United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-86/034
Sept 1986
Superfund
Record of Decision
Rockaway Borough Well Field, NJ
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TECHNICAL REPORT DATA
(ftease read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/RO 2-86/034
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Rockaway Borough Well Field, NJ
5. REPORT DATE
2Q. IQRfi
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Ropnrh
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Rockaway Borough Well Field site is located in Rockaway Borough, Morris County,
New Jersey, and consists of three municipal supply wells which are in a glacial iquifer
designated by EPA as the sole source aquifer for Rockaway Borough and the surrounding
communities. High concentrations of TCE and PCE have been detected in the aquifer since
1980, but no sources of contamination have been identified. In 1981, the Borough of
Rockaway constructed a three-bed granular activated carbon adsorption system to treat
contaminated well water. Treatment has effectively reduced volatile organic contaminant
concentrations in finished water to less than 1 part per billion (ppb). Although
thirteen VOCs have been detected in the well water, TCE and PCE are the primary
contaminants of concern. The site was listed on the NPL in December of 1982, and the
RI/FS was initiated in 1985.
The selected remedial action for the Rockaway Borough site includes: Rockaway
Borough maintaining the existing filtration system and modifying operations to ensure
compliance with Safe Drinking Water Act standards; and EPA continuing the RI/FS in an
attempt to identify the source and extent of contamination and evaluate additional
remedial action alternatives to address source control. Estimated capital cost of this
remedial action is zero with annual O&M costs of 374,800.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATi Field/Croup
Record of Decision
Rockaway Borough Well Field, NJ
Contaminated Media: gw
Key contaminants: TCE, PCE, VOCs
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report I
None
21. NO. Ol
20. SECURITY CLASS (Tins page)
None
22. PRICE
• ES
_6Q_
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLBTB
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RECORD OF DECISION
ROCKAWAY BOROUGH WELL FIELD
Site Rockaway Borough Well Field, Rockaway Borough, New Jersey
Documents Reviewed
I am basing my decision on the following documents:
- Remedial Investigation and Feasibility Study Report,
prepared by Science Applications International Corporation,
August 1986
- Responsiveness Summary, September 1986.
- Staff summaries and recommendations
- Borough reguest for reimbursement, June 1983
- Agency correspondence denying request, August 1983
Background
In 1981, the Borough of Rockaway installed a granular activated
carbon filtration system to treat contaminated groundwater
from its well field. The results of the remedial investigation
and feasibility study indicated that the most appropriate and
cost-effective means of providing safe, potable water which
meets relevant and appropriate standards is the continued
operation of the Borough's existing filtration system.
Description of Appropriate Remedy
- The Borough should maintain the existing granular activated
carbon treatment system. Operations should be modified to
ensure compliance with current Safe Drinking Water Act
standards. In EPA's judgment, the spent carbon should be
regenerated off-site.
- EPA will continue the remedial investigation and feasibility
study in an attempt to positively identify the contaminant
source(s), further delineate the full extent of contamination,
and evaluate additional remedial action alternatives to
address those sources.
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Reimbursement
Rockaway Borough officials requested that CERCLA funds be
used to reimburse the Borough for the water supply treatment
system which it installed. However, the action and related
expenditures did not occur during the CERCLA "window" period.
The CERCLA "window" period includes the years 1978 to 1980.
The filtration system was installed in 1981 after expiration
of the period.
Although EPA can pre-authorize or provide prior approval of
specific remedial actions with the intent of reimbursing the
costs of such actions, the Borough did not request approval
prior to installing the water treatment system. In fact, it
was not until 1983 that Borough officials first inquired
about the possiblity of reimbursement. At that time., the
Assistant Administrator for Solid Waste and Emergency Response
responded to the Borough's inquiry and formally notified
officials that costs incurred for the water treatment system
were not eligible for reimbursement.
For the foregoing reasons, I have decided that the Borough
cannot be reimbursed for the cost of the filtration system.
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
is an operable unit involving treatment of a drinking water
supply which is cost-effective and consistent with a permanent
remedy.
I have further determined that this remedy 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. Continued operation of this operable unit
by the Borough is appropriate at this time.
The State of New Jersey has been consulted and agrees with
this decision.
Date Christopher tf. D/Cggett
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
ROCKAWAY BOROUGH WELL FIELD
TABLE OF CONTENTS PAGE
SITE LOCATION AND DESCRIPTION 1
SITE HISTORY 1
CURRENT SITE STATUS- 8
ENFORCEMENT 9
ALTERNATIVE EVALUATION 9
1. No Action 12
2. Treatment via Granular Activated Carbon 12
Adsorption
3. Treatment via Air Stripping 13
4. Treatment via Air Stripping followed by 13
Granular Activated Carbon
COMMUNITY RELATIONS 14
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS 14
RECOMMENDED ALTERNATIVE ^ 15
OPERATION AND MAINTENANCE 18
SCHEDULE 18
FUTURE ACTIONS 18
ATTACHMENTS
Responsiveness Summary
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LIST OF FIGURES
FIGURE PAGE
1. Location of Well Field Site 2
2. Contaminant Concentrations of Drinking Water
Before and After Activated Carbon Treatment 3
3. Soil Gas Contours for TCE 6
4. Soil Gas Contours for PCE 7
5. Areas that May Contain Sources of Contaminants 11
Affecting the Rockaway Borough Well Field
11
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LIST OF TABLES
TABLE PAGE
1. Concentration Ranges of Volatile Organic 4
Compounds Detected in Rockaway Borough System
2. Description of Remedial Alternatives 10
3. Summary of Costs 16
111
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
ROCKAWAY BOROUGH WELL FIELD SITE
Rockaway Borough, New Jersey
SITE LOCATION AND DESCRIPTION
The Rockaway Borough Well Field site ("the site") is located
near the intersection of Union and Maple Streets in Rockaway
Borough, Morris County, New Jersey (Figure 1). The site con-
sists of three municipal supply wells which are in a glacial
aquifer designated by the Environmental Protection Agency (EPA)
as the sole source aquifer for Rockaway Borough and the sur-
rounding communities. The Rockaway Borough Water Department
currently operates the well field and treats the water supply
by activated carbon adsorption. No sources of contamination have
been identified at this time, although several potential sources
exist.
The site is located in a suburban residential setting and is
surrounded by homes, businesses and municipal property. The
wells are set within the Upper Rockaway watershed and provide
water service to approximately 11,000 people in Rockaway Borough
and portions of neighboring Denville and Rockaway Townships.
In addition, Rockaway Borough sells water to Rockaway Township
for distribution within its own system. High concentrations of
tetrachloroethylene (PCE) and trichloroethylene (TCE) have been
detected in the aquifer since 1980.
SITE HISTORY
Volatile organic contamination was detected in the municipal
wells in Rockaway Township in 1979. These findings prompted the
New Jersey Department of Environmental Protection (NJDEP) to test
the water quality in neighboring areas. Samples taken in March,
June and July of 1980 found contamination in three of Rockaway
Borough's municipal supply wells (Nos. 1, 5 and 6) and at
points within the Borough's distribution system. Concentrations
of PCE as high as 678 ppb (parts per billion) and TCE up to 172
ppb were identified in the supply well water along with lesser
concentrations of 1,1,1-trichloroethane, trans-1,2-dichloroethene,
toluene, methylene chloride, chloroform, trichlorofluoromethane,
carbon tetrachloride, benzene, chlorobenzene, 1,1-dichloroethene,
bromodichloromethane, and 1,1,2-trichloroethane (Table 1). The
highest initial concentrations of PCE and TCE were observed in
Wells 1 and 6 with detectable but lower levels observed in Well 5.
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Morris County
Line
0 5 10 20 30
Miles
' Miles
Figure 1 Location of Well Field Site
in Rockaway Borough, Morris County, New Jersey
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-3-
500
400-
T 300-
.o
1 200-
*•
o
u
o
0 IOOH
400
_ 300-
JB
a
e
u
200^
100-J
Now:
Calendar Year
1980
1981
1982
1983
1984
1985
Raw W«t«r
PCE Concentrations
Tr«at«d W»t«r
PCE Concentrations
I I I I i I I
400 800 1200 1600
Time Since Sampling Began (Days)
2000
2400
Raw Water
TCE Concentrations
Treated Water
TCE Concentrations
400
800
1200
1600
2000
2400
Time Since Sampling Began (Days)
Data from Borough of Rockaway Sampling Program (1980-1985):
Laboratory Analyses Conducted by Industrial Corrosion
Management Incorporated. Treatment System Startup on 7-7-81.
Sampling of blended raw water began
appro*. 480 day* following the beginning
of the Rockaway Sampling Program.
Figure 2 Contaminant Concentrations in Drinking Water
Before and After Activated Carbon Treatment
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Table 1
.CONCENTRATION RANGES OF VOLATILE ORGANIC COMPOUNDS DETECTED
IN ROCKAWAY BOROUGH WATER SYSTEM1
:CONCENTRATIONS IN PARTS PER BILLION (ppb)
Contaminant WELL WELL WELL RAW TREATED '
NO. 1 NO. 5 NO. 6 WATER WATER
Trichloroethylene (TCE) 1.0-9.7 0.5-76 5.7-172 1.0-41.2 ND-U.8 2.7
Tetrachloroechylene (PCE) 61.6-568 2-169 5-678 1.5-335 ND-25.43 Q.8
1,1,1-Trlchloroethane
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As these wells provided virtually all of the water utilized by
the public within the Borough and also supplied users in Rockaway
and Denville Townships, NJDEP directed the Borough of Rockaway
to: (1) give immediate preference to the use of Well No. 5, and
to use Well. No. 6 as a backup source, and Well No. 1 for peaking
purposes only; (2) provide an acceptable treatment technique;
and (3) sample each well monthly and analyze for volatile
organics. Between March 1980 and June 1981, groundwater samples
from the producing wells were tested approximately once a month
and the contaminant levels quantified. Concurrent with the
testing of well water samples, water from various points of
usage within the Borough was sampled and analyzed. Well No. 1
was removed from the distribution system in September 1980 and
.a water emergency was declared on February 28, 1981 when Well
No. 6 showed high concentrations of PCE and TCE. Residents
were advised to discontine using tap water for drinking and
cooking and temporary drinking water supplies were made available
to the public in tank trucks provided by the National Guard.
In general, initial PCE concentrations were highest at Borough
Well No. 1 (up to 568 ppb), but declined markedly after pumping
was stopped in 1980. Approximately coincident with the shutdown
of Well No. 1, PCE concentrations rose dramatically in Well No.
6, rising from an average pre-shutdown concentration of approx-
imately 15 ppb to a post-shutdown peak concentration of 678
ppb. PCE concentrations in Well No. 5 (up to 400 ppb) were
variable and showed a more gradual increase over time than in
the other Borough wells. TCE concentrations were generally low
(less than 10 ppb) in Well Nos. 1 and 5, with the exception of
a 76 ppb peak observed in Well No. 5 in August 1980. TCE con-
centrations in Well No. 6 were substantially higher and more
persistent (5.7 to 172 ppb) than those observed in Well Nos. 1
and 5 (Figure 2).
Water samples collected from various points in the Borough water
distribution system before water treatment was implemented rough-
ly followed the trends observed in the well samples. PCE con-
centrations fluctuated over time between 6 and 473 ppb. Contami-
nant concentrations in untreated water samples peaked during
September and October of 1984, when PCE concentrations rose to
approximately 473 ppb. As observed in the well samples, TCE
was consistently present, varying between 2 and 89 ppb.
The Borough of Rockaway constructed a three-bed granular activated
carbon adsorption system during the water emergency period, with
the assistance of Calgon Corporation. The system began treating
raw water pumped from the Borough wells in July 1981. The water
emergency was lifted when chemical testing indicated that total
concentrations of volatile organic compounds had been reduced
to levels below 100 ppb, the limit established by the State of
New Jersey.
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INTERCHANGE
\
IHceltes,
Legend
Q Rockmray Borough Supply Will
4Q/" TCE ConcMOmton Contour
In Soil QM (Concentration In
'urt Drawn Aftor Tracer KoMtrcfi Corp.
Octobor, r—
Scale in Feet
Q 1000
^1
Figure 3 Soil Gas Concentration Contours for TCE
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HANGE
Rockiwey Borough Supply Will
Concentration Contour
In Soil QM (Concentration In
Contour. Drawn Aftor Tracer RoMarch Corp
October. 1986
Scale in Feet
0 1000
Figure 4 Soil Gas Concentration Contours for PCE
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Each of the three adsorbers is 10 feet in diameter and 20 feet.
high and is filled with approximately 20,000 pounds of granular
activated carbon. When the carbon in any one of the three
adsorbers becomes saturated with impurities (usually after 10-
12 months in service), the adsorber is taken out of service and
the spent carbon is replaced with virgin Filtrasorb 300 activated
carbon. The spent carbon is then transferred as a slurry under
air pressure to a trailer for removal from the facility. This
system has effectively reduced contaminant concentrations in
the finished water to below 1 ppb.
Since the discovery of contamination in the Rockaway Borough
Well Field in 1980, water quality monitoring of water pumped
from the supply wells has been conducted by the NJDEP and by
the Borough of Rockaway. Water samples have been collected
predominantly from the presently producing wells and at various
points of usage within the Borough, including several of the
existing privately operated wells within the Borough. Water
quality monitoring of influent and effluent flow through the
treatment system is presently being conducted by the Borough of
Rockaway on a monthly basis.
The NJDEP submitted the well field contamination problem to the
EPA for consideration for funding under the Comprehensive Environ-
mental Response, Compensation and Liability Act of 1980 (CERCLA,
also known as Superfund). CERCLA is the Federal program for
identifying, investigating, and remediating uncontrolled hazardous
waste sites and related public health and environmental problems.
Subsequently, EPA proposed that the Rockaway Borough site be
placed on the National Priorities List (NPL) of uncontrolled
hazardous wastes sites to make it eligible to receive CERCLA
funding. Following a public comment period, the site was placed
on the NPL in December 1982.
CURRENT SITE STATUS
The existing problem in the Rockaway Borough Well Field results
from contamination of the water supplied from three production
wells by volatile organic compounds (VOCs), predominantly PCE
and TCE. Thirteen VOCs have been detected within the Borough's
three active wells, as well as within the water supply system
and at various usage points within the Borough. Eleven of
these compounds have occurred infrequently and at low concen-
trations. TCE and PCE, however, have shown greater persistence
and markedly higher concentrations (Figures 3 and 4). Accordingly,
they have been the focus of concern and activities relating to
the maintenance of a safe, potable public water supply. Water
quality data associated with samples regularly collected by the
Borough from various points of usage indicate generally higher
concentrations of PCE relative to TCE.
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It is not .known how long the volatile compounds have been
contaminating the aquifer penetrated by the Rockaway Borough
water supply wells, but their presence was detected upon the
first testing for the substances in 1980. Although the vertical
and areal extent of groundwater contamination has not been
fully determined, three areas containing potential sources of
groundwater"contamination by volatile organics have been identified
using the technique of soil gas sampling (Figure 5).
Until the sources of groundwater contamination can be defined
and their associated hazards assessed, the major concern associ-
ated with the contamination at the Rockaway Borough Well Field
is consumption of the water by the general public. Approximately
11,000 people receive potable water from the Borough's public
supply system.
A granular activated carbon treatment system which was installed
in July 1981 has been effectively treating the groundwater
prior to distribution. Exposure of the service population to
volatile organic contamination has been greatly reduced as a
result.
ENFORCEMENT
Three discrete areas of contamination have been found but no
responsible parties have been positively identified. A supple-
mental remedial investigation and feasibility study will be
conducted to attempt to pinpoint the source or sources of
groundwater contamination. In addition, several other investi-
gations are currently being conducted in this regard by the
NJDEP outside of the Superfund Program. It is anticipated that
information resulting from the above investigations may result
in enforcement activities which would attempt to recover costs
incurred by EPA, the State of New Jersey and the Borough of
Rockaway.
ALTERNATIVES EVALUATION
The feasibility study process involves, as a first step, select-
ing technologies that are appropriate for remedying the public
health and environmental concerns associated with a particular
site. For the Rockaway Borough Well Field site, one of the
remedial objectives is to restore a safe drinking water supply
to the affected residences. Consequently, in performing the
study, alternatives were evaluated as if there were no treatment
unit currently in operation. In comparing costs, however, the
capitol expenditures of the existing treatment system were
considered and incorporated into the cost-effective remedial
remedial action at sites that present complex cleanup problems.
action recommendation. This Record of Decision does not address
any source control measures, as no source has yet been positively
identified. The remedial alternatives are outlined in Table 2.
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TABLE 2
DESCRIPTION OF REMEDIAL ALTERNATIVES
Alternative #1 - No Action (No Treatment)
Alternative #2 - Treatment by Granular Activated Carbon
- spent carbon either regenerated, incinerated
or landfilled
Alternative #3 - Treatment by Packed-Tower Aeration with
Off-Gas Treatment
- spent carbon (off-gas filters) either regenerated,
incinerated or landfilled
Alternative #4 - Treatment by Packed-Tower Aeration and Polishing
with Granular Activated Carbon
- spent carbon either regenerated, incinerated
or landfilled
Alternative #5 - Provide a Replacement Well Field:
- deeper in the glacial aguifer
- in the lower bedrock aquifer
- relocated in the glacial aguifer
Alternative #6 - Purchase Water from Morris County Municipal
Utility Authority:
- Denville Route
- Dover Route
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•r i-.iiHf-^- f ' i'A^ <*
J3' /^:: :O' / -f ft \t "• .^
containing potential
f groundwater
Figure 5 Areas That May Contain Sources of
Contaminants Affecting the Rockaway Borough Well Field
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An operable unit is a discrete response measure that is consistent
with a permanent remedy, but is not the permanent remedy in and
of itself. This is consistent with the practice of phasing
remedial actions at sites that present complex cleanup problems.
The primary objective of this operable unit is to protect
public health by providing a reliable supply of safe, potable
water to those consumers currently dependent on the Rockaway
Borough Well Field.
Numerous operable unit alternatives were developed and evaluated
for the Rockaway Borough Well Field in accordance with the NCP
and developmental EPA guidance for providing alternate drinking
water supplies. The alternatives were grouped into four general
categories: 1) no action, 2) new water supply, 3) supplementary
water supply, and 4) treatment. The alternatives were evaluated
in terms of their ability to protect public health and their
technical feasibility and implementability.
The following treatment alternatives were advanced to further
screening: air stripping, granular activated carbon adsorption,
and air stripping followed by granular activated carbon adsorption.
In addition to the ability to protect public health and implementa-
bility, these alternatives were also evaluated in terms of
complexity, reliability, environmental impact, community impact,
compatibility with final remedy, and relative cost.
All three alternatives presented below are designed to achieve
the same removal efficiencies and drinking water quality. A
Maximum Contaminant Level of 5 ppb for each of the two compounds
of concern, trichloroethylene and tetrachloroethylene, was
recommended in the November 15, 1985 Federal Register. Influent
concentrations were based on a mass balance of the highest
concentrations of the various volatile organic contaminants found
in each well. This conservative design approach was taken to
ensure proper operational conditions and efficiencies regardless
of gaps in the data.
Alternative 1 - No Action
The results of the Remedial Investigation indicate that signif-
icant groundwater contamination exists at the Rockaway Borough
Well Field site. This alternative, no treatment of the area's
groundwater, does not adequately protect public health and has a
negative impact on the environment.
Alternative 2 - Granular Activated Carbon Adsorption
This alternative utilizes granular activated carbon (GAC) to
meet the objectives of the operable unit. Contaminated water
from the wells is pumped through contact units filled with GAC,
which adsorbs the volatile organic compounds (VOCs). The GAC
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adsorption system would likewise be designed to achieve sufficient
removal efficiencies to provide drinking water at less than a .1
x 10~6 excess lifetime cancer risk. Treated water would be
pumped directly into the distribution system.
Alternative 3 - Air Stripping
This alternative utilizes packed-tower air strippers with
off gas carbon treatment to meet the objectives of the operable
unit. Contaminated water from-the wells is pumped through the
air stripping towers to remove VOCs. Treated water would be
pumped directly into the distribution system.
The air stripping treatment system would be designed to achieve
5 ppb for both TCE and PCE, the main contaminants frequently
detected at Rockaway Borough Well Field. This removal efficiency
would provide treated water at less than a 1 x 10~6 excess lifetime
cancer risk.
Alternative 4 - Air Stripping Followed by Granular Activated
Carbon Adsorption
This alternative is a combination of the previous two treatment
technologies. Contaminated water is pumped through air stripping
units to remove approximately 70 percent of the contamination,
and then through granular activated carbon adsorption units for
removal of any residual contamination. Treated water would be
pumped directly into the distribution system.
" *»
As with the previous two alternatives, this treatment system
would be designed to achieve sufficient removal efficiencies to
provide drinking water at less than a 1 x 10~6 excess lifetime
cancer risk.
The three treatment alternatives identified above were further
evaluated in accordance with the NCP to determine the most ap-
propriate -cost-effective remedy.
Until the second phase of the remedial investigation for the
Rockaway Borough Well Field site is completed, the full nature
and extent of groundwater contamination will remain unknown.
The implementation of the appropriate operable unit as an
interim remedy will minimize the contamination of the drinking
water provided by Rockaway Borough Well Field and reduce the
associated health threat to those dependent on the municipal
water supply system. Without the implementation of such a
measure, the users of the system would be exposed to an un-
acceptable health risk. Therefore, the no action alternative
is not appropriate, as already discussed.
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Alternate water supply/ including a surface water system, re-
location of the well field both vertically and laterally, and
purchasing water from another source all have limited feasibility.
Any surface water sources would require a long time to implement
and have overwhelming institutional constraints. Any attempt
to relocate, the well field will likely encounter contamination.
There is no known aquifer in the area sufficiently isolated
from potential contamination to accomodate a new well field.
Neighboring municipal water systems do not have sufficient.
existing surplus capacities to provide the necessary quantities.
The Morris County Municipal Utility Authority is currently
expanding its system. Unfortunately, at this time, the Authority
does not have any surplus capacity. In addition, the Authority's
system is located at the other side of the County. Therefore,
only treatment alternatives remain for further consideration.
The remaining three alternatives — air stripping, granular
activated carbon (GAC) adsorption, and air stripping followed
by GAC adsorption — are comparable in regard to several of the
screening criteria used to select the appropriate alternatives
for the Rockaway Borough Well Field site. The following criteria
were utilized in screening these alternatives: ability to
protect public health, time required to implement, complexity,
technical feasibility, reliability, environmental impact,
community impact, ability to meet demand, compatibility with
final remedy, and relative cost. The ability to protect public
health is of primary importance, followed closely by the time
required for implementation. Table 3 summarizes the detailed
cost comparison of these three alternatives.
COMMUNITY RELATIONS
On August 18, 1986, NJDEP made the draft RI/FS report available
for public comment by placing four copies in public repositories
at the Morris County and Rockaway Borough Libraries, the Rockaway
Borough Municipal Building and the NJDEP offices in Trenton.
The public was notified of the availability of the documents by
letter to all those on the Rockaway Borough mailing list. A
public meeting to discuss the results of the RI/FS was held in
Rockaway Borough on August 28. The public comment period
extended from August 18 to September 10, 1986. The written
public comments and consequent responsiveness summary are
appended to this document.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The applicable law that regulates and protects public drinking
water supplies is the Federal Safe Drinking Water Act. New
standards have recently been promulgated in the November 15,
1985 Federal Register. These new standards have been considered
while evaluating the existing carbon treatment unit and its
operation.
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RECOMMENDED ALTERNATIVE -
The National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (40 CFR Part 300.68(j)) states that the appropriate
extent of remedy shall be determined by the lead agency's se-
lection of the remedial measure which the agency determines is
cost-effective (i.e., the lowest-cost alternative that is tech-
nologically feasible and reliable and which effectively mitigates
and minimizes damage to and provides adequate protection of
public health, welfare, and the environment). Based on the
evaluations of cost and effectiveness for each proposed alterna-
tive, the comments received from the public, and applicable
State and Federal environmental requirements, Alternative 2 has
been determined to be the cost-effective alternative.
The recommended alternative is considered an operable unit
remedial action. Operable units, as defined in Section 300.68
(e)(l) of the NCP, are similar to initial remedial measures
(IRMs). This operable unit remedial action for provision of an
alternate water supply is appropriate because there was contami-
nation of drinking water as measured at the tap. The objective
of this action is to provide those consumers currently dependent
on the Rockaway Borough Well Field for drinking water with a
reliable supply of safe, potable water until the final remedial
measure(s) may be implemented. A supplemental groundwater RI/FS
will examine appropriate final response action(s).
The recommended alternative provides for continued operation of
of the existing carbon treatment unit for 1.26 mgd (million
gallons per day) of contaminated groundwater. This capacity
represents the average rate of potable water distribution. The
recommended alternative has been designed and constructed to
allow flexibility relative to which wells to treat. Pumping
strategies therefore can be optimized. The carbon treatment
system has been designed to achieve removal of both trichloro-
ethylene (TCE) and tetrachloroethylene (PCE), the critical con-
taminants, to 5 ppb and consists of three carbon adsorption units,
This removal efficiency would provide drinking water at less
than a 1 x 10~6 excess lifetime cancer risk. The carbon treat-
ment system is designed to treat water with influent VOC con-
centrations based on the highest concentrations of contaminants
detected individually in each of the wells to be treated plus a
safety factor. Performance of the carbon system should be
frequently monitored to ensure that removal efficiencies required
to protect public health are maintained.
The capital cost of this alternative is considered to be zero
in the cost-effective analysis since the treatment system has
been installed and the related costs incurred by the Borough
($504,600) in the past. The operation and maintenance (O&M)
costs are estimated to be $74,800 per year for electric power,
operating labor, and carbon regeneration. The 30-year present
worth for the recommended alternative is $705,400.
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Table 3
Summary of Costs
Capital Cost* Annual Cost* Present Worth**
Alternative #1 0 9,300 88,000
No action
Alternative #2
(assuming no system is
in place)
Treatment by granular 504,600***
activated carbon,
with spent carbon:
- regenerated 74,800 1,210,000
- incinerated 281,400 3,157,800
- landfilled 95,200 1,402,300
Alternative #2
(considering capital costs
are sunk costs)
Treatment by granular 0
activated carbon,
with spent carbon:
- regenerated 74,800 705,400
- incinerated 281,400 2,653,200
- landfilled 95,200 897,700
Alternative #3
Treatment by 524,800
packed-tower
aeration and
gas phase carbon,
with spent carbon:
- regenerated 40,700 908,200
- incinerated 51,300 1,008,700
- landfilled 45,000 948,600
Alternative #4
Treatment by packed- 925,900
tower aeration
and carbon
polishing, with
spent carbon:
- regenerated 45,500 1,354,600
- incinerated 129,000 2,142,300
- landfilled 53,400 1,429,500
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-17-
Table 3 (Continued)
Alternative #5
Provide a~ replace-
ment well field:
- deeper in 582,000
glacial aquifer
- in bedrock 2,252,000
aquifer :
- relocated in 1,275,200
glacial aquifer
9,300
9,300
9,300
669,900
2,340,000
1,363,200
Alternative #6
Purchase water
from MCMUA
- Denville Route
- Dover Route
790,300
476,700
335,200
320,200
3,950,600
3,495,600
*1980 costs
**Discount rate of 10 percent; present worth annuity factor for
30 years = 9.427
***Represents an adjusted estimate of actual cost incurred by
Rockaway Borough for installation of the treatment.system.
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-18-
Operatiori and Maintenance
The operation and maintenance will continue under the supervision
of and expense to the Borough of Rockaway. The carbon will have
to be changed more frequently to comply with the new Safe Drinking
Water Standards for TCE and PCE, the contaminants of concern at
the site.
SCHEDULE
Scheduling for this remedial action is a moot point, since a
granular activated carbon system has already been installed by
the Borough of Rockaway.
Future Actions
A supplemental RI/FS will be conducted to identify the source(s)
of contamination and define the boundaries of the contaminant
plume, along with appropriate, additional response actions.
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ROCKAWAY BOROUGH WELL FIELD SITE
"Rockaway Borough, Morris County, New Jersey
RESPONSIVENESS SUMMARY
Public Comment Period:
- August 18, 1986 to September 10, 1986
This community relations responsiveness summary, prepared as
part of the Record of Decision (ROD), is divided into the
following sections; :
I. Background on Community Involvement and Concerns
This is a brief history of community involvement, activity
and concerns in Rockaway Borough regarding the contamination
of the well field and a summary of activities conducted by
the New Jersey Department of Environmental Protection (NJDEP)
and the Environmental Protection Agency (EPA) prior to and
during the remedial investigation and feasibility study
(RI/FS).
II. Summary of Major Questions and Comments Received During the
Public Comment Period .and NJDEP/EPA Responses
This includes a summary of major questions and comments
directed to NJDEP and EPA during the August 28, 1986 public
meeting on the results of the feasibility study, as well as
written comments sent to NJDEP during the public comment
period. Responses by NJDEP and EPA are included in this
section.
III. Remaining Concerns
This section briefly outlines the remaining community concerns
which NJDEP and EPA should be aware of in conducting the
next phase of the investigation at the Rockaway Borough Well
Field site.
List of Attachments
A - Attendance Sheet, May 9, 1985 Public Meeting
B - Information Package, May 9, 1985 Public Meeting
C - Attendance Sheet, August 28, 1986 Public Meeting
D - Information Package, August 28, 1986 Public Meeting
E - Mayor Smith's Written Comments on the RI/FS
F - EPA letter of response to Mayor Smith's Comments
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-2-
I. Background on Community Involvement and Concerns
The public first became aware of the Rockaway Borough Well
Field site in September 1980 when Borough officials announced
that one of three municipal wells was being closed due to
contamination and that residents should reduce their water
consumption by one-third. Initially, some residents objected
to the fact that Borough officials had known of the contamination
for many months. The contamination and the limited water
supply continued to be issues of concern through the fall of
1980. :
The Borough received national media attention when a water
emergency, which lasted four months, was declared in February
1981. Information was disseminated by the Borough through
the media, public meetings, publication of a newsletter,
house-to-house distributions by the Fire Department and Boy
Scouts, extensive telephone contacts, and public relations
by the firm hired to install the water treatment system.
Public interest declined substantially once the system was
installed. The remaining public concerns involve locating
the source(s) of contamination and the continuing financial
burdens to the community associated with the past installation
and future operation and maintenance of the ground water
treatment system.
On May 9, 1985, NJDEP/EPA held a public meeting to discuss:
(1) background history of the site and (2) an overview of
the remedial investigation and feasibility study (RI/FS)
workplan. Notification of the meeting was accomplished
through press releases and direct mailing of notices to local,
State and Federal officials, as well as concerned citizens.
Approximately 25 people attended the meeting (see Attendance
Sheet, Attachment A). An information package was distributed
to all who attended (see Attachment B). Issues and concerns
raised during the meeting follow:
- The expenditures on the treatment system incurred by the
Borough
- Indiscriminant dumping by local industrial companies
- Contamination of all three municipal supply wells
- Is the source continuing to release contamination into
the ground water?
- Potential health risks associated with consumption of
the water
- Can a source be positively identified? Will the scope
of the study be expanded if necessary to identify a
source?
- Adequacy of sampling and testing methodologies
- Surface water contamination
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-3-
II. Summary of Major Questions and Comments Received During the
Public Comment Period and NJDEP Responses
On August 18 1986, the RI/FS report was placed in the follow-
ing repositories for review: Rockaway Borough Library,
Morris County Public Library in Whippany, Rockaway Borough
Hall, and NJDEP, Division of Hazardous Site Mitigation in
Trenton. NJDEP issued press releases and notices regarding
the availability of the RI/FS at these repositories.
On August 28, 1986, NJDEP and EPA held a public meeting to
discuss the results of, and recieve comments/questions
regarding the RI/FS. Notification of the public meeting
was accomplished through press releases and direct mailing
of notices to local, State and Federal officials, as well
as concerned citizens. Approximately 25 people attended
the meeting (See Attendance Sheet, Attachment C). Infor-
mation packages were distributed to everyone who attended,
(see Attachment D). The public comment period extended
from August 18, 1986 through September 10, 1986. In addition
to the comments made during the public meeting, one letter
was recieved by NJDEP during this period (see Attachment E).
During the meeting, Kevin Boyer of Science Applications
International Corporation (SAIC), NJDEP's consultant,
presented the remedial action alternatives considered in
the feasibility study. These included:
0 No action;
0 Continuation of treatment through the existing granular
activated carbon (GAC) system with modifications;
0 Treatment with the existing GAC system in combination
with a packed tower aeration system;
0 Treatment by packed tower aeration;
0 Installation of new water supply wells, the location
and/or depths of which would be selected with the
intention of avoiding the plume of contaminants; and
0 Purchase of water from another municipal supplier.
Dr. Merry Morris, Assistant Director of the Division of
Hazardous Site Mitigation, then discussed NJDEP's recommended
remedial alternative which included: maintaining the existing
GAC treatment system, with modified operations to ensure
compliance with current Safe Drinking Water Act standards;
regeneration of spent carbon off-site; and the continuation
of the remedial investigation to identify the source(s) of
the contamination.
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-4-
The following is a summary, organized by subject, of all major
questions and comments received by NJDEP and EPA at the
public meeting and during the comment period.
Source of Contamination
The primary concern expressed by both local officials and residents
was locating the source of the contamination. The citizens of
the Borough are extremely concerned about the contamination of
their potable water supply and the financial effects on their
community, both immediate and:long-term. Several residents and
officials, including Mayor Smith, expressed some disappointment
that the source had not been located in this phase of the
RI/FS. For the most part, however, the community clearly
appreciates the importance and complexity of identifying the
contaminant source, and doing so as expeditiously as possible.
The following questions and comments pertaining to this issue
were raised:
Question: What do you think your chances of finding the source(s)
of contamination are?
Response: At the present time, the study has identified general
areas where these sources may be located and we are
reasonably assured that we will be able to identify
the source(s). NJDEP/EPA plan to review the industrial
and commercial facilities which operate within the
areas of suspected contamination in the next phase
of the investigation.
Question: The Industrial Survey conducted by the Borough was
not able to locate any industries in the Borough
using PCE (tetracholoethylene) and TCE (trichloro-
ethylene). Are you inferring that they are comming
from a dump?
Response: The source need not be actively producing chemicals
now. The possibility of an abandoned source (i.e. a
filled in lagoon, buried drums, etc...) still exists.
The Rockaway Borough Board of Health stated the
survey did not indicate that industries were not
using PCE or TCE, only that they were not abusing or
misusing these chemicals.
Question: Do you have information on ground water flow?
Response: It is known that the well field controls the direction
of ground water flow in the area (i.e. the well
literally pulls the ground water towards itself), but
it is not known how far this influence extends. The
lateral spread of contamination is also unknown and
there is a high degree of contamination overall
throughout this area, including Rockaway, Dover, and
Denville Townships.
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-5-
Q: Wouldn't it be advantageous to try to locate a new uncon-
taminated well field or drill deeper wells rather than using
all of our economic resources trying to find the source?
R: Our. geologists advise us that the probability of locating a
"clean" well in this area is highly unlikely. Again, many
neighboring towns are experiencing similar problems and
consequently are treating their water supplies.
0: Do Dover and Denville use the same aquifer as Rockaway
Borough? ;
R: The aquifer, though made up of similar deposits, is not
the same; nor is the contamination in the Dover and Denville
systems the same as that present in the Rockaway Borough
aquifer.
0: Why is there no mention in the recommended alternative of
removing the source?
R: The source(s) is unknown. Once identified, a supplemental
feasibility study will be conducted which will consider
containment, excavation and/or treatment of the source(s).
At this time, it is premature to talk about source control
measures.
Q: If the Borough itself was responsible i.e., it is a Borough
dump under the park that is causing the contamination, who
would pay for the cleanup, NJDEP and EPA or the Borough?
R: If this were the case, the existing Superfund legislation
establishes a liability of 50/50 between the local/State
governments and the Federal government for the costs of
remedial actions.
Nature of Contamination
Closely related to the issue of locating the source of the contam-
inants is the issue of defining the nature of the contamination.
Citizens and officials asked numerous questions regarding the
contaminants themselves and any related contaminant patterns.
Q: Do we have enough data to say whether the contamination is
maintaining a steady concentration rate?
R: The concentrations do fluctuate, as outlined in Figure 2 of
the ROD, Contaminant Concentrations of Drinking Water Before
and After Activated Carbon Treatment, (this graph was
passed around at the meeting). NJDEP/EPA or the Borough have
not been able to correlate the peaks and declines with any
trend in rainfall, season, etc...
-------
-6-
Q: Was any correlation found between the water table and the
concentrations of contaminants?
R: No
0: Can you explain the drop in the contaminant level in Well
#1 since no one has been using it?
R: Well #1 has not been in operation since 1981. The contami-
nation is drawn in the direction of the operating wells,
and away from the non-operating wells.
Q: Would reopening Well #1 relieve the contamination in the
other wells?
R: No, because the contamination would be drawn to the operating
well. Any change in the pumping scheme would not relieve the
contaminant problem.
Q: The level of PCE peaked in 1984 at 1100 parts per billion
(ppb). Does this indicate that the Borough can expect
another peak sometime in the future?
R: A slug of contaminants can occur at any time and, therefore,
a "peak" is always possible. A carbon system of this type
can adequately treat a slug of contamination. In addition,
the fact that there are two wells in operation would help to
provide some dilution prior to treatment, thereby dampening
any peaking effect.
Q: If contaminants flowing into the aquifer were to cease, how
long would it take to remove all of the contamination from
the aquifer?
R: There is no estimate as to how quickly the aquifer could
cleanse itself. This would depend on several factors,
including the amount of contamination present and the clay
content of the soils. Certain contaminants may be bound in
clay and could be released over a long period of time.
0: How would contaminants be released from the clay?
R: As the ground water in contact with the clay became cleaner,
the trend of contaminants would be to flow from the clay and
soil into the water. The flow would be from higher contaminant
concentrations to lower ones until an equilibrium condition
is reached.
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-7-
Have you any idea of the amount of contamination? Could it
be a number of buried drums; how many gallons a day are
being released?
We do not have sufficient information to estimate the amount
of contamination that exists. For organic solvents like
PCE, two or three drums of pure chemical could contaminate
a ground water system such as this.
Could you comment on the high concentrations of metals
contained in the stream sediments? Are they indicative of
past practices?
The concentrations are not of concern. In most cases, they
are in the ppb range. However, 100 ppb in sediment would
not be as much of a concern as 100 ppb in potable water. This
concentration in stream sediments is not uncommon in developed
areas.
What effect will the Environmental Cleanup Responsibility Act
(ECRA) have on people who own businesses within the en-
circled areas on the map?
The purpose of ECRA is to ensure that any business being
transferred or sold from one owner to another is investigated
and declared environmentally clean prior to the transaction.
Under the provisions of this law, any business in the three
areas under consideration for sale would be investigated
under ECRA, regardless of our investigation under Superfund.
Since 1981, I can not drink the water. Even with the treat-
ment system, it has an odor and I don't drink or use it;
I use bottled water. What can be done?
Based on the RI/FS report and other data, the water being
supplied by the Borough is of good quality.
Cost Issues
In regard to the State of New Jersey, payment to the Borough to
cover capital costs of the water treatment system can not be
provided under the New Jersey Spill Compensaton Fund (Spill
Fund). The Borough was advised of the contamination problem in
1980, installed the GAC system in 1981, but did not submit a
claim to the State until 1985, which was past the deadline for
submitting a Spill Fund claim.
-------
-8-
In addition, Exxon-vs-Hunt makes it unclear whether the State
can properly utilize Spill Fund monies to pay for O&M (operation
and maintenance) in this particular instance. In order not to
prejudice the State's position in the remand of that case, the
O&M cost will not be paid from the Spill Fund.
In regard to EPA, there is a "window" period under CERCLA ex-
tending from 1978 to 1980. Under certain circumstances, costs
incurred during this time period may be counted as a credit
towards the costs of future response actions at a site. Prior
approval, on the other hand, addresses reimbursement more
directly (rather than a credit towards future costs). EPA can
pre-authorize or provide approval of specific remedial actions
with the intent of reimbursing the costs of such actions. The
Borough had not requested approval prior to installing the
water treatment system. In fact, it was not until 1983 that
Borough officials first inquired about the possiblity of re-
imbursement.
Q: Mayor Smith commented that the Borough was not informed,
early on, that it could apply for Spill Fund monies. When
Borough officials became aware of this, they did apply,
however, the deadline had passed. The Borough is not looking
for an "outright gift" but would be interested in a low
interest loan.
R: NJDEP (Division of Water Resources) currently has a loan
program for water supplies. However, this program was not
in existence when the Borough's water treatment system was
installed. Under this program, an application would have
to be filed before the installation of such a system. Also,
please note Attachment F, EPA letter of response to Mayor
Smith's letter.
*Q: We are a town of 37 percent lower income families. Will we
be required to spend, by my estimation, $100,000 per year
to change the carbon?
R: The recommendation to change the carbon in the GAC system
more frequently is a result of updated Safe Drinking Water
Act standards. Every municipal water system will be required
to comply with these new standards. As a result, these
costs should be borne by the utility.
*Q:- When we discovered the contamination, we reached out to the
government for help and we hit a brick wall. We had to
solve our own problem and now we're being penalized. Where
was the information available about the time limitation to
apply for reimbursement under the Spill Fund? I want to
know where the lack of communication was five years ago in
dealing with this problem.
-------
STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Site Identified
and Referred
(5)
Prlorltization
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
(6)
Determination of Lead
(10)
Preparation of
Feasibility
Study
(14)
Cleanup Evaluation
(3) .
Secure Site
(A)
Site Analysis Evaluation
and Assessment
(7) (8)
Community Relations Signing of Contract or
Plan Activated Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Design
(15)
Contractor Audit and
Close out
r TV, . - i.
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ATTACHMENT C
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss
Results of Remedial Investigation/Feasibility Study
at
Rockaway Borough Wellfield Site
Thursday, August 28. 1986
7:}0 P.M.
All Purpose Room - Washington School
Academy Road
Rockaway, NJ
NAME
PLEASE PRINT
AFFILIATION
ADDRESS
7.
8.
9 •
10.
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12.
13.
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting to Discuss
Results of Remedial Investigation/Feasibility Study
at
Rockaway Borough Wellfield Site
Thursday, August 28, 1986
7:30 P.M.
All Purpose Room - Washington School
Academy Road
Rockaway, NJ
NAME
PLEASE PRINT
AFFILIATION
ADDRESS
5. I
/JJZ./5.
J?f V
t^niJ/Abfeff''.
10. >;
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ATTACHMENT D
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
Public Meeting
on
Results of
Remedial Investigation/Feasibility Study
at
Rockaway Borough We11fieId Site
Rockaway Borough
Morris County
Thursday, August 28, 1986
7:30 P.M.
All Purpose Room
Washington School
Academy Street
Rockaway, NJ
AGENDA
1. Opening Remarks;
Introduction of NJDEP Personnel
and Contractor: Science
Applications International
Corporation (SAIC)
2. Overview of Past History
and Current Situation
3. Presentation:
Remedial Investigation/
Feasibility Study
4. NJDEP Recommended
Alternative
5. Comments and Questions
Dr. Merry L. Morris, Assistant Director
Division of Hazardous Site Mitigation
David Paley, P.E., Site Manager
Bureau of Site Management
Division of Hazardous Site Mitigation
Kevin Boyer, P.E., Project Manager
SAIC
Dr. Merry L. Morris
The floor will be open for comments and
questions at this time.
-------
STATE OF NEW JERSEY
DEPARTMENT Of ENVIRONMENTAL PROTECTION
FACT SHEET
Public Meeting
on
Results of
Remedial Investigation/Feasibility Study
at
Rockaway Borough Wellfield Site
Rockavay Borough
Morris County
August 28, 1986
Site Description;
The three contaminated Rockavay Borough municipal wells are located in the
downtown area of the Borough within 1,200 feet of the Rockaway River. The
general area under Investigation extends from the wellfleld to Interstate Highway
80. It includes the wellfield itself, a 40-acre industrial area, residential and
commercial areas, some vacant land, an old Borough dump and a small dump within
the industrial area. The three wells produce over 1.1 million gallons of water
per day and serve approximately 10,000 people.
Elevated concentrations of volatile organics, predominantly trichloroethylene
(TCE) and tetrachloroethylene (PCE), have persisted in the wells since their
detection in 1980. The source of the contamination ±a unknown although a number
of potential sources have been Identified.
Background;
An activated carbon adsorption treatment system, which purifies the contaminated
water, was Installed In July 1981 and is presently being maintained at the
expense of the Borough. The quality of the Borough's drinking water is now well
within regulatory requirements, but PCE, TCE and other contaminants remain in
untreated ground water.
In August 1983 the United States Environmental Protection Agency (USEPA) drafted
a Remedial Action Master Plan and submitted It to the New Jersey Department of
Environmental Protection (NJDEP) for review. The NJDEP and USEPA signed a
Cooperative Agreement In January 1984 to commit $330,000 for a Remedial In-
vestigation/Feasibility Study (RI/FS). The Cooperative Agreement was amended In
July 1985 to commit approximately $421,000 for the RI/FS. A contract to conduct
the study was awarded to Science Applications International Corporation (SAIC),
formerly JRB Associates, of McLean, Virginia. Of 97 New Jersey sites on the
National Priorities List, the Rockaway Borough Well Field is ranked 54th in
priority.
over...
AVu Jersey Is An Equal Opportunity
-------
-2-
Statust
The Draft RI/FS was completed in August 1986. This draft report has been
available to the public since August 18, 1986 at the following repositories:
Rockavay Borough Library, Morris County Public Library in Whippany, Rockavay
Borough Hall, and NJDEP, Division of Hazardous Site Mitigation in Trenton. The
public comment period will extend until September 10, 1986. Any comments on the
study should be submitted to Jeffrey Folmer at NJDEP, Bureau of Community
Relations, CN 028, 432 East State Street, Trenton, NJ 08625. After considering
all public comments, NJDEP and USEPA will sign a Record of Decision detailing
the selected remedial alternative.
Summary of Remedial Investigation/Feasibility Study
The Remedial Investigation included the following activities:
0 Sampling and laboratory analysis of water samples from existing residential,
commercial, industrial and Borough supply wells.
0 Sampling and laboratory analysis of surface water and sediment samples from
Beaver Brook and the Rockaway River.
0 Sampling and on-site analysis of subsurface soil gases to provide an
indication of the presence of PCE, TCE and other volatile organic compounds
in underlying ground water.
0 Drilling and installation of ground water monitoring wells and on-site
chemical screening analysis of soil and ground water samples obtained during
drilling.
0 Sampling and laboratory analysis of ground water monitoring wells.
0 Mapping of ground water flow patterns, evaluating the areal and vertical
distribution of contaminants, and identifying areas that are probable
sources of contamination.
The results of the Remedial Investigation revealed that:
0 PCE and TCE remain the primary ground water contaminants of concern. The
detected concentrations of PCE are consistently greater than TCE, but both
have affected all three Borough wells.
0 Water withdrawn from the Borough wells remains unacceptable for use as
potable water unless treatment to reduce the concentrations of PCE and TCE
. is maintained.
0 There are no significant levels of contamination in area surface water,
soils or subaqueous sediments.
* Contaminants may be emanating from a number of different sources.
* PCE appears to have originated from a commercial area approximately one-half
mile southwest of the wellfield.
* TCE appears to have originated from a light Industrial area approximately
one-half mile northeast of the wellfield.
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-3-
0 Additional investigation is needed to definitively identify the exact
sources of the contaminants.
The remedial action alternatives identified are:
0 Alternative 1; No Action (The Superfund law requires that this alternative
be investigated.)
Entails the pumping of contaminated ground water from the
operating Borough wells directly into the distribution system without
treatment.
0 Alternative 2; Treatment with a Granular Activated Carbon (GAG) System
Entails the continuation of treatment through the existing GAG system with
modifications. The activated carbon would be changed at more frequent
intervals in order to meet current and/or pending water quality standards.
0 Alternative 3; Treatment by Packed Tower Aeration
Entails installing a packed tower aeration air stripping system to reduce
concentrations of PCE and TCE in water withdrawn from the existing wells.
This includes a gas phase carbon adsorption system to prevent PCE and TCE
from being released to the atmosphere.
0 Alternative 4; Treatment by GAC and Packed Tower Aeration
Consists of a packed tower aeration stripping system operating in com-
bination with the existing GAC treatment system.
0 Alternative 5; Replacement Well Field
Involves Installing new water supply wells, the locations and/or depths of
which would be selected with the Intention of avoiding the plume of
contaminants affecting the existing well field.
0 Alternative 6; Purchase of Water from Another Municipal Supplier
Includes the purchase of potable water from future suppliers of the Morris
County Municipal Utilities Authority through either the Dover Town system or
the Denville Township system.
For further information, please contact Jeffrey Folmer of NJDEP's Bureau of
Community Relations at (609) 984-3081.
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-9-
R: Correspondence from EPA to the Rockaway Borough Administrator,
dated April 27, 1983, discussed the procedure for claims
against CERCLA and also informed the Borough to inquire to
the State about the possibility of recovering costs from the
Spill Fund. It was not incumbent upon the State to advise
municipalities of applicable State laws. When contamination
was discovered in Rockaway Borough, the Spill Fund was
administered through the New Jersey Department of Treasury.
At that time, the only NJDEP office which dealt with Spill
Fund issues was the Office of Hazardous Substances Control
which would not have been involved in the installation of
the water treatment system. The Division of Water Resources,
which has perview over potable water issues, was not involved
in utilizing the Spill Fund at that time.
*Q: Can this system ever attain the values in the criteria
table, or are we going to go broke?
R: We feel it is technically achievable with an estimate cost
of $74,000 a year, an increase of $24,000 over current
spending.
Q: When is the next phase of the investigation going to start?
Are you at a stand still until funding is allocated? Who will
pay for Phase II? How do we go about getting that funded?
R: EPA will perform the additional RI/FS. While we hope to
identify the sources of contamination through this effort,
we can not forecast with certainty our success. The funding
for the effort is dependent on the reauthorization of the
Superfund legislation and, consequently, so is any schedule
of investigations. Other funding arrangements with the
State of New Jersey are being considered if Superfund is
not reauthorized shortly. Additionally, if responsible
parties are identified, they are liable for the costs of
the RI/FS. If necessary, we would seek to recover costs
through court action.
Q: Will there be another public meeting?
R: There will be a formal public meeting at the beginning and
the end of the new study, and we will also communicate with
you while work is in progress.
* Questions and comments submitted by Borough Council
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-10-
III. Remaining Concerns
Borough officials and members of the community are disturbed
that neither State nor Federal funding may be available to
cover the capital costs and operation and maintenance costs
for the existing treatment system. There is a feeling that,
although the Borough acted responsibly, it is now being
"penalized".
Disappointment has also been expressed because the RI/FS did
not identify the source(s) of the contamination. A supple-
mental study will be conducted in conjunction with a potentially
responsible party search in a further attempt to positively
identify the source(s) of contamination. If a responsible
party is identified, the Borough may seek to recover both
capital and operation and maintenance costs.
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ATTACHMENT A
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
Public Meeting to Discuss Commencement of
Remedial Investigation/Feasibility Study
at
Rockaway Borough Wellfield Site
Thursday, May 9, 1985
Washington School - All Purpose Room
Academy Street
Rockaway, NJ
Morris County
NAME
1.
AFFILIATION
ADDRESS
6.
X^IU^VCX/ &
11.
12.
13.
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NAME
AFFILIATION
ADDRESS
/n
18.
19.
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fat ft-- C-J:fo.
23.
26.
27.
28.
29.
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ATTACHMENT B
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
Public Meeting
on
Commencement of
Remedial Investigation/Feasibility Study
at the
Rockaway Borough Wellfleld Site
Thursday, May 9, 1985
8:00 p.m.
All Purpose Room
Washington School
Rockaway, NJ
AGENDA
1) Opening Remarks;
Introduction of NJDEP Personnel
Ms. Grace L. Singer, Chief
Office of Community Relations
NJDEP
2) Overview of Past History and
Current Situation; Introduction
of Contractor: JRB Associates
Mr. David A. Paley, Site Manager
Bureau of Site Management
NJDEP
3) Presentation: Remedial
Investigation/Feasibility Study
Mr. Kevin R. Boyer,
Senior Engineer
JRB Associates
P.E.
4) Questions/Answers
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STATE OP NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
FACT SHEET
on
Commencement of
Remedial Investigation/Feasibility Study
at
Rockavay Borough Wellfield Site
Rockaway Borough
Morris County
Kay 9, 1985
Site Description;
The three contaminated Rockavay Borough municipal wells are located in the
downtown area of the Borough within 1,200 feet of the Rockaway River. The
general area under investigation extends from the well field to Interstate
Highway 80. It includes the well field Itself, a 40-acre industrial area,
residential areas, some vacant land, public streets and other related urban
features, an old Borough dump and a small dump within the Industrial area.
Three municipal wells in the Borough were contaminated with volatile organlcs.
Including trlchloroethylene (TCE) and tetrachloroethylene (FCE), from an unknown
source. Currently there is no evidence of surface water contamination, but such
a potential exists due to the close proximity of the wells to the Rockaway
River. The Rockaway Borough wells serve approximately 10,000 people. The
ground water from which the well water is drawn is the sole source of potable
water for Borough residents.
Background;
An activated carbon filtration system which purifies the contaminated water was
Installed in July, 1981 and is being maintained at the expense of the Borough.
The quality of the Borough's drinking water is now well within minimum
regulatory requirements, but PCE, TCE, and other contaminants remain in
untreated groundwater. Monitoring and treatment will continue.
In August, 1983 the United States Environmental Protection Agency (USEPA)
drafted a Remedial Action Master Plan (RAMP) and submitted it to the New Jersey
Department of Environmental Protection (NJDEP) for review. The NJDEP and USEPA
signed a Cooperative Agreement on January 9, 1984 to commit $330,000 for a
Remedial Investigation/Feasibility Study (RI/FS). An amendment to increase this
amount of money is pending. A contract to conduct the RI/FS has been awarded to
JRB Associates of McLean, Virginia.
Of 97 New Jersey sites on the National Priorities List, the Rockaway Borough
Well Field is ranked 49th in priority.
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FACT SHEET
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
ROCKAWAY BOROUGH WELL FIELD
Purpose of the. RI/FS;
0 Ensure that all contaminants In the groundwater have been identified and
that their concentrations are known.
0 Identify interim measures, if needed, to maintain drinking water quality
and to protect the environment.
0 Identify source or sources of the contaminants.
0 Determine the most appropriate method of maintaining a high-quality
drinking water supply for the Borough in the future.
The Study will Include;
9 Sampling and analysis of water from the three Borough groundwater wells.
0 Sampling and analysis of water from private wells.
0 Sampling and analysis of water and sediments from the Rockaway River and
two tributary streams.
0 Drilling and installation of new monitoring wells and further sampling and
analysis of groundwater to determine the direction and location of the
contaminant source or sources.
0 Identification of specific alternative measures that can correct the
problems.
0 Evaluation and ranking of the alternative corrective measures.
0 Selection of the most appropriate corrective measure for review and
Implementation by NJDEP and USEFA.
What can the public do?
0 Provide access to private property for field activities, if requested by
NJDEP.
0 Alert NJDEP or Borough officials of past or present dumping of chemicals or
any other activity that could contribute to or aggravate the groundwater
contamination problem.
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Explanatory Terms
What is "Superfund"?
Superfund Is the common name for the Comprehensive Environmental Response,
Compensation and Liability Act enacted by Congress in December 1980. The Act
authorized the United States Environmental Protection Agency (USEPA) to provide
long-term remedies at hazardous waste sites. The Act established a $1.6 billion
fund, raised over five years (ending in 1985) from special taxes and general
revenues, to accomplish the cleanup of these sites.
What is the National Priorities List (NPL)?
The NFL is a list of the highest priority releases or potential releases of
hazardous substances, based upon State and EPA Regional submissions of candidate
sites and the criteria and methodology contained in the Hazard Ranking System
(HRS), for the purpose of allocating funds for remedial response. Published by
USEPA, the NPL is updated periodically.
What is a remedial investigation?
A remedial investigation Involves field activities for collecting information to
make decisions in controlling contaminants. The Investigation usually includes
sampling and analysis of ground water, surface water, soils, and other natural
and man-made substances for the presence of contaminants.
What Is a feasibility study?
A feasibility study Is an evaluation of alternative remedial measures for
controlling the contaminants and selection of the most appropriate alternative.
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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 meetings are conducted vlth 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 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
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NJDEP RECOMMENDED REMEDIAL ACTION ALTERNATIVE
The following remedial action alternative is being recommended pending comments
from the public and USEPA approval:
0 Maintain the existing granular activated carbon treatment
system, with modified operations which would ensure compliance
with current drinking water standards; spent carbon will be
regenerated off-site.
0 Continue the investigation in an attempt to positively
identify the contaminant source(s) and to further delineate
the full extent of contamination.
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Glossary of Terms
Administrative Consent Order (AGO); A binding legal document^ between a govern-
ment agency and a responsible party. It Is issued by the government in the form
of an order that specifies site mitigation activities to be undertaken by the
responsible party.
Contract; The legal agreement that outlines federal and state government
responsibilities at USEPA-lead sites on the National Priorities List (Superfund
sites) as authorized by the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA).
Cooperative Agreement; An agreement whereby USEPA transfers funds and other
resources to a state for the accomplishment of certain remedial activities at
sites on the National Priorities List (Superfund sites) as authorized by the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
Engineering Design (Remedial Design); Following a feasibility study, an
engineering design Is executed to translate the selected remedy in accordance
with engineering criteria in a bid package, enabling implementation of the site
.remedy.
Focused Feasibility Study (FFS); A limited feasibility study which is performed
on a certain aspect of site remediation and/or when more than one remedial
measure is considered technically viable for the immediate control of a threat.
Immediate Removal Actions (IRAs); Actions taken to prevent or mitigate immediate
and significant risk to human life, health or to the environment.
Initial Remedial Measures (IRMs); Actions that can be taken quickly to limit
exposure or threat of exposure to a significant health or environmental hazard at
sites where planning for remedial actions is underway.
Monitoring Well; A well installed under strict design specifications that, when
sampled, will reveal hydrogeologic data at its point of installation. Monitoring
wells are installed at predetermined locations, usually in groups, to gain
knowledge of site conditions Including; extent and type of ground water con-
tamination, soil types, depth co ground water and direction of ground water flow.
National Contingency Plan (MCP): The basic policy directive for federal response
actions under the Comprehensive Environmental Response, Compensation and
Liability Ace (CERCLA). It sets forth the Hazard Ranking System and procedures
and standards for responding to releases of hazardous substances, pollutants, and
contaminants. The NCP is a regulation subject to regular revision.
National Priorities List (NTL); A list of the highest priority releases or
potential releases of hazardous substances, based upon State and U.S.
Environmental Protection Agency (USEPA) Regional submissions of candidate sites
and the criteria and methodology contained in the Hazard Ranking System (HRS),
for the purpose of allocating funds for remedial response under the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA). Published by
the USEPA, the NPL is updated periodically. Sites on the NPL are cotanonly called
Superfund sites.
over...
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NJDEP: New Jersey Department of Environmental Protection.
NJDEP's Management Plan for Hazardous Waste Site Cleanups; The New Jersey plan
used to develop a work schedule and a systematic approach to remedial action at
hazardous waste sites and discharges of hazardous materials which pose a threat
to public health or the environment.
Remedial Action; (e.g., Removal/Treatment/Construction) The physical action
consistent with the selected remedy for a release or threatened release of a
hazardous substance into the environment. The term includes, but is not limited
to such actions as removal, storage, confinement, protection using dikes,
trenches, ditches, slurry walls, clay cover, neutralization, cleanup of released
hazardous substances or contaminated materials, recycling or reuse, diversion,
destruction, segregation of reactive wastes, dredging or excavations, repair or
replacement of leaking containers, collection of leachate and runoff, on-site or
off-site treatment or incineration, provision of alternate water supplies, and
monitoring required to assure that such actions protect public health and the
environment.
Remedial Investigation/Feasibility Study (RI/FS); The Remedial Investigation (RI)
portion ofa RI/FSin remedial planning involves a physical and other inves-
tigation to gather the data necessary to determine the nature and extent of
problems at the site; establish remedial response criteria for the site; and
identify technical and cost analyses of the alternatives. The Feasibility Study
(FS) portion of a RI/FS in remedial planning involves a study to evaluate
alternative remedial actions from a technical, environmental, and cost per-
spective; recommend the most effective remedy for adequate protection of human
health and the environment; and prepare a conceptual design, cost estimates for
budgetary purposes, and a preliminary implementation schedule for that action.
Responsible Party; Any person who has discharged a hazardous substance or is in
any way responsible for any hazardous substance which the NJDEP has removed or is
removing pursuant to the New Jersey Spill Compensation and Control Act and/or the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
Spill Compensation Fund; The Spill Compensation Fund was created in 1976 vith
enactment of the Spill Compensation and Control Act and became effective on April
1, 1977. It provides compensation to qualified individuals and businesses chat
have suffered damages as a result of a discharge of hazardous substances.
Superfund; Tht common name for the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) enacted by Congress in December 1980.
The Act authorized the United States Environmental Protection Agency (USEPA) to
provide long-term remedies at hazardous waste sites. The Act established a fund
from special taxes and general revenues, to accomplish the cleanup of these
sites.
USEPA; United States Environmental Protection Agency.
NJDEP
7/86
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE. MITIGATION .:
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 major stages
of the cleanup. Local briefings and 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 21-day comment period on the
alternatives during which the feasibility study Is available in local
repositories.
3) The commencement of the removal/treatment/construction stage to advise
of the expected physical remedial action.
4) 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) is the lead agency 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, Bureau of Community Relations (609) 984-3081. At Region II, EPA, the
Community Relations Coordinator Is Lillian Johnson, (212) 264-2515.
t. •?.
c :
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STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Sice Identified
and Referred
(2)
Initial Site Investigation
(3)
Site Secured
Site Analysis Evaluation
and Assessment
(5)
Priorltlzatlon
(6) .
Determination of Agency Lead
(NJDEP or USEPA)
(7)
Community Relations
Plan Activated
(8)
Signing of Contract or
Cooperative Agreement
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(10)
Preparation of
Feasibility
Study
(11) •:
Selection of Remedial
Action Alternative
(12)
Hiring of Contractor
for Engineering Design
(13)
Hiring of Construction/
Treatment/Removal Cleanup
Contractor
(14)
Cleanup Evaluation
(15)
Contractor Audit and
Close out
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ATTACHMENT E
Telephone 627-2000
Borough of Dockaway
MUNICIPAL BUILDING • 1 EAST MAIN STREET • ROCK A WAY, NEW JERSEY 07866
New Jersey Department of
Environmental Protection
Office of Community Relations
CN 028
432 East State Street
Trenton, New Jersey 08625
Attention: Mr. Jeffrey Folmer
He: Feasibility SLudy ~ Rockaway Borough Well Field
Dear Mr. Folmer:
Enclosed for the public record is our "List of Questions and
Concerns" on the "Remedial Investigation and Feasibility Study of
the Rockaway Borough Well Field Site" as prepared by our water
consultants, Lee T. Purcell Associates. Your response to these items
as well as any financial assistance that can be provided to the
Borough regarding our well contamination problem, will be greatly
appreciated.
Very truly yours,
BOROUGH OF ROCKAWAY
David L. Smith
Mayor
DS:
attachment
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LIST OF QUESTIONS AND CONCERNS
The following list of concerns or questions should be made a
part of the public record during the Public Hearing to be held on
August 28, 1986.
1. How .long is the record kept open for public comment from the
date of the public hearing on August 28, 1986?
2. On several occasions in the report,, the Borough's existing
method of treatment, (GAC) is considered by the consultant as
an interim remedial action. Does this mean that there is a
possibility that this method of treatment may be deemed
unacceptable or inappropriate as a result of the studies? If
GAC is no longer considered appropriate as a final solution,
who will pay for the capital cost and O&M cost to date?
3. There are indications in the report of "areas of possible
contamination". Have any specific industries or commercial
establishments been identified as contributing to the pollution
problem?
4. A great deal of time and effort has been expended on this study
and by the Borough of Rockaway since this contamination problem
became known. The report indicates however, that additional
"investigation is needed to definitely identify specific
contaminant sources". Can you say with any degree of certainty
that sources will be identified when these additional
investigations are concluded and is there a projected time
period to complete this so-called "additional investigation",
and who will pay for this additional work?
5. Will there be further studies to ascertain the aerial extent
and depth of contamination, who will conduct these studies and
what is the time frame for completion and who will pay for same?
6. The report refers to on-going investigations of groundwater
contamination outside the Borough of Rockaway which may affect
the Borough water supply. Who is conducting these studies,
what is the projected time frame for completion and will the
Borough be kept appraised of the findings?
7. Is it fair to say that Rockaway Borough is now considered as a
generator of hazardous waste because it is producing spent
carbon media containing PCE, TCE and possibly other VOC's? As
such, who will pick up costs incurred by the Borough to satisfy
the regulatory requirements imposed upon a hazardous waste
generator? If packed tower aeration is utilized with vapor
phase treatment, will these hazardous waste requirements and
attendent annual costs be greatly reduced?
8. Is the alternative of packed tower aeration with vapor phase
treatment, the most cost effective alternative which will satisfy
the public health requirement?
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9. There is a disparity between the total initial capital cost-
surrounding restoration of the Borough's water supply to potable
quality. The Borough contends this initial cost is $700,000
and NJDEP/USEPA is claiming only $504,600. Can you explain the
substantial difference in dollar amounts?
10. No matter which alternative or alternatives are finally selected
for implementation, who will be paying for the costs to date,
the costs for implementing the recommended
alternative/alternatives, both capital cost and recurring annual
costs? Will NJDEP and/or USEPA pick up both the capital costs
and the annual O&M cost for as long as the treatment is required?
11. Are there currently appropriated Federal and/or State monies
to pay for these capital costs and recurring annual O&M costs?
12. Potable water standards for the Borough of Rockaway's treatment
facility have recently been made more stringent resulting in
the carbon media being replaced on a more frequent and thus
more costly basis. Present carbon replacement costs approximate
$50,000/year and this cost could conveivably double. Couldn't
this cost be picked up by USEPA/NJDEP since the standards were
recently made more stringent by these federal and state agencies?
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y!Z'\
'I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f REGION II
"tC 26 FEDERAL PLAZA '
NEW YORK NEW YORK 10278
September 29, 1986
Honorable David L. Smith
Mayor, Borough of Rockaway :
Municipal Building
1 East Main Street
Rockaway, New Jersey 07866
Dear Mayor Smith:
Thank you for your letter to the New Jersey Department of
Environmental Protection (NJDEP) regarding the feasibility
study for the Rockaway Borough Well Field. Your letter and
"List of Questions and Concerns" are appended to the Environ-
mental Protection Agency's Record of Decision (ROD) and are
part of the public record. Included in the Responsiveness
Summary, our formal response to public comment, shall be this
letter of response.
First, I would like to commend Rockaway Borough personnel and
officials for the timely remedial actions they have taken to
restore a safe and reliable drinking water supply to Borough
residents. In addition, we would like to stress that the
remedial investigation will continue to attempt to positively
identify the source(s) of contamination. A responsible party
search will also be conducted.
Specifically, your questions and comments are addressed below.
1. The Public Comment Period was open from August 18 to
September 10, 1986 as specified in NJDEP's press releases
and notices to the public.
2. The existing granular activated carbon (GAC) treatment
system is treating your municipal water supply adequately.
The ROD has recommended a more frequent change of carbon to
comply with the Safe Drinking Water Act standards promulgated
as of November 13, 1985. The GAC system is considered an
appropriate final solution to treatment of the water supply.
It is considered interim in the sense that further remedial
actions may be appropriate to address the source(s) of the
contamination.
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3. At this point in time, three suspected contaminant sources
have been identified. A potentially responsible party
search will be conducted in conjunction with supplemental
remedial investigation and feasibility study (RI/FS)
activities to positively identify the sources of contamin-
ation. As you know, we can not take action against respon-
sible parties without sufficient evidence.
4&5. EPA will fund the additional RI/FS. While we hope to ident-
ify the sources and further define the contaminant plume
through this effort, we can not forecast our success with
absolute certainty. The funding for this effort is dependent
on the reauthorization of the Superfund legislation and,
consequently, so is any schedule of further investigations.
Other funding arrangements with the State of New Jersey are
being considered if Superfund is not authorized shortly.
Additionally, if responsible parties are identified, they
are liable for the costs of the RI/FS. Should it become
necessary, we would seek to recover our expenditures through
a cost recovery action.
6. There are a number of investigations that are being under-
taken by NJDEP that may relate to the contamination of the
Rockaway Borough Well Field. If any conclusions from these
studies affect the Borough, for example if any potentially
responsible parties are identified, the Borough will be
notified promptly.
7. If the Borough contracts with Calgon Corporation to handle
the replacement and regeneration of carbon for its treatment
system, Calgon would need to have all applicable permits
and "further, be responsibile as a hazardous waste generator/
transporter/disposer. Therefore, this should not be a
concern of the Borough. If a packed tower aeration unit
were to be utilized, the operation and maintenance costs,
as listed in the feasibility study, would be approximately
$45,000 per year compared to the carbon treatment system
with a $74,000 annual cost.
8. The ROD has identified the Borough's GAC system as the
appropriate remedy. In comparing the various alternatives,
there was no cost associated with the GAC system because it
was already in operation. Thus, it was determined to be
the most cost-effective alternative. The RI/FS did find,
however, that a somewhat different water treatment system
would be less expensive to operate, namely packed tower
aeration. Because the capital costs of the two systems are
similar and the packed tower aeration unit would be cheaper
to operate, it would have been recommended had the GAC
system not already been installed.
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-3-
9. The $504,600 figure was arrived at by deleting certain legal
and upgrading costs from the $700,000 total expended by the
Borough of Rockaway in 1981. We acknowledge that this was a
judgement call.
10& Your request for reimbursement for the expenses incurred
11. must meet the requirements of Sections 111 and 112 of
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) which authorized Superfund and the
National Contingency Plan (NCP) (40 CFR Part 300) in order
to be compensable as a claim against the Fund. Section
300.25(d) of the NCP provides:
If any person other than the Federal Government or a
State or person operating under contract or cooperative
agreement with the United States, takes response
action and intends to seek reimbursement from the
Fund, such actions to be in conformity with this Plan
for purposes of Section 111(a)(2) of CERCLA may only be
undertaken if such person notifies the Administrator
of EPA or his/her designee prior to taking such actions
and receives prior approval to take such actions.
Section 111(a)(2) of CERCLA provides that the Fund may only
reimburse claims which have been "approved under [the NCP]
and certified by the responsible Federal official."
By requiring the necessary approval and certification before
cleanup begins, EPA can more effectively fulfill its role
as manager of the Hazardous Substance Response Trust Fund
and ensure appropriate responses and sound uses of Fund
monies. The expenses already incurred by Rockaway Borough
may not be reimbursed from the Fund because EPA did not
give its prior approval for these expenditures.
12. Recent Amendments to the Safe Drinking Water Act now require
both PCE (tetrachloroethylene) and TCE (trichloroethylene)
to be treated to 5 parts per billion before distribution
in a public water system. Our estimates for the increased
carbon usage and consequent operation and maintenance costs
are approximately $74,000 per year. Again, these costs
reflect a change in standards for all municipal water treat-
ment system suppliers and, therefore, should be borne by the
Borough.
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If you have any further questions or comments, please feel free
to call me or Christine Beling of my staff at (212) 264-1870.
Sincerely yours,
. -JY
John S. Frisco, Chief
New Jersey Remedial Action Branch
cc: Jeffrey Folmer, NJDEP
Bureau of Community Relations
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