United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/096
September 1989
SERA
Superfund
Record of
Caldwell Trucking, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT Mtt
EPA/ROD/R02-89/096
X Recipient1* Acceeeton No.
1. Tin* wid Subtitle
SUPERFUND RECORD OF DECIUION
Caldwell Trucking, NJ
Second Remedial Action - Final
S. Report Date
09/28/89
7. Authors)
a. Performing Organization Rept No.
9. fltrtoimlng Organization Nam and Addreee
10. Pro|ecVTaak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nun* and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Typo of Report ft Pwiod Covered
800/000
14.
15. Supp4«nmiUry NolM
16. Abatract (Umlt: 200 word*)
The 11-acre Caldwell Trucking site is in Fairfield Township, Essex County, New Jersey.
The site is situated on an extensive 100-year floodplain of the Passaic River and
neighbors Deepavaal Brook and numerous wetlands, as well as residential and commercial
properties. From the 1950s to 1984 the Caldwell Trucking Company dumped, and allowed
others to dump, septic wastes into unlined lagoons and later into steel holding tanks at
the site. An EPA investigation conducted between 1984 and 1986 revealed that onsite
soil and a municipal well were contaminated with VOCs, PCBs, and metals. The
investigation resulted in a 1986 Record of Decision (ROD) which provided for soil
remediation, restoration of a municipal well, and residential hookups to municipal
water. Ground water, however, remains contaminated because of a TCE-contaminated plume
which extends 4,000 feet from the site towards the Passaic River. Additional sources of
the plume have been identified, including the neighboring General Hose facility which
will be addressed by other Federal and State authorities. A small seep to Deepavaal
Brook's tributary, which is recharged by ground water, is also contaminated with TCE.
This response is the second remedial action and addresses the remediation of
contaminated offsite ground water. The primary contaminants of concern affecting the
ground water are VOCs including TCE. (Continued on next page)
17. Documnt Analytic & Descriptor*
Record of Decision - Caldwell Trucking,
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (TCE)
b. ktontifiera/OpafvEndad Term*
NJ
e. COSAT1 Held/Group
18. AvaUabifty Statement
10. Security CUM (Thi» Report)
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49
22. Price
(Se* ANSI-Z39.18)
See butrucifofw on fl*wra»
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16. Abstract (Continued)
EPA/ROD/R02-89/096
Caldwell Trucking, NJ
The selected remedial action for this site includes pumping and treatment of offsite
ground water using air stripping with offsite discharge to the Passaic River;
installation of a drainage system to eliminate surface exposure to contaminated ground
water; sealing ground water wells; and ground water monitoring. The estimated present
worth cost for this remedial action is $11,540,000 which includes annual O&M costs of
$315,000 for 30 years. If, however, access to private properties and public roads needed
for implementation of this remedial action cannot be obtained, EPA and the State will
implement a contingency remedy which includes limited treatment of ground water,
remediation of surface water, and sealing ground water wells.
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DECLARATION STATEMENT
RECORD OF DBCIBIOH
CALDWELL TRUCXZMO COMPANY (07T-BITE AREAS)
Caldwell Trucking Company, Fairfield Township, Essex County,
New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Caldwell Trucking Company (off-site areas), chosen 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 Contingency Plan. This decision
is based on the administrative record on file for the site.
The State of New Jersey has concurred with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Remedy
The remedial action described in this document represents the
final of four planned operable units for the site and surrounding
area. The first three operable units, which were the subject of
a Record of Decision signed in September 1986, provided for
source remediation, restoration of a municipal well, and
residential hookups to municipal water. This final action will
address contaminated ground water in the underlying aquifer.
The major components of the selected remedy include:
Reduction in the Off—site Ground Water
A ground water pumping and treatment system will be
undertaken to reduce contaminant levels in the affected
aquifers, by implementing Alternative 3, or as a
contingency, Alternative 6. In recognition of public
concerns regarding Alternative 3, the Agency will work with
the community to further define the extent of ground water
cleanup and the number of wells employed.
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• Remediation of a Seep and Tributary to Deepaval Brook
An enclosed drainage system will be installed to eliminate
the health risk posed by surface exposure to contaminated
ground water if ground water pumping alone dqes not
remediate the problem.
• Protection of Municipal Wells
New monitoring wells will be installed near Municipal Well
Number 6 and Municipal Well Number 8 for long-term
monitoring purposes.
• Sealing of Wells in tfre. Plyje.
All wells impacted by contamination from the Caldwell
Trucking site will be sealed.
statutory Determinations
The selected remedy is protective of human health and the
environment, and is cost-effective. However, a waiver is
required from Federal and State standards for an aquifer
designated as a source of drinking water. The waiver is invoked .
on the basis of technical impractability, since it would take
more than one hundred years of pumping and treatment to attain
drinking water standards in the affected aquifers.
The remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduce toxicity, mobility, and/or volume as a principal element.
Because this remedy will result in hazardous substances remaining
in the ground water above health-based levels, a review will be
conducted within five years after commencement of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
William J.sJtaHfKi, P.E.
Acting Regional Administrator
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RECORD OF DECISION
DECI8ION SUMMARY
CALDWELL TRUCKING COMPANY (OFT-SITE AREAS)
SITE LOCATION AND DESCRIPTION
The Caldwell Trucking Company site is located in Fairfield
Township, Essex County, New Jersey. The site is an 11.25-acre
tract of land located in the eastern portion of the township,
between O'Connor Drive and Sherwood Lane, immediately east of
Passaic Avenue. Map coordinates for the site are latitude
40°53'23" north, longitude 74°16«16" west on the Pompton Plains
7.5-minute series quadrangle map. Fairfield Township itself is '
situated on an extensive floodplain of the Passaic River. The
floodplain is a low-lying area of little relief with numerous
swampy sections or wetlands which are gradually giving way to
residential and commercial construction. Maximum relief between '
the floodplain and the crests of major hills approaches 400 feet.'
Elevations within the study area range from 154 feet to 240 feet
above mean sea level (MSL). The 100-year flood elevation of the
Passaic River in this area is 171.5 feet above MSL.
Deepavaal Brook and the Passaic River are the major surface water
bodies within the study area. Deepavaal Brook flows to the
northeast and discharges to the Passaic River. Average measured
depths of Deepavaal Brook within the study area are approximately
3 feet and 6.5 feet under low-flow and high-flow conditions,
respectively. Average measured depths of the Passaic River at
mid-channel in the vicinity of the site are approximately 14 feet
and 19.5 feet during low-flow and high-flow conditions,
respectively. The average flow of the Passaic River is 1,160
cubic feet per second (cfs) at Little Falls, New Jersey, located
2 miles downstream of the study area.
Land usage within the Off-Site Remedial Investigation (RI) study
area is predominantly residential. The residential areas are
located in the northern portions of the study area which contains
approximately 150 dwellings and an estimated 450 residents. As a
result of the previous Record of Decision (ROD), all residences
located within the known plume area will be hooked up to
municipal water. Light industrial areas are concentrated mainly
to the southwest and northwest. Approximately 45 small
businesses are situated within a 1-mile radius of the Caldwell
Trucking Company site. The Essex County Airport property is
situated approximately 200 feet to the west of Passaic Avenue.
Several of the businesses in the study area have process water
supply wells.
The nearest community facility to the study area is the Essex
Regional High School, located approximately 200 feet east of
Caldwell Trucking Company. This school has approximately 1,800
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students, in grades 7 through 12. The areas served by the school
include Fairfield, Roseland, North Caldvell and Essex Fells. The
school is supplied water from the North Caldvell Water
Department, which uses wells located in Essex Fel^Ls. Essex Fells
is located approximately 3.5 miles south (upgradient) of the
Caldwell site.
The natural resources in the study area include the Passaic River
and the aquifers that supply ground water to municipal wells and
private/industrial wells. The Passaic River is used as a water
supply for communities downriver of the study area. The Passaic
Valley Water Commission has a water intake located on the Passaic
River, approximately 2.2 miles downstream of its confluence with
Deepavaal Brook. This water commission serves approximately
750,000 people. Similarly, there is a water intake about l mile
upstream of Deepavaal at the confluence of the Passaic and
Pompton Rivers.
Fairfield Township is located at the extreme northern edge of the
Buried Valley Aquifer System recharge zone. The recharge zone of
this aquifer system underlies the central basin of the Passaic
River in western Essex and southeastern Morris Counties. This
aquifer system is designated as a sole-source aquifer, a
designation which indicates that it is the sole or principal
source of drinking water in the area.
Numerous residential wells north of the study area are no longer
in use, and most of the residents now rely on municipal water.
However, two Fairfield Township municipal wells (Nos. 2 and 7),
south of the site, have been shut down since 1981 because of
contamination. These wells were relatively high-yielding and
provided a portion of the municipal water supply in Fairfield.
The sources of contamination impacting these municipal wells are
still under investigation.
Ground water within and in the vicinity of the study area has
been affected by numerous identified or potential sources of
contamination. Figure 1 illustrates the approximate locations of
four known contamination centers that impact the study area.
These include the Caldwell Trucking Company site (and the off-
site ground water plume under study), contamination in the
vicinity of Municipal Wells No. 2 and No. 7, and contamination
west of the study area (bounded by New Dutch Lane, Passaic Avenue
and Little Falls Road). There are approximately 130 properties
undergoing New Jersey Environmental Cleanup Responsibility Act
(ECRA) reviews in Caldwell and Fairfield Townships, and these
will likely pinpoint specific sources within these four
contamination centers.
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^^^v '*«• * r * r f* f i ^ i ^ ^9*~ Jt
CALOWELL TRUCKING CO. SITE1
SCALC IN MIT
BASE MAP ISA PORTION OF THE U.S.G.S. POMPTON PLAINS,NO QUAORANOL£(7.SMtt«JTE SERIES, l99S,PHOTQREVISEOSei)
AND A PORTION OF THE CALOWeUUNJ QUAORANOLE (75 MINUTE SERIES, 1954. PHOTOREVISEO 1961).
CONTOUR INTERVAL 20 SOURCE' EPA. 1989.
FIGURE 1
SELECTED MUNICIPAL WELLS AND CONTAMINANT CENTERS
FAIRRELD TOWNSHIP. NEW JERSEY
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There are no known endangered species or critical habitats
located within the study area. However, wetlands, as defined by
the U.S. Department of the Interior, are located In several
portions of the study area. A preliminary assessment of these
areas was performed by the EPA and is summarized in the Remedial
Investigation Report.
SITE HISTORY MTO EV7ORCEMZHT ACTIVITIES
In the early 1950's, Caldwell Trucking Company gradually acquired
several lots to the rear of 222 Passaic Avenue which it used to
deposit collected septic waste in unlined lagoons. During the
next 30 years, Fairfield evolved from a residential community to
one encompassing numerous commercial and industrial establish-
ments. Since many parts of Fairfield were not hooked up to
municipal sewers until the late 1970's, Caldwell Trucking hauled
and deposited septic waste from all three classes of customers at
its. facility. In addition, Caldwell Trucking allowed other
haulers to deposit their "septic" waste in the unlined lagoons on
its property. Around 1973, Caldwell Trucking switched to the use
of steel holding tanks and operated in that manner until 1984
when it discontinued use of the site for this purpose. In 1988,
the company ceased the remainder of its trucking operations and
went out of business.
Significant amounts of volatile organics were found to be in the
septic waste deposited at the site, which in turn were released
into the soil. The unlined lagoons became the primary source of
contamination in the soil at the site (the subject of an earlier
study), and in the ground water, which is the subject of the
current study and this document. There are others sources of
ground water contamination in the area, including the General
Hose property, which is a neighboring property to the Caldwell
site. In addition to the plume migrating from the Caldwell site,
there are at least three other contaminant centers, or plumes,
which ultimately overlap the Caldwell plume or pass west of it
moving toward the Passaic River. ,
The site was placed on the National Priorities List (NPL) in
December 1982. Between 1984 and 1986, EPA conducted the first
Remedial Investigation and Feasibility Study (RI/FS) for the
Caldwell Trucking site. The RI/FS was conducted to identify the
types, quantities, and locations of contaminants, and to develop
ways of addressing the contamination problems. The second or
Off-Site RI/FS was conducted between 1987 and the present (1989).
The results of the two RI/FSs are as follows:
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yirat RI/F8
•»
An estimated 28,000 cubic yards of surface and subsurface
soils were found to be contaminated with high levels of
volatile organics and much lover concentrations of heavier
organics, metals and some PCBs (polychlorinated biphenyls).
A pump test found no direct connection between Caldwell
Trucking and the contamination at Municipal Hell No. 7.
The test did show was that there were other potential
sources, and that there were two (2) separate plumes.
Based on the existing data on the downgradient plume, any
homes (private wells) in that area would be hooked up to a
municipal water supply.
Second (current) BI/T8
A plume of contaminated ground water extends from the site •
to the Passaic River, approximately 4,000 ft. away. The
plume is approximately 2,000 ft. wide and is found in both
the water table and bedrock aquifers.
Additional sources contributing to the plume were
identified, including the neighboring General Hose facility.
Additional plumes exist in close proximity to, and/or
overlapping, the plume originating from the Caldwell site.
After a public meeting and a 30-day public comment period (on the
first RI/FS), a Record of Decision was signed, on September 25,
1986, which selected remedial actions for the site itself,
Municipal Well No. 7, and affected or threatened private wells.
The 1986 ROD also required that a supplemental RI/FS be performed
to investigate the downgradient plume and other potential sources
of contamination.
The 1986 ROD called for the following:
- 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 Resource
Conservation and Recovery Act (RCRA) requirements.
- Restoration of a lost potable water resource by providing
treatment, via air stripping, of municipal public water
supply well No. 7.
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Provision of an alternate water supply f or^ 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.
The Caldwell Trucking site is the best known and most
concentrated "source1* of soil and ground water contamination in
the Fairfield area. The Caldwell Trucking site was the point of
deposition for a variety of waste generators. As previously
noted, there are at least four discernable contaminant centers,
and over 100 ECRA cases currently under review in Fairfield
Township .
In the course of the first RI/FS (1985-86) , Notice Letters were
sent out to Caldwell Trucking Company, as well as the current and
former owners of the neighboring property (General Hose) .
Caldwell provided a detailed response but denied any deliberate,
willful acts leading to the contamination of its property. The
other two parties disclaimed any involvement with Caldwell or any
accidental contamination on their own property. However, the
current Off-Site RI/FS revealed significant soil contamination on
General Hose's property which in turn would make them a
contributor to the ground water contamination. The data also
suggests there may be a third principal source to the "Caldwell
Plume", i.e., a neighboring property owned by Cobehn Inc., which
was a major user of chloroform and is now undergoing an ECRA
investigation.
As to the contaminant sources around Hunicipal Well No. 7, EPA
and the State believe there are several Potentially Responsible
Parties (PRPs) contributing to that plume, the most prominent
being Cooper Industries. The facility in question was an old
electric motor repair plant located in West Caldwell. EPA has
been pursuing a voluntary settlement with Cooper for three years,
but now Cooper Industries disclaims any connection with Well No.
7. Considerably less is known about the two remaining
contaminant areas (one near Well No. 2, and the other north of
the airport) . Here, the State will provide the enforcement lead
through its ECRA investigations.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Off-Site RI/FS Report and Proposed Plan related to the
Caldvell Trucking Company site were released to tile public for
comment on August 2 and 16, 1989, respectively. These documents
were made available to the public in both the administrative
record and an information repository maintained at the EPA Docket
Room in Region II as well as three outside repositories as
follows:
Town Clerk's Office
230 Fairfield Road
Fairfield, New Jersey 07006
(201) 882-2700
Anthony Pio Costa Memorial Library
261 Hollywood Avenue
Fairfield, New Jersey 07006
(201) 227-3575
New Jersey Department of Environmental Protection
Metro Bureau and Regional Enforcement
2 Babcock Place
West Orange, New Jersey 07052
(201) 669-3900
The notice of availability for these documents was published in
several newspapers, namely, THE NEWARK STAR LEDGER, THE PROGRESS,
DAILY RECORD, and SUBURBAN LIFE in the week preceding the public
meeting. A public comment period on the documents took place
from August 16 to September 15. In addition, a public meeting
was held on August 30, 1989. At this meeting, representatives
from the EPA presented the results of the Off-Site RI/FS and the
recommendation in the Proposed Plan, and later answered questions
about problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is part
of this ROD.
SCOPE AND ROLE OF FAST AND FUTUKB RESPONSE ACTION
The problems at the Caldwell Trucking site are complex. As a
result, EPA has divided the work into four phases or operable
units (OUs). These are as follows:
OU One: Contaminated or threatened private potable wells.
OU Two: Contamination in Municipal Well No. 7.
OU Three: Contamination in the soils at the site.
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8
OU Four: Contamination in the ground water dovngradient
from the site.
EPA has already selected cleanup remedies for OUs, One, Two, and
Three. OU Two and Three are in the remedial design stage, which
means that engineering consultants are developing specific plans
for implementation of the remedy. Municipal Well No. 7, which is
contaminated, is not in use and is therefore not a direct public
health threat at this time. OU One is underway and will
essentially be completed by the end of September (1989). OU one
involves connecting potentially impacted homes to municipal
water, thus eliminating the only immediate public health risk.
OU Two, the construction of wellhead treatment at Municipal Well
No. 7, is scheduled for the early summer of 1990, and OU Three,
remediation of the site, is projected for the late fall of 1990.>
OU Four, the subject of this document, deals almost exclusively
with off-site ground water contamination. While the primary
objective was to study the plume extending from the site and its!
impact on the Passaic River, another objective included the
investigation of the subsurface soils at General Hose Products,
Inc., the adjacent property owner.
The investigation of the General Hose property indicated there
were about 5,000 cubic yards of contaminated subsurface soils on
the property which should be remediated. The remediation of this
contamination is not being addressed under this Record of
Decision, but will be pursued independently through appropriate
Federal or State statutes.
SUMMARY OF SITE CHARACTERISTICS
Although the first RI/FS proposed affirmative remedial actions to
clean up the site, provide an alternate water supply to
properties with contaminated or threatened drinking water, and
restore a public well to service - the data was deemed
insufficient to characterize the downgradient plume and to
determine its impact on the Passaic River. These issues were the
basis of the present off-site study.
To characterize the plume, 12 ground water modelling points were
selected, and a total of 34 wells were installed. The elevations
selected were normally at the top and bottom of the water table
aquifer (defined as Zones A and B), and two elevations of the
bedrock aquifer (defined as Zones C and D). See Figure 2. The
ground water sampling results from these points were entered into
a computer model which produced the following results:
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C ZONE (BASALT BEDROCK)
D ZONE (BEDROCK)
0-ZO'
30-60'
60—350
1-350-370'
FIGURE 2
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10
The ground water is contaminated with volatile organics,
mainly trichloroethylene (TCE), from the top of the water
table (A Zone) down into the bedrock as deep as 370 feet (D
Zone). The horizontal area of contamination is about 4,000
feet long, from the site to the Passaic River, and about
2,000 feet wide, from Carlos Drive on the east to Passaic
Avenue on the west.
Based on the computer modeling, it is believed that the
Passaic River is only minimally impacted by the plume at the
present time, and the model projects further improvement
after site remediation. At normal flow conditions, there
does not appear to be a threat, even at present, to the use >
of the river as a source of drinking water. (River intakes
are located one mile upstream and two miles downstream of
the site.)
The computer model was also used to construct
isoconcentration lines for each of the four zones, and
predict changes over time. For example, Figure 3 shows
present day contaminant levels for Zone B, which range from'
500 to 10,000 ppb.
As noted previously, there are other contaminant centers, or
plumes, which are in close proximity to, or overlap the plume
emanating from the Caldwell site. The present day impact of
these plumes is included in the model. However, cleanup
projections derived from the model for the Caldwell Trucking/
General Hose plume do not reflect the impact of additional
contamination coming from other sources.
A small seep to the tributary of Deepavaal Brook, recharged by
the ground water, was discovered and found to be contaminated
with TCE in the range of 5 parts per million (ppm). The
tributary itself was also contaminated with TCE.
SUMMARY OF BITE RISKS
Human Health Risks
During the RI/FS, an analysis was conducted to estimate the
health or environmental problems that could result if the ground
water contamination from the Caldwell site was not cleaned up.
This analysis is commonly referred to as a baseline risk
assessment. In conducting this assessment, the focus was on the
health effects that could result from direct exposure to the
contaminants as a result of ingestion of the ground water. The
analysis focused on the major contaminant of concern, TCE, which
is a volatile organic compound that is known to cause cancer in
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^
.•'••' «\ i: t-.- .
FIGURE 3
TCE CONTAMINATION (ppb)H ZONE B - JUNE
CALDWELL TRUCKING CO OFFSITE RI/FS, FAIRFIELD TWP.. MJ
M mr
NUS
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12
laboratory animals and thus is classified as a carcinogen. It is
a highly mobile contaminant that typically migrates through the
soil into the ground water.
•»
Cancer potency factors have been developed by EPA's Carcinogenic
Assessment Group for estimating lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals. Cancer
potency factors, which are expressed in units of milligrams of
carcinogen per kilogram per day (mg/kg/day)"1, are multiplied by
the estimated intake of a potential carcinogen in mg/kg/day, to
provide an upper-bound estimate of the excess lifetime cancer
risk associated with exposure at that intake level. The term
"upper-bound" reflects the conservative estimate of the risks
calculated from the cancer potency factor. Use of this approach^
makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been .-
applied.
Reference doses have been developed by EPA for indicating the
potential adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. Reference doses, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the reference dose. Reference doses
are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the reference doses will not
underestimate the potential for adverse noncarcinogenic effects
to occur.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., ixlO*6 05 1E-6). An excess lifetime cancer risk of ixlO'6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as a hazard quotient
(or the ratio of the estimated intake derived from the
contaminant's reference dose). By adding the hazard quotients
for all contaminants within a medium or across all media to which
a given population may reasonably exposed, the Hazard Index can
be generated. The Hazard Index provides a useful reference point
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13
for gauging the potential significance of multiple contaminant
exposures within a single medium or across media*
EPA's sampling of the ground water found that the average
concentration of TCE was 5 parts per million. This concentration
level is associated with an excess lifetime cancer risk of 3.4 X
10* . This means that if no cleanup action is taken by EPA, an
additional 3.4 people per thousand have a chance of contracting
cancer as a result of the exposure to the contaminated ground
water. This estimate was developed by taking into account
various conservative assumptions about the likelihood of a person
being exposed to the ground water, and the carcinogenicity of
TCE. This risk estimate is based in part on the present, and
projected future, average concentration levels of TCE in each of
the four zones (reference Table 1).
However, since the affected population will be provided with a ".
public water supply, the remaining risks associated with the
contaminated ground water involve the use of it for non-potable
(non-drinking) purposes. There continues to be a potential risk -
associated with contact to the seep and the tributary of
Deepavaal Brook.
Environmental Risks
As noted in the concluding paragraph of the Site Description,
there are no known endangered species or critical habitats
located in the plume area. However, there are many small
scattered wetlands throughout the area which would be seriously
impacted under certain remedial actions while other alternatives
would have little or no impact on the wetlands. Hence wetlands
play an important role in balancing the advantages and
disadvantages of one alternative against another.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF REMEDIAL ALTERNATIVES
The RI identified two environmental media that were impacted by
the plume, i.e., the ground water itself and a small seep or
surface water recharged by contaminated ground water. In the FS,
three basic alternatives were considered: (1) No Action,
(2) Remediation of the seep (alone) and improvement of the
monitoring system, and (3) Pump and Treat the water table and
bedrock aquifers. As the Pump and Treat option could be
structured in various ways, it was expanded into three discrete
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14
TABLE 1
AVERAGE TRICHLOROETHENB CONCENTRATION (yg/1) IN GROONDWATER
NO-ACTION SCENARIO
CALOWELL TRUCKING COMPANY OPFSITE PS
Time
(Years)
0
20
40
60
80
100
140
180
200
Zone
A
1,004
436.0
321.4
243.3
184.7
140.3
80.7
47.3
36.5
B
3,637
2,520
1,892
1,476
1,178
954.1
643.9
444.8
371.9
C
5,250
3,626
2,880
2,356
1,962
1,653
1,198
880.2
756.3
D
556 . 2
1,238
1,616
1,814
1,882
1,863
1,675
1,410
1,275
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15
alternatives (3, 4, and 5), with the main variable being the
size, number and location of the air strippers needed to remove
the contaminants.
After an initial review by EPA and the New Jersey* Department of
Environmental Protection (NJDEP), when it was understood that it
would take between 100 - 200 years to attain State drinking water
standards under the full pump and treat schemes (Alternatives 3,
4, and 5), NJDEP suggested that two other (partial) remedies be
included for review. Alternative 6 proposed pumping and
treatment close to the site, where there is a band of higher
contaminant levels, before the plume spreads out and down and
becomes more dilute. The last alternative (No. 7) proposed to
install a series of barrier wells at the north and western edges.
of the plume to confine its movement. The seven alternatives are
listed below:
* Alternative 1: No Further Action with Monitoring.
* Alternative 2: Ground Water Use Restrictions and Surface
Water Controls.
* Alternative 3: Ground Water Pumping, Treatment at the
Caldwell Trucking Company Site/ and Discharge
to the Passaic River.
* Alternative 4: Ground Water Pumping, Treatment at Three
Locations, and Discharge to the Passaic
River.
* Alternative 5: Ground Water Pumping, Treatment near Fifteen
Well Locations, and Discharge to Surface
Water.
* Alternative 6: Partial Ground Water Pumping, Treatment at
the Caldwell Site, and Discharge to Surface
Water.
* Alternative 7: Pumping of Ground Water Barrier Wells and
Discharge to Surface Water.
Alternative 1:
NO FURTHER ACTION WITH MONITORING
Capital Costs: ' $ 30,000
Annual Operation and
Maintenance (O&M) Costs: $ 15,000
Present Worth: $ 261,000
Implementation Period: 1 month
This alternative would not require implementation of specific
remedial actions to address ground water and surface water
contamination. Under this alternative, a long-term monitoring
program would be implemented to determine whether ground water
and surface water contaminant concentrations are changing with
time, and to track the migration of contaminated ground water.
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16
The monitoring program includes sampling the spring where ground
water discharges to surface water, and sampling ground water from
monitoring wells near the outer edges of the contaminant plume.
Gradual attenuation of the plume will occur over time as a result
of other source removal actions being planned (reference
Table 1). * .
Alternative 2:
GROUND WATER USB RESTRICTIONS AHD 8URJACE WATER CONTROLS OHLY
Capital Costs: $ 390,000
Annual O&M Costs: $ 20,000
Present Worth: $ 700,000
Implementation Period: 2 years
•*
This alternative would not require removal or treatment of
contaminated ground water or surface water. Under this
alternative, administrative controls, such as ground water use
restrictions in the affected area, would be implemented by the
State and Fairfield Township as needed to prevent the use of
ground water as a drinking water supply and any risks posed by
non-potable uses. To reduce the potential for exposure, the
spring and drainage pathway, where contaminated ground water
discharges, would be filled with crushed stone and covered with a
layer of soil. A long-term monitoring program similar to that
proposed for the No-Action alternative would also be required. A
review of all off-site wells would be made to determine their
importance to the monitoring program, and to assist the Federal
and State government agencies in identifying other sources of
contamination affecting the quality of ground water in Fairfield.
In reviewing Alternative 2, concerns were raised involving the
potential risks associated with continued use of the contaminated
ground water for non-potable purposes and the risks associated
with the potential exposure to the southern tributary of
Deepavaal Brook. It is believed that some private wells within
the contaminated plume from Caldwell Trucking, which have been
replaced by municipal water, are still being used for non-potable
(non-drinking) purposes, such as irrigation. This use of these
wells still poses a potential health risk to the user through
ingestion and inhalation. In addition, there is a threat of
cross-contamination to the municipal supply if these contaminated
wells continue to operate. Therefore, to remove the health risk
to the user and the risk of cross contamination to the municipal
supply, Alternative 2 will include the sealing of those wells in
the contaminated (downgradient) plume which are still in
operation or have been abandoned. Figure 3 provides some
indication of the area of primary concern, namely those streets
within the 500 parts per billion (ppb) contour lines.
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17
In addition to the seep and its pathway, the southern tributary
from that juncture to Deepavaal Brook is contaminated and poses a
threat to human health. In order to remove this risk,
Alternative 2 would provide an enclosed path (French drain or
culvert) from that point on the tributary to Deepavaal Brook
(see Figure 4).
In order to ensure that this remedy continues to be protective of
human health and the environment, the above monitoring program
would be expanded to include new well points to detect potential
contamination approaching Municipal Wells Nos. 6 and 8 which are
major public water sources.
This expanded Alternative 2 would increase the remedial costs
shown in the FS as follows: raise capital costs from $105,000 to
$390,000, annual O&M costs from $15,000 to $20,000, and present
worth from $335,000 to $700,000. The implementation period for
Alternative 2 would be increased to approximately 2 years.
Alternative 3:
GROUND WATER PUMPINO, TREATMENT AT THE CALDWELL TRUCKING COMPANY
SITE, AND DISCHARGE TO THE PAS8AIC RIVER
Capital Costs:
Annual O&M Costs:
Present Worth:
Implementation Period:
$ 6,700,000 $ 6,700,000
$ 315,000 $ 315,000
$ 11,540,000 $ 14,340,000
30 years 100 years
This alternative involves installation of ground water recovery
wells equipped with pumps at 15 locations throughout the study
area to intercept contaminated ground water throughout the
vertical zones of contamination. The total pumping rate would be
approximately 1.2 million gallons per day (MGD). An air stripper
would be constructed at the Caldwell Trucking Company site to
treat the extracted ground water. Appropriate pollution control
systems would be installed to meet New Jersey air emissions
regulations (NJAC 7:27).
Influent piping would be installed between the wells and the air
stripper, and an effluent pipeline would be constructed to the
Passaic River (see Figure 5). The effluent will be treated to
meet New Jersey surface water discharge regulations. Ground
water pumping would lower the water table so that the spring
would no longer discharge contaminants to the southern tributary
of Deepavaal Brook. However, this would result in the water
table being pulled down over the entire area, including scattered
wetland acreage.
Table 2 shows computer derived projections of the estimated
reduction in TCE from Caldwell Trucking, by pumping and treating
for up to 200 years. According to the table, it would take over
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•M •• « FRENCH DRAIN
SOUTHERN TRIBUTARY
TO OEEPAVAAL BROOK
ALTERNATIVE 2
SURFACE WATER CONTROL
CALDWELL TRUCKING CO. OFFSITE RI/FS.
FAIRFIELD TWP. NJ
FIGURE 4
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>
ALTERNATIVE 3
SINGLE AIR STRIPPER AND PIPEUME LDCATH3M8
CALDWELL TRUCKING CO. OFFSiTE RI/F& FAIRF1ELD TWP.
FIGURE 5
SCAU M rtii
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20
TABLE 2
AVERAGE TRICHLOROETHENE CONCENTRATION (ug/1) IN GROUNOWATER
GROUNDWATER EXTRACTION AND TREATMENT FOR 200 YEARS
CALOHELL TRUCKING COMPANY OFPSITE
Time
(Years)
0
4
8
12
16
20
24
28
32
36
40
44
60
100
200
Zone
A
1,004
696.9
448.1
273.03
169.6
109.0
72.2
49.2
34.3
24.5
17.9
13.2
5.0
0.9
0.1
B
3,637
1,091
583.4
334.8
204.3
130.9
86.7
59.3
41.6
29.9
22.0
16.4
6.4
1.2
0.2
C
5,250
1,158
612.9
348.9
212.4
136.1
90.2
61.7
43.3
31.2
23.0
17.3
7.0
1.5
0.2
D
556.2
749.0
547.2
397.3
294.2
222.3
171.4
135.0
108.7
89.3
74.9
64.0
39.7
19.0
7.7
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21
over 100 years for the ground water to be cleaned up to the
State's drinking water standards of 1 ppb for TCE. Because of
the extremely long time required to reach drinking water goals,
and recognizing that there are other unknown sources
contaminating the aquifer, EPA and NJDEP would implement this
alternative for 30 years, to achieve an interim cleanup level
which allows for potable use of the ground water with minimal
treatment.
If drinking water standards were the objectives, the present
worth and analysis for the 100-year implementation period for
this and the following alternatives includes the discounted
annual operation and maintenance, and the discounted capital
investment which would be needed to replace equipment past its
useful life.
Alternative 4:
GROUND WATER PUMPING, TREATMENT AT THREE LOCATIONS, AND DISCHARGE
TO THE PAS8AZC RIVER
Capital Costs:
Annual O&M Costs:
Present Worth:
Implementation Period:
$ 5,755,000
$ 333,000
$ 10,865,000
30 years
$ 5,755,000
$ 333,000
$ 14,290,000
100 years
This alternative is similar to Alternative 3. It involves the
installation of ground water recovery wells at 15 locations
throughout the study area to intercept the contaminated ground
water. The total pumping rate would be approximately 1.2 million
gallons per day (MGD). Three air strippers would be constructed
near the following locations: (1) at the Caldwell Trucking
Company site, (2) an area between Pier Lane and Passaic Avenue,
and (3) north of, and in close proximity to, Deepavaal Brook.
Each air stripper would treat water from five well locations.
Influent piping would be installed between the wells and the air
strippers. Effluent piping would be installed between the air
strippers and the Passaic River. Even though this alternative
involves 3 (smaller) strippers instead of one, shorter and
smaller water gathering lines would save a million dollars in
capital investment over Alternative 3. Ground water pumping
would lower the water table at the spring, but would also result
in lowering the water table in the scattered wetland areas. This
alternative accomplishes the same remedial objectives as
Alternative 3.
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22
Alternative 5
GROUND WATER PUMPING, TRZATXZHT AT FIFTEEN WELL LOCATIONS, AND
DISCHARGE TO SURFACE WATER
Capital Costs:
Annual O&M Costs:
Present Worth:
Implementation Period:
^
$ 7,700,000 $ 7,700,000
$ 450,000 $ 450,000
$ 14,665,000 $ 19,250,000
30 years 100 years
This alternative is similar to Alternatives 3 and 4 in that it
involves the installation of ground water recovery wells at 15
locations throughout the study area to intercept and extract
contaminated ground water. The total pumping rate would be
approximately 1.2 MGO. Fifteen air strippers would be
constructed; one at or near every pumping well location. Each
air stripper would treat water at each well location. Short
reaches of influent piping would be installed between each well
location and the air stripper serving that location. Effluent
piping would be installed between the air stripper and the local -
storm sewer system, which would receive the treated ground water.
This alternative also would remediate the spring as a byproduct
of the pumping. This alternative accomplishes the same remedial'
objectives as Alternatives 3 and 4.
Alternative 6
PARTIAL GROUND WATER PUMPING, TREATMENT, AND DISCHARGE TO SURFACE
WATER
Capital Costs:
Annual 06N Costs:
Present Worth:
Implementation Period:
$ 2,020,000
$ 180,000
$ 3,700,000
12 years
$ 2,020,000
$ 180,000
$ 4,765,000
30 years
This alternative involves installation of ground water recovery
wells equipped with pumps at seven locations to intercept
contaminated ground water within the 10,000 ppb TCE contour in
the lower water table aquifer and the upper bed rock aquifer.
The total pumping rate would be approximately 0.25 MGD. An air
stripper would be constructed at the Caldwell Trucking Company
site to treat the extracted ground water. Appropriate pollution
control systems would be installed to meet New Jersey air
emissions regulations (NJAC 7:27). Influent piping would be
installed between the wells and the air stripper, and an effluent
pipeline would be constructed to the Passaic River, directly or
via Deepavaal Brook (see Figure 6). The effluent will be treated
to meet New Jersey surface water discharge regulations. Neither
the wetlands nor the spring are likely to be impacted under this
alternative.
Alternative 6, as presented in the Feasibility Study, considered
pumping and treating the more highly contaminated ground water
-------
®m%s&
|X \5PVs£>' •«*• I
^^ICSJ
TRUCKING COMPANY SlTE|
SCALE MFEET
ALTERNATIVE NO. 6: AIR STRIPPER. PIPELINE. AND
WELL LOCATIONS - PARTIAL GROUNDWATER PUMPING
.L TRUCKING CO. OFFSITE Rl/f
FAIRFIELD TWR, NJ
LEGEND
PROPOSED PUMPM6 WELL-ZONE B
PROPOSED PUMPMO WELL - ZONE C
PROPOSED AIR STRIPPER LOCATION
PROPOSED INFLUENT PIPING
POSSIBLE EFFLUENT ROUTES
FIGURE 6
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24
for 12 years, to reduce the level of TCE entering the extraction
wells from 10,000 ppb to 5,000 ppb, and thereby reducing the
average TCE concentration throughout the aquifer. Alternative 6
could be modified, to continue the pumping and treatment of these
areas for 30 years, to reduce the level of contaminants even
further. It is estimated that by pumping and treating for
approximately 30 years, the level of contamination can be reduced
such that the lover bedrock aquifer Would not be further
degraded, and potable water could be attained with moderate
treatment. Aquifer cleanup levels attainable for any time frame
(12, 30, or 100 yrs) under this scenario are identified in
Table 3.
Alternative 7
PUMPING OF GROUND WATER BARRIER WELLS AMD DISCHARGE TO SURFACE
WATER
Capital Costs: $ 1,510,000 .
Annual O&M Costs: $ 138,000
Present Worth: $ 3,625,000
Implementation Period: 100 years plus
This alternative involves installation of ground water barrier
wells equipped with pumps at four locations near the leading
northwestern edge of the ground water contaminant plume in the
bedrock aquifer. The wells would attempt to prevent further
migration of contaminated ground water. The total pumping rate
would be approximately 0.75 MGD. Piping would be installed
between the wells and the Passaic River. Treatment would not be
required, possibly for decades, since the wells would be located
at the leading edge of the contaminant plume. However, as ground
water contaminants migrate from more heavily-contaminated areas
of the plume toward the barrier wells, contaminant concentrations
would be expected to increase, and thus treatment might be
required in about 40 years. Under this alternative, there would
be a minor impact on the wetland water levels.
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25
TABLE 3
AVERAGE TRICBLOROETHENE CONCENTRATION (ug/1) IN GROUNDWATER
PARTIAL GROUNDWATER EXTRACTION AND TREATMENT (200 WARS)
CALDWELL TRUCKING COMPANY OFFSITE PS
Tine
(Yt«r»)
0
4
8
12
16
20
24
28
32
36
40
44
60
100
200
Zone
A
1,004
341.7
217.9
153.4
117.1
94.7
79.8
69.2
61.3
56.5
51.7
46.7
40.9
28.4
15.6
B
3,637
2,746
1,882
1,352
1,057
848.3
704.9
602.2
526.4
510.3
494.2
469.6
426.4
318.6
182.7
C
5,250
3,386
2,390
1,807
1,439
1,194
1,022
896.9
802.4
756.1
709.7
664.1
603.2
453.9
258.0
D
556.2
1,049
1,101
1,047
971.9
899.9
836.2
781.7
735.6
708.7
681.7
655.7
620.2
529.9
362.2
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26
SUMMARY 07 THE COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Contingency Plan, a detailed
analysis of each remedial alternative is conducted with respect
to each of nine detailed evaluation criteria. All selected
remedies must at least attain the Threshold Criteria. The
selected remedy should provide the best trade-offs among the
Primary Balancing Criteria. The Modifying Criteria were
evaluated following the public comment period.
Threshold Criteria
• Overall Protectiveness of Human Health and the Environment -
This criterion evaluates the adequacy of protection that the
remedy provides while describing how risks are eliminated,
reduced or controlled through treatment, engineering con- >
trols, and/or institutional controls.
• Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) - This criterion addresses whether a .-
remedy will meet all of the applicable or relevant and
appropriate requirements of other Federal and State environ-
mental statutes and/or provide grounds for invoicing a
waiver.
Primary Balancing Criteria
• Reduction of Toxicity, Mobility, or Volume (TMV) - This
criterion addresses the anticipated treatment performance of
the remedy.
• Short-Term Effectiveness - This criterion addresses the
period of time required to achieve remedial goals and the
risks to human health and the environment during the
remedial action.
• Long-Term Effectiveness and Permanence - This criterion
evaluates the magnitude of residual risk and the ability of
the remedy to maintain reliable protection of human health
and the environment over time once remedial goals have been
attained.- >
• Implementability - This criterion examines the technical and
administrative feasibility of executing a remedy, including
the availability of materials and services needed to imple-
ment the chosen solution.
• Cost - This criterion includes the capital and operation and
maintenance costs of the remedy.
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27
Modifying Criteria
• State Acceptance - This criterion indicates .^nether, based
on its review of the Operable Unit Two Feasibility Study and
Operable Unit Two Proposed Plan, the State of New Jersey
concurs with, opposes, or has no comment on the preferred
alternative.
• Community Acceptance - This criterion evaluates the reaction
of the public to the remedial alternatives and EPA's
Proposed Plan. Comments received during the public comment
period and EPA's responses to those comments are summarized
in the Responsiveness Summary attached to this document.
Analysis
This section discusses and compares the performance of the
remedial alternatives under consideration against the nine
criteria.
overall Protection
All of the alternatives, with the exception of the "No Action"
alternative, would provide some protection of human health by
eliminating, reducing or controlling risk through treatment,
engineering controls, or institutional controls. Full protection
of the environment would vary, according to the alternative
selected. Alternative 3 (30-year option) would reduce the risk
from using the ground water by reducing the level of contaminants
within the affected aquifer to an interim concentration which
would allow the aquifer to be used for potable water with minimal
treatment.
Alternatives 3, 4, and 5 (100-year option) would attempt to
reduce the level of contaminants to drinking water levels and
would be considered fully protective. Alternative 6 would reduce
the highly contaminated area of ground water to prevent the least
contaminated zone, the lower bedrock aquifer, from degrading
further, and would allow the aquifer to be used for potable water
with moderate treatment. Alternative 2 is protective through
institutional controls on the use of groundwater, and by
restricting exposure to the seep and the tributary. Alternative
7 protects against future migration only.
The "No Action1* alternative does not provide any additional
protection to that provided by the previous 1986 ROD and,
therefore, is not considered further in this analysis of options.
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28
Compliance with ARARS
Alternatives 3, 4, and 5 (100-year option) are designed to meet
Federal and State drinking water standards (ARARs^ after their
100-year implementation periods are completed. At that time, the
ground water would meet present day standards. Alternatives 3,
4, 5 and 6 (30-year option) are designed to achieve interim
concentration levels such that, after 30 years, the ground water
could be used for potable purposes with either minimal or
moderate treatment. In these four alternatives, the treated
ground water (effluent) will meet New Jersey surface water
discharge regulations, and the off-gas from the treatment units
will meet the NJAC 7:27 air emission regulations directly, or
through the use of appropriate pollution control systems.
; Alternatives 2 and 7 do not address the attainment of drinking
water standards in the aquifers.
There are some scattered wetlands in the area which will be
affected by actions taken to remediate the ground water.
Alternatives 3, 4, and 5 will have significant impacts on these
wetlands, while Alternatives 2, 6, and 7 would have minimal, if
any, impacts. Accordingly, Alternatives 3, 4, or 5 would require
compliance with the conditions of a New Jersey Fresh Water
Wetlands Permit equivalent and Federal Executive Order 11990.
Long-term Effectiveness and Permanence
Alternatives 3, 4, and 5 (30-year option) would provide long-term
protection by reducing the ground water to levels which could be
used for potable purposes with minimal treatment.
Alternative 6 is designed to reduce the level of contamination
only in areas with high levels of TCE. However, the levels of
contamination would be significantly reduced and would prevent
further degradation of the aquifer. Also, after 30 years, the
ground water could be used for potable purposes with moderate
treatment.
Alternatives 3, 4, and 5 (100-year option) are designed to return
the aquifer to use as a source of public water after their 100-
year implementation periods are completed. These three
alternatives provide the best options for long-term effectiveness
and permanence once drinking water standards are met.
Alternative 7 has a limited goal of keeping the plume from
migrating toward Municipal Well No. 8, which is still clean.
While the Caldwell plume would be intercepted for as long as the
pumps are in use, these wells would not protect Well No. 8 from
other plumes passing behind them (to the west).
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29
Alternative 2 provides long-term protection in controlling the
ground water seep and the southern tributary to Deepavaal Brook.
This alternative also provides permanent protection against cross
contamination of municipal water through a well Dealing program.
Reduction of Toxicity, Mobility, or Volume of the Contaminants
Through Treatment
Alternatives 3, 4, 5, and 6 (30-year option) would reduce the
toxicity, mobility, and volume of the contaminated ground water
through long-term treatment.
Alternatives 3, 4, and 5 (100-year option) afford the most
complete reductions through treatment of contamination over the
long implementation periods necessary under those options.
Alternative 6 would significantly reduce concentrations in the
most highly contaminated area of the plume such that drinking
water standards could be achieved with moderate treatment. '_
Alternative 7 controls the mobility (direction) of the plume to
some extent, but does not achieve permanence. Alternative 2 does
not involve any treatment systems.
Short-term Effectiveness
The major risk associated with the contaminated ground water is
the use of it for potable purposes. Provision of an alternate
water supply for the affected area is being accomplished under
the 1986 ROD. Therefore, this risk will be significantly
reduced. Alternatives 3, 4, and 5 (30-year option) would reduce
the level of contamination in the affected aquifer to acceptable
levels within the shortest time frame for potential future use as
potable water with minimal treatment. i
Alternative 6 would be highly effective in the short-term because
it is applied to the most concentrated area of the plume.
Alternative 2 would be the most effective alternative in the
short term, by quickly remediating the seep and implementing a
well sealing program.
Alternative 7 has no short-term advantages.
Alternatives 3, 4, and 5 (30-year option) may have a significant
impact on the wetlands in the area because of the draw down of
the water table. However, Alternatives 3, 4, and 5 (100-year
option) would continue this impact for a much longer time frame.
Alternatives 2, 6, and 7 would not impact the wetlands.
None of the listed alternatives should create any short-term,
health-related concerns for the public. All of the alternatives
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30
that involve well drilling will require protection for workers at
drilling sites.
•»
Xapleaentability
While Alternative 3 (30-year option) is the most desirable,
there are serious implementation problems associated with it.
In order to effectively capture the ground water and treat it at
a rate and volume to achieve the stated goal, approximately 15
well fields must be installed throughout the community. Because
of the density of the area, it is likely that a number of these
well fields would need to be located on residential properties.
These well fields would consist of a number of wells at each
location, pumps and other equipment, as well as a building to
house the equipment, if necessary. Since the impact on private
property owners might be significant, obtaining access to these
properties may be extremely difficult and time consuming.
Written and oral comments were received during the public comment
period which indicate a strong preference for Alternative 6
rather than Alternative 3 because it has less impact on
residential properties.
In addition to the well field location difficulties, there is
also a potential for encountering difficulty in obtaining access
to install the pipe lines from the well field locations to the
central treatment plant at the site and the effluent pipe from
the treatment plant to the Passaic River. These lines will have
to run along and cross fully developed roads and highways.
Alternative 3 (30-year option) is preferred over Alternatives 4
and 5 (30-year option) because it would be more implementable.
Alternatives 4 and 5 include multiple treatment plants at well
head locations, which would increase the impact on the private
property owner and would require operation and maintenance of
many treatment plants instead of one.
Implementation of Alternative 6 is also dependent upon the access
of property to place wells within the area of highly contaminated
ground water and the access to rights-of-way for pipelines from
the wells to the treatment plant at Caldwell and from the site to
the Passaic River. Of all the alternatives which involve pumping
and treatment of ground water, however, Alternative 6 may offer
the best opportunity for implementation since it requires the
placement of wells on only six, primarily commercial, properties.
The other pump and treat alternatives require a minimum of 15
locations, many of which are in residential areas. Alternatives
3, 4, 5, and 7 all involve implementation periods of 100 years or
more for the longer time period option. During that time, the
equipment will require maintenance, parts, and possibly complete
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31
replacement, since the pumps must be in use continually. Even
underground piping may need to be replaced.
Alternative 2 can be fully implemented with minimum difficulty.
Coat
Costs in thousands of dollars
Capital Annual Present
Alternative Costs O & M Worth
No. 2 390 20 700
No. 3 6,700 315 11,540
No. 4 5,755 333 10,865
No. 5 7,700 450 14,665
No. 6 2,020 180 4,765
No. 7 1,510 138 3,625
State Acceptance
The State of New Jersey supports both the preferred and
contingency remedies presented in this document.
Community Acceptance
Community acceptance of the preferred alternatives was evaluated
after the public comment period. Oral and written comments were
received which indicate a strong preference for Alternative 6
rather than Alternative 3. Comments raised at the public meeting
and during the public comment period are summarized in the
attached Responsiveness Summary.
SELECTED REMEDY
EPA and NJDEP believe that the contaminant levels in both
aquifers should be reduced as far as practicable. Alternative 3
(30-year option) would substantially reduce these levels in the
affected portions of each aquifer through pumping and treatment.
This would result in a level of concentration in the aquifers
that would allow them to be utilized for potable purposes with
minimal treatment in a reasonable time frame. Therefore, it is
believed to provide the best balance among alternatives with
respect to the evaluation criteria. However, it is recognized
that implementation of this alternative is dependent on obtaining
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32
access to the private properties needed for the well field
locations, and to public roads for construction of the pipelines.
Owners of 33 private homes in the access area stated their
opposition to wells on residential properties duVing the public
comment period. Therefore, if access to the properties needed
for implementation of Alternative 3 (30-year option) cannot be
obtained, EPA and NJDEP will attempt to implement a contingency
remedy of Alternative 6 (30-year option) and Alternative 2.
Alternative 6 would reduce the level of contaminants such that
potable water could be obtained with a moderate amount of
treatment. Expanded Alternative 2 would remediate the seep and
the southern tributary, provide new monitoring wells to safeguard
Municipal Wells No.6 and No.8, and institute a well sealing
program.
While implementing any remedy for the cleanup of ground water
affected by the Caldwell Trucking Company, it will be necessary
to address other sources of contamination and other plumes in the
area to ensure that the desired cleanup of the ground water can '
be achieved. These other sources and plumes would be addressed
under Federal and State authorities other than CERCLA.
Currently, it is believed that private wells may still exist in
the area of affected ground water contamination, even though an
alternate water supply is available for potable use. Because of
the threat to human health associated with the use of this ground
water for non-potable purposes and the potential for cross-
contamination to the municipal supply, the selected alternative
would also include sealing of such wells in the central plume
area.
Based on the information available at this time, EPA and the
State of New Jersey believe both the preferred alternative and
the contingency alternative would be protective of human health
and the environment, would be cost-effective, and would utilize
permanent treatment technologies or resource recovery
technologies to the maximum extent practicable. Because they
would treat the contaminants in the ground water, the above
remedies also would meet the statutory preference to employ
treatment as a principal element.
STATUTORY DETERMINATIONS
EPA's selected alternatives for plume remediation comply with the
requirements of Section 121 of CERCLA as amended by the Superfund
Amendments and Reauthorization Act. Both the preferred remedy
(Alternative 3) and the contingency remedy (Alternatives 6 & 2)
are protective of human health and the environment in the short-
term through institutional controls, and in the long-term as
pumping and treatment substantially reduces the health and
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33
environmental risks. While there are no unacceptable risks
throughout the implementation period, the remedies differ in
several respects. The preferred remedy treats a greater volume
of ground water and therefore attains lower interim contaminant
levels in the aquifer after 30 years. However, with regard to
the seep, Alternative 2 of the contingency remedy eliminates the
risk immediately and, through the installation of new monitoring
wells, would safeguard the existing public water supply.
The ARARs identified for the ground water are the Federal and
State Safe Drinking Water Act MCLs (Maximum Contaminant Levels).
Due to the extent and concentration of the ground water plume,
and the impact of other sources in the Fairfield area, it would
take more than 100 years to clean the aquifer to drinking water
standards. Accordingly, a waiver is invoked under this Record of*
Decision based on technical impractability, namely, that these
MCLs are not attainable within a rational time-frame. These
conditions, and therefore the waiver, would apply equally to both
the preferred and contingency remedies. The treatment facilities *
employed under both remedies would comply with State ARARs
governing air emissions and effluent discharges to surface
waters. The preferred remedy may require special conditions or
offsets to meet Executive Order 11990 (Federal ARAR) and a State
wetlands permit equivalent. The contingency remedy meets these
ARARs.
Both the preferred and contingency alternatives are projected to
be cost-effective in terms of achieving both short-term and long-
term cleanup goals for the ground water. However, since
Alternative 6 concentrates solely on the most contaminated
portions of the plume, and Alternative 2 remediates the seep
immediately, the contingency remedy is the most cost-effective of
the two.
Both the preferred and contingency alternatives utilize permanent
solutions and treatment technologies in remediating the
contamination in the ground water. The pump and treat schemes
specified under these remedies will significantly reduce the
toxicity, mobility, and volume of the contaminants found in the
ground water, thus bringing the aquifer much closer to its
purpose as a source of drinking water. Alternative 2 of the
contingency remedy provides monitoring wells to permanently
safeguard the existing public water supply.
Public comments were received which suggested that Alternative 3
could not be implemented, but were supportive of the contingency
remedy (Alternatives 6 and 2) presented in this Record of
Decision.
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RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
CALDWBLL TRUCKING COMPANY (O7T-8ITB AREAS)
FAIRTIELD TOWNSHIP
E88B1 COUNTY, NEW JERSEY
Z• OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public
comment period from August 16, 1989 through September 15, 1989
for interested parties to comment on EPA's final Remedial
Investigation and Feasibility Study (RI/FS) and Proposed Plan for*
the Caldwell Trucking Company (Off-Site Areas).
EPA held a public meeting on August 30, 1989 at the Fairfield
Township Municipal Building in Fairfield, New Jersey to describe
the remedial alternatives and present EPA's preferred and
contingency remedial alternatives for the Caldwell Trucking
Company site and to update the public on the implementation of
the 1986 Record of Decision.
A responsiveness summary is required for the purpose of providing
EPA and the public with a summary of citizens' comments and
concerns about the site as raised during the public comment
period, and EPA's responses to those concerns. All comments
summarized in this document were given full consideration in
selecting both the preferred remedy and contingency remedy for
the Record of Decision.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Caldwell Trucking Company site initially became an issue of
public concern -during the early 1980's when results of a 1980-
1982 NJDEP well sampling program revealed residential and
commercial well contamination. In February 1982, the Fairfield
Township Engineering Department notified residents with
contaminated wells that they should limit their well water usage
to bathing and household uses. Residents were provided with a
location to obtain water for drinking and cooking. In 1982,
Fairfield Township extended public water supply lines to the area
that had been affected by residential well contamination and
offered the first round of connections at a reduced fee.
Major issues and concerns expressed by the Community regarding
the Caldwell Trucking Company site are as follows:
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• Remedial Action Concerns
In the past, residential, commercial and industrial property
owners expressed a number of concerns related to the use of
their land for monitoring wells. Owners are now expressing
those same concerns in relation to the use of their property
for pumping wells. Additional concerns are being voiced
because of the long periods of time that would be needed for
completion of this action. Specifically, owners are worried
about the negative effects resulting from the installation
of pumping wells. These include: reduced property values and
marketability, liability coverage, restrictions on the use
of their property, aesthetics, and the credibility of long ""
term governmental commitments for property restoration.
• Human Health Concerns
Residents have expressed concern over the potential adverse *
health effects from the consumption and use of contaminated
well water. Residents have also asked about Federal or
State funding to connect to municipal water once their wells
are found to be contaminated.
• Migration of Contaminant Plume
In the past, local officials and residents have expressed
concerns regarding the potential for additional municipal
and residential well contamination by off-site ground water
contamination plume migration.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC MEETING AMD EPA RESPONSES.
Comments made during the August 30, 1989 public meeting for the
Caldwell Trucking Company site are summarized in this section are
summarized below and organized into the following categories:
A. Feasibility of Alternatives;
B. Technical Concerns;
C. On-site Soil Remediation; and
D. Miscellaneous Concerns.
A. Feasibility of Alternatives
1. Comment: A resident asked if, under Alternative No. 3, it
would be more effective to place extraction wells in closer
proximity to the Caldwell Trucking Company property rather than
placing them at the 15 proposed locations around Fairfield
Township.
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EPA Response: The primary difficulty in placing wells closer to
the Caldwell Trucking Company property is that there is a problem
in generating a capture zone radius sufficient to^contain the
contaminant plume. In addition, a substantial drawdown in water
levels would occur in a more confined radius.
2. Comment: A resident inquired into the feasibility of placing
extraction wells on residential properties under Alternative
Mo. 3.
EPA Response: Fifteen well locations would be stationed on a
combination of residential, commercial, and industrial
properties. EPA recognizes that there may be problems in
obtaining access to certain residential properties for the
installation of extraction wells. In addition to well field
location difficulty, there may be difficulty in obtaining access
to install pipelines from the well field locations to the central
treatment plant at the site and the effluent pipe from the
treatment plant to the Passaic River. It is most likely that
these lines would have to run along and across local and county
roads.
3. Comment: A local official asked if it would it be possible
to use or modify existing storm drains instead of installing new
piping for the transport of water from the proposed treatment
facility to be located on the Caldwell Trucking Company property
to the river.
EPA Response: One of the problems with using existing storm
drains is that the capacity that would be needed for capturing
stormwater would otherwise be utilized. EPA can further examine
the option for enlarging the existing storm drain during the
design phase of the cleanup.
4. Comment: A resident stated that the Caldwell Trucking
Company site was in a floodplain area and asked if EPA took into
account the effect a hundred year flood would have upon any.
selected remediation systems.
EPA Response: EPA is aware of the site's location relative to
the floodplain. During the design phase of the project, the
factor of a 100 year flood would be taken into account.
B. Technical Concerns
1. Comment: A resident asked what impact EPA's proposed ground
water pumping stations would have upon Fairfield Township's
ability to produce water for commercial purposes.
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EPA Response: EPA believes there will be no impact, or a minimal
impact at worse, upon Fairfield Township's ability to produce
water. EPA will be working with the Township during the design
phase to examine what impacts, if any, selected alternatives
would have upon municipal wells.
2. Comment: A resident inquired into the impacts of EPA's
preferred alternatives on residential wells.
EPA Response: Residential wells clearly located within the plume
area would likely be closed because of the contamination and the
potential risk to the public related to well water use even for
non-drinking purposes, and also because of the potential for >
cross-contamination to the municipal water supply. Those outside
or on the fringe of the plume would not be affected.
3. Comment: A resident asked if the sealing of private wells
would be on a recommendation basis or made mandatory by a Federal
or State agency.
EPA Response: EPA would select only those wells within the
contaminated plume from the Caldwell Trucking Company site and
would highly recommend those wells be sealed, to insure that
residents do not use the water for such purposes as lawn care or
washing cars, which might have adverse impacts. The State of New
Jersey, however, may require that selected wells be sealed.
4. Comment: One industrial company inquired about the
possibility of EPA utilizing existing production wells in the
Caldwell Trucking Company site cleanup.
i '
EPA Response: EPA will evaluate the use of any existing wells
during the design phase of the Caldwell Trucking Company site
cleanup.
5. Comment: President asked about the dimensions of the
proposed pump houses, and if there would be any noise generated
in this operation.
EPA Response: The final dimensions of the pump houses would be
determined during the design phase of the project. The pump
houses would be approximately ten to twenty feet square,
depending on how many wells would be stationed at that location.
There would be a low background noise generated by the pumps.
6. Comment: A resident asked about the dimensions of the air
stripping unit proposed for location on the Caldwell Trucking
Company site property.
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EPA Response: The exact dimensions would be calculated during
the design phase of the project. However, the dimensions might
be approximately forty feet high and six or eight* feet in
diameter for the main tower. In addition, there would be
auxiliary equipment, such as blowers and piping.
C. On-Site Soils Remediation
1. Comment: A resident inquired into the time-frame required
for treating on-site soil contamination and if the soils will
always remain toxic.
EPA Response: The actual soils remediation will take
approximately eighteen months and will involve the excavation of
approximately 30,000 yards on the Caldwell Trucking Company site
property. EPA will utilize a rotary kiln to vaporize volatiles,
which is practically all the contamination there is.
2. Comment: A resident asked if the treated soils could be
reused for fill.
EPA Response: EPA believes that the soils are primarily
contaminated with volatiles which would be virtually eliminated
during the rotary kiln process. However, there are some heavy
metals which would not be removed. Therefore, EPA will be
placing the excavated and treated soils in a secure landfill to
be constructed on the Caldwell Trucking Company property site in
accordance with Resource Conservation and Recovery Act (RCRA)
requirements.
3I Comment: Several residents inquired into the possibility of
hazardous waste from other sites being deposited in the landfill
proposed for construction on the Caldwell Trucking Company
property.
EPA Response: The landfill proposed for construction on the
Caldwell Trucking Company property would be dedicated to the
soils excavated on-site, and possibly that of contiguous
property. Once the excavation process is completed, the landfill
will be sealed.
4. Comment: Several residents expressed concern regarding the
potential for hazardous emissions coming from the proposed rotary
kiln to be stationed on the Caldwell Trucking Company site.
EPA Response: EPA must adhere to stringent State and Federal
emissions standards and will constantly monitor all equipment to
insure compliance with established standards. The rotary kiln
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unit proposed for the site would contain all vaporized volatiles.
If a mechanical problem should occur with the kiln, there is an
automatic backup system which would instantly shut the unit down.
D. Miscellaneous Concerns
1. Comment: Several residents inquired into the extent that the
Caldwell Trucking Company site contamination plume has affected
area ground water.
EPA Response: During EPA's past and present ground water
studies, four different sources of contamination were identified.
Wells located in the other identified contamination areas have
nothing to do with the Caldwell Trucking Company site. EPA and
State authorities will be making efforts to clean up these other
identified areas of contamination and stop the sources from
further polluting the region's ground water.
2. Comment: Several residents inquired into EPA's role in
reimbursing residents who, in the early 1980's, spent their own •
funds to connect to the municipal water supply.
EPA Response: Under the Superfund Law, EPA cannot compensate
residents for connections to a municipal water system prior to
EPA remedial site activities. There is the possibility that
those residents could receive compensation from the New Jersey
State Spill Fund. EPA will provide interested residents with the
names of NJOEP officials that can provide information on New
Jersey State Spill Fund eligibility.
3. Comment: A local official asked if Fairfield Township would
qualify to receive reimbursement for monies expended in
subsidizing the costs of residential connections to a municipal
water supply in the early 1980's.
EPA Response: The Superfund Law is very specific as to how EPA
can spend its funds. There are some provisions in the law for
local and state'government reimbursements. EPA will work with
Fairfield Township officials to determine if any reimbursement
can be made under existing legal requirements.
4. Comment: A resident who works in the vicinity of the
Caldwell Trucking Company's property asked if there were any
dangers from exposure to soils or waters running off of the
property due to heavy rains.
EPA Response: EPA believes that there is no danger of exposure
to volatiles from surface contact. At present, there are no
surface volatiles on the Caldwell property, and only a limited
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amount of heavy metals. Anything that could volatilize would
have done so over the last 15 years.
•»
IV. SUMMARY OF MAJOR WRITTEH COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AMD EPA RESPONSES.
A public comment period was held from August 16, 1989 through
September 15, 1989 to receive comments from the public on the
draft RI/FS reports and the Proposed Plan. Written comments
submitted during the period are summarized in this section, along
with EPA's responses.
A. Letter from Sadat Associates, consultant to General Hose
1. Comment: The consultant claims that the volume of
contaminated soil is less than the 5,000 cubic yards estimated by
EPA's contractor, NUS Corporation.
EPA Response: The volume of soil can be verified later. The
important issue is that the contaminated soil should be
remediated so it ceases being a source of contaminants in the
ground water.
2. Comment: The consultant claims that almost all the
contamination found in the soil on the General Hose property
actually migrated from Caldwell Trucking and hence General Hose
is not a "primary" source of contamination.
EPA Response: The term "primary" is related to the volume of
contaminated soil, which will be verified later. The
contaminated soil on the General Hose property is a source of
contamination to the ground water.
B. Letter from the RREEF real estate company, a malor
c^omm^rcial property owner in the area (See Attachment A)
Comment: RREEF gave the EPA access for four monitoring
wells on its property in 1987 and, therefore, would hope and
expect that EPA look elsewhere in locating wells under this
remedial action.
EPA Response: The RREEF property is a large area located close
to Caldwell Trucking where the ground water is highly
contaminated. For that reason, it may very likely be needed for
extraction well locations under either the preferred remedy
(Alternative 3) or the contingency remedy (Alternative 6).
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8
C. Petition from 33 property owners in the p
(See Attachment B)
•»
Comment: The petition requests that EPA not chose
Alternative 3, which they feel is not a fair or reasonable
solution, but rather should select and implement Alternative 6.
EPA Response: The petition confirms the problems related to
implementation that EPA recognized and addressed in the Proposed
Plan and at the Public Meeting. EPA will work closely with
property owners and local officials during the pre-design phase
to resolve problems which relate to the implementation of the
final remedy.
V. REMAINING CONCERNS
Concerns raised by the community regarding remedial action and
design activities at the Caldwell Trucking Company site will
continue to be important community issues in the future.
Since the preferred alternatives involve the placement of
extraction wells and related equipment on residential properties,
both residents and Fairfield Township officials have taken a
particular interest in the selection of the proposed
alternatives.
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Relations Activities
Caldvell Trucking Company (Off-Site Areas)
Public Meeting November 1987
Fact Sheet November 1987
Revised Community Relations Plan February 1988
Proposed Plan August 1989
Public Meeting August 1989
Responsiveness Summary September 1989
All community relations documents are available for public review
in the designated site information repositories.
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JREEF
The RREEF Funds
ATTACHMENT A
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 15. 1989
Mr. Edward J. Finnerty
Project Manager, ERRD
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
Re: Your Correspondence dated 8/31/89
Dear Mr. Finnerty:
Relative to your previous correspondence dated October 15,
1987, you installed four (4) ground water wells on our
property at 6 Kingsbridge Road in Fairfield, N.J. As
•entioned in your August 31, 1989 neno, you now want to
install wells at 7 Kingsbridge Road.
We believe these new wells will cause some disturbance to the
property and the tenants in this building.
Since RREEF peraitted you to install ground water wells at
the 6 Kingsbridge Road location, we cannot agree to
additional wells on the property at 7 Kingsbridge Road. I an
sure there are other properties where these new wells could
be installed.
Thank you for your understanding in this Batter.
Sincerely,
Nicholas A. Allegretti
Operations Manager
NAA/seb
cc: Ms. E. S. Cole
Avenue
)erve> 07601
:Jt>1 486-.300
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ATTACHMENT B
page 1 of 3
Septeaber 6, 1989
Mr. Edward J. Finnerty *
Keaedial Project Manager
U.S. Environmental Protection Agency
looa 711
26 Federal Plaza
Mew York. Hew York 10278
Dear Mr. Finnerty:
Attached please find a petition regarding the EPA'a Alternative
43 - Propoaal to build well flelda on residential properties/
The residential community, consisting of Orlando Drive, Harding
Drive Vest, Pier Lane and Toll Terrace are strongly opposed
to Alternative 43 and have so stated this by signing this
petition for the record.
The fact that these hoae owners were not notified properly
regarding the EPA Meeting that was held August 30th is also
a source of Irritation to this couunity. The Majority of
residents would have liked to have been at the meeting August 30
to voice their opinions for the record. This Matter could have
grave consequences to the hoae owners and is of a serious nature.
The articles in the Star Ledger/Caldwell Progress were obviously
not enough notification. In the future wa would like to be
notified of Meetings in a More sufficient Banner so it will not
be overlooked.
i
We are all aware of the Magnitude of the problea of the contaain-
ated water in well 17, however, wa are all la agreement that
Alternative 13 (wells on residential properties) is not a fair
or reasonable solution. Therefore, we all agree that Alternative
46 (wells on cosnercial properties) should be used.
Our opinion on Alternative 13 is "NO".
i
Sincerely,
lesldents Concerned About
Alternative 13
CC: MAYOR AND TOWN COUNCIL
230 Fairfield Koad
Fairfield, New Jersey
Caldwell Progress
Caldwell, New Jersey
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ATTACHMENT B
page 2 of 3
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