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SDMS Document 112016 Five-Year Review Report Vineland Chemical Company Superfund Site Vineland Township Cumberland County, New Jersey Prepared by: U.S. Environmental Protection Agency Region 2 New York, New York September 2011 Page 1 of 68

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Page 1: FIVE-YEAR REVIEW REPORT, VINELAND CHEMICAL COMPANY ... · five-year review for the Vineland Chemical Company Superfund site in Vineland, New Jersey. This five-year review is a discretionary

SDMS Document

112016

Five-Year Review Report

Vineland Chemical Company Superfund Site Vineland Township

Cumberland County, New Jersey

Prepared by:

U.S. Environmental Protection Agency Region 2

New York, New York

September 2011

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Table of Contents ^P

List of Figures iv List of Tables iv List of Acronyms v Executive Summary vii Five-Year Review Summary Form xii 1.0 Introduction ..1 2.0 Site Chronology 2 3.0 Background 3

3.1 Site Location 3 3.2 Physical Characteristics 3

3.2.1 Regional Geology and Hydrogeology 4 3.2.2 Site Geology and Hydrogeology 4

3.3 Land and Resource Use 4 3.4 History of Contamination and Initial Response 5 3.5 Basis for Taking Action 8

4.0 Remedial Actions 9 4.1 Operable Unit 1 - Plant Site Source Control - Site Soils Remediation 9

4.1.1 Remedy Selection (OU-1) 9 4.1.2 Remedy Implementation (OU-1) 10 4.1.3 Institutional Controls (OU-1) 11 4.1.4 Current Status (OU-1) 12

4.2 Operable Unit 2 - Plant Site Management of Migration 12 ^P 4.2.1 Remedy Selection (OU-2) 12 4.2.2 Remedy Implementation (OU-2) 12 4.2.3 System Operations/Operation and Maintenance (O&M) (OU-2) 15 4.2.4 Institutional Controls (OU-2) 17 4.2.5 Current Status (OU-2) 18

4.3 Operable Unit 3 - River Areas 23 4.3.1 Remedy Selection (OU-3) 23 4.3.2 Remedy Implementation (OU-3) 23 4.3.3 Institutional Controls (OU-3) 24 4.3.4 Current Status (OU-3) 24

4.4 Operable Unit 4 - Unit Lake Sediments 26 4.4.1 Remedy Selection (OU-4) 26 4.4.2 Remedy Implementation (OU-4) 26 4.4.3 Institutional Controls (OU-4) 27 4.4.4 Current Status (OU-4) 27

5.0 Five-Year Review Process 28 5.1 Administrative Components 28 5.2 Community Involvement 28 5.2 Data Review 28 5.3 Site Inspection 32 5.4 Interviews 33 •

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6.0 Technical Assessment 33 6.1 Question A: Is the remedy ftinctioning as intended by the decision documents? 33

Institutional Controls 34 6.2 Question B\ Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? 34 6.3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? 35

7.0 Issues and Recommendations 36 8.0 Protectiveness Statements 37 9.0 Next Review 37

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List of Figures

Figure 1 - Site Location Figure 2 - Groundwater Treatment Plant - Treatment plant as currently operated Figure 2-1 - Sampling Locations in Vicinity of Vineland Chemical Superfund Site,

April/May 2010 Figure 3 - Locations of OU3 Phases I-IV Figure 4 - Recovery and Monitoring Well Locations Figure 5 - Maximum Total Arsenic Concentration - Shallow Monitoring Wells Figure 6 - Maximum Total Arsenic Concentration - Mid-Depth Monitoring Wells Figure 7 - Arsenic Concentrations in Recovery Wells 1-3 Starting 2008 Figure 8 - Arsenic Concentrations in Recovery Wells 4-8 Starting 2008 Figure 9 - Arsenic Concentrations in Recovery Wells 9A-13 Starting 2008 Figure 10 - CEA-WRA Boundary Map

List of Tables

Table 1 - Site Chronology Table 2 - Annual OU-2 System Operations/O&M Costs Table 3 - Issues Table 4 - RSE Recommendations and Follow-Up Actions Table 5 - Document Review

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List of Acronyms

ARARs Applicable or Relevant and Appropriate Requirements ACL Alternate Concentration Limit As+5 Arsenate As+3 Arsenite BDAT Best Demonstrative Available Technology bgs Below Ground Surface CEA-WRA Classification Exception Area - Well Restriction Area CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations DAF Dissolved Air Flotation DI Design Investigation °C Degrees Celsius °F Degrees Fahrenheit DPCC Discharge Prevention Contaminant and Containment Measure EPIC Environmental Photographic Information Center ESD Explanation of Significant Differences FeCl3 Ferric Chloride FYR Five-Year Review gpm gallons per minute H202 Hydrogen Peroxide HI Hazard Index KMn04 Potassium Permanganate LDRs Land Disposal Restrictions MCL Maximum Contaminant Level mgd million gallons per day MSL Mean Sea Level mg/kg milligrams per kilogram Pg/L micrograms per liter NaOH Sodium Hydroxide NCP National Contingency Plan NJDEP New Jersey Department of Environmental Protection NPDES National Pollutant Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance ODI Optional Design Investigation ORP Oxidation Reduction Potential OSWER Office of Solid Waste and Emergency Response OU Operable Unit PI Plant Investigation PWTPC Post Water Treatment Plant Construction PPm parts per million (mg/kg) Ppb parts per billion (pg/kg) PRP Potentially Responsible Party

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PVC Polyvinyl Chloride RAGS Risk Assessment Guidance for Superfund Sites RAOs Remedial Action Objectives RCRA Resource Conservation and Recovery Act RfD Reference Dose RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study RME Reasonable Maximum Exposure ROD Record of Decision RPM Remedial Project Manager RSE Remedial System Evaluation SDWA Safe Drinking Water Act TBC To Be Considered TCE Trichloroethylene TCLP Toxicity Characteristic Leaching Procedure tph tons per hour TWA Treatment Works Authorization USACE United States Army Corps of Engineers EPA United States Environmental Protection Agency WTPC Water Treatment Plant Construction

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Executive Summary

The United States Environmental Protection Agency (EPA) Region 2 has conducted the first five-year review for the Vineland Chemical Company Superfund site in Vineland, New Jersey. This five-year review is a discretionary review because the remedies, as selected in the Record of decision, once fully implemented for all contaminated media, will not result in hazardous substances remaining on the site above health-based levels, and the trigger for this policy five-year review, the Preliminary Close-Out Report (PCOR), has not yet been signed. This review focuses on the Operable Unit 1 (OU-1), OU-2 and OU-3 remedial actions since construction activities have been initiated and/or completed for each of these OUs. The purpose of this five-year review is to determine whether the remedial actions being implemented at the site are, or are expected to be, protective of human health and the environment. The methods, findings, and conclusions of the review are documented in this report. In addition, this report summarizes issues identified during the review and includes recommendations and follow-up actions for them.

The Vineland Chemical Company plant site is located in a residential/industrial area in the northwest comer of the City of Vineland in Cumberland County, New Jersey. The plant site location is shown in Figure 1. Contaminated media include plant site soils, the underlying groundwater, approximately seven miles of stream/river corridor, and downstream Union Lake.

Vineland Chemical Company began manufacturing organic arsenical herbicides and fungicides at the Vineland, New Jersey site in approximately 1949. In addition to arsenical herbicides, the company also produced cadmium-based herbicides and used other metals, such as lead and mercury. Reportedly, in later years, the company produced only industrial biocides through a small-scale blending operation. All site production activities ceased in 1994. Based on information presented in the EPA Record of Decision (ROD) for the Vineland site, the herbicide manufacturing process reportedly produced approximately 1,107 tons of waste by-product salts each year, which were improperly stored until 1978. The improper storage of these salts on the plant property led to arsenic contamination in the soil and groundwater at the Plant Site, and arsenic contamination in surface waters and soils/sediments downstream from the plant.

The site was placed on the National Priorities List in 1984. Removal and remedial actions completed to date have removed/eliminated source materials including contaminated buildings and plant site soil contamination to a depth of 1-2 feet below the water table in most cases. Extraction and treatment operations have greatly reduced the average concentration of arsenic in groundwater, and significant amounts of sediment contamination have also been addressed.

Remedial Investigation and Feasibility Study Considerations

A Remedial Investigation and Feasibility Study (RI/FS) was conducted to identify the types, quantities, and locations of contaminants, and to develop ways to correct the problems posed by the contaminants. The Rl/FS completed in June 1989 indicated the following contamination problems:

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Vineland Chemical Plant Site

• On-site soils above the water table were substantially contaminated with arsenic in certain localized areas.

• Arsenic waste salts were piled into chicken coops and unlined lagoons, and were also stored in on-site factory buildings.

Vineland Chemical Groundwater

• Residuals beneath the water table were impacted by arsenic leaching form the plant site soils. • The shallow groundwater beneath the site was contaminated with arsenic, and to a lesser

degree with cadmium and trichloroethylene (TCE). However, recent analysis of extraction well groundwater indicates cadmium and TCE are non-detect.

River Areas

• Sediments and surface water in the Blackwater Branch had elevated arsenic concentrations downstream of the plant site, while having low to non-detectable levels upstream of the plant.

• Sediments and surface water in the Maurice River below, but not above, its confluence with the Blackwater Branch had elevated arsenic concentrations.

• An estimated six metric tons of arsenic entered the Blackwater Branch in 1987 due to arsenic-contaminated groundwater from the site.

Union Lake

• Arsenic contamination in sediment was widespread in much of the lake. Contamination is surficial with highly variable concentrations (undetected to elevated levels). Surface water samples only had elevated arsenic concentrations when agitated (mixed with contaminated sediment).

Operable Unit Descriptions and Status

Based on the RI/FS findings, EPA implemented a number of response actions that included securing the site with a perimeter fence and removing thousands of gallons of arsenic solutions and demolition of eight buildings.

A ROD for the site was signed in 1989 and determined that actual or threatened releases of hazardous substances from the site, if not addressed by implementing the response actions selected in the ROD, may present an existing or potential threat to public health, welfare or the environment. The ROD divided the site into four areas or operable units (OUs). A brief description and current status of each of the OUs is provided below:

The OU-1 Remedy (Plant Site Source Control) involved the excavation of arsenic-contaminated soil from five on-site source areas. Approximately 400,000 tons of soil were excavated from the surface to several feet below the top of the groundwater and treated via an on-site soil washing

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facility to below 20 milligrams per kilogram (mg/kg) total arsenic. The highly contaminated Blackwater Branch stream corridor and flood plain soils/sediments adjacent to the main plant site were soil washed along with the plant site soils. In addition, early actions resulted in the removal of arsenic-contaminated debris, exterior plant storage pad areas, and the contaminated cement floors of all on-site factory buildings. Engineering controls including fencing, air monitoring, and drainage controls were in place to prevent worker and off-site receptor exposure.

The OU-1 remedy excavation work was completed in December 2007, and the risk posed by direct exposure to arsenic-contaminated soils was substantially reduced. It also resulted in a significant reduction of source material contributing to arsenic contamination in the groundwater. However, some source material may remain in the saturated soils at depth.

The OU-2 Remedy (Groundwater/Plant Site Management of Migration) includes a groundwater pumping/extraction system and an on-site groundwater treatment plant. The groundwater remedy has two objectives — to minimize the flow of arsenic-contaminated groundwater to the Blackwater Branch and to restore the groundwater. The remedy selected and constructed to achieve these objectives includes a groundwater pumping system consisting of 16 recovery wells. The wells are designed to capture the arsenic-contaminated groundwater before it can discharge to Blackwater Branch. The water pumped by the extraction system is treated in an on-site water treatment plant prior to discharge to the Blackwater Branch.

The OU-3 Remedy (River Areas Sediments) addresses exposed and submerged arsenic-contaminated sediments in the Blackwater Branch adjacent to and downstream of the Vineland Chemical Company plant site and, in the future after further monitoring and evaluation, may also include the sediments in the Maurice River. The remedy involves excavation of exposed and submerged arsenic-contaminated sediments from the stream corridor and floodplain of Blackwater Branch. After excavation, the course-grained sediments were processed through the soil washing facility and re-deposited in the excavated areas. The fine-grained material not amenable to soil washing was high-pile dried and disposed of at a permitted off-site facility.

The OU-3 Blackwater Branch remediation from the plant site to near the confluence with the Maurice River is being implemented in four phases. Clean-water stream diversions are constructed within each phase to allow for the removal of contaminated sediment under controlled surface water management conditions and prevent the discharge of contaminated sediment into the Maurice River. Sequencing the work in phases accommodates stream diversion roadway crossings and supports schedule and budget management. The first phase encompassing the area east of Mill Road is complete. Sediment excavation and backfilling in the segments from Mill Road to Route 55 and Route 55 to the Maurice River parkway have been completed and restoration activities are ongoing. The final segment from Maurice River Parkway to near the confluence of the Maurice River and the remaining preliminary restoration activities are planned to be completed by 2014. This effort will be followed by a three-year period of natural river flushing of sediments in the Maurice River. After this period of flushing, a decision will be made regarding the extent of remedial action for the Maurice River. Initially, the river flushing period was to begin after stopping the flow of contaminated groundwater from the Vineland Chemical Company plant site. However, a remedial strategy approved by EPA Headquarters was implemented to sequence site activities to manage the highly contaminated

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sediments of Blackwater Branch which served as a source of contamination to the river and local groundwater, prior to evaluating the effectiveness of flushing the Maurice River.

The OU-4 Remedy (Union Lake Sediments) is identified in the ROD as an interim remedy consisting of excavation and treatment of arsenic-contaminated sediments around the periphery of Union Lake after remediation of the upstream river sediments. This remedy has not yet been implemented.

Five-Year Review

The five-year review (FYR) site inspection took place on March 15, 2010. During the inspection, the groundwater treatment facility and extraction system were inspected. Findings from the five-year review are summarized below:

• The maximum contaminant level (MCL) for arsenic has changed since signing of the 1989 ROD. The federal drinking water MCL has been reduced from 50 micrograms per liter (pg/L) to 10 pg/L; the state drinking water MCL has been reduced to 5 ug/L; and a state groundwater quality standard has been established at 3 pg/L (the practical quantitation limit). This change may not affect the approach to achieve the remedial objectives but may extend the length of time before the site will be available for unlimited use and unrestricted exposure to the groundwater.

• Arsenic source material or residual contamination remaining in the saturated soils at depth on the plant site may also affect the achievement of the groundwater restoration objectives and further extend the treatment time period.

• A Classification Exception Area with a Well Restriction Area (CEA-WRA) has been in place since 2007; this institutional control is implemented by the State of New Jersey to provide notice that constituent standards for a given aquifer are not being met, and reduces or eliminates the risk posed by the groundwater by ensuring there are no completed exposure pathways.

• The groundwater pumping/extraction system is effectively reducing surface water arsenic levels in Blackwater Branch to well below the standard of 50 pg/L identified in the ROD and, in most cases, below 9 pg/L (detection level of the water samples).

• The groundwater treatment plant has been effectively treating the groundwater below the ROD goal of 50 ug/L, typically below 10-15 ug/L.

There is a concern about an area of contamination beyond the limits of Blackwater Branch northwest of the site. While no known sources have been identified in this area, well-effect and/or local geochemistry, the proximity to contaminated sediments, the presence of unknown pumping wells, or residual plume contamination may be contributing to elevated arsenic levels in this area. The limits of this contamination are the subject of ongoing characterization by project scientists. This effort will include the installation of new

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monitoring wells, updating the site groundwater model, and contacting local businesses to ensure that potentially unknown pumping locations are not negatively affecting containment of the plume. If necessary, new extraction wells will be installed in the next few years to address contamination in this area.

• A number of groundwater treatment plant optimizations have been conducted and a Remedial System Evaluation (RSE) was completed for EPA by the U.S. Army Corps of Engineers in March 2011. Based on the RSE, a site-wide soil and water geochemistry evaluation is being conducted to better understand arsenic/media interactions, well plaque and near-well impacts on water quality data, and the potential for utilizing treatment enhancements including arsenic in-situ immobilization to expedite the cleanup process. The optimization efforts will also focus on attainment of the state's newly established groundwater quality standard of 3 ug/L.

Protectiveness

Based on the findings of the five-year review, significant progress has been made in reducing public exposure to arsenic contamination associated with the site. Protectiveness determinations for the three operable unit actions are as follows:

OU-1: short-term protective

The remedy for OU-1 (plant site soils) currently protects human health and the environment because contaminated soils above the water table have been excavated and treated and the direct contact exposure pathway has been eliminated. However, in order for the remedy to be protective in the long-term, arsenic source material or residual contamination in saturated soils below the water table needs to be addressed.

OU-2: short-term protective

The remedy for OU-2 (groundwater) currently protects human health and the environment because the extraction and treatment system prevents the off-site migration of arsenic-contaminated groundwater and no one in the area is using the water for potable purposes. In order for the remedy to be protective in the long-term, the remaining arsenic contamination in saturated soils needs to be addressed.

OU-2: will be protective

The remedy for OU-3 (Blackwater Branch and Maurice River sediments) is expected to be protective of human health and the environment upon completion and, in the interim, exposure pathways that could result in unacceptable risks are being controlled through site security, fishing bans, and restriction of recreational beach use.

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Five-Year Review Summary Form

sm: I D I M I I I C A R I O \ Site name (from WasteLAN): Vineland Chemical Company EPA ID (from WasteLAN)-. NJD002385664 Region: 2 | State: NJ 1 City/County: Vineland/Cumberland" S f T L S f I 1 L S

NPL status: s f Final • Deleted • Other (specify) Remediation status (choose all that apply): • Under Construction sf Operating • Complete

Site-Wide FYR • YES VNO Construction completion date: 06 / 04 / 2001 * *Date at which GWTP was operational

Has site been put into reuse? • YES VNO Ri:\ u:\\ STATI s

Lead agency: V EPA • State • Tribe • Other Federal Agency Author name: Nica Klaber and Ronald Naman Author title: Remedial Project Manager

Author affiliation: U.S. EPA

Review period: 04/13/ 2006 to 04 /13 / 2011 Date(s) of site inspection: 03 /15 / 2011 Type of review:

V Post-SARA • Pre-SARA • NPL-Removal only • Non-NPL Remedial Action Site • NPL State/Tribe-lead VRegional Discretion

Review number: sf 1 (first) • 2 (second) • 3 (third) • Other (specify) Triggering action: • Actual RA On-site Construction at OU # i • Construction Completion i sfOther (specify) - Discretionary - No Trigger Action

Actual RA Start at OU# Previous Five-Year Review Report

Triggering action date (from WasteLAN)'. Due date (fiveyears after triggering action date)'.

Does the report include recommendation(s) and follow-up action(s)? Vyes • no

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

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Issues

There appears to be a continuing source of arsenic contamination in saturated soils beneath the plant area.

The groundwater MCL for arsenic has changed since the signing of the ROD.

There may be a small area of groundwater contamination not being captured by the existing extraction system.

The arsenic geochemistry (complexation/adsorption/desorption) may be affecting groundwater quality data.

Groundwater institutional controls were established based on the MCL at the time of the ROD.

Recommendations

Characterize the arsenic source material or residual contamination in the saturated soils at the site and evaluate alternatives to address any such contamination, (e.g., mobilization/immobilization).

Evaluate and modify, as appropriate, the cleanup goals for groundwater and surface water in light of new federal and state standards.

Evaluate and implement enhancements to the groundwater extraction and treatment system to achieve any new cleanup goals to the extent practicable.

Update the groundwater delineation capture zone modeling northwest of Mill Road/Blackwater Branch and determine if and where additional off-site extraction well(s) may be needed.

Re-evaluate the recovery well network based on new data from the delineation northwest of Mill Road/ Blackwater Branch and information on unknown off-site pumping wells.

Continue evaluation/optimization of the groundwater monitoring network.

Evaluate the arsenic geochemistry and impacts on groundwater quality data.

Update the 2007 CEA-WRA to ensure that it extends beyond the limits of the plume/contaminated areas a distance equal to the maximum expected radius of influence from an off-site pumping well, if present.

Develop and initiate a sediment sampling plan for the Maurice River to assess the fate, transport and recovery of sediments considering the removal of contaminated sediments in Blackwater Branch and the ongoing extraction and treatment of groundwater.

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Protectiveness Statements!

The remedy for plant site soils (OU-1) currently protects human health and the environment because contaminated soils have been excavated and treated to the water table and the direct contact pathway has been eliminated. In order for the remedy to be protective in the long-term, arsenic source material or residual contamination in saturated soils below the water table needs to be addressed.

The remedy for groundwater (OU-2) currently protects human health and the environment because the extraction and treatment system prevents the off-site migration of arsenic-contaminated groundwater and no one in the area is using the water for potable purposes. In order for the remedy to be protective in the long-term, the remaining arsenic contamination in saturated soils needs to be addressed.

The remedy for the Blackwater Branch and Maurice River (OU-3) is expected to be protective of human health and the environment upon completion and, in the interim, exposure pathways that could result in unacceptable risks are being controlled through site security, fishing bans, and restriction of recreational beach use.

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1.0 Introduction

This is the first five-year review (FYR) for the Vineland Chemical Company site, located in Vineland, Cumberland County, New Jersey. The review was conducted by the Environmental Protection Agency (EPA) team including Remedial Project Managers (RPMs) Nica Klaber and Ronald Naman, along with Michael Sivak (Risk Assessor), Ed Modica (Hydrologist), Mindy Pensak (Ecological Risk Assessor) and a team from the United States Army Corps of Engineers (USACE) Philadelphia District. The five-year review was conducted pursuant to Section 121 (c) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. §9601 et seq. and 40 CFR 300.430(f)(4)(ii), and in accordance with the Comprehensive Five-Year Review Guidance, Office of Solid Waste and Emergency Response (OSWER) Directive 9355.7-03B-P (June 2001).

The purpose of a five-year review is to evaluate the implementation and performance of a remedy in order to determine if the remedy is or will be protective of human health and the environment. Protectiveness is generally defined in the National Contingency Plan (NCP) by the risk range and the hazard index (HI). Evaluation of the remedy and the determination of protectiveness should be based on and sufficiently supported by data and observations.

Remediation at the Vineland Chemical Company site is being addressed in four discrete phases or operable units (OUs): Operable Unit One (OU-1) - Plant Site Source Control, OU-2 -Groundwater/Plant Site Management of Migration, OU-3 - River Areas Sediments (Blackwater Branch and Maurice River), and OU-4 - Union Lake Sediments. A description of each of the OUs and their current status is provided in Section 4 of this report.

This five-year review is being conducted as a discretionary review. Actions at OU-1, OU-2 and OU-3 are being evaluated in this review. OU-4 is not subject to this review.

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2.0 Site Chronology

TABLE 1: Chronology of Site Events ou EVENT DATE 00 DISCOVERY 12/01/1966 00 PRELIMINARY ASSESSMENT 11/01/1979 00 SITE INSPECTION 09/01/1983 00 PROPOSAL TO National Priorities List (NPL) 09/08/1983 00 NPL RP SEARCH 11/15/1983 00 FINAL LISTING ON NPL 09/21/1984 01 COMBINED RI/FS 09/28/1989 01 RECORD OF DECISION 09/28/1989 00 REMOVAL 06/18/1992 00 REMOVAL 03/25/1994 05 REMEDIAL DESIGN 09/26/1994 00 REMOVAL 03/20/1995 05 REMEDIAL ACTION 09/28/1995 02 REMEDIAL DESIGN 10/31/1996 01 EXPLANATION OF SIGNIFICANT DIFFERENCES 06/30/1997 01 REMEDIAL DESIGN 04/13/2000 00 PPA ASSESSMENT 03/29/2001 02 REMEDIAL ACTION 06/04/2001 01 EXPLANATION OF SIGNIFICANT DIFFERENCES 09/10/2001 01 REMEDIAL ACTION Start 05/25/2000 02 LONG-TERM RESPONSE ACTION Start 06/04/2001 03 REMEDIAL DESIGN Start 04/04/2005

00 CLASSIFICATION EXCEPTION AREA- WELL RESTRICTION AREA (CEA-WRA) Start 05/01/2007

01 COMPLETION OF PLANT SITE EXCAVATION WORK AND SOIL PROCESSING 12/20/2007

03 COMPLETION OF CONTAMINATED SEDIMENT 10/31/2009 03 EXCAVATION TO ROUTE 55 10/31/2009

00 REMEDIATION SYSTEM EVALUATION 03/11/2011

00 - Sitewide; 01 - Plant Site Source Control; 02 - Groundwater/ Migration Management; 03 - River Areas Sediments; 04 - Union Lake Sediments; 05 - Building Demolition

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3.0 Background

3.1 Site Location

The Vineland Chemical Company plant site is located in a residential/industrial area in the northwest comer of the City of Vineland in Cumberland County, New Jersey. The plant location is shown on Figure 1.

3.2 Physical Characteristics

The Vineland Chemical Company site is essentially a level plain, sloping from northwest to southeast with topographic variations from 60 to 80 feet above mean sea level (MSL) near the former plant site to just below 30 feet MSL near Union Lake. Soils in the general area of the site are marine deposits.

The Blackwater Branch of the Maurice River flows northeast to southwest, in proximity to, and partially through, the site itself. A floodplain lies immediately adjacent to the Blackwater Branch along the entire length of the tributary extending to the Maurice River. According to officials of the City of Vineland, the Blackwater Branch is not currently used for recreational purposes. The Maurice River flows in a southerly direction approximately six miles to its confluence with Union Lake. A broad floodplain also borders the Maurice River.

A city park is located approximately one-half mile downstream of the confluence of the Blackwater Branch and the Maurice River at the Almond Road bridge. The swimming area here was closed by the New Jersey Department of Environmental Protection (NJDEP) as a result of arsenic contamination, but was reopened in June 1988. The city park was closed during the summer season of 2010 due to elevated levels of fecal colifbrm in the water and the lack of funding for recreational security/safety personnel. Beach and boating recreation areas are present at Union Lake. The City of Millville beach areas located along Union Lake have been closed for the past two summer seasons due to elevated fecal coliform levels and funding issues.

Available climatological data were obtained from cooperative weather stations, maintained by the National Weather Service, located in Vineland (precipitation and wind) and Bridgeton (temperature). The Vineland station had accumulated data since 1885, while the Bridgeton station had data dating back to 1894.

Vineland receives approximately 45 inches of rainfall per year. Monthly averages range from 3.46 inches in April to 5.21 inches in August. No temperature data are available for Vineland proper, but Bridgeton (12 miles west - southwest of Vineland) exhibits a mean annual temperature of 12.6 degrees Celsius (°C). The mean maximum and minimum annual temperatures are 18.3 °C and 7°C, respectively.

Although detailed information on wind direction is not available for the site, from October through April, the predominant wind direction is from the northwest. From May through

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August, the dominant direction is out of the southwest; during September, the wind is from the southeast.

3.2.1 Regional Geology and Hydrogeology

The Vineland Chemical Company site is located in the Atlantic Coastal Plain physiographic province. The area is characterized geologically by a thick sequence of Cretaceous to Recent age sediment (sand, gravel, silt, and clay) which overlies the Precambrian bedrock basement. The bedrock surface is inclined gently toward the southeast. The sediment consists primarily of marine and near-shore fluvial elastics and forms a stratigraphic wedge estimated to be from 2,500 feet thick in the northwestern part of the county to 4,500 feet thick in the southeastern part of the county (Walker, 1983).

The basic structural framework of the coastal plain is dominated by the southeast dip of the basement bedrock surface. The basement rock is believed to be primarily a Precambrian metamorphic complex which has been eroded to a relatively flat surface, then tilted to the southeast. The bedrock gradient or dip is approximately 100 feet per mile (approximately one degree).

3.2.2 Site Geology and Hydrogeology

The Vineland Chemical Company site is underlain by the sands of the Cohansey Formation, which locally are interbedded with thin silt and clay beds. Four informal stratigraphic units (from top to bottom: the "Upper Sand", "Banded Zone", "Middle Sand", and "Lower Sand") have been defined in the Draft Remedial Investigation Report and the Draft Optional Design Investigation Report (Ebasco, 1988 and 1992, respectively). These unit subdivisions are based on sample descriptions and borehole gamma logs. Split-spoon samples, obtained at two to five foot intervals, provided discrete sampling points throughout the boreholes, while the gamma logs provided a continuous stratigraphic record of the borehole walls to help identify geologic contacts and to establish a correlation between the boreholes. The sediments are grouped on the basis of overall similarities, but they are characterized by variability, both in samples and gamma response. They do not represent continuous, homogeneous, predictable units.

The Upper Sand strata, where the groundwater contamination is of concern, consists of well-sorted, typically light brown, sand beds that range in thickness from 40 feet in the northwestern part of the site to 80 feet in the southeastern part of the site. The Upper Sand is underlain by the Banded Zone that ranges in thickness from 13 to 26 feet, and is thickest in the northwestern part of the site. The Banded Zone consists of interbedded sand, silt, and clay beds that separate the well-sorted Upper Sand from the underlying Middle Sand.

3.3 Land and Resource Use

The site is located in the northwest sector of the City of Vineland entirely within a designated 1 -2 (General Industrial) zone. The site is bordered on the northeast, east and south by an R-3 (medium to low density residential) zone; on the north by an A (agricultural) zone; and on the west by North Mill Road and a W (woodlands) zone.

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The area around the site is seen by the City of Vineland as having limited potential for future residential development. However, commercial/industrial development is expected to increase in the future. A major catalyst for future commercial/industrial development in this area is the completion of New Jersey State Route 55. This major intrastate artery is located near the western border of Vineland and connects the Vineland-Millville area with the Philadelphia-Camden region.

The city is currently served by New Jersey Routes 47 and 55, and secondary routes 555, 540 and 552. These routes connect with other major and minor arterials in, and near, Vineland to provide surface transportation links to other major north-south and east-west transportation corridors.

Rail service in the area is provided by Conrail and is limited to freight service only. Local air service is provided by the Millville Municipal Airport in Millville, approximately 10 miles to the south.

3.4 History of Contamination and Initial Response

Vineland Chemical Company began manufacturing organic arsenical herbicides and fungicides at the Vineland, New Jersey site in approximately 1949. In addition to arsenical herbicides, the company also produced cadmium-based herbicides and used other inorganics such as lead and mercury. In later years, the company reportedly produced only industrial biocides through a small-scale blending operation. All site production activities ceased in 1994. As described in the Record of Decision (ROD) for the Vineland site, the herbicide manufacturing process reportedly produced approximately 1,107 tons of waste by-product salts each year, which were improperly stored until 1978. The improper storage of these salts on the plant property led to arsenic contamination in the soil and groundwater at the plant site; arsenic contamination has been detected in surface waters and soils/sediments as far as 36 miles downstream from the plant.

As early as 1966, the New Jersey Department of Health observed Vineland Chemical Company discharging untreated wastewater with elevated arsenic concentrations into the unlined lagoons. An unknown quantity of arsenic rapidly infiltrated to the groundwater from the lagoons. On February 8, 1971, Vineland Chemical was ordered to provide industrial wastewater treatment and/or disposal facilities. The wastewater treatment works did not become operational until March 1980.

Waste salts from the herbicide production process were stored on-site in uncontrolled piles on the soil in Lagoon LL-2 (see Figure 2), which was unlined at the time, and in abandoned chicken coops on the plant property. The storage of salts in piles was observed in April 1970 and in the coops in April 1973. It was not until 1978, after numerous court orders, that the salts were containerized and removed. These salts reportedly contained one to two percent arsenic based on a Resource Conservation and Recovery Act (RCRA) Part B Permit Application, 1980. Since these salts have a high solubility, precipitation contacting these piles rapidly dissolved the salts and carried an unknown quantity of arsenic into the groundwater.

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Between 1975 and 1976, Vineland Chemical was "fixating" the waste salts for disposal at the Kin-Buc Landfill. The process involved mixing the dried salts with ferric chloride and soda ash, reportedly reducing the solubility. The process was stopped in 1976 when the Kin-Buc Landfill voluntarily stopped accepting all chemical wastes, including the fixated salts. The company then resumed stockpiling the untreated waste salts on the soil surface at the plant site.

A court order issued on January 26, 1977 required Vineland Chemical to containerize the waste salts from the chicken coops and piles, and then store the drums in a warehouse off-site. In June 1979, another court order was issued for the disposal of the stored drums in an approved landfill. Removal and disposal of these drums were not completed until June 30, 1982.

/

Aerial photographs provided by EPA's Environmental Photographic Information Center (EPIC) as well as conversations with Vineland Chemical Company employees indicated several possible locations of historic contamination. The cleared area in the southwest corner of the site, shown as a "former outdoor storage area" in Figure 2, was previously occupied by two chicken coops. Sometime between November 1975 and March 1979, both coops were destroyed. These coops were reportedly used to store process chemicals and/or waste in the 1970s. The materials stored in the coops may have percolated into the groundwater. Photographs showed many locations containing mounded material and/or drums. These were observed in the lagoon area and along the plant road. The waste salts were reportedly mounded so high at times in Lagoon LL-2 that the salts spilled over onto the soil in the lagoon area.

It was alleged that the floors of the manufacturing buildings had been leaking arsenic compounds into the underlying sands for years. The original floors of the buildings were brick and were reportedly in need of repair. Allegedly, when the old bricks were removed, the underlying soil contained crystalline waste from previous spills. It is not known whether the soils were removed when the floors were replaced, although the Remedial Investigation (RI) Report indicates the soils below Building 9 were sampled and high arsenic concentrations were detected.

In response to a series of Administrative Consent Orders issued by NJDEP, Vineland Chemical instituted some cleanup actions and modified its production process. The cleanup actions included stripping the surface soils in the manufacturing area, piling these soils in the clearing near well cluster EW-15 (located south of the manufacturing area), and paving the manufacturing area; installing a storm water runoff collection system; removing the piles of waste salts; and installing a groundwater pump and treat system. Modifications to the production process included altering the water system so that mixing of process water and non-contact cooling water was unlikely, lining two of the lagoons used in the wastewater treatment system (LL-1 and LL-2), and properly disposing of the waste salts off-site. The lining has since been removed from Lagoon LL-1 and the entire area has been excavated.

Potentially responsible parties (PRPs) identified for the site include the Vineland Chemical Company and its owners. EPA signed an Administrative Consent Order with the Vineland Chemical Company on September 28, 1984 allowing the company to conduct a remedial investigation of the site pursuant to CERCLA. Vineland Chemical submitted Remedial Investigation and Feasibility Study (RI/FS) Work Plan drafts which required major revisions. The company failed to submit a draft work plan incorporating the modifications that EPA

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required by April 17, 1986. EPA granted the company additional time until May 6, 1986, but the revised work plan was not submitted in a timely manner. Consequently, EPA assumed responsibility for the RI/FS on May 8, 1986. It served as the basis for the selected remedy for the site. After the RI/FS was completed, a 30-day public comment period was provided, ending on August 1, 1989.

EPA determined that since Vineland Chemical could not effectively undertake the preliminary remedial investigation work, the company would not be given the option to perform the remedial design work. Instead, EPA proposed to use its enforcement authority to ensure that the PRPs funded the remedial work to the maximum extent possible. Following the death of the owner in October 1990, operations at the Vineland Chemical Company facility began to diminish.

In 1992, EPA assessed the plant site conditions after being informed by the plant manager that the Vineland Chemical Company site would be abandoned. There were thousands of gallons of arsenic solutions stored in tanks and containers on the site. In June 1992, EPA secured the buildings and installed fences around soil areas containing high levels of arsenic. In addition, a fence was installed around the plant site to restrict trespassers. Removal of the hazardous materials stored in tanks and containers began in the fall of 1992. The company ceased operations and the plant site buildings were abandoned in early 1994.

During the design investigations phase, borings were advanced through the floors of all the plant site buildings and paved areas. Samples were also collected from inside the buildings including the walls, floors, ceilings and equipment. Significant amounts of arsenic were discovered in some of the buildings and in the soils at depths down to the water table. Arsenic was found at a level of 2,530 parts per million (ppm) in the concrete floors below Building 3, 158 ppm in the subsurface soils under Building 7 (laboratory), 1,530 ppm in the floors below Building 8,11,100 ppm in the brick floors below Building 9, 5,650 ppm in the concrete floors below Building 10, 334 ppm in the concrete floors below the wastewater treatment plant, and 508 ppm in the wood framing of Chicken Coop 3. Arsenic was also found at 72 ppm in the subsurface soils beneath Building 5 (boiler plant).

Based on these findings, EPA decided to demolish and dispose of eight plant site buildings that were themselves contaminated with arsenic or constructed over contaminated soils. Because the arsenic had permeated the building materials, decontamination was not considered an effective approach. By remediating the contaminated buildings, the human health risk associated with exposure to contaminated building interiors was eliminated.

On June 26, 1997, EPA approved an Explanation of Significant Differences (ESD) which included the demolition and disposal of the plant site buildings and debris. The building demolition work, designed and managed by the USACE, cost approximately $2.7 million. The ESD also included an increase in volume of the contaminated plant site soils and changes in the groundwater treatment plant size and treatment process. The USACE continues to provide EPA with design and construction management assistance through numerous Interagency Agreements,

In August 2001, another ESD changed the in-situ soil flushing remedy to ex-situ soil washing. The soil washing facility operated on the site from 2005 until 2007, and cleaned over 400,000

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tons of contaminated soil. Approximately 94 percent of the washed soil met residential cleanup criteria and was later returned to the excavated areas.

A groundwater treatment plant and extraction system were constructed and brought online in 2001; the system was designed to contain the contaminated groundwater being flushed by the original remedy. Though the soil flushing remedy was changed to a soil washing remedy, the extraction system and groundwater treatment plant operate to contain the contaminated groundwater, prevent it from reaching the Blackwater Branch, and serve to support long-term aquifer restoration. The groundwater treatment plant currently processes between 1.1 and 1.3 million gallons of water per day. The extraction and treatment system is periodically optimized to adjust pumping locations and rates to maximize the extraction of the more highly contaminated groundwater and maintain capture of the groundwater plume.

In May 2007, an Institutional Control (IC) in the form of a Classification Exception Area (CEA)AVell Restriction Area (WRA) was granted by the State of New Jersey for the Vineland Chemical Company Superfiind site because constituent (arsenic) standards for portions of the Cohansey aquifer were not met and the use of groundwater in localized areas had to be restricted.

3.5 Basis for Taking Action

Improper plant practices released contaminants to the environment. Arsenic contamination extended from the plant soils and underlying groundwater, to the Maurice River and Union Lake downstream of the plant to the Delaware Bay. The site was placed on the National Priorities List (NPL)in 1984.

An RI/FS was conducted to identify the types, quantities, and locations of contaminants, and to develop ways to correct the problems posed by the contaminants. The RI/FS completed in June 1989 indicated the following contamination problems:

Vineland Chemical Plant Site • On-site soils above the water table were substantially contaminated with arsenic in certain

areas. • The decontamination of on-site areas used for arsenic waste salt storage.

Vineland Chemical Groundwater • Residuals beneath the water table were impacted by arsenic leaching from the plant site soils. • The shallow groundwater beneath the site was contaminated with arsenic, and contaminated

to a lesser degree with cadmium and trichloroethylene (TCE). However, analysis of water samples taken treatment plant influent in early 2011 found cadmium and TCE at non-detect (ND) levels.

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River Areas • Sediments and surface water in the Blackwater Branch had elevated arsenic concentrations

downstream of the plant site, while having low to non-detectable levels upstream of the plant. • Sediments and surface water in the Maurice River below, but not above, its confluence with

the Blackwater Branch had elevated arsenic concentrations. • Approximately six metric tons of arsenic per year entered the Blackwater Branch via the

plant groundwater.

Union Lake • Arsenic contamination in sediment is widespread in much of the lake. Contamination is

primarily associated with fine-grained deposits present in the shallow sediments with highly variable concentrations (undetected to elevated levels). Select location-specific surface water results showed elevated arsenic concentrations.

A baseline human health risk assessment was conducted as part of the RI and indicated the potential for unacceptable risks from direct contact with arsenic-contaminated soils by hypothetical future workers or residents in the on-site soils, ingestion of arsenic-contaminated groundwater from potential future use of groundwater as a potable water source, and from direct contact with arsenic-contaminated sediments in the Blackwater Branch and the upper Maurice River, and from ingestion of fish from the upper Maurice River due to arsenic in fish tissue.

A ROD for the site was signed in 1989 and determined that actual or threatened releases of hazardous substances from the site, if not addressed by implementing the response actions selected in the ROD, may present an existing or potential threat to public health, welfare, or the environment.

4.0 Remedial Actions

4.1 Operable Unit 1 - Plant Site Source Control - Site Soils Remediation

4.1.1 Remedy Selection (OU-1)

The remedial objectives are to prevent current or future exposure to the contaminated site soils and to reduce arsenic migration into the groundwater. The selected remedy involves in-situ treatment by flushing of the contaminated soils to reduce arsenic levels. Plant site remediation also includes closure of two lined surface impoundments in compliance with RCRA, and decontamination of the former chicken coop storage buildings.

Although the ROD identified in-situ soil flushing as the remedy for plant site soils, column leaching tests during the remedial design revealed that it would take 17 to 20 years of flushing to reduce arsenic to the cleanup goal of 20 parts per million (ppm) based on contaminated soil with an arsenic concentration of 178 ppm. In addition, it would take 38 to 43 years to reduce the level of arsenic in more highly-contaminated soil (1,720 ppm) to the cleanup goal.

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Due to the extremely long remediation time periods and the possibility of failure to achieve the 20 ppm arsenic cleanup goal associated with the in-situ flushing remedy, EPA decided to perform further testing to evaluate the plant site soil remediation approach. Additional testing revealed that 15 pore volumes or flushes of water reduced the level of arsenic in the soils to 27 ppm. However, it required 460 flushes to reach the arsenic cleanup goal (i.e., 20 ppm). As a result, EPA decided to evaluate soil washing as a possible alternative technology for the remediation of the site soils. Soil washing was already believed to the appropriate remedial technology for the stream sediments.

In order to evaluate the effectiveness of soil washing for the plant site soils, four vendors were selected to perform treatability studies. Two of the soil washing processes showed that they could effectively reduce the arsenic levels in over 90 percent of the site soils to below the cleanup goal of 20 ppm. In terms of the length of time to achieve the remedy, soil flushing was projected to take up to 43 years as compared to soil washing that was expected to take two years. Another consideration was the additional flow of arsenic into the groundwater, which would result from in-situ soil flushing, would make plume capture more difficult and even uncertain. Further, the operation of the groundwater treatment facility itself would be more complex due to the recovery of slugs of arsenic from the pumping wells. The additional arsenic loading, in turn, would make the achievement of effluent requirements more difficult. Cost was also considered, and although difficult due to uncertainties associated with soil flushing, it was estimated that soil washing would be less expensive than the soil flushing alternative.

After taking all of these factors into consideration, EPA believed that a revision to the remedy was appropriate. An Explanation of Significant Differences (ESD) was developed to change in the remedy for plant site soils selected in the 1989 ROD from in-situ soil flushing to ex-situ soil washing. The change was documented in the 2001 ESD.

4.1.2 Remedy Implementation (OU-1)

The final design documents and equipment procurement specifications were submitted in mid-2001. The design was approved for construction in late 2002. Remedial action activities included construction of a plant building, soil treatment support systems, a chemical storage area, and outside storage pads for contaminated and clean soil. Plant construction was completed in fall of2003. After a brief commissioning and prove-out phase, the plant assumed full-scale operation at the design rate of 56 tons per hour (tph). A plant optimization was performed in July 2004. Changes made during optimization process increased production rates from 56 tph to 75 tph. In total, approximately 400,000 tons of arsenic-contaminated soil were excavated and treated.

Briefly, the soil washing treatment plant combined particle size separation processes with a chemical leaching and washing step to effectively remove arsenic contamination from site soils.

The site soils were sandy and contained arsenic in concentrations ranging from less than 20 to greater than 5,000 ppm. The initial process step used trommel screeners and vibrating wet screens to remove oversized materials (more than two millimeters) from the feed, then hydrocyclones to remove the fine particles ("fines," defined as soils with particle sizes less than

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0.1 millimeter). In the soils being treated, oversized materials make up about two percent and fines approximately four percent by weight.

After removal of the oversized materials and fines, water was added to the remaining sand particles and the resulting sand slurry sent through for washing. After being heated to 130 degrees Fahrenheit (°F), the slurry passes through four in-series leaching tanks that mix in several process chemicals, including sodium carbonate, which is the primary washing and leaching agent.

The combination of high-temperature sodium carbonate slurry and the aggressive mixing dissolves the iron and arsenic coatings from the sand particles.

The resulting product was clean sand, with contaminated water as a byproduct that was further processed using pH adjustment and flocculation to precipitate (settle) the dissolved arsenic into highly contaminated sludge.

The sludge generated by this process, as well as the fines initially removed by the hydrocyclones, was consolidated into a highly concentrated sludge containing high levels of arsenic. The sludge was then shipped to an approved off-site hazardous waste landfill for disposal. Oversized materials were shipped to an off-site Subtitle D landfill for disposal.

Some 94 percent of the site's soils were treated and returned to the site as clean backfill, with the remaining six percent shipped to an approved off-site landfill in the form of oversized materials (gravel, roots and twigs, miscellaneous debris) and sludge. Clean topsoil from an approved off-site source is used to restore the site to grade and support re-vegetation. The completion of restoration plans is pending the conclusion of other operable unit activities.

4.1.3 Institutional Controls (OU-1)

Engineering controls for the site consisted of fencing surrounding all soils areas with levels of arsenic exceeding 20 mg/kg (ppm). In fact, fencing is still in place even though the area is clean. There is an electronic gate controlling entrance to the site. All visitors are required to sign in at the main administration building and be given a safety briefing by the Site Safety and Health Officer based on their proposed work activity. In addition, there are worker and perimeter dust monitoring stations that cause operations to cease if prescribed health-based levels are exceeded. At the completion of OU-1 remediation activities, all soils down to and slightly into the water table (water table at 10-12 feet) with arsenic levels at or greater than 20 mg/kg (ppm), the risk-based cleanup level identified in the ROD, were excavated. The site is currently zoned as industrial and is not expected to change in the future; however, the 20 mg/kg level meets residential criteria as well. Residual contamination above 20 mg/kg was left in place at some locations greater than 12 feet in depth (beneath the water table). These levels are expected to decrease over time due to the continued operation of the OU-2 pump and treat remedy. Pump and treat system enhancements to further reduce residual contamination are currently under investigation. In addition, alternatives are being evaluated to reduce or immobilize the residual arsenic contamination left at depth in the saturated soils.

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4.1.4 Current Status (OU-1)

The soil washing system treated approximately 400,000 tons of soil and sediment from the plant site source and adjacent Blackwater Branch east of Mill Road areas. Prior to completion of the source area excavation and treatment, soils/sediments from OU-3 (Blackwater Branch) were excavated and blended with site soils for processing through the soil washing system. The final source area associated with OU-1 was used as the staging area during the OU-3 remediation. After the OU-3 treated soils were re-deposited into Blackwater Branch, the final OU-1 source area was excavated and treated.

All on-site soil washing was completed by December 2007. The soil washing plant has been shut down but will be maintained in the event it is needed for cleanup of Maurice River or Union Lake sediments. Final grading and vegetation restoration of OU-1 areas are pending. Some of these areas may be utilized during OU-3 and OU-4 activities.

4.2 Operable Unit 2 - Plant Site Management of Migration (Groundwater)

4.2.1 Remedy Selection (OU-2)

The remedial objectives are to achieve an aquifer cleanup goal of 0.05 milligram per liter (mg/1) to the maximum extent practicable, and minimize the flow of arsenic-contaminated groundwater to Blackwater Branch.

The remedy selected for OU-2 in the 1989 ROD included removal of arsenic-contaminated groundwater through pumping, followed by on-site treatment and reinjection of the treated groundwater back into the aquifer at the maximum rate practicable. Any remaining treated groundwater was to be discharged to the Maurice River. A portion of the treated groundwater was also to be used for the OU-1 soil flushing operation. The arsenic-contaminated sludge from the groundwater treatment process was to be transported off-site for hazardous waste treatment and disposal. The focus of this remedy was to eliminate the source of arsenic to the Maurice River system and work towards restoration of the aquifer.

4.2.2 Remedy Implementation

In 2001, an ESD was issued for OU-1 source soils changing the remedy from in-situ soil flushing to ex-situ soil washing. One of the reasons for the change was a concern that flushing results in additional flow of arsenic to the groundwater, which would make plume capture more difficult and even uncertain. Therefore, when the remedy for OU-1 was changed to ex-situ soil washing, re-injection of the treated groundwater from OU-2 was also eliminated. Total flows of treated water are discharged to the Blackwater Branch through an outfall west and downstream of the plant site. The OU-1 soil washing facility was a closed loop system that recycled process water; on occasion, water from the soil washing facility was sent to the OU-2 groundwater treatment plant.

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In September 1997, a contract was awarded to Black and Veatch for the construction and prove--out of the groundwater remediation system. The groundwater treatment plant was designed to handle a flow of up to 2.0 million gallons per day (mgd). It was also designed to handle both organic and inorganic arsenic flows. The US ACE managed the construction of the new facility, which was completed in the spring of 2000. System startup and prove-out of the new facility also began in the spring of 2000, and was operating by mid-2001. The system consists of three identical treatment trains. Two of the trains, ORM-1 and ORM-2, were designed to operate sequentially for removal of the organic arsenic. The third treatment train, IRM-1, was intended to treat the plume containing only inorganic arsenic. It was subsequently determined that either system is capable of treating organic arsenic to below acceptable discharge standards.

4.2.2.1 Groundwater Extraction System

Currently, 15 (of the total of 16) recovery wells are used to pump/capture contaminated groundwater emanating from the Vineland Chemical site and generally flowing towards the Blackwater Branch, a nearby stream. Since the organic arsenic plume was considered, based on initial studies, to be more difficult to treat than the inorganic plume, the groundwater extraction system was designed to capture and treat each plume separately, while minimizing commingling of the two plumes. Per the design, water flow from ten of the wells (RW-1 to RW-10) could be directed into either treatment train while three wells (RW-11, RW-12, RW-13) are only diverted to the inorganic train. This separation was based on monitoring data available during design. The separation is continually evaluated based on monitoring data. The three extraction wells added to the system after the original construction period (RW-2A, RW-2B and RW-9A) can only be diverted to the inorganic force main. Operation of the system found that the organic portion of the plume could also be effectively treated via the inorganic train; therefore, all extraction wells currently discharge to a single equalization (EQ) tank prior to treatment. The locations of the recovery wells are shown in Figure 3.

4.2.2.2 Groundwater Treatment System

As per the Operations and Maintenance Manual (May 2007), the Groundwater Treatment System operates as follows (see Figure 2):

The first section of the groundwater treatment system consists of three treatment trains. The treatment trains contain the same steps. The groundwater contaminated with organic arsenic is treated sequentially by Organic Arsenic Trains 1 and 2, while the Inorganic Arsenic Train treats the inorganic arsenic-contaminated groundwater. The discharge from Organic Arsenic Train 2 and the Inorganic Arsenic Train is combined, processed through sand filters and discharged. The solids recovered from the treatment trains and the sand filters are treated by the solids treatment train. The water fraction from the solids treatment is returned to the head of Organic Arsenic Train 1 or the Inorganic Arsenic Train. Dewatered solids are disposed of off-site.

Hydrogen peroxide (H2O2) is added to the groundwater to oxidize the arsenic from arsenite (As+3) to arsenate (As+S). The oxidation occurs in a mixed oxidation tank. The effluent from the oxidation tank is treated with ferric chloride (FeCl 3) to coagulate the treated arsenic and with sodium hydroxide (NaOH) to raise the pH. The effluent from the oxidation tanks flow by

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gravity to the coagulation tanks, which are mixed. The effluents from the coagulation tanks are treated with potassium permanganate (KMnO,*) and an organic polymer to enhance the formation of floe (flocculation) particles. The effluents from the coagulation tanks flow by gravity to the flocculation tanks. The flocculation step occurs in two stage tanks. Variable speed mixers are used in each stage. The effluent from the flocculation tanks flows by gravity to dissolved air floatation (DAF) units where the bulk of the coagulated/flocculated arsenic is removed. The DAF unit effluent from Organic Arsenic Train 1 is pumped to the head of Organic Arsenic Train 2 where the water is treated a second time. The processes and tanks in Train 2 are identical to Train 1. The DAF effluents from Organic Arsenic Train 2 and the Inorganic Arsenic Train are combined in the filter feed sump, treated with NaOH (pH adjustment), KMn04 (flocculation aid), and pumped through sand filters. The effluent from the sand filters is stored temporarily in the effluent storage tank, which serves as the wet well for the effluent pumps. The effluents pumps discharge the treated water through the effluent pipeline to the Blackwater Branch. A second discharge location, a lagoon east of the water treatment plant, was also provided, but has since been removed due to on-site soil remediation activities.

The solids recovered from the DAF units and the backwash from the sand filters are pumped to the solids handling facility. As a first step, a gravity thickener is used to concentrate the solids. The floating and settled solids are skimmed and scraped out of the thickener and sent to centrifuges for the final onsite treatment. The centrifuges further concentrate the solids. The solids from the centrifuges drop onto a set of screw conveyers which carry the dewatered sludge to temporary on-site storage containers. Ultimately, the containers are transported to off-site disposal at an appropriate facility. The water (centrate) from the centrifuges is recycled to the thickener, while the treated water overflow from the thickener is pumped to the head of Organic Arsenic Train 1 or the Inorganic Arsenic Train.

During the initial startup period in 2000 and until plant upgrades were finalized in 2004, the treatment plant was staffed 24 hours per day, seven days per week by an N-4 licensed plant supervisor, two maintenance mechanics and eight treatment plant operators. The eight treatment plant operators worked rotating shifts to provide coverage 24/7. In addition, one full time chemist and one laboratory technician staffed the on-site lab five days per week.

Upgrades to the system performed in 2003 and 2004 integrated an equalization tank, an upgraded control system and new equipment components. As a result of these upgrades, all extraction wells now pump into the equalization tank before being processed through the treatment system and the thickener overflow stream is pumped into the EQ Tank. Also, the plant upgrades allowed for reductions in plant staffing.

Currently, the plant operates 24 hours per day, seven days per week. The plant is staffed during the day by a plant supervisor, two operators, and a maintenance technician. During night and weekend hours, a remote connection system notifies operators of any plant operation issues. The plant automatically shuts down when certain operation exceedances (including discharge levels above cleanup criteria) are triggered.

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As a result of the recent Remedial System Evaluation (RSE), additional optimization activities are being evaluated. These include process design changes as well as reduced sampling activities and changes to chemical additives.

4.2.3 System Operations/Operation and Maintenance (O&M) (OU-2)

The recovery well field and treatment plant are intensively monitored to ensure proper system performance and to prevent the discharge of contaminants to the environment. Daily monitoring of the recovery well field includes flow rate, totalizer, and groundwater elevations in each recovery well, and line pressures in each transfer line. Daily monitoring of each of the three treatment trains includes flow and totalizer readings, tank levels, oxidation reduction potential (ORP) and pH readings, pump cycles, air flow rate in the DAF units, turbidity measurements, and other readings. Daily monitoring of the sand filters includes system flow, sump levels, pH, air flow rates, pressures, turbidity, standing water level in the distribution manifold stand pipe and direct observations of the sand movement in each bed. Daily monitoring of the solids-handling unit includes sump levels, skimming level, thickener overflow rate, centrifuge sump levels, centrifuge feed pump cycles, centrifuge flow and run time, level of the sludge level in the thickener and level of cake in the sludge container. Monitoring of the chemical feed system includes chemical tank levels, gallons (or drums) per day used, and pump cycles. In all, daily monitoring involves the collection, compilation, and evaluation of over 200 readings for tracking of plant performance.

Compliance monitoring of the treatment plant includes tracking system performance by monthly collection of over 40 samples of process water for laboratory analysis for arsenic speciation, metals, chloride, conductance, pH, total dissolved solids, total suspended solids, and alkalinity. Groundwater monitoring includes monthly sampling of all recovery wells and selected monitoring wells for laboratory analysis of total arsenic and arsenic speciation. Surface water samples are collected quarterly from eight monitoring locations and submitted for laboratory analysis of total arsenic. Sampling frequencies are being evaluated as part of the overall plant process management.

4.2.3.1 Recovery Well Rejuvenation

A program of well rejuvenation has been implemented at six month intervals or longer to improve diminished well capacities caused by chemical and biological fouling within the recovery well and conveyance systems. Laterals and force mains are cleaned using jetting techniques. Recovery wells are redeveloped with a variety of techniques including both physical and chemical treatments. The fouling is related to iron chemistry, iron bacteria, and other biological issues.

At each recovery well location, the pump is lifted out of the pitless adapter and stabilized. Each pump is then transported to the groundwater treatment plant for cleaning and servicing. The entire length of well screen is wire-brushed with an eight-inch diameter heavy gauge steel brush attached to the drill stem on the rig to remove large-scale iron buildup from the screen. At the

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conclusion of wire brushing, large-scale debris from the well is removed using airlifting techniques until the water clarity is visibly free from fines and turbidity.

A solution of sulfamic acid is then mixed with potable water and pumped through a tremie pipe. The pipe is placed at the bottom of the well and gradually lifted through the entire screened interval to provide thorough treatment of the affected area. The well is then surged with a double surge block for a period of approximately one hour to ensure that the acid is forced into the filter pack and surrounding formation. Once the acid is thoroughly mixed and distributed throughout the well system, the surge block is removed and the well allowed to reach static conditions overnight (for a period of at least 12 hours).

A double surge block in combination with simultaneous airlifting is used to remove water and materials from the well. The surge block is lifted and lowered in incremental steps throughout the entire screened interval. The process continues until the water is visibly free from turbidity. Upon completion of the process, pumps are reinstalled in each of the wells. All water removed from the recovery wells is sent to the water treatment plant for processing.

Another rejuvenation technique that has been used with success is high pressure jetting of the well screen. When performing this technique, the well pump and piping are removed and the well is brushed as described above. However, instead of using chemicals and a double surge block to redevelop the well, a high pressure, rotating nozzle is lowered into the well and the well screen is high pressure washed. As the well is pressure washed, well water and solids are removed from the well using an air lift.

Between redevelopment events, a preventative maintenance acid soak is employed in order to slow down the deteriorating yield of the recovery wells. The selected well is taken off-line and about five gallons of glycolic acid is added to the well. The well valves are aligned to allow for recirculation in the well and the well is turned on for a few minutes to allow the acid/water mixture to re-circulate and mix thoroughly in the well. The pump is turned off and the well is allowed to soak overnight. The following day, the well valves are re-aligned for normal operation and the well is returned to service.

4.2.3.2 REDUX™ 300 Pilot Test

In an attempt to remove and prevent iron deposits from forming in the wells and conveyance systems, a pilot study was implemented using REDUX™ 300 deposit control agent with a continuous chemical feed pump at the wellhead. The pilot test was conducted over 92 days involving recovery wells RW-4, RW-6, RW-7. The objectives were to maintain the pumps in a deposit free condition, maintain pumping capacity, and minimize iron deposits in the related conveyance pipeline and prevent pressure buildup. Upon completion of the pilot study, it was concluded that REDUX™ 300 maintained pumping rates in all wells tested once the system stabilized. Two of the three wells were acceptably clean when inspected. RW-7 was heavily fouled upon inspection, yet extraction well performance was good during the course of the test. It was also concluded that RW-7 has the highest iron concentration of all the wells in the system, so it represents the most difficult treatment situation.

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The project team evaluates the use of Redux chemicals and other well rejuvenation techniques at monthly well meetings. Over the past few years, high pressure jetting has been used as a more aggressive physical means of cleaning recovery wells. This process includes directing high pressure water jets at well screens and interior pipe locations impacted with iron-arsenic buildup.

REDUX™ 333 and 610

Several extraction wells were treated with REDUX 333 or REDUX 610 from June 2008 through June 2009. A decision was made to terminate REDUX treatment at recovery wells RW-4, 5, 6, 7 and 8. REDUX termination at these wells coincided with well redevelopment and occurred between May 26, 2009 and June 12, 2009. Currently, only five wells are receiving REDUX treatments; RW-2, 2A, 2B, 3 and 9A.

4.2.4 Institutional Controls (OU-2)

Engineering controls at the site include a six-foot fence surrounding the main site to prevent uncontrolled entry. Each extraction well is enclosed by a separate security fence, primarily to prevent vandalism of the wells. A Classification Exception Area with a Well Restriction Area (CEA-WRA), proposed by EPA and issued by the State of New Jersey, has been in place at the site since 2007. This institutional control restricts the installation of groundwater wells and use of groundwater within the plume area, thus preventing a completed exposure pathway to the groundwater. The CEA-WRA was issued for arsenic, the constituent of concern, and applies to specific zones within the Cohancey and Kirkwood aquifers. The CEA-WRA boundary is delineated at 3 ppb (parts per billion), the current NJDEP Groundwater Quality Criterion for arsenic.

The New Jersey Department of Environmental Protection describes a CEA as "established in order to provide notice that the constituent standards for a given aquifer classification are not or will not be met in a localized area due to natural water quality or anthropogenic influences, and that designated aquifer uses are suspended in the affected area for the term of the CEA." NJDEP is obligated to restrict the use of potable groundwater within "any CEA where is or will be an exceedance of Primary Drinking Water Standards (N.J.A.C. 7:10). Therefore, when contaminant concentrations in a CEA exceed Maximum Contaminant Levels, and designated aquifer use based on classification includes potable use, the Department will identify the CEA as a Well Restriction Area (WRA). The WRA functions as the institutional control by which potable use restriction can be effected."

While the designated uses of Blackwater Branch include potable water supplies, the criteria (N.J.A.C. 7:9B-1.12(c)(4)) further states: "Public potable water supply after conventional filtration treatment (a series of processes including filtration, flocculation, coagulation, and sedimentation, resulting in substantial particulate removal but no consistent removal of chemical constituents) and disinfection." Although it is unlikely that Blackwater Branch would be considered for use as a potable water supply, there is no risk of direct uncontrolled use as a drinking water source. Any plans for use as a public potable water supply would require a rigorous planning and approval process where source water characteristics are considered and the appropriate treatment system is designed to remove any constituents exceeding drinking water

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quality standards. Therefore, there are regulatory requirements in place that result in an incomplete exposure pathway.

4.2.5 Current Status (OU-2)

The extraction and treatment system have been operating since the spring of 2001. To date, the system has treated about four billion gallons of water. In general, the treatment system has effectively reduced arsenic levels in the effluent to below the 50 pg/L discharge standard. There have only been two occurrences of the discharge to Blackwater Branch exceeding those standards. A continuous arsenic monitor checks the effluent discharge water quality to ensure that no spills of water exceeding the ROD criteria occur. The monitor is integrated into the plant's control system checks and shuts down the system if arsenic effluent levels reach a level of concern.

Weekly progress meetings continue to be conducted to keep EPA, USACE, and project personnel up-to-date on systems operations and include a variety of topics including, O&M activities, problems encountered, regular and preventive maintenance activities, and a two-week look ahead on planned activities.

Based on recent RSE investigations and modeling of the groundwater extraction system, several modifications to the system have been recommended to improve capture and containment of the arsenic plume. Modeling has determined that data gaps important to our understanding of the capture zone may exist. Plans are in place to install approximately 12 new monitoring wells on-site during the summer/fall of 2011, and one or two new extraction wells over the next three years. This will support optimizing arsenic reduction/removal through pumping of the most highly contaminated portion of the plume while still maintaining plume capture and controlling the amount of water extracted from clean areas.

Several overall site improvements have resulted directly from operation of the pump and treat system. The most important of these include a general decrease in the maximum arsenic plume concentrations and a dramatic reduction in surface water contamination in Blackwater Branch. Protection of Blackwater Branch is a primary objective of the groundwater program and has allowed excavation for floodplain sediment remediation (Operable Unit 3) to proceed. The groundwater treatment plant operation also supported source removal (Operable Unit 1) in treating effluent from the soil washing plant.

Groundwater and Surface Water Monitoring

There are no current, known exposures to groundwater contamination. The classification exception area and other land-use controls should prevent groundwater use in the vicinity of the site. The groundwater extraction system is achieving its primary goal of protection of surface water quality, though there are some subtle questions about the completeness of the capture of the entire plume as discussed above. The groundwater contamination northwest of Blackwater Branch is being further evaluated. While outside the current capture zone of the northwestern most recovery well, the area is within the CEA-WRA. The exact source and fate of this contamination is not known.

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The mid-depth wells are generally displaying decreasing concentrations. The shallow wells, however, are generally more stable. Groundwater capture zone demonstrates, with the exception of a newly found limited area north of Mill Road, that the extraction and treatment system is hydraulically containing the contamination on-site. However, because of the presence of residual contamination in the saturated soils, restoration of the groundwater may not occur for a long time. Optimization efforts and enhancements to the pump and treat system, in conjunction with treatability studies for the residual source materials, are being evaluated to determine if the cleanup time period can be reduced or, alternatively, if the restoration objective for groundwater in the near-term is still viable.

Based on thejsurface water sampling results, surface water quality in the vicinity of the site appears to be meeting goals for protection of ecological and human receptors. The treatment plant is more than meeting the arsenic discharge standard established in the ROD for surface water (50 pg/L) and, in fact, is generally achieving the new federal drinking water MCL of 10 pg/L.

Hvdrogeoloeic Investigation/Capture Zone Analysis

EPA Document Monitored Natural Attenuation of Inorganic Contaminants in Groundwater, Volume 2, October 2007, discusses the attenuation of arsenic in groundwater through precipitation, co-precipitation, or adsorption to various minerals, including iron oxyhydroxides. A number of factors are to be considered in assessing the natural fate of arsenic and any engineered immobilization as discussed below.

Metal Concentrations in Soil

Available data of metal concentrations in soil and groundwater are limited to Area 5 (one source area where soil was excavated). Data from the RSE shows that:

• With the exception of one point, plots of total versus dissolved arsenic show a near one-to-one relationship suggesting little trapping of suspended sediments with sorbed arsenic.

• Relatively good correlation is encountered between arsenic and iron in soil. These data may be used to develop a preliminary site-specific partition coefficient. The relatively good correlation between arsenic and iron concentrations and the elevated iron concentrations in soil (as high as two percent) show that iron is likely to play a dominant role in attenuation of arsenic.

• Sulfides concentration in soil is below 13 mg/kg and is limited in extent (most soil samples showing non-detect concentrations for sulfide). Sulfate concentration in groundwater ranges from ND to 182 milligrams per liter (mg/1) with most data ranging between ~ 5 mg/1 to ~15 mg/1. These data suggest ORP (Eh) values higher than those representing sulfate reducing conditions. During experimental work regarding enhanced arsenic mobilization, iron, aluminum and arsenic were desorbed during their testing. Aluminum concentrations in soil

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were not tested in some areas (Area 5) and, as such, additional data are needed to assess the potential for aluminum to attenuate arsenic and develop a site-specific partition coefficient. Similar metals data for soil in other parts of the site are also needed.

Arsenic Speciation in Groundwater

Under conditions observed at the site (pH < 5), adsorption of arsenate to iron oxyhydroxides would be the most stable form of immobilization. Speciation of arsenic at the site shows the presence of arsenate, arsenite, MMA, and DMA. The data indicate that the fraction of organic arsenic species (MMA and DMA) is insignificant in comparison to inorganic arsenic species. Overall, in groundwater, arsenate is the dominant form of arsenic although significant concentrations of arsenite are present. The ratio of arsenate to arsenite in the shallow zone ranged from values >1 to 6250 in ~ 200 samples and was less than one (i.e., where arsenite > arsenate) in ~ 60 samples. An additional -70 samples were non-detect for arsenic and had a ratio of one (i.e., the ratio of two equal detection limits). Concentrations of organic arsenic species, particularly MMA, have declined substantially in the treatment plant influent during pumping and treatment operation. MMA concentrations in 2003 were over 0.1 mg/L but have decreased to below 0.02 mg/L, which meets current ROD and discharge standards. By contrast, the combined arsenate and arsenite concentration is approximately 0.3 mg/L.

As an aside, arsenic speciation in process water prior to chemical addition shows that overall arsenate is the dominant form of arsenic; however, there are periods where arsenite is the dominant form of arsenic in process water. It is believed that arsenate is likely sorbed to the iron oxide precipitate that routinely clogs the well screen and extraction piping. This hypothesis is supported by a comparison of the arsenic concentrations sampled at the extraction wells and the arsenic concentration in the treatment plant effluent. Based on extraction well sampling results and extraction well rates, it is estimated that the blended arsenic concentration in the extraction wells is approximately 0.6 mg/L, whereas the actual blended influent concentration at the equalization tank is approximately 0.3 mg/L. This comparison suggests that up to 50 percent of the arsenic (in the form of arsenate) may be removed by precipitated iron within the extraction network. The removal of arsenate in the extraction network results in arsenite being the* dominant arsenic species in the treatment plant influent during some periods. Chemicals like the hydrogen peroxide used in the above-ground treatment process rapidly oxidize arsenite to arsenate under wide range of conditions and would also have the ability to oxidize the organic arsenic.

pH. ORP/ Eh. Dissolved Oxygen. and Temperature in Groundwater

Spatial plots of pH, ORP, dissolved oxygen, and temperature measured between 2009 and 2010 for the shallow and middle zones indicate the following:

• There is no clear monotonic (i.e., continuous decline or continuous increase) trend in any of the measured field parameters. Pumping may be confusing any natural trend that might exist. Groundwater temperatures in many monitoring wells between the extraction network and surface water are indicative of surface water temperatures, suggesting that the extraction network is pulling surface water into the aquifer.

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• Dissolved oxygen (DO) measurements indicate aerobic conditions, ORP is positive, and the elevated values are likely representative of the ferric/ferrous ion pair rather than the H/OH ion pair. For this reason, ORP cannot be related to dissolved oxygen measurements. Analysis of iron speciation in groundwater can be utilized to confirm this hypothesis and demonstrate the dominance of the iron chemistry in groundwater.

• Overall, the groundwater is acidic. Arsenate adsorption to iron oxides has been shown' to be effective at the pH encountered on the site. Further studies are needed to determine the optimal pH range for arsenate adsorption and the recommended procedure to attain and maintain the optimal pH. Site-specific studies are needed to determine the stability of the sorbed arsenic as well as the kinetic of arsenic adsorption and factors influencing adsorption kinetics. These studies are currently being carried out by USACE as part of a focused feasibility study and are directly connected to the upcoming monitoring well installation to be carried out in August/September of 2011.

Groundwater Modeling/Plume Capture Zone Analysis

The extraction system performance was evaluated based on several lines of evidence, including analysis of the piezometric surface contour maps, concentration contours and trend analysis, ground water flux estimates compared to pumping rates, and review of model results. This is generally in accordance with EPA guidance in assessing capture zones for groundwater extraction systems (EPA, 2008).

Piezometric surface maps were constructed by the RSE team based on water levels measurements taken in 2010 for shallow, mid-depth, and deep wells. General flow directions are to the northwest. The pumping of the northeastern extraction wells (for locations see Figure 4) — RW-2, 2A, 2B, 3, 4, 6, and 7 - have induced a northeasterly gradient adjacent to the northern arsenic plume, and contours parallel Blackwater Branch in this area. Pumping of the western wells - RW-8, 9, 9A, 10, and 12 - have created a westerly gradient for the western portion of the site, particularly along the western extent of the southern arsenic plume. A groundwater divide has been established between these two "lines" of wells, and the northern arsenic plume sits atop this divide. It appears that contaminant migration could occur northward toward the stream outside of the capture of extraction wells RW-7 and 8, but other lines of evidence are needed to more fully assess this possibility. Capture appears reasonably complete to the east and south of MW-31S/M. There is a lack of water level information between the extraction wells and Blackwater Branch to the northeast that could be addressed by additional monitoring points and/or including the water level of Blackwater Branch. Potentiometric surface contours prepared using 2003 data and contouring software (reference final draft RSE for data) indicate substantial flow from Blackwater Branch to the extraction wells, which might be consistent with the RSE potentiometric contours if water elevation information from Blackwater Branch was included. Site groundwater model interpretations of the system capture zone are illustrated in the final draft of the RSE, available upon request.

The natural flux of groundwater under non-pumping conditions was estimated based on historical pre-pumping groundwater contours provided by USACE Philadelphia District (2004; source information available upon request), model calibrated hydraulic conductivities (K) of 350

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to 700 ft/day, an estimated conservative maximum saturated thickness of 60 feet (erring on the side of a larger natural flux), and a plume width of 1200 feet. The gradients estimated from the contours were 0.0017 to 0.002 and 0.002 was used in the calculation. Flux was calculated to approximately 260 gallons per minute (gpm) with K = 350 ft/day and 520 gpm with K = 700 ft/day. Total pumping for the extraction system is approximately 700 - 800 gpm. This exceeds the natural flux, so there is circumstantial evidence that at least most of the plume is likely to be captured. Note, that any water pumped beyond the natural flux through the contaminated part of the aquifer is extracted from clean zones to the southwest or from Blackwater Branch. It is likely that the extraction system is drawing a significant amount of water from the stream, particularly with the eastern extraction wells. Though the site groundwater model provides a more robust tool to assess capture, these calculations are a reasonable check on the model results.

The concentration trends were computed for the wells using both qualitative and quantitative (Mann-Kendall) analysis. Trends for wells near and downgradient of the extraction well lines were examined for indications of contaminant "breakthrough." Most of the applicable wells display stable or decreasing trends, with a few exceptions. Some wells displayed an increase during and following excavation activities on-site, with recent declines following completion of that work. This is a common observation at sites undergoing large-scale disturbance. However, MW-38S appears to have an ongoing increasing trend, as does MW-40S. MW-53S has qualitative evidence of recently increasing concentrations (see Figures 5 and 6 for well locations). These exceptions are important because these are in areas in or downgradient of broader gaps in the extraction system (MW-40S is the larger gap between RW-7 and 8; MW-38S is between RW-2 and 3). Note that contamination moving through these gaps may still be captured as some flow lines enter the extraction wells from the "downgradient" side of the capture zone. Still, this analysis does raise some questions about the adequacy of the capture in these areas.

Modeling analysis included simple analytical modeling done using a capture zone width formula and assessment of numerical modeling of capture zones conducted by USACE Philadelphia District. Based on the other lines of evidence, the capture zone widths of RW-7 and 8 and RW-2 and 3 were computed using the following equation:

Width = Pumping rate / (saturated thickness * gradient x K)

For RW-7 and 8, the relatively small saturated thicknesses in this area and the observed flow rates would suggest broad capture zones 620-720 feet wide, if the K values are near the modeled 400 feet/day. However, these wells are close to an area of modeled higher K values, 700 - 1000 feet/day. If the K values are doubled, the capture zone widths are cut in half, 310 - 360 feet, slightly less than the distance between these two wells. In the case of RW-2 and 3, the capture zone widths, assuming saturated thicknesses in this area of45 - 60 feet and K values near 400 ft/day, are 220-320 feet, less than the spacing between these two wells. Capture zone analysis conducted using the site numerical groundwater model do not show such gaps in the reach of the extraction wells, though the model capture zones open more toward the east than the southeast. Based on this analysis, there is a chance that minor gaps exist between a few of the extraction wells.

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4.3 Operable Unit 3 - River Areas

4.3.1 Remedy Selection (OU-3)

The remedial action objectives are to minimize public exposure, either through containment, removal or institutional controls, to those areas with unacceptably high sediment arsenic concentrations, such as those in the Blackwater Branch floodplain.

The following remedy for OU-3 selected in the 1989 ROD:

Excavation and treatment of the exposed arsenic-contaminated sediments in the Blackwater Branch floodplain. Treatment will consist of a water wash extraction. The cleaned sediments will be re-deposited in the excavated portion of the floodplain. The sludge from the extraction process will be transported off-site for hazardous waste treatment and disposal. Remediation would begin after the contaminated groundwater flow into the Blackwater Branch has been stopped.

Submerged arsenic-contaminated sediments in Blackwater Branch, adjacent to and downstream from the Vineland Chemical Company site, will be removed and treated by water wash extraction. Prior to removing any sediments, an environmental assessment of the impact of dredging would be performed and a confirmation made that these sediments are a source of contamination to the river system. The treated sediments will be re-deposited on undeveloped areas of the Vineland Chemical plant site. The sludge from the extraction process will be transported off-site for hazardous waste treatment and disposal.

After stopping the flow of arsenic-contaminated groundwater from the Vineland Chemical Company plant site, a three-year period for natural river flushing will be implemented. This will allow the submerged, arsenic-contaminated sediments in the Maurice River to be flushed clean through natural processes. If, after this period, the submerged sediments are no longer contaminated with arsenic above the action level, no remediation will be performed in the river. Similarly, if sediment contamination above the action level persists, but the observed or expected natural decontamination rate is consistent with an acceptable public health risk, no remediation will be performed. However, if contamination above the action level persists in some locations and is expected to remain at levels posing unacceptable health risks, those locations would be remediated.

Remediation of the submerged Maurice River sediments will be performed, as necessary, by dredging and treatment with a water wash extraction. However, prior to removing any sediment, ah environmental assessment of the impacts of dredging will be made. The treated sediments will be deposited on undeveloped areas of the Vineland Chemical plant site. The sludge from the extraction process will be transported off-site for hazardous waste treatment and disposal.

4.3.2 Remedy Implementation (OU-3)

Actual implementation of OU-3 varied slightly but not significantly from that described in the ROD. During OU-3 design, high levels of arsenic were identified in exposed and submerged

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sediments along the entire stretch of the Blackwater Branch from the main plant area to its confluence with the Maurice River. A remedial action strategy to manage the contaminated sediments in a timely manner and reduce the potential for downstream migration to the Maurice River was developed and implemented. The OU-3 remedy began with the remediation of the Blackwater Branch east of Mill Road in 2005. Excavated sediment from this phase of work included a large sand component and was treated through the soil washing facility along with OU-1 materials. The area east of Mill Road was completed by December 2007. West of Mill Road, the overall fine-grained nature of contaminated sediments and the presence of a large fraction of organic material (i.e., peat and vegetation) made the excavated material unsuitable for the soil washing process. These materials were staged on-site in high piles to dewater and dry. After excavation and drying, the fine-grained sediments and organic material were shipped off-site for disposal in a permitted landfill. From a disposal perspective, these materials were found to pass RCRA toxicity characteristic leaching procedure (TCLP) testing.

Monitoring along the Maurice River suggests that while surface water quality has been controlled by the ongoing pumping and treatment activities, elevated levels attributable to mixing with contaminated sediments is an issue for future consideration. In regard to the OU-3 work completed to date, modeling of the system and testing during maintenance activities when individual pumps are not operating indicates contaminated groundwater would once again discharge to surface water along Blackwater Branch if the extraction and treatment system were shut down for more than a few weeks. For additional details, see Section 4.2.5. As mentioned in earlier text, new monitoring wells will be installed on the site in the summer/fall of 2011, and plans to install one to three new recovery wells are forthcoming over the next three years.

4.3.3 Institutional Controls (OU-3)

Signs are posted in accessible areas of Blackwater Branch and the Maurice River advising the public that sediments are contaminated with arsenic and there are risks associated with prolonged exposure of arsenic. Periodic monitoring of the signage is necessary, as signs have been removed in the past.

4.3.4 Current Status (OU-3)

Blackwater Branch

The Blackwater Branch work is being completed in four phases or stream sections. The work was divided into four sections due to logistical considerations. The implementation of the first phase of the OU-3 remediation was completed in December 2007 (see Figure 3). This involved the removal of highly-contaminated soils and sediments within the stream channel and floodplain portion of the Blackwater Branch east of Mill Road. The excavation work for the area between Mill Road and Route 55, and the area between Route 55 and the Maurice River Parkway has been completed. The majority of the backfilling has also been completed. Over the next few years, the final grading, placement of topsoil and vegetation restoration for these areas will be ongoing. The area (final phase) from the Maurice River Parkway to the Maurice River is in the staging and excavation phase. The initial phase of the Blackwater Branch remediation is almost

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three years into the restoration process with an established stand of Atlantic White Cedar trees and array of wetland vegetation. The second and third phases are at the beginning of the restoration process, with grading almost complete and a hydroseeded plant cover currently in place; native wetland grasses and Atlantic White Cedars are due to be planted in the fall of 2011.

Maurice River

Periodic sampling has been conducted along the Maurice River since May 2006. The results vary, but generally lower levels of arsenic are encountered in sediment and water samples collected along the river than were present along Blackwater Branch or are still recorded for Union Lake. The Periodic Sampling - Spring 2010 report produced for USACE (EA Engineering, Science and Technology, December 2010) provided the results of agitated water (total metals analysis), soil, and sediment sampling along the Maurice River. Results indicated arsenic contamination is sediment driven, with the majority of water samples taken before agitation of the sediment exhibiting arsenic concentrations less than 9 pg/L.

Results and locations from this surface water (after disturbance) and sediment sampling event are mentioned below (see Figure 2-1 for station locations):

Station 1 - West of Mill Road Station 1 was not sampled during the spring 2010 sampling effort due to excavation and remedial activities currently being conducted by USACE Philadelphia District.

Station 2 - West of Route 55 Station 2 was not sampled during the spring 2010 effort due to excavation and remedial activities currently being conducted by USACE Philadelphia District.

Station 3 - BWB & Maurice Confluence Arsenic was detected above the EPA drinking water standard of 10 ppb in the agitated water sample at a concentration of 58 pg/L. Arsenic was detected in the shore sediment sample at a concentration of 150 mg/kg, 7.5 times above the site cleanup level of 20 mg/kg (ppm). Arsenic was detected in the surficial mid-stream sediment sample at 3.1 mg/kg.

Station 4 - Alliance Beach Arsenic was detected in the surficial mid-stream sediment sample at 2.0 mg/kg and in the shore sediment sample at 0.84 mg/kg. Arsenic was not detected in the non-agitated or agitated water samples. In the additional beach transects, none of the arsenic concentrations exceeded the site cleanup level. Two of the agitated water samples exceeded the EPA drinking water standard.

Station 5 - Almond Beach Arsenic was not detected in the surface water, shore, or beach samples. Arsenic was detected in the surficial mid-stream sediment sample at 1.2 mg/kg. In the additional beach transects, arsenic was not detected in the surface water samples; arsenic detected in the sediment samples was below the site cleanup level of 20 mg/kg.

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Station 6 - "BareA" Beach Arsenic was detected in the non-agitated water sample (8.9 Jtg/L) and agitated water sample (370 /xg/L); the agitated water sample exceeded the EPA drinking water standard of 10 pg/L by a factor of 37! The sediment sample exceeded the site cleanup level of 20 mg/kg by a factor of six with an arsenic concentration of 120 mg/kg. The shore sample had an arsenic concentration of 160 mg/kg, exceeding the 20 mg/kg criterion by a factor of eight. Arsenic was not detected in the beach sample. The additional beach transect results had eight to ten sediment samples exceeding the site cleanup level. Four agitated water samples at the additional beach transects exceeded the EPA drinking water standard.

Station 7 - Sherman Ave. Arsenic was not detected in the non-agitated or agitated surface water samples. Arsenic was detected in the sediment sample (3.8 mg/kg) and shore sample (3.7 mg/kg); both were below the site cleanup level of 20 mg/kg.

4.4 Operable Unit 4 - Union Lake Sediments

4.4.1 Remedy Selection (OU-4)

The remedial action objectives are to reduce potential human health risks by minimizing public exposure to sediments with unacceptably high arsenic concentrations, either through removal, containment or institutional controls.

The remedy for OU-4 selected in the 1989 ROD is as follows: ~

Removal and treatment of arsenic-contaminated sediments on the periphery of Union Lake will be performed after the three-year flushing period (if no remediation is performed in the Maurice River) or after remediation of the Maurice River (if this is necessary following the flushing period). Verification sampling will be conducted prior to remediation to confirm the locations of sediments contaminated above the action level for arsenic along the periphery of Union Lake.

The arsenic-contaminated sediments at the periphery of Union Lake will be excavated after they are exposed by lowering the lake's water level. However, for the upper end of the lake above the submerged dam, prior to removing any sediment, an environmental assessment of the impact of dredging will be performed. The sediments will be treated by water wash extraction and the cleaned sediments returned to their approximate former locations in Union Lake. The sludge from the extraction process will be transported off-site for hazardous waste treatment and disposal.

>

4.4.2 Remedy Implementation (OU-4)

This is an interim remedy since arsenic-contaminated sediments above health-based levels will remain in Union Lake. Periodic reviews will be conducted to determine whether contaminated sediments are redistributed, through natural processes, to the cleaned areas. This remedy has not yet been implemented.

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4.4.3 Institutional Controls (OU-4)

Institutional controls in the Union Lake area will consist of posted signs warning against swimming in these water bodies due to risks associated with arsenic contamination, as warranted. Periodic sampling is required to determine near-shore arsenic in sediment concentrations. In the past few years, the beaches of Union Lake have been closed for swimming due to the lack of funding for lifeguards and elevated levels of fecal coliform in the water.

4.4.4 Current Status (OU-4)

As part of the ongoing periodic sampling, a sediment and water sampling program was completed over the summer of 2010 to evaluate the status of the arsenic contamination around the periphery, and particularly in the beach areas of Union Lake. All water samples represent total values. The results are discussed below (see Figure 2.1 for sample locations).

Station 8 - North End of Union Lake The agitated water sample exceeded the criterion of 10 pg/L by a factor of 7.6, with an arsenic concentration of 76 pg/L. Arsenic was detected in both the sediment sample (410 mg/kg) and shore sample (110 mg/kg). The concentrations exceeded the site cleanup level of 20 ppm by factors of 20.5 and 5.5, respectively.

Station 9 - Union Lake Beach The non-agitated surface water sample exceeded the criterion of 10 pg/L by a factor of 1.4 with a concentration of 14 pg/L. The agitated water sample also exceeded the criterion of 10 pg/L (ppb) by a factor of 12 with an arsenic concentration of 120 pg/L. Arsenic was detected in the sediment sample at a concentration of 330 mg/kg, exceeding the 20 mg/kg criterion by a factor of 16.5.

Arsenic was detected below the 20 mg/kg criterion in the shore sample with a concentration of 2.3 mg/kg and in the beach sample with a concentration of 1.1 mg/kg. In additional beach transects, arsenic was detected in all of the sediment samples but at concentrations lower than the site cleanup level of 10 pg/L. One agitated water sample exceeded the criterion of 10 pg/L by a factor of 1.1 with an arsenic concentration of 11 pg/L.

Station 10 - South End of Union Lake Beach Arsenic was detected in the agitated water sample at a concentration of 14 pg/L; this exceeded the federal drinking water standard by a factor of 1.4. The sediment sample had an arsenic concentration of 9.8 mg/kg and in the shore sample, a concentration of 1 mg/kg; both samples were below the site cleanup level of 20 ppm. Arsenic was not detected in the beach sample at this location. In additional beach transects, arsenic detected in sediment samples was below the criterion of 20 mg/kg. One agitated water sample exceeded the criterion of 10 pg/L by a factor of 1.1 with an arsenic concentration of 11 pg/L.

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5.0 Five-Year Review Process

5.1 Administrative Components

The five-year review team members included:

• Nica Klaber, Remedial Project Manager, EPA Region 2 • Ron Naman, Remedial Project Manager, EPA Region 2 • Michael Sivak, Risk Assessor, EPA Region 2 • Ed Modica, Hydrologist, EPA Region 2 • Mindy Pensak, Eco Risk Assessor, EPA Region 2

Other parties that provided input into the FYR include:

• Steve Creighton, Project Engineer, CENAP-EC-CS; USACE • Laura Bittner, GIS, CENAP-EC-H; USACE • Steve Gillespie, Project Manager, Sevenson Environmental Services, Inc.

5.2 Community Involvement

The EPA Project Officer (PO) for the site, Justin Gottesman, published a notice in The Grapevine, a local newspaper, on March 16, 2011, notifying the community of the initiation of the five-year review process. The notice indicated that EPA would be conducting a five-year review of the selected remedies to ensure that the remedies remain protective of public health and are functioning as designed, or will be protective, once implemented. It was also indicated that once the five-year review is completed, the results would be made available in the local site repositories. In addition, the notice included the address and telephone number of the RPM and the CIC (Community Involvement Coordinator) for questions related to the five-year review process at Vineland Chemical Company Superfund site.

Progress Since the Last Five-Year Review

This is the first five year review for the Vineland Chemical Company Superfund site.

Document Review

See Table 5.

5.3 Data Review

Remedy Evaluation and Data Review

According to the decision documents, the remedy for the Vineland Chemical Company site is being implemented in four discrete areas or operable units. OU-1 is a source control remedy, and includes soil washing of arsenic-contaminated soil and the closing of impoundments in the

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vicinity of the original Plant. OU-2 is a groundwater remedy and involves extraction and treatment of contaminated groundwater underlying the site. The OU-3 component of the remedy calls for excavation/dredging and treatment (by water wash extraction) of stream and river area sediments. After the completion of the Blackwater Branch work (comprised of soil excavation and habitat restoration), a three-year period would be allowed for the study of the Maurice River and to observe and document whether natural river flushing is a viable remedy. OU-4 involves the remediation of Union Lake sediments and calls for the removal and treatment of contaminated sediments on the lake periphery. OU-1 and OU-2 were to be implemented first and in parallel, as the original OU-1 remedy called for soil flushing and relied on a groundwater pump and treat operation being in place. OU-3 and OU-4 would be implemented in later phases in order to allow for upgradient contamination to be addressed first and to minimize the risk of re-contaminating downgradient media from upgradient sources.

OU-1 Soil Remedy

The objectives of the OU-1 (source control) soil remedy are to prevent exposure to contaminated site soils and to reduce arsenic migration into the groundwater. Originally, 126,000 cubic yards of unsaturated soil on the plant site were identified as contaminated with arsenic above the 20 ppm action level. The 1989 ROD called for in-situ flushing of arsenic-contaminated soil to accelerate washing of arsenic into the shallow aquifer, which was already contaminated and was to be remediated as part of the OU-2 groundwater remedy. Portions of the soil were to be excavated and consolidated with undisturbed contaminated soils into two active flushing areas. However, the soil remedy was modified by the 2001 ESD to ex-situ soil washing. Treatability studies demonstrated that soil washing was more effective than soil flushing in reducing arsenic to cleanup goal of 20 ppm. The ESD provided for the remediation of an increased volume of contaminated plant site soil as it was discovered during design investigations that significant amounts of arsenic were found beneath site buildings. The ESD also stipulated the demolition and disposal of plant site buildings including chicken coops used for storage because it was discovered that arsenic had permeated the building material. Closure of two lined surface impoundments in compliance with RCRA was also carried out as part of the soils remedy.

Excavation and treatment of soils on the site began in 2003 and were completed in late 2007. All identified contaminated soil in the unsaturated zone and some below the water table was successfully remediated, reducing the arsenic impact on groundwater. While some contaminated material below the water table was remediated (one to two feet), it should be noted that arsenic-contaminated saturated soils extended to depths further below. Soils in the saturated zone were not targeted for removal as they were considered inaccessible to the soil removal techniques used in soil remediation at the site. The saturated soils are likely a continuing source of arsenic contamination to groundwater. It will be necessary to rely on the groundwater containment component of the remedy to prevent arsenic-contaminated water from discharging to the Blackwater Branch, from affecting media in the drainage system further downgradient of the site, and to restore the groundwater aquifer. Furthermore, alternative or complimentary measures to help reduce arsenic contaminant mass in saturated soils are currently under consideration.

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OU-2 Groundwater Remedy

The OU-2 phase of the remedy addresses contaminated groundwater at the plant site through pumping/extraction and on-site treatment. Groundwater contamination by arsenic at the site is limited to the shallow Cohansey aquifer. The objectives of the OU-2 remedy are to achieve the aquifer cleanup goal of 0.05 mg/L arsenic in the shallow aquifer to the maximum extent technically practicable, and to minimize the flow of arsenic-contaminated groundwater to the Blackwater Branch. As an endpoint to pumping and treating, the remedy would need to achieve an arsenic plume concentration below 0.35 mg/L, the groundwater concentration at which the in-stream standard of 0.05 mg/L arsenic in Blackwater Branch would not be violated (based on a 7 to 1 dilution). According to the RJ/FS, approximately 13 years of extraction and treatment would be needed to achieve a maximum groundwater arsenic plume concentration below 0.35 mg/L.

Construction of the groundwater extraction and treatment system was completed in 2000 and the groundwater plant began operating in 2001. The extraction system consists of 16 extraction wells screened in the shallow Cohansey aquifer. Real-time and routine daily analyses ensure that arsenic levels in the groundwater are closely monitored. A monitoring well network that consists of 127 wells was put in place. Most monitoring wells are sampled annually and 11 shallow wells semi-annually. Extraction wells are sampled monthly. Water-level measurements are also made on an annual basis.

Data indicate that the extraction and treatment system has been performing satisfactorily and that the system has been successful at mitigating arsenic discharge to the stream. A capture analysis performed by the Remediation System Evaluation investigating team observed that plume capture was complete to the east and south of well MW-31S/M, although minor gaps in the extraction system may be present between extraction well pairs RW-7/RW-8 and RW-2/RW-3 (see Figures 5 and 6). Concentration trends for wells near and downgradient of extraction well lines were also evaluated for indications of contaminant breakthrough. Most wells display stable or decreasing trends, although wells MW-40S and MW-38S displayed increasing trends. These wells are located downgradient of the 'gap' areas and may support the assertion that minor gaps in capture are present. An evaluation of the groundwater flux at the Vineland site also suggests that most of the plume is likely captured. Total pumping from the extraction well system is approximately 700 to 1000 gpm and exceeds the estimated natural groundwater flux of what is estimated to be 260 to 520 gpm under non-pumping conditions. These data indicate that most of the plume is likely captured and that the extraction system may be drawing significant water from the stream.

An evaluation of groundwater arsenic concentration trends was performed for monitoring wells at the Vineland site as part of the RSE. Of 115 wells evaluated, over half were considered non-detects. Seventeen wells show decreasing trends. Six wells, screened in the shallow aquifer, showed increasing trends in total arsenic. Many trends displayed short-term increases due to post-excavation (of the source area) activity followed by a decrease.

Further evaluations were made to compare the extent of the plume in which arsenic concentrations are greater than 0.35 mg/L for the periods 2002/2003 and 2008/2009. For the

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shallow zone, there appears to be no substantial decrease in the size of the plumes during these periods, although a limited isolated plume in the southwestern part of the site had disappeared by the later period. There are also some increases in plume size in the northeast on the south bank of the Blackwater Branch, likely a result of plume redistribution by the recovery system. For the middle zone (deeper aquifer), the extent of the plume has not significantly changed between 2002/2003 and 2008/2009, although arsenic concentrations have decreased significantly in many wells including recovery wells (see Figures 7, 8 and 9). To further complicate the understanding of plume distribution, it does appear that near-well interferences associated with arsenic/iron geochemistry may result in higher than actual readings in a number of monitoring wells. This phenomenon, sometimes called well placqueing/scaling, is currently under investigation and may result in a reduction of the overall plume distribution.

A regression analysis performed for arsenic concentration trends in extraction wells shows that most decreases occurred in the first few years of operation and the rate of decrease is slowing. It would take from less than a year to 20 years for water quality in wells to reach the 0.35 mg/L target. Stable but elevated concentrations of arsenic remain in different parts of the plume necessitating continued use of some of the extraction wells beyond the 13 years of pumping originally anticipated in the ROD.

An evaluation of the effectiveness of the monitoring program employed at the Vineland site was also performed as part of the RSE. Using qualitative and quantitative means, an assessment of concentration trends, monitoring frequency, network redundancy, and network sufficiency was made. Based on the evaluation, the monitoring program appears to be adequate and effective in monitoring the contaminant condition in groundwater at the site (pending the results of the near well phenomenon investigation). The evaluation supports the use of annual sampling for most wells and shows that few wells should be excluded from the network, and that no significant gaps in the monitoring program were indicated.

The various components of the extraction and treatment system appear to be very well maintained. Extraction wells and piping are commonly beset with bio fouling and scaling problems, which tend to reduce the specific capacity of wells and the efficiency of pumping. Nevertheless, wells are routinely inspected and treated with chemical agents (one of which is Redux), jetted, and/or redeveloped when clogging develops.

OU-3 Stream River Area Sediments Remedy

According to the ROD, contaminated sediment along the Blackwater Branch is to be excavated and treated by ex-situ soil washing following the establishment of control of contaminated groundwater by the extraction and treatment system. The Blackwater Branch west of the site is currently undergoing remediation. A reach of the stream north of the site has been remediated and restored. The last phase of sediment excavation of the Blackwater Branch between the Maurice River Parkway and near the confluence with the Maurice River is currently underway and should be completely excavated and restored by the end of 2014.

OU-3 also includes the Maurice River. Once the source of contamination into the Maurice River from the Blackwater Branch has been eliminated, the river will be monitored over a three-year

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period to determine the effectiveness of natural flushing of the sediments. While the ROD called for the three-year period to start once the extraction and treatment system eliminated discharge to the river, it was recognized that contaminated sediments within the Blackwater Branch were also serving as a source of contamination to the river. A remedial strategy to cut off this source of contamination to the river was developed and implemented. Sequencing the work in this manner eliminated the Blackwater Branch sediments as a source of arsenic contamination to the Maurice River before the three-year monitoring period for natural flushing will begin. If effective, no significant remedial action may be needed. If natural flushing does not reduce sediment concentrations to acceptable levels, active remediation of the river sediments will be necessary.

OU-4 Union Lake

The ROD envisioned a limited action as an interim remedy for Union Lake whereby contaminated sediments near the shores would be dredged and removed. This would occur once a determination is made that the Maurice River no longer represents a source of arsenic contamination to the lake. At a minimum, cleanup of lake perimeter sediments could occur following the three years of monitoring the Maurice River or, alternatively, after the implementation of any necessary remedial action in the river. Since the lake is the sink or collection point for the arsenic, there is a potential that more extensive remedial action will be required for sediments in Union Lake. Additional study will be required to not only understand the levels of contamination in lake sediments, but their patterns of distribution and redistribution associated with flow patterns, weather events and seasonal conditions. For example, during periodic sampling from May 2006 through April 2010, arsenic sediment results from a north end of Union Lake sample ranged from 14 to 410 mg/kg, and results from a south end Union Lake Beach sample location ranged from 9.8 to 160 mg/kg. Further, surface water results for the after agitation sample at the south end of the lake ranged from non-detect to 550 fig/L. The extent of this remediation will be determined in the future.

5.4 Site Inspection

EPA RPMs (Nica Klaber and Ron Naman) and site hydrologist (Ed Modica) arrived at the site on the morning of March 15, 2011. The team attended progress meetings for OU-1 and OU-3, and a well meeting, in order to receive updated information from the previous month. This meeting serves to evaluate ongoing pumping operations and adjust pumping rates to optimize the extraction system. At the completion of the progress meetings, a more detailed inspection was performed on the groundwater treatment facility.

General Observations

The groundwater treatment facility is in excellent condition and is well-maintained. The State of New Jersey permit equivalencies are current and in compliance for treatment plants and groundwater withdrawal programs. All parties involved are pro-active at identifying problems or potential problems and identifying corrective actions to address those problems. This aggressive approach appears to have minimized system downtime that could negatively affect the protectiveness of the remedy and is reflected in the agenda and minutes from the weekly meetings. Ongoing site operations have an outstanding safety record and quality control

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measures are monitored closely.

Monitoring data is evaluated on a regular basis to ensure progress is being made to meet the objectives identified in the ROD. Monitoring systems are in place with both real-time and time dependant capabilities to ensure that treated water exceeding the ROD criteria of discharge is not released into the environment. Modifications to the system are made when necessary to correct any deficiencies or make improvements to the system in order to meet these objectives.

5.5 Interviews

An interview was conducted with Steve Gillespie, the on-site Project Manager for Sevenson Environmental Services (SES). SES is the prime contractor under the Interagency Agreement (IAG) with USACE for operation of the groundwater treatment plant and the remediation of Blackwater Branch. Interviews consisted of questions from the FYR Checklist in Appendix D of the FYR Guidance (IEPA 540-R-01-007) and general questions regarding project history and ongoing activities.

6.0 Technical Assessment

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

The remedy for the Vineland Chemical Company site is generally functioning as intended by the decision documents. According to the ROD and ESD, the remedy is being implemented in four discrete phases or operable units. OU-1: source control remedy - calls for soil washing of arsenic-contaminated soil on the site, demolition of contaminated buildings, and the closing of impoundments. OU-2: the groundwater remedy - calls for pumping and treating contaminated groundwater. OU-3: the stream and river area sediment remedy - involves the excavation/ dredging and treatment of Blackwater Branch and possibly Maurice River sediments. OU-4: the interim remedy for Union Lake sediments - calls for removal and treatment of lake periphery contaminated sediments. OU-1, OU-2 and the Blackwater Branch portion of OU-3 were the first remedy components implemented, whereas the Maurice River portion of OU-3 and OU-4 would be implemented in later phases so that upgradient contamination can be addressed first.

The OU-1 excavation and treatment of site soils began in 2003 and was completed in late 2007. Site buildings that were pervaded by arsenic contamination were demolished and the building materials disposed off-site. The objectives of the soil remedy have been met in that all identified contaminated soil, located mostly in the unsaturated zone, was successfully remediated, thereby reducing the potential for direct contact as well as reducing the arsenic impact on groundwater. Arsenic-contaminated materials beneath the water table are managed by the OU-2 groundwater treatment plant. The pump and treat system began operating in 2001. It has been performing as designed and has been successfully reducing arsenic contaminant levels in groundwater and preventing the migration of arsenic to Blackwater Branch. While the plant has been operating properly, groundwater arsenic levels in the aquifer have not dropped as predicted, likely as a result of residual contamination in saturated soils. Once the Blackwater Branch sediments have

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been addressed and no longer act as a source of contamination to the Maurice River, the river will be evaluated over a three-year period to determine the effectiveness of natural flushing of contaminated sediments to the lake, or, if and to what degree, active remediation is necessary. Contaminated sediments near the shores of Union Lake are yet to be dredged and removed. This phase of the remedy has not been implemented.

Institutional Controls

In May 2007, EPA completed the process of having the area encompassing the arsenic-contaminated aquifer designated as a NJDEP/State of New Jersey Classification Exception Area with a Well Restriction Area (CEA-WRA). With this institutional control in place (see Figure 10), the risk of uncontrolled exposure to the arsenic-contaminated groundwater has been greatly reduced. EPA maintains a presence on-site through a regularly-manned USACE and contractor field office. Technical staff members conduct periodic reviews to minimize the risk that a private pumping well could be installed.

6.2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

The site is comprised of four OUs. The RAO for OU-1 is to treat the on-site soils — a cleanup goal of 20 mg/kg was selected. This concentration is consistent with state-wide background levels of arsenic in New Jersey. It should be noted that this value does not take into account the potential for migration to groundwater. However, as the state-wide background concentration remains around 20 mg/kg, this level is considered appropriate. The OU-1 RAO also included the closing of the surface impoundments and cleaning the chicken coops. These objectives remain protective o f human health.

The OU-2 RAO involves containment and restoration of groundwater to its designated use as a drinking water source. At the time of the ROD, the MCL for arsenic was 0.05 mg/L. In January 2006, EPA's revised MCL for arsenic in drinking water went into effect and was reduced to 0.01 mg/L. Subsequently, also in 2006, the State of New Jersey revised its MCL for arsenic to 0.005 mg/L. In addition, the state established a groundwater quality standard for arsenic of 0.003 mg/L (the higher of the practical quantification level [PQL] or groundwater quality criterion). The PQL is the lowest concentration of a constituent that can be reliably measured among available laboratories within specified limits of precision and accuracy during routine laboratory operating conditions listed at N.J.A.C. 7:9C-1.9 or are listed in the calibration specifications or quality control specifications of an analytical method. The remedy must therefore be able to meet the most stringent cleanup standard — i.e., 0.003 mg/L. Remedy performance is currently being augmented based on recommendations of the Remedial System Evaluation to achieve plume containment and groundwater treatment consistent with the state groundwater quality standard. In addition, an IC, in the form of a Classification Exception Area, is in place to prevent use of groundwater.

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At the time of the ROD, a surface water goal of 50 ug/L was identified consistent with the federal drinking water MCL based on the reasoning that surface water could represent a source of drinking water. Some additional evaluation is recommended to determine whether a different surface water goal would be more appropriate.

The RAOs for OU-3 include dredging arsenic-contaminated sediments from the Blackwater Branch and floodplains, and, after a three-year flushing period, from the Maurice River, if necessary. The remediation goal for exposed sediments in the Blackwater Branch and the Maurice River is 20 mg/kg. This value is consistent with background soils, and remains protective of human health. Sediment and surface water data have been collected on a regular basis since May 2006. The first fish tissue data since the Remedial Investigation was collected in 2009. These data suggest that recreational exposure to surface water and sediments does not result in unacceptable health risks. Review of the fish tissue data indicates that although there are unacceptable levels of risk associated with ingestion of fish containing arsenic for specific populations, the specific fish and populations of concern are covered by existing state health department advisories on fish consumption for polychlorinated biphenyls (PCBs) and mercury. Additional fish tissue sampling and evaluation is ongoing (summer 2011).

The remedy for OU-4, Union Lake sediments, is an interim remedy, that includes evaluation of sediments after the three-year flushing period and, if necessary, excavation. The remediation goal for sediments in Union Lake is 20 mg/kg. This value is consistent with background soils, and remains protective of human health. Cleanup decisions for both the Maurice River and Union Lake will also consider the potential ecological risks associated with the contaminated sediments.

An exposure pathway that was not considered in the original assessment is vapor intrusion into indoor air. However, since volatile organic compounds (VOCs) or other vapor forming chemicals are not of concern in soil or groundwater at this site, vapor intrusion is not an issue.

Ecolosical Risk

Although a risk assessment was not conducted to assess ecological risk, sediments were removed two feet below the water table and the area was backfilled with clean material. Therefore, the exposure pathway to ecological receptors from sediment contaminants has been appropriately addressed in those areas where sediments have been excavated. Further, the measured effluent concentrations and surface water values are below New Jersey N. J. A. C. 7:9B Surface Water Quality Standards chronic values (150 /ig/L) of concern for aquatic receptors and, therefore, are protective of ecological receptors. Additional sediment samples should be collected to assess the effectiveness of the groundwater remedy and to determine whether arsenic concentrations are associated with unacceptable risks to environmental receptors.

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

Several issues have been identified during the five-year review. The toxicity of arsenic is under

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review by the IRIS (integrated risk information system) program. Upon completion of this review, any changes to the toxicity values will be evaluated to identify whether they impact the protectiveness of the remedy. Additionally, the MCL for arsenic has been lowered. The new federal drinking water standard is 10 ug/L, and the state has established a groundwater quality standard for arsenic of 0.003 mg/L.

Near-well geochemistry effects have also called into question the accuracy of monitoring well data. Higher than anticipated monitoring well arsenic concentrations have been recorded near pumping wells with reduced levels. Placqueing or a phenomenon associated with elevated arsenic coinciding with elevated iron levels (iron coating on well screens and within the adjacent aquifer formation material) is a potential cause for high readings. This phenomenon is being evaluated this summer/fall (2011), through a well redevelopment and sampling study. This could further reduce the footprint of the plume.

7.0 Issues and Recommendations

See also Tables 3 and 4 at the end of this document.

Some arsenic-contaminated soils remain in the saturated zone at the site. These soils are likely a continuing source of arsenic contamination to the groundwater and will extend the time for the groundwater cleanup. Studies involving the immobilization of arsenic in saturated soils are being proposed for the site to help expedite aquifer cleanup. Other studies involving the mobilization of arsenic are also proposed. The latter studies envision using a chemical amendment, such as oxalic acid, to help release arsenic from the soils to the groundwater, to be captured by recovery wells. These studies should be pursued as they may lead to application of remedial techniques that complement existing remedies to help reduce the arsenic contaminant mass at the Vineland site.

Groundwater contamination near wells MW-54S/M exists on the north side of the Blackwater Branch. The source of contamination in this area has not been determined. Additional wells and soil borings have already been proposed to characterize the extent of groundwater contamination in this area.

There is some evidence of incomplete plume capture between the extraction well pairs RW-2/3 and RW-7/8. Further investigation is warranted. USACE has proposed well locations for these questionable areas to evaluate their hydraulics. The RSE team found a lack of water level information between extraction wells and Blackwater Branch to the northeast that could be addressed by the installation of additional monitoring points. Additional monitoring wells have been proposed for this area.

Recent work indicates that certain wells may read false positive levels of arsenic contamination due to the buildup of iron plaque on the screens of wells in the shallow aquifer where iron chemistry is present. This hypothesis is currently being investigated in order to obtain an accurate understanding of on-site soil, sediment, and aquifer chemistry.

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8.0 IVoleetiveness Statements

Based on the find tags of the five-year review, significant progress has heeti made in reducing pub fie ill! ecotogical or eivmiimental exposure to arsenic contamination associated with the she, Prottxtiveaess statements for the three operable units subject to this review are pro v Med below,

OU»i: sfmrMerm protective /

The remedy for OLM {plant site soils) currently protects human. health and the environment because coniaintnated soils above the water table h.o e hccn excavated, and treated and the direct contact exposure pathway has been eliminated. In order for the remedy to be protective tn the Jong-term, arsenic source removal or resklua! contamination in saturated .toils below the water table needs to be addressed.

Qlf-2;...skffrM££m.ari^t'i my

The remedy for OU-2 (gramdwaieif currently protects human health and the environment because the extiaction and treatment system prevents the oiT-siie migration of arsenic-eotttamfoaied groundwater and no one in the area is using the water for potable purposes. In cutler for the remedy to be protective In the long-term the remaining arsenic corn,animation in saturaied sails needs to be addressed.

OU-3: M'ili i>e pmfective

The remedy for OU-3 (Blackwater Branch and Maurice River) is expected, to be protective of human health: and the environment upon completion and, in the interim. cxposre pathways that could result in unacceptable risks are being controlled through silo security, fishing bans, and restriction of reereatfonal use.

The next five-year review for the1 Vine land Chemical Company site should be completed within five years from the date this review is signed,

9 J Next Review

Etmtgenev and Remedial Response Division EPA - Region 1

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FIGURES

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Figure 2 Figure 2 "* Treatment plant as currently operated

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I f Solids [__ j Dewatenng via j " I Centrifuge |

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AH neatinent conducted with inorganic nnin (1,400 gpm mas. capacity). Organic and inorganic stream? are blended in equalization tank. System operated at approximately 800 gpm.

Pumped • Filter backwash • Thickener overflow • C en-rate

£ Pumped to next stnsre

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TABLES

Page 64 of

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Table 2: Annual OU-2 System Operations/O&M Costs (Contractor Costs Only)

Dates Total Cost rounded to nearest $1,000

From To Total Cost rounded to nearest $1,000

Aug 2005 Aug 2006 $2,434,000

Aug 2006 Aug 2007 $2,464,000

Aug 2007 Aug 2008 $2,621,000

Aug 2008 Aug 2009 $2,458,000

Aug 2009 Aug 2010 $2,352,000

Page 65 of 68

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rABLE3: Issues

Issue # Issue

Affects Protectiveness (Y/N) Issue # Issue

Current Future

1 Potential continuing source of arsenic contamination in saturated soils beneath plant area.

N Y

2

Groundwater MCL for arsenic has changed since ROD. ROD cleanup goal = 50 ppb; federal MCL = 10 ppb; state MCL = 5 ppb; state groundwater quality criteria = 3 ppb.

N Y

3 Small area of groundwater contamination potentially not being captured by existing extraction system.

N Y

4 Arsenic geochemistry may be affecting groundwater quality data.

N

J

N

5 Groundwater ICs established based on MCL at time of ROD. N Y

Page 66 of

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TABLE 4: Recommendations and Follow-Up Actions

Issue #

Recommendations/ Follow-up Actions

Party Responsible

Oversight Agency

Milestone Date

Affects Protectiveness

(Y/N) Current Future

1

Characterize residual arsenic contamination in saturated soils and evaluate remedial alternatives (mobilization/ immobilization studies).

EPA EPA 9/14 N Y

2

Establish new cleanup goals (ground and surface waters) based on current standards and optimize/enhance groundwater extraction and treatment system to meet new goals, if possible.

EPA EPA 9/15 N Y

3

Install new extraction wells, if necessary, based on updated groundwater capture zone modeling northwest of Mill Road/Blackwater Branch.

EPA EPA 9/14 N Y

4 Evaluate arsenic geochemistry and associated impacts on groundwater quality data.

EPA EPA 9/12 N N

5

Update institutional controls (2007 CEA-WRA) for groundwater consistent with new cleanup goals.

EPA EPA 9/15 N Y

6

Develop and initiate sediment sampling program for Maurice River to evaluate natural recovery.

EPA EPA 3/13 N Y

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TABLE 5: Document Review

The following documents were reviewed as part of the five year review:

• Remedial Investigation/Feasibility Study, EBASCO, 1989

• 1989 Record of Decision (ROD)

• 100% Design Analysis Report for the Source Control Remedial Design (OU-l and OU-3), Malcolm Pirnie, February 2000

• 2001 Explanation of Significant Differences (ESD)

• Arsenic Mass Balance for the Blackwater Branch, Maurice River and Union Lake, February 1994

• USACE Philadelphia District, Groundwater Modeling Results

• Groundwater Monitoring Results

• Operation and Maintenance Reports

• Quarterly or Annual Status Reports

• Soil Washing Treatment Plant Optimization Report, August 2004

• Classification Exception Area - Well Restriction Area (CEA-WRA), 2007

• Remediation System Evaluation, March 2011

• Fish Tissue Analysis and Risk Evaluation Report for Maurice River, February 2010

Vineland Chemical Phase V Sediment Sampling Report, February 2011

• Vineland Chemical Spring 2010 Periodic Sampling for OU-3 and OU-4, February 2011

Page 68 of 68

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REFERENCE 46

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U.S. DEPARTMENT OF COMMERCE WEATHER BUREAU LUTHER H. HODGES. Secretary F W" RKICHELDERFER. Chief

TECHNICAL PAPER NO. 40

RAINFALL FREQUENCY ATLAS OF THE UNITED STATES

for Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years

Prepared by DAVID M. HERSHFIELD

Cooperative Studies Section, Hydrologic Services Division

for

Engineering Division, Soil Conservation Service U.S. Department of Agriculture

WASHINGTON, D.C.

Ma j 1961

Repaginated and Reprinted Janoary 1963

Per "1« by the Superintendent of Document*, U>9> Crnrancat Printing Office, WwKington 3S, D.C. Price II. JS

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U.S. DEPARTMENT OF COMMERCE WEATHER BUREAU

TECHNICAL PAPER NO. 40

RAINFALL FREQUENCY ATLAS OF THE UNITED STATES

for Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years

WASHINGTON, D.C.

May 1961

Repaginated and Reprinted JIDBITJ 1963

Page 2 of 5

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Weather Bureau Technical Paper*

•No. •No.

•No. •No.

•No. •No.

No. No.

•No.

No.

•No.

No.

•No. No.

•No.

1. Ten-year normals of pressure tendencies and hourly station presures for the United States. Washington, D.C. 1943.

•Supplement: Normal 3-hourly pressure change# for the United Stake at the inter­mediate synoptic hours. Washington, D.C. 1945.

2. Maximum recorded United States point rainfall for 5 minutes to 24 hours st 207 firet order stations. Washington, D.C. 1947.

3. Extreme temperatures in the upper air. Washington, D.C. 1947. 4. Topographically adjusted normal isohyetal maps for wee tern Colorado. Washington,

D.C. 1947. 5. Highest persisting dewpointa in western United States. Washington, D.C. 1948. 6. Upper air average values of temperature, pressure, and relative humidity over the

United States and Alaska. Washington, D.C. 1945. 7. A report on thunderstorm conditions affecting flight operations. Washington, D.C.

8. The climatic handbook for Washington, D.C. Washington, D.C. 1949. 9. Temperature at selected stations in the United States, Alaska, Hawaii, and Puerto

Rico. Washington, D.C. 1949. 10. Mean precipitable water in the United States. Washington, D. C. 1949. .30 U. Weekly mean values of daily total solar and sky radiation.. Washington, D.C. 1949.

.15. Supplement No-1,1955. .06. 12. Sunshine and cloudiness at selected stations in the United States, Alaska, Hawaii,

and Puerto Rico. Washington, D.C. 1951. 13. Mean monthly and annual evaporation data from free water surface for the United

States, Alaska, Hawaii, and the West Indies. Washington, D.C.' I960. .16 14. Tables of precipitable water and other factors for a saturated peeudo-adiabatic

atmosphere. Washington, D.C. 1951. 15. Maximum station precipitation for 1, 2, 3,6,12, and 24 hours: Parti: Utah,PartII:

Idaho, 1951, each .25; Part III: Florida, 1952, .45; Part IV: Maryland, Delaware, and District of Columbia; Part V: New Jersey, 1953, each -25; Part VI: New England, 1953, .60; Part VII: South Carolina, 1953, .25; Part V1U: Virginia, 1954, .60; Part IX: Georgia, 1954, .40; Part X: New York, 1954, .60; Part XI: North Carolina; Part XII: Oregon, 1955, each .55; Part XIII: Kentucky, 1956, .45; Part XIV: Louisiana; Part XV: Alabama, 1955, each .35; Part XVI: Pennsylvania, 1966, .66; Part XVII: Mississippi, 1956, .40; Part XVIII: West Virginia, 1956, .36; Part XIX: Tennessee, 1956, .45; Part XX: Indiana, 1956, .55; Part XXI: Illinois, 1958, .50; Part XXII: Ohio, 1958, .65; Part XXIII: California, 1959, 61.60; Part XXIV: Texas, 1959, 81.00; Part XXV: Arkansas, I960, .50.

16. Maximum 24-hour precipitation in the United States. Washington, D.C. 1952. 17. Kansas-Missouri floods of June-July 1951. Kansas City, Mo. 1952. .60 18. Measurements of diffuse solar radiation at Blue Hill Observatory. Washington, D.C.

1952. 19. Mean number of thunderstorm days in the United States. Washington, D.C. 1952.

.15

No. 20. Tornado occurrences in the United Stake. Washington, D.C. 1952. .36 •No. 21. Normal weather charts for the Northern Hemisphere. Washington, D.C. 1952. •No. 22. Wind patterns over lower Lake Mead. Washington, D.C. 1953. No. 23. Floods of April 1952—Upper Mimiasippi, Missouri, Red River of the North. Wash-

' ington, D.C. 1954. f 1.00 No. 24. Rainfall intensities (or local drainage design in the United States. For durations of

6 to 240 minutes and 2-, 5-, and 10-year return periods. Part I: West of 115th meridian. Washington, D.C, 1953, .20; Part II: Between 105° W. and 116° W. Washington, D.C. 1954. .16

No. 25. Rainfall intonaity-duration-lrequancy curves. For selected stations in the United States, Atimlfa, Hawaiian Islands, and Puerto Rico. Washington, D.C. 1955. .40

No. 26. Hurricane reins and floods of August 1955, Carolines to New England. Washington, D.C. 1966. ' 61.00

•No. 27. The climate of the Matanuska Valley. Washington, D.C. 1956. •No. 28. Rainfall intensities for local drainage design in western United States. For durations

of 20 minutes to 24 hours and 1-to 100-year return periods. Washington, D.C. 1956. No. 29. Rainfall intensity-frequency regime. Part 1—The Ohio Valley, 1957, .30; Part 2— .

Southeastern United States, 1958, 81.25; Part 3—Hie Middle Atlantic Region, 1968, .30; Part 4—Northeastern United States, 1959, 81-25; Part 5—Great Lakes Region, 1960. ' 81.50

No. 30. Tornado deaths in the United States. Washington, D.C. 1967. .50 No. 31. Monthly normal temperatures, precipitation, and degree days. Washington, D.C.

1966. .25 No. 32. Upper-air climatology of the United States. Part 1—Averages for isobaric surfaces,

height, temperature, humidity, and density. 1957, 81.25; Part 2—Extremes and standard deviations of average heights and temperatures. 1958, .65; Part 3—Vector winds and shear. 1959. .50

No. 33. Rainfall and floods of April, May, and June 1957 in the South-Central States. Wash­ington, D.C. 1958. 81.75

No. 34. Upper wind distribution statistical parameter estimates. Washington, D.C. 1958. .40

No. 35. Climatology and weather services of the St. Lawrence Seaway and Great Lakes. Washington, D.C. 1959. .45

No. 36. North Atlantic tropical cyclones. Washington, D.C. 1959. 81.00 No. 37. Evaporation maps for the United States. Washington, D.C. 1959. .65 No. 38. Generalized estimates of probable «n*«in"»n precipitation for the United States west

of the 105th meridian for areas to 400 square miles and durations to 24 hours. Wash­ington, D.O. I960. 81.00

No. 39. Verification of the Weather Bureau's 3&day outlooks. Washington, D.C. 1061. .40

Weather Bureau Technical Papers for Bale by Superintendent of Documents, U.S. Government Printing Office, Washington 25, D.C.

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PREFACE

This publication b intended as a convenient summary of empirical relationships, working guides, and maps, useful in practical problems requiring rainfall frequency data. It is an outgrowth of several previous Weather Bureau publications on this subject prepared under the direction of the author and contains an expansion and generalisation of the ideae and results in earlier papers. This work has been supported and financed by the Soil Conservation Service, Deportment of Agriculture, to provide material for use in developing planning and design criteria for the Watershed Protection and Flood Prevention program (P.L. 566, 83d Congress and as amended).

The paper is divided into two parts. The first part presents the rainfall analyses. Included are measures of the quality of the various relationships, comparisons with previous works of a similar nature, numerical examples, discus­sions of the Limitations of the results, transformation from point to areal frequency, and seasonal variation. The second part presents 49 rainfall frequency maps based on a comprehensive and integrated collection of uj>to-dat6 statistics, several related maps, and seasonal variation diagrams. The rainfall frequency (isopluvial) maps are for selected durations from 30 minutes to 24 hours and return periods from 1 to 100 years.

This study was prepared in the Cooperative Studies Section (Joseph L. H. Paulhus, Chief) of Hydrologic Services Division (William E. Hiatt, Chief). Coordination with the Soil Conservation Service, Department of Agriculture, was maintained through Harold O. Ogrosky, Chief, Hydrology Branch, Engineering Division. Assistance in the etudy was received from several .people. In particular, the author wishes to acknowledge the help of William E. Miller who programmed the frequency and duration functions and supervbed the processing of ail the data; Normalee S. Foat who supervbed the collection of the basic data; Howard Thompson who prepared the maps for analysis; Walter T-Wilson, a former oolleegue, who was associated with the development of a large portion of the material presented here; Max A. Kohler, A. L. Shanda, and Leonard L. Weiss, of the Weather Bureau, and V. Mockus and R. Q. Andrews, of the Soil Conservation Service, who reviewed the manuscript and made many helpful suggestions. Caroil W. Gardner performed the drafting.

PREFACE INTRODUCTION

Histories] review - -General approach -

PART I: ANALYSES -Basic data - - - — Duration anoiysia.. - ............ ... —..—........ Frequency analyaie -Isoptuviat mapa - -Guides for estimating durationi and/or return periods not presented on the maps.. -Comparisons with previous rainfall frequency studies.............................. ....... ............. Probability considerations -Probable maximum precipitation (PMP) - -Area-depth relationships - — -Seasonal variation.............. — ...............—— .... References - -list of tables

1. 8ources of point rainfall data - -2. Empirical factors for oonverting partial-duration series to annual aeries. —.... —...... 3. Average relationship between 30-minute rainfall and shorter duration rainfall for the same return period

List of illustrations Figure 1.—Relation between 2-year 60-mlnute rainfall and 2-year clock-hour rainfall; relation between 3-year 1440-

minute rainfall and 2-year observational-day rainfall - - -Figure 2.—Rainfall depth-duration diagram -Figure 3.—Relation between observed 2-year 2-hour rainfall and 2-year 2-hour rainfall computed from duration diagram. Figure 4.—Relation between observed 2-year 6-hour rainfall and 2-year 6-hour rainfall computed from duraUoo diagram. Figure 6.—Relation between 2-year 30-minute rainfall and 2-year 60-mmnte rainfall Figure 6.—Relation between partial-dura lion and annual series Figure 7.—Rainfall depth versus return period. - - - — Figure 8.—Distribution of 1-hour stations.. —.... — Figure 0.—Distribution of 24-hour stations - ..... Figure 10.—Qrld density used to construct additional maps - - -Figure 11-—Relation between means from 60-year and 10-year records (24-hour duration) Figure 12.—Example of internal consistency check... — — -Figure 13.—Example of extrapolating to long return periods - — -Figure 14.—Relationship between design return period, T yean, design period, Tt, and probability of not being exceeded

in Tt years - -Figure 16.—Area-depth curves - -

PART H: CHARTS 1.—l-ycar 30-minute rainfall 2.—2-year 30-mlnuto rainfall -3.—6-year 30-minute rainfall -4.—10-year 30-minute rainfall — -5.—26-year 30-minute rainfall. ............. 6.—60-year 30-minute rainfall.. ..................— 7.—100-year 30-minute rainfall -g.—l-year 1-hour rainfall i -

CONTENTS

fate Past ii PARTS II: CHARTS—Continued I 0.—2-year 1-hour rainfall ". 16 I 10.—6-ycar 1-hour rainfall 17 I 11.—10-year 1-hour rainfall .... .... ... .... ... 18

12.—26-year 1-hour rainfall 19 * 13.—60-year 1-hour rainfall 20 1 14.—100-year 1-hour rainfall .... 21 3 16.—1-year 2-hour rainfall 22 3 16.—2-year 2-hour rainfall 23 * 17.—^year 2-hour raiufall ... 24 3 18.—10-year 2-hour rainfall ..... ..... 25 8 19.—25-year 2-hour rainfall 26 6 20.—60-year 2-hour rainfall.. .- 27 8 21.—100-year 2-hour rainfall 28 7 22.—1-year 3-hoar rainfall.. ............... .... ... ............. 29 7 23.—2-year 3-hour rainfall 30 7' 24.—6-year 3-hour rainfall 31

26.—M^year 3-hour rainfall. ...... .... ... ...................... 32 * 26.—26-year 3-hour rainfall....... .......... ..... :13 3 27.—50-year 3-hour rainfall 34 3 28.—100-year 3-hour rainfall - 35

29.—l-year 6-hour rainfall — - 36 30.—2-year 6-hour rainfall .... 37

' 31.—5-year 6-hour rainfall 38 3 32.—10-year G-hour rainfall - - 39 3 33.—26-year 6-hour rainfall. - 40

34.—60-year 6-hour rainfall ............. ... 41 3 36.—100-year 6-hour rainfall. - 42 3 30.—1-year 12-hour rainfall... - ........ ..... ... ........ ... ... 43 3 37.—2-year 12-hour rainfall 44 3 38.—6-year 12-hour rainfall - 46 4 39.—10-year 12-hour rainfall 46 3 40.—25-year 13-hour rainfall 47 8 41.—60-year 12-hour rainfall. ................ 48 8 42.—100-year 12-hour rainfall ........... ... 40 8 43.—l-ycar 24-hour rainfall 50

44.—2-year 24-bour rainfall.. ... ............... ........... ........... 51 . 45.—5-year 24-hour rainfall ....... ... .... ............... 52

46.—10-year 24-hour rainfall... ...... ........ .............. .... 53 47.—26-year 24-hour rainfall 54 4B.—60-year 24-hour rainfall - 66

10 49.—100-year 24-hour rainfall ............... 66 II 60.—Probable maximum 6-bour precipitation for 10 square mila .... ..... 57

61.—Ratio of probable maximum 6-hour precipitation for 10 oquare 'miles to 100-year 6-bour rainfall 68 13 62.—Seasonal probability of Intense rainfall, l-bour duration 59 14 63.—Seasonal probability of Intense rainfall, 6-hour duration q0 15 54. Seasonal probability of intense rainfall, 24-hour duration.. ... ......... ................ 61

U

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REFERENCE 47

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PROJECT NOTE : WESTON SOLUTIONS, INC.

To: Pure Earth Recycling Inc. site file

Date: April 13, 2015

W.O. No.: 20114.002.014.1414.00

From: G. Gilliland, Weston Solutions, Inc.

Subject: Drainage Area and Wetland Calculations

Drainage Area: Weston Solutions, Inc. (WESTON®) has calculated the drainage area for the Pure Earth site to be about 85 acres (see attached map). The site sources are situated throughout the site; the topography at and around the site is relatively flat, with a gentle slope generally from north to south; there are no barriers to runoff entering the site from the north; and the drainage area is bounded on the west by North Mill Road and on the north by Gallagher Drive, which act as barriers to runoff flow.

Wetland Frontage: WESTON obtained the most recent wetlands National Wetlands Inventory (NWI) GIS shapefile from U.S. Fish and Wildlife Service (USFWS) (http://www.tws.gov/wetlands/Data/State-Downloads.html"). evaluated the wetlands for HRS eligibility based on the 40CFR 230.3 definition of a wetland, included the HRS-eligible wetlands on the 15-Mile Surface Water Pathway Map (Figure 7) for the site, and used XTools Pro 7 for ArcGIS Desktop to measure and calculate the wetland frontage along each water body within the surface water pathway. There are more than 30 miles of wetland frontage along the 15-mile surface water pathway as follows:

Water Body Length (Feet) Length (Miles) Unnamed tributary 1,340 0.3 Burnt Mill Branch 11,749 2.2 Maurice River to Union Lake Dam 133,847 25.3 Maurice River below dam 17,300 3.3

Wetland Acreage: WESTON obtained and evaluated the NWI data as above, and included the HRS-eligible wetlands on the 4-Mile Radius Map (Figure 6) for the site. WESTON used the ArcGIS Clip tool to clip each wetland area at the distance category buffers and used XTools Pro 7 for ArcGIS Desktop to measure and calculate the acreage of HRS-eligible wetlands within each distance category. There are more than 480 acres of HRS-eligible wetlands within 4 miles of the site, as follows:

Distance Category Area (Sq. Ft.) Area (Acres) 0 to 14 mile 171,641 3.94

Greater than 14 to V4 mile 512,158 11.76

Greater than 14 to 1 mile 2,299,358 52.79

Greater than 1 to 2 mile 5,838,657 134.04

Greater than 2 to 3 mile 5,748,729 131.97

Greater than 3 to 4 mile 6,405,314 147.05

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Sources: 1. National Geographic TOPO! U.S. Geologic Survey (USGS). 7.5 Minute

Series (Topographic) Quadrangles: Newfield.NJ, 1995. 2. Google Earth Interactive Map

(PURE_EARTH_INTERACTIVE_MAP_II 5-22-13.kmz), Pure Earth Recycling Cleanup. Kemron Environmental Services. May 2013. ^ (J

Site Reference Point

Property Boundary

Pure Earth Recycling Inc.

Facility Location Map Pure Earth Recycling Inc.

3209 North Mill Road / 3137 Chammings Court Vineland, NJ 08360

CLIENT NAME:

EPA February 2015 Page 2 of 2

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REFERENCE 48

Page 79: FIVE-YEAR REVIEW REPORT, VINELAND CHEMICAL COMPANY ... · five-year review for the Vineland Chemical Company Superfund site in Vineland, New Jersey. This five-year review is a discretionary

MABLE/Geocorrl2 Version 1.2 - Missouri Census Data Center

Missouri Census Da la Center

MA'BLE/Geocorr/2: Geographic Correspondence Engine

Willi Census 20.10 (and later) Geography

Version 1.2. 2012

To access a version of this application that works with the old 2000 geography go to »eocon 2k.hirni.

Links: t"H IT for Common Codes (related app) | What's new in Geouonlx | ueocon 12 i'sa-nole:- (html-based)

2k version tutorials: ppf | .StftfV.l.Wt.'.lkj'.si.uiiplfss (video-based)

Original help Hir from 1996 (still the best source for explaining how it works)

This form has 5 sections but only the first 2 are required: tni>o' | Putnni | <'!i.-"gruntik' Filter | Point <£ OUnintf | Bounding B"e

® Input Options

Select the state (or states) to process.

Missouri Alabama * Alaska Arizona Arkansas

:glifornia Colorado Connecticut Delaware District Of Columbia Florida * Georgia

For background info re the Source/Target geocodes used in this application see the MdSter Ar&d Geogtephic Glossery Of Terms — iMAGGOl Hie.

All geocodes are as of 2010 unless otherwise specified.

Select 1 or more "SOURCE" Geocode(s)

Entire Universe (no code]

County County SubdivisiorVTown(ship)/MCD Place: City. Town, Village, etc. Census T ract Census Block Group Census Block (+) 5-digit ZiP/ZCT A: ZIP Census Tab. Area 2010

Concentric Ring Pseudo-Geocode (*) Urban-Rural Portion (2012) Urbanized Area/Urban Cluster PUMA ("2012") PUMA (2000-used in ACS data thru vintage 2011)

CBSA: Core Based (Metro/Micro-politan) Statistical Area - 2013 CBSA type: Metro or Micro Metropolitan Division - 2013 Combined Statistical Area - 2013 NECTA (New England only) NECTA division

v'otina Tabulation District: VTD Congressional District: 111th (2009-2010) Congressional District: 113th (2013-2014) State Legislative District - Upper Chamber (as of 2012) State Legislative District • Lower Chamber (as of 2012) State Legislative District - Upper Chamber (old 2010) State Legislative District - Lower Chamber (old 2010) Unified School District Elementary School District Secondary School District County Size Category ' Place Size Category

Select 1 or more "TARGET" Geocode(s)

Entire Universe (no code] State County County Subdivision/!own(ship).'MCD Piece: City. Town. Village, etc. Census Tract Census Block Group Census Block {+) 5-digit ZIP/ZCTA: ZiP Census Tab. Area 2010

Urban-Rural Portion (2012) Urbanized Area/Urban Cluster PUMA ("2012") PUMA (2000-used in ACS data thru vintage 2011)

CBSA: Core Based (Metro/Micro-politan) Statistical Area - 2013 CBSA type?: Metro or Micro Metropolitan Division - 2013 Combined Statistical Area - 2013 NECTA (New England only) NECTA. division

Voimg Tabulation District: VTD Congressional District: 111th (2009-2010) Congressional District: 1i3th (2013-2014) State Legislative District - Upper Chamber (as of 2012) State Legislative District • Lower Chamber (as of 2012) State Legislative District - Upper Chamber (old 2010) State Legislative District - Lower Chamber (old 2010) Unified School District Elementary School District Secondary School District County Size Category » Place Size Category :

Notes:

+ If vou chose census block then you may not choose more than 10 states.

' If you chose "Concentric Ring Pseudo-Geocode" from either list (above) then you must specify the "Point and Distance" or "Ring Geocode" options below.

Weighting Variable: Specify the variable to use for determining the portion of the source g

I Population (2012 est. - see note below) |Land Area (square miles) Housing Uniis (2010 census)

I Population (2000 census, estimate)

SI Ignore Census Blocks with a the weighting variable.

Note: Do NOT use the 2012 estimate as weighting variable when working with small (sub-county) geographic areas. The 2012 estimate for each block is just the pop2010 value multiplied by a county-based change-in-pop factor..

http://mcdc.missouri.edu/websas/geocorrl2.html

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MABLE/Geocorrl2 Version 1.2 - Missouri Census Data Center

' Output Option*

53 (J Have weighted centroids calculated and kept Generate 2nd allocation factor (AFACT2): portion of target Sort by target geocodes, then source geocodes (default on the output file(s) geocodes in source geocodes is by source, then target)

You have your choice of 2 output formats: a comma-separated-value (" csv") file and/or a report formal ("listing") file. For each file you can specify whether you want just the geographic codes, or the codes and the names associated with them (where applicable), or just the names.

Comma Separated Value File

• Generate a CSV tile • Use tabs as delimiter

Listing File

S Generate a listing file Format: [htmi

Just Codes(No Names)

Just Names (No Codes)

(Optional) Title for output report:

Just Codes (No Names)

Just Names (No Codes)

J ® Geographic Filtering Options

NOTE: This section allows you to specify options that will limit the geographic universe to be processed. If you just want to process the entire state(s) that you have selected then you can ignore this section. You can specify any or all of 4 types of geography to limit the universe to be processed. You may, for example, only want to see a tile with geography for a set of counties, or for a specific metro area (or areas), or possibly for a city (place). You can do so by entering the appropriate F1PS (Federal Information Processing Standard) codes in the text entry boxes that follow. If you need to look up the codes you can click on the links to the code-list files in each section (the section headers are also the links) or use the Cure for ilie Common Codes web app.

By default, if you specify more than one kind of geography here then the application assumes that you want to "and" the selections, keeping only areas that satisfy all criteria. For example, if you specified three counties and a metro area, you would only get data based on blocks that were in both the counties and the metro area (i.e. the

intersection of the selected areas.) To override this default and choose geographies that satisfy any (rather than all) of your select criteria — click here: •

All selections made below are in addition to the state-level or distance-based filtering which you specify

Count v codes. Enter 5-digit F1PS county codes with leading zeroes separated by blanks. You may enter 3-digit codes if you selected only one state. Your output will be limited to the counties specified. Examples:

• 29189 29510 17163 17119 (selects 4 counties in 2 states) • 005 017 049 (selects 3 counties from the single state selected)

Metro Area CC'BSA" i codes. Enter 5-digit Core-Based Statistical Area codes here to filter based on the Metropolitan/Micropolitan statistical areas. You can use the special value -99999 to select only those places which are outside any metro or micropolitan area.

Note that we no longer support filtering using the old (vintage 2000) 4-digit MSA/CMSA/PMSA codes.

Examples:

• 27620 42740 (Selects the Jefferson City Metropolitan and Sedalia Micropolitan Statistical Areas (MO) • -99999 (Selects all geographic areas that are NOT within a CBSA).

Place codes. Enter 7-digit FIPS place codes with leading zeroes separated by blanks. You can enter 5-digit codes if only one state has been selected. Your output will be limited to the official city limits of these cities as of the 2010 census. Enter a value of -99999 to indicate that you want to exclude all areas that are not inside any place. You will get all areas that are unincorporated and not within a Census Designated Place. Examples:

• 70520 70545 70550 53780 06020 (Saginaw City, Saginaw Township North and South, Midland, Bay City, M])

• -99999 You will get output that excludes any geographic area not included within a pi ace.

Reset Defaults Run Request j

® Point and Distance Options

Specify a point (location) and distance to be used as filter:

Value for radius of Circle or radius of largest Ring: [4 I (In miles, unless you check • here to specify kilometers.)

See iust below for links to help find coordinates. If you just want to do a test you can enter the values 38.7070 & 90.3127 which are the coordinates of UMSL in St Louis county, MO.

Coordinates of Point: 139.532697 ] degrees latitude, j -75.053197 | degrees longitude

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MABLE/Geocorrl2 Version 1.2 - Missouri Census Data Center

Label of Point: [Pure Earth Recycling inc., MW-1 ^optional)

Define Ring criteria (if Concentric ring geocode selected above) specifying only one of the following two options:

1. Q !# of equi-distant rings (integer value 1 to 10). Radius specified above will be divided by this to derive width of each Ring.

-OR-2. Specify your own custom list of up to 10 ring radii values in ascending order (values must be greater than zero, may be fractional, and largest should equal the radius

of the Circle specified above): „

ui[25 | 1 «[i j HIIIIZ! O #6EZZZ1 #7I ! mi J #9i Note: A ring is identified on output files by its outer radius. E.g., a ring of 4 to 8 miles will have code 8.

Link, .re provided here »Iseilitale obtaining coordinates for your location. (Click fTS*"] to use google maps lo specify LadLong or see Usasijitdsr lor links 10 web sties where you can enter an address and gel lis l.lilude-longitude

coordinates.) Note: If you specify a lal-iong location the variable "distance" will be added lo your output. This require:; lhal weighted cetitroids also be calculated (set automatically). 'Ihe "distance" variable will be between the weighted centroid and the specified Point. If you specify King Pseudo-Geocodes then distance and weighted centroid values will not be calculated or stored (because weighted ccniroids of donuts are misleading).

9 Bounding Box Filter Options

If you want to limit processing to blocks with center points that fall in a specified rectangular area you can enter the coordinates for such a "bounding box" here.

Define the "bounding box" coordinates in decimal degrees:

| Northern-most Latitude [ i Southern-most Latitude

[ Reset Defaults j [ Run Request J

] Western-most Longitude j j Eastern-most Longitude

Internal use only (ignore): |0

Please direct all questions and comments to

Last Modified: 03/2S/20IS 10:22:30

http://mcdc.missouri.edu/websas/geocorrl2.html

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Geocorrl2 - 16APR0934005

MABLE/Geocorr 12 Results

geocorrl2 1.2 Rev. 10/22/2014 1:26:27 PM Processing started at OSEDA/MCDC/Univ. of Missouri at 9:34:30 on 16APR15 (CDT) Job id: 16APR0934005 Requested states to be processed: 34 New Jersey

Source geocodes requested: state Target geocodes requested: ring

Output will show how combinations of the source geocodes you have chosen relate to the chosen target geocodes.

Blocks will be selected only if within a distance of less than 4 miles from a user-specified point labeled: Pure Earth Recycling Inc., MW-1, with coordinates: longtitude 75.053197 ,latitude 39.532697.

User has specified ring pseudo-geographic areas with the following outer diameters (ring geocode added to outputs): 0.25 miles 0.5 miles 1 miles 2 miles 3 miles 4 miles

Specs appear to be valid...request being processed. Please be patient.

572 census blocks selected and will be processed to create output files...

Phase 1 processing complete. Elapsed time: 1 seconds.

Phase 2 (invoking corrwt macro) completed...

***Listing output file has been generated.***

6 observations on output correlation list.

Output Files

Processing completed! Retrieve your results by following the links to your output file(s), above.

Processing ended at 9:34:30 on 16APR15. Total elapsed time: 1 seconds,

-fini-

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SAS Output

4-Mile Populations, Pure Earth Recycling Inc.

PIPS state State Postal Code

Ring Area Total Pop, 2010 census

state to ring alloc factor

ring to state alloc factor

34 NJ 0.25 20 0.001 1.000

0.50 75' 0.002 1.000

1.00 684 0.019 1.000

2.00 4716 0.132 1.000

3.00 11897 0.334 1.000

4.00 18202 0.511 1.000

Report Produced on 16APR15 by geocorr12 1.2 Rev. 10/22/2014 1:26:27 PM

http://mcdc.missouri.edu/tmpscratch/16APR09l8316.geocorrl2/geocorrl2.html

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