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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.