United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-90/127
September 1990
Superfund
Record of Decision:
Cinnaminson Groundwater
Contamination, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/127
3. Recipient's Accession No.
Title and Subtitle
SUPERFUND RECORD OF DECISION
Cinnaminson Groundwater Contamination, NJ
First Remedial Action
5. Report Date
09/28/90
7. Author(a)
8. Performing Organization Rept No.
8. Performing Organization Name and Address
10. ProiecVTask/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The 400-acre Cinnaminson Groundwater Contamination site is in the townships of
I Cinnaminson and Delran, Burlington County, New Jersey, and is comprised of a landfill,
I several industrial operations, and residential properties. The site overlies a deep and
•a shallow aquifer, and the latter is a potential source of drinking water. Furthermore,
^Khe site lies within the Delaware River floodplain. Land use in the vicinity of the
T site is residential, agricultural, and industrial. The onsite landfill was originally
used for sand and gravel mining operations. From 1950 to 1980, municipal solid waste
and other refuse were deposited in the mining pits, while mining operations continued in
other site areas. In 1970, Sanitary Landfill Inc. (SLI) operated an onsite sanitary
landfill in the same area, which accepted hazardous industrial waste. In 1980, the
State identified improper waste disposal practices onsite, and ordered SLI to close the
landfill. In 1981 as part of the closure plan, SLI capped the landfill with 18 inches
of clay, installed a gas collection and venting system, and initiated ground water
monitoring. Subsequent ground water studies by EPA and SLI identified onsite ground
water contamination in the landfill area. Additionally, various onsite industrial
operations and local area septic systems were also identified as potential sources of
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Cinnaminson Groundwater Contamination, NJ
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics (PAHs,
phenols), metals (arsenic, chromium,, lead)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
159
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/127
fcinnaminson Groundwater Contamination, NJ
"irst Remedial Action
Abstract (Continued)
ground water contamination. This Record of Decision (ROD) addresses remediation of
onsite contaminated ground water in the shallow and deep aquifers, and prevention of
further migration of contamination into municipal wells. The adequacy of the SLI
landfill closure will be addressed in a subsequent ROD. The primary contaminants of
concern affecting the ground water are VOCs including benzene, PCE, TCE, toluene, and
xylenes; other organics including PAHs and phenols; and metals including arsenic,
chromium, and lead.
The selected remedial action for this site includes pumping and treatment of ground
water from the shallow and deep aquifers using chemical precipitation and
biological/granular activated carbon; reinjecting the treated water onsite into the deep
aquifer; ground water monitoring; and implementing engineering and institutional
controls. The estimated present worth cost for this remedial action is $20,500,000,
which includes an annual O&M cost of $751,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water cleanup goals are based
on the more stringent of SDWA MCLs or State Standards including benzene 1 ug/1 (State),
xylenes 44 ug/1 (State), and arsenic 50 ug/1 (State) .
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
MRS Score (date)
NPL Rank:
Cinnaminson Ground Water
Contamination Site
Burlington County, New Jersey
USEPA Region II
37.93; April 1984
415
ROD
Date signed:
Remedy/ies:
Capital Cost:
0 & M/Year:
Present Worth:
09/28/90
Groundwater extraction and
treatment
$8,367,00
$751,000
$20,475,000
LEAD
Remedial/Enforcement:
Primary Contact (phone):
Secondary Contact (phone)
Remedial
Trevor Anderson, Project Manager,
USEPA, (212) 264-5391
Charles Tenerella, Chief SNJRAS,
USEPA, (212) 264-9382
WASTE
Type (metals,PCB, &c):
Medium (soil, g.w., &c):
Origin:
Est. Area of G.W. plume:
Volatile Organic Compounds and
metals
Groundwater
Landfills and underground storage
tanks
209 acres
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DECLARATION STATEMENT
RECORD 0? DECISION
CINNAMINSON GRODKD WATER CONTAMINATION SITE
Site
Cinnaminson Ground Water Contamination Site
Cinnaminson Township, Burlington County, New Jersey
Statement of Basis mnd Purpo_s«
This decision document presents the selected remedial action for
the cinnar.inson Ground water Contamination site, chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of I960,
as amended by the Superfund Amendments and Reauthorization Act cf
19S6 and, to the extent applicable, the National Oil and
Hazardous Substances Pollution Contingency Plan.
This decision document explains the factual and legal basis for
selecting the remedy for this site. The information supporting
this remedial action decision is contained in the administrative
record for the site.
Assessaent cf the Bite
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Becord of Decision, may present an imminent and
substantial endangerntent to public health, welfare, or the
environment.
pescription ef tha Remedy
The remedial action described in this document represents the
first of two planned operable units for the site. This operable
unit will address the remediation of contaminated ground water in
the aquifers underlying the site. Enhancement of the existing
cap on the landfill portion of the site will be the subject of a
future remedial action decision.
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The rajcr ccr.ponents cf the selected remedy for the first
operatic ur.it include the following:
Extraction and treatment (preferably by .nemical
precipitation and biological/granular activated carbon)
of contaminated ground water from both the shallow and
deep aquifers;
Reinjection of the treated water into the deep aquifer;
and
Installation and monitoring of additional wells to
ensure the effectiveness of the remedy.
Given the size of the landfill, large volumes of low-level-risk
wastes will rer.ain on the site above health-based levels. These
will continue to be addressed by engineering and institutional
controls already in place.
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 technologies to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment which reduces
tcxicity, mobility, and/or volume as a principal element.
Because this remedy will result in hazardous substances remaining
in the landfill above health-based levels, a review will be
conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
_onstantine Sidaraon-E«st?xf Date /
Regional Administrator / / '
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DECISION SUMMARY
RECORD OF DECISION
CINNAMINSON GROUND WATER CONTAMINATION SITE
SITE NAME. LOCATION. AND DESCRIPTION
The Cinnaminson Ground Water Contamination site ("the site")
covers approximately 400 acres in the Townships of Cinnaminson
and Delran in Burlington County, New Jersey. The site includes
properties bounded by Union Landing Road, Route 130, River Road,
and Taylors Lane (Figure 1). The Delaware River is located
approximately 5,000 feet northwest, and U.S. Route 130 passes
about 2,000 feet southeast of the site. The site consists of the
Sanitary Landfill Inc. (SLI), residential properties, and light
to heavy industrial properties. (Figures and tables are located
at the end of the document.)
A number of the industrial facilities in the study area have
petroleum underground storage tanks. Unlined slurry pits and
cooling ponds are located on one industrial property. There are
also a number of septic systems in the study area.
The total population of Cinnaminson Township is approximately
15,600. The nearest residential property is located
approximately 250 feet away from the SLI landfill. The nearest
school is located three-quarters of a mile south of the site.
The topography in the Cinnaminson area is very flat, as a result
of being within the boundaries of the Delaware River flood plain.
The natural land surface elevation varies from about 20 feet
above mean sea level (MSL) along River Road to about 80 feet
above KSL at Union Landing Road.
The Delaware River is the primary surface water body in the area.
Two small streams, Pompeston Creek and Swede Run, provide
immediate pathways for surface water runoff from the area into
the Delaware River.
The ground water resources in the Cinnaminson Study Area consist
of sedimentary deposits of the Potomac-Raritan-Magothy (PRM)
Formation. The study area lies within the unconfined outcrop
area of the PRM. Discontinuous clay layers within the PRM
Formation in part of the Cinnaminson area tend to create semi-
confining conditions in the deeper portion of the aquifer, while
the upper part (above the clay layers) acts as a water table
aouifer. The thickness of the PRM Formation varies from 20 feet
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to 200 feet in the Study Area. Ground water flows in a south-
southeasterly direction in this deeper aquifer.
Potable Water is provided by the New Jersey Water Company
Delaware Valley District. Seventeen wells tapping the PRK
Formation serve a population of 70,500. There are seven pumping
stations within a two-mile radius of the site.
Land use in the immediate area consists of residential
properties, farmland, small to large industrial properties, and
undeveloped rural lots. Since the spring of 1985, roost of the
area to the east and north of the site has been significantly
developed by light industry.
SITE HISTORY AKD ENFORCEMENT ACTIVITIES
SLI Landfill
The landfill portion of the site was originally owned by Lockhart
Construction Company and was used for sand and gravel mining
pits. The depth of mining excavations ranged between 20 feet
be lev original ground water levels in some parts of the pits and
60 to 70 feet in other areas. During the late 1950s, municipal
solid wastes were deposited in the completed mining pits while
sand and gravel mining operations continued in other parts of the
property. The mining operations were terminated in the late
1960s. After the mines were closed, large amounts of refuse and
solid waste were deposited in the pits.
In 1STO, Sanitary Landfill Inc., a subsidiary of Waste Management
Incorporated, purchased the landfill property and obtained a
perr.it from the New Jersey Department of Environmental Protection
(NJDEP) to operate the site as a sanitary landfill. Municipal
and institutional wastes, bulky wastes, vegetable and food
processing wastes, and industrial wastes, including hazardous
substances, were deposited in two areas. The landfilling
operation ceased in I960.
Industrial Operations
L & L Kedi Mix, Del Val Ink & Color, and Hoeganaes Corporation
are three major industrial facilities that are adjacent to the
landfill.
L 4 L Fedi Mix is a cement manufacturing facility located
southeast of the SLI property. Two underground bulk storage
tanks containing 3,000 gallons of diesel fuel and 2,000 gallons
of gasoline, respectively, are present on L & L Redi Mix
property.
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to 200 feet in the Study Area.
southeasterly direction in this
Sround water flows in a south-
deeper aquifer.
Potable Water is provided by the New Jersey Water Company
Delaware Valley District. Seventeen wells tapping the PRK
Formation serve a population of(70,500. There are seven pumping
stations within a two-mile radius of the site.
Land use in the immediate area
properties, farmland, small to
undeveloped rural lots. Since
area to the east and north of
developed by light indus-try.
:onsists of residential
arge industrial properties, and
:he spring of 1985, most of the
site has been significantly
tie
SITE HISTORY AND ENFORCEMENT ACTIVITIES
SIX Landfill
The landfill portion of the sit
Construction Ccr.pany and was us
pits. The depth of mining exec
below original ground water le\
60. to 70 feet in other areas.
solid wastes were deposited in
sand and gravel mining operations
property. The mining operatioi
1960s. After the mines were c!
solid waste were deposited in
In 1970, Sanitary Landfill Inc
Incorporated, purchased the
perr.it frcrr. the New Jersey Dep<
(NJDEP) to operate the site as
and institutional wastes, bulk}
processing wastes, and industr:
substances, were deposited in
operation ceased in 1980.
Industrial Operations
L & L Redi Mix,
are three major
landfill.
Del Val Ink &
industrial faci
L & L Redi Mix is a cement mani.
southeast of the SLI property.
tanks containing 3,000 gallons
of gasoline, respectively, are
property.
e was originally owned by Lockhart
ed for sand and gravel mining
-rations ranged between 20 feet
els in some parts of the pits and
During the late 1950s, municipal
the completed mining pits while
continued in other parts of the
s were terminated in the late
osed, large amounts of refuse and
pits.
Vhe
a subsidiary of Waste Management
landfill property and obtained a
rtment of Environmental Protectic:
sanitary landfill. Municipal
wastes, vegetable and food
al wastes, including hazardous
ttwo areas. The landfilling
qolor, and Hoeganaes Corporation
lities that are adjacent to the
facturing facility located
Two underground bulk storage
of diesel fuel and 2,000 gallons
present on L & L Redi Mix
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Del Val Ink & Color produces specialty printing inks. The
company has stored a number of hazardous chemicals and petroleum
products in underground storage tanks on its property.
Hoeganaes Corporation produces specialty iron powders. There are
two unlined slurry pits and a cooling pond within the Hoeganaes
property. The slurry pits are used to store a wet coke-lime
mixture which is reclaimed after drying. Some empty drums with
traces of solvent have been found on the property.
Enforcement Activities
During the 1970s, SLI was cited on several occasions by the NJDEP
for violations of state 'landfill regulations for its waste
disposal practices at the site. On September 27, 1980, NJDEP
issued an Administrative Order to SLI to close the landfill. In
1961, Waste Management Inc., acting on the behalf of SLI,
submitted a closure plan for the Sanitary Landfill to NJDEP for
approval. The plan was approved by NJDEP in 1981. As part of
the closure plan, the two landfill areas were capped with 18
inches of clay. The closure plan also provided for the
installation of a landfill gas collection and venting system, and
the initiation of a ground water monitoring program.
In June 1S64, the U.S. Environmental Protection Agency (EPA)
placed the Cinnaminson Ground Water Contamination site on the
National Priorities List (NPL) of Superfund sites. Verification
of ground water contamination was based upon the results of
quarterly ground water monitoring performed by SLI, as required
by the closure plan. Hydrogeological studies and annual reports
on ground water quality, conducted by Geraghty & Miller Inc. (G&X
1982, 1S54, and 1985) for SLI, confirmed the presence of ground
water contamination in the area of the landfills.
EPA initiated a Remedial Investigation (RI) in April 1985, to
determine the sources, nature and extent of contamination. The
RI report was completed by an EPA consultant, Camp Dresser &
McKee Inc. (COM), in May 1989.
The report concluded that the SLI landfill was the major source
of ground water contamination. Del Val Ink & Color, and L i L
Redi Mix were identified as additional potential contributing
sources; they both have petroleum underground storage tanks. The
Hoeganaes Corporation used unlined slurry pits and cooling ponds
which were also identified as potential sources of contamination.
In addition, local area septic systems were also cited as a
contaminant source.
A total of 28 General Notice Letters have been issued to
Potentially Responsible Parties (PRPs) to date.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
On April 14, 1986, EPA held a public meeting at the Cinnair.insor.
Township Municipal Building to discuss the initiation of the
remedial investigation and feasibility study (RI/FS).
On May 15, 1990, EPA released the RI/FS Report and the Proposed
Plan for the site to the public for comment. These documents
were made available to the public in the Administrative Record
repositories maintained .at the EPA Region II office located at 26
Federal Plaza, Rooir, 710, New York, New York 10278, and also at
the following locations:
Cinnar.inson Township Municipal Building
1621 Riverton Road
Cinnamir.son Township, NJ 08077
Cinnar.inson Public Library
1605 Jar.es Street
Cinnaminson Township, NJ 08077
East Riverton Civic Center Association
2905 Janes Street
Cinnar.inson Township, NJ 08077
A notice of the availability of the RI/FS Report and the Proposed
Plan was published in the Burlington County Times on May 24 and
29, 1950, respectively. A public comment period on the RI/FS
Report and the Proposed Plan was held from May 16 to July 31,
1550. A public meeting was held on May 31, 1990 in Cinnaminson
Township. At this meeting, representatives from EPA and EPA's
contractor, ICF Technology, presented, discussed, and answered
questions regarding the site and the remedial alternatives under
consideration. A public availability session was held on June 1,
1950, and a second availability session was held on July 25,
1950, to accept additional comments from the community. All
responses to the comments received during the public comment
period are included in the Responsiveness Summary, which is
included as part of this Record of Decision (ROD). This decision
document presents the selected remedial action for the
Cinnaminson Ground Water Contamination site, as amended by the
Superfund Amendments and Reauthorization Act (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). The decision for this site is
based on the administrative record.
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SCOPE AKD ROLE OF THE FIRST OPERABLE UNIT
The environmental problems and hydrogeology at the Cinnaminson
site are cor.plex. As a result, EPA has decided to address the
remediation of the site in two operable units.
Operable Unit One - The first operable unit will address the
remediation of the contaminated ground water.
The contaminated ground water has migrated from the perched
zones to the regional aquifer. The regional aquifer is a
source of drinking water in New Jersey. There are municipal
wells located about two miles south of the site, which need
to be protected from contamination. The purpose of this
response is to prevent the further migration of the
contaminated ground water towards the municipal wells.
Operable Unit Two - The second operable unit will address
the adequacy of the current closure of the SLI landfill.
The clay cap installed in 1985 by SLI is restricting rain
water from infiltrating into the wastes, thus reducing the
amount of leachate entering the ground water. However,
additional information and data are needed to determine the
long-ten:, effectiveness of the existing cap. As a result,
the second operable unit will not be addressed in this ROD,
but will be the subject of a subsequent ROD.
Other facilities which are not under Superfund jurisdiction
have been identified in the RI Report as potential sources
cf ground water contamination and will be addressed under
the regulatory authority of the NJDEP.
SUMMARY OF SITE CHARACTERISTICS
The RI field activities were conducted between April 1985 and Kay
1958, to determine the sources of ground water contamination;
obtain a better understanding of the hydrogeology of the site;
and identify the types, quantities, and locations of the
contaminants.
The RI activities included field surveys, hydrogeologic
investigations, ground water sampling, surface water/sediment
sampling, and potable well sampling. Details of the RI
activities are contained in the RI/FS reports.
the reports concluded that the SLI landfill was the major source
of ground water contamination. Del Val Ink & Color, L & L Redi
Mix were identified as additional potential contributing sources;
they have petroleum underground storage tanks. The Hoeganaes
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Corporation used unlined slurry pits and cooling ponds which were
also identified as potential sources of contamination. In
addition, local area septic systems were cited as a contaminant
source.
Ground Water
The regional aquifer - the Potomac, Raritan, Magothy (PRM)
Aquifer - is classified as GW-2, a source of drinking water, by
the State of New Jersey.
There are 87 monitoring wells in the study area. Twelve wells
were installed by EPA to investigate the ground water conditions
near active surface impoundments on the property of the Hoeganaes
Corporation. SLI installed 26 wells on the landfill property to
monitor leachate. During the RI, EPA installed an additional 49
monitoring wells to characterize the ground water contamination
throughout the study area.
The RI identified the presence of volatile organic and inorganic
compounds in the two aquifers, using data gathered from the 87
monitoring wells. Contaminants that were found included vinyl
chloride, 1,2-dichloroethane, trichloroethane, and benzene.
These monitoring wells also showed levels of chlorides and total
dissolved solids which are typically associated with leachate
generated from sanitary landfills. The levels of both organic
and inorganic contamination detected in the PRM aquifer (the
regional aquifer) and in perched water zones (the shallow
aquifer) were found to be above State and Federal Maximum
Contaminant Levels (MCLs) and the New Jersey Ground water
Criteria (see Tables 1 and 2).
The regional aquifer flows in a south-southeasterly direction..
The perched water zones flow downward into the regional aquifer.
The contamination appeared to be limited to an area within close
proximity to the SLI landfill and was not present south of U.S.
Route 130. The extent of ground water contamination is
represented in Figure 2.
Surface Water and Sediments
Both surface water and sediment samples were taken at three
retention basins within the SLI property; and at a Hoeganaes
impoundment area, Hunter's Farm Pond, Swede Run and Pompeston
Creek.
Surface water results indicate no organic contamination.
Chromium was detected in the surface water at the Hoeganaes
impoundment, a disposal area for process wastes, in
concentrations ranging from 57 to 137 micrograms per Liter
(ug/L).
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Chemicals detected in the sediments were found in concentrations
which did net exceed the NJDEP soil action levels.
Potable Wells
Twelve private wells, located upgradient of the s. te, were
sampled to establish background conditions related to this site.
The results showed that 12 metals, nitrate, and one organic
compound were detected. However, only nickel and nitrate
exceeded Federal and State drinking water quality standards. The
maximum concentrations of nickel and nitrate were 27 ug/L and 12
milligrams per liter (mg/L), respectively, found in one well.
These concentrations are higher than the MCLs, allowed under New
Jersey Statute, for nickel and nitrate in drinking water, which
are 15.4 (ug/L) and 10.0 (ug/L), respectively. The resident
whose well exceeded the MCLs for nickel and nitrate is now
receiving drinking water from the New Jersey American Water
Company (NJAWC).
However, based on the locations of these wells, relative to the
site and to the direction of ground water flow, these wells are
not affected by the study area ground water contaminant plume.
SUMMARY OF SITE RISKS
EPA conducted an Endangerment Assessment (EA) of the "no action"
alternative to evaluate the potential risks to human health and
the environment associated with the Cinnaminson site 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 (chemicals of concern). These "chemicals of concern"
and their indices of toxicity are shown in Tables 3 and 4.
The EA prepared for the site concluded that contaminated ground
water is the exposure medium of greatest concern. Human exposure
to contamination through other media, including soil and surface
water, was determined not to be significant, and is not presented
here.
EPA's EA identified several potential exposure pathways by which
the public may be exposed to contaminant releases from the
Cinnaminson site. These pathways and the populations potentially
affected include:
Potential ingestion of ground water from the perched water
table and the regional aquifer by residents in the area.
Potential exposure of workers in nearby industrial
facilities to chemicals through inhalation of volatile
organic compounds (VOCs) from the site.
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8
Potential exposure of nearby residents to chemicals through
inhalation of VOCs from the site.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and noncarcinogenic effects due to exposure to
site cher.icals are considered separately. It was assumed that
the toxic effects of the site related chemicals would be
additive. Thus, carcinogenic and noncarcinogenic risks
associated with exposures to individual indicator compounds were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and noncarcinogens, respectively.
Noncarcinogenic 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
fcr adverse health effects. RfDs, which are expressed in units
cf 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 hazard
index is obtained by adding the hazard quotients for all
cor.pcunds acrcss all media. A hazard index greater than 1
indicates that potential exists for noncarcinogenic health
effects tc 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 single
medium or across media.
Potential carcinogenic risks were evaluated using the cancer
potency factors (CPFs) developed by the EPA for the indicator
compounds. CPFs have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
cher.icals. CPFs, 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 CPF. Use
of this approach makes the underestimation of the risk highly
unlikely.
For known or suspected carcinogens, the EPA considers excess
upper bound individual lifetime cancer risks of between 1 X 10"
to 1 X 10'' 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.
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Hur.an Health Risks
Potential Inaestion of Ground Water from the Perched Water Table
and the Regional Aquifer
The risk frcr. ingestion of ground water from the perched water
zones and the regional aquifer by local residents was
quantitatively evaluated. It is unlikely that such exposures
would occur directly from the perched water zones, since the
perched water zones are not presently used as a drinking water
source. However, water from the perched water zones flows
downward into the regional aquifer, which is used as a drinking
water source. Therefore, local municipal drinking water wells
are potentially at risk from the migration of contamination in
the perched water table.
The potential excess lifetime cancer risks associated with
ingestion of ground water from the perched water zones and the
regional aquifer are 1 x 103 and 6 x 103 (one in one thousand and
six in one thousand) respectively, for the plausible maximum
cases. Vinyl chloride accounted for most of the estimated
carcinogenic risk for ingestion of ground water from the perched
water zones. Arsenic and vinyl chloride accounted for most of
the estimated carcinogenic risks for ingestion of ground water
fror. the regional aquifer. The Hazard Indices associated with
ingestion of ground water fror, the perched water zones and the
regional aquifer are 2 and 20 respectively, for the plausible
maxir.ur. cases. Table 5 and. Table 6 present the carcinogenic
risks and Hazard Indices associated with the ingestion of ground
water fror. the perched water zones and the regional aquifer,
respectively.
While the perched water zones are not used for drinking water
purposes, the real risks associated with the perched zones are a
result of contamination flowing from the perched zones to the
regional aquifer, which is used as a drinking water source.
Inhalation of VOCs by Nearby Workers
The risks related to exposure of workers in nearby facilities to
chemical releases from the SLI Landfills were quantitatively
evaluated". For this exposure pathway, the excess lifetime cancer
risk is well below 10"6, and the HI is well below one, indicating
carcinogenic and noncarcinogenic health effects are not likely to
occur. Table 7 presents the risks associated with the inhalation
of VOCs by nearby workers.
Inhalation of VOCs bv Nearby Residents
The risks related to exposure of nearby residents to chemical
releases from the site were evaluated. The results of this
assessr.ent revealed that no adverse health effects are likely to
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10
occur as a result of exposure to airborne contaminants. For this
exposure pathway, the excess lifetime cancer risk is veil below
10", and the HI is well below one, indicating carcinogenic and
noncarcinogenic health effects are not likely to occur. Table 8
presents the risks associated with the inhalation of VOCs by
residents.
Environmental Risks
Potential impacts associated with the contaminants of potential
concern were also assessed for nonhuman exposures at the
Cinnar.inson site. There are no endangered species or critical
habitats located in the .study area. It was determined that
environmental risks were not significant at the Cinnaminson site.
Uncertainties in the EA
As in any risk assessment, the estimates of risk for the
Cinnarinscn site have many uncertainties. In general, the
primary sources of uncertainty identified included the following:
Environmental chemistry sampling and analysis
Environmental parameter measurement
Fate and transport modelling
Exposure parameter estimation
Toxicological data
As a result of the uncertainties, the risk assessment should not
be construed as presenting an absolute estimate of risks to human
or environmental populations. Rather, it is a conservative
analysis intended to indicate the potential for adverse impacts
to occur.
Conclusion
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, and the environment.
DESCRIPTION OF ALTERNATIVES
Appropriate remedial technologies identified during the screening
process were assembled into combinations to address the remedial
action objectives for the site, namely:
- To satisfy applicable or relevant and appropriate
local, State, and Federal requirements (AJRARs) ;
- to reduce continued degradation of the ground water;
and
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to prevent contaminants from migrating toward existing
municipal drinking water wells.
The FS identified two types of actions that would address the
ground water problems: Source Control (SC) Alternatives aimed at
stopping the further leaching of contaminants into the ground
water from the landfills? and Ground Water Management of
Migration (MM) Alternatives which would address the contamination
already in the ground water.
In preparing the FS, several remedial technologies that could
meet ground water cleanup objectives were identified and reviewed
for effectiveness, implementability, and cost. Those
alternatives which passed the initial screening are highlighted
in this section. Descriptions of all of the remedial
alternatives evaluated for the Cinnaminson Ground Water
Contamination site are provided in the FS Report.
The alternatives evaluated included the following:
Source Control Alternatives
Alternative SC-1: No Further Action
Alternative SC-2: Monitoring and Administrative Controls
Alternative SC-3: RCRA Capping
As mentioned previously, the landfill was capped with 18 inches
of clay in 1SS5. Currently, the cap is effectively acting as a
barrier to the infiltration of rain water into the landfill,
which reduces the further migration of the contaminated ground
water plur.e. Maintenance of the existing cap and the
implementation of a Ground Water Management of Migration
alternative will provide additional information on the long-term
effectiveness of the cap. At that time, any added benefits of
installing a full RCRA (Resource Conservation and Recovery Act)
cap can be evaluated. Therefore, Alternatives SC-1, SC-2, and
SC-3 will not be discussed in this document, but will be
considered in a separate operable unit Record of Decision after
the selected management of migration (ground water control)
system is in place and operating.
Ground Water (Management of Migration) Alternatives
Alternative KM-i: No Further Action
Alternative KM-2: Monitoring and Administrative Controls
Alternative KM-3: Treatment of Ground Water from the Shallow
Aquifer (Perched Zone)
Alternative KM-4: Treatment of Ground Water from the Deep
Aquifer (Regional Aquifer)
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Alternative KM-5: Treatment of Ground Water from Both the
Shallow and Deep Aquifers
Alternatives MM-3, MM-4, and MM-5 each include three separate
ground water treatment options. These are:
Option A: Chemical precipitation with air stripping
Option B: Cher.ical precipitation with ultra-violet oxidation
Option C: Cher.ical precipitation with biological granular
activated carbon
(MM-1): No Further Action
Estimated Capital Cost: $0
Estimated Operation
and Maintenance (O&M) Cost: $15,000
Estimated Present Worth: $41,600
Implementation Period: None
The National Oil and Hazardous Substance Pollution Contingency
Plan (NCP) and the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) require the evaluation of
a No Action alternative as a basis for comparison with other
remedial alternatives. This No Further Action alternative
includes only those actions required by the existing SLI Landfill
closure plan, which includes: ground water monitoring within the
plur.e boundaries, maintenance of site fencing and the landfill
cap, and controlling access to the site. Because this
alternative does not entail contaminant removal, CERCLA requires
that a review of site conditions be conducted every five years,
which is the estimated O&M costs.
(KM-2): Monitoring and Administrative Controls
Estimated Capital Cost: $369,000
Estimated Annual OiM Cost: $84,000
Estimated Present Worth: $1,702,000
Implementation Period: 6 Months
The Monitoring and Administrative Controls alternative does not
include active treatment technologies, but presents passive
measures to reduce the probability of human contact with the
contaminated media. Monitoring controls consist of implementing
a long-term monitoring program beyond the plume boundaries and
continuing those actions which are required by the existing SLI
landfill closure plan, including; monitoring the ground water
within the site boundaries, maintaining site facilities (fences,
cap, etc.), and controlling access to the site. Administrative
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controls involve the State or local governments placing general
warnings on new well installation permits to warn of the .
potential health risks associated with using the ground water for
potatle purposes.
Because the Monitoring and Administrative Control alternative
results in the contamination remaining on site, CERCLA requires
that a review of site conditions be conducted every five years.
(XM-3): Treatment of Ground Water From the Shallow Aquifer or
Perched Zones
Alternative MM-3 includes the components of Alternative MM-2
along with a ground water extraction and treatment system for the
shallow aquifer. The conceptual model suggests that 130
extraction wells would be required in the shallow aquifer
(perched zones) to capture the contaminated water. The actual
nur.ber and location of these extraction wells will be determined
during the design of the project. Each extraction well would
extract contaminated water at a rate of approximately 1.7 gallons
per minute (gpm). The extraction wells would be installed to an
average depth of 35 feet. Following on-site treatment, the
effluent would be discharged into the regional aquifer by two
injection wells, which would be located downgradient of the
contaminated plume. Locating the injection wells downgradient of
the plume is expected to create a hydraulic barrier between clear.
and contaminated ground water. The hydraulic barrier would
reduce further migration of the contaminated plume toward the
municipal wells. The injection wells would be installed to an
average depth of 180 feet. Each injection well would inject the
treated water at"an approximate rate of 140 gpm. It is estimated
that the remediation would have to be carried out for
approximately five years. The approximate location of the
extraction wells and the treatment plant are shown in Figure 3.
Since the regional aquifer is a potential source of drinking
water in the area, it is classified by EPA as Class II B, and by
NJDZP as GK-2. Therefore, the shallow aquifer, which percolates
into the regional aquifer, would be treated to meet drinking
water standards. The treatment of the extracted ground water can
be accomplished by different treatment technologies. Three
treatment options for Alternative MM-3 are presented:
Option A: Chemical precipitation/air stripping treatment
Estimated Total Capital Cost: $4,739,000
Estimated Annual OS.M Cost: $506,000
Estimated Present Worth: $6,941,000
Implementation Period: 5 years
In Option A, following ground water extraction, the water would
be pumped to a centrally located treatment plant. Treatment
would consist of chemical precipitation to remove inorganic
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contaminants, followed by air stripping to remove the volatile
organic compounds. Bench-scale treatability studies during
remedial design would determine unit sizes and demonstrate
performance.
Option B: Cherical precipitation/UV oxidation treatment
Estimated Total Capital Cost: $5,192,000
Estimated Annual O&M Cost: $617,000
Estimated Present Worth: $15,083,000
Implementation Period: 5 years
In Option B, following extraction, the contaminated water would
be treated on site in an ultraviolet (UV) oxidation unit to
destroy the organic contaminants. In this treatment system,
after chemical precipitation, ground water would be mixed with ar.
oxidant (such as ozone or hydrogen peroxide) and then exposed to
UV light. The organic components oxidize to the point where the
by-products of the reaction are carbon dioxide, water, and non-
hazardous salts. The non-hazardous salts would be transported to
a licensed facility for disposal. All other components of this
alternative are identical to those described for Option A.
Bench-scale treatability studies during the remedial design would
determine unit sizes and demonstrate performance.
Option C; Chemical precipitation/biological granular activated
carbon treatment
Estimated Total Capital Cost: $8,093,000
Estimated Annual O&M Cost: $649,000
Estimated Present Worth: $18,633,000
Implementation Period: 5 years
Option C uses biological granular activated carbon treatment to
extract the organics. In this treatment method, contaminated
ground water would be pumped to an aeration basin after chemical
precipitation. In the aerated basin, the contaminated water
would be mixed with granular activated carbon and biological
solids. Following oxidation of the organic contaminants, the
mixture would be settled in a clarifier, with the overflow
becoming the treated effluent. Excess biological solids and
spent carbon would be collected and handled as a regulated
material. The excess biological solids/spent carbon mixture
would be dewatered and transported to a recovery facility for
regeneration. The water collected during the dewatering process
would be processed in the treatment plant. Bench-scale
treatability studies during design would determine unit sizes and
demonstrate performance.
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(MM-4): Treatment of Ground Water from the Deep Aquifer
Alternative MX-4 includes the components of Alternative MM-2
along with a ground water extraction and treatment system for the
deep aquifer. An estimated seven extraction wells would be
installed in the contaminated plume to remove the contaminated
ground water. Each well would extract the contaminated water at
an estimated rate of 80 gpm. The extraction wells would be
installed to an average depth of 240 feet. The extracted ground
water would be treated by one of the three options presented in
MM-3. Four injection wells would be used to reinject the treated
water into the regional aquifer. The injection wells would be
located downgradient of the contaminated plume and installed to
an average depth of 180 'feet. Each injection well would reinject
the treated water at a rate of about 140 gpm. The approximate
location of the extraction wells and the treatment plant are
shown in Figure 4. It is estimated that the remediation would
have to be carried out for approximately 30 years. Since the
regional aquifer is a potential source of drinking water in the
area, it is classified by EPA as Class II B, and by NJDEP as
GW-2. Therefore, the regional aquifer would be treated to meet
drinking water standards.
KM-4 with Octicr. A
Estimated Total Capital Cost: $5,192,000
Estimated Annual O&M Cost: $617,000
Estimated Present Worth: $15,083,000
Implementation Period: 30 years
MM-4 with Optien B
Estimated Total Capital Cost: $6,069,000
Estimated Annual O&tt Cost: $1,002,000
Estimated Present Worth: $21,879,000
Implementation Period: 30 years
MM-4 with Option C
Estimated Total Capital Cost: $5,628,000
Estimated Annual O&M Cost: $700,000
Estimated Present Worth: $16,796,000
Implementation Period: 30 years
The treatment components of Alternative KM-4 are identical to
those for Alternative MM-3 and its subset of Options A, B, and C.
(MM-5): Treatment of Ground Water from both the Shallow and Deep
Aquifers
Alternative MM-5 includes the components of Alternative MM-2
along with a ground water extraction and treatment system. This
alternative combines the extraction systems from both MM-3 and
MX-4 to withdraw contaminated water from both the shallow and
deep aquifers. This would include the installation of an
estimated 130 extraction wells in the perched zones and the
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installation of seven extraction wells in the regional aquifer.
The total rate of extraction from both aquifers would be 781
gallons per minute (gpm). The perched and regional aquifer
extraction wells would be installed to depths of 35 and 240 feet,
respectively. The contaminated ground water would be treated by
one of the three options presented in MM-3. After treatment, six
injection wells would be used to reinject the treated water into
the regional aquifer downgradient of the contaminated plume. The
injection wells would be installed to an approximate depth of 180
feet. Each injection well would be designed to reinject the
treated water into the regional aquifer at an estimated rate of
140 gpm.
The location of the extraction wells and the treatment plant are
shown in Figure 5. It is estimated that the remediation would
have to be carried out for approximately 30 years. Since the
regional aquifer is a potential source of drinking water in the
area, it is classified by EPA as Class II B, and by NJDEP as
GW-2. Therefore, the two aquifers would be treated to meet
drinking water standards.
MM-5 with Option A
Estimated Total Capital Cost: $8,093,000
Estimated Annual O&M Cost: $694,000
Estimated Present Worth: §18,633,000
Implementation Period: 30 years
yx-5 with Option B
Estimated Total Capital Cost: $9,122,000
Estimated Annual O&M Cost: $1,114,000
Estimated Present Worth: $26,810,000
Implementation Period: 30 years
MX-5 with Oction C
Estimated Total Capital Cost: $8,367,000
Estimated Annual O&M Cost: $751,000
Estimated Present Worth: $20,475,000
Implementation Period: 30 years
The treatment components of Alternative MM-5 are identical to
those for Alternative MM-3, and its subset of Options A, B, and
C.
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SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative is conducted with respect to each of the nine
evaluation criteria. All selected remedies must at least attain
the Threshold Criteria. The selected remedy should provide the
best trade-offs among the Primary Balancing Criteria. The
Modifying Criteria were evaluated following the public comment
period.
Threshold Criteria
• Overall protection cf human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
• Compliance vith ARARs addresses whether or not a remedy
will meet all of the applicable or relevant and appropriate
requirements (ARARs) of Federal and State environmental
statutes and/or provides a basis for a waiver.
Primary Balancing Criteria
Long-tern effectiveness refers to the ability of a remedy
tc maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
Reduction of toxieity. nobility or volume addresses the
performance of the remedy in terms of reducing the toxieity,
mobility, or volume of the contaminants of concern in the
environment.
Short-tern effectiveness addresses the period of time
needed to achieve protection, and any adverse impacts on
human health that may be posed during the construction and
implementation period until cleanup goals are achieved.
Implementability refers to the technical and
administrative feasibility of implementing a remedy,
including the availability of materials and services
required to implement a particular option.
Cost includes estimated capital, and operation and
maintenance costs of the remedy, and the net present worth
costs of the alternatives.
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Modifying Criteria
State Acceptance indicates whether, based on its review
of the RI/FS and Proposed Plan, the State concurs with,
opposes, or has no comment on the preferred --:ternative at
the present time.
Community Acceptance evaluates the reaction of the
public to the remedial alternatives and the Proposed Plan.
Corjiients received during the public comment period, and
EFA's responses to those comments, are summarized in the
Responsiveness Summary attached to this document.
AKALYSIS
This section discusses and compares the performance of the
rer.edial alternatives under consideration against the nine
criteria.
Overall Protection
All cf the action alternatives provide some degree of protection.
Alternative KM-2 prevents exposure to ground water contaminants
by ir.plerenting administrative controls. Alternatives MM-3, MX-
4, and KM-5 would provide a greater degree of protection by
extracting and treating contaminated ground water and reinjecting
it, with the goal of cleaning the aquifer to drinking water
standards. Alternative MM-3 provides ground water treatment of
the shallow aquifer only; contaminants in the regional aquifer
would be reduced by natural attenuation and biodegradation.
Alternative MM-4 provides ground water treatment of the regional
aquifer, which is a source of drinking water in the area. Under
Alternative MM-4, contaminants in the shallow aquifer, which
eventually percolate into the regional aquifer, would be captured
and treated by the extraction and treatment system for the
regional aquifer. This alternative is therefore more protective
than Alternative MM-3. Alternative MM-5 provides direct
treatment of both aquifers. Treating both aquifers would provide
the greatest overall protection of public health and the
environment.
Compliance with ARARs
Cherical-specific ARARs
The cleanup objectives for the ground water and the reinjected
treated water are provided in Tabl* 9. These levels represent
the concentrations which must be attained in both the treated
water before reinjection and in the ground water at the end of
the remedial action. They are based on State and Federal
standards for drinking and ground water. Alternatives MM-1 and
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KM-2 do not address the remediation of contaminated ground water,
and therefore do not comply with contaminant-specific ARARs.
Alternative KM-3, which treats ground water in the shallow
aquifer, would not meet ARARs for the contaminated water in the
regional aquifer. Alternative MM-4 would meet ARARs for only the
regional .aquifer. Since Alternatives MM-1 and K?.-2 would not
meet the ARARs for ground water, they will not be considered
further in this analysis as options.
Alternative KM-5 would meet ARARs for both the shallow and
regional aquifers.
All of the treatment technology options (A, B, or C) treat the
ground water to attain ARARs, with the possible exception of some
ser.i-volatiles under Option A.
Locatior.-specific ARARs
Alternatives KM-3, MM-4, and MM-5 would comply with State and
Federal regulations governing the construction of facilities in a
floodplain.
Activity-specific ARARs
Alternatives KM-3, MK-4, and KM-5 would comply with State and
Federal regulations governing the construction and operation of
the extraction, treatment and reinjection systems, and the off-
site disposal of hazardous sludges produced by any of the
treatment syster. options.
A list of ARARs for the clean-up is presented in Tabl« 10.
Long-term Effectiveness and Permanence
Alternatives KM-3. and KM-2 do not include active treatment of
ground water and therefore would not be effective or permanent.
Furthermore, these alternatives do not prevent the contaminant
plume from migrating toward municipal drinking water wells in the
area.
Alternatives KM-3, MM-4, and MM-5 include the extraction,
treatment, and reinjection of the contaminated ground water, and
would be both effective and permanent, over time. Furthermore,
these alternatives are designed to prevent the contaminant plume
from migrating towards municipal drinking water wells in the
area.
Reduction of Toxicity, Mobility, or Volua* of Contaminants
Alternatives KM-3, MM-4, and MM-5 treat extracted ground water
and reinject it in specific locations to reduce the toxicity,
mobility, and volume of contaminants. Alternatives MM-3 and MM-
4 would reduce the toxicity, mobility, and volume of contaminated
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ground water in the shallow and regional aquifers, respectively.
Alternative KM-5 involves extraction and treatment of ground
water fron both aquifers. This would reduce the toxicity,
mobility and volume of contaminants in both aquifers.
Short-tern Effectiveness
Alternative KM-2 does not include active treatment of ground
water, and therefore, would not be as effective. Unlike the
treatment based alternatives, this alternative does not prevent
the contaminant plume from migrating toward municipal drinking
water wells in the area.- Alternative KM-3 would be effective in
decreasing the contaminants in the shallow aquifer only; the
regional aquifer would remain contaminated. Alternative KM-4
would be effective in decreasing the contaminants in the regional
drinking water aquifer. However, since the shallow aquifer would
not be directly addressed, recontamination of the regional
aquifer, due to the downward percolation of contaminated ground
water fron the shallow aquifer, is likely to occur for a long
period of time. Alternative KM-5 would be most effective in
directly addressing contamination throughout both aquifers during
the remediation, by extracting and treating the ground water fror,
both the shallow and regional aquifers.
Treatment of the ground water (under option A, B, or C) would
produce a hazardous sludge which must be disposed of properly for
the duration of remediation.
Short-term risks to workers may occur during the installation of
the extraction and the reinjection wells in Alternatives KM-3,
KM-4 and KK-5. The pumping and piping system would be installed
below ground and would involve excavation. Risks to workers and
the nearby community from airborne contaminants would be
minimized during the implementation of each of these alternatives
through the use of appropriate engineering controls, and
comprehensive health and safety planning. New Jersey American
Water Company (NJAWC) drinking water wells are located within a
two-mile radius of the site. The initial start-up of the pumping
system could influence the amount of ground water being extracted
from these wells. The NJAWC would be consulted during the
remedial-design and remedial action, to minimize any effects that
the pumping and reinjection system would have on these wells. It
is expected that Alternative KM-3 could be started within 12
months. Alternative KM-4 could be started within 18 months; and
Alternative KM-5 in 24 months.
Implementability
Alternatives KM-3, KM-4, and KM-5 utilize extraction wells and
pumping systems that are proven and widely used technologies.
The hydrogeological characteristics of the regional aquifer allow
for easy, continuous removal of contaminated water. Alternatives
KM-3 and KM-5, which involve extraction of ground water from the
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shallow aquifer (perched zones), may be more difficult to
implement. The hydrogeological characteristics of the perched
zones do not allow a large volume of water to be extracted from a
single well. The conceptual model for the extraction system for
the shallow zone consists of an estimated 130 wells. Due to the
large number of wells, and the amount of connecting piping
required to be installed in commercial and residential areas,
problems with implementation could occur. Therefore, cleanup of
the shallow ground water may be limited to extracting and
treating the highly contaminated areas or "hot spots".
Three treatment technology options are presented for
consideration. Option A involves chemical precipitation and air
stripping, a proven technology for the treatment of volatile
organics, and would be fairly easy to implement. However, this
treatment combination may have some difficulty in removing all
the ser.i-voiatiie organics from the ground water down to
standards. Oprion B, chemical precipitation and UV oxidation,
may be somewhat difficult to implement successfully, since UV
oxidation technology is a relatively new technology whose
effectiveness with the contaminants at this site is questionable.
Option C appears to be the most viable choice; both semi-volatile
and volatile organics should be more easily removed from the
ground water to levels which meet MCL ground water standards by
using a combination of biological media and activated carbon.
Cost
The selected remedy, Alternative 5C, is cost-effective because it
provides the highest overall effectiveness proportional to its
cost. The cost of Alternative 5A is somewhat less expensive than
Alternative 5C. Alternative 5B is the most expensive.
Costs for the remedial alternatives are summarized in Table 11.
State Acceptance
The State of New Jersey, while concurring with the selected
remedy has raised concerns with the selection of ARARs for
discharge of treated ground water and the ultimate clean up goals
for the remedy. These concerns are largely related to
application of GW-2 "to-be-considered" (TBC) discharge
requirements developed by the NJDEP for the point of discharge.
EPA, has in this document, utilized promulgated ARARs. in
selecting the remedy. The appropriateness of NJDEP's MTBC"
requirements and the impact on treatment requirements will be
resolved during the remedial design.
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Community Acceptance
Community acceptance of the preferred alternative was evaluated
after the public comment period. The general public had no
opposition to the preferred alternative nor did they prefer any
other alternative. However, non-supportive comments were
received fror. potentially responsible parties. Comments raised
at the public meeting and during the public comment period are
summarized in the attached Responsiveness Summary.
SELECTED REMEDY
EPA and NJDEP have determined that the remedial goal for this
remedy is to return the regional aquifer to its beneficial use as
an actual or potential source of potable water, in accordance
with the expectations of the NCP. After a thorough review and
evaluation of the alternatives in the Feasibility Study, EPA, in
conjunction with the State of New Jersey, presented Alternative
MK-5 in the Proposed Plan as the Preferred Alternative. This
alternative was selected as the Preferred Alternative because it
would substantially reduce contaminant levels in the affected
portions of both aquifers, through pumping and treatment, and
ultimately would allow the deeper aquifer to be fully utilized as
a source of drinking water. Therefore, Alternative MM-5 provided
the best balance among alternatives in the Proposed Plan with
respect to the evaluation criteria.
The input received during the public comment period, including
questions raised at the public meeting held on May 31, 1990, and
comment letters received by EPA, are presented in the
Responsiveness Summary. The comments received encompassed a wide
range of issues, but did not necessitate any changes in the
remedial approach proposed to be taken at the site.
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, EPA
has selected the Preferred Alternative, Alternative MM-5,
Treatment of Ground Water from Both the Shallow and Deep Aquifers
(preferably by chemical precipitation and biological/granular
activated carbon), as the remedy for the site.
It may become apparent, during implementation or operation of the
ground water extraction system, that contaminant levels have
ceased to decline and are remaining constant at levels higher
than the remediation goal. In such a case, the system
performance standards and/or the remedy may be reevaluated.
The selected remedy will include ground water extraction for an
estimated -period of 30 years, during which the system's
performance will be monitored on a regular basis and adjusted
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according to performance data collected during operation. The
operating system may include:
a-) discontinuing operation of extraction wells in areas
where cleanup goals have been attained;
b) alternating pumping at wells to eliminate stagnation
points;
c) pulse pumping to allow aquifer equilibration and
encourage adsorbed contaminants to partition into
ground water; and
d) the installation of additional wells to optimize syster.
performance.
Due to the large number of wells and the amount of connecting
piping required to be installed in commercial and residential
areas, problems with implementation could occur. Therefore,
cleanup of the shallow ground water may be limited to extracting
and treating contaminated ground water from the more highly
contaminated perched zone "hot spots".
The treated ground water would be reinjected into the regional
aquifer and would comply with ARARs identified in Table 9.
Reir.jecticr. of the treated water into the regional aquifer
downgradient of the contaminated plume is expected to create a
hydraulic barrier, to prevent further migration of the plume.
Ground water monitoring will be implemented to observe the
hydrologic effects associated with the ground water extraction
and reinjection systems. It will also be used to appraise the
effectiveness of the treatment system and to monitor the movement
of the contaminated ground water plume. Furthermore, the ground
water monitoring program will be used in the evaluation of the
adequacy of the existing cap at the SLI landfill, which may be
the subject of a subsequent Record of Decision.
The points of compliance for ground water remediation are
throughout the plume.
The ground water monitoring program will comply with State
requirements and with RCRA regulations specified in
40 CFR 264.97, dealing with the installation of monitoring wells.
Alternative MM-5 would result in the reduction of the Hazard
Index to below 1, and carcinogenic risks to below 10"6, by
reducing volatile organic chemicals, semi-volatile chemicals, and
metals in the ground water to levels which meet State and Federal
.ground water standards.
Treatment system Option C includes chemical precipitation and
biological granular activated carbon. Option C would reduce the
toxicity and volume of both semi-volatile and volatile organics
found in the ground water, and would be designed to control air
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emissions of volatile organic compounds. A modified or
alternative treatment system may be selected during the Remedial
Design, based on changes in technical specifications, costs, or
treatability studies. The final chosen technology would, of
course, be required to meet ARARs.
The selected remedy poses no unacceptable short-term risks.
Notwithstanding, a comprehensive health and safe-y plan would be
prepared to ensure proper protection of the public, and workers
on site, during the remedial action.
The total estimated cost (at present worth) of Alternative W.-5
over 30 years, using Option C as the selected treatment
technology, is $20.5 million.
The total estimated capital cost for Alternative MM-5, using
Option C as the selected treatment technology, is $8.4 million.
This cost includes the design and construction of the ground
water treatment system, monitoring wells, reinjection wells,
associated piping, and miscellaneous facilities. The estimated
annual O&M cost is $751,000.
Currer.t engineering controls, including those actions required ir.
the closure plan for the SLI landfill, and institutional
controls, such as warnings on new well installations in the area,
are included as part of the remedy.
STATUTORY DETERMINATIONS
EFA's selected remedy for the ground water remediation complies
with the requirements of Section 121 of CERCLA as amended by the •
Superfund Amendments and Reauthorization Act. The action is
protective 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 alternative treatment
technologies to the maximum extent possible. The statutory
preference for treatment that reduces toxicity, nobility or
volume will be addressed by this action. The selected remedy
provides the best balance of tradeoffs among the criteria,
especially among the five balancing criteria. A brief, site-
specific description of how the selected remedy complies with the
statutory requirements is presented below.
1. Protection of Human Health and th« Environment
The selected remedy is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified.
The principle threat is the potential risk to local municipal
drinking water wells from the migration of contaminants in the
aquifers. By pumping and treating the contaminated ground water
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fro::, both aquifers, the selected remedy will reduce the health
and environmental risks associated with ground water in the area
down to levels that are acceptable for drinking water. l-n
addition, by treating a large volume of water from the regional
aquifer, the selected remedy will control further migration of
the plume, and thereby reduce the potential risk cf contaminating'
municipal drinking water wells.
The selected remedy poses no unacceptable short-term risks.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will comply with the following ARARs.
Cher.ical-specific ARARs
.. The cleanup objectives for the ground water and the
reinjected treated water are provided in Table 9. These
levels represent the concentrations which would be attained
in both the treated water before reinjection and in the
ground water at the end of the remedial action. They are
based on State and Federal MCLs for drinking water and New
Jersey Ground Water Quality Criteria.
Activity-specific ARARs
New Jersey air pollution control regulations are applicable
to the construction and operation of the selected remedy.
The operation of the treatment system will comply with RCRA
requirements. Hazardous sludges produced by the treatment
system will be disposed of off site in accordance with RCRA
requirements and State Sludge Quality Criteria; the exact
requirements will be determined during the design of the
treatment system.
The remedial action would be designed to meet New Jersey
requirements for ground water monitoring activities.
Location-specific ARARs
State and Federal regulations governing the construction of
facilities in a floodplain are applicable.
To Be Considered fTBCs)
The shipment of hazardous wastes off site to a treatment and
disposal facility should be consistent with the Off-site
Policy Directive Number 9834.11 issued by the EPA Office cf
Solid Waste and Emergency Response. This directive is
intended to ensure that facilities authorized to accept
CEP.CLA generated waste are in compliance with RCRA operating
standards.
-------
26
A comprehensive health and safety plan would be prepared to
ensure that the public and on-site workers are properly
protected during the remedial action.
Federal and State ARARs for the clean-up are presented in
Table 10.
The State of New Jersey, while concurring with the selected
remedy has raised concerns with the selection of ARARs for
discharge of treated ground water and the ultimate clean up goals
for the remedy. These concerns are largely related to
application of GW-2 "to-^be-considered" (TBC) discharge
requirements developed by the NJDEP for the point of discharge.
EFA, has in this document, utilized promulgated ARARs in
selecting the remedy. The appropriateness of NJDEP's "TBC"
requirements and the impact on treatment requirements will be
resolved during the remedial design.
3. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum
extent practicable. Contaminated ground water will be extracted
from the shallow and deep aquifers, and treated before
reinjection. This will significantly reduce the toxicity,
mobility, and volume of the contaminants found in the ground
water and restore the regional aquifer as a source of drinking
water. Hazardous wastes generated by the treatment process will
be treated and disposed of at approved facilities off site.
4. Preference for Treatment as a Principal Element
The selected remedy utilizes treatment to the maximum extent
practicable. Contaminated ground water will be extracted from
the shallow and deep aquifers, treated to meet standards, and
then reinjected into the regional aquifer. Hazardous wastes
generated by the treatment process will be treated and disposed
of at approved off-site facilities.
5. Cost-Effectiveness
Of the alternatives which most effectively address the threats
posed by the contaminant plume, the selected remedy affords the
highest level of overall effectiveness proportional to its cost.
Based on the information generated during the Feasibility Study,
the estimated total project cost is $20,475,000.
-------
27
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for.the Cinnaminson Ground Water Contamination
site was released to the public in May 1990. The Proposed Plan
identified the preferred alternatives for each source area. EPA
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, it was
determined that no significant changes to the selected remedy, as
it was originally identified in the Proposed Plan, were
necessary.
-------
EXHIBITS
-------
IAVI ons
ONION
lANfHNG
tlOAD
^ toon HAM
WMITTSriL
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TOPCMNSAUNtN
CINNAMINSON GROUND WATER CONTAMINATION SI1H
-------
'to
OClAWAttE
nivin
wtirrtsrit
•n
-------
HOCGANACS
COflPOMAIION
PEHCMCD
/ONt
IOWILLS
UNION
LANDING
ItUAO
PERCHED
7f>NE
100 WILLS
PERCHED
ZONE
M> WILLS
MEREDITH
PAVING
PERCHED
70HE
IOWLUS
TREATMENT
PLANT
TO PENNSAUKEN
ICF KAISER ENGINEERS, INC.
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loowriLS
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i:
ICF KAISCn ENGINEERS, INC.
CINNAMINSON GROUND WATER CONTAMINATION SITE
EXTRACTION WELL SYSTEM TOR ROTH AOUiriiMS ,
r»
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ft
In
rt
-------
TABLE 1
COMPARISON OF MAXIMUM CONCENTRATION
DETECTED IN THE PRM AQUIFER
(EPA WELLS ONLY) WITH THE KAX1MUM
CONTAMINANT LEVELS (MCLS)
CINSAMINSON GROUND WATER CONTAMINATION
FEASIBILITY STUDY REPORT
Maximum SDWA 1 NJSDWA 2
Chemical Concentration (uq/1) MCL's (uc/11 MCL's
1,2-DicMorobenzere 21.0
l,4-Dichlorober,zene 38.0
1,1-Dichlcroethane 440.0
1,2-Dichloroetrane 230.0 5.0 2.0
1,2-Dichleroethe^e (total) 260.0 10.0
1,2-Dicrilcropropane 35.0
1,1,1-Trichloroethane 23.0 26.0
1,1,2-Trichlorosthane 3.0
1,2,4-Tnchlcrcberzene 2.4 8.0
Acetone 2900.0
Antirr,:ry 54.0
Arsenic 110.0 50.0 50.0
Benzene 310.0 5.0 1.0
Benzcic Acid 65.0
7.0
400.0
Butyl ber,z^1p-r.:hilat« 14.0
Cad-iur. 13.8 10.0
Chlorcbr'zene 84.0 4.0
Chlorcfcrr. 2100.0 100.0
Cyanide 30.0
Di ethyl prthal ate 1.0
Di-n-butvl phthalate 2.0
Ethyl benzene 430.0
Manganese 14300.0 50.0
Noncarcinogenic PAH's 20.0
Selenium 5.0 10.0
Silver 18.7 50.0
Tetrachioroethene 110.0 1.0
Total Xylene-s 1100.0 44.0
Trichloroethene 380.0 1.0
Vinyl Chloride 85.0 2.0 2.0
1 Safe Drinking Water Act, Maximum Contaminant Levels
2 New Jersey Safe Drinking Water Act, Maximum Contaminant Levels
-------
TABLE 2
COMPARISON.OF MAXIMUM CONCENTRATION DETECTED IN THE
PERCHED ZONE (EPA WELLS ONLY) WITH
MAXIMJM CONTAMINATION LEVELS (MCLs)
•CINSAMINSON GROUND WATER CONTAMINATION
FEASIBILITY STUDY REPORT
Maximum - SDWA 1 NJSDWA 2
Che-cal Concentration fuc'11 HCL's ruo'll MCL's fuc'1)
1,1-DicMc-ethane 10.0
l,2-Dichloretha"e 50.0 5.0 2.0
1,2-Dicnlo-oetnene (total) 25.0 10.0
l,4-D'ichloi-cber,2ene 8.0
CMcrcber.zene 430.0 4.0
Eth^Tber.zer.e 107.0
Benzene 12.0 5.0 1.0
Vinvl Ch'cride 34.0 2.0 2.0
Total Xvier.es 67.0 44.0
Arsen:c 3.8 50.0 50.0
Ka-:a-ese 7270.0
Silver 31.0 50.0 50.0
1 Sa'e r--'-ki-'C U'a*.e- Act, Maxinur Contaminant Levels
2 Ne« Jerse.v Safe Drinking Water Act, Maximum Contaminant Levels
-------
Chemicals of Concern for the Regional Aquifer
and Perched Water Zones
Cfwr.:l,
.
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to* ^
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E.£ 3 (Co-.:irues>
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vinyl eMe-iOe
lou; tyiervss
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-------
TABLE A
Chemicals of Concern for the Inhalation of
VOCs
CfWil*
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-------
TABI.F. 5
Rlr.ks Aftsorlnton1 with th«* Indention of Ground
W.-ilrr I rom the Prrrhoil W.ilor /ones
r.tfc irUM|rn»;
mm INiRAiinM (m/i|
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CripmirA I
1 . 1 DlrhloroetMnp
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1,4-0 Ir.n lorolipn/pn^
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llpo/pnr
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mim (mri/ln/rliy) 1 Avprarj*
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-------
TABI.P 6
Risks Associated with the Inp.estlon of
Crniind M.-itcr (rom the Rep.lon.il Aquifer
r.irr. inof|rn<;
rottriNiPMirm (mi/M IHIAH
rhrmtc*!
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01 01
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II 04
71 01
51 04
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71 04
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.11 07
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II 0?
>l (7)
PATIO
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71 01
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.11 01
m oi
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>l (70)
NR - thp <(PipnPtr tc iKPan Mas not rpportpil (M), hpr*ll<:p thp qpnmptrlr mpan wa^ f|rpa|pr than or pc|tia I lo thp
a) Ol'.'.olvPfl contpntrat Ion was MSPrl to hp con^pr»at tvp hrcaii^P II purpprVd |hp total ronrpntrat Ion.
-------
TABI.K 7
Risks Assolc.itocl with the Inh.ilntlnn of VOCs
by nonrhy Workers
ttmrmic i>Mt» iMtwr
eaw.rNtMiirat tnq/mi) (inn (Mt/iq/rtny) r»«rr«
Onvtrtc Plwrcihlr 1*1 KM
fmfiminil Mr.in NniilMM Avrraqe Mnnimm (mq/tq/q»n*
CMtrmic n*iiT i«i*Kt
CmCrNIMtlON (n«/«1) l| (^/tq/rfoy)
Crwvlrlc riMRlhU INTO
CnUfMMnl •*«•>" NnNl«M* Avrrftq* M*«lmM (wq/ltq/rfMy)
4 Hf.lt.y1 7 pmlwwnv He I.OBt 0? •- ?.W O9 ?.W 0?
thl«n»m>««» I.WW 01 1.0U OZ 7. 4U 11 I.9IW 09 5. Or 01
Slyrrw 1.40C-OI 7.BW 07 ?.%9» 11 5.4W 09 ••
HA/KtO IHDCN:
r«i:rs% limn mimn
1 III IINI C»M«B •!<;»
PlMKihlr
Hvrmq^ ?*,-%• imMi
AT U U 11
71 -H U 1?
W-H U-11
roittfo t*iio
rlmrtlhlr
Av^rwq^ Maiimm
« 07
U-OB • «» nr
u on M or
- -
-------
TABI.F. R
Risks Aftsnlrntcd with the Inhnlnt Inn of VOCn
hy No.irhy
t™^,^
Nrthylonr rMorlifp
TO1MI:
rtwomr OAMV itttAtr rm^ iirrrt nnirw
CnNTrwiRAIinM I) (xr|/tq/cl«v) CANff* IMIIINI l»MfH« nil*
f.fimtr tf P
-------
Table 9
Ground Water ARARs
COMPOUND (micrograms/liter)
1,2-Dichlorobenzene 600
1,4-Dichlorobenzene 75
1,2-Dichloroethane 2
1,2-Dichloroethene (cis & trans) 10 '
1,1,1-Trichlcroethane 26 J
1,2,4-Trichlorobenzene ' 8
Benzene 1
Chlorobenzene 4 '
Chloroform 100
Tetrachloroethene 1
Total xylenes 44
Trichloroethene 1
Vinyl chloride 2
Arsenic 50 *
Cadmium 10 *
Cyanide 200 *
Manganese 50
Selenium 10 |
Silver 50
New Jersey Maximum Contaminant Levels
Federal Maximum Contaminant Levels
National Interim Primary Drinking Water Regulation
New Jersey Ground Water Quality Criteria
-------
Table 10
Summary of Federal and State ARARS
for the Cinnaainson Site
ARAR
Federal
Safe Drinking Water Act
National Primary Drinking Water
Standards
RCRA Standards for Owners
and Operator of Hazardous
Waste Treatment, Storage,
and Disposal Facilities
Resource Conservation and
Recovery Act (RCRA) -
Identification and Listing of
Hazardous Wastes
Executive Order on
Floodplain Management
Citation
40 CFR Part 141
40 CFR Part 264
and Part 264.97
40 CFR Part 264.1
Executive Order 11988 and
40 CFRs 6:302(b) and
Appendix A
State
New Jersey Safe Drinking
Water Act
New Jersey Ground Water
Quality Criteria
New Jersey Discharge of
Effluents to the Ground
Water
New Jersey Requirements for
Ground Water Monitoring
New Jersey Sludge Quality
Criteria
New Jersey Air Pollution Control
Regulations
Flood Hazard Area Control Act
NJAC 7:10-1 et sea.
NJAC 7:9-6.6(b)
NJAC 7:14A-1 et seq.
NJAC 7:26-9 e_t seq.
NJAC 7:14-4 Appendix B-l
NJAC 7:27-1 e_£ seq.
NJSA 58:16A-50
Flood Hazard Area Regulations
NJAC 7:13-1 et sea.
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RESPONSIVENESS SUMMARY
CINUAMINSON GROUND WATER
CONTAMINATION SITE
CINNAMINSON, NEW JERSEY
SEPTEMBER 1990
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Table 11
Costs cf Remedial Alternatives
Alternative Capital Annual Present
Costs o & M Worth
MM-l 0 5,000 416,000
MM-2 369,000 84,000 1,702,000
MM-3A 4,739,000 506,000 6,941,000
3B 5,192,000 617,000 15,083,000
3C 8,093,000 649,000 18,633,000
KK-4A . 5,192,000 617,000 15,083,000
4B 6,069,000 1,002,000 21,879,000
4C 5,628,000 700,000 16,796,000
MM-5A 8,093,000 694,000 18,633,000
5B 9,122,000 1,114,000 26,810,000
5C 8,367,000 751,000 20,475,000
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TABLE OF CONTENTS
Section Page
I. RESPONSIVENESS SUMMARY. OVERVIEW 1 •
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 3
III. SUMMARY OF MAJOR QUESTIONS, COMMENTS AND RESPONSES 4
A. Technical Issues 4
B. Source Control Issues 9
C. Potentially Responsible Party Issues 1C
D. Cost Estimation and Funding Allocation Issues 10
E. Property Issues 12
IV. WRITTEN COMMENTS AND RESPONSES 13
APPENDICES
Appendix A: Proposed Plan
Appendix B: Sign-in Sheets
Appendix C: Agenda for Public Information Meeting
Appendix D: Information Repository List
Appendix E: Superfund Update
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RESPONSIVENESS SUMMARY
CINNAMINSON GROUND WATER CONTAMINATION SITE
CINNAMINSON, NEW JERSEY
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) established a
public corjnent period from May 16, 1990 through June 15, 1990.
In response to a written request received by EPA, the public
consent period was extended to July 31, 1990. The public comment
period provided interested parties with the opportunity to
corjnent on the remedial investigation and feasibility study
(RI/FS) report and the Proposed Plan for the Cinnaminson Ground
Water Contamination (Cinnaminson) site, in Cinnaminson Township,
New Jersey.
EPA held a Public Information Meeting on May 31, 1990 at 7:30
p.m. in the Cinnaminson Township Community Center to outline the
remedial alternatives described in the RI/FS and to present EPA's
proposed remedial alternatives for controlling ground water
contamination at the Cinnaminson site. A public availability
session was held on June 1, 1990 from 10:00 a.m. to 1:00 p.m. In
addition, EPA held an additional availability session on July 25,
1990 at the request of several citizens that did not attend the
first meeting. The public availability sessions were held at the
Cinnardnson Township Community Center for interested citizens to
ask questions and to discuss concerns with EPA on a one-to-one
basis.
This Responsiveness Summary summarizes the written and oral
comments received by citizens during the public comment period
and EPA's responses to those comments. The EPA, in consultation
with the New Jersey Department of Environmental Protection
(NJDEP) , will select a final remedy for site cleanup only after
reviewing and considering all public comments received during the
public comment period.
This Responsiveness Summary is organized into four sections and
five appendices as described below:
I. RESPONSIVENESS SUMMARY OVERVIEW: This section briefly
describes the objectives and the format of the
Responsiveness Summary for the Cinnaminson site.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT XKD CONCERNS
EPA initiated community relations activities for the Cinnaminscn
site with a public scoping meeting at the Cinnaminson Township
Municipal Building on April 14, 1986. The meeting was held to
discuss the scheduled RI/FS activities. Approximately 80
residents and local officials from Cinnaminson and nearby Delran
Township attended the meeting.
According to a July 2, 1986 Meeting Summary, which is available
at the information repositories identified in Appendix D of this
report, the major concerns that were identified by the community
at that time are listed below:
Residents and local officials were concerned about the
limited availability of information to the public regarding
the status of EPA activities. They requested that they be
kept informed of future investigation results.
Residents expressed concern about contaminated ground water
affecting the municipal water supply wells. They wanted to
know if it was safe to drink, cook and bathe in the water
they were receiving from the New Jersey Water Company.
Residents stated that there was a lack of information
regarding the SLI (Sanitary Landfill Inc.) closure plan that
was approved by NJDEP.
Local officials and residents were concerned about the
funding for the remedial action at the site. They wanted to
know if the Superfund reauthorization in 1986 would delay
funding for the site cleanup.
Approximately 40 residents and local officials attended the
recent pubic meeting held by EPA on May 31, 1990. The meeting
was held to outline the remedial alternatives described in the
RI/FS and to present EPA's proposed remedial alternative for
controlling ground water contamination at the Cinnaminson site.
Several citizens, who did not attend the May 31st public meeting,
requested that EPA hold a second meeting. In response, EPA
scheduled a second availability session on July 25, 1990. The
community's major questions and concerns that were raised during
the public meeting and the two availability sessions are
summarized in the following Section.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS:
This section provides the history of community concerns
and interests regarding the Cinnaminson site.
III. SUMMARY OF MAJOR QUESTIONS, COMMENTS AND CONCERNS:
This section summarizes the oral comments received by
EPA at the May 31, 1990 public meeting and the June 1,
1990 public availability session, and provides EPA's
responses to these comments.
IV. WRITTEN COMMENTS AND RESPONSES: This section contains
all written comments received by EPA during the public
comment period as well as EPA's written responses to
those comments.
Appendix A: This appendix contains the Proposed Plan that
was distributed to the public during the public meeting held
on Kay 31, 1990.
Appendix B: This appendix contains sign-in sheets from: the
Public Information Meeting held on May 31, 1990 at 7:30
p.m.; the Public Availability Session held on June 1, 1990
from 10:00 a.m. to 1:00 p.m.; and the availability session
held on July 25, 1990 at 7:00 p.m.
Appendix C: This appendix contains the Agenda for the
Public Information Meeting held on May 31, 1990.
Appendix D: This appendix contains an updated list of the
information repositories designated for the Cinnaminson
site.
Appendix E: This appendix contains the Superfund Update
which summarizes the remedial activities conducted at the
Cinnaminson site.
The remedy to control ground water contamination at the site is
selected by the EPA Region II Administrator and will be
documented in the Record of Decision (ROD). EPA will issue a
press release to notify interested citizens that a remedial
decision has been made. This Responsiveness Summary) the ROD,
and the -other site-related documents that EPA used to select the
remedial alternative will be placed in the information
repositories for public review (See Appendix D).
-------
III. SUMMARY OF MAJOR QUESTIONS. COMMENTS AND RESPONSES
The oral comments raised during the public comment period and
EPA's responses to these comments are summarized below.
A. TECHNICAL ISSUES AND CONCERNS
COMMENT: One resident wanted to know in which direction the
contamination plume is moving.
RESPONSE: The results of the remedial investigation, conducted
by EPA's consultant, Camp Dresser & McKee (COM), indicated the
contamination plume in the deep aquifer is generally migrating in
a south-southeasterly direction. It should be noted that a
slight shift occurs in the northern area where the flow direction
deviates to a south-southwesterly direction. The flow of the
shallow aquifer or perched zone is very localized, and the ground
water in this zone primarily follows the inclination of the clay
layers which are responsible for forming the perched zone.
Ultimately, however, the ground water from the perched zone
migrates vertically through the clay layers and enters into the
deep aquifer and eventually migrates south-southeast.
COMMENT: A citizen wanted to know if it was possible for the
contamination in the perched zone to migrate in a different
direction other than southeast since the ground water in the
perched zone follows the inclination of the clay layers.
RESPONSE: The contamination in the perched zone may temporarily
migrate in a different direction from the regional plume;
however, it will eventually migrate vertically into the deep
aquifer and move with the regional plume toward the southeast.
COMMENT: The same resident wanted to know the flow rate and
general extent of the contamination plume in the shallow and deep
aquifers.
RESPONSE: Contamination in the perched zones is localized into
four distinct areas; three circular, and one sausage shaped. The
deep aquifer contamination extends to properties bounded by Union
Landing Road, Route 130, River Road, and Taylors Lane. The rate
of migration has not been determined. However, the rate could be
directly influenced by the rate that ground water is pumped from
the aquifer. It should be noted that, although the highest
levels of contamination are found near the sources of
contamination, results from ground water sampling suggest that
the plume is migrating slowly.
-------
COMMENT: One resident asked if the contaminants could sink to
the bottom of the aquifers, reverse their migration direction,
and backtrack north in the opposite direction of the regional
ground water flow.
RESPONSE: The majority of the contaminants detected in the
ground water are heavier than water and will sink to the bottom
of the aquifer. There is no evidence, however, to suggest that
these contaminants are backtracking and migrating north.
COMMENT: One local official wanted to know what monitoring wells
were used to determine the extent of the ground water
contamination plume.
RESPONSE: EPA obtained the data from 87 monitoring wells to
determine the extent of the contamination plume. The data was
based on information collected from several sources which
include: 49 wells installed by EPA during the remedial
investigation; 26 wells installed by SLI to meet closure plan
requirements; and 12 wells on the Hoeganaes Corp. property.
COMMENT: A citizen asked which municipal wells would be affected
first if the plume continued to extend further southeast, and
wanted to know what was being done to prevent the plume from
reaching these wells.
RESPONSE: According to the New Jersey American Water Authority
(NJAKA), the first wells that would be impacted are the New
Albany Road well and the Pomona Road well. However, if the wells
became contaminated, an interconnected water supply system would
enable NJAKA to shut down the contaminated wells and still
provide the community water from other wells in the area.
In order to prevent contamination of the public water supply, EPA
will coordinate with NJAWA during the design and construction
phase of the cleanup to avoid unnecessary strain on the aquifer.
Since the rate of migration could increase relative to increased
pumping at wells near the site, NJAWA stated they could alter
their pumping operation pattern to reduce the volume of ground
water extracted southeast of the site. This reduction could
substantially slow the plume's migration rate and reduce the
chances of contamination at the Albany and Pomona Road municipal
wells.
COMMENT: A resident wanted to know the volume of ground water
that would be treated during the remediation process.
RESPONSE: If Alternative MM-5 (Treatment of Ground Water from
Both the Shallow and Deep Aquifers) is selected, approximately
'9,340 million gallons of ground water would be treated, over
approximately 30 years.
-------
COMMENT: A resident asked how often the municipal wells were
tested for contamination.
RESPONSE: A representative from NJAWA stated a routine
monitoring program was implemented to include testing of
municipal wells on a monthly basis. In accordance with the Safe
Drinking Water Act, these results are submitted bi-annually to
NJDEP. NJAWA developed this stringent program to ensure good
quality drinking water quality to its customers.
COMMENT: One resident wanted to know if there had been any
studies conducted to test the water quality at Swedes Lake. He
suspects that the lake may be contaminated since he has noticed
less wildlife on the lake, and several members of his family had
developed a rash after swimming in the lake. He also inquired if
the ground water contamination from the Cinnaminson site could
eventually contaminate the lake.
RESPONSE: Swedes Lake is parallel to Leon Avenue and lies
outside the Cinnaminson study area, so the water quality had not
been assessed by EPA. According to the Burlington County Health
Department (BCHD), there have been no water quality tests
performed on this lake, since it is not an approved swimming
area. This lake was originally developed as a retention basin
and receives the road run-off from the area. Because of
suspected contaminants in the lake, the BCHD strongly suggests
that residents do not swim or fish in the lake.
Since the lake is hydraulically upgradient of the landfill, it is
unlikely that the landfill is contaminating the lake. However,
in response to the concern, EPA will undertake sampling of the
lake during the design of the remedial action.
COMMENT: One resident stated that it was difficult for him to
obtain information such as the RI/FS report, Proposed Plan, and
Superfund update from the information repositories.
RESPONSE: EPA had previously established three information
repositories. They were the: Cinnaminson Township Municipal
Building; Cinnaminson Township Community Center; and the East
Riverton Civic Center Association. To better serve the pubic's
needs, one of the repositories has been changed and contact
information has been updated. The location of the repositories
currently established for the Cinnaminson site are the:
Cinnaminson Township Municipal Building
1621 Riverton Road
Cinnaminson Township, NJ 08877;
Contact: Grace Campbell, Phone: (609) 829-6000
Hours of operation: Mon. - Fri. 8:30 a.m. to 4:00 p.m.
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East Riverton Civic Center Association
2905 James Street
Cinnaminson Township, NJ 08077
Contact: Dorothy A. Waxwood, Phone: (609) 829-1258
Information available upon request
Cinnaminson Public Library
1609 Riverton Road
Cinnaminson Township, NJ 08077
Contact: Molly Conners, Phone: (609) 829-9340
Hours of operation:
Mon. - Thurs. 10:00 a.m. to 8:30 p.m.;
Fri. 10:00 a.m. to 5:00 p.m.; and
Sat. 10:00 a.m. to 5:00 p.m. (Except July and August).
Please note that the Cinnaminson Township Community Center
repository was eliminated and replaced by the Cinnaminson Public
Library repository. The information repositories designated for
the Cinnaninson site contain the RI/FS report, Proposed Plan,
fact sheets and other site related documents. The Responsiveness
Summary and the ROD will also be placed in the repositories. EPA
will continue its efforts to keep the community informed of
developments related to the Cinnaminson site and to update the
repositories.
COMMENT: One resident asked if the soils and/or vegetation near
the site were contaminated.
RESPONSE: The RI sample analyses revealed that soil in the
vicinity of the site was not contaminated and that the
contamination was confined to the ground water.
COMMENT: One citizen wanted to know if the extraction wells,
proposed to be installed on residential properties, would be
intrusive and unsightly to homeowners.
RESPONSE: EPA intends to make the wells as inconspicuous as
possible; however, the deep aquifer extraction wells need to be
in place for approximately 30 years. This alone could be
.disturbing to homeowners. The wells will be contained, in small
sheds for example, and placed as far away from the homes as
possible. EPA plans to install deep aquifer wells only on
properties large enough to accommodate the structure, to limit
inconveniences to the residents.
COMMENT: Several residents wanted to know if EPA plans to
coordinate its remediation efforts with NJAWA during the
construction and implementation phase of the project.
-------
RESPONSE: During the Remedial Design phase of the cleanup, EPA
will develop design specifications for the selected alternative.
During this time, EPA will consult with NJAWA and other state and
local agencies.
COMMENT: One citizen wanted to know if EPA was aware that the
State plans to construct an incinerator at the Pennsauken
Landfill in Pennsauken, New Jersey. He asked if the incinerator
and the operational landfill could contribute further to ground
water contamination in the area.
RESPONSE: The Pennsauken Landfill is located at 9600 River Road
Pennsauken, New Jersey. According to the NJDEP, Bureau of
Resource Recovery, the incinerator has been permitted at the
landfill site but construction has been delayed. Because of the
location of the Pennsauken Landfill and the proposed incinerator,
EPA does not anticipate the landfill to have a detrimental impact
on ground water quality at the Cinnaminson site. The incinerator
is designed to process approximately 500 tons of waste per day;
the ash residual will be deposited at the landfill. Hazardous
waste will not be deposited at the Pennsauken landfill.
COMMENT: A resident asked if the air emissions from the site
were harmful.
RESPONSE: Air emissions from the site are not harmful. Ground
water is the only medium that has been contaminated.
'COMMENT: One citizen wanted to know if the possibility exists
that contaminants could be released to the atmosphere during
construction of the extraction wells. And, if so, they expressed
concern that the public could be exposed to additional health
risks because the contamination will no longer be limited to the
ground water but released into the atmosphere. He also wanted to
know how EPA intends to protect the community from such an
occurrence.
RESPONSE: The possibility exists that volatile organic and
inorganic compounds could be released into the atmosphere during
the well construction process. As a precaution, EPA will develop
a Health and Safety Plan (HSP) during the Remedial Design phase
of the cleanup.
The purpose of the HSP is to establish policies and procedures,
which are in accordance with the Occupational Safety and Health
Administration (OSHA) standards, that protect the health and
safety of on-site personnel and the community. Included in the
plan, workers are required to wear protective clothing and
equipment to safeguard them from exposure to contamination. In
addition, air quality is monitored to detect any release of
contamination into the atmosphere. The HSP also includes a
-------
Community Emergency Contingency Plan in the event of a
contamination release. In the rare event of wide spread
contamination, nearby residents could be evacuated. This plan
details contact information, notification systems and
arrangements for community evacuation procedures.
COMMENT: A resident asked if EPA could alter the cleanup plan
for this site after signing the ROD, if a more advanced treatment
technology was developed.
RESPONSE: According to the current Superfund Amendments and
Reauthorization Act (SARA) regulations, it is possible to re-
open and modify the ROD. Modifications may also be made to the
ROD if the selected treatment technologies prove to be
ineffective. If significant changes are made to the ROD, EPA is
required to conduct another public comment period such as this
one, and would likely hold another public meeting to discuss the
modifications.
COMMENT: One citizen wanted to know why it will take five years
to treat the perched aquifer and 30 years to treat the deep
aquifer.
RESPONSE: There is a much greater volume of water in the deep
aquifer; therefore, it will take longer to treat it than the
perched aquifer.
COMMENT: One resident asked why the government was planning to
spend so much money to clean up the site if there was no
immediate health risk to the public.
RESPONSE: In order to fund any cleanup, it must be determined
that the site poses an actual or potential risk to the public
and/or to the environment. Although the NJAWA public water
supply is currently unaffected by the ground water contamination,
and there is no immediate risk to the public, the contamination
poses a potential threat. It has impacted the environment and
created a potential threat to human health, should the plume
migrate further and contaminate the municipal wells, since it is
critical to protect our drinking water resources, the objective
of this remedial action is to confine the plume and eventually
eliminate contamination in the ground water.
B. SOURCE CONTROL ISSUES
COMMENT: Several residents and local officials wanted to know
why the Proposed Plan focused on cleaning up the ground water
contamination and not the potential sources of contamination
including the SLI Landfill, L&L Redi-Mix and DEL-VAL properties.
They felt the Proposed Plan did not adequately address source
control issues such as evaluating the efficiency of the landfill
-------
cap prior to ground water cleanup, and eliminating contamination
from underground storage tanks.
RESPONSE: During the RI/FS, EPA identified several potential
sources of ground water contamination, including the SLI
Landfill. In reviewing the data collected, it was determined
that insufficient information was available for some of the
sources to address their remediation. In regard to the SLI
Landfill, EPA determined that further evaluation is needed to
determine if the closure already in place is adequate.
Therefore, EPA has elected to divide the cleanup into different
phases of activity, referred to as operable units. Ground water
contamination will be addressed in the first operable unit and
the principal source control issue will be addressed as a
separate operable unit. This phased approach provides EPA with
the flexibility to examine source control issues in greater
detail while proceeding with the ground water Remedial Design and
cleanup activities. The State of New Jersey will be taking the
lead in addressing the remediation of a number of suspected
sources concurrent with the ground water cleanup.
C. POTENTIALLY RESPONSIBLE PARTY ISSUES
COMMENT: A resident asked who was going to pay for the cleanup.
RESPONSE: EPA replied that, where viable potentially responsible
parties (PRPs) exist, they are offered the option of conducting
and paying for the cleanup. To date, EPA has used Federal
Superfund monies for the RI/FS at the Cinnaminson site. EPA
intends to offer the PRPs the opportunity to conduct the Remedial
Design and Remedial Action at the site. In the event that the
PRPs do not perform or fund the selected remedy, EPA will pay 90
percent of the remedial action cost and the State will pay for
the remaining 10 percent. EPA may then pursue legal action for
cost recovery from the PRPs.
D. COST ESTIMATION AND FUNDING ALLOCATION ISSUES
COMMENT: One resident wanted to know how the present worth for
the remediation alternatives was derived.
RESPONSE: The present worth costs are used to determine and to
evaluate expenditures that occur over different time periods by
discounting all future costs to a common base year, usually the
current year. In conducting the present worth analysis,
assumptions must be made regarding the discount rate and the
period of performance. In this case, the discount rate, or Cost
Factor, is 5 percent and the period of performance is 30 years.
10
-------
Cost Factor = fl + 5%^*"" - l
5% (1 +
Therefore, the Present Worth equals the first year cost estimate
for operation and maintenance (O&M) , multiplied by the 30 year
period at a 5 percent discount rate, plus the Estimated Capital
Cost. When applied to the preferred alternative, MM-5 with
Option C, this equation translates to: [(Estimated O&M Cost) x
(Cost Factor) ] -f- Estimated Total Capital Costs = Estimated
Present Worth (PW)
[(751,000) X (15.37)] +8,367,000 = 19,909,870'
COMMENT: One citizen asked whether the Cinnaminson site would
still be cleaned up if S.uperfund monies were not reauthorized in
1991.
RESPONSE: For the Cinnaminson site, as for all National
Priorities List (Superfund) sites, EPA will first attempt to get
the potentially responsible parties (PRPs) to perform the design
and implementation of the selected remedy. Should the PRPs
refuse to design and implement the selected remedy, EPA will
perforn these activities using federal funds, pending
availability of these funds. EPA would then attempt to recover
the cost of all federal activities from the PRPs.
COMMENT: The same resident wanted to know if Superfund monies
had already been committed to remediate the site.
RESPONSE: After the ROD is signed, EPA will provide funds for
the design of the project. Construction costs will be allocated
after the completion of the design. EPA provides 90 percent of
those costs; the State provides the remaining 10 percent. Long-
term O&.M costs are provided mostly by the State.
COMMENT: A resident asked if the cost of the proposed remedial
program reflected the cost after a ten year period of inflation.
RESPONSE: The costs shown in the Feasibility Study and the
Proposed Plan represent compressed worth. Compressed worth is
the amount of money EPA would have to invest now at 8 percent
interest in order to have the appropriate funds, including
current projections for inflation, available at the actual time
the remedial action is implemented.
''The PW that is calculated in the FS varies slightly since
this calculation involves estimated costs and rounded down
figures.
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COMMENT: A resident inquired as to whether the EPA had received
bids from contractors for the cleanup, or whether the proposed
budget was an estimate.
RESPONSE: The proposed budget was an estimate for the relative
evaluation of cost. Therefore, the actual cost could be less or
more than the number presented.
E. PROPERTY ISSUES
COMMENT: Several residents were concerned that a Superfund site
in their neighborhood could have an adverse affect on the
property value in the area. They wanted to know if EPA would
compensate or reimburse them for any incurred loses.
RESPONSE: EPA explained that residents have three courses of
action. First, they could contact the NJDEP regarding the Spill
Compensation Act to determine the applicability of this act to
their situation. Second, residents have the option to take legal
actions against the PRPs. Third, EPA suggested that citizens
could have their property reassessed. If the appraised worth is
lower than its current worth, residents may qualify for a
reduction in their property taxes.
COMMENT: One resident wanted to know if their property could be
condemned because of the underlying contaminated aquifer.
RESPONSE: Since the ground water contamination poses no
immediate health threat to residents and the local community, it
is unlikely that their property could be condemned.
COMMENT: Residents wanted to know if they had the legal right to
refuse access to EPA, thereby interfering with EPA's plans to
install extraction wells on their property.
RESPONSE: EPA is permitted to install extraction wells on
private property only with the owner's consent.. The owner would
be asked to sign an access agreement which would authorize EPA to
proceed with the well construction plans. However, if the owner
does not consent to the access agreement, EPA is not permitted on
their property, unless a court order is obtained.
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IV. WRITTEN COMMENTS AND RESPONSES
This section contains all written comments received by EPA during
the public comment period as well as EPA's written responses to
those corjnents.
EPA RESPONSE tc P.M. KLOTZ«S JUNE 13. 1990 COMKEKV LETTER
COMMENT: Which company will be selected to do the overall
cleanup?
RESPONSE: If the Superfund is used to fund the cleanup, EPA will
provide money to the U. S. Army Corps of Engineers (COE) to
oversee both the design and the construction of the remedy. The
COE will select the best qualified company, through their Federal
contract award procedures. If potentially responsible parties
elect to manage the cleanup, EPA will oversee and approve all
work.
COMMENT: If it was Waste Management or a subsidiary, how do you
justify giving them the work?
RESPONSE: If Waste Management and/or other PRPs wish to
manage the work, EPA would ask them to sign a legal consent order
which would require them to perform the remedy as stipulated in
the Record of Decision. EPA would oversee and approve all work
throughout the cleanup.
COMMENT: What department (s) in the NJDEP will be supporting the
EPA in this cleanup effort?
RESPONSE: The Division of Hazardous Waste Management will be
supporting the EPA in this cleanup effort.
COMMENT: Is there any coordination among NJDEP's Water
Resources, Allocations, Hazardous Waste, etc?
RESPONSE: The Division of Hazardous Waste Management in NJDEP
works closely with EPA on all Superfund sites in New Jersey.
That division coordinates internally with all other involved
program offices in the NJDEP on Superfund site issues.
COMMENT: Since the petroleum underground storage tanks will not
be addressed under this Plan, when will they be addressed?
RESPONSE: The petroleum underground storage tanks will be
addressed under New Jersey State regulatory authorities.
COMMENT: Will there be a separate public hearing?
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RESPONSE: NJDEP has specific regulatory procedures for
addressing individual leaking underground storage tanks. NJDEP
should be contacted directly to determine whether public meetings
or hearings would be planned.
COMMENT: Will there be added cost?
RESPONSE: The Superfund law does not cover underground petroleur,
storage tanks, nor spills of petroleum products. Therefore, no
additional costs for leaking tank cleanups would be eligible
under Superfund.
COMMENT: According to Camp, Dresser & Mckee (CDM), contamination
is in both the shallow and regional (PRM) aquifer. What do you
estimate the cone of influence to be?
RESPONSE: A cone of influence does not exist in the shallow or
the regional (PRM) aquifer. In general, a cone of influence is
created by an extraction well when water is being pumped from the
ground. The approximate extent of ground water contamination is
represented in Figure 1 of the ROD.
COMMENT: The SLI Superfund site has many of the same
characteristics and background history as the Pennsauken Landfill
located on River Road including the same contaminants. The
Pennsauken site is also supposed to undergo remedial cleanup as
well. Is there any coordination between NJDEP and EPA pertaining
to these two sites? If wells are needed for the Pennsauken site,
what effect will these wells have on the Cinnaminson cleanup or
water supply wells in the area?
RESPONSE: The Pennsauken Landfill is located at 9600 River Road
in Pennsauken, New Jersey; it is not a Federal Superfund site.
Because of the location of the Pennsauken Landfill and proposed
incinerator, EPA does not anticipate that they will have a
detrimental impact on the Cinnaminson's ground water cleanup
activities or on the public drinking water wells.
COMMENT: How many gallons of water per day will be taken from
the 130 wells?
RESPONSE: Approximately 318,240 gallons of water per day will be
taken from the shallow aquifer.
COMMENT: How many from the other seven wells required for the
regional aquifer?
RESPONSE: Approximately 806,400 gallon per day will be taken
from the regional aquifer.
COMMENT: Will there be more wells needed for the regional
aquifer?
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RESPONSE: The conceptual design described in the Record of
Decision may be modified somewhat during the actual Remedial
Design of the remedy; perhaps, more wells may be needed or
locations changed. EPA will continue to keep interested citizens
informed as work progresses during both the design and the
remedial action.
COMMENT: What influence will the draw from these wells have on
the drinking supply wells located two miles south?
RESPONSE: The EPA wells will be drawing ground water from the
regional aquifer at a lower rate than the drinking water wells.
EPA believes that the lower extraction rate will not influence
the drinking water wells. EPA will coordinate cleanup activities
closely with the New Jersey American Water Company.
COMMENT: what influence will these extraction wells have on the
Delaware River since they are hydraulically connected?
RESPONSE: Due to the rate at which the extraction wells will be
pumping ground water from the regional aquifer, EPA believes that
the extraction wells will not influence the Delaware River.
COMMENT: Regarding risk from ingestion of ground water from the
perched water zones, do local farmers water from the perched or
regional aquifer?
RESPONSE: Hunter's Farm is the only farm that is located close
to the study area. Hunter's Farm receives drinking water from
the New Jersey American Water Company; pond water is used for
crop irrigation.
COMMENT: What health risk analysis have been done on absorption
via the skin of the ground water from the perched or regional
aquifer?
RESPONSE: The risk assessment prepared for the site identified
the potential ingestion of contaminated ground water from the
regional aquifer as the only significant threat.
COMMENT: At what velocity does the plume travel?
RESPONSE: The estimated average lateral velocity of the
contaminated ground water in the regional aquifer is 35 feet per
year.
COMMENT: Under Administrative Controls, a general warning is to
be placed on new well installations for potable water, would the
general public be notified through the nail or as a special
notice on their bills?
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RESPONSE: Administrative controls involve the State or local
governments placing general warnings on new well installation
permits to warn of the potential health risks involving the use
of the ground water for potable purposes. Therefore, applicants
for new well installation permits will be notified of the general
warning, but not the general public.
COMMENT: Under Alternatives MM-3, MM-4 (MM-5C), will there be
on-site treatment? If so, how much and what type of construction
would take place?
RESPONSE: Yes, there will be on-site treatment. All of the
extracted water will be treated in the treatment plant.
Construction components will include: extraction wells, piping to
convey the extracted ground water to an pn-site treatment plant,
and reinjection wells.
COMMENT: How would this affect the contamination plume?
RESPONSE: The construction activities, in and of themselves,
will not affect the contaminated plume. When construction is
completed, the combined process of extracting, treating, and
reinjecting the ground water is expected to reduce the
contaminated plume.
COMMENT: Under Option C: Chemical precipitation/biological
granular activated carbon treatment.
a) How is the chemical precipitation controlled?
b) What chemicals would be used and what airborne
particulates and gases will be emitted?
RESPONSE: In the chemical precipitation process, lime would be
added to the contaminated water to induce metals and solids
precipitation. In order to prevent air pollution, all treatment
units will be designed to ensure that there will be no air
emissions. For example, the equalization tank, the chemical
precipitation, and the filtration process units would be equipped
with floating covers to prevent loss of volatile chemicals.
COMMENT: What constitutes a waiver for an ARAR? And, who grants
such a waiver?
RESPONSE: There are six circumstances when ARARs can be waived
by the Regional Administrator of EPA, they include:
1) compliance with the ARAR is technically impracticable,
2) the remedial action selected will attain a standard of
performance that is equivalent to that required under
the ARAR using another method or approach,
3) compliance with the ARAR will cause a greater risk to
health and the environment,
4) the remedial action is an interim measure to be
followed by a complete measure,
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5) the State has not consistently applied the ARAR, and
6) the remedial action will not provide a balance between
the need for protection of public health, welfare and
the environment and the availability of the amounts
from the Superfund to respond to other sites.
COMMENT: The EPA and NJDEP both preferred Alternative MM-5C.
Does that fill the requirement of state acceptance? Would there
be any modifications to this alternative and would the public be
notified?
RESPONSE: EPA and the NJDEP work closely together on all
Superfund sites in the State of New Jersey. EPA gives formal
notice of State concurrence (or non-concurrence) in both the
Proposed Plan and the ROD. The public is notified of any major
modifications to the remedy selected in the ROD.
COMMENT: Is the cost of the cleanup fixed or will it escalate
during the 30 year duration?
RESPONSE: The cost presented in the Proposed Plan and the ROD is
an estimate of the cleanup cost over a 30 year period. A better
cost estimate will be determined during the design phase of the
remedy.
COMMENT: What effect does the soil contamination at the
Smythwycke development located at Church & Forklanding Roads have
on the local drinking supply wells?
RESPONSE: Currently, NJDEP is investigating the soil
contamination at the Sroythwycke development. Preliminary
sampling results indicated that the soil is contaminated with
metals and pesticides. Additional investigations are needed to
determine the extent of the soil and the ground water
contamination. With the limited sampling information that is
presently available, any effects that the soil contamination may
have on local drinking water wells can not be determined at this
time.
COMMENT: What remedial action is planned for the Smythwycke
site? And, how will that cleanup affect both the Cinnaminson
project and the proposed cleanup for Pennsauken?
RESPONSE:' Additional information on the extent of the soil
contamination is needed before NJDEP can evaluate and develop a
remedial action plan for the site.
COMMENT: Is there a grand plan or coordinating effort to protect
overall health and welfare of our communities in regard to all
the contaminated sites in the area (Cinnaminson, Pennsauken,
Swope, etc.)?
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RESPONSE: EPA works together with the NJDEP under a variety of
Federal and State legal authorities to address all of these
problem sites.
COMMENT: While I am in favor of the cleanup, what preventative
measures will be taken to allow permanent recharge to the aquifer
without further contamination?
RESPONSE: The current landfill cap is designed ^o reduce the
infiltration of rain water into the landfill, thereby decreasing
the further migration of the contaminated plume. EPA will be
monitoring the effectiveness of the landfill cap during the
ground water remediation, which is expected to drain the landfill
of much of its remaining contaminants during the course of the 30
year remedial action.
COMMENT: will there be any restrictions placed on industrial
growth or housing developments in the Tri-boro area?
RESPONSE: No restriction will be placed on industrial growth and
housing developments in the Tri-boro area as a result of the
Superfund remedial action.
EPA'S RESPONSE TO COMMENTS FROM JONATHAN PUL8IPER
COMMENT: Our wells along with all other potable wells in a given
radius should be included in an ongoing monitoring program.
RESPONSE: EPA is required to limit authorized monitoring and
remedial activities to those actions which relate directly to the
Superfund site. The well locations described in your letter are
not located in, or near, the contaminant plume defined for the
site.
EPA'S RESPONSE TO COMMENTS FROM SYLVIA i JOSEPH TAYLOR
COMMENT: I call on you and the Federal EPA to include five wells
in your monitoring process. These wells are all within 1/2 mile
of the site you are covering.
RESPONSE: EPA is required to limit authorized monitoring and
remedial activities to those actions which relate directly to the
Superfund site. The well locations described in your letter are
not located in the contaminant plume defined for the site.
COMMENT: Get the owners of the landfill to pay a large share of
the costs. There is no reason for all this cost to be borne by
taxpayers.
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RESPONSE: The Superfund law authorizes EPA to pay for site
cleanups only when potentially responsible parties cannot be
found, or if they refuse to participate in the clean-up. After
the ROD is signed, EPA will determine whether any PRPs are
interested in doing, or paying for, the work. If EPA continues
to use government funds to pay for the cleanup, the agency can
take legal action to attempt to obtain reimbursement of costs.
COMMENTOR; FORD ELECTRONICS ANT) REFRIGERATION CORPORATION
(FERCO)
COMMENT: FERCO is not persuaded that a state ARAB exists that
would necessitate pumping and treating the "shallow aquifer".
Thus, much of the proposed remedy (MM-5C) which includes pumping
and treating the perched water in addition to the lower aquifer
is unnecessary, wasteful and not legally required.
RESPONSE: The New Jersey Department of Environmental Protection
was contacted prior to initiation of the feasibility study to
determine if it would consider the perched zone (shallow aquifer)
as part of the Potomac-Raritan-Magothy (PRM) aquifer. The NJDEP
stated that it did. In addition, the perched zone is
hydraulically connected to the PRM. Consequently, contamination
frora the perched zone will migrate to the PRM if not remediated.
Therefore, NJDEP ground water standards apply to the perched
zone, and ground water pumping and treating from this zone was
included in the FS.
COMMENT: Inadequate consideration appears to have been given to
"soil flushing" technology.
RESPONSE: Soil flushing of the SLI Landfill was not included as
a source control alternative because of the low permeability of
landfill materials, and the potential to spread contamination
further. Because of the low permeability, water added to the
landfill would move very slowly through the compacted trash,
raising the saturated water level within the fill, potentially
increasing the rate of movement of leachate to the perched zone,
and spreading the contamination to additional areas.
COMMENT: FERCO is unconvinced that the very dilute levels of
inorganics are treatable by conventional chemical precipitation.
RESPONSE: Treatment for inorganics is required because
inorganics were detected at concentration levels that exceeded
MCLs. Chemical precipitation is a proven technology for
inorganics; however, as stated in the FS Report, treatability
studies will be required to verify the effectiveness. A
different treatment technology could be considered, if it could
meet ARARs.
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COMMENT: FERCO disagrees that any sludge generated during the
treatment process would necessarily be considered hazardous
either as a listed waste or characteristic waste.
RESPONSE: It is quite possible that the sludge generated during
the treatment process would be hazardous. The sludge
characteristics and the appropriate handling techniques will be
determined during treatability studies for the treatment process.
COMMENT: Other contributing sources should have been given
greater attention throughout the RI/FS process.
RESPONSE: Source-specific remediation for sources other than the
SLI Landfill were not considered in the FS. Other contributing
sources, such as underground petroleum storage tanks and other
commercial facilities, which are not regulated by Superfund, will
be handled under New Jersey State law and regulations.
COMMENTOR! AMERICAN WATER WORKS SERVICE CO., INC.
COMMENT: Before the collection wells and the 'discharge wells are
cited for the remedial project, a ground water model must be
created to reflect what is actually going on within the deep
aquifer.
RESPONSE: Additional ground water modeling (as requested by the
comr.entor) can be performed as part of the remedial design.
COMMENT: When the existing monitoring wells were installed, PVC
(polyvinyl chloride) casing and screening were used.
RESPONSE: EPA monitoring wells were constructed of stainless
steel.
COMMENT: Because of the nature of the technology being utilized
for the ground water cleanup together with the fact that the
discharge from the on-site treatment plant is going to be
injected into the aquifer, American Water Works Service Co.
requests permission to have access to the site for the purpose of
collecting samples of the water being discharged into the
aquifer.
RESPONSE: NJDEP regulations covering the sampling of treated
effluent will apply. The American Water Works Service Co. will
be able to review analytical data concerning the treated water
being discharged into the regional aquifer.
COMMENT: Since the quality of water in the production wells of
New Jersey American Water are free from any volatile
contamination, the quality of the discharge water from the
treatment plant should be of the same quality, or at the worst,
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meet the maximum contaminant levels as established by New Jersey
Department of Environmental Protection for drinking water
supplies.
RESPONSE: The treated effluent will meet, at a minimum, Federal
and State maximum contaminant levels.
COMMENT: Will the New Jersey American Water Company be eligible
for Superfund cleanup money or remedial treatment of these wells
if the contaminant plume reaches its wells?
RESPONSE: If the New Jersey American Water Company's wells are
affected by the contaminated plume from the site, Superfund
cleanup monies could be used to remediate the problem.
COMKENTOR; SANITARY LANDFILL, INC (SLI)
SLI submitted its comments in the form of a letter, dated July
30, 1990, from Katten, Muchin & Zavis, with various attachments
including SLI's previously submitted comments concerning the RI
(letter dated October 16,. 1989); all submitted materials are part
of the Administrative Record. The EPA has previously responded
to these comments on the RI in its report dated July 11, 1990,
which is part of the Administrative Record for the site. SLI had
a consultant (GeoServices Inc, Consulting Engineers) prepare a
report of the Cinnaminson RI/FS and has included this report
entitled Review of the USEPA Remedial Investigation and
Feasibility Study, Cinnaminson Study Area. Cinnaminson. New
Jersey, as an additional attachment to its July 30, 1990 letter.
SLI's findings and comments are summarized in Section 7 of the
report. EPA's responses to SLI's comments will follow the order
of the findings as set forth in Section 7.
COMMENT: The preferred remedial alternative does not meet the
primary remedial objective, to protect public health and the
environment. Ground water modeling and a review of available
data indicate that implementation of the preferred remedial
alternative would actually increase the threat of human health
effects and environmental damage.
RESPONSE: This is incorrect. The preferred remedial alternative
meets the primary remedial objective, to protect public health
and the environment. The extraction and treatment system will be
designed to capture the contaminants that are impacting the
aquifers and posing a threat to municipal drinking water wells.
The extracted water will be treated to meet State and Federal
drinking water standards before it is reinjected back into the
regional aquifer. The Environmental Protection Agency (EPA)
believes that over time, the extraction and treatment system will
reduce the levels of contaminants in both the shallow and
regional aquifers, and prevent the future migration of the plume
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toward the municipal drinking water wells. In addition to the
extraction and treatment systems, EPA will also install
monitoring wells to evaluate the effectiveness of the remedial
action and the current landfill cap. By reducing the contami-
nation levels in the ground water and preventing further
migration of the plume, the extraction and treatment system will
actually eliminate the threat to human health and the
environment.
COMMENT: Implementation of the preferred remedial alternative
will not result in a significant reduction of contaminant
concentrations in either the shallow perched zones or the PRM
Aquifer to acceptable levels during the implementation period (30
years). In fact, water quality following the implementation
period will be degraded,
RESPONSE: Over time, the preferred remedial alternative will
result in significant reduction of contaminant concentrations in
both the shallow and regional aquifer. Extracting the contami-
nated water from the shallow aquifer will reduce the amount of
contaminants flowing downwards into the regional aquifer. Since
the regional aquifer will be extracted concurrently with the
shallow aquifer, EPA believes that the combination will reduce
the contaminant concentrations and return both aquifers to
drinking water quality.
COMMENT: There are other significant areas of ground water
contamination than the landfills contributing to ground water
contamination in the Cinnaminson Study Area. The preferred
remedial alternative does not address either the source areas or
the primary pathways of migration. Instead, the preferred remedy
focuses on so-called "hot-spots" identified by the EPA Remedial
Investigation (RI) .
RESPONSE: EPA is aware of the other potential sources of ground
water contamination in the area. The RI Report identified other
potential sources, including petroleum underground storage tanks
(USTs). The preferred alternative was developed to capture the
ground water contaminants from the landfill and those
contaminants which have migrated from the other sources, since
those contaminants are commingled in the ground water and
practically indivisible for treatment. As stated in the Record
of Decision, the control of other sources will be addressed under
other State and Federal regulations.
"Hot Spots" were used in describing the remediation of the
shallow aquifer. The shallow aquifer does not contain
significant volumes of water that would allow continuous
extraction and treatment. EPA believes that the placement of
extraction wells in highly contaminated regions of the shallow
aquifer, defined as "hot spots", will be effective. The cone of
influence that would be produced by the extraction wells will
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capture a significant amount of the contaminated water in the
shallow aquifer.
COMMENT: Implementation of the preferred remedial alternative
will result in an increase in mobility of contamination from
other sources. The increase in mobility will be caused by
spreading the more highly contaminated ground water from the
source areas to previously uncontaroinated or less contaminated
areas of the aquifer.
RESPONSE: EPA does not believe that the preferred remedial
alternative will spread more highly contaminated ground water
from source areas to previously uncontaminated or less
contaminated areas of the aquifer.
After all of the data were carefully analyzed, the RI identified
the two SLI Landfills as the major sources of ground water
contamination. In addition to the landfills, the RI identified
several other potential sources, in close proximity to the
landfills, which are contributing to the ground water problems in
the area. During the design, additional ground water data will
be gathered and the extraction system will be designed in detail.
If it is determined during the design that contamination from
other sources will contaminate previously uncontaminated areas of
the aquifer, modifications to the conceptual configuration of the
extraction system will be made.
COMMENT: The screening, evaluation, and selection of the
preferred remedial alternative was based on an inaccurate
understanding of site conditions, geology, and hydrogeology.
This led to an inappropriate evaluation of remedial technologies
and selection of a remedial alternative which does not fit site
conditions. Ground water quality will degrade over time if the
preferred remedial alternative is implemented in the Cinnaminson
Study Area.
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RESPONSE: To understand the site conditions, EPA carefully
evaluated the information collected from both geological and
hydrogeological studies that were conducted at the site. The
studies and data are presented in the Final RI Report. Given the
extensive studies that were conducted at the site, EPA believes
that the preferred remedial alternative is appropriate and will
not degrade the ground water quality in the area.
COMMENT: The treatment system selected for the organics
recovered from ground water (biological granular activated
carbon) is not appropriate for the organics in the study area.
RESPONSE: Biological granular activated carbon is a proven
technology for the treatment of the organic compounds detected in
the Study Area. Nevertheless, as stated in the FS Report,
treatability studies will be performed to verify the effective-
ness of the treatment system. If necessary, another treatment
process will be utilized.
COMMENT: It would be impractical and extremely inefficient to
deploy the recovery wells as described in the EPA feasibility
study (FS).
RESPONSE: As stated above, the extraction wells will be placed
at the edge of the contaminated plume and in the path of the
oncoming ground water. Deploying the wells in this manner will
capture the contaminated ground water from all sources in the
area. In addition, as stated above, further analysis will be
done during the remedial design to ensure the efficiency of the
ground water extraction system.
COMMENT: The preferred remedial alternative does not consider
the beneficial impacts of the existing vapor extraction systems
on long-term water quality.
RESPONSE: The existing vapor extraction system is designed to
extract gases from the landfills to protect the existing caps.
The system is not intended to remediate the contaminated ground
water.
However, soil vapor extraction for ground water remediation was
considered in the FS, but was screened out because of a number of
site-specific conditions which nay preclude the use of vacuum
extraction at the site. The most difficult condition to overcome
is the heterogeneous nature of the soils at the site. The
permeability and nature of these materials will vary signifi-
cantly throughout the site and, in some cases, the permeability
will be relatively low. Due to the potential difficulties that
would prevent the successful implementation of this technology,
it was not retained for further consideration.
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COMMENT: The preferred remedial alternative does not consider
the beneficial impacts of biodegradation on long-term water
quality.
RESPONSE: In-situ biological treatment was considered in the FS,
but was also screened out for further evaluation for several
reasons; for example, the technology cannot meet the ground water
cleanup standards, which would allow it to be ce--.5id.ered a viable
alternative. In addition, EPA believes that biocegradation would
not be effective in reducing the mobility of the contaminated
ground water over the long term.
COMMENT: The present worth of the preferred remedial alternative
'is extremely high ($20,475,000) relative to the predicted
benefit.
RESPONSE: After a careful analysis of the remedial alternatives
presented in the FS report, EPA believes that the preferred
alternative is protective of human health and the environment,
reduces the toxicity, mobility and volume of the contaminants,
and provides a permanent solution to the ground water problems at
the site. In balancing the beneficial effects of the remedy with
its cost, EPA believes that the remedy is cost effective and
necessary to remediate the ground water contamination problems.
COMMENT: The preferred remedial alternative does not address
contamination from the SLI northwest landfill. This is due to
the improper assumption that site conditions at the northwest and
southeast landfills are similar.
RESPONSE: The preferred remedial alternative does address
the SLI.northwest landfill. EPA will install a total of 20
extraction wells in the shallow aquifer surrounding the northwest
landfill. The RI report indicated that the contaminants in the
regional aquifer beneath the northwest landfill have migrated to
the southeast landfill. The regional aquifer extraction system
will capture the contaminants flowing from both landfills and
other potential sources in the area.
COMMENT: The preferred remedial alternative will likely fail due
to increases in concentrations of organic constituents in the
monitoring wells over time. These increases in contamination may
result from migration of highly contaminated ground water from
other sources towards the recovery systems, or because of the
inefficiency of the proposed recovery systems relative to leakage
from the landfills.
RESPONSE: The treatment system is designed for average ground
water concentrations detected during the RI. It is not expected
that these levels will increase over time to levels high enough
such that the treatment system will not be effective.
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COMMENT: The preferred remedial alternative will likely fail
because the remedial technology selected from treatment of
organics (biological granular activated carbon) is inappropriate
for some of the primary organics in the contaminated ground
water.
RESPONSE: As stated before, biological granular activated carbon
treatment is believed to be appropriate for all of the organics
detected in the ground water. Treatability studies will indicate
the effectiveness of this technology.
COMMENT: The preferred remedial alternative will likely fail due
to the ground water recovery system capturing only a very small
percentage (less than 2%) of the overall leakage from the
landfill.
RESPONSE: The ground water extraction system is intended to
capture the overall leakage from the landfills, in addition to
removing ground water from areas of the regional aquifer which
are contaminated.
COMMENT: The preferred remedial alternative is incapable of
achieving the remedial objectives for the Cinnaminson Study Area.
RESPONSE: The preferred remedial alternative was developed
specifically to achieve the remedial objectives for the site.
The remedial objectives for the site are to: return the aquifers
to drinking water quality and prevent the further migration ot
the contaminated plume. The extraction and treatment systems are
designed to effectively extract and treat the contaminated water
to meet State and Federal standards.
COMMENT: Other sources of ground water contamination have a
significant impact on the threat to public health and the.
environment and would have a detrimental effect on the preferred
remedial alternative. The volume of discharge from the other
sources may be relatively small compared to the discharge from
the two SLI landfills. However, the nobility and toxicity of the
ground water contamination from the other sources is much higher,
resulting in a major impact on the threat to public health and
the environment.
RESPONSE: Other sources of ground water contamination nay have a
significant impact on the threat to public health and the
environment, but will not have a detrimental effect on the
preferred remedial alternative. The preferred remedial
alternative was developed, and will be designed, to address the
contamination in the aquifers from all sources. The volume and
concentrations resulting from all sources will be considered in
designing both the extraction and the treatment systems.
26
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COMMENTOR; HERCULES INCORPORATED
COMMENT: The only exposure scenario which presents a potential
for health risks was that of exposure via ingestion of ground
water from wells drilled on the contaminated site. Based on the
risk summary for carcinogens presented in the Feasibility Study,
excess lifetime cancer risks from ingestion of the contaminated
ground water predominantly range between 10* and 10" for the
average case. This is an acceptable range of risk by EPA
criteria.
RESPONSE: The plausible maximum risk for the perched water zones
and the regional aquifer are 1 x 103 and 6 x 103 respectively,
which establishes a risk which is higher than the accepted range.
Furthermore, contaminants exist in the perched zones and the
regional aquifer that exceed the Maximum Contaminant Levels
(MCLs), which are the drinking water standards to be met.
In addition, the Hazard Indices (noncarcinogenic risks)
associated with the ingestion of ground water from the perched
water zones and the regional aquifer are 2 and 20, respectively,
for the plausible maximum cases. A hazard index greater than 1
indicates that potential exists for non-carcinogenic health
effects to occur as a result of site-related exposures.
COMMENT: Monitoring.showed no migration of the chemical plume
toward public wells and the recommendation for continued
monitoring is appropriate.
RESPONSE: Monitoring well data and ground water flow data
collected during the Remedial Investigation show a strong
potential for the municipal drinking water wells to eventually
be affected by the contaminants in the groundwater. In addition
to the active remediation of the ground water to be performed
under the selected alternative, monitoring of the aquifer- will
continue.
COMMENTOR: DEL VAL« INK AKD COLOR. INC
.Del Val submitted a letter dated June 1, 1990 transmitting a
report, Rebuttal to Cinnaminson Ground Water Contamination Study
Final Remediation Report. November 1989. prepared by their
consultant, SMC Environmental Services Group. EPA's detailed
responses are contained in a response dated July 31, 1990. Both
the SMC report and EPA's response is part of this Responsiveness
Summary. Del Val's letter summarizes the consultants conclusions
as follows:
COMMENT: It can be concluded that there is no evidence presented
which confirms the conjectures stated several times [in the
Remedial Investigation Report] that Del Val is a source of
contamination.
27
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RESPONSE: Monitoring well sampling data from the remedial
investigation indicates that Del Val is one likely source of some
contamination, specifically chloroethane, in the ground water.
This determination is based on the following: Chloroethane was
found at higher concentrations in the shallow well on the Del Val
property and was not found in wells upgradient of the Del Val
property. However, while Del Val is suspected of being a source
of Chloroethane, it is recognized that they are not the only
source.
COMMENT: This consultant concludes that CDM statement is
misleading when it refers to Del Val as a possible minor source
of contamination since they have not first established the
presence of an additional source of contamination downgradient of
wells found to contain contamination.
RESPONSE: Again, the pattern of ground water contamination found
during the Remedial Investigation suggests that Del Val is a
likely source for ground water contamination. The RI recognizes
the potential for other sources. The existence of other sources
of ground water contamination downgradient does not discount the
likely potential that Del Val is also a source.
COMMENTOR: AFG INDUSTRIES. INC.
COMMENT: It appears that treatment of all ground water will be
the most expensive alternative and likely unnecessary to actually
protect the public interest in question.
RESPONSE: EPA has evaluated all the remedial alternatives
presented in the proposed plan in light of this comment and still
has concluded that of the alternatives which most effectively
address the threats posed by the contaminant plume, the proposed
remedy affords the highest level of overall effectiveness
proportional to its cost.
COMMENT: We believe that implementation of Alternative MM-5 is
contrary to the National Contingency Plan (NCP).
RESPONSE: EPA developed, proposed and selected the remedial
action 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 applicable, the NCP.
COMMENT: We would suggest re-examination of the proposed
alternatives and implementation of the least cost alternative
necessary to protect the public health and environment.
RESPONSE: EPA has re-examined the proposed alternatives in
considering this and other comments on the proposed plan and has
28
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determined that the remedy proposed is the appropriate remedial
alternative to protect public health and the environment and is
the most cost-effective.
COMMENTOR; GRINDING BALLS. INC.
COMMENT: I doubt if you are ever going to get good clean ground
water in this area as long as it co-mingles with the landfill
ground water.
RESPONSE: The ground water contamination from the SLI Landfills,
in addition to the ground water contamination from other sources
were considered in developing the alternatives and the likelihood
of attaining the ground water cleanup objectives. EPA believes
that the ground water can be effectively remediated. However, it
may become apparent during implementation or operation of the
ground water extraction system, that contaminant levels have
ceased to decline and are remaining constant at levels higher
than the remediation goal. In such a case, the system
performance standards and/or the remedy may be reevaluated.
COMMENTOR: PEPPER, HAMILTON I SCHEETZ FOR CHEMICAL LEAMAN
COMMENT: Inadequate consideration has been given to use of soil
vapor extraction and bioremedial techniques used at other sites.
RESPONSE; Soil vapor extraction for ground water remediation was
considered in the FS, but was screened out because of a number of
site-specific conditions which may preclude the use of vacuum
extraction at the site. The most difficult condition to overcome
is the heterogeneous nature of the soils at the site. The
permeability and nature of these materials will vary signifi-
cantly throughout the site and, in some cases, the permeability
will be relatively low. Due to the potential difficulties that
would prevent the successful implementation of this technology,
it was not retained for further consideration.
In-situ biological treatment was considered in the FS, but was
also screened out for further evaluation for several reasons;
for example, the technology cannot meet the ground water
cleanup standards, which would allow it to be considered a viable
alternative. In addition, EPA believes that biodegradation would
not be effective in reducing the mobility of the contaminated
ground water over the long term.
COMMENT: The proposed plan should be reviewed in light of an EPA
memorandum, dated October 18, 1989, which "warnfs] against the
full scale implementation of pump and treat as recommended in the
proposed plan."
29
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RESPONSE: EPA developed the proposed plan and the Record of
Decision utilizing this memorandum. This memorandum was
developed because of the difficulties experienced while
implementing ground water remediation alternatives. It makes
several recommendations, one of which recommends providing
flexibility in the selected remedy to modify the system based
on information gained during its operation. In the Record of
Decision, EPA recognizes the potential difficult;~s in ground
water remediation and has provided the flexibility to modify the
system as follows:
"It may become apparent, during the implementation o.r
operation of the ground water extraction system, that
contaminant levels have ceased to decline and are
remaining constant at levels higher than the remedi-
ation goal. In such a case, the system performance
standards and/or the remedy may be reevaluated."
The Record of Decision then goes on to list some potential
variations to the operation system to optimize the system's
performance.
30
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Appendix A
The Proposed Plan
which was distributed to the public during
the public meeting on May 31, 1990.
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Proposed Plan-
Cinnaminson Ground Water
Contamination Site
Burlington County, New Jersey
•
Region 2 May 1990
INTRODUCTION-
This Proposed Plan presents the preferred options
for addressing ground water contamination in an
arts encompassing about • 400 acres in the
To*Ti£hip of Cmnarrunsor.. in Burlington County,
Nevk Jersey. In addition, the Plan includes
summaries of other alternatives considered for
remediating this site. This document is issued by
tbe U. S. Environmental Protection Agency
(EPA), the lead agency for site aaMties, and tbe
Nevk Jersey Department of Environmental
Protection (NJDEPj. the support agency for this
proj&c;. The EPA. in consultation with the
NJDEP, will ielec: a remedy for the site only after
the public corr.rr.en; period has ended and the
informa;ior. submitted during this time has been
reviewed and considered.
The EPA is issuing this Proposed Plan as pan of
its public participation responsibilities under
Section 117(a) of the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA). This document
summarizes information that can be found in
greater detail in the Remedial Investigation (RI)
and Feasibility Study (FS) reports recently
completed, and other documents contained in the
administrative record for this site. The EPA and
the State encourage the public to review these
other documents in order to gain a more
comprehensive understanding of the site and
Superfund activities that have been conducted
there.
The administrative record, which contains the
information upon which the selection of ibe
response action will be based, is available at:
Clnnaminson Township Municipal Building
1621 Rjverton Road
Ctonaminson Township, NJ 08077
Contact: Catherine E. Obert (609) 8294000
Cinnaminson Township Community Center
Manor Road
Clnnaminson Township, NJ 08077
Contact Catherine E. Obert (609> 8294000
East Rjverton Civic Center Association
2905 James Street
Cinnaminson Township, NJ 08077
Contact: Dorothy A. Waxwood (609j 829-1258
COMMUNITY ROLE IN THE
SELECTION PROCESS
EPA solicits input from the community on the
cleanup methods proposed at each 'Superfund site.
EPA has set a public comment period from Mcr>
16, 1990 through June 15, 1990 to encourage
public participation in the selection process. Tbe
comment period includes a public meeting at
which EPA, with the NJDEP, will present the RI
and FS reports and the Proposed Plan, answer
questions, and accept both oral and written
comments.
A public meeting is scheduled for May 31, 1990
beginning at 730 pm in the Cinnaminsoc
Township Community Center. A public
availability session will be held June 1, 1990
from 10:00 a.m to 1KB p.m. ic the Cinnaminson
Township Municipal Building to provide interested
parties with an opportunity to discuss the plan.
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SUE BACKGROUND
The Cinr.affiinsoc Ground U^ter Contamination
Site covers approximate)) 400 acres in the
Townships of Cinnamj'nson and Delran in
Burlington County, New Jersey (See Figure 1).
It include* properties bounded by Union Landing
Road, Route 130, Rjver Road, and Taylors Lane.
The Delaware River is located about 5,000 feet
northwest and US Route 130 passes about 2,000
fee't southeast of the site. Two small streams,
Poir.pesion Crack and Swede Rue, provide runoff
from the arta into the Delaware River. The site
consists of residential and light to heavy industrial
properties. The RI report identified several
potential sources of ground water contamination,
including: the Sanitary Landfill, Inc. (SLI)
landfills, L i L Redi-Mix. DEL-VAL Ink and
Color, and the Hoegar.aes Corporation. The
potential sources of ground water contamination
on these properties include an unlined landfill,
petroleurr. and solvent underground storage tanks,
unhned slum pits, cooling ponds and local septic
systems.
The subject of this Proposed Plan is the ground
water coriteminatioD in the area. Petroleum
underground storage tanks in the area will not be
addressed under thai Proposed Plan, but wilJ be
addressed under other federal and State
authorities, such as. the New Jersey Spill Program
and the State and Federal Underground Storage
Tank Program.
The major contributors to the ground water
contamination are two landfills owned by SLI
which operated from the 1960's until closure in
19SO. The landfill* received municipal waste,
sewage sludge, food processing wastes, and
industrial wastes, including hazardous substances.
SLI implemented a closure plan under an
agreement with tbe NJDEP. As pan of the
closure, the Landfills were capped with 18 inches
of clay. A landfill gas collection and venting
system were also installed, and a ground water
monitoring program was initiated, la 1981,
NJDEP approved the SLI closure plan.
EPA placed the Cinnaminson Ground Ubter
Contamination Site ot the National Priorities List
(NPL) of Superfund sites in June 1984
Verification of ground water contamination was
based upon the results of quarterly ground water
monitoring performed by SLI, as required by the
closure plan. Hydrogeologjcal studies and annual
reports on ground water quality conducted b;
Geraghry &. Miller lnc.(G&M 1983, 1984, and
1985) for SLL confirmed tbe presence of ground
water contamination in the area.
EPA initiated an RI in 1985 to determine the
presence and impact of all sources of ground
water contamination. An RI report was prepared
by EPAi consultant. Camp Dresser & McKee
Inc.(CDM) under Contract No. 68-01-6939. The
report concluded that tbe SLI Landfill was the
major source of ground water contamination.
Del-Val Ink and Color, together with septic
systems, unlined slurry pits, and cooling ponds in
the local area were identified as additional
contributing sources.
Using data gathered from 87 monitoring wells, the
RI identified the presence of volatile organic
compounds and inorganic compounds, above
Maximum Contaminated Levels (MCL) permitted
for drinking water, in two separate ground water
aquifers. Ground water contamination was
detected in the regional aquifer known as the
Potomac, Raritan, Magothy (PRM) Aquifer, which
underlies the site, and also in perched water zones
which lie above the regional aquifer. The regional
aquifer Qows in a south-southeasterly direction.
Tbe perched water zones flow downward into the
regional aquifer.
Tbe contaminants in both aquifers consist
primarily of the following volatile organic
compounds: be nzene.ethylbenzene.chJorobenzene,
1,2-dichloroethane, lylenes, irichloroethene, and
vinyl chloride. Inorganic contamination includes
arsenic, beryllium, cadmium, and cyanide.
SCOPE AND ROLE OF ACTION
Tbe environmental problems and the nydrogeology
at tbe Cinnaminson site are complex As a result,
EPA has decided to address tbe three main
pathways of contaminant migration:
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SUMMARY OF ALTERNATIVES
The PS identified two types of actions that would
address the pound water problems: Source
Control (SC) Alternatives aimed at stopping the
further leaching of contaminants into the pound
water from the landfill; and Ground Uater
Management of Migration (MM) aliernatrves
which would address contamination already in the
pound water.
In preparing the Feasibility Study, four basic
alternatives were considered: no action,
containment, treatment, and disposal. Several
remedial technologies that could meet pound
water cleanup objectives were identified and
reviewed (or effectiveness, unplementability, and
cost Those alternatives which passed the initial
screening are highlighted in this section.
Descriptions of all of the remedial alternatives
evaluated for the Cinnaminson Ground V»ater
Contamination Site are provided in the Feasibility
Stud> Repon.
The alternatives evaluated included the following:
Sourer Control (SO Alternatives
Alternative SC-1:
Alternative SC-2:
Aliemativt SC-3:
No Further Action
Monitoring and
Administratrve Controls
RCRA Capping
As mentioned previously, the landfill was capped
with IS inches of clay. Currently, the cap is
effectively acting as a barrier to the infiltration of
rain water into the landfill, which reduces funher
migration of the contaminated pound water
plume. Maintenance of the existing cap and the
installation of a pound water control system will
provide additional information on the long-term
effectiveness .of the cap. At that time any added
benefits of installing a full RCRA cap can be
evaluated. Therefore, Alternatives SC-1, SC-2,
and SC-3 will not be discussed in this document,
but will be considered again after the selected
management of migration (ground water control)
system is in place and operating.
Ground Water (Management of Miention^ fMM]
Alternatives
No Further Action
Monitoring and
Administrative Controls
Treatment of Ground
Water from the Shallow
Aquifer (Perched Zone)
Treatment of Ground
vVater from the Detp
Aquifer (Regional Aquifer)
Treatment of Ground
Water from Both the
Srulkw and Deep Aquifer
MM-1:
Alternative MM-2:
Alternative MM-3:
Alternative MM-4:
Alternative MM-5:
Alternatives MM-3, MM-4, and MM-5 each
include three separate pound water treatment
options. Three are:
Option A: Chemical precipitation with au
stripping
Option B: Chemical precipitation with ultra-
violet oxidation
Option C: Chemical precipitation with biologicaJ
panular activated carbon
(MM-1): No Further Action
Estimated Capital Cost: SO
Estimated Annual O&M Cost: 515,000
Estimated Present Worth: $41,600
Implementation Period: None
The National Contingency Plan (NCP) and
CERCLA require the evaluation of a No Further
Action alternatives as a basis for comparison with
other remedial alternatives. The No Funher
Action alternative consists of only those actions
required by the existing SL1 Landfill closure plan,
which includes: pound water monitoring within
the plume boundaries, maintenance of site fencing
and the landfill cap, and controlling access to the
-------
Option C .Chemical j)rea'pitation.ftiological
granular activated
carbon sludge treatment
Estimated Total Capful Cost: SS.093.CXX)
Estimated Annual O
-------
treated to meet the ground water quality criteria
specified in NJ.A.C 7:14A-1, ud Federal and
State Safe Drinking Uaier An Maximum
Contaminant Levels (MCLs). This alternative
extracts water direct!) from the contaminated
perched water zones and the PRM Aquifer.
Tbe selected treatment process will be evaluated
funher during the remedial design and modified,
if necessary, to ensure that it wilJ meet ground
water quality criteria.
ANALYSIS
Overall Protection. A1J of the alternatives provide
some degree of protection. Alternatives MM-1
and MM-2 prevent exposure to ground water
contaminants by implementing administrative
controls. Alternatives MM-3, MM-4, and MM-5
provide a greater degree of protection by
extracting and treating contaminated ground water.
Alternative MM-3 provides ground water
treatment of the shallow aquifer and allows for
natural biodtgradauon of some contaminants in
the regional aquifer. Alternative MM-4 provides
ground water treatment of the regional aquifer,
contaminants in the shallow aquifer eventually
Do» into the regional aquifer and are treated.
Alternative MM-5 provides direct treatment of
both aquifers. Treating both the aquifers would
provide greater overall protection of public health
and tbe environment
Compliance »ith ARARs. Alternatives MM-1 and
MM-2 do no: address contaminated ground water.
These alternatives do not comply with
contaminant-specific ARARs. Alternative MM-
3, which treats ground water in the shallow-
aquifer but not the regional aquifer, would not
meet ARARs for the contaminated water in the
regional aquifer. Alternative MM-4 (with any of
the three treatment options) would be expected to
meet all ARARs for only the regional aquifer.
Because Alternatives MM 1 and MM-2 would not
meet the ground water ARARs, they will not be
considered further in this analysis as options.
Alternative MM-5C (Option C) would meet
ARARs for both the shallow and regional
aquifers.
Long-term Effectiveness and Permanence. Tbe
preferred alternative would extract the ground
water from the shallow and regional aquifers so
that it can undergo treatment to destroy the
contaminants. In Alternative MM-3, ground water
from the shallow aquifer would be extracted and
treated, but tbe regional aquifer would remain
contaminated. In Alternative MM-4, the shallow
aquifer would remain contaminated.
All of the treatment technology options (A, B, or
C) would produce a hazardous sludge which must
be handled for the duration of remediation.
Reduction of Toxidt> Mobility or Volume of
Coouminanu. Through tbe use of treatment
technologies, alternative MM-3 and MM-4 would
reduce the toxJcity and volume of contaminated
ground water in the shallow and regional aquifers,
respectively. Alternative MM-5, which involves
extraction and treatment of both aquifers, would
reduce the toxJcity and volume of contaminants in
the shallow and regional aquifers.
Short-term Effectiveness. It is expected that
Alternative MM-4 could be started within 18
months. Alternative MM-5 could be started
within 24 months and Alternative MM-3 in 12
months. Risks to workers and the nearby
community would be minimized during the
implementation of each alternative through the
use of appropriate engineering controls and
comprehensive health and safety planning.
Implemenubilit> Alternatives MM-3, MM-4, and
MM-5 utilize extraction wells and pumping
systems that are proven and widely used
technologies. Tbe hydrogeological characteristics
of tbe regional aquifer allow for easy, continuous
removal of contaminated water. Alternative MM-
3 and MM-5, which includes extraction of ground
water from the shallow aquifer (perched zones)
may not be as easy to implement. The
bydrogeological characteristics of the perched
zones do not allow a large volume of water to be
extracted from a single well. Tbe conceptual
extraction system for the shallow zone consists of
an estimated 130 wells. Due to the large number
of wells and the amount of connecting piping
required to be installed in a commercial
residential area, problems with implementation
could occur.
Cost Tbe preferred alternative, MM-5C, would
be protective of public health and the
environment, and would attain all ARARs in the
long term at a cost of 520,475,000.
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Glossary
• Aquifer An underground rock or soil foundation thai fa capable of supplying water to wells
and springs.
• Feasibility Study (FS): The second pan of a two-pan study RemediaJ Investjgauon/Feasibiliry
Srudy (RLrS). The Feasibility Study involves identifying and evaluating tbe most appropriate
lechnjca! approaches for addressing contamination problems ai a Soperfuod rite. The aJternatrves
considered in the FS are evaluated using tbe nine Superfund criteria, which includes effectiveness
in protecting human health and the environment
• Ground Water Ufcter that Clb spaces between sand, soil rock and gravel particles beneath
surface of the earth Raic water that does not evaporate or drain to surface water such as
streams, men, ponds, or lakes, but slowly seeps into the ground, forming a ground water reservoir.
Groundwater flows considerably more slowly than surface water, often along routes thai lead to
streams, rivers ponds, lakes and springs.
• Rvdrogeologic A word in reference to the science of hydrology, which studies the interactions
among surface water, ground water, and the earth's rocks and soils.
• National Priorities list (STL): A roster of uncontrolled hazardous waste sites nationwide that
po« ac actual or potential threat to human health or the environment, and are eligible for
and cleanup under the federal Superfund program.
• Ptrched Ground Water Zone: Unconfined ground water separated from the underlying main
body of ground water by an impermeable or semipermeable material.
• Proposed Plan: A document that describes all the remedial
alternates considered by U.S. EPA for addressing contamination at a Superfund site, including
the preferred U.S. EPA alternative.
• Remedial Action: A series of steps taken to monitor, control, reduce or eliminate risks to
human health or tbe environment. These risks were caused by the release or threatened release of
contaminants form a Superfond Site.
• Remedial Alternative: A combination of technical and administrative methods, developed and
evaluated in the Feasibility Study, that can be used to address contamination at a Superfund site.
• Remedial Investigation (RI): The first pan of a two-pan study Remedial
iDvestigaiion.'FeasibUiry Study. The Remedial Investigation involves collecting and analyzing
technical and background information regarding a Superfund site to determine the nature and
extent of contamination that may be present The investigation also determines bow conditions at
the site may affect human health the environment.
• Responsiveness Summary: A Section within the Record of Decision that presents U.S. EPAs
responses to public comments on the Proposed Flan and RI/FS.
• Super-fund: The common name for tbe federal program established by tbe Comprehensive
Environmental Response and, Liability Act (CERCLA) of 1980, as amended on 1986. Tbe
Superfund lav. authorizes US. EPA to investigate and cleanup the nations most serious hazardous
waste sites.
11
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Appendix B
Sign-in Sheets
from the Public Information Meeting
held on Kay 31, 1990 at 7:30 p.m.
in the Cinnar.inson Township Community Center and
the Public Availability Session
held on June 1, 1990 from 10:00 a.m. to 1:00 p.m.
at the Cinnaminson Township Municipal Center.
-------
; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
26
YO»K
10278
CXKXAMXNSON GROUKD WATER CONTAXIKATIOH SU7EX7UKD SITE
SICK-IN
PLEASE BE SURE TO PRIKT YOUR NAXE XKD ADDRESS CLEARLY SO TEXT WE
CA* ADD YOU TO OUR HAILING LIST:
L
- ADDRESS
C'*«'*.•• /v{» -• '«•/
PEL v/A
t; B.
Ml
OAK.
1 15
V, ,^r
/I' L£—
'.,'- e t »•..« ».•
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3?
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-------
; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. REGiON it
26 PECEOAL PU*ZA
NEW YO»K NEW YO«K 10278
CINNAXINSON CROWD WATER CONTAMINATION B77ZR7UND SITE
SIGN-IN MEET
PLEASE BE SURE TO PRINT YOUR NAXE AND ADDRESS CLEARLY 60 THAT WE
CAN ADD YOU TO OUR HAILING LIST:
NAME ADDRESS
Co.
g CC \ QCO O »^ iOrO L k g L^
T L fisc.h'm 7/y M/L^rer ftp C,*^ /J
(I/ L/
t. : •
.
. J/J.
M C'7 v^ru:^ d.C ;,-»,Vi. K ) T
_
/ Hs.iLt~J /c L^cl 3 2, / L, /V/ux^^ //^'^^^ //- /, ?6c7" -
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION II
MEETING WITH CITIZENS, CINNXKINSON T1TP. , N.J.
WEDNESDAY, JULY 25, 1990
CINNAMINSON TWP. MUNICIPAL BLDG.
PLEASE SIGN IN SO THAT WE CAN ADD YOUP NAME TO OUR PERMANENT
MAILING LIST FOR THE CXKNAMINSON GROUNDWATER CONTAMINATION
SUPZRFUND SITE
NAME
ADDRESS
C /— v '£ i
/I-'
f
/ ' J.
/
i r.
-------
V
U.S. EXVIROKXENTAL PROTECTION AGENCY, REGION II
KZETING WITH CITIZENS, CINXXXINSON TW?., H.J.
WEDNESDAY, JULY 25, 1990
CINNAMINSON TWP. MUNICIPAL BLDG.
PLEASE SIGN IN SO THAT WE CAN ADD YOUR NAME TO OUR PERMANENT
MAILING LIST FOR THE CINNAMINSON GROUNDWATER CONTAMINATION
SUPZRjrUND SITE
KA>S ADDRESS
/
>x
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Appendix C
Agenda for May 31, 1990 Public Information Meeting
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UMTtD STATES ENVIRONMENTAL PROTECTION AGENCY
26 r EDEPAL P
MEw YORK NEW YO«K 10278
PUBLIC MEETING ON
THE CZKKXXZNSON CFOUKD WATER CONTAMINATION 80PER7UKD SZT2
CINNAXINSON TOWNSHIP, NEW JERSEY
THURSDAY, KAY 31, 1990
•CZNKAKINSON TOWNSHIP MUNICIPAL BUILDING
CINNA.MINSON, NEW JERSEY
T.JO P.M.
AGENDA
Welcr-e 4 Introduction
General Overview of the
Superfur.d Process &
Purpose of Meeting
Ann RychlensXi
Public Affairs Specialist
U.S. EPA, Region II
Charles Tenerella, Chief
Central NJ Remedial Action
Section, U.S. EPA, Region :
Site History & Results of
Fereiial Investigation (HI)
Trevor Anderson, Project
Manager, U.S. EPA, Region I!
Bi/.c-.'ssicn of Feasibility Study
& Reredial Alternatives
William Moran, ICF Engineering
(EPA's consultant)
Presentation 01" Proposed
Remedial Alternative &
Final Sunr.ation
Charles Tenerella, Chief
Central NJ Remedial Action
Section, U.S. EPA, Region .'I
Questions & Answers
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Appendix D
Updated Information Repository List
-------
INFORMATION REPOSITORIES
FOR THE CINNAMINSON GROUND WATER CONTAMINATION SITE
Cinnaninson Township Municipal Building
1621 Riverton Road
Cinnaminson Township, NJ 08877;
Contact: Grace Campbell, Phone: (609) 829-6000
Hours of operation: Mon. - Fri. 8:30 a.m. to 4:00 p.m.
East Riverton Civic Center Association
2905 James Street
Cinnaminson Township, NJ 08077
Contact: Dorothy A. Waxwood, Phone: (609) 829-1258
Information available upon request
Cinnaminson Public Library
1609 Riverton Road
Cinnaminson Township, NJ 08077
Contact: Molly Conners, Phone: (609) 829-9340
Hours of operation:
Mon. - Thurs. 10:00 a.m. to 8:30 p.m.;
Fri. 10:00 a.m. to 5:00 p.m.; and
Sat. 10:00 a.m. to 5:00 p.m. (Except July and August)
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Appendix E
Superfund Update
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Super-fund Updat*-
Region 2
Cinnaminson Ground Water
Contamination Site
Burlington County, New Jersey
Miy 1999
INTRODUCTION
The U.S EnvironmentaJ Protection Agency CEP A)
is lisuir.g this update to bneOy summarize the
vanous remedial investigation and feasibility study
activities conducied at tlx Cinnaminson Ground
Water Con Lamination (Cinnaminson) Site from
19&5 10 date. For more detail regarding these
activities, interested citizens may review the
remcJ.al investigation/feasibility study reports at
the information repositories established for this
site. A list of the repositories is provided on the
last page of this update.
SITE BACKGROUND
The Cir.r.amirison site covers approximately 400
acres in the To*T.ships of Cinnaminson and Delran
in Burlington Counry, New Jersey. It includes
properties bounded by Union Landing Road,
Rome 130. River Road, and Taylors Lane (Exhibit
1). The sue cons is is of residential and light to
heavy industrial propenies. The Delaware River
is located about 5,000 feet northwest of the Site
and US Route 130 passes about 2,000 feet to the
southeast
Sand and gravel mining operations were conducted
in paris of the site in the 1950s while solid wastes
were deposited in previousry excavated mining pits
on-site. When mining operations discontinued
during the late 1960s, larger amounts of refuse
and solid wastes were deposited in the mining
pits.
Landfilling operations continued until 1981. The
landfill was permitted for use as a landfill to
dispose of municipal, industrial and institutional
wastes, sewage sludge, and food processing wastes.
The owner of the landfill, under agreement with
the NJDEP, implemented a closure plan for the
site in 1981. As pan of the closure: a {round
water monitoring program was initiated in 1981:
and in 1985, the landfills were capped with 18
inches of clay, and a gas collection and venting
system was installed. Landfill closure was
completed in July 1987.
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REMEDIAL ZNVLSTJCATION
In June 19S-!. the Cinnaminson Site was placed
on the National Priority List (>'PL) in response
to a ground water contamination problem in the
vicinirv of the Sanitary Landfill. Inc. (SLI)
propern located in Cinnaminson Township, New
Jersev
There uere several potential sources of ground
water conLarmnatiop detected at the Cinnaminson
site. Among these sources are two landfills, which
are operated b> SLI, and a number of surrounding
industries in the area. Eased on the results from
a quarterly ground water monitoring program
performed b> SLI. the EPA initiated a remedial
inves:ig3!ion in 1985. The remedial investigation
was performed to determine the nature and extent
of contamination and bo* conditions may affect
human health and the environment. A feasibility
study followed in 39S9 to identify and evaluate the
most appropriate technical approaches for
addressing site-reJated contamination problems.
Field activities were conducted between April 1985
and Ma;. 19&£ to: determine the source(s) of
con:ar.:r,ation; obtain a better understanding of
the hvdroeeology in the area; and identify the
types, qualities, and locations of contaminants.
Using data gathered from 87 monitoring wells, the
remedial ir.-.estigation identified the presence of
volatile organic and inorganic compounds in rwo
separate ground water aquifers. The remedial
investigation report was finalized io May 1989.
The fieid activities for the remedial investigation
included:
Field Surveys
Hvdrogeologic Investigation
Ground Water Sampling- and Analysis
Surface Water Sediment Sampling and Analysis
Potabie Welt Sampling
• Field Surveys
A field survey was conducted to prepare a site
propern map. topographic map. and base map of
sampling locations.
• Surfact Water Sediment Sampling and Analysis
The objective of this task was to identify
contaminants in surface water and sediments.
Surface water and sediment samples were collected
from retention basin.- as well as in Pompeston
Creek and Swede Ri Detected in surface water
samples were inorganic compounds, which
consisted of heavy metals and cyanide. Heavy
meials and two pesticides were detected in
sediment samples. Several volatile and semi-
volatile organic compounds were also found in
both sediment and surface water samples.
• Hvdrogeologic Investigation
The hydrogeologic investigation was conducted in
conjunction with a geophysical investigation to
determine the hydrogeologic characteristics of the
site and evaluate the extent of ground water
contamination. The investigation consisted of: test
boring; bore-hole geophysical surveys; drilling and
monitoring well installation; permeability testing:
and measuring ground water depth on monthly
intervals. Accurate elevations of ground water
were obtained and ground water flow directions
were developed.
Inorganic and organic contaminants were detected
in the regional aquifer, which underlies the site.
and also in the saturated perched zones, which lie
above the regional aquifer. It was determined that
the contaminated landfill leachate migrated along
the discontinuous clay layers in the unsaturated
zone and ultimately into the regional aquifer.
• Potable Hell Sampling
Twelve private wells, which were not serviced by
the public supply lines, were sampled to determine
whether contamination was present. Following
the analysis of the sampling, the potable wells
were resampled to verify the results. The results
showed that twelve metals, nitrate and one volatile
organic compound were detected. Nickel was
detected in two wells, and nitrate was detected in
one well. However, the only contaminants that
exceeded ambient water quality' standards were
nickel and nitrate.
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• Ground Water Sampling tod Analysis
Ground water qualify sampling and analysis was
conducted 10 determine the source (s) and extent
of grouni water contamination. Samples were
collected from previously installed, and newly
installed monitoring wells, to summary, the
hydrogeologic and ground water data indicated
thar the tuo SLI landfills are the major sources
of ground water contamination. The extent of
contamination appeared to be limited to an area
within close proximity of the two landfills and was
noi present south of US Route 130.
SUMMARY OF RESULTS
The remedial investigation report identified several
poicr.;;a! source* of ground water contamination.
The report concluded that the SL1 LandfilJ was
the major source of ground water contamination.
Del-Va'l Ink and Color. L A L Redi-MU. and
Hoeganae? Corporation were identified as other
possible sources. The potential ground water
cor,:arr;r.atior. sources on these properties include
an uRlined landfill, underground storage tanks,
unlined slurry pits, septic systems and cooling
ponis.
The ccr-iar.ir.ar.ts in the upper and lower zones
consis; of the voiaule organic compounds benzene,
eir,;.'benzene. 1.2-dichloroethane. xylenes,
chlorober.zene. irichloroe;hene, and vinyl chloride,
among others. Inorganic contamination includes
elements such as arvenic, beryllium, cadmium, and
cyanide. The contamination in the regional
aquifer flows in a south • southeasterly direction.
The contamination in the perched water rone
flows downward into the regional aquifer.
FEASIBILITY STUDY ACTIVITIES
The feasibility study focuses on identifying ani
evaluating, the most appropriate lechujcaJ
approaches for addressing contamination problems
that were identified at the site during the remedial
investigation. These alternatives are described IB
detail in the Proposed Plan and the Feasibility
Study report
FOR FURTHER INTORMATION-
Interested citizens may review the RemediaJ
investigation and feasibility study report or other
site related information at the following
information repositories:
Cinnaminson Township Municipal Building
1621 Rjvenon Road
Cinnaminson Township, NJ 08077
Contact: Catherine E. Obert (609) 8:9-6000
Cinnaminson Township Community Center
Manor Road
Cinnaminson Township, NJ 08077
Contact Catherine E. Obert (609) 8294000
East Rivenon Civic Center Association
905 James Street
Cinnaminson Township, NJ 08077
Contact: Dorothy A. Waxwood (609) 829-12iS
FOR FURTHER INFORMATION YOU MAY ALSO CONTACT:
Mr. Trevor Anderson
Remedial Project Manager
U.S. Environmental
Protection Agency, Room 711
26 Federal Plaza
New York, New York 10278
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.. , DiV> ylPtr
621 Fir Terrace
Pivertcr. , KJ CEO 7"
Vr. Trevrr 7-r.cerscr (609)629-7562
Feredial Project Var.acer
U.S. Er.vircr.rer.tal Protection *oer.cv
?c-c- 711
26 Federal riaza
Nev VcrV, Nev York 1C278
Dear *'r. Jr.iersor. ,
Th.ar.V vcu fcr this orpcrtur.itv to write ir. cer.-ents and ir.cu'*-ie =
pertair.ir.c to the cleanup cf the Superfur.c1. Fite at the dr. •": rf Trur.dvater c^r-
t a-: r.»ticr. ir. tu.e ares is a very real ccr.cerr,. Ur.f crtur.?telv , ^
VSF Arabic t~ atter.d the public reetir.r? rr. Vn\- 32 st ar'5 Tur*? 1
therefore, ! wrulr liVe tc sub~.it the frllovir.<~ rue^t: or. s •
vil! te selectee tr rr the ^vcr»i: clr-.--r.u-
2' *"-;t de~ s rf-er.t ( ? } ir. tue N.Trr vill he su*5r>rrtir.cr the rr.*
:r. t-:? 7le = -.u- ef'rrt?
/ v * e " " " r f s r. '.' ccc r d i r. * * i cr RT"cr. f '"." ~ T~ ' ? '''? t e r Pe scur c ~- ? * I 1 ^ r = *. i "~ ~
'' = r a rr.-'j - V'sste??, etc?
I '• r:-rc the- Tetrrleur ur.cercrrurr. strrare t^r.V
-------
Face 2
lOHcv r.sr.v callons of water per day will be taV.en frrr the 13i" veil?"'
IDKc-v rar.y fror. the ether seven wells reouired fcr the
i:)v'ill there be more wells needed fcr the recional aquifer?
13)v:-at influence will the draw fror. theee wells have or. the drir.V. ire
supply wells located 2 wiles south?
l.PA*? And who grants such a waiver?
23) -he EPA rP both preferred MM-5C. Does that fill the- r-euir
rent of f -eptance? Would there be any modif icatio-e to
this alte: -»-nd wou^c tne pactiic be notified.
24) Is the cost . cleanup fixed or will it escalate durinr the
3D year duration?
25)v-at affect «'oes the soil ccntarination at the SrvthwveVe
'development located at Church fc Forr.Adr.di.ic Rd= have en the local
drinking supply wells.
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P.M. vlrt2
621 rir Terrace
Pivertcr. . KJ C8077
Vr. Trevcr 7-r.cerscr. (609)629-7562
Peredisl 'reject .^ar.ac'er
U.S. Er.vircr.rer.tal Frctectior. *cencv
Poo- 711
2f Federal Flaza
J.'ev VrrV, Nev yery. 1C278
Dear "r. Tr.cersor.,
Thar.k vcu fcr this orncrtur.itv to write ir. ccr.-er.ts ar.d i~cu'-ie«-
pertair.ir.c to the cleanup rf the Superf ur.e. ?ite at the clr "er«pv.
r =- » r?": "" = -*• r* "r'vcrtT. !»r,^. thr evv-»-t r* <~rrur.c?vater c^r-
t a-: T.sticr. ir. the area is a very real ccr.cern. Ur.f crtur.?telv, *
VSF ur.ahlc to atter.d the cuhlic reetirr? or. Vnv 31st ar'5 T\;r** 1 a.rr
ther€rCT€, T voulr liVe to sub~.it the follovir^ rue?t: cr.s •
1' v.1-ir- cr—,ar." vill te selectee to ro the ~vrraH clr-r.--"
3' "•"•»t ce~»rt"~-er.t (?} ir. the N.TTr vill he su*2riortir.r the rr."
»\ ' c *i~!~: — c »r.'.' cocrcir. sticr. ar*cno *".*r.~~'F *'*?ter Peso'— rc^F, *Il^ra*'-"/"""
'' = r = --.--je' '.-rftste=, etc?
ur.dsr this riar., vher. vill thev he ?>crresser?
6! "ill tuere be a separate public heftrir.c"5
7) "ill there he acceo. copt? '.
6) 7ccorcirr tc Carp, Dresser & VcXee (C?") cor.tarir.atior i* • r. botw
the shallow ar.d regional (T~.V) apuifer. t-'hat do- you estirate the
core of in'luence tc be?
9) The ?-T euperfur.d site has rany c* the ?«rr>e ch«rpcteri«tics ard
bacXcrc-urd hirtrry «F the Perr-sau^er. Lanc'ill locateo. or. uivpr
-cac ir.cludir.r ••« sar.e contarir.a-. . Th» rerre--.:Vr.'r site i= ?!e~
su"-r"-sef tc ur.ct. • rer.ed: al cleanup as well. If there *r-.-
cccrcir.aticr. betv-.-:- '-.TH." and ~?^ pertair.-'-.c to the?e tv.-o sit*»5
If welfare reeded fcr the Per.r.sauVen site, vhat affect •ill these
veil? have cr. the Cir.nar.irsor. cleanup cr water surnly veil? i.r. the
a r e 5 "
...I/
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Mr. Trevor Anderson
U.S. E.P .: .
25 Federal Plaza
N.Y., N.Y. 1D278
June 1, 1990
Dear Mr. Ar.dersor. .
I live with EV wife and 4 children on Taylor's Fare at the feet of
"aylcr's Lar.e cr. the Delaware River in Cinnacinson, Hew Jersey.
Actable well along with 3 other potable veils that service our
irnediate re ig-.birs are ail within 1/2 mile of the Cinnaminson
grour.d-ater cer. tatir.at icn site that your agency is currently in the-
process cf cleaning up.
At a public meeting held at the Cinnacinson Community Center or.
Kay iI , IrrI, you asued for public coccent concerning the clear, up
process
1 :e=: very strongly that the E.P.A. should include our wells
alcr.e vit.-i all otner potable wells within a given radius in an ongoing
cor. itcrir.g zrerrac. Results of such monitoring should be mailed to all
resice-.ts oor-suting water froc potable wells within the monitoring zone
on a regular basis.
I assuce you intend to continue monitoring your own test wells.
Testing ar.c centering of the surrounding potable wells, at the sace
tir.e, would net be terribly expensive.
I leek forward to your response.
Very t
Jonathan ^d'ls'i's
Taylor's Lane
Cinnacinson, NJ 06077
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Pace 3
Jure 13, 1990
26]Vhat remedial action is planned for Sr.ythwycke? >nd how w:ll that
Cleanup effect both the Cinnar.inson project and the proposed
cleanup for Penr.sauken?
27) is there a grand plan or coordinating cffor to protect overall
health and welfare of our corrmnities in regards to all the
contaminated sites in the area (Cinn.,Fennsauken, Swope,etc.).
28)While I a.- in favor of the cleanup, what preventative treasures
will be taken to allow permanent recharoe to the e-ouifer without
further contamination?
29)wiil there be any restrictions placed on industrial growth or
housing developments inthe Tri-bcro area?
In conclusion, I hope a safe and effective procedure can be irple~.er.ted
ir. the very near future. I hope ve car. learn fror our past and costly
r:=ta--es ar.d that we have the wiscer-. and the courace to taV.e the
necessary action to develop the best and most responsible way of
harflir.r cur waste. Intense recycling ,corncstinc, source reduction,
v~e elirination of hazardous chericals ».nd most irpcrtartlv education
:= ±-e key to our success. It is ry opinion and that r* -»ny scientist
and .lav~aV.ers that incineration can only corrcunj. the prctle-s ve
r.rv f = ce in Suoerfund cleanups.
P.esr-ertfully yours,
...
cfcthv>'. Klctz
cc: Mr. Walter Engle
*'aor of Riverton
P:
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American Water Works 6ervice Co., Inc.
Eastern Region • 500 C'Ove Street • Haddon Heights, S) 08035
(609. S4'-3:n
A D Mz-:nc
1609 >»&;:>:
June 11, 1990
Ctr.Tinir. KAIL #P
RETURN RI3Z1FI REVESTED
Kr. Trevcr Anderson
Che".i cal/Er.vli uju::ca'i.
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SYLVIA E & JOSEPH H TAYLOR
KIVCK (IDE MOMCtTCAC PAftM
TAVtOIW LANE
July 12, 195C
Trevcr Andersen
26 Federal "?laza, Room 711
New YcrX, NY 1C2TS
Dear Trevcr Anderson:
relieving up cr. the .Key 31, 1990 meeting we both attendee at
the Cir.r.ari.-.ser. Township Co—unity Center, I wish to make the
AI : call en you and the federal EFA to include five wells
in your renitcring process. These wells are all within 1/2 mile
cf the site you are covering. They belong to and are user.
regularly fcr potable and household use by 30 or more adults and
children - memzers cf cur family and neighboring families. These
wells are located as follows on:
1 - Bloc< 2C1, Lot 2
2 - 51oc< 2C1, Lot 2
2 - Bloc< 2C1, Lot 4
-. & : - 5ioc.< 2C1, Lot 1.01
Note: Fcr two cf these wells I do have "Water Quality
Analyses" dated July 14, 1987:
FI::F.C NUMBER 9E6Cii2£
STATIC:; NUMBER 4oci450755936ci
STATIC:; NAME i
(probably Block 201, Lot 3)
CATE CF COLLECTION - 06-05-1986 1100
RECORD NUMBER 986009E1
STATION NUMBER 400147074593401
STATION NAME TAYLOR 2
(probably one of two on Block 201, Lot 1.01)
DATE OF COLLECTION - 06-05-1986 1515
Ei I call on you and other proper authorities to do all in
your power to get the owners of the landfill located between
Taylors Lane and Union Landing Road to pay a large share of the
cost cf ycur work. There is no reason for all of this cost to be
borne by taxpayers!
I trust you will be able to grant these requests. •
Sincerely yours,
A
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Kr. Trevcr Anderson
June II, 1550
Page 3
Trevor, cr.ce again, thanks for the opportunity to offer comments on this
remedial project for the Cinnaz.inson landfill and if you need any additional.
information or would like to discuss any of these items further, do not
hesitate to give ice a call. When you have developed a response to these
iters, please send then to me so that I cay review them with the
New Jersey-American Water Company staff.
Very truly yours,
A. D.
kc
cc: L. V. Erckav
K. T. Wragg
Kay:r Lavrer.ce Zleuteri, Cinr.air.inson Township
Ecrker Ka.-r.ill, KJDEP
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Kr. Trevcr Anderson
June 11, 1950
Page 2
at Chester Avenue next, to the municipal building and our two veils at Nev
Albany Poad, cur -two veils at Pomona Road, and our tvo veils at Steven's
Drive Station, ve most definitely have a significant impact on the deep
aquifer in that area. The vater levels that have been obtained from all
the existing monitoring veils do not reflect our true operation only an
effort by the vater company to modify its vithdraval pattern to minimize
the leachate of material from the landfill tovard its production veils.
These considerations must be vorked into a new model or revise the
existing greundvater model.
2. When the existing monitoring veils vere installed, PVC casing and
screening vere used. Because of the solvents present in the aroundvater.
ssme of the contamination detected from the sair.ples collected from these
r.rnitcTing veils may be influenced by the PVC casing and screen. All nev
rcr.itcrir.g veils should be constructed vith materials that vill not
influence the integrity of the groundvater sample.
Future CTsrericr.al Considerations
1. Because cf the nature of technology being utilized for the groundvater
cleanup and that the discharge from, the on-site treatment plant is going
t: te injected into the aquifer, Nev Jersey-American Water Company
requests permission to have access to the site for the purpose of
collecting samples of the vater being discharged into the aquifer.
I-'ev Jersey Department of Environmental Protection regulations require that
if treatment equipment is installed for the purpose of removing volatile
crganic compounds from vater, that monitoring be conducted tvice a month,-
en tvc- week intervals, to evaluate the effectiveness of the removal
process. Ve feel that this requirement should apply.
2. Since the quality of vater in the production veils of Nev Jersey-American
are free fr;m any volatile contamination, the quality of the discharge
vater from this treatment plant should be the same as the veils, or at
vcrst, reet the maximum contaminant levels as established by Nev Jersey
Department cf Ir.vircnmenthl Protection for potable drinking vater.
3. Although it is implied by the nature of this remedial action, no where is
it stat.ed that every effort vill be made to protect Rev Jersey-American
veils from future contamination nor what vill transpire vhen the
contaminant plume reaches these locations. Will Nev Jersey-American be
eligible for superfund cleanup money or remedial treatment of these veils
if the contaminant plume reaches the Nev Jersey-Aaerican veils prior to
the Tri-County Regional Water Supply Project coming on line?
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General Comments of Ford Electronics and Refrigeration Corporation
(FERCO) to the Proposed Plan, Final Remedial Investigation
Report, and Final Feasibility Study Report for the Cinnaminson
Ground Water Contamination Site in Burlington County, New Jersey.
1. FZRCO is not persuaded that a state ARAR exists that would
necessitate pumping and treating the "shallow aquifer". The
Proposed Plan, Final Remedial Investigatior, Report, and
Final Feasibility Study Report reference a "regional
aquifer" with perched water above flowing into it (lower
aquifer). Thus, much of the proposed remedy (MN-5C) which
includes pumping and treating the perched waters in addition
to the lower aquifer is unnecessary, wasteful, and not legally
required. If ground water pumping and treatment is warranted,
only the lower aquifer should be extracted for treatment.
2. Inadequate consideration appears to have been given to
"sell flushing" technology as a potentially quicker and more
ccst-effective remedy. Why install a comprehensive RCRA
performance cap, thereby entombing the wastes and limiting
leachate otherwise available for collection and treatment?
Allowing percolation of the waste could result in a more
effective remedy, since beneficial, natural chemical and
biological reactions would be enhanced.
3. The proposed remedy refers to chemical precipitation of
ir.crcanics. FERCO is unconvinced that the very dilute
levels indicated are treatable by conventional chemical
precipitation techniques. In addition, the inorganics
identified may not reflect other than naturally occurring
levels found elsewhere in the region. If the Remedial
Investigation indicates that the regional aquifer is
contaminated with organic constituents, that aquifer should
be extracted and treated for organics. Further complicating
croundvater treatment by also requiring chemical precipitation
of inorganics is not warranted.
4. The Proposed Plan assumes that the sludges generated by all
of the treatment options would be considered hazardous
waste and would have to be so managed for the duration of
remedial activities. The i-sis for this conclusion is not
indicated. FERCO disagree? ihat any such sludges would
necessarily be considered h .-ardous either as a listed waste
or by analysis as a characteristic vaste.
5. Inadequate consideration appears to have been given in
developing the Proposed Plan to implementing source-specific
remediation at sites, other than the Cinnaminson Landfill,
which are also contributing sources to the ground water
contamination. Other contributing sources should have been
given greater attention throughout the RI/FS process.
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0".:e c'
fore Mote' Cemci->
Pi'Kiiie Te»t'» w*i: Su'i
O^e cf«v«-c
Dti-oo-r. MieniQi* 48".2£
July 30, 1990
VIA FEDERAL EXPRESS
U.S. Environmental Protection Agency
Kev Jersey Remedial Action Branch
26 Federal Piaza, Room 711
New York, Kev York 10278
Atir.: Kr. Trevor Anderson
Cinnanonson Ground Water Contamination Site
Burlincrton County. New Jersey
Dear Mr. Anderson:
In respor.se to your letter of June 14, 1990, enclosed are
Fcri Electronics and Refrigeration Corporation's comments on the
Frcprsei Flan, Final Remedial Investigation Report and Final
Feasibility Study Report for the Cinnaminson Ground Water
Ccr.tar.inaticn Site in Burlington County, New Jersey.
If you have questions or need additional information, please
let re knov. I may be contacted by mail at the above address, by
telephone at (313) 322-1966 or by facsimile transmission at (313)
390-30E3.
Sincerely,
Robert E. Costello
Senior Attorney
rec/bg
enclosure
-------
Ge:ie-.-:e: :-:
s: c:. :
The Preferred Remedial Alternative does not meet the prirr.ary
re-5:ial objective, to protect public health and the environment.
Ground-water modeling and a review of available data indicate the*.
implementation of the Preferred Remedial Alternative would
actually increase the threat of human health effects an:
environmental damage.
Tne Preferred Remedial Alternative does not comply with the
stetutcry retirements for remedial alternatives listed in CEP.CL-
121,:}( •)(/}. Tne primary areas where the Preferred Remecie";
-"tST.ative is out of compliance with the statutory requirements
c»' CEP.ILA are summarized below:
Implementation of the Preferred Remedial Alternative will not
result in a significant reduction of contaminant
concentrations in either the shallow perched zones or the ??.v
Acjifer to acceptable levels during the implementation perio:
(30 years). In fact, water quality following the
implementation period will be degraded.
There are other significant areas of gro'und-water
contamination than the landfills contributing to ground-water
contamination in the Cinnaminson Study Area. The Preferred
Remedial Alternative does not address either the source areas
or the primary pathways of migration. Instead, the Preferred
Remedy focuses on so-called "hot spots" identified by the
USEPA RI.
Implementation of the Preferred Remedial A'tfnative will
result in an increase in mobility of contamination from other
sources. The increase In mobility wiV, be caused by spreading
the more highly contaminated ground water frc~ tr,e source
112
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ue:5e-.
7. CONCLUSIONS AND RECOMMENDATIONS
7.1
Tne USEFr Environmental Protection Agency (USEPA) conducted a remedia"
investigation (R!) and Feasibility Study (FS) of an area in Cinnaminscn.
N'e« Jersey bunded by Union Landings Road, River Road, Taylor's Lane, an;
r,:.:e 33C. The Cinnaminson Study Area encompasses approximately 400 acres
(l~^ re:*.c-es) end lies acprcxir.ately 5000 ft (1500 m) southeast of trie
!e"c-.£-e r.iver. The I'SEPA RI was performed by Camp, Dresser, anc M:Ke =
[IrHr]. Tne USEPA fS was performed by ICF Technology [1989]. Nur.erc-.s
£::-::c'ci site studies and investigations were performed from 19E3 to
:=:r. The results of the USEPA FS were summarized in the Proposed Pier,
for tr.e Cinnennson Study Area [1990].
--vices was asked by Sanitary Landfill, Inc. (SLI) to review the
.-c FS and other pertinent documents and to prepare a repcr:
. implementation of the Preferred Remedial Alternative, as
ces:-- in the Plan. The purpose of the study was to determine if the
'w5E:A r. an: FS were consistent with the CERCLA statutory requirements.
:re re:.-,re-.5nts set forth in USEPA RI/FS guidance documents; anc to
Ce'.erm:re if the Preferred Remedial Alternative would satisfy the primary
cr;:e:tive of .a remedial program [40 CFR 300.430(e)(9) (A)], i.e., to
protect hjmen health and the environment.
7.2 Conclusions
Eased on a review of available site data and information, and a review
of the USEPA RI, USEPA FS, and the Plan, GeoServices has concluded the
following:
111
-------
The present worth of the Preferred Remedial Alternative is
extremely high ($20,475,000) relative to the predicte:
benefit.
The Preferred Remedial Alternative does not address
contamination from the SLI northwest landfill. This is due t:
the improper assumption that site conditions at the northwest
and southeast landfills are similar.
• Tne Preferred Remedial Alternative will likely fail due to:
Increases in concentrations of organic constituents in tr.e
monitoring wells over time. These increases in contaminaticr
ray result from migration of highly contaminated ground water
fro" ether sources towards the recovery systems, or because of
tne inefficiency of the proposed recovery systems relative to
leakage from the landfills.
The remedial technology selected from treatment of orgar.ics
(biological granular activated carbon) is inappropriate fc"
sc~e of the primary organics in the contaminated ground wete-.
The crounc-water recovery system captures only a very srr.all
percentage (less than 2%) of the overall leakage from tr.e
landfill.
The Preferred Remedial Alternative is incapable of achieving
the remedial objectives for the Cinnaminson Study Area.
• •'•er sources of grcvd-water con;j-.ination have a sigmfica-t
• en the thret. rjblic health and the environment an:
we • ave a detri- ' effect on *he P'v'srrei RenicCia"
Alt, -:.
114
-------
Gesse-v-.ces >:
s: :: 2= -=::H;
areas to 'previously uncontaminated or less contaminated areas
of the aquifer.
• The screening, evaluation, and selection of the Preferred Remecia1
• Alternative was based on an inaccurate understanding of site
conations, geology, and hydrogeology. This lead to an
inappropriate evaluation of remedial technologies and selection of.
a remedial alternative which does not fit site conditions.
Ground-water quality will degrade over time if the Preferred
r.cTccial Alternative is implemented on the Cinnaminson Study Area.
• 7-1= Preferred Remedial Alternative consists of .remedial
tecnnologies, which are inappropriate for the study are-a. Other
technologies, which would be effective were not considered or were
eliminated during the screening process, as summarized below:
The treatment system, selected for the organics recovered from
groun: water (biological granular activated carbon) is not
appropriate for the organics in the study area.
It would be impractical and extremely inefficient to deploy
tr.e recovery wells as described in the USEPA FS.
The Preferred Remedial Alternative does not consioer the
beneficial impacts of the existing vapor extraction systems on
long-term water quality.
The Preferred Remedial Alternative does not consider the
beneficial impacts of biodegradation on long-term water
quality.
« The Preferred Remedial Alternative is an inefficient use of
available resources.
113
-------
Northwest Landfill and the other sources. The supplemental R!
vo'/ic include the following tasks:
Task 1 • Field Investigation: Installation and logging of 12
soil borings; installation, development, and sampling of II
new monitoring wells, and area-wide measurement of wate-
levels;
Task 2 • Halter Quality Sampling and Analysis:
sar.plinc of 11 new wells and 40 existing monitoring wells.
5 S.I monitoring wells, and 5 gas extraction wells, an:
analysis of ground-water samples for TCL * 30 arc
conventionals; and
Task 3 • Supplemental RI Report:
G-c-.'i-'h'eter Mcceling. Ground-water modeling would be perfer-.e:
tc evaluate the impact of the existing vapor extraction syster.s.
anc fciocegracation on long-term water quality. Recovery well
locations and depths would be evaluated in the shallow percr.e:
zones and the PRM Aquifer. Well locations would be selected tc
r.ex-i-ize recovery of contaminated ground water and to minimize the
potential of spreading contaminated ground water to previously
unaffected areaa of the aquifer. The impacts of the other sources
on the Alternative Remedy would be assessed.
Risk Assessment. The risk assessment would consist of the
following five elements:
data evaluation;
toxicity assessment;
116
-------
s:
The volume of discharge from the other sources may be
relatively small compared to the discharge from the two S-I
landfills. However, the mobility and toxicity of the gro-jr.d-
water contamination from the other sources is much hicr.er.
resulting in a major impact on the threat to public health ar.c
tne environment.
The Preferred Remedial Alternative does not take the other
soLi-ces into consideration. Since the recovery wells are
located outside the source areas, highly contaminated ground
water would be drawn from the other sources and spread ir.tc.
previously unccntar.inated or less contaminated parts of the
PRM Aquifer and the shallow perched zones. This condition
would likely be perceived as a failure of the Prefe^re:
Re-5Ciel Alternative.
7.2 Reco—
EiSri en the review of the USEPA FS, the Plan, and the supporting
c::j-er,ts and studies, it is apparent that the Preferred Remec-.ol
A": = T.£tive proposed by the USEPA is inappropriate for the Cinna-inscr,
Stucy Area. Ground-water modeling indicates that implementation of the
Preferred Remedial Alternative would actually increase the threat to tne
public health and the environment. An Alternative Remedy is needed which
is consistent with site conditions, geology, and hydrogeology, complies
with the remedial action objectives, and satisfies the CERCLA statutory
requirements. In order to select an Alternative Remedy which satisfies
tne above requirements, the following work must be performed.
• Supplemental RI. The Supplemental RI would provide the data
needed to refine the remedial alternatives for the SLI Southeast
Landfill, and select the remedial alternatives for the SLI
115
-------
Other Sources
shallow recovery wells, and
deep recovery wells (the number, locations, and depth c*
monitoring wells will be evaluated using ground-water
modeling, following the completion of the Supplemental RI).
The Focused FS would provide a detailed evaluation of tr.e
Alternative Remedy relative to the remedial objectives and tre
CE=.ILA statutory requirements. Risks associated with tr.e
Alternative Remedy would be compared to existing conditions arc
the Pre'erred Remedial Alternative. A Focused FS Report would be
P"=;ered with summarizes the results of the ground-water modeling,
risk assessment, and Focused FS. A conceptual design and detaile:
ccst estimate fcr the Alternative Remedy would be presented in the
Focuse: FS.
Fine": Design. Design drawings and construction specifications
w:."d be prepare: for the Alternative Remedy.
118
-------
Ge:le-.i:e: :-:
exposure assessment;
risk characterization, and
ecological assessment.
The risk assessment would be used in combination with ground-water
moceling and a focused FS to evaluate the impact of candidate
technologies, and to assure that the Al-ternative Remedy reduces
the threat to public health and the environment to an acceptable
level.
Focused FS. A focused FS is required to refine the Alternative
Re-ecy proposed for the SLI Southeast Landfill and to select
appropriate remedial technologies for the SLI Northwest Landfill
an: the other sources. The Alternative Remedy, which would be
evaluated in the focused FS, would consist of the following:
SLI Southeast Landfill
low-permeability cover system,
vapor extraction system,
shallow ground-water recovery well (number, location, and
depths to be selected based on ground-water modeling),
•• treatment system to be evaluated,
injection or discharge system (to be evaluated).
SLI Northwest Landfill
low-permeability cover soil,
vapor extraction system,
•« recovery and treatment systems (the need for a recovery
and treatment system will be evaluated after the mass
loading has been determined from ground-water modeling).
117
-------
SMC Envuonmental Services Group
A Subsidiary o! Saer.ce Management Corporation
900 W Valley Forge Road
PO Bex 659
Vcliey Forge Pennsylvania 1°4E2
Telephone 2.5 265 27X
May 8, 1990
Ref: 9524-89000
Mr. Frank A. Hamel, Jr.
Del Val Ink and Color, Inc.
1301 Taylors Lane
Riverton, NJ 08.077
1t
Subject; Review of Geraghty t Miller's Annual Reports
Dear Mr. Hanel:
Included with this letter is one copy of our review of
Ceraghty t Killer's 1983 and 1985 annual reports, which were
used as references by the 1989 Camp, Dresser & KcKee (COM)
report. This review is intended to be used as an addendum
to SKC's rebuttal to the CDM report, dated November 1989,
which you already possess.
The objective of our review documented in this letter is to
determine if CDM correctly interpreted information in the
Geraghty & Miller annual reports for use in their 1989
Cinnarsinson Landfill Study. We have determined that there
are alternative interpretations of the data that differ from
CDM1s. "
We vill be pleased to discuss the content of this section
should any questions arise.
Sincerely,
SMC ENVIRONMENTAL SERVICES GROUP
Peter D. Beyer ' ^ "V
Geologist
Richard M. Winar, CPG
Vice President
GeoEnvironaental Sciences Group
PDB:rm
Enclosures
9524:PBCL1J.WP
Fzr-erJy SMC Martin tec
-------
INK AND COLOR
INCORPORATED
June 1, 199
1301 TAYLOR'S LANE
RIVERTON. NJ 08077
Phone (Area Code 609) 829-7474
Penna. (Area Code 215) 671-1500
or Anderson
Prefect Xanager '
pates EPA
eera aza
:r.-., New VcrX 1C276
v.'e ar
e pleased to transr.it copies cf Science Management Corpora
the Carp, Dresser & KcKee FRI Report for Cinnar.insor. Groun
=-EE-:i-£5Jr , ar.= the referer.red Geraghty & Killer Report
:_r ocr.sultar.t ' s ccr.rlusior.s are as follows:
1. "It car. ce ccr.ciuded that there is no evidence presented
which cor.firr.s the conjectures stated several tines that
lei Val is a source of contamination" (Section £, Page 11;
2. "This consultant concludes that CDM statement is ir.isleadir.g
when it refers to Del Val as a possible minor source cf
ccntanr.ation since they have not first established the
presence cf an additional source of contamination downgradient
cf wells found to contain contamination" (Section 7, Page 1C)
es cf the consultant's report are enclosed for your use.
this independent consultant's report, Del Val is not a contamina-
e soil and not a party to the CERCLA clean-up process.
Val, however, urgently supports the clean-up efforts since its
value has been drastically reduced by SLI's actions.
Very truly yours,
DEL VAL INK & COLOR INC.
Frank A. Karr.el, J
President
Xr . :ir!< Ki-.ar, S.".:
-------
TABLE OF CONTENTS
Pace
1.0 INTRODUCTION 1
2.0 "' HYDROGEOLOGICAL REVIEW 2
3.0 GROUND WATER CONTAMINATION 3
-.
'/
4.0 AIR CONTAMINATION 10
5.0 CONCLUSION .11
6.0 RECOMMENDATIONS 12 .
9524:E?CV?J.KP
-------
REBUTTAL TO CINNAMINSON
GROUND WATER CONTAMINATION STUDY
FINAL REMEDIATION REPORT
Prepared for:
Mr. Frank A. Hamel, Jr., President
Del Val Ink & Color Inc.
1301 Taylors Lane
Prepared by:
SMC Environmental Services Group
900 K. Valley Forge Road
P. 0. Box 659
Valley Forge, PA 19482
November 1989
Ref: 9524-89000
9524-.IRCVPJ.WP
-------
2.0 HYDROGEOLOGICAL REVIEW
Based on our review of The Report, we generally concur with
its description of the hydrogeologic system of the study area.
Conclusions a-e in The Report (page 1-3) adequately summarize the
study area hydrogeology. It is important to point out that
although the regional ground water flows in a southeastern
*
direction (Figure 4-8 in .The Report), the mounding of the shallow
ground water under the landfills and the clay liners in the
"upper zone" of the Potomac-Raritan-Kagothy (PRK) formation have
caused the shallow ground water to (locally) flow radially away
frcm the landfill in all directions but at varying distances and
velocities. However, the shallow ground water (upper zone) will
eventually flow southeast and mix with the moderate and deep
ground water (lower zone). Shallow ground water flowing in
directions other than southeast as a result of the mound will
eventually reach the boundary of the zone of influence of the
ground water mound and will then change direction and flow
southeastward. Shallow ground water migrating on top of the clay
lenses will eventually reach a break or discontinuity in the clay
lens, migrate vertically down, mix with the lower zone, and
change direction to move southeast.
9524:ERJU'J.WP\2
-------
1.0 INTRODUCTION
This report describes a critique prepared by SMC Environ-
mental Services Group (SMC) for Del Val Ink and Color Inc.
»
(Del Val). The critique is of a 1989 report prepared by Camp,
Dresser & McKee Inc. for the U.S. Environmental Protection Agency
entitled "Final Remediation Investigation Report for the
'Cinnaninson Ground Water Contamination Study" (The Report). One
purpose of this critique-is identify and address any statements
cade in The Report which are unfounded, otherwise incorrect,
ar.d/cr unjustly detrimental to Del Val. The specific objective
of this report is to evaluate and discuss, if appropriate, all
negative statements made in The Report concerning Del Val.
9524:Z*?1J.WP\1
-------
TABLE 1
DIL VAL INK & COLOR INC.
Ground Water Analytical Results
Suasiary of Organics Detected
Concentrations (ppb)
Compound
»"Chloroethane
Acetone
1,1-dichloroethane
Trans-l,2-dichloroethene
1,2-dichloroethane
Benzene
Toluene
Chlorcber.zene
Ethylbenzene
Total Xylene
Dichlorofiuorcaethane
1,2-diethcxyethane
Di-isoprcpyl ether
Deeerier - 1986
CW-A6S GW-A6M
17
6 JBR
KD
NO
ND
5
1 J
6
8
14
ND
ND
ND
9 J
20 BR
28
2 J
10
31
1 J
7
10
7
8.1 J
22 J
5.6 J
July - 1987
GW-A6S GW-A6K
39
29
3 J
ND
ND
12
ND
11
29
27
ND
ND
ND
16
ND
59
2 J
17
50
ND
13
53
5
ND
ND
ND
Notes:
ND - Corpour.d analyzed for but not detected.
J - Estimated value. Reported value is less than the contract
req-jired detection limit but greater than zero.
R - Rejected. Compound did not meet QA/QC requirements.
B - Compound found in QC blank.
This Table was derived from data presented in The Report.
9524:ERTB1J
-------
3.0 CROWD WATER CONTAMINATION
Conclusion ID in The Report (page 1-5) states that, "It
appears that Del-Val Ink is also a source of ground water con-
t
lamination found in the Cinnaminson Study Area. However, based
on the marcher of compounds and their concentrations and the
nur±>er of wells found contaminated, it appears that Del Val Ink &
i
Color is only a minor source of ground water contamination found
in the Cinnaainson Study Area." The basis for this conclusion is
not stated. However, based on the data presented in The Report,
it say be surmised that this conclusion was reached after ana-
lyzing the results of two rounds of sampling from wells EPA-A6S
and EPA-A6K. These samples, from wells located on Del Val
property, were collected in December 1986 and July 1989. Results
of these sampling rounds are given on Tables 9-16 and 9-21 in The
Report.
Various constituents and their concentrations in the ground
water samples collected from GW-A6S and GW-A6H in December 1986
and July 1987 are given on Table 1. The organic chemicals
detected were chloroethane; acetone; 1,1-dichloroethane; trans-
1,2-dichloroethene; 1,2-dichloroethane; benzene; toluene;
chlorobenzene; ethylbenzene; total xylene; dichlorofluoromethane;
2,2-diethoxyethane; and di-isopropyl ether. There is data given
within The Report that suggests that all of these constituents
car. be attributed to sources other than Del Val. The following
statements suzaarize this supporting data.
t
9524:IRJUJ.WF\3
-------
GW-A6M is 13.25 ppb. The average reported concentra-
tion of total xylene in the samples from the veils
beneath the landfill is 394 ppb, with a qualifier that
total xylene was found in a QC blank. Further, The
Report does not suggest that Del Val is the source of
total xylene.
1,1-dichloroethane and 1,2-dichloroethane. - These
compounds have been detected in comparable or higher
concentrations in upgradient wells in both the upper
and lower zones of the PRM. Several examples of
upgradient ground water samples in which 1,1-
dichloroethane was detected include: Well C6S in
July 1987 with 440 ppb, Well C4M in July 1987 with
120 ppb, and Well C6M in July 1987 with 38 ppb.
Examples of upgradient ground water samples in which
1,2-dichloroethane was detected Include Well AIM in
December 1986 with 46 ppb, Well C6S in July 1987 with
230 ppb, and Well C6M in July 1987 with 84 ppb.
Average concentrations of 1,1-dichloroethane and 1,2-
dichlorcethane in samples obtained from the wells on
Del Val property are 23.8 ppb and 9.3 ppb, respec-
tively. Since these compounds have been detected at
'higher concentrations in upgradient wells, it is
conceivable that the source of these contaminants is
9524:IRRUiW?\6
-------
Acetone. - This compound is commonly detected in
environmental samples because of laboratory or field
contamination. This statement is supported on page 9-
33 in The Report - "Two of the sixteen compounds •
(methylene chloride and acetone) were also detected in
the field and trip blanks. Therefore, the presence of
these two compounds sight be due to laboratory or field
contamination. "
Benzene, toluene, chlorobenzene, ethylbenzene, and
trar.s-l,2-dichloroethene. - These compounds were
detected at comparable or higher concentrations in well
samples taken from beneath the landfill. Since the
landfill is located upgradient hydrogeologically from
Del Val, these compounds probably originated from the
landfill. This statement is supported on page 9-33 in
The Report - "Seven of the sixteen volatile organic
compounds (vinyl chloride, methlyene chloride, trans
1,2-dichloroethene, benzene, toluene, chlorobenzene,
and ethylbenzene) were also detected in the landfill
gas vent samples at comparable or higher
concentrations. "
Total xylene. - Total xylene was also found at higher
concentrations in well samples taken from beneath the
landfill (Table 9-2 in The Report) . The average
reported total xylene concentration in wells GW-A6S and
9524:ERR1J.WP\5
-------
Del Val property is 20.3 ppb. However, chloroethane is
also documented in The Report (page 2-1) as being
detected in a deep monitoring well identified in a
report prepared by Ceraghty & Killer Inc. Also,
Del Val has reported to SMC that they have never used
chloroethane. Thus, it is unlikely that Del Val has
been a source of chloroethane contamination.
Other items of concern with regard to ground water contami-
nation and Del Val are the following two statements made in The
Report. On page 9-36, The Report claims that, "Samples from
Wells EPA-A6S ft.nd.IPA-A6M, located in the vicinity of Del Val,
contained organic compounds (chloroethane, 1,1-dichloroethane,
1,2-dichloroethene, benzene, chlorobenzene, and di-isopropyl-
ether) that indicate that Del Val operations say be the source of
these contaminants." (Inclusion of "1,2-dichloroethene" on this
list is probably a spelling error since this compound is not
found in sarples from Well EPA-A6S and EPA-ABM; but, 1,2-
dichlcroethane was found in these veils.) However, the presence
of these organic compounds in the samples collected from the
veils on Del Val property, as discussed above, is more likely due
to migration from an upgradient source.
On page 9-60, The Report states that "But, other volatile
organic compounds (1-1-dichloroethane, 1,2-dichloroethane,
chloroform, trichloroethene, tetrachloroethene) detected during
Phase IA sampling as veil as in this sampling program in veils
-------
located upgradient to the north or northwest of the
Del Val property.
Dichlorofluoromethane, 1,2-diethoxyethane, and di-
isopropyl ether. - These compounds we:-e only detected
once, i.e., in Well GW-A6M in December 1986, and were
reported only at estimated concentrations. None of
these compounds were detected in the wells on Del Val
property in July 1987. Thus, these compounds should
not be of concern to Del Val. This statement is
supported in page 9-60 of The Report - "Some of the
organic compounds (dichlorofluoromethane,
diisopropylether} detected during the earlier Phase 1A
monitoring well sampling, which indicated that Del Val
Ink and Color could be a possible source of
contamination, were not detected in samples from
wells EPA-A6S and EPA-A6M during this sampling
program."
Chloroethane. - Excluding the veils on Del Val
property, this compound was only detected twice,
i.e., Well A1S in December 1986 at 55 ppb and Well C7K
in July 1987 at 2J ppb. The qualifier J means that the
magnitude of the reported concentration is estimated.
Well A1S is located upgradient and Well C7M is located
cross gradient from Del Val. The average concentration
of chloroethane in the samples from the veils on
9524:ERR1J.WP\7
-------
4.0 AIR CONTAMINATION
On page 5-13, The Report states that Del Val could be a
source of cethylene chloride contamination in air. Zt goes on to
say that methylene chloride was detected in air samples from two
of five sacple stations. The air sample from Station 3, on the
Del Val property, detected a aethylene chloride concentration of
3.49 eg/1. The air sample from Station 5 had a nethylene
chloride concentration of.16.03 ag/1. Without knowing the
prevailing wind direction, it is difficult to pinpoint the
possible source of aethylene chloride. However, contaminant
transport in air for a continuous source of contamination moves
frca points of high concentration to points of low concentration.
Thus, it is conceivable that Station 5 could be the source of the
aethylene chloride concentration in the air sample at Station 3.
9524:ERS1J.WP\10
-------
located close to the Del Val Ink Color Indicate that these
cor.pour.ds may be contributed by Del Val operations. Therefore,
Del Val is considered a probable source of ground water
contamination in the area." However, there is no evidence ••
presented in The Report which indicates that the presence of
these corpounds in the ground water is related to or caused by
Del Val operations. The on-site occurrence of 1,1-dichloroethane
and 1,2-dichloroethane have already been discussed in this
report. Chloroform, trichloroethene, and tetrachloroethene have
never been detected in any of the samples obtained from the wells
on the Del Val property. Further, these compounds have been
detected in sarples from upgradient wells. Thus, based on the
data presented within The Report, there is evidence which
indicates that Del Val is not the source of chloroform,
trichlcroethene, or tetrachloroethene contamination.
Also with regard to the area's ground water contamination
and Del Val, the consents made on conventional parameters
(pace 9-38) and total volatile organic contaminants (VOCs}
(page 9-60) in The Report should be noted. On page 9-38, The
Report states that three conventional parameters (TDS, ammonia,
and chloride) were detected in Well EPA-A6K at relatively high
concentrations, but were probably due to the landfill. On
page 9-60, The Report states that the source of the total VOCs
present in Well EPA-A6S appear to be the landfill.
9524:ZR*1J.WP\9
-------
6.0 RECOMMENDATIONS
To strengthen Del Val's position, SMC recommends the
following:
1. Conduct a Phase I Environmental Assessment as described
in Task 3 of the October 19, 1989 proposal.
2. Conduct an inventory of the history of organic
chemicals us'ed at Del Val. Based on this inventory,
perform a fate And persistence study on the inventoried
organic chemicals to identify their potential breakdown
components. This will confirm that the organic
chemicals of concern discussed in this report are not
breakdown products of the chemicals used by Del Val.
3. Conduct a review of the available Geraghty & -
Miller Inc. reports referenced in The Report.
9524:ZRRIJ.K?\12
-------
5.0 CONCLUSION
Based on the information within The Report and our review of
this data, it can be Concluded that there is no evidence
presented which confirms the conjectures stated several times
that Del Val is a japurce of contamination. All of the organic
contaminants identified in the ground water samples taken from
the wells located on Del Val property can more logically be
attributed to sources other than Del__VaJ. The aethylene chloride
contamination detected in the air sample taken from Station 3,
located on Del Val property can possibly be attributed to a
source other than Del Val.
•9524:ERR1?.K?\11
-------
7.0 REVIEW OF ADDITIONAL DOCUMENTS
7.1 Introduction
The 1989 Camp, Dresser & McKee report, which was reviewed
for Del Val, identified as major references the Geraghty & Killer
1983, 1984, and 1985 annual reports entitled, "Hydrologic and
Ground-Water Quality Conditions at the Landfill Operated by
Sanitary Landfill, Inc..Cinnaminson, New Jersey". Because of
their use as references,'an attempt was nade to obtain these
reports from the EPA and review then also. After filing a
Freedom of Information request letter, end after considerable EPA
delays, SMC obtained the 1983 and 1985 annual'' reports, but not
the 19S4 annual report.
Close inspection of the 1983 and 1985 reports indicated
that, other than the results of the laboratory analysis of each
year's ground water samples, there was little difference in
content, between the two publications. It was also discovered
.that the 1985 annual report contained the results of the
laboratory analysis of the groundwater samples from 1983 and
1984, as well as 1985. Based on these two findings, SMC decided
it would be sufficient to simply perform the evaluation of the
158:, »r.d 1985 annual reports and that it would not be necessary
to review the 1964 annual report.
9524:PBDVRJ.WP\1
-------
• SECTION 7.0
REVIEW OF ADDITIONAL DOCUMENTS
ADDENDUM TO
CAK?, DRESSER & MC KEE REBUTTAL
Prepared for:
Del Val Ink and Color, Inc.
1301 Taylors Lane
Riverton, NJ 08077
Prepared by:
SMC Environmental Services Group
900 W. Valley Forge Road
P. 0. Box 859
Valley Forge, PA 19482
May 1990
Kef: 9524-89000
9524:F3CVFJ.W?
-------
7.2 1983 Annual Report
Ceraghty & Miller state that there is both a shallow water
table aquifer, and a deeper artesian aquifer underlying the
landfill.
The ground water in the deep artesian aquifer flows
generally southward. The depth to the top of the deep, artesian
aquifer ranges from between approximately 30 feet to 50 feet
below ground surface.
The shallow water table aquifer was found to consist of
localized water zones perched on top of a clay layer. This clay
layer was found to be discontinuous along the northern and
southern boundaries of the landfill. This lack of continuity of
the clay layer indicates that ground water in the water table
aquifer probably flows only a short distance radially away fron
the landfill along the clay layer before it finds a break in the
clay end r.igrates vertically downward to join with the deep,
artesian aquifer. Therefore, the ground water in the shallow
water table aquifer flows in a direction away from the landfill
and towards Del Val. The presence of discontinuities in the clay
layer means that any contamination present in the shallow water
table aquifer should eventually enter the deep artesian aquifer.
The depth to the water table zones depends on what depth at which
the clay layer supporting the ground water is found. In general,
the depth to the water table aquifers ranges from between 12 feet
and ~2 feet.
£524:F3DVRJ.WP\2
-------
Each veil used for sampling the deep artesian aquifer has
the letter "D" on the end of its code designation (e.g.,'cM-SD);
whereas those wells used' for sampling the shallow water table
aquifer do not have the "D" (e.g., GM-8) in their title.
Geraghty & Miller's 1983 annual report also indicates that
Del Val's location, in regard to the deep artesian aquifer flow
direction, is cross-gradient to most of the landfill. Since
ground water flows in a downgradient direction, and south is
downgradient for this aquifer, this means that only the
southeastern portion of the landfill is considered to be a likely
area for recharge from any contaminated ground water that may
originate from Del Val. For this reason, wells in the
southeastern portion of the landfill were reviewed by SMC to
determine if ground water quality in this area was affected by
Del Val. A diagram of Del Val and the surrounding area is shown
in Figure 1. Ground water flow direction in the shallow water
table aquifer is generally perpendicular to the boundaries of the
landfill. Ground water flow direction in the deep artesian
aquifer flows in the southerly direction the arrows indicate.
Also, wells that are important for the characterization of ground
water quality near Del Val (GM-1, CM-ID, GM-8, GM-8D, GM-10) are
circled a'nd labeled.
7.2.2 1983 DeeT3. Artesian Aquifer Sampling Results
The report of Geraghty & Miller's 1983 ground water
sampling program indicates that contamination was being
9524:FEDVRJ.W?\3
-------
introduced into the deep/ artesian aquifer from a source north
«•
and upgradient of Del Val. Monitoring well GM-8D, the deep
aqruifer well located on the northern border of the landfill
approximately 500 feet north and up-gradient from Del Val, was
reported to contain benzene (252 parts per billion),
chlorobenzene (28 ppb), chloroethane (33 ppb), chloroform
(62 ppb), 1,1-dich.loroethane (485 ppb), 1,2-dichloroethane
*
(141 ppb), ethylbenzene (1,150 ppb), and toluene (2,930 ppb). By
contrast, monitoring well CM-ID, the deep aquifer well which is
directly downgradient of the Del Val property, contained a much
lower level of contamination: benzene (12 ppb), chlorobenzene
(32 ppb), chloroethane (31 ppb), and ethylbenzene (12 ppb). As
can be seen, monitoring well CM-ID did not contain any cor.pounds
that were not found in monitoring well GM-8D. However, many
compounds not found in CM-ID were present in GH-8D. If Del Val
were a source of contamination, new contaminants and higher
concentrations of contaminants would be expected in GM-8D. The
fact that this condition does not exist suggests that the main
source of ground water contamination for the deep, artesian
aquifer originates from a source upgradient of Del Val, and/or
even possibly upgradient from monitoring well GM-8D.
»
7.2.2 1983 Shallow. Water Table Aquifer Results
The water table aquifer monitoring well upgradient of
Del Val (GW-8J was not sampled in 1983, and therefore there was
9524:FBDVRJ.WP\4
-------
Figure 1
1983 Deep Aquifer Groundwater Flow Direction
(from Goraghly & MiHer, 1983)
tr uiACHir t HUH*, me
JA»IF»«T lANprtii. INC.
OIUKVAIION VlU
OF
tu*r«c(. IN mi
to MAN SIA um
I INI Or IQUAJ. U(*ATIM
0 or riiiomrMic .
C.Q IN ffll HtlAtltl TO NCAM
»CA UVfl
Landfill Boundary
rif VAIIOMS IN THE
/our ONOCtonrn ?r. 1091
-------
therefore no quantification of the amount of contamination
r
entering the artesian aquifer from upgradient could be made in
1584. Figure 2 shows the south-southeasterly ground water flow
direction (arrows) of the deep artesian aquifer and the location
of each of the above mentioned monitoring wells.
7.3.1 1954 Shallow Water Table Acruifer Sampling Results
The results,-of the 1984 shallow water table aquifer
sarpling program listed in the 1985 annual report indicated high
levels of contamination were still entering the landfill north
and upgradient of Del Val. The 1984 data states that GM-8, the
shallow water table aquifer monitoring well upgradient from Del
Val, "showed high (a total of 884 parts per billion)
concentrations of VOCs, primarily non-halogenated compounds
(benzene, toluene, xylene). The upgradient location of this
water table zone monitoring well with respect to the landfill
indicates the existence of upgradient off-site source(s) of
contamination.11 The complete list of compounds found in
monitoring well GK-8 includes benzene (192 ppb), chlorobenzene
(3C ppb), 1,1 dichloroethane (11 ppb), 1,2 dichloroethane
(17 ppb), ethylbenzene (575 ppb), and toluene (11 ppb). By
comparison, GM-10, which is the water table aquifer monitoring
well dovngradient of Del Val, did not report any of the above
parameters but did contain 13 ppb of chloroethane. The fact that
chloroethane was present in the downgradient well GM-10 but not
in the upgradient well GM-8 might suggest that Del Val could have
j
9524:F3DVHJ.KP\6
-------
no characterization of ground water quality of the shallow water
table aquifer up-gradient of Del Val in 1983.
Moreover, well GM-10, a shallow water table aquifer
nonitcring well downgradient from Del Val, contaii.-.d no
detectable levels of any volatile organic compounds. Since Del
Val is a user of several volatile organic compounds, the absence
of these compounds indicates that Del Val was not releasing any
of these cor.pounds into the ground water.
7.3 1984 Data in the 1985 Annual Report
As stated previously, SMC did not obtain a copy of Geraghty
& Killer's annual report for 1984. However, SMC did obtain
Geraghty & Miller's 1985 annual report which contained the
laboratory results froir. the 1984 sampling program and a short
text explaining these results.
Curing Geraghty & Miller's 1984 sampling program the water
levels in both the artesian and water table aquifers were
reported to have dropped to such low levels that several of the
monitoring wells on the landfill could not be sampled because
they were dry. Geraghty & Miller did sample two wells down-
gradient of the Del Val property (wells GM-10 and GM-1D) , but
only one of the wells upgradient from Del Val^ (well GM-8) .
•
Because the downgradient, deep aquifer, monitoring well (GM-8D)
was dry, no sample could be obtained from it. This means that
there was no analysis of the ground water from the artesian
aquifer upgradient from Del Val in the 1984 sampling program, and
952«:F3DVR7.WP\5
-------
been the source of this compound. However, after a coir.preher.sive
research of their past chemical purchases and inventories', Del
Val can positively state that they have never used chloroethane
in the plant (personal communication, A. Tobias). However, 'it is
also conceivable that the landfill itself may have been a source
of the chloroethane. In general however, these results show high
levels cf contamination upgradient of Del Val, but only low
levels of contamination -downgradient of Del Val. This again
suggests that Del Val was either only a very minor source of
contamination for the water table aquifer, or that there is a
discontinuity of the clay layer between Del Val and GK-1£ which
would allow for downward migration of contaminated ground water
into the artesian aquifer before it can be sampled at GM-10.
7.3.2 1984 Deep Artesian Aquifer Sampling Results
The results of the analyses of the ground water in the
deep artesian aquifer show that CM-ID, the artesian aquifer
monitoring well downgradient from Del Val, contained benzene
(14 ppb), chlorobenrene (37 ppb), chloroethane (40 ppb), 1,1
dichloroethane (15 ppb), ethylbenzene (26 ppb), and toluene
(21 ppb). Because GM-8D, the upgradient* artesian zone
monitoring well, was dry, the concentration of contamination
•
present.in the artesian aquifer upgradient of Del Val could not
be determined. Thus, for 1984, the origin of the ground water
contamination in the artesian aquifer cannot be determined with
certainty.
9524:?5DV3J.W?\7
-------
Figure 2
%
1984 Deep Aquifer Groundwater Flow Direction
(From Gcraqhly & Miller. 1984)
' cc-V
fIP|
MONitnniwr.HTM
B» CIIMCMIT • HUH*). INt .
Mrwiirwiwc vru
INSIM.UO ft OIMtM%
or cnouNi>-»Aici» now
— cr towAi Mff»4tvu nr»»t
-f.0""~ IMSWO KHIM IHHWO) IN Ull
RIlAIIVt 10 KAH SI A UVtl
.. «*tr»4tni tirvAtioN in rrn
m«tin to tc« «• uvu OATI»»
rirvAuox or wAitu irm w »«
row IN rrii
wiAim 10 HAM SIA itni
-------
1985 Deep Aquifer cffoundwater Flow Direction
(From Gcraghtv & Miller. 1905)
«m
•» CIMCMir t Nllll*. |«C.
ix i* rtn
«n*ti«t to (cwi «» itm
M«r*-it*n nt*«fiON n INT IOK.
MICSIM |0« |H mi NlMllt 10
icm MIIM
taiti wun-itm wrwnto «nmi
Hf-M IS OUIIIIONIWt.
Landfill Boundary
'- kfl
-------
7.4 1955 Annual Report
r
Geraghty & Killer's 19E5 sair.pling program was changed
significantly from the previous years programs. All five
ocr.itcring wells that defined groundwater quality upgradient and
downgradient of Del Val in 1983 and 1984 (CM-ID, GM-1, GM-10,
G"-8, and GM-8D) were either found to be dry or were not sar.pled
in 19£5.
However, two wells' installed in early 1985 yielded evidence
which again indicated that contamination was continuing to be
introduced into the deep, artesian aquifer upgradient of Del Val.
These two monitoring wells, designated DEP-1 and DEP-1D, are
located about 1,000 feet north and upgradient from the Del Val
property. Figure 3 shows the south-southeasterly direction of
deep aquifer ground water flow as indicated by the arrows, and
the location of wells DEP-1 and DEP-1D.
7.4.1 19S5 Deep Artesian Acruifer Sampling Results
The 1985 results showed that DEP-1D, the upgradient,
deep artesian aquifer monitoring well contained benzene
(327 ppb), chlorobenzene (405 ppb), 1,1 dichloroethane (208 ppb),
1,2 dichloroethane (186 ppb) and methylene chloride (88 ppb).
Although there were no wells downgradient of Del Val that were
•
sampled, the 1985 annual report states that, in general, for the
whole landfill area, "volatile organic compound concentrations in
dou-ngredie.-.t wells are one to two orders of magnitude lower than
in upgradient wells for the same species of organic compounds and
/
9524:?BDVRJ.W?\8
-------
data from wells that were installed after the time period covered
by Geraghty & Miller's annual reports. However, this Consultant
concludes that CDK's statement is misleading when it refers to
Del Val as a possible minor source of contamination, since they
have not first established the presence of an additional source
of contamination downgradient of the wells found to contain
contamination. There/are three reasons for this.
The first reason concerns the shallow, water table aquifer.
CDM states that water in this zone flows in the direction that
the clay layer upon which it is perched dips, which could be in
many directions. Geraghty & Miller states that the major
component of ground water movement in the shallow water table
aquifer is vertically downward with little lateral movement cff-
site. Both of these statements indicate that ground water in the
water table zone moves in a random direction and thus the source
of ar.y ground water contamination cannot be determined with
certainty.
The second reason concerns the 1984 and 1985 ground water
sampling program for the deep artesian aquifer. In 1984, no
artesian aquifer monitoring well upgradie.nt from Del Val was
sasplec. In 1985, no artesian aquifer monitoring well__dpwn-
gradient of Del Val was sampled. These two facts mean that a
concentration gradient for 1984 and 1985 could not be
established, end thus, for 1984 and 1985, no source of
9524:PBDVRJ.WP\10
-------
are probably all from the same source." This statement is based
en conclusions made on data collected in the western portion of
the landfill. Although it cannot be proven, Geraghty & Killer
suggests that this condition exists for the landf.'_l area as a
whole.
7.4.2 19S5 Shallow Water Table Aeruifer Sampling Results
As stated previously, the only water table aquifer well
in close proxir.ity to Del Val that was sampled in 1985 was the
upgradier.t monitoring well DEP-1. DEP-1 was found to contain
benzene (623 ppb), chlorobenzene (1,290 ppb), ethylbenzene
(1,360 ppb), methylene chloride (4.8 ppb), and 1,2 Trans-
dichlcroethene (60.5 ppb). These results again show that there
were detectable levels of VOC contamination in the area north and
upgradient of Del Val. Because no wells downgradient of Del Val
were sampled at this time, this sampling program cannot be used
to determine if either Del Val or the landfill was adding to the
contamination of the aquifer.
7.5 Conclusion
The data from all three sampling programs indicates that,
for the years 1583 through 1985, there was contamination present
in wells upgradient from Del Val. However, it is important to
*
note that Camp, Dresser, & McKee's (CDM) conclusions in their
1SE9 report were drawn from data collected in 1986 through 1989,
while the period covered by Geraghty & Miller's annual reports
v&s 19S3 through 1935. Additionally, (CDM) was able to draw upon
9524:F3DVRJ.W?\9
-------
RESPONSE TO
DEL VAL INK & COLOR COMMENTS
ON THE CINNAMINSON REMEDIAL
INVESTIGATION REPORT
prepared by
The U.S. Environmental Protection Agency
July 31, 1990
-------
contamination in the deep artesian aquifer can be determined with
certainty.
The third reason deals with the 1983 results of ground water
analyses for the deep, artesian aquifer. As stated previously in
this section, the upgradient well GM-8D recorded much higher
levels of contamination than well CM-ID, the deep aquifer
monitoring well downgredient of Del Val. This clearly states
that there is contamination entering the deep aquifer upgradient
of Del Val. However, the question of whether or not Del Val
contributed to this contamination as it moved under Del Val can
still not be answered because no rate of attenuation
(dissipation) could be calculated for the contamination reduction
between the upgradient and downgradient wells. If given enough
inforr.aticn, we can calculate a rate of attenuation over short
distances; however, we have insufficient data and cannot
determine if new sources have been added between the two points
where the contamination level is known.
9324:FBDVKJ.W?\11
-------
Page 2
Attachment
Subsections 2 through 5 (pages 5 through 7) address the possibility of Del
Val being a source of the folloving ground water contaminants: benzene,
toluene, chlorobenzene, ethylbenzene, trans-l,2-dichloroethane,
tctaluxylenes, 1,1-dichloroethane, 1,2-dichloroethane
dichlorofluororrethane, 1,2-diethoxyethane and di-isop:opyl ether.
Del Val Ink is not presently suspected to be a source of any of
these cocpounds.
Subsection 6 (pages 7 and 8 ) addresses the likelihood of Del Val being a
source of chloroethane found in the ground vater. The comment notes that
Del Val has reportedly never used chloroethane. The comment also compares
the average chloroethane concentration in the monitoring veils at Del Val
(20.0 ppb) vith the concentration in an upgradient monitoring veil (A1S at
55 ppb) and a veil cross gradient (C7M at 2J ppb).
The basis for the conclusion that Del Val may contribute
chloroethane has previously been presented (COM FPC, June 1990,
page 19) and is as follows:
o The concentration of chloroethane is higher in monitoring veil
A-6S than in A-6M. The higher concentrations in the shallov
aquifer suggest a local source. This pattern is in contrast
vith that found for the other chemicals found at the A-6
cluster. The other chemicals vere found in higher
concentrations in the deeper (semi-artesian aquifer) suggesting
a more distant source.
o Chloroethane vas not detected in veil C-6S upgradient of A-6.
This is in contrast to the other chemicals found at the A-6
cluster, vhich vere found in high concentrations at C-6S and
are believed to be from the landfill.
o Host of the other chemicals found in the A-6 cluster vere
detected in the landfill gas vent veils, vhile chloroethane vas
not.
The pattern of chloroethane contamination deviates fvom the
pattern of all the other chemicals found in that portion of the
site, suggesting a separate source. The higher level in A-6S
suggested a local source, ie, Del Val. It should be noted that
chloroethane contamination at other parts of the site is
attributed to the SLI landfill.
Section 4.0 (page 10} of the SMC report addresses air sampling conducted at
the site and states that vithout knoving the prevailing vind direction it
is difficult to pinpoint the possible source of methylene chloride. The
report also states that the source of contamination at Station 3 (Del Val)
could be Station 5 (SLI landfill) because the concentration at Station 5 is
higher than at Station 3.
(TV 26/17)
-------
ATTAriKENT
Section 2.0, page 2, addresses ground vater "Bounding" and perched water
conditions at the site. SMC Environmental Services Group (SMC) notes that
shallov ground vater flov is "(locally) radially avay from the landfill in
all directions but at varying distances and velocities" due to ground vater
mounding and clay "liners" of the Potomac-Raritan-Magothy (PRX) formation.
Carcp Dresser & HcKee Inc. (CDK) is no longer using the term
"mounding" to describe the conditions at the SLI landfill. There
is no evidence of mounding of the semi-artesian aquifer. As
stated in "Response to PRP comments, Cinnaminson Study Area,
Cinnan-.inson, Nev Jersey (CDM FPC, June 1990, page 7) perched vater
exists beneath and surrounding the landfill due to natural clay
layers and/or impermeable zones vithin the fill material itself.
Eovever, no conclusions regarding the distance perched ground
vater flovs avay froir the landfill or the velocity of such flov
vere presented in the RI report.
The flov of perched vater is independent of the ground vater flov
in the serti-artesian zone, hovever radial flov in all directions
outvard frott the landfill is not believed to occur. Perched vater
flov is more likely controlled by the dip of the clay layers.
(CDM FPC, June 1990, pages 7-9).
SMC uses the term clay "liners" in reference to the upper zone.
Only natural clay layers exist. These are Juiovn to be naturally
discontinuous (see RI fence diagram and CDM FPC, June 1990, page
5) and may have been removed by excavation in certain areas of the
landfill. Thus, they are not believed to be very effective as
liners. Eovever, SMC is correct in their statement that perched
ground vater vhich eventually reaches a break or discontinuity in
a clay lens vill migrate vertically dbvnvard, mix vith vater in
the lover (semi-artesian) zone and flov southeast vith regional
ground vater flov.
Section 3.0 of the SMC report refers to statements in the RI report
indicating that Del Val Ink & Color, Inc. (Del Val) is a source of ground
vater contamination. Six subsections of Section 3.0 are concerned vith
various chemical contaminants. Subsection 1 (page 5) states that acetone
in ground vater samples could be due to laboratory of field contamination.
Data validation criteria for common lab contaminants vere adhered
to (see CDM FPC, June 1990 page 12). The acetone found in both
the shallov and deep veil from the December 1986 sampling was
rejected. Hovever, the acetone concentration found in GV-ACS in
the July 1987 samples vas not rejected and is believed to
represent actual conditions. Therefore, Del Val is a possible
source of acetone contamination.
(TV 2B-17)
-------
JAV.E5 W BRADFORD JF.
August 25, 1990 . VICE PSES:DEN-AN: GENERA: co-'.;:_
Kr. Trevor Anderson
Remedial
U.S. Env:
Room 711
( Remedial Project Manager
U.S. Environmental Protection Agency
1 26 Federal Plaza
New York, New York 10278
Re: Cinnaroinson Groundwater Contamination Site
Dear Mr. Anderson
This letter sets forth in summary form the comments of
AFG Industries, Inc. concerning the proposed plan of
remediation for the Cinnaminson Groundwater
Contamination Site (hereinafter the "Site"). While AFG
Industries, Inc. desirous of protecting the public
health of area residents and persons coming in contact
with the Site, we do not believe it necessary to
effectuate the actions described as Alternative MM-5 in
the publication dated May 1990. It appears that
treatment of all groundwater will be the roost expensive
Alternative and likely unnecessary to actually protect
the public interest in question. Further, we believe
that implementation of Alternative MM-5 is contrary to
the National Contingency Plan.
We would suggest re-examination of the proposed
Alternatives and implementation of the least cost
Alternative necessary to protect the public health and
environment. AFG Industries, Inc. is not a contributor
to the contamination of or in any way connected with the
Site, but Bakes these comments as an interested citizen.
I request this letter be wade part of the Administrative
Record and that AFG be advised of any modification or
amendment to the remedial action proposed by EPA. Thank
you for your assistance.
Sincerely,
/ Jaaes W. Bedford .Air.
AFG Industries Inc.
r 0 SOA 929. K/.VCSPOnT. T£\\£SS££ 37662. (6J5, 229-7200
-------
Page 3
Attachment
CDM agrees that it is difficult to determine the source or sources
of methylene chloride in the air from the a-- . lable data.
Bovever, it should be noted that personnel conducting the field
activities notices organic vapor odors in the indoor air in the
Del Val plant, as veil as outside the plant building.
Section 5.G states that all ground vater contamination "can more logically
be attributed to sources other than Del Val".
It is CDM's opinion that chloroethane contamination found in veils
A-6S and A-6K, located on Del Val property can most likely be
attributed to Del Val, vhile chloroethane contamination found- in
other areas is not attributed to Del Val.
Section 7.0 revievs the 1983 and 1985 annual reports for Sanitary Landfill
Inc. by Geraghty & Miller (G&M), and discusses hydrogeological and ground
vater quality findings vith focus on the Del Val facility.
In general, the reviev conducted by SMC utilizes the ground vater
flov direction found by G&K. This has been documented to be
incorrect (CDK FPC, June 1990, page 4). G&M utilized CM-ID as a
se-i-artesian veil, hovever data obtained in RI indicates it is a
perched zone veil. Ground vater flov directions using vater
levels from GH-1D are skeved to the south. In addition, GH-8D is
also screened in the perched zone, although designated by G&.K as a
ser.i-artesian zone veil. The discussion of ground vater quality
and flov direction by SMC is based on the incorrect designation of
these veils as screening the semi-artesian zone. Any such
discussions of the semi-artesian aquifer including veils GM-8D and
CM-ID vill be misleading and incorrect as these veils actually
represent perched vater.
In addition, the discussion of GM-10 in section 7.2.2 and 7.3.1 is
misleading as the veil is referred to as dovngradient from Del
Val. This veil, as acknovledged by SMC, is vithin the perched
zone. No flov direction vithin the perched zone has been
determined, therefore its relationship to Del Val's location vith
respect to ground vater flov is unknown.
(TV 25/17)
-------
WASHINGTON. D.C
NEW YOPK. NEVr
HAP.P.IS* JPC
WP.ITC*'S DIP.CCT NUMBER
PEPPER, HAMILTON & SCHEETZ
ATTORNEYS AT LW
3OOO TWC LOGAN SOUAP.C
EIGHTEENTH & APCH STP.EETS
PHILADELPHIA. PENNSYLVANIA i0iOJ-27»9
z is-»e i-*ooo
FAJC: 2 IS-B8 I •* 7 SO • TWX:' 7 IO-«7O-O777
DETPC'T. M.Ci" ISA K
LOS ANGELES. CAL'ro*N,A
• CPWYN. PCNNSILVAN. A
WILMINGTON.
LONDON . E
(215) 981-4255
July 27, 1990
U.S. Environmental Protection Agency
New Jersey Remedial Action Board
26 Federal Plaza, Room 711
New York, NY 10287
Attn: Kr. Trevor Anderson
Re: Cinnaminson Ground Water Contamination Site
Dear Mr. Anderson:
As reflected in Katherine Laird's letter of July 23, it
appears that Chemical Leaman has been incorrectly identified as a
potentially responsible party at the Cinnaminson Ground Water
Contamination Site. Chemical Leaman does have some limited
comments regarding the Proposed Plan, however, which it would
like to add to comments of other parties.
It is our belief that inadequate consideration has beer,
given to use of soil vapor extraction. Additionally, it does
appear that volatiles are the agency's concern. Volatiles have
been effectively dealt with through bioremedial techniques at
other sites.
As you nay know, by October 18, 1989 memo, Jonathan
Cannon, then Acting Assistant Administrator of EPA, warned
against the full scale implementation of pump and treat as
recommended in the Proposed Plan. That memo, a copy of which is
attached, recommends a phased approach to pump and treat and
'equal detail* to alternative remedies (see pg. 5).
Additionally, he recommends obtaining additional data to better
assess the likely response of ground water to extraction. I
-------
BALLS, INC.
or .
Plant Union Landing Ro.d . Box 201, RJverton, N. J. 08077 . Phone: 609-829-1505
June 23, 1990
I". S. Environmental Protection Agency
'.'. J. ,-er.edial Action Ergnch
26 Federal Flaza, Ho DC 711
:;sv.- York, ?;.Y. 1027?
Att. Kr. Trevor Andersen
F.e : The Cinnar.inson Ground Water
Contamination Site in Bi;rlir.gto:
County, v. J.
3ear }.r. Andersen
Cur r»ro:5erty directly adjoins the Sanitarv
l=rdf;ll az the verv end of Grinding Eals Lane.
.-.en we fcui.t our plant ;5 years ago the level of the landfill
lant
v.'as arcut 2" ft. below the norr^l contour of the land in this
area. T-'.e area south cf us vss still a sand hole, containing
sor.e v.'ster - J s'.cpose around v.-fter. No water v;as available
fcr « surface v;ell a"d ve were advised bv Artesian veil
dri_.ers tn=t no water w=s available in deeoer areas. This
•• = = torr.e cut when Futlis service Electric f< Ga? Co. tried
drilling ncrth of us and south of us with no result. '•>
•alloed t:.er. to t=p into our line running to Union Landinr
road vr.rre city water is available.
L'ur riant has no underground tar.KS and does not discharge any
toxic .materials above or below ground - with one exception-
fcr c-ur toilets.
; doutfc if you tre ever going to get good clean ground
water in tr.is area as long as it co-r.ingles with the
landfill zround vater.
V,re have .heard ir.sny stories about trucks entering the
landfill at night and duiriing loads, undoubtlv toxic. I have
never witnessed this but it car-e fron those living on
! nion Landing F.oad.
CS..1 re if J car. be cf any further help.
Sincerelv,
aroa J. '.-.'inkeisp'-cnt, Pres.
-------
- -v"- S"A"SESviRCS^EN7Ai.*BCTE:- 0* AGENCY
; AAS-SS-OS = C ;:is:
:CT I 8 1989 Directive So
?_ s ~ '
S'.'B.'ICT: Considerations ir. Crou.id Water Rer.ediaticr. at Su=er:_
/•
F?.:M: Jcr.arf.a.-.'ti. winner.
ActJ.-.s Assistant Adr.i.-.istratcr
i
TC : «aste Ma.-.ager.er.t Div;sisr. Directors
r.e^icr.s i, :v, v, v:, v::. v:::
E.r.erce.-.cy a. id R«r,ei;ai Respcr.se rivisicr. Director
Resicr. II
Hasaris.s Waste Ma.-.aqer.er.t S:visisr. Directsrs
Seqien III, IX
Hazardous Waste Div;s;cr. Cirertsr
Region X
Purpose •
T.w.e purpose cf t.Ms aer.orandur, is to transr.it our findir.os
fror. a recently completed study cf several sites where grsur.a
water extracticn is being conducted to contain or reduce levels
contaminants in the ground vattr. In addition, this nescrar.c'-r
presents several recommendations for modifying the Superfund
approach to ground water remediation.
The "aoit co&aon method for restoring contaminated ground
water is extraction and treatment of contaminated ground water.
Recent research has suggested that in nany cases, it may be r.ore
difficult than is often estimated to achieve cleanup concentrat . :-
gcals in ground water. In response to these findings, the Off. re .
Esercer.cy and Remedial Response (CERA) initiated a project to
assess the effectiveness of ground water extraction systems ir.
achieving specified goals. Nineteen case studies were developer
fr^ asong Superfund and State-lead sites, RCRA and Federal
facilities. These sites were selected primarily on the basis va'
the ground water extraction systems had been operating for a per.
of tise sufficiently long to allow fcr an evaluation of the sys-.s-
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PEPPER. HAMILTON & SCHEETZ
U.S. Environmental Protection Agency
Page 2
July 27, 1990
would suggest that the Proposed Plan be reviewed with M:
Cannon's comments in mind.
Sincerely,
I
Philip L.' Hinerman
PLH/bab
cc: Robert Shertz
Katherine K. Laird, Esquire
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Environmental Research Ir.f crr.at ion TTS 6e4-":5: cr 151:, 5€9-
7-= fi.-c:.-gs cf the study sucstantiate previous researcr. a.-.c
rc-.f.rr t.-.it ground water remediation is a very new, complex
'r'.elc. Eased on tr.is study, I am. recommending consideration cf
certs..-, factors and approaches in developing and implementing
rround water response actions. The ma;cr recommendation .s tc
crient cur tr.in/cing so that we initiate early action on a small
scale, w.-.ile gathering, mere detailed data prior to committing t:
full-scale restoration. These recommendations are consistent
with the Guidance on Remedial Actions for Contaminated Ground
water at Superfund Sites and do not alter Superfund's primary
oca! of returning ground water to its beneficial uses in a time
frame that is reasonable given the particular site circumstances.
The recommendations do, however, encourage the collection of data
tc allow for the design c'f an efficient cleanup approacn that
-ere accurately estimates the time frames required for
remediation and the practicability of achieving cleanup goals.
While standard procedures for the more refined data
collection techniques suggested below are being developed, it
will be beneficial at most sites to implement the ground water
remedy in stages. This might consist cf operating an extract.c-.
system on a small scale that can be supplemented incrementally = £
..-formation on aquifer response is cctained.
These recommendations are described further below. The
2ttac.-ed flow en art illustrates how the recommendations fit into
tne 5.per fund ground water response process.
Recommendation l: Initiate Response Action Early.
The bias for action should be considered early in the site
management process. Response measures may be implemented to
prevent further migration of contaminants if they will prevent
the situation from getting worse, initiate risk reduction, and/or
the operation of such a system would provide information useful
to the design of the final remedy. Because the data needed to
design a ground water containment system are often more limited
than that needed to implement full remediation, it will in a
number of cases be possible and valuable to prevent the
contaminant plume froa spreading while the investigation to
select the re=ediation systea progresses. The determination cf
whether to implement a containment system should be based on
existing information, data defining the approximate plume
boundaries, hydrologic data, contaminants present, and
approximate concentrations, and best professional judgment.
Examples of situations where this type of action will probably be
warranted include sites where grcur.i water plumes are migrating
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t = -ect :ve
Tr.e ct;ective cf tr.is -er.cr2.-i>.- is tc iescr;re t.-.e fi-c.-=
::" •:.-..s st.cy arc tc recc-.-e.-.c tr.e CCT.S lierat: cr. cf cert a:-.
ractcrs a.-.e acrrracr.es in cevelcri-.g, and irp It • er.t ir.s rrcl-c -*-
rssrc-ss scc.crs at S-perfur.d sites.
Several trends were :der.t;f;ei frcr. tr.e case st-d:es:
z T.w.e extracticr. systems are generally effective ;r.
cc-.tair.ir.g ccr.tar.i.-.ar.t plur.es, tr.us preventi.-.g f.rt.-.er
-iijratic-n cf ccr.ta.r.inar.ts.
c Sicv.ifica.-.t r.ass rercval cf ccr.tar.ir.ar.ts 'up .tc i;:.:::
cc.r.is ever tr.ree years) is ceir.g acr.ievec!.
c Ccr.ce.-.trat:cr.s cf ccr.tar.ir.ar.ts have generally cecresse
s;cr.:f icantly after in.it:at:cn cf extract;cr." c.t nave.
ter.cei tc level cff after a pence! cf tir.e. At t.-.e s.
exar.inec!, tr.:s leveling cff usually began tc ccc.r at
ccrcentraticns accve tne cleanup gcal ccncentraticr.s
expected -.c have teen attained at tftat particular cc.-
in ti.r.e.
c Cata ccllecticn was usually ret sufficient tc fu.l.
assess ccntar.inant r.cver.ent and syster. respcnse tc
extracticn.
Several factcrs appear tc te lir.itir.g the «?ftectiveness ::
tr.e extracticn syster.s exar.in«d, including:
o Hydrogeological factcrs, such as tht h«t«rogeneity cf
s'_tsurfac«, the presence of low perseability layers, i
t.w.e presence of fractures;
c Contaain«nt-related factors, such a* sorption tc tne
soil, and presence of non-aqueous phase liquids
(dissolution from, a separate non-aqueous phase or
- partitioning of contaminants from the residual r.cn-
aqueous phase};
o Continued leaching from source areas;
c Systes design parameters, such as punping rate, scree-
interval, and location of extraction wells.
The report suanarizing the study and findings, entitled
Evaluation of Cround Water Extraction Resedies is attached.
Additional copies of the report are available through the Pur:.
Information Center ((202) 382-2080) or the Center for
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the remedy may reveal that it is technically impracticable ts
ac.-.ieve health-cased concentrations throughout the area of
attainment, and that ar.ctr.er remedy cr a ccntir.ge.-.t remedy may re
r.eesed.
where sufficient information is available to specify an
alternative cr ccr.tir.ger.t remedy at the time of remedy select:;-..
t.-.e ?.:: should discuss the contingency in equal detail to the
?nr.ary remedial option, and should provide substantive enter.2
ry -•.rich t.-.e Agency will decide whether or not to implement tr.e
contingency, £ee Interim Final Guidance on Preparing Superfur.i
reris.cn Documents, CSVER Directive 9355.3-02 (May 1985), at pace
5-ir.1 The ROD r.ay also discuss the possibility that an ARARs
waiver will be invoked when MCLs or other Federal or State
standards cannot practicacly be attained in the ground water; a
written waiver finding should be issued at the tir.« the
contingency is invoked, cr in limited circumstances, in the RC-2
.tself.*
The pur lie should be informed of the decision to invoke the
contingency (and, pernaps, the waiver) through issuance of an
Explanation cf Significant Differences (ESD) which involves a
public notice. A fcrr.ai public constnt period is not required
when a decision is sade to invoke a contingency specified in the
SCD; however, the Region may decide to hold additional public
ccTjr.er.t periods pursuant to NCP section 300.825(b) (propcsed)
Cec. 21. 15S3, 53FR at 51516). In any tvtnt, the public may
suint ccr.r.ents after ROD signature on any significant new
infcrrr.aticn which "substantially support^s] tht nttd to
significantly alter the response action" NCP Section 300..825(o
(proposed;.
There r.ay also be situations where the Region finds that it
is impracticable to achieve the levels stt out in tht ROD, but no
contingency had been previously specified in tht ROD. In such
cases, a RCD amendaent would bt ntcessary to docuatnt fundamental
changes that art aadt in tht remedy based on tht information
gained during iapleatntation; an ESD would bt necessary to
1 For instanct, tht ROD aay providt that a eentinqtnt
remedy will bt iapltatnttd if there is a Itvtlling-off.of
ccntaainant concentrations dtspitt continued ground wattr
extraction ever a stattd ptriod of timt.
2 It may bt possible to invoke a waivtr at tht tiat of ROD
«icr,ature (a "contingent vaivtr") vhtrt, for txaaplt, tht ROD is
detailed and establishes an objtctive Itvtl or situation at whic;
the vaivtr would bt triggered. However, tht ust of contingent
waivers should only bt considtrtd on a cast-by-cast basis after
discussion with OER£\OWP£.
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rscirly (e.g.. r.igr../ per-earle aquifers, m.coile oontan..-»-1s
;:ts-tial migration tr.crc.gr. fractures, and sites r.ear dri.-r --
-iter wells t-.at are sctertia.ly affected oy tr.e plume. " ~
A =errri :f "ecision •?.::,• for an interim remedy mav re
preoirrc w:tr. » limited evaluaticn cf alternatives tf.at ccmoares
:r.s ir.v».-.t»css cf taxing an early action to tr.e possible
rs-ifiratirrs cf waiting until tr.e investigation" nas seer.
::-rlet5r. The evaluation cf this.action sr.culd ce included >s
part cf tr.e scoping pr.ase fcr tr.e site and if determined to ce
apprrpriate. implemented ..-.lie tr.e overall RI/FS is under--av.
Tr.e .=.: r£ fcr tr.e final action at tr.e site sr.ould continue ar.o
incorporate information gained from, this early action. If »
containment action is implemented, tr.e ground water flow sr.o».o
re monitored frequently, immediately before, during, and
immediately after initiation of tr.e action to cctain inforr.at.z-.
or. system n spcr.se.
It is alr;o .advisable to implement ground water remediation
systems in a staged process at sites where data collected d_n-z
t.-.e re.-eoial investigation did not clearly define the' parameters
necessary to optimize system design. This might consist of
.-stalling an extraction system, in a highly contaminated area arc
reserving tr.e response of tr.e aquifer and contaminant plume
during implementation of the remedy. Based on the data gatr.ersr
during tr.is initial operation, the system could be modified a.-:
expanded as part cf the remedial action phase to address tr.e
entire plume in the most efficient manner.
Fecoarendation 2: Provide Flexibility in the Selected Reaedy -.o
Modify the Systea Based on Information Gained During Its
Operation.
In many cases it may net be possible to determine the
ultimate concentration reductions achievable in the ground water
until the ground water extraction system has been inpleaented ar.o.
monitored for soae period of tiae.: Records of Decision should
indicate the uncertainty associated with achieving cleanup goals
in the ground water.
Ih'general, RODs should indicate that the goal of the action
is to return the ground water to its beneficial uses; i.e.,
health-based levels should be achieved for ground water that is
potentially drinkable. In seae cases, the uncertainty in the
ability cf the raaedy to achieve this goal will be low enough
that the final reaedy can be specified without a contingency.
However, in nany cases, it may not be practicable to attain that
goal, and thus it say be appropriate to provide in the ROD for a
contingent reaedy, or for the possibility that this may only fee
an interia ROD. Specifically, the ROD should discuss the
possibility that inforaation gained during the iapleaentation of
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that protection is being maintained at the site will take place
at least every five years.
Recommendation 3: Collect Data to Better Asses: Contaminant
Movement and Lifcely Response of Ground Water to Extraction.
In addition to the traditional plume characterization data
r.crmally collected, the following data is of particular
importance to the design and evaluation of ground water remedies
ar.d s.-.euid be cer.sidered in scoping ground water RI/FSs.
Assessments of contaminant movement and extraction effectiveness
car. be greatly enhanced by collecting more detailed infcrmaticr.
en vertical variations in stratigraphy and correlating this te
contaminant concentrations in the soil during the remedial
investigation. More frequent coring during construction of
mcr.itcnng wells and the use of field techniques to assess
relative contaminant concentrations in the cores are methods thai
may te used to gain this information. More detailed analysis sf
ccntaminant sorption to soil in the saturated zone can also
previde the basis for estimating the time frame for reducing
contaminant concentrations to established levels and identifying
the presence of r.cr.-aquecus phase liquids. Cores taken from
depths where relatively high concentrations of contaminants were
identified might be analyzed to assess contaminant partitioning
between the solid and aqueous phases. This might involve
measuring the organic carbon content and/or the concentration ::'
tn.e contaminants themselves.
The long-term, goal is to collect this information during t.-e
?.I so that, mere definitive decisions can be made at the ROC
stare. Standardized sampling end analytical methods to supper-.
these analyses are currently being evaluated.
For further information, please consult the appropriate
Regional Ground Water Forua member, Jennifer Haley et
FTS 4T5-67C5 or Caroline Roe et ITS 475-9754 in OEM's Hazarde-s
Site Control Division, or Dick Scalf at the Robert S. Xerr
Environmental Research Laboratory (FTS 743-2308}
Attachse,nt,: Flow Chert
Summary Report
cc: Superfund Branch Chiefs, Regions I - X
Superfund Section Chiefs, Regions I - X vo/suaaary report
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document significant tut non-fundamental changes in the remedy
case: on the additional information.
For sites where there is substantial uncertainty regarding
the aoility of the remedy to return the ground water to its
re.-.ef.cial -ses (e.g., dense non-aqueous phase liquids in
fractured cedrccfc) it is appropriate to indicate that the initial
action is interim with an ultimate remedy to be determined at
scm.e specified future date. The action should be designed to
achieve the basic goal and carefully monitored over time to
determine the feasibility of achieving this goal. In many cf
tr.ese cases, this can only be determined after several years cf
operation. The five year review may be the most appropriate time
to maXe this evaluation, when sufficient data have been
collected to specify the ultimate goal achievable at the site
(e.g., first cr second five year review), a final RCO for ground
water would be prepared specifying the ultimate goal, includinc
anticipated time frame, of the remedial action.
Although overall system parameters must be specified in the
=.:T, it is usually appropriate to design and implement the grcurc
water response action as a phased process. An iterative process
cf system operation, evaluation, and modification during the
construction phase can result in the optimum systea design.
Extraction wells might be installed incrementally and cbser.-ei
for c.-.e to three months to determine their effectiveness. ?.-..=
will help to identify appropriate locations for additional we..s
and can assure proper sizing of the treatment systems as the
ranoe cf contaminant concentrations in extracted ground water .5
ccr.firr.ed.
If it is determined that some portion of the ground water
within the area of attainment cannot be returned to its
beneficial uses, an evaluation of an alternate goal for the
ground water should be made. Experience to date on this phase ::
ground water remediation is extremely limited and more defir.it.-. e
guidance on when to terminate ground water extraction will be
provided later. When the point at which contaminant
concentrations in'ground water level off, however, this should re
viewed as a signal that some re-evaluation of the remedy is
warranted. In many cases, operation of the extraction system c-
an intermittent basis will provide the most efficient mass
removal. This allows contaminants to desorb from the soil in t.-.e
saturated zone before ground water is extracted providing for
r.sximux removal of contaminant mass per volume of ground water
removed.
Ground water monitoring should continue for two to three
X«srs after active remediation measures have been completed to
ensure that contaminant levels do not recover. For cases where
contaminants remain above health-based levels, reviews to ensure
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Attachment 1 - PRPs List
Airco Industrial Gases
Division of BOC Group, Inc.
575 Mountain Avenue
Murray Hill, New Jersey 07974
Attn: Mr. Frank J. Dux, Manager
Environmental Affairs
Mr. James P. O'Donnell, President
Bass Transportation Co., Inc.
P.O. Box 391
Old Croton Road
Flemington, New Jersey 08822
Mr. Frank A. Homel, Jr., President
Del Val Ink & Color, Inc.
1301 Taylors Lane
Riverton, New Jersey 08077
Mr. Harold J. Winkelspecht,
President & Chairman
Grinding Balls, Inc.
Union Landing Road
Box 201
Riverton, New Jersey 08077
Mr. Jan A. White, President
Hoeganaes Corporation
River Road & Taylors Lane
Riverton, New Jersey 08077
Mr. Robert E. Costello
Senior Attorney
Ford Motor Company
Park Lane Towers West
Suite 401
One Parklane Blvd
Dearborn, MI 48126
Mr. Frank J. Quirus, P.E.
Regional Superfund Coordinator
Waste Management of North American
Northeast Region Office
Three Greenwood Square
3329 Street Road
Bensalem, PA 19020
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