United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-83/002
November 1983
Superfund
Record of Decision:
Burnt Fly Bog Site, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R02-83/002
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION:
Burnt Fly Bog Site, NJ
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT ANO PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Burnt Fly Bog site is located in Marlboro Township, Monmouth County and
Old Bridge Township, Middlesex County, New Jersey. Between 1950 and 1956, the site
had been used for lagoon storage and settling of reprocessed oil, storage of filter
clay from oil reprocessing operations, sanitary landfilling, and sand and gravel pit
operations. During these operations, hazardous substances were improperly disposed
of resulting in contamination throughout the 60-acre study area.
The selected remedial action for this site includes: excavation and disposal
off-site liquids, sludges, asphalt piles, drums, contaminated soil from lagoons
and wetlands, restore site contours and vegetation; monitor ground water for 5-year
period. The approach is a three-phase action.
Capital costs for the selected alternative are estimated at $2,200,000 for
Phase I, $5,110,000 for Phase II and $60,000 per year for operation and maintenance.
Key Words: Depth of Excavation; Off-Site Disposal; Soil Excavation; Contaminatior
Assessment; Supplemental ROD; Wetlands; Ground Water Contamination;
Ground Water Monitoring; Public Exposure; Site Restoration
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Record of Decision
Burnt Fly Bog, NJ
Contaminated media: gw, sw, soil, wetlands
Key contaminants: VOCs, solvents, PCBs,
metals, oils
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (TIlis Report)
None
21. NO. OF PAGES
34
20. SECURITY CLASS (TIlis page)
None
22. PRICE
EPA Form 2220-1 (R«». 4-77) PREVIOUS EDITION i* OBSOLETE
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EPA Form 2220.1 (R«v. 4-77) (R.v.,,.)
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Site:
ROD BRIEFING ISSUES
Burnt Fly Bog, New Jersey
Date:
Region; II
Briefing Date; November 16, 1983
ISSUES AND RESOLUTIONS
The remedial action selected for this
site involves excavation and off-site
disposal of lagoon liquids, sludges,
asphalt piles, drums and contaminated
soils. Concentration vs. depth and percent
removal vs. cost curves were developed and
used in determining the estimated volume of
material to be removed. Based on this
analysis, the recommended depth of removal
was 4 feet. It was further determined that
the level of contamination in the remaining
soil would not pose a health threat since
the site is in a ground water discharge zone
(as opposed to a recharge area), the level
of contamination in the soil below 4 feet is
very low and mobility of the contaminants is
minimal. Removal to a depth of
approximately 4 feet will provide roughly
90% contaminant removal; going beyond that
depth results in rapidly decreasing marginal
benefits at a significantly higher cost.
It was agreed that further study
of the westerly wetlands was appro-
priate in order to assess the extent
of contamination. A supplemental ROD will
be submitted if design and implementation of
a remedial plan is necessary.
There appears to be no indication
that contaminants in the ground
water are migrating towards private
wells in the surrounding area.
However, due to potential retardation
KEY WORDS
. Cost Effectiveness
. Excavation Depth
. Off-Site Disposal
Contamination
Assessment
Supplemental ROD
Ground Water
Contamination
Ground Water
Monitoring
Public Exposure
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Burnt Fly Bog, New Jersey
Briefing Date
Continued
ISSUES AND RESOLUTIONS KEY WORDS
of contaminants by fine grain soil
materials, future contamination of
private wells may occur. The design of
a comprehensive 5-year ground water
monitoring program was approved to
ensure the integrity of the cleanup.
4. Removal of contaminated material will . Site Restoration
not restore the physical integrity and
biological life of the site. Because of the
erosion-prone features of the site and the
unstable slope resulting from removal
activities, the design of a site restoration
plan was approved.
2201i/2
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Record of Decision
Remedial Alternative Selection
Site: Burnt Fly Bog, Marlboro Township, Monmouth County and
Old Bridge Township, Middlesex County, New Jersey
Analysis Reviewed
I have reviewed the following documents describing the analysis
of cost effectiveness of remedial alternatives at the Burnt Fly
Bog Site.
-Environmental Information Document, Engineering Study for
Clean-up of Burnt Fly Bog, Marlboro Township, New Jersey,
Dames & Moore, March 1983;
-Staff summaries and recommendations; and
-Recommendation by the New Jersey Department of Environmental
Protection (NJDEP).
Description of Selected Option
1. Phase I Remedial Action
- Design and implementation of the excavation and off-site
disposal of hazardous substances in lagoon 1, the asphalt
pile area, the tar patch area and the drummed waste area.
Contaminated lagoon water will be disposed of at a
commercial treatment facility while drummed liquid waste
will be incinerated. The tar patch waste will be disposed
of at an off-site intermediate sludge landfill while
lagoon 1 sludge, asphalt pile area waste and the drummed
solid waste will be disposed of at an off-site secure
chemical landfill. All disposal facilities are in compliance
with Subtitle C of RCRA.
- Design oŁ the excavation and removal of hazardous substances
in lagoons 2, 3 and 4, the northerly wetlands and the
contaminated soils area.
- Design of a site restoration plan.
- Design of a comprehensive 5-year groundwater monitoring
program. This will include testing of 8 area residential
wells.
- Further study of the westerly wetlands to determine the
extent of contamination in this area.
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2. Phase 2 Remedial Action
- Implementation of the excavation and off-site disposal of
hazardous substances in lagoons 2, 3 and 4, the northerly
wetlands and the contaminated soils area. The hazardous
substances shall be disposed of at an off-site secure
chemical landfill that is in compliance with Subpart C
of RCRA.
- Restoration of original site contours and revegetation of
the area.
Declaration
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan, I have determined that groundwater monitoring
including the testing of area residential wells, further study
of the westerly wetlands, and excavation and off-site disposal
of the lagoon liquids, sludges and contaminated soils, tar
patch area, asphalt piles, drums, contaminated soils area and
northerly wetlands surface soils at the Burnt Fly Bog site are
a cost-effective remedy, and that this remedy mitigates and
minimizes damage to and provides adequate protection of public
health, welfare and the environment.
I have also determined that the action being taken is appropriate
when balanced against the need to use Trust Fund money at
other sites. In addition, I have determined that the off-site
transport of hazardous substances is more cost-effective than
other remedial actions and therefore consistent with Section
101(24) Of CERCLA.
Lae M Thomas, Assistant Administrator
Office of Solid Waste & Emergency Response
NOV I 6 1983
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Burnt Fly Bog Site Remedial Action
Briefing Document
"Purpose of this briefing is to obtain AA approval for the
remedial action plan recommended by the Region and the State
for the Burnt Fly Bog Site. A "Record of Decision" has been
prepared to document the approval.
°The Burnt Fly Bog Site encompasses approximately 60 acres of
the 1700 acre bog.
"Between 1950 and 1965, the site had been used for lagoon storage
and settling of reprocessed oil, storage of filter clay from
oil reprpcessing operations, sanitary landfilling, and sand and
gravel pit operations. During this time, a portion of the
uplands area of the site had been used to deposit hazardous
substances, some of which have escaped to other portions of the
site.
"Site defoliation and past earth moving activities have caused
severe erosion to occur resulting in the movement of significant
amounts of site soils from upland areas toward lower lying
areas.
"Due to the high groundwater table, the highly contaminated
conditions at the site are of particular concern because the
site is located in an outcrop area of Englishtown Sands which
serves as an important aquifer in Monmouth County. Also,
contaminated surface runoff may reach Deep Run where recharge
basins have been constructed for the Raritan Magothy aquifer.
"The primary waste areas consists of four (4) lagoons, drum
storage area, tar patch area, asphalt pile, northerly wetlands,
contaminated soils area and westerly wetlands.
"Dames & Moore completed a feasibility study in March 1983 as
required by the existing Cooperative Agreement. This study
was funded by "pre-Superfund" RCRA monies.
"The feasibility study investigated three (3) separate cleanup
issues i.e., waste removal, groundwater management and site
closure.
"Incineration, chemical stabilization, on-site landfarming and
on-site landfilling -were eliminated as on-site treatment and
disposal options for the following technical reasons:
Incineration - There are no mobile incinerators presently
available which can reliably incinerate PCB waste. In addition,
the process would generate ash residual, wsstewater, and air
emissions residuals which will require treatment or secure
disposal. The incinerated contaminated soils would also require
on-site laboratory analysis to determine if disposal on-site is
appropriate or if off-site disposal is necessary due to the
presence of heavy metals or PCBs.
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Chemical Stabilization - The nature of the contaminants in
the soils at this site connot be effectively stabilized.
On-Site Landfarming - This system will not effectively treat the
heavy metal soil contamination. In addition, the presence of
these metals will inhibit the decomposition of the organic
contaminants.
On-Site Landfilling - Landfilling on-site would require deposition
of materials below ground water levels. Although a liner would
be used, off-site migration would be difficult to control.
Mechanical sludge dewatering and on-site waste water treatment
were evaluated to be technically feasible but would be much more
costly than the recommended option.
"For off-site removal of waste, each waste area referenced above
was investigated separately. For each waste area, different
alternatives were derived and compared on a cost-effective
basis.
°The following outlines the level of contamination in each waste
area along with the recommended alternative and associated cost.
a. Lagoon 1 - Organic Phase
The analytical results indicate the presence of various
toxic metals including lead which was measured at a
concentration of 1300 ppm. It is recommended to allow
the organic liquid phase to mix into the sludge by
pumping out the aqueous layer.
b. Lagoon 1 - Aqueous Phase
The aqueous phase was found to be relatively free of
contamination but must be pumped out to allow removal
of the sludge. Disposal at a RCRA approved facility
at a cost of $90,000 is recommended.
c. Lagoon*1 - Sludge Phase
Sludge material was found to contain high levels of
toluene (14.3 ppm), ethylbenzene (13.4 ppm), trichloro-
ethylene (11.5 ppm), PCB (30 ppm), zinc (1100 ppm), and
lead (3200 ppm). Removal to an off-site RCRA approved
landfill at a cost of $600,000 is recommended.
d. Tar Patch Area
It is recommended to remove the tarry surface material
to an intermediate sludge landfill at a cost of $60,000.
Pollutants found in this area include methylene chloride
at 0.3 ppm, tetrachlordethylene at 0.3 ppm, and trichloro-
ethylene at 0.5 ppm.
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e. Asphalt Pile
All samples indicate the presence of methylene chloride
in concentrations ranging from 305=2950 ppb. It is
recommended to remove this material to an off-site
RCRA approved landfill at a cost of $500,000.
f. Drums
There are approximately 350 drums present containing
petroleum still bottoms, contaminated solvents, waste
oils and contaminated materials. Removal of solids
to an off-site RCRA approved landfill and off-site
incineration of flammable liquids, all for a cost of
$50,000, is recommended.
g. Lagoons 2, 3 and 4 Sludge
Analytical results indicate high concentrations of lead
(35,000 ppm), PCB (55 ppm), zinc (12,000 ppm), toluene
(78 ppm) and total xylene (440 ppm). Removal to an off-
site secure chemical landfill at a cost of $3,300,000
is recommended.
h. Northerly Wet-lands
High toxic metal concentrations i.e. lead (320 ppm),
chromium (29 ppm), and arsenic (38 ppm), were found.
Removal to an off-site secure chemical landfill at a
cost of $220,000 is recommended.
i. Contaminated Soil
High concentrations of PCB (245 ppm) and lead (5600 ppm)
were found. Removal to an off-site secure chemical
landfill at a cost of $1,000,000 is recommended.
j. Westerly Wetlands
Further study of the westerly wetlands is being proposed
to determine the extent of contamination. This 17-acre
area was not included in the original scope of work,
however, a test sample was taken in the area which
showed possible contamination of heavy metals (lead at
11000 ppm) and PCBs (3.4 ppm).
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"For groundwater management, alternatives were prepared for
both aquifer management and end use management. The aquifer
management alternatives included no action with monitoring,
passive collection with on-site treatment, passive collection
with discharge to municipal sewer, complete containment and
disposal, partial containment and disposal, and active removal
and disposal of contaminated groundwater. Alternatives for
end-use management included no action with additional testing,
treatment at point of use, installation of new well and
connection to municipal water supply. However, all present
groundwater monitoring data confirm that the groundwater
contamination at the site is not serious and well below
applicable drinking standards. It is recommended that the
groundwater monitoring program be continued for 5 years to
ensure the integrity of the cleanup.
"For site restoration, three (3) different alternative plans
along with the no action plan were evaluated. While waste
removal will nearly eliminate the potential for future releases
of hazardous substances to the environment, it will not restore
the physical integrity and biological life of this area.
Physical integity will gradually and in some cases significantly
deteriorate due to the erosion-prone features of the surface,
as well as the unstable slope left behind as a result of waste
removal activities. It is therefore considered appropiate to
regrade the area.
The regulatory agencies are currently trying to establish the
current owners, as well as previous owners, as the responsible
parties. The cost of the regrading plan will be included in
any litigation concerning recovery of money.
°A public hearing was held in Marlboro Township on March 30,
1983. Approximately SO people were in attendance. The State
presented a summary of results and the recommended remedial
action plan to those in attendance for review and comment.
The public comment period was held open for 30 days. No
substantial criticism regarding the remedial plan was noted.
"Future public meetings are planned by the State as part of the
Community Relations Plan to update concerned citizens regarding
progress in this cleanup program.
"The State has taken the lead on enforcement actions regarding
this site. Since 1979, there have been legal proceedings
inlcuding the State and previous owners of the property to
establish among other items, the details of past operation.
Currently, the site is associated with litigation to establish
the party (or parties) .legally responsible for the site in
order to recover future costs of site cleanup.
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"The recommended approach for this project is a three (3) phased
one which can be outlined as follows:
Phase I Remedial Action
-Design and implementation of the excavation and removal of
hazardous substances in lagoon 1, the asphalt pile area,
the tar patch area and the drummed waste area.
-Design of the excavation and removal of hazardous substances
in lagoons 2, 3 and 4, the northerly wetlands and the
contaminated soils area. Included in this is the design of
a site restoration plan.
-Design of an extensive 5-year groundwater monitoring
program. This shall include testing of 8 area residential
wells.
-Further study of the westerly wetlands.
Phase II Remedial Action
-Implementation of the excavation and removal of hazardous
substances in lagoons 2, 3 and 4, the northerly wetlands
and the contaminated soil area.
-Restoration of original site contours and revegetation of
the area.
Phase III Remedial Action
-Based upon the further study of the westerly wetlands,
design and implementation of a remedial plan for this area
may be needed. This design and implementation, if needed,
shall be the subject of a supplemental ROD.
Phase I
°The removal of the visually contaminated substances in lagoon
1, the tar patch area, the asphalt pile area and the drummed
waste area is being proposed as a Phase I Remedial Action for
the following reasons:
-The feasibility study has identified this measure as a
cost-effective, feasible and necessary to limit the threat
of exposure to a significant health hazard.
-Since removal involves visually contaminated substances,
minimal design activities are required.
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-Removal of these substances will greatly facilitate design
of the Phase II Remedial Action because completion-of this
phase will improve access to lagoons 2, 3 and 4.
-Expensive mobilization costs are not anticipated since no
high technology procedures are being proposed.
Phase II
"The estimated amount of hazardous material to be removed
from lagoons 2, 3, and 4, the northerly wetlands and the
contaminated soils area is based upon the sampling and testing
that was.performed during the feasibility study. Duplicate
sampling was conducted in June 1983 which verified the results
of the original sampling.
"The sampling results indicate significant decreases in
concentrations of hazardous substances in the vertical direction.
Concentration vs depth and percent removal vs cost curves
were developed and used in determining the estimated volume
of material to be removed. These curves and a discussion of
the line of reasoning used in estimating the volumes to be
removed are attached as Appendix A.
"The volume of materials to be excavated from lagoons 2, 3, and
4 and the northerly wetlands is based on the removal of
materials to the depth of four feet. For the following reasons,
the level of contamination in the soil below this depth will
not constitute a threat to human health and the environment:
Because (1) the site is in a groundwater discharge — rather
than recharge — zone; (2) the level of remaining contamination
in the soil is very low ( arsenic, below 2 ppm; lead, below
50 ppm; and PCBs, below 10 ppm); and (3) the mobility of
these contaminants through the soil is also low. The level
of contamination of the groundwater and the surface water
beyond the perimeter of the site is not expected to exceed
drinking water standards.
"Costs for the^ recommended alternative are estimated at $2,200,000
for the Phase" I Remedial Action, $5,110,000 for the Phase II
Remedial Action and 560,000 per year for Operation and Maintenance.
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°The above costs breakdown as follows:
Activity Cost ($)
Phase I Remedial Action
- Phase I Removal
-Design & Excavation $200,000
-Lagoon 1 Liquid Removal 90,000
-Lagoon 1 Sludge Removal 600,000
-Tar Patch Area Removal 60,000
-Asphalt Pile Area Removal 500,000
-Drummed Waste Removal 50,000
-Engineering Support 100,000
-Contingencies 200,000
TOTAL $1,800,000
-Design of Phase II $ 360,000
Remedial Action
(includes study of
westerly wetlands)
-Design of Monitoring Plan
(includes well testing) 40,000
Phase II Remedial Action
-Lagoons 2, 3 and 4 Removal 3,300,000
-Contaminated Soil Removal 1,000,000
-Northerly Wetlands Removal 220,000
-Site Restoration 336,000
-Engineering Support 254,000
TOTAL $5,110,000
O&M
-Groundwater Monitoring *56,000/year
-Post-Closure Care 4,000/year
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8
"The State has agreed with the above approach.
°The "Record of Decision" certifies that:
-The selected remedial action is a cost-effective remedy
for the site.
-Further testing is necessary for the westerly wetlands.
-Further testing and monitoring of groundwater is necessary.
-Monies are available in the Fund to finance the Phase I
Remedial Action.
"The following actions are required to move the project into
construction:
-Approve proposed remedy AA, OSWER
Implement Phase I Remedial Action State
Obtain funding of Phase II
Remedial Action OSWER
Implement Phase II Remedial Action State
Approve proposed remedy for
Westerly Wetlands (WW) AA, OSWER
Design WW removal State
Implement WW removal plan State
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REMEDIAL IMPLEMENTATION ALTERNATIVE SELECTION
BURNT FLY BOG SITE
MARLBORO, NEW JERSEY
History
The Burnt Fly Bog site is located near the intersection of
Texas and Spring Valley Roads in Marlboro Township, Monmouth
County and Old Bridge Township, Middlesex County, New Jersey.
Although the bog encompasses some 1700 acres, the study area is
limited to approximately 60 acres; namely the site proper and
some of the affected adjacent areas. The site proper consists
of (1) an uplands area - Lot 43 - where a majority of the wastes
were originally deposited, i.e., four (4) lagoons, asphalt
pile, tar patch area, and drummed materials; and (2) low-lying
areas to the north - Lots 6 and 6A including the northerly
wetlands and old sanitary landfill, where wastes have migrated
due to lagoon overtopping, storm run-off, etc. Also included
in the study area is a 17-acre low-lying portion west of the
site proper, the westerly wetlands, to which contamination may
have migrated.
The study area has undergone several changes in ownership since
about 1950. However, use of different portions of the site
between 1950 and 1965 always included one or more of the
following:
1. use of the lagoons for reprocessed oil storage or
settling,
2. storage of the filter clay from an oil reprocessing
operation,
3. sanitary landfill, and/or
4. sand and gravel pit operations.
During these operations, hazardous substances were improperly
disposed of resulting in contamination throughout the study area.
The area designated as the site proper was owned and operated
by Eagle Asphalt Company, a road-oiling business, from about
1950 until 1964. Lagoons were developed during this period for
storage of the reprocessed oil and as settling ponds. In
November 1964, Mr. Eckel purchased the property from Eagle
Asphalt Company and sold it to hr. Dominck Manzo in July 1965.
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The old sanitary landfill was begun by Mr. Towler and received
local trash. Upon his death in 1961, landfill operations
ceased. This property was purchased by Mr. Dominick Manzo in
December 1963 and again utilized as a sanitary landfill until
1967. A court order disallowed continued use in 1969.
On October 26, 1973, a fire began in the lagoon area and burned
for 16 hours before it was extinguished with the use of chemical
foam. Pockets of oil and toxic materials feeding the fire
were blown up by a demolition team from the Earle Ammunition
Depot located in Middletown Township.
•
The fire at the site appears to have brought the area and its
potential hazardous/toxic problems more fully into public
view. Since approximately 1970, there have been legal proceedings
including the New Jersey Department of Environmental Protection
(NJDEP) and previous owners of the Study Area to establish,
among other items, the details of past operations. Currently,
the site is associated with litigation to establish the parties
legally responsible for the site, to recover NJDEP monies
spent, and to establish a source of funds to recover future
costs of site cleanup.
In April 1982, a 900-foot security fence was installed to
prohibit site access. A 6-foot section of dike was also repaired
to prevent spillage of lagoon liquid.
Current Status
A feasibility study has been prepared by Dames & Moore. The
purpose of the study was to develop recommendations for appro-
priate Remedial Action for Waste Removal and Disposal, Groundwater
Management and Site Closure. To achieve this goal, Dames &
Moore performed a variety of tasks to supplement the existing
site data base, defined the existing site problems, formulated
and comparatively evaluated alternative remedial action options
and plans, and.developed recommendations for remedial measures
to be implemented.
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In order to supplement the existing site data base, they
performed a one time, site-wide sampling program of wastes,
soils, surface water and groundwater, which combined with the
previous data would provide bases for conclusions and recommen-
dations. Chemical analyses which were performed on the collected
samples indicate that lagoon wastes have migrated to other low
lying areas of the site, due to overtopping or breaching of
the lagoon dikes. The composition of the sampled wastes included
many EPA priority pollutants, both organic and inorganic,
including PCBs. The presence of these wastes, together with
erosion has occurred at the site due to man's activities,
account for the site distress which is currently observed.
Investigation
1. Lagoon System
°The on-site system consists of 4 separate cells situated
within the site proper.
•Lagoon 1 contains free liquid which is bilayered with a
thin, floating organic layer (volume = 1,100 gallons) and
a large aqueous phase (volume = 450,000 gallons). The
organic and sludge phases of this lagoon were found to
contain various levels of organic contamination as well
as trace amounts of toxic metals. The aqueous phase was
relatively free of such contamination.
"Lagoons 2, 3, and 4 resemble the level of contamination of
the sludge phase of lagoon 1 with significant levels of
PCBs.
2. Tar Patch Area
•Pollutants found in this area consist of methylene chloride
at 0.3 ppm, tetrachloroethylene at 0.3 ppm, and trichloro-
ethylene at 0.5 ppm.
3. Asphalt Pile
•All samples taken indicate the presence of methylene
chloride in concentrations ranging from 305-2950 ppb.
4. Drummed Materials
•Majority were found in poor structural condition and will
require transfer/repackaging and removal. Contents are of
solid and semi-solid materials, flammable solvents and
oils along with empty degraded drums.
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5. Northerly Wetlands (north of lagoon 1)
"Contaminated with organic and inorganic waste constituents
including PCBs.
6. Westerly Wetlands (west of the four lagoons)
"Surface waste appears over a 10-acre area at a depth of
one foot covered by an average depth of eight, inches of
slowly flowing water. Analysis indicates the presence of
organics and some PCBs
7. Groundwater Analysis
"Subsurface data collected suggest that in this area the
Englishtown Formation underlying the western portion of the
study area consists of 2 saturated sandy units (upper and
lower aquifers) separated by a black upper clay lens.
°It appears that the upper clay unit may underly all the
study area's known surface contamination (lagoons, asphalt
pile, defoliated area and westerly wetlands). This unit
retards the downward flow between the 2 shallow aquifers,
but also serves to channel potential contamination to the
surface water discharge zone along the western portion of
the site.
"Although the groundwater flow in the upper aquifer is to
the west and away from most of the area homes and private
wells, the presence of a groundwater mound beneath lagoon
1 provides the potential for movement of some contaminants
toward the east and southeast where a majority of the
homes are located.
"Based upon priority pollutant analysis of one set of
groundwater samples from 8 domestic wells, there appears
to be little or no suggestion of such contaminants
migrating to those wells. However, due to potential
retardation of contaminants by fine grain soil materials,
some contaminants may not have yet reached the private
wells.
8. Public Safety
"The abandoned hazardous waste site represents a potential
danger to people trespassing on the area and/or handling
pets that have visited the site.
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"Because the site is a large, open area it is attractive to
children; there has been one documented case of lead
poisoning of a child who habitually played at the site (only
lagoon 1 is properly fenced).
For each of the waste types and site areas, a number of feasible
remedial actions options were considered with respect to
technical adequacy, cost-effectiveness, environmental impacts
and regulatory considerations, in order to formulate a Recommended
Remedial Action Plan.
•
Much of the recommended Remedial Action Plan involves the
removal of site wastes and contaminated soils to off-site secure
chemical disposal facilities. This would be followed by a Site
Regrading Plan in which the site topography is improved and
regraded with denuded surface areas revegetated.
On March 30, 1983, at a public hearing in Marlboro Township,
New Jersey, the recommended remedial action plan of the Dames
& Moore Report were presented by the State of New Jersey. The
State's reply to the public comments are attached.
Recommended Alternatives
Section 300.67(j) of the National Contingency Plan (NCP) states
that the appropriate extent of remedy shall be determined by
the lead agency's selection of the remedial alternative which
the agency determines is cost-effective (i.e., the lowest cost
alternative that is technologically feasible and reliable) and
which effectively mitigates and minimizes damage to and provides
adequate protection of public health, welfare, or the environment.
Based on our evaluation of the cost-effectiveness of each of the
proposed alternatives, the comments received from the public,
information from earlier technical studies, and with concurrence
from the State, we have determined that the following remedial
action plan meets the NCP criteria.
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Phase I - Remedial Action
-Design and implementation of the excavation and removal of
hazardous substances in lagoon 1, the asphalt pile area,
the tar patch area and the drummed waste area.
-Design of the excavation and removal of hazardous substances
in lagoons 2, 3, and 4, the northerly wetlands and the
contaminated soils area. Included in this is the design
of a site restoration plan.
-Design of an extensive 5-year groundwater monitoring
program. This shall include testing of 8 area residential
wells.
-Further study of the westerly wetlands.
Phase II - Remedial Action
-Implementation of the excavation and removal of hazardous
substances in lagoons 2, 3 and 4, the northerly wetlands
and the contaminated soil area.
-Restoration of original site contours and revegetation of
the area.
Phase III - Remedial Action
-Based upon the further study of the westerly wetlands,
design and implementation of a remedial plan for this area
may be needed. This design and implementation, if needed,
shall be the subject of a supplemental ROD.
The cost of the Phase I Remedial Action is $2,200,000, the cost
of the Phase II Remedial Action is $5,110,000 and the O&M cost
is $60,000/year. Operation and maintenance includes groundwater
monitoring forjEive (5) years and post-closure care for 10 years,,
at the end of which the O&M requirements must be reevaluated.
Proposed Action
We request your approval of the above plans as the remedial
implementation option for the Burnt Fly Bog. The attachment
which follows will provide additional information to support
the documentation for this decision.
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DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
8 E. H«no»*r S»~ CN 028, TrMifon. NJ. Oft*25
Marwan Sadat
oiBeeroa , AJminiatrat
umcw i ww t . • 4.. ^' i
L I o o i UOJ
Mr. John Frisco, Chief
Hazardous Site Remediation Section
USEPA - Region II
26 Federal Plaza
New York, NY 10278
RE: Burnt Fly Bog
Cooperative Agreement
Dear Mr. Frisco:
This is to provide our response to questions raised at our meeting with
c you and members of EPA headquarters staff in Washington, D.C. on October
25, 1983.
The following discussion illustrates our rationale for determining the
amount of excavation and- removal of contaminated materials at the Burnt
Fly Bog site in Marlboro, New Jersey. Its purpose is twofold; first,
to provide, based on existing data, the logic used to determine.the
extent of excavation being proposed in the cooperative agreement and
second, to illustrate a methodology that will be used during the
design, when additional data is available, to confirm and refine the
detailed cleanup plan.
This analysis is directed at the proposed removals in Lagoons 2, 3, and
I* since these are the largest excavations and represent the major cost
in the Phase II remedial program. The cost breakdown for the Phase II
program is as follows:
Lagoons 2, 3. & 4 $ 3.1 million
Contaminated soils 1.0 "
Northerly wetlands .2 "
Restoration . 3 "
Administration &
Const. Supervision . .5 "
Total $ 5.1 million
Based on soil analysis in the backfilled lagoons it can be seen that
contaminant concentrations are decreasing with depth. This is shown
on the enclosed plots of concentration vs. depth (figs. 1 & 2) for the
New Jersey Is An tifual Opportunity Umpioyer
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r
2, 3 5
JZ.
. Z.
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/o
, 3 * 4
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.o
z.o
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three main contaminants of concern, PCBs, lead and arsenic. From these
plots it is -possible to estimate percent contaminant removal at various
excavation depths by calculating the area under the curve and dividing
by the total area. These percent removals were then plotted against
the cost of excavation and disposal at the corresponding depths. This
plot is also enclosed (fig. 3).
Figure 3 shows that the recommended cleanup to approximately a 4 foot
depth, at a cost of $3.1 million, will provide roughly a 90% contaminant
removal. While going to only 3 feet would save about $1 million, this
would provide only 75-802 removal. In the other direction, going to
5 feet would only provide an additional 3-4% removal at the cost of
an additional $1 million. We therefore feel that the recommended cleanup
for the lagoon areas is reasonable and cost-effective and chat going
much beyond A feet results in rapidly decreasing marginal benefits at
a significantly higher cost. In addition, given the fact chat additional
sampling will be done during design, we feel confident that the con-
tamination levels that remain after the 4 foot removal will be
sufficiently low as to pose no further hazard at this sice.
As stated earlier, this analysis is directed at the lagoon areas. The
contaminated soil and northerly wetland areas do not lend themselves
to this type analysis since these areas exhibit basically a surface
contamination problem and only a one foot removal is being proposed.
However, as with the lagoon areas, additional sampling will be done
during design to refine these estimates.
We feel that this analysis coupled with currently available data
provides a reasonable and justifiable basis for proceeding with the
approval of design and remedial construction for the Burnt Fly Bog
project. As more detailed data becomes available during che design
phase, this analysis will be further refined with che intent of providing
a cost-effective and environmentally sound cleanup program.
Dr. Jo^rge Berkowicz,/Administrator
Hazardous Site Mitigation Administration
HS39:jdd
Enclosures
cc: Mr. Russell Wyer - USEPA - HQ
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POLLUTANTS REMAINING
The following is a list of data points used in developing
the precent removal vs. cost curve:
Parameter
Cone, (ppm) @ Various Depths
Lead
Arsenic
PCB
3'
280
1.6
30
4'
32
1.2
8.5
71
BMDL
1.0
BMDL
RCRA and TOSCA standards call for lead and arsenic concentrations
below 5 ppm and PCB concentrations below 50 ppm. As can be seen
from the above table, if we stop excavation at three feet, we are
leaving a significant concentration of lead. The 30 ppm of PCB,
although below TOSCA'S 50 ppm standard, can still be considered
significant. Excavation to seven feet would bring us below all
standards, however, the cost curves were developed to determine
the necessity and cost effectiveness of this. Using the above data,
the cost curves and historical data as .to the depth of the lagoon,
excavation to a depth of four feet was deemed appropiate. As c<
be seen from the table, 32 ppm of lead is still present at this I
depth, as is 8.5 ppm of PCB. It must be noted that the samplinc
data is from the center of the lagoons and therefore represents the
highest concentration at that depth. The sides of the lagoon are
expected to be free of contamination at 4 feet. For cost estimation
purposes, the four foot depth appears appropriate since it re-
presents an average depth. Excavation at the center of each
lagoon may extend beyond four feet but this should be compensated
by the fact that peripheral excavation should be less than four
feet. Boring work during the design phase will quantify the
exact depth or excavation.
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