I respectfully request that the United States Environmental Protection Agency (USEPA) requires Pfizer to permanently remediate the 80-year old leaking toxic dump, the American Cyanamid Superfund Site in Bridgewater, NJ. Please include my comments as part of the official public record. In order to protect human health and the environment, USEPA must require Pfizer to remediate the site using a...
I respectfully request that the United States Environmental Protection Agency (USEPA) requires Pfizer to permanently remediate the 80-year old leaking toxic dump, the American Cyanamid Superfund Site in Bridgewater, NJ. Please include my comments as part of the official public record. In order to protect human health and the environment, USEPA must require Pfizer to remediate the site using a modified version of “Alternative 7,” and not “Alternative 4A,” as described in their 2012 Proposed Plan. Alternative 4A is one of the least costly for alternatives for Pfizer, and is only a quarter of the cost of a comprehensive cleanup. USEPA needs to go back and reevaluate their options and present the public with a more comprehensive plan that is protective of both human health and the environment.
The selected remedy, Alternative 4A, will not be protective of human health and the environment for the following reasons: Filling in a floodplain and capping the site is NOT a full remediation. Pfizer claims there will be no net filling. That is not true as the entire area, not just the fenced site, is in the floodplain. Also, the effect on solidifying parts of the site and capping a floodplain this large is not a permanent long-term solution - it's an engineering control. All caps fail, it’s just a matter of time.
I am also highly concerned that Alternative 4A will drastically expand serious toxic flooding for thousands of neighboring families that are already plagued by heavy flood waters. The Proposed Plan Alternative 4A proposes to cover the contamination with a combination of soil and engineering caps, which will take 10 years to implement. For the larger portions of the site, Pfizer proposes to raise the gradient two feet. As you are aware, this site lies in the floodplain and, as the most recent flood of Hurricane Irene shows, the American Cyanamid Site can hold about 300,000,000 gallons of water. Placing two feet of fill on the site will reduce its flood storage capacity and could exacerbate the regional flood issue in the area. The USEPA claims that this cap will be built to withstand a 500-year flood. This area floods regularly just with normal amounts of rain, and a cap would fail way before a 500-year flood occurs.
In addition, filling of a flood zone is subject to both New Jersey and Federal regulations. These regulations specify that there can be no net filling of the wetlands or a flood zone, which means you cannot fill one area of the site without removing fill from some other location so the status quo doesn’t change. The Proposed Plan is completely silent of the impacts of filling, and this most critical aspect of the American Cyanamid site MUST be clearly presented. The implemented plan must assure it will not exacerbate flooding in the lower Raritan River. The U.S. Army Corps of Engineers is actively working on flood control projects in the Raritan River Watershed to help alleviate flooding in Manville, Bound Brook, Bridgewater and all surrounding towns. The American Cyanamid site is a natural fit for a regional flood control project and can be an environmental benefit for the region if the proper remedy is selected.
CRISIS - an ineffectual “advocacy group” responsible for dissemination of information and cleanup options on the site - spent over $235,000 of federal taxpayer money to have a technical advisor review documents and evaluate cleanup options. With all this taxpayer money down the drain, the question that has to be raised is why CRISIS and their technical advisors cannot come up with an actual permanent cleanup solution?
The Proposed Plan outlines more applicable cleanup alternatives than Alternative 4A suggests, including low temperature desorption (Alternative 7). This method was successfully used at the Cornell-Dubilier Superfund Site in South Plainfield, NJ to remediate soils with high levels of PCBs and heavy metals without disturbing the surrounding community. In addition, USEPA and Pfizer can make use of an active rail line that runs through the site to properly dispose of this material. The cost estimates for the alternatives seem very high and there must be a detailed analysis for the cost of a low temperature thermal desorption unit.
USEPA must look at low temperature thermal desorption in combination with other techniques, such as off-site disposal at their existing RCRA facility across the street, and other innovative technologies, such as bio remediation with specialized microorganisms. These contaminants lend themselves to thermal destruction offsite. The USEPA must choose the most protective remedy now and implement it in an acceptable time frame. Capping a site should not take 10 years to complete, which means the time frames for other alternatives are probably exaggerated as well.
Why did USEPA allow the responsible party to stop the cleanup midstream after the record of decision was signed, and then let the site languish for another eight years? This current plan for capping a toxic waste floodplain is unacceptable and threatens the Raritan River Estuary and the millions of New Jersey residents who live near or downstream from the site. USEPA has mishandled this site from the beginning, and it’s time to put the residents first. A scathing report by the USEPA Attorney General documents that USEPA and NJDEP did not ensure this Superfund site cleanup progressed at a timely pace, along with numerous other failures. The report can be found here: http://www.epa.gov/oig/reports/2008/20080602-08-P-0169.pdf.
This site cleanup has been languishing for over two decades, and it is time for USEPA to take serious action. In order to protect the health and safety of families that utilize this area for recreation, USEPA must require a proper cleanup, such as a modified version of Alternative 7 in the Proposed Plan. Capping this site violates USEPA's preference for permanent, cost effective, and protective cleanups, as caps always fail, especially in a floodplain. Other alternatives offer more permanent solutions for this cleanup.
This year, Pfizer will spend upwards of $8 billion on research. With some of the finest minds in the world and a CEO with a chemical engineering degree, why is Pfizer using cheap and outdated technology to cleanup this site? We need USEPA to protect public health and the environment, not the profits of Pfizer Executives Ian Read, Sally Susman, and Frank D'Amelio!
With dozens of permanent environmental cleanup options, which are being used throughout the United States, why is the lowest cost and least protective technology being thrown out as the only solution? This raises serious questions of the technical competency of not only CRISIS’ “technical advisor”, but all the stakeholders involved in this cleanup proposal.
I support the plans put forth by the nationally recognized environmental expert, the nonprofit Edison Wetlands Association, and their scientists and engineers to bring in a low temperature thermal desorption unit as well as utilize other technologies as appropriate for the various toxic and other wastes disposed of on site. I want other treatment technologies used that permanently remediate, not cap or solidify, the waste on site. Capping and/or solidifying the toxic and other wastes on site should not be used under any circumstances in this floodplain.
Thank you for your timely assistance on this important environmental issue.