United States
            Environmental Protection
            Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R02-88/075
September 1988
&EPA
            Record of Decision
            Ringwood Mines/Landfill,

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<




REPORT DOCUMENTATION j *.-nfO*T NO. 2.
PAGE j EPA/ROD/R02-88/075
4. Title »nd Subtitle
SUPERFUND RECORD OF DECISION
Ringwood Mines/Landfill, NJ
First Remedial Action - Final
^Author(s)
9. Performing Organization Name and Address

12. Sponsoring Organization Name and Address
U.S. Environmental protection Agency
401 M Street, S.W.
wasnington, u.c. <:U4ou
3. Recipient's Accession No.
5. Report Date
09/29/88
6.
8. Performing Organization Rept. No.
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
300/000
14.
 15. Supplementary Notes
 ls- A^te"c^(ingwoodwoM
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EPA/ROD/R02-88/075
Ringwood Mines/Landfill, NJ
First Remedial Action - Final

16.  ABSTRACT (continued)

surface water in the area.  In July 1982, NJDEP detected moderate levels of VOCs, as
well as naturally occurring heavy metals, in ground water in the northern section of the
site, which had been retained by RRC and a portion used for industrial waste disposal.
The site was subsequently divided into four discrete areas for investigation.  Between
October 1987 and February 1988, Ford International Services, Inc. conducted a removal
action, entailing excavation and offsite disposal of 7,000 yd3 of surficial paint
sludge containing lead and arsenic from four onsite areas.  Subsequent sampling,
however, indicated that soil within a small area (less than one acre) still contains
concentrations of lead and total petroleum hydrocarbons in excess of health-based
levels.  Furthermore, there is sporadic and moderate ground water contamination,
generally confined to paint sludge locations, exceeding MCLs for lead and arsenic.  The
primary contaminants of concern affecting the soil and ground water are arsenic, lead,
and petroleum hydrocarbons.

  The selected remedial action for this site includes:  confirmatory sampling of soil
with excavation and offsite disposal of any soil exceeding health-based levels, followed
by backfilling and revegetation; and ground water, surface water and wetlands
monitoring.  Since ground water in the vicinity of the paint sludge areas in not used as
a drinking water source and natural attenuation is expected to reduce contamination
levels of below health based levels after removal of the source, ground water will not
be treated.  The estimated capital cost for this remedial action is $225,000 with annual
O&M of $50,000.

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                       DECLARATION_STATEMENT

                         RECORD OF DECISION
SITE NAME.AND LOCATION

Ringwood Mines/Landfill, Ringwood Borough, Passaic County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action tor
the Ringwood Mines/Landfill Site in Ringwood, New Jersey, developed
in accordance with the Comprehensive Environmental Response, Com-
pensati.on, and Liability Act (CEhCLA), as amended by the Supertund
Amendments and Reauthorization Act (SARA), 42 U.S.C. §9601 et seq^
and to the extent practicable,  the National Contingency Plan (NCP),
at 40 C.F.R. Part 300.

The attached index identifies the documents' in the administrative
record upon which the selection of the remedial action is based.

The State of New Jersey concurs on the selected remedy.

DESCRIPTION OF THE REMEDY

The remedial action identified in this document is designed to
address potential soil, surface water and ground-water contamination
at the Ringwood Mines/Landfill Site.   A surficial paint sludge
removal .action was conducted at the Site pursuant to a CERCLA §106
unilateral order to remediate soil contamination and to eliminate
the direct contact hazard to human health and the environment.
Under the unilateral order any soil contaminated with lead and total
petroleum hydrocarbon concentrations  that exceed the New Jersey
Cleanup Objectives for Soil will be removed from the Site.

There is no detectable ground-water contaminant plume at the Site,
and contamination is not' entering the surface waters which arain
the Site.

A long-term ground-water and surface-water monitoring program will
be initiated at the Site.  The long-term monitoring program will
last a minimum of thirty years.

The major components of the monitoring program include:

   0 Sampling and analyses of potable wells in the vicinity or the
     Site.

   0 Performance of geophysical surveys in order to determine grouna-
     water flow and optimum placement of monitoring wells.

   0 Performance of soil and rock geochemical surveys to determine
     background concentrations of metals.

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     Sampling and analyses of new and existing ground-water
     monitoring wells, surface waters, and wetlands exiting the
     Site.
DECLARATION

Consistent with the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the selected remedy is pro-
tective of human health and the environment, attains Federal
and State requirements that are applicable or relevant and
appropriate to the remedial action and is cost effective.  This
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this Site.
However,  since treatment of the principal threats of the Site
was not found to be practicable, this remedial action does
not satisfy the statutory preference tor treatment as a
principal element of the remedy.

Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the  remedy continues to provide adequate protection of human
health and the environment.
Date
William J .
Acting Re-gional A
                                                      P . L .
                                                   inistrator

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                        Decision Summary

                    Ringwood Mines/Landfill



 ^.0	Site  Location  and  Description

 The  Ringwood Mines/Landfill Site (the  Site)  consists  of  approx-
 imately 500  acres  in  a  historic mining district  in  the Borough of
 Ringwood,  which  is located  in the northeast  corner  of Passaic
 County/ New  Jersey (Figure  1).   The Site, which  is  about one-half
 mile wide  and one  and one-half  miles long, consists of rugged
 forested areas,  open  areas  overgrown with vegetation, abandoned
 mine shafts  and  surface pits,  small surficial  pits, an inactive
 landfill,  an industrial refuse  disposal  area,  small surficial
 dumps,  a municipal recycling area, the Ringwood  Borough  garage and
 approximately 50 private  homes.   The Mines are located immediately
 west of the  town of Ringwood,  approximately  one-quarter  mile west
 of Ringwood  Manor  State Park and one mile northwest of the  northern
 most segment.of  the Wanaque Reservoir  (Figure  2).

 1.1     Site  Geology

 The  Site is  situated  at the southeastern extension  of the New
 Jersey  Highlands (Figure  1).   The rocks  of the New  Jersey Highlands
 are  chiefly  Precambrian age (more than 600 million  years old)
 banded  gneisses, schists  and  igneous intrusives  or  pegmatites.
 Topography consists mostly  of  northeast-southwest trending  broad-
 topped -parallel  ridges, which  were carved out  by the  continental
 ice  sheet  which  spread  over the area during  the  Pleistocene Epoch,
 approximately 2  million years  ago.  Bedrock  outcrops  are fairly
 common  along the ridges,  but are scarce  in the valleys.   The bedrock
 in the  valleys is  generally covered by unconsolidated and reworked
 glacial deposits.   Folding  is  the primary structural  geologic
 feature in the vicinity of  the  Site and  the  magnetite (iron ore) is
 associated with  the folds.

 The  combined action of  folding,  faulting and glaciation  have all
 had  an  impact on the  hydrogeology of the Site.   Two aquifers have
 been identified  beneath the Site.  The upper aquifer  consists of
 glacial till and overburden and  extends  down to  a depth  of  approx-
 imately 60 feet.   The direction of ground-water  flow  in  the upper
 aquifer is generally  to the south.  Ground-water discharge  from the
 upper aquifer is to surface streams and  the  Wanaque Reservoir.  The
 lower aquifer consists  of fractured gneiss bedrock.   The gneiss
 itself  is  not permeable so  that ground-water flow is  along  fractures
 in the  rock.  The  complex fracture system in the lower aquifer
 makes ground-water flow directions difficult to  predict  (Figure 3).
 The  upper  aquifer  near  the  Site  is not used  as a potable water
 source.  Furthermore, New Jersey State law requires that all wells
 in the  region must withdraw water below  50 feet.  Well yields
 within  the lower aquifer  generally range from  5  gallons  per minute
 (gpm) to 50  gpm.   Better  well  yields are found where  the wells are
 screened within  cross-cutting  fractures.  Hydraulic conductivity
•between the  upper  and lower aquifers is  poor.  Deep monitoring

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                               RINGWOOD MINES/LANDFILL SITE
Figure 1 •-  LOCATION AND  GEOLOGIC .SETTING OF
         '   RINGWOOD MINES/LANDFILL SITE

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,  WANAQUE
'RESERVOIR
     f\
                                                                                NORTH
         Figure 2 - RINGWOOD MINES/LANDFILL SITE
                   DRAINAGE PATTERNS WITH -SEDIMENT AND
                   SURFACE WATER SAMPLE LOCATIONS
SW - SURFACE WATER SAMPLE
SD - SEDIMENT SAMPLE

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Bedrock
Outcrops
         Figure  3
         SCHEMATIC DIAGRAM OF THE GEOLOGY AT THE RINGWOOD MINES/LANDFILL SITE

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wells  (below 100 feet) have shown that fracturing is less evident
as depth increases and where fractures do occur, they are generally
filled with silica.  The existence of perennial streams with relatively
small  drainage basins further implies rejected recharge from the
deep bedrock aquifer  (lower aquifer).

The Highlands in Passaic County are drained by the Pequannock,
Wanaque and Ramapo Rivers which join to form the Pompton River, a
tributary of the Passaic River.  There are three surface water
streams that drain the Site (Figure 2).  They are Mine Brook, Peters
Mine Brook and Park Brook.  Peters Mine Brook joins Mine Brook along
the southern boundary.  Mine Brook flows into Ringwood Creek, just
upstream (north) of the Wanaque Reservoir.  Pa-rk Brook flows into
Ringwood Creek just one mile upstream of its confluence with the
Wanaque Reservoir.

2.0    Site History

The Ringwood Mines are a series of iron ore mines that were operated
almost continuously from the mid-1700s to the early 1900s.  Prior
to 1940, the entire mine area was purchased by the U.S. Government
and administered by the U.S. Government Defense Plant Corporation.
The mine area was subsequently leased to the Alan Wood Steel Company
as part of the World War II effort.  Extensive subsurface mapping
of the mines was conducted during the early 1940s.  In 1956, the
U.S.  Government sold the property to the Pittsburgh Pacific Company,
of Hibbing, Minnesota.  Use of the Site between 1956 and 1965 is
not well documented.  Aerial photographs taken in 1959 indicated
that the mines were in operation at that time.

On January 1, 1965, the Pittsburgh Pacific Company sold the mine
area to the Ringwood Realty Corporation, a wholly-owned subsidiary
of Ford Motor Company (Ford).   The property was administered by
J.I. Keelak Inc. of Trenton, New.Jersey.  A Bureau of Mines Safety
Inspection Report, dated 1-965, indicated that some refuse, including
municipal waste, was already present in the abandoned mining pits
and shafts and recommended procedures for safeguarding the mines.

Beginning in 1967, Ringwood Realty used the site to deposit waste
products from the Ford factory in Mahwah, New Jersey.  These waste
products included, but may not have been limited to, car parts,
solvents and paint sludges.  Some of these wastes were deposited on
the ground surface in both natural and man-made depressions.  Other
wastes were allegedly dumped into the abandoned mine shafts.

In 1970, Ringwood Realty divided the property, donating 290 acres
to the newly-formed Ringwood Solid Waste Management Authority
(RSWMA).  The remaining land (approximately 150 acres) in the
vicinity of Peters' Mine was retained by the Ringwood Realty
Corporation.  A portion of the 150-acre tract was known as the O'Connor
Refuse Disposal Area and it was used for industrial refuse disposal
by Ford which used O'Connor Trucking as the hauler.  Property
records suggest that by 1974,  Ford was no longer sending waste of
any type to the Ringwood Mines/Landfill site, including the O'Connor
Refuse Disposal Area.  In 1973, Ringwood Realty donated the remaining
150 acres of the mine area to the Housing Operation With Training
Opportunity Inc. (How To Inc.).

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In March 1972, the North Jersey District Water Supply Commission,
(NJDWSC), which is responsible for administering the downstream
Wanaque Reservoir and the New Jersey Department of Environmental
Protection (NJDEP), agreed to permit the development of a municipal
refuse area on RSWMA property.  This municipal disposal area,
located near Margaret King Avenue (Figure 4) was supposed to be
limited to municipal refuse and industrial packing and waste parts
from Ford (not including liquid waste, chemical or petroleum products).
In 1976, the NJDEP sampled surface water from the vicinity of the
Municipal Disposal Area and determined that it was contaminated by
leachate emanating from the landfill.  NJDEP closed the landfill in
1976.  Preliminary Assessments were conducted by the United States
Environmental Protection Agency (EPA) and NJDEP between November
1979 and April 1980 for the entire Site.

In July 1982, NJDEP conducted a Site Inspection of the Ringwood
Mines/Landfill site.  Based on ground-water sampling results taken
from waters in the Peters'  Mine shaft which contained moderate
amounts of benzene, ethylbenzene, xylene, chloroethane and bis
(2-ethylhexyl) phthalate, as well as naturally occurring heavy metal
contamination (nickel, cadmium, tin and chromium) found in samples
from Peters'  Mine Brook, the Site scored high enough on EPA's
Hazard Ranking System to be proposed for the National Priorities
List (NPL) in December 1982.  The Site was officially added to the
NPL in 1983.   Pursuant to a March, 1984 Section 3013 Resource
Conservation and Recovery Act (RCRA) Administrative Order on Consent
between EPA and Ford International Services, Inc. (Services),
Woodward-Clyde Consultants (WCC)  was retained to perform the field
studies and conduct a Remedial Investigation (RI).  The RI was con-
ducted in four phases between March, 1984 and April, 1988 under EPA
oversight.

In June, 1987 a Section 106 Comprehensive Environmental Response,
Compensation, and Liability Act unilateral order was issued by EPA
to Services to conduct a Feasibility Study (FS).  WCC was retained
by Services to perform the FS.  In addition, Environ Corporation
was retained  by Services and WCC to conduct an endangerment assess-
ment in order to evaluate any potential risk to public health and
the environment posed by the Site.

Under a separate unilateral Administrative Order issued by EPA in
June, 1987, Services and its contractors in accordance with an EPA
approved work plan, excavated and removed 7,000 cubic yards of
surficial paint sludge containing lead and arsenic from four areas
at the Site.   The paint sludge was disposed of at an out-of-state
facility in compliance with Federal and State regulations.  Paint
sludge removal operations began in October, 1987 and ended in
February, 1988.

In August 1988 at a meeting between EPA and Ringwood Borough
officials, EPA agreed to monitor  potable ground-water wells which .
may have been affected by the Site as part of the proposed remedial
action.

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                                              fcingwood Manor
                                               State Forest
                                                         Furnace Oam Pond
                    alnt Sludge
                          O'Connor Disposal Area
                                      erimeter of
                                      Study Area
Peter's Mine
 Brook
                                    Residential  Lots
                              niclpal  Undfill
                 To Ringwood Cree
                   and  Uanaque Res.
                                                  Rlhgwooo Borough Hall
      Ł
    LEGEND
PAINT SLUDGE
MINE SHAFTS. PITS
STREAM

WETLANDS
                         Figure 6 -, GENERALIZED SITE PLAN
                          RINGWOOD MINES/LANDFILL SITE
                              RINGUOOD, NEU JERSEY

                       SOURCE: TAX ASSESSKNT MAP OF  '
                              BOROUGH OF RINGUOOD
                              6.  MALDO RUDE4ASSOC. 1981
                              AND USGS GREENWOOD LAKE
                            •  VQUADRANGLE
                              f.5 MINUTE SERIES, 1965
                                                                Approx. Scale
                                                                 T • 900'.

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3.0	Community Relations History

The Ringwood"Borough and concerned citizens have been  actively
involved in activities related to the Site since reports of dumping
were first received in the late  1960s.  Ringwood residents and
Borough officials aided NJDEP and EPA in determining sampling
locations for the Preliminary Assessment and Site  Investigation
completed in 1979 and 1980.

Prior- to the paint sludge removal operations in the fall of 1987,
a briefing and pre-removal meeting was held by EPA with potential
removal contractors and Borough  officials.  Some concerns were
expressed at that time about possible hazards (including fire)
related to the removal operations, but these concerns  were addressed
by EPA and removal contractor responses.

During performance of the field  studies for the RI, the Borough
officials were kept informed of  site activities.   In early 1988
following removal activities, local Borough and County health
officials requested that EPA and/or Services conduct ground-water
monitoring of potable wells which might be impacted by the Site.
EPA has informed the public health officials that  monitoring of
site-related potable wells will  take place during  the  Remedial
Action phase.

The RI/FS reports were sent to the Ringwood Borough Library which
is the local information repository.  Upon the library's receipt of
these reports, the .public comment period commenced and was ex-
tended from August 9,  1988 to September 6, 1988.   Copies of the
RI/FS were also sent to the Ringwood Borough Hall.  A  public
meeting was held on August 17, 1988 at which time  EPA  presented
the results of the RI/FS along with the preferred  remedial
alternative' for the Site.  Prior to the public meeting, a briefing
was held between EPA and local Borough officials on August 12,
1988.

4.0	Scope and Role of Response Action Within Site Strategy

The scope of this Record of Decision is to make a  final determination
of appropriate remedial action for the soils, surface waters and
ground waters (upper and lower aquifers) of the Ringwood Mines/Land-
fill site, and to provide for institutional controls (e.g. controls
on the drilling of ground-water wells and/or deed  restrictions)
and long-term monitoring.  A complete description  of the long-term
monitoring program is given in section 4.5.

As discussed above, a removal action was conducted by Services
in 1987-1988, and entailed the excavation and disposal of 7,000
cubic yards of paint sludge contaminated with lead.

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Based on aerial photographs and ground reconnaissance, the Site was
divided into four areas of potential environmental concern.  Area I
(Peter's Mine), Area II (St. Georges Pit/Miller Keeler Pit), Area
III (Cannon Mine), and Area IV (the inactive Borough Landfill).
The selected remedy addresses all of these Areas.

4.1    Area I  (Peter's Mine)

4.11   Soil

Surficial paint sludge containing lead was removed from three
locations totaling nine acres in Area I.  These former paint sludge
locations were sampled and then backfilled with clean soil.  These
sampling results indicated that residual levels of lead (1300 ppm)
and total petroleum hydrocarbons (1060 ppm) may remain within a
less than one-acre area from which paint sludge was removed (see
Tables I &II).

4.12   Surface Water

No significant contamination has been found in the surface waters
of Area I.  The recommended response action is a long-term monitoring
program for at least thirty years to monitor surface water quality.

4.13   Ground Water

4.131  Upper Aquifer

The EPA Maximum Contaminant Levels (MCLs) and New Jersey Ground
Water Quality Standards (NJGWQS) for both lead and arsenic .are 50
ppb.  Lead concentrations in the upper aquifer in two of seven
wells from Area I exceeded  Maximum Contaminant Levels (MCLs) by
a maximum of 35 ppb.  In addition the MCL was exceeded only once
during one of three sampling events.  The arsenic concentration in
one of seven wells exceeded the MCL by 6.6 ppb.  Furthermore, the
lead and arsenic contamination is localized and a ground-water
contaminant plume has not been detected  in Area I.  The upper
aquifer will be monitored to verify that contamination has decreased
to acceptable health-based levels through natural attenuation
processes.

4.132  Lower Aquifer

The lower aquifer in Area I is free of contamination and does not
pose a threat to human health and the environment.  A long-term
monitoring program of both the upper and lower aquifers is recom-
mended to ensure future protection of public health and the en-
vironment.

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                                       TABLE I

            SOIL: SUMMARY OF HAZARDOUS SUBSTANCE LIST METALS DETECTED IN
                         POST PAINT SLUDGE REMOVAL SAMPLES
                            RINGWOOD MINES/LANDFILL SITE
Soil Samples from Former Paint Sludge Locations
Location A

Antimony
Arsenic
Barium
Chromium
Copper
Lead
Nickel
Silver
Thallium
Zinc
A2 A3

1.8 1.5
24 39
18 22
15 46
14 4.0
14 16


35 36
A4

1.7
34
19
30
11
16


36
A5

1.4
25
18
21
25
14


30
A6
0.60
9.6
100
9.1
72
110
15
0.70
19
140
Location B
m
6.3
1.0
400
50
0.778
1300
0.794


97
B2
0.74
0.99
69
21
0.346
40
0.483


33
B3

1.0
54
40
0.319
5.6
0.683


35
Location C
_C3

0.95
58
33
1.38
13
0.460


38
JC7

1.0
39 ''
20
0.546
6.6
0.267


29
Location D
m

1.8
38
16
29
23
14


35
D2

1.7
31
15
16
3.0
14


36
NOTES:  1. Samples collected on 14 and 15 March 1988
        2. Values reported in micrograms per gram (ug/g)

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                                                                     \ LJ 1J L> X i.
                                                 SOIL: SUMMARY OF
                                   OROHK
                            COMPOUNDS DETECTED
                                                     IN POST PAINT SLUDGE REMOVAL  SAMPLES
                                                         RINGWOOO MINES/LANDFILL SITE
                                               Soil Samples from Former Paint Sludge Locations
                                           Location A                 Location 8       Location C
                                                                   Location D
                                A2
        A3
Benzene
Trans-1,2-dlchloroethene
Tetrachloroethene
4-methyI-2-pentanone
M-xylene
0, P-i«ylene

Bis (2 etylhexyl) phthalate
dl-n-butyl phthalate

Phenanthrene
Anthracene
Fluoranthene
Pyrene
Chrysene
Indeno (1,2,3-cd) pyrene
Ben/o (g,h,l) perylene
Benzo (a) anthracene
Ben.ro (b) fluoranthene*
Benro (k) Muoranthene*
Benzo (a) pyrene
Naphthalene
2-methy(naphthalene
A4
               3J
               2J
A5
A6
               IJ
Bl
82
83
C3
C7   Dl
02
                                                    2J
I20J   260J  IOOJ
                     2J
      300J
       7IJ
                            200J
                             35J
                            I90J
                            2IOJ
                            I20J
                             49J
                             56J
                            I30J
                            200J
                            200J
                             99J
        33
        4J
        4J

      5600
      IIOJ

       77J

       65J
       69J
       42J
                                                               2J
      I70J
       42J   94J
                                   I20J
                            46J   360J
                            46J   370J
                                  I80J
                                   66J
                                   77J
                            46J   I70J
                                  320J
                                  320J
                                  I80J
                                   2100
                                   1100
NOTES:   I.  Samples collected on 14 and 15 March  1988
         2.  Values reported In mlcrogram per kilogram  (ug/kg)
         3.  * * Indistinguishable Isomer
         4.  J « estimated value.  This flag Is used when  the mass  spectral data  Indicate the presence of a compound that meets the
            Identification criteria but the result  Is  less  than  the  specified  detection limit but greater than zero.

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                                 12
                                        r


 4.2    Area II  (St. Georges Pit/Miller  Keeler Pit)

 Contaminant concentrations found in all media in Area II  (Soils,
 sediment, surface water, seep water and ground water) were within
 acceptable health based levels.  Long-term monitoring of  surface
 water and ground water is recommended for Area II to ensure future
 protection of public health and  the environment.

 4.3    Area III (Cannon Mine)

 4.31   Soil

 Surficial paint sludge was removed from one location in Area III.
 Total volatile organics exceeded the New Jersey Cleanup Objective
 for Soil by 0.4 ppm in one soil  test pit sample obtained  prior to'
 paint sludge excavation (TP-3, Table III).  Two additional tests pits
 were dug (TP-19 and TP-20) during the post paint sludge removal
 sampling round to confirm that the contamination had been removed
 from the TP-3 area.  The total volatile organics were undetectable in
 TP19 and TP-20; therefore it is  concluded that the soil in Area III
 no longer poses a threat to public health and the environment and
 further remediation of soils is  not necessary.

 4.32   Surface Water

 No significant contamination has been found in the surface waters
 of Area III.  Long-term monitoring of surface water is recommended
 for. Area III to ensure future protection of public health and the
 environment.

 4.33   Ground Water

 Contaminants of concern were not detected in the ground water from
Area III.  Therefore, the ground water does not pose a threat to
 human health and the environment.  Long-term monitoring of ground
 water is recommended for Area III.

 4.4	Area IV (the inactive Borough Landfill)

 4.41   Soil

 No significant soil contamination was detected in.Area IV.  Soil
does not pose a threat to public health and the environment; there-
 fore remediation is not recommended.

 4.42   Surface Water

 Samples taken from the surface streams around Area IV did not detect
contaminants of concern.

 4.421  Seep Water

Seep-water quality is believed to be representative of surface water
quality at the Ringwood Mines/Landfill site.   Seep water  in one
 sample (S-3) taken in 1984 contained mercury contamination

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                                                                       Ill
                                    SOIL: SUMMARY OF ORGANIC COMPOUNDS DETECTED  IN SAMPLES FROM TEST PITS
                                                         RINGWOOO MINES/LANDFILL SITE
                               TP-I     TP-2    TP-3    TP-3    TP-4     TP-4      TP-5     TP-6    TP-7    TP-7    TP-8    TP-9    TP-IO
                                                       (Top            (Leaf                                     (Soil/
                               (Soil)   (Soil)   (Fill)   Soil)    (Fill)   Litter)    (Fill    (Fill)  (Fill)  (Soil)  Fill)   (Soil)  (Soil)
                                NS      NS      NS                                NS     NS      NS      NS                      NS
                                                        34
Benzene
Toluene
Ethylbenzene
Methylene Chloride
I,I,2,2-tetrachloroethylehe
Total Aliphatic Hydrocarbons
Total Alcohols and Ketones
                                                       510
                                                       140


                                                        26
                                                       665
36
81
                                                                                                                        262
NOTES:   I.  Samples TP-I through TP-13, and TP-IS were collected during July 1984
             Samples TP-I6 through TP-I8 were collected on 10 March 1986
             Samples TP-I9 and TP-20 were collected on 15 March 1988
         2.  FllI  = fill soil
         3.  NS =  not submitted.  Organic vapor monitoring did not Indicate the presence of  organic vapors associated with the test pit.
                                  Samples were therefore.not submitted for laboratory analysis.
         4.  Values reported In microgram per kilogram (ug/kg).
         5.  NR =  not reported.  Since paint sludge and associated contaminated soil have
             been  removed, the sample results are not representative of site conditions.
Cd88-l55T4
                                                                                                            Page I  of  2

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                                                                TABLE III  (continued)
                                                SOIL:  SUMMARY OF ORGANIC COMPOUNDS DETECTED IN SAMPLES FROM TEST PITS
                                                                    RINGWOOO MINES/LANDFILL SITE
TP-II
(Fill)
NS
TP-12
(Soil)
NS
TP-13
(Fill)
NS
TP-14
(Paint Sludge)
NR
TP-14 TP-14
(Soil) (Fill)
NR NR
TP-15
(Fill)
NS
TP-16
(FIII-6 ft)

TP-16
(FIII-8 ft)

TP-17
(Fill)
NS
TP-18
(Fill)
NS
TP-19
(Fill)

TP-20
(Fill)

Benzene
Toluene
Ethylbenzene
Methylene Chloride
I,1,2,2-tetrachloroethylene
Total Aliphatic Hydrocarbons
Total Alcohols and Ketones
20
NOTES:   I.  Samples TP-I  thorugh TP-13, and TP-15 were collected  during  July  1984
             Samples TP-16 through TP-18 Mere collected on 10 March  1986
             Samples TP-19 and TP-20 were collected on 15 March 1988
         2.  Fill = fill soil
         3.  NS = not submitted.  Organic vapor monitoring did not Indicate  the  presence of organic vapors associated with the test pit.
                                  Samples were therefore not submitted  for  laboratory  analysis.
         4.  Values reported In mlcrogram per kilogram (ug/kg).
         5.  NR = not reported.  Since paint sludge and associated contaminated  soil have
             been removed, the sample results are not representative of site conditions.
 cd88-155T4
             Page 2 of 2

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                                 15


above the MCL.  Subsequent sampling and analysis conducted in
March, 1988 did not show detectable mercury contamination.  There-
fore, it was concluded that seep water does not pose a threat to
public health and the environment.

Long-term monitoring of surface water in Area IV is recommended
to ensure future protection of public health and the environment.

4.43   Ground Water

4.431  Upper Aquifer

Contamination was not detected in the upper aquifer in Area IV.
The upper aquifer does not pose a threat to human health and the
environment.

4.432  Lower Aquifer

Benzene concentrations were above MCLs in two of eleven samples
from one lower aquifer well in Area IV.  These two samples are not
statistically valid because two subsequent sampling events taken in
1986 and 1988, did not reveal benzene concentrations in detectable
amounts.  Therefore the lower aquifer does not pose a threat in Area
IV.  Long-term monitoring of both the upper and lower aquifers is
recommended to ensure future protection of public health and the
environment.

4.5    Description of Long-Term Monitoring Program

The long-term monitoring program will be designed to monitor on-
site and off-site ground-water and surface-water quality to ensure
the future protection of public health and the environment.

A geochemical study of the soils and rocks at the Site will be
conducted in order to determine the background concentrations of
metals.

Presently ground-water wells are required by the NJDEP to be
screened at a depth of at least fifty (50) feet.  Ground water in
the vicinity of the former paint sludge disposal areas is not
used as a drinking water source.  Residences in the area are serviced
by a public water supply.

Specifically, the monitoring network will include all potentially
affected drinking-water wells and surface-water tributaries leading
to the Wanaque Reservoir.  A separate geophysical study will be
conducted to optimize the location and placement of monitoring wells.
The geophysical study should include a surficial fracture-trace
analysis as well as subsurface reflection seismograph analyses to
locate fractures within the deep bedrock.

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                                16
5.0	Summary of Site Characteristics

Six different media were sampled during the RI:  seep water/ soils,
overburden (upper aquifer) ground water, deep bedrock ground water,
surface water and stream sediments.  As previously stated, WCC
divided the Site into four areas of potential environmental concern:
Area I (Peters Mine), and Area II (St. Georges Pit/Miller Keeler Pit),
Area III (Cannon Mine), Area IV (the inactive Borough Landfill).
These Areas were delineated based upon aerial site reconnaissance,
previous site history information and geologic mapping.  Each Area
was investigated separately to ensure that all portions of the Site
which were potentially impacted, could be properly characterized.

5.1	Ground-Water Investigation

The monitoring wells at the Site range in depth from 14 feet to 543
feet below ground level.  Seventeen upper and four lower aquifer
monitoring wells were installed and sampled.

Existing data indicate that at Ringwood, as well as other areas in
the New Jersey Highlands, bedrock permeabilities typicallly decrease
with depth; that is the tightness of the rock mass increases with
depth.  Even though fractures exist within the bedrock, the frequency
of these fractures decreases with depth (Figure 3).  Therefore, the
potential for water transmission also decreases with depth.  Bedroc
permeabilities below 100 feet reported in the Phase II RI investi-
gat ions averaged on the order of 1x10~5 centimeters per second.
Based on these permeabilities, as well as investigations of the same
rock at other areas in New Jersey, there is very low potential at
deep depths for water flow and associated transport of contamination.

Only where vertical faults/fractures are encountered and are open
to flow is significant ground water found.  Fractures found at
depth which are filled with silica will not transmit water.  A
geologic study was conducted as part of the Phase I RI investiga-
tions to locate possible faults, fractures or joints.  Four deep
lower aquifer monitoring wells were located to investigate these
faults or joints.  A total of five faults were detected.  Water
production did not increase significantly in the wells when these
faults were encountered.  Therefore, it can be concluded that the
faults do not serve as a good conduit of water and associated
contamination.

The upper aquifer consists of an upper zone of glacial fill plus
a lower zone of fractured gneiss bedrock.  These fractures were
probably caused by buckling of the bedrock during geologic uplift
and erosion.   The lower fractured bedrock unit however is less
permeable than the upper unit.  Permeability of the bedrock unit
for both the upper and lower aquifers depends on the fracture

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                                17


frequency and spacing which generally decrease with depth.

Arsenic, cadmium, chromium, iron, lead, manganese and zinc are metals
found in ground water which exceed the MCLs at the Ringwood Mines/
Landfill site (Table IV).  Chromium, iron, manganese and zinc are
all related to the iron ore, magnetite.  Magnetite is part of a
mineral group called the Spinels.  Spinels are metallic oxides in
which metallic cations can substitute for each other within the
chemical framework of the mineral.  These metallic cations may
include chromium, iron, manganese and zinc.  As a result of this
substitution, all of these metals are considered to be naturally
occurring substances at the Site.  Since these metals are naturally
occurring, they are not considered a threat to public health and
the environment and are not addressed further.

A summary of contaminants which exceeded applicable or relevant and
appropriate standards (ARARs) is listed in Table V and these con-
taminants are addressed below by Area.

5.11   Area I (Refer to Table V)

Arsenic concentrations in the upper aquifer exceed the MCL by 6.6
ppb in one sampling round from one well in Area I.  Arsenic con-
centrations in all wells were below the MCL in two additional
sampling rounds.

The cadmium concentration in the lower aquifer exceeded the MCL
by 10 ppb in one well during the first sampling round.  Cadmium
was not detected in any well in two subsequent sampling rounds.

Lead concentrations exceeded the MCLs by a maximum of 35 ppb in
three of seven wells in the upper aquifer.  In each of these wells
lead was detected in only one of three sampling rounds.  This lead
contamination was most likely a result of residual contamination
following the paint sludge removal.

5.12   Area II

Ground-water contaminants did not exceed MCLs or other ARARs in Area II

5.13   Area III

Contaminants of concern did not exceed MCLs or other ARARs in Area III.

5.14   Area IV

Benzene concentrations exceeded the New Jersey Interim Action Levels
for Drinking Water by 19.3 ppb in two of eleven samples which were
taken in 1984 from one lower aquifer well.  In two subsequent sampling
events, benzene concentrations were not detected.

A ground-water contaminant plume has not been identified for any of
the contaminants found in any of the Areas at the Site.  Results of
the RI indicate that ground-water contamination occurs at a low level,
and is scattered and generally confined to paint sludge locations.  No

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                                               TABLE IV

                 SUMMARY OF CONTAMINANTS FOUND IN GROUND-WATER MONITORING WELLS
                                        RINGWOOD MINES/LANDFILL SITE



Arsenic
Cadmium
Chromium
Iron
Lead
Manganese
Zinc
Benzene
Arsenic
Cadmium
Chromium
Iron
Lead
Manganese
Zinc
Benzene
OB-1 OB-2 OB-3 OB-4
1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd
' _M JL



1.1 A. 6 NT 9.3 NT NT NT 33 NT

0.12 0.44 NT 0.14 NT NT NT 4.1 NT
0.01 NT 0.01 NT 0.04 NT
•
OB-7 OB-8 OB-9 OB-10
0.007 0.0106 0.031
NT
NT
7 NT 13 0.45 NT NT NT 9.5 NT
0.065
0.042 NT 1.9 0.32 NT NT NT 5.4 NT
0.01 NT 0.1 NT .054.088 .6 NT

OB-5
1st 2nd 3rd




31 NT

1.1 NT
NT

OB- 11
0.006


. 20 NT NT
0.06
2 . 9 NT NT
0.02 NT 0.046

OB-6
1st 2nd 3rd




4.1

0.09
0.02

OB-12



NT NT

NT NT
0.011 NT NT

NOTES:  1. First (1st), second (2nd), and third (3rd) refer to rounds of sampling
           First round samples were collected during August and -September 1984
           Second round samples were collected during June 1986
           Third round samples were collected during March 1988
        2. Values are reported in milligrams per liter (mg/1)
        3. NT = not tested
        4. U  = unfiltered
        5. F  = filtered (in the field)

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                                               TABLE IV (continued)
                                        «t

                                        *
                          SUMMARY OF CONTAMINANTS FOUND tf^ROUND-WATER MONITORING WELLS
                                           RINGWOOD MINES/LANDFILL SITE
OB- 13
1st 2nd 3rd

OB-14A OB-14B OB-15A
1st 2nd 3rd ' 1st 2nd 3rd 1st 2nd 3rd
U F U F
OB-15B
1st 2nd 3rd
U F
Arsenic
Cadmium
Chromium
Iron
Lead
Manganese
Zinc

Benzene
      NT
    0.027
NT
NT
NT

NT
NT
                        0.015 0.0566 0.0294
  NT

  NT
0.078
  NT
  NT
  NT
0.085
  NT
  NT
NT
NT
NT

NT
NT
0.0036
       NT  NT
       NT  NT
  NT   NT  NT

  NT   NT  NT
0.032  NT  NT
        0.0022


          NT   NT  NT

          NT   NT  NT
   0.021
RW-1
1st
2nd
3rd
1st
RW-2
2nd

3rd

1st
RW-3
2nd

3rd

1st
RW-4
2nd

3rd
Arsenic
Cadmium
Chromium
Iron
Lead
Manganese
Zinc

Benzene
NT
NT
NT
NT
NT
NT
NT
        NT
        NT
        NT
        NT
        NT
        NT
        NT
       NT
       NT
     NT
     NT
       NT   NT
      0.074 0.04Q
    0.02

    0.16
    0.05
    0.13
    0.02
             0.058
         NT   NT     0.42   NT

         NT   NT            NT
      0.018 0.037    0.03
NT
NT
NT
NT
NT
NT
NT
NOTES:  1.  First (1st),  second (2nd), and third (3rd) refer to rounds of sampling.
            First round samples were collected during August and September 1984.
            Second round samples were collected during June 1986.
            Third round samples were collected during March 1988.
        2.  Values are reported in milligrams per liter (mg/1) except for methylene  chloride which is reported in
             micrograms per liter (ug/1).
        3.  NT - not tested
        4.  U  - unfiltered
        5.  F  = filtered
        6.  *  = See table V   for benzene values

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                                                                                      TABLE  V
                                                                     SUMMARY OF  ARAR/CRITERIA  EXCEEDANCES
                                                               ADDRESSED  AT  RINGWOOD  MINES/LANDFILL SITE
WCC's ENVIRON'*
Area Area Constituent
1 Paint Sludge lead
location 0

1 Paint Sludge Cadmium
location D

1 O'Connor Arsenic
Disposal Area

1 O'Connor lead
Disposal Area


t
III- Municipal B«n/ene
IV landllll
Sampling Results by Round (ppm)
Sample 3rd ARAR/Crlterla
location Media 1st 2nd U f Title
OB- II GW 0.06 NO NO NO MCI
NJGWOS
NJCGWPR
RM-3 CW 0.0? NO NO NO MCI
NJGVOS
NJCGWPR
OB-HA CW - 0.01? 0.0)66 0.0?9« MCI
NJGWOS
NJCGWPR
08-UA O - NO 0.085 NO MCI
O9-9 CW NO 0.065 NO NO NJGWOS
NjCCwPR


RW-? CM 0.009* NO NO NJIAIDW

ARAR/Crlteria
Value
0.0)
0.05
0.05
0.01
0.01
0.01
0.05
0.05
0.05
0.05
0.05
0.05


0.00066

Comment (s)
• Fill nail screened across material >hlch
may be mine tailings.
• Detected in unllltered sample.
• Detected In unllltered sample
• Not detected In any other ground water.
seep and surface water samples
• Fill «ell apparently screened across 'III
soil and debris associated «ifh the
O'Connor OlSDOSSl »rea
K
C
• fill «eM apparently screened across II II
soil sod debris asioc'a'ed «lth f>e
O'Connor DISPOS9' *re> l09-'*»)
• De'ec'ed In uniiitfed samples

• Presence no* confirmed In subsequent
rounds
NOUS:    I.   Table based on Risk Assessment  perlorned by (NVIRON (I9HBI.
         ?.   Conccntra* Ions reported In ppi  ("K)/l  lor oater a»d «q/vq  lor soil and sedi«>«nt).
         J.   The sa«p'es »ere analyfed lor t^lal chromium.  We conservatively a%su«>ed  i»a» 'he chromium »as present In »ha more »o«lc he.avalenf form.
         4.   The concentration lor benrene In  Pw-?  Is an average ol  *he selective /one simples calculated by (NVIRON (19Q9I.
         5.   U • Unllltered
         6.   r • filtered (In the Held)
         7 .   ARAR:                                                                         Npn-Prc«»uli]/»ted Criteria :
             NJGWOS  •  He.  Jersey Ground w/»»er 0*j«  Jersey Criterion lor r,ro>>" Jrrser Ground w/)ier Cleanup Criteria
             MCI     •  USfP» Mfl.lmt.m Con t j|" < "In t  l»vel I or O' i "k I ng W/»ler                    NJI»IOW •  Me» Jt'\er Interim «CI'O" levels lor Drinking Mute'
             MJ»WOC  •  Ne.  Jersey «mbie"t filer Qiulit, Criteria                            AwQC    •  USIP« 'moment Mjter Quality Criteria
         8.   *   • ol ten selective /o"e s^">pie^. only  t.o hit-.,  the m««lmum concentration Is'reported.
         9.   GW  • ground •lie'
         10.  NO  • not detected

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                                 21

detectable migration of ground-water contamination has been  identified
at the Site.

5.2	Surface Water Investigation

There are three surface water streams that drain the Site  (Figure 2).
WCC measured stream flows from these streams on five different
occasions so that seasonal variations could be considered.

Three rounds of surface water sampling were conducted and  a  summary
of the analytical data results is presented in Table VI.

Iron and zinc consistently exceeded ARARs, but as explained  in the
Ground-Water Investigation section, these metals are naturally
occurring substances.

5.21   Seep Water Sampling

As previously mentioned, seep water quality is believed to be
representative of surface water quality.  Mercury contamination
exceeding MCLs was found in one  seep water sample from Area  III in
1984.  Subsequent sampling events did not detect mercury contamin-
ation.

Surface water quality at the Site is acceptable and contaminants
are not affecting the downstream Wanaque Reservoir.

5.22   Stream Sediment Sampling

Arsenic .was found in stream sediment samples from Park Brook and
Peters Mine Brook.  The highest concentration found was 31 mg/kg.
Arsenic concentrations as high as 13.5 mg/kg were found in upstream
samples.

5.3    Soil Investigation

Soil test pits were dug in each Area.  In one soil test pit  sample
from Area III taken prior to the paint sludge removal, total volatile
organics exceeded the New Jersey Cleanup Objective for Soils by 0.4
ppm.   Two additional test pits were dug following the paint  sludge
removal and the total volatile organics were undetectable  in these
test pits.

5.31   Paint Sludge Waste

Paint sludge was identified at four locations at the Site  (Figure 4).
As part of the Paint Sludge Removal Program, the paint sludge from
each of the four locations was sampled and analyzed to determine
a waste classification.  Based on these analyses, the sludge was
identified as EP toxic for lead.

After excavating the paint sludge, soil samples were taken from
the excavated surfaces of each of the former paint sludge  locations.
One sample,  B-l, contained concentrations of lead and total petroleum
hydrocarbons that exceed the non-promulgated NJDEP  Cleanup Objectives

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                                                    TABLE VI

                              SUMMARY OF CONTAMINANTS FOUND IN SURFACE WATER SAMPLES

                                          RINGWOOD MINE/LANDFILL SITE



Arsenic
Barium
Calcium
Iron
Manganese
Zinc
Di-n-
octylphathalate



'Arsenic
Barium
Calcium
Iron
Manganese
Zinc
Di-n-
octylphathalate
NOTES :
1. First (1st)
SW-1
1st 2nd 3rd
U F


4.3 4.2 NT NT
0.11 0.064 NT NT
NT NT



SW-7
1st 2nd 3rd



24 31
3.1 0.24
1.7 0.053
0.31



, second (2nd) ,
SW-2
1st 2nd 3rd
U .F
0.04

5.0 4.2 NT NT
0.27 0.15 NT NT
0.03 0.02 NT NT
0.049


SW-8
1st 2nd 3rd
U F


5.1 5.3 NT NT
0.17 0.26 NT NT
0.026 NT NT
0.086

14

SW-3 SW-4
,1st 2nd 3rd 1st 2nd 3rd



5.1 5.6 11 15
0.29 0.12 0.94 0.19
0.23 0.12
0.13 0.091


SW-9 SW-10
1st 2nd 3rd 1st 2nd 3rd



14 13 14 12
2.4 1.0 1.7 0.44
0.29 0.25 0.12
0.01 0.52 0.07

18

. SW-5 SW-6
1st 2nd 3rd 1st 2nd 3t
U

C
6.6 8.7 16 24 NT
0.33 0.18 4.2 3.0 NT
0.06 0.03 1.4 1.2 NT
0.19 0.01 0.31 0.


SW-11 SW-12
1st 2nd 3rd 1st 2nd 3rd
U F U


NT NT NT
NT NT NT
NT NT NT
0.039 0



and third (3rd) refer to rounds of sampling
3.
4.
5.
First round samples were collected on 10 July 1984
Second round samples were collected on 3 April 1985
Third round samples were collected on 17 March 1988
Values are reported in milligrams per liter (mg/1) except for Di-n-octylphathalate which is reported in
micrograms peV liter (ug/1).
NT - not tested
U - unfiltered
F - filtered

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for soil.  In sample Bl lead was reported at a concentration of
1,300 ppm and total petroleum hydrocarbons were reported at a
concentration of 1,060 ppm (Table II).  The NJDEP Cleanup Objective
for lead ranges from 250 to 1,000 ppm, and the objective for total
petroleum hydrocarbons is 100 ppm.  This location was backfilled
with three feet of clean soil; however, it still poses a threat to
public health and the environment as access to this location is
unrestricted.

6.0    Summary of Site Risks/Contaminant Pathways

The RI/FS studies at the Site and the surrounding area indicate
that there are limited pathways for the migration of contaminants
associated with site disposal activities through local soils,
ground water and surface waters.  A discussion of the locations and
media (soil, sediment, seep water, surface water, and ground water)
where contaminants were detected, and a separate evaluation of
potential impacts to public health and the environment are contained
in the document entitled An Assessment of the Human Health and
Environmental .Risks Associated With the Ringwood Mines/Landfill
Site, by Environ Corporation.

Environ Corporation, under contract to Woodward Clyde Consultants
and Ford International Services, Inc., performed a risk assessment
for the Site.  Numerical estimates of risk were calculated for
sixteen indicator chemicals1 for each potential route of exposure,
on the basis of Acceptable Intake for Chronic Exposure (AIC) or
Cancer Potency Factors (CPFs) and the human intakes estimated for
each exposure scenario.  For the Site, the potential health risks
were evaluated for the following indicator chemicals: benzene,
benzo[a]pyrene, methyene chloride, 1,1,2,2-tetrachloroethylene,.
arsenic, barium, cadmium, chromium, copper, lead, manganese, mercury,
nickel, selenium, thallium and zinc.

In the risk assessment, individual contaminants were separated into
two categories of chemical toxicity depending upon whether they
cause carcinogenic or non-carcinogenic effects.  In the case of
chemicals exhibiting carcinogenic effects, exposure and associated
risks were expressed in an exponential nomenclature; 1 X 10~4 (one in
ten thousand), 1 X 10~7 (one in ten million) etc.2

For chemicals exhibiting non-carcinogenic effects, exposure and
associated risks are expressed as a ratio.  This ratio was determined


1 Indicator chemicals for the Site were chosen using the ranking scheme
described in the Superfund Public Health Evaluation Manual (USEPA
1986).   This ranking scheme incorporates information on each constitu-
ent chemical's toxicity, concentration, environmental persistence
and mobility, in order to select those constituent chemicals predicted
to have the greatest impact on human health or the environment.

2 EPA considers health risks between 10~4 and 10~7 to be acceptable,
with risks below 10"^ considered negligible and risks above 10~4
considered unacceptable.

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                                  24


by dividing the maximum daily dose (MDD) that would be encountered
on site, by the AIC for each chemical compound.  The AIC represents
the amount of a compound that an  individual can be exposed to on a
daily basis over a long period of time, with no adverse health
effects.  When this ratio does not exceed one (1.0), non-carcinogenic
health effects would not be expected to occur under those conditions.

Health risks due to exposure to ground water, surface water, sediments/
seep water and soils were considered for the Site.  Highly conserva-
tive exposure scenarios were utilized in estimating contact with each
media.  For ground-water ingestion, for example, it was assumed that
individuals would drink only the most contaminated ground water
identified in each area over a seventy-year lifetime.

The risk assessment concluded that lifetime ingestion of arsenic
present in ground water from three sampling locations in the upper
aquifer, lifetime ingestion of lead and thallium in two of the same
sampling locations in the upper aquifer, and lifetime ingestion of
cadmium and lead from one sampling location in the lower aquifer would
pose unacceptable health risks.   It is noted however, that much of
the contamination appeared only sporadically in the sampling, and
was clearly not widespread throughout the Site.  Additionally, the
residents of Ringwood receive water from a municipal water supply,
and NJDEP will not permit installation of wells to minimize the
possibility of any future use of water from the upper aquifer.
Furthermore, natural attenuation processes should bring the sporadic
contamination down to health-based levels.

EPA determined further that the. presence of residual soils from the
paint sludge removal action in a small area around soil sample
Bl, could potentially pose a health risk over time, and EPA will
confirm this contamination through resampling, and, if necessary,
supervise the removal of these soils from the Site.

The risk assessment determined that exposure to other site soils
and surface water does not present significant risk to public
health and the environment.

Table VII lists compounds and their current pathways where a risk
greater than 1 X 10~6 and a MDD/ADI ratio greater than one was
estimated.

7.0    Documentation of Significant Changes

EPA's preferred alternative as documented in the Proposed Remedial
Action Plan (PRAP) was the No Further Action with Long-Term Periodic
Monitoring alternative.  This alternative has been altered because
a Health Consultation conducted by the Agency for Toxic Substances
and Disease Registry (ATSDR)  has shown that soil in a small portion
of Area I may pose a threat to human health.

Post paint sludge removal sampling revealed that one soil sample

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                                                            SUMMARY  OF POTENtlAL  PUBLIC  HEALTH  CONCERNS
                                                            ADDRESSED  AT  RINCWOOD MINES/LANDFILL  SITE
rfCC's
Sampling Results fly Round (ppm)
ENVIRON'S Sample • i» d
Area Constituent location Media 1st 7nd U F
1 i I e t i me
Cancer
Risk
Ma* Imum
MOO/A'JI Exposure
Ratio Scenario Comments
Exis;
Path-
Yes
I      Paint  Sludge   Arsenic
      location A

I      Paint  Sludge   Arsenic
      Ioc a 11 on 0
                                    O8-15B
09-11
                                                GW
           CM   0.006
                                                            0.00?
                         NO
                                                                      NO
                                                                                NO
                                            NO
                                                                                        1.01 K 10"
                                                   7.74  >  10"
Assumes  Ingest Ion of  upper
OQuller  ground water.

Assumes  Ingest Ion ol  upper
aquifer  ground water.
Detected In unllltered sample.
Does not e»ceed AHAR/Crlterla.

Fill *ell  screened across material
which may  be mine tailings.
Does not e»ceed *B»R/cnt«r|8.
Detected In unllltered sample.
      Paint  Sludge  . lead
      location D
                                     08-11       GW   0.06     NO      NO
                                                                                NO
                                                                 7.5?   • Assumes Ingestlon ol upper
                                                                        aquifer ground water.
                            Fill well screened  across material
                            which may be mine tailings.
                            Delected in unllltered sample.
      Ps'it  Sludge   Thai 11 urn
      local Ion D
                                     08-11       GW   0.01
                                                                      NO
                                                                                NO
                                                                 I*. 7   • Assumes Ingestlon ol upper
                                                                        aquiler ground water.
                            Fill well screened  across material
                            which may be mine tailings.
                            Detected In unliltered simple.
      Paint Sludge   Cadmium
      location 0
                                     RV-3       GW   0.07     NO      NO
                                                                                NO
                                                                 4.06   • Assumes IngestIpn ol lower
                                                                        aquiler ground water.
                            Detected In unliltered sample.
                            Not delected In any  other ground
                            water, seep and surlace water samples.
      Paint Sludge   lead
      local Ion 0

      Paint Sludge   Chromium
      location 0     (see not* B)
                                     RW-J       GW    0.0)     NO      NO
                                                                                NO
 RW-J       GW     NO      NO      NO       0.058
                                                                 7.1}   • Assumes Ingestlon ol lower
                                                                        aquiler ground  water.
                            Detected In unllltered sample.
                            Does not e«ceed ARAR/Crlterla.

                            Detected In tillered  sample only.
                            Not detected In any other ground
                            water, seep and *ur(ace  water sample*.

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                                                               S'JMMARY  OF  POTENTIAL  PUBLIC HEALTH  CONCERNS
                                                               ADDRESSED AT  RINGWOOD MINES/LANDFILL  SITE
Sampling Results By Round (pp(*o lifetime Ma«lmum
rfCC's ENV IRON'S
*rea Area Constituent
1 O'Connor Arsenic
Disposal Area


1 O'Connor Arsenic
Disposal Area


1 O'Connor Lead
Disposal Area
II- Municipal Ben/ene
Land! II 1


Sample
location
OB-MA
08- MB
OB-9
OB-IO
SD-9

SO- 10

08-I4A
08-9
RW-7



3rd Cancer MOD/'Dl t-oosure ^XIJ
Media 1st 7nd U
CM - 0.01) 0.0)66
GW - 0.0)6 NO
GM 0.007 O.OIO6 NO
CW O.OJI - NO
SED J1.4

SEO 77.3

GW - NO 0.08)
C* NO 0.06) NO
GW 0.009* NO NO



f Risk Ratio Scenario
0.0794 7.59 » 10 - • Assumes Ingestlon ol upper •
NO aquifer ground water.
NO
NO
1.3? » 10 • Assumes dermal contact •
wl th sediment.
-A
4.6) « 10 • Assumes Incidental
Ingestlon of sediment.
NO - 3.)7 • Assumes Ingestlon ol upper •
NO aquiler ground water. •
7.J8 « I0~6 - • Assumes Ingestlon ol lower •
aqul fer ground water
4.7) • 10 and Inhalation while
shower 1 ng.
Comments
Risk based on concentration
In 08.I4A.
Do not e»ceed ARAR/Crl ter la
(O8-I4B. 08-9, and 06-10).
Constituent occurs naturally. ^
concentration eq--i'-'sle"- -~ fcarXcrs-nc


Ratio based on concentration In OB-MA.
Detected In unliirered samples.
May be an artifact ol sampling.



OIES:   I.  Table based on Risk Assessment performed by ENVIRON  (1988).
       7.  Concentrations reported In ppm (mg/l for water, and  ng/kg lor soil end sediment I.
       3.  The concentration lor ben/ene In RW-? Is an average  ol the selective /one samples calculated by ENVIRON  (1988).
       4.  U • Unl11tered
       ).  r - filtered (In the Held).
       6.  • • O» ten selective /one samples, only two hits. The mo«l«u« concentration Is  reported.
       7.  NO • Not  Detected*
       8.  The samples were enaly/ed lor total chromium.  We conservatively assumed that chrc-lu- -as present In  the -ore to.lc he.evelent form.

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                                 27


(Bl) in Area I contained lead and total petroleum hydocarbons which
exceed the health-based levels (see Table I).  The remedial action
will now include confirmatory sampling and excavation and off-site
disposal of this soil.  The removal area will then be graded, back-
filled with clean soil and revegetated.  The capital cost for this
action is estimated at $75,000.

8.0	Description of Alternatives

A Feasibility Study (FS) was initiated in March 1988.  The FS eval-
uated various alternatives for site cleanup based upon the findings
of the RI.  Four ground-water alternatives were developed which
addressed the localized and low level contamination in Areas I, III
and IV.  These alternatives are described in the FS document and in
the Proposed Remedial Action Plan.

As documented in the Summary of Site Risks section of this document,
the ground water at the Site currently does not pose a significant
risk to human health and the environment.  Therefore, alternatives
discussed in the FS for ground-water remediation are not included
in the Record of Decision and only alternatives and proposals which
address the threats posed by the Site are described in this document.

8.1    Proposal for Confirmatory Sampling Then Removal of Soil,
Backfilling, Grading and Revegetation in Area ~T

As stated in the Site History section of this document, 7,000 cubic
yards of surficial paint sludge were excavated and removed by Services
under.a unilateral Administrative Order issued by EPA in June, 1987.
Post removal sampling revealed that soil within a small portion of
Area I (less than one acre) still contained lead and total petroleum
hydrocarbon concentrations in excess of health-based levels.
Confirmatory sampling will be performed in order to verify the
results of the post-removal sampling.  If these results are verified,
then the remaining contaminated soil exceeding health-based levels
will be removed from/and around the location of post paint sludge
excavation sample Bl and transported to a RCRA hazardous waste
facility.  The area will be resampled, then graded, backfilled with
clean soil and revegetated.

The lead concentration in sample Bl was 1,300 ppm.  The NJDEP
Cleanup Objective for lead in soils is from 250 to 1,000 ppm.  This
proposal is expected to reduce the lead level to below 250 ppm.

The total petroleum hydrocarbon concentration in sample Bl was
1,060 ppm.  The NJDEP Cleanup Objective for total petroleum hydro-
carbons in soil is 100 ppm.  This proposal should reduce the total
petroleum hydrocarbon concentration to below 100 ppm.

The estimated capital cost for this proposal is $75,000.

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                                  28


 8.2    Ground-Water and Surface Water Alternative;  No Further Actioji
 with Periodic Long-Term Monitoring

 This alternative addresses the ground water and surface water at the
 Site.  A long-term ground-water and surface-water monitoring program
 is included in this alternative in order to confirm that chemical
 concentrations in the ground water of the upper aquifer in Area I
 reach health-based levels within a short period of time, and to
 protect against possible future threats to the ground water and
 surface water throughout the Site.

 This alternative acknowledges that the suspected source of ground-water
 contamination (i.e. paint sludge) has been eliminated and assumes
 that any residual contamination levels will decrease over time to
 acceptable levels.  The monitoring network will include all potentially
 affected drinking water wells and surface water tributaries to the
 Wanaque Reservoir.  Geophysical studies such as fracture-trace analyses
 and mapping of faults, folds, lineations and joints will be conducted
 to optimize the location and placement of long-term monitoring wells.
 Geochemical analyses of surrounding rocks and soil will be conducted
 in order to establish background concentrations of metals.  After five
 years the monitoring program will be reevaluated to ensure that the
 ground water has reached health-based levels and the surface water is
 not impacting the Site.  However, long-term monitoring for the entire
 Site should continue for a period of thirty years.

 Presently, the shallow aquifer is not being used as a potable water
'source and•restrictions on shallow wells should remain in effect in
 the forseeable future.  Within a short period of time, natural atten-
 uation should bring levels of contaminants of concern below ARARs.

 Capital, operation and maintenance and net present worth costs are
estimated as follows:

                      Capital Costs = $150,000
             Operation and Maintenance Costs =  $50,000
                   * Net Present Worth = $712,889

 * Based on 8% discount rate and 30-year period of performance.

 9.0	Comparative Analysis of Alternatives

 Each proposal and alternative was evaluated and analyzed according
 to the following nine criteria:

        Overall protection of human health and the environment

        Compliance with ARARs

     -  Long-term effectiveness and permanence

        Short-term effectiveness

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                               29


        Reduction of toxicity, mobility or volume

        Implementability

     -  Cost

        State Acceptance

        Community Acceptance

9.1    Overall Protection of Human Health and the Environment

The proposal to conduct confirmatory sampling and remove soil that
is above health-based levels in Area I is protective of human
health and the environment because it eliminates the remaining
source of ground-water and soil contamination.

The No Further Action with Periodic Long-Term Monitoring Alternative
will provide adequate protection of human health and the environment.
The source of suspected contamination (i.e., paint sludge) has been
removed and the long-term monitoring program will be designed to
protect against future threats to human health and the environment.

9.2	Compliance with ARARs

The proposal to conduct confirmatory sampling of soil above health"
based levels will eliminate the contaminated soil around the Bl area
which is above the New Jersey Cleanup Objectives (NJCO) for soils.
This proposal will bring the remaining contaminated soil in compliance
with the NJCO.  This portion of the Site will be closed consistent
with- alternate clean-closure requirements under RCRA.

The paint sludge which has already been removed from the Sitef was
found to be a RCRA characteristic waste for lead.  Due to the
small amount of contaminated soil remaining .and its lower lead
concentration, the remaining soil is not expected to be a RCRA
characteristic waste.  Because the remaining soil is not a RCRA
characteristic waste, land ban requirements do not apply.

The purpose of the long-term ground-water and surface-water monitor-
ing program is to ensure that the ground water and surface water
are at State and Federal MCLs.

9.3	Long-Term Effectiveness and Permanence

Confirmatory sampling and removal of the soil in Area I will
permanently eliminate the remaining contaminated soil from the
Site.

The monitoring program provides for a minimal period of thirty
years of surface-water and ground-water monitoring and, therefore,
is effective in providing long-term protection of human health and
the environment.

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                              30

9.4	Short-Term Effectiveness

The proposal to conduct confirmatory sampling and then to remove
the soil in Area I provides for short-term effectiveness.

The No Further Action with Periodic Long-Term Monitoring Alternative
relies on natural attenuation processes to bring the remaining contam-
ination down to acceptable health-based levels.  Natural attenuation
of ground water and surface water should take a relatively short
period of time.  The monitoring program will be reevaluated in five
years to ensure that the ground water and surface water is at acceptable
health-based levels.

9.5	Reduction of Toxicity, Mobility or Volume

Only alternatives which involve treatment are analyzed under this
criterion.  Neither the Soil Removal Proposal nor the No Further
Action Alternative involve treatment and, therefore/ they are not
analyzed under this criterion.

9.6    Implementability
            "- -1-- -~'     "" "• —     *

Implementability addresses how easy or difficult it would be to
implement a given alternative from the design stage through con-
struction and long-term operation and maintenance.

The No Further Action Alternative, does not present any implementation
problems, except that before any additonal monitoring wells are
installed a detailed geochemical and geophysical survey must be
performed to optimize placement of these wells.

The Confirmatory Sampling, Removal of Soil, Grading, Backfilling and
Revegetation in Area I Proposal, would be easy to implement.  It
may require some time to mobilize heavy equipment before the removal
can be implemented.  Revegetation may require some maintenance of
the vegetative  cover to stabilize the soil and prevent erosion.

9.7    Cost

The cost criteria for each proposal and alternative include the
estimated capital costs and operation and maintenance costs (0 & M)
and the net present worth costs.

The capital, 0 & M and net present worth costs are presented in the
Description of Alternatives section of this document.  The proposal
to conduct confirmatory sampling and remove soil in Area I is a one-
time action which does not involve operation and maintenance nor
net present worth costs.

9.88    State Acceptance

This evaluation criterion addresses the concern and degree of support
that the State government has expressed regarding the remedial alter-
natives being addressed.  NJDEP has reviewed the RI, FS, Risk Assess-

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                               31
ment and this document.  NJDEP has given its concurrence on the
selected remedial action.

j?.j _ Community Acceptance
EPA held a public meeting on August 17, 1988 at which time the
results of the RI and FS were presented along with EPA's preferred
remedy.  Questions and comments raised during this meeting are
summarized in the Responsiveness Summary section of this document.

Prior to the public meeting EPA met with Ringwood Borough officials on
August 12, 1988 to discuss the proposed remedy.  Ringwood officials
stated their desire for the monitoring of potable wells near the Site
and gave their support of the proposed long-term monitoring program.

10.0   The Selected Remedy

EPA's selected remedy has three components:

  1. Achieving health-based levels in the upper aquifer of Area I
     through natural attenuation processes.

  2. Implementation of a long term surface water and ground-water
     monitoring program to confirm that ground-water contamination
     in Area I meets health-based levels and to protect against future
     threats to the ground water and surface water throughout the Site.

  3. Confirmatory soil sampling and possible removal of contaminated
     soils to levels meeting NJCO.  This action will be conducted
     pursuant to the CERCLA 106(a) unilateral removal order
     Index No. II-CERCLA-70102.

11.0   The Statutory Determinations

Section 121 of CERCLA requires that EPA select a remedy which is
protective of human health and the environment, attains ARARs , is
cost effective and utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable.

Based upon the analysis presented in the Comparative Analysis of
Alternatives and Selected Remedy sections, the following conclusions
are reached regarding the Soil Removal Proposal and the No Further
Action with Periodic Long-Term Monitoring Alternative.

11.1   Protection of Human Health and the Environment

Long-term ground-water and surface water monitoring are protective
of human health and the environment because the source of contamination
(i.e., paint sludge) in the ground water has been removed except for
a small' portion of Area I.  Removal of soil above health-based
levels around sample Bl will eliminate the remaining contaminated
soil in Area I.

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                                -32-

There  is no  immediate threat  to the downgradient Wanaque Reservoir.
Surface water sampling to date has shown  that no contamination  is
entering the reservoir from the Site.  The long-term monitoring
program will be designed to monitor on-site and off-site ground-water
and surface-water quality to  ensure future protection of public
health and the environment.

11.2   Attainment of ARARs

Promulgated  regulations which apply to the Ringwood Mines/Landfill
Site include the New Jersey Ground Water  Quality Standard, the  New
Jersey Criterion for Ground Water Protection and Response/ and  the
USEPA Maximum Contaminant Level for Drinking Water.  The principal
ARAR is to achieve 50 ppb arsenic and lead in the upper aquifer.
Non-pronulgated criteria include the New  Jersey Cleanup Objectives
for Soil.

As explained in the Comparative Analysis  of Alternatives section,
samples exceeding ARARs are localized and minimal.  Removal of  the
soil in Area I which is confirmed to be above health-based levels will
bring contamination levels below the New  Jersey Cleanup Objectives
for Soil.  It is expected that contaminants in the ground water
will reach health-based levels within a short period of time.
Ground-water monitoring will  be utilized  to confirm this hypothesis.

11.3   Cost-Effectiveness

The estimated costs associated with each  alternative are presented
in the Description of Alternatives section.  Combining the Proposal
for Confirmatory Sampling and Removal of  Soil in Area I and the No
Further Action with Periodic  Long-Term Monitoring Alternative
provides the maximum protection for human health and the environ-
ment and is cost effective.

11.4   Utilization of Permanent Solutions and Alternative Treatment
Techonolgies to the Maximum Extent Practicable

Confirmatory sampling and removal of the  contaminated soil around
sample Bl provides a permanent remedy for the soil medium in Area I.

11.41  RATIONALE FOR REMEDY SELECTION

Confirmatory sampling and removal of the  remaining contaminated
soil in Area I combined with  long-term ground-water and surface
water monitoring is the preferred remedy  for the Site.  The rationale
for the selection of this remedy is as follows:

0  The selected remedy is a straight-forward action and an obvious
solution.  It is consistent with other actions already taken at
the Site (i.e., paint sludge  removal).

0  The paint sludge removal already completed at the Site has

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                               33

eliminated the suspected source of ground-water contamination in
the upper aquifer, except for a small portion of Area I which the
Soil Removal Proposal addresses.

0  The residual concentration of contaminants in the ground water
was found to be low level and localized.  No ground-water contaminant
plume has been identified at the Site.

0  Presently, ground water in the vicinity of the former paint sludge
disposal areas is not used as a drinking water supply source.
Residences in the area are on a public water supply system.

0  There is no threat to the downgradient Wanaque Reservoir.  Surface
water sampling to date has shown that no contamination is entering
the reservoir from the Site.

0  Analyses of soil samples from test pits at the former paint sludge
locations and at the former O'Connor Landfill did not show significant
contamination except for a small portion of Area I.  This remaining
contaminated soil will be excavated, if necessary, and properly
disposed of off-site.

0  Although ground-water treatment technologies are proven and
reliable, they may not be feasible to implement because of the low
level and scattered nature of ground-water contamination at the
Site. -Specifically, extraction wells would draw clean water from
outlying areas into the areas of contamination, thus diluting the
already low levels of contamination in the ground water.  This
further dilution would make ground-water treatment impractical.

For the reasons stated above the Confirmatory Sampling and Soil
Removal Proposal combined with the No Further Action with Periodic
Long-Term Monitoring Alternative is the most appropriate remedy for
the Ringwood Mines/Landfill Site.  This remedy addresses the soil,  .
surface-water and ground-water media, at the Site and is protective
of human health and the environment.

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                      RESPONSIVENESS SUMMARY

                 FOR THE PROPOSED REMEDIAL ACTION
               AT THE RINGWOOD MINES/LANDFILL SITE
                       RINGWOOD, NEW JERSEY
                   TABLE OF CONTENTS

                                                        Page

I.    Introduction  -                                     1

II.   Site Contamination Concerns                        1

      A.  Iron Mines                                     1

      B.  Ground-Water Monitoring                        2

      C.  Drinking Water                                 3

      D.  Sampling      '                                 3

III.  Additional Areas of Concern                        4

      A.  Municipal Landfill                             4

      B.  Other Concerns                                 5

IV.   Written Comments                                   5

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                      RESPONSIVENESS SUMMARY

                FOR THE PROPOSED REMEDIAL ACTION
              AT THE RINGWOOD MINES/LANDFILL SITE
                       RINGWOOD, NEW JERSEY


I.   Introduction

The United States Environmental Protection Agency (EPA) held a
public comment period from August 9, 1988 to September 6, 1988, to
provide an opportunity for interested parties to comment on EPA's
proposed remedial action of the Ringwood Mines/Landfill Superfund
site in Ringwood, New Jersey.  EPA held a public meeting to present
the proposed remedial action plan on August 17, 1988.  Approximately
15 community residents attended the meeting.  Copies of the proposed
remedial action plan were distributed at the meeting and placed in
the information repositories for the site.

The purpose of this Responsiveness Summary is to document EPA
responses to comments and questions raised during the public comment
period.  Sections II and III below present a summary of the questions
and comments expressed by the public at the August 17 meeting.
Section IV presents a summary of written comments received following
the meeting.  The questions and comments are grouped into general
categories o"f subjects.  All questions or comments are followed by
EPA's responses.

II.  Site Contamination Concerns

     A.  Mines

         1.   A group of citizens asked for information about what is
              allegedly in the former Ringwood iron mines.

              EPA response;  Although there have been allegations of
              hazardous waste dumping in those mine shafts, they have
              not been supported by any documentation.  Allegedly,
              the Ford Motor Company dumped solid and industrial waste
              form car manufacturing and assembly.

              EPA's investigation at the site was targeted toward
              determining the quality of ground water in the mines.
              To that end, contractors sampled ground water which is
              hydrologically connected to the mine shafts.  This
              sampling was accomplished by drilling monitoring wells
              into fractures that run through the mines.  No con-
              tamination was detected.

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B.  Ground-Water Monitoring

    1.   One attendee spoke of the ground-water monitoring
         wells that were installed at Furnace Dam Pond and asked
         whether these wells were tested only for lead.  In
         addition, he wondered whether monitoring is being
         conducted to test the iron content in wells near the
         Furnace Dam Pond, as people use water from these wells
         because they believe that they are "natural".

         EPA Response;  In one round of monitoring, water from
         the Furnace Dam Pond area was tested for a comprehensive
         range of hazardous substances.  Other rounds tested for
         hazardous substances which included some heavy metals
         found in very low concentrations.  Lead was not found.
         The level of contamination is not likely to have changed
         in the past four years, as there is no contaminant plume
         moving from the site.  This area will be considered in
         the long-term monitoring program designed for the Site.

    2.   One resident noted that road workers are blasting to
         create Interstate 287 and wanted to know whether the
         blasting would cause fractures in the bedrock which
         could effect the Wanaque Reservoir.

         EPA Response;  Blasting can create fractures, but not
         deep enough to affect deep bedrock ground-water wells.
         Blasting to create 287 should not affect ground water
         near the Wanaque Reservoir, as these two locations are
         divided by a ridge system which serves as an effective
         ground-water barrier.

3.       One attendee questioned the Borough of Ringwood's
         reasons for installing gas vents in his yard, which
         borders the Municipal Landfill, and wondered whether
         gases would be pumped out through monitoring wells.

         EPA Response;  The vents have been installed to prevent
         the buildup of methane gas, which arises from decomposi-;
         tion and could lead to explosions within the landfill.
         Monitoring wells would not draw gases as they are
         screened in the ground water.

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C.  Drinking Water

    1.   One citizen expressed his concern about the possibility
         of contamination of drinking-water wells in Erskine
         Lakes and asked for EPA's assurance that the water is
         suitable for drinking.

         EPA Response;  The Borough samples the drinking water
         in Erskine Lakes regularly and there is no reason to
         believe that the water has been affected by contamina-
         tion at the Ringwood Mines/Landfill site.

 2.      One attendee asked whether EPA had studied the locations
         and depths of public and private wells and whether
         ground-water wells were monitored at the proper depth.

         EPA Response;  In 1983, EPA in consultation with the
         Borough of Ringwood, conducted a potable well inventory.
         Wells adjacent to the Site were analyzed and were found
         to be free of contamination.  Monitoring wells were
         screened at a variety of depths commensurate with
         potable wells in the area.

 3.      An attendee wanted to know the depths of potable wells.

         EPA Response;  Potable well depths in the area range
         from 70 feet to 600 feet, averaging approximately
         200 feet.

 4.      A-citizen asked the depth of the well from which the
         Borough draws its water.

         EPA Response;  Approximately 300 feet.

D.  Sampling

    1.   One attendee wanted to know who actually performed the
         sampling conducted as part of the remedial investigations
         at the Site.

         EPA Response;  Woodward-Clyde Consultants (WCC) performed
         sampling activities at the Site as a contractor working
         for the Ford Motor Company, with oversight by EPA.

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         2.   One attendee questioned whether WCC works for EPA;
              whether it has a laboratory in-house; and whether
              EPA approved the laboratory that was used by WCC.

              EPA Response;   WCC does not work for EPA; it was
              retained by the Ford Motor Company to perform technical
              investigations at the site.  WCC sends its samples to an
              outside laboratory which was approved by EPA.

      3.      One attendee asked whether, because EPA is relying on
              WCC and its laboratory, there are people taking civil
              and legal responsibility for the results, and who is
              liable in the event results have been falsified.
              He also asked what percentage of samples are "split","
              so that EPA tests the same samples as the contractor
              laboratory to check for inconsistent results. •

              EPA Response;   Falsification of data is a serious
              offense; however, EPA feels comfortable with the quality
              of the remedial investigation data due to the Agency's
              quality assurance/quality control approval process,
              sample splitting, and the fact that WCC used three
              different laboratories.  Although the percentage of
              samples that are split between EPA's laboratory and
              the laboratory used by WCC varies, it is usually 25 to
              30 percent.

III.   Additional Areas of Concern

      A.  Municipal  Landfill

          1.  One attendee asked what EPA is planning to do about
              the waste at the Municipal Landfill, which he believes
              to be  toxic, and wondered whether monitoring wells
              could  be installed in the landfill itself.  He feels .
              that EPA is not familiar enough with the region to
              identify all problem areas.

              EPA Response;   EPA has ensured that monitoring wells
              have been installed immediately downgradient of the
              Municipal Landfill to obtain ground-water data
              representative of what was disposed of in the landfill.
              Therefore, it is not necessary to install wells
              directly into the landfill to obtain water quality data.

              Up to  this point, it has been EPA's understanding that
              there  is no hazardous waste in the Municipal Landfill.
              There  are two monitoring wells in the landfill area
              which  revealed no contamination related to hazardous
              waste  disposal activities.  During the course of the

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                  long-term monitoring program, EPA will install more
                  wells, if needed.  EPA would be willing to accompany
                  residents on a field visit to locate any unaddressed
                  areas of concern.

         B.  Other Concerns

             1.   One citizen stated that his announcement of the public
                  meeting had been delivered in the mail only that
                  afternoon.

                  EPA Response;   In addition to mailing the announcement
                  of the meeting to interested persons,  EPA placed
                  advertisements in local newspapers announcing the
                  meeting.

IV.       Written Comments

         A.  The Proposed Remedy

            1.     Mr. Robert Westerdale of Hewitt,  New Jersey expressed
                  his belief that "no further action" is not a suitable
                  alternative for remediation of the site.  He stated
                  his concern that alleged uncontrolled dumping in the
                  mine area has  caused high levels  of ground-water
                  contamination  and that ground-water movement may be
                  deceptive.  Therefore, it may cause EPA to believe that
                  the Site is safe but in reality,  there may actually
                  be a highly-contaminated plume that will infiltrate
                  a drinking-water source someday.

                  EPA Response;   High levels of ground-water contamination
                  have not been  found at the Site,  and there is no
                  evidence of a  contaminant plume.   The long-term monitor-
                  ing program will be designed in such a way that any
                  contaminant plume that may develop in the future will be
                  detected.  Potable drinking-water wells will be
                  monitored to protect drinking-water sources.

            2.     Ms. Joan Helinski of the Northern New Jersey Water
                  Supply Commission expressed her support of the remedy
                  selected by EPA for the Site.

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