Here are answers to many of the Frequently Asked Questions regarding the Pilot Test on Impoundments 1 and 2 at the American Cyanamid Superfund Site.
What are the materials in Impoundments 1 and 2 and how did the material get there?
Impoundments 1 and 2 were used between 1947 through 1965 to store acid tar waste, a by-product of a coal/light-oil refining process conducted at the Site. Over time, through gravity, this material has separated into primarily two layers; a viscous-rubbery tar-like material and a hard-crumbly granular material. The materials are characterized by low pH and the presence of volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs), including benzene, toluene, xylenes, and naphthalene.
What is the Impoundment 1 and 2 pilot test?
The pilot test is a common approach in the environmental remediation industry that is designed to help evaluate the effectiveness of promising remediation technologies on a small section of Impoundment 2 material under actual conditions at the Site.
How will the pilot test be performed?
The pilot test will consist of three tests that will take place within three steel caissons or test cells. One cell will evaluate the effectiveness of thermal treatment alone, the second will evaluate stabilization/solidification alone, and the third cell will evaluate the combined effectiveness of the two technologies. The treated material will then be analyzed and the results used to determine treatment effectiveness and post-treatment disposition options.
Why are you not just moving forward with the full clean-up of the impoundments based on the previous treatability studies and bench-scale laboratory results?
Previous treatability studies and bench-scale laboratory studies have shown thermal treatment and solidification/stabilization to be promising technologies. The limiting factor has been the ability to perform the work safely in the field, including the generation of unacceptable emissions and odors. Although the methods proposed are considered to be common remedial technologies, they have never been applied in this type of setting. The pilot test is designed to treat the material under controlled conditions while it remains in the impoundments. This demonstration test will help determine if these technologies can be safely and effectively implemented on a larger scale.
Will the pilot test be safe?
The pilot test was designed with safety as the number one priority and consideration. The testing will occur within steel caissons resembling large columnar tubes that are lowered into Impoundment 2 and secured on a flexi-float platform that is essentially a small marine barge. Pilot test treatment activities will take place in-situ, within the steel caissons, minimizing exposure for workers and the community. Vapors will be treated in an air control device known as a thermal oxidizer located adjacent to the impoundment and raised out of the flood plain. Air monitoring will be conducted in the work area and at the site perimeter to verify that emissions remain under control during pilot activities. Additional safety measures (i.e. nitrogen inerting) will be taken to prevent fires and other construction related hazards.
What is the schedule for the pilot test?
Construction of the required infrastructure began in August 2013. The actual pilot testing involving the impoundment material is scheduled to occur between late 2013 and Spring 2014. This schedule could vary depending on weather and other field conditions. Updates to the schedule will be posted on AmCyRestoration.com.
Will the community see the pilot test?
The pilot test will take place primarily during the winter months when foliage is minimal. Large equipment and lights may be visible to motorists along I-287. Water vapor discharged from the air treatment system may be visible as a white condensate during the colder months.
Will the community be disrupted by delivery of trucks and equipment?
We do not anticipate any unreasonable disruption to the community as a result of the pilot test. The pilot test will use large equipment such as drilling rigs, cranes, caissons, Flexifloats, and treatment units. These materials will likely be delivered to the Site through one of two East Main Street entrances. Most deliveries will occur during standard business hours and all efforts will be made to limit community disruptions.
Will the community be impacted by air emissions during the pilot test?
The pilot test has been designed for the treatment to take place in-situ, within the impoundments, minimizing exposure for workers and the community. Vapors generated during the pilot test will be treated on-site a thermal oxidizer under NJDEP air permit requirements that will be issued by USEPA. Air monitoring will be conducted in the work area and at the site perimeter to verify that emissions remain under control during pilot activities. If air monitoring within the work area identifies emissions of concern, corrective actions will be taken, including temporary shutdown if necessary.
Is the pilot test infrastructure at risk from a flood?
The pilot test was designed to address the potential for flooding. The flexifloat structure is designed to float on top of the existing impoundments. The flexifloat will be secured by cables and anchors located outside the impoundments to hold the structure in place in the event of a severe flood.
What will happen in the case of a flood, fire or other emergency incident?
Detailed contingency plans have been developed to allow for appropriate response in adverse conditions. USEPA has reviewed the plans and local and county emergency management officials have been briefed on the site safety and emergency response procedures. In the event of a severe storm or other emergency event, the pilot test may be suspended or terminated.
Are Impoundments 1 and 2 at risk for failing during this pilot test and impacting the Raritan River?
Impoundments 1 and 2 are regularly inspected and maintained and do not pose an offsite risk. Routine inspections and recent engineering evaluations have shown that the impoundments continue to perform as designed. The equipment, infrastructure and technologies used during this pilot test do not present additional risk. The impoundment berms have been recently evaluated by a third-party engineering firm and deemed capable of withstanding earthquake and flood events.
Assuming the pilot test is successful; will these technologies definitely be used in the final remedy?
No decision has been made on the final remedy for Impoundments 1 and 2. After completion of the field pilot testing, the results of both the laboratory and field demonstration testing will be utilized to develop the FFS report. The FFS will evaluate a range of remedial options for the impoundments, that will take into consideration the remedial action objectives, treatment and ultimate disposition of the impoundment materials, the feasibility, implementability, effectiveness of the remedy (which will include consideration that the impoundments are within a floodplain), and comments from the community and other stakeholders. It is currently anticipated that a draft FFS report will be submitted to USEPA in late 2014 or early 2015.
When will a final remedy be selected?
The draft FFS report, expected to be submitted to USEPA in late 2014 or early 2015, will undergo a thorough evaluation by USEPA and its National Remedy Review Board, NJDEP and other stakeholders. Ultimately, USEPA will select a Proposed Remedy, seek input from the community, and release a Record of Decision. No timetable has been set for this decision.