UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 

REGION 2
 

JAN 27	 2011 

DATE: 

SUBJECT:	 

/

pons

National Priorities List Nomi tion of the Garfield Ground Water Contamination 

Site in Garfield, NJ 

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

TO:	 Betsy Sutherland, Director
 

Office of Assessment and Remediation Division
 

This memorandum is a request for placement of the Garfield Ground Water 

Contamination Site, Garfield, New Jersey on the National Priorities List (NPL) under the 

provisions in Section 300,425 (c) (3) of the National Contingency Plan (NCP). Attached 

are the following documents which support this action: 

1.	 The Public Health Advisory for the Garfield Ground Water Contamination Site 

prepared by the Agency for Toxic Substances and Disease Registry (ATSDR) 

(Attachment 1); 

2.	 A letter from the Centers for Disease Control (CDC), concurring in the
 

dissociation of residents from the area of ground water contamination
 

(Attachment 2);
 

3.	 A cost analysis of potential remedial and removal response actions at the site 

which demonstrate that it will be more cost effective to use remedial rather than 

removal authority to respond to the release (Attachment 3); 

4.	 Memo from EPA documenting our determination of significant threat (Attachment 

4); 

5.	 A letter from the State of New Jersey requesting placement of this 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 of an area of ground 

water contamination located within a mixed commercial and residential area in the Town 

of Garfield, New Jersey. Currently, the site is bordered by Van Winkle Avenue to the 

north, Monroe Street to the south, Sherman Place to the east, and the Passaic River to 

the west. To date, several investigation efforts have focused on chromium 

contamination in ground water. However, the nature and extent of contaminants at the 

GGCS will be further investigated during the remedial· investigation. At this time, this 

area is known as the Area of Concern (AOC). 

At the turn of the 20th century, the city of Garfield had a vibrant economy based on the 

textile, chemical, paper manufacturing industries, and other smaller industries, including, 
electroplating. Possible sources of contamination at the site include two former 

electroplating facilities and a former tannery. 

Several investigations conducted at the former E.C. Electroplating facility indicate there 

is chromium contamination in soils and ground water. In December 1983, approximately 

3,600 gallons of chromium plating solution was discharged from a partially below ground 

storage tank. The former operator initiated spill recovery actions under the oversight of 

the New Jersey Department of Environmental Protection (NJDEP). In June 1993, 

chromium contaminated ground water and crystals were discovered in the nearby fire 

house, Garfield Fire House #3, which was subsequently taken out of service. 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 of the chromium contaminated ground water plume. Between 

November 1994 through April 2000 four ground water monitoring wells were installed at 

the facility. As of April 2000, ground water samples indicated maximum concentrations 

of hexavalent chromium at 1,490,000 micrograms per liter (pg/L), at one 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 

solids from basement sumps which indicated the presence of total chromium and/or 

hexavalent chromium in several buildings. 

In October 2002, the NJDEP requested that EPA evaluate the presence of chromium 

precipitate in residential/commercial buildings within 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 September 2010, ATSDR issued a health advisory recommending residents to avoid 

any time 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 EPA take 

the necessary actions to permanently remove the source(s) of hexavalent chromium 

contamination to the GGCS. ATSDRanticipates that without 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 significant threat to their health. 
Significant Threat to Public Health 

The memo documenting the Agency's determination of significant threat can be found in 

Attachment 4. EPA's determination of significant threat is based on sampling performed 

by the removal program in the AOC. Based on sampling results, EPA determined that 

removal actions were necessary to mitigate unacceptable risks to residents and workers 

in 13 buildings. The removal response was initiated based on the exceedence of the 

site-specific RAL. Exceeding the RAL suggests that actual or potential exposure to 

concentrations of contaminants in buildings presents an unacceptable risk to occupants. 

To date, 13 properties have had infiltration of ground water with subsequent hexavalent 

chromium residue exceeding the RAL. These properties are eligible for a removal 

action and those efforts are ongoing1. 

It is important to note that the concentrations of hexavalent chromium used in the 

evaluation of contaminant 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, specifically the Golden Towers 

building, EPA believes that there is the potential for recontamination and new 

contamination events due to continued seepage of contaminated ground water. These 

contamination events have the potential to become more pronounced or frequent 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 greater than 36,000 ug/L within the AOC indicate the existence of 

significant contamination in ground water. Therefore, actual and threatened releases of 

hazardous substances at the GGCS continue to present a significant threat to public 

health and welfare. 

In April 2010, the New Jersey 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 of a complete exposure pathway for ingestion of and dermal contact 

with surface dust 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 of the GGCS would be more appropriate and more cost effective if 

conducted under remedial authority rather than under removal authority. 

Removal actions are designed to stabilize or clean up releases of hazardous 

substances that pose a threat to human health or the environment. See 42 USC 

§9601 (23). In contrast, remedial actions are those actions consistent with a permanent 

remedy taken instead of or in addition to removal actions. See 42 USC §9601(24). As 

set out below, EPA believes it is more appropriate to use its remedial authorities to 

address the significant threat to public health posed by releases from the GGCS. 

I As ofto date, the removal program has conducted response activities in 12 ofthe 13 properties with hexavalent 

chromium detections above the Removal Action Level. One property owner declined EPA's request for access and 

consent to conduct cleanup activities at their building. 
As indicated in the Cost Estimate for Remedial and Removal Actions report (attachment 

3), the removal action alternative consists of a series of actions intended to identify, 

mitigate, and monitor continued hexavalent chromium exposures to residents and 

workers within GGCS. This includes the initial cleaning of the affected properties and the 

installation of water infiltration controls to address hexavalent chromium seepage into 

buildings within the ground water contamination area. Continuous monitoring of 

buildings within the area of ground 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 event that additional contamination of 

buildings occurs, EPA would 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 of chromium 

contamination in ground water. 

In order to ensure permanent protection of human health and the environment, EPA 

anticipates that it will need to abate the hexavalent chromium contamination at the site. 

To accomplish this, EPA needs to reduce the mass of chromium contamination in 

ground water. Although the removal action alternative will temporarily mitigate the threat 

to human health posed by contamination in buildings, a significant threat 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 of ground water 

contamination. 

The remedial approach provides an alternative that will reduce the mass of hexavalent 

chromium in ground water and eliminate the human health threat posed by the presence 

chromium contamination within the GGCS. EPA anticipates that a remedial alternative 

consisting of zero 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 of human health and the environment. In 

addition, the remedial alternative presents an approach that has been proven to 

effectively reduce the toxicity and volume of chromium contamination in ground water. 

EPA has used PRB to treat metals and organic contaminants in ground water at other 

sites. An example of this is the 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 

water to non-detect values after the flow of contaminants pass thru the reactive barrier. 

Based on the discussion above, Region 2 believes the remediation of the GGCS would 

be more appropriate and cost effective under the remedial authority rather than 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 environment than the removal option? 

2 EPA's detennination is also infonned by its guidance document, entitled Use ofNon-Time Critical Removal 

Authority in Superfund Response Actions, dated February 14, 2000, which recommends the use of remedial authority 

at complex and costly sites to effectuate a comprehensive response. 
Recommendation 

.
 Since the Garfield Ground Water Contamination site meets the NPL listing criteria of 

Section 300.425 (c) (3) of the NCP, Region 2 recommends listing the site on the NPL. 

The ATSDR has recommended dissociation of individuals from the release at the site. 

Region 2 and ATSDR concur that the release poses a significant threat to the public 

health, and Region 2 anticipates that it will be more cost effective to use the Remedial 

Authority of CERCLA than Removal Authority to address the release at this site. 

Attachments