Welcome to CRISIS
epa superfund sites new jersey
NJ superfund sites
CRISIS is the toxic waste cleanup advocacy group of Bridgewater Township, New Jersey. CRISIS has been providing critical and technical oversight on behalf of the public (regarding the American Cyanamid/Pfizer Superfund site) since 1992.
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FAQ's on Impoundments1 & 2, etc.
Frequently Asked Questions
 
American Cyanamid Superfund Site
Somerset County, Bridgewater Township, New Jersey
Impoundments 1 and 2 (i.e. Operable Unit 8) Frequently Asked Questions
 
What are the materials in Impoundments 1 and 2 and how did the material get there?
Impoundments 1 and 2 were used between 1947 through 1965 to store acid tar waste, a by-product of a coal/light-oil refining process conducted at the Site.  Over time, through gravity, this material has separated into primarily two layers; a viscous-rubbery tar-like material and a hard-crumbly granular material.  The materials are characterized by low pH and the presence of volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs), including benzene, toluene, xylenes, and naphthalene.
What is the Impoundment 1 and 2 pilot test?
The pilot test is a common approach in the environmental remediation industry that is designed to help evaluate the effectiveness of promising remediation technologies on a small section of Impoundment 2 material under actual conditions at the Site. 
How will the pilot test be performed?
The pilot test will consist of three tests that will take place within three steel caissons or test cells.  One cell will evaluate the effectiveness of thermal treatment alone, the second will evaluate stabilization/solidification alone, and the third cell will evaluate the combined effectiveness of the two technologies. The treated material will then be analyzed and the results used to determine treatment effectiveness and post-treatment disposition options.  
Why are you not just moving forward with the full clean-up of the impoundments based on the previous treatability studies and bench-scale laboratory results?
Previous treatability studies and bench-scale laboratory studies have shown thermal treatment and solidification/stabilization to be promising technologies.  The limiting factor has been the ability to perform the work safely in the field, including the generation of unacceptable emissions and odors.  Although the methods proposed are considered to be common remedial technologies, they have never been applied in this type of setting.  The pilot test is designed to treat the material under controlled conditions while it remains in the impoundments.  This demonstration test will help determine if these technologies can be safely and effectively implemented on a larger scale.  
Will the pilot test be safe?
The pilot test was designed with safety as the number one priority and consideration.  The testing will occur within steel caissons resembling large columnar tubes that are lowered into Impoundment 2 and secured on a flexi-float platform that is essentially a small marine barge.  Pilot test treatment activities will take place in-situ, within the steel caissons, minimizing exposure for workers and the community. Vapors will be treated in an air control device known as a thermal oxidizer located adjacent to the impoundment and raised out of the flood plain. Air monitoring will be conducted in the work area and at the site perimeter to verify that emissions remain under control during pilot activities.  Additional safety measures (i.e. nitrogen inerting) will be taken to prevent fires and other construction related hazards.
What is the schedule for the pilot test?
Construction of the required infrastructure began in August 2013.  The actual pilot testing involving the impoundment material is scheduled to occur between November 2013 and March 2014.  This schedule could vary depending on weather and other field conditions. Updates to the schedule will be posted on AmCyRestoration.com.
Will the community see the pilot test?
The pilot test will occur during the winter months when foliage is minimal.  Large equipment and lights may be visible to motorists along I-287.  Water vapor discharged from the air treatment system may be visible as a white condensate during the colder months.

Impoundments 1 and 2 FAQs
 
Will the community be disrupted by delivery of trucks and equipment?
We do not anticipate any unreasonable disruption to the community as a result of the pilot test.  The pilot test will use large equipment such as drilling rigs, cranes, caissons, Flexifloats, and treatment units. These materials will likely be delivered to the Site through one of two East Main Street entrances.  Most deliveries will occur during standard business hours and all efforts will be made to limit community disruptions.
Will the community be impacted by air emissions during the pilot test?
The pilot test has been designed for the treatment to take place in-situ, within the impoundments, minimizing exposure for workers and the community.  Vapors generated during the pilot test will be treated on-site a thermal oxidizer under NJDEP air permit requirements that will be issued by USEPA. Air monitoring will be conducted in the work area and at the site perimeter to verify that emissions remain under control during pilot activities.  If air monitoring within the work area identifies emissions of concern, corrective actions will be taken, including temporary shutdown if necessary.
Is the pilot test infrastructure at risk from a flood?
The pilot test was designed to address the potential for flooding.  The flexifloat structure is designed to float on top of the existing impoundments. The flexifloat will be secured by cables and anchors located outside the impoundments to hold the structure in place in the event of a severe flood.
What will happen in the case of a flood, fire or other emergency incident?
Detailed contingency plans have been developed to allow for appropriate response in adverse conditions. USEPA has reviewed the plans and local and county emergency management officials have been briefed on the site safety and emergency response procedures.  In the event of a severe storm or other emergency event, the pilot test may be suspended or terminated.  
Are Impoundments 1 and 2 at risk for failing during this pilot test and impacting the Raritan River?
Impoundments 1 and 2 are regularly inspected and maintained and do not pose an offsite risk.  Routine inspections and recent engineering evaluations have shown that the impoundments continue to perform as designed.  The equipment, infrastructure and technologies used during this pilot test do not present additional risk. The impoundment berms have been recently evaluated by a third-party engineering firm and deemed capable of withstanding earthquake and flood events.
Assuming the pilot test is successful; will these technologies definitely be used in the final remedy?
No decision has been made on the final remedy for Impoundments 1 and 2.  After completion of the field pilot testing, the results of both the laboratory and field demonstration testing will be utilized to develop the FFS report. The FFS will evaluate a range of remedial options for the impoundments, that will take into consideration the remedial action objectives, treatment and ultimate disposition of the impoundment materials, the feasibility, implementability, effectiveness of the remedy (which will include consideration that the impoundments are within a floodplain), and comments from the community and other stakeholders. It is currently anticipated that a draft FFS report will be submitted to USEPA in late 2014.
When will a final remedy be selected?
The draft FFS report, expected to be submitted to USEPA in late 2014, will undergo a thorough evaluation by USEPA and its National Remedy Review Board, NJDEP and other stakeholders. Ultimately, USEPA will select a Proposed Remedy, seek input from the community, and release a Record of Decision.  No timetable has been set for this decision.
Who should the community contact if they have concerns about the pilot test?
Melissa Dimas, USEPA Community Involvement Coordinator, (212) 637-3677, Dimas.Melissa@epa.gov
Russell Downey, Pfizer Project Director, (908) 901-6079, www.amcyrestoration.com
 
SUMMARY OF NOVEMBER 14, 2012 MEETING

A meeting was held on November 14, 2012 between Crisis, Inc. and EPA, NJDEP, Bridgewater Township, Pfizer and its team of consultants that included CH2MHill, Quantum Management and Vita Nuova.  Attending for Crisis were Ross Stander, John Tucciarone and Dr. Ira Whitman, Technical Advisor Designee.

The purpose of the meeting was for Pfizer's engineering consultant, CH2MHill to make a presentation on Impoundments 1 & 2 at the American Cyanamid Superfund site, specifically regarding Laboratory Study Results & Concept, and Design for Field Pilot Testing.  Impoundments 1 & 2, also known by EPA as OU 8, are the most difficult elements of the Cyanamid cleanup and are the sources for the seepage of benzene into the Raritan River, which is being addressed by EPA on an emergency basis. Crisis is providing this summary report on the CH2MHill presentation, but is not endorsing the consultant’s proposals or conclusions. The agenda for the CH2MHill presentation included:

-Focused Feasibility Study Overview
-Impoundment History
-Treatment Technology Screening
-Laboratory Testing Results
-Field Pilot Testing
-Project Timeline

A copy of the entire CH2MHill PowerPoint presentation may be obtained from Crisis by request.  The bulleted categories of this study listed above represent the process described by the consultants as its "Focused Feasibility Study Pathway”.  Highlight of the presentation include:

Impoundment History   Impoundments 1 & 2 were used by American Cyanimid between 1947 and 1965 to store waste from its operation to produce the petroleum derivative compounds benzene, toluene and xylene (btx) from coal light oil.  The waste material stored in the impoundments is known as acid tar, a by-product of the coal light oil refining process.  Impoundment 1 is 2.1 acres in size, and stores approximately 24,000 cubic yards of waste.  Impoundment 2 is 2.3 acres, and stores approximately 30,300 cubic yards.  The impoundments are presently covered with a cap of synthetic membrane and water.  Physically, some of the waste material impounded is known as being "Hard Crumbly (HC)" and some is regarded as "Viscous Rubbery (VR)".  The acid tar material is very difficult to handle, is very acidic, has a high content of volatile organic material including btx, smells bad, and is not homogeneous.

CH2MHill noted that treatability tests had previously been performed on the acid tar material, and that each technology had its limitations, and could not be implemented at the full size scale of the impoundments.

Technology Screening   The engineering consultant noted that a combination of several technologies may be needed to address the complex physical and chemical characteristics of the acid tar waste at American Cyanimid.  Two technologies not previously studied were identified; In-Situ Thermal Treatment and In-Situ Stabilization and Solidification.  CH2MHill commissioned laboratory scale treatability studies for these 2 technologies employing outside sub-contractors that specialize in these methods.  The objective of the laboratory scale testing was to determine the effectiveness of each technology individually and in combination, and to develop a larger range of remedial alternatives considering the "best" results of each individual technology.

Laboratory Scale Testing  CH2MHill obtained sample waste material from the impoundments in early 2012, and provided it to their specialty sub-contractors for use in the laboratory scale treatability testing.

High temperature Thermal Treatment was conducted by heating VR and HC material from impoundment 2.  They noted that heating altered the physical properties favorably; decreasing the viscosity of the VR material, and increasing the compressive strength of the HC material.  Concentrations of the volatile (VOC) materials in the acid tar were reduced, possibly to levels where under federal rules the material would no longer be considered to be "hazardous".  VOC removal can be further enhanced by prolonged high temperature treatment (100°C).  pH of the material was reduced, resulting in a lower degree of acidity.  They concluded that thermal treatment may be a viable stand-alone technology for btx,  but more study is needed, and that it may be necessary to utilize supplemental technologies as well.

Stabilization and Solidification was performed by adding cement-like material, a process that increases the volume of the waste.  pH can be adjusted with this approach, and compressive strength increased.  However, following the performance of the stabilization process, the material still tested "hazardous" under the EPA rules.  They concluded that while Stabilization and Solidification may be viable as a stand-alone technology, combining this with a thermal treatment may yield a viable solution that improves both the chemical content and the compressive strength of the residual waste material.

The consultants noted that despite favorable results from the laboratory scale testing, significant challenges remain in enlarging the scale for pilot and full scale treatment.

Field Pilot Testing   CH2MHill is proposing to conduct pilot tests of the Thermal Treatment and Stabilization & Solidification processes in Impoundment 2 some time in September 2013, believing that such tests will be representative of conditions in both of the impoundments. Impoundment 2 represents the more difficult treatment challenge, because it has a higher proportion of the VR material.

The engineers propose to install three test cells in Impoundment 2, comprised of 8 foot diameter steel columns inserted over the full depth of the waste material.  During treatment, these test cells would be covered to enable the collection and treatment of vapors released during the treatment test period.  The caissons would actually be floated in the impoundment so as to not disturb the clay liner at the bottom of the impoundment.  The caisson technology is a proven method used elsewhere by the contractors who would install it.

The CH2MHill plan is to use one test cell to conduct Thermal Treatment only, a second test cell for Solidification and Stabilization, and the third test cell for combined treatment utilizing both processes. During the tests employing Thermal Treatment, vapors and water released by the treatment process would be collected and treated.

Focused Feasibility Study Report   Pfizer's consultants are presently working on the scoping and design of the field pilot tests.  They are expecting to complete and deliver a "Focused Feasibility Study Report" in April 2014, assuming that the field pilot testing is carried out in September 2013.

Crisis' Response   Crisis, Inc is reviewing the details of the Pfizer plan as presented on November 14, 2012 by CH2MHill, and will be preparing a letter to EPA with it's questions, comments and concerns.  That letter will be posted on this web site.