TAIT Group Site Remediation: for Proposed Mixed-Housing Redevelopment Proposed By: Lukas Brummer, Ryan Fahy, Karen

Foster, and Steven Dennis Date: 3/21/2014 Course #: ENVL-4446-001 Class: Remediation and Biotechnology

2 Introduction: Two sites owned by the TAIT Group will be remediateddue to suspected and known contamination of arsenic and/or lead. The TAIT Group is considering selling both properties to a developer for the construction of mixed housing, and thus before any construction begins, testing/sampling as well as a clean-up (remediation) of the sites must occur.

Site #1 (Previous Lead-Arsenate Pesticide Manufacturing Plant) Site Background: This site was formerly a lead-arsenate pesticide manufacturing plant. The plant closed last year after the owner's guilt that more than 99% of all (the TAIT Groups) applied pesticides do not reach their targets. It was discovered that over the course of time that the plant was in operation, some employees had buried scores of drums of expired pesticides in the back of the plant (within disposal pits). Lastly, it is suspected that numerous spills have occurred on many parts of the companys property overtime. Since this site was a former lead-arsenate (PbHAsO4) pesticide manufacturing plant, the remedial processes will focus on the clean-up of lead and arsenic contamination. This is especially the case, because some of the plants contents were improperly disposed of, poorly maintained, as well as the plants poor clean-up practice(s). Site Assessment: A study known as a site assessment was used to determine the extent of contamination at and around the site, and to evaluate any potential health and environmental impacts/threats. This assessment can also coincide with what is known as a Remedial Investigation/Feasibility Study (RI/FS), which would investigate soil, sediment, surface water, and groundwater conditions affected by past activities at the site owned by the TAIT Group. During the assessment, conditions on and around the property were observed. Any necessary modes of documentation (i.e. photographs) would be used to determine the locations of the plants building(s)/structure(s), as well as any other important aspects about the property: 1. The site contains buried drums within disposal pits, and has a history of spills. 2. The assessment of contaminants, lead-arsenate (lead and arsenic), is necessary to determine any and all levels of the current concentrations. 3. Testing was executed to evaluate the nature of the cleanup: a. Test the soils for physical/chemical properties and contaminant concentrations. b. Determine the groundwater level and any contaminant concentrations. c. Determine any nearby water body distances and contaminant concentrations (if applicable) within the water and sediments. d. (Optional) Conduct a biological survey of the site and any nearby water bodies to determine the ecological impacts.

3 Sampling Results (Findings): 1. The soil is identified as meeting the sandy loam characteristiccomposed mostly of kaolinite, has very little organic matter, and has a pH approximately of 5.6. It is important to note: a.) This particular type of soil most likely has a Cation Exchange Capacity (CEC) which has a moderate to small capacity for cations held by a unit weight of soil. This would mean that the soil will have to be extensively analyzed for the concentrations of the contaminants (of a cation nature). It is possible that cations could reach the groundwateras a result of low soil fertility/low CEC. However, it is our inclination that lead (a cation) should still be retained (mostly) within the soil. This retention may cause lead concentrations to be at a level over the NJDEPs Residential Direct Contact Soil Clean-up Criteria (RDCSCC) of 400ppmthus, prompting remediation. (This clean-up criterion was used because of proposed housing) (N.J.A.C., 2012; Soil, 1999). b.) The physical/chemical properties of soil make it so that any forms of lead (Pb), in the soil, (as a result of chemical reactions in the environment)should be retained mostly, instead of infiltrating straight to the groundwater. This is the case because lead is a cation. Lead typically has very poor mobility within soil, and usually stays within the surface region where it was depositedtypically within 1-2 feet (Peryea, 2001). c.) These same soil properties would make any forms of arsenic (As), (i.e. Arsenate AsO43- ; Arsenite AsO33), in the soil, (as a result of chemical reactions in the environment)to be poorly retained and infiltrate straight to the groundwater. This is the case because arsenic is an anion. Arsenic in soil is much more soluble and mobile than lead (especially in sandy soils), thus why infiltration to the groundwater is of concern (Peryea, 2001). If any arsenic was retained in the soil it would most likely not be greater than the NJDEPs Residential Direct Contact Soil Clean-up Criteria (RDCSCC) of 20ppm. (This clean-up criterion was used because of proposed housing) (N.J.A.C., 2012; Peryea, 2001; Soil, 1999). 2. The groundwater is shallow at the site, with an average depth of 15 feet. It is important to note: a.) Concentrations of arsenic (via lead-arsenate) will most likely be above water quality standards/criteria (10ppbpossibly 3-5ppb depending on state sanctioned site analysis)thus, prompting remediation (N.J.A.C., 2012; Soil, 1999). As noted before, arsenic will infiltrate the groundwater because of its own properties and the soil properties. 3. There is a nearby water body, a river, located about 500 yards away from the manufacturing plant. Due to the land gradient, it is possible that contaminated groundwater has been infiltrating into the river. It is important to note: a.) That this water body will not be the focus of this remediation proposal, however it is an important aspect, which would require further testing. This is the case, because

4 surface water and/or sediment within the river could be contaminated with lead and/or arsenic (via lead-arsenate).

4.) Based on evidence that there is likely contamination of the soil and groundwater, a biological survey would not need to be conducted right away, because contamination is present, but ecological conditions should return to normal following remediation. Thus, for the purpose of this remediation proposal we will not evaluate any biological survey. However, following the completion of the proposed remediation proposal, a biological survey could ensure that contamination levels in the environment have receded (particularly in the nearby river). Potential Health/Ecological Risks: Since the findings show that there is most likely soil and water contamination above the determined safe standards/criteria for lead and arsenic there are potential health and ecological risks. It is important to note: 1. People could be exposed to contaminants through the soil, any surface water, and if they were to come in contact with the groundwater. The groundwater is also of concern because areas in New Jersey depend of the groundwater/aquifers as drinking water (via wells). The sites current condition also allows for particulate matter (dust) that could be contaminated, to be inhaled by anybody on or near the site. a.) The (EPA) determines that lead (Pb) is most harmful to young children (less than seven years old), although adults can still be at risk. In children, lead poisoning can lead to: damage to the brain and nervous system, behavioral problems, anemia, liver and kidney damage, hearing loss, hyperactivity, developmental delays, and in extreme cases, death. In adults, lead poising can lead to: poor muscle coordination, nerve damage, increased blood pressure, hearing/vision impairment, and reproductive problems (i.e. decreased sperm count and poor fetal development in a suspecting mother) (Human Health, 2013). b.) The (EPA) has classified inorganic arsenic as a Group Ahuman carcinogen. There are acute effects such as nausea, abdominal pain, and other body aches. Also, there are known chronic effects which affect the skin and mucous membranes (Arsenic, 2013). 2. There are ecological risks such as deer which could live and forage around the site. Wildlife could be exposed to the lead and arsenic through the soil, dust, any surface water, as well as groundwater. Endangered and threatened species (i.e. Northern pine snake) could also be at risk from the contamination.

Remediation Action(s) Proposal: 1. Remediation will begin with the removal of the buried drums and transport to a hazardous waste facility. The drums will be treated as hazardous waste and will be placed and transported in lined-dumpsters. The initial phase of the soil remediation begins with the removal of the buried drums (on-site) which are a source of lead (Pb) and arsenic (As) contamination. 2. Any buildings and structures will be demolished and then sorted into normal waste (for recycle) and hazardous waste (for disposal). Any hazardous waste will be transported in lined dumpsters to a hazardous waste facility. The soils under the buildings where manufacturing and handling of the contaminants took place is likely to be contaminated (along with soil throughout the site). Demolition of the buildings is essential, because of that fact, as well as the proposed new housing that is to be built on the site. Preliminary testing methods revealed that the groundwater and soil contamination is suspected and should be remediated by these methods 3. A key step in this sites remediation is the treatment of groundwater (which is at an average depth of 15 feet below the surface). The groundwater has been determined to likely be contaminated with arsenic (As), along with the possibility of minor lead contamination. The most cost-effective and efficient way to approach this is through an on-site pump and treatment system. Treated water (which is determined safe) can be pumped down-gradient to the nearby river. Contaminated waste water will be handled in regards to state DEP oversight and recommendations. Suspected plumes of contaminants (via samplings), which are located in the groundwater beneath the soilsare within the confines of the sites contaminated area(s). Clean-up of the groundwater is a key step in the remediation, because the soil type/properties have enabled the migration of contaminants (specifically arsenic, which is soluble and mobile in soil) into the groundwater. Groundwater will be remediated to meet arsenic water quality standards/criteria of 10ppb (possibly 3-5ppb depending on a state sanctioned site analysis). Also, if there was any lead contamination in the groundwater, it should meet the water quality standard/criteria of 15ppb (possibly 5ppb depending on a state sanctioned site analysis) (N.J.A.C., 2012; Soil, 1999; Vineland, 2012). 4. Soils are determined to likely be contaminated with lead (Pb), with possible trace concentrations of arsenic (As). As noted before, lead in the soil should be retained mostly, instead of infiltrating straight to the groundwater. This is because lead typically has very poor mobility within soil and stays usually within the surface region, where it was deposited. Due to this soil contamination, there can be the implementation of a soil-separation process, coupled with a soil washing process. (This can take place on-site or off-site, depending on which method is deemed more cost-effective at the time). The soils will first be separated through a sieve, the clay and organic particles will then be sent to the scrubbing (wash) unit, and clean soil (mostly sand) will be separated and can be used as backfill soil at this site or elsewheregravel will also be separated. Soils will be remediated to meet the NJDEPs Residential Direct Contact Soil Cleanup Criteria (RDCSCC) of 400ppm for lead and 20ppm for arsenic (N.J.A.C., 2012; Soil, 1999; Vineland, 2012).

6 5. If determined later on (contingent upon results from additional testing) that surface water (i.e. the nearby river) and its sediments are of concern, then treatment through excavation and soil/sediment washing can be conducted. This would be a similar process to the soil washing used for the main soil on the site, and it could take place at the on-site treatment facility. The water itself would most likely clean itself overtime (a moving water body), once the pending sediment/soil treatment is finalized. Ecological and environmental impact studies would also be a part of this remediation step. The remedial action proposed is (at this time) the best available and most cost-effective strategythus why it was chosen. However, there could be alternatives that include, but not limited to: Remedial Action Alternatives Alternative 1No action. This alternative is listed as a baseline for comparison only. It will not be used because it does not address the contamination and potential exposures to humans and wildlife. Alternative 2After the removal of solid wastes, focus would be on the soil remediation or groundwater remediation. The focus would be made, based on which remediation technique provides the best option to minimize contamination, as well as potential exposures to humans and wildlife. Site #2 (Previous Lead-Battery Production Centerformerly a Skeet Shooting Range) Site Background: This is a 10-acre site, which has a lead-battery production center on its premises. This site (prior to the production center) used to be a skeet shooting range. Over the course of the shooting ranges operation, it is suspected that more than 100-tons of lead shot are on that site. Since this site has had various uses (both involving lead (Pb)), the remedial processes will focus on the clean-up of lead contamination. There are no records of the lead-battery production centers actions, however the lead being used at the production center could have escaped and contaminated soil at various points in time. Soil is already suspected of lead contamination, as a result of the 100-tons of lead shot that are on the site from the former shooting rangeso any lead released from the production center will be treated the same as lead from the lead shot. There are other chemical additives involved in lead-battery production, but the remedial processes, will once again, focus on the clean-up of only lead contamination.

7 Site Assessment: A study known as a site assessment was used to determine the extent of contamination at and around the site, and to evaluate any potential health and environmental impacts/threats. This assessment can also coincide with what is known as a Remedial Investigation/Feasibility Study (RI/FS), which would investigate soil, sediment, surface water, and groundwater conditions affected by past activities at the site owned by the TAIT Group. During the assessment, conditions on and around the property were observed. Any necessary modes of documentation (i.e. photographs) would be used to determine the locations of the plants building(s)/structure(s), as well as any other important aspects about the property: 1. The site contains 100-tons of lead shot and a lead-battery production center. 2. The assessment of the contaminant (lead) is necessary to determine any and all levels of the current concentrations. 3. Testing was executed to evaluate the nature of the cleanup: a. Test the soils for physical/chemical properties and contaminant concentrations. b. Determine the groundwater level and any contaminant concentrations. c. Determine any nearby water body distances and contaminant concentrations (if applicable) within the water and sediments. d. (Optional) Conduct a biological survey of the site and any nearby water bodies to determine the ecological impacts. Sampling Results (Findings): 1. The soil is identified as a typical Pinelands soil. It is important to note: a.) This particular type of soil most likely has a Cation Exchange Capacity (CEC) which has a moderate capacity for cations held by a unit weight of soil. This would mean that any lead (Pb)a cationthat was deposited on the soils surface would be suspected to be within (retained) by the soil. It is unlikely that lead could reach the groundwateras a result of moderate CEC. Lead that is retained within the soil could possibly be at a level over the NJDEPs Residential Direct Contact Soil Cleanup Criteria (RDCSCC) of 400ppmthus, prompting remediation. (This clean-up criterion was used because of proposed housing) (N.J.A.C., 2012; Soil, 1999). b.) The physical/chemical properties of soil make it so that any forms of lead (Pb), in the soil, (as a result of chemical reactions in the environment)should be mostly (or all) retained, instead of infiltrating straight to the groundwater. This is the case because lead is a cation. Lead typically has very poor mobility within soil, and usually stays within the surface region where it was depositedtypically within 1-2 feet (Peryea, 2001).

8 2. Due to lead being retained by soil, any lead contamination should not be impactful to groundwater or any surface water. Further testing should confirm this notion. 3. Based on evidence that there is likely only contamination of the soil, a biological survey is not deemed necessary, as ecological conditions should return to normal following remediation. Potential Health/Ecological Risks: Since the findings show that there is most likely soil contamination above the determined safe standards/criteria for lead there are potential health and ecological risks. It is important to note: 1. People could be exposed to contaminants through the soil and any surface water (after rain). The sites current condition also allows for particulate matter (dust) that could be contaminated, to be inhaled by anybody on or near the site. a.) The (EPA) determines that lead (Pb) is most harmful to young children (less than seven years old), although adults can still be at risk. In children, lead poisoning can lead to: damage to the brain and nervous system, behavioral problems, anemia, liver and kidney damage, hearing loss, hyperactivity, developmental delays, and in extreme cases, death. In adults, lead poising can lead to: poor muscle coordination, nerve damage, increased blood pressure, hearing/vision impairment, and reproductive problems (i.e. decreased sperm count and poor fetal development in a suspecting mother) (Human Health, 2013). 2. There are ecological risks such as deer which could live and forage around the site. Wildlife could be exposed to the lead through the soil, dust and any surface water (after rain). Endangered and threatened species (i.e. Northern pine snake) could also be at risk from the contamination. Remediation Action(s) Proposal: 1. Remediation will begin with the demolition of any buildings and structures on site and the ruble will be sorted into normal waste (for recycle) and hazardous waste (for disposal). Any hazardous waste will be transported in lined dumpsters to a hazardous waste facility. The soil under the buildings where manufacturing and handling of the contaminant (lead) took place is likely to be contaminated (along with soil throughout the site). Demolition of the buildings is essential, because of that fact, as well as the proposed new housing that is to be built on the site. 2. The main remedial action is that soil contaminated with lead (Pb) will be excavated. Following sampling of soil for lead concentrations on the 10-acre site, areas of concern will be identified. Those areas are where excavation will take place to a depth of 6-10 feetsince most lead is retained in the first 1-2 feet of the soil areas it was deposited in. This will be conducted carefullyas to not spread any lead beyond the areas that are undergoing excavation. a.) The recovered soil/lead shot will be stored temporarily on-site in sealed containers that do not allow for any rainfall infiltration. b.) Contaminated soil will then be transported to an off-site hazardous waste facility.

9 c.) Records will be kept of all soil that is excavated and the amounts received by the hazardous waste facility. d.) Groundwater will be monitored throughout the excavation process to determine if leaching/infiltration is taking place, due to exposed/tilled soils while excavation is ongoing. e.) Following all excavation, testing will be done to confirm that soils were remediated to meet the NJDEPs Residential Direct Contact Soil Cleanup Criteria (RDCSCC) of 400ppm for lead (N.J.A.C., 2012; Soil, 1999). f.) Following all excavation and final testing, clean soils (backfill) will be dumped back onto the excavation sites to fill the holes made from excavation. The remedial action proposed is (at this time) the best available and most cost-effective strategythus why it was chosen. However, there could be alternatives that include, but not limited to: Remedial Action Alternatives Alternative 1No action. This alternative is listed as a baseline for comparison only. It will not be used because it does not address the lead contamination and potential exposures to humans and wildlife. Alternative 2Excavate shallow soil, recover soil/lead shot, consolidate the contaminated soils on-site, and cap with clean soil. This alternative was not chosen because it did not remove all the contaminated soil from the site.

Conclusion/Summary: Two sites owned by the TAIT Group will be remediateddue to suspected and known contamination of arsenic and/or lead. Since, the TAIT Group is considering selling both properties to a developer for the construction of mixed housing, clean-up is necessary for these areas. Before any construction begins, testing/sampling as well as a clean-up (remediation) of the sites must occur. This is essential for the well-being of those who will eventually live in housing on the properties. The two sites have been analyzed and proposed remedial actions have been providedbased on clean-up standards/criteria and cost-effectiveness.

10 References Arsenic Compounds. (2013, October 18). Retrieved from http://www.epa.gov/ttn/atw/hlthef/arsenic.html Human Health and Lead. (2013, November 25). Retrieved from http://www.epa.gov/superfund/lead/health.htm N.J.A.C. 7:26D Remediation Standards. (2012, May 7). Retrieved from http://www.state.nj.us/dep/srp/regs/rs/ Peryea, F.J. (2001, July). Gardening on Lead- and Arsenic-Contaminated Soils. Retrieved from http://www.ecy.wa.gov/programs/tcp/area_wide/aw/appk_gardening_guide.pdf Soil Cleanup Criteria (mg/kg). (1999, May 12). Retrieved from http://www.nj.gov/dep/srp/guidance/scc/#g Vineland Chemical Co., Inc. (2012, February 14). Retrieved from http://www.epa.gov/region2/superfund/npl/0200209c.pdf