) . liiiiillFIVE-YEAR REVIEW REPORT FOR 113920

CURCIO SCRAP METAL INC. SUPERFUND SITE BERGEN COUNTY, NEW JERSEY

Prepared by

u.s. Environmental Protection Agency Region IT

New York, New York

March 2012

Table of Contents

I. Introduction 8

II. Site Chronology u.~: u 8'

III. Background.....•.....................................: ~ ~ 9 Land and Resource Use t..; 9

..H'lStOry 0 fC.. ontammatI , 9on .'. u ••••••••••••••••••••••••••••.

Geology/Hydrogeology u ~ ••••••••••••••••••••••••••••••• : •••••••••• ~ ••••• 10

Initial :Response ~ 10 Basis for Taking Action ~ ~ 10

IV. Remedial Actions , · · :u 11 Residential'Well Findings ~ , 14 Groundwater Monitoring Program 14 Institutional Control Implementation: 14

V. Progress Since the Last Review ·; 15

VI. Five-Year Review Process 15 . ·Administrative Components ~ 15

Community Involvement , 16 Document Review :. 16 Groundwater Data Review u u u.u u·16 Site Inspection u ; uu.u u uu., 18 Interviews u uu..u u 18

VII. Remedy·Assessment ' u u.u:uuuu u.uu.u uuu 18

Question a: Are the exposure assumptions, toxi~ity data, cleanup levels, and remedial action objectives used at the time ofthe remedy still valid? u.:uuu20 Question C: Has any other information come to .light that could call into question

Question A: Is the remedy functio~ing as intended by the decision document? 18 .

the protectiv~ness ofthe remedy? u.uu;u uu u.u: uuuuuu u u.uu 21

VIII. Recommendations and Follow-Up Act~ons u.uuu:uuuu u u.u u21

IX. Protectiveness Statement ~ u u u 22

x. Next. Review 22

Table 1 Chronology ofSite Events Table 2 Documents, Data and Information Used in ~ompleting Five-Year Review Table 3 Chemicals above detection limits in the 2007-2008 and 2010 rounds ofsampling Figure Curcio Site Plan

EXECUTIVE SUMMARY

This is the third five-year review for the Curcio Scrap Metal Inc. Superfund Site. The Site is located in Saddle Brook, New Jersey"and has two operable units (OUs). The Operable Unit 1 (OU1) Record of Decision (ROD) and Explanation of Significant Differences (ESD) called for the excavation of contaminated soils and transportation off-site for incineration or landfill· disposaL Operable Unit 2 addresses the groundwater. The OU2 ROD selecte~ a "No Further Action" remedy. As part of the "No Further Action" remedial approach, a long-term groundwater monitoring program was required.

This five-year review found tnat the OU1 and OU2 remedial approaches are functioning as . intended by the decision documents. The OU1 remedy is fully implemented and is protective. The OU2 groundwater remedy is fully implemented and is protective.

LIST OF ABBREVIATIONS

Acronyms used in this Document

ACO Administrative Consent Order. PCBs Polychlorinated Biphenyls

ARARs Applicable or Relevant· arid Appropriate Requirements

PRP Potentially Responsible Party

CEA Classification Exception Area RA Remedial Action

CERCLA Comprehensive Envirorunental Response, Compensation, and Liability Act

RCRA Resource Conservation and Recovery Act

.. . '.

CERCUS Comprehensive Environmental Response, Compensation, and Liability Act Information System

RD Remedial Design

CFR Code of Federal Regulations RI Remedial Investigation

CSMI Curcio Scrap Metal Inc. RI/FS Remediallnvestigation/Feasibility Study

CISC Cirello Iron and Steel Company ROD Record of Decision

EPA U.S. Environmental Protection Agency

RPM Remedial Project Manager

ESD Explanation of Significant Differences

SARA Superfund Amendments and Reauthorization Act

FS Feasibility Study SVOCS Semi-Volatile Organic Compounds

GMP Groundwater Monitoring PrograIl} TAL Target Analyte List

GWQS Ground Water Quality Standards TCL Target Compound List

MCLs Maximum Contaminant Levels U.S.C. United States Code

NJDEP N.J. Department of Environmental Protection

VOCs Volatile Organic Compounds

NPL National Priorities List WRA Well Restriction Area

O&M Operation and Maintenance

OU-l Operable Unit 1

OU-2 Operable Unit 2

OSWER Office of Solid Waste and Emergency Response

Five-Year Review Summary Form

; SITE IDENTIFICATION

Site Name: Curcio Scrap Metal Inc. Site

EPA 10: NJD011713584

City/County: Saddle Brook/Bergen County

NPL Status: Final

Multiple OUs? Has the site achieved construction completion? Yes Yes

I

REVIEW STATUS i ,

Lead agency: EPA

Author name (Federal or State Project Manager): Michelle Granger

Author affiliation: EPA

Review period: 07/21/07 - 02/01/2012

Date of site inspection: 11/08/11

Type of review: Policy

Review number: 3

Triggering action date: 07/20/07

Due date (five years after triggering action date): 07/20/2012

· .

Five-Year Review Summary Form (continued)

The table below is for the purpose of the summary form and associated data entry and does not replace the two tables required in Section VIII and IX by the FYR guidance. Instead, data entry in this section should match information in Section VII and IX of the FYR report.

I , Issues/Recommendations '

OU(s) without IssueslRecommendations Identified in the Five-Year Review:

OU2 ­ long-term groundwater monitoring

Issues and Recommendations Identified In the Five-Year Review:

OU(s): Issue Category: No Issue

Issue: NIA

Recommendation: NIA

Affect Current Protectiveness

N/A

Affect Future Protectiveness

N/A

Implementing Party

N/A

Oversight Party

N/A

Milestone Date

N/A

To add additional issues/recommendations here, copy and paste the above table as many times as necessary to document all issues/recommendations identified in the FYR report.

: Protectiveness Statement(s)

Include each individual OU protectiveness determination and statement. If you need to add more protectiveness determinations and statements for additional aus, copy and paste the table below as many times as necessary to complete for each au evaluated in the FYR report.

Operable Unit: OU2 - Groundwater

Protectiveness Determination: Protective

Addendum Due Date (if applicable): N/A

Protectiveness Statement: The OU2 remedy is expected to be protective upon completion of the monitoring requirement, and in the interim, exposure pathways are being controlled by the implementation of the NJ CEA.

Sitewide Protectiveness Statement (if applicable)

For sites that have achieved construction completion, enter a sitewide protectiveness determination and statement.

i

Protectiveness Determination: N/A

Addendum Due Date (if applicable): N/A

Protectiveness Statement: This five-year review found that the OUI and OU2 remedial approaches are functioning as intended by the decision documents. The OU2 remedy at the Curcio Scrap Metal Superfund Site is expected to be protective upon completion of the groundwater monitoring program, and in the interim, exposure pathways that could result in unacceptable risks are being controlled by the implementation of the NJ Classificiation Exception Area (CEA).

Curcio Scrap Metal Inc. Superfund Site . Sa~dle Br~ok, New Jersey

Third Five-Year Review Report

I. Introduction

This third five-year review for the Curcio Scrap Metal Inc. site· (Site), located in Saddle Brook, Bergen County, New Jersey; was conducted by U.s. Environmental ProtectionAgency (EPA) Remedial Project Manager (RPM), Michelle Granger. This five-year review ~as conducted in accordance with the. Comprehensive Five-Year Review Guidance, OSWER Directive 9355:7­03B-P (June 2001). The purpose of five-year reviews is to ensure that remedies protect public health and the environment and function as intended by the decision documents. This document will bec:ome part of the Site .file. .

The Site has two operable units (ODs). The cleanup of contaminated soil is Operable Unit One (OU-1) which addressed soil and sh~l1low groundwater contamination. The final remedy \Vas designated as OU-2 which addressed groundwater contamination. Long-term groundwater monitoring has been ongoing since March 2000.

The June 1991 ROD, as modified by the August 1992 ESD, selected excavation of soils contaminated with PCBs and heavy metals to residentialCleanup levels. Upon completion ofthe OU1 remedy, contaminants were not left onsite above Unlimited Use/UnlimitedExposure

. (UU/UE) levels. This OU is not being evaluated in this five-year review.·

The September 30, 1997 OU-2 ROD for groundwater selected a No Further Action remedy, which includes a long-term groundwater monitoring program and a Classification Exception Area (CEA). The ROD stated that the monitoring program and the CEA will remain in effect

.until "constituents in the groundwater do not exceed drinking water standards." Consequently, this Site is subject to "policy" five-year reviews.

II. Site Chronology

Table 1, below, summarizes site.;.related events from discovery to present activities:

..

Table.I: Chronology of Site Events

Event/Activity Date . Salvaging operations began at the Site 1950's

Main buildings constructed /

1970's

NJDEP conducts Site Investigation 1982

EPA conducted Preliminary Assessment I

-­1984

Site placed on NPL 1987

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ACO with PRPs to conduct RI/FS May 1988

OU-l ROD June 1991

EPA issued Administrative Order to PRPs to conduct RD/RA Sept 1991

OU-l Explanation of Significant Difference issued Aug 1992

OU-l Remedial Action completed Jan 1994

OU-2 ROD Sept 1997

OU-2 Administrative Order on Consent (AOC) to PRPs to perform long-term groundwater monitoring program

September 1999

OU-2 Annual Groundwater Monitoring Program Start March 2000

EPA First Five-Year Review September 2002

OU-2 First Amendment to September 1999 AOC to continue long­term groundwater monitoring program

April 2005

EPA Second Five-Year Review July 2007

OU-2 Second Amendment to September 1999 AOC to continue long-term groundwater monitoring program

April 2011

III. Background

The Curcio Scrap Metal, Inc. Site is located at 416 Lanza Avenue in Saddle Brook, New Jersey. The Site includes, but is not limited to, the real property where two active scrap metal recycling businesses operate; Curcio Scrap Metal, Inc., (CSMI) and Cirello Iron and Steel Company (CISC). The Site is approximately one acre in size and contains two single story buildings which are used primarily as warehouses. The Site is bordered by Lanza Avenue on the north, Walther Avenue on the south, a light industrial property on the east and Midland Avenue on the west. The area surrounding the Site is comprised of residential homes and industrial properties. .

Land and Resource Use

The Site is subdivided into the East, West and South Lots. The Site is used by CSMI and CISC to conduct their business. With the exception of two narrow passageways, the Site is paved. The Site has been in continued industrial use during remediation and post-remediation monitoring.

History ofContamination

Salvaging operations began at the Site in the early 1950's. Prior to this time, the land was used for dairy farming. In 1952, Mr. Curcio purchased the East and West Lots and in 1981, he purchased the South Lot. Initially, only rags and paper were recycled. Later, aluminum and copper were stored and recycled at the Site. Today, CSMI and CISC collect and compact scrap iron, aluminum, and other ferrous and non-ferrous metals. In 1977, the original structures on the Site were demolished, the present main building was erected and sections of the West Lot were

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paved. In 1978, the truck scale and scale control shed were constructed on the northern edge of the East Lot. In 1982, CSMIreceived shipments of 50 electrical transformers and, while cutting the transformers, oil containing polychlorinated biphenyls (PCBs) spilled onto the ground.

Geology/Hydrogeology

The Site is situated above a fractured bedrock aquifer calledthe Passaic Formation of the Brunswick Group. This aquifer supplies \yater to public and private wells in the area. Geophysical logging of boreholes was performed todefine the lithology and fractures and to help determine bedrock stratigraphy and structure. Three hydrogeologic zones were identified: the Overburden Water Bearing zone; transition zone; and the Upper Bedrock Aquifer zone.

Based on water level measurements, the direction of groUndwater flow was deterJ;nined to be northeasterly in' both the Overburden Water Bearing zone and the Upper Bedrock Aquifer zone. Shallow groundwater, located at a depth rangingbetweenapproxiIllately 5 feet to 15 feet below ground surface, is considered to be the·Overburden Water B~ariIig,zone. Changes.in the stratigraphy in the easternmost portion of the Site cause a general upgradient flow from the Upper BedrockAquifer zoneto the Overburden Water Bearing porti(;m of the aquifer. This may limit the vertical migration of contaminants to the deeper bedrockzone.Because of the upward hydraulic head in the Upper B<;:drock Aquifer zone in relation to the Overburden Water Bearing zone, there is limited potential for downward flow of water into the Upper Bedrock Aquifer zone within the eastern portion of the East Lot.

Initial Response

The NewJersey Department of Environmental Protection (NJDEP) conducted an initial investigation of the Site in October 1982. During thisinvestigation, severaldisassembled transformers were obserVed on the Site. Puddles of oil 'also were observed on theground beneath and adjacent to the transformers. Samples of the puddles were collected, analyzed and elevated concentrations of PCBs were detected. Further investigation revealed that transformers containing PCBs were purchased by SECO Corporation fromCon~olidated Edison Company of New York, Inc. (Con Ed) an.d subsequently sold to and transported to CSMlby SECO. At least three documented PCBspills have occurredon the Site.

Basis for Taking Action

At NJDEP's request, EPA conducted a Preliminary Assessment and Site Inspection in 1984 which revealed tlie presence ofhazardous substances such as PCBs, trichloroethylene, copper, lead and nickel, among other substances, in Site soils.

The Site was,placed on the National Priorities List (NPL) in July 1987. ,On May 27, 1988, EPA entered into an Administrative 'Order on Consent (ACO) with CSMI, SECO CorporatioJ.l and Con Ed (collectively referred to as 'Respondents'): The ACO required the performance of a ' Remedial Investigation and Feasibility Study (RIfFS) at the Site in order to determine the nature

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and extentof contamination along with the development of alternatives to address that contamination.

The RI was conducted from July 1989 through October. 1990 and addressed soil and shallow groundwater contamination. Based on the results of the investigation and the elevated risk posed by the contaminated soil, EPA determined that the cleanup of contaminated soil would be addressed on an expedited basis. Consequently, the Site was divided into two operable units (OUs). Operable Unit One (OU-1) addressed soil contamination and Operable Unit Two (OU-2) addresses groundwater contamination. The OUI RI concluded that soils were contaminated with PCBs and heavy metals including lead. The results of the risk assessment indicate that contaminated soil poses an unacceptable risk to workers and trespasser. The OU-2 RI for groundwater was performed from January 1996 to January 1997. The OU2 RI concluded that both the overburden and bedrock aquifer were contaminated with low levels ofVOCs including vinyl chloride, TCE, and methyl chloride and low levels of inorganics including lead, arsenic and thallium. The results of the risk assessment indicate that overburden groundwater poses an unacceptable risk for potential future on-site residents. In addition, activities taken to remediate surface water and sediment in Schroeder's Brook during the OUI remedial action were deemed to be protective. A baseline ecological risk assessment was conducted and concluded that there was no unacceptable ecological risk.

IV. Remedial Actions

QU-I: In June 1991, EPA issued a ROD for OU-l which called for excavation and off-site incineration of the contaminated soil. The cleanup level was established to be 1 part per million (ppm) for PCBs. In September 1991, EPA issued an Administrative Order (Index No. 11­CERCLA-I0113) requiring the Respondents to remediate the soil in accordance with the ROD.

Because of a nationwide shortfall in incineration capacity for PCB-contaminated materials that occurred after the issuance of the ROD, EPA issued ~ Explanation of Significant Differences (ESD), dated August 1992, that allowed disposal of soils containing less than 1,000 ppm of PCBs at a landfill permitted under both the Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act (TSCA).

OU-l established the following remedial objectives:

• Excavation of soil contaminated with polychlorinated biphenyls (PCBs) and heavy metals above applicable cleanup standards, and

• Transportation of the excavated soil to an appropriate incineration facility for treatment and/or disposal.

The Remedial Design (RD) was conducted by the respondents in conformance with the ROD as modified by the ESD. The RD was approved by EPA in March 1993. The OU-l Remedial Action (RA) was performed during the period from September 1993 through January 1994. The Respondents selected CH2M Hill to perform the remedial design and Westinghouse Remediation Services to conduct the remedial action activities. EPA's contractor, Camp Dresser & McKee

11

(CDM), provided full time oversight offield activities during implementation of the remedial action. Approximately 3,000 tons ofcontaminated soil were excavatedand removed from the Site. Approximately 500 tons ofcontaminated soil were transported off-site for disposal at the Aptus Incinerator iri Coffeyville, Kansas. Approximately 2,500 toris of contaminated soil were transported off-site for disposal at the Chemical Waste Management Landfill facility in Model City, New York. When confirmatory sampling indicated thatthe soil cleanup level was achieved, the area was backfilled with clean soil and a ten":inch thick reinforced concrete slab was installed over the East Lot. EPA conducted a final inspection on January 19, 1994 and determined that all remedial actions were successfully impl~mented by the·Respondents. A detailed description of the OU-l reme<,lial action activities is inCluded in the EPA approved March 1994 Remedial Action Reportfor Operable Uriit One: East Lot Soils, which is included in the Administrative Record.

In June 1995, as part of the OU-l soil remediation Site activities, the Respondents remediated a small body of standing surface water (Area ·1) and associated sediments (Area 2) of Schroeder's Brook, located approximately 300 feet to the east of the Site. A detailed description of the Area 1 and Area 2 remedial action activities is included in the EPA approved August 1995 Remedial . Action Report - Sediment Area, which is included in the Administrative Record.

OU-2: The Respondents began the groundwater investigation field work in January 1996 and concluded it in January 1997. The purpose of the groundwa~er investigation was to determine the extent of groundwater contamination; identify the stratigraphy of deeper portions of the . aquifer underlying the Site; and to determine the overall quality of the groundwater at the Site.

Seven monitoringwells were installed at the Site. In two of the three Upper Bedrock Aquifer zone monitoring wells, no volatile organic compounds (VOCs) were detected at levels exceeding the NJDEP Ground Water Quality Standards (GWQS) and/or federal Maximum Contaminant· Levels (MCLs). In one bedrock monitoring well, only trichloroethylene (TCE) was detected at 1.1 part per billion (Ppb) and 1.9 ppb. The GWQS for TCE is 1 ppb and the MCL is 5 ppb. The following inorganic compounds were detected in the UpperBedrock Aquifer atconcentrations exceeding the NJDEP GWQS and/or federal MCLs: aluminum, arsenic, lead and thallium.

The results ofthe sampling of the four wells in the Overburden Water Bearing zone indicated that three VOCs; vinyl chloride, benzene and trichloroethylene; were detected at concentrations exceeding state GWQS and/or federal MCLs. Vinyl chloride was detected in one well at concentrations ranging up to 7.3 ppb. Benzene was detected at concentrations of2.9 ppb to' 16 ppb. Trichloroethylene was detected at concentrations ranging from 2.7 ppb to 19 ppb. In addition, the sampling results indicated that the following inorganic compounds were detected at . concentrations exceeding the GWQS and/or MCLs: aluminum~ arsenic, iron, lead, manganese, sodium, and thallium.

It should be noted that the water in the Overburden Water Bearingzone is not currently being used as a potable water source. In the Overburden Water Bearing zone, the soil is characterized. as unstratified with low permeability and low yields (less than two gallons per minute (gpm)). Aquifer yields ofgreater than two gpm are required for residential, agricultural or commercial use. Therefore, the Overburden Water Bearing zone portion ofthe·aquifet does not produce sufficient quantities of water to teadilyserve as a reliable long-term potable source.

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Residents and businesses in the vicinity of the Site receive their water from public water supply wells which are operated by the municipalities of Garfield, Lodi, and Fair Lawn. The township of Garfield operates two municipal wells, which are approximately one mile upgradient of the Site. The townships of Lodi and Fair Lawn operate municipals wells within two to three miles of the area of the Site. In addition, the water drawn from the public water supply wells that are operated by the municipalities of Garfield, Lodi, and Fair Lawn, is currently being treated, prior to distribution, for the presence ofVOCs which are not related to the Site. The average depth of all of these municipal supply wells is approximately 400 feet below ground surface.

After careful consideration of site-specific details and analysis of all data collected, in September 1997, EPA selected a No Further Action remedy, with long-term monitoring. The major components of the No Further Action remedy are:

• Implementation of a groundwater monitoring program to monitor contaminants in the groundwater. Groundwater samples will be collected and analyzed for Target Compound List (TCL) volatile organic compounds (VOCs) and Target Analyte List (TAL) inorganic compounds for the first year on approximately a quarterly basis. Special analytical services will be used, where appropriate, in the analytical procedures to minimize any variability of data. The monitoring program may be modified based upon sampling results collected during the first year. Currently, EPA and NJDEP do not believe that additional groundwater monitoring wells will be required for the purpose of the sampling program. However, if the results of the initial rounds of sampling indicate that additional wells are necessary, then they will be installed;

• A Classification Exception Area (CEA) will be established by NJDEP to provide information on contamination in the groundwater resulting from Site operations. The CEA will remain in effect until contaminant levels are below New Jersey Groundwater Quality Standards. NJDEP may establish a Well Restriction Area (WRA) if groundwater contamination associated with the Site should be determined to impact potential users. By establishing a WRA, NJDEP can assure that contaminants in the groundwater will not pose a threat to human health as a result of well installation and operations; and

• After five years, or less, if the sampling and analyses indicate the need for action, the potential risks to human health and the environment will be reassessed. The groundwater monitoring would then either continue for another five-year period, or some other action will be considered. If monitoring reveals that contamination at the Site increases so that an unacceptable risk to human health or the environment develops, an appropriate action can be initiated at any time during the five-year period to address the risks. The CEA will remain in effect until constituents in the groundwater do not exceed established drinking water standards.

In September 1999, the Respondents entered into an Administrative Order on Consent (Index No. CERCLA-02-99-2026) (ACO) with EPA to conduct the groundwater monitoring program for OU-2. In February 2000, EPA approved the Groundwater Monitoring Work Plan. The Groundwater Monitoring Program which initially included quarterly sampling of on-site

13

monitoring wells, was conducted in 2000 and 2001. Hi-annual groundwater sampling was conducted in 2002,2003, and 2004. In April 2005, the respondents entered into an Amendment to the September 1999 ACO to continue the groundwater monitoring program at the Site. Annual groundwater sampling was conducted in 2005,2006; 2007 and 2008. In 2010, groundwater sampling began being conducted on a biennial basis. The first biennial sampling event was conducted 2010 and is ongoing.

In April 2011, the. 1999 ACO was amended,again (Second Amendment to the 1999 ACO) to extend the monitoring program for an additional five years. The ne'xt biennial groundwater sampling event will be in 2012.

Residential Well Findings

As part of the groundwater investigation, the Respondents conducted an updated well record search. The updated well record search indicated that there are no private wells in a . dOWngradient direction' within 'orie mile of the Site and within the Overburden Water Bearing zone or the Upper Bedrock Aquifer zone. There is one private well, located 2Sfeet upgradient from the Site, which was sampled in February 1997~ No organic orinorganic contaminants were found to be present in this well at levels above established drinking water standards. .

Groundwat~r Monitoring Program

The contaminated soil at the Site has been excavated, disposed off-site, and the area has been restored. There are no hazardous substances above residential standards remaining in Site soils. Since March 2000, a Groundwater Monitoring Program has been ongoing to monitor contaminants in the groundwater. Seven detailed "AnnualGroundwater Monitoring Reports" and the First and Second "Five-Year Groundwater Monitoring Reports" have been submitted to EPA by the Respondent's contractor, CH2M Hill. The details presented in these reports include a discussion of: the collection and analysis of groundwater samples from on-site wells; resurveying ofmonitoring wells; rehabilitation of outer flushmount protective road boxes of monitoring wells; obtainitlg additional concentration and flow dataat routine points; water level measurements taken during each sampling event; and coordination of the disposal of purge water. These reports also provide information related to addressing identified problems. Routine maintenance includ.es inspection of the concrete slab over the East Lot portion of the Site and monitoring well integrity. Progress reports are also submitted at the completion of each round of sampling. .

Seven groundwater monitoring wells are currently on-site. ,Four wells are installed in the Overburden Water Bearing zone at a depth pf approximately 10 feet below ground surface and three wells are installed in the Upper Bedrock Aquifer zone at depths ranging from approximately 50 feet to 68 feet below ground surface.

Institutional Control Implementation:

In December 2006, a CEA application was submitted toNJDEPby Con Ed for approval.

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NJDEP established the CEA on October 1, 2008.

V. Progress Since the Last Review

The second five-year review for this Site found the OUI remedy to be protective and the OU2 remedy to be protective in the short-term. The second five-year review suggestedthat groundwater monitoring of all the overburden and bedrock wells for VOCs and metals be continued and that the CEA be implemented. The issue/recommendation identified was to establish the CEA.

Annual groundwater sampling of all the overburden and bedrock wells was conducted in 2007 and 2008. Biennial groundwater sampling of overburden monitoring wells was conducted in 2010. The next biennial groundwater sampling event will be in 2012.

As indicated above, a CEA application was submitted to NJDEP by Con Ed for approval in December 2006. NJDEP established the CEA on October 1, 2008.

Following the establishment of the CEA, New Jersey Department of Environmental Protection (NJDEP) sent a letter to EPA dated October 28,2009 (Attachment 2) regarding the 2007 Annual GMPR and the establishment of the CEA at the Site. In this letter, NJDEP indicated that the collection of groundwater samples from the bedrock monitoring wells (BR-l, BR-2, and BR-3) at the Site are no longer required. As a result, EPA performed a comprehensive review of all of the groundwater data collected from the bedrock monitoring wells since the Groundwater Monitoring Program commenced in 2001, reviewed several of the prior Annual GMPRs, including the Year 2007 GMPR, and requested the additional Technical Memorandums prepared by CH2M Hill titled, Evaluation ofArsenic in Groundwater ofBrunswick Aquifer at Curcio Scrap Metal, Inc. Superfund Site (dated March 25, 2010) , and Evaluation ofLead in Groundwater ofBrunswick Aquifer at Curcio Scrap Metal, Inc. Superfund Site (dated May 18, 2010). After EPA's comprehensive review of all the above information, EPA determined that the sporadic low level exceedences of lead and arsenic appear to originate from regional geochemical conditions in the bedrock groundwater, rather than site-related sources. Therefore, EPA is in concurrence with NJDEP's recommendation regarding the bedrock wells and has agreed that no further monitoring of bedrock wells (BR-l, BR-2, and BR-3) will be necessary and these wells will be decommissioned in early 2012, in accordance with NJDEP policy.

VI. Five-Year Review Process

Administrative Components

The five-year review team consisted of Michelle Granger of EPA, Remedial Project Manager, Kimberly O'Connell (EPA - Section Chief), Marian Olsen (EPA-Risk Assessor), Katherine Mishkin, EPA-Hydrogeologist), and Pat Seppi (EPA-Community Involvement Coordinator).

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Community Involvement

EPA published a Public Notice in the "Bergen Record", a local/regional newspaper, on Thursday, December 15,2011 to notify the community of the five-year review and to address any public comment. The Notice included the EPA RPM's name, work address, and telephone number for public inquiries related to the five-year review of the Curcio Scrap Metal Inc. Site. It was also indicated that once the five-year review was completed, the results will be made available in the local repository at the Saddle Brook Memorial Library, 340 Mayhill Street, Saddle Brook, New Jersey, 07662. No comments from members of the public were received as a result of the above-described Public Notice.

Michelle Granger of EPA has discussed the ongoing groundwater monitoring program with the five-year review team, the Respondents, and the Saddle Brook Town Administrator. There were no issues or concerns raised about the protectiveness of the remedies for the Site.

Document Review

The documents, data, and information which were reviewed in completing the five-year review· are summarized in Table 2 (attached). Table 3 (attached) provides a listing of acronyms used in this document.

Groundwater Data Review

This Five Year Review focuses on analyzing groundwater data collected since the second Five Year Review in 2007 and comparing it to historical groundwater data.

Annual groundwater sampling of the overburden and upper bedrock aquifer units was conducted in 2007 and 2008. The 2007 and 2008 groundwater samples were analyzed for target compound list(TCL) VOCs and a reduced list of target analyte list (TAL) metals, The reduced list of TAL metals analyzed for included aluminum, arsenic, cadmium, iron, lead, manganese, and sodium.

The first round of biennial groundwater sampling of all overburden wells was conducted in 2010. The 20 I0 groundwater samples were analyzed for TCL VOCs and select TAL metals (aluminum, arsenic, lead, and manganese).

Between October 2007 and August 2010 all groundwater sampling results indicate the following:

• Overburden Monitoring Wells - VOCs Data - Low concentrations ofVOCs were· .detected in two of the four overburden wells sampled. These two wells, MW-3R and MW-4R, are located at the downgradient edge of the Site. Benzene and trichloroethene (TCE) were detected at levels that exceeded the state (NJ GWQS) and federal standards (MCLs). No VOCs were detected in the other overburden monitoring wells (MW-1 R and MW-2) during any of the sampling events. Historically, benzene has been consistently detected at low levels above the state and federal standards in MW-3R. During this review period, for the first time, benzene was detected at 0.5 ppb in MW-3R which is below the federal and state standards, however, monitoring for benzene will be continued. Historical TeE data levels in MW-4R have consistently fluctuated above the state and federal

16

standards, between 0.5 ppb to 18 ppb. TCE concentrations in MW-4R decreased slightly during this five-year review period from 12 ppb in 2007 to 10 ppb in 2010.

• Overburden Monitoring Wells - Metals Data - Arsenic, lead, and manganese were detected in the overburden wells at concentrations that exceeded the state or federal standards. Aluminum concentrations are shown to be at concentrations equivalent to the federal and state secondary standards. EPA modified the groundwater monitoring program in 2010. Cadmium, iron and sodium are no longer included in the monitoring program as levels detected were below levels of concern. Historical arsenic data indicates arsenic levels in MW-3R have consistently fluctuated above the state and federal standards, at levels between 175 ppb and 273 ppb. Historical lead data indicates lead levels in MW-4R have consistently fluctuated above the state and federal standards, at levels between 11 ppb and 100 ppb. While most historical lead concentrations were within this range, an exceedence as high as 424 ppb in 2006 at MW-4R has been noted. Manganese has been consistently detected at levels exceeding the federal and state standards in MW-2.

• Upper Bedrock Monitoring Wells - VOCs and Metals 2007 and 2008 Data - No VOCs were detected in the upper bedrock monitoring wells at levels exceeding state or federal standards. Iron and lead were detected above the state and federal standards. In 2009 and 2010, EPA performed a comprehensive review of all groundwater data collected from the bedrock wells (taken since the groundwater program commenced in 2001), and relevant technical memorandums. Based on this comprehensive review, EPA determined that the sporadic low level exceedences of lead and arsenic appear to originate from regional geochemical conditions in the bedrock groundwater, rather than site-related sources. In 2010, EPA requested that all bedrock wells (BR-l, BR-2, and BR-3) be eliminated from the groundwater sampling plan. These wells will be decommissioned in early 2012, in accordance with NJDEP policy.

Based on EPA's review of the groundwater monitoring data obtained to date as part of the Site long term Groundwater Monitoring Program, it appears that contaminant levels detected during the Groundwater Monitoring Program are within the same range as contaminant levels detected during the 1996 - 1997 groundwater remedial investigation and the previous Five Year Reviews. EPA has determined that while conditions at the Site are relatively stable, some contaminants have been detected above state and federal standards and the monitoring program will continue. The extent of groundwater contamination is known sufficiently to determine that no humans are consuming contaminated groundwater. In addition, a CEA has been established by NJDEP to assure that drinking water wells will not be placed in the vicinity of the Site in the future.

Based on static water-level measurements recorded during the groundwater monitoring program and by comparing overburden and bedrock contours, an upward gradient exists from the bedrock to the overburden in the area ofMW-3R and MW-4R. EPA performed a study to better understand the vertical flow conditions within the overburden and bedrock units which involved collection of daily water level elevations in MW-3R and BR-l from March 2003 to March 2004. This study provided a better understanding of the degree of hydraulic connection between these units and the land surface with respect to precipitation events, seasonal changes, possible nearby pumping, or sump pump operations. After approximately a year of water level monitoring, water level elevations and vertical gradients at MW-3R and BR-l were fully characterized and found to

17

be easily predicted, and because the groundwater quality data provided no indication of migration of contamination downward, water level monitoring was discontinued.

Additionally, water level data indicated the Site has a low horizontal gradient. The monitoring wells are low yielding and the formation is not readily conducive to groundwater flow, thereby contributing to static and sporadic contaminant levels. The groundwater sampling results indicate that the Site is not impacted by definable plumes of groundwater contamination, but by sporadic exceedances of low concentr~tionsover a small area.

Based on the findings of this five-year review, continued groundwater monitoring is warranted. Biennial groundwater monitoring for VOCs and select metals will continue to be implemented for all overburden monitoring wells.

Site Inspection

An inspection of the Curcio Scrap Metal Inc. Site was conducted by Michelle Granger (EPA), Katherine Mishkin (EPA, hydrogeologist), and Marian Olsen (EPA, Risk Assessor) on November 8, 2011. In general, the inspection found the Site's concrete slab covering the East Lot to be well-maintained and functioning in accordance with the design. There was no evidence of settlement or cracks. The monitoring wells are operational and functional.

Interviews

Michelle Granger of EPA has discussed the ongoing groundwater monitoring program with the five-year review team, the Respondent, and the Saddle Brook Town Administrator. There were no issues or concerns raised about the protectiveness of the remedies in place at the Site. After the inspection, EPA also spoke with representatives ofNJDEP and NJDEP indicated that they did not have any specific concerns regarding the selected remedies for the Site at this time.

VII. Remedy Assessment

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

Yes, the remedies are functioning as intended based on the information provided in the RODs for OU-l and OU-2.

OU-l established the following remedial objectives:

• Excavation of soil contaminated with polychlorinated biphenyls (PCBs) and heavy metals above applicable cleanup standards, and

• Transportation of the excavated soil to an appropriate incineration facility for treatment and/or disposal.

Direct contact risks associated with contact with contaminated soils and sediment were addressed through the excavation and removal of the soils and sediment and disposal of these materials at

18

an off-site facility. As discussed in the March 1994 Remedial Action Report, the Potentially Responsible Parties (PRPs) remediated the contaminated unsaturated soils from the East Lot and its immediate vicinity and the storm sewer system servicing the Site. In addition, the PRPs excavated sediments from an area where the sewer system discharged storm water runoff. In June 1995, the PRPs completed removal of contaminated sediment from Schroeder's Brook and a small body of standing water located near the Site. The remedy has been fully implemented and remedial objectives have been met.

OU2: In September 1997, the OU-2 groundwater ROD determined No Further Action was needed for groundwater with requirements for monitoring. The ROD required sampling of seven monitoring wells located at the Site; four wells screened in the unconsolidated overburden materials, and three wells installed in the shallow bedrock (50 feet below grade). The groundwater sampling required analysis for Target Compound List (TCL) VOCs, and TAL inorganic compounds including aluminum, arsenic, cadmium, iron, lead, manganese and sodium. Table 3 provides a comparison of the federal MCLs and NJDEP Class II A Groundwater Quality Criteria with the maximum concentrations from the July 2011 Groundwater Monitoring Program Report. The comparison indicates that the concentration of benzene of 0.5 ppb in well MW-3R was below the NJDEP Class II A Groundwater Quality Criteria of 1 ppb in 2010. TCE was detected in well MW-4R (overburden well) in August of2010 at a concentration of 10 ppb and this concentration exceeds the NJDEP Class II A GWQC value of 1 ppb and the federal MCL of 5 ppb. The concentration oflead of92 ppb detected in MW-4R exceeded the NJDEP Class II A GWQC value of 10 ppb and the federal action level of 15 ppb. Historical lead data indicates lead levels in MW-4R have consistently fluctuated above the state and federal standards, between Ilppb and 100 ppb. The concentration of arsenic in MW-3R (overburden well) of273 ppb exceeded the NJDEP Class II A GWQC of 8 ppb and the federal MCL of 50 ppb established in the ROD. The MCL for arsenic was subsequently updated in 2006 to 10 microgrmas per liter (ug/l). Historical arsenic data indicates arsenic levels in MW-3R have consistently fluctuated above the state and federal standards, between 175 ppb and 273 ppb. Of the four overburden wells, MW-3R is the only well with elevated arsenic levels.

Potential exposure to groundwater contaminants has been addressed through the establishment of a Classification Exception Area (CEA) by NJDEP as required by the ROD and established on October 1, 2008. The CEA is located solely within the Site and adjacent properties. Under the CEA, NJDEP requires biennial monitoring in the overburden water bearing unit in two wells (MW-3R and MW-4R) for VOCs plus aluminum, arsenic, lead and manganese. Collection of groundwater samples from the deeper bedrock wells (BRl, BR-2, and BR-3) is not required. EPA performed a comprehensive review of all groundwater data collected from the bedrock wells (taken since the groundwater program commenced in 2001), and relevant technical memorandums. Based on this comprehensive review, EPA determined that the sporadic low level exceedences of lead and arsenic originate from regional geochemical conditions in the bedrock groundwater, rather than site-related sources. In 2010, EPA agreed that all bedrock wells (BR-l, BR-2, and BR-3) could be eliminated from the groundwater sampling program. These wells will be decommissioned in early 2012, in accordance with NJDEP policy. Based on groundwater flow and contamination transport calculations, the PRP's estimate the duration of the CEA will be 21 years. The CEA established by NJDEP assures that there will be no unacceptable future use of contaminated groundwater in the vicinity of the Site and the exposure pathway will remain interrupted.

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Question B: Are the exposure assumptiOns, toxicity data, cleanup levels, and remedial action objectives used at the time ofthe r~medy still valid? '

There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. This is an operating,facilityin amixedzonedarea that includes commercial/industrial and residential.properties. The main entrance to the Site is from Lanza Avenue where trucks enter to bring'salvage materials. Physical barriers,and Route' 46 on the north, New Jersey Transit railroad tracks and right-of-way on the east and Midland Avenue on the west limit access to the Site. The majority of the Site is covered with current salvage materials and a ten-inch thickreinforced !concrete slab currently covers the entire surface area of the East Lot where excavation and removal of soil w~re conducted underthe original ROD,

The exposure assumptions used to develop ,the baseline human health risk assessment for the Site were for currentand'future exposures from Site contaminants for a residential use scenario~ The exposure assUinptions have not changed since the 'original baseline risk assessment. These assumptions are considered to be protective and represeritative of a reasonable maximum exposure. The remediation goal of 1 part per million (ppm) for PCBs established in the ROD remains protectiv~ for residential property use. Confirmatory sampling indicated that the soil cleanup levels (including NiDEP action levels for metals) were achieved. EPA conducted a final inspection on January 19, 1994 and determined that all remedial actions were successfully implemented by the Respondents. '

Groundwater. Currently, residents in the vicinity of the Site receive their water from public water supply wells which are operated by the municipalities of Garfield, Lodi and Fair Lawn. The baseline risk assessment indicated that the Site media did not pose any significant risk to human health with the exception of the hazards associated with the Overburden Water Bearing zone wells if the overburden water was used as a potable source. A CEA was established by NJDEP in 2008. The CEA serves to prevent potential exposures to contaminants in the shallow overburden water bearing zone under current'and future exposures scenarios. 'Furthermore, it is itnportant to note that the Overburden W~ter Bearing zone cannot support potable use based on its lowyield of groundwater; therefore, the risks posed byexposure to the limited area of contamination are not likely. There has been no significant change to the standardized risk assessment methodology that could affectthe protectiveness of the remedy. The remedy is progressing'as expected. The ongoing groundwater monitoring found concentrationsof several contaminants that exceed the current federal and state standards ,as described above; therefore, continued groundwater monitoring of the overburden monitoring wells is warranted.

Groundwater was collected over the past five years during three sampling events (2007, 2008 and 2010) and analyzed for select volatile organics'and seleCt TAL metals. Table 3 (attached) identifies the maximum concentrations ofthechemicalsdetectedduringthis review period, their respective state and federal MCLs, the wells where the detectiqnsexceeded these standards, and the year of the sampling event. Overall, the concentrations were comparable to previous years.

The ROD established the MCLsas the cleanup criteria for contaminants of concern identified

20

above. The MCL listed in the ROD for arsenic was 50 pph and this value was subsequently updated in 2006 to 10 ppb. In addition, local background arsenic levels indicate that arsenic is naturally elevated in bedrock. The toxicity values for b~nzene and TCE were updated through the Integrated Risk Information System (IRIS). The EPAMCLs and NJDEP groundwater quality standards remain protective. These changes in toxicity values do not change the overall protectiveness of the remedial action.

Soil Vapor Intrusion. Consistent with the Soil Vapor Intrusion Guidance, monitoring wells were evaluated based on groundwater concentrations of volatile organic compounds above screening levels. Only one well (MW-4R) had an elevated concentration ofTCE at 12 ppb; the

. remaining three wells had non-detectable levels at a detection limit of 0.5 ppb. The maximum concentration is above the screening level in the 2002 OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (Subsurface Vapor Intrusion Guidance) of 5.3 associated with a cancer risk of 1 x 10-4. The,concentration of 12 ppb is within the upperbounds of the risk range. However, this well is located over 100 feet from the nearest residence. Consistent with the Soil Vapor Intrusion Guidance, based on this distance, further evaluation of vapor intrusion at this Siteis not warranted. Note that the Site area is very small and that other closely located wells to MW-4R (MW-IR, MW-2, and MW-3R) all have acceptable levels. ." .

'''. '.' ' .n,. \ i ,

Overall, based on the past remedial actions and ongoing ~onitoring at'the Site, the remedy remains protective under the industrial and residential scenarios.

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

There is no other information that calls into question the protectiveness of the remedies implemented atthe Curcio Scrap Metal, Inc. Site. No ecological targets were identified during the baseline risk assessment and none were identified during the five-year review, and therefore monitoring of ecological targets is not necessary. No weather-related events have affected the protectiveness of the remedy.

VIII. Recommendations and Follow-Up Actions

The selected remedy includes ongoing monitoring activities which are subject to routine modification and adjustment. This report did not identify any issue or need to make any . recommendation for the protection of public health and/or the environment which was not included or anticipated by the Site decision documents.

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ugdan, Director and Remedial Response Division

IX. Protectiveness Statement

This five-year review found thatthe 'OU2remediai approaches are functioning as intended by the decision documents. The OU2 remedy at the Curcio Scrap Metal Superfund Site is expected to be protective upon completion of the groundwater monitoring program, and in the interim, exposure pathways that could result in unacceptable risks are being controlled by the implementation ofthe NJ CEA. The OU2 groundwater remedyis fully implemented and is protective.

X. Next RevieW

The next five-year review for the Curcio- Scrap Metal, Ip.c. Site should be completed'by March 2017. .

Approved:

Date

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,

.

Table 2: Documents, Data, andlnformation Used in Co;"p[etingFive-Year Review

~ Curcio Scrap Metal OU-l Record of Decision, EPA, June 1991

~ Curcio Scrap Metal- Inc.'Explanation of Significant Difference, EPA, August 1992

~ Curcio Scrap Metal Site OU-l Remedial Action Report, CH2M Hill, March 1994

~ Curcio Scrap Metal Site OU-2 Final Groundwater Investigation Report, CH2M Hill, March 1997

~ Curcio Scrap Metal Inc. OU·2 Record of Decision, EPA, September 1997

~ CERCUS Database Information, July 2002

~ Annual Groundwater Monitoring Report, CH2M Hill, April 2001

~ Annual Groundwater Monitoring Report, CH2M Hill, July 2002 , .'

~ Annual Groundwater Monitoring Report,CH2M Hill, February 2003

~ Annual Groundwater Monitoring Report CH2M Hill, March 2004

~ First FiveYear Groundwater Monitorirtg Report, CH2M Hill, January 2005

~ Progress Report No. 16 - May2005 Validated GrourtdwaterResults, January 2007

~ Progress Report No. 17 - October 2006 Validated Groundwater Results, January 2007 . .

~ Annual Groundwater Monitoring Report, CH2M Hill, March 2007

~ Annual Groundwater Monitoring Report, CH2M Hill, September 2008

~ Evaluation of Arsenic in Groundwater of Brunswick Aquifer at Curcio Scrap Metal Inc. Site, March 2010

~ Evaluation of Lead in Groundwat~r of Brunswick Aquifer at Curcio Scrap Metal Inc. Site, May 2010

. .

~ Annual Groundwater Monitoring Report, CH2M Hill, June 2011

~ Biennial Groundwater Monitoring Report, CH2M Hill, July 2011

~ Second Five Year Groundwater Monitoring Report, CH2M Hill, July 2011

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Table 3: Chemicals above detection limits in the 2007 - 2008 and 2010 rounds of sampling and their respective state and federal MCLs, and the wells where the detections exceeded these standards . . Chemical EPAMCL NJDEP Max. Max Cone. Result from

(ugll) Primary and

Cone. Location

2010 Location

2010

Secondary Drinking. Water

(2007 ­2008 )

Standards* (ugll)

Benzene 5 1 3.1 (MW­3R)

0.5 ppb (aU overburden wells)

Below NJDEP Primary MCL

Trichloroethylene 5 1 12 ppb . (MW-·

4R)

10ppb (MW-4R)

Exceeds NJDEP Primary MCLand federal MCL

Aluminum 50 ~ 200 (secondary standard)

200 (secondary standard)

200 ppb (MW­3R, -4R)

200 ppb (MW-3R, ­4R)

Equal to NJDEP secondary standards

Arsenic 10 5 274 ppb (MW­3R)

273 ppb (MW-3R)

Exceeds NJDEP Primary MCLand federal MCs

Lead 15 (action level) 15 (action level)

23.7 ppb (MW;. 4R)

92ppb (MW-4R)

Exceeds EPA Action Level and state Action Level

Manganese 50 (secondary standard)

50 (secondary standard)

9,040 ppb (MW-2)

10,300 ppb (MW-2)

Exceeds . NJDEP and

federal secondary standards

• Values from http://www.state.nj:us/dep/watersupply/standard.htm#inorganics. • Values from http://www.epa.gov/safewater/contaminants/index.html#mcls.

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