United States Office of
Environmental Protection, Emergency and
Agency , Remedial Response
EPA/ROD/R02-91/167
September 1991
Superfund
Record of Decision
Fort Dix Landfill, NJ
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50272-101
REPORT DOCUMENTATION 1. REPORT NO. z.
PAGE EPA/ROD/R02-91/167
4. Tltte and Subtitle
SUPERFUND RECORD OF DECISION
Fort Dix Landfill, NJ
First Remedial Action - Final
7. Author)*)
9. Ptrforming Organization None and Addre**
12. Sponsoring Organization Nun* and Addreu
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1* Acc***ton No.
5. Report Date
09/24/91
6.
8. Performing Organization Rept No.
10. Pro|ect/TMk/Work Unit No.
1 1. Contr»ct(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Umlt: 200 word*)
The 126-acre Fort Dix Landfill site is an inactive landfill located in the southwest
section of the U.S. Army Fort Dix Military Reservation, Pemberton Township,
Burlington County, New Jersey. The site is surrounded by military housing
developments, a hardwood swamp, and a densely vegetated hardwood forest. The site is
bordered by Cannon Run Stream, located on the east side of the landfill, and an
unnamed stream located northwest of the landfill. From 1950 until its closure in
1984, the site was used and operated by the Fort Dix Military Reservation to dispose
of various wastes including household waste from the military base, paints, thinners,
demolition debris, ash, and solvents. From 1968 to 1984, McGuire Air Force Base also
used the landfill for waste disposal. Landfilling operations consisted of excavating
a series of parallel trenches and filling with waste materials. .Waste disposal began
at the northern portion of the landfill in 1950 and proceeded in a southerly
direction to the southern boundary of the landfill. In addition to the landfill,
during 1982, the Army used a pit in the southwestern area of the site to dispose of
mess hall grease and degreasing agents. A 1982 State investigation revealed ground
water contamination beneath the site that had resulted from landfill leachate. This
(See Attached Page)
NJ
17. Document Amlycl* a. Descriptor*
Record of Decision - Fort Dix Landfill,
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: VOCs (benzene, toluene), other organics (PAHs), metals
.. .^ »« ~— * ^.-r (chromium, lead)
b. Identifiera/Open-Ended Term*
e. COSATI Reid/Group
1& Availability Statement
19. Security Cl*** (Thi* Report)
None
20. Security Claa* (Thi* Page)
None
21. No. of Page*
104
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R02-91/167
Fort Dix Landfill, NJ
First Remedial Action - Final
stract (Continued)
Record of Decision (ROD) addresses final source control at the site; however, if
additional investigations reveal significant increases in unacceptable risk to human
health and the environment, then additional remedial actions will be proposed. The
primary contaminants of concern affecting the soil and debris are VOCs including
benzene and toluene; other organics including PAHs; and metals including chromium and
lead.
The selected remedial action for this site includes capping the 50-acre southern
portion of the landfill with a clay or geomembrane cap; developing a soil erosion and
sediment control plan; long-term ground water, surface water, and air monitoring; and
implementing institutional controls including deed, land, and ground water use
restrictions, and site access restrictions such as fencing. The estimated capital cost
for this remedial action is $12,600,000, with an annual O&M cost of $218,900 for the
first 2 years and $199,900 for years 3-30.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
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ROD FACT SHEET
SITE
Name
Location/State
EPA Region
HRS Score (date)
NPL Rank (date)
Fort Dix Landfill
Pemberton Township, New Jersey
II
37.40
67 for Federal Facilities (8-30-90)
ROD
Date Signed
Remedy
Capital Cost
0 & M/year
9-24-91
Landfill Cap & 30 years of groundwater
monitoring
$12,600,000
$ 199,900
Enforcement, EPA
Primary contact
Secondary contact
Main PRP(s)
PRP Contact
Paul G. Ingrisano
Robert J. Wing
U.S. Army
Lt. Colonel Donnie L. Henley (609) 562-3255
(212) 264-6609
(212) 264-8670
Type and media:
Origin
Est. quantity
The groundwater and surface water are
contaminated with various volatile organic
compounds as well as, heavy metals including
manganese, lead, and cadmium.
On-site waste disposal.
126 acres
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Donnie L. Henley
Lieutenant Colonel, Engineer
Director of Engineering and Housing
Department of the Army
Headquarters, U.S. Army Training
Center and Fort Dix
Fort Dix, New Jersey 08640-5501
Dear Lieutenant Colonel Henley:
Enclosed is the final copy of the Record of Decision (ROD) for
the Fort Dix Landfill which was signed by the Deputy Regional
Administrator on September 24, 1991.
Please note that, as required by the Interagency Agreement (IAG),
within twenty-one (21) days of issuance of the ROD for the Fort
Dix Landfill, the Army shall propose deadlines for the submission
of the Remedial Design and Remedial Action Workplans in
accordance with Part XIII (Deadlines) of the IAG.
We ask that the Army place copies of this letter declaring that
the ROD has been signed, together with the ROD itself, on file at
the information repositories which the Army is maintaining for
this site.
If you have any questions concerning this matter, please contact
me at (212) 264-6609.
Sincerely yours,
Paul G. Ingrisano
Project Manager
Federal Facilities Section
Enclosure
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-2-
cc: Secretary L.D. Walker, U.S. Army
General JiP. Herriing, Fort Dix
L. Barb, U.S. Army
D. Felder, Fort Dix
E. Kauffman, USATHAMA
A. D. Gupta, Baltimore District, COE
N. Hubler, Philadelphia District, COE
C. Shah, Law Environmental, Inc.
K. Walters, Advanced Sciences, Inc.
L. Miller, NJDEPE
H. Shah, NJDEPE
bcc: V. Pitruzzello, PSB, w/o encl
R. Wing, PSB, w/o encl
R. Hargrove, EIB, w/encl
D. Mellot, ORC, w/encl
P. Ingrisano, PSB, w/o encl
M. Margetts-Jaeger, OEP, w/encl
P. Moss, PSB, w/encl^
L. Richman, NJSB2, w/encl
L. Elson, EPA-HQ, w/encl
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RECORD OF DECISION
PORT DIX LANDFILL
FORT DIX MILITARY RESERVATION
PEMBERTON TOWNSHIP
BURLINGTON COUNTY, NEV JERSEY
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TABLE OF CONTENTS
Section Page
1.0 DECLARATION STATEMENT 1-1
1.1 Site Name and Location 1-1
1.2 Statement of Basis and Purpose 1-1
1.3 Assessment of the Site 1-1
1.4 Description of the Selected Remedy 1-1
1.5 Declaration 1-4
2.0 DECISION SUMMARY 2-1
2.1 Site Name, Location and Description 2-1
2.2 Site History and Enforcement Activities 2-3
2.3 Highlights of Community Participation 2-5
2.4 Scope and Role of Response Action ;. 2-6
2.5 Site Characteristics 2-7
2.6 Summary of Site Risks 2-10
Human Health Risks , 2-11
Environmental Risks 2-15
2.7 Description of Alternatives 2-16
Alternative 1 - No Remedial Action 2-17
Alternative 2 - Cap and Monitor ..• 2-18
Alternative 3A - Ground Vater Pumping and On-site
Treatment 2-19
Alternative 3B - Ground Vater Pumping and Off-site
Treatment 2-20
Alternative 3D - Partial Ground Vater Pumping and
On-site Treatment 2-21
Alternative 4A - Ground Vater Interception and
On-site Treatment 2-21
Alternative 4B - Ground Vater Interception and
Off-site Treatment 2-22
2.8 Summary of Comparative Analysis of Alternatives 2-22
Overall Protection of Human Health and the
Environment 2-24
Compliance vith ARARs w... 2-25
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TABLE OF CONTENTS
(continued)
Long-Term Effectiveness and Permanence 2-26
Reduction of Toxicity, Mobility, or Volume through
Treatment 2-28
Short-Ten Effectiveness 2-29
Implement ability 2-30
Costs 2-31
State Acceptance 2-32
Community Acceptance 2-32
2.9 Selected Remedy 2-32
2.10 Statutory Determinations 2-34
Protection of Human Health and the Environment 2-35
Air 2-35
Soils 2-35
Ground Vater 2-36
Surface Vater , 2-36
Biological Community 2-37
Compliance.vith ARARs 2-37
Cost Effectiveness 2-38
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Tech-
nologies to the Maximum Extent Practicable . 2-39
Preference for Treatment as a Principal Element .. 2-39
Attachment 1. Figures
Attachment 2 Tables
Attachment 3 'Responsiveness Summary
Attachment 4 HJDEP letter of Concurrence vith the Record of Decision
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LIST OF FIGURES
Figure
1 General Location Map
2 Site Location Map
3 Land Use Map
4 Landfill Development Progression
5 Monitoring Veil and Piezometer Locations
6 Surface Vater, Sediment, and Leachate Sample Locations
7 Air Sample Locations
8 Alternative 1, No Remedial Action
9 Alternative 2, Landfill Closure
«
10 Typical Closure Cap Detail
11 Alternative 3A, Plume Pumping, Treatment and Reinjection
12 Treatment Process Schematic, Module I
13 Treatment Process Schematic, Module II
14 Treatment Process Schematic, Module III
IS Alternative 3B, Plume Pumping, Treatment and Off-site
Discharge
16 Alternative 3D, Localized Plume Pumping vith On-site Treatment,
Injection, and Landfill Closure
17 Alternative 4A, Interceptor Drains, Treatment and
Reinjection
18 Alternative 4B, Interception Drains, Treatment and
Discharge
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LIST OF TABLES
Table
1 Summary of Contaminants Detected in Ground Vater, Surface
Vater in Cannon Run, and Swamp Vater Table Samples
2 Summary of Contaminants Detected in Grease Pit, Subsurface
Soil, and Sediment Samples
3 Concentrations of Contaminants in Air Samples
4 Health Effects Criteria for Chemicals of Concern at the Port
Dix Site - Potential Carcinogens
5 He..th Effects Criteria for Chemicals of Concern at the Port
Dix Site - Noncarcinogens
6 Fort Dix Landfill Superfund Site Cost Summary and Implementation
Time
7 Summation of Total Estimated Risks for the Present Site Use
Exposure Pathways
8 Summation of Total Estimated Cancer Risks for the Future Site Use
Exposure Pathways
9 Characteristics of the Remedial Action Alternatives
10 Port Dix Sanitary Landfill: Selected ARARs
11 Estimated Capital Costs of Alternatives
*
12 Estimated Annual O&M Costs of Alternatives
(fortjlix 99)
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SECTION 1
DECLARATION STATEMENT
1.1 SITE NAME AND LOCATION
Fort Dix Landfill
Fort Dix Military Reservation
Pemberton Township
Burlington County, Nev Jersey
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Fort
Dix Landfill in Pemberton Township, Burlington County, Nev Jersey,
developed in accordance vith the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986 (CERCLA), 42 U.S.C. Section
9601, e_t seq., and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300.
This decision is based op the administrative record for this site.
The State of Nev Jersey concurs vith the selected remedy.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this Record
of Decision (ROD), may present an imminent and substantial endangerment to
public health, velfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY
The selected remedial alternative for the Fort Dix Landfill site is
essentially a source control action that vill reduce the amount of
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contamination being introduced into the ground water. It consists of
covering the southernmost SO acres of the landfill vith a low-permeability
cap, while undertaking actions consistent with State solid waste landfill
closure requirements and Resource Conservation and Recovery Act (RCRA)
guidance. Monitoring will also be conducted during the design phase and
will include the following:
1. Collect and analyze sediment samples at the point where
Cannon Run discharges into the North Branch of Rancocaa
Creek;
2. Perform standard bioassay testing for freshwater species on
samples collected from a piezometer, a proposed monitoring
well, and surface water along Cannon Run?
3. Conduct air sampling for volatile organic analysis; and,
4. Sample newly installed and selected existing monitoring wells
for chemical analysis.
A long-term monitoring program (30 years) will also be implemented as part
»
of this action to detect changes in ground water, surface water, and air
quality. These data will be reviewed, as they are collected so that, if
significant degradation in the quality of these media is noted that
produces an unacceptable risk, then further action can be initiated.
Unacceptable risk will b.e determined through a revision of the latest risk
assessment, using the most recent total volume of data. Risk assessments
will use EPA guidance and policy effective at the time of the review. The
information obtained during the monitoring program in items 1-4 above will
be used in the three year post-closure review. The effectiveness of the
selected remedy will be reevaluated no less often than three years after
commencement of remedial action and at least every five years thereafter as
required under CERCLA.
Land Disposal Restrictions (LDRs) are not applicable to this action because
the landfill will be capped and placement will not occur.
The major components of the selected remedial alternative are:
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1. Installation of a cap on the southern 50 acres of the
landfill that vill consist of vegetative, drainage, and
lov-permeability layers. Tvo feet of final cover vill be
maintained on the regaining portion of the landfill vhich
vill not receive the cap. The final cover requirements vill
be developed in consultation vith the Nev Jersey Department
of Environmental Protection (NJDEP) and the U.S.
Environmental Protection Agency (EPA).
2. Installation of a landfill gas venting and air monitoring
system (to determine if methane gas and volatile organic
compounds (VOCs) emissions require-treatment).
3. Installation of a chain-link fence around the perimeter of
the landfill to restrict access to the site.
4. Implementation of landfill closure requirements in accordance
vith Nev Jersey Administrative Code (NJAC) 7s26-2A et seq.
and RCRA guidance.
5. Long-term ground water, surface vater, and air monitoring (30
years) pursuant to the Nev Jersey State .closure requirements.
A yearly statistical analysis vill be performed on the
chemical analysis results to determine the trend of the
overall contamination levels.
6. Long-term operation and maintenance (O&M) to provide
inspection of and repairs to the landfill cap.
7. Institutional controls in the form of deed and vater use
restrictions on future uses of the landfill and ground vater
in the immediate vicinity of the landfill.
•»
8. Development and implementation of a soil erosion and sediment
control plan consistent vith the Soil Erosion and Sediment
Control Act Regulations of 1975, NJSA 4:24-40 et seq., and
NJAC 2:90-1.1 et seq.
9. Using the data obtained in the monitoring program, the risk
assessment vill be revieved and subsequently revised if the
trend shovs significant changes in vater quality. These
revievs and revisions vill occur no less often than three
years after commencement of remedial action and every five
years thereafter. Any changes in actual exposure scenarios
vill be addressed in the revised risk assessments. Risk
assessments vill use EPA guidance and policy effective at the
time of the reviev.
10. If significant increases in unacceptable risk to human health
and the environment are determined in the revised risk
assessments, additional remedial actions vill be proposed.
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1.5 DECLARATION
The selected remedy is protective of human health and the environment,
complies vith Federal and State requirements that are legally applicable or
relevant and appropriate (ARARs) 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.
Because treatment of the potential threats at the site vas not found to be
practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy.
Because this remedy vill result in hazardous substances remaining on-site
above health-based levels, a reviev vill be conducted vithin three years,
then every five years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human health and the
environment.
Date
Lewis D. Valker
Deputy Assistant Secretary
of the Army
Environment, Safety &
Occupational Health
Date
(fortjlix/98)
Regional Admi
Region II
U.S. Environmental Protection
Agency
1-4
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SECTION 2
DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
The Fort Dix Landfill is located in the southwest section of the U.S.
Amy's (Army) Fort Dix Military Reservation in Pemberton Tovnship,
Burlington County, Nev Jersey (see figure 1). The Fort Dix Landfill covers
approximately 126 acres and is located about 2,200 feet from the post
boundary (see figure 2). The site is surrounded by Pointville Road to the
north, Juliustovn-Brovns Mills Road to the east, Pemberton-Brovns Mills
Road to the south, and Pipeline Road to the vest. Tvo streams flov near
the landfill. Cannon Run, located on the east side of the landfill, flovs
south into the North Branch of Rancocas Creek. An unnaied stream, located
northvest of the landfill, flovs to the vest into the North Branch of
Rancocas Creek. A svaop that drains into Budds Run (and eventually into
the North Branch of Rancocas Creek) is located to the vest of Pipeline
Road. The terrain, is gradually sloping tovards the south, from a
topographic elevation of approximately 160 feet above Mean Sea Level (MSL)
at the northern portion''of the landfill to approximately 75 feet above MSL
tovards the svampy area to the south of the landfill.
The area immediately surrounding the landfill consists of a hardvood svamp
and densely vegetated hardvood forest. Unauthorized recreational
activities such as dirtbiking and hunting take place throughout the year,
although access to the landfill is restricted by road gates, boulders (at
dirt road entrances), and military police patrols. Three military housing
subdivisions are located beyond this forested area to the north of the
landfill (Kennedy Courts, Laurel Bousing, and Garden Terrace). The Fort
Dix Elementary School is also located to the north of the landfill (see
figure 3). The tovn of Brovns Mills is immediately to the east of the
military reservation. To the south of the Fort Dix Landfill are tvo
abandoned farms, approximately 12 homes, several county buildings, the
county hospital, and the Burlington County Juvenile Detention Center and
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Shelter. Pemberton Tovnship municipal buildings, sewage disposal plant,
public vater supply veils, and several homes are located to the southwest
of the landfill. The public water supply wells identified are located
within three miles to the southwest of the landfill boundary.
The Fort Dix site is located within the Protection Area of the New Jersey
Pinelands.
•
The site area lies within the Atlantic Coastal Plain physiographic
province, nich is characterized by a southeasterly dipping wedge of
unconsolidated sediments consisting of clays, silts, sands, and gravels
that thicken in a seaward direction. The Cretaceous and Tertiary age
sediments that overlie the bedrock strike northeast-southwest and dip
gently to the southeast between 10 and 60 feet per mile.
*
An understanding of the subsurface geology of the site is necessary to
evaluate any potential ground water contamination, its directions and speed
of travel, and its impact on the environment.
The thickness of the unconsolidated sediments at the site is approximately
1,200 feet; however, only the upper few hundred feet are important to this
study. The underlying sediments are effectively sealed off by relatively
impermeable formations of fine-grained silts and clay.
The subsurface geological formations under the site include the following:
o The Cohansey Sand, the uppermost formation, which outcrops
at the site, was observed to range from 15 to 90 feet in
thickness within the site
o The Kirkwood Formation, which outcrops south and southwest of
the landfill and east of the landfill along Cannon Run, was
observed to be 25 to 50 feet thick at the site
o The Manasquan Formation, which outcrops near the town of
Browns Hills, was observed to be 10 to 20 feet thick
o The Vincentown Formation, which is poorly developed at the
site, was observed to be 17 to 23 feet thick
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o The Homers tovn and Naves ink For nations, ranging from 12 to 30
feet thick and 12 to 22 feet thick, respectively
The Cohansey and Rirkvood Formations fori a single unconfined aquifer at
the site. Ground vater flow in this aquifer is to the south and southwest
toward Cannon Run and the marsh, where it discharges at the surface.
The underlying Manasquan, Homers tovn, and Navesink Formations form a
confining layer that limits ground water flow downward from the landfill
site.
The Cohansey and Kirkwood Formations were estimated to have horizontal
hydraulic conductivities (a measure of the ease with which ground water can
flow through the formation) of 25 feet per day and five feet per day,
respectively. These aquifers discharge into Cannqn Run and the marsh.
The vertical conductivity of the confining layer — consisting of the
Manasquan, Homers tovn, and Navesink Formations — was estimated to be
approximately 0.0001 feet per day, indicating that this layer forms a
barrier to the downward flow of ground water from the landfill site.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^"^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^"
The Port Dix Landfill has been in operation since 1950; it was officially
closed on July 6, 1984. Prior to landfill development, the area was used
for Army training. Between 1950 and 1984, the landfill was used and
operated by the Fort Dix Military Reservation. McGuire Air Force Base also
used the landfill from 1968 until it vas closed. Access to the landfill
was not controlled until 1980; therefore, records of disposal practices,
waste types, and quantities are incomplete. However, wastes that have been
reportedly disposed of at the landfill include domestic waste (household
waste from the military base), paints and thinners, demolition debris, ash,
and solvents. The final filled area is approximately 126 acres.
Landfill operations consisted of excavating a series of parallel trenches
to a depth of approximately 10 feet below grade. The trenches were then
2-3
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filled vith vaste materials and covered with about tvo feet of native soils
that vere originally removed during excavation. In general, trench exca-
vation and vaste disposal began at the northern portion of the landfill (in
the 1950's) and preceded in a southerly direction to the landfill's
southern boundary as of July 6, 1984 (see figure 4). After 1969, landfill
capacity vas increased by depositing wastes to an elevation of approxi-
mately 10 feet above grade, therefore doubling the depth of vastes disposed
of in each trench.
•
In addition to the landfill, a pit in the southwest area of the site (see
figure 2'f -as reported by the Army to be used for an estimated period of
four months in 1982 to dispose of mess hall grease and grease trap
cleansers. The pit covered approximately one-half acre to a depth of six
feet. Disposal into the grease pit vas discontinued in October 1982. The
t
type of grease trap cleansers has not been confirmed, although Army
contacts have stated that degreasers vere not used. Prior to disposal at
the grease pit, mess hall grease vas disposed of throughout the landfill.
Older portions of the landfill vere revegetated vith ash and pine trees,
vhile the never portions of the landfill vere left to naturally revegetate.
These portions of the landfill are either covered by high grass, lov
vegetation, or are bare'.' Never sections of the landfill vhere refuse vas
disposed of at elevations above the original grade suffer from extensive
soil erosion and vashouts, vhere vaste materials (e.g., tires) are exposed.
Along the eastern portion of the landfill (trenched from approximately 1960
to 1970), large metal and concrete objects vere exposed along the perimeter
of the landfill and appear to have been filled into the vet lands of Cannon
Run. These materials are nov partially covered vith natural organic
detritus. Tvo feet of final cover vill be maintained on the remaining
portion of the landfill vhich vill not receive the cap.
In 1979 and 1982, a series of ground vater monitoring veils (LF series
veils on figure 5) vere installed around the perimeter of the landfill.
Reports indicated that VOCs vere detected in many of the ground vater
samples taken in 1982. The major VOCs that exceeded the NJDEP ground vater
limits vere methylene chloride and trichloroethylene. In*December 1983,
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eight additional ground water monitoring veils (MV veil series in figure 5)
vere installed to further define ground vater contamination. Eleven veils
vere installed in May 1984 as part of a ground vater investigation
performed by the U.S. Army Engineers Vatervays Experiment Station (WES
series veils in figure 5). VOCs and heavy metals vere detected in the
ground vater samples collected from veils located immediately to the south,
southeast, and southvest of the landfill. These compounds included
methylene chloride, di- and trichloroethane,- tri- and tetrachloroethylene,
methyl ethyl ketone, methyl isobutyl ketone, mercury, cadmium, and other
heavy metals.
An interim Nev Jersey Pollutant Discharge Elimination System (NJPDES)
permit vas issued for the Fort Dix Landfill on May 29, 1984. Since that
time, quarterly sampling of "LF" monitoring veils continues to be performed
«
by various laboratories to satisfy the landfill NJPDES permit. On July 6,
1984, the Army ceased the disposal of vaste at the landfill in compliance
vith the landfill closure date. The landfill vas ranked for inclusion on
the National Priority List (NPL) on September 14, 1984. On .October 15,
1984, 32 Federal facilities sites, including the Fort Dix Landfill, vere
proposed in the Federal Register for addition to the NPL.
On September 16, 1985, "the Army entered into an Administrative Consent
Order (AGO) vith NJDEP and EPA. The AGO required the Army to conduct a
Remedial Investigation/Feasibility Study (RI/FS) and to implement the
selected remedial alternative approved by NJDEP and EPA.
The Fort Dix Landfill vas placed on the NPL in July 1987.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI and FS reports and Proposed Plan (PRAP) for the Fort Dix Landfill
site vere released to the public in April 1990. These documents vere made
available to the public in both the administrative record and at three
information repositories:
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o Fort Dix Environmental Resources Branch
Building 5512
Texas Avenue
Fort Dix, Nev Jersey
o Burlington County Library
Browns Mills Branch
348 Lakehurst Road
Browns Mills, Nev Jersey
o Nev Jersey Department of Environmental Protection
Division of Hazardous Site Mitigation
Bureau of Community Relations
401 East State St.
Trenton, Nev Jersey
The notice of availability for these documents vas published in the
Burlington County Times on April 26, 1990. A public comment period was
held from April 25, 1990, through Hay 25, 1990. In addition, a public
•
meeting vas held on May 7, 1990. At this meeting, representatives from the
Army formally presented the findings of the RI and FS and ansvered
questions about environmental conditions at the site and the remedial
t
alternatives under consideration. Representatives from EPA and NJDEP vere
also present to ansver questions. A response to the comments received
during this period is included in the Responsiveness Summary vhich is part
of this ROD. This decision document presents the selected remedial action
for the Fort Dix Landfill Site, in Pemberton Township, Nev Jersey, chosen
in accordance vith CERCLA, and, to the extent practicable, the NCP. The
decision for this site is based upon the administrative record.
2.4 SCOPE AND ROLE OF RESPONSE ACTION
The selected remedial alternative for the Fort Dix Landfill site is a
source control action that vill reduce the amount of contamination being
introduced to the ground vater. The RI vas designed to characterize
contaminant migration from the landfill through the implementation of a
series of field investigations. The FS report presents a complete descrip-
tion and evaluation of the alternatives.
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A long-term monitoring program (30 years) vill be implemented as part of
the selected remedial action to detect changes in ground vater, surface
water, and air quality.
If significant degradation in the quality of these media is noted that
produces an unacceptable risk, then further action vill be initiated.
Unacceptable risk vill be determined through a revision of the latest risk
assessment, using the most recent total volume of data. Risk assessments
vill use EPA guidance and policy effective at the time of the reviev. Thtf
effectiveness of the remedial action vill be evaluated no less often than
three years after commencement of remedial action and at least every five
years thereafter as required by CERCLA.
2.5 SITE CHARACTERISTICS
*
As a result of the Army's extensive RI at this site, the nature and extent
of contamination has been characterized in sufficient detail to conduct a
FS. the following is a summary of this characterization.
As part of the scoping for the RI, tvo suspected sources of contamination
vere identified for investigation. These areas vere the landfill and the
grease pit. The grease "pit vas evaluated through the analysis of soil
samples while the investigation of the landfill focused on characterizing
contaminant migration from the landfill through ground vater monitoring and
surface vater and sediment sampling.
The analyses of subsurface soil samples from the grease pit vere comparable
to subsurface soil samples taken to determine background or "natural*
conditions, indicating that the grease pit is not currently a source of
contamination, although it may have been in the past.
Ground vater in the shallow aquifer comprised of the Cohansey and Kirkvood
Formations immediately (approximately within 300 feet) to the south and
southwest of the landfill contained levels of VOCs and metals above
background and/or in excess of HCLs. These VOCs included, but vere not
limited to, vinyl chloride, benzene, trichloroethylene, te'trachloro-
2-7
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ethylene, 2-butanone, and toluene. In addition, inorganic compounds
(cadmium, calcium, chromium, cobalt, iron, magnesium, manganese, mercury,
nickel, and sodium) vere found at levels above background in these veils.
There vas no evidence of organic contaminant migration in the shallow
aquifer beyond 300 feet to the south/southwest of the landfill. The review
of the ground vater data collected between November 1982 and January 1986
indicated that the number of and concentration of VOCs declined*
substantially during the period of sampling events.
Magnesium, potassium, sodium, calcium, chloride, nitrate, and total dis-
solved solids were detected at levels above background in monitoring well
LP-11 (southeast of the landfill). These constituents may be attributed to
landfill leachate flowing into Cannon Run.
*
Low levels of trichloroethylene (TCE) were detected in well CDM-6, located
southwest of the landfill and screened in the Vincentown aquifer.
Additional field investigations were performed to identify the contaminant
source and consistency of contaminant concentration. Samples from three
other wells did not indicate the presence of TCE. The six sets of data
from CDM-6 Indicate a decreasing trend to the lowest level in the spring of
1989.
The landfill as a source of TCE in the Vincentown aquifer is questionable
because no other characteristics of the contaminant plume are evident in
ground water samples collected from the Vincentown aquifer. In addition,
subsurface soil samples collected from the Manasquan Formation (the
confining unit) at the location of well CDM-6 did not indicate
contaminant migration to or through this aquitard.
Further investigation of contamination detected in this aquifer is being
conducted separately from landfill activities by the U.S. Army Toxic and
Hazardous Materials Agency.
Soil screening for volatile organic vapors indicated no significant VOC
contamination within subsurface soils at any of the COM borehole locations.
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Ammonia, iron, magnesium, and calcium vere found to increase as the surface
vater sample locations approach the landfill. Berylliua, iron, and mercury
vere detected above the State surface vater criteria. Remedial criteria
for these contaminants have been established in table 1. The long-term
monitoring program (30 years) vill help determine if these contaminants are
reaching the remedial criteria once the cap is in place. Geophysical
investigations and chemical analyses of ground vater, surface vater, and
sediment samples indicate that a plume of contaminated ground vater in the
shallow aquifer is emanating from the southern portion of the landfill.
However, no contaminants from the landfill vere detected in the sediment,
surface vater or ground vater samples taken dovngradient of the area
immediately to the south of the landfill that is recharged by the
contaminated ground vater. Natural mechanisms (such as adsorption,
dispersion, and volatilization) may be dissipating contaminant
concentrations in these media to undetectable levels in the vicinity of the
landfill.
Organic compounds vere detected in only one sample from Cannon Run, a
leachate soil sample from the central eastern boundary of the landfill.
Two polynuclear aromatic hydrocarbons detected in this sample may be
related to early landfill practices of disposal of coal ash and refuse
burning. Pesticides such as DOT, vere also detected in this sample, and
may be the result of an accumulation of spraying around Fort Dix. DDT vas
used at Fort Dix in the 1950s and 1960s, although no records of usage or
disposal have been found. This information vas provided by intervievs vith
facility personnel.
VOCs vere detected at extremely low concentrations at several gas vents and
monitoring veil sampling locations. Host of these compounds vere also
detected in either field, trip, or method blanks and vere determined to be
unrelated to environmental conditions at the landfill.
A summary of contaminants detected in vater, soil, and air samples is
presented in tables 1, 2 and 3. Sample locations can be found in figures
5, 6 and 7.
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The major routes of migration of site contaminants is via precipitation and
subsequent formation and infiltration of leachate to ground vattr. They
move in the sane direction as the shallow ground vater to local discharge
areas along Cannon Run to the southeast and to the svamp to the southvest
of the landfill. Other potential routes of Migration include transport to
Cannon Run via erosion and runoff and volatilization.
2.6 SUMMARY OF SITE RISKS
During the RI/FS, an analysis vas conducted to detemine the potential for
any impact to public health and the environment vhich night result if the
contamination associated vith the Fort Dix Landfill vere not controlled in
an acceptable manner. This analysis of potential detriment to human health
or the environment, if no remediation is conducted, is commonly called a
«
baseline risk assessment. In conducting this assessment, the focus vas on
the human health and environmental effects that could result from exposure
to contaminants associated vith the landfill in various environmental media
(air, surface vater, sediments, soil, and ground vater).
During the evaluation of site risks, chemicals that vere detected in the
ground vater, surface vater, sediment, grease pit, subsurface soil and air
samples vere screened to' select indicator chemicals for the Fort Dix
Landfill site. These chemicals vere selected as those most representative
of site conditions and as those expected to contribute the greatest risks
to human health and the environment. The indicator chemicals for the site
are 1,2-dichloroethane, benzene, vinyl chloride, trichloroethylene,
tetrachloroethylene, chlorobenzene, 2-butanoiie, toluene,
trans-l,2-dichloroethylene, bis(2-ethylhexyl)phthalate,
1,4-dichlorobenzene, 1,1,1-trichloroethane, ethylbenzene, nickel, mercury,
cadmium, zinc, chromium, and manganese. EPA has classified the indicator .
chemicals as the following based on EPA's Weight-of-Evidence Categories for
Potential carcinogens:
o Benzene and vinyl chloride are classified as Group A, human
carcinogens
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o Trichloroethylene, 1,2-dichloroethane, tetrachloroethylenet
bis-(2-ethylhexyl) phthalate are classified as Group B2,
probable human carcinogens (based on aniul carcinogenic! ty,
yet inadequate evidence of human carcinogenic!ty)
o 1,4-dichlorobenzene is classified as Group C, possible human
carcinogen (based on limited evidence of carcinogenicity in
animals)
The remaining indicator chemicals are considered to be noncarcinogens by
EPA.
Human Health Risks
The human health exposure pathways that vere analyzed for current use of
the Fort Dix Landfill included:
•
o Inhalation of VOCs in the ambient atmosphere
o Direct, contact vith soils including dermal absorption of and
.incidental ingest ion of soil contaminants
o Direct contact vith surface vater in the svampy area vest of
the landfill and inhalation of VOCs
. o Direct contact • vith contaminants predicted to be present in
the North Branch of Rancocas Creek
*•
Under present conditions, exposure to ground vater in the Cohansey-Rirkvood
formation vas not considered to be a complete pathvay because private veils
are currently not in the path of the landfill plume. In addition, the
probability of future development of vater supplies in the
Cohansey-Rirkvood formation in the path of the landfill plume is unlikely
because of the characteristics of the aquifer in this area.
Exposure to soil is of greatest concern vith young children because of
their increased tendency to ingest soil. In addition, it is possible for
children to gain access to the landfill. Children have been seen playing
on and around the landfill. Thus, young children vere used to represent
the exposed population for most of the pathvays.
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The concentrations of the selected chemicals of concern at potential expo-
sure points vere estimated for each public health exposure pathway. These
"exposure point concentrations" along with assumptions concerning the ex-
posed populations, the rate of exposure, the duration of exposure, and the
level of exposure vere used in the calculation of chronic daily intakes.
For potential carcinogenic compounds, the lifetime exposure durations for
the selected chemicals of concern vere.developed to provide the upper-bound
cancer risk estimates. For chronic noncarcinogenic effects, the time
period used vas the actual period of exposure. The daily intake vas
expressed in terms of the concentration of the contaminant per unit of body
veight over the duration of the event (mg/kg/day).
The carcinogenic risks and noncarcinogenic hazards vere calculated using
the carcinogenic potency factors and reference doses (RfDs) shovn in tables
«
4 and 5, respectively. Cancer potency factors (CPF) have'been developed by
EPA's Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated vith exposure to potentially carcinogenic chemicals..
CPFs express carcinogenic potency in terms of lifetime cancer risks per
mg/kg/day" and are estimated upper 95-percent confidence limits of the
carcinogenic potency of a chemical. The carcinogenic risk vas developed
using the following equation:"
V
Risk - (LADE x CPF)
Because the CPF expresses the lifetime risk, the Lifetime Average Daily
Exposure (LADE) vas calculated by averaging the estimated chronic daily
intake by the years of exposure over a 70-year lifetime. The total
estimated carcinogenic risk for each pathvay vas estimated by summing the
individual carcinogenic risks. The results of this characterization
provided the upper-bound estimate of the potential carcinogenic risk per
pathvay. The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes the under-
estimation of the actual cancer risk highly unlikely. These total risks
vere used in the development of the aggregate risk for total ingestion,
inhalation, and dermal exposures.
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The hazard index (HI) provides a useful reference point for gauging the
potential significance of Multiple contaminant exposures vithin a single
medium or across media. Noncarcinogenic risks are assessed using a HI
approach. RfDs developed by EPA are estimates of daily exposure levels for
humans vhich are thought to be safe over a lifetime (including sensitive
individuals). Estimated intakes of chemicals are compared vith the RfO to
derive the hazard quotient for the contaminant in the particular media.
The HI is obtained by adding the hazard quotients for all compounds across
all media. A HI greater than one indicates that, potential exists for
noncarcinogenic health effects to occur as a result of site-related
exposures. The chronic daily intakes for noncarcinogens vere developed by
dividing the daily intake by one year of exposure. The RfDs shovn in table
5 vere used to calculate the potential hazards posed by the noncarcinogenic
compounds.
«
A comparison vas made between the projected chronic intake and the accept-
able intake for chronic exposure for noncarcinogens and between calculated
risks and target risks for potential carcinogens. Each exposure pathway
vas examined individually to estimate the potential health effects that
vould result from the exposure to the selected indicator chemicals. The
health risks from each'pathway were then summed to allow for a complete
evaluation of the potential risks and hazards that would be associated with
the Fort Dix Landfill and the surrounding area in the absence of remedia-
tion.
EPA has proposed that remediation should occur vhen the excess cancer risk
exceeds the acceptable range. The acceptable risk range for carcinogens is
-4
defined as an excess cancer risk posed to a population of from 1x10 to
1x10 . This is interpreted as the probability that one additional case of
x ... £
cancer in a population of ten thousand (10 ) to one million (10 ) is
expected to occur as a result of exposure to compounds associated vith a
site. For noncarcinogens, vhere the sum of expected dose/RfD ratios
exceeds one, observed concentrations pose unacceptable risks of exposure.
A summary of current site risks can be found in table 7. It vas determined
that the inhalation of VOCs detected in the ambient air vould not pose a
2-13
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significant risk to human health under both the most probable and worst
case scenarios. The scenarios developed used source concentrations and
represented the exposures that could reasonably be expected to exist during
the spring and fall. The risks to the surrounding community vould be
expected to be significantly lover than the estimated source risks due to
the distance to the nearest homes and the heavy vegetation surrounding the
site.
»
Direct contact and incidental ingestion of soils vould not present a risk
to human • calth under the vorst case conditions. For the most probable
conditions, it vas determined that this pathvay vas incomplete and vould
not present a risk to human health.
Because the calculated risk numbers in table 7 are less than the EPA risk
range of 1x10" to 1x10" , direct contact vith contaminants in the svamp
vould not pose a risk to human health. It vas also determined that the
inhalation of VOCs vould not pose a risk to human health. Risks posed by
the svamp vould be limited to individuals having access to the svamp and
vould not extend tD the surrounding community. No significant risks vould
be posed by periodic svimming in the North Branch of Rancocas Creek.
The sum of all estimated" most probable cases for carcinogenic risks under a
present use scenario for the four pathvays vould be eight additional cancer
a
cases in a billion (10 ) people. The vorst case, or more conservative
estimate, predicts an excess cancer risk of one in ten million (10 ).
Hovever, MCL's vere exceeded in the Cohansey aquifer, thereby varranting a
remedy other than no action.
Although future use of the landfill site vas not expected to result in any
additional exposure pathvays, three additional pathvays that may be of
concern in the future vere analyzed: (1) the construction of a surface
vater intake on the North Branch of Rancocas Creek; (2) the use of the
Vincentovn aquifer dovngradient of the landfill; and, (3) the use of the
Cohansey aquifer dovngradient of the landfill.
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Exposure to water from the North Branch of Rancocas Creek may be associated
7 -9
vith a 5 x 10 to 4 x 10 cancer risk using conservative assumptions. A
total estimated cancer risk for the 1989 Vincent own scenario (based on 1989
data) would be 1 x 10~7. Total risks of 5 x 10"7 and 8 x 10"6 were
estimated for the most probable and the worst cases Vincentown scenarios,
respectively.
Another possible future use is the construction of an on-site potable water
well screened in the Cohansey aquifer. The estimated risks associated with
the ingest ion of water within the plume found in the Cohansey aquifer range
from 2 x 10 to 6 x 10" . The future site risks are presented in table 8.
Under the current worst case conditions, the cancer risks associated with
the Fort Dix Landfill were at the lower end of the EPA risk range, while
the most probable case predicted the risk to be well below this range.
Based on the assumptions used in the risk assessment, noncarconogenic
hazards were predicted not to present a human health hazard under the
evaluated current and future (Rancocas Creek and Vincentown aquifer only)
case scenarios. Under future use conditions, however, the worst-case
cancer risk is above the EPA risk range. Furthermore, Federal or State
drinking water standards (HCL's) were exceeded for vinyl chloride,
1,2-dichloroethane, tritnloroethylene, benzene, tetrachloroethylene,
methylene chloride and trans-1,2-dichloroethylene.
Environmental Risks
The environmental assessment conducted as part of the RI determined that
contamination of the surface water and sediments of the swamp and Cannon
Run was limited to low concentrations of VOCs (swamp area only) and metals.
The concentrations of aluminum, calcium, iron, magnesium, manganese,
potassium and zinc were higher than would typically be expected, with iron
detected above the ambient water quality criteria. However, significant
impacts to wildlife and vegetation were not expected to occur and any
impacts to the biotic communities would be limited to areas where the
volatiles and/or metals were detected above the ambient water quality
criteria. •
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Actual or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare,
or the environment.
2.7 DESCRIPTION OF ALTERNATIVES
The alternatives presented in the PRAP vere developed based upon a
screening of possible remedial technologies, compliance of the alternatives
vith ARARs and the ability of the alternatives to satisfy the remedial
objectives summarized belov:
o To prevent contaminants that migrate from the landfill from
affecting drinking vater supplies of the local population
«
o To prevent landfill contaminant migration/exposure via Cannon
Run and Budds Run (svaap) from restricting State-designated
dovn-stream surface vater uses on the North Branch of Rancocas
Creek (i.e., fishing, svimming, and future vater supply)
o To protect people vho perform military-related or unauthorized
recreational activities on the Fort Dix property from
potentially harmful effects due to the landfill
o To satisfy all appropriate local* State and Federal
requirements for*proper landfill closure
o To prevent significant adverse environmental impacts on the
surrounding flora and fauna caused by contaminant release from
the Fort Dix Landfill
o To satisfy all site-specific ARARs as practicable
The remedial alternatives addressed both source control and plume
mitigation technologies. Excavation of the landfill material, including
the destruction of the vastes by incineration or other treatment
technologies, and its disposal off-site in a secure commercial landfill, or
re-disposal on-site in a lined landfill, vas eliminated early in the
screening process as a result of excessive cost, potential short-term
impacts on human health, and limited additional long-term benefit in
comparison to other alternatives.
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During development of remedial alternatives, it vas determined that
installation of a lov-per»eability cap over only the southernmost 50 acres
of the landfill should be evaluated because the older portions of the
landfill are believed to be exhausted of any hazardous leachable material.
The age of the landfill sections, the method of vaste material placement in
the landfill, and a thorough reviev of present and historical ground vater
quality records for the northern portions of the landfill indicated that
capping of the entire landfill is not necessary. In addition, a veil
established tree, shrub, and grass cover exists on the older portions of
the landfill. Maintenance of the existing vegetative cover is believed to
be more beneficial to the environment than installation of a
lov-pemeability cap over this older portion of the landfill.
Therefore, seven remedial alternatives vere evaluated that vould further
protect public health and the environment from the contamination identified
by the RI. The characteristics of each alternative are summarized in table
9. Remedial alternatives vere evaluated based on the nine criteria -
identified in the FS report and summarized in section 2.8 of this ROD.
CERCLA requires that each selected site remedy be protective of human
health and the environment, comply vith ARARs, utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable, and be cost-effective. The engineering
controls, institutional controls, quantity of vastes handled, and imple-
mentation requirements for each alternative vere discussed in detail in the
FS and its addendum. Each of these seven alternatives are summarized
belov. The construction cost, 04M costs, and the estimated time for
completion for each alternative are shovn In table 6.
Alternative 1 - No Remedial Action
The no remedial action alternative is defined as closure of the Fort Dix
Landfill in accordance vith NJAC 7:26-2A et seq., except that the final
cover system vould not include a lov-permeability geomembrane and/or clay
cap. Other closure improvements such as surface grading and revegetation
(vhere insufficient vegetation currently exists), stormvater and erosion
controls, gas monitoring and controls, and perimeter fencing vould be
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constructed under this alternative. Components of this alternative are
presented in figure 8.
The development and implementation of a closure and post-closure plan as
defined by NJAC 7:26-2A.9 e_t seq., vould also be included and is required
for landfill closure. The plan vould consist of both a closure and
post-closure care plan and financial plan.
In addition, the existing ground vater and surface vater monitoring program
(under NJPDES) vould be expanded to include more sampling points and more
analytical parameters.
Alternative 2 - Cap and Monitor
»
Alternative 2 involves landfill closure (as described in alternative 1
above), installation of a lov-permeability cap over the southern 50 acres
of the landfill (the never portion of the landfill), and an expanded
monitoring program (see figure 9). The partial cap vill serve to reduce
the amount of contamination being introduced to the aquifer system. The
cap vill consist of a multilayer cover system as required by RCRA and NJDEP
regulations. The three-layer cover system vill include an upper vegetative
layer, underlain by a drainage layer, over a lov-permeability layer (either
clay or geomembrane). A typical closure cap detail is presented in figure
10. This alternative also includes institutional controls in the form of
deed and vater use restrictions on future uses of the landfill and ground
vater in the immediate vicinity of the landfill.
A closure and post-closure care plan vill be prepared and vill include the
following activities: construction of a final cover (capping and
vegetation), construction of structures to control surface vater runon and
runoff, installation of a landfill gas monitoring and control system,
installation of a facility access control system, and implementation of
measures to ensure the site is compatible vith the surrounding area. A
financial plan vill also be developed and implemented.
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Monitoring of ground vater and surface vater vill continue until remedial
criteria are met as set forth in table 1, or alternatively it is determined
that further remedial action is necessary, but in either case long-term
ground vater and surface vater monitoring vill continue for 30 years under
the post-closure plan.
Alternative 3A - Ground Vater Pumping and On-sitc Treatment
Alternative 3A consists of collection of ground vater immediately
dovngradient of the landfill using extraction veils, on-site treatment, and
reinjection of the treated ground vater into the shallov aquifer, in
conjunction vith landfill closure in accordance vith RCRA and NJDEP
regulations and monitoring as described in alternative 2. Contaminated
ground vater vould be pumped out south of the landfill, treated, pumped to
the north of the landfill, and then reinjected upgradient of the capped
area. This alternative vould flush out, treat, and clean up contaminants
in the saturated zone at the site, and isolate any vastes above the vater
table. Since the ground vater is a potential future source of drinking
vater in the area, it vould be treated to meet drinking vater and ground
vater standards. The treated effluent vill meet KJPDBS requirements. A
general layout of alternative 3A is presented on figure 11.
»« •
A system of 11 extraction veils vould be installed to a depth of 30 feet to
the southvest of the landfill. Each veil vould be pumped at a rate of 10
gallons per minute, for a total of 110 gallons per minute to be extracted,
treated, and reinjected. A total of 30 injection veils vould be installed
to the norinvest of the capped portion of the landfill. The ground vater
treatment processes used in the preliminary design, presented in figures
12, 13, and 14, include unit processes grouped into the folloving nine
process system design modules:
o Module I - preliminary treatment (iron removal)
o Module II - VOC stripping
o Module III - semivolatile organic compound removal by granular
activated carbon adsorption (GAC), ion exchange, and pB
2-19
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adjustment for sodium concentration, reduction, and
neutralization
o Nodule IV - sludge and backwash handling
o Module V - lime slurry preparation
o Module VI - polymer and potassium permanganate (KMNO,)
solution preparation
o Module VII - carbon storage and transfer
o Module VIII - ion exchange regeneration and pH adjustment
o fc 'ule IX - utilities (plant vater, pover, compressed air,
heat)
Pilot testing would be required prior to final design of the treatment
system. Additional long-term monitoring (30 years) vould be required to
determine the efficiency of the treatment unit and to determine if
additional treatment for air pollution control and sludge disposal vould be
required.
Alternative 3B - Ground Vater Pumping and Off-site Treatment
Alternative 3B consists of collecting ground vater dovngradient of the.
landfill through interceptor veils, transmission of the ground vater to an
off-site facility for treatment and disposal, along vith landfill closure
in accordance vith RCRA and NJDEP regulations as described in alternative
2. Contaminated vater vould be pumped by a system of 11 interceptor veils
located to the southvest of the landfill to on-site storage, and then
transported by tanker truck to an off-site facility vhere it vould be
treated to meet NJPDES requirements. An estimated volume of 150,000
gallons per day of ground vater vould require transportation and treatment.
Collected ground vater vould be held in storage facilities vith at least
three days of storage capacity to allow the vater to be sampled and tested
daily prior to its transport. Pretreatment of ground vater for iron prior
to transportation may be necessary. Alternative 3B is presented on figure
15.
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Alternative 3D - Partial Ground Vater Pumping and On-site Treatment
This alternative is similar to alternative 3Aj the landfill vould be closed
in accordance with RCRA and NJDEP regulations, and interceptor veils vould
be used to capture contaminated ground water, vhich vould be treated
on-site, pumped to the northwest of the landfill, and reinjected upgradient
of the capped area. Since the ground water is a potential future source of
drinking vater in the area, it would be treated to meet drinking vater and
ground vater standards. The treated effluent vould meet NJPOBS
requirements. The intent of this alternative vould focus on the cleanup of
the inorganic plume alone, which is smaller in area than the organic plume.
Although treatment for VOCs vould be required for extracted ground water,
some of the organic plume would not be collected but rather vould be
allowed to discharge eventually to the surface vater bodies and volatilize
through natural processes.
Four interceptor veils located immediately to the southwest of the landfill
vould extract a total of approximately 40 gallons per minute and send it to
a treatment system consisting of the following principal components!
o Metals removal'by chemical precipitation, coagulation, and
sedimentation .
o VOC removal by air stripping
o Sludge and backvash handling
A schematic flovsheet for this proposed treatment system is presented in
figure* 16, although final design vould depend on a treatability study.
The treated vater vould be pumped to the northvest of the capped area of
the landfill for reinjection through a system of approximately eight veils.
Alternative 4A - Ground Vater Interception and On-site Treatment
This alternative consists of landfill closure vith a low-permeability cap
in accordance vith RCRA and NJDEP regulations (as presented in alternative
2), a dovngradient drainage trench or French drain to intercept the
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observed contaminant plume, an on-site treatment facility (as described in
alternative 3A), and upgradient injection of treated vater. This
alternative vas developed to accomplish the same purpose as alternative 3A,
to flush out leachable vastes in the saturated zone and treat the
contaminated vater. Since the ground vater is a potential future source of
drinking vater in the area, it vould be treated to meet drinking vater and
ground vater standards. The treated effluent vould meet NJPDES
requirements. The dovngradient drainage, trench replaces the interceptor
veils described in alternative 3A.
The dovngradient drainage trench vould be excavated to a depth of 30 feet
immediately to the southwest of the site. A geotextile filter, crushed
stone bedding and envelope, and a perforated pipe about 8 to 12 inches in
diameter vould be installed in the trench, vhich vould then be backfilled
*
to grade. The filter fabric vould be tested for compatibility vith the
contaminated ground vater. Contaminated ground vater vould be collected by
gravity. Because pumping vould not be necessary, this plume extraction
alternative vould require a minimum amount of energy.
On-site treatment and discharge of the collected ground vater vould be the
same as described in alternative 3A. This alternative is presented in
figure 17. s
Alternative 4B - Ground Vater Interception and Off-site Treatment
Alternative 4B consists of collection of ground vater dovngradient of the
landfill using an interceptor trench, off-site treatment to meet NJPDES
requirements and disposal of the ground vater (as vith alternative 3B), and
landfill closure in accordance vith RCRA and NJDEP regulations as described
in alternative 2. This alternative is presented on figure 18.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternative preferred by the Army, NJDEP, and EPA for implementation at
the Fort Dix Landfill is alternative 2, closure vith. a low-permeability cap
over the southern 50 acres of the landfill, and an expanded ground vater
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monitoring program. Based on current information, this alternative
provides the best balance among the nine criteria that EPA uses as a means
of alternative evaluation.
The alternative evaluation and comparative analysis have been made in
accordance vith the revised NCP (March 8, 1990). This section provides a
summary of the nine criteria and a comparative analysis of the remedial
alternatives to each of the criteria. The nine criteria are described
belov.
Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protectIon
and describes hov risks posed through each exposure pathway
are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
t
Compliance vith ARARs addresses whether or not a remedy meets
Federal and State environmental statutes arid/or provides
grounds for invoking a vaiver.
Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time once cleanup goals have been
met. It also addresses the magnitude and effectiveness of the
measures that may be required to manage the risk posed by
treatment residuals and/or untreated wastes.
•
Reduction of toxicity, mobility or volume of contaminants
addresses the anticipated performance of the remedy with
respect to these parameters.
Short-term effectiveness addresses the period of time needed
to achieve protection, and any adverse effects on human health
and the environment that may be posed during the construction
and implementation period of the alternative.
Implementability is the technical and administrative feasi-
bility of a remedy, including the availability and performance
of materials and services needed to implement the remedy.
Cost includes estimated capital, O&M costs, and net present
worth costs.
State acceptance indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or
has no comment on the preferred alternative.
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- Community acceptance indicates whether the public concurs
with, opposes, or has no comment on the preferred alternative
as reflected in the public comments received on the RI/FS
report and the PRAP.
The comparative analysis, which identifies the relative advantages and
disadvantages of each alternative under each evaluation criterion, is
presented below.
Overall Protection of Human Health and the Environment
The baseline risk assessment determined that the landfill does not present
significant risks and hazards to human health and the environment under the
known site use conditions. Each of the alternatives, including no action,
incorporates features to protect human health and the environment. These
are described below.
o Opportunity for direct contact with soils would be reduced by
construction of a fence.
o Surface grading would control runoff and erosion of soils.
o Based on water level elevations and water quality data south
of the landfill, the exposure pathway for ground water is
currently incomplete.
o Surface water and sediments pose no significant risk through
direct contact or ingestion exposures, and contaminant concen-
trations would continue to decrease through natural attenua-
tion.
o Existing institutional controls would prevent future use of
ground water from within the area of the contaminated ground
water plume.
o Gaseous emissions from the landfill pose no significant risk.
o Monitoring of ground water, surface water, and air quality
will provide sufficient advance notice of adverse changes from
existing conditions to allow determination of need for
additional remedial actions, and their implementation before
significant exposures could occur.
In each alternative, except Alternative 1 - no action, construction and
maintenance of a low-permeability cap would reduce leachate formation by
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limiting the infiltration of rain vater through the landfill and,
subsequently! the rate of contaminant discharge to ground vater and surface
vater. The cap also vould Minimize the incidence of soil transport by
erosion, and reduce the opportunity for direct contact by covering soils
and fill material that may be contaminated.
The ground vater interceptor and treatment systems proposed for alterna-
tives 3A, 3B, 4A, and 4B vould capture a significant portion of the con-
taminant plume exiting the landfill, reducing the total contaminant load
that may discharge to surface vater. The interceptor system proposed for
alternative 30 vould provide a smaller capture zone than the systems
evaluated for the other alternatives, and vould allow most of the ground
vater plume to discharge to surface vater.
«
None of the ground vater treatment alternatives vould provide any
additional public health benefit over landfill closure vith monitoring (the
selected remedy) because existing conditions currently do not pose a
significant risk to human health and the environment and the
lov-permeability cap should significantly reduce the generation of leachate
discharging to the ground vater.
*
Compliance vith ARARs .
Each of the seven alternatives vas estimated to achieve chemical-specific,
location-specific, and action-specific ARARs for ground vater quality and
surface vater quality, based on existing conditions and the expectation
that no future releases vould occur. The ground vater and surface vater
quality standards are based on State and Federal NCL's for drinking vater,
State ground vater and surface vater quality criteria, Federal vater
quality criteria, and NJPDES requirements. The location-specific ARARs,
including the E.O. 11990 "Protection of Wetlands", Nev Jersey Freshvater
Vetlands Act (NJAC 7:7A-1.1), E.O. 11988 "Floodplain Management", and
Section 7 of the Endangered Species Act, vill be addressed in the design
documents for the selected alternative. Any activities in the floodplain
of Cannon Run vill be designed in accordance vith the Flood Hazard Area
Control Act Regulations (NJAC 7:13-1.1 et seq.) for stream encroachment.
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Each alternative, except alternative 1, vould Beet landfill closure
requirements under RCRA and NJDEP regulations, and vould satisfy NJPDES
requirements. No action is not an appropriate alternative because of the
AGO and RCRA closure requirements for the landfill. Therefore, it vill not
be considered further in this analysis as an option. The soil erosion and
sediment control plan and the gas venting system vill conform to
requirements vithin the Soil Erosion and Sediment Control Act of 1975 (NJSA
4:24-40 et. seq., and the regulations NJAC 2:90-1.1 et seq.), arid Air
Pollution Control Regulations (NJAC 7:27-1 et seq.).
The alternatives incorporating ground vater treatment are expected to meet
NJDEP requirements for air emissions and NJPDES requirements for either
reinjection of treated effluent or its acceptance at a publicly-ovned
treatment vorks. The operation of the on-site treatment system vould
«
comply vith RCRA requirements.
Location-specific and action-specific "to be considered" (TBC) goals
identified for the Fort Dix site include State endangered plant/animal
habitat species and veil drilling, sealing, and pump installation
requirements. Although potentially threatened species or habitats vere
identified, vithin one mile of the site, the Fort Dix Landfill is not"
»,
impacting these areas. Veil drilling, sealing, and pump installations vill
be addressed in the design documents and vill be conducted in accordance
vith the Nev Jersey requirements for all actions.
Long-Term Effectiveness and Permanence
The technologies employed by each of the alternatives historically have
shovn high reliability, vith proper maintenance.
Under present site conditions (table 7) the total risk to human health
under a vorst-case scenario is 1x10" . Because this number is less than
the acceptable risk range, current exposure to the site is not expected to
pose a significant risk. The estimated cancer risk under future ground
vater use, however, is greater than the acceptable range and may pose a
significant risk.
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None of the alternatives provides a permanent remedy, and reviews of the
performance of the remedy vill be needed no less often than three years
after commencement of remediation and every five years thereafter, as
required under CERCLA. It is unlikely that Fort Oix, knowing the risks
that could result from the consumption of this water, would construct a
well for drinking water purposes either through or in the plume associated
with the landfill. In addition, it is unlikely that NJDEP would approve of
a well permit application for a water supply well in this area. As long as
Fort Dix maintains control of the landfill, the possibility of constructing
a well on-site is minimal. This aquifer will continue to be monitored and
appropriate remedial action will be implemented if needed.
Alternative 1 provides no controls for contaminant migration. Contaminants
would continue to migrate from the landfill to ground water, and subse-
quently to surface water.
Alternative 2 is a relatively simple remedy to operate and maintain.
Performance of the cap, passive venting system, and monitoring system are
reliable with proper maintenance. Monitoring would continue until the
remedial criteria for ground water and surface water are met as set forth
in table 1, or alternatively it is determined that further remedial action
is necessary, but in*either case long-term ground water and surface water
monitoring will continue for 30 years under the post-closure plan. If
significant increases in unacceptable risk to human health and the environ-
ment are determined in the revised risk assessments, additional remedial
action vill be proposed. Unacceptable risk vill be determined through a
revision of the latest risk assessment, using the most recent total volume
of data. Risk assessments vill use EFA guidance and policy effective at
the time of reviev. Once additional remedial action is deemed necessary,
clean-up goals for the ground water and surface water will be based on
chemical specific ARARs. Institutional controls (i.e., technical and/or
administrative restrictions placed by the Federal and/or State agencies) on
land use can be maintained as long as the Army retains control over the
landfill. Land use restrictions currently in place could be altered
through legislative action or the public review process, but should be
reliable at least through the planning period for the-remedial action.
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Vater use restrictions, if enforced properly through local, state, and
federal agencies, should also be reliable.
The ground vater interception and treatnent components of the other
alternatives are expected to be short-term actions (10-year planning
period), and provide no additional benefit toward long-term effectiveness
because remedial criteria are expected to be met vithin the same time frame
as in alternative 2.
Current risks and hazards to human health at the site are belov EPA's risk
range. The alternatives 2, 3A, 3B, 3D, AA and 4B would act to minimize
these risks even further, vhile Alternative 1 to a lesser degree, vould act
to minimize some of these risks. To minimize any future risk and to
evaluate the ground vater, surface vater, and air quality, these three
media vould be monitored under all alternatives.'
Reduction of Toxicity, Mobility, or Volume through Treatment
Under CERCLA, remedies that use treatment to permanently and significantly
reduce the toxicity, mobility, or volume of contaminants are to be given
preference over remedies that do not. Bovever, full compliance vith this
criterion is impractical at the Fort Dix Landfill, vhere the contaminated
volume is large and contaminant concentrations are believed to be lov.
Each of the alternatives selected for detailed evaluation in this report
vould allov this potential source of contamination to remain.
Alternative 2, and each of the remedial actions Incorporating ground vater
treatment, reduces the rate of contaminant migration to surface vater, and
the volume of the leachate generated, by reducing the infiltration of rain
vater through the landfill. Treatment of the ground vater is currently not
necessary for protection of human health or the environment, and treatment
of the landfill contents is not practical.
Treatment of the ground vater vould reduce the toxicity of the present-day
plume, and vould reduce the total amount of contaminants-eventually dis-
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charged to surface water. Under existing site conditions, ground water
treatment is not expected to yield significant benefit over landfill
capping alone, because the aaount of contamination discharging to surface
water is small and the contamination appears to be dissipating through
natural processes. Contaminants currently discharging to surface water
bodies do not present a threat to human health or the environment.
Alternatives 3A and 4A provide treatment to'the maximum practical extent,
but would produce residues (alkaline iron sludge and spent activated
carbon) that would require off-site disposal or additional treatment.
Alternative 30 would treat a smaller volume of ground water (50 instead of
220 gallons per minute), but would produce a smaller amount of sludge for
disposal, and no spent carbon. Alternatives 3B and 4B are similar to
alternatives 3A and 4A, respectively, but provide for off-site treatment of
the ground water.
Short-Term Effectiveness
Because volatile organics and particulate matter could be released into the
atmosphere during* the installation of the landfill cap, contingency plans
and monitoring plans for construction will be developed under the design-
stage documents to minimize risks to on-si.te workers or to the community.
Risks to the community will decrease as attenuation decreases contaminant
concentrations. Yorker protection will be maintained by monitoring to
detect deviations from expected conditions, and use of engineering
controls, including respiratory or dermal protection, if needed.
No significant adverse impacts are expected from the short-term operation
of any of these alternatives except 3B and 4B. Engineering controls will
be used to control surface runoff and minimize erosion, and suppress dust
generated during construction. '
Construction and maintenance of the low-permeability cap, under each of the
alternatives except "no remedial action," will significantly reduce the
rate of leachate formation and subsequent contaminant loading to ground
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water and surface vater. Alternatives 3A, 3B, 4A, and 4B will signifi-
cantly reduce the total contaminant loading to surface vater by intercept-
ing the contaminant plume exiting the landfill. However, the increase in
truck traffic associated with the off-site transport of ground vater under
alternatives 3B and 4B constitutes an undesirable short-term impact. Under
alternative 3D, most of the contaminant plume vould be allowed to dis-
charge. Alternative 2 vould allov all of the plume to discharge to surface
vater, but at a much lover rate than alternative 1, "no remedial action."
As there is no significant risk to public health or threat to the environ-
ment under current conditions, the differences in the rate or quantity of
contaminants discharged is not a critical factor in remedy selection.
Contaminant concentrations are lov and may be dissipating to undetectable
levels through natural processes.
Implementability
Excluding consideration of "no remedial action*, Alternative 2 vould be the
most simple to construct, and its O&M vould be the most straightforward.
Construction and operation of alternatives 3A, 3B, and 3D vould be more
complex, as there vould be more components to construct and operate, but
still vould be fairly straightforward. Conventional treatment processes
vould be used, and equipment specialists and materials are available.
Alternatives 4A and 4B vould be somewhat more difficult to implement.
Construction of the trench vould require devatering, and the collected
vater vould have to be treated for disposal. During operation an estimated
50 trips per day of trucks of 6,000-gallon capacity vould be required to
transport ground vater offsite for treatment. Over time the interceptor
trench may experience clogging or structural failure, and its repair or
replacement vould-be as difficult and costly as its construction.
Each alternative includes a monitoring program that vould provide notice of
deviations from expected environmental conditions or failure of the remedy
vith sufficient advance notice to determine vhether additional remedial
actions are warranted, and allov their implementation before significant
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exposures can occur. If additional actions are warranted, any of the
alternative remedies could be augmented by additional remedial actions
(e.g. extended cap, additional capture veils, changes to treatment process)
without interfering vith the existing remedy.
Under each alternative, KJDEP approval through NJPDES would be needed to
incorporate additional ground vater monitoring veils, and monitoring at
surface vater discharge points. Should land use and vater use restrictions
be necessary they vill be arrived at through consultation vith EPA, NJDEP, .
and the Army.
Under alternatives 3A, 3D, and 4A, NJDEP approval vill be needed for air
stripper emissions and effluent reinjection. Off-site disposal of
treatment residues may become more difficult as disposal regulations and
capacity limitations become more restrictive.
Under alternatives 3B and 4B, a Significant Indirect User permit and
approval from the Mount Holly Utilities Authority vill be needed for ground
vater to be received at the Mount Holly treatment plant. The facility
management has stated its willingness to accept ground vater from the site
for treatment.
Costs
Alternative 2 has the lowest total project and operating costs of all the
alternatives, except "no remedial action.* Construction of the cap is the
most expensive component of any of the remedies, but its annual maintenance
cost is the lowest*
Alternative 30 has the next lowest total project cost of the alternatives,
but offers no significant benefit over alternative 2. It has the next
lowest annual O&M costs, about 40 percent of those for alternative 3A or
4A, but would be much less effective in intercepting contaminants before
discharge.
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The total project costs of alternatives 3A, 3B, 4A, and 4B are comparable,
vith 3A being the least expensive. Annual costs for 3A and 4A are similar,
as are annual costs for 3B and 4B. Annual costs for these alternatives are
several times greater than for the other alternatives. A summary of costs
for each alternative is presented in tables 6, 11 and 12.
State Acceptance
•
The New Jersey State Department of Environmental Protection concurs vith
the selt-ied remedy.
Community Acceptance
Public comments on the Proposed Plan are addressed in the Responsiveness
Summary.
2.9 SELECTED REMEDY
The Army, EPA, and NJDEP have evaluated the remedial alternatives in
accordance vith Section 121(b) of CERCLA and Section 300.432 of the NCP,
and have selected alternative 2 as the preferred remedial action for the
landfill based on the findings of the RI/FS.
The selected remedy for the Fort Dix Landfill, alternative 2, is landfill
closure vith a lov-permeability cap and an expanded environmental
monitoring program subject to EPA approval. This provides a landfill
closure plan in accordance vith NJAC 7s26-2A et seq. The preferred remedy
includes but is not limited to:
1. Installation of a cap on the southern 50 acres of the
landfill that vill consist of vegetative, drainage, and
lov-permeability layers. Tvo feet of final cover vill be
maintained on the remaining portion of the landfill vhich
vill not receive the cap. The final cover requirements vill
be developed in consultation vith NJDEP and EPA.
2. Installation of a landfill gas venting and air monitoring
system (to determine if methane gas and VOC emissions require
treatment).
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3. Installation of chain-link fence around the perimeter of the
landfTil to restrict access to the site.
4. Implementation of landfill closure requirements in accordance
vith KJAC 7:26-2A et seq., and RCRA guidance.
5. Long-term ground water, surface vater, and air monitoring (30
years) pursuant to the Nev Jersey State closure requirements.
A yearly statistical analysis will be performed on the
chemical analysis results to determine the trend of the
overall contamination levels.
6. Long-term O&M to provide inspection of and repairs to the
landfill cap.
7. Institutional controls in the form of deed and vater use
restrictions on future uses of the landfill and ground vater
in the immediate vicinity of the landfill.
8. Development and implementation of a soil erosion and sediment
control plan in accordance vith the Soil Erosion and Sediment
Control Act Regulations of 1975, NJSA 4:24-40 et seq., and
NJAC 2:90-1.1 et seq. '
9. Using the data obtained in the monitoring program, the risk
assessment vill be revieved and subsequently revised if the
trend shovs significant changes in vater quality. These
revievs and revisions vill occur no less often than three
years after commencement of remedial action and every five
years thereafter. Any changes in actual exposure scenarios
vill be addressed in the revised risk assessments. Risk
assessments vill use EPA guidance and policy effective at the
time of the re^viev.
10. If significant increases in unacceptable risk to human health
and the environment are determined in the revised risk
assessments, additional remedial actions vill be proposed.
In addition, monitoring vill be conducted during the design phase that vill
include the folloving:
1. Collect and analyze sediment samples at the point vhere
Cannon Run discharges into the North Branch of Rancocas
Creek;
2. Perform standard bioassay testing for freshvater species on
samples collected from a piezometer, a proposed monitoring
veil, and surface vater along Cannon Run;
3. Conduct air sampling for volatile organic analysis; and,
4. Sample nevly installed and selected existing monitoring veils
for chemical analysis.
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This alternative is protective of human health and the environment,
complies vith ARARs, and is cost-effective. A list of ARARs for this
alternative is set forth in table 10. Labor, materials, and methodologies
are available for implementation of this alternative. Short-term risks
associated vith alternative 2 are construction-related and can be
minimized. The lov-permeability cap effectively reduces the amount of
infiltration and leachate generated by the landfill, provides a protective
layer that reduces potential impacts to the environment and public health,
and costs less than the other "action* alternatives.
As vith all of the alternatives, a long-term environmental monitoring plan
(30 years) vould be developed as part of landfill closure to monitor the
effectiveness of the remedy in protecting the environment and public
health. The results of the environmental monitoring vould be reviewed by
the Army, EPA, and NJDEF. Based on the results of this monitoring,
additional remedial actions may be required as appropriate.
»
Treatment of the ground vater is currently not necessary for protection of
human health or the environment. Treatment of the landfill contents is not
practical as described in the FS (i.e., the contaminated volume is large
and, based on the historical and RI data, the contaminant concentrations
are believed to be lov). Recent guidance pn remedy selection under
CERCLA indicates that treatment need not be considered under these
circumstances. LDR are not applicable to this action because the landfill
vill be capped and placement vill not occur.
2.10 STATUTORY DETERMINATIONS
The primary responsibility of the Army and EPA at Federal Facility
Superfund sites is to undertake remedial actions that achieve protection of
human health and the environment. In addition, section 121 of CERCLA
establishes several other statutory requirements and preferences. These
specify that vhen complete, the selected remedial action for this site must
comply vith applicable or relevant and appropriate environmental standards
established under Federal and State environmental lavs unless a statutory
vaiver is Justified. The selected remedy also must be cost-effective and
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utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ treatment that
permanently and significantly reduce the volume, toxicity, or mobility of
hazardous vastes as their principal element.
Protection of Human Health and the Environment
Because it vould include fencing, capping, monitoring, landfill gas
venting, and deed restrictions, the selected remedy vould be protective of
human health and the environment. Hov the selected remedy vill address
each potential exposure pathvay is presented belov.
Air. Following installation of the 50-acre cap, and revegetation of the
capped areas, exposure pathways involving air transport of contaminated
particulates vould no longer be complete. Those areas to the north of the
proposed cap, vhich are. not heavily vegetated, vould be covered with clean
soil and revegetated to maintain at least tvo feet of clean soil over the
landfilled material. The vegetation should reduce the erosion of the
surface and the transport of soils as fugitive dusts. Restricted site
access vould also reduce the potential for exposure at the older sections
of the landfill.
Methane, other gaseous components of anaerobic degradation, and VOCs vould
be released to the atmosphere from the passive gas-venting system installed
as part of closure. Bovever, the emission of VOCs is not expected to
present a threat to public health under knovn site conditions. In
addition, the air monitoring program vould be used to evaluate the
effectiveness of the system and to predict impacts to on-site workers and
the surrounding community.
Soils. Placement of the cap over the never sections of the landfill vould
cover any contaminated soils or vaste materials present at the surface of
the landfill. As long as the integrity of the cap is maintained, the
exposure pathvay of direct contact vith contaminated soil or vaste
materials vould be eliminated. In addition, the construction of the fence
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around the landfill to restrict site access also vould limit opportunities
for contact with on-site soils. Grading of the site and construction of
the cap vould reduce or eliminate hazards associated vith erosion or
vashout of on-site soils, and the exposure of refuse and construction
materials. Construction of the cap would, therefore, prevent the landfill
from presenting a risk to human health and the environment by eliminating
the exposure pathways involving direct contact yith contaminated soils, or
their transport in surface runoff.
Ground Water. Capping the landfill would significantly reduce the rate of
migration of contaminants to the ground water. If the landfill does not
continue to act as a source, the reduction in infiltration caused by the
cap would allow an eventual improvement of ground water quality.
The composition of the landfill materials was not' investigated during the
RI. However, inferences can be made regarding the likelihood of future
releases based on the information that is available. Because disposal
practices were controlled from 1980 until disposal activities ceased, it is
believed that drummed wastes are absent from the area identified as the
most likely source of the contaminant plume. Soils and fill materials have
been washed by infiltrating precipitation for up to 40 years, which would
be sufficient to remove most of the leachable waste material. Moreover,
there has been no evidence of episodic releases since ground water
monitoring was initiated in 1979. For these reasons, it is believed that
significant releases are not likely to occur at any future time.
Potential exposure pathways for ground vater are considered to be
incomplete under existing conditions. Institutional controls restricting
the use of on-site ground water would be needed to prevent exposure to
contaminated ground vater through future uses. Existing controls should be
adequate for this purpose. The purpose of the monitoring program is to
determine if further action at the Fort Dix landfill is needed.
Surface Vater. The construction of the landfill cap vould not directly
eliminate the existing contaminant plumes, or the transport of drainable
vastes (if present) from the landfill into the ground vater flow field.
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However, the cap would reduce the amount of leachate generated by reducing
the amount of infiltration. The baseline risk assessment determined that
periodic contact vith surface vater and sediments in the svamp and Cannon
Run would not pose a significant health risk to children playing in that
area, under existing conditions. Surface vater quality should improve over
time with the installation of the cap, with resulting reductions in
estimated risk.
Leachate seepage from the landfill will be significantly reduced through
capping, and fencing will restrict access to those sections of Cannon Run
immediately adjacent to potential seeps. The potential health risks
associated with exposure to contaminants in Cannon Run are not significant
under known conditions, and would be reduced to even lower levels by these
remedial measures.
*
Biological Community. Construction of a fence around the site and sections
of Cannon Run would decrease the likelihood of domestic or wild animals
coming in contact vith contaminated soil or ingesting contaminated plants.
However, fencing the site will make the landfill a less viable habitat for
larger animals. •
Continuation of contaminant discharge to either the svamp or Cannon Run may
result in adverse impacts to aquatic life, vegetation, and wildlife that
use these areas as a vater source. However, it is expected that the
adverse effects would be minimal, considering the nature and levels of the
contaminants detected in the ground vater and the history of improved vater
quality.
Compliance vith ARARs
The selected alternative consists of closure of the Fort Dix Landfill in
accordance vith NJDEP and RCRA regulations, along vith a sampling program
to monitor changes in ground vater, surface vater, and air quality. This
alternative vould also include a closure and post-closure plan as defined
by NJAC 7:26-2A.9 et seq. Monitoring of ground vater and surface vater
vill continue until remedial criteria are met as set forih in table 1, or
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alternatively it is determined that further remedial action is necessary.
The soil erosion and sediment control plan and the gas venting system vill
con fora to requirements vithin the Soil Erosion and Sediment Control Act of
1975 (NJSA 4:24-40 ejt seq. and the regulations NJAC 2:90-1.1 et seq.), and
Air Pollution Control Regulations (NJAC 7:27-1 et seq.). Any activities in
the flood plain of Cannon Run vill be designed in accordance with the Flood
Hazard Area Control Act Regulations (NJAC 7:13-1.1 e_t seq.) for stream
encroachment. .
t
A health \nd safety program for the installation and maintenance of the
landfill closure elements and monitoring program would be established in
compliance with the National Institute for Occupational Safety and Health
and the Occupational Safety and Health Administrations.
Location-specific ARARs, including the E.O. 11990 "Protection of Vet lands",
Nev Jersey Fresh Water Wetlands Act (NJAC 7:7A-1.1), E.O. 11988 "Floodplain
Management", and Section 7 of the Endangered Species Act vill be addressed
in the design documents for the selected alternative.
Location-specific and action-specific TBCs identified for the Fort Oix site
include State endangered plant/animal habitat species and veil drilling,
sealing, and pump installation requirements. Although potentially
threatened species or habitats vere identified vithin one mile of the site,
the Fort Dix Landfill does not impact these areas. Well drilling, sealing,
and pump installations vill be addressed in the design documents and vill
be conducted in accordance vith the Nev Jersey requirements for all
actions.
Cost
"he (elected remedy is cost-effective because it has been determined to
Provide overall effectiveness proportioned to its costs (present vorth -
114.3 million). Tables 11 and 12 compare estimated costs affiliated vith
••eh component of all alternatives. The selected remedy has significantly
lover capital and 04M costs than all of the other "action" alternatives.
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Utilization of Permanent Solutions and Alternative Treatment Technologies
or Resource Recovery Technologies to the Maximum Extent Practicable
The Army, EPA, and NJDEP have determined that the selected remedy
represents the maximum extent to vhich permanent solutions and treatment
technologies can be utilized in a cost-effective manner.
Based upon the information presented, the selected remedy vill protect
ground vater quality by reducing infiltration and leachate production. It
provides the best balance among all nine evaluation criteria, with the
following being the most important considerations for the site:
1. Compliance vith State and Federal ARARs for solid waste
landfill closure
2. Availability of equipment and materials
3. Cost of construction, 04M
4. Elimination of rain vater infiltration and, thus, reduction
in the volume of leachate released to the ground vater
5. Continued monitoring to ensure the remedy continues to be
protective of human health and the environment
Preference for Treatment as a Principal Element
The selected remedy does not satisfy the statutory preference for treatment
because treatment is impractical. The remedy does not include treatment of
any contaminated matrix. Treatment of the source of contamination (the
landfill itself) is technically impracticable because of the large volume
of material, the expected heterogeneity of the material, and the lov
contaminant concentrations believed to be present. The feasibility of
treating isolated, heavily contaminated areas cannot be evaluated because
the nature and extent of contamination vithin the fill area has not been
quantified.
None of the ground vater treatment alternatives vould provide any
additional public health benefit over landfill closure vith monitoring (the
selected remedy) because existing conditions currently do not pose a
2-39
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significant risk to human health and the environment and the
low-permeability cap should significantly reduce the generation of leachate
discharging to the ground water. The monitoring program that will be
implemented as part of this action will better define the nature and extent
of contamination (organic and inorganic) and detect changes in ground
water, surface water, and air quality. These data will be reviewed as they
are collected, so that if significant degradation in the quality of these
•edia is noted, then further action can .be initiated. Unacceptable risk
will be determined through a revision of the latest risk assessment, using
the most :ecent total volume of data. Risk assessments will use EPA
guidance and policy effective at the time of the review. Also, the
effectiveness of the selected remedy will be reevaluated no less often, than
three years after commencement of remedial action and at least every five
years thereafter as required under CERCLA.
(fort_dix/101)
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ATTACHMENT 1 FIGURES
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_J
^ I
t McGuire Air Force J
Base |
)
-/N
X
V*>
\s
\
Training Area
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1000 0 1000
SCALE PEST
COM
Figure 2
Site Location Map
Fort Oix Sanitary Lancfili
-------
LEGEND
AplcuHuiai fUsktenllal
AP A0ilCiilluial Pioduciion
R-1 lUoh Density Single Family Residential
0 ' •-"" Single, and Multiple Family
um Density Slnflla FamUy H«sideiilidl
H-6 Low O«nslly Slngl* FamUy
R-17 V«iy Low O«naily SlnQl* f wnUy
Mil Mobil* llom* n«sld*nll«l
TC Town C«ni«r
HO Ikuplial 0«v«lopm«nl
QIM IU"'V*"0n
LHH
KG KMMMfy Couda
* School
Land Use Mup
Foil Olx Sanitary
-------
N
1000
0 Materiai Riled Between 1974.1984
(?) Material Pilled Between 1970-1974
CQ Materiai Filled Between 1963-1970
0 Matehal Riled Between 1996-1963
(D Materiai Riled Before 1996
COM
Rgure 4
Fort Dix Landfill Development Progression
Fort Dix Sanitary
-------
N
Swampy Area
0 MW
(f)
O
IOOO
1000
PgureS
Monitoring Well and
Piezometer Locations
i
Fort Obc Sanitary Landfill
poon
ORIGINAL
-------
N
LEGEND:
C Surface Water
and Sediment
Sample Location*
1000
1000
SCALE FEET
COM
Figure 6
Surface Water. Sediment and
Leacnate Sample Locations
Fort Oix Sanitary UncMi
-------
N
r*1 Pvmocfton—Brawn* Millt Read
Swampy Area
Rancocas
LEGEND:
• .Air Samplt* Locations
• IF-Air Samp* Monitoring Wall
•OW—Downwind Sampte Location
•UW—Upwind Sampto Location
1000 o 1000
SCALE FEET
COM
Figure 7
Air Sample Locations
Port Oix Sanitary
-------
.N
1000
1000
COM
Figure 8
Alternative 1
No Action
Fort Ota Sanitary Landfill
-------
N
3 +i? ^^X,
Ptmbtrteo Ofo*ni MUls Read
1000
COM
Figure 9
Alternative 2
Landfill Closure
Fort Qix Sanitary Lanofilj
-------
Grass
v.r;*i-j '-ivr.' stfc;. »• f v;
FiH«f Fabnc
36 mil
Geomambrana
Unar
Nolle
COM
Figure 'i
Typical Closure Cap Detail
Side Slopes <7 %
Fort Oix Sanitary LandHi!
-------
N
Sctwntiic Injection
WtU
Senwnatle tmtmptor
WtlFMi
1000
1000
COM
Figure 11
Alternative 3A
Plum* Pumping, Treatment and Reinjectior
Fort OU Sinitiry Lane
-------
Mr
ph
Rawwatof
tan lank
125 gpm
Blower
700 dm
UTHaO
2 HP
Urn.
0-1.1 gph
1/4 HP
09gphHaO
10>KCa(OH)2
38gpd
fcom
bom
moduialX
Bachwash
357 gpm/liller
IS nun.
ftotUualF*
•ocadaOon
Scdlnwnlallon-
mtUfing
KMn04
8%:
Of*
125 gpm
60* TOM
5 Hp
Shjdfl*
pump
•" ^
1.5 ppm
» gph
Irom
4 25 gpm
1/SolliiM
modutolV
Backwash
sloiagc
12.000 Gal
5«Mn
module N
COM
FlQiiro li!
Trealmenl Process Schematic
Module I
Fort Oil SaniMry I jn.ll/U
-------
OFF GAS: (391-50) mgl x 8.34 X 0.18 -.512 ppd In 3340 ACFM x 1440 - 481 HO8 ACF
Hotwtftf
3.44 x 10 §
Blu/tir.
Frommodutel
65°F
140°F
85°F
ttoal •xchanger
300 «g ft.
100°F
Oil gas
VOC
•Kipper
column
130°F
Blower
To module III
COM
Ml
t mtn*g«m*nt coniuHtnn
Fiymu 13
Treatment Process Schumniic
Modulo II
foil Oi« SdiiilJiy I jiulliU
-------
125 gpm
fca«
125
30-TDII
LEGEND:
1
1cgpai;ISnln.
I
t
GACI
Ill gpm; oh.
Fraahi
I
t
OAC2
too
I
I
I
r
Ito. I
Towaato
IIMgpd^^
2410 gpd _
2IT40gpd^^ |
iliMiy
lOgph
M«l«ring
Pump
ba
Eidiang*
No. 2
25 gpm
phAd|
Static
To ElUuanl Tank
NOTE: Votum«t ol ragciMiant. spanl add
and «ISM. hw both unit
COM
FlQuia 14
Traalmeni Process Schematic
Modulo III
Foil Ou SjniUiy
-------
N
Sdwmatic Inttrctptor
WHRtW
Ptmbtneo—0
-------
"D
~°
oo
=9 33
OO
CDM
tnvroamoatsl »rrr
-------
Schematic Injection
Weil
'WMNO.
Sdwtnalte Lorn*"*1
at Intwaptor Orairag* Trwdi ^TvT
Swwnpy Arm
Pwntwion QIOWIIS Mills Road
1000
1000
COM
Figure 17
Alternative *A
Interceptor Drains.
Treatment and Reinfection
Fort OU Sanitary Landiii:
-------
' N
W«i NO.
A-1.2
S-». S
•-«. to
IBUNO:
GTMM Pit
Sctwnatte loctfton .*• .
at Intacwptor Driinag* Twnchs^ .--
Swampy
COM
Figure
Alternative •
Interception Drair
Treatment and Discharg
Fort Dix Sanitary Undfi.
OOR QUALITY
ORIGINAL
-------
ATTACHMENT 2 TABLES
-------
TABLE 1
SMART OF OCNEAKINANrS Lb'LVL'HU IN GROIN) WATER
StFFACE WATER IN CAMCN RLN
AM) SWAMP WATER TABLE SAMPLES
Organic
Chemicals
Volatile;:
Vinyl chloride
Chloroe thane
Methylene chloride
Acetone
1 , 1-Oichloroe thane
trans-1 , 2-Dichloroetnylene
1 , 1-Dichloroethylene
1 , 2-Dichloroe thane
2-Butanone
1,1, 1-Trichloroe thane
1 , 2-Dichloropropane
Trichloroetnylene
Benzene
4-Methyl-2-pentanone
Tetrachloroethylene
Toluene
Ethyl benzene
Total xylenes
Acid, Base/Neutral:
1, 4-Dichlorobenzene
4-Methylphenol
Isophorone
Benzole acid
Napthalene
Diethylphthalate
bis(2-Ethylhexyl)
phthalate
Di-n-butylphthalate
Frequency
of
detection
3/37
6/37
3/37
6/37
7/37
6/37
0/37
2/37
V37
3/37
3/37
10/37
6/37
4/37
4/37
5/37
6/37
6/37
1/37
3/37
17/37 •
3/37
4/37
6/37
23/37
1/37
Ground Water
Maxinun
concentration
-------
TABLE 1
(continued)
SUfiART OF OCNTAMnWNTS DETBCIH} IN OWN) WATER
AM) SURFACE USER
Surface Water from Cannon Run Remedial Criteria
Organic
Chsncials
Volatiles:
Vinyl chloride
Methylene chloride
Acetone
Chloroe thane
1 , 1-Dichloroe thane
trans-1 , 2-
5J
ND
W
ND
4J
ND
Geometric ,
mean FWT EWXT
(ug/1) (ug/1) (ug/1)
ND 2* WK
ND A.7^N
ND
ND
m *i
H> 700^ ....
ND 0-05^
ND 0.383
HI «
ND 3,100^
ND ...
ND 2.7TL
ND 1.2^*
»
ND ^.8
ND 10,0002
ND 3,100^
ND
ND 400
ND
2.7
ND
ND ^
ND 23,000^
*iV
3C 1 O^J"
.0 +v"
ND 2700 J
-------
TABLE 1
(continued)
SUtttRT OF OQNEAKINANES Ltltt'IlU IN GROUD UKDE8,
SURFACE BOER IN CAWCN ION,
AN) SlttMP VATER TAH£ SAMPLES
Organic
Chancials
VoLatiles:
Vinyl chloride
Methylene chloride
Acetone
Chloroe thane
1 , 1-Oichloroe thane
trans-l,2-dichloroethylene
1 , 1-Dichloroethylene
1 , 2-Dichloroe thane
2-Butanone
1,1, 1-Trichloroethane
1 , 2-Dichlotopropane
Trichloroethylene
Benzene
4-Methyl-2-pentanone
Tetrachloroethylene
Toluene
Ethyl benzene
Total xylenes
Acid, Base,/Neutrals:
1,4-Dichlorobenzene
4-Methylphenol
Isophorone
Benzole acid
Naphthalene
Diethylphthalate
bis(2-£thylhexyl)
phlhalate
Di-n-butylphthalate
Frequency
of
detection
0/6
2/6
0/6
1/6
1/6
1/6
1/6
0/6
0/6
1/6
0/6
1/6
0/6
1/6
0/6
0/6
0/6
0/6
0/6
0/6
0/6
1/6
0/6
1/6
0/6
0/6
Swanp Water Table
Maximum
concentration
(us/1)
to*
110
to
12
12
LJ
LJ
ND
to
8
ND
23
ND
93
to
to
to
LJ
t
ND
ND
ND
21
to
9
to
to
Geometric
mean
(ug>l)
ND
69
ND
12
12
1
LJ
ND
to
8
to
2
to
93
ND
to
to
LJ
ND
ND
ND
21
ND
9
ND
ND
Remedial Criteria*
FW2 FH3C
(ug/1) (ug/1)
2*
*W
4.7~K
Lit
700 *ff
°'<*ff
0.38^*
OJ
3,100*3
*K
7 7
*1K
1.2^K
A
*j-8
io,oco2
3,100^
400*
*-)
23,000^
*HK
^•8^
2700^
-------
TABLE 1
(continued)
SUfttKT OF OCNIAMINANrS LUlHim) IN GROIN) WATER
AND SURFACE WATER
Ground water
Inorganics
Aluminum
Barium
Berylliun
fjaHnriim
Calcium
Chronium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Tin
Vanadium
Zinc
Frequency
of
detection
37/39
24/39
9/39
14/39
24/39
33/39
18/39
28/39
39/39
21/39
39/39
38/39
8/39
6/39
25/39
1/39
24/39
3/39
22/39
39/39
Maximn
concentration
(ug/1)
52,240
551
3.2
10.2
38,210
197
86
89
285,000
114
90,510
4,626
16.8
146
26,230
2.4
237,000
26
239.5
910
Geometric3
mean
(ug/1)
940
178.5
0.3
4.9
6,149
16
8.5
12.3
3,222
19.5
4,218
69
3.9
34
3,122
2.4
10,759
24.6
11.2
36.7
Remedial Criteria*
GW2
(ug/1)
*
1000
*
10
it
50
*
ia»*
300*
50
*
»*
2
*
50*
50,000
*
5,000
-------
TABLE 1
(continued)
OP OWEAMDWHrS CETBCIH) IN GROIN)
AM) SURFACE WATER
Surface water from Camon Run Ranedial Criteria*
Frequency Maximum Geometric3
_ . °* concentration mnpn my niy
Inorganics detection (ug/1) (ug/1)
Aluminum
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Tin
Vanadium
Zinc
6/7
7/7
3/7
0/7
7/7
in
0/7
2/7
7/7
0/7
7/7
7/7
1/7
0/7
7/7
3/7
7/7
0/7
3/7
7/7
982
81
0.2
N)
38,280
3
ND
4
17,100
M)
6,094
173
0.4
H)
5,658
2.5
9,908
N)
4.2
21
152.9
48.2
0.2
to
20,863.6
3.5
to
3.5
515.5
to
4,688.2
61.6
0.4
M)
3,971.7
2.2
7,591.7
M)
4
8.8
+
1000
10
50*
50
2
X
50
«»•
,..0076*
Vf3
(Cr^ttTol; (CR+3) 33.0C03
j, f
1,300*^
JL
50
*f
50 *
*i-l*
510^
•<
913
-------
SIMttRY
TABUS 1
(continued)
OF CDNIAMDWJIS DETECTED IN OWN) WATER
ftO SSFffZ WATER
Swamp Water Table Randal
Inorganics
All minim
Barium
Beryllium
CadmiuDi
Calcium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Tin
Vanadium
Zinc
Frequency
of
detection
6/6
6/6
3/6
0/6
6/6
6/6
1/6
6/6
6/6
5/6
5/6
6/6
0/6
0/6
6/6
6/6
6/6
0/6
5/6
6/6
Maximum
concentration
(u*/l)
2,221
138
0.8
M)
16,060
11
9
15
129,000
11
14,840
865
NO
N)
5,305
5.5
23,390
M>
10
13,380
Geometric4
mean FW2
(ug/1) (ug/1)
551 .
72 1000
0.6
ro 10
3,272 ,
7 50
9
5
3,164
8 50
2,165
51
ND 2
NO
3,972 .
4.6 50
4,624
H>
7
10,026
.Criteria*
FWQC
(ug/1)
*K
..0076^
10
(CR+6)1703;(Cr*3)33,0003
o-J
1,300*3
50
50 ^
...14
510^
91^
aOnly the detected values of the contaminant were used in the calcula-
tion of the geometric mean. When the concentration was detected only
in one sample, the measured concentration was used to represent both
the maximm concentration and the geometric mean concentration.
^D - Not detected at the detection limit.
°B » Found in blank; use as estimated value.
J * Estimated value.
e a Office of Drinking Water, U5EPA, Drinking Water Regulations and
Health Advisories, April 1990 (Federal Drinking Water MCL's).
f = NJAC 7:10-16.7(a).
g = NJAC 7:9-6.6(b), Ground Water Quality Criteria.
h = MJAC 7:9-4.1 et seq., Surface Water Quality Standards.
i = 40 CFR Part 131, Federal Water Quality Criteria, June 15,1990.
j 3 Criteria revised to reflect current agency RFDs, as contained in
the Integrated Risk Information System (IRIS).
K - Criteria based on carcinogenicity (10 risk).
-------
TABLE 2
SUMMARY OP CONTAMINANTS Di'ilUU) ZN CREASE PIT,
SUBSURFACE SOIL, AND SEDZHDfT SAMPLES
Grtaa* pit
Prtqutncy Haxian GtOMtrie'
of concentration Man
Contaminant dtttction (ug/kg)
Volatilts:
Mtthyltm chloridt 0/15 ND* ND
Acttont 0/15 ND ND
Carbon diculfid* 0/15 M) ND
2-ButanoM 0/15 ND ND
Trlchloroethylene 0/15 ND ND
tenztM 0/15 ND ND
Tolutn* 0/15 ND ND
Chlorobcnxtn* 0/15 ND ND
Chlorocthant 0/15 ND ND
Total xylant* 0/15 ND ND
Acid, baM/twutrals:
l,3-DiehlorobtnMn« 1/15 130 130
l,4-Oichlorobtnz«M 0/15 ND ND
Di-n-butyl phthalatt 7/15 400 267
bis(2-EthylhMyl)
phthalat* 4/15 440JC 256
riuoranthvM 0/15 ND ND
B*nco(b)fluoranthtM 0/15 ND ND
Bmsoie acid • 1/15 1,OOOJ 1,000
Pt«ticidt§:
4,4'-OOT 0/15 ND ND
4, 4 '-0* 0/15 ND ND
4, 4 '-CO) 0/15 ND ND
(FD1/6)
-------
\
TABLE 2
(continued)
SUNfARY OF OQNZMfZMtfUS milLTUJ IN GREASE PIT,
SUBSURFACE SOIL, AND SEDZHEtfT SMffLES
Subsurface soil
Contaminant
Vole ilesi
Ite-nylene chloride
Acetone
Carbon disulfide
2-Butanone
Trlchloroethylene
Bensene
Toluene
Chlorobtnztnt
Chloroe thane
Total xylenes
Acid bftM/tomtralS!
1 , 3-Oichlorotenxtn*
, 4-DiciuoroMnztM
Di-ft-butyl phthalat*
bi§(2-Cthylh«xyl)
phthalaU
riuoranthem
B«nzo( b ) f luormntt)«M
Bensoic acid
Pesticides:
4,4'-DOT
4,4'-oce
4,4'-OCO
Frequency
of
detection
0/4
1/4
2/4
0/4
1/4
0/4
3/4
0/4
0/4
0/4
0/4
^r ~
0/4
0/4
3/4
0/4
0/4
0/4
0/4
0/4
0/4
Haxima
concentration
(ugAg)
* H
170Bd
26
(O
3J
ND
10
ND
ND
ND
-•
ND
ND
ND
480J
ND
ND
ND
ND
ND
ND
Geometric'
van
• (uo/kg)
ND
170
7
ND
3
ND
4
ND
ND
ND
ND
ND
ND
322
ND
ND
ND
ND
ND
ND
[roi/6)
-------
TABLE 2
(continued)
sumw or CONTMIXNANTS mm'm ZN GREASE FIT,
SUBSURFACE SOIL, AND SEDIKEWT SAMPLES
Contaminant
Volatile:
«»thyl«nt chloride
AC* tOM
Carbon disulfid*
2-Butanont
Trlchloroethylene
Benzene
Toluene
Chlorobtnztn*
Chloro«thaM
Total xyltms
Acid baa«/h«utralf:
1 , 3-DichlorobtnztM
1 , 4<-OiehlorobmMM
Di-n-butyl phthalau
bi«(2-Ethylhaxyl)
ptithalata
riuoranthtnt
Btnto ( b ) fluoranthtn*
Bcnzoie acid
FMticidu:
4, 4 '-DOT
4,4'-OC€
4,4'-CCO
Prtqvwncy
of
dttcction
Q/9
1/8
0/8
1/8
0/8
1/8
0/8
1/8
0/8
0/3
0/8
1/8
1/8
5/8
1/8
l/«
0/8
1/8
3/8
2/8
Cannon Run Mdiatnts
. Maxima
concentration
(ugAg)
(O
320B
to
888
ND
11
M>
28
(O
ND
ND
790
240J
1,600
1,500
1,100
(0
120J
180J
270J
GaoMtric*
man
(ug/kg)
ND
320
ND
88
ND
11
ND
28
ND
ND
ND
790
240
284
1,500
1,100
ND
120
13
52
(roi/6)
-------
TABLE 2
(continued)
SUMMARY OF CONTAMINANTS UtliLlii) ZN GREASE PIT,
SUBSURFACE SOIL, AND SEDIMENT SAMPLES
Contaminant
Vol» tiles:
Me^nylene chloride
Acetone
Carbon disulfide
2-Butanone
Trichloroechylene
Benzene
Toluene
Chlorobenzene
Chloroe thane
Total xylenes
Acid base/neutrals:
1 , 3-Dichlorobenzene
1 , 4-Di Chlorobenzene
Di-n-butyl phthalate
bis(2-Itnylhexyl)
~~~ phthalate
Pluoranthene
Benzo( b ) fluoranthene
Benzoic acid
Pesticides:
4,4'-DDT
• m 9 ••ODC
A A 9 «CDQ
Frequency
of
detection
1/4
0/4
0/4
R
0/4
1/4
4/4
1/4
1/4
1/4
0/4
0/4
1/4
V4
0/4
0/4
0/4
3/4
4/4
4/4
S*eH> sediamts
Haxiaui
concentration
(ug/kg)
10
ND
ND
R
ND
6
57
7
7J
7J
•
ND
ND
2,100
290J
ND
ND
ND
340
1,100
7,900
Geonetric*
Man
(ugAg)
10
ND
ND
R
ND
6
23
7
7
7
ND
ND
2,100
290J
ND
ND
ND
160
352
1,650
(FD1/6)
-------
TABLE 2
(continued)
SUMMARY or COWOMINANTS DETECTED ZN GREASE PIT,
SUBSURFACE SOIL, AND SEDIMENT SAMPLES
Grease pit
Frequency Maxioun Geenetric*
of Concentration HMD
HtUl detection . (ag/kg) (ag/kg)
AluBimai
Arsenic
Bariun
Beryllium
Calcivn
ChroniuB
Cobalt
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
PotassiuB
Silver
Sodixn
vanadit*
Zinc
16/16
1/16
9/16
16/16
0/16
16/16
16/16
3/16
16/16
14/16
16/16
0/16
0/16
16/16
8/16
16/16
16/16
16/16
5,558
7
13
0.7
ND
18
2
2
9,129
766
46
(!)
ND
1,969
2.7
479
18.2
20
2,047
7
8.0
0.5
W
. 11.8
2.0
2.0
4,760
227.3
13.7
. ND
ND
1,730
1.8
385.6
11.3
9.7
(roi/6)
-------
TABLE 2
(continued)
SIWARY OF CafOMnaNTS UtllUlD ZN GREASE PIT,
SUBSURFACE SOIL, MD SEDIMENT SAMPLES
Hetal
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Frequency
of
detection
4/4
0/4
0/4
4/4
4/4
4/4
4/4
3/4
4/4
3/4
4/4
4/4
0/4
4/4
4/4
2/4
4/4
4/4
4/4
Subsurface soil
«»«<•••
concentration
(•gAg)
6,400
ro
R«
0.9
113,400
29
a
10
20,122
6.8
4,513
99
MD
33
8,520
5.4
599
12.7
66
Geometric*
mean
(*3Ag)
5,339
ND
R
0.77
46,448
20.6
5.6
5.3
15,391
5.2
3,440
64.1
VD
22
7,489
2.5
375
8.5
62
(FD1/6)
-------
TABLE 2
(continued)
or carzMONMirs utin-iiD ZN GREASE PIT,
SUBSURFACE SOIL, MO SEDIMENT SAMPLES
Caiman Run Mdiatnts
natal
AluBinuB
Araanic
BariuR
Berylliui
Caleiw
ChroBiia
Cobalt
Copper
Iron
HagnaaiiB
Hanganeae
Mercury
Niekal
Potaaaiua
Silver
Sodiu*
vanadiuB
Zinc
Frequency
of
detection
R
0/8
7/8
8/8
R
5/8
8/8
5/8
8/8
4/8
8/8
0/8
0/8
8/8
5/8
R
7/8
R
KaxiKJB
concentration
R
M)
35
0.3
R
10
7
27
131,306
274
90
IB
M>
3,358
3
R
185
R
Geooetric*
•aan
(•9A9)
R
»
S.I
0.1
ft
4.3
2.3
3.4
2,356.3
85.9
5.1
MI
M)
1,284.2
2.4
R
5.4
R
(FD1/6)
-------
TABLE 2
(continued)
SUMMARY OF OGNIMUNMRS DETECTED ZN GREASE PIT,
SUBSURFACE SOIL, AND SEDIMENT SAMPLES
sediments
Metal
A1UBU..AJB
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Frequency
of
detection
4/4
0/4
4/4
4/4
4/4
4/4
0/4
4/4
4/4
4/4
4/4
3/4
0/4
4/4
0/4
4/4
4/4
4/4
Maximum
concentration
-------
TABLE 3
OONONIBATIONS Of OdNTAMDUHTS IN AH SAMPUS
Upwind/downwind sMplea
frequency HaxiauM Geometric
of concentration «eao
Chenical detection <•!/•) <•«/•)
Hethylene chlorid*
trans-l ,2-Dlchlaroethylene
1,1-OichloroethaM
1,1, 1-Tr ichloroathaM
Trichloroethylene
Benzene
Tetrachloroethylene
TollMIM
ChlorobonMM
BthylboMOM
^
1/4 3.3rtO"*J* 3.3»10"*
0/4 M^ MD
0/4 MD M>
1/4 l.SKW'j l.SalO"1
0/4 » M»
0/4 MD MD
3/4 6.5«10'SJ 4.3«10'§
0/4 MD ND
0/4 MD MD
2/4 l.felO~'j 3.3«10~4
Vent saaplea
Frequency
of
detection
1/11
1/11
2/11
4/11
2/11
2/11
11/11
3/11
1/11
6/11
NulM
concentration
<•«/•)
2.8>10~*J
5.9«10"SJ
5.U10"*J
8.telO~*J
4.2/10'Vl
4.9xlO~sJ
1.2K10'1
2.3B10'1
1.2xlO~'j
2.0JT10'1
Geocwtric
•can
(•I/-1
2.8«10~4
5.9nlO**
2.4«10"*
2.3«10~4
2.3nlO"4
4.2x10-'
4.2KMT*
2.9»10"'
1.2xlO~s
3.2«10''
'J BstiMted value.
kND ContMiinant was analyxed for but not detected in saaples at the detection Halt.
(Pni/24)
-------
TABLE 4
Health Effect Criteria for Chemicals of Conctrn
At tht Port Dix Site — Potential Carcinogens
EPA/CAG
Potency Factor*
Chemical (mi/kg/day)'1 Weight of Evidence6
Inhal
Oral Inhalation
Benseae 2.91-02 2.9E-02
bis( -Ethylhexyl) 1.4E-02 ~" B2
phthalate
1,4, -Dichlorobenzene
1,1-Dlchlorethane
1 , 2-Diehloroe thane
Tetrachloroe thane
1,1, 1-Tr iehloroethane
Trichloroechylene
Vinyl chloride
2.2E-02*
9.1E-02
9.1E-02
1E-02
t
1.1E-02
2.3
c
~
9.1E-02
cf
g.lE-09f
1.3E-02
2.9E-01
B2
C
B2
B2
D'
B2
A
B2
C
B2
B2
D/C'
B2
A
'Source of potency fact on EPA Integrated Risk Information Systea as of
June 7, 1989.
*EPA veiffht of evidence classification scheme
'— • Criterion has not been developed for this chemical and route of
exposure.
*HA • Mot applicable. Exposure via this route vas not quantitatively
evaluated.
*Source of potency factor for 1,4-dichlorobexene: Draft Toxicolofical
Profile for 1,4-Dichlorobensene (ATSOtVEPA, 1987).
*0ral carcinogenic potency factor vas used to asaess inhalation exposure.
'EPA has classified 1,1,1-trichloroethane as 0. not classifiable as s human
carcinogen, lovever, MJDEP classifies 1,1,1-trichloroethane as a class C
carcinogen for inhalation.
(FT DIX2/6)NT-GMO
-------
TABLE 5
"Btalth Effects Criteria for Chcaicals of Conetrn
At the Fort Oix Sitt — Noncarcinoftns
Cheaical
Organic*;
Benzene
bis(2-Ethylhexyl)
phthalace
2-Butanone
Chlorobenitne
1 ,4-Dichlorobenzene
1 , 1-01 chloroe thane
1,2-Dichloroe thane
1 , 2-Dichloroethylene(trans)
Ethylb«nrtn«
Tecrachloroechyl en*
Tolu«n«
' t
l,l,l-Trichloro«thaat
Trichloroethyltnt
Vinyl chloride
Inorianies:
Cadaiua
Chro«iua
MUfUCSt
Mtrcury
Nickel
Zinc
Oral
R£D
b
2.0E-02
3.0E-02
3.0E-02
1.1E-02
l.OE-01
b
2.0E-02
1E-01
l.OE-02
3.0E-01
9E-02
1.1E-02
b
5.0E-4
3.0E-03
1.0E*0
2.2E-01
3.0E-OA
2.0E-02
2.E-01
Source*
b'
XXIS
XRZS
BEA
BA
BEA
b
XKXS
ZXZS
ZXZS
PBZ
ZBZS
HIS
b
BA
IRIS*
IRIS
BEA
PBE
IRIS
BEA
Inhalation
WD Source*
b b
— ?
2.4E-02 . BA
5.0E-03 . BEA
—
l.OE-01 BEA
b b
^ ...
— —
1.9E-02 BA
2.9E-01 BA
..
1.3E-02 IRIS
b b
NA* NX
HA HA
HA HA
HA HA
HA HA
HA HA
-------
TABLE 5
(continued)
Health Effects Criteria For Chemicals of Conctrn
At tht Fort Dix Sitt — Noncarcinogens
'Source: IRIS as of 6/8/89
HA • Htalth Advisorits (EPA 1985)
PHE • Superfund Public Htalth Manual (EPA 1986)
HEA • Health Efftcts Assessments (EPA 1984)
*RfDs hav« not been calculated because of the potential nature of tht
carcinogenic response.
c—•Criterion have not been developed for this chemical and this route of
exposure.
*NA • Not applicable. Exposure via this route vas not quantitatively
evaluated.
*5.0E-03 is the value for chromium II
l.OE+0 is the value for chromium III
(FT OIX2/5)HT-CMO
-------
TABLE «
PORT Oil LANDFILL SUPERFUNO SITE
COST SIMNABY*
! Estimated Operation and
construction maintenance Total
Alternatives cost cost project cost
1.
2.
1A.
IB.
10.
4A.
4B.
No remedial action with monitoring
Landfill closure: wltn monitoring program
Ground water pumping and onsite treatment
with ground water Injection
Ground water pumping and off site
treatnent
Partial ground water pumping and onsite
treatment with ground wnter Injection
Ground water Interception and onslte
treatnent with ground wnter Injection
Ground water Interception and off si to
treatment
6.6 1.4 8.0
12.6 1.9 14.5
16.6 9.8 26.4
13.5 16.7 30.2
13.7 4.1 17.8
21.3 9.0 30.3
18.2 16.0 34.2
Implementation
time,
(years)
0.5
1.5
2.0
2.O
2.0
2.0
2.0
MOTE:
'costs are presented In nillions of dollars
bA 10-year landfill post-closure care period and 10-year gtound water withdrawal and treatnent
period were used to develop the total project cost.
(fort dlx/96)
-------
TABLE 7
SUWATION OF TOTAL ESTIMATED RISKS FOR THE
PRESENT SITE USE EXPOSURE PATHOYS
(Pristnt Site Uaa)
Exposuct
Pathway
Exposurt
Rout*
Total Estiaattd Risk
Host Prohibit worst cast
Air: Volatilti Inhalation
1 x 10*l°
2 x 10'*
Soils:
Surf act Kattr:
Swaap
Surf act watar:
Swiaaing
Total liaka:
All Pathways
Ingtstion
inhalation
Dtraal Absorption '
Ingtstion
Inhalation
Dtraal Abaorption-
aurfaca watar
Dtraal Abaorption-
aadiaanta
«
lagaation
Inhalation
.Dacaal Abaorption
1 x 10' l°
0 (3xW10)'
Inconplttt ,,
0 (8 x 10"11}
0 (4 x 10'1')
Incoaplttt
7 x 10'f
3 x lO'18
7 x 10'11
7 x lO0
6 x 10'11
1 « iO-11
8 x 10*'
2 x 10' '
2 x W'
8x 10
2 x 10'1
Inccnplete
6 x 10'1
4 x NT1
2 x 10'*
7 x 10'*
7 x 10'10
1 x W'
1 x 10''
*Tht tost probabla cast risks would bt zaro aa tht pathway was assuatd to
bt incoaplttt. Avtragt worst cast risks art prtstntad in tht partntheses.
(DPS02/25)NY
-------
TABLE 8
SUMMATION 0? TOTAL ESTIMATED CANCER RISKS
FOR THE POTENTIAL FUTURE SITE USE EXPOSURE PATHWAYS
(Future Site Use)
Total Estimated Risk
.1
Exposure ~~
Scenario Most Probable Worst Case
1. Rancocas CreeX 4 x 10* 5 x 10*'
2. Vincentovn Aquifer 5 x 10T 8 x 10**
3. Cohansey Aquifer 6 x 10* 2 x io4
-------
TABLE 9
CHARACTERISTICS OP THE REMEDIAL ACTION ALTERNATIVES
Alternative
nuaber
1
2
3A
3B
3D
4A
4B
Landfill
cap
No
Tea
Tea
Tea
Tea
Tea
Tea
Honitoring
prograa
Tea
Tea
Tea
Tea
Tea
Tea
Tea
Pluae
abateaent
No
Tea
Interceptor
veils
Interceptor
veils
Interceptor
veils (partial)
Interceptor trench
Interceptor trench
Ons ite treat Bent
and disposal
No
No
Tes
No
Tes
Tes
No
OCCsite treataept
and disposal
No
No
No
Tes
No
No
Tes
(fort dix/62)
-------
TAHIE 10
RFT rax SANITARY LAWFUL
FHHWL
SI/OB
o • 11 ^H i n»i t-?pt3ci£ic
SAFE OONOK; WATER ACT (SDUA)
o National Primary Drinking Water Standards,
40 OR Part 141
CLEAN WATER ACT (CWA)
o Water Quality Criteria, 40 CFR Part 131
Location-Specific
Executive Order 11990 "Protection of Wetlands"
Executive Order 11988 "Floodplain Management"
Endangered Species Act, 16 USC 1531
dean Water Act, Section 404, 40 OR 230
Action-Specific
Resource Conservation and Recovery Act, 40 CFR
Part 264
CLEAN WATER ACT (CHA)
o Disposal of Dredged and Fill Material,
40 OR 230
CLEAN AIR ACT (CM), 42 U.S.C. 7401 et seq.
OTHERS
o Occupational Safety and Health Act (OSHA),
29 U.S.C. 651-678
SDWA MCLs, NJAC 7:10-1 et seg.
Ground Water Quality Standards, NJAC 7:9-6.6 (b)
Surface Water Quality Criteria, NJAC 7:9-4.1
et seq.
Location-Specific
Flood Hazard Area Regulations, NJAC 7:13-1 et sea,.
Fresh Water Wetlands Protection Act Rules, NJAC
7:7A-1.1 et seg.
(fort dix/109)
CLOSURE AND POST-CLOSURE
o Hazardous Waste Regulations, NJAC 7:26-1
et seq.
o Non-Hazardous Waste Regulations, NJAC 7:26-1
et seq.
o Soil Erosion and Sediment Control Act Regula-
tions, NJAC 2:90-1.1 et ^.
AIR POLLUTION CONTROLS
o Air Pollution Control, NJAC 7:27-1 et seq.
HAZARDOUS WASTE FACILITIES
o Requirements for Ground Water Monitoring,
NJAC 7:26-9 et seq.
EMERGENCY RESPCNSE ACTIONS
o Notice of Release of Hazardous Substances to
Atmosphere and Water Pollution Control,
NJSA 26:2C-19
OTHER
o Noise Control Act NJSA 13:1G-1 et seg.
o Noise Pollution, NJAC 7:29-1 et seq.
-------
TABLE 11
ESTIMATED CAPITAL COSTS OF ALTERNATIVES
Component Alternative Alternative Alternative Alternative Alternatve Alternative Alternatl
1 2 3A 3B 3D 4A ' 4B
Landfill cloaure
Additional Monitoring wella
Extraction wella and piping
Injection wella and piping
Downgradlent trench
Ground water treatment
Storage and tranafer to
offalte treatment
Subtotal (rounded)
Engineering and contingencies
(15 percent)
Total
$4.900.000
25,000
$9.300.000
25.000
$9.300.000
25,000
200.000
220.000
2.600.000
$9.300.000 $9.300.000
25.000 25.000
180.000 80,000
50.000
690.000
$9.300.000 $9.300,0)
25.000 25,0.
220.000
3.700.000
2.600.000
460.000
3.700,01
460.0(
4.900.000 9,300.000 12.300,000 10.000.000 10.100,000 15.800.000 13,500.01
1.700.000 3.300.000 4.300.000 3.500.000 3.600.000 5.500.000 4.700.0'
$6.600.000 $12.600.000 $16.600,000 $13.500.000 $13.700.000 $21.300.000 $18.200,01
(DECI80/39)
-------
TABLE 12
ESTIMATED ANNUAL 04M COSTS OF ALTERNATIVES
Component Alternative
1
Poat-cloaure care with cap
Poet -closure cere without cap 31,500
Ground and aurface water 115.000
•onlcortng
Extraction and/or Injection wella -
Downgradlent trench -
Ground water treatment -
Storage and tranafer to offalte -
treatment
Offalte treatment
Total $146.500
Alternative ' Alternative Alternative Alternative
2 3A IB 30
$84,900 $84,900 $84.900 $84.900
-
115,000* II5.0001 II5.0001 115.000*
137.000 120.000 41,800
1.265.0002 - 369.400
20,000
- - 2.143.000
$199.900 $1.601,900 $2.482,900 $611,100
Alternative
4A
. $84,900
-
115.000*
17.000
15.500
I.265.0002
-
-
$1.497,400
Alternatlvt
4B
$84.901
115. OOO1
I5.i0d
20.00H
2,143.000
$2.378.400
$134,000 a year for the flrat two yeara.
Ftrat-year coat; annual coat In yeara 2-5 about $72.000 leas and annual coat In yeara 6-10 rangea fro* about $175,000 less
(year b) to about $569.000 leaa (year 10) mainly because of reduced chealcal and carbon regeneration coata.
(DKCIflO/39)
-------
ATTACHMENT 3 RESPONSIVENESS SUMMARY
-------
I. Introduction
In accordance vith EPA's Community Relations policy and guidance, the Army
held a public comment period from April 25, 1990 to Hay 25, 1990, to
solicit comments on remedial alternatives for the Fort Dix Landfill site.
As part of the selection process, the Any published a PRAP describing the
Army's and EPA's preferred alternative and issued a public notice
announcing a public meeting.
The Army, in conjunction vith the EPA and NJDEP, held the public meeting to
present the PRAP on Hay 7, 1990 at the Nev Hanover Tovnship Municipal
Building in Cooks town. Approximately 18 people attended the meeting,
including representatives of Federal, State, and local public agencies, and
from local newspapers. No members of the general public attended the
public meeting. Copies of the PRAP vere distributed at the meeting and
vere available in three information repositories.
The Army presented a brief overview of the Fort Dix Landfill site, the
decision-making process, the findings of the RI/FS and the preferred
alternative. Comments from the meeting attendees vere then received by the
Army. No comments vere received by the Army, other than those presented at
the public meeting, during the public comment period.
h
The purpose of the Responsiveness Summary is to document the Army's
responses to comments and questions raised during the public comment
period.
II. Response to Comments
1. When the results of the risk assessment vere being presented,
clarification as to vhat the computation 10 Mans vas requested.
Response: The value of 10 represents one additional cancer
risk in ten billion people exposed to certain environmental conditions.
-------
2. Definition of what a filter fabric is as part of the landfill cap
vas requested.
Response; Filter fabric is a permeable uterial often used
betveen layers of material of different grain sizes to prevent mixing of
finer material vith the layer of coarser uterial.
The effectiveness of the coarser layer used as a vater drainage layer in
the landfill cap may be reduced by the clogging of pores by fiaer material
if a filter fabric or a filter layer is not present. Filter fabrics can
also help :o minimize internal erosion and settlement as a result of fines
movement within the cap.
3. A request for clarification vas made concerning Table 5-1 of the
presentation given at the public meeting, vhich states that plume Abatement
is part of alternative 2.
Response: Alternative 2 does not include abatement of the ground
water plume directly. However, ground water monitoring and evaluation of
the remedial action at least every five years are included in alternative 2
which could trigger an active ground water treatment approach if deemed
necessary.
•
4. A review of the remaining steps in the process to implementing the
proposed remedial action was requested.
Responset After the public comment period is over a response to
all public concerns will be prepared and incorporated into a document
called a Record of Decision (ROD). The ROD will outline the alternative
that wax chosen, and the basis upon which it was selected'over the other
alternatives. The Deputy Assistant Secretary of the Army and the EPA
Regional Administrator will sign the ROD. Once the ROD has been finalized,
the Army will initiate the design and construction of the selected remedial
action.
-------
5. Has additional technical information btcn made available to the
public other than what was presented at the public meeting?
Response: Other technical information concerning the Fort Dix
Landfill is available for public reviev at the following three
repositories.
o Fort Oix Environmental Resources Branch
Building SS12
Texas Avenue
Fort Dix, Nev Jersey
o Burlington County Library
Brovns Mills Branch
348 Lakehurst Road
Brovns Hills, Nev Jersey
o Nev Jersey Department of Environmental Protection
Division of Hazardous Site Mitigation
Bureau of Community Relations
401 East State Street
Trenton, Nev Jersey
(fortjlix/102)
-------
ATTACHMENT 4 ~NJDEP LETTER OF CONCURRENCE WITH THE RECORD OF DECISION
-------
cu i OF ENVIRONMENTAL PROTECTCN
.JCDfTH X YASJCIN, COMMISSIONS*
CN402
TRENTON. NJ. 08625-0402
(609) 292-2185
Fix: .609) 984-3962
2 S Jt'N 1990
Mr. Joseph Haug
USATC «nd Fore Olz
Fore Olz Environmental Branch
ATZD-EB
Fore Dlx, NJ 08640-5500
Dear Mr. Baug:
Re: Draft Record of Decision
Fore Dix KPL Landfill
Pemberton Township* Burlington County, Hew Jersey
This Is to formally notify you Chat New Jersey Department of Environmental
Protection has reviewed the enclosed Draft Record of Decision for Che above
referenced site and concurs with the recommended remedy providing the
enclosed comments are Incorporated In the final Record of Decision. This
remedy will consist of the following components: .
Landfill Closure
Perimeter Fencing
Deed Restrictions
• - Storm Water *nd Erosion Control
- Air, Surface Water and Ground Water Monitoring
» • •
New Jersey fully appreciates the importance of the Record of Decision in the
cleanup process and will continue to take all reasonable steps to ensure
that the State's commitments in this area are mat.
/ 'Judith A. Taikl/
£/ Commissioner*^
Enclosure
c: With Enclosure:
VftVDm^l^mBH^m^Bm^Hmmms^H
All Alavi, USATHAMT
Without Enclosure:
Constantlne Sidamon-Eristoff, Regional Administrator/USEPA
Ntw Jtnif it M £fMo/ Opfonuiutf
------- |