UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 2



## JAN 27 2011
DATE:

SUBJECT: 

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pons National Priorities List Nomi tion ofthe Garfield Ground Water Contamination Site in Garfield, NJ 

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- FROM: Walter Mugdan, Director Emergency and Remedial e Division

TO: Betsy Sutherland, Director Office ofAssessment and Remediation Division

This memorandum is a request for placement ofthe Garfield Ground Water Contamination Site, Garfield, NewJerseyon the National Priorities List (NPL) underthe provisions in Section 300,425 (c) (3) ofthe National Contingency Plan (NCP). Attached
are thefollowing documents which supportthis action:

1. The Public Health Advisory forthe Garfield Ground Water Contamination Site prepared bythe AgencyforToxic Substances and Disease Registry (ATSDR) (Attachment 1);

2. A letterfrom the Centersfor Disease Control (CDC), concurring in the dissociation ofresidentsfrom the area ofground water contamination (Attachment 2);

3. A cost analysis ofpotential remedial and removal response actions at the site which demonstratethat it will be more cost effective to use remedial ratherthan removal authorityto respond to the release (Attachment 3);

4. Memo from EPA documenting ourdetermination ofsignificant threat (Attachment 4);

5. A letterfrom the State of NewJersey requesting placement ofthis site on the NPL (Attachment 5).

Background

The Garfield Ground Water Contamination Site (GGCS) (a.k.a, E.C. Electroplating, Garfield Chromium Ground Water Contamination Site) consists ofan area ofground water contamination located within a mixed commercial and residential area in the Town ofGarfield, NewJersey. Currently, the site is bordered by Van Winkle Avenue to the north, Monroe Streetto the south, Sherman Place to the east, and the Passaic Riverto the west. To date, several investigation efforts have focused on chromium contamination in ground water. However, the nature and extent ofcontaminants atthe GGCS will be further investigated during the remedial·investigation. At this time, this
area is known as the Area ofConcern (AOC).

At the turn ofthe 20th century, the city ofGarfield had a vibrant economy based on the textile, chemical, paper manufacturing industries, and other smaller industries, including,electroplating. Possible sources ofcontamination atthe site include two former electroplating facilities and a former tannery.

Several investigations conducted atthe former E.C. Electroplating facility indicate there is chromium contamination in soils and ground water. In December 1983, approximately 3,600 gallons ofchromium plating solution was discharged from a partially below ground storage tank. The former operator initiated spill recovery actions underthe oversight of the NewJersey Department of Environmental Protection (NJDEP). In June 1993, chromium contaminated ground water and crystals were discovered in the nearbyfire house, Garfield Fire House #3, which was subsequently taken out ofservice. As a result, in November 6 1993, E.C. Electroplating entered into a Memorandum of Agreement with the NJDEP to comply with regulatory investigation requirements including full delineation ofthe chromium contaminated ground water plume. Between November 1994through April 2000 four ground water monitoring wells were installed at the facility. As ofApril 2000, ground water samples indicated maximum concentrations of hexavalent chromium at 1,490,000 micrograms per liter (pg/L), atone on-site monitoring well.

In 2000, the NJDEP investigated several residential properties for the presence of chromium contamination in buildings. The NJDEP collected water samples and residue solidsfrom basement sumps which indicated the presence oftotal chromium and/or hexavalent chromium in several buildings.

In October2002, the NJDEP requested that EPA evaluate the presence ofchromium precipitate in residential/commercial buildingswithin the currently known AOC. In response, the EPA removal program has conducted inspections, testing, and cleanup activities in buildings to address hexavalent chromium in residential and commercial buildings potentially presenting an increased exposure to residents and workers. As of this date, EPA has addressed chromium contamination in twelve buildings that exceed the Removal Action Level (RAL) for hexavalent chromium. In addition, EPA has conducted a preliminary ground water investigation within the GGCS. Sampling results indicate concentrations of hexavalent chromium up to 36,200 pg/L in ground water within the AOC.

In September2010, ATSDR issued a health advisory recommending residents to avoid anytime in their basements due to the presence of hexavalent chromium levels that may present a significant health threat. In their report, ATSDR concluded that children and adults accessing basements in the AOC were, are, and will continue to be exposed to hexavalent,chromium at levels that may pose an immediate and significant threat to their health. ATSDR recommended that EPA take short- and long- term measures to dissociate persons from either residential or commercial properties, who live, work, or both, in the contaminant plume area. In addition, ATSDR recommended that EPAtake the necessary actionsto permanently remove the source(s) of hexavalent chromium contamination to the GGCS. ATSDRanticipates thatwithout addressing the contamination in ground water and the source(s) contributing to the contamination, all residents within the contaminant plume may continue to be exposed to hexavalent chromium at levels that present an immediate and significantthreatto their health.SignificantThreat to Public Health

The memo documenting the Agency's determination ofsignificant threat can be found in Attachment 4. EPA's determination ofsignificant threat is based on sampling performed bythe removal program in the AOC. Based on sampling results, EPA determined that removal actionswere necessaryto mitigate unacceptable risks to residents and workers in 13 buildings. The removal response was initiated based on the exceedence ofthe site-specific RAL. Exceeding the RAL suggests that actual or potential exposure to concentrations ofcontaminants in buildings presents an unacceptable risk to occupants. To date, 13 properties have had infiltration ofground water with subsequent hexavalent chromium residue exceeding the RAL. These properties are eligible for a removal action and those efforts are ongoing 1.

It is importantto note that the concentrations of hexavalent chromium used in the evaluation ofcontaminant levels in buildings, and the potential need for a removal action, represent a discreet moment in time. Based on previous experience of recontamination events in buildings within the GGCS, specificallythe Golden Towers building, EPA believes that there is the potential for recontamination and new contamination events dueto continued seepage ofcontaminated ground water. These contamination events have the potential to become more pronounced orfrequent due to wet weather conditions such as heavy rains that cause flooding. Based on a ground water investigation conducted by the removal program, maximum hexavalent chromium concentrations greaterthan 36,000 ug/L within the AOC indicatethe existence of significant contamination in ground water. Therefore, actual and threatened releases of hazardous substances atthe GGCS continue to present a significant threat to public health and welfare.

In April 2010, the NewJersey Department of Health and Senior Services (NJDHSS) and the ATSDR issued a health consultation which assessed the potential hexavalent chromium exposures to area residents based on previous sampling investigations conducted by EPA in residential/commercial properties. Both agenCies concluded that there is evidence ofa complete exposure pathwayfor ingestion ofand dermal contact with surfacedust containing hexavalent chromium. Both agencies also concluded that past, present and future exposures represent a public health hazard via the ingestion of hexavalent chromium dust in some basements.

Cost Effectiveness

The remediation ofthe GGCS would be more appropriate and more cost effective if conducted under remedial authority ratherthan under removal authority.

Removal actions are designed to stabilize or clean up releases of hazardous substances that pose a threat to human health orthe environment. See 42 USC §9601(23). In contrast, remedial actions are those actions consistent with a permanent remedy taken instead ofor in addition to removal actions. See 42 USC§9601(24). As set out below, EPA believes it is more appropriate to use its remedial authoritiesto address the significantthreat to public health posed by releases from the GGCS.

I As ofto date, the removal programhas conductedresponse activities in 12 ofthe 13 properties with hexavalent chromiumdetectionsabovetheRemoval Action Level. Onepropertyowner declinedEPA'srequest for access and
consenttoconductcleanup activities attheirbuilding.As indicated in the Cost Estimate for Remedial and Removal Actions report (attachment 3), the removal action alternative consists ofa series ofactions intended to identify, mitigate, and monitor continued hexavalent chromium exposuresto residents and workers within GGCS. This includes the initial cleaning ofthe affected properties and the installation ofwater infiltration controlsto address hexavalent chromium seepage into buildings within the ground water contamination area. Continuous monitoring of buildings within the area ofground water contamination is necessary as long as ground water contamination remains to ensure that no additional contamination events occur that would present a human health hazard. In the eventthat additional contamination of buildings occurs, EPAwould conduct additional cleanup actions, as necessary. The removal action alternative presents only a temporary solution to address contamination in buildings within the GGCS and does not address the treatment ofchromium contamination in ground water.

In orderto ensure permanent protection ofhuman health and the environment, EPA anticipates that itwill need to abate the hexavalent chromium contamination atthe site. To accomplish this, EPA needs to reduce the mass ofchromium contamination in ground water. Although the removal action alternative will temporarily mitigate the threat to human health posed by contamination in buildings, a significantthreat still exists. The potential for additional contaminated ground water seeps into buildings will continue to threaten the health of residents and workers within the area ofground water contamination.

The remedial approach provides an alternative thatwill reduce the mass of hexavalent chromium in ground water and eliminate the human health threat posed bythe presence chromium contamination within the GGCS. EPA anticipates that a remedial alternative consisting ofzero valent iron permeable reactive barriers (PRB) coupled with continuous monitoring and cleanups, as necessary until the chromium contamination is abated, will provide more comprehensive protection ofhuman health and the environment. In addition, the remedial alternative presents an approach that has been proven to effectively reduce the toxicity and volume ofchromium contamination in ground water. EPA has used PRB to treat metals and organic contaminants in ground water at other sites. An example ofthis isthe Frontier Hard Chrome Superfund site in Vancouver, WA. In that case, hexavalent chromium contamination in ground water has been treated successfully by using PRB to reduce the volume of hexavalent chromium in ground waterto non-detectvalues afterthe flow ofcontaminants pass thru the reactive barrier.

Based on the discussion above, Region 2 believes the remediation ofthe GGCS would be more appropriate and cost effective underthe remedial authority ratherthan the removal authority. The remedial option represents a permanent solution which, in the long term, will be more cost effective and provide more comprehensive protection of human health and the environmentthan the removal option?

2 EPA'sdetenninationisalsoinfonnedbyits guidance document, entitled Use of Non-Time CriticalRemoval AuthorityinSuperfundResponseActions, datedFebruary 14, 2000, whichrecommends theuse ofremedial authority
atcomplex and costlysites to effectuate a comprehensiveresponse.Recommendation



# . Since the Garfield Ground Water Contamination site meets the NPL listing criteria of Section 300.425 (c)(3) ofthe NCP, Region 2 recommends listing the site on the NPL. The ATSDR has recommended dissociation of individualsfrom the release atthe site. Region 2 and ATSDR concurthat the release poses a significant threatto the public health, and Region 2 anticipates that it will be more cost effectiveto usethe Remedial Authority ofCERCLAthan Removal Authorityto address the release atthis site.

Attachments