PRELIMINARY CLOSEOUT REPORT FOR THE CHEMICAL LEAMAN …

PRELIMINARY CLOSEOUT REPORT FOR

CHEMICAL LEAMAN TANK LINES, INC. SUPERFUND SITE GLOUCESTER COUNTY, NEW JERSEY

EPA ID: NJD047321443 September 2019

Prepared by U.S. Environmental Protection Agency

Region 2 New York, New York

2

SUPERFUND PRELIMINARY CLOSEOUT REPORT CHEMICAL LEAMAN TANK LINES, INC. SUPERFUND SITE CEDAR SWAMP and OAK GROVE ROADS, BRIDGEPORT,

GLOUCESTER COUNTY, NEW JERSEY

I. INTRODUCTION

The United States Environmental Protection Agency (EPA) has determined that construction activities at the Chemical Leaman Tank Lines, Inc. (CLTL) Superfund Site (Site) have been completed in accordance with the May 2011 Close Out Procedures for Nation Priorities List Sites (OSWER Directive 9320.2-22A, May 2011)).

Based upon field observations associated with EPA’s construction oversight and a July 31, 2018 inspection of the site by Matthew Westgate of the EPA and Gregory Hattan of the U.S. Army Corps of Engineers, EPA determined that Quality Distribution Inc. (QDI), formerly Chemical Leaman Tank Lines, the Site’s sole potentially responsible party (PRP), has completed all construction activities at the Site in accordance with remedial design plans and specifications. Long-term operation, maintenance and monitoring activities are currently being conducted in accordance with EPA approved operation and maintenance plans.

II. SUMMARY OF SITE CONDITIONS

The Site is in Logan Township, Gloucester County, New Jersey, approximately one mile east of Bridgeport, New Jersey (See Figure 1) and two miles south of the Delaware River. The CLTL property encompasses approximately 31.4 acres of former farmland and wetlands with an active tank-washing terminal area occupying 14.1 acres. The Site is situated at the intersection of Cedar Swamp Road and Oak Grove Road. Portions of Cedar Swamp lie adjacent to the CLTL facility to the east and southeast, and Oak Grove Road runs through the western portion of the CLTL property. Conrail railroad tracks border the Site to the north and separates it from several private residences along Route 44. The CLTL terminal property is zoned for industrial use. Facility operations at the Site began in 1961. Historically, wastewater from washing and rinsing tanker trucks was contained on-site in seven unlined settling lagoons before being discharged to the Cedar Swamp and Moss Branch Creek via adjacent wetlands. Three of these lagoons were the Primary Settling Lagoons located just east of the Terminal Building and four lagoons were the Secondary Aeration and Settling Lagoons located south of the Terminal Building. (See Figure 2) By 1977, the facility ceased using the wastewater lagoons. The liquid that remained in the lagoons was drained and the sludge in the Primary Settling Lagoons was removed. The lagoons were then backfilled with fill and construction debris. Sludge in the Secondary lagoons was not removed prior to backfilling. In 1980 and 1981, the New Jersey Department of Environmental Protection (NJDEP) found carbon tetrachloride and other organic compounds in the groundwater on the site property, as well as in neighboring private wells. (See Figures 3, 4 and 6) The presence of these compounds

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was due to disposal practices at CLTL. Contamination was also found in soils and the adjacent wetland area. Specifically, site-related volatile organic compounds (VOCs), base-neutral extractable compounds, and metals were detected in soils and in wetlands. VOCs were the principal contaminants of concern. In 1982, the sump beneath a 3,000-gallon stainless steel settling tank (located in a waste accumulation building) was found to be leaking and was repaired. (See Figure 2) Visible sludge and contaminated soil in the former Primary Settling Lagoons and around the settling tank were excavated by the PRPs to a depth of approximately 12 feet below ground surface (bgs), under the supervision of the State of New Jersey. These excavations were backfilled with sand. The site was placed on the National Priorities List (NPL) on September 21, 1984. In 1985, the PRP entered into an Administrative Consent Order with EPA to perform the site’s remedial investigation/feasibility study (RI/FS). Based on the complexity of the site, EPA divided it into the three Operable Units (OUs): OU1 addresses the contaminated groundwater underlying the site; OU2 addresses the sources of groundwater contamination (i.e., contaminated soils and areas containing nonaqueous phase liquids (NAPL)); and OU3 addresses the contaminated wetlands at the Site. Remedial Construction Activities Operable Unit 1 - Groundwater On September 28, 1990 EPA issued a Record of Decision (ROD) for OU1, which selected groundwater extraction and treatment as the groundwater remedy. The Remedial Action Objective (RAO) for OU1 was to restore the aquifer to drinking water standards. In September 1991, the PRPs entered into a Consent Decree (CD) with EPA to perform the Remedial Design/Remedial Action (RD/RA) for the OU1 treatment system. The RD began in 1991 and was completed in September of 1997 by the PRP. It called for the pumping of groundwater from 24 extraction wells screened in the shallow, intermediate and deep aquifer zones. After the submittal of the original design the PRP proposed an alternative RD for OU1 which was approved by EPA in January 2004. The modified design consisted of an optimized groundwater pump and treat system with 20 extraction wells pumping at a combined rate of 230 gpm from the shallow and intermediate aquifer zones, eliminating unnecessary pumping from the deep aquifer. This was to be paired with treatment of the sources of groundwater contamination. EPA determined that the use of source area treatment technologies combined with the optimized pump and treat system would provide for a more efficient and effective remedy for groundwater. As per the June 2005 Explanation of Significant Difference (ESD) treated groundwater was to be discharged to a culvert at the confluence of Moss Branch Creek and an unnamed tributary to the Delaware River. Construction began on the pump and treat system in May 2005 and startup/shakedown began in February 2007. The groundwater treatment facility consists of process treatment steps for the removal of metals and VOCs. During startup numerous difficulties were experienced that

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required re-fabrication and replacement. The treatment plant was started up again in 2010 and operated for five weeks before being shut down due to air emissions greater than those permitted by the State. The exceedances were due to changes in influent contaminant concentrations. Modifications, including installation of new chemical oxidation tanks, to address these higher levels were completed in 2011. The system began operating again on September 8, 2011. The total VOC loading in September 2011, was 4,949 μg/L. The average system flow rate at that time was 230 gpm. As documented in the Semiannual Groundwater Extraction System Performance Report (October 2017 – March 2018), the average total VOC loading from October 2017 through March 2018 was 1,370 μg/L with an approximate average system flow rate of 180 gpm. The influent total VOC concentration has dropped by more than 3.5 times since the system restart (September 2011) In June 2003, as part of OU1, a Non-Aqueous Phase Liquid (NAPL) recovery system was installed in the central portion of the former Primary Settling lagoon. This NAPL recovery system operated from July 2003 to January 2015 after recovering 5,148 gallons of dense NAPL (DNAPL). The OU1 Remedial Action Report was approved by EPA on November 21, 2011. And a final inspection by EPA occurred in January 2012. Operable Unit 2 - Soils

The OU2 ROD was issued in September 2009 and established the following RAOs:

• Reduce the contaminant levels present in the source areas of groundwater contamination

to the maximum extent practicable • improve the efficiency and effectiveness of the OU1 groundwater pump and treat

remedy.

The major components of the selected remedy include the following:

• In-Situ Thermal Treatment with Soil Vapor Extraction (SVE) to treat areas that are sources to groundwater contamination that are primarily contaminated with VOCs and semi-volatile organic compounds (SVOCs) including Areas 1, 4, 6 and the Waste Accumulation Building (WAB) (See Figure 2);

• Installation of a Non-Aqueous Phase Liquid Recovery (NAPL) system to remove contaminated free-phase product in Areas 1, 4, 6 and the WAB;

• Extraction and treatment of highly contaminated groundwater in the vicinity of areas that are sources to groundwater contamination including Areas 2 and 3; and

• Establishment of a Classification Exception Area (CEA).

In October 2010, the PRPs entered into a Consent Decree with EPA to perform the RD and RA work for the OU2 remedy. The RD was completed on February 19, 2015, and construction of an Electrical Resistance Heating and Multi Phase Extraction (ERH-MPE) system, commenced on April 17, 2015.

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Phase 1 -July 13, 2015 to February 2016

The ERH-MPE system startup was on July 13, 2015, within Treatment Areas (TA) 1, 4 and 6. (See Figure 2) The ERH-MPE system operated through December 2015, then power was reduced in an attempt to evaluate the unanticipated introduction of polychlorinated biphenyl compounds (PCBs) from the heated vapor phase as part of the NAPL waste stream. PCBs are not one of the OU2 COCs and the ERH-MPE treatment train was not designed to remove PCBs. In February 2016, the OU2 ERH-MPE system was completely shut down when it was determined that it had to be redesigned to appropriately manage the PCBs.

On May 31, 2016, the PRPs provided a report on the ERH-MPE system. This report documented the status of soil remediation within three targeted treatment areas TA 1, 4 and 6. The report detailed that the ERH-MPE treatment system achieved significant reductions in the mass and concentrations of contamination during its operation. However, it was clear that additional remediation was necessary to meet RAOs. On January 30, 2017, the PRPs submitted a plan to modify the treatment system to address PCBs and to continue to reduce levels of soils contamination. EPA approved the PRP’s redesign on March 10, 2017.

In addition, during Phase 1, there were several spill events where PCB contaminated water impacted surface soils. Samples of the soils were collected and analyzed. In three areas concentrations of PCBs were found at levels greater than the NJDEP Non-Residential Direct Contact Standard (i.e., 1.0 mg/kg). Contaminated soils from these areas were removed, and the remaining soil was re-sampled. The post-excavation samples all had levels of PCBs below 1.0 mg/kg, therefore no further action was required.

Phase 2 – March 2017 – December 2017

Several system modifications were incorporated into the original ERH-MPE system design in order to improve soil heating in the deeper soils, focus heating on the remaining areas of concern based on the results of post-ERH soil sampling performed in 2015 and allow for mobilization of PCBs in the subsurface. The overall objective of Phase 2 was to reduce the remaining contaminant mass to the maximum extent practicable, understanding that not all mass would be removed. The Agency acknowledged that, though the ERH-MPE system operation would remove semi-volatile organic compounds (SVOCs) and 1,2-dichlorobenzene (DCB) contamination, it would occur at a significantly reduced rate as compared to volatile organic compounds (VOCs) due to the high boiling points of SVOCs and DCB. Based on historical groundwater data, under ambient conditions SVOCs are not partitioning into site groundwater and are therefore not considered a contributor to site groundwater quality. As EPA’s oversight contractor, a representative of USACE was on site March 6, 2017 to receive a tutorial on system operations and to perform a final inspection of the installation prior to the initiation of soil heating operations. No significant deficiencies were identified.

The ERH-MPE system was restarted on March 28, 2017 and is now finished operating because the system met its’ time and temperature requirements. Approximately 72% of TCE and DCE

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mass from the soil and groundwater was removed after temperatures in the subsurface reached target levels.

In July 2018, an additional extraction well EW-15I was installed in the OU2 source areas to augment ongoing OU-1 groundwater extraction and treatment. EW-15I was developed and started pumping into the GWTP system in October 2018.

The components of the soil remedy that included the NAPL recovery system and extraction and treatment of the highly contaminated groundwater in the vicinity of areas that are sources to groundwater contamination including Areas 2 and 3 was addressed under the OU1 remedy.

Operable Unit 3 - Wetlands EPA issued a ROD for OU3 on October 5, 1993 that selected excavation and off-site disposal of contaminated wetland soils and sediments along with wetland restoration activities. In September 1998, EPA issued a Unilateral Administrative Order to the PRP for implementation of the RD and remediation activities. Construction of the OU3 remedy was initiated in June 2004. Excavation and disposal of approximately 7,500 cubic yards of sediment and surface soils occurred between June 2005 and February 2006. Analytical results of post-excavation samples showed that the ROD cleanup goals were achieved for all areas except the Main Swale Area. In response, EPA approved the Main Swale Area’s closure plan in March 2006 with the following requirements:

• The PRPs must monitor OU1 groundwater influent to treatment plant for the OU3 Contaminants of Concern;

• The PRPs must place 12 inches of topsoil when backfilling areas excavated to a depth of more than 6 inches; and

• The PRPs must develop and implement a monitoring and maintenance plan for the Main Swale Area.

These requirements were addressed in June 2006, through an updated Wetland Mitigation and Monitoring Plan. It should also be noted that post-excavation sampling indicated exceedances of the background value for arsenic (24.0 milligrams/kilogram (mg/kg)) in Areas 1, 2, 3, and 3A sediments at varying depths. (See Figure 5) An additional arsenic background study was conducted, and results of the study indicated that the arsenic background level in sediment should be 46 mg/kg. This new background level for arsenic was approved by EPA in November 2005. All results from subsequent sediment sampling, beginning in 2006, has shown arsenic levels below 46 mg/kg. Twelve OU3 Access Restriction Signs and seven Main Swale Area Access Restriction signs were installed between June and July 2006. In spring 2006, the excavated areas were backfilled with approximately 8,100 CY of imported sand fill and 3,700 CY of topsoil and the wetlands restoration work was initiated. Wetlands restoration included planting and seeding, installation of debris piles and vertical snags to promote reintroduction of wildlife species, and initial invasive species control. (See Figure 5) Planting and seeding activities were completed in July 2006.

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Cutting of phragmites to grade was performed in April 2006. An initial application of HABITAT (invasive species control spray) was performed in May 2006. A second application was performed in June 2006 to address areas of new growth. Galerucella beetles were introduced to the Site in the Spring of 2007 and 2008 to help control the spread of purple loosestrife, an invasive species prevalent in the wetland areas. In addition, thirteen new piezometers were installed in July 2006, in preparation for O&M activities. Vegetative monitoring plots were established having piezometers as the center point of the plot. The effectiveness of the remedy is regularly monitored in accordance with the schedule established in the WMMP for OU3. Remediation and restoration activities in wetland areas of the Site were completed in July 2007. III DEMONSTRATION OF CONSTRUCTION QUALITY ASSURANCE AND QUALITY CONTROL Remedial Action (RA) activities were undertaken in a manner consistent with the RODs, the RD plans and specifications and the as-built drawings. All applicable EPA and State quality assurance and quality control (QA/QC) procedures and protocols to be followed by construction contractors were specified in the RD. Appropriate EPA analytical methods were used for all groundwater, and soil sample collection and analyses during all RA activities; the sample analyses were performed at certified laboratories. Oversight of daily construction activities was provided for by the U.S. Army Corps of Engineers and periodic visits were conducted by EPA and NJDEP. The QA/QC program used throughout the soil and groundwater RAs was rigorous and in conformance with EPA and State standards; therefore, EPA and the State determined that all analytical results are accurate to the degree needed to assure satisfactory execution of the RAs and that they are consistent with the ROD and RD plans and specifications, as modified by the as-built drawings. IV ACTIVITIES AND SCHEDULE FOR COMPLETION The activities that remain to be completed for the site include completing the groundwater restoration to drinking water standards and approving the OU2 RA report, performance of the long term response actions, completing the CEA, deed notice, five-year reviews, operation and maintenance, preparation of a Final Close-Out Report, deletion of the site from the NPL. These activities will be completed according to the following schedule. Activity Responsible Organization Date Approval of CEA NJDEP PRP 2020 Approve OU2 RAR EPA 2020 Third Statutory Five-Year Review

EPA 2022

Approve Final Closeout Report EPA TBD Deletion from NPL EPA TBD

Five Year ReviewThe selected remedy will result in hazardous substances, pollutants, or contaminants remainingon-site above levels that will allow for unlimited use and unrestricted exposure. Therefore, astatutory review was required within five years after the initiation of remedial action to ensurethat the remedy is or will be protective of human health and the environment. The first five-yearreview of the groundwater remedy was performed in 2017.

Pat Evangelista, Acting DirectorSuperfund and Emergency Management Division Date

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FIGURES

1. Site Location Map – Bridgeport, NJ 7.5 minute quadrangle2. CLTL Site Map with OU-2 Areas of Concern and Treatment Areas3. Groundwater Intermediate Sub-Zone4. Groundwater Deep Sub-Zone5. OU-3 Wetlands Piezometer and Vegetative Plot Locations6. Groundwater Shallow Sub-Zone

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Delaware R iver

Hendrickson Mill Road

Oak Grove Road

US Route 130Unnamed Tributary tothe Delaware River

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Site Location Map

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Fig ure 1

.Chemical Leaman Tanks Superfund Site

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Figure 1

GROUNDWATER SCIENCES CORPORATION

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Site Map with OU-2 Areas ofConcern and Treatment Areas

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Bridgeport, New Jersey

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Text Box

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NOTES:

1) Property Boundary from Figure 1-2 Site Layout from Environ, dated 3/2012002. 2) Well and former lagoon locations from surveys conducted by B&B Hi-Tech Solutions, LLC. 3) Concentrations are in micrograms: per liter (µg/L). 4) U-Analyte was not detected above the reporting limit. 5) J- Result is less than the Reporting Limit (RL) but greater than or equal to the Method Detection Limit (MDL). and the concentration is an approximate value. 6) D- Analyte analyzed at a dilution. 7) Detected concentrations that are 1�reater than theNJDEP Class II-A GWQS/USEPA MCL are in bold red. 8) The 1 and 1 O µg/1 contour lines were positioned based on the analytical data from the ay 20·1 a sampling round. The 1 oo µg/1 and the 1,000 µg/1 contour lines were positioned based on the analytical da,ta from multiple sampling rounds. 9) May 2018 round sample results a1re highlighted in pink. 10) Refer to chemistry table for histo-ric sampling results. 11) Wells sampled for the routine seimiannual sampling round (027 - May 2018) are highlighted in yellow. 12) TVOC results were rounded to the nearest whole number.

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Chemical Leaman Tank Lines Superfund Site Bridgeport, New Jersey

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1} Property Boundary from FigurH 1-2 Site Layout from Environ, dated 3/20/2002. 2) Well and former lagoon locatic,ns from surveys conducted by B&B Hi-Tech Solutions, LLC . 3) Concentrations are in micrograms per liter (µg/L). 4) U-Analyte was not detected a'bove the reporting limit. 5) J-Result is less than the RepClrting Limit (RL) but greater than or equal to the Method Detection Limit (MDL), and the concentration is an approximate value. 6) D-Analyte analyzed at a dilution. 7) Detected concentrations that are greater than the NJDEP Class II-A GWQS/USEPA MCL are in bold red. 8) May 2018 round sample results are highlighted in pink. 9) Refer to chemistry table for historic sampling results. 1 O) 2001 analytical data is from Environ DRAFT Plate 1 -Concentrations of VOC's in Groundwater, May 25, 2007. 11) ND -Not Detected 12) Bis (2-Chloroethyl) ether -BCEE is an SVOC. 13) NA -Not Analyzed 14) Wells sampled for the routine, semiannual sampling round (Q27 • May 2018) are highlighted in yellow. 15) Sample for BCEE from 15-62:0 was collected on May 3, 2018.

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Rd JJ

CONRAIL RAIL LINE

TCE .·

C-1,2·DCE vc

B

TVOC

7A Anal e 2/23/IS PCE o.su

TCE o.su

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VC 0.5U 6 0.5U TVOC 0

MW-215 Analvte S/2/18 MW-115

IU IU IU IU 0

GM9S-MW2S Analyte S/3/18 PCE IU TCE IU C-1,2-0CE I U VC IU

IU TVOC 0

PCE IU TCE IU C-1,2,DCE I U VC IU

IU TVOC

COOPER LAKE

EW-8S Analyte 5/3/18 PCE TCE C·l,2-0CE vc

TVOC

7A �7B

Anal te 11/20 IS PCE lU TCE IU C•l,2,IDCE IU VC IU 8 IU TVOC

MW-10S A,oalyte 11/17/17 PCE lU TCE IU C··l,2-0CE 1.3 Vt: lU 8 IU TVOC 1

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EW•IAS Anal te S/3/18 PCE IU TCE IU C-1,2-DCE JU vc

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EW-7S

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OBS-IS .·. :·•.:. , Anal te 5/2/18 ·: PCE I U

Analyte S/2/18 l--'"'

Analvte 3/15/18 1A PCE JU PCE 2.7

TCE IU TCE 7 C•l,2•DCE IU C•l,2-DCE 27.1 vc IU VC 9.8 B IU B

TVOC 0 TVOC

Analyte

PCE TC£

C-1,2-DCE vc

B TVOC

LEGEND

c=::=>c?

GM95-MW40 GM95-MW4S

GM95-MW4S Anal te 5/1/18 PCE IU TCE IU C-1,2-0CE lU vc lU 8 IU TVOC 0

$ Extraction Well

-\- Monitoring Well

$ Abandoned Monitoring Well

Approximate OU-2 Thermal Treatment Area Boundary


1 o µg/L Total voe Contour Line


1 ooo µg/L Total voe Contour Line

..._,_.,_ Conrail Line Scale (feet)

c::::=J Existing Building 0 87.5 175

c::::=J Former Lagoon

� Approximate CLTL/0DI Property Boundary

Water Body

Wetlands

350

SU SU

3.9J SU

363 456 334

17.9 ISSS

EW,11S 5/3/18 lOOU 634

2670

134

34.2] 4474

GM9S-MWSS Analvte S/1/18 PCE 1U TCE IU C-1,2-DCE 1U vc 1U B lU TVOC 0

·.· ·;

'9-MW-141I

NOTES:

EV-."13I �-

Q

lU 12.7 216 29.3 2.6

TVOC 447

$EW-14I

28 Analyte S/20/10 PCE IOU TCE 47 C-1,2-DCE 1800

vc 260 B 2.lJ TVOC 2136

D

VC

1) Property Boundary from Figure, 1-2 Site Layout from Environ, dated 3/20/2002. 2) Well and former lagoon locations from surveys conducted by B&B Hi-Tech Solutions, LLC. 3) Concentrations are in microgra,ms per liter (µg/L). 4) U- Analyte was not detected at>ove the reporting limit. 5) J. Result is less than the Reporting Limit (RL) but greater than or equal tothe Method Detection Limit (MDL), and the concentration is an approximate value. 6) D- Analyte analyzed at a dilution. 7) Detected concentrations that are greater than the NJDEP Class II-A GWQS/USEPA MCL are in bold re,d. 8) The 1 and 10 µg/I contour lines were positioned based on the analytical data from the May sampling rouncl. The 100 µg/I and the 1,000 µg/I contour lines were positioned based on the analytical data from multiple sampling rounds. 9) The May 2018 round sample results are highlighted in pink. 1 O) Refer to chemistry table for historic sampling results. 11) Wells sampled for the routine semiannual sampling round (027 - May2018) are highlighted in yellow. 12) TVOC values are rounded to the nearest whole number.

SU SU 9.3

5/3/18 JU lU

16A 0.53J

28

, TC£ lU c-1,2-oa lU

GAVENTA PONO

MW-235 Analyte 5/2/18 PCE IU TCE IU C-1,2-0CE IU

. vc lU B lU

. TVOC 0 '• :· •·t\.MW:23�-

GM95-MW65 Analyte PCE TCE C-1,2-DCE vc

B

TVOC

5/1/18 1U 1U 1U 1U 1U 0

�M95 GM9

-MW6S 5-MW6I

GM95-MW6D

MW-24I :,,

1- Figure 6


Shallow Subzone Total voe

lsoconcentration Map

DRAWN BY: JPB CHECKED AND APPROVED BY: COO DATE: 12/1812018 Q:\12000\12006\Bridgeport\Pmjects\Quarterty Report\2018_27 _28_qWigS.1_ShalVOC_20181010.mxd

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