United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/122
September 1990
&EPA Superfund
Record of Decision:
Sayreville Landfill, NJ
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50272-101
1 REPORT DOCUMENTATION t. REPORT na 2.
PAGE EPA/ROD/R02- 90/122
1 4. TMomdSUbM*
SUPERFUND RECORD OF DECISION
Sayreville Landfill, NJ
| First Remedial Action
1 7. AutM*.)
12. SponooringOrgonlzMlan Norn and Addr*M
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Rcdptanrs AccoMton No.
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09/28/90
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1. P*rtomOnq Orgtnlmlon Ropt Mo.
10. ProtMVTMk/Work IMt No.
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1*. Type of Report • Ported Covmd
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15. SuppMmnUry NolM
1C. Abclnct (Unite 200 word*)
The 35-acre Sayreville Landfill site is an inactive municipal and industrial landfill
in the Borough of Sayreville, Middlesex County, New Jersey. The site overlies several
sedimentary aquifers, includes a tidal wetlands area, and lies within the 500-year
floodplain of the South River, which forms the western boundary of the site.
Surrounding land use is industrial. Beginning in 1971, the landfill was used to
fcdispose of municipal and hazardous wastes, including an estimated 50 to 150 drums
Kontaining hazardous wastes. The drums were buried in a 20-acre area of the site. In
1977, landfill operations ceased, but subsequent unauthorized dumping of hazardous
waste may have occurred. In 1980, a landfill closure plan was implemented by the
borough, but was not properly completed. In 1981, the State excavated 30 drums
containing benzene, pesticide-, and acid-contaminated liquids. Investigations from
1986 to 1990, revealed ground and surface water contamination as a result of migration
of onsite landfill contaminants, and the data were used to further characterize
contaminant sources within the landfill. This Record of Decision (ROD) addresses
remediation of onsite drummed wastes. A subsequent ROD will address further source
remediation (leachate) and remediation of ground and surface waters. The primary
(See Attached Page) .
NJ
17. Document AnoJyste •. Descriptor*
Record of Decision - Sayreville Landfill,
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (pesticides,
phenols), metals (arsenic, chromium, lead)
b. MtnMon/Opin-EmM Torino
18. Avrilibflty Stitommt
1». Secwtty CIMO (Thto Report)
None
20. Security Ctaoo (Thto Pjigo)
None
21. No. o!P«OM
263
22. Prico
I ANSt-ZU.18)
See Initructlont on /town*
(Fomwfty NT1S4S)
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EPA/ROD/R02-90/122
Sayreville Landfill, NJ
First Remedial Action
stract (Continued)
contaminants of concern affecting the soil and debris are VOCs including benzene,
toluene, and xylenes; other organics including pesticides and phenols; acids; and
metals including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating the remaining 50 to 150
drums buried onsite, and thermally treating the drummed waste offsite; disposing of
the residual ash offsite; installing a multi-media cap over the landfill; constructing
passive gas collection and surface runoff control systems at the landfill; monitoring
ground and surface waters, stream sediment, and air to determine the need for
subsequent remedial activities and/or a leachate collection and treatment system; and
implementing institutional controls including deed restrictions, and site access
restrictions such as fencing. The estimated present worth cost for this remedial
action is $16,516,600, which includes a present worth O&M cost of $746,400 for year
one, $431,800 for years 2-5, and $354,600 for years 6-30.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup levels will be based on the State
Interim Soil Action Levels (ISALs) including arsenic 20 mg/kg (ISAL), chromium
100 mg/kg (ISAL), and lead 250-1,000 mg/kg (ISAL).
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ROD FACT SHEET
Name: Sayrevill-e Landfill Superfund Site
Location: Borough of Sayreville, Middlesex County, NJ
EPA Jurisdiction: EPA Region II
HRS Score (Date):
NPL Rank: 571
ROD (Operable Unit One)
EPA Signature: September 28, 1990
Remedy: Capping of the landfill
Capital Cost: 5,178,000
O & M Cost: 377>953
Present Worth: 16,516,600
Lead v
Agency: State Enforcement
Primary Contact: Paul Marsenison (212) 264-4593
State Contact: Michael Burlingame (609) 292-1424
Waste
Type: Organics, inorganics, and pesticides.
Medium: Wastefill soils are contaminated. Further
investigation of groundwater, surface waters, and
sediments will be conducted to determine the
extent of contamination of these mediums.
Origin: Illegal dumping of hazardous waste allegedly took
place .between August 1974 and June 1977.
Estimated Quantity:
i
It is estimated that 50 to 150 drums of
hazardous waste are buried within the landfill.
POOR
ORIGINAL
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DECLARATION STATEMENT
RECORD OF DECISION
SAYREVILLE LANDFILL
SITE NAME AND LOCATION
Sayreville Landfill
Borough of Sayreville, Middlesex County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This Record of Decision presents the selected remedial action for
the Sayreville Landfill site, chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan of 1990. This decision document
serves to explain the factual and legal basis for selecting the
remedy for this site.
The State of New Jersey concurs with the selected remedy.
Information which supports the remedy can be found within the
administrative record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record Of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this document addresses current
and future threats to public health and the environment posed by
the Sayreville Landfill. It includes the removal of buried drums
and closure of the landfill in accordance with State of New
Jersey Solid Waste Landfill Closure Regulations. A subsequent
decision document will address the remediation of ground water,
surface waters and stream sediments, as well as the need for a
landfill leachate collection and treatment system.
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-2-
The major components of the selected remedy include the
following:
- restrictions to site access by means of fencing and the
establishment of appropriate deed restrictions;
- excavation and removal of buried drums for off-site
treatment and disposal;
- placement of a landfill cap with an impermeable liner
to reduce leachate generation;
- installation of a landfill gas management system;
- installation of additional ground water monitoring wells;
and
- implementation of an environmental monitoring program to
ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable for this
site. The statutory preference for permanent treatment as a
principal element of the remedy will not be completely satisfied
by the selected remedy. Treatment of the entire contents of the
wastefill was not found to be practicable. However, the remedy
does include treatment of the drums of hazardous wastes excavated
from the landfill at a RCRA-approved treatment and disposal
facility. Removal of these drums would also serve to eliminate
the principal threat posed by the site.
Because this remedy will result in low levels of hazardous
substances remaining on the site above health-based levels, a
review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
S idamon-Eristoff,
Regional Administrator
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DECISION SUMMARY FOR THE RECORD OF DECISION
8AYREVILLE LANDFILL
SITE LOCATION AND DESCRIPTION
The Sayreville Landfill site is located in a moderately
industrial section of the Borough of Sayreville in Middlesex
County, New Jersey, approximately 1 mile south of Route 535 and
1.5 miles north of the Bordentown-Amboy Turnpike (see Figure 1).
Several small industries surround the site to the north, east,
and south. The South River, which flows north, is a major
tributary to the Raritan River and forms the western border of
the site. The river waters adjacent to the site are designated
for both primary and secondary contact recreation. Pond Creek
forms a portion of the site boundary to the north and northwest,
and Duck Creek on the south and southwestern edges. These waters
are classified as fresh water Non-Trout. The site is partially
located within the tidal wetlands of the river with drainage
swales along the western section of the property.
The landfill property encompasses approximately 35 acres of land,
of which, approximately 20 acres was used for wastefill (i.e.,
contains buried wastes). See Figure 2 for approximate landfill
property and wastefill boundaries. The wastefill area rises
above the natural grade by approximately 8-10 feet and is
covered with low-lying vegetation and marsh grasses and bordered
by small surface streams. The eastern section of the site, near
Jernees Mill Road, contains clusters of hardwood trees.
The nearest residential developments are located 1/2 mile to the
north and 1/4 mile to the west (across the South River) .
Currently, access to the site is unrestricted.
The landfill is underlain by three major stratigraphic units.
The Woodbridge/South Amboy semi-confining sequence separates the
deep Farrington Sand aquifer from the shallow Cape May and
alluvial deposit aquifers. Both the shallow and deep aquifers
are designated by the State as suitable for use as drinking water
sources.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
From 1971 to August 1977, the Sayreville Landfill was operated by
the Borough of Sayreville as a licensed municipal landfill which
accepted primarily municipal solid wastes and some light
industrial wastes. Reports from previous investigations indicate
that hazardous wastes were disposed of at the site between August
1974 and 1977 when landfill operations ceased. ' In addition, it .
is alleged that additional quantities of hazardous wastes were
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dumped at the site after 1977.
In 1980, a landfill closure plan approved by the New Jersey
Department of Environmental Protection (NJDEP) was implemented at
the site by the borough. The cover requirements consisted of the
following: one foot of clay on the landfill side slopes covered
by one foot of soil capable of supporting vegetation, a surface
of a minimum of two feet of soil capable of supporting vegetation
and graded and compacted to reduce the infiltration of rainwater,
and seeding and maintenance of the cover to prevent erosion. In
addition, the plan called for the installation of methane gas
vents at 200 square foot intervals. Subsequent site inspections,
however, revealed that the closure had not been properly
completed. The existing vegetative growth over the landfill has
eroded in many areas and fails to significantly impede the
release of fugitive dust or landfill gas emissions. In 1981,
NJDEP issued an order to the Borough of Sayreville to cease
violations regarding maintenance of the landfill. The order
identified deficiencies which included inadequate cover and
failure to maintain grade and cover thickness.
In April 1981, the New Jersey Division of Criminal Justice
performed a magnetometer survey on a portion of the landfill
alleged to contain buried hazardous waste materials. Based on
survey results, an estimated 30 drums were excavated from the
western peninsula of the wastefill area (near Test Pit No. 14
(TP-14)) and sampled (see Figure 3 with drum locations).
Analytical results detected various hazardous compounds,
including pentachlorophenol, para-ethyl toluene, chloroform,
methyl bromide, carbon tetrachloride, methanol, pentane,
dichlorophenol and benzene as well as pesticides and acids.
Later, in August 1982, the Environmental Protection Agency (EPA)
visited the site to gather information for ranking it on the
Federal Superfund National Priorities List (NPL). Based on data
collected from this and previous investigations, the Sayreville
Landfill site was proposed for the NPL on December 1, 1982 and
placed final on the NPL on September 1, 1983.
In February 1986, the State engaged B&V Waste Science and
Technology, Inc. (BVWST) to begin a remedial investigation and
feasibility study (RI/FS) at the site. The Phase I field work
was conducted between November 1986 and March 1987 and included
the following activities:
installation of 21 ground water monitoring wells
and piezometers;
collection of ground water samples from 20 on-site
monitoring wells;
. - collection of surface water and stream sediment
samples from 11 locations surrounding the site;
excavation of five test pits and collection of
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soil samples; and
air monitoring at 52 locations.
Phase II of the RI began in October 1989 and was intended to
supplement and verify the findings and analytical results from
Phase I of the investigation. Included in this phase of
investigation were the following: _ '
- collection of ground water samples from 21 on-site wells;
collection of three surface water and six sediment
samples; and
- excavation of 11 test pits and collection of 12 drum
samples.
Based on the results of the RI, BVWST completed a FS report which
identified and evaluated a number of remedial alternatives.
In June of 1986, 17 potentially responsible parties (PRPs) were
notified by NJDEP of their cleanup liabilities and directed to
contribute toward the costs associated with the RI/FS. In
response to this directive, NJDEP and nine of the PRPs entered
into an Administrative Consent Order (ACO) for the RI/FS costs.
Subsequent directives to PRPs secured costs associated with
additional RI work.
In August of 1990, EPA informed the nine cooperative PRPs of
their liabilities and provided them the proposed plan of action
for the site. The remaining PRPs were informed of the status of
site-activities and the intended plan of action at the site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS reports were completed in July 1990 and the Proposed
Plan for this remediation was released to the public for comment
on July 27, 1990. These two documents were made available to the
public in both the administrative records for the site and
information repositories maintained at the main office of the
NJDEP in Trenton, the Sayreville Borough Hall and Public Free
Library, and the Middlesex County Health Department.
The notice of availability for these two documents was published
in a state-wide news release from the NJDEP on July 30, 1990. A
public comment period on the documents was held from July 27
1990 to August 25, 1990. In addition, a public meeting was .:ald
on August 16, 1990. At this meeting, representatives from NJDEP
and their consultant presented the results of the RI/FS and the
major components of the preferred alternative. Also, the NJDEP
answered questions and concerns raised by the public about the
site and the remedial alternatives under consideration.
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Responses to significant continents, criticisms and any new data
received during this period is included in the Responsiveness
Summary, which is part of this Record of Decision.
In addition, a Community Relations Plan for the site is available
for review at the public repository locations. This plan
includes a description of the site background, history of
community involvement at the site, community relations
strategies, a schedule for community relations activities, and a
list of affected and interested groups and individuals.
This decision document presents the selected remedial alternative
for the Sayreville Landfill site in the Borough of Sayreville,
New Jersey, chosen according to the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and in a manner not inconsistent with the National
Oil and Hazardous Substances Contingency Plan (NCP). The
decision for this site is based on the Administrative Record.
SCOPE AND ROLE OF RESPONSE ACTION
This decision document addresses the principal threat posed by
the landfill site, the drums of hazardous waste materials buried
within the wastefill area. Following the removal of these drums
for treatment, the remaining wastefill materials will be
contained. Based on the RI/FS, three major pathways of
contaminant migration were identified and will be addressed by
the selected remedy, as follows:
- migration of contaminated soils from the landfill to
surface waters and stream sediments;
- migration of wastefill leachate into ground waters,
surface waters and sediments; and
- migration of contaminants from buried drums to
surrounding soils, ground water and surface waters.
Additional sampling and monitoring of air, ground water, surface
waters, and stream sediments will also be required to better
characterize their conditions. The frequency of sampling and
sampling parameters will be determined by NJDEP and EPA during
the remedial design phase. In addition to sampling and
monitoring, other appropriate studies may be required to
determine if additional remediation is necessary. A subsequent
decision document will address the required remediation of these
media as well as the need for a leachate collection and treatment
system.
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SUMMARY OF SITE CHARACTERISTICS
Results of Phases I and II of the RI included characterization of
the geology and hydrogeology within the vicinity of the site.
Based on soil borings and samples collected during the
installation of ground water monitoring wells, four major units
were identified. These include, from the most shallow to the
deepest, the following: waste materials combined with leachate;
the Alluvial/Cape May deposits forming a semi-confined to
unconfined aquifer; the Woodbridge/South Amboy Clay sequence with
water-bearing sandy units; and the semi-confined Farrington Sand
aquifer. See Figure 4 for a generalized representation of the
regional stratigraphy. In addition, it was found that a
relatively thin layer of peat separates the waste materials from
the Alluvial/Cape May deposits. Based on aerial photograph
analyses, it appears that the waste materials were directly
deposited over the wetlands which originally covered the site.
The RI also concluded that the shallow Alluvial/Cape May aquifer
appears to be in partial hydraulic communication with the South
River along the western site boundary and flows from east to west
toward the river. Regional hydrogeologic studies indicate that
the deep Farrington aquifer flows toward the south.
The remainder of the RI results are presented below by the
various media sampled.
TEST PIT INVESTIGATION
Magnetic and electromagnetic geophysical studies were conducted
to locate areas containing concentrations of metals, including,
in particular, buried drums. During Phase I, five test pits were
excavated at representative locations within the wastefill to
investigate waste types. Materials encountered consisted of
household trash along with small amounts of industrial waste,
such as plywood, sheet metal, automobile parts and a canvas fire
hose.
During Phase II, eleven additional test pits were excavated to
establish the type, number and volume of buried drums at the
site. These locations were based on Phase I geophysical survey
results and testimony submitted before the New Jersey Grand Jury
regarding drum disposal operations at the landfill (see Figure 3
for test pit locations 5 - 16) . A total of 28 drums were
encountered, the majority of which were found in TP-8, TP-9,
TP-14 and TP-16. The drums were severely deteriorated, leaking
and perforated and contained a variety of wastes including oil,
tar, solid resins and liquids. Twelve drums were sampled and
analyzed for the Target Compound List, plus a 30-peak scan, EP-
toxicity, Resource Conservation and Recovery Act (RCRA)
characteristics and incineration properties. See Table 1 for the
results of the analyses.
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Based on the total area of test pit excavation and the size of
the geophysical anomaly, it was estimated that between 50 and 150
55-gallon drums are buried within the wastefill. These drums are
located in the vicinity of TP-14, TP-16 and an area of
approximately 100 square feet between TP-8 and 9 (see Figure 3
for drum locations).
SOILS INVESTIGATION
A soil investigation was conducted to determine the extent of
potential contamination within the soil matrix, including the
various geologic units underlying the site. Samples were
collected from a total of 24 soil borings and five test pit
excavations and analyzed for the following parameters: priority
pollutants, total petroleum hydrocarbons, extractable total
organic halides, flash point, total organic carbon, metals,
cyanide, phenols, thermal headspace/portable photoionization
detector response, asbestos, and dioxin. See Table 2 for a
summary of chemical compounds detected in representative soil
samples.
Analysis of metals concentrations in soils determined that levels
of cadmium, antimony and zinc exceeded NJDEP Interim Soil Action
Levels (ISALs). Concentrations of total semi-volatile and total
volatile organic compounds also exceeded SALs in several of the
wastefill soil samples.
SURFACE WATER AND STREAM SEDIMENTS INVESTIGATION
Sampling of the surface waters and stream sediments was conducted
during the RI to determine whether contaminants had migrated from
the wastefill area. Fourteen surface water (SW) and seventeen
sediment (SE) samples were collected from Pond and Duck Creeks
and the South River (see Figure 3 for sampling locations). On-
site and off-site sediment samples were collected from directly
beneath the surface water sampling locations. Analyses of the
surface water samples detected compounds shown on Table 3.
Samples collected from Duck and Pond Creeks adjacent to and ,
downstream from the landfill detected levels of chlorides and
total dissolved solids (TDS) exceeding NJ Surface Water Quality
Standards (NJWQS) for fresh water streams. It is believed that
the south River, which is naturally high in chlorides and serves
as a tidal influence on Duck and Pond Creeks, may contribute to
the elevated chloride levels.
Samples from Duck and Pond Creeks at all locations detected
levels of lead, cadmium and ammonia exceeding fresh water NJWQS.
Concentrations of other chemicals detected within surface waters
were within the NJWQS.
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Analyses of the stream sediment samples indicated the presence of
compounds shown on Table 4.
Concentrations of the following inorganics were detected in
stream sediments at levels exceeding NJDEP TSALs: arsenic, lead,
cadmium, chromium, silver, copper and zinc (in Pond Creek) and
arsenic, 4-4'-ODD, chromium and silver (in Duck Creek). Levels
of arsenic, mercury, selenium and zinc were also detected in
samples collected from the South River exceeding ISALs.
Concentrations of total base neutral compounds were above SALs in
several samples collected from Pond Creek.
AIR INVESTIGATION
During Phase I of the RI, an air quality investigation was
conducted to characterize the baseline air quality conditions at
the site. In addition, the investigation characterized the
impacts of remedial investigation activities and evaluated
potential air-quality concerns related to remedial actions at the
site.
Monitoring was conducted at a total of 52 locations using both a
Foxboro Organic Vapor Analyzer (OVA) and HNu photoionization
detector (to discriminate between methane and non-methane
contaminants).
In general, the data gathered indicated that air emissions at the
site do not represent an imminent threat to human health and the
environment. Air emissions identified consisted almost
exclusively of methane. Some measurements obtained during
sampling indicated the presence of localized, moderate
concentrations of volatile organics in site soils. While
disturbance of such soils during remediation could potentially
release volatile materials into the atmosphere, it was determined
that the magnitude of such potential releases would not appear to
present a significant threat to human health and the environment
provided the appropriate controls are employed.
LEACHATE AND GROUND WATERS INVESTIGATION
During the investigation, ground water monitoring wells were
installed within the wastefill and adjacent locations upgradieht
and downgradient from the site. The wells were drilled and
screened within the shallow Alluvial/Cape May aquifer, the South
Amboy/Woodbridge Clay unit, the sand lenses of the lower
Woodbridge Clay and the Farrington Sand aquifer. See Figur
for monitoring well locations. Leachate samples were colle i
for laboratory analysis from wastefill monitoring wells MW-', 1W-
8, MW-9, MW-10, and MW-ll and the various test pits. The results
of the analyses are shown on Table 5.
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Among the organic contaminants detected, benzene, chlorobenzene,
total xylenes and vinyl chloride levels exceeded the New Jersey
State Drinking Water Act (NJSDWA) Maximum Contaminant Levels
(MCLs). Inorganics exceeding MCLs included cadmium, chromium,
and lead.
Water samples were collected from wells MW-1S, MW-2S, MW-3, MW-
4S, MW-5S, MW-6S, MW-12, MW-13, MW-P2, MW-P4 and MW-P6, installed
within the shallow Alluvial/Cape May aquifer upgradient,
dowhgradient and adjacent to the wastefill.
Analyses of these samples detected the compounds shown on
Table 6.
Concentrations of benzene, chromium, and nickel exceeded NJSDWA
MCLs in the upgradient wells. In addition to these same
contaminants, cadmium exceeded NJSDWA MCLs in downgradient and
on-site monitoring wells (MW-4S, MW-5, MW-6S, and MW-12).
Analyses of ground water samples collected from monitoring wells
located within the Woodbridge Clay Unit (Well MW-6M) detected
compounds such as ethylbenzene (1.8 parts per billion (ppb)),
naphthalene (10 ppb), cadmium (4 ppb), chromium (301 ppb), lead
(8.2 ppb) and nickel (325 ppb). The concentrations of chromium
and nickel exceeded NJSDWA MCLs within MW-6M.
Additional ground water monitoring wells will be required to
fully evaluate the potential impact of the landfill on the deep
Farrington Sand aquifer. Analyses of samples taken from an
upgradient monitoring well screened within the aquifer detected
compounds such as benzene (1.4 ppb), cadmium (10 ppb), chromium
(173 ppb), and nickel (227 ppb), all of which exceeded of the
NJSDWA MCLs. Samples taken from MW-4D screened within the lower
Woodbridge unit, downgradient from the site, detected no
compounds exceeding NJSDWA MCLs.
SUMMARY OF SITE RISKS
The NJDEP conducted an Endangerment Assessment (EA) of the "No
Action" Alternative to evaluate the potential risks to human -.
health and the environment associated with the Sayreville
Landfill in its current state. The EA focused on the
contaminants which are likely to pose the most significant risks
to human health and the environment (indicator chemicals). These
"indicator chemicals" and their concentrations in site media are
shown on Table 7.
The NJDEP's EA identified several potential exposure pathways by
which the public may be exposed to contaminant releases from the
Sayreville Landfill. These pathways and the populations
potentially affected are shown in Table 8. Populations assumed
>* -
8
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to be at risk under current conditions include on-site sever line
workers, trespassers and off-site residents. Under a worst-case
future land use scenario, the population assumed to be at risk
includes on-site residents.
i
Although not guahitified, there exists a risk to ground water
users. Currently, the shallow and deep aquifers are designated
as drinking water sources. It has been shown that contamination
from the landfill has impacted the quality of the shallow
aquifer. The sampling results in the shallow aquifer indicated
that health-based levels (MCLs) were exceeded for benzene,
cadmium, chromium and nickel. In order to reduce the migration
of contamination from the landfill, and thus reduce the potential
future risks to users of the shallow aquifer, capping of the
landfill is required.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer-causing) and non-carcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site-related chemicals would be
additive. Thus, carcinogenic and non-carcinogenic risks
associated with exposures to individual indicator compounds were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and non-carcinogens, respectively.
Non-carcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (reference doses). Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects. RfDs, which are expressed in units
of mg/kg/day, are estimates of daily exposure levels for humans
which are thought to be safe over a lifetime (including sensitive
individuals). Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) are compared with the RfD to derive the hazard
quotient for the contaminant in the particular media. The
reference doses for the chemicals of potential concern at the
Sayreville Landfill site are presented in Table 9. The hazard •
index is obtained by adding the hazard quotients for all
compounds across all media. A hazard index greater than one
indicates that potential exists for non-carcinogenic health
effects to occur as a result of site-related exposures. The HI
provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a sing:
medium or across media.
The hazard indices for non-carcinogenic effects from the site re
listed in Table 10. The hazard indices for all current scena 33
are less than one; however, for future scenarios, the hazard
indices for on-site residents are all above one, suggesting that
non-carcinogenic effects may occur. Adult and child on-site
residents being exposed to soil have His of five and eight,
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respectively. The ground water HI of one should be added to each
of these, resulting in a nine HI for future children living on
the site. In soil, the bulk of this risk is from pesticides. In
ground water, the bulk of the risk is from metals, some of which
could be indicative of background contamination.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by the EPA for the indicator compounds.
Slope factors (SFs) have been developed by EPA's Carcinogenic
Risk Assessment Verification Endeavor for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. SFs, which are expressed in units of
(mg/kg/day)"', are multiplied by the estimated intake of a
potential carcinogen, in mg/kg/day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper-
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of
the risk highly unlikely. The SFs for the chemicals of potential
concern are presented in Table 11.
For known or suspected carcinogens, EPA considers excess upper
bound individual lifetime cancer risks of between 1 X 10"* to 1 X
106 to be acceptable. This level indicates that an individual
has not greater than a one in ten thousand to one in a million
chance of developing cancer as a result of exposure to site
conditions. A summary of the carcinogenic risk estimates is
presented in Table 12. For current on-site workers, the lifetime
excess cancer risk is 9 X 10"6. Current adult and child
trespassers have lifetime excess cancer risks of 1 X 10"4 and
3 X 10s, respectively. Current adult off-site residents have
lifetime excess cancer risk of 2 .X 107, while current off-site
child residents have risks of 5 X 107 and 3 X 10"8 for 1-6 year
olds and 8-16 year olds, respectively.
For future on-site residents, the lifetime excess cancer risk is
2 X 103, primarily from dermal contact with pesticides in soil.
The potential risks to residents due to carcinogens at the site
are greater than the acceptable EPA risk range of 1 X 10"* to
1 X 10'6.
Ecological Assessment
Environmental risks were qualitatively evaluated at the landfill
by comparing contaminant concentrations with published criteria.
It was determined that surface water concentrations of lead and
cadmium in Pond and Duck Creeks pose a potentially significant
risk. In addition, sediments near the confluence of Pond Creek
and the South River contaminated with DDT, cadmium and mercury,
pose potentially significant risks for exposed aquatic organisms.
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No significant signs of stressed vegetation resulting from
chemical toxicity were observed.
Several species of special interest were identified in the South
River due to their abundance and/or recreational importance.
These included four species of anadromous fish, one species of
catadromous fish, five species of euryhaline fish, and two
species of invertebrates. The American Shad, a threatened
species in New Jersey, was recently introduced into the upper
reaches of the Raritan River. It is anticipated that fish
migration will expand south into the vicinity of the site as the
re-introduction program progresses. In addition, it was noted
that the riparian wetlands along the South River may provide
spawning or nursery habitat for the anadromous and invertebrate
species found in the South River.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include the following:
- environmental chemistry sampling and analysis;
- environmental parameter measurement;
- fate and transport modeling;
- exposure parameter estimation; and
- toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. The uncertainty surrounding
contamination in the deep aquifer adds significantly to the
overall uncertainty in the risk assessment. The incomplete
characterization of the deep aquifer leaves a significant gap in
the risk assessment process, as the completeness of an exposure
pathway cannot be adequately determined from available data. The
one "downgradient" well (BPT) is only marginally downgradient of
the landfill, as it is on the southeast side of the site very
close to the edge of the wastefill. Migration patterns cannot be
adequately determined from this single well. The uncertainty of
contaminant migration from other sites towards the Sayreville
Landfill site adds considerable uncertainty to the exposure point
concentrations as calculated for the site. This is most
applicable to the surface waters and stream sediment data, and is
further complicated by tidal influences within the region. It is
difficult to tell whether several sample locations are upgradient
or downgradient. This adds uncertainty in the overall
interpretation of the data and site contaminant migration
patterns.
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Environmental chemistry analysis error can stem from several
sources including the errors inherent in the analytical methods
and characteristics of the matrix being sampled. Uncertainties
in the exposure assessment are related to estimates of how often
an individual would actually come in contact with the chemicals
of concern, the period of time over which such exposure would
occur, and in the models used to estimate the concentrations of
the chemicals of concern at the point of exposure. Uncertainties
in toxicological data occur in extrapolating both from animals to
humans and from high to low doses of exposure, as well as from
the difficulties in assessing the toxicity of a mixture of
chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the EA provides upper-
bound estimates of the risks to populations near the landfill,
and is highly unlikely to underestimate actual risks related to
the site.
For more specific information concerning public health risks,
including quantitative evaluation of the degree of risk
associated with various exposure pathways, please see the
Baseline Risk Assessment Report for the site dated August 1990.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this document, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF ALTERNATIVES
Initially, a number of remedial alternatives were screened and
evaluated for effectiveness, implementability and cost. The
screening was performed to reduce the number of remedial
technologies and process options for detailed evaluation. The
following represent those alternatives for which a more-detailed
evaluation was performed. As required by the federal NCP, a "No
Action" Alternative was also considered.
Since a complete analysis of impacts to ground water, surface
waters, and stream sediments was not accomplished during the
remedial investigation, continued sampling and monitoring of
these media will be required. Therefore, remediation of these
media will not be addressed within this document. Based on the
results of continued sampling and monitoring, a subsequent
decision document will be issued to address these media. This
subsequent document will also address the need for a leachate
collection and treatment system.
The remedial action objectives for the Sayreville Landfill site
include the following: . •
^* -
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- Prevent direct contact with landfill soils and buried
drums and minimize surface water runoff which contributes
to landfill erosion;
- Minimize migration of soil and drum content contaminants
into ground water, surrounding surface waters and stream
sediments; and
- Identify potential releases of contaminants to
ground water, surface waters and sediments.
In the Proposed Plan, construction of an active gas management
system was considered as an option under Alternative 3. In
response to public comment, however, this component was deleted
from this alternative (see the section of this document entitled
Documentation of Significant Change for a more-detailed
discussion on this matter) as well as from Alternatives 4A and B
and 5. Thus, the present worth cost estimates for Alternatives
3, 4A and B and 5 differ from those presented within the Proposed
Plan to include costs associated with a passive gas management
system.
Alternative 1: No Action
Estimated Present Worth Cost: $ 4,966,300
Estimated Implementation Period: 6 months
The NCP and CERCLA require the evaluation of the No Action
Alternative as the basis for comparison with other remedial
alternatives. The No Action Alternative includes: fencing of
the site to restrict access; deed restrictions on the landfill
property and ground water use; and ground water, surface water,
stream sediment and ambient air sampling and monitoring,
including the installation of additional ground water monitoring
wells within the deep Farrington Sand aquifer. The locations of
the monitoring wells, and the frequency of sampling and sampling
parameters of the various media will be determined during the
remedial design phase. Operation and maintenance for thirty
years following closure would also be included. This alternative
does not include any major cleanup activities to address the
remedial action objectives.
Alternative 2; Drum Removal and Soil Cover
Estimated Present Worth Cost: $ 11,704,400
Estimated Implementation Period: 2 years
This alternative includes all of the components of the No Action
Alternative including fencing, deed restrictions, and monitoring
programs including well installation. In addition, an estimated
150 buried drums containing hazardous materials would be
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excavated and removed off site for thermal treatment and
disposal. Thermal treatment of the contents of the drums will be
performed by a RCRA-permitted facility. Final disposal of
residues will be in accordance with the RCRA Land Disposal
Restrictions. Following the removal of drums, the site will be
cleared, grubbed, graded and covered with six inches of fill soil
and six inches of vegetated topsoil.
To minimize erosion of the cover and transport of sediment to
off-site areas (storm water control), a soil erosion and sediment
control plan would be implemented pursuant to the Soil Erosion
and Sediment Control Act of 1975 as amended, and the New Jersey
Administrative Code.
Operation and maintenance of the soil and vegetative covers,
fencing and monitoring wells are also included as part of this
alternative. This will include inspections of the integrity of
the cap, monitoring wells, and storm water control system.
Alternative 3; Drum Removal and Landfill Closure with a NJDEP
Solid Waste Cap
Estimated Present Worth Cost: $ 16,516,600
Estimated Implementation Period: 2 years
This alternative consists of landfill closure for the Sayreville
Landfill in accordance with New Jersey Administrative Code 7:26
"Closure and Post-Closure Care of Sanitary Landfills" and RCRA
Subtitle D requirements. All fencing, deed restrictions,
monitoring programs, drum removal, treatment and disposal
operations, and storm water control measures which are
implemented for this alternative are identical to those described
in Alternatives 1 and 2. The wastefill cap design would be based
on guidelines for a Solid Waste Landfill Cap as described below,
or a similar design of demonstrated equivalent performance (see
Figure 5). The components include: clearing, grubbing and
grading of the landfill, construction of an access road,
placement of a NJDEP Solid Waste Cap, and construction of a
passive gas management system.
The landfill area would first be graded so as to minimize soil
erosion and sediment deposition. The construction of the cap
will begin with the placement of supplemental clean fill material
for site preparation. A 6-inch sand layer would be placed over
the fill to act as a base for the liner. An impermeable liner,
such as a 40-mil geomembrane liner, would be placed above the
layer of sand to prevent percolation of storm water through the
landfill materials. The impermeable liner would be overlain by a
sand drainage layer to allow precipitation that filters through
the upper cap layers to drain from the cap. A geotextile layer
would be placed on top of the drainage layer to prevent mixing of
the coarser sand materials with the finer material of the
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vegetative layer, thereby preventing the alteration of the
drainage layer permeability. The final layer in the cap would
comprise a vegetative layer. This layer would be two feet in
thickness, consisting of 18 inches of clean fill overlain by six
inches of topsoil, and capable of supporting a selected type of
vegetative growth. Measures will be taken to accommodate
settling and subsidence in the design of the cap.
The need for leachate collection and treatment will be based on
wastefill conditions and ground water impacts identified through
monitoring of ground water, surface waters and stream sediments.
Alternative 4; Drum Removal and Landfill Closure With NJDEP
Hazardous Waste Cap
Estimated Present Worth Costs (Option A): $ 19,658,600
(Option B): $ 17,478,200
Estimated Implementation Periods: 2 years
Alternative 4 would incorporate all of the components of
Alternative 3, with the exception of the cap requirements.
Alternative 4 would incorporate the requirements for landfill
closure in compliance with the New Jersey Hazardous Waste
Regulations (NJAC 7:26-10.8). These regulations require that the
landfill cap consist of two impermeable layers. The upper layer
would consist of a geomembrane liner with a minimum thickness of
30-mils and a permeability of less than or equal to the
permeability of the bottom layer. The lower layer would consist
of either a minimum of three feet of clay (Option A) , or a
geosynthetic liner with a minimum thickness of 20-mils (Option
B) . The distance between the upper and lower layers would be a
minimum of six inches and would be filled with a bedding material
(typically sand) that is free of foreign objects which could
damage the liners. The lower layer would be underlain by six
inches of the same bedding material. If the clay/geomembrane
liner option is chosen, a filter fabric would be installed
between the bedding material and the clay to prevent any mixing
and maintain the integrity of the clay layer.
A drainage layer would be installed above the double liner system
with a minimum thickness of 12 inches. This layer would be
designed to provide an effective path for storm water flow
through the vegetative layer above and have a permeability of
greater than or equal to the permeability of the liner. A layer
of filter fabric would separate the drainage and vegetative
layers. The filter fabric would allow infiltration from the
vegetative layer to the drainage layer, but prevent the finer
particles of soil in the vegetative layer from mixing with the
coarser-grained materials of the drainage layer.
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The final layer of the cap system would consist of vegetative
cover. This layer would consist of soil materials with a minimum
thickness of two feet. Typically, this layer consists of 18
inches of clean fill material and six inches of vegetated
topsoil. The cap will be designed to accommodate settling and
subsidence while maintaining its integrity.
Alternative 5; Drum Removal and Landfill Closure with RCRA
Hazardous Waste Cap
Estimated Present Worth Cost: $ 17,449,200
Estimated Implementation Period: 2 years
Alternative 5 would incorporate all of the components of
Alternatives 3 and 4, with the exception of the capping
requirements. Specific performance standards for the cap are
given in 40 CFR 264.310(a). EPA guidance on RCRA landfill design
specifies the following: a vegetative cover, a middle drainage
layer, and a low-permeability bottom layer.
The low-permeability bottom layer would consist of two
components, an upper geomembrane liner and a lower compacted soil
layer (generally a clay material). The geomembrane liner would
have a 20-mil minimum thickness and a final slope of two percent
after settling. The geosynthetic liner would be located below
the average depth of the frost penetration layer. The lower clay
layer would have a minimum thickness of 24 inches.
The middle drainage layer would have a minimum thickness of 12
inches. The final bottom slope of the drainage layer must be at
least two percent. A layer of filter fabric would be placed
above the middle drainage layer to prevent the finer soil
particles of the vegetative layer from mixing with the granular
material of the drainage layer.
The final layer would consist of vegetative cover with a minimum
thickness of two feet. The vegetation selected would be a
species that does not require continued application of
fertilizers or irrigation, and would have a shallow root system.
Alternative 6; Excavation of Drums and Solid Waste. Off-Site
Treatment and Disposal
Estimated Present Worth Cost: $ 95,605,500
Estimated Implementation Period: 2-3 years
Alternative 6 includes all of the components of Alternative 1,
and includes the removal of the wastefill (approximately 280,000
cubic yards and 150 drums of hazardous waste) from the site. The
wastefill materials, including the drums, will be taken to a
RCRA-permitted Subtitle C facility for treatment and disposal.
Waste water accumulated from decontamination procedures would be
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collected and trucked offsite to a treatment facility. When all
wastes are removed from the wastefill, the site would be
backfilled with clean fill and graded to encourage drainage from
the site. The site would then be revegetated with material
native to the area. Affected wetlands would require mitigation
in compliance with the New Jersey and federal wetlands «
regulations.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of nine criteria.
This section discusses and compares the performance of the
remedial alternatives considered against these criteria. The
nine criteria are described below. All selected alternatives
must at least attain the Threshold Criteria. The selected
alternative should provide the best balance among the Primary
Balancing Criteria. The Modifying Criteria were evaluated
following the public comment period.
Threshold Criteria
Overall Protection of Human Health and the Environment addresses
whether or not an alternative provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.
Compliance with Applicable and Relevant and Appropriate
Requirements (ARARs) addresses whether or not an alternative will
meet all of the applicable or relevant and appropriate
requirements of Federal and state environmental statues or
provide a basis for invoking a waiver.
Primary Balancing Criteria
Long-term Effectiveness and Permanence refers to the magnitude of
residual risk and the ability of an alternative to maintain
reliable protection of human health and the environment over time
once remedial objectives have been met.
Reduction of Toxicity, Mobility, or Volume is the anticipated
performance of the disposal or treatment technologies that may be
employed in a remedial alternative.
Short-term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the alternative's
potential to create adverse impacts on human health and the
environment that may result during the construction and
implementation period.
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Implementability is the technical and administrative feasibility
of an alternative including the availability of materials and
services needed to implement the chosen solution.
Cost refers to estimates used to compare costs among various
alternatives including capital, operation and maintenance and the
net present worth costs.
Modifying Criteria
State Acceptance indicates whether, based on its review of the FS
and Proposed Plan, the NJDEP concurs with, opposes, or has no
comment on the preferred alternative.
Community Acceptance addresses the public's concerns and comments
about the Proposed Plan and the RI and FS reports. This criteria
is evaluated in the Responsiveness Summary of this document.
ANALYSIS
Overall Protection of Human Health and the Environment
All of the alternatives provide some degree of protectiveness.
Alternative 6, Excavation of Drums and Solid Waste, Off-Site
Treatment and Disposal, provides the greatest degree of
protectiveness. All wastefill materials would be removed off-
site for treatment and disposal. The site would then be restored
to a baseline condition. The existing vegetative cover, which
may be inhabited by wildlife, would require removal. However,
after the wastefill is removed and the remaining area restored,
wildlife would again repopulate the site.
Alternatives 3, 4 and 5 would be protective of human health and
the environment. These alternatives include all of the measures
described in Alternative 2, in addition to placement of
impermeable liners to reduce leachate generation. Also, a
passive gas management system would be included in these
alternatives. Alternatives 4 and 5 would reduce infiltration to
a greater extent than Alternative 3, because of the double
impermeable liners.
Alternative 2, Drum Removal and Soil Cover, would provide for
some reduction in fugitive dust emissions and off-site migration
of contaminated soils by means of erosion. Excavation of drums
of hazardous waste will remove the major source of ground water
contamination. However, the soil cover does not provide a
barrier to the potential for leachate generation by infiltration
of storm waters, nor is the release of wastefill gasses
addressed. Several exposure pathways, therefore, are not
addressed by this remedy.
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Alternative 1, No Action, provides limited protection by means of
restricting access to the wastefill and, therefore, contact with
contaminated soils. Exposure to contamination in the ground
water, surface waters and stream sediments, and air, however, are
not addressed.
Compliance with ARARs
SARA requires that remedial actions meet legally applicable or
relevant and appropriate requirements (ARARs) of other
environmental laws. These laws may include: the Toxic
Substances Control Act, the Safe Drinking Water Act, the Clean
Air Act, the Clean Water Act, the Resource Conservation and
Recovery Act, and any New Jersey State law which has stricter
requirements than the corresponding federal law.
A "legally-applicable" requirement is one which would legally
apply to the response action if that action were not taken
pursuant to Sections 104, 106 or 122 of CERCLA. A "relevant and
appropriate" requirement is one that, while not "applicable", is
designed to apply to problems sufficiently similar that their
application is appropriate.
Alternative 6 would exceed ARARs for remedial actions.
Restoration of the landfill to a baseline condition would also
exceed ARARs.
Alternatives 3, 4 and 5 will achieve proper landfill closure
under different ARARs. By minimizing construction activities in
areas adjacent to the landfill proper, ARARs for floodplain and
wetland management will be met. Alternative 3 will meet State
and Federal solid waste landfill closure requirements since this
alternative includes the removal of drums containing hazardous
wastes from the site. Alternatives 4 and 5 will meet State and
Federal ARARs, respectively, for hazardous waste landfill caps.
These alternatives will minimize the generation of leachate
through the use of impermeable liners and properly manage
landfill gas emissions. Releases of contaminants and the
affected media, will therefore, be brought into compliance with
ARARs.
The thermal destruction of hazardous wastes in buried drums, as
proposed for Alternatives 3, 4, 5 and 6 will be performed by a
RCRA-approved facility. Final disposal of the residues will be
in accordance with the RCRA Land Disposal Restrictions.
Alternative 2 would not meet the appropriate impermeable liner
requirements for closure of a solid waste landfill in New Jersey.
Other appropriate controls systems are also not included in this
alternative. ARARs for ground water, surface waters, and air
would not be met since there would be no mitigation of leachate
generation or gaseous emissions from the wastefill by means of a
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soil cover. Since this alternative provides neither overall
protection of human health and the environment, nor brings
releases of contaminants from the site into compliance with
ARARs, it fails the most fundamental of the nine screening
criteria and will not be evaluated further below.
Alternative 1 would not comply with ARARs. The existing landfill
closure system does not comply with State Solid Waste Regulations
for landfill closure (NJAC 7:26). The potential for releases of
wastefill gases, fugitive dusts and contaminated leachate will
remain. Proper closure of a landfill requires appropriate
controls for these releases. Since this alternative fails to
provide overall protection of human health and the environment or
meet ARARs, it is unacceptable and will not be evaluated further
herein.
Long-term Effectiveness and Permanence
Alternative 6 is the most effective and permanent remedy, since
the sources of contamination are permanently removed.
Alternatives 3, 4 and 5 incorporate requirements for closure of a
landfill with impermeable liners. This would result in the
significant reduction of fugitive dust emissions, erosion of
contaminated soils into surface water bodies, wastefill gas
emissions, and the generation of leachate. Drums of hazardous
waste buried in "hot spots" in the wastefill would be removed and
their contents treated to reduce their mobility, toxicity and
volume.
Monitoring of ground water, surface waters, stream sediments, and
ambient air in the vicinity of the wastefill would provide
adequate warning if the wastefill gas management or capping
systems were failing and contaminants were being released to the
environment. The potential for damage or destruction of the- cap
and gas vents exists. However, the cap and vents will be
routinely inspected, in accordance with the post-closure plan,
and repaired as required.
Reduction of Toxicity. Mobility or Volume via Treatment
Alternative 6 includes the removal of drums with off-site
treatment and disposal and removal and disposal of solid wastes
from the wastefill. The costs include restoration of the site to
a baseline condition. All wastes will be removed from the
wastefill, thereby, reducing the toxicity, mobility or volume of
contaminants.
Removal and thermal treatment of drums of hazardous wastes as
required for Alternatives 3, 4 and 5 will reduce the toxicity,
mobility and volume associated with the organic contaminants in
the drums. Inorganic compounds remaining after thermal treatment
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will be disposed of properly by the treatment facility.
Installation of a cover or cap under Alternatives 3, 4 and 5 will
reduce the mobility of contaminants by reducing soil erosion,
minimizing leachate generation and controlling gas emissions.
Short-term Effectiveness
Minor impacts will occur during the construction of Alternatives
3, 4 and 5. These impacts, however, will be related to
construction activity occurring only during the landfill closure
construction phase. The short-term risks associated with these
alternatives can be reduced by implementing mitigation measures
including employee protection along with blowers and dispersers,
sealed transport of construction soils used at the site, dust
suppression via soil wetting, vehicle decontamination to prevent
off-site transport of landfill materials onto local roads, and
appropriate air monitoring.
Alternative 6 poses slightly more short-term risks to the
community due to the high volume of truck traffic on the local
roads caused by transporting the wastes off site.
Implementabilitv
Alternatives 3, 4 and 5 would take approximately two years to
implement after completion of remedial design. Impermeable liner
caps are the current state-of-the-art technology for closure of
landfills. Many firms are familiar with the equipment,
specialists and materials required to construct these caps.
Should a clay layer be utilized as part of the cap system, it
would require monitoring during installation to insure that the
clay is compacted to acceptable densities.
The construction techniques required to implement Alternative 6
are all demonstrated and commercially-available techniques.
However, the practice of removing all waste materials from a
landfill to an off-site disposal facility, is rarely done.
Additional problems associated with this alternative include
risks involving the following: fires in the exposed trash;
increased leachate production and migration of contaminated soils
into the adjacent streams; traffic; noise; air pollution; and
fugitive emissions. This alternative will take between two and
three years to implement.
Cost
Table 13 presents the present worth values for capital costs and
annual operation and maintenance (O&M) costs for each
alternative. Total present worth is also provided in the final
column of the table.
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State Acceptance
Based on consideration of the criteria above and comments from
the public, the State of New Jersey concurs with the selection of
Alternative 3, Drum Removal and Landfill Closure with a NJDEP
Solid Waste Cap. Alternative 3 was presented in the Proposed
Plan as the Proposed Alternative.
Community Acceptance
Community acceptance is assessed in the attached Responsiveness
Summary. The Responsiveness Summary provides a thorough review
of the public comments received during the public comment period
on the RI/FS and Proposed Plan, and EPA's and NJDEP's responses
to the comments received.
SELECTED REMEDY
After review and evaluation of the six remedial alternatives in
accordance with Section 121 of CERCLA and Section 300.430 of the
NCP, the EPA and NJDEP presented Alternative 3, Drum Removal and
Landfill Closure with a NJDEP Solid Waste Cap, to the public as
the preferred alternative. The input received during the public
comment period is presented in the Responsiveness Summary, which
is part of this document. The public comments that were received
encompassed a wide range of issues but did not necessitate any
major changes in the general remedial approach proposed for the
site. Accordingly, the preferred alternative was selected for
remediation of the site.
See Table 14 for a cost summary including capital costs for each
component of the selected remedy.
The selected alternative includes the following components:
fencing of the site to restrict access and the
establishment of deed restrictions;
capping of the wastefill with a NJDEP Solid Waste Cap
to prevent infiltration and any potential releases of
hazardous waste to ground water and surface waters;
construction of an access road and storm water and
passive gas management systems;
removal and off-site thermal treatment of buried drums
containing hazardous wastes;
intensive ground water, surface waters, stream
sediments and air sampling and monitoring; and
t
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the installation of additional ground water monitor
wells within the deep Farrington aquifer.
Initially, buried drums containing hazardous wastes which are
located within known "hot spots" of the wastefill will be
excavated and packaged for transportation off site to a RCRA-
permitted thermal treatment and disposal facility. Following the
removal of these "hot-spot" areas, closure in accordance with the
New Jersey Solid Waste Management regulations would be
appropriate. Since the landfill is only 20 feet thick,
excavations of drums from these areas can be accomplished with
standard construction equipment.
To facilitate construction of the landfill cap, clearing and
grubbing of the site would be required. Access road improvements
may be needed to accommodate the construction equipment that
would be traveling to the site. On-site dust control measures
(e.g., the use of water trucks) will minimize the off-site
migration of dust.
The site will be graded to direct surface runoff away from the
landfill without causing soil erosion or sediment deposition.
The slope would be designed and contoured to collect surface
runoff and direct it to a storm water control system.
The NJDEP Solid Waste Landfill Cap is composed of the following:
(1) a vegetative top layer that would minimize erosion and act as
a buffer to the underlying layers, (2) a middle drainage layer
that allows for the drainage and runoff of any infiltrating storm
water so that there would be no accumulation of standing water on
the low-permeability layer, and (3) an impermeable layer (a 40-
mil liner made of geosynthetic material or another of similar
demonstrated performance).
Following the placement of a layer of supplemental clean fill, a
six-inch sand layer would be installed to act as a base for the
geosynthetic liner. The six-inch sand layer would have a
saturated hydraulic conductivity greater than or equal to 1 x
103 centimeters per second (cm/sec) and would be free of any
debris that might damage the liner. An impermeable 40-mil liner
would be placed above the six-inch sand layer. The liner will be
chemically compatible with materials it may come in contact with
and be able to accommodate stresses caused by settling.
Acceptable design criteria for the impermeable liner will be
established by EPA and NJDEP during the remedial design.
The impermeable liner shall be overlain by a sand drainage layer
with saturated hydraulic conductivity sufficient to allow
precipitation that filers through the vegetative layer above it
to drain off the cap, therefore reducing the hydrostatic head on
the liner. A geotextile layer would be placed on top of the
*
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drainage layer to prevent mixing of the coarser sand material
with the finer material of the vegetative layer, thereby
preventing the alteration of the drainage layer permeability.
The final layer in the cap would be the vegetative layer. This
layer shall be two feet thick and consist of 18 inches of clean
fill overlain by six inches of topsoil. This layer shall be able
to support vegetative growth and shall be thick enough to contain
the effective root or irrigation depth of the selected type of
vegetation planted. A top cover maintenance plan will be
developed as part of the final closure plan to ensure that the
vegetative growth is maintained.
Currently, some levels of contaminants at the landfill exceed
appropriate health-based standards. However, with the placement
of the impermeable liner system, current and potential future
leaching of contaminants from the landfill will be minimized. In
addition, capping of the landfill will minimize the migration of
contaminants into adjacent streams by means of minimizing soil
erosion and leachate generation.
To prevent soil erosion and reduce off-site sediment transport, a
soil erosion and sediment control plan would be prepared in
accordance with the Soil Erosion and Sediment Control Act of
1975, in conjunction with the Middlesex County Soil Conservation
District. These plans will identify the measures, such as
drainage channel stabilization necessary to prevent soil loss and
off-site damages, measures to establish proper vegetation, post-
closure maintenance procedures and schedules, and the
identification of those persons responsible for implementing
maintenance procedures.
An intensive air, ground water, surface waters, and stream
sediment sampling and monitoring program will be implemented as
part of this remedy. The required programs will result in data
for establishment of the following: ground water flow patterns,
vertical and horizontal gradients, hydraulic conductivities and
contaminant distribution maps. This would allow for a
comprehensive hydrogeologic evaluation of the nature and extent
of ground water contamination in the vicinity of the site. A
detailed plan for this additional work must be approved by NJDEP
and EPA. A subsequent decision document will address the
appropriate remediation of these media based on results of the
sampling and monitoring program.
Due to the lack of an adequate number of ground water monitoring
wells in the deep Farrington Aquifer to the south of the site,
additional monitoring wells will be installed as part of this
program. Monitoring well locations, frequency of sampling, and
sampling parameters will be determined by NJDEP and EPA during
the remedial design phase. The additional wells will be used to
monitor the effectiveness of the selected remedy and the need for
t
24
-------
supplemental remedial actions.
The need for leachate collection and treatment will also be
addressed in a separate decision document, based on the results
of the additional sampling and monitoring programs.
Because a portion of the site lies within the tidal wetlands of
the South River, a wetlands delineation and assessment is
required to address the effects of contamination on the affected
wetlands, as well as the potential for impacts from the remedial
action. In addition, a floodplain assessment will be conducted
as portions of the site lie within the Federal Emergency
Management Agency's 500-year floodplain (tidal and riverine).
A preliminary evaluation of the site area has indicated the
potential for discovery of cultural resources. In order to
comply with the National Historic Preservation Act, a Stage 1A
cultural resources survey will be required to determine whether
the remedial action will impact cultural resources on or eligible
for inclusion on the National Register of Historic Places. Also,
the site is located within the coastal zone as designated by the
State of New Jersey. Accordingly, a determination of consistency
with applicable policies of New Jersey's Coastal Management
Program should be completed.
Finally, surface water and sediment bioassays should be performed
along with the ground water, surface waters and sediment
monitoring using samples collected along a gradient from Pond
Creek to the South River to determine the bioavailability and
combined toxicity of the numerous inorganic substances present
and indicate whether contamination in Pond Creek and the South
River is sufficient to warrant remediation. Tissue analyses
should also be performed on select fish and macrobenthos (blue
crab, filter feeding bivalves) collected from Pond Creek and the
South River to determine the level of contamination in biota.
The above studies will be performed during the remedial design
phase.
Post-closure maintenance will be provided after landfill closure
under appropriate State of New Jersey arid EPA requirements.
Maintenance needs would be determined by periodic site
inspections. At a minimum, the final cover, side slopes, off-
site areas, monitoring points, and landfill perimeter areas would
require periodic inspection.
Post-closure activities also include maintenance of ground water
monitoring wells, the storm water and gas collection systems, and
the leachate collection and treatment system, if required. Post-
closure care is required for a minimum of 30 years.
25
-------
Potential post-closure reuse options of the site will be
evaluated as part of landfill closure design; however, because
this landfill is a Superfund site, reuse options are expected to
be extremely limited.
STATUTORY DETERMINATIONS
EPA's selection of Alternative 3, Drum Removal and Landfill
Closure with a NJDEP Solid Waste Cap, complies with the
requirements of Section 121 of CERCLA, as amended by SARA. The
selected remedial action offers overall protection of human
health and the environment, complies with Federal and State
requirements that are applicable or relevant and appropriate to
this action, and is cost-effective. This action utilizes
permanent solutions and alternate treatment (or resource
recovery) technologies to the maximum extent practicable.
Because treatment of the entire contents of the wastefill was not
found to be practicable, the action does not satisfy the
statutory preference for permanent treatment as a principal
element of the action. Treatment will be employed, however, on
the drums of hazardous wastes excavated from the landfill.
Further actions to address ground water, surface waters and
stream sediment contamination will be addressed in a subsequent
decision document, pending further sampling and monitoring of
these media. The need for leachate collection and treatment will
also be addressed at that time.
A brief, site-specific description of how the selected remedy
complies with the statutory requirements is presented below:
Overall Protection of Human Health and the Environment
The selected remedy offers overall protection to both human
health and the environment. Removal of the drums containing
hazardous wastes from "hot spots" within the wastefill will
eliminate a major source of contamination from the environment.
Thermal treatment of those wastes will destroy virtually all of
the organic contaminants. The remaining, inorganic contaminants
would be properly disposed of at a RCRA-permitted treatment and
disposal facility. The impermeable cap will serve to reduce the
infiltration of storm water through the wastefill resulting in
reduction of the generation of leachate. Direct-contact risks
associated with contaminated soils will be reduced through the
placement of the cap, and implementation of soil erosion and
sediment controls. Gaseous- emissions from the wastefill will be
controlled by a collection system, and treated appropriately if
deemed necessary. Fencing of the site and the establishment of
deed restrictions will prevent access to and development of the
site which might result in unacceptable risks.
26
-------
Compliance with Applicable and Relevant and Appropriate
Requirements (ARARs)
A complete listing of contaminant-, action-, and location-
specific ARARs which were evaluated for the site are included in
the Feasibility Study. The primary ARARs attained by this remedy
are action-specific ARARs dealing with landfill closure in
accordance with New Jersey Solid Waste Management Regulations
(NJAC 7:26), RCRA Subtitle D requirements and RCRA requirements
dealing with storage, transportation and disposal of the drums of
hazardous waste which will be removed from the wastefill.
It has been determined that landfill closure is the applicable
ARAR for this site. The results of the remedial investigation
and enforcement documentation were used to locate the hot spot
areas of hazardous wastes within the wastefill. Since this
action includes the removal of these hazardous wastes sources,
and because the landfill ceased operations prior to the effective
date of RCRA Subtitle C and was used primarily for the disposal
of municipal wastes, closure in accordance with the New Jersey
Solid Waste Management Regulations is appropriate.
By means of controlling the source of contamination, this remedy
is intended to attain the chemical-specific ARARs for ground
water and surface waters, and the NJDEP chemical-specific
requirements for contaminated soils and stream sediments.
Further sampling and monitoring of air, ground water, surface
waters and stream sediments will be required to determine the
effectiveness of this action.
In order to comply with the location-specific ARARs, additional
studies will be conducted during remedial design. These studies
will include a wetlands delineation and assessment, a floodplains
assessment, a Stage 1A cultural resources survey and a formal
determination of consistency with applicable policies of New
Jersey State's Coastal Management Program.
Cost-Effectiveness
The selected remedy is the least costly of the capping
alternatives that include the removal of buried drums from the
wastefill for treatment and disposal. Alternative 3 provides
overall protection of public health and the environment at an
estimated present worth cost of $ 16,516,600.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable and Preference for
Treatment as a Principal Element
The selected remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum
extent practicable by providing the best balance among the nine
i
27
-------
evaluation criteria. Permanent treatment will be employed on the
drums of hazardous wastes excavated from the wastefill at a RCRA-
permitted treatment and disposal facility. Of the five primary
balancing criteria, short-term effectiveness, implementability
and cost were the most decisive factors in the selection process.
Because this remedy will result in low levels hazardous
substances remaining on the site above health-based levels, a
review will be conducted within five years after commencement of
remedial action, to ensure that the remedy continues to provide
adequate protection of human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Sayreville Landfill site was released
to the public in July 1990. This plan identified the preferred
alternative, Drum Removal and Landfill Closure with a NJDEP Solid
Waste Cap. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, and the data from the remedial investigation, NJDEP and
EPA determined that a passive gas management system should be
sufficient to achieve the appropriate ARARs for air emissions at
the site. If, however, upon review of subsequent air monitoring
results, it is determined that the passive system has failed to
meet the ARARs, another opportunity for public review of
alternatives developed to address the new situation will be
provided. Notwithstanding this change, the selected remedy for
the site remains Alterative 3.
28
-------
ERNSTON
SAYREVILLE
LAUREL
PARK
PARLIN
SAYREVILLE
LANDFILL SITE
MADISON
PARK
NEWTOWN
HEIGHTS
,/? >/4 0
SITE LOCATION
Sayrevill& Landfill
-------
APPROXIMATE
WASTEFILL BOUNDARY
> tOO' SEWER RIOHT Of WAY
•v \ HI
SOUTH flIVEH
REFERENCE: Br.ROUCH OF SAYREVILLE,
Tf.X ASSESSMENT MAP
Rt
-------
. ... .,
'-^ i. .;, -.I..
Sayrevllle Landfill
INVESTIGATION SAMPLING LOCATIONS
-------
RECENT ALLUVIUM
CAPE MAY FORMATION
Z
o
H
<
1
ff
O
u.
SOUTH AMBOY CLAY
SAYREVILLE SAND
WOODBRIDGE CLAY
FARRINGTON SAND
RARiTAN FIRE CLAY
BEDROCK TRIASSIC-JURASS1C
GENERALIZED REPRESENTATION OF
REGIONAL STRATIGRA'PHY
s veaccn
Engineers
Sayreville Landfill
Figure 4
-------
\lx \l/\lx xl/xix
18,, SELECT FILL
12" * :. t : o • t • o-:.o':-.o'-DRflINAGE LAYER lX10~2cm/sec ;J'.:. £'.:. ^'.i. j'.:. ^'.:. ^'.i. |j
) ^V-^--^--^-^.-^.^^^^^- \M1N1 Mwrn J ^•^^••^•'^••^••^••^•^••tf-'tf
MMMHMMMM^^MMMIMMMMMMMBWMMMMm 40~MlL
\\\\\\\\\\:-.-.-.-.-.-.Y.-.-.-.-.-.-/.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.Y.-.-.-.-.-.-j.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-/.-.-.-.-.-.-.-.-.-. GEOMEMBRANi
B" •.•/.•.•.•.•.•...•.•.•/.•..•..•.•.•.•.•.•//.•.-.SAND LAYER 1X10 cm/eee.v.'.Y.Y.Y.Y.Y.Y.Y.Y.Y.Y.Y.Y. LINER
DEPTH
VftRIES
SUPPLEMENTAL CLEAN FILL
(AS NECESSARY FOR REGRADING
AND SITE PREPARATION)
NOTE :
EXISTING WASTEFILL
WASTE LANDFILL CAP IN ACCORDANCE
MJAC 7:2S-2A.9.
NOT TO SCALE
ALTERNATIVE 3 - NJDEP SOLID WASTE CAP
\t.»CC AND TTO4NOLDCT COW.
SAYREVILLE LANDFILL
Figure 5
-------
TABLE 1
ANALYTICAL DATA FOR
TEST PIT INVESTIGATION
Concentration Range
(parts per million fppml)
Volatile Compounds
- Acetone 0.82 - 140
- Toluene 0.41 - 450
- Ethylbenzene 0.43 - 220
- Total Xylenes 0.32 - 1,200
- Methylene Chloride 0.6 - 87
Semi-Volatile Compounds/Pesticides
- Phenol 68 - 81,000
- Bis(2-ethylhexy)phthalate 0.29 - 110
- 4-4'-DDD 1.1 J
Inorganic Compounds
- Arsenic 1.3 - 6.6
- Barium 14 - 169
- Cadmium 4.7 - 131
- Chromium 6.5 - 45.9
- Copper 6.6 - 155
- Iron 3,680 - 30,000
- Lead 2.7 - 1,500
- Nickel 4.1 - 152
- Zinc 39.6 - 7,220
J - Quantitation is approximate due to limitations identified in
the quality control review.
-------
TABLE 2
ANALYTICAL DATA FOR SOILS
Volatile Compounds
(parts per billion (tmb) )
- Methylene Chloride
- Acetone
- 2-Butanone
- Toluene
- Chlorobenzene
- Ethylbenzene
- Total Xylenes
Semi-Volatile Compounds fppb)
- Di-n-butylphthalate
- Bis(2-ethylhexyl)phthalate
Pesticides fppb)
- Gamma BHC (Lindane)
- Heptachlor
- Endosulfan sulfate
- 4, 4 '-DDT
- Dieldrin
- Endrin
- Endrin ketone
Inorganic Compounds
(parts per million fopm) )
- Antimony
- Arsenic
- Cadmium
- Chromium
- Copper
- Lead
- Zinc
Concentration Range
BMDL - 80 B
BMDL - 4,900 B
BMDL - 220
BMDL - 360
BMDL - 210
BMDL - 520
BMDL - 2,400
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
4
BMDL
BMDL
* New Jersey Interim Soil Action Levels
numbers used to identify the presence of
B - Analyte present in method
J - Quantitation is approxima
- 2,500
- 4,100
- 1,554
- 3,976 B
- 318 B
- 1,150 J
- 5,386
- 8,241 J
- 550 J
- 23.3
- 19.2
- 5.5
- 24.3
- 31.5
- 65.7
- 404.4
NJ ISALs*
1,000
1,000 - 10,000
»
10
20
3
100
170
250 - 1,000
350
(ISALs) are reference
contamination .
blank.
te due to limitations
identified in
the quality control review.
-------
TABLE 3
ANALYTICAL DATA FOR SURFACE WATERS
Concentration Range
(parts per billion fppbl
Volatile Compounds
- Toluene (PC)
- Benzene (PC)
Semi-Volatile Compounds
Upstream Edge of Landfill*
BMDL
BMDL
Downstream
BMDL - 8 B
BMDL - 3 J
- Bis(2-ethylhexyl)phthalate (DC) 100
- Di-n-butylphthalate (PC) BMDL - 68J
Inorganic Compounds
BMDL
BMDL - 49 JB
- Cadmium
.
- Lead
- Chromium
(PC)
(DC)
(PC)
(DC)
(SR)
(PC)
(SR)
86 E
14 E
12.5 J -
114
BMDL
26
14
BMDL - 25
11 E - 14 E
231 25 - 250
199
BMDL - 87.9
12 - 40
12-15
Other Parameters
- Ammonia
(PC)
(DC)
(SR)
- Total Dissolved Solids (PC)
(DC)
(SR)
1,200
<100
1,200
348,000
126,000
377,000
800 - 1,200
150 - 1,200
500
364,000 - 729,000
332,000 - 396,000
427,000 - 1,029,000
* Note: Upstream sampling locations include SW-1, SW-6, SW-9,
SW-14, and SW-16.
KEY: PC - Pond Creek, DC - Duck Creek, SR - South River
BMDL - Below minimum detection limits.
B - Analyte present in method blank.
J - Quantitation is approximate due to limitations identified
in the quality control review.
JB - Result estimated due to blank contamination.
E - Estimated due to interference.
-------
TABLE 4
ANALYTICAL DATA FOR STREAM SEDIMENTS
Concentration Range
(parts per billion)
Upstream Edge of Landfill*
Volatile Compounds
- Carbon Disulfide (SR)
(PC)
- Carbon Tetrachloride (PC)
(SR)
Semi-Volatile Compounds/Pesticides
- Di-n-butylphthalate (PC)
(DC)
(SR)
- Fluoranthene (PC)
- Pyrene (PC)
- Polychorinated Biphenols (PC)
- 4,4'-DDD (DC)
Inorganic Compounds
- Arsenic (PC)
(DC)
(SR)
- Chromium (PC)
(DC)
(SR)
- Cadmium (SR)
- Silver (PC)
(DC)
- Lead (PC)
(DC)
(SR)
- Copper (PC)
(DC)
(SR)
- Mercury (SR)
- Zinc (PC)
(DC)
(SR)
BMDL
BMDL
BMDL
BMDL
BMDL - 6,800
BMDL
BMDL
1,000 - 3,600
860 - 2,300
BMDL - 5,200
BMDL
3.4-7.4
4.4
15.6 N
14.2-347 JB
15.9
14
BMDL
BMDL-12.9
BMDL
24.4 J-762 J
.5 N
54.3 N
13.4-268 J
BMDL
18
BMDL
13-570 JB
7.6
115.1 N
Downstream
BMDL - 14
BMDL - 220
BMDL - 660
BMDL - 95
BMDL - 11,000
1,300 - 1,400
6,100 - 7,300
BMDL - 5,200
BMDL - 6,600
BMDL - 3,173.5
15.85 J
BMDL-92.7 N
12-29
10.8 N
15.4 JB-141 JB
15.6-47.6
12-15
BMDL-19.6
BMDL-16.2
BMDL-8
21.8 J-444.3N
192.7-337.8
63.7 N-119.6
11.7-308
22.4-94.7
BMDL-238.2
0.7-2.4
27.49 N-772 JB
41.5-159.6
86.8 N-1,000 N
KEY: Pond Creek - PC, Duck Creek - DC, South River - SR
* Note: Upstream sampling locations include SE-1, SE-6, SW-9,
SE-9, SE-12, SE-14 and SE-16.
-------
BMDL - Below minimum detection limits.
B - Analyte present in method blank.
J - Quantitation is approximate due to limitations identified
in the quality control review.
JB - Result estimated due to blank contamination.
See Table 2 for the ISALs for the inorganics: arsenic, cadmium,
chromium, copper, lead and zinc. ISALs for the remainder of
compounds detected above ISALs in stream sediments include: 4,4'
-ODD - determined on a case-by-case basis; mercury - 1 ppm;
selenium - 4 ppm, and silver - 5 ppm.
-------
TABLE 5
ANALYTICAL DATA FOR
WASTEFILL
,
Volatile Compounds
- Benzene
- Chlorobenzene
- Ethylbenzene
- Total Xylenes
- Vinyl Chloride
Semi-Volatile Compounds
- 4-methylphenol
- Naphthalene
Pesticides
- Heptachlor
- 4, 4 '-DDT
Inorganic Compounds
- Beryllium
- Cadmium
- Chromium
- Copper
- Lead
- Manganese
-. Zinc •
Other Parameters
- .Chloride
- Ammonia
- Sulfate
MONITORING WELLS
Concentration Range
(parts per billion)
BMDL - 110
BMDL - 50
BMDL - 94
BMDL - 1,100
BMDL - 3.9 J
BMDL - 220
• BMDL - 44
BMDL - 1.09
BMDL - 0.28
BMDL - 9
BMDL - 24
BMDL - 433 N
BMDL - 217
BMDL - 343
500 - 2,698 E
50 - 2,062
100 - 3,000
10 - 800
92 - 1,500
MCLs*
1
4
44
2
10
50
50
* MCLs represent enforceable reasonable goals for drinking
water quality.
J - Quantitation is approximate due to limitations identified in
the quality control review.
-------
TABLE 6
ANALYTICAL DATA FOR
SHALLOW AQUIFER MONITORING WI
Volatile Compounds
- Benzene
- Carbon disulfide
- Chloroethane
Semi-Volatile Compounds
- 1,4 dichlorobenzene
- Bis(2-ethylhexyl)phthalate
- Benzo(a)pyrene
Inorganics
- Arsenic
- Cadmium
- Cyanide
- Chromium
- Lead
- Nickel
- Zinc
Other Parameters
- Chloride
- Total Dissolved Solids
- Ammonia
Concentration Range
{parts per billion fppb)I
Upgradient* On-S ite/Downgradient
1.3 JB
1
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL
BMDL - 1.8 J
BMDL
BMDL
24 - 197
3.1 B• - 27 N
43 - 187
56 - 311 J
28,000 - 66,000
164,000 - 200,000
BMDL - 1,200
BMDL - 1.9 JB
BMDL - 4 J
BMDL - 7.7 J
BMDL - 3
BMDL - 25
BMDL - 13
BMDL - 20.7
BMDL - 28
BMDL - 17 N
BMDL - 252
BMDL - 12.5 JB
16 J - 301
84 - 424
65,000 - 2,976,000
456,000 - 4,196,000
200 - 10,800
* Note: Upgradient wells include MW-2S, MW-3, MW-P2, and MW-P4.
BMDL - Below minimum detection limits.
J - Quantitation is approximate due to limitations identified
in the quality control review.
JB - Result estimated due to blank contamination.
N •- Spike recovery out of control limits.
See Table 5 for the MCLs for benzene, cadmium, and chromium. The
MCL for the metal nickel is 13.4 ppb.
-------
TABLE 7
Exposure population
Current Off-site Residents
SUMMARY OF EXPOSURE POINT CONCENTRATIONS
OF CHEMICALS OF POTENTIAL CONCERN
Exposure Medium
Sediment
Surface water
Curren; On-site Workers
Current On-site Trespassers
Future On-site Residents
Current On-site Workers
(Continued)
Current On-site Trespassers
(Continued)
Furure On-site Residents
(Continued)
Soil
Current On-site Workers
Furure On-site Residents
Sewer Line (Water)
Groundwater (Shallow
Exposure Point Concentra-
tions (a) (pans per million
[ppml. oars per billionfppbll
Acetone
Carbon Bisulfide
Chloroform
Carbon Tetrachloride
Phenanchrene
Di-n-burylphthalate
Fluoranthene
Pyrerie
Buryl benzyl phthalate
Benzo(a)anthracene
Chryscne
Benzo (b) fluoran thene
Benzo(a)pyrene
Indend ,2,3-cd)pyrene
Benzo(g,h,0 perylene
Mercury
Chloroe thane
Benzene
Bis (2-ethylhexyI) phthalate
Di-n-ocryiphthalate
Aluminum
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Manganese
Zinc
Acetone
Vinyl Acetate
Toluene
2-Butanone
Chloro benzene
Ethyl benzene
Xylene
Phenanthrene
Di-n-burylphthalate
Fluoranthene
Pyrene
Bis(2-ethylhexyl)phthalate
Benzo(a)pyrene
Gamma BHC (Lindane)
Heptachlor
Dieldrin
4-4-DDD
Endrin
Endosulfan Sulfate
4,4'-DDT
Endrin Ketone
Methoxychlor
Carbon Disulfide
Xylene
»
Carbon Disulfide
1.2
0.051
0.0077
0.16
0.07
5.3
1.2
1.5
0.21
0.078
5.1
0.17
0.1
0.062
0.067
0.00099
2.
2.5
240.
18.
720.
6.7
15.
24.
76.
20.
210.
4,900.
130.
ppm
ppb
2.5
0.0091
0.086
0.097
0.044
0.16
0.68
0.46
0.68
3.8
4.
1.3 .
0.39
0.3
0.74
1.
0.1
1.5
0.15
0.22
0.13
0.017
0.018
0.032
0.003
ppm
ppb
ppb
-------
Arsenic 0.018 ppb
Beryllium 0.013
Cadmium 0.0038
Thallium 0.00098
Vanadium 0.019
Future On-site Residents Groundwater (Shallow Chloroethane • 5.3 ppb
Aquifer GW-13-02) Carbon Disulfide 0.012
1,2 Didiloroethene 0.002
Trans-l,3-Dichloropropene 0.003
Chlorobenzene 0.004
Xyiene 0.004
(a) Concentrations are the 95
percent upper confidence
limit on the arithmetic mean
of measured concentrations.
-------
Table 8
Summary of Exposure Pathways
Current Land Use
POTENTIALLY
EXPOSED
EXPOSURE rOLTE
AND POINT
MEDIUM
Residents
(Cf?s;te)
incestion of, direct
comae: with, and
inhalation of
contaminants.
Surface Water
(C"s;:e)
lnc;de.-ta! incestion cf.
anc direct contact win
contaminants.
Sediment
Workers Incidental incesticn cf,
(Onsite) and direct contact witn
soil, and contaminants
in sewer line water.
Sewer Lne
Incicerta! incesticn of
and direct contact witn
ccrtamirants.
Soil
Future Land
Residents Incdenta/ingestion of, Groundwater
(On-sitej direct contact wttft, (Sha/low Aqutfe
and inhalation of
contaminants.
Residents
(On-site)
^«
Residents
(On-site)
Incidental ingestion of,
and direct contac: with
contaminants.
Soil
/ncidentaJ ingestion of, Groundwater
direct contact with, (Shallow Aquffer-
and inhalation of GW-13-02)
contaminants.
-------
Table 9
Reference Doses (RfD) for Chemicals of Potential Concern
Cseotr
Cfir.iO*
IMC
3E-*
Zinc
S-2E-3
T.-ars- • .3-;.
t*> =C J uu
•—. . ;a:a ^
m» We « Cr» WO X Abioiwion Pacsof
^ „._ DERMAL
Cn/orocWD -
Seufe»
ISO
SE-2
16-3
JE-3
17E-2
2S-Z
2E-:
3E-»
re-ste!
7E-3
-------
TABLE 10
SUMMARY OF CHRONIC HAZARD INDEX ESTIMATES
Current Land Use
Population
Exposure Pathway
On-site workers Ingestion of soil
Dermal contact with soil
Ingestion of sewer line water
Dermal contact with sewer line
water
Inhalation of contaminants in
sewer
Total exposure index =
Adult trespassers
On-site Ingestion of soil
Dermal contact with soil
Total exposure index =
Child trespassers
On-site Ingestion of soil
Derroal contact with soil
Total exposure index =
Adult residents
Off-site Ingestion of sediment
Dermal contact with sediment
Total exposure index -
Child residents
Off-site Ingestion of sediment
Dermal contact with sediment
Dermal contact with surface water
while swimming (8 - 16 yr)
Ingestion of surface water while
swimming and wading (1-6 and
8-16 yr)
Dermal contact with surface water
while wading (1-6 yr)
Total exposure index (1-6 yr) =
Total exposure index (8-16 yr) =
Future Land Use
Adult residents
On-site Ingestion of soil
Dermal contact with soil
Total exposure index =
Children residents
On-site
Residents
On-site
Ingestion of soil
Dermal contact with soil
Total exposure index =
Ingestion of ground water
Dermal contact with ground water
Inhalation of contaminants in
the shower . • —
Total exposure index =
Hazard Index
1 X 10"
3 X 102
6 X 107
8 X 10s
1 X
3 X 10
2
8
2
3 X 10"
3 X 101
3 X 101
2 X 103
6 X 10'
6 X 10°
2 X 10s
2 X 10*
2 X 10"
1 X 10"
6 X 10"
7 X 103
7 X 10"
4 X 103
1 X 102
1 X 102
3 X 102
5 X 10°
5 X 10°
X 101
X 10°
8 X 10°
1 X 10°
7 X 103
IX TO0
-------
Table 11
Slope Factors (SF) for Chemicals of Potential Concern
Sloe* Factor (Sr) (a) W»i{ftt-o(-Ews»nci
Ci»~iea' i/fmo/Ko/gavi r^*rtir,m,nn
AJuminum -•• ' ...
Arstnie 5.0E-1 A
Btryiliu.Ti 8.4E.O 82
Cac~iuiri 6.1E»0 Bl
Cvsmiun VI 4. l£»l A
Cacsr — —
Cyar.ice — —
Liac — 82
Ma."sa"ese --- — -
2ir.s
B«-zt-e 2.9E-2 A
2-8v-:a.-.c-» — D
Ca.-rr^ Sis.'iiici —
Caw T«::a:-.is.'iet 1.3E-1 82
C.-.:s.-s:e-^ ME-2 82
'. .2 Icr.isror.-its* — —
=;-yi«:e-iene — 0
Toiuti* — C
Vir« *c§:a:e — —
Xyisr.Bs — 0
^ir^.-yT.,, ^_ 82
?-.»-a-:-.r«n« — 0
Fuc:a.-.:nt.-.« — 0
Py-i.-.t — D
' 6.-i>a:ar:r,.-a:en. — 82
C.-.:»si,-.. — 82
B**.i>/^!'.:uo.'a":Har^ — 82
tciCf*(" .2.j-r;}?vrtn* ... 82
S..-.-.-,.;.V.;S4P,,^, — . ' D
:.-.-x:,-:-.r.a.aia — —
uSt'I-tiny .^trvJjsfttnaiati ••• 82
ia.T.rr.a SHC iL:"Cana). — B2/C -
:«:;a:-:cr *.5E-0 82
.».:•" i.SE-i 82
.* -rcr — 32
•i
4 -=C- — 82
"c^ K*c[" ' ~1
Siaot Faear (SF) (a)
1/Tma/KOfCav) SFfe) SF Seuro
_ ...
— 1.75E*0 WS
4.3E-0 - —
— - - Oral SF/Abso/oilon Factor
-------
TABLE 12
SUMMARY OF CANCER RISK ESTIMATES
Current Land Use
Population Exposure Pathway Risk
On-site worker Ingestion of soil 5 X 10"*
Dermal contact with soil 9 X 10"6
Total exposure risk « 9 X 10*
Adult trespassers
On-site Ingestion of soil 9 X 10"*
Dermal contact 1 X 10"4
Total exposure risk = 1 X 10"4
>
Child trespassers
On-site Ingestion of soil 1 X 10'7
Dermal contact 3 X 10s
Total exposure risk = 3 X 10s
Adult trespassers
Off-site Ingestion of sediment 2 X 10"7
Dermal contact with sediment 8 X 10'9
Total exposure risk = 2 X 10'7
Child residents
Off-site Ingestion of sediment 5 X 107
Dermal contact with sediment 4 X 10"'
Dermal contact with surface
water while swimming 2 X 10"8
(8 - 16 year old)
Ingestion of surface water
while, swimming and wading 7 X 10"'
(1-6 and 8-16 year olds)
Dermal contact with surface
water while wading (1- 6 yr) 8 X 109
Total exposure risk (1- 6 yr) = 5 X 107
Total exposure risk (8- 16 yr) = 3 X 10*
Future Land Use
Adult residents
On-site Ingestion of soil 1 X 10s
Dermal contact with soil 2 X 10"3
Total exposure risk = 2 X 10'3
Child residents
On-site Ingestion of soil 2 X 10s
Dermal contact 4 X 10"4
Total exposure risk = 4 X 10"4
-------
TABLE 13
ESTIMATED COSTS
Alternative Capital Cost ($) Annual O&M Present Worth Total Present
Number ($/year) O&M ($) Worth ($)
1 359,000 537,400 (1) 4,607,300 4,966,300
: 222,800 (2-5)
145,600 (6-30)
2 2,704,000 701,100 (1) 9,000,400 11,704,400
386,500 (2-5)
309,300 (6-30)
3 6,300,600 746,400 (1) 10,216,000 16,516,600*
431,800 (2-5)
354,600 (6-30)
4A 9,442,600 746,400 (1) 10,216,000 19,658,600*
431,800 (2-5)
354,600 (6-30)
4B 7,262,200 746,400 (1) 10,216,000 17,478,200*
431,800 (2-5)
354,600 (6-30)
5 7,233,200 746,400 (1) 10,216,000 17,449,200*
431,800 (2-5)
354,600 (6-30)
6 90,953,600 568,700 (1) 4,651,900 95,605,500
224,500 (2-5)
145,900 (6-30)
* Note: Estimates have been revised from the Proposed Plan to reflect
costs associated with a passive gas management system.
38
-------
Table 14
Alternative 3
Cost Analysis: UCP Solid Haste Cap
Itea
1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
16
17
18
19
20
Description
Mobilization
Wetland Assessment Study
Floodplaln Assessment Study
Estinted
Quantity Unit Cost ($)
Monitoring Well Installation
(Table 4-13)
Farrington Monitoring Hells
Sailing (S39.400/event z 4
12* Supplemental Clean Fill
6* Inch Sand Layer
12* Drainage Layer
18- Select Fill
6" Top Soil
40 ail Geonentrane Liner
Filter Fabric
Cap Placement
Seeding
Clearing and Grubbing
Removal, Stockpiling. i
Decon of Site Debris
Excavation of Dnos
Transportation of Drue
Incineration of Dnas
Stonwater Control .
events)
37.037 cy 5.95 per cy
18,519 cy 9.42 per cy
37.037 cy 12.25 per cy
55.557 cy 5.95 per cy
18.519 cy 10.25 per cy
1.000.000 sf 0.63 per sf
111.111 sy 2.43 per sy
166,669 cy
871,200 sf 0.08 per sf
871,200 sf 0.11 per sf
25 cy 150.00 per cy
150 druB 482.00 per dnai
150 dnfls 8.50 per drm
150 dnas 475.00 per dnai
Total Cost ($)
550.000
9.400
2.100
39.600
157.600
220,400
174.400
453.700
330,600
189,800
630.000
270.000
758,300
70,600
95,800
3,800
72.300
1.300
71.300
91.700
(Table 4-10)
-------
Alternative 3
Cost Analysis: HJDEP Solid Haste Cap
Item
21
22
23
24
25
26
27
28
29
30
31
32
•
Est lasted
Description Quantity Unit Cost ($)
Leachate Collection (optional)
(Table 4-9)
Active Gas Control Systea
(Table 4-12)
Passive Gas Control Systea
(Table 4-11)
Access Road 4.135 sy 12.36 per sy
Fencing, including 4.700 ft 18.20 per ft
Gates and Installation
Warning Signs 94 signs 11.90 per sign
Drainage Layer Piping 10.100 ft 3.90 per ft
Fittings and Ceaent
(20* of Piping)
Nanagenent and Overs Ite
(2 years)
Antient Air Monitoring
Subtotals
A) Cap
B) Cap w/ Active Gas Systea
C) Cap ml Active Gas and
Leachate Collection System
D) Cap w/ Passive Gas Systea
E) Cap «/ Passive Gas and
Leachate Collection Systeas
Engineering and Contingencies
A) Cap
Contingencies (15% of Subtotal)
Engineering (10* of (Subtotal + Contingencies))
B) Cap M/ Active Gas Systea
Contingencies (15% of Subtotal)
Engineering (10% of (Subtotal + Contingencies))
Total Cost ($)
75.700
349.500
112.100
51.100
85,500
1.100
39.400
7.900
434.800
56,100
4.868.600
5.218.100
5.293.800
4.980.700
5.056.400
730.300
559.900
782.700
600.100
-------
Alternative 3
Cost Analysis: HJDEP Solid Haste Cap
EstlBted
Itea Description Quantity Unit Cost ($) Total Cost ($)
C) Cap «/ Active Gas and
Leachate Collection Systems 794.100
Contingencies (15% of Subtotal) 608.800
Engineering (10% of (Subtotal + Contingencies))
0) Cap •/ Passive Gas System
Contingencies (15* of Subtotal) 747.100
Engineering (10% of (Subtotal + Contingencies)) 572.800
E) Cap •/ Passive Gas and
Leachate Collection SysteB
Contingencies (15% of Subtotal) 758.500
Engineering (10% of (Subtotal «• Contingencies)) 581.500
33 TOTALS
A) Cap 6.158.800
B) Cap w/ Active Gas System 6.600.900
C) Cap «/ Active Gas and 6.696,700
Leachate Collection Systeos
0) Cap N/ Passive Gas System 6.300.600
E) Cap w/ Passive Gas and 6.396.400
Leachate Collection Systess
-------
Alternative 3, 4A, 4B, and 5
O&H Analysis: Multi-layer Caps
Item DescriptionCost Per Year(5)
1 Fencing and Signs 4,500
2 Mowing Vegetative Cover 14,300
3 Landfill Cap and Stormwater Control 164,800
4 Leachate Control System (Optional) 278,900
5 Active Gas System (Optional) 886,200
6 Passive Gas System (Optional) 2,400
Subtotals
Basic Alternatives 183,600
w/Active Gas System (Years 1-30) 1,069,800
w/Active Gas and Leachate Systems (Years 1-30) 1,348,700
w/Passive Gas System (Years 1-30) 186,000
w/Passive Gas and Leachate Systems (Years 1-30) 464,900
8 Contingencies (15 percent)
Basic Alternatives 27,500
9
w/Active Gas System (Years 1-30)
w/Active Gas and Leachate Systems (Years 1-30)
w/Passive Gas System (Years 1-30)
w/Passive Gas and Leachate Systems (Years 1-30)
Ground Water (Year 1)
Surface Water and (Year 2-5)
Sediment Monitoring (Year 6-30)
160,500
202,300
27,900
69,700
522,400 *
207,800 *
130,600 *
10 Air Monitoring (Years 1-30) 10,100 *
Includes 15 percent contingency
-------
Alternative 3, 4A, 48, and 5
O&H Analysis: Multi-layer Caps
Item Description
gostPer Tear(J)
11 Total O&M
Basic Alternatives
w/Active Gas System
w/Active Gas and Leachate Systems
w/Passive Gas System
w/Passive Gas and Leachate Systems
(Year 1)
(Year 2-5)
(Year 6-30)
(Year 1)
(Year 2-5)
(Year 6-30)
(Year 1)
(Year 2-5)
(Year 6-30)
(Year 1)
(Year 2-5)
(Year 6-30)
(Year 1)
(Year 2-5)
(Year 6-30)
743,600
429,000
351,800
1,762,800
1,448,200
1,371,000
2,083,500
1,768,900
1,691,700
746,400
431,800
354,600
1,067,100
752,500
675,300
-------
APPENDIX A
NJDEP LETTER OF CONCURRENCE
-------
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
jyon-H A. YASKIX, COMMISUOKER
CN«02
TRENTON, XJ. OI6UO402
(609) 2>2 2185
Ftv. (609) 914-3962
SEP 2
Mr. Ccr.etar.tine Sidaacn-Zriatoff
Regional Adcini»trator
USEPA - Rtgion II
Jacob K. Javite Federal Building
New York, NY 10278
Dear Mr. Erietoff:
Potl-lt* bra^d fax trantntittal memo TpTl
EV}fe£O
Co.
W5T
"^^
&rfG-
"KSfST
P»xf '
The Cepertsent of Environat&tal Protection has evaluated and concurs vlth
the eelected recedy for the Sayraville Landfill Superfund Site outlined
beiov:
f
The (elected remedy ineludee the removal of buried drun* and cloeure of
the ler.dfill in accordance with State of New Jereey Solid Vaata
• Lerdfill Closure Regulation*. A eubiequenc decieion docuaent vill
tddresi the resedietion of ground water , aurface vatere and etream
«eci=er.ts, ai veil ae the need for a landfill leeehate collection and
treatment ayates.
The c&jor cosponer.ta of the aelected remedy include the following:
reitrictione to aite aeceae by oeana of fencing and the
• stAbliehtrent of appropriate deed restrictions;
excavation «nd removal of buried dru&a for eff-eice treetaent
and dispoetl;
placement of a landfill cap . with an impermeable liner to
reduce leachste generation;
installation of a landfill gaa sanageaent ayataa;
instillation of additional ground vater monitoring velle; and
ieplesentation of an anvironaental monitoring prograa to
•neure the effeetivcneaa of the reaedy.
A'»»- Ji'tty i, an Equal Oppenunir. S.
-------
-2-
Tht Department rtitrvts itt final coomtnct on tbt eoapltt* JUcord of
Decision ptading tn opportunity to r«vi«w th* eoapltttd documents, including
tht document'• rtsponfiiv«r.e«« tummtry.
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
89/20/98 . Index Docuient Nutber Order Page: 1
SAYREV1LLE LANDFILL Documents
Docuient Kuiber: SAY-Bei-BBBl To 4821 ^te: 87/38/98
Title: (News release announcing public teeting to be held on 88/16/98, to discuss Proposed Plan for
cleanup of Sayreville Landfill)
Type: CORRESPONDENCE
Author:, none: N3 Dept of Environmental Protection
Recipient: none: none
Docuient Nuiber: SAVM1-8B82 To 8882 Date: 84/38/86
Title: Background Investigation Study - Reiedial Investigation/Feasibility Study for the Sayreville
Landfill
Type: PLAN
Autnor: none: Black & V'eatch
Recipient: rone: NJ Dept of Environiental Protection
Docuier,: Nutisr: SAY-eei-8ZZ" Tc 8683 Date: 88/25/86
Title: F;E:: iii:::^ Plan - Sayreville Landfill
Tyce: P1.AV
Author: H:sier, J Lawrence: Black t Veatch
Re:i:ier.t: 6L':;rgaie, Hichael: NJ Dept of Environiental Protection
Ds:aisr.t Kaiser; SfiY-eEJ-8884 Tc 8BB4 Date: 88/25/86
Title: Health ani Safety Plan - Sayreville Landfill
Tyoe: Pi-A-X
Abthcr: Hosier, J Lawence: Black, k Veatch
Recipient: Burhngaie, Michael:' NJ Dept of Environiental Protection
Docuirt Nt«w: SP-Mi-llK To Kt5 Date: 12/12/86
Title: in •*» ?;«:. S^ort Fon - QA Prograi Plan - Sayreville Landfill
Tyoe: PLAN
flut^:-: Hrsfr'. .' Le«-er'.ce: Sia:l' I Vestcfi
S-e::.::i.'t: s;r,5: fcJ ts?4. of Environientsi rrotectiw
-------
Index Docuient Nuiber Order
SAYREVILLE LANDFILL Docuients
Page: 2
89/28/98
Docuier.t Njiber: SAY-8B1-ZBB6 To B8B6 Pate: 12/12/86
Title: Quality Assurance Project Nanageient Plan
Type: PLAN
Author: Hosier, J Lawrence: Black t Veatch
Recipient: none: NJ Dept of Environiental Protection
Docuient Nuiber: SftY-eei-888? To 8807 Date: 88/85/62
Title: HRS Scoring Package - Sayreville Landfill
Type: PLAN
Author; floore, Ed: US EPA
Recipient: none: none
Dccutert Nuiser: SA\-Bei-BBeS To 8888 Date: 87/81/85
Title: Cc-ii'jr.ity Relations Plan for Ha:ardoi:S Haste Site Reiedial Action - Sayreville Landfill
Type: Fifth
At'tRD': none: NJ Dept of tnvi'onten'al Protection
Recipient: none: r>0ne
Ds:u»er: M:»': S#»-8«:-B8C? To 8889 Date: 87/16/98
Title: 'ur.f tra-uitting site comttee conents on the Draft Feasibility Study and Baseline Risk
Aueisier.t reports dated June 1998)
DRREE^ONrEKCE
fiutr.zr: Le*:s. S';s:ser. V: Soldshore K'olf & Lexis
Re::c:ent: B^cd*. Neal: NJ Dept of Environiental Protection
^^Av v*v * •• -mf ~^^^ Ma ^ ^" ^-^« • * ^^^^»^ ^^^^^^^^^^^^^^^^~^^**^^^*^^"*™^*'^^^^^^^^^^^^^*^^^^^^^^^^^—*^^^-"^^^^^^^fc^^™'^^T^^^^^^^^^****^
Docuient ^i:f: SAf-tll-BBlB lo 8818 Date: 87/12/98
Title: (Keic regarding Air Prograis Branch coiients on the Sayreville Landfill Draft Feasibility
Stu:y)
Type: CD»R£SP01C':V3
fljtNor: fle>:-.5. ^.•.::-::i: US- E?ft
Recicier,;: htiinsor.. Sharer,: US EPA •
-------
89/28/98 Index Docuient Nuiber Order Page: 3
SAYREVILLE LANDFILL Documents
Docuient Nuiber: SAY-881-8811 To 8811 Date: 87/17/90
Title: IKeic regarding Hater Ranageient coiients nith respect to wetlands on the Draft Feasibility
Study for the Sayreville Landfill)
Type: CORRESPONDENCE
Author: Ha Heck, John S: US EPfl
Recipient: Borseiiino, Ronald J: US EPA
Docuiert toiler: SAY-BB1-B812 To 8812 Date: B7/U/98
Title: (Beic regarding RCRA review of Sayreville Landfill Feasibility Study)
Tvse: CORRESPONDENCE
ftjtn;r: Sfl'ina. Andre*: US EPA
Recipient: Borsellina. Ronald J: US EPA
Dc:uier.: NuiSer: SAY-0e:-0Bi3 To B?13 Date: B7/16/9B
Title: (flei: recsrding cciients on Draft FS Report)
K. !.-••:-: :.='::*.. T:-»: K'J Dept of Environienta! Protection
Re::::erit: t^rlir.cats. flichael: NJ Dept of Enviromental Protection
Ccc-.ir.: Sarsr: sAi-BZl-een To 8814 Date: 87/24/98
Title: (Letter reoarem: caitents or Draft Proposed Plan for Sayreville Landfill site operable unit
AiftriCr: Csiiak. Frar.l B: National Oceanic & Attospheric Adiinistration (NOAA)
Recipient: Atr.insr, Snaron: US EPA
Docuient Hii;er: SAY-BB1-BB15 To 8815 . Date: B7/B9/9B
Title: (He»'o regar5ing coiients on the Feasibility Study for SayrevilJe Landfill Superfund Site)
Tvpe: CD
Authar: Luckty, Frederick J: US EPft
Recipient: Lr:h, Do'.; US EPfe
-------
19/28/90 Index Docuient Nuiber Order Page: 4
SfiYREVILLE LANDFILL Docuients
Docuient Nuiber : SAY-881-8816 To 0816 Date: B7/11/9B
Title: (Heio regarding couents on Sayreville Landfill Reiedial Investigation and Feasibility Study)
Type: CORRESPONDENCE
Author: Yeates, Robert: NJ Dept of Environmental Protection
Recipient: Burlingaie, Hichael: NJ Dept of Environmental Protection
Docuient Nuiber: SAY-BBl-8ei7 To 8817 Date: 87/26/98
Title: Proposed Flan - Sayreville Landfill Superfund Site
Type: FlftS
Author: Singer. Brace L: NJ Dept of Environiental Protection
Recipient: none: none
Docuient N-jiSer: SAY-BZI-BZIS To 8216 Date: 89/18/89
•Title: (Lilts' translating for service a Directive in tne latter of Sayreville Landfill III)
Ty??: ::->:: r-^'DESTE
fiiitr.c-r: JraCY, Neil: Nj Dept of Environiental Protection
Re:ip:ert: ".ore: Potentially Responsible Party (PRP)
Attache*: SA:-eBi-?B;5; SAY-BB1-8B16E SAY-BB1-8B1SC SAY-BB1-B81BD
Docuiert S.*:e': SA\-M:-eei5'; Tc ZeiB'A Parent: SAY-BBl-BBIB Date: 89/18/89
Title: Direr.ive III in the Setter of Sayreville Landfill III Haste Disposal Site
Typ;: LE5AL DDCUrEKT
Autn:-: Lcrcc-r,-, Pr-ald T: NJ Dept of Environiental Protection
fiecipaer.t: nsae: Pctentiall) fiejporEiile Party (FfiP)
Docuier.t \.iier: Sh<-BBi-BBi8/B To BB18/B Parent: SAY-BBl-BBIB Date: 86/19/86
Title: Directive and Notice to Insurers in the Hatter of the Sayreville Landfill III
Type: LESAL Dj:i"£».T
Author: Corcory, Ronaio T: KJ Dept of Environmental Protection
Recipient: none: Potential)* responsible Party I PRP)
-------
89/28/98
Index Document Nuiber Order
SAYREVILLE LANDFILL Oocuients
Page:
Docuient timber: SAY-8B1-BB1B/C To BB1B/C Parent: SAY-BB1-BB18 Date: 18/28/86
Title: Adiinistrative Consent Order and Agreeient in the flatter of Sayreville Landfill III
Type: LE6AL DOCUMENT
Author: Corcory, Ronald T: NJ Dept of Environmental Protection
Recipient: none: Potentially Responsible Party (PRP)
Docuient Number: SAY-BB1-BB1B/D To B818/D Parent: SAY-BB1-BB1B Date: B8/B7/B9
Title: Directive II in the Ratter of Sayreville Landfill III Haste Disposal Site
Type: LEEfiL DOC'JHENT
Autnr: Corcory, Ronaid T: NJ Dept of Environiental Protection
Recipie:.:: r:nr: Potentially Responsible Party (PRP)
Docuier.t ^sier: SAV-BBl-BBl? To 8B19 Date: 88/81/98
Title: Baseline Risk Assessment - Sayrevilie Landfill
Typs; P^AH
Auth:r: n:>r.r. Biv haste Science 4 Technology Corporation
Recipient: r.cne: NJ Dept of Environienta! Protection
Docuier.t Narsr: SAY-8Z:-BB2P To BO Date: B3/28/9B
Title: Final fie;ort: Reiedia! Investigation - Sayreville Landfill
' Type: PLAN
Author: none: Fl'v Kaste Science I Technology Corporation
Recipient: r.ane: Nj Dept of Environiental Protection
Attached: SAV-B81-BB21
Docuient Nuiber: SflY-B2:-8821 to 8821 Parent: SAY-BB1-8B2B Date: B3/2B/9B
Title: Appendices: Reiedial Investigation - Sayreville Landfill
Type: PLAN
Author: none: BtV Haste Science 4 Technology Corporation
Recipient: none: NJ Dept of Environmental Protection
-------
I9/2B/9B
Index Docuient Nuiber Order
SAYREVILLE LANDFILL Documents
Page: &
Docuient Nuiber: SAY-BB1-BB22 To 8822
Title: (Cover aeic to Phase 2 Investigation Work Plan - Supplemental RI Mork)
Type: CORRESPONDENCE
Condition: M1SSINE ATTACHMENT
Author: Burlingaie, Hichael: NJ Dept of Environiental Protection
Recipient: none: distribution list
Date: 18/84/89
Docuier.t limber: SAY-BB;-ea23 To 8823
Title: Feasibility Study Report - Sayreville Landfill
Type: PLAN
Author: none: 84V Haste Science 4 Technology Corporation
Recipient: none: NJ Dept of Environmental Protection
Date: 87/81/98
Docuier:t Nuttier: SfiY-eei-B22< To BO
Title: !*::::E letter for the Sayreville Landfill site in Middlesex County NJ)
Type: CORRESPONDENCE
Autr,e': Casce, Richard L: US EPA
Recicieat: eootiir.g, Daniel L: Potentially Responsible Party (PRP)
Date: 88/21/98
Docuiert Njiser: SAY-8Zl-Be:5 To BB25
Title: [»ict;ce letter for the Sayreville Landfill site in Middlesex County NJ)
Type: CS^ESPONDENTE
. fiuth;r: Caspe, Richard L: US EPA
Recipient: none: Potentially Responsible Party (PRP!
Date: 88/21/98
Docuient Kut&er: SAY-BZi-BBZi To 8B2& Date: 81/26/81
Title: (Notice of Apearance before State Grand Jury of John J. Degnan, Esq. Attorney General)
Type: LEGAL DOCUMENT
Author: Corvine, Pasquale F: court reporter
Recipient: none: NJ, State of
-------
Index Docuient Nuiber Order Page:
SAYREVILLE LANDFILL Documents
Oocment Nuiber: SAV-BB1-8B27 To BB27 Date: 88/38/84
Title: (Deposition of Thoias Kitzi - in re: Sayreville Landfill III)
Type: LEGAL DOCMENT
flutter: Sullivan-Hill, Linda: court reporter
Recipient: none: NJ Dept of Environmental Protection
-------
09/20/98 Index Chronological Order Page: 1
SAYREVILLE LANDFILL Documents
Document Ha»ter: SAY-BB1-8B26 To BB26 Date: B1/26/B1
Title: (Notice of Apearance before State Brand Jury of John J. Degnan, Esq. Attorney General)
Type: LESfiL DOCUMENT
Author: Corvine, Pasquale F: court reporter
Recipient: none: NJ, State of
Docuier.t Kuioer: SAY-BB1-BB87 To 8087 Date: 08/05/82
Title: HRE Scoring Package - Sayreville Landfill
T\pe: PLAN
Author: floo^e, Ed: US EPA
Recipient: none: none
Docuier.t ^«ber: SAY-eei-0e:7 To 8827 Date: 88/38/84
Title: •Je—iition of Thoias Kitzi - in re: Sayreville Landfill III)
*VDS: L-SA. DOCU-ENT
A-tV:-: SLliivan-HiIl, Linca: court reporter
F:ec:::;-t: ncr.e: NJ Dept of Environmental Protection
Docaer: «.yi:e': SAY-BZl-BZeS To 8828 Date: 87/81/85
Title: Coii^nity r.eleiions Plan for Hazardous Kaste Site Reiedial Action - Sayreville Landfill
TVJE: P1*N
.A.:'.:", "3^,9; NJ Dept of Environtental Protection
Re:ip;ev.: none: none
Docuiev. kjser: 5AV-0Bl-0«18/6 To B818/B Parent: SAY-BB1-B818 Date: 86/19/86
Title: Di'e'ctive and Notice to Insurers in the Hatter of the Sayreville Landfill III
Type: LESftL DOCUMENT
Author: Corcory, Ronald T: • NJ Dept of Environiental Protection
Recipient: ::r«: Potentially Responsible Party (PRP)
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.89/28/98 Index Chronological Order Page: 2
SftYREVILLE LANDFILL Documents
zs3zz:s:3zszzz:3szzzszzzz::z::zsz™z:zsz::sz3sz3zzs:zzzs:zzsrsz:szzzzzzrss3zzzzzzzrzzzzzzz;szzz:zz=s::z:zzz3zszrzzsz:zsz
Docuier.t Nmber: SAY-BBl-BBe: To 8882 Date: 86/38/86
Title: Background Investigation Study - Reiedial Investigation/Feasibility Study for the Sayreville
Landfill
Type: PLAN
Author: none: Black 4 Veatch
Recipient: none: NJ Dept of Environmental Protection
Docuient NuiDer: SAY-881-8883 To 8BB3 Date: 88/25/86
Title: Field Saipling Plan - Sayreville Landfill
Type: FL?K
Author: Hosier, J Laurence: Black 4 Veatch
Recipient: Burhngaie. P.ichaei: NJ Dept of Environmental Protection
Dc:uier.t Nuiier: SA>-ee<-BZ?4 To 8884 Date: 88/25/86
Title: Health sni Safety Plan - Sayreville Landfill
Type: PLAN
nutnr: Hcs»er. J La*rer:e: Black t Veatch.
Recip:e-t: &.ri:n:st5. ftichael: K; Dept of Environiental Protection
Dsc-.ir^. ^iier: SftT-eei-eeiB/C To 8818/C Parent: SAY-881-BB1B Date: 18/28/86
Title: Ainristrative Consent Order and Agreeient in the Hatter of Sayreville Landfill III
Type: L-SAL DQCL'K-NT
ftutr:5r: Co'cory, Roriald T: NJ Dept of Environiental Protection
Recit:s:t: none: Potentially ResponsiDle Party .(PRP)
i
Dacuient Aj;er: S*v-ZZi-B8B5 To B885 Date: 12/12/86
Title: toork/Sn Flan Short Fori - QA Prograi Plan - Sayreville Landfill
Type: PLAN
Author: Hosier, J Laurence: Black I Veatch
Recipient: none: NJ Dept of frvirsn»ental Protection
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89/28/98
Index Chronological Order
SAYREVILLE LANDFILL Oocuients
Page: 3
Document Nuiber: SAY-881-BBB6 To 8886 Date: 12/12/86
Title: Quality Assurance Project Hanageient Plan
Type: FLftN
Author: Hosier, J Laurence: Black 4 Veatch
Recipient: none: NJ Dept of Environmental Protection
Docuient Nuiber: SAY-8B1-8818/D To 881B/D Parent: SAY-8B1-8818 Date: 88/87/89
Title: Directive II in the Natter of Sayreville Landfill III Haste Disposal Site
Type: LEShL DDCUHENT
ftutho1". Ccrtory, Ronald T: NJ Dept of Environiental Protection
Recipient: none! Potentially Responsible Party (PRP)
Docute:.: fciier: SA*-Bei-B8i5 To 8818 Date: 89/18/89
Title: (Letter fansiitting for service a Directive in the latter of Sayreville Landfill 111)
Ty:e: CD::E!?:N:EN:E
Autr,!r: Erod>, Sea!: S'J Dept of Environiental Protection
Kecipie-t: ncr.?: Pctentially Responsible Party (PRP)
Attacl-.ei: 5A»-ee:-Be:BA SAY-8ei-eei8B SAY-88;-eeiBC SAY-B81-BB18D
Dccaiert s-i:?". ^.'-Zei-eeiE/fi To B816/A Parent: SAY-BB1-8B18 Date: 89/18/89
Titie: Directive III in the flatter of Sayreville Landfill II! Haste Disposal Site
Tvse: i.E5A. K:UKit,l
•Au:n;r: Cc*::'v, Romaic T: NJ Dept of Environienta! Protection
Recipier:: none: Potentially Responsible Party (PRP)
Dr-r.se-.-. Vjiter: SAi-811-182: To 8212 Date: 1B/B4/89
Title: (Cover lets to Phase 2 Investigation Mork Plan - Suppleiental RI Nork)
Tyae: ^'-ISPON'M^E
Condition: P.Iti.'Sc r*Tt^ft-VT
Autho'? ?;•;;.-.:»§e, «:ik5ei: NJ Dept of Envi'Mienta! Protection
r. iist
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89/28/98
Index Chronological Order
SAYREVILLE LANDFILL Documents
Page:
Docuient Nuiber: SAY-8ei-8828 To 0820 Date: 03/20/98
Title: Final Report: Retedial Investigation - Sayreville Landfill
Type: PLAK
Author: none: BiV Haste Science & Technology Corporation
Recipient: none: KJ Dept of Environmental Protection
Attache:: SAY-B8i-?B21
Docuient Suiber: SAY-0B1-SB21 To 0021 Parent: SAY-0B1-B020 Date: 83/20/90
Title: Appendices: Reiedial Investigation - Sayreville Landfill
Type: FLAN
Author: r,:.r>e: BIV *aste Science i Technology Corporation
Recipient: nc-r.e: NC tept of Enviror«er.tal Protection
Docuier.: N-ji:er: SAY-0Z;-0e:3 To 8B23 Date: 07/81/90
Title: FeaE:c:hty Study Report - Sayreville Landfill
Ty;-s: FL^N
ALf-cr: r:-.e: B»V tisste Science I Technology Corporation
Reciter.:: r.:r.e: KJ Dep: cf Environmental Protection
Dc:u»rt N.•:?-: SAy-0e;-BZ:5 Tc 88:5 Date: 07/89/98
Title: I*E:; re:ordir!? coieents on the Feasibility Study for Sayreville Landfill Superfund Site)
Tyrs: C^rSrCNEESZE
Co-:;t;:r: D-A-T
Ai't-sr; Lucf:e\, Crec:en;» J: Iji tPA
ftec:::e-t: .yr.tf., ten: US EPA
Bocccs--. kmser: JiY-iei-Kib-Tc B816 Date: 87/11/98
Title: Tr>: recardinc conents on Sayreville Landfill Reiedial Investigation and Feasibility Study)
Ty:s: cc;::":-:i:z*.::
Authcr: Yeatts. Rci-e't: VJ t*:t :' Erv:ron*ental frotection
Rec:piert: .r.-I;::s»t. «;cnaei: KJ !•»;! :' Environiefita: rrotsction
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89/28/98
Index Chronological Order
SAYREVILLE LANDFILL Docuients
Page: 5
Docuient Nuiieri SAY-8B1-B81B To 8818 Date: B7/12/9B
Title: (Beio regarding Air Prograis Branch couents on the Sayreville Landfill Draft Feasibility
Study)
Type: CORRESPONDENCE
Author: Devine, Alison: US EPA
Recipient: Atkinson, Sharon: US EPA
Docuient Nuiser: SAY-BB1-BBE9 To BBB9 Date: 87/14/98
Title: (Letter translating site coiiittee couents on the Draft Feasibility Study and. Baseline Risk
Assessient reports dated June 199B)
TyDe: rD
Author: Lewis, Nielsen V: fioldshore Ho If 4 Lewis
Recipient: Ero:y, Neal: NJ Dept of Environiental Protection
Docuient N^iier: SAY-Be:-eei2 To BB12 Date: 87/16/98
Title: (*ez: r^rc'ir,; ?:.RA review of Sayreville Landfill Feasibility Study)
T^r: :CF.Fi;:C:iDEN:E
ftuf,:-: Be:;:na, Andrew: US EPA
Re:i;ie-t: i:'??!!:':, Sorsls J: US EPA
DOCUIK.: d-jicer: SSY-BB1-BB13 To B213 Date: B7/16/98
Title: (He«t recarcino couents on Draft FS Report)
•'Tv3e: COC.F.ES'OniDENCE
Aiithc". l»e':tt, "::: NJ Deot of Environiental Protection
Recipient: Burlinges?, l?s:r,jel: *J Dept of Environiental Protection
Docuier.t Nuiber: SAY-BB1-BB11 To 8811 Date: 87/17/98
Title: f«e:-r rece'iin: Water Kanageient couents with respect to wetlands on the Draft Feasibility
SLr- ;:- f.? ii^r.i.'ls Lwafih'/
Author: fta'.Jert . Johrs S: '•!';. tFP •
Recipient: E:r«eilino, Ronali J: US-EPA
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89/28/90
Index Chronological Order
SAYREVILLE LANDFILL Docutents
Page: 6
Oocuient Nuiber: SAY-001-0B14 To 0014
Date: 87/24/9B
Title: (Letter regarding conents on Draft Proposed Plan for Sayreville Landfill site operable unit
one)
Type: CORRESPONDENCE
Author; Csulak, Frank 6: National Oceanic I Atiospheric Administration (NOAA)
Recipient: Atkinson, Sharon: US EPA
Docuient Nuiber: SAY-8B1-B017 To 8017 Date: 07/26/90
Title: Proposed Plan - Sayreville Landfill Superfund Site
Tyoe: PLAN
Autr.cr: Singer. Grace L: NJ Dept of Environiental Protection
Recipient: none: none
Docuien: N-iier: S;-«e;-8Bei To BBZ1 Date: 07/38/98
Title: fce*s release announcing oublic letting to be held on 08/16/90, to discuss Proposed Plan for
cieri: •:' Eavre,--::j Landfill)
TvEt: CORRESPONDENCE
Autric-: nor-e: NJ Dept of Environiental Protection
Redder- r.s*.e: nore
Docuient falser: SAY-Bei-BBl0 To 8019 Date: 08/81/98
Title: Baseline ?.isr Assessient - Sayreville Landfill
,'ype: P.AN
ftu*/.:r: 7.t,:.4-. ft.' fcists Ecience * Technoloov Corporatior,
Recipient: none: »] Lspt of Ervironiental Protection
Docuient Nuiber: SAY-881-BB24 To 8024 Date: 08/21/90
Title: 'fcrti-s lette' fcr the Sayreville Landfill site in Middlesex County NJ)
Type: 'i:-:iv >?=i"
Authcr: Casps. :.:-,ir: •.: •!'£ E:>
Recipient: f-rcd-c. Da?:?:. >: rotentiallj Responsitrle Party (PW)
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§9/28/98 Index Chronological Order Page: 7
SAYREVILLE LANDFILL Docuients
Docuiert Kuiber: SAY-881-B825 To 1825 Date: 88/21/98
Title: (Notice letter for the Sayreville Landfill site in Hiddlesex County NJ)
Tyoe: CORRESPONDENCE
Autftcr: Casoe, Richard L: US EPA
Recipient: none: Potentially Responsible Party (PRP)
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09/20/98 Index Author Naie Order Page: 1
SAYREVILLE LANDFILL Docuients
Docuient Nuiber: SAY-0Z1-0881 To 0081 Date: 07/30/90
Title: (He»s release announcing public teeting to be held on 08/16/90, to discuss Proposed Plan for
cleanup of Sayreville Landfill)
Tvpe: CORRESPONDENCE
Author: none: NJ Dept of Environtental Protection
Recipient: none: none
Docuier.t limber: SAY-001-088: To 0002 Date: 06/30/86
Title: h:icrcjni Investigation Study - Reiedial Investigation/Feasibility Study for the Sayreville
Lan:fill
T»:e: PLAN
fiatn:r: nsne: Eiao 4 Veatch
Rec:::er.t: rme: NJ Dept of Environaental Protection
Nu»:e': SAY-0e:-00ZE To 0B0B Date: 07/01/85
Title: C;**.-:t. sf]ei:G^ Plan for Ka:ardoj= Waste Site Reiedial Action - Sayreville Landfill
%•:;: PLAN
A-jtrr: nr.e: NJ Dept cf Environiental Protection
Rs::f:e::: ncne: 'none
Doc.tr.: N.I:?': Si'-2ei-eZ19 To 0219 Date: 88/81/98
Title: hsrl;-.f :;=l AEse-:ier:t - Sayreville Landfill
. Tjjs: F.AN
A-.th:*: rjone: Hv ka;te Science 4 Technology'Corporation
Recipier.: nc.'.e: SJ De:t oi Environiental Protection
Oocbient N-^iSer: SAY-0e;-082e To 0020 Date: 03/20/90
Title: Final Report: Reiedial Investigation - Sayreville Landfill
Tyse: PLA"
fl-jthc-r; r,cr=: P/v Waste Science i Technc-logy CDrporation
Recipier.;: none: NJ Dept of Environmental Protection
Attache:: SAY-801-0B21
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89/28/98
Index Author Nate Order
SAYREV!LIE LANDFILL Documents
Page: 2
Docuient Nuiber: SAY-B8i-8B21 To BB21 Parent: SAY-BB1-8B2B
Title: Appendices: Reiedial Investigation - Sayrevil-le Landfill
Type: PLAN
Author: none: BIV Haste Science ( Technology Corporation
Recipient: none: NJ Dept of Environmental Protection
Date: 83/28/98
Document Nutber: SfiY-881-8823 To 8823 Date: 87/61/98
Title: Feasitehty Study Report - Sayreville Landfill
Type: PLAN
Authcr: nine: BJV Haste Science 4 Technology Corporation
Recipient: r.sr.e: NJ Sect of Environmental Protection
Document falser: £Av-2ei-eei2 To BB12 . Date: 87/16/98
Title: (ieH regarding RCRA revien of Sayreville Landfill Feasibility Study)
TV:E: CD:::-S-.-SKHCE
Abt^D': Fellina, Andre*: US EFA
Recisiert: Bcrsellinc, Ronald J: US EPA
Dcr^e--: !.-•:?-: 5;--£Jl-Be;c To 8816 Date: 89/18/89
Title: (.Et:?' :ran=iittinc -for service a Directive in the latter of Sayreville Landfill III)
Type: CD*:;iE:'uK['ENCE
#tfiv". tr::>. !<-oi: »iJ Ce:t cf tMiror.iePtal Protection
Ft::::sr:: no^-e: Peter*.ially Resosnsible Party (PRP)
dttii';*;: 5iv-tZ;-881cA SAV-M1-8B19B SAY-BBJ-IB1BC SAY-8B1-B81BP
Dccuient ^tten Efil-BBl-BBi: To BB22 ' Date: 1B/B4/B9
Title: (Cover leio to Phase 2 Investigation Kork Plan - Supplemental RI Hork)
Type: CORFiSPDNDENCE
Condition fti55IN6 ATTACHNENT
Author: Burhngaie, Michael: NJ Dept of Environmental Protection
Recipier/.: r.one: distrio^tio,' list
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19/28/98
Index Author Naie Order
SAYREVILLE LANDFILL Docuients
Docuient Nuiber: SAY-881-B824 To 8824 Date: 88/21/98
Title: (Notice letter for the Sayreville Landfill site in Middlesex County NJ)
Type: CORRESPONDENCE
Author: Caspe, Richarc L: US EPA
Recipient: Booding, Daniel L: Potentially Responsible Party (PRP)
Docaient Nuiier: SAy-881-8825 To 8825 Date: 88/21/98
Title: (Notice letter for the Sayreville Landfill site in Middlesex County NJ)
Type: CORRESPONDENCE
Autro': CUBE, Richard L: US EPA
Recipient: r.cne: Potentially Responsible Party (PRP I
DocLient Nuiser: SAY-BZl-B8i8/A To BB18/A Parent: SAY-881-8818 Date: 89/18/89
Title: Directive III in the Hatter of Sayreville Landfill 111-Kaste Disposal Site
Type: LE5AL DOCUMENT .
«i.t-,:': Cc'rrrv, Ronald T: NJ Dept of Environiental Protection
Re:icieri: none: Foier.tially Responsible Party (PRP)
Cc:uis-.t tur.er: 5fi>-Mi-Bei6/B Tc 8818/B Parent: SAY-8B1-«B18 Date: 86/19/86
Title: Directive and Notice to Insurers in the Hatter of the Sayreville Landfill III
Type: LE^L DDCL'HEM
. ftjtr:-: l:rcor., ?,;-aid 1: HJ Dept of Environiental Protection
Recrpiert: none: Pctertially Responsible Party (PRP)
Docuier.t Nuiser: SAY-Bli-Beifi/C To B818/C Parent: SAY-BB1-B818 Date: 18/28/86
Title: Ao«:r.istrative Consent Order and Agreeient in the Hatter of Sayreville Landfill III
Page: 3
Type: LESAL DCCUHENT
Author: Corcory, Ronalt! T: NJ Dept of Environiental Protection
Recipient: none: Pc;e-,tially Responsible Party (PRP)
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B9/28/9B Index Author Nate Order Page: 4
SAYREVILLE LANDFILL Docuients
Docuient Nuiber: SAT-BB1-BB1B/D To 8B18/D Parent: SAY-881-8B1B Date: 88/07/69
Title: Directive II in the Hatter of Sayreville Landfill III Haste Disposal Site
Type: LE6AL DOCUMENT
Author: Corcory, Ronald T: NJ Dept of Environiental Protection
Recipient: none: Potentially Responsible Party (PRP)
Docuient Nuioer: SAY-eBi-BB26 To BB26 Date: 81/26/81
Title: (Notice of Apearance before State Brand Jury of John J. Degnan, Esq. Attorney General)
Type: LEGAL iiCUnENT
Aut^.or: Corvine, Faspuale F: court reporter
Recioier.t: none: . NJ, State of
Docuient Mser: SAr-BBl-BB14 To BE'4 Date: B7/24/9B
Title: ilette- reaariir.g coner.ts on Draft Proposed Plan for Sayreville Landfill site operable unit
one:
Type: CCSPESFOKD-CE
Actr-rr: C=i;:al. Frank E: National Oceanic 4 Atiospheric Adiinistration (NOAA)
Recipierit: Atkinson. Sr.a-or: US EPA
Docuiert Mrer: SA»-Be:-fl8ie To BBiB Date: B7/12/9B
Title: ;fteft recarcing Air Proorais Branch coiients on the Sayreville Landfill Draft Feasibility
St.:/]
Autho'i I'evine, Alison:. US EPA
Recipient: Atdnson, Sharon: US EPA
Docuier.t N^iter: SAy-BBi-8013 To BB13 • Date: 87/U/9B
Title: (Neie regarding coiients on Draft F5 Report)
Type: CORRESPONDENCE
Authsr; Eve'iit. Ton NJ Dept of Environmental Protection
Recipient: Burhngaie, Bichael: MJ Dept of Environiental Protection
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89/28/98
Index Author Nate Order
SAYREVILLE LANDFILL Documents
Page: S
Docuient Nuiber: SAY-Bei-BBBZ To 8883
Title: Field Saiphng Plan - Sayreville Landfill
Type: PLAN
Author: Hester, J Laurence: Black I Veatch
Recipient: Burlingaie, flichael: NJ Dept of Environmental Protection
Date: 88/25/86
Docuient Nuiaer: SAY-Bei-8884 To 8884 Date: 88/25/86
Title: Health and Safety Plan - Sayreville Landfill
Type: FLAN
Autwr: Hcsser, J Laurence: Black & Veatch
Recipient: Bu'lincaie. flichael: NJ Dept of Environiental Protection
Dccuier.t Kuiber: Sfi»-88i-BB85 To 8285 Date: 12/12/86
Title: «:-k'8A :;ar, Ehsrt Fori - OA Prograi Plan - Sayreville Landfill
Tycs: P.AN
A.-.-•:': h:-=i.er, J Laurence: Black & Veatch
Recipient: nine: NJ Dept of Enviror.iental Protection
D;:LI=-: N.sre': SSv-Be:-BBB6 To 8886 Date: 12/12/86
Title: Qjaht* fiSB'jrance Frcject Hanageient Plan
Tyoe: PLAN
Autw: Hssigr, J Laurence: Black t Veatch
Re'iipie::: none: KJ Dept of Environiental Protection
5cr: SAr-BBi-8889 To 8889 Date: 87/16/98
Title: (Letter transiitting site conittee conents on the Draft Feasibility Study and Baseline Risk
Assessient reparts dates! June 1998)
Type: CORRESPONDENCE
ftjfi:': Lenis, Ni?!ser. V: 6olfi5hore MoH & Lewis
Re::pie:'.: Ero:;, KES:: NC Dejt of Environiental Protection
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19/28/98 Index Author Mate Order Page: &
SAYREVILLE LANDFILL Docuients
Docuient Nu«ber: SAY-BB1-BB15 To BB15 . Date: B7/B9/90
Title: (Neic regarding coiients on the Feasibility Study for Sayreville Landfill Superfund Site)
Type; CORRESPONDENCE
Condition: DRAFT
Author: Luckey, Frederick J: US EPA
Recipient: Lynch, Don: US EPA
Docutent Nuiber: SftY-BBl-BB'll To 8811 Date: B7/17/9B
Title: («eic regarding Water Nanageunt co§«nts with respect to wetlands on the Draft Feasibility
Stucy for the Sayreville Landfill)
Type: fCPSESPONDENCE
Author: IV.ieck. John S: US EPft
Reedier:: Bc-rseiiino, Ronald J: US EPA
Docuient Nuijer: Sfi»-BZl-2eZ7 Tc BZE? Date: 88/85/82
Title: HP.E Scoring ?a:ta;e - Sayreville Landfill
Ty;&: ?^N
Autn:r: !i::'e. EC: US EPA
Reap: 9':: "*e: none
Docuier.t Nu«:sr: SAY-BZ:-8B17 To 8B17 Date: B7/26/9B
Title: Frc::Esi Fisr. - Sayreville Landfill Superfund Site
• Type: PlAK
Attnor: £:riC£r, Brace L: KJ Dept of Environmental Protection
Recipient: none: none
Docuier.t KuiDer: SAY-BB1-8B27 To BB27 . Date: B8/3B/84
Title: (Deposition of Thoias (it:i - in re: Sayreville Landfill III)
Tyse: i.EBAL BCCIWEWT
Auf;r: BLlavar-Rili, Linda: court reporter
Recipient: none: NJ Dent of Environiental Protection
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89/21/98
Index Author Nate Order
SAYREVILLE LANDFILL Docuients
Page: 7
s=rzszz:rzizzrzzsszzrzszrzrrzzzzzzzzz==sszr:szrrs=szzzrzrzzrzzzszzzrzzzrzzz=zzszzsrzszzsz=srz=zzszzsszsz=szzssssszszrs:
Docuient Nuiber: SAY-881-8816 To 8816 Date: 87/11/98
Title: (He«o regarding conents on Sayreville Landfill Remedial Investigation and Feasibility Study)
Type: CORRESPONDENCE
Author: Yeates, Robert: NJ Dept of Environiental Protection
Recipient: Burhngaie, Kichael: NJ Dept of Environmental Protection
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RESPONSIVENESS SUMMARY
SAYREVILLE LANDFILL
BOROUGH OF SAYREVILLE, MIDDLESEX COUNTY
NEW JERSEY
From July 27, to August 25, 1990, the New Jersey Department of
Environmental Protection (NJDEP) held a public comment period to
obtain verbal and written comments from citizens, elected
officials and other interested parties for the preferred remedy
proposed for the Sayreville Landfill site located in the Borough
of Sayreville, Middlesex County, New Jersey. This responsiveness
summary provides highlights of community involvement and NJDEP
community relations activities at the site during the remedial
investigation and feasibility study (RI/FS) and public comment
period. In particular, the document summarizes community
relations, technical concerns and legal questions pertaining to
the findings of the RI/FS and Proposed Plan expressed by
residents, local officials and other interested parties.
I. OVERVIEW
At the public meeting held on August 16, 1990, NJDEP formally
presented its preferred alternative for the Sayreville Landfill
site. The preferred alternative, which was detailed in the
July 27, 1990 Proposed Plan, is Alternative 3, Drum Removal and
Landfill Closure with a NJDEP Solid Waste Cap. The components of
this alternative include the following:
fencing of the site to restrict access and the
establishment of deed restrictions;
capping of the wastefill with a NJDEP Solid Waste Cap
to prevent infiltration and any potential releases of
hazardous waste to ground water and surface waters;
construction of an access road and storm water and
passive gas management systems;
removal and off-site thermal treatment of buried drums
containing hazardous wastes;
intensive ground water, surface waters, stream
sediments and air sampling and monitoring; and
the installation of additional ground water monitor
wells within the deeper Farrington aquifer.
The need for leachate collection and treatment will also be
determined based on monitoring results and further studies, as
required, and will be addressed in a subsequent decision
document.
Comments received during-the public comment period focused, in
part, on whether or not the proposed remedy was the most
-------
effective way to protect human health and the environment.
Concern was expressed over the costs associated with
implementation of the preferred alternative. Some commenters
felt that these costs would place an unfair financial burden on
the residents of the Borough of Sayreville (one of the
potentially responsible parties (PRPs)). Non-supportive comments
were received from the PRPs on the RI/FS and Risk Assessment
Reports and the Proposed Plan for the site.
In summary, the Site Committee (i.e., a group of 9 PRPs including
the Borough of Sayreville) felt that the proposed alternative "is
an excessive and unreasonable remedy which, in light of the
limited public health and environmental risks identified at this
site, is not cost effective and not required to meet applicable
or relevant and appropriate requirements (ARARs) or to protect
public health and the environment". Instead, the Committee
supports a modified version of the "No Action" Alternative
consisting of "no action" combined with institutional controls,
selective areas of soil cover application to supplement and
enhance the existing soil cap, and removal of buried drums.
Responses to verbal comments made at the August 16, 1990 public
meeting and written comments submitted by other interested
parties are found in Part III of this document entitled Summary
of Public Comments and Lead Agency Responses. Responses to
written comments received from the PRPs are found in Part IV of
this document. Many of these comments involved requests to amend
specific language within documents which were issued prior to
this record of decision. The comments are, therefore, irrelevant
to the issuance of this decision. However, the full text of
NJDEP's responses are included because some of the changes have a
substantive impact on selecting the remedy for this site.
Community relations activities for the Sayreville Landfill site
have included the following:
- NJDEP prepared a Community Relations Plan (July 1985).
Copies of this plan are located in the public repositories
for the site.
- NJDEP held a public meeting on June 5, 1986 at the
Sayreville Borough Hall to discuss initiation of the RI/FS
and respond to citizen's comments and questions.
- NJDEP initiated a continuing series of semi-annual site
status reports for the Borough of Sayreville.
- NJDEP held a public meeting on April 26, 1988 to discuss
the status of the RI/FS and respond to citizen's comments
and questions.
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- NJDEP held a public meeting on August 16, 1990 at the
Sayreville Borough Hall to discuss the results of the
RI/FS and the Proposed Plan and respond to citizen's
comments and questions. A transcript of the meeting is
available at the public repository locations.
- The public comment period on the RI/FS documents and
Proposed Plan extended from July 27, 1990 to August 25,
1990.
II. BACKGROUND ON COMMUNITY INVOLVEMENT
The Sayreville Landfill was operated by the Borough of Sayreville
from the early 1970s through 1977 for the disposal of municipal
wastes. Drums of hazardous wastes were also disposed of at the
site. The landfill was closed with a vegetated, soil cover in
1979. Problems with exposed wastes, and erosion of the cover in
the early 1980s led NJDEP to issue an Administrative Order on
October 26, 1981 to the Borough to cease violations at the
landfill.
In April 1981, 30 buried drums were located during an exploratory
excavation conducted jointly by NJDEP and the New Jersey
Department of Law and Public Safety. The drums were sampled and
found to contain among other substances, para-ethyl toluene and
pentachlorophenol. A second exploratory excavation took place in
October 1989 with the discovery of 28 additional drums. An
estimated 50 to 150 drums remain buried within the wastefill.
Local officials have maintained close contact with the NJDEP,
requesting regular status reports about this and other hazardous
waste sites in the Borough of Sayreville. On December 10, 1984,
a petition was sent to NJDEP signed by 150 Sayreville residents
which expressed their fears about toxic dumps in their community.
III. SUMMARY OF PUBLIC COMMENTS AND LEAD AGENCY RESPONSES
Verbal comments made at the August 16, 1990 public meeting are
summarized briefly below followed by responses by the lead agency
(NJDEP). Written comments submitted from the Sayreville
Environmental Commission, Assemblyman James E. McGreevey and a
local resident are also included in the comment summaries. The
comments are categorized by topic area. A copy of the transcript
of the August 16 meeting is available at the public repositories
for the site. Copies of the written comments received are
attached in Part IV of this document. The comment period was
held from July 27, 1990 to August 25, 1990.
Drum Removal
One resident questioned the need for drum removal at the landfill
and the associated costs.
-------
Response: The drums discovered in 1981 were removed from the
landfill. All of the drums found during the RI test pit
excavation, were either crushed or leaking; none were found
intact. With the passage of time, drums that were once intact
would too begin to decay and leak. Sampling of the excavated
drums indicated the presence of hazardous waste materials. These
drums, thus, constitute the primary source of contamination and
risk at the landfill site. Their removal and disposal is
essential for continued protection of human health and the
environment in the vicinity of the site. The estimated cost of
the drum removal is $ 145,000.
Another inquiry concerned identification of the locations of the
drums and the possibility for residual contamination following
the removal.
Response: The locations of the drums were determined based on
magnetic and electromagnetic geophysical studies, extensive test
pit excavation, and testimony submitted before the New Jersey
Grand Jury regarding drum disposal operations at the landfill.
It is estimated that between 50 and 150 drums remain buried
within the wastefill area. These will be removed from the
wastefill along with any visibly-contaminated areas adjacent to
the drums. Any residual contamination would be addressed through
an intensive ground water, surface waters and stream sediment
sampling and monitoring program. In addition, because of the
potential for residual contamination, the preferred alternative
includes closing of the landfill with a NJDEP Solid Waste
Landfill Cap.
Leachate Management
The question was raised as to why the leachate collection and
treatment system would not be installed during the remedial
action phase.
Response: Because few conclusions have been made from the
remedial investigation regarding ground water, surface waters and
stream sediments, additional sampling and monitoring programs for
these media are necessary. It was felt that the determination
involving the leachate management system would best be deferred
until after the cap is in place and the results of the sampling
and monitoring are known. If the results of the sampling and
monitoring indicate the need for a leachate management system,
such a system could be installed through the existing wastefill
cap. It is hoped, however, that significant reductions in the
generation of leachate will result from placement of the landfill
cap.
-------
A resident inquired about whether other alternatives to contain
the landfill leachate were considered.
Response: The installation of a slurry wall located between the
wastefill and the South River was considered within the FS. It
was found, however, that due to the tidally-influenced South
River's proximity to wastefill, such an alternative would not be
technically feasible. Landfill leachate would be better
addressed through pumping.
A question was raised regarding the location(s) to which the
leachate would be pumped.
Response: The leachate could be pumped and treated to an
acceptable level for discharge to the river or nearby sewage
treatment plant, or simply transported by truck to an industrial
treatment plant. These options, and possibly others, will be
evaluated by a number of standard criteria, if it is determined
that management of the leachate is necessary.
Another commenter inquired about the costs associated with a
leachate collection and treatment system.
Response: The estimated capital costs associated with collection
of the leachate is $ 75,700. Annual operation and maintenance
and treatment costs are estimated to average $ 320,700.
Another inquiry concerned the components of the sampling and
monitoring program.
Response: Samples will be collected for analysis from a variety
of locations including surface waters, visible leachate seeps,
stream sediments and groundwater monitoring wells installed
within the shallow and deep aquifers. Additional tests will also
be performed to determine the hydraulic connection between the
aquifers, and the groundwater flow and vertical and horizontal
gradients within the deep aquifer. Data from these activities
will be used to determine the need for a leachate management
system and will be made available for public review at the NJDEP
offices.
Gas Management System
The suggestion was made that NJDEP consider piping the methane
gas emissions from the wastefill for use as fuel in nearby Perth
Amboy (as is being done at the Edgeboro Landfill).
Response: If it is determined that an active system is
necessary, the suggestion may be a consideration upon reopening
this record of decision. However, a study would need to be
conducted to determine if the gas is of the required quality.
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One commenter questioned the differences between an active and
passive gas management system.
Response: The passive gas management system would involve the
placement of perforated piping within the surface of the
wastefill to allow for the natural passage of gas emissions to
the atmosphere without treatment. Gas vents will be provided
through the proposed cap. The active system uses mechanical
devices to draw gasses from the wastefill. This system would
consist of perforated piping placed into the wastefill. The
piping would be ducted to a collection system which would consist
of fans, valves and a flare to collect and burn the gaseous
emissions.
Liner Systems
One resident inquired about the life span of clay and synthetic
liners and the decision to use a synthetic liner at the landfill.
Response: The life span of the two types of liners are
comparable. Based on the topography of the landfill which is
nearly flat, it was determined that a synthetic as opposed to a
clay liner system was the more appropriate alternative.
Variations to the Proposed Alternatives
A commenter questioned the absence of a storm water control
system under Alternative 2, Drum Removal and Soil Cover.
Response: The soil cover system proposed under Alternative 2
would be constructed to minimize erosion from storm water and
infiltration by means of grading in conjunction with revegetation
of the cap. Both are used to modify and stabilize the site
surface. Revegetation includes seeding, fertilizing and watering
the site until vegetation is established.
Ground Water Concerns
One commenter wanted to clarify the fact that the Borough of
Sayreville does indeed take water from the deep Farrington Sands
aquifer and the South River.
Response: The Borough of Sayreville draws water from wells
located within the Old Bridge aquifer (located in the vicinity of
the site) and from the South River, above the landfill site. The
aquifers beneath the site, however, are designated as suitable
for drinking water sources (GW-2).
Surface Water Concerns
The question was raised regarding the results of the
investigation of the surface waters and stream sediments.
«
.-6
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Response: Results of these investigations identfied levels of
chlorides and total dissolved solids (TOS) exceeding New Jersey
Surface Water Quality Standards (NJSWQSs) for fresh water streams
in Duck and Pond Creeks. In addition, analyses of samples from
Duck and Pond Creeks at all locations detected levels of lead,
cadmium and ammonia exceeding fresh water NJSWQSs.
Concentrations of the following inorganics were detected in
stream sediments at levels exceeding NJDEP Interim Soil Action
Levels (ISALs): arsenic, cadmium, chromium, copper, lead, silver
and zinc (in Pond Creek); and arsenic, 4,4'-DDD, chromium and
silver (in Duck Creek). Levels of arsenic, mercury, selenium and
zinc were also detected in samples collected from the South River
exceeding ISALs. In addition, concentrations of total base
neutral compounds were above ISALs in several samples from Pond
Creek.
While the placement of the cap on the landfill is intended to
minimize future impacts to surface waters and stream sediments by
controlling the source of contamination, continued monitoring of
surface waters and stream sediments will be conducted. These
media will be addressed in a subsequent decision document if it
is determined that additional action is necessary.
Nature and Extent of Waste Area
One resident stated that there are some areas where wastes were
disposed of that lie outside the landfill property boundary. The
commenter inquired about the area to be addressed by the remedy.
Response: The cap, as proposed, will occupy the entire area
covered by the wastefill (beyond the landfill property boundary).
Another commenter questionned whether the landfill overlaps with
any meadowlands, tidelands, wetlands or riparian lands of the
State of New Jersey.
Response: Portions of the site lie within the tidal wetlands of
the South River and the Federal Emergency Management Agency's
500-year floodplain (tidal and riverine). In addition, the site
is located within the coastal zone as designated by the State of
New Jersey. As a result, additional studies will be required
including a wetlands delineation and assessment, a floodplain
assessment and a formal determination of consistency with
applicable policies of New Jersey's Coastal Management Program.
This additional work will be performed during remedial design.
Risk Assessment Clarifications
The question was raised as to why $ 16/516,600. must be spent to
address a site wbere the risks were determined to be minimal.
-------
Response: The Endangennent Assessment conducted for the site
revealed unnacceptable risks associated with allowing the
landfill to remain in its current state. Therefore, further
action was determined to be warranted. The Proposed Plan
includes excavation of the remaining drums which would remove
both the primary source of contamination and risk at the site.
In addition, the landfill will be capped to reduce the generation
of leachate and the potential for further degradation of the
surrounding media. In addition, although not quanitified, there
exists a risk to users of the shallow ground water aquifer. This
aquifer (and the deeper Farrington aquifer) are currently
designated as suitable for drinking water sources. It has been
shown that contamination from the landfill has impacted the
quality of the shallow aquifer. Sampling results in the aquifer
indicated that health-based levels were exceeded for benzene,
cadmium, chromium and nickel. To reduce the continued migration
of contamination from the landfill, and thus reduce the potential
future risks to users of the shallow aquifer, some form of
containment of the landfill is required.
General Cost Concerns
One resident inquired about the total cost of the preferred
alternative.
Response: Including costs associated with a passive gas
management system, the total present worth cost of the preferred
alternative is an estimated $ 16,516,600. Estimated O&M costs
will differ over the years as follows: $ 746,400 per year (year
1) ; $ 431,800 per year (years 2-5); and $ 354,600 per year
(years 6 - 30) .
Another comment questionned whether this plan, if implemented,
would be a burden on taxpayers within the Borough of Sayreville.
Response: The Borough of Sayreville has been linked to the
illegal disposal operations at the Sayreville Landfill. Thus,
the Borough was identified as a PRP and will be held liable for
cleanup costs under State and Federal laws. Although all PRPs
are responsible for the full cost of cleanup, cleanup costs are
often shared with other PRPs for the site. EPA and NJDEP do not
have any control over tax decisions of the Borough of Sayreville.
An inquiry was made regarding costs incurred to date on the
project.
Response: To date, NJDEP has spent approximately $ 925,000.
on the RI/FS for the project. The investigation incuded the
installation of a number of ground water monitoring wells,
sampling and analysis of the various media, and extensive test
pit excavation. The RI/FS work plan, located in the public
repositories for the site, provides more detail on the work
" 8 '
-------
performed. The public repositories for the site are located at
the Sayreville Borough Hall and Public Free Library, the
Middlesex County Health Department in North Brunswick, and the
NJDEP offices in Trenton. Additional cost documentation is
available for review at the NJDEP offices. EPA has also incurred
costs in its oversight of the project.
Potentially Responsible Parties
One commenter inquired about who is responsible for generating
the hazardous wastes located at the landfill.
Response: Information related to the liabilities of specific
parties can be found at the offices of NJDEP.
Another commenter inquired as to whom from the Borough was
responsible for accepting the wastes. Also, they questioned the
ownership of the landfill.
Response: Although the Borough operated the landfill, the owner
was Quigley Co., Inc. at the time the landfill was operated. The
current owner of the landfill is Pfizer Inc. See also final
comment of this section.
An inquiry concerned how the site was discovered.
Response: A confidential informant notified the New Jersey
Criminal Justice Department of the illegal operations at the
landfill.
A resident inquired about who will undertake the cleanup of the
landfill.
Response: Under close supervision by the NJDEP, the PRPs may
decide to clean up the site as outlined in this decision
document. Otherwise, NJDEP, in conjuction with the United States
Environmental Protection Agency (EPA), will perform the cleanup
using Federal and State monies. The EPA and NJDEP will then seek
to recover their respective cleanup costs from the PRPs.
One commenter responded to a statement made during the meeting
concerning the belief that a municipal employee had been
convicted in connection with the dumping of wastes at the
landfill in the 1970s. To correct the record/ he stated that he
was familiar with the Grand Jury transcripts through his work on
prior investigations and knew categorically that no municipal
employee was ever convicted of any illegal dumping. To continue,
he maintained that, in fact, municipal employees cooperated with
the Grand Jury to provide evidence in that investigation. The
evidence was brought to bear and the parties who were convicted
were a company known as Vamp Chemical Resources, one of its
principals, and, he believed, one of its employees. Finally, he
-------
stated that, in actuality, the state found no cause of action to
prosecute any employee of the Borough of Sayreville.
Comparison of the 1979 Landfill Closure with the Preferred
Alternative
One commenter inquired about the differences between the 1979
closure of the landfill and the preferred alternative.
Response: The primary difference between the two closures
concerns the type of cover. The 1979 cover consisted of one foot
of clay on the landfill side slopes covered by one foot of soil
capable of supporting vegetation. The preferred alternative
calls for a cap composed of the following: (1) a vegetative top
layer that would minimize erosion and act as a buffer to the
underlying layers, (2) a middle drainage layer that allows for
the drainage and runoff of any infiltrating storm water so that
there would be no accumulation of standing water on the
impermeable layer, and (3) an impermeable layer (a 40-mil liner
made of geosynthetic material or another of similar demonstrated
performance).
Another commenter inquired about the state of the existing
landfill cover and the party responsible for its maintenance.
Response: Site inspections have revealed that the 1979 closure
had not been properly completed. The existing vegetative growth
and cover over the landfill has eroded in many areas exposing
wastes and fails to significantly impede the release of fugitive
dust or landfill gas emissions. NJDEP considers both the
landfill operator and property owner liable for the maintenance
of the landfill cover.
Preferred Alternative Implementation Period
One commenter inquired about the time frame for construction of
the cap and conduct of further sampling and monitoring programs.
Response: It will take the NJDEP an estimated two years to
prepare the design for the landfill cap and another two years to
implement the remedy. As for the additional sampling and
monitoring programs, they will begin as soon as possible within
remedial design.
Future Land Use and Access Restrictions
A resident inquired about whether the site could potentially be
used again.
Response: The preferred alternative calls for the establishment
of appropriate deed restrictions to prevent future use of the
site.
10
-------
Another commenter inquired about the existence of fencing at the
site and whether cleanup could proceed if fencing was erected
prior to construction of the remedy.
Response: Fencing of the site is a componet of the preferred
alternative. However, currently, there are no plans concerning
the timing of construction of the fencing at the site. "No-
trespassing" signs were posted at the entrances of the landfill
in response to concerns raised by the Borough of Sayreville. In
addition, piles of dirt were placed over former access roads to
further restrict access to the landfill. The need to make
construction of the fencing a priority during remedial design
will be evaluated by NJDEP and EPA.
11
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SAYREVILLE ENVIRONMENTAL COMMISSION
167 MAI'S STREET
SAYREYILLE. N.J. OS572
August 23, 1990
Grace L. Singer, Chief
Bureau of Community Relations
Div. of Hazardous Site Mitigation
N.J. Dept. of Environmental Protection
Re: Sayreville Landfill #3
Dear Ms. Singer:
The Environmental Commission wishes to have its comments
includes for the proposed remediation plan for Landfill *3. We
did net meet officially after the hearing, so therefore could
net core to a consensus on Plan A, B, etc., but a few. questions
arcse individually.
The first was fencing off the property. Is this being erected
nev? The plan mentions that risk assessment is highest for
children trespassing. As Sayreville's vacant land diminishes,
the cpen space at Landfill *3 becomes more attractive for dirt
tikes ar.c the like. Can cleanup work, continue if a fence is
erected beforehand?
A figure of $75,000 was mentioned as the capital expense for
instilling a leachate collection system. What is the total cost
for such a project? Our fear is that more barrels will be found.
Is this a possibility? Our feeling is vhy go back into the
landfill a third time if it can be avoided now.
As tc the passive/active methane control system; as far as ve can
recall there have never been any odor complaints on Landfill *3.
There is nev housing construction on Jernee Mill Road, but it is
still SODC distance avay. Has the landfill reached its peak
production cf methane (is there a way to calculate that)? Of
course, should the situation change (information on concentrations
of volatile organics) ve would opt for the active control system.
I would like to add that many thought it was a fine presentation
and a veil run meeting.
Thank you
Eloise Hansen
Chairperson
NATURAL RESOURCES « PROTECT THEM OR PERISH
-------
REMARKS OF THE HONORABLE JAMES E. MCGREEVEY
IN RESPONSE TO
RESULTS OF THE REMEDIAL INVESTIGATION/
FEASIBILITY STUDY AND PROPOSED
REMEDIATION AND CLEANUP PLAN
FOR THE
SAYERVILLE LANDFILL SUPERFUND SITE
SUPERFUND SITE #468
AUGUST 16, 1990
BOROUGH OF SAYERVILLE
MIDDLESEX COUNTY, NEW JERSEY
-------
Good evening, and thank you for this opportunity to testify.
I aw 01m McGreevey, Assemblyman for the 19th Legislative
District. I represent the Middlesex communities of Perth Amboy.
South Amboy. South River, Hoodbrldge, and Sayervllle.
I have read the Department of Environmental Protection's (DEP)
Proposed Plan for the Cleanup of the Sayervllle Landfill Superfund
Site, and wish to lend my support to the general direction of the
Department's proposal for this cleanup operation.
Since last March, I have been 1n touch with various DEP officials
about the need to protect Sayervllie's water supply wells from
contamination from this site and others. Assistant Commissioner John
Trela, 1n particular, has been especially helpful In explaining the
hazardous waste problems of our area and DEP's current activities to
address those problems.
I am satisfied that DEP will address the major environmental
problems associated with this site by removing drums and putting a
solid waste cap and stormwater management system over the site. I am
nevertheless anxious about several aspects of the proposed plan.
No one In Sayervllle could be completely happy with the proposed
plan for Superfund Site #468 If only because so many of the
pollutants currently on the site will be left on site after cleanup
operations are terminated. These Include pollutants that are
contained In the general municipal solid waste stream.
Kithout remediation measures that both contain and treat
pollution that may emanate from the site In the future, the site will
remain a permanent threat to the Alluvial/Cape May and Farrlngton
Sani Aquifers as well as to the surface waters of Pond Creek and Duck
Creek.
DEP's Remedial Investigation and. Feasibility Study for the site
found that the wasteful's leachate contains volatile organic
compounds, pesticides, and metals. Air emissions from the site could.
reasonably be expected to contain volatile organic compounds as
well. Soils In and around the site contain excessively high levels
of organic compounds and metals. Groundwater samples In the vicinity
of the site contain levels of cadmium, chromium, benzene, and
ch'lorobenzene.
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Page 2
McGreevey - Sayervllle Site 468
August 16, 1990
I think It Is reasonable to conclude that Site #468 is a threat
to our environment.
For this reason, I would call upon DEP to give further
consideration to the need for a leachate collection and treatment
system at the site or at least to develop a clearer and more detailed
plan for determining whether such a system is needed at the site in
the future.
I am concerned that materials In the wastefill will begin to
decompose more rapidly than they would if this site had a
state-of-the-art landfill liner to prevent leaching into ground and
surface waters. It is my understanding that the microbes and
bacteria normally found in large numbers in wetlands area such as
those beneath the wastefill will actively breakdown the materials 1n
the wastefill. If that is true, the current absence of unacceptable
levels of hazardous chemicals in the waters around the site may be a
short-lived phenomenon. With time, these pollutants could appear in
excessive levels in leachate from the site.
If DE? determines that the leachate collection system should not
be Included in the initial phase of this remediation, I would
strongly urge you to put in place a comprehensive ground and surface
water monitoring system as soon as possible and and that the results
of the monitoring be made public on a regular basis.
I would also urge all of the Responsible Parties and Potentially
Responsible Parties, . to
contribute to this aspect of the cleanup project.
It Is essential that a decision on leachate collection and
treatment be made sooner rather than later. While the proposed plan
calls for a decision document for the leachate system based on
groundwater monitoring results, It appears that the close proximity
of Site #468 to surface water bodies and to critical aquifers
warrants expedited action on this aspect of the cleanup project. It
would be helpful 1f a specific date could be established for the
completion of the groundwater analysis.
Finally, through my*.discussions with DEP and legislative staff, I
have learned that the remedial on .of this site will probably take
four years f/om th: di'. -:n •• vMrt'. the design phase begins. The
j~,t~* nksra rrsulrt fake 1 _ 1 ? uaarc Honpnrllnn nnon wetlandc
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Page 3
McGreevey - Sayerville Site 468
August 16, 1990
Issues.- The contract phase could tike an additional 8 months, and
construction could take a full-two years after the design and
contract phases are completed.
The length of time required to deal with the site is astounding,
given that this site is relatively easy to deal with in comparison
with other Superfund sites throughout our State.
I have asked the Office of Legislative Services to undertake a
comprehensive study of the site remediation process to determine how
the Legislature can assist our environmental officials in shortening
the time for remediation projects of this kind. In particular, I
want to ensure that the State Is devoting adequate resources to the
investigation, design and contract phases .of Superfund sites and
other hazardous waste sites that are not on the National Priority
List.
Once again, I am grateful for this opportunity to express my
views on your cleanup program and hope that I can assist you in
expediting this much needed cleanup.
-------
GOLDSHORE. WOLF & LEWIS
ATTORNEYS AT LAW
2683 MAIN STREET
LAWRENCEVILLE NEW JERSEY O6646
MARSHA WOLF
NIELSEN V LEWIS
ROBERT J CASH--
•NJ ANO
••NJ ANO
8»«S
84BS
(6091 696 I66O
FAX I6O»> 895-IO71
August 24, 1990
VIA MESSENGER
Neal Erody, Esq.
State cf New Jersey
NJDEP '
Office of Regulatory Services
401 E. State Street
CM 4C2
Tr enter., NJ 08625
.
Mr. Michael Burlingame
Site Manager
NJDEP
Division of Hazardous Site
Mitigation
CN-413
Trenton, NJ 08625-2902
Re: Proposed Remedial Action Plan and RI/FS
Sayreville Landfill III
Gentlemen :
Enclosed please find the Site Committee's comments concerning
(1) the final Remedial Investigation/Feasibility Study Reports?
and (2) the Proposed Remedial Action Plan dated July 26, 1990.
Should you .have any questions, please do not hesitate to
contact me or Dennis Farley.
Respectfully yours,
"
Nielsen V. Lewis
NVL'rer
Enc.
cc
Ms. Sharon Atkinson, USEPA
Joe McVeigh, Esq., USEPA
Site Committee -•
Dennis Farley
Fred C. Hart Associates, Inc.
-------
August 24, 1990
Neal Brody, Esq. Mr. Michael Burlingame
Office of Regulatory Services Site Manager
NJDEP NJDEP
410 East State Street Division of Hazardous Site
CN-402 Mitigation
Trenton, NJ 08625 CN-413
Trenton, NJ 08625-2902
Re: Proposed Remedial Action Plan And RZ/F8
Savreville Landfill III
Dear Mr. Brody and Mr. Burlingame:
Please accept the following comments on behalf of the
signatories to the Administrative Consent Order dated October 28,
1986 ("Site Committee") concerning (1) the final Remedial
Investigation/Feasibility Study ("RI/FS") Reports; and (2) the
Proposed Remedial Action Plan dated July 26, 1990 ("PRAP"), issued
by the Department of Environmental Protection ("DEP") for this
site. It is the understanding of the Site Committee that these
comments, as well as previous correspondence between DEP and the
Site Committee or its members, will be treated as part of the
administrative record and considered prior to issuance of a record
of decision ("ROD").
PROPOSED REMEDIAL ACTION PLAK
MCLAREN/HART COMMENTS
In a Memorandum dated August 24, 1990 to the Site Committee,
its technical consultant, McLaren/Hart, the successor to Fred C.
Hart Associates, Inc., has prepared comments on the PRAP
("Attachment 1"). The members of the Site Committee hereby adopt
and incorporate McLaren/Hart's comments in this letter as their
own.
ADDITIONAL COMMENTS
In addition to the Mclaren/Hart comments, the Site Committee
makes the following comments on the PRAP.
-------
Messrs. Neal Brody and Michael Burlingame
August 24, 1990
Page Two
Alternative 3 - DEP Solid Waste Closure
The preferred remedial action alternative chosen in the PRAP
is Alternative 3 (DEP Solid Waste Closure). The Site Committee
objects to Alternative 3 on the basis that it is an excessive and
unreasonable remedy which, in light of the limited public health
and environmental risks identified at this site is not cost
effective and not required to meet applicable or relevant and
appropriate requirements ("ARARs") or to protect public health and
the environment.
The Remedial Investigation (RI) Report and Feasibility Study
(FS) Report conclude that Sayreville Landfill III poses only
minimal health and environmental risks. They find that: (1) the
site has not significantly impacted the ground water, surface water
or surrounding sediments; (2) the water quality of the South River
and groundwater downgradient of the landfill is not significantly
impaired and poses no potential risk to human health; (3) no
remediation of surface water or groundwater is required; and
(4) potential health and environmental risks are minimal (e.g.. see
RI Report, pages ES-5, ES-6 and 9-8, and FS Report, pages ES-5, 1-
43, 2-2, 2-4 and 3-1). In effect, the only real potential human
health risk found is a theoretical risk to trespassers who dig down
beneath the present landfill soil cover and may be exposed to
buried materials if access to the landfill is not restricted.
As pointed out in McLaren/Hart's previous comments on the
draft FS Report, ingestion of soils by residents living on or near
the landfill is an unlikely and unrealistic exposure scenario.
There exist no residences on or in the immediate vicinity of the
landfill nor are there any plans for such residential development
known to the Site Committee. Such residential development is very
unlikely due to existing development restrictions contained in
present laws and regulations respecting floodplains, wetlands and
solid waste landfills. It is also unlikely due to practical
engineering considerations, such as the instability 'of landfills.
Even today, it should be noted that site access is prohibited by
posting and there is in place a soil cover varying in depth from
six inches to two feet over the plateau of the landfill, as well
as a clay cover on its slopes, providing considerable protection
against exposure of area residents to buried soils.
As previously noted in the Site Committee's May 2, 1990
comments on the draft RI Report, Sayreville Landfill III was closed
in 1979 pursuant to DEP's lanrJfill closure requirements at the
time. Those requirements included final grading, installation of
methane vents and drainage structures, and construction of a
modified landfill cover consisting of a vegetative soil cover on
the surface of the landfill -».nd a combined soil and clay cover on
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Messrs. Heal Brody and Michael Burlingame
August 24, 1990
Page Three
its side slopes. At the August 16, 1990 public meeting at Borough
Hall, DEP stated that this original closure of the landfill in 19^9
complied with DEP's requirements and was "state of the art" at the
time.
In view of the measures already taken in the original landfill
closure and the minimal degree of risks identified in the RI/FS,
it is readily apparent that current DEP solid waste closure
requirements should not be considered ARARs for Sayreville Landfill
III. Even if DEP's more stringent modern closure requirements are
relevant, the issue is whether they are appropriate in this case.
They do not appear appropriate in light of the minimal risks posed
at this site described in the RI/FS. Clearly, other simpler
remedial alternatives identified in the FS or otherwise readily
available for this site, in combination with the existing landfill
soil cover and proposed monitoring program, are appropriate closure
requirements fully capable of addressing the limited risks
identified at this site and protecting human health and the
environment. With the selection of drum removal, there is even
less reason to opt for the full landfill cap contemplated in
Alternative 3.
Alternative 3 - Active Methane Gas System Option
The Site Committee objects to inclusion of an active gas
treatment system option in the present ROD. There is no data in
the RI/FS or administrative record indicating that the landfill is
currently producing methane at any level of concern or justifying
selection of this costly and complicated remedial option at this
time. Nor has any engineering design or performance criteria been
identified to provide a basis for evaluating the data and need for
such a system. Given the data in the record showing no present
risks and the age and condition of the landfill, an active gas
treatment system is not indicated at this time and should not be
a remedial option selected in the.current ROD.
Instead, as detailed in McLaren/Hart's comments (Attachment
1) , the potential need for an active gas treatment system is more
appropriately treated as a separate operable unit. If a solid
waste cap is selected by DEP as. the remedy, the need for the active
gas system should be evaluated in a subsequent decision document
based on proper criteria and data collected in a gas monitoring
program implemented after construction of the cap (including a
passive gas system).
In short, it is the Site Committee's position that adoption
of the active gas treatment system in the present ROD would be
technically unjustified and inappropriate. Furthermore, the Site
Committee submits that it would be arbitrary< and fundamentally
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Messrs. Neal Brody and Michael Burlingame
August 24, 1990
Page Four
unfair to the Site Committee to adopt the extremely costly active
gas system in the ROD when the Committee does not even have the
benefit of a preliminary engineering design or performance criteria
for implementation of the active gas system option. Without this
basic information required to properly evaluate the reasonableness
of such an option, it would be unreasonable and unfair to ask the
Site Committee to consider a commitment to undertake the remedial
design and implementation work in the ROD.
Modified Alternative l - Drum Removal, Additional Soil Cover And
Institutional Controls
In its July 16, 199n comments on the draft FS Report,
McLaren/Hart recommended DEP's evaluation of a modified version of
the Alternative 1 "no action" remedy consisting of "no action"
combined with institutional controls, selective areas of soil cover
application to supplement and enhance the existing soil cap, and
removal of the buried drums.
The Site Committee reiterates its support for this remedial
alternative as a readily impleroentable and cost-effective remedy
which meets ARARs and protects public health and safety. This is
especially true taking into account that a substantial combination
clay and soil cover is already in place that enhances the
protection provided by this remedial approach. As pointed out in
FS Report, the landfill has been closed with a mixed soil and clay
cap pursuant to DEP requirements and subject to precipitation for
years. Since the landfill has not significantly impacted the local
environment to date, institutional controls, including site access
restrictions and a monitoring program, together with the removal
of drums, meets the FS objectives to protect public health and the
environment. This remedial alternative ensures that conditions
will not deteriorate to the point where they endanger public health
or the environment.
For all of the reasons expressed herein and previously, .the
Site Correittee submits that DEP should adopt this modified remedial
alternative as the final remedial plan in its ROD.
REMEDIAL INVESTIGATION REPORT
On May 2, 1990, the Site Committee submitted comments on the
draft RI Report dated March 20, 1990. On July 16, 1990, the Site
Committee submitted comments in response to comments on the RI
Report made by DEP and the United States Environmental Protection
Agency ("EPA") . A revised form of RI Report was issued on July 24,
1990. To the extent that the revised RI Report fails to
incorporate views expressed in the previoo*; comments of the Site
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Messrs. Neal Brody and Michael Burlingame
August 24, 1990
Page Five
Committee, or is inconsistent therewith, the Site Committee renews
its previous comments herein.
Additionally, the Site Committee has the following comments:
1. The RI Report's narrative description of the site is
inconsistent with the site drawings and inaccurate. As
shown on the drawings (e.g. see Figures 1.3 and 1.4),
part of the main wastefill located south of Pond Creek
occupies Block 58, Lot 1A (former site of Vamp Chemical
Resources, Inc.). Yet the narrative of the report does
not identify this property and its owners in its
description of the landfill site. According to recent
records of the municioal tax assessor, the owners of
Block 58, Lot 1A, are C.E. Laslo, J. Polak and T. Polak.
Consistent with this information and the FS Report (page
1-5) , the RI Report should be corrected to include
reference to this property and its owners as part of the
landfill site and future DEP reports should reflect this
information.
2. At page 1-3, the RI Report inaccurately states that
Sayreville Landfill III was denied a certificate of
registration. The October 7, 1971 Memorandum from James
K. Rankin of the Bureau of Navigation cited as authority
for this statement does not support it. Mr. Rankin's
Memorandum was only a recommendation that the certificate
of registration be denied in view of the State of New
Jersey's riparian interest in the landfill property.
His recommendation was not adopted by DEP. The RI Report
should be corrected to accurately reflect the landfill's
permitting history and future DEP reports should reflect
the landfill's permitted status.
3. The RI Report is internally inconsistent in its
findings regarding PCBs. At page 1-15, the report states
that PCEs were found on site ("northern portion of the
wastefill"). Elsewhere, it states that the PCBs were .
found at sampling stations located off site, including
a PCB found 25 to 27 feet beneath the surface in soils
at MW-13 (pages 7-1 and 7-13) and arochlor-1248 and
arochlcr-1260 in sediments at SED-14 (pages 3-23, 6-10),
the latter sampling station established to determine the
contribution of the DuPont outfall discharge to area
. contamination (page 6-3). Both of these sampling
stations are located upgradient of the site on the
opposite side of Pond Creek from the landfill. The RI
should be clarified as to the off-site location of the
PCBs detected and future DEP reports should be clear and
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Messrs. Ne.al Brody and Michael Burlingame
August 24, 1990
Page Six
accurate on this subject.
FEASIBILITY STUDY
On July 16, 1990, the Site Committee submitted comments on the
draft Feasibility Study ("FS") Report dated June 1990. A final
form of FS Report was issued on August 1, 1990. To the extent that
the final FS Report fails to incorporate the previous comments of
the Site Committee, or is inconsistent therewith, the Site
Committee renews those comments herein.
In addition, the following comments are provided:
1. Sayreville disagrees with speculation in the FS Report
that the prior closure of the landfill did not conform
to the first DEP-approved closure plan (1-12). No
documentation is cited in support of this statement.
This statement is inconsistent with the observation of
DEP at the August 16, 1990 public hearing concerning the
PRAP that the prior closure was proper (discussed
earlier).
According to Sayreville's information and investigation,
the original landfill closure conformed to the approved
closure plan. If the FS observation that soil cover is
less than two feet in some places is accurate, it is
likely that such conditions reflect the impacts of post-
closure activities at the site, such as the buried drum
excavations done in the early 1980's during the
DEP/Division of Criminal Justice investigation and
alleged post-closure dumping (see page 1-12). Another
example of post-closure activities was the 1978 trunk
sewer installation by the Middlesex County Utilities,
which on June 14, 1978, was cited by DEP for failure to
re-cover disrupted material and restore proper cover (see
letter of Walter Burshtin dated June 14, 1978, to Edward
Nyland, c/o George Harms Construction Company, appended
hereto as "Exhibit A"). Post-closure activities as a
potential explanation for thin cover and the presence of
waste material near the landfill surface should be
discussed in the RI/FS Reports. The locations of the
prior drum exca.vations and other potentially disruptive
post-closure construction and field activities at the
landfill should be plotted on maps. (The other members
of the Site Committee express no opinion as to this
comment by Sayreville).
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Messrs. Neal Brody and Michael Burlingame
August 24, 1990
Page Seven
2. The FS is inconsistent as to the number oi drums
sampled during the supplemental remedial investigation.
For example, at page 1-13, the FS reports that 12 drums
were sampled; at page 2-1, it reports that 10 drums were
sampled. These discrepancies should be resolved.
In general, DEP should review the RI and FS Reports for
internal inconsistencies that remain and require clarifications and
corrections as needed.
The Site Committee reserves the right to respond to DEP's
comments on the draft FS Report and Baseline Risk Assessment Report
which have not yet been made available to the Committee, as well
as to supplement these comments as appropriate.
CONCLUSION
Please accept these comments by the Site Committee and
McLaren/Hart in the spirit of cooperation to assist DEP and EPA in
their review and selection of a remedial plan for this site.
Nothing in these comments should be construed as an admission of
any legal responsibility, fault or liability on the part of the
Site Comir.ittee or any of its members.
Should you have any questions or wish to discuss any matters
raised in this letter, please do not hesitate to contact the Site
Committee representatives. Thank you for your careful
consideration of the views expressed herein.
Respectfully submitted,
Borough of Sayreville
Celotex Corporation
Chevron Chemical Company
Hercules Incorporated
Mobil Chemical Company
Pfizer Inc.
Ruetgers-Nease Chemical Company, Inc.
NVL:er
cc: Ms. Sharon Atkinson, USEPA
J.oe McVeigh, Esq., USEPA
Attachments
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glair of ftriu 3frrunj
DEPARTMENT OF ENVIRONMENTAL PROTECTION
• OUID WA.STC ADMINISTRATION
TRENTON. OM2S
I. TVLUTKI
June 14, 1978
Mr. Edward Nyland
c/o George Harms Construction Company, Inc.
Post Office Box 128
Pequannock, New Jersey 07440
'Dear Mr. Nyland:
RE: Disruption of Sayreville Boro SUDA under Middlesex County Sewage Authority
Contract J3G-B Splid Uaste Administration ID01219E
On June 28. 197? your Hrn subraitterf an application and an engineering design for
the disruption of. a portion of the Sayreville Borough SWOA.
On September 19, 1977 the Solld'l/aste Administration approved that design ar.J is-
sued a Certificate of Approved Registration and Design IDJ 1219E. ;
«
the commentary portion of your submission, under the heading of "Operations!
'an," paragraph number nine states, "No material will be stored on site, t-jt will
e properly re-depos1 ted, spread and covered Immediately in another location in
the landfill. Excavated areas will be filled with suitable fill material."
On March 31, 1978 and again on June 7, 1978 inspections of the site v:ere conducted
by Solid Uaste personnel. These inspections disclosed that disrupted rater'al had
not been properly rc-deposfted, spread, and covered, but ratner had just been left
in piles or, site. This constitutes a violation of N.J.A.C. 7:26-2.2.4 which is
punishable by a maximum penalty of $3,000 per day.
This excavated material must be properly re-deposited, spread, and covered by
\ 1978.
If you have any questions regarding this matter, please contact Andrew Knioclk Jr.
or John Castner, of my staff at (609) 292-7646 or (609) 292-0241.
Very truly yours,
Jalter Durshtin, P.E..P.P.
Chief, Engineering I Enforcement
Solid Uaste Administration
EXHIBIT
MI «i«t iroti • •
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ATTACHMENT 1
MEMORANDUM
To: Sayreville Landfill III Steering Committee
From: Michael A. Barbara
Dennis Farley
Re: Comments on Proposed Remedial Action Plan (PRAP)
Date: August 24, 1990
As you requested, McLaren/Hart has reviewed the PRAP for
the Sayreville Landfill III site prepared by N.7DEP. Based on
this review, our meeting with Mr. Michael Bnrlingame on August
15, 1990, and attendance at the Public Meeting on August 16.
1990, the following ma^or areas were identified for submission
of comments:
1. Incorporation of active methane gas system in
selected alternative
2. Configuration of NJDEP Solid Waste Cap
3. Monitoring
4. Alternate Remedial Implementation Approach for
the Record of Decision (ROD)
Each of these issues is discussed in detail below.
ACTIVE METHANE GAS SYSTEM
The proposed remedy for the site, Alternative 3 was
presented at the Public Meeting as having an estimated capital
cost of $6.6 million with an annual O&M cost of approximately
$1.25 million. The present worth analysis performed by NJDEP
resulted in a present worth value in excess of $44 million.
The summary table presented in the Feasibility Study (FS)
indicated a capital cost of approximately $4.2 million and a
present worth value of $13.6 million. The PRAP estimates
include capital expenditures for an active methane collection
system and an operation cost for that system of approximately
$900,000 per year. Clearly, the present worth analysis is
driven by the O&M costs associated with the active methane
system. Note that approximately $800,000 per year has been
allocated for a natural gas supply to fue*l the methane gas
flares.
No evidence has been entered into the Administrative
Record to indicate the need for the installation of an active
25 Independence Boulevard. Warren. NJ 07060 (201) 647-8111 FAX (201) 647-8162
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methane collection system. Discussions presented in the
Remedial Investigation on the findings of site investigations
do not present, any data which indicates that the landfill is
producing methane at a level to warrant any remediation.
Given the data presented in the Rl and the age and condition
of the landfill, it is not necessary to even suggest that site
conditions warrant the installation of such a system. Ax
such, to present an estimate which drives up the present valu*»
of the entire remedy by such a drastic amount without clearly
indicating the improbability of such a system being
implemented is misleading to the general public. In addition,
without a comprehensive predesign study, the design parameters
and associated capital and operation costs of the active gas
system are highly speculative, even for the FS phase of the
process. Accordingly, while it is possible that the data to
be collected in the future might support implementation of an
active gas system, there is no data in the Record that
justifies the inclusion of this option in the ROD at this
time. NJDEP acknowledged in the Public Meeting that the cost
estimate for the methane system is "worst case" and would
require additional engineering evaluation before the actual
concept design was accepted. [NOTE: Mr. Ed Putnam of NJDEP
incorrectly stated that the system included granular carbon
to treat VOCs and a flare. The system proposed and costed in
the FS does not include an activated carbon system (See FS at
Figure 3-5) .]
It would be appropriate and much more cost-effective to
stipulate that the cap be installed with passive gas vents
which are significantly less expensive than the active system
and do not reguire expensive maintenance and operational
costs. It is possible to install passive vents which are
easily converted to an active system, should future site
conditions indicate the need to do so. Before an active gas
system is considered, the specific purpose and standards
applicable to the system should be developed so that an
appropriate monitoring and contingency plan can be prepared.
Following the completion of the landfill cap, the newly-
installed passive vents should be periodically monitored in
conjunction with a perimeter methane survey to establish the
migration potential of the gas under actual closure
conditions.
In general, specific remedial actions should be
implemented only if lateral migration of gas caused by the
installation of the impermeable cap (and not relieved by the
passive system) result in dangerous levels beyond the landfill
boundary. Mr. Burlingame^informed us that the criteria for
implementing the active system will be an emission rate
provided by EPA in a guidance document dated June 15, 1989.
This document (OSWER Directive 9355.0-28) addresses the
control of emissions from air strippers installed to remove
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volatile organic compounds (VOCs) from aroundwater at
Superfund sites as a means of preventing ozone production.
This document states that sources "most in need of controls
are those with an actual emissions (sic) rate in excess of 3
pounds per hour (Ib/hr) or 15 lb/day...of total VOCs." These
levels are applied on a "facility" basis, which is defined as
"a contiguous piece of property under common ownership." The
guidance is referred to as being "suitable for VOC sources
from other vented extraction technigues (e.g., soil vapor
extraction) but not for area sources (e.g., soil excavation).
The ROD should clearly indicate that methane should not
be included in the VOC emission rate since "volatile organic
substances" are defined in N.J.A.C. 7:27-16.1 to specifically
exclude methane. Methane is typically excluded from VOC
standards since it is not photochemically reactive. Given the
age and size of the Sayreville site, it is highly unlikely
that the emission rate for non-methane VOCs will approach the
15 Ib/day level presented in the guidance. The guidance
stipulates that "at • minimum" the RI/FS should collect site-
specific data on estimated uncontrolled emissions,
consideration of health risks for both the no action and
implemented remedy scenarios, control alternatives and their
cost, ozone attainment status, and air ARARs. As a site-
specific program to address these data needs was not conducted
in the RI/FS process, this information would have to be
collected prior to implementation, most likely in a predesign
study following completion of the cap construction and
landfill gas monitoring program. This monitoring program
should encompass a long enough period to ensure the system
returns to some equilibrium following construction activities
and allows for seasonal variation. Since the guidance
document states that the threshold emission rate assumes
discharge at 24 hr operation for 365 days/yr, this monitorina
program should be at least one year in duration following
completion of construction before a valid decision can be
ir.a d e.
Mr. Putnam stated in the Public Meeting that the criteria
for evaluating the need for the active system would also
include a threshold level for methane (und*»r the hydrocarbon
emission reguirements). He referenced N.J.A.C. 7:26-17 et seg
following the meeting; we have been unable to find any
reference to methane emissions in that reference or any other
section of the New Jersey air pollution regulations.
Historically, NJDEP has required that methane vents at
sanitary landfills be handled as new sources requiring
permits. It is probable that since this is a CERCLA site, the
permit reguirements will be waived.
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SOLID HASTE CAP CONFIGURATION .
As presented in the PRAP. the selected alternative
incorporates the installation of a NJDEP Solid Waste Cap over
the wastefill area of the site. McLaren/Hart previously
prepared and submitted comments on the estimate prepared bv
Black & Veatch in the Feasibility Study. At that time, the
cost estimates presented were evaluated as being
unrealistical ly low and did not include major elements
associated with implementation. These comments also stated
that the selection of Alternative 3 did not take the existing
cover materials into account in the configuration of the cap.
In addition, the PS and the PRAP fail to account for the
problems associated with the installation of the cap on the
steep sideslopes of the fill. McLaren/Hart has previously
submitted comments which address the inappropriateness of thj?
Solid Waste Cap at the Sayreville site. The following
comments were prepared assuming selection of Alternative 3
(Solid Waste Cap) in the ROD.
McLaren/Hart has performed a preliminary engineering
evaluation of the cap configuration proposed in Alternative
3 of the FS (and selected in the Proposed Plan) and has
concluded that the maximum slope that the cap could be
installed on is 5H:1V (assuming a factor of safety of 1.5).
The topographic information presented in the FS indicates
sideslopes which are significantly steeper than 5:1.
Therefore, without significant regrading of the sideslopes,
it appears unlikely that the cap configuration presented for
Alternative 3 can be constructed on the existing sideslopes
without significant amoxmts of regrading or filling with clean
materials. Placement of fill at the toe of the landfill would
probably result in the disruption of wetland areas.
The proposed NJDEP Solid Waste Cap is based upon the
guidance criteria cited in the New Jersey Register (June 1,
1987). It should be noted that, to date, these criteria have
not been promulgated and no engineering design or performance
criteria exist in N.J.A.C. 7:26-2A.9. Based on this, numerous
configurations are available to meet the guidance criteria.
Jn order to properly define a cap configuration that is
appropriate for the Sayreville Landfill, a site-specific
predesign study must be conducted to address existing grade
conditions, degree of sideslopes, existing cover conditions,
and current slope stability. Absent this study and data, the
selection of a specific cap configuration for the Sayreville
Landfill is inappropriate and does not provide an adequate
mechanism for the selection of a cost-effective configuration
which meets the remedial objectives and the documented minimal
risks posed by the site in its current condition.
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Alternative configurations have been accepted by NJDF.P
for cappinq of solid waste landfills which incorporate
independent designs for "plateau" areas and sides!ores. Given
the difficulties associated with the installation of synthetic
membranes on sideslopes and the fact that clay cover materials
have previously been placed on the slopes, the most cost-
effective solution for the site cannot, be selected without
more site-specific information. It is likely that a
combination of independent designs for sideslopes and plateau?
will produce the most cost-effective configuration for the
site. Mr. Putnam stated in the Public Meeting that alternate
configurations would be evaluated; he also responded favorably
to a question on whether NJDEP might consider issuing a
performance standard rather than a fixed configuration for the
cap.
The predesign study would evaluate the conditions under
which alternative cap configurations could provide compliance
with NJDEP criteria. For example, an alternative, more cost-
effective configuration to the NJDEP Solid Waste Cap described
in the FS should be considered which incorporates the
following elements:
- 6" topsoil layer
- 12" general fill
- non-woven geotextile
- geonet drainage layer
- 40 mi 1 HDPE geomembrane
- 6" granular fill layer
- existing cover soils
It is estimated that a cap of this configuration (illustrated
in Figure 1) could be constructed on the plateau area for
approximately 35 percent less cost than the proposed NJDEP
Solid Waste Cap. Increasing the thickness of the general fill
layer to provide an increased level of protection against
frost would still allow a savings of approximately 30 percent
over the design presented in the PRAP and FS.
MONITORING
The PRAP correctly defers the decision to install
leachate collection and/or treatment systems at the Sayreville
Landfill to a "subsequent decision document". No information
is presented in the PRAP which defines the criteria under
which leachate collection might be deemed necessary.
McLaren/Hart previously submitted comments to NJDEP which
addressed the inadequacy of the leachate collection system
proposed in the FS even if, although it appears to be
unlikely, a leachate collection system, is required in the
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future. As the cost, to .implement an adequate collection and
treatment system will most likely be far in excess of that
presented in the FS, NJDEP should carefully evaluate the
conditions under which this aspect of remediation might be
implemented.
Since the landfill in its current condition has not
impacted groundwater downgradient of the site and has not
significantly impacted the shallow groundwater beneath the
site, it is unlikely that post-remedial conditions will
warrant the installation of a leachate control system. AP
this decision will be made after issuance of the ROD, the
criteria under which this evaluation is made will have
significant impacts on the long-term costs associated with
this remedy. Mr. Burlingame informed us that the groundwater
monitoring program for this site will include three additional
wells installed in the Farrington formation. Monitoring will
be implemented in the shallow and deep formations and compared
with upgradient levels to ascertain whether or not. the
landfill is having a statistically significant effect on
groundwater.
NJDEP acknowledged in the Public Meeting that, the issue
of groundwater monitoring in the area of the site is "complex"
and would require careful evaluation to develop th»» monitoring
plan and criteria for implementing a leachate control system.
Mr. Putnam stated that the incorporation of leachate controls,
if necessary, would be handled as another Operable Unit and
would necessitate re-opening the ROD. He also mentioned in
passing that a "pumping test" would be performed to evaluate
the hydraulic connection between the Farrington formation and
the shallow groundwater. This was the first mention of such
a test up to this point in the process.
RECOMMENDED ALTERNATIVE REMEDIAL IMPLEMENTATION^APPROACH
Given the uncertain nature of the need and/or the
configuration of the various elements of the selected remedy,
the following approach to implementation of Alternative 3 is
a 1ogical, cost-effective process:
1. A ROD should be developed which calls for the
implementation of the cap (with a passive gas system) as an
Operable Unit. The present worth cost analysis should not
include costs for the active gas and leachate control systems
which are highly speculative, and by NJDEP's own admission,
not likely to be required. McLaren/Hart agrees with the
approach taken by NJDEP in the PRAP and the Public Meeting to
address the leachate control system as a separate Operable
Unit. The implementation of the active gas system, if
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demonstrated to be necessary by future site conditions, should
be addressed in a subsequent, separate Operable Unit.
2. The ROD should identify the need to complete
comprehensive monitoring of the landfill gas conditions for
a period of at least one year following completion of
construction. In addition, the criteria for determining the
need for implementing the active gas system as a separate
Operable Unit should be identified at this time.
3. An appropriate groundwat.er monitoring program
should be developed which specifically addresses the
conditions in the shallow groxmdwater. This monitoring
program should be developed with a sufficient degree of
flexibility so that the freguency, duration, a'nd analytes can
be evaluated and modified to meet site-specific conditions on
an annual basis.
4. The ROD should clearly state that the
implementation of either the active gas or the leachate
collect! on syst em woti J d require engineering predesi gn studies.
These studies would evaluate site-specific conditions and
provide alternative analysis to determine the most appropriate
and cost-effective means of implementing the 'additional
Operable Units, if necessary.
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9C WC
SUiTC .4CC
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THEMTON. NJ O66C7 1296
(609; 3»? 2>OC
FACSIMILE (6C9 . 39J 7BS6
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HANNOCH WEISMAN
A PROFESSIONAL CORPORATION
COUNSELLORS AT LAW
* BECKER FARM ROAD
ROSELAND. NEW JERSEY O7O68-37B6
(tOO S3S-5300
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PLEASE REPLY TO:
P.O. BOX IO4O
NEWARK. NJ O7IOI-96I9
JOSEPH A
WRITER'S DIRECT LINE:
201-535-5503
43364-4
August 30, 1990
Neal Brody, Esquire
State of New Jersey
New Jersey Department of
Environmental Protection
Office of Regulatory Services
401 East State Street
CN 402
Trenton, New Jersey 08625
Michael Burlingane, Site Manager
New Jersey Department of
Environmental Protection
Division of Hazardous Site Mitigation
Bureau cf Site Management, Region I
401 East State Street - 6th Floor
CN 413
Trenton, New Jersey 08625
Re:
Proposed Remedial Action Plan and RI/FS
Savreville Landfill III
Gentlemen:
On behalf of Rhone-Poulenc, Inc., thank you once again
for .the extension of time to provide comments on the Final
Remedial Investigation/Feasibility Study Reports and the Proposed
Remedial Action Plan of July 26, 1990.
In the last two days we have formally joined the
Sayreville III Site Committee and have received a copy of its
comments transmitted to you by letter of August 24, 1990 of
Nielsen V. Lewis, Esquire. Please be advised that Rhone-Poulenc
joins in those comments as a member of the Site Committee and
urges your careful consideration of the views, therein expressed.
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HANNOCH WEISMAN
A PROFESSIONAL CORPORATION
Heal Brody, Esquire
Michael Burlingame, Site Manager
Page 2
Please make this letter and Rhone-Poulenc's joinder in
the aforementioned comments part of the administrative record.
Thank you for your consideration.
Respectfully yours,
JAH:sjf
Via Fax &
•U.S. Mail: Neal Brody, Esquire (609-984-3488)
Michael Burlingame, Site Manager (609-633-2360)
cc: Rhone-Poulenc, Inc.:
Christian S. Berry, Manager of H.S. & E.A.
William N. Farran, III, Esquire
Nielsen V. Lewis, Esquire
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NJDEF Responses to comments on the Proposed Plan and RI/FS,
Sayreville Landfill III, submitted by the Borough of Sayreville;
Celotex Corp.; Chevron Chemical Co.; Hercules, Inc.; Mobil
Chemical Co.; Pfizer Inc.; and Ruetgers-Nease Chemical Company,
Inc., dated August 24, 1990, to Michael Burlingame and Neal Brody
and comments on the same by Joseph A. Hoffman of Hannoch Weisman,
Attorneys for Rhone-Poulenc, Inc., dated August 30, 1990, to
same.
Proposed Plan
Additional Comments by the .Site Committee
Alternative 3 - PEP Solid Waste Closure
The Site Committee (Committee) objects to the selection of
Alternative 3, Drum Removal and Landfill Closure with a NJDEP
Solid Waste Cap, on the basis that, in light of the limited
public health and environmental risks posed by the site, the
preferred alternative is not cost-effective and not required to
meet ARARs or to protect public health and the environment.
Technical justification is presented in their comments for these
conclusions.
The necessity of a new, impermeable cap was evaluated in the FS
in accordance with the nine evaluation criteria from the NCP (and
not risks alone). The impermeable cap is required to meet EPA's
two threshold criteria: overall protection of human health and
the environment and compliance with ARARs. Currently, New Jersey
Safe Drinking Water Act (NJSDWA) MCLs and New Jersey Ambient
Water Quality Criteria (NJAWQC) are exceeded in the ground water
and surface waters, respectively. NJDEP Interim Soil Action
Levels are also exceeded in the sediment samples, which are the
appropriate "To Be Considered" criteria. Based on preliminary
calculations, ARARs for discharge to surface waters are also
exceeded at the site. Attached are two memoranda: (1) M.
Burlingame to I. Kropp, undated and (2) S. Kim to I. Kropp, dated
1/26/88. The later memorandum indicates that, based on
preliminary calculations, using flow rates presented in the RI,
the discharge of contaminatation in the landfill leachate (and
concurrently into the shallow aquifer) into the South River is
unacceptable.
Without some barrier to prevent the continued generation of
leachate, the potential for continued releases of contamination
from the wastefill will remain, and the attainment of ARARs in
the ground and surface waters, and the natural attenuation of
existing contamination in the stream sediments, will not be
possible.
The potential for future releases of more-elevated levels of
contamination will also not be mitigated without minimizing the
generation of leachate with an impermeable cap. Although
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geophysical surveys conducted during the remedial investigation,
along with extensive test pit excavation, have located areas
where drums of hazardous wastes are concentrated, the possibility
remains that there are other areas in the wastefill which contain
additional drums, contaminated materials or pockets of hazardous
liquids, which may continue to leach into the environment. As
the solid waste materials composing the wastefill degrade, their
ability to hold contaminants will diminish. Short of removing
the entire wastefill under Alternative 6, the next best
alternative involves the placement of an impermeable cap to
reduce the genera .on of leachate in the wastefill. Of those
alternatives which include impermeable liner systems, Alternative
3 is the most cost-effective.
The statement in this comment that the risks at the site are
minimal is contrary to the results of the Endangerment Assessment
conducted for the site. It was determined that for future
scenarios, the hazard indices for on-site residents exceeds one
(suggesting that non-carcinogenic effects may occur as a result
of site-related exposures). Adult and child on-site residents
exposed to soils have hazard indices (His) of five and eight,
respectively. A ground water HI of one should be added to each
of these, resulting in a HI of 9 for future children living on
the site. In soils, the bulk of risks is associated with
pesticides and in ground water, metals. For future on-site
residents, the lifetime excess cancer risk is 2 X 103, primarily
from dermal contact with pesticides in soil. The potential risks
to residents due to carcinogens at the site are greater than the
acceptable EPA risk range of 1 X 10"1 to 1 X 10*.
In addition, although not quanitified, there exists a risk to
users of the shallow ground water aquifer. This aquifer (and the
deep Farrington aquifer) are currently designated as suitable for
sources of drinking water. It has been shown that contamination
from the landfill has impacted the quality of the shallow
aquifer. Sampling results in the aquifer indicated that health-
based levels were exceeded for benzene, cadmium, chromium and
nickel. To reduce the continued migration of contamination from
the landfill, and thus reduce the potential future risks to users
of the shallow aquifer, some form of containment of the landfill
is required.
Since re-capping of the landfill has been selected as part of the
preferred alternative, the design and construction of the cap
will be performed in accordance with current state and federal
requirements (ARARs). These include the New Jersey Solid Waste
Regulations (NJAC 7:26) and RCRA Subtitle D requirements. The
current state-of-th.e-a.rt cap requires: (1) a vegetative top
layer that would minimize erosion and act as a buffer to the
underlying layers, (2) a middle drainage layer that allows for
the drainage and runoff of any infiltrating storm water so that
there would be no accumulation of standing water on the low-
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permeability layer, and (3) an impermeable layer (a 40-mil liner
made of geosynthetic material or another of similar demonstrated
performance).
In summary, NJDEP believes that the preferred alternative would
serve to protect human health and the environment by minimizing
the generation of leachate and potential for continued releases
from the wastefill. Alternative 3 also promotes cost-
effectiveness as it represents the least expensive of the capping
alternatives.
Alternative 3 - Active Methane Gas System Option
The Committee objects to the inclusion of an active gas treatment
system in the ROD. It is argued that there is no data in the
RI/FS or administrative record indicating that such a system
would be required. It is requested that the active gas treatment
system be treated as a separate operable unit and evaluated in a
subsequent decision document based on proper criteria and data
collected in a gas monitoring program implemented after
construction of the cap.
NJDEP agrees with this comment. The RI findings to date indicate
that gaseous emissions from the landfill are almost exclusively
methane. As a result, a passive gas collection system will be
required and installed as part of Alternative 3. However,
emissions from the passive system will be measured to determine
whether or not treatment of the gases is required. If treatment
of the gaseous emissions is found to be required, this ROD will
either be re-opened and modified to include the required
installation of an active gas treatment system, or a separate
decision document will be developed.
The regulations and guidance used to determine whether an active
gas treatment system is required refers primarily to non-methane
volatile organic emissions. Applicable or relevant and
appropriate requirements include New Jersey regulations on
volatile organic substances (NJAC 7:27-16), New Jersey toxic
substances rules (NJAC 7:26-17), Federal emission standards for
air pollutants (40 CFR 61), and Federal ambient air quality
standards (40 CFR 50, 53 and 61). Guidance presented in a
memorandum from EPA's Office of Emergency Response and the EPA
Office of Air Quality Planning and Standards, dated June 15, 1989
would also be considered. These include the emission limit of 15
pounds of volatile organic compounds per day within areas that
are nonattainment for ozone (i.e., all of New Jersey).
Modified Alternative 1 - Drum Removal. Additional Soil Cover and
Institutional Controls
The Committee proposes that this "modified" Alternative 1 be
selected as the preferred alternative. This prpposal is based on
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the conclusions that the landfill has already been closed
according to NJDEP requirements and has not impacted the local
environment. The Committee feels that this alternative will
ensure that conditions will not deteriorate to the point where
public health will be endangered.
NJDEP refers the Committee to the response above, concerning
their comments on Alternative 3. In addition, standards have
been exceeded for each of the various media investigated.
Subsequent site inspections have also revealed that closure of
the landfill,was not completed. The existing vegetative growth
and cover over the landfill has eroded in many areas exposing
wastes. It is believed that the landfill fails to significantly
impede the release of fugitive dust or gas emissions.
It was also requested in the Committee's comments on the FS
report that another alternative be presented which would be
equivalent to Alternative 2, Drum Removal and Soil Cover, but
require only patching of the existing cap, rather than the
placement of a new cover two-feet in thickness. Except for the
costs associated with each, the proposed alternative would not
differ substantially from Alternative 2. No matter which cap or
cover is selected, however, consideration will be given to
incorporating the existing soil cover materials into the proposed
NJDEP solid waste cap.
Remedial Investigation Report
The Site Committee has requested that their comments on the draft
RI report, dated March 20, 1990, and their responses to NJDEP and
EPA comments be renewed. In consideration of this, the following
attachments have been added to this response:
- Attachment A: Comments on the Draft RI Report, dated
March 20, 1990, to N. Brody, dated May 2, 1990, from the
Borough of Sayreville; Celotex Corp.; Chevron Chemical
Co.; Hercules, Inc.; Mobil Chemical Co.; and Ruetgers-
Nease Chemical Co., Inc.
- Attachment B: EPA and DEP comments on the Draft Remedial
Investigation Report, Sayreville Landfill III, Dated July
23, 1990, to Neal Brody and Michael Burlingame, from the
Borough of Sayreville; Celotex Corp.; Chevron Chemical
Co.; Hercules, Inc.; Mobil Chemical Co.; Pfizer Inc.; and
Ruetgers-Nease Chemical Co., Inc.
Specific comments on the final RI report were also submitted and
are answered below.
1. It is agreed that Block 58, Plot 1A, is part of the landfill
site. The owners of the property presently are C.E. Laslo, J.
Polak, and T. Polak. Figure 2 of the decision ^summary shows the
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rear of this property as part of the wastefill area of the
Sayreville Landfill.
2. The history presented on pages 1 - 3 of the RI report is
believed to be accurate. Further research has indicated that
although the Borough had a permit for waste disposal operations
at the landfill in July 1970, the permit expired on 6/30/71 (ref.
letter to the Mayor, from Arthur Price, NJDEP/BSWM, dated
3/19/71). Further expansion of the Sayreville Landfill was
denied by the NJDEP after expiration of the permit on 6/30/71.
3. Contrary to the Committee's comment, PCBs were detected on-
site in the stream sediment sample at location SE-2 (Arochlor
1260 at 3,173.5 ppb) taken from the northern portion of the
landfill.
Feasibility Study
The Site Committee has requested that their comments (dated July
16, 1990) on the draft FS report (and Risk Assessment report),
dated June 1990, be renewed. In addition, comments submitted by
the Hercules Corp., dated July 17, 1990, on the draft Risk
Assessment report, have not yet been formally addressed. In
consideration of this, the following attachments have been added
to this response:
- Attachment C: NJDEP Responses to Comments entitled,
Feasibility Study and Risk Assessment Reports, Sayreville
Landfill III by the Borough of Sayreville; Celotex Corp.;
Chevron Chemical Co.; Hercules, Inc.; Mobil Chemical Co.;
Pfizer Inc.; and Ruetgers-Nease Chemical Company, Inc., to
Neal Brody and Michael Burlingame, dated July 16, 1990.
- Attachment D: NJDEP Responses to Sayreville Landfill
III - Hercules, Inc.'s comments on Baseline Risk
Assessment, dated July 17, 1990, by John F. Lynch, Jr. of
Carpenter, Bennett & Morrissey.
1. NJDEP agrees that the Borough's plans for landfill closure
were accepted by NJDEP at the time they were submitted.
Numerous, post-closure inspections at the landfill, however,
revealed areas with inadequate cover and severe erosion of the
side slopes. The inspection reports from NJDEP files (by R.S.
Feehan, attached) show that these problems were not associated
with either the New Jersey Criminal Justice Investigation of the
western peninsula of the landfill, or the installation of the
sewer line along the eastern edge of the wastefill. The
Middlesex County Sewerage Authority was cited for placing
improper cover over the portions of the landfill which they had
disrupted. However, in view of the strict fines with which they
were threatened, NJDEP is dertain that these areas were
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subsequently covered properly.
2. The discrepancies have been clarified in the FS report
concerning the exploration and sampling of buried drums. A total
of 11 test pits were excavated during the Phase II RI and a total
of 10 drums were sampled and 2 soil samples were taken adjacent
to the drums (within the excavated test pits) .
Comments From M.A. Barbara and D. Farley of McLaren/Hart.
entitled Comments on Proposed Remedial Action Plan (PRAP1. dated
August 24. 1990. and Designated as Attachment 1
Active Methane Gas System
1. It is recommended that it would be much more appropriate and
cost-effective to stipulate that the cap be installed with
passive gas vents which could be converted to active gas vents
later, should conditions varrant the change. Before an active
gas system is installed, the specific purpose and standards for
the system should be developed so that an appropriate monitoring
and contingency plan can be prepared. Monitoring of the passive
vents is also recommended.
NJDEP agrees with the comment that a passive gas management
system be installed and monitored periodically to determine the
need for a treatment system. Cost estimates in the decision
summary of this document thus differ from those presented within
the Proposed Plan to provide for costs associated with a passive
gas management system vis-a-vis an active gas management system.
2. The NJDEP stated that EPA OSWER Directive 9355.0-28, dated
June 1989, would be used to determine if an active system is
required. The VOC emission rate specified in this Directive
excludes methane gasses. The decision document should clearly
indicate that methane should not be considered in this VOC
emission rate. The guidance also states that the threshold
emission rate assumes discharge at 24-hour operation for 365 days
per year. The monitoring program should, therefore, be conducted
for at least one year following completion of construction before
a decision can be made concerning the need for an active system.
NJDEP agrees that emission rates in the referenced Directive
exclude methane. The regulations and guidance used to determine
whether an active gas treatment system is required refer
primarily to non-methane volatile organic emissions. Applicable
or relevant and appropriate requirements include New Jersey
regulations on volatile organic substances (NJAC 7:27-16), New
Jersey toxic substances rules (NJAC 7:26-17), Federal emission
standards for air pollutants (40 CFR 61), and Federal ambient air
quality standards (40 CFR 50, 53 and 61), in addition to the
guidance presented in OSWER Directive 9355.0-28 from EPA Office
of Emergency Response and the EPA Office of Air Quality Planning
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and Standards,
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The need for sampling and monitoring and for appropriate studies
of ground water, surface waters and stream sediments was stated
in the Proposed Plan. A pump test has not specifically been
determined to be necessary as part of these "appropriate
studies". It was mentioned by NJDEP as an example of what
additional work might be required. A pump test of the lower
aquifer may very well be required as .the RI concluded that an
aquifer test of much greater magnitude and detail than that
conducted during the remedial investigation would be required to
assess whether significant vertical leakage from the landfill to
the deep Farrington aquifer is occurring at the site.
Recommended Alternative Remedial Implementation Approach
The commenters outline a four-step approach to implementation of
Alternative 3.
NJDEP believes that the responses previously provided to the
commenter's specific concerns above indicate our general
agreement with the commenter's approach.
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NEK JERSEY STATE DEPARTMENT OF ENVIRONMENTAL PROTECTION
Division of Water Resources
MEMORANDUM
TO; Superfund Coordinator Irene Kropp, Division of Vater Resources
THRU: Section Chief William Boehle, Industrial Permits Section
Supervising Er.v. Engineer RamamuntThy Pyarilal,
Industrial Perr.its Secf'on
FROM; Senior Er.v. Er.cineer StecherfTfir., Industrial Permits Section
SVBJEC7: Savreville Landfill Discharce to the South P.iver
DATE:
This Sertirr. has reviewed the available information included in
Michael Burlir.gar.e' s memo addressed to you regarding the..
discharge of ccntar.ineted ground water from Sayreville Landfill
to the South River and has determined that the discharge is not
acceptable due to the high level of Arjnonia, BODS, COD,
Benzene, Chlorcbenzene, Toluene, Ethylbenzene, Phenol, and
Pesticides concentrations and the lack of bioassay toxicity
infcrr.aticn.
If you have any cuestion reaarding this matter, please contact me
at :-O;CT.
WQMlB5:esr
-------
£tfitt of Jitto
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
403 E. Siate Si.. CN 413, Titmon. NJ. 08625
(609) 984-2902
Anthony J. Frro
Director
TO: Irene Kropp, Superfund Coordinator
Division of Water Resources
FROM: »Xik.e Burllngaae, Site Manager
Bureau of Site Management
El: Sayreville Landfill Discharge to the South River
The Remedial Investigation of the Sayreville Landfill NPL Site is almost
complete and the consultant is about to begin the Feasibility Study. One of
the possible environmental impacts that has been identified by the
geohydiologicfil studies is the discharge of leachate under the landfill,
irto the South River. It is herewith requested that DWR determine whether
this discharge to the South River would be in violation of dischange limits,
if considered as a point source.
Attached are both the analytical results for groundwater under the Landfill
and results of aurface water taken from the South River. Prior to assembling
this information, I net vlth Steve Kim (Industrial Permits) to determine
what information would be required for this problem. The following
summarizes the data attached to this memorandum:
1. .Groundwater Analytical Data end Flow Rates: Partial Priority
Pollutant results are presented on Sheets GW-1 and GV-2 for the
Wasteful and Alluvial aquifers under the Landfill (inorganic
results will be provided separately). The estimated groundwater flow
rates from the aquifers under the Landfill, discharging to the South
River, are 2,200 gpd and 5,000 gpd for the alluvial and wastefill
aquifers, respectively.
2. Surface Vater and Sediment Data: This data is presented for various
points around the Landfill on Sheets SW-1 to ?«-*. Sampling locations
are presented oc Fig. 6.2. The Consultant's analyses of the surface
water and sediment data are presented on pages 6*1 to 6-9. in addition
to historical water quality data on the South River. Not* that the
South River Is tidal and flows north.
3. Flov Rate of Receiving Str«ac: Pages 6-13 and 6-U present the
estimated flow rates of the South River, adjacent to the Landfill.
These are 140-235 cfs for July 10, 1967 (arbitrary date) and 6.5 cfs
for a 10 year lov-flw*
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If you require further information, please contact me as toon AC possible at
633-0767. Also, after a preliminary review of the data, if the discharge
clearly appears unacceptable or acceptable, please let me know.
HS227:bltt
Attachnents
cc. K. Kur.ze, BEERA
Dv Kaplan, DWR
file: Savreville Landfill B5
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SAMPLING LOCATIONS
n««
-------
November 20, 1937
Revision No. 00
6.0 SURFACE-VATZR INVESTIGATION
€.1 General
The Sayreville Landfill lies vithin the South River Drainage Basin.
The drainage area above thr landfill site is approximately 130 square Biles
(FEKA, 1987 (13)]. In the immediate vicinity, the surface-water hydrology
is highly conplex due to tidal influences.
Significant surface-viler bodies in the vicinity of the site include:
Pond Creek at the northern and northwestern perimeters of the vastefill,
draining into the South River to the vest of the vastefill; Duck Creek at
the southern and southwestern perimeters of the vastefill, draining into
the South River to the southwest of the vastefill; and Vilbur Creek south
of the landfill site, draining into the South River. A discharge from the
Dupont Chemical Plant also drains into Pond Creek near the SV/SE-3 sampling
location. The priaary off-site surface-water body in the vicinity of the
site is the South River vhich receives drainage from the northern,
.northwestern, southern, and southwestern portions of the landfill site.
The South River is a major tributary to the Raritan River and forms the
vestern boundary for the study.
The Federal Xaergency Management Agency (FEHA) has sponsored Flood
Insurance Studies to develop flood-hazard data for low-lying communities.
These studies attempt to quantify potential vater-level increases due to
both riverine and tidal influences and to estimate the degree of flood
plain inundation. The study conducted for the Borough of Sayreville (FEHA,
198? (13)] indicates base flood elevations for a 100-year (average
recurrence interval) event of 4-8.6 (non-tidal) and 410.1 (tidal) feet MSL.
t-1
-------
November 20, 1987
Revision No. 00
Discussions vith the NJDEP Bureau ef Flood Plain Kanage»ent suggest that
the tidal 100-year flood elevation should be Increased to +12.1 feet.
Figure 6.1 illustrates the FEMA-delineated boundaries for the 100- and
500-year flood levels for the region containing the Sayreville Landfill.
It should be noted that vMle the floodvay fringe encompasses all of the
Sayreville Landfill, the topographic Bap indicates that the surface of nost
of the vastefill between Fond Creek and Duck Creek vould reaain above the
100-year flood elevation. However, the potential for vastefill erosion
vould remain since floodwa;ers vould contact the vastefill on three sides.
In order to determine vhether constituents from the vastefill have
entered the surface waters on or off-site, a sampling prograt vas developed
and implemented. Eleven (11) surface-vater and sediment sanples vere
collected. Figure 6.2 illustrates the 11 sampling locations. All samples
vere subsitted to the analytical laboratory for analyses. The locations
which vere sampled between February 12 and 16, 1987 include:
o SV/SE-1: upstream on Fond Creek, northeast of the landfill.
o 5V/SE-2: en Fond Creek, north edge of the vastefill.
o SV/SE-3: on Fond Creek, northwest edge ef the vastefill.
e SV/SE-4: downstream1 en Fond Creek, vest edge ef the landfill.
o SV/SE-5: in swampy area, tast ef the vastefill.
o SV/SE-6: headwaters of Duck Creek, aoutheast of the vastefill.
o SV/SE-7: on Duck Creek, south tdge ef the vastefill.
o SV/SE-8: downstream on Duck Creek, southwest edge of the
vastefill.
-------
November 20, 1987
Revision No. 00
9 '
f
o SV/SE-9: upstream on South River on Wilbur Creek, southvest bf«
the landfill.
o SV/SE-10: South River dovnstreaa of site.
o 5V/5E-21: South River dovnstreaa of site.
6.2 SURfACE-VATEF OUALTTT
6.2.1 Previous Investigation
A Halted sampling program of South River vater and sediment vas
performed on July 29, 1981 by the Nev Jersey Departaent of Environmental .
Protection. The vater aid sediment samples vere analyzed for volatile
V.x"
orgar.ics and pesticides (kepone and tirex). Less*than-values vere reported
for five sites vhere river vater and river sediments vere sampled.
The only gauging station in the vicinity of the site is the U.S.
Geological Survey (USCS) gauge located six Biles upstream of the site on
the South River at the Duhernal Dam near Old Bridge. Records for this
gauge are coaplete, dating back to 1939. The gauge has not, hovever, been
*
operational for the last six months because of repairs on the Duhernal Dair.
IUSCS, 1987 (J4)J.
The aost rteent vater-quality records for South River at Old Bridge
vere examined for the period February 1982 to July 1983. The reviev of the
data presented in Table 6.1 generally indicates no change in vater quality
at this upstrean sample location over the 17-aonth period, except the
July-August 1982 period vhen chloride, hardness, specific conductivity,
sulfste, and total dissolved solids increased, but then subsided to the
norr.al level of concentration in the month of September 1982.
6-3
-------
Revision No. 00
UNI 1.1 i MUft BUDlIII KCOfiBS, SOU1M MIVCN BtlON BUWNMl BM, OIB WlOSt, NJ.
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-------
November 20, 19B7
Revision No. 00
6.2.2 Current Investigation
Surface-vater staples vere collected at 11 locations around the
Sayrcville Landfill site to assess the impact on the South River watershed.
The samples vere used in conjunction vith historic data collected at the
USCS vater-quality static- rated approximately four Biles upstream of the
site on the South River.
The USCS vater-quality stations provide regional data on seasonal
fluctuations over tine for conventional vater-quality parameters. The data
in the present investigation represent a singular tine evaluation of the
vater-quality in the vatershed. The Remedial Investigation surface-vater
and sediment samples vere collected betveen February 12 and 16. 1967.
Since the stapling vas conducted early in the vet season and near high
tide, the sample analyses Bay reflect high flov, and therefore high
dilution conditions. The samples vere analysed for priority pollutant
compounds, plus a 40-peak scan, as veil as standard vater-quality
parameters.
On-site and off-site sediment samples vere collected directly beneath
the surface-vater sampling locations depicted en Figure 6.2. The purpose
of the prograa vas to deteraine the existence and extent of contaminant
deposition bj adsorption or dissolution of constituents suspended in the
vater. A total of 11 sediment samples vere obtained belov the stream or
creek-bed utilizing dedicated stainless steel hand augers and stainless
•teel spoons to transfer sediaent to the sample bottles. The sediments
vere analysed for priority pollutant compounds, plus a 40-peak scan.
Summaries of the analytical results of the surface-vater sediment analyses
are provided in Appendix E.
6-4
-------
November 20, 19S7
Revision No. 00
6.3 Data Interpretation
6.3.1 Surface Tater
The surface vater-quallty data collected during . this . irwestigatior.
generally indicate:
o The concentri j.ns of ammonia upstream and dovnstreair. are
coBparable to etch other and USGS data upstream at Old Bridge.
o Chloride concentrations downstream are higher than the chloride
concentration upstream in Pond Creek and Duck Creek. Elevated
chloride values vere obtained at stations SV-3, SV-4, and
SV-11. The highest measured chloride value (602 Bg/1) occurs at
station SV-11 on the South River. The elevated chloride levels
•ay be attributable to tidal mixing of saline vater frotr the
South River.
o Eardness represents the total concentration of calcium and magne-
sium expressed as their CaCO. equivalent, and are elevated at
stations SV-3, SV-4 and SV-11. The highest hardness value va
obtained at station SV-11. ,
o Specific conductivity, which is related to the concentration of
ionized substances in vater, is elevated at stations SV-3, SV-4,
and SV-11. The highest specific conductivity value vas obtained
at station SV-11.
o The concentration of sulfate, fluoride, and nitrite do not vary
significantly between upstream and downstream samples.
o Concentrations of nitrate are elevated at stations SV-3, SV-4,
SV-9, SV-10 and SV-11. The highest concentration of nitrate
(9.55 »g/l) vas obtained at station SV-9.
o The Methylene Blue Active Agents (KBAs), vhich represent foaming
agents, range from less than 0.02 ag/1 to 0.046 ag/1 in all
samples, both upstream or downstream.
o Total Dissolved Solids (TDS) vary between (126-427 tig/1) upstream
and (332-1,029 cg/1) downstream. The highest concentration of
TDS is found downstream on the South River at station SV-11.
Several sasipJes exceed the New Jersey Surfaee-Vater Quality
Standard for TDS of 500
In general, the concentrations of a-etals upstream are slightly
higher than the concentrations downstream. Comparison of the.
surface-water quality data collected during this investigatio^
with the New Jersey Surface-Vater Quality Standards (NJSVQS^
6-5
-------
November 20, 1987
Revision No. 00
indicate that the constituent standards vere exceeded .in the
following samples:
> The NJ5VQS for chloride is exceeded in staples SV-3, SV-4, and
5V.11.
. The NJSVOS for total dissolved solids (TDS) is exceeded in
staples SV-3, r , and SV-11.
- The NJSVQS foi cadmium is exceeded in samples SV-1, SV-2, SV-5,
SV-6, SV-7, and SV-8.
- The NJSVQS for lead is exceeded in saaples SV-1, SV-2, SV-i,
SV-5, SV-6, SV-10, SV-7, and SV-6.
The SV-3 and SV-4 are surface-vater stations in Pond Creek. The
increase in the concentration of water-quality parameters at these stations
Bay be attributable to runoff from the vastefill. Stations SV-3 and SV-4
in Pond Creek are dovnstream from a Dupont Chenical Plant discharge.
Contribution from the discharge of the Dupont Plant *ay be affecting the
samples at these stations.
In addition to the conventional pollutants, the priority pollutant
data indicated that aethylene chloride, acetone, trichloroethane, benzene,
chloroethane, toluene, bis(2-ethylhexyl) phthalate, and di-n-octylphthalate
vere present in the surface vater at the sit*. The presence of stethylene
chloride and acetone are questionable since these compounds are used to
clean laboratory glassvare and field equipment, respectively. In addition,
chloroethane (SV-8) and benzene (SV-2) vere found at levels belov the
contract detection limits in only one sample each and trichloroethane
(SV-2), toluene (SV-2), and bi*(2-ethylhexyl) phthalatt (SV-6) vere found
in BethDd, field, or trip blanks in one sample tacb. Tvo phthalates vere
detected in one sample (SV-5). -—
6-6
-------
November 20, 1987
Revision No. 00
Several compounds vere tentatively identified in the curface^vater
sa-ples. Some appeared only In one cample: oxybic-propane (SV-2), tri-
Bethylsilanol (SV-3), end trichlorotrifluoroethane (SV-7), vhile tetra-
chloroethene appeared in all curface-vater samples except SV-3, and the
*ethod blanks. Propanol vas tentatively identified in SV-1 and SV-2. The
i ;
metals data do not indicate an obvious trend vhen comparing upstream and
dcvr.stream surface vater vithln any of the creeks of the South River. This
may be because of dilution caused by tidal flooding in the South River and
Pond and Duck Creeks; the campling vas conducted near high tide, as
previously stated. Cadmium and lead exceed the Nev Jersey Surface-Vater
Quality Standards. A subsequent event for curface-vater and sediment
sa-;ling at lov tide vill be employed to Bininlze dilution of future
sa~.pl es.
6.3.2 SediacJit
The sediment data presented in Appendix t indicate that methylene
chloride, acetone, toluene, carbon disulfide, chloroform, 2-butanone,
carbon tetrachloride, trichloroethylene, xylene, 4-»ethyl-2-pentanone,
phthalates, fluoranthene, and pyrene vere present in the sediment camples.
Samples SE-6 and SE-4 indicate the presence of toluene and
trichloroethylene, respectively. Carbon diculfide vac detected in SE-3,
SE-i, and SE-11 vhile chloroform vas found in SE-02 and SE-05. Carbon
tetrachloride vas present In SE-2, SE-4, and SE-11 vhile 2-butanone,
•ylenes, anrf a PCE vere detected in SE-2. Ac vith the curface-vater
sa-p:«s, methylene chloride and acetone aay be attributable to laboratory
or field contamination.
Phthalates vere found in all but one of the downstream samples (SE-9).
6-7
-------
November 20, 196?
Revision No. 00
Bis(2-ethylhexyl) phthalate vts detected In three of the downstream samples
(5E-2, SE-4, and SE-11), the Baxlmum concentration of vhieh is present in
•aspic SE-4 (16,000 *g/kj). The concentration of di-n-butylphthalate is
betveen 1,300 and 7,300 Bg/kg in the downstream tanples; the Baxiiruir
concentration compound vas found in sample SE-11. Fluoranthene and pyrene
vere both found in the upstream .sample SE-1 and the downstream cample
SE-2.
Sample SE-11 indicates the presence of a pesticide, 4,4'-DDT, vhile
4,4'-DDD vas detected in SE-07 at a level belov the contract detection
lisit. Gamma-BBC (lindane) vas found in SE-3, 5E-6, and SE-7, as veil as
the Bethod blank. T>£. V* — CW^'"*"
*
Comparison of the sediment quality data collected during this investi-
gation vith the Nev Jersey"5oil Cleanup Criteria indicate that the cleanup
standards are exceeded in the following samples:
e The concentration of arsenic exceeds the standard in saeples
SE-2, SE-4, and SE-7.
o The concentration of copper, Bercury, fine, and selenium exceed
the standards in sample SE-11.
e The concentration of silver exceeds the standard in sample SE-B.
Sacple •tations SE-2 and fE-4 are downstrea» along ?ond Creek, north
and vest of the vastefill, respectively. Sample SE-7 is downstream along
Duck Creek, south of the vastefill. The downstream increase in the concen-
tration of arsenic, copper, Bercury, lead, tine, selenium, silver, and
cyanide Bay be attributed to runoff free the vastefill.
Ho conclusive trend in the contribution of aetals froa the vastefill
runoff and subsequent deposition vas observed. Increases in the concen-
trations of arsenic, copper, Bercury, lead, xinc, selenium, silver, and
6-6
-------
i*ov*ttber 20, 1987
- Heviiion No. 00
cyanide are observed in the sanples froa the northern, the southern
vestern periaeters of the vastefill. A ttatistical coaparison over time
vould be required to conclusively determine if the differences between
wpstrear, and downstream levels vere caused by vastefill runoff or by normal
variations in the streair, sediments. Another event of samples collected at
lov tide aay provide acre conclusive results.
6..* TIDAL IKFLUENCE ON SURPACB-VATKR BTDRAUUCS
(.4.1 General
The Sayreville Landfill lies vithin the Rari tan/South River estuarine
systea. This system is affected by tvo high and two lov tides per day*.
i.e., semidiurnal. According to the National Oceanic and Atmospheric
Administration (NOAA) 1987 Tide Tables (US DOC, 1987 (IB)], the predicted
* & —
ftean tidal tenge at the South River Highway Bridge (Veteran Memorial
Bridge) is 5.5 feet. During spring tidal conditions, the aean tidal range (
increases to €.7 feet.
During the course of each aonthly tidal cycle, the height of tach
successive high-tide and lev-tide is different. This diurnal inequality is
typified by consecutive high or lev-tide variations cf up to 1.5 feet.
There also is a seall difference in the predicted lives ef high and lev- f
tide. The predicted time lag referenced to Sandy Book, Key Jersey, is *3^K
ffinutes to high water and +64 ainutes to lov vater at the Veteran Memorial..,,
Bridge.
The range ef the daily tides are affecttd aoatly by the relative
positions of the Moon, Earth, and Sun. This range ef vater levels nay be
affected significantly by uncommon astronoaical and Meteorological
-------
November 20, 1987
Revision No. 00
conditions. Tidal ranges increase during closer orbits of the Moon to-
Earth. Occasionally, the Moon's orbit at perigee is closer to Earth than
usual. The perigean tides which result have been known to increase tidal
levels by 40 percent [Wood, 1987 (19)]. Tropical and extratropical storms
lover the barometric pressure and are commonly associated with strong
onshore winds and precipitation. These events may produce storm surges and
surface-water runoff that would add to the tidal level to rapidly elevate
water levels several orders-of-magnitude above predicted conditions.
During times of higher water levels, the erosion potential of the
wastefill increases due to its proximity to the South River. As depicted
in Figure 6.1, flood waters could contact the fill on three sides.
Flooding on the northern and southern edges of the wastefill would be
exacerbated by the two tidal channels, Pond and Duck Creek.
6.4.2 Hydrography Survey
6.4.2.1 General
To evaluate the potential for contaminant migration via the tidal
channels, a survey was conducted on July 10, 1987 to measure the tidal
range and current velocity at several of the surface-water/sediment
sampling locations. The selection of July 10, 1987 as the survey date
reflected a desire to observe tidal levels at near-extreme conditions. The
tidal cycle surveyed occurred during an enhanced period of tidal fluc-
tuation due to a full-moon/spring-tide superimposed on perigean conditions.
The predicted tidal range for the survey period was 7.2 feet, approximately
0.5 feet above the mean spring range. The predicted times of the antici-
pated high, low, and high tides, including all correction factors, were
0839, 1453, and 2103 hours, daylight savings time, respectively.
6-10
-------
November 20, 1987
Revision No. 00
6.4.2.2 Tidal Cycle Elevation and Current Velocity Relationships
Prior to the hydrographic survey, calibrated tide-staffs were placed
as far across each channel as possible. The top and ground surface of each
staff was topographically surveyed with reference to mean sea level by
Lippincott Engineering Associates. On the day of the survey, additional
calibrated staffs were placed further at stations where the tide dropped
below the ground elevation of the original staff. The secondary tide
staffs were referenced to the original staffs with a leveling Brunton
compass and subsequently checked with a theodolite.
The actual survey began at 0715 hours on July 10, 1987 and continued
through 1930 hours that evening. Equipment, manpower, and mobility
logistics allowed only surface-water stations SW-1, SV-2, SV-3, SV-4,
SV-7, and SU-9 to be included in the hydrography study. These locations
are indicated on Figure 6.2.
A summary diagram with the water-level elevations measured throughout
the study period appear in Figure 6.3. Readily apparent in this diagram is
the clustering of points at about the same elevation as the water level
approaches high tide, and a divergence of water-levels as low tide
approaches. This refers to the decrease of channel base level, with
respect to mean sea level, as the stations progress from the upland, non-
tidal SV-1, through the Pond Creek and Duck Creek stations (ie., SV-2,
SV-4, SV-3, and SV-7), to station SV-9 in the South River. The progressive
lowering of base level is also corroborated by the stream profiles
topographically surveyed by theodolite after the hydrographic study (Figure
6.4).
6-11
-------
r/1
H
U
W
SURFACE WATER ELEVATIONS - TIDAL
10 JULY 1087
07OO
O90O
1100
n sw-i
1 3OO
HOURS
A SW-4
SW-7
-------
10
-I
5 4
60
120
10-
-4
5 -I
-t
j
0 4-
SW-2
-2
60
120
Ul
111
10
5 -!
-2 —
60
SW-3
120
10 -i-
SW-4
120
10 -s-
-2
60
DISTANCE (FEET)
SW-7 i
120
FIGURt
-------
November 20, 1987
Revision No. 00
Including factors such as current velocity and tide stage vithin the"
cycle provides an understanding of the sequential events throughout the
tidal cycle. Figures 6.5 through 6.8 provide synoptic views of tidal
elevations and current velocities at four stations during the survey
period. Current velocities were measured in feet per second and plotted
such that flood-directed currents are positive values and ebb-directed
currents are negative values. Zero velocity represents negligible
movement or a slack tide condition.
Surface-water stations SV-2, SW-3, and SV-4 exhibit similar current
velocity trends during a tidal cycle. As the water level begins to recede
from high-tide, ebb velocities increase through low-tide, until there is a
rapid transfer to flood conditions with little or no slack water. This
occurs because ebb flow progressively constricts to deeper portions of the
tidal channels, abandoning the mud flats. As seen in Figure 6.3, low-tide
in the South River occurred at approximately 1230 hours. At that time, the
water levels in the upstream tidal creek stations (SV-2 and SV-7) had
reached a low-tide base flow. The stations closer to the South River,
SV-3 and SV-4, continued to drain for an additional 1.25 hours before
reaching base flow. Base flow discharge was maintained for about one
additional hour while the South River had already begun to flood. Vhen the
water level in the South River reached the tidal creeks, rapid flooding
ensued. Initially, flood velocities were relatively high while the deeper
portions of the channels filled. When the flow expanded over the mudflats,
velocities dropped considerably. Water levels continued to rise at about
the same rate for the duration of the study.
6-12
-------
Q
fc
O
U
w
I/J
04
Ul
(X
H
W
e
xi
H
TIDAL ELEVATIONS,'VELOCITIES - SW-2
in JULY JOB?
4
3
1
0
1
-3 -
_ A
-5
0700
— t-r--r-i-] r -r-r r i— i — r-p i—r— i—
0000
1100
J300 1500
tl T1J5AL KIJSN'ATION
HOURS
] 700
•f VELOCITY
1000
-------
TIDAL ELEVATIONS/VELOCITIES - SW-3
Q
fc
O
u
w
t/J
w
IX
H
Id
W
in
H
U
W
0700
10 JULY 1087
0900 1100
D TIDAL ELEVATION
1 »'.! i •
1500
HOURS
1700
VELOCITY
1900
-------
o
u
w
1/1
W
IX
H
W
W
(fl
Vr4
(*i
H
U)
U
TIDAL ELEVATIONS/VELOCITIES - SW-4
10 JULY 1087
5
4 -\
3
I
0
1
-3 -
-4 -
-5 -
ovoo
nono 1100
n TIDAL KIJWATWN
1300
HOURS
1500 J700
t VELOf:iTY
900
-------
TIDAL ELEVATIONS/VELOCITIES - SW-7
O
U
w
OT
K
W
B,
H
W
W
fe
X
CO
H
Id
U
5 -r-
10 JULY 1087
•5 r—i—r—r-i—i—i—|—i—i—r
0700 0900
"i—r—i—f—T—i—i—i—i—i—r-|—i—i—i—i—i—i—i—f T"I—i—r
1100 1300 1500 1700 1900
n TIDAL ELEVATION
HOURS
+ VELOCITY
-------
JJoveaber 20, 1967
Revision No. 00
6.4.2.3 KitiMted South River and Tidal Creek Discharge
Discharge estimates vtrc calculated for tht South River Adjacent to
the landfill cite. Discharge data for July 10, 1967 at the Spotsvood
Gauging Station vere used to estimate the daily average discharge a: the
'Duhernal gauging station on the South River (USCS, 1967 (2)]. Flov or. that
day vas estitated to range fro* 100 to 170 cubic feet per second (cfs).
Using a drainage basin correction factor obtained free the FEKA (19£7)
report [13], this corresponds to a range of UO to 235 cfs adjacent to the
landfill.
Data generated fror the hydrographic study in Pond and Duck Creeks
suggest • lev-flov discharge of less than 10 cfs en July 10, 1967. This
base flov condition occurred during late ebb-tide vhen vater levels dropped
belov the base level of the tidal channels into the South River. The lov-
fiov discharge free the tidal creeks possibly consist of a combination of
streaR discharge and drainage fror the saturated aoils (e.g., vastefill)
along the channels. Since station SV-1 aair.tained a fairly ur.ifore
dovnstreae flov throughout the hydrography study, streas discharge is
certainly a component of the Pond Creek lov-flov discharge. In Duck Creek,
feovever, the riverine segment upstreae of SV/SE-6 is apparantly ephemeral.
Therefore, a significant portion ef the late-ebb discharge fros Duck Creek
vould consist ef drainage fro* the channel and adjacent soils.
An estimation vas also completed for the »ini«ut average seven
consecutive day flov vith a statistical recurrence interval ei 10 years
(HA7DC10). A flov ef 4.6 cfs for the South Rivar at Old Bridge vas
provided by USCS t**J. Using a drainage basin correction factor, the
estimated KA7DC10 flov in the South River adjacent to th* landfill is t.5
6-13
-------
Hovetber 20, 1957
Revision No. DC
eis. Extrapolating this value, an estimated HA7CD10 flov ef 0.25 efs would
discharge {IDE the tidal cracks.
«.S TIDA1 INFLUEHCIS ON GROUND VATER LEVELS
During the hydrographic study conducted on July 10, 1987, vater levels
vere also Beasured in the site Bonltering veils throughout the day. Vhile
all of the Bonitoring veils txhibited aone vater-level fluctuations, only
veils KY-1S, KV-1D, KV-4S, KV-iD, KV-5, KV-6S, KV-6K, KV-13S and KV-P£
fluctuated in a Banner strongly correlative to the tides. Appendix X
contains coeputer-generated vater-level diagracs, at a eoa&on scale, for
all of the conitoring veils.
The tidally-influenced veils exhibit vater-level variations and
ti&e-lag characteristics that do not appear to be related to the screened
depth ef the veil. For exanple, veils KV-1D, KV-4D, and KV-6K are screened
at average depths of 105, 68 and 36 feet, respectively, but all responded
vith a strong connection to the surface tides evidenced by the lack ef a
tiBe-lag to lev vater. This direct connection Bay be attributable to a
direct hydraulic linkage vith a surface txpression ef the screened
formation, or a potentioaetrlc tiaad fluctuation rtlat»d te the veight
differential of the ebbing and flooding surface vattr.
Shallov veils, such as KV-1S and KV-?£, vould be expected to react
quickly to tidal fluctuations but these veils lagged up to 1.3 hours behind
predicted lov tide. This say be due to an indirect connection to the
surface vaters or the frictional_ losses through soaevhat Itss perneable
lithologies.
-------
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W4J?
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NEW JERSEY STATE DEPARTMENT Of ENVIRONMENTAL PROTECTION
FROM
SUBJECT
r\ r^
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State cf New Jerrey
""P^ »^*~«~•• C * ^TiV* ~CJ^"£~t£» ?'•
TO: File -
S.
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•»« — —.
•.".
' !£-s" etc.fwtt observed In front cf th* dirt tile •! t*
Meld feccesa roef. Scattered plastic ani furr:lture (i^-
' 'csverft-)*«g oS8»rv.fl in the wooded area to the r5cht o
i :2 irt pile
r.ext to the wooded area.
' A-. In C,s«g sketch; An 6r«e spprox. SxlO1 .consisting cf
i '-expcae; ce~er.t »••« otig«rv-g. __
2.5.1?
e sketch; An area epprox.
50* .eonrjptinr of
j lexpoeei »sph«lt arid ceir,«nt was observed.
2.5.15 !',Ah£A £,B*e sketch; The top area of the landfill contained
j Scattered refuse protruding thru th- er.vr. F»fu*e ob-
| jserved included tir»s, bottles, cement etc.
2.5.15.-^Hi^ K.see aketch; ^ area approx. SOx^O.*, consist ing of
j lexpcsed refuse was observed. Kot«:this area uppears to
jh*v- been disrupted at on* time. Deer lids were present
_ —_—-_. — •- _ _ ._ - .... _ . —_ ^ _ . . _ _ . . _
(here.
C,see sketch: An are* approx. '20x^0' ,consistlrr cf
jpxposed tires,metal,wood,household etc »as observ-d
-------
M Z X 0 a A
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Stats cf New Jerrey
:.2-t cf Ir.vircrjr.sr.tcl ?:
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2.5.1V -Ar.ZA £,s«e sketch: Erosion or. th«; slope aree we* ois»rved
• i jlr. this area. _ _
2.5.17 j:A.-.Lr. !,?•• sketch; 'grosion or. th* slop* >r*8 was observed
; arc refuse »«s becinr.inr to protrude thru th» cov«r here.
'
-------
NEW JERSEY STATE DEPARTMENT 0* ENVIRONMENTAL PRDTECTlQr;
TO f,k
FROM
DATE
SU8JECT•
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MEMO
TO
NEW JERSEY STATE DEPARTMENT QF ENVIRONMENTAL PROTECTION
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-------
ATTACHMENT A
-------
May 2, 1990
Heal B"rody, Esq.
Office of Regulatory Services
Hew Jersey Department of Environmental Protection
410 East State Street
CN-402
Trenton, KJ 06625 . . .
Re: Bavreville Landfill III
Dear Kr. Brody:
This letter is submitted by the undersigned signatories to the
Agreere.-.t and Administrative Consent Order dated October 28, 196£
("settlers"). Its purpose is to provide comnents on the draft
"Final Report: Remedial Investigation/Feasibility Study" date::
March 2C, 155C ("Final RI Report"), prepared by B t V Waste Science
and Technology Corporation.
7RZD C. HART COKXEKTB
In * Xercrandur. to the settlors, Fred C. Hart Associates, Inc.
("KA.-.T") has suiritted written consents on the Final RI Report
which are attached to this letter ("Attachment 1"). Ar.ong other
things, HA£7 reaches the following conclusions based upon its
review of the rer.edial investigation data: (1) there is no basis
for arguing possible "leakage" of landfill contaminants into the
deep Farrinrtor. Aguifer (all hydrogeclogic and analytical data
corpels the contrary- conclusion that contamination of the deep
aq-jifer is not an environmental concern) ; (2) existing data does
not support a conclusion that there are significant discharges of
hazardous substances from the landfill into the South River; (3)
a water quality sub-classification of the shallow Cape Kay alluvial
aquifer or waiver of applicable water quality standards is
justified (based upon well-documented saline intrusion and the
SE-1 classification of the river, the lack of a demonstrated
hydraulic connection to the river and the lack of potable water
supply receptors in the area); and (4) leachate production at the
landfill is einimal and can be effectively eliminated or controlled
by eliminating precipitation as a source of recharge. The settlors
incorporate by reference HART'S comments and Bake them a part of
this letter.
-------
OTCTE ttgKERXL COMXEVTB
In addition, the settlors submit the following general
consent* on the RI Report.
treaealatioB of Remedial Investigation Data
1. 'The title of the report should be changed to "Remedial
Investigation Report." The subject Batter of the report is the
remedial investigation. The Feasibility Study is not completed and
will be-the subject Batter of another report.
2. The Executive Summary should be revised to include the
significant findings and conclusions of the remedial investigation.
It should include at least the findings itemized in Comment No. 1C
belev under "Substantive Comments."
3. The report's reference fe.c. . Pages ES-6, 1-3 and 5-2) to the
potential for aigration of landfill contaminants into the deep
Farringtcn Aquifer in its descriptions of the "principal
enviror.rer.tal concern" raised by the landfill is confusing ani
misleading. As presently written, the report can-be construed tc
suggest that this potential migration is a present concern wher.,
in fact, it refers to an environmental concern that existed befere
the remedial investigation. The text should be clarified to make
this clear.
4. An important conclusion based on the remedial investigation data
is that the principal environmental concern at the site is lir.ite:
to contamination of the underlying shallow alluvial Cape Kay
aquifer and the actual or potential migration of contaminants frcr
that aq-ifer into the South River. The report should clearly state,
this conclusion in the Executive Summary, Section 1.2
(Introduction: Nature and Extent of Concern), Section 9.0 (Public
Health and Environmental Concerns), and a new "Section 11. c
"Conclusion" section which should be added to the report.
5. The initial health and environmental concerns about the landfill
that existed before the remedial investigation have been
significantly reduced based en the results of this investigation.
For exarple, Page 9-8 concludes that a minimal threat to public
health exists at this time and Page 9-10 concludes that only
Binical environmental impacts are created by the landfill. These
conclusions should also be stated in the Executive Summary, Section
1.2, and new "Conclusion11 section.
«. Key analytical And factual data supporting the findings that
minimal public health and environmental risks a-xist should be
summarized in the Executive Summ'STy, Section 1.4 (Introduction:
Suw.ery of Remedial Investigations), Section 9.0 and new
"Conclusion." For example:
-------
• A black peat layer of meadovmat one to five feet thick
in all boring locations underlies the waste material
indicating .the recent alluvial deposits (Page 7-6),
providing evidence that the waste?ill material was
disposed of over the existing meadovaat without prior
•xcavation (Pages 5-18, 7-6). This is further borne out
by the landfill engineering plans and drawings and aerial
photography interpretation (Appendix A).
• This peat material is a silty, mucky type of material
that is virtually impermeable to water and serves as a
natural liner preventing or severely retarding the
migration of hazardous substances and wastes in wastefill
into the lover alluvial aquifer..
• The fluid bearing zone within the wastefill materials
is perched above the underlying shallow aquifer (Page
ES-2) end water levels in the wastefill wells are not
subject to significant tidal influence (Pages 5-23, 5-
25).
"• Water quality of the South River and groundwater
dovnrraiient of the site are not significantly degraded
(Faces S-8 to 9-9).
• Vater quality of the South River and groundwater
dovr.gradier.t of the site are not materially different
thar. the water quality upgradient of the site and, in
fart, the concentrations of netels upstrear are generally
sliohtly higher than'dowr.strear. (Page ES-5, Pages 6-6,
8-1C).
* Significant levels of contaminants in surface waters
were not found (Page 3-16).
* The South River and underlying shallow aquifer are not
a present or potential source of potable water supplies
due to present water quality classifications and
extensive saline intrusion in this area and pre-existing
background contamination levels.
* JJo significant levels of contamination were found in
the deep Farrington Aquifer (Pages ES-5, 1-10).
• The water quality of the deep aquifer in the landfill
area has been adversely affected by a steady process of
• aline intrusion that has been documented for 50 years
(Pages 1-5, 1-10).
• Ketals concentrations in the soils ef Seyreville
Landfill III and off-site are consistent with those
-------
normally found in New Jersey and Eastern United States
•oils (Pages 7-2, 7-14).
• At this point, Sayreville Landfill III does not appear
to be the source of metals found in soils occurring
outside the wastefill (Page 7-14).
e- Leachate from the landfill doe* not appear to have
. significantly affected flora or fauna (Page 9-10).
7. The report variously refers to "industrial wastes," "limited
light industrial wastes," and "hazardous wastes." It is important
to define these terms and standardize them wherever possible.
Where each separate tern appears for the first tine in the report,
the term should be accompanied by a clear definition and the words
"as used hereafter." See Substantive Comments.
8. The report lacks adequate naps shoving the geographic locaticr.
of places and concerns in relation to the landfill, such as the
Sayreville and South River well fields and the Sayreville Water
Department's intake on the South River.
9. Kar.y figures and tables are eislabelled, apparently as a result
of earlier use in another draft of the report. For exar.ple,
figures and tables in Volume 1 are mistakenly identified as "Volur.e
2. "
•ubitartive Co&se&ts
10. The Executive Surr.ary, Section 1.4 (Surjr.ary of Feriefiel
Investigations) and. new "Conclusion" section of the report should
include the following basic findings and conclusions:.
~ • The results of the phase 2 drur. investigation dc not
support previous allegations of hundreds of drums buried
in the landfill and environmental concerns about these
drur.s may have been overstated. Fewer than three dozer.
drums were found during the remedial investigation.
• Water quality data from the wastefill fluids indicates
approximate confor&ance with typical sanitary landfill
performance (Pages 5-36 to 5-39). On the basis of this
data alone, remediation of the landfill would not be
indicated.
e A black peat layer of aeadovaat one to five feet thick
in all boring locations underlies the waste material
indicating the recent alluvial deposits (Page 7-6). This
indicates that the wastefill material was disposed of
ever the existing meadov&at with no prior excavation
(Pages 5-18, 7-6). This is further borne out by the
landfill engineering plans and drawings and aerial
-------
photography interpretation (Appendix A).
9
• This peat material it a silty, aucfcy type of material
that is virtually impermeable to water and serves as a
natural liner preventing er severely retarding the
•igration of hazardous substances and wastes in wastefill
into the lover alluvial aquifer.
e" The fluid bearing zone within the wastefill materials
is perched above the underlying shallow aquifer (Page
IS-2) and water levels in the wastefill wells are not
subject to significant tidal influence (Pages 5-23, 5-
25), . - ;
• The South River and underlying shallow alluvial aquifer
are not a present or potential source of potable water
supplies due to present water quality classifications
(SI-1), progressive saline intrusion in this area and
pre-existing background contamination levels.
.* significant levels of contaminants in surface water
were net found (page 3-16).
• The vater quality of the South River and groundvater
dovngradient of the site are not significantly degraded
(Pages 9-6 to 9-5) .
• The water quality of the South River and groundvater
dcvngradier.t of the site is not materially different than
the vater quality upgradient of the site and, in fact,
the concentrations of sone constituents upstream are
generally slightly higher than ' downstrear. (Page ES-5,
Pages 6-6, 9-10).
• Leachate fror the landfill does not appear to have
significantly affected flora or fauna (Page 9-10).
• Metals concentrations in the soils of Sayreville
Landfill III and off-site are consistent with those
norrally found in New Jersey and Eastern United States
soils and not cause for concern (page 7-14).
• At this point, Sayreville Landfill III does not appear
to be the source of metals found in soils occurring
outside the wastefill (Page 7-14).
• K= significant levels of contamination have been found
in the deep Farrington Aquifer (ES-5, Page 1-10).
• The Voodbridge/South Aftboy Sequence clay is an
effective aquitard which has prevented vertical leakage
-------
. " "*
ef hazardous substances into the deep Farrington aquifer
(Pages ES-5, 4-11).
• The water quality of the deep Farrington Aquifer in the
landfill area has been adversely affected by a steady
process of saline water intrusion over many years (Pages
1-5, 1-10). It is not a source of potable water supplies
fn the landfill area.
•
11. The tern "limited, light industrial wastes" appearing
throughout the report is vague and ambiguous. On Page 3-1, it is
immediately followed by a broad "textbook" definition of
"industrial wastes," yet the intended meaning of the tenr. appears
to be the definition on Pages 3-4 and 4-10: "plywood and plywood
containers, sheet aetal, automobile parts, and a canvas fire hose."
These materials sight more accurately be classified as "bulky
wastes" perritted by the landfill's registration permit. If these
aaterials are what is intended by the term "industrial wastes,"
this generic tern should be deleted to avoid confusion with
regulatory definitions. The particular wastes should be specified.
12. Sir.ilarly, the terr "hazardous wastes" appearing throughout the
report is broad and vague. In the overall context of the report,
this terr. appears to refer only to the drur.s allegedly buried at
the landfill in 1574-1977 and wastes allegedly dumped at the
•landfill after closure. Without clear definition, the tenr »ay be
misconstrued to suggest a r.uch greater disposal practice and
environmental concern than actually exists at the site.
Clarification cf "hazardous wastes" and specific docunentation is
irpcrtar.t to reach sensible conclusions and avoid the potential
for misleading the public.
13. The narrative of the report does not adequately discuss other
potential sources of hazardous substances, wastes or discharges
that were identified during the remedial investigation. These
potential sources include:
• DuPont cher.ical plant outfall discharge into Pond Creek
(elevated contaminant levels reported in nearby and
downgradiert surface water and sediment samples (SW/SED
14, SK/SED-3 and SW/SED-4).
• Middlesex County Utilities Authority ("MCUA") sewer
interceptor under the landfill (elevated levels of aetals
and organics reported in the effluent, Page 5-33), both
as a result of potential exfiltration and disruption ef
the landfi-12 cover and drainage during the 1977-1976
•ever line installation.
• Drums excavated in Phase 1 and 2 which had identifying
Barkings.
-------
• Block 58, Lot 1A -(foraer Van? Cheaical Resources
Company cite), which, is a part of the site (see Page 1-
2 and Figure 1.4, "Lot Boundaries"). It should be noted
all PCB erochlor, and the elevated levels of contaminants
in XW-13, were found at locations on the triangular piece
ef this property located on the other side of Pond Creek
or its tributary frot Block 57. The following sampling
locations appear not to be "upgradient" of the landfill,
but on this separate property and distinct portion of the
•*- landfill: TP-6, TP-7, KW-13, SW/SED-2, SW/SED-15 »nd
SV/SED-14 (near DuPont discharge outfall).
• The abandoned 10,000 gallon bulk liquid storage tank
located on Block 56, Lot 1A which earlier DIP records
indicate is sirilar to a storage tank used by Vamp
Cherical Resources.
(Please consider other connects and evidence that have beer.
subritted separately by the settlors identifying PRPs.)
14. The drur inventory logs (Appendix C) are incomplete. They dc
not reecrd the crushed drur. found in Test Pit 13 (HART report).
They fail to record scr
-------
Services that registration be denied pending resolution of the
State's riparian interest in the property involved; that
recoaaendation was not adopted by DIP which issued the registration
permit.
17. The report o&its reference to the approved landfill closure.
Its discussion of the landfill permitting history should state that
the landfill was closed in accordance with an engineering closure
plan approved by D£P, which included final grading, the
installation of methane vents and drainage structures, and
installation of a landfill cover consisting of a combined soil and
cl.ay cover on the side slopes and a vegetative soil cover on the
landfill surface. (REFERENCES: See DEP letters dated September 10,
1979 and November 20, 1979, copies of which are appended hereto as
"Attachment 3".) Mistaken allegations or background references to
the effect that Sayreville failed to provide a clay cover as
required by DE? should be deleted.
18. Information on Pages 1-1 to 1-2 as to the identity of the
owners of the property on which the landfill is located is
incomplete and inaccurate. Celotex Corporation does not own any
portion of the landfill property and its name should be Strieker..
On the other hand, the report fails to identify the owner of Block
56, Lot 1A (former site of Var.p Chemical Resources Inc. and Rice
Transportation Co., Inc.). The rear triangular portion of Block
58, Lot 1A, is part of the landfill site and wastefill area (see
Page 1-2 and Figure 1.4). According to recent municipal tax
records, the currer.t owners of this property are: C.E. Laslo, J.
Pclak ar.i 7. Pclak. They should be identified in this section of
the report ar.d any other descriptions of landfill ownership.
(Settlors believe that Block 58, Lot 1A, is currently occupied by
a company dcing business under the name of "L.P.4 Sons JBrickote,
Inc.")
19. Source references for factual and historical allegations in the
report are generally lacking or incomplete. Documentation for
these allegations should be revisited and the endnote references
should be supplemented.
iBttrnal I&co&siste&cies ifi the Report
The following are some of the more obvious inconsistencies or
possible ir.ccrsistences in the report apparent to the settlors.
In ger.ertl, the report needs to be reviewed for consistency in
content and standardization of its terms.
20. At Page ES-2, the report states: "... the fecility is
therefore subject to daily tidal as well as flooding inundation by
the South River." This observation is, contradicted by the water
level »eesuresents and other data obtained during the investigation
indicating that this is not the case. It is inconsistent with the
findings that the fluid bearing tone within the wastefill materials
-------
is perched above the underlying shallow aquifer (Page IS-2) and
that the water levels in the vastefill veils are not subject to
signif ieant tidal influence (Pages 5-23 and 5-25) .
21. At Page 10-2, the report concludes: "It is reasonable to
predict future discharges froa the Bite with a high degree of
reliability.* The existing hydrogeologic and analytical data do
not support this concluding paragraph of the report. Even if a
theoretical potential for future discharges is a concern, the data
does not support the present prediction of such discharges "with
a high degree of reliability."
22. At page 5-1, the report states that "limited samplings by NJDEP
ef the South River vater and sediaent performed in July 1961 near
the landfill reveal anosalous a&ounts ef organic compounds [47]."
The term "anomalous* is vague. Elsewhere, the report describes
these analytical results as "less-than-value" (Page 6-3). The
nature, location and significance of this sampling effort should
be explained or the results should be deleted.
23. The "vastefill boundaries" drawn in the large, foldout "Site
Map*' are inconsistent with Figure 1.4 (Lot Boundaries) and the text
of the repcrt (Page 1-2) which indicate that Block 58, Lot 1A, is
included in the Sayreville Landfill III site.
COKXEKTE
In addition to the foregoing cor.ir.ents, specific page-by-page
ccr.rer.ts are set forth in "Attachment 2" and made a part of this
letter.
COKCLPBIOK
These ccrjr-ents by the settlors are subr.itted in the spirit of
cooperation and for the purpose of aiding and assisting DEP at this
site. They are not an admission of any wrongdoing, fault or
liability on the part of any settlor. By not submitting comments
on certain aspects of the RI Report, the settlors do not
necessarily indicate their agreement with, or acquiescence in,
those aspects of the RI Report.
This subzission is made on the understanding that EPA vill be
afforded an opportunity to review and comment on then. Settlors
vish to confirm their understanding that settlors' correspondence
vith DIP discharges any obligations settlors may have to notify
EPA. This viii else restate the settlors' understanding that there
vill be a decision document issued by DEP at the conclusion ef the
RI/FS and that IPX vill express in writing its concurrence vith the
DEP's decision at the conclusion ef this RI/FS. Although the exact
fore of EPA's concurrence has not been established, settlors
understand that it vill be adequate to avoid additional site
activities and to support eventual delisting ef the Sayreville
-------
landfill III site fron"£he National Priorities List. Settlors
respectfully request clarification or confirmation ef these
understandings which are ef great import and concern to the
settlors.
Finally, the settlors respectfully request copies ef the
following documents:
eTuSEPA, 1982, HRS RanXing Sheets (37).
e All documentation for the allegations of buried druir.s
and- .pest-closure disposal activities at the landfill
which are not part of DIP'S Hazardous Site Mitigation
file.
e XI1 written D£P and EPA cofijaents regarding the RI/FS
to date.
e All agreements, aer.orand;. or understanding or guidance
docucer.ts governing the protocol and relationship between
EPA and DIP at this site.
They revest an opportunity to subirit supplemental or revised
cozr.ents base:? upcn receipt and review of this additional
information.
Thank you fcr the opportunity to subr.it these cocnents for
DIP'S consideration ir, connection with its review and finalizing
of the Final Rl Repsrt.
Respectfully submitted,
Borough of Sayreville
Celotex Corporation
Chevron Cheir.ical Company
Hercules, Inc.
Mobil Chemical Company
Pfizer Inc.
Ruetgers-Nease Che&ical Company, Inc.
WL:«r
ec: Michael Burlingaoe, KJO£?
trie Schwartz, USEPA
Joe McVeigh, Esq., VSEPA
10
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ATTACHMENT 1
MEMORANDUM
TO: Sayreville Landfill III Committee
FROM: Dennis Farley
RE: RI/FS - Technical Comments
DATE: Aprn 25. 199D
Enclose:! are HART's technical comments on the draft "Final Re;:-t
Rerr.eii*: Investlpstion/FeaslfcHity StuOy" datei March 20, 199D ("Fine! R!
Re;:-t'') prepared by BIV Waste Science and Technology Corporation.
-------
-2-
1. ALLEGED •LEAKAGE" THROUGH THE SOUTH AMB3Y/MOOQBgIPCg CLJ.Y.
The text contains several references to potential leakage which may be
occurring through the South Amboy/Hoodbrldge clay (page 5-22, "... this 1s
wpported by the literature which documents -saline water Intrusion into
the Farrlngton aquifer 1n this area."; page 5-37 "... which may Indicate
the---migration of heavy metals frotr, the wastefm may be occurring."). The
validity of this alleged scenario U disputed based on the follow-in;
technical arguments: ' .
a. The results of the aquifer pumping test, reported on pages 5-5 tc
5-14, Indicate that no hydraulic communication exists between the
Fa^rlngton aquifer and the shallow alluvial aquifer or Sayrevllle
Landfill in. it should be noted that the thickness of the South
Artoy/Wooitridge cley sequence 1n the vicinity of the Landfill 1s or
the order of 6D-70 feet.
t. The encroachment of saline water Into the Farrlngton aquifer does r.:*
suppc-t the supposition of leakaje through the South Amboy/Woodtrltfre
city as proposed on Page 5-22. This supposition 1s tn contradiction
U page 1-5 of the report, which states the source of the saline
contamination to be 1n the vicinity of the Washington Canal, wn;.ch
joins the South River approximately 1 mile downstream fror the
Landfill. The references dted 1n the report explain this
encroachment more thoroughly. Appel (1962, report reference [1])
describes the Intrusion of saline water Into the Farrlngton to occur
updlp of the landfill 1n the area of the Rarltan estuary, where the
Farrlngton outcrops are exposed to salt water. In addition to the
area of the Nashlngton Canal, other principal areas where saline water
has entered In the Farrlngton are near the e»uth of the Rarltan River,
and an area one tile downstream from the confluence of the Washington
Canal and the Rarltan River. As stated In the report, long-term
pumping of the Farrlngton has drawn this saline vater southward from
the outcrop areas over ttae.
(19E9P)
-------
•3-
Thls Information further disputes the ttfctenervt made on page 5-12 of
the report, "The hydrographs of Hells 1-0 e,nd 4-D clearly reflect the
Influence of tidal loading from the South River. • The observed tidal
Influences tre likely due to tidal loading of the Rarltah tstuary, an*
subsequent hydraulic communication via the locations described above.
c. The reference to possible migration of 'elevated concentrations of
heavy metals" (e.g., page 5-35, 5-37) from Sayrevllle Landfill III tc
..the Farrlngton tqulfer 1s not supported by the analytical date
provided 1n the report. Of the "elevated concentrations of chronlurr,
nickel, managanese ind zinc* discussed, only nickel and manganese
exceed the 'Regulatory Standard" limits provided alongside the data 1n
Appendix E. The concentrations of manganese, though elevated, are
wUMn the range of USGS Ambient Kater Quality Data for this area, as
discussed on page 5-34. Elevated levels of nickel were only found In
deep veils screened 1n the Hoodbrldge agultard; those screened solely
1n the Farrlngton aquifer, Mrt-lD and B?T, were both clean. It should
be ncted that concentrations of nickel were »lso Identified 1n the
Alluvial /Cape May aquifer, at levels much greater than any observed 1n
the refe-red-to "wasteful" wells or test pits. This would appea- tc
indicate a non-Seyrev1lle Landfill III source to exist, such as
natural concentrations related to the clayey material Itself. Base;
or. the data provided, no contaminant "fingerprint" exists 1n
ground*ater 1n the Farrlngton tqulfer which 1s Indicative of the
of my contaminants frorr Sayrevllle Landfill III.
Based on these technical arguments, 1t Is felt that any and all
refiTir,:es/al legations contained 1n the rtport to leakage through the
-South Amboy/Haodbrldge Clay ire unjustified and misleading. The evidence
contained In the report clearly Indicates that no effects upon the
Farrlngtor, aquifer have been observed, and that minimal potential for this
to happen 1n the future eilsts. As this Is one of the most Important
findings of the Investigation. It should be clearly stated In all
conclusions, is well as 1n the Ex*&Jt1ve Summary. All references to the
contrary (e.g., pages 5-22 and 5-37} should be deleted.
(19E9F)
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2. POTENTIAL COXTAK!JJfcKT MIGRATION FROM THE ALLUVIAL AQUIFER TO THI Sfr'Tu
RIVER.
An Important consideration of the report should fee * thorough
assessment of whether contaminants are migrating to the South River fror
the Sayrevllle Landfill III via the alluvial aquifer. Several references
(t.g., P«g« 5-21, 5-11) ire made 1n the report which state that the
alluvial aquifer 1s likely 1n hydraulic communication with, and
essentially, discharging to the South River. In order to proceed with
proper remedy selection for the landfill, a acre definitive conclusion
must be reached. It Is felt that the findings of this study are contrary
tc that which 1$ Inferred 1n the report.
Prior to considering technical arguments regarding the hydraulics of
this potential pathway, the obtained analytical data for the alluvial
aquifer should te sunvr,irlzed to Indicate the significance of
contamination. Although a thorough presentation of the analytical
flnd'.ngs are made on pages 5-32 and 5-36, the listing of findings which
are net significant tends to confuse the reader. Of the metals which are
listed, only manganese, chromium and cadmium were detected at
concentrations exceeding the "Regulatory Standard" provided with the
data. Cf these, manganese was present at concentrations lower than the
USSS Artlent Hater Quality data discussed on page 5-34. Chromium was
detected at concentrations 1n the alluvial aquifer which are higher thar,
the 'wasteful" wells, and was present 1n wells KK-2S. MK-P2. MK-12. Mn-3
and M*-4. all of which are upgradlent of the Sayrevllle Landfill III.
This Information supports a source(s) of chromium other than Sayrevllle
Landfill III to exist. Levels of cadmium narrowly exceeded the regulatory
standard In three wells, one of which 1$ the background well. UK-IS. It
should be noted that no levels of cadmium above the Regulatory Standard
were reported for Round II of the sampling.
Of the organic contaminants presented in the rtport, only
chlcroethane. total xylenes, and napthalene exceed ECRA Surrogate Action
Levels, and this was observed 1n only one well. M-M3 (located on the
(15E9P)
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-5-
Block 56, Lot la peninsula). Several of the compounds detected, such as
•ethylene chloride, acetone, and the phthalates are common laboratory
and/or field decontamination contaminants. Benro(a)pyrene, detected only
In the Round I sampling, 1s flagged as a blank, contaminant.
In summary, significant contamination of the alluvial aquifer appeals
limited to the several organic* detected 1n MW-13. As these .contaminants
serve as a fairly accurate "fingerprint" of the Landfill contaminants.
their presence 1n only one well seems.to Indicate that wholesale migration
of contaminants from Sayrevllle Landfill III to the alluvial aquifer is
net occurring. On the contrary, their presence 1n MW-13 1s nst
necessarily logical, as this particular area appears to be Immediately
underlain by a thicker (16 feet) sequence of clay than the remainder of
.the Sayrevllle Landfill III (based on figure 4.8). The possibility does
exist, .based on the drilling/Installation procedure described on page 5-6
and 5-7, that Landfill contaminants could have been Introduced to the
alluvial aquifer during drilling, figure 4.8 Indicates MW-13 to be one of
the furthest up;rad1ent wells which actually underlies the Sayrevllle
Landfill III. If the Landfill 1s the source of the observed contamination
1n this area, one would expect to observe vertical leaching of the
contaminants through the clay sequence 1n this area. Analytical data fc-
the son sar.ple collected during the Installation of this well does n:t
Indicate the presence of these contaminants, although no "depth
of-sair.pl 1ng" Information 1$ provided.
Based on this understanding of contaminant presence 1n the alluvial
aquifer, the following comments are provided regarding potential migration
to the South River:
a. The results presented 1n the report regarding site geology and
hydrogeology do not demonstrate the «x1$tance of hydraulic
communication between the alluvial aquifer and the South River.
As discussed on pages 5-21 and 5-22, the vattr levels 1n wells
MK-5S and MK-6S are consUtanly below the level of the Soutr.
R1v»r. While several scenarios have been presented which attempt
to explain this observation, one scenario has been overlooked:
(1969?)
-------
-6-
the alluvial'aquifer and South River My fifil be 1n hydraulic
communication. Information regarding Uthology beneath the
river, as veil ts thickness of accumulated t*d1»ent. 1s nc.t
provided. Observed tidal effects 1n the alluvial aquifer could
be the result of Influence 1n other areas In the Rarltan Estuary
where the alluvial aquifer outcrops. Klthout further Information
regarding river depth and Uthology, 1t 1s not possible to state
with certainty that the alluvial aquifer and South River are 1n
direct hydraulic communication. Site-specific Information
obtained to date suggests that they are not.
Regardless of the hydraulics of any South River/alluvial aq-'ifer
relationship, an assessment of the effect of potential
contaminant *1grat1on can only be aade by comparing analytical
data fror, the alluvial aquifer and the South River surface
yater. Such a comparison would assess the presence of
^fingerprint" alluvial contaminants 1n the surface water sar.;1es
obtained. Of these fingerprint "contaminants, chloroethane was
detected at a level below the contract detection I1ir.1t 1n one
surface water sample, as discussed on page 6-7. Cadmlur. was
detected at several surface water sampling locations, with the
highest concentrations detected 1n SN-1. This sample was
collected adjacent to Jernees Mill Road, far upgradient of the
site. As with the ground*ater data, no cadmium was detected in
any of the Phase II samples. Based on this assessment of the
data, 1t appears that significant contaminant migration to the
South River via the alluvial aquifer 1s not occurring.
NJDEP's comments on Black I Veatch's ARARs Document of March 6,
1969 discussed the possibility of tub-classifying the groundtater
or obtaining a waiver from DWR cleanup criteria for the alluvial
aquifer. TMs seems appropriate based on the discussed receptors
and/or potential users of water from the diluvial aquifer.
Although uncertanties exist regarding the aquifer's relationship
with the South River, the River's SE-1 classification 1s
(1989?)
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-7-
conslstent with this thinking. Saline Intrusion of the
Farrlngton and Old Bridge aquifers has been documented it their
outcrop areas, tnd severely Units their useab111ty at these
locations. Even If the alluvial aquifer 1s continuous to these
outcrop areas, the txlstance of saline Intrusion would justify i
waiver from DHR cleanup criteria.
.Based on the arguments presented, the following conclusions should be
siade 1n the report and .presented 1n the Executive Summary.
contamination attributable to Sayrevllle Landfill III has
been detected 1n the alluvial aquifer.
• Based on the results of this study, the alluvial aqi'lfer may net
be 1n hydraulic cownunl cation with the South River.
* Poter.tlal receptors of ground*ater from the alluvial aqulfe? e^e
themselves de^aded due to salinity, and are relatively useless
as pstatle supplies at locations 1n close proximity to the
landfill.
It 1s felt that these findings are Important conclusions of the study
and will weigh' heavily In remedy selection. As such, they should be
Included 1n the report as conclusions 1n the Executive Summary.
3.
It appears from the data that an assessment of leachate quality
escaping from the site, attempted via the surface water and sediment
sampling programs, was relatively Inconclusive. The surface water data
does not Indicate any obvious trends, as noted In the report, and
Indicates that upjradlent and/or ubiquitous sources of contaminants likely
txlst. The sedtaent data My Indicate several Instances of Isolated
contairl nation, 1n addition to an apparant upgradltnt contamination
toi'-ce(s) on Pond Creek, (see, e.g., SE 1 I 12). High levels of PAH'S,
(198S?)
-------
-8-
phthalates, and other compounds were detected as fir upgradlent is Jernee
N111 Road. The Isolated Instances of sediment contamination Involve
concentrations which only slightly exceed the Regulatory Standard to which
they are compared In the report. The reported "high concentrations" of
Avochlor 1246 and 1260 In SED 14, discussed on page 6-10. Is disputed.
These compounds were detected 1n three samples at concentrations ranging
from 1.3 ppm to 5.2 ppm. The referenced HODEP Soil Cleanup Standards
range to 5.0 ppm. Based on this analytical data, contaminant migration
via leachate seepage from Sayrevllle Landfill III appears minimal.
It 1s felt that a further discussion of $1te hydrology as 1t relates
to landfill leachate 1s warranted In the report, as these conclusions ce-
significantly effect the remedy selection process. It 1s Inferred fror
the report that no active leachate seeps were noted during this
Investigation, as none are reported. Based on the age of the Landfill, 1t
1$ quite possible that the major leachate production cycle has conclude;,
and that generation of leachate at this time 1s predominantly controlled
by Infiltration of water, such as precipitation. Page 5-24 of the report
Indicates thtt precipitation 1s the only source of recharge to Sayrevllle
Landfill III. No tidal Influences upon the Landfill were observed durln;
this study as Indicated on page 6-16; 1n fact the 'wasteful fluids"
themselves were determined to be perched on the underlying alluvial clay.
as discussed on page 5-23. Based on this, tidal "washing" of the Landfill
materials 1s not a threat to leachate production.
As a result of these findings. It can be summarized that future
l*e:U*.e production can be controlled through minimization of the
principal form of recharge to me uanonii » precipitation, sucr. a
control would essentially render harmless any remaining contaminant
toupees and litigate the threat of future potential discharges from the
landfill.As this conclusion 1s critical to the remedy selection process.
It should be Included In the report.
(1989P)
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ATTXCHX2KT
OQKXZKTS
DRAJT HZ KID I XL IHVXSTIOXTIOK RXPORT
SAYRIVILLZ XAKDPILl ZZZ
•
1XXCUTIVI SUXXXKY '
1. Page'ES-2: The tern "limited light industrial wastes" is vague.
It should be clearly defined in the Executive Sunsary and
Introduction of the report "as used -hereafter." The. tenr, appears
to refer to the wastes described on Pages 3-4 and 4-10: "Industrial
waste included plywood and plywood containers, sheet netal,
autorc-rile parts, and a canvas fire hose." This waste appears tc
be in the nature of "bulky wastes" permitted under the landfill's
registration perrit. If the ten "industrial wastes" is intended
to refer tc these saterials, it should be deleted to avcid
cor.fusicr. with regulatory definitions. The particular wastes
should be specified.
2. Page ES-2: Descriptions in the report of allegations that
"hazardous wastes" were disposed of at the landfill are vague and
lacking dccurentaticn. What is »eant by this terr, should be
clearly defined. All sources and documentation should be
identified.
3. Page IS-2: "Development of the site apparently involved disposal
directly en the aeadovxat covering the wetlands, and lateral
expansion across the tidal flats."
ADD: "The wastefill saterial was placed over
the existing »eadovsat with no apparent prior
excavation." (Page 7-6}
4. Page ES-2: "... the facility is therefore subject to daily
tidal as veil as flooding inundation by the South River." This
observation is contradicted by the water level »easurenents and //
other data obtained during the investigation indicating that this
is not the case. It is inconsistent with the findings that the
wastefill fluids are perched above the natural groundvater table
(Page ES-2) and that the water levels in the wastefill wells are
not subject tc significant tidal influence (Page 5-23).
5. Page £5-2: States that the South River's designated uses are
•primary" and "secondary" contact uses.
* ^^^^
ADD: "However, existing use restrictions, which prohibit
watersXiing for safety reasons, reduce the potential for
contact and huitan txposure. See, N.3.S.A. 12:7-16.1 «t
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seq., and DEP, Bureau of Boating Regulations codified at
K.J.A.C. 7:6-1.1 H »eq."
6. Page IS-6: The observation that some sediment »etals exceed
•NJDEP Coil Cleanup Objectives" is confusing and should be
clarified or eliminated. First, it should be noted that KJDEP Soil
Cleanup Objectives are not promulgated State regulations and they
therefore do not constitute applicable or relevant and appropriate
requirements ("ARARs") under CERCLA. This comment is consistent
with DEP's comment (Michael Burlingame undated letter) concerning
Black and Veatch's ARARs report of March 6, 1989. Secondly, the
conclusion that such levels are exceeded appears mistaken or out
of proper context. Elsewhere the report finds that the levels of
aetals detected in the soils are generally consistent with metals
in New Jersey and Eastern soils and not attributable to discharges
fror. the landfill.
7. Page ES-6: "The principal environmental concern raised . . . ."
NSZ TO; "At the commencement of this investigation, .
the principal concerns were . . . ." Based on the
results of this remedial investigation, the principal
concern is limited to the actual and/or potential
•migration of contaminants from hazardous substances or
wastes in Sayreville Landfill III into the shallow
aquifer and the South River. The underlying Koodbridge
cley confining layer has been an effective aepjitard which
has prevented the migration of contaminants into the deep
aquifer ever, if, which has not been determined, the
potential for such migration otherwise existed."
•ECU OK i.O INTRODUCTION
1.1 Cite Background
6. Page 1-1: "... it is alleged that there are still several
hundred [drums] present [37, 47, 48]."
CHANSE TO; "... has been alleged that as aany as
several hundred drums may be present. However, the drum
investigation and excavation project during phase 2 of
the remedial investigation uncovered fewer than three
dozen drums and does not support these earlier
estimates."
Tbe source information for earlier drum estimates is not adequately
identified. The only reference appears to be US EPA, 1982, KR5
RanXing Sheets (37). XI I/ supporting documentation should be
identified. —
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9. Page 1-1 : "The Bite is ewnad by Quigley Corporation, a
subsidiary of Pfizer Chemical Company, and vac leaked . . . ."
This sentence regarding site ownership is inaccurate.
sr TOi «A >ajor portion of the site is presently
owned by Pfizer Inc. Quigley Company, Inc., a subsidiary
ef Pfizer Inc., leased the site to the Borough ef
Sayreville from 1971 through 1977 for the disposal of
" Municipal wastes."
10. Page 1-1: "The wastefill area covers plots ef land owned by
Pfizer, Inc; . . . ." This ownership description of the wastefill
area is inaccurate and incomplete. Celotex Corporation does not
own any portion of Sayreville Landfill. Ill and its name should be
stricken. On the other hand, the owners of Block 56, Lot 1A
(former Var? Chemical Resources, Inc. and Rico Transportation Co.,
Inc. site) are omitted. Block 58, Lot 1A is part of the site and
wastefill area (see Page 1-2 and Figure 1.4) and their names should
be included in any ownership description.
«. . . and C.E. Laslo, J. Polak and T. Polak (Block
5E, Lot 1A, the former site Vamp Chemical Resources
Inc.).11
ALEC A??; "An abandoned 10,000 gallon tank is located in
the rear triangular portion of Block 58, Lot 1A.
According to earlier DEP records, this tank is similar .
to a 10,000 gallon tank used by Var.p Chemical Resources
or. this property for the transfer, storage and disposal
of bulk liquid Cherical wastes."
11. Pare 1-3: "Sometime after March 1971, the NJDEP denied the
Borough a permit." This is incorrect. DEP did not deny the
Borough an operating permit.
CKlvss TO; "On July 23, 1970, Sayreville received from.
DE? ar. approved registration permit for operation of the
landfill for the disposal of municipal and bulky wastes.
Between 1571 and August 15, 1977, the landfill operated
under DIP Registration No. 1219B as an approved solid
waste disposal facility. Sayreville ceased landfill
operations and closed the landfill on August 15, 1977.
Subsequently, Sayreville implemented an engineering
closure of the landfill approved by the Department,
including finel grading, the installation ef drainage
structures and methane vents, and the construction ef a
landfill cover consisting of two feet of soil capable ef
supporting vegetation on the top snd ene foot of such
soil combined with one foot ef clay on the slopes."
(REFERENCES: See DEP letters dated September 10, 1979 and
November 20, 1979, copies ef which are appended hereto
in "Attachment 3.")
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All aistaken alligations or iaplications in 'the report that
Sayreville failed to provide a proper landfill cover required by
D£P should be deleted.
1.2 Valuta tad Szte&t of Co&cera
12. Pe-ge 1-3: "The principal environmental concern raised . . . ."
* CHANGE TO: "At the coanenceaent of this investigation,
the principal environmental concerns were .... Based
upon the results of this investigation, the principal
concern is li&ited to the potential for leakage of
hazardous waste aaterials or substances into the shallow
aquifer and migration to the South River. The underlying
Voodbridge/South Aaboy Sequence, clay layer appears to
have been an effective aquitard that has prevented
contamination of underlying deep aquifers."
2.3 Previous laveatigatien*
13. Page 1-4: "The 1975 groundwater aonitoring syster . . .
elevated levels of . . ." The "elevated levels"
characterization is cisleading and should be deleted. It seezs tc
icply th&t the 1575 sonitoring data results were out of the
ordinary for a sanitary landfill. This was not the case. As noted
by Kooivard-Clyde, aonitoring veil analyses during the landfill
operation shewed parameters nor&al for a sanitary landfill (44).
Moreover, analytical parameters of. the vastefill obtained in the
subject reredial investigation are consistent with those of a
typical solid waste landfill (Pages 5-36 to 5-39 of the report).
CKASSr TO; "Early analytical results fror. this .
ground.ater aonitoring syster. revealed paraseters
• considered norcal for permitted solid waste landfills
(44)."
14. Page 1-7: "On April 16, 1981, the New Jersey Division of
Cririnal Justice sacpled the site . . . ."
CLAP.IFY! "On April 16, 1981, as part of a confidential State
crirj.nal investigation into alleged illegal disposal practices
by V&rp Che&ical Resources Inc., the New Jersey Division . .
. ."
15. Page 1-7: "Pesticides, and acids were also detected in these
druas [313." The reference "131]" appears incorrect. The correct
reference appears to be "[41]."
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Sectioe 1.4 iusaary cf Investigations
16. Page 1-12: The report indicates that elevated levels of
pesticide vere found "... in the outfall to Pond Creek."
.. in the DuPont chemical plant discharge
outfall . . . ." (See Pages 3-10, 6-3, 6-7 and 6-10.)
MCTXOK 3.0 HAZARDOUS iDBSTAHCES INVESTIGATION
S.i Watte Types aafl Quantities
17. Page 3-1: "... which also accepted limited light,: industrial
wastes."
See Cosr.ent No. 1.
18. Page 3-1: " quantities of hazardous wastes . . . and following
its closure in 1977." As noted above, the report provides sparse
documentation for the allegation of post-closure dumping. The only
reference here is "(^S)" which only vaguely refers to "Var.p Bill
of Ladings - ." These bills of lading should be specified. All
other documentation relied on for this allegation should be
identified.
'19. Page 3-1: Sets forth estimates of tonnages of solid waste
disposer of at the landfill allegedly based on annual operational
stater-arts. Estimated tonnages appearing in this section of the
report are partially undocumented and appear exaggerated. The
source for the 1571 tonnage estimates on page 3-1 is unknown. For
1975, the annual operating statement estimated 23,250 tons; the
133,000 tonnage figure used on page 3-1 is undocumented. These
figures should be checked and corrected as appropriate.
20. Page 3-1 "In addition, manifests fror several sources indicated
that hazardous wastes were disposed at the site." These
•sanifests1' are not identified. Provide specific documentation.
21. Page 3-2: "Additional quantities of hazardous wastes . . . and
after landfill operations ceased in 1977 147)." (3-2)
See Comment No. 18.
22. Page 3-6: The report fttates that 28 druas were excavated and
sampled.
+
See General Comment No. 14.
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fSCTJOK 4.0 OBOLOC2C XKD XYDROOBOLO02C ZVTZB720ATZOM
23. Page *4-5: "The wastefill is covered with about two feet of
•oderate brown coarse to fine Band." The report'* descriptions of
the landfill cover appear to be based en a superficial visual
inspection and are not accurate. They fail to taXe into account
Sayreville's closure of the landfill in accordance with a Dip-
approved closure plan, including construction ef the approved
landfill cover described in the General Co&sents.
CHA.VSS TO; "The vastefill was capped with a cover
approved by DEP, as part of an approved closure plan,
consisting of two feet of soil on the top surface capable
of supporting vegetation and one foot of clay covered by
one foot of soil capable of supporting vegetation on the
landfill side slopes." (SEE XBDVE REFERENCES.)
•ECTZOK 5.0 GRDUXDWATER XHVZ6TIGATXON
S.I Background
24. "Irpcrtar.t dates" (Pages 5-1 to 5-2):
• "1577 . . . earth cover . . . ."
CO?.-.* r?: "... cor±ined clay and earth cover in
arccrcar-ce vith an NJDEP-approved closure plan."
• "7/19E1 . . . licited sar.plings by KJDEP of the South
River water end sediaent near the landfill reveal
ansr.alrus erounts of organic cocpounds [47]."
The source of this allegation is not identified. "[47]"
is out of place and applies to the earlier part of the
paragraph. The meaning of the vague "anomalous"
chararterization of the results should be explained or
the terr. deleted. The nature, location and significance
of this stapling should be explained or the results
deleted. Compare Page 6-3 reporting "less-than-value"
results.
• *7he principal anvironaental concern raised by
Sayreville Landfill ....*•
See Cov&ent No. 7.
I.) Grou&dvater Jissesssazit
25. Page 5-22: "There say therefore be leakage through the South
A&boy/Vaodbridge day in this area . . . ." This statement is
wholly unjustified and unsupported by the objective hydrogeologic
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and analytical data ?ather«d in the investigation. The data
compels the contrary conclusion that leakage into the Farringtor.
aquifer has not occurred and is not an environmental concern.
See HART Comments.
S.4 ffrou&dvater Quality Evaluation
26. Page 5-29: Describes 1976 monitoring veil analytical results.
See Consent No. 13.
27. Page, 5-35: Regarding the deep veils, the report states that
•significant elevated concentrations of heavy metals nay be
attributable to migration from the vastefill." Settlors, maintain
that this conclusion is wholly unjustified and unsupported by the
data.
See HART Comments.
26. Pages 2-6, 9-6 and others: State that the Farrington Aquifer
ground-water flows toward the South Ajr±>oy and Sayreville veil
fields. The basis for this statement should be provided and
documented. The potentiometric naps indicate a groundwater flow
southward. To settlors' understanding, the Sayreville veil fields
lie east of the landfill. A sap should be provided indicating the
geographic relation of the vellfields to the landfill. The
pettlcrs find no basis for finding any impact vhatever by the
landfill or. these vellfields.
29. Page 5-37: Reveals the presence of organic contaminants in
sever line which nay indicate industrial contar.inants. In light
of this data, the report ahould discuss the possibility that the
sewer line is a source of landfill contar.inants. It should else
discuss the possibility that installation of the sewer line v.ay
have created or aggravated site conditions by disturbing the
landfill cover and drainage i&prove&ents.
S.4.5.2. tastefill Monitoring Well Data
90. Page 5-36: "Proposed maximum contaminant level goals are levels
to which specific compounds should be remediated.*' This
observation is erroneous and should be deleted. Neither
groundwater nor surface vater at or from the site are drinking
water sources. Furthermore, '-proposed maximum contaminant level
goals are not ARARc. At best, they are standards "to be
considered" ("TBC's") in a feasibility study. See Comment Ho. 19
Of DE? (Kichael Burlingame undated letter) on Black ft Veatch's
ARARc report of March 8, 1989. .__
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31. Pages 5-36 to 5-39: 'Find that vat*r quality data from vast*fill
•onitoring veils indicate approximate conformance with typical
sanitary landfill performance. This conclusion should also be
stated in the Executive Suaaary, Section 1.4, Section 9.0 and new
•Conclusion."
•ICTIOii f.O lURJACZ WATZR XWZBTZOATXON
32. Page €-3: "July 29, 1981 sampling program by DEP . . . ."
See,Comment No. 24.
33. Page 6-7: Reveals that the DuPont chemical plant discharge may
be contributing to increased vater-o^ality parameters exhibited at
the SV-3 and SK-4 sampling points downstream from the discharge.
This finding should be stated in the Executive Summary, Section 1.4
and new •'Conclusion.11
34. Page €-10: Reveals that pesticides "were detected in high
concentrations in SED-14." This sar.pling point was established tc
deterrine the potential contribution Iron the DuPont plant
discharge outfall (Page 6-3). This finding should be stated in
the Executive Summary, Section 1.4 and new "Conclusion."
A??: "... in the immediate vicinity of the DuPont
plant discharge outfall."
SECTION 7.0 BOIL XKTZ6TIGATXOX
35. Page 7-14: States that metals concentrations in the "soils" in
the vastefill and off-site are consistent with those normally found
in Nev Jersey and Eastern United States soils and that the
vastefill does not appear to be the source of metals found in soils
occurring outside the vastefill. This finding should also be stated
in the Executive Summary, Sections 1.2, 1.4, 9.0 and new
"Conclusion."
•ECTXOK 9.0 PUBLIC EIXLTE AXL IKVIRONXZNTA1 CONCERNS
36. Page 9-2: "Refuse is visible in the fill area where little or
no cover soil has been applied." The latter observation is vholly
speculative and unwarranted and should be deleted. As noted
previously, a DEP-approved closure landfill cover was implemented
by Sayreville after the landfill vas closed. Visible refuse and
araas lacking cover are »ost likely attributable to unauthorized
post-closure dumping and post-closure excavations and
investigations which did not properly restore the original cover
and drainage, including the 1977-19.18 axcavation by the MCUA for
installation ef the sewer interceptor under the landfill
(REFERENCE: see DEP letter dated June 14, 1978, copy appended
hereto in "Attachment 3"), the 1981 excavations during the
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investigation by the Division ef Criminal Justice, And possibly
•xcavations during the subject investigation.
37. Page 9-2: "A vegetative cover was installed . . . • This is
inaccurate.
CHANG! TO; "Sayreville implemented an engineering closure
ef the landfill approved by DEP, consisting of final
*• grading, the installation of drainage structures and
•ethane vents, and the construction of a landfill cover
consisting of two feet of soil capable of supporting
vegetation on the top and one foot of such soil combined
with one foot of clay on the slopes'."
38. Page 9-3: "The roadway entrance from Jernees Kill Road is open
and vehicular traffic can access . . . ." This is incorrect. The
roadway entrance to the landfill has been secured preventing access
by vehicular traffic.
39. Page 9-5: "... vacant prime connercial land border the
landfall site . . . ." Settlors are net aware of any real estate
appraisal or other basis for this statement. It should be deleted.
40. Page 9-€: "A 45-inch diameter interceptor sewer line buried .
• * *
ATt: " Based -upon sar.pling and analysis of the sewer line
effluent, this sever line is a potential source of hazardous
sur-star.ce discharges at the landfill due to the potential fcr
breaks and exfiltration. Installation of the sewer line may
also have seriously disrupted the closure of the landfill,
including its drainage and landfill cover, contributing tc
site conditions."
41. Page 9-6: "Industrial establishments . . . located upgradient
of the landfill nay affect the background water quality." As it
pertains to Vacp Chemical Resources, this statement is not
accurate. The rear triangular portion of the former site of Var.p
Chemical Resources (Block SB, Lot 1A) is part of the landfill (see
Page 1-2 and Figure 1.4). While as noted this property nay be a
source of contaminants at the landfill, it is an on-site source not
upgradient of the landfill.
42. Page 9-6: "... direct contact does, however, remain a
consideration."
CLARIFY: " . . . direct contact does, however, ramain a
potential consideration."
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43. Page 9-6: Explain the relevance of the discussion concerning
the Couth River classification between the Duhernal Lake and
Sayreville Water Department. The South River is classified SE-l
adjacent to Sayreville Landfill III.
44. Page 9-7: "... the South River would be classified as having
uses for both 'primary' and 'secondary' contact recreation."
'However, the potential for direct contact is
reduced as a result of recreational use limitations,
including statutes and DIP regulations governing the
South River in the landfill area which prohibit water-
skiing for safety reasons (i.e. . physical hazards).
K.J.S.A. 12:7-1 tl scg. t K.J.A.C. 7:6-1.1 £l aea."
45. Page 9-7: "Sediment within the river nay be contaminated . .
. particles transported to the river from the landfill . . .
contaminants free potentially contaminated groundwater as it
discharges . . . ." The report pays insufficient attention tc
Kpstrea- sources of contamination.
9.4 Public Eealtb Xssessme&t
46. Page 9-6: The report states that "samples collected at the
Sayreville well-field indicate that a minimal immediate threat .
'. . exists at the present time." Settlors object to this statement
because nothing in the data indicates that Sayreville Landfill III
impacts on the Sayreville wellfields in any respect.
47. Page 9-9: "It is imperative that since this preliminary
evaluation of public health impacts is based only on one sampling
ever.t . . . .* "One sampling event," also used on Page 9-10,
appears incorrect. Phase 2 of the RI provided a second round of
sampling.
46. Page 9-1C: "... environmental impacts created by the.
Sayreville Landfill site are minimal at present." The relevant
data and factual support for this minimal public health assessment
should be summarized in this narrative.
49. Pages 9-9 to 9-10: Conclude that remediation will include a
future detection monitoring program to evaluate potential future
health and environmental impacts of the landfill. The basis for
this conclusion is not explained. Firm conclusions about
remediation should be reserved for the Feasibility Study and public
health and risX assessments.
50. Table 9.1: Table title reads "... Which ere Likely to be
Contaminated."
CHANGE TO: «... Which Kay Be Impacted."
10
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10.0 iuaaary ef Data Caps
f
51. Page 10-2: "It is reasonable to predict future discharges fror.
the site with a high degree of reliability.*1 This confident
prediction at the end of the report is overstated and unjustified.
A prediction of future discharges with "high degree of reliability"
is nonsupported by existing data and findings in the report. Ever,
if the potential for future discharges is a concern, this does net
jurtify the leap in logic that such discharges are highly
predictable.
11.0 Ccnclutior. (Mev)
52. The report should add a "Conclusion" section cu&aarizing its
critical findings and conclusions. .
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i •" ' .*
V.I ;-/» '.'i ' '; .. REPEPEKCES
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;itr nf ftrui 3/rrnri|
DEPARTMENT OF ENVIRONMENTAL PROTECTION
• OUID WASTt ADWI
TUCNTON e»«ie
»«4t«ICS • tTltllVI
September 10, 1979
n riiiML-i , r.i:.
oiM l.ii];iuciM jug , Inc.
Offj.'t- Hox Mlft
Hil.-iu-.iii, Nr.. .Jersey 07747
II.1:: S.nrrvillc BcTn:ig!i 5ar,it":y Landfill, Sayrcville
.x Co;j;;ty, TacJlity Hr^istvaiJOii N;r.il>er 1219B
Item- K; . Cli;- ic-J :
1.: !.-..: icvicuoi', {lie infon-nt io:'. in our files
a!ii-vc 1 . •.:!.•;'; ]J . Ji.Tse.! u;>o:i your toj'iespnujence a;iJ 01; inspections
by o.ir m.-fr, we a:c preprtreil Jo icvjse tlie final cover require-
in-ii: .IK.' ^.i- vein locations so ilmi the InnJfjll may l>e properly
J.
The fiinl covo' sliall consist on one fool of clay on the land-
fill si lit- slo;v«s covered l>y one fout of soil cnpnhle of support ing
vctr'-'i "»••'• '"'C top surface sli:>l 1 consist of a minim.rr. of two
fed cf soiJ c:ipn!;le of $uj>port iuj; vegetation and shall be graded
antl com; -..-iw ted so as to reduce infiltration of rainwater. AH
su; fnccs sJj.iJ] l>c seeded and shall he naint.iined to prevent erosion.
>i tfi.-i;-/.- p,.-.s vents shall be installed at the 200 feet by 200 feet
:is yuu have previously requested. A copy of tl»e constniction
loi H.TS vcnis is enclosed for your reference.
Mc.-isc mm net Mr. Robert IViwclJ at (609) 292-0415 or Mr. John
O»sinr> at (6n.O) 292-02^0, both of my siaff, regarding a completion
dale cr lit'.- ;I!KIVC rcquitcmcnts su t'»nt **e awy arrange a final in-
§j>cit in:, of il»c fflcility.
Very tmly yours,
W.iltrv Ikirslilin, P.H., V.P.
Oiicf, Ijujincci jnt auu la» for cement
ec: i>liry .1. Kos:ikuwsVi, Boro»iph Clerk '
Htisscll Meyer, Su]>t. of Roads .
b~f}
(
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Y
£iaif of Sffu> 3ff rsrij
DEPARTMENT OT ENVIRONMENTAL PROTECTION
OIVIHON er ENVIRONMENTAL OUAUTT
JOHN PITCH ruA.1*. CN 017. TACMTON N. J. O««ll
Solid Wane Administration
November 20, 1979
Mr. Anthony Forliri
Schoor, Df PaliM'ft Gillen, Inc.
P.O. Be* SOB
Mata*ar;, he- Jersey 07747
R£: Sayreville Borough Saniter/ Landfill, Middlesex County,
Facility hurrier 12196
Deer Mr. Fcrlinl :
T^.e Sclid Waste Adr.-inistration has reviewed your propcial for
revi$i:".s tc the closure plan fcr the above landfill contained in
yo.'- lette- dated hsven&er S. 1575 and the plan reviled October 25,
1575 These revisions provide for the installation of permanent
drainaje structures in order to prevent the recurrence of erosjor,
on the'landfill $ide slopes due to stonrwater. Also, the locations
for methane pas vents have been changed to provide gas venting only
• lor; the eastern portion of the Undfill.
This Ai-inijtration has determined that the proposed revisions
ire acceptable. The Borough of Sayreville may, therefore, begin in-
stallation of the drainape pipin; and the methane gas vents as
delineated on the October 29, 1979 plan. Upon completion, please
contact Mr. Alan feczoroski ef ty staff, »t (609) 9B«-«DE3, to
arrange for a final Inspection.
Fiease be advised that this approval in no way alleviates the
ftoroucVs responsibility for mintaining the closed landfill in a
•inner that will prevent environmental hazards.
yot have any further Questions, pletse contact Mr. John
Castrver at (fcD5) 292-02AD. ._
Very truly yours,.
Walter lurshtin. P.C., P.p
Chief, Engineering ft Enforcement
Solid Waste Administration
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§Jalr jtf Krut
DEPARTMENT OF ENVIRONMENTAL PROTECTION
• DUD WAtTC
THCNTON. O»(2S
•(««•!€( • »•*.«"«'
»MIt»«
June 14, 197B
Mr. Edward Nyland
c/f> George Hariri Construction Company, Inc.
Post Office Box' 1?6
Pequannock, Me* Jersey 074O
Dear Mr. Nylan;: . :
R£: Disruptie-. of Sayreville Bc-o SlOA uncer Middlesex County
Contract f3:-B Solid l/oste Administration 1DM219I
On June It, 19"' ye.-- firr. stbr.itte- ar, applicatior. ani an engineering
the disruption cf- a portion of the SeyreviUe Borough SWDA.
On September 15. 1S"7 the Solid'li'aste Adr.inistratior, approves that Ctsicn er.j is-
sued a Certificate cf Approver Re^stration end Dcsipr, JDr 12151.
con-if-ta'v pc-'tior of you' $uD"ijsioi, under the heading cf "f/peret iir.;l
pere:*i;* r.j-.^e' nine stites. "Nomaie'ial will be storci on sue-. I.-; ui'
be prope*1> re-i'epc-s*. tei. spree; an; covered im-ciiately in anotlier 1ocav.tr, in
the lancfHi. Lx:«.«;e: areas will be filled with suitable fill Mtcnal."
On March 31, 15"£ an; arjiin on June 7, 1978 inspections of the lite >.ere 'condjcte
by iolid Uastc- personnel. These inspections disclosed that disrupte: w.erol ni
not been prope-l.y re-deposited, spread, and covered, but ratner nad jus; bee- lef
in piles or, site. This constitutes a violation of N.J.A.C. 7:26-2. 2. < whur. is
punishable fc> a c.n\r.*r. penalty of S3, 000 per day.
This excavate; r.i'.erial injst be properly re-deposited, spread, and covered ty
, We.
If you have ar.v questions rentrdinn this •tatter, please contact Andrew Kniecik Jr.
or John Castner, of «ny Jtaff «t (GOD) 292-76<6 or (609) 292-0241.
Very truly yOuri,
aher Burshtin. P.E..P.P.
Chief, tnoineerinp I Enforce.^ent
Solid Waste Administration
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Responses to comments OB tne Draft RI Report/, dated March 20, 1990,
to Neal Brody, dated Kay 2, 1990, from the Borough of Sayreville;
Celotex Corp.; Chevron Chemical Co.; Hercules, Inc.; Mobil Chemical
Co.; and Ruetgers-Nease Chemical Co., Inc.
NJDEP forwarded the responses below to the parties above on July
5, 1990. Many of the comments involved requests to amend specific
language of a document which was issued prior to this record of
decision. The comments are, therefore, irrelevant to the issuance
of this decision. However, the full text of NJDEP's response is
included because some of the changes have a substantive impact on
selecting the remedy. Wherever the response is made below that
"adjustments will be made as required", the text of the RI report
has been changed to reflect the Committee's comment. Many of the
Committee's comments requested changes in wording to the draft RI
report. These were not thought to affect the technical ideas
communicated in the report. Therefore, it was felt that the
NJDEP was under no obligation to reword the report. In these
cases, the response was made that "this comment will be
considered".
Fred C. Hart Comments
1. Specific comments submitted by Hart are answered below.
Other General Comments
1. The title on the cover of the report is "Remedial
Investigation". No change is required.
2. The Executive Summary will consider inclusion of the
findings itemized in your Comment #10.
3. Adjustments will be made, as required, to the Report.
4. Adjustments will be made, as required, to the Remedial
Investigation Report. A "Conclusion" section will not be added
to the Report. When this RI/FS contract was awarded to the
contractor, a "Conclusion" section was not required in accordance
with EPA guidance. B&V will not be required at this time to add
this section and perform extra work due to changes in EPA
procedures. The Executive Summary, however, will be.improved to
include what vould otherwise be included in a Conclusion section.
5. Risks posed by the site will be addressed in detail in the
forthcoming Risk Assessment Report.
6. Risks posed by the site will be addressed in the forthcoming
Risk Assessment Report. Sampling and analysis of the groundwater
under the Landfill indicates that the water quality has been
degraded in the shallow aquifer. These finding disprove your
argument that the peat layer acts as a "natural liner preventing
-------
or severely retarding the migration of hazardous substances".
*
7. Definitions o'f industrial waste are given in Sec. 3.1.1. A
definition of hazardous waste will be added and the language
added, "as found throughout the Report11. '•
8. A better map will be located and inserted into the Report.
9. Adjustments will be made as required.
10. See Response |2.
11. Adjustments will be made as required.
12. A clearer definition of hazardous waste, as defined in the
CFR, will be included.
13. The Report presents the data from all of these other
potential sources of contamination, except for the storage
tanker, which will be added. The forthcoming Risk Assessment
will discuss contributions to the stream contamination from the
Landfill and from off-site sources.
14. The drum inventory logs are field records and cannot be
altered. Video tapes of the drums are also available. For the
purposes of this RI, the technical information obtained from the
druir. investigation is sufficient.
15. A separate section will be added to the Report discussing
the drum investigation and findings.
16. Adjustments will be made as required.
17. Although the plans for Landfill closure were approved, the
field construction never was approved. The Report will be
clarified to reflect this point.
18. Adjustments will be made as required.
19. No response is required.
20. The Landfill is subject to flooding by the South River. The
south-west portion of the Landfill lies within the 100-year flood
plain. Monitoring Well #5 (MW-5) showed regular water level
fluctuations that can be correlated to tidal fluctuations in the
South River, as did KW-1D, MW-4D and BPT.
21. Agreed. While it may be difficult to predict releases from
the Landfill with "a high degree of reliability", the general
nature of the releases (composition, concentrations, etc.),
however, could likely be reasonably predicted.
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22. Adjustments will be made as required.
23. Adjustments will be made as required.
24. A request is made at the end of the letter for information
which should be located in NJDEP files. The Freedom of
Information Act allows you to request and arrange a review of
these files, at which time you could obtain the information
requested.
Comments from Dennis Farley. HART, dated April 2?. 1990
1. -. a. "No hydraulic communication" has not been proven
definitely, although the analytical results indicate minimal
leakage across the Woodbridge Clay. Note that the 60 -. 70
ft thickness referred to does not consist completely of clay
and silt.
b. It is highly speculative that the tidal loading of the
Raritan estuary in the vicinity of the Washington Canal and
the mouth of the Raritan River would cause the water level
fluctuations shown in the data. It is true that pumping of
the Farrington has caused salt water intrusion into the
Farrington.
c. See response below.
2. The attached Memorandum from the NJDEP Division of Water
Resources, by Dave Kaplan, shows the degree to which the shallow
Alluvial/Cape Kay aquifer has been contaminated. Concerning .the
potential connection between the South River and the Alluvial
Aquifer, the health risks will be evaluated in the forthcoming
Risk Assessment Report. Note that ECRA Surrogate Action Levels
are not ARARs. The hydraulic connection between the ground
waters in the vicinity of the site and the South River is
intuitively correct and consistent with published reports for the
area.
3. The environmental and health risks posed by stream
contamination from both on-site and off-site sources will be
discussed in the forthcoming Risk Assessment Report. The
conclusion that precipitation is the major cause of leachate
generation will be considered for inclusion into this Report.
Attachment 2- Specific Comments
1. Definitions of industrial waste are given in Sec. 3.1.1. The
language will be added, "as found throughout the Report", after
the definition is given.
2. "Hazardous waste" will have the same meaning as provided in
40 CFR 261.3. In general, a waste is considered hazardous if it
-------
exhibits ignitability, corrosivity, reactivity or if it exhibits
the characteristics of EP Toxicity.
' t
3. This comment will be considered.
4. See response to comment 120 above.
5. Because the South River is designated for primary contact
uses, swimming is included. Although water skiing is prohibited,
human contact is still possible. The Risk Assessment Report will
further discuss health risks associated with these activities.
6. This comment will be considered.
7. This comment will be considered.
8. This comment will be considered. The HRS Sheets are the only
source of this earlier drum estimate.
9. Adjustments will be made as required.
10. Adjustments will be made as required.
11. This comment will be considered and adjustments will be made
as required.
12. This comment will be considered.
13. This comment will be considered.
14. Adjustments will be made as required.
15. Adjustments will be made as required.
16. Adjustments will be made as required.
17. See response 11.
19. The estimates will be checked.
20. A reference will be provided.
21. See response #18.
22. See response 122.
23. Although the DEP-approved closure plan nay have specified a
composite soil cover for the Landfill consisting of clay and soil
fill, visial site inspections and RI soil borings indicate
otherwise.
24. These comments will be considered.
4
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25. No response required.
26. See response 113.
27. No response required.
28. This comment will be considered and adjustments will be made
as required. A site nap shoving the locations of these well
fields will be included in the final Report.
29...The discussion of the sever line on page 5-33 vill be
clarified as to whether it is a potential source of
contamination. We vill not speculate on the possible impact on
the site conditions caused by excavation of the sever line.
30. The ground vater in the shallow Alluvial/Cape May aquifer is
classified as GW-2 by the NJDEP Division of Water Resources.
Drinking vater standards are, therefore, applicable.
31. This conment vill be considered. A "Conclusion" section vill
not be added to the Report. When this RI/FS contract vas avarded
to the contractor, a "Conclusion" section vas not required in
accordance vith EPA guidance. The contractor vill therefore not
be required at this time to add this section and perform the
extra work required due to changes in EPA procedures.
32. See response #24.
33. See response $31.
34. See response $31.
35. See response #31.
36. See response $23.
37. See response $36.
38. Adjustments vill be made as required to the Report.
39. This comment vill be considered.
40. This comment vill be considered.
41. Adjustments vill be made as required to the Report.
42. This comment vill be considered.
43. Discussion of the classification of the South River in the
vicinity of the Sayreville Water Department is of importance
because of the vater intake located in the vicinity of the Water
Department.
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44. See response #5;
45. Detailed consideration of health and environmental risks will
be provided in the forthcoming Risk Assessment Report.
46. This comment will be considered.
47. Adjustments will be made as required to the Report.
48. This comment will be considered.
49.,.This comment will be considered.
50. This comment will be considered.
51. This is a professional opinion, however, this issue will be
discussed further in the FS.
52. See response #31.
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ATTACHMENT B
-------
July 23, 1990
HAND DELIVERY
Neal Brody, Esq. Mr. Michael Burlingame
Office of Regulatory Services Site Manager
NJDEP NJDEP ;
410 East State Street Division of Hazardous Site
CN-402 Mitigation
Trenton, NJ 08625 CN-413
Trenton, NJ 08625-2902
R»: EPA and DEP Comn«nt» on tb« Draft Remedial Investigation
Report
Bavreville Landfill III
Dear Kr. Brody and Mr. Burlingame:
This letter is respectfully submitted by the signatories to
the Agreement and Administrative Consent Order entered into en
October 28, 1986 ("Site Committee") in connection with this site.
The purpose of this letter to respond on the record to comments
prepared by the New Jersey Department of Environmental Protection
("DEP") and by the United States Environmental Protection Agency
("EPA") concerning the draft "Final Remedial Investigation Report"
dated March 20, 1990, prepared by B & V Waste Science and
Technology Corporation ("RI Report"). The Site Committee requests
that these comments and its original comments on the RI Report
submitted on May 2, 1990, as well as all other correspondence it
has had with DEP concerning this site, be made a part of the
administrative record.
BACKGROUND
On March 20, 1990, the RI Report was issued by B & V Waste
.Science and Technology Corporation. By letter dated May 2, 1990,
the Site Committee submitted comments to DEP on the RI Report.
Copies of the Site Committee's comments were simultaneously
forwarded to EPA.
The Site Committee's prior comments on the RI Report
incorporated comments in a separate memorandum dated April 25,
1990, prepared by Fred C. Hart Associates, Inc. ("HART"), an
independent consultant retained by Site Committee. In those
comments, HART concluded from its review of the RI data, among
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other things, that:'• '
(1) there is no basis to argue possible "leakage" of
landfill contaminants into the deep Farrington aquifer
(all hydrogeologic and analytical data compel the
contrary conclusion that contamination of the deep
aquifer is not an environmental concern).
(2) the RI data does not support a finding that there is
a significant migration of hazardous substances from the
landfill into the South River.
(3) the RI report shows that the contamination of the
shallow aquifer under the landfill is minima] and of
limited concern. " .
(<} a water quality subclassification of the shallow Cape
K&y alluvial aquifer or waiver of water quality
standards, if applicable, is justified based upon well-
documented area saline intrusion, the 5E-1 classification
of the river, and the lack of potable water supply
receptors in the area.
Inasnuch as HART'S previous comments pertain to matters covered in
DEP's and EPA's comments, a copy of HART'S previous comments are
appended and made a part of this letter ("Attachment 3").
Since submission of their original comments on the RI Report,
the Site Cor.ir.ittee has had the opportunity to review the comments
on the RI Report prepared by DEP and by EPA. It respectfully
subr.its the following comments responding to comments made by the
governmental agencies.
FRED C. KXRT RESPONSE
In a separate memorandum dated July 20, 1990 to the Site
Comrittee, HART has responded to certain EPA comments on the RI
Report. HART's comments are appended here and adopted by the Site
Comr.ittee ("Attachment 1").
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-GENERAL RESPOKSE
RESPONSE TO DEP COKMEKTS
In response to DEP's comments dated May 4, 1990 on the RI
Report, the Site Committee has the following comments.
7. The statement that there have been no allegations of
hazardous waste disposal on Block 58, Lot 1A, the property
adjacent to Landfill III on the north formerly owned by Ben
and Aaron Rosenblum, where Vamp Chemical Resources, Inc.
("Vamp Chemical") operated its chemical waste treatment
. facility, is incorrect. Allegations of hazardous waste
disposal activities from 1975 to 1978 on Block 58, Lot 1A
exist in DEP's file on this cite. Testimony taken during the
State Grand Jury investigation into the unlawful disposal
practices of Vamp Chemical alleges that Vamp Chemical.
discharged chemical wastes and buried containers of hazardous
waste, including laboratory packs, on Block 58, Lot 1A (for
exar.ple, see January 26, 1981 Grand Jury testimony of John
Gregorio and Thomas Lyngholm (transcript at pages 32-33, 47-
46). Moreover, according to 1984 deposition testimony of
Thomas Kitzi, the president of Vamp Chemical, the owners of
Block 56, Lot 1A at the time of Vamp Chemical's operations,
Ben and Aaron Rosenblum, were aware of Vamp Chemical's
disposal activities (see August 30, 1984 testimony of Thomas
Kitzi, transcript at pages 51-52).
The alleged disposal of chemical wastes on this property is
corroborated by subsequent investigations finding chemical
spills on this property and recommending further remedial
investigation, including: (1) Sayreville Police Department
Operations Reports dated July 7, 1977 (copies attached); (2)
report of Louis Rafano (copy attached); (3) DEP letter datei
Kay 13, 1961 to Dickerson, Devoe and Bolster, attorneys for
Rico Transportation Co., Inc., a subsequent property owner of
Block 56, Lot 1A, confirming a surface chemical contamination
probler. and potential subsurface contamination (copy
attached); (4) Malcola Pirnie, potential Hazardous Waste Site
Preliminary Assessment dated April 2, 1985 (copy attached) ;
(5) the RI sampling analytical data showing that all PCB
arochlor, the elevated contaminant levels of MW-13 and other
contaminants exist on the rear triangular portion of this
property (the RI sampling stations on this property include
TP-6, TP-7, MW-13, SW/SED-2, SW/SED-15 and SW/SED-14, the
latter near the Dupont discharge outfall); and (6) other
findings of the RI Report, such as the existence of an
abandoned liquid storage tank on the rear portion of this
1 The Site Committee's comments are numbered according to the
nur±>er of the DEP comment which they address.
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property resembling one of the storage liquid tanks used by
Vamp Chemical 'for storing and transferring chemical liquid
wastes, and the log of test pit TP-7 on this property
revealing wasteful material.
Furthermore, it should be noted that a portion of Landfill
III is located on this property (see Figures 1.3, 1.4 and
5.1).
Accordingly, the Site Committee respectfully submits that
DEP's comment concerning Block 56, Lot 1A, should be corrected
or withdrawn. Furthermore, the RI Report's treatment of a
portion of this property as part of the Sayreville Landfill
III site under remedial investigation (Page 1-2 and Figure
1.4} is appropriate and justified.
21. DEP's conclusion that no exfiltration from the KCUA sewer line
can be occurring is not justified by existing RI data.
Exfiltration is a possibility (see HART comments, Attachment
1). In the past, the MCUA sewer trunk line has been known to
be operating under surcharge conditions in the general area
of the landfill; resulting internal pressure may have resulted
in exfiltration and the release of contaminants from the sewer
line. The possibility that contaminants from the sewer line
may have discharged or be discharging, contributing to site
conditions, cannot be ruled out.
22. The Site Corjr.ittee disagrees with the position that drinking
veter standards may be considered ARARs for the site. This
is even more so here, where the comment refers to water
quality data from wastefill wells. As found in the RI Report,
the wastefill fluids are perched above a relatively-
This comment should not detract from the Site Committee's
previous comments that the physical installation of the
sewer line in 1977-1978 may have contributed to site
contamination. In 1981, testimony before the State Grand
Jury investigating Vamp Chemical's disposal practices
revealed that Vamp Chemical had discharged bulk liquid
chemical wastes directly into the MCUA sewer line running
under Block 58, Lot 1A, and thence south across the
landfill. In 1978, as pointed out in a July 19, 1990
letter to OEP from counsel to the Borough of Sayreville,
CEP received reports that deteriorated buried drums in
Landfill III were encountered by MCUA's contractors
during the landfill excavation for installation of the
MCUA sever line and then re-covered with vastefill or
soil. Disturbance of—the drums by the MCUA or its
contractors in 1978 nay have contributed to site
conditions.
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impermeable aeadowmat and the shallow alluvial aquifer.
Neither the vastefill nor the shallow alluvial aquifer are
used as drinking water supplies and the potential for such use
is remote. The area is zoned industrial and a number .of
industrial plants are located on Jernee Mill Road. As
previously noted in HART'S comments on the RI Report
(Attachment 3, pages 6-7), there are no potable water supply
receptors in the area due to background contamination levels
in the South River, its SE-1 classification next to the
landfill, background contamination in surface water
tributaries of the South River upgradient of the landfill
.(e.g. see water quality data at SW/SED-14 near DuPont
discharge outfall), and the progressive saline intrusion of
aquifers in the area. A subclassification of the alluvial
aquifer or a waiver front ARARS, if applicable, appears
warranted based on these well-documented conditions. In its
consents on the March 8, 1989 preliminary B i V ARARs
document, DIP discussed this possibility.
33. As pointed out in HART'S previous RI comments (Attachment 3),
the RI data does not support the conclusion that hazardous
substance discharges to the groundwater or the South River are
a concern. See the points summarized in the "Background"
section above. The Site Committee concurs, however, with the
need for a focused conclusion in the RI Report discussing the
significance of all relevant RI data and the overall probler.
at the site. As is true generally with regard to the RI
Report, the failure to express relevant findings and
conclusions, or to adequately document them and discuss all
relevant data, nay render the findings unsustainable or DEP's
administrative record incomplete. The Site Committee reserves
the right to supplement the administrative record with
relevant data and information.
RESPONSE TO EPA COMMENTS
The following comments are submitted on behalf of the Site
Corjrittee to respond to the comments on the RI Report prepared by
EPA in a series of memoranda.
1. Corrections Of Tactual Inaccuracies
Some of EPA's comments are based on major factual assumptions
that are not correct. The Site Committee submits the following
corrections of these factual inaccuracies.
The Site Corurittee's comments are numbered according to the
numbers of the EPA comments or, where no number is assigned to
EPA's corients, according to the numerical order of the paragraphs
of EPA's comments.
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1. The Borough of Sayreville's municipal wells are not
screened in the deep Farrington aquifer. The only Borough of
Sayreville potable well screened in the Farrington aquifer was
pulled out of service years ago due to regional saline
intrusion.
2. Groundwater in the shallow Cape May alluvial aquifer is
rot used as drinking water supply and is unlikely to be used
for this purpose in the future. See previous HART comments
.. (Attachment 3) . .
3. Surface water downgradient of site is not used as a
drinking water supply due t.o salinity, SE-1 water quality
classifications and background contamination.
4. The phenomenon of saline intrusion into the deep Farrington
aquifer creating the high chloride levels and related ground
water quality parameters is well documented in the RI Report,
and is a well-known phenomenon (see for example references
cited on page 5-22). .
5. In view of these considerations, the Site Committee
strongly believes that MCL's are not ARARs for this site.
6. There were at least two wells, and arguably four wells (see
DEP's July 5, 1990 response to EPA comments at Page 4, par.
5), screened in the deep Farrington aquifer and sampled for
contaminants, including two downgradient wells, MW-4D and BPT.
Substantive Comments
1. Based or. the foregoing misperceptions, it appears that EPA does
not have as thorough a familiarity with the site and area
conditions as DEP.
2. EPA's comments about potential concerns fail to take into
account relevant RI data and findings of the RI report such as the
following, further contributing to EPA's misperceptions about this
site:
* The landfill is underlain by a black peat layer of
weadowuat one to five feet thick (page 7-6) providing
evidence that wastefill was deposited over the existing
neadowmat without excavation or penetration.
* Tr.is peat material is a silty, mucky type of material
that is highly .iapermeafcle to water. As noted in the
draft Feasibility Study (FS), this peat layer has
provided *n effective natural liner preventing or
severely retarding the migration of hazardous substances
or wastes front the landfill into the lower aquifer.
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* RI data shows that the migration of hazardous
substances from the landfill and contamination of the
shallow Cape May alluvial aquifer are minimal.
* Beyond documented saline intrusion, no contamination
has been found in the deep Farrington aquifer in the deep
veils screened to the aquifer.
The RI Report should be amended to reflect that the RI data does
not support a finding that there is a significant migration of
hazardous substances from the landfill, as appears to be suggested
by EPA. •
3. There is no credible basis to argue that potential leakage of
landfill contaminants into the deep Farrington is a concern. All
hyrogeologic and analytical date compel the contrary conclusion
that contamination of aquifer by the landfill is not an
environmental concern. They show that there has been no impact by
the landfill on the deep aquifer and that the potential for
migration of contaminants from the landfill into the deep aquifer
is not an environmental concern. See HART comments (Attachments
1 and 3), including the following points:
* The extended process of salt water intrusion into the deep
Farrington aquifer adversely affecting its water quality, due
to the location of the aquifer outcrop areas'and the influence
of pumping at well fields, is a well-documented historical
phenomenon.
* The RI data shows only minimal contamination of the shallow
Cape May alluvial aquifer between the wastefill and the South
Araboy/Woodbridge Clay Sequence.
* Results of the aquifer pumping test (pages 5-9 to 5-14)
indicate that no hydraulic communication exists between the
shallow alluvial aquifer and the deep Farrington aquifer.
* The thickness of the South Amboy/Woodbridge Clay Sequence
underlying the shallow aquifer in the vicinity of the landfill
is approximately 60-70 feet.
* The only elevated metal contaminants reported in the deep
veils vere manganese and nickel. The levels of manganese are
vithin the range of USGS Ambient Water Quality Data for this
area. The levels of nickel in the shallow alluvial aquifer
are much greater than in the wastefill wells or test pits,
indicating a non-landfill source of this metal in the shallow
alluvial aquifer and deep aquifer (where found in the latter
at all) .
* Based on the RI data, no "fingerprint" contaminants have
7
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been found in the deep Farrington aquifer indicative of the
migration of any contaminants from the landfill into the .deep
aquifer.
4. The degree of EPA's concern about the potential migration of
contaminants from underlying alluvial aquifer into the South River
is not justified by the RI data. The RI data does not support a
finding that there is a significant migration of hazardous
substances from the landfill into the South River. See previous
Hart comments (Attachment 3), including:
* The RI data is most notable for the relatively limited
contamination of the shallow Cape May alluvial aquifer it
found. This nay be partially attributable to underlying peat
layer which has served effectively to prevent or retard
contaminant migration from the landfill.
* Significant reported organic contamination of the underlying
shallow aquifer appears limited to KW-13. MW-13 is an off-
site sampling station located north and upgradient of Landfill
III on the triangular peninsula toward the rear of Block 58,
Lot 1A (the property leased by the former Vamp Chemical
Resources Inc.) on the other side of Pond Creek from the
landfill. Accordingly, MW-13 sampling results should not be
interpreted as evidence of contaminant migration from the
landfill.
* A comparison of the contaminants found in South River and
the shallow aquifer does not reveal "fingerprint" contaminants
suggesting a significant migration of contaminants into the
South River from the shallow alluvial aquifer.
SPECIFIC RESPONSES
In addition to the foregoing general comments, the Site
Coir.ir.ittee submits specific comments responding to specific comments
made by EPA in "Attachment 2."
CONCLUSION
These comments by the settlors are offered in the spirit of
cooperation and for the purpose of aiding and assisting DEP at this
site. They are not an admission of any wrongdoing, fault or
liability on the part of any settlor.
-------
Thank you for the opportunity to submit these comments for
OEP's consideration in connection with its review and finalizing
of the Final RI Report.
Respectfully submitted,
Borough of Sayreville
Celotex Corporation
Chevron Chemical Company
Hercules Incorporated
Mobil Chemical Company
Pfizer Inc.
Ruetgers-Nease Chemical Company, Inc.
NVLrer
cc: Ms. Sharon Atkinson, USEPA
Joe McVeigh, Esq., USEPA
-------
SAYREVILLE POLICE DEPARTMENT
OPERATIONS REPORT
10:05
Uniform
MAIUIIOt
INCIDIWT
IOCMION Of
INCIDIW7
VICTIM
ACCUtlB
o«.u or iMctoixi
7/25/77
INCtOlWI NO.
4433
Thru: Pep.Chief Douglas Sprague,
Division Commander
Thru: Chief Ray Sweeney, Chief of
iru:SayrevilleTBoarB of,Health~ :
•»ru: Chairman of Sayreville Water Dept.
To:Sayreville Mayor and Council
S.ub1: Illegal dumping of a chemical
solution (pollutant)
(In reference to incident 04414_OH_.
7/24/77)
77-605
ACtlON lAIlN
On the early morn ing of 7/25/77, the New Jersey Dept.
of
of
Environmental Protection was advised by headquarter
the above incident. At 10:05 this
date, headquartc
gnled this officer to proceed to the contanu'hated~"
Safran sand pit area, Bordentown Ave. and accompany
Dept" o"f~)EnviromnentaJL Protection inveTtiBator"~Th"b"mas
J. Allen while he observed the location and took
additional soil
entered and the
samples. The private property was
^samples were taken without incident^
At this time the strong chemical odor which permeated
air ±he previous dav was still present. After
completion of the assignment, this officer was
_dJLspatched bv headquarters to accompany Investigatory
Allen to the Vamp Chemical Co. on Jernee Mill Road
for the purpose of taking additional pollution
samples. At Vamp Chemical Mr.Allen was snown the
surrounding area by this officer. At this time a
chemical sample was talten rrom a leaKing tank trailer
at the rear of the site. Another liquid sample was
taken from some brackish water in a swamp area
adjacent to the site. Mr.Allen also photographed
the area and also an unlocked trailer containing drum*
I4DCI MUM»f I
AMI 01 u»oti
ClAUlMCAIIOM
HOUU
•AOlO
FHOMl
ON VllXi
IHHIAlt
WtlVllOf'1 CMICC AMD AJMOVA1
It-101
-------
t • It
of chemical waste which were labeled as beinp, "poison..
After completing the assignment *»t Vamp Chemical Co.,
Mr.Allen accompanied this officer to Sayreville Police
headquarters and took charge of four 1 qt. bottles
of chemically contaminated soil retrieved from the
Safran sand pit, Bordentown Ave. on 7/24/77 . Mr.Allen
receipted for the material and transported all samples
obtained to the Department of Environmental Protection
lab. for analysis. (See Property Report)
Pel.Edward Szkodny
-------
SAYREV1LLE POLICE DEPARTMENT
OPERATIONS REPORT.
IK.] 0' IMCIOIWT
11:15
MATUll Or
E£!!*0'
VICTIM
COM*LAIMkMT
ACClMID
Thru:
Thru:
Thru: .
To *
Subj:
'
OiviliO*
Uniform
DAiioMNCiwwr
7-25-77
Dep. Chief Douglas Spragoie
HKIOtNlHO.
4435
, Uniform
Division Comnander
_Chief Rnv Sweeney, Chief of Police
Sayreville Board of Health
Illegal dumping of a chemical
solution • (poll
ULeUi t;
^ ' • . '
77-605
ACTtOM TAUM
At the above time and date this officer v/as assigned—
by headquarters to accompany N.J. Dept.of Environ-
mental Protection investigator Thomas J. Allen to the
Vazp Chemical Co. property, Jernee Mill Rd., for the""
purpose of obtaining chemical pollution samples at that
loca-ios.wmie traversing the property on foot witrT
investigator Allen the following observations were read;:
*j encj.osec oox iraaaer v/as j. oca tea near toe ent rywa y
into the main yard.- The trailer (Fruehauf make), whicfi
mi: I;UL nave any I den LI Tying narkingg, uag not locked
and contained a load of 55 and 5 gallon netal and fibr »
tli
ux cntrDi
waste and several were labled as being poison. Also
& £ Q J
uxciu^ c!
solution. Another box trailer located in the Bain yar
Igcrt1' ^ici3 na Vinr^.n- f±r\T^£. \i*.-\—3-np.V^t'—vrrri—i-inili^ •!!•>*'
^. w w i * \* •. A ^ w w ^^ S iAJ^ »TC«**J |/*T V fc ^ *r * / O J JLwW&^W ^ J J U WW U JU U 1J w ^
be entered. The trailer v/as leaking a black tar like
front cmd year*
in the main yard was a green International truck tract; >r,
>' r.CD plato io
istered to Thonas Kitzi, 2392 Woodbridge Ave., Edison,
N. .T . on a f\d P.b^v pan^l tTnmV try '.'f- *7ni^O a^-^
3-77 (license plate on the vehicle is possibly ficti
tious).. Also located v/ithin the main y$££ two
CUAUeriCAllON
HOUU
IA&IO
fHOMl
ON virv»
CO»»nri
INItlAti
Ul'ttVIVOri CMICI
I M-IOl
1
-------
metal tasks, one being cylindrical arprox. 10' X 30« and
laying on top of the ground. The other tank was round,
vertical appro*. 12' X 10' and anchored into the ground.
At this time it could not be determined if the above .
tanks were full of chenical waste. Also in the main yard
were two tank trailers, one identified only as NSA4/X4202
and the other as a Heil oa_ke, 1IJ TH-421D (80) which is
registered to J & G Trucking United Carrier, P.O. Box
63, South Amboy, K.J. on a 63 Fraehauf, exp. 3-75 (also
a possible fictitious license plate). Also laying about
the nain yard were .15 eapty 55 gallon taetal drums and a
large quantity of tank trailer connecting hoses. At this
tine a strong chemical odor permeated the air within the ;
yard. Fresh tire tracks were observed on the ground ;
within the yard indicating recent activity. On the South .
side of the main yard a swamp area was observed that i
contained dead vegetation and discolored water (black).
The above swamp area is located adjacent to a brook which ;
runs to the Raritan River. Another swaap area appror. j
100' to the rear of the main yard bad oil floating on the i
top of the water surface. Approx. 125 yds. to the rear of j
the main yard eleven old and deteriating tank trailers are
being stored on VaDp Chemical Co. property. One of the
tank trailers itt TP-63? (75) is registered to Old Bridge
Chenical Co., Old Water Works Rd.f Old Bridge', N.J..
Another KJ TPF-390 (74) is registered to Food Additives,
Old Water Works Rd., Old Bridge, N.J.. Two others bore
the markings of Tisco Oil, Avenel, N.J. and Allied Chemi-
cal. Another tank trailer was uncapped and partially
filled with a dark, odorous-cheaical solution. - . _
After the above observations'were cade and pollution
sasples taken this officer and investigator Allen left
the Vacp Chemical Co. property.
At 1330, 7-27-77, this officer returned to the Vatop
Cherical Co. property and took several photographs of the
main yard, vehicles and surrounding area..
Ptl." Edward Szkodny ff4S
i/A!
-------
/O • J'
J Attl* •
UtCfHtft" 0f A-u /Mk'taTUfrT7t/et...*rir rt/JtA /s /^ y^/ Oy 3e 7f ^f
> U^t' 7/| Mv l/A/Lt'l. U'ft-J (.m/C/i/O 4>*^tt/ TUv
T Co-
Sifac'iM THUT T/ye Z/'^uii0 6jp«*
OolH -Ufa- C/^t7nu./Vt. /V^L/Q ^^ r/hTo
-------
7Mtf ..l' 771 A-T
C/Cff'K UK(_ |3 1
F li f\Awir AN'"! v t/?:Tltt7Z_ / r*> Ftt^ttl'tvu C
' /
L
-------
£iair ut" rCriu Blrnini
t-l r-AII fklf M I Ol tNVlRONMC NTAL fTV'Tf O MOH
ll« / Mfit ft AH Ai-I.MI N I OIVI-..DN '
• • *
«.U1« f*« VAMXVItkl . M /. •«*?•
J-.l IMt |O»lt»| • |h*«| III II /I l»« HOwll K.ITLIMI I
13, 1981
Dickcrson, Devoc and Drjlster
Heritage Dank Building
Onr» Risirncr Drive
Now Jersey 08B31
Attn: Goorgo F. ttolster
Dear ft. Dolstcr:
TJiis is in rcsjaonso to your letter of A^ril 27, 1981 rcxj.irJj/ifj tJw property off
f'.ill Fto-id, Siyrcvillc.
Oi ^i3r^^h 3, 1081 and again on April 27, 1981 personnel frcn the Division of
Hazard Min^goncnt and Lho Division of Crijninal Justice did n 1 united im-est-
_i-jation of possible sub-surfocc cixsnicnl contamination on this property. This
"investiijation was bused uir»n infomntion that licjuid Laboratory rhcmicAls
hu^d bocn [xsurod into shallow pits on the thon Van%> Oianical Crrpany site.
A. Timber of hand auger holes dcvn to a level of approxijnatoly 4 foet, failed
to uncover any evidence of chemicals. Huwpver, this operation uns of limited
value to the overall invcstiyation of this site and the adjmrcnt Inndfill site.
It wns of 1 united scope «*uid Lhurefore any real problem of soil contamination
r.uy KJVC Lwn missod. Tic only wiy for Uie present owner or Ihe purctnsor of
Uus prujx-rty Lo be clear of ijosulblo future probhvts vould Iv n nure cxltaisiw
for these areas.
I nn presently in touch with Mr. tosonbloom and his counsel to rexxrmtinrt that a
surface contamination problcn, rocuntly carrnunrloJ by tho removal of an cibnvc
ground tank, be clcnncxl up Ijcforr; transfer of the property.
003617
Thomas J. Allen
Chiefi Bureau of ntcrgcncy Jtosponse
000006
-------
. MA1JOCXM
' PIRNIE
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
V»mp Chemical keuourccs 29B
Site Name, Site ID Number
Jernee Mill Road Sayreville, Middlese:: Co.,NJ
Address City. State
Date of OM-Sile Reconnaissance »arch -7, 19SS
SITE DESCRIPTION
Vamp Chemical Resources was a chemical brokerage firm involved
with the transportation of industrial wastes to off-site disposal
facilities. The facility is no longer located *t this site. During
its operation, Vamp was located at the far southwestern perimeter
of an unuave:) lot. Present at the site were rented tanl: true! s and
trailers.. Upon Vamp's departure, the lot was purchased by and^is
presently occupied by Kico Trucking. Before Kico occupied the
property, analyses were performed on bore samples tal en from the
lot. The results of the analyses were not available fpr review.
The facility was reported to have several spill problems and court
testimony revealed that Vamp was illegally disposing of wastes at
the Sayreville Municipal Landfill, which is located approximately
200 yds from the site. In addition, it was revealed through court
testimony that Vamp .was disposing of wastes directly intc> the
Sayreville Sewer System.
PRIORfTY POR FURTHER ACTION: High Medium Low > None
RECOMMENDATIONS
Since th»;re is limited information available on the e::tent of
contami nation present »t the silt-, it is recommended that the
site bt.» inspected on * t i «ne-*v*i 1 abl e basis. Activities should
consist of sampling soil from the- Jot »«nd from the cur rounding
ground!*, filso, the portion of the sewer line reportedly used for
vi AS t e tliv.pooal «ihould bu inupected for physical damage •• a result
of the alleged dumping.
Prtpated by: Gary T. Vaccaro Da!e. April =, J9BS
• - JKE< Associates
-------
/;/
(POTENTIAL HAZARDOUS
C CPA PRELIMINARY ASSES
\/l— !/"» PART I -SITE INFORMATION Ar,
WACTFClTr t (DC N Tlr 1C" I iQ^
SMENT ei»';"|ek>oV"'it'
DA55E55MENT ' *•
II. SITE NAME AND LOCATION
Oi ttll •«•* A.*.'. .—— .- •...-»— ....«•.... /
Vamp Chemical Resources
eie«rt
Sayrevi 11 i?
40 -6 54.0 1 7i 21 rr.«''
1
Main St. west. Tale n*in St. to Wast
west. Ma'e l'e*t r>n Jornve Mill Rd. Si
C> JIW 1
Jl.'rn
NJ
eiec.5
r.annc «o.e* t>l«r< iec«tio« «<•"«*
re Mill Road
01 r» coot B«cow»'» e'eoiol't "*yTiC
OBQ72 Middlcof"
0 ' io» 1 ^
5ty South to E::it 12^ to.
Vinqton Rd., continue
t e i s one .mi 1 • on r i oht .
m RESPONSE. E ^ST.CS
Oi O»«l«.'.— -^
Rico Trucl inc a'ntf Tr*n*ror t at » on
Sayrevi 1 1 r
O»C"T
^yrevi I 1 c-
Ot !'•((
Jerri
0iiir>*r«
OBB7r ( )
PP| O»
(XJt
Ql
DC »'«'c Qe tou«'» Qc «.u«iei»*t
Qc u»«»e-«
i cm
06/OB/R1 Qc
IVCHARACT£R.:4TiOl.
oi*» t'tc
D* ***
Qt
l»«CO*«««t»0« Qt ««»»f
Qe ot«t*
01 >lt( |t*Twl >
Qc «i».
e>ti**i o<
0<
The only available information indicates that Vamp accepted T-.B mg
of All aline process waste containing inorganics *nd possibly organics,
between 1975 and 197B. (Attachments ft. C)
o»
i ••/••» to f««-«o»»
V»i»p MAS illegally di schf*rni ny M*ct« into thp s*nit*ry sewer., end
*ll*Q«01y illug*lly dumped waste into the S*yreville Municipal
F',C> *
vPRIORITY ASSESSMENT
iTON AVA:^A9.E
OlCO*««CT
red SchmH.t
F.
O>
M0*rt
-------
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 2- WASTE wrORMATlON
NJ
II WASTE STATfS.OUftNTiTlES.AKD CHARACTERISTICS
Ol *MT«Uk l«»t| >C~t. .« <
DC
r*CS CD'
DC stuoce DC
ot »*rf o><*»v»
*C 1 1 1
on p • 1 J on
ont»»i
Oft Si Lily O
between l
V.
V FfEOSTOCxS
e/t«f *
c
-------
POTENTIAL HAZARDOUS WASTE SITE
PRELIMINARY ASSESSMENT
PART 3-DESCRIPTION OF HAZARDOUS CONDITIONS AND INCIDENTS
1 IDENTIFICATION
0> »'«'(
H.I
0? »'M nuvK
Jv-t1
II. HAZAPOX'S CONOiTONS AND NODENTS
e> 0'
itiiT •»»fcrto
The facility »j#s reported In have fc»ve.»ral »pi 1 1 problc»mc c-n-uite.
Since Van*? way located on tmpavcjd grounds, the potential v.: lets for
ground--«•;.•» ter contannnat i on. (Attachment. CO
01 3§ *«•'•£' ••'!• eo«i««"»4no* ot
oi »o»ui»rKK»o»c»'»'«iiT •'•tetro,
Spills reported on-sjte may havt? alibied contaminants to bo c»rric-d
by runoM to creel located alongside property.
P>
Ol DC CCK•«•••»!•>. O'«'•' . Ol DfiM'.lC IO»'C
01 I
Oi DC •'•» /!• I0»-vl CC«0.'.0«I Ot LJoi»f«vfO IO»'C
oi [£jt o<*i:' co«t«;i ot
o> »o»j-.*'ic» »:M«.''«.L» «"tc'f o o«
otenti*! L-.-rtsts -f or direct contact »-n Lfi contaminated coils by
; on-sitc. (Attachment l«)
o> Sr co'»t«*»^*<'0*> o' »O'L ot L o«j(«vf n io*it
01
Since the facility ••* n (V"'/ o c a t e d on tmp Ot
ot wm*'"O« »»'f««''*iL» "'ictco _^_^^___^^_^__ o«
Ot Qn»t(*»rr in*tr
0} •O*<( «»»CtI«ifi»iiT t'MCTeO _^_^^^.^______ °*
Kotenti*! r::ists lor Direct contact with cont*minated coils; by
iertonnel t»n-Eite. «Att*chment £<>
oi B' »o»-ui.«ii&. Ci«o»u«t/i*ju»t ot (Joetdxb iu*tr
oie
jaer*
^ftlO*
'otentj.tj t::ists tor ilirer.L contat't "•cn.t.tt cont ami natetl soi 1 «i by
ber*orinel on-site. (Attachment b)
-------
- POTENTiALHAZARDOUS WASTE SITE
5vpP/\ PRELIMINARY ASSESSMENT
*'t-1 P**T J.DESCRIPTION 0? HAZARDOUS CONDITIONS *ND INCIDENTS
I IDENTIFICATION
0<
NJ ->:L:
II MAZARPOXI'. CONATION'S AND ffJCIDENTS
tc '10**
•4 •MIAlnrl »UC«"t*«
et
to»ti
to
et
ie*rc
*tifeco
co«'»»-«»"o« o> 'coo c«»>
l »|»C«'»llO» *
PI Qo*i(*>t e to«'i
e< CL«
»> t >rt
ci
»e tt
he <«'i:jljtv »"r«b reportecJ to iu«vr »evr»r,>l *pilj
i*ndlei3 J;y NJDEF' Emergency Response. (Att*Chment
«' t I00"t>t(
ct
e<
oort te-it:monv r«ve*!eO th*t V*mp diach^rged w*«te* directly irito
he S*vn?viJie sct-icr line. t-J^utcs were i\loo Allegedly illegally dumped
n ».hc ;: wr '.'v* 1 1 1; tl\.-n > c i pfl L»nOfill . e *r»*ly*«»» were not *vi\il*Dlt> for
evi«\-i.
O1
TlQN «<.•«»»»«•«•«'»*»•«*«»' » » »'«•»«•'«•.»«»»•«»'••*••« «««»•«•
VHbiV» ontl Ui-Cr^ KiiCt: Att«-»chmcntv» A through L>
i: (>
-------
Sj-V^'sss
?.-M s$±*
-------
HART
ATTACHMENT 1
MEMORANDUM
To: Sayreville Landfill III Committee
From: Dennis Farley
Date: July 20, 1990
Enclosed are HART's comments in response to NJDEP's and
EPA' s comments on the Final Rl Report prepared for the
Sayreville Landfill III. Comments which are both global and
specific in nature have been formulated to address several
of the technical issues of concern.
Global Comments-
1. Several of the EPA comments concern the potential for
vertical leakage to occur from Sayreville Landfill III to
the Farrington Aquifer. The validity of this argument is
disputed for the following reasons:
«. The results of the aquifer pumping test
h>draulic communication exists between
aquifer and the shallow alluvial aquifer or Sayreville
Landfill III. It should be noted that the thickness of the
South Amboy / Koodbridge clay sequence in the vicinity of
the Landfill is on the order of 60-70 feet.
b. Based on the analytical data, no contaminant
"fingerprint" exists in groundwater in the Farrington
aquifer which is indicative of the migration of contaminants
from Sayreville Landfill III. A review of the data obtained
from MK-1D and BPT does not indicate the presence of any
such contaminants.
indi cat e that no
the Farrington
2. Several of the EPA comments concern the potability of the
shallow alluvial and Farrington aquifers in the site
vicinity. The encroachment of saline water into the aquifers
in this area is veil documented as indicated by the number
of references provided in the Rl Report. Review of these
references indicate that • significant amount of work has
cone into investigating this saline intrusion problem for
•any years; in fact the USCS and State of New Jersey
cooperated on one such special report as long ago as 1962
(Appel, Rl Report ref erance~~t~l ]). Saline intrusion has been
observed in wells in the area, as indicated in Appendix Y of
the Rl Report, USGS Ambient Water Quality for the Farrington
Aquifer. Concentrations of chlorides in wells MK-1D and BPT
are consistent with the range of chloride concentrations
exhibited by these other Fa;.ing:sn
.ills.
-------
HAFT
Specific CommenLs
1. (NJDEP Comment i21) DEP
is below the water table,
could be occurring.
information has been
anywhere in the Rl
provided in the boring
to exist at a depth of
of MW-4, the closest
1ine and we!] MK-4
presence of saturated
and not indicative
Furthermore, depth to
seasonal effects such
to-water fluctuations
potential infiltration
states that, since the sewer line
only infiltration of groundwater
It is not clear from where this
derived, as it is not presented
Report. Depth-to-water information
logs indicates saturated: conditions
approximately five feet in the area
well to the sewer line.. As the sewer
are located in fill material, the
materials could be location-specific
of actual water table conditions.
this "perched water" may be subject to
as precipitation, resulting in depth-
over time. Other factors affecting
include the operating pressure of the
system itself; gravity systems are generally subject to
charging during periods of high loading. Under such
conditions, exfiltration could preferentially occur rather
than inf i1t rat i on.
2. (EPA-Marseni son Comment *4) Site specific data has been
presented to support the interpretation that elevated
chloride levels at surface water sampling stations is due to
tidal mixing of the South River. The river is classified as
SE-1 at this location, with "SE" indicative of the general
surface water classification applied to saline waters of
estuar i es .
3. (EPA-John Malleck Comment il) Due to the saline nature of
the groundtater in this area, the applicable Classification
Guideline is likely Class III. Class 111 groundwater is
regarded as unfit for human consumption due to high salinity
or widespread contamination that is not related to a
specific contaminant source. For Class III groundwater,
drinking water standards are not considered ARARs.
4. (EPA-Frederick J. Luckey Comment 125) Significant
groundwater contamination in the alluvial aquifer has only
been detected in the vicinity of MW-13, which lies
uppradi ent of Sayreville Landfill III. Also, as previously
sidled in the committee's comments on the Final Rl Report
dated May 2, 1990, the lack of Landfill "fingerprint"
contaminants in the alluvial aquifer seems to indicate that
migration of contaminants from Sayreville Landfill III is
not occurring. In this regard, the low permeability clays
and silts AI_e seen as "providing an effective barrier »o the
-------
HART
downward migration of leachate." As further addressed in
the May 2, 1990 comments, the presence of contaminants in
MK-13 also is not necessarily logical, as this particular
area appears to be immediately underlain by a thicker (16
feet) sequence of clay than Sayreville Landfill 111. The
possibility does exist that contaminants could have been
introduced to the alluvial aquifer during drilling.
5. (EPA-Luckey Comment
as used in the report.
an artesian aquifer at
artesian aquifer.
«35) The term
The. Farr ingt on
this 1 oca Ii on,
"artesian"
Aquifer is
though not
is correct
cons i der ed
a flowing
6. (EPA-Luckey Comment §57) It should be noted that
acetone was used in the field decontamination of soil
sampling equipment.
-------
ATTACHMENT 2
SPECIFIC RESPONSES TO EPA COMMENTS
8AYREVILLE LXKDFILL III
DRAPT PINAL R£K£DXAL INVESTIGATION REPORT
tted April 27. 1990 of Paul R. M&rsenisen
4. The Site Committee disagrees with the comment that there is no
site specific data to support the conclusion that elevated chloride
levels in surface water samples may be attributed to tidal mixing
of the South River saline solution. The comment overlooks the
SE-1 classification of the South River (high salinity), the fact
that it is part of the Raritan estuary, and the widely recognized
process of saline water intrusion of groundwaters in this region
of New Jersey.
5. See General Response.
6. See General Response. There is no basis to support the
conclusion regarding hydraulic communication of the deep Farrington
aquifer with the shallow Cape May alluvial aquifer. This comment
overlooks that the BPT well was also screened in the underlying
clay and deep Farrington aquifer downgradient of the site and was
analyzed for groundwater quality.
Page 2 of Marsenison Memorandum
2. See General Response. There is no basis in the RI data to
warrant further investigation of a potential for leakage of
landfill contaminants to the deep Farrington aquifer.
Memorandum of John S. Maileek
1. As stated in HART'S previous comments (Attachment 3), the
shallow groundwater II-A classification is inappropriate and
drinking water standards should not be considered ARARs. The
shallow Cape Kay alluvial and deep Farrington aquifers in this site
area should be subclassified or a waiver from ARARs, if applicable,
should be granted. Reclassification for non-potable water uses
would be consistent with the SE-1 classification of the South River
adjacent to and downgradient of the landfill.
Page 2 of Ma.ll«ck M«aona6ua
2. See HART comments (Attachment 1). The suggestion of additional
studies to examine a possible hydraulic connection between the
shallow aquifer and the South River is not supported by RI data or
justified. It ignores relevant data and findings of the RI,
including the following: (1) the wastefill is perched on a highly
-------
impermeable peat layer above the underlying shallow aquifer where
it is not subject to significant tidal fluctuations; (2)^
contaminants in the underlying shallow aquifer are minimal,
providing evidence that the underlying peat layer is an effective
leachate control system and migration of contaminants from the
landfill into the aquifer has been minimal; (3) no significant
degradation of the South River has been found adjacent to or
dovngradient of the landfill; and (4) significant discharges from
the shallow aquifer into the South River have not been identified.
lated April 23. 1990 of Wi:
2. The comment that the facility is subject to daily tidal flow .of
the South River is undocumented and contrary to the RI data. It
ignores the contrary finding of the RI Report that the wastefill
is perched and not subject to significant daily tidal fluctuations
(see pages ES-2, 5-23 and 5-25).
Memorandum of Andrev Bellina dated April 26. 1990
1. Use of the term "manifests" is confusing, misleading and
inappropriate. The landfilling and site disposal activities pre-
dated RCRA and State laws establishing the "manifest" system for
documenting the waste stream. The Site Committee has requested,
but not been given, identification of the documentation supporting
alleca^ions about hazardous waste manifests. Unless this
information is forthcoming, this information or allegation,
whatever it is, cannot be considered credible and is not part of
the adrir.istrative record.
Mecorandua of Frederic* J. Luefcev dated April 24. 1990
2. The comment about deleting the references to regional saline
intrusion is unjustified and exhibits a lack of familiarity with
regional hydrogeology. Regional saline intrusion studies
explaining elevated chloride levels in the area aquifers are widely
recognized and documented in the RI Report (e.g. page 5-22). The
alternative possibility that the landfill may be the source of
elevated chlorides in area aquifers, especially the deep Farrington
aquifer underlying 60 to 70 feet of the Woodbridge/South Amboy
Clay sequence, is not supported by RI data and not justified. See
General Response.
Page 2 of Luckey Memorandum
5. The comment that only one veil vas screened in the deep
* It should be noted that that the elevated contaminants found
in KW-13 are upgradient of the landfill. They are not evidence of
migration of contaminants from the landfill into the shallow
aquifer.
-------
Farrington aquifer is inaccurate. At least two wells were screened
in the deep aquifer/.including the BPT downgradient of the landfill
site. The comment about gathering additional information on water
quality parameters in the deep aquifer has no support in the RI
data and findings. These findings include that even the shallow
aquifer immediately underlying the site has been minimally impacted
by contaminants from the landfill and that no "fingerprint"
contaminants in either the MW-l or the BPT were found indicative
of potential contaminant migration from either the shallow aquifer
or the wastefill.
Specific Comments of LucXey Memorandum
7. The comments in this paragraph appear .to reflect a
misunderstanding that the Farrington aquifer is used a source of
drinking water supplies in the Borough of Sayrevilie. Based on
well-documented saline intrusion, the deep aquifer is not used for
drinking water by the Borough. The only well from the municipal
Sayrevilie wellfields screened in this aquifer was decommissioned
due to high salinity. The conclusion that elevated chloride levels
in the deep aquifer are probably due to landfill leachate migration
is wholly unsupported and should be withdrawn.
25. Contrary to this comment, the RI data supports the conclusion
that the underlying peat layer and clay deposits have been an
effective barrier retarding landfill contaminant migration. The
only monitoring well in the shallow aquifer exhibiting elevated
levels of contaminants of potential concern was MW-13. However,
as already noted, MW-13 and the constituents found in it are
upgrafier.t of the landfill and not indicative of landfill
contar.inant migration. As also pointed out in HART'S comments
(Attachment 1) , there is the possibility that the contaminants
reported in KW-13 were artifically introduced.
-------
ATTACHMENT
fi.E.AJi P U H
TO: Sayrevllle Landfill III Committee
.FROM: Dennis Farley
RE: RI/FS - Technical Comments
DATE: April 25. 1990 ;
Enclosed are HART'S technical comments on the draft "Final Rep-rl:
Remedial Investigation/Feasibility Study" dated March 20. 1990 ("Final it]
Report") prepared by B&V Haste Science and Technology Corporation.
-------
-2-
1 . ALLEGED "LEAKAGE" THROUGH THF SOUTH AMBQY/HOQDBRIDGF .£l_A.y .
The text contains several references to potential leakage which nmy it-
occurring through the South Amboy/Hoodbrldge clay (page 5-22, "... this u
supported by the literature which documents saline water Intrusion into
the Farrlngton aquifer .In this area."; page 5-37 "... which may indicate
the migration of heavy metals from the wasteful may be occurring.-"). 1 in-
validity of this alleged scenario Is disputed based on the follow! mj
technical arguments:
a. The results of the aquifer pumping test, reported on payes 5-L» to
5-14, Indicate that no hydraulic communication exists between lh-.-
farrlngton aquifer and the shallow alluv1a.l aquifer or Sayrevil It-
Landfill III. It should be noted that the thickness of tin- South
Amijcy/Hoodljridge clay sequence in the vicinity of the- landfill u CM
the order of 60-70 feet.
I. The encroachment of saline water Into the Farrington aquifer iJQfs \]£,\
support the supposition of leakage through the South AniLcy/Woodl ridge-
clay as proposed on Page 5-22. This supposition is in cojilradu i ijn
to page 1-5 of the report, which states the source of tht saline
contamination to be In the vicinity of the Washington Canal, wi.ich
joins the South River approximately 1 mile downstream from the
Landfill. The references cited 1n the report explain this
encroachment more thoroughly. Appel (1962. report reference Ml)
Describes the Intrusion of saline water Into the Farrinyton lo oicur
updip of the landfill 1n the area of the Raritan estuary, where the
Farrlngton outcrops are exposed to salt water. In addition to the
area of the Hash Ing ton Canal, other principal areas where saline water
has entered 1n the farrlngton are near the mouth of the Ron tan River.
and an area one mile downstream from the confluence of the Washiiujton
Canal and the Raritan River. As stated 1n the report, lomj-tcrm
pumping of the Farrlngton has drawn this saline water southward from
the outcrop areas over time.
(19B9P)
-------
-3-
This Information further olsputes the statement made on page 5-12 of
the report, 'The hydrographs of Hells 1-0 and 4-0 clearly reflect the
Influence of tidal loading from the South River." The observed tide?
Influences are likely due to tidal loading of the Raritan estuary, and
subsequent hydraulic communication via the locations described above-.
c. The reference to possible migration of "elevated concentrations of
heavy metals" (e.g., page 5-35, 5-37) from Sayr«ville Landfill III lu
the farrington aquifer 1s not supported by the analytical dj^u
provided in the report. Of the "elevated concentrations of chromium.
nickel, managanese and zinc" discussed, only nickel and manganese-
exceed the "Regulatory Standard" limits provided alongside tlie data in
Appendix E. The concentrations of manganese, thoucjh elevated, arc
within the range of USCS Ambient Hater Quality Data for this area, as
discussed on page 5-34. Elevated levels of nickel were only found in
deep wells screened in the Hoodbridge aqultard; those screened solely
in the Farrington aquifer, MW-1D and BPT, were both clean. It shoulJ
be noted that concentrations of nickel were also identified in tin-
Alluvial/Cape May aquifer, at levels much greater than any observed in
the referred-to "wastefill" wells or test pits. This wouU appear tu
Indicate a non-Sayreville Landfill III source to exi>t, such as
natural concentrations related to the clayey material itself. BcseJ
on the data provided, no contaminant "fingerprint" exists in
groundwater in the Farrinyton aquifer which 1s Indicative of tin.'
migration of any contaminants from Sayreville Landfill III.
Eased on these technical arguments. It Is felt that any and all
references/allegations contained In the report to leakage through the
South Amboy/Hoodbridge Clay are unjustified and misleading. The evidence
contained 1n the report clearly Indicates that no effects upon the
Farrington aquifer have been observed, and that ainloal potential for this
to happen 1n the future exists. As this 1s one of the most important
findings of the Investigatiop^ It should be clearly stated In all
conclusions, as well as In the Executive Summary. All references to the
contrary (e.g., pages 5-22 and 5-37) should be deleted.
(19B9P)
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-4-
2. POTENTIAL CONTAMINANT MIGRATION FROM THE ALLUVIAL AQUIFER TO THE SJJJJ.-TJ!
RIVER.
An Important consideration of the report should be a thorough
assessment of whether contaminants are migrating to the South River from
the Sayrevllle Landfill 111 via the alluvial aquifer. Several references
(e.g., page 5-21, 5-11) are nade In the report which state that the
alluvial aquifer 1s likely 1n hydraulic communication with. and
essentially, discharging to the South River. In order to proceed with
proper remedy selection for the landfill, a more definitive conclusion
must be reached. It 1s felt that the findings of this study are contrary
to that which Is Inferred 1n the report.
Prior to considering technical arguments regarding the hydraulics of
this potential pathway, the obtained analytical data for the alluvial
aquifer should be summarized to Indicate the significance of
contamination. Although a thorough presentation of the analytical
findings are made on pages 5-32 and 5-36, the listing of findings which
are not significant tends to confuse the reader. Of the metals which are
listed, only manganese, chromium and cadmium were detected at
concentrations exceeding the "Regulatory Standard" provided with tiit
dcta.- Of these, manganese was present at concentrations lower than the
U5CS Ambient Hater Quality data discussed on page 5-34. Chroniium was
detected at concentrations In the alluvial aquifer which are higher than
the "wasteful" wells, and was present 1n wells MH-2S. MH-P2. MW-12. MK-'J
and HK-4, all of which are upgradient of the Sayrevllle Landfill 111.
This Information supports a source(s) of chromium other than Sayreville
Landfill III to exist. Levels of cadmium narrowly exceeded the regulatory
standard In three wells, one of which 1s the background well, MH-1S. It
should be noted that no levels of cadmium above the Regulatory Standard
were reported for Round II of the sampling.
Of the organic contaminants presented In the report, only
chloroethane. total xylenes, and napthalene exceed ECRA Surrogate Action
Levels, and this was observed In only one well. MH-13 (located on the
0
11
J89P)
-------
-5-
Block. 58, Lot la peninsula). Several of the compounds detected, such as
nethylene chloride, acetone, and the phthalates are common laboratory
and/or field decontamination contaminants. Behzo(a)pyrene. detected only
In the Round I sampling, 1s flagged as a blank contaminant.
In summary, significant contamination of the alluvial aquifer appears
limited to the several organlcs detected 1n MH-13. As these contaminants
serve as a fairly accurate "fingerprint" of the Landfill contaminants.
their presence In only one well seems to Indicate that wholesale migration
of contaminants from Sayrevllle Landfill III to the alluvial aquifer is
not occurring. On the contrary, their presence In MH-13 Is net
necessarily logical, as this particular area appears to be immediately
underlain by a thicker (16 feet) sequence of clay than the remainder of
the Sayrevllle Landfill III (based on Figure 4.8). The possibility does
exist, based on the drilling/Installation procedure described on page 5-6
and 5-7. that Landfill contaminants could have been Introduced to th?
alluvial aquifer during drilling. Figure 4.8 Indicates MH-13 to be out- of
the furthest upgradlent wells which actually underlies the Sayrevi) It-
Landfill III. If the Landfill Is the source of the observed contamination
In tills area, one would expect to observe vertical leaching of tin.-
cor.tair.inants through the clay sequence in this area. Analytical data for
the soil sample collected during the Installation of this well does not
Indicate the presence of these contaminants, although no "depth
of-sampllng" Information 1s provided.
Based on this understanding of contaminant presence in the alluvial
aquifer, the following comments are provided regarding potential migration
to the South River:
a. The results presented 1n the report regarding site geology and
hydrogeology do not demonstrate the exlstance of hydraulic
communication between the alluvial aquifer and the South River.
As discussed on pages 5-21 and 5-22, the water levels In wells
MH-5S and MH-6S are conslstanly below the level of the South
R1y»r. While several scenarios have been presented which attempt
to explain this observation, one scenario has been overlooked:
(19B9P)
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-6-
the alluvial aquifer and South River, nay nfit l»fe In hydraulic
communication. Information regarding llthology beneath the
river, as well as thickness of accumulated sediment, is not
provided. Observed tidal effects In the alluvial aquifer could
be the result of Influence In other areas 1n the Raritan Estuary
where the alluvial aquifer outcrops. Without further information
regarding river depth and lithology, It Is not possible to state
with certainty that the alluvial aquifer and South River are in
direct hydraulic communication. Site-specific Informal ion
obtained to date suggests that they are not-
Regardless of the hydraulics of any South River/alluvial aquifer
relationship, an assessment of the effect of potential
contaminant migration can only be made by comparing analytical
data from the alluvial aquifer and the South River surface
water. Such a comparison would assess the presence of
"fingerprint" alluvial contaminants in the surface water sample*
obtained. Of these fingerprint contaminants, chloroelhane wa<,
detected at a level below the contract detection limit in
surface water sample, as discussed on page 6-7. Cadmium
detected at several surface water sampling locations, witli
highest concentrations detected 1n SH-1. This sample was
collected adjacent to Jernees Kill Road, far uprjradient of the
site. As with the groundwater data, no cadmium was detected in
any of the Phase II samples. Based on this assessment of the
data, 1t appears that significant contaminant migration to the
South River via the alluvial aquifer 1s not occurring.
NJDEP's comments on Black & Veatch's ARARs Document of March 8.
1989 discussed the possibility of sub-classifying the tjroundwater
or obtaining a waiver from DHR cleanup criteria for the alluvial
aquifer. This seems appropriate based on the discussed receptor:,
and/or potential users of water from the alluvial aquifer.
Although uncertantles exist regarding the aquifer's relationship
with the South River, the River's SE-1 classification u
[19B9P)
-------
-7-
conslstent with this thinking. Saline Intrusion of the
Farrington end Old Bridge aquifers has been documented at their
outcrop areas, and severely limits, their useablllty at these
locations. Even If the alluvial aquifer 1s continuous to these
outcrop areas, the existence of saline Intrusion would justify &
waiver from DWR cleanup criteria.
Based on the arguments presented, the following conclusions should Lc
'>
made 1n the report and presented In. the Executive Summary.
Minimal contamination attributable to SayrevilJe Landfill m hoi
been detected In the alluvial aquifer.
* Based on the results of this study, the alluvial aquifer tuby not
be 1n hydraulic communication with the South River.
* Potential receptors of groundwater from the alluvial aquifer art-
themselves degraded due to salinity, and are relatively useles*
as potable supplies at locations 1n close proximity to the
landfill.
It 1s felt that these findings are Important conclusions of the stud-y
and will weigh heavily In remedy selection. As such, they should be
Included 1n the report as conclusions 1n the Executive Summary.
3. t/W?riit LFACHATF PRODUCTION
It appears from the data that an assessment of leachate quality
escaping from the site, attempted via the surface water and sediment
sampling programs, was relatively Inconclusive. The surface water data
does not indicate any obvious trends, as noted In the report, and
Indicates that upgradlent and/or ubiquitous sources of contaminants likely
eilst. The sediment data may -indicate several Instances of Isolated
contamination. In addition to an apparant upgradient contamination
suurce(s) on Pond Creek (se?. e.a.. SE 1 I 12). High levels of PAii's.
(1989P)
-------
-8-
phthalates, and other compounds were detected as far upgradlent as Jernee
Mill Road. The Isolated Instances of sediment contamination Involve'
concentrations which only slightly exceed the Regulatory Standard to which
they are compared In the report. The reported "high concentrations" of
Arochlor 1248 and 1260 In SED 14, discussed on page 6-10, 1s disputed.
These compounds were detected 1n three samples at concentrations ranging
from 1.3 ppm to 5.2 ppm. The referenced NJDEP Soil Cleanup Standards
range to 5.0 ppm. Based on this analytical data, contaminant migration
via leachate seepage from Sayreyllle Landfill III appears minimal.
It 1s felt that a further discussion of site hydrology as it relates
to landfill leachate Is warranted In the report, as these conclusions can
significantly effect the remedy selection process. It Is Inferred from
the report that no active leachate seeps were noted during tins
Investigation, as none are reported. Based on the age of the Landfill, it
Is quite possible that the major leachate production cycle has concluded.
and that generation of leachate at this time Is predominantly controlled
ty Infiltration of water, such as precipitation. Page 5-24 of the report
Indicates that precipitation 1s the only source of recharge to Sayrevjlle
Landfill 111. No tidal Influences upon the Landfill were observed durimj
this study as Indicated on page 6-16; In fact the "wasteful fluids"
themselves were determined to te perched on the underlying alluvial clay.
as discussed on page 5-23. Based on this, tidal "washing" of the Landfill
materials is not a threat to leachate production.
As a result of these findings. It can be summarized that future
•eachate production can be controlled through minimization of the
principal form of recharge to the Landfill - precipitation. Such a
control would essentially render harmless any remaining contaminant
sources and eltlyate the threat of future potential discharges from the
landfill. As this conclusion Is critical to the remedy selection process.
it should be Included In the report.
HQR9P)
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Responses to ZPA and DEP comments OB the Craft Remedial
Investigation Report, Sayreville Landfill XII, dated July 23,
1990, to Neal Brody and Michael Burlingame, from the Borough of
Sayreville; Celotex Corp.; Chevron Chemical Co.; Hercules/ Inc.;
Mobil Chemical Co.; Fficer Inc.; and Ruetgers-Nease Chemical. Co.,
Inc.
General Response
Response to PEP Comments
7. NJDEP agrees with the Committee's comments that alleged
disposal of hazardous wastes could have occurred on Block 58,
Plot 1A based on the evidence presented in this comment.
However, based on extensive test pit excavation, no evidence of
buried drums in this area was found. We agree, however, that it
was appropriate to include this property in these investigations,
based on its past history.
21. NJDEP agrees that if surcharge conditions came about in the
MCUA sewer lines, then exfiltration of contaminated sewer waters
into the ground water at the site could not be ruled out. Under
open-channel flow conditions, however, only infiltration would
occur given the depth of the pipeline (below the water table).
22. The DEP Division of Water Resources has determined that the
shallow and deep aquifers are classified as type GW-2 ground
waters. Drinking water quality standards are thus ARARs. The
DEP Commissioner may be petitioned for subclassification of these
aquifers.
33. No response required.
Response to EPA Comments
1. Corrections of Factual Inaccuracies
1. - 4. These conclusions are not disputed.
5. See response to 122. above.
6. Deep monitoring well (MW-1D) is screened within the deep
Farrington Sand aquifer. Pump test well BPT is screened across
both the Woodbridge Clay unit and Farrington Sand aquifer (see
Table 3.1, TS Report). MWs 2D and 4D are screened in the lower
(basal) Woodbridge Clay unit. These determinations are based on
stratigraphic descriptions of the various units identified.
Substantive Comments
1. No response required.
2. It should be noted that all of the contaminants detected above
NJSDWA MCLs in the shallow ground water aquifer (i.e., including
-------
chromium, benzene, cadmium, and nickel) were also present in the
landfill leachate. Also, the only downgradient monitoring well
located within fctoe deep aquifer possessed an excessively long
screened interval which would not allow for a true representation
of the groundwater quality in that aquifer. In any case, it is
not possible to obtain complete ground water quality data on the
deep aquifer, either beneath or downgradient from the site based
on the existing monitoring wells. In addition, analyses of
surface water and stream sediment samples collected from
locations adjacent to and downstream from the wastefill detected
contaminant concentrations exceeding the appropriate regulatory
standards. These contaminants are also present in the landfill.
3, It is the DEP's judgement that additional ground water
monitoring wells located within the deep aquifer, located both
directly beneath and downgradient from the site, and sampling and
analysis of ground water from the deep aquifer, is required
before any conclusions regarding the impact(s) of the landfill on
the aquifer can be made. Since this aquifer is a drinking water
source, it would be premature to dismiss it as unaffected, based
on such limited analytical data.
4. The impact(s) of landfill on the South River and adjacent
streams (Pond and Duck Creeks) is not clear at present. Only two
rounds of stream sampling was been performed. There is some
question as to whether the upstream samples were taken
sufficiently far enough upstream so as not to be influenced by
the tidal nature of the site. Therefore, additional sampling and
analysis of surface water and sediment samples from all surface
water bodies in the vicinity of the site will be required before
any conclusions regarding these media can be made.
Attachment 1. Comments from Dennis Farley. HART, dated 7/20/90
Global Comments
1. a. Sec. 5.2.5.2 of the RI Report discusses the aquifer pump
test. The results of the test were qualified for a number of
reasons relating to the diameter of the pumping well and the
distance of the pumping well from the ground water monitoring
wells. No drawdown was observed in MW-P4, located adjacent to
pump test well BPT. However, this may not be representative of
the conditions at other locations. The conclusion was made that
in order to assess if significant vertical leakage from the
landfill into the deep aquifer is occurring at the site, a pump
test of much greater magnitude would be required to sufficiently
stress the deep aquifer.
It should be noted that although the Woodbridge Clay sequence is
on the order of 60 - 70 feet in thickness at the site, the
-------
sequence contains sand lenses of up to approximately 30 feet in
thickness (see logs for MW-4D and BPT) which produce measurable
quantities of water.
b. Analytical results from Wells BPT and MW-4D, located
downgradient of the site, did not indicate the presence any
contaminants of concern. However, as previously discussed, the
ability of these wells to comprehensively monitor conditions of
the deep aquifer downgradient from the site is questionable. BPT
contains a screened interval of 75 feet. Samples taken from this
well are therefore a mixture of waters from a 75-foot interval of
the aquifer. To avoid mixing of ground waters from large
intervals which can result in the dilution of contaminated waters
with clean waters, EPA guidance states that screen lengths should
not exceed ten feet in length. Thus, samples taken from BPT
represent a composite of the aquifer in its entirety and
therefore, cannot be considered truly representative of water
quality within the deep aquifer. MW-4D is screened within the
upper portion of the deep aquifer. Therefore, no conclusions can
be drawn from samples taken from this well regarding the
conditions of other zones of the aquifer. In addition, only two
rounds of ground water samples were collected from each well.
Without further, longer-term sampling monitoring and the
installation of additional ground water monitoring wells in the
deep aquifer, conclusions regarding the impact(s) of the landfill
on the deep aquifer cannot be made.
2. The DZP Division of Water Resources has determined that the
shallow and deep aquifers are classified as type GW-2 ground
waters. Drinking water quality standards are thus ARARs. The
DEP Commissioner may be petitioned for subclassification of these
aquifers.
-*
Specific Comments
1. Information concerning the sewer lines comes from as-built
drawings prepared for the Middlesex County Sewerage Authority.
The older sever line is 45 inches in diameter and two feet below
Pond Creek at that location (record drawing dated April 1958).
The newer sewer line is 84 inches in diameter and five feet below
Pond Creek at that location (record drawing dated October 1980}.
NJDEP agrees that if surcharge conditions came about in the MCUA
sewer lines, then exfiltration of contaminated sewer waters into
the ground water at the site could not be ruled out. Under open-
channel flow conditions, however, only infiltration would occur
given the depth of the pipe (below the water table).
2. No response needed.
3. See response 12 above.
4. See Substantive response #2 above.
-------
5. No response required.
6. No response required.
Attachment 2. Specific responses to EPA comments
Memorandum dated April 27^, 1990 of Paul Marsenison
4. No response required.
5* See General Response.
6. See response #1 to Global Comments.
Page 2 of Marsenison Memorandum
2. See response 16 above.
Memorandum of John S. Malleck .
1. See response #2 to Global Comments.
2. The decision regarding the performance of these additional
studies will be deferred until further sampling and monitoring
results are available for evaluation.
Memorandum dated April 23. 1990 of William Barrett
2. The final Rl Report was made consistent with the William
Barrett memorandum of April 23, 1990.
Memorandum dated April 26, 1990 of Andrew Bellina
1. B&V Waste Science and Technology, the contractor for the
RI/FS project, has been unable to find the reference to the
statements made on page 3-1, second paragraph, second and third
sentences, of the RI report. These state that manifests from
several sources indicate that liquid hazardous wastes were
disposed of at the landfill. Since we cannot locate the source
of this information, and because the manifest system for
hazardous wastes was not in effect during that time, the accuracy
of these statements cannot be verified and they should be struck
from the record.
Memorandum dated April 24. 1990 of Frederick J. Luckey
2. Further ground water monitoring of the deep aquifer is
proposed and will determine whether or not the landfill serves as
a contributor to the elevated levels of chlorides detected in the
surface waters investigation.
5. See response II to Global Comments.
4
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Specific comments of Luckev Memorandum
7. See response #2 above.
25. See Substantive response #2 above. Further sampling and
monitoring is required to determine the origin of contamination
detected in MW-13 identified in the Phase I RI sample results.
Attachment 3. comments from Dennis Farley. HART., dated 4/25/90
These were previously responded to by the NJDEP on July 5, 1990.
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ATTACHMENT C
-------
July 16, 1990
Heal Brody, Esq. Mr. Michael Burlingame
Office of Regulatory Services Site Manager
NJDEP NJDEP
410 East State Street Division of Hazardous Site
CN-402 Mitigation
Trenton, NJ 08625 CN-413
Trenton, NJ 08625-2902
Re: Feasibility Study and Risk Assessment Reports
Sayreville Landfill III
Dear Mr. Brody and Kr. Burlingame:
The following comments are respectfully submitted by the
signatories to the Agreement and . Administrative Consent Order
entered into on October 28, 1986 ("Site Committee") conc-erning the
draft Feasibility Study Report dated June 1990 and the draft
Baseline Risk Assessment Report dated June 1990, both prepared by
B&V Waste Science and Technology Corporation in connection with
this site investigation. The Site Committee assumes that these
comments, as well as all other correspondence with the Department
of Environmental Protection ("DEP") by the Site Committee or its
members, will be treated as part of the administrative record.
FEASIBILITY STUDY (FS)
HART Comments
In a memorandum dated July 16, 1990 to the Site Committee,
Fred C. Hart Associates, Inc. ("HART") has prepared comments on the
draft Feasibility Study Report (FS). The Site Committee attaches
and adopts HART's comments as their own ("Attachment 1").
Other Comments
In addition to HART'S comments, the Site Committee comments
on the FS as follows.
-------
Neal Brody, Esq. , •
Michael Burlingame, Site Manager
July Ifc, 1990
Page Two
1. .The report repeats inaccurate information contained in the
draft Remedial Investigation Report dated March 20, 1990
regarding owners of the Sayreville Landfill III site and
should be corrected as follows.
a. Celotex Corporation does not own any portion
of the landfill site identified on Figure 1-4
(Sayreville Landfill III).and Figure 1-5 (Lot
Boundaries) and its name in this connection •
should be stricken.
fc. The current owner of Block 57B, Lot 1, is
Pfizer Inc. and its name should replace that
of Quigley Co., Inc., as owner. A former
owner of the property, Quigley Co., Inc., a
subsidiary of Pfizer Inc., leased it to the
Borough of Sayreville for operation of the
municipal landfill.
c. The FS also fails to record the owner of Block
58, Lot 1A adjoining the Pfizer property on
the north. Block 58, Lot 1A j.'s part of the
site under study (see Figures 1-4 and 1-5
depicting the boundaries of the main landfill
in relation to area properties). According to
recent municipal tax records, the current
owners of this property are: C.E. Laslo, J.
Polak and T. Polak." The Site Committee
believes that the property is currently
occupied by a company doing business under the
name of "L.P.fc Sons Brickote, Inc."
d. On information and belief, the prior owner of
Block 58, Lot 1A was Rico Transportation Co.,
Inc.1 On information and belief, the owners
prior to Rico Transportation Co., Inc., were
Ben and Aaron Rosenblum, who leased the
property to Vamp Chemical Resources, Inc. for
1 See the information regarding this prior owner and its
purchase of this property, with apparent Knowledge of potential
contamination problems on the property, previously set forth in the
letter to DIP *ated August 8, 1989 from Nielsen V. Lewis.
-------
Weal Brody, Esq.
Michael Burlingame, Site Manager
July 16, 1990
Page Three
its hazardous waste treatment facility.2
e. On information and belief, the Middlesex
County Sewerage Authority is the owner of an
easement on the landfill property traversing
the landfill from north to south in which its
sewer trunk line discussed in the FS is
located. .
2. The Site Committee disagrees with the categorical statement
that compliance with current DEP solid waste closure requirements
is necessary to meet applicable or relevant and appropriate
requirements ("ARARs") at this site (e.g. . Page 4-11). As pointed
out in the Site Committee's comments dated May 2, 1990 on the draft
Remedial Investigation Report, Sayreville Landfill III was closed
in compliance with DEP landfill closure requirements applicable at
the time. Those requirements included final grading, installation
of methane vents and drainage structures, and construction of a
modified landfill cover consisting of a vegetative soil cover on
the surface of the landfill and a combined soil and clay cover on
its side slopes. In its approval of the original landfill closure
plan, DEF specifically waived the requirement of a clay cover on
the surface of the landfill (see DEP letter dated September 10,
197S appended as "Exhibit A").
Current solid waste closure requirements are not ARARs fcr
Sayreville Landfill III. Stringent modern closure requirements
are not applicable or relevant to landfills closed long before
their enactment. Even if they were relevant, they clearly would
not be appropriate in light of the Risk Assessment demonstrating
the minimal risks at this site and other simpler remedial
alternatives identified in 'the FS which adequately address these
limited risks and protect human health and the environment.
2 See the letter referred to in Footnote 1 providing
information on these prior owners, including their alleged
knowledge of the disposal practices of Vamp Chemical Resources,
Inc., when it occupied the property as lessee and operator of a
hazardous waste storage and treatment facility and allegedly
disposed of drum* containing chemical or industrial wastes in
Sayreville Landfill III.
-------
Neal Brody, Esq.
Michael Burlingame, Site Manager
July It, 1990
Page Four
BASELINE RISK ASSESSMENT REPORT
HART Comments
In its memorandum dated July 16 , 1990 (Attachment 1), HART
has commented on the draft Baseline Risk Assessment Report ("RA").
The Site Committee adopts HART'S comments on this report as their
own.
Other Comments
1. Like the FS, the RA repeats incorrect information in the draft
Remedial Investigation Report regarding owners of the
Sayreville Landfill III site. See the Comments above
correcting this ownership information.
2. The RA provides additional evidence that E. I. DuPont
DeNeincurs and Co., Inc. ("DuPont") is a potential source of
area contaminants and a potentially responsible party in this
matter. In the description of other industrial facilities in
the area (Section 1.5.5), the RA discloses that contaminants
have been detected in the groundwater and soils of DuPont's
facility, including, inter alia. PCB aroclor 1248.
Significantly, the RA reports that PCB aroclors 1248 and 1260
were also detected upgradient of the landfill in the vicinity
of the landfill in DuPont's outfall discharge into Pond Creek
(Page 2-5).
3. The RA findings regarding PCB aroclor associated with DuPont's
discharge are supported by the data reported in the draft
Remedial Investigation Report which found aroclor 1248 and
1260 in SED-14 (Pages 3-20, 6-10), the sampling station
established to determine the contribution of the DuPont
outfall discharge to site area contamination (Page 6-3).
Other contaminants nay exist in or as a result of the DuPont
discharge and warrant further investigation of this potential
contaminant source.
Specific Comments
The Site Committee incorporates wore specific comments on the
RA appended hereto ("Attachment 2").
CONCLUSION
Please accept these comments by the Site Committee in the
spirit of cooperation for th-2 purpose of assisting DEP in its
review and finalizing of the FS and RA for this site. Nothing in
these comments should be construed as an admission of any legal
-------
Heal Brody, Esq.
Michael Burlingame, Site Manager
July Ifc, 1990
Page Five
responsibility, fault or liability on the part of the Site
Committee or any member of the Committee.
It should be noted that the Site Committee was given only a
short--time to review these voluminous and complicated draft FS and
RA reports and submit comments. It is the Committee's
understanding that the shortness of this comment period may be
attributable to a draft Proposed Remedial Action Plaji ("PRAP")
prepared by DEP which it intends to issue within the next few days.
Be that as it nay, the Site Committee feels that it was not
afforded an adequate opportunity to properly review and assess the
FS and RA and provide complete and thorough comments. It reserves
the right to supplement its comments based on additional review and
other information that may come to its attention.
Finally, the Site Committee wishes to bring to DEP's attention
that it is in the process of preparing comments responding to EPA' s
and DEP's comments on the draft Remedial Investigation Report.
Because of the short time afforded to comment on the FS and RA,
the Site Conrittee's other comments were not completed and
submitted to DEP on the date originally intended. It anticipates
submitting these comments in the next few days. The Site Committee
reserves the right to file these comments and to supplement ther.
in the future, as necessary and appropriate.
Thank you for the opportunity to submit these comments for
DEP's consideration.
Respectfully submitted,
Borough of Sayreville
Celotex Corporation
Chevron Chemical Company
Hercules, Inc.
Mobil Chemical Company
Pfizer Inc.
Ruetgers-Nease Chemical Company, Inc.
NVL:er
cc: Ms. Sharon Atkinson, USEPA
Joe McVeigh, Esq., USEPA
Attachments
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frkilr nf Nnn j/ri
DEPARTMENT OF ENVIflONMEN T A I. PROTECTION
SOLID WAflC AIIMINlSt n*TlON
TWCNTON one IB
Septembei 10, 1<>7<)
Peter riwim.-j, P.I:.
.Vhoor Ijij; incci inj; , Inc.
Post 01 I ii-e Ifcix Mlfl
K-ilau.ni, N.-w Jersey 077-17
III!: S:iyirvilte Ilornugh Snni tary l.:n»ill i 1 I , SayrcvilJe llojoiu;h,
Mi.K!lesi.-x County, facility Urjjist \ at ion Number 12l(JH
Dear Mi . iriiinicJ:
Wi1 li.-ivc reviewed tlie jnfonii.-ii inn in 0111 files i eluding DIP
nhovc l.-ind.rj 1 J . H:i.sed tipon yum COM c*j>"iiilnu e ,t>ul nn insj>c< t ions
by oin sia.T, we .TIC prepaied tn icvisc tin.1 final cover r
and ^.r, vcnl locations 5^ ll>-'>l Hi<% l;un!fill in.iy l>r
UIL' final fover shall rtm«ii^t »»n (UK- ('out of tiny on tin? laml-
fill sii!.- sln,vs covcicd by one (uol uf scii I capalile of suppurt iuj;
veuotal ion. 'liic top sut favv sli;>11 consist of a minimum of two
feel of soil capnl>lc of supporting vv^iMat ion and shall be pjadt-d
nnd coni;>aticd so as lo vciliae infijlialion of injnwaici. All
surfaces shall he seeded nnd shall he maintained tn pi event erosion.
Mr thane j;a?< vents shall he installed at Ihc 200 fcrt by 20d (ret
Spai'in^, as yon h.ive previously injucslcd. A copy of Ihc constHK:! in
details lot \\:\r, vents is enclosed for yom refcmir.e.
Plra'.f tnnf;ict Mr. Uohci! P.»«-ll at (fif)'I) 2t.)2-(l'Jir, or Mi. John
Castuci at (fill'.)) 2'J2-02'in, both of my staff, vr^.n«liiiij a completion
tl.itc <>( Ihc ahovr X'tntiiciimnt s so t!i;it we may nirnngr a final in
SIKH t ion nl UH« facility.
Vfi y f inly ymu «»,
Kin
•W.i I in ihii-rJajib P.I:., P.P.
Hurl , I.nj;iiuTi iii]>. and l:.nforccnicnt
cc: Miiy .1. Ki»r.akin«ski , Horouj'.h CltM k_
U.i-.-.i-ll .M.-yc'i . .SupI . of lloa.K .
"1
"I
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ATTACHMENT 1
TO Be* 310. Hbe'V Corner. N J 0793P 0310 (?0i) 647
-red C. HdrfAssocbtes, inc.
»t NV
N>
MA
H«; NJ
Mo>«fo
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(ii) there are no plans that the Site Committee is
aware of to construct residences on or in the immediate
vicinity of the landfill;
(iii) development of the property may be restricted
by laws respecting development in wetlands, floodplains, and
on solid waste landfills; and,
(iv) if residential development must.be considered
in the RA, modest controls could be implemented (i.e.. zoning
restrictions) to further limit the likelihood of this
scenario.
3. Given the minimal risks identified in the RA, the
FS fails to adequately address the appropriateness of the No
Action alternative, or some modification of this alternative
which incorporates the installation of limited areas of soil
cover, site security, and institutional controls, and thereby
adequately addresses the current and future risks associated
with the site. A more conservative approach might include the
selective removal of drums still located in the fill (see
com.T!ent 4), in combination with the above. This should be
evaluated as a separate remedial alternative in the FS.
4. The FS places a great emphasis on the removal of
drums from the landfill, incorporating this as an element of
each alternative except the No-Action alternative. It is
important to note the documented low concentrations of
constituents taken from these drums and surrounding soils
during the Remedial Investigation. The FS implies that drums
at the site represent a significant source of contaminants to
be released in the future. Again, it should be noted that
despite extensive geophysical surveys and test pit excavations
only a relatively small number of drums have been found.
It should be noted in the FS that the presence of
"industrial" waste materials in small quantities does not have
a measurable effect on leachate or gas quality. In fact,
studies have shown that sanitary landfills have the capacity
to absorb relatively large quantities of hazardous material
with little impact on emissions from the site (Household
Hazardous Haste in the Sanitary Landfill , Kinman and Nutini,
Chemical Tames and Trends, July 1988). Field studies
performed by Unocal and others have also demonstrated that
releases from municipal landfills and those at which co-
disposal has occurred are indistinguishable except for those
which are dominated by large quantities of "mobile" (i.e.,non-
containerized, liquid) industrial wastes. This is not the
case at the Sayreville site. The conditions found at the
Sayerville site clearly resemble those of a municipal landfill
and not those of a "hazardous waste" disposal site.
Therefore, any over-emphasis of the industrial contribution
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to the site is not supported
literature.
by the RJ database and the
HART
5. The estimates provided for the capping options
(Alternatives 3,4, and 5) do not include line items usually
incorporated into estimates of this type. These items include
mobilization, health and safety requirements, site inspection
and management costs, personnel protection costs,
-stabilization of landfill surfaces, and accounting fees. As
these items can be significant (15-20 percent of capita]
cost), it appears that the estimates for the .capping options
may be artificially low and do not represent realistic
estimates of implementation costs. In addition, the use of a
30 percent contingency would be more appropriate to apply to
the more complex alternatives (i.e., 4 and 5), given the level
of analysis applied to the conceptual design presented in the
FS. While the accuracy of the estimates by B6V have not been
verified and accepted by the Committee, incorporation of these
additional elements could increase the capital cost of
Alternative 3 to $5.0 million. Alternative 4A/B to $7.3 - 10.3
ir.illion. and Alternative 5 to $7.3 million. Some offset of
these increases could be realized for Alternative 3 if the
existing solid waste cap materials can be integrated into the
fir.al design.
The estimates for Operation and Maintenance of
Alternatives 3,4. and 5 fail to clearly address costs
associated with the collection and disposal of leachate, if
that option is chosen. It is unclear what the cost of
$276,903 for O&K of the leachate control system includes and
upon what assumptions it is based. No presentation of the
assumptions used to determine adequate flow rates, capture
zones or placement of the collection network is made in the
FS. As a result, the accuracy of cost estimates for
construction, operation, and maintenance of a leachate
collection system at the site cannot be evaluated.
In any event, the specific operation and maintenance
requirements of the selected remedy cannot be determined until
the detailed design is completed. It is essential that an
appropriate level of flexibility be built into the operation
and maintenance plan which allows for the identification of
target parameters for monitoring and/or reduction of sampling
frequency as supported by the data. The Site Committee
anticipates the submission of additional comments to the
operational plans as they develop during the remedial phase
of this investigation.
6. The implementation of Alternative 6. Excavation with
Offsite Treatment/Disposal, is clearly not appropriate for
consideration due to issues of cost, excessive increase in
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timeframes, implementabi1ity , and significantly increased risk
to human health and the environment.
It is likely that the capital cost to implement this
alternative will be far in excess of the projected $89 million
presented in the PS. The cost of excavation alone would be
increased due to unforeseen conditions and the general
inexperience in the industry of performing such an operation.
'Contractors would apply high levels of risk to such an
operation and thereby significantly increase unit costs for
such operations. The lack of actual cost .data makes, the
estimate, _as proposed, hi.ghly speculative. the PS presents
little information on how such a remedy could be physically
performed, a realistic projection of schedules, or the costs
associated with permitting, protection of the environment, and
mitigation of potential impacts to the community.
Additional problems are associated with the
implementabi1ity of such an alternative. The probability of
finding an approved facility with sufficient capacity to
handle 280,000 cubic yards is extremely low. Similarly, B&V
estimates that over 18,000 truckloads would be necessary to
remove the landfill materials; expansion of the in-place
materials may significantly increase the number of loads
required to transport the waste. Even at the current level,
the risks associated with traffic, noise, air pollution, and
fugitive emissions will far outweigh those of leaving the
material in place in its current condition. In addition,
excavation and removal of the waste to a disposal facility is
inconsistent with the National Contingency Plan and exposes
a much greater number of receptors to the source constituents.
The process of excavating the fill materials would pose a
significant risk to on-site workers through the volatilization
of organics, increased insect and vector nuisances, and
increased likelihood of constituents entering the food chain
over a significant period of time. Further, the exposure of
the refuse to the air might result in fires, would produce a
serious odor problem, and could pose a potential health
threat. It is highly unlikely that these risks can be
mitigated to any reasonable level' of public safety.
Exposure of the landfill materials to precipitation
for a long period of time will also increase leachate
production and increase the migration of source constituents
into the South River, estuary and tidal wetlands, and
neighboring properties. Mitigation of these effects, if
possible, will require the design and implementation of long-
term erosion control programs which have not been included in
the current estimate.
7. The Baseline Risk Assessment selects "ingestion and
contact with sewer line water" as an exposure pathway under
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both the current and future land use scenarios. The
incorporation of this pathway is inappropriate based on the
fact that the source of the observed contaminants (carbon
disulfide and lylene) has not been adequately defined. In
addition, the RI reports that "it is not known at this time
if exfiltration or infiltration is occurring" (See Rl at 5-
33). Therefore, the source of these contaminants may very
well be off-site rather than the landfill itself. Until the
mechanism of transport is defined, these compounds should not
be included as chemicals of potential concern from the sewer
line.
8. Table 2-13B of the. RA dismisses PCB Arochl or -1248 and
1260 as chemicals of potential concern in sediment. The
identification of PCBs as "chemicals of potential concern"
(gee RA at 3-13), and the inclusion of Arochlor 1260 as a
chemical of concern in Table 6-1 is inconsistent with the
findings of the screening process. These specific references
should be edited to be consistent with Table 2-13B.
Sl'KMARY EVALUATION OF FS ALTERNATIVES
Alternative 1 - No Action - This alternative should be
given serious consideration. The Rl and RA have both
demonstrated that the site does not pose a significant risk
to human health and the environment. Early reports of
significant hazardous waste disposal were not verified by
field investigations. Even in areas of drum disposal, the
levels of contamination measured were not inconsistent with
typical municipal waste landfills. The FS should justify and
document why the no action alternative (delisting the site)
is not a viable remedy.
Alternative 2 • 0oil Cap - As above, this alternative
meets the response objectives to protect human health and the
environment. Given the findings of the RI and RA, an
alternative which combines selective removal of drums, re-
establishment of the soil cover in limited areas, and site
security should be considered. Due to the fact that • solid
waste cap has already been installed on the sideslopes of the
fill, the concept of a soil cap to enhance and/or repair the
existing cap is a viable remedy. The possibility of delisting
the site following implementation of this alternative should
also be investigated. As with Alternative 1. the conclusion
that Alternative 2 may not comply with ARARs should be fully
explained and justified.
Alternative 3 - NJDEP Solid Wait* Cap - Based on the
findings of the RI and RA, the selection of this alternative
is inappropriate and unnecessary. However, should it be
positively concluded that an impermeable cap be required, this
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HART
alternative is the most appropriate of those presented in the
FS. In fact, the level of protection to human health and the
environment provided by placement of this cap is further
enhanced by the existing solid waste cap at the site. This
approach is reinforced if the planned removal of all buried
drums is implemented. The remaining waste will be almost
exclusively municipal, and any more stringent remedial action
would be excessive.
Alttrnativts 4,5- NJDEF/RCRA Hatardoua Wait* Cap -
These alternatives are clearly excessive and inconsistent with
the findings of the RI and RA. Removal of drums obviates the
need for RCRA-related ARARs. Hazardous waste caps are
intended for closure of RCRA-type facilities where.
concentrated wastes are contained in discrete units. The
application of a RCRA-type cap at a municipal landfill where
the waste is widely dispersed and bears little resemblance to
the discrete units regulated under Subtitle C of RCRA is
inappropriate (See 53 Federal Register 51447, December 21,
1985). Cost estimates do not include sufficient contingency
or numerous implementation costs. Actual costs of
construction for these alternatives could easily exceed
current estimates by 35 percent.
Alternative 6 - Total Excavation and Disposal - This
alternative is not implementable on a practical basis, will
take an extremely long period to complete, and is inconsistent
with the National Contingency Plan. Mitigation of probable
impacts to human health and the environment would be
prohibitively expensive and difficult to implement. Lack of
industry experience in action of this type makes estimating
cost difficult and speculative. Increased risk to human
health simply due to transportation of 16,000 loads would
increase incremental risk well above current levels.
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ATTACHMENT 2
KA COMMENTS
peotien 1.1.1 (PP. 1-1) - sake* reference tq "Numerous drums,
containing a variety of volatile organic* ... have been excavated
from the site. Although some drum* were excavated, it is alleged
that th«r« are druma present...." These statements tre imprecise
and confusing in their ambiguity. Relatively few druse have
actually been discovered at the Landfill III, despite extensive
geophysical investigations and excavation activities.
Figure 1.4 fpo. l.ai - Figure 1.4, labeled as a "Site Plan"
depicts an area identified as the "work area.11 The site
coffm.ittee is unclear concerning the purpose or implication of
this designation. Clearly the area designated as the "work area"
includes areas outside of, and separate front the Sayreville
Landfill III. The Site Committee objects to the inclusion of
risk factors in the JRA for the Landfill III attributable to
activities outside of the Landfill III.
fleetion 1.3 (pa. 1-12) - The Site Committee objects to the
development of the RA for the Landfill III based on contaminants
froc "other hazardous waste sites." Empirical data demonstrates
that the Landfill III has not contributed, and ia not now a
significant contributor of contamination to the environment
surrounding the wastefill. To the extent the RA fails to
distinguish between risks associated with off-site sources (such
es chromium, the presence of PCB aroclorc 1246 and 1260 in
sediments below DuPont's outfall and PAHs and other sediment
contaminants detected in the South River upstream of the Landfill
III), it should be reworked or disregarded.
flections l.s end l.s.a (pas. 1-16 end 1-lil - Celotex/Ineul-
Coustic strenuously objects to the RA's characterization of, and
implication that the neighboring Insul-Coustic property is a
"hazardous waste site." The Insul-Coustic property is not a
hazardous waste treatment, atorage or disposal facility under
state cr federal law and there is no evidence presented in the
draft RI, Dennis Cray's Preliminary Assessment or the NJDEP's
Bureau of Community Relation's files to suggest, let alone
confirm that the property is now, or ever has been a hazardous
vasts cite. Implication of the Insul-Coustic property and
facility in hazardous substance contamination In or about the
fiayrevllle Landfill III ehould be deleted. (The fits Committee
does not express an opinion concerning this Comaent by
Celotex/lniul-Couiticj
emotion l.s fpgt. l-li through 1-21) - Evidence concerning the
nature and type of contaminants oonfirmed to be present et
adjacent facilities should be diecussed and developed in greater
detail, so that correlationa can be made between documented
nd*hb^>ing contamination problems (e.g., PCB's at DuPont's
facility) and conditions near the Landfill III (PCB'e downstrear.
of DuPont's discharge outfall). By way of further example, the
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w
Site Conaittee also believes currant data euggeste that chroaium
contamination in tha vicinity of the Landfill til ia cauaed by
aourcaa upgradient of the Sayreville Landfill. Ill, a auppoeition
which could ba conflnnad by raviaw of information knovn to DEP
and/or EPA regarding upgradiant facilities. ' (There alao appear*
to ba a typographical error in tha refaranc* to *Owners-
Xllinoia": the reference probably ahould ba to "Owene-Xllinoia").
peetloa i.a.a fpy e-iai - Reference is made to the Spotawood Pine
Barrens being "juat north" of the Landfill III. The RA should be
•ore .preciae concerning this dietance, which ia well beyond tha
aphere of influence of the Landfill III.
•action t.2.5 fpo. t-U) - The obaervation that atreaaed
vegetation vaa "aighted in araaa of expoaed waste" is
inconaiitent with other eectione of the RA which atate that the
areas of exposed vaate lacked vegetation (due to a lack of eoil),
and that actual vegetation adjacent to theae araaa did not appear
atreased. (&££, e.o.. pge. 6-12 and 7-7). indeed, tha RA
properly reporta in other areae that the Landfill III aupports a
healthy vegetative cover. It alec ahould be noted that the
"exposed waste" ia typical municipal waste and not "hazardoua"
waste.
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NJDEP Responses.to comments entitled/ Feasibility study and Risk
Assessment Reports, 8AYREVILLE LANDFILL III, by tbe Borough of
Sayreville; Celotex Corp.; Chevron Chemical Co.; Hercules, Inc.;
Mobil Oil Chemical Co.; Pfizer Inc.; and Ruetgers-Nease Chemical
Co. Inc., to Neal Brody and Michael Burlingame, dated July 16,
1990.
Feasibility Study fFS)
Other Comments
1. a. Agreed. No response required.
b. Agreed. No response required.
c. Agreed. No response required.
d. No response required.
e. Agreed. No response required.
2. The necessity of a new, impermeable cap was evaluated in the
FS in accordance with the nine evaluation criteria from the NCP
(and not risks alone) . The impermeable cap is required to meet
EPA's two threshold criteria: overall protection of human health
and the environment and compliance with ARARs. Currently, New
Jersey Safe Drinking Water Act (NJSDWA) MCLs and New Jersey
Ambient Water Quality Criteria (NJAWQC) are exceeded in the
ground water and surface waters, respectively. NJDEP Interim
Soil Action Levels are also exceeded in the sediment samples,
which are the appropriate "To Be Considered" criteria. Based on
preliminary calculations, ARARs for discharge to surface waters
are also exceeded at the site. Attached are two memoranda: (1)
M. Burlingame to I. Kropp, undated and (2) S. Kim to I. Krbpp,
dated 1/26/88. The later memorandum indicates that, based on
preliminary calculations, using flow rates presented in the RI,
the discharge of contaminatation in the landfill leachate (and
concurrently into the shallow aquifer) into the South River is
unacceptable.
Without some barrier to prevent the continued generation of
leachate, the potential for continued releases of contamination
froir, the wastefill will remain, and the attainment of ARARs in
the ground and surface waters, and the natural attenuation of
existing contamination in the stream sediments, will not be
possible.
The potential for future releases of more-elevated levels of
contamination will also not be mitigated without minimizing the
generation of leachate with an impermeable cap. Although
geophysical surveys conducted during the remedial investigation,
along with extensive test pit excavation, have located areas
where drums of hazardous wastes are concentrated, the possibility
remains that there are other areas in the wastefill which contain
additional drums, contaminated materials or pockets of hazardous
liquids, which may continue to leach into the environment. As
the solid waste materials composing the wastefill degrade, their
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ability to hold contaminants will diminish. Short of
implementing Alternative 6 which would result in the removal of
all wastefill materials, the second best approach involves the
placement of an impermeable cap on the landfill to reduce the
generation of leachate in the wastefill. Of those alternatives
which include impermeable liner systems, Alternative 3 is the
most cost-effective.
The statement in this comment that the risks at the site are
minimal is contrary to the results of the Endangerment Assessment
conducted for the site. It was determined that for future
scenarios, the hazard indices for on-site residents exceeds one
(suggesting that non-carcinogenic effects may occur as a result
of site-related exposures). Adult and child on-site residents
exposed to soils have hazard indices (His) of five and eight,
respectively. . A ground water HI of one should be added to each
of these, resulting in a HI of 9 for future children living on
the site. In soils, the bulk of risks is associated with
pesticides, and in ground water, metals. For future on-site
residents, the lifetime excess cancer risk is 2 X 10'3, primarily
from dermal contact with pesticides in soil. The potential risks
to residents due to carcinogens at the site are greater than the
acceptable EPA risk range of 1 X 10^ to 1 X 10*.
In addition, although not quanitified, there exists a risk to
users of the shallow ground water aquifer. This aquifer (and the
deep Farrington aquifer) are currently designated as suitable for
sources of drinking water. It has been shown that contamination
from the landfill has impacted the quality of the shallow
aquifer. Sampling results in the aquifer indicated that health-
based levels were exceeded for benzene, cadmium, chromium and
nickel. To reduce the continued migration of contamination from
the landfill, and thus reduce the potential future risks to users
of the shallow aquifer, some form of containment of the landfill
is required.
Since re-capping of the landfill has been selected as part of the
preferred alternative, the design and construction of the cap
will be performed in accordance with current state and federal
requirements (ARARs). These include the New Jersey Solid Waste
Regulations (NJAC 7:26) and RCRA Subtitle D requirements. The
current state-of-the-art cap requires: (1) a vegetative top
layer that would minimize erosion and act as a buffer to the
underlying layers, (2) a middle drainage layer that allows for
the drainage and runoff of any infiltrating storm water so that
there would be no accumulation of standing water on the low-
permeability layer, and (3) an impermeable layer (a 40-mil liner
made of gecsynthetic material or another of similar demonstrated
performance) .
In summary, NJDEP believes that the preferred alternative would
serve to protect human health and the environment by minimizing
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»
the generation of leachate and potential for continued releases
from the wastefill. Alternative 3 also promotes cost-
effectiveness as it represents the least expensive of the capping
alternatives.
Baseline Risk Assessment Report fRA)
Other Comments
1. See response $1 above.
2. No response required.
3. No response required.
Attachment 1; Comments on Sayreville Landfill III Feasibility
Study and Risk Assessment, bv M.A. Barbara and D. Farley. F.C.
Hart Assoc.. Inc.
1. More detail has been provided in section 4 of the FS
concerning Alternatives 1 and 2 and how they meet ARARs.
2. The statement in the FS that the wastefill has not impacted
ground water, surface water or sediments is incorrect and has
been changed. It is agreed that a security system to prevent
access to the site would eliminate risks to trespassers, however,
the same would not be true regarding risks to the environment.
Note that risk to human health is not the only evaluation
criteria for a viable alternative (see response #2 above to FS
comments) . It is also agreed that the future residential use of
the site is unlikely and language to that effect has been added
to the RA (see Sec 3.3.3.2).
3. Additional language has been added on pages 4 - 6 to discuss
compliance with ARARs for the No Action Alternative. In
addition, the request was made to present an additional
alternative in the FS, equivalent to Alternative 2, Drum Removal
and Soil Cover, but requiring only patching of the existing cap,
in place of placement of a new cover two-feet in thickness. With
the exception of cost, it is felt that this alternative .would not
differ substantially from Alternative 2 as originally proposed.
No matter which cap or cover is selected, consideration will be
given to incorporating the existing soil cover materials into any
new cap or cover.
4. We do not dispute that studies of other sites have shown that
sanitary landfills have the capacity to absorb relatively large
quantities of hazardous materials with little impact on site
emissions. However, levels of contaminants in ground water,
surface waters and stream sediments have exceeded regulatory
standards for these media at the site.
5. Based on previous experience with other similar remedial
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projects, a conti-ngency of 15% of the subtotal was chosen to
cover items such as health and safety costs and accounting fees.
Tables 4-2 thru 4-8 include mobilization costs as a separate line
item. Costs for stabilization of landfill surfaces are included
in cap placement costs. Leachate collection and disposal costs
are included in the O&M costs and will not be presented
separately. Please note that these costs are only estimates.
6. It is agreed that Alternative 6 would be very difficult to
implement. However, the alternative was retained as it would
attain or exceed all ARARs for the site, and result in the return
of.the area to its original baseline condition.
7. The origin of the contaminants (i.e., carbon disulfide and
xylene) considered in connection with exposure to the sewer line
water was not a consideration. Determining the total risk
experienced by workers on the sewer line to all possible
contaminants was the desired result within the Risk Assessment.
In addition, the assessment identified the various risks posed by
the contaminants and the pathways for exposure.
8. Chemicals of potential concern for the ecological assessment
(Table 6-1) include several more than those selected as a concern
for human health (in Table 2-13). Arochlor 1260 is one of these
additional chemicals.
9. Alternative 1, No Action: Section 4.2.1 of the FS presents
an evaluation of this alternative according to 7 of the 9
criteria in the NCP. The threshold criteria, overall protection
of human health and the environment and compliance with ARARs,
will not be met by the No Action Alternative. Delisting of the
site is not a possibility as long as hazardous materials remain
onsite and continue to leak into the environment.
10. Alternative 2, Soil Cap: See response to FS comment #1 on
page 1.
11. Alternative 3, NJDEP Solid Waste Cap: No response required.
12. Alternatives 4A and 6 and 5, NJDEP/RCRA Hazardous Waste Caps:
See response 15 above concerning the cost estimate.
13. Alternative 6, Total Excavation and Disposal: No response
requested.
Attachment 2: Specific RA Comments
1. Sec. 1.1.1: This statement has been reworded.
2. Figure 1.4: "Work area" has been changed to "sampling area".
The RA attempted to screen out risks due to chemicals from other
sites by excluding from consideration contaminants found only in
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background samples, excluding metals that were detected at less
than five times Background, and eliminating common laboratory
contaminants.
3. Sec. 1.3: To the extent practicable, the RA attempted to
screen out risks due to background contamination (see response #2
above) or treat them separately (see Appendix A for ground water
in MW-13 and Appendix D for risks from surface water samples 1,
6, 9, 14, and 16). Regarding human health risks under current
conditions, the greatest carcinogenic risks are from exposure to
contaminated landfill soils. This determination did not depend •
on background contamination. For the assessment of current
ecological risks posed by contaminated surface waters, the RA
found no risk. This was because lead and cadmium may have
originated from an upgradient source. The RA did note potential
current risks for aquatic organisms exposed to sediments near the
confluence of Pond Creek and the South River due to the presence
of cadmium, DDT and mercury. Both cadmium and mercury were
elevated in samples taken from the South River downstream from
the site. In addition, these chemicals were present in the
wastefill leachate. It is believed that based on the above,
background levels of contamination were screened appropriately.
4. Sees. 1.5 and 1.5:3: Changes have been made to the RA as
suggested.
5. Sec. 1.5: It was beyond the scope of the RA to research in
detail problems at other facilities in the vicinity of the site.
Due to high levels of background contamination in the vicinity of
the site, the RA purposely confined itself to the site to avoid
becoming a regional study. The adfjacent facilities presented in
Section 5.1 of the FS support the existence of background
contamination.
6. Sec. 6.2.3: It is agreed that the Spotswood Pine Barrens
outlier is beyond the influence of contamination at the site.
7. Sec. 6.2.5: Changes will be made as appropriate to the text.
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ATTACHMENT D
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CARPENTER, BENNETT & MO$R]SSEY
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Michael Burlingane
State of Hew Jersey
Department of Environmental Protection
Division of Hazardous Site Mitigation
CN-413
Trenton, Nev Jersey 08625-0413
Neal Brody, Esq.
Office of Regulatory Services
Nev Jersey Department of
Environmental Protection
410 East State Street
CN-4.01
Trenton, Nev Jersey 08625
Re: Sayreville Landfill III - Hercules
Incorporated'B Comments on Baseline
Risk Assessment
Dear Sirs:
The following are Hercules Incorporated'e
(•Hercules") cocxents on the draft Baseline RisX Assessment.
At the outset you should be aware that Hercules
supported the employment of Fred C. Hart as the Site Committee's
technical advisor, and it joins in the comments made by Fred C.
Hart on behalf of the group. Furthermore, while Hercules signed
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ABPEK7IR. BEKNETI & MORRJSSEY
Michael Burlingame
July 17, 1990
Page 2
off on the Site Committee's cover letter drafted by Mr. Nielsen
Lewis and supports the group's effort in this regard, it does not
*
agree, with all of the comments Bade in that letter and takes no
position thereon. In addition, you should be aware that due to
time constraints in meeting NJDEP's deadlines, Hercules was not
able to circulate these comments to the other members of the Site
Committee prior to submitting them to you. Accordingly, the
other members of the Site Coirjr.ittee have reserved the right to
comnert on this letter.
The double reference to "Hercules Incorporated
Landfill" and "Hercules Landfill" on page 1-21 is misleading.
First, Hercules does not have two landfills in the Sayreville
Landfill III (or the "Site") area. The Hercules property
referred to in the Baseline Risk Assessment at page 1-21 is its
Parlin facility, which is a RCRA permitted facility and which has
also received a HSWA permit from USEPA to conduct RCRA facility
corrective action on its solid waste management units. Second,
neither the RI/FS, nor the Baseline Risk Assessment, nor any
other document that Hercules is aware of have ever indicated that
this facility has impacted on the Sayreville Landfill III;
therefore, it is inappropriate to suggest that the Parlin
facility nay be a contributing factor to the contamination at the
Sayreville III Site. Accordingly*; the double reference to
"Hercules Landfill" should be deleted or at a minimum should be
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CARFEK7IB. BEXNETT ft MOEB1SSEY
9
Michael Burlingame
July 17, 1990
Page 3
revised to accurately reflect the fact that there is only one
Hercules facility proximate to the Site, and that this facility
has not been demonstrated to affect the Site.
In addition to the foregoing, Hercules has general and
conceptual criticisms concerning the Baseline Risk Assessment
document.
First, Black t Veatch analyzes and calculates the
carcinogenic and non-carcinogenic risks.posed by contamination at
the Site based on the assumption that the land upon which the
Sayreville Landfill III is located will be used as a residential
area in the future, with extensive soil excavation (thus bringing
contaminated soil to the surface) , and with the installation of
drinking water veils. As explained in the comments submitted by
Fred C. Hart at pages 1 and 2, the assumption of future
residential use is unrealistic for numerous reasons outlined
therein; consequently, the calculation of carcinogenic and non-
carcinogenic risks based on these assumptions is overstated.
Assuming non-residential future use would have been a store
realistic scenario upon which to base the risk assessment..
Related to the misplaced assumption of future residen-
tial use is the fact that the soil camples and attendant analysis
were obtained from soil sampled at depths of up to twelve feet.
Assuming that the Site will noffcte used for residential purposes,
it is difficult to envision human exposure to contaminants that
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CAHFEXHB. BEXKETT ft MORJUSSEY
Michael Burlingame
July 17, 1990
Page 4
are twelve feet below the surface of the ground. The use of a
non-residential scenario coupled with restrictions such as site
security and fences would have produced a more realistic scenario
upon-which to base exposure pathways and the calculation of risks
based thereon. Indeed, at pages 3-49 and 3-59, even Black &
Veatch acknowledges that its assumptions of future residential
use and attendant excavation will result in exaggerated exposure
data.
Inasmuch as soil is an exposure route of primary
concern in the Baseline Risk Assessment, the depth at which soil
sar.ples were obtained should be provided; otherwise, it is
impossible to determine from the information provided whether
specific contaminants were found at or near the surface.
Moreover, the brief description at pages 2-6/2-7 of how
soil samples for analyses were obtained indicates that they were
collected from a depth of four to twelve feet. There is no
discussion to indicate if surface soil samples were collected and
analyzed, and later in the report (at pages 3-22/3-23) Black I
Veatch states that it "estimated" actual exposure concentrations
by using, inter alia, analytical data from soil taken from depths
of tero to twelve feet. The failure to provide information
concerning the actual depths at which specific soil samples were
taken and whether surface samples were taken Bakes it impossible
for the reader to determine whether Black fc Veatch's estimated
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CABPEKTER. BEXXETT & MORRISSEY
Michael Burlingame
July 17, 1990
Page 5 .
exposure data can be relied on for purposes of selecting a
re»edy.
In addition to these inadequacies, Hercules submits the
following specific comments on exposure levels and pathways:
Section 3; .
This section discusses exposure pathways for humans
fror current and future use of the land.
Table 3-2 summarizes exposure pathways from current
use, gives reasons for excluding certain pathways from
consideration, and also provides the rationale for including
other pathways in the risk assessments. The pathways of concern
for current use are 1) exposure of offsite residents to sediment
in creeks and rivers, 2) exposure by ingestion and dermal contact
of onsite workers to soil and contaminants in the sewer line, and
3) exposure by ingestion and dermal contact of adult and child
trespassers to soil. As stated previously, it is difficult to
imagine that trespassers or even onsite workers will be exposed
to contaminants found in soil taken from 12 foot depths.
Table 3-3 summarizes future land use exposure pathways.
The pathways of concern and for which risk assessments were done
are those which assume that the landfill site will become a
residential site. The pathways for exposure assessed vere 1)
exposure to groundwater from the'shallow aquifer by onsite
residents due to the installation of wells and 2) exposure to
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CABPDOXR. BEXKETT & MORJUSSEY
9
f
Michael Burlingane
July 17, 1990
Page 6
•oil by onsite residents as the chemical contaminants are brought
to surface during excavation. Although these two scenarios are
stated to be "unlikely", nevertheless, risk assessments were done
on this presumption. This is a landfill closed under NJDEP
standards vith a cover of soil and clay; it is probably in both a
flood plain and a wetland. It is a gross understatement to say,
as the RA does, that construction of residences requiring 12 feet
of excavation is unlikely.
Another pathway of concern is the groundwater in veil
GW-13 which is discussed in Appendix A. Apparently it has not
beer, determined whether this well is impacted by the Sayreville
Site or is upgradient of the Site.
Sectior, 5;
This section presents calculations and summaries of
chronic, i.e., non-carcinogenic, hazard indices and carcinogenic
risk for current and future land use scenarios which were
determined in Section 3 to be of concern.
For current land use the chronic risk or chronic hazard
index for the offsite residents exposed to sediment, for onsite
workers exposed to soil and sewer line contaminants and for adult
and child trespasser are all below the hazard index of concern.
For carcinogenic risk for current land use for onsite workers and
trespassers, the risks are slightly above the 1x10-6, i.e., 1 in
a million, which is a risk level that is considered to be
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CABFEXTEE. BEKXETI & MORJUSSEY
9
Michael Burlingame
July 17, 1990
Page 7
acceptable by the EPA. The report does state on page 5-12 that
ZPA policy states that the total individual risk resulting from
exposure at a Superfund site may range from 10"4 to 10'7. The
carcinogenic risks are 4xlO"6 for onsite workers, 8xlO~6 for
adult trespassers and 2xlO~6 for child trespassers which is well
within this range. These risks are primarily due to chlorinated
pesticides. The risk to current offsite residents is 8xlO~s for
adults and 1x10*8 for children; these levels are below concern
levels.
For future land use (keep in mind that this means using
the Site for water wells and residences) the chronic non-carcino-
genic hazard indices are above 1, the level of concern, for
adults and children; the index for adults is 4 and for children
is 7 (the 7 includes the risk for drinking water from an onsite
well).
How the index for children was calculated cannot be
determined from Table 5-2 since it appears that it has been
assumed that children will be exposed to sewer line water
contaminants by ingestion, skin contact and inhalation and since
the sewer line was not considered to be a pathway for future
exposure. The section for children also includes calculations
for adult trespassers. This section of Table 5-2 should be
revised.
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CARPENTER. BEXXTTT & MORJUSSEY
»
r
Michael Burlingame
July 17, 1990
Page 8
For future land use the carcinogenic risk 1x10-3 fOr
•dults and 2xlO~4 for children is primarily from exposure to
chlorinated hydrocarbon pesticides in the coil. Arsenic in the
groundvater also presents a 4x10-4 risk according to the
document. If the future land use scenario is used, i.e.,
conversion to a residential area, then the risk would have to be
reduced to at least IxlO"6.
Section 6;
The ecological assessment section is sparse both on
data and conclusions. The primary concern is the presence of
pesticides, e.g., DDT, and heavy metals, e.g., mercury and
cadriur in the sediment. These can accumulate in aquatic
organises and move up the food chain. There is some discussion
of the options that could be used to return this Site to its
natural state; however, no conclusion is reached.
Appendix A; Well CS-13. The non-carcinogenic risk is
below the level of concern. However, the carcinogenic risk
lxlO-4 due to arsenic. Trans-l,3-dichlorpropene has been
included in the carcinogenic risk assessment although no
information has been presented in Appendix B that it or its
surrogate, 1,3-dichlorpropene, whose elope factor vas used in the
calculations, is a carcinogen.
Aside from these concerns, Hercules respectfully
subaits that the copy of the Baseline Risk Assessment it received
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CARPEXTER. BEKKETT & MORR1SSEY
»
Michael Burlingame '
July 17, 1990
Page 9
appears to have pages and data missing from certain tables and
discussions. These omissions prevent the reader from deter-
mining whether chemicals not detected at the Site were used in
calculating exposure and risk assessments, and whether these
calculations were performed correctly for chemicals actually
found at the Site. In this regard, Hercules offers the following
specific co&nents:
Section 2:
Page 2-2: Figure 1-6 which is mentioned on this page
is not included in the report.
Page 2-13: It is stated that characteristics of
cher.icals of potential concern are included in Appendix B. All
of the chericals used for exposure and risk analyses are not
included in Appendix B, and health effects summaries for
chericals that are not of concern are included in Appendix B.
(See coEjnents on Appendix B below.)
Tables: It is Hercules' opinion that pages are missing
from its copy of the Baseline Risk Assessment for Tables 2-6A, 2-
6B, 2-6A, 2-8B, 2-10, 2-12A, 2-12B and 2-14. If pages are not
missing, then the information in the frequency of detection
columns is incorrect. For example, Table 2-6A indicates that
chloroethane was detected in 8 of 9 samples analyzed; however,
data is presented for only 2 samples. A page headed as Table 2-
12B (Continued) is in the report; however, there is no previous
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CAHFEKTEB. BDWFJ7 A MOSR15SEY
9
t
Michael Burlingame
July 17, 1990
Page 10
page for Table 2-12B. In addition, Table 2-12B (Continued) does
not include frequency of detection or detection limit infor-
mation.
If pages are not missing from the tables mentioned
above, then Tables 2-7A, 2-7B, 2-9A, 2-9B, 2-12A and 2-15 are •:
incorrect for they give the rationale for stating that chemicals
are of potential concern when they were not detected at the Site
based on data provided in this document.
Table 2-16 which summarizes chemicals of concern in
specific media is also incorrect if pages are not missing from
the tables providing data, since Table 2-16 lists chemicals
reported as not detected. This table also includes a list of
chericals in a column headed "chemical or parameter", but does
not indicate what the parameter(s) of concern are.
Incomplete data tables make it impossible for the
reader to determine whether exposure and risk calculations were
done correctly. In the case of many of chemicals of concern, the
only information provided in this report are that they were not
detected in certain media. Also, as discussed above, since
exposure to toil is an exposure route of concern, the depth at
vhich the soil samples were obtained should be provided. It
cannot be determined from the information provided whether a
particular contaminant was found in surface or near-surface soil.
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CAEPEKHR. BEKKTTT A MOBK1SSEY
Michael Burlingame
July 17, 1990
Page 11
Section 4;
It appears in some instances that if no information v
located for a given chemical detected at the Site, then
information for a surrogate vas used vithout providing the
rationale for the selection of the surrogate. For. instance, in
Tables 4-1, 4-2 and 4-3: The assumption that RfD's (reference
doses) and SF's (slope factors) for possibly similar chemicals
are similar to those chemicals for which no information is
available, is not justified. In fact, Table 4-3 presents RfD's
and SF's for trans-1,3-dichlorpropene, endosulfan sulfate and
endrin ketone vithout noting that the values are not available
for the listed checicals. Table 4-3 also lists as a chemical,
"vasadol". This chemical is unknown to Hercules; is it supposed
to be vanadium?
Zn addition, Appendix B is confusing and somewhat
misleading. Physical/chemical information, as veil as health
effects information, for all chemicals of potential concern is
supposed to be included in this section. Information on all
chemicals is not included, e.g., trans-1,3-dichloropropene (or
1,3-dichlorpropene), and information, including carcinogenic
affects for chemicals not of concern, e.g., benzene, is included
Only those chemicals of actual potential concern at the Site
should be included in the appendix*; otherwise, the reader is
aisled into assuming that a particular chemical is on the Site
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CARFZK7IB. BZKKETT 4 MORRJSSIY
Michael Burlingame
July 17, 1990
Page 12
when in fact it is not. Furthermore, lack of information on a
chemical actually detected at the Site (as opposed to its
surrogate) prevents the reader from determining the actual risks,
if any, posed by the chemical in question.
Page B-28 includes in the section for chloroethane
information that does not apply to chloroethane, but to "similar"
chericals. This information on similar chemicals is not needed
since there is sufficient information on chloroethane itself. On
page B-29, it is stated that acetone is in EPA carcinogen
category D; Table 4-2 indicated that acetone has not been
classified.
Page B-36 includes what is supposed to be health
effects information of polynuclear aromatic hydrocarbons (PAHs).
The discussion is actually on benzo(a)pyrene. Since individual
PAHs are used for the risk assessments and because EPA has
classified several PAHs, a summary of information for the
individual PAHs should be included in the discussion. If the
proposed cancer slope factors for oral and inhalation routes are
no longer recommended for use in quantifying cancer risk, they
should not have been used for calculations done in the document.
Tables B-6 through B-17 which present "physiochemical"
properties of various aetals and selected compounds Are
misleading. The characteristics of metal compounds which are not
listed as having been found on the site are included, e.g., Table
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CABPEXTIR. BENNTTT & MORRJSSEY
Michael Burlingame
July 17, 1990
Page 13
B-12 includes inorganic as veil as organic lead compounds. These
superfluous compounds should be excluded from the tables.
Hercules respectfully requests that it be granted an
additional 30-day comment period to review omitted information
discussed in this letter once it becomes available..
Very truly yours,
5ENTEK, BENNETS9* MORJUSSEY
JFL:296:el
cc: Sayreville Landfill 111 Site Committee
(via First Class Mail)
Fred C. Hart (via First Class Mail)
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NJDEP responses t6 SAYREVILLE LANDFILL III - Hercules, Inc.1*
comments on Baseline Risk Assessment Report, dated July 17, 1990,
by John F. Lynch, Jr. of Carpenter, Bennett t Morrissey
Page 2, Comment regarding the double reference to the Hercules
Parlin facility: The double reference has been changed to a
single reference. The discussion of the Hercules facility and
other facilities surrounding the site was merely intended to give
the reader an idea of the type of setting in which the site is
located and that background contamination levels may be
significant.
Page 3, Comment regarding the evaluation of the site for future
residential use: A qualitative, statement of the likelihood of
the future land use occurring has been included in the Risk :
Assessment. The assumption of future residential land use was
chosen because this use is most often associated with the
greatest exposures and is generally the most conservative choice.
Page 4, Comment concerning the depths at which soil samples were
taken: The depths at which samples were taken have been added to
Table 2-SB. Due to the limited number of surficial soil samples
collected, a conservative approach was taken and the analytical
results from soil samples at all depths in the wastefill were
assumed to pose an exposure risk at the surface.
Page 7, Comment concerning errors in Table 5-2: Table 5-2 has
been revised, as requested.
Page 8, Comment concerning Sec. 6: Various options are presented
to restore the site to various levels of usefulIness.
Conclusions regarding remediation are made in the FS report and
would not be appropriate here.
Page 8, Comment concerning Appendix A: The slope factor for 1,3-
dichloropropehe has recently be added to the January/April 1990,
EPA, Health Effects Assessment Summary Tables.
Page 9, Figure 1-6 has been added.
Page 9, Comment concerning Page 2-13: The text of Appendix B has
been modified to include only those chemicals for which
information is available and which were analyzed in the Risk
Assessment.
Pages 9-10, Typographical errors in the Tables in Sec. 2 have
been corrected.
Page 11, Comment concerning Sec. 4: Tables 4-1 thru 4-3 have
been corrected to reflect that there are no values for endosulfan
sulfate and endrin ketone. HEAST does not indicate whether the
SF for 1,3-dichloropropene is for the cis or trans isomer,
therefore, no special discussion of the SF for the trans isomer
was provided.
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Page 11, Comment on Appendix B: Superfluous chemicals have been
deleted from the' text. No changes will be made to data Tables B-
1 thru B-17. No information is available specifically on trans-
1,3-dichloropropene, therefore, none is included. 1,3-
dichloropropene was not detected at the site.
Page 12, Comment on chloroethane: The data on chloroethane in
Appendix B in the final Risk Assessment is based solely on that
compound.
Page 12, Comment on the classification of acetone: Acetone is
classified as category D, meaning it is unclassified.
Page 12, Comment on health effects of PAHs: Since information on
the toxicity of other individual PAHs is sparse, and it is EPA's
policy to use benzo(a)pyrene to characterize the risk of all
known and suspected carcinogenic PAHs, this discussion in the
Risk Assessment is entirely appropriate. Further, although IRIS
no longer recommends use of the proposed cancer slope factors for
oral and inhalation routes of benzo(a)pyrene, EPA's interim
policy in the absence of new numbers is to continue using the
benzo(a)pyrene slope factors to characterize PAH risk.
Page 12, Comment on Tables B-6 thru B-17: They are not meant to
imply that all of these chemicals were found at the site.
Page 13, Request for additional 30 days to review the Risk
Assessment once it has been revised to reflect these comments:
The public comment period concluded on Saturday, August 25, 1990,
and a substantial period of time has passed since the Risk
Assessment Report was finalized. The general conclusions
incorporated into the final Risk Assessment Report did not change
substantially from the draft version of the report. However, we
would be glad to informally answer any additional questions you
may have regarding the final Risk Assessment Report.
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