CRISIS Encourages Investigations in Superfund Cleanup

To the Editor:

The U.S. Environmental Protection Agency [EPA] held a . The Plan is based on the Comprehensive Site-wide Feasibility Study [SWFS] dated February 2012.

CRISIS adopted Technical Advisor Tom Germinario’s recommendations as the organization’s general position, subject to our review of any additional information that may be forthcoming during the public comment period.

The Proposed Plan advances Alternative 4A from the SWFS as the remedy for the six impoundments addressed in this phase of the site cleanup. Impoundments 1 and 2, which contain the most dangerous concentration of hazardous wastes on the site, are NOT INCLUDED in this phase; they are the subject of a separate study.

The mainstay of Alternative 4A calls for a process known as in situ solidification/stabilization [s/s]. This means leaving much of the hazardous waste in place [in situ] in the impoundments being remediated. While this may not sound like an ideal solution, it appears to be the most feasible under the current circumstances, mainly because of the characteristics of the waste to be treated. Solidification/stabilization has been effective in preventing waste from migrating offsite at other Superfund locations.

It is crucial to note that CRISIS’s support for this alternative is based on the following conditions:

• Long-term groundwater treatment should rely on an on-site system designed specifically for the site’s contaminants, not on the Somerset Raritan Valley Sewerage Authority’s [SRVSA] municipal wastewater treatment system.
• Interim groundwater treatment at the SRVSA should be subject to enforceable effluent limitations for VOCs and SVOCs.
• Materials in the floodplain requiring direct contact, vapor or movement control should be relocated to the Main Plant area and covered by an appropriate, engineered multi-layered cap.
• Bench-scale testing should be conducted during the remedial design phase to determine the most effective combination of amendments, stabilizing agents and geogrids to be used in the in­situ s/s process.
• Principal threat wastes, if any, located in impoundments 13, 17 and 24 should be removed and consolidated in Impoundments 3, 4 and 5 for in­situ [in place] s/s treatment. The same should apply to any principal threat wastes, including tarblooms, located outside the impoundments.

We have asked that each of these conditions be incorporated into the Record of Decision for this phase of the site cleanup.

Several other potential treatment methods were considered during the remediation studies which can be referenced in the SWFS.

One area environmental group may propose the use of Low Temperature Thermal Desorption [LTTD] as a remedy. It involves in-place thermal treatment that causes the contaminants to separate [desorb] from the soil without burning. The vapors are then captured and treated. Germinario has expressed the view that the process would not be suitable for the impoundments in this phase of the remediation. Here is an excerpt from his report:

"Anyone with any degree of familiarity with Impoundments 3, 4 & 5 would conclude that LTTD is NOT a good fit. It works well primarily with soils that are contaminated with PHC [petroleum hydrocarbons]. The contaminants have to be relatively homogeneous because there's a specific range of temperatures that needs to be applied to volatize the contaminants while not oxidizing [burning] them. Also, the sticky tar consistency of this waste [Impoundments 3, 4 & 5] would make a mess in an LTTD system. The tar would have to be processed into a fine granular material. That would be a difficult task in itself, and would almost surely result in large fugitive emissions of VOCs [Volatile Organic Compounds] during the material processing."

Another potential alternative, removing the waste and transporting if off-site, presents a different range of environmental problems, not the least of which are the threat of “fugitive” air emissions, blowing of contaminated dust and worker safety.

Sincerely,

Walt Sodie

CRISIS, the recipient of EPA Technical Assistance Grants awarded to us for monitoring the clean up of the American Cyana­mid Superfund site