United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-86/028
Sept 1986
&EPA
Superfund
Record of Decision
Combe Fill North Landfill, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing!
1. REPORT NO.
E PA/ROD/RO 2-86/028
3.
\. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Combe Fill North Landfill, NJ
5. REPORT DATE
September 29. 1986
6. PERFORMING ORGANIZATION COOE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Combe Fill North site is located in Mount Olive Township, NJ, near the
intersection of U.S. Highway 206 and Interstate 80. The former landfill comprised 65
acres of the 103-acre property. The area surrounding the site is primarily wooded, with
small residential areas, farms and light industry nearby. Approximately 10,000 people
rely on ground water supplied from wells downgradient of the site. Between 1966 and
1978, the site operated as a sanitary municipal landfill, accepting municipal,
vegetative, and non-chemical industrial wastes, along with small amounts of dry sewage
sludge. From September 1978 until January 1981, the landfill was owned and operated by
the Combe Fill Corporation (CFC). During this time, CFC was repeatedly cited for
violations of New Jersey solid waste administration codes. In 1979, public outrage at
the disposal practices of CFC led to formation of SMOTHER (Save Mount Olive
Township-Halt Environmental Rape), a public action group which conducted ground water
sampling and initiated procedures to include the Combe Fill North site on the NPL.
During the RI, ground water, soils, leachate, sediments and surface water were sampled.
Low levels of volatile organics were found in soils and leachate, and hexachlorobenzene,
phenol and bis (2-ethylhexylt) phthalate were detected in low concentrations in ground
water samples.
(See Attached Sheet)
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Combe Fill North Landfill, NJ
Contaminated Media: soils, ground water
Key contaminants: methylene chloride,
ethylbenzene, toluene, phenol
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report)
None
21. NO. O
GES
20. SECURITY CLASS (Tills page I
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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EPA/ROD/R02-86/028
Combe Fill North Landfill, NJ
16. ABSTRACT (continued)
The selected remedial action for the Combe Fill North site includes:
grading and compacting the 65-acre waste disposal area; capping the landfill
in accordance with appropriate solid waste management criteria; installation
of a drainage system, including perimeter ditches and corrugated metal
pipes; installation of a methane ventilation system; fencing the entire
site; and implementation of an appropriate monitoring program to ensure the
effectiveness of the remedial action. Estimated capital cost for the remedy
is $10,500,000 with annual O&M costs of $168,000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site Combe Fill North Landfill, Mount Olive Township, New Jersey
Documents Reviewed
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Combe Fill North Landfill site:
- Combe Fill North Landfill Remedial Investigation and
Feasibility Study, Ebasco Services, May 1986
- Responsiveness Summary, August 1986
- Staff Summaries and Recommendations
Description of Selected Remedy
- Grade and compact the 65-acre waste disposal area
- Cap the landfill in accordance with appropriate
solid waste^management criteria
- Install a drainage., system, including perimeter ditches
and corrugated metal pipes
- Install a methane venting system
- Construct a security fence surrounding the site
- Implement an appropriate monitoring program to ensure
the effectiveness of the remedial action
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the remedy described above,
closure of the landfill in accordance with appropriate solid
waste management criteria, is the cost-effective remedial
action alternative for the Combe Fill North Landfill site.
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It is hereby determined that implementation of this remedial
action is the lowest cost alternative that is technologically
feasible and reliable, and which effectively mitigates and
minimizes damages to and provides adequate protection of public
health, welfare and the environment. It is also hereby determined
that the selected remedy is appropriate when balanced against
the availability of Trust Fund monies for use at other sites.
The State of New Jersey has been consulted and agrees with the
selected remedy.
~t$U
*
Date Christopher J. Daiggett
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
COMBE FILL NORTH LANDFILL
MOUNT OLIVE, NEW JERSEY
SITE LOCATION AND DESCRIPTION
The Combe Fill North site is located on Gold Mine Road near the
junctions of U.S. Highways 206 and 46 and Interstate 80 in Mount
Olive Township (Figure 1). The residential communities of
Netcong Boro, to the northeast, and Budd Lake, to the southwest,
are both less than two miles from the site. The former landfill
comprises 65 acres of the 102.8-acre property. In appearance,
it forms an insignificant mound in the hilly surroundings. A
dirt road borders the filled area on the south and east, and
several large piles of daily cover material lie to the north and
west (Figure 2). A gasoline pump near the entrance to the site
implies the presence of an underground storage tank.
Much of the land surrounding the site is wooded; the developed
areas are residential with some farming and light industry nearby.
Budd Lake is a developed resort and Route 46 is highly commer-
cialized. Approximately 10,000 people use groundwater from
private wells located downgradient (northeast) and within two
miles of the site. There are several small ponds on-site, and
surface runoff drains into two small streams, east and west of
the site, that are tributaries to Wills Brook, which empties
into the Musconetcong River.
SITE HISTORY
The site was first operated as a municipal landfill beginning in
1966. It reportedly accepted municipal, vegetative, and indus-
trial (non-chemical) wastes and small amounts of dry sewage
sludge. Wastes were deposited in a marshy area and remain below
the water table.
From 1969 until 1978, the landfill was operated by Morris County
Landfill, Inc. It was registered with the New Jersey Department
of Environmental Protection (NJDEP) on 8 January 1976. From
September 1978 until January 1981, the landfill was owned and
operated by Combe Fill Corporation (CFC), a wholly owned sub-
sidiary of Combustion Equipment Associates (CEA). CFC was
repeatedly cited for violations of New Jersey solid waste admini-
stration codes.
Public outrage at the operating practices of CFC led to the forma-
tion of a citizens' group called SMOTHER (Save Mount Olive Town-
ship - Halt Environmental Rape) in 1979. This group conducted
groundwater sampling around the site and was influential in
initiating the process for ranking the site on the National
Priorities List (NPL). The site was added to the NPL in December
1982.
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4
?LEDGEWOODl
•~ L
. . MILL I
V POND I
HcKketlstown
Reservoir
Sneen Acrest
PnjKl/
M O
^782!
COMBE FILL NORTH
JOD
BL7DD
LAKE
V
I
MOUNT
OLIVE
- - *3
Own '«ij
COMBE FILL NORTH
MOUNT OLIVE TOWNSHIP, MORRIS COUNTY
NEW JERSEY
Scale in Miles (Approx.)
1 2
Figure 1
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Piles of Daily'
Cover Material
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There have been no remedial actions at Combe Fill North to date.
The United States Environmental Protection Agency (EPA) sent
information request and notice letters to all known potentially
responsible parties in 1983 before beginning the Remedial
Investigation (RI) and Feasibility Study (FS). A summary of
enforcement activities taken to date is provided in another
section of" this document.
CURRENT SITE STATUS
Low concentrations of hazardous substances were found at the
site during the RI. Soils, leachate, surface water, sedi-
ments, and groundwater were sampled between December 1984 and
July 1985. Soils at the site were found to contain methylene
chloride at 123 ppb; ethylbenzene and toluene were found in
leachate at 21 ppb and 25 ppb; and hexachlorobenzene, phenol,
and bis(2-ethylhexyl)phthalate were found in the groundwater
at the site at 3.3 ppb, 56.6 ppb, and 49.5 ppb. The complete
chemical data base from the RI is provided in Appendix 1.
The site was originally evaluated for ranking on the NPL using
groundwater data collected by SMOTHER, the NJDEP, and other
agencies. These data indicate that higher levels of organic
chemicals may have once been present at and. leaking from the
site. However, since sampling methods and analytical techniques
are not known and original data and supporting information do not
exist, these data are of questionable quality and value. The
data obtained during the RI provide the basis for the FS; these
data represent the most complete assessment available of the
current condition of the site.
The available chemical data, which indicate that concentrations
at the site are low and that there is currently no off-site
migration, do not indicate that there are human receptors
currently endangered by the site. However, the site is covered
with rocky, permeable soil and waste is known to exist in a
shallow aquifer that is connected to a deeper aquifer that serves
more than 10,000 people downgradient and within two miles of
the site. In the site's present condition, this population is
potentially exposed to contaminants that could enter this
source of drinking water. This assessment of the site will be
refined by additional sampling events conducted by the NJDEP
during and after design and implementation of the selected
remedy. The site was resampled on 13 August 1986.
ENFORCEMENT
The State of New Jersey and EPA have identified CFC and its
parent company, CEA, as potentially responsible parties (PRPs).
A notice letter was sent to CEA and over 100 other PRPs on 26
September 1983 regarding a proposed RI/FS at the site. None of
the acknowledged recipients offered to undertake the study.
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On 21 November 1983, EPA entered into a cooperative agreement
with the NJDEP whereby the NJDEP was authorized to use Superfund
money to conduct the RI/FS at the site.
On 22 January 1986, EPA filed an application in Bankruptcy Court
seeking reimbursement of Superfund monies spent to date at the
site from CFC, which had declared bankruptcy in October 1981.
Because of the limited funds remaining in the bankrupt's estate,
EPA and CFC reached a tentative settlement of the Superfund
claims in May 1986. EPA has not yet initiated any enforcement
actions against any other PRPsr, including CEA.
ALTERNATIVE EVALUATION
Six remedial alternatives were analyzed in detail in the FS.
They are listed in Table 1. Remedial objectives were developed
to address the potential release of hazardous substances since
there is little evidence of a significant release at this time.
Potential exposure routes include contact with groundwater and
surface water that could be contaminated by chemicals leaching
from the landfilled waste. Hazardous substances, including
methylene chloride, hexachlorobenzene, and bis(2-ethylhexyl)
phthalate, are known to be present at the site. The results of
a methane migration survey indicate that explosive levels of
this gas may also present a hazard.
Several remedial technologies were eliminated during screening
as inappropriate or infeasible for the Combe Fill North site.
Complete and partial removal of wastes as-well as on- and off-
site treatment and relocation of residents were determined to
be inappropriate to address' the remedial objectives.
The remaining alternatives included no action, several variations
of closing the landfill and containing the waste, and excavating
the waste and returning it to improved cells. These alternatives
attain federal public health and environmental standards to
varying degrees, based on assumptions about the content of the
landfill. All of the alternatives include the construction of
a security fence surrounding the site and the implementation of
a groundwater and surface water monitoring program.
No Action
This alternative includes the construction of a security fence
to restrict access to potentially contaminated areas and the
implementation of a long-term groundwater monitoring program to
provide advance warning of increased releases of hazardous sub-
stances in the future. It employs established construction
techniques, and although it does not mitigate any of the poten-
tial exposure routes, it does provide an early-warning system
so that appropriate action could be taken.
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Table 1
COMBE FILL NORTH LANDFILL
Summary of Remedial Alternatives
Alternative
No Action
Solid Waste Land-
fill Closure
Capital Cost
($ million)
0.5
10.5
23.9
Hazardous Waste
Landfill Cap
(HWLC)
HWLC and Ground- 26.3
water Extraction/
Treatment
HWLC and Ground- 35.7
water Diversion
Barrier
On-Site Disposal 72.3
in Hazardous
Waste Landfill
New Water Supply* 3.8
Treated Existing 4.0
Water Supply*
Present Worth
of O&M
($ million)°
0.4
1.6
4.7
7.6
5.5
13.7
5.9
11.0
Total
Present Worth
($ million)0
0.9
12.1
28.6
33.9
41.2
86.0
9.7
15.0
0 Based on 10 percent interest and a 30-year time period.
* The costs of the alternate water supply options are listed
separately although one would only be implemented in conjunction
with a closure alternative.
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Solid Waste Landfill Closure
Combe Fill North is an open dump as defined in 40 CFR Part 257,
"Criteria for Classification of Solid Waste Disposal Facilities
and Practices". The Resource Conservation and Recovery Act (RCRA),
Subtitle D, which is relevant and appropriate to Superfund actions
according to the "CERCLA Compliance With Other Environmental
Statutes" p'olicy memo of 2 October 1985, requires the states to
develop solid waste management plans. The Combe Fill North Solid
Waste Landfill Closure alternative complies with New Jersey's
specifications for closure of sanitary landfills developed pur-
suant to the State plan.
The 1981 New Jersey Court order to close the Combe Fill North
Landfill could not be enforced because CFC declared bankruptcy a
few months after it was issued. Implementing this remedial
alternative would close the dump in accordance with RCRA Sub-
title D and New Jersey Administrative Code 7:26, "Nonhazardous
Waste Management Regulations". The landfilled area would be
graded, capped, and seeded, and a surface water drainage system,
a methane venting system, and a security fence would be installed.
A map showing the features of this alternative is provided in
Figure 3; Figure 4 contains a detailed cross-section of the
cap.
This alternative would minimize surface water infiltration, thus
reducing the production of leachate. The site is currently
covered with permeable backfill material and is graded in such a
way that large ponds have formed, creating a hydraulic head that
forces surface water into the waste deposits. The cap would also
eliminate the threat of direct contact with leachate on the sur-
face. The fence would restrict access and limit possible direct
contact with hazardous materials, and the methane venting system
would eliminate the explosion hazard. The waste would, however,
continue to be in contact with the groundwater, so the potential
for generating hazardous leachate would not be eliminated.
This alternative, which would properly close the site (an open
dump) as a sanitary landfill, may attain all appropriate environ-
mental standards. However, any sanitary landfill contains some
amount of hazardous substances. As such, RCRA hazardous waste
regulations may be appropriate to the site, yet there is little
evidence that Combe Fill North received greater quantities of
hazardous substances than any other sanitary landfill. If there
is to be a distinction between the closure of sanitary and
hazardous .waste landfills, current data indicate that this site
can be closed using techniques for the former category.
Implementation of Solid Waste Landfill Closure would utilize only
proven technologies. Although increased air emissions should
be expected during grading, this alternative will provide
long-term benefits without negative side effects. The alterna-
tive is highly reliable and involves minimal operation and
maintenance.
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y/w^»^vi
~> / yy^fWJT-**/
SANITARY LANDFILL'CLOSURE
//ra
/ ' ' ''-I
''
Figure 3
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Figure 4
Sanitary Landfill Cap
•6" TOPSOIL
BORROW COVER (CLEAN SOIL)
1* CLAY COVER (PERMEABILITY 10'7 CM/SEC)
EXISTING
SOLID WASTES
19'
1' COMMON BORROW
MATERIAL (CLEAN SOIL)
5'
vO
I
DRAINAGE DITCH
NOT TO SCALE
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Alternate Water Supply
Two schemes for providing an alternate water supply were
developed to be used in conjunction with a containment action.
There is no need to implement either scheme at this time as
there is no indication that potable wells are contaminated. If
contamination is detected in the future, water could be supplied
to residents at that time. All of the alternatives presented
in this document include long-term monitoring of the groundwater
to provide early warning of contamination. Providing alternate
water would protect public health from contamination only in
potable well supplies; contaminants could still enter the ground-
water and potentially move into surface waters.
The first alternate water supply option would involve creating
a new well-field in the Kittatinny limestone formation in the
Drakes Brook drainage area south of the site. This area was
recommended by the Morris County Master Plan - Water Supply Element
as being able to provide water to satisfy the projected needs
of the affected area. Established technologies would be utilized;
a 21,000-foot water main, two chlorinators, two booster stations,
a water distribution system, and four wells would be required.
The second alternate water supply option would involve treating
the existing water supply of Netcong, Stanhope, and the Village
Green Apartments. Air stripping and activated carbon could be
used to treat contaminated groundwater. The decontaminated
water would then be redistributed to users in the affected area.
Providing an alternate water source wouTd only be necessary if
the aquifer became contaminated and private wells were threatened.
If this occurs, implementing this alternative will not prevent
the spread of contamination in the environment and so will not
achieve compliance with other environmental statutes. It might
also fail to protect public health if contaminants were discharged
from the aquifer to surface waters. However, it would be reliable
and would provide a safe water supply for domestic' use.
Hazardous Waste Landfill Cap
This alternative would involve regrading and compacting the 65-
acre dump and covering it with a clay/synthetic cap as shown at
the top of Figure 7. This alternative does not include the liner/
leachate collection system shown at the bottom of this figure.
The other features of this alternative are similiar to the Solid
Waste Landfill Closure: surface water diversion, security fence,
methane venting, and groundwater monitoring.
The environmental benefits from this alternative are similar to
those for Solid Waste Landfill Closure. Surface water infiltration
would be more effectively restricted by this cap thereby reducing
the potential of producing hazardous leachate. However, the
wastes would still remain in contact with the groundwater. The
implementability and reliability for this alternative are the
same as for Solid Waste Landfill Closure.
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This alternative would provide a more impermeable surface barrier
than Solid Waste Landfill Closure, but since the wastes would remain
in contact with the groundwater, this alternative does not achieve
full compliance with RCRA Subtitle C, "Hazardous Waste Management".
The applicability of the statute to this site has already been
considered.
Hazardous Waste Cap and Groundwater Diversion
Two alternatives were developed that employ the landfill cap
described in the previous alternative in conjunction with a
means of reducing contact between the wastes and the aquifer.
The technologies for lowering the water table are an upgradient
slurry wall and a system of groundwater extraction wells. The
primary benefit of both of these alternatives is that removing
groundwater from the wastes will further reduce the potential
for creating leachate.
A 4000-foot slurry wall, approximately 60-feet deep and anchored
in bedrock, would extend from the western property boundary,
along Gold Mine Road on the south, to the eastern property
boundary as shown in Figure 5. A french drain upgradient of
the wall would prevent groundwater from mounding at and
overtopping the wall. The wall and drain would redirect ground-
water around the site to prevent groundwater from infiltrating
the waste.
This alternative employs well-established technologies and is
highly reliable. It requires minimal operation and maintenance
and offers significantly greater protection than the alterna-
tives discussed previously by isolating the wastes from the
surrounding environment. Nevertheless, hazardous substances were
not detected in significant,quantities in the groundwater or
leachate at this site. Therefore, compliance with other environ-
mental statutes is achieved and public health protected without
implementing an alternative as extensive as this.
Hazardous Waste Cap with Groundwater Extraction
This alternative is a variation of the one discussed above.
Twelve extraction wells would be pumped to lower the water
table below the waste for most of the year. A map of the site
indicating locations of the wells and the treatment plant is
provided in Figure 6. During periods of highest water table
elevations, groundwater would come into contact with the wastes.
However, any hazardous leachate that may be generated would be
pumped to the treatment plant before it was released. Treatment
would consist of air stripping, metals removal, and activated
carbon adsorption. As with the previous alternative/ the
current data base indicates that such extensive action is not
justified.
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^^•"v--V&-
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, , - : : X.?f f' >/-'tejS5^
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f-;i/v- - r -^ff^«^sdr^^^^^p^.^«^^
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ACRE ACTIVE LANDFILL AREA)
_, . (
SLURRY>J
Figure 5
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-13-
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'GROUNDWATER
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'(NON-LANDFILL AREA)j
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vjn\yWIVL/K/^ i tn .^.' •'• •. "V\
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f. (65 ACRE ACTIVE LANpFILLAREAK
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Figure 6
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-14-
The wells needed for this alternative are easier to install than
a slurry wall. As a result, projected construction time is
somewhat less. The durability and reliability of this alternative
may also be somewhat less than the slurry wall groundwater
barrier. Loss of well yield, due to corroding or clogging of
the wells or pumps, would allow the groundwater to come into
contact with the waste again. The operation and maintenance
requirements of this alternative are greater than those of the
other containment actions discussed.
Re-Landfilling Into New Hazardous Waste Cells
This alternative would involve excavating the waste materials,
backfilling the excavated pit with clean material to raise the
ground surface five feet above the water table, installing a
RCRA double liner, redepositing and compacting the waste, and
covering the landfill with a RCRA hazardous waste cap. Figure
7 provides a schematic detail of the RCRA hazardous waste
containment system.
This alternative, once implemented, would provide the greatest
isolation of the waste from the environment currently available
from a containment system. This landfill would be more durable
and reliable than any of the other alternatives presented.
However, during construction, workers would be exposed to large
volumes of wastes, and hazardous substances that are not currently
mobile could be released to the environment when these wastes
are disturbed.
This alternative would comply fully with all environmental stat-
utes. However, the expense of this alternative is not justified
by an existing threat to public health or the environment. The
technologies and construction techniques required to implement
this alternative are well established.
COMMUNITY RELATIONS
Concerned citizens formed SMOTHER to involve the public in op-
posing the operation of the Combe Fill North Landfill. The
group has sampled wells and gathered information about the
site; it reflects the community's interest in properly closing
Combe Fill North. Township residents have expressed concern
regarding odors emanating from the site and the potential for
contaminants to enter surface waters and drinking water supplies.
The RI/FS report was made public on 12 June 1986. A public com-
ment period began on that day and was closed on 16 July 1986.
Two public meetings were held at the Mount Olive Municipal
Building: one at the outset of the RI/FS on 2 October 1984, and
another on 1 July 1986 to discuss the findings of the study and
the preferred alternative. Concerns expressed by the public
are addressed in the Responsiveness Summary appended to this
document (Appendix 2).
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Figure 7
•TOPSOIL
RCRA
CAPPING
SYSTEM
• • " w '
1*
t
r
\
SAND (DRAINAGE LAYER)
>
CLAY SEAL
RCRA
DOUBLE
LINER
SOLID WASTE REDE POSITION
LEAK DETECTION SYSTEM
(4"
40 MIL
'SYNTHETIC LINER
LEACHATE COLLECTION SYSTEM
(6" * PVC)
V
•i'cf
y
r
SAND
SAND
CLAY LAYER
CLEAN SOIL BACKFILL
O
o
V
40 MIL
SYNTHETIC LINER
GROUNDWATER TABLE
NOT TO SCALE
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CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The operators of the Combe Fill North Landfill were frequently
cited for violating New Jersey solid waste management codes.
Among other problems, the dump was not properly closed when
operations ceased. The Resource Conservation and Recovery Act
prohibits open dumping and requires that state solid waste
management-plans provide for upgrading existing open dumps.
The Solid Waste La'ndfill Closure alternative presented previously
was designed to comply with New Jersey "Nonhazardous Waste
Management Regulations".
Although past chemical data indicated greater releases of hazardous
substances from the site in the past, analytical results from
the RI indicate that only low levels of hazardous substances are
present or being released from the Combe Fill North Landfill at
this time. Information currently available indicates that the
site may not have received larger quantities of hazardous sub-
stances than any sanitary landfill would be expected to receive in
municipal refuse. Therefore, the nonhazardous waste regulations
of RCRA Subtitle D are considered relevant and appropriate to this
site.
The hazardous waste cap and groundwater barrier was developed
as a remedial alternative to comply with RCRA Subtitle C,
hazardous waste regulations. Compliance with these more stringent
requirements would be attained by utilizing a less permeable cap
and preventing groundwater from infiltrating the waste. The
hazardous waste cap with groundwater extraction and the hazardous
waste cap alone would allow the wastes to come into contact with
the groundwater for at least part of the year. Therefore, these
alternatives would not ensure compliance with RCRA Subtitle C as
fully as would the cap with the slurry wall. The re-landfilling
option would comply with RCRA Subtitle C and would be more durable
and reliable than the other alternatives.
The hazardous waste regulations in RCRA Subtitle C are not con-
sidered relevant to this site. Enforcement investigations to date
have not revealed any reliable evidence that hazardous waste
dumping activities occurred at the site, and the current chemical
data base does not indicate that hazardous substances are
present or being released in significant quantities.
RECOMMENDED ALTERNATIVE
The cost-effective remedy for this site is Solid Waste Landfill
Closure. As discussed previously, the relevant and appropriate
federal statute governing closure of the site is RCRA Subtitle D.
Pursuant to this subtitle, and in anticipation of a stronger
emphasis on state standards in the new CERCLA legislation,
State of New Jersey solid waste management guidelines were
considered in developing the remedial alternative. Solid Waste
Landfill Closure complies with the relevant and appropriate
federal statutes.
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Th e chemical data obtained during the RI does not indicate that
the landfill is releasing significant quantities of hazardous
substances at the current time. Nonetheless, the No Action
alternative is considered inappropriate as a permanent remedy
since it does not protect against potential increased releases
of contaminants into area groundwaters which are used extensively
for drinking purposes.
However, Solid Waste Landfill Closure does provide adequate protec-
tion from potential releases to groundwater and surface water
and is required to achieve compliance with RCRA, which prohibits
open dumping and requires upgrading open dumps.
The other remedial alternatives developed in the FS are not
cost-effective because they provide levels of protection that
are not warranted by a chemical hazard posed by this site. All
of the alternatives considered in this summary are listed in
Table 1 along with their capital costs. The total present
worth of each, based on 30 years' operation and maintenance is
also provided.
A site layout and a cap cross-section illustrating the recommended
alternative are provided in Figures 3 and 4. The features of the
Solid Waste Landfill Closure are:
"Grade and compact the 65-acre waste disposal area
"Cover with one foot of common borrow material
"Cap with one foot of clay (permeability 1x10"? cm/sec)
"Cover with sufficient common borrow material to ensure
the clay cap is below the average frost penetration depth
"Cover with six inches of topsoil
"Plant a vegetative cover (grass seeding)
"Install a drainage system, including perimeter ditches
and corrugated metal pipes
"Install a methane venting system
"Construct a security fence surrounding the site
"Implement a quarterly groundwater and surface water
monitoring program
-------
-18-
OPERATION AND MAINTENANCE (O&M)
The O&M requirements of the recommended alternative are very
limited. They include mowing the grass on the landfill/ visually
inspecting the runoff ditches, clearing litter from the ditches,
and performing sampling and analysis for the long-term monitoring
prog ram. - ..
Both the ditches and the cap are subject to cracking. However,
proper installation should minimize the possibility of this
occurring.
Annual O&M should cost $168,000; the present worth of 30 years
O&M is $1.6 million. Operation and maintenance will be funded
as specified in CERCLA and the NCP.
SCHEDULE
Project Milestone Date
-Approve Remedial Action September 1986
-Initiate Enforcement Negotiations September 1986
-Amend Cooperative Agreement for Design Pending CERCLA
Reauthorization
or State Funding
-Initiate Design Pending CERCLA
Reauthorization
' •" or State Funding
-Complete Design Pending CERCLA
Reauthorization
or State Funding
FUTURE ACTIONS
After the Record of Decision is signed, ongoing quarterly moni-
toring of surface water and groundwater will be implemented. A
monitoring plan has been developed by the NJDEP and released
for public comment.
-------
APPENDIX 1
CHEMICAL DATA
Table Media
1 Test Pits and Soil Borings
2 Leachate
3 Surface Water
4 . Sediment
5 Monitoring Well Water
6 Potable Well Water
-------
Table 1
SUMMARY OP RESULTS
Depth
Sample I.ab Date Saapled
ID ID Taken (Ft)
STP1 F9154 12/11/84 6.75-7.75
STP-2B K3865 10/21/85 12.5
STP-3B K3866 10/21/85 15
STP-4B K3868 10/21/85 7.5
CHEMICAL ANALYSIS OP TEST PIT SOIL SAMPLES
Volatile Fraction Acid Fraction Base/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cooc. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
ND ND ND Aa
Ba
Cr
Pb
ND ND. ND Sb
Aa
Be
Cr
Pb
Nl
Zu
ND ND ND Sb
Aa
Be
Cr
Pb
Nl
Zn
Methylene 123 2.8 ND ND Sb
Chloride Aa
Be
Cr
Pb
Nl
Zn
Cone.
(PP»>
1.4
87
14
3.6
17
1.3
0.6
10
4
8
50
10
1.3
0.5
10
4
3
40
11
I
0.4
6
28
3
40
DL
(PP*>
0.5
0.5
I
0.5
4
1
0.08
2
0.5
1
30
4
1.0
0.08
2
0.5
1
30
4
1
0.08
2
0.5
I
30
DL - Detection Halt
ND - Not detected
(b) - Qualified due to hold tlae exceedancea
STPl - Soil fro* teat pit It
-------
SUMMARY OP RESULTS
Depth
Saaple Lab Date Sampled
ID ID Taken (Ft)
STP5 P9155 12/11/84 7.0-8.0
STP6 F9150 12/14/84 8.5-9.0
STP7 F9149 12/13/84 lO.O-ll.O
STP8 P9148 12/13/84 11.0-12.0
STP-9B K3864 10/21/85 10
CHEMICAL ANALYSIS OP TEST PIT SOIL SAMPLES
Volatile Fraction Acid Fraction Baae/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
ND ND NO As
fea
Cr
Pb
ND(b> ND ND Aa
Ba
Cr
Pb
ND ND ND Aa
Ba
Cr
Pb
ND ND ND Aa
Ba
Cd
Cr
Pb
Hg
ND ND ND Sb
Aa
Be
Cr
Pb
Nl
Zn
Cone.
(PP-)
6.5
39
12
6.4
1.4
40
8
3
1.5
130
10
24
1.4
94
3
II
67
0.4
16
1.4
0.5
10
4
3
50
DL
(PP-)
0.5
0.5
I
0.5
0.5
0.5
I
1
0.5
0.5
1
0.5
0.5
0.5
0.5
I
5
O.I
4
I
0.08
2
0.5
I
30
DL - Detection Llalt
ND - Not detected
(b) - Qualified due to hold tli
STP5 - Soil from teat pit IS
esceedance*
-------
SUMMARY OP RESULTS
.
Depth
Saajple tab Date Sampled
ID ID Taken (Ft)
STPIO P9135 12/12/84 5.0-6.0
•
STPll P9157 12/12/84 6.0-7.0
STP12 P9156 12/12/84 11.0-12.0
CHEMICAL ANALYSIS OP TEST PIT SOIL SAMPLES
Volatile Fraction Acid Fraction Baae/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Coapound (ppb) (ppb) Coapound
ND<°>« MD NO As
' Be
Cr
Cu
Pb
Nl
Zn
ND(b) ND MD j. Aa
Ba
Cr
Pb
MD(b) MD MD Aa
Ba
Cr
Pb
Cone.
(ppa)
2.7
0.7
10
18
6
9
48
1.2
26
8
3
1.6
59
6
2.6
DL
(PP»>
0.5
0.5
I
1
0.5
I
I
0.5
0.5
1
I
0.5
0.5
I
0.5
DL - Detection Llalt
ND - Not detected
(b) - Qualified due to hold tl«e exceedancea
* - Compound alao preaent In lab reagent blank.
STPIO - Soil fro* teat pit HO
Therefore, actual presence and/or quantification la questionable.
-------
SUMMARY OP RESULTS
Depth
Saaple Lab Date Sampled
ID ID Taken (Ft)
SMW7 C5071 1/2/85 10.0-18.0
SNW8 C5074 1/7/85 10.0-70.0
SMW9 G5073 1/7/85 14.0-20.0
SNWIO G5075 1/10/85 3.0-13.0
SMWU P9142 1/9/85 20.0-28.0
CHEMICAL ANALYSIS OP MONITORING WELL SOILS
Volatile Fraction Acid Fraction Base/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
ND ND ND Ba
Cr
Pb
Hg
ND ND ND Aa
Ba
Cr
Pb
ND ND ND Aa
Ba
Cr
Pb
ND ND ND Aa
Ba
Cr
Pb
ND
-------
SUMMARY OP RESULTS
Depth
Sample Lab Date Saapled
ID ID Taken (Ft)
SMW12 F9143 1/11/85 36.0-43.0
SN13B J23SO 7/19/85 45.0-46.0
SM13B J2351 7/19/85 45.0-46.0
OOP
SMH14 C5076 2/1/85 13.0-20.0
SMW16 C8383 2/20/85 40.0-42.0
CHEMICAL ANALYSIS OF MONITORING WELL SOILS
Volatile Fraction Acid Fraction Base/Neutral Fraction Metala/Cranldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
MD MD NO ' Aa
Be
Cr
Cu
Pb
Nl
Zn
ND ND ND Aa
Ba
Cr
Pb
ND ND ND Aa
Ba
Cd
Cr
Pb
ND
0.5
0.07
2
I
1
I
0.5
0.4
4.0
0.5
1.0
0.4
4.0
0.5
I
O.I
0.4
2
0.6
I
0.8
0.2
I
8
2
0.1
DL - Detection Llailt
ND - Not detected
(b) - Qualified due to hold tlate ezceedancea
SMW12 - Soil from monitoring well '12
-------
SUMMARY OP RESULTS
CHEMICAL ANALYSIS OF MONITORING WELL SOILS
Saaple Lab
ID ID
Date
Taken
Depth
Sampled
(Ft)
Volatile Fraction
Acid Fraction
Co*pound
Cone.
(ppb)
DL
(ppb)
Bage/Neutral Fraction
Compound
Cone.
(ppb)
DL
(ppb)
Compound
Cone.
(ppb)
DL
(ppb)
Metala/Cyanldea/Phenola
Cone. DL
Compound (ppn) (pp>)
SMW16B G8385 2/20/85 60.0-62.0
ND
ND
ND
Aa
Ba
Cr
Pb
Cu
1.4
25
7
2.3
10
I
0.3
0.8
0.6
I
DL - Detection Ll«lt
ND - Not detected
(b) - Qualified due to hold tl*e exceedancea
SMW16B - Soil fro* Monitoring well '16, location B
-------
Table 2
SUMMARY OP RESULTS
CHEMICAL ANALYSIS OP LEACHATE SAMPLES
Sample Lab
ID III
CLl PJ098
CL2 P9103
CL3 P9097
CL4 P9093
CLS P9094
Date
Taken
12/12/84
12/12/84
12/12/84
12/12/84
12/12/84
Depth
Saapled
(Pt)
MA
MA
MA
MA
MA
Volatile Practloa Acid Fraction
Cone. DL Cone.
Compound (ppb) (ppb) Compound (ppb)
ND ND
ND ND
ND ND •
Ethyl- 21 10 ND
benzene
•' i
Toluene 25 " 10
ND ND
Baae/Neutral Fraction Metals/Cyanldea/Phenols
DL Cone. DL
(ppb) Compound (ppb) (ppb) Compound
ND ND
ND Pb
Zn
ND ND
ND Nl
Zn
Phenol*
ND Pb
Cone. . DL
(ppb) (ppb)
8
70
30
180
110
7
5
10
20
10
50
5
DL - Detection Ll»tt
ND - Not detected
BMDL - Below *ethod detection ll»lt
NA - Not applicable
CLl - Leachate aaaple fro* location 01
-------
Table 3
SUMMARY OP RESULTS
Sample
ID
RSW1
RSW2
RSW3
RSW3S
RSW4
RSW5
RSV5D
Lab
ID
F9100
F9099
P9096
P9105
P9104
F9102
P9107
Date
Taken
12/2/84
12/12/84
12/11/84
12/11/84
12/11/84
12/11/84
12/11/84
Depth
Sampled
(Ft)
NA
NA
NA
NA
NA
NA
NA
CHEMICAL ANALYSIS OF SURFACE WATER
Volatile Fraction Acid Fraction Base/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone.
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb)
ND HD NO
NO HD NO
ND ND bls(2- 47*
ethyl-
heiyl
phthalate
ND ND ND
ND ND ND
ND ND ND
ND ND ND
DL Cone. DL
(ppb) Compound (ppb) (ppb)
ND
Zn 30 10
10 ND
ND
ND
Pb 10 5
Pb BMDL 5
NA - Not applicable
DL - Detection limit '
BNDL - Below Method detection limit
ND - Not detected
* - Compound alao present In lab reagent blank. Therefore actual presence and/or quantification la questionable.
RSWl - Surface runoff stream aaaple ll
-------
Table *
SUMMARY OP RESULTS
Depth
Saaple Lab Date Sampled
ID ID Taken (Ft)
BSEDl F9134 12/12/84 Surface
BSCD2 K9133 12/12/84 Surface
BSB03 P9132 12/11/84 Surface
CHEMICAL ANALYSIS OF SEDIMENT SAMPLES
Volatile Fraction Acid Fraction Baae/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
Methylene 60* 10 ND ND Aa
chloride Be
Cr
Cu
Pb
Nl
Zn
ND(b) ND ND Aa
Cr
Cu
Pb
Nl
Zn
MD ND ND Aa
Cr
Cu
Pb
Nl
Tl
Zn
Cone.
1.4
0.8
6
9
9.3
4
83
2.9
11
6
6.9
3
83
0.7
7
6
10
4
0.5
45
DL
(Ppa)
0.5
0.5
1
I
I
1
I
0.5
I
1
0.5
1
I
0.5
I
I
0.5
I
0.5
1
ND - Not detected
DL - Detection limit
BMDL - Below Method detection Halt
(b) - Qualified due to hold tl«e ezeeedancea
• - Compound alao preaent la lab reagent blank.
BSEDl - Surface runoff atreaa aedl*ent tl
Therefore actual presence and/or quantification la questionable.
-------
SUMMARY OF RESULTS
Depth
Saaple tab Date Sampled
ID ID Taken (Ft)
BSED3S F9131 12/11/84 Surface
BSED4 F9128 12/11/84 Surface
BSED5 F9130 12/11/84 Surface
BSED5D F9129 12/11/84 Surface
CHEMICAL ANALYSIS OP SEDIMENT SAMPLES
Volatile Fraction Acid Fraction Baae/Neutral Fraction Metala/Cyanldea/Phenola
Cone. DL Cone. DL Cone. DL
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound
ND ND ND As
Be
Cr
Cu
Pb
Nl
Zn
ND ND ND * Aa
Cr
Cu
Pb
Nl
Zn
ND(b) ND ND Aa
Cr
Cu
Pb
Nl
Zn
ND
2.3
0.6
7
7
13
4
51
1.0
5
6
7.9
3
65
1.4
4
5
7
3
56
4
1.3
8
5
7
4
100
DL
(PP»)
1
0.5
I
1
0.5
I
I
0.5
I
I
0.5
I
I
0.5
I
I
0.5
I
1
0.5
0.5
I
I
0.5
1
I
DL - Detection Halt
ND - Not detected
NA - Not applicable
BMDL - Below act hod detection Halt
(b) - Quail-fled due to hold tiae exceedancea
BSED3 - Surface runoff atreai aedlaent 13
-------
Table 5
SUMMARY OP RESULTS
Depth
Sample Lab Date Sampled
ID ID Taken (Pt)
HMW6 J2150 7/12/85 NA
HMH7 J2140 7/19/85 NA
HMH8 J2141 7/12/85 NA
HHW9 J2142 7/23/85 NA
HMHIO J2143 7/23/85 NA
HMHll J2147 7/19/85 NA
CHEMICAL ANALYSIS OP MONITORING HELL HATER
Volatile Fraction Acid Fraction Base/Neutral Fraction Metala/Cyanldes/Phenols
Cone. DL Cone. DL Cone. DL Cone.
Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb) (ppb) Compound (ppb)
ND ND ND NO
ND ND ND Zn 50
Phenols 150
ND ND ND Zn 30
ND*b) ND ND ND
Methylene^W.l* 2.8 ND ND Nl 40
chloride
ND ND bl*(2-ethyl- 93.8* 10. 0 Phenols 120
hexyl)
phthalate
Dl-n-butyl 13.4* 10. 0
phthalate
DL
(ppb)
20
50
10
30
50
(•) - Sample lost during sanple prep.
DL - Detection limit
ND - Not detected
BMDL - Below Method detection 11*1t
NA - Not applicable
(b) - Qualified due to hold time exceedances
* - Compound alao present in lab reagent blank.
HMW6 - Hater from Monitoring well 16
Therefore actual presence and/or quantification is questionable.
-------
SUMMARY OP RESULTS
Depth
Saaple Lnb Date Saapled
ID ID Taken (Ft)
VMU12 J2138 7/23/85 NA
HMW13 J2144 7/30/85 NA
WMW14 J2139 7/23/85 NA
HMW15 J2148 7/26/85 NA
VMH16 J2145 7/26/85 NA
WMH16 J2149 7/26/85 NA
DUP
CHEMICAL ANALYSIS OF MONITORING WELL HATER
Volatile Fraction Acid Fraction Base/Neutral Fraction Me tain/Cyan Ides/Phenols
Cone. DL Cone. DL Cone.
Coapound (ppb) (ppb) Coapound (ppb) (ppb) Coapound (ppb)
ND 100
11
2.0
10 Phenola 93
DL
(ppb)
25
50
I
10
9
20
30
50
50
(a) - Saaple loat during Maple prep.
DL - Detection Halt
ND - Not detected
BMDL - Below aethod detection Halt
NA - Not applicable
(b) - Qualified due to hold tlae ezceedances
* - Coapound alao preaent In lab reagent blank. Therefore actual preaence and/or quantification la questionable.
WMWl2-Vvt>terfroa aonltorlog well '12
-------
Table 6
SUMMARY OF RESULTS
CHEMICAL ANALYSIS OP POTABLE HATER SAMPLES
Saaple
ID
WPWl
WPW2
WPW3
VPW4
WPWS
WPW6
WPU7
WPWS
WPW9
WPWIO
Lab
ID
P9U6
F9122
P9095
P9120
P9127
F9117
F912S
P9121
F9114
P9124
Date
Taken
1/8/85
1/8/85
1/8/85
1/8/85
1/8/85
1/9/85
1/9/85
1/8/85
1/8/85
1/9/85
Depth
Sampled
(Pt)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Volatile Fraction Acid Fraction
Cone.
Compound (ppb)
ND
ND ,
ND
ND
Methylene 20*
chloride
Trlchloro- 98
ethylene
ND
ND
ND
ND
ND
DL Cone .
(ppb) Compound (ppb)
ND
ND
ND '
ND
1
10 ND
10
ND
ND
ND
ND
ND
Base/Neutral Fraction Metals/Cyanldea/Phenola
DL Cone.
(ppb) Compound (ppb)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
DL
(ppb) Compound
Zn
or
CN~
CN~
Cu
Zn
CN-
Zn
CN-
ND
ND
Zn
CtT
Zn
CN~
Se
Zn
Cone.
(ppb)
40
35
32
38
70
50
34
440
30
770
34
40
35
6
90
. DL
(ppb)
10
25
25
25
20
10
25
10
25
10
25
10
25
5
10
DL - Detection limit
ND - Not detected
NA - Not arallable
* - Compound alao present In lab reagent blank. Therefore actual presence and/or quantification la questionable.
WPWl - Potable well aaaple *l
PW5 was resampled by NJDEP; no contaminants were detected.
-------
APPENDIX 2
Responsiveness Summary
Completion of Remedial Investigation/Feasibility Study
Combe Fill North Landfill
Mount Olive Township
Morris County
-------
This Combe Fill North Responsiveness Summary documents the concerns of the public
and the Department's responses that were expressed during two public meetings and
the public comment .period. Meetings were held at the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) and at the conclusion of the RI/FS. This
Responsiveness Summary is prepared in three sections:
I. RI/FS Initiation Meeting - October 2, 1984
II. RI/FS Completion Meeting - July 1, 1986
Questions/Comments received during the public meeting and
comment period, and NJDEP's Responses
III. Remaining Concerns
Attachments
A. Information Package for 10/2/84 Public Meeting
B. List of Attendees at the 10/2/84 Public Meeting
C. Information Package for 7/1/86 Public Meeting
D. List of Attendees at the 7/1/86 Public Meeting
E. Correspondence to NJDEP from Schwartz, Tobia
& Stanziale
-------
I. RI/FS Initiation Meeting
A public meeting was held by the New Jersey Department of Environmental
Protection (NJDEP) on October 2, 1984 to discuss the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) for the Combe Fill North Landfill.
Notification of the meeting was accomplished through press releases sent to all
newspapers listed in the "Contacts" section of the Community Relations Plan.
Meeting notices were also sent directly to all residents and officials listed in
the Community Relations Plan. An information package (Attachment A), including
an agenda, fact sheet, overview of the community relations program at Superfund
hazardous waste sites, and the steps involved in a major hazardous waste site
cleanup, was distributed to everyone at the beginning of the meeting. The
meeting was attended by approximately 30 people including local and state
officials (Attachment B). Dr. Jorge Berkowitz, Administrator for Hazardous Site
Mitigation Administration, made opening remarks and introductions. Ms. Grace
Singer, Chief of the Bureau of Community Relations, gave an explanation of the
community relations program. Mr. Edgar Kaup, Site Manager, presented a site
overview and introduced the contractor. Mr. Gary Cusack of Envirosphere Company,
Division of Ebasco Services, Inc., made a presentation on the scope of work for
the RI/FS. The meeting was then opened for discussion.
After the presentation there were several questions and comments regarding the
RI/FS. Following is a summary of the questions/comments and responses.
Question: What is the time frame for this project (RI/FS)?
Response: Optimistically, it is 36 weeks.
months to complete.
Realistically, it will take 9 to 12
Comment: Mount Olive Township needs this landfill closed expeditiously and in a
practical manner. Another study that does not accomplish this would be
a disaster. Our files, studies, etc. are available. We will cooperate
in any way possible.
Response: The primary task is to evaluate all existing data. Whenever NJDEP has
evidence of a public danger, we can use emergency resources. We do not
have to wait until the study is completed. Thus far, we have not seen
a public danger. The RI/FS and cleanup process will be Implemented as
planned.
Question: How far to the east and west of the landfill will you be testing for
water contamination?
Response: At this time the exact distance is unknown. We will test as far as
required in order to define the plume of contamination.
Question: Could there be a correlation between the coliform contamination in my
potable well and my son's hepatitis?
Response: The likelihood is close to nil.
-------
Question: We are presently at step #9 (hiring of contractor for RI/FS) according
to the steps involved in a major hazardous waste site cleanup. How
long will it take to complete the process (through step //15)?
Response: It will" take approximately 9-12 months to get to step //ll (selection
of remedial action alternative). The engineering design will take
approximately 6-9 months. The time frame required for actual cleanup
will depend on what is found during the RI/FS.
Question: What is the direction of flow of the plume?
Response: It is believed to be in the NW direction, but is not yet actually
defined.
Question: Has there been consideration of an on-site laboratory capability?
Response: There is constant monitoring during on-site work so that we can take
immediate safety measures if necessary. On-site laboratories are
biased, site specific, and not quality controlled. They have been
tried in the past but the preferred method is to send samples to a
laboratory to assure quality control of the data.
Question: Is there a contingency plan? Is there a mechanism for notifying the
public in case of volatile air emissions?
Response: The health and safety plan includes an emergency response section
which addresses evacuation procedures, notification procedures, etc..
We are very willing to share this plan and will make it available to
the local fire department, police department and officials.
Question: Are there any resources to address health impacts to Mt. Olive Township
residents, especially those in close proximity to the landfill?
Response: New Jersey has a program for such residents. Anyone who feels
impacted can go to a New Jersey Department of Health Clinic and consult
with an occupational physician.
Question: How many landfills has Ebasco closed? How effective are these plans?
Response: Remedial action is different from closure. Closure is when the
facility has outlived its usefulness and is closed according to
environmentally safe standards to ensure no leakage. Remedial action
identifies and eliminates the source(s) of contamination now and in the
future. This is not classically called closure. After we develop a
remedial action plan we must monitor the site for many years. There
are a lot of tried and proven methods of treatment and remedial action
here and throughout the world.
Question: Do all such plans involve a cap?
Response: No, sometimes a cap is not an acceptable alternative. .But there have
been good results when caps were utilized. There must be a long-term
commitment to the site.
-------
Question: Can a cap be placed on the landfill immediately?
Response: No, a hazardous waste site can not be capped until a Remedial
Investigation/Feasibility Study has been completed so that we know what
contaminants need to be remediated, as well as the most appropriate
cleanup "alternatives. A cap would be considered in the evaluation of
cleanup options for this site, along with other technologies to remedy
the problems.
Comment: I would like to see a list of criteria for this.
Response: That's our legislative mandate. We do not have to reiterate that
purpose. That is the reason we exist (i.e. DEP's legislative mission).
Question: After the study is complete, will we be able to use the site for
anything?
Response: That depends on the findings from the RI/FS. That is a site specific
issue and we are wrestling with this issue now. It is possible that
many sites will be useable in the future.
Question: Do you have an overall plan for post implementation/monitoring?
Response: Yes, we will be involved in monitoring, as well as operations and
maintenance. It is too early to have specifics, until more is known
about what is in the landfill and the selected remedial action plan.
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II. RI/FS Completion Meeting
A second public meeting was held by NJDEP on July 1, 1986 to discuss the results
of the RI/FS for the Combe Fill North Landfill. Notification of the meeting was
accomplished by sending press releases to local and county newspapers, as well as
notices to municipal, county, state and federal officials and to all concerned
citizens. The RI/FS Report was made available for public review and comment
starting June 12, 1986 at the following repositories: Mt. Olive Municipa
Building, Mt. Olive Public Library, Hackettstown Free Public Library, Morris
County Library in Whippany and the NJDEP in Trenton. The public comment period
extended until July 16, 1986 during which time only one written comment was
received by the Department. An information package (Attachment C), including the
agenda and fact sheet, was distributed to all attendees at the commencement of
the meeting. In addition to the NJDEP representatives, approximately 30 people
were in attendance (Attachment D). Mr. Anthony Farro, Assistant Director for the
Division of Hazardous Site Mitigation, made opening remarks and introductions.
Next, Mr. Edgar Kaup, Site Manager, provided an historical overview and a current
status report. Mr. Joseph Cleary of Ebasco Services, Inc. discussed the results
of the RI/FS and presented the following remedial action alternatives for
long-term site remediation:
1. Construction of a security fence around the perimeter of the site and a
long-term (30-year) monitoring program.
Ib. Sanitary Landfill Closure: Sanitary landfill closure in accordance with
RCRA (Resource Conservation and Recovery Act) subtitle "D" and New Jersey
Solid and Hazardous Waste Management regulations. Perimeter security
fencing and a long-term monitoring program.
2a. Alternative Water Supply: Creation of a new well field and source of water
for the potentially affected communities downgradient of the site. The
water supply system would include four wells in the limestone formation
aquifer located approximately three miles south of the landfill. Sanitary
landfill closure as described in Alternative Ib. Perimeter security fencing
and a long-term monitoring program.
2b. Treatment of Existing Water: This entails upgrading the existing water
treatment systems at three locations: Village Green Apartments, Netcong and
Stanhope. The treatment system would include a combined air
stripping-carbon absorption system for removal of organic priority
pollutants. Sanitary landfill closure is also included in this alternative.
Perimeter security fencing and a long-term monitoring program.
3. Surface Water Control (RCRA Cap) and Alternative Water Supply: A RCRA cap
in accordance with RCRA Subtitle "C" requirements, as well as an alternative
water supply. Perimeter security fencing and a long-term monitoring
program.
4. Surface Water Control (RCRA Cap) and Ground Water Diversion Barrier: A RCRA
cap and a slurry wall upgradient of the site which would divert ground water
flow around the landfill minimizing leachate generation and the potential
for ground water contamination. Perimeter security fencing and a long-term
monitoring program.
5. Surface Water Control (RCRA Cap) and Leachate/Ground Water Control: A RCRA
cap and a series of ground water extraction wells downgradient of the
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landfill to intercept and treat any ground water contamination leaving the
landfill. The treated ground water would be discharged to one of the
unnamed tributaries to Wills Brook. Perimeter security fencing and a
long-term monitoring program.
6. On-site Disposal in RCRA Landfill: Excavation of the solid wastes and
on-site disposal in a secure RCRA Landfill. The RCRA landfill would include
a cap and a double liner system. This alternative would also include the
removal and disposal of any hazardous wastes or drums discovered during the
excavation of the landfill. :
Mr. Anthony Farro presented Alternative Ib as NJDEP's recommendation for
long-term site remediation. The meeting was then opened to the public for
comments and questions. Following is a summary of the questions/comments and
responses.
II. Questions/Comments Received During the Public Meeting and Comment Period,
and NJDEP's Responses
Question: How can Alternative Ib be proposed when you know there are two
interconnected aquifers below the landfill?
Response: We have run several analyses on the aquifer and our testing has
indicated that no contaminants have left the site via the aquifer.
Comment: SMOTHER conducted tests that revealed selenium and other organic
chemicals on and off site. These were not shown in your presentation
of contaminants found during the Remedial Investigation.
Response: We sampled approximately 1*5 years ago and did not find those
contaminants. It is possible, however, that they were present at the
time of your sampling. When we developed the study, we Were
knowledgeable about your study and about six other studies that
indicated the presence of contaminants. However, we did not rely on
these studies because of the various methodologies employed (i.e.
sometimes samples were taken from one well, or from three wells, or
from one well three times per year). Different laboratories have
different quality assurance/control requirements. None of the previous
studies used stainless steel wells; some were pc pipe and some were
cast iron pipe. There are localized contaminants that can be picked up
during sampling. We have addressed these sampling issues and did not
find contaminants during the course of the remedial investigation.
Question:*How many times did you take samples? It is ludicrous to base the
results of the RI/FS on one set of gas chromotography GC samples at one
point in time.
*There was concern about the adequacy and integrity of sampling and considerable
dialogue before a complete answer was given. This issue and the correct
response became confused and somewhat lost during the discussion at the public
meeting. Therefore, this account extracts and summarizes the concerns and
responses that may not be apparent in reading the transcript. Unfortunately,
the complete answer appears in several pages following the question in the
transcript.
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Response: We looked at the results of 65 samples and did not see any
contamination. We went back and resampled several monitoring wells.
However, we did not discuss this additional sampling because our
quality assurance/control program rejected the analysis of the base
neutral .fractions and, therefore, discarded the entire set of data. It
is relevant to know that the volatile organic analyses were acceptable
and did not indicate contamination. Additionally, we are going to
conduct another round of sampling at the site.
One complete round of samples did meet our standards. The quality
assurance/control program is one that allows us to authenticate the
data. We are confident that the data is representative of what
contaminants are present at the site. You can sample a site
indefinitely and get different results each time. We will be backing
our decision by our monitoring program.
Explanation of Sampling: We
pits. These were not taken
wells and stabilized them
stainless steel wells is to
contamination. All samples,
approximately ten different
the 65 samples taken during
we did not see contaminants.
the results of the study.
took saturated soil samples from 12 test
on the same day. We then developed the
for 72 hours. The purpose of having
be able to detect the minutest level of
including the water samples, were taken on
days over a two-month period. In all of
the two months of sampling various media,
This methodology should more than justify
Comment: We tested an area directly across the street from the landfill and
detected 4,000 + ppb of practically everything. According to your map
that is upgradient on the other side of Goldmine Road. Redi Crete has
a well that is 285 feet deep and the surface is lower than the highest
point in the landfill by 40 or 50 feet.
Response: It is not upgradient according to ground water flow patterns. Our
deep wells are at the same depth as area potable wells. The upgradient
monitoring well is about 160 feet deep. The downgradient well is about
100 feet deep. Again, these wells are in the same aquifer which
supplies area potable wells.
Comment: There may be an underground stream and some of that leachate is
dropping down not into the plume but into an underground stream and
affecting an upgradient site, such as Redi Crete.
Response: We had three upgradient wells; one on Flanders Road and two on site.
Comment: Redi Crete, however, is in the southwest corner almost % mile away.
You did not drill a well or take samples down there.
Response: There was no need to do so because we found that ground water was not
moving in that direction.
Question: Did you sample Redi Crete and detect any contaminants? There is
off-site contamination.
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Response: Yes we did sample and found low level contamination but we do not know
the source. Our report indicates that there is potential for off-site
contamination. If there was a plume leaving this site, we would not be
recommending Alternative Ib. There is no such evidence at this time.
I cannot spend public monies based on the assumption that there will be
a problem ten years from now.
Comment: What you are proposing does nothing to mitigate leachate going into
the aquifer. It will stop rain water from going through the landfill
but that is all.
Response: Our plan will minimize, if not stop, ground water or the plume from
leaving the site. To date no contaminants related to the site are
leaving the landfill. I cannot spend an additional $20 million because
there may be a slim chance that contaminants are going to migrate off
site. Our recommended alternative is environmentally sound, not just
cost effective.
Question: Why spend $10 million to cap a dump when only $13 million would
provide water to 10,000 residents?
Response: If there was proof that area potable wells are being impacted, we
would be recommending a water line. The landfill has not contaminated
the water supply. Therefore, the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) law and regulations
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Response: There are no records of what was dumped at this site.
Question: Will the gasoline tank located in the landfill be removed?...before
capping?
Response: Yes, the underground storage tank will be removed during grading.
Question: Is there a way to know what contaminants are in the landfill?
Response: You can not be totally sure but you can monitor for what is suspected
to be in the landfill. '-
Question: What are the depths of the monitoring wells?
Response: There are three deep wells (ISO1, 100' and 86') and six shallow wells.
Comment: Geologically this is a rather unique area. We are In the Reading
Prong (on the Schooley's Mountain klippe) which is nothing more than
gneiss (ranging 200-330 feet) over limestone. The limestone is the
extremely porous lithosil type. It looks like solidified sponge. My
potable well is about 350 feet deep and probably is in the limestone.
Your report discusses a well system which will draw from the limestone.
The Musconetcong River Valley is limestone, Flanders Valley is
limestone and I have a feeling that the limestone runs all the way in
between. My concern is that fractured gneiss is above the limestone
and that a plume may exist undetected by your ground water monitoring
wells. I would like you to check this with a seismograph study to see
if, in fact, limestone is under there.
Response: I think our geologist's opinion would be that the gneiss is so dense
that it can not be penetrated. During the course of drilling the ISO
foot upgradient well we hit very tight bedrock gneiss and we had to use
a cable tool drill to get through it. (Subsequent discussion with the
staff geologist indicates his opinion that although limestone was found
to the north and to the west of the site, limestone does not underlay
the site. The only absolute method to determine whether limestone is
there is to do a boring to that depth.)
Comment: My concern is not regarding a depth of 150 feet but that limestone is
at 200-300 feet. If it is in fact lithosil limestone, it is very
porous. You should act quickly.
Response: We will consider a seismograph study. The opinion of the project
geologist (based on a follow-up discussion of this issue) is that a
seismographic survey would not detect whether there is limestone
beneath the dense, granitic rock layer.
Question: Is there a possibility that this landfill will be opened again?
Response: I don't think that someone is going to recommend opening a National
Priorities List (NPL) site that we are basically closing. However,
there is no guarantee that this will not happen sometime in the future.
I tend to think that it will not happen. I am sure that you fought it
before and that you would fight it again and probably win.
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Comment: My well is polluted with contaminants that have not been found in the
landfill. My family has a long history in Mt. Olive. Our property is
all farm land and I know my relatives did not dump any pollutants on
this property. Can anything be done to determine the source of
contamination?
Response: During the past 40-50 years many pesticides and chemicals have been
used in the farming industry. There have been cases where these
pesticides and insecticides have been found in wells. Regarding the
area potable wells* the Division of Water Resources has been and will
continue to investigate this to determine a source. If sampling
indicates that there are levels of contaminants exceeding the drinking
water standards, I am sure that the Department will take action. We
are familiar with your particular case and know that the Bureau of Safe
Drinking Water is investigating this matter.
Comment: When the landfill was in operation, there was a leachate spill that
ran down through my pond and killed all my fish. Subsequently the
owners built a berm adjacent to and around my property. The berm has
deviated surface runoff collected to the south of my property into the
Wills Brook which runs into the Musconetcong River. The berm is the
only thing that protects my property from the leachate. If you build a
fence between my property and the berm, there must be a gate so that I
can gain access in order to maintain the berm (as I am the only one who
has maintained it for the past 11 years).
*
Response: Once the cap is constructed, it will prevent water from percolating
through the landfill and generating more leachate. We understand that
your concern is for the interim period. We "did a risk assessment based
on leachate analysis from five samples which indicate that it presents
no health risk. The fish .kill was probably due to the overutllization
of oxygen by the organic material in the leachate which entered the
pond, thereby not leaving enough oxygen for the fish. There is also a
lot of iron in that leachate, causing the orange stain. The likelihood
of this happening was much greater ten years ago than it is now. Much
of the readily utilizable organic material in the landfill is already
decomposed. Most landfills reach a peak of fertile activity in a
period of three to five years. The engineering design will begin in
four to five months and will take approximately 9-12 months to
complete. Construction will start four to five months thereafter.
Construction may be phased so that the leachate problem will be
addressed right away. That is something that we will have to look
into.
Question: From this time (July 1986), how long will it be before the entire
project is completed, other than monitoring?
Response: About 2*$ to 3 years.
Question: Will this project be funded through its completion (in light of the
fact that it is #36 on the NPL and the contamination is much less that
suspected)?
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10
Response: Once a study is initiated New Jersey is committed to complete all
projects through construction. The ranking of a site does not
influence whether a project is completed. The state has and will offer
USEPA the funding to complete this project, if necessary. The
Department has developed a funding plan that will take us through
Federal FY '87 and we are seeking additional funding to get us past
that earmark.
Question: Is the "heat off" Combe Fill North to the extent that the timing of
the cleanup will be affected?
Response: No, the Department has committed to funding this project, regardless
of its ranking. We will proceed at the same rate.
Question: When are you next scheduled to conduct monitoring?
Response: We will sample during the design phase. The full monitoring program
will be initiated during construction and conducted throughout and
after construction. Because of the concern expressed there should be
some monitoring between now and the start of construction.
Question: How many permanent test wells are there?
Response: Eleven.
Question: How much will it cost to do one more round of sampling of these 11
wells?
Response: Approximately $1,500. per sample.
Question: This question pertains to the concerns of the people who want more
tests over a longer time period. Will more sampling take place and
when?
Response: There will be 11 samples (9 ground water & 2 leachate) taken in July
1986. Results will be made public in September, after the data is
determined to be valid by our quality assurance/control program.
(Sampling was conducted on August 14, 1986).
Question: What is the maximum distance from the landfill that you tested potable
wells?
Response: Approximately one mile.
Question: What is being done to identify off-site contamination in potable
wells? What kind of assistance can you give these residents? If there
is a source somewhere else, we should investigate and deal with it.
Response: I have been told that some of the wells are periodically tested. This
is not being handled by the Division of Hazardous Site Mitigation so I
do not know the details. I will look into this and get back to you.
(Correspondence was sent from the Division of Hazardous Site Mitigation
to the Division of Water Resources (DWR) requesting that this issue be
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11
directly addressed. Subsequent inquiries of this nature are being
referred to DWR.)
Question: What good will it do if the results of the July sampling are not
available until after the decision on the selected cleanup alternative
has been made?
Response: Design work will not start for another four to five months. If the
results of the July sampling disprove what we are presenting tonight,
there is no reason why we cannot change the "Record of Decision".
Question: Can you be more precise about the on and off-site monitoring program?
Response: It has not yet been developed. We will make it available to the
public when it is complete. You may comment on it. It will be
designed to give us an early warning signal for movement of a suspected
plume.
Comment: Yes, we would like to receive it and perhaps have a public hearing on
it. We will give you our input quickly.
Question: Would you buy a property near this landfill?
Response: From an environmental perspective, yes. In terms of health risks,
based on our studies of a one in a million cancer risk level, there is
no danger in living near this landfill.
Question: Can you guarantee that it is safe to live by or near this landfill?
Response: No guarantees can be made. There is always a potential risk.
Question: There were only ten potable wells tested. Where are these ten wells
located and is there a reason why you stopped at ten?
Response: It was a matter of judgement. We selected ten wells in the suspected
direction of ground water flow. These should be representative of the
area's potable water quality.- Had we found contaminants similar to
those in the landfill, we would have extended our testing an additional
2,000 or 2,500 feet.
Question: Is there a possibility of leakage, rather than a plume, that may have
gone beyond the 1% mile area that was tested and is causing a greater
problem beyond this area?
Response: Based on our findings, we feel that we have tested all the wells that
may be impacted by this site.
Question: Will additional potable wells be tested for contamination by the
Division of Water Resources to try to determine the source of
contamination?
Response: It is my understanding that some sort of study is being done. I will
look into it. Also, I will talk with our geologist concerning the
area. Additional work will be done, if necessary.
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12
Question: Will the landfill ever be usable for recreational purposes?
Response: I cannot answer that question now. It may be possible at some point
in the future. I can not address that because the funding is for
remedial action, not recreational purposes.
Comment:* It appears that the present worth for Alternative IB, which
includes estimated capital cost of $10.5 million and annual operation
and maintenance costs of 1.6 million, is excessive in light of the work
to be performed.
Response: The capital cost of Alternative IB is primarily the sanitary landfill
cover. The capital cost of this alternative is $3.70/square foot based
on 65 acres which is within the range of reported costs for this type
of cover. To clarify the operation and maintenance, the $1.6 million
is not an annual cost but the present worth of the annual operation and
maintenance for 30 years at an interest rate of 10 percent. The annual
operation and maintenance costs in 1986 dollars is $167,800/year.
Comment: Is a clay cap preferable or necessary for the site in light of
increased acceptance of H.D.P. Geomembranes?
Response: Alternative IB includes a cap consisting of one foot of clean soil, one
foot of clay and one foot of topsoil. The clay provides an impermeable
barrier to the percolation of water vertically through the solid
wastes. Clay is the most common type of cover used for solid waste
landfills, particularly for sanitary landfills. The H.D.P.
Geomembrane, a thin (40 mils) high density polyethylene synthetic
membrane, was included in Alternatives 3,4,5 and 6 (RCRA cap) together
with two feet of clay cover. The synthetic liner by itself is not
appropriate for solid waste landfills due to the potential for puncture
when in contact with solid waste materials such as glass and metal
objects. The synthetic liner would require one foot of sand as bed
material and two feet of sand as protection material thereby making
this cover more expensive then that proposed in Alternative IB. In
addition, a synthetic liner is susceptible to attack by organic vapors,
gas, and damage - by fire which are the common problems of sanitary
landfills.
Comment: The Ebasco report is inconsistent in terms of the amount of clay
required for the proposed clay cover.
Response: Alternative IB incorporates one foot of clay cover, not two feet. The
one foot of clay is shown in the report in Figures 2-1 and 3-2, Table
3-2, as well as discussed in various sections of the report. It should
be sufficiently clear from reviewing the report that 1 foot of clay
cover is proposed. However, Table A-l, which summarizes the screening
evaluation of alternatives conducted prior to detailed evaluation and
cost estimating, may create some confusion in that two feet of clay
liner is identified which should be one foot of clay and one foot of
soil. However, the cost of clay and soil was assumed to be the same
and therefore the cost shown in Table A-l is correct. Table A-l will
be changed in the final report to indicate one foot of clay plus one
foot of soil.
*The following comments were received in correspondence from Schwartz, Tobia &
Stanziale (See Attachment E).
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. 13
Comment:
Response:
Comment:
Response:
Comment:
Response:
The site investigation report appears to conclude that the Combe Fill
North Landfill did not accept hazardous waste nor is it a hazardous
waste site, thus seriously questioning its status as a "Superfund" site
requiring special treatment. In fact, it should be delisted and/or
closed as a solid waste facility.
Even though there is no documented evidence of hazardous waste
disposal at the site, chemical contamination has been detected in
ground water at the site. Since communities downgradient of the site
rely on this potable ground water supply, the site was identified as a
Superfund site based on the studies conducted as part of the Remedial
Action Master Plan (RAMP). The remedial action proposed by the NJDEP
and EPA is consistent with State of New Jersey Solid Waste regulations
for sanitary landfills and is not proposed to satisfy RCRA regulations
for hazardous waste landfills as per the RCRA cap proposed in
Alternative 3.
Clay is not normally included in the drainage ditch surrounding a
landfill cover system.
It is good engineering planning to include a liner in the drainage
ditch design to ensure that any runoff water will not infiltrate back
into the solid wastes and generate leachate. The RCRA guidelines
(subpart 264.301) also recommend that clay cover on landfills be
extended to the surrounding runoff ditch.
One must question the derivation of the figure shown in Table A-l of
$12,000 per acre for grading and compaction and $5500 per acre for
revegetation. . ~ •
These unit costs, which- -were only used in the screening evaluation,
were based on average reported costs presented in the "Compendium of
Costs of Remedial Technologies at Hazardous Waste Sites", EPA Hazardous
Waste Engineering Research Laboratory, Environmental Law Institute
(September 1985), which is identified as Reference 6 in the Combe Fill
North Report. The average costs reported in this reference were
escalated to 1986 prices for the report.
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14
III. Remaining Concerns
There was concern expressed by several residents regarding the potential for
off-site contaminant migration that may at some point in the future impact area
potable wells. The NJDEP will develop a comprehensive monitoring plan that will
be given to Mount Olive Township for review and comment. Additionally, NJDEP
will monitor ground water quality before the start of design, during design and
during construction. These provisions should be incorporated in the Record of
Decision (ROD).
In order to address the concern of residents regarding their potable well
contamination that is not correlated to the Combe Fill North Landfill, the
Division of Hazardous Site Mitigation has apprised the Division of Water
Resources of this issue. Furthermore, the Division of Hazardous Site Mitigation
has requested that the Division of Water Resources meet with affected residents
and elected officials in order to pursue their investigation of the contaminant
sources.
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15
Attachments
A. Information Package for 10/2/84 Public Meeting
B. List of Attendees at the 10/2/84 Public Meeting
C. Information Package for 7/1/86 Public Meeting
D. List of Attendees at the 7/1/86 Public Meeting
E. Correspondence to NJDEP from Schwartz, Tobia & Stanziale
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ATTACHMENT A
MARWAN M. SADAT. P £
DIRECTOR
§tate of ^eui Jersey
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
CN 028. Trenton, NJ. 08625
JORGE H BERKOWITZ. PH D
ADMINISTRATOR
Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
at
. Combe Fill North Landfill
Tuesday, October 2, 1984
7:00 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, NJ
L
'
07 A
•' t • /
. Gracj. Singer, Community ' ^-/ %•'' •'
»^^
Relat! .-,.-. Program Manager, NJDEP \ /-
Mr. L;:'..;ar Kaup, Site Manager, NJDEP
•^y */
1
Mr. Gary "-.: ^.-.k, Envirosphere
Company, Division of Ebasco
r # L' -
Services, Inc. J_ /\ /-
Is An Equal Opportunity Employer
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FACT SHEET
for
•Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
at
Combe Fill North Landfill
Mount Olive Township
Morris County
October 2, 1984
Site Description;
The Combe Fill North Landfill is located on Gold Mine Road
just west of Netcong-Flanders Road in Mount Olive Township.
The landfill site which is located in a fresh-water marshland
covers approximately 102 acres, however, it is estimated that
only 65 acres have been used for the disposal of solid waste.
Surrounding areas Include the residential communities of
Netcong and Stanhope to the northeast and Budd Lake to the
west. There is some agricultural land in the immediate
vicinity. The site is not fenced and there is no
treatment or abatement of the leachate. Substantial amounts
of leachate are generated at the site due to the great
quantity of rain water percolation. Pecords indicate the
presence of asbestos material. The landfill is eroding at a
rapid pace, resulting in increasing amounts of exposed
garbage.
Background;
The Combe Fill North Landfill began operating in 1966 for
the disposal of municipal, vegetative, and industrial
(non-chemical) wastes along with minimal amounts of dry
sewage sludge. Currently the landfill is not in operation,
however, proper State closure procedures have not been
implemented because Combe Fill Corporation filed for
bankruptcy in September 1981. From 1969 to 1978 the landfill
was operated by Morris County Landfill Incorporated. In
September 1978, ownership was transferred to the Combe Fill
Corporation which operated the landfill until January 1981
when the New Jersey Department of Environmental Protection
(NJDEP) denied an expansion request and operations ceased.
NJDEP issued several Notices of Prosecution to the landfill
operators for improper intermediate landfill cover which
resulted in windblown debris on and off site, contact of
solid waste with uncontrolled ground water, and inadequate
leachate control. The results of ground water sampling both
on and off site has indicated the presence of numerous
organic contaminants. The majority of the population
surrounding the landfill depends on private or municipal
ground water wells for their potable water supply.
Over...
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Combe Fill North
-2-
Status; On November 21, 1983, NJDEP signed a Cooperative Agreement with the
United States Environmental Protection Agency to commit $371,800 for a
Remedial Investigation/Feasibility study (RI/FS). In August 1984,
NJDEP awarded the contract for performance of the RI/FS to Ebasco
Services Incorporated of New York City. The scope of work will
involve the following activities:
Evaluation of all available background information, confirmation
of the level of protection to be worn by on-site workers
during investigations, and preparation of a Health and
Safety Plan, Field Sampling Plan and Quality Assurance/Quality
Control Plan for site activities.
Identification, as far as possible, of the type, source and
location of hazardous wastes disposed of at the site.
Determination of the nature, extent and severity of ground water
contamination beneath the site and the surrounding areas.
Determination of the nature, extent and severity of soil
contamination.
. Determination of the nature, extent,and severity of surface water
contamination on site and in the surface streams and water bodies
impacted by the site.
Air monitoring for the determination of the nature and extent of
gaseous emissions.
Selection of remedial response objectives and identification of
alternatives.
Evaluation of alternatives and selection of the most
environmentally sound and cost-effective remedial action.
Development of the conceptual design for the selected remedial
action and preparation of the final report.
NJDEP
9/84
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TASK ACTIVITY NETWORK
COMBE FILL NORTH LANDFILL FEASIBILITY STUDY
TA3K 1
PREINVESTIGATION ACTIVITIES
PROJECT PLANS
TASK 2 SITE INVESTIGATIONS
TASK 4.1
LABORATORY ANALYSIS
TASK 3 SELECTION
OF REMEDIAL RESPONSE
OBJECTIVES A IDENTIFICATION
OF ALTERNATIVES
TASK 4.2A BENCH
SCALE TREATABILITY
STUDY PROGRAM
DEVELOPMENT
TASK 5 EVALUATION
Of ALTERNATIVES
TASK 4.2B
BENCH SCALE
TREATABILITY
STUDY PROGRAM
IMPLEMENTATION
TASK 6 CONCEPTUAL DESIGN
AND FINAL PROJECT REPORT
FINAL
PROJECT
REPORT
-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup at hazardous waste
sites, a Community Relations Program is conducted to receive local input and
to advise local residents and officials about the planned remedial actions at
the three major stages of the cleanup: 1) remedial investigation/feasibility
study 2) engineering design and 3) removal/treatment/construction. Local
briefings and public meetings are conducted with elected officials and
residents and generally take place at:
1) The commencement of a remedial investigation/feasibility study so
that local concerns can be addressed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial action. There is a 30-day comment period after
public presentation of the alternatives during which the feasibility
study is available in local repositories.
3) The engineering design stage to carry out the mandates of the
selected remedial alternative.
4) The commencement of the removal/treatment/construction stage to
advise of the expected physical remedial action.
5) The completion of the remedial action.
In addition to the more formal activities outlined above, there is
generally informal communication with local officials and residents.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a site, community relations activity is conducted by
the relevant State or Federal agency.
In New Jersey, the DEP Community Relations Program is conducted by Grace
Singer, Community Relations Program Manager (609) 984-3141/4892. At Region
II, EPA, the contact person is Lillian Johnson, Community Relations
Coordinator (212) 264-2515.
HS45:ms
5/84
-------
STEPS INVOICED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(I)
Site Identified
and Referred
(5)
Prioritir atIon
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feqsibillty
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
Determination of Lead
Preparation of
Feasibility
Study
(14)
Cleanup Evaluation
(3)
Secure Site
(4)
Site Analysis Evaluation
and Assessment
(7) (8)
CoHminlty Relationa Signing of Contract or
Plan Activated Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Deaign
(15)
Contractor Audit and
«
Close out
New Jersey Department of Environmental Protection
5/84
Over.
-------
ATTACHMENT B-
N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Commencement of
Feasibility Study/Remedial Investigation
at Combe Fill North
Hazardous Waste Superfund Site
Mt. Olive Township, Morris County, New Jersey
Tuesday, October 2, 1984
7:00 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, New Jersey
NAME
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NAME
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N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Commencement of
Feasibility Study/Remedial Investigation
at Combe Fill North
Hazardous Waste Superfund Site
Mt. Olive Township, Morris County, New Jersey-
Tuesday, October 2, 1984
7:00 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, New Jersey
AFFILIATION
ADDRESS
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-------
N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Commencement of
Feasibility Study/Remedial Investigation
i at Combe Fill North
Hazardous Waste Superfund Site
Mt. Olive Township, Morris County, New Jersey
Tuesday, October 2, 1984
7:00 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, New Jersey
NAME
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ADDRESS
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ATTACHMENT C
STATE OF NEW JERSEY
DEPARTMENT OP ENVIRONMENTAL PROTECTION
Division of Hazardous Site Mitigation
Public Meeting
on
Results of
Remedial Investigation/Feasibility Study
at
Combe Fill North Landfill
Mount Olive Township
Morris County
Tuesday, July 1, 1986
7:30 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, NJ
AGENDA
1. Opening Remarks and
Introductions
Mr. Anthony Farro, Asst. Director
Division of Hazardous Site Mitigation
2. Historical Overview and
Current Status
Mr. Edgar Kaup, Site Manager
Division of Hazardous Site Mitigation
3. Presentation: Remedial Investigation/
Feasibility Study
Mr. Joseph Cleary
Principal Environmental Engineer
Ebasco Services, Inc.
4. NJDEP Recommended Alternative
Mr. Anthony Farro
5. Comments & Questions
At this time, the floor will be.open
for comments and questions.
Yr» ./«-/->iT /.i An Kiiua
t'nf>l«\\.-r
-------
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
FACT SHEET
for
Public Meeting
on
Results of
Remedial Investigation/Feasibility Study
at
Combe Fill North Landfill
Mount Olive Township
Morris County
July 1, 1986
Site Description; The Combe Fill North Landfill is located on Gold Mine Road
just west of Netcong-Flanders Road in Mount Olive Township. The landfill site
which is located in a fresh-water marshland covers 102 acres, however, only
approximately 65 acres have been used for the disposal of solid waste. The local
communities of Netcong, Stanhope and Budd Lake are located downgradient of the
site and rely on ground water supplies for potable water. There is some agricul-*
tural land in the immediate vicinity, however, most of the adjacent land is
wooded or wooded marshland. Leachate is generated at the site due to rain water
percolation, and there is no treatment or abatement of the leachate. The
landfill is eroding, resulting in increasing amounts of exposed garbage.
Presently, the site has an entrance gate but is not fenced.
There are two aquifers upgradient of the site which flow to the northwest: 1) a
shallow, unconfined aquifer in the surficial glacial moraine deposits and 2) a
deeper, semiconfined aquifer in the lower portions of the glacial deposits and
upper zone of the gneissic bedrock. The two aquifers are interconnected below
the landfill and become one aquifer.
Background : The Combe Fill North Landfill began operating in 1966 for the
disposal of municipal, vegetative, and industrial (non-chemical) wastes along
with minimal amounts of dry sewage sludge. From 1969 to 1978 the landfill was
operated by Morris County Landfill Incorporated. In September 1978, ownership
was transferred to the Combe Fill Corporation which operated the landfill until
January 1981 when the New Jersey Department of Environmental Protection (NJDEP)
denied an expansion request and operations ceased. Currently the landfill is not
in operation, however, proper closure procedures have not been implemented
because Combe Fill Corporation filed for bankruptcy in September 1981. NJDEP
issued several Notices of Prosecution to the landfill operators for improper
intermediate landfill cover which resulted in windblown debris on and off site,
contact of solid waste with ground water, and inadequate leachate control.
On November 21, 1983 NJDEP signed a Cooperative Agreement with the United States
Environmental Protection Agency (USEPA) for a Remedial Investigation/Feasibility
Study (RI/FS) at the site. In August 1984 NJDEP awarded the contract for perfor-
mance of the RI/FS to Ebasco Services Incorporated of New York City. The cost of
this study is approximately $720,000.
over...
()ppnriunil\ r.'n
-------
-2-
Status; The Draft Feasibility Study was completed in June 1986 and the remedial
action alternatives are presently being evaluated by NJDEP and USEPA. The Report
on the Remedial Investigation/Feasibility Study has been available for public
review and comment since June 12th at the following repositories: • Mt. Olive
Municipal Building, Mt. Olive Public Library, Hackettstown Free Public Library,
Morris County Library in Whippany and the NJDEP in Trenton. The public comment
period extends until July 16, 1986. Comments regarding the study should be
mailed to Janice Haveson, NJDEP, Office of Community Relations, 432 E. State
Street, Trenton, NJ 08625. After consideration of all public comments, NJDEP
and USEPA will determine the most environmentally sound and cost-effective
remedial alternative. In the fall of 1986 a Record of Decision, specifying the
selected long-term cleanup alternative for the Combe Fill North site, will be
signed by USEPA and NJDEP. Of the 97 New Jersey sites on the National Priorities
List, the Combe Fill North Landfill site is ranked 36th.
Summary of Remedial Investigation/Feasibility Study
Objectives; The RI/FS included the following tasks:
0 Identification of the type, source and location of hazardous wastes disposed
of at the site;
0 Determination of the nature, extent, and severity of ground water, soil and
surface water contamination;
0 Air monitoring to determine the nature and extent of gaseous emissions;
0 Identification and evaluation of cleanup alternatives;
0 Evaluation of the most environmentally sound and cost-effective alternative;
0 Development of the conceptual design for the selected remedial action.
Remedial Investigation Results; Several contaminants, at levels below existing
health risk guidelines, were identified during the Remedial Investigation
including:
0 Soil: Lead, Mercury and Methylene Chloride
0 Leachate: Ethylbenzene and Toluene
0 Ground water (Monitoring Wells): Phenol, Phthalate and Cyanide
0 Ground water (Potable Wells): Methylene Chloride, Trichloroethylene and
Selenium
0 Surface water: Phthalates and Lead
The results of the Risk Assessment concluded that the low levels of contamination
detected In on-site monitoring wells do not pose any health risk at this time.
Although the site does not present an Immediate threat to the local ground water
supplies, a potential exists for future off-site contaminant migration
downgradient of the landfill. It is expected that any contaminant migration
would be slow given the slow ground water velocity and the fact that on-site
contaminants have not been detected in any off-site potable wells.
-------
-3-
Remedial Action Objectives of the Feasibility Study; The objectives require the
development of mitigative measures to:
0 Ensure that the potential ground water contamination from the landfill will
not effect the water supply wells downgradient of the landfill site.
0 Prevent leachate from contacting people through surface water migration,
direct contact, or chemical volatilization. It is recommended that
additional ground water sampling be conducted to determine whether there is
the potential for future contaminant release.
Remedial Alternatives for Long-Term Site Remediation; The following alternatives
for long-term site cleanup were identified and evaluated:
0 Alternative 1 - Construction of a security fence around the perimeter of
. the site and a long-term (30-year) monitoring program.
Alternative IB - Sanitary Landfill Closure: Sanitary landfill closure in
accordance with RCRA (Resource Conservation and Recovery Act) Subtitle "D"
and New Jersey Solid and Hazardous Waste Management regulations. Perimeter
security fencing and a long-term monitoring program. r
Alternative 2A - Alternative Water Supply: Creation of a new well field and
source of water for the potentially affected communities downgradient of the
site. The water supply system would include four wells in the limestone
formation aquifer located approximately three miles south of the landfill.
Sanitary landfill closure as described in Alternative IB. Perimeter
security fencing and a long-term monitoring program.
Alternative 2B - Treatment of Existing Water: This entails upgrading the
existing water treatment systems at three locations: Village Green Apart-
ments, Netcong and Stanhope. The treatment system would include a combined
air stripping-carbon absorption system for removal of organic priority
pollutants. Sanitary landfill closure is also included in this alternative.
Perimeter security fencing and a long-term monitoring program.
'•- . • 'V
Alternative 3 - Surface Water Control (RCRA Cap) and Alternative Water Supply:
A RCRA cap in accordance with RCRA Subtitle "C" requirements, as well as an
alternative water supply. Perimeter security fencing and a long-term
monitoring program.
Alternative 4 - Surface Water Control (RCRA Cap) and Ground Water Diversion
Barrier: A RCRA cap and a slurry wall upgradient of the site which would
divert ground water flow around the landfill minimizing leachate generation
and the potential for ground water contamination. Perimeter security
fencing and a long-term monitoring program.
Alternative 5 - Surface Water Control (RCRA Cap) and Leachate/Ground Water
Control: A RCRA cap and a series of ground water extraction wells down-
gradient of the landfill to intercept and treat any ground water
contamination leaving the landfill. The treated ground water would be
discharged to one of the unnamed tributaries to Wills Brook. Perimeter
security fencing and a long-term monitoring program.
over...
-------
-4-
Alternative 6 - On-Site Disposal in RCRA Landfill: Excavation of the solid
wastes and on-site disposal in a secure RCRA landfill. The RCRA landfill
would include a cap and a double liner system. This alternative would also
include the removal and disposal of any hazardous wastes or drums discovered
during the excavation of the landfill.
NJDEP Recommended Alternative
The NJDEP recommends Alternative IB, RCRA Subtitle "D" closure of the 65 acres
which were used for landfilling at the Combe Fill North site. Closure would be
in accordance with the New Jersey Solid and Hazardous Waste Management Regulation
7:26-2.9 Closure and Post-Closure Care of Sanitary Landfills. The closure would
Include grading and compaction, final cover, vegetation, soil erosion and
sediment control, and a methane gas venting system. A security fence will be
constructed around the perimeter of the 102-acre landfill. There will be a,
long-term (30-year) monitoring program of on-site.wells. The major construction
components of the sanitary landfill closure system are summarized below:
s
0 Grading and compaction of the 65-acre area;
0 One foot common borrow material;
0 One foot clay cover;
e Six inch borrow cover;
0 Six inch topsoil and grass seeding;
0 Drainage system including perimeter ditches and corrugated metal
pipes; and
0 Methane gas venting system including gravel trenches, venting pipes
and vent valves.
The recommended alternative will provide the following environmental and public
health benefits:
0 Minimize the surface water and rainfall infiltration and associated
leachate generation;
0 Minimize air pollution;
0 Minimize methane gas migration; and
0 Prevent human direct contact with solid wastes.
If you have any questions, please contact Janice Haveson of NJDEP's Office of
Community Relations at (609) 984-3081.
HSa?/198:fb
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION 07 WASTE MANAGEMENT
«.
HAZARDOUS SITS MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Vast* Sites
As pare of the federal/state- program of cleanup at hazardous vaaca
sites* a Community Relations Program is conducted co receive local input and
to advise local residents and officlala about eha planned remedial actions at
th« three major stages of the elaaanp: 1) remedial investigation/feasibility
study 2) engineering deaign and 3) remeval/treatmant/construction. Local
briefings and meetings are conducted with elected officials and residents and
generally take place at:
1) The cnnmaiii.ement of a raaadlal investigation/feasibility study so
that local concerns can be addraaaed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial action. Thar* is a 30-day comment period after
public presentation of the alternatives during which the feasibility
study is available in local repositories.
3) The engineering design stage to carry out the mandates of the
selected-remedial alternative.
4) The commencement of the removal/ treatment /construction stage to
advise of the expected physical, remedial action.
5) The completion of the remedial action.
In addition to the activities outlined above, there is generally
ongoing communication with local officials and residents as required.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a site, community relations activities are conducted by
the relevant State or Federal agency.
In New Jersey, the DEP Community Relations Program is directed by Grace
Singer, Chief, Office of Community Relations (609) 984-3081. At Region II,
EPA, the contact person is Lillian Johnson, Community Relations Coordinator
(212) 264-2515.
HS45:js
4/85
Over. .
-------
STEPS INVOLVED IN A KAJOR HAZARDOUS WASTE SITE CLEANUP
(I)
Site Identified
and Referred
(5)
Prioritization
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Conatruction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
(6)
Determination of Lead
Preparation of
Feasibility
Study
(14)
Cleanup Evaluation
(3)
Secure Site
(7)
Community Relations
Plan Activated
Site Analysis Evaluation
and Assessment »
(8)
Signing of Contract or
Cooperative Agreement
(II) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Design
(15)
Contractor Audit and
•
Cloae out
I
Jersey Department of Environmental Protection
Over. . .
-------
ATTACHMENT D
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss Results of Remedial Investigation/Feasiblity Study
at
Combe Fill North Landfill
Tuesday, July 1, 1986
7:30 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, NJ
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-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss Results^ of Remedial Investigation/Feasiblity Study
at
Combe Fill North Landfill
Tuesday, July 1, 1986
7:30 p.m.
Mt. Olive Municipal Building
Route 46
Budd'lake, NJ
NAME
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-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss Result^ of Remedial Investigation/Feasibility Study
at
Combe Fill North Landfill
Tuesday, July 1, 1986
7:30 p.m.
Mt. Olive Municipal Building
Route 46
Budd Lake, NJ
NAME
AFFILIATION
ADDRESS
2.
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10.
11.
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-------
THEODORE » SCHWARTZ
CHARLES A STANZIALE JR ""
RONALD L TOBIA"
KENT A F WEISERT
WARREN B KASDAN
BEN M BECKER
JOSEPH * OBERWAGER-
STEVENS WElNSTEIN"'
GARY S ROSENSWEIG
DAMON R SEDITA""
RAYMOND T LYONS JR
JOSEPH M CAMPISANO
FRANK R CAMPISANO
ELIZABETH A JOYCE"
STEVEN T SINGER
DONALDJ CRECCA
ATTACHMENT E
LAW OFFICES
SCHWARTZ. TOBIA & STANZIALE
A PROFESSIONAL ASSOCIATION
22 CRESTMONT ROAD
MONTCLAIR. NEW JERSEY 07042
TELEPHONES
NEW JERSEY
(2O1) 7466OOO
NEW YORK
1212) »26 I«IO
TELEX 1302*8
OF COUNSEL
PETER W. RODINO III
MEMBER OF NY BAR-
MEMBER OF FLA BAR-
MEMBER OF D C BAR-
MEMBER OF CAL BAR—•
MEMBER OF COLO BAR9
July 15, 1986
Ms. Janice Haveson
New Jersey Department of Environmental
Protection
Office of Community Relations
432 East State Street
Trenton, NJ 08625
RE: Combe Fill North Landfill
Remedial Investigation/Feasibility Study
Dear Ms. Haveson:
This letter, is submitted in response to the Remedial
Investigation/Feasibility Study prepared by Ebasco Services,
Inc. relative to the Combe Fill North Landfill. The public
comment period expires July 16, 1986, on the project, and we
would appreciate inclusion of the within comments as part of
the public record.
In reviewing the results of the site investigation and the
remedial recommendation made- by the Department of
Environmental Protection, it appears that the present worth
cost for Alternative IB, which includes estimated capital
costs of $10.5- million and annual operation and maintenance
costs of $1.6 million, is excessive in light of the work to be
performed.
The largest single component of closure costs is for the
i-nstallation of a clay cap to minimize exposure to
contaminants and reduce leachate generation. The initial
question we raise is whether a "clay cap" is either preferable
-------
Janice Haveson
July 15, 1986
Page 2
or necessary for the site. The use of H.D.P. Geomembranes as
part of a long-term closure plan is gaining increasing
acceptance in the scientific ana regulatory community. The
Ebasco report makes no attempt to evaluate the use of this
type of membrane at the Combe Fill North site and whether it
will provide the same environmental benefits at less cost than
the clay cap. Such an evaluation should be performed before
the decision is made that a clay cap is a preferred
alternative.
Further with regard to proposed clay cover, the Ebasco
report is inconsistent in terms of the amount of clay
required. Table A-l proposes a two-foot thick clay liner with
estimated quantities of 210,000 cubic yards. Tables B-2 and
C-3 show estimated quantities of 105,000 cubic yards for the
clay layer, apparently based on the premise that only one foot
of clay is required. In fact, the latter figure should be the
correct one. One foot of compacted clay as final cover is a
standard requirement of a solid waste facility Certificate of
Registration. No sound reason exists for the placement of an
additional foot of clay. The Ebasco estimates require a
downward revision in this cost component. The site
investigation report appears to conclude that the Combe Fill
North site did not accept hazardous wastes nor is it a
hazardous waste site, thus seriously questioning its status as
a so-called "Superfund" site requiring any special treatment.
In fact, it should be delisted and/or closed as a. solid waste
facility averting the necessary expenditure of public funds.
A similar problem arises in the construction of the
proposed drainage system. Table B-2 and Table C-3 propose the
use of a two-foot thick clay liner in the drainage system. No
reason is given for the use of a clay layer in the drainage
system. To our knowledge, clay is not normally included as an
element of such a drainage system and is certainly not
required in a two-foot thick layer.
The lack of a breakdown on the various construction
components in terms of the work to be performed and the basis
for the cost estimates makes the critique difficult. One must
question how the figure shown in Table A-l of $12,000 per acre
for grading and compaction over the 65-acre site was derived.
The same table shows revegetation costs estimated at $5,500
per acre which is far in excess of experience at other sites.
While our comments are not as exhaustive as we might like
them to be, we hope to impress upon the Department the need
for further information relative to the costs of the proposed
remedial alternative. We ask that Ebasco be required to
submit such information and have same be made publicly
available prior to final selection of the remedial alternative.
-------
Janice Haveson
July 15, 1986
Page 3
In closing, we thank you for the opportunity to submit the
above comments and trust that they will be given careful
consideration.
Very truly yours,
SCHWARTZ, TOBIA § STANZIALE
'BY: Steven T/Singer
STSrs
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