Reports and Memos

MARCH-APRIL 2015 TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS, Inc.

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.

Ecological

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

OCTOBER-NOVEMBER TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS, Inc.

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

SEPTEMBER TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS, Inc.

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 4^th 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

AUGUST TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS, Inc.

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 24^th 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 19^th, 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.

1.0       GROUND WATER AT AMERICAN CYANAMID SITE

          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).

2.0       GROUND WATER REMEDIATION

          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.”

3.0        RARITAN RIVER SEEPS

         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.

          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.

4.0        CUCKEL’S BROOK SEEPS

         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

MONTHLY TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS, Inc.

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

MONTHLY TECHNICAL REPORT

AMERICAN CYANAMID SUPERFUND SITE

CRISIS Inc.

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.

*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)

          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

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 3^rd 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.