Document Dxq3NjKOpZMR4nMjdVmO7oEd

Vista Chemical Company 900 Threadneedle Houston, Texas 77079 (713} 588-3000 P.O. Box 19029 Houston, Texas 77224 Fox (713) 588-3236 CERTIFIED MAIL RETURN RECEIPT REQUESTED August 6, 1991 Mr. Robert M. Akin Vice President-Petro Chemicals E. I. Dupont de Nemours & Company 1007 Market Street, Suite N6404 Wilmington, Delaware 19898 TGG: JCL: XF:____ AJO: RA /I Mr. C. H. Lee Executive Vice President Refining, Marketing, Supply & Transportation Conoco, Inc. P. 0. Box 2197 Houston, TX 77252 Gentlemen: Pursuant to 15.1 and 12.5 of the Asset Purchase Agreement letters dated July 20, 1984, between E. I. Dupont De Nemours & Company, Conoco, Inc,, and Vista Chemical Company (Vista), we hereby provide notice of recently-discovered information that may lead to the filing of an Environmental Claim. Vista has received inquiries from USEPA regarding our potential involvement in the White Chemical Superfund Site in Newark, New Jersey. The initial inquiry was addressed to Vista Chemical and was, in our judgement, in reference only to Vista Chemical product shipments to White Chemical (Attachment 1). However on July 29 we received a Request for Information from EPA that included a time period from 1982 to September, 1990 (Attachment 2)m. "It is for this reason that we are notifying^.^ou- of this action. For your information, at this time we believe we have made only one drum quantity sale of ALFOL* 6 Alcohol to White. Sincerely, Thomas G. Grumbles, C.I.H. Manager Environmental Affairs dlj Attachment cc: L. L. Zimmerman J. Christopher-Conoco VVV 000007442 ft UocVnmaa H I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II JACOB K. JAVITS FEDERAL BUILDING NEW YORK. NEW YORK 10278 June 21, 1991 ' CERTIFIED MAIL RETURN RECEIPT REQUEST Vista Chemical 9794918-00 PO Box 75422 Charlotte, NC company 75422 Re: White Chemical Corporation Superfund Site Newark, Essex County, New Jersey Dear Sir/Madam: The United States Environmental Protection Agency {EPA) is charged with responding to the release or threatened release of hazardous substances into the environment and with enforcement responsibilities under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, 42 U.S.C. Section 9601 et sea. EPA has documented the release or threatened release of hazardous substances, pollutants, or contaminants into the environment at the White Chemical Corporation Site (Site) located at 660 Frelinghuysen Avenue, Newark, New Jersey. EPA has spent, and is considering spending additional public funds on actions to investigate and control such releases or threatened releaflw* 2Tt the Site' This letter constitutes official notification to you that EPA may conduct or require potentially responsible parties (PRPs) to conduct remedial action, as defined in the National Contingency Plan, 40 C.F.R. Part 300, at the White Chemical Corporation Superfund Site. This letter is also to advise you that EPA has in its possession information which may lead to your company being designated as a PRP for the White Chemical Corporation Site. Enclosed is a list of other companies that have been identified by EPA to date, which may also be designated as PRPs. PRPs under CERCLA include current to former owners and operators on the Site as well as persons who arranged for disposal or treatment of hazardous substances sent to the Site, or persons who accepted hazardous substances for transport to the Site. VVV 000007443 2 PRPs may be liable for any costs incurred by the government in responding to any release or threatened release at the Site. Such response actions and costs may include, but not be limited to, expenditures for conducting a focused feasibility study (FFS), an early remedial response action, and other future investigations, planning, response, oversight, and enforcement activities. In addition, PRPs may be required to pay for damages for injury to, destruction of, or loss of natural resources, including the cost of assessing damages. In preparation for these response activities, EPA has prepared a Proposed Plan for an early remedial response action at the Site. A copy of the Proposed Plan is enclosed. The Plan is based primarily upon the FFS for the Site performed by EPA and presents a summary of the remedial alternatives developed for the White Chemical Corporation Site and a preliminary selection of a preferred remedial alternative. Before making a final selection of a remedial alternative, EPA will evaluate public comments regarding the Proposed Plan. The public comment period ends on July 22, 1991, therefore, please submit any comments on or before this date. After that time, EPA plans to select a remedy for the Site. Comments should be addressed to: U.S. Ms. Silvina Fonseca Remedial Project Manager Environmental Protection Agency - Region II 26 Federal Plaza, Room 711 New York, New York 10278 If there are any questions on this matter, please contact Bruce Aber, Esq., of the Office of Regional Counsel at (212) 264-5547. Sincerely yours, ^Kathleen C. Callahan, Director ' Emergency and Remedial Response Division Enclosure vw 000007444 Superfund Update EPA Region 2__________ 4-^ {2,vd*- <n^ I yj^^\^rrA White Chemical Corporation Site ^ ^ Newark, New Jersey June_1991 PROPOSED PLAN WHITE CHEMICAL CORPORATION SITE PURPOSE OF PROPOSED PLAN This document describes the Proposed Plan developed by the U.S. Environmental Protection Agency (EPA), in conjunction with the New Jersey Department of Environmental Protection (NJDEP), for the remediation of surface contamination at the White Chemical Corporation Superfund site. It also outlines all of the remedial alternatives evaluated for the site and presents the rationale used to make a preliminary selection. The preferred alternative is based on one key document: the Focused Feasibility Study (FFS) report, which characterizes the site and describes the nature and extent of the contamination present, and describes how the various remedial alternatives were developed and evaluated. The remedy proposed in this document is an early remedial response which addresses the surface contamination on the site. OOOO074*5 This Proposed Plan is being distributed as required by Section 117 of the Comprehensive Environmental Response, Compensation and Liability Act of 19S0 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), along with the draft FFS report, to solicit public comment regarding the most acceptable way to clean up the surficial contamination found at the White Chemical Corporation site. Detailed information on any of the material included in the Proposed Plan may be found in the FFS report. This report has been placed at an information repository located at the Newark Public Library, 5 Washington Street, Newark, New Jersey. Additional documentation regarding the proposed remedy is available in the administrative record for the site. A copy of the administrative record, as assembled to date, is located at the Newark Public Library. It is also available at EPA's regional office at 26 Federal Plaza in New York. COMMUNITY ROLE IN THE SELECTION PROCESS EPA relies on public input to ensure that the remedy selected for each Superfund site is fully understood and that the agency has considered the concerns of the local community prior to selecting the final remedy, as well as ensuring that the selected remedy provides an effective solution. This Proposed Plan and the FFS report are being made available to the public during the public comment period. Written comments on the Proposed Plan or the FFS report will be welcomed through July 22, 1991, and, if received by that date, will be considered in the Record of Decision (ROD) which will formally document the selected remedy. All written comments should be addressed to: Ms. Silvina Fonseca Remedial Project Manager U.S. Environmental Protection Agency - Region II 26 Federal Plaza - Room 711 ,w New York, NeAS^Sort 10278 The final remedy selection will be documented in the ROD only after consideration of all comments on the FFS report and any of the remedial alternatives addressed in the Proposed Plan. A public meeting has been scheduled for 7:00 p.m. on July 11,1991 at the Senior Citizen Complex located at 130 Dayton Street, Newark, New Jersey, to present both the findings of the FFS report and the Proposed Plan, and to solicit comments on these documents. vvv 000007446 2 SITE BACKGROUND The White Chemical Corporation site is a 4.4-acre, inactive facility that formerly manufactured acid chlorides and flame retardant compounds. The site is located at 660 Frehngnuysen'Avenue ill u heavily populated and industrialized area of Newark, Essex County, New Jersey. The site is located immediately east of two large manufacturing facilities; a feather company and a sportswear manufacturer. A large clothing manufacturing company is located north of the site. The eastern border of the site is adjacent to the Conrail railroad line, a major rail corridor to New York City. The Newark brewery of Anheuser-Busch, Inc., is located on the far side of the railroad line. Approximately one-half mile further east are U.S. Highways 1 and 9, and Newark International Airport. Weequahic Park, several large housing complexes and several high-rise senior citizen homes are present near the site. There is a daytime population of approximately 12,000 within a one-quarter mile radius of the site. In September 1970, Central Services Corporation (CSC) purchased the property on which the site is located from the Union Carbide Corporation. It is believed that much of the present site infrastructure, including sewer and utility conduits and buildings, may date from the time of Union Carbide's ownership. CSC sold the property to the Lancaster Chemical Company, a division of AZB Corporation, in August 1975. In 1983, the White Chemical Corporation (WCC) moved its operations from Bayonne, New Jersey, to the present site in Newark. WCC ceased operation in July 1990. Five major buildings are located on the site, as well as three smaller, facility support buildings. Tanks are present in three areas of the property, and 55-gallon drums are located primarily in an area east of the buildings. The site is secured by a chain-link fence that was installed by EPA in 1990. In addition, EPA is maintaining 24-hour security at the site. NJDEP conducted several inspections of the facility between June and September 1989 pursuant to the Resource Conservation and Recovery Act (RCRA). During these inspections NJDEP issued Notices of Violation (NOVs) for improper drum management, leaking drums, open containers, and inadequate aisle space. On September 22, 1989 the site was reinspected and it was noted that the facility had attained only partial compliance. As a result, an Administrative Order and penalty was issued by NJDEP on March 15, 1990. According to NJDEP, WCC never complied with the order and never paid the penalty. VVV OOOOG7A47 3 From March 27 through March 29, 1990, NJDEP reinspected the facility and again found many RCRA violations. As a result, NJDEP issued NOVs under the New Jersey Spill Compensation and Control Act and ordered WCC to immediately remediate all spills and other violations. WCC never complied with the NOVs. On May 8, 1990, NJDEP issued a Directive to WCC pursuant to the New Jersey Spill Compensation and Control Act, in order to secure the perimeter of the facility, provide 24-hour security and attempt to stabilize drums located on the premises. WCC never responded to the Directive. In early 1990, NJDEP issued Directives to WCC to clean up the site. No response to the Directives was received. Consequently, on May 15, 1990, NJDEP initiated a removal action, under the New Jersey Spill Compensation and Control Act. However, after removing approximately 1,000 drums, NJDEP reached its project ceiling of $825,000 and was forced to suspend operations in August 1990. As a result, on August 24, NJDEP requested that EPA consider taking a removal action at the site. On September 7, 1990, EPA performed a preliminary assessment of the White Chemical facility and found numerous air- and water- reactive materials in 55gallon drums. These materials were releasing acid gases into the ambient air. At that time, EPA overpacked 11 of the drums and secured them for future handling. During this assessment, numerous RCRA violations were discovered. On September 28, the Agency for Toxic Substances and Disease Registry (ATSDR) issued a health consultation that concluded that the site poses an imminent and substantial health and safety threat to nearby residents and workers. A Public Health Advisory was later issued in November 1990. EPA performed supplementary assessments on October 2 and 4, 1990 which included the laboratory located on the site. The laboratory, which consists of several rooms, contained flammable liquids, corrosives, acids, oxidizers, shocksensitive materials, and air- and water- r^^tive materials. In December 1990, a room containing a large volume of explosive material was found, along with a pallet of shock-sensitive material. Removal actions currently in progress include drum overpacking on an emergency basis, segregating incompatible substances, and further assessing the nature of the chemicals present. Approximately 12,000 laboratory containers have been restaged and inventoried, however, the results of the inventory have not yet been compiled. Based on the known contamination present, EPA proposed the White Chemical Corporation site for inclusion on the National Priorities List (NPL) of Superfund sites on May 9, 1991. Recognizing the nature and complexity of the site, EPA is 4 VVV 000007448 undertaking a multi-tiered approach to addressing the contamination problems at the site, which includes a removal action, an early remedial response, and a long term remedial action. FIELD INVESTIGATION SUMMARY The objectives of the field investigation for the early remedial response were to identify and characterize the potential sources of contamination, and to gather data to evaluate remedial alternatives. Because of the large number of containers present at the site, a complete inventory of the drums, tanks and laboratory containers has not been assembled. Much of the information gathered about the contaminants on the site is based on data from White Chemical's 1989 SARA Title III Survey, corporation records available to date, and information developed during the implementation of the removal action. The field investigation indicated that, subsequent to the NJDEP removal action and the removal of empty drums, approximately 10,900 drums of hazardous materials remained improperly stored and precariously stacked throughout the 4.4- acre site. Drums and other containers were found in various stages of deterioration, fuming, and leaking material onto the soiL Numerous stains were observed on the soil. Due to the on-going removal action, 4,200 empty drums have been shipped off site and approximately 6,700 staged drums remain on the site. The contents of many of the drums are unknown because of a lack of labeling or the presence of multiple labels. Other containers were found labeled "Salvage Hazardous Waste Rejected". Other containers found on the site include approximately 150 cylinders, 126 tanks, hundreds of fiberpack drums, gallon bottles, carboys, boxes, and approximately 12,000 laboratory-size containers. Most of the containers appear to be full. Some chemicals suspected to be on the site include: bromine, chromic acid, phosphorous trichloride, hydrochloric acid, xylene, fatty acids, benzene, red phosphorus, and sulfuric acid. " The laboratory present on the site contained thousands of unsegregated laboratory chemicals in deteriorating containers. These materials were haphazardly stored on structurally unstable shelving. vvv 000007449 5 SCOPE AND HOLE OF ACTION The remediation of the site is complicated by the quantity and condition of surface contamination. This remedy will be considered an early remedial response, based on the FFS report. This action will address surface contamination only (e.g., drums, tanks, laboratoiy containers) and further stabilize the site until an overall, permanent remedy can be selected. Other potentially contaminated media including soil, ground water, surface water, and buildings will be addressed at a later date when an overall remedial investigation and feasibility study (RI/FS) will be performed. SUMMARY OF SITE RISKS In September 1990, EPA requested that ATSDR review site information and data for the White Chemical Corporation site, and characterize the threat to public health posed by the site. ATSDR responded to that request by performing a Health Consultation. ATSDR concluded that the threat of catastrophic release posed by the uncontrolled storage of hazardous substances, and conditions of on going release at the site, present an imminent and substantial threat to public health. Because of the limited information available as to the exact nature of the chemicals on the site, a quantitative risk assessment could not be performed as part of the FFS. However, EPA, in consultation with ATSDR, did an analysis to estimate the health problems that could result if the contamination and hazardous conditions at the White Chemical Corporation site were not cleaned up. This assessment, referred to as a Public Health Evaluation (PHE), is presented in the FFS. Because surface contaminants at the site pose a potential immediate health threat, consultations with ATSDR served as the primary supporting information for the PHE. The PHE focused on identifying chemicals of concern, evaluating pathways of exposure, describing potential receptor populations, and characterizing the consequent health hazards. Due to the limited and uncertain chemical inventory at the site, assessment of site hazards was performed by evaluating chemical classes rather than individual compounds. Many of the compounds identified at the site do not fit into any one particular category; individual compounds may have combined corrosive, oxidizing and shock-sensitive properties. The potential for toxicologic interactions between chemical classes at the site exists. However, in the absence of specific information, this type of interaction has not been considered. Chemical classes of concern at the site include flammable liquids, corrosives, oxidizing agents, and shock sensitive material. VVV 000007450 6 Exposed or potentially exposed populations include nearby residents, workers, and site trespassers. In addition, a future exposure route in case of a catastrophic fire/explosion event could result in two additional potentially exposed populations, fire-fighting personnel and railway commuters. The predominant route of exposure is inhalation for all of the potentially exposed populations, and direct contact for trespassers or fire-fighting personnel. Non-carcinogenic and carcinogenic adverse health effects have been associated with many of the contaminants identified on the site. Chronic or acute inhalation of or direct contact with site contaminants by individuals could result in deleterious health effects. The release of acid fumes has already occurred on frequent occasions. The potential for nearby residents, workers, and site trespassers to be exposed to contaminants by inhalation and/or direct contact, currently exists. Persons who suffer impaired respiratory function (e.g., asthma, bronchitis) are at greater risk than the general public. Site circumstances suggest that the present unstable situation could lead to a catastrophic release of hazardous material that would likely affect the surrounding community. Current exposures to on-site hazardous materials and the threat of a catastrophic release posed by the uncontrolled storage of materials on the site pose an imminent and substantial threat to public health. REMEDIAL ACTION OBJECTIVES Remedial action objectives have been established for the site in relation to the surface contamination sources. The objectives have been established by considering the known contamination present, the threats to public health and the environment associated with the hazards at the site, and any applicable or relevant and appropriate requirements of other Federal and State environmental laws and regulations. The objectives of this action are to address those hazards at the site that require immediate attention, and are intended to fiyfoer-stabilize the site until an overall, permanent remedy can be selected. Such an' action would continue the stabilization efforts that began with the removal action. Remedial alternatives for a permanent cleanup of the entire site will be evaluated later in an Rl/FS. The specific remedial action objectives for the site are presented below. The remedial objectives are the basis for the development and evaluation of remedial alternatives. The development of remedial alternatives is presented in more detail in the FFS. The drums, tanks and small containers/gas cylinders located at the site pose several imminent hazards to public health and the environment. Many of the 7 VVV 000007451 drums and tanks contain hazardous substances that would pose an immediate threat if they leaked from these containers. Many of the containers are deteriorated and may leak unless they are addressed by an expedited action. The objectives of the early remedial response for the drums, tanks and small containers/gas cylinders are to: 1. Prevent ingestion/inhalation/direct contact with hazardous substances at concentrations posing a potentially imminent and substantial endangerment; and 2. Prevent releases of hazardous substances that would result in or form a catastrophic event (e.g., explosion, fire, generation of contaminant plume) or migration of hazardous substances that would result in contamination of ground water, surface water, soil, or releases into the atmosphere. Actual or threatened releases of hazardous substances from this site, if not addressed by the preferred alternative or the other active measure considered, may present a current or potential threat to public health, welfare, or the environment. FOCUSED FEASIBILITY STUDY Information obtained from the field investigation and the on-going removal action was used to conduct the FFS. The FFS report provides a detailed evaluation of various options, referred to as remedial alternatives, to remediate the site. Remedial alternatives were evaluated based on the nine criteria identified in the FFS report and described later in this document. SUMMARY OF REMEDIAL ALTERNATIVES The Comprehensive Environmental Response, Compensation, and Liability Act, as amended, requires that each selected site remedy be protective-of human health and the environment, comply with applic^ or relevant and'appropriate requirements (ARARs), utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable, and be cost effective. The FFS developed and evaluated, in detail, three alternatives for an early remedial response to the surface contamination at the White Chemical Corporation site that might satisfy these criteria. VVV 00000T452 8 Alternative 1: No Further Action Estimated Capital Cost: Estimated Present Worth of Five-Year Review: $0 $ 38,000 The Superfund program requires that the "no action" alternative be evaluated at every site to establish a baseline for comparison of alternatives. Under this alternative, EPA would take no further action to address contamination at the site. (While the on-going removal action will complete additional site stabilization tasks, EPA's removal authority does not maintain the capacity to complete a removal action of this magnitude and at the same time retain the resources necessary to respond to other emergency situations at other sites. It has been conservatively assumed here that the removal action would not complete any additional work.) The potential for exposure to contaminants is not reduced in this scenario, and exposure-related risks will remain similar to those discussed earlier. The access restrictions (i.e., fencing, warning signs) that were installed and maintained under the removal action would remain in place, but no further maintenance would be provided. However, a review would be conducted after five years to determine site conditions at that time. Alternative 2: Site Stabilization and On-site Storage Estimated Capital Cost: Estimated Annual Operation and Maintenance (O & M) Costs: Estimated Present Worth: Implementation Timeframe: O & M Timeframe: $ 7,767,000 $ 2,652,000 $18,062,000 2 years 5 years This alternative, site stabilization and on-site storage, is an interim response action that would be a continuation and modification of the removal action currently in progress. Only limited measures would betaken toward site remediation; i.e.t measures to prevent further releases to the environment. Although a percentage of the site stabilization process has been performed by the on-going removal action, it may be necessary to perform some additional activities. The alternative involves compiling an inventory of hazardous substances present and includes restaging and segregating any incompatible materials to prevent uncontrolled chemical reactions. However, it might be necessary to dispose of some of the extremely hazardous materials at off-site facilities to maintain on-site stability of the remaining chemicals. Transferring chemicals to new containers would be performed on containers that are in poor condition to prevent releases from occurring. Consolidation or bulking would be performed if sufficient quantities of compatible materials were found. They would be properly combined and stored on the site in 9 WV 000007453 tanker trucks until a final response action is taken. Empty containers would be rinsed and crushed for disposal. An emergency response contingency plan would be developed to provide a mechanism for responding to any releases, fires, etc., that might occur during the stabilization effort. Further, because large quantities of hazardous material would remain on the site, site security, extensive monitoring and an emergency response contingency plan would be maintained at the site from the completion of the interim remedial action to the initiation of a subsequent, final action for surface contamination. It is estimated that it would take two years to stabilize the site, and that on-site storage would be required for a period of five years until a final remedial action could be selected and implemented The site would be reviewed, as mandated by CERCLA, as amended, every five years while hazardous substances remain on the site. Alternative 3: Stabilization/Treatment and Off-site Disposal Estimated Capital Cost: Estimated Annual O & M Costs: Estimated Present Worth: Implementation Timeframe: $22,096,000 $0 $18,261,000 2 years This alternative includes all of the process options and materials handling techniques presented in Alternative 2, however, it also provides for the treatment and off-site disposal of material. This alternative is developed as a final remedy for the contamination sources (i.e., drums, tanks, other containers), but recognizes that additional efforts would be required to complete the overall site remediation. No measures are included in this alternative to address the potential contamination of soil, ground water, surface water, buildings, or other media. This alternative would include all of the measures employed in Alternative 2, but would also include disposal measures for removing surface contamination from the site. These disposal methods might invol^,mobilizing a treatment unit or units to the site, and treating or neutralizing some of the materials prior to off-site disposal. If untreated material were found to be sufficiently free of impurities, it would be recycled, as well as some of the treated material. Once the material has been sufficiently stabilized, bulked, and/or treated, it would be transported off the site to a RCRA-approved treatment facility, to a hazardous waste disposal facility, or to an appropriate facility for recycling or processing. Additional risks which would arise from the off-site transportation of hazardous material would he minimized by utilizing appropriate shipping containers and preparing a transportation safety contingency plan. vvv 000007^5^ 10 Extensive environmental monitoring would be conducted during the implementation of this alternative to ensure the mitigation of any releases. An emergency response contingency plan would also be developed to provide a mechanism for responding to any releases, fires, etc., that might occur during the stabilization, treatment, and off-site disposal efforts. Site security would continue until all material is removed, then security measures could be reduced. Because this would be a final remedy for the surface contamination, a five-year review would not be required. It is assumed that it would take two years to complete the source remediation under this alternative. Because all of the surface contamination sources will have been removed from the site, no operation and maintenance is anticipated for this alternative. As noted above, site security measures would be reduced, in all likelihood, to passive access restrictions, such as the existing fencing and warning signs. EVALUATION OF ALTERNATIVES The preferred alternative is Alternative 3, stabilization/ treatment and off-site disposal. Based on current information, this alternative appears to provide the best balance of trade-offs among the alternatives with respect to the nine criteria that EPA uses to evaluate alternatives. This section profiles the performance of the preferred alternative against the nine criteria, noting how it compares to the other options under consideration. A glossary of the evaluation criteria is noted below. Based on new information or public comments, EPA in consultation with the State of New Jersey, may modify the preferred alternative or select another response action presented in this Plan and the FFS report. The public, therefore, is encouraged to review and comment on all of the alternatives identified in this Proposed Plan. The FFS report should be consulted for more detailed information on these alternatives. _ GLOSSARY OF EVALUATION CRITERIA Overall Protection of Human Health and the Environment: This criterion addresses whether or not a remedy provides adequate protection and describes how risks are eliminated, reduced or controlled through treatment, engineering controls or institutional controls. vvv 000007455 11 Compliance with Applicable or Relevant and Appropriate Rprpiirpmpnt.q nf Federal or State of New Jersey Regulations: This criterion addresses whether or not a remedy will meet all of the applicable or relevant and appropriate requirements of other environmental statutes and/or provide grounds for invoking a waiver. . Long-term Effectiveness and Permanence: This criterion refers to the ability of the remedy to maintain reliable protection of human health and the environment over time once cleanup goals have been met. Reduction of Toxicity. Mobility or Volume: This criterion addresses the anticipated performance of the treatment technologies that a remedy may employ. Short-term Effectiveness: This criterion considers the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implementation period until cleanup goals are achieved. Implementabilitv: This criterion examines the technical and administrative feasibility of a remedy, including availability of materials and services needed to implement the chosen solution. Cost: This criterion includes capital and operation and maintenance costs. State Acceptance: This criterion indicates whether, based on its review of the FFS and the Proposed Plan, the State concurs with, opposes, or has no comment on the proposed alternative. VVV 0000074*56 12  flnmTnunitv Acceptance: This criterion will be addressed in the Record of Decision following a review . of the public comments received on the FFS report and the Proposed Plan. COMPARATIVE ANALYSIS OF ALTERNATIVES Overall Protection of Human Health and the Environment The No Further Action alternative would provide no further protection of human health and the environment than that afforded by the removal action to date. Deteriorating containers would continue to degrade and release hazardous substances. Small containers and gas cylinders would remain on the site in their present condition. The potential for a catastrophic event would continue and increase with the presence of non-stabilized reactive materials. Because site security measures would be discontinued, trespassing and exposures to hazardous materials could not be prevented. Alternative 2 is an interim remedial action that would provide a significant level of protection because the site would be stabilized. However, extensive monitoring, security, and preventive maintenance measures would need to be taken to preserve the protectiveness of the action. Alternative 3 would provide the greatest degree of protection of human health and the environment because, in addition to stabilizing conditions on the site, hazardous materials would be removed from the site for appropriate off-site processing or disposal. Proper materials handling techniques would be employed during the action to ensure that risks are controlled. Additional risks which would arise from the off-site transportation of hazardous materials would be minimized by utilizing appropriate shipping containers and preparing a transportation safety contingency plan. Compliance with Applicable or Relevant anETkppropriate Requirements (ARARs) Primary ARARs for the White Chemical site include Occupational Safety and Health Administration (OSHA) Standards, the Resource Conservation and Recovery Act, and the Clean Air Act. There are no chemical-specific ARARs that need to be met for implementing these alternatives. ^ 000007*57 13 Alternative 1 would not comply with ARARs because hazardous substances would remain improperly stored on the site. Releases would continue to occur, in violation of Clean Air Act and RCRA requirements. Alternative 2 would comply with most ARARs, although some RCRA requirements relating to the storage of hazardous materials would not be met. However, because the alternative is an interim measure, and could become part of a total remedial action that would attain ARARs, a basis exists under the National Oil and Hazardous Substances Pollution Contingency Plan for invoking a waiver. Alternative 3 would comply with ARARs. Activities related to the handling of wastes would comply with all ARARs, including OSHA requirements. Off-site transportation of hazardous materials would be accomplished in accordance with Department of Transportation regulations and hazardous waste management requirements. Materials removed from the site would be treated, processed, or disposed of in accordance with RCRA requirements. Reduction of Toxicity. Mobility, or Volume Through Treatment The No Further Action alternative would not reduce the toxicity, mobility, or volume of contaminants to any degree. Additionally, the mobility of the contaminants may significantly increase as the deteriorating containers continue to degrade. In the event of a fire, the toxicity and mobility of the contaminants could also increase. Alternative 2 would reduce the mobility of the contaminants through the site stabilization effort, however, this reduction would not be achieved through treatment. Although this alternative provides for the removal of extremely hazardous materials, the volume of hazardous substances remaining on the site would not be substantially reduced Further, there would be no reduction in the toxicity of the material remaining on the site. Alternative 3 would reduce the toxicity, nyfeiliiy, and volume', through treatment, of much of the hazardous substances present at the site. The alternative also provides for the recycling of as much material as practical. Short-Term Effectiveness Alternative 1 would provide no short-term, effective remedial measures. Alternatives 2 and 3 would begin to be effective as they are implemented Both alternatives are expected to be fully effective within a two-year period Alternative 2 involves the implementation of extensive monitoring and maintenance programs to ensure its effectiveness for both the short- and long-term. VVV 000007459 14 Potential adverse impacts could occur under Alternatives 2 and 3 during their implementation. Proper materials handling practices would need to be employed to minimize the potential for short-term adverse impacts under both alternatives. Alternative 3 would provide an additional potential for short-term impacts through the off-site transportation of hazardous materials; however, these concerns could also be addressed through the preparation of a transportation safety contingency plan. Long-Term Effectiveness and Permanence . The No Further Action alternative provides no long-term effectiveness and would result in significant risks to human health and the environment remaining at the site. This alternative provides no permanent remedy of site conditions. Alternative 2 is an interim remedy that provides for extensive monitoring and maintenance activities to ensure its effectiveness for an estimated five-year period. It would be necessary to continue the interim action beyond that period, or implement a more permanent remedy, to provide long-term effectiveness and permanence. Alternative 3 would be effective in the long-term because the most serious threats posed by the site would be removed for off-site treatment, processing, or disposal. The remedy is considered permanent for the sources of the contamination; however, additional measures would need to be taken to remediate the contamination potentially remaining at the site in other media, such as soil and ground water. Implementabilitv There are no remedial measures to be implemented under the No Further Action alternative. Alternative 2 is easily implemented and, ipjacfr, is an extension of the removal action currently in progress at the site. The necessary materials and equipment are readily obtained. Sufficient personnel trained in the proper techniques are available. Alternative 3 is also an extension of the removal action and provides for treatment and off-site disposal of material. This alternative is also easily implemented. As with Alternative 2, the necessary materials and equipment are readily obtained. Sufficient personnel trained in the proper techniques are also available. 15 WV 000007459 Because no actions are taken, other than a one-time monitoring event to review site conditions after five years. Alternative 1 has the lowest present worth, which is estimated to be $38,000. Conversely, Alternative 3, involving the most comprehensive cleanup approach, has the highest present worth. It is estimated to be $18,261,000. The estimated present worth of Alternative 2 is $18,062,000. State Acceptance The State of New Jersey supports the preferred remedial alternative presented in this Proposed Plan. Community Acceptance Community acceptance of the preferred alternative will be evaluated after the public comment period ends and will be described in the Record of Decision for the site. SUMMARY OF THE PREFERRED ALTERNATIVE In summary, the preferred alternative is believed to provide the best balance among alternatives with respect to the evaluation criteria. Therefore, based on the information available at this time, EPA and the State of New Jersey believe the preferred alternative will be protective, will attain ARARs, will be costeffective, and will utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. VVV 000007460 This sheet is CONFIDENTIAL and shouid not be distributed outside VISTA Chemical Co. Special ID: ALFOL 10 ALCOHOL 1-DECANOL FOR SHEREX ONLY TEST TOTAL ALCOHOL, WT% DISTRIBUTION (100% ALCOHOL) C80H AND LOWER, WT% CIOOH, WT% C120H AND HIGHER, WT% ALCOHOL COLOR APHA METHOD WATER, WT% ACID, AS ACETIC, WT% IODINE NUMBER CARBONYL, AS C = 0, PPM SPFCIFTCATTON 98.5 MIN 0.3 MAX 98 MIN 10 MAX 0.15 MAX 0.005 MAX 0.2 MAX 100 MAX Spec. No. 03-4030-02 PROPERTY 99.2 0.1 99.3 0.6 0 0.04 0.001 0.06 25 METHOD V2.000 V2.000 V2.000 V2.000 V1J295 V13SQ Vl.430 V1.510 V1.515 10-May-90 VVV OOOOOT461 i White Chemical Data System Mailing List Owners and Operators Transporters Bee Line 6 Gardner Road Fairfield, NJ 07006 Bilgrey Cargo, Inc. 150-40 183rd Street Springfield Gardens, NY 11413 Brown/Thurston Transportation Co. Brown/Thurston Transort Co. 600 Johnson Road Charlotte, NC 28206 Matlack, Inc. P.O. Box 1791 Wilmington, DE 19803 McLean Trucking Company P.O. Box 213 Winston-Salem, NC 27154 Miller Transporters, Inc. P.O. Box 1123 Jackson, MS 39215 Moore Transport Inc. 2710 North West Ave P.O. Box 1816 El Dorado, AR 71731 Moores Trucking P.O. Box 817 Stelton Rd Piscataway, NJ 08854 P.I.E. Nationwide 115 Moonachie Ave Moonachie, NJ 07074 Penta International Corp. PO Box 1448 Fairfield, NJ 07007 Quality Carriers 3108 central Drive Plant City, FL 33567 vvv 000007462 1 White Chemical Data System Mailing List Transporters (continued) Rutgers Express 6 Connerty Court East Brunswick, NJ 08816 SCA Chemical Services Co. Earthline Division 100 Lister Avenue Newark,, NJ 07105 SCA Chemical Services Co. SCA Model City Landfill P.O. Box 200 Model City, NY 14407 Shanahan*s Express, Inc. 2201 Garry Rd Cinnaminson, NJ 08077 Sicomac Carriers 273 New Road Parsippany, NJ 07054 St. Johnsburg Trucking Co. 38 Main St Jay, VT 05819 Sterns Transport P.O. Box 397 Bradley Beach, NJ 07720 Superior Carriers P.O. Box K Kenvil, NJ _ 07847 Superior Carriers 95 Madison Avenue Morristown, NJ Yellow Freight Systems, Inc. C/O Yellow Forwarding Company P.O. Box 7903 10990 Roe Ave Overland Park, KS 66207 Yellow Freight Systems, Inc. 335 Delancey St Newark, NJ 07105 VVV 000007463 2 White Chemical Data System Mailing List Transporters (continued) Generators 3M Company Box 33131 St. Paul, MM 55133 ACI Chemicals, Inc. 17 Barstow Road Great Neck, NY 11021 Abbott Labs P.O. Box 177 1400 Sheridan Road, 13th North Chicago, IL 60064 St. Entrance Ace Scientific Supply Co.,Inc. 40-A Cotters Lane P.O. Box 1018 East Brunswick, NJ 08816 Aetna Chemical Corporation P.O. Box 430 Wallace Street Extension Elmwood Park, NJ 07407 Air Products and Chemicals, Inc. P.O. Box 8500 S-4165 Philadelphia, PA 19178 Air Products and Chemicals, Inc. 7201 Hamilft$ Bivd. Allentown, PA 18195 Air Products and Chemicals, Hometown Facility P.O. Box 351 R.D. 2 Tamaqua, PA 18252 Inc. Air Products and Chemicals, Inc. P.O. Box 538 Allentown, PA 18105 Albright & Wilson, Inc. P.O. Box 26229 Richmond, VA 23260 Wv 0007464 3 White Chemical Data System Mailing List Generators (continued) Alcolac 3440 Fairfield Road Baltimore, MD 21226 Alden Leeds, Inc. 55 Jacobus Ave. South Kearny, KJ 07032 Aldrich Chemical Company,Inc. P.O. Box 355 Milwaukee, WI 53201 Aldrich Chemical Company,Inc. 1001 West St. Paul Milwaukee, WI 53233 Aldrich Chemical Company,Inc. 230 S. Ember Lane Milwaukee, WI 53233 Almet, Inc. 300 Hartzell Road P.o. Box 346 New Haven, IN 46774 Alnort Processing Co. 2500 Broadway Camden, NJ 08104 Alnort Processing Co. 2430 Broadway Camden, NJ-^tB8ID4 V Aluchem 01 Landy Lane Reading, OK 45215 Amchem Products, Inc. Parker and Amchem 32102 Stephenson Highway Madison Heights, MI 48071 Ameribrom, Inc. 1250 Broadway New York, NY 10001 American Cyanamid Company 1 Cyanamid Plaza Wayne, NJ 07470 4 VVV 000001*65 White chemical Data System Mailing List Generators (continued) American Cyanamid Company P.o. Box 1809 Clifton, NJ 07002 American Cyanamid Company Clarksville Road Peton, NJ 08540 American Cyanamid Company p.o. BOX 390 Bound Brook, NJ 08805 American Fast Print Hwy 1-85 at Bryant Road P.O. Box 5765 Spartansburg, SC 29304 American Hoechst Route 202-206 North Somerville, NJ 08876 American Hoechst 1250 West Mock Yard Lane Dallas,, TX 75247 American International Chemical 27 Strathmore Road Natick, MA 01760 American Leather 2195 Elizabeth Avenue Rahway, NJ 07065 ," Ametek Microfoam Division, Inc. Brandywine Four Bldg. Routes 1 and 202 Chadds Ford, PA 19317 Amoco Research Center Warrenville Road & Mill Street Naperville, IL 60566 Anax R & D Lab 5950 McIntyre Avenue Golden, CO 80403 Apache Chemical, Inc. 16161 sixth street P.O. Box 126 Seward, IL 61077 VVV 000007466 5 White Chemical Data System Hailing List Generators (continued) Appropriate Technology P.O. Box 975 Technology Drive Brattleboro, VT 05301 Aptec, Inc. P.0. Box 1726 25 South Shore Drive Toms River, NJ 08753 Arkansas Eastman Company P.O. Box 2357 Batesville, AR 72501 Ashland Chemical Division P.O. Box 2219 Columbus, OH 43216 Ato Chem 266 Harristown P.O. Box 607 Glen Rock, NJ Road 07452 Atomergic Chemetals Corp. 91 Carolyn Blvd. Farmingdale, NY Aztec Chemicals 2190 North Loop West, Suite 202 Houston, TX 77018 B & P Chemical Co^gpny, Inc. 128 Boser Drive Oakland, NJ 07436 B&P Environmental Resources 555 Goffle Road Ridgewood, NJ 07451 B.F. Goodrich Corporation 9921 Brecksville Road Brecksville, OH 44141 B.P.F. 301 E. Meadowview Road Greensboro, NC 27420 B.P.F. Hr. H. Bennett B.R. Laboratory 714 West 5lst Street Miami Beach, FL 33140 VVV 000007467 White Chemical Data system Mailing List Generators (continued) B.W. Services, Inc. P.O. Drawer 2300 Keystone Heights, FL 32656 BASF Wyandotte Corporation 100 Cherry Hill Road P.O. Box 181 Parsippany, NJ 07054 BGF Industries, Inc. 401 Amherst Ave. Altavista, VA 24517 BTS Incorporated P.O. Box B14 300 Communipaw Ave. Jersey City, NJ 07304 Badische Corporation Mr. Bob Oats Marketing Badische Corp. P.O. Drawer D Williamsburg, VA 23187 Basic Transportation Inc. 110 Shrewsbury Drive Livingston, NJ 07039 Bedoukian Research Inc. Mr. Tom Csengery Finance Drive Commerce Pac& " Danbury, CT' 06810 ," Beecham Inc. Mr. Richard Goltermann Three Garret Mountain Plaza West Patterson, NJ 07424 Belding Corticelli Thread Co. 107 Providence St. Putnam, CT 06260 Bergen Barrel & Drum Co. 43-45 O'Brien St. Kearny, NJ 07032 VVv 00000746a 7 White Chemical Data System Mailing List Generators (continued) Bernuth, Lembcke Co., Inc. Mr. Peter W. Gilderson President 7600 West Tidwell Road Suite 204 Houston, TX 77040 Bernuth, Lembcke Co., Inc. 999 Ponce De Leon Blvd. No. 650 Coral Gables, FL 33134 Bicron Corporation 12347 Kinsman Road Bldg. #C2 Newbury, OH 44065 Biddle Sawyer Corporation Biddle Sawyer Corp. Suite 2355 2 Penn Plaza New York, NY 10121 Bio-Life Inc. Mr. Merle McGrane p.o. Box 130 Ionia, IA 50645 Biocraft Laboratories Ms. Joy Sneyder Director of Purchasing 92 Route 4$_ -- Elmwood ParkT NJ 07407 Biodex Inc. Mr. Dave Burton 165 - 8th Street Room 306 San Francisco, CA 94103 Blue Eagle Corporation P.O. Box 377 Oak Ridge, NJ 07438 Bohager/Goodhues, Inc. Mr. Joseph A. Campanella Vice President 521 E. Joppa Road Suite 104 Towson, MD 21204 000007^.69 yvv 8 White chemical Data System Hailing List Generators (continued) Boise Cascade Corporation Mr. George McBride Specialty Paperboard Division 100 Main street P.O. Box 68 Beaver Falls, NY 13305 Bonmar Chemical'Co., Inc. Mr. Sanford Cohen P.0. Box 494 Fair Lawn, NJ 07410 Bowman Transportation, Inc. Executive Offices P.O. Box 105121 Atlanta, GA 30348 Brandywine Chemical Co. 600 Terminal Avenue New Castle, DE 19720 Brenntag Interchem, Inc. Mr. Jeffrey J. Hallamore General Manager 211 Rock Hill Road Bala Cynwya, PA 19004 Bristol-Myers Company Ms. Joanna A. Rice Industrial Division P.O. Box 4755 Syracuse, NY 13221 Bristol-Myers Company 345 Park ave. New York, NY 10154 % Brown Mat Inc. P..O. box 2069 Brownsville, TX 78522 Brunswick Defense Corporation Mr. Joe Decillis 2000 Brunswick Lane Deland, FL 32724 Brunswick Defense Corporation Bunswick Corp. Defense 1 Brunswick Plaza Skokie, IL 60077 Div. ^ 00000/470 9 White Chemical Data System Mailing List Generators (continued) Bruzynski Research Institute Mr. Linvood Clayton 12707 Trinity Drive Stafford, TX 77477 Buck Scientific Inc. 58 Fort Point Street East Norwalk, CT 06855 Burlington Industries, Inc. Box 21448 301 E. Meadowview Rd. Greensboro, NC 27420 Burlington Industries, Inc. 3330 Friendly Ave. P.O. Box 21207 Greensboro, NC 27420 CDI Dispersions P.O. Box 2639 27 Haynes Avenue Newark, NJ 07114 CEMCO P.O. Box 9797 Greensboro, NC 27429 Calgon Corporation Box 1346 Pittsburgh, PA 15230 Callahan Chemical-^O.-- 200 Industrial Ave. Ridgefield Park, NJ 07660 Cape Industries P.O. Box 1694 Wilmington, NC 28402 Cape Industries 24055 Mound Road Warren, MI 48091 Catalyst Resources,Inc. 2190 North Loop West Suite 400 Houston, TX 77018 yVV 000007471 '\, J 10 White Chemical Data System Mailing List Generators (continued) Champion Chemical 1100 Richmond Avenue, #400 Houston, TX 77042 Champion Chemical 3130 FM 521 Fresno, TX 77545 Charles Schaefer Sons, inc. P.O. Box 236 Elizabeth, NJ 07207 Charles Schaefer Sons, inc. Magee Avenue and Harding Road Union, NJ Chemical Compounds, Inc. P.O. Box 115 Netcong, NJ 07857 Chemical Dynamics Corporation 3001 Hadley Road P.O. Box 395 South Plainfield, NJ 07080 Chemical Waste Management P.O. Box 100285 Atlanta, GA 30384 Chemical Waste Management 3003 Butterfield Road Oak Brook, IL 60521 Chemland T** P.O. Box 2999 Turlock, CA 95881 % Chevron Chemical Company P.O. Box 8500 S-6965 Philadelphia, PA 19178 Chevron Chemical Company 575 Market Street San Francisco, CA 94105 vW OOOOOT^72 Chugai Boyeki (America) Corp. 500 Fifth Avenue New York, NY 10110 11 White Chemical Data System Mailing List Generators (continued) Chugai Boyeki (America) Corp. 55 Mall Drive Commack, NY 11725 Chugai International Corp. 500 Fifth Ave. New York, NY 10110 Chugai International Corp. Chugai USA Inc. 3780 Hawthorne Ct. Waukegan, IL 60087 Ciba-Geigy Corporation P.O. Box 65108 Charlotte, NC 28265 Ciba-Geigy Corporation 566 Morris Ave. Summit, NJ 07901 Ciba-Geigy Corporation Dyestuffs, Chemicals Saw Mill River Road Ardsley, NY 10502 Org/Inorg. Pigments Ciba-Geigy Corporation Plastic Additives Water 3 Skyline Drive Hawthorne, NY 10532 Treatment Ciba-Geigy Corporation, Dyestuffs ffT^Jhemicals P.O. Box 18300 Greensboro, NC 27419 Division Cinelli Scrap Metal, Inc. P.O. Box 414 Carlstadt, NJ 07072 Cinelli Scrap Metal, Inc. 130 Jacelyn Avenue Woodridge, NJ 07075 vvv 000007473 Clean Harbor Corp. P.O. Box 327 Braintree, MA 12 White chemical Data System Mailing List Generators (continued) Clean Harbor Corp. 1200 Crown Colony Drive P.O. Box 9137 Quincy, MA 02269 Colgate Palmolive 105 Hudson Street Jersey City, NJ Cometals, Inc. One Penn Plaza Suite 4901 New York, NY 10119 Commodity Chemical Corp. P.0. BOX 4397 Vero Beach, FL 32961 Continental Chemical Co. 207 Clifton Boulevard Clifton, NJ 07015 Coyne Chemical 3015 State Road Croydon, PA 19020 Crown Metro, Inc. P.O. Box 5695 Greenville, SC 29606 Crown Metro, Inc. Echelon Road Greenville, SC 29606 Crown Metro, Inc.T'* P.O. Box 5857 Greenville, SC 29606 D & O Chemical 300 Grand Ave Englewood, NJ 07631 D & 0 Chemical P.O. Box 29 Fort Lee, NJ 07024 D & 0 Chemical 291 S. Van Brunt Street Englewood, NJ 07631 VVV 00007474 13 White Chemical Data System Mailing List Generators (continued) -Dana Transport P.0. BOX 370 Avenel, NJ 07001 Deepwater Inc. 935 E. Victoria Street Carson, CA 90224 Deerborn Chemical Division 300 Genesee Street Lake Zurich, IL 60047 Delaware Container Co., Inc. West Eleventh Ave & Valley Rd Coatesville, PA 19320 Dial Corporation Fatty Acids Sales Manager 2000 Ancutt Road Montgomery, IL 60538 Diamond Shamrock Corporation TR Evans Research Center 7528 Auburn Road Painesville, OH 44077 Dixie Chemical Co. 10701 Bay Area Blvd. Pasadena, TX 77507 Dow Chemical Corp. Building 1710 _ Midland, 48640 Dow Chemical USA PO Box 1724 Midland, MI 48640 Dow Chemical USA 2020 Willard H. Bow Center Midland, MI 48674 Dow ''orning Corp. PO Box 7247-8879 Philadelphia, PA 19170 Dow Corning Corp. Dept. A0021 P.O. box 0999 Midland, MI 48686 VVV 000007475 14 White Chemical Data System Mailing List Generators (continued) E.l. duPont de Nemours & Co. Brandywine Building 7th Floor Wilmington, DE 19698 Inc. E.l. duPont de Nemours & Co. Inc. Corporate Headquarters Barley Mill Plaza Bldg. 29 Wilmington, DE 19880 E.l. duPont de Nemours & Co. Inc. 1007 Market Street Wilmington, DE 19898 EM Science 2909 Highland Avenue Cincinnatti, OH 45212 Eastern Chemical Division United-Guardian, Inc. p.o. Box 2500 Smithtown, NY 11787 Eastman Kodak Company 1041 Ridge Road West Rochester, NY 14652 Eastman Kodak Company 343 State Street Rochester, NY 14652 Eastman Kodak Company-- Plant K.o." Building 7, FI. 19 Rochester, NY 14650 Econalytic Systems, Inc. 2995 Wilderness Place Boulder, CO 80301 Economic Development Corp of Essex Cnty 443 Northfield Avenue West Orange, NJ 07052 Eli Lilly and Company P.O. Box 685 Lafayette, IN 47902 yvV 000007VT6 15 White Chemical Data System Mailing List Generators (continued) Ethyl Corporation Chemicals Division 451 Florida Blvd. Baton Rouge, LA 70801 Ethyl/Saytex 879 Main street Sayreville, NJ 08872 Exxon Chemical Company, U.S.A. P.O. Box 3272 Houston, TX 77001 FMC Corporation 2000 Market St Philadelphia, PA 19103 Fallek Chemical 2125 Central Ave. Fort Lee, NJ 07024 Fanwood Chemical, Inc. 219 Martine Avenue, P.O. BOX 159 Fanwood, NJ 07023 North Ferro Corporation 3000 Sheffield Ave Hammond, IN 46320 Ferro Corporation m Bedford Ch^q^cal Division' 7050 Krick Road Bedford, OH 44146 " Ferro Corporation Grant Chem. Division P.O. Box 263 Baton Rouge, LA 70821 Ferro Corporation l Erieview Plaza Cleveland,, OH 44114 Fine Pigments, Inc. 180 Blanchard St Newark, NJ 07105 vvv 000007477 16 \ y White Chemical Data System Mailing List Generators (continued} Fisher Scientific X Reagent Lane Fair Lawn, NJ Fisher Scientific 711 Forbes ave. Pittsburgh, PA 15219 Flexible Products Company P.O. Box 3190 1007 Industrial Drive Marietta, GA 30061 Fluid Energy Processing & Equipement P.0. Box A 153 Penn Ave Hatfield, PA 19440 Co. Freeman Industries, P.O. Box 415 914 Woodbine Tuckahoe, NY Inc, 1-2100 10707 Freeman Industries, Inc. 100 Marbledale Road Tuckahoe, NY 10701 Frey Industries, Inc. 29 Riverside Ave Newark, NJ 07104 GAF P.O. Box 700 _ Linden, NJ '*ttf7036 GAF 1361 Alps Road Wayne, NJ 07470 General Chemical Corporation P.O. BOX 360464 H Pittsburgh, PA 15251 General Chemical Corporation P.O. Drawer 2168 1627 Abutment Rd Dalton, GA 30722 17 White Chemical Data System Mailing List Generators (continued) General Chemical Corporation 90 E. Halsey Road P.O. Box 393 Parsippany, NJ 07054 General Felt Industries, President, CEO Park 80 Plz W Saddle Brook, NJ Inc. 07662 General Laboratory Supply Company 438 Pompton Road Wayne, NJ 07470 General Plastic & Chemical Corp. 848 Beacon Street Boston, MA 02216 General Plastic & Chemical Corp. 159 Boden Lane Natick, MA 01760 Givaudan Corporation 125 DElawana Ave Clifton, NJ 07014 Givaudan Corporation 100 Delawanna Ave. Clifton, NJ 07014 Glenery, Inc. P.O. Box 392 Kearny, NJ<T-*7to2 Great Lakes Chemical P.O. Box 92894 Chicago, IL 60675 Great Lakes Chemical Corporation P.O. Box 2220 Highway 52 NW West Lafayette, IN 47906 Greensboro Finishing P.O. BOX 21448 301 E. Meadowview Rd. Greensboro, NC 27420 yVV 000007479 18 ; White Chemical Data System Mailing List Generators (continued) Gulf oil Chemicals Company P.O. BOX 6200B Pittsburg, KS 66762 Gulf Oil Chemicals Company P.O. Box 509 Bayton, TX 77521 Hawkins Chemical, Inc. 3100 East Hennepin Ave Minneapolis, MN 55413 Helena Chemical P.O. Box 159 Shrewsbury, PA 17361 Helm U.S. Chemical 1110 Centennial Dr Piscataway, NJ 08854 Hexagon Enterprises, Inc. 60 Midvale Road Mountain Lakes, NJ 07046 Hexagon Enterprises, Inc. P.O. Box 18023 Newark, NJ 07191 High Point Chemical PO Box 2316 255 Beddington High Point, NC St 27261 Hoechst Celanese'T&emical Group, PO Box 8500-S-6430 Philadelphia, PA 19178 Inc. Hoechst Celanese Chemical Group, Inc. 1250 W. Mockingbird Lane Dallas, TX 75247 Hoffman - La Roche, Inc. 340 Kingland Street Nutley, NJ 07111 Hooker Chemical 345 Third Ave Niagara Falls, NY 14302 19 VVV 000007480 White Chemical Data System Mailing List Generators (continued) Hordo Chemical/ Inc. PO BOX 9931 BakersfieId, CA 93389 Hummel Croton, Inc. 10 Harmich Rd South Plainfield, NJ 07080 Humphrey Chemical Corporation PO Box 2 Edgevood Area Aberdeen Proving Gnd, MD 21010 Hunter Douglas, Inc. 601 Alter Street Broomfield, CO 80020 Huntsman Chemical Corp. President 60E South Temple Street, 2000 Salt Lake City, UT 84111 ICC Industries 720 Fifth Ave New York, NY 10019 ICD Group Inc. 600 Madison Ave., 17th FI. New York, NY 10022 ICI Americas, Inc. Concord Pike & Murphy Rd Wilmington, DE _19897 T* ICP Chemical Group, Inc. PO Box 156 Lido Beach, NY 11561 IFP Enterprises Inc. 680 Fifth Ave New York, NY 10019 Inmont 201 Armistice Rd Pawtucket, RI Inmont 125 Broad Street Clifton, NJ 07015 20 Vvv 00007*31 White Chemical Data System Mailing List Generators (continued) Index Chemical Company Jackson & Swanson Streets Philadelphia, PA 19148 Insulated Technologies Corporation PO Box 66 Darby, PA 19023 International Flavors & Fragrances 600 State Highway Hazlet, NJ 07730 International Flavors & Fragrances 521 W. 517th Street New York, NY 10019 J.A. Miller, Inc. 50 Chestnut Ridge Road Suite 117 Montvale, NJ 07645 J.F. Henry Chemical Co., Inc. P.O. Box 2050 Foot of Fenwick St Newark, NJ 07114 J.G. Eberlein & Co., Inc. 90 west street New York, NY 10006 J.T. Baker Chemical Co. 222 Red School Lane Phillipsburg, NJ 08865 Jame Fine Chemicals, Inc. 100 West Main Street P.O. Box 669 Bound Brook, NJ 08805 Jarchem Industries, Inc. 40 Balol Street Newark, NJ 07105 Jarchem Industries, Inc. 414 Wilson Ave. Newark, NJ 07105 John Boyle and Company Mr. John Boyle John Boyle Co. P.O. Drawer 791 Salisbury Road Statesville, NC 28677 * D_ *VV 000007482 White Chemical Data System Nailing List Generators (continued) Jonas Chemical Corporation 5 Beekman St New York, NY 10038 Jonas Chemical Corporation 16821 59th Street Brooklyn, NY 11204 Jones Chemicals, Inc. 100 Sunny Sol Blvd Caledonia, NY 14423 K & K Laboratories Division ICN Biomedicals, Inc. 121 Express Street Plainview, NY 11803 Kalama Chemical Inc. 1110 Bank of California Center Seattle, WA 98164 Kelco Division Merck & Co. Inc. 20 Wacker Drive Chicago, IL 60606 Kelco Division 8355 Aero Drive San Diego, CA 92123 Kenrich Petrochemicals, Inc. 140 East 22nd Street P.0. Box 3-^-r* " Bayonne, NJ 07002 Key Polymer Corporation Jacobs Way Lawrence Industrial Lawrence, MA 01842 Park King's Laboratory, Route 1 P.O. Drawer Blythewood, Inc. 120 SC 29016 Kowa American Corp. Importers and Exporters 1140 Avenu of americas New York, NY 10036 vvv 00000740, 22 White Chemical Data System Mailing List Generators (continued) Kramer Chemicals, Inc. p.o. Box 1299 Allwood Station Clifton, NJ 07012 Kramer Chemicals, Inc. 935 Allwood Road Clifton, NJ 07012 Kramer Chemicals, Inc. 206 Clifton Blvd. Clifton, NJ 07012 L. J. & M. LaPlace LeHart's Lane Elmwood Park, NJ 07407 Lake Chemical Co. LA-C0 Industies, Inc. 270 N. Washtenaw Chicago, IL 60612 Lidochem, Inc. 20 Village Court Havlet, NJ 07730 Lonza Inc. 22-10 Route 208 Fairlawn, NJ 07410 Ludlow Industrial Park 60 Washington Street Conshohocker, -PA 194 28 T* Lydall, Inc. Manning Division PO Box 328 Troy, NY 12181 - M & T Chemicals, Inc. Woodbridge Road & Randolph Ave. P.O. Box 1104 Rahway, NJ 07065 M. Michel and Company, Inc. 90 Broad Street New York, NY 10004 VVV 000007484 23 White Chemical Data System Mailing List Generators (continued) Maag Agrochemicals Inc. P.O. Box 6430 Vero Beach, FL 32961 Malden Mills 46 Stafford Street Lawrence, MA 01841 Mallinkrodt, Inc. P.O. Box 5349 St. Louis, MO 63147 Mallinkrodt, Inc. President 675 McDonnel Blvd. St. Louis, MO 63134 Marubeni American Corp. President-CEO 200 Park Avenue New York, NY 10166 Matheson Gas Products, Inc. P.O. Box 23029 Newark, NJ 07189 Maybrook, Inc. P.O. BOX 68 Lawrence, MA 01842 Maypro Industries, Inc. 550 Mararoneck-Ave. Harrison, Ti? 10528 McGean-Rohco, Inc. 2910 Harvard Ave P.O. Box 09087 Cleveland, OH 44109 McGean-Rohco, Inc. 1252 Terminal Tower Cleveland, OH 44113 McGean- ohco, Inc. 3 Public Square oom 1250 Cleveland, OH 44113 24 vvv 000007405 white chemical Data System Mailing List Generators (continued) Melamine Chemicals, Inc. River Road P.O. Box 748 Donaldsonville, LA 70346 Mellen Chemicals, Inc. 211 Randolph Ave Aven-sl, NJ 07001 Merck & Co., Inc. 126 E. Lincoln Ave. Rahway, NJ 07065 Merck & Co., Inc. P.O. Box 2000 Rahway, NJ 07065 Mitsubishi International Corp. 520 Madison Ave New York, NY 10022 Mitsubishi International Corp. 875 Supreme Drive Bensenville, IL 60106 Mitsui & Co. (U.S.A.), Inc. 200 Park Avenue New York, NY 10166 Mobay Corporation Mobay Road Pittsburgh, PA 15205 ,' Mobil Chemical Co.' Chemical Products Division P.O. Box 26683 Richmond, VA 23261 Mobil Chemical Co. 150 E. 42nd Street New York, NY 10017 Monsanto Company 800 N. Lindbergh Blvd. St. Louis, MO 63167 Monson Chemicals Inc. 154 Pioneer Drive Leominster, MA 01453 vvv 000007486 25 White Chemical Data System Mailing List Generators (continued) Morre-Tec Industries Inc. 500 Westfield Ave Elizabeth, NJ 07208 Morton- Thiokol P.O. BOX 2184 1116 Tanner Rd Taylors,' SC 29687 Morton- Thiokol 110 N. Wack Drive Chicago, IL 60606 Morton- Thiokol P.O. Box 368 Greenville, SC 29602 Myrton & Noel Assoc., Inc. 1440 Boynton Avenue Westfield, nj 07090 NIPA Labs 3411 Siverside road 104 Hagley Building Wilmington, DE 19810 NL Chemicals/NL Industries, Inc. PO Box 700 Hightstown, NJ 08520 Nagase American Corporation 500 Fifth Ave. New York, * IDllO Nalco Chemical One Nalco Center Naperville, IL 60566 Natico, Inc. 6700 South Leclaire Ave. Chicago, IL 60638 National Caselie of N.J. PO Box 226 Riverton, NJ 08077 National starch and Chemical Corporation PO Box 100141 Atlanta, GA 30384 VVV 000007487 26 White Chemical Data System Mailing List Generators (continued) -National Starch and Chemical Corporation 10 Finderne Avenue Bridgewater, NJ 08807 Noodex Inc. Turner Place Piscataway, NJ 08854 Novick Chemical, Inc. 35 Walnut Avenue Clark, NJ 07066 Nyacol Products Inc. Megunco Hoad PO Box 349 Ashland, MA 01721 Orbis Products Corporation 140 Route 10 East Hanover, NJ 07936 Orbis Products Corporation 55 Virginia Street Newark, NJ 07116 PAN Chemical Corporation l Washington Ave Hawthorne, NJ 07507 PMC corp Industrial Avenue Ford, NJ PPG Industries PO Box 1000 Columbia Southern Lake Charles, LA Rd 70602 PPG Industries 1 PPG Place Pittsburgh, PA 15271 Park Trading Co. PO Box 9521 Providence, RI 02940 Park Trading Co. 976 Park Avenue Cranston, RI VVV 000007488 27 White Chemical Data System Nailing List Generators (continued) Pennwalt Corporation Lucidol Division 1740 Military Road Buffalo, NY 14240 Phillip Hunt Chemical 1 Wellington Rd Lincoln, RI 02865 Pittman Moore PO Box 207 Terre Haute, IN 47808 Poly Extrusions 4325 Murray Street Halton City, TX 76117 Pratsil Inc. P.O. Box 859 Bound Brook, NJ 08805 Pressure Chemical 3419 Mailman Street Pittsburgh, PA 15201 Preston Trucking Co., Inc. 151 Easton Blvd Preston, MD 21655 Proctor & Gamble Co. B Building 11520 Reed Hartman Hwy Cincinnati^oH 45241 Proctor & Gamble Co. 1 Proctor & Gamble Plaza Cincinnati, OH 45202 Proctor & Gamble Co. Industrial Chem. Division P.O. Box 599 Cincinnati, OH 45201 Quantum Lab Supply Inc. 6351-H Yarrow Drive Carlsbad, CA 92008 Quick Chemical Inc. 200 Winston Drive Cliffside Park, NJ 07010 yyV 000007^8 28 White Chemical Data system Mailing List Generators (continued) . R.T. Vanderbilt Company, Inc. 30 Winfield St Norwalk, CT 06855 Rambach Chemical Co. Inc. P0 Box 5187 Newark, NJ 07105 Reigel Textile Corp. 1150 Hammond Drive Suite A-1200 Atlanta, GA 30328 Reigel Textile Corp. P.0. Box 329 Ware Shoals, SC 29692 Reilly Industries President 151 North Delaware Street Indianapolis, IN 46204 1510 Reliance Chemical Products 64 Avenue A PO Box 336 Bayonne, NJ 07002 Company Rhone Poulenc, Inc. Black Horse Lane P.0. Box 125 Monmouth Junction, NJ 08852 Rhone-Poulenc Ag ~* P.O. Box 12'614 (Rm 2127) Res. Triangle Park, NC 27709 Rhone-Poulenc Basic Chemical Co. Dir. of Environmental Services One (1) Corporate Drive Shelton, CT 06484 Robecco Chemicals, Inc. P.O. Berth 80 Elizabeth Pier, NJ 07207 Robert I. Webber Company, Inc. 26 Sixth St Stamford, CT 06905 29 VVV 000007490 White Chemical Data System Mailing List Generators (continued) Roche Products Inc. PO Box 452 Manati, PR 00701 Rockland Industries 1601 Edison Highway P.O. Box 17293 Baltimore, MD 21213 Rohm and Haas Company Independence Mall West Philadelphia, PA 19105 Russell-Stanley East, Inc. River Road & State Street Camden, NJ 08105 Russell-Stanley East, Inc. Russell Stanley Corp. Conbery Blvd. P.O. BOX 458 Woodbridge, NJ 07095 SRS Inc. 1200 Sylvan St Linden, NJ 07036 Sargent-Welch Scientific Co. 35 Stern Ave Springfield, NJ 07081 Sargent-Welch Scientific Co. 7300 N. Linder^Ave. P.O. Box 1026 Skokie, IL 60077 Saytech Inc. 879 Main St Sayreville, NJ 08872 Saytech Inc. P.O. Box 171760 Newark, NJ 07194 Schaefer Salt & Chemical P.O. Box 236 Elizabeth, NJ 07207 30 000007491 VVV White Chemical Data System Mailing List Generators (continued) Schering Plough President One Giralda Farms Madison, NJ 07940 Seidler Chemical & Supply Co. 27 Haynes Avenue Newark, NJ 07114 Signo Trading International, Ltd. 208 S. 14th Avenue Mt. Vernon, NY 10550 Signo Trading International, Ltd. 208 S. 14th Avenue Mt. Vernon, NY 10550 Solem Industries 5824D Peachtree Corners East Norcross, GA 30092 Solem Industries 4940 Peachtree Industrial Blvd. Norcross, GA 30071 Spectrum Chemical Mfg. Corp. Vice President 14422 S. San Pedro Street Gardena, CA 90248 Spray Drying Service, Inc. 501 North Avenue Garwood, N^TTQ1K)27 Squibb Manufacturing P.O. Box 609 Humacao, PR 00661 Stauffer Chemical Co. 1200 south 47th St Richmond, VA 94804 Stockton Sales, Inc. 44 Ryders Lane P.O. Box 983 East Brunswick, NJ 08816 Suburban Chemical Co. 59 Lee Avenue P.O. Box 8690 Haledon, NJ 07538 000007492 vv 31 White Chemical Data System Mailing List Generators (continued) T.E. Nesby Inc. Biotics & Biologicals 2227 No. Pleasant Fresno, CA 93711 T.E. Plastic Parkersburg Center 5th Ave. & Avery Street Parkersburg, WV 25102 TCI 150 Meadowland Parkway P.O. Box 2458 Secaucus, NJ 07096 Tanner Chemical PO BOX 1967 Greenville, SC 29609 Tennessee Eastman Company P.O. Box 511 Bldg. 75 Kingsport, TN 37662 Textile Chemical Company Pottsville Pike & Huller Lande Reading, PA 19605 Thomas Scientific 99 High Hill Road at 1-295 Box 99 Swedesboro, NJ_ 08085 Troy Chemical Corporation 1 Avenue L Newark, NJ 17105 Tunnel Barrel & Drum Co., Inc. 85 Triangle Blvd Carlstadt, NJ 07072 Turnbull Corporation 400 Valentine St Hackettstown, NJ 07840 Twin Lake Chemical Inc. 520 Mill St PO BOX 411 Lockport, NY 14094 vvv 000007493 32 White Chemical Data System Mailing List Generators (continued) . U.S. Industrial chemicals Co. P.O. Box 98752 Chicago, IL 60693 Union Carbide Electronics Division 8888 Balboa Avenue San Diego, CA 92123 Union Carbide Headquarters 390 Ridgebury Road Danbury, CT 06817 Union Carbide 514 University Plaza Hackensack, NJ 07601 Union Carbide Chemicals & Plastics Co. Old Ridgebury Road Danbury, CT 06817 Union Carbide Chemicals & Plastics Co. 1 University Plaza Hackensack, NJ 07601 Uniroyal Chemical Corporation World Headquarters Middlebury, CT 06749 Uniroyal Chemical Corporation Research Laboratories 120 Huron j^yeet Guelph, OT ' ^~ Unitas Corporation 152 Madison Avenue New York, NY 10016 United Jersey Bank/Commercial Vice President 15 Exchange Place Jersey City, NJ 07302 Trust Valchem Chemical Division 1407 Broadway New York, NY 10018 33 000007494 VVV White Chemical Data System Mailing List Generators (continued) Van Waters & Rogers, Inc. 160 Essex Ave East Avenel, NJ 07001 Vanchlor Co. Inc. N Transit Rd Lockport, NY 14094 Veckridge Chemical Co. 60-70 Central Avenue Kearny, NJ 07032 Vista Chemical company 9794918-00 *-----* PO Box 75422 Charlotte, NC 75422 Walsh Chemical 207 Telegraph Drive Gastoniz, NC 28052 Walsh Co. President c/o John J. McClure Agency 1700 Race Street Philadelphia, PA 19103 West Agro-Chemical, Inc. PO Box 1386 Shawnee Mission, KS 66222 West Design Chemical Inc. 4350 Johns4^Dir Suite 280 Fairway, KS 66205 White Cross Laboratories Inc. PO Box 1075 Rye, NY 10580 Witco Chemical Co 6200 W. 51st St Chicago, IL 60638 VW 000007495 Cy \\ a eta iVfl A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION II JACOB K. JAVITS FEDERAL BULBING NEW YORK, NEW YORK 10270 July 12, 1991 CERTIFIED-. MAIL RETURN RECEIPT REQUESTED President vista Chemical Company 9794918-00 P.O. BOX 75422 Charlotte, NC 75422 Re: Request for Information Pursuant to 42 U.S.C. $9601 et sea, and 42 U.S.C. $6901 fit sea.. White Chemical Corporation Site, Newark, New Jersey. Dear Sir/Madam: The U.S. Environmental Protection Agency (EPA) Is charged with responding to the release and/or threatened release of hazardous substances, pollutants and contaminants into the environment and with enforcement responsibilities under the Comprehensive Envi ronmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C. $9601 e sea and the Resource Conservation and Recovery Act (RCRA), 42 U.S.C. $6901 seq. EPA has documented the release and/or threatened release of hazardous substances into the environment at the White Chemical Corporation Site, (the Site). Pursuant to Section 104 of CERCLA, 42 U.S.C. $9604, and Section 3007 of RCRA, 42 U.S.C. $6927, EPA may request certain informatioi^grom parties who handle or have handled hazardous substances and hazardous waste, as those terms are defined at Section 101(14) of CERCLA, 42 U.S.C. $9601(14), and Section 1004 of RCRA, 42 U.S.C. $6903, respectively. Section 104(e) of CERCLA, 42 U.S.C. $9604(b), enables EPA to request relevant information or documents relating to the nature and quantity of materials which have been or are generated, treated, stored, or disposed of at a facility or transported to a facility. Pursuant to these statutory provisions, EPA hereby requires that your company answer questions posed in the attached "Request for Information" letter. If your company has an EPA Identification Number, kindly state it in your response. PRINTE0 ON RECYCLED PAPER Your company's response to the "Request for Information" should be postmarked or received by EPA within twenty-one (21) calendar days of your receipt of this letter. The company's response should be mailed to: U.S. Ms. SiIvina Fonseca Mew Jersey Superfund Branch - I Environmental Protection Agency, Region II 26 Federal Plaza, Room 711 New York, New York 10278 with a copy to Bruce Aber, Esq., office of Regional Counsel, Room 309 at the same address. Your company's failure to respond to the "Request for Information" within the time specified above may subject it to an enforcement action under Section 104(e)(5) of CERCLA, 42 U.S.C. 99604(e)(5), and/or section 3008 of RCRA, 42 U.S.C. -56928. An enforcement action may include the assessment of penalties of up to $25,000 for each day of continued noncompliance. The notarized signature of an officer or other responsible official of the company must appear on the enclosed "Certification of Answers to Request for Information", which should be attached to tne response to this "Request for Information". Be advised your company is under a continuing obligation to supplement its response if information not known or not available to the company as of the date of submission of its response should later become known or available. If at any time in the future the company obtains or becomes aware of additional information and/or finds that any portion of the submitted information is false, misleading or misrepresents the truth, the company must promptly notify EPA. If any part of the company's response is found to be untrue, the signatory and the company may subject to criminal prosecution. If desired, the company may assert a business confidentiality claim covering all or part of the information requested by this letter. The claim must be supp$?ted by each of the four factors specified in Section 104(e)(7)(E) of CERCLA, 42 U.S.C. 59604(e)(7)(E), and must be asserted at the time of submission, by placing on (or attaching to) the information a cover sheet, stamped or typed legend, or other suitable form of notice employing language such as "trade secret", or "proprietary", Nor "company confidential". Information covered by such a claim will be disclosed by EPA only to the extent and by means of procedures set forth in Title 40 C.F.R. Subpart B. If no such claim accompanies the information when it is received by EPA, it may be made available to the public by EPA without further notice to the company. vvv ooooo-r^7 If you have any questions concerning this "Request for Information", please contact Silvina Fonseca, of my staff, at (212) 264-7604 or Bruce Aber, Assistant Regional Counsel, at (212) 264-5547. Please note that all communications from an attorney must be directed to Bruce Aber. Your cooperation is appreciated. Sincerely yours. Kathl* Director Emergency and Remedial Response Division Enclosures VVV 000007476 IMflTRPCTXOKB FOR RESPONDING TO REQUEST FOR IffiTORMATIOM I. A complete separate response must be made to each Individual question in this "Request for Information". 2 Precede each answer with the number of the question to which it is addressed. 3. In preparing your response to each question, consult with all current and former employees and agents of the company who may be familiar with the matter to which the question pertains. 4. Interpret "and" as well as "or" to include within the scope of the question as much information as possible. Xf two interpretations of a question are possible, use the one that provides more information. 5. If you are unable to give a detailed and complete answer or to provide any of the information or documents requested, indicate the reasons for your inability to do so. 6. if you have reason to believe that there is an individual who may be able to provide more detail or documentation in dispense to any question, state that person's name, last Known address and phone number, and the reasons for your belief. 7. For each document produced in response to this "Request for Information", indicate on the document, or in some other reasonable manner, the number of the question to which it applies. 8. If anything is deleted from a document produced in response to this "Request for Information", state the reason for, and the subject matter of, the deletion. 9. If you are unable to provide a copy of any document, identify the document by describing^the nature of the document (e.g., letter, file memorandum. jjivolce. inventory form, billing record, hazardous waste manifest, etc.) and provide an explanation as to why a copy of the document cannot be produced. Describe the relevant information therein. Identify by name and job title the person who prepared the document. If the document is not readily available, state where it is stored, maintained, or why it is otherwise unavailable. 10. Whenever in this "Request for Information" there is a request to identify a person or an entity other than a person, state the person or entity's full name, last known employment, present or last known home address, and telephone number. II. As used herein, the term "release" and "person" shall have the meaning set forth in Section 101(22), and (21) of CERCLA, 42 U.S.C. $9601(14), and (21), respectively. VVV 000007499 12. As used herein, the terns "disposal" and "storage" shall have the meanings set forth in Sections 1004(3) and (33) of rcra, 42 U.S.C. $6903(3) and (33), respectively. 13. As used herein, the tern "industrial waste" shall nean any solid, liquid, gas, or sludge or any mixtures thereof which possess any of the following characteristics: a. it contains one or more "hazardous substances" (at any concentration) as defined in 42 U.S.C. S9601(14); b. it is a "hazardous waste" as defined in RCFA 42 U.S.C. 56903(5); c. it has a pH less than 2.0 or greater than 12.5; d. it reacts violently when nixed with water; e. it generates toxic gases when mixed with water; f. it easily ignites or explodes; g* it is an industrial intermediate waste product; h. it is an industrial treatment plant sludge or supernatant; i. it is an industrial byproduct having some market value; j. it is coolant water or blowdown waste from a coolant system; k. it is a spent product which could be reused after rehabilitation; 1. it is any material which you have reason to believe would be toxic if either ingested, inhaled or placed in contact with your skin; or n. it is used product, primarily derived from petroleum (e.g., fuel oils, motor oils, gear oils, cutting oils, transmission fluids, hydraulic fluids, and dielectric fluids). 14. As used herein, the term "raw material" or "product" means hazardous substance for a productive use. As used herein, the terms "drum" or "container" include, but are not limited to, drums, vats, pails, carboys, boxes, tanks, tank trucks, kettles, barrels, cans^ bulk solids; bottles and cylinders. 'T"* 16. As used herein, the term "you", "your", "company", "entity" and similar terms shall mean any person as defined in Section 101(21) of CERCLA ("Person"), and shall include all past and present facilities and employees of your corporation, its subsidiaries, parent company, divisions, affiliates, and branches of the corporation, unless its meaning is otherwise explicitly redefined in any specific question. 17. As used herein, the term "White Chemical corporation" or the "Site" shall refer to a parcel of property identified as Block 3782, Lot 109 on the tax map of Essex County, located at or about 660 Frelinghuysen Avenue, Newark, New Jersey. VVV 000007500 1C. In answering these questions, every source of information to vhich you have access should be consulted, regardless of whether the source is in your immediate possession or control. All documents or other information, including records of all types of manufacturing, treatment, transportation or disposal operations, possession or in the possession of the company should be consulted. If you do not have access to certain information and/or documents, state the nature of this information and/or *?~vaient(s), and indicate in whose possession they can be found. 19. For each of the following questions, send copies of all documents that relate to the question. VVV 000007501 REQUEST FOR INFORMATION a. State the legal name of the entity ("Entity") responding to this "Request for Information," as that term is defined in instruction number 16. b. If you are a commercial entity; 1) Identify by name, address, nature of business operation, dates of operation, the Entity including, but not limited to parent, subsidiary, affiliate, division or any business unit which is now, or was during the period 1982 through September 1990, related to your Entity, which generated, transported, disposed of, supplied and/or sold any industrial waste, as that term is defined in instruction number 13, raw material or product, as those terms are defined in instruction 14, during the period 1982 through September 1990* If any entity identified above did business under more than one name, each name should be stated with the response to this question. 2) Identify the state of incorporation and the agents for sezvice of process in the state of incorporation for every entity identified above. 3) State the name(s) and address(es) of all past and present officers of your Entity and related entities and the individual(s) responsible for environmental programs and compliance in the entities identified above, for the period 1982 to September 1990. c. If you are a Person, other than a commercial entity, state all the locations, with addresses, from which you or your agents generatedtransported, disposed of, supplied to, and/or dQTfe any industrial waste materials raw materials, or product during the period 1982 to September 1990. Respond to the following question by checking the YES or NO Column as applicable to the White Chemical Corporation Site. During the period 1982 through September 1990, has the Entity or any related entity generated, arranged for the generation of, transported, or arranged for the transportation of, sold, arranged for the selling of, and/or supplied: 00001502 vMV 0 iS a. commercial refuse* b. Industrial waste c. Petroleum or petroleum products d. Raw material/Product e. Finished chemicals f. Chemical waste of any type g. Hazardous waste of any type h. Hazardous waste containers (e.g., drums) i. Pesticides j. Construction and demolition waste v, Industrial sludge l. Chemical solvents m. "CERCLA WASTE MATERIAL"; i.e., any solid, liquid, or sludge, or any mixtures thereof which possess anv of -the characteristics defined in #14 of the Instructions HQ Commercial refuse includes any waste material that was generated at and/or transported from a business which was not involved in manufacturing operations. 0Oo 750j 3. For each item marked YES state the nature of thu operations and processes which were conducted at each Entity or by any Person generating, transporting and/or selling any industrial waste, listed in response to question l above, for each year from 1982 to September 1990. 4. If you answered YES to any item in question 2 above: a. Identify by name, composition, quantity, and source of origin, each substance identified in question /2, which was generated, transported to, disposed of, sold and/or supplied to, or which you have reason to believe was generated, transported to, disposed of, sold, and/or supplied to the White Chemical Corporation, Newark, New Jersey. For each material, identify the entity which generated, transported, disposed of, sold and/or supplied such material. b. If your Entity or any related entity generated material identified in question #4(a), identify by name, address, specific dates of service and total billings for each year of service, the haulers that transported, or may have transported, the aforesaid material to the White Chemical Corporation during the period of 1982 through September 1990. c. Identify by name, composition, and source of origin, each material transported to, or which you have reason to believe was transported to the White Chemical Corporation. For each, state whether your Entity, or any related entity transported such material. d. If your Entity or any related entity transported the material identified in question #4(a), state the total quantity of material transported and . identify by name, address, specific dates of service and total billings for each year of service, the generators of. the material you transported, or may hfiftl transported to White Chemical Corporation during the period 1982 through the present. For quantity totals for liquids, the answer should be in terms of volume, for solid material, in terms of weight. e. Explain how the material was containerized for handling and transporting (e.g., drums, bulk solids, tank trucks, bulk liquids (uncontainerized), etc.). f. Please state whether your Company purchased from White Chemical Corporation any product which was manufactured from any of the materials you identified in 2 above? 000001** Does your Company have any past or present "toll processing** or "toll manufacturing**, conversion arrangements, third party contracts, consignments, or other arrangement vith White Chemical Corporation, Newark, New Jersey, D & O Chemicals, Inc., Englewood, New Jersey, or Hexagon Enterprises, Inc., Mountain Lakes, New Jersey? If so, identify the purpose or nature of each arrangement. Also describe how each arrangement provided for the generation, transportation, storage, or disposal of any of the material identified in question /4 above, and provide documentation. Has your Company ever had an ownership interest in any items affirmatively identified in question #2 above, while they were being stored at the Site during the years 1982-1990 which has not been fully described pursuant to question 5 above. If so, describe the nature of your ownership interest, your company's arrangements vith White Chemical, and how each arrangement provided for the generation, transportation, storage, or disposal of the materials and provide documentation. If you answered YES to any item in question 2 above, please answer the following: a. For each entity, listed in response to question 1 above, state whether there was any treatment system, the type of system, the years in operation, the volume and nature of the material treated and the volume and chemical constituents of the sludge, waste water and other by-products produced on an annual basis for the years 1982 through September 1990. b. What amount and percentage of the total waste listed in response to this question was transported and/or sold to the White Chemical Corporation each year during the period 1982 through September 1990? _ T* c. Were analyses performed on the sludge, waste waters and/or other by-products? If so, state the results* If you answered YES to question 4, 5, or 7 above, identify by name, job title and description, address, and year(s) of service, all individuals having knowledge of the generation, treatment, storage, transportation, disposal and marketing of waste material by any Person listed above for the period 1982 through September 1990. Has your Company ever had any authority to participate in or influence White Chemical Corporation's management, waste disposal or financial operations? If so, describe any such authority and supply all documents which relate to such authority. vvv 000007505 Has your Company ever actually participated in or influenced White Chemical Corporation's management, waste disposal, or financial operations? if so describe any such participation and supply all relevant documents. Include, but do not limit your response to, all instances where the Company specified to White Chemical Corporation the process to be used in White Chemical Corporation's production of a finished product. Has your Company ever performed or contracted to have performed any site inspections or investigations of the White Chemical Corporation Site or any aspect of White Chemical Corporation's operations? If so, a. list the dates of the inspection(s), b. describe the purposes for and results of the inspection(s), c. supply copies of any documents which contain results or analyses of the inspection(s), and d. state the names of any officers, employees, contractors, consulting companies, or other persons who assisted in performing the inspection(s). VVV 00000750t CERTIFICATION OF ANSWERS TO REQUEST FOR INFORMATION State of . County of I certify under penalty of lav that I have personally examined and am familiar with the information submitted in this document (response to EPA Request for Information) and all documents .-emitted herewith, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete, and that all documents submitted herewith are complete and authentic unless otherwise indicated. I am Aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. I am also aware that the Corporation is under a continuing obligation to supplement its response to EPA's Request for Information if any additional information relevant to the matters ...Pressed in EPA's Request for Information or the Corporation's response thereto should become known or available to the wwxporacion. NAME (print or type) TITLE (print or type) SIGNATURE r** Sworn to before me this day of , 19_ Notary Public vVV 000007507 TO: Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 7, 1991 NEARLY ANNUAL SAFETY DIRECTORS MEETING VISTA As planned, the meeting will be held on Tuesday, September 10, in Houston, It will be a one-day meeting. The primary focus of the meeting will be on the Safety and Health Audit Program. We will be doing training on how to use the audit system. Below are the preliminary agenda items. Please contact me with other thoughts on the agenda content. 1. Health and Safety Audit Program: content, administration, and how to use training. 2. Process Safety Update: Eric Meyer will give a status report on Vista's efforts. 3. Responsible Care Update and Issues. 4. Regulatory and Health Hazard Updates. A more detailed agenda will be sent prior to the meeting. Once again, please provide me with your comments and thoughts on additional agenda items. T. G. Grumbles dlj Distribution: SAFETY DIRECTORS T* ^ .. Bruce Trego-Aber, Brent White-Bait, George Williams-Blane, Matt Tonkovich-Hmd, K. L. Fogg-LCCP, R. V. Gantz-LCLAB, Mike LunsfordLCVCM, Mark Markerson-Okc , Greg Lipps - Premiere, R. B. Martin-Austin, J. R. Drumwright, J. G. Farrier cc: PLANT MANAGERS R. W. Seymour-Aber, L, R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCIAB, P. Carrico-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin R. D. Gamblin, T. H. Huffman, A. Clark, E. Meyer tfVV 000007508 TO: R. D. Gamblin Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles August 9, 1991 CIIT PARTICIPATION AND COSTS I've attached a memo from 1988 regarding CUT membership. The dues structure is essentially the same except that a discount factor of approximately 0.80 is now applied to dues. This is a result of increasing membership. The membership list has increased from 32 companies in 1988 to 50 today. A current membership list is attached. I believe our dues would be in the range of 100,000 to 110,000 for the first year. The remainder of the information in the 1988 memo is current. T. G. Grumbles dlj 000007509