United States
            Environmental Protection
            Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-86/030
Sept 1986
«EPA
Superfund
Record of Decision
            Sharkey Landfill, NJ

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
 EPA/ROD/RO2-86/030
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 SDPERFDND  RECORD OF DECISION
 Sharkey Landfill, NJ
                                                            5. REPORT DATE
                       September  29, 1986
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
 U.S. Environmental Protection Agency
 401 M Street,  S.W.
 Washington,  D.C.   20460
             13. TYPE OF REPORT AND PERIOD COVERED
             	Final  ROD Report
             14. SPONSORING AGENCY CODE

                        800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
    The Sharkey  Landfill site comprises approximately 90 acres in the Parsippany  - Troy
 Hills and East  Hanover Townships, Morris County,  NJ.  The site consists of  4     +
 disconnected  areas:   North Fill, South Fill,  Northwest Fill, Southwest Fill.   Two
 aquifers are  found at this site.  The upper  aquifer, which comes into contact  with fill
 material in portions of the landfill, primarily drains into the bordering Rockaway and
 Whippany Rivers.   These rivers are used for  recreational activities, and the Rockaway
 serves as a potable water source further downstream.  The Passaic Valley Water
 Commission utilizes  this aquifer for public  supply.   The lower aquifer completes a
 public supply well in East Hanover Township.   In  1945 the site began accepting municipal
 solid waste from  NJ counties.  Between 1962  and 1969, Ciba-Geigy Co. allegedly disposed
 of 753,000 Ibs. of hazardous and/or toxic materials.  From April 1972 to May 1972,
 25,700 tons of  non-chemical wastes and 1,160  tons of "liquid and/or chemical wastes"
 described as  cesspool-type, and sludge from  the adjacent Parsippany-Troy Hills Sewage
 Treatment Plant (PTHSTP) were also deposited at the  site.  Between 1979 and 1981 refuse
 was removed from  the South Fill portion of the site  and re-disposed in the  North Fill
 area for a PTHSTP expansion.  Currently, landfill contaminants have migrated and
 continue to migrate  into the shallow aquifer  beneath the site and the adjacent surface
 water bodies.   Although available data do not suggest that significant quantities of
 (See Attached Sheet)                      	__	
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lOENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
 Record of Decision
 Sharkey Landfill,  NJ
 Contaminated Media:  gw, sw, soil,
 Key contaminants:  VOCs, TCE, organics,
  inorganics, heavy metals
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report!
          None
1. NO. OF PAGES

          66
                                               20. SECURITY CLASS (Tliil page!
                                                         None
                                                                          22. PRICE
BPA form 2220-1 (R«». 4-77)   PREVIOUS EDITION is OBSOLETE

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EPA/ROD/RO 2-86/030
Sharkey Landfill, NJ

16.  ABSTRACT (continued)
hazardous substances are being  released at  the  present  time,  there exists
the potential for future releases  of  contaminants  at  levels which could pose
a serious threat to public health  and the environment.   The primary
contaminants of concern include:   VOCs,  TCE,  organics,  inorganics, and heavy
metals.
   The selected remedial action includes:   capping of the landfill in
accordance with relevant RCRA Act  requirements,  including the appropriate
grading of fill areas;  a venting system for  landfill  gases; extraction and
treatment of shallow ground water  and leachate;  surface water controls to
accommodate seasonal precipitation and storm runoff as  well as erosion
control for river banks; security  fencing to restrict site access; and
environmental monitoring program to ensure  the  effectiveness  of the remedial
action.  The estimated  capital  cost is 323,173,000 with annual O&M of
$330 ,000 .

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                       RECORD OF DECISION

                 REMEDIAL ALTERNATIVE SELECTION


Site

Sharkey Landfill, Morris County, New Jersey


Documents Reviewed

I am basing my decision on the following documents, which describe
the analysis of remedial alternatives considered for the Sharkey
Landfill site.

  - Remedial Investigation Report, prepared by Alfred Crew
    Consulting Engineers, and Hazen and Sawyer, dated July 1986

  - Evaluation of Alternatives (Feasibility Study) Report,
    prepared by Alfred Crew Consulting Engineers, and Hazen and
    Sawyer, dated August 1986

  - Responsiveness Summary, dated September 1986

  - Staff summaries and recommendations


Description of Selected Remedy

  - Capping of the landfill in accordance with relevant Resource
    Conservation and Recovery Act requirements, including the
    appropriate grading of fill areas

  - A venting system for landfill gases

  - Extraction and treatment of shallow groundwater and leachate

  - Surface water controls to accommodate seasonal precipitation
    and storm runoff as well as erosion control for river banks

  - Security fencing to restrict site access

  - An environmental monitoring program to ensure the effective-
    ness of the remedial action

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                              -2-
Declarations

Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act  of 1980,  and  the National Oil
and Hazardous Substances Pollution Contingency Plan (40 CFR
Part 300),- I have determined that the alternative described
herein is a permanent remedy that will control the source of
contamination and mitigate off-site migration of contaminants.

I have further determined that  this remedy is the lowest cost
alternative that is both technically feasible and reliable.  It
effectively mitigates and minimizes threats  to and provides
adequate protection of public health and the environment.  At
the same time, it meets all applicable and relevant Federal and
State public health and environmental requirements.  Further,
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.
                                                    J& ~~
Date       I                  Christopher JJf Daggefct
                             Regional Administrator

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           SUMMARY FOR REMEDIAL ALTERNATIVE SELECTION

                     SHARKEY LANDFILL SITE
SITE LOCATION AND DESCRIPTION

The Sharkey Landfill site is located in the Townships of
Parsippany-Troy Hills and East Hanover, Morris County, New
Jersey.  The study area lies within the area bounded by Route
46 to the north, New Road to the west, and the Rockaway River
to the east.  To the south, sections of the site extend beyond
Route 280 into the neck between Troy Meadows and the Hatfield
Swamp.  The general area in which the landfill is located can
be described as residential and light industrial to the north
and west, with the Whippany River and considerable swamp land
to the east and south.  The site location is shown in Figure 1.

The site is located approximately 1/2 mile southwest of the
Pine Brook section of the Township of Montville, and is centered
approximately at 40° 50' 50" north latitude and 74° 20' 50"
west longitude.  The landfill site consists of approximately
90 acres of irregularly-shaped, disconnected areas.  The site
has been divided into the following areas as shown in Figure 2:

  0 North Fill; The North Fill area is located on an island at
    the northern end of Sharkey Road, and is bounded by branches
    of the Rockaway River.  The North Fill Bridge over the west
    branch provides limited access from the South Fill to the
    26-acre island.  The island is owned by the Township of
    Parsippany-Troy Hills.

    This island site contains fill with intermittent soil cover
    to a depth of 80 feet, resulting in steep, sparsely vegetated
    slopes containing a number of leachate seeps and eroded
    gullies.  The highest portions of the North Fill were deposi-
    ted there from the South Fill during the second expansion
    of the Parsippany-Troy Hills Sewage Treatment Plant (STP).
    The Rockaway River has undercut the landfill's banks and
    exposed waste materials along the steep banks.

  0 South Fill; Most of the South Fill site is located southeast
    of Sharkey Road and is generally bounded on the east by the
    Rockaway River, on the south by the Parsippany-Troy Hills
    STP and the Whippany River, and on the west by the STP and
    an adjacent wooded area off Edwards Road.  This fill also
    includes the area northwest of Sharkey Road between two
    ponds and the Rockaway River.  The South Fill site is owned
    by the Township of Parsippany-Troy Hills.

    The South Fill, excluding the sewage treatment plant, is
    approximately 29 acres in size.  The original treatment
    plant structures were reportedly built on piles over the
    landfilled wastes, but most of the wastes were removed
    from the areas during construction of the expanded plant
    facilities.

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                            -2-




*•*-Si- --^^-*E^ ^ CV*
=J^^i>fei=ft AN
^~l-C=-~-rr£JZr&.-K S\l

        S^^^rJ FILL AREAS
                       FIGURE  1
            SHARKEY LANDFILL LOCATION PLAN
                                 2000
                           SCALE

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                             -3-
                                                   NORTH FILL
NORTHWEST
   FILL
i^=^>>  SOUTH FILL •   AJ

     SOUTHWEST
        FILL
                                             000'
                         1000'
                                                  SCALE IN FEET
            Figure 2  :   Sharkey Farms Landfill
                         Site Map

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                            -4-
  The removed material  associated with  the  first  expansion
  was relocated immediately  northwest of  the  plant  where it
  formed the upper portion of  the mound on  the  South Fill.
  The fill deposited  in this area ranged  up to  70 feet  high.
  The mound's side slopes are  steep but the earth cover
  appears to be fairly  uniform and, except  where  some erosion
  has occurred, to be supporting vegetation.  Gas vents are
  located along the top of the South Fill mound where the
  re-deposition occurred, but  some of the vents have been
  vandalized and are  inoperative.

  Access to this fill is mostly unrestricted  except for gates
  recently constructed  at the  entrance  of Sharkey Road  and
  one near the North  Fill Bridge.  The  two  ponds, located
  northwest of the South Fill  adjacent  to Sharkey Road, are
  reportedly clean and  supporting fish, amphibians, and
  aquatic vegetation, despite  the presence  of plastics  and
  gas bubbles.

0 Northwest Fill;  The Northwest Fill consists of  two fill
  areas divided by Route 280 and relocated  Edwards  Road.  The
  area southwest of Edwards  Road, estimated at  15 acres, is
  bordered by the new Whippany River to the south,  Troy
  Meadow to the west, and by a heavily-wooded area  south of
  the New Road/Edwards  Road  intersection.   This portion of
  the Northwest Fill  site is owned by COMG  Realty,  c/o  Ringlieb
  Family.

  The area northeast  of Route  280 is bounded  by Edwards Road
  to the northeast, the Whippany River  to the southeast, and
  a wooded area bordering New  Road to the northwest.  This
  portion of the Northwest Fill site, with  an estimated area
  of 11 acres, is owned by Dowel Associates.

  The two portions of this fill area have sparse  to intermittent
  soil cover with many  large areas of exposed refuse, including
  rusted drums, particularly in the portion southwest of
  Edwards Road.  The  topographic relief created by the  landfill
  operations in these areas  is not as pronounced  as in  the
  North and South Fill  areas,  generally reaching  an estimated
••: elevation of 20 to  30 feet above the  adjacent swamp to the
  southwest.  Access  to these  site areas  is limited only by
  the terrain.

8 Southwest Fill;  This  fill  area is located in  East Hanover,
  and is bounded by Ridgedale  Avenue to the northeast,  a
  drainage ditch to the southeast, the  old  Whippany River
  channel to the southwest,  and the relocated new Whippany
  River to the northwest.  The Southwest  Fill site, with an
  estimated area of 9 acres, is owned by  Wildlife Preserves.

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                              — 5 —
    The Southwest Fill is relatively level and ranges about 10
    to 20 feet above the adjacent swampland.  It also displays
    generally good soil cover and vegetative growth.  Part of
    the original landfill was reportedly used for the redispos-
    ition of approximately 184,000 cubic yards of wastes and
    cover material excavated during the construction of Route
    280 through the landfill.  However, recollections of New
    Jersey-Department of Transportation personnel during the
    construction period indicate that some of the excavated
    wastes were deposited in the southwest portion of the South
    Fill.  Access to the Southwest Fill is limited only by the
    terrain.

SITE HISTORY

During the 1930's, the site was used as a pig farm, and in 1945,
landfilling operations began.  In addition to accepting municipal
solid waste from several counties in northern New Jersey, the
landfill allegedly received hazardous and/or toxic materials
between 1962 and 1969 from Ciba-Geigy Company.  Records indicate
that approximately 560,000 Ibs of toluene, 130,000 Ibs of benzene,
40,000 Ibs of chloroform, 20,000 Ibs of methylene chloride, and
3,000 Ibs of dichloroethylene were disposed at the site.

Operating reports filed by Sharkey Farms, Inc. with New Jersey
Department of Environmental Protection (NJDEP) for the period
from April 13, 1972 to May 10, 1972 indicate that approximately
25,700 tons of non-chemical wastes (90 percent household, 8
percent commercial, and 2 percent industrial) and 1,160 tons of
"liquid and/or chemical wastes" described as cesspool-type were
deposited at the site.  In addition to the aforementioned
wastes, sludge from the adjacent Parsippany-Troy Hills STP was
deposited in the landfill.

Sharkey Farms ceased landfill operations on September 9, 1972.
However, it has been reported but not verified that about three
million gallons of wastewater of unknown composition were taken
to "Sharkey Disposal-Pine Brook" between 1972 and 1974.  It is
not known, however, whether this is the Sharkey Landfill site.
The source of this wastewater was Koppers Chemical Company which
manufactured organic compounds.  Koppers is no longer in operation,

The Sharkey Landfill is believed to have remained inactive until
1979, when excavation began for the expansion of the Parsippany-
Troy Hills STP.  Several acres of refuse were removed from the
South Fill and re-disposed in the North Fill area.  No evidence
of chemical waste disposal was reported during the excavation.
The expansion project was completed in 1981.  Since that time,
the site has apparently remained unchanged.

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                              -6-
GEOLOGY

The site is located in the Piedmont Physiographic Province.
It is situated within the Rockaway and Whippany River flood-
plains, in which recent deposition of clay,  silt, and sand have
occurred.  The area is characterized by a swampy lowland with a
few surrounding ridges and isolated hills rising above the
plain.  Most of the area lies between the elevations of 170 and
440 feet above the mean sea level.  The alluvial deposits are
underlain by stratified sands and gravels of glacial outwash of
the Wisconsin Epoch of Pleistocene Age.

The Wisconsin glaciation of Pleistocene Age  has resulted in
significant morphological change of topography within this
physiographic province.  During the Pleistocene Era, this area
was located near the northwestern shoreline  of a very large
glacial lake, termed Lake Passaic, bordered  by the highlands to
the southeast.  This lake was fed by outwash from a northerly
retreating glacier that formerly occupied the area.  The natural
drainage outlets for the pre-lake area were  to the southeast,
near Summit, New Jersey.  This outlet area was blocked by
glacial moraine during the development of the lake.  Lake
Passaic grew in size as the glacier retreated northward.  The
nearest that the Lake Passaic shoreline came to the landfill
was near Boonton, approximately five miles northwest of the
site.

As the glacier retreated and Lake Passaic grew, coarser outwash
deposits were deposited in areas to the south of the retreating
glacial front.  Shoreline areas also received sediment-laden
runoff from the highlands to the west and the Basalt ridges to
the north and east.  As the glacier retreated even further
northward from this area, silt and varved clay lake deposits
accumulated on the floor of the expanding lake.  Both vertical
and lateral changes in composition occur in  this type of deposit.

Pleistocenic glaciation buried the previous  topography including
the preglacial stream valley in the area. The western portion
of Essex County delineates the extent of some of these buried
valleys.  According to this data, the southern part of the site
lies near the western fringe of the buried Millburn Valley.
The buried valley may be influencing groundwater flow patterns
in the area.

Bedrock belonging to the Brunswick Formation of Triassic Age
underlies the unconsolidated deposits at the site.  The depth to
bedrock on the site is believed to be approximately 150 feet on
the southern end of the landfill decreasing  to 30 feet on the
northern end.  The bedrock is composed of interbedded red shale
and sandstone with occasional conglomeritic  beds.  The thickness
ranges from 6000 feet to 8000 feet.

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                              -7-
The southern tip of a Triassic basalt flow known as Towoco
Mountain occurs less than 1/2 mile north of the site.  It is
much more resistant than the adjoining shale and sandstone and
thus forms a prominent, crescent shaped ridge approximately seven
miles long.  The Triassic rocks exhibit as monoclinal feature
and dip west-northwest at about eight to ten degrees.  An
extensive northeast-southwest trending normal fault has uplifted
Precambrian Age metamorphic rock to ground level, approximately
seven miles west of the site.

CURRENT SITE STATUS

During the remedial investigation of the Sharkey Landfill site,
the following activities were undertaken:

  - Electromagnetic and magnetometer survey of the entire site

  - Installation of twenty-six monitoring wells

  - Air monitoring

  - Collection and priority pollutant analysis of the following:
     0 Five shallow soil samples
     0 Thirty-two groundwater samples
     0 Eighteen surface water and sediment samples from the
       Rockaway and Whippany Rivers

The results of the chemical analyses of these samples are
presented in Appendix 1.

The remedial investigation revealed that the site is characterized
by five distinct material types:  fill, upper alluvial deposits,
varved clay, lower glacial outwash deposits, and bedrock.  The
two aquifers found at this site - one in the upper alluvial
deposits (the upper aquifer) and one in the lower glacial
outwash deposits (lower aquifer) - are separated by the clay
layer.  This clay layer is estimated to have an average thickness
of about 25 feet, an overall permeability of 1.3 x 10~7 centi-
meters per second (cm/sec), and is believed to be continuous
throughout the site.

The upper aquifer, which comes in contact with the fill material
in portions of the landfill, primarily drains into the Rockaway
and Whippany Rivers.  These rivers are used for recreational
activities in areas near the landfill, and the Rockaway serves as
a potable water source further downstream.  While no public ground-
water supplies are known to be derived from this aquifer in the
immediate area, three private wells are believed to exist,
upgradient of the site.  The Passaic Valley Water Commission
does utilize this aquifer for public supply, although the
intake for this water supply is greater than eight miles down-
stream of the Rockaway/Passaic River confluence.

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                              -8-
The lower aquifer, which is a major drinking water source in
the area, primarily flows in the southwest direction.   A public
supply well in East Hanover Township,  which reportedly produces
500,000 gallons per day, is completed  in this aquifer.  This
well is within two miles of the site in an upgradient  direction.
Three other private wells are also installed in this aquifer
within a mile of the site,  and are likewise considered
upgradient.

In general, while some contaminants have been found in the
sampled media at and near the Sharkey  site, they were  found at
relatively low concentrations.  Based  on the types and concen-
trations of these contaminants, the site does not pose a signi-
ficant public health or environmental  risk at this time.
Results from the air monitoring performed during the installation
of the monitoring wells suggest low probability of respiratory
or dermal hazard from air-borne volatile organics under ambient
conditions.

During the electromagnetic  survey, five anomalous electromagnetic
conductivity areas were delineated.  Subsequent magnetometer
surveys indicated that four of these anomalies were probably
caused by buried iron mass.  A soil sample was taken of the
remaining anomalous area, but no significant detection of
organic compounds was reported.

The soil sampling points were selected at leachate seep drain-
ageways, storm water drainageways and  the area of unexplained
anomalous electromagnetic readings.  Seven volatile organic
compounds were identified from these samples at relatively low
concentrations:  acetone, 2-butanone,  naphthalene, phenanthrene,
2-methylnaphthalene, fluoranthene, and pyrene.  Acetone and
2-butanone were also found  in groundwater samples.  In addition,
four pesticides were identified in these soil samples:  dieldrin,
4,4'-DDD, endrin, ketone, and PCB-Aroclor 1254.  Several inorganic
compounds were also detected, but at very low concentrations.

Of the twenty-six monitoring wells installed at the site,
fourteen were screened in the upper aquifer and twelve were
screened in the lower aquifer.  In addition to these monitoring
wells, groundwater samples  were taken  from nearby residential,
commercial, and public supply wells.  Three of the residential/
commercial wells were screened in the  shallow aquifer; two were
screened in the lower aquifer, and one in the bedrock aquifer.

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                              -9-
The analytical results of the samples of the shallow aquifer
monitoring wells indicated low levels of organic contamination,
with only benzene and trichloroethene exceeding drinking water
standards.  Inorganic chemicals, primarily heavy metals, were
also detected in the shallow aquifer.  Some of these contaminants
were also found in excess of drinking water standards in both
rivers near the landfill.  However, a short distance downstream,
the contaminant levels are low.  The overall adverse effects of
the landfill on the water quality of the Rockaway and Whippany
Rivers appears to be minimal at this time.  Also, the next
surface water intake, for the purpose of public consumption, is
approximately eight miles downstream of the site; thus, any
contaminants would be diluted.

The analytical results of the samples of the deeper aquifer reveal
the presence of cadmium, lead, chromium, iron, manganese, mercury,
and nickel at concentrations in excess of drinking water standards,
indicating that the landfill has impacted the aquifer.  The
analyses of the lower aquifer also found one organic compound,
benzene, in one well at a concentration of 13 micrograms per
liter (ug/1).  However, this detection is believed to be an
isolated occurrence which does not indicate significant organic
contamination in the lower aquifer.

While none of the samples of the residential and commercial wells
contained organic compounds, iron and manganese were found to
exceed drinking water standards in all wells.  However, iron
and manganese appear to be common to the area.  Low levels of
cyanide, phenols and chromium were found in the East Hanover
public supply well; they were below drinking water standards.
Based on the results of the remedial investigation, the location
of the existing potable wells in the vicinity of the Sharkey
site, and the flow direction of the two aquifers, the landfill
does not appear to be adversely affecting potable water quality
in the area at this time.

Two rounds of surface water, sediment, and leachate samples
were taken, one during dry weather conditions and the other
during wet weather conditions.  The dry and wet weather surveys
detected low concentrations of organic or inorganic priority
pollutants.  Cadmium and mercury concentrations exceeded the
drinking water standards downstream of the site at the Whippany
River during wet weather conditions and lead concentrations
exceeded the standards at the Rockaway River during dry weather.
However, cadmium and lead were found at higher concentrations
upstream of the site, and iron and manganese exceeded drinking
water standards at upstream sampling locations.  The data
suggest that the site may not be the only source of these
metals.  Cyanide was found during the wet weather survey at
location SD-7, which is close to the South Fill, at a concen-
tration of 33 ug/1, which is well below the drinking water
standard of 200 ug/1.  This may indicate that cyanide is not an
environmental concern.

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                              -10-


ENFORCEMENT

The U.S. Environmental Protection Agency (EPA)  sent Information
Request Letters and Notice Letters to potentially responsible
parties (PRP's) during the years 1983 and 1984.   The PRP's decli-
ned to undertake the remedial investigation and  feasibility study
(RI/FS).  Clba-Geigy met with EPA and NJDEP in  May of 1984 to
discuss previous site investigations and planned RI/FS activities.

Additional Information Request Letters were sent by EPA in
September 1986.  Notice Letters asking the PRP's to voluntary
undertake the Remedial Design and Remedial Action activities
will be issued after the designated deadline for response to
the information letters.  On September 22, 1986, EPA and NJDEP
met with counsel for Ciba-Geigy to discuss the  company's
efforts to locate additional parties who may have disposed of
hazardous waste at the site.

EVALUATION OF ALTERNATIVES

The evaluation of the results of the Remedial Investigation
provided the basis for establishing the cleanup  goals and
objectives for site remediation.  The cleanup goals and objectives
for the Sharkey Landfill site include the following:

0 Minimize the potential for migration of the low levels of
  groundwater contamination                                         I

0 Minimize the risk to the public from exposure  to waste and
  contaminated soil on the site

The purpose of a Feasibility Study (FS) is to develop and assess
remedial action alternatives based on site-specific conditions.
At a minimum, one alternative should be developed for each of five
categories outlined in the National Contingency  Plan and EPA's
FS Guidance.  The development and screening of  remedial techno-
logies for the Sharkey Landfill involved the following procedure:

- From results of Remedial Investigation, identify site problems
  and pathways of contamination;
- Identify general response actions that address site problems
  and meet cleanup goals and objectives;
- Identify and screen possible remedial technologies in each
  general response action based on applicability to site conditions;
- Combine technologies into feasibile alternatives;
- Screen alternatives based on protecting the environment,
  public health, public welfare, and cost.

A list of general response actions that appeared to be appropriate
for the Sharkey site is presented in Table 1.  This table also lists
the associated remedial technologies for each action along with an
assessment of the applicability of each remedial action based on
site characterisitics, waste problems, and existing contamination
at the site.  Some of the technologies considered were innovative.

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                                         TABLE 1
          ACTION
      SHARKEY LANDFILL

 SCREENING OF ALTERNATIVES

APPLICABILITY/LIMITATION OF
   SPECIFIC TECHNOLOGIES


     APPLICABILITY
       SITE/WASTE LIMITATIONS
            TO TECHNOLOGY
1.  Surface Water Controls
    A.   Capping
        1.  Synthetic membrane


        2.  Clay
        3.  Asphalt
        4.  Concrete

        5.  Chemical additives/
            Stabilizers

        6.  Multilayered Cap

    B.  Grading
        1.  Scarification
        2.  Tracking
        3.  Contour Furrowing
    C.   Revegetation

        1.  Grasses
        2.  Legumes, shrubs, trees
          Yes
         Maybe
          Yes
          No
          No

         Maybe
          Yes

          Yes
          Yes
          Yes
          Yes
          Yes

          Yes
          No
Slopes may restrict use of certain
materials.  Also capping is required
by NJDEP for closure.

Incompatibility with site wastes;
slope considerations; may be part of
multimedia cap.
Probably as part of multilayered cap.
Rigidity unsuitable for unstable land-
fill environment; also may be incom-
patible with waste.
May be useful in reducing shrink/swell
behavior or neutralizing acid cover
soils.
An effective solution.

In conjunction with cap; not suitable
by itself.  Slope should be sufficient
to promote runoff without erosion.
Primarily used for preparing top cap
layer for revegetation.
Tracking used principally in steep
slopes.

Necessary to prevent erosion and desi-
cation of cap layers.

Root systems would crack cap allowing
infiltration.

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                                  TABLE 1  (Page 2 of. 1)
                                     SHARKEY LANDFILL
                            SCREENING OF REMEDIAL TECHNOLOGIES
          ACTION
APPLICABILITY
       SITE/WASTE LIMITATIONS
            TO TECHNOLOGY
    D.  Diversion and Collection
        System
        1.  Berms
        2.  Ditches, trenches
            and swales
        3.  Terraces and benches

        4.  Chutes and downpipes

        5.  Seepages or recharge
            basins
        6.  Storage ponds
        7.  Levee/flood walls


2.  Leachates and Groundwater Controls

    A.  Capping (See l.A)

    B.  Barriers
     Yes



     Yes



     Yes

     Yes

    Maybe

    Maybe

    Maybe


    Maybe
     Yes

     Yes
        1.  Location
            a.  Downgradient
            b.  Upgradient
            c.  Horizontal
                (bottom sealing)
     Yes
    Maybe
Required to control erosion, runoff
during construction and as a secondary
device for storm water control.

Particularly applicable during con-
struction; should be used in conjunc-
tion with other controls in a perman-
ent system.
Effective perimeter collection
mechanisms.
Primarily used in conjunction with
grading.
Only if necessary during construction.
Not long-term erosion control measure.
Possible for surface water diversion
depending on pern^ability of soils.
In conjunction with surface water
collection systems.  Can be used to
dampen runoff flows from site.
Probably ineffective due to inherent
localized flooding.
Geology of site may enhance effective
placement of barrier in shallow aqui-
fer.  The varved clay provides concep-
tually the potential for "keying" a
vertical retention barrier or slurry
wall.
                Already present
                clay deposit.
                i.n form of natu

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                              TABLE 1  (Page 3 of 7)
                                 SHARKEY LANDFILL
                        SCREENING OF REMEDIAL TECHNOLOGIES
      ACTION
APPLICABILITY
    SITE/WASTE LIMITATIONS
         TO TECHNOLOGY
    2.  Material/Construction
        a.  Soil/bentonite
            slurry wall
        b.  Cement/bentonite
            slurry wall
        c.  Grout curtains
        d.  Sheet piling
            (steel)
        e.  Synthetic membrane

C.  In-Situ Permeable Treatment Beds
    Maybe



     No

    Maybe



    Maybe

    Maybe

     No
D.  Groundwater Pumping



E.  Subsurface Collection System




    1.  Drainage ditches/trenches

    2.  French drains/tile

    3.  Pipe drains
        (multimedia drains)
     Yes
    Maybe
     Yes

     No

     Yes
May be chemically attached by
leachate resulting in greater
permeability; strong acids or
bases may dissolve soil/bentonite.
Extra strength provided by cement
makes wall more permeable.
Grout can be mixed to set up fast
enough to fill large voids, but is
very expensive.  May be chemically
attacked by leachate.
(See I.A.I).

Most treatment bed materials are
not effective for organic conta-
minants.  Volume of leachate
generated at site would quickly
surpass capability of beds.

Used in conjunction with capping
and treatment.  To lower groundwater
and extract leachate/groundwater.

Effective leachate/groundwater
collection mechanism for shallow
aquifer.  Combination cap and
slurry wall, if implemented,
would limit effectiveness.
May have clogging problems.

Easily clogged.  Difficult to
maintain.
May require filter cloth envelopes
to prevent clogging.
Ui
I

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                               TABLE  1   (Page 4 of 7)
                                  SHARKEY LANDFILL
                         SCREENING OF REMEDIAL TECHNOLOGIES
      ACTION
APPLICABILITY
        SITE/WASTE LIMITATIONS
             TO TECHNOLOGY
Excavation and Removal of
Waste and Soil
    Maybe
Removal/Containment of Contaminated
Sediments

A.  Sediment Removal

B.  Sediment/turbidity controls
    1.  Silt curtains
    2.  Cofferdams/sheet pile
        stream diversion/barriers

In-Situ Treatment
Water Treatment
A.  Incineration/Destruction
     No



    Maybe


    Maybe
     No
B.  Gaseous Waste Treatment
C.  Liquid Waste Treatment
    1.  Biological treatment
     No
Although some excavation of waste and
soil may be necessary as part of site
grading, the volume of waste/soil at
the site will probably preclude com-
plete removal/excavation, unless a
new RCRA facility is created on or
off-site.

Not applicable as contaminated sedi-
ment was not measured at the site.
Use if cannot excavate during dry
weather.

Generally unproven, experimental
technologies often waste specific,
Not applicable for site.  Potential
contamination or existing contamina-
tion is at very low levels which are
not suitable for incineration tech-
nology.

No gas problems or potential volatile
organics were observed or monitored
at the site.

Existing contamination levels and
specific compounds found
organics) suggest on-site
treatment is not applicable.

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                                    TABLE 1  (Page 5 of 7)
                                       SHARKEY LANDFILL
                              SCREENING OF REMEDIAL TECHNOLOGIES
          ACTION
                                     APPLICABILITY
        SITE/WASTE LIMITATIONS
             TO TECHNOLOGY
7.
        2.  Chemical treatment

        3.  Physical treatment
            a. Activated carbon
            b. Air stripping
        4.  Discharge to publicly
            owned treatment works

    D.  Sludge Handling and Treatment

        1.  Thickening/Dewatering
        2.  Treatment

    E.  Solidification/Encapsulation
    1.  Solidification
    2.  Encapsulation

Land Disposal/Storage

A.  Landfills
                                          No

                                         Maybe




                                         Maybe


                                          No
                                          No
                                             Maybe
    B.  Surface Impoundments
    C.  Land Application
                                         Maybe
                                          No
Same waste limitations as for biolo-
gical treatment
On-site treatment of the shallow
aquifer could involve activated carbon
and/or air stripping due to the vola-
tile organics found in the shallow
wells and at very low concentrations.
POTW on-site (Parsippany-Troy Hills
Advanced Waste Treatment System)
No observed sludge problems at
site.
the
Waste and site characteristics
indicate that this technology is not
applicable for the site.
Although no known RCRA off-site
facility has landfill capacity in the
immediate area, EPA guidelines
suggest that this alternative be
screened.

Liquid waste (leachate) could not be
merely collected and stored. May
require treatment depending on the
contamination concentrations.

Potential toxicity/hazardousness of
waste preclude land application.

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          ACTION
                                    TABLE 1  (Page 6 of 7)
                                       SHARKEY LANDFILL
                              SCREENING OF REMEDIAL TECHNOLOGIES
APPLICABILITY
        SITE/WASTE LIMITATIONS
             TO TECHNOLOGY
    D.  Waste Piles

    E.  Deep Well Injection


  _ F.  Temporary Storage

8.   Contaminated Water Supplies

    A.  Alternate drinking water
        supply
        1.  Deeper wells
        2.  Cistern or tanks
        3.  Municipal water system
    B.  Individual Treatment Units



9.   Relocation


10. Access Restriction

    A. Signs

    B. Fencing

    C. Security guards
                                              No

                                              No


                                              No



                                              No
    Maybe
    Maybe
    Maybe
    Maybe



     No


     Yes

     Yes

     Yes
    ^o
                Need further treatment/disposal.

                Lower aquifer is used as potable water
                source.

                Not applicable.
Public or residential potable wells
indicate concentrations below drinking
water standards.  Some temporary
measures may be applicable as other
long-term remedial actions are pursued
if wells were to become contaminated.
If future conditions indicate contam-
ination, these subtechnologies may be
applicable.  Note:  Sampling of lower
aquifer which is used for water supply
did not indicate any organic contam-
ination .

In future, if contamination is isola-
ted or if low levels of contamination
are found.

Unless emergency or unexpected circum-
stances occurs.

Restricting access to site will reduce
chances of physical contact with
contaminants and reduce chances of
normal personal injuries.
Security guards would not be c
effective.
                                                                                                 cr>
                                                                                                 I

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                                    TABLE 1  (Page 7 of 7)
                                       SHARKEY LANDFILL
                              SCREENING OF REMEDIAL TECHNOLOGIES
          ACTION
APPLICABILITY
        SITE/WASTE LIMITATIONS
             TO TECHNOLOGY
11. Erosion Control of River Banks
     Yes
12.  Gas Migration Controls

    A.  Passive pipe vents

    B.  Passive trench vents

    C.  Active gas collection system
     Yes

     Yes

     No

    Maybe
Must control refuse materials (tires,
bottles, debris) from leaving the
site along North Fill and South Fill
into the Rockaway River.

The level of methane system may re-
quire an active system.  Additional
air sampling is required to defined
methane levels.  In any event, NJDEP
required at least passive controls
for landfill closures.

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                              -18-
In following the procedure defined above,  screened alternatives
were combined to form more definitive alternatives which addressed
the Sharkey Landfill's remedial objectives and EPA guidance
requirements for Comprehensive Environmental Response Compensation,
and Liability Act (CERCLA) feasibility studies.  The results are
presented in Table 2 where six preliminary alternatives are
listed along with the corresponding remedial technologies.
Table 3 lists these alternatives and sub-alternatives along with
the associated capital and operation and maintenance costs.
These remedial alternatives are discussed  below:

1. No Action

The National Contingency Plan requires that a No Action alterna-
tive be evaluated.  Alternative 1, No Action, would involve
only long-term monitoring.  This monitoring program would
include sampling of air, groundwater, and  surface water at
several locations on a semi-annual basis.   Three new shallow
wells and one intermediate well, into the  lower aquifer, would
be installed at the site as part of this alternative.  This
alternative would allow contaminants to continue to migrate
into the environment unchecked.  While the present environmental
impact is limited, the data does show that hazardous materials
are currently migrating from the landfill  with the surrounding
surface water.  Since there were confirmed reports of hazardous
waste disposal at the site, there is a potential for a future
release of hazardous materials should this alternative be
implemented.

2. Minimal Action

Although Alternative 1 provides a program  for monitoring at the
site, additional actions would be needed to reduce existing
site problems.  Alternative 2 includes erosion control for the
banks of the Rockaway River, soil covering of the exposed
areas, rehabilitation of the North Bridge, additional site
security to control vehicle and pedestrian access to the Sharkey
Landfill, and a long-term monitoring program.  Figure 3 shows
the areas to be fenced and exposed areas to be covered with
clean fill.

Areas of severe erosion are located at the northern tip of the
North Fill and along the banks of the South Fill, both on the
Rockaway River.  In addition, there is no  fill cover on the
banks of the Rockaway River along these two fill areas, and
garbage, tires, glass and rags are exposed.  Under Alternative
2, the affected banks would be stabilized  through the use of
gabion walls.

-------
Preliminary
Remedial Actions
                                           TABLE 2
                           LISTING OF PRELIMINARY REMEDIAL ACTIONS
                            AND ASSOCIATED REMEDIAL TECHNOLOGIES


                                           Remedial Technologies
                                     Capping
             Site    Cover          (Grading)   Contain-                     Ground-
           Security Exposed Erosion Stormwater   ment    On-Site  Off-Site   water              Off-Site
Monitoring Control   Areas  Control  Control   Barriers Treatment Treatment Pumping  Excavation Disposal
1. No Action

2. Minimal Action

3. Capping

4. Containment of
   Site Contaminants
   and Capping
5. Capping and          X
   Groundwater
   Pumping, Treatment,
   Reinjection

6. Excavation of        X
   Landfill & Off-Site
   Disposal
X
X
X
X

X
X
X

XX
X X
X X



X
                                                                                                            VO
                                                                                                            I

-------
                                    -20-
                                  Table  3

                 Summary of Capital  and  Present  Worth  Costs
Alternative

1. No Action

2. Minimal Action

3. Multimedia Cap
   A. Sanitary closure
   B. Synthetic liner
   C. RCRA clay
   D. RCRA clay and
      synthetic liner

4. Capping and Containment
   A. RCRA "model" cap
   B. RCRA "model" cap for
      three areas and
      sanitary closure for
      two areas
   C. RCRA clay cap

5. Capping and Groundwater
   Treatment
   A. Air stripping system
      a. RCRA "model" cap
      b. RCRA clay cap
   B. Sewage Treatment
      Plant
      a. RCRA "model" cap
      b. RCRA clay cap

6. Excavation and Removal
   A. Existing RCRA site
   B. Sanitary landfill
   C. New RCRA site
Capital Costs

 $     40,000

    1,300,000
   15,240,000
   17,700,000
   21,400,000
   34,700,000
   54,800,000
   48,700,000
   41,500,000
   36,500,000
   23,173,000
   36,400,000
   23,100,000


  617,000,000
  201,000,000
  289,000,000
Present Worth*      Total
  O&M Costs     Present Worth
$  792,000

 1,339,000
 1,377,000
 1,424,000
 1,502,000
 1,801,000
  2,226,000
  2,152,000
  1,971,000
  2,952,000
  2,697,000


  4,602,000
  4,348,000
$    832,000

   2,639,000
  16,617,000
  19,124,000
  22,902,000
  36,501,000
  57,026,000
  50,852,000
  43,471,000
  39,452,000
  25,870,000


  41,002,000
  27,448,000
                617,000,000
                201,000,000
                289,000,000
  Based on 30 years and 10% interest  (factor  9.43)

-------
                           -21-

•_vj ^..A'-rvC^c?-^/^ •*"" "^
-- —\ *• / -i^v ^** •-•- • f\ ^-^  _ *S.*«^_X .\-^L:
                       FIVE SITE OPTION


                ALTERNATIVE 2 - MINIMAL ACTION

-------
                              -22-
There are areas of exposed refuse  which  need  to be covered in
the North Fill, South Fill and the Northwest  Fill south of Route
280.  These exposed areas could be a potential  source of air
emissions and also provide a mechanism for precipitation to
come in contact with hazardous substances  and carry contaminants
into the aquifer beneath the site.  Covering  these exposed
areas will include clearing and grading; placing a layer of
clean fillT and seeding, fertilizing and mulching.  In order to
work in areas in the North Fill,  the North Bridge which accesses
the fill needs to be rehabilitated.  Alternative 2, like Alter-
native 1, would allow contaminants to continue  to migrate into
the environment and would not reduce the potential for a future
release of contaminants that may pose a  public  health or environ-
mental threat.

3. Multimedia Cap

There is documentation of hazardous waste  dumping at Sharkey
Landfill.  Although available data indicate that the level of
contamination at present is relatively low and  localized in the
shallow aquifer which drains into the Rockaway  and Whippany
Rivers, the potential exists for detection of higher levels of
contamination in the future.  Alternative  3 includes a multimedia
cap over the Sharkey Landfill (Figure 4),  surface water (runoff)
control, erosion control for the banks of  the Rockaway River,
rehabilitation of the North Bridge, installation of gas collection
vents, additional site security,  and long-term  monitoring.  This
alternative would control the migration  of contaminants off-site
by reducing the rate of leachate produced  through infiltration of
precipitation.  However, there would still be a natural exchange
between the landfill and rivers,  especially on  the North Fill
and part of the South Fill, where a portion of  the fill material
is actually situated below the surface water  level of the
Rockaway River.  The potential environmental  and public health
risks associated with the exposure of fill material and leachate
seeps are greatly reduced by this alternative.

Four capping options were evaluated, each  providing a different
degree of protection and reliability.  They include capping
with clay, capping with a synthetic liner, and  capping with a
combination of clay and a synthetic liner  (Response Conservation
and Recovery Act (RCRA) "model" cap).

-------
                    -23-
                                          KAZEN AND SAWYER, re
                                                    Eno,
                FIVE SITE OPTION
ALTERNATIVE 3, 4, 6 AREAS  OF  REMEDIAL  ACTION

-------
                              -24-
  A.  Clay Cap - Sanitary Landfill Closure

The Sharkey Landfill can not be considered a sanitary landfill
because hazardous waste dumping at the site is documented.
Therefore, Alternative 3-A,  which would close the site as a
sanitary landfill, is not considered appropriate.  However, it
does satisfy the objective of evaluating remedial actions which
do not attain applicable or relevant public health or environmental
standards but would reduce the likelihood of present and future
threats from hazardous substances.

For this alternative, a complete cap typically consists of
the following: a bedding layer^placed and compacted on top of
the solid waste; an impervious layer; a drainage layer; and a
vegetative layer.  Figure 5 shows the detailed typical cross-
section of the cap.

The implementation of sanitary landfill closure is based on known
technologies and engineering principles and is effective in re-
ducing infiltration.  Although increased air emissions would
be expected during grading,  this alternative will provide some
long-term benefits.  These benefits include a reduction in pond-
ing of rain water on the fill, a reduction in leachate generation
and subsequent off-site migration of contaminants, and a reduction
in potential air emmissions due to inadequate cover.  However,
the wastes would still remain in contact with the groundwater,
specifically in the North Fill and areas of the South Fill,
could cause some leachate production and off-site contamination.
This alternative is implementable, provides some degree of
reliability, and involves minimal operation and maintenance.

  B.  Synthetic Liner Cap

This alternative, which would include the same closure standards
as for Alternative 3-A, considers the use of a synthetic liner
as the component of the impervious layer instead of clay.  The
capping criteria would be as follows: a 6-inch sand bedding; a
30-mil synthetic liner; a 1-foot drainage layer; and 1 foot of
topsoil and vegetation.

The environmental benefits and the implementability of this
alternative are similar to those for Alternative 3-A.  However,
because of the steep slopes at the site, the synthetic liner is
not considered as reliable as clay.

This alternative does not attain all of the environmental
standards but would reduce the likelihood of present and future
threats from hazardous substances.

-------
                   -25-
                VEGETATION
          w/
              1'  TOP SOIL
        SJSJ
        :::1   DRAINAGE  LAYER:?:
                   CLAY;
              SOLID WASTE
                                       9/19/86
FIGURE 5
SANITARY LANDFILL CAP

-------
                              -26-
  C.  Clay Cap

This alternative considers the closure of the landfill as a
hazardous waste site in accordance with relevant RCRA and State
requirements.

Instead of using one foot of clay for the impervious layer, as
in Alternative 3-A, Alternative 3-C would include two feet of
clay.  This alternative meets the performance requirements of
RCRA Subtitle C which includes a multimedia cap with a permeability
of 10~7 cm/sec.  It also is consistent with State of New Jersey
requirements for the closure of landfills which accepted all types
of solid wastes.

There is evidence of hazardous waste dumping at the landfill
and hazardous substances were found to be present.  Although
available RI/FS data do not indicate that significant quantities
of contaminants are currently being released to the environment,
there exists the possibility of future releases which may cause
serious environmental and public health impacts.  This capping
alternative would consider such a potential threat and provide
a more protective and reliable cover than Alternative 3-A or
3-B.  Figure 6 shows the detailed typical cross-section of the
cap.

The environmental benefits of this alternative are greater than
those for Alternative 3-A, based on the more impermeable and
reliable surface barrier.  However, wastes would still remain
in contact with the groundwater as in the previously described
capping alternatives, which could cause leachate production and
off-site contamination.

Implementation of this capping option is based on known technolo-
gies and engineering principles and is effective in reducing
infiltration.  This alternative has similar, but increased
benefits compared to Alternative 3-A, and involves minimal oper-
ation and maintenance.

  D.  Clay and Synthetic Liner Cap - RCRA "Model" Cap

This alternative involves the closure of the site as a hazardous
waste landfill utilizing a RCRA "model" cap.  The "model" cap
consists of the following: a bedding layer installed on top of
the solid waste; an impervious layer (clay); a second bedding
layer; a second impervious layer (synthetic liner); a drainage
layer; and a vegetative layer (see Figure 7).  The cover require-
ment used for this alternative also meets NJDEP Regulations
pursuant to N.J.A.C. 7:26-10, "Additional Operational and
Design Standards for Hazardous Waste Facilities", specifically
N.J.A.C. 7:28-10.8,"Hazardous Waste Landfills".

-------
                     -27-
                  VEGETATION
          >:1' DRAINAGE LAYERS
                    CLAY!
                                        9fi5l96
FIGURE 6
RCRA CLAY CAP

-------
                       -28-
                 VEGETAT10N
20 MIL.

LINER
        :-:-:-:DRAINAGE LAYER:-:-:-
              SOLID  WASTE
          T-
          2'

          I   r''

                                    .  1
                                              0H9/86
  FIGURE 7
RCRA "MODEL" CAP

-------
                              -29-

The environmental benefits of this alternative are similar to,
but greater than those for any of the other capping options.
The "model" cap would provide a more impermeable surface barrier
than the other capping options.  However, because the waste
would remain in contact with the groundwater, the alternative
does not achieve greater compliance with RCRA Subtitle C,
Hazardous Waste Management Regulations.

Although this alternative does not attain all the environmental
standards, it would reduce the likelihood of present and future
threats from hazardous substances.

4. Multimedia Cap and Containment Barrier (Slurry Wall)

This alternative adds to Alternative 3 by providing an additional
component to the remedial action, containment of the shallow
aquifer.  The alternative controls migration of contaminants
from the landfill through a multilayered cap which controls
leachate production, and a slurry wall barrier along the perimeter
of the fill areas which control the migration of contaminated
groundwater in the shallow aquifer.  The slurry wall would be
keyed to the clay layer beneath the site.

The slurry wall would minimize the lateral groundwater flow into
and out of the fill areas.  The total length of the proposed
slurry wall would be approximately 21,000 linear feet with an
average depth of 40 feet.  The remedial technologies associated
with Alternative 4 would be the same as Alternative 3, in ad-
dition to the construction of the slurry wall.  Groundwater con-
tainment by use of slurry wall is a proven, effective technology.

Based on the present data and past references, three options have
been considered under this alternative.

     Option A - Installing a RCRA "model" cap and a slurry wall
                throughout the entire fill area.  The cap will
                be installed with the same specifications as
                for Alternative 3-D.

     Option B - Installing a RCRA "model" cap and slurry wall
                for the North an.d South Fills, and installing a
                sanitary landfill cap in the Northwest (North and
                South of Route 280) and Southwest Fills.  The
                sanitary landfill cap is well explained in
                Alternative 3-A.

     Option C - Installing a RCRA clay cap and slurry wall
                throughout the entire area.  The components of
                the cap are described in Alternative 3-C.

This alternative meets applicable or relevant public health and
environmental standards and will satisfy both Federal and State
requirements concerning the closure of hazardous waste landfills.
This alternative prevents the contact of waste with the groundwater,
complying with RCRA Subtitle C, Hazardous Waste Management Regu-
lations.  Therefore, this alternative provides more environmental
protection than Alternative 3.

-------
                              -30-


5.  Multimedia Cap,  Groundwater Pumping  and Treatment

This alternative would control migration of contaminated material
off-site through installation of a multimedia cap and groundwater
extraction and treatment.   Based on EPA  and NJDEP requirements
for closure of a landfill,  treating groundwater without providing
a surface cap is not considered an acceptable alternative.

Under this alternative, groundwater would be pumped from the
landfill areas, as shown in Figure 8,  to extract contaminated
groundwater from the shallow aquifer.  Groundwater would be
removed from the shallow aquifer at a  rate equivalent to the
estimated recharge to that  aquifer.  It  is projected, however,
that the refuse in some areas of the landfill will exist below
present and anticipated post-closure groundwater levels.
Therefore, there would be  a continuing interaction between
groundwater and refuse materials.   Extraction of the groundwater
should effectively isolate  the contaminants from the surrounding
ground and surface waters.

Under this alternative, a  series of perimeter recovery wells
would be constructed along  a line parallel to the Rockaway and
Whippany Rivers, bordering  all five areas, and linked by a
common trench along the pumping line.  The contaminated ground-
water could be either treated on-site  using a separate air
stripping treatment system  or treated  at the Parsippany-Troy
Hills sewage treatment plant, which is on the site.  These two
treatment alternatives are  discussed below:

Option A:  On-Site Air Stripping Treatment System

           This alternative would involve a centralized treat-
           ment system with discharge  of treated effluent to
           the Rockaway River.  A preliminary unit sizing for
           an air stripping system would be a 2.5 feet diameter
           packed column with 15 to 20 feet depth of plastic
           media.

Option B:  Parsippany-Troy  Hills Sewage  Treatment Plant

           The existing sewage treatment plant includes secondary
           biological treatment with seasonal nitrification and
           denitrification.  Since the contaminants detected in
           the groundwater  are biodegradable, the contaminated
           groundwater could be treated  by the sewage treatment
           facility.

The environmental benefits  of this alternative exceed those of
Alternative 3.  Not only is leachate production reduced through
the installation of a cap,  but contaminants would not migrate
off-site because of the effective isolation of the waste through
groundwater pumping.

-------
                      -31-
                  FIVE SITE OPTION
ALTERNATIVE 5 - CAPPING  AND GROUNDWATER PUMPING

-------
                              -32-
The isolation of wastes  through groundwater management is a
demonstrated, reliable technology/  and  is  implementable.   In
addition, this alternative meets applicable or relevant public
health and environmental standards.

6. Excavation and Off-Site Disposal  of  Waste

This alternative would control  migration of materials off-site
from the Sharkey Landfill through the excavation and removal of
the entire landfill, and transporting the  excavated material
for disposal at an approved landfill site.   The entire fill
area as shown in Figure  4 was  considered for off-site disposal.
Three disposal options were considered  in  assessing this altern-
ative.

   0 Option A - Transport the  waste  to  an  approved existing
                RCRA disposal  facility, such as at Model City,
                New York.

   0 Option B - Transport the  material  to  a local sanitary
                landfill, such  as at the Meadowlands, New
                Jersey.

   0 Option C - Transport the  waste  to  a new RCRA facility to
                be constructed  as part  of  this alternative.

The estimated amount of  material to  be  removed is 3,900,000 cubic
yards of fill.  The excavated  areas  would  be backfilled,  regraded
up to an elevation of approximately  175 feet above mean sea level,
and seeded.  The backfilling operation  would require approximately
1,500,000 cubic yards of fill.   Since the  actual location(s) of
areas of potential contamination were not  positively defined
from historical information or  from  the remedial investigation,
total removal and disposal of  the Sharkey  Landfill material was
the only case considered for the off-site  disposal.

This alternative meets the CERCLA remedial objective that re-
quires evaluation of an alternative  which  provides for treatment
or disposal of hazardous substances  in  an  approved off-site
facility.  By removing all the  fill  material, one can expect the
site to be considered clean after completing the filling, grading
and revegetation.  Therefore,  this alternative also satisfies
the requirements of examining  a remedial alternative which ex-
ceeds existing standards.  This alternative would provide a highly
effective means to mitigate the potential  exposure to any con-
taminants in the landfill or any material  remaining at the site.

COMMUNITY RELATIONS

A public meeting was held on November 29,  1984 at the Parsippany-
Troy Hills Municipal Building  to discuss the proposed RI/FS.

-------
                              -33-

Notices announcing the meeting were sent to local officials and
interested parties as outlined in the Sharkey Landfill Community
Relations. Plan.  At this meeting, NJDEP officials and their
consultants discussed in detail the work to be conducted as
part of the RI/FS for the site.

The RI/FS report was made public on August 13, 1986.  A public
comment period began on that day and was closed on September 2,
1986.  A second public meeting was held on August 21, 1986 to
discuss the results of the RI/FS and the preferred alternative.
Concern expressed by the public and other entities are addressed
in the Responsiveness Summary appended to this documment
(Appendix 2).

CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS

In addition to accepting municipal solid waste, the Sharkey
Landfill allegedly received hazardous and/or toxic materials
between 1962 and 1969 from Ciba-Geigy, a pharmaceutical company.
Sharkey Farms Landfill was permitted by the local health depart-
ment to operate until 1970, when State regulations preempted
all local regulations.  A certificate to conduct a refuse
disposal operation (Certificate No. 1458300) for refuse, chemical
waste (liquid and solid), and waste oils was issued on July 10,
1970 by NJDEP.  The landfill reportedly operated for six days a
week until a July 6, 1972 order issued by the New Jersey Department
of Public Utilities required the discontinuance of Saturday
service in order to provide the time needed to install sufficient
cover material, in accordance with Chapter 8 of the New Jersey
Sanitary Code.

The sanitary landfill closure alternative considered the history
of the site and the relevant State guidelines and regulations.
However, the documentation of hazardous waste dumping, and
available chemical data indicating the presence of hazardous
substances in the landfill site, suggest that implementation of
the sanitary landfill closure alternative is not appropriate.
To cap the site as a sanitary landfill to comply with the New
Jersey "Non-hazardous Waste Management" Regulations would not
provide a sufficient level of protection to accomodate the
potential future releases of contaminants.  Moreover, this
alternative is not consistent with applicable Federal require-
ments under RCRA for hazardous waste facilities.

Because of evidence of hazardous waste dumping and the detection
of some hazardous substances at the site, the relevant and
appropriate standards for closure are stated in RCRA Subtitle C.
The hazardous waste cap and groundwater barrier alternative was
developed as a remedial alternative to comply with RCRA.  The
RCRA cap with groundwater extraction, and the RCRA cap alone,
would allow the waste to come into contact with the groundwater,
specifically in the North Fill and part of the South Fill.
Therefore, these alternatives would not ensure compliance with
RCRA Subtitle C as fully as would the cap with the slurry wall.

-------
                              -34-

The RCRA cap with groundwater pumping would  effectively
isolate the waste so that generated leachate does not migrate
off-site.  Groundwater would be extracted  and treated either
on-site or at the sewage treatment plant.  The excavation and
off-site disposal alternative would also comply with RCRA
because the disposal facility would be reguired to comply with
the appropriate regulations.

RECOMMENDED ALTERNATIVE

In evaluating the alternatives, it was determined that Alternative
5-A(b) would provide sufficient protection of public health and
the environment, would meet the performance  standards of the
applicable reguirements, is cost-effective and has a legal
basis for remedial action under Superfund.

As stated previously, hazardous wastes were  disposed of at the
Sharkey Landfill site, which was not properly closed after
operations ceased.  As a result, landfill  contaminants have
migrated and continue to migrate into the  shallow aguifer
beneath the site and the adjacent surface  water bodies.  Although
available data do not suggest that significant guantities of
hazardous substances are being released at the present time,
there exists the potential for future releases of contaminants
at levels which could pose a serious threat  to public health and
the environment.  Therefore, Alternative 1 (No Action) and
Alternative 2 (Minimal Action) are not considered adequate
because they do not meet the proper closure  reguirements for
landfills nor do they address the potential  threat of a future
release of contaminants.

Alternative 3 addresses capping of the landfill in accordance
with RCRA and State requirements.  However,  wastes that may
contain hazardous substances are known to  be in contact with the
groundwater which discharges into the surface waters surrounding
the site.  This condition could cause the  production of leachate
and off-site migration of contaminants. Therefore, Alternative
3 was not considered appropriate.

Alternative 6 (Excavation and Removal) would totally remove the
threat to public health and the environment.  However, this
alternative is extremely expensive, difficult to implement, and
unwarranted based on the level of risk associated with the
site.

The two alternatives which address leachate  production and the
off-site migration of landfill contaminants  into the groundwater
are Alternative 4 (Capping and Containment)  and Alternative 5
(Capping and Groundwater Treatment).  In view of the level of
health or environmental risk, it is believed that Alternative 5
would provide sufficient control of the migration of contaminants
through the groundwater pathway.  Alternative 4 would more
effectively isolate the wastes from the environment and thus
provide a higher degree of control of contaminant migration.
However, the substantial higher cost to implement Alternative 4
is not considered cost-effective in comparison to Alternative 5.

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                              -35-


In evaluating the options within Alternative 5, RCRA and State
closure requirements were considered, as were groundwater
treatment requirements.  As discussed previously, the Sharkey
Landfill is considered a hazardous waste site.  Therefore, the
relevant and appropriate Federal statute governing closure is
RCRA Subtitle C.  The recommended alternative meets the perfor-
mance requirements of the relevant RCRA regulations (multimedia
cap with a"permeability of 10~7 cm/sec), although it does not
meet the compositional criteria of the RCRA "model" cap.  The
"model" cap with the added synthetic liner would significantly
increase the costs without showing a corresponding increase in
effectiveness.  It is considered unwarranted for this site.  If
a synthetic liner is required in the future, the additional
grading of the fill areas will facilitate installation.

The multimedia cap of Alternative 5-A(b) will reduce the infil-
tration of precipition through the landfill, and the use of a
pumping and treatment system will prevent contaminants from
migrating off-site.  The pumping system, as explained in Alter-
native 5, will be installed to capture contaminated groundwater.

One final option which was considered and rejected involved
treating some fill areas as hazardous waste sites and others as
sanitary landfills.  Based on information concerning the time of
hazardous waste dumping and the transfer of waste materials
among the various fill areas during construction of a highway
and sewage treatment plant, it was determined that such a
distinction (i.e., hazardous versus non-hazardous) could not
definitely be made.  Because of the lack of information confirm-
ing the absence of hazardous waste at any of the fill areas,
the recommended alternative includes capping and groundwater
pumping for all five fill areas.

A cap cross-section and a site lay-out illustrating the recommended
alternative are provided in Figures 4 and 7.  The features of
the selected alternative are described in Table 4.

OPERATION AND MAINTENANCE

Upon installation of the recommended remedial action, operation
and maintenance (O&M) will consist of:

  0 O&M of the groundwater pumping and treatment system
  0 Routine maintenance of the landfill cap and gas vents
  0 Routine maintenance of the site to control erosion and
    surface water runoff
  0 Long-term monitoring to assess the quality of the groundwater
    (lower and upper aquifers) and surface waters (Rockaway and
    Whippany Rivers)

The annual operation and maintenance cost is estimated at
$330,000.

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                                  -36-


                                Table  4

              Capital Cost  Estimate  For  Alternative  5-A(b)



 Activity                                           Capital Cost*

 1 - Capping all five areas                         $13,513,000
 2 - Groundwater pumping and  recovery  system           1,700,000
 3 - Air stripping treatment  system                      100,000
 4 - Clear,  grub and grade  sites                        327,000
 5 - Cover exposed areas                                454,000
 6 - Methane collection vents                           284,000
 7 - Shoreline stabilization                             192,000
 8 - Storm water control                              1,319,000
 9 - Improvement of site security                        145,000
10 - Rehabilitation of North  Fill  Bridge                 91,000
11 - Long-term monitoring (installation  of
      additional monitoring wells)                    	48,000

     Total Capital Cost                              23,173,000


 * 10 percent for contingency and  10 percent  for engineering, legal
   adminstration, and startup costs  are  included.

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                              -37-
SCHEDULE -

         Project                                   Date

 - Record of Decision                          September 1986

 - Initiate Enforcement Action                 September 1986

 - Obligate Design Funds                       Pending CERCLA
                                               Reauthorization
                                               or State Funding

 - Amend Cooperative Agreement                 Pending CERCLA
   for Design                                  Reauthorization
                                               or State Funding

 - Initiate Design                             Pending CERCLA
                                               Reauthorization
                                               or State Funding

 - Complete Design                             Pending CERCLA
                                               Reauthorization
                                               or State Funding

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   APPENDIX I




    SUMMARY




       OF




SAMPLING RESULTS

-------
SUMMARY OF RESULTS
NORTH FILL
         (PPB)
                       >-9  WS-]
ws-:
                                                WI-15  WI-16
                                               SD-10&11  L-6
                                                       S-!
Chlorobenzene
Toluene
Ethylbenzene
Methyl Chloride
Xylene
Chloroform
Benzene
Benzo (a) Pyrene
Acetone
Tetrachloroethene
Trichloroethene

INORGANICS (PPB)

Chromium
Lead
Mercury
Nickel
Barium
Cadmium
Cyanide
                      17
                      14
                      27
146
480
1.6
564
                             73
                             42
                             32
                            334
                           1390
                                    18
                                    22
 75
 77

320
  21
  34
  22
                                                  27
                                                                15
                                                                      940*
                                                                      310*
                                                                      940*
                                                                      940*
                                                                      310*
                                          182
 405
1440
                       60
                                                                70
                              70
                                                         19
                                                                                           16
 32

 46

 6.1
332
                                                  60
                                                 776
WS = Shallow wells
WI = Intermediate wells
WD = Deep wells
SD = Surface water samples
L  = Leachate samples
S  = Soil samples
                              Sediment Samples

-------
(Cont.  SUMMARY OF RESULTS)


SOUTH FILL

ORGANICS (PPB)   WS-2 WS-6 WS-7 WS-8 WS-17 WI-6 WI-7 WI-8 WI-17 WD-2 SD-3 SD-6 SD-7 SD-8&9 L-3&4 S-4
Chloroform
Trichloroethene
Benzene
  75
  13
   6
                               13
ACID .BASE
NEUTRAL (PPB)

Bis(2-Ethylhexyl)
  Phthalete
Phenanthrene
Flouranthene
Pyrene
Benzo (a)
  Anthracene
Benzo (k)
  Fluoranthene

INORGANICS (PPB)

Chromium
Nickel
Lead
Cadmium
Mercury
Cyanide
Barium
4990
  87
  63
63   60
 41
145
97
49
16
31
206
181
39

25
                                                370*

                                                270*
                                                670*
                                                200*
                                                200*

                                                330*
 60
 70*
 13
2.1
60
                                                                12
                                                           33
80
                                                                3.2
                                                              1020
                                                                    138
WS = Shallow wells
WI = Intermediate wells
WD = Deep Wells
SD = Surface Water Samples
L  = Leachate Samples
S  = Soil Samples
        Sediment Samples

-------
 (Cont.  SUMMARY OF RESULTS)

 NORTHWEST (S)  FILL
ORGANICS (PPB)
Chlorobenzene
Benzene
INORGANICS (PFB)
Chromium
Nickel
NORTHWEST (N) FILL
ORGANICS (PPB)
Acetone
Benzo (a) Pyrene
INORGANICS (PPB)
Chromium
Lead
Cyanide
Nickel
SOUTHWEST FILL
INORGANICS (PPB)
Chromium
Lead
Nickel
BACKGROUND
ACID BASE NEUTRALS
Bis(2-Ethylhexyl)
Fluoranthene
INORGANICS (PPB)
Chromium
Nickel
Cadmium
Lead
Barium
WS-5 WI-5
23
28

WS-3 WI-3

54 68
290
248
172 72
WS-4 WI-4
341
81
246 17
(PPB) WS-14
Phthalate
89
60
L-2 SD-2
10
80 60
50
WD-3 L-5

143
80
307 100
SD-2 L-l
60 69
WS-lOt SD-1

492
594
13
80
1280



S-3
57
1500
159
27
S-l
28
50
SD-4
370
200
70
70
 WS  =  Shallow Wells
 WI  =  Intermediate Wells
'WD  =  Deep Wells
 SD  =  Surface Water  Samples   *  Sediment  Samples
 L  =  Leachate Samples
 S  =  Soil Samples
 t Undetermined as background

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 APPENDIX II




RESPONSIVENESS




   SUMMARY

-------
                             Sharkey Fr.rr.s Landfill
                Parsippany-Troy Kills and East Hanover Townships
                                  Mcrrir. Ccuuty
                                   New Jersey

                             Responsiveness Summary
                               for comments on the
                            On-site Feasibility Study

This  community  relations responsiveness summary, prep?red  as  part of the Record
of Decislor  CP.CD),  is divided into the following sections:

I.    Background on  Community Involvement and Concerns
      This  is a  brief history of  community  interest  concerning the Sharkey Farms
      Landfill sitt  tr
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     Fillppone,   Executive   Administrator   of  the   Coalition,   stressed   the
     Coalition's  interest   in   the   Passaic  River  Watershed   basin,   and  in
     particular, the poEribility of pollutants moving  into  the aquifers from the
     landfill.   A particular  concern was  the fact  that the  landfill operated
     before  regulations  existed.   The  Coalition  requested  that a  monitoring
     program  be  implemented  prior  to  cleanup,   ar.d   thet  "containment  and
     cleanup... be  expedited,  as  it  poses  a  grave  threat  to a  designated sole
     source aquifer1' (see attachment A).

     In addition tc the Psssaic River Coalition,  there were various requests for
     information on  the  landfill  status  from various parties.    Theee ir.cliirled
     requests  from  then Assemblyman  Dean  Gallo's  office,  the  Townships  cf
     Parsippany-Troy  Hills,   East  Hanover,  Montville  and   Washington,   the
     Boontcn-Mrntville League  of  Women Voters,  individual  citizens,  the  Star
     Ledger and WMTR radio.  Again, the primary  issues of concern were potential
     contamination of  the  aquifers and  that  site  clean-up be  implemented  in a
     timely manner.   In each case,  information on the Sharkey site was giver over
     the  telephone   by  the  NJDEP's,  Bureau  of  Community  Relations  and  ell
     interested parties were placed on the mailing list for this site.

     An atteirpt was made by NJDEP  to  locate  any  additional interested parties or
     active citizen  groups  in the area.    In contacts with  the Parsippany-Trcy
     Rills and East Hanover Town Halls and Health  Departments, it was deterrir.ec?
     that there were no additional  organized active citizens/environmental group?
     in the area.

     On November  29,  1984  NJDEP  held  a  public  meeting at  the Parsippany-Troy
     Hills  Town  Hall  tc  dircuss  the  initiation of  the  RI/FS  at  the  site.
     Notification of  the meeting  was  accomplished through  press releases and
     direct mailing of roticer: tc  local, state and  federal  officials, as well as
     all  concerned   citizens and  citizens  groups.    Approximately  30  people
     attended the meeting  ard  ?£er.dns and information packages  were  distributed
     (cue attendance  sheet  and  information p^ckrpe,  Attachment B).   Issues and
     concerns raised during the  re.eting  and  responses given included:

 Ccrjr.er.t: Concern about  creating  unnecesEzry  fear  among  local  residents  and
          spending so much  money when previous  DEP monitoring  did not indicate
          the presence of a toxic condition.

Response: It was  pointed out that a  careful  definition of  hazardous  ard tcy.ic
          terms was  important.    EPA  sampling in  1980  and  1981  indicated that
          toxic substances  may  be present  at  the landfill.   DEP sair.p]irg was
          conducted  in 1978 when sampling  techniques vere not as advanced as they
          are fccY.y (1984).

 Comment: The Parsippany-Troy hills Volunteer Fire DepartE.crt expressed concern
          about the  errerper.cy  response  plan and  offered to  point out locations
          where fires have occurred on the  site.
Response: A  copy  of  the  health  and   safety  plan  WPF  offered  to  the  Fire
          Department, and  thr.?.r  collaboration  on  It was welcomed.   In addition,
          they were  offered  a  key  to  the  trailer where rprcial  fire-fighting
          equipment would  be  stored.   It vas pointed out  that the DEP emergency
          unit is available on a 24-hour basis.

-------
 Comment: A question vas raided about responsible party pursuit. ?rd an offer was
          made  to review observations  of  landfill operations,  during  its active
          period.

Response: The  principal sources  of  infonr.fitier  ?re  the  1976  State  Industrial
          Survey and a  similar study conducted by the federal government in 1S.'1;0.
          Activities conducted by  the KJDEP as r.  follow-up to the public meeting
          included  briefing  the  P?r?Ippc-ny-Troy  Hills Fire  Department  on  the
          Emergency  Response  Plan, as  well  as infomiirp  their,  of  planned well-
          drilling,  etc.,  and crrrultation with Mrs. Dorothy  Jurgel,  a resident
          of New  Road   regarding past operating procedure Pt  the  landfill.   In
          January  1985, Mr.  ?.r:d Mrs. Jurgel  submitted a  27-page  compilation of
          Information  en the  Sharkey Landfill including  news,  articles, letters,
          ordinances   ard   regulations,   photographs  and  persons1  rotes   (see
          Attachment C).

II.  Summary of Major Questions/Commcntc Pprelved During the Public Connent
     Period and NJDEP's Responses

     On August  13, 1986 the  RI/FS WEE  pieced  in  the  following repositories for
     public  review:    East   Hanover  Municipal Building,  Farsippany-Troy Hills
     Municipal  Building, Morris Ccurty  Public Library in Whippany,  Parsippany-
     Troy  Hills  Public Library,  East   Hanover Public  Library  and   the  NJDEP,
     Division  of  Hazardous Site  Mitigation  in Trenton.    NJDEP issued  a press
     release and  contacted  local officials, as well as Interested citizen groups
     regarding the svelJfbility of the RI/FS at these repositories.

     On August  21, 19S6 NJDEP held  a public meetirp tr present the  results of,
     and  receive  cominents/quppfions  regarding the  RI/FS.  Notification  of the
     meeting  was  accomplished through  press releafF?  and  direct   mailing of
     notices to local,  stpte ard federal officials, as well as concerned citizens
     and citizen groups (see Attachment P).  Approximately 30 pecple cttended the
     meeting;  rrd  esch received  an  agenda,  fact sheet,  an  overview  of  the
     community  relations program   and  a  paper copy of  the slides used in the
     contractors  presentation.   (attendance  sheet and hand-out,  see  Attachment
     E).    The  public   comment period  was  held  from August   13,  19P6   through
     September  2,  1986.   In  addition  to  the comn-er.ts made  during  the public
     meeting,   four letters were  received by  the  Department  during  this period
     (See Attachnrrt F).

During  the  public meeting,  Dr.   George  Kehrberger  of  Alfred Crrx.-  Ccrrulting
Engineers  presentee1 rir i-eniedial  alternatives for long-tern  site remediation.

These are:
     0 Ko action, except long-term monitoring:
     0 Lung-term monitoring, erosion control,  site  security and
       ccverirp exposed areas;
     0 Long-tenr. monitoring, erosion control,  site  security ard  a
       multimedia cap;
     0 Long-term monitoring, erosion control,  sire  security, a
       multimedia cap and containment barrier;
     0 Long-term rccr.itrrlnp, erosion control,  site  security, a
       uultircedia cap and pumping and treatment of  ground  water; and
     0 Excavation and removal of waste r.r.terlals.

-------
Richard Salkie, Acting Director of NJDEP's Division of Razerdrur Site Mitigation,
then discussed  NJDEP's  recommended alternative which includes  site security and
access,  erosion control  and  shoreline  {stabilization,  capping,  gas  collection
system, storm water  control  and long-term roonltrrlrg of  the  site.  Comments and
questions were  ther  received from  the  audience.   In addition to Director Salkie,
and  Dr.  Kehrberger,  representatives  assisting  with  the RI/FS  of P.F.  V'ri^lit
/.££c-cl?tes=,  HydroQual  and  Hazer.   and Sawyer  were  present  and  responded  tc
questions relevant to their areas of expertlpr.

Questions and Coianer.tE from the August 21, 1986 Public Meeting

Note:   Subsequent  to the August 21,  1986  public netting, the NJDEP has been in
consultation with  the USEPA et Region II  and  Headquarters  in  Washington, D.C.
The USEPA  has  requested  the  KJDEF to  recommend  additional  reiredial measures for
an extra rcrr^in of control of  contamination release  based  upon documentation cf
waste disposal  at  this  site.   These additional  Erasures  included implementation
of a ground  water recovery  and treatment  system and capping fill areas to meet
federal Resource  Conservation  and Recovery Act  (RCRA)  requirements.   From this
landfill.  The responses to comments belcv are PP. given at the public meeting and
represent NJDEP's position on August 21, 1986.

In general,  the  tone of  the  public  comments  was very  positive.  Several in-
dividuals, including  Psrsippany-Troy Hills Mayor  Frank  Priore and Dr.  Daniel Van
Abs  of the  Fassaic  River  Coalition,  expressed  fhst  they  were  "pleased" and
"relieved" at the  findings of  the  study.   The  Mayor stated that he realized that
excavation and  removal were unreel!Ftic,  and felt  that the  recoci:ended alter-
native  was "ambitious".   There were, however, some  prer.r cf concern raised, and
these are summarized by subject as follows:

     0  Movement of contamination off-site;
     0  Sampling results and laboratory procedure;
     0  Police officers' use of pistol range on-site;
     0  Concerns of the Fire Department;
     0  Methcne gas recovery;
     0  Responsible party involvement; and
     0  Other issues.

Movement of Cortrpilration off-Site
The  primary   concern  expressed  at  the  meeting   was   the  possibility  that
contamination was-  present at the landfill  but had not yet moved tbrcvph the fill
nr.d  Irto   the  aquifer.    Residents  were  assured  that  the  long-term  monitcrirp
program reccinrended  by NJDEP  would detect  any  such movement  of contaminant?.

 Comment: What  if  the chemical wastes were deposited OVL  the InrHflll during its
          "warning yf?rc"  cf operation and are  just now working their way down
          through  the 80 feet of fill?

Response: That  is  a  possibility. ?rd the  long-term monitoring  program is set up
          for  just  this  reason;  to detect  any  contatrirctlon  moving  into the
          ground water from  the landfill.   This  monitoring would be conducted on
          s per.!-cnnual basis for 30 years.

-------
 Comment: VP.S  the sampling done  at  various levels?   I'is  concerned that in your
          drilling,  you might  have drilled  right through  something  ii\r.t(>F
-------
          reasons, v;e  will  corduct  a  third round  of  sarcpllrjr  tc  confirm our
          earlier results.

 Conjcent: If there was  laboratory  interference,  could the state  use a different
          laboratory?

Response: The record round of  sampling did go  to  a different laboratory for just
          that rceson.

 Comment: Have the results of  the  second  round of sampling on the KcmeFtesd Well
          been fcrvnrded to the East  Hanover  Township Water Department?

Response: No, we received them  two cays ago  and  they must go through our Duality
          Assurance program.   After that,  they will be sent.

 Coirnert: Pid NJDEP do this testing?

Response: Kc, a private laboratory  conducteo  the  testing.

 Comment: What is the time frame for  the third round of f.ar.pHr.£?

Response: Seme cr.ir.ples have already been  collected;  the  others will be collected
          shortly.

Police Officer's Use of Pistol Range  On-Site

 Comment: As you know, the police  department has  a pistol range en  the site.  We
          want "the bottom line" -  are our officers safe to go onto  the landfill?

Response: Of the areas we sampled, we found no significant  ccntatr.ination in the
          soils or aev.ifer.  We are  recommending  additional  sampling even though
          we don't feel there  is a problem.   The  only time we were  ccrcerr.ed was
          when we  were  drilling  wells.   The  fence  is  primarily  to  keep out
          children who night get in  and damage the cap or pet into  the leachate.


Concerns of the Fire Department

 Coiraent: As  Assistant Chief  of  fbe Fire  Department,  I'm  concerned about  a
          methane fire bursting through the cap.*  How ruch damage would we  do to
          the cap if we had to go in  and put  ort  a irethane fire?

Response: The vents  aJong the  trenches  would collect the  methere.   This  is a
          passive  system  and  we   don't  foresee   a prcbler.  with  methane  coming
          through the cap.
 Comment: Is there any  danger  in  feeing cr the site,  and if not,  why is there a
          decontamination zone?  Shorld ve decontaminate our equipment?

Response: The  decontamination  zone  was   user1   primarily   during  our   field
          investigation.   It  is e  routine procedure  to  assure that while we ere
          investigating the site we  do not bring  any ccr.tppiretion  onto the site
          or  take  any out.   We assume that  you would  use  normal  fire-fighting
          precautions, but there are  no plans  for fire-fightsrp re  decontaminate
          their equipment.

''•The issue of methane gas at the cite JP addressed separately in this
 responsiveness summary.

-------
 Comment: If  there was  a fire  and we  had to  go  In and  put It out,  is
          someone we vct:ld have  to  notify or contact?

Response: The  police know the  ccnhination to  the  locks and  in the  evtnt  cf a
          fire,  you would just  go  right in.   We would  like  to be  notified, but
          not  if It ±t going to  delay you in performing jour duties.

At  this  point a member  of  the  audience asked  the Assistant  Fire CHff if  there
had been any recent fires at the site.   He  responded that ncr.e had been reported;
perhaps  there were underground  fires   he  was  not  awsre  cf.   Director Salkie
pointed out that  the  investigaticr  would have revealed any underground fires, if
there had been any.

Methane Gas Recovery

 Comr.ent: What are  the  quantities  of methane  g£r?   The town might be interested
          in  recovering  it for  use ir  the. incinerator at  the sewage treatment:
          facility.

Response: We believe  that at tl.ir  point,   14  years  after  the landfill operated,
          most of  the biological activity  has already taken place,  and there are
          no significant levels  cf  r.ethare  pas.  We did not encounter  any methane
          en the surface, and only  small prrur.f.s when we were  drilling.

 Cocment: What about the bubbling in tin: pr-rde?

Response: THp is normal anerobic  activity.  We monitored the ponds and found no
          contaminants of any degree.

Responsible Party Involvement

General  interest  and  concern   VF.F. expressed  regarding  the  party   or  parties
involved in bringing  the wastes into the  landfill,  particularly Ciba-Geigy, and
the state's pursuit of extracting payment from  the responsible party.

 Comment: How  dia  Ciba  Geigy move  this material in?   War it  liquid, solid, in
          barrels,  or what?

Response: We have  no records  of how  it got  there  or where  it was  put  or. the
          landfill.   We  have  no  records   of  whether it  was dry,  liquid,  etc.
   roufcttt: Did you find any barrels during your investigation?

Response: No.

 CoTrjT'.ert: Who was responsible  for  v/har vas  coming into  the  landfill?  Worc.r. rt
          there any standards?

Response: The problem is at  that  time - 1945 to  197*  -  vher Sharkeys operated,
          there were  very few  Ftrnderds.   The NJDEP was  not formed until  1970.

(Note:   The  following answer  was  not  provided  ct thp  public  meeting.   It  is
expanded here to  provide clarification.)

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      lly  the  landfill operator  is  respcr.tjib.le for  what  comes into  a
although the generators do btar the  liabilities  of  their waste r.nd p?rt disposal
practices.

Landfill  regulations  began on  July  1,  1958  when  the  New Jersey  Department  of
health Regulations were  put lr effect  under  Chapter VIII of  the  State Sanitary
Lode.  Operational procedures (ie. dust  control, scavenge  control  etc.) were the
focus of this early regulations.  When the NJDEP was fcnrfo. in 197C, Chapter VIII
was expanded.   Effective  July 1,  1970 the NJDEP began   registration, permitting,
arV verc  requesting  engineering design reports including  slope  design,  r?r?city
and categories  and amount  of  waste accepted during  the  previous; ye?r.    Haulers
had to be  registered crd proper labeling; and  "bills  of  lading" were to accompany
shipments  of hazardous and chemical wastes.   Chapter VTII continued  to evolve.
In  1976  landfills began  to be  regulated by  the  type  of waste  that  could  be
accepted by waste classifications  indictrpd or landfill  permits.

 Comment: So the only  way you would  ever  know what  was  dumped is if someone came
          out and admitted it?

Response: We do have  scire  records,  but  they are  limited.    Early  records  are
          non-specific and  it  is  difficult to  determine IP f.circ  cases  what was
          dumped in the past.   Certainly if someone  admits  to disposing material,
          that  is a key indication of what was dumped and when.

 Comment: Who will pay for this remedial r.lternative?

Response: Superfurd monies will be used.  If Superfund is not reauthorized, state
          funds would then be used.

 Comment: What  about  trying to get the responsible  party to pay?
Response: At this point,  I  can only .epy- that we would  use  public funds - either
          Superfund  or   state.     The  enforcement  process   usually  involves
          litigation and we're not at liberty to discuss this aspect of the case.

 Comment: I  feel  the state  is responsible since  they  allowed  this  landfill to
          operate.

 Comment: From my experience  (working with EPA)  it  seems  like  any involvement on
          the  part   of  Ciba-Geigy   indicates  a   poter-rlel   for   dioxin  or
          dibenzo-furans.  Has this possibility been investigated?

Response: We have  no reason to  tert  for the  potential presence  of  dioxin or
          dibenzo-furans at  this  site.   We GO hfve s list  of  chemicals disposed
          at this location by  Ciba Geipy.  That  list  provides  no indication  that
          the presence of dioxin or dibenzo-furar.E vcrld be expected.

Other Issues

 Comment: With the recoinrerded alternative, would all five  fill areas be capped?

Response: At this  point, three  would definitely be  capped.   At the  other two
          areas, no  ccr.tppilration was found.   One  of  these areas  is a wildlife
          preserve.   We  will study  and  monitor  these  press  further.    If no

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           contamination  is  found,  it irpy  ret be  necessary to  cap  then.    (tee
           NJDEP's  Revised  Frccn-jiifciided Alternative,  p. 10)
Comment: What
                   the  cost  of  the  recommended ret.trlia.1.  rJ ferr.ative?
Response: Approxlir?f r.ly  £21  million to cap all five areas, and  approximately  $16
          million-  to  cap  three  areas.     (see  NJDEP's   Revised   Peroinrended
          Alternative, p. 10)

 Comn.ent: Is NJDEP  responsible  for  a?i  90 acres  of  the  site?

Response: The  actual  landfill is larger- than 90 acres.  The  fill  areas  comprise
          90  acres.  Or  that,  70  acres  have been found  tc  hsve  some levels  of
          contacination.

 Comment: What is the time frame  fcr  tMe project?

Response: After we  will receive your  comments,  we  will prepare  a  responsiveness
          summary,  sign  a Record  of  Decision  and come  up  with  a  remediation
          design.   Thar whole process  takes  about  six months.   The  design  phase
          lasts  approximately  one  year,  procuring a  contractor  taker  approxi-
          mately  three ircnths,  and  the  construction phase  takes  approximately  two
          to three  years.  V7e voulc hope  to  have the  landfill closfc-crt  ir  about
          four years.

 Comment: What priority  does  this site  have or. ycrr ?^?t?

Resporpe: Erch rr'tr is a  separate project - we don't like  to  prioritize them.   We
          hope to have enough money to  clean-up  all of  our sites.

 Comment: Could v:e  ever build on  top  of this  lerdfil]?

Response: We would  not recoirarend  doing  that.   It  is difficult to monitor  if  there
          is  a building on  top  of  the area.  In the  event  that ccrstruc.tion  is
          considered  at  any  fcrrer  landfill operation in New Jersey,  permits  and
          approvals muat first be  obtained  from NJDEP. Pivision of  Solid  Waste
          Management.

 Comment: Ir   the   RI/FS  you  recommend   the' installation  of   four  additional
          monitoring  wells.   Is  one  of  these wells  planned  for iret Dilation  in
          the  clay  der.reFfJon found at  this site.

Response: Yes, an additional  ircrJtoring well is recommended  to  be  installed into
          that clay channel  location.

III. Remaining Concerns  from  the August 21,  1986  Public Meeting

     In general,  the  coirmurity  near the Sharkey  Landfill was  pleased and  relieved
     at  the  results oi  the  KI/FS.    They regarded it  as  good new?  fcr  the; ticst
     part, and were especially relieved  that their water supply does not appear
     to  be  threatened.   The primary  concern that remains  is the prfer.ti.nl  for
     mcvener.t  of contamination off-site.    The  citizens  and  officials of  the
     community have been  assured by NJDEP  that a long-term monitorirg program
     will be  ir  effect at the  site for 30 years.  Any movement  of contamination

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                                       10
     which threatens  their water  supply  would be  detected and  acted  upon  in  a
     timely irarr.er.

IV.  NJDEP's Revised Recommended Alternative

     The  revised.- recommended alternative  presented below will  provide an  extra
     margin of control for  contaminntior  release  from this landfill at  a  cost of
     approximately $28.1 million.  The crirr-cr.ents of this alternative are:


V.   Summary of Major Written Quesficn? and Comments Received during the Public
     Ccrr.ent Period and NJDEP's Responses.

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                               11
             Responses to Written Comments Received
                  During Public Comment Period
              August 13, 1986 to September 2, 1986


During this public comment period two packages of extensive
written comments were received.  One package contained three
letters discussing and supporting of the same issue and will be
referred to as one commenter.

In general/ both commenters addressed the fact that the RI
adequately evaluated and characterized the nature of contamination
and hydrogeology at this site.  They both agree that this site
presents no significant contamination and thus minimal risk to
the public or environment.  One commenter primarily directs his
comments towards the result of the effects of the FS on the
Northwest (North of Route 280) Fill area, while the other
commenter is concerned with the overall scope of the project
and its cost-effectiveness.

The written comments have been listed according to the five
following categories:

     0 Site Characteristics and Classification
     0 Adherence to Regulatory Obligations
     0 Effectiveness of the Remedial Alternatives
     0 Recommendations for Alternatives
     0 Future Site Development

Each comment will be considered prior to selecting a final
remedial alternative and is accompanied by NJDEP's and/or EPA's
response, and the position concerning long-term remediation at
this site.
            Site Characteristics and Classification

Comment:   The data (RI/FS) clearly indicates that the site
           represents a typical municipal solid waste landfill
           and identified organic compounds are ubiquitous in
           household products.   The leachate from the Sharkey
           Landfill represents a typical municipal solid waste
           leachate that should be addressed within the context
           of sanitary landfill regulatory requirements.

Response:  Documents show that hazardous wastes were dumped at
           the site.  Therefore, the landfill is considered
           a hazardous waste site.  Contamination has been
           found at low concentrations in the shallow aquifer
           and in the Rockaway and Whippany Rivers.

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                               12
Comment:   Although,  industrial  waste may have been received by
           the landfill,  there is  really nothing about the
           leachate or contaminated groundwater which could not
           be attributed  to a municipal  solid  waste leachate.
          - In fact, the character  of the leachate is indicative
           of an older well leached sanitary landfill which, of
           course,  the Sharkey's site is.

Response:  The presence of hazardous wastes on-site creates a
           potential  for  migration and possible exposure to
           humans.   Lack  of high levels  of contaminants in
           leachates  does not rule out presence of chemicals on
           site.

Comment:   In the preparation of the site wide water budget there
           is an apparent error  in the calculation of the volume
           of groundwater moving through the clay aquitard.

Response:  We do recognize that  an error was made in calculating
           this figure.  The correct figure of 860 gpd should
           replace  100 gpd on page 3-108 of the RI.  We also
         .  agree with your evaluation that the correct volume
           (rate) is  still a small percentage  of the total flow.

Comment:   The piezometric surface contour maps for the water
           bearing  zone presented  in the RI report are quite
           unusual  for a  relatively high permeability, confined
           aquifer  and must be considered suspect.

Response:  The piezometric surface contour maps were developed
           using the  data obtained from  the field.  Groundwater
           level was  measured at each of the 26 monitoring well
           locations.  The data  was plotted on a scaled site map,
           and interpolation was used to draw  the contour
           lines.  The NJDEP and EPA believe that the data
           substantiate the contours as  shown.

Comment:   Because  the site is essentially a sanitary landfill,
           (Ciba-Geigy Corporation generated only a tiny fraction
           of the material disposed of at Sharkey's, less than
           one ten  thousandth of the total, with the bulk of the
           remainder  being municipal waste) it is highly unlikely
           that it  will ever contaminate drinking water supplies.

Response:  The site is classified  as a hazardous waste site, as
           explained  in prior responses.  Although, no contami-
           nation has been detected at present in the drinking
           water supply,  the site  is classified as a hazardous
           waste site, as explained in prior comments.  A
           potential  release of  contaminants may cause contamin-
           ation of the drinking water supply  in the future.

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                               13
           The amount of hazardous waste dumped by Ciba-Geigy
           at the site exceeds the maximum allowed in a sanitary
           landfill, even though the total amount of hazardous
           waste may be considered a small percentage of the
           total amount of solid waste in the entire landfill.

Comment:   The risk to drinking water at a more distant site
           would be even smaller, since it is well established
           that all groundwater transport involves substantial
           dilution.

Response:  We agree that the risk of contaminant exposure to
           drinking water is diminished through various mechanisms
           (i.e. bio-degradation, absortion, dilution).  However,
           consideration must be given to the degradation of
           groundwater quality at the site as well as to the
           risk presented at distant drinking water sources.
              Adherence to Regulatory Obligations

Comment:   Is the "Superfund" to be applied the closure of a
           relatively innocuous sanitary landfill site?

Response:  "Superfund" is not to be applied to the closure of
           an "innocuous landfill site", but "Superfund" may
           appropriately be used in the closure of this site.
           At this site, the selected alternative was based on
           the results of the RI/FS and documents supporting
           the hazardous waste dumping.  Sharkey Landfill is an
           open dump as defined in 40 CFR Part 207, "Criteria
           for Classification for Solid Waste Disposal Facilities
           and Practices." RCRA, Section 4005(a), which is
           relevant and appropriate to this site, states that
           dumps should be closed properly.  A proper closure,
           including a multimedia cap as discussed in the ROD
           is eligible for federal funds.

Comment:   The Department's contractor excluded that option
           (groundwater treatment without capping), which might
           be more cost-effective than a cap because of its
           perception that state landfill regulations preclude
           that alternative.  That perception may be incorrect
           and is not dispositive as to the selection of
           alternative under CERCLA.

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                               14
Response:  The USEPA Feasibility  Study  Guidance  recommends that
           alternatives  be  developed  that  satisfy the five
           .criteria as listed  on  page 2-5  of  the Task 6 report
           "Evaluation of Alternatives".   These  criteria were
           followed in the  study.   The  alternative of ground-
           water treatment  without  capping was  included in the
           screening of  alternatives  and rejected.

Comment:   The State Action Level II  figures  for organics in
           drinking water contained in  the January, 1986 NJDEP
           Drinking Water Guidance  would also be met by such a
           10-fold dilution (downstream or away  from the site).
           In that regard,  the decision of the  contractor to
           use Action Level I  for the Guidance  as appropriate
           state standards  for drinking water is clearly erroneous
           as a matter of law. Existing drinking water systems
           in current use throughout  the state  are not legally
           compelled to  meet Action Level  I concentrations;  it
           makes no sense to require  that  the water in a landfill
           do so.

Response:  The use of Action Level  I  figures  for organics in
           drinking water was  appropriate  as  a  measure of com-
           parison to applicable  and  relevant guidance.  We
           agree that recommending  remedial action (other than
           monitoring) based on Action  Level  I  concentrations
           is inappropriate.  The NJDEP did not  recommend
           remedial action  based  on those  levels.

Comment:   The Department's contractor  assumed  that any landfill
           closure is required by the Department to meet current
           landfill closure requirements.   If this view is
           correct, even landfills  which were closed prior
           January 1, 1982  must meet  the standards of N.J.A.C.
           7-26 Subpart 2,  which  implement the  State's Solid
           Waste Management Act.

Response:  It is NJDEP and  USEPA  policy to implement remedial
           actions at Superfund sites that attain or exceed
           the relevant and appropriate requirements of environ-
           mental laws and  to  consider  other  criteria, advisories,
           guidance and standards.   Within this  policy, NJDEP
           considers current state  landfill standards relevant
           to this site. We do not intend to imply that all
           landfills closed prior to January  1,  1982 must meet
           the standards of N.J.A.C.  7-26, Subpart 2.

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                               15
                  Effectiveness of Remedial Alternatives

Comments:  To what standard of clean-up are we to address the
           remedial action?

Response:  This question is not relevant here.  The system at
           this site is containment system to control future
           migration of hazardous substances from the site.  In
           contrast, a clean-up standard is appropriate, for
           example, when contaminated soil is removed.

           For this site, discharge standards for the options
           involving groundwater treatment pursuant to New
           Jersey Pollution Discharge Elimination System permits
           or local industrial pre-treatment standards will be
           used.  This remedial action addresses the objectives
           identified on pages 124-125 of the Task 6 report.

Comment:   How are the various alternatives to be compared so
           that their effectiveness in meeting the standards can
           be judged?

Response:  For a containment system, the alternatives are compared
           to each other based on reliability, implementability,
           safety, environmental and public health impact,
           institutional requirements and cost.  The comparision
           is used in fulfilling the remedial objectives and
           the requirements of the law.

Comment:   The cost-effectiveness analysis presented in the
           Feasibility Study does not conform to the methodology
           presented in the Cooperative Agreement for the site
           dated December 26, 1983.

Response:  The Cooperative Agreement (CA) between NJDEP and
           USEPA pertains to a preliminary scope of work and
           costs, which are subject to revision and negotiation.
           The methodology proposed in the CA may not reflect
           the actual method used by the contrator since the
           award of a contract is based in the actual proposal
           of the contractor and subsequent negotiations between
           the contractor and NJDEP.  The actual cost-effective-
           ness methodology used complies with the requirements
           of the National Contingency Plan (NCP), 40 CFR 300.

Comment:   The method by which the effectiveness ratings have
           been assigned is clearly subjective and arbitrary,
           and lacks a sound technical basis.

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                               16
Response:  The effectiveness  ratings were assigned in a consistent
           manner and reflect sound professional judgment.  The
           effectiveness ratings are one factor among many others
           used to select the remedial alternative.

Comment:   The suggested remedy does not meet the cost-effective-
           ness requirements  of the National Contingency Plan.

Response:  The Alternative 5-A(b)  complies with the  cost-effec-
           tiveness requirements of the NCP.

Comment:   Certainly, neither CERCLA nor the NCP require that
           the cost-effectiveness alternative identified in the
           FS by the contractor be adopted.  To the  contrary,
           the lead agency has a legal obligation to make its
           own determination  of cost-effectiveness,  and select
           the alternative which adequately protects the public
           interest at the lowest cost.  If a remedial alternative
           was selected based on the ordinary cost-effectiveness
           method used by the contractor, the decision would be
           arbitrary and capricious and out of keeping with
           the standards for  decision making under well understood
           principles of federal and state administrative law.

Response:  USEPA made a determination of the cost-effectiveness
           of the remedial alternative which adequately protects
           the public interest at the lowest cost.  USEPA in
           consultation with  NJDEP used the RI/FS as a basis
           for selecting the  appropriate remedy for this CERCLA
           site.  In addition, the decision was based on the
           comments received  during the public comment period.
                     Recommendations for Alternatives

Comment:   It is the position of the commenter that the property
           (Northwest (N)  Fill)  should not be affected by the
           selected remedial alternative or long-term site
           clean-up and excluded from the effect of any further
           action by the NJDEP and USEPA.  We also request that
           this parcel be removed from the Sharkey Landfill
           designation on the NPL.

Response:  Based on the information available, the Northwest
           (N) Fill may not appropriately be removed from the
           Sharkey Landfill designation on the NPL.  As explained
           in the ROD, this site presents a threat of release
           of hazardous substances.  It is unlikely that this
           property can be excluded from the selected alternative

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                               17
         -  for remediation unless the owner presents USEPA with
           a plan for the use of the property that clearly
           provides a level of protection equal to or greater
           than the selected remedial alternative.

Comment:   .The data (RI/FS) clearly indicates that the site
           represents a typical municipal solid waste landfill.
           We concur with the conclusion of the RI report that
           this site represents minimal risk to the public health
           and environment and is clearly a candidate for a "No
           Action" or a "Minimal Action" remedial program.

Response:  The location of the site, the length of time required
           to implement corrective action for a future release
           and the potential threat to the public health were
           considered in the selection of alternatives as
           explained in previous responses.  For these reasons,
           a No Action or Minimal Action Alternative will not
           provide adequate protection for human health and the
           environment.

Comment:   In the absence of a quantitative Risk Assessment,
           the FS has failed to demonstrate a significant risk
           to the environment or to the public health.  .Accordingly,
           selection of a costly remedial action has not been
           shown to provide demonstrable benefit to the environment
           or public health and is not supported by the evidence.

Response:  While the contaminants detected at present at the site
           pose little or no environmental and public health
           risk at current concentrations, there is a potential
           threat of release which cannot be quantified.  Since
           documentation shows hazardous waste was disposed of
           at the site, there exists a threat of a future release
           of these substances.  The selected alternative addres-
           ses the potential threat of release.

Comment:   Since the site poses no substantial present risk,
           relatively modest remedial measures are all that is
           required, and the expenditure of vast sums at the
           site would be wasteful.  The best approach would be
           one involving site stabilization (North and South
           sites to prevent erosion) and access control (deleting
           requirement for access control at the two Northwest
           and Southwest sites) coupled with continued monitoring
           and contingency plans for capping or groundwater
           treatment, re. a modification of Alternative 2.

Response:  It is agreed that the expenditure of vast sums of
           money at this site would be wasteful.  The selected
           alternative is consistent with health and environ-
           mental concerns and not excessive in cost.

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                               18
           As explained in previous responses,  the site has
           been classified as a hazardous waste site and the
           Minimal Action Alternative will not  adequately pro-
           ±ect human health and the environment.   Furthermore,
           in the long-term monitoring program  designed to sample
           every six months, a potential release of contaminants
           could be detected six months after its occurrence.
           After such a release of contamination was detected,
           the process for construction of a cap would take
           three years to complete.  A contingency plan which
           would take three and a half years to be implemented
           is not acceptable because of the risk posed to the
           public health and the environment.

Comment:   No ones interest is served by the expenditure of
           greater amounts of money at a particular site than
           are necessary to protect fully the health and the
           safety of the public, whether those  funds are provided
           from "Superfund" or by potentially responsible parties.

Response:  We agree.

Comment:   A pump and treat alternative without capping deserves
           favorable consideration in light of  the possibility
           that future monitoring would show that additional
           remedial measures are needed.  The capital cost and
           operating cost calculated for the pump and threat
           portion of Alternative 5 (FS pp B-12, B-13) suggest
           that the total cost of collecting and treatment might
           be sustantially less than the cost of capping along,
           depending on the extent of the pumping program and
           the degree of treatment.

Response:  As explained in the ROD, the closure of Sharkey Land-
           fill is governed by RCRA.  Closure requires a cap in
           accordance with the proper requirements.  The imple-
           mentation of groundwater treatment without capping
           is an incomplete measure which will  allow water
           infiltrate through the landfill, carrying potential
           contamination to the aquifer.

Comment:   It is true that the quantity of groundwater requiring
           treatment of the entire site would be greater under
           an alternative involving no-cap than the contractors
           estimate for Alternative 5 with a cap.  However, the

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                               19
           cost would not necessarily be greater.  The RI
           indicates that concentration levels are the highest
           at the North Fill site (RI pp 3-114 to 3-117).
           Accordingly, if pumping ever became necessary, it may
          . be needed only at the North site.

Response:  The alternative of treating the groundwater with no-
           cap not only increase the quantity of groundwater to
           be treated, but may carry contamination to the
           shallow aquifer.  The alternative of no capping is
           not as reliable as the selected alternative.

           In addition, as explained in prior responses, the
           entire site is considered to contain hazardous
           wastes.  Although concentrations of hazardous sub-
           stances were higher in the North Fill area, the
           other four areas cannot be excluded for groundwater
           treatment.

Comment:   A capping alternative is unnecessary and would be
           excessively expensive.  Before any cap alternative is
           adopted, the Department should take into account the
          . degree to which Alternative 2 reduced the need for
           Alternative 3.  In the event that a cap remedy is
           choosen, the Department should restrict capping to
           the North and South Fill sites.  Imposing an expensive
           capping remedy at the Northwest and Southwest sites
           can only be justified if, following the investigation,
           it could be said that they properly form a portion
           at the Superfund site.  In addition, the Department
           should defer a choice between a clay cap and the
           less costly synthetic cap until the design phase.

Response:  As stated before, the use of a cap is necessary for
           the proper closure of the entire site, and capping
           cannot be restricted to the North and South Fills.
           Photographs show fill activity in the Northwest Fill
           until somewhere between 1961 to 1966.  During this
           period, hazardous materials from Cieba-Geigy are
           believed to have been disposed of in an undefined
           area of the site.  Southwest Fill was used by the
           Department of Transportation to dump excavated
           material containing hazardous waste from the North-
           west Fill during the construction of Route 280 from
           1971 to 1974.

           In addition, the cap with synthetic liner was consid-
           ered in the evaluation of alternatives.  This cap is
           not as reliable as the clay cap.  A synthetic liner
           does not meet the requirements for a hazardous waste
           site.

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                               20
Comment:   Adopting an alternative which may not withstand legal
           scrutiny could result in either (i)  a substantial
           delay in implementing a remedial program for the site
           or (ii) the inability of the government to obtain
           full, much less prompt, cost recovery because an
           unnecessarily expensive alternative  was picked.

Response:  The alternative of capping and treating the groundwater
           meets all applicable requirements and is the most cost-
           effective alternative.  The selected remedial alter-
           native satisfies the requirements of RCRA and the NCP.
           There is no pre-enforcement review of action taken
           under CERCLA.  Therefore, no delay or inability of
           the government to obtain full cost recovery is
           expected.

Comment:   One commenter reported that at the August 21, 1986
           Public Meeting, he questioned Mr. Richard C. Salkie,
           Acting Director of the Division of Hazardous Site
           Mitigation in NJDEP, about capping option the NJDEP
           favored (all five areas or just the  three with
           contamination).

Response:  Director Salkie did not reply, as stated in this com-
           menter1 s follow-up letter, that the  Dowel Associates
           portion of the landfill was not being considered for
           remediation activity.  Director Salkie did respond
           that three areas were likely to be capped.

           Two areas were referred to by Dr. Kehrberger.  He
           said no contamination was found in the Wildlife Pre-
           serve (Southwest Fill) and the Northwest (N) Fill.
           USEPA does not agree with the conclusion of Dr.
           Kehrberger.  The results of the RI/FS indicate con-
           tamination in all areas; in Southwest Fill, concen-
           trations are almost at standard levels.
                            Future Development

Comment:   The proper development for this site (Northwest (N)
           Fill) provides superior environmental control for
           the property in question (Block 768, Lot 2 Parsippany
           Troy Hills) than could ever be achieved by capping.

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Response:  There is no indication that the plan submitted for
           this development would provide the measure of protect-
           ion over this entire fill area to control the potential
           for contamination release.

Comment:   It is clear that the above referenced RI/FS did not
           conclude that the commentator's site is unsuitable
           for construction.  In short, we would appreciate the
           NJDEP's consideration of the issuance of a letter to
           the commentator indicating that there is no impediment
           or objection to development of the site as proposed
           by the commentator and that further construction as
           proposed by the commentator will not interfere with
           the NJDEP's investigation and enforcement activities
           regarding the site.

Response:  Based on the determination that this property (North-
           west North Fill) represents a threat of release of
           hazardous substances requiring proper closure, this
           site is unsuitable for development and use as proposed.

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