ROEBLING STEEL COMPANY SITE NAME AND LOCATION

DECLARATION FOR TEE RECORD OF DECISION

ROEBLING STEEL COMPANY

SITE NAME AND LOCATION

Roebling Steel Company, Florence Township, Burlington County, NewJersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action forthe Roebling Steel Company site, chosen in accordance with therequirements of the Comprehensive Environmental Response,Compensation, and Liability Act of 1980, as amended by theSuperfund Amendments and Reauthorization Act of 1986 and, to theextent practicable, the National Oil and Hazardous SubstancesPollution Contingency Plan. This decision document explains thefactual and legal basis for selecting the remedy for this site.

The State of New Jersey has been consulted and concurs with theselected remedy. The information supporting this remedial actiondecision is contained in the administrative record for this site.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response actionselected in this Record of Decision, may present an imminent andsubstantial endangerment to public health, welfare, or theenvironment.

DESCRIPTION OF THE SELECTED REMEDY

The interim action described in this document is the first of aseries of planned remedial action operable units for the site.There have been two removal actions conducted to stabilize themost hazardous areas of the site. The first operable unit, whichis the subject of this Record of Decision will address on-siteareas that pose a sufficiently imminent hazard to requireexpedited remediatiori, and that were not addressed in theprevious removal actions. These areas include the remainingdrums and exterior tanks, transformers, a baghouse dust pile,chemical piles and tires. The first operable unit will alsoaddress soil under a water tower in the Roebling Park adjacent tothe Poebling Steel site.

DEISEN04

Typewritten Text

DOC ID 63581

-2-

Operable units for long-term remediation of the site will bedetermined as appropriate. A comprehensive remedialinvestigation will determine the nature and extent ofcontamination over the entire site. Areas of concern includesoils, surface water, groundwater, sediments, air quality, andother remaining contamination sources.

The major components of the selected remedy for this firstoperable unit include the following:

DRUMS/DRUM CONTENTS: Overpacking and Off-site Disposal

TRANSFORMERS/TRANSFORMER CONTENTS: Shipment OfTransformers En Masse

TANK CONTENTS: Bulking of Contents and Off-siteDisposal

BAGHOUSE DUST: Off-site Treatment and Disposal

CHEMICAL PILES: Off-site Treatment and Disposal

TIRES: Off-site Disposal

WATER TOWER SOIL: Off-site Treatment and Disposal

STATUTORY DETERMINATIONS

The selected remedy is protective of human health and theenvironment, complies with Federal and State requirements thatare legally applicable or relevant and appropriate to theremedial action, and is cost-effective. This remedy utilizespermanent solutions and alternative treatment (or resourcerecovery) technologies, to the maximum extent practicable, giventhe limited scope of the action. It also satisfies the statutorypreference for toxicity, mobility, and/or volume as a principleelement. The waste will be transported and properly disposed ofat a RCRA approved treatment and disposal facility. Althoughhazardous substances will remain on site above health basedlevels after implementation of this interim action, the five-year review will not apply because subsequent actions are plannedto fully address the remaining principle threats posed by thissite.

__Constantine Sidamon-Regional Administrat

017W

DECISION SUMMARY FOR TEE RECORD OF DECISION

ROEBLING STEEL COMPANY SITEFLORENCE TOWNSHIP, BURLINGTON COUNTY

NEW JERSEY

Interim Action - Oper&bl* Unit X

01703

TXBLB OP COVTXVT8

Section

Site Location and Description 1

Site History and Enforcement Activities 3

Highlights of Community Participation 10

Scope and Role of Interim Action 11

Summary of Site Characteristics 12

Summary of Site Risks 14

Description of Alternatives 17

Summary of Comparative Analysis of Alternatives 23

Selected Remedy 30

Statutory Determinations 34

Documentation of Significant Changes 37

Appendices

Appendix A. NJDEP Letter of Concurrence

Appendix B. Administrative Record Index

Appendix C. Responsiveness Summary

DECISION SUMMARY FOR THE RECORD OF DECISION

ROEBLING STEEL COMPANY

SITE LOCATION AND DESCRIPTION

The Roebling Steel site is a 200-acre, inactive facility thatfabricated steel wire and cables. The site is located inFlorence Township, Burlington County, New Jersey, in the vicinityof 40* 07' 25" north latitude and 74* 46' 30" west longitude.

The site is bordered by Second Avenue on the west and HornbergerAvenue on the south in the Village of Roebling. It is bounded onthe north and east by the Delaware River and Crafts Creek,respectively. The Roebling Park, a public playground adjacent tothe site, is located on Riverside Avenue. U.S. Route 130 isapproximately one-half mile south of the site. The site andRoebling Park are shown on Figure 1.

The site was used from 1906 until 1982 primarily for theproduction of steel products. In recent years, parts of the sitehave been used for various industrial operations. There areapproximately 55 buildings on site connected by a series of pavedand unpaved access roads occupying most of the site. Slagresidue from steel production was used to fill in a large portionof the bordering Delaware River shoreline. Numerous potentialsources of contamination exist at the site, including 757 drumscontaining liquids and solids, 106 abandoned tanks, 183transformers containing PCB-contaminated oils, 52 railroad carscontaining fly-ash, dry sludge and debris, pits and sumps,process buildings containing chemical treatment baths, two sludgelagoons, friable asbestos insulation on pipes, a baghouse dustpile, chemical piles, tire piles, and a landfill.

Residential properties are located to the west and southwest ofthe site at a zoning density of approximately eight dwellings peracre. The closest residences to the site are approximately 100feet away from the property boundaries, 250 feet from the slagpile and 1,200 feet from the sludge lagoons and wastewatertreatment plant tanks. The Northwest Playground consists of alarge open area which includes swings, basketball and tenniscourts, and a large elevated water tower. The playgroundelevation is about 10 to 15 feet above the Roebling Steel site.A Penn Central (Conrail) .railroad track runs to the southeast ofthe site. Areas zoned for special manufacturing activities arefound 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).

0170 3

URGE:

.w TOPOGRAPHIC 7H M I N U T E S E R I E S OUADRANGLISFrREMONWEST.NJ , tRHTOLM;TRENTON EAST>U;TRENTON WEST/U.

KOEBLlNCSTtElSITE

FIGURE I

STTE VKaNTTY MAPPARK AND STEEL PLANT

01706

The Delaware River is used for contact (i.e., swimming} and non-contact (i.e., boating) recreational activities in the vicinityof the site and is also used for fishing. The Delaware River isused for water supply by the city of Burlington, approximatelysix miles downstream from the site, and the city of Philadelphia,farther downstream. Crafts Creek, a tributary to the DelawareRiver, with headwaters in north-central Burlington County,comprises the eastern boundary of the site and forms a 40-acrepond south of the site. Crafts Creek discharges to the DelawareRiver on the eastern boundary of the site. Crafts Creek is usedby nearby residents, particularly by children, for fishing andplaying.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Historical Site Use

A steel mill was established at the site in 1906 by the J. A.Roebling's Sons Company for the fabrication of steel wire andcables from scrap steel. The site remained owned by the Roeblingfamily until 1952 when it was sold to the Colorado Fuel and IronCompany (CF&I). CF&I operated the facility until May 1979.

In May 1979, the John A. Roebling Steel Company (JARSCO) wasformed with financial assistance provided by the U.S. Departmentof Commerce, Economic Development Administration (EDA), the NewJersey Economic Development Authority, and private funds. JARSCOceased operations in June 1981 and leased portions of the site toother businesses. The Roebling Wire Company (RWC) beganoperating on a leased portion of the site in January 1982. RWCclosed its operations between June 30, 1983 and July 28, 1983,filed a Chapter XI petition for bankruptcy, and continued tooccupy the site premises until October 1985. RWC informed theNew Jersey Department of Environmental Protection (NJDEP) that ithad ceased operations at the Roebling Steel site and did notintend to resume at that location.

In addition to the companies noted above, the site supported avariety of other industrial uses, including a polymer-reclamationfacility, a warehouse facility, a facility for repairing andrefurbishing refrigerated trailers and shipping containers, andan equipment storage facility for a construction company. EDAremains the mortgagee in possession of the site and previouslymaintained a security force at the site to protect its remainingfinancial interests. "A list of the companies that have occupiedthe site is provided in Table 1.

TABLE 1

HISTORICAL SITE D8ESTEEL AND WIRE RELATED COMPANIES

COMPANY

John A. Roebling SonsCompany (1906-1952)

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

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

Roebling SteelCorporation (JARSCObought the premisesfrom Roebling Steel &Wire Corporation,1979-1982)

Poebling Wire Company(RKC) bought Wire Millequipment and leasedthe Wire Kill premisesfrom Jarsco, Bldgs 8,10, 13 and 14, Jan 1982-Oct 1985)

ACTIVITIES

Production of wire,wire cable and cablefor suspension bridgesfrom scrap 6 pig iron

Steel & wire productshigh carbon-wireWastewater treat-ment plant

Steel billets & wireConstruction of waste-water treatment plant

Carbon and alloysteel billets (onlyportions of the plantand equipment neededfor their products;Wire Mill Facilitiesidle); Wastewatertreatment plant

Wire production;Wastewater treat-ment

SUSPECTEDWASTES

Waste oil,heavy metals

Wastewater dis-charged intoDelaware Rivercontainingcopper, zincand cadmiumwastes, mineralacids, acidsolutions,sludges, wasteoil, spentsolvents, bag-house dust

Sludges, wasteoil, processwater, heavymetals, spentsolvents

Waste oil,furnace slag,baghouse dust,heavy metalsludges, waste-water discharge

Waste oil, heavymetals sludges,VOAs, wastewaterdischarges, acidsolutions

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TABLE 1 (cont'd)

HISTORICAL SITE USEUNRELATED STEEL AND WIRE COMPANIES

M.A. Industries, Inc.

M.A. Industries operated a polymer-reclaiming business on thesite from June 1, 1978 until May 31, 1983 under a lease agreementwith the Roebling Steel and Wire Corporation. M.A. Industriesoccupied Building 114, which had formerly been used for wirestorage. M.A. Industries reportedly recovered plastic cases fromlead storage batteries.

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, which had formerly been a part of the wiremill, and a portion of Building 88, which had been the coppermill. According to Stauffer Chemical Company, this space wasused for storage of vinyl products.

Joe Tiederman Truck Specialist

Joe Tiedenrian Truck Specialist held a five-year lease forproperty on the site beginning in April 1980. This companyoccupied a portion of Building 80, which formerly was the scrapbuilding.

Project Packaging. Inc.

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

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, which had been the scrap building.

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TABLE 1 (cont'd)

HISTORICAL SITE DSEUNRELATED STEEL AND WIRE COMPANIES

Henkels and McCoy. Inc.

HenXels 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.

Greentree. Inc.

Greentree, Inc. vas alleged to be subleasing property (Building97) from RWC during 1984 (in violation of New Jersey bankruptcylaws then affecting RWC), and had been observed housing severalhundred containers on site.

Johns-Kanville

Johns-Manville occupied office space on site as well as Building77. Johns-Kanville used the building to store insulationmaterials.

^idvay Container Services. Inc.

Midway Container Services, Inc. leased Building 77, formerlyoccupied by the Stauffer Chemical Corporation. Midway ContainerServices was engaged in welding/container reparation.

Vanco. Inc.

Vanco, Inc., leased space on the site for trucking and mechanicalrepair operations.

Remedial Actionc to Date

The improper use, or lack, of environmental control facilities atthe site over the last twenty-five years resulted in severalregulatory agencies issuing notices of noncompliance to citeowners. On May 19, 1964, the New Jersey Department of Health(NJDOH) recommended that CF4I install a wastewater treatmentplant. A NJDOH status report described operations conducted atthe site by CF&I, which was then discharging 15-million gallonsper day (MGD) into the Delaware River. The effluent was acidic,and contained high levels of iron and other metals, suspendedsolids, and oil. On May 31, 1968, NJDOH ordered CF6I to ceasepolluting the Delaware River and required the construction of awastewater treatment plant. In 1972, the wastewater treatmentplant was completed and placed into operation.

On November 15, 1974, NJDEP met with facility owners to discussvarious aspects of the facility operation, including the absenceof liners under the sludge lagoons, groundwater contamination,landfill operations, oil unloading, and transmission and storageoperations. In October 1979, NJDEP issued JARSCO a permit toconstruct and operate an industrial wastewater treatment plant(the CF&I wastewater treatment plant with improvements). Thepermit required the installation of monitoring wells and theperformance of bioassay monitoring. Also, the Delaware RiverBasin Commission (DRBC) granted approval to JARSCO to withdrawsurface water from the Delaware River, and to dischargewastewater to the Delaware River in compliance with DRBC qualitystandards.

On June 13, 1979, the JARSCO site was inspected by NJDEP and theBurlington County Health Department. Six hundred 55-gallon drumscontaining waste oil were discovered on site. NJDEP requestedthat these drums be removed. In November 1979, NJDEP issued anotification of violation to JARSCO, as a result of an inspectionof the site on June 13, 1979. JARSCO was later cited forcommitting a health and safety violation as it attempted toremove the drums from the site without completing the requiredwaste manifests.

On January 29, 1980, NJDEP named JARSCO as one of 38 hazardouswaste sites roost urgently needing cleanup in the State of NewJersey. The following potential pollution sources wereidentified: 100 drums, PCB transformers, a tire pile, abandonedoil and chemical storage tanks, and bag house dust storage piles.

In 1981, JARSCO was cited for noncompliance with conditions inthe permit for operation of its wastewater treatment plant(installation of monitoring wells, bioassay monitoring, flowmeasurement and discharge monitoring). NJDEP issued a Notice of

omt

Prosecution to JARSCO seeking the removal of oil drums, and otherhazardous wastes stored on site. A Resource Conservation andRecovery Act (RCRA) inspection of the facility was performed, andJARSCO was cited for storage of baghouse dust without apermit.NJDEP inspected and sampled the sludge lagoons, and foundthe sludge to contain volatile organics and heavy metals.

On July 22, 1981, JARSCO removed 20,000 gallons of waste oil and60 cubic yards of contaminated soil from the site.

On February 1, 1982, NJDEP issued JARSCO a deadline for the sub-mittal of a compliance plan, which would address violation ofmonitoring requirements for the wastewater treatment plant.Since the JARSCO plant had closed in November 1981, it was notrequired to meet the deadline.

In June 1982, NJDEP required the installation of two groundwatermonitoring wells downgradient from the lagoons, and one wellupgradient from the lagoons. EPA issued a Complaint andCompliance Order that directed JARSCO to stop storing hazardouswastes without a permit, to remove spilled dust and contaminatedsoil, and to address contaminant migration.

In Decei-ber 1982, an acid cloud at the RWC was reported. Noviolations could be detected when the facility was inspected byNJDEF.

In February 1983, JARSCO officially abandoned the site withoutsufficiently addressing the permit noncompliances first cited in1981.

In 1983, NJDEP inspected the site and found that permits andcertificates were missing from some of the RWC equipment. ACorpliance Evaluation Inspection performed by NJDEP foundunacceptable conditions at the RWC site.

The site was added to the National Priorities List (NPL) ofSuperfund sites in December 1982. In 1983, EPA performed a siteinspection which included soil sampling. The existing data wereassembled in a Remedial Action Master Plan. In May 1985, EPAbegan a Remedial Investigation and Feasibility Study (RI/FS) todetermine the nature of the contamination at the site and toevaluate remedial alternatives to address this contamination.

In 1985, Notice Letters pursuant to Section 107(a) of theComprehensive Environmental Response, Compensation and LiabilityAct (CERCLA) were sent to eight potentially responsible parties(PRPs), inviting participation in the remedial action. No PRPaccepted responsibility or liability for hazardous substances atthe Roebling Steel site. On October 29, 1987, Notice Letters

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pursuant to Section 107 (a) of CERCLA, as amended by theSuperfund Amendments and Reauthorization Act (SARA), were sent tonineteen PRPs, as identified by the Environmental ProtectionAgency (EPA), inviting participation in the removal action,discussed in the next section. As of December 1, 1987, sixreplies had been received by EPA, but no PRP has acceptedresponsibility or liability for hazardous substances at theRoebling steel site. Seven letters have been returned to senderor indicate moved, not forvardable.

Two removal actions have been performed at the cite. In December1985, NJDEP removed picric acid and other explosive chemicalsfrom one of the on site laboratories and detonated them at theEarle Naval Weapons Station. The EPA performed a removal action,between October 1987 and November 1988.

EPA REMOVAL ACTION fOCT 1987 - NOV 1988)

1. Approximately 300 lab pack containers of chemicals werecollected, removed, and disposed of off site. Thechemicals found included acids, bases, inorganic salts,alcohols, and other halogenated and non-halogenatedorganic compounds.

2. 3,203 55-gallon drums (2,004 full; 1,199 empty) weresampled and disposed of at RCRA permitted facilities.

3. 120 cubic yards of emptied drums were crushed andremoved to an EPA approved hazardous waste landfill inIndiana.

4. Three pounds of metallic mercury were collected,repackaged and sent to a recycling facility inPennsylvania for distillation and reuse.

5. Thirty-seven tons of baghouse dust near the southernborder of the site have been contained and secured withtarps and barriers.

6. One drum of hazardous waste containing cyanide wasshipped to an approved treatment facility.

7. Forty compressed gas cylinders containing flammablegases, oxidizers, corrosives, poisons, and other gaseshave been returned to manufacturers or other facilitiesfor reuse and recycling. Several cylinders weredetonated on site.

C1713

8. Approximately 3,000 gallons of sulfuric acid and 2,150gallons of phosphoric acid were sampled, analyzed, andremoved from two large, above-ground tanks and sent toa facility for reuse.

9. 239,000 pounds of hazardous solids in drums were bulkpacked into roll-off containers and shipped to a RCRApermitted facility.

10. Exposed asbestos in potential personnel-entry zones waswrapped and contained.

Current Conditions

The site is presently inactive and under the control of EPA,which maintains 24-hour security at the site. The site is fencedon the entire north and south sides. The western border, whichis formed by the Delaware River, and the eastern border, which isformed by Crafts Creek, are not fenced. EPA has posted signsindicating that the site is hazardous and entry to the propertyis restricted.

Currently, Ebasco Services Incorporated, contracted by EPA, isperforming remedial activities for the on-going RI/FS. Thisstudy is being conducted concurrently with the interim action andwill address remaining site contamination. Most of the samplingactivities for the RI/FS have been completed.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Focused Feasibility Study (FFS) and the Proposed Plan for theRoebling Steel site were released to the public for comment onJanuary 8, 1990. These two documents are available to the publicin both the administrative record at EPA and two informationrepositories maintained at Florence Township Public Library andFlorence Township Municipal Building. The notice of availabilityfor these two documents was published in the Burlington CountyTimes on January 7 and 8, 1990 and the Bordentown Register Newson January 11, 1990. A Superfund Update was mailed toapproximately two hundred individuals on the mailing list. Apublic comment period was held from January 8, 1990 to February6, 1990. In addition, a public meeting was held on January 18,1990. At this meeting, representatives from EPA and the Agencyfor Toxic Substances and Disease Registry (ATSDR) answeredquestions about problems at the site and the remedialalternatives under consideration. A response to the commentsreceived during the comment period is included in theResponsiveness Summary, which is part of this Record of Decision(ROD).

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This decision document presents the selected interim remedialaction for the Roebling Steel site, in Roebling, New Jersey,chosen in accordance with CERCLA, as amended by SARA and, to theextent practicable, the National Contingency Plan. The decisionfor this site is based on the administrative record.

SCOPE AND ROLE OF INTERIM ACTION

As with many Superfund sites, the problems at the Roebling Steelsite are complex. As a result, EPA has organized the remedialwork into phases or operable units. This ROD addresses the firstplanned remedial action at the site. This action vill addressthose hazards at the site that require immediate attention, andis intended to stabilize the site until an overall, permanentremedy is selected. The interim action will continue thestabilization effort that began with the previous removal action.The interim action is consistent with Section 104 of CERCLA, asamended, in that it will provide an orderly transition into, andwill contribute toward, the efficient performance of futureremedial actions. Remedial alternatives for a permanent cleanupof the entire site are being evaluated in the ongoing remedialinvestigation and feasibility study.

Removal Actions

Operable Unit 01

included two cleanups, the first wasperformed in 1985 by the NJDEP, and thesecond was performed in 1987 - 1988 by theEPA. The objective of these actions was tostabilize the most hazardous areas of thesite. Explosive chemicals were removed fromthe site in the 1985 removal. In the secondremoval action, lab pack containers and drumsof corrosive and toxic materials, acid tanksand compressed gas cylinders were removed.

is the subject of this decision document. Itwill address those on-site areas that pose asufficiently imminent hazard to requireexpedited remediation but were too complex orrequired too expensive a response to addressduring the removal actions. These areasinclude the remaining drums and exteriortanks, transformers, a baghouse dust pile,chemical piles, and tires. It will alsoaddress the soil under the water tower in theRoebling Park, adjacent the Roebling Steelsite.

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• Additional Units will determine the nature and extent ofcontamination over the entire site. A RI/FSis currently being performed that willaddress the remaining areas of contaminationat the site. The RI/FS will examine soils,surface water, groundwater, sediments, air,lagoons and other remaining contaminationsources. The remaining areas will beexamined for further operable unitsegregation so as to address the worst areasof the site first.

6UKKARY OF SITE CHARACTERISTICS

The Roebling Steel site was used during the last 75 years mostlyfor the production of steel wire and cable. Recently, portionsof the site were used for various industrial operations thatgenerated, stored, or buried raw materials and wastes in manydifferent locations on site. As a result, there are a variety ofpotential sources of chemical contamination, numerous potentialmechanisms for chemical migration, and many potential exposurepathways for both human and ecological receptors.

Numerous potential contamination sources of hazardous wastes areidentified at the site. Below is a list of potential sourcessegmented into areas to be addressed under this ROD and those tobe addressed in the ongoing RI/FS.

Interim Action (OU-cm

• 757 drums remain scattered throughout the site, inside andoutside of 37 buildings. A previous removal actionaddressed 3,203 55-gallon drums, of which 2,004 were fulland 1,199 were empty. These drums are expected to contain avariety of organic and inorganic liquids and solids.

• 183 transformers that contain oil contaminated withpolychlorinated biphenyls (PCBs) have been identified onsite. The results from the PCB analysis showed highconcentrations of Arochlor 1242 and 1260.

• There are approximately nine exterior tanks ranging in sizefrom 100 to 8,000 gallons, many of which are in poorcondition, with rusted walls, leaky valves and open roofs.They contain oil, acids, sludges.

• Approximately 530 cubic yards of baghouse dust is beingstored in a roofed area adjacent to building 88. Samples ofthe baghouse dust showed high concentrations of most metal

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contaminants. Cadmium, chromium, arsenic, lead, and zincare all present at elevated levels. Cadmium, chromium andlead levels in the TCLP (leachate) metals analysis exceedthe land disposal restrictions (LDR) treatment standards forthese contaminants.

• Chemical piles consisting of powders and unknown materialhave been discovered. Chemical pile samples showed highconcentrations of most metal constituents. Cadmium,chromium and lead levels in the TCLP (leachate) metalsanalysis exceed the LDR treatment standards for thesecontaminants.

• Approximately 10,000 discarded tires are located aroundBuilding 18 and 70; these present a potential fire hazard.

• Approximately 120 cubic yards of surface soil under thewater tower in the Roebling Park is contaminated withelevated levels of lead.

Additional Operable Units

• There are approximately 90 tanks located throughout thebuildings. Many of them are in poor condition, with rustedwalls, leaky valves and open roofs. Among the tanks are sixwastewater treatment flocculation and settling tankscontaining very acidic water and sludges.

• Two inactive wastewater treatment plant lagoons, which werefound to be contaminated with lead, cadmium, copper, zinc,and volatile compounds, are located on the site.

• Furnace slag disposal areas cover approximately 20 acres andcould be a source of heavy metal contamination, as well assulfur, phosphorous, and metal oxides.

• A landfill in which rubble and debris were disposed islocated on the site.

• 52 inactive railroad cars containing furnace slag, ashes,and sludge have been found.

• There are 55 buildings on the site containing physical andenvironmental hazards, including water filled basements,hidden pits, and sumps containing contaminated liquids andsludges.

• Loose friable asbestos insulation have been found throughoutthe buildings, and on overhanging pipes.

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cm?

In addition to the numerous contamination sources describedabove, contaminants have migrated into the soil, water, sedimentand air. Limited sampling of some potentially contaminatedenvironmental media was conducted and summarized below.

Surface soil samples were obtained from locations within a gridoverlay encompassing the site. Composite samples were obtainedfrom each 200 square foot grid and analyzed for EP toxicity con-stituents and petroleum hydrocarbons. In addition, subsurfacesoil samples were taken from boreholes and monitoring wells.Both the surface and subsurface soils are highly contaminatedwith metal pollutants. Numerous organic compounds are present atelevated levels in soils.

Groundwater samples were collected from 17 monitoring wells.Analyses of these samples show high concentrations of metalcontaminants.

Analysis of 14 surface water samples collected from the DelawareRiver and Crafts Creek did not show concentrations of pollutantsexceeding Water Quality Criteria (WQC) except near storm waterdischarge points. However, sediment samples from the samelocations detected high levels of metal contaminants. Highlevels of semi-volatile organic compounds were also present. Inaddition, low concentrations of volatile organics were detectedin a few samples. Sediment samples did not contain detectableamounts of pesticides or PCBs.

Contaminated soil, sediment, groundwater, surface water and airare still under study and will be addressed in a future ROD.

SUMMARY OF SITE RISKS

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the interim actionselected in this ROD, may present an imminent and substantialendangerment to public health, welfare, or the environment.

Human Health Risks

An evaluation of risks associated with each area of concern forthe interim action was performed to determine the impact onpublic health and the^environment under various exposurescenarios and different contaminant pathways. This evaluation ispresented in Section 3.4 of the FFS report. Vandalism andtrespassing are two major concerns at the site which seriouslyaggravate the chemical and physical hazards present, and haverequired the use of expensive security measures.

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The potential for significant exposure through inhalation anddermal contact is considered high. Both the drums and tankscontain a variety of hazardous (toxic, corrosive, and reactive)constituents. The transformers contain oil contaminated withhigh levels of PCBs. There are two major concerns associatedwith the drums, transformers and tanks: trespassers may beexposed to hazardous chemicals if they approach or tamper withany of these containers; and container vessels are deterioratedand may leak at any time, releasing hazardous substances, eitherthrough volatilization of the chemical or a spill.

The baghouse dust and chemical piles were found to contain highlevels of several heavy metals (lead, chromium and cadmium), manyof which are toxic and/or carcinogenic. Baghouse dust from steelmanufacturing electric arc furnaces is a restricted RCRA listedwaste (K061—emission control dust/sludge from the primaryproduction of steel in electric furnaces). The existing cover onthe baghouse dust pile provides temporary protection of publichealth and the environment. However, this cover may becomedegraded by the weather and cease to provide effectivecontainment. Migration pathways exist for the transport ofuncontained baghouse dust and chemical pile contents into the airvia resuspension through wind erosion or mechanical disturbances.The hazardous constituents measured in the baghouse dust nayleach into the environment and may also pose a health risk totrespassers through direct exposure.

Approximately ten thousand tires are located in piles both insideand outside of buildings, primarily around the south easternportion of the site. On several occasions, fires have occurredin the tire piles. The tire fires constitute a chemical threatto public health and the environment as well as a physicalhazard. Burning tires release hazardous constituents, such aspolynuclear aromatic hydrocarbons, into the air, and produce atoxic tar-like sludge.

The most significant exposure scenario is the incidentalingestion of contaminated soil by young children. Surface soilin Koebling Park was analyzed; an area of the park under thewater tower adjacent to a playground frequented by young childrenwas found to be contaminated with unacceptably highconcentrations of lead. Low levels of PCBs have also beendetected in this area of the park. The incidental ingestion orinhalation (through migration into the air by wind erosion ormechanical disturbances) presents a public health risk tochildren, particularly of preschool age.

The potential health and toxicological effects of somesubstances, such as heavy metals and PCBs, are well known.Table 2 provides a summary of the health effects from knowncompounds at the Roebling Steel site.

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TABLE 3

POTENTIAL HEALTH AMD TOXICOLOOICAL EFFECTS

HEALTH BFTECT

Eye, SkinRespiratory andMucous MembraneIrritation

Liver Damage

Kidney Damage

Lung Damage

Central NervousSystem Damage

Acutely Toxic viaInhalation, Ingest ion,or Skin Absorption

Carcinogenic

Reproduction Toxicity

Mutagenic

COMPOUND

Chromium Copper Lead Acids/Corrosive PCBs Asbestos

X X X X X

X X X

X

X X X

X

X X X

X X X X

X X X

X

Environmental Risks

As previously noted, the Delaware River to the north and CraftsCreek to the east form the boundaries of the Roebling Steel site.The Delaware River serves as a drinking water source for thecities of Philadelphia, Pennsylvania and Burlington, New Jersey.In addition, the Delaware River and Crafts Creek are being Usedas a recreational facility for residents on both sides of theriver. Human health could be impacted most directly via waterquality deterioration and contamination of recreational fishspecies. Although there are risks to human health fromcontamination sources, the potential also exists for migration ofthe contaminants into the air, soil, surface water andgroundwater. The principle environmental threat present at theRoebling Steel site is the continued degradation of thecontainers holding hazardous waste. If contaminants were toenter the Delaware River, they would pose potential threats topublic health and the environment.

Contaminants may enter Delaware River and Crafts Creek viaseveral pathways. The toxic chemicals may leak from drums,transformers and tanks located throughout the site, andpotentially leach into the river and groundwater systems.Contaminated soils from leaking containers may be transported bysurface runoff. Contaminated groundwater may also discharge intothe river. Fugitive dust from contaminated soils, baghouse wasteor chemical piles may be blown off site by the wind and enter theriver system.

The most significant effects on ,endangered species could occurduring site remediation activities. An endangered aquaticspecies known to inhabit this section of the river is the adultshortnose sturgeon (Acipenser brevirostrum). Endangered raptorsfound in the area are the bald eagle fHalialetus leucocephalus)and the American peregrine falcon fFalco peregrinus anatum). Nosignificant negative 'effects on endangered species areanticipated from site remediation activities, due to the natureof this action. Only off site treatment and disposal are beingconsidered for the contaminants addressed in the interim action.In future remediation phases, the potential impacts of siteremediation activities will be evaluated further.

DESCRIPTION OF ALTERNATIVES

The alternatives analyzed for the interim action are presentedbelow. These alternatives are numbered to correspond with thosein the Focused Feasibility Study report. These alternatives weredeveloped by screening a range of alternatives for theirapplicability to site-specific conditions, and evaluated for

17

01721

effectiveness, implementability, and cost. The alternatives thatwere not eliminated from consideration during screening weresubjected to a more detailed evaluation. In addition to thealternatives described below (Table 3), a No Action alternativewas considered for the on-site areas and water tower soil.

MO ACTION

The No Action alternative provides a baseline for comparing thealternatives that provide a greater degree of response. Underthis alternative, no effort would be made to change or maintainthe current status of the drums, transformers, tanks, baghousedust pile, chemical piles and tires. The container vessels(drums, transformers, tanks) would continue to degrade andpotentially leak hazardous substances. The temporarily containedand uncontained contaminated materials (baghouse dust andchemical piles, respectively) would continue to migrate. Thetires would remain in place and another fire might occur. Underthe No Action alternative, no remedial action would beimplemented to eliminate the health risk posed by thecontaminated soil under the water tower. No remedial technologywould be utilized to reduce the toxicity, mobility or volume ofthe waste. The No Action alternative is retained as a baselinealternative for each contamination source.

ON-SITE AREAS OF CONCERN:

DRUMS/DRUM CONTENTS (DR)

DR-1 Drum Bulking and Off-site Disposal

Estimated Cost: S 869,000Implementation Period: within one year

Under this alternative, action would be taken to remove the drumsfrom the site and to properly dispose of the wastes. First, anydeteriorated drums would be overpacked. All drums containingwastes would then be sampled. The samples would be tested todetermine compatibility of the wastes. Drums containingcompatible waste would be staged (grouped) until final wastebulking. Prior to final disposal, the contents of each stageddrum would be consolidated (bulked) into a bulking chamber withthe contents of other drums of compatible material. One wastesample would be taken from each bulked category; these samples

18

01722

Table 3SUMMARY OF REMEDIAL ALTERNATIVES

CONTAMINATION SOURCE ALTERNATIVE

ON-8ITE AREAS OF CONCERN

DRUMS/DRUM CONTENTS DR-1 Bulking Contents andOff-site Disposal/Crushing Drums and Off-site Disposal

DR-2 Overpacking of Drums andOff-site Disposal

TRANSFORMERS/TRANSFORMER CONTENTS

TR-1

TR-2

Bulking Contents and Off-site Incineration/Dismantling Transformersand Off-site Disposal

Transformer Shipment EnMasse

TANK CONTENTS TK-1 Bulking and Off-siteDisposal

BAGHOUSE DUST BH-1 Off-site Treatment andDisposal

CHEMICAL PILES CP-1 Off-site Treatment andDisposal

TIRE PILE TP-1 Off-site Disposal

OFF-SITE AREA 0? CONCERN

WATER TOWER SOIL WT-3 Excavation and Off-siteTreatment and Disposal

01723

would undergo rigorous analytical testing to determine theappropriate method of final disposal for each category. Thebulked waste would be loaded into a tanker truck and hauled offsite to a RCRA approved treatment facility or to a hazardouswaste disposal facility. After bulking, empty drums would becrushed for disposal.

DR-2 Overpaying of Drums and Off-site Disposal

Estimated Cost: $ 1,475,500Implementation Period: within one year

This alternative involves overpacking each drum of waste at thesite in an approved container to prevent further leakage orspillage of the drum contents. This alternative would includesampling of each drum along with a complete disposal parameteranalysis. Once the drums are overpacked, they would be hauledoff site to a RCRA approved treatment facility or to a hazardouswaste disposal facility.

TRANSFORKERS/TRANSFORMER CONTENTS (TR)

TR-l Bulking and Incineration of PCB-ContaminatadLiquids/Dismantling and Disposal of Transformers


This alternative involves the consolidation of the contents ofindividual transformers into a tanker to be shipped off site forincineration. The contents would be tested before consolidationto ensure that the materials are treated appropriately based onthe concentration of PCBs present. The transformer housingswould be decontaminated before off site disposal.

TR-2 Shipment of Transformers En Masse


This alternative involves shipping the transformers and theircontents to a facility that would properly dispose of the PCB-contaminated oil, dismantle and clean the transformers anddispose of the housings.

20

01724

TANK CONTENTS (TK)

TK-1 Bulking of Contents and Off-sit« Disposal


This alternative involves the removal of contaminated materialfrom exterior tanks and shipment to an off site RCRA approvedtreatment facility or to a hazardous waste disposal facility.The contents from these tanks would be tested, bulked andconsolidated into similar waste streams for disposal. The tanksthemselves would be decontaminated during the long-term RI/FS,when tanks are removed from the site. The remaining tanks andtank contents located inside buildings will also be addressed inthe RI/FS.

BAGHODSE DUST (BH)

BH-1 Off-site Treatment and Disposal

Estimated Cost: $ 405,000Implementation Period: within one year

This alternative involves the removal of approximately 530 cubicyards of baghouse dust to an off site RCRA approved treatment anddisposal facility. The dust was consolidated into one pileduring the previous removal action, covered with a plastic tarp,and secured by large concrete barriers. Sand bags were used toreduce migration from the base of the pile by securing the tarponto the pile. The waste would be loaded into approximately 30roll-off containers and transported to an off site RCRA approvedtreatment and disposal facility. Off site disposal would be usedin conjunction with a pre-disposal treatment measure, such assolidification or stabilization, that would be capable ofphysically or chemically binding inorganic contaminants andsignificantly reducing their potential to leach.

CHEMICAL PILES (CP)

CP-1 Off-site Treatment and Disposal


21

This alternative involves the off site treatment and disposal ofapproximately twenty-four tons of material from seventy-ninechemical piles scattered throughout the site. Compatiblematerial from these piles would be consolidated And transportedto an off site RCRA approved treatment and disposal facility. Aswith the baghouse dust, off site disposal would be used inconjunction with a pre-disposal treatment measure, such assolidification or stabilization.

TIRE PILES (TP)

TP-1 Off-sit* Disposal


This alternative involves the removal and off site disposal ofapproximately 10,000 tires and burnt rubber. At present, most ofthese tires are stored in and around Buildings 18 and 70.

OFF-SITE AREA OF CONCERN:

WATER TOWER SOIL (WT)

WT-3: Excavation/Treatment and Disposal


Under this alternative, contaminated soils under the water towerwill be excavated to a depth of six inches using ordinaryconstruction equipment (backhoes and front-end loaders). Thevolume of contaminated soil is approximately 120 cubic yards.The excavated area would be backfilled with uncontaminated soiland revegetated. The contaminated soils would be loaded intorolloffs, transported to the Roebling Steel site for temporarystorage if necessary, and then sent to a RCRA approved treatmentand disposal facility. Disposal of the contaminated soil wouldbe used in conjunction with a pre-disposal treatment measure,such as solidification or stabilization, that would be capable ofphysically or chemically binding inorganic contaminants andsignificantly reducing their potential to leach. (The focusedfeasibility study refers to this alternative as PS-3.)

22

cms

SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES

In accordance with the National Contingency Plan, a detailedanalysis of each remedial alternative was conducted with respectto each of nine criteria. This section discusses and comparesthe performance of the remedial alternatives under considerationagainst these criteria. The nine criteria are described below.All selected alternatives must at least attain the ThresholdCriteria. The selected alternative should provide the besttrade-offs among the Primary Balancing Criteria. The ModifyingCriteria were evaluated following the public comment period.

THRESHOLD CRITERIA

• Overall Protection of Human Health and Environment addresseswhether or not a remedy provides adequate protection anddescribes how risks posed through each pathway are eliminated,reduced, or controlled through treatment, engineeringcontrols, or institutional controls.

Compliance with ARARs addresses whether or not a remedy willmeet all of the applicable or relevant and appropriaterequirements of other Federal and State environmental statutesand/or provide grounds for invoking a waiver.

PRIMARY BALANCING CRITERIA

Long-term Effectiveness and Permanence refers to the magnitudeof residual risk and the ability of a remedy to maintainreliable protection of human health and the environment overtime once remedial objectives have been met.

Reduction of Toxicity, Mobility/ or Volume Through Treatmentis the anticipated performance of the disposal or treatmenttechnologies that may be employed in a remedy.

Short-term Effectiveness refers to the speed with which theremedy achieves protection, as well as the remedy's potentialto create adverse impacts on human health and the environmentthat may result during the construction and implementationperiod.

Implementability is the technical and administrativefeasibility of a remedy, including the availability ofmaterials and services needed to implement the chosensolution.

Cost refers to estimates used to compare costs among variousalternatives.

C1727

MODIFYING CRITERIA

• State Acceptance indicates whether, based on its review of theFFS and Proposed Plan, the NJDEP concurs with, opposes, or hasno comment on the preferred alternative.

Community Acceptance will be assessed in the Record ofDecision following a review of the public comments received onthe FFS report and the Proposed Plan.

ANALYSIS

Each area of concern is considered separately below. The firstseven evaluation criteria are considered in the order they arelisted above and the merits of each alternative relative to thatcriterion are evaluated. To avoid redundancy, the remaining twocriteria, state acceptance and community acceptance, aresummarized for each source area.

The State has reviewed the FFS and Proposed Plan and concurs withthe remedy selected in this decision document.

The objective of the community relations activities was to informthe public about the work being performed at the site and toreceive input from the public on the remedy. There has been nocoiTjaunity opposition to the preferred alternative presented tothe public.

NO ACTION

The No Action alternative for each source area would not provideprotection of human health and the environment because hazardouscontaminants are known to exist in concentrations withsignificant health risks. The No Action alternative provides abaseline for comparing alternatives that result in remedialresponses.

Full protection from immediate risks would not be attained bythis alternative. There is a high potential for future exposureto off site human and environmental receptors which needs to beaddressed. The container vessels (drums, transformers, tanks)would continue to degrade and potentially leak hazardoussubstances. The temporarily contained and uncontainedcontaminated materials (baghouse dust and chemical piles,respectively) would continue to migrate. The tires would remainin place and another fire might occur. Under the no actionalternative, no remedial action would be implemented to eliminatethe health risk posed by the contaminated soil under the water

24

C1728

tower. The toxicity, nobility and volume of the hazardousconstituents would not be reduced.

The no action alternative is the lowest in cost, and leasteffective in addressing the contamination found at the RoeblingSteel site. In addition, this alternative would be unacceptableto both the State of New Jersey and the local community.


DRUMS/DRUM CONTENTS

Removal of the wastes and treatment at an off site facility inboth of the remaining alternatives (DR-1 and DR-2) would preventa release of hazardous substances to the environment, and wouldfully protect human health and the environment. Bothalternatives were used during the past removal action.

There are no chemical-related applicable- or relevant andappropriate requirements (ARARs) that need to be met forimplementing these alternatives. Activities related to thehandling of wastes and the transportation to an off site facilitywould be accomplished in accordance with the Department ofTransportation (DOT) regulations and hazardous waste managementrequirements. The waste would be removed to a RCRA permittedfacility.

Both alternatives, DR-1 and DR-2, effectively remove the wastefrom the site, eliminating the potential threat to human health.As the hazardous substances would be removed and treated ratherthan just contained or managed, either alternative would providea permanent remedy.

Treatment would eliminate the toxicity and/or volume of thewaste. In addition, the removal of drums from the site willeliminate the physical hazards associated with drums that mightinjure trespassers or rupture and leak their contents.

The short-term effectiveness of both alternatives is high, asboth can be quickly implemented and both will immediately addressthe hazards posed by the drums. However, the overpackingalternative requires less time to implement because the majorityof the activity would be performed off site. Analysis for thecompatibility testing'for the bulking operation can be performedin an on site mobile laboratory.

Adequate worker protection during implementation activities canbe ensured by wearing the proper level of protection, followingthe proper handling protocols, and good safety practices. There

25

01729

is an increased risk associated with the bulking operationcompared to the overpacking of drums because there is more onsite maneuvering of hazardous wastes.

On site bulking and off site treatment ($ 869,000} is lessexpensive than individually overpacking the drums and shippingthem to an off site facility for treatment ($ 1,475,500). Thecost estimates for both alternatives are worst case scenarios.These estimates are based on using incineration to treat all ofthe waste. However, sampling may indicate that some other lessexpensive treatment method may be appropriate.

TRANSFORMERS/TRANSFORMER CONTENTS

Both remedial alternatives, bulking and incineration of trans-former oils, and dismantling and disposal of the transformerhousings (TR-1); and shipment of the transformers en masse (TR-2), are protective and constitute a final remedy. The threat ofPCB-contaminated oil leaking from the transformers would beaddressed. Both alternatives utilize incineration to permanentlydestroy the contaminants.

There are no chemical-specific ARARs that need to be met beforeimplementation. However, in implementing the action, any oilcontaining PCBs must be treated in accordance with the ToxicSubstances Control Act (TSCA). TSCA regulations for PCB disposaldistinguishes between not regulated (< 50 parts per million(ppm)), PCB-contaminated (50 ppm < PCB concentration < 500 ppm)and PCB (> 500 ppm). There are disposal restrictions regardingPCB transformers. One method used to dispose of PCB transformerhousings containing liquids with PCB concentrations of 500 ppm orgreater are regulated under TSCA Part 761.60. PCB transformerhousings must be properly drained and flushed. The transformercontents and flush must be incinerated and the housing disposedof in a TSCA PCB approved chemical waste landfill. The PCBtransformer housing may not be dismantled.

Both alternatives effectively remove the oil from the site,eliminating the potential threat to human health. Incinerationof PCB-contaminated oil provides a permanent remedy. Bothalternatives are consistent with the long-term remedy.

Incineration of the contaminated oil will totally destroy thetoxicity and mobility of the waste, and will reduce the volume ofthe oil. In both cases, the transformer would be removed fromthe site.

Short-term effectiveness is high for both alternatives, as thecontaminated oil would be removed from the site and treated.

26

01730

Both alternatives achieve their maximum effectiveness quickly,although alternative TR-2 requires less time to implement thanTR-1. Short-term hazards involved in handling and transportingthe oils include risks to workers as veil as a potential threatto trespassers that might come in direct contact withaccidentally spilled waste. Any short-term impacts duringimplementation can be mitigated by following proper protocols andrequirements.

The multi-staged process of sampling and bulking the PCB-contaminated oil, transporting it to an off site incinerator, anddismantling and disposing of the transformer housings increasethe risk during implementation activities of alternative TR-1.

Shipment of transformers en masse ($ 1,541,000) is cheaper thanbulking and dismantling all the transformers ($ 1,840,000), andcan be performed in an expedited fashion.

TANK CONTENTS

Bulking of tank contents and off site disposal (TK-1) isprotective of human health and the environment because iteliminates the future threat of leakage by further deteriorationand tampering of the tanks. There are no chemical related ARARsthat need to be met before implementation. However, shipment anddisposal must be treated in accordance with RCRA, if the contentsare RCRA hazardous wastes.

Bulking of tank contents and off site disposal is the onlyalternative that passes the threshold evaluation. Disposal ofthe waste to an off site RCRA approved treatment and disposalfacility may reduce its toxicity, mobility, and volume, and is apermanent treatment technology.

The short-term risks associated with bulking and transporting thewaste to a disposal facility are minimal because of the smallvolume of waste found in the tanks being addressed. The wastestream characterization should not be complex, which would limitthe number of bulking chambers and tanker trucks. In addition,the approach can be quickly implemented because of the smallnumber of tanks.

The estimated cost of this alternative is $1,483,500.

BAGHODSE DUST

Off site treatment and disposal of the baghouse dust isprotective of human health and the environment because it

27

C1731

eliminates the risk of direct exposure, which may occur throughtampering, or weathering of the tarp. Landfilling this aaterialinvolves the placement of a restricted RCRA listed waste (K061—emission control dust/sludge from the primary production of steelin electric furnaces) and RCRA Land Disposal Restrictions must beconsidered before the waste is land disposed. Treatmentstandards, either concentration levels or a specified technology,would be determined before the material can be removed to alandfill. The treatment facility must test wastes aftertreatment and before land disposal to ascertain that LORtreatment standards have been net.

Disposal of the baghouse dust to an off site RCRA approvedtreatment and disposal facility is the only alternative thatpasses the threshold evaluation. This alternative eliminatesmigration and, depending on the treatment technology, naydecrease toxicity. Off site disposal used in conjunction with apre-disposal treatment measure would be consistent with the long-term remedy.

The short-term risks associated with this alternative can beminimized by using dust control measures to prevent migrationcaused by moving vehicles and equipment, and wind erosion duringthe implementation stage. The waste would be loaded intoapproximately 30 roll-off containers and transported to thetreatment and disposal facility.

The cost of this alternative is estimated at $405,000.

CHEMICAL PILES

Off site treatment and disposal of the chemical piles isprotective of human health and the environment because iteliminates the risk of exposure by migration and direct contactat the site.

Landfilling this material involves the removal of acharacteristic hazardous waste to an off site RCRA approvedtreatment and disposal facility and must comply with theappropriate land disposal restrictions. The treatment facilitymust test wastes after treatment and before land disposal toascertain that LDR treatment standards have been met.

Off site treatment and disposal of the chemical piles is the onlyalternative that passes the threshold evaluation. Thisalternative raises the same issues regarding dust controlmeasures and land disposal restrictions as were considered forthe baghouse dust.

28

C1798

The cost of this alternative is estimate at $21,600.

TIRE PILES

Off site disposal of approximately 10,000 tires is a final remedyto the threat of future tire fires and is protective of humanhealth and the environment. There are no chemical-related ARARsthat need to be met.

Tire fires are particularly hazardous because of thepetrochemical composition of the tires. When ignited, the tiresproduce a smoke plume that contains many gaseous byproducts andparticipates, including hazardous organic compounds. Burningtires produce oils that can make the fire uncontrollable. Thereis also a possibility of the fire spreading to an area whereflammable or explosive chemicals are located. Removing the tireswould insure the protection of human health and the environmentfrom this hazard.

Off site disposal of tires is the only alternative that passesthe threshold evaluation. This alternative is a permanent remedyand is effective in eliminating the future threat of tire firesand the production and migration of hazardous by-products.

The disposal of tires has no short-term effects and is readilyimplementable. The cost of off site disposal of the tires is$12,000.

OFF-SITE AREA OF CONCERN:

WATER TOWER SOIL

Under this alternative, action would be taken to excavate thecontaminated soil and transport it to a RCRA approved treatmentand disposal facility. Contaminated surface soil (i.e., leadlevels greater than 250 ppm) is limited to the area under thewater tower.

Treatment and disposal of contaminated material to an off sitefacility would fully protect human health and the environment.RCRA Land Disposal Restrictions must be considered before thewaste is land disposed. Treatment standards, eitherconcentration levels or a specified technology, would bedetermined before the material is removed to a landfill.

Activities related to the handling of wastes and transportationto an off site facility would be accomplished in accordance withU.S. Department of Transportation (DOT) regulations and hazardous

29

01733

waste management requirements. Any temporary storage of rolloffsor drums containing contaminated material on the Roebling Steelsite would be conducted in accordance with the RCRA standardsregarding storage of hazardous waste for off site disposal. Thecontaminated material will ultimately be removed to a RCRApermitted facility.

This alternative will effectively remove the waste from the area,eliminating the potential threat to human health. Since thehazardous material will be removed and properly disposed, thisalternative would provide a permanent remedy. This alternativewould eliminate future migration of the contaminated soil.

The short-term effectiveness of this alternative is high, as itcan be quickly implemented and would immediately address thehazards posed by the contaminated soils. Worker hazards would beminimal due the nature of the removal. Adequate workerprotection during implementation activities can be ensured byfollowing appropriate safety practices.

Excavation and off site treatment and disposal of thecontaminated soil under the water tower is the only alternativethat passes the threshold evaluation. The cost of thisalternative is approximately $64,800.

SELECTED REMEDY

After a thorough review and evaluation of the alternativespresented in the Focused Feasibility Study, to achieve the bestbalance among all evaluation criteria, EPA presented Overpackingof Drums and Off-site Disposal (DR-2), Transformer Shipment EnMasse (TR-2), Bulking of Tank Contents and Off-site Disposal (TK-1), Off-site Treatment and Disposal of Baghouse Dust (BH-1), Off-site Treatment and Disposal of Chemical Piles (CP-1), Off-siteDisposal of Tires (TP-1), and Excavation, Treatment and Disposalof Water Tower Soil (WT-3) to the public as the preferred remedyfor the Roebling Steel site. The input received during thepublic comment period, consisting primarily of questions andstatements transmitted at the public meeting held on January 18,1990, is presented in the attached Responsiveness Summary.Public comments received encompassed a wide range of issues butdid not necessitate any changes in the remedial approach proposedto be taken at the site. Accordingly, the preferred alternativeswere selected by EPA as the remedial solution for the site.

The estimated total cost for all tasks associated with thisremedy is $5,003,400. The tasks identified as part of the remedyare: labor, equipment and material; transportation; disposal;and analytical (Table 4).

30

CI734

TABLE 4

ESTIMATED COST OF SELECTED REMEDIES

Estimated Cost*DRUMS/DRUM CONTENTS COMPONENT

CONSTRUCTION (757 drums and 44,000 gallons of contents)

• Labor, Equipment and Materials $110,500• Transportation 52,500• Disposal 640,000• Analytical 480,000

CONTINGENCY (15%) 192,500

TOTAL CAPITAL COST $1,475,500

TRANSFORMER/TRANSFORMER CONTENTS COMPONENT

CONSTRUCTION (183 transformers and 67,000 gallons of contents)

• Transportation of Transformer/ $1,340,000Contents, Incineration of Contents,Dismantling and Decontamination ofTransformer



TANK CONTENTS COMPONENT

CONSTRUCTION (150,000 gallons of contents)

• Labor, Equipment-and Materials negligible• Transportation $84,000• Disposal 1,200,000• Analytical 6,000



01735

TABLE 4 (cont.)


Estimated Coats

BAGHOUSE DUST COMPONENT«

CONSTRUCTION (530 cubic yards)

• Transportation• Fixation (Stabilization)• Disposal

CONTINGENCY/SERVICE/AWARD COSTS (35%)

TOTAL CAPITAL COST

$97,50093,750108,750

105,000

$405,000

CHEMICAL PILES COMPONENT


• Transportation• Fixation (Stabilization)• Disposal

CONTINGENCY/SERVICE/AWARD COSTS (35%)

TOTAL CAPITAL COST

$5,2005,0005,800

5,600

$21,600

TIRES COMPONENT

CONSTRUCTION (10,000 tires)

• Disposal

CONTINGENCY (20%)

TOTAL CAPITAL COST

$10,000

2,000

$12,000

C1736

TABLE 4 (CO&t.)


Co»t»

WATER TOWER SOIL COMPONENT


• Transportation $15,600• Fixation (Stabilization) 15,000• Disposal 17,400

CONTINGENCY/SERVICE/AWARD COSTS (35%) 16,800

TOTAL CAPITAL COST $64,800

COST SUMMARY FOR TEE SELECTED REMEDIES

DRUMS (DR-2) ($)1,475,500TRANSFORMERS (TR-2) 1,541,000TANKS (TK-1) 1,483,500BAGKOUSE DUST (BH-1) 405,000CHEMICAL PILES (CP-1) 21,600TIRE PILES (TP-1) 12,000WATER TOWER SOIL fWT-3) 64.800

TOTAL PROJECT COST . ($)5,003,400

C1737

Some additional activities nay be performed during the initialphases of the remedial design process and prior to implementationof the selected remedial alternatives. A treatability study maybe conducted to evaluate the effectiveness of soil and dusttreatment through stabilization, if appropriate. .

STATUTORY DETERMINATIOHS

EPA's selection of alternatives for the seven areas of concerncomply with the requirements of Section 121 of CERCLA as amendedby SARA. The interim action is protective of human health andthe environment, complies with Federal and State requirementsthat are applicable or relevant and appropriate to this action,and is cost-effective. This action utilizes permanent solutionsand alternative treatment technologies to the maximum extentpracticable, given the limited scope of the action. Thestatutory preference for treatment that reduces toxicity,mobility or volume will be addressed in this interim action, asappropriate. The interim action does not constitute the finalremedy for the site. Subsequent actions are planned to fullyaddress the remaining principle threats posed by this site. Abrief, site-specific description of how the selected remedycomplies with the statutory requirements is presented below.

1. Protection of Human Health and the Environment

All alternatives are protective of human health and theenvironment, dealing effectively with the threats posed by thecontar.inants which were identified. The principle threatsinvolve:

• The inhalation and dermal contact of hazardous materialsfound in drums, transformers and tanks.

• The inhalation of uncontained baghouse dust and chemicalpiles that may become airborne via resuspension through winderosion or mechanical disturbances.

• The physical hazard and inhalation of hazardous constituentsreleased by burning tires.

• The incidental ingestion or inhalation of contaminated soilunder the water tower through migration into the air viawind erosion and young children playing in the playground.

The selected remedy addresses these contaminant pathways bycapturing and removing the contaminant sources before anyadditional migration continues. In implementing the interim

34

01738

action, the idea is to minimize the risks associated withconstruction and the length of tine for implementation.

2. Compliance with Applicable of Relevant and AppropriateRequirements

Action-Specific

All remedial activities will comply with RCRA/CERCLA regulations.

• RCRA Subpart 268 - Land Disposal Restrictions

• RCRA Part 264 standards are applicable to the bulking andstorage of hazardous waste for off site disposal. If thematerial, once displaced, remains on site for more than 90days, RCRA standards are applicable to the storage ofhazardous waste on the facility property. Even if notstored for more than 90 days, RCRA standards are relevantand may be appropriate.

• RCRA Parts 262 and 263 standards are applicable to theproposed remedial activities involving RCRA hazardous waste.These provide standards for manifesting, transport, andrecordkeeping. In addition, the date which accumulationbegan in each container must be clearly indicated on «achcontainer. Other requirements listed in Part 262 are alsoapplicable to site operations.

• The baghouse dust is a restricted RCRA listed waste (K061—emission control dust/sludge from the primary production ofsteel in electric furnaces). All remedial activities willcomply with applicable RCRA regulations.

Chemical-Specific

• EPA plans to treat the baghouse dust, chemical piles, andwater tower soil in conjunction with off site disposal. Thepre-disposal treatment measures would reduce toxicity tolevels (treatment standards) specified by the RCRA LandDisposal Restrictions. Treatment methods will have toreduce the waste's leachability to TCLP concentrationsestablished by LDRs.

• Toxic Substances Control Act regulates the disposal of fluidand transformer housings contaminated with PCBs (Part 761).TSCA distinguishes between the various concentrations: notregulated (< 50 ppm) except when used for dust control and

35

C1739

fuel, PCB-contaminated (50 ppm < PCB concentration < 500ppm) and PCB (>. 500 ppm) .

TSCA Part 761 regulations are applicable to decontaminationof heavy equipment (lift trucks, rams or presses) usedduring construction activities.

To Be Considered

• The shipment of hazardous waste off cite to a treatmentfacility should be consistent with the Off-Site PolicyDirective Number 9834.11 issued by Office of Solid Waste andEmergency Response (OSWZR) which became effective November13, 1987. This directive is intended to ensure thatfacilities authorized to accept CEPCLA generated waste arein compliance with RCRA operating standards.

• NJDEP Soil Cleanup Objectives for concentrations of lead insoil, which range between 250-1000 ppm.

• U.S. Department of Health and Human Services (Centers forDisease Control) health-based concentrations of lead insoil, ranging between 500-1000 ppm.

• Potential emissions are expected in the form ofvolatilization of hazardous constituents and fugitive dustduring excavation, transport and disposal of baghouse dust,chemical piles and contaminated soil. Dust control measureswill be included in the design specifications, and healthand safety plans to ensure 'compliance with RCRA, Clean AirAct and State regulations during implementation.

3 . Utilization of Permanent Solutions and Alternative TreatmentTechnologies to the Maximum Extent Practicable

The selected remedy utilizes permanent solutions and treatment(or resource recovery) technologies to the maximum extentpracticable by providing the best balance among nine evaluationcriteria of all the alternatives examined. Contaminated materialwill be transported off site to an appropriate RCRA approvedtreatment and disposal facility. Of the five primary balancingcriteria, short-term effectiveness and implementability were themost decisive factors in the selection process. Alternativesthat offered minimal short-term risks, time-efficiency andmaximum effectiveness were maintained through the selectionprocess.

36

01740

4. Preference for Treatment as a Principal Element

The selected remedy fully satisfies this criterion. The varietyof wastes found at the site indicates that several treatmentmethods (e.g. incineration, stabilization, etc.) will need to beused. Incineration will be the preferred technology fortransformer oil contaminated with PCBs, and drum and tankcontents high in organic content but low in metal content. Thosematerials high in inorganics (metals) will be treated beforelandfilling in a RCRA approved facility.

5. Cost-Effectiveness

Of the alternatives which most effectively address the principlethreats posed by the contamination at the site, the selectedremedy affords the highest level of overall effectivenessproportional to its cost. The selected remedy is cost-effectiveand represents a reasonable value for the money. Based on theinformation generated during the FFS, the estimated total projectcost is $5,003,400.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Roebling Steel site was released to thepublic in January 1990. The Proposed Plan identified thepreferred alternatives for each source area. EPA reviewed allwritten and verbal comments submitted during the public commentperiod. Upon review of these comments, it was determined that nosignificant changes to the selected remedy, as it was originallyidentified in the Proposed Plan, were necessary.

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C1741

APPENDIX A

MJDEP LETTER OF CONCURRENCE

CI742

STATE OF NEW JERSEYDEPARTMENT OF ENVIRONMENTAL PROTECTION

JUDITH A. YASJON. COMMISSIONERCN402

TRENTON. NJ. 08625-0402(609) 292-2885

Fix: (609) 984-3962

April 10, 1990

Mr. Constantine Sidamon-EristoffRegional AdministratorUnited States Environmental Protection

Agency, Region II26 Federal Plaza, 7th FloorNew York, NY 10278

SUBJECT: Roebling Steel Superfund SiteRecord of Decision

Dear Mr. Sidamon-Eristoff:

A draft Record of Decision (ROD) has been prepared by the UnitedStates Environmental Protection Agency (USEPA), in accordance withthe requirements of the Comprehensive Environmental Response,Compensation and Liability Act of 1980 (CERCLA), as amended by theSuperfund Amendments and Reauthorization Act of 1986 (SARA), forthe Roebling Steel Superfund Site in Florence Township, BurlingtonCounty, New Jersey. The ROD covers interim actions to address themost urgent problems at the site; additional remedial actions toaddress long term problems will be forthcoming. The State of NewJersey concurs with the interim remedy as quoted below from theDeclaration in the Record of Decision.

Description of the Selected Remedy

The interim action described in this document is the first of aseries of planned remedial action operable units for the site.There have been two removal actions conducted to stabilize the mosthazardous areas of the site. The operable unit which is thesubject of this Record of Decision, will address on-site areas thatpose a sufficiently imminent hazard as to require expeditedremediation, and that were not addressed in the previous removalactions. These areas include the remaining drums and exteriortanks, transformers, a baghouse dust pile, chemical piles andtires. The first operable unit will also address soil under awater tower in the Roebling Park adjacent to the Roebling Steelsite. Operable units "for long-term remediation of the site will bedetermined as appropriate. A comprehensive Remedial Investigationwill determine the nature and extent of contamination over theentire site. Areas of concern include soils, surface water, groundwater, sediments, air quality, and other remaining contaminationsources.

01743New Jersey a cm Equal Opportunity Employer

The major components of the selected remedy for this first operableunit include the following:

DRUMS/DRUM CONTENTS: Overpacking and Off-site Disposal

TRANSFORMERS/TRANSFORMER CONTENTS: Shipment ofTransformers En Masse

TANK CONTENTS: Bulking of Contents and Off-site Disposal

BAGHOUSE DUST: Off-site Treatment and Disposal

CHEMICAL PILES: Off-site Treatment-and Disposal

TIRES: Off-site Disposal

WATER TOWER SOIL: Off-site Treatment and Disposal

It is our understanding that for the Water Tower Soil, which is ina park used by area children, the clean-up standard for lead willbe 250 parts per million.

After a review of the final decision document, the State may haveadditional comments to be addressed by USEPA during remedialdesign. These comments would not affect the State's concurrencewith the above remedy.

The State of New Jersey appreciates the opportunity to participatein this decision making process and looks forward to futurecooperation with USEPA.

Very truly yours,

Judith A. Yaskin, CommisDepartment or Environment

01744

APPENDIX B

ADMINISTRATIVE RECORD ZHDEX

1̂745

RQEBLING STEEL STTEADMINISTRATIVE RECORD FILE

INDEX OF DOCUMENTS

REMOVAL RESPONSE

Correspondence

P. 1-82 Waste Characterization Forms (WCFs), DrumDisposal Characterization from Removal Action(U.S. EPA), prepared by ThermalKEM, Inc., 8/86

P. 63-202 Pollution Reports, prepared by D.5. EPA,9/24/87-9/1/89.

P. 203-461 Report: On-Seene Coordinator's* Report.Roebllng Steel Company NPL Site. EmerpencyResponse and Removal Action,. Florence

• Township. Burlinpten Conntyr New Jerseyrprepared by Mr. Charles E. Fitzsimmons, U.S.EPA and Mr. Christopher A. Militscher, U.S.EPA, 2/2/90.

REMZ5IAL INVESTIGATION

Sarr.plinc and Analysis Plans

P. 462—707 . Report! Field Sampling and Analysis Plan.Remedial Investigation/Feasibility Study.Roebliny Steel Site, Florence Township^ NewJersey. Volume I. prepared by Ebasco Services,Inc., 3/89.

Sa-.plinc and Analysis Data/Chain of Custody Forms

P. 708-774 Report: Roeblino Steel Site, Slag Disposaland Park Area Surface Soil and AnalysisResults. 1/90.

* Administrative Record File available 3/8/90.

Note: Company or organizational affiliation is mentioned onlywhen it appears in the record.

P1746

Morfc P lans

P. 775-958 Work P lan . Remedial Invest ion/Feasibility Study. Roebling Steel Site.Florence Township. Kew Jersey, prepared byEbasco Services, Inc., 3/89.

P. 959-1005 Report: Attachment I; Revisions to Work Jand Field Sampling and Plan. 6/27/89

P. 1006-1019 Report: Attachment- TTr Hobbling Ste«»lRevisions to Work Plan and Field Sampling andAnalysis Plan. 8/89.

F E A S T B T L T T Y STUDY

Feasibi l i ty Study Reports

P. 1020-1219 Report: Focused Feasibility Study. RoeblingSteel Company. .Florence Township. Kew Jersey.prepared by U.S. EPA, Region II, 1/90.References are listed on p. 1067.

Correspondence

1220-1221 Memorandum to Distribution from Mr. Anthony JFarro, New Jersey Department of EnvironmentalProtection, re: Draft Proposed Plan, 10/3/89.The distribution list is attached.

1222-1501 Letter to Mr. Harry J. Rzomp, FlorenceTownship Board of Fire Engineers, and Ms.Donna J. Boston, Florence Township Office ofEmergency Management, and Mr. C. Lester Smith,Florence Township Board of Fire Commissioners,from Mr. Bruce M. Benedetti, Mayor of FlorenceNew Jersey, re: Focused Feasibility Study,1/19/90. The Roebling Steel Site. Buildlny-by-Building Schematic Drawings of ContaminantSources and the Roebling Steel SiteContaminant Source Inventory Detail Reportreports are attached.

C1747

HEALTH ASSESSMENTS

Correspondence

P. 1502-1537 Article: "Preventing Lead Poisoning in YoungChildren,* prepared by the Centers for DiseaseControl, U.S. Department of Health and HumanServices, 1/85.

P. 1536-1544 Memorandum to Ms. Tamara Rossi, U.S. EPA, fromMs. Denise Johnson, ATSDR, re: Sampling data,10/13/86. A meeting agenda, and four citelayout figures are attached.

P. 1545-1545 Letter to Ms. Tajnara Rossi, U.S. EPA, from Ms.Denise Johnson, ATSDR, re: Soil samplingdata, 11/10/89.

P'J£1.C PARTICIPATION

Co.— J"ur ity Relations Plans

P. 1546-1568 Report: final Community Relations Plan forthe Roebling Steel Site^ Florence Township.Purlinyton County. New Jersey, prepared byEbasco Services, Inc., 3/89.

F-blic Notices

F. 156S-1570 Public Notice inviting public comment on theproposed cleanup alternatives for the RoeblingSteel Site, Interim Action, Roebling, NewJersey, (undated) . A draft copy is attached.

F'jblir Meetin Transcrits

P. 1571-1676 Transcript: Public Meeting, Rpebliny SteelCompany Site. 1/18/90.

Fact Sheets and Press Releases

P. 1677-1677 Fact Sheet: "Focused Feasibility Study forRoebling Steel Site," prepared by U.S. EPA,1/90.

P. 1676-1679 Press Release: "EPA to Hold Public Meeting onProposed Interim Cleanup Plan for RoeblingSteel Company Superfund Site," prepared byU.S. EPA, 1/4/90.

C1748

Proposed Remedial Aetien Plans

P. 1680-1691 Report: Proposed Plan. Roebliny Steel CompanyHew Jersey, preparedgite, Florence Township.

by U.S. EPA, 1/90.

Correspondence

P. 1692-1692

P. 1693-1693

P. 16S4-1706

Letter to Ms. Marian Hubler, Florence TownshipPublic Library, from Ms. Tamara Rossi, U.S.EPA, re: Documents for the informationrepository, 1/5/90.

Letter to Mr. Richard Brook, Florence TownshipMunicipal Building, from Ms. Tamara Rossi,U.S. EPA, re: Documents for the informationrepository, 1/5/90.

Letter to Ms. Tamara Rossi, U.S. EPA, from Mr.Bruce Benedetti, Mayor, Township of Florence,re: Off-site safety measures, 1/30/90.

f!749

EBASCO ENVIRONMENTALe E»*S:: SE

»6C Cftuos Avtnm Lynflfwrst. NJ 07071-3566 [2011460-«SOO

March 21, 1990RMOII-90-05*

Ms. Lillian JohnsonChief Community Relations StaffUS Environmental Protection Agency26 Federal PlazaNew York, NY 10278

Subject: REM III PROGRAM - EPA CONTRACT NO. 68-01-7250WORK ASSIGNMENT NO. 226-2L91ROEBLING STEEL COMPANY SITE - OPERABLE UNIT 01FINAL RESPONSIVEKESS SUMMARY __________ __

Dear Ms. Johnson:

Ebasco Services Incorporated (EBASCO) is pleased to submit thisFinal Responsiveness Suiucary for the Roebling Steel Company SiteOperable Unit 01. If you have any comments, please call ae at(201) 460-6434 or Steven Senior at (201) 906-2400.

Very truly yours,

Dcv F Sachdev, PhD PERegional Manager-Region II

cc: K S AlviJ FriscoC TenerellaR FellnanF TsangS SchrcidP EnnekingJ GiordanoS Senior

01780

Ms. Lillian JohnsonMarch 21, 1990Page 2

OF &1CIZFT

Please acknowledge receipt of this enclosure on the duplicatecopy of this letter and return the signed duplicate letter to:Dr. Dev Sachdev, Ebasco Services Incorporated, 160 Chubb Avenue,Lyndhurst, New Jersey 07071.

Ms. Lillian Johnson Date

EPA WORK ASSIGNMENT NO. 226-2L91EPA CONTRACT NO. 68-01-7250

FINALRESPONSIVENESS SUMMARY

FOROPERABLE UNIT 01

OF THEPOEBLING STEEL COMPANY SITEFLORENCE TOWNSHIP, NEW JERSEY

KARCH 1990

NOTICE

The preparation of this document has been funded by the UnitedStates Environmental Protection Agency (U.S.EPA) under REWContract No.66-01-7250 to Ebasco Services, Inc. (EBASCO).

01752

REM III PROGRAM

REMEDIAL PLANNING ACTIVITIES ATSELECTED UNCONTROLLED HAZARDOUS SUBSTANCEDISPOSAL SITES WITHIN EPA REGIONS X-XV

CPA WORK A5SIGKHEKT NO. 226-2L91EPA CONTRACT NO. 68-01-7250

FINAL RESPONSIVENESS SUMMARYOPERABLE UNIT 01

ROEBLING STEEL COMPANY SITE

FLORENCE TOWNSHIP, NEW JERSEY

MARCH 1990

Prepared by:

Steven T. SeniorCommunity RelationsSpecialistICF Technlogy, Inc.

Approved by:

./tfoanne M. Giordano DateREM III Region XICommunity Relations ManagerXCF Technology, Xnc.

Approved by: Approved by:

DateREM III gion IISite ManagerEbasco Services, Xnc.

Dev R. Sachdev DateREM III Region XXPrograa ManagerEba&co Services, Xnc.

01758

OPERABLE UVIT 01FOR TEE

BOEBLINO STEEL COMPANY SITEFLORENCE TOWNSEIP, MEW JERSEY

FINAL RESPONSIVENBSS SUMMARY

The U.S. Environmental Protection Agency (EPA) held a publiccomment period froa January 8, 1990 through February 6, 1990 forinterested parties to comment on EPA's Focused Feasibility Study(FFS) and Proposed Plan for Operable Unit 01 of the Roebling SteelCompany cite and the sampling program conducted in the RoeblingPark.

In addition, the EPA held a public meeting on January 18, 1990 atthe Roebling Volunteer Fire Company f 3 Station in Roebling, NewJersey to discuss the FFS, outline the Proposed Plan, and presentthe EPA's preferred remedial alternatives for Operable Unit 01 forthe Roebling Steel Company site.

This document is a responsiveness summary highlighting commentsreceived at the public meeting and those received during thepublic corjsent period. It presents both those comments and theEFA responses to them. A responsiveness summary is required bySuperfund policy for the purpose of providing the EPA and thepublic with a summary of citizens' comments and concerns about thesite. All corusents summarized in this document vill be factoredinto the EPA's final decision for selection of the remedialalternatives for cleanup of the Roebling Steel Company siteOperable Unit 01.

This responsiveness summary is organized in the followingsections.

I. RESPONSIVENESS SUMMARY OVERVIEW

This section briefly describes the background of the RoeblingSteel Company site and outlines the proposed remedial alternativesfor Operable Unit 01.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

This section provides a brief history of community interest andconcerns regarding the Roebling Steel Company site.

III. SUMMARY 07 MAJOR QUESTIONS AND COMMENTS RECEIVED DURING TEEPUBLIC COMMENT PERIOD AND EFA RESPONSES TO THESE COMMENTS

This section summarizes both oral and written comments submittedto the EPA at the public meeting and during the public commentperiod, and provides the EPA's responses to these comments.

C1754

IV. REMAINING CONCERNS

This section discusses community concerns that the EPA should beav&re of as they prepare to undertake remedial design and remedialaction activities at the Roebling Steel Company site.

Attached are four appendices. Appendix A contains the ProposedPlan for Operable Unit 01. Appendix B contains the sign-in sheetof attendees at the January 18, 1990 public meeting. Appendix Ccontains the public notice issued to the Burlington County Ti»esand printed January 7, 1990 - January 8, 1990. Appendix Dcontains the Superfund Update distributed to approximately twohundred (200) individuals on the vailing lilt.

z. KxspovsrroresB ftnaauti aravziv1. fite Description

The Foebling Steel Company site is a large site, approximately200-acres, and is presently an inactive facility that vas usedfrom 1906 until 1982 primarily for production of steel products.In recent years, parts of the site have been used for variousindustrial operations. There are approximately 55 buildings on-site, occupying most of the site, connected by a series of pavedand unpaved access roads. Slag residue from steel production vasdisposed of on the western side of the site and filled in aportion of the Delaware River. Numerous potential sources ofcontamination exist at the site, including 757 drums containingliquids and solids, 106 tanks, 183 transformers containing PCB-contacinated oils, 52 railroad cars containing slag, dry sludgeand debris, pits and sumps, process buildings containing chemicaltreatment baths and numerous chemical piles, two sludge lagoons,friable asbestos insulation falling from pipes, a baghouse dustpile, tire piles, and a landfill.

The site is located in the Village of Roebling in FlorenceTownship, Burlington County, New Jersey (Figure 1). It isbordered by Second Avenue on the vest and Kornberger Avenue on thesouth. The Roebling Park, a public playground adjacent to thesite, consists of a large open area which includes swings,basketball and tennis courts, and a large elevated vater tower.The Delaware River forms the northern boundary of the site, andthe eastern shoreline of Crafts Creek forms its eastern boundary.U.S. Route 130 is located just south of the site.

Residential lands are located to the vest and southwest of thesite at a toning density of approximately eight dwellings peracre. The closest residences to the site are approximately 100feet away from the property boundaries and 250 feet south of theslag disposal area.

C1755

FIGURE tSITE MAP

ROEBLING STEEL

RIVER

B. EFA's Activities at the fit*

Recognizing the size and complexity of the Poebling Steel Companysite, the EPA has undertaken a vulti-tiered approach to addressingthe contamination problems at the site. This approach hasincluded removal activities and remedial activities. Removalactivities are those activities undertaken to decrease immediaterisks to public health and the environment. The TTS identifiesspecific removal actions for several contaminant sources that canreadily be disposed of and pose a significant risk.

Remedial activities are designed to determine the nature andextent of contamination on-site; to identify and analyze remedialaction alternatives to cleanup the site; and to eliminatepotential long-term health and safety risks.

Previous Perceval Actions

Previous removal actions at the Roebling Steel Company siteconducted by regulatory agencies included two cleanups: the firstvas performed in 1985 by the Kev Jersey Department ofEnvironmental Protection (NJDEP) and the second was performed in1987 - 1989 by the EPA. The objective of these actions were tostabilize areas then identified as the most hazardous areas of thesite prior to more detailed investigations (i.e. TTS and RI/FS).Explosive chemicals were removed from the site in the firstremoval action (1985). In the second removal action, lab packcontainers and drums of corrosive and toxic materials, acid tanksand compressed gas cylinders were removed.

Previous and Future pettedjal Action ActivitiesThe EPA has completed several phases of their remedial activitiesat the Roebling Steel Company site. The purpose of this phasedapproach is to most expeditiously address those contaminants thatwere identified as presenting an imminent threat to human healthand the environment and simultaneously address the remainder ofthe contaminants in a more methodical fashion. These activitiesincluded a preliminary site investigation and assessment of theproblem (i.e., identification of the contaminant sources), and theTTS to address those contamination sources identified in pastremoval actions.

Currently, a remedial investigation and feasibility study (RI/FS)is being conducted at the sit*. The RI/FS is an extensive study.The first stage of this study, the RI, defines the nature andextent of contamination and is used for conducting a public healthand environmental risk assessment. A sampling program iscurrently being conducted to determine the level and extent ofcontamination. Both source and environmental media are beinginvestigated including the following:

01757

Surface and subsurface soils;Surface water and sediments;Air;Croundwater;Buildings, landfills, tanks/baths, pits and sumps, pipeinsulation; and,

. Railroad cars, the slag pile, and lagoons.The second stage of the study, the PS, vill identify and evaluateremedial alternatives for addressing those contaninants identifiedin the RI as representing a threat to bunan health and theanvironaent.Those contaminant sources not removed in prior cleanup activitiesand still requiring expeditious assessment were the subject ofthis TTS and remedial alternatives were evaluated for thea. TheEPA's preferred remedial alternatives for those areas are detailedin the following section.

C. Summary of Preferred Seaedial Alternatives

The public meeting addressed both on-site and off-site areas ofconcern. The following section summarizes the preferred remedialalternatives for Operable Unit 01 at the Roebling Steel Companysite. These alternatives are described in detail in the TTS andin the Proposed Plan for Operable Unit 01 found in Appendix A.

On-5ite Areas of Concern

• DRUMS/DRUM CONTENTSDR-2 Overpacking of Drums and Off-site Disposal

e TRANSFORMERS/TRANSFORMER CONTENTSTR-2 Shipment of Transformers En Masse

a TANK CONTENTSTK-1 Bulking of Contents and Off-site Disposal

• BAGHOUSE DUSTEH-1 Off-site Treatment and Disposal

e CHEMICAL PILESCP-1 Off-site Treatment and Disposal

B TIRE PILESTP-1 Off-site Disposal

01758

Off-Site Area cf Concern;

• WATER TOWER SOILWT-3: Excavation/Treatment and Disposal

Selection cf an Alternative

The EFA's selection for remediation for the Roebling Steel Companysite Operable Unit 01 vill be based on the requirement* of theComprehensive Environmental Compensation and Liability Act(CEFCLA) and Superfund Amendments and Reauthoritation Act (SARA)regulations. These regulations require that a selected siteremedy be protective of human health and the environment, cost-effective, and in accordance with other statutory requirements.Current EPA policy also emphasizes permanent solutionsincorporating on-site remediation of hazardous vaste contaminationwhenever possible. Final selection of a remedial alternative villbe documented in the Record of Decision (ROD) only afterconsideration of all comments received by the EPA during thepublic comment period are addressed in this responsivenesssummary.

II. BACKGROUND OK COWfTOITY IMVOLVZXZKT AKD OOMCIRH8

Residents have expressed a high level of interest throughout theremoval operation, FFS, and during other site-related incidents(i.e. fires, picket lines). The community as a whole is proud ofits history as a company town around the J.A. Roebling's SonsCompany steel mill and would like to see the area revitalized.Residents believe they could have been kept better informed afterthe removal action performed by the EPA's Environmental ResponseTeam at the Roebling Steel Company site but have expressedappreciation for improved communications since then. The primaryconcerns citizens have raised include:

• uncertain communication lines between the EPA and localofficials and residents;

• potential health affects associated with exposure tocontaminants in on-site and off-site areas;

• impacts on local employment and the availability of biddingprocedures for local contractors; and

e potential fire hazards on-site and contingency planning.

01759

XZZ. SUXXA3Y or MAJOR O.UE8TXOM XKD COXXZKTf MCEITTft DURING TIEPUBLIC COKXZHT PERIOD JJTD IPX 118POMIIS TO TIESE COXXXVTfi

Concents raised during the public consent period for the FoeblingSteel Conpany site Operable Unit 01 and the ZPA responses aresummarized in the following section. Comments received during thepublic consent period axe organized into five categories: FocusedFeasibility Study/Remedial Alternatives, Health Related Issues,RI/FS Activities, Cost/Schedule Issues, and Future Activities.A. r&cused Feasibility ttndy/Xeaedial AlternativesConsentsSeveral issues were raised concerning the specific remedialalternatives preferred: specifically, would this remedial actionremove all of the drums on-site; and, could all the tanks on-sitebe dealt with at this tine, including those in the buildings.

EPA Response:

The planned remedial action includes the renoval of all knowndrurs froir the site. They vill be pacXed in over-pack drums andremoved to an appropriate disposal facility. In order to expeditethis reaedial action, the EPA has chosen not to renove those tanksin the buildings because of the poor structural integrity of aanyof the buildings, potential asbestos contanination, and safetyhazards that these present. Those tanks and other health andsafety hazards presented by the buildings vill be dealt with infuture reaedial actions.

Comment:

Clarification of the classification of transformers by type wasrequested at the meeting. Also requested was whether thisre&edial action includes the disposal of all transformers on-site.

EPA Response:

The preferred remedial alternative for transformers (TR-2)involves the shipment of those transformers containing PCB-contaminated oil to a fecility that vould properly dispose of thecontaminated oil, dismantle and clean the transformers and disposeof the carcasses. Those transformers on-site that are •dry" —those manufactured without oil — do not present a hazard.

Comment:

Questions concerning the amount and type of the analytical datapresented in the 7TS were asked. An individual felt that many ofthe analytical services performed were excessive and unnecessary.He questioned the use of RCRA parameters in some of the testing.

61760

IFA Response:

The analyses performed ver« done to properly characterize thecontaminants to be removed. The FF5 vas conducted vith the intentbeing to expedite the removal of those imminently hazardous areason-site. To do this, the EPA conducted many analyses during theTTS, which are often done during the remedial design phase ef acleanup, to expedite the cleanup activities.Comments

An individual questioned the quality assurance aspect ef theanalytical data presented in the TTS. Specifically, be felt thatthe numbers of unreported results, the numbers ef estimatedresults, and the analytical results of the qualityassurance/quality control samples potentially indicated anunacceptable level of confidence in the analyses.IPX Xesponsa:

The EPA determines data quality objectives based on expectedresults and potential remediation techniques being examined.Given available information on the areas addressed in the TTS andthe desire to expedite remediation, the EPA has determined thatthe analytical results are sufficient to proceed vith the remedialactivities.

Comment:

Mayor Benedetti requested that the EPA consider temporarilycapping the slag area of the site. He indicated that a potentialsource of capping material could be obtained from the BurlingtonCounty Solid Waste Authority.EPA Kesponse:

The EPA is approaching the remediation of the Roebling SteelCocpany site in phases. The FFS has addressed several areas thatrepresent a high hazard. The slag area vas not addressed by thisFFS but vill be considered in the future by the on-going RI/FS.The EPA vill consider all suggestions for remediation from localofficials and interested parties.Comment:

Kayor Benedetti and several residents expressed concern that theslag area and the off-site vater tower area are still accessibleto children. They asked if the EPA vould be restricting access tothese areas and could these efforts be expedited.

EPA Response:

The EPA is currently axpediting tht restriction of accecc to theseareas. Fencing and signs indicating the presence ef hazardoussubstances will be utilised.

Comment:

An individual asked for clarification ef the hazards that the slagarea presents to residents and thought that capping it vould be anaffective method of remediation as it vould renove human contactfrom the hazard.IPA ResponsesThe health hazard from the slag area includes heavy »etalscontamination and is one that primarily affects the children thatplay on the slag. Zngestion of soil from the area is consideredthe primary pathway of contamination. The EPA Bust consider bothhealth and environmental impacts when selecting remedialalternatives. Heavy metal contamination in the slag nay impactenvironmentally sensitive areas like the Delavare River.

Comment:

Several individuals indicated that they thought that the tires on-site should be dealt with expeditiously since they represent afire hazard.

ZPA Retponse:

The EPA is currently exploring options for disposal of the tiresto deal with then quickly and safely.

Potentially Responsible Party (PRPJ Comment!

In addition to the residents comments at the public meeting, a PRPsubmitted written consents regarding the types and amount ofanalytical services performed on the various media that weresampled. The PRP questioned both the quality assurance aspect ofthe analytical data presented and the cost efficiency of themethods used.

tPA Response:One of the EPA's primary goals in conducting its TTS vas toproceed as expeditiously as possible without sacrificing qualityin data collection or inefficiency in costs. The EPA hasextensive quality control and quality assurance programs toaccomplish those goals.

C1762

PRP Comment:

A PRP made several written comments in regards to the remedialalternatives evaluated for transformers/transformer contents, tankcontents and baghouse dust.

ZPA Response:Specifically, the PRP suggested alternatives for disposal that areconsistent with the preferred remedial alternatives. The EPA willconsider all such suggestions during remedial design.

B. Eealtb Belated IssuesComment:

An individual who stated he was a »ember of the citizens group,People United for a Clean Environment (PUCE), noted what heperceived to be an unusually high incidence of cancer in theRoebling area. He indicated that he believed this vas a directresult of the proximity to the Roebling Steel Company site andthat the potable groundvater supply in the area vas contaminatedfror the site. He asked if groundvater sampling vas beingconducted at the site.

AT8DR/EFA Response:

The New Jersey State Department of Health has been contacted, anda request has been made, to investigate cancer rates via theircancer registry to determine if the Roebling area has an unusuallyhigh rate of cancer compared to the general population. It shouldbe noted that residents in proximity to the site utilize municipalwater which to date has shown no signs of contamination. Ground-water sampling is a component of the ongoing RI/FS at the site.

Comment:

Mayor Benedetti requested that the EPA be involved in developing ablood testing program for children living in the immediatevicinity of the Roebling Park vater tower.

EPA Response:The EPA vill forward this request to the Agency for ToxicSubstances and Disease Registry (ATSDR).

Comment:

Several individuals inquired about contingency planning for thesite: specifically, is a contingency plan currently in place or indevelopment and would a site specific health and safety plan bedeveloped. A local fire department member expressed concern that

10

C1763

coordination with the EPA officials had been poor and that thelocal emergency responders vere anxious to be a part of thedevelopment of contingency plans for the »ite.IPA Response:

Health and safety plans and contingency plans are developed as anelement of the Superfund remedial process. Currently, a sitespecific health and safety plan exists for the ongoing RI/FS. Znaddition, during remedial design, health and safety andcontingency plans are developed in conjunction with townshipofficials including health, police, and fire department officials.

C. fcX/rs Activities

Consents

Mayor Benedetti and a resident requested soil sampling for theresidential areas adjacent to the sita.

EPA Response:

The EPA plans to sample surface soil of residential propertiesadjacent to the vater tower area in the near future. Propertyovr-ers have been notified and several consent agreements foraccess to the properties to perform surface soil sampling havebeen signed.

Comment:

A resident inquired about the results of sampling activities shewitnessed in the playground area adjacent to the main gate at thesite.

EPA Response:

Analytical results from the sampling conducted during the RZ/FSwill be presented in the Roebling Steel Company site RI report.

D. Cost/Schedule Issues

Comment:

An individual asked about the costs of the cleanup: specifically,hov it was being paid for, if Superfund monies were being used,and how Superfund monies were generated.

IFA responsei

Currently, Superfund monies are being utilized to expedite thecleanup of the Roebling Steel Company site. An important elementof the Superfund program is cost recovery of axpeditures from

11

01764

responsible parti**. The EPA will explore all avenue* availableto recover costs at the site. All Superfund »onies spent to datehave been generated through a tax on the petrochemical industry.

Coaaent:

Several individuals asked about the schedule for the plannedremedial action for Operable Dnit 01 and the overall remediationof the site.

IPX Response:Although there is currently no precise schedule available, the EPAhas expedited the remedial design with the help of the Amy Corpsof Engineers to complete the planned remedial action for OperableUnit 01 as soon a* possible. As »ore information becosesavailable through the completion of the ongoing RI/FS, a Boreprecise schedule for remediation of the entire site can bedeveloped.

Comment:

An individual asked if disposal areas had been obtained for thosematerials being removed from the Roebling Steel Company site andwhether the availability of such disposal sites could cause delaysin the planned remedial activities.

ZPA Response:Remedial contractors provide proposed disposal areas in their bidpackages which must be approved by the EPA. This vill occurduring the upcoming remedial design for the site. At this time,the EPA does not foresee delays caused by the availability ofdisposal sites for the known contaminated »edia.

Z. Future Activities

Comment:

An individual asked if future remedial actions conducted at thesite would result in the solicitation of bids for contractors.

IPA Response:Bids will be solicited by the U.S. Army Corps of Engineers forconstruction type work during future remedial actions.

Comment:

Several individuals expressed interest in the status of ownershipand control of the site.

12

01765

E?A Response:

Title to the property is held by the John A. Roebling SteelCompany (JARSCO), currently in bankruptcy. JARSCO was foraedthrough financial assistance provided by the U.S. EconomicDevelopment Administration. When JARSCO defaulted on a loanguaranteed by the EDA and ceased operation at the cite, EDA becamea creditor in possession for the purposes of liquidation.However, the EDA has not foreclosed on its loan and thereforeJARSCO remains the site ovner. In addition, the State of NewJersey has declared JARSCO void by proclamation. The EPAmaintains primary control of the site for the purposes ofresponding to removal and remedial actions.Comments

Several individuals asked about the fate of the site afterremediation including the fate of the buildings on the site.

IPX Response:

It has not been determined at this time whether any of thebuildings on-site would need to be demolished as part of theremedial actions. Currently, the EPA has access to the sitethrough the U.S. Economic Development Administration. The EPAdoes not acquire ownership of Superfund sites during theirremediation and therefore would be unable to determine theultimate fate of the property.

IV. KEKAIKING CONCERHB

Issues relative to the EPA's close coordination of their remedialefforts with township officials and residents will continue to becritical areas of concern. Such issues would include the EPA'scommunication of site related information as it pertains torestricted access to site areas, health and safety and contingencyplanning, and the availability of information regarding sub-contracting of construction work during the remedial actionimplementation.

13

01766

XIPETOII X

01767

Superfuod Update

Roebling Steel Company Site

EPAf,Region 2

Roebling, New Jersey

PROPOSED PLAN

ROEBLING STEEL COMPANY SITEFJorrnee Township, New Jeney

ANNOUNCEMENT OF THEPROPOSED PLAN

This Proposed Plan identifies the preferredoptions tor addressing several imminentlyhazardous areas at the Roebling Steel Companysite. In add i t ion , the Plan includes turn manesof other alternatives ana hied for this interimremedial action, designated is Operable UnitOne (OU-01). This document is issued by theU.S Environmental Protection Agency (EPA),the lead agency for site activities, and the NewJersey Department of Environmental Protection(NJDEPj, the suppon agency for this project.The EPA. in consultation with the NJDEP, willsclcc: a i n t e r im remedy for the site only afterthe p u b l i c comment period has ended and thein format ion submit ted during this time has beenreviewed and considered.

COMMUNITY ROLE IN THESELECTION PROCESS

The EPA is issuing this Proposed Plan as penof its public participation responsibilities utder»ection 117(a) of the ComprehensiveEnvironmental Response, Compensation, andLiability An (CERCLA). This documentsummarizes information that can be found ingreater detail in the Focused Feasibility Studyreport (FFS) and other documents contained IBthe administrative record for this site. TbeEPA and the Sute encourage the public torevic* these other documents to gain a morecomprehensive understanding of the site andSuperfund activities that havt been conductedthere.

Written comments can be sent to:

Tamara Ro&siRemedial Project ManagerU.S. Environmental Protection AgencyRoom 71126 Federal PlazaNew York, NY 10278

The administrative record, which contains theinformation upon which the selection of theresponse action will be based, is available at:

Florence Township Public Library1350 Hornberger AvenueRoebling, New Jersey 08554(609) 499-0143

Florence Township Municipal Building711 Broad StreetFlorence, New Jenev 08518(609) 499-2525

SITE DESCRIPTIONi

Tbe Roebling Steel site is • 200-acre, inactivefrcfliry that was used from since 1906 until 1982primarily for production of steel products. Inrecent yean, pans of the site have beea usedfor various industrial operations, Taere areapproximately 55 buildings on-siie conceded bya series of paved and unpaved acres roadsoccupying most of the site. Slag residue fromnee! production was used to fill in I largeportion bordering the Delaware River shoreline,

Numerous potential sources of contaminationexist at the sue, including 757 drums conuininfliquids and solids, 106 abandoned tanks, 1S3transformers containing PCB-contaminaied oils.52 railroad can containing fly-ash, dry (Judgeand debris, pits and sumps, process buildingscontaining chemical treatment baths, two sludgelagoons, friable asbestos insulation falling frompipes, a bagbouse dust pile, chemical piles,compressed gas cylinders, tire piles, and aland fill.

The site is located in the village of Roebling inFlorence Township, Burlington County, NewJersey (Figure 1). Ii is bordered by SecondAvenue on the west and Komberger Avenue onthe south. The Rocbling Park, a public

playground adjacent to the site, consists of alarge open area which includes swings,basketball and tennis courts, and a largeelevated water tower. The Delaware Riverforms the northern boundary of the site, andCrafts Creek forms iu eastern boundary. U.S.Route 130 is south of the site.

Residential bods are located to the west andsouthwest of the site at a zoning density ofapproximately eight tfwellinp per acre, Theclosest residences to the site are approximately100 feet away from the property boundaries, 250feet from the slag pile and 1.200 feet from thesludge lagoons and wistrwiter treatment plantmi let

FIGURE 1

SITE MAP

WVti

01*9

SCOPE OF THE OPERABLE UNIT

Because or the size and complexity of theRoebling Steel site the EPA is addressing itsremediation in phases, or operable units.

• Removal Actions included two cleanups, thefirst was performed in 1985 by the NJDEP, andthe second was performed ia 19T7 -1988 by theEPA, The objective of these actions was tostabilize the most hazardous areas of the site,Explosive chemicals were removed from the aitein the 19&5 removiL In the second removalaction, lab pack containers and drums ofcorrosive and toxic materials, acid tanlo andcompressed gas cylinders were removed.

• Operable Unit 01 is the subject of thisProposed Plan. It will address those on-siteareas tha: pose i sufficient)) imminent hazardto require expedited remediation but were toocomplex or required too expensive a responseto address during the removal actions. Theseareas include the remainifil dnims and exteriortanks, transformers, a baghouse dust pile,chemical piles, tires, and the remaining fascylinders. It will also address the soil under thewater tower in the Roebling Park adjacent theRoebling Steel site.

• Operable Unit 02 will determine the natureand extent of contamination over the entire site.A remedial investigation and feasibility atudy(RLTS) is currently being performed that willaddress the remaining areas of contamination atthe sue. The RLTS will examine soils, surfacewater, groundwater, sediments, air, lagoons andother remaining contamination sources.

SUMMARY OF SITE RISKS

The FFS developed remedial objectives for theareas of concern in the interim action, based onthe nature and extent of the contaminants andthe imminent hazard posed by each area.Vandalism and trespassing are two majorconcerns at the site and seriously aggravate thechemical and physical hazards present. Inaddition, trespassing and vandalism at the aitein the pas: have required the use of expensivesecurity measures. A brief description of the

risb associated with each area and the remedialobjectives developed to address those risksfollows.


DRUMS/DRUM CONTENTS AND TANKCONTENTS

Both the drums and the tanks contain s varietyof hazardous (loxJc, corrosive, and reactive)constituents. There are two major concernsassociated with the drums and the tanks.Trespassers may be exposed to hazardouschemicals if they approach or tamper with anyof these containers. Abo, because the drumsand the tanks are mostly very deteriorated, theymay teak a: any time, releasing hazardoussubstances that present a risk of direct humanexposure as well as a release of these materialsinto the environment.

The drums and tanks are imminent hazardsbecause of the nature of the contents and thecondition of the containers themselves. Anexpedited action is required to isolate theCOD tents of these containers from theenvironment and any trespassers.

TTUNSFORMERS/TRANSTORMERCONTENTS

The transformers contain oil contaminated withhigh levels of PCBs. Any oil that kaks fromthe transformers will pose a serious andimminent threat to public health and theenvironment. As the transformers wflleventually have to be removed from the site,addressing them during the interim action isconsistent with the overall remedy for the site.

COMPRESSED GAS CYLINDERS

An inventory of the remaining cylinders wascreated during the FFS, and it was discoveredthat they are all old fire extinguishers. Thesecylinders do not contain hazardous constituentsand, therefore, do not pose a physical orchemical hazard. In the absence of a hazard,there is no remedial objective for the cylindersand remedial alternatives were not developedfor them.

01T70

BACHOUSE DUST AND CHEMICAL PILES OFF-SITE AREA OF CONCERN:

The baghouse dust and chemical piles weresampled in the FFS and were found to containhi|h levels of several heavy meals, such as lead,chromium and cadmium, many of which aretone and/or carcinogenic Bagbouse dust fromsteel manufacturing electric arc furnaces is alisted RCRA waste. This pile was exposed tothe weather and was temporarily stabilizedduring the removal action with plastic coven.These coven may become degraded by theweather and cease to provide effectivecontainment. The hazardous constituentsmeasured in the baghouse dust will teach intothe environment and may also pose a healthrisk 10 trespassers through direct exposure.Chemical piles are located in buildings at thesite. Trespassers may be exposed to thiscontaminant.

The bag house dust and chemical piles currentlypose hazards to public health and theenvironment. The remedial objective for theseareas of the site is to isolate the hazardousconstituents from the public and theenvironment.

TIRI PILES

Approximately ten thousand tires are locatedboth inside and outside of buildings in pilesprimarily around the south eastern portion ofthe site. On several occasions fires haveoccurred in the tire piles. The tire firesconstitute a chemical threat to public healthand the environment as well as a physicalhazard. Burning tires release hazardousconstituents into the air and produce a tonetar-like sludge.

Based on the history of tire Ores at the site andthe probability that these fires have been startedby vandals, the tires should be removed fromany areas that may be available to public

WATER TOWER SOIL

The surface coil under the water tower in theRoebling Park is contaminated. The analysis ofsamples colkoed under the water towerindicates unacceptabry high concentrations oflead in an tret adjacent to playground that isfrequented by young children. Low levels ofFCBs have also been detected. The IncidentalDigestion of soil from this area presents apublic health risk to children, particularly ofpreschool age. Remediation of sorficiaJ soils inthis pan of the park would reduce the risk fora segment of the most sensitive subpopulation,young children. The lead levels in the soilsamples outside the water tower area of thepark are typical of the lead levels found in •residential or urban area.

SUMMARY OF ALTERNATIVES

The FFS presents remedial alternatives toaddress six areas of concern at the site: drams,transformer*, tanks, baghouse dust pile,chemical piles, and tires. In addition, remedialalternatives were considered for the off-sitewater tower soil. A wide range of technologieswas considered to address the remedialobjectives for each of these areas. Thetechnologies thai were not eliminated fromconsideration during screening were assembledinto remedial alternatives. In addition to thealternatives described below, a No Actionalternative was considered for the water towersoil and on-n'te areas of concern.

NO ACTION

The No Action alternative provides a baselinefor comparing the alternatives that provide agreater degree of response. Under thisalternative, BO effort would be made to changeor maintain the current status of the drams,transformer*, taaJa, baghouse dust pOe,chemical piles and tires. The container vessels(drums, transformers, tanks) would continue to

degrade and potentially leak hazardoussubstances. The temporarily contained anduncontained contaminated materials (baghousedust and chemical piles, respectively) wouldcontinue to migrate. The tires would remain inplace and another fire might occur. Under theNo Aojon alternative, no remedial action wouldbe implemented to eliminate the health riskposed by the contaminated toil under the watertower. No remedial technology would beutilized to reduce the toririry, nobility orvolume of the waste. The No Actionalternative is retained as a baseline alternativefor each contamination source.

ON-51TE ARJEXS OF CONCERN:

DRUMSDRUM CONTENTS (DR)

DR-1 Drum Bulking and OfT-sIu Disposal

Estimated Cost: S 869,000Implementation Period: within one year

Under this alternative, action would be taken toremove the drums from the site and to properlydispose of the wastes. First, any deteriorateddrum would be overpacked. All drumsccnia-.nir.g wastes would thec be sampled. Thesample* would be tested to determinecompatibiliry of tie wastes. Drums containingcompatible waste would be staged (grouped)un t i l Tina! waste bulking. Prior to finaldisposal, the contents of each staged dnunwould be consolidated (bulked) into a bulkingchamber with the contents of other drums ofcompatible material One waste sample wouldbe taken from each bulked category; thesesample would undergo rigorous analyticaltesting to determine the appropriate method offinal disposal for each category. The bulkedwaste would be loaded into a tanker truck andhauled off-site to a RCRA approved treatmentfacility or to a hazardous waste disposal tttility.After bulking, empry drums would be crashedfor disposal.

DR-2 Overpacking of Drums and Off-siteDisposal

Estimated Cost: S 1.47&000Implementation Period: within one year

This alternative involves overpacking each drumof waste at the siu in an approved container toprevent further leakage or (pillage of the drumcontents. This alternative would includesampling of each drum along with a completedisposal parameter analysis. Once the drumsare overpacked, they would be hauled off-site toa RCRA approved treatment facility or to ahazardous waste disposal facility.

TRANSFORM ERS/TRANSFORMERCONTENTS (I*)

TR-1 Bulking and Irvdntntioo of PCB-Contaminated LJquids/Disraantltng andDisposal of Transformer

Estimated Cost: S IjMO.OOOImplementation Period: within one year

This alternative involves the consolidation ofthe contents of individual transformers into atanker to be shipped off-site for incineration.Tbe contents would be tested beforeconsolidation to ensure thai the materials tretreated appropriately based on the concentrationof PCBs present. Tbe transformer carcasseswould be decontaminated before off-sitedisposal

TR-2 Shipment of Transformer! ED Masse

Estimated Cost S 1̂ 40,000Implementation Period: within one year

This alternative involves shipping thetransformers and their contents to a ocQiry thatwould properly dispose of the PCB-contaminated ofl, dismantle and dean thetransformers and dispose of the carcasses.

TANK

TX-I

CONTENTS •̂OK)

Bulking of Contents and OfT-ilteDisposal

Estimated Cost: J 1,480,000Impiemenution Period: within one year

This alternative iovoNes the removal ofconuminated material from exterior tanks todshipment to an off-site RCRA approvedt reatment facility or to a hazardous wastedisposal facility. The contents from these tankswould be tested, bulked and consolidated intosimilar waste streams for disposal The tanksthemselves would be decontaminated during thelong-term RLTS, when unto are removed fromthe site. The remaining unto and unkcon ten is located inside buildings will also beaddressed in the RUFS.

BAGHOUSE DUST (BE)BH-l OfT-sitc Trejuuent and Disposal

Estimated Cost: S 405,000Implemenuuon Period: within one year

This alternative invorves the removal ofapproximately 530 cubic yards of baghouse dustto an off-site RCRA approved treatment anddispou; facility The das; was consolidated intoone pile during the previous removal action,covered wuh vt^queec and urps, and secured bylarge concrete barriers. Sand bags were used toreduce migrat ion from the base of the pile bysecuring the urp onto the pile. The wastewould be loaded into approximately 30 roll-offcontainers and transported to an off-site RCRAapproved treatment and disposal facility. Off-sitedispou! would be used in conjunction with apre-disposal treatment measure, such assolidification or stabilization, that would becapable of physicaJry or cbemJcaDy bindinginorganic conuminants and significantlyreducing their potential to kach.

CHEMICAL PILES (CP)

CP-1 Off-site Treatment and Disposal

Estimated Cost: S 21,000

Impiemenution Period: within one year

This alternative iovoNes the off-site treatmentand disposal of approximately twenty-four tonsof material from seventy-nine chemical pilesscattered throughout the site. Material fromthese pOes would be consolidated andtransported to an off-site RCRA approvedtreatment and disposal facility. As with thebagiouse dust, off-site disposal would be usedin conjunction with a pre-disposal treatmentmeasure, such as solidification or subiiization.

TIRE PILES <TP)

TP-1 Off-site Disposal

Estimated Cost: S 12.000Impiemenution Period: within one year

This alternative invoNes the removal and off-site disposal of approximately 10,000 tires andburnt rubber. At present, most of these tiresare stored in and around Buildings 18 and 70.

OFT-SITE AJtEA OF CONCERN:

WATER TOWER SOILvYT-3: Excarition/Treauneot ind Disposal

Es Lima ted Cost: S 64300Impiemenution Period: within one year

Under this alternative, contaminated soils underthe water tower will be excavated to a depth of6 inches using ordinary construction equipment(backhoes and front-end loaders). The volumeof contaminated soil tt approximately 120 cubicyards. The exravated area would be backfilledwith v neon umina ted soO and revegeuted. Theeonuminatec* soils would be loaded intoroUoffc, transported to the Roebling Steel sitefor temporary storage if necessary, aod thensent to a RCRA approved treatment aaddisposal facility. Disposal of the contaminatedsoD wooM be used in conjunction with a pre-tfbposaJ treatment measure, soch assolidification or subilizauon, that would becapable of physically or chemically bindinginorpru'c contaminants and sipificantlyreducing their potential 10 teach. It should be

noted thai the focused feasibility study refers toalternative as PS-3.

EVALUATION OF ALTERNATIVES

EPA uses nine criteria to evaluate tbealternatives and to select a preferred alternativefor each source. This section discusses aadcompares the performance of the remedialalternative under consideration for e»c± sourceagainst these criteria. Tbe nine criteria aredescribed in the following glossary. Tbecriterion for long-term effectiveness andpermanence was adapted for the interim actionso tha; alternatives that are not permanentremedies by themselves will be considered ifthey are consistent with the final remedy for tbesite.

ANALYSIS

Each area of concert is considered separatelybelow. For each area, the first seven evaluationcriteria are considered in the order they arelisted above and the menu of each alternativerelative to tha: criterion are evaluated.

NO ACTION

The No Action alternative for each source areawould not provide protection of public healthor the environment. Contaminants wouldremain in ihei; present state with potential forleakage and migration. There b a potential riskthrough diren exposure to the contaminants.Tbe No Action alternative fails to meet theremedial objectrvts, and therefore, it iseliminated from further consideration in thedetailed analysis,

ON-SITE ARIAS OF CONCERN:

DRUM&DRUM CONTENTS

Removal of the wastes and treatment at an off-site facility in both of the remaining alternativesPR-1 and DR-2) would prevent i release of

Overall Protection of Human Health todE&vlroaBeat addresses whether or not aremedy provides adequate protection anddescribes bow rfab posed through eachpathway are eliminated, reduced, orcontrolled through treatment, engineeringcontrols, or institutional controls. : v

* Compliance with AKARs addresses whether:«r not a remedy will meet aD of the .....:,-.:applicabk or relevant and appropriaterequirements of other r«deraJ and Stateenvironmental statutes and/or providegrounds lor invoking a waiver. •'."'"''• .'. " :Long- tens Effectivtoesi and Permanenc*refers to the magnitude of residual riskand the ability of a remedy to maintainreliable protection of human health andthe environment over time once remedialobjectives have been metReduction of ToxJdrj; Mobility or VolumeThrough Trtatnxflt is the anticipatedperformance of the disposal or treatmenttechnologies thai may be employed in a

' remedy. , - , . v ^••.:-f:i.- ; • • ;., ;.•....-:•• • ' :- - -:- ' • ',• •Short-term EffertJveneu refers to thefpeec* wiih which the remedy achievesprotection, at well as the remedy'spotential to create adverse impacts on

.human health and the environment that ;may result doring the construction andimpfementation period. : . • ::ImplcmeatabUirj b the technical andAdministrative feasibOiry of a remedy,.including the avmBabQity of materials andservices needed to implement the chosen

re/e« to estimites •used to compareamong various aJternatrves.;^^.^;;'.AecepfaiKt Indicates whether, bided

its Tcview of the FFS and PTOpoaedthe NJDEP concur* wfth, opposes, :

has no cpmmeni on the preferred ^ ::'

b CoffiBunrty AcceptaJx* wTD be tfff* Jnf-the'Kecord ofpecision following a reviewt- of (he poblk commecu received on the' • JFS report and the Proposed Plan.

01174

8

hazardous substances to the environment, andwould fully protect human health and theenvironment. Both alternatives were usedduring the past removal action.

There are no chemical-related ARARs thatneed to be met for implementinf thesealternatives. Activities related to the handlingof wastes and the transportation to an off-sitefacility would be accomplished in accordancewith the Department of Transportation (DOT)regulations and hazardous waste managementrequirements. The waste would be removed so aRCRA-permJtted facility.

Both alternatives DR-1 and DR-2 effectivelyremove the waste from the litt, eliminatin| thepotential threat 10 human health. As thehazardous subs unto would be removed andtreated rather than just contained or managed,either alternative would provide a permanentremedy.

Treatment would eliminate the tenacity and/orvolume of the waste. In addition, the removalof drums from the site will eliminate thephysical hazards associated with drums thatmight in jure trespassers or rupture and leaktheir contents.

The shon-ierm effectiveness of both alternativesis high, as bcib car be quickly implemented andboth will immediately address the hazards posedby the drums. Hcra^ever, the overpackingalterative requires less time to implementbecause the majority of the activity would beperformed off-site. A&arysis for thecompatibility testing for the bulking operationcan be performed in an on-site mobilelaboratory.

Adequate worker protection duringimplementation activities can be ensured bywearing the proper level of protection, followingthe proper handling protocols, and good safetypractices. There is an increased risk associatedwith the bullring operation compared to theoverpacking of drums because there it more on-site maneuvering of hazardous wastes.

De-site bulJting and off-site treatment (J869,000) is less expensive than individually

overpacking the drums and shipping them to anoff-site facility for treatment (5 1,476,000). Thecost estimates for both alternatives are wontcase scenario*. These estimates are based onusing incineration to treat all of the waste.However, sampling may indicate that someother treatment method may be appropriate.

TRANSFORMERS/TRANSFORMERCONTENTS

Both remedial alternatives, bulking andIncineration of transformer oils, and dismantlingand disposal of the transformer carcasses (TR-I); and shipment of the transformers en masse(TR-2), are protective and constitute a finalremedy. The threat of PCB-contaminated oilleaking from the transformers would beaddressed. Both alternatives utilize incinerationto permanently destroy the contaminants.

There are no chemical-specific ARARs thatDeed to be met before implementation.However, in implementing the action, all oilcontaining PCBs, must be treated in accordancewith the Toxic Substances Control Aa (TSCA).

Botb alternatives effectively remove the ofl fromthe site, eliminating the potential threat tobuman health. Incineration of ?CBcontaminated oil provides a permanent remedy.Botb alternatives are consistent with the long-term remedy.

Incineration of (he contaminated oil will totallydestroy tostity and mobility of the waste, andwill reduce the volume of the ofl. la bothcases, the transformer would be removed fromthe site.

Short-term effectiveness is high for bothalternatives, as the contaminated ofl would beremoved from the site and treated. Bothalternatives achieve their maximum effectivenessquickly, although alternative TR-2 requires lesstime to implement than TR-1. Short-termhazards Involved in handling and transportingthe oQs indude risks to workers as well as apotential threat to trespassers that might comein direa contact with acddenuHy spilled waste.Any short-term impacts during Implementation

01775

car, be mitigated by following proper protocolsand requirements.

The multi-staged process of sampling andbulJang the PCB-contaminated oil transportingit to an off-site incinerator, and dismantling anddisposing of the transformer carcasses increasesthe risk during implementation activities ofalternative TR-1.

Shipment of transformers en masse(S 1,540,000) is cheaper then bulking anddismantling al] the transformers (S 1340,000),and can be performed in an expedited fashion.

TANK CONTENTS

Bulking of tank contents and off-site disposal(TK-1) is very protective of human health andthe environment because it eliminates the futurethreat of leakage by further deterioration andtampering of the tank. There are no chemicalrelated A.~_ARs that seed to be met beforeimplementation. However, shipment anddisposal must be treated ic accordance withRCRA. if the contents are RCRA wastes.

Bulking of tani contents and off-site disposal isthe only alternative that pisses the thresholdevaluation. Disposal of the waste to an off-siteRCRA approved treatment and disposal facilitymay reduce its tocciry, mobility, and volume,and is a permanent treatment technology.

The short-term risks associated with bulking andtransporting the waste to a disposal facility areminimal because of the small volume of wastefound in the tanks being addressed. The wastestream characterization should not be complex,which would limit the number of bulkingchambers and tanier trucks. In addition, theapproach can be quickly implemented becauseof the small number of lank*.

The estimated cost of this alternative isS 1,480,000.

BACHOUSE DUST

Off-site treatment and disposal of the baghousedust is protectrve of human health and theenvironment because it eliminates the risk of

direct exposure, which may occur throughtampering, or weathering of the tarp.Landfiiling this material invoNes the placementOf a restricted RCRA listed waste (K061-emissfon control dustAludgt from the primaryproduction of steel in electric furnaces) andRCRA Land Disposal Restrictions must beconsidered before the waste is land disposed.Treatment standards, either concentration levelsor a specified technology, would be determinedbefore the material can be removed to a

Disposal of the baghouse dust to an off-siteRCRA approved treatment and disposal facilityis the onJy alternative thai passes the thresholdevaluation. This alternative eliminatesmigration and, depending on the treatmenttechnology, may decrease tobtiry. Off-sitedisposal used in conjunction with a p re -disposaltreatment measure would be consistent with thelong-term remedy.

The short-term risks associated with thisalternative can be minimi.7/id by using dustcontrol measures to prevent migration caused bymoving vehicles and equipment, and winderosion during the implementation stage. Thewaste would be loaded into approximately 30roll-off containers and transported to thetreatment and disposal facility.

The cost of this alternative is estimated at5405,000.

CHEMICAL PILES

Off-site treatment and disposal of the chemicalpQes is protective of human health and theenvironment because ft eliminates the risk ofexposure by migration and direct contact at thesite. This alternative invorves the removal ofwaste to an off-site RCRA approved treatmentand disposal facility and must comply with theappropriate land disposal restrictions.

Off-sfte treatment and disposal of the chemicalpiles is the onJy alternative that puses thethreshold evaluation. This alternative raises thesame issues regarding dust control measures andland disposal restrictions as were considered forthe bajboase dost

01776

10

The cost of this alternative is estimate at$21.000.

*TIR£ PILES

Off-site disposal of approximately 1CWXJO tires isa final remedy to the threat of future tire firesand is protective of human heaJth aad theenvironment. There are no chemical-relatedARARs thai need to be met.

Tire Tires are particularly hazardous because ofthe petrochemical composition of the tires.When ignited, the tires produce a smoke plumethai contains many gaseous byproducts andpanicu'aies, including hazardous organiccompounds. Burning tires produce oils thai canmake the fire uncontrollable. There b also apossibility of the fire spreading to an areawhere flammable or explosive chemicals arelocated. Removing the tires would insure theprotection of human health and theenvironment from this hazard.

Off-site disposal of tires is the only alternativethat passes the threshold evaluation. Thisal ternat ive is a permanent remedy and iseffective in eliminating the future threat of tirefires and the production and migration ofhazardous by-products.

The disposal of tires has no shon-term effectsand is readily implemeniable. The cost of off-site disposal of the tires is Si2,000.

OFF-SITE ARIA OF CONCERN:WATER TOWER SOILUnder this alternative, action would be taken toexcavate the contaminated soil and transport itto a RCRA approved treatment and disposalfacility. The contaminated surface toil blimited to the area directly under the watertower.

Treatment and disposal of contaminatedmaterial to an off-site facility would fullyprotect h u m a n health and the environment.RCRA Land Disposal Restrictions must beconsidered before the waste is land disposed.

Treatment standards, either concentration levelsor a specified technology, would be determinedbefore the material is removed to a landfillActivities related to the handling of wastes andtransportation to an off-site facility would beaccomplished it accordance with U.S.Depanmeat of Transportation (DOT)regulations and hazardous waste managementrequirements. Any temporary storage of rollofbor drums containing contaminated material onthe Roebling Steel site would be conducted inaccordance with the RCRA standards regardingstorage of hazardous waste for off-site disposalThe contaminated material will ultimately beremoved to a RCRA-permitted facility.

This alternative will effectively remove the wastefrom the area, eliminating the potential threatto human health. Since the hazardous materialwill be removed and properly disposed, thisalternative would provide a permanent remedy.This alternative would eliminate futuremigration of the contaminated soil

The short-term effectiveness of this alternativeis high, as it can be quickly implemented andwould immediately address the hazards posed bythe contaminated soils. Worker hazards wouldbe minimal due the nature of the removalAdequate worker protection duringimplementation activities can be ensured byfollowing appropriate safety practices.

Excavation and off-site treatment and disposalof the contaminated soil under the water towerb the only alternative that passes the thresholdevaluation. The cost of this alternative bapproximately $64,800.

SUMMARY OF 1HEPREFERRED ALTERNATIVES

The EPA and the NJDEP have evaluated theremedial alternatives in accordance with Section121 of CERCLA and {300.430 of the NCP, anddeveloped preferred remedies for interim actionOB etch of the areas of concern at the site,based on the findings of the FFS. The public bencouraged to review all of the findings of theFFS and offer comments on that document and

01777

11this Proposed Plan. The EPA and the NJDEPwill noi select a final remedial alternative untilafter all comments received during the publiccomment period have been considered. Thefinal selected remedy will be presented ia theRecord of Decision (ROD).

The evaluation of the aJtemauva in theprevious section discussed each of theaJiernatives relative to criteria established underthe Superfund law and regulations. The intentof the interim action is to stabilize those areasof the siie thai require ac expedited response,and to implement remedial actions that will, tothe greatest extern practicable, be consistentwith the final remedy at the site.

In summary, the preferred remedies for each ofthe areas of concern are presented below. Thepreferred remedy would stabilize those areas ofthe siie that were determined to requireexpedited at tent ion and would provide at leastsbon-ierm protection of public health and theenvironment. The interim action wilJ beimplemented in accordance with all Federal,State, and local requirements.

SUMMARY OF PREFERRED ALTERNATIVES

DRUMS DRUM CONTENTS: Overpackang andoff-site disposal PR-2), at a cost ofapproximately 51,476,000, is preferred overbulking of drum contents and off-site disposalPR-1), which cosu approximately $869,000,because there are fewer short-term risks and itrequires less time to implement.

TRANSFORMERS TRANSFORMERCONTENTS: Shipment en masse oftransformers (TR-2), at a cost of approximately$1,540,000, is preferred over bulking oftransformer oil and off-site incineration (TR-1),which cosu approximately 51340,000, becausethere are fewer short-term risk, it requires feutime 10 implement, and the cost of shipment eamav* is lower than bulking the transformer ofl.

TANK CONTENTS: Bulking and off-sitedisposal (TK-1) is the onJy alternative thatpAsied the first two criteria, which are thresholdcriteria thai must be satisfied. The cost isapproximately Si,440,000.

BACHOUSE DUST: Off-site treatment anddisposal of bagiouse dust (BH-1) is the onlyalternative that passed the threshold criteria.The cost is approximately $403,000.

CHEMICAL PILES: Off-site treatment anddisposal of chemical piles (CP-1) is the onlyalternative that passed the threshold criteria.The cost is approximately 521,000.

TIRE PILES: Off-site disposal of the tires (TP-1) is the only alternative that passed thethreshold criteria. The cost is approximately$12,000.

WATER TOWER SOTL; Excavation and off-sitetreatment and disposal of contaminated soils(PS-3) is the only alternative that passed thethreshold criteria. The cost is approximately$64,800.

COST SUMMARY FOR THE PREFERREDALTERNATIVES

ON-SITE AREAS

DRUMS PR-2) (S)l,476£00TRANSFORMERS (TR-2) 1,540.000TANKS (TK-1) 1,4*0,000BAGHOUSE DUST (BH-1) 405,000CHEMICAL PILES (CP-1) 21,000TIRE PILES (TP-1) 12,000

OFF-SITE AREA

WATER TOWER SOILCWT-S) 64 .gooTOTAL 4,99*400

C1778

12

COMMUNITY INVOLVEMENT

EPA solicits input from the communify on thedeanup methods proposed n each Superfundsite. EPA has jet a public comment periodfrorn^ January 8, 1990, through February 6,1990.to encourage public participation in theselection process. Tbe comment period iadudesa public meeting at which EPA, with theNJDEP, will present the FFS report andProposed Plan, answer questions and acceptboth oral and written comments.

A public meeting is scheduled for 7.00 p.m.,Thursday January IS, 1990 and will be held atthe Roebiing Volunteer Fire Company 03,located on 7ih and Main Streei, Roebiing, NewJersey.

Comm en is on the Proposed Plan or the FFSrepori wil! be welcomed through February 6,199C, and will be summanzed and responded toin the Responsive Summary section of theRecord of Decision (ROD) for the RoeblingSteel sue. The ROD is the document thaipresents EPA's final selection for cleanup. '

Written comments an be tent to:

Taman RassiRemedial Projea ManagerU.S. Environmental Prelection A|tncyRoom 71126 Federal FlaaNew York, NY 10278

The administrative record, which contains theInformation upon which the (election of theresponse action will be based, is available at:

Florence Ibwnship Public Library1350 Hornberger AvenueRoebiing, New Jersey 04554(609) 499-0143

Florence Township Municipal Building711 Broad StreetFlorence, New Jersey 08518(609) 499-2525

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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCYINVITES

PUBLIC COMMENT ON THEPROPOSED CLEANUP ALTERNATIVES

FOR THEROEBLINQ STEEL COMPANY SITE

INTERIM ACTIONROEBLINQ, NEW JERSEY

The US Environmental Protection Agency (EPA) recently completed a Focueed Feasibility Stu-dy (FFS) that evaJuaied options for addressing several imminently hazardous araas at tha Roe-biing Steel Company Site. As a pan of its public participation responsibilities under section117(a) of the Comprehensrve Environmental Response. Compensation, and Liability Act (CER-CLA), EPA ana the New Jersey Department of Environmental Protection (NJDEP} are issuing aProposed Plan available for public comment summarizing the alternatives tor remediation thatEPA considered during its Focused Feasibility Study.EPA. the lead agency, and NJDEP, tha support agency, will be accepting public comments ontha Proposed Plan from January 6.1990 to February 6.1990. In addition, EPA will hold an in-formational public meeting at 7:00 p.m. on January IB. 1990 at the Roebling Volunteer FireCompany *3, located on 7th and Main Street. Roebling. New Jeraey. to present both the find-ings of the Focused Feasibility Study and the preferred remedial alternatives.EPA and NJDEP evaluated the following optons for the Interim Action at tha aita. The InterimAction will continue the site stabilization effort initiated under tha previous removal action. ;

DRUMS DR-1 Drums Bullung and Off-site DisposalDR-2 Overpacking of Drums and Off-site Disposal

TRANSFORMERS TR-1 Bulking and Incineration of PCB-ContaminatedLiquids/Dismantling and Disposal of Transformer

TR-2 Shipment of Transformers En MasseTANKS TK-1 Bulking of Tank Contents and Off-site DisposalBAGHOUSE DUST BH-1 Off-siteTreatment and DisposalCHEMICAL PILES CP-1 Off-site Treatment and DisposalTIRES TP-1 Off-site DisposalWATER TOWER WT-3 Excavation of Soil under the Water Tower in theSOIL Roebling Parfc/Off-sKe Treatment and DisposalEPA s preferred remedial alternatives are DR-2. TR-2, TK.1, BH-1, CP-1. TW and WT-3. De-tailed informahon on these eitematrves is available for review in the Proposed Plan. FocusedFeasibility Study, and other arte related documents located at the following information repoaito-nes:Florence Townihlp Municipal BuDdlng Florence Townehip Public Library •

711 Broad Street 1350 Horn berg er AvenueFlorence, New Jertey 06518 Rc*bllng, New Jerwy 08554

Wr/rten comment* (postmarked' on or before February 6. 1990) on Ihe proposedaffemaffve* ehouti be aenf to: •

Tamara RossiRemedial Project Manager

U.S. Environmental Protection AgencyRoom 711 .:

26 Federal Plaza *;New York, New York 10278

ROEBLING STEEL COMPANY SITE NAME AND LOCATION

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