Mr. Ferrante managed the preparation of the following reports for this site. A RIR/RAWP to address soil and ground water was developed and submitted to the USEPA and NJDEP for comment on January 13, 2006. USEPA commented on the RIR/RAWP in a letter dated March 14, 2006. It was determined that soils containing 50 mg/kg or more total PCBs were regulated for disposal and that based on the change in proposed land use to include residential development, Victory Center was to comply with the requirements of TSCA under 40 CFR 761.61(a), self-implementing on-site cleanup and disposal of PCB remediation waste; or the requirements of 40 CFR 761.61 (c), for a risk-based disposal approval.

The area included in this RAWP Addendum includes the North Yard of the IGI site located south of Patterson Street and between Grant and Sheridan Streets. The area north of Patterson Street is being addressed separately. The current property owner and party to complete the proposed remedial action is Victory Center LLC, 26 Chapin Road, Unit 1112, PO Box 720, Pine Brook, NJ 07058. Current redevelopment plans include developing the northern third of the North Yard on the south side of Patterson Street into residential lots for townhome construction, with the southern two thirds facing Riverview Drive proposed to be developed into a single commercial lot. For the commercial and low occupancy areas of the site, engineering and institutional controls was proposed. In areas where residential development is proposed, will be remediated to the NJDEP residential direct contact soil cleanup criteria and a No Further Action (NFA) Letter and Covenant Not to Sue for those residential areas, will be applied for.

The change in redevelopment plans requires consideration of the applicable cleanup levels and site-specific factors by USEPA and NJDEP in determining what cleanup levels are appropriate for what areas of the site under their authority to implement TSCA and ISRA, respectively. In areas where residential development is proposed, we intend to remediate to the NJDEP residential direct contact soil cleanup criteria and will apply for a NFA-A Letter, as detailed below.

Soils at or below 0.49 mg/kg PCBs in any area shall be left on-site and not require further remedial action, engineering or institutional controls. Cleanup to 0.49 mg/kg is proposed in the residential development areas so that no engineering or institutional controls will be required. Soils with PCB concentrations between 0.49 and 10 mg/kg in other than residential redevelopment areas shall be left in place or moved to commercial use or low occupancy areas with engineering and institutional controls meeting the requirements of 40 CFR 761.61(a)7 and 761.61(a)8. Soils with PCB concentrations between 10 and 100 mg/kg will either be disposed of on-site in low occupancy areas (e.g., under parking lots) with appropriate engineering and institutional controls, or shipped for off-site disposal, depending on volume and feasibility of managing the soils on-site. The low occupancy cleanup level is proposed only for those portions of the site to be redeveloped as parking or other paved areas, as they meet TSCA low occupancy criteria. Remediation will include capping and deed restrictions as required. Soils with greater than 100 mg/kg PCBs will be shipped off-site for disposal in a properly permitted facility. Any engineering and institutional controls will be completed in accordance with TSCA regulations and incorporated in the redevelopment design for the entire project. Approximately 1000 cubic yards (40’ by 40’ by 16’ deep) of soil will be excavated and stockpiled on the site, pending additional investigation into the extent of LNAPL in soils, as described in Section 2.2 below. The excavation will be temporarily secured pending the final RAWP approval. LNAPL fluids found in the vicinity of MW-2 will be addressed concurrently with the LNAPL in the vicinity of the VER system.

Monitoring wells in the area of the VER system will be sampled for the presence of free-phase product. If product is detected, the time period allowed for product removal and the limits of excavation may need to be extended. Note that the VER system will be dismantled and several monitoring wells abandoned prior to the excavation and product removal. The VER electrical supply, piping, the remediation unit and associated equipment will be dismantled, decontaminated and handled as necessary. Residual product in the system will also be characterized and disposed of at a licensed facility. Product will be collected and removed from the excavation.