United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-86/024
June 1986
Superfund
Record  of Decision

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1
 ,;;.          TECHNICAL REPORT DATA         
      (Pletlle ,etld InllNetions on the ,evene IHfOl'e eom"letinlJ     
1. REPORT NO.       12.         3. RECIPIENT'S ACCESSION NO. 
_PA/ROD/R02-86/024                     
.. TITLE AND SUBTITLE              5. REPORT DATE     
UPERFUND RECORD OF DECIS ION            .Tl1n~ ?7 19B/,; 
"lorence Landfill, NJ            e. PERFORMING ORGANIZATION CODE
7. AUTHORIS)                8. PERFORMING ORGANIZATION REPORT NO.
t. PERFORMING ORGANIZATION NAME AND ADDRESS      10. PROGRAM ELEMENT NO.  
                   11. CONTRACT/GRANT NO.  
12. SPONSORING AGENCY NAME AND ADDRESS       13. TYPE OF REPORT AND peRIOD COVERED
J. S. Environmental Protection Agency          Fin",' ROD  
01 M Street, S.W.              14. SPONSORING AGeNCY CODe 
iVashington, D. C. 20460               800/00    
15. SUPPLEMENTARY NOTES                     
16. ABSTRACT                        
 The Florence  Land Recontouring (FLR) Landfill is a 60-acre site located on Cedar i:.ane
_x te ns ion in the Tbwnships of Florence, Mansf ie Id, and Springfield in Burlington County,
~w Jersey. The site consists of a 29-acre landf ill, two lagoons, a pond and two tanks,
md is located in a combined residential-agricultural area. The site is bounded by land
)urchased by Burlington County for a new 600-acre solid waste management facility and by
Assiscunk Creek, a tributary to the De laware River which is used for recreation and 
,i.rrigation. The FLR landfill was operated as a solid waste disposal facility from late
973 to la te 1981 and was permitted to accept sanitary and non-chemical industrial 
flastes. In 1975, the New Jersey Department of Environmental Protection investigated
~hemical waste disposal at the site and disclosed that 95 tons of hazardous waste 
~onsisting of phthalates, heavy metals and vinyl chloride monomers had been illegally
Jisposed at the  site. Elevated levels of hazardous substance have been discovered in
soils and groundwater within the landf ill.             
 The selected remedial alternative includes: construction of a synthetic membrane and
~lay composite cap, a circumferential soil/bentonite slurry containment wall, an 
~pgradient grouno water interceptor system and a new stormwater management system; 
e acha te treatment and disposal at a PO'lW or the Burlington County Solid Waste Complex;
~as collection and treatment; removal and disposal of lagoon liquids and sediments, and
(See Attached Sheet)                     
17.           KEY WORDS AND DOCUMENT ANALYSIS        
a.      DESCRI PTO RS      b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
~cord of Decision                      
='lorence Landfill, NJ                    
~ntaminated Media: gw, soil, sediments              
ey contaminants: heavy metals, phthalates,             
phenols, VOCs                       
        , .. '.               
         -              
18. DISTRI8UTION STATEMENT        1t. SECURITY CLASS (T/lis Repo,,) 21. NO. OF PAGES
                  None     154
               20. SECuff,lTY CL.ASS (This pq" 22, PRICE 
              ,    None        
E18. '_2220-1 (a...- 4-77)
P".VIOUS EDITION IS OBSOLETE

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INSTRUCTIONS
1.
REPORT NUMBER
Insert .he I:.PA report number IS it IppeUS on lhe cover of Ihe public:alion.
2.
3.
LEAVE BLANK

RECIPIENTS ACCESSION NUMBER
Reserved for use by c;ach rcport rel:ipient.
4.
TITLE AND SUBTITLE
Title should indicate de;&fly and briefly the subjel:t I:overaill: 01" Ihe report. and be disl'lay~'d I'rumi,wnlly, S"I SUhl ilk, .1' us~'\I, III slII;alio:r
Iype or otherwise subordinate it 10 mlintitle: When I report is I'rep:ared in more Ih;an \,n.. v"lunl\:, r""";lt Ih" I'rim;ary 1111", ;a\1\1 v,)I:anw
number and mdude sublltle for the specific mle.

REPORT DATE
Each report shall carry I date indic:alinl at leasl monlh. and year. Indicate Ih" h;asls UII whidl il ,,,,, ...:Ic~.t"d (c',K" Jalc' (1/ isstlc', .Jlllc' (1/
IIpproNl, diltt o{ preptlf'flrion, tIC,),
5.
I.
PERFORMING ORGANIZATION COOE
Lelve blank.

AUTHORISI '
Give namets) in ':\lnvenlional order (John R, D«, J, Rolx." Dot', ,'te). List ;authur's ;atfiliiallull if it .Iith'rs fr"lIIlh~' I"'rfmlllinit ,,'ltalll'
Zltion.
7.
8.
PERFORMING ORGANIZATION REPORT NUMBER
Insen if performins organization WIshes to assipl this number.
I.
PERFORMING ORGANIZATION NAME AND ADDRESS
Give name. sueet. city. state. and ZIP code. List no more than two levels of ;an ura:;aniz;aliulI;a1 hireiu.:hy,
10. PROGRAM ELEMENT NUMBER
Use the program element number under which the report w;as prepared. Subordill;alc number' ilia)' II\: IlIdu,,,".lm I'a,,,"th,',,,s.
11. CONTRACT/GRANT NUM8ER
Insert conUact or grant number under which report w.n prepared.
12. SPONSORING AGENCY NAME AND ADDRESS
Indude ZIP code.

13. TYPE OF REPORT AND PERIOD COVERED
Indicate interim final. etr.. and if applicable. dales covered.
14. SPONSORING AGkNCY CODE
Insert appropriate code.

15. SUPPLEMENTARY NOTES
Enter information not induded elsewhere but useful, such as:
To be published in, Supersedes, Supplements. etc.
Prepillred ill .:uoper;atiun wllh, ",all,lalioli 0', I'I\:....'III~'" al ~'OIl"""I1'" of,
11. ABSTRACT
Include a brief (200 words or less) factual summary of the most sil!nilkillntlftfurmalinn ,.ulltaln,'" III II", '''1''''1. II Ih,' '''I'm 1 "I/II;IIII',j
significant bibliography or lilerature survey. mention il here,
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS ...select from Ihe Thesaurus of Engineerir.1! ;and Sc:i,,"lIlk T.:rnh the p,upcr autho"/~o I~"III' thaI locllilry th" ilia/HI
concept of the research and are sufficiently specific and pre.:ise to be useu a\ IRUCX ~ntrie~ lur ~atalol!lnl!,

(b) IDENTIFIERS AND OPEN.ENDED TERMS. Use identifiers for prole.:t n;alll~'. ':UUC lIam.:,. "4ulpmcllt \J~'ll!nators, dc:, lis<: "1'.:11'
ended terms written in descriplor form for those subjects for which no dl:s<:rlptur .:"isls.
(c) COSA TI HELD GROUp. Held and Jlfoup illSsilnmenls arc 10 be t;ak.:n hum Ihe 1965 COSh'll Sl.lhi~'d ('at~'l!ory Ust, Sin.:\' Ihl: 111;1'
jority of documents are multidisciplinary in nalure. Ihe Prim:ary Held/Group ;as,ignmcIIU, I will b.: 'p~'\lII~' UI" Iphn.:. .IIl"a of hUlllan
endeavor. or type of physical object. The applicationts) will be crun.re"cn:n.:ed with SI:\'ullllary I "'hilI ;'ClUI' a"II!"II"'lIh Ihal \\'111 1'011,,\\
the primary posungts).

18. DISTRIBUTION STATEMENT
Denote releasabilit)' 10 the publi.: or linlllalion for rea,ons uther Ihilln ,.:\:urtly fur .:"amrlc "R~lca'\: LIIIIIIIIll"I," (,I" allY a';lil;,I>,hl)' I..
the public, with address ;and pflC:C,
19..20. SECURITY CLASSIFICATION
DO NOT submit classified reports 10 Ihe Nalional Te.:hnic;allnformatiun s<:rvice.
21, NUMBER OF PAGES
Insert Ihe lotal n~ber of pages. inchlding!,his OQC aDd unnumbered page'. bUI eJl;~lud.: di,trlbuliun h,t, 1/ any.

22. PRICE .
Insert Ihe price set by Ihe National [echaW:ailnformaUoD S':fV\l:C ur I hI: Govl:rnmcnl PrintJng om.:c, II knuwn,
E PA for", 2220-1 (Rn. .-77) CR...,..)

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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
'.
Site
-
Florence Land Recontouring (FLR) Landfill, Florence,
Mansfield, and Springfield, New Jersey
Documents Reviewed
I am basing my decision on the following documents describing
the analysis of cost-effectiveness of remedial alternatives for
the FLR Landfill site:
- Remedial Investigation/Feasibility Study for the FLR Landfill,
Black & Veatch Engineers-Architects, May 1986:
- Staff summaries and recommendations:
- Responsiveness Summary, June 1986.
Description of Selected Remedy
- Construction of a synthetic membrane and clay compesite cap:
.
- Construction of a circumferential soil/bentonite slurry
containment wall:
- Construction 'of an upgradient ground-water interceptor system:
- Construction of a new stormwater management system:
- Leachate treatment and disposal at a POTW or the Burlington
County Solid Waste Management Facilities Complex:
- Gas collection and treatment:
- Removal and 'disposal of lagoon liquids and sediments, and
other surface debris:
- Construction of a partial fence with warning signs:
- supplemental sampling of ground water, surface water and
sediments during design.

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Declarations
'.
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 and the National Oil
and Hazardous Substances Contingency Plan, 40 CFR Part 300, and
pursuant to EPA Delegation Manual Order 14-5, I have determined
that the remedy described above is the cost-effective remedial
action alternative for the FLR Landfill site.
It is hereby determined that implementation of this remedial
action is the lowest cost alternative that is technologically
feasibre and reliable, and which effectively mitigates and
°minimizes damages to and provides adequate protection of public
health, welfare and the environment. It is also hereby determined
that the selected remedy is appropriate when balanced against
the availability of Trust Fund monies for use at other sites.

The State of New Jersey has been consulted and agrees with the
selected remedy.
. ... - ..
'_0
J '-'IVI. Z, 7 . (1ft
,
Christopher J. Da .ett
Regional Administrator
Date
-0
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FLORENCE LAND RECONTOURING LANDFILL SITE
TABLE OF CONTENTS
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  PAGE
 -
  1
  1
  6
  11
  11
  11
  15
. '" - -' 19
. ,
  21
  23
  26
  28
  28
  30
  31
  32
  35
  35
SITE LOCATION AND DESCRIPTION
SITE HISTORY
CURRENT SITE STATUS
ENFORCEMENT
ALTERNATIVES EVALUATION
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Alternative 5
Alternative 6
Alternative 7
Discussion
COMMUNITY RELATIONS
CONSI~ENCY WITH OTHER ENVIRONMENTAL LAWS
AND REQUIREMENTS
RECOMMENDED ALTERNATIVE
OPERATION AND MAINTENANCE
SCHEDULE
ATTACHMENTS
...-.,:" ~"...<"e ~~.'
.f:
I.. Analytical Data
2 ~. .Responsiveness S,umma.r:y..

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LIST OF FIGURES
FIGURE
1. Site Location Map
2. Site Location Map
3. General Site Plan
4. Domestic Well Sampling Locations
S. Investigation Sampling Points
6. Partial Fencing Locations
7. Alternative 2
8. Alternative 3
9. Alternative 4
10. Alternative 5
11. Potentiometric Surface and Transmissivity
Hap of Overburden Aquifer
12. Alternative 6
13. Alternative 7
LIST OF TABLES
TABLE
1. Description of Remedial Alternatives
2. Cost Summary for Remedial Alternatives
3. Detailed Costs of Recommended Alternative
ii
P.AGE
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2
3
5
7
8
16
17
20
22
2A ,~.
. 25
27
29
PAGE
12
14

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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FLORENCE LAND RECONTOURING LANDFILL
FLORENCE, MANSFIELD, AND SPRINGFIELD, NEW JERSEY
SITE LOCATION AND DESCRIPTION
'.
The Florence Land Recontouring (FLR) Landfill is located on
Cedar Lane Extension in the Townships of Florence, Mansfield,
and Springfield in Burlington County, New Jersey (see Figure 1).
The site is situated between the New Jersey Turnpike and 1-295,
one mile south of Interchange 52 on 1-295 (see Figure 2). More
specifically, the landfill property is delineated as Block 173,
Lots 1, 2, 3A and 3B in Florence: Block 44, Lot 7 and Block
44A, ~ot 8 in Mansfield: and Block 304, Lot 1 in Springfield.
These parcels of land cover an area of about 60 acres. The
site includes a 29-acre landfill, two leachate collection
lagoons, a pond believed to have been formed by excavation of
soils, which were used as landfill cover material, and two empty
tanks.
The area surrounding FLR is predominantly residential and
agricultural. Adjacent to most of the site perimeter are lanes
recently acquired by Burlington County for the implementation
of a new 600-acre solid waste management facility. . ~~~ remaining
site boundaries are formed by the Assiscunk Creek. '-The creek
flows in a southerly direction, is a tributary to the Deleware
.River and is used for both noncontact recreational purposes and
for irrigation. .
The FLR Landfill lies above the Raritan-Magothy Aquifer, a major
source of drinking water for the area. The Raritan-Magothy
Formation comprises about 150 feet of interbedded sands, silts and
clays. separating the landfill from this aquifer is 50 to 70 feet
of Merchantville Clay. Overlying the Merchantville are Pleistocene
deposits~varying from zero to 25 feet in thickness, which consist
of sand, silt and clay. The surficial Pleistocene Aquifer is used
as a water supply, but to a lesser extent than the Raritan-Magothy.
Flow in both the Pleistocene and Raritan-Magothy is in the south-
southeast direction toward the Assiscunk Creek. Based on existing
hydraulic gradients, leachate from the landfill has the potential
to flow out of the fill into the adjacent surficial Pleistocene
Aquifer. Since ground water from the Pleistocene Aquifer discharges
into the Assiscunk Creek, the creek acts as a natural hydraulic
barrier to further contaminant transport in the ground water beyond
the creek.
SITE HISTORY
The FLR Landfill was operated as a solid waste disposal facility
, from November 1973 until November 1981. Florence Land Development,
a partnership, owned the site from April 1974 to May 1978. Since

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FLORENCE'
LAND RECONTOURING
LANDFILL SITE
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Florence Land Recontourlng Landfill

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Florence Land Recontourlng Landfill
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then, Florence Land Development, Inc. has owned the site. During
all of its operating period except for 1977, the laadfill was
operated by Florence Land Recontouring (FLR), Inc. In 1977, the
site was operated by Jersey Environmental Management Services
(JEMS) .
During its operation, the landfill was permitted to accept
sanitary and industrial (non-chemical) waste, including septage
and sewage sludge. In 1975, an investigation by the New Jersey
Department of Environmental Protection (NJDEP) disclosed chemical
waste disposal at the landfill. Due to a history of environmental
concerns, including observed leachate seeps, potential ground-
. water contamination and emissions to the atmosphere, a Consent
Order to alleviate and control further contamination was issued
by the New Jersey Superior Court in January 1979. Elements of
this order included a listing of permitted and prohibited waste
types for acceptance at the facilitY1 establishment of a sampling
and analysis program for existing ground-water monitoring wells:
specifications for site preparation, disposal limits, and' -
operations: design and installation of a leachate coll~ctibn
system1 pumping and removal of leachate to alleviate hydraulic
head pressures: the construction of cutoff walls, dtke8~ and
wastefill gas vents1 provisions. for the control of litter, dust,
odor, noise and fire protection, and the establishment of the
final elevation and depth of excavation. Leachate removed from
the landfill is being discharged to the Willingboro Wastewater
Treatment Plant under NJPDES/SIU Permit INJ0029289. Compliance
with the Consent Order has been sporadic. Quarterly responses to
the order have been prepared by FLR's consultant, M. Disko
Associates, since its issuance in January 1979.

In July 1981, FLR, Inc. submitted a final landfill closure plan,
and operations terminated in November 1981. Following this
closure plan, the wastefill area was capped with on-site clayey
material reported to be Merchantville Clay and subsequently
revegetated. 'The extent and level of accuracy to which landfill
construction, operations, and closure were performed as represented
by design drawings and reports are unknown. A general site plan
Is presented In Figure 3.
The quarterly reports prepared by FLR's consultants have demon-
strated inadequate leachate removal. Due to the lack of compliance
with the Consent Order, NJDEP brought FLR to court in August 1985.
At that time,FLR was directed to remove 350,000 gallons per'
month from the manholes of the leachate collection system.
Reports filed with.,the NJDEP by industrial generators indicated
that 95 tons of hazardous waste were disposed at the FLR Landfill
site. These wastes reportedly contained phthalates, heavy metals"
and. ,v.inyl,.cblo~J.cle...monomers.
'...' .

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SITE PLAN
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Florence land Recontouring landfill

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CURRENT SITE STATUS
. '.
Residents in the general area of the site have been complaining
of private potable well contamination, which they believe
originates from FLR, for several years. In 1985, NJDEP Division
of Water Resources found petroleum hydrocarbon contamination in
the supply of the Columbus Water Company, which is located in
Mansfield Township. NJDEP concluded that the petroleum hydro-
carbons detected in water samples originated from within the
water company's system. The system was subsequently cleaned to
eliminate the water problem. In response to complaints by
Mansfield Township residents of potable well contamination, EPA
sampled thirteen potable wells both upgradient and downgradient
of the site including the Columbus Water Company in August 1985.
One chemical compound, bis(2-ethylhexyl) phthalate, was detected
in the samples, as well as in the laboratory blank prepared for
data validation purposes. EPA concluded that the presence of
this chemical in the blank indicated that it was introduced in-
the labora tory.
Samples were collected from twenty domestic water-supply wells
installed in both the shallow .Pleistocene and deep Raritan-Magothy
Aquifers and located hydraulically upgradient and downgradient of
the site as part of the remedial investigation. The locations of
these wells are provided on Figure 4. Methylene chloride and
bis(2-ethylhexyl) phthalate were the only volatile and base
neutral compounds found in twelve of the twenty samples. These
compounds were found at low levels, none of which exceeded 23
ppb. Their presence may be due to laboratory contamination since
these particular compounds are frequently laboratory introduced
during analysis. Additional sampling and analysis would be
required to make a more definite conclusion. It should be noted
that the levels found are significantly lower than EPA drinking
water ;crlteria. Domestic well water data are summarized on
Table;l in Attachment 1.
Elevated levels of hazardous substances were detected 1n the
landfill material and 1n ground water from monitoring wells
within the landfill. Leachate samples from the existing leachate
collection system manholes contain much lower levels of contaminants
than the ground water from the wells within the landfill. However,
these samples are not as indicative of the leachate generated by
the waste as samples from the landfill wells. This conclusion is
based on the concept that ground water migrates along the pat'h of
least resistance, through the collection system where it dilutes
the leachate, rather than. flowing directly through the landfill
materials. The locations of all sampling points are provided on "
Figure 5. Analyses of leachate collected from the manholes is
presented on ~able 2 in Attachment 1.
-:.
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Florence land Recontouring landfill
Figure 4
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INVESTIGATION SAMPLING POINTS
I .

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The landfill ia aituated in the aurficial Pleietocene Formation.
Organic compounde were detected in water aamplea from monitoring
wells inatalled around the aite in the thia aquifer. well 45,
located hydrsulically upgradient of the landfill bU~ locally
downgradient of the leachate lagoona. contained 10.46 ppb of total
organiC compounda. Wells 55 and 65. located downgradient of the
landfill, contained 231.61 ppb and 3.15 ppb of total organic
compounds.
Interpretation of analytical reaults of water samplea from wells
in the Raritan-Magothy Aquifer indicate that the water quality
upgradient and downgradient of the site is equivalent. which leads
to the conclusion that water quality in thia aquifer haa not been
impacted by the aite. Thia concluaion ia aupported by the
following. permeability in the 50 to 70 feet of Merchantville
clay was determined to be between 10-5 centimetera per aecond
(cm/aec) and 10-7 cm/aec and pump teata performed on the Rarit~n-
MagothY indicated nO hydraulic connection between this aquifer
and the pleiatocene Aquifer in which the landfill ia located. '
Data collected indicates that there ia no off-aite plume. The
presence of random contaminanta detected in Raritan-Magot\y aamplea.
such as methylene chloride and bis(2-ethylheXyl) phthalate, wilr
be addreaaed further in future aampling. Ground-water data ia
presented on Table 3 of Attachment 1. :- ,..

Migration of contamination ia further evidenced by the collected
aoil data. Levela of methylene chloride aa high'aS 938 ppb were
found within the landfill and were subaequently detected in
downgradient boringa at 172 ppb and 419 ppb. Theae levela far
exceed the NJDEP guideline that methylene chloride be five times
greater than the concentrationa found in the blank to be considered
an environmental contaminant. In addition, heavy metal analyaea
from aoil borings outaide the landfill indicate concentrations
similar to, and greater than in the landfill samples, which further
supports that some migration from the landfill is occurring. The
highest metal concentrations were found in the Merchantville
clay. This' can be attributed to properties of clay which enable
it to capture metals via an ion exchange mechanism. Soils data
are summarized in Table 4 of Attachment 1.
Ground water downgradient of the site in the surfical aquifer
flows into the ASsiscunk Creek. pentachlorophenol and phenol
were detected in the surface-water and aediment samples from the
creek. Their presence does indicate the impact of the landfill
on the pleistoCene Aquifer. surfsce-water and sediment data are
summarized on Tables 5 and 6 in Attachment 1.
Air sampling performed at FLR uaing the flame ionization detector
(FID) and photoiOnizatiOn detector (PID) ahowed elevated levels
, of volatile organic compounds at the site. The highest concen-
trations mea~red,were found sbove manholes and monitoring wella.
Backgrollnd levelaWere"detected at the site t;>oundariee.' In
add i tion to the PID and 'nD : s.mpUng ,,-carbOs" ed.or,pt ion, tubes
, ..

-------
----~-~_._._--_._-._._-~ _. - --~
<)
-10-
were used to identify specific compounds present 1~ the air
emissions. Although the recommended holding times were exceeded,
benzene and toluene were detected in the air samples. An air
model was used to estimate the concentration of volatiles at the
nearest off-site residence, which was calculated to be 0.453 ppm.
Assuming that this were entirely benzene or entirely toluene,
this value 1s insignificant in relation to potential health
impacts. Since emissions were not detected at the site boundaries
and were not calculated to be of significant levels at the nearest
residence, 1t can be concluded that off-site air emissions from
FLR do not pose a public health threat.

Public health concerns at the FLR Landfill site in its current
condition are summarized below.
.The ground water in the landfill 1s contaminated and there is a
potential for migration into the adjacent Pleistocene Aquifer and
the lower Raritan-Magothy Aquifer. There are a limited numbe~
of homes with potable wells in the Pleistocene Aquifer downgradrent .
of the site due to the short distance between the landfill and
. . .....
the Assiscunk Creek, which acts as a hydraulic barr4er to ground-
water transport. These homes. are being purchased by Burlington
County, which will leave no potable wells immediately downgradient
of the site in this aquifer. Contaminated ground water from the
site is expected to reach the drinking water supplies in the
Raritan-Magothy in a minimum of twenty-four years if no remedial
action is implemented. There are approximately 500 persons
within a three-mile radius downgradient of the site with potable
wells in the Raritan-Magothy.
.The Assiscunk Creek has shown minimal impacts from the FLR
Landfill. However, there is a potential for contaminants to
migrate~to the creek via surface-water runoff and ground-water
flow jn the surifical Pleistocene Aquifer. The creek is used
for recreation and irrigation purposes and is considered an
exposure pathway through dermal contact and ingestion.
.The air investigation has not shown the air emissions from FLR
to pose a health threat off-site. The concentrations of total
volatile organics found on-site are at levels high enough to
pose a health threat depending on the specific chemicafs present.
The remedial investigation, however, did not detect particular
chemicals at the concentrations of total volatile organics,
measured. Air emissions are an exposure pathway through inhalation.

.Hazardous substances found in the landfill may be present at the
ground surface on-site and may present an exposure pathway through
dermal contact..,
,";":', ,. )

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-11-
'.
ENFORCEMENT
An investigation to identify potentially responsible
(PRPs) is in progress for purposes of potential cost
and enforcement actions in regard to future costs of
activities. parties identified as PRPs will be sent
letters offering them the opportunity to perform the
construction activities recommended in this document
and NJDEP make a decision to fund any future work.
parties
recovery
remedial
notice
design and
before EPA
ALTERNA~IVES EVALUATION
The feasibility study process involves, as a first step, selecting
technologies that are appropriate for remedying the public
health and environmental concerns associated with a particular
site. In the case of FLR, the remedial objective is to control.
the potential release o( contaminants from the landfill. Based
on the general exposure pathways, more specific objectives were
established: -
- Mitigate downgradient, off-site ground-wate~ contamination
- Mitigate on-site surface-water runoff contamlnation
- Mitigate off-site air contamination
- Mitigate the potential for health hazard exposure and
enhance on-site safety
The remedial measures evaluated were designed to alleviate the
potential public health riake and environmental impacts associated
with the landfill wastes.
considering available technologies and the site's existing physical
conditions, several remedial alternatives were developed and are
listed in Table 1. capital costs, operation and maintenance c~sts,
and tqtai present worth costs for the alternatives are provided
in Table 2. 'present worth costs for all alternatives were calculated
using a thirty year life cycle as a basis for comparison of these
costs. A more detailed description of the technology screening
and remedial alternative development can be found in Volume 3 of
the Remedial Investigation/Feasibility Study dated May 1986. The
remedial alternative descriptions that follow identify each
action, present the effectiveness and cost of the action, and
address the alternative's consistency with other environmental
lawe. Consistency with other environmental laws is described
more completely in a latter section of this document.

..Alternative 1 - No Action
',"... :"
<;, ,
Under the No Action alternative, all current leachate handling
activities would be. abandoned. Monitoring of air, ground wa.ter,
and. su~face.wat.r8,.:...nd periodic si te.inspections would continue
as operation and 8Iaintenanee'e' ,'.'" , . ',' ," ' .,' . '

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- --- --"'--'---"'-'-"-""-'- -
-12-
TABLE 1
'.
DESCRIPTION OF REMEDIAL ALTERNATIVES
Alternative I - No Action
- Termination of leachate pumping and removal
Alternative 2
- Maintenance of current volumes of leachate pumping and removal
- Leachate treatment and disposal at an off-site POTW
- Temporary leachate storage in an on-site tank prior to
transport to POTW
Replacement of carbon filters above manholes
- Repairs to existing cap and stormwater management system
Alternative 3
- Circumferential barrier wall with upgradient grou~d'vater
interceptor and diversion tr.nch
- RCRA compliant composite cap
Leachate removal using present leachate collection system
- Temporary leachate storage in an on-site tank prior to
transport to an off-site POTW or BCSWMFC
- Passive gas collection system with activated carbon treatment
- New stormwater management system
Alternative 4
- New synthetic membrane cap and stormwater management system
- Extraction wells augmenting present leachate collection system
- Dire.ct#leachate discharge to BCSWMFC for treatment
- Act~ve gas collection and direct discharge to BCSWMFC for
incineration
Alternatives 5, 6, and 7
- Partial upgradient barrier wall with upgradient ground-water
interceptor and diversion trench
- New synthetic membrane cap and stormwater management system
- Extraction wells augmenting present leachate collection system
- Active gas collection
Treatment Options

Alt.rn~tiv8 5 - Leachate and gas treatment at BCSWMFC
Alternat1ve:6"--.On-s1te leachate pretreatment1 temporary .
storage. 1n on-site tank and truck.transport,
to POTW: on-site'" 98s'1neiner8t1on" .' . .

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L..
-13-
Treatment Options (continued)
'.
Alternative 7 - On-site leachate treatment and discharge to
Assiscunk Creek: on-site gas incineration

Actions Common To All Alternatives
- Partial fence installation
- Long-term air and water-quality monitoring
Actions Common To Alternatives 2 through 7

- Lagoon removal
- Debris removal
- Archeological investigations
-
,
~d
, '
.'
.'
. '. - ~

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'J
-14-
TABLE 2
'.
CAPITAL COSTS, OPERATION AND MAINTENANCE
COSTS, AND PRESENT WORTH COSTS
1
 Annual 
Capital Operation & Present
Cost f-Jaintenance Worth
($) ($) ( $ )
62,000 48,000 453,000
469,000 394,000 4,172,000
7,937,000 169,000 9,208,000
4,492,000 312,000 7,262,000
4,751,000 235,000 6, 7~0'iooo
5,335,000 257,000 7,616,000
5,619,000 201,000 7,402,000
Alternative
2
3
4
5
6
7
-
,

-------
-15-
. .
A partial fence with warning signs would be installed. It
would serve to restrict site access, which would reduce the
occurrences of direct contact with'any hazardous materials and
inhalation of high levels of volatile organics. The fence would
extend from the Assiscunk Creek along the northern property line
to Cedar Lane Extension and along Cedar Lane Extension and the
southern fill area back to the creek (see Figure 6).

It is estimated that approximately 21,000 gallons per day (GPD)
of leachate are currently generated by precipitation infiltration
and ground-water inflow. An average of 12,000 GPD is currently
removed by pumping performed in compliance with the NJDEP
Consent Order. In addition to the potential for migration
laterally into the pleistocene Aquifer, the unremoved leachate
could eventually create a hydrostatic pressure head sufficient
to induce leachate migration into the underlying Merchantville
Formation and ultimately encounter the Raritan-Magothy Aquifer-
The potential for surface-water runoff contamination wQuld
increase since the continued erosion of the existin~,sCil cover
would inevitably expose additional waste to surface-water runoff.
The potential for off-site air contamination would incrementally
increase over several years as the cap erodes sufficiently to
facilitate the release of landfill gas. Since the activated
carbon in the filters above the manholes is spent at present,
the presence of the filters has no effect on air quality.

In addition, the potential for on-site safety and health hazard
exposure would increase due to the cessation of leachate removal,
, which wou~d permit leachate to accumulate in the manholes, and
continued cap erosion, which would further expose waste and
potentially create additional air emissions. Although install-
ation Df a partial fence around the site would discourage
unauthorized site entry, the potential for on-site safety and
health hazard exposure on the site itself would still increase.
Alternative 2
This alternative includes repairing the existing cap, replacing
the carbon absorption filters, and maintaining the current
practice for leachate handling (see Figure 7). On-site material
would be used to repair the eroded portion of the cap for,
mitigation of surface-water runoff contamination. The existing
,drainage pipes and slope downpipes would be refurbished, and new
dikes. and flumes would be constructed to improve on-site drainage
patterns. All areas disturbed by this acti v'i ty would be revege-
,tated. Air contamination would be addressed by replacing the
existing carbon ,filters, on the manholes with new carbon filters
on 8 cont~nu'inq.,:ba8is.,..' The. existing leachate: collection system ".
would be utilized for collection' frolll'existing 'manholes' for, ,.'
".,;'" .

-------
-
-
~-
-
,
Cedar Lene Exten810n

J
\:
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:r . ,~~~:ff.:i:~~i~~~i}~~t:~i~$~~~~fiti .
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LEGEND
-)(-)0(- PIa,'" F8ndng -
. . Cedar La... E.18.8I...,
:
LandOn Prop.rty
Bound."
SITE SECURITY: PARTIAL FENCING LOCATIONS
~ & Vl!:dt.t..1 ,
fngir ",chitect.
FLORENCE LAND RECONTOURING LANDFILL
figure
6

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~~~ ~ .--1 -':::;.';$::7/ ...... I '.j£:-d j~" ! I '''. . !-.-/
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" .,' 'N.~~->< /((t~ rl~>' ]} .~ '\ t -I ~II I~~~ ... ;::':;~~~

~;...:"~.~' Florence Land Recontouring Land~iIIl ALTERNATIVE I I Figure7 .
.
......
.....
I

-------
----- ..----------------- ---- ------- -----
,,)
-18-
transfer by truck to a publicly-owned treatment works (POTW)
for treatment and disposal. The existing lagoons would be
abandoned and a new 75,000 gallon leachate storage facility
would be constructed for temporary' storage. Reduction of the
health and safety exposure would be achieved by removing the
lagoons, on-site trailer, and miscellaneous debris for disposal
at appropriate facilitles. The fence would be installed as
described in Alternative 1. Long-term air and water quality
monitoring programs would be implemented for determination of
the'ef~ectiveness of the improvements.

Under this alternative, the potential for ground-water, surface-
water and air contamination is expected to be mitigated slightly
due in part to the repair of the cover system and the replacement
of the activated carbon filters on the manholes. In addition,
continued removal of the leachate from the existing collection
system, which would be cleaned and rehabilitated to increase
pumping efficiency, would assist in minimizing any vertical and
lateral migration of leachate. It should be noted that the
repair of the cover system would only function to ret~~d, not
prevent precipitation infiltration. .,
It is estimated that approximately 21,000 GPD of leachate will
be generated by precipitation infiltration and ground-water
inflow into the wastefill. 12,000 GPD will be removed by the
upgraded collection system, resulting in a net volume of 9,000
GPD of leachate to accumulate in the wastefill. While this
alternative does provide for the capture of a portion of the
potentially contaminated leachate, it does not prevent the
migration of leachate downgradient of the site.
The potential for surface-water runoff contamination would
decrease slightly as a result of repair of the existing cover
system~ However, discontinuities in the cap would be created by
weathecing, and erosion would occur at different rates in the'
cap even with periodic maintenance. Such irregular weathering
would continue to create a potential for the contamination of
surface-water runoff and infiltration.
The potential for off-site air contamination would be mitigated
slightly as a result of the cap repair, which would promote the
venting of emissions through the carbon filters. However, the
carbon filters are not expected to treat the trace elements in
landfill gas which cause odors: therefore, the nuisance potential
of the emissions would not be mitigated. In addition, the
potential for on-aite aafety and health hazard. exposure would
be mitigated by the installation of a partial fence around a
portion of the site, the decommissioning of the_lag~ons, the
repair of the cover system; and the replacement of the carbon
in the. manhole.; fil.ters. ,Both the cap. repair.,'and~ the .carbon". '
filters are remedial measureswhich-wouldrequir..-period1c '
maintenance and replacement in order to be effective.

-------
-19-
Alternative 3
'./
Alternative 3 is designed to minimize the volume. of leachate
. produced by containing the waste (see Figure 8). A circumfer-
ential barrier wall would be constructed around the landfill
from the ground surface into the Herchantville Clay. A relatively
impermeable cover system compliant with Resource Conservation and
Recovery Act (RCRA) requirements would be placed over the entire
landfill. This cover consists of the following material layers
in ascending elevation: one foot of coarse drainage material with
a permeability less than 10-3 cm/sec containing a polyethylene
pipe collection system for the controlled discharge of collected
gases: two feet of compacted clay with a permeability coefficient
less than 10-7 cm/sec: a sJnthetic membrane: one foot of coarse
drainage material with 10- cm/sec permeability: filter fabric:
and two feet of vegetative cover consisting of on-site soils.
The unsuitably steep slopes along the eastern side of the landfill
would be regraded to a slope no greater than two horizontal to
one vertical (2:1). To aid in the control of ground-water
migration, a ground-water interceptor system would be installe~
immediately upgradient of the cutoff wall. This sys.tem would
serve to reduce the hydrostatic head on the barri.r,~all and
enhance the reliability of the containment system~ It would
consist of perforated, heavy~duty tubing centered within crushed
atone backfill. The piping would be connected to non-perforated
conveyance piping for transmission around the northeastern
perimeter of the site to a discharge near Assiscunk Creek. The
leachate management system specified for Alternative 2 would be
incorporated into this alternative. The amount of leachate
generated and recovered would be significantly less so the
leachate storage structure would have a 10,000-gallon capacity.
The leachate would be periodically removed and discharged to a
POTW or the BCSWMFC. The gases generated would migrate upward to
the coarse cover layer and be directed by pipes to two atmospheric
vents at the crown of the landfill. The gas would pass through
activated carbon filters over each vent before being released to
the ~tmosphere. A new stormwater management system would consist
of seven riprap channels extending down the side slopes and an
intercepting stormwater runoff conveyance channel over the cover
in the northeastern sector of the landfill. Installation of a
partial fence, removal of the lagoons, the on-site trailer and
miscellaneous debris, as well as air and water quality monitoring
would occur as in Alternative 2.
.
-,
The installation of a circumferential wall, an upgradient ground-
water interceptor, and a composite synthetic membrane/clay cover
system would divert upgradient 9round-water flow around the
landfill, greatly reduce infiltration, and prevent the contact of
surface-water runoff with the waste. They would serve to prevent
the migration of leachate out of the landfill and the contamination ~ "
of surface-water runoff. 'The full containmentw.ll is supplemented'
"by the 'RCRA cOlDpliant-c:ap,'-~c~~se th~,objective ',of..t.his: eystem;.i.a ",'
"

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~,~.1-" Florence Land Recontouring Landfill ALTERNATIVE S IFi'qure 8.
-)
I
N
o
I

-------
-21-
. .
to minimize leachate production and this type of cap will provide
the greatest assurance for preventing infiltration. It is .
estimated that the total volume of ground water and precipitation
which infiltrates the wastefill would be 100 GPD. To arrive at
this estimate, assumptions of neglible inflow through the barrier
wall and less than 100 GPD through the cap based on a permeability
of 10-11 cm/sec were used. A conservative volume of approximately
5,000 gallons per month of water infiltrating the landfill has been
utilized for operation and maintenance cost estimation purposes.
This infiltration would be removed by pumping from the cleaned and -
rehabilitated leachate collection system for subsequent disposal at
a POTW or the Burlington County Solid Waste Management Facilities
complex (BCSWMFC).
The potential for air contamination is expected to be moderately
mitigated by the installation of a synthetic membrane/clay cover
system and coarse drain'age blanket vent layer which would channel
landfill gas to the manholes for venting through the replaced
ca~bon filters. As discussed for Alternative 2, the a,ctivated
carbon will not treat trace elements, such as hydrocj.ei'r'sulfide, 1n
the landfill gas~ therefore, the trace element odors will not be
mitigated. Alternative 3 is expected to mitigate on-site safety
and health hazards to a greater degree than Alternative 2 because
of the superior cover system which would be installed.
Alternative 4
A new synthetic membrane cap would be constructed over the landfill
to minimize infiltration and contamination of surface water runoff
(see Figure 9). The cap would be constructed in the areas with
slopes flatter than 3:1 of the following material layers in
ascending elevation: one foot coarse drainage material with a
permeapility greater than 10-3 cm/sec: filter fabric~ six inches
of compacted on-site soils: a synthetic membrane: and two feet
of vegetative cover. In the areas steeper than 3:1, a modified
cap would be constructed. The cap would consist of the following
material layers in ascending elevation: one foot coarse drainage
material with a permeability less than 10-3 cm/sec and two feet
of vegetative cover. A new system of surface-water controls,
consisting of interceptor dikes, flumes and drainage pipes would
be installed. Five extraction wells on the downgradient side of
the site would augment the existing leachate collection system.
Leachate would be directly discharged to the proposed BCSWMFC for
treatment and disposal. An active gas extraction system consisting
., of a blower systea that would withdraw directly from the headspace
of the extraction wells, existing manholes, and from the perforated'
collection header of a new blanket layer to be placed over the
. ".landfill. The blower .syatem would discharge' directly to "the
BCSWMPC.~fortr.atlt.nt" of:- the gases. Installation ,of the.; fence',
. removal of the lagoona,'on-aite; trailer'a.nd miscella1leous-'debris,
and long-term Itonitoring would occur as in Alternative 2.
0. "::r' ..",

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-23-
Under Alternative 4, the potential for ground-water. contamination
would be moderately mitigated and the potential for surface-water
and air contamination, and on-site safety and health hazard
exposure would be significantly mitigated. The installation of
a synthetic membrane cover system would prevent surface-water
runoff contamination and minimize precipitation infiltration.
However, upgradient ground-water infiltration into the wastefill
would still create leachate, which would be extracted and trans-
ported to the BCSWMFC -for treatment. It is estimated that approx-
imately 10,000 gallons per day of leachate will be generated and
this entire amount will be extracted from the manholes and new
extraction wells. As with Alternative 2, while Alternative 4
provides for the capture of the potentially contaminated leachate,
it does not prevent the potential for degradation of upgradient
ground waters in the pleistocene Aquifer that infiltrate the
landfill.
The new synthetic membrane cover system would prevent surface--
water runoff contamination and significantly reduce pr~cipitation
infiltration. While the synthetic membrane system ,S ~onsidered
to be similar in permeability to the composite synthet1c membranel
clay cover system in Alternative 3 and therefore expected to
permit only a small amount of infiltration, a clay layer is not
incorporated as a back-up in the event of membrane breach.
Consequently, this alternative is considered less reliable.
The synthetic membrane cover system, coupled with an active gas
extraction system, would significantly mitigate the potential
for air contamination, including odors, at the site. The
active gas extraction system would also promote more complete
removal of the gas than a passive system.

The potential for on-site safety and health hazard exposure
would be~virtually eliminated by the partial fence and cover
syste. insta~lation, lagoon decommissioning, and active gas and
leachate extraction with off-site treatment. In addition, the.
implementation of a long-term air and water-quality monitoring
program will assist in the future evaluation of the site.
Alternative 5
Alternative 5 is similar to Alternative 4 with the addition of
a partial wall and a ground-water interceptor system along the
upgradient side of the landfill (see Figure 10). The cutoff.
wall would divert ground-water flow around the landfill, which
would decrease the volume of leachate generated. From analysis
of the potentiometric surface map (see Figure. 11), the required
limits for the partial wall were determined to extend from
approximately the aite entrance at Cedar Lane. Extension to the
area of.. the exi.sting .leachate lagoons. This.wall would be
installed . at'. the toe of: ~h.,.landfill,..ber.8' and~estend. from existing
grade elevation to a ~inimum of three feet into .the underlying
Merchantville Clayla~.r.:
., -

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~~ oh Florence Land Recontouring landfill ALTERNATIVE 5 "i'>ure 10
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'\1 1 ~...".' . --.-" ..~ .......""''' POTE I". SURFACE AND Y '\, ,,'
=.~.. Florence Land Recontourmg Landftll'TRANSMISSIVITY MAP OF OVERBURDEN AQUIFER "iaure 11
------..
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-26-
The potential for ground-water, surface-water, an~.air contamin-
ation, and on-site safety and health hazard exposure would be
significantly mitigated under this alternative. The installation
of a partial slurry wall and upgradient ground-water interceptor
would prevent and divert upgradient ground-water flow from the
Pleistocene Aquifer away from the landfill. In addition, the
installation of a synthetic membrane cover system would prevent
surface-water runoff contamination and minimize precipitation
infiltration into the landfill. It is estimated that approximately
2,000 GPD of leachate will be generated, and 1,000 GPD of ground-
water flow will be induced, for a total extraction volume of
3,000 GPD. Hater will be extracted from the existing manholes
and new leachate extraction wells for treatment at the BCSWMFC.
In relative terms, the partial barrier wall will be somewhat less
effective than the complete slurry wall in mi~imizing ground-water
inflow and contamination, but significantly more effective than
having no barrier wall. The effectiveness of the synthetic membrane
Cover system and the active gas extraction system is t.he same as-
described for Alternative 4. In addition, tbe pote~t~~l for on-site
safety and health hazard exposure and the effect of'~ long-term
monitoring program is also as ~escribed in Alternative 4.

Alternative 6
Alternative 6 is similar to Alternative 5 with the addition of
on-site leachate pretreatment and disposal at a paTH and on-site
gas incineration rather than treatment at the Burlington County
facility (see Figure 12). The leachate would be pretreated by an
anaerobic biological process followed by transfer by truck to a
paTH. The pretreatment would reduce the chemical oxygen demand
(COD), which is a consideration for discharge to a POTW. The
estimated pretreatment system design parameters would include a
3,000~PD flow rate with influent COD of 6000 to 8000 milligrams/
1 iter; (mg/l) 'and an effluent COD less than 1000 mg/l. The sludges
and solids from the process would be disposed off-site in an
approved RCRA facility or State licensed industrial landfill,
depending upon the characteristics of the sludge.

The potential for ground-water, surface-water, and air contamin-
ation, as well as on-site safety and health hazard exposure,
would be significantly mitigated by Alternative 6. The effective-
ness of stormwater management measures is the same as discussed
for Alternative 5. Air contamination would be controlled by an
active gas collection and incineration system. Although emissions
would be created by the gas combustion, these. are not expected
to be significant or create any ~uisance potential.
"'''','

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~,~ d\ Florence Land Recontouring Landfilll ALTERNATIVE 6 IFigure 1'2
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-28-
Ground-water contamination would be controlled by a. partial
barrier wall and synthetic membrane cover system, as discussed
for Alternative 5, with leachate extraction and on-site pretreatment,
followed by final effluent disposal at a POTH. The pretreatment
facility is expected to treat the leachate to the level necessary
for acceptance at a POTW, assuming that unexpected or abnormal
changes do not occur over time in the leachate composition.
The potential for on-site safety and health hazard exposure would
be mitigated by the installation of a fence and synthetic cover
system, the decommissioning of the lagoons, and active gas extrac-
tion and flaring. Potential explosion hazards could be created
by the flare units if not properly maintained. The pretreatment
facility is not expected to create safety or health hazards
since it would be stationary and enclosed. Adherence to standard
safety and operating procedures at the site should prevent
accidental mishaps.

Finally, as with Alternatives 2 through 5, the implementation of-
a long-term air and water-quality monitoring program ~ill assist
in early detection of contamination and future site;evaluation.
Alternative 7
Alternative 7 is similar to Alternative 6 with the addition of
a complete leachate treatment system which directly discharges
treated effluent to the Assiscunk Creek rather than pretreatment
followed by disposal at a POTH (see Figure 13). The treatment
process would include anaerobic filters, followed by the activated
. sludge process and solids contact basins for reduction of the
high concentrations of biological oxygen demand (BOD), COD, and
metals. The added treatment is for the purpose of reducing the
BOD to 3Q mg/l and the suspended solids to 30 mg/l. Sludges
genera~ed from the treatment plant would be transported off-site
for disposal.'
The treatment facility has been conceptualized to treat the leachate
to a degree sufficient for discharge to the Creek, based on the
projected leachate quality and effluent requirements. The possibility
exists, however, that the treatment process proposed will be unable
to effectively treat the leachate if its quality is significantly
different than expected or changes greatly over time. In addition,
it should be noted that the surface-water quality in Assiscunk
Creek will be impacted by the plant effluent. However, since the
effluent quality will meet State requirements, the impact is
expected to be minimal.
Discussion of Alternatives
The alternat1".s: de"eloped:for .FLR fu.lfill,.,thed'a~1on.l: Contingency
Plan requirement 1n that ate least oneJalternative from each of
the following groups 1s considered: the no-action alternative:

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'~, ' , J. ~ ~) I; / r'..\' (I ~, ' \ ~ ~ ~ '\ ...... .. - W'." __I '
~,~. Florence Land Recontouring Landfill ALTERNATIVE 7
Figure 1)
..
:)
,
f\.)
\0

-------
- -'-..----. "~--------
-30-
alternatives that do not attain applicable or relevant environ-
mental standards but provide significant protection to public
health, welfare and the environment: alternatives that exceed
applicable or relevant environmental standards: alternatives
that attain applicable or relevant environmental standards: and
alternatives that use ~reatment or disposal at an off-site
facility.
Alternatives 1 and 2 do not provide significant protection to
public health and the environment since they allow for the
release of ground water from the landfill. Hazardous substances
found in the landfill have the potential to migrate into the
Pleistocene Aquifer and the Assiscunk Creek under these alterna-
tives. The remaining alternatives are designed to eliminate
virtually all ground-water migration from the landfill. For
this reason, they recei~ed higher evaluations than Alternatives
1 and 2 and were more likely candidates for the recommended,
alternative.
Alternative 3 is designed to contain the waste by alJo~ing for
a minimal amount of percolation and ground-water infiltration.
An estimated 5000 gallons of leachate per month would be pumped
and treated. Alternative 4 allows for a larger volume of ground
water to infiltrate through the waste and, as a result, 10,000
GPD leachate would be pumped and treated. The partial wall in
Alternatives 5, 6 and 7 is designed to divert most of the ground
water around the landfill and reduce the amount in contact with
the waste. 3000 GPD leachate would be pumped and treated.
Alternatives 4, 5, 6 and 7, which allow for some ground water/
waste contact, have the potential to remove contaminants from the
landfill ~y wflushingw. However, the extent of flushing that
occurs. cannot be determined. Alternative 3, the full-containment
option~ is not a system which would encourage flushing due to the
limited infiltration volumes. The wastes would remain encapsulated.
The alternatives which allow for a greater production of leachate,
Alternatives 4, 5, 6 and 7, require more operation and maintenance
than the full-containment option. Full containment with leachate
collection would provide the most assurance for preventing leachate
migration downgradient because of the physical barriers associated
with it. The other alternatives all rely solely on the leach~te
collection system for migration prevention.
COMMUNITY RELATIONS~
A public meeting was. held.on June 12, 1986 t~. pr.esent the results
of the RIfFS and.; the recommended alternative. . The RI/FS reports'
were."diatributed. to. the:public..on May. 19, and::the. comment period .',
. ." . \
extended until June 23. Responses' to..l!" public comments are ,. .
included in the Responsiveness Summary in Attachment 2 of this
report.

-------
-31-
. .
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS AND REQUIREMENTS
Compliance With RCRA

The remedial alternatives developed for FLR were designed to
control the source of contamination and prevent contaminant
migration. Each alternative has the goal of preventing
infiltration from entering the landfill as well as preventing
runoff from coming in contact with exposed waste. Two types of
caps were evaluated in the Feasibility Study: a RCRA compliant
cap consisting of a synthetic membrane and a clay layer; and a
cap consisting of a synthetic membrane. The full-containment
option includes the RCRA cap because the objective of this
alternative is to produce a minimal amount of leachate and the
cap provides the greatest assurance for prohibiting infiltration.
The synthetic membrane ~ill allow virtually no infiltration
when it 1s intact. The purpose of the clay layer is to prov.ide
additional protection and reliability.
A clay layer was not included in the caps for Alter~at~ves 4,
5, 6 and 7, which provide for partial containment of the waste.
Since some ground water would continue to flow into the landfill
with these alternatives, the volumes of water passing through
any tears in the membrane would be insignificant and not warrant
the extra protection and reliability provided by a clay layer.
In order to comply with RCRA requirements, the synthetic membrane
and clay composite cap will be installed as part of the selected
remedy of the FLR Landfill site.
Compliance With the National Historic Preservation Act

A Stage rA archeological study prepared for Burlington County
state~ that there may be significant archeological sites on the
FLR L~ndfill property. These sites may be eligible for placement
on the National Register of Historic Places. The National
Historic Preservation Act states that properties with archeological
value must be addressed prior to a federal agency's approval of
an undertaking on that land. In accordance with the requirements
of this law, further archeological studies will be conducted at
FLR during the remedial design process before the remedial
action is implemented. Alternatives 2 through 7 will include
the performance of a Stage 18 archeological survey and any.
further archeological studies necessary to mitigate impacts on
significant archeological sites prior to on-site remedial.
construction.

-------
-32-
Compliance with Executive Order 11988 (Floodpl~in Management)

Approximately 30\ of the FLR Landfill property (the southern
and eastern portions of the site) lie within the 100-year flood-
plain as designated by the Federal Emergency Management Agency.
All of the remedial alternatives, except Alternative 1, will
require unavoidable encroachment on the fringe area of the
floodplain. However, none of the alternatives will result in
long-term adverse impacts to the floodplain or flooding levels.
Short-term impacts related to construction activities associated
with Alternatives 2 through 7 will be mitigated through strict
adherence to appropriate engineering specifications developed
during the remedial design process.
RECOMMENDED ALTERNATIVE
The National Oil and Hazardous Substances Pollution Contingency
Plan in 40 CFR Part 300.68(i), specifies that the lead agency -
will select 8... a cost-effective remedial alternative .which
effectively mitigates and minimizes threats to and p~~!~des
adequate protection of public health, welfare, and ~he environment...
This will require selection of'a remedy that attains or exceeds
applicable or relevant and appropriate Federal public health
and environmental requirements that have been identified for
the specific site.8 Evaluation of the remedial alternatives
leads to the conclusion that the action described below is a
cost-effective remedy at the FLR Landfill site.
The various aspects of the recommended alternative are described
. below along with the rationale for selection:
Three remedies for the cap were evaluated: the RCRA synthetic
membrane ~nd clay composite cap, a synthetic membrane cap, and
repair~of the. existing cap with on-site soils. In accordance
with the 8CERCLA Compliance With Other Environmental Statutes"
policy, a cap compliant with RCRA requirements will be constructed
at the FLR Landfill. This cap will be effective in eliminating
precipitation from infiltrating into the landfill and eliminating
contact between surface-water runoff and the waste.
Three options for prevention of ground-water inflow were evaluated:
a circumferential barrier wall: an upgradient partial barrier wall~
and no barrier wall. The estimated volumes of ground-water intrusion
through the circumferential wall i8 neglible. For the partial wall
and for no wall, the volumes are 2000 GPD and 9000 GPD, respectively.
The estimated cost of the full barrier wall 18$626,000, and the
estimated cost. of the partial wall is $172,000.

-------
-33-
Selection of a leachate disposal method is based on cost-
effectiveness for the leachate volumes generated. Various
options were identified in the alternatives. Alternative 3,
which yields a minimal leachate volume, utilizes transport by
truck to a POTW or the BCSWMFC. For Alternatives 4 and 5,
which yield larger volumes, direct discharge to the BCSWMFC was
evaluated. Alternative 6 has a volume equal to that for
Alternative 5 and utilizes on-site pretreatment followed by
transport to,a POTW for disposal. Alternative 7 has the same
volume as Alternatives 5 and 6 and utilizes on-site treatment and
discharge to the Assiscunk Creek. A comparison of the costs for
leachate treatment in Alternatives 5, 6 and 7 shows that disposal
at the BCSWMFC is the most cost-effective method.
Alternatives 3, 4 and 5 are all designed to prevent downgradient
ground-water migration. In Alternative 3, 5000 gallons of
leachate per month is generated in comparison with 10,000 GPD .
1n Alternative 4 and 3,000 GPD in Alternative 5. As a result,
Alternative 3 has a sm~ll annual leachate treatment cost of -
$5,300 compared to $109,500 and $32,900 for Alternatives 4 and
5, respectively. The circumferential wall, which is ~he cause
for the small leachate volume, bears a capital cost; e>f,' $626,000. .
The partial wall in Alternative 5 has a cost of $172,000.
Installation of the circumferential wall would result in the
'lowest 11 fe-cycle cost, because in a fini te numbe.r of years,
the higher capital cost would be off-set by the lower treatment
cost. Considering both the additional assurance gained with
the circumferential wall and the lower life-cycle cost, it is
recommended that the full wall be installed at the FLR Landfill
aite.
The recommended remedy for the FLR Landfill will consist of the
following: a RCRA synthetic membrane and clay composite cap1
new stormwa'ter management system1 circumferential barrier wal11
upgradieht ground-water interceptor system1 leachate treatment
and dfsposal .at a POTW or the BCSWMFC1 gas collection and treat~
ment1 'removal of lagoons with disposal of sediments on-site
before landfill is capped1 disposal of on-site trailer and
miscellaneous debris at an appropriate off-site landfil11 and
installation of a partial fence with warning signs. Leachate
treatability studies will be conducted during design. The costs
for this alternative are summarized in Table 3.
In addition, supplemental sampling will be conducted during
design of the selected remedy. . The reason for this action i$
twofold: significant outstanding concerns expressed by citizens
regarding potable vater quality at the June 12, 1986 public
meeting and development of a more comprehensive data base of
existing off-site ground-water quality prior to the installation
of the BCSWMFC. This program vill include sampling groundwater
from,'the, ,existing"monitor1ngwells, new moni,toring wells, if . .
nec"ssary," and area potable -'wells.';;' Surface':vater:, 'and:sediment.
aamples will a180 be obtained from the Assiscunk Creek.
"

-------
-~.._--- _._--~-----._---- ~----
-34-
TABLE 3
DETAILED COSTS OF RECOMMENDED ALTERNATIVE
CAPITAL COST SUMMARY
MObilization
Circumferential barrier wall with upgradient
ground water interceptor
Leachate collection system refurbishing and
lago?n decommissioning

Composite synthetic membrane/clay cover system
Gas collection and treatment system
Monitoring wells
Miscellaneous site improvements
Subtotal
Contingencies (15\)
Engineering and Administration
Total
'.
$ 563,000
 626,000
 55,000
4,853,000
 111,000
 23,000
 117,000
$6,3.48,000
'... 
 952,000
 721,000
$8,021,000
Operation and Maintenance Cost Summary

Annual O&M Cost
( $ /YR )
Leach~e collection

,
Leachate transport and disposal at POTW
or BCSWMFC
Gas treatment
Cap and drainage structure maintenance
Monitoring
Miscellaneous O&M
Total
$ 2,500
 15,300
 33,000
 80,000
 48,000
 1,200
 $ 170,000
Total Present Worth_Co8t-~$9,270,OOO

-------
-35-
OPERATION AND MAINTENANCE
'.
Operation and Maintenance (O&M) of the site will include long-
term collection and treatment of the gas and leachate. In
addition, long-term monitoring and maintenance of the cap and
drainage structures will be required. The monitoring program
will include sampling" of ground water, surface water, sediments,
and air. The O&M cost 1s estimated to be $170,000 annually.
O&M will be funded as specified in CERCLA and the NCP.
SCHEDULE
~ect Milestone
- Approve Remedial Action
E.!l!
June 1986
- Amend Cooperative Agreement for Design
December 1986

Pending C~RCLA Reauthor-
izatio,~ ~r State Funding
- Complete Enforcement"Negotiations
- Initiate Design
Pending CERCLA Reauthor-
ization or State Fundin~
- Complete D.sign
Pending CERCLA Reauthor-
ization or State Funding
~
,

-------
ATTACHMENT 1
Analytical Data
-
,
.'
'.
. . .

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Table 1
SUMMARY OF GROUND-WATER
DOMESTIC WELL ANALYSES

-------
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SUMMARY' OF "L~ACAATE. MANHOLE.ANAL YSES
III Cl
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Table 3
SUMMARY OF GROUND-WATER
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Table J
.
:
(continued)
ICI< & ~at:m
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Florence Land Recontouring Landfill
SUMMARV OF GROUND-WATER
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Table 4
~,':.~~ct'8 1 Florence land Recontouring landfill
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.
Florence land Recontouring Landfill
Table 4 (continued)
, SUMMARY OF SOIL BORING ANALYSES
(CONTINUED)
act< & veatc:n
In.''. . ""'hi'.c'. .
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SUMMARY.. OF SURFACE~WATERANALYSES:
~CI(C\l8~-.
....... . -....
Florence. Land Recontourlng Landfill
Table 5 ..
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. ,
ATTACHMENT 2
Responsiveness Summary
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,
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. '. - A
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RESPONSIVENESS SUMMARY:
Completion of Feasibility Study
Florence Land Recontouring, Inc. Landfill
Florence, Mansfield and Springfield Townships
Burlington County
,New Jersey
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,
..
'.
.. '.-.'
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Responsiveness Summary:
Completion of Feasibility Study
Florence Land Recontouring Landfill, Inc.
Florence, Mansfield and Springfield Townships '.
A public meeting was held by the New Jersey Department of Environmental
Protection (NJDEP) on Hay 2, 1985 to discuss the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) for the Florence Land Recontouring, Inc.
Landfill (FLR) site. Notification of the meeting was accomplished through press
releases sent to all newspapers listed in the FLR Community Relations Plan and
mailings to all parties listed in the "Contacts" section of the plan. An
information package including an agenda, fact sheet, glossary of terms, overview
of the community relations program at Superfund hazardous waste sites, site maps
and the steps involved in a major hazardous waste site cleanup was given to all
attendees at the beginning of the meeting (see Attachment A). The meeting was
attended by appro~imately 40 people in addition to the local officials, NJD;P
representatives and USEPA representatives. (See Attachment B). After the
initial presentation by NJDEP's contractor, Black and Veatch
Engineers-Architects, the meeting was opened for discussion.
A second public meeting was held by NJDEP on June 12, 1986 to discuss~ the results
of the RI/FS at the FLR site. Notification of the mUting was ..irccomplished
. through press releases sent to all ~ewspapers listed in the ~ FLR Community
Relations Plan and mailings to all parties listed in the "Contacts" section of
the plan and on the attendance sheet from the May 2, 1985 public meeting. An
information package including the agenda, fact sheet, glossary of terms, overview
of the Superfund community relations program, and the steps in a major site
cleanup was handed out to all attendees at the beginning of the meeting (see
Attachment C). Approximately 90 people attended (see Attachment D).
.
The contractor, Black & Veatch Consulting Engineers, discussed the results of the
RI/FS and the remedial action alternatives for long-~erm site remediation. NJDEP
then presented its recommended alternative.
The draft RI/FS was made available for public review and comment, beginning on
May 19, 19;86, at si~ respositories: The Florence, Mansfield and Springfield
Township Municipal Buildings, the Florence Township Library, the Burlington
County Library in Mount Bolly, and the NJDEP Division of Hazardous Site
Mitigation in Trenton. The comment period closed on June 23, 1986.
Following is a summary of the major verbal and written questions and comments
with NJDEP's and USEPA's responses:
,. .'
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Issue:
Anewe 1':
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Answer:
1
RESPONSIVESNESS SUMMARY
Verbal Comments
Well #4 is not a true upgradient well. They are impac~d by lagoons.
How were upgradient aquifer conditions assessed?
Based on the results of the RI, NJDEP and USEPA have concluded that
well BV - 4S is not a true upgradient well. This may be a result of
local impact on the upper (Pleistocene) aquifer from the lagoons or
spillage which has occurred during leachate removal from the lagoons.
However, the upgradient water quality conditions could be assessed by
the upgradient potable wells. This information will be augmented by
the upgradient wells installed as part of the supplemental sampling
program.
This landfill is only 13 years old and relatively young. As such,
there has been insufficient time for the leachate to migrate. The
Townships are not convinced that FLR is not contributing to the water
problems being experienced in the area. In the past year and a half,
the community has utilized three different laboratories as well as
NJDEP and USEPA and we see different contaminants popping up. Blaclt-
and Veatch (B&V) and NJDEP knew that in addition to the RIfFS,
residents wanted the problem of ground water contamination .~addressed.
Data collected to date has indicated random, not persistemx;.pollution.
The selected alternative will mitigate any future release of
contamination from the FLR landfill. The circumferential barrier wall,
composite c_p and subsequent leachate extraction will minimize the
hydraulic pressures which cause contaminant migration. Public comment
was considered in the design of the RI/FS sampling program. The
sampling indicated that all drinking water criteria had been met. The
two organic contaminants that were detected at trace levels were
methylene chloride and bis(2-ethylhexyl) phthalate. With regard to the
methylene chloride, it has been detected in ten of the 21 homes
sampled. However, in all instances (except for DW-09) it was also
detected in corresponding trip and field blanks (Quality Control
Seples). . For DW-09, a duplicate of this sample was analyzed and
methylene chloride could not be detected. Bis(2-ethylhexyl) phthalate
was detected in three domestic wells as follows: at below method
detection limits (BMDL) in two wells and at 16.0 parts per billion
(ppb) in one well. However, the corresponding trip blank contained
80.0 ppb of this contaminant. Therefore bis(2-ethylhexyl) phthalate and
methylene chloride are believed to be laboratory introduced for the
potable well samples.
We are not sure if the wells were sampled correctly. With regards to
exceeded holding times, Section 10 of the RI has the biggest disclaimer
we've ever seen. . The FS neglects analysis of contaminants that may
have escaped from the landfill already.
All potable wells were- 'sampled in accordance ...with acceptable NJDEP
s8DL1'ling' procedures under- supervision of a NJDEP, representative. The
fitst round of analyses'indicated:"tbat...the,,'laboraeory ,had: exceeded,
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Issue:
Answer:
Issue:
Answer:
2
holding times for ~he volatile organic analysis by six to seven days.
As a result, affected wells were resampled and analyzed for the
volatile organic fraction only. The results of these latter analyses
passed the NJDEP Quality Assurance review withou~. qualification.
However, as with previous analyses, methylene chloride was detected in
these samples and in the trip blank. It is believed that this
contaminant was laboratory introduced throughout the course of the
project, however supplemental sampling will be conducted to address the
presence 'of these low levels of contaminants found in the potable well
samples. This supphmental sampling will include existing monitoring
wells, newly-installed monitoring wells, a selection of local potable
wells and surface/sediment samples from the Assiscunk Creek. A long-
term monitoring program will also be implemented as part of the
selected alternative.
Statements in the RI report are inconsistent regarding the integrity of
the Merchantville Clay. It is stated that the Merchantville is
impermeable, but also suggested that it is not. We know clay layers
may seem to have low permeability and appear continuous, but in nature
clay can fracture and deviate in thickness. The analysis in the RI did
not indicate any connection between the shallow and deeper aquifer-.
That analysis should be completed.
. 'u-'
The RI did not state that the Merchantville Clay was impermeable, but
that it serves to retard the migration of contamination. T~~
permeability of the Merchantville wa~ measured to be between 10
centimeters per second (em/see) and 10 em/sec. At this rate, ground
water in the surface aquifer could migrate through the clay and reach
the Raritan-Magothy in 24 years. Pump tests performed in the
Raritan-Magothy showed no direct hydraulic connection between this
aquifer and the surface aquifer. The recommended alternative will not
only minimize the production of leachate, but will extract any
remaining liquid from the landfill and relieve the hydraulic pressures
which. would drive the leachate through the clay in the 24 year period.
This is expected to substantially reduce the potential for contaminant
migr&tion.
- "
We know about serious problems in Mansfield with regard to high cancer
rates and contaminated water. We are disappointed with the B&V ground
water flow reports. We feel that they are inaccurate. We were
instrumental in getting the site on the National Priorities List. We
went to Washington D.C. to meet with William Hedeman and Chris Smith
and were told that the RI would include an investigation of potable
wells. At the May 1985 public meeting this was again expressed. We
question whether potable sampling was done. Residents that were listed
as being sampled say they were not sampled.

A potable well sampling program was implemented as part of the RI. The
selection of the 20 locations were based on "the following criteria:
1)
Coordination with respect to survey results of the
incidence of cancer on Hedding-Jacksonville Road (at the
request of' Dorothy, W1r~h"" Chairperson to": 'ELB Citizen's
Advisory Committee [FLRCAC)}. '
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Issue:
Answer:
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3
2)
Use of locations with an existing data base. This
focused on the wells sampled be Geraghty and Miller in
1982.
'.
3)
A representative cross section of wells upgradient and
downgradient of the landfill.
The daily sampling logs are available upon request.

In addition to the potable wells sampled during the RI, USEPA sampled
13 potable wells in Mansfield Township in August 1985.
We know there is no source, other than FLR, for the ground water
contamination in the area. We question your analyses. The RI report
stated that there were quality assurance problems with the data.
The potable well data from the RIfFS does not show any contamination in
drinking water supplies which can be attributed to the FLR landfill.
As stated in an earl~er response, detected contaminants are suspected
of being laboratory introduced. The resampling of select potable wel~s-
is expected to clarify this issue. It is possible that there are other
sources of potential ground water contamination in the.~ area. All
potable wells which had quality assurance problems were ~esampled. The
references to qualified data for potable well samples is incorrect and
the final RI report will reflect the correct results. Out of
ninety-two samples taken during the FLR RI, eighteen pieces of data
were qualified due to exceeded holding times for the volatile organic
fraction. It should be recognized when assessing these samples,
however, that they are of a solid matrix in which the holding times are
not as critical as in a liquid matrix. Fluid samples allow for greater
volatization of contaminants during handling then do solids such as
soils and sediments. Due to the nature of these matrices, holding
times are not critical. Resampling was performed on all other matrices
due to exceeded holding times.
I~ future years, how will the origin of detected off-site contamination
b~ distinguished between FLR and the Burlington County Solid Waste
Management Facilities Complex (BCSWMFC)?
The long-term monitoring program will continue for at least a 30-year
period. This, in conjunction with the supplemental sampling program,
will: (1) further investigate potential residual contamination; and (2)
establish a strong data base prior to the installation of the BCSWMFC.
A figure of $300 million was presented in the FS as the cost for
excavation and removal of the landfill. What is the origin of this
figure?
The number of facilities nationwide which are currently permitted to
accept. hazardous waate,. is very limited. Theae. facilitie.s. were.
contacted for representative prices and trucking costs were evaluated,
based upon:. trauportat1on :~, to. . the.:. closest ,': licensed .:' f acil1ty., . (CECOS '.
Landfill in Niagra Falls, NY). Movement of the 30 acre landfill could
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4
take up'to five years with no assurance during the process that CECOS
will remain a permitted facility.
Containment is not permanent. Only two alternatives, ..containment and
no action, have been evaluated; other technologies should be evaluated.
Other technologies were evaluated (refer to Chapter 3 of the FS - Vol.
3) but were determined inappropriate for this site. Complete
encapsulation with a full slurry wall and clay/synthetic cap is a
state-of-the-art remediation technology for a landfill of FLR's size.
At the June 12, 1986 public meeting, NJDEP made it clear that during
the comment period, the public may submit additional alternatives that
may not have been considered. None were received.
No coordination with the emergency departments occurred during this
project.
In June 1985, NJDEP met with representatives of the police, fire and
ambulance squads of Florence, Mansfield and Springfield Townships. In
addition, representatives of local hospitals were present. Topics of
discussion at this meeting included the sampling program for the Rr,
equipment which was to be utilized and possible emergencies which could -
arise (their origin, who would respond, etc).
.
.
'. - ...
There are numerous families now using bottled water and bagged ice.
My family has suffered from repeated medical problems as well as
unexplained illnesses. This imparts not only financial stresses, but
emotional strain as well. More work needs to be done to establish the
true significance of the contamination there. Containment must be
combined with an alternate water supply.
All sampling, to date, has indicated that there does not exist any
potable wells which have contaminants which exceed relevant drinking
water criteria. Traces of contamination which have been found cannot
be definitively linked to the FLR landfill. By law, there existS no
justification to implement public water lines in the area. The
s~ppiemental sampling program will be implemented in the Design phase
tQ further' address area water quality.
Were the selection of alternatives influenced by the County and the
facility they are building?
No. Both on-site and off-site facilities were evaluated for leachate
and gas treatment. Any reference to a Publicly Owned Treatment Works
(POTW) in the FS could mean the use of the BCSWMFC as an option. The
BCSWMFC was evaluated as a technically sound alternative for leachate
disposal and by law must be addressed. No contracts have been
developed for its use.
.. (,"
What carries ':more 'weight in evaluating the" alternatives, governmental'"
concerns or local concerns?
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5
Answer:
Neithe~ . governmental nor local concerns carry more weight over the
other during the. alternatives evaluation process. Section 300.68
(3)(i) (1-4) .of the National Contingency Plan states that:
-
,
(i) Selection of Remedy (1) The
appropriate extent of remedy shall be
determined by the lead agency's selection
of a cost-effective remedial alternative
that effectively mitigates and minimizes
threats to and provides adequate
protection' of public health and welfare
and the environment. This will require
selection of a remedy that attains or
exceeds applicable or relevant and
appropriate Federal public health and
environmental requirements that have been
identified for the specific site. (2) In
selecting the appropriate extent of
remedy from among the alternatives that
will achie~e adequate protection of
public health and welfare and the
environment in accordance with 300.68
(1) (1), the lead agency will consider
cost, technology, reliability,
adminstrative and other concerns, and
their relevant effects' an public health
and welfare and the environment. (3) If
there are no applicable or relevant and
appropriate Federal public health or
environmental requirements, the lead
agency will select that cost-effective
alternative which effectively mitigates
and minimizes threats to and provides
adequate protection of public health and
welfare and the environment considering
cost, technology, and the reliability of
the remedy. (4) Pertinent other Federal
.cri teria, advisories, and guidance and
State standards will be considered and
may be used in developing alternatives.
with adjustments for site-specific
circumstances.
'.
:.. '. - ...
In Section 300.38(3)(i)(2) "other concerns" includes any state or
local concerns. USEPA mandates that the lead agency (in this case
NJDEP) conduct a Community Relations Program which addresses local
government and citizen concerns. This Responsiveness Summary is a
summary of community input.
Issue:
We are concerned over pthe contaminants which do not"have standards and
which could have potential long term effects on health. Tbe standards
for contaminants, 'should be zero parts per billion;,;... .
, """..''.. . ,.,','
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Answer:
Issue:
Answer:
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Answer:
Issue:
Answer:
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"Answer:
6
This ye~r. NJDEP expects to complement USEPA's drinking water criteria
by setting 16 additional state drinking water standards. The laws
under which NJDEP and USEPA function allow for action only in the event
that contaminant levels present exceed applicable and relevant
standards. criteria or guidelines. All qualifications br descriptions
of water quality and all remediation decisions must be made in
reference to these standards. All relevant standards will apply to
present and future sampling.
Removing the entire waste fill will not remove all of the contamination.
Contaminants are already present in the Merchantville Clay. What would
be done about the contamination in the clay if the site were to be
excavated?
That portion of the affected clay would have to be removed.
Was the Roebling Steel Facility ever
upgradient ground water quality of FLR?
evaluated as
impacting the
No. There has not been any evidence of a connection between the two
sites. Roebling Steel 'is several miles from FLR and is presently being
investigated by USEPA under a separate RI/FS.
The FS does not evaluate the off-site risk due to on-site emergencies.
We are concerned about the health and safety of local residents during
the construction phase.
During the Design phase of this project. a contingency plan to address
such emergencies will be developed. This plan will be available for
public review upon request. A Health and Safety Plan will be developed
for the future construction activities. The plan will be developed in
coordination with local input.
When will work be initiated at FLR?
The Design phase. which averages 12 to 15 months in duration. is
scheduled to begin in early 1987. The Construction phase is currently
ptojected .to begin in 1988. following the completion of the Design.
Initiation of further work may be dependent upon Superfund
reauthorization.
Who will perform the Operation and Maintenance (O&M) at the site?
O&M is the responsibility of the NJDEP and will be accomplished under
contract with a private firm.
What is NJDEP's responsibility in keeping the local
notified of activities and providing monitoring reports?
communities
. ,
Agreements wilLbe,1I8de with local officials regarding the circulation
of the data results. Other than public meetings and/or briefings at
pre-set points in the remediation process (or when major events occur)
the community_" ,~has,,' the responsibility:' of_. contacting, NJDEP 'for
information'.:,,:. . " "
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Answer:
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7
Written Comments
The general
significant
been posed
"Superfund"
.summary of .the report (Volume 2, page i) states that "no
adverse impacts on the, environment or pubJ.ic health have
by the FLR Landfill." By the very definition of a
site, this is a contradiction.
The statement made in the RI (Vol 2, pg. i) which states, "the
investigations conducted at the FLR Landfill site indicate that no
significant adverse ~pact on the environmental surroundings or public
health have been imposed by the facility to date" is accurate with
respect to the RI performed by Black and Veatch and does not contradict
. its status as a "Superfund" site. The National Priorities List (the
national ranking of sites eligible for Superfund monies) is comprised
of sites with known hazardous wastes that are either presently
jeopardizing, or have the potential to jeopardize, public health and
the environment. The RI performed at FLR clearly identified hazardous
wastes within the landfill. Although no migration has been evidenced
off-site to date, there exists a potential for a release, leading NJDEP
and USEPA to elect to encapsulate the source.
Twelve volatile organics, three acid compounds and several heavy metals-
were detected in the B&V monitoring wells, which transbtes into a
variety of environmental threats and health ha~rd$. These
contaminants will be a th~eat to anyone using water from the
Raritan-Magothy. '
Regarding the variety of contaminants (including volatile organics,
heavy metals and acid compounds) which were detected at elevated
levels, please be aware that none of these parameters exceeded drinking
water standards. The recommended alternative 1s designed to remove
contaminants from the landfill and will alleviate the hydraulic head on
the Merchantville Clay formation. It is these hydraulic presssures
which serve as the driving force of water through the Merchantville
into'the Raritan-Magothy.

I~ is not hydrologically astute of the report to say that "the effects
o.r the contaminant migration from the landfill are. limited due to the
dilution of the contaminants in the surface waters of the Assiscunk
Creek." Because the water dilutes the contaminants, doesn't mean that
there are less contaminants, but that they are more widely spread.
The intent of B&V's statement was not to say that the dilution in the
Assiscunk Creek was an acceptable method of treatment, but rather a
present condition at the site which minimizes off-site impact. As a
result of this and other phenomena, an encapsulation alternative has
been chosen. In addition, sampling will be implemented to address 'any
potential residual contamination.
There is a contradiction in the two statements that "the investigations
conducted. at the FLR Landfill site indicated that no significant
adverse impact on the environmental surroundings or public health have
been ,impo'8echby,. ,the facil~ty to, date".. (Vol,. 2..".,pg. i) and "it 1s the
opinion of Black. and. Veatch'" that'.. off-site' :ccmtam1n.tion'" I18Y:: be .
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Answer:
Issue:
,Answer:
Issue:
Answer:
. .,,~ ' ,
'.:
Issue: '
8
contributed both by unidentified errant sources other than FLR and
limited contribution'by the FLR Landfill at this time."
There is no contradiction in terms with respect to claiming that FLR is
not imposing a significant adverse impact on the environment and that
it could also be a contributing source of erratic contamination found
off site. Contaminants found off site were infrequent, with no
distinguishable pattern, and were well below known drinking water
standards. Therefore, it is NJDEP's and USEPA's judgement that there
is no significant off-site impact from FLR and traces of contamination
which were found mayor may not be associated with the site.
The ground water is contaminated with arsenic, chromium, zinc, iron,
and' total organic compounds and we suspect that this is the cause of
the high rate of mysterious illnesses and cancer cases in close
proximity to the FLR site. In an unscientific survey, we found a
cancer rate three times higher than the rate for the State of New
Jersey. We petitioned USEPA to do a health survey. The NJDEP spoke
with me about a health survey, but nothing was ever done. We have
contacted a university ~o conduct a survey.
Contaminants found offsite were infrequent, with no pattern and welr
below any standards. There is no significant impact by FLR and -
contamination which was found mayor may not be assocutt!'t\. with it.
Therefore t the cause of any illnesses cannot be attributed to FLR at
this time. The New Jersey Department of Health is currently conducting
a Cancer Cluster Investigation in the area. This is a .preliminary step
which may lead to a more in-depth survey.
The residents of the Township of Springfield petition for "total
cleanup and removal of all hazardous compounds" from the landfill.
The estimated cost of this remedial action alternative is $300 million.
Although total removal may seem to be the ideal remedial action
alternative, the Superfund budget simply precludes this choice. This
figure represents a substantial portion of the total proposed Superfund
b~get over the next several years and this is only one of 888 sites
nationwide~
Furthermore, there are other disadvantages which must be taken into
account when considering this alternative. For example:
Increases in area traffic over a period of years from thousands of
heavy-duty trucks which would be needed to remove the waste;
Increases in the risk of off-site contamination posed by potential
accidents involving hazardous waste transportation;
-'
Lack of,licens~~diposal facilities available to dispose of such a
large volume of waste material (which would ;probab1y have to be
placed in another landfill). '
"We...,petit1oned:, NJDEP"towork closely with ,us,during the course of the
RI/FS, but were told' that NJ1)EP~va8unableto:,meetw1th"Us. ,We ,feel we,,'
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Answe r :
9
could have made suggestions concerning the locations of domestic wells
that could have influenced the selection of wells tested.
Requests for additional meetings to discuss sampling' data were' denied
because data had not yet passed Quality Assurance/Quality Control
review. The data was not available until two days prior to the public
release of the RI/FS. Up until that time, all other information had
been forwarded as it was available. The field sampling plan (the scope
of work for the investigation and probably the most important document
for public input prior to the final report) was forwarded to both Mr.
William Wilkens, Attorney for Florence Township, as well as to Mr. Dan
Raviv, Mansfield Township's hydrogeologist. Written comments were not
received from either party although Mr. Raviv did telephone the NJDEP
site manager after his review. His only contention with the potable
sampling program was that well-screen depths be determined prior to
sampling. In addition, the proposed potable sampling program was
modified in response to conversations between USEPA/NJDEP and Mrs.
Dorothy Wirth of the Mansfield Township Environmental Commission.
This land was clean in 1973. None of the seven alt'ernatives presented
will restore the land to that condition. There are only t'i.O
alternatives presented: no action and containment. Containment will not -
work. The contamination w11l eventually migrate. ,Innovative
technologies have been identified and should be explored~~ .'.'.

In most cases, it is not possible to return contaminated land to its
former pristine condition. Containment with leachate, treatment is the
best alternative identified for preventing further environmental
impacts via contaminant migration. In Chapter 3 of the Feasiblity
Study, Black and Veatch evaluated the known technologies to date. The
implementation of a slurry wall was the only applicable state-of-the-
art technology for a thirty-acre landfill. The development of further
alternatives was requested from the communities during the public
meeting for NJDEP/USEPA review. None were received.
The ~hreats posed by FLR are minimal and are representative of those of
a. sanitary landfill. Nothing in the B&V RI/FS demonstrates any
j~stif1cation for the site's inclusion on the National Priorities List.
The lavishly expensive remediation alternatives presented in the FS are
wholly unwarrranted and represent overly complex methods of closure
that exceed NJDEP's normal requirements for landfill closure.
Although the RI!FS states that the landfill is representative of a
typical municipal sanitary landfill, the data collected during the
field investigation determin~d the presence of elevated levels of
hazardous substances in the ground water and soils in the FLR Landfill.
Substances found in the ground water in the landfill include 351ppb
1,1 dichloroethane, 148 ppb ethylbenzene, 787 ppb toluene and 1600 ppb
arsenic. The landfill so11s contain 79,609. ppb toluene, 298 ppb
pentachlorophenol, 30,100 ppb bis(2-ethylhexyl) phthalate and 2030 ppb
tetrachloroethylene. .Section 104(a) of CERCLA states that "Wherever
"'any hazardous substance is released or there. is a ,substantial threat of
such, B.. releBH: into,. the, evironment.. . the President is" authorized to
act, consistent with the National Contingency Plan (NCP)' to provide', for,
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10
remedial action relating to such hazardous substances..." The
hazardo~s substances found in the FLR Landfill pose a threat of release
into the environment and therefore the USEPA and NJDEP are acting to
remediate the' site consistent with the NCP. The alternative selected
in the R.O.D. is designed to prevent the release of-- the hazardous
substances from the landfill into the environment.
Issue:
Hazardous compounds found in the leachate were at lower concentrations
. than that found two years ago, which indicates a dilution of
contaminants in the wastefill. The impacts on ground and surface water
quality downgradient of the site are minimal.
Dilution of contaminants does not mean that they disappear, rather that
are spread over a larger area. In the case of FLR, ground water in the
landfill containing hazardous substances is migrating from the landfill
into the adjacent Pleistocene Aquifer. This release or even the
potential release of hazardous substances provides authorization to
remediate the site consistent with the NCP under Section 104(a) of
CERCLA.
Answer:
Issue:
No ,levated levels of. volatile organic compounds were detected in the
air at the site.
Page ii of the RI report states that "the presen$:e of elevated levels
of volatile organic compounds was not detected (in the;~ir' emissions
from FLR)." This statement 'refers to. the fact that no specific
volatile organic compound was identified at elevated levels. The air
data on Tables 8.2, 8.3, and 8.4 do in fact show levels of volatile'
organics onsite as high as 180 parts per million. Regardless of the
results of the air investigations, a remedy involving capping of the
landfill necessitates gas collection and treatment to alleviate the
build up of gases within the landfill or gas migration through the
ground.
This site was improperly placed on the National Priorities List and
should be de listed now. The Rl shows that closure under CERCLA is
unne~ssary. No significant adverse impact on the environment or
p~lic hea~th have been posed by the facility to date.
.
Although B&V stated that "no significant adverse impact on the
environmental surroundings or public health have been imposed by the
facility to date", the potential for adverse impacts exists and is the
justification for remediating this site consistent with the NCP. In
its present state, the FLR landfill site does not meet the criteria for
deletion from the National Priorities List. This site will be eligible
for deletion after the necessary remedial actions are taken and it is
proven, via monitoring, that a potential public health or environmen~al
threat no longer exists.
Answer:
Issue:
Answer:
The NJDEP and USEPAbelieve that there is evidence of some migration
from the FLR landfill into the environment. Downgradient well BV-SS in
the Pleistocene Aquifer, contained 231.61.. ppb of total- organic
. compounds. the Assiscunk Creek contained 9.42'ppb of pentachlorophenol
and 16.5 ppb of' phenol. ..The'1lIlFS; e~1mat.ed; that contaminants ,from the.
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11
landfill' would migrate through the Merchantville Clay to the
Raritan-Magothy Aquifer in 24 years if the landfill remained in its
present state.
This site will soon be surrounded by the proposed BCSwMFC. Any chance
of lateral migration of leachate from FLR will be foreclosed by the
containment barriers which must be constructed for the solid waste
facility. .
The containment system for the solid waste facility is not being
designed to "foreclose" leachate from FLR and cannot be relied on to do
so. They are independent facilities whose retention mechanisms will
not interact with one another.
Governmental, public and judicial knowledge can certainly be taken with
regard to the serious domestic water supply contamination problem in
private potable water supplies located in proximity to the FLR
Landfill. Vinyl chloride, methylene chloride, chloroethane,
1-2-dichlorobenzene, bis (2-ethyl hexyl) phthlate, arsenic and numerous
other carcinogens hav.e been found in significant concentrations in
domestic water supplies in both the shallow Pleistocene Aquifer and the
deep Raritan-Magothy Aquifer.
Some of the concentrations of these contaminants are in:~xcess of five
times the concentrations found in field blanks and therefore merit
further intense investigation. . This data has been compiled over the
last several years as a result of tests performed .by NJDEP, USEPA,
Burlington County, Mansfield Township and private water well
investigations by concerned residents.
Mansfield Township has, in fact, expended a great deal of time and
money with regard to its efforts in having its ground water
hydrologist, Dan Raviv Associates, perform water tests throughout the
township in an effort to analyze contaminant data and contaminant
sources.
Tpe alarmingly high cancer occurrences and cancer related deaths
experienced by residents living in close proximity to the contaminated
~astefill area has been repeatedly communicated to various USEPA and
NJDEP officials over the last several years. Cancer occurrences in the
area of the township where the FLR landfill is located exceed the New
Jersey average by approximately three hundred (300) percent.
At a conference in Washington. D.C., prior to the award of the RI/FS
contract to B&V, William N. Hedeman, Jr., then Director of the Office
of Emergency and Remedial Response in the Federal Superfund Program,
indicated that the domestic water supply contamination problem would be
investigated in conjunction with and as a part of the RI/FS for FLR and
that remediaton of FLR would be coordinated with the location and
construction of the BCSWMFC proposed by the Burlington County Board of
Chosen Freeholders. on the parcel of land adjacent.:. to the F1A Landfill
site. .
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Township representatives have repeatedly expressed their concerns over
deferriftg commencement of waste filling operations in the new County
landfill next to the FLR Superfund site until remediation has been
completed and. domestic water supplies are free from con~amination. The
Township has also expressed an additional concern pertaining to the
location of a 1,200-unit adult community, which is now being completed,
which is supplied by water with two on-site wells. . This development is
located approximately one mile from the FLR Wastefill area. Mansfield
and Florence Townships were, therefore, under the opinion and belief,
based upon representations from NJDEP and EPA, that the scoping of the
project included an expansive investigation, dealing with both source
and off-site contamination and environmental concerns, and that the
factors set forth in 40 CFR Section 300.68(e) would be incorporated
into the RI/FS analysis. Pursuant to subsection (e) (1) (3i) of 40 CFR
Section. 300.68 (e), the expanded analysis would necessarily include an
analysis of "contaminated drinking water at the tap" and remediation
measures responding thereto, including provision for water supplies.
All of these concerns were again expressed at the first public meeting
arranged by your offic~ which was held on May 2, 1985. Both Townships
and their residents were led to believe that such an expanded analysis
was part of the study, especially in light of the following statements
contained in Section 2.4, entitled Potable Water Supply Well. Inventory, -
on Page A-14 of BlaV's Project Specific Proposal for FLR: . ,'..',
. .
"as part of the field opet:ations, a survey of domestic and any
public, water supplies within a one-mile radius of the site will
be conducted. The purpose of this survey wilf be to identify
domestic water supply wells that may have been impacted by
contaminant migration from the site and to further define the
geologic and hydrologic conditions in the area."
Needless to say, the Townships were dismayed to find, upon receipt and
review of BlaV's RI/FS Report two weeks ago, that BlaV did not
investigate domestic water supplies within one mile of the contaminated
waste fill area as represented, but, instead, simply tested twenty
domes~ic wells located in close proximity to the waste fill area. The
To~ship officials and the residents and professional consultants were
equally dismayed that BlaV did not expand their investigation and study
upon finding contaminants in those wells sampled. BlaV simply indicated
that further tests should be conducted in the future with respect to
these issues and, as will be discussed in subsequent comments,
indicated that the contaminant source might not be the landfill
inasmuch as the same or similar contaminants were found in both
upgradient and downgradient wells.
Based upon the limited scope of the investigation, BlaV concluded in its
RI that the contamination was "source contained". The remediation
alternatives suggested in the FS were predicated upon and presuppose
the accuracy of this conclusion in the RI. The Ipwnships feel that the
remedial alternatives may not accurately or fully address the nature,
scope and breath of appropriate remedial measures if the supposition in,
_the RI pertaining to "source contamination" is. incorrect,
unsubstantiatecL and/.or.-:1ncoDclus1ve.
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It is the opinion of NJDEP and USEPA that the potable sampling program
perfurmed by B&V was in accordance with Mr. Hedeman's assurances to the
Townships, the CFR and the project-specific proposal submitted by B&V.
As per Mr. Hedeman and the CFR, a domestic water supply investigation
was performed to assess the potential impact of FLR an area potable
wellti. The traces of contaminants found in potable wells did not
exceed current drinking water standards and could not be directly
associated with FLR. Regarding the "one-mile survey" listed in the
proposal, a survey ~ !!2! include every home wi thin a one-mile
radius, rather a representative sample of a potentially affected,
Community. B&V, in their response to Dan Raviv's comment letter, did
in fact, map out the 20 samples taken and found that a one-mile radius
had been addressed (see attached).
The Townships were advised by USEPA and NJDEP that an enforcement
action would be brought by the government(s) under CERCLA to recoup its
costs incurred resulting from investigation and remediation. However,
Page 5-58 of the FS (Volume 3) indicates as follows:
"An endangerment assessment is often prepared as part of the
public health assessment for enforcement-related remediation~
Since the remediation to be performed at the FLR Landfill is not -
currently defined as an "enforcement action" under CERCLA, a
separate endangerment assessment has not be perform,,?..,tj.

NJDEP's enforcement attorney was present at the June 12, 1986 public
meeting and representations were made at the premeet1ng conference with
the Municipal officials that an enforcement action would be brought by
the government. The Townships request written confirmation that an
"enforcement action" under CERCLA will be instituted by the government
and that a separate endangerment assessment will be performed and made
available to the Townships within the next several weeks. The
Townships have incurred substantial investigatory and remediation costs
on their own and may wish to commence litigation to recoup their costs.
I am' advised that Florence Township has already filed a "Notice of
Claim~' under CERCLA.
A1i exposure assessment was completed (RI!FS, Volume 7, Appendix Q)
which identified the exposure pathways at the site, and as a result the
recommended alternative was designed to eliminate these pathways. The
supplemental sampling program will address both ground water and
surface water quality. In the event that contamination is detected in
potable wells at levels which exceed present drinking water criteria
and which can be linked to FLR, a risk assessment will be performed at
that time. With regards to the aforementioned enforcement action, an
investigation to identify potentially reponsible parties (PRPs) is'in
progress for the purposes of potential cost recovery and enforcement
actions in regard to future costs of remedial activities. Parties
identified as PRPs will be sent notice letters offering them the
opportunity to perform the Design and/or Construction activities
recommended in the Record of Decision before USEPA and NJDEP make a
decision to fund' any future work. Should' they decline, they are
VU~~L&~l..uly. liable; for~' .treble damagea.,., ' '~ ",
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14
Both the RI and FS devote substantial verbiage to an explanation of
groundwater flows in both the shallow aquifers in the Pleistocene
deposits and' the deep Raritan-Magothy Aquifer. Reference is made to
prior studies and reports focusing on the geologic" and hydrologic
analysis of the site by Geraghty and Miller. Inc. (G&M). Woodward-
Clyde, Richard A. Alaimo Associates. Princeton Aqua Sciences. Inc. and
Roy F. Weston. Page 5-30 of the RI (Volume 2) indicates that "The
configuration of the potentiometric surface contour lines (See Figure
5.7) indicates a general ground-water flow direction from the northwest
to the southeast and. south, toward Assiscunk Creek." Several sections
in both the RI and FS indicate that this "flow description" applies to
both the shallow aquifers and the Raritan-Hagothy Aquifer. Other
sections in the reports indicate that this "flow description" applies
to both the shallow aquifers in the Pleistocene deposits. The
Townships request WTitten clarification from B&V as to whether this
"flow description" is limited to an analysis of the shallow aquifer
flows and/or whether the "flow description" is also applicable to flows
in the Raritan-Hagothy Aquifer. At the June 12, 1986 public meeting,
Lawrence J. Hosmer of B&V presented a slide which was shown to the
public which appeared' to indicate that the flow description appli~s
only to the shallow aquifers in the pleistocene deposits.
Please refer to the attached B&V letter.
. '. - JIo
.
As indicated previously. B&V has offered an opinion that the
groundwater flow is from the northwest to the south~ast to the south
towards the Assiscunk Creek. B&V has concluded that the contamination
found in "upgradient" wells cannot be caused by the landfill inasmuch
as the landfill is hydrologically "downgradient". B&V has also
indicated that groundwater flows can be changed by heavy water
utilization and pumping in the area. The Townships feel that an
explanation is in order from B&V to reconcile these two statements and
opinions. The Townships request WTitten confirmation from B&V that the
contamination found in the supposedly "up gradient" wells cannot
possibly be coming from the FLR waste fill area.
Please refer to the attached B&V letter.
. .
,
B&V indicates that the waste fill area is located in close proximity to
the Raritan-Hagothy recharge area and that this aquifer is recharged by
the Delaware River and through vertical downward infiltration from
overly1n~ water sources. B&V has also indicated that the
Merchantville Clay Formation. which overlies the Raritan-Magothy
Aquifer. "...is fairly irregular and suggests the presence of remnant
fluvial-induced, erosional features." Not withstanding the foregoing
comments, B&V has determined that the existence of the Merchantville
Clay Formation can be expected to protect the Raritan-Magothy Aquifer
from leachate contamination. These statements and this analysis
appears to conflict. . If the Raritan-Hagothy 1& "impermeable", the
Raritan-Hagothy Aquifer would not be able to be recharged by vertical
seepage from;' shallow caquifers. The Townships request a WTitten
explanation from B&V. further expanding upon the. "pe-rmeability factors"
of the MerchantTille... Clay ':cFormation...::: It is . also~ to.' b-e.. noted ,':,as1
advised at the June 12 public meeting; that Beatrice Tylutki testified
,",.: .
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Answer: .
15
in court proceedings in the late 1970's that the Merchantville Clay
Formation had been pierced under the waste fill area and that the waste
fill leachate 'was then contaminating the Raritan-Magothy Aquifer. An
explanation is in order as to why DEP and B&V's current position
appears to be that the Merchantville Clay Formation'. has not been
pierced and that there is no contamination seeping into the
Raritan-Magothy Aquifer. .

The RI/FS report did not state that the Merchantville Clay Formation
was "impermeable" but rather was characterized by low permeability. In
fact, B&V has ackno\1ledged that, given present conditions, break
through of the clay would occur in 24 years. As a result, the
recommended alternative seeks to mitigate the driving hydraulic force
which "pushes" the contaminants through the clay. This will be
achieved by encapsulating at the landfill with state-of-the-art
technologies, and by extraction of the remaining liquids within the
fill material. In response to the inquiry as to the testimony of
Beatrice Tylutki, the site manager, Beth Muhler, has contacted Mayor.
Sharon Worrell of Florence Township to obtain tbecourt proceedings.
However, their existence does not alter the fact that neither the pump
tests nor the samples taken during the RI/FS indicated a direct
hydraulic interconnection between the upper and lower aquifers. In the -
event that the court proceedings do indicate a "pit" of some. sort, this
information will be considered during the Design phase. . ,~.
'-.
SURFACE WATER IMPACTS AND SOIL 'SAMPLINGS. Methylene chloride was found
in both the surface water and soil samples that ~ere taken. B&V
concludes that water quality in the Assiscunk Creek has "changed
slightly in the last three years" and that several constituents exceed
the state's water quality standards. A review of Table 6.1, which
compares upstream and downstream stations, reveals that fecal
chloroform, fecal strep and phosphate levels are all in violation of
the State standards. A series of other chemicals, including phenol,
were present in both the Assiscunk Creek and the drainage channel
located adjacent to Cedar Lane extension. B&V indicates that "it is
also -theoretically possible that these constituents are emanating from
t~e waste fill since phenol was present in the water in BV-2S and
p,ntachlorophenol was present in the soil in B-03.". B&V also found
that phthalate contamination actually increased in concentration
approximately 54 feet into the Merchantville Formation. The existence
of the methylene chloride contamination along with the other
contaminants that were found at the levels that they were found in the
soils and in the Assiscunk Creek should have spurred additional
investigation by B&V. However, B&V simply reported the existence of
the contaminants and stopped its investigation after rendering an
. opinion that the contamination could not be caused from the waste fill
area. It is obvious to anyone investigating the FLR Landfill that it
is the only source of contamination in those portions of Florence and
Mansfield Townships. B&V should have expanded its investigation as
opposed to stopping its investigation when these contaminants, at the
levels found, were de~ted.
., .
The. IlIIFS'~found. tbat..:the:.trac:e... levels. of. contaminants'detected in the.
surface water and soils could not be directly linked to' FLR in the form
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16
of a ground water plume, but acknowledged FLR to be a potential source.
It is the acknowledgement that has prompted both the USEPA and the
NJDEP to endorse the complete containment of the landfill. In
. addition, to address potential residual contaminat~on, a sampling
program will be initiated in the Design phase and haa been incorporated
as part of the selected remedy.
There has been misinterpretation with respect to B&V's statement
regarding the concentrations of contaminants increasing at 50-60 feet
in the Merchantville Clay. This depth reference was relative to the
top of the wastefill and represents the junction of the clay and the
wastefil1- For further clarification, refer to Volume 2, table 7.3,
"Wastefill" heading, B02-02 and Volume 2, Figures 4.5-4.8.
REMEDIATION ALTERNATIVES. At the June 12, 1986 public meeting, DEP and
B&V indicated that Alternative 3, with modifications thereto, would be
the selected remediation procedure. The Townships feel that additional
off-site monitoring wells should be included in the remediation process
to further investigate contaminant levels. Additionally, provisions
for potable water supply for the residents in the area should be
included in the remediation alternative. Many of the residents living
in close proximity to the landfill have been drinking bottled water-
since the late 1970's. Installation of a water line connected to the
Burlington Township public water supply is in order for th~~~rotection
of these individuals. .,
An additional sampling program has been included ~n the selected
remedial alternative. This program will include the implementation of
additional upgradient and downgradient monitoring wells and the
reapect1ve sampling of these wells, pre-ex1at1ng wells, select potable
wells, surface water and sediment matrices.
Consistent with the explanation provided in the June 12, 1986 public
meeting, the provision for a public water supply cannot be performed
via the FLR Superfund Project. All data, to date, has not indicated an
impact from the landfill c;m local potable supply wells. Methylene
chloride, the reoccurring contaminant found in the potable wells, was
found both upgradient and downgradient of the landfill and was well
below drinking water standards. In the event that future sampling
demonstrates a potential public health problem associated with the
drinking water supplies, appropriate remedial action will be
considered.
It is my understanding that 2-ethyl hexyl phthalate concentrations were
found in wells that have been installed by Burlington County on the
tract of land adjacent to the FLR Landfill where the new County
Landfill is to be located. Based upon the B&V reports, this area is
supposed to be "upgradient". An explanation is requested from B&V as
to how this situation; could occur. As referred to earlier in this
letter, B&V has' neglected to investigate." the 8ources.. of the
cont8J!1inants found in the supposedly "up gradient" wells. A more
intense a~ detailed investigation and analysis. of. this issue must be
. conducted. .
. ,..
Issue:
Answer:
Issue:
'. ~.; "
,.,.,. .
'. ...;., ..',
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Answer:
, 17
Levels of. bis-2-ethyl-hexyl phthalate, well below current drinking
water standards, were found both by Burlington County during their
field investigations and by USEPA in their August 1985 investigation of
, the water problems being experienced by the people of Columbus. This
is a reccurring regional problem that Mansfield Township's own
hydrologist, Dan Raviv Associates, has not been able to pinpoint a
source for. Its occurrence has been so varied and irregular that no
direct link has been established to FLR or any other source. NJDEP has
begun to investigate potential sources, other than FLR, that might be
the cause of the phenomenon.
B&V was contracted through federal funding to address the FLR landfill
and its subsequent tmpact on the environment and public health of the
surrounding community. Ground water flows were established in
agreement with the NJDEP's Division of Water Resources, and upgradient
and downgradient flow conditions clearly defined. You are referred to
the attached B&V letter for a further discussion of this issue.
The accuracy of the lab tests and data that was compiled is
questionable in light of all of the Quality Assurance problems and
improper testing procedures utilized. The conclusions drawn by B&V are
based upon the inaccurate and incorrect data. It is suggested that-
retesting and reanalysis is in order to assure the quality of the lab
results and data on hand."
. ..
'..,.. .-
Attached, please find an intra-D~partmental memorandum which summarizes
the qualifications on the laboratory data. This should replace
Appendix G of the RIfFS which was an incomplete' draft of this
attachment. In addition, the "QD" denotation on the six potable
samples is incorrect. It referred to the qualifications on the first
round of sampling. The numbers presented represent the resampling
performed for the volatile organic fraction which had originally
exceeded holding times. In light of this information, the quality
assurance problems, after resampling, were minimal.
-
,
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, .
BLACK Be VEATCH
ENGINEERS-ARCHITECTS
TEL. 13011 840-1123
SUITE 200, 2£01 RESEARCH BOULEVARD
ROC:KVILLE,.MARYLAND 20850
June 27, 1986
"so Beth I. Huhler, Site Hanager
Nev Jersey Department of Environmental
Pro-tection
Hazardous Site Hitigation Administration
428 East State Street, Second Floor
Trenton, Nev Jersey 08625
Dear Hs. Huhler:
Re:
Response to Public Comment
Florence Land Recontouring (FL~)
Landfill RIIFS "
. ,.-..
.
In accordance vith your request, ve have revieved the comments received
by the New Jersey Department of 'Environmental Protection (NJDEP) from the
firms of Parker, HcCay & Criscuolo, P.C. and Dan Rav~v Associates, Inc.
(DRAI) during the public comment period relative to the remedial
investigation/ feasibility study conducted at the FLR Landfill in Burlington
County, New Jersey. The comments offered by DRAI are specifically addressed
in this response. General information is also provided to assist the NJDEP in
responding to Parker, McCay & Criscuolo, and as a result of a Black & Veatch
review of the "Preliminary Interpretation of the Regional Hydrogeology in the
Vicinity of the FLR Landfill", prepared by DRAI. This response is organized so
as to directly correlate with the points addressed by DRAI.
1.
Herchantville Formation Characterization
-
Commen t :
"Black & Veatch indicate that the Herchantville occurring in the
study area consists of strata of clay, silt, and sand vhich are
vertically and laterally discontinuous. The report is deficient in
describing the occurrence and lateral movement of ground vater in the
Herchantville, vhich vould impact potential contaminant movement from
vastes in the overlying FLR landfill. A quantitative analysis of the
rate of dovnward infiltration, based on differences in ground vater
levels betveen all three units, is also lacking in the Black & Veatch
study."
Response: .

, Discussion ,:, presented in the RI report, vi tb respect': to. the potential, for'
the' vertical and' lateral aigration' of'.', contaminants', through the Herchantville
Formation is necessarily limited to the extent of data.,avaiILble. A quantita-
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BLACK a VEATCH
New Jersey Department of Environmental Protection
Hs. Beth I. Huhler 2
June" 27, 1986
tive assessment of vertical and lateral flow through the Herchantville
Formation, and an assessment of the potential for contamination. of the
Raritan-Hagothy Formation by the landfill, were not performed during the RI/FS
because the existing database was not sufficient considering the heterogeneous
character of the formation. The hydraulic conductivity of each of the 3
geologic units is indeed integral to determining cross contamination
potential; however, the level of detail appropriate to the overall scope of
the study was. applied in .order to determine the physical properties of each
un.it. Additional data on the head and the vertical/horizontal permeabili ty
distributions across the Merchantville Formation would be required to prepare
a reasonably precise, quantitative assessment. This level of data is being
gathered by Voodward-Clyde Consultants for the confining unit underlying the
. proposed Burlington County SVMFC. By analogy, justified by the proximity of
the facility to the FLR Landfill site and similar depositional and physical
properties of the Merchantville and Voodbury clays, the Voodward-Clyde data
and assessment would most probably be reasonably applicable, and therefore
could be employed at the FLR Landfill site, once complete. It is anticipated
that this information, based upon preliminary discussions with Voodward-Clyde,
would correlate favorably with the parameters utilized for the MerchantiYille
clay at the FLR Landfill. ~
The ability of the middle stratum, the Merchantville:folmation clay, to
maintain the 2 overlying/underlying aquifers as separate units was measured
during this study in terms of a vertical permeability (k). As discussed
in Section 5.1.2, page 5-3 of the Rt report, th~ k value of tKe Merchantville
clay underlying the site averages 1.2 x 10- v centimeters per second
(em/see). Laboratory analysis,of the coefficient of permeability north of the
FLR Landfill site vas 10 x 10- em/sec. These data are limited to vertical
permeability; the relationship of the horizontal permeability to the vertical
permeability can vary throughout a stratum, but may generally be represented
by a translational factor.

For a homogeneous, isotropic.material, kh and k would be the same, or
k /k ~ 1.0 would be appropriate; hoveVer, ~ost formations have a
cRa~~cteristically greater component of permeability in the horizontal
dir,ction as. a result of depositional patterns vhich subsequently control
lateral migration. Literature and experience with the Merchantville Formation
clay indicates an approximate horizontal permeability on the order of 5 times
the vertical permeability. Lateral movement of ground water in the formation
is, hovever, limited by both the soil and depositional characteristics vi thin
the unit. As described in Section 7.1.1.2 of the RI report,
"...the Herchantville Formation materials consisted primarily of a.
greenish-gray to olive-black, glauconitic silty, clayey sand, vith
occasional thin lenses of sand."
Relatively impervious. pockets and thin lenses within the Merchantville
Formation could theoretically transmit water if an outlet were available;
however, ground-water. flow cannot, in general, be transmitted through the
lenses due to t~~ discontinu~ty of t,he Merchantville"utrix.
. t,~.; " ;..: .;. ..
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. '
BL.ACK a VEATCH
New Jersey Department of Environmental Protect~on
Hs. Beth I. Huhler 3
June 27, 1986
The presence of ground water within the Herchantville Formation vas
determined by a review of the physical parameters of the-soil. Samples of the
Herchantville clay were obtained and subjected to physical testing to
determine density, moisture content, particle-size and hydraulic conductivity;
in addition, calculations were performed utilizing recorded water levels to
determine permeability and hydraulic gradients. The Herchantville Formation.
discussion did not elaborate upon ground-water flov or occurrence due to the
lack of ground water detected within the matrix.
2.
Ground-Vater Flov
Commen t :
"Ground vater in the Pleistocene aquifer and Raritan-Hagothy aquifer
is described as moving in a southeast direction. These flov
directions are based on water level measurements taken at the FLR
site only. The Black' Veatch study is deficient in information
concerning the relationship between ground vater flow directions at
the site and the surrounding area. consequently, evaluatfbn!
concerning the impact of the FLa and proposed BCSVHFC on area ground
water flov directions and potential contaminant migration routes
cannot be made." . :~ '-'
Response:
At the FLa Landfill site, several factors influence the ground-vater flov
pattern, such as the proximity of Assiscunk Creek, on-site leachate pumping,
and the hydraulic head on each geologic unit. These factors in addition to
water level measurements observed in each veIl vere considered vhen
determining ground-vater flov. Off-site influences such as major veIl fields
and the BCSVHFC may additionally have an affect on the local hydrologic
regime. The RI report is intended to discuss the near-local pattern of
ground-vater flov; a complete regional hydrologic assessment of the ground
water~ was not performed since the CERCLA program confines the study area to
th~ site and immediate influences.

The regional flow direction toward the southeast in the Raritan aquifer
beneath the site was determined from potentiometric levels in the monitoring
wells. This direction is consistent with previous data developed by Geraghty
, Hiller, with the Voodvard-Clyde data developed for the proposed BCSVHFC, and
with the original pre-pumping regional flov pattern in the aquifer. This flov
pattern has been observed at and near the site during the several recent
investigations (and is supported by the DRAI "Preliminary Investigation");
misinterpretation of this regional flow direction is therefore unlikely.
Near Camden, and at other locations, large pumping troughs have disturbed
the original potentiometric surface and the odgnal flow direction in the,
aquifer. Some small-scale maps depict the trough as extending to the vicini ty"
of the site, but the effects of pumping at more distant centers such as this
are not yet apparent at,' the site. The potential impact of the' Burlington
County_' facility onflov- in"'the ~itan-Hagothy Formation,relates primarily to
a reduced aquifer recharge over" ,the' facility area~' - That aspect has been
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-~----~--------
- --~-----.--~ --- ------ - --
BLACK a VEATCH
New Jersey Department of Environmental Protection
Ms. Beth I. Muhler 4
June 27, 1986
analyzed by Voodward-Clyde in their report to Burlington County. If a
substantial reduction of the recharge was to occur, a flow component from the
FLR Landfill toward the County facility might be expected to originate.
However, the Burlington County facility represents a relatively small portion
of the total recharge area available to the Raritan aquifer, and therefore the
likelihood of a significant depression occurring is remote. The potential for
a depression occurring would be further mitigated by the short-term mounding
effect which could occur during loading of the soil structure with the BCSVHFC
landfill.
3.
Location of BV-4D
Commen t :
"Sampling of deep well BV-4D which was constructed to monitor
upgradient conditions (background) in the deep aquifer indicated the
occurrence of contaminated ground water. In our opinion, this well
is located too close to the existing lagoons to be qualified, as- a
background well. Hounding effects due to the operation of the
lagoons may have caused downward and localized upgradien.t movement of
contaminated ground water recharge." . ,~.
'-'
Response:

The comment poses two questions. If the well reference is incorrectly
stated in the comment; i.e., BV-4S is potentially locally downgradient and
contaminated by the lagoons rather than BV-4D, the RI report describes Black &
Veatch well number BV-4S as regionally upgradient, but locally downgradient of
the site. Two portions of Section 5.3.3 of the RI report describe the
location of BV-4S as follows:
-
,
"A portion of the ground-water flow beneath the wastefill was
diverted beneath the western end of the wastefill. This may be due
to the removal of overburden material beneath a'large portion of the
wastef.ill and replacement wi th low-permeabili ty waste, thereby
creating a barrier to ground-water flow. A shallow surface
depression over the area appears to be recharged by ground-water flow
resulting from the "damming" effect created by the low-permeability
material. It is assumed that this pond receives both surface-water
run-off and ground-water inflow. Downgradient, in the southern
portion of the higher transmissivity zone, the ground-water flow
divides partly toward Assiscunk Creek and the remainder toward Cedar
Lane Extension. The low-permeability zone located near GH-39. and
GM-48 appears to promote this diversion. Based on this analysis,
veIl BV-4S is considered to be located regionally, hydraulically
upgradient of the wastefill, and veIls BV~5S and BV-6S are located
dovngradient of the wastefill."
Ground-vater8ounding beneath the lagoons'~in "this instance "llay indeed'
have an'. effect,:on; :the ability ofvell BV-4S. '. to serve. as an.' upgradien
(background) vell. As described'in ;the".RI, local discharge' from the 1agoon-
could occur through the vadose zone in a radial pattern until intercepted in
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BL.ACK a VEATCH
New Jersey Department of Environmental Protection
Ms. Beth 1. Muhler 5
June 27, 1986
the ground-water 'regime; a .mounding effect could thereby be created which
would permit local; i.e., in the vicinity of the lagoons, flow in a
northwesterly direction (regionally upgradient). However~' upon mixing with
the regional ground water, the direction would reverse to characterize the
regional flow direction. Monitoring in the "mixing zone" could be indicative
of conditions which do not represent regional background. For this reason,
additional off-site monitoring wells are proposed for installation during the
design of the site remediation, and incorporation into the overall site
monitoring system.
The thickness of the Merchantville Formation in the vicinity of wells
BV-4S/D was determined to be approximately 68 feet. Mounding of the Raritan
aquifer at this location, created by surcharge loading of the surface by the
lagoons, is highly remote considering the light applied loads and pressure
distribution with depth. Significant recharge of the Raritan aquifer, through
the Pleistocene deposits and the Merchantville Formation, by the lagoons is
also considered remote since contaminants released by the lagoons would be
intercepted, diluted and transported by the shallow aquifer, thereby
minimizing the contaminants available for further vertical percolation.- The
increased hydraulic head applied by the mounding in the shallow aquifer, in ~n
area in which the Pleistocene deposits are thin (on the order of 10 feet in
thickness) would be minimal, resulting in a limited verti~al migration
potential through the Merchantvill~ Formation; this increasid head would most
probably be offset by the relatively greater thickness of the Merchantville
Formation in this area. Contamination noted in the ana\ysis of samples from
BV-4D is therefore considered to be generated by off-site, upgradient sources.
Monitoring well BV-4D is considered to represent regional upgradient
conditions in the Raritan aquifer, as stated in Section 5.3.3 of the RI
report:
"potentiometric surface maps of the Raritan aquifer were constructed
based on water-level measurements. The elevations of the water
surface ranged from -3.0 feet Mean Sea level Datum (msl) near the
leachate lagoons to -6.0 feet msl. The potentiometric contours
~consist . of nearly straight lines with equal interspacing indicating
'flow direction toward the southeast. In a regional sense, well BV-4D
is therefore located hydraulically upgradient of the wastefill, and
well BV-6D is located downgradient." .
As stated previously, additional upgradient wells, to be installed during
design phase, will be intended to verify this assertion.
the
4.
Transmissivity of the Merchantville Formation
COllUlen t :
"The evaluations' are deficient in data pertaining to water level
response in the Merchantville Formation during the tests. This data
is necessary forquantitification of the amount of.~round vater .and ..
subsequent.. rou.tes. of.. potential.. . contaminants . 'released.. .to . the."""
, Rar! tan-Mago.thy . aquifer:under 'PUllpiq' condi dons (i!.I~ 'fro." gYound
wa ter supply.. wells) . " .
..
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BL.ACK a VEATCH
New Jersey Department of Environmental Protection
Hs. Beth I. Huhler 6
June 27, 1986
Response:

Vater level responses were not observed in the Herchantville Formation as
the purpose of the pump tests in the deep wells was to ascertain the hydraulic
characteristics of the Raritan aquifer at these locations. Other techniques;
e.g., literature search values and laboratory testing of relatively
undisturbed samples for permeability and particle-size characterization,
rather than in-situ, full-scale pump tests were employed to determine the
hydraulic characteristics of the Herchantville Formation.
5.
Drawdown Effect
Commen t :
"Black & Veatch indicate that no effects of pumping in
the Raritan-magothy were observed in the shallow aquifer. A positive
response would be indicative of the potential for downward ground
water movement and subsequent potential contaminant movement. A
deficiency in this interpretation is that it is possible that the
duration and rate of testing" were too low to cause sufficient amounts- -
of ground water movement during the short testing period. Black &
Veatch indicate that a "significant recharge effect" w.s observed
during the testing of wells completed in the Raritan-Hagothy
Formation. This affect may 'be' the result of ground-water being
released from the overlying Herchantville Formation which has been
characterized by Black & Veatch to be of low permeability and an
effective barrier to downward contaminent movement, but also a source
of recharge."
Response:

The Raritan aquifer is one of the major potable water resources for the
New Jersey coastal plain; many of the domestic and municipal well fields in
the area~withdraw water from this aquifer. Since the available yield in the
Raritan aquifer is significant, the small-scale, limited pump tests conducted
during the RI(FS placed a localized, and therefore inconsequential overall
demand on the aquifer system. Unless the aquifer was sufficiently stressed so
as not to be readily recharged, thereby developing a suction head on the
overlying "erchantville Formation, flow through the Merchantville Formation
clay would necessarily be driven, and limited by the physical characteristics
of the formation such as permeability and the gradients applied by the
overlying strata. Since it is not reasonable, in an investigation of this
type, to stress an aquifer with such a significant yield as the Raritan, the
duration and rate of pumping in these tests should have no impact on the
transmission characteristics of the overlying Herchantville Formation.
6.
Transmissivity Values
Cooen t :
"Many of the 'as suap t ions: inherent in the methods of analysis used to
evalua'te the aquifer 'bydraulics,:t'estiq'"data:are.;,violated.due 'to'
their application to observations made solely in pumped' wells.
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..
BLACK a VEATCH
New Jersey Department of Environmental Protection
Ms. Beth I. Muhler 7'
Junt! 27, 1986
Consequently, the transmissivity values obtained from the evaluations
are subject to error. The transmissivity values obta~ned by Black &
Veatch for the Raritan-Hagothy formation are consistently lover
(greater than an order of magnitude) than those reported by the USGS
(Gill and Farlekus, 1976). Using lower transmissivity values might
lead to a false sense of safety in determining if a pumping well,
which was completed in the Hagothy-Raritan aquifer near the site,
could be affected by potential contamination."
Response:

Pump test data from the 3 deep wells were interpreted using standard
analytical techniques (Theis and Jacob for drawdown and recovery periods).
The pump test set-up; i.e., single-well, limited test duration, may b~ debated
as to the level of accuracy produced, but the interpretation represents an
appropriate application of the technique vithin the bounds of the test set-up.
The pump test results indicate that the transmissivity and hydrsulic
conductivity values varied by over an order of magnitude for the tested
sections of the 3 vells. Such variability is consistent vith the lithology of
the sections. The reported "recharge or discharge" effec~~ apparent for the
- test curves were logically interpreted as manifestations of the lenticular
character of several horizons, an observation also indicated by geologic data.
In addition, as only the upper 20 feet of the aquifer section vas tested, the
values obtained should not be interpreted as representative of the entire
aquifer section. Also, any comparison of the site-specific values of the
aquifer parameters with the "regional" values can be made only if the aspects
of variability and position of the test section are considered.
7.
Domestic Vell Contaminant Source
Commen t :
"The study indicates the occurrence of numerous landfill affiliated
~contaminants in ground water at the FLR site. The Black & Veatch
study initially states that methylene chloride vas the only
contaminant detected in sampled domestic vells located upgradient and
dovngradient of the site. The levels detected are reported by Black
& Veatch to be significantly less than the suggested USEPA health
advisory criteria. Black & Veatch indicates, further on in the
study, that other contaminants (Acid Base Neutral Compounds) vere
found in the majority of the domestic vells sampled. The ground
vater quality in the area of the site is qualified by Black & Veatch
as "good". No definitive statement is made concerning the sources'of
the detected compounds."
Response:

The concentrations of methylene chloride in do.estic vell vater sample.s;-, ..'
while. significantly., lover tban health advisory,standards, , vere exhibited iri"'"
, higher leVels and detected:.:,lIOre'frequently ':, than ;the' 'acid extractable or
base/neutral, compounds... Due to a lack of existing cri teria, standards ,or
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BLACK. VEATCH
New Jersey Department of Environmental Protectio~
Hs. Beth I. Huhler 8
June 27, 1986
advisory levels. for the compounds detected which fall within the acid
extractable or baselneutral fractions, specific comparisons and statements as
to the water quality cannot be made; no definitive statement was therefore
offered regarding the potential for health hazard. Bowever, based upon the
number, types and levels of contaminants present, and consideration of areal
background and anticipated levels, the overall water quality vas characterized
as good.
In response to the comment that "no definitive statement is made
regarding the sources" of these compounds detected, a variety of possible
sources could be considered. Several sources potentially contributing to the
acidtbase/neutral compound levels detected include: other land disposal
operations in close proximity (several of which are under investigation by the
USEPA/NJDEP at the present time); other commerciallindustrial operations; and
agricultural sources. In addition, the mere installation of domestic veIls has
a history of being a primary contributor of phthalate compounds in veIl water
due to the construction components of the veIls. Contributions by the above
sources are beyond the consideration of the FLR Landfill RIIFS activities,
vhich are intended to identify contaminants in the vastefill and the extent,
if any, of their migration, but not the identification of external
contaminants and sources.
8.
Domestic VeIl Sampling Protocol
: -. '...~
Commen t :
"It does not appear that Black & Veatch compiled well logs for the
domestic wells which were sampled during this investigation. In
addition, the protocols for domestic veIl sampling are not presented
in the RI."
Response:

A search of records maintained by the NJDEP, Division of Vater Resources
vas conducted at the outset of the FLR Landfill RIIFS studies. This search
vas ;intended to identify and assimilate data on domestic wells within a 1.0 -
mile;radius of the site. (A copy of the data obtained for the domestic veIls
is attached to this letter.) Based upon this data, prior sampling locations
and information developed during previous studies, and intervievs vith
residents in the area, the 20 domestic veIl locations vere jointly identified
by USEPA/NJDEP and Black & Veatch. These locations vere selected as
representing a variety of conditions, such as aquifer tapped, location in the
aquifer with respect to the FLR Landfill site, availability of sampling
points, and sampling history, and vere authorized by the appropriate owners.
The sampling of the domestic veIls vas performed in accordance with both
NJDEP and USEPA sampling procedures, as described in the Black & Veatch.
Engineers-Architects, Field Sampling Plan for the Florence Land Recontouring
Landfill site,.dated.May 17,1985. All samples were collected from that point
in closest proximity to the veIl, and most. accessible. Strict
decontamination.:;surp!e, pawling and handling, andchain-of-custody protocols
vere 'exercised during the. execution of this task.. . .
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BL.ACK a VEATCH
New Jersey Department of Environmental Protection
Ms. Beth I. Huhler 9'
June 27, 1986
Prior to sample collection, water was evacuated from the point source for
.15 to 30 minutes to flush residual contaminants commonly 'butlt-up in domestic
plumbing. The location of each point source varied dependent upon domestic
well availability. In addition, care was taken to avoid water treatment
systems such as softeners so as not to introduce any "new" constituents which
could affect the ionic conditions in the water. The specified locations of
each point source where a domestic well water sample was obtained is specified
in Table 1. The locations of each source point was a factor considered during
the evaluation of final analytical data.
9.
Data Restrictions
Commen t :
"It is strange that
program, devoted one
to the quality and
investigation. "
Black & Veatch, after their 'extensive' sampling
section of the RI (Section 10.0) as a disclaimer
reliability of the analytical results of their
Response:

Section 10.0 of the RI does not offer a "disclaimer ~o,the quality and
reliability of the analytical results..."; this section discusses the bounds
of reasonable extrapolation and limitations imposed by the data assimilated
from this and prior investigations at the site. As with any scientific study,
findings and conclusions can only be drawn from valid datapoints, and
reasonably extended from representing a specific situation to characterizing a
general finding. Vith increased datapoints, reliability is increased through
repetitive, replicating data; i.e., the hypothesis is verified. Broader-based
data also extends the ability to laterally extrapolate general findings with a
reasonable assurance of accuracy. This discussion of scientific method is
addressed for the FLR Landfill RIIFS in Section 10.3: Qualifications on the
Remedial Investigation, the first paragraph of which follows:
."Any site investigation is based upon a limited amount of data, from
;which judgment must be applied in order to characterize the site.
Every investigation could generally benefit from the collection of
additional field data, in the form of additional test borings,
monitoring stations, analytical data points, etc., but this is
neither practical nor cost effective. Vith this understanding,
reasonable and prudent judgment must be utilized in assessing the
data available. Therefore, while additional data would be useful in
verifying the conclusions in this remedial investigation, the level
of data has been sufficient to draw reasonable conclusions. Howev~r,
in examining these conclusions, it is prudent to appreciate the
reliability of the results; therefore, several qualifications of the
remedial investiaation are presented in this. section." .
This section of the RI was incorporated in the interest of full.
disclosure of. the basis upon which conclusions vere drawn . during" the FLR.
Landfill.llII.FS~" No .'. state.en~: is intended... to.; imply. that.. the . conclusions" .
presented in tl.'e RIIFS are not support eeL by the data collected, :"or that the
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BLACK a VEATCH
Sample
Identification
GV-DV09
GV-DVI0
GV-DVll
GV-DV12
GV-DV14
GV-DV16
GV-DV17
GV-DV19
GV-DV22S
GV-DV22D

GV-DV50
GV-DV51
GV-DV52
GV-DV53
GV-DV54
. GV-DV55
GV-DV56
GV-DV57
GV-DV58
GW-DW59
-
,
..
'Table 1:
Domestic VeIl Locations
Ovnerl
Residence
. Location of 'Point Source
Vorrell
Roche
Roche
Borton
Burnett
Conlov
Moska
Lovenduski
Marshall
Marshall
Front faucet on right side.
Faucet on rear side.
Faucet on left side of garage.
Faucet on rear, near porch.
Faucet in rear.
Faucet in rear on right.
Open vell in front yard.
Bose faucet on south side.
Faucet in rear on right side.
Dug veIl (cistern) in yard on
right side.
In a shed laundry spigot.
Faucet in rear on left side.
Faucet on south side.
Utility sink in garage.
Faucet in front.
Faucet in front on left side.
Dug vell (cister:n),:.'in front
yard. ,.
A line from a 50-gallon holding
tank.
In house, bathroom faucet.
Faucet in rear on right.
Miller
Freck
Hall
. Cummings
Heise
Rule
Neindorf
Commercfo
Haragalino
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BL.ACK a VEATCH
New Jersey Department of Environmental Protection
Hs. Beth I. Huhler 10'
June 27, 1986
study findings are not reasonable interpretations based upon the data
-developed. The- laboratory data qualifications do, '. however~ present
limitations, or gaps, which should be eliminated by supplemental information
to be collected to verify and reconfirm the data upon which remediation
decisions have been made. The acquisition of this supplemental information was
subsequently addressed in the feasibility study as a design, implementation,
and operational requirement for broad-ba~ed monitoring programs.
General Comments
The conclusion of DRAI is that "the RI/FS is deficient in its treatment
of the impact on regional hydrogeology, water resources, and water quality".
In support of this opinion, "a cursory evaluation as conducted by ORAl of the
regional hydrogeology and its interaction with the FLa is presented in (as)
Attachment I". Attachment I, entitled "Preliminary Interpretation of the
Regional Hydrogeology in the Vicinity of the FLa Landfill", summarizes
existing well data collected from a records search for wells in Hansfield
Township. These wells ,exhibit a geographic centroid at a distance of
approximately 2.25 miles from the FLa Landfill site. Three wells in Flo~nce
Township, near the township line, and 3 deep wells on the FLa landfill site,
installed during the 1982 Geraghty & Hiller investigation are also
incorporated. Two concentrations of these wells are addresse~~as a focus of
the study; one west of Columbus, at an approximate distance of closest
approach of 1.4 miles from the FLR Landfill site, and the other in Columbus,
at an approximate distance of 2.6 miles from the si~e. Vhile definite
boundaries cannot generally be defined for the area of influence of a facility
such as the FLa Landfill, a 1.0-mile distance - is considered reasonable. This
radius from the FLa Landfill, and the domestic wells surveyed within that
approximate boundary during the RIIFS, are presented on Figure 1. It should
be noted that only 4 of the ORAl domestic wells fall within the l.O-mile
boundary.
The ORAl "cursory evaluation" further presents isopleth mapping of the
"shallow aquifer ground-water elevation", the "deep aquifer potentiometric
surface ~levation", and the "elevation of top of Voodbury Formation". These
inter~retations are based upon the domestic well data presented previously.
These )nterpretations may indeed be reasonable and representative of the study
area; however, the study area only peripherally includes the FLa Landfill.
The shallow aquifer map is based upon an effective total of 5 data locations,
only one of which is within 1.0-mile of the FLR Landfill site. Extrapolations
of the ground-water surface in the vicinity of the FLa Landfill are therefore
without adequate basis. Vhile flow is indicated across the FLa Landfill site
toward the northwest, conflicting data from the RI/FS and other sources near
the site have not been incorporated, as is evidenced by equipotential lines
with an elevation of +40 feet, mean sea level (msl) datum crossing Assiscunk
Creek at a point where the free surface-water elevation in the creek is
approximately elevation +15 feet msl. In general, the development of a
: ground-water surface map for this large area based upon 5 data points is not
- reasonable, particularly since the surface is, in large measure,
topographically controlled.
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~
I
DOMESTIC WELL SAMPLI~G LOCATIONS
- ~ & v.!..m
.... AIt.h.'..'I
Florence La,
!lecontouring Landfill
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. .
. .
BL.ACK a VEATCH
New Jersey Department of Environmental Protection
Hs. Beth I. Huhler 11
June 27, 1986
. The ORAl potentiometric surface map for the deep aquifer is in essential
accord with the conclusions of the RIfFS. Since a Voodbury'~ormation surface
isopleth was not prepared for the RIfFS, no comparisons are appropriate in
this regard. Therefore, in summary, while the ORAl data and interpretation in
those areas which have adequate datapoints may be correct, extrapolation of
this information beyond the fringe of the study area is not warranted, and
therefore not reliable. As evidenced above, such extrapolations represent
conjecture at best. The interpretation of the shallow aquifer flow aside, the
"cursory evaluation" is considered to support the overall conclusions of the
RIIFS.
Ve trust these responses are adequate within the
additional discussion is available if so warranted.
questions, please do not hesitate to contact us.
Very truly yours,
given time-frame;
If you have any
. Lawrence Hosmer
seb
At tachments
-
.
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---- ----_._-~._-~----.~----~~---- --- -
MARWAN M $AOAT, P E
DIRECTOR
. .....:.."...,,~....
t,lt'~ ~{" -

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'hlte of ~ew Bersey

,DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT "
HAZARDOUS SITe MITIGATION ADMINISTRATION
CN 028. Trenton, N,J, 08625
14 M~.., ~
JORGE H, 8ERKOWITZ, PM 0
ADMINISTRATOR
~MORANDUM
MAY 1 3 1986
, TO:'
T~OUGi:
BETH t4H..ER, Si te Manager, 85M ..
FROM:
SlSJECT:
,'"

MARJA VAN OUWERKERK, Assistant Chief, BEERA'Y''\\t \.:

ANNE DECICCO, Technical Coordinator, BEERA AD '

FlORENCE L~ND RECONTOURING LANDFILL: QUALIFICATIONS ON THE
RI/FS DATA'
.,
As you are aware, finalization of the Remedial Investigation/
Feasibility Study for the subject'site has been delayed due to the numerous
laboratory qual! ty assurance issues surrounding the chemical analytical
results of this study. ETC Corporation performed the majority of the
analytical work on this project. On April 9, 1986, a meeting was held to
discuss these qual! ty assurance issues with representatives from NJDEP,
Black &: Veatch (prime contractor) and ErC Corporation in attendance.
During the meeting, ETC was presented with a list of outstanding quality
assurance items to address, which had been prepared by Tien-Nye Vaccari of
the DWM - Office of Quality Assurance. These items were presented to ETC
in anticipation that ETC could provide additional information in order to
reduce the number and type of qualifications on some of the data. Through
an April 24, 1986 letter to Lawrence Hosmer, B&:V, ETC provided a response
to these items. Based on a review of the ETC response with Ms. Vaccari,
OQA . (in a meeting on May 5, 1986), the final quall f1cations on the
analytical results for this site were outlined and are provided in
Attachement 1. Air data has not yet been submitted for review, therefore,
it has not been included here.
. ,. .,
.~
As a forward conment, .the outstanding QA issues primarily include
exceedance of sample holding time for volatile organic and base/nuetral
extractable fractions in some of the samples and trip/field blank
contamination (methylenephloride and Phthalates)., ,

In general, the data provide a good representation of the quality of
the matrices sampled, however, due to the qualifications noted in
Attachement 1, in some cases, the contaminant values reported are not
exact."
N,", J"s,>, /s An Equal 0ppor/unity £/Ilp/I))'"
-------
. "
Attachment 1
'.
Provided below are non-correctable quality assurance issues" which have
resulted in usable yet qualified data:

Batch 1 -- Surface Water and Sediment Samples
For surface water samples, all data are acceptable except for the acid
extractable fraction of SW-04-0l. It should be noted that SW-03-02 was
also unacceptable, however, a duplicate of this sample, SW-03-02, has been
validated and is therefore usable.
For the" sediment samples, the following problems remain unresolved,
thereby resulting in a high qualification of the data.
PROBLEM
VO exceeded holding times (-25 days)
SAMPLES AFFECTED

SSE-07-0l, SSE-02-D2,
SSE-02-0l, SSE-Ol-Ol;
SSE-04-Ql

. , .
a.
. .
b.
B/N/A exceeded holding times. (1 month)
Same as above.
c.
Method blank contamination (phthalates)
Same as above.
d.
Wrong method for TCDD analysis
SSE-02-0l, SSE-OI-Ol,
SSE-03-0l
Batch 2-7, 15 -- Soil Samples/Borings 4,5,6

All data are acceptable, however, several problems are noted below,
therefore, the data is qualified.
PROBLEM
SAMPLES AFFECTED
SSO-B04-02
XF'B-09l0-5
SF'B-09l2-5
-
a. . VO exceeded holding times (-24 days)
b.
B/N/A exceeded holding times
S5O-B04-02
S5O-B04-03
S5O-B04-04
c.
Contaminated FB & TB (Mel)
Batch 2,4,5"
Regarding methylene chloride (Mel) contamination in the trip and field
blanks, this problem was project-wide and should be addressed as an
overall forward comment when describing the results of this study.
-------
- -----_._~_._-_._~--_.- --.._-----._---
d.
Internal standard not detected in
method b l.i/1 II.
'.
XTB-09l0-S
SF'B-09l2-S
STB-09l2-S
Batch 19 -- Shallow MonitorinQ Wells BV-45. 55. 65
All data are acceptable, however, the following problems are noted:
PROBLEM
SAMPLES AFFECTED
WF'B-1l20-W
WFB-1120-W
a.
VO exceeded holding times
b.
Surrogate recovery outside of limits
WFB-1l20-W
WTB-1l20-W
WGW-BV45-0l
Batch 20 -- MonitorinQ Well BV-40 and GM-45
All data are acceptable, however, the following pro~l~.is noted:

'"
PROBLEM
SAMPLES AFFECTED
FB-1l25-W
TB-1l25-W
a.
Contamination in TB & FB (phthalates)
Batch 21 -- MonitorinQ Wells BV-50. 60
All data are acceptable, however, the following problems are noted:
PROBLEM
SAMPLES AFFECTED

WGW-BV5D-Ol
WGW-BV60-0l
WTB-1125-W (7 days)
a.
yo exceeded holding times (1-2 days)
-
,
b.
Contamination in TB & FB (Mel & phthalates)
WTB-1125-W
WFB-1125-W
Batch 22 -- Waste-fill MonitorinQ Wells BV-15. 25. 35
All data are acceptable, however, the following problems are noted:
PROBLEM
SAMPLES AFFECTED
WGW-BVIS-Ol
a.
B/N/A exceeded holding times

Surrogate recovery outside of control.limits...
(attributed ,to, sample matrix) ,
WGW-BVIS-OI
WGW-BVlS-OlR .
WGW-BV35-0IR. '
, '
b.
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.
.
. .
Batch 24 -- Domestic well sam les (11 total) lus GM-40

All data are acceptable, with the exception of the va fraction for 6
wells which had exceeded holding times. These wells have been resampled
and analyzed for VOs only and.are also acceptable.
PROBLEM
va exceeded holding times (6-7 days)
SAMPLES AFFECTED

WGW-DW17-02
WGW-DW22D-02
WGW-DW16-02
WGW-DW55-02
WGW-DW54-02
WGW-DW56-02
WTB-12l0-W
a.
Wi th regard to the resampled potable wells, only a Tier II data
package was submitted to NJDEP. All the backup information required
for a Tier 1 package will have to be submitted in order. fG1; these
. sample results to be approved. '-

Batch 25 -- Domestic wells
All data are acceptable except for the VO fraction of WGW-09-02.
However, since this sample had a duplicate, WGW-09-03, which was accepted,
no serious qualifications have resulted.

Batch B. 13. 16. IB Soil Samples
All data are acceptable,
days) for Batch B.Since
acceptab~e yet qualified.

.
however, va holding times were exceeded (13
these are soil samples, the results are
HS6B/km
c:
Dr. Merry Morris
Tien-Nye Vaccari, OQA
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Attac~nt A
;.
..
'.
\- .\
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"
NEW JERSEY DEPARTHENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
'.
Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
Focus Feasibility Study
at the
Florence Land Recontouring Landfill Site
Florence, Mansfield and Springfield Townships
Burlington County
Thursday, May 2, 1985
7:00 p.m.
Florence Township Memorial High School
Auditorium
Front Street
Florence, NJ
AGENDA
1.
Opening Remarks;
Introduction of NJDEP personnel.
. , -,
.
Dr. Jorge H. Berkowitz~
Administrator
Hazardous.Site Mitigation Administration
NJDEP
2.
Community Input
Ms. Grace L. Singer, Chief
Office of Community Relations
NJDEP
3.
Overview of Past History
and Current Situation;
Introduction of Contractor:
Black and Veatch Engineers -
A"hitects

,
Ms. Beth Muhler, Site Manager
Bureau of Site lanagement
NJDEP
4.
Presentation: 'Remedial
Investigation/Feasibility
Study
Mr. Lawrence J. Hosmer,
Project Officer
Black and Veatch Engineers - Architects
s.
Questions and Answers
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- --'-'--.--- ._--~_._- -----~_._~- - - -
~~ .
.'..
. ."".".
- .'
., .
STATE OF NEW JERSEY
DZPARTXENT or ENVrROH'XENTAL PROTECTION
FACT SHEET
'.
on
Commencement of
Remedial Investigation/Feasibility Study
Focus Feasibility Study
at
Florence Land Recontouring Landfill Site
Florence, Mansfield and Springfield Townships
Burlington County
May 2, 1985
Site Description:
The Florence Land iecontouring Landfill, covering 29 acres in a mixed
residential and agricultura~ area, was operated as a disposal facility from 1973
until 1981. During this time, the landfill was permitted to accept sanitary and
industrial waste, including septage and sewage sludge. (For approximately one
year during this period, the site was identified as JEMS and. operated by Jersey
Environmental Management Services.) '- .
Although a leachate collection system exists at the site. excessive levels of
leachate have been found within the landfill. Surficial' leachate seeps have
been observed near the banks of the Assicunk Creek which is used for recreation
and irrigation. Ground water sample results indicate the presence of volatile
organic' compounds in the shallow aquifer. There is a possibility of
contamination in the deeper Kagothy-Raritan aquifer. which is the primary ground
water source for the local community. Similarities of chemical constituents
were found in the landfill leachate and in some private wells. There are
approximately 16 public wells and over 1.800 private wells within a three mile.
radius of .the site. Preliminary air monitoring has indicated the presence of .
volatile organics emanating from manholes and monitoring wells at the landfill.
Vents ~qu1pped with carbon filters were installed in order to control air
em1ssiqns; however, there is some question regarding the adequacy of these
measures.
Backaround

A Consent Judgement was issued by the New Jersey Superior Court in January, 1979
to close the landfill. In July. 1981 Florence Land iecontouring submitted a
closure plan and the operation terminated in November, 1981.
A Cooperative Agreement was signed by the United States Environmental Protection
Agency and the New Jersey Department of Environmental Protection on Karch 28,
1984, providing funds in the amount of $434.225 to conduct a Focus Feasibility
Study and a Remedial Investigation/Feasibility Study (RI/FS).
Of 97 New Jersey"sites" on the National Priorities':Urt," the' norence Land,'.
ReCDntour.1Da,..Landf1l1.a1te,,1.~ united 10th. in priority.,'.,.,
over. . .
-------
3
.
What is "Superfund"?
Superfund is the common name for the Comprehensive Environmental Response.
Compensation and Liability Act enacted by Congress in Decem1?er 1980.. The Act
authorizec the United States Environmental Protection Agency (USEPA) to provide
long-term remedies at hazardous waste sites. The Act established a $1.6 billion
fund. raised over five years (ending in 1985) from special taxes and general
revenues. to accomplish the cleanup of these sites.
What is the National Priorities List (NPL)?
The NfL is a list of the highest priority releases or potential releases of
hazardous substances. based upon State and EPA Regional submissions of candidate
sites and the criteria and methodology contained in the Hazarc Ranking System
(HRS). for the purpose of allocating funds for remedial response. Published by
USEPA. the NfL is updated periodically.
What is a remedial investigation?
A remedial investigation involves field activities for collecting information rb
make decisions in controlling contaminants. The investigation usually includes
sampling and analysis of ground water. surface water. soils. aJld '. bther natural
and man-made substances for the presence of contaminants.
What is a feasibility study?
A feasibility study is an evaluation of alternative remedial measures for
controlling the contaminants and selection of the most appropriate alternative.
-
,
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
'.
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup at hazardous waste
sites, a Community Relations Program is conducted to receive local input and
to advise local residents and officials about the planned remedial actions at
the three major stages of the cleanup: 1) remedial investigation/feasibility -
study 2) engineering design and 3) removal/treatment/construction. Local
briefings and meetings are conducted with elected officials and residents and
generally take place at:
1)
The commencement of a remedial investigation/feasibility st~dy so
that local concerns can be addressed early in the process.
2)
The completion of a feasibility study to disc~ss, ,'~he alternative
courses of remedial action. There is a 30-day cb=ment period after
public presentation of ' the alternatives during which the feasibility
study is available in local repositories.
3)
The engineering design stage to carry out the mandates of the
selected remedial alternative.
4)
The commencement of the removal/treatment/construction stage to
advise of the expected physical remedial action.
5)
The completion of the remedial action.
I~ addition to the activities outlined above, there is generally
ongqing communication with local officials and residents as required.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a aite, community relations activities are conducted by
the relevant State or Federal agency.
In New Jeraey, the DEP Community Relations Program is directed by Grace
Singer, Chief, Office of Community Relations (609) 984-3081. At Region II,
EPA, the contact person ia Lillian Johnson, Community Relations Coordinator
(212) 264-2515.
BS45:j.'
4/85.
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(1)
Site Identified
and Referred
:
(5)
Prioritization
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(2)
Initial Site Investigation
(6)
Determination of Lead
(10)
Preparation of
Feasibility'
Study
(14)
Cleanup Evaluation
New Jersey Department of Environmental Protection
.5/84
(3)
(4)
Secure Site
Site Analysis Evaluation
and Assessment
(7) (8)
Community Relations Signing of Contract' or 
Plan Activated Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
 "
Action Alternative for Engineering Design
(15)
Contractor Audit and
Close out
.
.,...
-------
:
Attachment B
;.
.'
'.
. .
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~EW JERSEY DEPARTMENT OF ENVIRONNENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADHINlSTRATION
Public Meeting to DiscusS Commencement of
Remedial Investigation/Feasibility Study.
at .
Florence Land Recontouring Landfill Site
Florence, Mansfield and Springfield Townships
Burlington County
Thursday, ~~y 2, 1985
~iA..£.,..

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126.
AFFILIATION
ADDRESS
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-------
;
--
Attachment C
<.
..
'.
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--NEW JERSEY DEPARTMENT OF ENVIRO~~ENTAL PROTECTION
. DIVISION OF HAZARDOUS SITE MITIGATION
'.
Public Meeting
on
Completion of
Remedial Inve-stigation/Feasibility Study (RI/FS)
at
Florence Land Recontouring Landfill Site
Florence, Mansfield and Springfield Townships
Burlington County
Thursday, June 12, 1986
7:30 P.M.
Fountain of Life Center
Columbus & Old York Roads
Florence, NJ
AGENDA
.. '...'
',-
1.
Opening Remarks;
Introduction of NJDEP Personnel
and Contractor:
Black & Veatch/Engineers-Architects
Mr. Anthony
Division of
Farro, Assistant Director
Hazardous Site Mitigation
2.
Community Input
Ms. Grace L. Singer, Chief
Office of Community Relations
Division of Hazardous Site
3.
Overview of Past History
and;Current Situation
. .
,
Ms. Beth Muhler, Site Manager
Bureau of Site Management
Division of Hazardous Site
4.
Presentation:
Remedial Investigation/
Feasibility Study
Mr. Lawrence J. Hosmer, Project Officer
Black and Veatch/Engineers-Architects
5.
NJDEP Recommended
Alternative
Mr. Robert Predale, Chief
Bureau of Site Management
Division of Hazardous Site
6.
Comments and Questions
The floor will be open
and questions at this time.
..
Mitigation
Mitigation
Mitigation
for
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--~~---
---------
. 0
,
.
STATE OF NEW JERSEY
DEPARTMENT 01' ENVIRONMENTAL PROTECTION
'.
.
Fact Sheet
on
Completion of
Remedial Investigation/Feasibility Study
at
Florence Land Recontouring Landfill
Florence, Mansfield and Springfield Townships
Burlington County
June 12, 1986
Site Description: The Florence Land Recontouring Landfill (FLR) is an inactive
site covering 29 acres in a 1IIixed residential and agricultural area where
Florence, Mansfield and Springfield Townships merge. FLR operated as a licensed
municipal landfill from Novembe~ 1973 until November 1981. During this time, the
landfill was permitted to accept sanitary and industrial waste including sept~ge
and sewage sludge. (For approximately one year during this period the landfill-
was identified as JEMS and was operated by Jersey Environmental Management
Services.) :, '.'
Although a leachate collection system exists at the site, concern about the
system's adequacy has been expressed through the years. Surface leachate seeps
have been observed sporadically near the banks of the Assicunk Creek which is
used for recreation and irrigation. Ground water sample results have indicated
on-site contamination by volatile organic compounds in the shallow Pleistocene
Aquifer. The potential for contamination of the deeper Magothy-Raritan Aquifer,
which is the primary local ground water source, has also been a concern. The
largely rural/agricultural area contains approxi1llately 16 public potable wells
and over 1,800 individual potable wells within a three-mile radius of the site.
Air monitoring has indicated the presence of volatile organic gases' emanating.
from manholes' and monitoring wells at the landfill. Vents equipped with carbon
filters wete installed by Florence Land Recontouring, Inc. in ~rder to control
air emissions; however, there is some question regarding the &dequacy of these
measures due to lack of ownership ..intenance.
Background: A Consent Judgement was issued by the New Jersy Superior Court in
January 1979 to close the landfill due to the site's history of enviromnental
problems. Florence Land Recontouring, Inc. terminated operations in November
1981.
A Cooperative Agreement was signed by the United States Environmental Protection
Agency (USEPA) and the New Jersey Department of Envir~~~n~a\ Protection (NJDEP)
on March 28, 1984 providing funda in the amount of'~~42.445 to conduct a Focus
Feasibility'Study and a Remedial Investigation/Fea8ibil.~y Study (RI/FS).

Status: A Draft Feasibility Study' vaa completed in May 1986 and the remedial.
. action. altematives. .are pr..ently. being evaluated by.IIJDEP. and. USEPA. . . The
,uhlic!',eammnt-':pel'iDd,' .nding'..em". J1I1I8-:-23.~ v....anncnmcad.:, Oft Hay':.:.l9.; 1986. '..The','.
Lraft Feasibility Study has been available aince May 19 at the following
l'epositorie8:
:'\'C'''' J~r'~1' I.~ ..." £qlUll OppllrlUflil1' l::mpl'J.I'~r
over.. .
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------ ------ ----------- ---~'"""",- ------~--- ----
-3-
11.
Summary of Feasibility Study Results:
A.
Principal Remedial Response Objectives:
'.
.
Mitigate downgradient, off-site ground water contamination.
Mitigate off-site, surface water run-off contamination.
.
.
Mitigate off-site, air contamination.
.
Mitigate the potential for health hazard exposure.
Principal Remedial Alternatives for Long-Term Site Remediation:
B.
Alternative 1 - No action except to complete the implementation of Initial
Remedial Measures (fencing and continued long-term environmental monitoring
program).
Alternative 2 - Upgrade .and refurbish surface water run-off controls;
improve the leachate management system; replace carbon filters on manholes
and maintain these, as required; remove on-site debris and structures and.
continue the long-term environmental monitoring program. '
. '.."
.
Alternative 3 Incorporates a .leachate management system similar to
Alternative 2, with the addition of a circumferential slurry barrier wall;
the installation of a composite synthetic membrane/clay cover; the
installation of a new surface water control system; use of a passive gas
collection system and continue the long-term environmental monitoring
program.
Alternative 4 - Use of the current leachate mana~ement system, augmented
with extraction wells for leachate removal; off-site disposal of leachate;
installation of a new synthetic cap over the wastefill; improvement of the
surface water run-off system; use of an active gas extraction system with,'
disposal at the Burlington County Solid Waste Management Facility Complex'
and cQnttnue the long-term environmental monitoring program.

,
. .
Alternative 5 - Alternative 5 i8 similar to Alternative 4 with the addition
of a partial .lurry wall along the upgrad1ent side of the wastefUl (to
reduce leachate quantities generated).
Alternative 6 - Alternative 6 i8 similar to Alternative 5 with the addition
of on-site pretreatment of leachate and the implementation of an on-site
incineration facility.

Alternative 7 - Alternative 7 is similar to Alternative 6 with the addition
of a complete leachate treatment system; it incorporates the partial slurry
vall of Alternatives 5 and 6 and incorporates poth on-site leachate and gas
treatment plants.
For further' information, 'or' if you-have any que8tlona,'.:eoutact 'Jeffrey, Folmer.of, ,
NJDEP.' s Oii~~ of. COIIIIUmity Relations a~ (609} 984-3081..
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Glossary of Terms
Administrative 'Consent Order (ACO): A binding legal doc~~ent between a
government agency and a responsible party. It is issued by the
government in the form of an order that specifies site mitigation
activities to be undertaken by the responsible party.
Contract: The legal agreement that outlines federal and state
government responsibilities at USEPA-lead sites on the National
Priorities List (Superfund sites) as authorized by the Comprehensive
Environmental Response. Compensation and liability Act (CERCLA).
Cooperative Agreement: An agreement whereby USEPA transfers funds and
'other resources to a state for the accomplishment of certain remedial
activities at sites on the National Priorities I.lst (Superfund sites)
as authorized by the Comprehensive Environmental Response. Compensation
and Liability Act (CERCLA).
Engineering Desi~n (Remedial Design): Following a
an engineering design is executed to translate the
accordance with e~gineering criteria in a bid
implementation of the site remedy.
feasibility study.
selected remedy ia..
package. enabling
.
.
Focused Feasibility Study (FFS)~. A limited feasibility study which is
performed on a certain aspect of site remediation and/or when more than
one remedial measure is considered technically viable for the immediate
control of a threat
Immediate Removal Actions (IRAs):
immediate and significant risk
environment.
Actions taken to prevent or mitigate
to human life. health or to the
Initial Remedial Measures (IRMs): Actions that can be taken quickly to
limit exposure or threat of exposure to a significant health or
envirpnmental h,szard at sites where plannir.~ for remedial actions j s
uru1erway.

.
Monitoring Well: A well installed under strict design specifications
that. when sampled, will reveal hydrogelottic ~ata at its point of
installation. Monitoring wells are installed at predetermined
locations, usually in groups. to gain knowledge of site conditions
including: extent and type of grnund water contaminaticn. soil types,
depth to ground water and direction 0: ground water flow.
National Contingency Plan (NCP): The basic policy directive for
federal response actions under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA). It sets forth the
Hazard Ranking System and procedures and standards for responding to
Teleases of hazardous substances, pollutants. and contaminants. The
NCP is a rettulation subject to regular revision.
National PrioTitiesList (~PL): A list of the highest priority
releases or potential" releases:" of' :. hazardous:'c.aub8taace. ~ .ba..d~. upon'."
..
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BEW JDSn DIPAll'tHDIT or ERVIRONHENTAL PROTICTIOR
DmSIOR or WTlIWfAGEKERT
'.
II.U.&DOOUS SIT! HITIGATION ADHIBISTU'l'I01I
A C4
",of ty ltalat1cma Prolr- at SuperfUDC! Bazardoua Waate S1ta.
Aa part of the f8cleral/ecate proar- of clUDup at hazardou. vuee
.1tea, a Community ltalat1on. Proar.. 1e cODclucted to receive local 1Dput and
to adv1ae local rea1dent. &Dd off1c1al8 about theplaaned remedial action. at
the three -jor .Ule. of the cl88DUp: 1) r...d1al 1Dve.t1laUon/f...1b1l1ty
.tucly 2) &D11De.rtna de.1an 8DcI 3) raoval/treat1ll8Dt/conatruction. Local
brief1Dl. and ..et1Dl. are conducted with elected off1c1al. and re.1dents and
aenerally tab place at: .
.oa....'"
1)
The C08l8Dce..t of a r_d1a1 1Dveat1lai:1on/fea.1bWty .CUdy .0
that local concern. CaD be addre..ed early 1D the proce...

The completion of a fea.1b1l1cy .tucly to ct18cua. the alternative
cour.e. of r...d1al action. There 1. a 3O-Uy ~t periDd after
public pre.entat1on of the alternative. dur1DI' which the f...1bllity
.tucly i. ava1lable 1D local repo.1torie.. .
2)
3>
The aaineer1D1 de81811 .tale to carry out the II8Dclate. of the
.elected r8D8cl1al alternative.
4)
The C01llll8Dcemant of the raoval/treatment/c0118truct1on .Cage to
advi.e of the expected phy.1ca~ remedial action.

The completion of the remed1al action.
5>
In add1t10n to the act1vit1e. outl1Ded above, there 18 generally
onlo1D* cOllllllUDicat1on with local official. and res1denu a. required.
Deiend1D1 upon whether the Rev Jersey Depareaent of Enviroumencal Protection
(DIP) or the United Seaee. !av1ronmantal Protect1on.Alency (ErA) ha. the lead
1D r...d1al actioD at a .ite, commua1cy relation. activitie. are conducted by
the rel8VaDt State or r8cleral alaney.

In Rev Jer.ey, the DIP COIIIIIUnity IlalaUon. Prolr.. 1. directed by Grace
S1Dler, Chief, Office of Community Relatione (609) 984-3081. At RelioD II"
ErA, the contact persO;D i. Lillian JohD.on, Community Relations Coord1Dator
(212) 264-2515. .
BS4S: j.
4/85
.
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Over. .."..
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Attactunent D
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NEW JERSEY DEPARTMENT OF ENVIRONME~TAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
. '.
Public Meeting to Discuss
Completion of
Remedial Investigation/Feasibility Study
at
Florence Land Recontouring Landfill
Thursday, June 12, 1986
7:30 P.M.
Fountain of Life Center
Columbus & Old York Roads,
Florence, NJ
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SITE MITIGATION ADMINISTRATION
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...
NtW JERSEY DEPARTMENT OF E~VIRONME~TAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss
Completion of
Remedial Investigation/Feasibility Study
'.
at
Florence Land Recontouring Landfill
Thursday, June 12, 1986
7:30 P.M.
Fountain of Life Center
Columbus & Old York Roads
Florence, NJ
PLEASE PRINT
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PLEASE PRINT
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NEW JERSEY DEPARTMENT OF ENVIRONME~~AL PROTECTION
DIVISION or HAZARDOUS SITE HITIGATION '.
Public Hllting to D18CU,.
Completion of
. Remedial Inv.8ti.8tton/r8a81b1lity Study
at
Florenee Laud R.contouring Landf!ll
Thuraday, Jun. 12, 1986
7.30 P.H. .
Fountain of Lif, Cent.r
Columbu8 , Old YOrk Road,
Florenc., NJ
10.
PLEAsE PRINT
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AfFILIATION

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ADDRESS
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'.
COMMENT LETTERS
.~
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8118Dan Raviv Associates, Inc.
Consultants in.ground water hydrology, water quality and landfill hydrology
'.
June 23, 1986
New Jersey Department of Environmental Protection
. Division of Hazardous Site Mitigation
432 East State Street - 01028
Trenton, New Jersey 08625
Attention:
HI'. Jeffrey Folmer
Re: Review Coaments of RIIFS Report Prept.red by
Black and VeatCh Relardina FLR lAndfill
Job No. 84C175
aentlemen:
.. '.."'
.
'lbe followina letter presents review CCIIIDenta prepared by Dan Ravi v
Associates, Inc. (DRAI) on the Remedial Investiaation and Feasibility
Study (RIIFS) of the Florence Land Recontourina (FLR) l.al¥1fill
prepared by Black&: Veatch (BatV). DRAI has been retained by the law
finD of Parker, McCay " Criscuolo on behalf of the Townships of
Mansfield and Florence, Burlinlton County, New Jersey.
Work performed by DRAI included a review of various dOC\.lDents relative
to the RIfFS, supplied by the NJDEP, and verbal carments durina the
June 12 public meetina. Host of the hydrogeololic and leotechnical
studies which were referenced to by the B&V study are available from
the DRAI project file.
-
. .
, Introduction
Work conducted by DRAI included the followina:
(1) Review, evaluate, and ~t on the sections of the RI/FS as it
pertaina to the .eolOJY, .round water, surface water and water
quality.
(2) Review and CXIIIDent on the sections of the RI/FS which pertains to
present and potential environmental imp8ct from the existina FLR and
the proposed Burlinaton Co\mty Solid Waste Mana,lement Facilities
Caaplex (BCSWMFC).
.-.
(3) Review and coament on the methods and prooedures used to collect
and evaluate h1droIeololic and water q\&lity Wanat.iaD. in the . '-
vic~t.7 of....the exiatinl andproJX)sed facilities.
5 Central Avenue;' West Orange, New Jersey 07052 (201) 325-0806...
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~'Ir. Jeffrey Folmer
.. NJDEP
June 23. 1986
Paae 2 --
~
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(4) Identify deficiencies relati~ to the collection of data needed
to conduct a quanti tati ve impact analysis of the proposed BCS'-MFC on
the hydrolo.ic environment.
'.
(5) Provide a .eneral s\.lllDf1ry of the RI/FS review and evaluation.
SuDmarY of Findirurs
''!be followi~ s\.llllBry is based on our review and evaluation of the
RIfFS and supportina doc\.lDents:.

(1) '!be Florence Land Recoutouri~ landfill is a superfund site.
ranked nUDber 192 on the National Priority List and nUDber 39 in New
Jersey.
(2) Ground water is dOCUDented as oocurrina in a shallow aquifer
(pleistocene) and a deep aquifer (Raritan-Maaothy Formation). The
Raritan-Maaothy aquifer is a re.ionally important source of around
water. The two aquifers are separated by the Merchantville Formation.
The Herchantville is described by BatV as a .eolo.lc unit bavin. a low
vertical permeability which allowa IDinimal downward infiltration of
.round water f!'aD the shallow aquifer to the deep aquifer. The
Herchantville is also described as a source of recharae to the
Raritan-Maaothy aquifer.
MV indicate that the Herchantville oocurrina in the study area
consists of strata of clay, silt, and sand which are vertically and
laterally discontinuous. The report is deficient in describina the
occurenc:e and lateral movement of .round water in the Herchantville,
which would impact potential contaminant movement f!'aD wastes in the
overlyina FLR landfill. A quantitative analysis of the rate of
downWlP;rd infiltration. based on differences in around water levels
be~t.Ieen all three units, is also lackina in the BatV study.

,
(3) Ground water in the pleistocence aquifer and Raritan-MBaothr
aquifer is described as IDOVinl in a southeast direction. These flow
directiona are based on water level lDeasurements taken at the FIR site
only. 'lhe MV study is deficient in information concemina the
relationship between around water flow directions at the 8i te and the
surroundina &rea. Consequently, evaluations concemina the i.mp&ct of
the FIR and proposed BCSWMFC on area around water flow directions and
potential contaminant mi..ration routes cannot be 18de.
In eddition, samplina of deep well BV-4D which .... ocnatn.lcted to
8onitor \1PIrl'8dient conditions (b8ckarowd) in the deep aquifer
indicated the occurrence of contaminated around water. In our
opinion, this well .i8 located too close to the exiatiDa laaoona to be
qualified as a bBcqround well. Mo\mdina effects due to the operation
of the l_aoona" 887 have' ""-ed cboaarci.and jnf"c8!ized,;\II:Cu..1ient.,.~ .
80VeIIent of contaminated 8rourxi ..ter recbarae. . . .
Dan Aaviv Associates. Inc.
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r
~. Jeffrey Folmer
NJDEP
June 23, 1986
Paae 3
--
(4) Testina of aquifer hydraulics at individual monitorihl wells
completed at the site was performed in order to obtain data on the
localized around water transmittina capabilities (transmissivity) of
the tested aquifers. The evaluations are deficient in data
pertainina to water level response in the f1erchantville Fonation
durina the tests. This data is necessary for quantification of the
amount of ,round water.and subsequent routes of potential contaminants
released to the Raritan-Macothy aquifer under puapina conditions (e.,
frcm ,round water supply wells).
MV indicate that no effects of JUllPina in the Rari tan-Haaothy were
observed in the shallow aquifer. A positive response would be
indicati ve of the potential for downward ql'O\md water IDOvement and
subsequent potential contaminant IDOvement. A deficiency in this
interpretation is that it is possible that the duration and rate of
testina were too low to cause sufficient amounts of around ..ter
lDOVement durina the short testina period. MV indicate that a
"sianificant rechar8e effect" was observed durina the testina of wells
CCIIIpleted in the Rari tan-Maaothy Formation. This affect 187 be the
result of around water beina released from the overlyina ~tville
Fonation which has been characterized by MV to be of low"
penlleabili ty and an effective barrier to downward contaminant
IDOvement, but also a source of recharJe.
Many of the asSlillptions inherent in the methods of analysis used to
evaluate the aquifer hydraulics testina data are violated due to their
application to observations made solely in puaped wells.
Consequently, the transmissivit7 values obtained from the evaluations
are subject to error. The transmissivity values obtained by MV for
the Rari tan-Maaothy Formation are consistently lower (areater than an
order of macni tude) than those reported by the USGS (Gill and
Farlekus, 1976). Usina lower transmissivity values miaht lead to a
false sense of safety in determinina if a JUllPina well, which was
completed in the ~othy-Rari tan aquifer near the site, could be
affeeted by potential contamination.

(5) '11Ie study indicates the oocurrence of n\.lDerous landfill
affiliated contaminants in arowd water at the FI.B site. The MV
study initially states that met.hylene chloride was the only
contaminant detected in sampled domestic wells located uppwiient and
dDwnaradient of the site. The levels detected are reported by MV to
be sianiticantly less than the suaested USEPA health advi8017
criteria. MV indicates, further on in the study, that other
ccntaminant.8 (Acid Base Neutral Compounds) were fO\A'd in the aajority
ot the dcmestic wells sampled. '11Iearound water qualit7 in the area
of the site is qualified ,by BltV as ",ood". No definitive stau.ent is
made cancemina the sources of the detected CCIIIIpO'.Dia.
(6) It does not appear that MV caapiled well lo,s for the domestic
wells ,which were"SII1IIp1.ed,durinathis inveatiaatian. '~',In:.,8ddition the" ,', ,
, protocols for dcaaestic well 88IIIp1ina are not . p.. ~8f!11t.ed 'in the RI', "
Dan Raviv Associates. Inc,
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r
~. Jeffrey Folmer
NJDEP
June 23, 1986
PB4&e 4
report. The results of analyses of samples obtained frau. domestic.
wells are dependent \JIX)n the location of the samplina point (e. a.,
...ter faucet, versus from the well). This dependency is due to the
increased potential for aeration of the water samples with distance
fram the well. .
(7) It i. stranae that SiV, after their 'extensive' aamplina proaram,
devoted one section of ' the RI (Section 10.0) as a disclaimer to the
quality and the reliability of the analytical results of their
investiaation.
Conclusions
In SUllllal7, it is our opinion that the ~aeoloaic conditions in the
vicini ty of the FLR landfill and proposed ~, their mutual
interaction, and the potential impact on the local and reaional
aquifers and the local water supply wells, are not p~sented in an
adequately quantitative manner in the RI/FS. Data'deficiences can be
remedied by resamplina aid meaaurina water levels in residential wells -
in the area, addina wells within the shallow and deep aquifers as well
as the Merchantville Formation in the vicinity of the FLR, and
conductin8 additional aquifer hydraulic tests and data anII~)"8es.

In our opinion, the RI/FS is deficient in ita treatment of the i..aq:&ct
on reaional h)'droaeoloay, water resources, and water q\8lity. An
example of a cursory evaluation as conducted by DRAI of the reaional
hydroaeoloay and its interaction wi th the FIB is presented in
Attachment 1. We r~ that the appropriate sections be uparaded
with quantitative data and that the RI/FS be amended.
If you should have further questions, or need additional information,
please call.
Very truly )'OUrS,
~~?~~;. nc.

President
DIlVlb
oc: Ronald C. Horpn, Eaq.
Mayor William M. Aaronson
Hanafield, New Jersey
MaJor Sharon A. Worrell
Florence, New Jersey
Dan Raviv Associates. Inc
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Attachment I
PrelimiJiary Interpretation of the Re,ional Hydro'eQlolY
in the Vicinity of the FLR LANDFILL .
Introduction
As requested by Mansfield Township Environmental Coamission, Dan Raviv
Associates, Inc., (DRAI) baa completed a cursory evaluation of the It'Ound
1oI8ter cond.i tions oocurrine about Mansfield Township and the Florence Land
Recontourine (FLR) landfill. The p.u-poae of this study was to evaluate the
relationship between the reeional h)'droleolOlic conditions and the FLR
landfill.
The attached fieures (Fil\,.lre8 1-9) and tables (Tables I A; II) are based on
intonation obtained from 10is of domestic wells (obtained from NJDEP by
Mrs. Dottie Wirth of Mansfield Township) and a report by Geraahty A; Hiller,
Inc. (The Technical Evahation of The Florence Landfill Recontourinl, Inc.,-
Landfill, May 1982).
Source of Information
. '.'
.~
Sued on lo,s supplied by Mansfield TOwnship, domestic '-!ells can be
cate,orized as either deep or shallow, dependi.na on the depth of the well
screen interval wi th respect to a re,ional hydro,eolo,ic unit of low ,rourd
water transmittina capability (Woocib..Iry Clay/Merchantville Formation). The
lo,s of domestic '-!ells reviewed by DRAI were compiled by the Burlinaton
CcKmty Health Department in conjunction with the NJDEP. This study also
utilized the lo,s of deep wells (38,39,40) as presented in the Geraahty I;
Hiller, Inc. report .

The locations of wells used in this study are shown on Fieure 1. The wells
are located on the 7.5 min. u.s. GeolOlical Survey Topo,raphic ~le
Maps of Bristol and Col\Dbus, New Jersey. The approximate ,round elevation
at each :-well was. interpolated from these quad,ranlles and 8\.1111B.rized in
Table I;
Approximate static It'OUnd "8ter elevations were interpolated fl"C8 the
obtained well lo,s. The respective around water levels were measured at
the time ot well installation. Consequently, the dates of water level
measurement ranle from 1951 to 1985. The wells are desilnated as shallow
or deep dependina on the penetrated aquifer. Ground water contour
elevationa in the shallow and deep aquifers are ahown on Fiaura 2 and 3, .
reapecti wly.
1
Dan Raviv Associates, Inc.
Job No. 84C175,
........
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T.
HYdroaeoloaic ..Settirur
The 8rOUnd water environment in the study site area is comprised of a
shallow and a deep aquifer. The shallow aquifer is primarily .~rised of
sand belonaina to the Enilishtown Fonration with localized areas of fill
II&terial (e..., FIR Landfill) and atream deposits. The deep aquifer
consists of clay, silt, and sand deposita belonaina to the Hari tan-Hacothy
FOl"II8tion. The shallow and deep aquifers are sel8-1'ted by low permeability
deposits comprised primarily of clay and silt belonaina to the ~ and
Herchantville Formations.
Ground. water flow direction in the shallow aquifer is controlled by the
surface topo.raphy, top of Woodbury fOnlBtion topo.raphy, and location of
surface water bodies. Ground water flow in this aquifer is frea areas of
hiper around water elevation oocurrina to the northeaat of the PIB, and
radically towards all directions (FilUre 2). Consequently, 80IDe of the
arcxmd water flow in the shallow aquifer is westerly across the Florence
landfill. A hiah point in the top of the Woodbur:Y FOl'IIBtion (F1aure 4)
concurs with the localized hiah point of ~ water elevation in the
shallow aquifer.

~ional 8rO\md water flow in the deep aquifer is controlled by the
re.ional incline of the aquifer towards the east. Consequently, roe.ional
,rouhd water flow is from the west, towards the east in the ~taD'-HB8othy
Formation. The easterly incline of the Maaoth;r-Raritan FOl'IIBtion from -50
feet .1 in the west to -130 feet .1" in 'the east 1s illustrated in Fi8ure
5. The around water contour intervals (Fiaunt 3) indicate localized
depressions in the 8rO\md water surface (potentiometric surface) of the
deep aquifer near, the Town of CoI\.lDbus and ,eneral vicinity of the Maher
elevations of around water in the shallow aquifer. These depressions are
characteristic of condi tions caused by the puapina of water supply wells
and result in localized deviations of ~ water DIOvement fraa the
re.ional IBttem.
S\.maary
The above evaluations of around water elevations and .eoloaic \.81i t
occurrene:e are be.sed on approxiJlationa obtained fram 10,s of daDestic and
monitoriha wells installed bet"'8en 1951 and 1985. This cursory evaluation
18 in~ u a Jeneral interpretation of reJional trends in the vicini t7
of the FLR Landtill and Hanafield Township only. However, the evaluation
presented ia the firat atep for a re.ional USe8811ent of around water
ccndi tiona baaed on the available hiatorical data.
2
Dan Raviv Asaociatea, Inc.
Job No. 84C175
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C!ownj,hip of d1.anj,fi£ld

BURLINGTON COUNTY
P.O. BOX 24e
ATLANTIC AVENUE
COLUMBUS. NEW JERSEY 08022
MARION E. HAY
MUNICIPAL CLERK
'.
MUNICIPAL COMPLEX
609.298-<>S42
June 20, 1986
State of New Jersey
Department of Environmental Protection
Office of Community Relations
432 East State Street
Trenton, New Jersey 08625
Att:
Jeffrey Folmer
Dear Mr. Folmer:
Concerning the Department of Environmental Protection's Remedial Investig-
ation/Feasibility Study for the Florence Landfill Recontouring Hearing held
on June 12, 1986, I would like the following concerns be made a matter of record
and be entered into the comments concerning the Florence Land Recontouring RIFS.
My name is Dorothy Wirth. My positions are: 1). Chairman of the FLR Citizens
Clean Up Committee, 2). Vice-Chairman of the Mansfield Township Environmental
Commission, 3). Member of the Mansfield Township Planning Bbard.
I wish to address several issues. I will not take the time to reiterate
the concerns of Dan Raviv, our Geo-Hydrologist or Ronald Morgan, our Attorney.
However fully concur with all the issues that they have raised.
I would specifically like to discuss some previous water problems and
testings that were alluded to in the RIFS.
We have had five sets of water testing done throughout the Township. Several
of these sets of tests indicated the presence of specific pollutants. Other sets
of tests. indicated that levels of contamination were present, but no specific
pollutants could be identified (similiar to some occurances in your RIFS
water testing).
One set of tests was conducted by the E.P.A., we flew to Washington to
petition them to assist us in searching for the source of our local water
contamination problem. The testing done by the E.P.A. indicated the presence
of Bis 2 ethylhexyl phalate. They concluded that this was a labratory con-
tamination since the trip blank showed Bis 2 ethylhexyl phalate at the level
of 67 ppb. We had four locations all in close proximity to FLR that showed
levels of Bis 2 ethylhexyl phalate from 700 ppb to 1200 ppb, more than five
times that of the trip blank. This base neutral is a known carcinagin. It
was found to be present at the FLR site in both your tests and the County tests
in both the soil and the water. Three of the four homes that showed high levels
of contamination with the above-mentioned chemical have had cancer-deaths.
-------
-
.
.
-2-
Department of Environmental Protection
Att: Jeffrey Folmer
June 20, 1986
~
In one
colon.
colon.
of them, 'the husband, approximately 39 years of age, died of cancer of the
Six months later, the wife, also 39, was diagnosed as having cancer of the
All four sUrrounding neighbors have suffered the sam&.ailment. One other died.
The house that showed levels of the same chemical at 1200 ppb also had a 38 year
old man die of cancer. One of the other .two homes with a level of over 700 ppb also
had a cancer death.
In an
Road had a
of 4 mile.
was sold.
admittedly unsc~entific survey, we found that the Hedding-Jacksonville
50\ cancer rate. We have five cases of breast cancer in the distance
One owner of a house died of breast cancer. Subsequently, the house
The new owner has now contracted and been operate on for breast cancer.
If we extrapolated our population so that we had 100,000 residents, our cancer
rate would be 1450 per 100,000. The rate in 1985 for the State of New Jersey was 425
per 100,000 for men and 400 per 100,000 for women. Ours is three times greater.
Because we have a great deal of concern over this situation, we petitioned t~e EPA4
at a meeting in New 'ork in September, to do a health survey. The D.E.P. spoke
with me in approximately Feb~uary of 1986 saying that they were considering asking
that a health survey be included in the RIFS. Nothing was ever done concernlng
this. Because of this, our Township has been forced to make arrangements with-
experts from a leading university to assist us in conducting such.'a survey. Prior
to doing this, we had directly approached the State Departrnent:o{Health. We were
told that a need must be shown, befor~ they could institute a survey. They would
not accept anything that we presented as being scientific and a sufficient reason
for doing a health survey. Therefore, there was no way that. we could persuade
them to assist u!; in doing such a survey.
This has been a typical example of our relationship with the D.E.P. and various
State agencies throughout the course of the RIFS. We repeatedly petitioned the
D.E.P. to work closely with us during the course of the clean-up study. We are
aware that Burnt Fly Bog, the Ellis site and Lipari have had many meetings and
constant input during the course of the preparations for clean-up. We have been
repeatedly told how busy and unable to attend meeting the D.E.P. officials were.
Our treatment has been totally different than that at the other five sites.
We nave a great concern that the site be adequately cleaned up due to the
fact that the County Landfill will be located adjacent to the site.
Had we been given a freer range of access:
1. We could have made suggestions concerning locations of comestic
wells that it would have been advisable to test.
2. We could have contributed the expertise of our Geo-Hydrologist.
3. We could have prov~ the need for a comprehensive health study.
4. We could have provided input that would have contributed to a more
complete feasibility study that would be an accurate and adequate guide in select-
ing a proper means of clean-up.
ve~.Y ~urs. ~
Do thy Wirth. - .
Co-C airper.~D.fieldTwp. Enviroo.Comm.
Chairperson, -. FLR 'Ci tizen! s .Aclviscry' Commi ttee
DW:mh
cc: Ronald C. Morgan~:Township.Sclicitor
File
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~
Clown!l.hip of o11.an!l.~~tJ

BURLINGTON COUNTY
P.O. BOX 249
ATLANTIC AVENUE
COLUMBUS. NEW JERSEY 08022
MARION E. HAY
MUNICIPAL CLERK
'.
June 20, 1986
MUNICIPAL COMPLEX
609.298~S42
State of New Jersey
Department of Environmental Protection
Office of Community Relations
432 East State Street
Trenton; New Jersey 08625
Att:
Jeffrey Folmer
Dear Mr. Folmer:
The following concerns are to be a matter of record and entered into the
comments concerning the Florence Land Recontouring RIFS:
I became involved in the FLR site in late 1978, so I am not unfamiliar or
uninformed. For eight years, I've devoted much time and effort-to the environ-
mental issues surrounding this site. 'I'm on the Board of Directors of NJCA,
worked actively on the N.J. campaign on toxic hazards, the R~ght to Know Bill
and am a member of CCHW founded by Lois Gibbs of Love Canal.
I've testified before the Congressional Committee on the Superfund issue
and am actively working with the N.J. Environmental Federation and the N.J.
Environmental Lobby.
In January 1986, I began the first year of a three year term on my
Municipal Committee, after having served on our local Board of Education and
other municipal committees and community organizations. I am not a hysterical
housewife.
I ~ totally. familiar with the bureaucracy (which everyone refers to as
red tape)' in our Government. Bureaucracy is, (a) the administration of a
90vernm~nt chiefly through bureaus and (b) the non-elective officials staffing
such bureaus. It is also government marked by diffusion of authority amuRg
numerous offices and adherence to inflexible rules of operation.
The Easy Access directory put out by the DEP should be titled "No Easy
Access". Direct answers are virtually impossible to obtain as is information
and explanations. Unless of course a "Political" contact is obtained.
On the local level, we municipal officials are accountable to our people.
On the State level, non-elected officials such as yourselves are not and cannot
be held accountable. However, you can take this information presented here
tonight bac~ to the "Politicians" .who will ultimately decide this .iasueandthe .
fate of our two communities'with respect to contamination exposure in our
water,..8oil.and"in.t.ha:.air.be"breath. . '. . .
-------
-2-
Department of Environmental Protection
Att: Jeffrey Folmer
June 20, 1986
'-'"
Evidence has come to light over the past years that indicate that past
and present land qwners and corporate officers knew hazardous waste was being
dumped'at the FLR site. They must be held accountable for t~eir irresponsible
actions and open disregard for the~ety and well being of our people and our
natural resources.
This land was clean in 1973. Uncontaminated. None of the seven
alternatives presented has a goal to restore this land to that condition.
There are actually only two alternatives. 1. Non-Action and 2. Contain-
ment. We all know what non-action means so I'll address containment. Its a so
called "proven technology". Its proven - proven to fail. It doesn't
render harmless the problem. Eventually the contamination will migrate. Caping
is not permanent and containment only replaces one problem with another.
Other technologies have been identified and should be explored. The
EPA's new SITE program (Superfund Innovative Technology Evaluation) began primarily
to replace conventional cleanup methods that transfer risk or at best, contain
the wastes, which is not a permanent alternative.
I direct your attention to Vol 2, RI Summary on page 10-S-Data Gaps,
and I quote: "The reliability of the analytical data is also ~ue~tionable since,
in several instances, various holding times were exceedea: Although
small exceedance for certain constituents should not invalidate the
analyses, the results must be considered suspect. Of .greater significance
at the FLR Landfill site is that, in most instances, only low concentrations
of contaminants are apparent in the samples. The presence of only low
levels of constituents makes it difficult to actually quantify the extent
of contamination. This fact, in conjunction with exceeded holding times,
creates a situation where the levels of detected concentrations could
be exceeded by the range of analytical error, or could be masked by
background levels. Therefore, the low concentrations of contaminants
apparent at the site could be potentially non-representative of the
actual site condition.
. ~ince only a single sampling event was conducted during this in-
ve~tigationi it is not reasonable to predict future leachate discharges
from the site with a high degree of reliability. Predictions of future
site performance are based on the current information incorporated with
past studies. The absence of off-site contamination at the present time
should not be misconstrued to imply that these discharges could not occur
in the future; additional future monitoring would therefore be necessary
to identify any contaminants plumes if they should form and migrate off-
site. The presence of various contaminants in the waste disposed at the
site identifies a potential for future discharges and the need for
continuous monitoring."
I maintain that a technology for the clean up of the FLR site cannot be selected
if the problem is not perperly defined or if the RI/FS investigation is suspect ,,'
or incomplete. By Black and Veatch's own statement on the Summary of Data Gaps,
such is ,the case here,",', ',' '
-------
-3-
Department of Environmental Protection
Att: Jef4£ey. Folmer
June 20, 1986
'.
Further, there are constant references made to "low levels" of contamin-
ants. There are many Ghronic health affects attributable to "low-level", long
term exposure ranging from allergies, to depression, to cancer and lukemia.
Low levels should not be irterpreted as being "safe".
The DEP and the EPA a~e responsible for protecting the public health
and the environment.
. We urge you to pay strict attention to the testimony presented here tonight.
We have done our homework as elected municipal officials. Now we expect you
to do yours.
Finally, I ask you to keep this in mind: "We didn't inherit this earth
from our parents, we are borrowing it from our children".
MEL: meh
cc: William M. Aaronson, Mayor
John R. Bereczki, Committeeman
Mary Ellen Lister, Committeewoman
Ronald C. Morgan, Township Solicitor
Mansfield Township Environmental Commission
Win Porter, Assist. Administrator, US EPA
File
ank you,




Mansfiel wnship

. .
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-------
iv~PUKE
",
-=-
'.
. June 18, 1986
N. J. Department of Environmental
Office of Community Relations
432 East State Street
Trenton, New Jersey 08625
Protection
Dear Mr. Follmer:
I am subm~tting additional comments about the draft
RIfFS for Florence Land Recontouring site.

Generally speaking, the alternative selected appears
. to be acceptable when compared with the other atterhatives
presented. Naturally, we would opt for removal of all wastes
at the site as the most preferred course of action.
~
,
. -
" .
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. -.
~c 1.."'1rmp ~"- ~~N e:N{I~d'i~T R1)f.!1, fiox 3310, l\ot'dcntcn-m, NJ
..
08505 "
-------
~
'.
Addressing alternative .3 specifically is rather difficult
without detailed design and engineering plans. This brings up the
first suggestion and comment - the FLR citizens committee should
be involved directly during the preparation of enginering and design
plans. I would urge the site manager to share all draft plans, reports,
schedules, etc. with the committee to assure prompt and comprehensive
feedback, as well as being an ideal vehicle for disseminating correct,
complete and timely information to the local citizenry. The suspicion,
distrust and, I daresay, emnity evoked at the June 12th meeting can
only increase, if no positive steps are taken by your office. Full
disclosure of your plans will be the best protection against rumor,
resistance and opposition in your already difficult job. Full involvement
of the citizens' committee will demonstrate the level of confidence'
you have in your plans and their results. It will .~lso serve as
a methodology for resol~tion of citizens' concerns about the remediation
heightened by the dispute over technical issues.
Alternative '3's implementation raises serious concerns
about one, the criticality of the Health and Safety Plan apdtwo,
long term monitoring of air and water, especially for contamination
to the Raritan-Mogothy aquifer. -
We maintain that our township officials should insist upon
a detailed Health and Safty plan which contains adequate measures
to prevent on-site incidents, and detailed contingency plans to handle
on-site emergencies. These plans and actions must provide for the
safeguarding of all residents' health and safety. The input of the
FLR citizens committee would be essential for such questions as:
1.
How do you plan to coordinate emergency response efforts
with the fire and police?
.;.
2.
What plans exist for early warning of residents in
. the event of an emergency requiring evacuation?
3.
What security and surveillance measures at the site
at night are you proposing?
4.
Decontamination procedures, contractor liability and
reimbursement for loss of property due to off site
contamination during construction?
s.
What plans for traffic control exist during construction?
-------
~
We plan to provide our suggestions on these and similar
questions to you in the near future when we offer our health and
safety plan requirements.
Our second concern is after the remediation is complete.
With the continued presence of the wastefill at FLR, long term air
and water monitoring are a vital necessity. Again, we strongly urge
citizens involvement through direct access to all air and water monitoring
plans, designs and reports. In addition, we believe that the FLR
citizens committee must receive copies of all monitoring reports
rendered to the State by the contractor directly from the State.
Such a direct mailing will demonstrate good faith on the part of
the State and contractor performing the monitoring. Transmittal
through township officials to the citizens committee would be deemed
unacceptable in any proposed monitoring plan.
We will propose to you a geophysical monitoring program
employing the use of surface measurements of the. electromagnetic
conductivity and/or galvanic resistivity of the earth water materials
underlying the site to detect leachate plume movement. We. believe
this methodology offers a cost effective, long term monito~ing and
detection system.
In closing, I again reiterate the necessity to involve
the FLR citizens committee in all future plans.
Sincerely,
~
Herbert Meire , President
People United for
Klean Environment
.;.
-------
~wnship 01 morence
-=-
MUNICIPAL COMPLEX
BROAD STREET
FLORENCE. NEW JERSEY OB51B
609.499.2525
'.
June 18, 1986
Mr. Jeffrey Folmer
NJ Department of En",ironmental
Office of Community Relations
CN 028
432 E. State Street
Trenton, NJ 08625
Protection
Dear Mr. Folmer:
The members of the En",ironmental Commission of Florence Township
attended the recent public meeting on the completion of the Remedial.
"In",estigation/Feasibility Study at the Fountain of the Life Center and
.
"
would like to express concern on the exclusion of a health impact
accessment.
TIle accessment is underscored by numerous cases of cancer along
with physical maladies of people li~ing in the proximity of the Florence
Land Recontouring Site.
We are looking forward to your consideration in this ",ital matter.
;
ZZ)e~t( j)~fjJ
Dana Paykos
Chairman of En",ironmental Commiss ion
DP:ts
-------
-..t:"
We plan to provide
questions to you in the near
safety plan requirements.
our suggestions on these and similar
future when we offer our health and
Our second concern is after the remediation is complete.
With the continued presence of the wastefill at FLR, long term air
and water monitoring are a vital necessity. Again, we strongly urge
citizens involvement through direct access to all air and water monitoring
plans, designs and reports. In addition, we believe that the FLR
citizens committee must receive copies of all monitoring reports
rendered to the State by the contractor directly from the State.
Such a direct mailing will demonstrate good faith on the part of
the State and contractor performing the monitoring. Transmittal
through township officials to the citizens committee would be deemed
unacceptable in any proposed monitoring plan.
We will propo~e to you a geophysical monitoring program
employing the use of surface measurements of the electromagnetic
conductivity and/or galvanic resistivity of the earth water materials
underlying the site to detect leachate plume movement. We. believe
this methodology offers a cost effective, long term monito~ing and
detection system.
In closing, I again reiterate the necessity to involve
the FLR citizens committee in all future plans.
Sincerely,

~
;
Herbert Meire , President
People United for
Klean Environment
-------
&ownshiP oj g/orence
-..;::
MUNICIPAL COMPLEX
BROAD STREET
FLORENCE. NEW JERSEY OB51B
609.499.2525
'.
June 18, 1986
Mr. Jeffrey Folmer
NJ Department of En'1ironmental
Office of Community Relations
CN 028
432 E. State Street
Trenton, NJ 08625
Protection
Dear Mr, Folmer:
The members of the En',ironmental Commission of Florence Township
attended the recent public meeting on the completion of the Remedial-
.In?estigation/Feasibility Study at the Fountain of the Life Center and
,
,
would like to express concern on the exclusion of a health impact
accessment.
TIle accessment is underscored by numerous cases of cancer along
with physical maladies of people lbing in the proximity of the Florence
Land Recontouring Site.
We are looking forward to your consideration in this ',ital matter,
;
J)~~ jJ~f;
Dana Paykos
Chairman of En',ironmental Commiss ion
DP:ts
-------
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--""
MIELE, COOPER, SPINRAD & KRONBERG
~UNe/~ d ~
90 MILLBURN AVENUE
MILLBURN,N.J.07041
'0
JOSEPH P. MIELE-
LAWRENCE COOPER-
MAX SPINRAD-
MARTIN F. KRONBERG
(201) 762~4700
. WDGD N.J. AI'4> N.!. aAAS
June 13, 1986
Mr. Jeffrey Folmer
N. J. Department of Environmental Protection
Office of a:mnuni.ty Relations
Ql 028
432 East State Street
Trenton, N.J. 08625
Re: FIDREN:E IAND RECDNroURING - PUBLIC HEARING
HELD JUNE 12, 1986 OON:ERNING RIPS
.
,
Dear Mr. Folmer:
Enclosed find a letter frcrn the urx1ersigned as CDunsel to Florence Land
Recxmtouring together with an attached letter fran New Jersey First, Inc. setting
forth the position of our client relative to the RIFS CDnducted by Black & Veatch.
Pursuant to the hearjng oonducted on June 12, 1986 relative to the alDve, kindly
see that this 8 page letter from the undersigned together with the one page letter
from New Jersey First, Inc. be made part of the reoord ooncerning the p.Jblic hearing
in this matter.
-
.
Very truly yours,
CERrIFIED MAIL, R.R.R.

MS:SM
Encl.
cc: Mr. Richard J. SUllivan, w/olerc.
New Jersey First, Ine.

cc: Anne R. SiIrol'X)ff,D.A.G~, w/olerc.

cc: BethI..Muhler1'.wlo/enc.. .
Hazardcus Site Mitigation .Administration .
MIELE, CXDPER, SPINRAD & lOONBERG

BY2:!z~
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--=-
.

MIELE, COOPER, SPINRAD & KRONBERG
~td~
90 MlLLBURN AVENUE
MILLBURN.N.J.07041
'.
JOSEPH P. MIELE.
LAWRENCE COOPER.
MAX SPINRAD.
MARTIN F. KRONBERG
(201) 7132-4700
June 11, 1986
. WIMIUI N.'. AND N.\': BAAS
Anne R. Simonoff, Esq.
Deputy Attorney General
Hughes Justice Complex
CN 112
Trentoni New Jersey 08625
Florence Land Recontouring Landfill
Remedial Investigation/Feasibility Study

Dear Ms. Simonoff:
Re:
As the attorney for Florence Land Reco~~o~ring,
.Inc. and Florence Land Development (collectively "FLR"),
I have reviewed the Black & Veatch Remedial Investigation/Feasi-
bility Study ("RIFS"), dated May 12, 1986, concerning the
Florence Land Recontouring, Inc. landfill (the .site"),
which NJDEP provided to my clients.
This study was conducted
under the. supervision and authority of NJDEP, which we under-
~
stand is t~e lead agency in connection with possible remedial

.
measures to be undertaken at the site.
This letter constitutes
FLR's official response to the RIFS and we therefore ask
you to include it as part of the record developed in connection
with the announced public meeting to be held by NJDEP on
June 12, 1986.
In addition, we enclose a letter from Richard
J. Sullivan, .the. environmental consultant;.for. 'FLR, which'
j~; .
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MIELE, COOPER, SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page Two '
June 11, 1986
'.
should also be included in that record.
The Black' Veatch RIFS is the most recent and
most costly report in a series of environmental studies
of this site, all of which have reached the same conclusion:
that the health hazards or threat of environmental harm
created by this site are de minimis and represent the normal,

expected incidents flowing from the use of land as, a sanitary
landfill.
Nothing i~ the Black' Veatch RIFS demonstrates
any justification for this site's inclusion on the EPA's
. , .,
~ational Priority List as a "superfund site" unde~ the Compre-
hensive Environmental Response, Compensation an4 Liability
Act, 42 U.S.C. S960l et seq. ("CERCLA").
The Remedial Investi-
gation in fact demonstrates that the lavishly expensive
remediation alternatives set forth in the Feasibility Study
are wholly unwarranted and represent overly complex methods

of clospre that exceed the normal requirements for landfill
clos~re as set forth in proposed NJDEP regulations.
In 1982 Geraghty, Miller, Inc. performed a thorough
investigation of ground water quality at and around the
site for the County of Burlington.
Its report, which concluded
that the water quality parameters indicated values in the
range of "normal" background levels, is consistent with
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MIELE, COOPER, SPI}\;RAD & KRONBERG
Anne R. Simonoff, Esq.
Page T~e
June 11, 1986
'.
other studies and the Black & Veatch investigation.
See
Technical Evaluation of the Florence Land Recontouring,
Inc. Landfill, May 1982: Memo of Peter Sugarman dated October
21, 1982, to Edward Londres: RIFS, Volume II, Remedial Investi-
gat~on, at 5-36 to 5-37, 5-42, 5-53.
Indeed, Black & Veatch
has concluded that any hazardous compounds found in the
leachate were at lower concentrations than that found two
years ago, indicating a dilution or "flushing" of contaminants
in the wastefill, a normal incident of a typical landfill.
See RIFS, Volume II, Remedial Investigation, at ~~50.
In
fact, the unanimous conclusion of the various reports is
that the location of this landfill over the sixty foot thick
Merchantville Clay formation, with its very low permeability,
has "perched" the ground water above as effectively as would
be done by a man-made liner system.
See RIFS, Volume II,
Remedial Investigation, at 4-11.
Black & Veatch has unquali-
fie4ly stated that "impacts on water quality down gradient
.
of the wastefill are minimal."
Id. at 5-57.
The water quality
in domestic wells in the vicinity downgrade of the site
was found to be within acceptable limits except for iron
and zinc, which were also found upgrade of the site and
therefore are most probably from a source other than the
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MIELE, COOPER, SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page Four
June 11 ,-=19~ 6
landfill.
In sum, "the ground water quality in the area
is good."
Id. at 1-5.
The nearby surface water has been similarly unaf-
fected by the landfill.
Black & Veatch has confirmed the
earlier findings by Geraghty & Miller, Inc. that the landfill
has "little or no impact on water quality" in nearby Assiscunk
Creek.
And the soil analysis performed showed that the
materials detected in the waste were at "significantly lower
[concentrations] than would be expected to occur in a sanitaTY
or industrial waste landfill," presumably caused,. a,&, Black

,
& Veatch has acknowledged, by the "effectiveness of the
existing leachate collection system."
Id. at 7:"10.
As to air quality, no "elevated levels" of volatile
organic compounds were detected at the site; merely the
usual "nuisance impact" associated with most garbage landfills
where waste is decomposing.
See RIFS, Volume II, Summary
.
of R~medial Investigation, at iii.
Inclusion of the site on the National Priority
List under CERCLA was said to be because of the potential
health and safety threats caused by this site as a result
of the presence of hazardous wastes in significant quantities.
But here, as Black & Veatch acknowledged, the only source
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.
,
()
MIELE, COOPER, SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page Five
June 117"1986
indicating the deposition of hazardous waste is 'the NJDEP
hazard ranking form and the NJDEP industrial survey generator
reports.
RIFS, Volume II, Remedial Investigation, at 1-4.
Neither of these sources is firsthand: and there is no confir-
mation by Black & Veatch that hazardous wastes exist at
the site in any but the most nominal amounts, amounts expected
to be found at a landfill where ordinary household chemical
materials are deposited with municipal solid wastes.
Indeed,
the only hazardous substance encountered in detectable amou~ts
during the Black & Veatch site investigation was landfill-
. . .
,
generated leachate, to be e~pected in any sanitary landfill.
RIFS, Volume II, Remedial Investigation, at )-1.
Leachate
has been pumped out of the landfill since closure of the
landfill: the hazardous substance concentration in the leach-
ate, which has typically declined in strength over time,
is no ~ore th~n "average" and for some constituents lower

tha~ average than that found in "typical sanitary landfill
.
leachate."
RIFS, Volume II, Remedial Investigation, at
)-11.
Moreover, according to Black & Veatch, the pH level,
an indicator of hazardous levels, "falls within the normal
range of sanitary wastes."
Id.
In sum, Black & Veatch's study confirms earlier
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MIELE, COOPER. SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page Six
June Ii"; 1986
'.
conclusions that "no significant adverse impact on the environ-
mental surroundings or public health have been imposed by
the facility to date," almost five years after landfilling
ceased.
RIFS, Volume II, Remedial Investigation Summary,
at i.
NJDEP's exorbitantly expensive and thorough site
investigation demonstrates that this landfill should never
have been designated as a superfund site.
FLR objected
to that designation back in 1983, when EPA first decided
to list the site, and reiterates its contention ~h~~ this
,
designation is without basis and will result in NJDEP expending
government resources on unnecessary studies and remediation
measures that constitute overly expensive and unwarranted
closure procedures.
The Black & Veatch RIFS demonstrates
that this site was improperly placed on the National Priority
List and should be delisted now, before additional funds
are;expended for closure measures which the Remedial.Investi-
gation shows are unnecessary.
Surely the full panoply of remedial measures listed
in Black & Veatch's alternatives 3 through 7 identified
in its Feasibility Study should not be undertaken.
Given
the results of the Remedial Investigation, it is clear that
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. 0
MIELE. COOPER. SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page S~n
June 11, 1986
'.
the cover material and cap called for in alternative 5 is
unnecessary and exceed NJDEP's current requirements and
even its probable future requirements for capping a closed
landfill as set forth in its proposed closure regulations.
See 18 N.J.R. 914 (May 5, 1986).
FLR has already capped
the landfill with acceptable, low-permeable clay soil from
the Merchantville Formation in accordance with their closure
plan; additional capping should only, at most, have to meet
the proposed requirements, which are exceeded in Black &
Veatch's alternatives.
.
.
Moreover, the slurry walls or contaminant barriers
called for in alternatives 3 and 5 are also unnecessary
and would not be required in a normal sanitary landfill
closure, which is all that should be required for this site.
DEP's proposed new closure regulations only require cut-off
walls where there is a need to "restrict the lateral migration
of leachat~, provide for a compl~te contaminant system and

,
prevent pollution of the underlying aquifer."
18 N.J.R.'
909.
At this site there has been no demonstrated lateral
migration of leachate, nor should any be anticipated, and
the underlying aquifer is well protected by the clay strat~
that contains the wastefill.
Moreover, FLR's earlier closure
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. ,
MIELE. COOPER. SPINRAD & KRONBERG
Anne R. Simonoff, Esq.
Page EiC)'ht,
June 11, 1986,
'.

plan included the construction of cut-off walls, which were
obviously performed as intended to prevent leachate migration
and contain any contaminants.
Finally, the proposed slurry
walls fail to take account of the fact that this site will
soon be surrounded by the proposed Burlington County Waste
Management facility.
Any chance of lateral migration of
leachate from this site will be foreclosed by the containment
barriers which must be constructed under DEP regulations
in connection with the operation of that facility.
Under these circumstances, the remedia~_measures
proposed by Black' Veatch is not justified by its own in-
vestigation, or by NJDEP requirements.
This site should
be delisted and the government's time and money concentrated
on sites legitimately in need of the exorbitant type of
remedial measures proposed here, for what should be an ordi-
nary landfill closure.
-
,
I appreciate your consideration of the above.
FLR stands ready to meet with you and other NJDEP representa-
tives to discuss this subject in detail.
Very truly yours,
MIELE, COOPER, SPINRAD , KRONBERG
Attorneys for Florence Land
Recontouring and Florence
Land Development
" .. By:
~1J.~
I' '

~' /, !:-~ . '..
MA)C S
cc:
Beth I. Muhler, Site Manager
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. .
I,
I>
A1C"OAO J SUU"O"
"'tHI"'''' ( SCMlUT[A
. trgnV ~W:~N~L:~:E:E~ C~!.~:~ '=::::NESS AND .DVERwWEN,
'.
10 June 1986
Ms. Beth I. Muhler
Hazardous Site Mitigation
CN 028 NJDEP
Trenton, New Jersey
Adminis tra tion
Dear Ms. Muhler:
08625
As an environmental adviser to Florence Land Recontouring
Incorporated and Florence Land Development, I have reviewed
the 12 May 1986 report of the Remedial Investigation/Feasibility
Study of the FLR landfill done by Black I Veatch. I am present-
ing these comments 'for the record of the public meeting to be
held by the Department of Environmental Protection on 12 June
1986 concerning this study: '
ROUTE ~1 "'Onss~ 1UIl0lHCl8 ,. 'ENNlNQTOH "01.0. T"EHTON. N.J. 088». PHON!: ""'3003' ,>,
-
.
RJS: jeb
.
.
1.
Neither this study by Black, Veatch nor other studies
which preceded it have discovered evidence of the dis-
charge, potential discharge or even 'the presence of .
hazardous wastes disposed of at the landfill site.
2.
The failure of comprehensive investigation to discover
such evidence indicates that the landfill should not
be included on the EPA's National Priority List as a
Superfund site.
3.
The BIV study shows that the
duced in the landfill are of
with that found in a typical
landfill.
leachate and gases pro-
a character consistent
municipal solid waste
4.
The Department's landfill closure regulations and
NJPDES permit requirements should govern the design
of the Florence landfill closure.
Sincerely,
,e~A;.IIttt?~ d~~

Richard J. Sullivan
Principal, '
.- "
..,:.
'.
,,'
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"
~
'.
230E Jacksonville-Hedding Road
RD1 Bordentown, New Jersey 08505
June 20, 1986 '
New Jersey Dept. of Environmental
Office of Community Relations
CN028
432 East State Street
Trenton, New Jersey 08625
Protection
Attention:
Mr. Jeffrey Folmer
To the Members of the New Jersey Dept. of Environmen~al Protection:
In an effort to convey to you the very serious concerns of the resi-
dents of Springfield Township, Burlington County, regarding the
Florence Land Recontouring Landfill Site located in Florence and
Mansfield Townships, a petition bearing 404 signatures is enclosed.
Those signing the petition live nearest the western portion of the
Township (west of U. S. Highway 206), living in very close proximity
to the landfill.
As the petition states, the residents are urging the approval of a
total clean-up and removal of contaminents on the landfill site.
We are also petitioning the Committee Members of Springfield Township
to join with Mansfield and Florence Townships in their efforts to
completely eliminate this health-hazard and to restore to us the
clean environment to which we are entitled. .
Sincerely,

V~
(Mrs.) Veronica A. Stevenson
Encs. - petition ~pages 1-24
.'", .
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ILl
L>
Encl. I
JUNE 1986
---=
PETITION TO: THE NEW JERSEY VEPARTMENT OF ENVIRONMENTAL PROTECTION
VIVISION OF HAZARPOUS SITE MITIGATION '.
FROM:
RESIPENTS OF SPRINGFIELV TOWNSHIP, BURLINGTON COUNTY, NEW JERSEY.
we, THE UNPERSIGNEV RESIPENTS OF SPRINGFIELV TOWNSHIP, WISH TO MAKE KNOWN OUR
CONCERN REGARVING THE FLORENC£ LANP RECONTOURING LANPFILL SITE LOCATEV IN FLORENCE
ANP MANSFIELV TOWNSHIPS. BECAUSE OF THE HIGHLY TOXIC WASTE KNOWN TO EXIST ON
THE SITE ANP THE VERY PROBABLE LIKELIHOOV OF CONTAMINATION OF THE WATER SUPPLY,
WE URGENTLY PETITION THE NEW JERSEY VEPARTMENT OF ENVIRONMENTAL PROTECTION
TO APPROVE TOTAL CLEAN-UP ANP REMOVAL OF ALL HAZARPOUS COMPOUNPS IN THIS
SITE.

THE HEALTij ANP WELFARE OF ALL RESIPENTS IN THIS AREA IS AT STAKE. OUR LIVES ARE
ENPANGEREP ANV WE PLEAP FO~MMEPIATE ACTION!
NAME (PRINTEV) APPRESS
'7c~'ep ~ P. 'WtI {-hc~:X+ 2.2~
Kd

2.. z. '-f cgcJ. ~ ~dliL~ ~ . &6~.jJ. 3ut ~
SIGNATURE
.

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...
L.AW 0F"F"ICE5
PARKER, MCCAY & CRISCUOLO
A "ROr[SS'O"AL COR"ORAT'ON
--=
SUITE ~Ol
THREE GREENTREE CENTRE

ROUTE 73 & GREENTREE ROAD
MARL TON, N. ..J. 08053
'.
(808) 1588-8800
June 23, 1986
File No. .1~91-0005RCM
Mr. Jeffrey Folmer
NJDEP Division of
Hazardous Site Mitigation
CN 028
432 E. State Street
Trenton, N.J. 08625
Re:
Written Comments on RI/FS Prepared by Black and Veatch
Engineering Architects Regarding Florence Land Recontouring
. (FLR) Landfill :, . ..
Dear Mr. Folmer:
This office serves as Solicitor for the Township of Mansfield.
I attended the June 12, 1986 Public Meeting held by NJDEP at the
Fountain of Life Center in Florence Township and expressed certain
comments and concerns on behalf of Mansfield and Florence Townships
with respect to the RI/FS Report prepared by Black and Veatch
(hereinafter referred to as B&V).
At the meeting, Anthony Farro, Assistant Director of the NJDEP,
Division of Hazardous Site Mitigation, indicated that additional
written comments would be accepted by NJDEP and EPA on or before
June~23, 1986 and that these governmental agencies and/or B&V would
respond to each comment and concern in writing. Grace Singer, Chief
of the Office of Community Relations in the NJDEP Community Rela-
tions Program indicated that all written comments should be address-
ed and directed to you for appropriate response.

This letter is intended to summarize and expand upon the verbal
comments that I posed at the June 12, 1986 meeting and raise. certain
additional technical comments and concerns which merit a written
explanation and response.
My comments are as follows:

1. SCOPE OF STUDY. Governmental, public"and judicial knowl~-
edge can cer.tainly be taken with regard to the serious domestic
water:: supply cantamiDaticn~prob~em., in.. private..pOtable'.water . supplit.
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(]
t,
PARKER, M!;CAY & CRISCUOLO
PAG E 2
-=
located in proximity to the FLR Landfill. Vinyl chloride, methylene
chloride, chloroethane, l-2-dichlorobenzenes, bis (2-ethyl hexyl)
phtahlates, arsenic and numerous other carcinogens have been found
in significant concentrations in domestic water supplies in both the
shallow aquifers and the Pleistocenes deposits and the deep Raritan-
Magothy Aquifer.
Some of the concentrations of these contaminants are in excess
of five (5) times the concentrations found in field blanks and
therefore merit further intense investigation. This data has been
complied over the last several years as a result of tests performed
by NJDEP, EPA, Burlington County, Mansfield Township and private
water well investigations by concerned residents.
Mansfield Township has, in fact, expended a great deal of time
and money with regard to its efforts in having its ground water
hydrologist, Dan Raviv Associates, perform water tests throughout
the township in an effort to analyze contaminant data and contami-
nant sources.
The alarmingly high cancer occurrences and cancer related
deaths experienced by residents living in close proximity to the
contaminated waste fill area. has been repeatedly communicated to
various EPA and NJDEP officials over the last s~veral years. Cancer
occurrences in the area of the township where the FLR Landfill is
located exceed the New Jersey average by approximately three hundred
(300) percent.
At a conference in Washington, D.C., prior to the award of the
RI/FS contract to B&V, William N. Hedeman, Jr., then Director of the
Office of Emergency and Remedial Response in the Federal Superfund
Program, indicated that the domestic water supply contamination
problem 'would be investigated in conjunction with and as a part of
the RI/FS for FLR and that remediation of FLR would be coordinated
with th$ location and construction of the Burlington County Solid
Wast4 Management Facilities Complex proposed by the Burlington
County Board of Chosen Freeholders on the parcel of land adjacent to
the FLR Landfill site.
Township representatives have repeatedly expressed their
concerns over deferring commencement of waste filling operations in
the new County landfill next to the FLR Superfund site until 'reme-
diation has been completed and domestic water supplies are free from
contamination. The Township has also expressed an additional
concern pertaining to the location of a 1,200 unit adult community,
which is now being completed, which is supplied by water with two
on-site wells. This development is located approximately one mile
from the FLR Waste fill area. Mansfield and Florence Townships
were, therefore, under the opinion and belief, based upon represen~" .
: tations from NJDEPand EPA, that the scoping o£ the project included'
, an, expansive'~ investiqation,..dealing. with both,.source. 'and .:off-site .
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".
'"
, '
PARKER M~CAV & CRISCUOLO
, , ~'t

PAG E 3
--"-
contamination' and environmental concerns, and that the factors set
.forth in 40 CFR Section 300.68(e) would. be incorporated into the
RI/FS analysis. Pursuant to subsection (e) (1) (3i) of 40 CFR Section.
300.68(e), the expanded analysis would necessarily include an
analysis of "contaminated drinking water at the tap" and remediation
measures responding thereto, including provision for water supplies.

All of these concerns were again expressed at the first public
meeting arranged by your office which was held on May 2, 1985 at the
Florence Township High School prior to preparation of the RI/FS by
B&V. Both townships and their residents were led to believe that
such an expanded analysis was part of the study, especially in ligh~
of the following statements contained in Section 2.4, entitled
Potable Water Supply Well Inventory, on Page A-14 of B&V's Project
Specific Proposal for FLR:
"As part of the field operations, a survey of
domestic and any public, water supplies within a
1-mile radius of the site will be conducted. The
purpose of this survey will be to identify domes-
tic water supply wells that may have been .',
impacted by contaminant migration from the site
and to further define the geologic and hydrologic
conditions in the area."
Needless to say, the Townships were dismayed to find, upon
receipt and review of B&V's RI/FS Report two weeks ago, that B&V did
not investigate domestic water supplies within one mile of the
contaminated waste fill area as represented, but, instead, simply
tested twenty domestic wells located in close proximity to the waste
fill area. The Township officials and the residents and profession-
al consu.ltants were equally dismayed that B&V did not expand their
investigation and study upon finding contaminants in those wells
sampled~ B&V simply indicated that further tests should be conduct-
ed i~ the future with respect to these issues and, as will be
discqssed in subsequent comments, indicated that the contaminant
source might not be the landfill inasmuch as the same or similar
contaminants were found in both upgradient and downgradient wells.
Based upon the limited scope of the investigation, B&V conclud-
ed in its RI that the contamination was "source contained". The
remediation alternatives suggested in the FS were predicated upon
and presuppose the accuracy of this conclusion in the RI. The
Townships feel that the remedial alternatives may not accurately or
fully address the nature, scope and breath of appropriate remedial
measures if the supposition in the RI pertaining to "source con-
tamination" is incorrect, unsubstantiated and/or.inconclusive.
2. ENDANGERMENT ASSESSMENT AND ENFORCEMENT ACTION. .The
Townships were advised by EPA and NJDEP that an enforcement action
wou.l.d..:bfL. brought "by.. the.:.government (& ),,; under'.. CERCLA.:, to. . recoup~ i t.s. .
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PARKER, M~CAY & CRISCUOLO
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costs incurred resulting from investigation and remediation.
However, Page 5-58 of the FS (Volume 3) indicates as follows:
"An endangerment assessment is often prepared as
part of the public health assessment for enforce-
ment-related remediations. Since the remediation
to be performed at the FLR Landfill is not cur-
rently defined as an "enforcement action" under
CERCLA, a separate endangerment assessment has not
been performed."
NJDEP's enforcement attorney was present at the June 12, ~986
public meeting and representations were made at the premeeting
conference with the Municipal officials that an enforcement action
would be brought by the government. The Townships request written
confirmation that an "enforcement action" under CERCLA will be
instituted by the government and that a separate endangerment
assessment will be performed and made available to the Townships
within the next several weeks. The Townships have incurred suhstan-
tial investigatory and remediation costs on their own and may wish'
to commence litigation to recoup their costs. I am,advised that
Florence Township has already filed a "Notice of Claim" under
CERCLA.
3.
GEOLOGIC AND HYDROLOGIC ANALYSIS
A. Groundwater flows. Both the RI and FS devote substantial
verbage to an explanation of groundwater flows in both the shallow
aquifers in the Plestocene deposits and the deep Raritan-Magothy
Aquifer. Reference is made to prior studies and reports focusing on
the geologic and hydrologic analysis of the site by Geraghty and
Miller, Inc. (G&M), Woodward-Clyde, Richard A. Alaimo Associates,
Princeton Aqua Sciences, Inc., and Roy F. Weston. Page 5-30 of the
RI (Volume 2) indicates that "The configuration of the potentiome-
tric s~rface contour lines (See Figure 5.7) indicates a general
grou~d-wate~ flow direction from the northwest to the southeast and
south, toward Assiscunk Creek". Several sections in both the RI and
FS indicate that this "flow description" applies to both the shallow
aquifers and the Raritan-Magothy Aquifer. Other sections in the
reports indicate that this "flow description" only applies to the
shallow aquifers in the plestocene deposits. The Townships request
written clarification from B&V as to whether this "flow description"
is limited to an analysis of the shallow aquifer flows and/or
whether the "flow description" is also applicable to flows in the
Raritan-Magothy Aquifer. At the June 12, 1986 public meeting,
Lawrence J. Hosmer of B&V presented a slide which was shown to the
public which appeared to indicate that the f~ow description applies,
only to the shallow aquifers in 'the plestocene deposits.

B. Changes in G'roundwater Flow. As indicated..pre~iously, B&V
has. offered, an, opinion that the, :9roundwater,:flow~, is:.,fram,;,.the:. north- '
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PARKER, MC;;CAY & CRISCUOLO
PAG E 5
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west to the southeast to the south towards the Assiscunk Creek. B&V
has concluded that the contamination found in "upgradient" wells
cannot be caused by the landfill inasmuch as the landfill is hy-
drologically "downgradient". B&V has also indicated that ground-
water flows can be changed by heavy water utilization and pumping in
the area. The townships feel that an explanation is in order from
B&V to reconcile these two statements and opinions. The Townships
request written conf~rmation from B&V that the contamination found
in the supposedly "upgradient" wells cannot possibly be coming from
the FLR waste fill area.
c. Outcrop Area and Recharge of Raritan-Magothy Aquifer. B&V
indicates that the waste fill area is located in close proximity to
the Raritan-Magothy recharge area and that this aquifer is recharged
by the Delaware River and through vertical downward infiltration
from overlying water sources. B&V has also indicated that the
Merchantville Clay Formation, which overlies the Raritan-Magothy
Aquifer, .... is fairly. irregular and suggests the presence of
remnant fluvial-induced, erosional features.". Notwithstanding the
foregoing comments, B&V has determined that the existence of the
Merchantville Clay Formation can be expected to protect the Raritan-
Magothy Aquifer from leachate contamination. Thes~ statements and
this analysis appears to conflict. If the Raritan-Magothy is
"impermeable", the Raritan-Magothy Aquifer would not be able to be
recharged by vertical seepage from shallow aquifers. The Townships
request a written explanation from B&V further expanding upon the
.permeability factors" of the Merchantville Clay Formation. It is
also to be noted, as I advised at the June 12 public meeting, that
Beatrice Tylutki testified in court proceedings in the late 1970's
that the Merchantville Clay Formation had been pierced under the
waste fill area and that the waste fill leachate was then contam-
inating the Raritan-Magothy Aquifer. An explanation is in order as
to why DEP and B&V's current statements seem to conflict with prior
court testimony given by a former DEP employee. In summary, DEP's
position during the Court proceedings in the 1970's was that the
Merc~antville Clay Formation had been pierced and that the waste
fill area was contaminating the Raritan-Magothy Aquifer. DEP and
B&V'.s current position appears to be that the Merchantville Clay
Formation has not been pierced and that there is no contamination
seeping into the Raritan-Magothy Aquifer.
3. SURFACE WATER IMPACTS AND SOIL SAMPLINGS. Methylene
chloride was found in both the surface water and soil samples that
were taken. B&V concludes that water quality in the Assiscunk Creek
has .changed slightly in the last three years" and that several
constituents succeed the State's water quality standards. A review
of Table 6.1, which compares upstream and dOwnstream stations,
reveals that fecal chloroform, fecal strep and phosphate levels are
all in violation of the State standards. A series of other chemi-
cals, including phenol, were present in both the Assiscunk Creek anr
the. drUnage.; c:ba!U1el...:loc:a~ed. adjacent .to.Cedar:~Lane. extension..,. B"
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indicates that Wit is also theoretically possible that these con-
'sti tuents are emanating from the waste fill since'. phenol was present
in the water and BV-2S and pentachlorophenol was present in the soil
in B-03.w. B&V also found phalate contamination actually increased
in concentration at approximately fifty-four feet into the Merchant-
ville Formation. The existence of the methylene chloride contamina-
tion along with the other contaminants that were found at the levels
that they were found. in the soils and in the Assiscunk Creek should
have spurred additional investigation by B&V. However, B&V simply
reported the existence of the contaminants and stopped its inves-
tigation after rendering an opinion that the contamination could not
be caused from the waste fill area. It is obvious to anyone inves-
tigating the FLR Landfill that it is the only source of contamina-
tion in those portions of Florence and Mansfield Township. B&V
should have expanded its investigation as opposed to stopping its
investigation when these contaminants, at the levels found, were
detected.
4. REMEDIATION ALTERNATIVES. At the June 12, 1986 publi~
meeting, DEP and B&V indicated that Alternative 3, with modifica-
tions thereto, would be the selected remediation procedure. The
Townships feel that additional off-site moni toring"wells should be
included in the remediation process to further investigate contami-
nant levels. Additionally, provision for potabl~ water supply for
the residents in the area should be included in the remediation
alternative. Many of the residents living in close proximity to the
landfill have been drinking bottled water since the late 1970's.
Installation of a water line connected to the Burlington Township
public water supply is in order for the protection of these indi-
viduals. .
s. BURLINGTON COUNTY SOLID WASTE MANAGEMENT FACILITIES COM-
PLEX. it is my understanding that 2-ethyl hexyl phtalate
concent~ations were found in wells that have been installed by
Burl;ngton County on the tract of land adjacent to the FLR Landfill
where the new County Landfill is to be located. Based upon the B&V
reports, this area is supposed to be Wupgradientw. An explanation
is requested from B&V as to how this situation could occur. As
referred to earlier in this letter, B&V has neglected to investigate
the sources of the contaminants found in the supposedly Wupgradient"
wells. A more intense and detailed investigation and analysis of
this issue must be conducted.
DEP must withhold additional approvals of the County Landfill
project until these contaminant sources are located and remediation
has been completed with. respect to this Superfund site.
6. QUALITY ASSURANCE PROBLEMS. The accuracy of the lab tests
and data that was compiled is questionable in light of all of the
Quality Assurance problems and improper testing procedures utilized. >
The' conclusions'.~ drawn', by: 'B&V.are"based.':upon:--the; inaccurate.:'and:': .
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PAG E 7
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incorrect data. It is suggested that retesting and reanalysis is in
order to assure the quality of the lab. results and data on hand.

Dan Raviv Associates will be forwarding its report to you with
respect to certain technical hydrogeologic issues. The comments and
concerns raised by Dan Raviv are intended to be incorporated by
reference into this report.
The Townships look forward to promptly receiving B&V's written
comments in response to this letter and Mr. Raviv's report.
/
cc:
. Dan Raviv
Marion E. Hay, Township.Clerk
RCM: j m
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