Chrome Update 25 (December 1996)
TO: Hudson County Chromate Waste Sites Mailing List
FROM: Ronald T. Corcory, Project Coordinator, New Jersey Department of Environmental Protection
SUBJECT: Hudson County Chromate Update #25, December 1996
The following summarizes significant developments which have occurred between April 1996 and December 1996 regarding the Hudson County Chromate Waste Sites.
AlliedSignal, Inc. (Allied) submitted a draft Alternative Remediation Standard (ARS) protocol to the Department for review in April 1996. In the interim the Department and Allied have modified the protocol, and the Department is currently reviewing the final draft from Allied. Comments will be issued by mid-December. A remediation standard as defined by the Industrial Site Recovery Act is "The combination of numeric and narrative standards to which contaminants must be remediated for soil groundwater, or surface water as provided by the Department, pursuant to section 35 of P.L. 1993, c.139 (C.58:10B- 12)". A person may also perform a remediation of contaminated real property, by submitting an ARS based upon site specific factors in lieu of using the established minimum remediation standards. The Department must however determine that the requested ARS is protective of public health and safety and protective of the environment. It is anticipated that the development of an ARS for the Allied sites will remove the outstanding issues regarding the current cleanup criteria.
The Communipaw Jughandle Site (Chromium Site 71), is located at the intersection of State Route #440 and U.S. Routes 1 & 9 in Jersey City. This site categorized as an Allied site under their November 8, 1993 supplemental Administrative Consent Order (ACO) with the State of New Jersey. Since the execution of that ACO, Allied has been unable to obtain an access agreement with the current property owner. The Department has also undertaken measures to obtain access to the property and cap the site using public funds. The Department has met with the property owner, and they have expressed a willingness to investigate and remediate the property in lieu of Allied's responsibilities under the ACO.
Allied has also submitted a supplemental interim remedial measure (IRM) work plan for the Roosevelt Drive-In Site (Site 115). This work plan was submitted to address the Department's concerns regarding the durability of the IRM and the potential for migration of contaminated surface water from the site. The plan has been reviewed and approved. Construction activities are anticipated to begin in early December.
In September 1996, NJDEP and G. Heller Enterprises, Inc. entered into a Memorandum of Agreement for performance of a remedial investigation and remedial action at chromium site 117 (also known as Ryerson Steel Site), located on Route 440 in Jersey City. The developer expressed willingness to perform the work as stipulated in the Allied Administrative Consent Order (ACO) in lieu of AlliedSignal, Inc.. The field work for the investigation began on September 3, 1996 and is now complete. A Remedial Investigation report and remedial action work plan was submitted in early November and is currently under review. The clean up of this site will permit the future development of a shopping center with a "Home Depot" as its primary tenant.
Maxus Energy Corporation
In April of 1990, Occidental Chemical Corporation ("Occidental", the successor to Diamond Shamrock Chemicals Company ["DSCC"]) entered into an Administrative Consent Order (ACO) with the State of New Jersey Department of Environmental Protection under which Occidental is obligated to implement certain Interim Remedial Measures, conduct a Remedial Investigation and Feasibility Study, and implement appropriate remedial activities under the oversight of the Department at designated sites in Hudson County, New Jersey with respect to the presence of chromite ore processing residue (COPR) historically used as fill material. DSCC was one of several companies that historically generated COPR in the area. Maxus Energy Corporation (Maxus), under a private contract with Occidental, has been performing Occidental's obligations under the ACO. Effective as of August 1, 1996, Maxus assigned to Chemical Land Holdings, Inc. (CLH), the responsibility for performing Occidental's obligations under the ACO. The Department will now be referring to CLH and Occidental Chemical Corporation as the responsible parties for the operations of the former Diamond Shamrock Chemicals Company located in Kearny, Hudson County.
The Department was notified by CLH that the scheduled due date for the submission of the Remedial Investigation Report was being delayed due to lack of cleanup standards. The Department has approved the extension of the schedule.
CLH has also submitted an Alternative Remediation Standard (ARS) protocol similar to the Allied protocol referenced above. This document is currently under review and final comments shall be issued by mid-December. The final ARS for the CLH sites will remove the outstanding issues over the current cleanup criteria.
The Department received a supplemental interim remedial measures work plan for the St. Johnsbury Site (Site 41) located on Sellers Street in Kearny, Hudson County. The work plan was reviewed and approved. This work is currently underway and is anticipated to be concluded by mid-December.
PPG Industries, Incorporated
The Remedial Action Report for the Group #14 site (Value City Furniture) should be submitted in November 1996. Investigative work at the remaining sites is currently on hold due to the possible change in the chromate cleanup standards for soil.
July 2, 1993 AlliedSignal Directive Sites and Orphan Sites Groups 1 n& 2
The preliminary site characterization (PSC) soil investigations have been completed at a total of twelve sites in the Allied Directive group, they include sites numbered 15, 68, 69, 70, 91, 92, 130, 165, 172, 178, 183 and 185. The analytical data from these investigations is currently undergoing Quality Assurance/Quality Control review. The results and recommendations will be presented in the PSC Remedial Investigation (RI) reports. Monitor wells have been installed at sites 15, 91, 92,165, 183 and 185. Building inspections have been completed at six sites. PSC Ground water sampling has occurred at site 15. PSC Surface water and sediment sampling has been completed at site 15. Eleven site remain to be investigated under this directive.
The contract for the Remedial Investigations of the Orphan Sites Group 1 has been awarded to L. Robert Kimball Associates of Ebensburg, Pennsylvania. A kickoff meeting between the consultant and the Department will take place in December. The Scopes of Work and Workplans for the Remedial Investigations will be started early in 1997.
Orphan Sites Group 2 are still in negotiations with potential responsible parties who may take responsibility for some of the sites in this group.
Suggested Soil Cleanup Criteria for Trivalent and Hexavalent Chromium
The NJDEP is currently developing appropriate responses to the issues identified by the comments received during last year's public comment period. In certain instances information gaps were identified by the comments and NJDEP is attempting to fill these gaps by further research and study. In addition, new information generated externally is also being incorporated into the Department's response. Much of this information is from the United States Environmental Protection Agency (USEPA) and reflects the impact of Executive Order Number 27 and Public Law 1995, c.65 analysis which directs NJDEP to incorporate USEPA standards and guidance.
One of the outcomes of the above was a decision by the Department to initiate rule making procedures regarding chromium remediation criteria. Such criteria, if promulgated, would carry the weight of standards rather than the advisory nature inherent in guidance. A team has been assembled to develop the necessary documentation for rule proposal under the administrative rule making procedures. However, following proposal, the promulgation process is relatively lengthy and may take up to a year to be finalized.
During the informal interested party review, questions were raised about the protection of ground water resources from hexavalent chromium. The Department is currently evaluating a protocol which will focus on using site specific information to determine the appropriate level of remediation required.
Based on comments received, the Department is also reevaluating the allowable levels of chromium in the soil in order to eliminate the generation of potential adverse exposures in the air. Also being considered is the employment of newly finalized USEPA guidance relevant to these calculations.
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