Second Five-Year Review Report

Brook Industrial Park Superfund Site Somerset County

Bound Brook, New Jersey

Prepared By: United States Environmental Protection Agency

Region II New York, Ne~ York

September 2009

Table of Contents

I. Introduction .............................................. 5 I I. Si te Chronology ........................................... 6 III. Background ................................................ 6

Site Location and Description ........................ 6 Si te-Specific Geology ................................ 6 Hydrogeology ......... \ ............................... 6 Land and Resource Use ................................ 7 History of Contamination ............................. 7 Ini tial Response ..................................... 8 Basis for Taking Action .............................. 8 Contaminants . ' .... ' .................................... 8

IV. Remedial Actions .......................................... 9 Remedy Selection ..•.................................. 9 Remedy Implementation ............................... 11 Operation, Maintenance, and Monitoring .............. 13

V. Progress Since the Last Review ........................... 13 VI. Five-Year Review Process ...... ~ .......................... 14

Administrative Components ........................... 14 Community Notification and Involvement .............. 14 Document Review ..................................... 14

,Data Review ......................... ' .... " ........... 15 Si te Inspection ..................................... 15 Interviews .......................................... 15

VII. Technical Assessment ..................................... 15 VIII.lssues, Recommendations and Follow-up Actions ............ 20 IX. PrQtectiveness Statement ............................ ! •••• 20 X. Next Review .................................... ' .......... 21

Appendices

-Attachment A: Attachment B: Attachment C:

Attachment D: Attachment E:

Figure 1

List of Acronyms Chronology of Site Events Comparison of Groundwater Standards for Chemicals of Concern Comparison of Soil Cleanup Criteria List of Documents Reviewed.

Site Map

Five-Year Review Summary Form

SITE I DE\TI FIC\T10\

Site name (from CERCLIS): Brook Industrial Park

EPA ID (from CERCLIS): NJD078251675

NPL status: • Final 0 Deleted 0 Other (specifY)

Remediation status (choose all that apply): 0 Under Construction. Constructed • Operating

Multiple ODs?* 0 YES • NO Construction completion date: 09/29106

Has site been put into reuse? 0 YES 0 NO • N/A

IU:"IL\\ S I \ It S

Lead agency: • EPA 0 State 0 Tribe 0 Other Federal Agency

Author name: Peter Mannino

Author title: Remedial Project Manager I Author affiliation: EPA

Review period: ** 09/1512004 to 09/15/2009

Date(s) ofsite inspection: 06/22/09

Type of review: • Post-SARA o Pre-SARA o NPIrRemoval only o Non-NPL Remedial Action Site o NPL StatelTribe-Iead o Policy o Regional Discretion

Review number: o 1 (first) • 2 (second) o 3 (third) 0 Other (specifY)

Triggering action: o Actual RA Onsite Construction at OU # __ o Actual RA Start at OU# o Construction Completion • Previous Five-Year Review Report o Other (specifY)

Triggering action date (from CERCLIS): (Previous Five-Year Review) 09/14/04

Does the report include recommendation(s) and foUow-up action(s)? • yes 0 no

Is the remedy protective of the environment? • yes o no

* ["OU" refers to operable unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in CERCUS]

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Five-Year Review Summary Form (continued)

Issues

An Explanation of Significant Differences (ESD) is required to document deviations from the Record of Decision (ROD).

During the June 2008 site inspection, some of the groundwater monitoring well casings were missing locks. In addition, construction activities related to the Green Brook Flood Control (GBFC) project, currently underway at the direction of the United States Army Corps of Engineers (USACE), have disturbed wetlands at the site, including areas restored as part of the site remedy.

Recommendations and Follow-up Actions

Issue an ESD to document the following deviations from the ROD; o The selected remedy did not clearly identify that institutional controls

would be required to assure the long-term protectiveness of the implemented remedy. Pursuant to a Consent Decree, the landowner PRP has filed a Declaration of Restrictive Covenants on the site to maintain the protectiveness of the remedy.

o Pursuant to the ROD, the groundwater component of the remedy required reinjection of the treated groundwater into the aquifer or discharge to the Raritan River. The PRP is discharging the treated extracted groundwater to the nearby publicly-owned treatment works (POTW).

o Pursuant to the ROD, contaminated soil in the footprint of the former Blue Spruce building was to be removed. Post-excavation sampling revealed exceedanc~s of the soil clean-up criteria adjacent to the foundations; however, any further soil excavation ~~uld have compromised the structural integrity of the adjacent structures. As a result, the area was backfilled with clean fill and capped with an asphalt cap.

o. Pursuant to the ROD, contaminated soil in the Stirling Center basement was to be removed. Post-excavation sampling revealed exceedances of the soil clean-up criteria; however, any additional soil excavation would have compromised the structural integrity of the building. Asa result, a concrete. cap was installed in the crawl space of the Stirling Center basement.

o Pursuant to the ROD, soil and sediments found in the two pits in the National Metals building were to be removed. Post-excavation sampling revealed exceedances of the soil clean-up criteria; however, any additional soil excavation would have compromised the structural integrity of the building. As a result, concrete pads were installed at the base of the pits and the walls were lined with steel plates.

Conduct a follow~up inspection at the site to ensure that the missing locks on the groundwater monitoring wells are replaced.

Coordinate with USACE to ensur~ that wetlands disturbed a~ the site as a result of the GBFC project are restored.

Conduct vapor intrusion sampling for buildings that lie over the groundwater plume.

The remedy at the Brook Industrial Park site is protective in the short-term; however, in order for the remedy to be protective in the long-term, vapor intrusion sampling needs to be conducted. . .

The building demolition component of the remedy is protective of human health and the environment. The demolition of the Blue Spruce building limits the possibility of exposure to the contaminated structure. The installation of

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Five-Year Review Summary Form (continued)

cement stucco on the remaining two common walls and the implementation of deed restrictions, controls exposure pathways that could result in unacceptable risks. Periodic inspections reveal no evidence of vandalism or damage to the concrete stucco. Repairs to the concrete stucco are performed by the property ~wner pursuant to an O&M Plan.

The soil component of the remedy is protective of human health and the environment through the removal of contaminated soils from the site, thereby limiting the possibility of exposure to these soils. The installation of asphalt and concrete caps over contaminated soils that could not be excavated, and implementation of deed restrictions c~ntrol exposure pathways that could result in unacceptable risks. Periodic inspections reveal no evidence of vandalism or damage to the asphalt and concrete caps. Repairs to the asphalt and concrete cap are performed by the property owner pursuant to an O&M Plan.

The groundwater component of the remedy is protective of human health and the environment in the short-term since the plume is undergoing remediation via an extraction/treatment facility, is stable, and con'taminated groundwater is not impacting surrounding properties. Institutional controls restrict the use of groundwater at the industrial park.

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I. Introduction

The purpose of the five-year review is to determine whether the remedies at a site are protective of human health and the environment. . The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five­Year Review reports identify issues found during the review, if any, and identify recommendations to address them.

This review was conducted pursua'nt to Section 121 (c) of (the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) , as amended, .42 U.S.C. Section 9601, et seq., and 40 C.F.R. 300.430(f) (4) (ii) and in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001) ,

The U. S. Environmental Prote'etion Agency (EPA), Region 2, conducted this five-year review of the remedy implemented at the Brook Industrial Park Superfund site in Somerset county, New Jersey. This five-year review was conducted by Peter Mannino, Remedial Project Manager (RPM). This report documents the results of the review.

This is the second five-year review for the Brook Industrial Park site. The triggering action for this statutory review was the first five-year review, dated September 14, 2004. A five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use and unrestricted exposure.

The first five-year review included a site visit by the EPA RPM in addition to a review of documents, data and available information. The purpose of the first five-year review was to examine whether the building demolition component of the remedy was protective of human health and the environment. The soil and groundwater components of the remedy were not completed at that time. The first five-year review determined that the implemented remedy provided adequate protection of public health and the environment.

A ROD was issued on September 29, 1994 that addressed building, soil, sediment, and groundwater contamination at the site. To date, all remedial actions have been completed.. The operation and maintenance activities f.or the pump and treat groundwater system, stucco walls, and asphalt caps are being performed by the property owner, a PRP for the site.

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II . SITE CHRONOLOGY

The chronology of events for the Brook Industrial Park site are summarized in Attachment B.

III. Background

Site Location and Description:

The Brook Industrial Park site (site) is located at 100 West Main Street in the Borough of Bound Brook, Somerset County, New Jersey. The site consists of a 4.5 acre complex of warehouses and light industries situated on the northern bank of the Raritan River. The site is bordered by the New Jersey Transit Railroad Line to the north; the Lehigh/Port Reading Railroad Lines to the south; ,a light industrial warehouse area to the west; and an undeveloped lot to the east. Figure 1 shows the location and layout of the site.

Site-Specific Geology:

The topography at the site slopes gently to the south and southeast. At the fence line, located along the southern portion of the site, the topography drops significantly to a small unnamed tributary to the Raritan River and a drainage ditch that runs between the site and the railroad right-of-way. The unnamed

'tributary and the drainage ditch are intermittently flowing. The site lies within the floodplain of the Raritan River, which flows east along the southern boundary of the site. Areas surrounding the drainage ditch and the unnamed tributary are classified as wetlands. The geology consists of a layer of fill ranging in thickness from approximately 1 foot to as much as 17 feet, overlying unconsolidated overburden sediments. Bedrock is encountered approximately 20 feet below ground surface. The top portion of the bedrock is highly weathered and fractured.

Hydrogeology:

Groundwater beneath the site is present in the unconsolidated overburden aquifer and a deeper fractured bedrock aquifer that is part of the Brun.swick group. The water table within the unconsolidated overburden aquifer is an average, depth of 10 feet below grade and appears to be sloping towards the Raritan River.

The source of" groundwater recharge is precipitation. The precipitation infiltrates the grouI?-d, moving through subsurface material, and is stored in the aquifers. "Generally, the overburden aquifer recharges the bedrock aquifer. Groundwater elevation data show that the two units are in hydraulic communication. Although these two units are hydraulically connected, they constitute two separate groundwater flow systems

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due to their differences in hydraulic properties.

Groundwater flow in the overburden is under unconfined conditions and has both lateral and downward components. The lateral flow discharges to the small tributaries in the area, while the downward flow recharges the underlying bedrock. Major flow in bedrock is along bedding plane partings, with vertical joints providing leakage between bedding planes. The result is that the groundwater flow system behaves as a multi-unit aquifer system with a relatively strong horizontal flow. Therefore, although the overburden and bedrock are hydraulically connected, they constitute two separate groundwater flow systems due to differences in hydraulic properties.

Pumping of the Jame Fine Chemical (JFC) production well controls the direction of groundwater flow in the bedrock aquifer at the site. The well is located within the JFC building on the site. It is 187 feet deep and is constructed as an open-bedrock well. This JFC well is pumped at a reported rate of approximately 125 gallons per minute (gpm) and the extract·ed groundwater is used as noncontact cooling water by JFC. The pumping of the JFC well creates an extensive cone of depression in the bedrock potentiometric surface that maintains hydraulic control, and to a lesser extent in the overburden.

Land and Resource Use:

The Brook Industrial Park site is located between the New Jersey Transit Railroad Line to the north and the Lehigh Valley/Port Reading Railroad Lines to the south. The railroad tracks merge together east of.the site. The area east and north of this merge is an urban/commercial section of the Borough. Property to the southwest is undeveloped woodland.

History of Contamination:

Industrial, chemical and pesticide production, usage and storage 6perations began at the site in 1971 when Blue Spruce International occupied a number of the buildings. Substances handled at the Blue Spruce facility included various pesticides, dioxin and arsenic compounds. Blue Spruce International ceased operations in.1982 ..

The National Metal Finishings Corporation has operated at Brook Industrial Park since the early 1970s. The metal plating process performed by National Metal Finishings at one time included electroplating chromium onto large steel rollers, followed by a final rinse over an open pit to remove the residual chromium. The chrome-plating units are located in two subsurface pits. Prior to the remediation, it was believed these pits were in

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direct contact with the groundwater. A closed-loop process was subsequently installed which eliminated any further discharge to the pits.

JFC has operated a bulk pharmaceutical manufacturing operation, to pioduce specialty chemicals, at the Brook Industrial Park since the 19705. Site investigations hav~ revealed that JFC handled several of the contaminants present'in the groundwater. JFC and National Metal Finishings Corporation are currently operating at Brook Industrial Park.

Initial Response:

From 1980 through 1988, EPA and New Jersey Department of Environmental Protection (NJDEP) conducted initial studies to ascertain the potential threat to public health and the environment from the site. Inspections discovered leaking drums, and illegsl discharges to surface soil, groundwater, and the Raritan River. Sampling of the groundwater, surface soils, and the Blue Spruce building demonstrated the presence of volatile organic compounds (VOCs), pesticides, metals, and dioxin.

In August 1983, EPA used emergency funds to secure the Blue Spruce building and to cover a dioxin-contaminated area with asphalt. In 1990, fencing was installed on a portion of the site to minimize the potential for incidental contact with contaminants.

Basis for Takinq Action:

On October, 4, 1989, EPA included the Site on the National Priorities List (NPL) '. In April 1989, EPA' began a Remedial Investigation and Feasibility Study (RI/FS) to determine the nature and extent of contamination at the Site. Tlile RI indicated elevated levels of contaminants in the ,Blue Spruce building, surface and subsurface soils, sediments, and groundwater.

Contaminants:

The RI identified the following hazardous substances in the groundwater:

benzene chlorobenzene 1,2-DCA trans-1,2-DCE PCE TCE vinyl chloride

Aluminum Antimony Arsenic Beryllium Cadmium Chromium Lead

" Nickel

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Alpha-BHC 4,4'-DDD Dieldrin Endrin Endosulfan Heptachlor xylenes

In the soils:

Arsenic Beryllium Chromium Lead

Aldrin 4,4-DDT Dieldrin 2,3,7j8-TCDD

At the Blue Spruce building:

aldrin dieldrin

2,4-D 2,4,5-T

2,3,7,8-TCDD

To assess site-related human health risks, several exposure pathways were selected for detailed evaluation under both current and future land-use conditions. Under current land-use conditions, the general exposure pathways evaluated were incidental ingestion or dermal absorption of soil, inhalation of fugitive dust and dermal absorption of surface water. Under future land-use conditions, the general exposure pathways evaluated were incidental ingestion and dermal absorption of soils and ingestion of groundwater.

IV. RemedialActions

Remedy Selection:

Based on the results of the RI/FS( EPA issued a ROD on September 29, 1994, selecting a final remedy for the site that addressed the threats to human health and the environment associated with groundwater contamination in the overburden and bedrock aquifers, contaminated material from the Blue Spruce building, and contaminated soils and sediments at the site. The major features of the selected remedy included the following:

Building Interior • Demolition and off-site disposal of the dioxin-contaminated

material from the Blue Spruce building; sealing of the common walls if demolition compromised the structural integrity of the adjacent facilities; and maintenance of the sealed walls over the lifetime of the/adjacent buildings.

Soils • Excavation of contaminated soil in the eastern and

southwestern portions of the site, which are designated as Area One and Area Two, respectively, the soil in the basement of the Blue Spruce and Stirling Center buildings, sediment in the ~wo subsurface pits in the National Metal Finishings building, and sediment in the wetlands; off-site

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treatment and disposal of the contaminated soil; backfilling of the excavated areas with clean fill; and mitigation of the wetland area as appropriate.

The ROD limited the excavation of contaminated soils to the water table (approximately ten feet below ground .surface) .

Groundwater • Installation of groundwater extraction wells; treatment of

the oontaminatedgroundwater' by chemical precipitation and air stripping; reinjection of the treated groundwater into the aquifer; and long-term monitoring.

The ROD identified the following remedial action objectives (RAOs) for the site:

• Reduce risks associated with incidental ingestion of and direct contact with contaminated soils in Area One, Area Two, basements and sediments (wetland area) .

• Reduce risks associated with direct contact with contaminated building interiors.

• Reduce potential risks associated with ingestion of the overburden and bedrock ground water.

To achieve the RAO for soils, EPA developed site-specific, risk­based remediation goals based on EPA's policy of calculating the concentr~tion of a chemical which equals a carciriogenic r~sk of one in one million (1x10~6), for the following contaminants of concern: chromium (50 ppm); beryllium (1.3 ppm); DDT (17 ppm); aldrin (0.33 ppm) and dieldrin (0.35 ppm). The remediation goal for chromium below five feet was based on a risk of one in one­hundred thousand (500 ppm). These remediation goals were based on the assumption that the site would continue to be used for industrial 'purposes only. If a residential land-use assumption were used, more stringent remediation goals would likely result. The remediation goal for arsenic (20 ppm) was based on the New Jersey State background concentration. The remediation goals for lead (500 ppm) and PCBs (1 ppm) were based on EPA policy. Because significant contaminant concentrations are present near the groundwater table in some areas of the site, the ROD called for soil in these areas to be remediated to the water table (approximately ten feet below ground surface).

To achieve the RAO for the Blue Spruce Building interiors,. the goal was to remediate areas of the building where dioxin contamination was above 1 ppb. To achieve the RAO for groundwater, the goal for the remediation of the groundwater was

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to restore the aquifer to promulgated federal and New'Jersey MCLs and NJGWQS.

Remedy Imp1ementation:

In 1997, using federal funds, EPA initiated th~ remedial design activities for the soil, Blue Spruce building, and groundwater components of the remedy.

In September 1999, EPA completed the demolition of the Blue Spruce building, off-site disposal of the demolition debris, and sealing of the adjacent building walls. Approximately 400 tons of brick/concrete and 500 cubic yards of wood were transported off site for disposal. Furthermore, the two common walls that support the roofs of the adjacent facilities were sealed with a cement stucco.

In September 1999, EPA also began the remedial action for the soil component of the remedy. Eighteen thousand tons of contaminated soil were excavated and' transported off site for treatment and disposal, resulting in the completion of the Area Two remedial action and most of Area One. Following the removal and off-site treatment and disposal of contaminated soil from the Stirling Center basement, a concrete cap was installed to prevent direct contact to residual contamination.

The remaining soil excavation was delayed when soil sampling at nearby properties conducted by EPA in July 2001 revealed elevated levels of chromium and arsenic in soils up-gradient of the site.

As a result, excavation of soil in the wetlands was halted until a further evaluation of this area could be performed to determine if, other sources of contamination exist.

In addition, the remaining soil component of the remedy required coordination with the Green Brook Flood Control (GBFC) project, which is being performed by the USACE. As part of the GBFC project, a flobdwall and levee system is to be constructed on the Brook Industrial Park. The remaining work in the wetlands area required the relocation of utilities that are interconnected with the GBFC project and EPA coordinated with the USACE on these activities. After completing the delineation of site-related contamination and the design for the relocation of the utilities, in May 2006, EPA mobilized at the site to complete the remaining soil and sediment excavation activities. As part of this effort, an additional 11,300 tons of soil and sediment were removed 'from the site. The soil remedial action was completed in September 2006.

After successful negotiations with PRPs for the site, the groundwater Remedial Design/Remedial Action (RD/RA) activities

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were taken over by a group of PRPs in 2001. In September 2004, the PRP group completed the 100% remedial design for the groundwater component of the remedy. The groundwater extraction system consists of six overburden extraction wells. One bedrock groundwaier extraction well, the JFC production well, provides non-contact cooling water for the facility and provides site-wide hydraulic control. Although this well is part of the extraction well network, it is not connected to the treatment system. The treatment process for the extraction water from'the overburden aquifer consists of ion exchange and granular activated carbon. The PRP commenced construction activities for the groundwater remedy in February 2006 and completed the construction of the groundwater extraction/treatment facility in September 2Q06.

With the completion of the Remedial Action, EPA has identified the foilowing deviation,s from the remedy as documented in the ROD:

o The selected remedy did not clearly identify that institutional controls would be required to assure the long-term protectiveness of the implemented remedy. Pursuant to a Consent Decree, the landowner PRP has filed a Declaration of Restrictive Covenants on the site to maintain the protectiveness of the remedy.

o Pursuant to the ROD, the groundwater component of the remedy required reinjection of the treated groundwater into the aquifer or discharge to the Raritan River. The PRP is discharging the treated extracted groundwater to the nearby publicly-owned treatment works (POTW). '

o Pursuant to the ROD, contaminated soil in the footprint of the former Blue Spruce building was to be removed. Post-excavation sampling revealed exceedances of the soil clean-up criteria adjacent to the foundations; however, any further soil excavation would have compromised the structural integrity of the adjacent structures. As a result, the area was backfilled with clean fill and capped with an asphalt cap.

o Pursuant to the ROD, contaminated soil in the Stirling Center basement was to be removed. Post-excavation sampling revealed exceedances of the soil clean-up criteria; however, any additional soil excavation would have compromised the structural integrity of the building. As a result, a concrete cap was installed in the crawl space of the Stirling Center basement.

o Pursuant to the ROD, soil and sediments found in the two pits in the National Metals building were to be removed. Post-excavation sampling revealed exceedances of the soil clean-up criteria; however, any additional soil excavation would have compromised the structural

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integrity of the building. As a result, concrete pads were installed at the base of the pits and the walls were lined with steel plates.

EPA has concluded that an Explanation of Significant Differences (ESD) is required for the site to document deviations from the ROD identified above.

Operation, Mainten~noe, and MOn~torinq:

The Operation and Maintenance (O&M) Plan includes maintenance of the two common walls of the former Blue Spruce building, the asphalt caps in Area One and Area Two, the asphalt cap within the footprint of the former Blue Spruce buildlng, and the concrete cap in the Stirling Center basement.

The O&M Plan for the groundwater remediation system is currently under review by EPA.

Pursuant to the Consent Decree, in December 2008, the property owner executed a Declaration of Restrictive Covenants for the site. The Declaration of Restrictive Covenants applies restrictions on use of the contaminated common walls of the former Bl,ue Spruce building, soils, and groundwater at the site. This action provides the appropriate institutional controls for

site use and for the protection of the implemented remedies.

v. Proqress sinoe the last review

The first five-year review for the site, which was completed in September 2004, noted that several portions of the soil remedial action were not completed by EPA and that the PRP had not begun construction activities for the groundwater component-of the remedy. As a result, the protectiveness determination made in the first five-year review was "will be prot~ctive" and there were no issues/recommendations identified. Since the completion of the first five-year review, construction is complete at the site and the ROD has been fully implemented. A remedial action report for the soil activities was approved by EPA on September 17, 2007 and a remedial action report for the groundwater activities was approved by EPA on September 18, 2007.

In additi9n, pursuant to the Consent Decree; the property owner has executed a Declaration of Restrictive Covenants for the site. The Declaration of Restrictive Covenants applies restrictions on use of the contaminated common walls of the former Blue Spruce building, soils, and groundwater at the site. This provides the appropriate institutional controls for site use and protect the implemented remedies.

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Currently, the project is in the long-term monitoring (LTM) phase designed to monitor the nature and extent of groundwater contamination and assess the migration and potential attenuation of the plume.

VI. Five-Year Review Process

Administrative Components:

The five-year review team consisted of Peter Mannino (EPA~RPM), Richard Krauser (EPA-Hydrogeologist), Charles Nace (EPA-Risk Assessor), Robert Collier (NJDEP) and Vijay Sundaram (NJDEP).

Community Notification and Involvement:

EPA notified the community of the initiation of the five-year review process by publishing a notice in the Courier-News, the area newspaper on September 2, 2009. The notice in~icated that EPA would be conducting a five-year review of the remedy at the Brook Industrial Park to ensure the remedy remains protective of public health and is functioning as designed. The notice included the RPM's address and telephone number for questions related to the five-year review process. In addition, the notice indicated that once the five-year review is completed, the results.would be made available to the public at the following locations.

Bound Brook Public Library 402 East High Street Bound Brook, New Jersey 07080 (732) 356-0043

u.S. EPA Records Center, Region II 290 Broadway, 18 th Floor. New York, New York 10007-1866 (212) 637-3261

Document Review:

The documents, data, and information which were reviewed in completing this five-year review are identified in Attachment E.

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Data Review:

Since the completion of the Blue Spruce building component of the remedy, no additional sampling was performed of the tW9 common walls. The purpose of the concrete stucco was to prevent contact to the remaining contaminated common walls. Because of the chemical properties of the contaminants, natural attenuation or degradation of the contaminants is not expected.

. "

As for the soil component of the remedy, post-excavation soil sampling was collected in Area One, Area Two, within the footprint of the former Blue Spruce building, and the wetlands area. Pursuant to the ROD, soil excavation did not go beyond the water table, approximately ten feet below ground surface. Post­excavation soil sampling results are contained in the remedial action report, dated May 2007.

As part of the LTM for the groundwater component of the remedy, the PRP has implemented a comprehensive groundwater monitoring program. The results of the most recent sampling event are provided in Attachment c.

Site Inspection:

The site inspection was conducted on June 22, 2009 by EPA and representatives of the property owner. The NJDEP project team was not available to participate in the site inspection. The purpose of the site inspection was to assess the protectiveness of the remedy. The site was found to be in good cODdition and no significant issues were identified, howeve~ the following activities"are suggested: Locks were missing on some of the monitoring well casings and need to be replaced.

Interviews:

The site remedy was discussed with representatives of the property owner. There were no interviews with local officials or community representatives.

VII. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

Yes, the remedy is functioning as intended by the decision document.

As a result of the removal of contaminated soils/sediments from the site and the remaining soils/sediments exceeding the cleanup criteria are capped, the direct contact pathway is incomplete.

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The cement stucco on the two common walls of the former Blue Spruce building, the concrete cap in the basement of the Stirling Center basement,the asphalt cap within the footprint of the former Blue Spruce building, and the steel plates lining the two pits in the National Metals building appear to be in good condition.

The stone installe~ to stabilize the steep bank along the southern portion of the site, adjacent to the storm drain and the railroad line appears to be stable and in good condition. However, some of the trees and vegetative cover along the drainage ditch in the wetland area was disturbed due to the construction of a flood-control levee. This is further described in the ecological risk assessment section of Question B, below.

'Although this area was disturbed it should not affect the protectiveness of the remedy.

Groundwater in the overburden aquifer is ad~ressed via an extraction and treatment facility. Althoughextracted groundwater from the bedrock aquifer is not managed by the treatment facility, the pumping of the JF~ production well maintains hydraulic control of the bedrock aquifer. The extracted groundwater is used by JFC as noncontact cooling water, and discharged to·a POTW facility under a pre-existing permit.

There are no drinking water wells within the plume 'of cont~mination and institutional controls restrict groundwater use at the industrial park.

As part of the groundwater component of the remedy; groundwater samples are collected semi-annually and analyzed for volatile organic compounds (VOCs) and metals. In general, analytical results have shown a decrease in contaminant concentrations; however, exceedencesof the cleanup criteria are preval~nt. For example, groundwater sampling performed during the remedial design in 1997 revealed a maximum concentration of 15,500 ppb for chromium. Groundwater sampling performed as part of the biannual monitoring program in April 2008 revealed that the maximum concentration for chromium decreased to 3,710 ppb. In 1997, the maximum concentrations detected for benzene, chlorobenzene, and tetrachloroethene were 59 ppb, 277 ppb, and' 71 ppb, respectively.

In April 2008, the maximum concentrations detected for benzene, chlorobenzene, and tetrachloroethene were 22 ppb, 55 ppb, and 52 ppb, respectively. .

There have b~en no changes to the physical conditions at the site that would affect the protectiveness of the remedy.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy still valid?

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Human Health - (a) The previous five-year review indicated that the exposure assumptions used to support the remedial decision at the site were still valid, although some of the default exposure assumptions may have changed since the signing of the ROD. The findings during this review period agree with the previous evaluation of the exposure assumptions and conclude that the exposure assumptions used at the time of the remedy are still valid. (b) The previous five-year review indicated that the toxici ty values that were used s·erved two functions. The first was to estimate the risks and hazards at the site and the second was to develop soil cleanup goals for five compounds (aldrin, dieldrin, DDT, beryllium, and chromium). As identified in the previous five-year review, the toxicity values for two chemicals have changed since the ROD was signed. The exact assumptions used to calculate the remediation goals could not be located, however, based on the relationship between the old toxicity values and the current toxicity values the following conclusions can be made: the remediation goal for beryllium would decrease by approximately 0.41% and the remediation goal for chromium would decrease by 0.6%. These small percentages would not affect the protectiveness of the remedy. (c) As indicated above, there were five remediation goals that were identified on page 12 of the ROD which were developed using toxicity values and four additional chemicals that used either background or agency policy to develop the remediation goal. If remediation goals were to be calculated using current toxicity values, two of the remediation goals would be slightly different, although the small change in the cleanup value would not change the protectiveness of the remedy. These differences were~documented in the text above. (d) The RAOs that are presented in the ROD are to reduce risks associated with incidental ingestion of and direct ~ontact with contaminated soils in Area One, Area Two, basements and sediments (wetland area), reduce risks associated with direct contact with contaminated building materials, and reduce potential risks· associated with ingestion of the overburden and bedrock groundwater. The RAOs listed in the ROD are still valid at this time.

The previous five-year review indicated that the potential for vapor intrusion should be evaluated for buildings that may lie over the groundwater plume. It is expected that the groundwater plume is contained within the site boundary. Given this, the only buildings that would have the potential for vapor intrusion would be the industrial facility located on the site. The most recent groundwater data were evaluated to determine if the vapor intrusion pathway is potentially complete at the site. The assessment of the vapor intrusion pathway consisted of following the flowchart presented in the 2002 USEPA and 2005 NJDEP Vapor Intrusion Guidance documents, as updated. NJDEP Vapor Intrusion

17

guidance documents can be found at http://www,nj.gov/dep/srp/guidance/vaporintrusion. Groundwater at the site is located less than 100 feet below the ground surface and there are buildings within 100 feet of the groundwater plume, so the groundwater data were screened against values presented in Table 2c1

• The most recent groundwater data from the April 2008 monitoring report was used. There were twelve VOCs detected in the latest groundwater sampling event and four of the compounds exceeded the groQndwater screening values (benzene, cis-1,2-dichloroethene,' trichloroethene, and vinyl chloride). Following the guidance mentioned above, if the detected groundwater concentrations do not exceed the screening value by more than 50 times, the likelihood of vapors intruding into buiLdings is low. Only trichloroethene exceeded the screening value by ~ore than 50 times. The highest detected concentrc;ition of trichloroethenewas 56 ug/l (EW-1), which is 1056 times the screening value. This suggests that vapor intrusion is potentially an issue for this site. Additionally, trichloroethene was detected at 12 ug/l in the JFC production well, which is 226 times the screening value. It is important to note that the JFC production well is located within one of the buildings. Given that the groundwater exceeds the screening value for trichloroethene, it is recommended to further evaluate the vapor intrusion pathway at the site by conducting subslab sampling in the buildings that lie over the plume.

Ecological - A four-step process was utilized for assessing site­related ecological risks for a reasonable maximum exposure scenario. The process included the following steps: Problem Fo~mulation - a qualitative evaluation of contaminant release, migration, and fat~; identification of contaminants of concern, receptors, exposure pathways, and known ecological effects of the contaminants; and selection of endpoints for further study; Exposure Assessment -.;.. a quantitative evaluation of contaminant release, migration, and fate; characterization of exposure pathways and receptors; and measurement or estimation of exposure point concentrations; Ecological Effects Assessment - literature reviews, field studies, and toxicity tests, linking contaminant concentrations to effects on ecological receptors; and Risk Characterization - measurement or estimation of both current and future adverse effects.

The ecological assessment found that the most important potential exposure pathway for ecological receptors at the site was associated with chemicals in the sediments and surface water of the unnamed tributary, the drainage ditch, and the Raritan River

1 Table 2c contains several screening values that are based upon the maximum contaminant level (MCL), however, for this assessment,the MCL screening value was replaced with a more.sensitive health-based value set at a cancer risk of 10-6 or a hazard index of 1.

18

(wetland area). Aquatic animals could be exposed to the chemicals through direct contact or through ingestion while feeding. Chemical concentrations in on-site surface soils were at levels that may potentially impact plants and earthworms. However, on­site habitat for plants and earthworms is limited because of paved areas and compacted gravelly soils. The potential exposures to birds and mammals were also estimated to be very limited. The site provides very limited habitat for birds and mammals that feed on soil organisms, such as worms, since the site consists primarily of buildings and paved areas. Given the limited habitat on the on-site property and the remediation and restoration that occurred in the drainage ditch area, the remedy is functioning as intended for the protection of ecological receptors. Exposure path~ays that were identified in the ecological risk assessment have been eliminated and the remedy is protective for ecological receptors and the environment.

It is important to note that during the site visit the restored wetland area appeared to be potentially impacted by the construction work associated with building a levee system for flood protection. The wetland area should be inspected for adverse impacts and restoration activities should be implemented after the construction activities have ended, if needed.

Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No.

Technical Assessment Summary

According to the reviewed data, and the site inspection, all three components of the remedy are functioning as intended by the decision document.

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VIII. Issues, Recommendations and Follow-up Actions

Issue

Locks on some of the groundwater monitoring well casings are missing. The potential for vapor intrusion may exist for buildings that lie over the groundwater plume. An ESD is required to document deviations from the ROD.

Construction activities related to GBFC project have disturbed wetlands at the site.

Recommendations & Party Oversight· Milestone Affects Follow-up Actions Responsible Agency Date Protectivene

Replace missing locks and conduct follow-up inspection.

Conduct vapor intrusion sampling.

Issue ESD to document

. institutional controls required for the remedy, discharge of treated extracted groundwater to POTW and the installation of asphalt and concrete caps. Coordinate with USACE to ensure that wetlands disturbed at the site as a result of the GBFC are restored.

PRP

EPA

EPA

EPA

EPA

NJDEP

NJDEP

NJDEP

ss'? (YIN)

Current Future 11/30/2009 N N

03/31/2010 Y Y

06/30/2010 N N

12/31/2011 . N N

IX. Protectiveness Statement

The remedy at the Brook Industrial Park site is protective in the short-term; however, in order for the remedy to be protective in the long-term, vapor intrusion sampling needs to be conducted. The building demolition component of the remedy is protective of human health and the environment. .

The demolition oJ the Blue Spruce building limits the possibility of exposure to the contaminated structure. The installation of cement stucco on the remaining two common walls and the implementation of deed restrictions, controls exposure pathways that could result in unacceptable risks. Peri6dic inspections reveal no evidence of vandalism 9rdamage to the concrete stucco.

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Repairs to the concrete stucco are performed by the property owner pursuant to an O&M Plan.

The soil component of the remedy is protective of human health and the environment through the removal of contaminated soils from the site, thereby limiting the possibility of exposure to these soils. The installation of asphalt and concrete caps over contaminated soils that could not be excavated, and implementation of deed restrictions control exposure pathways that could result in unacceptable risks. Periodic inspections reveal no evidence of vandalism or damage to the asphalt and concrete caps. Repairs to the asphalt and concrete cap are performed by the property owner pursuant to an O&M Plan.

The groundwater component of the remedy is protective of human health and the environment in the short-term since the plume is undergoing remediation via an extraction/treatment facility, is stable, and contaminated groundwater is not impacting surrounding properties. Institutional controls restrict the use of groundwater at the industrial park.

X. Next Review

five-year review for the Brook Industrial Park site completed before September 2014.

¥02( 2.00 7 Date · Mugdan, irector

Emergency and Remedial Response Division

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Attachment A: List of Acronyms

CERCLA

EPA

ESD

GBFC

GPM

JFC

LTM

MCL

NJDEP

NPL

O&M

OU

POLREP

PPB

PPM

POTW

PRP

RAO

RD/RA

RI/FS

ROD

RPM

SARA

ug/l

USACE

VOCs

Comprehensive Environmental Response, Compensation, and Liability Act

United States Environmental Protection Agency

Explanation of Significant Differences

Green Brook Flood Control

Gallons Per Minute

Jame Fine Chemical

Long Term Monitoring

Maximum Concentration Limit

New Jersey Department of Environmental Protection

National Priorities List

Operations and Maintenance

Operable Unit

Pollution Report

Parts Per Billion

Parts Per Million

Publically-Owned Treatment Works

Potentially Responsible Party

Remedial Action Objective

Remedial Design/Remedial Action

Remedial Investigation/Feasibility Study

Record of Decision

Remedial Project Manager

Superfund Amendments and Reauthorization Act

Microgram Per Liter

United States Army Corps of Engineers

Volatile Organic Compounds

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Attachment B: Chronology of Site Events.

Chronology of Events

Event Date

. Blue Spruce Corporation was fined by NJDEP for illegal 1977 storage of lindane.

Sampling performed by NJDEP reveals arsenic and lindane in soil behind the Blue Spruce building. 1980

NJDEP issues an Administrative Order and Notice of Civil 1980 Administrative Penalty against Jame Fine Chemicals, Inc. To cease discharge of wastewater to the Raritan River.

Employees at the Brook Industrial Park file a complaint 1980 with the MBRHC. Employees complained of nausea, dizziness, and headaches.

NJDEP inspection of two pits inside the National Metal 1981 Finishings Corp. building suggest that waste from grinding and polishing operations are discharged directly to the groundwater..

NJDEP conducts extensive soil and groundwater sampling at 1982 the Brook Industrial Park

NJDEP announces that 2,3,7,8-TCDD was found in soil 1983 samples collected at the Blue Spruce building

The Blue Spruce building is secured against trespassers 1983 and a dioxin-contaminated area is capped with asphalt.

Site was placed on the National Priorities List. 1989

The Remedial Investigation and Feasibility Stuq.y was 1989 initiated by ICF Technology; Inc.

Record of Decision for the site was issued. 1994

The remedial qesign for the soil, groundwater, and Blue 1997 Spruce remedies is initiated.

The design of the Blue Spruce building demolition is 1998 completed.

The design of the soil excavation is completed. 1999

The remedial action for the Blue Spruce building is 1998 initiated.

23

The demolition of the Blue Spruce building is completed. 1999

The remedial action for the soil component of the remedy 1999 is initiated.

The soil remedial action for the Stirling Center 2000 basement, Area 1 and Area 2 is completed.

Five Year Review Completed. 2004

The remedial action for the groun~water component of the 2006 remedy is initiated.

The soil remedial action for the National Metals pits and 2006 the wetlands area is initiated.

The soil remedial action for the National Metals pits and 2006 the wetlands area is completed.

The remedial action for the groundwater component of the 2006 remedy is completed.

24

Attachment C: Comparison of Groundwater Standards for Chemicals of Concern.

Contaminant Maximum Federal State ROD Concentratio MCL . Groundwater Action n Detected* (ppb) Standard Level

(ppb) (ppb) (ppb)

Benzene 22 5 1 1

Chlorobenzene 55 100 4 4

tetrachloroethe 52 5 1 1 ne

trichloroethene 26 5 1 1

Arsenic 138 50** 8 8

Chromium 3710 100 100 100

* Based on the m6st recent sampling event petformed ~n May 2008. ** The federal standard changed to 10 ppb in January 2006.

25

Attachment 0: Comparison of Soil Contaminants of Concern.

Contaminant Maximum ROD Remediation Concentration Goal

Detected* (ppm) (ppm)

Arsenic 500. 20

Beryullium 23.5 1.3

Chromium 3,540 50/500**

Lead 2,060 500

PCBs 10 1

Aldrin 7.4 0.33

DDT 26 17

Dieldrin 6.3 0.35

Dioxin*** 6.1 1

* Maximum concentration detected during the Remedial

** Investigation and/or the Remedial Design. The Remediation Goal for chromium' is 50 ppm for soils at surface to 5 feet below grade and 500 ppm for soils from feet below grade to the water table.

*** Dioxin concentrations are in parts per billion (ppb).

26

the 5

Attachment E: List of Documents Reviewed.

o Record of Decision for Brook Industrial Park Superfund site, dated September 30, 1994

o Consent Decree (multiple p~rties) for the Brook Industrial Park site, dated September 27, 2000

o Consent Decree (Arnold Livingston) for Brook Industrial Park site, dated January 11, 2001

o Remedial Action Report for ~lue Spruce Building Remedial Action, dated September 1999

o 100% 'Remedial Design Report for Groundwater at Brook Industrial Park site~ dated June 2004

o POLREP Reports for Soil Remedial Action at Brook Industrial Park site

o Soil Sampling Trip Report for Brook Industrial Park site, dated September 1999

o Remedial Action Work Plan for Soil at Brook Industrial Park site, dated September 1998

o O&M Plan for Brook Industrial Park site, dated May 2001 o Soil Remedial Action Report, dated May 2007 o Groundwater Remedial Action Report, dated October 2006 o Draft Groundwater O&M Plan, dated June 2009 o Test America Groundwater Analytical Report, dated May 2008

27

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