PB99-963122
EPA541-R99-098
1999
EPA Superfund
Record of Decision Amendment:
Woodland Routes
72 Dump and 532 Dump Sites
Woodland Township, NJ
7/1/1999
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SUPERFUND RECORD OF DECISION AMENDMENT
WOODLAND TOWNSHIP ROUTE 72 SITE
WOODLAND TOWNSHIP ROUTE 532 SITE
WOODLAND TOWNSHIP, BURLINGTON COUNTY
NEW JERSEY
Prepared by: N. J. Department of Environmental Protection
Site Remediation Program
Bureau of Federal Case Management
April 1999
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DECLARATION FOR THE RECORD OF DECISION AMENDMENT
'i v- ;-
SITE NAME AND LOCATION
Woodland Township Route 72 Site
Woodland Township Route 532 Site
Woodland Township, Burlington County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This Record of Decision presents the selected remedial action for the Woodland
Township Route 72 and Route 532 Sites, which has been chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation and
Liability Act, as amended, and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan. This Record of Decision explains the factual
and legal basis for selecting the remedy.
The US Environmental Protection Agency (EPA) concurs with the selected remedy. This
Record of Decision is based on the administrative record file for these sites.
ASSESSMENT OF THE SITES
Actual or threatened releases of hazardous substances from the Woodland Township
Route 72 and Route 532 Sites, if not addressed by implementing the response action
selected in this Record of Decision Amendment, may present an imminent and
substantial threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy addresses the contaminated ground water at the Woodland
Township Route 72 and Route 532 Sites. The major components of the selected remedy
include the following:
Ground water in the site disposal areas at both the Route 72 and Route 532 Sites will be
remediated using an air sparging system to inject air into the saturated zone and strip
away volatile and semi-volatile organic compounds dissolved in ground water and
adsorbed to the soil, a soil vapor extraction system to capture sparged vapors, and a
vapor treatment system to treat the soil vapor extraction offgas.
The downgradient portion of the plumes at both sites will be allowed to naturally
attenuate.
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DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost effective. The remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable. The selected
remedy is a permanent remedy and satisfies the statutory preference for treatment as a
principal element.
Because this remedy will result in hazardous substances remaining in the ground water
downgradient of the Site above health-based levels, a review will be conducted within
five years after commencement of the remedial action to ensure that it continues to
provide adequate protection of human health and the environment.
/kichard J. Gimpn'oT'&ssistant Commissioner
New Jersev^fepartmenyof Environmental
Protection
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TABLE OF CONTENTS
INTRODUCTION
SITE BACKGROUND
SITE HISTORY AND ENFORCEMENT ACTIVITIES
RESULTS OF THE VARIOUS STUDIES
BASIS FOR THE ROD AMENDMENT
REMEDIAL ACTION OBJECTIVES
DESCRIPTION OF ALTERNATIVES
EVALUATION OF ALTERNATIVES
SELECTED REMEDY
CONTINGENCY REMEDY
STATUTORY DETERMINATIONS
DOCUMENTATION OF SIGNIFICANT CHANGES
ATTACHMENTS
APPENDDU: FIGURE
APPENDIX II:
APPENDIX III:
APPENDLXIV:
TABLES
ADMINISTRATIVE RECORD
RESPONSIVENESS SUMMARY
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5
8
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32
68
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INTRODUCTION
The Woodland Township Route 72 she and Woodland Township Route 532 she are
located in Woodland Township, Burlington County, New Jersey. Both shes are situated
within the Preservation Area District of the New Jersey Pinelands. The Route 532 site also
falls within the designated "special agricultural area" of the Pinelands. Both shes were
used as disposal facilities for waste materials during the 1950s.
The New Jersey Department of Environmental Protection (NJDEP) is the lead agency that
has overseen activities at the Woodland Township Shes since 1985 under various
Administrative Consent Orders (ACOs). The U.S. Environmental Protection Agency
(EPA) is the support agency. Both sites were listed on the National Priorities List (NPL) in
September 1983. Current site work is being performed under an August 15, 1991 ACO
(AGO IV) between NJDEP and Hercules, 3M, and Rohm and Haas.
As with many Superfund shes, the problems at the Woodland Township Route 72 and
Route 532 shes are complex. As a result, NJDEP has organized the remedial work into two
operable units. Operable Unit One addressed the contaminated surface material and the
contaminated ground water at both shes. Operable Unit Two addressed the subsurface
soils.
The Record of Decision (ROD), signed on May 16, 1990, documented the selection of the
remedial action for Operable Unit One. Under the 1990 ROD, the contaminated surface
materials were disposed of at an off-she facility. This work was conducted under ACO in
(dated June 15, 1990) and was completed in 1990. The ROD also required treatment of
contaminated ground water by extraction and treatment. It was specified in the ROD and
ACO IV that various studies be conducted prior to implementation of the ground water
extraction and treatment remedy. These studies consisted of a bench-scale treatability test
for extracted ground water, a ground water flow model, an ecological-risk assessment, an
environmental/resource inventory, and an evaluation of ground water remedial approaches.
These studies then led to the determination that air sparging and soil vapor extraction is a
more appropriate remedy for the shes because this technology will remediate the on-site
ground water contamination in less time and at a substantially lower cost than ground water
extraction and treatment. In addition, air sparging-soil vapor extraction will not affect the
level of the ground water table as the ground water extraction and treatment remedy would,
thereby being more protective of the wetlands.
The Proposed Plan for the ROD Amendment was released to the public for comment on
September 22,1998. This document as well as all the reports and documentation related to
this Record of Decision Amendment were made available to the public in both the
administrative record and information repositories indicated below. The notice of
availability for these documents was published in the Burlington County Times on
September 22, 1998. A public comment period on the documents was held from
September 22, 1998 to October 22, 1998 (30 calendar days). In addition, a public meeting
was held on October 8, 1998. At this meeting NJDEP representatives answered questions
about the proposed remedy at the sites. A response to comments raised at the public
meeting as well as comments received in writing is included in the Response Summary,
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which is part of this ROD Amendment. In accordance with the NCP, section
300.825(aX2), this ROD Amendment will become part of the Administrative Record File.
The Administrative Record may be found at the following locations:
Woodland Township Municipal Building
Main Street
Chatsworth, NJ 08019
(609)726-1700
NJ Department of Environmental Protection
Bureau of Community Relations, Floor 6
401 East State Street, P.O. Box 413
Trenton, NJ 08625
(609) 984-3081
SITE BACKGROUND
The Route 72 site is approximately 12 acres in size and is located on tax block 5501, lot 15
and tax block 6301, lot 1. The she is 1/4 mile south of Route 72 along Crawley Road.
Crawley Road is labeled as Sooey Road on United States Geological Survey maps.
Crawley Road meets Route 72 approximately 1 and 1/3 miles southeast of the intersection
of Route 532 and Route 72. Approximately 800 acres of wetlands, including cedar swamp,
bog hardwood swamp, and pitch-pine lowland are located in close proximity to the Route
72 she. Pope Branch, an intermittent stream, is located approximately 500 feet to the north
and 1,000 feet west of the she. An active commercial cranberry bog is located
approximately 1/2 mile northwest of the site.
The Route 532 she is approximately 20 acres in size and is located on tax block 4210, lot 1.
The site is at the end of an access road approximately 1/8 mile south of Route 532. The
unnamed site access road meets Route 532 approximately 1 and 1/8 miles west of the
intersection of Route 532 and Route 72. Goodwater Run, an intermittent stream, and
Bayley Road border the site to the east. An unpaved forest fire control road runs along the
southern edge of the she. More than 200 acres of wetland including cedar swamp, bog,
hardwood swamp, and pitch-pine lowland are located downgradient of the former disposal
area of the Route 532 Site. Active commercial cranberry bogs are located approximately 1
mile west-southwest of the site.
One private residence is located within a 3-mile radius of each site. The sites are
approximately 3 miles apart and are at an average elevation of 125 feet above mean sea
level. Both shes are characterized by loose sandy soils.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
Route 72 Site
Francis Estlow owned the Route 72 site until 1957, when the property was purchased by
Rudolf Kraus. Rudolf and/or Eleanor Kraus also owned Industrial Trucking Services
Corporation, the company that reportedly transported the waste materials to the sites for
disposal. Cohen, Weiss and Krell purchased the property in April 1964. It is unclear from
Woodland Township records when the property was acquired hy hs current owner,
Airtime, Inc.
A 1951 aerial photograph of the site illustrates conditions prior to the waste disposal
operation. Probable concrete pads, possible basement space, a utility building and a
sidewalk can be observed. An unpaved road connected the site to the perimeter road of the
Coyle Airport. Crawley Road and a fire road north of the site were also present
A 1956 photograph shows several trenches elongated in an east-west direction on the
northern third of the site. The trenches were located on both sides of Crawley Road. The
central portion of the site was covered with general refuse and stained soils. Small
depressions containing standing liquid were evident on the western half of the site. The
southern portion of the site west of Crawley Road contained a wide depression with
standing liquid in it. The southern portion east of Crawley Road contained several shallow
trenches oriented along a north-south axis.
Between 1956 and 1962, the site layout remained unchanged based on a 1962 photograph.
However, the trenches were apparently deepened, and those in the northern and southern
portions of the site contained a standing light-colored liquid.
A 1984 photograph did not identify any changes to the site since 1962. The outlines of
trenches and depressions could be observed. Drums, stained soils, and general refuse were
identifiable in the central portion of the she. Much of the pine forest at the edge of the site
had regenerated, while on-site disposal areas remained unvegetated. This site was also
uncontrolled between 1962 and 1986. In 1986, the Potentially Responsible Parties (PRPs)
constructed a security fence to restrict site access.
Route 532 Site
Early records indicate ownership of the Route 532 site by Francis Estlow. In 1973, Estlow
sold the property to Cohen, Weiss and Krell. In 1976, Airtime, Incorporated purchased the
property and subsequently sold it to its present owners, Joseph and Albert Spitzer.
An aerial photograph from 1951 shows that a pine forest existed in the study area prior to
the beginning of disposal operations. The exact date disposal began is unknown; however,
it is estimated to have begun between 1951 and 1956. The western half of the Route 532
site was organized into a series of bermed lagoons when the disposal began. A 1956 photo
indicated these lagoons contained black liquid waste. It was also evident from the
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photograph that this waste was released along an on-ske road and flowed toward a depres-
sion.
By 1962, most of the disposal areas had been regraded. In a 1962 aerial photograph, new
bulldozer scrape marks indicate that the disposal area was being enlarged. The black
liquid, previously dumped on site, had also breached the lagoon berm and was flowing into
the nearby pine forest. A second flow was observed extending from the eastern border
toward the path of Goodwater Run.
A 1984 photograph indicated that the site remained essentially unchanged between 1962
and 1984. Denuded areas could be observed where the two liquid flows moved off site.
The photograph also shows partially buried drums on the down-slope edges of the former
lagoons and road on the western half of the she. Partially buried drums and general refuse
were piled along former roads on the eastern half of the property at that time. No site
controls were in place from 1962 to 1986. In 1986 the PRPs constructed a security fence to
restrict site access.
Enforcement Activities
The Burlington County Health Department in April 1979 advised the NJDEP of
environmental problems at the sites. The NJDEP subsequently conveyed the information
to the USEPA. At about the same time, a biologist investigating endangered species for the
NJDEP also reported environmental problems at the shes.
Due to similarities at the two sites (i.e., PRPs, waste disposal practices, location and
physical/chemical characteristics), enforcement efforts for the sites have been combined.
The NJDEP issued a directive on March 4, 1985 to the Rohm and Haas Company, the
Minnesota Mining and Manufacturing (3M) Company, Hercules, Inc., and other companies
identified as PRPs to arrange for the investigation and remediation of the sites. On March
27, 1985 the NJDEP entered into an Administrative Consent Order (ACO) with Hercules,
Incorporated to help pay for the investigative and administrative costs. On July 6, 1987,
the NJDEP entered into a similar ACO with 3M and Rohm and Haas Company.
On January 2,1990, the NJDEP entered into a second Administrative Consent Order (ACO
II) with Hercules, 3M, and Rohm and Haas. The purpose of this ACO was to compel the
PRPs to remove liquids and sludges from isolated locations on the sites' surfaces.
On May 16, 1990 a Record of Decision (ROD) was signed for Operable Unit 1. The
selected remedy in this ROD included the following:
Surface Materials
Excavation and further characterization of 54,000 cubic yards of contaminated surface
materials and sediments (soils, sludges, debris, etc.) and 19 cubic yards of
radiologically contaminated surface materials.
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Disposal of the excavated materials at a permitted off-site facility.
Ground Water
Extraction of the contaminated ground water plume, and treatment of the extracted
ground water prior to reinjection.
Conduct the following assessments prior to the remedial design of the ground water
system: endangered species survey, biological survey, wetlands delineation and
assessment, floodplain impacts, and cultural resources survey.
The excavation and off-she disposal of the surface materials was conducted in 1990. The
actual amount of contaminated materials and sediments removed from the Route 72 and
532 sites was 37,200 and 60,200 cubic yards, respectively, compared to the ROD estimate
of 54,000 cubic yards. Part of the reason for the higher volumes is that much of the
contaminated subsurface soils were removed along with the removal of the visibly
contaminated surface materials. These soils had been acting as a source of continuing
contamination of the ground water. The excavation of the soil was intended to minimize
cross-media impacts of contaminated soil on the ground water. The removal of additional
subsurface soils further reduced these impacts.
Subsequent to the excavation of the contaminated surface materials, the sites were graded
to prevent soil erosion. Protective vegetative and mulch covers were also established to
prevent erosioa The May 1990 ROD called for final restoration of the sites after the
remedial actions were completed.
On August 15, 1991, the fourth AGO (AGO IV) was signed with Hercules, 3M, and Rohm
and Haas. The purpose of this AGO was to require the PRPs to extract and treat
contaminated ground water as specified in the ROD and to perform a remedial
investigation and feasibility study (RI/FS), and remedial action, if necessary, for the
subsurface soils. Based on the data collected in the RI, it was determined that no
remediation was needed for the subsurface soils and a "No Further Action" ROD was
issued in September 1993.
RESULTS OF THE VARIOUS STUDIES
A Remedial Investigation (RI) was conducted in three phases from 1985 through 1989.
The RI activities primarily consisted of sample collection and analysis of soils, wastes,
ground water, potable wells, air, surface water, sediments, and cranberries. It was
determined that ground water was contaminated at both sites with various volatile organic
compounds (VOCs), semi-volatile organic compounds (SVOCs) and inorganics. The
various contaminants include 1,2-dichIoroethane, 1,1,2,2-tetrachloroethane, bis(2-
chloroethyl)ether, benzene, and toluene. Tables 1 and 2 list all the contaminants and the
maximum concentrations found at the Route 72 and Route 532 Sites, respectively.
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As part of the RI, a baseline Risk Assessment was prepared. For the ground water portion
of the assessment, it was assumed that human beings would live at both sites in the future
and would use the ground water for household activities. The exposure pathways that were
considered were dermal absorption, ingestion, and inhalation of contaminants from ground
water beneath the sites.
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer
potency factor. These risks are probabilities that are generally expressed in scientific
notation (e.g., IxlO"6 or 1E-6). An excess lifetime cancer risk of IxlO"6 indicates that, as a
plausible upper bound, an individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-year lifetime under the specific
exposure conditions at a site,
Potential concern for non-carcinogenic effects of a single contaminant in a single medium
is expressed as the hazard quotient (HQ). By adding the HQs for all contaminants within a
medium or across all media to which a given population may reasonably be exposed, the
Hazard Index (HI) can be generated. A HI greater than 1 indicates that adverse non-
carcinogenic effects may occur.
For the Route 72 Site, a total carcinogenic risk greater than 2xlO"1 (2 in 10) was calculated
for ground water use, which exceeds a target risk of IxlO"6. The non-carcinogenic hazard
exceeded the HI of 1, indicating a potential cause of concern to human health. For the
Route 532 site, a worst case carcinogenic risk of IxlO"2 (1 in a hundred) was calculated and
the non-carcinogenic hazard exceeded the HI of 1. For both the Route 72 and Route 532,
there are no present risks since the contaminated ground water is not being used as drinking
water at this time. This information is documented in the report entitled Remedial
Investigation/Feasibility Study for the Woodland Township Route 532 and Route 72
Hazardous Waste Sites, dated July 1989.
Treatability studies for extracted ground water were conducted in 1992 and 1993. It was
determined that the ground water could be treated to meet the treatment objectives. This
information is documented in Groundwater Treatability Studies for the WPSG Route 532
and Route 72 Sites, dated December 1993.
The ground water flow model was developed to predict the outcome of various ground
water extraction and discharge scenarios and to predict the fete of contaminants in the
Cohansey Aquifer. The model was developed to evaluate ground water and wetlands
impacts associated with the ground water extraction and treatment system. The model
results indicated that ground water extraction of the entire downgradient plume, as
specified in the ROD, would dewater 2.2 square miles of wetlands and surface water bodies
within and adjacent to areas overlying the downgradient portion of the ground water plume.
In addition, the model results indicated that an upgradient recharge scenario could result in
raising the water table up to 20 feet, thereby having a negative impact to the uplands.
Ecological risk assessments were performed to estimate the ecological risk associated with
the downgradient discharge of site-related compounds to potential receptors. The
ecological risk assessments indicated that the risk to receptors in the downgradient
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wetlands from chemicals discharging from ground water was negligible at the Route 72 site
and no measurable impact to the ecosystem related to the ground water plume was
observed or anticipated in the surface water and wetlands downgradient of the Route 532
site. This information is documented in the reports entitled Ecological Risk Assessment,
Route 72 Groundwater Plume, dated September 1994 and Ecological Risk Assessment,
Wetland Study Area, Route 532 Superfund Site, Woodland Township, Burlington County,
New Jersey, dated April 4,1995.
An assessment of environmental impacts associated with the ground water extraction and
treatment remedy was completed to satisfy the requirements of the ROD and AGO IV to
protect human health, the environment, and the sensitive New Jersey Pinelands
environment Several reports were prepared addressing downgradient sampling results and
ecological considerations at, and downgradient of, the sites. These reports determined that
there was no apparent ecological stress in the study area stream system related to the
discharge of the Route 72 ground water plume; there were no measurable impacts
associated with the downgradient ground water plume of the Route 532 site on the
wetlands, cranberry bogs, and harvested cranberries; and the Shoal Branch and its wetlands
prevent further travel of the Route 72 ground water plume to Dukes Bridge. In addition, 14
critical environmental and ecological resources that could be impacted by remediation of
the sites were identified. They included wetlands, wetland transition areas, floodplain,
streams, hydrologic resources, species of concern, soils, cultural resources, rare natural
communities, fire ecology, agricultural resources, topographic resources, recreational land
use, and scenic resources. The detailed evaluation of ground water remediation approaches
evaluated various remedial alternatives and recommended air sparging and soil vapor
extraction as the most promising alternative because of its ability to actively and directly
remediate the chemical mass residing in the subsurface at the disposal areas of the sites.
This information is documented in the reports entitled Final Draft Environmental
Constraints Analysis Route 532 Superfund Site, Woodland Township, Burlington County,
New Jersey, dated October 4, 1993; Final Draft, Route 72 Superfund Site Environmental
Resources Inventory, Woodland Township, Burlington County, New Jersey, dated October
1994; Detailed Evaluation of Groundwater Remedial Approach, Part III of III - Remedial
Alternatives Analysis (Final Draft), Route 72 Site, Woodland Township, New Jersey, dated
June 10,1996; and Detailed Evaluation of Groundwater Remedial Approach, Part III of HI
- Remedial Alternatives Analysis, (Final Draft), Route 532 Site, Woodland Township, New
Jersey, dated June 13, 19%.
In 1996, an air sparging and soil vapor extraction field demonstration was conducted at
both sites. The results showed that chemical mass can be rapidly reduced. Ground water
concentrations were reduced by 1 to 3 orders of magnitude at locations 10 to 15 feet away
from the sparging well in a matter of weeks. The results of this field demonstration are
documented in the Field Demonstration Report Air Sparging and Soil Vapor Extraction
(Final Draft), Route 72 and Route 532 Superfund Sites, Woodland Township, New Jersey,
dated November 18, 1996.
The Final Focused Feasibility Study, Route 72 and Route 532 Sites, Woodland Township,
Burlington County, New Jersey, dated August 14, 1997, was then prepared which
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compared the ground water extraction and treatment remedy in the ROD with the air
sparging and soil vapor extraction alternative.
BASIS FOR THE ROD AMENDMENT
Under 1990 ROD, ground water was to be treated by extraction of the contaminated
ground water plume, treating the extracted water, and then reinjecting the treated water
back into the aquifer. Treatment would consist of air stripping, metals removal,
biological treatment, and advanced oxidation or carbon adsorption. At the Route 72 she,
the entire plume would be treated. At the Route 532 site, the downgradient portion of the
plume would be allowed to naturally attenuate.
Various studies were conducted subsequent to the ROD to fulfill the requirements of the
ROD and AGO IV. The environmental impacts associated with the ground water
extraction and treatment remedy were assessed and k was determined that there was no
apparent ecological stress in the study area stream system related to the discharge of the
Route 72 ground water plume; there were no measurable impacts associated with the
downgradient ground water plume of the Route 532 site on the wetlands, cranberry bogs,
and harvested cranberries; and the. Shoal Branch and hs wetlands prevent further travel of
the Route 72 ground water plume to Dukes Bridge. In addition, fourteen critical
environmental and ecological resources that could be impacted by remediation of the
sites using the ground water extraction and treatment remedy were identified. They
included wetlands, wetland transition areas, floodplain, streams, hydrologic resources,
species of concern, soils, cultural resources, rare natural communities, fire ecology,
agricultural resources, topographic resources, recreational land use, and scenic resources.
The detailed evaluation of ground water remediation approaches evaluated various
remedial alternatives and recommended air sparging and soil vapor extraction as the most
promising alternative. In 1996, an air sparging and soil vapor extraction field
demonstration was conducted at both sites. The results showed that chemical mass in the
ground water was rapidly reduced. Based on the results of the various studies and the
field demonstration, in 1997 the PRPs requested that NJDEP and EPA consider allowing
air sparging and soil vapor extraction instead of ground water extraction and treatment
for the remediation of the ground water at both sites.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment.
The following remedial action objectives were established for the ground water:
The ground water at the site is classified as 1-PL (Preservation Area). Pursuant to the
Ground Water Quality Standards (N.J.A.C. 7:9-6 et seq.X the ground water quality
criterion for Class 1-PL areas is the natural quality for each constituent. For a
constituent whose natural quality level is less than the Practical Quantitation Level
(PQL), which is the lowest concentration of a constituent that can be reliably detected
during routine laboratory operating conditions, then the PQL is the Ground Water
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Quality Criterion. The Ground Water Quality Criteria for various contaminants are
listed in Table 3.
Adverse environmental impacts and permanent ecological damage in sensitive areas
must be avoided.
Human health and the environment must continue to be protected through remediation
and institutional controls.
A standard of performance equivalent to the ground water extraction and treatment
remedy specified in the ROD must be attained.
All parts of the ground water plume containing chemical concentrations exceeding
either the NJDEP's Ground Water Quality Standards or the Federal MCLs must be
remediated. Ground water within the site disposal areas that is considered to potentially
impact ground water quality downgradient will be actively remediated, while remaining
areas outside of the vertical and horizontal extent of these areas will naturally attenuate.
Those areas where ground water contains aromatic hydrocarbon concentrations in
excess of one percent solubility or 1,2-DCA concentrations in excess of 100 times the
ground water quality standard are considered areas impacting ground water quality.
For the Route 72 site, the ROD required that the entire plume be treated using the pump
and treat remedy to prevent ground water contamination from impacting the potable
wells in Dukes Bridge. Investigations conducted after the ROD have determined that
the ground water contaminant plume discharges into Shoal Branch and does not
threaten the potable wells of Dukes Bridge. This ROD Amendment allows the
downgradient contaminant plume to naturally attenuate, which differs from the 1990
ROD.
For the Route 532 site, the 1990 ROD specified that the downgradient portion of the
contaminant plume be allowed to naturally attenuate. This ROD Amendment also
provides that the downgradient portion of the contaminant plume be allowed to
naturally attenuate.
DESCRIPTION OF ALTERNATIVES
CERCLA §121(b)(l), 42 U.S.C. §9621 (b)(l), mandates that a remedial action must be
protective of human health and the environment, cost effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. Section 121(b)(l) also establishes a preference for remedial
actions that employ, as a principal element, treatment to permanently and significantly
reduce the volume, toxicity or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a
remedial action must attain a level or standard of control of the hazardous substances,
pollutants and contaminants, which at least attains ARARs under federal and state laws,
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unless a waiver can be justified pursuant to CERCLA §121(d) (4), 42 U.S.C. §9621
This amended ROD evaluates in detail two remedial alternatives for addressing the
ground water contamination at the Woodland Township Route 72 and Route 532 sites.
The time to implement each remedial alternative reflects the time required to design and
construct or implement the remedy. The costs presented for each alternative include
capital costs and operation and maintenance (O&M) costs over a thirty year period.
The remedial alternatives are:
Alternative 1: Ground Water Extraction and Treatment (Remedy selected in 1990 ROD)
The costs presented below are in 1990 dollars.
Route 72 Site
Estimated Capital Cost: $ 1 8,000,000
Estimated Annual O&M Cost: $ 6,400,000
Years of Operation: 30
Estimated Net Present Value: $80,000,000
Route 532 She
Estimated Capital Cost: $5,200,000
Estimated Annual O&M Cost: $ 1,100,000
Years of Operation: 30
Estimated Net Present Value: $22, 1 00,000
Total Estimated Net Present
Value for both sites: $102,000,000
This remedy consists of collection wells for the extraction of contaminated ground water,
which would be treated and then reinjected back into the aquifer. The treatment of the
ground water would consist of biodegradation, air stripping, and a polishing step, if needed,
to attain treatment objectives. The polishing step would consist of either granular activated
carbon or advanced chemical oxidation processes.
For the Route 72 site, all contaminated ground water would be extracted and treated at an
estimated rate of between 965 gallons per minute (gpm) to 7,000 gpm (1.34 to 10 million
gallons per day) to achieve most ARARs in approximately 30 years; the former pumping
rate is the estimate provided in the original RI/FS Report (CDM, 1989) and the latter is an
estimate based on recent ground water modeling presented in the Final Focused Feasibility
Study.
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For the Route 532 site, contaminated ground water from beneath the former disposal area
would be extracted and treated at an estimated extraction rate of 400 gpm. This rate was
estimated to prevent the further migration of the ground water contamination plume from
beneath the former disposal she. The downgradient portion of the contamination plume
would be allowed to naturally attenuate. It was estimated that the remaining ground water
contamination plume would be removed in approximately 30 years.
At both sites, monitoring of ground water and surface water would continue until the
ARARs are obtained. Although not an existing institutional Control at the time the 1990
ROD was issued, ground water use would be managed with the identification of a
Classification Exception Area within and immediately adjacent to the ground water
contaminant plume at both sites until ARARs are obtained.
Alternative 2: Air Sparging and Soil Vapor Extraction
The costs presented below are in 1997 dollars.
Route 72 Site
Estimated Capital Cost: $2,800,000
Estimated Annual O&M Cost: $ 860,000
Years of Operation: 5
Estimated Net Present Value: $9,000,000
Route 532 She
Estimated Capital Cost: $2,100,000
Estimated Annual O&M Cost: $ 410,000
Years of Operation: 5
Estimated Present Value: $5,500,000
Total Estimated Net Present
Value for both sites: $14,500,000
The remedy consists of (1) an air sparging system to inject ah- into the subsurface below the
water table, a soil vapor extraction system installed above the water table to collect the
sparged vapors, and a vapor collection system to treat off-gas vapor from the ground water
and soils beneath the disposal area, and (2) natural attenuation of the downgradient ground
water contaminant plume.
For the Route 72 she, sparging wells will be placed to an estimated depth of 15 to 30 feet
below ground surface. The air sparging system will either inject air continuously or in
pulsed modes depending on whichever is determined based on performance data to be most
effective.
II
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It is anticipated that the Route 72 site soil vapor extraction system would consist of vapor
extraction wells located above the water table. The air sparging-soil vapor extraction
system will be designed to remove as many of the organic contaminants above the first
fine-grained layer (approximately the top 22 feet of the saturated zone) as possible. Only
the volume of soil and water above the upper fine-grained layer is targeted because most of
the site disposal area contamination resides in this zone. Volatilization and biodegradation
would remove the VOCs, while the SVOCs would be removed mostly through
biodegradation.
For the Route 532 site, the air sparging system would consist of sparging wells placed at
an estimated depth of 12 to 35 feet below ground surface, corresponding to the depths just
above and within the fine-grained unit, where the majority of the contamination lies. The
air sparging system will either inject air continuously or in pulsed modes depending on
whichever is determined based on performance data to be most effective. The soil vapor
extraction system would remove VOCs by volatilization, oxidation and biodegradation,
while the SVOCs would be removed mostly through oxidation and biodegradation.
The introduction of sparge air would be accomplished using low-pressure, oil-free air
compressors at each site. Soil vapor extraction at each site would be accomplished using
explosion-proof positive-displacement or regenerative blowers, each with a moisture
separator and filter to protect the blower. Two units may be used to provide operating
flexibility and to conserve power.
Vapor treatment at each site will be accomplished by either destructive oxidation and/or
absorptive (e.g., activated carbon) technologies depending on the amount and types of
contaminants present in the vapor stream during the period of operation.
The estimated time frame for air sparging-soil vapor extraction to complete ground water
remediation is dependent on various factors including: well spacing, volumes of sparged
air, subsurface geology, geochemistry, and the specific physical and chemical properties of
the ground water contaminants. Results of predictive models have indicated that the
proposed air sparging-soil vapor remedies for the former disposal areas at both sites will
significantly remove the remaining contaminants present in ground water beneath the
former disposal areas within six months to five years after start-up of the air sparging-soil
vapor extraction remedies. These model predictions are consistent with results observed
during the air sparging-soil vapor extraction pilot tests.
Natural attenuation would be implemented for the downgradient plume of each site.
Routine and periodic sampling and analysis of ground water from selected monitoring
wells would occur on at least an annual basis for approximately 30 years. Chemical
transport modeling of the downgradient contaminant plumes and the source
reduction/control provided by the air sparging-soil vapor extraction at the former disposal
areas will result in ground water ARARs being attained at both sites in approximately 30
years or less.
12
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Current institutional controls include security fences surrounding the former disposal areas
at both sites which will remain in place until at least thfe completion of the air sparging-soil
vapor extraction remedy at the disposal areas. A Classification Exception Area (CEA) and
Well Restriction Area (WRA) will be implemented at both sites. The CEA will suspend
the designated original uses of the ground water beneath each site until ground water
ARARs are attained. The CEA at each site will consist of (1) a written description of and a
map detailing the area at each site that does not meet current ground water ARARs as well
as any known and anticipated ground water migration pathways, (2) a list of chemicals for
which the CEA is being established, and (3) an estimated duration of the CEA. The WRA
for each site will be established to prevent the use of ground water beneath the sites as
potable water where ground water ARARs are exceeded. Finally, sentinel wells have been
installed between the edge of the Route 72 site and Dukes Bridge and have been sampled
periodically since 1994 with no detection of organic ground water contaminants. A
sentinel well network will be established for the Route 532 site as part of the natural
attenuation remedy. The sampling of the sentinel well networks will occur on an annual
basis until it is shown by results of the natural attenuation monitoring that no further
migration of the ground water plume is occurring because these data indicate that the
contaminant plumes are retreating upgradient.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each alternative was assessed
utilizing nine evaluation criteria as set forth in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) and Office of Solid Waste and Emergency Response
(OSWER) Directive 9355.3-01. These criteria were developed to address the requirements
of Section 121 of CERCLA to ensure all important considerations are factored into remedy
selection decisions.
The following "threshold" criteria are the most important, and must be satisfied by any
alternatives in order to be eligible for selection:
Threshold Criteria
1. Overall protection of human health and the environment addresses whether or not
a remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
i
2. Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy will meet all of the applicable or relevant and
appropriate requirements of other federal and state environmental statutes and
requirements or provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify
the major trade-offs between alternatives:
13
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Primary Balancing Criteria
3. Long-term effectiveness and permanence refers to the ability of a remedy to
maintain reliable protection of human health and the environment over time, once
cleanup goals have been met.
4. Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies a remedy may employ.
5. Short-term effectiveness addresses 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.
6. Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
7. Cost includes estimated capital and operation and maintenance costs, and net present
worth costs.
The following "modifying" criteria are considered fully after the formal public comment
period on the Proposed Plan is complete:
Modifying Criteria
8. EPA acceptance discusses if the support agency concurs with the remedy selected by
theNJDEP.
9. Community acceptance is assessed based on a review of the public comments
received on the technical reports and the Proposed Plan.
Route 72 Site
Overall Protection of Human Health and the Environment
The ground water extraction and treatment remedy provides protection to human health
by containing and treating the contaminated plume, but studies show that h may cause
damage to the environment through lowering of the ground water table elevation
associated with ground water extraction, which is particularly damaging to the
wetlands; rise of ground water elevations associated with groundwater recharge; and
physical impacts associated with the construction of the extraction and treatment
system. As a result of those studies, NJDEP and USEPA believe that the ground water
extraction and treatment remedy specified in the 1990 ROD would have to be modified
in order to be implemented at the site.
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Air sparging-soil vapor extraction provides protection of human health and the
environment by rapid reduction of chemical mobility and volume in the site disposal
area. This alternative provides active and aggressive remediation of contaminated
ground water, saturated soil, and unsaturated subsurface soil, thereby permanently
reducing the mass of constituents contributing to potential future risk.
Compliance with ARARs
Applicable or relevant and appropriate requirements (ARARs) are those federal or state
environmental and public health regulations that apply to remedial activities at a site.
There are three classifications of ARARs: chemical-specific, which are health- or risk-
based concentration limits; location-specific, which are based on the geographical
location of the site and its surroundings; and action-specific, which are controls on
particular types of remedial activities.
The ground water extraction and treatment remedy would eventually meet the
chemical-specific ARARs in the ground water. However, it may take an extended
period of time for all ARARs to be reached. The alternative would be able to meet
requirements for air discharges by treating the off-gases from the proposed treatment
plant.
Regarding location-specific ARARs, the ground water extraction, injection, and
treatment systems would be designed and constructed to meet the intent of the
Pinelands Management Plan with respect to preserving the pristine nature of the area
for agricultural, ecological, and social reasons. However, action-specific ARARs
would not be met since the land, streams, wetlands, vegetation, and the ecology will be
significantly disturbed.
For the air sparging-soil vapor extraction system, it is predicted that the chemical-
specific ARARs in the site disposal area will be met in less than five years. The
downgradient portion of the plume is predicted to reach ARARs through natural
attenuation in less than 30 years.
Location-specific ARARs would be met since the air sparging-soil vapor extraction
system would be designed to meet the intent of the Pinelands Management Plan with
respect to preserving the pristine nature of the area for agricultural, ecological and
social reasons.
Action-specific ARARs would be met since the air sparging-soil vapor extraction
system would nonimpact the streams, wetlands, vegetation, ecology and cultural
resources as would the ground water treatment and extraction system.
Long-term Effectiveness
Both the ground water treatment and extraction remedy and the air sparging-soil vapor
extraction remedy will reduce potential human health risks associated with the site
15
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disposal area ground water. With both remedies, some residual contamination may
remain adsorbed to the fine-grained units, however the risk associated with this
contamination can be managed through institutional controls. Air sparging-soil vapor
extraction will reduce concentrations of contaminants at the site disposal area more
rapidly than pumping and treating.
Reduction in Toxicfty. Mobility, or Volume
The ground water extraction and treatment remedy would substantially eliminate the
potential for further migration (mobility) of chemicals beyond the existing plume
through hydraulic control and treatment. This alternative would reduce toxicfty and
volume in the site disposal area very slowly because many chemicals are expected to
remain entrapped in the pore spaces and desorb very slowly. Air sparging-soil vapor
extraction would provide direct, rapid, and permanent reductions in toxicity, mobility,
and volume because it directly targets the areas impacting ground water.
Short-term Effectiveness
There would be short-term adverse impacts to the ecology and environment from the
construction equipment used during implementation of both the ground water
extraction and treatment and air sparging-soil vapor extraction alternatives. The pump
and treat system would cause a significant amount of damage because it requires a large
amount of equipment and extensive construction in previously undisturbed areas.
Disturbance and damage associated with air sparging-soil vapor extraction would be
generally restricted to the site disposal area and existing downgradient monitoring well
network.
Implementability
The ground water extraction and treatment alternative requires further aquifer testing
and pilot-scale testing before it can be designed and implemented. The reinjection
system associated with this alternative has some implementability issues because the
feasibility of injecting or recharging all the extracted ground water upgradient of the
site without adversely impacting the environment is unknown but is judged to be
difficult based on ground water modeling evaluations and a limited assessment of
associated adverse environmental impacts conducted to date.
A pilot test of the air sparging-soil vapor extraction system was performed at the site
and preliminary full-scale operating parameters have been evaluated. The system
would use conventional equipment, which is available from several companies.
Therefore, there are no major implementability issues with this technology.
Cost (Route 72 site only')
The present worth cost for the existing ground water extraction and treatment remedy is
estimated to be $80,000,000 in 1990 dollars for a thirty year period. The present worth
16
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cost for the proposed air sparging-soil vapor extraction system, based on 5 years of
operation and 30 years of ground water monitoring is $9,000,000 in 1997 dollars.
USEPA Acceptance
The USEPA concurs with the proposed change to the ground water remedy.
Community Acceptance
NJDEP solicited comments from the community on the proposed remedial alternatives
for the contaminated ground water at both sites. The attached responsiveness summary
addresses all verbal comments received at the public meeting as well as written
comments received during the public comment period
Route 532 Site
Overall Protection of Human Health and the Environment
Overall protection of human health and the environment would be maintained by
current site conditions and institutional controls and would continue to be provided by
each of the remedial alternatives. Both alternatives would allow for the natural
attenuation of the downgradient plume. The ground water extraction and treatment
alternative provides control over off-site ground water migrating from the site disposal
area. This alternative would take a very long time to treat the contaminated ground
water. The air sparging-soil vapor extraction remedy is anticipated to reduce chemical
mass more quickly and is predicted to meet some ARARs in one-tenth the time
predicted for the ground water extraction and treatment alternative, with little potential
for adverse impact to environmental resources.
Compliance with ARARs
Applicable or relevant and appropriate requirements (ARARs) are those federal or state
environmental and public health regulations that apply to remedial activities at a site.
There are three classifications of ARARs: chemical specific, which are health- or risk-
based concentration limits; location-specific, which are based on the geographical
location of the site and its surroundings; and action-specific, which are controls on
particular types of remedial activities.
The ground water extraction and treatment alternative will likely achieve the chemical-
specific ARARs in the ground water for the downgradient ground water plume in about
25 years. However, it is estimated that ft will take a very long period of time to meet
ARARs in the disposal area.
The location-specific ARARs would be met since the ground water extraction,
injection, and treatment systems would be designed and constructed to meet the intent
of the Pinelands Management Plan with respect to preserving the pristine nature of the
17
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area for agriculture, ecological, and social reasons. However, the land, streams,
wetlands, vegetation, and the ecology will be significantly disturbed.
Action-specific ARARs would not be met since the ground water extraction and
injection systems would impact the streams, wetlands, vegetation, and ecology.
The air sparging-soil vapor extraction alternative will likely attain chemical-specific
ARARs in as little as two to five years in most areas of the site disposal area. It is
estimated that ARARs will be obtained in the downgradient plume in approximately 25
years.
The air sparging-soil vapor extraction system would meet location-specific ARARs
since the system would be designed to meet the intent of the Pinelands Management
Plan with respect to preserving the pristine nature of the area for agriculture, ecological
and social reasons.
The air sparging system would meet action-specific ARARs since the system would not
impact the streams, wetlands, vegetation, ecology, and cultural resources as would the
ground water extraction and treatment system.
Long-term Effectiveness
The long-term effectiveness of the ground water extraction and treatment alternative is
satisfactory. It can slowly reduce chemical concentrations within the aquifer, but may
not reduce levels within the site disposal area to meet ARARs in a reasonable time
frame. The air sparging-soil vapor extraction system would rapidly reduce the site
disposal area chemical mass, thereby rapidly reducing chemical concentrations which
may contribute to potential future risks.
Reduction of Toxicity. Mobility, or Volume
The ground water extraction and treatment alternative would substantially eliminate
off-site migration (mobility) of the she disposal area compounds through hydraulic
control and treatment. This alternative would also reduce toxicity and volume in the
site disposal area, though very slowly, because many chemicals are expected to remain
entrapped in the pore spaces and desorb very slowly. The air sparging-soil vapor
extraction alternative would provide direct, rapid, and permanent reductions in toxicity
and volume because it targets the areas impacting ground water quality.
Short-term Effectiveness
There would be short-term adverse impacts to the ecology and environment from the
construction equipment used during implementation of both the ground water
extraction and treatment alternative and the air sparging and soil vapor extraction
alternative. The ground water extraction and treatment alternative is likely to cause
more damage than the air sparging-soil vapor extraction alternative because it requires
18
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the largest amount of equipment and construction, and some of the construction would
occur in previously undisturbed areas.
Impiementability
Both alternatives would be technically feasible to implement. The ground water
extraction and treatment alternative requires further aquifer testing and pilot-scale
testing before it can be designed and implemented. The ground water extraction and
treatment alternative requires more testing to provide design information than the air
sparging-soil vapor extraction alternative. The air sparging-soil vapor extraction
alternative can be implemented more rapidly. The reinjection system associated with
the ground water extraction and treatment alternative has some implementability issues
because the feasibility of injecting all the extracted ground water upgradient of the site
without adversely impacting the environment is unknown, but is judged to be difficult
based on ground water modeling evaluations conducted to date.
Cost (Route 532 site only)
The present worth cost for the existing ground water extraction and treatment remedy is
estimated in 1990 dollars to be $22,100,000 for thirty years of operation. The present
worth cost for the air sparging-soil vapor extraction alternative is estimated to be
$5,500,000 in 1997 dollars, which is based on five years of operation and 30 years of
ground water monitoring.
USEPA Acceptance
The USEPA concurs with the proposed change to the ground water remedy.
Community Acceptance
NJDEP solicited comments from the community on the proposed remedial alternatives
for the contaminated ground water at both sites. The attached responsiveness summary
addresses all verbal comments received at the public meeting as well as written
comments received during the public comment period.
SELECTED REMEDY
After reviewing the alternatives and public comments, NJDEP and EPA have determined
that Alternative 2 is the appropriate remedy for the sites because it best satisfies the
requirements of CERCLA §121, 42U.S.C. §9621, and the NCP's nine evaluation criteria
for remedial alternatives, 40 CFR §300.430(eX9).
19
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The major components of the modified remedy are as follows:
Ground water in the site disposal areas at both the Route 72 and Route 532 sites will be
remediated using an air sparging system to inject air into the saturated zone and strip
away volatile and semi-volatile organic compounds dissolved in ground water and
adsorbed to the soil; a soil vapor extraction system to capture sparged vapors; and a
vapor treatment system to treat the soil vapor extraction offgas.
The downgradient portion of the plumes at both sites will be allowed to naturally
attenuate.
CONTINGENCY REMEDY
A contingency remedy will be implemented at each site if any of the following conditions
occur. The contingency remedy for both sites will consist of a ground water extraction and
treatment system. This system would be modified from the system described in the 1990
ROD.
A formal workplan for Natural Attenuation complying with all Federal and State
requirements for implementing that portion of the remedy at each site will be submitted to
NJDEP and USEPA. In accordance with OSWER directive 9200.4-1, if it is determined
that the Natural Attenuation remedy for the downgradient plumes at each she is not
adequately protective of human health and the environment, the Contingency Remedy or
another technology of equal or greater effectiveness will be implemented. Any technology
other than the Contingency Remedy will be subject to public comment.
The ground water monitoring program will include quarterly ground water monitoring for
at least 8 quarters. This will include monitoring for VOCs, SVOCs, and all of the
inorganic contaminants identified in the 1990 ROD with ground water remedial ARARs.
Based on monitoring, if ft is determined that the air sparging/soil vapor extraction remedial
action is no longer decreasing the levels of contamination and levels of contamination
remain on-site at levels requiring active remediation, the Contingency Remedy or another
technology of equal or greater effectiveness will be implemented. Any technology other
than the Contingency Remedy will be subject to public comment.
The FFS states that ground water flow modeling indicated that the plume discharges into
the Pope and Shoal Branch wetlands rather than intercepting the potable water wells at
Dukes Bridge. However, if the ground water monitoring program reveals that the
conclusions of the FFS are incorrect and the ground water plume is migrating toward the
potable water wells at Dukes Bridge, then the Contingency Remedy or another technology
of equal or greater effectiveness will be implemented. Any technology other than the
Contingency Remedy will be subject to public comment.
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STATUTORY DETERMINATIONS
As previously noted, CERCLA §121(bXl), 42 U.S.C. §9621(bXl), mandates that a
remedial action must be protective of human health and the environment, cost effective,
and utilize permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section 121 (b)(l) also establishes a
preference for remedial actions which employ treatment to permanently and significantly
reduce the volume, toxicfty, or mobility of hazardous substances, pollutants, or
contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621 (d) further specifies that a
remedial action must attain a degree of cleanup that satisfies ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA §121(dX4), 42 U.S.C.
§9621(dX4). For the reasons discussed below, NJDEP has determined that the selected
remedy at the Woodland Township Route 72 and Route 532 sites meets the requirements of
CERCLA §121,42 U.S.C. §9621.
Protection of Human Health and the Environment
Of the two alternatives evaluated, the selected remedy for contaminated ground water
provides the greatest protection of human health and the environment. Air sparging and
soil vapor extraction will remediate the contamination in the former disposal areas faster
than ground water extraction and treatment. Human health will be protected through the
implementation of a Classification Exception Area (CEA) and a Well Restriction Area
(WRA). Security fences surrounding the former disposal areas at both sites will remain in
place until at least the completion of the air sparging-soil vapor extraction remedy at the
disposal areas.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
The selected remedy will meet all chemical-specific, action-specific, and location-specific
ARARs discussed under the "Summary of Comparative Analysis of Alternatives", above.
Cost Effectiveness
The cost effectiveness of an alternative is determined by weighing the cost against the
alternative's ability to achieve ARARs and remedial action objectives. The selected
remedy is cost effective and will cost approximately $87,600,000 less than ground water
extraction and treatment.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected technology utilizes permanent solutions and treatment technologies to the
maximum extent practicable and provides the best balance of trade-offs with respect to
the nine evaluation criteria previously discussed.
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Preference for Treatment as a Principal Element
The selected technology meets the statutory preference for treatment as a principle
element.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Woodland Township Route 72 and Route 532 sites ROD
Amendment was released for public comment on September 22, 1998. The proposed
plan identified Alternative 2 as the preferred remedy for the sites. The notice of
availability for these documents was published in the Burlington County Times on
September 22, 1998. A public comment period was held from September 22, 1998 to
October 22, 1998. NJDEP has reviewed all written comments submitted dining the
public comment period. In addition, a public meeting was held on October 8, 1998. A
response to comments raised at the public meeting and provided in writing is included in
the Responsiveness Summary, which is part of this ROD Amendment. Upon review of
the comments, NJDEP determined that no significant changes to the remedy, as h was
originally defined hi the Proposed Plan, were necessary.
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APPENDIX I
FIGURE
2.1
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.-./ .N *--J
nOUT
DISPOSAL
ROUT6 72
FORMCR
DISPOSRL
RRCfl
V-/O-O :-rV
A/ STREAM
A/PAVED ROADWAY
FORMER DISPOSAL AREAS
WETLANDS AND SURFACE WATERS
ROUTC 72 AND ROUT6 532 SUP6RFUND SITCS
UJoodlond Township, Burlington County, New Jersey
04/20/98
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APPENDIX II
TABLES
25
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Table 1
Maximum Detected Chemical Concentrations in Groundwater
Route 72 Superfund Site
Constituent
Maximum Detected
Groundwater Concentration (ug/l)
Volatiles
1,1 -Dichloroethene
1,2-Dtchloroethane
1,2-Dichloroethene (total)
1,2-Dtchloropropane
1,1,2-Trichloroethane
1.1,2,2-Tetrachloroethane
2-Butanone
4-Methyl-2-Pentanone
Acetone
Benzene
Carbon Bisulfide
Carbon TetrachlorkJe
Chlorobenzene
Chloroform
Chloromethane
Ethylbenzene
Methylene Chloride
Styrene
Tetrach loroethene
Toluene
Trichloroethene
Vinyl Chloride
Xylene
43
7,800
850
320
380
730
270
140
1,600
2,700
420
39
12,000
80
50
15,000
370
13,000
99
52,000
4,000
5
11,000
Semi-volatiles
1,2-Dichlorobenzene
1,2,4-Trichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Chlorophenol
2-Methylnaphthalene
2-Methylphenol
2-Nitroaniline
2,2-Oxybis(1-chloropropane)
2,4-Dimethylphenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
4-Methylphenol
Acenaphthene
bis(2-Chloroethyl)Ether
bis(2-Chloroisopropyl)ether
bis(2-Ethylhexyl)Phthalate
Benzyl alcohol
ButylbenzyJphthalate
Dibenzofuran
Di-n-ButyJ phthalate
Di-n-Octylphthalate
Diethylphthalate
Fluorene
1,500
74
55
220
38
140
810
28
560
1.080
40
4
2,200
10
2,000
860
480
850
51
32
93
99
160
27
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Table 1
Maximum Detected Chemical Concentrations in Groundwater -
Route 72 Superfund Site
Constituent
Naphthalene
Phenol
Phrenathrene
Metals
Aluminum
Arsenic
Cadmium (total)
Calcium (total)
Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Zinc
Maximum Detected
Groundwater Concentration (ug/1)
120
340
3
1,100
30
37
9,700
630
26
132,000
32
7,500
730
1.1
90
14,400
14,200
35,000
Maximum concentrations in groundwater samples collected and analyzed since June 1991 from permanent
monitoring wells and/or HydropunchD samples.
c/WOOOLANDS/Ma«mum D«!octed Chemical Concentrations in Groundwater - Rle 72/sls
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Table 2
Maximum Detected Chemical Concentrations in Groundwater -
Route 532 Superfund Site
Constituent
Maximum Detected
Groundwater Concentration (ug/1)
VOCs
1,1 -Dichloroethane
1,1-Dichloroethene
1,1,1-Trichloroethane
1,1,2-Trfchloroethane
1,1,2,2-Tetrachtoroethane
1,2-Dichloroethane
1,2-Dichloroethene (total)
1,2-Dichloropropane
2-Butanone
2-Hexanone
4-Methyl-2-Pentanone
Acetone
Benzene
Bromodichloromethane
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chloroform
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
Trichloroethene
Xylene
5
300
27
230
6,400
60,000
35
240
660
300
1,800
4,400
1,800
1
610
41
510
1,200
1,500
620
2,600
700
40,000
790
10,000
Semi-Volatiles
2-Methylphenol
2,4-Dimethylphenol
4-Methylphenol
bis(2-Chloroethyl)ether
bis(2-Ethylhexyl)phthalate
Benzole acid
Benzyl alcohol
Butylbenzylphthalate
Di-n-Butyl phthalate
Di-n-Octylphthalate
Dibenzofuran
Diethylphthatate
Dim ethylphthalate
Naphthalene
Phenanthrene
Phenol
1,800
14,000
3,100
200,000
77
390
2,800
2
17
4
25
85
330
40
1
14,000
Metals
Aluminum
Calcium (total)
Cadmium
Chromium
128,000
106,000
97
350
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Table 2
Maximum Detected Chemical Concentrations in Groundwater -
Route 532 Superfund Site
Constituent
Cobalt
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Maximum Detected
Groundwater Concentration (ug/l)
50
63,500
155
9,300
30,000
0.2
350
10,200
40,500
440
79,000
Maximum concentrations in groundwater samples collected and analyzed since June 1991 from permanent
monitoring wells and/or HydropunchD samples.
MF|WOOOLANDS|Maximum Detected Chemical Concentration in Grauodwatef - Rio 532|ste
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TABLES
Ground Water Remediation Goals
Constituent
.ug/i
Acenaphthene 10
Acetone 25
Aldrin 0.04
Aluminum 200
Ammonia 200
Arsenic g
Barium 200
Benzene I
Benzidine 50
Benzyl alcohol 4
Bis(2-chloroethyl)ether 10
Bis(2-chloroisopropyl)ether 10
Bis(2-ethylhexyl)phthalate 30
Bromodichloromethane 1
2-Butanone 100
Butylbenzyl phthalate 20
Cadmium 2
Carbon disulfide 5
Carbon tetrachloride 2
Chlordane 0 5
Chloride onnn
y-it-l i ZUUU
Chlorobenzene 2
Chloroform 1
Chloromethane 2
2-Chlorophenol 20
Chromium 10
Color 20 CU
Copper 1000
Cyanide 40
4-4 DDT 006
Dibenzofuran 4
1,2-Dichlorobenzene 5
1,3-Dichlorobenzene 5
1,4-Dichlorobenzene 5
1,1-Dichloroethane 2
1,2-Dichloroethane 2
1,1-Dichloroethylene 2
cis-l,2-Dichloroethylene 2
trans- 1,2-Dichloroethylene 2
1,2-Dichloropropane 1
Diethy 1 phthalate
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Constituent ug/j
2,4-Dimethyl phenol 20
Dimethyl phthalate 10
Di-n-butyl phthalate 20
Di-n-octyl phthalate 2
Endrin 0.04
Ethylbenzene 5
Fluoride 500
Fluorene 10
2-Hexanone 25
Iron 100
Isophorone 10
Lead , 10
Manganese 6
Mercury (total) 0.5
4-Methyl 2-pentanone 50
Methylene chloride 2
2-Methylnapthalene 4
2-Methylphenol 20
4-Methylphenol 20
Naphthalene 2
Nickel 10
2-Nitroaniline 3
PCBs 0.5
Phenathrene 10
Phenol 10
Selenium 10
Silver 2
Sodium 400
Styrene 5
Sulfate 5000
1,1,2,2-Tetrachloroethane 1
Tetrachloroethylene 1
Toluene 5
Total Dissolved Solids 10,000
Toxaphene 3
1,2,4-Trichlorobenzene 1
1,1,1-Trichloroethane 1
1,1,2-Trichloroethane 2
TricMoroethene 1
2,4,5-Trichlorophenol 10
2,4,6-Trichlorophenol 20
Vinyl Chloride 2
Xylenes (total) 2
Zinc 30
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Reproduced by NTIS
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