Five-Year Review Report Chemical Insecticide Corporation Superfund Site Edison Township Middlesex County New Jersey

Prepared By United States Environmental Protection Agency

Region II New York New York

March 2009

Executive Summary

This is the third five-year review for the Chemical Insecticide Corporation (CIC) Superfund Site (site) The site is located in Township of Edison Middlesex County New Jersey

The site was addressed in four remedial phases or Operable Units (OUs) Operable Unit One (OUI) was an interim remedy to control contaminated runofffrom the site based on a Record of Decision (ROD) issued on September 29 1989 Operable Unit Three (OU3) was a final remedy addressing contaminated soil and sediment in off-site creek areas based upon a ROD issued on March 28 1995 Operable Unit Two (OU2) was the final remedy for surface and subsurface soils at the site based upon a ROD issued on September 29 2000 Operable Unit Four (OU4) was the final remedy addressing the contaminated groundwater associated with the site based upon a ROD issued December 22 2003 The OUI OU2 and OU3 remedial actions have been completed and no further actions are anticipated The groundwater remedy (OU4) which requires long-tenn groundwater monitoring and institutional controls is currently being implemented Under the OU4 remedy monitoring activities have indicated that groundwater in the overburden and bedrock aquifers is contaminated at the site and nearby areas This is consistent with the findings of the OU4 ROD which included an applicable or relevant and appropriate requirement (ARAR) waiver for the area of contaminated groundwater due to technical impracticability The conditions that led to the waiver of ARARs were still found to be present during this five-year review Based on the data collected to date constituents ofconcern include metals (specifically arsenic) SHe pesticides (specifically alpha-SHC) herbicides (specifically dinoseb) and to a lesser extent volatile organic compounds (VQCs) (benzene and chlorinated solvents) However there were some notable decreases in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations

This five-year review found that the remedies are functioning as intended by the decision documents and are protecting human health and the environment

2

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN) Chemical Insecticide Corporation

EPA lD (from WasteLAN) NID980484653

NPL status bull Final 0 Deleted 0 Other (specify)

Remediation status (choose all that apply) 0 Under Construction Constructed bull Operating

MUltiple ausmiddot bull YES 0 NO Construction completion date NA

Has site been put into reuse 0 YES 0 NO bull NA

IHII SI IlS

Lead agency bull EPA 0 State 0 Tribe 0 Other Federal Agency

Author name Mark Austin

Author title Remedial Project Manager IAuthor affiliation EPA

Reviewperiod 122912003 to 012292008

Date(s) of site insplaquotion 11242008

Type of review bull Post-SARA o Pre-SARA o NPlrRemoval only o Non-NPL Remedial Action Site o NPL StateTribe-lead o Policy o Regional Discretion

Review number o 1 (first) 02 (second) bull 3 (third) 0 Other (specifY)

Triggering action o Actual RA Onsite Construction at OU ~_o Actual RA Start at OU__ o Construction Completion bull Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN) 1212912003 (Previous Five-Year Review)

Does the report include recommendation(s) and follow-up action(s) 0 no Is the remedy protective of the environment o no

bull (OU refers to operable Ufllt]

bullbull [Review period should correspond to the actual start and end dates of the Five-Year Review in WastelAN]

3

Five-Year Review Summary Form (continued)

Issues

- A Classification Exception Area (CEA) part of the OU4 remedy restricting the installation ofwells and groundwater use in the area ofsite-related groundwater contamination needs to be established - Gaps in the fencing found during the November 2008 site inspection could allow for trespassing - A deed notice for continued use of the property as non-residential (comm~ciaVlight industrial) identified in the OU2 ROD has yet to be implemented and is under review

Recommendations and Follow-up Actions

- The CEA is currently being prepared - Gaps in the fencing will be repaired to protect the existing monitoring wells - The deed notice requirement as part ofOU2 is being reviewed by EPA Ifit is detennined that a deed notice is not necessary EPA will issue an Explanation of Significant Differences (ESD) that will waive both institutional controls and future five-year review requirements under the OU2 remedy

Other Comments on Operation Maintenance Monitoring and Institutional Controls

EPA will continue to conduct routine operation and maintenance activities at the site and adjustments to these activities will be made on an ongoing basis as needed

Once the CEA (an OU4 institutional control) is established for the site and surrounding areas EPA will work with the New Jersey Department of Environmental Protection (NJDEP) to ensure its effectiveness

The technical impracticability (TI) conditions that led to the need for a Tl waiver of applicable or relevant and appropriate requirements ofother statutes (ARARs) still exist and the TI waiver is still appropriate

Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility of exposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-tenn institutional controls preventing groundwater use need to be implemented

4

Table of Contents

Executive Summary bull 2

Five-Year Review Summary Fenn 3

T Introduction _ 7

II Site Chronologybullbullbullbullbullbull 8

III Background 9

Physical Characteristics 9 Geology 9 Hydrogeology 10 Land and Resource Use 10 History ofContatnination 10 Initial ResJX)nse II

IV Remedial Actions 11

Remedy Selection and Implementation 11

V Progress Since Last Review 13

VI Five-Year Review Process 14

Administrative Components 14 Community Involvement 15 Document Review 15 Data Review 15 Site Inspection 17 Interviews 17

VII Technical Assessment 18

Question A Is the remedy functioning as intended by the decision documents 18

QuestionB Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time ofthe remedy selection still valid 19

Question C Has any other information come to light that could call into question the protectiveness ofthe remedy 20

Technical Assessment Summary 20

5

Executive Summary

This is the third five-year review for the Chemical Insecticide Corporation (CIC) Superfund Site (site) The site is located in Township of Edison Middlesex County New Jersey

The site was addressed in four remedial phases or Operable Units (OUs) Operable Unit One (OUI) was an interim remedy to control contaminated runofffrom the site based on a Record of Decision (ROD) issued on September 29 1989 Operable Unit Three (OU3) was a final remedy addressing contaminated soil and sediment in off-site creek areas based upon a ROD issued on March 28 1995 Operable Unit Two (OU2) was the final remedy for surface and subsurface soils at the site based upon a ROD issued on September 29 2000 Operable Unit Four (OU4) was the final remedy addressing the contaminated groundwater associated with the site based upon a ROD issued December 22 2003 The OUI OU2 and OU3 remedial actions have been completed and no further actions are anticipated The groundwater remedy (OU4) which requires long-tenn groundwater monitoring and institutional controls is currently being implemented Under the OU4 remedy monitoring activities have indicated that groundwater in the overburden and bedrock aquifers is contaminated at the site and nearby areas This is consistent with the findings of the OU4 ROD which included an applicable or relevant and appropriate requirement (ARAR) waiver for the area of contaminated groundwater due to technical impracticability The conditions that led to the waiver of ARARs were still found to be present during this five-year review Based on the data collected to date constituents ofconcern include metals (specifically arsenic) SHe pesticides (specifically alpha-SHC) herbicides (specifically dinoseb) and to a lesser extent volatile organic compounds (VQCs) (benzene and chlorinated solvents) However there were some notable decreases in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations

This five-year review found that the remedies are functioning as intended by the decision documents and are protecting human health and the environment

2

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN) Chemical Insecticide Corporation

EPA lD (from WasteLAN) NID980484653

NPL status bull Final 0 Deleted 0 Other (specify)

Remediation status (choose all that apply) 0 Under Construction Constructed bull Operating

MUltiple ausmiddot bull YES 0 NO Construction completion date NA

Has site been put into reuse 0 YES 0 NO bull NA

IHII SI IlS

Lead agency bull EPA 0 State 0 Tribe 0 Other Federal Agency

Author name Mark Austin

Author title Remedial Project Manager IAuthor affiliation EPA

Reviewperiod 122912003 to 012292008

Date(s) of site insplaquotion 11242008

Type of review bull Post-SARA o Pre-SARA o NPlrRemoval only o Non-NPL Remedial Action Site o NPL StateTribe-lead o Policy o Regional Discretion

Review number o 1 (first) 02 (second) bull 3 (third) 0 Other (specifY)

Triggering action o Actual RA Onsite Construction at OU ~_o Actual RA Start at OU__ o Construction Completion bull Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN) 1212912003 (Previous Five-Year Review)

Does the report include recommendation(s) and follow-up action(s) 0 no Is the remedy protective of the environment o no

bull (OU refers to operable Ufllt]

bullbull [Review period should correspond to the actual start and end dates of the Five-Year Review in WastelAN]

3

Five-Year Review Summary Form (continued)

Issues

- A Classification Exception Area (CEA) part of the OU4 remedy restricting the installation ofwells and groundwater use in the area ofsite-related groundwater contamination needs to be established - Gaps in the fencing found during the November 2008 site inspection could allow for trespassing - A deed notice for continued use of the property as non-residential (comm~ciaVlight industrial) identified in the OU2 ROD has yet to be implemented and is under review

Recommendations and Follow-up Actions

- The CEA is currently being prepared - Gaps in the fencing will be repaired to protect the existing monitoring wells - The deed notice requirement as part ofOU2 is being reviewed by EPA Ifit is detennined that a deed notice is not necessary EPA will issue an Explanation of Significant Differences (ESD) that will waive both institutional controls and future five-year review requirements under the OU2 remedy

Other Comments on Operation Maintenance Monitoring and Institutional Controls

EPA will continue to conduct routine operation and maintenance activities at the site and adjustments to these activities will be made on an ongoing basis as needed

Once the CEA (an OU4 institutional control) is established for the site and surrounding areas EPA will work with the New Jersey Department of Environmental Protection (NJDEP) to ensure its effectiveness

The technical impracticability (TI) conditions that led to the need for a Tl waiver of applicable or relevant and appropriate requirements ofother statutes (ARARs) still exist and the TI waiver is still appropriate

Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility of exposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-tenn institutional controls preventing groundwater use need to be implemented

4

Table of Contents

Executive Summary bull 2

Five-Year Review Summary Fenn 3

T Introduction _ 7

II Site Chronologybullbullbullbullbullbull 8

III Background 9

Physical Characteristics 9 Geology 9 Hydrogeology 10 Land and Resource Use 10 History ofContatnination 10 Initial ResJX)nse II

IV Remedial Actions 11

Remedy Selection and Implementation 11

V Progress Since Last Review 13

VI Five-Year Review Process 14

Administrative Components 14 Community Involvement 15 Document Review 15 Data Review 15 Site Inspection 17 Interviews 17

VII Technical Assessment 18

Question A Is the remedy functioning as intended by the decision documents 18

QuestionB Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time ofthe remedy selection still valid 19

Question C Has any other information come to light that could call into question the protectiveness ofthe remedy 20

Technical Assessment Summary 20

5

Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN) Chemical Insecticide Corporation

EPA lD (from WasteLAN) NID980484653

NPL status bull Final 0 Deleted 0 Other (specify)

Remediation status (choose all that apply) 0 Under Construction Constructed bull Operating

MUltiple ausmiddot bull YES 0 NO Construction completion date NA

Has site been put into reuse 0 YES 0 NO bull NA

IHII SI IlS

Lead agency bull EPA 0 State 0 Tribe 0 Other Federal Agency

Author name Mark Austin

Author title Remedial Project Manager IAuthor affiliation EPA

Reviewperiod 122912003 to 012292008

Date(s) of site insplaquotion 11242008

Type of review bull Post-SARA o Pre-SARA o NPlrRemoval only o Non-NPL Remedial Action Site o NPL StateTribe-lead o Policy o Regional Discretion

Review number o 1 (first) 02 (second) bull 3 (third) 0 Other (specifY)

Triggering action o Actual RA Onsite Construction at OU ~_o Actual RA Start at OU__ o Construction Completion bull Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN) 1212912003 (Previous Five-Year Review)

Does the report include recommendation(s) and follow-up action(s) 0 no Is the remedy protective of the environment o no

bull (OU refers to operable Ufllt]

bullbull [Review period should correspond to the actual start and end dates of the Five-Year Review in WastelAN]

3

Five-Year Review Summary Form (continued)

Issues

- A Classification Exception Area (CEA) part of the OU4 remedy restricting the installation ofwells and groundwater use in the area ofsite-related groundwater contamination needs to be established - Gaps in the fencing found during the November 2008 site inspection could allow for trespassing - A deed notice for continued use of the property as non-residential (comm~ciaVlight industrial) identified in the OU2 ROD has yet to be implemented and is under review

Recommendations and Follow-up Actions

- The CEA is currently being prepared - Gaps in the fencing will be repaired to protect the existing monitoring wells - The deed notice requirement as part ofOU2 is being reviewed by EPA Ifit is detennined that a deed notice is not necessary EPA will issue an Explanation of Significant Differences (ESD) that will waive both institutional controls and future five-year review requirements under the OU2 remedy

Other Comments on Operation Maintenance Monitoring and Institutional Controls

EPA will continue to conduct routine operation and maintenance activities at the site and adjustments to these activities will be made on an ongoing basis as needed

Once the CEA (an OU4 institutional control) is established for the site and surrounding areas EPA will work with the New Jersey Department of Environmental Protection (NJDEP) to ensure its effectiveness

The technical impracticability (TI) conditions that led to the need for a Tl waiver of applicable or relevant and appropriate requirements ofother statutes (ARARs) still exist and the TI waiver is still appropriate

Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility of exposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-tenn institutional controls preventing groundwater use need to be implemented

4

Table of Contents

Executive Summary bull 2

Five-Year Review Summary Fenn 3

T Introduction _ 7

II Site Chronologybullbullbullbullbullbull 8

III Background 9

Physical Characteristics 9 Geology 9 Hydrogeology 10 Land and Resource Use 10 History ofContatnination 10 Initial ResJX)nse II

IV Remedial Actions 11

Remedy Selection and Implementation 11

V Progress Since Last Review 13

VI Five-Year Review Process 14

Administrative Components 14 Community Involvement 15 Document Review 15 Data Review 15 Site Inspection 17 Interviews 17

VII Technical Assessment 18

Question A Is the remedy functioning as intended by the decision documents 18

QuestionB Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time ofthe remedy selection still valid 19

Question C Has any other information come to light that could call into question the protectiveness ofthe remedy 20

Technical Assessment Summary 20

5

Five-Year Review Summary Form (continued)

Issues

- A Classification Exception Area (CEA) part of the OU4 remedy restricting the installation ofwells and groundwater use in the area ofsite-related groundwater contamination needs to be established - Gaps in the fencing found during the November 2008 site inspection could allow for trespassing - A deed notice for continued use of the property as non-residential (comm~ciaVlight industrial) identified in the OU2 ROD has yet to be implemented and is under review

Recommendations and Follow-up Actions

- The CEA is currently being prepared - Gaps in the fencing will be repaired to protect the existing monitoring wells - The deed notice requirement as part ofOU2 is being reviewed by EPA Ifit is detennined that a deed notice is not necessary EPA will issue an Explanation of Significant Differences (ESD) that will waive both institutional controls and future five-year review requirements under the OU2 remedy

Other Comments on Operation Maintenance Monitoring and Institutional Controls

EPA will continue to conduct routine operation and maintenance activities at the site and adjustments to these activities will be made on an ongoing basis as needed

Once the CEA (an OU4 institutional control) is established for the site and surrounding areas EPA will work with the New Jersey Department of Environmental Protection (NJDEP) to ensure its effectiveness

The technical impracticability (TI) conditions that led to the need for a Tl waiver of applicable or relevant and appropriate requirements ofother statutes (ARARs) still exist and the TI waiver is still appropriate

Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility of exposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-tenn institutional controls preventing groundwater use need to be implemented

4

Table of Contents

Executive Summary bull 2

Five-Year Review Summary Fenn 3

T Introduction _ 7

II Site Chronologybullbullbullbullbullbull 8

III Background 9

Physical Characteristics 9 Geology 9 Hydrogeology 10 Land and Resource Use 10 History ofContatnination 10 Initial ResJX)nse II

IV Remedial Actions 11

Remedy Selection and Implementation 11

V Progress Since Last Review 13

VI Five-Year Review Process 14

Administrative Components 14 Community Involvement 15 Document Review 15 Data Review 15 Site Inspection 17 Interviews 17

VII Technical Assessment 18

Question A Is the remedy functioning as intended by the decision documents 18

QuestionB Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time ofthe remedy selection still valid 19

Question C Has any other information come to light that could call into question the protectiveness ofthe remedy 20

Technical Assessment Summary 20

5

Table of Contents

Executive Summary bull 2

Five-Year Review Summary Fenn 3

T Introduction _ 7

II Site Chronologybullbullbullbullbullbull 8

III Background 9

Physical Characteristics 9 Geology 9 Hydrogeology 10 Land and Resource Use 10 History ofContatnination 10 Initial ResJX)nse II

IV Remedial Actions 11

Remedy Selection and Implementation 11

V Progress Since Last Review 13

VI Five-Year Review Process 14

Administrative Components 14 Community Involvement 15 Document Review 15 Data Review 15 Site Inspection 17 Interviews 17

VII Technical Assessment 18

Question A Is the remedy functioning as intended by the decision documents 18

QuestionB Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time ofthe remedy selection still valid 19

Question C Has any other information come to light that could call into question the protectiveness ofthe remedy 20

Technical Assessment Summary 20

5

VIII Issues Recommendations and Followmiddotup Actionsbull 21

IX Protectiveness Statement 21

IX Next Review 22

Appendix A List ofAcronyms 23

Appendix B Documents Reviewed 24

Figures 25

6

I Introduction

The purpose of the five-year review is to detennine whether the remedies at a site are protective ofhuman health and the environment The methods findings and conclusions of reviews are documented in Five-Year Review reports In addition Five-Year Review reports identity issues found during the review ifany and identity recommendations to address them

This review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended 42 USC Section 9601 et seq and 40 CFR 3oo430(f)(4)(ii) and in accordance with the Comprehensive Five-Year Review Guidance OSWER Directive 93557-03B-P (June 2001)

Tbe US Environmental Protection Agency (EPA) Region 2 conducted this five-year review of the remedies implemented at the Chemical Insecticide Corporation (CIC) Superfund site in Edison Township New Jersey This five-year review was conducted by Mark Austin Remedial Project Manager (RPM) This report documents the results of the review

This is the third five-year review for the CIC site The triggering action for this statutory review was the initiation of the first remedial action in September of 1990 A five-year review is required due to the fact that hazardous substances pollutants or contaminants remain at the site above levels that aUow for unlimited use and unrestricted exposure

The first five-year review for the site was completed in June 1998 In December 2003 EPA conducted a second five-year review which included several site visits by the EPA RPM in addition to a review ofdocuments data and available infonnation The purpose of the second five-year review was to examine whether the interim remedy under OU I at the site and the offshysite remedy under OU3 was protective of human health and the environment OU2 and OU4 were not completed at that time The 2003 five-year review detennined that the implemented remedies provided adequate protection of public health and the environment

This site (see Figure I) was addressed under four operable units (OUs) OUI was an interim remedy to control contaminated runoff from the site based on a Record of Decision (ROD) issued on September 29 1989 OU3 was a final remedy to address contaminated soil and sediment in off-site creek areas based upon a ROD issued on March 28 1995 OU2 was the final remedy for surface and subsurface soils at the site based upon a ROD issued on September 29 2000 OU4 was the final remedy addressing the contaminated groundwater based upon a ROD issued December 22 2003

To date OU I OU2 and OU3 have been completed The groundwater remedy (OU4) which is currently being implemented includes restricting the installation ofwells restricting the use of groundwater in the area ofgroundwater contamination and conducting a long-tenn groundwater sampling program to monitor the nature and extent of contamination and assess the migration and potential attenuation of the plume over time Because the OUI interim remedy has been superceded by the OU2 final remedy and because the OU3 remedy resulted in conditions that allow for unrestricted use and unlimited exposure for their respective media this and subsequent

7

five-year reviews will specifically consider the OU2 remedy results and the ongoing protectiveness of the OU4 groundwater remedy

ll Site Chronology

Table I below summarizes site-related events

Table I ebronololn of Site Events

EventActivity Date

CIC owned and operated the site for the formulating of and possibly the manufacturing of insecticides fungicides rodenticides 1954-1970 and herbicides

CIC declares bankruptcy The facility is bought by Piscataway 1970

Associates

EPA found extensive contamination on-site and limited off-site 1983

areas

Remedial Investigation (RI) initiated at the site 1987

Operable Unit One (OU I) ROD issued an interim remedy that consisted mainly offence installation capping the site and 91989 constructing a surface water runoff system

Site listed on EPAs National Priorities List (NPL) 81990

Investigations by EPA at off-site locations 1992-1993

OU I Remedy completed 91994

Operable Unit Three (OU3) ROD issued addressing soil and 31995

sediment contamination on off-site areas

OU3 Remedy initiated and completed 41997

First Five-Year Review completed 61998

Operable Unit Two (OU2) ROD issued consisting of the excavation and off-site disposal ofcontaminated soil followed by restoration of 912000 the all affected areas on site

EPA entered into a Settlement Agreement with Piscataway Associates 612001 and Piscatawav Corn landowners and PRP OU2 remedy commenced and OU2 baseline groundwater sampling 2003 event completed bv EPA Both the Second Five-Year Review and Operable Unit Four (OU4) ROD were issued OU4 selecting a groundwater remedy consisting of 122003 a lon(-term groundwater monitorinl Dian and institutional controls

OU2 Remedy completed 512005

OU2 post-remediation groundwater sampling event completed by 2005

EPA

OU4 Remedy initiated with a well inventoryusability survey 2006 cornoJetion

8

OU4 Quarterly groundwater monitoring events being implemented 2007 to present

OU2 Remedial Action Report approved 912007

CIC Property sold to Township of Edison by land owner 912008

III Background

Physical Characteristics

The CIC site (see Figure I) is a fenced 57-acre property located at 135 Whitman Avenue in Edison Township Middlesex County New Jersey It is bounded on the north by Route 287 on the east by a 35-foot wide Public Service Electric and Gas easement and active commercial properties owned by Metroplex and Total TEe on the south by a large warehouse owned by Morris Companies and property once occupied by the former Allied Chemical Company and on the west by a vacant industrial property formerly owned by MuDer Machinery and a COnrailCSX railroad right-of-way The site is currently covered with grass and also contains a rip rap channel and grass-lined swale to manage surface water runoffand drainage

The nearest residential properties are located approximately 300 to 400 yards away from the site and are separated from the site by either Route 287 to the north or the railroad right-of-way to the southwest There are no pennanent surface water bodies on the site After heavy precipitation the surface water runoffdrains toward the northeast comer of the site where it discharges into an underground conduit which flows into an UMamed tnbutary of Mill Brook MiD Brook in turn flows into the Raritan River approximately four miles downstream of the site Both the unnamed tnbutary and Mill Brook run through residential areas The residents near these tnbutaries and the residents directly surrounding the site all obtain potable water from a public water supply system located approximately eight miles from the site

Geology

Based on drilling logs from investigations of the site and neighboring properties the geology consists of the following four stratigraphic units

bull Fill- Fill materials comprise the upper 2 to 12 feet of unconsolidated materials and are predominantly composed ofmedium to coarse sand with subordinate amounts ofgrave~ silt and clay and minor amounts ofdebris

bull Fluvio-glacial deposits - Beneath the fill materials are 2 to 35 feet ofgravels silts and clays bull Weathered bedrock (or saprolite) - Underlying the fluvio-glacial deposits are 4 to 45 feet of

red clays and silts with lesser amounts ofsand and gravel This geologic unit appears to function as a semi-confining barrier to vertical groundwater flow and is a weathering product of the underlying bedrock

bull Bedrock - The Brunswick Formation (red shale) occurs anywhere from 15 to 65 feet below grade

The unconsolidated stratigraphy is heterogenous and discontinuous within the area studied Clay content increases as the contact with bedrock is approached and the clay appears to grade into weathered bedrock

9

Hydrogeology

Hydrogeologically the subsurface is best viewed as two water-bearing units - an unconfined overburden zone and a partially confined fractured bedrock water-bearing zone - separated by a leaky confining layer (the saprolite)

The overburden material and weathered bedrock (or saprolite) within the site area comprise a single water-bearing unit although the weathered bedrock could be considered a leaky confining zone and may locally comprise a water-bearing unit The saprolite acts as a semi-confining layer and for all practical purposes is not considered an aquifer but rather an aquitard

Groundwater within the overburden aquifer has been encountered anywhere from 4 to 23 feet below grade throughout the area Generally the overall groundwater flow in the overburden aquifer is to the southeast with flow directly from the CIC site itselfhaving a localized northeast flow direction (towards Interstate 287)

Overall groundwater flow within the shallow (20 to 50 feet) bedrock (due in part to more closely spaced fracture spacing) mimics the flow direction within the overburden aquifer Groundwater flow within the deeper bedrock is controlled by fracture hydraulics and is expected to behave more consistent with regional hydraulic flow which is generally to the southeast However in the northern portion of the CIC site flow is influenced by lower topography along Interstate 287 creating localized flow to the northeast

Land and Resource Use

CIC owned and operated the site from 1954 to 1970 The site was used for the formulating o~

and possibly the manufacturing ot insecticides fungicides rodenticides and herbicides These formulating activities combined with poor housekeeping led to widespread chemical contamination at the site as well as migration ofcontaminants to off-site areas

The site is currently zoned for light industrial use and is expected to remain so into the future The site is currently surrounded by industrial commercial and residential land uses In evaluating potential risks posed by the site EPA considered the possibility of future light-industrial recreational development

On September 222008 the CIC property portion ofthe site was purchased by the Township of Edison This property is expected to be used for recreational purposesopen space The groundwater aquifer underlying the site is classified as a Class IIA groundwater aquifer (potable water source) by the State of New Jersey however is not used for potable purposes in the vicinity of the site

History ofContamination

As previously stated the site was used in the fonnulating and manufacturing of insecticides fungicides rodenticides and herbicides It is believed that these fonnulating activities along with

10

reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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28

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concentration (ugL)

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I Introduction

The purpose of the five-year review is to detennine whether the remedies at a site are protective ofhuman health and the environment The methods findings and conclusions of reviews are documented in Five-Year Review reports In addition Five-Year Review reports identity issues found during the review ifany and identity recommendations to address them

This review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) as amended 42 USC Section 9601 et seq and 40 CFR 3oo430(f)(4)(ii) and in accordance with the Comprehensive Five-Year Review Guidance OSWER Directive 93557-03B-P (June 2001)

Tbe US Environmental Protection Agency (EPA) Region 2 conducted this five-year review of the remedies implemented at the Chemical Insecticide Corporation (CIC) Superfund site in Edison Township New Jersey This five-year review was conducted by Mark Austin Remedial Project Manager (RPM) This report documents the results of the review

This is the third five-year review for the CIC site The triggering action for this statutory review was the initiation of the first remedial action in September of 1990 A five-year review is required due to the fact that hazardous substances pollutants or contaminants remain at the site above levels that aUow for unlimited use and unrestricted exposure

The first five-year review for the site was completed in June 1998 In December 2003 EPA conducted a second five-year review which included several site visits by the EPA RPM in addition to a review ofdocuments data and available infonnation The purpose of the second five-year review was to examine whether the interim remedy under OU I at the site and the offshysite remedy under OU3 was protective of human health and the environment OU2 and OU4 were not completed at that time The 2003 five-year review detennined that the implemented remedies provided adequate protection of public health and the environment

This site (see Figure I) was addressed under four operable units (OUs) OUI was an interim remedy to control contaminated runoff from the site based on a Record of Decision (ROD) issued on September 29 1989 OU3 was a final remedy to address contaminated soil and sediment in off-site creek areas based upon a ROD issued on March 28 1995 OU2 was the final remedy for surface and subsurface soils at the site based upon a ROD issued on September 29 2000 OU4 was the final remedy addressing the contaminated groundwater based upon a ROD issued December 22 2003

To date OU I OU2 and OU3 have been completed The groundwater remedy (OU4) which is currently being implemented includes restricting the installation ofwells restricting the use of groundwater in the area ofgroundwater contamination and conducting a long-tenn groundwater sampling program to monitor the nature and extent of contamination and assess the migration and potential attenuation of the plume over time Because the OUI interim remedy has been superceded by the OU2 final remedy and because the OU3 remedy resulted in conditions that allow for unrestricted use and unlimited exposure for their respective media this and subsequent

7

five-year reviews will specifically consider the OU2 remedy results and the ongoing protectiveness of the OU4 groundwater remedy

ll Site Chronology

Table I below summarizes site-related events

Table I ebronololn of Site Events

EventActivity Date

CIC owned and operated the site for the formulating of and possibly the manufacturing of insecticides fungicides rodenticides 1954-1970 and herbicides

CIC declares bankruptcy The facility is bought by Piscataway 1970

Associates

EPA found extensive contamination on-site and limited off-site 1983

areas

Remedial Investigation (RI) initiated at the site 1987

Operable Unit One (OU I) ROD issued an interim remedy that consisted mainly offence installation capping the site and 91989 constructing a surface water runoff system

Site listed on EPAs National Priorities List (NPL) 81990

Investigations by EPA at off-site locations 1992-1993

OU I Remedy completed 91994

Operable Unit Three (OU3) ROD issued addressing soil and 31995

sediment contamination on off-site areas

OU3 Remedy initiated and completed 41997

First Five-Year Review completed 61998

Operable Unit Two (OU2) ROD issued consisting of the excavation and off-site disposal ofcontaminated soil followed by restoration of 912000 the all affected areas on site

EPA entered into a Settlement Agreement with Piscataway Associates 612001 and Piscatawav Corn landowners and PRP OU2 remedy commenced and OU2 baseline groundwater sampling 2003 event completed bv EPA Both the Second Five-Year Review and Operable Unit Four (OU4) ROD were issued OU4 selecting a groundwater remedy consisting of 122003 a lon(-term groundwater monitorinl Dian and institutional controls

OU2 Remedy completed 512005

OU2 post-remediation groundwater sampling event completed by 2005

EPA

OU4 Remedy initiated with a well inventoryusability survey 2006 cornoJetion

8

OU4 Quarterly groundwater monitoring events being implemented 2007 to present

OU2 Remedial Action Report approved 912007

CIC Property sold to Township of Edison by land owner 912008

III Background

Physical Characteristics

The CIC site (see Figure I) is a fenced 57-acre property located at 135 Whitman Avenue in Edison Township Middlesex County New Jersey It is bounded on the north by Route 287 on the east by a 35-foot wide Public Service Electric and Gas easement and active commercial properties owned by Metroplex and Total TEe on the south by a large warehouse owned by Morris Companies and property once occupied by the former Allied Chemical Company and on the west by a vacant industrial property formerly owned by MuDer Machinery and a COnrailCSX railroad right-of-way The site is currently covered with grass and also contains a rip rap channel and grass-lined swale to manage surface water runoffand drainage

The nearest residential properties are located approximately 300 to 400 yards away from the site and are separated from the site by either Route 287 to the north or the railroad right-of-way to the southwest There are no pennanent surface water bodies on the site After heavy precipitation the surface water runoffdrains toward the northeast comer of the site where it discharges into an underground conduit which flows into an UMamed tnbutary of Mill Brook MiD Brook in turn flows into the Raritan River approximately four miles downstream of the site Both the unnamed tnbutary and Mill Brook run through residential areas The residents near these tnbutaries and the residents directly surrounding the site all obtain potable water from a public water supply system located approximately eight miles from the site

Geology

Based on drilling logs from investigations of the site and neighboring properties the geology consists of the following four stratigraphic units

bull Fill- Fill materials comprise the upper 2 to 12 feet of unconsolidated materials and are predominantly composed ofmedium to coarse sand with subordinate amounts ofgrave~ silt and clay and minor amounts ofdebris

bull Fluvio-glacial deposits - Beneath the fill materials are 2 to 35 feet ofgravels silts and clays bull Weathered bedrock (or saprolite) - Underlying the fluvio-glacial deposits are 4 to 45 feet of

red clays and silts with lesser amounts ofsand and gravel This geologic unit appears to function as a semi-confining barrier to vertical groundwater flow and is a weathering product of the underlying bedrock

bull Bedrock - The Brunswick Formation (red shale) occurs anywhere from 15 to 65 feet below grade

The unconsolidated stratigraphy is heterogenous and discontinuous within the area studied Clay content increases as the contact with bedrock is approached and the clay appears to grade into weathered bedrock

9

Hydrogeology

Hydrogeologically the subsurface is best viewed as two water-bearing units - an unconfined overburden zone and a partially confined fractured bedrock water-bearing zone - separated by a leaky confining layer (the saprolite)

The overburden material and weathered bedrock (or saprolite) within the site area comprise a single water-bearing unit although the weathered bedrock could be considered a leaky confining zone and may locally comprise a water-bearing unit The saprolite acts as a semi-confining layer and for all practical purposes is not considered an aquifer but rather an aquitard

Groundwater within the overburden aquifer has been encountered anywhere from 4 to 23 feet below grade throughout the area Generally the overall groundwater flow in the overburden aquifer is to the southeast with flow directly from the CIC site itselfhaving a localized northeast flow direction (towards Interstate 287)

Overall groundwater flow within the shallow (20 to 50 feet) bedrock (due in part to more closely spaced fracture spacing) mimics the flow direction within the overburden aquifer Groundwater flow within the deeper bedrock is controlled by fracture hydraulics and is expected to behave more consistent with regional hydraulic flow which is generally to the southeast However in the northern portion of the CIC site flow is influenced by lower topography along Interstate 287 creating localized flow to the northeast

Land and Resource Use

CIC owned and operated the site from 1954 to 1970 The site was used for the formulating o~

and possibly the manufacturing ot insecticides fungicides rodenticides and herbicides These formulating activities combined with poor housekeeping led to widespread chemical contamination at the site as well as migration ofcontaminants to off-site areas

The site is currently zoned for light industrial use and is expected to remain so into the future The site is currently surrounded by industrial commercial and residential land uses In evaluating potential risks posed by the site EPA considered the possibility of future light-industrial recreational development

On September 222008 the CIC property portion ofthe site was purchased by the Township of Edison This property is expected to be used for recreational purposesopen space The groundwater aquifer underlying the site is classified as a Class IIA groundwater aquifer (potable water source) by the State of New Jersey however is not used for potable purposes in the vicinity of the site

History ofContamination

As previously stated the site was used in the fonnulating and manufacturing of insecticides fungicides rodenticides and herbicides It is believed that these fonnulating activities along with

10

reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

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five-year reviews will specifically consider the OU2 remedy results and the ongoing protectiveness of the OU4 groundwater remedy

ll Site Chronology

Table I below summarizes site-related events

Table I ebronololn of Site Events

EventActivity Date

CIC owned and operated the site for the formulating of and possibly the manufacturing of insecticides fungicides rodenticides 1954-1970 and herbicides

CIC declares bankruptcy The facility is bought by Piscataway 1970

Associates

EPA found extensive contamination on-site and limited off-site 1983

areas

Remedial Investigation (RI) initiated at the site 1987

Operable Unit One (OU I) ROD issued an interim remedy that consisted mainly offence installation capping the site and 91989 constructing a surface water runoff system

Site listed on EPAs National Priorities List (NPL) 81990

Investigations by EPA at off-site locations 1992-1993

OU I Remedy completed 91994

Operable Unit Three (OU3) ROD issued addressing soil and 31995

sediment contamination on off-site areas

OU3 Remedy initiated and completed 41997

First Five-Year Review completed 61998

Operable Unit Two (OU2) ROD issued consisting of the excavation and off-site disposal ofcontaminated soil followed by restoration of 912000 the all affected areas on site

EPA entered into a Settlement Agreement with Piscataway Associates 612001 and Piscatawav Corn landowners and PRP OU2 remedy commenced and OU2 baseline groundwater sampling 2003 event completed bv EPA Both the Second Five-Year Review and Operable Unit Four (OU4) ROD were issued OU4 selecting a groundwater remedy consisting of 122003 a lon(-term groundwater monitorinl Dian and institutional controls

OU2 Remedy completed 512005

OU2 post-remediation groundwater sampling event completed by 2005

EPA

OU4 Remedy initiated with a well inventoryusability survey 2006 cornoJetion

8

OU4 Quarterly groundwater monitoring events being implemented 2007 to present

OU2 Remedial Action Report approved 912007

CIC Property sold to Township of Edison by land owner 912008

III Background

Physical Characteristics

The CIC site (see Figure I) is a fenced 57-acre property located at 135 Whitman Avenue in Edison Township Middlesex County New Jersey It is bounded on the north by Route 287 on the east by a 35-foot wide Public Service Electric and Gas easement and active commercial properties owned by Metroplex and Total TEe on the south by a large warehouse owned by Morris Companies and property once occupied by the former Allied Chemical Company and on the west by a vacant industrial property formerly owned by MuDer Machinery and a COnrailCSX railroad right-of-way The site is currently covered with grass and also contains a rip rap channel and grass-lined swale to manage surface water runoffand drainage

The nearest residential properties are located approximately 300 to 400 yards away from the site and are separated from the site by either Route 287 to the north or the railroad right-of-way to the southwest There are no pennanent surface water bodies on the site After heavy precipitation the surface water runoffdrains toward the northeast comer of the site where it discharges into an underground conduit which flows into an UMamed tnbutary of Mill Brook MiD Brook in turn flows into the Raritan River approximately four miles downstream of the site Both the unnamed tnbutary and Mill Brook run through residential areas The residents near these tnbutaries and the residents directly surrounding the site all obtain potable water from a public water supply system located approximately eight miles from the site

Geology

Based on drilling logs from investigations of the site and neighboring properties the geology consists of the following four stratigraphic units

bull Fill- Fill materials comprise the upper 2 to 12 feet of unconsolidated materials and are predominantly composed ofmedium to coarse sand with subordinate amounts ofgrave~ silt and clay and minor amounts ofdebris

bull Fluvio-glacial deposits - Beneath the fill materials are 2 to 35 feet ofgravels silts and clays bull Weathered bedrock (or saprolite) - Underlying the fluvio-glacial deposits are 4 to 45 feet of

red clays and silts with lesser amounts ofsand and gravel This geologic unit appears to function as a semi-confining barrier to vertical groundwater flow and is a weathering product of the underlying bedrock

bull Bedrock - The Brunswick Formation (red shale) occurs anywhere from 15 to 65 feet below grade

The unconsolidated stratigraphy is heterogenous and discontinuous within the area studied Clay content increases as the contact with bedrock is approached and the clay appears to grade into weathered bedrock

9

Hydrogeology

Hydrogeologically the subsurface is best viewed as two water-bearing units - an unconfined overburden zone and a partially confined fractured bedrock water-bearing zone - separated by a leaky confining layer (the saprolite)

The overburden material and weathered bedrock (or saprolite) within the site area comprise a single water-bearing unit although the weathered bedrock could be considered a leaky confining zone and may locally comprise a water-bearing unit The saprolite acts as a semi-confining layer and for all practical purposes is not considered an aquifer but rather an aquitard

Groundwater within the overburden aquifer has been encountered anywhere from 4 to 23 feet below grade throughout the area Generally the overall groundwater flow in the overburden aquifer is to the southeast with flow directly from the CIC site itselfhaving a localized northeast flow direction (towards Interstate 287)

Overall groundwater flow within the shallow (20 to 50 feet) bedrock (due in part to more closely spaced fracture spacing) mimics the flow direction within the overburden aquifer Groundwater flow within the deeper bedrock is controlled by fracture hydraulics and is expected to behave more consistent with regional hydraulic flow which is generally to the southeast However in the northern portion of the CIC site flow is influenced by lower topography along Interstate 287 creating localized flow to the northeast

Land and Resource Use

CIC owned and operated the site from 1954 to 1970 The site was used for the formulating o~

and possibly the manufacturing ot insecticides fungicides rodenticides and herbicides These formulating activities combined with poor housekeeping led to widespread chemical contamination at the site as well as migration ofcontaminants to off-site areas

The site is currently zoned for light industrial use and is expected to remain so into the future The site is currently surrounded by industrial commercial and residential land uses In evaluating potential risks posed by the site EPA considered the possibility of future light-industrial recreational development

On September 222008 the CIC property portion ofthe site was purchased by the Township of Edison This property is expected to be used for recreational purposesopen space The groundwater aquifer underlying the site is classified as a Class IIA groundwater aquifer (potable water source) by the State of New Jersey however is not used for potable purposes in the vicinity of the site

History ofContamination

As previously stated the site was used in the fonnulating and manufacturing of insecticides fungicides rodenticides and herbicides It is believed that these fonnulating activities along with

10

reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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Dinoseb bull well BF-2

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28

ug1

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Jul-9S

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Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

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Jul-QS

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Jul-Q7

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concentration (ugL)

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OU4 Quarterly groundwater monitoring events being implemented 2007 to present

OU2 Remedial Action Report approved 912007

CIC Property sold to Township of Edison by land owner 912008

III Background

Physical Characteristics

The CIC site (see Figure I) is a fenced 57-acre property located at 135 Whitman Avenue in Edison Township Middlesex County New Jersey It is bounded on the north by Route 287 on the east by a 35-foot wide Public Service Electric and Gas easement and active commercial properties owned by Metroplex and Total TEe on the south by a large warehouse owned by Morris Companies and property once occupied by the former Allied Chemical Company and on the west by a vacant industrial property formerly owned by MuDer Machinery and a COnrailCSX railroad right-of-way The site is currently covered with grass and also contains a rip rap channel and grass-lined swale to manage surface water runoffand drainage

The nearest residential properties are located approximately 300 to 400 yards away from the site and are separated from the site by either Route 287 to the north or the railroad right-of-way to the southwest There are no pennanent surface water bodies on the site After heavy precipitation the surface water runoffdrains toward the northeast comer of the site where it discharges into an underground conduit which flows into an UMamed tnbutary of Mill Brook MiD Brook in turn flows into the Raritan River approximately four miles downstream of the site Both the unnamed tnbutary and Mill Brook run through residential areas The residents near these tnbutaries and the residents directly surrounding the site all obtain potable water from a public water supply system located approximately eight miles from the site

Geology

Based on drilling logs from investigations of the site and neighboring properties the geology consists of the following four stratigraphic units

bull Fill- Fill materials comprise the upper 2 to 12 feet of unconsolidated materials and are predominantly composed ofmedium to coarse sand with subordinate amounts ofgrave~ silt and clay and minor amounts ofdebris

bull Fluvio-glacial deposits - Beneath the fill materials are 2 to 35 feet ofgravels silts and clays bull Weathered bedrock (or saprolite) - Underlying the fluvio-glacial deposits are 4 to 45 feet of

red clays and silts with lesser amounts ofsand and gravel This geologic unit appears to function as a semi-confining barrier to vertical groundwater flow and is a weathering product of the underlying bedrock

bull Bedrock - The Brunswick Formation (red shale) occurs anywhere from 15 to 65 feet below grade

The unconsolidated stratigraphy is heterogenous and discontinuous within the area studied Clay content increases as the contact with bedrock is approached and the clay appears to grade into weathered bedrock

9

Hydrogeology

Hydrogeologically the subsurface is best viewed as two water-bearing units - an unconfined overburden zone and a partially confined fractured bedrock water-bearing zone - separated by a leaky confining layer (the saprolite)

The overburden material and weathered bedrock (or saprolite) within the site area comprise a single water-bearing unit although the weathered bedrock could be considered a leaky confining zone and may locally comprise a water-bearing unit The saprolite acts as a semi-confining layer and for all practical purposes is not considered an aquifer but rather an aquitard

Groundwater within the overburden aquifer has been encountered anywhere from 4 to 23 feet below grade throughout the area Generally the overall groundwater flow in the overburden aquifer is to the southeast with flow directly from the CIC site itselfhaving a localized northeast flow direction (towards Interstate 287)

Overall groundwater flow within the shallow (20 to 50 feet) bedrock (due in part to more closely spaced fracture spacing) mimics the flow direction within the overburden aquifer Groundwater flow within the deeper bedrock is controlled by fracture hydraulics and is expected to behave more consistent with regional hydraulic flow which is generally to the southeast However in the northern portion of the CIC site flow is influenced by lower topography along Interstate 287 creating localized flow to the northeast

Land and Resource Use

CIC owned and operated the site from 1954 to 1970 The site was used for the formulating o~

and possibly the manufacturing ot insecticides fungicides rodenticides and herbicides These formulating activities combined with poor housekeeping led to widespread chemical contamination at the site as well as migration ofcontaminants to off-site areas

The site is currently zoned for light industrial use and is expected to remain so into the future The site is currently surrounded by industrial commercial and residential land uses In evaluating potential risks posed by the site EPA considered the possibility of future light-industrial recreational development

On September 222008 the CIC property portion ofthe site was purchased by the Township of Edison This property is expected to be used for recreational purposesopen space The groundwater aquifer underlying the site is classified as a Class IIA groundwater aquifer (potable water source) by the State of New Jersey however is not used for potable purposes in the vicinity of the site

History ofContamination

As previously stated the site was used in the fonnulating and manufacturing of insecticides fungicides rodenticides and herbicides It is believed that these fonnulating activities along with

10

reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

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Hydrogeology

Hydrogeologically the subsurface is best viewed as two water-bearing units - an unconfined overburden zone and a partially confined fractured bedrock water-bearing zone - separated by a leaky confining layer (the saprolite)

The overburden material and weathered bedrock (or saprolite) within the site area comprise a single water-bearing unit although the weathered bedrock could be considered a leaky confining zone and may locally comprise a water-bearing unit The saprolite acts as a semi-confining layer and for all practical purposes is not considered an aquifer but rather an aquitard

Groundwater within the overburden aquifer has been encountered anywhere from 4 to 23 feet below grade throughout the area Generally the overall groundwater flow in the overburden aquifer is to the southeast with flow directly from the CIC site itselfhaving a localized northeast flow direction (towards Interstate 287)

Overall groundwater flow within the shallow (20 to 50 feet) bedrock (due in part to more closely spaced fracture spacing) mimics the flow direction within the overburden aquifer Groundwater flow within the deeper bedrock is controlled by fracture hydraulics and is expected to behave more consistent with regional hydraulic flow which is generally to the southeast However in the northern portion of the CIC site flow is influenced by lower topography along Interstate 287 creating localized flow to the northeast

Land and Resource Use

CIC owned and operated the site from 1954 to 1970 The site was used for the formulating o~

and possibly the manufacturing ot insecticides fungicides rodenticides and herbicides These formulating activities combined with poor housekeeping led to widespread chemical contamination at the site as well as migration ofcontaminants to off-site areas

The site is currently zoned for light industrial use and is expected to remain so into the future The site is currently surrounded by industrial commercial and residential land uses In evaluating potential risks posed by the site EPA considered the possibility of future light-industrial recreational development

On September 222008 the CIC property portion ofthe site was purchased by the Township of Edison This property is expected to be used for recreational purposesopen space The groundwater aquifer underlying the site is classified as a Class IIA groundwater aquifer (potable water source) by the State of New Jersey however is not used for potable purposes in the vicinity of the site

History ofContamination

As previously stated the site was used in the fonnulating and manufacturing of insecticides fungicides rodenticides and herbicides It is believed that these fonnulating activities along with

10

reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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reckless waste and wastewater disposa~ led to widespread chemical contamination on the site as well as migration of contaminants to off-site areas At one time the property consisted of approximately seven buildings used for the formulationstorage ofpesticides and herbicides Additionally lagoons existed along the eastern property boundary and were reportedly used to hold some of the facilitys wastewater

In the mid-l 960s the Edison Department of Health and Human Resources became concerned about activity on the site due to numerous neighborhood complaints ofodors off-site discharges and releases and the frequency ofon-site fires In June 1966 the Edison Township Health Officer ordered the facility to stop discharging wastewater oversaw disposal ofleaking drums to eliminate an odor problem and ordered the closing ofthe onmiddotsite lagoons On August 10 1970 CIC declared bankruptcy

Initial Response

In 1983 the fonner CIC facility was included in an EPAlNew Jersey Department of Environmental Protection (NJDEP) dioxin-screening program that identified and sampled potential dioxin-contaminated sites Sampling revealed low-level dioxin contamination in some of the fonner process areas while results from neighboring properties did not show any evidence of dioxin contamination More notably while conducting the sampling at the site EPA also collected additional samples for other commonly found pollutants Data indicated widespread arsenic pesticide and herbicide contamination on the site and limited contamination off the site

Based on the results of the earlier investigations EPA initiated a Remedial Investigation and Feasibility Study (RIlFS) at the site in July 1987 Concurrent with the RIlFS EPA conducted several removal actions to mitigate risks associated with contaminated soil and surface water runoff from the site In September 1989 EPA issued a ROD for OUI selecting an interim remedial action to control surface water runoff installing a fence for security and covering the site with a high-density polyethylene surficial cap

In August 1990 EPA included the CIC site on the National Priorities List (NPL)

IV Remedial Actions

Remedy Selection and Implementation

OUI - In September 1989 EPA issued a ROD for OU I selecting an interim remedial action to control runoff from the site The primary objective of the remedy was to stabilize the site until final remedies could be selected and implemented at the site The remedy consisted of installing a fence around the site clearing and grading covering the site with a high-density polyethylene surficial goo-cap and constructing a surface water runoffdiversion system to collect uncontaminated surface water runoff from the cap and channel it to a drainage system Construction of the interim remedy was completed in September 1994

OUJ - In March 1995 EPA issued a ROD for OU3 selecting a remedy to address arsenicshycontaminated soil and sediment identified in off-site creek areas The remedial action objectives

1I

ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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date

28

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Jan-Q2 N CD

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Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

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concentration (ugL)

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ofthe OU3 remedy were to prevent direct contact with the contaminated sediment that posed unacceptable exposure risk to residential receptors This remedy included excavation transportation and off-site disposal ofcontaminated soil and sediment containing arsenic in excess of20 parts per million (ppm) followed by restoration ofoff-site areas stream beds and wetlands This remedy initiated in June 1996 resulted in the excavation and off-site disposal of 13BOO cubic yards ofarsenic-contaminated soil and sediment The OU3 remedy was completed in April 1997 Subsequent post-remediation monitoring showed that the cleanup goals were achieved and the disturbed creek areas have been restored The OU3 remedy remediated the offshysite creek areas to a level that aUows for unrestricted useunlimited exposure

OU2 - An OU2 ROD in September of2000 specified that contaminated surface and subsurface soils on the site were to be excavated and disposed of at appropriate off-site landfills Restoration would follow on all affected areas The OU2 objectives were to reduce or eliminate the direct contact pathway for human exposure and address the source ofcurrent and future groundwater contamination Field activities for the OU2 remedy activities began in May 2003 By May 2005 approximately 241 000 cubic yards ofcontaminated soil had been removed and transported off site The OU2 remedy addressed contaminated soils found on all areas of the fonner CIC facility in addition the remedy removed soils on JXgtrtions of the neighboring Metroplex MorrisAllied and Muller properties that were contaminated as a result ofCICs operations To address the remedial objectives the depths ofexcavation varied from the first two feet ofsoils to as deep as the saprolitelbedrock surface approximately 20 feet below ground surface The deeper excavations removed soils considered to be sources ofgroundwater contamination While a variety of contaminant-specific remediation goals were established in the OU2 ROD the extent of the excavation was primarily defined by the extent ofarsenic contamination The arsenic remediation goa~ 20 ppm addressed both direct contact risks and a continuing groundwater source After completion of the soil excavation the site was backfilled to grade with clean soil and restored with natural vegetation

During the OU2 remedy implementation in 2003 it was unclear at the time whether the OU2 remedy would result in conditions that require restricted use or whether unrestrictive use conditions would be achieved Since the remedy comprised of a large-scale excavation and the remediation goal selected for arsenic was 20 ppm a goal that was used for both commercial property (restricted use) cleanups and for unrestricted use cleanups the uncertainty did not derive from arsenic but from uncertainties about any remaining contamination from other known siteshyrelated pesticides such as DDT The OU2 remedy allowed DDT and other contaminants that did not pose a threat to groundwater to remain in deeper soils After completing the OU2 remedy a review of the post-excavation sampling results confirmed that all other identified site contaminants had been removed along with the deeper arsenic contamination Hence no elevated site contaminants had been left behind that would limit future site uses With these results the implementation of the OU2 ROD institutional controls requirement (placement ofdeed notices on the CIC site where restricted use is warranted) is currently under EPA review Ifit is detennined that the deed notices are not necessary EPA will issue an Explanation of Significant Differences (ESD) By approving an ESO both institutional controls and future five-year reviews would not be required for the OU2 remedy

12

The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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The OU2 remedy addressed soil contamination on the neighboring Muller Machinery property that derived from CICs operations as evidenced by arsenic and other pesticide contamination EPA and NJDEP determined that the Muller Machinery operations had independently contaminated portions of that property with lead and that this lead contamination would not be addressed by the CIC remedy After completing the OU2 remedy EPA documented this remnant lead contamination and transferred jurisdiction for Muller Machinery back to NJDEP The property is not occupied and has been abandoned by Muller NJDEP plans to work with a future owner to address the remaining lead contamination prior to reuse of this property

OU4 - In December 2003 EPA issued a ROD for OU4 selecting a remedy to address groundwater contamination directly associated with the site The affected aquifer is identified as Class I~ a current or potential source ofdrinking water However groundwater under the site is not currently used for drinking water nor is it anticipated that it would be used as a drinking water source in the future The original remedial objective of the OU4 remedy was to restore the groundwater to potable use however EPA concluded that the presence ofhighly elevated arsenic pesticide and herbicide contamination in the fractured bedrock formation would be technically impracticable to address to a degree that would allow the groundwater to be restored to potable use Addressing the soil contamination (OU2) was expected to substantially improve the conditions in the shallow and bedrock groundwater The shallow groundwater is expected to recover somewhat but the contamination was determined to be technically impracticable to remediate in an area of the overburden and bedrock aquifer As part ofthe OU4 remedy a waiver of the drinking water ARAR was established for the entire contaminated groundwater plume involving both aquifers The waiver referred to as a technically impracticable (TI) waiver consists ofa surface area of approximately 50 acres in size and extends from the elC site on a portion ofthe Metroplex property and under Route 287

VOCs detected on neighboring properties to the southeast were detennined to be not site-related and therefore were not addressed by the OU4 remedy

The remedy consists ofa long-term groundwater monitoring plan encompassing a sampling and analysis program to monitor the nature and extent of groundwater contamination in the overburden and bedrock at the site The results of the program are designed to assess the contaminated groundwater plume over time and assure that the plume does not migrate to detennine whether the conditions that led to the TI waiver are still valid and to monitor improvements in overall groundwater quality that may have resulted from the OU2 source removal In addition the remedy requires the implementation of institutional controls in the form ofa NJDEP-administered Classification Exception Area (CEA) to restrict the installation ofwells and use ofgroundwater in an area ofgrowtdwater contamination that includes the site and areas nearby covering approximately 50 acres The groundwater monitoring efforts to satisfY the 2003 ROD requirements were initiated in November of2006 and are ongoing

v Progress since the last review

The second five-year review for the site which was completed in December 2003 noted that the interim remedy for OUI was performed in accordance with the 1989 ROD the final remedy for OU3 was performed consistent with the t 995 ROD and that the remedy for OU2 was underway

t3

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

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311104

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311106

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91100

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31107

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FIGURE 4

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FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

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date

28

ug1

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Jul-99

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Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

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Jul-Q7

Jan-QS

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concentration (ugL)

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Aug-99

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bullFelHl8

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-Cl lt 1l

Since the completion ofthe second five-year review the site has remained secure The OU2 ROD has been fully implemented A remedial action report has been completed and was approved by EPA on September 28 2007 The cleanup ofOU2 is protective and has restored the area to light industrialrecreational use In addition the CIC property portion ofthe site was purchased by the Township of Edison (September 22 2008) The Township of Edison plans to re-use the purchased parcel in an undetennined recreational capacity or as open space

As the final remedy for the site OU4 ROD which addresses site-related contaminated groundwater is currently being implemented Initial work efforts for OU4 which focused on compiling and reviewing existing information and data for the site and surrounding properties began in November 2006 From this evaluation EPA set the following goals to satisfY the OU4 ROD

bull Evaluate existing data gaps with respect to the delineation ofthe current plume of groundwater contamination and how those data gaps will be addressed

bull Establish a long-term monitoring (LTM) well network and sampling program so that sufficient monitoring data can be collected to assess groundwater contaminant levels and plume migration over time and

bull Establish a CEA for the CIC site to meet NJDEP requirements

Currently the project is in the LTM phase designed to roonitor the nature and extent of contamination and assess the migration and potential attenuation ofthe plume In addition data for the CEA is being compiled As ofthe writing ofthis five-year review five quarterly LTM events have been conducted (JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008) The purpose of these quarterly LTM events is to collect groundwater samples from the site LTM well network (involving 25 wells) in order to monitor contaminant concentrations and the affects ifany ofthe completion ofthe OU2 remedy The results ofthese events can be found below in Section VI

VI Five-Year Review Process

Administrative Components

At the CIC site the first five-year review dated June 1998 detennined that the remedies selected and implemented (OUI and OU3) for the site remained protective ofhuman health and the environment

In December 2003 EPA conducted a second five-year review which included site inspections reviews ofdocuments data and all available information The 2003 five-year review also determined that the implemented remedies for au 1 and OU3 continued to provide adequate protection of public health and the environment

For this five-year review the review team consisted of Mark Austin (EPA - RPM) Robert Alvey (EPA - Hydrogeologist) Lora Smith (EPA - Human Health Risk Assessor) Mindy

14

Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

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Pensak (EPA - Ecological Risk Assessor) and Craig Wallace (NJDEP - Program Manager) Community Involvement

EPA published a notice in the Edison-Metuchen Sentinel a local newspaper on December 10 2008 notifYing the community of the five year review process The notice indicated that EPA was in the process ofconducting a five-year review of the remedies for the site to ensure that the implemented remedies remain protective of public health and the environment and are functioning as designed It also indicated that upon completion of the five-year review results of the review would be made available at the designated site repositories In addition the notice included the RPMs address and telephone number for questions related to the five-year review process or the eIC site The EPA RPM was not caUed by any members of the community regarding this fiveshyyear reVIew

EPA has made all site-related documents available to the public in the administrative record repositories maintained at the EPA Region II office (290 Broadway New York New York 10007) the Edison Library (340 Plainfield Avenue Edison New Jersey 08817) and the Metuchen Library (480 Middlesex Avenue Metuchen New Jersey 08840)

Document Review

This five-year review consisted of a review of relevant documents including monitoring data (See Attachment B for a list of documents reviewed)

Data Review

Since OU I OU2 and OU3 are completed and no new data exists for these actions the OU4 (groundwater) sampling data was reviewed As previously mentioned in Section V five quarterly LTM events were conducted in JulyAugust 2007 December 2007 March 2008 June 2008 and September 2008 With the results of these events the following conclusions can be made

bull Groundwater in the overburden and bedrock aquifers is contaminated at the site with the principal sources being contaminated soil and source materials (all ofwhich have been removed as part of the OU2 remedy) Historic routes ofsurface water drainage from the CIC site are now controlled

bull Based on the data collected from 2003 to date constituents ofconcern include metals (specifically arsenic) BHC pesticides (specifically alpha-BHC) and herbicides (specifically dinoseb) and to a lesser extent VOCs (benzene and chlorinated solvents)

bull Generally the widest variety of contaminants has been detected in the overburden monitoring wells along the eastern boundary ofthe CIC site (proximity offormer lagoons) and in the deeper overburden and bedrock wells in the northeastern portion of the site (where bedrock was encountered at a shallower depth than in other portions of the CIC site)

15

bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

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bull There is also contamination in the southern portion of the CIC site within the deeper overburden and bedrock aquifers that appears to be specifically related to historic elevated concentrations ofherbicid~ in this area

bull Sporadic contamination has also been identified to the east of the CIC site (ie Metroplex and Total TEC portion of the CIC Study Area) which is indicative ofhistoric surface water drainage patterns

bull Elevated levels of trichloroethylene (TCE) have been detected at monitoring well BFshy5 located east of the Metroplex building area over 1000 feet east of the CIC property boundary (Figure I) Concentrations ofTCE were detected at 1800 micrograms per liter (ugll) in samples collected in 1998 and September 2008 and have been fairly consistent throughout the sampling period A review of the analytical results for TCE from all other monitoring wells at the site do not show similar levels Therefore TCE is not considered to be a CIC site-related contaminant

bull There were some notable decreas~ in concentrations from 2003 to 2008 which is an indication that the OU2 soil remedial action is continuing to have a beneficial effect on groundwater concentrations (Figures 2 through 7) For instance

- In most cases detected concentrations of pesticides in groundwater have remained at low levels since the aU2 soil remedial action was completed indicative ofa stable area ofgroundwater impact (Pesticide concentrations appear to be highest in the northeast comer and along the eastern CIC property boundary) Overall the trend is stable to decreasing At monitoring well BF-2 sampling results showed the largest decrease in groundwater concentrations of alpha - BHC subsequent to the OU2 soil remedial action (Figure 2) - Based on historical information on soil contamination from herbicides significant levels ofDinoseb were identified in the southern JXgtr1ion of the CIC site Groundwater sampling results from monitoring wells QD and BF-2 show a decrease in detected concentrations subsequent to the completion of the OU2 remedial action (Figures 3 and 4) - The concentration of arsenic in bedrock monitoring well BF-2 decreased dramatically from 2003 to 2008 from 12700 ugll to 760 ugll For wells where low levels ofarsenic were historically detected such as monitoring well UU a downward trend is also observed though the trend in the data is less definitive (Figures 5 and 6) - Groundwater analytical results for VOCs reported concentrations above remediation goals for a number ofconstituents including TCE benzene and vinyl chloride Not all wells were affected and VOC concentrations were primarily located at the northeast comer and along the eastern comer ofthe CIC property boundary A decreasing trend in concentrations was observed for Benzene in monitoring well BF-2 (Figure 7) The concentrations generally decrease moving downgradient across the CIC site

Overan concentrations of arsenic and alpha-BHC are decreasing vacs and herbicides have gradually stabilized and low-level detections of these constituents are attributed to stable plume

16

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

- V ~ ---s ~

0 ~ c

611iU3

I91Al3

1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

bull ~ ~ CD c bull I

~

bull0shy - isect Ol ~~ g

= ~

~ 0 I ~ 0

~

s s

flt1

-~-- f ~ ~

~ I

FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

-Cl lt 1l

conditions It can also be concluded that the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate

Site Inspection

An inspection of the CIC site was conducted on November 24 2008 The following parties were in attendance Mark Austin EPA Region II Project Manager Robert Alvey EPA Region II HydrogeoJogist Lora Smith EPA Region II Human Health Risk Assessor Mindy Pensak EPA Region II Ecologieal Risk Assessor Craig Wallace NJDEP Program Manager and Lisa Tilton EPA Contractor (Obrien amp Gere)

The site inspection consisted ofa physical inspection of the entire remediated property security fencing monitoring wells on-site drainage systems and surrounding off-site areas

The following sections present the resuhs of the site inspection separated into each inspected element

Security Fencing - Upon inspection minor deficiencies were noted regarding the site security fencing One of the sites two gates was unlocked and a few areas in the fencing had noticeable gaps which increases the potential for on-site trespassers (It should be noted that fencing at the site is not needed to maintain the protection ofthe remedies)

Groundwater Monitoring Wells - There are a number ofwells on the site and off-site that are part of the sampling plan No damages were observed All wells were detennined to be in good working order These wells will continue to be inspected throughout the long-tenn monitoring program as needed Ifthere is a need to decommission any wells in the future the appropriate actions will be taken

Surrounding Areas - Nothing out of the ordinary was noted No new construction on neighboring properties or other factors that might change exposure scenarios were identified

On-site Drainage System - The drainage system located in the center and along the northern portion of the site was inspected No blockages or debris were noted and water was flowing through the system New vegetative growth was observed in the surrounding areas

Off-site UMamed Creek Areas - AU four reaches originally remediated were inspected The four reaches each ofwhich had undergone some excavation and restoration in 1997 continued to support old and new vegetation with a significant amount of invasive species present in Reaches I 3 and 4 The vegetation near Reach 2 consisted of mowed lawn and ornamental shrubbery Rip-rap appeared to be in good condition and the creek channel appeared to be stable

Interviews

No interviews were conducted

17

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

- V ~ ---s ~

0 ~ c

611iU3

I91Al3

1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

bull ~ ~ CD c bull I

~

bull0shy - isect Ol ~~ g

= ~

~ 0 I ~ 0

~

s s

flt1

-~-- f ~ ~

~ I

FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

-Cl lt 1l

VII Tecbnical Assessment

Question A Is tbe remedy functioning as intended by tbe decision documents

Yes the remedies for the site are functioning as intended by the decision documents EPA issued four RODs to mitigate contamination at the site The 1989 ROD for OU I controlled contaminated runoff the 1995 ROD for OU3 addressed arsenic-contaminated soils and sediments in and around the off-site Mill Creek the 2000 ROD for OU2 addressed contaminated soils on the CIC property and the 2003 ROD for OU4 selected a remedy for groundwater contamination associated with site activities These remedial activities were necessary in order to attain the remedial action objectives (RAOs) of reducing or eliminating the potential for exposure to contaminated soils at the site reducing or eliminating the potential for exposure to contaminated soilssediments at surrounding properties along an unnamed tnbutary and Mill Creek and minimizing or eliminating the migration of contaminants to groundwater and surface waters

The interim remedy put forth in OUI no longer exists superceded by the OU2 remedy In OU2 and OU3 on- and off-property contaminated soils and off-property contaminated sediments were excavated and disposed ofoffsite at a licensed facility and the control ofsite drainage was reshyestablished as part ofOU2 As a result ofthe removal ofcontaminated soilssediments from the site and the remaining soilssediments remain below cleanup goals the direct contact and inhalation of particulates pathways are incomplete The remedies put forth in the OU2 and OU3 RODs are functioning as intended and meet the selected RAOs

Groundwater is being addressed via institutional controls and the implementation of a long-tenn groundwater sampling program This program is being designed to monitor the nature and extent ofcontamination and assess the migration and to a degree the potential attenuation of contaminated groundwater over time in both the overburden and bedrock aquifers In addition as part of the OU4 ROD a TI waiver was included for the both the overburden and bedrock aquifers The OU4 monitoring program also serves as a way to measure the changes ifany to these aquifers

Historic sampling results from monitoring wells identified exceedances of metals (including arsenic) benzene hexachloride (BHC) pesticides herbicides - primarily dinoseb VOCs including benzene and chlorinated solvents and minor SYOCs Elevated levels ofTCE in excess of I000 ugll have been regularly detected in bedrock Monitoring WeU BF-5 to the east and downgradient of the site however this contamination is not believed to be site-related

As part of the OU4 remedy implementation groundwater samples have been coUected and analyzed for VOCs SVOCs pesticides herbicides and metals

Detections ofVOCs have remained predominately stable except at Monitoring WeD BF-2 where significant decreases were noted Benzene decreased from 110 ugll in 2003 to 41 ugfl in the 4th

quarter of2008 Vinyl chloride decreased from 59 ugll to 84 ugll and PCE decreased from 22 ugl to non-detect

Detections ofSVOCs have be~n at low concentrations with only minor exceedances Analyses for

18

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

- V ~ ---s ~

0 ~ c

611iU3

I91Al3

1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

bull ~ ~ CD c bull I

~

bull0shy - isect Ol ~~ g

= ~

~ 0 I ~ 0

~

s s

flt1

-~-- f ~ ~

~ I

FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

-Cl lt 1l

4-Chloroanaline indicated a decrease in Monitoring Well BF-2 from 680 ugll in 2003 (prior to completion of the OU-2 remedy) to 110 ugll in 2008 SVOCs are not considered significant at this site and are currently being considered for elimination from the COC list since no SVOCs were detected in site soils suggesting a potential off-site source

Analytical results for pesticides between 2003 and present are stable Results from Monitoring Well BF-2 showed significant decreases with alpha-BHC decreasing from 49 ugll in 2003 to 29 ugll in 2008 Concentrations generally decrease moving downgradient and across the site

The herbicide dinoseb had elevated historic detections at the site In genera~ concentrations have decreased since the completion of the OU-l remedy Reported dinoseb levels decreased at Monitoring Well QD from 21 ugll (pre OU-2 completion) to 71 ugll in 2008 Concentrations at Monitoring Well BF-2 decreased from 24 ugll (pre OU-2 completion) to non-detection in 2008

Metals are not a significant source ofcontamination in groundwater and for the most part levels were indicative ofnaturally occurring background levels Elevated concentrations of arsenic in groundwater samples from wells on the site and immediately downgradient of the site are related to past site operations Arsenic levels decreased significantly in Monitoring Well BF-2 from 12700 ugll in 2003 to 760 ugll in the 4 quarter 2008

Overal~ concentrations ofmost COCs initially declined after the removal ofsoil and source material from the site and surrounding properties and have remained relatively stable As previously mentioned the most significant decreases in arsenic alpha-SHC and dinoseb were observed in Monitoring Well BF-2

And finally arsenic remains the most significant site-related contaminant While exceedences of the cleanup goals identified in the OU4 ROD exist in several monitoring wells groundwater concentrations have dramatically declined Well s MW-2S MW-21 MW-2BR GU and BF-4 act as sentinel wells for the surface water creek All contain low levels of site contaminants indicating that migration to the creek from groundwater is not occurring Expectations of the OU4 ROD which presumed that the migration of contaminants to groundwatersurface water from OU2 soils was addressed have shown to be achieved

Question B Are the exposure assumptions toxicity data cleanup levels and remedial action objectives used at the time of the remedy still valid

There have been no physical changes to the site that would adversely affect the protectiveness of the remedies

Land use assumptions exposure assumptions and pathways and RAGs considered in the decision documents for OU2 and OU4 remain valid During the selection for OU2 ecological risks were considered however exposures were addressed based on human health risks By addressing the human health risks all ecological risks were also addressed Although specific parameters may have changed since the time the risk assessment was completed the process that was used remains valid ln addition since the implementation of the OU2 remedy led to the site property being cleaned up to unlimited use standards EPA is reviewing whether or not a deed notice

19

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

- V ~ ---s ~

0 ~ c

611iU3

I91Al3

1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

bull ~ ~ CD c bull I

~

bull0shy - isect Ol ~~ g

= ~

~ 0 I ~ 0

~

s s

flt1

-~-- f ~ ~

~ I

FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

-Cl lt 1l

should be placed upon this property Ifit is determined that the deed notice is not required EPA will issue an ESD By approving an ESD both institutional controls and future five-year reviews would not be required for the OU2 remedy

Similarly since the OU3 remedy which addressed human health risks in lieu ofecological risks resulted in the remediation of the off-site creek areas to levels that allow for unrestricted use the land use assumptions exposure assumptions and pathways and RAOs identified in the decision documents continue to remain valid Also because the OU3 remedy resulted in unrestricted use no institutional controls were anticipated to be necessary

A cleanup goal for arsenic in groundwater was established at 3 uglI This value which represents the New Jersey Groundwater Quality Standard (NJGWQS) is the lowest of the EPA Maximum Contaminant Levels (MCLs) New Jersey MCLs and NJGWQS although a TI waiver exists as part of the OU4 ROD This cleanup goal remains protective of human health However the TI conditions that led to the need for a TI waiver still exist and the TI waiver is still appropriate It is also worth noting that the toxicity ofarsenic is under review with EPAs Office of Research and Development in Integrated Risk Infonnation System (IRIS) When the review is completed the protectiveness of this remedy will be re-assessed In the area of the established TI waiver institutional controls through a CEA will assure that the contaminated groundwater is not used

While VOCs are known groundwater contaminants at the site soil vapor intrusion is not a concern since the property does not have any buildings and after purchase by Edison Township will not be redeveloped with buildings in the future

The surrounding properties are currently zoned as commerciaVlight industrial and residents near the site andor tributaries aU obtain potable water from a public supply water system located approximately eight miles from the CIC site As a result the remedy is protective in the shortshytenn Long-tenn protectiveness will be ensured with the implementation of future deed restrictions or an ESD and CEA

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 (OU2 OU3 and OU4) remedies are functioning as intended by the decision documents

20

VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

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611106

91100

121Mgt6

31107

61107

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91108 bull I

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30

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Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

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Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

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VIII Issues Recommendations and FoUowmiddotup Actions

Table 2 below summarizes site-related issues recommendations and proposed follow-up actions

Table 2 Issue

A CEA part oftheOU4 remedy restricting the installation ofwells and groundwater use in the area of site-related groundwater contamination needs to be established

Recommendations amp Follow-up Actions

CEA is currently being prepared

Party Responsible

NJDEP

Oversight Agency

EPA

Milestone Date

December 2009

Affects Protectiveness

(YIN)

Current Future

N Y

Gaps in the fencing found during the Nov 08 site inspection could allow for trespassing

Gaps in the fencing will be repaired to protect the existing monitoring wells

EPA EPA December 2009

N N

A deed notice for continued use of the property as nonshyresidential (commercialllight industrial) identified in the OU2 ROD has yet to be implemented and is under review

The deed notice requirement as part of OU2 is being reviewed by EPAlfitisdetermined that a deed notice is not necessary EPA will issue an ESD thai will waive both institUlional controls and future five-year review requiremenls under the OU2 remedy

EPN propeny owner

EPA December 2009

Y Y

IX Protectiveness Statement

The remedy under OU2 is protective of human health and the environment through the removal of arsenic pesticide and herbicide-contaminated soils from the site thereby eliminating the possibility ofexposure to these soils

The remedy under OU4 is protective ofhuman health in the short-tenn since the plume is stable and all surrounding industries and businesses are connected to public water In order to be protective in the long-term institutional controls preventing groundwater use need to be implemented

21

X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

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611104

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611106

91100

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61107

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91108 bull I

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FIGURE 4

30

25

20

15~

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5

0

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FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

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FebQ5

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X Next Review

The next Five-Year Review for the Chemica1lnsecticide Corporation Superfund site should be completed by December 2013

Approved

3IOOq Date

22

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

- V ~ ---s ~

0 ~ c

611iU3

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1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

bull ~ ~ CD c bull I

~

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= ~

~ 0 I ~ 0

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FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

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Aug-Q4 C C

FebQ5

AugQS

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Aug-OO

Feb-07

AugQ7

bullFelHl8

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-Cl lt 1l

AlTACHMENT A - LIST OF ACRONYMS

ACO ARARs BHC CEA CERCLA CIC COC EPA ESD FS GWQS IRIS LTM MCL NJDEP NJGWQS NPL OampM OU OUI OU2 OU3 OU4 ppb ppm PRG PRP QAPP RA RAO RD RDIRA RI ROD SVOC TI TCE USACE VOCs

Administrative Consent Order Applicable or Relevant and Appropriate Requirements Benzene Hexachloride Classification Exception Area Comprehensive Environmental Response Compensation and Liability Act Chemical Insecticide Corporation Contaminant ofConcem (United States) Environmental Protection Agency Explanation of Significant Differences Feasibility Study Groundwater Quality Standard Integrated Risk Infonnation System Long-Tenn Monitoring Maximum Contaminant Level New Jersey Department of Environmental Protection New Jersey Groundwater Quality Standard National Priorities list Operation amp Maintenance Operable Unit Operable Unit One Operable Unit Two Operable Unit Three Operable Unit Four Parts Per Billion Parts Per Million Preliminary Remediation Goals Potentially Responsible Party Quality Assurance Project Plan Remedial Action Remedial Action Objective Remedial Design Remedial DesignlRemedial Action Remedial Investigation Record of Decision Semi-volatile organic compound Teclmically Impracticable Trichloroethylene United States Anny Corps of Engineers Volatile Organic Compounds

23

ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

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1211Kl3

311104

611104

I911104 I

121104

31105

611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

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91108 bull I

tiO i 0 ~ ~ bullen~ OlCD

J ltT l 0~ bulll CiE cl

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~

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30

25

20

15~

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5

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FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

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Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

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FebQ5

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Aug-OO

Feb-07

AugQ7

bullFelHl8

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ATIACHMENT B - DOCUMENTS REVIEWED

bull us Envirorunental Protection Agency EPA Superfund Record aDecision Operable Unit One ChemicaInsecticide Corporation Site Edison TOlnship Middlesex County NJ Region 2 New York New York September 1989

bull US Environmental Protection Agency EPA Superfund Record aDecision Operable Unit Three ChemicaInsecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York March 1995

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Tl1XJ Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2000

bull US Environmental Protection Agency EPA Superfund Record ofDecision Operable Unit Four Chemical Insecticide Corporation Site Edison Township Middlesex County NJ Region 2 New York New York September 2003

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TO1TlShip Middlesex County NJ Region 2 New York New York June 1998

bull US Environmental Protection Agency EPA Five-Year Review Chemical Insecticide Corporation Site Edison TOrVnShip Middlesex County NJ Region 2 New York New York December 2003

bull US Army Corp of Engineers Remedial Action Report Chemical Insecticide Corporation Superfund Site Operable Unit 2 - Soil Remediation Edison NJ September 2007

bull US Army Corp of Engineers Additional Groundwater Investigation Report and 112rwJ

Quarter Long-Term Monitoring Events Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOKnship Middlesex County NJ May 2008

bull US Army Corp of Engineers 3rd Quarter Long-Term Monitoring Event Report Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundwater Edison Township Middlesex County NJ June 2008

bull US Anny Corp of Engineers Annual Report Long-Term Monitoring Program- Year I Chemical Insecticide Corporation Superfund Site Operable Unit 4 - Groundlmter Edison TOK-nship Middlesex County NJ October 2008

24

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

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311104

611104

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121104

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611iUS

911JD5

1211Kl5

311106

611106

91100

121Mgt6

31107

61107

91107

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30

25

20

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10

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Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

-Cl lt 1l

FIGURES

25

US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

GIG Sile Site Drainage and Monitoring Wells

~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

alpha-BHe ugl ug1

0 o- - tol ~

~ ~ ~ N W W ~ ~ gt o ~ 0 ~ 0 ~ 0 ~ 0 ~I e ~

V 0

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611iU3

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911JD5

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611106

91100

121Mgt6

31107

61107

91107

121107

31MlB

6111Q8 bull I I

91108 bull I

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bull ~ ~ CD c bull I

~

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FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

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Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

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FelgtOO

Aug-OO

Feb-07

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US ENVIRONMENTAL PROTECTION AGENCY

_- Chemical Insecticide Corporatlon Superfund Site N r Figure 1

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~ e Map from GEOO Photogrllrtmetric SCiInces Survey TIdllIOIogIes FOSTER WHE8ER EtNlRONMENTAl CORPORA

bull

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121104

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91100

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31107

61107

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91108 bull I

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FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

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FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

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V 0

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6111Q8 bull I I

91108 bull I

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~

s s

flt1

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FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

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AugQS

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FIGURE 4

30

25

20

15~

10

5

0

i 6 xP

FIGURES

Dinoseb bull well BF-2

~ ~ ~ ~~ ~~

ampgt ltt bull ltt amp b amp ft o~ ltsectgti 6 xP i 6 x i 6 xl i 6 xP date

Arsenic - Well BF-2

14000 - shy

~ 12000

1000

ug11 8000

6000 -shy ~ 4000

2000

-----shy -

0 630103 122106073107122010703260806171089162008

date

28

ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

AugQS

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ug1

~

~ l ~ i J ~ ~ 2l lB 80 0 0

Jul-9S

Jan-99

Jul-99

Jan-QO

Jul-QO

Jan-Q1

Jul-Q1 III CD

Jan-Q2 N CD

Jut-Q2 CD

Jan-Q3

~a Jul-Q3~

Ii IIIJan-Q4 bullNJul-Q4

Jan-QS

Jul-QS

Jan-QS

Jul-QS

Jan-Q7

Jul-Q7

Jan-QS

Jul-QS

concentration (ugL)

0 0 - 0 ~

Aug-99

FetHlO

Aug-QO

Feb-Q1

AugQ1

Feb-02

AugQ2 l en CDFeb-03

AugQ3 -Cl a ~ Feb-Q4lt E

CD1l Ii

Aug-Q4 C C

FebQ5

AugQS

FelgtOO

Aug-OO

Feb-07

AugQ7

bullFelHl8

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