feasibility study work plan for the hercules …

Prepared for

Hercules Incorporated

Ashland Research Center, Bldg. 8139

500 Hercules Road Wilmington, Delaware 19808-1599

FEASIBILITY STUDY WORK PLAN

Former Higgins Plant

Gibbstown, New Jersey

February 2010

Prepared by

CSI Environmental, LLC

918 Chesapeake Avenue Annapolis, Maryland 21403

Feasibility Study Work Plan Hercules Incorporated, Gibbstown, New Jersey

1 CSI Environmental, LLC Rev. 02/16/10

TABLE OF CONTENTS EXECUTIVE SUMMARY ................................................................................................ 2 1. INTRODUCTION ...................................................................................................... 4

1.1 Background and Site History.............................................................................. 4 1.2 Purpose of the FS Work Plan.............................................................................. 8

1.3 Deliverables ............................................................................................................ 8 2. LIST OF POSSIBLE TECHNOLOGY TYPES AND PROPOSED TREATABLITY STUDIES ............................................................................................................................ 9 3. DEVELOPMENT AND SCREENING OF REMEDIAL ACTION OBJECTIVES, TECHNOLOGIES AND REMEDIAL ALTERNATIVES .............................................. 11

3.1 Remedial Action Objectives ............................................................................. 11 3.2 Applicable or Relevant and Appropriate Requirements (ARARs) ................... 11 3.3 Identification and Screening of Technology Types and Process Options ........ 11

3.3.1 Identification and Screening of Technologies .......................................... 11 3.4 Development of Remedial Action Alternatives................................................ 12

4. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES ...................... 13 4.1 Detailed Description and Assessment of Remedial Action Alternatives.......... 13 4.2 Comparative Analysis of Remedial Action Alternatives .................................. 13 4.3 Recommendation of Remedial Action Alternative and Conceptual Design .... 13 4.4 Evaluation of Alternatives ................................................................................ 13

5 EVALUATION OF ALTERNATIVES ................................................................... 15 5.1 Overview........................................................................................................... 15

5.1.1 Threshold Criteria ..................................................................................... 15 5.1.2 Primary Balancing Criteria ....................................................................... 16 5.1.3 Modifying Criteria .................................................................................... 16

5.2 Sustainability..................................................................................................... 17 6. REFERENCES ......................................................................................................... 18 Figures Figure 1 Site Location Figure 2 Vicinity Plan Tables Table 1 Proposed Feasibility Study Outline



EXECUTIVE SUMMARY

The following work plan describes the performance of the Feasibility Study (FS) and preparation of the FS Report for the Hercules Incorporated (Hercules), a wholly owned subsidiary of Ashland Inc., former Higgins Plant located in Gibbstown, New Jersey. The FS will be prepared and reported concurrently with the ongoing Remedial Investigation (RI) as described in the United States Environmental Protection Agency’s (EPA’s) Statement of Work (SOW), Remedial Investigation and Feasibility Study, Hercules, Inc. Superfund Site, Gibbstown, Gloucester County, New Jersey (USEPA, September 2009). Data already obtained through the implementation of the RI will be evaluated and incorporated into the FS report, as needed, to identify techniques that will potentially be effective to remediate environmental media at the site, if necessary.

The FS report will summarize current conditions at the Hercules former Higgins

Plant located in Gibbstown, New Jersey, with reference to the RI where appropriate, and identify environmental media requiring remediation. A detailed nature and extent discussion of contamination at the site will be presented for each significant contaminate by media type, which will also identify data gaps, if any. Media-specific remedial action objectives (RAOs) will be identified in concert with the USEPA and New Jersey Department of Environmental Protection (NJDEP) and reported in the FS report. Potentially effective techniques to remediate environmental media at the site will be evaluated and identified in the FS report. Remedial alternatives that have a reasonably efficient potential to achieve RAOs for each environmental medium requiring remediation will be considered. Candidate remedial alternatives will be evaluated using USEPA criteria. Alternatives will be screened using USEPA criteria and at least one will be carried forward through detailed analysis. The FS report will provide recommendations for the selection of the technology or technologies that are anticipated to improve conditions in environmental media that require remediation.

The FS report will also include recommendations for any treatability studies or

pilot studies needed to evaluate and optimize remediation techniques recommended in the FS report. Hercules will prepare treatability study work plans (TSWPs) and/or pilot study work plans (PSWPs), as required, to convey information describing the objectives and procedures for any treatability or pilot studies that are required. However, the actual scope of any treatability or pilot studies performed may vary, based on the results obtained through the implementation of the upcoming RI and FS.

Hercules currently operates a groundwater extraction and treatment system

(GWETS) and may want or need to alter the groundwater remediation strategy to optimize attainment of remedial endpoints for the site. The current GWETS, its effectiveness and any efforts previously made to optimize the system will be described in the FS report. Additional alternative groundwater remediation techniques may be identified in the FS that will augment or altogether replace the current GWETS and expedite site remediation. Thus, provisions for groundwater remediation treatability or pilot studies are identified in the work plan and are summarized herein.



There are a number of techniques that may be effective for groundwater

remediation including, but not limited to, monitored natural attenuation, air sparging coupled with soil extraction, reagent injection, and continued operation of the existing GWETS. One technique currently under evaluation is the injection of one or more reagents into affected groundwater to promote in-situ remediation, particularly in areas containing higher concentrations of constituents in the vicinity of the previously active process area. Other remediation techniques may be required depending upon the findings of the RI and FS.

The RI/FS report, will be prepared in accordance with the schedule provided in

the above mentioned document and will include the results of past and current investigations and evaluations at the site. This FS work plan is presented to provide the EPA and NJDEP with an opportunity to comment on the intended substance of the FS report. An outline of the proposed FS is provided in Table 1.



1. INTRODUCTION

1.1 Background and Site History The Former Higgins Plant (Site) is located in Gibbstown, Greenwich Township, Gloucester County, New Jersey (Figure 1). The northern plant property boundary is the Delaware River; Valero Refining and Marketing Company (Valero) tank farms and landholdings are to the east; residential communities (Gibbstown) are to the south and west; and Greenwich Township Board of Education property, as well as open land owned by E. I. du Pont de Nemours Incorporated (Du Pont), are to the west (ERM, 2003) (Figure 2). The southwestern portion of the site, including the plant area, is composed of uplands. Northeast from the plant area are Clonmell Creek, wetlands, and the Delaware River. Clonmell Creek, a tidal tributary of the Delaware River, courses northwest through the middle of the property. On the plant property, the creek is approximately 20 to 35 feet wide and ranges in depth from approximately 2 to 3 feet. Flow in Clonmell Creek is controlled by a tide gate at its confluence with the Delaware River. The gate opens and shuts in response to pressure changes resulting from tidal fluctuations in the Delaware River. The creek receives permitted discharges from industrial facilities upstream and east of the Plant (ERM, 2003).

DuPont formerly owned the 350-acre property, which was indentured to the Hercules Powder Company on 4 September 1952. Hercules constructed the manufacturing facility and began production in the former Higgins Plant by 1959. GEO Specialty Chemical Co. (GEO) purchased the manufacturing facilities covering approximately 80 acres in May 2001.

Hercules formerly produced phenol and acetone at the plant. Isopropylbenzene (cumene) and cumene hydroperoxide were included in the production of phenol and acetone. GEO produced three products, including (i) cumene hydroperoxide, (ii) diisopropylbenzene hydroperoxide, and (iii) dicumyl peroxide. The four major raw materials used in this manufacturing process were cumene, diisopropylbenzene, sodium hydroxide (caustic soda), and sulfuric acid (ERM, 2003). Before Hercules acquired the site, DuPont disposed of aniline still bottoms in an area known as the Solid Waste Disposal Area (SWDA), located in the northern portion of the property. In 1996, a Record of Decision (ROD) for the SWDA required that the SWDA be capped (ERM, 2003).



Several investigations and site improvements have been conducted or are ongoing at the Site and are compiled below: • In 1979, the U.S. Geological Survey (USGS) investigated regional groundwater

quality. As part of the USGS evaluation, benzene was detected in samples taken from production well PW-4 in the southwestern corner of the site. In 1982, Hercules, in cooperation with the NJDEP, began an investigation to determine potential sources of the benzene, which led to the detection of site-related constituents in groundwater (ERM, 2003).

• In December 1982, the site was listed on the Comprehensive Environmental

Response, Compensation and Liability Act (CERCLA) National Priorities List (NPL) (ERM, 2003).

• February 1983 — Hercules installed four shallow monitoring wells, according to NJDEP specifications, as required by NJDEP in an attempt to determine whether the benzene identified by the USGS in well PW-4 was related to the SWDA (ERM, 2003).

• Phase I - April/May 1983 — A preliminary study was completed to review available

data regarding hydrogeologic conditions at the Plant and to make a preliminary determination as to the possible source(s) of the benzene that had been identified in well PW-4 (ERM, 2003).

• Phase II - December 1983 — The report entitled “Installation of a Ground Water

Monitoring System for Hercules Inc., Gibbstown, New Jersey” documents the installation of 14 monitoring wells and the collection of 11 soil samples in the area of the Tank Farm and Process Areas (see Figure 1-3). Chemical analysis of the soil samples indicated that, in areas of sandy surficial deposits, organic compounds apparently passed through the unsaturated soils to ground water, leaving behind only low concentrations of compounds. In contrast, a soil sample taken from a silty clay zone contained relatively high concentrations of isopropylbenzene (ERM, 2003).

• Phase III - April 1984 — The report entitled “Phase III Hydrogeologic Definition and

Initiation of Remedial Activities for Hercules Inc., Gibbstown, New Jersey” documents the installation of 10 additional wells and the further delineation of affected ground water underlying the Plant (ERM, 2003).

• Phase IV - November 1984 — The report entitled “Hydrogeologic Definition and

Continuation of Remedial Activities for Hercules Inc., Gibbstown, New Jersey” documents testing of the existing ground water recovery wells at the Plant, and the installation of new monitoring wells (ERM, 2003).



• Phase V - May 1985 — The report entitled “Status Report of the Phase V

Investigation” documented the drilling and installation of off-site monitoring wells and four additional ground water recovery wells. Twenty-one soil borings were installed, and 29 soil samples from the Plant Process and Tank Farm Areas (Figure 1-3) were analyzed. A final Phase V report was not issued; however, data gathered during the study were submitted as part of the Status Report. Review of the soil analytical data revealed that the highest levels of benzene, phenol, and cumene were found in the Active and Inactive Process Areas. With the exception of one sample, soil samples from the Tank Farm contained no detectable concentrations above method detection limits (ERM, 2003).

• In 1986, Hercules and the NJDEP executed an ACO describing required site

evaluations, including areas to be investigated, sampling frequency and analysis, and deliverables for each investigation. As a requirement of the 1986 ACO, Hercules designed, installed and continues to operate an on-site groundwater recovery system (ERM, 2003).

• Ground Water Quality Assessment Program, Equalization Basin -May 1987 — The

report entitled, “Ground Water Quality Assessment Program—Equalization Basin, Hercules Inc., Gibbstown, New Jersey” documents the results of this investigation. The study addressed ground water quality in the vicinity of the Equalization Basin (Surface Impoundments), tidal influences associated with Clonmell Creek in the area of the Equalization Basin, and a hand auger and soil gas survey. The results indicated the following:

− The hand auger survey, conducted in the area between Clonmell Creek and the Equalization Basin (generally the area referred to as the Northern Chemical Landfill Area), defined the boundaries of the area containing refuse materials. With the exception of one location, the soil gas survey detected total organic vapor concentrations of greater than 1,000 ppm at all locations; and

− The tidal influence study monitored minor ground water level fluctuations, ranging from 0.2 to 0.4 feet in monitoring wells MW-30 and MW-38. No ground water fluctuations were observed in wells south of the Equalization Basin. This investigation concluded that the influence from Clonmell Creek level changes is limited to within approximately 500 feet of the creek (ERM, 2003).

• Phase I Soils Investigation - 1988 — This investigation included a comprehensive

evaluation of soil quality through completion of 69 soil borings in 12 “areas of concern” throughout the Plant. The results of this investigation were reported in the



14 September 1989 report “Higgins Plant, Revised 1988 Soils Investigation, Hercules Inc., Gibbstown, New Jersey.” (ERM, 2003)

• Surface Impoundment Closure Investigation – 1990 – Groundwater Technology, Inc.

(GTI) performed a soil gas and soil sampling effort in conjunction with closure of the Equalization Basin surface impoundments. This work was summarized in the 30 January 1990 report, “Results of Soil Gas Survey and Soil Sampling for the Surface Impoundment Closure Plan at Hercules Incorporated, Gibbstown, New Jersey.” The report indicated that Plant-related organics were in soils beneath the impoundments, but that concentrations of these organics decreased with depth (ERM, 2003).

• Phase II Soils Investigation - 1995 — This investigation focused on the Active and

Inactive Plant Areas located to the south of Clonmell Creek. The intent of these activities was to complete the remedial investigation of the soil to support completion of a Risk Assessment and Feasibility Study for the soil medium. A total of 289 soil borings were completed on site, and 743 soil samples were collected. Ground water samples were also collected during on-site activities by means of Geoprobe® and lead-screened auger sampling. The results of the Phase II Soils Investigation are reported in the 4 October 1995 report, “Hercules Incorporated, Phase II Soils Investigation, Hercules Higgins Plant, Gibbstown, New Jersey.” (ERM, 2003)

• Supplemental Remedial Investigation - 2003 — In 2002 ERM Inc. collected 50 soil,

47 groundwater, 33 sediment and 16 surface water samples to confirm previous environmental and hydrogeologic findings, and closed data gaps in various plant areas. The results of the Supplemental Remedial Investigation area reported in the January 2003 report, “Supplemental Remedial Investigation Report, Former Higgins Plant, Gibbstown, NJ.” (ERM, 2003)

• Groundwater Extraction and Treatment System Replacement - 2008 – A new granular

activated carbon treatment system was installed at the site to replace the existing treatment system. The new system provides increased flexibility and efficiency for the treatment of groundwater at the site. Operation of the new system began in September 2008.

• Installation of Replacement Extraction Wells PW-4R and PW-10R – 2009 –

Replacement extraction wells PW-4R and PW-10R were installed To enhance the recovery of groundwater and replace extraction wells PW-4 and PW-10 due to decreased well yield. The new extraction wells PW-4R and PW-10R were installed in 2007 and brought online in April 2009. .

• Sewer System Replacement – 2009 — Bruce Industrial (General Contractor)

completed a sewer replacement project at the Site between April 2008 and January



2009 based on previous investigation results which concluded that the integrity of portions of the industrial process sewer system may have been suspect. The sewer replacement project involved the excavation and removal of soil adjacent to the sewer lines undergoing replacement (CSI, 2009).

• Focused Investigation/Remedial Investigation (FI/RI) – 2009 — CSI performed a

focused investigation to address regulatory concerns regarding lingering data gaps from the Supplemental Remedial Investigation Report, Former Higgins Plant, Gibbstown NJ (SRI Report). The SRI report was prepared by ERM, Inc. in 2003 to satisfy the obligation of the 1986 Administrative Consent Order (ACO) between Hercules and NJDEP (CSI, 2008). Media evaluated as part of the FI/RI to address these data gaps included groundwater, soil, sediment, surface water and soil vapor.

1.2 Purpose of the FS Work Plan

The purpose of this FS work plan is to describe the procedures that will be followed to conduct a Feasibility Study (FS) and prepare a FS Report for the Site. The objective of an FS is to provide an evaluation of various remedial action (RA) alternatives that address soil, groundwater, sediment and surface water; consistent with the United States Environmental Protection Agencies (USEPA) Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final (USEPA, 1988). As stated therein, “[t]he objective of the RI/FS is not the unobtainable goal of removing all uncertainty, but rather to gather information to support an informed risk management decision regarding which remedy appears most appropriate for a given site.” The remedy selection process described herein is based on this guidance.

1.3 Deliverables Based upon the EPA’s September 2009 SOW for the site several other deliverables may be required as part of the FS. These deliverables are as outlined below:

• Candidate Technical Memorandum • Treatability Study SOW

o Treatability Study Work Plan o Treatability Study Quality Assurance Project Plan o Treatability Study Health and Safety Plan o Treatability Study Evaluation Report

• Technical Memorandum on Remedial Action Objectives and Remedial Alternatives

These deliverables will be provided, if they are necessary, in accordance with the EPA’s September 2009 SOW.



2. LIST OF POSSIBLE TECHNOLOGY TYPES AND PROPOSED TREATABLITY STUDIES

Possible general actions have been identified for the Site based on information and data gathered for the RI/FS report. In accordance with the USEPA guidance on conducting an FS, the general remedial actions, remedial technology types and associated aspects of the RI/FS process have been subjected to an initial screening on the basis of the technical ability to implement the remedies (USEPA, 1998). The general remedial action/technology types and process options to be considered may include, but not be limited to, the following: Soil

• No Action • Removal – Excavation • Treatment – In-situ: such as air sparging/soil vapor extraction and/or application

of reagents to enhance in-situ degradation • Treatment – Thermal

- Incineration • Disposal – Landfill

– On-Site/Off-Site – On-site treatment/reuse

• Containment – Cap – Soil/clay cap – Engineered multilayer cap

• Institutional and Site (i.e. Engineering) Controls – Access restrictions – Deed restrictions – Fencing

• Green Remedial Techniques will be Considered for all Alternatives Groundwater

• No Action • Monitored Natural Attenuation • Containment

– Extraction and treatment o Activated carbon o Ion exchange resin o Reverse osmosis o Air Stripping

• Groundwater Extraction and Treatment for Remediation (on-site/off-site) • In-situ Treatment

– Injections – Air Sparging

• Institutional and Site Controls – Access restrictions – Deed restrictions – Fencing



– Monitoring • Green Remedial Techniques will be Considered for all Alternatives

Sediment

• No Action • Removal – Excavation/Dredging and On-site Treatment

- Incineration - Air Sparging - Soil Vapor Extraction

• In-situ Treatment – Biological – Physical

• Excavation/Dredging and Disposal – Landfill – On/off site disposal – On-site treatment/reuse

• Containment – In Situ Cap – Clean sediment, sand, gravel geotextile, or liner


• Green Remedial Techniques will be Considered for all Alternatives

Surface water • No Action • Pump and Treat – Physical

– Dewatering – Surface water diversion


• Green Remedial Techniques will be Considered for all Alternatives

Following EPA approval of the FS work plan, these technologies will be

assembled into RA alternatives and evaluated further for implementation at the Site. Treatability and/or pilot testing may be conducted in an effort to collect additional information for technology evaluation and implementation. If a treatability or pilot study is to be conducted, a work plan will be submitted to the EPA, which will provide details on the performance of the study and reporting of results. The results of any treatability or pilot study will be included in the FS Report.



3. DEVELOPMENT AND SCREENING OF REMEDIAL ACTION OBJECTIVES, TECHNOLOGIES AND REMEDIAL ALTERNATIVES

3.1 Remedial Action Objectives

During the initial stages of RA alternative development, RAOs will be established for the Site. RAOs consist of medium-specific or operable unit specific goals for protecting human health and the environment. Applicable or Relevant and Appropriate Requirements (ARARs) will be considered in developing RAOs. The results of human health and ecological risk assessment studies at the site will also be used to assist in determining the optimum RAOs for site specific constituents at the site. Based on the RAOs, an estimate can be prepared regarding the volume of media and area for which containment, treatment, or removal actions may be applied.

3.2 Applicable or Relevant and Appropriate Requirements (ARARs) ARARs can be divided into three general types. Chemical-specific ARARS set limits on concentrations of specific hazardous substances, pollutants and contaminants in the environment. Examples of these types of ARARs are drinking water standards and ambient water quality criteria. Location-specific ARARs set restrictions on certain activities based on their location (i.e. wetlands, floodplains, historic sites, etc). These ARARs generally apply to most alternatives as they are based on the location of the site. Finally, action-specific ARARs place restrictions on the technologies used for remedial action. The Resource Conservation and Recovery Act (RCRA) regulations for waste treatment, storage, and disposal are an example of such action-specific ARARs.

3.3 Identification and Screening of Technology Types and Process Options

The RA technologies will be selected based on their ability to reduce the risk to human health and the environment from exposure to COCs in environmental media. Based on the limited potential for exposure, remediation technologies do not need to have an immediate endpoint to be effective. However, faster-acting technologies will be favored to eliminate risk rapidly and cost effectively. Other factors, such as minimizing the potential impact to wetlands and the sustainability or “green” aspects of each technology will also be considered during the identification and screening process.

3.3.1 Identification and Screening of Technologies Technologies will be identified for additional consideration with input from USEPA representatives. The technologies previously identified will be included among others.



3.4 Development of Remedial Action Alternatives

The list of possible technology types will be assembled into a range of RA alternatives. The range of RA alternatives developed for soil may include, but will not be limited to: excavation and treatment alternatives, excavation and disposal alternatives, containment alternatives, and a no action or limited action alternative. In-situ alternatives also may be considered, if applicable. The range of alternatives developed for groundwater may include, but will not be limited to: extraction and treatment alternatives, extraction alternatives, in-situ treatment alternatives, monitored natural attenuation, and a no action or limited action alternative. The range of alternatives developed for sediment may include, but will not be limited to: excavation/dredging and treatment alternatives, excavation/dredging and disposal alternatives, containment alternatives and a no action or limited action alternative. The range of alternatives developed for surface water may include, but will not be limited to: collection and treatment alternatives, dewatering or surface diversion alternatives, or a no action or limited action alternative.



4. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES

After a set of RA alternatives providing overall protection of public health and welfare and the environment has been developed a detailed evaluation of each alternative and a comparison of the alternatives will be performed so that a recommendation for RA alternative implementation at the Site can be made.

4.1 Detailed Description and Assessment of Remedial Action Alternatives

Each RA alternative will be described and assessed for effectiveness, implementation, and cost in both the short and long term. The evaluation will consider the effectiveness of each alternative in protecting human health and the environment. The technical and administrative feasibility of constructing, operating and maintaining each RA alternative will be considered during the evaluation. The minimization of potential impact to wetlands and the sustainability or “green” aspects of each alternative will also be considered during this assessment process. Finally, the cost evaluation will include comparative estimates for RA alternatives so that cost decisions among alternatives will be sustained as the accuracy of cost estimates improve beyond the screening process, taking into account both capital and operations & maintenance cost (USEPA, 1988).

4.2 Comparative Analysis of Remedial Action Alternatives

After the RA alternatives have been described and individually assessed, a comparative analysis will be conducted and presented. The purpose of the comparative analysis is to identify the advantages and disadvantages of each RA alternative relative to one another.

4.3 Recommendation of Remedial Action Alternative and Conceptual Design Based on the detailed analysis and comparison of RA alternatives, CSI will provide a recommendation for implementation to address concerns in soil, groundwater, sediment, and surface water at the site. A conceptual design for implementation of the recommended alternative will be presented and may include the following: conceptual plan drawings, layouts, and cross sections to depict the various components of the RA alternative, descriptions of the equipment and processes used, as well as expected quantities and volumes of materials required, identification of additional data needs for final design, discussion of operation and maintenance requirements, institutional issues, cost, and estimated schedule for implementation.

4.4 Evaluation of Alternatives The evaluation of remedial alternatives is discussed in detail in Section 5 and follows the format outlined in 40 CFR § 300.430(e) (7). Each alternative will be



screened initially using three principle criteria: effectiveness, feasibility to implement and cost. Each remedial alternative that is retained following initial screening will be further evaluated using nine additional criteria, which include the following: Threshold Criteria 1. Overall Protection of Human Health and the Environment 2. Compliance with ARARs Primary Balancing Criteria 3. Long-term Effectiveness and Permanence 4. Reduction of Toxicity, Mobility, or Volume 5. Short-term Effectiveness 6. Feasibility to Implement 7. Cost Modifying Criteria 8. State/EPA Acceptance 9. Community Acceptance In addition to the prescribed nine criteria as outlined above, the sustainability of the remedial alternatives will also be considered during the screening process. The long-term energy consumption, emissions and other relevant factors will be considered when assessing the sustainability of the various alternatives. Green remediation technologies will be considered for each media type and used whenever practicable.



5 EVALUATION OF ALTERNATIVES

5.1 Overview In accordance with 40 CFR § 300.430(e) (7), the development of the remedial alternatives will be guided by the following initial screening criteria:

• Effectiveness – the ability of an alternative to eliminate or reduce risks to human health and the environment by reducing toxicity, mobility, and/or volume in a reasonable period of time;

• Feasibility to Implement – the capability of the alternative to be technically feasible given the availability of the technologies each alternative would employ; and

• Cost – the practicability of the alternative given the costs of construction and any long-term costs of operation and maintenance (O&M) activities.

The short- and long-term aspects of these factors will be considered during the remedial alternative selection process. Alternatives deemed to be significantly less implementable or more costly than comparably effective alternatives will be eliminated from consideration. After the selection of remedial alternatives, each alternative will be evaluated and compared using the nine evaluation criteria required by 40 CFR § 300.430(e)(9). A discussion of the criteria to be used to evaluate each alternative is provided below.

5.1.1 Threshold Criteria

Overall Protection of Human Health and the Environment Alternatives will be further evaluated based on their ability to protect human health and the environment in both the short- and long-term by eliminating, reducing, or controlling possible exposures to site related constituents at concentrations exceeding RAOs. Human health and ecological risk assessment study results will be considered to aid in determining which alternatives may be most protective of human health and the environment.

Compliance with ARARs

The ability of alternatives to meet all applicable and relevant federal, state, and local environmental requirements (ARARs) will be assessed for each alternative. The use of a waiver under 40 CFR § 300.430(f)(1)(ii)(C) will be considered, where applicable.



5.1.2 Primary Balancing Criteria

Long-term Effectiveness and Permanence The long-term effectiveness of the alternatives will be assessed along with the degree of certainty that the alternatives will prove successful. This will be evaluated by considering the magnitude of constituents remaining in affected environmental media upon conclusion of remedial activities and the adequacy and reliability of any control measures necessary to address the remaining constituents, if any.

Reduction of Toxicity, Mobility, or Volume The degree to which the alternative reduces toxicity, mobility, and/or volume will be assessed. The factors for consideration will include: the processes employed; the amount of constituents to be addressed; the degree of expected reduction of toxicity, mobility, and/or volume; the degree to which the treatment is irreversible or permanent; the type and quantities of any residual wastes, if any; and the degree to which remedy implementation reduces risks to human health or the environment.

Short-term Effectiveness

The short-term impacts will be evaluated based on the risks posed by the implementation of the alternative, including the potential impacts on workers, the community, and the environment during remedial activities, and the time until protection is achieved.

Feasibility to Implement

The ease or difficulty of implementing the alternative will be considered. The factors impacting this consideration include: technical feasibility, including difficulties and unknowns; administrative feasibility, including coordination with all parties and the time involved in obtaining approvals and permits; and the availability of services and materials necessary to implement the alternative.

Cost

Costs will be evaluated for each alternative. The cost evaluation will include capital costs, annual O&M costs, and the net present value of capital and O&M costs.

5.1.3 Modifying Criteria

State/EPA Acceptance State and/or EPA acceptance will be assessed upon receipt of any comments from EPA on the FS Report to be prepared and submitted and upon the previous acceptance of various RA alternatives by the regulatory agencies



Community Acceptance

Anticipated community concerns will be considered as part of the remedial alternative selection process, such as the timeframe required to meet RAOs, potential future uses of the Site, and the likelihood that implementation of the remedy would impact the community (e.g. any discharges to the environment). The EPA will address community comments during the public review process.

5.2 Sustainability As described in Section 4, in addition to the prescribed evaluation criteria, the sustainability of the remedial alternatives will also be considered during the screening process. Criteria including long-term energy consumption, emissions, and other relevant factors will be considered along with the other nine criteria when assessing the sustainability of the various alternatives. If possible, preference will be given to the more sustainable alternatives when recommendations are made, which will be noted in the FS report.



6. REFERENCES CSI Environmental, LLC, 2008. Focused Investigation Work Plan, Former Higgins Plant, Gibbstown, New Jersey, Appendix F Soils Management and Sampling Plans, May 2008. CSI Environmental, LLC, 2009. Interim Remedial Measures Report, Former Higgins Plant, Gibbstown, New Jersey, August 2009. ERM, Inc., Supplemental Remedial Investigation Report, Former Higgins Plant, Gibbstown, NJ, January 2003. USEPA, 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, Interim Final, August 2009.

FIGURES

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VICINITY PLAN Former Hercules Higgins Plant

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TABLES



TABLE 1 Proposed Feasibility Study Outline

1. INTRODUCTION 1.1 Purpose and Organization of Report 1.2 Background Information

1.2.1 Site Description

1.2.2 Site History 1.2.3 Nature and Extent of Contamination

1.2.4 Contaminant Fate and Transport

1.2.5 Baseline Risk Assessment

2. IDENTIFICATION AND SCREENING OF RETAINED TECHNOLOGIES 2.1 Overview 2.2 Remedial Action Objectives (RAOs)

2.2.1 Applicable or Relevant and Appropriate Requirements (ARARs)

2.2.2 Development of Remedial Goals for Affected Environmental Media 2.3 General Response Actions

2.3.1 Exposure Routes

2.3.2 Nature and Extent of Contamination

2.3.3 Preliminary Remediation Goals

2.3.4 ARARs 2.4 Identification and Screening of Technology Types and Process Options

2.4.1 Identification and Screening of Technologies

2.4.2 Evaluation of Alternatives 3. EVALUATION OF ALTERNATIVES 3.1 Overview



Table 1 Cont.

3.1.1 Threshold Criteria Overall Protection of Human Health and the Environment Compliance with ARARs

3.1.2 Primary Balancing Criteria

Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility or Volume Short-term Effectiveness Feasibility to Implement Cost

3.1.3 Modifying Criteria

State/EPA Acceptance Community Acceptance

3.1.4 Sustainability 3.2 No Action – Alternative 1 for Soil

3.2.1 Description of No Action Alternative

3.2.2 Evaluation of No Action Alternative

Threshold Criteria Overall Protection of Human Health and the Environment Compliance with ARARs

Primary Balancing Criteria


Modifying Criteria


Sustainability 3.3 Excavation – Alternative 2 for Soil

3.3.1 Description of Excavation

3.3.2 Evaluation of Excavation




Table 1 Cont.

Primary Balancing Criteria Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility or Volume Short-term Effectiveness Feasibility to Implement Cost

Modifying Criteria


Sustainability 3.4 In-situ Treatment – Alternative 3 for Soil

3.4.1 Description of In-situ Treatment

3.4.2 Evaluation of In-situ Treatment

Bench Scale Treatability or Pilot Study for Treatment Alternatives




Modifying Criteria


Sustainability

3.5 Thermal Treatment – Alternative 4 for Soil

3.5.1 Description of Thermal Treatment

3.5.2 Evaluation of Thermal Treatment





Table 1 Cont.

Primary Balancing Criteria Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility or Volume Short-term Effectiveness Feasibility to Implement Cost

Modifying Criteria


Sustainability 3.6 Landfill Disposal – Alternative 5 for Soil

3.6.1 Description of Landfill Disposal

3.6.2 Evaluation of Landfill Disposal




Modifying Criteria


Sustainability

3.7 Containment Cap – Alternative 6 for Soil

3.7.1 Description of Containment Cap

3.7.2 Evaluation of Containment Cap

Threshold Criteria Overall Protection of Human Health and the Environme nt Compliance with ARARs


Long-term Effectiveness and Permanence Reduction of Toxicity, Mobility or Volume



Table 1 Cont.

Short-term Effectiveness Feasibility to Implement Cost

Modifying Criteria


Sustainability 3.8 Institutional and Site Controls– Alternative 7 for Soil

3.8.1 Description of Institutional and Site Controls

3.8.2 Evaluation of Institutional and Site Controls




Modifying Criteria


Sustainability

3.9 No Action – Alternative 1 for Groundwater








Table 1 Cont.

Modifying Criteria State/EPA Acceptance Community Acceptance

Sustainability 3.10 Monitored Natural Attenuation (MNA)-Alternative 2 for Groundwater

3.10.1 Description of MNA

3.10.2 Evaluation of MNA




Modifying Criteria


Sustainability 3.11 Containment – Alternative 3 for Groundwater

3.11.1 Description of Containment

3.11.2 Evaluation of Containment

Threshold Criteria

Overall Protection of Human Health and the Environment Compliance with ARARs



Modifying Criteria




Table 1 Cont.

Sustainability

3.12 Pump and Treat – Alternative 4 for Groundwater 3.12.1 Description of Pump and Treat 3.12.2 Evaluation of Pump and Treat

Bench Scale Treatability or Pilot Study for Treatment Alternatives Threshold Criteria




Modifying Criteria


Sustainability

3.13 In-situ Treatment– Alternative 5 for Groundwater 3.13.1 Description of In-situ Treatment 3.13.2 Evaluation of In-situ Treatment

Bench Scale Treatability or Pilot Study for Treatment Alternatives Threshold Criteria




Modifying Criteria




Table 1 Cont.

Sustainability 3.14 Institutional and Site Controls– Alternative 6 for Groundwater






Modifying Criteria


Sustainability

3.15 No Action – Alternative 1 for Sediment






Modifying Criteria


Sustainability



Table 1 Cont.

3.16 Excavation/Dredging and On-site Treatment– Alternative 2 for Sediment

3.16.1 Description of Excavation/Dredging and On-site Treatment

3.16.2 Evaluation of Excavation/Dredging and On-site Treatment





Modifying Criteria


Sustainability 3.17 In-Situ Treatment – Alternative 3 for Sediment

3.17.1 Description of In-situ Treatment

3.17.2 Evaluation of In-situ Treatment





Modifying Criteria


Sustainability



Table 1 Cont.

3.18 Excavation/Dredging and Landfill Disposal – Alternative 4 for Sediment

3.18.1 Description of Excavation/Dredging and Landfill Disposal

3.18.2 Evaluation of Excavation/Dredging and Landfill Disposal




Modifying Criteria


Sustainability

3.19 Containment: In Situ Cap – Alternative 5 for Sediment

3.19.1 Description of In Situ Containment Cap

3.19.2 Evaluation of In Situ Containment Cap




Modifying Criteria


Sustainability

3.20 Institutional and Site Controls – Alternative 6 for Sediment




Table 1 Cont.





Modifying Criteria


Sustainability

3.21 No Action – Alternative 1 for Surface Water






Modifying Criteria


Sustainability

3.22 Pump and Treat– Alternative 2 for Surface Water

3.22.1 Description of Pump and Treat 3.22.2 Evaluation of Pump and Treat




Table 1 Cont.




Modifying Criteria


Sustainability 3.23 Institutional and Site Controls– Alternative 3 for Surface Water






Modifying Criteria


Sustainability 4. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 4.1 Overview 4.2 Remedial Alternative Matrix Discussion (Tabular Comparison of Nine Criteria

Evaluation) 4.3 Comparative Analysis Conclusion



Table 1 Cont.

5. REMEDIAL ALTERNATIVES SELECTION AND IMPLEMENTATION 5.1 Remedial Alternative Selection 5.2 ROD Modification Process (if necessary) 5.3 Additional Pilot/Bench Scale Studies 5.4 Proposed Schedule 6. REFERENCES

feasibility study work plan for the hercules …

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