United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R02-86/029
Sept 1986
V-/EPA
Superfund
Record of Decision
Caldwell Trucking, NJ
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TECHNICAL REPORT DATA
(Please read Instniciions on the reverse btfore completing)
1. REPORT NO.
EPA/ROD/RO 2-86/029
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Caldwell Trucking, NJ
5. REPORT DATE
September 25. 1986
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
O. ABSTHACT
The Caldwell Trucking Company site is a 12.2-acre property in Fair field Township,
Essex County, NJ which is bordered by light industry to the north, west, and southwest
and is directly across from the Essex County Airport property. Approximately 45 small
businesses are situated within one mile of the site. The nearest major residential area
is about 1,000 feet northeast of the site. The Passaic River is located about 4,000
feet northeast and is used as a public water supply. Numerous residential wells north
of the site are no longer in use and most of the residents now use municipal water. The
Caldwell Trucking Company was incorporated by the State of NJ in 1946 for the purpose of
cleaning residential septic tanks. For a number of years, Caldwell emptied septic
systems and transported the waste to an old slaughter house property (now part of the
Caldwell site) for disposal in one of the open, unlined lagoons present on site. Based
on information supplied by Caldwell in 1973, wastes would be treated with a disinfectant
such as sodium hypochlorite and allowed to settle. Later, the "clarified" liquid layer
would be pumped out and transported by tank truck to a large seepage lagoon where the
liquid would percolate quickly through the sandy soil. In the mid-1950s light industry,
developing in the area, may have discharged hazardous substances into their septic
systems to be subsequently pumped out and deposited on the Caldwell property. There
were also other trucking companies who brought septic substances to the site, which may
(See Attached Sheet) ___
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Caldwell Trucking, NJ
Contaminated Media: gw, sw, soil, sediment
Key contaminants: PAHs, PCBs, PCE, TCE,
VOCs, inorganics, lead
8. DISTRIBUTION STATEMENT
19. SECURITY CLASS IThis Report)
None
21. NO. OF PAGES
66
20. SECURITY CLASS tThii page I
None
22. PRICE
EPA Form 2220-1 (R«». 4-77) PREVIOUS EDITION is oaioierc
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EPA/ROD/RO 2-86/029
Caldwell Trucking, NJ
16. ABSTRACT (continued)
have been mixed with hazardous wastes. There are also indications that
spent solvents and other industrial liquid wastes were disposed of in onsite
lagoons. In 1972 seepage and odors from the site revealed that Caldwell was
disposing of septic waste in this manner without the necessary permits.
They were licensed to transport waste but were not an approved disposal
facility. A 1973 application to operate as a sanitary landfill was denied
by the NJDEP. Subsequently, Caldwell backfilled all lagoons except one,
which was covered with plywood. At the start of the RI in 1982, the
Caldwell property showed almost no visible signs of a septic waste disposal
facility. The source of contamination, which had been deposited in unlined
lagoons, had been backfilled 12 years earlier. The primary contaminants of
concern include: VOCs, TCE, PCBs, PAHs, inorganics, and lead.
The selected remedial action includes: excavation and treatment, via
heat addition, of approximately 28,000 cubic yards of contaminated soils and
waste materials; disposal of treated soils in a secure landfill to be
constructed at the site in accordance with RCRA requirements; restoration of
a last potable water resource by providing treatment, via air stripping, of
municipal public water supply well number 7; provision of an alternate water
supply for residents potentially affected by ground water contamination from
the site; preparation of a supplemental RI/FS to identify the extent and
other sources of ground water contamination and to develop and evaluate
appropriate remedial alternatives. Estimated capital costs for this
remedial action are $5,490,000 with annual O&M costs of $48,000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site
Caldwell Trucking Company, Township of Fairfield, Essex County,
New Jersey
Documents Reviewed
I am basing my decision on the following documents, which provide
a thorough analysis of the remedial alternatives considered for
the Caldwell Trucking Company site:
- Results of investigations and sampling conducted by the
New Jersey Department of Environmental Protection at
or near the site over a period of years
- Remedial Investigation, Caldwell Trucking Company Site,
prepared by NUS Corporation, June 1986
- Feasibility Study, Caldwell Trucking Company Site, pre-
pared by NUS Corporation, June 1986
- Responsiveness Summary, August 1986
- Staff Summaries and Recommendations
Description of Selected Remedy
- Excavation and treatment, via heat addition, of approxi-
mately 28,000 cubic yards of contaminated soils and
waste materials.
- Disposal of treated soils in a secure landfill to be
constructed at the site in accordance with Resource
Conservation and Recovery Act requirements.
- Restoration of a lost potable water resource by providing
treatment, via air stripping, of municipal public water
supply well number 7.
- Provision of an alternate water supply for residents
potentially affected by ground water contamination from
the site.
- Preparation of a supplemental remedial investigation and
feasibility study to identify the extent and other
sources of ground water contamination and to develop and
evaluate appropriate remedial alternatives.
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-2-
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the remedy described above,
which includes operable units involving control of the source
of contamination and restoration of a contaminated public water
supply well, is cost-effective and consistent with a permanent
remedy.
It is hereby determined that implementation of this remedy is
the lowest cost alternative that is technologically feasibile
and reliable, and which effectively mitigates and minimizes
damages to and provides adequate protection of public health,
welfare and the environment. Implementation of these actions
is appropriate at this time, pending a determination of the
need for any further remedial actions. It is also hereby
determined that implementation of the selected remedy is
appropriate when balanced against the availability of Trust
Fund monies for use at other sites.
The State of New Jersey has been consulted and agrees with the
selected remedy.
J l\^iS^f
>J
Date Christopher J. Daggett
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
CALDWELL TRUCKING COMPANY SITE
SITE LOCATION AND DESCRIPTION
The Caldwell Trucking Company site is located at 222 Passaic
Avenue in Fairfield Township, Essex County, New Jersey. This
12.2-acre property comprises Lot 17 of Block 2201 and Lots 18
and 20 of Block 2302 on local tax maps. The site is immediately
adjacent to the General Hose Products facility at 30 Sherwood
Lane, which is designated as Lot 7 of Block 2302.
The property is bordered by light industry to the north, west
and southwest and is directly across from the Essex County Air-
port property. Approximately 45 small businesses are situated
within one mile of the site (see Figure 1), most of them to the
southwest and northwest. Several of these businesses have
wells that supply water for various commercial operations. Also,
several use well water as their potable-water source for employees.
The community facility nearest the site is the Essex Regional
High School, located approximately 200 feet to the east but at
a higher elevation. This school has approximately 1800 students
in grades 7 through 12 and serves Fairfield, Roseland, North
Caldwell, and Essex Fells. The school is supplied with water
from the North Caldwell Water Department, which uses wells
located in Essex Fells. Essex Fells is located approximately
3.5 miles south (upgradient) of the site.
The nearest major residential area is about 1000 feet northeast
of the site. The Passaic River is located about 4000 feet
northeast (downgradient) of the site and is used as a public
water supply with an intake approximately 2.2 miles downstream.
Numerous residential wells north of the site are no longer in
use and most of the residents now use municipal water. Addition-
ally, two Fairfield Township municipal wells (Nos. 2 and 7)
were taken out of service in 1981 and 1982 due to ground water
contamination.
The site is located on glacial deposits of clay, sand, gravel
and boulders overlying the Preakness Mountain Basalt Formation,
a fractured igneous rock. The ground water is used for public
and private water supplies and for industrial purposes. The
major component of ground water flow has been found to be north
across the site and then north and east to the Passaic River.
While much of Fairfield is situated on an extensive flood plain
of the Passaic River, the site itself is located in a hilly
area in the eastern part of the Township well above the floodplain.
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-2-
BASE MAP IS A PORTION Of THE U.S.OA POMPTON PLAINS.NJ OUAOMNOUE(7.9 MMUTE SEMES. 999,PHOTOAEV6£0 661)
AND A PORTION Of THE CAIDWELL, NJ QUAOAANOLE t? 9 MINUTE SCMCS, »»4. PHOTOREVUEO19641
CONTOUR INTERVAL 80. FIGURE-1
LOCATION MAP
CALDWELL TRUCKING CO. SITE, FAIRF1TLD TWP..NJ
SCAL£>r«200tf
CX3RPORATON
A Halliburton Company
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-3-
SITE HISTORY
The Caldwell Trucking Company (Caldwell) was incorporated
by the State of New Jersey on May 17, 1946 for the purpose of
cleaning residential septic tanks. For a number of years after
World War II, Caldwell emptied septic systems and transported
the waste to an old slaughterhouse property for disposal.
Between 1948 and 1954, Caldwell acquired the various parcels
that make up Lots 17 & 20 to the rear of 222 Passaic Avenue and
angle around the back of Heisler Machine and Tool Company
(Heisler) and General Hose Products (General Hose). Figure 2
shows the relative locations of these properties. Due to the
rural nature of the Fairfield area up through the mid-1950's,
it is unlikely that anything other than septic waste would have
been brought to the site prior to 1954. Similarly, 1954 would
be the earliest date that septic waste could have been deposited
in one of the open, unlined lagoons on Lot 17 (south of Heisler).
Based on information supplied to the New Jersey Department of
Environmental Protection (NJDEP) by the Caldwell Trucking
Company in March 1973, wastes would be treated with a disinfectant
such as sodium hypochlorite and allowed to settle. Later, the
"clarified" liquid layer would be pumped out and transported by
tank truck to the large seepage lagoon at the rear of Lot 20, ...
near General Hose, where the liquid would percolate quickly
through the sandy soil.
Sometime in the mid-1950's, light industry began to develop in
the Fairfield area, although sewer mains were not installed un-
til the late 1970's. Some of these industries may have discharged
hazardous substances into their septic systems, to be subsequently
pumped out and deposited on the Caldwell property. There were
also other trucking companies who brought septic substances to
the site, which may have been mixed with hazardous wastes.
Finally, there are indications that spent solvents and other
industrial liquid wastes were disposed of in on-site lagoons.
In 1972, seepage and odors from the site revealed that Caldwell
was disposing of septic waste in this manner without the neces-
sary permits. The company was licensed to transport such
materials but was not an approved disposal facility. A 1973
application to operate as a sanitary landfill was denied by the
NJDEP. Alternatively, Caldwell purchased several large tanks
that allowed it to transport and store septic waste, but not
physically dispose of it. Subsequently, the Company backfilled
all lagoons except one, which was covered with plywood. As of
1984, when the U.S. Environmental Protection Agency (EPA) initi-
ated its remedial investigation and feasibility study (RI/FS),
these storage tanks were empty and the Company's operations
reduced to that of a transporter with no active storage capability,
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GENERAL
IMUS
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-5-
Ground water contamination in the area first became apparent
around 1970, when chlorinated hydrocarbons were detected in an
industrial well near the site. In the mid-1970's, private
wells on Orlando Drive, 1200 feet north of the site, were shown
to contain carbon tetrachloride and trichloroethylene and hence
were closed. In 1980, the NJDEP began an extensive sampling
program of private wells in the area. On February 4, 1982, the
Fairfield health officer was notified that wells on Pier Lane,
2400 feet north of the site, showed extremely high levels of
several chlorinated hydrocarbons. In March 1982, the NJDEP
recommended that public water be provided to all residents
between the site and the Passaic River. Connection was not
mandatory, but most of the residents with contaminated water
connected to the public supply. The plume area, as estimated
in 1982, extended from the site to the Passaic River and was
approximately 1300 feet wide, as shown on Figure 1.
The investigation into the source of the contamination intensified
in 1980. The investigation indicated that Caldwell was a source
of contamination, but not necessarily the only source. On
March 12, 1981, NJDEP staff inspected and sampled the lagoons
on Caldwell's property and noted spillage of solvents on General
Hose's property. Sample analyses showed significant concentra- .
tions of solvents in both the lagoon sludge at Caldwell and
soil samples associated with the spillage at General Hose. In
June 1981, both companies were instructed by NJDEP to install
monitoring wells on their property. While General Hose stated
it would not install the wells, Caldwell complied and the
monitoring well installations were completed on February 15,
1982. Samples collected by NJDEP on February 23, 1982 from
Caldwell showed substantial ground water contamination with
chlorinated hydrocarbons.
On February 1, 1983, General Hose Products entered into a Admin-
istrative Consent Order with NJDEP requiring the installation
of monitoring wells and the remediation of ground water contami-
nated by its facility. On April 13, 1983, NJDEP sampled four
of the twelve septic pits at General Hose. The analyses revealed
the presence of chlorinated hydrocarbons. Consequently, in the
summer of 1983, General Hose installed three monitoring wells
on its property as part of the Consent Order. Soil and ground
water samples from these wells showed significant levels of
solvents.
From September 1980, when the well on Heisler Machine and Tool
Company's property was found to be contaminated, until the
spring of 1982, 25 domestic, 14 industrial and all of Fairfield's
municipal wells were tested. Many were found to be contaminated
with similar hazardous solvents, including two of the municipal
wells. Municipal well No. 7 (MW-7), the most productive well
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-6-
in the Township, rated at 400 gallons per minute (gpm), was
shut down in June 1981. Municipal well No. 2, which has a much
smaller capacity (50 gpm), was closed in early 1982, but the
NJDEP believed that it had not been contaminated by the site.
Although MW-7 is 3300 feet south of, and thus hydraulically
upgradient from, the site, heavy pumping may have drawn contami-
nants from Caldwell by reversing the gradient.
At the start of the investigation, the "L"-shaped Caldwell
property showed almost no visible signs of a septic waste
disposal facility. Only a few.tank trucks, a hose extending
from a buried storage tank, and a dried-up lagoon covered over
with plywood were observed. The source of contamination, which
had been deposited in unlined lagoons, had been backfilled
twelve years earlier.
CURRENT SITE STATUS
The Superfund State Contract, an agreement between the State of
New Jersey and EPA defines, among other things, the scope of
the investigation to be carried out under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
and the National Oil and Hazardous Substances Pollution Contin-
gency Plan (NCP). In the case of Caldwell, the site was very
broadly defined in that agreement, namely:
"The Caldwell Trucking Company site consists of Caldwell Truck-
ing's facility, General Hose Products' facility, the area of
the plume of contamination flowing from Caldwell Trucking
north to the Passaic River, surface runoff into Deepavaal Brook,
Deepavaal Brook, the Passaic River, Municipal Well No. 7, and
the surrounding areas to the extent necessary to evaluate the
problem (the "Site")."
Because this definition encompasses an area of more than two
square miles, the actual site was restricted in size so that a
study could be performed within a reasonable period of time and
cost. On a complex site such as this, a phased approach allows
EPA and NJDEP to move quickly on source control while developing
a more accurate perception of the problem and the final remedial
measures required. Accordingly, EPA's initial investigation and
study, thus, focused on Caldwell, clearly the main source of
contamination, and included an elaborate pumping test to deter-
mine the connection between the site and MW-7. However, the
study also developed additional data on the contamination on
the General Hose property, in the surface streams leading to the
Passaic River, the river itself, and in residential wells in
the plume area.
From the information available on the site, EPA's contractor,
NUS Corporation, prepared a detailed risk analysis for this
site. The extensive Remedial Investigation (RI) implemented by
NUS at the Caldwell site included the following major tasks:
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-7-
0 Drilling and installation of nineteen monitoring wells
to determine subsurface conditions, particularly southwest
of the site, to provide observation wells for a pump test,
and to provide ground water sampling points.
0 Drilling and sampling of eighteen soil borings in the
former lagoon areas on-site to characterize the vertical
and horizontal extent of contamination.
0 Sampling of: seven residential wells in the contaminant
plume area north of the .site; seven of the ten seepage
pits behind General Hose's plant; eight surface water
and sediment locations in Deepavaal Brook, the Passaic
River and other surface waters downstream of the site;
and the four holding tanks and the one visible lagoon
that remains on-site.
0 Surveying of on-site and off-site sampling locations,
including an on-site sampling grid, and all monitoring
wells.
0 Collection of six air samples on-site during completion
of soil boring B-l to provide .air-quality data associated
with ground disturbances on-site.
0 Two sampling rounds for the nineteen NUS-installed monitor-
ing wells and the six existing monitoring wells.
0 An aquifer pumping test of MW-7 to investigate the effect
of long-term pumping on the hydraulic gradient between the
site and the well. Gas chromatography screening for
both volatile organics in the pumping well and selected
monitoring well water samples was performed, in an on-site
mobile laboratory, to monitor changes in contaminant
concentrations during the test.
0 In-situ soil gas screening to investigate areas of sur-
face and near-surface soil contamination.
0 Sampling and analysis of eighteen surface soil and ten
sediment locations on- and off-site. Screening for
volatile organics and polychlorinated biphenyls (PCBs)
was performed on-site by a mobile laboratory for rapid
turnaround of results.
In total, 220 samples were sent to EPA-certified laboratories
for detailed analysis, while the mobile lab on-site tested
another 60 samples for volatile organics and PCBs. Air samples
taken during drilling indicated that the volatiles present dis-
sipated very rapidly after release into the air. Extrapolation
of these data indicate that even large-scale excavation of the
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-8-
backfilled lagoons, which are high in volatiles, would not
cause a health risk to the nearest population center (the high
school).
An RI of this scope, which resulted in a four-volume report,
can only be- summarized here. The report's highlights can be
more readily assimilated if grouped and discussed in the same
order as they are in the Feasibility Study (FS). Site remediation
consists of several discrete operable units, which together
constitute a complete remedy. However, because NUS refers to
these units as remedial components in the FS, both terms will be
used here to avoid confusion. The findings of the RI are:
Operable Unit I
(Remedial Component I)
- Findings related to Municipal Well
No. 7.
Operable Unit II - Findings related to the downgradient
(Remedial Component II) plume, surface waters and sediments.
Operable Unit III - Findings related to or impacting the
(Remedial Component III) site.
Operable Unit (or Remedial Component) I - The major findings
of the RI for this segment were based largely on the pump test
and monitoring data from the upgradient wells. They are as
follows:
0 Geology in the area consists of unconsolidated glacial
sediments overlying basalt bedrock.
0 Ground water occurs in both the glacial deposits and in
fractured bedrock. These two aquifers are hydraulically
connected.
0 The hydraulic gradients in both aquifers are significantly
influenced by pumping of local industrial and municipal
wells. (Figure 3 shows the hydraulic gradient change or
competition when two large capacity wells are pumping.)
0 The normal direction of ground water flow can be reversed
by sustained, heavy upgradient pumping, such as MW-7
pumping at 390 gpm.
0 Ground water contamination was detected upgradient of
the site in the area of MW-7, downgradient of the site,
and at the site. However, ground water contamination
was not detected in monitoring wells between the site
and MW-7 (see Figure 4) indicating the possible presence
of another source or sources of contamination.
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. .. .
.V:.. -_:.*•»'• . .„. . |, -"• .... ; .'
-"--- '
CWUNPWATER CONTOURS IN m ,
CALDD»ELLTRUCKilGCO.SrTE^^r.nT^PMr **"• ""P™ T PUMRN6
FIGURE 3
IMUS
ICONPORATUM
. —_-^-i_»-i»
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LEGEND
INATCO OROUNOWATCT
TOTAL VOUTILE ORGANICS
BASE MAP IS AN ENLARGEMENT OF A
FIGURE 4
EXTENT OF CONTAMINATION IN GRQUNDWATER
CALDWELL TRUCKING CO. SITE. FAIRFIELD TWP. NJ
SCALE :("• 1000'
CX3RPORATOM
A Halliburton Company
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-11-
Operable Unit (or Remedial Component)II - The major findings
for this segment, listed below, are based on the current RI,
including a mail survey of residential well owners. However,
NJDEP investigations and sampling of residential wells in the
early 1980-'s were fully utilized in the RI/FS analysis (see
Figures 5, -6, 7, 8, 9) .
0 Regional ground water flow in both aquifers is to the
northeast, toward the Passaic River.
0 There is a plume of contaminated ground water from the
site to the Passaic River. The lateral extent of the
plume to the northwest is not well defined at this
time.
0 The RI results have shown that the current contaminated
ground water discharge into the Passaic River does not
significantly impact the quality of that body of water.
0 Chlorinated aliphatic compounds are the major ground water
contaminants in the area. Of these, trichloroethylene and
related compounds constitute the greatest proportion.
0 Surface water and sediments in the vicinity of the site
are contaminated to varying degrees with contaminants
similar to those detected at the site. However, all but
one of these locations are most likely contaminated from
sources other than the Caldwell Trucking Company site.
0 The major health risk stemming from the site is associated
with ingestion or domestic use of contaminated ground
water. Although no residents or workers in the plume
area are currently at risk, this could change as a
result of localized pumping influences or dispersion of
the contaminant plume.
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^ V A
/ •- 7 \ \ \
X^>^1^\^V^^
sgs^a^^iP^pg ^
iflra&afe *nm$mg%
ft •Mom«.«u«
ft WMW1M
\
FIGURE 5
INORGANIC GROUNOWATER CONTAMINATION IN DOWNGRAIMENT WELLS
CALDWELL TRUCKING (XX SITE. FAIRFELD TWP.. NJ
JCM.I
A HaMxrtn Compviy
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FIGURE
OR6ANIC CROUNOKKTER CONTAMNATIOM IN DOWNGRADIENTS WELLS
CALOWELL TRUCKt^G pq SITE. FAIRFCLD TWR. NJ
«c«L(inrt(f
WPORATtlM
I
UJ
I
^ A HMmrton Company
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-/4-
NOT6: ALL VAIUCS ARE MCSCNTED IN M/L (ppb)
LEGEND
COMBINED SEDIMENT AND SURFACE
BASE MAP IS AN ENLARGEMENT OF A PORTION OF FIGURE 2H.
INORGANIC
CONTAMINANT CONCENTRATIONS iN SURFACE WATER
CALDWELL TRUCKING CO. SITE. FAIRF1ELD TWR. NJ
SCALE :f« 1000'
WATER SAMPLE
FIGURE 7
CORPORATION
A Halliburton Company
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BASE MAP IS AN ENLARGEMENT OF A PORTION OF FIGURE 2-1
^ NOTt: AU.VAIUES ARE PRESENTED INUQAQ(OPb)
LEGEND
COMBINED SEDIMENT AND SURFACE
WATER SAMPLE
SEDIMENT SAMPLE
FIGURE 8
ORGANIC CONTAMINAI^T CONCENTRATIONS IN SEDIMENT
CALOWSLL TRUCKING CO. SITE.FAIRFIELD TWP. NJ
SCALE =l"« 1000'
CORPORATION
A Halliburton Company
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-16-
totno-titittt
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tw%
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t.ooo
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^••H
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C
^
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Qq
.• •
•i •
^
ps!
^n
ENLARGEMENT OP A POfTDON'or ROME 2-1
INORGANIC CONTAMINANT CONCENTRATIONS IN SEDIMENT
NOTE: AU VALUES ARE PRESENTED IN VQ/kg (ppb)
**. LEGEND
1 A COMBINED SEDIMENT AND SURFACE
«** ^ WATER SAMPLE
• SEDIMENT SAMPLE
FIGURE 9
CALDWcLL TRUCKING CO. SITE.FAIRFIELD TWP. NJ
SCALE :|"« 1000'
CORPORATION
A Halliburton Company
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-17-
Operable Unit (or Remedial Component) III - Using historical
aerial photographs, a dozen buried lagoons were identified and
sampled down to bedrock. Based on extensive sampling of surface
and subsurf-ace soils, ground water and air emissions, the
on-site RI findings (Table I, Figures 10 & 11) can be summarized
as follows:
0 Surface soils throughout the site are contaminated with
varying levels of PCBs and lead.
0 On-site subsurface soils in the former lagoon areas are
contaminated with chlorinated aliphatic and polynuclear
aromatic hydrocarbons and lead.
0 Environmental receptors (biota) may be affected by the
site. Inorganic compounds are the primary contaminants
of concern for aquatic biota. PCBs and lead in on- and
off-site surface soils could potentially affect terrestrial
biota.
Additionally, sediment samples taken from concrete seepage pits
at the rear of General Hose's property revealed considerable
levels of volatile organics, and one contained PCBs.
ENFORCEMENT
Under CERCLA, parties reponsible for the release or threatened
release of hazardous substances into the environment at a given
facility may be liable for all monies expended by the federal
government in taking necessary response actions at that facility:
investigative, planning, removal and remedial actions. Such.
parties may also be held liable for any enforcement costs incur-
red by the government. Potentially Responsible Parties (PRP's)
include current and past owners and operators, as well as persons
who generated or were involved in the transport, treatment, or
disposal of hazardous substances at the facility. It is EPA's
policy to negotiate with PRP's to encourage them to accept their
responsibility and undertake the implementation of the remedy.
EPA sent Notice Letters in June 1986 to three PRP's - the
owner/ operator of Caldwell Trucking, plus the present and
former owners of General Hose. To date, all parties have
refused to undertake any of the remedial alternatives presented
in the FS and again at the public meeting. However, EPA is
continuing to investigate records to either identify additional
PRP's or further substantiate the liability of the PRP's already
identified.
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TABU 1
SUMMARY OF SUBSURFACE SOIL CONTAMINATION FOUND IN THIS INVESTIGATION
CALOWELL TRUCKING COMPANY SITE
Subsurface Soils
PPf
30V
23V
10V
11V
87V
B5V
86V
38V
TV
29V
65A
62B
26B
27B
25B
8B
55B
77B
IB
20B
81B
68B
39B
84B
67B
66,
CAS *
156-60-5
67-66-3
107-06-2
71-55-6
79-01-6
127-18-4
108-88-3
100-41-4
108-90-7
75-35-4
108-95-2
62-75-9
541-73-1
106-46-7
95-50-1
120-82-1
91-20-3
208-96-8
83-32-9
86-73-7
85-01-8
84-79-2
206-44-0
129-00-0
85-68-7
117-81-7
Contaminant Name
Trans-1.2-Dlchloroethene
Chloroform
1.1-Dkhloroethane
1,1,1-Trichloroethane
Trichloroethene
Tetrachloroethene
Toluene
Ethylbenzene
Chlorobenzene
1.1-Dlchloroethene
Phenol
N-Nitrosodlphenylmlne
1,3-Dichlorobenzene
1,4-Dlchlorobenzene
1.2-Dichlorobenzene
1.2.4-Trlchlorobenzene
Napthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Dl-n-butylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
Bis (2-ethylheKyl)phthala
Concentration
Range (ug/l)
3.1 - 21.000
2.5- 14,000
180 - 30,000
4.0 - 240.000
100 - 790.000
4.1 - 840.000
1,600 - 94.000
7.7 - 66,000
9
160
280-15.000
410
240
260
410
190
190
940
180
540
350
280
240
230
220
180
- 6.800
- 16.000
- 44.000
- 3.400
- 3.100
- 2.800
- 3.600
- 8.900
- 380
- 4.800
- 9.000
- 9,000
Number of Occurrences/
_ Number of Samples*
10/58
4/58
3/58
6/58
9/58
17/58
8/58
4/58
1/58
1/58
4/56
1/58
3/58
7/58
6/58
2/58
6/58
1/58
4/58
3/58
5/58
2/58
5/58
4/58
1/58
16/58
I
Cfc
I
-------
FABLE 1
SUMMARY OF SUBSURFACE SOIL CONTAMINATION FOUND IN THIS INVESTIGATION
OALDWCLL TRUCKING COMPANY SHE
?AGE TWO
Subsurface Soils
!>P f
93P
94P
92P
I06P
HOP
107P
NP
NP
NP
NP
NP
NP
CAS f
72-55-9
74-54-8
50-29-3
53469-21-9
12672-29-6
11097-69-1
75-15-0
95-48-7
106-44-5
65-85-0
91-59-6
132-64-9
Contaminant Name
4.4'-DDE
4.4'-DDD
4.4'-DDT
Arochlor 1242
Arochlor 1248
Arochlor 1254
Carbon disulflde
Total xylenes
2-Methylphenol
4-Methylphenol
Benzole acid
2-Methylnaphthalene
Dlbenzofuran
Concentration
Range (ug/H
620
8.4 - 4.000
120 - 28.000
930 - 360.000
340
180 - 3.600
3.6
3.7 - 280,000
9.700 - 14.000
2,400 - 14,000
1,100
260 - 3.400
290 - 2.800
Notes:
* Date Includes all LSS samples (except 002 and 006) and SS001, SS004 - 008
NP • Non-Priority Pollutant
Number of Occurrences/
Number of Samples*
1/58
2/58
2/58
8/58
1/58
4/58
1/58
8/58
2/58
3/58
1/58
5/58
4/58
I
10
-------
N fr
^ \ /< I
o
I
FIGURE IP
ORGANIC COMTAMtlATION IN ONSITt SURFACE SOILS AND SEDIMENTS
CALDWELL TRUCKING CO. SITE. FAIRFIELO TWR. NJ
KM.1 M fllf
IMUS
CX3MPCWATOM
-------
IS!
=1 I
FIGURE 11
qplTAMIMATK)N IN ONSITE SURFACE SOH.S AND SEDIMENTS
CALDWELL TRUCKING CO. SITE, FAIRFIELD TWR. NJ
KM.I " tit
rawus
_LJ COH^OMATON
Q A HaMxvkm ComfMny
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-22-
EVALUATION OF ALTERNATIVES
The purpose of the Feasibility Study (FS) is to develop and
assess remedial action alternatives based on site-specific
conditions. At a minimum, one alternative should be developed
for each of five categories outlined in the National Contingency
Plan and EPA's FS Guidance Document. The process is as follows:
Identify General Response Actions
- Identify site problems and pathways of contamination
(Remedial Investigation).
- Identify general response actions that address site
problems and satisfy remediation goals and objectives.
Identify and Screen Technologies and Develop Remedial
Alternatives
- Identify possible technologies in each general response
action and screen the technologies to eliminate in-
applicable and infeasible technologies based on site
conditions.
- Assemble the technologies that pass the screening into
complete alternatives.
Table 2 lists various response actions with the related remedial
technologies considered in this study. The more advanced or
innovative of these techniques were considered under the last
two response actions—namely, Treatment of Contaminated Soils
and Treatment of Liquid Wastes. With contaminated soil, key
considerations are the volume to be handled and whether it in-
volves primarily surface or subsurface contamination. In the
case of Caldwell, with approximately 25,000 cubic yards (CY) of
subsurface contamination, in-situ soil treatment would be
expected to be more cost-effective than excavation. Hence, both
solvent extraction and biodegradation were considered. However,
solvent extraction was eliminated because of the problems antici-
pated in flushing through glacial till containing large boulders,
thus possibly diverting solvent through the bedrock and -into
the ground water.
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-23-
TABLE 2
GENERAL REPONSE ACTIONS AND REMEDIAL TECHNOLOGIES
CALDWELL TRUCKING COMPANY SITE
General Response Actions
No Action
Containment
Diversion and Collection
Restrict Access
Partial Removal
Complete Removal
Disposal
Alternative Water Supply
Treatment of Contaminated Soils
Treatment of Liquid Wastes
Associated Remedial Technologies
Monitoring
Capping
Ditches, berms, sedimentation basins
regrading, and revegetation
Fencing of areas with contaminated
surface soils
Excavation of wastes, contaminated
soils, and tanks
Excavation of wastes, contaminated
soils, and tanks
Landfilling
Treatment of MW-7, alternate water
supply for the plume area
Post-excavation
"Incineration
- Rotary kiln
- Fluidized bed
- Multiple hearth
°Solidification
- Lime based
- Cement based
- Thermoplastic
- Classification
Powdered Activated Carbon
Treatment (PACT)
Activated carbon
Air stripping
Ion exchange
Filtration
Biological
In-Situ
"Solvent extraction
"Biodegradation
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-24-
Similarly, biodegradation presented a number of obstacles,
including the array of organics to be removed, expected inter-
ference with metals, and the need to treat both the saturated
and unsaturated layers. As a result, it too was eliminated.
Volume of material is also important in screening post-excavation
techniques. Large volumes translate to high costs and, with
the current limited number of fully permitted incinerators,
lengthy remediation timeframes.- Incineration is an effective
technique to address all priority pollutants except for heavy
metals. Since heavy metals exist at Caldwell, incineration
would have to be followed by a solidification process to stabilize
the metal-containing ash residue. Direct solidification of the
excavated soil without incineration was also considered, but
placing the matrix back in the ground in direct contact with
the ground water leaves some long-term uncertainties. Hence,
direct solidification was screened out. As to treatment of
liquid wastes, the techniques listed would only be analyzed and
screened in any detail if the liquids were to be treated on-site.
At Caldwell, the liquid wastes, found only in storage tanks,
represented only about 20,000 gallons and hence could easily be
removed to a PACT facility. The other techniques are used
selectively, depending upon the nature of contaminants and the
results of any treatability studies. However, both air stripping
and activated carbon adsorption were proposed to control vapor
phase contamination under different alternatives.
In summary, the complexity of the site problems, the widespread
contamination in the area, and the presence of other potential
sources of contamination complicated the development of a
comprehensive remedial program to address all the problems in
the area. Therefore, the alternatives were divided into remedial
components (operable units), based on the particular problem
being considered. Three remedial components were developed
along with eleven remedial action alternatives. These remedial
components and the corresponding alternatives are as follows:
Remedial Component I - Remediation of Municipal Well No. 7
- Remedial Action Alternative No. 1 - No Action
- Remedial Action Alternative No. 2 - Purchase of Water from
Passaic Valley Water
Commission
- Remedial Action Alternative No. 3 - Wellhead Treatment of
Municipal Well No. 7
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-25-
Remedial Component II - Remediation of Downgradient Contaminant
Plume
- Remedial Action Alternative No. 4 - No Action with Monitoring
- Remedial Action Alternative No. 5 - Alternative Water
Supply and Sealing of
Private Wells
Remedial Component No. Ill - Remediation of On-site Wastes and
Contaminated Soils
- Remedial Action Alternative No. 6 - No Action
- Remedial Action Alternative No. 7 - Capping
- Remedial Action Alternative No. 8 - Excavation and Disposal
in an Off-Site Landfill
- Remedial Action Alternative No. 9 - Excavation and Disposal
in an On-Site Landfill
- Remedial Action Alternative No. 10 - Excavation and Off-Site
Incineration
- Remedial Action Alternative No. 11 - Excavation, On-Site
Incineration and
Solidification
Each of these alternatives is described more fully in the
following pages, by remedial component (operable unit), along
with the related capital and operating costs developed in the
Feasibility Study.
Remedial Component I - Remediation of Municipal Well No. 7
Remedial Action Alternative No. 1 - No Action
If no remedial action is taken under CERCLA, the Township of
Fairfield would most likely continue to purchase water from the
Passaic Valley Water Commission (PVWC) to replace the capacity
lost from MW-7. Hence, the risk associated with the ingestion
of contaminated water from MW-7 would be effectively eliminated.
Under this remedial alternative, the Township continues to bear
the financial burden, and PVWC the added burden on its water
resources.
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-26-
Remedial Action Alternative No. 2 - Purchase of Water from Passaic
Valley Water Commission
In this alternative, the water that the Township of Fairfield
is currently purchasing from the PVWC will be paid for by the
State and/or Federal government. Again, the risk associated
with the consumption of contaminated water from MW-7 will be
effectively eliminated. This alternative relieves the financial
burden on the Township, but does not relieve the water resource
burden on the PVWC. ;
The cost of this alternative is estimated at $23,690 per year,
based on an average annual water purchase of 46 million gallons.
However, if Alternative No. 5 is also implemented, an additional
15 million gallons per year will be needed to meet the demand
created by additional tap-ins to the Township's water system.
The projected costs for 61 million gallons per year would be
$31,415 at current prices.
Remedial Action Alternative No. 3 - Wellhead Treatment of
Municipal Well No. 7
The treatment of the contaminated water at MW-7 was evaluated
prior to this FS in a study of water treatment alternatives by
Malcolm Pirnie, Inc., under contract to the Township of Fairfield.
Malcom Pirnie selected an air-stripping unit designed to match
the full capacity of MW-7, plus some reserve, or 220 million
gallons per year. For comparison purposes with Alternative 2,
NUS pro-rated the capital and operation and maintenance (O&M)
costs of this larger unit with one capable of treating 61
million gallons plus the Township's peak summertime demand.
The smaller unit is estimated to cost $222,000 with an O&M of
$7,000 per year. This alternative would remove the present
burdens from both the Township and the PVWC. Additionally, by
treating and upgrading the contaminated ground water to potable
standards, the alternative is remediating a currently unusable
resource.
Remedial Component II - Remediation of Downgradient Contaminant
Plume
While the objective of Component II was to remediate the down-
gradient contaminant plume, the information collected in the
RI/FS was not sufficient to address the entire problem. Hence,
a further study will be needed to characterize the contaminant
plume and determine if General Hose, and possibly other sources,
have contributed materially to the ground water contamination.
Accordingly, Component II is limited to protecting those people
in the plume area who are currently or imminently at risk
through the use of their private wells.
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-27-
Remedial Action Alternative No. 4 - No Action with Monitoring
While many of the residences in the area have been provided with
municipal water, some may continue to use private wells for
potable and -non-potable domestic water. However, the NJDEP
will implement restrictions on installing any new wells in this
area.
At a minimum, monitoring would be provided in the plume area
and on the perimeter of the plume. This will detect contaminant
migration over time and alert regulatory agencies to the
potential exposure to residents of contaminated water. No
capital costs are anticipated for this alternative because
existing monitoring and residential wells will be used for the
monitoring program. The total (O&M) cost of the monitoring
program is estimated to be $35,040 per year for 30 years.
Remedial Action Alternative No. 5 - Alternative Water Supply
and Sealing of Private Wells
Analysis of State and RI data led to the identification of 100
homes in the plume area that were currently or potentially at
risk via ingestion of contaminated water from private wells.
In addition to hooking up these people to municipal water,
there was concern about leaving the wells intact for non-potable
usage, thus imposing the risk of fume inhalation. The safest
course would be to seal up 90 percent of these wells with the
remainder left open for future monitoring. The capital costs
associated with this alternative are estimated at $269,480.
There would be no annual operation and maintenance costs for
this alternative.
Remedial Component III - Remediation of On-Site Wastes and
Contaminated Soil
Remedial Action Alterative No. 6 - No Action
Under this alternative, site wastes and contaminated soils,
routes of off-site contaminant migration, and human and environ-
mental exposure pathways will all remain unchanged. In addition,
subsurface soils and wastes will continue to contaminate the
ground water via the infiltration of precipitation and the
leaching of hazardous constituents.
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-28-
Remedial Action Alternative No. 7 - Capping
The primary intent of this alternative is to provide a source-
control remedy. It entails the removal and/or treatment of the
on-site storage tanks, the installation of a 24-inch compacted
soil cap over areas with contaminated surface soils", and the
installation of a multimedia cap (several feet thick and highly
impervious) over areas with subsurface soil contamination. The
purpose of any cap is to eliminate direct (human) contact and
to prevent infiltration of rainwater which, in turn, would carry
the contaminants into the ground water. The capping of contam-
inated surface soils also prevents migration of these soils
from the site via surface run-off and wind erosion. This
alternative also includes silt fencing, an upgradient diversion
wall to protect the multimedia cap, and ground water monitoring,
using existing wells to gauge the long-term effectiveness of
the remedy. The capital costs for this alternative are estimated
at $740,485, with an annual O&M of $18,120.
Remedial Action Alternative No. 8 - Excavation and Disposal in
an Off-Site Landfill
Alternatives 8-11 each involve the handling of buried tanks and
the excavation of an estimated 28,000 cubic yards of soil for
ultimate disposal. Under Alternative No. 8, the excavated
material is trucked to a permitted landfill while the site
would be regraded and backfilled with clean soil. Excavation
is not expected to generate air pollution problems on-site.
All contaminated materials except the tank contents would be
hauled to a licensed Hazardous Waste Management Facility (HWMF).
While the actual disposal site would be approved by the EPA,
subject to availability, a HWMF in Buffalo, New York was chosen
for costing purposes. Accordingly, the full cost of this
remedy was estimated at $18,188,000, with an O&M of $26,200 a
year for ground water monitoring. Implementation of this
remedy would take about six months, and would eliminate both the
direct-contact hazard and the source of ground water contamination.
Remedial Action Alternative No. 9 - Excavation and Disposal in
an On-Site Landfill
This alternative involves the construction of a secure on-site
landfill for the containment of the excavated material. The
preliminary location selected is on the eastern end of the
Caldwell property. The landfill, including embankments, com-
prises approximately 3.4 acres. Dimensions are roughly 300 by
-------
-29-
500 feet with a design capacity of 30,000 cubic yards. The
construction of this landfill would conform to specifications
under the Resource Conservation and Recovery Act (RCRA) and the
Toxic Substances Control Act (TSCA). In this alternative, the
top of the cap will be covered with grass and the rest of the
site graded and revegetated. While the primary purpose of
these measures is erosion control, the whole site is simultane-
ously upgraded and made more pleasing in appearance. The cost
for this remedy is estimated at $3,166,000 with an O&M of
$41,000 a year due to extensive monitoring. The remedy would
take twelve months to implement.
To reduce or eliminate hazardous waste whenever practical, a
low-temperature vaporization loop can be inserted between the
excavation and landfilling steps. This will drive off the
volatiles, leaving only the more stable organics and metals in
the soil to be landfilled. As these residual compounds are
relatively immobile, they constitute a safer and hence more
suitable landfill burden. The separated volatiles are then
collected in activated carbon canisters and shipped off-site.
The cost of this system, including one year of operation, is
$500,000. Addition of the loop would extend the overall con-
struction timetable by three months and bring the combined cost
of this alternative to $3,666,000.
This alternative would effectively eliminate the human health
hazard and permanently seal off the residual contaminated
material in a RCRA landfill, built completely above-grade for
maximum security.
Remedial Action Alternative No. 10 - Excavation and Off-Site
Incineration
In this alternative, the excavated waste materials are destroyed
via incineration and the remaining ash is disposed of properly
by the operators of the off-site incinerator. For costing
purposes, a commercial incineration facility in southern New
Jersey was chosen. The final selection of an off-site inciner-
ation company would be approved by EPA. More importantly,
however, the availability of an off-site incineration facility is
currently uncertain because of the large backlog of wastes and
limited loading capacities of existing units (currently one to
two tons per hour). The time required to implement this alter-
native at these loading rates, is approximately three to six
years. The estimated capital costs for this alternative are
$49,056,421 with annual O&M costs of $26,200.
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-30-
Upon completion of this remedy, the direct contact risks would
be eliminated and the site itself would cease to be a source of
ground water pollution. However, excavation and stockpiling of
this material over a period of years imposes direct contact risks
throughout these operations.
Remedial Action Alternative 11 - Excavation, On-Site Incineration
and Solidification
A mobile incineration system is considered to be a viable
option for soil/waste volumes of less than 100,000 cubic yards,
as is the case with Caldwell. Currently, only one company has
a fully operating and permitted mobile unit available, so it was
used for design and costing purposes. The unit can be trans-
ported to the site, set up, and soil decontamination begun
within a few months. The mobile unit incorporates the use of a
well established incineration technology, the rotary kiln, and
all necessary ancillary equipment, including stack gas and waste
water treatment. The incineration system can handle four to
five tons per hour of contaminated soil. The temperature
within the rotary kiln, approximately 2000°F, will be sufficient
to either destroy or drive off all of the organic contaminants.
The volatilized contaminants that are not destroyed in this
chamber will be subjected to nearly 2300°F in a secondary
combustion chamber. The residual metals and ash would be
solidified on-site to facilitate final disposal. The capital
cost of this alternative is estimated at $42,463,335. Operation
and maintenance costs are estimated at $26,200 per year. The
estimated time to implement this alternative is 2.5 years.
Subject to the availability and size of these mobile units,
this alternative would, over a period of years, eliminate both
the source and direct contact risks.
All the above alternatives are summarized in Table 3, which
affords a comparison of both their respective capital costs and
30-year present worth calculations.
COMMUNITY RELATIONS
The first public meeting on the site was held by EPA in January
1985 when EPA and its contractor reviewed the scope of the
RI/FS (Remedial Investigation and Feasibility Study) prior to
beginning field work. In May 1986, when the study was completed,
EPA sent copies of the reports to three different repositories
where they could be reviewed by the public. The 6-volume study
was forwarded to Fairfield's public library, the Municipal
Building (town hall), and the West Orange Office of the NJDEP.
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-31-
TABLE 3
REMEDIAL ACTION ALTERNATIVES COST SUMMARY
CALDWELL TRUCKING COMPANY SITE
(Costs ere In 19B6 Dollars)
Remedial Action Alternative
Remedial Component I
1. No actl-;n
2. Purchase of watar from
Passalc Vallay Watar Commission
3. Wallhaad traatmant of
Municipal Wall No. 7
Ramadlal Component II
4. No action/monitoring
5. Alternative watar supply and
sealing of private wells
Remedial Component ill
6. No action
7. Capping
8. Excavation and offslte landfill
9. Excavation and onsrte landfill
• With low temperature
vaporization loop
10. Excavation and offslte Incineration
11. Excavation, onslta Incineration,
and solidification
Capital Cost
($1.0001
-0-
-0-
222
-0-
740
18,188
3,166
3,666
49,056
42,463
Present-Worth
Costs ($1,000)
Baseline
-0-
297
288
-0-
269
332
269
-0-
911
18,434
3,554
4,053
49,302
42,709
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-32-
The reports were delivered on June 3, 1986 with the notice of a
3-week comment period ending June 25. A second public meeting
was held on June 16 where a summary of the reports was provided
and public questions and comments were received. A responsiveness
summary addressing the comments received at the meeting is
attached.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
To the extent practicable, it is EPA's intention to develop
remedies that comply with all applicable and relevant Federal
public health and environmental laws and regulations. Other
Federal criteria, advisories, guidances, and State standards
are also considered.
For Remedial Component I (Alternatives 1, 2 and 3), the lack of
data to characterize the extent of the ground water contamin-
ation around MW-7 suggests that these alternatives may only
provide a partial or interim remedy. A permanent remedy will
be evaluated in a future study. Because these alternatives may
be interim remedies, they would not necessarily be expected to
comply with all applicable and appropriate requirements.
Alternative 1, No Action, would probably result in the Township
continuing to purchase water and the continued "non-use" of the
aquifer. Under EPA's ground water protection strategy, the
aquifer in the area of MW-7 would be classified a Class 1 or
Class 2 aquifer. These designations would prompt EPA to evaluate
alternatives to restore the aquifer to a useable condition. As
such, the No Action alternative would not be consistent with
the ground water protection strategy nor would Alternative 2.
Alternative 3, however, would allow the aquifer to be used by
treating the water, but would not necessarily restore the aquifer
in a true sense. To the extent that the aquifer would be restored,
Alternative 3 would be considered a permanent remedy under the
ground water protection strategy.
Under Alternative 3, the standards to consider in developing
treatment or effluent limits would be the proposed maximum
contaminant levels (MCL's) promulgated under the Safe Drinking
Water Act (SDWA) and the State's "Interim Action Levels and
Recommendations for Responses for Selected Organics in Drinking
Water", developed pursuant to recent amendments to the State's
safe drinking water act. This Act is commonly referred to as
A-280.
Based on treatability studies performed for the Township and a
comparison of the contaminants found with the MCL's, trichloro-
ethene (trichloroethylene or TCE) appears to be the critical
contaminant for determining the design parameters for an air
-------
-33-
stripper. The MCL for TCE is 5 micrograms per liter (ug/1).
To meet this effluent criterion, the removal efficiency would
have to be greater than 99 percent (influent concentration is
approximately 500 ug/1). At this removal efficiency for TCE,
the other contaminants which have proposed MCL's would also be
expected to-have effluent concentrations below their MCL's.
From the available literature on actual field applications of
air strippers, a 99+ percent removal is technically feasible.
The proposed MCL's would, therefore, be appropriate and practical
to use as the design effluent criteria.
The State's A-280 level 2 criteria could also be used for
effluent design criteria. Of the contaminants detected in Well
No. 7, only one compound (trans-1,2-dichloroethylene) has an A-280
action level (148 ug/1), although it does not have a proposed
MCL. Two other compounds—1,1,1-trichloroethane and carbon
tetrachloride—have A-280 levels lower than their MCL's. 1,1,1-
trichloroethane has an A-280 level of 110 ug/1 and an MCL of
200 ug/1, while carbon tetrachloride has an A-280 level of 2.7
ug/1 and a MCL of 5 ug/1. The 99+ percent removal efficiency
for trichloroethene required to meet the MCL would also be
expected to result in 99+ percent removal efficiencies for
1,1,1-trichloroethane and carbon tetrachloride, which would
bring the effluent levels well below the A-280 levels. In fact,
the discharge concentrations can be brought down to the minimum
action levels for these compounds as set by the NJDEP.
Since the A-280 levels can be achieved by designing the treatment
system to meet the MCL's, EPA will use the proposed MCL's for
the design effluent criteria, to be consistent with the SDWA.
Again, because of the lack of ground water data for the down-
gradient plume, the alternatives in Remedial Component II are
considered to be interim remedies at this time. As with Alter-
native 1, Alternatives 4 and 5 would not be consistent with
EPA's ground water protection strategy. Both alternatives do,
to different degrees, satisfy a primary goal of CERCLA and
other environmental laws—i.e., to protect public health. For
Alternative 4, the MCL's and the A-280 action levels would be
appropriate to use to determine if a particular residence
should be supplied with alternate water. Because of the time
involved between sampling and receiving the results, EPA feels
it would be prudent to use the more stringent level of A-280
"no-action" levels and the ""L's to determine if a residence
should be supplied with municipal water. However, since some
of the A-280 "no-action" levels are below the current routine
detection limits, the detection limit would be the action
level. For Alternative 5, consistency with both Federal and
State drinking water standards would be ensured through existing
regulations governing the water purveyors.
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-34-
For Remedial Component III, the alternatives are intended to be
permanent remedies for the materials found at Caldwell. Therefore,
EPA policy dictates an evaluation of the alternatives vis-a-vis
all other applicable environmental laws. The applicable and
appropriate'Federal requirements for Remedial Component III
include the Resource Conservation and Recovery Act (RCRA)
and the Toxic Substances Control Act (TSCA).
Alternative 6, No Action, would not comply with RCRA or TSCA.
The presence of EP toxic waste and PCBs in the waste materials
dictate disposal in a facility meeting RCRA and TSCA requirements.
The current placement of the waste on-site does not comply with
RCRA or TSCA disposal requirements. Alternative 7 would comply
with existing RCRA closure requirements for landfills. Alter-
natives 8, 9, 10, and 11 are designed to be in full compliance
with the technical requirements of both RCRA and TSCA. EPA's
off-site disposal policy would ensure that the off-site facility
for Alternatives 8 and 10 is in compliance with RCRA and TSCA.
For Alternative 11, on-site incineration, to be in full compliance
with RCRA, the incinerator residue or ash would have to be
re-designated as a non-hazardous waste prior to placing the
solidified ash on-site.
Other Federal criteria, advisories, guidances and State standards
to be considered for Remedial Component III would include:
State hazardous waste regulations, State air pollution regulations,
Federal sole-source aquifer requirements, State Hazardous Waste
Facility Siting Criteria, State solid waste regulations, State
waste water discharge regulations, and local construction require-
ments.
Since the State hazardous waste regulations are an extension of
RCRA, the two should be in close accord. However, in case of
conflict, the Federal standard will apply.
Alternative 8, Off-Site Landfill, appears to be affected only
by local construction regulations, such as run-off control, fire
and building codes. EPA intends to comply with the technical
requirements of those regulations.
For Alternative 9, On-Site Landfill, it would be appropriate to
consider other State regulations and the Federal sole source
aquifer requirements. The vaporization loop option in this
alternative is intended to comply with State air pollution
regulations. Although little to no leachate would be expected
in the landfill's leachate collection system, treatment and
disposal of any leachate would be designed to comply with State
water pollution regulations. The site is located at the
boundary of the area of concern for the Buried Valley Aquifer
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-35-
System Sole Source Aquifer. The intent of the sole source
aquifer designation is to protect the quality of the ground
water, to allow its continued use as a safe potable water supply.
Alternative 9 satisfies this intent by removing a primary source
of ground water contamination. To ensure that the on-site
landfill would not become another source, the landfill would be
double-lined and equipped with a leachate collection system.
Any leachate that might migrate through the first liner would
be collected in the leachate collection system and be properly
disposed of. Locating the on-site landfill above existing
grade allows for monitoring of the liners and collection system
to ensure they are functioning properly. Adding the vapori-
zation loop option to Alternative 9 provides further protection
in that it removes significant amounts of the more mobile
contaminants (volatile organics) and reduces the moisture
content of the material. Reducing the moisture content reduces
the amount of water available to produce leachate. Reducing
the volatile organics decreases significantly the contaminants
that can most easily migrate or leach from the waste. EPA
feels that the design requirements for a RCRA secure landfill
suffice to protect the ground water quality under the site, and
therefore fulfill the intent of the sole source aquifer require-
ments. The vaporization loop would provide additional safeguards
in that it would greatly reduce the likelihood of leachate
being formed.
The construction of an on-site RCRA disposal facility under
Alternative 9 would not comply fully with the State's Major
Hazardous Waste Facility Siting Criteria. However, these
criteria were developed for siting new commercial hazardous
waste treatment and disposal facilities. Such criteria were
not intended to be applied to remedial actions that correct an
existing pollution problem. They are, in part, intended to
prevent such occurrences, by helping to ensure proper disposal
and to protect the health of nearby residents. EPA feels that
the on-site landfill will properly dispose of the on-site
wastes. EPA will also implement the necessary safeguards to
protect the health of the residents in the area during and
after construction.
Alternative 10, as well as Alternatives 8 and 9, will comply
with local construction codes.
Alternative 11, On-Site Incineration, is intended to comply
with State air pollution regulations. As with Alternative 9,
it would not be in full compliance with State siting criteria.
Solidification and placement of the ash on-site, although in
compliance with RCRA, would not be in compliance with State
solid waste regulations and may not satisfy the intent of the
sole source aquifer requirement. Additional studies on the
leachability of the contaminants from the solidified matrix
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-36-
would be needed in order to evaluate the environmental impact
of on-site deposition in relation to the solid waste regulations
and the intent of the sole source aquifer requirements. Quench
or scrubber water would be treated and disposed of according to
State water pollution control regulations. As with all the
excavation alternatives, all remedial activities would be
performed in accordance with local construction requirements.
RECOMMENDED ALTERNATIVE
For Remedial Component I, Alternative 3, wellhead treatment, is
the recommended alternative. Treatment of MW-7 allows for the
continued use of local ground water, a very important resource
for the area. This alternative will also relieve the burden on
the Township of purchasing water to supplement the loss of MW-7.
Implementing a ground water treatment system is, in part, a step
towards permanent remediation of the ground water in the area and
consistent with EPA's ground water strategy. Additional studies
to discover and mitigate other potential sources of contamination
are also recommended. Pumping MW-7 will aid in any future in-
vestigations by controlling the ground water flow regime and
also clean up an identified plume of contaminated ground water.
Since the area between MW-7 and the site is not contaminated,
pumping should prevent the contamination around the well from
migrating north into this area. Conversely, to prevent MW-7 from
drawing contamination from the site into this area, the well
should not be pumped at a flow rate that would extend the cone
of depression beyond Monitoring Well No. 8. Considering the
present pumping pattern of industrial wells in the area EPA
recommends that MW-7 flow rates not exceed 200-300 gpm, and
that Monitoring Well No. 8 be maintained as and "Early Warning
System" signaling any significant changes in this pattern in
the future. Further pumping tests of MW-7 may be appropriate
to determine the optimium pumping rate that would satisfy the
Township's water demand without drawing contaminants back from
the site.
In summary, Alternatives 1 and 2 would allow the continued
migration of contaminants and would not relieve the burden on
the water resources of the area. As Alternative 3 involves
capital equipment, it is necessarily more expensive than Alter-
native 2 in the short term. However, with lower operation and
maintenance (O&M) expenses, it becomes more cost-effective over
the long term, $288,000 over 30 years versus $297,000 for Altern-
ative 2 (see Table 4).
For Remedial Component II, Alternative 5 is the recommended
alternative. The data indicate that the downgradient plume is
migrating laterally toward the private wells on the edge of the
plume (see Figure 12). Since many wells within the plume are
shut down, continued pumping of wells along the edge of the
plume may be diverting the contaminants and extending the width
of the plume. Connecting the homes north of the site and
-------
TABU 4
REMEDIAL ACTION ALTERNATIVES COST SUMMARY
CALOWEU TRUCUNO COMPANY SITE
(Costs are to 1968 Oottars)
Remedial Action Alternative
Remedial Component I
1. No action
2. Purchase of water from
Passafc Valley Walar Commission
3. Wellhead treatment of
Municipal WaH No. 7
Ramadial Componant JI
4. No actton/monHoiioj
5. Alternative water supply and
sealing ol private waNs
Remedial Component III
6. No action
7. Capping
8. Excavation and offsita landfUl
0. Encawalion and onsHa landlUI
• With tow tamparatura
vaporization loop
10. Encavatlon and offslte Inclnaration
11. Excavation, onslla Inclnarallon
•nd solidification
Capital Costs
It 1.0001
-O-
222
-0-
269
-0-
740
19.188
3.166
3.666
49.056
42.463
Annual O&M Costa (tl.OOO)
mcludas MonHorlng and
fost-Ctosura Mamtananco
POvaarsI
31.5
7.0
35.0
-0-
18.1
26.2
41.0
41.0
26.2
26.2
Peasant-Worth Costs tl1.000|
Low
-0- -0-
~ 297
~ 288
— 332
223
269
293
-0- -0- -O-
783 911 1.123
9.625 18.434 27.441
2.664 3.SS4 4.7S2
3.115 4.053 5.300
34.496 49.302 69.375
41.783 42.709 43.964
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AREA OF TAP-IN,SEALING. 8
WELL RESTRICTIONS EXTENDS
TO INTERSECTION OF US ROUTE
46 AND WEST BANK OF PASSAJC R.
HATCHURES NOlCATE AREA OF MUNICIPAL
TAP-N,SEAJJNG OF PRIVATE WELLS, AND
WELL RESTRICTIONS
^» • ^ ^ ** r i
Y GENERAL H06C /
TRUCKMO
COMPANY I SITE
OF WELL RESTRICTIONS ONLY
• I ••••
tSiS B
^ ••••
AREAS FOR MUNICIPAL TAP- IN. SEALING OF
PRIVATE WELLS. S WELL USE RESTRICTIONS
CALDWELL TRUCKING CO. SITE. FAIRF1ELD TWR. N J
SCALE: !*• 1000'
A Halliburton Comp
-------
-39-
sealing their wells would protect the residents from future
exposure and should retard the lateral expansion of the down-
gradient plume. Again, in this remedial component, a tradeoff
exists between an immediate capital investment (Alternative 5)
and long-term monitoring costs (Alternative 4). As can be seen
in Table 4," Alternative 5 is more cost-effective over time, and
has the advantage of removing 100 households from risk almost
immediately.
Additional study is needed to determine if other sources (such
as General Hose) may be contributing significantly to the plume
and how to remediate the ground water problem that currently
exists.
For Remedial Component III, Alternative 9, with the vaporization
loop, is the recommended alternative. The No Action and capping
alternatives would allow for the continued contamination of the
ground water. Of the excavation alternatives, Alternative 9 is
the most cost-effective alternative by which the wastes would
be contained and prevented from contaminating the ground water.
The vaporization loop adds a treatment step to the recommended
alternative (See Figure 13). The loop would significantly re-
duce the concentration of volatile organics and therefore reduces
the overall mobility of the waste to be contained on-site. The
organics driven off by the heating process are collected in
granular activated carbon canisters which, when fully loaded,
are returned to the manufacturer for regeneration.
Alternative 8 costs appoximately $14 million more than Alternative
9 without providing any greater environmental benefit. It also
adds an increased risk to public health during transportation.
Alternative 10 presents a similar increased risk during trans-
portation. Further, Alternative 10 was deemed not cost-effective
since it provides only a small increase in environmental benefit
at more than ten times the cost. Alternative 11, on-site
incineration, was also considered to be not cost-effective
since the degree of environmental benefit is not proportionately
greater. In fact, future availability and capacity of incineration
units, on- or off-site, are speculative at best.
In summary, the alternatives recommended at this time for the
Caldwell site may not include all of the components associated
with a permanent remedy for the site in its entirety. However,
they do effectively address the three remedial components (or
operable units) of the site, namely:
I. Restoring a lost water resource by providing well-head
treatment, via air stripping, of MW-7.
II. Removing people from risk in the downgradient plume by
providing municipal hook-ups and taking private wells out
of service.
-------
FIGURE-13
LAtiPPILL AMD EXCAVATION PLAN
f ALDWELL TRUdcf^r. «1 SITE. FA.RF.ELD TWP. HJ
•CM* • ratt
CXJHMLMaTON
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-41-
III. Effectively sealing off the Caldwell property as a source
of future ground water contamination. The cost elements
related to this alternative are shown in Table 5.
Ground water contamination in the vicinity of the site still
remains to be addressed. Therefore, a supplemental Remedial
Investigation and Feasibility Study should be performed to
determine the full extent of ground water contamination, the
contribution of the General Hose Products Company and other
sources to that contamination, and what remedial measures need
to be developed to remediate the ground water problems. If the
study finds contaminated soil at General Hose that needs to be
removed, it should be integrated with the Caldwell landfill if
at all feasible.
TABLE 5
Selected Remedial Alternative (9) Capital Costs
Activity Costs
Site Preparation 87,758
Landfill Construction 1,593,675
Tank Removal 150,057
Excavation & Backfill 701,654
Engineering & Contingencies (25%) 633,286
Sub-Total $3,166,000
Vaporization Loop 500,000
Total Capital Costs $3,666,000
Preparation of Detailed Design 500,000
Additional On-Site Investigation* 150,000
Construction Phase Costs:
S&A by COE (.06 x $3.7 million) 222,000
E&D Changes (.01 x $3.7 million) 37,000
Bid Contingencies (.15 x $3.7 million) 555,000
Construction Change
Orders/Claims (.08 x $4.5 million) 360,000
Total Funds Required $5,490,000
Note: *As noted in the Feasibility Study, additional subsurface
borings, surface samples, and the related lab analyses
will be needed in the design stage to more precisely
define the perimeter and volume of soils to be excavated
and treated.
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-42-
OPERATION & MAINTENANCE
Operation and Maintenance (O&M) will be required under two of
the operable units (I and III) to ensure their continued effect-
iveness and. reliability. As shown in Table 4, the O&M costs for
Operable Unit I are estimated at $7,000 per year. These are
solely for the operation of the air stripper. O&M costs for
Operable Unit III are estimated at $41,000 per year and would
include both post-closure and long-term monitoring, and general
maintenance of the site such as ground and landfill care, fence
repair, etc.
SCHEDULE
As noted below, post Record of Decision activities are contingent
upon reauthorization of Superfund or advance match funding by
the State of New Jersey.
Activity Date
Approve Remedial Action September 1986
Award IAG for Design Pending Reauthorization
or State Advance Funding
i
Amend State Superfund Contract for Design "
Start Design** "
Complete Design "
Award IAG for Construction "
Amend State Superfund Contract "
for Construction
Start Construction "
Complete Construction "
** The specifications for tap-ins to municipal water can be
finalized first in the design phase and/or let separately for
construction if desired.
FUTURE ACTIONS
As recommended here and in the RI/FS report, an additional study
is needed to characterize the area's ground water contamination and
to determine if treatment of the plume.would be both feasible and
cost-effective. The study should focus on the General Hose
property as a potential plume source. In addition, to the extent
practical, other contributors (sources) would be identified in
the course of the above investigation.
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RESPONSIVENESS SUMMARY
FOR THE
CALDUELL TRUCKING COMPANY SITE
TOWNSHIP OF FAIRFIELD
ESSEX COUNTY, NEH JERSEY
BASED ON COMMENTS FROM THE
PUBLIC MEETING OF
JUNE 16, 1986
INTRODUCTION
This Responsiveness Summary for the Caldwell Trucking Company Site outlines
key community concerns regarding the Remedial Investigation and Feasibility
Study (RI/FS) Report and the proposed alternatives for site remediation.
These public comments will be taken Into consideration when the U.S. Environ-
mental Protection Agency (EPA) makes Its final selection of the preferred
remedial action. The Responsiveness Summary Is prepared by the EPA to address
these comments and 1s Incorporated Into the Record of Decision, which states
the selected remedial alternative.
Major questions and comments that were made to the EPA during the public
meeting of June 16, 1986, and comments that were submitted to the EPA 1n
writing are summarized 1n this report. Comments with the EPA's response are
categorized under separate topics.
ORAL COMMENTS
The following comments were made by citizens at the public meeting.
Topic: Hell Sampling
Issue: Where was the screening on the monitoring wells?
Response: The bedrock wells were open bore-hole to the bottom of the line;
the shallow wells were screened above the bedrock. I think we had
20 feet of screen, but I'm not exactly sure; 1t was right above the
bedrock.
Issue: When you sampled the residential wells In the plume, were the
residents notified that the wells would be sampled?
Response: We sampled 6 or 7 wells 1n the plume area. The residents knew that
we were going to sample their wells. When we received phone calls
from Interested citizens, we told them that 1f we had any negative
results, we would certainly get 1n touch with them right away. If
there was no problem, we would not notify them as such.
-------
Issue: When were the private wells sampled?
Response: We sampled them in Hay 1985.
Issue: My house 1s the last one on the left on your map. and we never
received any calls notifying us that our well would be sampled. In
fact, if any well should have been sampled, 1t should have been
ours, because we're right 1n the center of the plume.
Response: Our objective was not to sample every well; we know the plume is
there, we know where 1t is located, and we know at what level it
Hes. We simply wanted to confirm earlier sample results and
sample a few houses that were not previously sampled.
Issue: I didn't know anything about the well-sampling. I knew nothing
about this until yesterday when I read the article 1n the paper.
The EPA said that I had to have my well sampled on my own if I
wanted it sampled.
Response: Do you have a private well? What 1s your address?
[Citizen
Comment] :
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
About 2 or 3 years ago, all of the homes were checked out.
next to you, and your well was checked.
I live
As we begin to explain the remedial alternatives, you will see that
no one 1n this area 1s Ignored. We know that the contamination 1s
there, and we plan to address 1t.
Have you sampled any wells to the right of the plume?
ascertained the extent of the plume?
How have you
Historically, the wells have been sampled within this area, and we
sampled four of them as well. The wells are clean; we did not find
any contamination in this area. However, this whole area 1s going
to be addressed 1n a remedial alternative.
i
North of the site, where was the first monitoring well Installed,
if any?
We have piezometers near the Passalc River, but we do not have
monitoring wells north of the site.
Why 1s that?
This 1s further reason why we feel that additional studies are
needed. We did not have the time or the resources to encompass
this area in our study because we were focusing on the relationship
between the site and municipal well No. 7.
-------
Issue: Would it be fair to say that, lacking Information at present, there
may possibly be other sources of the contamination that you found
at your piezometers near the river?
Response: I would say that 1t 1s possible for other additional sources, but I
would not say that there are other sources Instead of the Caldwell
Site.
Topic: Alternative Mater Supply/Hater Hook-ups
Issue: What are you going to do 1f a person doesn't want to be hooked up?
My water 1s fine. At one one point, I could have switched, but at
this point 1n life, I don't want to.
Response: There are two alternatives. You can continue to drink contaminated
water, or we could require that the well be condemned.
Issue:
If the well 1s clean, will 1t be condemned anyway?
Response: You are looking at a plume of contamination that 1s moving under-
ground. Even If your well 1s not contaminated today, 1t could be
by tomorrow.
Issue: How many homes are left that are not hooked up? We have millions
of dollars being spent, but for what?
Response: We said that we—the EPA—will pay for any hook-ups.
Issue: How did you delineate the area that you recommended for water hook-
ups? How did you establish the boundaries?
Response: We started with the plume area that we defined. The state DEP
(Department of Environmental Protection) provided additional
Information about residential wells In other areas. We are dealing
with an unknown. It ,1s difficult to pinpoint exactly where a
contamination zone Is that you cannot see. It 1s silly to say that
someone on one side of the street Is going to get hook-ups and that
someone living on the other side 1s not. We tried to come up with
a general Idea of where the plume 1s and then, being a little
conservative 1n our approach, fanned out to Include everyone who 1s
potentially affected.
-------
Issue:
NJDEP
Response:
Issue:
NJDEP
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
What about those of us on the eastern side of the plume who aren't
eligible for hook-up? What about our health?
On the eastern side of the plume—beginning at Carlos Drive—the
State has been sampling wells in that area for the past 3 or 4
years, and the results have consistently shown no detectable or
very low levels of contamination. The levels should remain the
same over the next 9 to 12 months. Over the short term, your
health should be okay.
Do you know for a fact that it should be okay, or are you just
telling us that?
We have quite a bit of data—since 1982— in that area. It would
cost too much to sample every house; instead, we chose representa-
tive houses. I would suggest that if you feel uncomfortable with
the data, then have a sample taken or contact the health
department. The water 1s potable now, but over the long-term, it
could become a problem.
If the residents in those areas close to the plume decided to
connect to the hook-up at their own expense, would they be reim-
bursed once the money was appropriated?
You could get reimbursed under the State's Spill Fund, but Super-
fund does not reimburse homeowners.
Could the hook-up be expedited 1n any way?
The problem right now in expediting anything 1s that we are in
limbo relative to Superfund reauthorization. Certainly, as soon as
the funds are available, we will expedite the hook-up Immediately.
If the people who are eligible for a hook-up did not want one,
could they have the government put the money aside, which they
could use 1f the problem was determined to exist?
I would find 1t hard to believe that someone in the plume area
would want to drink contaminated water. It would be to the benefit
of homeowners to hook up to the public water supply to Increase
their property values. I'm not certain whether you would have a
choice If you were in the middle of the plume area. The state has
the authority to put the area under a well restriction, which would
mean that all current wells would be sealed and no new wells would
be constructed.
-------
Topic: Remedial Investigation/Feasibility Study Results
Issue: What Is the total volume of contaminated soil at the site?
Response: The volume 1s approximately 28,000 cubic yards. That would Include
several different areas.
Issue:
What are the soil action levels—the approximate concentrations?
Response: For which compounds? You have a different action level for each
compound, and these are 1n the report. I do not have the numbers
off the top of my head.
Issue: Are these EPA levels or OEP levels?
Response: They are risk base levels primarily, and where there are action
levels that exist either through EPA guidance or the state action
levels, we use those.
Issue: Could you give us the approximate levels of concentration for lead
and PCBs detected 1n the soil?
Response: The highest PCB level was 360 parts per million. There were
several high readings like that, and they occurred 1n both the
surface and subsurface soils but not outside certain areas. The
highest level found 1n surface soil was 75 parts per million; the
highest level found 1n subsurface soil was 360 parts per million
and that was almost 15 feet.
Issue: We're the PCBs Isolated 1n pockets, or were they fairly distributed?
Response: No, there Isn't too much distribution. We were taking samples all
the way down to 30 feet, and maybe only 1n one strata would we find
PCBs. We did not find them all the way down.
Issue: What were the concentrations for lead?
Response: I think maybe 400 or 500 parts per million. They vary a lot.
Issue: Is that contamination more evenly distributed?
Response: No, It 1s the same situation as with the PCBs. We took as many
samples as we could take. Some of the samples that we analyzed had
very high levels of lead and PCBs. Exactly how the contaminants
are distributed, I couldn't tell you. The difference Is that we
would detect lead 1n the surface as well as 1n the subsurface soil,
but only rarely would we detect PCBs of any concentration 1n the
surface soil.
-------
Issue: Would the capping alternative Include Installation of a slurry
wa-11?
Response: In this area, the land slopes In this direction. If the capping
alternative were to be Implemented, there would be a subsurface
diversion wall keyed Into the bedrock 1n this area so that any
water that Infiltrated and flowed through the soil or along the
bedrock surface would not go underneath the cap. It would be
diverted around the contaminated area.
Issue: Under one situation described (a remedial alternative), this land
would not be usable forever? Or would there be some new technology
to clean up the site?
Response: That 1s going to be the case with all of the alternatives except
for total excavation.
Issue: The contamination that 1s 1n the ground—would that just be allowed
to dissipate?
Response: The purpose of the cap 1s to minimize contaminant migration from
the subsurface soils Into the groundwater. Once you do that, 1t Is
not going to move appreciably.
Issue: But what about the problem that 1s already 1n the plume?
Response: We have a problem with people drinking contaminated water, so we
have to provide an alternative water supply somehow; the way we'd
like to do that Is to connect everybody who 1s potentially affected
to a public water supply. The second piece of this puzzle 1s that
we have contamination on the site, and the cap deals with
containing this contamination. Beyond that, there 1s a plume of
contamination underground that we haven't fully defined. We are
deferring our decision on how exactly to deal with that because we
feel that there has to be additional testing to make sure we
accurately define 1t and verify that there aren't any additional
sources causing the 'problem. We are not writing off the
groundwater problem, but we are deferring that decision until we
get some more data. We will start that task as soon as possible;
the only thing holding us back 1s Congressional approval of Super-
fund reauthorlzatlon.
Issue: In the alternative citing excavation and construction of a
landfill, how much of the money—of the total cost Involved—1s for
the construction and reinterment of the soil Into the landfill?
Response: It will cost $3.2 million to do everything—that 1s, excavating the
soil, constructing the landfill, putting the contaminated soil Into
the landfill, capping the landfill, and revegetating the area.
-------
Issue:
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
Issue:
Response:
Couldn't you spend a small amount of money to better define where
the concentrations of heavy metals and PCBs are, isolate those
pockets, and vaporize the soil so as to be able to use the land for
construction Instead of a landfill?
There are two problems. First, the nature of the material 1s such
that unconsolidated material 1s glacial material with boulders and
rocks. It 1s very difficult to get a good sample. We sampled as
much as we could, but there were a lot of zones that we missed just
because of mechanical difficulties. Therefore, we are unclear as
to the exact distribution of the contaminants. However, their
presence in the soil column is, no doubt, a large presence, and we
have to assume that, at least at this point, they are somewhat
evenly distributed. We are also obligated to follow regulations
concerning PCB wastes, and we have to landfill that waste.
You said that the volatilization
degrees. That seems very low, like
temperature was around 160
on the oven.
"warm"
It 1s 160 degrees Fahrenheit. These chemicals have very high vapor
pressures. We will have to refine that temperature and perform a
pilot study to determine the exact temperature.
Will this volatilization process lead to air pollution?
The gases coming from the dryer (in the air stripper system) will
be contained in a knock-out drum, to remove moisture, and from
there, they will go to a carbon adsorption container. At that
point, all of the volatilization is picked up, and the air that is
released is clean air.
How long would you maintain groundwater monitoring?
We are deferring our decision on the groundwater problem until we
collect more data and perform additional testing.
I'm concerned that your success will lead to your failure; that is,
you are going to resolve the onslte problem but not the
groundwater. As you take care of the onslte problem, the plume
crisis will become less of a crisis in light of the national prob-
lem with the Superfund 11st, and this plume will wind up decreasing
1n terms of Importance.
We would not let that happen because we do not change the priority
as a result of taking partial remedial action.
It 1s a concern because we would like to see the plume addressed
before the plume moves any farther.
We do not see that as a problem because the plume 1s not moving
that quickly.
-------
Issue: How far has the plume extended from the site already?
Response: It extends longitudinally about 4,000 feet all the way to the
Passalc River; 1t measures approximately 1,500 feet 1n width.
Issue: The northwest part of the plume 1s not defined. Could you give us
an Idea as to what plans you have to discern where that plume is
and what timetable you are operating on?
Response: Our contract with NUS terminates September 30, 1986, but NUS will
be part of another team of contractors working for the EPA. Our
plans would be to Install some additional wells 1n that area. We
are In a slowdown until Congress reauthorizes the funding—that 1s
the only thing stopping us right now. The OEP has data available
defining this area; a lot of work has already been done.
Issue: Old you say that Caldwell Trucking 1s not responsible for the
contamination of municipal well No. 7?
Response: Under normal conditions, when well No. 7 1s not pumping, 1t appears
that the normal direction of groundwater 1s away from the well,
toward the site. In other words, the well would be upgradlent of
the site. We do know that, through a pumping test, when the well
1s pumping at a normal rate necessary to supply water, the normal
gradient that would take the material away from the well reverses
Itself. When the well Is pumping, there 1s the potential that
contaminants from the Caldwell Site are drawn toward that well.
The pumping test that was done showed an Isolated plume around the
Ca.ldwell Site and another Isolated plume around Well No. 7. The
theory 1s that there may be another source contributing to the
contamination of well No. 7. Some of the contaminants 1n well No.
7 may have come from the Caldwell Site. Certainly, 1f you turned
well No. 7 on, 1t would draw contaminants from the site toward the
well. As a conservative approach to things, we are providing
treatment to well No. 7.. Part of the additional studies we will be
doing would help determine whether there are other sources 1n the
area around well No. 7 that are contributing to the contamination.
It 1s not that black and white relative to the Impact from the
Caldwell Site.
Issue: You said earlier that 1f you turned on well No. 7, 1t would draw
contaminants to 1t. Was a capture zone analysis conducted for that
well?
Response: Certainly, you could pump the well at a lower rate and create a
hydraulic barrier so that the contaminants would not move as far,
but the system 1s extremely complex and dynamic, affected not only
by municipal well No. 7 but also by other Industrial wells 1n the
area. We would not only have had to control well No. 7 but a lot
of other wells In the area, also.
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Issue:
Response:
Issue:
Did you monitor contaminant concentrations during that pumping
test?
Yes. The well was contaminated as soon as we started to pump 1t,
at approximately 0.5 parts per million total volatile organlcs. It
was sampled every few hours for 7 days, and the levels gradually
Increased to 1.5 parts per million by the end of the pumping test.
Is well No. 7 on airport property?
full of on.
I see ditches at the airport
Response: No, 1t 1s not on airport property. The airport 1s one of the areas
that we will Investigate 1n the future to determine whether 1t 1s a
source of contamination.
Issue: When you begin the additional groundwater studies, will you put a
monitoring well on airport or county property?
Response: We will come back before we begin the groundwater study and conduct
a scoping meeting to get your Input as to what areas you feel we
should Investigate.
Topic: AdBlnlstratlve/Legal Concerns
Issue: If you are going to build an aeration tower at well No. 7, why not
build one at Falrfleld's distribution point, which provides water
for the whole system?
Response: Right now, the first priority 1s to provide people with a safe
source of drinking water. We can do that 1n several ways. We can
have you purchase the water from Passalc Valley and maybe foot the
bill for that, or we can turn on well No. 7, provide some treat-
ment, and get a good quality source of water. We are not defining
(the treatment of) well No. 7 as the way to clean up the
groundwater plume, and we are not saying that we need air strippers
all over the place. What we are saying 1s that as a method of
providing these people with a safe source of drinking water, well
No. 7 seems to be a viable alternative, and the pumping rate ap-
pears to satisfy the current need for that well.
The township would apparently like to Increase the capacity for
that well and 1s looking for a larger unit than the EPA could pay
for under the Superfund Program. Certainly, the township can pay
the difference to have a larger unit Installed, but the EPA can
only pay for the Superfund-related problem. Any expansion would be
up to the town to decide and to pay the difference. Also, there 1s
no reason to treat the whole system, as there are only two wells
that are contaminated in the system—Wells No. 2 and No. 7. And
Well No. 2 Is very small 1n comparison, pumping 50 gallons per
minute compared to 400 gallons per minute.
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Issue: Are you going to try to force Caldwell Trucking and General Hose to
pay for the $4.5 million 1n costs?
Response: We will deal with that after we complete the remedial action.
Issue: I am representing the County Administrator's Office and would like
to Inform you that we will be submitting written commments.
However, I do have several questions to ask tonight. You haven't
defined a time schedule for this remediation process.
Response: Superfund reauthorfzatlon Is really holding us up right now. We
know that we are going to provide people with hook-ups to a public
water supply.
Issue: The final concern deals with the process of having these regularly
scheduled meetings with the public and the meetings held lately.
We would like to see regularly scheduled meetings with the public
to provide updates on the status of the project.
Response: Do you mean like every 6 months or so? We can do that.
Issue: In determining present-worth costs* what discount rate did you use?
Response: Ten percent, which you cannot get anymore.
Issue: How does this site rank on the National Priorities List?
Response: It 1s 1n the top 10 percent.
Issue: I understand that this particular site overlies a sole-source
aquifer. What priority does a site affecting a sole-source aquifer
receive from the EPA?
Response: Normally, as a general guidance, we try to address sites on the
National Priorities List 1n the order of their priority. Once the
remedial Investigation.begins, there 1s no advantage to Increasing
or decreasing the priority. We are going to move as fast as we can
through the process. The trigger date 1s the day we start; from
then on, we are restricted by how long 1t takes to collect the
samples and to receive sample results, how long 1t takes to find a
contractor, and so on.
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Topic: Other Concerns
Issue: On the map, there Is no Indication of the Jersey City water pipe-
line. The pipe has not been cleaned. A lot of water 1s going over
the pipeline. I've lived here for 26 and have had a lot of prob-
lems with my septic line. The first time there was a problem, the
people along Orlando Drive received free water hook-ups because
nobody knew where the contamination was coming from. I think you
should Investigate the factories 1n the area of the pipeline and,
if they are 1n violation, then say so. Please clean up the pipe-
line.
Response: Could you show us where that pipeline is on the map? We
acknowledge that we have some contamination off site, and we will
deal with that. We also accept the fact that we have not fully
delineated the extent of groundwater contamination, that there may
be other sources in the area that are causing problems. We will
notify the public when we start the investigation of other sources.
Issue:
Township
Response:
There aren't many people here tonight, even though there was an
article in the paper. And you had to read that article very care-
fully to even know that there was going to be a meeting. Why
wasn't there anything in the article to inform people of the
meeting and to get more people to attend? (This question was
directed toward a local official.)
I believe that the news release was distributed to all of the local
papers. I don't know why the article did not mention it to a
greater degree. Actually, we are not running this meeting; it is
being conducted by the EPA.
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WRITTEN COMMENTS
Source of Comments - Passaic River Coalition
Issue: The Remedial Investigation did not accomplish the
original objectives; namely, to accurately define
the nature and extent of the ground water contami-
nation downgradient from the site and Well #2, and
the contribution to that contamination by General
Hose Products Co.
Response: During the Remedial Investigation, it became apparent
that sources other than Caldwell Trucking and General
Hose Products were contributing to the area ground
water contamination. To properly investigate all
the potential sources would have resulted in a
substantial increase in the scope of the remedial
investigation with corresponding increases in time
and costs. At that time, additional funding for this
site was limited and it was decided to utilize the
available resources to the maximum extent possible.
Sufficient funds were available to properly investigate
Well #7 and Caldwell Trucking. Caldwell Trucking
was believed to be the major source of the contamina-
tion and Well #7 appeared to be the most significant
impact caused by the site. So as not to delay action
on the Caldwell Trucking property and Well #7 while
awaiting additional funding, EPA proceeded with the
feasibility study to determine the cost-effective
remedial actions for those portions of the site.
EPA recognizes that additional investigation of the
ground water contamination, including identification
of other sources such as General Hose Products, is
necessary. Further investigation of General Hose
Products will be included in the future investigation.
In regard to Well #2, the National Priority List
description of the Caldwell Trucking Company site
did reference Well #2. However, prior to our initiating
the Superfund action at this site, EPA was informed
by the State that, based on its investigation, Well
#2 did not appear to be impacted by the site.
Therefore Well #2 was not included in EPA's study.
Issue: The public comment period after the public meeting
was very short, indicating prior conclusions and a
possible disinterest in substantive comment.
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Response: It is EPA's policy to hold the public meeting in the
middle of the public comment period. The primary
purpose is to allow the public to review the documents
before the public meeting so that EPA can receive
substantive comments and respond to specific questions
and concerns at the public meeting.
Issue: The study shows that pumping Well #7 induces flow
from the site and, hence, whether the site contaminated
Well #7 in the past or not, the site clearly contributes
to the continued shutdown of Well #7. Therefore, the
site is a proven source of ground water contamin-
ation which makes Well #7 non-potable. EPA should
make that conclusion.
Response: The concentration of contaminants, regardless of
their origin, is responsible for Well #7 being non-
potable. The pumping of Well #7 indicates a potential
for contaminants to migrate from the site to Well #7.
Because of this potential, EPA evaluated remedial
alternatives for Well #7.
Issue: Alternative No. 1, the No Action Alternative, is
clearly untenable, a straw man.
Response: EPA policy requires an evaluation of the "No Action"
Alternative. The comment on this alternative will
be considered in EPA's selection of the remedial action.
Issue: Alternative 2, purchase of water, requires Fairfield
to assume the burden of contamination caused by
others.
Response: If EPA were to choose this alternative, the financial
burden of purchasing water may be assumed by the
government. The burden of replacing the resource
lies with the Passaic Valley Water Commission. EPA
has considered this in the selection of the remedial
action.
Issue: Alternative 3, wellhead treatment, should include a
mechanism for divorcing Well #7's cone of influence
(depression) from Caldwell Trucking's plume, since
treatment at the wellhead is not viable if additional
contamination is induced from the site.
Response: The remedial investigation indicates a potential for
contaminants to migrate from the site to Well 17.
This potential was realized at a pumping rate of
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390 gpm. Based on the present pumping pattern in
the area, EPA estimates that the maximum flow rates
for MW-7 be held to the 200-300 gpm range, with the
further precaution of using well No. 8 to monitor
the clean zone between the site and MW-7.
Issue: Alternative 3, treatment at the wellhead, must not
substitute for aquifer decontamination.
Response: Treatment at the wellhead is not intended to be the
sole action for aquifer decontamination. The remedial
alternatives for aquifer decontamination will be
evaluated in a future study.
Issue: Remedial Component II - remediation of the ground water
plume. The alternatives in this component are totally
insufficient to address the problem of the downgradient
plume. Additional alternatives should be evaluated.
Response: Remedial alternatives to address the ground water
contamination will be evaluated in a future study.
EPA recognizes, and did not intend for the altern-
atives presented to be a complete remedy for the
downgradient plume. The alternatives are intended
to evaluate the need for an interim action (operable
unit) to prevent the consumption and exposure to
contaminants by residents.
Issue: Alternatives 6 and 7 are clearly inadequate to the
problem.
Response: For this particular site, EPA agrees.
Issue: Remedial Component III, remediation of on-site wastes
and contaminated soils. An option not listed is to
remove the VOCs (volatile organic compounds) through
vaporization and remove the remaining contaminants
to a secure location.
Response: This alternative is identified as an option to
Alternative 9. This is the selected alternative for
the on-site material. The on-site landfill will be
designed and built to comply with the specifications
of a secure hazardous waste landfill pursuant to the
Resource Conservation and Recovery Act (RCRA).
Issue: The Fairfield area is located within the Buried
Valley Aquifer Systems sole source aquifer. Its use
as a hazardous waste dump was not suitable in the
past nor is it suitable now.
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Response: The sole source aquifer in the vicinity of the site
was considered in EPA's selection of the remedial
action for the on-site wastes. EPA believes the
disposal of the wastes in a secure landfill designed
to RCRA specifications will adequately protect the
ground water. A further discussion of this appears
in the Record of Decision under, "Consistency With
Other Environmental Laws".
Source of Comments - Attorneys for Caldwell Trucking (PRP)
Issue: One of the stated objectives of the RI, namely, "to
determine the nature and degree of contaminant
migration off-site and related environmental impacts
and public health hazards", indicates that NUS Cor-
poration had some preconceived ideas about the
site's contribution to the plume.
Response: RI/FS contractors like NUS conduct technical studies.
without prejudice. They base their findings and
assumptions on field data and hence their reports
are free of words such as "alleged", "reportedly",
etc. Similarly, while the contractor may have seen
evidence of other sources in performing the RI, the
scope of the RI did not include searching for these.
sources. This will be part of the scope of a future
RI/FS.
Issue: Hydrogeology - The contractor indicates that ground
water flow and elevations in the deep aquifer under-
lying the study area are reported to be primarily
controlled by fracture zones and an isolated, laterally
continuous strata within the basalt of fractured,
sedimentary rock. The report lacks quantitative
data to support this conclusion.
Response: This comment is difficult to understand since the
report discusses extensively the continuity of flow,
the movement of contaminants in the direction of
flow and their location as a result of flow. There
are some wells which exhibit anomalous water levels
such as GH-1, MW10, MW1, MW2. These wells are
explained by NUS as not tapping the more regional
fracture zone in which the contaminants are generally
found. Such situations are not uncommon in fractured
rock and therefore should not be surprising. Indeed,
further testing might satisfactorily explain all
anomalies, but such activity was beyond the necessary
scope of the report. In addition, it is our opinion
that the data from the RI/FS yielded a reasonable
picture of the hydrologic conditions at the site.
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Issue: The attorneys for Caldwell Trucking make the following
assertion, " the narrow scope of the present RI and
resulting data are inadequate to support the proposed
finding that the site is a source of the plume of
contaminants. Furthermore, the other conclusions of
the report, narrow as it is, demonstrate that this
finding is tentative, lacking in supporting data and
premature."
Response: It is our opinion that the RI/FS has demonstrated
beyond all doubt that the high concentrations of
contaminants found in the buried lagoons on the site
are leaching into the shallow and bedrock aquifers
creating a plume.
Issue: The report states that the pumping of Well No. 7
over time resulted in localized reversal of the
hydraulic gradient between the well and the site.
No quantitiative evaluation (such as a capture zone
analysis) was provided concerning the potential for
drawing contaminants from the site to the well.
Response: Capture zone analysis was preformed by NUS and is
illustrated by figures 4-8 and 4-9 of the RI. How-
ever, the problem is complicated by the pumping of
industrial wells in the area.
Issue: Alternative #5, which proposes hooking-up a 100
residences in the plume area, appears premature or
excessive at this point.
Response: It is our technical determination that the RI and
additional State data show that 100 homes, which
will be supplied with an alternate water supply, are
either currently contaminated or have a potential
for future contamination of their well water.
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