Waste Classification Sampling and Off-Site Disposal. All soils with constituent levels above SCOs, as well as other soils that Sun Chemical determined were inappropriate to leave on-site (e.g., pigment-stained soils), were disposed of off-site either at the Pure Earth, Inc. facility in Vineland, New Jersey (“Pure Earth”, for non- hazardous waste) or at the Xxxxx Ecology Oil Salvage, Inc. facility in Vineland, New Jersey (“Xxxxx”, for hazardous waste). As summarized below, composite soil samples were first collected from excavated soils for waste classification purposes as required by these disposal facilities. The frequency of this sampling was also determined by disposal facility requirements, as well as by the locations from which a given quantity of soil was derived. For example, ENVIRON collected a minimum of one waste classification sample from each soil pile generated per the soil segregation specifications provided above in Section 5.2.5, and thus, at least one waste classification soil sample was collected from each IRM area. For certain IRM areas from which relatively large soil volumes were removed or when the total soil volume was removed over a relatively extended period of time (e.g., the Blue Wing), several waste classification samples were collected to ensure that the soil volume was fully characterized. Separate waste classification samples were also collected from soils segregated based on visible evidence of potential contamination, including pigment staining or anthropogenic fill materials (i.e., at the Storage Building and Powerhouse). Per Pure Earth/Xxxxx requirements, all waste classification soil samples from the Site were analyzed for the following constituents/parameters: • RCRA characteristics (i.e., ignitability, corrosivity and reactivity); • Full RCRA inorganic and organic list by TCLP; • PPMs+Ba; • PCBs; • VOCs (total); and • Gasoline-range and diesel-range organics. Analytical results from these samples are provided in Appendix B and indicate that with one exception, all soils excavated from the Site were classified as RCRA non-hazardous waste. The only exception, fill material and soils removed from directly beneath the Powerhouse slab, were classified as RCRA characteristic waste for lead (USEPA waste code D008) due to a lead concentration of 7.3 mg/l in the sample, compared to the maximum allowable concentration of
