United States
Environmental Protection
Agency
Office of .
Emergency and
Remedial Response
EPA/ROD/R02 -84/001
December 1984
Superfund
Record of Decision:
Bridgeport Site, NJ
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BRIDGEPORT, NJ
Record of Decision
Abstract
This 30-acre site is located approximately one mile east of the Town
of Bridgeport and about two miles south of the Delaware River. The site
is an abandoned waste oil storage and recovery facility which operated
from 1950 through the early 1970's. The site includes a tank farm
consisting of 90 tanks and process vessels, drums, tank trucks and a 12.7
acre waste oil and wastewater lagoon. The lagoon is divided into three
layers: an oily upper layer, an aqueous middle layer, and bottom
sludge/sediment deposits. Sampling of these lagoon layers and the ground
water reveal average PCB concentrations in excess of 500 ppm; organics,
such as benzene, methylene chloride and toluene, at concentrations up to
1,000 ppb; and acetone at levels up to 70 ppm.
The cost-effective remedial alternative selected for the first
operable unit includes disposal of oily waste and sediment/sludge via
on-site incineration; removal and disposal of contaminated water via an
on-site treatment system; drum excavation and removal; maintenance
pumping to prevent further migration of the contaminated plume; complete
removal of tanks and waste; installation of a water supply pipeline from
an existing pump station; and a second phase RI/FS to determine
appropriate ground water cleanup and lagoon closure remedies. The
estimated total project capital cost for this remedy is $57,672,000 and
the estimated 10-year operation and maintenance costs for the water
supply pipeline is $20,000.
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'..JNMTED STATES F iv \'iRr^^FNT'AL PROTECTION AGENC'-.
Record of Decision
Remedial Alternative Selection
Site
Bridgeport Rental and Oil services (BROS), Inc., Logan Township,
New Jersey.
Documents Review
I am basing my decision on the following documents describing the
analysis of cost effectiveness of remedial alternatives for the
BROS site:
- BROS Remedial Investigation Report and Feasibility Study
(RI/FS, July 1984)
- Summary of Remedial Alternative Selection
- The documents attached to this Record of Decision
Description of Selected Remedy
Lagoon;
- Removal and disposal of oily waste via on-site incineration*
- Removal and disposal of sediment/sludge via on-site incineration*
- Removal and disposal of contaminated water via an on-site
treatment system
- Drum excavation and on-site disposal
- Maintenance pumping to prevent further spreading of
contaminated plume and ensure capture of any contaminants
that may escape during lagoon excavation
*0ff-site incinerators may be permitted to bid on this project
Tank Farm;
- Complete removal of tanks and waste.
Residental Wells;
- Water supply pipline from an existing pump station in the
Village of Bridgeport to contaminated wells.
Additional Studies;
- 2nd phase RI/FS to determine appropriate ground water
cleanup and lagoon closure remedies.
-------
- 2 -
Declaration
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR part 300), I have determined that the
selected remedy as described above is a cost-effective remedy and
provides adequate protection of public health, welfare, and the
environment. The State of New Jersey has been consulted and
agrees with the approved remedy.
I have also determined that the action being taken is appropriate
when balanced against the availabilty of Trust Fund monies for
use at other sites. In addition, the off-site transportation,
storage, destruction, treatment, or secure disposition of wastes
stored in tanks currently on-site is more cost-effective than
other remedial action, and is necessary to protect public health,
welfare, or the environment.
Date •' Lee -W. Thomas, Assistant Administrator
Office of Solid Waste and
Emergency Response
-------
Summary of Remedial Alternative Selection
11
Bridgeport Rental and Oil Services
Bridgeport, New Jersey
Site Location and Description
The Bridgeport Rental and Oil Services BROS site is located on
Cedar Swamp Road at the divergence of Route 130 and 1-295 in southwest
New Jersey, approximately one mile east of the Town of Bridgeport
and about 2 miles south of the Delaware River (see Figure 1). More
specifically, the BROS site is located on a parcel of land delineated
as Block 59, Lots 18, 22A, 22B and 22F on Tax Map 14A, Township of
Logan, Gloucester County, New Jersey. The total area of the site
is about 30 acres. The site includes a tank farm containing about
90 tanks and process vessels, drums, tank trucks and a 12.7 acre
waste oil and wastewater lagoon. The general arrangement of the
site is shown on Figure 2.
The area surrounding the BROS facility is predominately rural and
agricultural in nature. An active peach orchard borders the western
edge of the BROS site. A truck repair garage is located approximately
300 feet northwest of the site and 3 homes are located about 800
feet north. East of the site is a swampy area (Little Timber Creek
Swamp) which leads into Little Timber Creek. South and southwest
of the site, adjacent to the lagoon, are three large ponds. These
ponds are man-made and were excavated by a sand and gravel mining
operation which started in the late 1940's and was completed by the
early 1970's.
Topography surrounding the site is nearly flat. The Bridgeport
area is bounded on the north by the Delaware River, and the local
land is characterized by swamps and streams flowing north-northwest
to the river. However, the site is not located within the 100
year floodplain.
A thick clay layer exists beneath the BROS site. The top of this
clay layer is located at a depth of 100 feet below ground surface
in the northwest corner of the site and dips southeast to a depth
of about 140 feet below the ground surface in the southeast corner.
Above the clay layer is the Cape May/Magothy-Raritan Formation,
which is a surficial aquifer beneath the site and an outcrop of the
Raritan Magothy aguifer, one of New Jersey's major sources of
potable water- Regional flow of this aguifer is estimated to be
north toward the Delaware River with a velocity of about .056
ft/day; however, local flow is radial around the BROS lagoon due to
mounding effects from the hydrostatic head of the lagoon. This
aguifer is also used as a potable water supply for about 800 people
in the Bridgeport area. Domestic water wells are located north,
northwest and west of the site, with ten wells located from 50 to
1000 feet of the site.
-------
-2-
Site History
The BROS lagoon reportedly began to form in the 1940's as a result
of sand and gravel dredging operations. An examination of aerial
photos reveals that light dumping in the lagoon was occuring at
about the same time. From the 1940's to present, the lagoon
increased in size from .54 acres to 12.7 acres. Presently the
lagoon is 21 feet deep in certain locations and the bottom 13
feet of the lagoon is in contact with groundwater. Also, during
that time frame, various liguids and oils were deposited into the
lagoon. In the late 1950's and 1960's, storage tanks began to be
constructed on the site. The wastes in the lagoon and in some of
the tanks still remain.
When the present owners of the site took over in the late 1960's,
the site was used for waste oil storage and recovery, and for
storage tank leasing operations. In the early 1970's, the eastern
dike of the lagoon was breached and caused a large area (3 acres)
of vegetative damage. The damage included an area of obviously
stressed vegetation including shubbery and trees. In addition,
the 3 acre area is covered with a surficial layer of PCB contaminated
oil. From 1975 to 1980, various remedial cleanup efforts were
proposed by the owners of BROS to clean up the lagoon. Those
that were attempted proved to be unsuccessful. These unsuccessful
attempts included booming and collecting the oil, unsuccessfully
treating the agueous phase of the lagoon, as well as attempting
to volatilize the volatile organics from the lagoon by using a
giant fan. In the Spring of 1981, the lagoon.began to rise and
threatened to overflow its dike. In response to this threat, the
U.S. Coast Guard utilizing funds provided by Section 311(K) of
the Clean Water Act increased the height of the existing dike by
about 5 feet. This addition was designed to contain the liguid
in the lagoon for approximately 4 to 5 years.. However, in the
Spring of 1982 and 1983, the lagoon again rose and threatened to
flow over the new dike. Durinq those two periods, EPA initiated
emergency action at the site. This action consisted of lowering
the level of the lagoon by pumping the aaueous phase through a
mobile activated carbon system. The lagoon level was lowered
approximately 2 feet each time. Presently, under an initial
remedial action at the site, EPA has lowered the level of the
lagoon by approximately 8 feet. This was accomplished by pumping
the agueous phase of the lagoon through an oil/water separator,
flocculation/sedimentation tanks, sand and granular activated
carbon filters and discharging the effluent to Little Timber Creek.
This action was designed to stabilize the situation until a
long-term cleanup could be implemented.
Current Site Status
The BROS site, as previously described, consists basically of a
tank farm and a 12.7 acre waste oil and wastewater lagoon. Table I
describes the guantity and guality of the material in the tanks
with the most significant volumes. Most of the tanks are in
poor condition and not suitable for long-term storage of material.
-------
''"""i""""""""'"" "
; BRIDGEPORT RENTAL
OIL SERVICES SITE
./- \ '
-;L.:.\.O
.. . .
BASE MAP IS A POmON Of THE U.S.O.S BRIOGEPOflT,NJ-PA QUADRANGLE (7.5 MINUTE SERIES, B67). CONTOUR IN
TERVAi. t
-------
K>
I
U)
PROPERTY
BOUNDARY
MARSH
, TOPOGRAPHIC
CONTOUR
TANKS AND
VESSELS
GENERAL SITE ARRAN
BRIDGEPORT RENTALS OIL SERVICEsHSGAN TWP.t NJ
STAi F-
-------
TABLE 1
DRAFT
GENERAL PHYSICAL AND CHEMICAL CHARACTERIZATION OF TANK CONTENTS
BROS SITE. LOGAN TOWNSHIP. NEW JERSEY
NUS Tank
Number1
Sampled
Phase
Estimate
Volume of
Sampled Phase
(Gallons)
1
6
15
18
18
21
30
31
36
37
38
39
50
51
52
53
54
55
56
60
63
66
68
69 Top3
69 mid3
69 Bot3
70
82
87
88
88
Sludge
Sludge
Aq. Liq.
Aq. Liq.
Sludge
Aq. Liq.
Oil
Oil
Oil
Oil
Oil
Oil
Aq. Liq.
Oil
Oil
Oil
Solid
Oil
Oil
Oil
Oil
Oil
Aq. Liq.
Oil
Aq. Liq.
Sludge
Aq. Liq.
Oil
Aq. Liq.
Aq. Liq.
Oil
2.600
1.100
1.500
2.500
2.500
22.800
4.200
3.400
11,200
4,800
2.600
3.900
18.900
2.300
3.200
1.300
1,500
9.500
1.700
11.400
216.500
1.700
1.800
310.000
90.000
13,000
6.000
3.300
1.800
1,800
7,100
Total HSL2
Organics
fuq/g)
ND
72
ND
2.5,02
4.615
ND
88
2.5
40
9.087
537
385
ND
307
1,544
225
ND
1.739
33
2.250
3.782
255
11,600
258
15
955
ND
142
ND
2.500
ND
Chlorinated
Hydrocarbon
Solvents
(ug/g)
ND
ND
NO
180
430
ND
ND
ND
ND
687
29
ND
ND
65
ND
60
ND
105
ND
115
30
ND
ND
50
ND
290
ND
30
ND
ND
ND
PCS
(ug/ko)
ND
ND
ND
11
4.7
ND
300
87
940
66
28
ND
ND
113
217
150
ND
3.900
1.200
ND
1,240
ND
ND
128.000
ND
330.000
ND
ND
ND
ND
ND
1 Tank locations are shown on Figure 3-24.
2 HSL - Hazardous Substance List.
3 Tank Number 69 was not sampled in the NUS Rl; reported volumes and results are from
previous sampling performed by COM in July 1982.
Source: NUS Remedial Investigation. 1983.
3-29
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-------
DRAFT
TABLE 3
SEDIMENT SAMPIINO RESULTS
BRIDGEPORT RENTAL AND OIL SERVICES SITE
Sample IdenlilicallonO) BPR-SD-OI
Parameter Units
Oil/Grease. Soxhlel % <01
tP loxicily
Arsenic
Barium
Cadmium
Chromium
lead
Mercury
Seluiuuin
Silver
EP loxlcily Pesticides
llndane
Endrin
Mallioxyclilor
loxnphene
EP loxicily Herbicides
2.4 -Dichlorophenoiiy-
ur.elic ucid
2.4.5- InclilorophenoMy-
pr
-------
DRAFT
TAOIE 3
SEDIMENT SAMPtINQ RESULTS
BIIIDGEPOKT RENTAL AND OIL SERVICES SITE
PAGE IWO
Sainnla IdanlilicallonCI BPR-SD-Q1 OPR-SD-Q2 BPft-SD-04 BPR-SD-05 BPR-SD-16 BPR-SD-16 BPR-SO-17 BPR-SD-1B BPR-SO-21
_ Parameter _ Units
Volatile*
Mtjlhyleno Chloride po/kg 132 62 29 NOB 7.2 65 72 NOB NOD
Toluene |iQ/kg LT
PuMiciilas NO NO NO NO NO NO
PCB-TOTAL uu/ky PN-2500 PN-96 PNI90*
J. Dio«iiis MQ/kQ NO NO ND NO NO NO NO NO NO
00
1) Sample description found In the lexl of Section 3.0
ND - All MSI compound •nalyied. but no) delected above lha detection limit ol the procedure
LT - Praienl bin below detection limits
NOB - Concentration In Ilia blank Is (trailer lh*n 1/2 the detection limit and Is greater than
1/2 the conttnuailon in Hie sample.
PN - PCB cannot be confirmed by GC/MS, but is Identified by electron capture. Value Is the combined
total of all PCB.
1 - Combination of PCD 12S4 and 1260.
Source: NUS Remedial Investiijalion. 1983
-------
TAOLE 3
SURFACE WATER SAMPLING RESULTS
BRIDGEPORT RENTAL AND OIL SERVICES SITE
OHAft
Sample lilanlllicalioMM
Parameter
Organic Carbon
Total Orfjanic Halogen
Dissolved Solids. 1BOC
Suspended Solids. 103C
j^ Oils. Extracted
1
O Maiardous Substance list |HSl)
Acid/Base/Neulral Compounds
Volatile*
Melhylene Chloride
Acetone
Pesticides
4.4'-DDT
PCB-TOTAl
Dioxtns
Units
mg/l
I'Q/I
my/1
mg/l
mo/I
pg/i
MO/1
HI*
12 9
300
106
3
2.7
ND
28
NO
NO
42 9
300
186
8800
4400
NO
33d
PN-34
ND
25 5
720
114
94
4.5
ND
41
ND
ND
LT - Present bul below (he duiection limit
NO. - All HSL compounds analyzed bul none delected above Hie detection
PN - PCB cannot be confirmed by GC/MS bul Is identified by electron cap
(1) - Sample descriptions lound in Hie text of Section 3.
BPR-SW-OI BPR-SW-Q2 BPR-SW-Q4 BPR-SW-05 BPR-SW-15 BPR-SW-16 BPR-SW-17 BPR-SW-18 BPR-SW-21
41 7
103
140
128
89
NO
11
PN-36
NO
10.6
25
86
9
4.1
ND
ND
ND
ND
96
20
99
2
ND
ND
ND
NO
8.6
73
94
2
14
NO
30
ND
NO
8.6
40
81
1
6.2
NO
24
01
ND
94
66
68
NO
41
ND
ND
Value Is the combined total ol all PCB.
Source: NUS Remedial Inveslifjalion. 1983.
-------
GROUNDWATER MODELING OF CONTAMINANT MIGRATION
BRIDGEPORT RENTAL BOIL SERVICES. LOGAN TWP. NJ
FIGURE 3
A Halliburton Company
-------
AREA1 AREA 2 AREA 3
RESIDENTIAL BELL HILLMAN AUGUST LLOYO
WELL OWNERS BYRNES KELLER MJKULETSKY "**
IDENTIFIED CAHILL LINOLE MUNTZ
TRPW ** OUATTHOCHI
BY AREA FISH DIESEL REPAIR NEWTON RETKOVIS
FRYBERGER PEPPER INO. WILSON SEIVERO
GENERAL LOCATION OF RESIDENTIAL WELLS SAMPLED BY THE EPA.
AREA 4
BECKETT
COCO
PANSERRA
PAAISI
STULL
BRIDGEPORT RENTAL 8 OIL SERVICES. LOGAN TWR. NJ
SCALE l"= 200O' &
AREAS
GAVENTA
NUNES
WACHTER
WEIT2 '
FIGURE 4
:F|\IU£
C3QRPORATC
& ^
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Also, in general, many of the tanks are empty or contain only a
residual amount of sludge and liquid. However, some tanks contain
large quantities of PCB-laden oil.
Also on the site is a 12.7 acre lagoon. As previously mentioned,
the lagoon is 21 feet deep in certain locations. The bottom 13
feet of the lagoon is in contact with the groundwater. The lagoon
is basically divided into three phases including an oily layer with
drums, trash, and other debris floating upon it; an aqueous layer;
and sludge/sediment deposits on the bottom. The oil layer is
contaminated with PCB's above 500 ppm as well as other priority
pollutant chemicals. It is estimated that there are approximately
2.5 million gallons of oil. The depth of the oil layer varies from
a few inches to 2 feet. The depth of the oil at any given location
is dependent upon meteorological conditions at the time. Below the
oily layer is the aqueous phase of the lagoon. Presently, the
aqueous layer has been lowered to an elevation 7.2 feet above mean
sea level (MSL) and contains approximately 44 million gallons of
water. Underlying the water phase is a sludge layer. The depth of
this layer varies from 2 to 4 feet with an estimated volume of
60/000 yd3. Sampling of the sludge layer reveals average PCB
concentrations in excess of 500 ppm. Beneath the sludge layer is
contaminated groundwater and soils. Contaminants found in the
various phases of the lagoon are shown in Table 2. The major
problems associated with the site and its contaminants are as
follows;
1) The sludge layer on the bottom and sides of the lagoon
has partially sealed the lagoon, thus preventing any
significant discharge of liquids through it. In addition,
the oil layer on top of the lagoon inhibits any significant
evaporation. Therefore, the level of the lagoon rises
with each rainfall. Left unattended, the lagoon level
would continue to rise, eventually overtop the dikes
and spread contaminated material over the surrounding
area.
2) The lagoon surface is about 10 feet above the water table.
This 10 feet of hydrostatic head acts as a driving force,
since the lagoon is only partially sealed, "pushing" the
contaminated lagoon water and its contaminants into the
groundwater. Further, the sludge layer at the bottom of
the lagoon is in contact with the groundwater and is
contributing to groundwater contamination.
3) Some of the tanks on the site contain a substantial amount
of waste and could pose a serious hazard to public health
and the environment if a tank would rupture and leak its
contents over the surrounding area.
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4) Other concerns related to the BROS site include surface
soil in the marsh, and sediment in Little Timber Creek
which are contaminated (via PCB oil) due to previous
lagoon seeps, overflows, and from spillage of wastes in
and around the tank area. Table 3 indicates the extent
of contamination found in these areas (See July, 1984
RI/FS, Drawing No. 0707-15-01 for exact sampling locations).
Also, according to magnetometer surveys, drums have been
reportedly buried around the site.
In addition, the contamination from the site has spread into the
surrounding groundwater about 600 feet away from the lagoon.
Figure 3 identifies the edge of the contaminated plume where
concentrations are estimated to exceed background. Results of
the Remedial Investigation reveal that organics such as benzene,
methylene chloride and toluene, have been detected in the ground-
water at concentrations up to 1000 ppb. Furthermore, acetone
has been detected up to 70 ppm. Also, oily waste has been
detected in some wells. See Table 4 for further definition of
the contaminants found in the groundwater. For more detailed
information regarding groundwater contamination please refer to
the BROS RI/FS report dated July 1984. Due to the radial movement
of the groundwater near the lagoon, the contamination has spread
to varying degrees in all directions. Ten private wells are
potentially affected by the contamination in the relatively
near future. Their general locations in relation to the site
are shown on Figure 4 (Area 1). However, at this time, only
the Keller well has been closed by the State of New Jersey due
to this contamination. Trichloroethene was detected in this
well at levels exceeding 200 ppb.
Enforcement Activities
The State of New Jersey, Department of Environmental Protection,
filed suit against the Defendant, Bridgeport Rental and Oil Services,
Inc., charging that the Defendant had polluted the waters of the
State by allowing waste oil to leach from the waste oil lagoon.
(State of New Jersey Department of Environmental Protection v.
Bridgeport Rental and Oil Service, Inc., Case No. C-1523-73, Superior
Court of New Jersey, Chancery Division, Gloucester County). A
Consent Order was filed April 26, 1976 in that action. In that
Order, which was signed by counsel for both parties, the Defendant,
in part, agreed to collect and analyze samples from the waste oil
lagoon, formulate a treatability study for the waste, and plan,
construct and operate a waste oil recovery and treatment facility,
all by January 7, 1977. BROS did not comply with that Order.
A Second Order, State of New Jersey Department of Environmental
Protection v. Bridgeport Rental and Oil Service, Inc., supra, was
filed March 10, 1977. This Order reguired Defendant, in part, to
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prepare a preliminary engineering report on the feasibility of its
new treatment proposal for the material in the waste oil lagoon by
April 11, 1977. Again, BROS did not comply with the Order.
The United States filed suit pursuant to Section 7003 of RCRA
on October 2, 1980, against Bridgeport Rental and Oil Services,
Inc., Dominick and Elia Borrelli, the president and secretary
of BROS. Settlement negotiations resulted in a Consent Decree
that was signed by the Court on June 25, 1982. The Decree
reguired BROS to make the following payments: $25,000.00; ten
percent of all gross revenues from BROS from whatever source
received; entire proceeds of liguidation or sale of the BROS
facility. As a result of the agreement, EPA also obtained
access to the site. The Defendants were released from: civil
claims that could have been raised in the action; other environ-
mental and health claims under existing federal laws resulting
from or related to the migration, discharge or storage of
chemicals and/or oil from the BROS site; and civil claims under
CERCLA arising after entry into the Decree. Releases were
based on the Defendants' factual representation made to the
plaintiff and the Court in view of their entry into the Decree.
These representations include assertions that BROS and
the Borelli's were not involved in the introduction of any
additional waste into the lagoon.
A burglary took place at the BROS site on January 23, 1981. The
firm's business records were among the stolen items. These documents
would have been subject to pretrial discovery, and most likely
would have been made available to the government.
In April, 1983, Information Reguest letters were sent to Potentially
Responsible Parties (PRPs). Records indicating lessees of tanks at
the BROS facility near the waste oil lagoon, provided the basis for
identifying the PRPs. For the most part the companies responded
that they used the tanks only for storage and that none of
their wastes were disposed of at the BROS site. One company
admitted making a shipment of acetone wastes to the BROS site for
disposal.
EPA will follow up on any leads concerning additional PRP's.
We do not believe that the remedial action should be delayed in
anticipation of any further investigation since it is not likely
to be fruitful in a timely manner.
ALTERNATIVES EVALUATION
The major objective of the feasibility study was to evaluate remedial
alternatives using a cost-effective approach consistent with the
goals and objectives of CERCLA. A cost-effective remedial alternative
is defined in the National Contingency Plan (NCP) (40 CFR 300.68(J))
as "the lowest cost alternative that is technologically feasible
and reliable and which effectively mitigates and minimizes damage
to and provides adeguate protection of public health, welfare, or
the environment." The NCP outlines procedures and criteria to be
used in selecting the most cost-effective alternative.
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The next step is to develop a limited list of possible remedial
actions which could be used. The no action alternative is included
on the list.
The third step in the process is to provide an initial screening of
those alternatives. The costs, possible adverse effects, relative
effectiveness in minimizing threats, and reliability of the methods
are reviewed here.
The no action alternative was evaluated for BROS in the following
assessment:
The results of the RI/FS indicate that there is significant contamin-
ation at BROS. Specifically, three distinct sources of potential
contamination are defined, the tank farm area, the 12.7 acre lagoon
and the groundwater. Analyses of the three indicate that the BROS
lagoon poses the most serious threat to the health and welfare of
the general public and the environment. The lagoon oil and sediment
are laden with PCBs at concentrations above 500 ppm, as well as
other organics, and the lagoon water and oil contain significant
concentrations of a variety of priority pollutants (See Table 2)
Without any action, the lagoon will pose a health threat from direct
contact, and the level will continue to rise from rainwater input,
and eventually overflow the existing dike and thereby cause sub-
stantial contamination of the local environment. Overflow of
the dike can cause severe damage to the -surrounding ponds that are
stocked with fish, Cedar Swamp where a variety of wildlife habitate,
as well as providing a larger area where contaminants can percolate
into the groundwater. The lagoon did overflow in the mid 1970 "s
resulting in the contamination of approximately 3 acres of marshland.
This area has severely stressed vegetation and represents a potential
source for the introduction of PCB's into the surrounding wetland
ecosystem due to the lipophilic nature of PCB's. Also, an adjacent
active peach orchard can become contaminated. Furthermore, the
lagoon wastes are in contact with the underlying aquifer, which as
previously described, is used for potable water, and according to
the results of the RI/FS is contaminated.
In addition, many of the tanks are in relatively poor condition and
not suitable for storage of materials. Many of the tanks are
rusted, with paint peeling off the sides. Inspections of the
tanks indicates that leakage has occurred in the past from many of
these tanks. Refer to Table 3-1 in the July 1984 RI/FS for more
specific information relative to each tank. Some of these tanks
contain liquids and sludges contaminated with significant concentrations
of PCBs and chlorinated hydrocarbons. These tanks pose a potential
threat to the general public and local environment should they
eventually leak and begin to discharge their hazardous contents.
Analysis of the potable groundwater aquifer, see Table 4, describes
the nature of the contamination caused by the BROS lagoon. The
contaminated groundwater poses a concern to public health. Contami-
nant levels found in the monitoring wells exceed the New Jersey
Department of Environmental Protection drinking water quality guide
for volatile organics (100 ppb for total volatile organics). In
fact, one residential well has been closed due to contamination and
nine others are threatened.
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TABLE 4
Summary of Groundwater Sampling Results at BROS
Concentration Range
PPB
Contaminant
Methylene Chloride 9 - 10,000
Trichloroethene 10 - 9,000
Aldrin .19 - .23
Dieldrin .39 - 1.15
Endrin ND - .52
Benzene ND - 800
Toluene ND - 1000
2-butanone ND - 4900
Endosulfanl ND - .47
Heptachlor ND - .60
1, 2-Trans dichloroethene ND - 520
Bis (2-ethylhexyl) phthalate ND - 110
Chlorobenzene ND - 130
Ethylbenzene 4 - 490
1, 1, 1 trichloroethane ND - 840
Acetone ND - 73,000
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Based on these problems, the no action alternative was eliminated
from further consideration.
To address the potential above referenced problems caused by the
BROS site, the remedial options were divided into 4 broad categories;
remediation of the lagoon, tank farm, residential wells and ground-
water.
The list of alternatives considered under each of these broad
categories are contained in Table 5.
However, before discussing remedial action options for the 12.7 acre
lagoon, a principal consideration was whether contaminated materials
would remain in contact with and continue to contaminate the ground-
water after completion of a particular activity. Therefore, those
alternatives that permitted the hazardous wastes in the lagoon (includ-
ing the oil, agueous, and contaminated sediment phases) to remain
in contact with the groundwater were eliminated from further considera-
tion. This was because the hazard posed by the lagoon in terms of
continued groundwater contamination would still exist. Also, the
technical reguirements of TSCA and RCRA would be violated.
The alternatives presented in Table 5 were initially screened using
technical feasibility, costs, and environmental/ public health
impacts as criteria for evaluation (RI/FS, July, 1984). The following
presents a summary of the reasons why various alternatives were
eliminated from further consideration.
Lagoon;
No action - The alternative was eliminated due to the reasons
specified above.
Site Management (lagoon-level control) - this alternative involved
just maintaining the level of the lagoon such that the contents
won't overflow the existing dikes. However, this alternative was
screened out because the contents of the lagoon would remain in
contact with the groundwater.
Cap System - this alternative involved constructing a cap with
impervious material such that the potential for leachate generation
and migration is reduced. Obviously, as the lagoon exists today, a
capping system is not feasible given tht liguid state of the lagoon.
However, a capping system can be utilized as part of other lagoon
remedial actions, such as waste excavation.
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TABLE 5
POTENTIAL REMEDIAL ACTION STRATEGIES
AT THE BROS SITE
Lagoon
0 No Action
0 Site Management (lagoon-level control)
0 Cap System
0 Lagoon Waste Excavation, Stabilization and Replacement
0 Lagoon waste Excavation and Onsite Encapsulation
0 Lagoon waste Excavation and Onsite Incineration
0 Wastewater Treatment
0 In-site Biodegradation of Waste
0 Waste Removal with offsite disposal in a Annex I Incinerator
0 Waste Removal, waste stabilization with offsite disposal in
an Annex II Chemical Landfill
0 Cut off wall
0 Partial Lagoon Removal
Tank Farm
0 No Action
0 Tank Cleaning and Waste Removal
0 Tank Demolition and Removal
Residential Wells
o
No Action/Monitoring
Carbon Filtration of Individual Residential Water Supplies
Alternate Water Supply (pipeline from the terminus of the
existing .municipal water system)
Alternate Water Supply (pipeline from the existing pump station)
Groundwater
0 No Action/Monitoring
0 Passive Groundwater Controls (Flow Diversion)
0 Active Groundwater Controls (Flow Manipulation)
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Insitu Waste Stabilization with Onsite Storage - this alternative
involves removing the liquid contents of the lagoon to the depth
of the water table. Chemicals and inert materials would be
mixed with the contaminated lagoon sediment to form an admixture.
This alternative was screened out because the hazardous materials
in the lagoon would not be removed from contact with the ground-
water and could continue to contaminate the groundwater. In
addition, leaving the materials in-place would be inconsistent
with several technical siting reguirements for PCB landfills
given in 40 CFR Section 761.75(b). Also, it would be extremely
difficult if not impossible to successfully blend chemicals to
produce a uniformly inert admixture.
Lagoon Waste Excavation, Stabilization and Replacement - this
alternative requires that the waste be removed from the lagoon,
be stabilized by a chemical fixation process in a
stabilization facility and then returned to the lagoon. This
alternative was screened out for the following reasons: 1) The
available space at the BROS site is not sufficient (even if the
tanks are removed) to store the lagoon waste while the lagoon
in being backfilled. 2) reachability studies that were performed
showed that the stabilized sediment appeared to leach more
organic contaminants than the unstabilized sediments. 3) Add-
itionally, this alternative would place hazardous waste into
an area with an unfavorable site geological framework (e.g.
sandy soils and high water table). This would be inconsistent
the with siting requirements of PCB landfills, 40 CFR Section
761.75(6) .
Lagoon Waste Excavation and Onsite Encapsulation - this altern-
ative would reguire the excavation of the bottom sediments,
encapsulating (lining) the lagoon replace the sediment and
place a cap on the replaced sediment. This alternative was
rejected for many of the same reasons as the one described
above. In particular, the BROS site is not situated in a
favorable location for a hazardous waste containment facility.
In-situ Biodegradation of Waste - this alternative involves the
employment of a mutant strain of bacteria to metabolize and
thereby destroy or detoxify the organic contaminants. This
alternative was screened out because current research indicates
that no specific microorganism has been discovered that will
effectively oxidize or degrade highly chlorinated biphenyls,
which are the contaminant of primary concern in the BROS lagoon.
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Cut-off Wall - this alternative involves the installation of a
subsurface cut-off wall designed to divert groundwater flow from
coining in contact with the lagoon bottom sediments. However,
this alternative was screened out because the depth to the confining
layer beneath the site (100 to 140 feet) approaches the limits of
the feasible depth of cut-off walls. This is particularly true
in the BROS situation because of the irregular site topography
(dikes), and the confined work space which would require that
considerable site preparations be done and innovative construction
methods be used in order to install cut-off walls. In addition,
the presence of dikes around much of the BROS lagoon would preclude
constructing cut-off walls directly around the perimeter of the
lagoon since the cut-off wall trench would seriously jeopardize
the integrity and stability of these dikes. In addition, due to
the extremely swampy conditions around the entire area, it would
be technically difficult to install a wall and there would be
serious questions as to the technical reliability of the alternative.
Partial Lagoon Removal - this alternative involved cleaning out the
entire lagoon except that the lagoon sludge would be left in
place. However, this was rejected for the following reasons:
a) the lagoon sludge/sediment creates a partial seal about the
lagoon bottom. If the seal is maintained, the lagoon would
always fill up with water and eventually would overflow its
dikes. This water would likely be contaminated due to leaching
from the sediments. b) The contaminated sediments would still be
in contact with groundwater. c) Treatability studies performed
on the sediments in the lagoon indicate that various organics such
as 2,4-dimethylphenol, phenol were found in the leachate. Therefore,
the sediment would be a continuous source of contamination into
the groundwater. Based on these reasons, this alternative was
rejected.
Tank Farm:
In reference to Table 5, the only alternative to be screened out
was the no action alternative. This was eliminated because the
tanks on the site are in very poor condition and it is likely that
they will eventually leak their contents. Some of the tanks contain
PCB contaminated oil and sludges as well as other contaminated
liquids (see Table I), and leakage or rupture of these tanks would
further contaminate the existing soils in the tank farm area. In
addition, the contamination could easily spread into Cedar Swamp and
Cedar Swamp Road. This could destroy a wetland (Cedar Swamp)
that is habitated by many species of wildlife as well as contaminate
an entrance road to an Interstate highway (Cedar Swamp Road).
Residential Wells:
In reference to Table 5, none of the alternatives were screened
out.
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Groundwater;
In reference to Table 5, only the passive groundwater control
alternative was eliminated. This is essentially the cut-off wall
alternative which was eliminated for the same reason as discussed
under the lagoon alternatives. Also, the groundwater would still
remain contaminated.
After completion of the initial screening of technologies, a detailed
evaluation of technologies was conducted in order to recommend a
cost-effective alternative.
Table 6 presents the technologies that passed the initial screening
phase. The technologies are categorized into groups according to
which site problems the technology addresses (i.e. lagoon, tank
farm, residential wells, groundwater). Furthermore, the lagoon
technologies are particularly categorized into subgroups depending
upon which phase of the lagoon cleanup technology is involved
(i.e., waste disposal, waste removal, site closure). The technologies
that are determined to be the most cost-effective in each group
will then be combined into one cleanup alternative for the site.
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Table 6
ALTERNATIVES EVALUATED IN DETAIL
Group #1: LAGOON;
Subgroup A) Waste Disposal - Oil
Alternative 1- Onsite incineration
Alternative 2- Offsite incineration
Subgroup B) Waste Disposal - Sediment
Alternative 1- Onsite incineration
Alternative 2- Offsite incineration
Alternative 3- Stabilize and landfill offsite (if less than
500 ppm PCB)
Subgroup C) Waste Disposal - Agueous Phase
Alternative 1- Onsite treatment
Alternative 2- Offsite treatment
Subgroup D) Lagoon Waste Removal
Alternative 1- .Remove oil (via pumping), remove agueous
phase (via pumping), dredge sediments,
(ONLY AVAILABLE OPTIONS) and maintenance
pumping
Subgroup E) Closure
Alternative 1- Backfill lagoon to above the water table
arid revegetate
Alternative 2- Regrade and revegetate lagoon sides,
allow lagoon to remain as a pond
Group #2; TANK FARM
Alternative 1- Tank cleaning and waste removal
Alternative 2- Tank demolition and removal
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Group 13;
Alternative
Alternative
Alternative
Alternative
Group #4;
Alternative
Alternative
RESIDENTIAL WELLS
1- No action/monitoring
2- Carbon filtration of individual wells
3- Alternate water supply (pipeline from the terminus
of the Pennsgrove Water Supply Company).
4- Alternate water supply (pipeline from existing pump
station.
GROUNDWATER
1- No action
2- Active groundwater control
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The cost-effective alternative is the lowest cost alternative that
is technologically feasible and reliable and which effectively
mitigates or minimizes damage to and provides adequate protection
of public health, welfare, and the environment. The candidate
technologies were rated according to several measures of effective-
ness and cost.
The critical components of effectiveness measures were determined
to be:
o Technology Status
o Risk and Effect of Failure
o Level of Cleaning/Isolation Achievable
o Ability to Minimize Community Impacts
o Ability to Meet Relevant Public Health and
Environmental Criteria
o Ability to Meet Legal and Institutional/Regulatory Require-
ments .
o Time required to Achieve Cleanup/Isolation
o Acceptability of Land Use After Action
The following evaluation of the remedial action alternatives will
consider the effectiveness of each alternative to meet these critical
components.
Also, according to the NCP, a total cost estimate for remedial action
must include both construction and annual operation and maintenance
costs. Construction costs and operation and maintenance costs were
estimated for the alternatives under consideration. For operation
and maintenance costs, a "present value" analysis was used to
convert the annual costs to an equivalent single value. Operation
and maintenance costs were considered over a 30 year period (except
for active qorundwater control which has a projected life of 5
years); a 10 percent discount rate and 0 percent inflation rate
were assumed.
Group 1:
LAGOON;
As previously mentioned, each of the technologies that passed the
initial screening for the remediation of the BROS lagoon was
grouped into a category based on which aspect of the lagoon cleanup
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the technology addressed. Each of these categories (waste dis-
posal-oil; waste disposal—sludge; waste disposal—water; waste
removal; and site closure) will be evaluated separately, with the
exception of waste removal, in order to determine the most cost-
effective alternative in each category. The chosen technologies
from each category will then be combined to form the overall
cost-effective action with respect to the lagoon.
After initial screening of alternatives, the removal of waste
(oil, aqueous and sludge) from the lagoon was a common denominator
among all alternatives. Therefore, the cost-effectiveness of
waste removal need not be performed. The only issue that
remains is the method of removal of the various phases within
the lagoon. The method of removal will be discussed in general
terms, since the design engineer and cleanup contractor may
modify the removal method.
Subgroup A
Waste Oil Disposal;
As previously stated, the average concentration of PCBs in the
oil is greater than 500 ppm. Therefore, the only appropriate
disposal method available is incineration (See 40 CFR Section
761.60). Onsite or offsite incineration are available methods
of disposal.
Onsite incineration of the lagoon oil would involve the setting
up of a mobile incinerator at BROS to incinerate the lagoon
oil. Included with this technology would be the need to have
laboratory facilities present at the site to determine whether
the established emission guidelines are being satisfied. Also
included is the proper disposal of the residual ash produced by
the incineration of the oil.
Offsite incineration of the lagoon oil would involve hauling the
oil to an approved incinerator that is licensed to handle PCB
wastes. In terms of the effectiveness criteria, both options
are fairly similar. However, the local community impact may be
unfavorable to onsite incineration. The local community has
strongly opposed any incineration of hazardous waste in the
area and will likely oppose the installation of any onsite
incineration facility. In fact, the Township has an ordinance
which prohibits PCB incineration. The onsite incinerator will
meet the technical requirements of TSCA and RCRA. The State
has informed EPA of its intention to conduct an analysis of
incinerator emissions on the airshed and establish criteria for
design and operational requirements. EPA will consider the
results of the State analysis in developing an operation plan
for the incinerator.
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i
Offsite incinerators have an extensive backlog of materials to
burn and therefore delays may occur in disposing of the lagoon
oil. In addition, the11 possibility of accidents during transportation
of the oil to an offsite facility increases the risk of failure
of an offsite alternative.
The average costs for onsite and offsite incineration are presented
below. The costs include the actual incineration costs, hauling
costs, and ash disposal costs. Mobilization and permitting costs
are also included. The cost estimates assume that an average of
2.5 million gallons (with a range of 2 to 3 million gallons) of oil
would be disposed onsite via the Pyrotech mobile incinerator. For
offsite disposal the oil would be transported to PCB permitted
incinerators in either Chicago, 111. or El Dorado, Arkansas.
Mejbhpd Cost (millions of dollars)
Alternative 1- Onsite incineration-oil 2.65
Alternative 2- Offsite incineration-oil 8.66
Subgroup B) Waste Di sposal—S1udge
The methods which passed the initial screening
process include:
Alternative 1 - onsite incineration
Alternative 2 - offsite incineration
Alternative 3 - stabilization and landfilling
The onsite and offsite incinerator options are similar to
those described for oil disposal except that a greater amount
of ash will be generated for each option.
The stabilization and landfilling option involves removing the
sludge from the lagoon, stabilizing it onsite in a stabilization
facility, and hauling it to an approved chemical waste landfill.
However, the alternative can only be used if the sludge (class-
ified as a non-solid) is categorized as containing less than 500
ppm PCB. While the average PCB concentration in the sludge was
greater than 500 ppm PCB, the level of PCBs found in the sludge
ranged from 7.5 ppm to 2010 ppm. Therefore this alternative is
being considered in more detail.
In terms of the effectiveness criteria, onsite incineration and
offsite incineration compare similarly for disposal of the sludge
as for disposal of the oil.
" th the stabilization and landfilling alternative and the inciner-
ation alternatives will meet public health and environmental criteria
if operated and maintained properly, however, the risk of failure of
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the stabilization and offsite incineration .alternatives may
be somewhat greater than onsite incineration because of
the possibility of accidents during the transportation of the
sludge. Also, once the sludge is landfilled, there is always
the risk that leachate from the landfill may escape and contaminate
the environment around the landfill.
Stabilization and landfilling and offsite incineration would be
more favorable to the local community than the onsite incineration
alternative for the same reasons described under oil disposal.
Also, stabilization and landfilling would be slightly favored over
onsite incineration because the time to complete the stabilization
and landfilling alternative is on the order of 1 year whereas it
may take 3 year to complete the onsite incineration effort due
to the capacity of mobile or transportable units.
The costs for these alternatives are presented below. The costs for
the incineration alternatives include the same costs as that
described for the incinerators in the oil disposal alternatives.
The sludge stabilization and landfilling cost estimate includes
the cost for eguipment, materials and labor to stabilize the sludge
and the cost to haul the sludge to CECOS in Niagara Falls, New York.
Also, assumed in this cost estimate is that an estimated 60,000 yd3
(with a range of 40,000yd3 to 80,000yd3) of sludge will be
landfilled or incinerated.
Method Cost (Millions of Dollars)
Alternative 1- Onsite incineration 32.4
Alternative 2- Offsite incineration 129
Alternative 3- Stabilization and landfilling 25.8*
* This cost assumes that all of the sludge will be allowed to be
stabilized and landfilled. However, if some of the sludge contains
greater than 500 ppm PCB, then that portion would reguire incinera-
tion. Because of space limitations at the site, an onsite incinerator
and a stabilization facility could not both be located at the same
time. Therefore, any sludge that is removed and contains a PCB
concentration of greater than 500 ppm must be hauled and incinerated
at any offsite location. With this in mind, a sensitivity analyses
was performed which indicated that, if as little as 5 percent of
the sludge contains in excess of 500 ppm PCB, the cost for stabiliza-
tion and landfilling will increase to about the same'cost as onsite
incineration. Based on previous sampling and analysis, it is
likely that 5% of the sludge does contain greater than 500 ppm
PCB.
Subgroup C) Waste Disposal — Water
The methods which passed the initial screening of
alternatives were:
Alternative 1- Onsite Treatment
Alternative 2- Offsite Treatment
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Onsite treatment for the disposal for the BROS lagoon water involves
the construction of a treatment facility on the site, similar to the
facility that was utilized in the initial remedial action (see Site
History section). The waste water would be pumped through this
facility and treated and discharged to Little Timber Creek.
As in the initial remedial action, the discharge requirements would
entail meeting a TOC limit of 50 ppm on a 30 day average as well
as other various limitations specified by NJDEP in order to adequately
protect the water quality of the receiving stream.
The treatment system will include oil/water separation, flocculation
and sedimentation, granular activated carbon filtration, and sludge
handling facilities. The separated oil would be handled in the same
manner as the oil collected from the lagoon. The sludge generated by
the system would be taken to an approved landfill.
The offsite treatment option involves pumping the lagoon water into
tank trucks and hauling the water to a nearby industrial wastewater
treatment facility that has previously been contacted and is willing
to accept the waste.
In terms of the effectiveness criteria, both options compare equally,
however, there may be a greater risk in the offsite treatment option
in that there is a potential for a spill during hauling of the waste
water to the offsite treatment facility.
The average costs for onsite and offsite treatment are presented
below. The onsite treatment cost estimate includes the capital
cost for the treatment plant and the operation cost for the system
(labor, chemicals, energy, sludge disposal). The offsite treatment
cost estimates include labor (to load the hauling vehicle).
transportation costs and the disposal fees.
Assumed in the cost figures is that an average of 70 million gallons
(within a range of 44 to 95 million gallons) will be treated by the
system. The actual volume of water to be treated is highly
dependent upon the amount of rainfall accumulated over the next 2
to 3 years and the amount of sediment excavated from the lagoon.
Method Cost (Millions of dollars)
Alternative 1- Onsite Treatment 5.92
Alternative 2- Offsite Treatment 11.3
Subgroup D) Lagoon Waste Removal
As previously mentioned, all options that left the lagoon waste
in place were screened from further consideration and thus it
became evident early in the site evaluation process that the
waste needed to be removed. Therefore, the only analysis
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necessary is a discussion of possible removal techniques, the
order of removal of the various contaminants and buried drums
in and around the lagoon and a safety system design to ensure
that no additional contaminants enter the groundwater during
the removal operation.
The removal of the lagoon water would occur via pumping (a
straight forward and well established technology). The oil
will be removed first as a layer floating on top of the water.
The oil removal method involves using a floating oil skimmer pump
to pump the oil from the surface of the lagoon to an oil/water
separator. The oil effluent from the separator would then be sent
to a holding tank until it is ready to be fed to an incinerator.
The aqueous phase would be fed to the onsite treatment system.
The cost of this removal operation is estimated to be 400,000
dollars.
Removal of the contaminated sludge on the sides and bottom of
the lagoon, including an area that has been surficially contaminated
on the east side of the lagoon, the debris in the lagoon as
well as the oil layer in the Gaventa Pond and Little Timber
Creek, will likely be performed either via a dragline dredge or
sauerman (The PCB laden surficially contaminated soil must be
removed because it is located in a wetland area where various
birds and other wildlife habitate). Once the material has been
dredged, it would be placed in sedimentation bins for dewatering
and incineration. The water collected from the sediment will be
treated via the treatment system established for disposal of
the lagoon's aqueous phase.
It is estimated that the cost for dredging and dewatering will
be approximately 8.22 million dollars. This is based on removing
an estimated sludge volume of 60,000yd3 (within a range of
40,000yd3 to 80,000yd3). The sludge will be dredged until soils
appear which are not visibly contaminated. Visible contamination
is defined as the oily characteristics of the sludge. Once
non-oily sludge or soil is observed the initial excavation will
stop. At that point, additional sampling will be conducted and a
decision will be be made as to the need for additional excavation.
Also, sampling of the lagoon bottom will be performed during
design in order to better estimate the volume and concentration
of the sediment.
Another action included in the lagoon waste removal alternative
is tr.e exploration for buried drums around the site and their
disposal, should any be found. During sludge removal, the
dikes will eventually be removed thus exposing drums which have
been buried around the site. In addition, an access road will
likely be constructed around the lagoon for the excavation
equipment. Buried drums are again likely to be exposed. If
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the drums were not excavated, they are likely to be crushed by
heavy equipment on the site. Although the contents and condition
of these drums is unknown they were assumed to contain material
similar to what has been found at the site (including PCB's) and
they must be assumed to pose a future threat to groundwater due
to rupture and leakage. Therefore, these drums will be excavated
and disposed during the initial site preparation. Areas to be
dug include those sections around the lagoon where the magnetometer
survey suggests that buried ferromagnetic materials exist.
(See Drawing 0707.15-04 in RI/FS, July, 1984). Since little is
known about what may be found, it is roughly estimated that the
cost of the operation is 1.46 million dollars. This assumes
that 100 drums buried to a depth of 5 feet will be found,
examined and disposed of onsite by incineration or by water
treatment if appropriate.
Also included under this alternative is a maintenance pumping
system. The purpose of this system is to ensure that any
contaminant that may be released into the groundwater during
lagoon excavation is captured and treated, as well as preventing
the groundwater plume from advancing any further. This alternative
will remain in place until a final groundwater cleanup alternative
is determined as a result of the second phase RI/FS. In addition,
this alternative will consist of monitoring the groundwater to
ensure that it is working effectively. This alternative will
basically just consist of maintaining the level of liguid in
the lagoon, by pumping the aqueous phase through the waste
treatment system, below the level of the groundwater table. In
that way, the groundwater gradient would be towards the lagoon
and therefore, additional contamination of the groundwater,
which may occur during the excavation operation, will be prevented.
Also, with the groundwater flowing into the lagoon, it is
likely that the contaminated soils under the lagoon will be
cleansed thus reducing the need for additional soil excavation.
This option will be further developed during design. Other
systems, such as a well Dumping system will also be examined
during design. It is anticipated that a flow rate of between
500 and 700 gpm would have to be maintained in order to keep
the liguid level of the lagoon below the level of groundwater
table. The cost of this system includes an increase in size of
the agueous phase onsite treatment facility, and a groundwater
monitoring system. The cost is estimated to be about $1,500,000.
This also includes the incremental cost in operation and maintenance
of the aqueous phase on site treatment system. It is assumed
that the system would run for about 180 days during the first
phase excavation.
Subgroup E) Lagoon Closure
Two options are feasible for the final closure of the BROS
lagoon. These are:
Alternative 1- Backfilling and revegetation
Alternative 2- Revegetation and leaving the lagoon as a pond
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Under the backfilling option, the lagoon would be backfilled to
above the high water table elevation and then revegetated. The
lagoon would be contoured such that rainwater runoff would
discharge into Little Timber Creek Swamp. A security fence
would also be provided.
Under the pond option, the lagoon would not be backfilled. The
lagoon sides would be contoured and revegetated, and the cleared
lagoon would remain as a pond. A security fence would also be
provided. Since the lagoon would have already been dredged and
the sludge layer removed, the lagoon water level would fluctuate
with the water table and the lagoon level would not rise as it
does now.
In terms of effectiveness criteria, both options are fairly
comparable except that the backfilling option would likely
achieve a higher level of isolation in that it would more
effectively reduce human contact to the former lagoon area.
The pond option might encourage human contact in that a pond
would remain and people could trespass and go swimming. If
contaminated materials were left in the pond, a problem could
arise.
The costs for the two closure options are presented below:
Option Cost (millions of dollars
Capital Cost 30-year O&M"
Alternative 1 - Backfilling 1.7 .141
and revegetation
Alternative 2 - Revegetation and .211 .203
leaving the lagoon as a pond
The cost of backfilling and revegetation is based on an average of
60,000yd3 (within a range of 40,000yd3 to 80,000yd3) of backfill
material being placed in the lagoon. Also included is backfilling
with rock to the water table for stability, followed by gravel
sand, and common borrow to achieve the desired contours. The O&M
costs include sampling and analysis of offsite surface water twice
year. The costs for revegetation include hauling and spreading top
soil as well as some grading. The O&M costs include sampling and
analysis of the pond water twice a year.
Group 2) Tank Farm
The only two alternatives that passed initial screening for the tank
farm are:
Alternative 1- Removal of tank wastes and cleaning of tanks
Alternative 2- Complete removal of tanks and contained waste
materials
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In terms of effectiveness criteria, comlete removal of the tanks
and waste is superior to the option of just removing the waste.
The removal of the tanks will provide the needed work area when
lagoon cleanup activities commence. An examination of Figure 2
shows limited area for the amount of equipment that would be
brought onto the site. This includes an onsite incinerator
unit typically consisting of 7 trailers plus support facilities,
mobile water treatment units, sedimentation bins (as previously
described) as well as heavy earth moving equipment. In order
to work safely and effeciently during the clean up operation,
the tanks must be removed to provide adequate work space. This
is also true if an offsite incineration option is selected.
Room would be needed for earth moving equipment as well as
sedimentation bins. In addition, an area would have to be
provided to load the many hundreds of trucks that would be
necessary to haul the contaminated material to the offsite
facility.
The costs for both options are presented below. They include
removal, transportation disposal of the waste at an off site
facility, cleaning of the tanks and demolition as appropriate.
Offsite disposal is necessary because the on site treatment
facility will not be available until the tanks and their contents
are removed and there are no other viable means for onsite
disposal.
Method Cost (millions of dollars)
Alternative 1- Removal of tank waste and 3.53
cleaning of tanks
Alternative 2- Complete removal of tanks and waste 4.14
Group 3) Residential Wells
After the initial screening of alternatives, all three options
were retained for further consideration. These options are:
Alternative 1- No action except for monitoring
Alternative 2- Carbon filtration of each well
Alternative 3- Pipeline extension from the terminus of the Penns-
grove Water System
"Jternative 4- Pipeline extension from the existing pump station
As previously mentioned, only ten residential wells are threatened
by the BROS plume in the next ten to twenty years (see Area 1 on
Figure 4). The above options, theref^^e, address remediation of
those wells only.
Alternative 1) No Action/Monitoring
This alternative involves quarterly sampling of all ten wells for
volatile organics and annually for priority pollutants. Also
included would be the sampling of six monitoring -wells to determine
if a plume "wave front" was approaching the wells.
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Alternative 2) Carbon Filtration of Each Residential Well
This option involves installing a granular activated carbon
filter on each residential well. Monitoring as described under
the no action alternative would be required except that both
carbon filter influent and effluent sampling would be necessary.
Alternative 3) Alternate Water Supply - Pipeline from the terminus
of the Pennsgrove Water Supply Company
This option involves the installation of a potable water pipeline
from the Pennsgrove water system, at its terminus on Steelman Avenue,
to the affected residents, including hookups.
Alternative 4) Alternate Water Supply - Pipline from existing pump
station
This option involves the installation of a potable water pipeline
from the terminus of the Pennsgrove water system (at Steelman Avenue)
to the affected residents, including hookups. Also included is a
new water main from the terminus of the system to an existing
pumping station near the municipal water supply well at Station Avenue
In terms of effectiveness criteria for each of the alternatives,
the 2 pipeline options are superior. They have an extremely low
risk of failure and will isolate the residents from the groundwater,
contamination as compared with the other non-pipeline alternatives.
Also, the pipelines will be more favorably recieved by the local
community because it will provide a safer supply of water than the
other options.
The cost for the 4 options are presented below. Alternative 3
costs include a 6 inch diameter pipeline for a length of 8000
feet from the terminus of the system to the 10 affected homes,
including ten home connectors. Alternative 4 costs include, for
estimation purposes, installation of 3,300 feet of 8 inch pipe
from the existing pumping station to the terminus of the system
and then 8000 feet of 8 inch pipe from the terminus of the system
to the 10 affected homes, including ten home connectors. The O&M
costs for these two alternatives includes the cost for water
service and the base annual service charge. The carbon filters
capital costs include material and installation costs. O&M costs
include carbon replacement, monitoring and analytical requirements.
The no action option has no capital costs. The O&M costs for
the no action alternative include labor and analytical costs for
monitoring.
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Option Cost (millions of dollors)
Capital Annual J3&M Total Present Worth
No Action/Monitoring 0 .048 .30
Carbon Filtration .020 .051 .50
*Water Pipeline (From .29 .002 .31
Terminus)
*Water Pipeline (From ' .48 .002 .50
Pump Station)
*Actual length and pipe size will be determined during the detailed
design phase
Group 4) Groundwater
The only two alternatives that passed initial screening for the
groundwater control alternative were:
o No action
o Groundwater extraction and treatment
Alternative 1) No action:
This alternative involves taking no action to prevent the migration
of contaminated groundwater or to clean up the contaminated
groundwater. However, this alternative does include a long-term
groundwater monitoring program to track the plume.
Alternative 2) Groundwater Extraction and Treatment:
This alternative involves placing 32 extraction wells in and around
the BROS lagoon, and pumping these wells at a rate of 20 gpm in
order to remove the contaminated groundwater from the underlying
aquifer thus cleaning the groundwater. The extracted groundwater
would be treated via activated carbon to remove the contaminants,
and the treated water would be discharged to Little Timber Creek.
This alternative would operate until the groundwater achieves
either drinking water guidelines or background levels are achieved.
A five year operating period is expected. In addition, groundwater
monitoring programs as proposed in the no action alternative
would also be required.
In terms of effectiveness criteria, the groundwater extraction
and treatment alternative is far superior than the no action
alternative. In particular, the groundwater extaction alternative
would clean up the groundwater to drinking water levels whereas
the no action alternative would let the contaminated plume enter
Little Timber Creek and Cedar Swamp. Also, the groundwater
extraction alternative would meet appropriate environmental
standards, and the groundwater extraction alternative could make
this groundwater resource usable once again as a potential water
supply aquifer.
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The costs for the two options, including monitoring, are presented
below. The cost for the no action alternative inludes just monitor-
ing costs. The costs for the extraction alternative include instal-
lation of 32 wells> pump, piping, etc. The O&M cost include rental
of activated carbon units, monitoring, labor costs, etc. This
alternative is anticipated to operate for 5 years.
Option
Cost (Millions of Dollars)
Capital Annual O&M-
30 year
Present Worth
.281
6.24*
No Action Monitoring 0 .03
Groundwater Extraction .83 1.46
and Treatment
* 5 year Present Worth
Table 7 represents a summary of all the alternatives and their
estimated costs.
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TABLE 7
Cost Summary
Alternative Capital
I . Lagoon
A. Waste Disposal-Oil
- Onsite incineration 2
- Offsite incineration 8
B. Waste Disposal-Sediment
- Onsite incineration 32
- Offsite incineration 129
- Stabilize and landfill
offsite (PCB < 500 ppm) 25
C. Waste Disposal - Aqueous
- Onsite treatment 5
- Offsite treatment 11
Cost
.65
.66
.4
.0
.8
.92
.3
D. Lagoon Waste Removal (only alternative
-Remove Oil
- Remove Sludge
- Buried Drum Excavation
- Maintenance pumping
E . Closure
- Backfill Lagoon
- Leave as Pond
II. Tank Farm
- Tank Cleaning and Waste
Removal
- Tank Demolition and
Removal
II. Residential Wells
- No Action
- Carbon Filtration
- Alternate Water Supply
.4
8.22
1.46
1.50
1.7
.211
3.53
4.14
-
.02
.29
30 Year Total Present
O&M Worth
2.65
8.66
32.4
129.0
25.8
5.92
11.3
available)
.4
8.22
1.46
1.50
.141 1.84
.203 .414
3.53
4.14
.30 .30
.48 .50
.02 .31
(from terminus)
- Alternate Water Supply
(from pump station)
.48
.02
50
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Alternative
Capital Cost
30 Year Total Present
IV. Groundwater
- No Action -
- Active Groundwater Controls .83
- Groundwater Monitoring
(Required for any groundwater
alternative)
Note: All costs in millions of dollars
*5 year present worth
O&M
.281
5.41*
.281
Worth
.281
6.24
.281
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Community Relations
In March 1983, EPA held a meeting regarding implementation of
the initial remedial measure at the BROS site. In addition,
EPA made a public presentation of the remedial investigation
and feasibility study work plan for the BROS site. Notification
of the meeting was accomplished through newsreleases and Township
mailings. Attachment 1 is a list of attendees from the meeting.
In general, the public seemed pleased that we were implementing
an initial remedial measure at the lagoon. They also understood
why we had to do additional studies to determine the most cost
effective long term remedial plan. However, they were upset
that the study would take so long. Also, they claimed that we
have sufficient information to make a decision.
In particular, they were concerned about their drinking water
supplies that have been contaminated by the BROS site. They
were concerned that it would take nearly a year before a decision
would be made as to whether or not a water line could be con-
structed. The public felt that action should be taken now.
On July 9, 1984, EPA made the draft Remedial Investigation/
Feasibility Study (RI/FS) available for public comment at
select locations in Gloucester County. In addition, the Agency
met with the Logan Township Council on July 17, 1984 to explain
the findings of the report. After that meeting a public meeting
was set up for August 22, 1984. The public comment period was
opened until August 31, 1984. Notification of the meeting was
handled by EPA. An attendance sheet is attached as Attachment
2. EPA and NUS Corporation made a presentation on the RI/FS
findings and recommendations. The responsiveness summary that
was prepared is based on public comments received at the meeting
and is attached as Attachment 3. In general, however, the
public was opposed to onsite incineration. This was due to the
negative experience that they have had with a nearby hazardous
waste incinerator, as well as their perception of the efficiency
of the technology. In addition, EPA received 3 comment letters
regarding the RI/FS. Copies of those letters and EPA responses
are attached as Attachment 4.
Consistency With Other Environmental Laws
The final recommended remedial alternatives for BROS will require
the removal and disposal of oil, wastewater and sludge from
the lagoon; removal and disposal of the contents of the tanks
as well as the dismantling of the tanks; surficial cleanup of
contaminated soil; and provision for an alternate water supply.
The treatment and disposal of oil, and PCB contaminated sediments
from the lagoon will be performed via incineration in accordance
with applicable substantive RCRA and TSCA requirements. The waste
materials in the tanks and the tanks themselves will be disposed
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of in an offsite treatment facility or landfill that complies
with RCRA and TSCA. The contaminated soil that contains levels
of PCBs over 500 ppm will also be treated and disposed of via
incineration in accordance with the substantive requirements of
TSCA and RCRA. Compliance with the Safe Drinking Water Act
will be the responsibility of the water purveyor.
Recommended Alternatives
According to 40CFR Part 300.68(j), cost-effectiveness is described
as the lowest cost alternative that is technically feasible and
reliable and which effectively mitigates and minimizes damage
to and provides adeguate protection of public health, welfare
and the environment. Evaluation of the suggested remedial
alternatives leads to the conclusion that alternatives shown in
Table 8 are the cost-effective options for the BROS site.
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Table 8
Recommended Alternatives
Group #1 Lagoon;
Subgroup A) Waste Disposal-Oil
Alternative 1 - Onsite incineration*
Subgroup B) Waste Disposal-Sediment
Alternative 1- Onsite incineration*
Subgroup C) Waste Disposal-Aqueous Phase
Alternative 1- Onsite treatment
Subgroup D) Lagoon Waste Removal
Alternative 1- Remove oil phase, aqueous phase,
sediments, buried drums and maintenance
pumping
Group #2 Tank Farm
Alternative 2- Tank demolition and removal
Group #3 Residential Wells
Alternative 4- Alternate Water Supply (From existing
pump station)
Additional Studies
- 2nd phase RI/FS to determine appropriate
groundwater cleanup and lagoon
closure remedies.
*0nsite incineration was found to be cost effective, however,
final design criteria and implementation costs will be considered
before determining whether the wastes will be disposed of either
on or off site.
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The above referenced alternatives are technically feasible and
reliable and, when combined, provide adequate protection for
public health, welfare and the environment. Preceding the
detailed alternative evaluation, it was determined that the
only solution to the problems and potential problems posed by
the BROS site, as well as to meet the requirements of other
environmental laws, was to remove and dispose of the contents
of the lagoon, therefore, Group #1 (lagoon) evaluated the most
cost effective methods of performing that task. In most cases,
the cost was the decisive criteria or determining factor. The
disposal of the lagoon oil via onsite incineration was significantly
less costly than shipping the oil to an offsite facility (by
approximately 6 million dollars). The local community, however,
does object to onsite incineration. Nevertheless, the cost
difference between on and offsite incineration significantly
favors onsite incineration, therefore, onsite incineration is
recommended.
In terms of sediment disposal, it was least costly to stabilize
the sludge/sediments and dispose of them at a landfill. However,
this would only be the case if less than 5% of the sediments
contain PCBs greater than 500 ppm. If more than 5% of the
sediment contain in excess of 500 ppm PCB, then onsite incineration
is more cost-effective. (Offsite incineration is likely to be
subtantially more costly than onsite incineration). Based on
sampling results, it is likely that more than 5% of the sediments
contain greater than 500 ppm PCBs. In addition, sampling to
determine PCB concentration of the sludge in every truck load
exiting the site would not be practical and the burden of proof
would be on the generator (EPA) to demonstrate that all sludge
removed from the site had a concentration of less than 500 ppm.
Therefore, as with the oil disposal option, onsite incineration
is recommended as the disposal option for the lagoon sediments.
It should be noted, that incineration of the lagoon waste can
be performed either onsite or at an offsite .location. Final
design criteria and implementation costs will be considered in
selecting the most appropriate incineration location. However,
the cost estimates contained in the RI/FS suggest that onsite
incineration at BROS is the most economical method for disposal
of both the lagoon oil and sediments.
In terms of aqueous disposal, it was least costly to dispose of
the lagoon water via an onsite treatment system. All other
criteria involving on and offsite treatment alternatives were
essentially the same. The onsite treatment system would consist
of an oil/water separator, floculation/sedimentation and granular
activated carbon units and sludge treatment units.
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.*.
As discussed in the Alternatives Evaluation section, removal of
the waste is the only alternative available which allows compliance
with other relevant laws. The method of removal is discussed
in that section. Included in this alternative is a maintenance
pumping system and monitoring to ensure that any contaminants
that are released into the groundwater during the excavation of
the lagoon are captured and treated and the identified contaminated
plume does not advance any further. Other removal methods may
be evaluated during the final design and value engineering
phases of this project.
It should also be noted that since the lagoon cleanout may not
begin for two years, that it is recommended that a dike inspection
should be performed during design and that necessary corrective
action be taken, if deemed appropriate, to ensure that the dike
does not fail in the interim. Also, as mentioned in the Current
Site Status section of this document, additional characterization,
of the lagoon sediments, in terms of concentration and volume,
will be performed during design.
The closure of the lagoon involved either leaving it as a pond
and revegetating it, or backfilling the lagoon and revegetating
the new ground surface. In evaluating the alternatives, it
appeared as though the backfilling alternative was more effective
than the pond alternative to achieve a higher level of isolation
in terms of human contact. However, the cost of backfilling
the lagoon was about 1 million dollars more than leaving it as
a pond. During the dredging of the lagoon sampling will occur
within the pond to determine the efficiency of the dredging
process and how effectively the contaminants were removed. At
that point, a study will be initiated to determine the exact
closure option.
Group #2 evaluated whether to remove the contents from and
clean the tanks, or whether to remove the contents from the
tanks and clean and remove the tanks themselves from the site.
In the effectiveness criteria evaluation, complete removal of
the tanks was found to be superior compared to just cleaning
them out. Although the cost for removing the tanks is $600,000
more than leaving them, the removal of the tanks was determined
necessary to accommodate the eguipment (described in the
Alternative Evaluation Section) that is reguired to remove and
dispose of the contaminated materials in the BROS lagoon.
Therefore, it is recommended to clean and remove the tanks from
the BROS site.
Group #3 evaluated the actions to be taken to remediate the
problems with the residential wells. These actions include, no
action/ monitoring, individual carbon filtration units, and 2
pipeline extension alternatives for the Pennsgrove Water System.
In terms of effectiveness criteria, the pipeline extension
alternatives are clearly superior to the other alternatives.
They will provide a safer and more reliable source of water to
the homes, and allay any concerns that private wells may become
contaminated at some future time. As previously mentioned, the
contaminated groundwater plume is moving in the direction of
those residences and may eventually contaminate the wells. A
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cost evaluation for these alternatives indicate that the no
action/monitoring alternative and the pipeline extension from
the terminus of the system are equal in cost, with the pipeline
extension from the pump station being the next least cost
alternative. However, since it has been demonstrated that
contamination has been detected in the area of the private
wells and that the groundwater plume is heading in the direction
of the wells, the no action/monitoring alternative was deleted.
Moreover, the condition of the existing municipal water system is
extremely poor. The system was constructed in 1904 with the
majority of pipelines being constructed of cast iron. Many of
these pipes are deteriorated and in conversations with the Township
Engineer it has been indicated that many people barely get a
"trickle" out of their taps. Therefore, extension of the system
from its terminus would result in insufficient pressure (<20psi)
at the new connections and seriously jeopardize pressure for
existing customers. Based on these technical consideration this
alternative is eliminated. The next least costly alternative,
the carbon filtration system, was eliminated from further
consideration because of its lack of reliability over a long
period of time. Breakthrough of the system may occur and not
be detected for weeks or months, and therefore can cause a
public health concern. The extension of the pipeline from the
existing pump station would provide a water line, with adequate
pressure, to the new connections. Therefore, it is recommended
that the pipeline extension from the existing pump station be
implemented.
Group #4 evaluated qroundwater control options which included
no action/monitoring, and groundwater extraction, treatment and
monitoring. However, the soils beneath the sludge layer in the
lagoon have not been sampled, but are likely to be contaminated
with solvents because of their presence in the groundwater.
Therefore, additional sampling of this soil will be performed
during the sludge excavation and disposal phase of the project.
This information will enable an assessment of future conditions
and the need for additional remedial action. For instance, if
the contaminated soil continues to serve as a groundwater
contamination source which causes concentration above safe
drinking water levels, then available alternatives include
establishing alternate concentration limits, pumping and
treating, soil excavation, or a combination of the above. While
it is recognized that the groundwater must be remediated, a
decision on the exact method of groundwater cleanups is therefore
deferred until this assessment is completed. However, as
previously discussed, maintenance pumping will be performed
during the cleanup of the lagoon in order to ensure that the
contaminated plume doesn't spread any further. This pumping
will be maintained until a long term cleanup stategy is determined
and implemented.
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In summary, the following activities are recommended for approval:
-Installation of a potable-water pipeline from the Pennsgrove
Water Supply Company, from the existing pump station, to the
affected residents
-Complete removal of the tank wastes and tanks
-Removal and onsite incineration of the lagoon oil
-Removal and onsite incineration of the lagoon sediment
-Removal and onsite treatment of the lagoon water
-Excavation and incineration of buried drums
-Maintenance pumping
The determination as to whether incineration will take place onsite
or at an offsite location will be detemined during final design
and the competitive bidding process.
The following represents the cost estimates for the proposed
action. Cost sharing for project implementation is 90% Federal
and 10% State on capital costs. Water usage costs will be borne
by the individual residential consumers. Post closure monitoring
costs will be borne by the State of New Jersey.
Action
LAGOON
°0il removal
°Sediment removal
"Onsite incineration
of oil
°Onsite incineration
of sediment
"Onsite treatment
of water
°Drum excavation
and incineration
"Maintenance pumping
and monitoring
TANK FARM
"Complete removal of
tanks and wastes
Capital Cost
$400,000
$8,220,000
$2,650,000
$32,400,000
$5,920,000
$1,460,000
$1,500,000
30 Year O&M
Present Worth
$4,140,000
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RESIDENTIAL WELLS
"Water supply pipeline $482,000 $20,000
(From existing pump station)
ADDITIONAL STUDIES
°2nd Phase RI/FS (determine $500,000
closure option and final
groundwater cleanup option)
Total Capital Cost $57,672,000
WETLANDS AND FLOODPLAINS
Executive Order 11990 provides for the protection of wetlands
when Federal agencies conduct construction activities. The marshy
area adjoining the BROS site is a wetland. There is no practicable ^
alternative to the selected alternative, and the selected alternative
includes all practicable measures to minimize harm to wetlands. ^
Executive Order 11988 contains requirements for Federal
agencies to avoid adverse effects in floodplains. The BROS lagoon
site is located in a 500-year floodplain, it is not located in a
100-year floodplain. The selected alternative is consistent with
the requirements of the Executive Order and implementing guidance
for 500-year floodplains.
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OPERATION AND MAINTENANCE (O&M)
' I
The operation and maintenance activities involved in this phase
of the project only include the water user charges to the
residential homes. The water user charges will be borne by the
residents.
The annual O&M cost for the 10 residential homes is estimated
to be 2000 dollars a year.
SCHE PULE
- Enforcement action has essentially
ceased with a signed consent decree.
However, some additional investigation
to identify PRPs may begin shortly.
- Final Record of Decision
- Amend State Superfund Contract
- Award IAG for Design
- Start Design
- Complete Design
- Start Phase Construction
- Start 2nd Phase RI/FS
- Complete Construction
DATE
December 31, 1984
December 31, 1984
December 31, 1984
January 15, 1985
January 15, 1986
October 1, 1S85
October 1, 1987
September 1, 1990
It is anticipated that this project will be phased. The first
activity will be the construction of the water pipeline and the
removal of the tanks. Removal of the tanks is a necessary first
step in order to provide sufficient work area for the lagoon
removal and disposal activities. Once the lagoon removal and
cleanup activities are initiated, a 2nd phase RI/FS will begin
for the purpose of determining the cost effective groundwater
cleanup approach and determining the final lagoon closure
alternative.
FUTURE ACTIONS
Upon approval of the recommended remedial action, as outlined in
the Recommended Alternative section, the design of those actions
will commence. The design will include the preparation of plans
and specifications for the recommended remedial alternatives.
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During design, additional sampling will take place to further
define the extent of PCR contamination in the sludges and the
underlying soils leading to a confirmation of the volume of
material requiring excavation. After completion of design, the
recommended remedial actions will be implemented. As previously
mentioned, the data indicates that PCB's are closely associated
with the presence of oily wastes and therefore the sludge/sediments
in the lagoon will be excavated until nonoily soils which are
beneath the sludge layer are observed. This sludge excavation
represents the first phase of the lagoon cleanup. The need for
a second excavation phase will be assessed in a study which
will determine the cost-effectiveness of additional excavation.
The study will specifically address groundwater solvent contamination,
residual PCB contamination of the lagoon, and the procedure for
final closure of the lagoon. The second phase analysis will be
conducted during the sludge excavation and disposal phase so
any additional remedial measures can be implemented immediately
following the first phase excavation.
The second phase study will address groundwater contamination.
Sampling results indicate that PCB's have not been carried away
from the site by the solvents which are found- in the groundwater.
However, the soils beneath the sludge layer are likely to be
contaminated with these solvents because of their high
concentration in the groundwater. Since the solvents are in
equilibrium with the soil matrix, they may continue to be
released into the groundvater after the sludge layer is removed
and the existing contaminated groundwater is pumped and treated.
Additional sampling of the soil beneath the sludge layer will
identify the distribution of the contaminants and their potential
for leaching into the groundwater and the lagoon. This
information will enable an assessment of future conditions and
the need for additional remedial action.
If the contaminated soil will continue to serve as a source
which causes concentrations above safe drinking water levels
then available alternatives consist of establishing Alternate
Concentration Limits, pumping and treating, soil excavation,
or a combination of the above. The groundwater model which has
been developed for the site can be used to determine the well
placement and pumping duration which will be required to capture
different quantities of contaminants released"from the soil.
This will enable an analysis of different soil excavation and
groundwater pumping scenarios leading to the determination of a
cost-effective strategy for complete restoration of the
groundwater and the site.
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