-12, item 1. "enouh" should be "enough"

Page 6-13, last paragraph, last sentence. "grave" should be"gravel."

Page 6-15, first paragraph, first sentence. Remove the word"model" between the words "transport" and "conceptual."

Page 6-16, last paragraph, fourth sentence. "at" should be"as"

xPage 6-25, last paragraph, first sentence, "om" should be Q"from."

oPage 8-8, fourth paragraph, "drillling" should be S"drilling"

oPage 8-7, fifth paragraph. Remove the word "marsh" £

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Page 8-9 first paragraph. "ares" should be "areas"

Page 8-9, Section 8.4, first paragraph. "requirement"should be "requirements"

Page 8-13, Section 8.5.1, first sentence. Remove the work"Landfill" and replace it with "mound."

Page 8-14, Section 8.5.3, second paragraph, "anc" should be"and"

Page 9-1, last paragraph. "KinBuc" should be "Kin-Buc."

139. As part of EPA's review of the draft RI Report,approximately 25% of the raw data submitted by Respondentswith the RI report was checked against data presented in thetables in the draft RI Report. Attachment A detailserroneous sample results and other discrepancies which weredetected as a result of this audit.

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