United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-8e/059
June 1988
EPA Superfund
Record of Decision
Tabernacle Drum Dump, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/059
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
^Tabernacle Drum Dump, NJ
st Remedial Action - Final
:hor(s)
3. Recipient's Accession No.
5. Report Date
06/30/88
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 word*)
The Tabernacle Drum Dump (TDD) site is a one-acre facility located in Tabernacle •
Township, Burlington County, New Jersey. Drum disposal activities, which resulted in
contamination by hazardous substances, occurred on a 2,000 ft^ area portion of the
site. Land use in the area consists mainly of woodland, bogs, agriculture, and
recreation. The soils typically found in the area are highly permeable, sandy, and
«'dic. Approximately 75 to 100 residents live within a one-mile radius of the site.
t of the residents located down-gradient of the site depend on individual residential
Is for potable and agricultural purposes. TDD is currently owned by Mr. and Mrs.
Phillip Myers. In 1976 and 1977, the property was occupied by Mr. and Mrs. Robert
Ware. During that period, Mr. Ware's employer, the Atlantic Disposal Services (ADS),
disposed of approximately 200 fifty-five gallon drums, twenty gallon containers, and
five gallon paint cans. These containers were stored at the site from 1977 to 1984.
Deterioration and leakage of some containers resulted in visible soil contamination and
ultimately ground water contamination. Based on a referral from Tabernacle Township
officials, the Burlington County Health Department conducted a site inspection in August
1982, and discovered over 100 abandoned drums. In November 1982, the New.Jersey
Department of Environmental Protection (NJDEP) conducted a more detailed site
(See Attached Sheet)
Taoernacle Drum Dump, NJ
First Remedial Action - Final
Contaminated Media: gw
Key Contaminants: VOCs (DCE, TCA)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
ibility Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
105
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-88/059
Tabernacle Drum Dump, NJ
First Remedial Action - Final
16. ABSTRACT (continued)
inspection. Leaking and deteriorated drums containing solvents, paint sludges, heavy
metals, and visibly contaminated surface solids were revealed. In 1984, EPA issued an
administrative order to ADS requiring it to perform a surface cleanup of the site,
install and sample four monitoring wells, and sample and analyze site surface and
subsurface soils for priority pollutants. During April 1984, ADS initiated some
remedial measures including the numbering, logging, and sampling of site containers.
Surface cleanup was completed in July 1984 and consisted' of removing containers,
40 yd3 of drum material, 8 truck loads of excavated soil, and approximately
3,000 gallons of liquid material. The principle threat posed at the site is potential
ingestion of ground water by down-gradient residents. The primary contaminants of
concern are VOCs including 1,1,1-trichloroethane (TCA) and 1,1-dichloroethene (DCE).
The selected remedial action for this site includes: installation of ground water
monitoring wells with implementation of a monitoring program to delineate the extent of
the plume; ground water pump and treatment using air stripping and possibly carbon
adsorption followed by reinjection, ground water monitoring, and exhaust gas analysis;
and soil sampling of the former drum dumping and storage area. The estimated capital
cost for this remedial action is $772,600 with present worth O&M of $215,600.
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DECLARATION STATEMENT
RECORD OF DECISION
Tabernacle Drum Dump
SITE NAME AND LOCATION
Tabernacle Drum Dump, Tabernacle Township, Burlington County, New
Jersey
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for
the Tabernacle Drum Dump site, developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and Reauthori-
zation Act of 1986, and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record, and that
Characterize the nature and extent of contamination and evaluate
Pong-term remedial alternatives for the Tabernacle site:
- Draft Remedial Investigation Report, Tabernacle Drum Dump,
prepared by Camp Dresser & McKee, February 1988
- Draft Feasibility Study Report, Tabernacle Drum Dump, prepared
by Camp Dresser & McKee, February 1988
- Proposed Remedial Action Plan, Tabernacle Drum Dump, March 1988
- The attached Decision Summary for the Tabernacle site
- The attached Responsiveness Summary for the site, which incorpo-
rates public comments received
- Staff summaries and recommendations
DESCRIPTION OF SELECTED REMEDY
The remedial alternative presented in this document represents
a final remedial solution for the Tabernacle site. It addresses
ground water contamination in the underlying aquifer. A surface
cleanup involving the removal of drums and other containers as
well as contaminated soil has already been accomplished. >,
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-2-
The specific components of the remedial action are as follows:
- Installation of additional ground water monitoring veils to
further delineate the extent of the contaminant plume;
- Implementation of a ground water monitoring program 'for down-
gradient residential wells until the contaminant plume has been
delineated precisely;
- Additional soil sampling at the former drum dumping and storage
area to support existing data indicating only trace levels of
contaminants;
- Extraction of the contaminated ground water through pumping
followed by on-site treatment and reinjection of the treated
effluent into the ground. This process will continue until
federal and state cleanup standards are attained to the maximum
extent practicable; and
- Implementation of a ground water monitoring program for a period
of five years after site cleanup goals have been achieved.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980, as amended, and the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the selected remedy is protective
of human feealth and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for
this remedial action, and is cost-effective. Furthermore, this
remedy satisfies the preference for treatment that reduces toxicity,
mobility, or volume as a principal element. Finally, I have
determined that this remedy utilizes permanent solutions and
alternate treatment technologies to the maximum extent practicable.
The State of New Jersey has been consulted and agrees with the
selected remedy.
V,
Date Christopher J>J Dagrfett
Regional Administrator
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Decision Summary
Tabernacle Drum Dump
Site Description
The Tabernacle Drum Dump site is a wooded one-acre parcel of
undeveloped land located on Carranza Road in Tabernacle Township,
New Jersey in the northern region of the New Jersey Pine Barrens
(Figure l). The site is bordered to the northwest by farmland
and to the south and east by residential properties. The illegal
drum dumping activities which resulted in contamination by hazardous
substances occurred on.a portion of the one-acre site, approximately
2,000 square feet in size (Figure 2).
Land use in the area consists mainly of woodland, bogs, agricul-
ture (including cranberry and blueberry farming) and recreation
(especially canoeing in the Mullica River system). The soils
typically found in the area are highly permeable, sandy and acidic.
The nearest down-gradient surface water body is a cranberry bog
.located 0.7 miles south-southeast of the site dumping area.
Another cranberry bog exists at a distance of 0.5 miles, but is
located east-southeast of the site.
Approximately 75 to 100 residents live within a one-mile radius
I the Tabernacle site. The nearest drinking water well is
rated about 650 feet to the southwest. Most of the residents
located down-gradient of the site depend on individual residential
wells for potable and agricultural purposes. Figure 3 shows the
locations of some of the residential wells in the immediate site
vicinity and the direction of ground water flow which is calculated
as south-easterly. The nearest down-gradient well southeast of
the site is found at a distance of approximately 2,300 feet.
Two aquifers exist beneath the site which are separated by an
intermittent, 20-foot thick clay layer. The upper water bearing
source is the Cohansey aquifer which has a depth of approximately
100 feet at the site and which supplies the majority of those
residents living in the immediate site vicinity.-_ In some areas,
the Cohansey aquifer is hydraulically connected to the underlying
Kirkwood aquifer which is not typically used as a source of
potable water in the Pine Barrens region.
SITE HISTORY
Origin of Problem
The one-acre site is currently owned by Mr. and Mrs. Phillip
Myers of Marlton, New Jersey. The legal description of the
property is Block 1202, Lot 22, in the Tabernacle Township tax map.
(1976 and 1977, the property was occupied by the Myers» daughter,
th Ware (now Edith Ruhl), and her husband, Robert Ware. During
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- Burlington County
Boundary
Tabomacla/
Township
FIGURE 1 SITE LOCATION MAP- TABERNACLE DRUM DUMP SITE
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Tabemade Drum Dump
— Property Boundaries
Site Boundaries
FIGURE 2 LOCATION OF TABERNACLE DRUM DUMP SITE
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, To Tabernacle
Ground Water Flow
MCondurso
RW-7
Ruhl Tabernacle Drum Dump Site
RW-9
Location
Indefinite
Legend
Condurso- Resident Name
- Residential Sampling Point
RW-1. Residential Well Number
Nunziata
RW
ftW-8
Meredrtti&
Scale In Feet
FIGURE 3 LOCATION OF RESIDENTIAL GROUNDWATER SAMPLING POINTS
TABERNACLE DRUM DUMP SITE - DECEMBER 1986
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-5-
period, Mr. Ware's employer, Atlantic Disposal Services,
(ADS) , disposed of approximately 200 containers on the
Myers property. These containers included 55-gallon drums,
5-gallon paint cans and 20-gallon containers which were stored
at the site between 1977 and 1984. Deterioration and leakage
of some of the containers resulted in visible contamination of
the soils and ultimately of the ground water underlying the site.
Initial Enforcement Actions and Subsequent Remedial Measures
Based on a referral from Tabernacle Township officials, the
Burlington County Health Department (BCHD) conducted a site
visit in August 1982, discovering over one hundred abandoned
drums. In November 1982, the BCHD sampled approximately 25
private potable water wells in the area. No significant levels
of contamination were measured in the residential drinking
water at that time. At this point in time, the New Jersey
Department of Environmental Protection (NJDEP) conducted a more
detailed inspection of the site. This inspection revealed the
presence of leaking and deteriorated drums containing solvents,
paint sludges, heavy metals, and visibly contaminated surface
soils as evidenced by dead vegetation. NJDEP obtained three
organic waste samples from three separate drums and one aqueous
sample composited from seven different spill locations. The
analysis showed the presence of carbon tetrachloride,
toluene, ethylbenzene , xylenes , chromium and lead.
In September 1983, the Tabernacle Drum Drump site was proposed
for inclusion on the National Priorities List (NPL) to become
eligible for Superfund monies. The final approval for inclusion
on the NPL was given in September 1984. The site is ranked No.
445 on the most recent NPL update listing of March 1987. In
February 1984, the U.S. Environmental Protection Agency (EPA)
issued an administrative order to ADS to perform a surface
cleanup of the site, install and sample four monitoring wells,
and sample and analyze site surface and subsurface soils for
priority pollutants. During April 1984, ADS initiated some
remedial measures including the numbering, logging and sampling
of the containers found on the site. Surface cleanup was
completed in July 1984 and consisted of removing the containers
found at the site, 40 cubic yards of material from the drums,
eight truck loads of excavated contaminated soil, and approxi-
mately 3,000 gallons of liquid material. The only soil sampling
performed by ADS was conducted in March and April 1985 and
consisted of surface soil compositing from depths of 0-6 inches
from within ten zones at the site.
ADS did not perform the additional soil sampling from various
depths also mandated by the administrative order issued in
;ruary 1984, constituting a violation of that order. Monitoring
Is were never installed by ADS to assess the impact of
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-6-
contamination on ground water resources, also constituting a
violation of that order. It is important to note that the orig-
inal findings of leaking and deteriorating drums, coupled with
the highly permeable nature of the sandy soils, indicated a
strong potential for ground water contamination beneath the site.
Subsequently, the United States filed a civil action against ADS,
seeking penalties for its violations of the February 1984
administrative order, as well as the recovery of EPA's oversight
costs. That judicial action was resolved by consent decree,
pursuant to which ADS paid $115,000 in penalties and oversight
costs.
Remedial Actions by EPA
The EPA performs remedial actions at toxic waste sites in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, which was amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986. In most
instances, these actions are conducted in three major phases.
First, a remedial investigation and feasibility study (RI/FS)
is done to determine the nature and extent of the contamination
present at the site, and to develop and evaluate a range of
remedial action alternatives to deal with that contamination.
After the RI/FS is completed, a Record of Decision (ROD) is
prepared to document the remedy selected. Subsequently, the
remedial design (RD) phase begins, followed by the remedial
action (RA), during which the design is actually implemented.
In addition to these scheduled activities, a removal action may
be taken at any time to address acute hazards posed by the site.
Remedial Investigation
In accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), EPA conducted an RI/FS at the
Tabernacle site. Preliminary sampling of ground water and
surface and subsurface soils at the site was performed in July
1985 as part of an initial site evaluation. The formal field
work for the RI began in December 1986 and was completed in
December 1987. Major contaminants in the soils and ground
water are listed in Table 1, which includes data from the two
rounds of sampling undertaken in July 1985 and December 1986.
The RI report identified eight indicator chemicals in accordance
with the Superfund Public Health Evaluation Manual and documented
the existence of two contaminated media — soil and ground water.
These chemicals were detected at levels somewhat higher than
background concentrations and were considered to be site-related.
They are as follows: chromium, cyanide and lead in the surface
soils; and cadmium, chromium, lead, 1,1,1-trichloroethane (TCA)
and 1,1-dichloroethene (DCE) in the ground water.
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-7-
Ruring the RI, the soils were investigated through the analysis
of a total of eight soil borings and 17 surface soil samples.
Although the metal concentrations of chromium, cyanide and lead
in the surface soils exceeded site background levels, they did
not exceed the existing cleanup criteria established for soils
by the New Jersey Department of Environmental Protection (NJDEP).
These levels are known as the New Jersey Recommended Soil Action
Levels and are shown for comparison in Part A of Table 1.
During the RI, ground water was studied through on-site
monitoring wells, three of which were installed and sampled in
July 1985. Five additional wells were later installed and a
total of eight monitoring wells were sampled in December 1986.
In addition, three residential wells were sampled in July 1985,
and a total of ten potable wells were sampled in December 1986.
The analytical results for all of these ground water sampling
events are shown in Table 1 (Parts B and C) along with the
applicable or relevant and appropriate requirements (ARARs)
established by EPA or NJDEP.
The state ARARs for the various inorganic compounds listed in
Table 1 (Parts B and C) are known as the New Jersey Ground Water
Quality Criteria. The cleanup criteria for cadmium and chromium
t'n ground water are set at natural background levels by NJDEP and
re more stringent than the federal ARARs, known as the primary
aximum contaminant levels (MCLs) for these metals. The state
and federal cleanup levels are both set at 50 parts per billion
(ppb) for' lead. Based on the RI results for the December 1986
ground water sampling event, five monitoring wells exhibited
concentrations of total cadmium which exceed the state ARAR.
Furthermore, cadmium was not detected in any of the ten residential
wells which were sampled. During the RI, total chromium and total
lead were analyzed for in the July 1985 and December 1986 ground
water sampling events. Total chromium exceeds the state ARAR in
all of the monitoring wells sampled and in five of the residential
wells sampled. One of the monitoring wells and none of the
residential wells displayed concentrations of total lead which
exceed the state cleanup criteria. -•
In addition to the anorganic indicator chemicals identified as
part of the public health evaluation in the RI report — cadmium,
chromium and lead — some of the other metals detected in the
ground water exceed state and federal cleanup levels. The state
ARARs for iron, manganese and silver are equivalent to the federal
ARARs for these inorganics as shown in Parts B and C of Table 1.
Iron, manganese and silver were only analyzed for in the December
1986 ground water sampling event. The state cleanup criterion
for total iron was exceeded in all of the monitoring wells sampled,
jut in only one of the residential wells. Two of the morfitoring
ills and none of the residential wells displayed concentrations
>f total manganese which exceed the state ARAR. Finally, while
silver was not detected in any of the monitoring wells, three
residential wells exhibited levels of silver which exceed the
state ARAR.
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The volatile organic compound, 1,1,1-trichloroethane (TCA),
significantly exceeds the proposed MCL established by NJDEP in
six of the monitoring wells sampled in December 1986 by up to a
factor of 30 times. This observation confirms the exceptionally
high concentrations of TCA found in all of the monitoring wells
sampled in July 1985. In addition, the federal MCL for TCA is
also exceeded. It is important to note that TCA was not detected
in any of the residential wells sampled in December 1986. The
residential wells sampled in July 1985 detected extremely low
levels of TCA that are significantly below the most stringent
drinking water standards for TCA.
TCA undergoes chemical hydrolysis and breaks down into another
volatile organic compound, 1,1-dichloroethene (DCE), which is
considered a potential carcinogen. DCE was detected in only two
of the monitoring wells sampled in December 1986, at concen-
trations which were estimated and below method detection limits.
Therefore, it cannot be determined accurately whether the levels
of DCE found at the site exceed the proposed MCL set forth by
NJDEP which is more stringent than the federal MCL for DCE.
However, DCE was measured previously in two of the three monitoring
wells sampled in July 1985. Again, it is important to note that
DCE was never detected in any of the residential wells ever
sampled during the RI.
Contaminant Pathways
A public health evaluation (PHE) was performed at the Tabernacle
site to determine the impact on public health and the environment
under various exposure scenarios and different contaminant
pathways. This evaluation is presented in Section 6 of the RI
report (Volume 1). Although the PHE only identified two contami-
nated media — soil and ground water — the potential exists for
migration of the contaminants into other exposure media, such as
air and surface water, which were both included in the PHE.
The potential for significant exposure through dermal contact
with and incidental ingestion of site soils by trespassers is
considered low. This direct pathway represents a very low
potential health hazard since the RI findings indicate that the
surface soils are not highly contaminated. As was previously
noted, the levels of contaminants found in the surface soils
did not exceed the existing soil ARARs established by NJDEP.
Two migration pathways may exist for the transport of contami-
nants from the soils and into the air: volatilization from the
soils and resuspension of the soils through wind erosion or
mechanical disturbances. Yet, site-related volatile organics
are not present in the soils which makes volatilization a
negligible pathway under current site conditions. Also, t!he
coarseness of the sandy soils limits the suspension of parti-
culates into the air.
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TABLE 1
(page 1 of 5)
MAJOR CONTAMINANTS FOUND AT THE TABERNACLE SITE
" A. SURFACE SOILS
Sampling Dates
ORGANIC CONTAMINANTS 4/85 7/85 12/86
Volatiles
Acetone
2-Butanone
Carbon Disulfide
Chloroform
1,1-Dichloroethene
«hylene Chloride
rachloroethylene
1,1,1-trichloroethane
Base/Neutrals
Benzo(a)anthracene
Benzo Perylene
Bis(2-ethylhexyl)phthalate
Butyl Benzyl Phthalate
Di-n-butyl Phthalate
Dibenzoanthracene
Indenopyrene
Naphthalene
Phenanthrene
Interval: (0-6
NA
NA
NA
ND
ND
.172
.022
ND
in) (0-12 in)
NA
.026J
.012J
.019J
ND
.110
ND
.014J
(0-12 in)
.029
.024
ND
ND
ND
.003J
ND
ND
ND
.366
<.420
ND
.596
.366
.440
.073
.217
ND
NA
NA
NA
NA
NA
NA
NA
NA
.007J
ND
.266
. -- 1.1
6.3
. ND
ND
ND
ND
ARARs
NJDEP
1 ppm
for
total
volatile
organics
(not
exceeded)
10 ppm
for
total
base/
neutral
compounds
(not
exceeded)
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TABLE 1
(page 2 of 5)
A. SURFACE SOILS (Continued)
Sampling Dates
ORGANIC CONTAMINANTS
(all units are in ppm)
Pesticides
a-BHC
B-BHC
4, 4 '-ODD
4,4»-DDE
4f4»-DDT
Endosulfansulfate
Endrin
Heptachlor
INORGANIC CONTAMINANTS
(all units are in ppm)
Cadmium
Chromium
Copper
Cyanide
Iron
Lead
Manganese
Nickel
Silver
Zinc
4/85
Interval: (0-6
ND
ND
<.118
NO
.396
ND
ND
ND
4/85
Interval: (0-6
ND
15
8
1.1
NA
10
NA
4
<.200
70
7/85
in) (0-12
.002J
<.007
<.017
.009
.020
<.017
<.017
<.007
Sampling
7/85
in) (0-12
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
12/86
in) (0-12 in)
ND
.077
.007
.210
.520
.008
.023
.140
Dates
12/86
in) (0-12 in)
2.8
23
8.2
2.88
10,400
71
44
5.8
ND
43
ARARs
NJDEP
NG
NG
NG
NG
NG
NG
NG
NG
ARARS
NJDEP
3
100
170
NG
NG
250-1,000
NG
100
5
350
NOTE: In July 1985, the surface soil samples were analyzed for
EPA Priority Pollutant volatile organic compounds, pesti-
cides and PCBs. They were not analyzed for metals.
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TABLE 1
(Page 3 of 5)
•B. GROUND WATER (Sampled from on-site monitoring wells)
ORGANIC CONTAMINANTS
'(all units are in ppm)
1,1,1-trichloroethane(TCA)
1,l-dichloroethene(DCE)
Acetone
Methylene Chloride
Tr i chloroethene
Sampling Dates
ARARs
7/85
1.000
.018
.006J
.006J
ND
12/86
.920
.020J
.035
.030J
ND
State*
.026
.002
NG
.002
.001
Federal
.200
.007
NG
NG
.005
INORGANIC CONTAMINANTS
(all units are in ppm)
Cadmium
Chromium
Sampling Dates
ARARs
Iron
Lead
Manganese
Nickel
Silver
Zinc
7/85
NA
.051
NA
NA
.132
NA
NA
NA
NA
12/86
.013
.072 -.
.029
142
.042
.234
.043
ND
.070
State**
(A)
(A)
1.0
.30
.050
.050
NG
.050
5.0
Federal
.010
.050
1.3 \\\
.30 \\
.050
.050 \\
NG
.050
5.0 \\
NOTE: In July 1985, the ground water samples were analyzed for
lead, chromium, EPA Priority Pollutant volatile organic
compounds, pesticides and PCBs. No PCBs or pesticides
were detected in the ground water samples. ,,
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TABLE 1
(Page 4 of 5)
C. GROUND WATER (Sampled from off-site residential wells)
ORGANIC CONTAMINANTS
(all units are in ppm)
1,1,1-trichloroethane(TCA)
1,1-dichloroethene(DCE)
Acetone
Methylene Chloride
Trichloroethene
Sampling Dates
ARARs
7/85
.002J
ND
NA
.004J
ND
12/86
ND
ND
ND
.001J
State*
.026
.002
NG
.002
.001
Federal
.200
.007
NG
NG
.005
INORGANIC CONTAMINANTS
(all units are in ppm)
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Nickel
Silver
Zinc
Sampling Dates
ARARs
7/85
NA
.350
NA
NA
.005
NA
NA
NA
NA
12/86
ND
- .012
.279
.423
.031
.043
ND
.078
.192
State**
(A)
(A)
1.0
.30
.050
.050
NG
.050
5.0
Federal
.010
.050
1.3 \\\
.30 \\
.050
.050 \\
NG
.050
5.0 \\
NOTE: In July 1985, the ground water samples were analyzed for
lead, chromium, EPA Priority Pollutant volatile .organic
compounds, pesticides and PCBs. No PCBs or pesticides
were detected in the ground water samples. „
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TABLE 1
(Page 5 of 5)
Data Reporting Qualifiers
* State of New Jersey proposed Maximum Contaminant Levels
(MCLs) for "A-280" contaminants (N.J.A.C. 7:10-16)
** New Jersey Ground Water Quality Criteria for the Central
Pine Barrens (N.J.A.C. 7:9-6)
\ All values reported as Federal MCLs unless stated otherwise
\\ Secondary MCLs
\\\ MCL Goals
A Ground Water Quality Criteria set at natural background
J Estimated value
NA Sample was Not Analyzed for this compound.
NG A value is Not Given for this compound.
Sample was analyzed for this compound but was
Not Detected in that sample.
Value given is less than the method detection limit
but is above zero.
Data invalidated by QA/QC
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Soil contaminants may also migrate into surface water by over-
land flow or by percolation into the underlying aquifer with
eventual surface discharge. There is no evidence of overland
flow as a contaminant pathway based on numerous inspections of
the site. Based on ground water flow data compiled during the
RI, the Cohansey aquifer flows to the southeast and possibly
discharges into a down-gradient surface water body. The nearest
downgradient surface water body is a cranberry bog located 0.7
miles south-southeast of the site dumping area. Based on the
estimated rate of travel of the contaminant plume and the
distance to this cranberry bog, there is no indication that
migration of the contaminants through the aquifer system will
impact this relatively distant surface water body in the near
future. It is more likely that the local residential wells
would be impacted prior to ground water discharge to the
cranberry bogs.
The most significant exposure scenario is the ingestion of con-
taminated ground water by residential well users. The analyses
performed to date of various down-gradient residential wells
give evidence that contaminants traveling by the ground water
pathway have not yet impacted any of these residents, located
within a one-mile radius of the site, who utilize ground water
for potable purposes. Nonetheless, a ground water monitoring
program will be implemented for those down-gradient residential
wells with the highest potential for being impacted by a con-
taminant plume traveling through the ground water pathway.
The migration of contaminants into the air from the ground water
is not considered significant based on the RI findings. A
possible inhalation pathway could exist in a situation where con-
taminated water is being used in a household shower or outdoor
sprinkler system. This usage could cause some organic contaminants
to volatilize out of the water allowing them to be inhaled. Since
there is no evidence that contamination has reached the various
residential wells sampled, this pathway is not considered complete
at this time.
ENFORCEMENT ACTIVITIES
Four potentially responsible parties (PRPs) were identified for
the Tabernacle site. All of the PRPs were notified in writing
and given the opportunity to perform the RI/FS under EPA super-
vision. However, none of them elected to undertake remediation
of the site. After the RI/FS was completed, the 30-day public
comment period was provided, ending on April 21, 1988. Special
notice letters will be sent out to the previously identified
PRPs updating the status of the site and providing them with
the opportunity to perform the remedial design and remedial
construction phases of the project.
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RELATIONS ACTIVITIES
A Community Relations Plan for the Tabernacle site was finalized
on October 18, 1985. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination
of pertinent information.
EPA finalized the work plan for the RI/FS in June 1986 and placed
this document in the three local information repositories esta-
blished for the site. A public meeting was held on August 25,
1986 to discuss the work plan and to inform the public about the
Super fund program and the history and status of the site.
The need to conduct some residential well surveys and potable
water sampling gave EPA an opportunity to contact many local
residents to inform them of the ongoing RI/FS activities and
the current site status. Upon completion of these activities,
the RI/FS reports were also sent to the three information
repositories to initiate the public comment period, which
extended from February 24, 1988 to April 21, 1988. A public
meeting was held on March 10, 1988 to present the results of
the RI/FS and the preferred remedial alternative for the site
»ye loped by EPA.
CRIPTION OF REMEDIAL ALTERNATIVES
This section describes the remedial alternatives that were
developed, using suitable technologies, to meet the objectives
of the NCP and the Superfund Amendments and Reauthorization Act
(SARA). These alternatives were developed by screening a
wide range of technologies for their applicability to site-
specific conditions and evaluating them for effectiveness,
implementability, and cost.
The remedial alternatives presented in this document are based
on the findings of the RI and focus on contamination of the
ground water by 1,1,1-trichloroethane (TCA) and ojie of its break-
down products, 1,1-dichloroethene (DCE). Yet, some additional
activities will need to be performed during the initial phases
of the remedial design process and prior to implementation of the
selected remedial alternative. A detailed description and justi-
fication of these additional activities is included in the dis-
cussion of the selected site remedy which follows the evaluation
of the various alternatives considered.
In general, applicable or relevant and appropriate requirements
(ARARs) are promulgated and legally enforceable to address a
aecific contaminant (such as TCA), location (such as a wetland),
iction (such as air stripping). Contaminant-specific ARARs
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-16-
can be applied to the RI results before any remedial alternatives
are developed. The federal and state ARARs which have been
established for ground water are presented in Table 1, Parts B
and C. If available technologies exist that can meet or exceed
the most stringent ARARs, these standards are used to develop
the cleanup objectives (criteria) for the site remedy. The
proposed Maximum Contaminant Levels (MCLs) established by NJDEP,
which are more stringent than the federal standards for TCA and
DCE, are as follows: 26 parts per billion (ppb) for TCA and
2 ppb for DCE. It is expected that the more stringent levels
proposed by NJDEP will be promulgated prior to the implementation
of the remedial action. Therefore, the remedial action will
comply with the NJDEP levels in anticipation that these standards
become state ARARs.
As previously indicated, the Tabernacle site is located in the
Central Pine Barrens. The goal for ground water quality in this
area is set as natural background conditions. In pursuit of
this goal, best available technology will be employed for the
treatment of the extracted contaminant plume. The treated ground
water will be reinjected at 26 ppb or less of 1,1,1-trichlorethane.
A comprehensive list of candidate remedial technologies was
compiled to characterize each technology and determine its
applicability to the site. The original list is included as
Table 2 which also provides a brief rationale as to why some of
the technologies were excluded from further consideration.
The technologies that were retained after the preliminary
screening process were assembled in various combinations to form
nine general alternatives for remedial action. These technologies
fall within five general response actions:
* no remedial action, ground water extraction/reinjection through
pumping, on-site treatment, off-site treatment, and provisions
for an alternate water supply.
The components of each of the nine remedial alternatives developed
for the Tabernacle site are described below and the present-worth
cost estimates for these alternatives are listed in Table 3.
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TABLE 2
(Page 1 of 2)
SCREENING OF REMEDIAL TECHNOLOGIES
Tabernacle Drum Dump Site
Limitations/ Technology
Technology Disadvantages Retained
I. GROUND WATER CONTROL MEASURES
Capping Contamination no longer contained no
to the site surface. Horizontal
migration in ground water unaffected.
Containment Difficult to install due to aquifer no
Barriers depth which exceeds 60 feet.
Ground Water Discharge and recharge must be properly yes
Pumping managed to avoid surface water impacts.
Technology should be incorporated along
with a treatment technology.
ed Not suitable for deep aquifers. Adverse no
ersion impact on surface waters and possible
lowering of the water table. Requires
disposal of large quantities of water.
Subsurface Not suitable for depth of aquifer no
Collection encountered on the site.
Drains
II. ON-SITE TREATMENT
Physical Treatment
Air Stripping Most effective for treating volatile yes
organic contaminants. May require air
emission controls. Pilot studies
required.
Carbon Contaminated carbon generated would yes
Adsorption require regeneration or disposal.
Pilot studies required.
Reverse Energy-intensive. Requires extensive r no
pre-treatment and disposal or post-
treatment of the concentrated waste
stream. Inappropriate for large
volume of dilute solution.
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TABLE 2
(Page 2 of 2)
Technology
Limitations/
Disadvantages
Technology
Retained
Spray
Lagoon
Chemical Treatment
Chemical
Oxidation
Biological Treatment
Aerobic Bio-
degradation
Questionable performance due to suscepti- yes
bility to changing environmental condi-
tions. Potentially uncontrollable air
emissions.
Process is not selective and oxidizing no
agents may be consumed by organic
compounds other than the contaminants of
concern.
Not proven as an effective method for no
the contaminants of concern at low
concentrations.
III. ALTERNATE WATER SUPPLIES
Provide Bottled
Drinking Water
Install Deeper
Private Wells
Develop Central
Water Supply
IV. OTHER
Relocation of
Impacted Families
In-Situ Biological
Treatment
(Anearobic
Bioreclamation)
Only a temporary solution. Existing no
residential wells would not be capped
or abandoned and may be potentially
contaminated in the future.
Confining layer is intermittent and yes
cross contamination may occur during
new well installation.
Extensive and lengthy construction yes
requirements. Some residents may refuse
to connect to a municipal supply or may
object to billing charges. _
Duration of relocation may be indefinite. no
Potential detrimental sociological and
cultural impacts on the local families.
Effectiveness limited by such variables no
as site pH range, microbial competition,
and non-uniform nutrient addition which
makes this technology unreliable. ,r
Products may be more toxic than the
original contaminants.
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TABLE 3
COMPARISON OF PRESENT WORTH FOR REMEDIAL ALTERNATIVES
Alter-
native
1
2
Alternative
Description
No Action
Pump/Treat
Capital
Cost ($)
31,700
916,000
O & M
Present
Worth
166,600
159,500
Total
Project
Cost
198,300
1,075,500
6
7
8
Using GAC
Pump/Treat
Using Air
Stripping
Pump/Treat
At Off-Site
Facility
Existing
Public Water
Supply
Community
Water Supply
Install New
Residential
Wells
GAC Treatment
At Residential
Wells
Pump/Treat
Using Spray
Lagoon
772,600
212,300
1,941,000
439,300
378,900
58,300
273,600
215,000
776,600
291,600
287,500
473,900
118,900
987,600
9,218,600 9,430,900
2,717,700
730,900
666,400
532,200
392,500
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ALTERNATIVE 1: NO REMEDIAL ACTION
This alternative would not directly address nor reduce site
contamination and its associated risks. Under current site
conditions, contaminant movement and dispersion should continue
to follow the path of natural ground water.flow, which may
significantly impact water quality southeast of.the site. There-
fore, a comprehensive ground water sampling program would be
implemented to track the movement of the contaminant plume in the
Cohansey aquifer. This program would consist of the installation
of two additional shallow monitoring wells located down-gradient
of the site and up-gradient of those residential wells which are
in the path of contaminant migration. The monitoring wells would
be sampled and analyzed for priority pollutants on a quarterly
basis for a period of fifteen (15) years.
All of the remaining alternatives also include this ground water
monitoring program, with varying lengths of duration, to provide
down-gradient residential well users with an adequate warning
system of an approaching contaminant plume. Accordingly, the
following descriptions will focus on those elements of the remedial
alternatives that directly address or remediate ground water
contamination.
ALTERNATIVE 2: PUMP/TREAT USING GRANULAR ACTIVATED CARBON
This alternative would involve extracting the contaminated ground
water plume 'from the underlying aquifer through recovery wells
and pumping it to a treatment/recharge location up-gradient of
the extraction points. The contaminated water would be treated
with a granular activated carbon (GAC) filtration bed to remove
organic compounds from the liquid phase. When the contaminant
concentration of the treated water meets or exceeds the required
cleanup criteria, the water would be reinjected into the ground
through recharge wells. Two new monitoring wells would be installed
at points of interception between the site and down-gradient
residential homes to verify that the removal of contaminants has
been accomplished. This ground water monitoring-program would
continue for a period of five years.
A remedial action consisting of GAC treatment may also include
mobilization, operation and maintenance, carbon regeneration,
proper disposal of spent materials, and demobilization. In
addition, the GAC treatment unit may be proceeded by granular
media filtration to remove suspended solids, if necessary. A
pilot test would be conducted to determine the need for pre-
treatment and the frequency of change of the activated carbon.
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>TIVE 3: PUMP/TREAT USING AIR STRIPPING
This alternative also involves extraction of the contaminated .
g'round water plume through recovery wells. At the treatment/
recharge locations, the water would be treated through an air
stripping tower to remove volatile organic compounds (VOCs).
This technology involves injecting heated air into contaminated
water and extracting the exhaust gases (off-gases) by pumping.
The vapor phase concentrations of the volatile constituents
would be monitored and, if necessary, the off-gases would be
treated by GAC adsorption units before they are released to the
atmosphere to ensure that the maximum allowable air emission
standards are not exceeded. After the treated water reaches the
cleanup criteria, it would be reinjected into the ground through
several up-gradient recharge wells. This alternative includes
the implementation of a ground water monitoring program for a
period of five years.
A pilot test would be conducted to optimize the removal
efficiency of air stripping which is a function of the ratio of
air to water in the treatment tower unit.
ALTERNATIVE 4: PUMP/TREAT AT OFF-SITE FACILITY
this alternative, the contaminated ground water plume
be extracted from the underlying aquifer through several
wells equipped with submersible pumps and fed into a
central holding tank. The contaminated ground water would be
transported by tanker trucks to a RCRA-approved wastewater
treatment plant. For cost estimating purposes, it is assumed
that such a facility is located within twenty (20) miles of the
site. Further classification of the contamination in the
ground water would be required by the treatment facility to
determine the volume of water which would be accepted, which is
expected to be within the plant's capacity. In addition, a
ground water monitoring program would be implemented for a
period of five years.
ALTERNATIVE 5: EXISTING PUBLIC WATER SUPPLY -
This alternative would involve supplying a minimum of twenty
(20) potentially affected residents (within a one-mile radius
of the site) with an alternate source of water from the nearest
existing (municipal) potable water supply company. This alterna-
tive would provide a permanent and serviceable system requiring
approximately seven (7) miles of piping running west along
Route 70 and then south along Route 206 to Carranza Road. A
booster pumping/disinfection station with a chlorine injection
system, an adequate routing distribution design, and some house
lections and appliances would also be required. •
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-22-
This alternative could take a period of approximately one year
to implement due to construction and installation efforts. A
ground water monitoring program would be implemented for a period
of fifteen (15) years.
ALTERNATIVE 6: NEW COMMUNITY WATER SUPPLY
This alternative also provides a minimum of twenty (20) potentially
affected residents with an alternate source of potable water.
A new community well would be installed at a distant location
up-gradient from the area of contamination, approximately 1,000
feet northwest of the site. The new community well system
would provide a permanent supply of potable water from the
Cohansey aquifer which can easily yield sufficient quantities
of water.
This alternative would require 1.5 miles of water main piping
along Bozarthtown and Carranza Roads, a pump station, disin-
fection and distribution systems, house connections, backup
controls, and overall security and maintenance of the community
well. The installation of the new well and some house connec-
tions could require up to two years to complete. A ground
water monitoring program would be implemented for a period of
fifteen (15) years.
ALTERNATIVE 7: INSTALLATION OF NEW RESIDENTIAL WELLS
This alternative would involve abandoning the existing down-
gradient residential wells which tap into the Cohansey aquifer
and drilling new deep wells into the underlying Kirkwood aquifer.
Installation of a minimum of twenty (20) new residential wells
would involve test hole drilling, appropriate drilling and
grouting methods, and connecting new wells to existing residential
well piping. In the Pine Barrens area, the Kirkwood aquifer is
not typically used as a source of potable water, but available
information concludes that it would yield a sufficient quantity
of slightly acidic water. Prior to usage, the water pumped
from the Kirkwood would be tested and disinfected'-while residents
could be required to utilize conditioning units to adjust and
neutralize the water pH levels.
A twenty-foot thick layer of clay typically separates the
Cohansey aquifer from the underlying Kirkwood aquifer in the
Pine Barrens area. The ground water monitoring program for this
alternative would entail the installation and periodic samping of
two well clusters. Each cluster consists of one shallow and
one deep monitoring well. Monitoring of both aquifers through
the shallow and deep wells would be implemented for a period of
fifteen (15) years.
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8: GAC TREATMENT AT RESIDENTIAL WELLS
•This alternative would involve treating the contaminated ground
water from approximately twenty (20) residential well outlets
prior to consumption through a granular activated carbon (GAC)
•adsorption tank system to remove organic compounds. Continuous
treatment would be achieved by using two interchangeable GAC
tanks connected in series. Training the residents in the proper
use of the treatment system and properly maintaining the GAC units
(including disposal or regeneration of the contaminated carbon
in accordance with the appropriate environmental regulations)
would ensure the effective treatment of the individual wells.
A pilot study would be required to determine the frequency of
carbon replacement so that the cleanup criteria for contaminant
removal is achieved. Periodic monitoring of the GAC system and
analysis of the domestic well water would be carried out in
addition to implementing the fifteen (15) year ground water
monitoring program.
ALTERNATIVE 9: PUMP/TREAT USING A SPRAY LAGOON
This alternative would involve extracting the contaminated ground
water plume through several recovery wells, pumping it to a
election station, and routing all of the water through a single
seline back to the site for treatment.
The contaminated water would be distributed through a spray system
consisting of several nozzles dispersing the water as a mist over
a recharge basin. The volatile contaminants would leave the mist
to enter the gaseous phase at an expected concentration which
falls within environmentally acceptable limits (allowable air
emission standards). The recharge basin would be appropriately
sized so that the treated ground water which collects in the basin
readily infiltrates back into the ground. The recharge water
would be tested periodically to ensure that it meets the cleanup
criteria for this site. Ground water monitoring would be
conducted throughout the implementation of this alternative and
for a period of five years following the initiation of site
remediation activities.
Evaluation of Alternatives
Pursuant to CERCLA, as amended, EPA must evaluate each alternative
developed with respect to nine criteria. These criteria were
developed to address the requirements of Section 121 of SARA.
They include short-term effectiveness, long-term effectiveness and
permanence, reduction of toxicity, mobility and volume, implementa-
bility, cost, attainment of ARARs, protectiveness, community
eptance, and state acceptance. Table 4 indicates the various
s of evaluation criteria and the interrelationships between
them.
-------
TABLE 4
The Nine Remedial Evaluation Criteria
Overt*
Protection
Compliance
wlthARARs
Long-term
Ellectlveness
and
Permanence
Reduction of
Toxlclty, Mobility,
and Volume
(TMV)
Short-term
Effectiveness
• How alternative elimi-
nates, reduces, or
controls existing and
potential risks to hu-
man health and the
environment through
tieatment, engineering
controls, and/or Institu-
tional conuota
e Attainment of chemical-.
location-, and aciion-
specilic requirements
e Compliance with other
criteria, advisories, and
guirtancos
e Grounds lor invoking
a waiver
Magnitude ol total residual
risk in terms ol untreated
waste & treatment
residuals
Adequacy and suitability
ol controls (engineering &
Institutional) used to man-
age untreated waste and
treatment residuals
Reliability of controls over
time. Including potential
for failure and potential
resulting risk
e Treatment process and
amount ol material to be
treated
e Amount of hazardous
materials that wiN be
destroyed or reduced,
Including how principal
threat la addressed
through treatment
e Degree of expected TMV
reduction (e.g.. percent
of total, order of
magnitude)
e Degree to which treatment
Is Irreversible
e Type and quantity ol
residuals resulting from
treatment process
e Potential impacts on
community during RA
Implemeniation
e Potential impacts on
workers during RA and
the effectiveness and
reHabikiy ol protective
measures
e Potential environmental
impacts of RA and the
ellectlvenesa and
reliability of mitigelive
measures
e Time until protection la
achieved
-------
TABLE 4 (CONT.)
The Nine Remedial Evaluation Criteria
Cost
State
Acceptance
Community
Accept
*
Technical leasibttiy
- Dtfliculiies A unknowns associated
with technology
- Hntlsbily of lechnotogy
- Ease of undertaking additional action.
M required
- ReHebmy 4 ellectiveneu of moniiorino
Administrative feasibility
- Ability i time neceaaary to obtain required
approvals/permits
- Stepa required to coordinate with
other Agencies and aaaodated
time roqulrementa
Availability of services and materials
- Treatment, storage or disposal capacity
- Existence of multiple vendors
- Availability of needed equipment
Aspedalisls
- Timing ol technology avattabiMy
e Capital
e Operation & maintenance
e Present worth
Features of the alternative
the State supports
Features of the alternative
about which the State has
reservationa
Elements of the alterna-
tive the Stale strongly
Features of the alterna-
tive the community sup-
ports
Features ol the alterna-
tive about which the
community has reserva-
tions
Elements ol the alterna-
tive the community
strongly opposes
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-26-
This type of comprehensive analysis helps to identify those
criteria that are most important in evaluating the alternatives
developed. Accordingly, the discussions given below focus on
the significant evaluation criteria as they pertain to the
site. Any criterion judged to be sufficiently important for at
least one alternative is discussed for all the other alternatives,
as well, to ensure consistency and minimise subjectivity.
For the purpose of avoiding redundancy in the discussions that
follow, alternatives 2,3,4 and 9 will be evaluated as a group
since they all involve pumping and treating contaminated ground
water. Similarly, alternatives 5, 6 and 7 will also be grouped
for evaluation since they all involve providing an alternate
source of potable water.
ALTERNATIVE 1: NO REMEDIAL ACTION
Because hazardous contaminants are known to exist in the ground
water at the Tabernacle site, in concentrations associated with
significant health risks, the concept of a no-action alternative
is untenable. Moreover, this alternative does not comply with
any applicable or relevant and appropriate requirements (ARARs)
or cleanup standards which were significantly exceeded in many
of the monitoring wells tested during the RI.
The existing risks associated with current site conditions will
not be reduced, and stem from the potential that down-gradient
residential well users within a one-mile radius of the site may
ingest or inhale volatile compounds found in the contaminated
ground water. Full protection from the immediate risks will not
be attained by this alternative which also exhibits the highest
potential for future exposure to off-site human and environmental
receptors such as the down-gradient wetlands and surface water
bodies located beyond the immediate site vicinity.
The toxicity, mobility, or volume of the hazardous constituents
will not be reduced and a committment to long-term monitoring
of the ground water quality will be required. As a consequence,
if the 15 year monitoring program identifies contaminated
residential well water, the no-action alternative may need to
be replaced with another remedy.
Of the nine alternatives evaluated. Alternative 1 is the lowest
in cost and the least effective in addressing the contamination
found at the Tabernacle site. In addition, the no-action alter-
native would be unacceptable to both the local community and the
State of New Jersey.
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2: PUMP/TREAT USING GAC
TIVE 3: PUMP/TREAT USING AIR STRIPPING
ALTERNATIVE 4: PUMP/TREAT AT OFF-SITE FACILITY
ALTERNATIVE 9: PUMP/TREAT USING A SPRAY LAGOON
Alternatives 2,3,4 and 9 comply with the site ARARs by removing
and treating contaminated ground water. The existing risks asso-
ciated with ingestion or inhalation of volatile contaminants by
residential well users will be significantly reduced. Full pro-
tection from the immediate risks will be attained by capturing the
contaminant plume before it reaches down-gradient receptors. The
potential for future exposure of these human and environmental
receptors is minimized since these alternatives will permanently
and significantly reduce the toxicity, mobility and volume of the
hazardous constituents. The magnitude of any remaining residual
risks will be evaluated through a five year ground water monitoring
program.
While alternatives 2 and 3 will not cause any adverse impacts on
nearby down-gradient wetland areas, alternative 4 does not include
local recharge which may result in some surface water drawdown.
Similarly, if unfavorable climatic conditions are encountered
during implementation of alternative 9, the treated water may not
easily recharge back into the ground resulting in an overflow from
e lagoon and possible surface water runoff.
1 four of these processes utilize technologies which are capable
of accomplishing the same cleanup goals for remediation of the
site. Alternatives 3 and 9 take advantage of the volatile nature
of the contaminants and are particularly more effective in removing
the volatile organic compounds from the ground water.
Alternatives 2 and 4 are also effective but they involve necessary
off-site activities as well. Implementation of alternative 4 is
dependent on obtaining the necessary approvals from other agencies
for transporting and disposing contaminated ground water to an
off-site wastewater treatment facility. Although the ground
water is treated on-site with a GAC filter, alternative 2 would
still involve considerable off-site disposal or-regeneration of
contaminated carbon in accordance with appropriate waste management
regulations.
In alternative 3, GAC filters may also be required to treat the
air stripper exhaust gases but only if monitoring of the vapor
phase contaminant concentration during remediation reveals levels
that exceed acceptable air emission standards. It is expected
that the pilot studies will accurately determine the air stripping
design parameters so that GAC treatment and carbon off-site
disposal will not be necessary. Therefore, alternative 3 would
>t require this additional operation and maintenance (OfcM) step
}ile still maintaining very high short-term and long-term
"fectiveness.
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Implamentation of alternative 9 presents a very low degree of
reliability or effectiveness since it is greatly influenced by
fluctuations in ambient temperatures and wind speed and direction.
The short-term and long-term effectiveness of alternative 4 is
not very high, since hauling such a large volume of contaminated
ground water off-site could result in transportational complications
Adequate engineering and institutional control measures would be
critical to the proper management of the untreated waste water.
Alternatives 2 and 3 both employ on-site treatment technologies
which mandate only standard design and construction requirements
and are of comparable costs. The total project cost of alterna-
tive 4 is the highest of all the alternatives considered and
reflects the extensive O&M functions required to haul and dispose
of the large quantity of water. Alternative 9 is low in cost
but is also extremely unreliable.
The community has given a highly favorable response to alternatives
2 and 3, while alternative 4 would not be well accepted since road
congestion by tanker trucks would directly impact the local
residents, community opposition to alternative 9 seems likely
since residents have expressed concerns over the health risks
associated with releasing contaminants from the ground water and
into the air. Alternative 9 is unreliable in that the contami-
nant volatilization process may not be controllable under certain
conditions. These same concerns raised by the local residents
are not relevant to alternative 3 since the air stripping unit
would volatilize the organic contaminants through a controlled
process which would release off-gases at concentrations well
below the state air emission standards. It is unlikely that
the State of New Jersey would accept alternative 4 and 9 in
light of its preference for alternative 2 or 3.
ALTERNATIVE 5: EXISTING PUBLIC WATER SUPPLY
ALTERNATIVE 6: NEW COMMUNITY WATER SUPPLY
ALTERNATIVE 7: INSTALLATION OF NEW RESIDENTIAL WELLS
Alternatives 5, 6 and 7 are not effective in remediating the
ground water contamination and, therefore, do not comply with
the ARARs established for the site. These alternatives simply
provide an alternate supply of potable water for residential
use thereby reducing the immediate risks associated with the
exposure of down-gradient residents to contaminated ground
water in their existing individual wells. Full protection from
the immediate risks is limited to those residents receiving a
clean supply of potable water but the potential for future
exposure to off-site human and environmental receptors farther
down-gradient is still very high. Therefore, these alternatives
cannot be considered permanent solutions to the contamination
at the Tabernacle site.
-------
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t amount of potable water that is required by these alterna-
es to supply at least twenty or so residents is relatively
small. Acquiring this amount from the underlying aquifers in
alternatives 6 and 7 will not cause any adverse impacts on the
wetland areas near the site. The construction of extensive water
main pipes in alternative 5 may have some impact on the nearby
floodplains. Also, the contamination left in the untreated
ground water under alternatives 5, 6 and 7 may severely impact
the wetlands and floodplains located in the vicinity of the site.
The toxicity, mobility or volume of hazardous constituents in
the ground water will not be reduced under any of these alterna-
tives unless natural processes such as biodegradation, dispersion
or dilution occur. The occurrence of these natural processes
cannot be accurately predicted or guaranteed since they are
wholly dependent on a variety of conditions necessarily existing
in the ground water environment.
Alternatives 5 and 6 are easily implemented entailing only standard
design and construction requirements to install very extensive
water main systems. It may take up to one year and two years to
implement alternatives 5 and 6, respectively, because of the
extensive construction required for a pumping station and several
miles of piping. Alternative 7 may be implemented in much less
»me and the construction needed to install a new residential
11 is limited to the residential property. Improper well
installation into the lower Kirkwood aquifer and the potential
for hydraulic connection between the contaminated upper Cohansey
aquifer and the lower one, renders alternative 7 as the most
unreliable since the new residential wells may provide contami-
nated water. Alternatives 5 and 6 are equally reliable but
implementation of alternative 5 is dependent on obtaining the
necessary approvals from the existing water supply company and
other regulatory agencies as well.
Extensive O&M functions are required in alternatives 5 and 6
since a pump station and a chlorination system must be continu- •
ously operated to provide the affected residents with an adequate
potable water supply. In alternative 7, there is an increase
in operational requirements for the new residential wells
because of their extended depths. There are additional costs
associated with the ground water monitoring program for both
the upper and lower aquifers. The overall project costs for
alternatives 6 and 7 are comparable while alternative 5 ranks
second highest in cost of all nine alternatives considered.
Community opposition to alternatives 5 and 6 seems likely since
construction activities may last up to two years. During this
time, visible equipment and off-site road construction will
•impact the local traffic within a two to seven mile distance.
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In addition, the community may react unfavorably to billing
charges incurred for the use of municipal water in alternative 5.
The possibility exists that some residents may refuse to connect
to a community water supply in alternative 6, or may object to
construction activities on their property to install new resi-
dential wells in alternative 7. Some of the residents have
demonstrated a favorable response to the implementation of alter-
native 7, but only in combination with alternatives 2 or 3.
It is unlikely that the State would favor alternatives 5, 6 or
7 since the contamination at the site would not be completely
addressed.
ALTERNATIVE 8: GAC TREATMENT AT RESIDENTIAL WELLS
Alternative 8 does not comply with the site ARARs since it does
not remediate ground water contamination in the underlying
aquifer. This action simply provides for the treatment of
local individual supplies of potable water to meet the cleanup
standards, thereby reducing the immediate risks associated with
the exposure of downgradient residents to contaminated water in
their existing wells. Full protection from the immediate risks
is limited to those residents receiving GAC treatment on an
individual basis, but the potential for future exposure to
off-site human and environmental receptors is still considerably
high. Similar to alternatives 5, 6 and 7, this alternative
cannot be considered a permanent site remedy.
No pumping .is required by this alternative so that the water
table of the nearby wetlands will not be affected in the least.
Yet, the untreated and contaminated ground water may still have
a detrimental impact on the wetlands and floodplains located
near the site.
Similar to alternatives 5, 6 and 7, this alternative will not
reduce the toxicity, mobility, or volume of hazardous consti-
tuents in the ground water unless certain natural processes such
as biodegradation, dispersion or dilution occur. These processes
are not predictable and the rate at which they occur cannot be
fully ascertained in this environment.
Alternative 8 utilizes a very effective treatment technology
that is easily implemented and capable of successfully removing
the contaminants from the ground water to meet the cleanup
standards for specific residential water supplies. Although
the individual water supplies are treated on-site, considerable
off-site disposal or regeneration of the contaminated carbon is
required in accordance with appropriate waste management regula-
tions. The degree of long-term reliability presented by this
alternative will be determined by the necessary and proper
maintenance of the GAC system. -
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This alternative necessitates only standard design and construc-
requirements to connect the GAC adsorption tank system to
residential well outlets and may be completed in a short
period of time. The total project cost for alternative 8 is
comparable to that of alternatives 7 and 9, and consists mainly
of the O&M cost for servicing the GAC treatment system.
The construction activities to be carried out on the residential
properties are not extensive or lengthy and, therefore, should
not meet with community opposition based on this factor. Yet,
there has been some indication that local residents would react
unfavorably to any alternative that does not treat the contami-
nated ground water plume in the underlying aquifer, which is
true of alternatives 1, 5, 6, 7 and 8. The potential exists
for a household member to tamper with the system which would
render alternative 8 unreliable. Therefore, residents may
refuse to connect to the GAC treatment units since such a
situation could arise in their homes. Again, it is unlikely
that alternative 8 would be acceptable to the State as a final
solution to the contamination present at the Tabernacle site.
SELECTED REMEDY
After careful review and evaluation of the alternatives presented
in the feasibility study to achieve the best balance of all
aluation criteria, EPA presented alternative 3 to the public
the preferred remedy for the Tabernacle site. The input
ceived during the public comment period, consisting primarily
of questions and statements transmitted at the public meeting
held on March 10, 1988, is presented in the attached Responsive-
ness Summary. Public comments received encompassed a wide range
of issues but did not necessitate any major changes in the remedial
approach taken at the site. Accordingly, the preferred alternative
was selected by EPA as the remedial solution for the site. Some
additional activities will be performed during the initial phases
of the remedial design process and prior to implementation of the
selected remedial alternative. These activities are described
and justified as follows:
• Exact characterization and delineation of the "Vertical and
horizontal extent of the contaminant plume has not been fully
determined based on the data collected from the RI. Therefore,
additional monitoring veils (including deep and shallow depth
wells) will be installed and sampled to more accurately define
and characterize the contaminant plume. These monitoring
wells will be located down-gradient of the site and up-gradient
of the residential wells, to intercept the plume well before
it reaches potential down-gradient receptors.
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e A treatability study will be conducted to evaluate the effective-
ness of ground water treatment through air stripping. Carbon
adsorption will also be evaluated, if necessary to remove con-
taminants which may not be effectively treated by air stripping,
or to meet best available technology requirements associated
with ground water reinjection. As discussed earlier, carbon
adsorption is very effective in treating the major contaminants
already identified in the ground water.
• A ground water monitoring program for down-gradient and
nearby residential wells will be developed and implemented
until the contaminant plume has been delineated precisely.
Should contamination be detected, appropriate measures will
be taken to mitigate the situation and provide potable water
supplies to the affected residents.
• Additional discrete soil sampling will be conducted at the
former drum dumping and storage area. The analytical results
will be used to support existing data from the RI which shows
only trace levels of inorganic (metal) contaminants in the
surface soils. The extent of contamination and the health
hazards associated with exposure of the local community to
contamination by dermal contact with and incidental ingestion
of the soils will be reevaluated if high levels of soil
contaminants are observed. Should this confirmatory sampling
event reveal significantly higher concentrations of hazardous
substances, remediation measures will be carried out for site
soils as a separate operable unit and may involve further
soil excavation.
The costs associated with the selected alternative are itemized
in Table 5. The major components of this action are as follows:
• Extracting contaminated ground water through pumping followed
by on-site treatment through air stripping and reinjection of
the treated effluent into the ground. Additional pre-treatment
and post-treatment units may be necessary to meet ground
water reinjection requirements, or to remove any other contami-
nants detected in the ground water during final delineation
of the plume. Any wastes generated by the additional treatment
units will be treated to meet applicable disposal requirements.
The required overall treatment process will continue until
federal and state cleanup standards are attained to the maximum
extent which is technically practicable.
•Conducting an analysis of the contaminant concentration levels
found in the exhaust gases emitted by the air stripping unit.
This analysis will determine whether additional post-treatment
units are required to meet national and state ambient air
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-33-
ality standards. If additional treatment units are necessary,
he exhaust gases will be treated to meet federal air emission
standards and the requirements of the New Jersey Air Pollution
Control Act.
0 Implementing a ground water monitoring program for a period
of five years after site cleanup goals have been reached.
PROTECTIVENESS
The selected site remedy protects human health and the environ-
ment by dealing effectively with the principal threats posed
by the Tabernacle site. These principal threats involve the
ingestion or inhalation of volatile contaminants found in the
ground water. The selected alternative addresses these con-
taminant pathways by capturing and treating the contaminant
plume before it reaches any potential receptors. The primary
contaminants of concern identified in the RI report are 1,1,1-
trichloroethane (TCA) and 1,1-dichloroethene (DCE). The statutory
preference for treatment is satisfied by the selected remedy
which employs on-site treatment of the ground water through air
stripping to effectively reduce the toxicity, mobility, or
volume of these contaminants.
«the alternatives which most effectively address the principal
reats posed by the contamination at the site, the selected
medy affords the highest level of overall effectiveness
proportional to its cost. The selected remedy is cost-effective
and represents a reasonable value for the money.
The selected remedy utilizes alternative treatment technologies
to the maximum extent practicable by providing the best balance
among the nine evaluation criteria of all the alternatives
examined.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Action-specific
Under the Clean Air Act (CAA), the National Ambient Air Quality
Standards (as contained in 40 CFR }} 50.6, 50.7 and 50.12) are
considered applicable federal requirements for limiting the
concentration of particulate matter which may be emitted from
the air stripping unit in the selected remedy. Applicable
state requirements include the Ambient Air Quality Standards
(NJAC 7:27-13). The emission standards provided by NJAC 7:27-6
(Control and Prohibition of Particles from Manufacturing) and the
substantive requirements for the operation of air pollution
control equipment under NJAC 7:27-8 (Permits and Certificates)
.are considered to be relevant and appropriate requirements.
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TABLE 5
COST SUMMARY FOR REMEDIAL ALTERNATIVE 3
PUMP AND TREAT USING AIR STRIPPING
1. Site Clearing and Site Restoration $ 3,600
2. Installation of Recovery/Recharge Wells $ 88,300
3. On-Site Air Stripping $ .396,300
4. Mobilization/Demobilization $ 107,800
5. Installation of Monitoring Wells $ 31,700
6. Engineering and Contingencies $ 144,900
TOTAL CAPITAL COST: $ 772,600
O&M PRESENT WORTH: $ 215.000
TOTAL PROJECT COST: $ 987,600
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•femical-specific
As outlined in Table 1, Parts B and C, the federal MCLs under the
Safe Drinking Water Act (SDWA) are promulgated applicable
requirements which limit the concentration of contaminants in
the treated ground water which is to be recharged on-site
through reinjection wells. The more stringent New Jersey
proposed MCLs are expected to be promulgated prior to the
implementation of the remedial action. As promulgated applicable
state requirements, these standards would limit the concentrations
in the treated effluent at the point of reinjection to levels
of 26 ppb for TCA and 2 ppb for DCE, the major contaminants in
the ground water.
Location-specific
The Batsto River is located approximately 4.2 kilometers from
the site and is on a list of rivers eligible to be designated
as wild and scenic, under the National Wild and Scenic Rivers
Act. It is expected that the selected remedy will not have an
impact on the Batsto River based on its distance from the site.
In compliance with the Endangered Species Act, an informal
consultation with the U.S. Fish and Wildlife Service will be
»rried out to evaluate the potential for encountering federal
dangered or threatened species in the vicinity of the Tabernacle
site. It is expected that the selected remedy will not have any
detrimental, impact on these species because of their transient
nature in this area.
Regarding other location-specific ARARs, it appears that the
selected remedy may have an impact on the wetlands and floodplains
located in the vicinity of the site. Additional information on
the wetlands and floodplains will be collected during and/or
prior to remedial design to evaluate this potential. If this
additional information indicates that the selected remedy may,
in fact, have an impact on wetlands and floodplains, a combined
wetlands and floodplains assessment will then be conducted to
ensure compliance with Executive Orders 11988 and 11990 before
the remedial action is implemented.
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T&EESNACZE ERM EDO?
, KB* JERSEY
Itadc Assigment No. 97-2IA4.8
Document Oontxol Number: 197-GR1-KP-OCMD-1
Uiis document he^ been prepared for the U.S. Brvironmental Protection
Agency under Contract 68-01-6939. The material contained herein is not to be
disclosed to, discussed with, or Bade available to any person or persons for
any reason without the prior expressed approval of a responsible official of
the U.S. Environmental Protection Agency. •'
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CDM CAMP DRESSER 4 McKEE INC.
mtrmgvrm* oorauOna Nm Vartb Nnr Vortt 10006
SI2MMS7D
June 9, 1988
Mr. Shaheer Alvi
Regional Project Officer
U.S. Environmental Protection Agency
26 Federal Plaza
New Tork, Nev York 10278
Ms. Lillian Johnson
Regional Superfund Community Relations Coordinator
U.S. Environmental Protection Agency
26 Federal Plaza
New York, Nev York 10278
Ms. Lorraine Prigerio
Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
Nev York, Nev York 10278
Project: REH II Contract: 68-01-6939
Tabernacle Drum Dump Site
York Assignment No.t 97-2LAA
1 Document No.z 197-CR1-RT-GCMD-1
Subject: Final Responsiveness Summary
for the Tabernacle Drum Dump Site
Dear Mr. Alvi, Ms. Johnson, and Ms. Frigerio:
Camp Dresser & McKee Inc. is pleased to submit this Final
Responsiveness Summary for the Tabernacle Drum Dump site in
Tabernacle, Nev Jersey.
If you have any questions or comments, please contact me or Carl
Zoephel, the REH II Community Relations Specialist for this site.
Very truly yours,
CAMP DRESSER & McKEE INC.
Peter V. Tunniciiffe,yV.E.
REM II Region II Manager
xc: Document Control
Tom Stevenson
Carl Zoephel (CD1/7)
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399 Thornall Street Sixth Floor
Edison. New Jersey
08837-0001
201/906-2400*
ICFTECHNOLOGY INCORPORATED
MEMORANDUM
To: Ton Stevenson, REM H Site Manager
Tram: Elizabeth S. Marcotte, REM U Cbanunity Relations Manager
Date: May 20, 1988
DOC No.: 197-OU-RT-GCMD-l
Project: REM U Contract No. 68-01-6939
W.A. No.: 97-2IA4.8
Subject: Responsiveness Summary for the Tabernacle Drum fr«T> Site
Action: Transmit to EPA
The attached Responsiveness Sunnary for the Tabernacle Drum
Tabernacle, Burlington County, New Jersey was prepared at the request of
Johnson, EPA Regional Superfund Connunity Relations Coordinator.
If you have any questions about this Responsiveness Sunnary, please do not
hesitate to contact me or Carl Zoephel at (201) 906-2400.
Eate
Elizal^th S. Marcotte
REM U Ccnnunity Relations Manager
cc: Peter Tunnicliffe, REM U Region U Manager
r.^ea Lowe, REM U Technical Specialist
Carl Zr*10! / REM ZZ Ocoounity Relations Specialist
Bob Pierce, REM U Comnnity Relations Specialist
Patrick Schaffner, COM FPC (3)
File
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HBRFQRBNCE OF KEMbULAL RESPdGE
ACUVTEEES ATtNOCNQQEZED
HAZARDOOS K&STC STTRS (FEM H)
U.S. EEA CCNIRACr NO.: 68-01-6939
_ RR TBE
TABEKNACXE EKM DCHP
aAEEEMAOE, MO? JERSBf
FEM H DOOMENT NO.: 197-Gfa-RT-GCMD-l
Prepared by; ^A *fL( Date:
Carl Zoephef
u Odumunity Relations Specialist
Elizabeth S. Marootte
REM IT Ocnmunity Relations Manager
Approved bv: C^W^7 /? Jtfffl &&* *- *gi.'S Date:.
TOD Stevenson v
"FEK U Site Manager
^^_^^_ Date: &/9/S&
W~. Tunnicliffe
REH n Region U Manager
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TAHtJNACEZ EFLM DTMP SHE
BORLENSICH COUNTY, NEW JERSEY
The U.S. Environmental Protection Agency (EPA) held a _
period from February 25, 1988 through April 21, 1988 for interested parties to
comment on EPA's draft Feasibility study (FS) and Proposed p^norij*! Action
Plan (PRAP) for the Tabernacle Drum PnnT> (Tabernacle) site.
EPA also held a public meeting on March 10, 1988 at the Tabernacle
Township Municipal Building to describe the remedial alternatives and present
EPA's preferred remedial alternative for the Tabernacle site.
A responsiveness summary is required under the regulations of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERdA), and the Superfund Amendments and Reauthorization Act (SARA) for the
purpose of providing EPA and the public with a summary of citizens' comments
and concerns about the site, as raised during the public umiumil period, and
EPA's responses to those concerns. All of the comments summarized in this
document will be factored into EPA's final decision of the remedial
alternative for cleanup of the Tabernacle site.
This community relations responsiveness summary is divided into the
following sections:
I. Responsiveness Summary Overview. This section briefly outlines the
proposed remedial alternatives for the Tabernacle site.
II. \ Background on Community Involvement Concerns. This section provides
a brief history of community interest and concerns regarding the
Tabernacle site.
XXI. Sunti^Ty of Ma^or Questions and Comments Receive^ pTTino th*»
Conro^nt Period and EPA P^gponspg to Thg^e Qjnuiy^nfeg. This section
summarizes both oral and written comments submitted to EPA at the
public meeting and the public comment period, and provides EPA's
to these consents.
XV. Remaining Concerns. This section rt1 qoTWfs TrimiiTnity concerns that
EPA should be aware of as they prepare to undertake the remedial
design and remedial action at the Tabernacle site.
X. RESPONSIVENESS SdfJARY OVERVIEW
The Tabernacle Drum Dump site is a wooded, one-acre parcel of undeveloped
land located off Carranza Road in Tabernacle Township. The site is located in
the northern region of the New Jersey Pine Barrens. The Tabernacle site is
bounded on the north by farmland and is otherwise surrounded by woodlands.
Approximately 75 to 100 residents live within a one mile radius of the site.
These residents rely on domestic wells for their water supply. ',
Between 1977 and 1984, approximately 200 containers, including 55-gallon
drums, 5-gallon paint cans, and 20-gallon containers were stored at the site.
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It is alleged that the containers were dl^p"^ of at the site by Atlantic
Disposal Services, Inc. (ADS) in 1977. At the time the containers were
disposed of at the site, the property was lived en by an ADS employee who is
the son-in-law of the property's owners.
By 1982, drum deterioration had occurred and several drums were found
empty. The drums containing chemicals were sampled and analyzed under the
direction of the New Jersey Department of Environmental Protection (NJEEP) .
Laboratory results showed the presence of barium, chromium, lead, silver,
nickel, toluene, benzene, ethylbenzene, and carbon tetrachloride.
In September 1983, the Tabernacle Drum Dump site was proposed for
inclusion on the National Priorities List (NFL) — a listing of the nation's
priority hazardous waste sites, thus making it eligible for federal Superfurd
monies. The final approval for inclusion on the NFL was given in September
1984. Two factors leading to placement of the site on the NFL included; its
location within a sensitive environment (the Pine Barrens) , and its setting
over sandy soils which could allow contamination to seep down into the ground.
water.
In 1984, the drums and visibly-contaminated soils were removed from the
site under EPA orders. Sampling conducted by ADS's contractor- in April 1984
revealed that TCA, benzene, and ethylbenzene were the three compounds present
in the highest concentrations. In 1985, EPA authorized an initial
investigation to evaluate the nature and extent of the contamination at the
site, and installed three ground water monitoring wells. The results of this
initial investigation indicated that contamination was present in soil samples
as well as in the ground water, and that a more in-depth investigation of site
conditions was warranted. EPA, therefore, determined that a
Investigation/Feasibility Study (3RI/FS) was necessary to fully characterize
contamination at the site and to develop alternatives for remediating the
site.
The draft PJ/FS reports have now been completed for the Tabernacle site.
The PI determined that inorganic and volatile organic compounds are present in
the soils and ground water at the Tabernacle site. However, since only trace
amounts of contaminants were detected in the soils, the alternatives developed
in the draft FS focus on the ground water contamination. This responsiveness
summary M**rwus*R public comments on the draft FS. The alternatives evaluated
for remediation of the Tabernacle site include;
Alternative 1: No P«?"**M?7 Action
The no-remedial-action alternative would not directly address nor reduce site
contamination and its associated risks. The site would remain in its present
condition and contaminants in the ground water could eventually migrate off-
site. In addition, periodic sampling of the existing on-site monitoring wells
would be oonductffrt to evaluate the ground water quality. All of the following
remedial alternatives include monitoring of the ground water to provide an
early warning of contamination.
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Alternative 2: Pump/Treat Using Activated Carbon
Alternative 2 would involve extracting the contaminated ground water plume
from the underlying aquifer through recovery wells and pumping it to a
treatment/recharge location up-gradient of the extraction points. The
contaminated water would be treated with a granular activated caTtxn (GAC)
filtration bed to remove organic compounds. When the contaminant
concentration of the treated water meets or exceeds the required cleanup
criteria, the water would be reinjected into the ground through recharge
wells. New monitoring wells would be installed at points of interception
between the site and down-gradient residential homes to verify that the
removal of contaminants has been accomplished. A pilot study would be
required for this alternative.
?; Pump/Treat Using Air Stripping
Alternative 3 also involves extraction of the contaminated ground water plume
through recovery wells. One water would be treated through an air stripping
tower to remove volatile organic compounds (VOCs) . This technology involves
forcing heated air into contaminated water and extracting the exhaust gases
(off-gases) by pumping. The vapor phase concentration of the contaminants
would be monitored and, if necessary, the off-gases would be treated by a GAC
filter before they are released to the atmosphere to ensure that the
allowable air emissions are not exceeded. .After the treated water reaches the
cleanup criteria, it would be reinjected into the ground through recharge
wells followed by implementation of a giuund water monitoring piuyiam. A
pilot study would also be required for this alternative.
4? Pump/Treat at Off-Site Facility
Alternative 4 would involve extracting the contaminated ground water plume
through recovery wells. The extracted water would then be transported to an
approved off-site wastewater treatment plant located within 20 miles of the
site for processing. In addition, a monitoring program would be implemented
to evaluate ground water quality at the site.
? Existing Public Water Supply
Alternative 5 would involve supplying the potentially affected residents with
an alternate source of water from the nearest existing potable water supply
company. This alternative would provide a permanent and serviceable system
requiring approximately seven (7) miles of piping, a booster pumping station,
and an adequate routing distribution design. This alternative would not
M^rwss the contaminated ground water; however, a monitoring piuyidiu would be
implemented.
Alt^ITPtfo? $j New Ccnramity Water Supply
Alternative 6 would involve installing a new cccnunity well at a distant
location up-gradient from the area of contamination, approximately 1,000 feet
northwest of the site. The new community well system would provide a
permanent supply of potable water from the Cohansey aquifer and would require
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a pump station and distribution system. A monitoring piujidiu would be
implemented as well.
Alternative 7: Installation of New Residential Wells
Alternative 7 would involve abandoning the existing residential veils which
tap into the Oohansey aquifer and drilling new deep wells into the underlying
KirJcwood aquifer. In the Pine Barrens area, the Kirkwood aquifer is not
typically used as a source of potable water, but available information
concludes that it would yield a sufficient quantity of slightly »f-i4i
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H. BACK3OTND GN CCMCKnY INVGDVEMENT AND GCNCEfKS
In November 1982, the Burlington County Health Department (BCHD) first
notified area residents living near the Tabernacle Drum Dump site of potential
ground water oontamination during preliminary testing of potable well water
supplies. At that time., the New Jersey Department of Environmental Protection
(NJDEP) and the BCHD collected information from nearby residents who had
observed waste disposal activities at the site and were concerned about
contamination of their private wells.
In May 1985, EPA conducted interviews with local officials and residents
to assess their concerns regarding the oontamination at the Tabernacle site,
and EPA's plans for cleaning up the site. The key issues and concerns
identified are summarized below.
Ground water ccntamination. In 1985, the residents and local officials
did not perceive the Tabernacle site contamination as a serious problem.
They did, however, believe that there was potential for area ground water
to become contaminated and subsequently jeopardize the primary water
supplies in the area. Residents and local officials also thought that
cjruund water oontamination could pose a potential threat to the stability
of the local economy and quality of life in Tabernacle Township.
Wasteful use of taxpayer's money by EPA. Residents expressed the belief
that the amount of money obligated for the Tabernacle RI/FS seemed
excessive. They thought the removal action in 1984 had taken care of
site oontamination, and they were not aware of the Superfund piuyiaui.
Negative press. The Tabernacle Township officials were concerned that
the Tabernacle RI/FS would create adverse local publicity, discouraging
economic and residential development in the area.
Coordination with local officials. Tabernacle Township officials
expressed concern over the lack of timely information from EPA and NJDEP.
The felt that there was a need for much more coordination with EPA, NJDEP
and themselves.
In August 1986, EPA held a public meeting with area residents and
officials to rtier»ea the cleanup workplan and future remedial activities for
the Tabernacle site. The major issues of concern expressed by residents at
this meeting are summarized below.
Test results from the initial sampling efforts. Residents requested
further information about TCA contamination detected during EPA sampling.
They requested additional information about potential sources of TCA, and
the extent to which contamination had spread.
Time and resources devoted to tte Tfthemarile site. The residents wanted
clarification on the amount of testing that was needed at the Tabernacle
site, and how long it would take. There was «!«<•> concern about the cost
of additional testing, and who was financially responsible for costs
incurred.
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The -foipHrMt-icn of NFL status for Tabernacle residents. Residents were
concerned that the void "dump" in the NFL registered name of the
Tabernacle Drum Dump site reflected badly on the whole Tabernacle area.
The need for improved nrmn mi ration among interested pnrtles. Residents
stated that information about EPA activities at the Tabernacle site was
sporadic and insufficient.
HI. SDMMARY OF MAJCR QDESTICK5 AND COMEN35 KkULlVU) UUK1NC WR PUBLIC
PERIOD AND EPA RESPONSES TO innm* cottons
Concents raised during the Tabernacle site public txmimiL period are
summarized below. 2he public comment period was held from February 25, 1988
to April 21, 1988 to receive concents on the draft RI/FS reports and the
Proposed Rpmfrtinl Action Plan. Comments received during the public cuutumL
period are summarized and organized into the following categories:
A. Results of initial and RI sampling pmjiaas;
B. Characterization of primary contaminant, TCA;
C. Ground water flow and contaminant plume charantpri zat ion;
D. ' Potential health hazards;
E. Technical questions regarding air stripping treatment;
F. Other possible treatment alternatives; and
G. . Costs and financial responsibilities.
Written comments submitted to EPA during the public cuatmit period along
with ERA'S responses to these comments, are attached as Appendix A.
A. HKSmaS OF INITIAL AND RI SAMPLING FROGRMB
1. Comment: A resident nsVp»1 why additional monitoring wells had to be
installed for the remedial investigation since wells had already
been installed for the initial site investigation.
EPA Response: The data from the initial wells were used primarily
to interpret the direction of ground water flow. Additional wells
were installed during the remedial investigation in order to further
characterize the direction of ground water flow in the immediate
area. These wells proved to be important because they identified
the areas of highest contamination.
2. CuumiL: Several residents inquired about the results of the RI,
and whether any site related contaminants were detected in
residential wells.
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EEA Response: Results of the RI irtpntlflert the areas of
contamination and characterized the plume of ground water
contamination that is moving in a southeasterly direction away from
the Tabernacle site. Contaminants from the site have not reached
any residential wells which have been sampled. The contaminant
plume is at least 2300 feet away from the closest residential well.
The remedial actions proposed by EPA will ensure that contaminants
will be removed from the ground water to avoid any possibility of
residential well contamination.
3. QjuiifcfliL; Several residents inquired about the test results from the
monitoring well located upgradient from the Tabernacle site and
whether the results indicated if there were other sources of
contamination.
EPA Response; There is a monitoring well located about 60 feet
upgradient of the original drum storage area. A contaminant, TCA,
was detected in that well at 68 parts per billion (ppb), as compared
to levels of TCA detected in downgradient monitoring wells at levels
of up to 920 ppb. TCA was one of the major contaminants found in
the drums that were stored on site. Most of the contaminants that
went into the ground water are moving downgradient, but due to a
high concentration of TCA at the site, some of the TCA contamination
spread out in t*ll directions for a short distance and was Tl^t^^^d
in the upgradient well.
4. n HUM it; During the public meeting EPA stated that the two
chemicals of concern at Tabernacle are TCA and DCE. A resident
inquired why other chemicals detected in the ground water are not a:
EPA Response; EPA is concerned with any chemical detected in ground
water, and has thoroughly investigated all the chemicals detected
near the Tabernacle site. Many chemicals occur naturally in the
soils of a particular area, and consequently are found dissolved in
the ground water. With the exceptions of TCA and DCE, the other
chemicals detected appear to be within normal background levels, and
are within acceptable limits established by the Federal Safe
Drinking Water Act, and the New Jersey State standards.
5. QjuiiiaiL; Several residents asked if soil samples had been taken at
the site, and what the samples revealed.
EPA Response; The soil samples indicate that the initial soil
removal action at the site took care of virtually all of the
contaminated soil. There is one mall area of soil that may still
contain contaminants and will be reexamined during the initial
phases of the remedial design process. If that area shows
txjiii+^rcnTTreticn at levels above the cleanup criteria f^g****^ \ cSorf for
the soils, EPA will remediate the soil contamination.
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B. CHARACTERIZATION OF FKBBRY OOKTMnNANT, TCA
1. CHiumL; TWo residents asked if TCA could possibly be a naturally
occurring substance in the Tabernacle area. One of the residents
asked whether TCA contamination had been introduced to the ground
water via man-made products.
EPA Response: TCA is a chlorinated hydrocarbon compound that is
man-made and does not occur naturally. It is widely used as a
degreasing agent; for example, electronics manufacturers use it to
ensure that metal parts are very clean so they can be properly
soldered and bonded.
2. comment: One citizen asked whether TCA was a volatile chemical, and
if it would escape into the air after being spilled on the ground.
EPA Resprtise; TCA is a volatile organic compound (VDC), which means
that it does volatilize into the air. However, when spilled on the
ground, seme of it would percolate down into the ground water before
it could volatilize.
3. cmiuaiL: The citizen also asked if EPA has ascertained whether the
TCA at the Tabernacle site would biodegrade over a period of time.
EPA njOQcrv-t: The contaminant plume at Tabernacle is too close to
private wells for biodegradation to be a viable alternative at the
site. Biodegradation has limited applications as a remedial
technology and would take a long tiT^ as compared to more physical
. or chemical types of treatment. It would also require pumping
'. additional material into the ground water, which is not a preferred
EPA policy.
4. Comment: The citizen followed up his question by asking if the TCA
could be diluted in the ground water by pumping in additional water.
EPA Response: Dilution would expand the area of contamination over
time. The contamination might be less concentrated but would still
£rxrvanf\ acceptable levels.
5. OmiuaiL; One person questioned if EPA had estimated the volume of
TCA that would have been necessary to create the contaminant plume
at Tabernacle.
EPA RpRpmspi; A couple hundred gallons of TCA could have created
the plume of contamination at Tabernacle, however, that data is not
needed in order to estimate the extent and size of the plume.
6. OLnimiL; A resident asked if there was any known agent or chemical
that could be used on TCA to neutralize it so that it would not be
harmful to drinking water.
8
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EPA Response: Although chemical bending could theoretically be used
to neutralize TCA, that type of technology could take a long ^jp>e to
develop and perfect and is an unproven treatanent for this type of
contamination. There would be a possibility of creating a worse
problem by pumping new chemicals into the ground.
C. Ground water ECOW AND GCKDOHKANT PUME O3ARACXEKIZATIEN
1. omitait; One citizen asked a number of questions about studies to
characterize ground water flow and velocity in the Tabernacle area.
The first question concerned the amount of background information
that was used for these studies.
EPA Response: EPA used information from the State of New Jersey and
from the U.S. Geological Survey (USGS) that indicated a regional
ground water flow to the east. However, when dealing with a
particular site in a local area, it is important to define the
direction of local ground water flow. The monitoring wells
installed by EPA indicate that the yxuuuJ water flow in the local
area is to the south or southeast.
2. CLumiL; The citizen also asked if EPA had tested the direction of
ground water flow by injecting dye into an upgradient well and then
checking the downgradient wells for the dye.
EPA Response; EPA prefers not to inject dye into the ground
unnecessarily. Ground water moves very slowly and it could take
many months for an injected dye to show up in a downgradient well.
Instead, EPA conducted other proven, reliable tests to determine
'. ground water flow direction.
3. fviiiMMrt-* 2he citizen stated that EPA's initial investigation at the
Tabernacle site estimated the ground water flow velocity at 33 feet
per year. The later remedial investigation indicates the velocity
at 113 feet per year. The citizen wanted to know which figure was
accurate and whether some of the data were inaccurate.
EPA Response; The initial report was an estimate based on the data
available at the time. The remedial investigation had more
monitoring wells and more data, which enabled EPA to more accurately
characterize both the direction and velocity of the ground water
flow.
4. OumnPiit: Several residents asked EPA for more information about the
contaminant plume in the ground water and whether the eight
monitoring wells installed by EPA were adequate to characterize the
plume.
EPA Response; The projection of the plume is based on data from the
eight monitoring wells, along with the known information on the
ground water velocity and the knowledge that the year 1977 was the
earliest possible t.lmp for contaminants to have entered the ground.
-------
5. Commit; One resident requested information on the depth of the
plume. He nsfrpd if the plume stayed near the surface, or if it
floated up and down in the ground water.
EPA Response: There is not a great dpftl of infamation about the
vertical distribution of the contamination. The average depth of
the monitoring wells is about 30 to 35 feet, with the deepest well
going down to 60 feet. The deepest well did not detect any traces
of contamination, but additional information about the depth of the
plume will be compiled during the initial phases of the remedial
design process.
6. Gboment: A citizen asked if EPA's estimate of 14 years for the
contaminant plume to reach residential wells is valid, or if the
time frame could vary based on the initial ground water velocity
data.
EPA Response: Regardless of the time estimate, EPA will not take a
chance with peoples' health. The current data supports the estimate
that it would take at least 14 years for the plume to reach
residential wells. This is a conservative estimate, and it would
probably take many more years for the situation to occur; however,
it is EPA's policy to practice prudent environmental management by
remediating contamination that poses a threat to public health.
D. PUUNTIAL prarrm HAZARDS
1. OiiiiHTit: A local property owner asked if there was some type of
N filtering system he could install on his domestic well that would
• eliminate the types of contaminants that are found at the Tabernacle
site.
EPA Response: There is absolutely no threat to residential wells at
this time. If a resident felt more comfortable by utilizing a
filtration system, then he could use one of the
available units that are several feet long and filled with activated
charcoal.
2. Comment: One resident expressed concerned that contaminants
extracted from ground water by air stripping would enter the air.
He stated that if the contaminants are not good in the ground water,
* then they probably should not be in the air.
EPA Response: During the air stripping treatment contaminants
volatilize into the air from the water. However, there is also a
carbon filtration technology that EPA can use that can capture the
contaminants prior to release into the air. In addition, the
exhaust gases from the air stripping unit would be treated to meet
federal air emission standards and the requirements of the New
Jersey Air Pollution Control Act.
10
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3. QuintsiL: A resident inquired about the potential hazards to human
health that could result from consumption of contaminated ground
water.
EPA Response; At this time, there is no contamination of
residential or municipal wells. If, however, someone was to drink
contaminated ground water from a well directly on the Tabernacle
site, it could result in Illness. It should be reemphasized that
the most recent sampling of wells indicated no sign of
contamination.
E. TECHNICAL QUESTIONS REGARDING AIR STRHTTNG TREATMENT
1. Ouiuiait; A resident inquired about the physical characteristics and
operation of the proposed air strippers.
EPA Response; The air stripping towers are about 20 to 30 feet
high, and will not be visible at the Tabernacle site because of the
tree cover. The towers are relatively quiet, and could be compared
to the noise of a washing machine. Several technical personnel will
staff the towers at all times.
2. QiiLfcait; One resident commented that if the air stripping technique
is used, then he would want a cartxm filter on the unit to capture
the off-gases.
EPA Response; EPA, as part, of its commitment to protect the
environment will comply with all federal and state environmental
laws, including the New Jersey Emission Standards. A filter will
' certainly be used if the off gases are above allowable limits, to
prevent the release of these gases into the atmosphere.
3. OuuufcgiL; One individual inquired about EPA's experience in cleaning
up sites similar to the Tabernacle site.
EPA Response: There is more work like this in New Jersey than in
any other state in the country. Remediation decisions have been
**** at over 30 sites in New Jersey. In many of these cases the
qruutii water is the primary problem, just as it is at Tabernacle.
This is the tenth or twelfth time in this region that EPA will
conduct this type of action, and EPA is confident that this
remediation will be successful.
F. OTHER uuMKimg TREATMENT AI3ERNATTVES
1. O-iuutfliL; One resident wanted to know if it would be feasible to dig
. up all of the contaminants and make a lake.
EPA Response; Virtually all of the contaminated soil has been
removed. Contaminants remaining at the Tabernacle cite are located
in the subsurface ground water, and it would not be feasible to
excavate them.
11
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2. Comment: Another resident »eVgH what would happen to the ground
water during treatment if the "Pump/Treat Using Activated Carbon"
alternative was used at the site.
EPA Response; The ground water would be pumped out of wells, and
passed through a portable treatment facility containing carbon
filters. The water would then be immediately recharged into the
ground.
3. cmiuaiL; A resident expressed concern about the alternative that
involved pumping and then treating the water at an off-site
facility. He wanted to know what would happen to the water after it
was trucked to the off-site facility for treatanent.
EPA Response: The treated water would be released at the treatment
facility. For example, if the chosen facility was near the Delaware
River, then the treated water would be piped right into the river.
EPA doesn't prefer this alternative because of the logistical
difficulty required to move the estimated 143 ™
-------
*
2. Cuuuait; A citizen asked EPA for the price breakdown of each
alternative.
EPA Response; Alternative 1 is approximately $200,000; Alternative
2 is approximately $1,100,000; Alternative 3 is $1,000,000;
Alternative 4 is $9,400,000; Alternative 5 is $2,700,000;
Alternative 6 is $750,000; Alternative 7 is $700,000; Alternative 8
is $500,000; and Alternative 9 is $400,000.
3. CuiiuaiL; A citizen also requested information on whether the cost
of the alternatives included equipment and hardware costs that would
be necessary to implement the treatments, and if there were residual
values attached to the hardware after the cleanup was completed.
ERA Response: Ihe cost estimates do include all the necessary
equipment and hardware. However, any residual values are not
included in the cost estimates.
4. Comment: A resident asked EPA if Atlantic Disposal Services would
assume financial responsibility for the investigation and
remediation of the Tabernacle site.
EPA Response; One of the reasons why Congress passed the Superfund
law was to give EPA a block of money that could be used to clean up
hazardous waste sites without delays. EPA pursues legal channels
whenever possible to seek reimbursement for the costs incurred at
Superfund sites.
TV. REMAINING CCNOEENS
1. r\«iiiMi«-; Several residents asked how much longer it will take to
clean up the Tabernacle site.
EPA Response; A final decision regarding a selected remedial
alternative will be made following completion of the public
period. EPA will then hire a contractor to design the remedial
alternative. This will take about 8 to 10 months. Construction of
the rgp*ft'tial alternative will take an additional 6 months. Once the
system is in operation, it will take one to two years to completely
remove the contaminants from the aquifer. -
2. p.yinMifci Two residents wanted to know how EPA would determine when
the ground water was really clean. Ihey asked how long EPA would
continue to monitor wells after the cleanup, and whether EPA could
install a sentry well closer to residential wells that would give
adequate warning if contamination continued to spread.
13
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EPA Response: If necessary, EPA could install a sentry well closer
to residential wells. EPA will continue to monitor wells after
remediation until federal and state cleanup standards are attained
to the raxi'™™ extent which is technically possible. At other sites
of this type the monitoring has generally been continued on an
annual basis over a five year period.
3. OuuifcaiL; A resident inquired if there would be any residual damage
at the Tabernacle site when EPA completed the remediation.
EPA Response: When remediation is complete, there will not be any
residual damage to the site. All equipment will be removed, and,
upon completion of monitoring, there will be no indication that
Tabernacle was a nnTarrtnis waste site.
4. ' OuiiimL; A resident asked how the public will be notified once EPA
reaches a decision regarding selection of a final remedial
alternative.
EPA Response; EPA will issue a press release to be published in
local newspapers that will announce the selected remedial
alternative.
5. OumtfliL; A citizen inquired about the steps EPA took to finalize
the Draft Final RI/FS Report. Two other residents requested
information on the location of site related documents.
EPA Response: EPA will incorporate public comments on the Draft
Final RI/FS Report into the Record of Decision (POD) for the
Tabernacle site. This is done to ensure that the Report is
accurate, and that everyone has a chance to comment on potential
inconsistencies. Site related documents are available for review at
the listed information repositories.
14
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APPENDIX A
Attachment I
LIST OF ATTACHMENTS
Correspondences received from local residents
during the public comment period and EPA's
response.
Attachment II - Correspondences received from local/county
officials or agencies during the public
comment period and EPA's response.
Attachment III - Comments received from PRPs during the public
comment period and EPA's technical responset
as prepared by the government contractor.
•
v
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.Attachment I"
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S3
IS A^tsL^&i
-------
«° "="•«,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
Dr. and Mrs. Anthony J. Andrews
53 Bozarthtown Road, R.D. No.3
Vincentown, New Jersey 08088
Dear Dr. and Mrs. Andrews:
This is in response to your letter, dated March 21, 1988, which
provided comments on the proposed remedial action plan (PRAP)
for the Tabernacle Drum Dump Superfund site in Tabernacle, New
Jersey.
The Environmental Protection Agency (EPA) received a number
of comments during the public meeting for the Tabernacle site.
The comment period extended from February 24 to April 21, 1988.
After review of all submitted comments, EPA intends to proceed
with a final remedial solution for the site that is protective
of human health and the environment, cost-effective, and attains
federal and state requirements that are applicable or relevant
and appropriate.
The remedial solution corresponds to Alternative 3 in the RI/FS
report.• It will be discussed in detail in the Record of Decision
(ROD) for the Tabernacle site. The remedial action includes the
following components: installation of additional ground water
monitoring wells to further delineate the extent of the contami-
nant plume; implementation of a ground water monitoring program
for down-gradient residential wells until the contaminant plume
has been more precisely delineated; additional soil sampling at
the former drum dumping and storage area to support existing
data indicating only trace levels of contaminants; extraction
of the contaminated ground water through pumping followed by
on-site treatment and reinjection of the treated effluent into
the ground (to continue until federal and state cleanup standards
are attained to the maximum extent practicable); and implementa-
tion of a ground water monitoring program for a period of five
years after site cleanup goals have been achieved.
Your March 23 letter expressed a preference for the implementa-
tion of both Alternatives 3 and 7 as the remedial solution for
the Tabernacle site.
-------
-2-
Implementation of Alternative 7 would involve abandoning the
existing down-gradient residential wells, which tap into the
Cohansey aquifer, and drilling new deep wells into the under-
lying Kirkwood aquifer. The evaluation of Alternative 7,
which was carried out in the ROD, determined that this
alternative is highly unreliable since the new residential
wells may provide contaminated water. This situation could
result from improper well installation and the potential for
hydraulic connection between the contaminated upper Cohansey
aquifer and the underlying Kirkwood aquifer. In addition,
the Kirkwood aquifer is not typically used as a source of
potable water in the Pine Barrens area.
The remedial action described in the ROD includes a provision
for ground water monitoring of the residential wells during
the initial phases of the remedial design process. In
addition, should contamination be detected, appropriate
measures will be taken to mitigate the situation and provide
potable water supplies to the affected residents. This
provision will ensure a more prompt and effective response
than that proposed by Alternative 7. Therefore, Alternative 7
has not been incorporated into the final remedial solution
developed by EPA for the Tabernacle site.
I hope that your concerns have been adequately addressed.
Your interest in the environment at the Tabernacle site is
greatly appreciated.
Sincerely yours,
Original Signed By
Lorraine Frigerio
Lorraine Frigerio, Project Manager
Southern New Jersey Remedial Action Section
-------
?&,, Vi'n'cejiipwn, tJ.J. 08083
»*./f/7 .. ".//'•/*
Ms. Lorraine Frigerio "'"••
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
New York, New York 10278
Dear Ms. Frigerio:
We would like to take this time to comment on the Proposed
Remedial Action Plan. While we agree, that alternative 3 is an
acceptable choice to extract the contaminated ground water
plume, we also feel alternative 7, the installation of new
residential wells, is imperative and should be part of the PRAP.
We have reached this conclusion based on the facts released
at the Tabernacle Township meeting. It had been stated at the
m&eting that the contamination is not primarily at the original
source but has moved on to attack the wells of homeowners south-
east of the drum site. Being a homeowner located southeast of the
drum site and obtaining our drinking supply through the Cohansey
Aquifer, we feel, to insure the safety of our family, we should
be allowed to have a new residential well installed.
In our research we have determined that the clay layer
between 'the Cohansey and Kirkwood Aquifers' range from four (4)
feet in thickness to ten (10) feet. We feel this is not
sufficient thickness to protect us and our right to quality
drinking wster. We would like to see, since we are in the
direct path of the plume, the construction of a new residential
well in the Mt/ Laurel Aquifer due to this clay layer being
approximately two hundred (200) feet 'thick.
In conclusion, we feel that as a homeowner, we can protect
our family if alternatives three (3) and seven (7) are
implemented. W<= would like to see alternative seven (7) be
extended to including the ability to tap into -the Mt. Laurel
Aquifer esprecially for residents in the direct plan of the
contaminated plum.
Thank you for allowing us to express our concerns and views.
Sincerely,
ohn and Andrea Esposito
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i?2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1OE78
Mr. and Mrs. Esposito
73 Bozarthtown Road
P.O. Box 2252
Vincentown, New Jersey 08088
Dear Mr. and Mrs. Esposito:
This is in response to your letter, dated March 23, 1988, which
provided comments on the proposed remedial action plan (PRAP)
for the Tabernacle Drum Dump Super fund site in Tabernacle,
New Jersey.
The Environmental Protection Agency (EPA) received a number
of comments during the public meeting for the Tabernacle site.
The comment period extended from February 24 to April 21, 1988.
After review of all submitted comments, EPA intends to proceed
with a final remedial solution for the site that is protective
of human health and. the environment, cost-effective, and attains
federal and state requirements that are applicable or relevant
and appropriate.
The remedial solution corresponds to Alternative 3 in the RI/FS
report. It will be discussed in detail in the Record of Decision
(ROD) for the Tabernacle site. The remedial action includes the
following components: installation of additional ground water
monitoring wells to further delineate the extent of the contami-
nant plume; implementation of a ground water monitoring program
for down-gradient residential wells until the contaminant plume
has been more precisely delineated; additional soil sampling at
the former drum dumping and storage area to support existing
data indicating only trace levels of contaminants; extraction
of the contaminated ground water through pumping followed by
on-site treatment and reinjection of the treated effluent into
the ground (to continue until federal and state cleanup standards
are attained to the maximum extent practicable); and implementa-
tion of a ground water monitoring program for a period of five
years after site cleanup goals have been achieved.
Your March 23 letter expressed a concern over the fact that the
contamination at the site has extended beyond the original
source as a ground water plume which is moving in a south-
easterly direction. As a homeowner located in this direction,
you also expressed a preference for the implementation'pf both
Alternatives 3 and 7 as the remedial solution for the Tabernacle
site.
-------
-2-
Implementation of Alternative 7, as described in the PRAP,
would involve abandoning the existing down-gradient residen-
tial wells which tap into the Cohansey aquifer and drilling
new deep wells into the underlying Kirkwood aquifer. The
evaluation of Alternative 7, which was carried out in the
ROD, determined that this alternative is highly unreliable
since the new residential wells may provide contaminated
water. This situation could result from improper well
installation and the potential for hydraulic connection
between the contaminated upper Cohansey aquifer and the
underlying Kirkwood aquifer. Your March 23 letter proposes
that new residential wells be installed into the Mount Laurel
aquifer which underlies the Kirkwood. These new residential
wells would need to extend to a depth of several hundred feet.
Improper well installation, which is more likely to occur at
increasing depths, could also result in cross contamination
of the water supply obtained from the Mount Laurel aquifer.
The remedial action described in the ROD includes a provision
for ground water monitoring of the residential wells during
the initial phases of the remedial design process. In addition,
should contamination be detected, appropriate measures will
be taken to mitigate the situation and provide potable water
supplies to the affected residents. This provision will
ensure a more prompt and effective response than that proposed
by Alternative 7. Therefore, Alternative 7 has not been
incorporated into the final remedial solution developed by
EPA for the Tabernacle site.
I hope that your concerns have been adequately addressed.
Your interest in the environment at the Tabernacle site is
greatly appreciated.
Sincerely yours,
Original Signed By
Lorraine Frigerio
Lorraine Frigerio, Project Manager
Southern New Jersey Remedial Action Section -
-------
78 Bozarthtown Road "^fy** &- '
Vincentown, NJ 08088 '<£'
March 23, 1988
Lorraine Frigerio
Remedial Project Manager
U.S. EPA
Room 711
26 Federal Plaza
New York, New York 10278
Dear Ms. Frigerio:
•
We have reviewed the proposed remedial action .plan for the
Tabernacle Drum Dump and have several concerns and recommendations.
Although we believe the primary objective of this remedial action
is to provide the residents with pure water we also believe in a clean
environment and any plan that only treats the symptoms and does not
correct the problem is totally unsatisfactory. In our opinion Alter-
natives 1, 5, 6 and 8 fall into this category and we recommend that
they be eliminated from serious consideration.
Ve believe that a combination of Alternative 3 (pump and treat via
air stripping) and Alternative 7 (installation of new residential
wells) is the best solution. Alternative 3 would eventually elimi-
nate the source of contamination while Alternative 7 would immediately
ensure residents with a pure water supply.
One concern with Alternative 3 is the potential health implica-
tions of the gases from the volatile organic compounds. What type of
health risks are associated from these gases and how will the monitor-
ing be conducted to ensure there is no health risk to residents? The
report indicates that this procedure is an effective technology for
removal of pollutants. However, we are concerned that should Alterna-
tive 3 become delayed or develops complications the residents will be
living in fear of potential veil contamination. Thus, the recommenda-
tion for implementation of Alternative 7 in addition to Alternative 3.
In summary, regardless which alternative is selected to purify the
contaminated ground water, the installation of new residential wells
should be incorporated into the remedial action. Residents of this
area have had to live with the threat of well contamination since this
dump site was discovered and should not be expected to 'endure this
stress any longer.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
<""e"V 26 FEDERAL PLAZA
REGION I I
EDERAL PL
NEW YORK. NEW YORK 1O278
Mr. and Mrs. McCloy
78 Bozarthtown Road
Vincentown, New Jersey 08088
Dear Mr. and Mrs. McCloy:
This is in response to.your .letter, dated March 23, 1988, which
provided comments on the proposed remedial action plan (PRAP)
for the Tabernacle Drum Dump Superfund site in Tabernacle, New
Jersey.
The Environmental Protection Agency (EPA) received a number
of comments during the public meeting for the Tabernacle site.
The comment period extended from February 24 to April 21, 1988.
After review of all submitted comments, EPA intends to proceed
with a final remedial solution for the site that is protective
of human health and the environment, cost-effective, and attains
federal and state requirements that are applicable or relevant
and appropriate.
The remedial solution corresponds to Alternative 3 in the RI/FS
report.' It will be discussed in detail in the Record of Decision
(ROD) for the Tabernacle site. The remedial action includes the
following components: installation of additional ground water
monitoring wells to further delineate the extent of the contami-
nant plume; implementation of a ground water monitoring program
for down-gradient residential wells until the contaminant plume
has been more precisely delineated; additional soil sampling at
the former drum dumping and storage area to support existing
data indicating only trace levels of contaminants; extraction
of the contaminated ground water through pumping followed by
on-site treatment and reinjection of the treated effluent into
the ground (to continue until federal and state cleanup standards
are attained to the maximum extent practicable); and implementa-
tion of a ground water monitoring program for a period of five
years after site cleanup goals have been achieved.
Your March 23 letter expressed certain concerns over the
potential for residential well water contamination to occur
should the implementation of Alternative 3 become delayed or
develop complications. Therefore, you expressed a preference
for the implementation of both Alternatives 3 and 7 as the
remedial solution for the Tabernacle site. '»
-------
Implementation of Alternative 7 would involve abandoning the
existing down-gradient residential wells which tap into the
Cohansey aquifer and drilling new deep wells into the under-
lying Kirkwood aquifer. The evaluation of Alternative 7,
which was carried out in the ROD, determined that this
alternative is highly unreliable since the new residential
wells may provide contaminated water. This situation could
result from improper well installation and the potential for
hydraulic connection between the contaminated upper Cohansey
aquifer and the underlying Kirkwood aquifer. In addition,
the Kirkwood aquifer is not typically used as a source of
potable water in the Pine Barrens area.
The remedial action described in the ROD includes a provision
for ground water monitoring of the residential wells during
the initial phases of the remedial design process. In
addition, should contamination be detected, appropriate
measures will be taken to mitigate the situation and provide
potable water supplies to the affected residents. This
provision will ensure a more prompt and effective response
than that proposed by Alternative 7. Therefore, Alternative 7
has not been incorporated into the final remedial solution
developed by EPA for the Tabernacle site.
Another concern raised in your letter was directed at the
potential health impacts associated with the exhaust gases
emitted from the air stripping unit in Alternative 3. One of
the activities to be performed during the remedial design
process is an analysis of the contaminant concentration levels
in the air stripping emissions. This analysis will determine
whether" additional post-treatment units are required to
meet national and state ambient air quality standards. If
additional treatment units are necessary, the exhaust gases
will be treated to meet federal air emission standards and
the requirements of the New Jersey Air Pollution Control Act.
I hope that your concerns have been adequately addressed.
Your interest in the environment at the Tabernacle site is
greatly appreciated.
Sincerely yours,
Original Signed By
Lorraine Frigerio
Lorraine Frigerio, Project Manager
Southern New Jersey Remedial Action Section
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Attachment II
-------
The Pinclands Commissiofl|y
P.O.Box 7, New Lisbon, N. J. 08064 (609) 894-9JJ2 •
March 23. 1988 > «!
^A "~
"%
Lorraine Frigerio
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
New York, New York 10278
Re: Tabernacle Drum Superfund Site
Dear Ms. Frigerio:
*
The Pinelands Commission staff has reviewed the "Draft Final
Remedial Investigation/ Feasibility Study" (RI/FS) prepared for
the referenced hazardous waste site. The Commission is also in
receipt of the News Release dated March 2, 1988 which identifies
the preferred remedial alternative.
The fol lowing comments are offered concerning the RI/FS and the
identified preferred remedial alternative:
' *\
1. The standards contained in the Pinelands Comprehensive
Management Plan should be included as "Applicable
Relevant and Appropriate Requirements" (ARARS). The
conditions at* the Tabernacle Drum Site raise particular
concerns with regard to the Pinelands water quality
standards.
The Pinelands Comprehensive Management Plan (CMP) was
adopted by the Finelands Commission pursuant to the
National Parks and Recreation Act of 1978 and the New
Jersey Pinelands Protection Act of 1979. One of the
stated purposes of both the state and -federal acts is
the preservation and protection of the exceptional
surface and ground water quality within the Pinelands
area. The water quality standards of the CMP
(promulgated as N.J.A.C. 7:50-6.8) require that no
development be permitted which degrades surface or
ground water quality or which does not meet state water
quality standards, in this case GW-1.
Therefore, while the water quality standards of the CMP
do not identify specific limits for the contaminants'
found in the groundwater at the site, the
non-degradation standard should be applied to any
proposed remediation. Proposed clean-up goals should be
set at natural background levels for all substances.
The Pinelands - Our Country's First National Reserve
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2. The RI/FS does not address any environmental impacts
such as potential degradation of the habitat and
impacts upon the biota at the down-gradient cranberry
bog and surface water into which the contaminant plume
will discharge.
3. Lead and chromium levels in groundwater exceeded
background levels and at least one of the identified
ARARS, yet the proposed remediation is for
tr-ichloroe thane (TCA) and 1,1-dichloroethene only.
Clarification is needed concerning the reason for the
elimination of the metals as contaminants of concern.
The news release identifies the preferred remedial alternative
as the pumping, treatment and re inject ion of the contaminated
plume of groundwater. The news release does not identify the
levels to which the contaminant concentration will be treated.
Any remediation which will not reduce contaminant concentrations
to background levels cannot be considered to be consistent with
the standards of the CMP. If it was not technically feasible to
achieve background levels, the standards of the CMP would
require that appropriate contaminant limits be based upon
environmental risk assessment as well as human health risk
assessments.
The Pinelands Commission will object to any Record of Decision
which does not address the standards of the Pinelands
Comprehensive Management Plan and the concerns raised herein.
If there are any questions concerning this matter, please
contact Kathleen Swigon, of my staff.
Sincerely,
Will'iam F. Harrison
Assistant Director
c.c. Arnold Schiffman, N.J. D.E.P.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
May 11, 1988
Mr. William F. Harrison
Assistant Director
The Pinelands Commission
P.O. Box 7
New Lisbon, New Jersey 08064
Dear Mr. Harrison:
This is in response to your letter, dated March 23, 1988, which
provided comments on the remedial investigation and feasibility
study (RI/FS) and the preferred remedial alternative.for the
Tabernacle Drum Dump Superfund site in Tabernacle, New Jersey.
The Environmental Protection Agency (EPA) has received a number
of comments during the public meeting for the Tabernacle site.
The comment period extended from February 24 to April 21, 1988.
After review of all submitted comments, EPA intends to proceed
with a final remedial solution for the site that is protective
of human health and the environment, cost-effective, and attains
federal and state requirements that are applicable or relevant
and appropriate.
The remedial solution corresponds to Alternative 3 in the RI/FS
report. It will be discussed in detail in the Record of Decision
(ROD) for the Tabernacle site. The remedial action includes the
following components: installation of additional ground water
monitoring wells to further delineate the extent of the contami-
nant plume; implementation of a ground water monitoring program
for down-gradient residential wells until the_contaminant plume
has been more precisely delineated; additional soil sampling at
the former drum dumping and storage area to support existing
data indicating only trace levels of contaminants; extraction
of the contaminated ground water through pumping followed by
on-site treatment and reinjection of the treated effluent into
the ground (to continue until federal and state cleanup standards
are attained); and implementation of a ground water monitoring
program for a period of five years after site cleanup goals
have been reached.
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-2-
I would now like to address the specific comments presented in
your March 23 letter.
Your first comment suggests that the proposed cleanup goals be
set at natural background levels for all substances based on
the non-degradation standard of the Pinelands Comprehensive
Management Plan (CMP).
EPA would like to make a number of points relative to this com-
ment. First, our proposed cleanup action should not be considered
new development which may degrade water quality in the Pinelands.
Rather, the ground water in the aquifer underlying the Tabernacle
site is contaminated as a result of improper hazardous waste
disposal. By extracting and treating this ground water, the
water quality will be significantly improved. For this reason,
we do not believe that the non-degradation standard is an
applicable requirement.
In addition, it is EPA's policy to only consider numerical or
quantitative standards in establishing cleanup goals for Superfund
sites. Since the Pinelands CMP does not identify specific
concentration limits for the contaminants found in the ground
water underlying the Tabernacle site, EPA has looked at other
regulatory and legislative requirements in determining appropriate
cleanup levels.
The remediation planned by EPA will not reduce contaminant con-
centrations in the ground water to background levels. For your
information, cleanup to such levels is not technically feasible.
The State of New Jersey has developed numerical water quality
standards for a number of chemical substances under its A-280
legislation. The State standards have been developed based on
risk assessment factors. Therefore, EPA has determined that
they are appropriate cleanup requirements for the Tabernacle
site.
EPA agrees with your second comment that further information is
needed to assess any environmental impacts in ±he vicinity of
the site. In particular, additional sampling will be undertaken
in the nearby wetlands to determine whether it has been affected
by site contaminants.
With regard to your third comment, although the RI/FS focused
on ground water contamination involving 1,1,1-trichloroethane
(TCA) and 1,1-dichloroethene (DCE) in the development of various
remedial alternatives, the selected remedial action outlined
above contains provisions to address other ground water contami-
nants which may be detected during final delineation of,the
plume. The cleanup goals for these additional contaminants
will be developed consistent with the most conservative appro-
priate numerical standards.
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-3-
The ARARs (applicable or relevant and appropriate requirements)
for the Tabernacle site which are currently identified in the
ROD include cleanup levels of 26 parts per billion (ppb) for
TCA and 2 ppb for DCE which are the proposed Maximum Contaminant
Levels established by the State of New Jersey under its A-280
legislation. These health-based levels are more stringent than
federal standards for these same compounds. Although they are
only proposed at this time, promulgation of the State levels is
expected prior to the implementation of the remedial action.
Therefore, EPA has determined that they are the appropriate
ARARs for the Tabernacle site. Cleanup levels for any additional
contaminants which may be detected will be established in a
similar manner.
Your cooperation in providing comments on our proposed remedial
action is greatly appreciated. I hope that the concerns raised
by the Pinelands Commission have been fully addressed. Should
you have any further questions in this matter, do not hesitate
to contact me or Lorraine Frigerio, the project manager for the
Tabernacle site, at (212) 264-1870.
Sincerely yours,
SIGNED BY
j. S. FRISCO
John S. Frisco, Chief
New Jersey Remedial Action Branch
*
cc: Anthony J. Farro, NJDEP
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Attachment III
-------
COMMENTS TO DRAFT FINAL REMEDIAL INVESTIGATION AND FEASIBILITY
STUDY AT THE TABERNACLE DRUM SITE
SUBMITTED BY!
ATLANTIC DISPOSAL
SERVICE, INC.
Church and Springdale Roads
Mt. Laurel, New Jersey 08054
Of Counsel:
RIVKIN, RADLER, DONNE 6 BAYH
EAB Plaza
Uniondale, N.Y. 11556-0111
(516) 357-3000
DATED: April 21, 1988
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I. INTRODUCTION
These comments, along with the annexed comments by O.K.
Materials, Inc. ("OHM") (Exhibit A), are submitted on behalf of
Atlantic Disposal Service, Inc. ("Atlantic") in response to the
Draft Final Remedial Investigation and Feasibility Study ("RI/FS")
at the Tabernacle Drum Site prepared by Camp, Dresser & McKee,
Inc. ("CDM"), dated February 24, 1988. The purpose for these
comments is to highlight the deficiencies in the RI/FS,
deficiencies which are so significant that they evidence
inconsistencies with the National Contingency Plan ("NCP"). These
deficiencies also invalidate the proposed remedial alternative
offered by the United States Environmental Protection Agency
("EPA") for the Tabernacle Drum Site.
II. BACKGROUND
*"» • *
CDM notes that the Tabernacle Drum Site is located in
Tabernacle, New Jersey in a rural section in the southern part of
the State. The site measures approximately 125 by 75 feet in
size. The RI reports that the site was the residence of Mr.
Robert Ware, a former employee of Atlantic, and his wife in the
mid-1970's when permission was granted to Atlantic to store
containers at the site. In 1982 the Government was alerted to the
presence of these containers and efforts were begun to remove them
from the site. To that effect, CDM notes that in 1984, EPA •
ordered Atlantic to perform a surface cleanup at the «ite.
Atlantic subsequently hired Freehold Cartage, Inc. to* perform the
r
surface cleanup work which was completed in July 1984. The site
was cleared of all containers and visible surface contaminants.
-------
The cost of this cleanup, which was borne entirely by Atlantic,
was approximately $160,000. Subsequently, CDM prepared a work
plan to undertake an RI/FS at which tine comments were submitted
by Atlantic challenging the scope and necessity of the outlined
program. This program was subsequently implemented by CDM and has
resulted in the subject Draft Final RI/FS Report. Under no
circumstances does Atlantic concede the accuracy or relevancy of
any of the facts alleged by CDM in its RI/FS.
III. GENERAL COMMENTS
The RI/FS is fundamentally flawed in that it does not
determine the extent of any contamination at the site or the
threat presented by the alleged releases. After expending
$750,000 to conduct this RI/FS, CDM has failed to define the site.
It must be noted here that EPA stated at the work plan stage that
the cost of an RI/FS that would determine the extent of the
release would not exceed $375,000-$500,000 for this site. The NCP
requires that an RI/FS shall be undertaken to determine the nature
and extent of the threat presented by a release, including the
gathering of sufficient information to determine the necessity tor
and proposed extent of remedial action. Hence., the RI/FS for the
Tabernacle Drum Site is inconsistent with the NCP and has exceeded
the cost estimates for its preparation by almost 100%.
The Comprehensive Environmental Response, Compensation
and Liability Act ("CERCIA"), 42 D.S.C. | 9607, as amended by the
Superfund Amendments and Reauthorization Act ("SARA"), requires
»
that remedial alternatives be chosen on the basis of their ability
-2-
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to provide a permanent solution to the hazardous condition at a
site. By COM's own admission, the extent of any contaminant plume
underlying the site remains undefined. This admission alone
demonstrates an inability to fashion an appropriate remedial
alternative. Therefore, any alternative selected by EPA based
upon the scant data developed thus far is wholly speculative and
cannot be considered consistent with Section 9621(b)(l) of SARA
mandating the use of permanent solutions.
Atlantic recommends that an alternative be developed
that will overcome the data deficiencies that pervade the RI and
still provide for protection of the public health and
environment. Consequently, Atlantic suggests an alternative
remediation strategy consisting of removal of contaminated
groundwater for treatment through a combination of air stripping
and granular activated carbon. In this manner the benefits of
EPA1 s alternatives No. 2 and No. 3 can be incorporated into a plan
that is flexible enough to account for actual conditions at the
site that have not been defined to date. Moreover, the needless
expenditure of additional sums to further investigate this site
will be avoided by this alternative. ~
IV. COMMENTS ON REMEDIAL INVESTIGATION
The NCP provides that:
An RI/FS shall, as appropriate, be undertaken
by the lead agency conducting the remedial
action to determine the nature and extent of
the threat presented by the release and to
evaluate proposed remedies. This includes
sampling, monitoring, and exposure assessment',
as necessary, and includes the gathering of
sufficient information to determine the
-3-
-------
necessity for and proposed extent of remedial
action.
40 C.F.R. 8 300.68 (d). However, the RI/FS for the Tabernacle Drum
site does not meet these requirements. The definition of .
contamination at this site, COM admits, remains unknown.
(Remedial Investigation ("RI"), 5-40, 7-1). In fact, CDM
anticipates continuing its Investigations during the design phase
so that it can finally determine how it will remediate the site.
(RI, 7-1). This methodology is inconsistent with the NCP and
blatantly inappropriate as it undertakes the design of remedial
alternatives before fully evaluating conditions at the site which
could affect the choice of an alternative.
A. Data Evaluation Deficiencies
There is overwhelming evidence that CDM's remedial
investigation was improperly conducted. Data inaccuracy and
imprecision is found throughout CDM's draft final report. Strong
support for the assertion that this data is unreliable is the fact
that the results of field sampling is often based on contaminated
rinse and field blanks, evidence of quality assurance and quality
control ("QA/QC") deficiencies. Tables 5-6 and 5-9 demonstrate
QA/QC results which highlight deficiencies in sampling and
decontamination procedures. This point has been conceded by CDM
in its discussion of chromium levels found in well samples, where
they point out that chromium was also detected in field blanks
accompanying these samples. (RI, 5-22).
r
The analysis of metals is another example of data
evaluation deficiencies. Table 1-8 indicates aetals contamination
-4-
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in upgradient veils (Wills and Condurso), as well as dovngradient
wells. This indicates that a measurement of total metals does not
represent contamination solely as a result of the site. As
indicated in the attached comments by OHM, the analysis for
dissolved metals is a better indication of groundvater conditions.
B. Failure to Accurately Define Aquifer Characteristics
Further evidence of an inadequate investigation is
represented by CDM's failure to adequately define aquifer
characteristics. CDM has relied upon figure 2-2 to illustrate
that the aquifer thickness is 100 feet. It is obvious that this
assumption is pure speculation as that figure depicts most of New
Jersey, while the site, indicated in the figure by a small dot is
only about one acre in area and only a portion of that
(approximately 2,000 square feet) was allegedly affected by
contamination.
As OHM points out, CDM had only to install a deep boring
at the site in order to accurately determine this parameter.
CDM's assumption, however, is not based on site specific data,
rather it is based upon literature references of a regional
perspective. While this may be proper procedure for scoping the
site, it is not appropriate for actual site characterization.
Further, the depth of 100 feet is used later to calculate
hydraulic conductivity which is key to a determination of
groundwater velocity. Therefore, this assumption raises serious
questions about the validity of estimated groundwater velocities
»
and associated remedial alternatives which rely upon them.
-5-
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Calculations for hydraulic gradient are not adequately
described in the RI. OHM points out that the actual hydraulic
gradient in the vicinity of the site can vary as much as 30% (7.7
ft/mile to 10.5 ft/mile). The use of 8.9 ft/mile as a gradient
for calculating velocity includes enormous errors which have not
been accounted for or even mentioned in the RI. The hydraulic
conductivity utilized by CDM in calculating groundwater velocity
(343.5 gpd/sg. ft.) is in great variance with conductivities
referred to in the literature. (RI, Table 3-1). As CDM's
estimate is also based upon its previously discussed estimate of
aquifer thickness, there are obvious errors associated with this
parameter which have not been accounted for in the RI.
The calculation of groundwater velocity, which is used
in the report to estimate contaminant travel times, relies upon
each of'.the above aquifer characteristics, as pointed out in the
RI. (RI, 3-6). Given the enormous uncertainties associated with
these parameters, as described above, there is no meaningful ?
value in relying upon a velocity based upon them as has been done
in the RI.
Another flaw in the remedial investigation concerns
site specific data for subsurface soils. The general discussion
of soils in the area does not rely upon site specific data
concerning soil type, but instead relies upon interstate and
regional data which could affect assumptions of vertical and
horizontal permeabilities. Since background soil borings were not
" *
drilled, there is no basis for this data comparison. A more
-------
appropriate procedure would have been to compare specific on-site
data and background data. The failure to make this comparison
invalidates CDM's conclusions and ignores contaminant transport
through on-site soils.
C. Failure To Define Contamination At The Site
A major consequence of the inadequate definition of the
aquifer is a failure of the RI to characterize the extent of
groundwater contamination, both vertically and areally. Indeed,
the RI not only fails in this characterization, but it portrays a
lack of understanding of contaminant migration. This is
exemplified by figures 5-4 and 5-5 which obviously do not
correspond. As noted by OHM, figure 5-4 depicts migration in an
easterly direction from MW-2 towards MW-3. Figure 5-5, however,
indicates that migration is how moving in a southerly direction
towards'MW-6. it is likely that CDM's decision also to ignore
chemical transport parameters such as dispersion, sorption,
dilution and biodegradation has contributed to its failure to
characterize the contaminant plume. (RI, 6-19). It must be
emphasized that this factor is critical to the evaluation of the
"no action" alternative.
D. Inappropriate Reliance On Chemical Migration Rates
As noted above, inaccurate data and site
characterization pervade the RI. Accordingly, estimated
contaminant travel times should not be based upon these data and
characterizations, as COM has done. As-the attached comments of
»
OHM point out, estimates of contaminant velocity can vary
-7-
-------
tremendously rendering conclusions based upon these estimates
unreliable. While the RI relies upon a contaminant migration rate
of 94 feet per year, OHM finds a velocity of 42 feet per year to
be reasonable. Moreover, in its work plan for the RI/FS, COM had
calculated groundwater velocity at approximately 31 feet per year.
(RI/FS Work Plan, 2-19). The vide variation in estimates of
velocity noted above, demonstrates that little weight should be
placed upon them. However, COM relies upon its estimate of
contaminant migration rates in its assessment of exposures without
qualification.
E. Inconsistencies in Public Health Evaluation
The public health evaluation contained in Section 6 of
the RI points out the weakness in relying upon estimated values
containing enormous errors in measurement and determination. It
states that "all of these individual errors from different sources
may be propagated into larger errors by mathematical combination
in the risk assessment." (RI, 6-29). Nonetheless, it concludes
that even with these enormous errors, useful information may be
provided. However, the above statements ignore practical
considerations of the validity of information forming the basis
for determining remedial alternatives. While at one point the
health evaluation points out the significance of factors tending
to reduce the mobility of contaminants in soil and groundwater,
these considerations are then explicitly ignored (RI, 4-19). In
the place of estimates of chemical transport based upon,
r
reasonable scientific certainty are statements that aigration time
-8-
-------
will approximate 14 years for TCA, for instance. This is in stark
contrast to the estimated migration time of 33 years previously
reported by the same authors in the RI/FS work plan (RZ/FS Work
Plan, 2-22). There seems to be no rhyme or reason to
methodologies evaluating risk in this RI. Hence, the conclusions
which are based upon flawed evaluation and which form the basis
for the determination of a proposed remedial alternative in the
feasibility study, are likewise invalid.
The RI also focuses on several chemicals as presenting
potential health risks over time, without properly evaluating the
reliability of the data utilized. For instance, lead is seen as a
potential health risk although the RI fails to point out that lead
was detected .in significant concentrations in background
residential and monitoring wells during sampling in 1985 (RI,
Table 1-8). The same is true for chromium, where significant
concentrations were detected in upgradient wells. This fact alone
raises serious questions as to the validity of inorganic
groundwater results, especially for total metals, as reported in
RI, Tables 5-9 and 5-10 where inorganics were detected in
upgradient wells in addition to trip, field and rinse blanks used
to verify accuracy of the results obtained. Moreover, organics
such as lead and copper have been viewed in the past by EPA as
artifacts of residential water distribution systems containing
copper and lead elements. Nonetheless, the RI's health evaluation
relies upon total lead concentrations in estimating maximum
»
exposure conditions. It can be seen from Table 6-10 that without
-9-
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lead, maximum exposure conditions would be below the total hazard
index required for site remediation. Hence, the RI raises serious
questions as to the validity of its conclusions that remediation
at the site is necessary based upon concentrations of inorganics
which have not been demonstrated to result from activities at the
site alone.
V. COMMENTS ON FEASIBILITY STUDY
A. Inappropriateness of Proposed Remedial Alternative
As set forth above, aany assumptions were Bade in the
preparation of the RI report. These assumptions, therefore, have
a significant effect on the determinations of the proposed
remedial alternative by the EPA. As these assumptions have been
shown to contain enormous and unqualified errors, the selected
remedial alternative based upon these flawed assumptions must
similarly be questioned.
As pointed out in the accompanying comments by OHM, many
considerations have not been discussed in the feasibility study
portion of this report. In particular, without adequate
understanding of site characteristics, it seems impossible to
fashion an alternative aimed at remediating the site. Not only is
a decision favoring one alternative over another purely
speculative, but an estimation of the dollar cost for implementing
each specific alternative tends to approach absurdity.
B. Failure to Consider Additional Alternatives
It has been recommended by OHM that a further,
*
alternative be considered for remediating the site which would
-10-
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combine the benefits of alternatives No. 2 and No. 3. It is
suggested that such an alternative would combine the benefits of
both alternatives discussed in the Feasibility Study ("FS") vhile
maintaining sufficient flexibility to-be cost effective. In light
of the major deficiencies in evaluating the site as noted above, a
more flexible alternative capable of adjusting to actual site
conditions as they become known would be preferred over one
committing enormous financial resources without any guarantee of
its effectiveness. For this reason, the FS is flawed for having
failed to consider the alternative posed by OHM (combining
alternatives 2 and 3) in the preparation of the FS.
VI. CONCLUSION
The deficiencies that pervade the Draft Final RI/FS are
clear evidence of an investigation and study that is inconsistent
with the NCP. Laboratory contamination and other inadequacies in
the data reported in the RI undermine their value in describing
i
potential environmental contamination at the site. More
significantly, EPA has failed to define the aquifer
characteristics and, as a consequence, has failed to characterize
the extent of contamination at the site during the RI phase. Its
reliance on an estimate of contaminant migration rates without
qualification despite its awareness of the wide variation in
estimates of velocity shows a disregard for the value of the
information the Agency has sought to gather, and is irresponsible
at best.
-11-
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Without adequate data, a clear definition of the site
contamination and an understanding of the contaminant migration
tines, EPA does not have the ability to formulate appropriate
remedial alternatives. Accordingly, the proposed alternative
decided upon by EPA could not reasonably have been based upon
actual conditions at the site and is, therefore, arbitrary.
A more prudent remedial plan to pursue has been
recommended by OHM. This plan involves a combination of
alternatives considered by EPA. It is viewed as being capable of
protecting public health and the environment in a cost effective
manner and should, therefore, be considered by EPA.
-12-
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OJl Materials Corp.
P.O. Box 41
WindMr, NJ 06561-0041
609-443-2800
GENERAL COMMENTS page 1
OHM
Zn general, the RI/FS has several flaws that are apparent
throughout the report and Bay adversely affect the study
conclusions and selection of the ultinate remedial action for
the site. These are as follows:
o QA/QC problems are evident for many of the
analyses performed. Irregularities were
detected in both field procedures and laboratory
procedures (field and trip blanks,
respectively). Some key data, such as dissolved
lead results were considered invalid by EPA and
not used during the risk assessment.
o The velocity of groundwater is calculated using
several assumed values. These assumptions may
or may not be valid and should have been
verified prior to using the data for decision
making purposes. Specifically, the aquifer
depth and hydraulic gradient are in question.
o The report uses total metals rather than
. dissolved metals concentrations throughout the
study, particularly as a basis for risk
assessment calculations. The total metals tests
do not provide actual groundwater concentrations
due to the potential for sediments to be present
in the sample. Standard practice is to filter
samples and test for dissolved metals (NJ DEP
Field Sampling Guidance Manual, March, 1988).
o At least one goal and objective listed in
Section 1.4 has not been met. Zn particular,
the extent of groundwater contamination, both
vertically and areally, has not been
characterized.
o The risk assessment concludes that the potential
hazard at the site is through groundwater
ingestion due to lead concentration. Yet the
feasibility study is directed towards TCA as the
major contaminant of concern. The results of
the risk assessment are not being used to
justify any remedial actions.
A Subsidiary of Environmental Treatment and Technologies Corp.
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Page 2
VOLUME 1 - REMEDIAL INVESTIGATION
SECTION 2.0 GEOLOGY
Section 2.2
Page 2-5
Based on Figure 2-2, the thickness of the
aquifer is assumed to be 100 feet. This
assumption is not based on site specific data
and therefore may be invalid. This depth (100
feet) is used later to calculate hydraulic
conductivity which is key to groundwater
velocity determinations.
Zn order to properly define aquifer thickness, a
deep boring should have been drilled at the site
to determine the exact depth of aquifer. If
this boring had been drilled properly, the
information to calculate hydraulic conductivity
plus data necessary to evaluate the option of
installing new private wells (suitability of
lower aquifer) would be available.
SECTION 3.0 HYDROLOGY
Section 3.1
Page 3-6
Bydrogeological calculations are based on
assumptions which may not be valid, yet affect
the design of remedial alternatives.
Calculations for hydraulic gradient are not
provided in detail. It should be noted that
MW-4 is located in a topographic low. Based on
•aps provided in the report, the hydraulic
gradient between MM-1 and MW-4 could be
approximately 10.5 ft/mile. The hydraulic
gradient from MW-4 to the Esposito well is
approximately 7.7 ft/mile. Also, the hydraulic
conductivity of 343.5 gpd/sq ft is almost half
the lower limit of the permeability presented in
Table 3-1 for the Cohansey Sand. This
discrepancy is not addressed in the report.
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Page 3
SECTION 4.0 SOILS
The general discussion of soils in the area does
not address site specific data concerning soil
type which could affect permeability
assumptions. There was no assumption of TCA
migration time from surface soil to the water
table based on attenuation factors. Section 4.2
describes local soils using general references.
Ho detail account of soils based on borings and
field observation is provided other than a
general statement that local soils are
consistent with regional literature.
SECTION 5.0 SITE CONTAMINANTS
Page 5-2
Comparison of site data in Section 5.2.1 to
background data should be limited to onsite
specific background data. Interstate and
regional data is too broad to be used in the Rl
context.
Page. 5-8
Field and trip blanks in Table 5-2 and 5-3
contained traces of contamination. Therefore/
QA/QC practices are questionable. This places
doubt on the validity of surface soil analysis
data for organic and inorganic constituents.
Page 5-17
Background soil borings were not drilled.
(Figure 5-2). Therefore, there is no basis for
data comparison, in Table 5-5. Using Table 5-5,
lead concentrations are considered below
background.
Page 5-19
Tables 5-6 and 5-7 show contamination of rinse
and field blanks which are indicative of
apparent QA/QC deficiencies. A trip blank was
not analyzed for organic constituents of soil
borings.
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Page 4
Page 5-22
Chromium was present in a field blank.
Therefore QA/QC procedures for groundwater
analysis are questionable.
Although total chromium was present in
residential wells, dissolved chromium was not
detected. Dissolved metals analysis is a better
indication of groundwater conditions.
Page 5-24
Table 5-8 presents results that show lead
analysis to be questionable. The only lead
results available were for total lead which is
non-representative of actual groundwater
conditions. Additionally, since high copper
concentrations were explained as due to copper
piping, it follows that lead contamination stay
be due to solder of the copper pipes.
Page 5-27
Table 5-9 presents QA/QC results that show
deficiencies in sampling and decon procedures.
Chromium, iron, manganese and zinc were present
in the rinse blank which shows that sampling
equipment was contaminated. Some of these
compounds were also present in the trip and
field blanks.
Page 5-35
The methods for predicting contaminant migration
velocity is unclear. The initial method is
based on contour comparisons. Yet, there is no
initial concentration at MW-6 to use.
Therefore, no comparison can be made to previous
concentration in the vicinity of MW-6. If the
300 ppb contour is used, a migration rate of 42
feet per year can be calculated. This wide
range of values makes this methodology
questionable. . - • .
Mention is made of a retardation factor used. .
This factor and calculation are not explained.
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Page 5
Also, the decrease in velocity down gradient of
MW-4 is not taken into account. In general, the
estimated TCA migration velocity is probably
much higher than the actual velocity.
Page 5-35 (cont.)
These problems are acknowledged in a discussion
on page 5-35 and 5-38. Yet, no attempt is made
to validate the data. Instead, the 94 ft/yr
velocity is used as a best guess. This rate is
used later in the report to estimate the extent
of the plume, as a factor in risk assessment and
as a basis for alternative design. An overly
conservative velocity would adversely alter
these determinations.
In general, Figures 5-4 and 5-5 do not
correspond. Figure 5-4 shows migration from
MW-2 towards MW-3. In Figure 5-5, migration
seems to change direction towards HH-6.
Section 6.0 PUBLIC HEALTH EVALUATION
Page 6-19
The report states that dispersion, sorption,
dilution and biodegradation were ignored. This
contributes to the inaccuracy of the predicted
migration rate of TCA.
Although the report states that 1,1-DCE is
present and a potential hazard, it should be
noted that the concentration found was below
the detection limit. The hazard rating is based
on estimated concentration of 20 ppb"which may
or may not be accurate.
Page 6-35
The exposures and risks from periodic ingestion
of local groundwater (current conditions) were
determined to be less than 1 under average
conditions. Using maximum concentrations, the
report states that lead may be a problem. As
previously noted, the feasibility study
concentrates on TCA rather than lead as a .
problem.
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Page 6
VOLUME 2 - FEASIBILITY STUDY
SECTION 3.0 EVALUATION OF REMEDIAL ACTION ALTERNATIVES
Page 3-3
The decision to proceed vith the feasibility
study was apparently based on the concentration
of TCA exceeding the proposed MCL of 26 ppb.
Yet the risk assessment shoved no hazard unless
a veil is installed at the site for drinking
vater purposes. The results of the risk
assessment do not seem to justify remedial
actions at the site.
SECTION 3.1.2.1
Page 3-4
There has been extensive sampling of surficial
soil and deeper soils vhich indicated no
significant contamination at the site.
Additional soil sampling seems unnecessary.
Assumptions used, during the feasibility study
•ay have a significant effect on determining the
\ appropriate remedial action. These assumptions
should be validated prior to selecting the
ultimate technology for the site.
SECTION 3.2 Alternative 1 - No Action vith Monitoring
Page 3-7
The RI/FS has made no attempts to discuss or
predict dilution, dispersion and biodegradation
of TCA. This factor is critical to the
evaluation of the no action alternative.
SECTION 3.3 Alternative 2 - Pump/treat using GAC
Page 3-16
Further information is needed to evaluate GAC
such as definition of vertical and areal extent '
of contamination to determine total volume of
vater to be treated and amount of carbon
necessary. Without these factors, this option'*
may be substantially over estimated.
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Page 7
SECTION 3.4 Alternative 3 - Pump/treat using air stripper
Page 3-33
The possibility exists that EPA will require GAC
to treat the air stripper air effluent stream.
This cost should be included in the evaluation
process. Also, the air stripper is oversized
for 750 gpm. One five foot diameter stripper
•ay be adequate. Capital costs should be
reduced by approximately $150,000.
SECTION 3.8 Alternative 7 - Install new residential veils
Page 3-62
Deed restrictions would be limited to requiring
deep wells for drinking water. This could be
controlled by NJ PEP well permitting
restrictions. Restricting all new construction
at the site is excessive.
Cost of entire electrical usage is excessive.
Only the cost above current costs now paid by
-the resident should-~be included.
Also, as discussed below, only 8 homes would
require new wells, reducing this cost estimated
significantly.
SECTION 3.9 Alternative 8 - GAC treatment at residential
wells"
Page 3-69
Assuming the plume direction is correct, only 8
homes would potentially be affected. Assuming
20 homes inflates the cost for this alternative
tremendously.
Additional Alternatives for Consideration
One alternative not evaluated is the combination
of air stripping and carbon adsorption. This
alternative should be included in the evaluation
since it combines the benefits of alternatives 2
and 3 and may be cost effective.
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Tabernacle Drum Dump Site
Burlington County, New Jersey
Response To Comments
From
Atlantic Disposal Services, Inc.
For
Draft Remedial Investigation and Feasibility Study
On April 21, 1988, Atlantic Disposal Services, Inc.,
submitted written comments, via legal council of Riukin,
Radler, Dunne and Bayh and technical council of O.K.
Materials, concerning deficiencies in the draft Remedial
Investigation and Feasibility Study for the Tabernacle Drum
Dump Site. The comments have been reviewed and evaluated.
Based on this evaluation, the following responses are made:
1. A general comment was made which alleged that there was
a failure to define the site.
Within Volume 1, Figures 1-3 and 1-4 define the area of
waste storage and excavation area, Figure 1-2 defines
the property boundary of the site and Figure 5-6
defines the estimated plume boundary.
2. A -general comment was made that the extent of any
contamination at the site or the threat presented by
the alleged releases was not determined.
Within Volume 1, Section 5 describes the extent of
contamination at the site and Section 6 describes the
threat presented by the alleged releases.
3. A general comment was made that the cost to perform the
RI/FS should not have exceeded $375,000 - $500,000,
however $750,000 was actually spent.
The estimate prepared during the preliminary work plan
stage was modified as site specific information was
obtained during the initial work effort. The
evaluation of this information resulted in a revised
work plan being prepared, submitted for consideration
by USEPA and approved for implementation.
4. A general comment was made that remedial alternatives
could not be selected as a permanent solution because
the extent of any contamination plume underlying the
site remains undefined. -
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The estimated extent of the contaminant plume is based
on field sampling, field measurements, literature
review and mathematical calculations performed by
trained staff hydrogeologists. The results of field
sampling as described in Volume I, Section 5.2.4
indicates the presences of contaminants. The recording
of field measurements in August 1985, October 1986,
December 1986 and December 1987 for groundwater
elevations and an aquifer pump test in October 1987
provided site specific information. To supplement the
field measurements, a literature review, directed
through the M.J. Pinelands Commission, was performed.
As stated in Section 3.3 of the Addendum to Volume 1,
three analytical methods,
a. Boulton's method for unsteady-state flow in
unconfined aquifer with delayed yield.
b. Jacob's modification on Theis' non-equilibrium
well formula, for draw down data.
c. Jacob's modification to Theis' non-equilibrium
well formula, for recovery data,
were used to calculate aquifer transmissivity and
specific yield. Based on these calculations, the
extent of the contamination plume was estimated as
stated in Section 5.4 of Volume 1 (see Figure 5-6).
5. A general comment was made that an alternative
remediation strategy should be considered consisting of
removal of contaminated groundwater for treatment
through a combination of air stripping and granular
activated carbon.
Based on the Technology Screening described in Section
2.0 of Volume II, treatment efficiency for air
stripping or granular activated carbon "separately"
should be sufficient to reduce contamination
concentrations to acceptable levels. The use of either
these two processes would result in the reduction of
contamination levels considerably below acceptable
levels.
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During the public meeting held in March 1988, USEPA
stated its willingness to combine air stripping of
contaminated groundwater with 6AC treatment of air
exhausted from the stripping tower if necessary to
reduce TCA emissions. It is not beneficial or
necessary to combine air stripping of groundwater and
GAC treatment of groundwater since each technology is
in itself capable of removing TCA to levels which
satisfy all ARARs as well as public health concerns.
6. A specific comment on the Remedial Investigation was
made concerning data evaluation deficiencies. Sampling
was performed in accordance with standard procedures
required by EPA.
As stated on Tables 5=6 and 5-9, data not in compliance
with QA/QC standards was invalidated as directed by
USEPA Region II (see notes on the bottom of each
table). The- presence of detectable contaminants in
rinse blanks, field blanks and trip blanks indicate
that QA/QC procedures were followed and gives assurance
to the public that the other reported values are
precise, accurate and that they can be correctly
interpreted. Finally, the information presented in
Table 1-8 is accurately and specifically noted
concerning the analysis for total metals. Dissolved
metals analysis was not performed.
7. A specific comment on the Remedial Investigation was
made concerning the failure to accurately define
aquifer characteristics.
The hydrogeology of the site is described in Chapter 3
of Volume 1. Regional and site information is provided
in this chapter. The installation of a deeper boring
would be advantageous and is planned to be performed
during the design phase of the site remediation
program.
8. A specific comment on the Remedial Investigation was
made concerning the failure to define contamination at
the site.
Contaminant migration is accurately shown on Figures
5-4 and 5-5, with migration to the southeast. - Section
5.2 provides a detailed description of detected
contaminants in the surface soils, subsurface soils and
groundwater.
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9. A specific comment concerning the Remedial
Investigation was directed towards the inappropriate
reliance on chemical migration rates.
As stated in Section 5.3 of Volume 1, contaminant
migration rates were estimated using the horizontal
movement of the 900 ppb concentration contour line for
TCA between July 1985 to December, 1986, the hydraulic
characteristics of the aquifer based on the pump test
(Addendum, Vol 1) and the use of Wilson's Retardation
Value for TCA of 1.2.
10. A specific comment concerning the Remedial
Investigation was directed toward inconsistencies in
the Public Health Evaluation (Section 6 of Volume 1).
The evaluation was a balanced, practical and
conservative discussion concerning the estimated
magnitude and probability of actual or potential harm
to public health, welfare and the environment. As
stated in response f9, the migration rate has been
estimated to be higher than originally estimated in the
work plan, therefore the migration times have been
proportionally reduced. The presence of lead, chromium
and copper were noted, and a discussion has been
presented which interprets these inorganic
contaminants.
11. A specific comment was made about the Feasibility Study
concerning the inappropriateness of the proposed
remedial alternatives.
Sufficient information has been collected at the site
and evaluated so that there is an adequate
understanding of site conditions to propose remedial
alternatives. Assumptions were used, where
appropriate, however, they are explicitly noted in the
report and the implications are described as they
impact the remediation alternative.
12. A specific comment was made about the Feasibility Study
concerning the failure to consider one other additional
alternative.
The combination of alternatives No. 2 and Jfo. 3 is
discussed in Response No. 5, above.
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13. A final conclusion comment vas made that the Draft
Final RI/FS vas deficient in general due to the
previously stated comment.
The Draft Final RI/FS vas prepared in compliance vith
USEPA guidelines. Adequate data vas obtained at the
site and this data vas evaluated to formulate
reasonable, feasible, corrective alternative to protect
the public health, velfare and environment.
14. Additional comments vere made by O.H. Materials
Corporation vhich vere not incorporated into the
primary document prepared by Counsel. Response to
these annexed comments are as follows:
a. General Comments
o Item No. 2
Groundwater velocity is calculated by using the
hydraulic conductivity, the ground water gradient, and
porosity. Groundwater elevations vere measured at the
site in August 1985, October 1986, December 1986 and
December 1987, providing site specific data. The value
for soil porosity vas obtained from grain size fraction
analysis performed on site soils samples. Hydraulic
conductivity vas calculated from the results of a pump
test' performed in October 1987. Thus, valid and
verified data vas employed in the RI/FS.
o Item No. 3
The study presented analyses for both total and dis-
solved metals, as given in tables 5-9 and 5-10. The
risk assessment utilized total metals because such
assessments employ the vorst reasonable case assumptions
for the sake of conservatism.
o Item No. 4 -_
The vertical extent of groundvater contamination vill be
defined during the design phase of the program.
o Item No. 5
The study found that total lead concentrations exceeded
the most stringent ARAR in a single sample out of the
many samples taken. Thus the agency does not believe
that high lead levels characterize site groundvater.
The Record of Decision vill state that if additional
contaminants are found, they vill be treated for.
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b. Volume 1 - Remedial Investigation Comments
Response to Section 3-1, page 3-6.
The values of permeability, or hydraulic conductivity,
presented in Volume 1, Table 3-1 represent available
regional data for the Cohansy Aquifer. Site specific
data was collected by means of a pump test from which
transmissivity was calculated (see Appendix, Figure 3-3).
Hydraulic conductivity was then calculated by dividing
transmissivity by aquifer thickness.
Response to Section 4.0 Soils
In Appendix B, Volume 3, soil and well boring logs
indicate that site-specific data concerning soil type has
been collect and analyzed by size fraction.
Response to Section 5, page 5-2.
The study employed on site data which was developed
during the study, and use regional data as a supplement.
Response to Section 5, page 5-17.
v
The RI/FS concludes that soil concentrations of lead are
indeed below background levels.
Response to Section 5, page 5-19.
As shown in Table 5-7, trip blanks were taken. These are
designated "trips11 in the table heading.
Response to Section 5, page 5-24.
In addition to total lead, the RI/FS also addresses
dissolved lead and other dissolved metals. This is shown
in Table 5-9. The possibility of lead derivation from
pipe solder is an additional reason for excluding lead as
a site contaminant requiring remediation.
Response to Section 5, page 5-35.
The method for predicting contaminant migration velocity
is based on using a concentration as a marker and
following the movement of that marker over time and ,
distance. There is greater confidence in using the''
highest measured TCA concentration as a marker, because
f 6 -
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the highest concentration is expected to have a more
discreet distribution. Use of the 900 part ppb
concentration as a marker also gives a more conservative
result from the health effects perspective.
The retardation factor is explained on page 5-35 of
Volume 1, and in response 9 above. Retardation is
defined as the velocity of groundwater divided by the
velocity of the contaminant, and is a factor which
modifies the rate of contaminant movement. See also:
Wilson, Section 8, Selected References in the RI/FS.
With regard to migration directions, please note that
Figures 5-4 and 5-5 do not actually display migration
directions. However, migration directions which can be
estimated from the two figures are in close agreement.
Figure 5-5, which includes additional data points which
can be used in estimation of migration direction,
confirms the direction as southeasterly.
Response to Section 6 page 6-19.
The suggested dispersion/dilution of TCA as a remedial
action is not considered a reasonable option.
Biodegradation of TCA within a soil strata above the
groundwater table may be reasonable for consideration,
however, within the groundwater system there is no known
information to support rates or levels of removal. In
the risk assessment process the most conservative, rea-
sonable assumptions are taken. Thus physical,
biological, and chemical factors which might act to
change TCA migration rates, but which cannot be
quantified for the Tabernacle Site, are not incorporated
in the risk assessment portion of. the RI/FS.
With respect to 1, 1-DCE, this compound was found at
levels above detection level during 1985 sampling, and
thus its further study is not based solely on estimated
concentrations. DCE was evaluated as a contaminant of
concern because it is a potential carcinogen. In
addition, it is a breakdown product of TCA, and for this
reason its concentration may increase over time, in the
absence of ground- water remediation.
Response to page 6-35.
In characterizing the site only a single occurrence of
lead in groundwater exceeded the most stringent, ARAR.
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Thus the RI/FS concludes that high lead levels do not
characterize site groundwater.
C. Volume 2 - Feasibility Study Comments
Response to Section 3, page 3-3.
Although no well is currently installed on the site for
drinking water purposes, as assumed in the risk analysis,
a number of residential veils are in the path of plume
movement. In addition, the possibility of development of
the site and down-gradient areas above the plume also
exists. SARA and CERCLA legislation require remediation
in such cases.
Response to page 3-4.
With respect to possible additional soil samples, any
such sampling will be conducted to confirm trace levels
previously detected, rather than to investigate for new
areas of potential contamination.
Response to page 3-16.
In the Design Phase, further definition of the vertical
and aerial extent of contamination will be developed.
This will allow refinement of the estimated volume to be
treated. The amount of GAC required will be determined
through pilot testing if this alternative is selected.
Response to page 3-33.
The assertion that the air stripper is oversized is not
substantiated by our calculations. The air stripper was
sized using the following values for model parameters:
Henry's Law Constant - 300 atm
Air Temperature » 10° C
Water/Air Ratio - 30 Vol/Vol
Blower Efficiency - 70%
Pump Efficiency « 60%
The air stripper proposed in the Feasibility Study has
been conceptually designed with a margin of safety to
account for the critical effects of pH, ionic strength
and surfactants on the Henry's Constant, and the effects
of low air temperatures in winter upon removal
efficiency.
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Response to page 3-62.
Deed restrictions were proposed to prevent the
construction of new hones with private wells. The
restriction was not proposed for all new construction.
The cost for electrical usage by a deep submersible pump
is not excessive for normal residential consumption of
water. It is estimated to cost each home owner about
$0.30 per day.
Up to twenty homes may be effected if localized
conditions vary as the plume travels in the estimated
flow direction. In addition, lateral dispersion can
cause contaminant movement in directions perpendicular to
the plume axis.
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