### 1

September 2014 

### HAZARD RANKING SYSTEM (HRS) PACKAGE

PIE RSON’S CREEK NEWARK, NEW JERSEY

CERCLIS ID No.: NJD002144517

EPA Contract No. EP

- S5 -06 -04

TDD No. S05-0013 -11 11 -015

Document Control No. 1 673-2A-BDFA

December 2013 Revised: September 2014

Prepared for:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Prepared by: Weston Solutions, Inc. Edison, New Jersey 08837

### 2 This page has been left blank intentionally.

### 3

September 2014 HRS DOCUMENTATION RECORD

-- REVIEW COVER SHEET

Name of Site: Pierson’s Creek

Date Prepared: December 2013 Date Modified: September 2014

Contact Persons

Site Investigation: Ildefonso Acosta (212) 637- 434 4 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.

### 4 Th is page has been left blank intentionally.

### 5

September 2014 HRS DOCUMENTATION RECORD

Name of Site: Pierson’s Creek Date Prepared: December 2013

EPA ID No.: NJD002144517 Date Modified: September 2014

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 95.99 Soil Exposure Pathway Not Scored Air Pathway Not Scored

HRS SITE SCORE 47.996



### September 2014 WORKSHEET FOR COMPUTING HRS SITE SCORE

PIERSON’S CREEK

S S 2

1. Ground Water Migration Pathway Score (S gw ) Not Scored (from Table 3-1, line 13)

2a. Surface Water Overland/Flood Migration Component 95.99 9,214. 08 (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 (S

sw ) 95.99 9,214.08 Enter the larger of lines 2a and 2b as the pathway score.

3. Soil Exposure Pathway Score (S

s ) Not Scored (from Table 5-1, line 22)

4. Air Migration Pathway Score (S

a ) Not Scored (from Table 6-1, line 12)

5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a 2 9,214.08

6. HRS Site Score Divide the value on line 5

by 4 and take the square root 47.997



### September 2014

SURFACE WATER OVERLAND/FLOOD

MIGRATION COMPONENT Factor Categories & Factors

DRINKING WATER THREAT MAXIMUM

VALUE VALUE

ASSIGNED

Likelihood of Release

1.

2.

3.

4.

5. Observed Release

Potential to Release by Overland Flow

2a. Containment

2b. Runoff

2c. Distance to Surface Water 2d. Potential to Release by Overland Flow

(lines 2a [ 2b + 2c ]) Potential to Release by Flood 3a. Containment (Flood) 3b. Flood Frequency 3c. Potential to Release by Flood

(lines 3a x 3b) Potential to Release (lines 2d + 3c)

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

10

25

25

500

10

50

500

500

550 550

not scored

not scored

not scored

not scored

not scored

not scored

not scored

not scored

550

Waste Characteristics

6.

7.

8. Toxicity/Persistence

Hazardous Waste Quantity

Waste Characteristics *

*

1 00 not scored

not scored

not scored

Targets

9. Nearest Intake 10. Population

10a. Level I Concentrations

10b. Level II Concentrations

10c. Potential Contamination 10d. Population (lines 10a + 10b

11. Resources

12. Targets (lines 9 + 10d + 11) + 10c) 50

**

**

**

**

5

** not scored

not scored

not scored

not scored

not scored

not scored

not scored

13. DRINKING WATER THREAT ([lines 5 x 8 x 12]/82,500) SCORE 100 not scored

* Maximum value applies to waste characteristics category.

** Maximum value not applicable SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

PIERSON’S CREEK8



### September 2014

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

PIERSON’S CREEK

SURFACE WATER OVERLAND/FLOOD

MIGRATION COMPONENT Factor Categories & Factors

HUMAN FOOD CHAIN THREAT MAXIMUM

VALUE VALUE

ASSIGNED

Likelihood of Release

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

Waste Characteristics

15.

16.

17. Toxicity/Persistence/Bioaccumulation Hazardous Waste Quantity

Waste Characteristics *

*

1,000 5.00E+08

100

320

Targets

18.

19.

20. Food Chain Individual Population

19a. Level I Concentrations

19b. Level II Concentrations

19c. Potential Human Food Chain Contamination 19d. Population (lines 19a + 19b + 19c)

Targets (lines 18 + 19d) 50

**

**

**

**

** 20

0

0

0.0000003

0.0000003

20.0000003

21. HUMAN FOOD CHAIN THREAT ([lines 14 x 17 x 20]/82,500) SCORE 100 42.66

* Maximum value applies to waste characteristics category.

** Maximum value not applicable9



### September 2014

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

PIERSON’S CREEK

SURFACE WATER OVERLAND/FLOOD

MIGRATION COMPONENT Factor Categories & Factors

ENVIRONMENTAL THREAT MAXIMUM

VALUE VALUE

ASSIGNED

Likelihood of Release

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

Waste Characteristics

23.

24.

25. Ecosystem Toxicity/Persistence/Bioaccumulation Hazardous Waste Quantity

Waste Characteristics *

*

1,000 5.00E+08

1 00

320

Targets

26.

27. Sensitive Environments

26a. Level I Concentrations

26b. Level II Concentrations

26c. Potential Contamination

26d. Sensitive Environments

Targets (line 26d) (lines 26a + 26b + 26c) **

**

**

**

** 0

25

0.001

25 .001

25 .001

28. ENVIRONMENTAL THREAT ([lines 22 x 25 x 27]/82,500) SCORE 60 53.33

29. WATERSHED SCORE (lines 13 + 21 + 28) 100 95.99

30. SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE (S of ) 100 95.99

SURFACE WATER MIGRATION PATHWAY SCORE (S

sw ) 100 95.99

* Maximum value applies to waste characteristics category.

** Maximum value not applicable10



### September 2014 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] Updated and accessed on June 20, 2014.

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 Qu adrangle, New Jersey-New York, 7.5-minute Series (Topographic). 19 95 . [1 map]

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

, Newark,

NJ

, . Dec ember 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# MBAK Y9

. 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 s ite 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 s ite under the CLP Case # 43052, SDG # BA L 19

. November 29, 2012 . [ 1 42 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 s ite under the CLP Case # 43052, SDG # BA L31,

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 s ite under the CLP Case # 43052, SDG # BA L07

. 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: Mer cury 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 Boat er’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



### September 2014 SITE DESCRIPTION

The Pierson’s Creek

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 historic al 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 in to 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 C reek 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 the se 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 in to 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



### September 2014 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 approxima tely 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 Pierson’s Creek 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 ].FIGURE #: DATE: CLIENT NAME: PROJECT: LEGEND: TITLE: Pierson's Creek

0 500 1,000 250

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 Pierson's Creek

August 2013 1 

### Location Map

Pierson's Creek Newark, Essex County, NJP:\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



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September 2014FIGURE #: DATE: CLIENT NAME: 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 Pierson's Creek

August 2013 2 

### Historical Facility Map  3LHUVRQ
V&UHHN
Newark, Essex County, NJ 0 100 200 50

Graphic Scale In Feet 

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! ( 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.mxdFIGURE #: DATE: CLIENT NAME: PROJECT: LEGEND: TITLE: ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( ! ( !

( ! ( ! (

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! ( ! (



# ! 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 Pierson's Creek

August 2013 3 

### Surface Water Pathway Zone of Contamination

Pierson's Creek Newark, Essex County, NJ 0 400 800 200

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 BoundaryFIGURE #: DATE: CLIENT NAME: PROJECT: LEGEND: TITLE: 

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# *

# * # * # * # * # * # *

# * # * # * # *

# * # * # * # * # *

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# * # * # * # *

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# * # * # * # * # * # * # * # *

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# * # * # * # *

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# * # *

# * Facility Location

Approximate PPE

Target
Distance Limit

Target
Distance Limit

Target
Distance Limit Target

Distance Limit

Target
Distance Limit

R 2

. 502

. 5 1.25

Graphic Scale In MilesP:\SAT2\Piersons Creek\MXD\2013_08_HRS\13535_TCC_Sample_Loc_201308.mxd

EPA Pierson'sCreek

August 2013 4 

### Surface Water Migration Pathway Map

Pierson's Creek 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 ne ar 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 discharge d 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 the se 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 discharg ed 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 (former ly 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 th e 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 Apr il 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 indus trial 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



### September 2014 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 discharge s 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 thes e 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 th is 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. While discharges containing mercury are documented to have occurred from the Troy Chemical facility during this time period, the documentation contains some uncertainty on the actual quantity of mercury-bearing wastewater discharged. Therefore, the hazardous wastestream quantity value has been assigned a value of undetermined, but greater than zero [Ref. 1, Section 2.4.2.1].

Hazardous Wastestream Quantity Value: Undetermined, but greater than zero

SD-Hazardous Waste Quantity

Source No.: 125



### September 2014 2.4.2.1.3 Volume

There are insufficient historical and current data available to adequately determine the Tier C volume measure 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 eva luated 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 undetermined, but greater than zero for Tier B

– Hazardous Wastestream Quantity [Ref. 1, Section 2.4.2 ].

Source Hazardous Waste Quantity Value: Undetermined, but greater than zero26



### September 2014 SD -Summary

SITE SUMMARY OF SOURCE DESCRIPTIONS

TABLE 1. HAZARDOUS WASTE QUANTITY AND CONTAINMENT

Source Number Source Hazardous Containment Waste Quantity Value Ground Water Surface Water Air

Gas Particulate

1 >0 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 indicat ed 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 Jul y 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



### September 2014 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 C reek 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

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

proper ty ; 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 Pierson’s Creek 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 Pierson’s Creek 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; s tormwater from adjacent industrial facilities, including Troy Chemical, drain ed 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 in to 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 observ ed 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 fl ow ing 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 do wnstream from the [old] locker room discharge), C27084 (Groundwater/stormwater sample fl ow ing into Pierson's Creek through a crack in the creek wall adjacent to Troy's tank farm E), and C27085 (Stormwater fl ow ing 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 wa stestreams
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 sampl es 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 [Figure s 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

 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 SW OF-Observed Release

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

Due to the se 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.

Hazar dous 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. pp. 8, 5, p. 11; 6, 29; 11, p. 8 Ref. pp. 8, 5, p. 11; 6, 29; 11, p. 9 Ref. pp. 9, 5, p. 11; 6, 29; 11, p. 9 Ref. 5, p. 12; 6,

pp. 9 , 29; 11, p p

. 1,

11 Ref. pp. 9, 5, p. 12; 6, 29; 11, p. 11

Result R D L Result RDL Result RDL Result RDL Result RDL

Mercury (mg/kg) 1.9 0.1 3 4.0 0.3 2.6 0.2 4 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 analyte s [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 ( it alicized ) 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) + N o analysis 33.6 j 30.4 35.2 64.9 9.2

Reference(s) Ref. 5, p. 9, 29; 11, 12; 6, pp. 1, pp. 11 Ref. 5, p. 12; 6, pp. 9, 29; 11, pp.

11

- 12 Ref. pp. 9, 5, p. 14; 6, 37; 11, p. 12 Ref. pp. 9, 5, p. 14; 6, 37; 11, p. 13 Ref. pp. 9, 5, p. 14; 6, 37; 11, p. 15 Ref. pp. 9, 5, p. 14; 6, 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 (30.19 5 ) 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]. The se 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

- SD13 B PC

- SD 14A PC

- SD 14B PC

- SD 14C ** PC

- SD 17 B

Inorganic CLP No. MBAK Y7 MBAK Y8 MBAK Y9 MBAK Z0 MBAK Z6

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

- 1 4

% 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, p p . 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) 4 8.7

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

qu antification 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. 11, 5, p. 18; 6, pp.

64 ; 11, p. 19 Ref. 11, 5, p. 18; 6, pp. 64; 11, p. 20 Ref. 11, 5, p. 18; 6, pp. 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]. The se 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



### September 2014 SWOF-Observed Release

Attribution

For the Pierson’s Creek site , the source under consideration is the historical disposal of mercury-containing

wastewater s 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 direct ly 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]. Th at 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 supp orted 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 Pierson’s Creek site

.

================================================================================== Observed Release Factor Value: 55035



### September 2014 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

Fa ctor Value ** Toxicity/Persistence/

Bioaccumulation Factor Value ( HRS Table 4

- 16) Ref. 2 Page Mercury 1 10,000 1 50,000 5 x 10 8 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 quantity hazardous constituent data complete? (yes/no)

1 >0 No

Sum of Values: 1 (rounded to nearest integer as specified in HRS Section 2.4.2.2 )

The hazardous constituent quantity for the source has not been adequately determined. The hazardous waste quantity is undetermined, but greater than zero. According to Section 2.4.2.2 of the HRS (Ref. 1, p. 51592), if any target for the migration pathway under consideration is subject to Level I (or Level II) concentrations, assign either the value from Table 2-6 (Ref. 1, p. 51591) or a value of 100, whichever is greater, as the hazardous waste quantity factor value for that pathway. Because Level II concentrations are present in an HRS eligible wetland, a hazardous waste quantity factor value of 100 is assigned. Hazardous Waste Quantity Factor Value: 100 (Ref. 1, Table 2-6, p. 51591)

4.1.3.2.3 Waste Characteristics Factor Category Value

Mercury associated with Source 1, which ha s a surface water pathway containment factor value greater than 0 for the watershed, corresponds to a toxicity/persistence factor value of 10 ,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) = 10 ,000 x 100 = 1 x 10 6

[Ref. 1, Section 4.1.3.2.3]

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potential Factor Value) = (1 x 10 6 ) x (50,000) = 5 x 10 1 0 subject to a maximum of 1 x 10 12

[Ref. 1, Section 4.1.3.2.3]

The value of 5 x 10 1 0 corresponds to a waste characteristics factor category value of 320 in Table 2- 7 of the HRS [Ref. 1, Section 2.4.3.1].

================================================================================== Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8

Hazardous Waste Quantity Factor Value: 100 Waste Characteristics Factor Category Value: 32036

4.1.3.3 Human Food Chain Threat - Targets

The New York-New Jersey Harbor Estuary within the 15-mile TD L, 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 69 th 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 Conc entration ( 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. pp. 1

- 8, 18 10, pp. 5, 16, 58; 16,

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. pp. 8, 18 9, pp. 3

- 5, 24, 80; 16,

PC

- SD14A 1,150 feet Mercury 694 J (379.23) Figure 3 ; Ref. 8, 18 8, pp. 5, 30, 81; 16, pp.

PC

- SD14B 1,150 feet Mercury 1,290 J (704.92) Figure 3 ; Ref. pp. 8, 18 9, pp. 3

- 5, 10, 75; 16,

PC

- SD14C 1,150 feet Mercury 1,400 J (765.03) Figure 3 ; Ref. pp. 8, 18 9, pp. 3

- 5, 13, 76; 16,

PC

- SD13B 1,300 feet Mercury 924 J (504.92) Figure 3 ; Ref. 8, 18 8, pp. 5, 29, 80; 16, pp.

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]. SWOF/Food Chain-Targets /F ood Chain Individual37 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 f ood 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 Dilution Weight Reference(s) Body Upper New York Bay Coastal tidal water s 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: 2038



### September 2014 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 69 th 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 f ood 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 Pierson’s Creek 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 P i x D i

Fishery Production Water Body Annual Flow Value (P i ) Weight (D i ) (Pounds) (Table 4

- 1 3 ) (cfs) (Table 4

- 1 8 ) (Table 4

- 1 3 )

NY

- NJ Harbor Greater than Coastal tidal N/A 0.03 0.0001 0.00 0003 Estuary 0 waters

Sum of P i x D i : 0.000003 (Sum of P i x D i )/10: 0.0000003

================================================================================== Potential Human Food Chain Contamination Factor Value: 0.000000339



### September 2014 SWOF/Environment-Hazardous Waste Characteristics

4.1.4.2 Environmental Threat - Waste Characteristics

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

TABLE 9 . ECOT OXICITY/PERSISTENCE/BIOACCUMULATION

Hazardous

Substance Source

Number Ecot oxicity

Factor Value Persistence

Factor

Value * E cosystem

Bioaccumulation

Fa ctor Value ** Ecot oxicity/Persistence/

Bioaccum ulation Factor Value ( HRS Table 4

- 21 ) Ref. 2 Page Mercury 1 10,000 1 50,000 5 x 10 8 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 Harbo r 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 1 0

. HAZARDOUS WASTE QUANTITY

Source Number Source Hazardous Waste Quantity (HWQ) Value ( HRS Section 2.4.2.1.5 ) Is source quantity hazardous constituent data complete? (yes/no)

1 >0 No

Sum of Values: 1 (rounded to nearest integer as specified in HRS Section 2.4.2.2 )

The hazardous constituent quantity for the source has not been adequately determined. The hazardous waste quantity is undetermined, but greater than zero. According to Section 2.4.2.2 of the HRS (Ref. 1, p. 51592), if any target for the migration pathway under consideration is subject to Level I (or Level II) concentrations, assign either the value from Table 2-6 (Ref. 1, p. 51591) or a value of 100, whichever is greater, as the hazardous waste quantity factor value for that pathway. Because Level II concentrations are present in an HRS eligible wetland, a hazardous waste quantity factor value of 100 is assigned. Hazardous Waste Quantity Factor Value: 100 (Ref. 1, Table 2-6, p. 51591) 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 10 ,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) =

10 ,000 x 10 0 = 1 x 10 6

[Ref. 1, Section 4.1.4.2.3]

(Ecotoxicity/persistence factor value x hazardous waste quantity factor value) x (bioaccumulation potential factor value) = (1 x 10 6 ) x (50,000) = 5 x 10 1 0 subject to a maximum of 1 x 10 12

[Ref. 1, Section 4.1.4.2.3]

The value of 5 x 10 1 0 corresponds to a waste characteristics factor category value of 320 in Table 2- 7 of the HRS [Ref. 1, Section 2.4.3.1].

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8
Hazardous Waste Quantity Factor Value: 100 Waste Characteristics Factor Category Value: 32 040

4.1.4.3 Environmental Threat - Targets

The zone of contamination (i.e., area where observed release by chemical analysis is docu SWOF/Environment-Targets

mented) 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 -SD13 B approximately 0.25 mile downstream [Figure 3; see Section 4.1.2.1.1]. There are

HRS-eli gible 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, th is sensitive environment is evaluated as subject to potential contamination [Figure s 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 1 1

. SAMPLES FOR OBSERVED RELEASE Sample ID Distance

from PPE Hazardous Substance Conc entration ( mg/kg) Reference(s)

PC

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

PC

- SD23A 1 80 feet Mercury 737 J (402.73) Figure 3 ; Ref. pp. 1

- 8, 18 10, pp. 5, 16, 58; 16,

PC

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

PC

- SD17B 7 00 feet Mercury 855 J (467.21) Figure 3 ; Ref. pp. 8, 18 9, pp. 3

- 5, 24, 80; 16,

PC

- SD14A 1

, 15 0 feet Mercury 694 J (379.23) Figure 3 ; Ref. 8, 18 8, pp. 5, 30, 81; 16, pp.

PC

- SD14B 1,150 feet Mercury 1,290 J (704.92) Figure 3 ; Ref. pp. 8, 18 9, pp. 3

- 5, 10, 75; 16,

PC

- SD14C 1,150 feet Mercury 1,400 J (765.03) Figure 3 ; Ref. pp. 8, 18 9, pp. 3

- 5, 13, 76; 16,

PC

- SD13B 1,300 feet Mercury 924 J (504.92) Figure 3 ; Ref. 8, 18 8, pp. 5, 29, 80; 16, pp.

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 1 2

. LEVEL II CONCENTRATIONS

– WETLANDS

Wetland Wetland Frontage Wetlands Rating Value (HRS Table 4

- 24) Reference

Pierson’s Creek 0.15 mile 25 Figures

43

- 62 2, 3; Ref. 5, pp.

Wetland Value: 25

Sum of Sensitive Environments Value + Wetland Value: 25

================================================================================== Level II Concentrations Factor Value: 2542 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 1 3 . 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,

p p. 1

- 10 100

Sum of Sensitive Environment Values (S j ) = 1 00 [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 (W j ) is not scored.

Potential Contamination Factor Value (SP)

TABLE 1 4

. POTENTIAL CONTAMINATION FACTOR VALUE Type of Surface Dilution Weight Sum of Sensitive Wetland Frontage Potential Water Body ( D j ) from HRS Environment Value (W j ) Contamination

Table 4

- 13 Values (S j ) Factor Value ([ W j + S j ]*D j ) / 10

Coastal Tidal Waters 0.0001 100 Not scored 0.00 1 (NY

- NJ Harbor Estuary)

The potential c on tamination factor value is 0.001 [Figure 4; Ref. 1, Tables 4-13, 4- 23

, and 4- 24 ].

================================================================================== Potential Contamination Factor Value: 0.001