1

HAZARD RANKING SYSTEM (HRS) PACKAGE 

TROY CHEM CORP INC 

NEWARK, NEW JERSEY 

CERCLIS ID No.: NJD002144517 

EPA Contract No. EP-S5-06-04 

TDD No. S05-0013-1111-015

Document Control No. 1673-2A-BDFA 

December 2013 

Prepared for: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Prepared by: 

Weston Solutions, Inc. 

Edison, New Jersey 08837 
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HRS DOCUMENTATION RECORD--REVIEW COVER SHEET

Name of Site: Troy Chem Corp Inc 

Date Prepared: December 2013 

Contact Persons

Site Investigation: Ildefonso Acosta (212) 637-4344 

U.S. Environmental Protection Agency 

New York, NY 

Documentation Record: Ildefonso Acosta (212) 637-4344

U.S. Environmental Protection Agency 

New York, NY 

Pathways, Components, or Threats Not Scored

The surface water migration pathway – drinking water threat, ground water migration pathway, soil exposure 

pathway, and air migration pathway were not scored because the listing decision is not affected significantly by 

those pathways. The site score is sufficient to list the site on the surface water migration pathway score based on the 

human food chain and environmental threats. 

The ground water migration, soil exposure, and air migration pathways are adversely affected and are of potential 

concern, as the information in the HRS documentation record indicates. Soil and ground water contamination is 

widespread throughout the Troy property, and there was an air release from the facility in January 2011 that had an 

adverse effect on workers at the adjacent Federal Express facility. 
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HRS DOCUMENTATION RECORD

Name of Site: Troy Chem Corp Inc Date Prepared: December 2013 

EPA ID No.: NJD002144517 

EPA Region: 2 

Street Address of Site*: One Avenue L, Newark, NJ 07105 

County and State: Essex County, New Jersey 

General Location in the State: urban northeastern portion of State 

Topographic Maps: Elizabeth, NJ-NY

Latitude*: 40 42 58.68” North (40.7163°) Longitude*: 74 08 42.72 West (-74.1452°) 

Site Reference Point: concrete portion of Pierson’s Creek, south edge of Troy Chemical property 

[Figures 1, 2; Ref. 3, p. 1; 4, p. 1; 5, p. 6] 

** The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS) 

documentation record identify the general area where the site is located. They represent one or more locations EPA 

considers to be part of the site based on the screening information EPA used to evaluate the site for NPL listing. 

EPA lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, the 

focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has 

been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring and the subsequent 

listing of a release merely represent the initial determination that a certain area may need to be addressed under 

CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of 

scoring will be refined as more information is developed as to where the contamination has come to be located. 

 Scores

Ground Water Pathway Not Scored 

Surface Water Pathway 100.00 

Soil Exposure Pathway Not Scored 

Air Pathway Not Scored 

HRS SITE SCORE 50.00 
 6 

WORKSHEET FOR COMPUTING HRS SITE SCORE 

TROY CHEM CORP INC 

S S

2

1. Ground Water Migration Pathway Score (Sgw) Not Scored

(from Table 3-1, line 13) 

2a. Surface Water Overland/Flood Migration Component 100.00 10,000.00

(from Table 4-1, line 30) 

2b. Ground Water to Surface Water Migration Component Not Scored

(from Table 4-25, line 28) 

2c. Surface Water Migration Pathway Score (Ssw) 100.00 10,000.00 

Enter the larger of lines 2a and 2b as the pathway score. 

3. Soil Exposure Pathway Score (Ss) Not Scored 

(from Table 5-1, line 22) 

4. Air Migration Pathway Score (Sa) Not Scored

(from Table 6-1, line 12) 

5. Total of Sgw

2

+ Ssw

2

+ Ss

2

+ Sa

2

10,000.00 

6. HRS Site Score Divide the value on line 5 

 by 4 and take the square root 50.00
 7 

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET 

TROY CHEM CORP INC 

SURFACE WATER OVERLAND/FLOOD MAXIMUM VALUE

MIGRATION COMPONENT VALUE ASSIGNED

Factor Categories & Factors

DRINKING WATER THREAT

Likelihood of Release

1. Observed Release 550 550

2. Potential to Release by Overland Flow

 2a. Containment 10 not scored

 2b. Runoff 25 not scored

 2c. Distance to Surface Water 25 not scored

 2d. Potential to Release by Overland Flow 500 not scored

 (lines 2a [2b + 2c])

3. Potential to Release by Flood

 3a. Containment (Flood) 10 not scored

 3b. Flood Frequency 50 not scored

 3c. Potential to Release by Flood 500 not scored

 (lines 3a x 3b)

4. Potential to Release (lines 2d + 3c) 500 not scored

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics

6. Toxicity/Persistence * not scored

7. Hazardous Waste Quantity * not scored

8. Waste Characteristics 100 not scored

Targets

9. Nearest Intake 50 not scored

10. Population

 10a. Level I Concentrations ** not scored

 10b. Level II Concentrations ** not scored

 10c. Potential Contamination ** not scored

 10d. Population (lines 10a + 10b + 10c) ** not scored

11. Resources 5 not scored

12. Targets (lines 9 + 10d + 11) ** not scored

13. DRINKING WATER THREAT SCORE 100 not scored

 ([lines 5 x 8 x 12]/82,500)

* Maximum value applies to waste characteristics category. 

** Maximum value not applicable 
 8 

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET 

TROY CHEM CORP INC 

SURFACE WATER OVERLAND/FLOOD MAXIMUM VALUE

MIGRATION COMPONENT VALUE ASSIGNED

Factor Categories & Factors

HUMAN FOOD CHAIN THREAT

Likelihood of Release

14. Likelihood of Release (same as line 5) 550 550

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation * 2.00E+08

16. Hazardous Waste Quantity * 10,000

17. Waste Characteristics 1,000 1,000

Targets

18. Food Chain Individual 50 20

19. Population

 19a. Level I Concentrations ** 0

 19b. Level II Concentrations ** 0

 19c. Potential Human Food Chain Contamination ** 0.0000003

 19d. Population (lines 19a + 19b + 19c) ** 0.0000003

20. Targets (lines 18 + 19d) ** 20.0000003

21. HUMAN FOOD CHAIN THREAT SCORE 100 100.00

 ([lines 14 x 17 x 20]/82,500)

* Maximum value applies to waste characteristics category. 

** Maximum value not applicable 
 9 

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET 

TROY CHEM CORP INC 

SURFACE WATER OVERLAND/FLOOD MAXIMUM VALUE

MIGRATION COMPONENT VALUE ASSIGNED

Factor Categories & Factors

ENVIRONMENTAL THREAT

Likelihood of Release

22. Likelihood of Release (same as line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence/Bioaccumulation * 2.00E+08

24. Hazardous Waste Quantity * 10,000

25. Waste Characteristics 1,000 1,000

Targets

26. Sensitive Environments

 26a. Level I Concentrations ** 0

 26b. Level II Concentrations ** 25

 26c. Potential Contamination ** 0.001

 26d. Sensitive Environments (lines 26a + 26b + 26c) ** 25.001

27. Targets (line 26d) ** 25.001

28. ENVIRONMENTAL THREAT SCORE 60 60.00

 ([lines 22 x 25 x 27]/82,500)

29. WATERSHED SCORE (lines 13 + 21 + 28) 100 100.00

30. SURFACE WATER OVERLAND/FLOOD 100 100.00

 MIGRATION COMPONENT SCORE (Sof)

SURFACE WATER MIGRATION PATHWAY 100 100.00

SCORE (Ssw)

* Maximum value applies to waste characteristics category. 

** Maximum value not applicable 
 10 

REFERENCES

Reference 

Number Description of the Reference

1. U.S. Environmental Protection Agency (EPA). Revised Hazard Ranking System, Final Rule, 40 CFR 

300, Appendix A. Federal Register. December 14, 1990. A complete copy of the rule is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS Rule. [138 pages] 

2. EPA. Superfund Chemical Data Matrix (SCDM) – excerpts. March 31, 2012. Accessed and printed 

from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm on April 23, 2013. [7 pages] 

3. EPA. Search Superfund Site Information, Troy Chem Corp Inc. Accessed and printed from 

http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0200114 on April 23, 2013. [1 page] 

4. U.S. Department of the Interior Geological Survey (USGS). Elizabeth Quadrangle, New Jersey-New 

York, 7.5-minute Series (Topographic). 1995. [1 map] 

5. Weston Solutions, Inc. (WESTON). Field Logbook, Pierson’s Creek-Troy Chem Corp Inc, Newark, 

NJ,. December 14, 2011 – October 25, 2012. [62 pages] 

6. Gilliland, Gerald V., WESTON. Sampling Trip Report, Work Assignment No. 1673, Troy Chem Corp 

Inc. (Pierson’s Creek), Contract No. EP-S5-06-04, TDD No. S05-0013-1111-015. November 9, 2012. 

[69 pages] 

7. Sheikh, Muhammad (Hanif), EPA. Email with attachments to Ildefonso Acosta et al, Subject: 

Regionally Assessed Inorganic Data for Troy Chemecal Corp Site --Case # 43052, SDG# MBAKW1. 

November 27, 2012. [79 pages] 

8. Sheikh, Muhammad (Hanif), EPA. Email with attachments to Ildefonso Acosta et al, Subject: 

Regionally Assessed Inorganic Data for Troy Chemecal Corp Site --Case # 43052, SDG# MBAL23. 

December 6, 2012. [85 pages] 

9. Sheikh, Muhammad (Hanif), EPA. Email with attachments to Ildefonso Acosta et al, Subject: 

Regionally Assessed Inorganic Data for Troy Chemecal Corp Site --Case # 43052, SDG# MBAKY9. 

December 6, 2012. [86 pages] 

10. Sheikh, Muhammad (Hanif), EPA. Email with attachments to Ildefonso Acosta et al, Subject: 

Regionally Assessed Inorganic Data for Troy Chemecal Corp Site --Case # 43052, SDG# MBAL06. 

December 7, 2012. [64 pages] 

11. Bourbon, John R., EPA Region 2 Laboratory. Transmittal to Gerry Gilliland, WESTON, RE: Troy 

Chem Corp, Inc. – 1210055 (results of analyses). December 7, 2012. [29 pages] 

12. Arnone, Russell, EPA. Email with attachments to Ildefonso Acosta et al, Subject: Attached are the 

regionally assessed data for the Troy Chemical Corp site under the CLP Case # 43052, SDG

#BAKW1. November 29, 2012. [231 pages] 

13. Arnone, Russell, EPA. Email with attachments to Ildefonso Acosta et al, Subject: Attached are the 

regionally assessed data for the Troy Chemical Corp site under the CLP Case # 43052, SDG # BAL19. 

November 29, 2012. [142 pages] 

14. Arnone, Russell, EPA. Email with attachments to Ildefonso Acosta et al, Subject: Attached are the 

regionally assessed data for the Troy Chemical Corp site under the CLP Case # 43052, SDG # BAL31, 

BAKY3. December 5, 2012. [411 pages] 
 11 

REFERENCES (continued) 

Reference 

Number Description of the Reference

15. Arnone, Russell, EPA. Email with attachments to Ildefonso Acosta et al, Subject: Attached are the 

regionally assessed data for the Troy Chemical Corp site under the CLP Case # 43052, SDG # BAL07. 

December 7, 2012. [139 pages] 

16. EPA. Quick Reference Fact Sheet EPA 540-F-94-028: Using Qualified Data to Document an 

Observed Release and Observed Contamination. Office of Emergency and Remedial Response. 

November 1996. [18 pages] 

17. New Jersey Department of Environmental Protection (NJDEP), Responsible Party Investigations Unit. 

Investigative Summary, Case name: Troy Chemical Corporation, Inc., AKA: Troy Chemical 

Company. June 1991. [80 pages] 

18. Hayton, Anne, NJDEP. Referral Form to Manuel Sanchez, Metcalf and Eddy, with enclosed Troy 

Chemical Company historical information. July 19, 1996. [70 pages] 

19. EMCON. Remedial Investigation Report, Troy Chemical Corporation, Inc., Newark, New Jersey, 

Project 83611.001.000. Prepared for Troy Chemical Corporation, Inc. February 1998. [236 pages] 

20. Environmental Liability Management, Inc. (ELM). Remedial Investigation Report for Additional Soil 

and Groundwater Sampling and Remedial Action Selection, Report for Soil, Troy Chemical 

Corporation, Inc., for the property located at One Avenue L, Newark, New Jersey. Prepared for Troy 

Chemical Corp., Inc. September 27, 2000. [206 pages] 

21. Environmental Data Resources Inc. (EDR). Certified Sanborn® Map Report, Piersons Creek, 1 

Avenue L, Newark, NJ, 07105; Inquiry Number 3263219.3. February 22, 2012. [23 pages] 

22. EDR. The EDR Aerial Photo Decade Package, Piersons Creek, 1 Avenue L, Newark, NJ, 07105; 

Inquiry Number 3263219.4. February 22, 2012. [15 pages] 

23. Heacox, Illse, NJDEP. Memo to Assistant Commissioner Arbesman, Subject: Troy Chemical 

Pretreatment Issue. December 17, 1979. [2 pages] 

24. United States International Trade Commission (USITC; formerly United States Tarriff Commission). 

Synthetic Organic Chemicals, United States Production and Sales; excerpts from annual reports, 1956 

to 1994. Various dates, 1957 to 1995. [508 pages] 

25. Lintner, William, L & L Chemical Construction and Engineering Co. Letter with enclosed permit 

application package to William B. Honachefsky, NJDEP, Subject: Permit to Locate, Pursuant to NJSA 

58:10-17 to 21, inclusive, Troy Chemical Company, Newark City, Essex County. June 15, 1977. [9 

pages] 

26. Shulfer, S., NJDEP. Memorandum to Robert Harrison, Subject: Permit to Locate inspection, Troy 

Chemical Corporation, City of Newark, Essex County. July 22, 1977. [5 pages] 

27. Honachefsky, William B., NJDEP. Letter to Milton Nowak, Troy Chemical Corporation, Re: Denial 

of Permit to Locate pursuant to N.J.S.A. 58:10-17 to 21; inclusive, Troy Chemical Corporation, City of 

Newark. July 22, 1977. [2 pages] 
 12 

REFERENCES (continued) 

Reference 

Number Description of the Reference

28. Schwartz, Theodore A., Schwartz, Steinberg, Tobia, & Stanziale. Letter to William B. Honachefsky, 

NJDEP, Re: Permit to Locate, pursuant to NJSA 58:10-17 to 21, inclusive, Troy Chemical Company, 

Newark, New Jersey. July 28, 1977. [4 pages] 

29. NJDEP. Authorization to Discharge under the National Pollutant Discharge Elimination System, 

Permit No. NJ0031453, Troy Chemical Corporation, 1 Avenue L, Newark, New Jersey 07105. April 7, 

1978. [9 pages] 

30. Ciancia, John, EPA. Memorandum to Paul Jacobi, Re: Inspection and Sampling Survey of Troy 

Chemical Co, Plant in Newark, New Jersey for mercury pollution. September 7, 1979. [9 pages] 

31. Maack, Charles L. and Charles L. Johnson, NJDEP. Memo to Edward H. Post, Subject: Inspection of 

Troy Chemical Corporation, Newark, NJ. December 21, 1979. [3 pages] 

32. Maack, C. and C. Johnson, NJDEP. Memo to File, Subject: Sampling Inspection, Troy Chemical 

Corporation, Newark. March 25, 1981. [9 pages] 

33. Johnson, Charles L., NJDEP. Memo to Charles L. Maack, Subject: Inspection of Troy Chemical 

Corporation, Newark. February 23, 1981. [2 pages] 

34. Gruzlovic, Mark S. through Bruce Comfort, NJDEP. Memo to Spill File, Subject: (07-14) #84-01-28-

03C --- Unknown Liquid Discharge from Troy Chemical. May 3, 1984. [5 pages] 

35. Capasso, Edward J., Troy Chemical Corporation. Letter to Mr. Perrapato, Passaic Valley Sewerage 

Authority, Re: Sewer Permit #20403290. August 29, 1986. [2 pages] 

36. Capasso, Edward J., Troy Chemical Corporation. Letter to F.A. Quintieri, Passaic Valley Sewerage 

Commissioners. March 10, 1987. [1 page] 

37. Decicco, Anne, NJDEP. Memo to Steve Borgianini through John Mateo, Subject: Request for 

Preliminary Assessment of Troy Chemical Site, Newark. March 10, 1988. [40 pages] 

38. The ELM Group, Inc. Remedial Investigation Report for Sediment and Surface Water, Troy Chemical 

Corporation Property, One Avenue L, Newark, Essex County, New Jersey, Case No. G000001344. 

Prepared for Troy Chemical Corporation. July 21, 2010. [356 pages] 

39. Moore, Jeffrey S. and Mark D. Fisher, The ELM Group, Inc. Letter to Haiyesh Shah, NJDEP, RE: 

Remedial Investigation Report Addendum/Remedial Investigation Workplan Addendum for Sediment 

and Surface Water, Troy Chemical Corporation Property, One Avenue L, Newark, Essex County, New 

Jersey, NJDEP Case No. G000001344. February 25, 2011. [35 pages] 

40. Zach, Alvin L., Newark Department of Engineering. Letter to Beatrice Tylutki, NJDEP, RE: Mercury 

at site of previous Albert Steel and Drum, located at Wilson Avenue and Avenue L (Block 5038, Lot 

70 – 97-98). May 24, 1979. [4 pages] 

41. Gevirtz, Arthur and John Ciancia, EPA. Memorandum to Dr. Richard Spear, Re: Site Inspection at the 

Former Albert Drum Co., Newark location on June 6, 1979. June 8, 1979. [3 pages] 

42. Morgan, James, Newark Fire Department. Memo to James P. O’Bierne, Re: Ave ‘L’ and Wilson Ave 

(Former Owner Albert Steel Drums). June 8, 1979. [1 page] 
 13 

REFERENCES (continued) 

Reference 

Number Description of the Reference

43. Oliva, Jean L. and Andrew Zlotnick, TRC. Final Background Investigation, Interim Report, Albert 

Steel Drum/Prentiss Drug and Chemical Site, Newark, New Jersey, TRC Project No. 3711-N81-17. 

March 11, 1987. [56 pages] 

44. Reference Number Reserved.

45. Gallagher, Tom and James Mack, The Morris Companies. Letter to Stephen Kehayes, NJDEP, Re: 

Albert Steel Drum, Drainage Ditch, Remedial Activities Report. May 19, 2004. [12 pages] 

46. Reference Number Reserved.

47. Reference Number Reserved.

48. Gilliland, Gerry, WESTON. Project Note to Troy Chem Corp Inc File, Subject: Wetland Frontage 

calculations, with attached Target Distance Limit Pathway Map. April 24, 2013 and August 9, 2013. 

[2 pages] 

49. Burger, J., Rutgers University. Consumption patterns and why people fish; Abstract. Environ Res. 

2002 Oct;90(2):125-35. October 2002. [2 pages] Accessed April 24, 2013 

50. NJDEP and New Jersey Audubon Society. Fishing for Answers in an Urban Estuary; excerpts. 2004 

[56 pages] 

51. EPA and New York/New Jersey Harbor Estuary Program. EPA’s National Estuary Program, with link 

to the New York-New Jersey Harbor Estuary Program website (About the Program, About the Estuary, 

Useful Resources: Publications – Program Planning Documents and About the Program: Action Plan). 

Downloaded from http://www.epa.gov/owow/estuaries/ and http://www.harborestuary.org/ on April 

21, 2009. [35 pages] 

52. New Jersey Department of Transportation/Office of Maritime Resources (NJDOT/OMR), I Boat NJ 

Program. New Jersey Boater’s Ramp Guide; excerpt. Undated. Downloaded from 

http://www.njfishandwildlife.com/pdf/boat_ramp_guide.pdf. [24 pages] 

53. New York State Department of Environmental Conservation (NYSDEC) Region 2. Saltwater Fishing 

in New York City. NYSDEC Region 2, Long Island City, NY. Undated. Downloaded from 

http://www.dec.ny.gov/docs/fish_marine_pdf/ifishny.pdf [33 pages] 

54. Going Coastal, Inc. Reel It In! Brooklyn, Fish Consumption Education Project in Brooklyn. Undated. 

[68 pages] 

55. Lauinger, John and Elizabeth Hays, Daily News. Fishing for danger: Poor people driven to catch and 

eat toxin-filled species. July 6, 2009. Downloaded from http://www.nydailynews.com/newyork/fishing-danger-poor-people-driven-catch-eat-toxin-filled-species-article-1.426367. [3 pages] 
 14 

REFERENCES (continued) 

Reference 

Number Description of the Reference

56. U.S. Army Corps of Engineers (USACE). Essential Fish Habitat Assessment For Newark Bay 

Maintenance Dredging; Newark Bay – Port Newark Channel, Port Newark Pierhead Channel, & Port 

Elizabeth Channel of Newark Bay, Hackensack & Passaic Rivers Federal Navigation Project. 

Undated. Downloaded from http://www.nero.noaa.gov/hcd/efh%20nb-kln.pdf . [27 pages] 

57. Gregory, Alexander F., Columbia University. Assessment of Mercury Contamination in Surficial 

Sediments of Newark Bay. Submitted in partial fulfillment of the requirements for the degree of 

Master of Science in Earth Resources Engineering, Advisor: Professor Nickolas J. Themelis. 

November 2001. [72 pages] 

58. NJDEP. N.J.A.C. 7:9B, Surface Water Quality Standards (courtesy copy). Statutory Authority: 

N.J.S.A. 58:10A-1 et seq., 58:11A-1 et seq., and 13:1D-1 et seq. Re-adopted: November 16, 2009, 

Last Amended: April 4, 2011. [113 pages] 

59. Weinstein, Norman J., P.E., Recon Systems, Inc. Engineering Report, Wastewater Effluent, Albert 

Steel Drum Co., Inc., 338 Wilson Avenue, Newark, New Jersey, 07105. June 16, 1976. [10 pages] 
 15 

SITE DESCRIPTION

The Troy Chem Corp Inc site (EPA ID No. NJD002144517) is located at One Avenue L in Newark, Essex County, 

New Jersey [Ref. 3, p. 1; 4, p. 1; 21, p. 11]; the site location is shown in Figure 1. The site as scored consists of 

sediments in Pierson’s Creek contaminated with mercury as a result of historical releases from the chemical 

manufacturing facility located at One Avenue L [see Sections 2.2 and 4.1.2.1.1]. The Troy Chemical facility, which 

remains active in the manufacture of antimicrobial and antifungal paint additives and related products, manufactured 

mercury compounds from 1956 or 1957 until 1987 [Ref. 17, p. 4, 22, 57; 18, p. 2; 19, pp. 12-14; 20, p. 14; 28, p. 2; 

29, pp. 2-3, 6-7; 30, pp. 1-2; 37, p. 1; 38, pp. 13, 29-30]. Manufacturing processes at the facility included 

purification of mercury metal, production of mercuric oxide from the mercury metal, and the manufacture of organic 

mercury compounds using mercuric oxide [Ref. 17, p. 22; 18, p. 4; 19, p. 14; 20, pp. 14-15, 63; 30, p. 2]. The 

mercuric oxide manufacturing process was reported to be the primary source of mercury-bearing wastewater at the 

facility, accounting for approximately 7,000 gallons per week [Ref. 17, p. 22; 18, p. 4; 30, p. 2]. Other sources of 

mercury-bearing wastewater included spillage, leakage, and washing of equipment and floors in the mercuric oxide 

manufacturing operation; production of phenyl mercuric sulfide; and spills, leaks, and washings in all organic 

mercury compound manufacturing operations [Ref. 17, p. 22; 30, p. 2]. The Troy Chemical facility is shown in 

Figure 2. 

The Troy Chemical facility discharged its mercury-bearing wastewater directly into Pierson’s Creek without prior 

treatment until 1965, and after sulfide precipitation pretreatment from 1965 until 1976 [Ref. 17, pp. 6, 8; 18, p. 5; 

30, p. 3]. Pierson’s Creek historically flowed in the concrete channel that bisects the facility, and an unnamed, 

intermittent tributary flowed along the eastern property boundary and joined Pierson’s Creek just south of the Troy 

facility [Ref. 17, pp. 1, 5, 7, 41; 19, pp. 3, 11, 64, 135; 22, pp. 9-14]. Due to a drainage improvement project 

completed in 2007, the perennial portion of Pierson’s Creek now begins just south of the Troy Chemical facility, 

where it receives stormwater runoff from a large culvert as well as the concrete channel and east ditch on the Troy 

property [Ref. 5, p. 6; 38, pp. 14-23, 80]. Pierson’s Creek flows from there through a series of open channels and 

culverts in a general south-southwesterly direction to the Port Newark Channel portion of Newark Bay [Figure 4; 

Ref. 5, pp. 6-8; 18, p. 69; 38, pp. 15-16].

In 1976, the Troy Chemical facility connected to the Passaic Valley Sewerage Commission (PVSC) sewer system, 

and began diverting wastewater from the mercury pretreatment system to an overall plant wastewater treatment plant 

(WWTP), where wastewaters were treated by settling, removal of suspended solids and oil, and neutralization before 

subsequent discharge to the PVSC system [Ref. 17, p. 22; 19, pp. 14-15]. Even these additional levels of treatment 

did not remove all mercury from the process wastewater – the mercury contribution to PVSC was calculated to be 

approximately 327 pounds per day tested in 1979; in another instance, the facility discharged an average of more 

than 30,000 gallons per day of mercury-bearing wastewater for a 91-day period in 1986 [Ref. 23, p. 1; 35, p. 1]. 

In addition to the facility wastewater discharges directed to Pierson’s Creek, there are other reported instances of 

mercury-containing wastewater and stormwater discharging from the Troy facility into Pierson’s Creek after 

connection to the PVSC sewer system [Ref. 18, pp. 5, 12-21]. An inspection in July 1977 revealed numerous pipes 

discharging into the stream, none of which were depicted on the site plan for the facility [Ref. 17, pp. 14-15]. 

During an inspection on April 28, 1980, New Jersey Department of Environmental Protection (NJDEP) observed 

stormwater and wastewater flowing into Pierson’s Creek and its unnamed tributary via runoff, pipes, cracks in the 

creek’s concrete walls adjacent to a Troy building and tank farm, and overflow from Troy’s industrial wastewater 

collection sump [Ref. 32, pp. 1-2]. All of these liquids flowing into Pierson’s Creek and its tributary were found to 

contain mercury, including one that contained mercury droplets; copper, lead, arsenic, and zinc were also detected 

[Ref. 32, pp. 1-9]. In January 1984, NJDEP observed cracks in a concrete wall of the creek and a pipe discharging 

into the creek [Ref. 34, p. 2]. In 1998, Troy Chemical considered surface water and sediment conditions in 

Pierson’s Creek and its unnamed tributary to be the principal environmental concerns associated with the site [Ref. 

19, p. 11]. 
 16 

SITE DESCRIPTION (continued)

Investigations by Troy Chemical, NJDEP, and EPA have indicated significant increases in sediment mercury 

concentrations at and downstream of the facility compared to upstream sediment concentrations, as recently as 2010 

[Ref. 18, pp. 12-20; 19, p. 147; 30, pp. 4-9; 33, pp. 1-2; 37, p. 12; 38, p. 84; 39, pp. 29, 32]. In July 1979, EPA 

collected a sediment sample from Pierson’s Creek just downstream of the mercury wastewater treatment system and 

reported a mercury concentration of 22,400 milligrams per kilogram (mg/kg), compared to upstream concentrations 

of 140 and 191 mg/kg; EPA also reported mercury concentrations above background for samples collected 

downstream of the facility [Ref. 30, pp. 4-7]. The same report indicates a significant increase in water 

concentrations for benzene, which was a raw material at the Troy Chemical facility [Ref. 30, pp. 6-8]. 

EPA conducted an investigation of Pierson’s Creek in October 2012, which confirmed the observed release of 

mercury to the creek sediments. Mercury was detected in sediment samples collected throughout the accessible 

portions of the creek, and a site-attributable observed release is documented for a distance of approximately 0.25 

mile downstream of the Troy facility [see Section 4.1.2.1.1]. The affected area includes 0.15 mile of wetland 

frontage [Figure 3; Ref. 1, Section 4.1.4.3.1; Ref. 5, pp. 43-62]. The zone of contamination and the wetland frontage 

are shown in Figure 3. 

Pierson’s Creek flows through a series of open channels and culverts to Newark Bay approximately 1.5 miles 

downstream of the Troy Chemical facility [Figures 3, 4; Ref. 5, pp. 6-8; 18, p. 69; 38, pp. 15-16]. There are 

downstream areas within the target distance limit (TDL) where fish are caught and consumed, and Newark Bay is 

part of the New York-New Jersey Harbor Estuary, a sensitive area identified under the National Estuary Program 

[Figure 4; Ref. 48, p. 2; 51, pp. 1-10; 53, pp. 29-30; 54, pp. 15, 22, 29; 55, p. 1]. 

For the Troy Chem Corp Inc site, EPA is evaluating the human food chain and environmental threats of the surface 

water migration pathway, overland/flood migration component [Ref. 1, Sections 4.1.3 and 4.1.4]. The source under 

consideration is the collective historical discharge of mercury wastewater from the Troy Chemical manufacturing 

facility (Source 1). Laboratory analytical results for sediment samples collected by EPA in October 2012 confirmed 

the observed release of mercury to the creek downstream of the Troy Chemical facility; the zone of contamination is 

partially bordered by wetlands [Figure 3; see Sections 4.1.2.1.1 and 4.1.4.3.1.2].
CLIENT NAME: DATE: FIGURE #:

PROJECT:

LEGEND: TITLE:

Pierson's Creek

0 250 500 1,000

Graphic Scale In Feet

Pierson's Creek

SOURCE:

1. NJ Office of Information Technology (NJOIT), Office of Geographic Information

 Systems (OGIS). New Jersey 2012 - 2013 High Resolution Orthophotography,

 NAD83 NJ State Plane Feet, MrSID Tiles. March 2013.

 https://njgin.state.nj.us/NJ_NJGINExplorer/jviewer.jsp?pg=2012_OrthoImagery.

EPA

Troy Chem Corp Inc 

August 2013 1

Location Map

Troy Chem Corp Inc 

Newark, Essex County, NJ

P:\SAT2\Piersons Creek\MXD\2013_08_HRS\13534_TCC_Site_Loc_201308.mxd

Feeder Stream

Feeder Stream

Feeder Stream

Feeder Streams

(Unnamed Tributaries)

Flow Direction

Site Area

"

NJ

PA

NY

Facility Boundary

Troy Chem Facility

®
CLIENT NAME: DATE: FIGURE #:

PROJECT:

LEGEND: TITLE:

!(

!(

!(

Troy Chemical Facility

Bldg. 40

Bldg. 56

Bldg. 71

Former Location of Hg 

Pretreatment System

Concrete-Lined Channel

(Former Pierson's Creek)

Unnamed Tributary

Box Culvert

SW25

SD25A

SD25CC (Dup)

SD25B

Probable Point of Entry (PPE)

Pierson's Creek

SW23

SD23A

SD23B

Former Location of Hg 

Recovery Still

SW24

SD24A

SD24B

R

EPA

Troy Chem Corp Inc 

August 2013 2

Historical Facility Map

Troy Chem Corp Inc 

Newark, Essex County, NJ

0 50 100 200

Graphic Scale In Feet

®

!( Sample Location

Facility Boundary

NOTE:

1. All samples IDs are preceded by “PC-“

SOURCE:

1. NJ Office of Information Technology (NJOIT), Office of Geographic Information

 Systems (OGIS). New Jersey 2012 - 2013 High Resolution Orthophotography,

 NAD83 NJ State Plane Feet, MrSID Tiles. March 2013.

 https://njgin.state.nj.us/NJ_NJGINExplorer/jviewer.jsp?pg=2012_OrthoImagery.

2. Ref. 5, p. 18; 6, pp. 8, 11, 14; 19, pp. 135-136.

P:\SAT2\Piersons Creek\MXD\2013_08_HRS\13585_TCC_Historic_Facility.mxd
CLIENT NAME: DATE: FIGURE #:

PROJECT:

LEGEND: TITLE:

!(

!( !(

!( !( !(

!(

!( !(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!U

!(

Troy Chemical

Facility

Access Gate

SW27

SD27A

SD27B

SW23

SD23A

SD23B

SW02

SD02A

SD02B

SW24

SD24A

SD24B

SW22

SD22A

SD22B

SW21

SD21A

SD21B

SW18

SD18A

SD18B

SW17

SD17A

SD17B

SW16

SD16A

SD16B

SW15

SD15A

SD15B

SW06

SD06A

SD06B

SW12

SD12A

SD12B

SW11

SD11A

SD11B

SW07

SD07A

SD07B

SW09

SD09A

SD09B

SW08

SD08A

SD08B

SW04

SD04A

SD04B

SW01

SD01A

SD01B

SW13

SW29 (Dup)

SD13A

SD13B

SW25

SD25A

SD25CC (Dup)

SD25B

SW05

SW03 (Dup)

SD05A

SD05C (Dup)

SD05B

SW14

SD14A

SD14B

SD14C (Dup)

R

EPA

Troy Chem Corp Inc 

August 2013 3

Surface Water Pathway Zone of Contamination 

Troy Chem Corp Inc 

Newark, Essex County, NJ

0 200 400 800

Graphic Scale In Feet

®

NOTE:

1. All samples IDs are preceded by “PC-“

SOURCES:

1. NJ Office of Information Technology (NJOIT), Office of Geographic Information

 Systems (OGIS). New Jersey 2012 - 2013 High Resolution Orthophotography,

 NAD83 NJ State Plane Feet, MrSID Tiles. March 2013.

 https://njgin.state.nj.us/NJ_NJGINExplorer/jviewer.jsp?pg=2012_OrthoImagery.

2. Ref. 5, pp. 10-40, 43-62; 6, pp. 5-14.

P:\SAT2\Piersons Creek\MXD\2013_08_HRS\13536_TCC_SW_Zone_Contamination_201308.mxd

!( Sample Location

!U Access Gate

Zone of Contamination

Wetland Frontage

Pierson's Creek

Feeder Streams

(Unnamed Tributaries)

Facility Boundary
CLIENT NAME: DATE: FIGURE #:

PROJECT:

LEGEND: TITLE:

#*

#*

#*

#*

#*

#*

#* #*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#* #*

#*

#*

#*

#* #* #* #* #*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

Facility Location #*

Approximate PPE

Target

Distance Limit

Target

Distance Limit

Target

Distance Limit

Target

Distance Limit

Target

Distance Limit

R

2.502 1.25 .5

Graphic Scale In Miles

P:\SAT2\Piersons Creek\MXD\2013_08_HRS\13535_TCC_Sample_Loc_201308.mxd

EPA

Troy Chem Corp Inc 

August 2013 4

Surface Water Migration Pathway Map 

Troy Chem Corp Inc 

Newark, Essex County, NJ

®

SOURCE: 

1. National Geographic TOPO! U.S. Geologic Survey (USGS). 7.5 Minute Series 

 (Topographic) Quadrangles: Arthur Kill, NY, 1981; Brooklyn, NY 1995; Caldwell, NJ 1995; 

 Central Park, NY, 1995; Coney Island, NY 1995; Elizabeth, NJ 1995; Hackensack, NJ 

 1998; Jersey City, NJ 1995; Orange, NJ 1995; Paterson, NJ 1998; Perth Amboy, NJ 

 1995; Pompton Plains, NJ 1995; Roselle, NJ 1995; The Narrows, NJ, 1998; Weehawken, 

 NJ 1998; and Yonkers, NY 1998:

Legend

Facility Boundary

 -Longitude: West 74 08 42.7 

 -Latitude: North 40 29 58.68

15-Mile Surface Water Pathway Area

#* 15-Mile Surface Water Pathway Marker

15-Mile Surface Water Pathway

(Dashed for Radii)
 21 

SD-Characterization and Containment 

SOURCE DESCRIPTION

2.2 SOURCE CHARACTERIZATION

2.2.1 Source Identification

Number of the source: Source No. 1

Name and description of the source: Historical Wastewater Discharge – Troy Chemical facility

Source Type: Other

Source 1 consists of the historical discharge of mercury-bearing wastewater from the Troy Chemical facility into 

Pierson’s Creek. The facility initiated manufacture of mercury-containing products in 1956 or 1957 [Ref. 17, pp. 4, 

22; 19, p. 14; 20, p. 14; 28, p. 2; 30, p. 1]. Organic mercury compounds produced at the facility included 

phenylmercuric acetate (PMA), phenylmercuric oleates, phenylmercuric ammonium acetate, 

chloromethoxypropylmercuric acetate, phenylmercuric borate, diphenylmercury dodecenylsuccinate, 

phenylmercuric hydroxide, phenylmercuric lactate, and phenylmercuric sulfide [Ref. 24, pp. 79-80, 86, 90-92, 95, 

99-101, 106, 111-112, 117, 122-123, 127, 131-133, 136, 141-142, 146, 150-153, 157, 161-164, 167, 171-174, 179, 

183-184, 187, 194, 198-199, 202, 208, 212-213, 221, 225-226, 234, 238-239, 247, 252-253, 258, 264, 269-270, 279, 

284-285, 294, 300-301, 310, 316-317, 319, 333-334, 344, 349, 358, 363, 372, 377-378, 387, 392-393, 401, 405-406, 

413, 417, 425; 30, p. 2]. Manufacturing processes included purification of mercury metal, production of mercuric 

oxide from the mercury metal, and production of the organic mercury compounds using the mercuric oxide [Ref. 

17, p. 22; 18, p. 4; 19, p. 14; 20, pp. 14-15, 63; 30, p. 2]. 

The mercuric oxide manufacturing process was reported to be the primary source of mercury-bearing wastewater at 

the facility, accounting for approximately 7,000 gallons per week [Ref. 17, p. 22; 18, p. 4; 30, p. 2]. Spillage, 

leakage, and washing of equipment and floors contributed additional mercury-bearing wastewater from the mercuric 

oxide manufacturing operation [Ref. 17, p. 22; 30, p. 2]. The mercuric oxide manufacturing process took place near 

Building 56 (constructed prior to 1954 on the east side of Pierson’s Creek) until 1971, when the process was moved 

across the creek to Building 40 [Ref. 19, pp. 14, 135; 20, pp. 15, 49, 63]. In the organic mercury compound 

manufacturing operations, the main source of discharged mercury-containing wastewater was the production of 

phenylmercuric sulfide [Ref. 17, p. 22; 30, p. 2]. Spills, leaks, and washings in all organic mercury compound 

manufacturing operations contributed additional mercury-bearing wastewater [Ref. 30, p. 2]. Until 1976, Building 

91 (constructed prior to 1954 along the east bank of Pierson’s Creek) was the manufacturing portion of the chemical 

facility [Ref. 19, pp. 14, 135]. In June 1976, fungicide manufacturing began in Building 71, construction of which 

began in the western portion of the facility in 1975 [Ref. 19, pp. 15, 135; 25, p. 5]. In a June 1977 permit 

application for the fungicide plant, Troy Chemical indicated that the plant was generating 2,962-2,963 gallons per 

day of industrial wastewater [Ref. 25, pp. 1-6; 26, p. 1]. The locations of Buildings 56, 40, and 71 are shown in 

Figure 2. 

The Troy Chemical facility discharged its mercury-bearing wastewaters directly to Pierson’s Creek without 

treatment until 1965, when the facility’s mercury pretreatment system was installed west of Building 56 at the edge 

of the creek [Ref. 17, p. 6; 18, p. 5; 20, pp. 14-16, 49, 63; 30, p. 3]. From 1965 to 1976, the mercury-bearing 

wastewaters were discharged to Pierson’s Creek after a sulfide precipitation process in the pretreatment system [Ref. 

17, pp. 6, 8; 18, p. 5; 19, pp. 13-14]. In 1976, the facility connected to the PVSC sewer system, and began diverting 

wastewater from the mercury pretreatment system to the facility WWTP, where wastewaters were treated by 

settling, removal of suspended solids and oil, and neutralization before subsequent discharge to the PVSC system 

[Ref. 17, p. 22; 19, pp. 14-15]. Even these additional levels of treatment at the WWTP did not remove all mercury 

from the process wastewater – the mercury contribution to PVSC was calculated to be approximately 327 pounds 

per day tested in 1979, and the facility discharged an average of more than 30,000 gallons per day of mercurybearing wastewater to the PVSC sewer system for a 91-day period in 1986 [Ref. 23, p. 1; 35, p. 1]. The facility 

reported that it ceased the manufacture of mercury-containing products that discharged to the sewer effluent as of 

February 1, 1987 [Ref. 36, p. 1]. 
 22 

SD-Characterization and Containment 

In addition to the facility wastewater discharges directed to Pierson’s Creek, there are other reported instances of 

mercury-containing wastewater and stormwater discharging from the Troy facility into Pierson’s Creek after 

connection to the PVSC sewer system [Ref. 18, pp. 5, 12-21]. An inspection in July 1977 revealed numerous pipes 

discharging into the stream, none of which were depicted on the site plan [Ref. 17, pp. 14-15]. During an inspection 

on April 28, 1980, NJDEP reported the observance of stormwater and wastewater flowing into Pierson’s Creek and 

its unnamed tributary via runoff, pipes, cracks in the creek’s concrete walls adjacent to a Troy building and tank 

farm, and overflow from Troy’s industrial wastewater collection sump [Ref. 32, pp. 1-2]. All of these liquids 

flowing into Pierson’s Creek and its tributary were found to contain mercury, including one that contained mercury 

droplets; copper, lead, arsenic, and zinc were also detected [Ref. 32, pp. 1-9]. In January 1984, NJDEP observed 

cracks in the concrete wall of the creek and a pipe discharging into the creek [Ref. 34, p. 2]. 

Location of the source, with reference to a map of the site: 

The direct discharges to Pierson’s Creek occurred in the concrete channel (formerly Pierson’s Creek) that bisects the 

Troy Chemical facility [Ref. 19, pp. 135-136]. The location is shown in Figure 2. 

Containment

Release to surface water via overland migration and/or flood: 

The Troy facility discharged untreated mercury wastewater directly to Pierson’s Creek until 1965, and partially 

treated mercury wastewater directly to the creek from 1965 until 1976 [Ref. 18, pp. 4-5; 30, pp. 2-3]. The October 

2012 EPA investigation confirmed that mercury has migrated from the source; analytical results for sediment 

samples downstream of the historical releases indicate the presence of mercury [see Section 4.1.2.1]. Based on the 

historical lack of containment and the current evidence of overland hazardous substance migration from the source, 

a surface water containment factor value of 10 is assigned for this source [Ref. 1, p. Table 4-2]. 
 23 

SD-Hazardous Substances 

Source No.: 1 

2.2.2 Hazardous Substances

The Troy Chemical facility discharged treated mercury-bearing wastewaters into Pierson’s Creek from 1965 until 

1976 [Ref. 17, pp. 6, 8; 18, p. 5; 19, pp. 13-14; 20, pp. 14-16, 49, 63; 30, p. 3]. In addition, there are other reported 

instances of mercury-containing wastewater and stormwater discharging from the Troy Chemical facility into 

Pierson’s Creek after connection to the PVSC sewer system [Ref. 18, pp. 5, 12-21]. During an inspection on April 

28, 1980, NJDEP reported the observance of stormwater and wastewater flowing into Pierson’s Creek and its 

unnamed tributary via runoff, pipes, cracks in the creek’s concrete walls adjacent to a Troy building and tank farm, 

and overflow from Troy’s industrial wastewater collection sump [Ref. 32, pp. 1-2]. All of these liquids flowing into 

Pierson’s Creek and its tributary were found to contain mercury, including one that contained mercury droplets; 

copper, lead, arsenic, and zinc were also detected [Ref. 32, pp. 1-9]. 
 24 

SD-Hazardous Waste Quantity 

Source No.: 1 

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

The hazardous constituent quantity for Source 1 could not be adequately determined according to the HRS 

requirements; that is, the total mass of all Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) hazardous substances in the source is not known and cannot be estimated with reasonable 

confidence [Ref. 1, Section 2.4.2.1.1]. There are insufficient historical and current data (Manifests, PRP records, 

State records, Permits, Waste concentration data, etc.) available to adequately calculate the total mass of all 

CERCLA hazardous substances in the source and the associated releases from the source. Therefore, there is 

insufficient information to evaluate the associated releases from the source to calculate the hazardous constituent 

quantity for Source 1 with reasonable confidence, and hazardous constituent quantity is not scored (NS). 

Hazardous Constituent Quantity (C) Value: NS 

2.4.2.1.2 Hazardous Wastestream Quantity

The Troy Chemical facility initiated manufacture of mercury-containing products in 1957, and the facility 

discharged its mercury-bearing wastewaters directly into Pierson’s Creek until 1976 [Ref. 17, pp. 4, 6, 8, 22; 18, p. 

5; 28, p. 2; 30, pp. 1-3]. The mercuric oxide manufacturing process was reported to be the primary source of 

mercury-bearing wastewater at the facility, accounting for approximately 7,000 gallons per week [Ref. 17, p. 22; 18, 

p. 4; 30, p. 2]. Other sources that contributed additional, undisclosed quantities of mercury-bearing wastewater at 

the facility included spillage, leakage, and washing of equipment and floors in the mercuric oxide manufacturing 

operation; production of phenyl mercuric sulfide; and spills, leaks, and washings in all organic mercury compound 

manufacturing operations [Ref. 17, p. 22; 30, p. 2]. 

In addition to the facility wastewater discharges directed to Pierson’s Creek, there are other reported instances of 

mercury-containing wastewater and stormwater discharging from the Troy Chemical facility into Pierson’s Creek 

after connection to the PVSC sewer system in 1976 [Ref. 18, pp. 5, 12-21]. An inspection in July 1977 revealed 

numerous pipes discharging into the stream, none of which were depicted on the site plan for the facility [Ref. 17, 

pp. 14-15]. During an inspection on April 28, 1980, NJDEP reported the observance of stormwater and wastewater 

flowing into Pierson’s Creek and its unnamed tributary via runoff, pipes, cracks in the creek’s concrete walls 

adjacent to a Troy building and tank farm, and overflow from Troy’s industrial wastewater collection sump [Ref. 32, 

pp. 1-2]. All of these liquids flowing into Pierson’s Creek and its tributary were found to contain mercury, including 

one that contained mercury droplets; copper, lead, arsenic, and zinc were also detected [Ref. 32, pp. 1-9]. 

Based on this information, 7,000 gallons per week during the period when Troy Chemical discharged its mercurycontaining wastewater into Pierson’s Creek (1957-1976) is considered a minimum estimate of hazardous 

wastestream quantity for Source 1. This estimate accounts for only one of several wastestreams, and it does not 

account for the documented discharges that occurred after 1976. Whether a whole year of discharge occurred in the 

first year (1957) or the last year (1976) is uncertain based on the available documentation, so only full years of 

operation (1958 through 1975 – 18 years) are evaluated. Using an average of 50 operating weeks per year, the 

volume of mercury-containing wastewater discharged to Pierson’s Creek during that 18-year period would have 

been 6,300,000 gallons. HRS Table 2-5 uses a conversion rate of 2,000 pounds per 200 gallons, or 10 pounds per 

gallon [Ref. 1, Section 2.4.2.1]. Therefore, an estimated total mass of 63,000,000 pounds of mercury-containing 

wastewater were discharged into Pierson’s Creek from 1958 through 1975. The hazardous wastestream quantity in 

pounds (W) is divided by 5,000 to obtain the assigned value, as shown below [Ref. 1, Table 2-5].

Mass of source (lb): (7,000 gal/wk) x (50 wk/y) x (18 y) x (10 lb/g) = 63,000,000 lb

Hazardous Wastestream Quantity Value: 63,000,000/5,000 = 12,600 
 25 

SD-Hazardous Waste Quantity 

Source No.: 1 

2.4.2.1.3 Volume

The Tier C volume measure is not scored because the hazardous wastestream quantity for the source is estimated 

with reasonable confidence [Reference 1, Section 2.4.2.1.3]. 

Volume (V) Assigned Value: 0 

2.4.2.1.4 Area

The Tier D area measure is not evaluated for source type “other.”[Reference 1, Section 2.4.2.1.4, Table 2-5].

Area (A) Assigned Value: 0 

2.4.2.1.5 Source Hazardous Waste Quantity Value

The source hazardous waste quantity value for Source 1 is 12,600 for Tier B – Hazardous Wastestream Quantity 

[Ref. 1, Section 2.4.2].

Source Hazardous Waste Quantity Value: 12,600
 26 

SD-Summary 

SITE SUMMARY OF SOURCE DESCRIPTIONS

TABLE 1. HAZARDOUS WASTE QUANTITY AND CONTAINMENT

Source Number Source Hazardous 

Waste Quantity Value

Containment

Ground Water Surface Water Air

Gas Particulate

1 12,600 NS 10 NS NS

NS = Not Scored 

Other Possible Sources and Areas of Concern

Discarded Troysan phenylmercury acetate: In May 1979, investigators from the City of Newark, the U.S. 

Attorney’s office, and EPA discovered grayish powder dumped on the ground throughout the 338 Wilson Avenue 

property north of the Troy facility, including alongside and within the Pierson’s Creek streambed [Ref. 40, pp. 1-4; 

41, pp. 1-3; 42, p. 1; 43, pp. 4, 24]. The property was also littered with open bags labeled “Troysan”, and the 

analysis indicated that the mercury content of the product (PMA, or mercury acetate) was 12% [Ref. 40, pp. 1-4; 41, 

p. 1]. Troysan was a trade name used by Troy Chemical Corp. for many of the products manufactured at the facility, 

including PMA [Ref. 17, p. 74]. A laboratory analysis of the grayish powder that had been dumped on the ground 

indicated that it contained 0.5% mercury [Ref. 40, pp. 1, 4]. The discarded bags and grayish powder were located 

on the 338 Wilson Avenue property north of the current Troy facility, which is the address that Troy reported as its 

facility address from 1961 until 1969 [Ref. 24, pp. 85, 92, 101, 110, 119, 126, 136, 146, 156; 43, pp. 4, 24]. That is 

also the property address for the Albert Steel Drum/Prentiss Drug & Chemical (ASD/PDC) site [Ref. 43, pp. 4-5; 59, 

pp. 1], which is discussed further in Section 4.1.2.1. 

Other areas of concern: Investigations completed by Troy Chemical and by regulatory agencies have identified 

several other areas of concern related to mercury and other hazardous substances, including benzene; areas of 

concern include the former mercury recovery still (also referred to as the mercury reclamation process area), located 

along Pierson’s Creek in the southeastern corner of the facility and operational in the 1970s; the vicinity of the 

former mercury treatment system to the west of Building 56; the former septic tank on the eastern side of the site; 

and contaminated soil associated with mercury-related and other operations at several buildings [Ref. 20, pp. 16-21, 

30-36; 26, p. 2; 37, pp. 1-2]. In July 1977, the facility’s Plant Engineer informed NJDEP that the old septic system, 

which was not on the site plan provided by Troy and was being used illegally at the time, had been dye tested and 

was found to leach into the stream; the NJDEP inspectors confirmed the condition with their own dye test [Ref. 26, 

p. 2; 27, pp. 1-2]. NJDEP also observed drum storage areas without secondary containment and leakage of waste 

material from drums to the ground [Ref. 26, pp. 2, 4-5]. During an inspection of the facility in December 1979, 

NJDEP observed mercury droplets on the concrete pad and all areas surrounding the mercury recovery still, and “a 

lot of mercury” on the floor and outside concrete pad of Building 40 [Ref. 17, pp. 25-26; 31, pp. 1-2]. In January 

1984, NJDEP observed flammable brown liquid coming out of the Troy Chemical property via Pierson’s Creek, and 

observed spillage of red-brown liquid within the Troy Chemical plant [Ref. 34, pp. 1-4]. 
 27 

SWOF-Surface Water Overland Flow/Flood Migration Pathway 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

Pierson’s Creek is an approximately 1.5-mile, man-made ditch located in a heavily industrialized section of Newark 

[Figure 4; Ref. 5, pp. 6-8; 18, p. 69; 38, pp. 15-16; 48, p. 2]. For more than 100 years, the creek has been used as an 

urban stormwater drainage structure and it continues to be a component of the City of Newark's stormwater 

management system [Ref. 38, p. 15]. Historically, including at the time of mercury releases, Pierson’s Creek 

surfaced from a 36-inch stormwater culvert on the adjacent property to the north of Troy Chemical and flowed in the 

concrete channel that bisects the Troy facility; an unnamed, intermittent tributary flowed along the eastern property 

boundary and joined Pierson’s Creek just south of the facility [Ref. 17, pp. 1, 5, 7, 41; 19, pp. 3, 11, 64, 135; 22, pp. 

9-14; 38, pp. 15-16; 39, p. 29; 43, pp. 20-21; 45, pp. 9, 12]. Due to a drainage improvement project completed in 

2007 (* - see Note below), the perennial portion of Pierson’s Creek now begins just south of the Troy Chemical 

facility, where it receives stormwater runoff from a large culvert as well as the concrete channel and east ditch on 

the Troy property [Ref. 5, p. 6; 38, pp. 14-21, 80]. The probable point of entry (PPE) to surface water is this point 

just south of the Troy Chemical facility, as shown in Figure 2. 

Pierson’s Creek flows from the PPE through a series of open channels and culverts in a general south-southwesterly 

direction for approximately 1.5 miles to the Port Newark Channel portion of Newark Bay [Figure 4; Ref. 5, pp. 6-8; 

18, p. 69; 38, pp. 15-16; 48, p. 2]. Port Newark Channel is listed as the receiving waters for Troy’s 1978 National 

Pollutant Discharge Elimination System (NPDES) permit [Ref. 29, p. 1]. During the October 2012 sampling event, 

Pierson’s Creek showed signs of tidal influence from the bay, including water-level fluctuations and flow reversal 

[Ref. 5, pp. 19-40]. Troy Chemical has reported that salinity measurements collected in March 2005 showed tidal 

influence only near its discharge point to Newark Bay [Ref. 38, pp. 15]. Moving north to south, the creek flows 

through the Former Red Star property (currently occupied by Continental Hardware); the vacant, former Engelhard 

property; Conrail’s Oak Island rail yard; and private parking lots built on a former landfill within the Port of Newark 

[Ref. 5, pp. 4-8; 38, pp. 15-16]. The creek flows through these properties for approximately 1 mile before being 

routed through culverts beneath Interstate 78, Newark International Airport, and New Jersey Turnpike [Figures 3, 4; 

Ref. 18, p. 69; 38, pp. 15-16]. 

Newark Bay is part of the New York-New Jersey Harbor Estuary, which also includes Upper New York Bay, Lower 

New York Bay, and Raritan Bay; the channels that connect the bays, including Arthur Kill/Pratt Creek, Kill Van 

Kull, and The Narrows; and the tidal portions of the Hackensack River, Passaic River, and other rivers [Ref. 48, pp. 

1-2; 50, pp. 1-10, 14]. The surface water migration pathway for the Troy Chemical site extends throughout the 

coastal tidal waters of Newark Bay, Arthur Kill, Kill Van Kull, Upper New York Bay, The Narrows, and into Lower 

New York Bay, in a series of arcs through the bays and lines through the channels [Figure 4; Ref. 1, Section 4.1.1.1; 

48, p. 2]. In addition, the lower reaches of the Passaic and Hackensack Rivers are included within the target 

distance limit (TDL) because they are classified as saline estuarine waters, indicating that the tidal run could carry 

hazardous substances to upstream targets [Ref. 1, Section 4.1.1.2; 58, pp. 44, 80-85]. Due to the complexity of the 

estuary and the presence of large landmasses, there are multiple TDLs for the Troy Chem Corp Inc site, as shown in 

Figure 4 [Ref. 48, p. 2]. 

* Note: Until 2007, the northern (upper) reach of Pierson’s Creek emanated from the 36-inch box culvert, which 

received stormwater from Newark’s Ironbound District; stormwater from adjacent industrial facilities, including 

Troy Chemical, drained directly to the creek via overland flow and stormwater management structures [Ref. 38, pp. 

15-17]. In 2007, the City of Newark rerouted the stormwater drainage system to bypass the upper reach of Pierson’s 

Creek (i.e., FedEx and Troy Chemical) [Ref. 38, pp. 15-17]. The new configuration of stormwater drainage consists 

of a box culvert near the intersection of Avenue L and Wilson Avenue, which receives stormwater from the 

surrounding neighborhoods and routes it through a culvert that flows south under Avenue L and turns east at the 

southern end of Avenue L [Ref. 5, pp. 6, 8]. The culvert discharges to the open portion of Pierson’s Creek just south 

of the Troy Chemical facility [Ref. 5, pp. 6, 8]. The former northernmost reach of the creek has been buried beneath 

the Federal Express parking lot, as shown in Figure 2. 
 28 

SWOF-Observed Release 

4.1.2.1 Likelihood of Release 

4.1.2.1.1 Observed Release

An observed release to surface water is documented by direct observation and chemical analysis. 

Direct Observation

Observed release by direct observation is supported by numerous reports of mercury-containing wastewater and 

stormwater discharging from the Troy facility directly into Pierson’s Creek and its unnamed tributary [Ref. 18, pp. 

5, 12-21]. On March 25, 1977, NJDEP issued Troy Chemical a Notice of Violation and Offer of Settlement 

(NOV/OOS) indicating that waste chemicals were allowed to enter a tributary to Newark Bay; Troy settled the 

NOV/OOS as stipulated [Ref. 17, p. 11]. During an inspection on April 28, 1980, NJDEP observed stormwater and 

wastewater flowing into Pierson’s Creek and the unnamed tributary via runoff, pipes, cracks in the creek’s concrete 

walls adjacent to a Troy building and tank farm, and overflow from Troy’s industrial wastewater collection sump 

[Ref. 32, pp. 1-2]. NJDEP collected and analyzed samples C27080 (Stormwater runoff sample, flowing into a 

tributary of Pierson's Creek directly east of tank farm A), C27091 (Liquid sample, containing mercury droplets, 

collected at the same location as sample No. C27080), C27081 (Stormwater pipe flowing into Pierson's Creek), 

C27082 (Groundwater/stormwater sample flowing into Pierson's Creek through a crack in the Creek wall adjacent to 

Troy's Blue building), C27083 (Overflow from Troy's industrial wastewater collection sump; discharge was on the 

east side of Pierson's Creek approximately 50 feet downstream from the [old] locker room discharge), C27084 

(Groundwater/stormwater sample flowing into Pierson's Creek through a crack in the creek wall adjacent to Troy's 

tank farm E), and C27085 (Stormwater flowing into Pierson's Creek on the south side of Troy's maintenance 

building) [Ref. 32, pp. 1-9]. The laboratory analyses indicated the presence of mercury in all of these wastestreams 

observed flowing into Pierson’s Creek and its tributary; copper, lead, arsenic, and zinc were also detected in 

multiple samples [Ref. 32, pp. 3-9]. 

The observed release to surface water is also supported by the EPA investigation results, as described below. 

Chemical Analysis

In October 2012, EPA collected surface water and sediment samples for TAL metals and TCL organics analysis 

from the open-water segments of Pierson’s Creek along the in-water segment of the surface water migration 

pathway downstream of the Troy facility site source, and at background locations along unnamed tributaries (i.e., 

feeder streams) [Figure 3; Ref. 5, pp. 9-18; 6, pp. 3-14]. The sampling and analysis by EPA showed the presence of 

mercury at concentrations significantly above background concentrations in sediment samples collected along the 

downstream in-water segment of the surface water pathway [Figures 3, 4; see Tables below]. The observed release 

by chemical analysis is documented along the surface water migration pathway downstream of the site source, 

between the sample PC-SD25B at the PPE and sample PC-SD13B, approximately 0.25 mile downstream [Figure 3].

Notes on Sample Similarity:

Release samples were collected along the surface water migration pathway downstream of the Troy facility; 

background samples were collected from feeder streams believed to be unaffected by site sources due to not being 

downstream [Figure 3]. The background and release samples were handled the same procedurally and were similar 

physically, as follows: 

 Sampling Methods: The background and release sediment samples were all collected by EPA during the 

same sampling event in October 2012 [Figure 3; Ref. 5, pp. 9-18; 6, pp. 3-14]. Sediment samples were 

collected within the 0- to 6-inch and 12- to 18-inch depth intervals with decontaminated augers, and the 

samples were homogenized in dedicated, disposable aluminum trays with dedicated, disposable plastic 

scoops [Ref. 5, pp. 9-18, 22, 24-25, 28-31, 34, 38, 40; 6, pp. 5-11]. The sampling team maintained custody 

of the samples until shipping to the laboratory, and the samples were received by the laboratory intact and 

under custody [Ref. 6, pp. 3-6, 15-69].
 29 

SWOF-Observed Release 

 Analytical Procedures: The background and release sediment samples were analyzed for TAL metals 

including mercury by Test America Laboratories, Inc. according to the Contract Laboratory Program (CLP) 

Statement of Work (SOW) [Ref. 7, pp. 2-5; 8, pp. 2-5; 9, pp. 2-6; 10, pp. 2-5]. Reporting detection limits 

(RDL) for the results represent the increase over Quantitation Limits based on factors such as sample 

characteristics and dilution to enable quantification of target analytes [Ref. 7, pp. 71-76; 8, pp. 76-82; 9, pp. 

75-80; 10, pp. 58-61]. Therefore, the RDL for each result is considered to equate to sample quantitation 

limit (SQL), which is defined in the HRS as the quantity of a substance that can be reasonably quantified 

given the limits of detection for the methods of analysis and sample characteristics that may affect 

quantitation (for example, dilution, concentration) [Ref. 1, Sections 1.1 and 2.3]. 

 Sampling Depth: Background and release sediment samples were collected from the 0- to 6-inch or 12- to 

18-inch depth intervals within the Pierson’s Creek or unnamed tributary streambed, with the exception of 

sample PC-SD17B collected from the 12- to 14-inch depth interval; water depth at the sample locations 

ranged from 4 to 24 inches [Ref. 5, pp. 9-18, 22, 24-25, 28-31, 34, 38, 40; 6, pp. 5-11]. 

 Percent Solids: The Test America laboratory measured the percent solids of each sediment sample. 

Percent solids in the background samples ranged from 33.3% to 75.0%, and percent solids in the release 

samples ranged from 31.1% to 60.5% [Ref. 7, pp. 2, 5, 26, 28, 30, 35, 37, 40, 42; 8, pp. 2, 5, 9, 12, 29, 30, 

32, 34; 9, pp. 2, 5, 10, 13, 24; 10, pp. 2, 5, 16, 19, 27].

 Total Organic Carbon: The sediment samples were analyzed by the EPA Region 2 Laboratory for total 

organic carbon (TOC) according to method EPA 415.1mod / SOP C-88 [Ref. 11, pp. 3-5]. TOC levels in 

the background samples ranged from 18,000 mg/kg to 130,000 mg/kg, while TOC levels in the release 

samples ranged from 15,000 mg/kg to 120,000 mg/kg [Ref. 11, pp. 8-9, 11-13, 15-16, 19-20, 22-25, 28].

 Grain Size: The sediment samples were analyzed by the EPA Region 2 Laboratory for grain-size 

distribution according to method ASTM D422-63 / BIO 8.3 [Ref. 11, pp. 3-5]. The amount of fine-grained 

materials (silt, clay, and colloids) in the solid portion of background samples for which analysis is available 

ranged from 7.6% to 64.9%, and the amount of fine-grained materials in the solid portion of the release 

samples ranged from 10.6% to 61% [Ref. 11, pp. 1, 8-9, 11-13, 15-16, 19-20, 22-25, 28].

Due to these similarities (i.e., same time frames, sampling and analytical methods, and sampling depths; similar 

ranges of percent solids, TOC, and grain-size) among the background and release samples, the background and 

release analytical results are considered to be comparable. The background and observed release concentrations for 

sediment samples are presented on the following pages. 

Hazardous Substances Released:

Mercury 

Note: Mercury was detected in the majority of sediment samples collected downstream of the Troy Chemical 

facility during the October 2012 EPA sampling event; concentrations documenting an observed release are 

presented in Table 3 [Figure 3; Ref. 7, pp. 68-76; 8, pp. 76-82; 9, pp. 75-83; 10, pp. 57-62]. Other hazardous 

substances, including volatile organic compounds (VOC), semivolatile organic compounds (SVOC), pesticides, 

polychlorinated biphenyls (PCBs), and additional inorganic constituents, were detected at significant concentrations 

in sediment or surface water samples collected downstream of the Troy Chemical facility [Figure 3; Ref. 5, pp. 9-18; 

6, pp. 3-14; 7, pp. 62-77; 8, pp. 66-82; 9, pp. 67-83; 10, pp. 50-62; 12, pp. 28-217; 13, pp. 25-112; 14, pp. 30-249, 

288-382; 15, pp. 28-125]. Some of these substances might be attributable to historical releases from the facility, but 

they are not as uniquely connected to facility operations and there are other possible sources of these contaminants 

[Ref. 38, pp. 3-4, 35-42]; therefore, they are not included in scoring the site. 
 30 

SWOF-Observed Release 

Background and Observed Release Concentrations 

Sediment Samples, October 2012

TABLE 2. BACKGROUND CONCENTRATIONS *

Field Sample ID PC-SD05A PC-SD05C ** PC-SD05B PC-SD08A PC-SD08B

Inorganic CLP No. MBAKW9 MBAKX1 MBAKX0 MBAKX6 MBAKX7

Date 10/17/2012 10/17/2012 10/17/2012 10/17/2012 10/17/2012

Depth (inches) 0 - 6 0 - 6 12 - 18 0 - 6 12 – 18

% Solids 68.6 65.9 75.0 33.9 53.2

% Moisture 31.4 34.1 25.0 66.1 46.8

TOC (mg/kg) 30,000 18,000 j 27,000 94,000 j 130,000 j

Total Fines (%Silt + 

%Clay/Colloids) 7.6 15.7 10.4 No analysis 42.2 j

Reference(s) Ref. 5, p. 11; 6, 

pp. 8, 29; 11, p. 8

Ref. 5, p. 11; 6, 

pp. 8, 29; 11, p. 9

Ref. 5, p. 11; 6, 

pp. 9, 29; 11, p. 9

Ref. 5, p. 12; 6, 

pp. 9, 29; 11, pp. 1, 

11

Ref. 5, p. 12; 6, 

pp. 9, 29; 11, p. 11

Result RDL Result RDL Result RDL Result RDL Result RDL

Mercury (mg/kg) 1.9 0.13 4.0 0.3 2.6 0.24

59.4 J 

(108.70) 5.4 41.1 3.5

Reference(s) Ref. 7, pp. 26, 71 Ref. 7, pp. 30, 73 Ref. 7, pp. 28, 72 Ref. 7, pp. 5, 35, 

75; 16, pp. 1-8, 18 Ref. 7, pp. 37, 75

 mg/kg – Milligrams per kilogram 

 j – The identification of the analyte is acceptable; the reported value is an estimate [Ref. 11, p. 1]. 

 RDL – Reporting detection limit. RDLs represent the increase over Quantitation Limits based on factors such as sample characteristics and dilution to enable 

quantification of target analytes [Ref. 7, pp. 71-73, 75]. Therefore, the RDL for each result is considered to equate to sample quantitation limit (SQL), which is 

defined in the HRS as the quantity of a substance that can be reasonably quantified given the limits of detection for the methods of analysis and sample 

characteristics that may affect quantitation (for example, dilution, concentration) [Ref. 1, Sections 1.1 and 2.3]. 

 J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 7, pp. 2, 5]. These mercury results have been adjusted according to 

the EPA fact sheet "Using Qualified Data to Document an Observed Release and Observed Contamination"; adjusted values are shown in parentheses [Ref. 16, 

pp. 1-8, 18]. 

* Maximum background values (italicized) were used for determination of observed release. 

** PC-SD05A and PC-SD05C were field duplicate samples from the same location and depth [Ref. 5, p. 11; 6, p. 8]. 
 31 

SWOF-Observed Release 

Background and Observed Release Concentrations 

Sediment Samples, October 2012 (continued)

TABLE 2. BACKGROUND CONCENTRATIONS * (continued)

Field Sample ID PC-SD09A PC-SD09B PC-SD06A PC-SD06B PC-SD27A PC-SD27B

Inorganic CLP No. MBAKX8 MBAKX9 MBAKX2 MBAKX3 MBAL17 MBAL18

Date 10/17/2012 10/17/2012 10/18/2012 10/18/2012 10/18/2012 10/18/2012

Depth (inches) 0 – 6 12 - 18 0 - 6 12 – 18 0 - 6 12 - 18

% Solids 33.3 47.0 42.8 47.5 34.0 49.6

% Moisture 66.7 53.0 57.2 52.5 66.0 50.4

TOC (mg/kg) 87,000 j 130,000 j 130,000 j 66,000 110,000 110,000

Total Fines (%Silt + 

%Clay/Colloids) No analysis 33.6 j 30.4 35.2 64.9 9.2

Reference(s) Ref. 5, p. 12; 6, pp. 

9, 29; 11, pp. 1, 11

Ref. 5, p. 12; 6, 

pp. 9, 29; 11, pp. 

11-12

Ref. 5, p. 14; 6, 

pp. 9, 37; 11, p. 12

Ref. 5, p. 14; 6, 

pp. 9, 37; 11, p. 13

Ref. 5, p. 14; 6, 

pp. 9, 37; 11, p. 15

Ref. 5, p. 14; 6, 

pp. 9, 37; 11, p. 16

Result RDL Result RDL Result RDL Result RDL Result RDL Result RDL

Mercury (mg/kg) 66.4 J 

(121.51) 5.5 42.7 J (78.14) 4.1 3.1 J (5.67 ) 1.0 16.5 J (30.195)

1.9 28.7 J 

(52.52) 2.8 3.3 J (6.04) 0.2

Reference(s) Ref. 7, pp. 5, 40, 

76; 16, pp. 1-8, 18

Ref. 7, pp. 5, 42, 

76; 16, pp. 1-8, 18

Ref. 8, pp. 5, 9, 

76; 16, pp. 1-8, 18

Ref. 8, pp. 5, 12, 

76; 16, pp. 1-8, 18

Ref. 8, pp. 5, 32, 

82; 16, pp. 1-8, 18

Ref. 8, pp. 5, 34, 

82; 16, pp. 1-8, 18

 mg/kg – Milligrams per kilogram 

 j – The identification of the analyte is acceptable; the reported value is an estimate [Ref. 11, p. 1]. 

 RDL – Reporting detection limit. RDLs represent the increase over Quantitation Limits based on factors such as sample characteristics and dilution to enable 

quantification of target analytes [Ref. 7, p. 76; 8, pp. 76, 82]. Therefore, the RDL for each result is considered to equate to SQL, which is defined in the HRS as 

the quantity of a substance that can be reasonably quantified given the limits of detection for the methods of analysis and sample characteristics that may affect 

quantitation (for example, dilution, concentration) [Ref. 1, Sections 1.1 and 2.3]. 

 J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 7, pp. 2, 5; 8, pp. 2, 5]. These mercury results have been adjusted 

according to the EPA fact sheet "Using Qualified Data to Document an Observed Release and Observed Contamination"; adjusted values are shown in 

parentheses [Ref. 16, pp. 1-8, 18]. 

* Maximum background values (italicized) were used for determination of observed release. 
 32 

SWOF-Observed Release 

Background and Observed Release Concentrations 

Sediment Samples, October 2012 (continued)

TABLE 3. RELEASE CONCENTRATIONS *

Field Sample ID PC-SD13B PC-SD14A PC-SD14B PC-SD14C ** PC-SD17B

Inorganic CLP No. MBAKY7 MBAKY8 MBAKY9 MBAKZ0 MBAKZ6

Date 10/23/2012 10/23/2012 10/23/2012 10/23/2012 10/23/2012

Depth (inches) 12 - 18 0 - 6 12 - 18 12 – 18 12 - 14

% Solids 32.6 31.1 33.4 33.3 41.1

% Moisture 67.4 68.9 66.6 66.7 58.9

TOC (mg/kg) 120,000 77,000 110,000 97,000 100,000

Total Fines (%Silt + 

%Clay/Colloids) 61 j 37.2 j 49 29 50.8

Reference(s)

Ref. 5, p. 16; 6, 

pp. 10, 50; 11, p. 

23

Ref. 5, p. 16; 6, pp. 

10, 50; 11, p. 24

Ref. 5, p. 16; 6, pp. 

10, 50; 11, p. 24

Ref. 5, p. 16; 6, pp. 

10, 50; 11, p. 25

Ref. 5, pp. 16, 24; 

6, pp. 10, 52; 11, p. 

28

Result RDL Result RDL Result RDL Result RDL Result RDL

Mercury (mg/kg) 924 J 

(504.92) 50.2 694 J (379.23) 42.3 1,290 J (704.92) 95.3 1,400 J (765.03) 90.1 855 J (467.21) 48.7

Reference(s) Ref. 8, pp. 5, 29, 

80; 16, pp. 8, 18

Ref. 8, pp. 5, 30, 

81; 16, pp. 8, 18

Ref. 9, pp. 3-5, 10, 

75; 16, pp. 8, 18

Ref. 9, pp. 3-5, 13, 

76; 16, pp. 8, 18

Ref. 9, pp. 3-5, 24, 

80; 16, pp. 8, 18

 mg/kg – Milligrams per kilogram 

 j – The identification of the analyte is acceptable; the reported value is an estimate [Ref. 11, p. 1]. 

 RDL – Reporting detection limit. RDLs represent the increase over Quantitation Limits based on factors such as sample characteristics and dilution to enable 

quantification of target analytes [Ref. 8, pp. 80-81; 9, pp. 75-76, 80]. Therefore, the RDL for each result is considered to equate to SQL, which is defined in the 

HRS as the quantity of a substance that can be reasonably quantified given the limits of detection for the methods of analysis and sample characteristics that may 

affect quantitation (for example, dilution, concentration) [Ref. 1, Sections 1.1 and 2.3]. 

 J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 8, pp. 2, 5; 9, pp. 2, 5]. These mercury results have been adjusted 

according to the EPA fact sheet "Using Qualified Data to Document an Observed Release and Observed Contamination"; adjusted values are shown in 

parentheses [Ref. 16, pp. 1-8, 18]. 

* Maximum background values (italicized) were used for determination of observed release. 

** PC-SD14B and PC-SD14C were field duplicate samples from the same location and depth [Ref. 5, p. 16; 6, p. 10]. 
 33 

SWOF-Observed Release 

Background and Observed Release Concentrations 

Sediment Samples, October 2012 (continued)

TABLE 3. RELEASE CONCENTRATIONS * (continued)

Field Sample ID PC-SD23A PC-SD23B PC-SD25B

Inorganic CLP No. MBAL07 MBAL08 MBAL12

Date 10/25/2012 10/25/2012 10/25/2012

Depth (inches) 0 - 6 12 - 18 12 - 18

% Solids 47.6 50.3 60.5

% Moisture 52.4 49.7 39.5

TOC (mg/kg) 84,000 73,000 15,000

Total Fines (%Silt + 

%Clay/Colloids) 41.4 25.2 10.6

Reference(s) Ref. 5, p. 18; 6, pp. 

11, 64; 11, p. 19

Ref. 5, p. 18; 6, pp. 

11, 64; 11, p. 20

Ref. 5, p. 18; 6, pp. 

11, 64; 11, p. 22

Result RDL Result RDL Result RDL

Mercury (mg/kg) 737 J 

(402.73) 80.8 1,130 69.8 1,770 99.2

Reference(s) Ref. 10, pp. 5, 16, 

58; 16, pp. 1-8, 18 Ref. 10, pp. 19, 58 Ref. 10, pp. 27, 61

 mg/kg – Milligrams per kilogram 

 RDL – Reporting detection limit. RDLs represent the increase over Quantitation Limits based on factors such as sample characteristics and dilution to enable 

quantification of target analytes [Ref. 10, pp. 58, 61]. Therefore, the RDL for each result is considered to equate to SQL, which is defined in the HRS as the 

quantity of a substance that can be reasonably quantified given the limits of detection for the methods of analysis and sample characteristics that may affect 

quantitation (for example, dilution, concentration) [Ref. 1, Sections 1.1 and 2.3]. 

 J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 10, pp. 2, 5]. These mercury results have been adjusted according 

to the EPA fact sheet "Using Qualified Data to Document an Observed Release and Observed Contamination"; adjusted values are shown in parentheses [Ref. 

16, pp. 1-8, 18]. 

* Maximum background values (italicized) were used for determination of observed release. 
 34 

SWOF-Observed Release 

Attribution

For the Troy Chem Corp Inc site, the source under consideration is the historical disposal of mercury-containing 

wastewaters into Pierson’s Creek. The Troy Chemical facility manufactured mercury compounds from 1956 or 

1957 until 1987 [Ref. 17, p. 4, 22, 57; 18, p. 2; 19, pp. 12-14; 20, p. 14; 28, p. 2; 29, pp. 2-3, 6-7; 30, pp. 1-2; 37, p. 

1; 38, pp. 13, 29-30]. The facility discharged its mercury-bearing wastewater directly into Pierson’s Creek until 

1976, and there were additional discharges, leaks, and spills to Pierson’s Creek after the facility connected to the 

PVSC sewer system in 1976 [Ref. 17, pp. 6, 8, 14-15; 18, pp. 5, 12-21; 30, p. 3; 32, pp. 1-9; 34, p. 2]. Troy 

Chemical has considered surface water and sediment conditions in Pierson’s Creek and its unnamed tributary to be 

the principal environmental concerns associated with the site, and the company has reported that its former 

operations have contributed to the mercury detected in sediment within the concrete ditch and downstream areas of 

Pierson’s Creek [Ref. 19, p. 11; 38, pp. 59-60, 84; 39, pp. 9, 16, 29]. 

Previous investigations by Troy Chemical, NJDEP, and EPA have indicated significant increases in sediment 

mercury concentrations at and downstream of the facility compared to upstream sediment concentrations, as recently 

as 2010 [Ref. 18, pp. 12-20; 19, p. 147; 30, pp. 4-9; 33, pp. 1-2; 37, p. 12; 38, p. 84; 39, pp. 29, 32]. Some of the 

sediment and surface water sampling events were conducted when the creek originated north of the Troy Chemical 

facility and flowed through the concrete channel on the property [Ref. 18, pp. 12-20]. In July 1979, EPA collected a 

sediment sample from Pierson’s Creek just downstream of the mercury wastewater treatment system and reported a 

mercury concentration of 22,400 mg/kg, compared to upstream concentrations of 140 and 191 mg/kg; mercury was 

also detected above background in samples collected downstream of the facility [Ref. 30, pp. 4-7]. That sampling 

event occurred shortly after one of Troy Chemical’s products (Troysan PMA) was found dumped on the upstream 

property, including alongside and within the Pierson’s Creek streambed, which could have been responsible for 

upstream mercury contributions [Ref. 40, pp. 1-4; 41, pp. 1-3; 42, p. 1; 43, pp. 4, 24]. The observed release to 

Pierson’s Creek and associated wetland areas is supported by the October 2012 EPA sampling data. 

Although there are other possible sites in the vicinity of the Troy Chemical facility, the release samples show 

concentrations of mercury, a site-attributable contaminant, that are significantly above the concentrations in 

background samples [Figure 3]. Background sediment samples were collected from unnamed tributary streams that 

are also located in this heavily-industrialized section of Newark [Figure 3]. In all cases, maximum background 

concentrations were used for comparison to account for other possible contributors of mercury contamination, and 

release concentrations were significantly above these maximum background levels [see Tables 2 and 3]. Mercury 

was detected above background at other sediment sample locations downstream of the Troy Chemical facility. 

[Figure 3; Ref. 7, pp. 68-76; 8, pp. 76-82; 9, pp. 75-83; 10, pp. 57-62]. The increase in concentrations is located 

immediately downstream of the Troy Chemical facility, beginning at the PPE [Figure 3]. 

In 2010, Troy Chemical assessed other point source and non-point source contributions to sediment contamination, 

including industrial properties in the immediate vicinity of the Troy Chemical facility and Pierson’s Creek: Former 

Red Star property to the immediate south, Globe Metals property to the immediate east, Former Albert Steel 

Drum/Prentiss Drug Co. (ASD/PDC) property to the immediate north, and Former Engelhard property to the south 

of Former Red Star [Ref. 38, pp. 3-4, 35-42]. None of these properties were identified as a contributor of the 

sediment mercury contamination [Ref. 38, pp. 35-42]. Based on the assessment, Troy concluded that the historical 

information and available sediment data indicate at least a partial contribution of mercury from Troy Chemical 

operations [Ref. 38, pp. 3-4]. 

Based on these considerations, the observed release to surface water is considered to be at least partially attributable 

to the Troy Chem Corp Inc site. 

==================================================================================

Observed Release Factor Value: 550
 35 

SWOF/Food Chain-Waste Characteristics 

4.1.3.2 Human Food Chain Threat - Waste Characteristics

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

TABLE 4. TOXICITY/PERSISTENCE/BIOACCUMULATION

Hazardous 

Substance

Source 

Number

Toxicity 

Factor 

Value

River 

Persistence 

Factor 

Value*

Food Chain 

Bioaccumulation 

Factor Value**

Toxicity/Persistence/ 

Bioaccumulation Factor 

Value (HRS Table 4-16)

Ref. 2 

Page

Mercury 1 10,000 0.4 50,000 2 x 108 BI-8

* The predominant water category between the PPE and the documented fishery in Upper New York Bay is Coastal 

tidal waters; therefore, the river persistence factor value for mercury is assigned [Ref. 1, Sections 4.0.2, 4.1.2.2.1.2 

and 4.1.3.2.1.2; 2, p. BI-8]. 

** The documented fishery in Upper New York Bay is a saltwater fishery; therefore, the bioaccumulation factor 

value for salt water is assigned [Ref. 1, Section 4.1.3.2.1.3; 2, p. BI-8; 53, pp. 10, 29-30; 55, p. 1]. 

4.1.3.2.2 Hazardous Waste Quantity

TABLE 5. HAZARDOUS WASTE QUANTITY

Source Number Source Hazardous Waste Quantity 

(HWQ) Value (HRS Section 2.4.2.1.5)

Is source hazardous constituent 

quantity data complete? (yes/no)

1 12,600 No

Sum of Values: 12,600 (rounded to nearest integer as specified in HRS Section 2.4.2.2)

The sum corresponds to a hazardous waste quantity factor value of 10,000 in HRS Table 2-6 [Ref. 1, Section 

2.4.2.2]. Therefore, a hazardous waste quantity factor value of 10,000 is assigned for the surface water migration 

pathway. 

4.1.3.2.3 Waste Characteristics Factor Category Value

Mercury associated with Source 1, which has a surface water pathway containment factor value greater than 0 for 

the watershed, corresponds to a toxicity/persistence factor value of 4,000 and bioaccumulation potential factor value 

of 50,000, as shown above [Ref. 1, Section 4.1.3.2.1.4; 2, p. BI-8]. 

(Toxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 

4,000 x 10,000 = 4 x 107

[Ref. 1, Section 4.1.3.2.3] 

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x 

(Bioaccumulation Potential Factor Value) = (4 x 107) x (50,000) = 2 x 1012

 subject to a maximum of 1 x 1012

[Ref. 1, Section 4.1.3.2.3] 

The maximum value of 1 x 1012 corresponds to a waste characteristics factor category value of 1,000 in Table 2-7 of 

the HRS [Ref. 1, Section 2.4.3.1]. 

==================================================================================

Toxicity/Persistence/Bioaccumulation Factor Value: 2 x 108

Hazardous Waste Quantity Factor Value: 10,000 

Waste Characteristics Factor Category Value: 1,000 
 36 

SWOF/Food Chain-Targets/Food Chain Individual 

4.1.3.3 Human Food Chain Threat - Targets

The New York-New Jersey Harbor Estuary within the 15-mile TDL, including the Newark Bay Complex and other 

water bodies, is used for consumption fishing [Ref. 49, p. 1; 50, pp. 9, 14-16; 51,pp. 5-7]. There are fishing access 

locations to Newark Bay, Arthur Kill, Kill Van Kull, Upper New York Bay, The Narrows, and the tidal rivers that 

flow into the harbor [Figure 4; Ref. 52, pp. 18-21; 53, pp. 13-14, 29-30; 54, p. 15]. One example of a specific 

location within the TDL where consumption fishing has been reported is the 69th Street American Veterans 

Memorial Pier, located in Brooklyn along the eastern edge of Upper New York Bay [Figure 4; Ref. 53, pp. 29-30;

54, pp. 15, 22, 29; 55, p. 1]. The available documentation does not demonstrate that the fishery is located within the 

zone of contamination; therefore, the target fishery is evaluated for potential contamination [Figures 3, 4; Ref. 1, 

Section 4.1.3.3; Ref. 50, p. 14].

Samples for Observed Release/Level I/Level II Concentrations 

The sediment concentrations meet the criteria for Level II concentrations because there are no media-specific 

benchmarks for sediment [Ref. 1, Sections 2.5 and 4.1.4.3.1; 2, p. BII-8]: 

TABLE 6. SAMPLES FOR OBSERVED RELEASE

Sample ID Distance 

from PPE

Hazardous Substance Concentration

(mg/kg)

Reference(s)

PC-SD25B 0 feet Mercury 1,770 Figure 3; Ref. 10, pp. 27, 61

PC-SD23A 180 feet Mercury 737 J (402.73) Figure 3; Ref. 10, pp. 5, 16, 58; 16, 

pp. 1-8, 18

PC-SD23B 180 feet Mercury 1,130 Figure 3; Ref. 10, pp. 19, 58

PC-SD17B 700 feet Mercury 855 J (467.21) Figure 3; Ref. 9, pp. 3-5, 24, 80; 16, 

pp. 8, 18

PC-SD14A 1,150 feet Mercury 694 J (379.23) Figure 3; Ref. 8, pp. 5, 30, 81; 16, pp. 

8, 18

PC-SD14B 1,150 feet Mercury 1,290 J (704.92) Figure 3; Ref. 9, pp. 3-5, 10, 75; 16, 

pp. 8, 18

PC-SD14C 1,150 feet Mercury 1,400 J (765.03) Figure 3; Ref. 9, pp. 3-5, 13, 76; 16, 

pp. 8, 18

PC-SD13B 1,300 feet Mercury 924 J (504.92) Figure 3; Ref. 8, pp. 5, 29, 80; 16, pp. 

8, 18

J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 8, pp. 1-5; 9, pp. 1-5; 

10, pp. 1-5]. These results have been adjusted according to the EPA fact sheet "Using Qualified Data to Document 

an Observed Release and Observed Contamination"; adjusted values are shown in parentheses [Ref. 16, pp. 1-8, 

18]. 
 37 

SWOF/Food Chain Individual 

4.1.3.3.1 Food Chain Individual

There is an observed release to surface water of at least one hazardous substance (mercury) with a bioaccumulation 

potential factor value of 500 or greater and there is a fishery present within the 15-mile TDL [see Sections 4.1.2.1.1, 

4.1.3.2.1, and 4.1.3.3]. Therefore, a food chain individual factor value of 20 is assigned [Ref. 1, Section 4.1.3.3.1]. 

Sample ID: PC-SD25B, PC-SD23A. PC-SD23B, PC-SD17B, PC-SD14A, PC-SD14B, PC-SD14C, 

PC-SD13B 

Hazardous Substance: Mercury 

Bioaccumulation Potential: 50,000 

References: See Section 4.1.2.1.1 

TABLE 7. FISHERIES

Identity of Fishery Type of Surface Water 

Body

Dilution Weight Reference(s)

Upper New York Bay Coastal tidal waters 0.0001 Figure 4; Ref. 1, Table 4-

13; 49, p. 1; 50, pp. 9-10, 

14-16; 51, pp. 6-7; 53, pp. 

29-30; 54, pp. 15, 22; 55, 

p. 1

==================================================================================

Food Chain Individual Factor Value: 20
 38 

SWOF/Food Chain-Level I/Level II Concentrations/Potential Contamination 

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations

The Level I concentrations factor value is 0 because there are no fisheries subject to Level I concentrations [Ref. 1, 

Section 4.1.3.3.2.1]. 

==================================================================================

Level I Concentrations Factor Value: 0 

4.1.3.3.2.2 Level II Concentrations

The Level II concentrations factor value is 0 because there are no fisheries subject to Level II concentrations [Ref. 1, 

Section 4.1.3.3.2.2]. 

==================================================================================

Level II Concentrations Factor Value: 0 

4.1.3.3.2.3 Potential Human Food Chain Contamination

People catch fish for consumption from the New York-New Jersey Harbor Estuary within the 15-mile TDL of the 

site [Figure 4; Ref. 49, p. 1; 50, pp. 9-10, 14-16; 51, pp. 6-7; 54, pp. 4, 15]. One such specific location where 

consumption fishing has been reported is the 69th Street American Veterans Memorial Pier, located in Brooklyn 

along the eastern edge of Upper New York Bay [Ref. 53, pp. 29-30; 54, pp. 15, 22, 29; 55, p. 1]. The fish 

consumption rate for the downstream fishery is not documented but known to be greater than zero, so the fishery is 

assigned to the category “Greater than 0 to 100 pounds per year,” which corresponds to the assigned human food 

chain population value of 0.03 in Table 4-18 of the HRS [Ref. 1, Section 4.1.3.3.2; Ref. 52, pp. 18-21; 53, pp. 13-14, 

29-30; 54, p. 15, 22, 29; 55, p. 1]. The available documentation from the October 2012 EPA sampling event 

indicates that the fishery is located within the TDL but does not demonstrate precisely that the fishery is located 

within the zone of contamination associated with the Troy site; therefore, the target fishery is evaluated for potential 

human food chain contamination [Figures 2, 4; Ref. 1, Section 4.1.3.3; Ref. 50, p. 14; 54, p. 15; 55, p. 1]. Previous 

studies have shown that mercury affects the sediments of Newark Bay, but those data are not considered here for 

evaluation [Ref. 57, pp. 28-39].

TABLE 8. POTENTIAL HUMAN FOOD CHAIN CONTAMINATION

Identity of Annual Type of Surface Average Population Dilution Pi x Di

Fishery Production Water Body Annual Flow Value (Pi) Weight (Di)

(Pounds) (Table 4-13) (cfs) (Table 4-18) (Table 4-13)

NY-NJ Harbor Greater than Coastal tidal N/A 0.03 0.0001 0.000003

Estuary 0 waters

Sum of Pi x Di: 0.000003 

(Sum of Pi x Di)/10: 0.0000003

==================================================================================

Potential Human Food Chain Contamination Factor Value: 0.0000003
 39 

SWOF/Environment-Hazardous Waste Characteristics 

4.1.4.2 Environmental Threat - Waste Characteristics

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

TABLE 9. ECOTOXICITY/PERSISTENCE/BIOACCUMULATION

Hazardous 

Substance

Source 

Number

Ecotoxicity 

Factor Value

Persistence 

Factor 

Value *

Ecosystem

Bioaccumulation 

Factor Value **

Ecotoxicity/Persistence/ 

Bioaccumulation Factor 

Value (HRS Table 4-21)

Ref. 2 

Page

Mercury 1 10,000 0.4 50,000 2 x 108 BI-8

* The predominant water category between the PPE and the nearest sensitive environment (i.e., wetlands along 

Pierson’s Creek) is River; therefore, the river persistence factor value is assigned [Ref. 1, Sections 4.1.2.2.1.2 and 

4.1.4.2.1.2; 2, p. BI-8]. 

** The sensitive environments being evaluated are in fresh water (Pierson’s Creek), brackish water (NY-NJ Harbor 

Estuary – Newark Bay), and salt water (NY-NJ Harbor Estuary – Arthur Kill, Kill Van Kull, Upper New York Bay) 

[Figure 4; Ref. 38, pp. 14-15, 84, 90; 53, pp. 10, 14-15, 29-30; 56, p. 5]. The environment bioaccumulation factor 

value for both fresh and salt water is 50,000, which is assigned as the ecosystem bioaccumulation factor value [Ref. 

1, Section 4.1.3.2.1.3 and 4.1.4.2.1.3; 2, p. BI-8] 

4.1.4.2.2 Hazardous Waste Quantity

TABLE 10. HAZARDOUS WASTE QUANTITY

Source Number Source Hazardous Waste Quantity 

(HWQ) Value (HRS Section 2.4.2.1.5)

Is source hazardous constituent 

quantity data complete? (yes/no)

1 12,600 No

Sum of Values: 12,600 (rounded to nearest integer as specified in HRS Section 2.4.2.2)

The sum corresponds to a hazardous waste quantity factor value of 10,000 in HRS Table 2-6 [Ref. 1, Section 

2.4.2.2]. Therefore, a hazardous waste quantity factor value of 10,000 is assigned for the surface water migration 

pathway. 

4.1.4.2.3 Waste Characteristics Factor Category Value

Mercury associated with Source 1, which has a surface water pathway containment factor value greater than 0 for 

the watershed, corresponds to an ecotoxicity/persistence factor value of 4,000 and bioaccumulation potential factor 

value of 50,000, as shown above [Ref. 1, Section 4.1.3.2.1.4; 2, p. BI-8]. 

 (Ecotoxicity/persistence factor value) x (hazardous waste quantity factor value) = 

4,000 x 10,000 = 4 x 107

[Ref. 1, Section 4.1.4.2.3] 

(Ecotoxicity/persistence factor value x hazardous waste quantity factor value) x 

(bioaccumulation potential factor value) = (4 x 107) x (50,000) = 2 x 1012 subject to a maximum of 1 x 1012

[Ref. 1, Section 4.1.4.2.3] 

The maximum value of 1 x 1012 corresponds to a waste characteristics factor category value of 1,000 in Table 2-7 of 

the HRS [Ref. 1, Section 2.4.3.1]. 

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 2 x 108

Hazardous Waste Quantity Factor Value: 10,000

 Waste Characteristics Factor Category Value: 1,000 
 40 

SWOF/Environment-Targets 

4.1.4.3 Environmental Threat - Targets

The zone of contamination (i.e., area where observed release by chemical analysis is documented) along the surface 

water migration pathway downstream of the site source extends from the PPE at sample location PC-SD25B south 

to sample location PC-SD13B approximately 0.25 mile downstream [Figure 3; see Section 4.1.2.1.1]. There are 

HRS-eligible wetlands along the zone of contamination, and the total wetland frontage considered as subject to 

actual contamination is approximately 0.15 mile [Figures 2, 3; Ref. 1, Section 4.1.4.3.1; 5, pp. 43-62]. There are no 

media-specific benchmarks for sediment, so the target wetlands are subject to Level II concentrations [Ref. 1, 

Sections 2.5 and 4.1.4.3; 2, pp. BII-8].

Newark Bay is part of the New York-New Jersey Harbor Estuary, which is a sensitive area identified under the 

National Estuary Program [Ref. 51, pp. 1-10]. The available documentation does not demonstrate that the estuary is 

located within the zone of contamination; therefore, this sensitive environment is evaluated as subject to potential 

contamination [Figures 2, 4; Ref. 1, Sections 4.1.1.2 and 4.1.4.3].

Samples for Observed Release/Level I/Level II Concentrations 

The sediment concentrations meet the criteria for Level II concentrations because there are no media-specific 

benchmarks for sediment [Ref. 1, Sections 2.5 and 4.1.4.3.1; 2, p. BII-8]:

TABLE 11. SAMPLES FOR OBSERVED RELEASE

Sample ID Distance 

from PPE

Hazardous Substance Concentration

(mg/kg)

Reference(s)

PC-SD25B 0 feet Mercury 1,770 Figure 3; Ref. 10, pp. 27, 61

PC-SD23A 180 feet Mercury 737 J (402.73) Figure 3; Ref. 10, pp. 5, 16, 58; 16, 

pp. 1-8, 18

PC-SD23B 180 feet Mercury 1,130 Figure 3; Ref. 10, pp. 19, 58

PC-SD17B 700 feet Mercury 855 J (467.21) Figure 3; Ref. 9, pp. 3-5, 24, 80; 16, 

pp. 8, 18

PC-SD14A 1,150 feet Mercury 694 J (379.23) Figure 3; Ref. 8, pp. 5, 30, 81; 16, pp. 

8, 18

PC-SD14B 1,150 feet Mercury 1,290 J (704.92) Figure 3; Ref. 9, pp. 3-5, 10, 75; 16, 

pp. 8, 18

PC-SD14C 1,150 feet Mercury 1,400 J (765.03) Figure 3; Ref. 9, pp. 3-5, 13, 76; 16, 

pp. 8, 18

PC-SD13B 1,300 feet Mercury 924 J (504.92) Figure 3; Ref. 8, pp. 5, 29, 80; 16, pp. 

8, 18

J – This flag indicates that the result qualified as estimated; direction of bias is unknown [Ref. 8, pp. 1-5; 9, pp. 1-5; 

10, pp. 1-5]. These results have been adjusted according to the EPA fact sheet "Using Qualified Data to Document 

an Observed Release and Observed Contamination"; adjusted values are shown in parentheses [Ref. 16, pp. 1-8, 

18]. 
 41 

SWOF/Environment-Level I/Level II Concentrations 

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

The Level I concentrations factor value is 0 because there are no sensitive environments subject to Level I 

concentrations [Ref. 1, Section 4.1.4.3.1.1]. 

==================================================================================

 Level I Concentrations Factor Value: 0 

4.1.4.3.1.2 Level II Concentrations

There are no media-specific benchmarks for sediment, so the target wetlands are subject to Level II concentrations 

[Figures 3, 4; Ref. 1, Sections 2.5 and 4.1.4.3; 2, p. BII-8].

Sensitive Environments 

There are currently no known sensitive environments other than wetlands that are considered as subject to Level II 

concentrations [Figures 3, 4; Ref. 1, Section 4.1.4.3]. 

Wetlands

There are HRS-eligible wetlands along the zone of contamination, and the total wetland frontage subject to actual 

contamination is approximately 0.15 mile [Figure 3; Ref. 1, Section 4.1.4.3.1; Ref. 5, pp. 43-62]. 

TABLE 12. LEVEL II CONCENTRATIONS – WETLANDS

Wetland Wetland Frontage Wetlands Rating Value 

(HRS Table 4-24)

Reference

Pierson’s Creek 0.15 mile 25 Figures 2, 3; Ref. 5, pp. 

43-62

Wetland Value: 25

Sum of Sensitive Environments Value + Wetland Value: 25

==================================================================================

Level II Concentrations Factor Value: 25
 42 

SWOF/Environment-Potential Contamination 

4.1.4.3.1.3 Potential Contamination

Sensitive Environments

Newark Bay is part of the New York-New Jersey Harbor Estuary, which is a sensitive area identified under the 

National Estuary Program [Ref. 51, pp. 1-10]. 

TABLE 13. POTENTIAL CONTAMINATION – SENSITIVE ENVIRONMENTS

Type of Surface 

Water Body

Sensitive Environment References Sensitive Environment Rating 

Value (HRS Table 4-23)

Coastal Tidal Waters NY-NJ Harbor Estuary (sensitive 

area identified under National 

Estuary Program)

Figure 4; Ref. 51, 

pp. 1-10

100

Sum of Sensitive Environment Values (Sj) = 100 [Figure 4; Ref. 1, Table 4-23; 51, pp. 1-10] 

Wetlands

Although the most recent National Wetlands Inventory (NWI) information available from U.S. Fish and Wildlife 

Service (USFWS) indicates that there are approximately 29 miles of wetland frontage within the TDL [Figure 4; 

Ref. 48, pp. 1-2], the wetland frontage value (Wj) is not scored. 

Potential Contamination Factor Value (SP)

TABLE 14. POTENTIAL CONTAMINATION FACTOR VALUE

Type of Surface 

Water Body

Dilution Weight 

(Dj) from HRS 

Table 4-13

Sum of Sensitive 

Environment 

Values (Sj)

Wetland Frontage 

Value (Wj)

Potential 

Contamination 

Factor Value

([Wj + Sj]*Dj) / 10

Coastal Tidal Waters 

(NY-NJ Harbor 

Estuary)

0.0001 100 Not scored 0.001

The potential contamination factor value is 0.001 [Figure 4; Ref. 1, Tables 4-13, 4-23, and 4-24]. 

==================================================================================

Potential Contamination Factor Value: 0.001