Tier 3 Report for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority

Transcription

1 Tier 3 Report for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority Prepared for: PCB Subcommittee of the New Jersey Harbor Dischargers Group Judy Spadone, Linden Roselle Sewerage Authority 5005 South Wood Ave Linden, NJ Bridget McKenna, Passaic Valley Sewerage Commissioners 600 Wilson Ave. Newark, NJ And the New Jersey Harbor Dischargers Group Prepared by: Aquatic Sciences Consulting (ASC) John Botts, Principal Scientist Bushy Park Road Woodbine, MD July 28, 2006

2 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 2 Executive Summary The New Jersey Harbor Dischargers Group (NJHDG) initiated a pilot study at the Linden Roselle Sewerage Authority (LRSA) in March 2001 to evaluate an approach for tracking polychlorinated biphenyls (PCBs) and determine if it is possible to identify and reduce significant PCB sources at LRSA. Monitoring of the main sewer lines throughout LRSA s sewer system 1 (Phase III) found elevated PCB levels in the western portion of the sewer system and, potentially, the northeastern portion of the sewer system. Phase IV efforts have focused on the western sewershed (Figure 1), where it was anticipated that the PCB source(s) may be more easily located because it is a well-defined, relatively isolated area (NJHDG 2004a). The PCB contribution from the northeast area has also been assessed by monitoring reference locations. All three tiers planned for Phase IV have been completed. The results of the first tier were presented in Tier 1 Report/Tier 2 Plan for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority (May 19, 2005). Results for the second tier were reported in Tier 2 Report/Tier 3 Plan for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority. The findings of the third and final tier are summarized herein. Accepted methods of sampling (whole water composites and grabs) and PCB analysis [high resolution gas chromatography with low resolution mass spectrometry (HRGC/LRMS)] were applied to isolate PCB source(s) to a smaller area in LRSA s western sewershed (Figure 2). Recent flow data were used to determine which locations had the highest PCB loadings. Information on PCB activities and contamination in the area of concern was also gathered from public records and industrial dischargers. Additionally, a sample collected from a newly sewered residential area was analyzed to evaluate the background contribution of PCBs in domestic wastewater. In addition to the sewer trackdown, information on the contribution of PCBs from atmospheric deposition was gathered and reviewed. Samples from potential sources were also collected and analyzed for PCBs. The findings were used to evaluate the potential for accumulation of atmospheric PCBs on land and surface water and their potential transport to LRSA s sewer. Summary of Tier 3 Findings Trackdown Results for both sampling rounds in Tier 3 exhibit similar patterns in PCB concentrations along LRSA s western sewer line (Figures 3 and 4). Manhole MK had, by far, the highest total PCB concentrations (630 and 462 ng/l) of the sampling locations. The 1 The sewer system is owned and maintained by the cities of Linden and Roselle.

3 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 3 Round 1 result was one of the highest PCB levels observed in LRSA sewer water samples collected to date (NJHDG 2004b, 2005, 2006). The next highest total PCB concentrations for Tier 3 were observed downstream at Manholes RLD and SM. Total PCB levels at Manhole SM ( ng/l) were lower than the Tier 2 concentrations ( ng/l; NJHDG 2006). Total PCB concentrations at Manhole 7B were similarly lower in Tier 3 (36-38 ng/l) than in Tier 2 ( ng/l). The Tier 2 PCB levels at Manhole 7B were similar to those observed in Tier 1 ( ng/l). A review of precipitation records indicates greater rainfall prior to and during Tier 3 compared to Tiers 1 and 2. As would be expected, total suspended solids (TSS) concentrations of sewer samples collected during these periods appeared to be inversely correlated with rainfall (i.e., higher TSS levels in Tiers 1 and 2 compared to Tier 3). Given the affinity of PCBs for solids, the lower PCB concentrations at Manholes 7B and SM in Tier 3 compared to Tiers 1 and/or 2 may be related to the frequency and/or magnitude of rainfall. Potential contributing sources to the western sewer line between Manholes 7B and MK were monitored (i.e., Industry A, B and C s process and/or storm water flows and a tributary sewer sampled at Manhole GMQ as shown in Figure 2). As shown in Figure 4, Industry A s discharge was one of three inputs that exhibited total PCB concentrations (44 ng/l in Round 2) that were greater than those observed at the study reference location, the Borough of Roselle s Flume (17-30 ng/l in Tier 1; NJHDG 2005). PCB concentrations in Industry A s discharge appear to be influenced by PCBs in the industry s dry weather flow (97 ng/l in Round 2), which combines with Industry A s process flow before discharge. The dry weather flow originates from a storm water containment basin where dry and wet weather flows are segregated for discharge to LRSA s sewer and Kings Creek, respectively. As shown in Figure 3, total PCB concentrations in the Round 1 dry weather sample were five-fold lower than in Round 2 (19 ng/l) and the Industry A discharge had correspondingly lower total PCB levels in Round 1 (5 ng/l). Manhole GMQ was another location that exhibited total PCB concentrations (150 ng/l in Round 1) higher than the reference level at Roselle Flume. The results for Rounds 1 and 2 were variable (i.e., 8 ng/l total PCBs for Round 2). The water samples did not include discharge from Industries B and C as the tributary sewer was diverted upstream at Manhole FCP in April 2005 (more than eight months before Tier 3 sampling). The sampled water may have contained infiltration and inflow (I & I) and/or residual discharge from Industries B and C remaining in the sewer since April PCB concentrations in Industry B s and C s current discharge and Industry B s storm water basin were <4 ng/l; therefore, it is unlikely that relatively recent industrial discharges contributed to the PCB levels observed downstream at Manhole GMQ. The Round 1 result indicates the presence of PCBs from past activities.

4 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 4 Relatively low PCB concentrations at Manhole FCP (7.9 ng/l), which marks the beginning of the tributary sewer diversion, suggest that residual PCBs are not present upstream of the diversion (Figure 5). However, only a single data point was obtained and, given the variability observed at Manhole GMQ, the absence of PCBs can not be confirmed. The third input with PCB levels higher than the Roselle Flume reference level was the storm water collected in the Manhole RLD insert (Figure 5). Both water and sediment concentrations of total PCBs in the storm water (i.e., 420 ng/l and 140 ng/g) were higher than water and sediment PCB levels observed at the Roselle Flume reference location (17-30 ng/l and 71 ng/g, respectively, in dry weather; NJHDG 2005). It is not known if these results may be representative of storm water elsewhere in the LRSA s service area; however, the total PCB concentrations at Manhole RLD are significant. Given the potential for storm water to enter sanitary sewers through infiltration or cross connection, the contribution of PCBs from storm water is a concern that warrants further investigation. The storm water insert results were compared to data for the main western sewer line. The total PCB level in the water portion of the storm water insert sample was in the range of total PCB levels observed in the main western sewer. The total PCB concentration in the sediment portion of the sample was lower than the levels found in the western sewer at the nearby Manhole SM (16, ,000 ng/g in Tier 2; NJHDG 2006). Although the storm water may be a source of PCBs found in the western sewer, it is not possible to estimate the magnitude of the PCB contribution (i.e., loading) without knowing the volume of water and sediment that infiltrates Manhole RLD or other manholes in the area of concern. This information should be gathered as part of a further investigation of storm water sources of PCBs. In an effort to minimize the PCB discharge, LRSA is replacing the oversized cover at Manhole RLD. PCB loading estimates were calculated based on flow data obtained in Tier 2 for Manholes 7B and SM (NJHDG 2006) and industry flow rates monitored or estimated during Tier 3 sampling. The loading estimates are shown in Figures 6 and 7. The sum of the total PCB loadings from Manholes 7B and GMQ and Industry A s discharge ( g/day) accounts for less than 15% of the total PCB loading at the next downstream location, Manhole MK ( g/day). Tiers 1 and 2 results indicate that a significant portion of the water PCB concentration, and hence loading, can be influenced by PCB levels in the underlying sediment in the sewer (NJHDG 2005, 2006). Although Manhole MK was not sampled for sediment, its presence was confirmed, and if it contained high PCB levels, the sediment may have contributed to the PCBs observed in the water samples. Further downstream at Manholes RLD and SM, total PCB loadings decreased more than five-fold to g/day. The cause of this decrease is unknown. Nonetheless, the results indicate that the primary source(s) of PCBs is upstream of Manhole SM between Manholes MK and 7B. The results also suggest that neither

5 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 5 Industry A nor the tributary sewer sampled at Manhole GMQ is a significant, current source of the PCBs observed in the main western sewer. The trackdown objective stated in the quality assurance project plan (QAPP) is to identify sources in LRSA s western sewershed that contribute total PCB concentrations that are more than 3 to 6-fold higher than the levels observed at the western sewershed terminus (NJHDG 2004a). This objective was also interpreted to apply to PCB loadings as well as concentrations (NJHDG 2006). In Tier 3, Manhole MK exhibited PCB concentrations and loadings that were about 6 to 7-fold higher than those observed at the downstream boundary of the area of concern (Manhole SM). Therefore, the objective was met and, by definition, the PCB source(s) are located at or upstream of Manhole MK and downstream of Manhole 7B. PCB homolog distributions were compared between sampling locations to further evaluate the PCB source(s) between Manholes 7B and MK. As shown in Figure 8, PCBs with a higher level of chlorination (i.e., tetra, penta and hexa chlorinated biphenyls) were present in the Round 2 sample of Industry A s dry weather flow than in the Round 1 sample (tri, tetra and penta chlorinated biphenyls). As expected, this pattern was reflected to some extent in the Industry A discharge samples for Rounds 1 and 2 (Figure 9). The homolog distributions also indicate that Industry A s dry weather flow is not the primary contributor of PCBs to the western sewer line as lower chlorinated biphenyls, which are indicative of Aroclors 1016, 1242 and 1254, are predominant at Manholes MK, RLD and SM (see Figure 10). Storm water entering Manhole RLD also does not appear to be a primary contributor of PCBs in the western sewer. Higher chlorinated biphenyls (hexa, penta, hepta) were present in the storm water insert sample (both water and sediment) than in the western sewer (Figure 11). As shown in Figure 12, the homolog distribution for the Round 1 Manhole GMQ sample is generally similar to the homolog distribution observed at Manholes MK, RLD and SM. These results indicate that the sewer accessed by Manhole GMQ may have been a source of the PCBs observed downstream at Manholes MK, RLD, SM, as well as Manholes SCP and 8 in Tier 2. Although flow is no longer discharged through Manhole GMQ, it is conceivable the tributary sewer may have contributed more substantial PCB loadings in the past. High levels of PCBs observed in the sediment at Manhole SM (total PCBs up to 181,000 ng/g in Tier 2) may indicate residual contamination from past activities. Industry B reported PCB contamination at two locations at its facility; however, the PCB type (Aroclor 1254) does not match the predominant Aroclors 1016/1242 in the western sewer line at Manholes MK, RLD and SM. A review of sewer maps also indicated no current pathway for PCBs to enter LRSA s sewer. Therefore, the source of PCBs at Manhole GMQ is unknown. Unidentified PCB source(s) may be located along the western sewer line between Manholes 7B and MK. For example, it was learned that an 18-inch sanitary sewer, which originates from the southwest end of West Elizabeth Ave, ties into the western sewer

6 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 6 below Manhole 7B (see Figure 2). Also, a review of public records identified four PCB contaminated properties in LRSA s western sewershed. All of the properties are located above the upstream boundary of the area of concern (Manhole 7B). However, contamination from one property reportedly migrated offsite to an area adjacent to the railroad, which is downstream of Manhole 7B (see Figure 2). The predominant PCB type in the contaminated area is Aroclor 1242, which matches the type observed in the western sanitary sewer. However, the pathway for the PCB contamination to the sewer has not yet been defined; therefore, this site is not a confirmed source. A whole water sample was collected from a newly sewered, residential area near Linden, NJ, that is reportedly not affected by I & I. The total PCB concentration of 10.8 ng/l in the sample indicates that substantial PCB levels may be contributed from purely domestic wastewater. This PCB concentration may represent a large portion of the total PCB levels observed at LRSA s study reference location (i.e., ng/l at Roselle Flume), which receives residential/commercial flow. Comparable PCB data on urban residential wastewater are limited. No PCBs were detected in pump station samples collected in Delaware County (DELCORA 2005); however, the pump stations receive commercial/ industrial flows, which may dilute PCBs from residential areas. Contribution of Atmospheric PCB Deposition The fate and transport of atmospheric PCBs is not easily understood and, as stated in the QAPP (NJHDG 2004a), NJHDG does not intend to study this question in detail. A review of existing air deposition data indicated the likelihood of a net accumulation of atmospheric PCBs on land or surface water (NJHDG 2006). Precipitation can wash deposited chemicals off of urban surfaces and runoff can convey them to storm sewers or surface waters (Labencki et al, in press). A literature review performed by the Delaware River Basin Commission (DRBC 2003) indicated that total PCB concentrations in urban runoff may average 62 ng/l. Although LRSA has separate sanitary and storm water sewer systems, storm water may enter sanitary sewers through cross connections or infiltration. Therefore, it is possible that PCB contaminated runoff is conveyed to the wastewater treatment plant (WWTP). Sources that may convey air-deposited PCBs to LRSA s sewers include (1) surface water that is collected as potable water and subsequently used and discharged to the sewer, (2) storm water runoff that washes PCBs off impervious surfaces and, by cross connection or I & I, into sewers and (3) groundwater that may infiltrate sewers (NJHDG 2004a). Existing PCB data for potable water and groundwater were initially reviewed to determine if the results were suitable. The local water supply company, New Jersey American Water (NJAW, formerly Elizabethtown Water Company), was contacted regarding available PCB data for potable water. Although data provided by NJAW showed no detectible PCBs, the reporting limits were relatively high ( ppb by Aroclor). Therefore, a composite sample of potable water samples from ten NJHDG WWTPs was prepared and analyzed by HRGC/high resolution mass spectrometry

7 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 7 (HRMS). The total PCB concentration in the sample was 0.49 ng/l, which is nearly two orders of magnitude lower than the total PCB concentrations observed at the sewer reference location, Roselle Flume (17-30 ng/l in Tier 1). Although the potable water result is a single data point and the sample may not be representative of the raw water supply in the service areas of NJHDG WWTPs, the result indicates that potable water is not a significant source of PCBs. As noted, the manhole insert results indicate a potential for significant contribution of PCBs from storm water. Additional sampling is recommended to determine if the results are representative of storm water elsewhere in the LRSA service area. More data are forthcoming on storm water. Storm water samples were to be collected in a presumed uncontaminated area in the Borough of Roselle. However, weather conditions have not been favorable and sample collection has been deferred to Phase V. In 2003, a groundwater sample was collected and analyzed as part of an application for discharge from construction of the city of Linden s flood control sewer, which is located in the vicinity of the area of concern (Figure 2). The sample contained 10.8 ng/l total PCBs. Although the PCB concentrations were relatively high, the results indicate that groundwater collected near the flood control sewer is not a significant contributor of PCBs to the area of concern. Phase V Plan The QAPP states that a PCB reduction plan will be developed based on the Phase IV findings. However, the PCB source(s) have not yet been identified. The NJHDG will review the Phase IV results and submit a plan for completing the trackdown.

8 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 8 1. Introduction EPA requested the assistance of the NJHDG in evaluating approaches for tracking sources of PCBs at municipal WWTPs (EPA 1995). LRSA was selected as a study site for a pilot PCB trackdown study. After initial EPA participation (Phases I and II), the NJHDG implemented the trackdown phase of the study in March The objectives of the study are to evaluate an approach for tracking PCBs and determine if it is possible to identify and reduce significant PCB sources at LRSA. It is anticipated that the study findings will be helpful in designing future trackdown efforts in the New Jersey/New York Harbor. 1.1 Phase III The pilot study was planned as a phased effort in which the results of each phase will be used to design the scope for subsequent phases. Upon completion of the QAPP for Phases I and II and an initial sampling effort by EPA (Phase II), the NJHDG began tracking PCBs in the main sewer lines and influent waste streams at LRSA using two available sampling methods (Phase III). The Phase III results (NJHDG 2002) provided a basis for further isolating PCB sources in Phase IV. Elevated PCB levels were consistently found in the western portion of the LRSA sewer system, a well-defined, relatively isolated sewershed, and, potentially, the northeastern portion of the sewer system, which is less well-defined with multiple tributary sewers to LRSA s main trunk line. As shown in Figure 1, the western sewershed boundary is at Manhole 8 and the northeast sewershed is located between Roselle Flume and Manhole T. Given that an original purpose of the study was to evaluate the utility of PCB trackdown, the NJHDG planned to focus its Phase IV efforts in the western sewershed, where PCB sources may be more easily located. The PCB contribution from the northeast area is also being assessed by monitoring reference locations Phase IV Phase IV was planned as a step-wise study. Three sampling tiers were envisioned to isolate the PCB sources to smaller and smaller sections of the sewer system until the contaminated properties or discharges are identified Tier 1 The Tier 1 results show that the area between Manhole 7B and Manhole 8 is the predominant contributor of PCBs (NJHDG 2005). Total PCB levels in whole water 2 Reference sites are located above and below the northeastern sewershed (i.e., Roselle Flume and Manhole T).

9 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 9 samples from Manholes 7B and 8 (122 and 157 ng/l average) were 4 to 7 times higher than at the reference location at Roselle Flume (24 ng/l average). 3 Industrial discharges to the western sewer line increased the flow by about 100% between Manholes 7B and 8. When flow rates are considered, Manhole 8 was found to have more than twice the total PCB loading (average of 1.7 g/day) than Manhole 7B (average of 0.6 g/day). The PCB loading from Manhole 8 represents the majority of the 1.8 g/day loading to the LRSA WWTP as measured at Manhole T3 and the Relief Line (RL). These results indicate a predominant PCB source(s) in the service area between Manholes 7B and 8. Elevated PCB levels were also observed in the sewer line that serves the northern part of the western sewershed (Manhole W-NE). As part of the Tier 1 trackdown, lower cost sampling and analytical tools were evaluated as alternatives to the conventional methods of whole water composite collection and GC/MS. Grab samples of sewer sediment were analyzed by both HRGC/LRMS and enzyme linked-immunosorbent assay (immunoassay). The results showed very good agreement as indicated by a correlation coefficient (R 2 ) of However, inconsistencies between whole water and sediment results suggest that trackdown by immunoassay of sediment alone may be uncertain. Sediment was envisioned as a suitable sample for immunoassay because PCB concentrations are above immunoassay s relatively high minimum detection level (whole water concentrations are too low). In an effort to continue using immunoassay as a tracking tool and obtain more consistent data, the Tier 2 plan called for using whole water settleable solids as an alternative sample to sediment. Further sediment sampling was also planned because of the good agreement between water and sediment PCB results in the area of concern (Manhole 7B to Manhole 8) Tier 2 Samples were collected from several points in the area of concern between Manholes 7B and 8 as well as in the upstream portion of the western sewershed. Although results were variable between sampling rounds, water PCB concentrations at a manholes upstream of Manhole 8 at Smith St (Manhole SM) and the Airport Plaza Shopping Center (Manhole SCP), were higher than those a Manhole 7B. When real-time flow data were considered, results for both sampling rounds showed a pattern of higher PCB loadings at Manholes SM, SCP and 8 compared to Manhole 7B. The difference in PCB loadings (2 to 6-fold) was larger than the difference in PCB concentrations (1.1 to 4-fold) because of the addition of substantial flow from industries that discharge between Manholes 7B and SM. The trackdown objective of identifying sources that contribute total PCB concentrations that are more than 3 to 6-fold higher than the levels observed at the western sewershed 3 The trackdown objective was to identify sources in the western sewershed that contribute total PCB concentrations that are more than 3 to 6 fold higher than the levels observed at western sewershed terminus. A significant source is defined according to the results for the previous study phase (Phase III), which showed total PCB concentrations in the western sewershed to be about 3 to 6 fold higher than the levels observed at Roselle Flume, a largely residential/ commercial area.

10 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 10 [boundary] (NJHDG 2004a) was interpreted to apply to PCB loadings. Therefore, the loading results were interpreted as indicating a significant PCB source between Manholes 7B and SM. Elevated PCB concentrations at one manhole (ELM) upstream of Manhole 7B appeared to be related to relatively high PCB levels in the underlying sediment. The average distribution of PCB congeners (homologs) in whole water samples from Manhole ELM indicated a predominance of Aroclor Downstream, the pattern shifted to a greater abundance of penta, tetra and hexa-chlorinated biphenyls at Manhole 7B. As the flow continues to Manhole SM, lower chlorinated biphenyls ( tetra, penta and tri-chlorinated biphenyls), which indicated the presence of Aroclors 1016/1242 and 1254, were more prevalent. These results provided further evidence for a PCB source in the vicinity of Manholes 7B and SM that dominates the downstream PCB homolog pattern. Total PCB concentrations in sewer sediment were more than one to two orders of magnitude higher at Manhole SM (i.e., 11.8 to >100 ppm by immunoassay) than at other sampling locations (406 1,067 ppm). These results provided further evidence of a PCB source in the vicinity of Manhole SM. Immunoassay results were correlated with HRGC/LRMS results (R 2 of 0.86 for Tiers 1 and 2 data). However, inconsistencies between whole water results and settleable solids and sediment results confirmed that PCB trackdown by immunoassay alone may be misleading (NJHDG 2005). Other data indicated good agreement between water and sediment PCB results in the area of concern (Manhole 7B to Manhole 8). Nonetheless, there is uncertainty about whether or not sediments characterize local conditions as they may be transported over relatively long distances in the sewer Tier 3 All known inputs and several manholes on the main western sewer line were sampled in the area of concern between Manholes 7B and SM. As shown in Figure 2, whole water samples were collected from the discharges of three industrial users, a sewer tributary to the western sewer line and two manholes (Manholes MK and RLD) located on the main sewer line between Manholes 7B and SM. The samples were analyzed by the preferred analytical tool, HRGC/LRMS. It was anticipated that the results would indicate the source(s) of PCBs on the western sewer line. In addition, a sample was collected from a newly sewered residential area to evaluate the background contribution of PCBs in domestic wastewater.

11 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 11 In addition to the sewer trackdown, the NJHDG initiated an evaluation of the contribution of PCBs by atmospheric deposition. Sources that may convey air-deposited PCBs to LRSA s sewers include (1) surface water that is collected as potable water and subsequently used and discharged to the sewer, (2) storm water runoff that washes PCBs off impervious surfaces and, by cross connection or I & I, into sewers and (3) groundwater that may infiltrate sewers (NJHDG 2004a). Existing data on these sources was reviewed and samples were collected and analyzed for PCBs. Assuming the PCB source(s) are located, a plan for reducing PCBs is to be prepared and implemented in Phase V.

12 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Methods Samples of whole water and one sediment sample were collected from the area of concern in LRSA s western sanitary sewer system. A domestic wastewater sample was collected from a residential area near Linden, NJ (Township A) and potable water was taken from taps at the WWTPs of NJHDG members. The water samples were analyzed for PCB congeners and TSS. A single sediment sample was analyzed for PCB congeners. Sanitary sewer sampling was performed in two sampling rounds: January and January 25 26, Other locations were sampled once in successive months (February May, 2006). Flow measurements were not taken during this period; however, it was anticipated that the flow data collected in Tier 2 (June 2005) were current to Tier 3 and could be used to calculate PCB loadings. 2.1 Sampling Locations Trackdown As shown in Figure 2 and Table 1, samples of whole water were collected from twelve locations in the area of concern within LRSA s western sanitary sewer system. Manhole 7B is located on LRSA s main western sewer line at the upstream boundary of the area of concern. A tributary sewer downstream of Manhole 7B adds flow from two industries, which are anonymously named B and C. Industry B is closing, but batch discharged process and storm water during Tier 3. Industry C is a batch discharger that discharged once or twice a day during Tier 3. The tributary sewer was sampled at Manhole FCP, which marks the point where the sewer was recently diverted south of its original junction with the main western sewer. 4 The cutoff section of the original tributary sewer was sampled near its junction with the main western line at Manhole GMQ. A few yards downstream of this junction, Industry A discharges to the main western sewer. Industry A s storm water sewer system discharges to a containment basin where dry and wet weather flows are segregated for discharge to LRSA s sewer and Kings Creek, respectively. The dry weather flow is combined with the process flow before discharge to the main western sewer. Further downstream, the western sewer line was sampled at Manholes MK, RLD and SM. A small pipe inside Manhole MK that conveys additional dry weather flow from Industry A was also sampled. Manhole RLD is located at a structural diversion to a relief line that was constructed to divert high flows to LRSA s WWTP. Manhole SM represents the downstream boundary of the area of concern, where the highest PCB levels were found in Tier 2. 4 The tributary sewer was re-routed during construction of the city of Linden s flood control sewer.

13 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 13 Table 1. Description of LRSA Sampling Locations for Phase IV Tier 3 Trackdown Location ID Address/Location Flow Rate Sampling Date (2006) Sample Type/ Method Manhole 7B Main western sewer; 1515 W Elizabeth Ave (parking lot) 1.12 mgd* (Rounds 1&2) Jan (Round 1) Jan (Round 2 24-hour composite using auto sampler (SOP #1, NJHDG 2004a) Manhole GMQ Tributary sewer; Near northern boundary of Industry A next to railroad; manhole closest to main western sewer; No flow; cut-off section Jan 11 (Round 1) Jan 25 (Round 2) 1 to 2-hour composite; used peristaltic pump to collect grabs every 25 min (SOP #3, NJHDG 2004a) Manhole FCP Tributary sewer at beginning of diversion Unknown** Apr 25 Single grab using peristaltic sampler (SOP #3) Manhole MK Main western sewer; Industry A s property in truck parking lot 1.8 mgd* (Rounds 1&2) Jan (Round 1) Jan (Round 2) 24-hour composite using auto sampler (SOP #1, NJHDG 2004a) Manhole RLD Main western sewer; Near Industry A s entrance from Pleasant St 1.8 mgd* (Rounds 1&2) Jan (Round 1) Jan (Round 2) 24-hour composite using auto sampler (SOP #1, NJHDG 2004a) Manhole SM Main western sewer; 820 Smith St 1.8 mgd* (Rounds 1&2) Jan (Round 1) Jan (Round 2) 24-hour composite using auto sampler (SOP #1, NJHDG 2004a) Industry A Outfall 005 discharge to LRSA (process & dry weather flow) Near Industry A s entrance at Linden Ave 1.03 mgd** (Round 1) 0.95 mgd** (Round 2) Jan (Round 1) Jan (Round 2) 24-hour composite using auto sampler (SOP #1, NJHDG 2004a) Industry A Storm Water Containment Basin (dry weather flow only) Industry A property mgd** (Round 1) mgd** (Round 2) Jan 12 (Round 1) Jan (Round 2) Single grab and 24-hour composite using auto sampler (SOP #1, NJHDG 2004a)+ Industry A dry weather discharge to Manhole MK Manhole MK; Source is lift station #6 on Industry A property mgd++ Jan 26 (Round 2) 1 ½-hour composite; used pole sampler to collect samples every 25 min (SOP #1C,

14 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 14 Table 1. (continued) NJHDG 2006) Location ID Address/Location Flow Rate Sampling Date (2006) Sample Type/ Method Industry B Process Discharge Pleasant St on Industry B property 0.08 mgd** (Round 1) Jan 11 (Round 1) 2-hour composite timed with Industry B batch discharge; used pole sampler to collect samples every 30 min (SOP #1C, NJHDG 2006) Industry B Storm Water Discharge Pleasant St on Industry B property; holding basin None; batch discharge when basin is full Apr 25 Single grab sample collected using SOP #1C (NJHDG 2006) Industry C Discharge (Round 1) Industry C property mgd** (Round 1) Jan 11 1-hour composite timed with Industry C batch discharge; used peristaltic sampler to collect grabs every 30 min (SOP #3, NJHDG 2004a) Industry C Discharge (Round 2) Pleasant St & Linden Ave (at point of discharge to LRSA s sewer; outside Industry C gate) mgd** (Round 2) Jan 25 1 ½-hour composite timed with Industry C batch discharge; used pole sampler to collect samples every 25 min (SOP #1C, NJHDG 2006) Storm Water Insert at Manhole RLD Near Industry A s entrance from Pleasant St Flow not measured; sample collected after 1.44 rainfall May 12 Single grab sample of whole water and sediment collected using SOP #6B (Appendix A) * Flow data were collected in Tier 2 (June 2005). ** As measured by the industrial user. Industry C discharged on the day that the Manhole FCP sample was collected; however, the timing and flow rate of the batch discharge are unknown. + In Round 1, sampler program failed; single grab taken on Jan 12, In Round 2, only 23 of 96 possible subsamples were collected, although the sample jar was full. ++ Flow measured by bucket on June 21 and 22, 2006.

15 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 15 In addition to sewer water, samples of storm water runoff (whole water and sediment) were collected from an insert installed at Manhole RLD in the area of concern (Table 1). This manhole is located in an area prone to flooding and the manhole cover is over-sized for the opening. Storm water runoff has been observed to enter this manhole. The NJHDG planned to collect a sample of domestic wastewater to evaluate the background contribution of PCBs to municipal WWTPs. The city of Linden and Borough of Roselle did not have residential areas with newly constructed sewers that would exclude extraneous flows such as storm water or I & I. Therefore an alternative location was identified in nearby, new residential area (Township A). On February 7-8, 2006, a whole water sample was collected from a sanitary sewer pump station that receives wastewater from newly constructed sewers in a residential area Atmospheric Deposition of PCBs Existing PCB data for potable water and groundwater were initially reviewed to determine if the results were suitable for evaluating the contribution of air deposited PCBs to LRSA s sewer system. The local water supply company, New Jersey American Water (NJAW, formerly Elizabethtown Water Company), was contacted regarding available PCB data for potable water. NJAW is required to collect such data under the Safe Drinking Water Act. The maximum contaminant level (MCL) for total PCBs is 0.5 ppb. It was anticipated that the minimum detection levels for the analytical data may be low enough to allow a comparison to some of the highest PCB results for LRSA s sewer (i.e., 0.1 to 0.5 ppb total PCBs). However, data obtained from NJAW showed no detectible Aroclors at reporting limits of ppb. NJHDG decided to collect and analyze potable water samples for PCB congeners using lower detection limits and compare the results to the sewer trackdown results. LRSA obtained PCB congener data on groundwater as part of an application for discharge to its WWTP. The proposed discharge was related to construction of the city of Linden s flood control system in the vicinity of the area of concern (i.e., Manholes 7B to SM). No supplemental information (i.e., exact location, depth of collection, supplemental analytical results such as TSS, ph, conductivity, etc.) were provided with the PCB data; therefore, NJHDG intended to collect and analyze an additional groundwater sample. Three samples were planned to be collected in Tier 3 as part of the preliminary evaluation of atmospheric PCB deposition. On April 13, 2006, potable water samples were collected from the cold water taps at the WWTPs of nine of the NJHDG members [Passaic Valley Sewerage Commissioners, Bergen County Utilities Authority, Joint Meeting of Essex & Union Counties, Rahway Valley Sewerage Authority, North Hudson Sewerage Authority (Adams St and Way St facilities), Linden Roselle Sewerage Authority, North Bergen Municipal Utilities Authority, Edgewater Municipal Utilities Authority and Secaucus Municipal Utilities Authority]. On April 25, 2006, whole water

16 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 16 was collected from Manhole FCP, which was initially thought to represent groundwater and residual storm water from the city of Linden s flood control sewer. As noted, it was later learned that this manhole was actually the beginning of the diverted, tributary sanitary sewer (Section 2.1.1). Collection of a storm water sample in a presumed uncontaminated section of the Borough of Roselle was planned as part of Tier 3. However, as of the submittal date of this report, weather conditions have not been favorable for sample collection. 2.2 Sample Collection Automatic water composite samplers were outfitted with pre-cleaned pump tubing, Teflon-lined intake tubing and strainers. Each sampler was programmed to collect approximately 8 L of sewer water over a twenty-four hour sampling period [see SOP #1 in Appendix A of the QAPP (NJHDG 2004a)]. Samples were collected into pre-cleaned 2 ½ gal glass containers. Ice was packed around the containers during sample collection and handling. Upon retrieval, the samples were transferred to LRSA for processing. Whole water grab samples or composites of whole water grab samples were collected by two primary methods: portable peristaltic pump sampler or pole sampler. As described in SOP # 1C (NJHDG 2006), pole samplers were used to sample flow from lateral discharges to manholes where the discharge pipe was perched above the sewer invert. These locations included Industry A s dry weather flow pipe at Manhole MK, Industry B s process discharge and Industry C s process discharge to the LRSA s sewer (Round 2). It was possible to sample these flows using a precleaned 1-L jar attached to the pole sampler without touching the pipe or manhole surfaces. The pump samplers were used to sample intermittent discharges (e.g., Industry B and C process discharges) where there was sufficient depth to cover the intake strainer (SOP #3). The pump sampler was prepared in the same manner as the automatic composite sampler, except the sampler was operated in a manual mode. Access to the Industry B storm water basin was limited; therefore, the water grab sample was collected with a stainless steel bucket attached to a rope. Whether collected by pump sampler, pole sampler or bucket, samples were composited into pre-cleaned 2 ½ gal glass containers upon collection in the field. 5 Whole water field and equipment blanks were prepared as practiced in Tiers 1 and 2 and as described in SOP #2 of the QAPP (NJHDG 2004a). The storm water insert at Manhole RLD was fabricated from stainless steel and was designed to fit into the manhole opening (see Figure 13). 6 A center overflow pipe was added to limit the sample volume to a manageable weight. The insert was installed in the manhole opening prior to a significant storm, which occurred on May 11 12, 2006 (1.44 ). The sample collected in the insert consisted of water and sediment (see Figure 14). The water sample was transferred to a pre-cleaned 2 ½ glass container and the 5 Sample compositing was performed in the field rather than at LRSA as noted in SOP #1C. 6 The storm water insert was fabricated by the Passaic Valley Sewerage Commissioners (PVSC).

17 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 17 sediment was scraped out of the insert using a stainless steel spoon and placed into precleaned 1-L glass jars (see SOP #6B, Appendix A). Potable water samples were collected from each location as a single grab in pre-cleaned 1-L glass jars (see SOP #6A, Appendix A). The samples were collected from cold water taps after the taps had been opened for several minutes. The Township A domestic wastewater sample was collected as a twenty-four hour composite. Sampling procedures followed SOP #1 (NJHDG 2004a). Additional details of the sample collection are given in the attached field reports (see Appendix B), which were completed each time samples were collected. Details of equipment cleanup before sampling are provided in Appendix A of the QAPP (NJHDG 2004a). 2.3 Sample Preparation All samples were delivered to LRSA where they were processed for delivery to the analytical laboratories. Portions of the whole water samples were prepared for shipment for PCB congener analysis by AXYS Analytical Services, Ltd (Sidney, Canada) and TSS analysis by LRSA s laboratory. Sample preparation is summarized as follows. Additional details are provided in the Appendix A SOPs and Appendix A of the QAPP (NJHDG 2004a) Whole Water Composite Samples Whole water composite samples were thoroughly mixed and 2 L was poured into two pre-cleaned 1 L jars for PCB congener analysis by HRGC/LRMS. Two additional liters of sample were archived at 4 o C in case of sample loss or laboratory error. Approximately one liter of each composite sample was also poured into 1 L plastic containers for TSS analysis. Samples for PCB congener analysis were packed into coolers with freezer packs and shipped by overnight courier to AXYS. TSS samples were transferred to LRSA s laboratory manager Whole Water Grab Samples Sewer water grab samples were composited upon collection. The composited samples were split for HRGC/LRMS and TSS analysis and archiving using the procedures referenced in Sections 2.2 and 2.3. HRGC/LRMS samples were shipped in coolers with freezer packs to AXYS. TSS samples were transferred to LRSA s laboratory manager. The whole water sample collected in the storm water insert was split for HRGC/LRMS and TSS analysis and archiving using the procedures noted in Sections 2.2 and 2.3. A 1- L portion of the sediment was prepared for shipment and a 0.5 L portion was archived.

18 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 18 Samples for PCB congener analysis were packed into coolers with freezer packs and shipped by overnight courier to AXYS. The sediment sample was not freeze dried and sieved before analysis, as was practiced with earlier sediment samples (NJHDG 2006), due to schedule constraints. The potable water samples from the NJHDG WWTPs were delivered to LRSA and composited into a pre-cleaned 2 ½ gal glass container. The composited sample was split for HRGC/LRMS analysis and archiving using the procedures referenced in Sections 2.2 and 2.3. Samples for PCB congener analysis were packed into coolers with freezer packs and shipped by overnight courier to AXYS. 2.4 Sample Analysis HRGC/LRMS All samples, except the potable water and Township A water samples, were analyzed for PCB congeners using HRGC/LRMS (modified EPA method 1668) as described in Section 9 of the QAPP. Water samples were spiked with labeled quantification standards (surrogates). The samples were then filtered, the filtrate and particulate phase were extracted separately with dichloromethane and the extracts were combined. The extracts were cleaned with Florisil, gel-permeation, alumina and acid-base silica chromatography columns. Finally, all extracts were reduced in volume and spiked with labeled recovery (internal) standards before instrumental analysis. Quality control (QC) samples [i.e., a procedural blank and ongoing precision and recovery (OPR) sample] were analyzed along with each sample batch. The potable water and Township A water samples were analyzed for PCB congeners using HRGC with high resolution mass spectrometry (HRMS) as described by EPA method 1668A. This method used an SPB octyl column in lieu of the DB-5 column used for HRGC/LRMS to reduce the number of co-eluting congeners. The HRMS instrument also has a higher mass resolution with higher mass specificity. Water samples were prepared as described for HRGC/LRMS except that the whole sample was extracted, not filtered with separate extractions of the filtrate and particulate phase. This approach is typically used for samples with <1% solids. More surrogate standards were used for this method than for HRGC/LRMS. The cleanup steps were the same as for HRGC/LRMS, except that cleanup standards were introduced to quantify losses that are specific to sample cleanup. Acceptance criteria (QA objectives) for surrogate recoveries were different for HRGC/HRMS compared to HRGC/LRMS (see Section 3.3.2). Both analytical methods used the same basic quantification procedures. Sample specific detection limits were calculated for each target analyte. Target concentrations were determined by isotope dilution/internal standard quantification methods. These methods correct for possible congener losses during sample extraction and cleanup. Results were presented as congener concentrations, homologs and total PCBs. Homolog totals were

19 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 19 calculated by summing the detected congeners for each level of chlorination (i.e., mono, di, tri, tetra, penta, hexa, hepta, octa, nona, deca chlorobiphenyls). Total PCBs represent the sum of all quantified congeners Total Suspended Solids Whole water samples were analyzed for TSS (Method per EPA 1999) by LRSA s laboratory. The results were compared with total PCB results to evaluate the relationship between TSS and total PCB concentrations. 2.5 Industrial User Survey A questionnaire was submitted to Industries A, B and C to request information on current and past PCB activities. The following information was gathered: Presence of transformers, capacitors, heat transfer fluids, hydraulic fluids or other materials that may contain PCBs Current or past on-site remediation of PCB contaminated soils, surface water or groundwater Current or past activities involving the use, storage or generation of PCBs Although the Tier 3 plan specified that two other property owners, the railroad and electric utility, would be surveyed, it was decided that the information would be gathered at a later time. 2.6 Review of Public Records Information on properties contaminated with PCBs was gathered through a public records review. This review focused on properties in the vicinity of the Tier 3 area of concern. The following records were reviewed: Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Resource Recovery and Conservation Act (RCRA), and New Jersey s Open Public Records Act (OPRA) data bases on remedial activities performed to address PCB contamination Toxic Substances Control Act (TSCA) data bases on PCB contaminated transformers and PCB storage, generation or disposal Toxics Release Inventory (TRI) on PCB releases

20 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 20 LRSA pretreatment files, specifically applications for discharge of PCBcontaminated groundwater or storm water to the WWTP

21 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Results This section summarizes the results of the Tier 3 trackdown and the preliminary evaluation of atmospheric PCB deposition. 3.1 Trackdown Results are summarized as follows for the sewer trackdown, industrial user survey and public records review of waste sites in the area of concern. Whole water composite samples were successfully collected from all intended locations with the exception of the Industry A dry weather flow, where a single grab sample was substituted in Round 1 and the composite sample in Round 2 was collected in only six hours of the twenty-four hour collection period (see Table 1). The samples are considered to be representative of the flow because dry weather flow collects in Industry A s storm water containment basin for a few hours before the basin pumps are activated to pump the water to Industry A s process discharge outfall. PCB congener data obtained by HRGC/LRMS are shown in Appendix C. PCB results for the first round of samples collected on January 10 11, 2006 did not meet some quality control requirements (see Section 3.3.2). Normally, these samples would have been re-analyzed to achieve the QC limits; however, (1) the sample data were recovery corrected using the low surrogate recoveries, so the deviation was compensated and (2) the project schedule did not allow sufficient time for the re-analysis. QC requirements were largely met for PCB analysis of the second round of samples collected on January 25 26, The sample data were not blank corrected. PCB 1 and PCB 36 were detected in the equipment blank for Round 2, but the peaks did not meet quantification criteria. Similar detections in field samples were not included in the total PCB sum; therefore, the Round 2 sample data were not blank corrected. Sample data for Round 1 were not blank corrected as quality control problems were encountered in analysis of the field blank (see Section 3.3.2). However, no PCB congeners were found in a field blank collected with a sample of Industry B s discharge on December 21, 2005 prior to Round 1 (Industry B letter to LRSA dated February 27, 2006). Also, PCB congeners were not confirmed in field blanks collected in Tiers 1 and 2 of Phase IV.

22 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 22 Results for Rounds 1 and 2 exhibit similar patterns in PCB concentrations between sampling locations on LRSA s western sewer line. As shown in Table 2 and Figures 3 and 4, Manhole MK had, by far, the highest total PCB concentrations (630 and 462 ng/l) of the Tier 3 sampling locations. The Round 1 result was one of the highest PCB levels observed in LRSA sewer water samples collected to date (NJHDG 2004b, 2005, 2006). The next highest total PCB concentrations for Tier 3 were observed downstream at Manholes RLD and SM. Total PCB levels at Manhole SM ( ng/l) were lower than the Tier 2 concentrations ( ng/l). Total PCB concentrations at Manhole 7B were similarly lower in Tier 3 than in Tier 2 (i.e., ng/l for Tier 3 versus ng/l for Tier 2). The Tier 2 PCB levels at Manhole 7B were similar to those observed in Tier 1 (i.e., ng/l for Tier 1). A review of precipitation records indicates greater rainfall prior to and during Tier 3 ( monthly rainfall for December 2005 through January 26, 2006) compared to Tier 2 ( monthly rainfall for May through June 17, 2005) and Tier 1 ( monthly rainfall for October through November 18, 2004). Not surprisingly, TSS concentrations of sewer samples collected during this period appeared to be inversely correlated with rainfall (i.e., higher TSS levels in Tiers 1 and 2 compared to Tier 3). TSS may accumulate in sewers until increased flows, typically from storm runoff, wash the solids downstream. Given the affinity of PCBs for solids, the lower PCB concentrations at Manhole 7B in Tier 3 compared to Tiers 1 and 2 may be related to frequency and/or magnitude of rainfall. Potential contributing sources to the western sewer line between Manholes 7B and MK were monitored (see Table 2 and Figures 3 and 4). Industry A s discharge was one of three inputs that exhibited PCB concentrations that were greater than that observed at the study reference location, Roselle Flume (17-30 ng/l in Tier 1; NJHDG 2005). PCB concentrations in Industry A s discharge (total PCBs of 44 ng/l in Round 2) appear to be influenced by PCBs in the industry s dry weather flow (97 ng/l in Round 2). Although dry weather flows are segregated from wet weather flows in Industry A s storm water containment basin, an intermediate flow was observed during Round 2 sampling, which occurred two days after a significant rainfall (0.68 at Newark Airport). The Round 2 dry weather flow sample was more turbid and had higher total suspended solids than the Round 1 sample (110 mg/l versus 7 mg/l, respectively). TSS concentrations were also slightly higher in the Industry A discharge sample in Round 2 than Round 1 (65 mg/l versus 52 mg/l). Manhole GMQ was another location that exhibited total PCB concentrations (150 ng/l in Round 1) higher than the reference level at Roselle Flume. However, the results for Rounds 1 and 2 were variable (i.e., 8 ng/l total PCBs for Round 2). The water samples did not include actual discharge from Industries B and C as the tributary sewer was diverted upstream at Manhole FCP in April The sampled water may have contained infiltration and inflow (I & I) and/or residual discharge from Industries B and C remaining in the sewer since April PCB concentrations in Industry B s and

23 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 23 Table 2. Summary of Total PCB and TSS Results for LRSA in Tier 3 Sample Identification Location PCBs, ng/l by HRGC/LRMS* Estimated Loading, g/day (Flow, mgd **) TSS, mg/l Manhole 7B 1515 W Elizabeth Ave (parking lot) R 1 R 2 R 1 R 2 R 1 R (1.12) 0.15 (1.12) Manhole GMQ Near northwestern corner of Industry A (NM) -- (NM) 4 4 Manhole FCP Near northwestern corner of Industry A NM (NM) -- (NM) NM 6 + Manhole MK Industry A parking lot (1.87) 3.27 (1.87) Manhole RLD Sanitary sewer near Relief Line diversion (1.87) 0.68 (1.87) Manhole SM 820 Smith St (1.87) 0.50 (1.87) Industry A Process Flow Northwestern corner of Industry A (1.03) 0.16 (0.95) Industry A Dry Weather Flow (Basin) Dry/wet weather containment basin at Industry A <0.01 (0.07) <0.01 (0.11) Industry A Dry Weather Flow (Lift Station 6) Lateral pipe at Manhole MK NM (NM) <0.01 (<0.01) NM 5 Industry B Process Flow Pleasant St & Linden Ave 2 NM <0.01 (<4) ++ (0.08) -- (NM) 56 NM Industry B Storm Water Pleasant St & Linden Ave (Basin) NM (NM) -- (NM) NM 14 + Industry C Process Flow Pleasant St & Linden Ave <1 <1 <0.01 (0.02) <0.01 (0.02) <4 <4 Storm Water Insert at Manhole RLD Manhole RLD; near Relief Line diversion NM ng/g # -- (NM) -- (NM) NM * Not blank corrected ** Flow data for Manholes 7B, MK, RLD and SM are based on Tier 2 flow monitoring; Industry A dry weather flow at Lift Station #6 was measured in June NM not monitored + Samples collected after Round Result for a grab sample of Industry B s process discharge collected on December 21, 2005 and analyzed by EPA Method 1668A. # Result for sediment portion of sample.

24 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 24 C s current discharge and Industry B s storm water basin were <4 ng/l; therefore, it is unlikely that recent industrial discharges contributed to the PCB levels observed downstream at Manhole GMQ. The Round 1 result indicates the presence of PCBs from past activities. Relatively low PCB concentrations at Manhole FCP (7.9 ng/l), which marks the beginning of the tributary sewer diversion, suggest that residual PCBs are not present upstream of the diversion (Figure 5). However, only a single data point was obtained and, given the variability observed at Manhole GMQ, the absence of PCBs can not be confirmed. Industry C discharged on the day that the Manhole FCP sample was collected; however, the timing and flow rate of the batch discharge are unknown. The third input with PCB levels higher than the Roselle Flume reference level was the storm water collected in the Manhole RLD insert (Figure 5). Both water and sediment concentrations of total PCBs in the storm water (i.e., 420 ng/l and 140 ng/g) were higher than water and sediment PCB levels observed at the Roselle Flume reference location (17-30 ng/l and 71 ng/g, respectively, in dry weather; NJHDG 2005). It is not known if these results may be representative of storm water elsewhere in the LRSA s service area; however, the total PCB concentrations at Manhole RLD are significant. Given the potential for storm water to enter sanitary sewers through infiltration or cross connection, the contribution of PCBs from storm water warrants further investigation. The storm water insert results were compared to data for the main western sewer line. The total PCB level in the water portion of the storm water insert sample was in the range of total PCB levels observed in the main western sewer. The total PCB concentration in the sediment portion of the sample was lower than the levels found in the western sewer at the nearby Manhole SM (16, ,000 ng/g in Tier 2; NJHDG 2006). Although the storm water may be a source of PCBs found in the western sewer, it is not possible to estimate the magnitude of the PCB contribution (i.e., loading) without knowing the volume of water and sediment that infiltrates Manhole RLD or other manholes in the area of concern. In an effort to minimize the PCB discharge, LRSA is replacing the oversized cover at Manhole RLD. PCB loading estimates were calculated based on flow data obtained in Tier 2 for Manholes 7B and SM and industry flow rates monitored during Tier 3. The loading estimates are shown in Figures 6 and 7. The sum of the total PCB loadings from Manholes 7B and Industry A s discharge (< g/day) accounts for less than 15% of the total PCB loading at the next downstream location, Manhole MK ( g/day). Tiers 1 and 2 results indicate that a significant portion of the water PCB concentration, and hence loading, can be influenced by PCB levels in the underlying sediment in the sewer. Although Manhole MK was not sampled for sediment, its presence was confirmed 7, and if it contained high PCB levels, the sediment may have contributed to 7 LRSA observed sediment at Manholes MK and RLD on June 21, 2006.

25 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 25 the PCBs observed in the water samples. Further downstream at Manholes RLD and SM, total PCB loadings decreased more than five-fold to g/day. The cause of this decrease is unknown. The total PCB loading at Manhole SM in Tier 2, Round 2 (2.4 g/day) is more consistent with the total PCB loading observed at Manhole MK. Nonetheless, the results indicate that the primary source(s) of PCBs is upstream of Manhole SM between Manholes MK and 7B. The trackdown objective stated in the QAPP (NJHDG 2004a) is to identify sources in LRSA s western sewershed that contribute total PCB concentrations that are more than 3 to 6-fold higher than the levels observed at the western sewershed terminus. This objective was also interpreted to apply to PCB loadings as well as concentrations (NJHDG 2006). In Tier 3, Manhole MK exhibited PCB concentrations and loadings that were about 6 to 7-fold higher than those observed at the downstream boundary of the area of concern (Manhole SM). Therefore, the objective was met and, by definition, the PCB source(s) are located upstream of Manhole MK and downstream of Manhole 7B. PCB homolog distributions were compared between sampling locations to further evaluate the PCB source(s). As shown in Figure 8, higher chlorinated biphenyls (tetra, penta and hexa) were present in the Round 2 sample of Industry A s dry weather flow than in the Round 1 sample (tri, tetra and penta chlorinated biphenyls). This pattern was reflected to some extent in the Industry A discharge samples for Rounds 1 and 2 (Figure 9). The homolog distributions also indicate that Industry A s dry weather flow is not the primary contributor of PCBs to the western sewer line as lower chlorinated biphenyls (tetra, penta, tri chlorinated biphenyls), which are indicative of Aroclors 1016, 1242 and 1254, are predominant at Manholes MK, RLD and SM (see Figure 10). Storm water entering Manhole RLD also does not appear to be a primary contributor of PCBs in the western sewer. Higher chlorinated biphenyls (hexa, penta, hepta) were present in the storm water insert sample (both water and sediment) than in the western sewer (Figure 11). As shown in Figure 12, the homolog distribution for the Round 1 Manhole GMQ sample is generally similar to the homolog distribution observed at Manholes MK, RLD and SM. These results indicate that the sewer accessed by Manhole GMQ may have been a source of the PCBs observed downstream at Manholes MK, RLD, SM, as well as Manholes SCP and 8 in Tier 2. Although no flow is currently contributed from Manhole GMQ, it is conceivable the tributary sewer may have contributed substantial PCB loadings in the past. High levels of PCBs observed in the sediment at Manhole SM (total PCBs up to 181,000 ng/g in Tier 2) may indicate residual contamination from past activities. Alternatively, unidentified PCB source(s) may be located along the western sewer line between Manholes 7B and MK. For example, it was learned that an 18 sanitary sewer, which originates from the southwest end of West Elizabeth Ave, ties into the western sewer below Manhole 7B (see Figure 2). Also, it is not known if other connections may exist (see Section Aristech Chemical Company).

26 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 26 Results for the Township A sample indicate that substantial PCB levels may be contributed from domestic wastewater. Total PCB concentrations in the sample were 10.8 ng/l. Comparable PCB data on urban residential wastewater are limited. No PCBs were detected in pump station samples collected in Delaware County (DELCORA 2005); however, the pump stations receive commercial/industrial flows, which may dilute PCBs from residential areas. In the LRSA trackdown, total PCB concentrations at Roselle Flume (17-30 ng/l) were not much higher than those in the Township A sample. The higher PCB concentrations at Roselle Flume may be related to sources in addition to domestic wastewater, such as storm water from cross-connections or I & I. These sources reportedly don t exist in the newly sewered area in Township A Supplementary Analysis Results In Tier 3, total PCB concentrations in whole water samples correlated somewhat with the samples TSS concentrations (R 2 of 0.63). Round 1 data for Manhole RLD strongly affected the correlation. When the Manhole RLD data were removed from the data set, the R 2 was When PCB and TSS data for all tiers of Phase IV were compared, the R 2 was As noted, results for some locations (i.e., Manhole SM in Tier 2 and Manhole RLD in Tier 3) strongly affected the correlation. A review of the Tier 1 data shows that the Manhole WNE results also affected the correlation. Relatively high levels of PCBs were found in sediment at each of these locations. The ratio of total PCB concentrations to TSS concentrations at these locations was high (>1) relative to many other sampling locations (<0.5). Overall, the comparison of total PCB and TSS concentrations shows that TSS analysis is not a useful surrogate for PCB analysis in sewer trackdown. Sediment PCBs levels vary throughout the sewer system and may influence whole water PCB concentrations and, hence, the correlation of PCB and TSS results Industrial User Survey Responses to the PCB questionnaire were received from Industries A and B. Industry C is in the process of being sold and did not respond Industry A In response to the survey questionnaire, Industry A advised that all equipment that contained >50 ppm PCBs had been removed from their facility by All other equipment with the potential to contain PCB levels <50 ppm was also removed. The former locations of this equipment were identified from a facility map.

27 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 27 Two accidental PCB releases were reported: about 17 gal of PCB transformer oil in 1997 and about 10 gal of PCB transformer oil (20-30% PCBs) in Regulatory authorities were notified, the releases were cleaned up and the waste was removed for off-site incineration or disposal. Industry A advised that PCBs are not a constituent of concern for any medium in their remediation program. Constituents of concern are defined as significant constituents onsite in terms of concentration, toxicity and overall site distribution. Industry A stated that the facility has no known processes that generate PCBs. In addition to the flows sampled in Tier 3, Industry A advised LRSA of three additional discharges to the western sewer line: Sanitary flow from a guard house located near the northwest boundary of the facility A connection at a water pump building, also located near the northwest boundary of the facility Sanitary flow from a contractor work area near the northern boundary of the facility close to Manhole RLD Industry B In response to the survey questionnaire, Industry B advised that an inventory was performed of all equipment that may contain PCBs within the facility. All eight of the transformers located at Industry B s main substation are classified non-pcb transformers (<50 ppm PCBs). Analysis of the transformer fluids in April 2006 identified two transformers with detectible PCBs (4 and 31 ppm total PCBs). These transformers are routinely inspected and maintained according to regulations. The facility is undergoing a hazardous waste investigation for past activities as required by RCRA. A Current Conditions Report (CCR) was prepared in May 2002 to assess historical hazardous waste management practices. The CCR identified no historical PCB spills or suspect management of PCB material at the facility. Records indicate that PCBs were not used at the facility since A Remedial Investigation (RI)/Facility Investigation (RFI) report and addendum prepared in 2004 and 2006, respectively, identified PCB contamination at two locations. PCBs were found in soils on the north and east side of the facility and in soil and light nonaqueous phase liquids (LNAPL) at a building on the southwest side of the property. Aroclor 1254 was identified as the predominant PCB type at both locations. Aroclor 1254 is indicated in the western sewer line at Manholes MK, RLD and SM, although the predominant Aroclors are 1016 and 1242.

28 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 28 The southwest contamination is being remediated as specified in a Corrective Measures Plan. Planned remedial activities include removal of the PCB contaminated soils and the LNAPL. A review of sewer maps indicated no current pathway for PCBs to enter LRSA s sanitary sewer. There is no defined pathway for PCBs in the north/east side soils to enter the sanitary sewer. The area of contamination is isolated from storm water and sanitary sewers. The area is also covered with pavement so that the affected soils are not in contact with storm water. Industry B stated that the facility has no known processes that generate PCBs Review of Public Records The public records review identified four PCB contaminated properties in LRSA s western sewershed. All of the properties are located above the upstream boundary of the area of concern (Manhole 7B). However, contamination from one property migrated offsite to an area adjacent to the railroad, which is downstream of Manhole 7B (see Figure 2; property is on eastern side of West Elizabeth Ave across from Marion Ave). A description of the PCB contaminated properties is given as follows. Celanese Polymer Specialties Corporation, located at 1401 West Blanke St, reported PCB concentrations in excess of 50 ppm in soils (Environ 2003). Aroclor 1254 was identified as the major PCB type. The property was previously owned by Resyn Corporation, which reportedly manufactured alkyd and epoxy resins and coal tar. PCBs have been associated with the manufacture of some resins; however, it is not known if PCBs were used at this site. As of April 2004, PCB contaminated soils were planned to be remediated (NJDEP 2004). No further information is available to determine if remediation has begun or been completed. Gomar Manufacturing/Honeywell, located at West Blanke St, applied for discharge of groundwater to LRSA (Honeywell 2000). LRSA denied the application after a review of remediation investigation reports because of concerns about the presence of PCBs in the groundwater. A Remediation Investigation Workplan (ABB Environmental Services 1998) described PCB contamination in soils exceeding 100 ppm. The contaminated soils were subsequently removed in August Post excavation analysis of the area found 1 14 ppm PCBs, which was below NJ cleanup criteria. NJDEP accepted the remediation results and planned to issue a No Further Action/Covenant Not to Sue letter (NJDEP 2003). Standard T Chemical Company, located at 1312 West Elizabeth Ave, found PCB contaminated soils (EPA 2005). As required under NJ s Industrial Site Recovery Act (ISRA), Standard T removed PCB contaminated soils, installed a soil cap over the

29 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 29 remainder of the contaminated soil and recorded a deed restriction to prevent future disturbance of the area. Aristech Chemical Company, located at 1711 West Elizabeth Ave, operated pilot plants to experiment with the manufacture of specialty polyester resins (EPA 2004). PCBs were used in heat transfer systems. Elevated PCB levels in soils at the facility were presumed to be associated with incidental spills from the heat transfer systems. The highest contamination, primarily Aroclor 1242, was found at the southeast boundary of the property that adjoins the railroad. Although the on-site soils were remediated, the PCB contamination migrated off-site along the Amtrak railroad not far from the main western sanitary sewer. PCB concentrations in the off-site soils were as high as 234 ppm. EPA believes that this contamination was associated with storm water runoff from the Aristech site and other possible sources. Runoff is directed to a drainage ditch that parallels the railroad tracks, flowing southwest to northeast into a catch basin. EPA (2004) reports that the catch basin subsequently drains into the municipal storm sewer system. Although the sanitary and storm sewers in Linden are separate, no information is available to determine if flow from the storm sewer may have entered the sanitary sewer. A Remediation Action Workplan (2003) was prepared and approved by NJDEP and Amtrak. No further information is available to determine if remediation has begun or been completed. EPA s PCB activity data base (PADS) was reviewed. Only one facility in the area of concern (Industry A) was listed for PCB activity. Industry A was noted as a PCB generator, presumably for the purpose of off-site disposal of PCB waste. EPA s TRI was reviewed and no PCB releases were reported for Union County, NJ since records were compiled in The TRI is intended to report on-site and off-site releases to air, water and land. 3.2 Contribution of Atmospheric PCBs to LRSA The evaluation of air deposition of PCBs focused on the collection and analysis of potable water and storm water samples and the review of existing ground water data. The manhole insert sample results (Section 3.1) may shed light on the contribution of PCBs from atmospheric deposition and storm water runoff. Additional data are forthcoming on storm water. Storm water samples were to be collected in a presumed uncontaminated area in the Borough of Roselle. However, weather conditions have not been favorable and sample collection has been deferred to Phase V. PCB sample results were blank corrected by subtracting congener concentrations detected in the laboratory water blank. Results for the potable water sample and lab blank are shown in Appendix C.

30 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 30 Total PCB concentrations in the potable water composite sample were 0.49 ng/l. This value is nearly two orders of magnitude lower than the total PCB concentrations observed at the sewer reference location, Roselle Flume (17-30 ng/l in Tier 1). Although the potable water result is a single data point and the sample may not be representative of the raw water supply in the service areas of NJHDG WWTPs, the result indicates that potable water is not a significant source of PCBs. As noted in Section 3.1, the manhole insert results indicate a potential for significant contribution of PCBs from storm water. However, the manhole insert sample was collected in the area of concern and may not be representative of storm water elsewhere in the LRSA service area. Additional sampling is recommended at locations that would more fully characterize LRSA s sewer system. The sample collected from Manhole FCP was intended to represent groundwater/ dry weather flow in the western area of concern. However, it was later learned that this manhole does not access the Linden Flood Control sewer. Manhole FCP is actually located on the diverted tributary sanitary sewer, which receives flow from Industries B and C (see Figure 2). As noted, a groundwater sample was previously collected in the vicinity of Manhole FCP. The results show that the total PCB concentration (10.8 ng/l) is not significant compared to the PCB levels found in the western sanitary sewer. Groundwater in this area does not appear to be a significant contributor of PCBs to the area of concern. 3.3 QA/QC Results Representativeness Representativeness in sample collection was achieved by: Collecting samples in manholes where the flow depth was sufficient to cover the water sampler intake strainer and the flow velocity achieved mixing throughout the depth profile Collecting samples during normal business hours when industries were discharging Collecting at least 8 L of whole water sample so that representative aliquots could be taken for HRGC/LRMS and TSS analysis As noted in Section 3.1 and the Tier 2 report (NJHDG 2006), the whole water samples collected at Manholes SM, RLD and MK may not have been representative because of the potential influence of underlying sediment. Although it is not possible to confirm that underlying sediments contributed PCBs to water samples, there is evidence to support this assumption. The two sampling locations where underlying sediment with relatively high PCB levels was observed in Tier 2 (Manholes ELM and SM) tended to have higher

31 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 31 water PCB concentrations than other nearby locations. These results may be an artifact of the sampling method. It was not possible to locate the sampler intake strainers above the bottom of the sewer pipe because of concern about missing samples due to fluctuating water levels. Therefore, the intake strainers were placed on the pipe bottom over top of the sediment. Not surprisingly, some sediment was observed in the composite sample containers at Manholes ELM and SM. Sediment was also found in Manholes RLD and MK, although no samples were taken for PCB analysis Accuracy Accuracy in GC/MS analysis was measured using surrogate spikes and matrix spikes. A known amount of each surrogate spike was added to every sample, reference sample and blank before preparing the samples for analysis. In this way, the efficiency of the extraction and analytical steps could be estimated by the recovery of surrogate spikes. The matrix spike and matrix spike duplicate (MS/MSD) represented the actual analytical recovery of PCB congeners. The QA objective of performing matrix spike analyses on 5% of samples and surrogate spikes on all samples and blanks was met. An analytical reference sample, referred to as the OPR sample was prepared and analyzed with each sample batch analysis. The analytical laboratory (AXYS) changed the surrogate PCBs used for Tier 3 analysis. QA objectives for each surrogate were as follows: 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % As noted, two samples were analyzed by HRGC/HRMS (Method 1668A). The QA objective for HRGC/HRMS surrogate recoveries was as follows: 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB %

32 Tier 3 of the Phase IV PCB Trackdown at LRSA Page C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % 13 C 12 PCB % The QA objective for MS/MSD recoveries was 60% to 130% as stated in the QAPP (NJHDG 2004a). The GC/MS surrogate and MS/MSD recovery objectives were met with the following exceptions. The deviations did not appear to compromise the analysis; therefore, the results are considered valid. In one case, samples were reanalyzed when poor surrogate recoveries were observed in the field samples and OPR sample Round 1 - Whole Water Samples Surrogate recoveries for initial analysis of the samples did not meet QA objectives. Archived aliquots of the samples were resubmitted for analysis. In the second analysis, recoveries of 13 C 12 labeled PCBs 3, 8, 28, 101 and/or 118 in some samples were below QA objectives. Also, recoveries of 13 C 12 labeled PCBs 3, 8, 28, 101 and 202 were below the objectives for the OPR. In addition, the 13 C 12 labeled PCB 3 was not quantifiable in the Industry C sample; therefore PCBs 1, 2 and 3 could not be quantified for the sample. Normally, these samples would have been re-analyzed to achieve the QC limits; however, (1) the sample data were recovery corrected using the low surrogate recoveries, so the deviation was compensated and (2) the project schedule did not allow sufficient time for the re-analysis. The lab blank analysis demonstrated the overall accuracy of the analyses. Surrogate recoveries in the lab blank were acceptable, except for PCB 28.

33 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Round 2 - Whole Water Samples Recoveries of 13 C 12 labeled PCBs 3, 8 and/or 28 were slightly below QA objectives for the equipment blank, Manhole MK, Industry Dry Weather Basin duplicate, Industry Dry Weather Lift Station #6, lab blank and OPR samples. However, the recovery correction procedure compensated for the slight variances and the data were deemed valid. PCB recoveries in the MS/MSD samples met QA objectives except for minor deviations for 13 C 12 labeled PCB 54 in both samples and 13 C 12 labeled PCBs 15, 77, 104, 105/127 in the MSD. Overall, the MS/MSD demonstrated acceptable accuracy. Matrix interferences were noted for samples from Manholes MK, RLD, SM and 7B. Additional copper cleanup improved the detection limits; however, some still exceeded QA objective of 0.5 ng/l. This deviation did not significantly affect the results as total PCB concentrations at these manholes were 36 to 462 ng/l. The Township A domestic wastewater, Industry B storm water and Manhole RLD storm water insert samples were analyzed in separate batches. Surrogate recoveries for the domestic wastewater sample and associated OPR sample and lab blank met the QA objectives for HRGC/HRMS. Cleanup standard recoveries were also within QA objectives. Surrogate recoveries for HRGC/LRMS analysis of the Industry B storm water sample met QA objectives. Surrogate recoveries for HRGC/LRMS analysis of the Manhole RLD storm water insert sample met QA objectives except for slight deviations in 13 C 12 labeled PCB 3 and 13 C 12 labeled PCBs 28 and 209 in the associated lab blank and OPR samples, respectively Atmospheric Deposition Evaluation Samples Surrogate and clean up standard recoveries for the potable water sample and the associated OPR sample and lab blank met QA objectives Precision Precision was assessed by analysis of OPR reference samples and duplicate samples. The QA objective for the OPR sample used for HRGC/LRMS was 60 to 130% recovery of mono, di and deca chlorinated biphenyls and a 70 to 130% recovery of all other congeners (NJHDG 2005). The QA objective for the OPR sample used for HRGC/HRMS was 50 to 150% for all congeners. The QA objective for duplicate analyses for both GC/MS methods was 40% relative percent difference (RPD) as stated in the QAPP. A 20% RPD was the objective for TSS measurement. The surrogate recovery problem noted for the Round 1 OPR sample did not affect analysis of the native PCB congeners in OPR samples. Precision QA objectives for HRGC/LRMS were met with the following exceptions.

34 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Rounds 1 and 2 - Whole Water Samples Percent recoveries of native PCBs 54 and 104 in the Round 1 OPR sample and native PCB 54 in the Round 2 OPR sample slightly exceeded the QA objective. Results reported for field samples were considered to be similarly affected. However, these congeners represent a small subset of the congeners detected in the samples and the total PCB sample values should not have been affected. Native percent recoveries for OPR samples analyzed with the Township A domestic wastewater and Industry B storm water samples met QA objectives. Native percent recoveries for the OPR sample analyzed with the Manhole RLD storm water insert met QA objectives with the exception of a slight deviation in the native PCB 54. The RPD for duplicate PCB analysis of the Industry A Dry Weather Lift Station # 6 sample was 4% (based on total PCB concentrations), which demonstrated the precision of the HRGC/LRMS method. Duplicate TSS analysis was performed on all whole water samples. The RPD for duplicate results was <8.1% with the exception of one duplicate set, which had a RPD of 86%. The single deviation was related to variable results at the method s minimum detection level (MDL) of 4 mg/l. Results for the deviating duplicate pair were 2 and 5 mg/l. Overall, the duplicate results demonstrate acceptable precision Atmospheric Deposition Evaluation Samples Native percent recoveries for OPRs analyzed with the potable water sample met QA objectives Sensitivity The MDLs for HRGC/LRMS analyses were well below the minimum levels needed for PCB trackdown. The average MDL for congeners in water samples was less than the QA objective of 0.5 ng/l with the exception of the four samples noted in Section Comparability As noted in Section 3.1, total PCB concentrations were lower for Manholes 7B and SM in Tier 3 compared to Tier 2. These results, together with the Tier 1 data, appear to be related to differences in rainfall rather than a deviation in the trackdown methods. The water PCB homolog distributions for Manholes 7B and SM were similar between tiers, which demonstrates the reproducibility of the sample collection and HRGC/LRMS methods used in Phase IV.

35 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 35 TSS concentrations were lower for Manholes 7B and SM in Tier 3 compared to Tier 2. Again, variations in rainfall may explain this difference (see Section 3.1). The whole water sampling procedures were checked and found to be identical between tiers. Also, precision in TSS analysis was excellent as noted in Section Completeness The completeness objective of obtaining 80% of all data within the allowable limits for accuracy and precision was achieved for HRGC/LRMS and TSS analysis of whole water.

36 Tier 3 of the Phase IV PCB Trackdown at LRSA Page References ABB Environmental Services, Inc Preliminary Assessment/Site Investigation Report and Remedial Investigation Work Plan at Gomar Manufacturing Company. Prepared for Allied Signal, Inc. DRBC Calibration of the PCB Water Quality Model for the Delaware Estuary for Penta-PCBs and Carbon. Prepared by the Delaware River Basin Commission. DELCORA Report on the Phase I Trackdown of Polychlorinated Biphenyls (PCBs) at Delaware County Regional Water Quality Control Authority s Western Regional Treatment Plant. Prepared by Aquatic Sciences Consulting for DELCORA. ENVIRON Remedial Investigation Report and Remedial Action Workplan for the Celanese Americas Corporation Facility in Linden, Union County, NJ. EPA Letter to Sheldon Lipke, Chairperson, NJHDG, from Richard Caspe, Director, Water Management Division. EPA Total Suspended Solids, EPA Method Revision to Methods for Chemical Analysis of Water and Wastes. EPA/600/ , Cincinnati, OH. EPA Fact Sheet for Aristech Chemical Company. EPA ID Number: NJD EPA Fact Sheet for Standard T Chemical Company. EPA ID Number: NJD Honeywell Letter Request for Sanitary Sewer Discharge to LRSA. Labencki, T., Diamond, M., Motelay-Massei, A., Truong, J., Branfireun, B., Dann, T. In Press. Variability in and Mechanisms of PAH Washoff From Urban Impervious Surfaces. NJDEP Letter to John Mojka, Honeywell International, dated December 31, NJDEP Memorandum from Walter Samsel (Bureau of Environmental Evaluation and Risk Assessment) to Brian Keune (Bureau of Case Management), April 6,

37 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 37 NJHDG Final Report Trackdown of Polychlorinated Biphenyls (PCBs) in a Municipal Sewer System: Phase III of the Pilot Study at the Linden Roselle Sewerage Authority. Prepared by Aquatic Sciences Consulting for the New Jersey Harbor Dischargers Group. NJHDG. 2004a. Quality Assurance Project Plan for Phase IV of the Trackdown of Polychlorinated Biphenyls (PCBs) in a Municipal Sewer System: Pilot Study at the Linden Roselle Sewerage Authority. Prepared by Aquatic Sciences Consulting for the New Jersey Harbor Dischargers Group. NJHDG. 2004b. Report on the Dry Run Assessment for Phase IV of the Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority. Prepared by Aquatic Sciences Consulting for the New Jersey Harbor Dischargers Group. NJHDG Tier 1 Report/Tier 2 Plan for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority. Prepared by Aquatic Sciences Consulting for the New Jersey Harbor Dischargers Group. NJHDG Tier 2 Report/Tier 3 Plan for the Phase IV Trackdown of Polychlorinated Biphenyls (PCBs) at the Linden Roselle Sewerage Authority. Prepared by Aquatic Sciences Consulting for the New Jersey Harbor Dischargers Group

38 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 37 N # Roselle Flume (St. Georges Ave and Hussa St) Manhole ROS (Rose Parkway) Manhole 516 (Ainsworth St) Manhole 304 (Elm St) Manhole W-NW Manhole ELM ( Stiles & Henry St) (Elm & Lindegar St) Manhole W-NE (Stiles & Elm St) # Manhole 7B (West Elizabeth Ave and behind Paramount) Manhole GEP (Gilbert Express) Manhole HDP (Airport Plaza) # Manhole 8 (12 th St & Harding Ave and 12 th & Mopsick) Manhole SCP (Airport Plaza) Manhole C (20 th & Clinton St) # # Manhole T (Truck Co.) Manhole SM (Smith St) Relief Line Water Sampling Locations Sediment Sampling Locations Water & Sediment Sampling Locations Sewer Lines LRSA WWTP Screen House and Primary Influent Miles Figure 1. LRSA s Main Sanitary Sewer Lines and Sampling Locations for Phase III and Phase IV (Tiers 1 and 2)

39 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 38 E Ave R a i l r o a d FCP BS BP CP Industry B 7B GMQ Industry C AP M Ave MK R a i l r o a d AD P St 7B AP Industry A L e g e n d LRSA Sewer Sampling Location Industry Sampling Location (A,B &C) P = process, S = storm water, D = dry weather flow Sewer Line Street Railroad Property Boundary (approximate) N AD RLD Relief Line SM H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 2. Sampling Locations for Phase IV Tier 3

40 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 39 E Ave 7B 38 R a i l r o a d FCP NM GMQ 150 L Ave 2 BP <1 CP Industry C Industry B AP 5 M Ave MK 630 R a i l r o a d AD P St 38 5 L e g e n d Industry A LRSA Sewer Sampling Location with Total PCBs (ng/l) Industry Sampling Location (A,B &C) with Total PCBs (ng/l); P = process, S = storm water, D = dry weather flow; NM = not monitored Sewer Line Street Railroad Property Boundary (approximate) N 19 AD RLD 84 Relief Line SM 114 H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 3. Total PCB Concentrations (ng/l) for Round 1 by Tier 3 Sampling Location

41 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 40 E Ave 7B 36 R a i l r o a d FCP NM GMQ 8 NM BP <1 CP Industry C Industry B AP 44 M Ave MK 462 R a i l r o a d AP 20 P St 38 5 L e g e n d Industry A LRSA Sewer Sampling Location with Total PCBs (ng/l) Industry Sampling Location (A,B &C) with Total PCBs (ng/l); P = process, S = storm water, D = dry weather flow; NM = not monitored Sewer Line Street Railroad Property Boundary (approximate) N 97 AD RLD 97 Relief Line SM 70 H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 4. Total PCB Concentrations (ng/l) for Round 2 by Tier 3 Sampling Location

42 P St Tier 3 of the Phase IV PCB Trackdown at LRSA Page 41 E Ave FCP R a i l r o a d BS Industry C Industry B M Ave R a i l r o a d 38 5 Industry A L e g e n d LRSA Sewer Sampling Location with Total PCBs (ng/l) Industry Sampling Location (A,B &C) with Total PCBs (ng/l); P = process, S = storm water, D = dry weather flow; SW = storm water insert at Manhole RLD Sewer Line Street Railroad Property Boundary (approximate) N RLD-SW 412 Relief Line H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 5. Total PCB Concentrations (ng/l) for Other Tier 3 Locations Sampled After Round 2

43 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 42 E Ave 7B 0.2 R a i l r o a d FCP NM GMQ NM <0.1 BP <0.1 CP Industry C Industry B AP<0.1 M Ave MK 4.5 R a i l r o a d AP NM P St L e g e n d Industry A LRSA Sewer Sampling Location with Total PCB Loadings (g/day) Industry Sampling Location (A,B &C) with Total PCB Loadings (g/day); P = process, S = storm water, D = dry weather flow; NM = not monitored Sewer Line Street Railroad Property Boundary (approximate) N <0.1 AD RLD 0.6 Relief Line SM 0.8 H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 6. Total PCB Loadings (g/day) for Round 1 by Tier 3 Sampling Location

44 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 43 E Ave 7B 0.2 R a i l r o a d FCP NM GMQ NM NM BP <0.1 CP Industry C Industry B AP 0.2 M Ave MK 3.3 R a i l r o a d AP <0.1 P St L e g e n d Industry A LRSA Sewer Sampling Location with Total PCB Loadings (g/day) Industry Sampling Location (A,B &C) with Total PCB Loadings (g/day); P = process, S = storm water, D = dry weather flow; NM = not monitored Sewer Line Street Railroad Property Boundary (approximate) N <0.1 AD RLD 0.7 Relief Line SM 0.5 H St R St S St To Manhole 8 and WWTP Sn St Rt O & N Figure 7. Total PCB Loadings (g/day) for Round 2 by Tier 3 Sampling Location

45 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 44 Percent PCB Homolog Abundance Round 1 Round 2 Mono Di Tri Tetra Penta Hexa Hepta Octa Nona Deca PCB Homologs Percent PCB Homolog Abundance Round 1 Round 2 Mono Di Tri Tetra Penta Hexa Hepta Octa Nona Deca PCB Homologs Figures 8 and 9. PCB Homolog Distributions for Industry A s Dry Weather Flow (top) and Industry A s Final Discharge (bottom)

46 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Percent PCB Homolog Abundance Mono Di Tri Tetra Penta Hexa Hepta Octa Nona Deca PCB Homologs Industry A Dry Flow (Round 2) Avg MMK, MRLD & MSM Percent PCB Homolog Abundance Insert - Water Insert - Sediment Avg MMK, MRLD & MSM Mono Di Tri Tetra Penta Hexa Hepta Octa Nona Deca PCB Homologs Figures 10 and 11. Comparison of Average PCB Homolog Distributions for Manholes MK, RLD and SM Versus Industry A s Dry Weather Flow (top) and Manholes MK, RLD and SM Versus Manhole RLD Storm Water Insert (bottom).

47 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Percent PCB Homolog Abundance Avg MGMQ Avg MMK, MRLD & MSM Mono Di Tri Tetra Penta Hexa Hepta Octa Nona Deca PCB Homologs Figure 12. Comparison of Average PCB Homolog Distributions for Manholes MK, RLD and SM Versus Manhole GMQ.

48 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 47 Figures 13 and 14. Installation of Fabricated Storm Water Insert in Manhole RLD (top) and After Collection of Storm Water Runoff (bottom)

49 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 48 Appendix A Standard Operating Procedures: SOP #6A - Collection of Potable Water SOP #6B - Collection of Storm Water Using Manhole Insert

50 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 49 SOP #6A Collection of Potable Water Samples of potable water will be collected from water taps at WWTPs owned or operated by NJHDG members. Samples from the individual WWTPs will be composited into a single sample for analysis. 1. The sampling location will be a tap on a sink in a relatively clean area such a breakroom, kitchen or administrative staff restroom. The sink should be clean and provide sufficient space to fill a 1-L container under the cold water tap without touching the sink or tap. 2. Open the cold water tap at about half way and allow it to run for at least three minutes to purge any sediment or debris that may be in the line. 3. Lay aluminum foil on a nearby bench or table. 4. After three minutes, don nitrile gloves and remove a 1-L certified clean glass jar from its protective plastic bag. Hold the jar under the cold water tap and fill it about 4/5 full. The jar should not be in contact with the sink or the tap. 5. After filling the jar, place it on the aluminum foil and affix a label. Add the sampling date and time and place it back into the plastic bag. 6. Note the sampling location and other observations such as water clarity on a Field Record (separate form for each location). Note the sampling date and time on a COC form (separate form for each location). 7. Place the sample into a cooler with freezer paks and bubble wrap and delivered to LRSA for processing. 8. At LRSA, prepare a bench for the sample compositing by rolling out aluminum foil. Mix each individual sample well and pour them into a pre-cleaned 2 ½ gal glass container. If the 2 ½ gal container is full before all 1-L samples are added, note the samples that are not added, set them aside and proceed to the next step. 9. Mix the 2 ½ gal container well and distribute aliquots to six 1-L certified clean glass jars (not the jars that were used for sampling) and additional containers provided by LRSA s laboratory. Mix the sample well before distributing to each jar. 10. Affix labels on the aliquot jars and note the beginning and ending date and time for collection of the individual WWTP samples on each label. Place the jars into protective plastic bags and refrigerate in a secure location at 4 o C.

51 Tier 3 of the Phase IV PCB Trackdown at LRSA Page Complete COC forms for the six 1-L certified glass jars and the additional LRSA containers. 12. ASC will take custody of the samples in the near future.

52 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 51 SOP #6B Collection of Storm Water Using Manhole Insert The NJHDG proposes to evaluate the use of protective covers (inserts) for preventing contaminated storm water and sediment from entering sanitary sewers through manhole covers. Many manhole covers do not form a watertight seal with the manhole opening and some have holes for lifting. A manhole insert will be purchased and inserted in a manhole in LRSA s area of concern. Following a significant storm (>0.25 in 24 hours), the storm water and sediment captured in the insert will be collected and analyzed for PCBs. 1. Measure the manhole opening at Manhole RLD, which is located near the construction entrance to Industry A. Manhole RLD is the point where the Relief Line diverges from LRSA s main western sewer line. This manhole is in an area that is prone to flooding in wet weather. Storm water runoff often deposits soil on the manhole cover. 2. ASC will order a stainless steel insert to fit the Manhole RLD opening. 3. Upon receipt, clean the insert as follows: Wash with hot water and detergent. Allow the insert to air dry completely. Rinse the inside of the insert twice with acetone. Rinse the inside of the insert twice with hexane. Wrap the insert in aluminum foil. 4. A NJHDG sampling crew will install the insert one to two days before a forecast storm (>0.25 in 24 hours). Upon arrival at Manhole RLD, the crew will remove the manhole cover and scrape dirt off the edges of the manhole opening. The crew will then don nitrile gloves, remove the aluminum foil from the insert, place the insert in the manhole opening and replace the manhole cover. 5. Following the storm, the NJHDG crew will return to Manhole RLD and remove the manhole cover. Aluminum foil will be placed on the ground nearby and sampling jars will be placed on the foil. 6. If the insert is too heavy or awkward to pull out without spilling the captured water, a certified-clean glass jar can be used to dip water out of the insert and place it into a second certified-clean jar. Water and sediment will be collected into separate 1-L and 250-mL jars, respectively. When the insert is light enough to lift out of the manhole, the remaining water can be poured into the sample jar. Sediment will be scraped into its sample jar using pre-cleaned, stainless steel spatulas.

53 Tier 3 of the Phase IV PCB Trackdown at LRSA Page After filling the jars, place them on aluminum foil and affix labels. Add the sampling date and time, cover the labels with clear packing tape and place the jars into plastic zip-lock bags. 8. Place the samples into a cooler with freezer paks and bubble wrap and deliver it to LRSA for processing. 9. At LRSA, prepare a bench for the sample processing by rolling out aluminum foil. If less than two liters of water was collected, open the 1-L jars and composite the sample by pouring the half of the contents back and forth between the jars at least five times. Cap the jars and refrigerate the sample. If more than three liters of water was collected, mix the sample in the 1-L jars and pour it into a pre-cleaned 2 ½ gal glass container. Mix the 2 ½ gal container well and distribute aliquots to three or more 1-L certified-clean glass jars (not the jars that were used for sampling) and an additional 250 ml container provided by LRSA s laboratory. Mix the sample well before distributing to each jar. 10. Affix labels on the aliquot jars and note the date and approximate time of collection on each label. Place the jars into protective plastic bags and refrigerate at 4 o C. 11. The sediment sample will be composited after freeze drying (see SOP #8). 12. Complete COC forms for the water and sediment samples to be analyzed for PCBs and for the 250-mL sample to be analyzed for TSS by LRSA s laboratory. 13. ASC will take custody of the samples to be analyzed for PCBs.

54 Tier 3 of the Phase IV PCB Trackdown at LRSA Page 53 Appendix B Field Records for Tier 3 Sampling

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