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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.


Reports and Memos

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Ira L. Whitman, P.E., PhD Technical Advisor

March-April 2015

Issued May 13, 2015

On March 26, 2015 members of the Executive Committee and Board of CRISIS, Inc. met with representatives of Pfizer and EPA at a long-planned meeting on the subject of Ecological Risk Assessment (ERA) for three specific impoundments on the Am Cyan site; Impoundments 13, 17 and 24.  CRISIS requested such a meeting last fall based on the schedule for this component of the site-wide OU4 pre-design investigation for this module of work.  EPA agreed, and a presentation to CRISIS was planned for January, but postponed until March due to the terrible weather conditions this past winter.

The three Impoundments studied all contain serious hazardous chemicals, and are each in flood-prone areas on the river-side of the flood protection berm that protects the more “upland” areas on the property.  CRISIS has long expressed its concerns that areas where hazardous wastes are situated that are not within the flood protection zone are particularly vulnerable and therefore of potential hazard to the surrounding communities.

march 26 meeting

Following EPA’s site-wide Record of Decision of 2012 for the American Cyanamid Superfund site, Pfizer began a comprehensive technical phase leading to the eventual construction/remediation for a majority of contaminated areas of the site.*  The first major step in this process is known as Pre-Design Investigations (PDI) which by their most recent Monthly Progress Report, Pfizer states are 88% complete.  The results of these PDI’s will have a direct bearing on the final remediation of the site including which materials will be capped in place, and which will be transported to locations beyond the flood plain, or off-site – hence CRISIS’ concerns for Impoundments 13,17 and 24.

EPA Presentation

The initial presentation on March 26 was given by EPA, and dealt with Ecological Risk Assessments in general.  EPA’s message can best be summed by its definition of the ERA

*The major exception is Impoundments 1 & 2, located nearest to the Raritan River, which contain particularly nasty and difficult to treat chemicals.  I have reported on actions for these impoundments (designated OU8) in several of my Technical Reports over the past 2 ½ years.  The schedule to remediate OU8 is several years behind OU4.

“The Ecological Risk Assessment is a process that evaluates the likelihood that adverse ecological effects are occurring or may occur as a result of exposure to one or more stressors.”

Baseline ERA focuses on:

The chemicals (stressors) at the site.

The pathways available (erosion, dust, runoff, percolation into the soil, ground water, etc.) for the chemicals to reach the “receptors”.

Receptors – species of organisms in the food chain including invertebrates, amphibians, rodents, birds and mammals.

EPA made it clear that a Baseline ERA is conducted only if a “Screening Level” ERA, which compares contaminant concentrations to literature scientific benchmarks, shows it to be necessary, which apparently was the case with Impoundments 13, 17 and 24.  In an earlier Baseline Ecological Risk Assessment of other areas of the site, EPA indicated that “on-site habitat does not support threatened or endangered species”.

Prior Risk Assessment Studies at Am Cyan Site

A Baseline Risk Assessment was concluded in 2005 that pertained to terrestrial areas on the Am Cyan site apart from these impoundments.  EPA concluded that these other areas are subject to an acceptable level of ecological risk.

It is not clear whether an Ecological Risk Assessment per se was conducted for the aquatic areas of the site; i.e., Cuckel’s Brooks and the Raritan River.  However, Surface Water Quality Standards adopted for these two water courses are New Jersey Ecological Water Quality Standards, which are more stringent that New Jersey’s health based surface water quality standards.  As a result, Pfizer is required to conduct semi-annual surface water and sediment monitoring in Cuckel’s Brook and the Raritan River, the results of which I review on a regular basis. My Technical Reports of August, July, June and March 2014 addressed surface water quality issues at the site.

EPA’s Record of Decision of 2012 cites both Human Health Risk Assessments and Ecological Risk Assessments conducted in the past, and concludes; 

“Based upon the results of the risk assessments conducted to date, EPA has determined that actual or threatened releases of hazardous substances from the site, if not addressed by the preferred alternative or one of the other active measures considered, may present a current or potential threat to human health and the environment.”

EPA’s 2012 ROD indicated that Impoundments 13, 17 and 24 were not included in earlier Risk Assessments, and specified that an Ecological Risk Assessment will be performed during the remedial design for these impoundments.  It is this ERA that was reported on by Pfizer on March 26.

ecological risk assessment, impoundments 13, 17 & 24

Issues of Flooding

The ERA for Impoundments 13, 17 and 24 related to their presence in areas identified as “having a flood potential”, as defined below.  

Within the 100 year floodplain, areas with high flood flow velocities are labeled as “floodways”.  None of the impoundments on the Am Cyan property are within a floodway.

Within the 100 year floodplain, areas with low flood flow velocities are labeled as “flood fringe”.  Impoundments 13, 17 and 24 are in the 100 year flood fringe.

All locations in the North Area of the site where soil and waste materials are stored are within the flood fringe.

Large precipitation and site flooding events in recent years (e.g. Hurricane Irene and Hurricane Sandy) have not caused loss of waste contents from any of the site impoundments, including impoundments 13, 17 and 24.

Post-flooding analyses confirmed there were no impacts from flood (events).

Pfizer has previously indicated that any wastes not removed from high velocity floodway areas will be capped and sealed in concrete.

Field Work

The following field tasks were completed for the Ecological Risk Assessment for Impoundments 13, 17 and 24.:

Soil samples were collected only in the top 2’ of soil adjacent to each impoundment (the zone of terrestrial ecological exposure).

Terrestrial habitat on site has been characterized.  Specific “receptors” of potential ecological concern were selected (3 mammals and 2 birds).

Chemicals of Potential Ecological Concern were selected for each impoundment, with over 20 organic and inorganic chemicals common to all 3 impoundments and the adjacent soil.

Potential Risk Estimates were calculated for many combinations of exposure and ecological effects.

Some of the estimated ecological hazard quotients found from this investigation indicate the need for further risk assessment or risk management, with the robin being the primary species candidate for further assessment.

Steps Going Forward

Pfizer’s consultants have made the following recommendations regarding the Ecological Risk Assessment for Impoundments 13, 17 and 24:

Additional Exposure and Toxicity Assessments are needed for hazardous chemicals within the impoundments that are not normally evaluated for ecological risk – including additional field work. (A Workplan Addendum needs to be submitted to EPA before new field work can be conducted).

When work is completed, submit the ERA report to EPA as part of a Pre-Design Summary Report on the impoundments.  (Targeted for late 2015).

How risk assessments affect EPA remediation decisions

We have seen that the remediation of a complex Superfund site can be long drawn out process.  The American Cyanamid site was placed on the National Priorities List under CERCLA (The Superfund legislation of 1980) on September 8, 1983.  That’s almost 32 years ago!

There are a series of investigative, design and decision making steps that determine how a Superfund site is cleaned up and the public protected.  The Record of Decision of September 27, 2012 was one of those key milestones in the decision making process.  EPA makes the decision on how to remediate, based on technical work conducted and funded by the “responsible party”, in this case Pfizer, as corporate successor to American Cyanamid, and Wyeth Holdings Corporation, which owns title to the Am Cyan property.

Risk assessments can be key elements of the investigation of a contaminated site.  Risk assessments are normally conducted to assess:

Human health impacts

Ecological impacts

of a contaminated site.  These in turn become the basis for determining the answers to the question that has dominated thinking in the decades following the enactment of CERCLA in 1980:  How clean is clean?

Human Health

Each chemical found at a complex chemical manufacturing facility like American Cyanamid has a myriad of potential health impacts on the human population potentially exposed to those chemicals, by such means as:

Ingestion of food and water

Inhalation of airborne contaminants

Direct contact

Remediation is about protecting persons from these hazards.  In most cases, air quality, water quality and soil standards for chemicals are based on toxicological scientific studies of the impacts of each chemical.  EPA and state environmental agencies (NJDEP) use these studies to develop appropriate standards consistent with the level of risk determined to be acceptable.

For American Cyanamid, the cleanup standards applied to soil, ground water, surface water and sediment, at a minimum, meet health based standards promulgated by NJDEP.


In the Declaration Statement to the 2012 Record of Decision, EPA asserts

Statutory Requirements

The selected remedy is protective of human health and the environment, complies with federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective.  This remedy utilizes permanent solutions and alternative treatment or resource recovery technologies to the maximum extent practicable.

“Protection of the environment” considers the specific ecological resources impacted by a site, including flora, fauna, surface water bodies, wetlands, and other sensitive ecological receptors.  Hence, where appropriate, Ecological Risk Assessments are conducted to calculate the potential risks to the sensitive species at risk.

For the Am Cyan site, it has been determined that the NJDEP surface water quality standards normally applicable to drinking water sources would not be protective of aquatic life and ecological resources in the Raritan River.  Hence EPA has established a more stringent surface water quality standard for this site.

The Ecological Risk Assessment conducted for Impoundments 13, 17 and 24 has not been concluded.  Based on the presentation to CRISIS on March 25, 2015, it is possible that Pfizer will recommend some soil removal, as expressed in the March 26 presentation as follows:

“Top 2 feet of soil (exposure zone) in the vicinity of three sample points with highest concentrations could be removed to address ecological risk.”

Mitigating Flood Risk

The Ecological Risk Assessment reported in this Technical Report is related to the presence of Impoundments 13, 17 and 24 within the 100-year flood zone.  EPA’s Record of Decision describes these impoundments having been used for the storage of on-site waste water sludge containing volatile compounds including benzene and chlorobenzene, semi-volatiles such as naphthalene and nitrobenzene, and metals including chromium, lead and mercury.  The ROD also states that the physical characteristics of these impoundments “do not allow for the contents to be transported by surface water runoff.”

EPA designated the site into 5 areas:

North Area

South Area

West Area

East Area

Impoundment 8 Facility

EPA notes that “the entire site lies within the flood hazard area of the Raritan River, with the exception of the Impoundment 8 Facility (which is designated as the corrective action management unit).  The Impoundment 8 Facility is that portion of the site situated within the flood control berm in place on the site.

It appears that the flood hazard issue at the Am Cyan site is still an open question, but is not subject to any flood specific Risk Assessment investigations and analyses such as those that have been carried out for issues of human health impacts and ecological impacts.

Communities on the Raritan River that are subject to frequent flooding, including Bound Brook and Manville, are located downstream of the American Cyanamid site.  Wastes and contaminated soil dislodged from the site by a severe flood could potentially create a health risk to the residents of these communities.

My May-June Technical Report will address the flood hazard issue, and its potential significance to the eventual remediation of the American Cyanamid site.

CRISIS will continue to follow progress and issues associated with the Ecological Risk Assessment at the American Cyanamid site, simultaneously with keeping our attention on site-wide soil and ground water (OU 4) and the Focused Feasibility Study for Impoundments 1 & 2 (OU 8).

If you have any questions or comments, please contact CRISIS’ Technical Advisor by email at iwhitman@whitmanco.com.

Ira L. Whitman, P.E., Ph.D

Technical Advisor to CRISIS, Inc.

May 13, 2015

==============================end of article==============================





Ira L. Whitman, P.E., PhD Technical Advisor 

October-November 2014

Issued December 22, 2014



          Much of the work being conducted by Pfizer during the past couple of months revolves around the ground water issues associated with   OU4, Site Wide Remedy, at the American Cyanamid Superfund Site.


          The reasons for the current focus on ground water, and hence the emphasis on ground water in the current Technical Report is two-fold.


  1. The field pilot study for OU8, Focused Feasibility Study for Impoundments 1 & 2, was completed in June 2014.  The results of the pilot study are now being assessed and discussed between Pfizer and USEPA.  CRISIS should be able to report on the study results during the first or second quarter of 2015.
  2. Many of the activity modules being conducted for the Soils/Impoundment components of the Site Wide Remedy are in stages of review and reporting, and are presently less active at the site.  These will be systematically reported by me in the future.


          I addressed Site Wide Ground Water issues in my May 2014 Technical Report where I indicated that Pfizer and EPA had structured the   ground water design activity into three components:


  • Extraction
  • Treatment
  • Discharge
    • Shallow stratum – the shallow unconsolidated soil layer known as overburden, generally varying from 9 feet to 15 feet deep.  Occupying the pores or voids between soil particles, the overburden (shallow) ground water is heavily contaminated.
    • Deep stratum – the thick base of fractured bedrock beneath the American Cyanamid site.  In the bedrock, ground water occupies fractures and fissures, and flows in a complex three dimensional pattern based upon the structure of the rock formation.



1.0       ground water extraction


The American Cyanamid site has two (2) significant strata from which a substantial volume of ground water must be extracted and treated.



         Pfizer’s ground water consultants have conducted numerous geophysical and hydraulic tests of the overburden and bedrock strata as a prerequisite to designing a ground water extraction system for the site.


         To add to the present capacity for extracting ground water, one additional bedrock extraction well is presently being installed at the site.  To design its ground water treatment and discharge systems, Pfizer needs to develop an accurate accounting of the volume of ground water capable of being drawn out of the two strata, and a reasonable determination of where the water is being drawn from so that the design for ground water remediation confirms that the entire mass of contaminated water may be removed and remediated.


         In the bedrock, extraction wells must be located based on detailed studies of the rock formation that inform the designing geologists as to how water bearing fractures and channels are connected horizontally and vertically.  Without fundamental knowledge of the geology, wells are likely to fail to intercept and withdraw much of the ground water within the bedrock beneath the site.


         In the overburden, the soil beneath the ground water table (the horizontal elevation of the ground water) is saturated with water as if the overburden material operates as a sponge.  In this stratum, cutoff walls and trenches will be used to channel the ground water into the shallow extraction wells that are installed at key water removal points.


         Bottom line:  The objective of the ground water extraction system is to remove all contaminated ground water, in time, so that it may be treated in accordance with the ground water treatment design.



2.0       ground water treatment


Pfizer’s Field Sampling and Analysis Report (FSAR) for ground water treatment for OU4, Site Wide Remedy, has been approved by EPA.  This puts the ground water treatment activity into the design phase where a Remedial Design Work Plan has been prepared and reviewed by EPA.


Because Pfizer plans to discharge treated ground water back into the ground, two separate sets of treatment criteria and objectives have been established; one for ground water extracted from and discharged back into the overburden, the other for ground water extracted from and discharged back into the bedrock.


Both the overburden and bedrock water contain organic chemicals and metals generated by American Cyanamid over the many years it operated at the Bridgewater-Bound Brook plant.  In general, the overburden ground water has higher concentrations of the chemical pollutants from American Cyanamid’s diverse chemical operations.  Conversely, the bedrock ground water has higher concentrations of metallic salts that occur naturally in the bedrock formation, or that have migrated on to the site from offsite sources.  As a result, different treatment approaches are needed for each ground water source, and different NJDEP Discharge Permit Equivalent Criteria will apply. 


          Pfizer has already received permit equivalent approvals from NJDEP for water to be injected back into the ground water formations.  The discharge quality requirements specified by NJDEP through its permits (or in this case “permit equivalents”) for water discharged to bedrock are more stringent than for the overburden, because the overburden water will continue to be recycled, and withdrawn and re-treated over a long period of time.


*Note:  In this case NJDEP issues “permit equivalents” and not “permits” because American Cyanamid is a Superfund case and as such the federal EPA has primacy over the New Jersey Department of Environmental Protection.



3.0       treated ground water discharges


Being situated on the north bank of the Raritan River, it is natural to assume that all treated waste water from the American Cyanamid Superfund site remediation would be discharged directly into the river.  As it turns out, current plans are that none of the treated ground water will be discharged directly into the Raritan.


          In EPA’s Record of Decision (ROD) in 2012, bedrock injection was identified as a suitable ground water discharge option.  Going further, NJDEP prefers reinjection of treated ground water effluent as a means of sustaining the ground water resource.  In many locations in the arid western states of the U.S., sewage effluent is discharged and recycled in ground water as a means of conserving and optimizing the use of a scarce water resource.  Southern California is increasingly dependent upon recycled sewage effluent as a primary source of drinking water.


          *Note:  As a result of the far reaching and complex network of drinking water sources and delivery systems in Central New Jersey, treated effluent from an American Cyanamid waste water treatment plant(s) would not be re-used for potable water supplies, regardless of whether that effluent was discharged into the Raritan River or injected into the ground at the site.


          Pfizer’s consultants have been conducting pilot injection tests in overburden wells at the American Cyanamid site, as part of its design activity for treated water discharges.  The goal is to assure that the volume of water withdrawn from the overburden can be treated and effectively replaced.  For the recycling plan for ground water to work in the overburden, a flow and water pressure schematic for the water table has to be developed so that a pattern of effective recirculation can be created and sustained over a period of many years.


          With regard to discharges of bedrock, the physical act of injecting water back into the ground at depth is more difficult, and entails high energy costs.


          The most recent schedule available to CRISIS shows that the OU4 ground water activity should result in the completion of the design phase in 2015, and the initiation of construction of the extraction, treatment and discharge facilities in 2016.


          CRISIS will continue to follow progress and issues associated with ground water remediation at the American Cyanamid site, simultaneously with keeping our attention on soil and impoundment issues under OU4, and the Focused Feasibility Study under OU8.


          If you have any questions or comments, please contact CRISIS’ Technical Advisor by email at iwhitman@whitmanco.com.



                                                                                       Ira L. Whitman, P.E., Ph.D

                                                                                           Technical Advisor to CRISIS, Inc.

                                                                                           December 15, 2014


==============================end of article==============================





Ira L. Whitman, P.E., PhD Technical Advisor

June- July 2014

Issued September 15, 2014


           While June and July were busy months for Pfizer on the investigation and remediation of the American Cyanamid Superfund Site, CRISIS, Inc.’s involvement consisted largely of the review of technical reports and data submitted to EPA, and our monthly status conference calls with Pfizer and EPA.  From those calls, I’ve elected to highlight some of the discussions of milestones and issues presented.



1.0       impoundment 2 field pilot study


The Impoundment 2 Field Pilot Study was completed as of early June.


         This is a significant milestone in the OU8 Focused Feasibility Study (FFS) that I have been reporting on for well over a year – primarily in the future tense.  The planning phase for the study occurred largely from Mid-2012 through the summer of 2013.  Construction took place from mid-summer 2013 through the end of the year, with follow up modifications and weather related delays into February 2014.  Thermal treatment at Impoundment 2 was initiated on February 28, 2014, and concluded around May 10.  The second phase, stabilization and solidification required much less time, and started in mid-May.  By early June, it was completed with the curing of stabilized waste material in Caissons 1 & 3 within the Impoundment 2 floating treatment platform.


         As of the end of July, the test site had been decontaminated and decommissioned, with waste material generated being containerized and awaiting approval for shipping and disposal at permitted out of state disposal facilities.  Two of the three roll-off containers with the pilot study waste residue are slated to go to Missouri where the material will be thermally destructed in a high temperature cement kiln.


         The takeaway on the Pilot Study schedule which has been completed (but behind schedule):


  • Planning and design stages:  (starting Mid-2012), 9-12 months
  • Construction:  (Mid-2013), 6 months
  • Time out for bad weather:  1-2 months
  • Actual Pilot Test:  3+ months
  • Decommissioning:  2 months


                           Total time elapsed – approximately 2 years.


          Pfizer and its consultants are now assembling data for the post-study analysis and integration into a remediation plan and report for Impoundments 1 & 2.


          Note:  Remediation of Impoundments 1 & 2 was originally addressed in 1998 in EPA’s Record of Decision, as supported at that time by CRISIS.  However, in 2004, further action on Impoundments 1 & 2 was suspended as the remedy originally selected by EPA was found to be technically infeasible following bench scale testing.  In the Record of Decision of September 2012, EPA noted that remedial activities for these impoundments were never initiated, and are being reevaluated as part of a separate study due to the nature of their content, their non-homogeneity and their complexity.  Particularly problematic were the physical properties (the:”goo” factor”) of the contents of Impoundments 1 & 2, whereas the chemical properties are by no means unique or untreatable.  The ROD noted that in 2009, EPA and NJDEP agreed to separate Impoundments 1 & 2 from the Site-Wide Feasibility Study and the site-wide remedy decision.  EPA noted the “highly complex” nature of the contaminants within Impoundments 1 & 2 and their close proximity to the Raritan River.  Pfizer then embarked on its Focused Feasibility Study for Impoundments 1 & 2, which included as a critical component the recently completed Impoundment 2 Field Pilot Study.


          With the completion of the Field Pilot Study, the schedule to reach a final decision on how to remediate these impoundments is likely to be longer than originally anticipated by CRISIS.  Based on discussion at our July 28 conference call with EPA and Pfizer, I am expecting the following milestones to apply to OU-8.


  • Assembling data from Field Pilot Study, prepare validated data and field pilot study scale results report (2nd Quarter, 2015)
  • Feasibility Study – reporting on full set of remediation alternatives including those tested in recent Field Pilot Study
  • Proposal of remediation plan for public review
    • 30 day public comment period, which can be extended 15 to 30 days.  CRISIS intends to comment when the opportunity exists.


          From my experience, these milestones are likely to be reached within 15-18 months, with a Record of Decision by EPA possibly occurring sometime in Mid-2016.  I will continue to report on the OU8 Focused Feasibility Study.  Each month, as my Technical Report is drafted, I discuss the current issues with Ross Stander, Executive Chairman of CRISIS, who reviews each draft report.



2.0       site-wide remedy (0u4)


         In my May 2014 Technical Report, I reported extensively on progress by Pfizer in investigating ground water contamination and the geologic conditions at the site that determine the ultimate fate and transport of these contaminants in the environment.  For readers interested in understanding the issue, I recommend going back and reviewing the May report which is on the CRISIS website, www.crisistoxicwatch.org.  The ground water remediation effort has been structured by Pfizer into these three components:


  • Ground water extraction
  • Ground water treatment
  • Ground water discharges


         If any of you have technical or regulatory questions regarding ground water at the American Cyanamid site, email the question to me at iwhitman@whitmanco.com and I will do my best to provide a non-technical answer to your question.  If you wish, include your telephone number, because in some cases it is easier to explain a technical concept verbally than it is to provide a concise written answer.


         Ground water is but one element addressed by EPA in its 2012 Record of Decision.  A myriad of other environmental and remediation issues are being addressed simultaneously by Pfizer as they proceed with the Site-Wide Remedy, known as Operating Unit (OU4).


         Each month, during our monthly conference calls with Pfizer, USEPA and NJDEP, Pfizer reports on the status and progress of each unit or “module” into which the site-wide remedy activity is divided.  Sometimes there is “real” progress such as the completion of a pilot study or the generation of meaningful environmental monitoring data.  Sometimes Pfizer reports on regulatory or bureaucratic progress, such as EPA returning comments on a report submitted, or a meeting with EPA and NJDEP on a pre-permit application, and sometimes there is no progress on a particular module from one month to the next.


         EPA and Pfizer’s current activities on the Site-Wide Remedy, OU4, are derived from EPA’s Record of Decision (ROD) of 2012.  Leading up to the issuance of that ROD, CRISIS participated in public meetings (Spring 2012) and offered comments to EPA on the approaches selected by EPA for remediation under the ROD.  Among the concerns expressed by CRISIS at that time were:


  • Leaving waste materials in Impoundments 13, 17 and 24
  • Using ecological assessments of proposed remedial actions to determine the ultimate fate of the material in these impoundments
  • Impacts of flooding on the proposed remedial actions in the flood plain


         CRISIS’ support for the ROD was conditioned on having its concerns addressed during the build-up to the design of the remedial actions, characterized by EPA as the Pre-Design Investigations, or PDI.  It is this phase that is presently occurring, and CRISIS is working to see that Pfizer/EPA gives due consideration to our concerns.  We will continue to monitor not only the progress of this phase of the OU4 work, but also the substance so that we may be assured that the issues of concern to CRISIS are addressed in a way that protects the community and the environment.


         When it is summed up, remediation of a Superfund site is a slow process, even following the determination by EPA as to how the site will be remediated and the public protected against future environmental hazards.  The process of review-comment-revision-approval is inherent in the environmental regulatory world, and the regulatory steps often take as long or longer than the investigation, engineering and construction steps.*  Therefore, CRISIS, Inc. and its members are bound to be frustrated by the slow pace of progress, which frequently we are.  However, slow as it may seem, overall progress is being made with most of the OU4 components in the Pre-Design Phase (PDI).


         Some recent activity on OU4 Modules consist of the following:


2.1   Lagoon 7 Interim Water Treatment System


          Lagoon 7 is the largest of all of the lagoons on American Cyanamid site, covering an area of approximately 900’x900’ (19 acres).  It is located along the western boundary of the property, near where the Conrail line that bisects the property crosses the Raritan River.  Lagoon 7 is part

of the storm water management system for the property, and is used to store storm water runoff.



*      The slowness of environmental regulatory progress was one factor in New Jersey that motivated the State Legislature in 2009 to draft and adopt SRRA, the Site Remediation Reform Act.  SRRA licenses senior professionals in the state and gives them the authority to issue decisions and determinations of No Further Action previously reserved for NJDEP.  There are presently 579 licensed LSRPs in New Jersey, each of whom has passed a lengthy and difficult exam (including myself).  As a result, progress on state supervised cleanups has accelerated, and remediations are being completed more expeditiously.  The American Cyanamid site, however, is not subject to SRRA inasmuch as Superfund is a federal program under EPA’s jurisdiction.


New Jersey’s LSRPs are subject to rules and a Code of Conduct administered by the site Remediation Professional Licensing board created by the legislation.  I am pleased to be a member of this very active licensing board.


Pfizer designed an interim treatment system for the water contained in Lagoon 7, and construction of this system was initiated on July 28.  Start-up for this system was scheduled for August, and it will be operating half time for several years.  The treated effluent from this system will become the primary volume of water flowing in Cuckel’s Brook.  Ultimately, as other areas of the site are remediated, it is anticipated that future storm water will not require treatment prior to being discharged to an adjacent surface water.


2.2   Module 1 - Discharge to Ground Water


          Two bedrock injection wells were installed in July.  Pfizer’s consultants conducted pump tests in August to determine parameters for reinjecting treated ground water back into the bedrock formation following treatment, an approach which, among other things, helps to protect the quality of water in the Raritan River.


          A meeting on this component of the Site Wide Remedy was held by Pfizer with NJDEP on August 7 to deal with site hydrogeology and Clean Water Act permit issues.  NJDEP water quality standards must be met by all effluents discharged to ground water or surface water at the site.  Of particular concern is the background ground water quality, particularly the concentrations of naturally occurring metals in the water. 


2.3   Module 11 – Soil Vapor Extraction


          Pfizer is exploring the use of remediation by Soil Vapor Extraction (SVA) in portions of the northeast area of the property.  SVE is a common soil remediation procedure for certain volatile organic contaminants.  Meetings on this component of the remediation were held by Pfizer with EPA on May 8th and July 15th.  Reponses to EPA’s questions and comments were included in a work plan for Module 11 submitted to EPA at the end of July.


          Field testing of the SVE process was scheduled for mid-late August, and it is desirable to conduct the field sampling during the dry, hot summer conditions.  Heavy rains on August 21 (1-2 inches) impacted the testing which was then postponed for at least one week.


2.4   Summary


          The takeaway from the examples of Site Wide Remedy activities is that the process moves forward, sometimes with definitive results, sometimes with delays, and sometimes with what seems like an overload of regulatory steps.


          CRISIS will continue to report on progress, on results and delays as the OU4 Site Wide Remedy activities move forward, and we will continue to push for Pfizer to meet the conditions on which our support for this program was based.


          Your comments and questions are welcome.


                                                                                    Ira L. Whitman, P.E., PhD

                                                                                    Technical Advisor to CRISIS, Inc.

                                                                                    September 15, 2014


==============================end of article==============================





Ira L. Whitman, P.E., PhD Technical Advisor

May 2014

Issued June 17, 2014



May was a busy month for CRISIS, Inc. that included three significant events in the course of one week.


May 3 – Bridgewater Township Eco-Fair

May 7 – Tour of Impoundment 2 Field Pilot Study Area and Update of Status of the Pilot Study

May 9 – Status Update meeting by Pfizer for CRISIS, Inc., on Ground Water Extraction, 

Treatment and Discharge.



1.0       impoundment 2 field pilot study


         In November 2013, Ross Stander, Executive Chairman of CRISIS, Inc., and Ira Whitman, Technical Advisor, had the opportunity to observe the Impoundment 2 Field Pilot Study Area when it was under construction.  Photos from that day were shown as part of CRISIS’ exhibit on May 3 at the Bridgewater Township Eco-Fair.  We hope that you had the opportunity to stop by our table.


         On May 7, Ross Stander, John Tucciarone and Ira Whitman were given the opportunity to observe the Pilot Study Area in operation.  Joining us was Dan Hayes, Mayor of Bridgewater Township.  Conducting the tour were Pfizer’s American Cyanamid Project Manager, Russell Downey, and a number of their sub-contractors involved with this ongoing Pilot Study.


         A description of the pilot Study was presented in my March – April 2014 Technical Report.  When we were on site on May 7, it was indicated that the first phase of the treatment program, thermal treatment, would be completed within a couple of days, and that Pfizer will then embark upon a 10 day transition period into the second phase of treatment, stabilization and solidification.  This phase is currently in full operation, and is expected to carry over through the early part of June.


         A notable element of being escorted around the Superfund site is the health and safety measures imposed on each visitor, who are provided, and must wear steel toed boots, a hard hat, safety goggles and safety vest.  Persons who ventured out on to the platform floating on the surface of Impoundment 2 to get a closer look at the treatment caissons and vapor collection system were required to wear a life vest as well.


         On our path across the site leading to and from Impoundment 2 (which is on the south side of the property in the flood plain near the Raritan River) we were able to see several of the air quality monitoring stations installed for the Pilot Test.  Fortunately, to date, there were no exceedances of the applicable air quality standard which led to a shutdown of the vapor collection or treatment system.


         Also on the roads in and out of the Impoundment 1 and 2 area we were able to see the flood levels that were reached only 5 days earlier on May 1, when very heavy rains caused the Raritan to top its banks.  Operation of the Impoundment 2 Pilot Study was not seriously disrupted by the flood, as all of the essential components of the test have been situated on higher ground.  However, Pfizer and subcontractor personnel had no access to Impoundment 2 for a period exceeding 24 hours.


         In his May 19, 2014 Semi-Annual Progress Report to NJDEP under Pfizer’s 1988 Administrative Consent Order, Russell Downey reported that the May 1, 2014 flood caused the Raritan River to crest at elevation 36.65 feet in Bound Brook.  This was estimated to be the 7th highest crest at Bound Brook since 1970.  The highest during the past 44 years was Hurricane Floyd at 42.13 feet and Hurricane Irene at 41.90 feet.  Pfizer reports that minor damage to the bank stabilization system in Cuckel’s Brook may need repairs as a result of the May 1, 2014 flooding.



2.0       Site-wide Ground Water


         On May 9, Pfizer gave a presentation to 5 persons from CRISIS, Inc., including myself, updating the status of the Pre-Design Investigation for highly contaminated ground water under the Site Wide Remedy (OU 4) of the Superfund remediation.  The basis of this work is derived from EPA’s Record of Decision (ROD) for the site of September 2012.


         It should be noted that while the site-wide ground water remediation system is in the pre-design stage, the temporary modular ground water system installed to deal with benzene seeps into the Raritan River continues to operate.  This system, which collects ground water from the overburden near Impoundments 1 & 2 will be phased out of use when the site-wide system is finally installed and in operation.


         In my March – April 2014 Technical Report now posted on the CRISIS, Inc., website (www.crisistoxicwatch.org), I indicated that Pfizer has structured the ground water design issue into these three components:


  • Extraction
  • Treatment
  • Discharge
    • Relocate the primary extraction well to a central location
    • Add new extraction wells, as necessary
      • Control/collect overburden ground water using trenches, wells and/or containment walls.
        • Advanced Oxidation Processes (AOP)
        • Metals Precipitation
        • Biological Oxidation
        • Filtration
        • Adsorption
        • Membrane Separation


2.1   Ground Water Extraction


          The design investigation for ground water extraction is being conducted by Pfizer’s consultant for this purpose, Golder Associates.  Golder’s mission is to provide information on, and design the appropriate system for extracting ground water for treatment.


1.Ground Water Strata


         Ground water is often present in layers or strata.  In the geologic zone where the American Cyanamid facility is situated, there are two (2) such strata:


a)     Overburden - ground water existing in the shallow soil layer that caps the site.  The overburden soil is heavily contaminated, as is the ground water that occupies the pores or voids between soil particles in this layer.  In this region, the overburden thickness generally varies between 9 feet and 15 feet.

b)    Bedrock – this area of the Raritan River basin is underlain by a thick base of fractured Triassic bedrock known as the Passaic formation.  The bedrock itself is impervious to water, however the many fractures in the bedrock are filled with water which may contain dissolved contaminants.  In this rock formation, water and contaminants move in a complex vertical and horizontal grid which is the pattern of 3 dimensional diagonal layers and fractures.  In order to determine this pattern, Golder conducted many geophysical and hydraulic tests by installing a series of test wells to evaluate flow parameters in several bedrock layers (hydrostratigraphic units).


2.Hydraulic Control


         A key design objective of a ground water extraction system is to attain “hydraulic control” over the entire superfund site.  Hydraulic control of a site assures that a) all contaminated ground water can eventually be drawn into the system by installing wells at the correct locations and depths, and b) no contaminated ground water can leave the site because a positive flow gradient toward the extraction wells is created.  In some areas, cutoff walls and collection trenches are needed in addition to shallow wells to collect the overburden ground water.


3.Flow Rates


         The ground water extraction study must, among other things, provide the system designers with potential rates of flow (gallons per minute) from both the overburden and bedrock wells in order to design the flow capacity of all three system components; extraction, treatment and discharge.  Once designed and built, it is anticipated that the site-wide ground water treatment system will operate for many years, at a relatively set rate of X gallons per minute; Y gallons per day.


4.Extraction Well Locations


         The EPA Record of Decision anticipated an expansion and optimization of the ground water extraction system at American Cyanamid that had been in place going back a couple of decades.  EPA stated the following in 2012 regarding ground water extraction:



         In order to meet this requirement spelled out by EPA, it was necessary for Pfizer and Golder to create detailed maps and charts that identify the locations of the water-bearing strata.  Pump tests and geophysical data were used to determine potential extraction well locations, and a central well location was selected.  To design the overburden extraction system, Golder drilled 39 geotechnical borings to assess soil characteristics along a potential collection trench and barrier wall alignment.  14 shallow monitoring wells were drilled and installed to assess the overburden hydrogeology and chemistry.


         From these studies, now concluded, a conceptual overburden and bedrock ground water extraction system has been developed, with some wells already in place and others to be installed.  The overburden collection wall will extend from the collection trench already in place along the Raritan River through the southern portion of the property and then along Cuckel’s Brook.


         Pfizer and Golder believe that approximately 40% of ground water collected will be from the overburden, and 60% from bedrock.  However, water found in the overburden is more heavily contaminated.


2.2   Ground Water Treatment


          Pfizer and its predecessor companies have been collecting ground water quality data at the Bridgewater site for many years, so the general nature of the ground water treatment challenge has been well documented.  The target “Compounds of Concern” fall largely within two separate and distinct families of chemicals; Organics (primarily Volatile Organic Compounds) and heavy metals that include such commonly used substances as lead, arsenic, cadmium and mercury.  However, the naturally occurring bedrock ground water contains minerals that impact and/or impede how the contaminants can be successfully treated or removed.  These include sulfates, sodium, calcium, manganese, elevated hardness and total dissolved solids.


          Pfizer’s ground water treatment consultant, Brown and Caldwell, set out to design a ground water treatment system focused on the Contaminants of Concern-Target COC’s (organics and heavy metals) and considered the following categories of treatment processes:



          In designing the ground water treatment system, Pfizer’s consultants had to take into account where the treated waste effluent would be discharged as different ground water quality standards apply to discharges to surface water (Raritan River) than to ground water (overburden or bedrock).  Although the treatment system design process is overseen by the federal EPA, the applicable standards are set by the state agency, NJDEP which are enforced by a mechanism developed for federally supervised sites known as Permit Equivalents issued through a Permit-By-Rule.


          Pfizer plans to separate the water extracted from the overburden and the bedrock for purposes of both treatment and discharge (see Section 2.3).


          The primary treatment processes selected for the overburden ground water are Fenton’s Oxidation for organics and precipitation for metals.  Fenton’s Oxidation involves the use of iron and a catalyst to oxidize the organic components and pH adjustment with a polymer to remove the contaminants, first through settling and then with the use of a multi-media filtration system.


          The same treatment system will be utilized to treat bedrock ground water, with a significant additional step involving the use of biological processes with added nutrients to further treat organic chemicals.  Following the removal of organics with multi-media filters, further removal will be done by employing granular activated carbon.


          Brown and Caldwell’s rationale for employing additional treatment processes for the bedrock ground water relates to the discharge requirements imposed by NJDEP, where treated water discharged back into the bedrock is subject to more stringent water quality standards than water discharged back into the overburden.


2.3   Ground Water Discharges


          Although the American Cyanamid site is located directly along the Raritan River, and is bifurcated by Cuckel’s Brook, Pfizer is not planning to discharge its treated ground water into the river, but rather will discharge the effluent back into the ground.  Specifically, water extracted from the overburden and treated will be discharged back into the overburden.  Likewise, treated ground water from the bedrock will be discharged back into the bedrock.  Bedrock reinjection was contemplated in the EPA ROD as a suitable ground water discharge option.  NJDEP prefers reinjection as a means of sustaining the ground water resource.  The downside to discharging ground water back into the ground is that is requires more maintenance and energy and hence is more costly than discharging into the Raritan River.


          Treated water returned into the overburden will be discharged at locations that enable hydraulic control of the overburden ground water to be maintained.  The design investigations currently under way are developing the appropriate locations for overburden recirculation of flow.  Recirculating water into the overburden will lead to a flushing of contaminants from the soil, as the ground water in the overburden gradually carries reduced concentrations of metals and organic chemicals.


          Discharging treated ground water into the bedrock is trickier and brings with it higher energy costs.  For the naturally occurring minerals present in the bedrock water, including sodium, calcium and sulfates, Pfizer is not required by the regulatory agencies to remove those minerals to below their natural levels.


2.4   Ground Water Strategy Moving Forward


          Pfizer believes that it has solved most of the challenging technological problems associated with ground water extraction, treatment and discharge at the American Cyanamid site.  It will be seeking EPA approval for the Conceptual Site Model it presented to CRISIS, Inc., on May 9.  Following EPA’s review and subsequent discussion, Pfizer will move into the detailed design phase for this proposed site-wide ground water remediation concept.


          While Pfizer originally believed that the site-wide ground water remedy would be operational by 2015, the extensive pre-design investigations have caused that targeted date to slip by two years, and the following schedule is now envisioned.


          Likely schedule for Site Wide Ground Water Remediation





Complete Pre-Design, submit to EPA for review




Initiate Construction


Complete Construction, begin operation


          CRISIS welcomed the opportunity to see Pfizer’s progress on this phase of its site-wide remedy firsthand, and appreciated the presentation by Pfizer, Golder and Brown and Caldwell.  We will continue to follow the developments with the site-wide remedy, and will continue to report back to CRISIS’ members and the public as more elements of the site-wide remedy are conceptualized, designed and constructed.



                                                                                       Ira L. Whitman, P.E., Ph.D

                                                                                           Technical Advisor to CRISIS, Inc.

                                                                                           June 17, 2014


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Ira L. Whitman, P.E., PhD Technical Advisor

March - April 2014

Issued May 7, 2014



CRISIS, Inc. has been following recent activity and progress at the American Cyanamid Superfund Site both at the Impoundment 1 & 2 area (OU8 Focused Feasibility Study) and for the site-wide Remedy (OU4 Remedial Design).

We received recent updates on a conference call with Pfizer, EPA and NJDEP on April 28.





The Pilot Study area within Impoundment 2 consists of three steel caissons, each 7’ in diameter, driven through the waste in the impoundment to the clay layer beneath the waste.

The treatment program for the 3 caissons include:


Caisson #1      Combination of two processes tested individually in the other caissons


Caisson #2      Thermal treatment only


Caisson #3      Stabilization and solidification only


A cover over the three caissons evacuates vapors thrown off by the treatment, and then the vapors are treated and stripped of their hazardous chemicals.


Full thermal treatment was initiated on February 28, and has been operating continuously for approximately 9 weeks.  The temperature in one caisson has averaged 85° C, and in the other 95°C (converting to Fahrenheit, 185°F, 203°F respectively).  Pfizer reports that the majority of anticipated removal of hazardous substances has taken place, and they expect to shut down the thermal treatment in these two caissons on or about May 10.


Following a 10 day transition period, stabilization and solidification will proceed in caissons 1 and 3.


The primary chemicals removed by the thermal treatment process are Benzene, Toluene (Volatile Organic Compounds) and Hydrogen Sulfide.

Because the Field Pilot Study is designed to determine the feasibility of scaling up the remediation at Impoundments 1 & 2 for the entire impoundments, it is important to note the difficulties with the test as well as the benefits.  To date, some of the difficulties with the thermal treatment have included:


·       Uneven temperature distribution in the test cells.

·         Corrosion – One heater has been lost in caisson #2 due to the highly acidic character of the waste being treated.

EPA and Pfizer have been monitoring air quality in the test area during the thermal treatment tests.  No exceedances of air quality criteria have occurred that would lead to a test shutdown.  Their biggest problem with the air quality monitoring has been false positive alarms set off by rain and high humidity.

The air quality monitoring is of particular interest to CRISIS, Inc. as a means of protecting the community from excessive fugitive vapors.  Should Pfizer and EPA select the thermal treatment process for the full-scale treatment of Impoundments 1 & 2, CRISIS, Inc. will be very watchful over their plans to continuously monitor air quality.


On May 7, John Tucciarone, CRISIS Board Member, and Ira Whitman, Technical Advisor will be given a tour and inspection of the Impoundment 2 treatment area by Pfizer.  We will share our experience with you in future reports, and will do our best to photograph the elements of the testing/removal facility and make those photos available to the public.


2.0        SITE-WIDE REMEDY (OU4)


Pfizer is in the Remedial Design Phase of developing the “Site-Wide Remedy” for the American Cyanamid Superfund Site as put forth by EPA’s Record of Decision (ROD) of September 2012.  Most of the activity consists of developing plans for EPA review and approval, and several rounds of comments back and forth between Pfizer and EPA.


A very important component of the site-wide remedy Remedial Design pertains to the site-wide remediation of ground water, an issue I reported on in my Technical Report of January – February 2014.  On May 9 Pfizer has scheduled a meeting to brief CRISIS on ground water:


·       Extraction

·       Treatment

·       Discharge

As presently being formulated, I will report on these plans and on this meeting in my next Technical Report.

Other site-wide remedy issues reported on by Pfizer include updates for the following:


Ecologic Risk Assessment:  (Module 4) Pfizer’s Field Sampling and Analysis Plan for Impoundments 13, 17 and 24 was submitted to EPA in March  The plan, along with comments from EPA will determine the design of the final remediation of these impoundment areas.


Drying Bed Area:  (Module 10) New soil borings and test pit sampling are presently being conducted to characterize and delineate this area of soil contamination.


North Area Vapor Pathway:  (Module 11) Soil vapor investigations have been conducted and Pfizer is meeting with EPA on May 8 to review their results and to discuss the remediation of this area of the American Cyanamid site.

Russell Downey of Pfizer indicated that there will be a lot of Pre-Design Investigation work done in 2014 for the OU4 Soils and Impoundment Areas throughout the site.  He expects this to be followed in 2015 by treatability studies to deal with specific contaminant issues, and for 2015 to be largely devoted to remediation design for the areas of soil and impoundment contamination within OU4.


CRISIS is likely to be briefed later in 2014 on some of the specific plans for these areas, while they are in the pre-design stage.

While the field pilot tests continue at Impoundments 1 & 2, and pre-design work continues for many other areas of soil and impoundment contamination, more routine operations, monitoring and maintenance continue throughout the site.





Pfizer conducts regularly scheduled ground water, surface water, sediment and ambient air quality monitoring on and adjacent to the American Cyanamid site.


Results from the most recent ambient air monitoring event are not yet available.  Results from sediments taken from Cuckel’s Brook and the Raritan River early in March were satisfactory.  Sediment characteristics are an important criteria in evaluating the biological and ecological health of a stream or river.


Surface water samples also taken in early March showed a slippage in water quality from samples taken after the first quarter of 2013.  Concentrations of benzene in Cuckel’s Brook and the lower reaches of the Raritan River have exceeded the allowable surface water quality criteria for the first time during the most recent four rounds of surface water monitoring.  Pfizer will need to determine if this is a seasonal phenomenon or if there is an actual increase in the volume of benzene and related substances entering Cuckel’s Brook and the Raritan River.


Information on past surface water quality monitoring can be found in my May 2013 Technical Report, which is posted (along with much other information) on our website, www.crisistoxicwatch.org.  We will continue to update you as other monitoring results of significance are made available.


Ira L. Whitman, P.E., Ph.D

Technical Advisor to CRISIS, Inc.

May 7, 2014

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Ira L. Whitman, P.E., PhD Technical Advisor

January – February 2014

Issued April 2, 2014

In this report I will focus on several issues that were of interest and concern to CRISIS, Inc. in 2013.  EPA’s monthly status conference calls with CRISIS, Inc. were held on January 27, February 24 and March 24, 2014.  Monthly progress reports to EPA have been issued by Pfizer on January 15, February 15 and March 15.


Several times during 2013, I reported on the status of Cuckel’s Brook, the small stream bisecting the American Cyanamid site that generally flows to the southwest where it enters into the Raritan River.

Water samples taken by Pfizer in 2012 in Cuckel’s Brook exceeded allowable surface water quality standards for benzene at seven (7) locations.

In May 2013, Pfizer reported that a small ground water seep into Cuckel’s Brook was discovered.  Following a reconnaissance inspection, other seeps into Cuckel’s Brook were found, and Pfizer agreed to develop and submit to EPA a work plan for interim remedial measures for contaminants entering the Brook, many of which exceeded allowable standards by 1000 times or more.

Pfizer instituted interim measures to intercept and treat contaminants entering Cuckel’s Brook.  Pfizer’s consultants also performed an analysis of the mass of contaminants seeping into the Brook at CRISIS’ request.  While the concentrations of benzene and other organic chemicals seeping into the Brook were very high, such a small volume of ground water was entering the Brook that the total calculated mass was very small, approximately 0.17 grams per day, which is about 1/10 of 1% of the mass of benzene that had seeped previously into the Raritan River in the vicinity of Impoundments 1 & 2.

While the Cuckel’s Brook “problem” seems to have been abated, ground water in the vicinity of the Brook is very contaminated, and CRISIS, Inc. will keep it on the “front burner” and pay close attention to future surface water sampling results from the Brook.


Elements of the OU 8 Field Pilot Study in Impoundment 2 were to start in December, but it was mid-January before all of the components and equipment were in place due to construction delays and awful winter weather.  Crisis has previously expressed its concerns over delays in this important program.  The purpose of the Pilot Study is to provide Pfizer’s engineers with answers to open questions regarding the remediation of Impoundments 1 & 2.

The final pieces were inserted into this complex jigsaw puzzle; on February 26, the thermal oxidizer in the first two test units was hooked up, and on February 28, the heaters for thermal treatment became operational.  Much of the January – February timeframe was used to conduct operational and safety testing on the treatment system.  According to Pfizer (as of March 24), the system is operating as designed.  The temperature in the two caissons being heated averaged 60C (140F), with parts of the caissons reaching 80C (176), which is above the boiling point of benzene, one of the primary chemicals being treated.  A large increase in mass vaporization has been seen, and Pfizer’s engineers may slow down the rate of future heating – with potential safety being one concern.

Ambient air monitoring stations surround the Impoundment 2 test area.  Thus far, no levels of Hydrogen Sulfide (H2S) or Volatile Organics (VOCs) have been measured at these monitoring stations so as to trigger any response or to suspend the tests.

Pfizer believes that the total pilot test will exceed the 90 day test period permitted by NJDEP.  A 90 day permit extension will be applied for, but NJDEP has indicated that a third 90 day permit extension request would not be favored.  Based on the discussion during EPA’s conference call on March 24, 2014, I would expect the pilot tests to continue until the end of May.  It will then be several months before the test data can be interpreted and disseminated.  Thus it is not likely that a determination can be made as to whether these treatment processes can be scaled up so that all of Impoundments 1 & 2 can be remediated until late 2014, November or December, resulting in continued uncertainty regarding this element of the total site remediation.


EPA is conducting a mandatory “5-year review” of the American Cyanamid site.  An EPA meeting with Pfizer will be held soon to kick off this activity, which should be of interest to the members and friends of CRISIS, Inc.

The 5-year review will result in an up to date evaluation of all remedial actions previously completed at the American Cyanamid Superfund Site, to determine whether the remediation of each area has been effective, whether other actions should be taken, and to report back the findings to the public.  Under EPA’s Superfund program procedures, this effort is to be completed by September of this year.

EPA has indicated that while it is not common for a 5-year review to result in any remedial updates or changes, it has happened in instances where, for whatever reason, past actions have proven to not be fully protective of the environment.

CRISIS, Inc. will keep its members and the readers of this report updated on the findings by EPA of the 5-year review.


Pfizer and its consultants will shortly be meeting with EPA and NJDEP to present their overall concepts for ground water extraction, treatment and effluent discharge for the permanent site-wide ground water treatment system.  Ground water remediation, site-wide, in the long run is likely to prove to be a costly and time consuming component of the entire American Cyanamid site remediation program.  Since 2012, an interim modular treatment system has been operating and discharging its effluent to SRVSA.  The permanent side-wide system will discharge to the Raritan River.

Pfizer’s consultants have been evaluating ground water extraction options for months, conducting numerous pump tests and in-well geophysical tests.  In addition, they have been conducting laboratory tests to determine the best individual and combined treatment methods to use to achieve the level of contaminant removal prescribed under EPA and NJDEP discharge permits.  I believe that by mid-2014, the site-wide ground water program will become one of the more prominent elements of the American Cyanamid Superfund Site remediation, and will be given a lot of attention by Pfizer and it’s consultants, by the regulators and by us, the members of the public.  Pfizer has not given us a revised schedule for the installation and start-up of the site-wide ground water system.


Work being undertaken at present at the American Cyanamid site is likely to result in important findings and conclusions later in the year.  By the end of 2014, Pfizer and EPA  should have a clearer picture of the directions to be taken in undertaking several of the most important elements of the cleanup, namely

  • Impoundments 1 & 2 (OU 8)
  • Site wide ground water extraction and treatment
  • Impoundments and site-wide soils making up the remainder of the site-wide remedy    (OU 4)

CRISIS, Inc. expects to meet several times this year with Pfizer and EPA, and will participate in each monthly project conference call.  As we learn more from the findings and conclusions from the various field, laboratory and pilot tests now taking place, we will continue to post information on our web site www.crisistoxicwatch.org and we will continue to address what is happening in my monthly Technical Reports.

Ira L. Whitman, P.E., Ph.D

Technical Advisor to CRISIS, Inc.

April 2, 2014

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Ira L. Whitman, P.E., PhD Technical Advisor December 2013
Issued January 15, 2014

The theme of this final Technical Report for 2013 is to sum up the key activities at the American Cyanamid Superfund Site in 2013 in terms of progress made toward the final remediation of the site, and the concerns and issues moving forward as seen by CRISIS, Inc. More information on activities at the site may be found in my earlier reports posted on the CRISIS web site.

EPA’s monthly status conference call with CRISIS, Inc. was held on December 17, 2013. Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc. The primary topics for discussion on the agenda provided by Pfizer included:

Impoundments 1 and 2 Focused Feasibility Study (OU8) (Field testing of remediation methodologies)

Site Wide Remedy (OU4)

On going Routine Operations, Maintenance and Monitoring

Community Outreach



Several issues raised during the December conference call were of concern to CRISIS, Inc., and we will be following them closely during the next several months.

OU8 Schedule: Pfizer reported that they were refining the “recipe” of chemicals to be added to the waste material in caisons installed as test cells in Impoundment 2 for the stabilization phase of the OU8 Field Pilot Study. Stabilization is the addition of selected chemical substances to bring about changes to physical properties of the waste that render it to be more manageable. While the pilot study was originally to begin in November 2013, it was recently scheduled to begin on January 6, 2014.

Last minute tweaking of the processes, construction delays and difficult winter weather are likely to lead to additional slippage in the schedule in this key element of the Impoundments 1 and 2 Focused Feasibility Study, a development which we will be monitoring and reporting to CRISIS’ members.

CRISIS understands that field testing remediation methods is crucial in determining the feasibility of using those methods to conduct full scale remediation. However, we note that even if the pilot study is successful, there are no assurances that the methods tested will be successful at full scale in bringing about the level of cleanup specified under USEPA’s Record of Decision.

OU4 Schedule: Pfizer reported that it is working toward optimizing the various elements of treatment for its permanent site wide ground water treatment system, by performing bench scale treatability studies, with certain contaminants and effluent toxicity a particular concern. While necessary to maximize the effectiveness of this very important remediation component, this work is causing schedule slippages in obtaining permits and in the design of the system. Originally scheduled for installation in late 2015, Pfizer has not yet issued a revised schedule for the treatment system.

Air Monitoring: Because of our concerns for community health and well-being, we queried Pfizer and USEPA about preparations for air quality monitoring during the soon to be initiated Field Pilot Study at Impoundment 2.

Pfizer reported that they will monitor air quality continually during the pilot study, at points along an inner ring adjacent to the impoundment to reflect conditions for on-site workers; and along an outer ring to reflect concerns for the neighboring communities. EPA indicated that it will be independently monitoring air quality as a control.

A significant part of the pilot study will be to collect vapors emitted from the thermal and waste stabilization treatment cells and to treat/remediate those vapors.

If activities at the pilot study site lead to concentrations of contaminants in excess of allowable air quality standards, Pfizer will be required to shut down the pilot study at least until the cause of the air quality violation can be identified and corrected.

OU4 Pre-Design Investigations (PDI): In accordance with EPA’s Record of Decision (ROD) of September 2012, Pfizer and its consultants are conducting PDI on various issues of concern moving forward with the Site-Wide Remedy (OU4). These investigations are being carried out on work plan elements identified as WP Modules1.

“Module 4” of the OU4 PDI is Ecological Risk Assessment of three of the impoundments on the American Cyanamid property; Impoundments 13, 17 and 24. CRISIS has asserted to USEPA in the past that it wants to see these flood plain impoundments emptied and cleaned out, because of our concerns that on-site flooding is likely to cause the contents of the impoundments to be washed into the Raritan River; thus the need for the Ecological Risk Assessment. Should such a flood event occur, the introduction of the stored wastes into the river could result in an ecological disaster to the aquatic life in the Raritan River.

EPA has stated that the contaminants in these three impoundments provide “no human health risk”. EPA’s Record of Decision indicates that these impoundments were used for disposal of American Cyanamid’s waste water sludge, and contain “elevated levels” of benzene, chlorobenzene, toluene and xylene, and may also contain semi- volitile compounds including naphthalene and nitrobenzene, and metals including arsenic, chromium, lead and mercury.

CRISIS is concerned that based on the results of the Module 4 Ecological Risk Assessment, EPA may decide to allow the contents of Impoundments 13, 17 and 24 to remain in place on the property, a measure that CRISIS opposes. Needless to say, CRISIS will follow the outcome of the Ecological Risk Assessment carefully, and will reiterate its opposition to any final remediation decision that we believe to be not in the best interest of the neighboring communities and/or the ecological well being of the Raritan River.

Community Outreach: USEPA’s community liaison for the American Cyanamid Superfund Site, Melissa Dimas, stated that EPA has interviewed members of the public who attended the EPA Public Information meeting on October 24, 2013. She indicated that in general the attendees liked the presentations, and the community appears to be well informed. The results of EPA and its contractor’s inquiries are expected to be available sometime in January 2014.

CRISIS’ Mission is to be a community watchdog regarding American Cyanamid, and to inform, educate and represent the community at large in Bridgewater, Somerville, Bound Brook and adjacent towns; a mission we have had for over 20 years which we take very seriously. We will report on the results of EPA’s survey when they become available.

One of the joys of following Superfund remediation projects under USEPA is that an entire new language has been created by the bureaucracy for reasons I’ve never quite understood, despite being in this field for the 33years since the Superfund law (CERCLA) was passed. Section 5 of the December 2013 Pfizer Progress Report to EPA listed 59 abbreviations of technical and bureaucratic terms!

2.0 2013 IN SUMMARY

Regardless of the concerns expressed in Section 1.0 of this report (Current Issues of Concern), 2013 was a year of definite progress and accomplishment at the American Cyanamid Superfund Site, as demonstrated by some of the following issues reported on by me throughout the year.

Raritan River Water Quality. In 2012, surface water quality in the river, downstream of Cuckel’s Brook was found to be non-compliant with NJDEP surface water standards for benzene. Following the installation of a cutoff wall and collection trenches along the river, and interim treatment of ground water, benzene concentrations in the Raritan River were reduced in concentration and since May 2013 have met the applicable surface water standard of 0.15 parts per billion (μg/l).

Cuckel’s Brook. Very high concentrations of organic contaminants were found in Cuckel’s Brook (which trans-sects the American Cyanamid property) in early 2013. Upon inspection, a sheen (small oily slick) was found in the Brook, and seeps were discovered discharging small volumes of contaminated shallow ground water into the Brook. The seeps are now being intercepted and treated. Pfizer’s consultants have calculated the total mass flow of the water and contaminants seeping into Cuckel’s Brook, showing that the seeps represent a small fraction of the natural flow on the Brook. Therefore, a small (but significant) total mass of contamination is transported into the Raritan River itself.

The shutting down of this contaminant source into the river was a positive development of 2013.

Impoundments 1 and 2. At the end of 2012, Pfizer revealed the general outline of its plan to conduct a detailed, large scale field pilot study for treating the very difficult wastes in Impoundments 1 and 2.

With its design studies approved by EPA, and permits issued by NJDEP, Pfizer’s engineers have installed equipment for an elaborate 3 month pilot treatment study (see my September 2013, and October/November 2013 Technical Reports for details). As of early January, the 3 month pilot study is about to begin.

Site-Wide Remedy (OU4). With the September 2012 EPA Record of Decision for the site-wide remedy, Pfizer embarked on the detailed design on the remedy, including:

  • -  Laboratory treatability studies of ground water treatment processes

  • -  Bedrock geologic studies of ground water, leading to determination of how to extract sufficient volumes of deep ground water from the complex bedrock formations beneath the site.

  • -  Development of work plans for remediation of site-wide soils and impoundments. 2013 Overview

    -  Actions taken toward the Impoundments 1 and 2 remediation are quite visible, as seen by Ross Stander and me during our November 7, 2013 inspection of the site. Remediation methods being tested are promising, but unproven. Progress made toward the site-wide remedy is more of the nature of design, treatability studies and investigations, and therefore is not as evident.

    -  Positive steps occurred in 2013, even as some schedules have slipped. CRISIS will continue to monitor progress and schedules, and will question many of the elements of the proposed remediation in 2014 as we deem necessary when details are made known to us, in order to represent the interests of the community at large.

    -  More detailed information can be found on our web site, www.crisistoxicwatch.org as well as web sites posted by Pfizer and by USEPA.

    -  CRISIS, Inc. and its Board wish all readers and members a good healthy 2014, a year during which we hope to see improvement in the local (American Cyanamid) environment and the global environment.

Ira L. Whitman, P.E., Ph.D Technical Advisor to CRISIS, Inc. January 15, 2014

=========================== end of article ===========================





Ira L. Whitman, P.E., PhD Technical Advisor

October/November 2013

Issued November 26, 2013



          Ross Stander, Executive Chairman of CRISIS, Inc., and Ira Whitman, Technical Advisor to CRISIS attended an information meeting with Pfizer at the American Cyanamid Superfund site on November 7.  Also attending the meeting were representatives of USEPA, NJDEP and 5 of Pfizer’s technical and management consultants who are working on elements of the Superfund remediation.  The meeting included a tour of the site, with emphasis on the Impoundment 2 Pilot Study which is under construction.


          The November 7 meeting took the place of the monthly telephone conference call update that normally would have occurred on October 27.  For this reason, CRISIS decided to wait for November 7 before preparing an October Technical Report.  Accordingly, I have prepared one combined October/November Technical Report so that the most up to date information could be included.





          The September 2013 report (issued on October 21, 2013) focused largely on the Impoundment 1 and 2 Focused Feasibility Study (FFS) and the Impoundment 2 Pilot Study.  Section 2.0 of this report represent a significant update on this element of the September report.





          The Pilot Study was largely described in my September report and by Pfizer at the EPA October 24 public information availability meeting at The Bridgewater Municipal Building.  It can be thought of as including the following steps:


1.        Planning (completed)

2.        Design (completed)

3.        Construction (nearing completion)

4.        Installation of process and monitoring equipment (under way)

5.        Pilot test operation and monitoring

6.        Contaminant treatment

7.        Shutdown and decommissioning

8.        Sampling and evaluation of results

9.        Determination of viability of technologies tested.


          With regard to each of these steps, they fit into the overall Superfund remediation process as follows:


·          Planning:  Following laboratory treatability studies of the wastes contained in Impoundments 1 and 2 in 2012, Pfizer recommended that the field Pilot Study be conducted to determine if the recommended treatment processes could be scaled up to actual size in the two impoundments which cover almost 4 ½ acres (approximately 190,000 square feet) and which contain over 50,000 cubic yards of difficult to treat toxic waste.


·          Design:     Completed in first half of 2013, with some design elements approved by EPA, others currently under review.


·          Construction:   Beginning in July 2013, Pfizer’s engineers assembled and erected a floating platform on the surface of Impoundment 2, on which cranes and other construction equipment were mounted in order to install three (3) 8’ diameter steel caissons into the lagoons.  The caissons are fixed into place with support from the floating platform – as was observed by Ross Stander and me on November 7.  The construction phase was nearing completion as of November 7.


·          Installation of Process Equipment:    With the construction phase completed, Pfizer will install vapor and water collection equipment, thermal process and solidification equipment, and vapor and water treatment equipment with which to perform the pilot studies.  This equipment is expected to be installed by mid-December, approximately one month later than originally scheduled.


An air pollution control permit will be issued by NJDEP for the pilot test when the test is ready to commence.  It will permit Pfizer to operate the tests for a permit duration of only 90 days.


·          Operation and Monitoring:    The pilot test operations are expected to commence in December and be completed in March 2014.  All environmental impacts – predominantly vapors and air quality, will be continually monitored, as will safety elements, structural stability of the impoundment, and public access to the site.


·          Treatment:                              Volatile vapors and condensed water vapor removed from the three test cells will be collected and treated through the duration of the tests.


·          Decommissioning:    Upon completion of the pilot tests all of the test equipment will be decommissioned, decontaminated and removed from the American Cyanamid site, likely in April – May 2014.


·          Sampling and Evaluation:    The treated contents of the three pilot test cells will undergo physical and chemical testing.  The degree of removal of contaminants will be assessed, as will the structural changes in the material.  The structural changes are important in determining how the material will ultimately be handled and disposed of.


·          Viability of Technologies:    The Pilot Study results will be considered by Pfizer and USEPA and integrated into the overall Focused Feasibility Study for OU8, Impoundments 1 and 2.  The timing of the Pilot Study should enable Pfizer to complete the Focused Feasibility Study by the summer of 2014.


CRISIS will continue to keep the public up to date on the progress of the Pilot Study for Impoundments 1 and 2.  Additional information can be found on the CRISIS web site www.crisistoxicwatch.org.



3.0        SITE–WIDE REMEDY (OU4)


          While the tour of the American Cyanamid site on November 7 focused largely on the Impoundment 2 Pilot Study, most of what was reported by Pfizer and its consultants were reviews of other actions that were taking place with regard to the Site-Wide Remedy (OU4).  Of the many actions moving forward since the Site-Wide Record of Decision (ROD) of 2012 by USEPA, the following are the most note-worthy at this time.


3.1    Ground Water Treatment Facility


          The Site-Wide remedy for American Cyanamid will result in the collection of both shallow and deep (bedrock) contaminated ground water from the entire site for treatment at a permanent on-site waste water treatment plant.  This facility will discharge directly to the Raritan River.  Pfizer and EPA have identified a long list of contaminants known to be in ground water that will be treated, including:


·       Benzene and other aromatic hydrocarbons

·       Chlorobenzenes

·       Analine

·       Chlorinated hydrocarbons

·       Metals


          The effluent discharged from a site-wide ground water treatment plant will have to meet stringent effluent criteria established by NJDEP (effluent is the term used to signify the treated wastewater leaving the plant and discharged into the river).  Pfizer and DEP will be working together to develop Permit-Equivalent conditions for the effluent under a NJPDES (New Jersey Pollutant Discharge Elimination System.) permit equivalent.


          Pfizer’s wastewater consultants have been conducting treatment pilot studies on each category of ground water contaminant at the site, and believe that they have identified several technologies that will meet permit limits for the discharge of each of these contaminants.  They are continuing with these studies.  Interestingly, there are two conditions that reflect combinations of contaminants that are causing the wastewater treatment specialists the greatest difficulty thus far:


·       Total organic carbon (TOC)


·       Whole effluent toxicity


          Total organic carbon reflects the total organic strength of the waste stream rather than that of individual components.  TOC is produced by benzene and by a wide variety of other petroleum derived compounds.


          Whole effluent toxicity reflects the impact of the treated waste on the live biota that populate a receiving water like the Raritan River.


          As a result of these issues, Pfizer’s specialists are conducting additional treatability studies, incurring delays in their completion schedule for this task.  A revised schedule has not yet been presented by Pfizer.  When completed; they will prepare a Field Sampling and Analysis Report (FSAR) which will propose specific treatment technologies for the site-wide ground water collection and treatment system.  CRISIS would expect to review and comment on the FSAR when released by USEPA.


          As reported in my August 2013 Technical Report, under OU8, the Impoundment 1 and 2 Focused Feasibility Study, Pfizer is presently collecting and treating shallow ground water in the vicinity of these two impoundments.  The water is collected as a result of a cutoff wall having been built in 2012 to prevent highly contaminated water from seeping into the Raritan River.  The ground water being collected from the former Raritan River seeps is being treated at a temporary facility on-site.  When the site-wide ground water extraction and treatment facilities are completed, the temporary plant will be closed down and the ground water from the Impoundments 1 and 2 area of the site will be treated in the permanent site-wide ground water treatment facility.


3.2    Ground Water Extraction System


          Controlling and collecting ground water from an old industrial site of several hundred acres with two distinct and different geologic strata is by no means a simple enterprise.


          To efficiently capture all of the ground water beneath the site, as well as all ground water that in the future will infiltrate into the subsurface layers requires a very detailed understanding of the complex bedrock geology, the overburden soil strata, and the hydraulic conditions that lead to the storage and migration of water beneath the American Cyanamid property.  The natural overburden soil on the site is generally 16’ to 20’ deep, with bedrock typically found at depths within 30’ of the ground surface.


          Pfizer’s ground water consultant has recently drilled bedrock bore holes for testing and mapping the subsurface bedrock.  A site-wide geophysical investigation was conducted using electrical resistivity as a means of identifying bedding plane fractures in the rock that define areas of high ground water flow – information needed to map the locations where permanent ground water recovery wells should be installed.  Pump tests will be performed in November and December which are needed to determine the ultimate volume of ground water yield from the bedrock, and to see how the various bedrock fractures and bedding planes are connected with one another.


          While recovery wells will be used to extract ground water from the deeper bedrock zones beneath the site, other measures are applicable to the shallower soil overburden.  To collect water from the overburden, barriers walls will be constructed to intercept the lateral flow of ground water at the selected locations, and collection trenches will be constructed to channel the shallow ground water into sumps and collection points from which it can be pumped into the site-wide collection system that will convey the water to the site-wide treatment facility.


          When constructed, the ground water extraction and collection system will resemble a maze of horizontal and vertical plumbing installed into a complex arrangement of soil, bedrock, surface streams (Cuckel’s Brook), and man made structures including impoundments, roads, rail lines and underground utilities.


          Besides diverting and collecting ground water under these complex conditions, the ground water extraction system will be required to meet one other significant test; hydraulic control.  Under standard regulatory practice, Pfizer must exercise hydraulic control over all surface water and ground water that enters the site and that originates on the site so that no contaminated surface water or ground water can exit the site.  In other words, a ground water system on (and beneath) a Superfund site must be a “Closed System” such that no water with contaminant concentrations exceeding applicable standards may exit the site without being treated to acceptable levels.


          Designing a site-wide ground water extraction system is further complicated by natural conditions at the American Cyanamid site, which include:


·       Seasonal variations in elevations of the ground water table

·       Periodic flood conditions which inundate the site adding huge volumes of water on a temporary basis, disrupting normal operations.


          Pfizer’s schedule for design, construction and start-up of operation for the site-wide ground water collection and treatment system was specified back in 2012 to be completed by the end of - 2015.  This date is no longer considered as being realistic, but a new date for the completion of the ground water management system has not yet been provided to CRISIS, Inc.  The absence of a firm schedule for completion is of concern to CRISIS at this time.  Once this system is operational, it can be anticipated that it will be necessary to collect and treat ground water site-wide for decades.


3.3    Other Elements of the Site-Wide Remedy


          In addition to ground water collection and treatment, Pfizer is working on other elements of the site-wide remedy (OU4) including;


·       Pre-Design Investigations (PDIs) of Impoundments and Site-Wide Soil

·       Flood Storativity Analysis

·       Ambient Air Monitoring Program.


          These other important elements of the Site-Wide Remedy will be reported on in future Technical Reports by CRISIS, Inc. as more information is made available by Pfizer and USEPA.


          With the November 2013 Technical Report, I am completing my first year as Technical Advisor to CRISIS, Inc.  I appreciate the opportunity to continue working with the CRISIS, Inc. Board and members, and welcome your questions, comments and suggestions.  I also appreciate the professionalism and cooperation of the persons at Pfizer, its contractors and consultants, USEPA and NJDEP who have made it easy for me to obtain the information I need to be able to assist CRISIS and the general Somerset County community that has lived with concerns regarding the American Cyanamid Superfund site for decades.





                                                                                    Ira L. Whitman, P.E., Ph.D.

                                                                                    Technical Advisor to CRISIS, Inc.

                                                                                    November 26, 2013

=========================== end of article ===========================




Ira L. Whitman, P.E., PhD Technical Advisor

September 2013

Issued October 21, 2013

  1. update on prior technical reports

The August 2013 Technical Report dealt primarily with ground water.  Several issues discussed in my report were updated during Pfizer’s monthly conference call update on September 23, 2013 with USEPA and CRISIS, Inc.

  • Semi-annual ground water sampling – to be conducted during October 2013.  CRISIS will review the sampling results when received, and will report on this sampling round in a future Technical Report.

  • Cuckel’s Brook Seeps – the interim measure to control the flow of contaminants from the seeps was carried out in August.  The inspection and monitoring plan for the seeps was approved by USEPA in September.

  • The annual surface water and sediment report was submitted to USEPA on August 22 and is still under review.  CRISIS received validated surface water and sediment monitoring data from this report in early October, and will review the data for changes from previous reports.

  1. Impoundment 1 and 2 focused feasibility Study (FFS)

Several years ago it was determined by EPA and Pfizer that Impoundments 1 &2 should be separated from the American Cyanamid site-wide remedy because of the unique and complex set of treatment challenges presented by the wastes in these two impoundments.  Therefore in mid-2009 USEPA moved these two waste storage impoundments into a separate Focused Feasibility Study. (FFS).  The FFS for the remainder of the site was completed and in September 2012 EPA issued a Record of Decision (ROD) for a site-wide remedy for all other impoundments, requiring remediation.  A separate Focused Feasibility Study was initiated for Impoundments 1 &2.

The FFS for Impoundments 1 and 2 has been on-going for several years, with the process involving the following steps:

  • Evaluation of earlier studies by American Cyanamid
  • Screening of additional treatment technologies
  • Laboratory bench scale testing of waste samples from Impoundments 1 &2.

In late 2012 Pfizer proposed to conduct a large scale Field Pilot Treatability Study of the wastes in these impoundments, and selected Impoundment 2 as the target study area as this impoundment presents the more difficult waste treatment challenges.  The study was targeted for the 4th quarter of 2013.  CRISIS, Inc. has been following Pfizer’s preparations for the Field Pilot Treatability Study of Impoundment 2 by attending several meetings with Pfizer, reviewing monthly progress reports and by reviewing Pfizer’s October 2012 report to USEPA, Impoundments 1 and 2 Treatability Study Results.

  1. Impoundment 2 Pilot Study – Schedule and procedures

The Pilot Study is scheduled to begin in November and conclude in March 2014.

  • September 4 – PSIP (Project Safety and Implementation Panel) met with neighbors to the American Cyanamid site to discuss field activities and logistics.

  • Local and county Emergency Management officials met with Pfizer, USEPA, Bridgewater Township and CRISIS on September 19, and a site visit was included in the program of the meeting.

  • At 6:30 PM on October 24 a public information availability meeting will be held at the Bridgewater Municipal Building.  This meeting is a great opportunity for CRISIS members and the general public to learn about the planned Pilot Study, and what the community should be concerned about.

  • CRISIS, USEPA and Pfizer will meet on November 7 to update the status and details of the Pilot Study.

  • Look for the Frequently Asked Questions (FAQs) sheet about the Pilot Study on The CRISIS website.  On the website, check out the Fall 2013 Newsletter of CRISIS, Inc. by Ross Stander, Executive Chairman of CRISIS, Inc.  Ross provides additional information on the September 19 meeting and on other elements of the preparations for the Pilot Study.  For this information go to www.crisistoxicwatch.org.  You will find tab headings for FAQs and Newsletter (which were also e-mailed to CRISIS’ readers).

  1. charateristics of impoundments 1 and 2

Impoundments 1 and 2 are located in the southeastern portion of American Cyanamid, between the rail line that traverses the property and the Raritan River.  Located about 1,100’ to the west of I-287, the impoundments are approximately 700’ from the Raritan River at their nearest point.  Impoundment 1 is about 2.1 acres in size with a volume of waste material of about 24,200 cubic yards; Impoundment 2 is 2.3 acres with about 30,300 cubic yards of waste material.  The Impoundments have been covered by a cap of synthetic membrane and water to prevent the escape of vapors and odors.

Between 1947 and 1965 American Cyanamid manufactured the very common petroleum based compounds of benzene, toluene and xylene from the raw material of light oil produced from coal.  A by-product of refining light oil from coal is known as acid tar, a material that not only contains the hazardous substances of benzene, toluene and xylene, but which is exceedingly acidic and therefore highly corrosive, with a very low pH.

Acid tar has a high content of hazardous organic compounds that are volatile and highly malodorous.  The material has many difficult physical characteristics, including

  • It is a heterogeneous mixture of not only many different chemicals, but of many material types and structures

  • As such, not only is it difficult to treat chemically, but it is difficult to handle physically.  The primary categories of materials are hard crumbly – with a solid physical structure, not liquid, and viscous rubbery – best described as difficult smelly “goo”.

In the past, treatability studies were performed on these materials, all of which had significant limitations and therefore none of these could be implemented full scale.  However, laboratory bench scale treatability testing in 2012 has led Pfizer to select two (2) separate technologies that will be field tested in the upcoming pilot study.

  • In-situ Thermal Treatment
  • In-situ Solidification and Stabilization
  • Combination of both technologies.

  1. pilot study operation

Earlier in 2013, Pfizer’s consultants completed the engineering design of the pilot study equipment and operations, and USEPA approved the engineering design.  Since July, Pfizer has been acquiring, constructing and assembling the equipment to be used in the pilot study.

Three cylindrical steel columns, 8 feet in diameter, are being lowered into the northwest section of Impoundment 2, where they will be eased on to the floor of the impoundment.  These cylinders or caissons will each be covered by a circular vapor collection “shroud”, with ventilation openings and hinged steel access doors on top.  The caissons will be accessed in place using devices known as flexifloats, which will be able to support a crane and other equipment while floating on the surface of the impoundment.

  1. Thermal Treatment.

Test cell 1 will be used for thermal treatment only.  Using electrical heating and mixing, the contents of the 8’ diameter cell (containing 250 to 300 cubic feet of waste material) will be heated to approximately 100°C (212°F).  Vapors will be released by this process and collected under the vapor shroud.  Vapors and liquid condensate driven off by the thermal treatment will themselves be treated.  The test procedures call for collecting and testing the core material subjected to the thermal treatment, and evaluated for the degree of removal of the hazardous compounds and the changes in the physical properties.

Test cell 2 will be used for solidification and stabilization of the waste material within the 8’ diameter test cell.  The process is carried out by introducing a slurry of reagent and solidification chemicals, mixed with water, that are designed to achieve the following results:

  • Immobilize hazardous chemical compounds
  • Increase pH
  • Reduce permeability (ability of water to penetrate)
  • Increase compressive strength.

Test cell 3 will be used to conduct thermal treatment which then will be followed with the introduction of a reagent mixture and allowed to cool to ambient temperature.  Following the test, the material in cell 3 will be evaluated for both the removal of hazardous compounds and the changes to the physical properties of the material in the cell.

Following the completion of the Impoundment 2 field pilot study, and the assessment of the results, Pfizer is scheduled to complete the Focused Field Study report for Impoundments 1 and 2, most likely in the summer of 2014.

CRISIS, Inc. will review the pilot study test results when available, and will be eager to receive the FFS report when it is completed and reviewed by USEPA.  The FFS is designed to evaluate a range of remedial options for Impoundments 1 and 2 taking into consideration that the impoundments are in the flood plain.  There will be opportunities for community and stakeholder input into EPA’s decision, and CRISIS, Inc. will continue to inform the public and provide a forum for the point of view and concerns of the community.

Ira L. Whitman, P.E., Ph.D.

Technical Advisor to CRISIS, Inc.

October 21, 2013

=========================== end of article ===========================





Ira L. Whitman, P.E., PhD Technical Advisor


August 2013

Issued September 20, 2013



          CRISIS reviews status reports issued to EPA by Pfizer on a monthly basis.  The August reports indicated that work on the Site-Wide Remedial Design (OU4) and the Impoundments 1 and 2 Focused Feasibility Study (OU8) is continuing.  I have reported on the details of some of this work in previous Technical Reports, and will do so again in the future.  Activities of note include:


·       EPA is planning a public availability meeting on the evening of October 24th to discuss the upcoming field pilot test at Impoundment 2 to begin in November.  CRISIS, Inc. plans to provide additional information on its website regarding this meeting, such as time and location, when these become known.

·       On September 19th, Pfizer and EPA met with community emergency management officials to inform them about the field pilot tests that will begin in November.  CRISIS, Inc. will report on the outcome of this meeting.

·       CRISIS will present a fact sheet of Frequently Asked Questions (FAQs) about the Impoundment 2 field pilot test on its website.

·       CRISIS, Inc. has requested that Pfizer provide our group with progress updates on key elements of the design of the OU4 site-wide remediation.  Meetings to provide these updates are to be scheduled.  CRISIS, Inc. has reiterated its concerns expressed previously to Pfizer and EPA about the site-wide remedy.


          For this month, I have decided to concentrate on one particular issue that underlies much of the present and future activity associated with cleaning up this site:  GROUND WATER.





          Ground water is generally a misunderstood element of the natural environment that is a factor in most environmental cleanup situations, including remediation of the American Cyanamid Superfund site.


          Ground water is present in most locations beneath the Earth’s surface at an elevation known as the “water table.”  It is an important component of the hydrologic cycle that transfers water from precipitation through the ground to rivers and streams and ultimately to the oceans, from which it is evaporated back to the atmosphere to repeat the cycle.  Ground water supports some of the Earth’s vegetation, balances flow of water into and out of rivers, and is utilized heavily in New Jersey to provide safe potable water to millions of persons.  Ground water is a fragile ecological resource that is easily damaged in quality and diminished in quality.


          At the American Cyanamid site, ground water is present in two zones beneath the surface:


               ·          Overburden Zone – Present in the soil cover beneath the surface, as near to the surface as 5 feet at some locations, including the flood plain adjacent to the Raritan River.

               ·          Bedrock Zone – Present in cracks and crevasses in the massive bedrock beneath the site that is known geologically as the Passaic Formation.


          Many persons refer to ground water as “underground rivers” a concept that may describe its large presence but which does not reflect its movement.


          The forces of gravity cause water in the ground to move – usually very slowly in the order of several feet per year.  Dissolved contaminants in ground water move with it, but usually at a slower rate as their movement may be retarded by the soil.  At many locations, shallow ground water may move in one direction, usually reflecting local topography, while deeper bedrock ground water may move in a completely different direction at a different rate of movement (velocity).





          At many Superfund sites, ground water cleanup is the most costly and time consuming element of the entire program of remediation.


          According to EPA (Removal Action Order of 2011):


A partial ground water containment system (at American Cyanamid) was constructed and continues operating on the Site.  The system consists of two extraction wells installed into the bedrock.  The groundwater extraction well system has been operating for approximately 30 years to control the migration of contaminated groundwater through continuous pumping. This system operates 24 hours a day seven days a week and pumps a minimum of 650,000 gallons of groundwater per day that is subsequently treated offsite at the neighboring SRVSA municipal wastewater treatment system.


         The system described by EPA was not designed to clean up ground water at American Cyanamid but was installed to “contain” the water and prevent contaminants from migrating off-site by exercising “hydraulic control” over the water.


         EPA’s Record of Decision (ROD) for Operable Unit 4 (OU4) of the American Cyanamid site was issued in September 2012, and deals with the entire site with the exception of the area on the southern portion of the site with Impoundments 1 and 2, which is known as OU8.


         The 2012 ROD specifies the selected (by EPA) remedy, which for ground water includes:


               ·          Relocation of primary bedrock extraction wells to a more central location, and adding new extraction wells.

               ·          Construction of an overburden ground water recovery system such as trenches, containment walls and shallow wells.

               ·          Treatment of ground water on-site with discharge of the treated water to surface water (Raritan River).


         In response to the ROD, Pfizer has been conducting geophysical testing in the bedrock to better characterize the presence and movement of the bedrock ground water, as a prerequisite to installing new wells.  The company is also in the process of completing a pilot study and laboratory testing to determine which treatment processes are likely to be needed in order to meet the requirements of the ROD to “restore the overburden and bedrock aquifers within the area of attainment to their expected beneficial use and to concentrations below the more stringent federal and state ground water quality standards within a reasonable period.”





         In 2006 - 2007, based upon a Remedial Investigation for ground water, it was reported that shallow ground water in the vicinity of Impoundments 1 and 2 flows from north to south toward the Raritan River.  Field investigations in 2010 identified four (4) potential ground water discharges (seeps) to the Raritan River, three (3) of which were observed to be below the river’s surface water line. The fourth seep, about 65 feet long, was observed discharging from the river bank above the water line.  On December 6, 2010, a surface water sample was taken from the river at this point, to collect as much material emanating from the seep with as little dilution from the river as possible.


         The laboratory analysis of the December 6, 2010 water sample from the river showed concentrations of seven contaminants in excess of New Jersey Ground Water and/or Surface Water Criteria.  Six of these were metals, with the seventh being a notable contaminant marker compound known to be present within the waste stored in Impoundments 1 and 2, Benzene.


         The following table shows the December 6, 2010 concentrations of the seven (7) contaminants in parts per billion, micro grams/liter, or ug/l.





in ug/l

NJ Ground Water


NJ Surface Water


































in ug/l

NJ Ground Water


NJ Surface Water











          The source of the metals in the river is unclear, with some of these metals likely originating at American Cyanamid.


          The source of the Benzene in the river was clear – the southern portion of American Cyanamid likely including Impoundments 1 and 2.


          On July, 19, 2011 EPA executed an Administrative Consent Order known as the “Removal Action Order” which labeled the ground water in the vicinity of Impoundments 1 and 2 as “conditions that constitute an actual or a threat of “release” of a hazardous substance from the facility”.  The Settlement Agreement with American Cyanamid was “necessary to protect the public health, welfare, or the environment”.



          Referring to the discharge to the Raritan River, EPA ordered American Cyanamid to


Design and construct a Removal System which will block, intercept and capture or otherwise address to EPA’s satisfaction (i) the known seeps… (ii) any other seeps discovered during construction of the removal system, and (iii) those seeps or discharges identified in studies … that are found discharging to the Raritan River, Cuckel’s Brook or from the Route 287 Pond to the Raritan River and Middle Brook…


          In 2012, Pfizer constructed a cutoff wall between Impoundments 1 and 2 and the river, and a small wastewater treatment plant for the ground water intercepted near the river.  This interception and treatment system began operating in May 2012.  Modifications to the system were developed to deal with such issues as freezing, toxicity testing of effluent and treatment plant operation.


         Water quality samples from the Raritan River are collected quarterly, and have been reported on in my previous Monthly Technical Reports.  Through January 2013, concentrations of Benzene in the river at three (3) locations in the vicinity of Impoundments 1 and 2 exceeded the NJDEP surface water standard of 0.15 ug/l (parts per billion).  In my June 2013 report, I reported that for the first time, in May 2013, Benzene at all locations in the river were in compliance with the 0.15 ug/l standard.


         CRISIS will continue to report on Raritan River surface water quality as the results of new quarterly sampling rounds are received.





         Cuckel’s Brook is a small stream that internally transects the American Cyanamid site, flowing into the Raritan River from northwest to southeast.  The natural flow of the brook is very small, but in the past it carried the effluent from the SRVSA waste treatment plant which greatly exceeded in volume the natural stream flow.  Cuckel’s Brook does carry a small volume of shallow ground water inflow to the stream from American Cyanamid at locations on the property where the shallow ground water remains highly contaminated, including the areas adjacent to Impoundment 5 and Impoundment 2.


          As reported in my May 2013 Technical Report, on May 6 a sheen (small oily slick) was observed on Cuckel’s Brook in the vicinity of one of the surface water sampling locations, and further observation showed the presence of a ground water seep into the brook.  The water at the location of the seep was sampled and analyzed as reported in June.  In my July report, I indicated that following inspection of the entire length of the brook running through the property, other seeps into Cuckel’s Brook were found.


          The following actions were reported by Pfizer as having been taken as a consequence of their findings with regard to Cuckel’s Brook.


·       Water samples from two of the newly discovered seeps were taken on July 24.


·       Preliminary data from the seeps indicated that the impact to water quality in the stream warrants an interim treatment measure; carbon bags to treat water on a temporary, localized basis.  EPA has approved this as an interim measure.


          CRISIS, Inc. recommends that Pfizer continue to monitor water quality in Cuckel’s Brook, and to evaluate whether the interim measures taken in response to these discharges are adequate and appropriate based on the mass of the contaminants seeping into the brook.  Pfizer should determine whether additional measures are needed to protect surface water until the long term collection and treatment measures for site-wide ground water issues prescribed in EPA’s 2012 ROD are implemented.


          Ground and surface water will continue to be a major concern to CRISIS, Inc.  We anticipate the need to report frequently on ground water issues at the American Cyanamid site.





                                                                                    Ira L. Whitman, P.E., Ph.D.

                                                                                    Technical Advisor to CRISIS, Inc.

                                                                                    September 20, 2013

=========================== end of article ===========================




Ira L. Whitman, P.E., PhD Technical Advisor

July 2013

Issued August 16, 2013

  1. impoundments 1 and 2 (OU8) Update

CRISIS met with Pfizer and EPA on July 23 to review progress on the Impoundments 1 & 2 Pilot Test Program phase of the OU8 Focused Feasibility Study.

Impoundments 1 & 2 cover a total area of nearly 4 acres on the south side of the American Cyanamid site.  They are located approximately 800 feet north of the Raritan River, in the flood plain.  For over 50 years they have contained solid and semi-solid waste from a coal light-oil refining process, with three distinct layers of waste; a light-oily sludge, a viscous-rubbery tar layer, and a hard-crumbly tar layer.  The material is difficult and nasty to handle as a consequence of its physical properties and chemical properties.  It is highly acidic, with sulfuric acid being used in the industrial operations that produced the waste.

The waste material to be treated contains Volatile Organic Compounds (VOC) including benzene derivatives, and Semi Volatiles including Napathlaene.  The waste material gives off strong odors, and vapors.  The pilot test will be conducted in Impoundment 2. 

In November 2012, Pfizer briefed CRISIS on its EPA-approved plan to determine the best methods for treating these wastes by performing large scale pilot studies in 2013, which follow bench scale laboratory treatability studies conducted in 2012.  Pfizer’s report to CRISIS on July 23, 2013 detailed the concept and design for the pilot studies. 

Key elements of Pfizer’s report to CRISIS include Pilot System Construction, August-November 2013; and Pilot Study Operations, November 2013 -March 2014.

Construction steps will include:

  • Infrastructure for the test, Aug/Sept, including construction of a test area bench, flexi floats and anchoring.
  • Conduct a clay tar survey, September
  • Installation of caissons within which pilot test will be performed, October 
  • Vapor treatment system construction and start-up, November

Berm Armoring:

  • Sept. 2013, Pfizer will reinforce the berms surrounding Impoundments 1 & 2 for containment

Pilot Study Operations:

  • Thermal treatment, Nov 2013 - Feb 2014
  • Stabilization/Solidification, Feb/Mar 2014

The pilot study infrastructure and berm armoring are designed to withstand flooding from The Raritan River should that occur between now and March 2014.

Three treatment processes will be undertaken during the November-March testing period:

  1. Thermal treatment of the waste
  2. Stabilization and solidification
  3. Combination of 1 & 2

In addition, vapors released by the thermal treatment will be collected and treated.

Safety elements incorporated into the design include:

  • Ability to withstand category 2 hurricane events
  • Vapor treatment system elevated above the flood plan
  • Thermal treatment will be conducted under oxygen-deprived conditions
  • All processes were evaluated using a Process Hazard Assessment.

Pfizer is installing piezometer wells around the periphery of Impoundment 2 to monitor ground water quality before, during and after the pilot test.

During the pilot test, real-time air quality monitoring will be conducted at locations along the perimeter of the American Cyanamid property. If the air quality test results are unsatisfactory, or if there are unacceptable odors, the test will be shut down.

Following the pilot test, EPA and Pfizer will evaluate the results to determine which methods are most effective and feasible in remediating the hazardous chemicals stored in Impoundments 1 and 2. 

As the test moves forward, CRISIS will provide updates to the community as we follow the pilot study program in detail.  As the results of the pilot testing are factored in to the overall Feasibility Study for Impoundments 1 and 2, CRISIS will focus its attention on the critical ultimate question for this area of the site: Can the treated waste material be allowed to remain in place in an area where Impoundments 1 and 2 are capped, or will the waste have to be removed following full treatment with permanent disposal off site in a secure landfill?

  1. site-wide remedial design (ou4)

EPA has designated Operating Unit 4 (OU4) as all areas of the American Cyanamid site for soil and ground water excepting Impoundments 1 & 2.  Pfizer’s schedule for OU4 calls for submittal of the 30% design for the site-wide ground water treatment facility to EPA in September 2013.

While interim removal and treatment measures for ground water control and treatment are presently in operation, the ultimate plan for ground water remediation is to collect ground water from shallow and deep bedrock wells site-wide, and to treat ground water at one on-site facility, equipped with several treatment processes.  The effluent from the site-wide facility is to be discharged into the Raritan River, an event which his several years in the future.

Pfizer has been conducting laboratory testing on ground water, and pilot studies on various proposed treatment processes for the site-wide ground water remediation.  The treatment processes selected will have to be capable of removing volatile organics, semi volatile organic compound and metals. 

  1. cuckel’s brook

In my May and June 2013 Technical Reports I discussed the finding of a contaminated ground water seep into Cuckel’s Brook, on the American Cyanamid site.  This seep is located in the vicinity of the highly contaminated Impoundment 5.

Pfizer reports that the entire American Cyanamid site is bounded by fencing to keep unauthorized persons from entering, and that there are physical barriers on the brook itself that will prevent persons from exposure to the brook and the contaminated seeps. 

Following inspection of the entire length of the brook, other seeps have been found.  Pfizer is submitting a work plan to EPA for interim measures to contain and intercept these seeps, to keep the contaminants from reaching Cuckel’s Brook.

The newly discovered seeps were to be sampled later in July.  CRISIS will be given the sampling results and I will discuss the results in a subsequent report.  The seeps impact water quality in Cuckel’s Brook adversely, but due to the small volume of water seeping into the Brook, the total volume of contaminates impacting the brook is relatively small. 

The source of the seeps is chemicals in the ground water derived from waste discharges or storage in the immediate vicinity of the brook, indicating that shallow ground water in these areas is not fully under control.  Eventually this ground water will be collected and treated at the site-wide ground water treatment facility under design as discussed under Site-Wide Remedial Design, Section 2.0 of this report. 

CRISIS will continue to monitor Pfizer’s findings and actions with regards to Cuckel’s Brook.  

Ira L. Whitman, P.E., Ph.D.

Technical Advisor to CRISIS, Inc.

August 15, 2013

=========================== end of article ===========================





Ira L. Whitman, P.E., PhD Technical Advisor


June 2013



          EPA’s monthly status update meeting with CRISIS, Inc. was held on June 24, 2013.  Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc.  The format for the monthly call has been changed by Pfizer who is now providing EPA with monthly progress reports as required under the recent Administrative Settlement and Order of Consent executed between Pfizer and USEPA.



1.0        surface water sampling results


          Pfizer conducted surface water sampling in early May at 10 locations in the Raritan River, 9 locations in Cuckels Brook (which transects the American Cyanamid Property), and at one location in the Millstone River and one in Middle Brook.


          Of primary interest, concentrations of benzene in the Raritan River diminished in May 2013 relative to all previous sampling events.  In the three sampling locations of greatest concern, immediately downstream of Cuckel’s Brook, the benzene concentration changes from January to May 2013 were as follows.




Benzene- ug/l*


Sampling Location

Approximate Distance below entry point of Cuckel’s Brook


January 2013


May 2013












Below detection


*ug/l- Micrograms per liter


          Notably; the NJDEP surface water quality criteria for benzene is 0.15 ug/l, so for the first time, in May 2013 all surface water samples from the Raritan River met this standard for benzene.


          In Cuckel’s Brook, as before, benzene was detected in seven surface water samples, CB-02 through CB-08, a distance about 0.8 miles.  This stretch of Cuckel’s Brook is directly adjacent to much of the waste storage and disposal areas of the American Cyanamid site.  While concentrations of benzene and other organic compounds exceed standards in Cuckel’s Brook, the volume of flow in the brook is quite small, hence the net contribution of organic contaminants to the Raritan River from Cuckel’s Brook is low.



2.0       ground water seep into cuckel’s brook


In my May 2012 Technical Report, I reported the presence of a small seep of ground water into Cuckel’s Brook near samplings station CB-06.  Pfizer has provided the analytical data from a sample taken of the seep to CRISIS, and as would be expected there are very high concentrations of a number of organic compounds.  The compounds listed below are present in the seep in concentrations that exceed the concentrations of the same chemicals nearby at CB-06 in Cuckel’s Brook by at least 3 orders of magnitude (1000x)



1,2 Dichlorbenzene

1,2 Dichloroethene








          As a result of finding this ground water seep, Pfizer and USEPA conducted an inspection of much of the length of Cuckel’s Brook and identified other locations with ground water seeping into the brook.  These other discharges are to be sampled on July 17. 


          Pfizer may pursue an interim treatment action for the contaminants finding their way into the brook, utilizing activated carbon bags along the bank of the brook.  Ultimately Pfizer will have to intercept the seepage flow into the brook, collect it and treat it, likely as part of its site-wide ground water collection and treatment program, which is presently in the design phase (Operating Unit-OU4)


          CRISIS will continue to follow this relatively new development at the American Cyanamid site, and periodic updates of how this is being managed will be presented in future Monthly Technical Reports.



3.0        Pfizer status update


          Pfizer’s work on designing its Pilot Study for Impoundments 1 & 2 is progressing on it’s revised schedule.  Construction related to the pilot study is scheduled to begin in late July, and the pilot study itself is scheduled to begin in late November 2013 at The American Cyanamid site.


          Pfizer is looking to accelerate its treatment of water contained in an impoundment known as Lagoon #7, which primarily contains storm water.  Following treatment for pH adjustment using neutralization and filtration, the water in Lagoon #7 will be discharged into the sewerage system operated by the Somerset Raritan Valley Sewerage Authority.



          CRISIS is scheduled to meet with Pfizer and EPA on July 23 to review progress on the Impoundments 1 & 2 Focused Feasibility Study (OU8).  We will report on the results of this meeting in the next Technical Advisors Report.




                                                                                    Ira L. Whitman, P.E., Ph.D.

                                                                                    Technical Advisor to CRISIS, Inc.

                                                                                    July 15, 2013

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Ira L. Whitman, P.E., PhD Technical Advisor

May 2013

    EPA’s monthly status update meeting with CRISIS, Inc. was held on May 20, 2013.  Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc.  The format for the monthly call has been changed somewhat by Pfizer who is now providing EPA with monthly progress reports as required under the recent Administrative Settlement and Order of Consent executed between Pfizer and USEPA (see my April 2013 Technical Report).  Future monthly status meeting are being changed from the third to the fourth Monday of each month.

downstream water intakes from raritan river

    CRISIS recently received an inquiry as to the presence of drinking water supply intake from the Raritan River downstream of the American Cyanamid Superfund site.  The query implied that any such intakes should be coupled with extensive analysis of any contaminants in the river water, and measures to treat such water prior to distributing it for potable use.

    Information provided by the New Jersey Water Supply Authority indicates that no drinking water supply intakes are situated on the river downstream of The American Cyanamid site.  This is both good news in terms of potential impacts to the public from the Superfund site, and logical as the Raritan flows southeastward from Bridgewater and Bound Brook.  The river becomes tidal in less than 5 miles, and once tidal is no longer suitable as a source of fresh potable water.

background on public water supply sources for bridgewater

    For a state that is one of the smallest (in geographic extent) in the nation, New Jersey has a complex system of public water supply agencies and private water companies that utilize a multitude of fresh water sources delivered to millions of residents and businesses through a complicated network of public water systems

    All public water systems1, in New Jersey and the country are required to perform, at a minimum, the following steps.

Sample and monitor water at its point of entering the system
Provide physical and chemical treatments to meet state wide drinking water standards
Provide disinfection to meet bacteriological standards
Meet taste and odor requirements based on subjective parameters in these categories
Sample finished water following treatment
Publish its finished water quality data and distribute such data to its customers

    Chris Paulson, of the Bridgewater Health Department reports that Bridgewater presently relies largely on surface water as provided by the New Jersey American Water Company, whereas 20 years ago a significant volume of water was withdrawn from the ground using wells in the Finderne section of the Township2.

    It should be understood that CRISIS, Inc. does not provide monitoring, study or evaluation of any public water systems (nor of private well) or treatment of them in any municipality or region.  This is not part of CRISIS, Inc.’s mission.

    CRISIS does seek to understand whether contamination from the American Cyanamid site enters ground water aquifers or surface water sources (e.g. Raritan River) of potable water.

Pfizer status update

    Much of the progress reported by Pfizer in its May 20 status meeting pertains to pre-determined milestones with regard to its primary remediation activities, and its interaction with the regulatory agencies, USEPA and NJDEP.  Highlights include:

    Impoundments 1&2 Focused Feasibility Study (OU 8)

EPA has provided comments to the 30% design for Impoundments 1&2 (now referred to as OU [Operating Unit] 8)
Pfizer anticipates that the field pilot study for the two impoundments will be carried out from November 2013 through March 2014.  (The actual study will be conducted in Impoundment 2).
EPA anticipates conducting a public information meeting regarding the OU 8 field pilot study several months prior to the start of the study

    Site Wide Remedy (OU4)

The ground water treatment Feasibility Pilot Study is on-going.  A comprehensive ground water plan is expected during the first half of 2014.
Pfizer is conducting a Flood Storability Analysis and planning for soil importation, the results of which will be shared with CRISIS.
Pfizer’s quarterly surface ground water and sediment monitoring program was carried out on May 6.  At that time a partial drum was found in Cuckel’s Brook, removed and laboratory analyzed.

    Impoundments 1 & 2 Ground Water Removal Action

A sheen was observed on Cuckel’s Brook and further examination led to the discovery of a ground water seep into Cuckel’s Brook in the vicinity of sampling station CB-06.  Laboratory analysis of the water from the seep indicated the presence of many volatile organic and semi volatile organic compounds, including benzene, toluene and chlorinated solvent compounds.  Since Cuckel’s Brook discharges directly into the Raritan River, CRISIS will continue to review all surface water quality results for samples taken from the Raritan River.  Pfizer was scheduled to conduct its 2nd quarter 2013 surface water and sediment sampling in the River during the second week of May.  The sampling results will be discussed by me once the analytical data are made available by Pfizer.
As a result of discovering the ground water seep, Pfizer will perform a reconnaissance of the balance of the areas adjacent to Cuckel’s Brook.
EPA and Pfizer are developing a plan for soil removal between the subsurface barrier wall and the Raritan River, designed to reduce the amount of benzene seeping into the River.

                Ira L. Whitman, P.E., Ph.D.
                Technical Advisor to CRISIS, Inc.
                June 20, 2013

=========================== end of article ===========================

Monthly Technical Report - April 2013
American Cyanamid Superfund Site
Ira L. Whitman, P.E., PhD Technical Advisor
April 2013
          EPA's monthly status update meeting with CRISIS, Inc. was held on April 15, 2013.  Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc.  One issue discussed that is of particular interest to CRISIS Inc. is Whole Effluent Toxicity Testing, conducted by Pfizer on the effluent from the ground water treatment system installed to treat ground water collected in the vicinity of Impoundments 1 and 2.
          In my Monthly Technical Report for March 2013 I discussed how surface water in The Raritan River and Cuckel's Brook is sampled quarterly throughout the year, to determine impacts to the river from contaminated ground water in the vicinity of Impoundments 1 &2, and from the discharge of Pfizer's ground water treated system into Cuckel's Brook.  I reported that at some locations in the Raritan and Cuckel's Brook concentration of benzene exceeded New Jersey's
surface water quality standard for benzene of 0.15 parts per billion.
          I also reported that Pfizer believes that concentrations of benzene in surface water will decrease over time, and that CRISIS, Inc. will carefully monitor Raritan River water quality sampling data.
          A second type of sampling is performed on the discharge from the Pfizer ground water treatment plant, known as "Whole Effluent Toxicity Testing", which are biological tests conducted to monitor the impact of the treated effluent on one or more selected test organisms.  In the case of the American Cyanamid site, the test organisms specified were daphnia, defined as "a variety of small freshwater crustaceans of the genus Daphnia.”
          Some species of Daphnia are commonly used as food for aquarium fish.  Daphnia are important organisms in the freshwater food chain; therefore their reaction to treated wastewater or ground water is an important indicator as to whether a treated effluent has a deleterious impact on the aquatic ecosystem.
          In March 2013, Pfizer reported that it had to make several corrective actions to its ground water treatment as a result of unfavorable results from its Whole Effluent Toxicity Testing.  These changes consisted primarily in corrections to chemical imbalances due to natural ground water chemistry, and to the adjustment of the pH (acidity) of the final effluent.  In January, USEPA had approved Pfizer's Preliminary Corrective Action Plan to investigate issues with its Whole Effluent Toxicity Testing.
          In Pfizer's most recent toxicity test report dated March 27, 2013 the laboratory results indicated a 100% reproductive success rate of the test species following the chemical modifications made in the pH adjustment.  With these tests having been successful, Pfizer plans to make modifications to its ground water treatment equipment that will allow the substitution of calcium hydroxide for sodium hydroxide for pH adjustment.
          Pfizer will face similar issues in approximately two (2) years when it implements its site wide ground water treatment programs by collecting ground water from the entire American Cyanamid site, including Impoundments 1 & 2.  Presently, all ground water collected at the site except Impoundments 1 & 2 is being discharged through the publically owned facility operated by Somerset Raritan Valley Sewerage Authority.
          To reach the point of being able to design and construct a site-wide treatment system, Pfizer has developed a Pilot Study Work Plan to evaluate the various treatment processes that may be utilized in a site-wide system.  EPA has reviewed and commented on the Pfizer work plan and the draft plan has been revised in response to EPA's comments.
          The development of an effective site-wide ground water treatment system is an important milestone in implementing a site-wide remedy for American Cyanamid, and CRISIS, Inc. will be paying close attention to Pfizer's progress and to the direction that this component of the site-wide remedies takes.
          Much of the progress reported by Pfizer in its April 15 status meeting pertains to pre-determined milestones with regard to its primary remediation activities, and its interaction with the regulatory agencies, USEPA and NJDEP.  Highlights include:
          Impoundments 1&2 Focused Feasibility Study:
· Permit-equivalency applications for the field pilot treatability study are to be submitted in early May.
· Pfizer and EPA met to discuss the 60% pilot treatability study design status.
          Impoundments 1&2 Ground Water Removal Action
·        Pfizer reported on the success of its modifications to ground water treatment as reflected by the Whole Effluent Toxicity Testing (see Section 1.0 of this report)
·        Soil was excavated between the subsurface cutoff wall and the Raritan River, to be landfill disposed off-site.

          Site-Wide Remedy
                 ·   An Administrative Settlement Agreement and Order of Consent for Remedial Design (OU 4 and OU 8 in accordance with the Record of Decision of September 2012). Project coordinators for the two operable units were named.
                 ·   Pfizer presented USEPA and NJDEP a revised Baseline Ground Water Monitoring Work Plan.  Pfizer's plan includes an update of recent geophysical testing at the site and pilot testing for future planned bedrock extraction wells and overburden collection trenches.
          Ambient Air Monitoring
                    ·            Ambient air sampling was conducted in early April
          Surface Water & Sediment Monitoring Program
                    ·            Sampling is scheduled for May 6-10
          Ground Water Monitoring Program
                    ·            1st half 2013 ground water sampling took place on April 1-12.
                                                                                    Ira L. Whitman, P.E., PhD
                                                                                    Technical Advisor to CRISIS, Inc.
                                                                                    April 30, 2013

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Monthly Technical Report - March 2013
American Cyanamid Superfund Site
Ira L. Whitman, P.E., PhD Technical Advisor
March  2013
          EPA’s monthly status update meeting with CRISIS, Inc. was held on March 18, 2013.  Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc.  One issue discussed that is of particular interest to CRISIS Inc. is the surface water quality sampling conducted quarterly by Pfizer.
          I was asked by CRISIS’ Chairman, Ross Stander to provide an explanation on the units of measurement commonly used to report the results of sampling for contaminants in soil, surface water and ground water at Superfund and other sites where remediation is conducted.
          It should be recognized that in most cases we are reporting very low concentrations of contaminants, and hence these concentrations are reported (but not in the actual laboratory data) in parts per million and parts per billion (Think of one blue ping pong ball in Madison Square Garden filled with white ping pong balls).
          1 part per million (ppm) is the equivalent of 0.00001% concentration of the contaminant, and 1 part per billion (ppb) would be 0.00000001%.
          By contrast, sea water contains approximately 3.5% salt, or 35,000 parts per million.
          However, the terms “parts per million and billion” are popular equivalents for the actual units used in laboratory reports of soil and water samples.
          Concentrations of contaminants in soil are reported on a weight per weight basis.
          for soil contaminants:
          1 part/million (1 ppm) = 1milligram/kilogram, 1 mg/kg
          1 part /billion (1 ppb) = 1 microgram/kilogram, 1 μg/kg
          Concentrations of contaminants in surface water and ground water are reported on a weight per volume basis, and therefore on a very high contaminant concentration there is not an exact 1 to 1 correspondence between parts per million/billion and the actual reported unit.  However, at the low concentrations typically encountered, the equivalence is close enough for all practical purposes.
          for water contaminants:
          1 part/million (1 ppm) = 1 milligram/liter, 1 mg/l
          1 part/billion (1 ppb) = 1 microgram/liter, 1 μg/l.
          For purposes of my reports to CRISIS I will report results in ppm or ppb, while the lab data provided to me are in mg/l or μg/l.
          The Raritan River borders the American Cyanamid Superfund site to the south, winding from southwest of the site for 3,600 feet until the junction with the Millstone River, and then southeast of the site for approximately 8,400 feet.  The river flows west to east in the area of the site.
          Cuckel’s Brook (also known as Cuckhold’s Brook) disects the site and empties into the Raritan River.  Until recently, the Somerset-Raritan Valley sewage treatment plant discharged into Cuckel’s Brook, but several months ago that discharge was moved and now it discharges directly into the Raritan, in the vicinity of Impoundment 18.
          Pfizer’s Ground Water Removal Action instituted to divert ground water discharging benzene into the Raritan River operates by intercepting ground water with a cutoff wall and trenches, collecting the flow and treating it at a temporary treatment plant, which discharges into the lower stretch of Cuckel’s Brook near Impoundment 2.
          Pfizer instituted quarterly sampling of sediment and surface water in the Raritan River and Cuckel’s Brook in August 2012.  In general, contaminants from the American Cyanamid site have not been detected in the river sediments.  However, benzene, one of the principal contaminants in Impoundments 1 & 2 has been present in surface water at some locations in Cuckel’s Brook and the Raritan River, as discussed below. (As well as a few other Volatile Organic Compounds, but benzene is used as the “marker” when evaluating contamination.)
          The sampling laboratory results for benzene and other Volatile Organic Compounds are reported by Pfizer’s consultants in micrograms per liter (μg/l) or parts per billion (ppb).  The NJDEP Surface Water Quality Standard (for human health) for benzene is 0.15 part per billion; whereas the NJDEP Ground Water Quality and Drinking Water Standard for benzene is 1.0 part per billion.  Thus, the quality of water in the river for benzene is expected to be better than is required for potable water.
          Cuckel’s Brook:
          There are 10 surface water sampling locations on Cuckel’s Brook.
          Samples taken in August and October 2012 were all acceptable; i.e., below the surface water quality standard for benzene.  However, in December 2012 the SRVSA discharge was removed from Cuckel’s Brook, resulting in a significantly lower volume of water flow thereby removing the dilution flow provided by the treated sewage.
          Samples taken in January 2013 exceeded the benzene surface water quality standard in Cuckel’s Brook at different locations, likely attributable to inflow into the Brook from Impoundments 1 & 2 as well as several upstream areas on the American Cyanamid site.  Benzene concentrations exceeded the 0.15 part per billion standards at the following locations.


          Raritan River – Below Cuckel’s Brook:
          There are 5 Raritan River sampling points below (downstream) where Cuckel’s Brook empties into the river.  Three of these points are adjacent to Impoundments 1 & 2, and the ground water seeps into the river from American Cyanamid discovered in 2011; RR – 05, RR – 04 and RR – 03.  The other two points are further downstream on the other side of Interstate I-287, below where Middle Brook empties into the Raritan.
          Benzene has been found at these sample locations since sampling began in 2012.


          The surface water quality data for this section of the Raritan River shows clearly that benzene concentrations are highest near Cuckel’s Brook and Impoundment 2, and decrease with distance in the downstream direction.
          Raritan River Above Cuckel’s Brook:
          There are 5 Raritan River sampling points above (upstream) where Cuckel’s Brook joins the Raritan, and there is one point on the Millstone River.  All of these points are adjacent to the American Cyanamid site, these sampling points are identified as RR – 06, RR – 07, RR – 08, RR – 09, RR – 10 and MS – 01.
          At all 6 locations, for each of the August, October and January sampling dates, benzene concentrations were found to be not detected above the reporting limit.
          Conclusions on Surface Water Quality:
          Volatile Organic Compounds from soil, ground water and impoundments at the American Cyanamid Superfund site are having no impact on the river upstream of Cuckel’s Brook and Impoundment 2.  However, in Cuckel’s Brook and in the Raritan River for 1,400 feet below Cuckel’s Brook benzene is present above the surface water quality standard of 0.15 parts per billion, likely from two (2) sources:
1.        Discharges from Pfizer’s treatment plant along Cuckel’s Brook treating ground water collected from the Impoundments 1 & 2 area
2.        Seepage of ground water directly into the Raritan River from the Impoundments 1 & 2 area.
          Pfizer believes that concentrations of benzene in surface water will decrease over time as its ground water interception structures divert more organic contaminants from direct seepage into the river, and as it designs, constructs and operates its site-wide ground water collection and treatment facilities, scheduled to begin in 2015.
          CRISIS, Inc. will be monitoring Raritan River surface water quality quarterly as data is received from Pfizer, and will periodically be reporting on the results in the Technical Advisor’s Monthly Technical Report.
          Impoundments 1 & 2 Focused Feasibility Study:
          Pfizer’s Focused Feasibility Study, Draft Laboratory Treatability Study Report for Impoundments 1 & 2 is presently under review by EPA’s office of Research and Development.  The results of the treatability study were presented by Pfizer and its consultant, CH2MHill at the CRISIS project update meeting on February 27.
          Pfizer presented EPA with its field test 30% design memo.  Pfizer will be constructing an elevated platform in the flood plain near Impoundment 2 for the placement of vapor treatment equipment for the field pilot study later this year.
          Impoundments 1 & 2 Ground Water Removal Action:
          Pfizer has modified its procedures for whole effluent toxicity testing of effluent from the ground water treatment system that went operational in May 2012, and is modifying its pH adjustment procedure from potassium to sodium hydroxide.  Ground water extraction and treatment are on-going.
          Concentrations of benzene have decreased in the river; however in the areas of the benzene seeps concentrations still exceed the 0.15 part per billion standard.  See Section 2.0 of this report for more detail on surface water quality.
          Site-Wide Remedy:
          USEPA and Wyeth Holdings Corporation (Pfizer) executed an Administrative Settlement Agreement and Order of Consent for Remedial Design, Operable Unit 4 (and Focused Feasibility Study, Operable Unit 8) on March 18.
          Geophysical studies were concluded that are expected to provide necessary data for locating future ground water extraction wells that will intercept ground water plumes within the most productive zones of fractured bedrock beneath the site to provide hydraulic control and contaminant mass removal.
          NJDEP had recommended a NJPDES Permit-By-Rule for a pilot ground water treatment system that will enable Pfizer to evaluate the most appropriate ground water treatment technologies for the future site-wide ground water treatment plant.
          Pfizer is preparing to conduct a Baseline Ground Water Monitoring Program in April.
          Ambient Air Monitoring Program:
          Reports for Fourth Quarter 2012 and First Quarter 2013 have been presented to USEPA, NJDEP and Bridgewater Township.  They are awaiting EPA approval.  Ambient air quality for these 2 quarters has been largely similar to the previous 2 quarters, except for an improvement in benzene levels  and a detection of hydrogen sulfide near Impoundment 2.
          Surface Water and Sediment Monitoring:
          First quarter surface water and sediment data were provided by Pfizer to EPA, and Pfizer received comments from EPA on its 2012 water and sediment monitoring report.
          NOTE:      See Sections 1.0 and 2.0  for more discussion on surface water quality in Cuckel’s Brook and the Raritan River.
          Ground Water Monitoring Program:
          Second half 2012 ground water monitoring data were presented to USEPA.
          Pfizer has given STS (Tires) access to its site near its boundary with STS for soil and ground water sampling on the Pfizer property.
          As EPA’s TAG grant recipient for the American Cyanamid Superfund Site, CRISIS conducted a public stakeholder’s meeting on February 27 at USEPA offices in Edison, New Jersey.  The presentations at the meeting were conducted by Pfizer and its contractor CH2MHill.  Sessions were presented on these subjects and issues:
·       Background and history of Impoundments 1 &2
·       On-going ground water removal action
·       On-going site sampling and monitoring
·       Impoundments 1 &2 Focused Feasibility Study process.
          CRISIS, Inc. moderated an extensive question and answer session following the presentation.  A separate report on this meeting will be posted on the CRISIS web site.
                                                                                    Ira L. Whitman, P.E., PhD
                                                                                    Technical Advisor to CRISIS, Inc.
                                                                                    April 11, 2013

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CHAIRMAN’s REPORT, March, 2013
From Ross Stander, Exec. Chairman

Note:  Please also see the latest Technical Report (Feb. 2013) from our Technical Adviser, Dr. Ira Whitman. [News Articles, Technical Reports, Memoranda and so on, are arranged in chronological order below]


1) The Record of Decision (ROD) for OU4 (Operable Unit 4 in official parlance) was issued by US-EPA in Sept. 2012.   The OU4 ROD covers much of the Cyanamid site including Impoundments 3, 4, 5 and 13, 17 & 24 plus contaminated site soils, groundwater and related wetlands. (But it excludes Impoundments 1&2, the most difficult areas to remediate.  This ROD provides the remediation plan for OU4 as was presented in the Site-wide Feasibility Study (SWFS) at the public hearings in March 2012.  CRISIS conditionally signed off on this EPA remediation plan subject to various important conditions that would strengthen the plan in our view.  These CRISIS conditions have to do with armoring the soil caps against erosion; moving certain principal threat-materials (PTWs) to a berm-protected location on-site (within which groundwater is pumped and then treated; and providing for more flood protection devices.  Our conditions can be found on this website dating to our official response letters to EPA of last Spring, 2012.

2) Treatability Studies for Imp. 1&2 (also called OU8):
For the worst impoundments (#1&2) on site, Pfizer hired the respected consulting firm CH2MHill to analyze the high concentration benzene and other VOCs therein (both tarry and crumbly textures as it turned out), evaluate alternative remedial solutions, and perform laboratory treatability studies for leading candidates.  These studies were reported to CRISIS and others initially on Nov. 14, 2012 in an EPA sponsored meeting in Bridgewater.  Our report to members on this meeting by Dr. Whitman, our TA, is on this website under the “Impoundment 1&2” tab.  

As of February 2013, no decision has yet been made on the remediation plan that Pfizer will submit to EPA for Imps. 1&2.  The next step in this process, which is part of EPA’s Focused Feasibility Study (FFS) process for Imps.1&2, not due out until mid-2014, is for Pfizer and consultants to do a scaled up pilot test of the leading remediation candidates during 2013.

These candidates involve both heating the tarry and crumbly impoundments (in place) to drive off (and then capture) the VOCs (volatile organic compounds like benzene); and, second, stabilizing and solidifying (in a binder cement) the VOCs.  It is possible (and probably better) that both be employed.  A big question is whether EPA will require the treated materials to then be removed from these impoundments which are both quite close the the Raritan River.  EPA and Pfizer want to see the technical results of the pilot tests before deciding.  CRISIS may take a preliminary position on this issue since the Raritan River will be faced with potential safety concerns, especially under flood conditions, if the treated and solidified material is left in place.  (See also item #4 below on the Feb. 27 Progress Report Meeting on Imp. 1&2 Study.)

3) Positive Data on Reduced Benzene Contamination in River:

It should be recalled from local media news (in 2011 and early 2012) that benzene and other organic contaminants were found to be seeping at high concentration from the ground near Imps.1&2, and entering the Raritan River through groundwater at very unacceptable concentrations of over 100 parts per billion (ppB) at nearby river locations.  First emergency response was carbon filtering bags (later removed). The medium-term plan of action adopted by Pfizer, approved by EPA, was three-fold: digging an interceptor trench from which the contaminated ground water could be pumped to a treatment facility; installing a dedicated groundwater treatment facility near Imps.1&2; and building a slurry wall (down to bedrock), essentially around these impoundments.  These were completed in Spring 2012.  (The dedicated groundwater plant is a modular one, so it was installed quickly.  A permanent treatment plant, something that CRISIS had pushed for some years, is in planning.)  Pfizer has spent over $10 million on these mitigation steps so far.

Results to date are clearly positive.  The old seeps themselves are not seen because of the slurry wall installation, but the groundwater continues to be contaminated.  The encouraging aspect is that measurement of benzene in the river at points quite close to impoundments 1&2 are now (January 2013 sampling) in the low part per billion range (roughly 1 ppB), where they were previously in the 200 ppB range before the groundwater-mitigation projects. However, this much improved, lowered concentration is still above the regulatory 0.15 ppB level. During 2013, the levels of benzene in the river are to be monitored to see if the situation improves further.  (Long-run, the answer will be the still to be determined remediation plan for Imps.1&2 discussed in item 2 above.)  CRISIS thinks further intermediate term action might be required if the downward trend in benzene is not sustained.

Up-river (westerly) from the Impoundment 1&2 location, where the water company intake is located, the January 2013 sampling data reported by Pfizer indicate no detectable level of benzene.  Also at sampling points roughly a half-mile down-river (easterly) from impoundments 1,2, the levels of benzene have been lower (roughly the 0.15 ppB regulatory limit) than in vicinity of Imps. 1&2.

A more detailed study of sampling data changes and causes is being made by our Technical Adviser, and will be discussed in his coming March 2013 TA’s Report.

4. Progress Update Meeting on Feb. 27. 2013:

CRISIS hosted, under EPA auspices at its location in Edison, a Progress Report Meeting (technically oriented) for primary stakeholders on Laboratory Treatability Studies for Impoundments 1&2.  Invited were environmental organizations, local government representatives, and local business representatives.  Pfizer and CH2Mhill were the main speakers.  A separate report on this meeting will be prepared for our website.  (Our Treasurer, John Tucciarone, computerized the mailing lists required to do invitations and reminders for the meeting, without which we could not have pulled it off.)


TAG Grant Renewal from EPA:  Renewal of our TAG (Technical Assistance Grant) was received effective Jan. 25, 2013 for $50,000 to run through Aug. 31, 2015.  Most of this money is dedicated to paying our TA for his work.  A small portion is budgeted for website development.  We are required to provide $12,500 of “in-kind” (non cash) member contributions over the course of this grant extension.

CRISIS hired Dr. Ira Whitman, P.E. (Ph.D. in Environmental Engineering from Johns Hopkins University) as our new technical adviser (TA) commencing on Nov. 12, 2012 (he was able to attend the Nov. 14 EPA meeting).  We also interviewed two other very qualified candidates and developed a quantitative scoring matrix, submitted to EPA, to support our hiring evaluations.  We continue (through our TA) to monitor reports and data about the site issued by Pfizer, EPA and DEP.

Our new website (www.crisistoxicwatch.org) went into action in Sept. 2012.  It was developed by Casey Kittel, a member, who continues to manage the site.

Our founding Exec. Director, Walt Sodie, is currently on leave of absence to allow him time to work on his other business activites.
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Monthly Technical Report by CRISIS TA
February 2013


Ira L. Whitman, P.E., PhD Technical Advisor

February 2013

    EPA’s monthly status update meeting with CRISIS, Inc. was held on February 11, 2013.  Ross Stander and Dr. Ira Whitman participated on behalf of CRISIS, Inc.

Impoundments 1 &2, Focused Feasibility Study

    Pfizer’s Focused Feasibility Study, Draft Laboratory Treatability Study Report for Impoundments 1 & 2 is presently under review by EPA’s office of Research and Development.  Comments from EPA are expected in March.  The results of the treatability study will be presented by Pfizer and its consultant, CH2MHill at the CRISIS project update meeting on February 27.

    Pfizer will be meeting on February 21 with NJDEP to review permit requirements for air emissions for the 2013 field pilot demonstration planned for September 2013.  The 30% design phase will be discussed by Pfizer with EPA on February 13.  On February 25 Pfizer will be giving EPA a preview of its February 27 presentation; CRISIS will attend.

Impoundments 1 & 2 Ground Water Removal Action

    Due to issues with toxicity testing, Pfizer has expanded its sampling activity for effluent from its modular ground water treatment plant.  EPA has approved, and NJDEP concurred with a Preliminary Corrective Action Plan for an investigation of the whole effluent toxicity testing procedure proposed.  Adjustments in ground water treatment have been made as a result of difficulties arising from freezing temperatures.

    Pfizer has presented EPA with a sampling plan for beneficial on-site reuse of soil displaced for construction of the removal system.

    Concentrations of benzene have decreased in the river; however in the areas of the benzene seeps concentrations still exceed the 1 part per billion standard.

Site-Wide Remedy

    Preliminary design plans are under discussion with EPA.  EPA conditionally approved a geophysics work plan designed to find the best locations for ground water capture wells.  A NPDES discharge permit application is presently being reviewed by NJDEP for a permanent future on-site ground water treatment system capable of treating all existing and future ground water (as distinguished from the new modular treatment facility near Impoundments 1 & 2 to treat VOC contaminated ground water before it is sent to SRVSA for final treatment).

Ambient Air Monitoring

    Third quarter perimeter air quality monitoring results have been presented to EPA showing no air quality concerns at present.  First quarter 2013 sampling took place on January 8, 2013.  Slightly elevated concentrations of benzene were detected in air quality measurements for Impoundment 2.  Pfizer will prepare an Ambient Air Quality fact sheet for use at CRISIS’ February 27 meeting.

Surface Water and Sediment Monitoring

    First quarter 2013 sampling took place during the week of January 7, 2013.  Additional sampling was conducted in the Cuckel’s Brook area made accessible by SRVSA’s rerouting of its discharge directly to the Raritan River.

Ground Water Monitoring Program

    Ground water monitoring was conducted during the week of November 26, 2012.  A draft report of sampling results will be submitted to EPA and NJDEP at the end of February.  Access will be given to consultants for a neighboring site, STS, to sample soil and ground water on the Pfizer property near their property boundaries.

Preparation for February 27 Meeting

    Ross Stander and Ira Whitman met with Pfizer and its consultants on February 1 to discuss the February 27 technical progress update meeting.  CRISIS presented a draft agenda for that meeting that was discussed in a conference call with EPA on February 7.  A consensus agenda will be finalized and distributed by CRISIS to conference attendees approximately 10 days before the February 27 meeting.

                Ira L. Whitman, P.E. PhD
                Technical Advisor to CRISIS, Inc.
                February 14, 2013

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December 11, 2012


     Pfizer reports that Hurricane Sandy, and the subsequent Nor’easter rainstorm, during late October and early November this fall, resulted in no flooding of the Cyanamid site.  Serious to massive flooding of the site has been (and will continue to be) a serious worry in terms of potential damage to impoundment liners and flood protection berms on the site, if that should result in release of nasty materials into the Raritan River or brooks.

     During Hurricane Sandy and the Nor’easter winds caused minor damage to Impoundment 8 temporary liners and these are now being repaired by Pfizer.

     Another concern has been the possibility of power interruptions from flooding or winds that could impact the continuous pumping of contaminated groundwater to the treatment facilities, both the on-site Modular Facility put up by Pfizer during 2012, and at SRVSA (which is contiguous with the site).  While pumping interruption did occur in the September 2011 Hurricane Irene event, such was not the case during this fall’s storm events.

     CRISIS has set, as an important part of its conditions for full support of the ROD issued by EPA in Sept. 2012 for a large portion of the site (but not including the toughest part, Impoundments 1 and 2 right near the river), that several measures be taken to preserve pumping ability and berms during flooding.  These measures have not yet been acted upon by EPA, but we believe they will be during the engineering design phase (of the issued ROD) to take place over the next two years.  CRISIS will continue to press this issue, and other conditions we specified (see our letters to EPA under the “Current News” tab on this website, which may move to “Archives” tab at some point).

(R. Stander, for CRISIS, 12/11/12)
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October 3, 2012

To: CRISIS Members and Interested Parties
From: Ross Stander, Exec. Chairman; Walt Sodie, Exec. Dir.
Summary of Recent Activity on American Cyanamid (Pfizer) Superfund Project and Within CRISIS

1. The CRISIS website is available to all for both recent news and ongoing information at:
The site was developed and established this summer by our member Casey Kittel. On it you can find for example the April 30, 2012 Supplemental Statement we sent to EPA during the public comment period (look under the Current News Tab). This was previously sent to most of you by email (June 28, 2012). This letter details the conditions set forth by CRISIS for our full support of the Remedy Alternative 4A of the EPA Proposed Plan for Sitewide Remediation, excluding Impoundments 1 & 2.
Also under Current News is the letter sent by BCOC (Bridgewater Cyanamid Oversight Comm.) which details what this panel would like to see added to the 4A Remedy.
2. ROD (Record of Decision) and Remedy:
The EPA issued the ROD for the site (excluding Impoundments 1 & 2) on September 28, 2012. Here is a direct link to the lengthy document:
Please see the attachment for our initial response to the ROD.
Following is background on some of our work related to the site remedy that is contained in the ROD.
In May 2012, Ross presented our position/Conditions for full support of 4A to the Bridgewater BCOC (Chaired by Bob Albano). I was helped in the presentation and discussion by John Tucciarone (Director, Treasurer) and Jim Crane (Member from Somerville). Pfizer and its consultants actively participated there, providing technical information and answering questions. For example, there was discussion of Pfizer’s promise to fortify soil caps of the proposed 4A Remedy against the serious/massive flooding that has already occurred on the site. Such soil caps were much criticized by other groups at the March Public Hearing. Fortification of the soil caps is part of our “conditions” on 4A, and we will be pressing the issue of how Pfizer proposes to implement this design when it is presented. As noted the BCOC letter to EPA is on our website, and it is fair to say CRISIS and BCOC take similar (but not identical) positions regarding conditions on 4A.
These conditions on 4A are real and meaningful. Another example (besides fortification of soil caps) is that Pfizer move all principal threat wastes (PTWs) that lie outside the main plant (MP) berm to within that berm (effectively , a large flood-protective wall). The current EPA/Pfizer proposed plan leaves some PTWs outside that berm. After solidification and stabilization, these PTWs would be placed under soil caps (hopefully fortified). While the whole Cyanamid site is subject to massive flooding, as in hurricane Irene in 2011, at least the area behind the MP berm undergoes groundwater pumping which can then be treated for contaminants. Other flood related protections are included in our Supplemental Letter to EPA as discussed above.
The BCOC letter to EPA states that BCOC fully supports the work of CRISIS particularly in providing technical information and analysis developed by our TA (Tech Adviser) and evaluated by our Board, Exec. Director, and active members.
3. TAG Renewal and TA Hire Needed:
Our TAG grant period ended on June 30, 2012. During June, we applied to US-EPA for renewal of the EPA TAG grant, hopefully for another 3 years. At this writing EPA has requested additional information, which we are providing. The TAG grant has paid for our TA (tech adviser) for the prior two-decade period. Tom Germinario was our TA over that entire period. Tom decided, entirely of his own volition, not to return to the project if we get the TAG renewal. We clearly thank Tom for his many years of valuable service including and especially his many suggested improvements that were accepted by EPA and/or NJ-DEP. One of the most significant was Tom’s push over years for dedicated groundwater pretreatment (to be able to fully handle benzene and other nasty organic contaminants in the groundwater). Fantastic: this has now been accepted by and the first stage implemented (up and running) for Impoundments 1, 2 by Pfizer. We wish Tom continued success.
We are now in process of seeking and hiring a new TA, under proviso that EPA renews the grant. Serious new technical work, requiring community oversight, is expected to begin later this month, such as the feasibility evaluations for treating the benzene and other nasty materials in Impoundments 1, 2. You can find our RFP request for TA applicants on our website under the Tech Adviser tab.
4. Impoundments 1, 2 Area Groundwater Treatment:
As noted, Pfizer has implemented its dedicated groundwater pretreatment system (a modular plant) at the Impoundment 1, 2 area of the site, which is reported to be fully functional.
5. Benzene Seepage into Raritan river:
The abatement plan (see June 28 Update) to stop the highly publicized (during 2011 and at the EPA Public Hearing of March 8, 2012) seepage of benzene has been implemented by Pfizer, under EPA’s order and supervision. It includes and interceptor trench around Impoundments 1, 2; the modular treatment plant; and pumps for the groundwater in the trench to be sent to the treatment plant. Indications are that it is doing the abatement job. We are awaiting word on test measurements. The TAG renewal (for the new TA) would be very helpful in our monitoring of these tests. (Carbon filter bags, originally placed for the benzene emergency, have been removed recently, as no longer needed.)
6. Impoundments 1, 2 Long Term Remedy (Focused Feasibility Study-FFS)
The current, interim abatement process for groundwater seepage from these two impoundments (the most dangerous and hardest to remedy on the site), will eventually be replaced by treatment and removal of these dangerous materials. The FFS for this long term remedy (see June 28, 2012 Update) is not due until mid-2014. This is a delay from the original schedule, which we are told will allow more complete evaluation of the treatability plans even at a field testing level. We are expecting to see some reports on these treatability lab studies, possibly later this month.
7. Air Monitoring from Impoundments 1, 2 were done July 18-20. CRISIS is waiting to see that data.

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September 2012

CRISIS Response to EPA Record of Decision (ROD), September 2012, for Former American Cyanamid Superfund Site, Bridgewater, New Jersey

The ROD does not satisfactorily respond to all of the points we outlined regarding measures to withstand flooding.  It did not directly address the following conditions from the 4/30/12 CRISIS written Supplement Statement (supplementing our testimony from the 3/8/12 EPA public meeting):

The Site-wide Feasibility Study indicates that the caps to be used in the Main Plant area (now called the North Area) will be multi-layered and engineered to withstand the stress of periodic flooding. That will be done during the Remedial Design phase, and CRISIS will monitor the process closely.  However, the Record of Decision should require that the highest attainable engineering standards be used in constructing the caps.  In this regard, cost should not be a consideration.  No matter how high the cost, Pfizer must be required to design, engineer and construct the caps for maximum resistance to floodwaters.
The caps and the berm should be heavily armored at points of highest water flow velocity, as experienced during Hurricane Irene.

Additionally, the ROD does not respond to this “General” concluding statement:

Because of the complexity of the Cyanamid site, the large-scale distribution of hazardous waste in the impoundments and soils, and the threat of frequent flooding, EPA must impose the most stringent possible standards for the current phase of the remediation and vigilantly monitor every step of the remediation process.  Furthermore, EPA should require Pfizer and/or its successors to monitor the site in perpetuity (under EPA supervision) and to make repairs that may be required to meet the conditions of all Records of Decision issued for site remediation.  This would include the flood berm, impoundments, groundwater pumping system, interceptor trench, slurry wall, treatment facilities, effluent gates, etc.  If EPA deems it appropriate to assure compliance, Pfizer could be required to post a bond to protect the community in case of financial changes in the company’s future or sale of Pfizer or the Cyanamid site to another firm.  As stated above, cost should not be a consideration in these decisions.

However, the ROD did address our other conditions, each of which is satisfactorily covered:  

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 the appropriate engineered multi-layered cap.
All principal threat wastes should be consolidated in Impoundments 3, 4 and 5 for in-situ s/s treatment.
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 in-situ s/s process.

We will continue to communicate with EPA and will strive to convince the agency to address the concerns noted above in the next round of the site remediation, which is the Remedial Design phase.
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August 28, 2012
DATE: August 28, 2012

TO: Meeting Attendees
FROM: Vince D’Aco
RE: American Cyanamid Superfund Site, Bridgewater, NJ
Minutes – Monthly Update with CRISIS
August 20, 2012 Conference Call
Mark Austin, USEPA Russ Downey, Pfizer Inc
Joseph Battipaglia, USEPA Elaine Richardson, Vita Nuova
Angela Carpenter, USEPA Vince D’Aco, Quantum Management Group
Melissa Dimas, USEPA
Walt Sodie, CRISIS
Chris Poulsen, Bridgewater Township
CC: Haiyesh Shah, NJDEP
Allan Motter, NJDEP
Michael Sivak, USEPA
The Agenda for this progress update is attached. The following bullets summarize the discussion and
action items from this meeting.
A. Impoundments 1 and 2 Focused Feasibility Study (FFS)
a. Russ indicated that a revised draft of the FFS Work Plan, responding to USEPA’s comments
of August 8, 2012, will be submitted to USEPA by August 27. Walt asked if USEPA
would distribute the Work Plan and Mark indicated that the final version would be distributed
after USEPA approval.
b. Russ provided an update on the laboratory treatability studies. The thermal treatment and
stabilization tests will be completed by August 24 and August 31, 2012, respectively. Preliminary
results have been positive, although there are technical challenges with both approaches.
c. Russ indicated that the draft laboratory treatability studies report will be available in October
2012. Mark said that Pfizer would present the results of the treatability work at a meeting
at the Site, possibly in October. He said that CRISIS and the Township will be invited
to this meeting. Russ asked whether CRISIS’ technical advisor would attend. Walt responded
that he hoped to have a technical advisor on board by that time.
B. Impoundments 1 and 2 Area Groundwater Removal Action
a. Russ indicated that the groundwater extraction trench and treatment system continues to
operate in compliance with the discharge permit equivalent.
- 2 -
b. Russ reported that a revised arsenic design modification will be submitted to USEPA today.
The system will be constructed in two phases – the infrastructure to support the ion
exchange units will be installed now and the ion exchange units will be installed in the future
if necessary, i.e. if arsenic concentrations in the groundwater increase.
c. Russ indicated that the carbon bags installed on the seeps in March 2011 are being removed
because the groundwater collection trench and hydraulic barrier wall are now in
place to prevent further seepage into the river. This work will be complete by August 24.
d. Vince indicated that installation of a utility casing under the railroad tracks has been put
on hold due to unexpected field conditions, including interferences from a New Jersey
American Water pipeline and several fiber optic lines. Options are being evaluated for
providing power via overhead power lines. This is not interfering with operation of the collection
trench and treatment system, which are powered from diesel generators.
C. Ambient Air Monitoring Program
a. Russ reported that the first sampling event was conducted on July 18-20, 2012 and that
analytical data is starting to arrive. The data is being tabulated and will be compared with
screening levels. The results will be shared with USEPA and NJDEP soon.
D. Surface Water & Sediment Monitoring Work Plan
a. Russ reported that the surface water and sediment monitoring work plan and QAPP were
approved by USEPA on August 10 and that the first round of sampling was conducted
during the week of August 13, 2012. Walt asked for an electronic copy of the work plan
and QAPP – Vince will provide this.
E. Groundwater Monitoring Program
a. Vince will send an electronic copy of the First Half 2012 Semi-Annual Groundwater Monitoring
Report to CRISIS.
F. Other Discussion
a. Walt indicated that CRISIS has developed a demo website and asked if anyone was interested
in seeing it. Melissa asked for the website link.
G. The next CRISIS progress update is scheduled for September 17, 2012 at 11:00 a.m. An agenda
will be distributed on the Thursday prior to the call.
Wyeth Holdings Corporation
American Cyanamid Superfund Site Remedial Program
Status Update Meeting with CRISIS
August 20, 2012 at 11 a.m.
Phone number: 877.580.3949; Access Code: 52451906
A. Impoundments 1 and 2 Focused Feasibility Study (FFS)
a. Revised Draft FFS Work Plan: USEPA comments provided 8-Aug-12
b. Lab Treatability Studies: Ongoing; Draft Report by Oct 2012
c. Technology Evaluation: Ongoing; Complementary to Lab Treatability Studies
d. Thermal/Solidification Bench-Scale Study Update
B. Impoundments 1 and 2 Area Groundwater Removal Action
a. Start-up of groundwater extraction and treatment system initiated 11-May-12
b. Arsenic treatability study: Ion Exchange modular unit to be installed for As treatment option
c. Jack & Bore for new utilities below railroads complicated by NJAW line and fiber optics – New
design underway and subsequent railroad approval will be required
d. Continued improvements underway for treatment system operation and maintenance
C. Ambient Air Monitoring Program
a. 2Q12 sampling event occurred 19/20-Jun-12
D. Surface Water & Sediment Monitoring Work Plan
a. Revised Work Plan and QAPP approved by USEPA on 26-Jul-12 and 10-Aug-12, respectively
b. 3Q12 sampling event occurred during week of 13 thru 17-Aug-12
E. Groundwater Monitoring Program
a. Semi-Annual GWMR submitted to USEPA/NJDEP on 1-Aug-12
Next Meeting: 17-Sept-12 (3rd Monday of month) at 11 a.m.
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June 28, 2012
Date: Thursday, June 28, 2012, 11:40 AM

TO: CRISIS Members & Interested Parties

FROM: Walt Sodie, Executive Director


Here is a summary of recent activity on the project.


1. Site Remedy:  USEPA is in the process of developing a Record of Decision (ROD) for the site, with the exception of Impoundments 1 & 2 (more on them below).  The decision will establish the remedy for this phase of project, which will be implemented over a period of several years.  The ROD is expected to be issued in the fall, possibly as early as September.  It will be based on the Sitewide Feasibility Study (FS) and the Proposed Remedial Action Plan (PRAP), which were the focus of the March 8, 2012 EPA public participation meeting that several of you attended, as well as further written comments that were submitted up to the end of the public comment period on May 15. To augment our March 8 testimony, CRISIS submitted a Supplement Statement to EPA on April 30 (distributed to most of you via e-mail update on May 3).  While no formal procedures exist for expressing our opinions on the remaining phases of the FS/PRAP/ROD process, CRISIS will continue to speak out, seek meetings with EPA and pursue whatever steps are available to us if we take exception to any of the decisions.


2. Groundwater:  One of our prime objectives during the 19+ years in which we have been working on the site has been an upgrade in the treatment of contaminated groundwater.  A positive step in that direction has occurred since the May 3rd update. Pfizer recently began treating some of the groundwater in its own, on-site interim treatment plant, which is operating under a Permit Equivalent issued by NJDEP.  The on-site facility was trigged by item #3 below, and the groundwater currently being treated by Pfizer is in connection with that program.  The treated water is being discharged into Cuckhold’s Brook, which flows into the Raritan River .  CRISIS will review monitoring reports from the two waterways when they become available in the near future.  Because the interim plant’s capacity is limited, the Somerset-Raritan Valley Sewerage Authority will continue to treat much of the site’s groundwater. However, if the current operation is successful, Pfizer will seek approval to build a permanent plant that could handle all site groundwater.


3. Impoundments 1 and 2 Area Groundwater Removal Action:  In late 2010, benzene-contaminated groundwater was discovered seeping into the Raritan River in the vicinity of Impoundments 1 and 2.  Pfizer entered into an Administrative Settlement Agreement with EPA to correct the problem.  The abatement plan included placement of carbon filters, building an interceptor trench and slurry wall, and installation of pumps to remove the groundwater for treatment.  Pfizer and EPA believe the steps have cut off the seepage into the river but CRISIS is awaiting the next round of river-water testing before we issue a statement.


4. Surface Water & Sediment Monitoring Work Plan:  Although CRISIS has asked for more frequent testing of Cuckhold’s Brook and the Raritan River , this pending workplan calls for quarterly monitoring.  However, EPA and DEP have not yet issued final approval of the plan and both have scheduled web conferences with Pfizer and its consultants to discuss agency concerns.  CRISIS will continue to monitor these developments.  If the next round of testing indicates any cause for concern, we will push for follow-up testing well before the scheduled three-month timetable.


5. Impoundments 1 and 2 Remedy:  Because these impoundments contain the heaviest concentrations of the most toxic contaminants on the site, they are being addressed via a separate Focused Feasibility Study (FFS).   While the full study is not expected to be ready until mid-2014, critical testing will be conducted during that time, including laboratory and field testing of in-place thermal treatment and solidification/stabilization of contaminants.  In earlier phases of the site remediation, testing was not conducted until after feasibility studies were issued.  Thus, while the target date for the FFS is later than we originally anticipated, the selection of a remedy should occur more quickly after its completion than was the case with the previous feasibility studies.  CRISIS will monitor each phase of the FFS process.


6. Flood Emergency Procedures Plan/Flood Management Response Plan:  EPA is currently reviewing these plans, which deal with operational response prior to, during, and following a flood.  CRISIS’s Supplement Statement to EPA (point #1 above) asked EPA to order measures to protect against future flooding as part of the site remedy, which is separate from the Flood Emergency Procedures Plan/Flood Management Response Plan.  While some of the site infrastructure was upgraded following Hurricane Irene, the height of the berms has not been increased to protect against a 500-year flood, as CRISIS requested.  EPA has declined to say whether that issue and the others we raised will be part of the site remedy but indicated that CRISIS’s comments will be addressed in the Responsiveness Summary that will be issued with the ROD.  We will be vigilant on these flood issues.


7. Non-Technical Activity:  With the Superfund project having moved back into high gear early this year, CRISIS has been expanding our membership and adding to our list of interested parties.  If any of you would like to become more active in what we are doing, please contact me at the e-mail address above or CRISIS Chairman Ross Stander at tensor_metrix@yahoo.com.  In addition to any other aspects of the project that may be of special interest to you, Ross is taking the lead on development of a CRISIS website and welcomes volunteers for help with that task.

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May 12, 2012

The following is a response letter sent by the Bridgewater Cyanamid Oversight Committee (BCOC), chaired by Robert Albano, to the EPA during the recent public comment period following the March 2012 public meeting regarding the site remediation. 


Robert E. Albano

1149 Papen Rd

Bridgewater NJ 08807

908 658 3387  bobalbano@yahoo.com

May 12, 2012





Joseph Battipaglia

Remedial Project Manager


290 Broadway, 19th Floor

New York, NY 10007-1866



Mr. Joseph Battipaglia

Re: written response on EPA Public Comment on American Cyanamid Superfund Feasibility Study


On behalf of the Bridgewater Cyanamid Oversight Committee, I wish to thank you for efforts you and your associates are making to remediate the site. Thanks for the presentation you gave the Committee in Dec 2011 and for the information you provided at the March public hearing.

This letter is the position and recommendation of the Bridgewater Cyanamid Oversight Committee.

Very Truly Yours,


Robert Albano

Chair- Bridgewater Cyanamid Oversight Committee




Att: 1


CC: Bridgewater Mayor and Township Council

        Russell Downey – Pfizer Project Manager

        Walt Sodie – CRISIS

        BCOC members




To: Mr. Joseph Battipaglia

Subject: written response on EPA Public Comment on American Cyanamid Superfund Feasibility Study

From: Robert Albano, Chairman – The Bridgewater Cyanamid Oversight Committee

Date: May 12, 2012



The Bridgewater Cyanamid Oversight Committee, BCOC, was formed with assistance of the Mayor and Township Council of Bridgewater in May 2011. The BCOC consists (1) of local residents of diverse backgrounds and interests.  Many members are long time residents and community leaders, some of whom were already familiar with the American Cyanamid site and situation.  The Committee was assembled to study the proposed alternatives and to evaluate the benefits and liabilities of each.  Its responsibility is to provide input to the EPA, DEP, Pfizer and the community on cleanup and future use of the property.


The Committee has met numerous times during the past year and has met with many people including EPA officials, Pfizer personnel and consultants,  CRISIS members, Bridgewater Township officials and local interested parties.  The Committee has studied background information, the alternative proposals for cleanup and visited the site on several occasions.  This letter expresses recommendation of the Bridgewater Cyanamid Oversight Steering Committee as a whole and not of any one member. This letter expressly indicates the Committee’s support for the proposed remedy with the additional conditions stated below.


The American Cyanamid Superfund site has been under review for almost 30 years.  Exhaustive study has been conducted during that time leading to the present EPA identification of the preferred alternative.  Pfizer, the current site owner, acquired the property in a corporate acquisition, never operated this site nor contributed to the existing conditions.  In all our contacts with Pfizer to date, they have accepted responsibility for implementing an effective remediation plan and returning the site to a safe and useful property. 


The Bridgewater Cyanamid Oversight Committee strongly supports the implementation of Alternative 4A.  This alternative provides a balanced approach offering several benefits.  It should make this site safe for residents of the surrounding area as well as for those living downstream from the site.  Alternative 4A uses proven conventional technologies that can be implemented in a reasonable period of time.  Since this alternative requires limited surface disturbance and soil relocation, it should minimize risks for residents during construction.  The proposed 4A plan is consistent with EPA’s RTU Initiative per the EPA Web site which encourages reuse of the property with a limited section having potential for commercial development and other areas available for active and passive recreation.  Alternative 4A may also reduce the impact of future floods. Plan 4A has the additional advantage of being a living document that will accommodate use of new technologies and approaches as these are discovered. The Plan also will begin the clean up in a more timely and effective manner than other Plans under discussion,


The BCOC is working closely with and fully supports the effort of CRISIS, a local citizens group, which has monitored the cleanup for nearly 18 years, to continue its work under and extension of  its TAG grant. CRISIS has and does serve as an information source and provides technical expertise on the site cleanup for the entire community and region. CRISIS has reviewed Proposal 4A. BCOC is primarily concerned with the future use consistent with safety of the community and surrounding areas. BCOC relies on CRISIS as a technical resource and BCOC supports the recommendations that CRISIS has put forward to improve Plan 4A. 


The BCOC suggests the following be added to Plan 4A

  1. Remove all PWT from the river banks to impounds behind the existing berm regardless of the risk assessments
  2. Maintenance of the existing berm toProvide for stabilization of VOC/SVOC with evidence of effectiveness through Simulation, Bench and Field testing prior to implementations
    1. control >100 yr storms by retaining excess flood waters
    2.  provide an added level of safety against accidental leakage or seep from the impounds

  3. Full treatment of ground and surface water on site with a specifically designed facility and not use SRVSA for water treatment
  4. Ensure that all impounds and impacted areas are stable in the 500 yr storm for leaching, scouring, erosion or uplifting.
  5. Protection of SRVSA and American Water from contamination from the site
  6. Redundant capability to ensure that power to operations is not compromised by adverse weather, flood, or power interruption, such as 2011 Storm Irene.
  7. Financial bonds for continuous operation, monitoring and maintenance of the site
  8. Separation of impounds 1 and 2 from FS4A for a separated feasibility study
  9.  Implement Plan 4A consistent with “Return to Use” principles that support the economic value of the site as commercial ratable status. The Committee recognizes that much of the site cannot be returned to commercial use but support identification of areas in the Northern end of the property for commercial development and the central portion of the property for recreation uses.


The BCOC believes that moving forward with Plan 4A represents the best approach to cleanup of the site that has been on hold for 10 years. We disagree with those who suggest that the plan be scrapped for more study. We agree with CRISIS, Bridgewater Township, Somerset County, Pfizer and EPA   assessments that Alternative 4A offers the best level of safety and timeliness.


Questions or comments may be addressed to:

Robert Albano

1149 Papen Rd

Bridgewater NJ 08807



1 Bridgewater Cyanamid Oversight Committee members




Alan Kurydla

Bridgewater Township Council President

Chris Poulsen

Bridgewater Health Director and Liaison to Bridgewater Township

Gene Yuliano

MD and Member Bridgewater Health Bd

George Schofield

Business owner- across from site, Rescue Squad member, Long time resident

Jim Anderson

Bridgewater resident

Jim Rokosny

Chairman Bridgewater Environmental Commission

John Schmitt

Chairman Bridgewater Economic Development Committee

Joseph Lefreiri

Commissioner, SRVSA

Michelle Lawrence

Member Bridgewater Recreation Board

Nitin Apte

Environmental Consultant and resident

Robert Albano

Chairman and former Bridgewater Township Council member, current Planning Bd member

Ross Stander

Chairman - CRISIS

Susan Dorward

Bridgewater Sustainability Task Force




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April 30, 2012



                                                                                  925 Brown Rd.   Bridgewater, NJ 08807


April 30, 2012                                                            (Sent via e-mail this date)



Joseph Battipaglia

Remedial Project Manager

USEPA Region 2



Dear Mr. Battipaglia:


We are submitting this communication in follow-up to statements we entered into the record at the March 8, 2012 EPA-conducted public hearing on remediation plans for the American Cyanamid (Pfizer) Superfund site.  The points that follow supplement oral statements that were given by CRISIS Technical Advisor Thomas Germinario, CRISIS Board Chairman Ross Stander and myself, and Mr. Germinario’s letter of March 6, 2012 to you (“Re: Site-Wide Feasibility Study and Proposed Remedial Action Plan, American Cyanamid Superfund Site”).  Some of the material reiterates sections of our March 8 presentations that require more emphasis. 


CRISIS recognizes that EPA is cognizant of some of the points to be made below and that EPA may have already planned to implement some of the suggestions.  They are included not only for EPA’s consumption but also for review by other interested parties.


While CRISIS does not object to EPA’s preferred remedy of solidification/stabilization (S/S), we strongly believe that the plan should be bolstered by implementation of the measures that follow.



Conditions for Implementing Solidification/Stabilization (S/S) Remedy


CRISIS wishes to stress the importance we place on the five bulleted points on page 3 of Mr. Germinario’s letter referred to above.  These proposed steps, repeated immediately below, not only are conditions for our support of EPA’s preferred remedy but are actions we believe are essential for inclusion in the Record of Decision:


  • 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 the appropriate engineered multi-layered cap.
  • All principal threat wastes should be consolidated in Impoundments 3, 4 and 5 for in-situ s/s treatment.
  • 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 in-situ s/s process.
    • The caps and the berm should be heavily armored at points of highest water flow velocity, as experienced during Hurricane Irene.
      • LTTD is a poor choice for a heterogeneous mix of volatile and semi-volatile organic compounds (VOCs & SVOCs).  LTTD uses heat to vaporize the organic contaminants so that they are driven off the waste and captured for treatment. Therefore, LTTD has to operate in the temperature range between the boiling point and the combustion temperature of the organic compound.  Since SVOCs have a much higher boiling point than VOCs, completely vaporizing a mix of VOCs and SVOCs would require a higher temperature than would be safe to use, because it would be too close to the flashpoint of the VOCs.

Our conditions for groundwater treatment are crucial.  The impoundments to be treated with S/S are located in the Main Plant Area where the groundwater flow is controlled by the bedrock pumping wells. Therefore, any leaching of organics will be drawn down into the groundwater recovery system and sent for treatment.  Currently, this treatment is being done at the SRVSA, with which CRISIS is not satisfied. (We have repeatedly asked for an engineering analysis of SRVSA’s capabilities to treat VOC/SVOC wastes and never gotten any response.  The typical municipal-type sewage treatment plant is not equipped to remove these wastes without some degree of pre-treatment.)  If CRISIS is successful in getting Pfizer to design and build a state-of-the-art, on-site dedicated groundwater treatment plant, the site will then have a much stronger system that will protect the environment, even if some leaching of organics occurs from the S/S impoundments.

The condition calling for bench-scale testing (done in a simulated environment) is also critical; its implementation would assure that the best possible S/S technology will be used.  Here is more detail on bench-testing techniques CRISIS is asking EPA to order:


We favor re-remediation testing of various types of S/S treatment to determine the optimal method of immobilizing the unique mix of organic contaminants at this site. There are leaching procedure test methods that have been approved by USEPA for simulating how the S/S treated material will perform in its intended disposal site. These leaching procedures can accurately predict the rate at which organic compounds will leach under the influence of simulated rain and groundwater.



Flooding and the Danger of Cap Erosion


A few speakers at the March 8 EPA public hearing cited frequent flooding as an argument against S/S, contending that floodwaters will wash away caps covering the waste impoundments and release hazardous waste into the water.


While the entire Cyanamid site is in the Raritan River’s floodplain, there is a substantial difference between the risks associated with wastes stored inside and outside the Main Plant area. As discussed above, the groundwater in the Main Plant area is controlled by the bedrock pumping system and can be treated if contaminants escape as a result of flooding. Also, the Main Plant is surrounded by a flood dike which slows the rate at which flood waters enter and recede from that area. Therefore, the risk of contaminants being washed away by the uncontrolled force of floodwaters is much less within the Main Plant area than outside it.  Nevertheless, the threat demands that EPA impose rigorous conditions to mitigate flood damage


The Site-wide Feasibility Study indicates that the caps to be used in the Main Plant area will be multi-layered and engineered to withstand the stress of periodic flooding. That will be done during the Remedial Design phase, and CRISIS will monitor the process closely.   However, the Record of Decision should require that the highest attainable engineering standards be used in constructing the caps.  In this regard, cost should not be a consideration.  No matter how high the cost, Pfizer must be required to design, engineer and construct the caps for maximum resistance to floodwaters.
Additionally, we request that the following conditions be included in the Record of Decision:


  • The impoundments must be much better protected than in recent extreme flooding.  Specifically, the berm around the main plant area must be improved to withstand a “500-year” flood, a magnitude that has been reached or approached several times at the site.  The improvement should be both in height and strength of the berm. 


  • The Remedial Design must specify a means to firmly secure the S/S material under the soil caps to prevent contaminants from being washed out in serious, repeated floods.



  • The ground water pumping system must be protected against electricity failure in storms, including maintenance of large backup generators on high ground, and allowing for proper water runoff into the outflow brook.



Low Temperature Thermal Desorption Inappropriate for Cyanamid Site


A small number of environmental groups with no previous involvement at the site called for LTTD to be used for the most severely contaminated sections: impoundments 3, 4 and 5. 


LTTD involves in-place thermal treatment that causes contaminants to separate (desorb) from the soil without burning.  CRISIS’s extensive review of engineering and environmental reports and studies indicates that the process is not a suitable remedy for impoundments 3, 4 and 5. 


CRISIS has been studying and responding to actual and potential remedies for this highly contaminated site for over 20 years and has substantial knowledge of the waste characteristics and past attempts to treat a wide range of deadly substances there.  To document our position that LTTD is not the appropriate remedy for these impoundments, CRISIS developed the following points from our review of engineering and environmental reports and studies*:



  • Just one example: The Sidney Tar Sands site in Nova Scotia, Canada called for remediation of a number of tar ponds having a heterogeneous mix of VOCs and SVOCs, including Benzene, Xylenes, Toluene and Naphthalene, which are also the principal organic contaminants of Cyanamid’s Impoundments 3, 4 and 5.  After extensive studies, the selected remedy (2007) was solidification/stabilization (S/S) technology, not LTTD.


  • 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.





Because of the complexity of the Cyanamid site, the large-scale distribution of hazardous waste in the impoundments and soils, and the threat of frequent flooding, EPA must impose the most stringent possible standards for the current phase of the remediation and vigilantly monitor every step of the remediation process.  Furthermore, EPA should require Pfizer and/or its successors to monitor the site in perpetuity (under EPA supervision) and to make repairs that may be required to meet the conditions of all Records of Decision issued for site remediation.  This would include the flood berm, impoundments, groundwater pumping system, interceptor trench, slurry wall, treatment facilities, effluent gates, etc.  If EPA deems it appropriate to assure compliance, Pfizer could be required to post a bond to protect the community in case of financial changes in the company’s future or sale of Pfizer or the Cyanamid site to another firm.  As stated above, cost should not be a consideration in these decisions.


Thank you for your consideration of this communication.


Walt Sodie

Executive Director





* Following is a list of references for our position that S/S technology is more appropriate than LTTD for impoundments 3, 4 & 5. While not every one of the sources provided the explicit information contained in the three bullet points regarding LTTD, they indicate the difficulties of applying LTTD to mixed wastes. Some of the sources were not directly researched by CRISIS but were cited by reference material that was examined.



http://en.wikipedia.org/wiki/Sydney_Tar Ponds.




Applying Solidification/Stabilization for Sustainable Redevelopment of Contaminated Property - (Charles M. Wilk LEHP, QEP, LEED AP, Program Manager, Waste Treatment, Portland Cement Association.


Conner, J.R. Chemical Fixation and Solidification of Hazardous Wastes; Van Nostrand, Reinhold: New York.


Technology Resource Document—Solidification/Stabilization and Its Application to Waste Materials; EPA 530/R-93/012; U.S. Environmental Protection Agency.


Innovative Treatment Technologies for Site Cleanup: Annual Status Report, 12th Edition; EPA 542-R-07-012; U.S. Environmental Protection Agency.


Engineering Bulletin—Solidification/Stabilization of Organics and Inorganics; EPA 540/S-92/015; U.S. Environmental Protection Agency.


Weitzman, L.; Conner, J.R. Descriptions of Solidification/Stabilization Technologies. In Immobilization Technology Seminar—Speaker Slide Copies and Supporting Information; CERI-89-222; U.S. Environmental Protection Agency.


Conner, J.R. Guide to Improving the Effectiveness of Cement-Based Stabilization/Solidification; EB211; Portland Cement Association: Skokie, IL.


Pozzolan—a siliceous or siliceous and aluminous material which in itself possess little or no cementitious value, but which will, in finely divided form and in the presence of moisture, chemically react with calcium hydroxide at ordinary temperature to form compounds  possessing cementitious properties. Standard Terminology Relating to Hydraulic Cement, ASTM C 219-98.


Stabilization/Solidification of CERCLA and RCRA Wastes—Physical Tests, Chemical Testing Procedures, Technology Screening, and Field Activities; EPA 625/6-89/022; U.S. Environmental Protection Agency.


Einhaus, R.L.; Erickson, P. Fate of Polychlorinated Biphenyls (PCBs) in Soil Following Stabilization with Quicklime; EPA 600/2-91/052; U.S. Environmental Protection Agency.


Guide Specification for Military Construction—Solidification/Stabilization of Contaminated Material; CEGS-02445; U.S. Army Corps of Engineers.


Delisio, R. Cement-Based Solidification/Stabilization on Brownfield Sites in New Jersey, USA Presented at the Cement Association of Canada, Remediation Technology Workshop: Solidification and Stabilization Treatment, Toronto, Ontario, Canada, (unpublished).


Wilk, C.M.; DeLisio, R. Solidification/Stabilization Treatment of Arsenic- and Creosote-Impacted Soil at a Former Wood-Treating Site; SR99.


Wilk, C.M.; Germano, M. Remediation of Lead- and Petroleum-Contaminated Soils at a Boston Brownfield Site Using Cement-Based Solidification/Stabilization. In Proceedings of the International Containment & Remediation Technology Conference, Orlando, FL.



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