United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/072
September 1988
SEP A
Superfund
Record of Decision
Burnt Fly Bog, NJ
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REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/072
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Burnt Fly Bog, NJ
Second Remedial Action
5. Report Date
09/29/88
1
Authors)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Burnt Fly Bog site is located in Marlboro Township, Monmouth county, New jersey.
The site is situated in a rural area with an auto salvage yard and a few scattered
residences, nearby. The entire Burnt Fly Bog encompasses about 1,700 acres. This
remedial action addresses the 10-acre area constituting the Westerly Wetlands Operable
Unit. The area is affected by contamination from the 10-acre parcel where waste was
originally deposited (Uplands Area Operable Unit). The site includes both flood plains
and wetlands. Contamination has been detected in the surface water, surface soil, and
shallow subsurface soil as -a result of uncontrolled discharges and runoff from the
plands Area waste sources. The Uplands Area includes several abandoned oil storage and
treatment lagoons containing residual oil sludges and aqueous wastes, contaminated waste
piles, and buried or exposed drummed wastes. These are the result of activities at the
site from 1950 to 1965. The site property is presently owned by Mr. Dominick Manzo, who
operated part of the property as a sanitary landfill from 1963 to 1969. The Uplands
Area is currently being cleaned up under a Record of Decision signed on November 16,
1983. The volume of soil contaminated with PCBs and lead is estimated to be 76,400
yd3 at the site, with an additional 5,600 yd-3 of contaminated sediments in an
adjacent downstream area. There is no evidence of PCB contamination in surface water.
(See Attached Sheet)
Burnt Fly Bog, NJ
Second Remedial Action
Contaminated Media: sw, soil, sediments
Key Contaminants: metals (lead), PCBs
b. Identifiers/Open-ended Terms
c. COSATI Reid/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
46
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-88/072
teurnt Fly Bog, NJ
Second Remedial Action
16. ABSTRACT (continued)
The primary contaminants of concern affecting the surface water, soil and sediments are
PCBs and lead.
The selected remedial action for this site includes: access restrictions; excavation
of contaminated sediments from the downstream area with disposal at an offsite RCRA
Subtitle C facility; as an interim remedy, containment without capping contaminated soil
in the Westerly Wetlands through installation of a sedimentation basin and appropriate
diversion controls; and performance of treatability studies on the most promising
innovative technology alternatives to provide the final remedy. A subsequent ROD will
address this final remedy for the contaminated soil. The estimated present worth cost
for this remedial action using a 20-year life estimate is $6,100,000 with annual O&M
costs of $320,000.
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DECLARATION STATEMENT
RECORD OF DECISION
Burnt Fly Bog
Westerly Wetlands
SITE NAME AND LOCATION
The Burnt Fly Bog Superfund site is located in Marlboro Township,
Monmouth County, New Jersey.
STATEMENT OF PURPOSE
This decision document presents the selected interim remedial
action for the Westerly Wetlands portion of the Burnt Fly Bog
Superfund site, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act
of 1986, and to the extent applicable, the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300.
The state of New Jersey has been consulted and agrees with the
selected remedy for the Westerly Wetlands operable unit of the
Burnt Fly Bog Superfund site.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record, and which
characterize the nature and extent of contamination and evaluate
remedial alternatives for the Burnt Fly Bog site:
- Westerly Wetlands Supplemental Stage II Field Investigations:
Volume Estimate of Contaminated Soils—Final Report, pre-
pared by Ebasco Services, January 1988;
- Westerly Wetlands Supplemental Stage II Investigations:
Feasibility Study, prepared by Ebasco Services, January 1988;
- Westerly Wetlands Supplemental Stage II Investigations:
Water Budget, prepared by Ebasco Services, January 1988;
- Environmental Information Document: Engineering Study for
the Cleanup of Burnt Fly Bog, Marlboro Township, New Jersey,
prepared by Dames & Moore, March 1983;
- Record of Decision for Burnt Fly Bog, Uplands Area Operable
Unit, November 16, 1983;
- Basis of Design Report: Upland Area Remedial Action, prepared
by Ebasco Services, May 1986;
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- Implementation of Final Remedial Action at the Burnt Fly
Bog Site Uplands Area: Volumes I and II, prepared by Ebasco
Services, July 1986;
- Proposed Remedial Action Plan for the Burnt Fly Bog site,
March 1988;
- The Responsiveness Summary for the Burnt Fly Bog site based
on the public meeting held on March 29, 1988;
*«
- The attached Decision Summary for the Burnt Fly Bog site; and
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
The remedial alternative presented in this document represents
an interim remedy for the Westerly Wetlands portion of the Burnt
Fly Bog site. This alternative includes the following components:
- Excavation of approximately 5,600 cubic yards of contaminated
materials from the Downstream Area which have migrated past
the Westerly Wetlands;
- Disposal of the excavated materials at an off-site facility
in the same manner as the materials being addressed by the
on-going remedial action for the Uplands Area;
- Containment without Capping of the contaminated soil in the
Westerly Wetlands through the installation of a. sedimentation
basin and appropriate diversion controls;
- Construction of a security fence and access road around the
Westerly Wetlands; and
- Treatability studies on the most promising treatment altern-
atives for the contaminated materials in the Westerly Wetlands,
the Northerly Wetlands and the Contaminated Soils Area.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Com-
pensation and Liability Act of 1980, as amended, and the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the selected remedy is protective
of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for
this remedial action, and is cost-effective.
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Furthermore, the remedy utilizes permanent solutions and alter-
nate treatment technologies to the maximum extent practicable
for the contaminated materials in the Downstream Area. However,
because treatment was not selected as a component of the remedy,
it does not satisfy the preference for treatment that reduces
toxicity, mobility or volume as a principle element for the
contaminated soils in the Westerly Wetlands.
Date William 3< Mus^frjpSki , P.E.
Acting Regional Administrator
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SUPPLEMENTAL RECORD OF DECISION
DECISION SUMMARY
BURNT FLY BOG SITE
Westerly Wetlands Operable Unit
Marlboro Township, Monmouth County, New Jersey
SITE LOCATION
The Burnt Fly Bog Superfund site is located near the intersection
of Texas and Spring Valley Roads in Marlboro Township, Monmouth
County, New Jersey, in the east-central part of the State (see
Figure 1). The site is situated in a rural area about thirty
miles northeast of New Jersey's capital of Trenton and about five
miles from Raritan Bay (see Figure 2), with only an auto salvage
yard and a few scattered residences nearby.
The Township's dominant land uses include agricultural land,
vacant and wooded lands, and residential developments. While
the entire Burnt Fly Bog encompasses about 1,700 acres, the
area constituting the Superfund site is limited to the approxi-
mately sixty acres apparently affected by contamination (see
Figure 3). The majority of the waste was originally deposited
in a ten acre parcel located in the southeastern area (Uplands
Area) of the site. Much of the waste has since migrated west-
ward to the Westerly Wetlands.
SITE DESCRIPTION
The Burnt Fly Bog site consists of two basic areas: the Uplands
Area and the Westerly Wetlands (See Figure 4).—Ihe-UpXands
Area includes several abandoned oil storage and treatment
lagoons containing residual oil sludges and aqueous wastes,
contaminated waste piles, and buried or exposed drummed wastes.
The Westerly Wetlands area has contamination in the surface
water, surface soil, and the shallow subsurface soil. This
contamination is a result of uncontrolled discharges and run-
off from the Uplands Area waste sources.
The Uplands Area is currently being cleaned up under a Record
of Decision (ROD) signed on November 16, 1983. The Westerly
Wetlands and the Downstream Area is the subject of this operable
unit ROD.
This site is located in a fringe area of the New Jersey Pine
Barrens. The New Jersey Pine Barrens is an environmentally
sensitive area of the state. The interior of the bog is
considered an undisturbed wilderness area with documented
reports of wildlife including red and gray fox, several species
of squirrel, rabbit, white-tailed deer, opossum, raccoon,
skunk, and seasonal birds. Other wildlife types, such as reptiles
and amphibians, are also present.
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MARLBORO
PENNSYLVANIA
FIGURE 1
REGIONAL SITE LOCATION
BURNT FLY BOG
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luck
FIGURE 2
* LOCATION OF BURNT FLY DOG
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; M~ A'*•-=*. V" ^V ~r-« S^'l; • --//
j ..^ft«-'^ * Vfi.._.^A
- /^!?
/' ?:":^
/' •*;. * -T; ."•" -"• . **
M ^ ^
s? ^
\ .xi ^^:
' FIGUMf'3
STUDY AREA 6 ENVIRONS
IW
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• tM
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The Westerly Wetlands is an approximately ten-acre, irregularly
shaped area lying to the west and southwest of the Uplands Area
of the site. It is approximately 2,500 feet in length and
about 200 feet wide at its widest point.
Like the Uplands Area, the Westerly Wetlands is located in the
outcrop area of the Englishtown Formation. At the Westerly
Wetlands, a relatively impermeable clay layer is at or near the
ground surface. Ground water flowing through the overlying
upper sand layer discharges to the surface of the Westerly
Wetlands which is inundated most of the year. The Westerly
Wetlands receives drainage from the Uplands Area (including
lagoons) and most of the surrounding 1,700 acres of bog and
pine barrens. Surface water flows from the Westerly Wetlands
to the southwest, where it eventually joins a channel draining
the entire Burnt Fly Bog area. Ultimately, the combined flow
enters Deep Run, a creek located approximately 3,000 feet from
the western end of the Westerly Wetlands. Deep Run is a source
of potable water for the City of Perth Amboy, New Jersey.
The Westerly Wetlands has had significant loss of plant cover
as the result of a fire in 1973 and the potentially toxic
effects of contaminants present in the Wetlands. Some of the
lower portions of this area have not redeveloped vegetative
cover, while other areas have re-established indigenous plant
life. This varied redevelopment of the area is linked to
differing levels of contamination and is influenced by natural
erosion patterns.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The activities responsible for contaminating-the-area occurred—
during the interval from 1950 to 1965. During this period,
different portions of the site were used for reprocessed oil
storage or settling lagoons, oil reprocessing filter cake
storage, sanitary landfill activities, and sand and gravel pit
operations.
Prior to 1950, the Burnt Fly Bog site was still an undeveloped
area. About 1950, the Champion Oil Company established an oil
reprocessing facility located on Orchard Place in Morganville,
New Jersey, approximately two miles east of the site. At about
the same time. Eagle Asphalt Company purchased that portion of
the present Superfund site comprising the area around the four
lagoons in the Uplands Area. These lagoons were developed for
use as oil storage facilities and as settling ponds to handle
the reprocessed oil. These facilities were operated until the
property was sold in November 1964 to a Mr. Eckel.
In 1960, sanitary landfill operations began at another portion
of the future Burnt Fly Bog site, reportedly receiving local
trash. The owner/operator, Mr. Towler, died in 1961, and the
landfill discontinued operations. Subsequently, Mr. Dominick
Manzo purchased the property in December 1963, reopening the
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landfill and operating it with the approval of the municipality
until 1967. In July 1965, Mr. Manzo acquired the former Eagle
Asphalt Company property from Mr. Eckel. This purchase,
coupled with the purchase of an adjoining plot in July 1968,
brought under one ownership adjoining plots of land that
together would eventually become known as the Burnt Fly Bog
Superfund site.
In 1969, the Middlesex County Court ordered the closure of the
landfill. Aside from the deposition of excavated fill from a
Hazlet, New Jersey sewer construction project in July 1979,
there have been no operations at the site since 1969. On
October 26, 1973, a fire started and burned at the site for
16 hours before it was finally extinguished.
The New Jersey Department of Environmental Protection (NJDEP)
has the lead for this site. As such, all studies and actions
were performed by NJDEP. A remedial investigation and feas-
ibility study (RI/FS) was performed for the Uplands Area to
characterize the contamination at the site and to evaluate
remedial action alternatives. On November 16, 1983, a Record
of Decision (ROD) was signed selecting the remedial action
to be taken for this portion of the site. The 1983 ROD also
called for a supplemental RI/FS to further investigate the
Westerly Wetlands. This supplemental RI/FS was completed in
March 1988.
The search for potentially responsible parties (PRPs) for
this site is ongoing. To date, the PRPs who have been notified
of the impending actions have declined to voluntarily undertake
them.
CURRENT STATUS
This Record of Decision addresses the Westerly Wetlands area.
The Uplands Area, currently in the remedial action phase, was
addressed in a ROD signed on November 16, 1983.
In November 1985, contaminated materials from the "Asphalt
Pile" area were removed as an Interim Remedial Measure. In
March 1988, remedial activities for the Uplands Area were
initiated in accordance with the original 1983 ROD. These
remedial activities include excavation and off-site disposal of
contaminated materials from the Uplands Area.
Two contaminated areas included in the 1983 ROD (the Northerly
Wetlands and the "Contaminated Soils" Area) are not being
addressed as part of the current remedial action for the Uplands
Area. Since these areas are more topographically and hydro-
logically similar to the Westerly Wetlands than the Uplands
Area, they will be remediated as part of a future ROD for the
Westerly Wetlands and these areas.
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In addition to defining the remedial actions for the Uplands
Area, the 1983 ROD called for further study of the Westerly
Wetlands to determine the extent of contamination in this area.
Following the 1983 ROD, field investigations were performed to
determine the nature and extent of contamination in the Westerly
Wetlands as well as the non-wetland area immediately downstream
of the Westerly Wetlands known as the Downstream Area. Follow-
ing the characterization of the study area, a feasibility study
was performed to evaluate alternatives for the remediation.
The RI/FS was released to the public on March 13, 1988.
COMMUNITY RELATIONS HISTORY
In 1981, concerned residents organized the Burnt Fly Bog Citizens
Advisory Committee (BFBCAC). BFBCAC, originally composed of
residents from Marlboro and Old Bridge Townships, now includes
Marlboro Township residents and officials, and Monmouth County
officials. The Committee functions as the liaison between the
NJDEP and the local community.
Since the establishment of NJDEP's Community Relations Program
in 1982, representatives of NJDEP have met with the BFBCAC
approximately four times per year. All pertinent site data,
reports and events have been shared and discussed with the
BFBCAC to enable their input to be incorporated into the decision-
making process involving site activities.
Community concerns have focused primarily on the potential envi-
ronmental and human health risks posed by the site. The inges-
_tion-X>f -contaminated -ground-stater—or surface water has been of
major concern to the community because of the high lead concen-
trations at the site. Moreover, residents and officials of
neighboring communities have expressed concern about contam-
inant migration to Deep Run which receives drainage from the
Westerly Wetlands.
Several public meetings have been held to present the findings
of the Upland Area studies. In August 1983, a public meeting
was held to discuss the remedial alternatives evaluated for
the Uplands Area of the site and to receive public comment
before selecting the remedial action for this portion of the
site.
On March 13, 1988, the Westerly Wetlands RI/FS and the Proposed
Remedial Action Plan (PRAP) were made available to the public
at the Marlboro Township Municipal Building and the Monmouth
County Library. The PRAP is a summary of the RI/FS and the
remedial actions that are being proposed by the Environmental
Protection Agency (EPA) and NJDEP. On March 29, 1988, a public
meeting was held to present the findings of the Westerly Wetlands
RI/FS and PRAP and to receive public comment. The public
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comment period lasted until April 29, 1988, during which time
comments and questions from members of the public were accepted.
A Responsiveness Summary is attached which incorporates the
public comments raised at the public meeting and submitted
during the public comment period. Also included in the Responsive-
ness Summary are the NJDEP and EPA responses to these comments.
As stated in the PRAP, notice of the selected remedial action
plan (documented in this ROD) will be published and the final
plan itself made available to the public at the repositories
before the commencement of any remedial action.
SCOPE AND ROLE OF OPERABLE UNIT
As discussed above, a ROD was signed on November 16, 1983 that
selected the remedial actions for the Uplands Area. That ROD
also called for further investigation into the Westerly Wetlands
portion of the site.
In conformance with the 1983 ROD, a supplemental RI/FS for the
Westerly Wetlands was performed. This supplemental RI/FS found
that there is significant polychlorinated biphenyl (PCS) and lead
contamination in the Westerly Wetlands and the Downstream Area
that pose risks to human health and the environment. These
risks include direct contact with contaminated soils and sediment,
and uncontrolled off-site migration of contaminants into Deep Run,
which is serving as a water supply for the City of Perth Amboy.
Following the completion of the Westerly Wetlands RI/FS, suffi-
cient information was not available, specifically treatability
data, to evaluate potential alternative treatment technologies
that may be applied. In view of this and because of the need
to take prompt action to mitigate site threats, several alterna-
tives were analyzed for temporary containment. Each of these
alternatives is an interim action. However, downstream sediments
would be excavated as a final measure and disposed of off-site
as a final action.
The treatability studies to be performed will evaluate the
most promising innovative technologies for the treatment of
the contained contaminated material. Following the completion
of the treatability studies, a third ROD will be signed selecting
the final remedy for the contaminated soil.
SITE CHARACTERISTICS
Field investigations for the Westerly Wetlands were segregated
into the Westerly Wetlands proper and the Downstream Area.
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Westerly Wetlands
Chemical analysis of the Wetlands soil has indicated a large
extent and high degree of PCB and lead contamination. PCB
concentrations in the Wetlands soil range from "not detected"
(ND) to 232 parts per million (ppm). The distribution of
contaminated soil suggests that the PCB contamination is only
a surface phenomenon. In addition, chemical analysis of the
surface water in the Westerly Wetlands indicates that PCBs
are not present in water. The total volume of PCB-contaminated
soil in the Wetlands above 5 ppm (the New Jersey soil cleanup
criterion established as the action level for the site) is
approximately 62,600 cubic yards (cy). This total does not
include the contaminated soils discovered in the Downstream
Area.
Lead contamination has been found in the Wetlands soil within
the area of PCB contamination and elsewhere. Lead has been found
in the Wetlands soil in concentrations ranging from ND to
31,000 ppm.
It was found that an additional 13,800 cy of soil is contami-
nated with lead above 250 ppm (the New Jersey soil cleanup
criterion established as the action level for the site), bringing
the total amount of contaminated soils in the Westerly Wetlands
to 76,400 cy. Lead was found in the surface water at concen-
trations ranging from 44 parts per billion (ppb) to 1,900 ppb of
total lead (16 ppb to 1,600 ppb of dissolved lead). Finally, it
should b.e noted that contaminated soil continues to migrate
with surface water run-off. As such, the area of contamination
will continue to change unless some action is taken.
Downstream Area
In the upper reaches of the Downstream Area adjacent to the
Westerly Wetlands boundaries, high concentrations of PCBs and
lead were detected in the sediments. PCB contamination was
found to range in concentration from ND to 8.4 ppm, with
approximately 1,400 cy of sediments containing PCBs above
5 ppm. Lead contamination in sediments was found to range in
concentration from 2 ppm to 1,900 ppm, with approximately
4,200 cy of sediments above 250 ppm. The total volume of
contaminated soils exceeding action levels in the Downstream
Area is 5,600 cy. There was no evidence of PCB contamination
in the surface water. However, lead was found in the surface
water and measured from 4 ppb to 280 ppb of total lead (3 ppb
to 200 ppb of dissolved lead), decreasing in the downstream
direction.
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The total volume of contaminated soils is the sum of the volume
from the Westerly Wetlands (76,400 cy) and the volume of contami-
nated soils from the Downstream Area (5,600 cy). This total
volume amounts to 82,000 cubic yards.
SUMMARY OF SITE RISKS
The results of the risk assessment prepared for the Westerly
Wetlands indicate that there are two major contaminants of concern,
PCBs and lead, and four significant routes of human exposure:
- ingestion of site soil
- ingestion of blueberries grown on-site
- inhalation of airborne contaminants in case of a fire
- ingestion of ground water/surface water
The risk assessment shows that exposure through the ingestion
of blueberries poses a marginal concern for lead but may be
significant for PCBs.
The potential for fire at the site exists and is evidenced by
the fire that occurred in 1973. During a fire, the potential
for the release of PCBs into the atmosphere and the formation
.and subsequent release of polychlorinated dibenzofurans and
polychlorinated dibenzo-p-dioxins could pose a significant
health risk.
Only lead presents a concern in the potential ingestion of sur-
face and'ground water. Given that Deep Run is being used as a
water supply downstream of the Westerly Wetlands and the Wetlands
becomes a recharge zone for the Englishtown aquifer during
drought conditions, there is significant risk associated with
this pathway.
In addition to the human health risk, there is also the
continued risk to the environment. As noted before, the area
has a varied indigenous animal and plant population, which
remains at risk under the present site conditions. Further
migration of contaminants will continue under the present site
conditions, which will threaten the surface water downstream of
the site.
DESCRIPTION OF ALTERNATIVES
After screening more than 50 potential technologies, the RI/FS
identified fourteen different alternatives for further evaluation.
These alternatives were evaluated using remedial action levels
of 5 ppm for PCBs and 250 ppm for lead, the New Jersey soil
cleanup criteria that EPA and NJDEP have agreed to use for this
site.
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The 14 alternatives evaluated in the RI/FS were final alterna-
tives that included both conventional and alternative treatment
technologies. Final remedial alternatives discussed in the
RI/FS included:
Conventional Technologies:
Total In Situ Encapsulation
Excavation and Total Encapsulation (On-site Landfill)
Excavation and Off-site Disposal
Innovative/Alternative Treatment Technologies:
In Situ Vitrification
On-site Incineration
B.E.S.T. Process
Potassium Polyethylene Glycol (KPEG) Process
Fixation/Solidification
Ultrasonics/Ultraviolet Irradiation
Bio-Clean Process
As stated before, since treatability data were not available
for the innovative/alternative treatment technologies, they
could not be fully evaluated. In addition, since the Superfund
Amendments and Reauthorization Act of 1986 requires that treat-
ment alternatives be fully evaluated during remedy selection,
a final remedial action could not be selected for this operable
unit. ~~'
**
However, since there is currently a risk to human health and
the environment, an interim remedial action was considered
necessary. This operable unit ROD will address interim
remedial actions for the Westerly~Wetlands.The~~interim
remedial actions discussed in this ROD were evaluated in the
RI/FS as final remedial actions, but are evaluated in this
ROD only as interim actions. The following will reference
the interim alternatives discussed in this ROD to the final
alternatives discussed in the RI/FS and attached responsiveness
summary:
ROD RI/FS & Responsiveness Summary
A. No Action/Site Security A. No Action
B. Excavation and Site D. Excavation and Site
Consolidation Consolidation
C. Containment without Capping and F. Non-Encapsulation Containment
Excavation of Downstream Area
D. Containment without Capping and G. Non-Encapsulation Containment
Hot Spot Removal and Hot Spot Removal
A portion of three of the remedial actions will include final
remedies for proposed excavated portions of the site.
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Table I lists the construction activities required for each
of the following alternatives:
Alternative A; NO ACTION/SITE SECURITY
EPA considers the no action, or in this case, a limited action
alternative as a baseline for comparison with other alternatives.
This alternative would leave the Westerly Wetlands in its present
state. There would be no action relative to site contamination.
However, limited work would be performed including ground- and
surface-water monitoring and fencing to limit access to the
site.
The ground- and surface-water monitoring program would be per-
formed on a quarterly basis to assess the on-site contribution
of contaminants to the shallow and deep aquifers. This would
be accomplished through the installation of one shallow and
one deep monitoring well to help quantify any contamination
from the site. Periodic maintenance of fencing would be
required.
Alternative B; EXCAVATION AND SITE CONSOLIDATION
Site consolidation operations would consist of the excavation
of contaminated soils from a portion of the Wetlands and putting
these soils on the remaining Wetlands area to reduce the total
area of contamination. In effect, about one-half of the Wetlands
area would be remediated by excavation and the remaining area
by containment without capping and sedimentation.
Site operations would involve excavation, backfilling, and
construction of the containment syste»-whte«-wouid—inciude-ar
ditch and dike system and a sedimentation basin.
Approximately 41,000 cy of material would be excavated and
consolidated on the remaining five acres of undisturbed contami-
nated Wetlands. The excavated area would be backfilled and the
original grade re-established. A ground water diversion
system would be used during excavation. Surface run-on and
run-off would be controlled via a ditch system. Run-off and
leachate from soil dewatering and ground water pumping during
excavation would be channeled to a sedimentation basin.
A ditch and dike system, along with a perimeter access road and
fence, would be constructed around the five-acre site in which
all the waste material would be contained. No cap would be
placed over the contaminated soils.
In addition to ground-water monitoring, maintenance of the site
would include site inspections, maintaining roads and fencing,
and removal of contaminated liquids that have accumulated in the
site consolidation area with transport to an off-site treatment
facility.
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TABLE I
CONSTRUCTION ACTIVITIES
CONSTRUCTION ACTIVITIES
ALTERNATIVE *
Access Road Construction
Fencing
Waste Excavation
Other Excavation
Backfilling
Ground Water/Surface Water
Diversion
Waste Dewatering/
Stabilization
-Qn-Si^te -Disposal—
Capping
Off-Site Waste Transport
Ground water/Surface Water
Monitoring
Post-Closure Maintenance
X
X
B
XXX
XXX
X X
XXX
X X
X
reatment X
X
— f
X X
X X
X
X
X
X
X
X
X
* Alternative A =
Alternative B =
Alternative C =
Alternative D =
No Action/Site Security
Excavation and Site Consolidation
Containment Without Capping, and
Excavation of the Downstream Area
Containment Without Capping, and Hot
Spot Removal
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Although the ingestion and direct contact pathways of exposure
to contamination are temporarily controlled in this alternative,
contaminant sources still remain on-site and untreated.
Alternative C: CONTAINMENT WITHOUT CAPPING OF THE WESTERLY
WETLANDS, AND EXCAVATION OF THE DOWNSTREAM AREA
Containment Without Capping includes the construction of a
drainage system and sedimentation basin to control run-on and
run-off and reduce further migration of contaminants. In the
sedimentation basin, particulate matter would settle, thus
reducing the possibility of the spread of contamination. Silt
fences and other erosion-control devices would be installed
to further limit the run-off of particulate matter from the
Wetlands. This alternative also includes the construction of
a security fence to limit access to the site and an access
road for maintenance.
This alternative would also include excavation of the 5,600 cy
of contaminated sediments fr*om the Downstream Area. These
sediments would be disposed of off-site at an appropriately
permitted RCRA or TSCA facility.
In addition to ground water monitoring, maintenance would
include maintaining the drainage system and periodically
dredging the basin to remove silt for solidification, off-site
transportation, and disposal.
Although this alternative would reduce the threat of direct
contact and ingestion pathways from on-site contamination, the
contaminant sources would still remain on-site and untreated.
Alternative D; CONTAINMENT WITHOUT CAPPING, AND HOT SPOT
REMOVAL
This alternative consists of isolating the contaminated Wet-
lands Area with a diversion dike and a drainage ditch. The
remedy also includes a perimeter security fence and an access
road. In addition, soils having PCB concentrations in excess
of 100 ppm (hot spots) would be excavated and removed to an
off-site permitted facility.
Approximately 18,500 cy of PCB contaminated soils above 100 ppm
would be excavated and disposed of off-site. Afterwards, the
area would be backfilled and regraded to control erosion. Con-
taminated run-off from the excavations and from the containment
area would.be diverted to a sedimentation basin located down-- ••—'•-••
stream of the containment area. Run-off ditches would divert •--'-
run-off flows from outside the containment area. A lined storage
area would be located in the Uplands Area as a staging and stabili-
zation area where the excavated Wetlands sands and organic soils
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-16-
can be mixed, dewatered, treated with stabilization additives,
and temporarily stored before being transported off-site for
disposal.
A long-term program to monitor ground water will be instituted.
Silt fences, erosion-control dikes, and ditches will receive
appropriate maintenance. The sedimentation basin will be periodi-
cally dredged and the accumulated material removed for solidifi-
cation and off-site disposal.
This alternative would still leave most of the contaminated mate-
rial on-site and untreated even though direct contact and inges-
tion pathways would be eliminated.
COMPARATIVE ANALYSIS OF ALTERNATIVES
All four alternatives will be analyzed in terms of the nine
evaluation criteria:
(1) overall protection of human health and the environment
(2) compliance with applicable or relevant and appropriate
requirements (ARARs)
(3) long-term effectiveness and permanence
(4) reduction of toxicity, mobility, or volume
(5) short-term effectiveness
(6) implementability
(7) cost
(8) community acceptance
(9) state acceptance
Compliance with ARARs
This section defines what Federal and State environmental and
human health requirements are applicable or relevant and
appropriate for the remedial alternatives associated with this
operable unit for the Burnt Fly Bog site. In addition, this
section will define other Federal and State criteria, advisories,
guidance and standards considered in evaluating the remedial
alternatives for the site.
ARARs and other requirements can be divided into chemical-,
action-, and location-specific requirements. While there are no
chemical-specific ARARs for the actions discussed in this ROD,
there are chemical-specific soil cleanup criteria developed by
the NJDEP. These soil cleanup criteria have been accepted as
the action levels for the Westerly Wetlands contamination. The
action levels for the contaminants of concern in soil are
250 ppm for lead and 5 ppm for PCBs.
Action-specific ARARs include requirements for treatment, storage,
and transportation of materials under the Resource Conservation
and Recovery Act and the Toxic Substances Control Act.
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-17-
Since the site is a wetland and is within a floodplain, other
location-specific considerations include Executive Order 11990
(Protection of Wetlands) and Executive Order 11988 (Floodplain
Management).
Alternative A; NO ACTION/SITE SECURITY
The perimeter fence to be installed as part of the No Action
alternative would restrict access to the site, thereby reducing
the potential for human contact with and ingestion of the on-site
contaminants. Safety concerns, mainly involving the potential
for short-term worker safety effects during fence installation,
can be mitigated by the use of protective equipment and air
monitoring. There would be insignificant effects on neighboring
communities.
Although this alternative reduces public access to the site and
is somewhat protective of public health, it does not destroy or
reduce the inherent hazards posed by the contaminants found at
the site. There is no reduction in the toxicity, mobility, or
volume of contaminants, and the contaminants will continue to
migrate off-site.
The long-term effectiveness of this alternative in reducing the
human health risks would remain unchanged.
The No Action alternative is technically feasible since activi-
ties are limited to fence construction, and monitoring well
installation and surveillance. Costs for this alternative
are estimated to be $500,000 for construction costs and
$50,000 per year for maintenance. Since additional studies
will be performed, the present worth analysis was performed
using three-year life (assuming further action will occur in
that time) and using twenty-year life (assuming no further
action will take place). The present worth for the No Action
alternative would be $636,000 and $1.1 million, respectively.
The No Action Alternative is not acceptable to the State of New
Jersey nor to the local community, especially since Perth Amboy
utilizes Deep Run as a potable water source.
Alternative B; EXCAVATION AND SITE CONSOLIDATION
Site consolidation operations would consist of the excavation
of contaminated soils from a portion of the Wetlands and place-
ment of these soils on the remaining Wetlands to reduce the
total area of contamination. In effect, approximately one-
half of the Wetlands Area would be remediated by excavation
and the remaining area by containment without capping.
This alternative is being considered as a final remedy for the
excavated portion of the site and an interim remedy for the
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-18-
remainder. The excavation of the contaminated soils from a
portion of the Wetlands would permanently remove the human
health and environmental risks from that area.
The interim remedy will provide public health and environmental
protection while permanent treatment alternatives are being
evaluated further.
Off-site migration of particulate matter would be reduced by
silt fences and construction of the sedimentation basin for
the consolidated area. Fences surrounding the consolidated
area would protect the public from risks associated with
contact with contaminated soil. During unusual storm events,
some contamination may continue to migrate off-site in the
form of dissolved and suspended material in the surface and
ground waters.
In the area where there is no excavation, there are no ARARs
to be considered. The area being excavated would be cleaned up
to the appropriate soil cleanup criteria. Since the excavated
material is being consolidated, there is no placement occurring.
Therefore, land disposal restrictions are not applicable or
relevant and appropriate.
Since this is an interim remedy, the consolidation is not
intended to provide treatment or long-term effectiveness and
permanence .
Short-term, adverse impacts may occur during excavation due
to physical transport of contaminants during and after storm
events. However, as appropriate, run-off control measures can
be installed to mitigate these impacts . -Dust.. emissions
excavation and transportation activities are expected to be
minimal due to the wet nature of the soils. After excavation,
erosion of the backfill soils will be controlled with wetland
vegetative plantings and seeding.
Costs for this alternative are estimated to be $6,270,000 for
construction and $270,000 per year for operation and maintenance.
Similar to the No Action alternative, the present worth analysis
was performed using three-year and twenty-year life. The present
worth costs for this alternative are $7 million and $9.6 million,
respectively.
Alternative C; CONTAINMENT WITHOUT CAPPING OF THE WESTERLY
WETLANDS, AND EXCAVATION OF THE DOWNSTREAM AREA
Containment Without Capping would consist of controlling run-
on and run-off of surface water through a drainage system and
a sedimentation basin. These control systems would limit the
migration of contaminants off-site. However, dissolved and
suspended contaminants passing through the sedimentation basin
would continue to migrate off-site. Site access would be
limited by the construction of a security fence around the site.
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-19-
In addition, approximately 5,600 cy of contaminated sediments
would be excavated from the Downstream Area. The excavated
sediments would be transported for off-site disposal with
the contaminated soils currently being excavated in the
Uplands Area.
Similar to Alternative B, Excavation and Site Consolidation,
this alternative is being considered as an interim remedy for
the Westerly Wetlands to provide human health and environmental
protection while permanent treatment alternatives are being
evaluated further.
The soil and blueberry ingestion pathways of exposure would be
reduced by installing a fence to control site access. This
remedy provides adequate short-term protectiveness. Controlling
contaminant migration through the use of a drainage system and
sedimentation basin also affords protection to the environment.
It should be noted that while the threat posed through the
surface and ground water pathways of exposure is reduced, it
still remains a concern.
Since the Containment Without Capping of the Westerly Wetlands
is being considered an interim remedy to provide short-term
control of the materials, there are no ARARs to be considered.
In addition, this interim remedy is not intended to provide
treatment or long-term effectiveness and permanence.
The construction of the sedimentation basin and drainage system
may temporarily increase the potential for contaminated surface
water run-off. However, erosion control measures would be
installed to reduce this potential.
Containment Without Capping would involve standard methods
of excavation for the drainage system and construction of the
sedimentation basin.
The sediments in the Downstream Area will be excavated to the
soil cleanup criteria agreed to by the EPA and NJDEP, 5 ppm
for PCBs and 250 ppm for lead. These sediments would be
transported off-site and disposed of in a RCRA-Subtitle C
facility.
Currently, over 80,000 tons of contaminated soil are being
excavated and transported off-site for disposal at appropri-
ately permitted facilities (RCRA or TSCA), depending on their
concentration of PCBs. The Uplands Area is the source of the
contamination in the Westerly Wetlands and the Downstream Area.
It is expected that the existing construction contracts for
the Uplands Area will be available and it would be expeditious
to add the excavation and off-site disposal of the sediments
from the Downstream Area to this contract.
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-20-
None of the contaminated materials at the Burnt Fly Bog site
are considered RCRA listed or characteristic wastes. Therefore,
the RCRA land disposal restrictions are not applicable and the
material can be disposed of off-site without treatment. The
highest concentration of PCBs found in the Downstream Area was
8.4 ppm. Treatment to reduce the PCB concentration even lower
would be impractical.
Should the existing excavation and off-site disposal contracts
not be available to handle the Downstream Area sediments, these
sediments would be excavated and consolidated with the Contami-
nated Soils Area in the Uplands Area. The consolidated
materials would then be evaluated for further remedial action
under the next operable unit after the treatability studies
are performed.
Short-term effectiveness in protecting public health and the
environment is related to protecting nearby residents and site
workers during the excavation of the sediments. Appropriate
health and safety procedures, equipment, and air monitoring
would be implemented during construction.
The costs for this alternative are estimated to be $2,210,000
for construction and $320,000 per year for operation and main-
tenance. The total present worth costs for this alternative
are $3.0 million for three-year life and $6.1 million for
twenty-year life.
Alternative D; CONTAINMENT WITHOUT CAPPING, AND HOT SPOT
REMOVAL
_This__alternative consists of—isolating the contaminated Wet
lands with diversion ditches, dikes and a sedimentation basin
and the excavation and off-site disposal of soils with a PCB
concentration greater than 100 ppm.
This alternative would be a final remedial action for the
material excavated and disposed of off-site and interim for
the material in the containment system. While this alterna-
tive would be effective and permanent for the areas excavated,
there would be no reduction in toxicity, mobility, or volume
of the excavated soil, such that the contaminants retain
their inherent hazardous characteristics.
The evaluation of this alternative leads to the same conclu-
sions as Alternative C, with the following exceptions.
Excavation of the soils with PCB concentrations over 100 ppm
would increase the protectiveness, long-term effectiveness,
and permanence of the remedy. However, there are more soils
being excavated with higher concentrations of PCBs than in
Alternative C. PCBs have been found in concentrations up to
232 ppm, which is technically practicable to treat.
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-21-
The estimated costs for this alternative are $17,160,000 for
construction and $320,000 per year for operation and maintenance.
Again, using three- and twenty-year life estimates, the total
present worth costs are estimated at $18 million and $21.2
million, respectively.
THE SELECTED REMEDY
The selected remedy is Containment Without Capping of the
Westerly Wetlands as an interim remedy and excavation and
off-site disposal of the Downstream Area as a final remedy.
Treatability studies will be performed on the most promising
innovative technology alternatives (On-site Incineration,
B.E.S.T., KPEG, and Bio-Clean). These treatability studies
will be carried out in a search for a suitable treatment-based
remedial action for the Westerly Wetlands soils, the Northerly
Wetlands soils and the Contaminated Soils Area. After the
studies are completed, the results will be evaluated and a
determination will be made as to the preferred remedy. When a
preferred remedy is identified, a public meeting will be held
to present the results of the study and the proposed action.
Subsequently, the selected remedy will be documented in a third
Record of Decision for the Burnt Fly Bog site.
Treatability testing of several alternatives could taJce over a
year to complete and evaluate. EPA and NJDEP believe that the
risks associated with the existing site conditions warrant an
interim remedy for the Westerly Wetlands to reduce these risks
while the treatability studies are being performed. In addition,
the threat posed by the Downstream Area sediments warrants their
removal and disposal. These risks include contact with on-site
contaminated soils and the continued off-site migration of
contaminants. The off-site migration is threatening to contaminate
a potable water source downstream of the site. The selected
remedy would provide sufficient human health and environmental
protection for the interim period.
The No Action alternative, which includes site security, would
not address the risks associated with this site and contamination
will continue to migrate off-site.
The remaining alternatives, Excavation and Site Consolidation,
and Containment Without Capping, and Hot Spot Removal, may not
be consistent with the final remedial action and are not consid-
ered cost-effective for an interim remedy. Excavation and Site
Consolidation does not add further protectiveness than the
selected remedy. In addition, consolidation of excavated
material would not likely be needed to implement any future
remedy.
While Containment Without Capping, and Hot Spot Removal may be
more protective than the selected remedy since high concentra-
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-22-
tions of PCB-contaminated soil would be removed from the site,
the increased protectiveness is not significant enough to
justify this remedy over the selected interim portion of the
remedy. In addition, the excavated material would have PCBs in
concentrations up to 232 ppm. Unlike the material being exca-
vated from the Downstream Area under the selected alternative
which has low concentrations of PCBs (8.4 ppm), treatment of
these soils to reduce the level of PCBs is potentially effective
and needs to be investigated under the next operable unit.
Containment Without Capping, the selected remedy for the Westerly
Wetlands, will include the installation of an appropriate drain-
age system and sedimentation basin. In the sedimentation basin,
particulate matter would be allowed to settle, thus reducing the
possibility of the spread of contamination. This alternative
also includes the construction of a security fence and access
road. This alternative will prevent further off-site migration
of the lead contamination which is threatening to enter Deep Run,
and it will eliminate the direct contact pathway of exposure.
The selected remedy also includes the excavation of approximately
5,600 cy of sediment contaminated with PCBs and lead which has
migrated into the Downstream Area. These sediments would be
disposed of at an appropriate permitted, off-site hazardous
waste facility.
The decision for off-site disposal for the excavated contaminated
sediments has been made with the expectation that the existing
construction contracts for the Uplands Area can also be utilized
for the disposal of this material.
It has been determined that the contamination found in the
Downstream Area, while significant enough to pose a threat in
the stream, is of a sufficiently low concentration that treat-
ment is not warranted. PCBs have been found in this area at
8.4 ppm. At this level, containment in a RCRA- or TSCA-permitted
facility would be protective, and treatment would be technically
difficult and unwarranted. It was determined that treatment of
the contaminated sediments is not warranted prior to off-site
disposal because the waste concentrations are sufficiently low
in terms of a direct contact threat and would not pose a ground
water threat due to the low mobility of both these contaminants.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The containment of the Westerly Wetlands will reduce the risks
posed by the continued migration of contaminants from the
Wetlands. The excavation of the contaminated sediments in the
Downstream Area will remove the risk of contamination to Deep
Run, which is a drinking water source for Perth Amboy. There
are no unacceptable short-term risks or cross-media impacts which
will be caused by implementation of this remedy.
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-23-
ARARS
The excavation of the Downstream Area will be done in conformance
with the soil cleanup criteria agreed to by EPA and NJDEP, 5 ppm
for PCBs and 250 ppm for lead. The selected remedy attains all
applicable or relevant and appropriate requirements. Contaminated
materials are not RCRA listed wastes and are not expected to be
RCRA characteristic.
Cost Effectiveness
The selected remedy provides overall effectiveness proportionate to
its cost such that it represents a reasonable value for the money.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
The interim solution for the Westerly Wetlands was determined
to be the most appropriate solution for the site. It will
reduce the existing risks to human health and the environment,
while treatability studies are being performed to determine the
the most appropriate final remedy for the Westerly Wetlands.
The excavation and off-site disposal of the Downstream Area
sediments is considered the most appropriate remedy for that
portion of the site. The contaminants are found at concentrations
which do not warrant treatment prior to off-site disposal.
•»
For the Westerly Wetlands soils, treatment will be considered
under the next operable unit study and is not within the limited
scope of the selected remedial action.
Both the community and the state support the need for rapid
action at this site and support the selected remedy.
Preference for Treatment as a Principal Element
The principal threats of the site involve the continual migration
of contaminants into the Deep Run and the potential for direct
contact at the site. This interim action will address these
principal threats on a short-term basis, while treatability
studies are being performed to determine the appropriate final
remedy for the Westerly wetlands.
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BURNT FLY BOG SUPERFUND SITE
TEXAS AND SPRING VALLEY ROADS
MARLBORO TOWNSHIP
MONMOUTH COUNTY
NEW JERSEY
RESPONSIVENESS SUMMARY
FOR
WESTERLY WETLANDS
FEASIBILITY STUDY
MAY 1988
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This Community Relation* Responsiveness Summary, prepared aa part of the
Racord of Daciaion (ROD) document* la dividad into tha following aaetiona:
*
I* Background on Community Involvement and Concarna
Thia la • briaf hiatory of community intaraat in tha Burnt Fly Bog aita
and a chronology of community ralatlona activitlaa conductad by tha Nav
Jaraey Department of Environmental Protaction (NJDEP) prior to and
during tha Remedial Investigation/Feasibility Study (RI/FS) at tha
Westerly Wetlands portion of tha aita.
II. Summary of Major Questions and Comments Received during the Public
Comment Period and NJDEP*s Responses
This la a summary of major questions and comments directed to NJDEP
during the March 29. 1988 public meeting regarding the results of the
S
Feasibility Study and sent to NJDEP during the public comment period.
NJDEP1s responses are included in this sections
III. Remaining Concerns
Discussion of remaining community concerns of which NJDEP and USEPA
should be aware in conducting the remedial design and remedial actions
at the Westerly Wetlands portion of the Burnt Fly Bog site.
Attachments
A. Agenda and Fact Sheets distributed at the 3/Z9/88 Public Meeting.
B. Liat of Speakers at tha 3/29/88 Public Meeting.
C. Letters sent to NJDEP during the public comment period.
-------
D. Proposed Renedial Action Plan.
-------
I. Background on Community Involvement and Concerns
Burnt Fly Bog has consistently rscsivsd personal attention from
residents, the media, snd municipal, county* state and federal
•
officials. In 1981, concerned residents organized the Burnt Fly Bog
Citizens Advisory Committee (BFBCAC). The Committee originally
included representatives from Marlboro and Old Bridge Townships;
however, it is now comprised of Marlboro residents and officials and
Monmouth County officials. The BFBCAC was formed before the
establishment of the Community Relations Program within the NJDEP's
Hazardous Site Mitigation Administration. The Committee functions as
the liaison between the NJDEP and the local community.
*•
Since the establishment of the NJDEP's Community Relations Program in
1982 (within the Hazardous Site Mitigation Administration) to address
Superfund public participation requirements, representatives of NJDEP
have been meeting with the BFBCAC approximately four times per year.
._*§tjb _g«ports,jnd_evifttj are shared with the BFBCAC
so that NJDEP can incorporate their input into decision-making
concerning site activities.
Community concerns have focused on potential environmental and public
health risks posed by the site. In particular, the Ingest ion of
contaminated ground water or surface water has been an issue because of
the high concentrations of lead on site. The NJDEP routinely tests
area potable wells to monitor water quality for these residents.
Moreover, residents and officials of Old Bridge, Perth Amboy and
Matavan have expressed concern about contaminant migration to Deep Run
-------
which receive* drainage from the Westerly Wetlands and serves or will
serve as a water supply for these areas.
m _
Another recurring concern regarding the remediation of Burnt Fly Bog is
that the site does not becossa the dunping ground for other hazardous
waste site cleanups in New Jersey. Residents are especially sensitive
to this issue in light of the potential utilisation of on-site
incineration to mitigate some of the waste. However. NJDEP has
reassured the community that if incineration is used* jit will be a
mobile, rather than* a permanent unit.
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Chronology of Community Halations Activities
. *
June 20. 1984 - Public Meeting to discuss initial surface removal and
design for long-tern site remediation.
June 20, 1984 - Burnt Fly Bog Citizens Advisory Committee Meeting
(BFBCAC)
September 19* 1984- BFBCAC Meeting - discussion of asphalt pile disposal and
grant funding amendment to USEPA for $11.3 million.
January 16, 1985 - BFBCAC Meeting - discussion of further contamination
found on site.
April 9, 1985 - BFBCAC Meeting - sampling update for the Westerly
Wetlands; preliminary disposal costs for Uplands removal.
June 3, 1985 - BFBCAC Meeting - discussion of disposal contract;
update on contlnuetion of on-site work.
S
July 15, 1985 - BFBCAC Meeting - update on Uplands.
October 2, 1985 - BFBCAC Meeting - status of Westerly Wetlands;
additional sampling to take place.
November 12, 1985- BFBCAC Meeting - discussion of Health & Safety issues.
January 14, 1986 - BFBCAC Meeting - update on removal of drummed wastes
and asphalt pile.
May 22, 1986 - BFBCAC Meeting - details of bid package; Uplands
design; Westerly Wetlands Focused Feasibility Study;
residential veil sampling.
October 7, 1986 - BFBCAC Meeting - discussion of delays in procurement
«.
process; status of drummed vactee at the Westerly
Wetlands.
-------
May 6, 1987 - BFBCAC Meeting - Westerly Wetlands Supplemental
Remedial Investigation; funding; Uplands Invitation for
*
Bid; disposal contracts.
October 1, 1987 - BFBCAC Meeting - discussion of Imperial Oil - Phase I
RI results; Burnt Fly Bog - status of Uplands contract
award and results of Westerly Wetlands RI.
March 29, 1988 - BFBCAC Meeting and Public Meeting to discuss results of
Westerly Wetlands Feasibility Study and construction
activities at the Uplands.
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8
II. Summary ef Major Questions and Comment* Received During the Public
Comment P«riod and NJDEP*s Responses
On March 24, 1988, the Feasibility Study and the Proposed Remedial
*
Action Plan (PRAP) for the Westerly Wetlands vas placed in the
following repositories: Monmouth County Library, 1 Library Court;
Marlboro Township Municipal Building, 1979 Township Drive; NJDEP, 401
E. State Street, Trenton; and USEPA, 26 Federal Plaza, New York, NT.
NJDEP issued press releases and contacted municipal, county and state
officials and the Burnt Fly Bog Citizens Advisory Committee regarding
the PRAP and the availability of the Feasibility Study and the PRAP at
the repositories. Additionally, the PRAP was mailed directly to these
officials and members of the Burnt Fly Bog Citizens Advisory Committee.
On March 29, 1988, NJDEP held a public meeting to present the results
of and receive comments/questions, regarding the Feasibility Study for
the Westerly Wetlands as well as the ongoing construction activities at
the Uplands. (See Attachment A: agenda-and *act ^heet-diatributed-at-
the meeting.) The meeting was held at the Marlboro Township Municipal
Building, 1979 Township Drive in Marlboro.
Notification of the public meeting was accomplished through press
releases and direct mailing of notices to municipal, county, state and
federal officials and concerned citizens. The Burnt Fly Bog Citizens
Advisory Committee also notified citizens through their newsletter.
Approximately 40 people attended the meeting and seven people commented
during the meeting. Responses to comments and questions, for the most
part, were stated at the public meeting. The public comment period was
-------
held from March 29 through April 29, 1988. la addition to the comments
nad* during the public netting only one letter was received by the
Department during this period.
•
After Introductory remark* by Director Farro and an overview of the
project status and history by Mr. David Henderson of NJDEP, Ms. Sheila
Blscoblng, Project Manager for Ebasco Services. Inc.* gave a
presentation of the 14 remedial action alternatives that were
considered in the Feasibility Study. These are:
Conventional Technologies
— No Action;
— Total in-situ encapsulation;
~ Excavation and total encapsulation on-site;
— Excavation and site consolidation;
— Total excavation and off-site disposal;
— Non-encapsulation containment; —
— Non-encapsulation containment and hot spot removal,
Innovative Treatment Technologies
— In-situ vitrification;
— Incineration;
•
— Basic extraction sludge treatment (BEST) process;
— Potassium polyethylene glycol (KPEG) process;
— Fixation/solidification (cement/silicate-based
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10
solidification);
— Fixation/solidification (cement-based solidification);
~ Bio-Clean.
«>
Mr. David Henderson* Section Chief. Bureau of Site Management* HJDEP then
discussed the preferred remedial alternative as developed by HJDEP and the
United States Environmental Protection Agency (USEPA). After his
presentation* the meeting was opened for questions and comments.
The preferred alternative entails a non-encapsulation containment action as
an interim solution to the contamination problem at the Westerly Wetlands
portion of the site. This interim action would include the installation of
a fence and access road around the Westerly Wetlands and the installation of
a sediment collection basin at the outflow of the Wetlands to prevent
contamination from being transported downstream. Approximately 5*800 tons
'>
of sediment contaminated with polychlorinated biphenyls (PCBs) and lead
which has _moved off..site .into_a downstream area will—be—excavated.
Restoration and revegetation of the sediment collection basin and
restoration of the excavated downstream area will be performed as part of
the action.
Concurrently* treatabillty studies for four of the most promising innovative
technology alternatives listed in the PRAP (on-site incineration, B.E.S.T.*
KPEG, and Bio-Clean) will be carried out in a search for a suitable
permanent remedial action for the Westerly Wetlands soils. Once the studies
are completed and the results are evaluated, a permanent remedy will be
proposed for the Westerly Wetlands. A second Record of Decision will be
-------
11
developed by NJDEP and EPA with Input from the public during another meeting
and public comnent period.
Following ia a aummary, organized by aubject. of all major questions and
coomenta received by NJDEP at the public meeting and during the public
comment period. Major aubjecta include:
— Preferred Alternative;
—- Innovative Technologies;
— Incineration Option;
— Sedimentation Pond Considerations;
— Adjacent Land Use;
— Costa associated with Burnt Fly Bog and the Superfund
Program;
— Local Roadways;
*<
— Future Use of Site; and
— Other Contaminants.
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Preferred Alternative
*
*
Comments: This alternative, as described, would be a temporary holding
solution. Alternatives B and C would be sore immediate.
Response: The selected alternative, consisting of non-encapsulation
containment, installation of a sediment collection basin, and
excavation of the downstream area, will be a necessary part of any
permanent remedial alternative chosen for the Westerly Wetlands.
Alternatives B (Total In-Situ Encapsulation,) and C (Excavation &
Total Encapsulation On-Site) would result in the destruction of
the wetlands area which is undersirable. Permanent treatment for
the site is favored under the mandates of the Superfund Amendments
and Reauthorization Act of 1986 (SARA). Neither Alternative B or
C would be considered permanent.
Innovative Technologies
Comment: Since innovative technologies are very expensive and are currently
undergoing extensive, time consuming treatment studies, NJDEP
should concentrate on the less expensive conventional, proven
technologies.
Response: As stated in the previous response, NJDEP is mandated under SARA
to look at permanent solutions to site problems. This requires
conducting treatablllty studies for four of the most promising
innovative technology alternatives in a search for a suitable
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permanent remedial action for Cha Vaatarly Vatlanda aoila. Tha
innovative technologiea being eonaidarad will., enable NJDEP to
remove contamination from the wetlands* ravegatata the area* and
• •
raatore and maintain the area aa a natural raaourca.
Question: la Burnt Fly Bog being uaed aa a proving ground for other
Superfund aitaa?
Response: Innovative technologies have been shown to work in various
applications* such aa In field and laboratory studies and in
vnd
various mediums* however none have been proven to vork^ the
Ccndi -+icn±
specific^ at Burnt Fly Bog. The Westerly Vetlanda present a unique
acanario where PCBs and lead are together in a wetlands
•/jreAfA^Vi'/y 5yt/
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Response: Chemical fixation vai considered by HJDEP during the Feasibility
Study process* however» this type of technology was eliminated
from the list of four preferred pilot studies due to the nature
*
and uncertainty of the area's hydrology and the disruption that
this technology could cause.
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Incineration Option
•
Comment: Concern vas expressed ov«r the possibility that any incinerator
•.
used on-slte would become a permanent facility for uaa by other
townships or counties. If the incineration alternative is chosen,
several residents said they would be in favor of an on-site nobile
facility which could be removed after its use* at Burnt Fly Bog.
Response: If incineration is selected as a permanent remedy at Burnt Fly
Bog* NJDEP would anticipate using a temporary, mobile unit on
trailers for incineration of Burnt Fly Bog waste only.
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Sedimentation Pond Considerations
Question: What effects, if any, would the sedimentation pond have on the
area's wildlife if they were to drink this water? Furthermore,
what are the potential health effects if insects or wildlife make
human contact after being exposed to the sedimentation pond?
Response: The Remedial Investigation for the Westerly Wetlands indicated
that the majority of contamination is attached to the soils and
sediments that move along the bottom of the stream. Animal
exposure would be minimal, and any secondary exposure to humans
*
would be even less.
Adjacent Land Use
"»
Question: Can NJDEP restrict or limit development on the land that is for
sale adjacent to Burnt Fly Bog? Development of adjacent
properties should be subject to NJDEP approval.
Response: NJDEP is available to advise potential property buyers of
hazardous waste sites near a property through the Land Information
Program, however, this service is advisory only. Currently, there
is no regulatory or other mechanism which allows the state to
become involved with local land use decisions related to hazardous
waste sites.
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Costs Associated with Burnt Fly Bog and the Superfund Program
Question: Docs the cost of each technology have any bearing on which one
•
is chosen?
Response: The DSEPA along vith HJDEP are required to select the remedial
alternative gemee'tel- which is best suited to the contamination
problems at Burnt Fly Bog, and provides protection of public
health and the environment in the most cost-effective manner.
Question: How much funding is needed in the long-term to clean up all of
New Jersey's Superfund sites?
Response: It is difficult to estimate the amount of funding needed to clean
up all of Hew Jersey's Superfund sites since each site is unique.
X
However, one estimate in 1987 was that $1.5 billion would be
»
needed to meet New Jersey's cleanup goals for the years 1988
through 1992.
Comment: Concern was expressed regarding the availability of adequate
funding to complete the Burnt Fly Bog cleanup.
Response: Since the Burnt Fly Bog site is so far along in the Superfund
process (construction at the Uplands and remedial alternative
selection at the Westerly Wetlands), we do not anticipate funding
problems for this site.
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Local Roadways
Question: If local roadways are damaged due to the heavy truck traffic
*
during site remediation, will the cost of replacement and/or
repair be covered under the Superfund program?
Response: This issue is currently being looked into by the department.
Although NJDEP cannot guarantee payment for road repair• we
believe that if damage occurs to local roadways as a result of our
cleanup effort, we would repair the roadway.
Future use of Site
Comment: Once the cleanup is completed, Burnt Fly Bog could be used as a
wildlife refuge or natural area.
'>
Response: Yes, this future use should be possible.
Other Contaminants
Question: What other contaminants were found at Burnt Fly Bog, aside from
PCB's and lead, and will the ultimate treatment technology address
these contaminants as well?
Response: The RI/FS determined that lead and PCBs are the most far reaching
V.
contaminants at Burnt Fly Bog. If we target the remediation of
lead, then we will also address the other metals found on site.
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Also, if we target PCBs, other organics vill in turn be addressed.
•
•
HI. Remaining Concerns
Although the local officials and residents are very confident about
the on£oing cleanup of Burnt Fly Bog, there are concerns regarding
the interim and the permanent remedy for the Westerly Wetlands. These
include the use of on-site incineration, the duration of the testing
of innovative technologies before a permanent remedy can be decided,
and adequrte federal and state funding to implement and complete the
site cleanup.
The results of the treatability studies for the Innovative technologies
vill be evaluated with respect to the following criteria:
%
— public health^ and public acceptanceJ
— environmental benefit;
— implenentablllty;
— treatment of sidestreaas produced during process;
— tlmeframe;
— cost; and
— restoration prospects for the Wetlands.
After the studies are completed, the results vill be evaluated and a
determination vill be made as to the preferred permanent remedy. At
this time another public meeting vill be held to present the results of
the studies and the proposed action. Subsequent to public comment,
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another Record of Decision will be developed by NJDEP and USEPA.
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