EPA/ROD/R02-95/249
August 1995
EPA Superfund
Record of Decision:
JIS Landfill
South Brunswick Township, NJ
8/15/95
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DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
AUG I 5 1995
SUBJECT: Record of Decision
JIS Landfill Site
FROM: Kathleen C. Callahan, Director (2ERRD) n-
Emergency and Remedial Response Division
TO: Jeanne M. Fox (2RA)
Regional Administrator
Attached for your approval is the Record of Decision (ROD) for
the JIS Landfill Site, located in South Brunswick Township,
Middlesex County, New Jersey. The selected remedial action
addresses the first and final remediation of contaminated
ground water.
The selected remedy calls for extraction and on-site treatment
of contaminated ground water, installation of a modified New
Jersey Department of Environmental Protection (NJDEP) hazardous
waste cap, and provision of alternative water supply to
residents with contaminated drinking water wells. The total
estimated present-worth cost of the selected remedy is $14.3
million. The remedy is the same as the preferred alternatives
presented in the Proposed Plan.
The remedial investigation and feasibility study reports,
prepared by B&V Waste Technologies, Inc. for the NJDEP, and the
Proposed Plan were released to the public for comment on
November 28, 1994. A public comment period on these documents
had been scheduled from November 28, 1994 through December 28,
1994. However, the public comment period was extended to
February 6, 1995, upon request from the public. In addition, a
public meeting to discuss these documents and the preferred
remedy was conducted by the NJDEP on December 7, 1994. With
the exception of comments from the potentially responsible
parties, comments received during the public comment period
generally supported the preferred remedial alternatives, and
are addressed in the attached Responsiveness Summary.
The ROD has been reviewed by the NJDEP, and the appropriate
program offices within Region II. Their input and comments are
reflected in this document. The NJDEP has concurred with the
selected remedy for the JIS Landfill Site, as indicated in the
attached letter.
If you have questions or comments on this document, I would be
happy to discuss them with you at your convenience.
Attachments
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DATE:
SUBJECT:
PROM:
TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
AUG I 5 1995
Record of Decision
JIS Landfill Site
Kathleen C. Callahan, Director (2ERRD)
Emergency and Remedial Response Division
Jeanne M. Fox (2RA)
Regional Administrator
Attached for your approval is the Record of Decision (ROD) for
the JIS Landfill Site, located in South Brunswick Township,
Middlesex County, New Jersey. The selected remedial action
addresses the first and final remediation of contaminated
ground water.
The selected remedy calls for extraction and on-site treatment
of contaminated ground water, installation of a modified New
Jersey Department of Environmental Protection (NJDEP) hazardous
waste cap, and provision of alternative water supply to
residents with contaminated drinking water wells. The total
estimated present-worth cost of the selected remedy is $14.3
million. The remedy is the same as the preferred alternatives
presented in the Proposed Plan.
The remedial investigation and feasibility study reports,
prepared by B&V Waste Technologies, Inc. for the NJDEP, and the
Proposed Plan were released to the public for comment on
November 28, 1994. A public comment period on these documents
had been scheduled from November 28, 1994 through December 28,
1994. However, the public comment period was extended to
February 6, 1995, upon request from the public. In addition, a
public meeting to discuss these documents and the preferred
remedy was conducted by the NJDEP on December 7, 1994. With
the exception of comments from the potentially responsible
parties, comments received during the public comment period
generally supported the preferred remedial alternatives, and
are addressed in the attached Responsiveness Summary.
The ROD has been reviewed by the NJDEP, and the appropriate
program offices within Region II. Their input and comments are
reflected in this document. The NJDEP has concurred with the
selected remedy for the JIS Landfill Site, as indicated in the
attached letter.
If you have questions or comments on this document, I would be
happy to discuss them with you at your convenience.
Attachments
BORSELUNO
FINN/ROONEY
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DECLARATION STATEMENT
RECORD OF DECISION
JIS Landfill
SITE NAME AMD LOCATION
JIS Landfill
South Brunswick Township, Middlesex County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the JIS Landfill site, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision document explains the
factual and legal basis for selecting the remedy for the site.
The New Jersey Department of Environmental Protection concurs
with the selected remedy. The information supporting this
remedial action decision is contained in the administrative
record for the site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
JIS site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The response action described in this document represents the
first and only planned remedial phase or operable unit for the
JIS Landfill site. The selected remedy addresses the remediation
of contaminated ground water through capping of the landfill and
active restoration of the aquifer.
The major components of the selected remedy include the
following:
provision of an alternative water supply for residents
with contaminated drinking water wells;
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upgrading of the existing landfill cap to include:
- 24 inches vegetated topsoil;
- 12 inches soil drainage layer with a minimim 1 x 10'2
centimeters per second (cm/sec) permeability;
- 30-mil textured synthetic, material layer; and
- 12 inches clay with a maximum 1 x 10'7 cm/sec
permeability;
• extraction of contaminated ground water from the
primary plume underlying the site;
treatment of the contaminated ground water in a
facility to be constructed on the site;
• disposal of the treated ground water on the site by a
recharge trench; and
implementation of a ground-water monitoring program to
monitor the primary and secondary plumes, and to ensure
the effectiveness and protectiveness of the remedy.
NJDEP will place well-use restrictions on well permits to prevent
the installation of new wells in the contaminated portion of the
Old Bridge Aquifer. Appropriate deed restrictions will be
required for the landfill.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The selected remedy
utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent
practicable, and it satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, mobility or
volume as their principal element.
Because the selected remedy will result in hazardous substances
remaining on the site above health-based levels, a five-year
review pursuant to Section 121 (c) of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended, is required. The purpose of the reviews is to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Jeanne M. Fo ' f Dat
Regional
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DECISION SUMMARY
RECORD OF DECISION
JIS Landfill
South Brunswick Township, Middlesex County, Mew Jersey
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES . 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF RESPONSE ACTION 4
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 6
DESCRIPTION OF REMEDIAL ALTERNATIVES . 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
SELECTED REMEDY 24
STATUTORY DETERMINATIONS 26
DOCUMENTATION OF SIGNIFICANT CHANGES 29
APPENDICES
APPENDIX I. FIGURES
APPENDIX II. TABLES
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SITE NAME. LOCATION AND DESCRIPTION
The Jones Industrial Services (JIS) Landfill site is located on
Cranbury South River Road (Route 535) in South Brunswick
Township, Middlesex County, New Jersey (see Figure 1). The site
is bordered on the west by the New Jersey Turnpike and a 36-inch
diameter gas transmission pipeline located between the Turnpike
and the landfill. The gas pipeline is owned by the Colonial
Pipeline Company. The north side of the site borders an
agricultural field while the south side adjoins a horticultural
nursery. Residential areas of Monroe Township and the Borough of
Jamesburg are located east of the site.
The site is designated as Block 17.010, Lots 9.05 and 9.06 on the
South Brunswick Tax Map. The site covers approximately 24 acres
and includes a 7.8-acre landfill adjacent to the New Jersey
Turnpike, an inactive borrow pit, and a solid waste transfer
station. Current operations at the site involve the solid waste
transfer station.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The site property was originally a farm. In 1950, Grandview
Construction Corporation bought the property and began soil
excavation activities at the site. By 1951, the site was being
used as a borrow pit for the construction of the New Jersey
Turnpike. Material excavated from the site was used as fill
material for the Turnpike. In 1955, Jones Road Material Company
bought the property, and began landfilling operations on part of
the property. The JIS Industrial Services Company (JISCO) still
owns, and formerly operated, the JIS Landfill. A related
company, the JIS Industrial Services Corporation (JIS Corp.), was
involved in the transportation and disposal of wastes, including
hazardous substances, at the JIS Landfill. Mr. Donald Jones is
the principal owner and officer of JISCO and JIS Corp. From the
1960s through the early 1970s, the landfill accepted a large
variety of chemical, municipal, and industrial wastes. Based on
available evidence, which includes letters, invoices, and
hazardous waste reports, the landfill accepted hazardous
substances, including acetone, benzene, ethylene dichloride,
toluene, xylene, trichloroethene, and methylene chloride. All of
these substances have been detected in the ground water.
In 1970, the New Jersey Department of Environmental Protection
(NJDEP) approved the operation of the landfill to accept
industrial, agricultural, and institutional wastes, tree stumps,
dead animals, junk automobiles, chemicals, and waste oils.
Approximately 50,000 to 65,000 cubic yards of waste were accepted
annually at the landfill. The amount of hazardous waste in the
landfill is difficult to precisely determine because most
documents do not identify the quantities. However, one document
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indicates that, during 1974, one particular company disposed of
as much as 100,000 gallons of waste containing acetone, ethylene
dichloride, toluene, and phenol at the site. Another document
indicates that, during 1977, 990 gallons of waste containing
acetone, benzene, chloroform, methylene chloride, ethanol,
hexane, toluene, and xylene were disposed of at the site. These
chemicals have been detected in the ground water.
In July 1975, in response to complaints regarding contamination
of drinking water, the U.S. Environmental Protection Agency (EPA)
sampled the drinking water well of a residence located adjacent
to the site. An analysis of the sample revealed high levels of
volatile organic compounds (VOCs), including trichloroethene,
benzene, toluene, xylene, chloroform, trichloroethane, and
dichloroethene. In addition, EPA sampled four on-site monitoring
wells and four off-site potable wells. The additional sampling
revealed VOC contamination in those wells. NJDEP concluded that
the landfill was the source of the ground-water contamination
affecting the wells because the landfill accepted industrial
waste containing chemicals similar to the contaminants detected.
In December 1975, NJDEP ordered Mr. Jones, JISCO, and JIS Corp.
(hereinafter referred to collectively as JIS) to cease all
landfilling operations at the JIS Landfill. In January 1976,
NJDEP brought suit in the Superior Court of New Jersey, seeking
the closure of the landfill. In August 1976, the Court
prohibited the disposal of additional chemical or hazardous
substances at the landfill, but allowed JIS to accept other
specified wastes.
In January 1980, EPA took another round of ground-water samples
from the monitoring wells at the site and from nearby private
wells. These samples continued to show significant ground-water
contamination. The site was placed on the National Priorities
List (NPL) on September 1, 1983. In June 1984, NJDEP revoked the
landfill registration for the JIS Landfill, and in December 1985,
the Appellate Division of the Superior Court of New Jersey issued
an order for closure of the landfill.
From 1980 to 1985, JIS installed a solid waste cap over the
landfill. To date, NJDEP has not approved the closure of the JIS
Landfill because the cap did not comply with the closure
requirements specified in the order.
From 1984 to 1988, the Monroe Township Health Department
continued to sample private water supply wells for the township
residents. Many of the residents in the vicinity of Bordentown
Turnpike, downgradient from the landfill,, had contaminated
drinking water. Under a removal action, EPA provided these
residents with bottled water from June 6, 1989 until they were
permanently connected to the municipal water system in February
1992.
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On May 20, 1986, NJDEP directed JIS to fund a remedial
investigation and feasibility study (RI/FS) at the site. In
October 1986, NJDEP selected B&V Waste Science and Technology
Corp. to perform the RI/FS.
Subsequently, NJDEP identified 12 companies which generated and
disposed of hazardous substances and/or hazardous wastes at the
JIS Landfill. On March 27, 1987, NJDEP issued a Supplemental
Directive to these companies to fund the RI/FS. In June 1987,
these companies signed an Administrative Consent Order to fund
the RI/FS. In a Second Supplemental Directive, dated December
14, 1988, NJDEP identified, and directed, eight additional
companies to contribute towards the cost of the RI/FS. In
Directive II, dated December 18, 1989, NJDEP identified nine
additional companies. NJDEP directed these 9 companies and 23
previously identified parties to contribute towards the cost of
the RI/FS. Subsequently, NJDEP identified four additional
companies. On September 17, 1991, NJDEP issued Directive III to
all 36 respondents to contribute towards the cost of the RI/FS.
Remedial Investigation and Feasibility Study
The remedial investigation (RI) was initiated in October 1986 by
B&V Waste Science and Technology Corp. The purpose of the RI was
to characterize the nature and extent of contamination, evaluate
the integrity of the landfill cover and sideslope, and
characterize potential risks to human health and the environment.
Based on the information obtained during the RI, a feasibility
study (FS) was undertaken to identify and screen remedial
alternatives to address the contamination at the site. The RI/FS
and Baseline Risk Assessment reports were completed in August
1993.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and the Proposed Plan for the site were released to the
public for comment on November 28, 1994. These documents were
made available to the public in the Administrative Record at the
South Brunswick Municipal Building, South Brunswick Public
Library, and information repositories at NJDEP and EPA
Region II in New York. The notice of availability for the above-
referenced documents was published in The Home News on
November 26, 1994. The public comment period relative to these
documents was scheduled from November 28, 1994 to December 28,
1994, and subsequently extended to February 6, 1995 upon request
from the public.
On December 7, 1994, NJDEP held a public meeting at the South
Brunswick Senior Citizens Center to inform local officials and
interested citizens about the Superfund process, to discuss
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proposed remedial activities at the .site, and to respond to
questions from area residents and other interested parties.
Responses to the comments received at the public meeting, as well
as written comments received during the public comment period,
are included in the Responsiveness Summary.
SCOPE AND ROLE OF RESPONSE ACTION
This response action addresses the remediation of contaminated
ground water at the JIS Landfill site. It includes remedial
alternatives to address source control and contaminated ground
water, and focuses on the protection of human health and the
environment. No other operable units are planned for the future.
SUMMARY OF SITE CHARACTERISTICS
Site Geology and Hydrology
The site is situated in the Atlantic Coastal Plain. Two major
aquifers underlie the site: the Farrington Sand and the Old
Bridge Sand. Both aquifers are major sources of potable water in
Middlesex County. Ground water flows in a southeasterly
direction. Residents in the immediate vicinity of the site are
currently connected to a municipal water system. Based on
information provided by Monroe Township and the New Jersey
American Water Company, NJDEP estimates that as many as 115
residents located near Manalapan Brook, about 2 miles southeast
(downgradient) of the site, may not receive municipal water and
are presumed to use domestic wells as a source of drinking water.
The predominant land use in the vicinity of the site is
agricultural/farmland, including crop, pasture and orchard/
horticulture, and residential. Areas to the west of the site,
however, are mostly industrial, with much of the industry located
in the South Brunswick Industrial Park.
Mature and Extent of Contamination
Ground Water
Ground-water contamination appears to be limited to the Old
Bridge Aquifer. The predominant contaminants detected above
Federal and State Safe Drinking Water Act Maximum Contaminant
Levels (MCLs), and the respective range of concentrations in the
primary and secondary plumes, are shown in Table 1.
The ground-water contaminants appear in two distinct zones of
contamination, i.e., a primary plume and a secondary plume (see
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Figures 2 and 3). The primary plume extends approximately 2,000
feet downgradient from the landfill. The highest concentration
of total VOCs detected in the primary plume was 30,558 parts per
billion (ppb). The secondary plume is located approximately
5,000 feet downgradient from the landfill, and extends
approximately 8,500 feet downgradient from the landfill towards
Manalapan Brook. The highest concentration of total VOCs
detected in the secondary plume was 894 ppb. The contaminants in
the secondary plume are similar to the contaminants in the
primary plume, but at lower concentrations.
The contaminant levels in the secondary plume appear to change
sporadically. Levels of trichloroethene (TCE) range from 6.9 ppb
to 78 ppb within a very short distance. The sporadic nature of
the contamination may be caused by the variable water usage for
irrigation at a horticultural nursery located 1,000 feet
downgradient of the site. The nature and distribution of
contamination indicates that the variable nursery water usage may
cause the levels of TCE at the nursery itself to be significantly
lower than samples taken from side-gradient locations.
Sediments and Surface Water
On May 20, 1993, NJDEP collected sediment and surface water
samples at three locations along Manalapan Brook and Manalapan
Lake (located two miles downgradient from the landfill). The
samples were analyzed for VOCs. No contaminants were detected.
Soils
Contaminants found in the surface and subsurface soils outside of
the landfill include traces of arsenic, chromium, lead, 1,1,1-
trichloroethane, phenanthrene, pyrene, Aroclor 1260 (a
polychlorinated biphenyl or PCB compound), 4,4'-DDT, and 4,4'-
DDE. The levels of predominant soil contaminants are summarized
in Table 2.
Landfill Cap
JIS closed the landfill under a court order, which included
closure requirements. The order required JIS to install a solid
waste cover system consisting of a minimum of 18 inches of
continuous low permeability clay with a maximum in-place
permeability of 1 x 10'7 centimeters per second (cm/sec) , overlaid
by a minimum of 6 inches of vegetative soil cover.
The results of a landfill cap investigation indicate that the
current landfill cover clay layer ranges in thickness from 9.0
inches to 19.9 inches, with an average clay thickness of 14.85
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inches. The permeability of the clay layer ranges from 1.5 x 10'5
to 5.56 x 10-* cm/sec, with an average permeability estimated to
be 1 x lO* cm/sec. Furthermore, an examination of the cap
revealed cracking and voids which give rise to conduits,
therefore allowing a higher infiltration than would occur
compared to a thoroughly mixed and well compacted homogeneous
clay cap.
A vegetative top layer was required to promote drainage and
minimize erosion or abrasion of the cap. The vegetative soil
thickness of the current JIS Landfill cover varies from 3.6
inches to 20.9 inches with an average thickness of 9.0 inches.
However, many areas on the top of the landfill are not supporting
vegetative growth. This is most likely due to the poor organic
content of the soil. Therefore, the existing cap does not meet
the 1977 NJDEP capping requirements.
During the cap evaluation, the western slope of the landfill,
adjacent to the New Jersey Turnpike, was assessed to determine
slope stability under current conditions, utilizing site-specific
soil properties. The slope was estimated to be marginally
stable.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a Baseline Risk Assessment was
conducted to estimate the risks associated with current and
future site conditions. The Baseline Risk Assessment estimates
the human health and environmental risks which could result from
the contamination at the site if no remedial action were taken.
Human Health Risk Assessment
A four-step process is used for assessing site-related human
health risks for a reasonable maximum exposure scenario. Hazard
Identification—identifies the contaminants of concern at the
site based on several factors such as toxicity, frequency of
occurrence, and concentration. Exposure Assessment—estimates
the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated ground water) by which humans are
potentially exposed. Toxicity Assessment—determines the types
of adverse health effects associated with chemical exposures, and
the relationship between magnitude of exposure (dose) and
severity of adverse effects (response). Risk Characterization—
summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative (e.g., one-in-one-million
excess cancer risk) assessment of site-related risks.
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The Baseline Risk Assessment began with selecting contaminants of
concern that are representative of site risks. Chemicals of
concern were identified for soil and ground water beneath the
site. The contaminants of concern for soil (excluding the
landfill) include 1,1,1-trichloroethane, phenanthrene, pyrene,
Aroclor 1260, 4,4'-DDT, and 4,4'-DDE. The contaminants of
concern for ground water include methylene chloride, benzene,
tetrachloroethene, dichlorobenzenes, arsenic, lead, and copper.
The Baseline Risk Assessment evaluated the health effects which
could result from exposure to contamination at the site, under
current and future land-use scenarios. The site is a commercial
property and there are no residents on site. Therefore, under
current land use, on-site workers and off-site residents
represent the likely populations to be exposed to site-related
contaminants. The likelihood of future on-site residential land
use is unlikely because JIS still owns and operates part of the
site. Therefore, future land use was considered to be the same
as current land use.
Under the current land-use scenario, the exposure pathways of
concern include: incidental ingestion of, and dermal contact
with, chemicals in the on-site soils outside of the landfill
itself, for on-site workers; ingestion, inhalation and dermal
contact with ground water for off-site residents using domestic
wells in the Old Bridge Aquifer. On-site worker exposure to
ground water was not evaluated because there are no domestic
wells on site. Off-site residential exposure to on-site soil was
not evaluated because access to the site is restricted by a
fence. Exposure to contaminants in the landfill itself was not
evaluated because the ingestion, inhalation, and dermal contact
pathways are virtually eliminated by the existing landfill cap.
Since both current and future land use are the same, the exposure
pathways of concern for future land use are the same as those for
current land use. Therefore, for simplicity purposes, risk will
be discussed with respect to on-site workers, off-site residents,
and off-site workers.
For carcinogens, risk is represented in terms of an individual's
likelihood of developing cancer as a result of exposure to a
carcinogenic chemical present in the exposure media. For
example, a cancer risk level of 1 x 10"3 indicates that an
individual has a one-in-one thousand chance of developing cancer
during his or her lifetime. Such a risk may also be interpreted
as representing one additional case of cancer in an exposed
population of one thousand people. EPA's acceptable cancer risk
range is 1 x 10"4 to 1 x 10"6, or a one-in-ten thousand to one-in-
one million increased chance of developing cancer as a result of
a site-related exposure to a carcinogen over a 70-year lifetime.
Generally, if the lifetime excess cancer risk exceeds 1 x 10"*,
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the contamination is of sufficient concern to warrant a remedial
action. If the excess cancer risk falls between 1 x 10"6 and
1 x 10"1, the need for a remedial action is evaluated on a site-
specific basis. Finally, where the calculated lifetime excess
cancer risk is below 1 x 10"6, no remedial action is generally
required.
To assess the overall potential for non-carcinogenic effects
posed by more than one contaminant, EPA developed the Hazard
Index (HI). This index measures the assumed simultaneous
exposures to several chemicals, which could result in an adverse
health effect. When the HI exceeds 1, there may be concern for
potential non-carcinogenic health effects.
The results of the Baseline Risk Assessment indicate that site
soils do not pose a risk to human health. However, contaminated
ground water was found to pose a risk to off-site residents in
both the current and future land-use scenarios. The carcinogenic
risk to an off-site resident ranged from 1 x 10"6 to 4 x 10"*, for
each individual downgradient ground-water well. Carcinogenic
risk for an off-site resident would have a total risk of
3 x 10"3, using data from all monitoring wells. The risk was
attributable to ingestion and inhalation of chemicals in the
ground water.
Non-carcinogenic health effects are not likely for on-site
workers. The calculated HI for this scenario did not exceed 1.
However, non-carcinogenic health effects for an off-site resident
were found to be likely. The HI was calculated to be 10, using
data from all monitoring wells. The exposure pathways with the
greatest potential risk (carcinogenic and non-carcinogenic) for
an off-site resident are ingestion of chemicals in the ground
water and dermal contact uses of ground water (i.e., bathing).
Since there are no future-use restrictions which prohibit the use
of the Old Bridge Aquifer as a source of potable water supply,
the risk assessment assumes that future off-site residents might
use this aquifer as an untreated source of potable water.
Ecological Risk Assessment
The objective of the Ecological Risk Assessment is to evaluate
the actual or potential impacts to ecological receptors (i.e.,
flora and fauna) due to exposure to chemicals/contaminants or
contaminated media identified at the JIS Landfill site.
The site itself includes small areas of old field habitat and
upland hedgerow/shrubland habitat which do not support large
populations of any species. Most of the site exists as disturbed
grassy areas.
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The land areas surrounding the site consist primarily of
agriculture and small lowland oak forests. The nearest surface
water body is Manalapan Brook in Jamesburg, approximately two
miles east of the site. The Manalapan Brook is classified as a
freshwater non-trout stream (FW2-NT). While a variety of
endangered or threatened species may be found in the vicinity of
the JIS Landfill site, no critical or sensitive habitats or areas
were identified on the site.
Potential on-site ecological impacts are generally restricted to
those animal species that come in contact with buried waste or
contaminated ground water. Since the wastes in the landfill are
buried below the normal burrowing depth of animals, there is no
risk due to exposure of buried contaminants. No ecological
routes of exposure to contaminated ground water exist on site.
Off-site plants and animals could potentially be at risk should
they inhabit areas where contaminated ground water discharges to
a surface water body or wetland area.
Surface water and sediment samples taken along Manalapan Brook
did not reveal any measurable contamination. Consequently, there
is no evidence of ecological impact from the landfill along
Manalapan Brook.
Uncertainties In Risk Assessment
The risk assessment process involves numerous conservative
assumptions, all of which contributed to uncertainty in the risk
evaluation. In general, sources of uncertainties associated with
the risk assessment include: environmental sampling and analysis,
exposure assessment, and toxicity assessment.
Uncertainties in environmental sampling arise in part from the
potentially uneven distribution of chemicals in the media
sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the risk
assessment provides upper-bound estimates of the risks to
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populations near the site, and is highly unlikely to under-
estimate actual risks related to the site.
Conclusion
Based on the results of the Baseline Risk Assessment, NJDEP and
EPA determined that contaminated ground water at the site poses
an unacceptable risk to human health.
Actual or threatened releases of hazardous substances from the
JIS Landfill site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to the public health, welfare, and the
environment through the continued migration of contaminants from
the site.
Remedial Action Objectives
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information and standards, such as applicable or
relevant and appropriate requirements (ARARs) and risk-based
levels established in the Baseline Risk Assessment.
Because the Baseline Risk Assessment established that the ground
water at the site poses an unacceptable risk to human health, the
following remedial action objectives were established:
Source Control
* Prevent or reduce further migration of contaminants from the
landfill into the ground water.
Ground Water
* Prevent human exposure to contaminated ground water.
* Prevent further migration of contaminated ground water off
site.
* Prevent the migration of contaminated ground water into the
underlying aquifers.
* Reduce contaminant concentrations in the Old Bridge Aquifer
to levels which do not exceed applicable Federal and State
water quality standards.
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DESCRIPTION OF REMEDIAL ALTERNATIVES
The Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), requires that
each selected site remedy be protective of human health and the
environment, comply with other statutory laws, be cost-effective,
and utilize permanent solutions, alternative treatment technolo-
gies and resource recovery alternatives to the maximum extent
practicable. In addition, the statute includes a preference for
the use of treatment as a principal element for the reduction of
toxicity, mobility, or volume of the hazardous substances.
This Record of Decision (ROD) evaluates remedial alternatives for
addressing ground-water contamination at the JIS Landfill site.
Since the migration of hazardous substances in the landfill into
the ground water is a pathway of concern, the FS included source
control remedial alternatives to address the landfill. A
detailed description of all of the alternatives may be found in
the FS report.
The estimated capital cost, operation and maintenance cost, and
present worth cost of each alternative discussed below are
provided for comparison. The cost figures are in 1992 dollars
because the FS was prepared in 1992. The present worth costs
were calculated at a five percent discount rate in the FS. For
the alternatives discussed below, the present worth costs were
recalculated at a seven percent discount rate to comply with EPA
Office of Solid Waste and Emergency Response Directive No.
9355.3-20 (June 25, 1993).
The estimated implementation time reflects only the time required
to construct or implement the remedy, and does not include the
time required to design the remedy, negotiate with the
responsible parties, or procure contracts for design and
construction.
Source Control Alternatives
The FS considered the following general response actions for the
source control of the landfill: no action, limited action, cap
improvements, and excavation/incineration.
Because the western slope of the landfill is steep and only
marginally stable, a retaining structure may be required as part
of any source control alternative involving cap improvements.
The need for, and design of, a retaining wall would be determined
during the Remedial Design phase. However, for the purpose of
developing cost estimates of alternatives, NJDEP estimated that
the cost of constructing a retaining wall at the JIS Landfill
would be approximately $2.1 million. The cost of a retaining
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wall is included in each of the capping alternatives discussed
below.
Because the gas pipeline is located along the (marginally stable)
western side of the landfill, construction activities at the
landfill, such as installation of a retaining wall, may affect
the integrity of the gas pipeline. To address safety concerns,
each capping alternative below also includes an evaluation of the
effects to the gas pipeline. Options, such as rerouting the gas
pipeline, will be considered during the Remedial Design phase if
warranted.
A gas collection system was installed by JIS when the landfill
was first capped. Each capping alternative includes an
evaluation of the existing landfill gas collection system, which
would be conducted during the Remedial Design phase to determine
whether additional controls are necessary to minimize gas
migration.
A discussion of the remedial alternatives which received detailed
analysis is provided below. Alternative SC 7, which consists of
excavation and on-site incineration of the waste in the landfill,
was analyzed in the FS. It did not pass the screening process
because of the extremely high cost; therefore, this alternative
is not included below.
Alternative SC 1: NO ACTION
Estimated Capital Cost: $0
Operation & Maintenance (0&M)/5 year review: $6,500
Present Worth: $14,000
Implementation Time: Not Applicable
CERCLA requires that a No Action alternative be evaluated at
every site to establish a baseline for comparison to the other
alternatives. Under this alternative, NJDEP and EPA would take
no further action at the site.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the site be reviewed at least every
five years. If justified by the review, remedial actions would
be evaluated at that time to address the contamination. The cost
estimates above include the cost to perform this review.
According to EPA's Hydrologic Evaluation of Landfill Performance
(HELP) model, the existing cap has an estimated infiltration rate
of 3,300,000 gallons/year. The HELP model evaluates the movement
of water through a landfill coyer.
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Alternative SC 2: LIMITED ACTION
Estimated Capital Cost: $45,000
0&M/5-year review: $6,500
Present Worth: $59,000
Implementation Time: 6 months
This alternative would consist of institutional controls to
minimize potential risks associated with the wastes in the
landfill. A fence would be constructed around the landfill to
restrict access. As in the No Action alternative above, the site
would be reviewed at least every five years. The cost estimates
above include the cost to perform this review. Because this
alternative would not include any improvements to the existing
landfill cover, the infiltration rate would be the same as in
Alternative SC 1 (i.e., 3,300,000 gallons/year).
Alternative SC 3: 1977 SOLID WASTE CAP
Estimated Capital Cost: $3,210,500
O&M 1st year: $301,700
O&M 2-30 years: $105,700
0&M/5-year review: $6,500
Present Worth: $4,719,000
Construction Time: 1.5 years
Alternative SC 3 would involve rebuilding and rehabilitating the
existing cap on the landfill to conform to the 1977 NJDEP capping
requirements for a solid waste landfill. The 1977 NJDEP Solid
Waste Cap Alternative would include:
6 inches vegetated topsoil
18 inches clay with maximum 1 x 10'7 cm/sec permeability
A fence would be constructed around the landfill to restrict
access. Operation and maintenance during the first year would
include monitoring the cap and maintaining the vegetative cover.
Long-term maintenance and monitoring would be implemented to
ensure the integrity and effectiveness of the cap.
Based on the HELP model, this type of cap would reduce the
current infiltration rate by approximately 92 percent. The
overall thickness of this cap would be 24 inches on top of the
waste.
As with the No Action alternative, the site would be reviewed at
least every five years.
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Alternative SO 4: AUGMENTED 1977 SOI/ID WASTE CAP
Estimated Capital Cost: $3,635,400
O&M 1st year: $301,700
O&M 2-30 years: $105,700
0&M/5-year review: $6,500
Present Worth: $5,144,000
Construction Time: 1.5 years
Alternative SC 4 would be identical to Alternative SC 3, except
the design of the cap would be augmented by an additional 18
inches of topsoil to provide freeze and thaw protection. The
Augmented 1977 Solid Waste Cap Alternative would include:
24 inches vegetated topsoil
18 inches clay with maximum 1 x 10"7 cm/sec permeability
The Augmented 1977 Solid Waste Cap is the same as the 1977 Solid
Waste Cap (Alternative SC 3), except an additional 18 inches of
topsoil would be added. A security fence would be installed
around the landfill to restrict access to the cap.
Based on the HELP model, this cap would reduce the current
infiltration rate by approximately 94 percent. The overall
thickness of this cap would be 42 inches on top of the waste.
As with the No Action alternative, the site would be reviewed at
least every five years.
Alternative SC 5: RESOURCE CONSERVATION AND RECOVERY ACT
HAZARDOUS WASTE CAP
Estimated Capital Cost: $5,272,000
O&M 1st year: $311,400
O&M 2-30 years: $115,400
0&M/5-year review: $6,500
Present Worth: $6,403,000
Construction Time: 1.5 years
Alternative SC 5 would involve rebuilding the existing landfill
cap to conform to the substantive requirements of Subtitle C of
the Resource Conservation and Recovery Act (RCRA) for the closure
of hazardous waste landfills.
The RCRA cap would include:
24 inches vegetated topsoil
12 inches soil drainage with minimum 1 x 10'2 cm/sec
permeability (or geosynthetic materials with
equivalent performance characteristics); a filter
layer
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20-mil flexible membrane liner
24 inches clay with maximum 1 x 1C)'7 cm/sec permeability
A security fence would be installed around the landfill to
restrict access to the cap.
Based on the HELP model, this cap would reduce the current
infiltration rate greater than 99.9 percent. The overall
thickness of this cap would be at least 60 inches on top of the
waste.
As with the No Action alternative, the site would be reviewed at
least every five years.
Alternative SO 6: MODIFIED NJDEP HAZARDOUS WASTE CAP
Capital Cost: $4,557,300
O&M 1st year: $311,420
O&M 2-30 years: $115,400
0&M/5-year review: $6,500
Present Worth: $6,186,000
Construction Time: 1.5 years
This alternative was developed to provide a light weight
hazardous waste capping system for the JIS Landfill site because
of the steep sideslope. It would include a textured synthetic
material layer that would increase friction along the landfill
sideslopes, and provide greater stability. In addition, this cap
would have a reduced unit weight and thickness. The Modified
NJDEP Hazardous Waste Cap would include:
24 inches vegetated topsoil
12 inches soil drainage layer with minimum 1 x 10~2 cm/sec
permeability
30-mil textured synthetic material layer
12 inches clay with maximum 1 x 10"7 cm/sec permeability
A security fence would be installed around the landfill to
restrict access to the cap.
Based on the HELP model, this cap would reduce the current
infiltration rate greater than 99.9 percent. This infiltration
rate is virtually the same as the RCRA cap. The overall
thickness of this cap would be at least 48 inches on top of the
waste.
As with the No Action alternative, the site would be reviewed at
least every five years.
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Ground-Water Alternatives
The four remedial alternatives that were evaluated in the FS are:
Ground-Water (GW) Alternative 1 - No Action, GW Alternative 2 -
Limited Action, GW Alternative 3 - Entire Plume Capture and
Treatment, and GW Alternative 4 - Primary Plume Capture and
Treatment, and Provision of Alternative Water Supply.
Alternative GW 3, Entire Plume Capture and Treatment, was not
developed fully in the FS because of several factors. The
contamination in the entire plume is spread over a large area and
the concentrations vary widely. Furthermore, the concentrations
of contaminants in the secondary plume are at low levels as
compared to the primary plume. Remediation of the entire plume
would require the installation of a large number of extraction
wells over a one square mile area, with many of the wells needed
to be located on residential property. Recent experience has
shown that obtaining access for extraction well installation is
extremely difficult and highly unlikely when impacting
residential property. The piping network required to connect
these wells with the treatment plant would be extensive and could
have adverse impacts on major roadways. Since the concentrations
of contaminants in the overall plume vary and the volume of
ground water needed to capture the overall plume is high, the
influent to the treatment plant would likely be very dilute,
making effective treatment extremely difficult. In addition,
natural attenuation of the secondary plume is likely to achieve
the cleanup levels within 10 to 30 years, which is a typical time
frame for active restoration. Because of these technical,
engineering, and administrative difficulties, Alternative GW 3
was not considered further in the FS and is not discussed below.
GW Alternative 1 - NO ACTION
Estimated Capital Cost: 0
0&M/5-year review: $6,500
Estimated Net Present Worth Cost: $14,000
Implementation Time: None
CERCLA requires that a No Action alternative be evaluated at
every site to establish a baseline for comparison to the other
alternatives. Under this alternative, NJDEP and EPA would take
no further action at the site.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the site be reviewed at least every
five years. If justified by the review, remedial actions would
be evaluated at that time to address the contamination. The cost
estimates above include the cost to perform this review.
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GW Alternative 2 - LIMITED ACTION
Estimated Capital Cost: $45,000
O&M: $12,000
0&M/5-year review: $6,500
Estimated Net Present Worth Cost: $207,900
Implementation Time: 6 months
This alternative would consist of institutional controls and
ground-water monitoring. NJDEP would place well-use restrictions
on well permits to prevent the installation of new wells in the
contaminated Old Bridge Aquifer. Ground-water sampling and
analysis would be performed periodically to monitor contaminant
migration.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the site be reviewed at least every
five years. If justified by the review, remedial actions would
be evaluated at that time to address the contamination. The cost
estimates above include the cost to perform this review.
GW Alternative 4 - PRIMARY PLUME CAPTURE AMD TREATMENT, AND
PROVISION OF ALTERNATIVE WATER SUPPLY
Capital Cost: $1,913,800
Alternative Water Supply: $690,000
O&M 1st year cost: $666,900
O&M 2-30 years: $441,500
0&M/5-year review: $6,500
Net Present Worth Cost: $8,097,000
Construction Time: 1 year
GW Alternative 4 involves pumping and treating the primary
contaminated ground-water plume in the vicinity of the JIS
Landfill site to meet State and Federal MCLs and/or the New
Jersey Ground-Water Quality Standards (NJGWQS). The contaminated
ground water would be treated by chemical oxidation/precipitation
to remove metals and air stripping to remove VOCs. Carbon
adsorption may be required to control air stripper emissions.
The treated ground water would be discharged back to the Old
Bridge Aquifer through a recharge trench. The exact number of
extraction wells, well locations, pumping rates, and operating
parameters would be determined during Remedial Design.
As many as 115 downgradient residents with private wells in the
Old Bridge Aquifer could potentially be affected by contamination
in the secondary plume. As part of this alternative, residents
with contaminated wells would be provided with an alternate
source of drinking water. NJDEP estimates that it would cost
approximately $6,000 for each water main extension and
connection. For the purpose of developing the cost of providing
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an alternative water supply, a conservative estimate of $690,000
was used.
NJDEP would place well-use restrictions on well permits to
prevent the installation of new wells in the contaminated portion
of the Old Bridge Aquifer.
Under Alternative 4, a monitoring program would be developed
during the design phase to verify the performance of the pump and
treat system remediating the primary plume and the natural
attenuation processes remediating the secondary plume. The
secondary plume would be monitored at least annually, and
evaluated every five years as part of the CERCLA five-year review
requirement discussed below. If, based on the monitoring data,
the estimated time period for natural attenuation of the
secondary plume does not meet with NJDEP's and EPA's
expectations, or NJDEP and EPA determine that natural attenuation
will not remediate the ground water to levels protective of human
health and the environment, then alternative aquifer restoration
methods may be evaluated to address the contamination in the
secondary plume. If necessary, such an alternative aquifer
restoration method would be set forth in a subsequent decision
document.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the site be reviewed at least every
five years. This review will include an evaluation of the
ground-water monitoring data referenced above. The cost
estimates above include the cost to perform this review.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan, a detailed analysis of each remedial
alternative was performed with respect to each of the nine
criteria. This section discusses and compares the performance of
the remedial alternatives under consideration against these
criteria. These criteria were developed to address the
requirements of Section 121 of CERCLA to ensure all important
considerations are factored into remedy selection decisions.
All selected remedies must at least satisfy the Threshold
Criteria. The selected remedy should provide the best trade-offs
among the Primary Balancing Criteria. The Modifying Criteria are
evaluated following the public comment period.
Threshold Criteria
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
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exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy
would meet all of the applicable or relevant and appropriate
requirements of Federal and State environmental statutes and
requirements and/or provide grounds for invoking a waiver.
Primary Balancing Criteria
3. Long-term effectiveness and permanence refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time, once remedial objectives have been
met.
4. Reduction of toxicitv. mobility or volume through treatment
addresses the statutory preference for selecting remedial
actions that employ treatment technologies that permanently
and significantly reduce toxicity, mobility or volume of the
hazardous substances as a principal element.
5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until the remedial
objectives are achieved.
6. Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
alternative.
7. Cost includes estimated capital and operation and
maintenance costs, and the present-worth costs.
Modifying criteria
8. State acceptance indicates whether, based on its review of
the RI/FS and the Proposed Plan, the State supports,
opposes, and/or has identified any reservations regarding
the preferred alternative.
9. Community acceptance refers to the community's comments on
the alternatives described in the Proposed Plan, and the RI
and FS reports. Responses to public comments are addressed
in the Responsiveness Summary of this ROD.
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A comparative analysis of the remedial alternatives based upon
the aforementioned evaluation criteria follows.
Overall Protection of Human Health and the Environment
Alternative SC 1 (No Action) and the Alternative SC 2 (Limited
Action) would not protect human health and the environment
because contaminants would continue to migrate into the ground
water through infiltration. Alternatives SC 3 (1977 Solid Waste
Cap), SC 4 (Augmented 1977 Solid Waste Cap), SC 5 (RCRA Hazardous
Waste Cap), and SC 6 (Modified NJOEP Hazardous Waste Cap) would
protect human health and the environment because cap improvements
would reduce the infiltration of water through the wastes, thus
reducing contaminant migration into the ground water.
Alternative GW 1 (No Action) and Alternative GW 2 (Limited
Action) do not employ any treatment, and would not protect human
health and the environment. Contaminants would remain in the
ground water and continue to migrate. GW Alternative 4 would
protect human health and the environment because it would require
an alternative water supply for affected wells and provide
further protection of human health through the issuance of well
use restrictions on new permits. The contaminants in ground
water are expected to be reduced, through active treatment of the
primary plume and natural attenuation of the secondary plume, to
levels that would be protective of human health and the
environment within 10 to 30 years.
Compliance with ARARs
There are several categories of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific ARARs are
technology or activity-specific requirements or limitations
related to various activities of the project. Chemical-specific
ARARs are usually numerical values which establish the amount or
concentration of a chemical that may be found in, or discharged
to, the ambient environment. Location-specific ARARs are
restrictions placed on the concentrations of hazardous substances
or the conduct of activities solely because they occur in a
special location. A list of ARARs is included in Table 3.
Action-Specific ARARs
Because hazardous substances were disposed of in the landfill,
the capping requirements in the NJDEP Hazardous Waste Regulations
(NJAC 7:26-10.8) and RCRA Subtitle C (40 CFR 264.310) regulations
pertaining to landfill closure are action-specific relevant and
appropriate requirements.
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Source Control Alternatives SC 1 (No Action), SC 2 (Limited
Action), SC 3 (1977 Solid Waste Cap), and SC 4 (Augmented 1977
Solid Waste Cap), would not comply with ARARs because the caps
associated with these alternatives do not meet the minimum design
requirements specified in the applicable regulations.
Alternative SC 5 would comply with all ARARs. Alternative SC 6
was developed (as a specialized modification of the Federal and
State caps) to address the slope stability concerns specific to
the JIS Landfill. For this alternative to be implemented, a
waiver of the capping requirements of the New Jersey Hazardous
Waste Landfill Closure Regulations (NJAC 7:26-10.8(i)2) would be
required based upon technical impracticability considerations
from an engineering perspective.
Chemical-Specific ARARs
Because ground water at the site is classified as Class II (i.e;,
drinking water), the following are considered relevant and
appropriate requirements: National Primary Drinking Water
Standards, New Jersey Safe Drinking Water Act Maximum Contaminant
Levels for Hazardous Contaminants, and/or New Jersey Ground Water
Quality Criteria (NJGWQC) established in the New Jersey Ground-
Water Standards (NJAC 7:9-6.7). These ARARs are presented in
Table 4 for the contaminants of concern in the ground water.
Table 5 represents the cleanup goal for the aquifer, which was
developed by selecting the most stringent criteria of the four
ARARs for each contaminant.
Alternatives GW 1 and GW 2 would not comply with ARARs because
contaminants at levels above the standards would remain at the
site. Alternative GW 4 would comply with ARARs because
contaminants in the primary plume would be treated until ARARs
are attained. Natural attenuation of the secondary plume would
comply with ARARs because the contaminants in the secondary plume
are expected to meet the Federal and State MCLs and.or NJGWQC
within 10 to 30 years. Carbon adsorption would be added to the
air stripper if needed to comply with the NJDEP Regulations for
Air Pollution Control.
Location-Specific ARARs
Because wetland areas are located downgradient from the site and
may potentially be affected by the extraction of ground water,
location-specific ARARs include the Wetlands Protection Act of
1970 and Executive Order 11990—"Protection of Wetlands."
The extraction wells and recharge trench would be designed to
minimize impacts to the wetlands to the maximum extent
practicable to comply with the location-specific ARARs.
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Because Alternatives GW 1, GW 2, SC 1, and SC 2 do not provide
overall protection of human health and the environment and do not
comply with ARARs, they do not meet the threshold criteria that
each alternative must meet in order to be eligible for selection.
Therefore, these alternatives will not be discussed further.
Long-Term Effectiveness and Permanence
Alternatives SC 5 and SC 6 are more effective and reliable than
Alternatives SC 3 and SC 4 because the cap designs allow the
least amount of water infiltration and provide protection against
damage due to freeze and thaw.
With respect to the primary plume, Alternative GW 4 is effective
and reliable because contaminant concentrations in the primary
plume would be reduced through treatment. The treatment system
includes chemical oxidation/precipitation and air stripping,
which are proven technologies. The provision of alternative
drinking water supply to downgradient residents with private
wells contaminated by the secondary plume offers long-term
effectiveness and a permanent solution.
Reduction in Toxicity, Mobility or Volume
Alternative SC 3 provides the least reduction of mobility and
volume, since it has the greatest amount of infiltration among
the four capping alternatives. Alternative SC 4 provides greater
reduction of mobility and volume than Alternative SC 3.
Alternatives SC 5 and SC 6 provide the greatest reduction in
mobility and volume because these two alternatives have the
lowest infiltration rate. Toxicity would not be reduced by
Alternatives SC 3, SC 4, SC 5, and SC 6 because cap improvements
would reduce the infiltration of water through the wastes, but
not treat the wastes themselves.
Alternative GW 4 would reduce toxicity, mobility, and the volume
of contaminants in the primary plume through treatment. The
mobility and volume of contaminants in the secondary plume would
remain the same through natural attenuation; however, toxicity of
the contaminants would decrease through degradation.
Short-Term Effectiveness
On-site remedial workers might be exposed to hazardous wastes or
contaminated soil during the installation of the cap in
Alternatives SC 3, SC 4, SC 5, and SC 6. A site-specific Health
and Safety Plan would be developed and implemented to minimize
the risks to workers.
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The installation of extraction wells and sampling of monitoring
wells associated with the implementation of Alternative GW 4 may
expose workers to contaminants. These risks would be minimized
by the use of personal protection equipment. Sludges produced
from the treatment process would be disposed of at an appropriate
off-site facility.
Implementability
Capping is a conventional and widely used method for waste
containment at hazardous waste sites. The equipment, material,
and contractors are readily available and would not pose a
problem in that respect for Alternatives SC 3, SC 4, SC 5, and SC
6. However, the steepness of the landfill sideslope and the
presence of the gas pipeline may make the implementation of these
alternatives difficult.
Alternative GW 4 would be relatively easy to implement. The
proposed treatment technologies are proven and reliable, and the
equipment, materials, and specialists needed for implementation
would be readily available.
COSt
Of the Source Control Alternatives, Alternative SC 3, costs the
least, with an estimated present worth of $4,719,000.
Alternative SC 4 would be the next expensive, with an estimated
present worth of $5,144,000. Alternative SC 5 is the most
expensive, with an estimated present worth of $6,403,000.
Alternative SC 6 has an estimated present worth of $6,186,000.
Ground-Water Alternative GW 4 has an estimated present worth of
$8,097,000.
State Acceptance
The New Jersey Department of Environmental Protection concurs
with the selected remedy.
Community Acceptance
Community acceptance was evaluated after the close of the public
comment period. Written comments received during the public
comment period, as well as verbal comments during the public
meeting on December 7, 1994, were evaluated. The response to
those comments are addressed in the Responsiveness Summary.
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SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments, the
NJDEP and EPA have determined that Alternatives SC 6 and
GW 4 constitute the remedy that is protective of human health and
the environment, and will maintain an adequate level of
protection over time.
The ground-water cleanup levels for the JIS Landfill site are
listed in Table 5.
The major components of the selected remedy include the
following:
• provide an alternative water supply for residents with
contaminated drinking water wells
upgrade the existing landfill cap to consist of:
24 inches vegetated topsoil
12 inches soil drainage layer
30-mil textured synthetic material layer
12 inches clay with maximum 1 x 10'7 cm/sec permeability
extract contaminated ground water from the primary
plume underlying the site
treat the contaminated ground water in a facility to be
constructed on site
• dispose the treated ground water on the site by a
recharge trench
implement a ground-water monitoring program to monitor
the primary and secondary plumes, and to ensure the
effectiveness and protectiveness of the remedy
NJDEP will place well-use restrictions on well permits to prevent
the installation of new wells in the contaminated portion of the
Old Bridge Aquifer. Appropriate land-use restrictions will be
required for the landfill. In addition, because this alternative
would result in contaminants remaining on site, CERCLA requires
that the site be reviewed at least every five years.
The goal of this remedial action is to restore the ground water
to its beneficial use, in this case, a source of drinking water.
However, NJDEP and EPA recognize that the selected remedy may not
achieve this goal because of the technical difficulties
associated with achieving ground-water cleanup levels. It may
become apparent, during implementation or operation of the
ground-water extraction/treatment system, that contaminant levels
have ceased to decline and are remaining constant at levels
higher than the remediation goal. In such a case, the system's
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performance standards and/or the remedy may be reevaluated.
Performance monitoring of the ground-water extraction and
treatment system will be implemented. The data collected would
be used to suggest system adjustments or modifications to provide
more effective or efficient attainment of cleanup levels. Such
adjustments or modifications may include: increasing or
decreasing the extraction rate, initiating a pulsed pumping
schedule, installing additional extraction wells (or drains), or
ceasing extraction at wells where cleanup levels have been
achieved. Monitoring data will be used to assess the
effectiveness of the modifications implemented and may be used to
re-assess the time frame required to achieve cleanup levels.
Monitoring will also be performed on at least an annual basis to
evaluate the ongoing natural attenuation of the secondary plume.
The secondary plume will be evaluated every five years as part of
the CERCLA five-year review requirement. If, based on the
monitoring data, the estimated time period for natural
attenuation of the secondary plume does not meet with NJDEP's and
EPA's expectations, or EPA and NJDEP determine that natural
attenuation will not remediate the ground water to levels
protective of huiran health and the environment, then alternative
aquifer restoration methods may be evaluated to address the
contamination in the secondary plume. If necessary, such an
alternative aquifer restoration method would be set forth in a
subsequent decision document.
Because the ground-water extraction system may adversely impact
nearby wetlands, a wetlands assessment will be conducted during
the design phase to evaluate the potential effects due to the
extraction and discharge of ground water. In addition,
supplemental data will be gathered from wetland areas
downgradient from the site to ensure that there are no serious
ecological effects caused by the contamination plume discharging
to the surface in wetland areas. Adverse impacts to the wetlands
will be mitigated through engineering controls to the maximum
extent practicable.
STATUTORY DETERMINATIONS
The remedy selected by NJDEP and EPA for ground water and source
control at the site complies with the requirements of Section 121
of CERCLA, as amended by SARA. The selected remedy is protective
of human health and the environment, complies with Federal and
State requirements that are applicable, or relevant and
appropriate to this action, and is cost-effective. The selected
remedy utilizes permanent solutions, and alternative treatment
technologies or resource recovery technologies, to the maximum
extent practicable. The statutory preference for treatment that
reduces toxicity, mobility or volume will be satisfied by the
selected remedy. The selected remedy provides the best balance
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of trade-offs among the criteria. The following sections discuss
how the selected remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified.
The principal threat posed by the site is the hazardous
substances in the landfill as it affects the ground water. The
pathways associated with this threat include the infiltration of
landfill contaminants into the ground water and the potential
migration of contaminated ground water into the deeper aquifers.
By minimizing infiltration, and extracting and treating the
contaminated ground water, the threats to human health and the
environment will be reduced. Contaminants in the ground water
will be reduced to levels that are acceptable for drinking water.
Well-use restrictions will be placed on well permits to prevent
the use of contaminated ground water before levels protective of
human health are reached.
Compliance with ARARs
With the exception noted below, the selected remedy will comply
with the substantive requirements of the statutes and regulations
listed in Table 4 to the extent they are applicable or relevant
and appropriate to the remediation at this site.
Action-Specific ARARs
The selected remedy will meet the appropriate RCRA Subtitle C
Regulations. However, pursuant to 40 CFR 300.430(f)(ii)(C), a
waiver of the capping requirements of the New Jersey Hazardous
Waste Landfill Closure Regulations set forth in NJAC 7:26-
10.8(1)(2) is being invoked under this ROD. The basis for
invoking this waiver is technical impracticability. The specific
engineering design criteria for the cap established in the New
Jersey Hazardous Waste Landfill Closure Regulations cannot be
implemented due to slope instability concerns. Notwithstanding,
the selected remedy will attain a standard of performance that is
equivalent to that required under the New Jersey Hazardous Waste
Landfill Closure Regulations. The remedy will meet the
appropriate Federal and State guidelines and requirements for
subsurface gas management systems.
26
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Chemical-Specific ARARs
The contaminants of concern in the primary plume will be
remediated to the cleanup levels listed in Table 5. The cleanup
levels represent: the concentrations which would be attained in
the treated water before discharge into a recharge trench, and
the cleanup goal for the aquifer.
Natural attenuation of the secondary plume will comply with ARARs
because the contaminants in the secondary plume are expected to
meet the Federal and State MCLs and/or NJGWQC within 10 to 30
years.
Emissions from the air stripper will be designed to comply with
the New Jersey Air Pollution Control Regulations for VOC and
toxic emissions (NJAC 7:27-16 & 17).
Location-Specific ARARs
The substantive requirements of Executive Order 11990 and the
Freshwater Wetlands Act (NJAC 7:?A-1.1 et sea.) will be met. The
extraction wells and recharge trench will be designed and located
to minimize impacts to the wetlands to the maximum extent
practicable.
Advisories. Guidance and Criteria To Be Considered
The shipment of hazardous wastes off site to a treatment/disposal
facility will be conducted in accordance with EPA's Office of
Solid Waste and Emergency Response Directive No. 9834.11,
"Revised Procedures for Planning and Implementing Off-site
Response Actions." The intent of this directive is to ensure
that facilities authorized to accept CERCLA-generated waste are
in compliance with RCRA operating standards.
Cost-Effectiveness
Of the alternatives which most effectively address the threats
posed by site contamination, the selected remedy provides for
overall effectiveness in proportion to its cost. The estimated
total project cost is $14.3 million.
Utilization of Permanent solutions and Alternative Treatment
Technologies to the Maximum Extent practicable
Contaminants in the primary plume will be removed and treated
before reinjection. Hazardous wastes generated by the treatment
process will be disposed of at an approved off-site facility.
27
-------
This will significantly reduce the toxicity, mobility and volume
of the contaminants, and offers a permanent solution to the risks
posed by the contaminated ground water.
Preference for Treatment as a Principal Element
With respect to the primary plume, the selected remedy satisfies
the statutory preference for treatment as a principal element.
The selected remedy reduces levels of contaminants in the ground
water through treatment, using chemical oxidation/precipitation
to remove metals and air stripping to remove VOCs, and thereby
reducing the risk to human health.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the JIS Landfill site was released to the
public on November 28, 1994. The Proposed Plan identified the
preferred alternatives for ground-water and source control. EPA
reviewed all written and verbal comments received during the
public comment period. Upon review of these comments, EPA
determined that no significant changes to the selected remedy, as
it was originally identified in the Proposed Plan, were
necessary.
28
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APPENDIX I
FIGURES
Figure 1 JIS Landfill Site Location
Figure 2 Primary and Secondary Ground-Water Contamination Plumes
Figure 3 Primary Ground-Water Contamination Plume
-------
iff
JONES INDUSTRIAL SERVICES
UNDFILL SITE
GIWMC
Figure 1. Jones Industrial Services CJIS) Superfund Site Location
-------
300'
300'
GRAPHIC SCALE
BVWST
TRAILERS
Figure 2.. JIS Landfill Superfiind Site
Primary Ground Water Contamination Flume
-------
_500Q
Figure 3.- JIS Superfund Site
Primary and Secondary Ground Water Contamination Plumes
-------
APPENDIX II
TABLES
Table 1 Predominant Ground-Water Contaminants and Range "of
Concentrations Detected
Table 2 Predominant Soil Contaminants and Range of
Concentrations Detected
Table 3 Summary of Federal and State Applicable or Relevant and
Appropriate Requirements (ARARs) for the JIS Landfill
Site
Table 4 Applicable or Relevant and Appropriate Requirements for
Contaminants Detected in the Ground Water at the JIS
Landfill Site
Table 5 Ground-Water Cleanup Levels for the JIS Landfill Site
-------
Table l. Predominant Ground-Water Contaminants and Range of
Concentrations Detected in parts per billion (ppb)
Contaminant
antimony
benzene
chromium
1,2-dichloroethene (total)
ethylbenzene
lead
methylene chloride
toluene
trichloroethene
tetrachloroethene
vinyl chloride
xylenes
Primary Plume
81.8 - 82.8
14 - 7,900
10 - 26
2 - 750
5 - 480
3.3 - 90
3 - 5,300
2 - 4,700
2-77
3 - 190
3 - 180
6 - 2,500
Secondary Plume1
Not Detected
6 - 370
7.2 - 11.2
28.3 - 220
Not Detected
4.4 - 20.3
0.9 - 6.4
0.6 - 2.3
11.1 - 87
1.2 - 2.5
Not Detected
6 - 9.4
1 One hot spot contamination of unknown source is not reflected.
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Table 2. Predominant Soil contaminants and Range of
Concentrations Detected in parts per million (ppm)
Contaminant
arsenic
chromium
lead
1,1, 1-trichloroethane
di-n-butylphthalate
phenanthrene
pyrene
bis-2-ethylhexylphthalate
Aroclor 1260
4,4' DDE
4,4' DDT
Surface
11.7 - 59.6
9.9 - 10.5
4.0 - 23.7
1-3
140 - 5400
140 - 29001
43 - 69002
71 - 110
170 -3802
98.0
15 - 2302
Subsurface
2.1 - 85.6
1.7 - 18.6
1.7 - 18.6
Not Detected
Not Detected
Not Detected
Not Detected
Not Detected
Not Detected
28 - 1601
25 - 6202
1 Contaminant detected in two soil samples.
• Contaminant detected in three soil samples.
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Table 3. Summary of Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs) for the JIS Landfill Site
FEDERAL ARARs
National Primary Drinking Water Standards--
Maximum Contaminant Levels
National Primary Drinking Water Standards--
Maximum Contaminant Level Goals
Resource Conservation and Recovery Act (RCRA)
Standards for Owners & Operators of Hazardous
Waste Treatment, Storage, and Disposal
Facilities—Hazardous Waste Landfill Covers
Protection of Wetlands
STATE ARARs
New Jersey Safe Drinking Water Act--
Maximu;.. Contaminant Levels
New Jersey Ground Water Quality Standards--
New Jersey Ground Water Quality Criteria
New Jersey Air Pollution Control Regulations--
Volatile Organic Compounds
New Jersey Air Pollution Control Regulations--
Toxic Volatile Organic Compounds
New Jersey Fresh Water Wetlands Protection Act
New Jersey Hazardous Waste Regulations--
Hazardous Waste Landfill Covers
CITATION
40 CFR Part 141
40 CFR Part 141.
40 CFR Part 264.
Executive Order
50
300
11990
CITATION
NJAC 7:10-16
NJAC 7:9-6.7
NJAC 7:27-16
NJAC 7:27-17
NJSA 13:96-1
NJAC 7:26-10.8
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TABLE 4. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR CONTAMINANTS DETECTED
IN THE GROUND WATER AT THE JIS LANDFILL SITE
in parts per billion
GROUND-WATER CONTAMINANT
Acetone
Benzene
Chlorobenzene
Chloroform
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1.1-Dichloroethane
1 ,2-Dichloroethane
1,1-Dichloroethene
cis 1 ,2-Dichloroethene
trans 1,2-Dichloroethene
1,2-Dichloropropane
Ethylbenzene
Methylene chloride
4-Methyl-2-Pentanone
Nitrobenzene
1 ,1 ,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1 ,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
Trichloroethene
Vinyl chloride
Xylenes (total)
Antimony
Arsenic
Barium
Cadmium
Chromium (total)
Copper
Lead
Manganese
Nickel
Zinc
FEDERAL MCL1
5
100
600
75
5
7
70
100
5
700
5
5
1,000
70
200
5
2
10,000
6
50
2,000
5
100
. 1,300
15
100
FEDERAL
MCLG2
zero
100
600
75
zero
7
70
100
zero
700
zero
zero
1,000
70
200
zero
zero
10,000
6
2,000
5
100
1,300
zero
100
NJ MCL3
1
4
600
600
75
2
2
10
10
5
700
2
1
1
8
26
1
2
44
6
50
2,000
5
100
1,300
15
100
NJGWQC4
700
0.2
5
6
600
600
75
70
0.3
1
10
100
0.5
700
2
400
3
2
0.4
1,000
9
30
1
0.08
40
2
0.02
2,000
4
100
1,000
5
50
100
5,000
1 National Primary Drinking Water Maximum Contaminant Level (MCL).
2 National Primary Drinking Water Maximum Contaminant Level Goal (MCLG). Only non-zero MCLGs are
considered applicable or relevant and appropriate requirements.
3 New Jersey Safe Drinking Water Act Maximum Contaminant Level.
4 New Jersey Ground Water Quality Criteria.
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TABLE 5. GROUND-WATER CLEANUP LEVELS FOR THE JIS LANDFILL SITE
in parts per billion (ppb)
GROUND-WATER CONTAMINANT
Acetone
Benzene
Chlorobenzene
Chloroform
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
1 ,2-Dichloroethane
1,1-Dichloroethene
cis 1,2-Dichloroethene
trans 1 ,2-Dichloroethene
1 ,2-Dichloropropane
Ethylbenzene
Methylene chloride
4-Methyl-2-Pentanone
Nitrobenzene
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1 ,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
Trichloroethene
Vinyl chloride
Xylenes (total)
Antimony
Arsenic
Barium
Cadmium
Chromium (total)
Copper
Lead
Manganese
Nickel
Zinc
CLEANUP LEVEL
(ppb)
700
0.2*
4
6
600
600
75
70
0.3°
1°
10
10
0.5°
700
2
400
3*
2
0.4°
1
8
26
1
0.08°'a
40
2».«
0.02°
2,000
4
100
1,000
5*
50
100
5,000
PRACTICAL QUANTITATION
LIMIT (ppb)
1
2
2
1
10
1
5
20
8
10
0 The cleanup level is the New Jersey Ground Water Quality Criteria (NJGWQC). Compliance with the NJGWQC will
be determined by analytical measurements equal to, or less than, the specific Practical Quantitation Limit (POL), as
defined and established in NJAC 7:9-6, and shown above.
a Rigorous testing that produces a lower detection limit than the POL may be required for this contaminant on a
periodic basis.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION
JIS Landfill Site
South Brunswick Township, Middlesex County, New Jersey
United States Environmental Protection Agency
Region II
New York, New York
-------
RESPONSIVENESS SUMMARY
JIS LANDFILL SITE
South Brunswick Township, Middlesex county, New Jersey
INTRODUCTION
A responsiveness summary is required by Superfund policy. It
provides a summary of citizens' comments and concerns received
during the public comment period, and the New Jersey Department
of Environmental Protection (NJDEP) and the United States
Environmental Protection Agency (EPA) responses to those comments
and concerns. All comments summarized in this document have been
considered in the NJDEP and EPA final decision for selection of a
remedial alternative for the JIS Landfill site.
OVERVIEW
The preferred remedial alternative, which w?.s presented in the
Proposed Plan, addresses source control and contaminated ground
water at the site. The major components of the preferred
alternative included extraction and on-site treatment of
contaminated ground water, and disposal of treated ground water
on the site by a recharge trench; upgrade of the existing
landfill cap to meet Modified NJDEP Hazardous Waste cap; and
provision of an alternative water supply to residents with
contaminated drinking water wells.
SUMMARY OF COMMUNITY CONCERNS
Comments from the public comment period generally supported the
remedial alternative chosen to remediate ground water at the
site. Several commenters questioned the need to upgrade the
existing landfill cap. Major concerns included how remedial
activities would affect the natural gas pipeline, compensation
for expenses associated with closing a contaminated residential
well and water main hook up, health risks associated with the
site, the funding source for the cleanup of the site, and the
time frame for remediation. Several comments concerned the long
time it took to reach this point from when ground-water
contamination was first discovered.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Remedial Investigation and Feasibility Study (RI/FS), .and the
Proposed Plan for the site were released to the public for
comment on November 28, 1994. These documents were made
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available to the public in the administrative record file at the
EPA Docket Room in Region II, New York and the information
repositories at the South Brunswick Municipal Building and the
South Brunswick Public Library. The notice of availability for
the above-referenced documents was published in The Home News on
November 26, 1994. The public comment period on these documents
was held from November 28, 1994 to December 28, 1994.
On December 7, 1994, NJDEP conducted a public meeting at the
South Brunswick Senior Citizens Center, to inform local officials
and interested citizens about the Superfund process, to review
current and planned remedial activities at the site, and to
respond to any questions from area residents and other attendees.
SUMMARY OF COMMENTS AND RESPONSES
The following is a summary of the comments provided at the public
meeting and comments received during the public comment period,
as well as NJDEP's and EPA's response to those comments.
COMMENTS RAISED DURING THE PUBLIC MEETING ON DECEMBER 7. 1994
1. COMMENT:
RESPONSE:
Is Black & Veatch under investigation by the NJDEP
for fraudulent billing?
Black and Veatch is the NJDEP contractor who
performed the RI/FS, and no, they are not under
investigation. However, NJDEP is reviewing the
contract with Black & Veatch to determine whether
there are any discrepancies between the contract
and the invoices. This is standard procedure.
2. COMMENT:
RESPONSE:
When was the last set of ground-water samples
taken?
Ground-water monitoring wells were last sampled by
Black & Veatch in late 1991-early 1992.
3. COMMENT:
RESPONSE:
Was the first round of soil borings from the clay
cap on the landfill taken by Black & Veatch
analyzed incorrectly by Empire Soils?
Eight soil borings of the landfill cap were taken
by Black and Veatch. Permeability testing was
performed on six of those samples by Empire Soils.
NJDEP found that a portion of the analyses by
Empire Soils were performed incorrectly. They
were subsequently reanalyzed by Woodward-Clyde
-------
Consultants. It was these reanalyzed results that
were reported in the RI/FS.
4. COMMENT:
RESPONSE:
There are 12 inches of clay in the [JIS] landfill
cap. It's the same that's in every single
landfill. The Brown and Ferris [South Brunswick]
and the Monroe Township landfills both have 12
inches of clay. JIS installed a cap on the
landfill under a 1977 court order. This cap was
state-of-the-art. JIS has all the test results,
but the NJDEP has never reviewed them.
The reports submitted by JIS were reviewed and
summarized and discussed in the RI/FS. NJDEP
evaluated the existing landfill cap and concluded
that the cap must be upgraded in order to protect
human health and the environment. There is still
significant ground-water contamination emanating
from the landfill. Enhancing the existing cap to
the Modified NJDEP Hazardous Waste Cap gives the
required protection and is the best way to prevent
further ground-water contamination. (See summary
of written comments from Borrus et al. and A-Z
Environmental COMMENT/RESPONSE 37 for further
discussion on this topic).
5. COMMENT:
RESPONSE:
6. COMMENT:
RESPONSE:
JIS investigated initiating grpund-water treatment
at the site 9-10 years ago. If that system had
been put in operation then, the ground-water
remediation would be well underway now. The NJDEP
never looked into this study.
The history of the NJDEP's response to, and
negotiations with, the owner of the landfill is
beyond the forum of the public meeting (see
COMMENT/RESPONSE 41 for further discussion on this
issue).
What is the background ground-water quality?
NJDEP sampled four monitoring wells on the western
side of the NJ Turnpike, located upgradient of the
JIS Landfill (MW-1S, MW-1D, MW-14S, and MW-14D).
These wells reflect the background ground-water
quality. Only one compound in one of the four
wells exceeded the New Jersey Ground Water Quality
Criteria (NJGWQC)—in MW-1S, lead was found at
16.5 parts per billion (ppb).
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7. COMMENT:
RESPONSE:
At the toe of the landfill, one monitoring well is
contaminated and ten feet away, a deeper well is
clean. Can the monitoring wells spread the
ground-water contamination from one aquifer to
another?
All of the monitoring wells were installed in the
Old Bridge Aquifer, which is above the clay layer
that protects the deeper (Farrington Sands)
aquifer.
8. COMMENT:
RESPONSE:
Is the pumping well, PW-1, installed by the NJDEP
used for reinjection of untreated ground water
contributing to the spread of contamination?
NJDEP used pumping well PW-l for circulating
ground water collected for testing purposes back
into the plume, from which it was extracted,
during the aquifer pump test for the RI. NJDEP
was not degrading any ground water or spreading
contamination by putting the ground water back
into PW-1 because this well is located down-
gradient from the well with the highest level of
contamination.
9. COMMENT:
RESPONSE:
Whose money is being, and will be, spent on
cleanup of the JIS Landfill?
The Remedial Investigation and Feasibility Study
(RI/FS) was conducted using State funds; those
funds were then reimbursed by a group of
potentially responsible parties (PRPs) who
disposed of wastes in the JIS Landfill. Once the
remedy is selected in the Record of Decision,
NJDEP will offer the PRPs the opportunity to
undertake the cleanup. If the PRPs decline, then
federal Superfund money and NJ Hazardous Discharge
Bond money will be used to fund the cleanup. EPA
and/or NJDEP would then attempt to recover these
funds from the PRPs.
10. COMMENT:
RESPONSE:
Can residents who used their own money to connect
to a public water supply when their drinking water
well was contaminated be reimbursed?
There is a State fund under which residents could
file a claim for reimbursement. The regulations
associated with this fund have a one year statute
of limitations for claims of this nature. If
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residents did not file a claim within one year of
connecting to public water, they are no longer
eligible to file a claim.
11. COMMENT:
RESPONSE:
How will putting a cap on the landfill address the
contamination in the ground water?
Upgrading the existing landfill cap to the NJDEP
Modified Hazardous Waste Cap will ensure that no
further contamination enters the ground water by
reducing the infiltration of rainwater through the
chemicals in the landfill. The pumping and
treating of the ground water will draw
contaminated ground water back towards the
landfill so that it does not continue to spread
away from the landfill. In order for the ground-
water remedy to be effective, the existing
landfill cap must be upgraded. See COMMENT/
RESPONSE 61 for further discussion on this topic.
12. COMMENT:
RESPONSE:
Don't hazardous waste landfills usually have some
type of liner to catch the leachate? Also, what's
going to stop the leachate from continually
flowing away from the landfill once you place a
cap on it? And, how long will the contamination
continue to emanate from the landfill?
Current regulations require new hazardous waste
landfills to have a bottom liner to prevent
leachate from migrating out of the landfill. At
the time this landfill was built, these
requirements were not in place. Therefore, this
particular landfill does not have a bottom liner.
However, the new cap should significantly reduce,
if not stop, the amount of leachate emanating from
the landfill by preventing infiltration from
passing through the wastes in the landfill. NJDEP
cannot specifically calculate how long the
leachate will continue to emanate from the
landfill.
13. COMMENT:
RESPONSE:
If the cap was ordered in 1977, and it wasn't done
right, then why is it 1994 when we're finally
doing something about it? Why has it taken NJDEP
so long to get to the point of remediating the
contamination?
In December of 1975, NJDEP ordered the landfill to
cease operations; litigation ensued until 1988.
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This postponed the initiation of the actual
investigation of the site. Superfund was created
in 1980 to specifically handle sites such as JIS,
where federal and state monies are used to
investigate and remediate sites when PRPs are
unwilling to take responsibility or are
financially unable to conduct the work themselves.
JIS was placed on the National Priorities List on
September 1, 1983. The Rl began in 1986 and was
completed in 1992. The FS was initiated in 1991
and completed in 1993.
NJDEP first addressed the immediate risks from the
site by offering impacted residents an alternative
source of drinking water. Once this was
accomplished, the RI was initiated to address long
term risks. Although the time frame seems
unnecessarily long, the complex nature of the site
required several rounds of sampling before the
site could be characterized.
14. COMMENT:
RESPONSE:
Are heavy metals a concern at this site and in the
secondary plume? How does the NJDEP plan on
addressing the heavy metals migration?
Heavy metals present in the primary plume will be
treated with the rest of the ground-water
contamination by chemical oxidation and
precipitation to remove the metals. Heavy metal
contaminant concentrations in the secondary plume
are at lower levels and will be monitored at least
annually. If the secondary plume does not
naturally attenuate within a reasonable time
frame, or is determined to be no longer protective
of human health and the environment, other
remedial alternatives will be evaluated to address
the contamination. Much of the metals found in
the secondary plume are attributed to be occurring
in nature as part of the local geology.
15. COMMENT:
RESPONSE:
The sampling of monitoring wells is too distant.
You don't sample the monitoring wells consistently
on a monthly or quarterly basis. Can you build
into your procedures a plan that would definitely
monitor these wells on a monthly or bimonthly
basis?
During the actual remedial work, monitoring wells
will be sampled on a regular basis in accordance
with the ground-water monitoring plan to be
-------
developed during the .design phase. The monitoring
frequency will be determined during the design,
but would probably be twice a year for the first
five years. The ground-water monitoring results
will be available to the public for review.
16. COMMENT:
RESPONSE:
What is meant by a reasonable time frame for
natural attenuation, and can it be speeded up?
A reasonable time frame for natural attenuation
would be 30 years. There is no way to increase
the rate of natural attenuation without active
remediation.
17. COMMENT:
RESPONSE!
Have the PRPs been fined so that they could help
defray the cost of cleaning up the site? Does the
NJDEP ever succeed in getting compensated for
funds spent to clean up these sites or natural
resource damages?
No, the PRPs have not been fined because there are
no fines associated with the regulations. The
PRPs have not entered into an agreement with NJDEP
or EPA to undertake or fund the cleanup at the JIS
Landfill Site. Yes, NJDEP is successful in
recovering costs and collecting natural resource
damages.
18. COMMENT:
RESPONSE:
The State of New Jersey, including NJDEP and
Rutgers University, have disposed of wastes in the
JIS Landfill. Are they paying for the
remediation? Are they considered liable for the
cleanup?
According to the NJDEP, one state agency cannot
sue another state agency. However, under CERCLA,
a state can be considered liable for cleanup of a
National Priorities List (NPL) site if it disposed
of hazardous waste not related to a response
action. Based on information available to EPA,
there is insufficient evidence to support JIS's
claim that the State of New Jersey, NJDEP, and
Rutgers University disposed of hazardous waste at
the JIS Landfill.
19. COMMENT:
Why was Brown and Ferris [Browning Ferris]
Industries taken off of the PRP list?
-------
RESPONSE:
NJDEP issued Browning Ferris Industries a Request
for Information in 1989. Based on a review of the
response, NJDEP determined that Browning Ferris
Industries was not a PRP, and consequently was not
included on the PRP list.
20. COMMENT:
RESPONSE:
The State acts as if the owners of JIS were
engaged in illegal activity by accepting wastes at
the landfill when in actuality the landfill was
licensed by the State during its operation.
The NJDEP has never alleged any illegal activity
on the part of the owners of JIS Landfill.
However, under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA),
as owner and operator of the JIS Landfill, they
are liable for the cleanup of the site.
21. COMMENT:
RESPONSE:
How big will the ground-water pump and treat
facility be and what will it look like?
Specific plans for the plant will not be drawn up
until the design of the remedy is in progress.
The plant itself will be located on-site. The
NJDEP tries to make these plants as unobtrusive as
possible.
22. COMMENT:
RESPONSE:
Will the recovery wells be located on or off the
site?
Some recovery wells will be located on the JIS
property while others may be installed across
Cranbury-South River Road off JIS property.
23. COMMENT!
RESPONSE:
At what rate is the plume of contamination
travelling at and how was this rate calculated?
The rate of migration of the ground water had been
calculated at an average of 1.2 feet per day.
That's based on the slope of the ground-water
table and on the rate at which water flows through
the soil in the aquifer, the Old Bridge Aquifer in
this case. The plume is flowing in a southeast
direction.
The slope of the aquifer is considered in the
calculation of the ground-water flow. The change
in aquifer elevation from one point to another is
8
-------
considered and the type of geologic material it's
flowing through is also considered. The rate of
flow is a calculated value based on field tests.
24. COMMENT:
RESPONSE:
How far below the ground surface is the ground
water?
Ground-water table elevations can vary with
topography and seasonal rainfall. The ground-
water table is about 70 feet above mean sea level
(MSL). The ground surface at the JIS Landfill is
about 130 feet above MSL, and about 85 feet above
MSL in the pit next to the landfill. Therefore,
the ground water is approximately 60 feet below
the ground surface at the JIS Landfill, and
approximately 15 feet below the ground surface at
the pit adjacent to the landfill.
25. COMMENT:
RESPONSE:
Have you determined to what depth wastes were
deposited in the landfill? Are wastes in direct
contact with the ground water?
Aerial photographs of the area taken during the
1950s did not indicate that the borrow pit was
excavated to the ground-water table. NJDEP did
not install borings or monitoring wells through
the landfill, so the exact depth of the waste and
the exact depth of the ground-water beneath the
waste is not known. However, monitoring wells
MW-3 and MW-16 were installed in the pit 10 feet
from the edge of the landfill, and the depth to
ground water in these wells is 15 feet. The
bottom of the pit adjacent to the landfill is most
likely the lower limit for the deposition of any
waste in the landfill. Since the depth to ground
water is 15 feet below this level, this suggests
that the waste is not in contact with ground
water, and that there is a 15 feet unsaturated
zone between the waste in the landfill and the
ground-water table.
26. COMMENT:
RESPONSE:
Has the NJDEP taken into consideration the 36-inch
natural gas pipeline that runs between the
landfill and the NJ Turnpike?
Yes. NJDEP has contacted the Colonial Pipeline
Company, the owner of the pipeline. They are
willing to work with the NJDEP and ensure that
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remedial activities are done safely to avoid
rupturing the pipeline.
27. COMMENT!
RESPONSE:
How might a resident get exposed to the
contaminated ground water?
Exposure to contaminated ground water could occur
by ingesting and/or inhaling chemicals in the
contaminated portion of the Old Bridge Aquifer.
Residents with private wells in the contaminated
portion of the Old Bridge Aquifer may be exposed
by drinking water and/or showering.
28. COMMENT!
RESPONSE:
How close to Manalapan Brook and Thompson Lake did
you test the ground water?
Ground water from a natural spring in Thompson
Park was tested on May 26, 1993. The spring is
1,000 feet west of Manalapan Brook and 1,000 feet
south of Lake Manalapan. No contamination above
the NJGWQC was found in the ground-water sample.
29. COMMENT:
RESPONSE:
What levels of contamination exists immediately
across Cranbury-South River Road?
The maximum contamination east of Cranbury-South
River Road was in monitoring well MW-6D at 890 ppb
of acetone. The NJGWQC for acetone is 700 ppb.
For a full review of all chemicals found in MW-6D,
please refer to the RI/FS report.
30. COMMENT:
RESPONSE:
What is the next step in the Superfund process?
Who selects the remedy?
After the public comment period is over, NJDEP
will review the comments received and respond to
them in the Responsiveness Summary. The
Responsiveness Summary is part of the Record of
Decision. The Record of Decision selects the
remedy after considering all the comments
received. It is a formal decision document which
is signed by EPA, with NJDEP concurrence. Once
this document is signed, NJDEP will approach the
PRPs and offer them a chance to implement the
rerredy. If they refuse, NJDEP will implement the
remedy and sue the parties for three times the
cost of the remediation (treble damages). Once it
is determined who will go ahead with the
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remediation, the Design Phase begins. This could
take a year or more. Construction of the actual
remedy may take two years or so. Of course, there
may be delays in any phase depending on weather,
unforeseen circumstances, etc. Optimistically,
the soonest the pump and treat of the ground water
would begin is approximately two years from now.
31. COMMENT:
RESPONSE:
Are there any current health risks or hazards
associated with the landfill right now, other than
the ground water?
The results of the Baseline Risk Assessment
indicate that the landfill itself does not pose a
risk to human health. However, the Baseline Risk
Assessment does show a risk associated with the
ground water.
32. COMMENT:
RESPONSE:
Who will oversee the construction of the remedy to
ensure that, it is performed correctly?
If PRPs conduct the remediation, there will be
government oversight during all phases. If public
funds are used, the NJDEP will hire all the
consultants and contractors, and will have daily
on-site presence during the construction. EPA
will also oversee this as well.
33. COMMENT
RESPONSE:
Will the construction contract for remediation go
to local contractors?
If NJDEP conducts the remedial action, NJDEP is
required to have open competitive bidding for the
work. Therefore, engineering firms from other
states are also eligible to bid for the work.
Most contracts are generally awarded to New Jersey
firms.
34. COMMENT:
RESPONSE:
Who are the PRPs involved in JIS?
At this time, the following parties are considered
PRPs by NJDEP. PRPs include generators and
transporters of hazardous waste disposed at the
landfill, as well as the owner and operator of the
JIS Landfill.
American Standard, Inc.
Applied Bioscience International, Inc.
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BASF Corporation
Beatrice Foods Company
Bio/dynamics, Inc.
Cities Services Company
Columbian Chemical Company
Columbian Carbon Company
Covino Trucking Company
Delco Remy Div. of General Motors
Dow Jones and Company, Inc.
FMC Corporation
Frederick H. Levey Company, Inc.
General Electric Company
General Motors Corporation
Hartz Mountain Corporation
Helme Tobacco Company
Higgins Disposal Service, Inc.
J.I.S. Industrial Service Company
J.I.S. Industrial Service Corp.
Johnson & Johnson, Inc.
Mobil Oil Corporation
Mobil Research & Development Corp.
Occidental Petroleum Corporation
Ortho Pharmaceutical Corp.
Patterson Sargent Company
Phelps Dodge Corp. .
Revlon, Inc.
Ronnie Packaging Company
Shell Chemical Company
Shell oil Company
Squibb Corp.
Teledyne Packaging/Turner Tube
Textron, Inc.
Thor Metals Company, Inc.
Triangle Industries, Inc.
Triangle PWC
Triangle Pipe and Tube Co., Inc.
Warner Lambert Co.
Webcraft Packaging
Webcraft Technologies, Inc.
Container Corporation of America
Index of Written Comments Received
Borrus, Goldin, Foley Vignuolo, Hyman & Stahl; Received 12/9/94
Township of Monroe, Environmental Commission; Received 12/26/94
Hartz Mountain Corporation; Received 12/27/94
Lorraine Orlando, William & Joan Herig,
Stuart & Mary Ann Hagerty, Residents; Received 12/27/94
Victor F. Janas, Resident; Received 1/30/95
A-2 Environmental, Inc.; Received 2/3/95
Environmental Resources Management, Inc.; Received 2/6/95
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Summary of Written comments
Comments received from Borus, Goldin, Foley, vignuolo, Hyman &
Stahl representing Jis Industrial Services, inc.
35. COMMENT:
RESPONSE:
The Public Notice advertisement had a limited
description of the Site Background and Current
Status.
Space limitations in the advertisement made a
brief description of the Site Background and
Current Status necessary. The purpose of this
description is to give the reader a general
overview of the site.
36. COMMENT:
RESPONSE:
On October 30, 1985, JIS submitted to NJDEP a
report prepared by French and Parrello Associates
concerning the closure and capping of the JIS
Landfill. The report concluded that, based on
their field testing and inspections, the landfill
closure conformed to NJDEP regulations. On
November 25, 1985, Richard Gauck of Van Note-
Harvey Associates confirmed the installation of
the clay cap overlined [sic] with six inches of
topsoil, with required permeability and thickness.
Numerous requests were made to NJDEP to inspect
and acceptance of the cap and closure. No
response was received.
These efforts by French & Parrello Associates, as
well as all other efforts by other firms hired by
JIS regarding the cap construction and integrity,
are summarized and evaluated in great detail in
Section 6.0 of the RI. This section of the RI
provides all of the concerns and problems with the
results of those reports. In addition, Black &
Veatch performed their own field investigation and
engineering evaluation of the landfill cap.
37. COMMENT:
RESPONSE:
We request that NJDEP compare JIS Landfill with
the closure at Monroe Township, South Brunswick
(BFI), and Jackson landfills, where NJDEP-approved
closure requirements were less stringent. The
Spillatore Landfill was not covered at all. The
same "liberality" applied to these landfills
should apply to JIS Landfill.
Remedies at NPL sites are selected on a site-
specific basis. Of the landfills mentioned, all
are on the NPL except the Spillatore Landfill.
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Volatile organic compounds (VOCs) are the
predominant contaminants at each of these
landfills. The ground-water contamination at JIS
is between 1 and 3 orders of magnitude greater [10
to 30 times greater] than the contamination at the
Monroe, South Brunswick, and Jackson Landfills.
Consequently, the preferred alternatives for the
JIS Landfill Site included a ground-water remedy
to address the contamination and upgrading the
existing cap. In order for the ground-water
remedy to be effective, the existing cap needs to
be upgraded to minimize the infiltration of
rainwater through the wastes in the landfill. The
RI estimated that the infiltration rate of the
existing cap is 3.3 million gallons per year.
Upgrading the cap would virtually eliminate
infiltration.
38. COMMENT:
RESPONSE:
The proposed remediation of the JIS Landfill
involves an area adjacent to the NJ Turnpike in
which the Colonial Pipeline has an existing right-
of-way for the maintenance of a 36-inch natural
gas pipeline. The proposed remedy could have
dangerous consequences in the disturbance of the
existing pipeline. This area should be avoided.
The Colonial Pipeline Company is aware of the
preferred remedial action. They do not have any
objections to the remedy outlined by the proposed
plan as outlined at the public meeting and the
Proposed Plan. The company requested that they be
kept informed with the progress of the remediation
effort.
Regarding the issue of risk associated with
remedial activities close to the pipeline, the
NJDEP will work closely with Colonial Pipeline
Company to ensure safety.
39. COMMENT:
In August 1984, JIS retained J.E. Rhodes
Consulting Engineers for the purpose of oversight
of the ground-water remediation project. In
February 1985, the firm of Paulus, Sokolowski and
Sartar completed an aquifer test for the project.
One of the conclusions of the study suggested that
contamination was being drawn to the site from
off-site sources. NJDEP never followed up on the
recommendation that monitoring wells be installed
off the JIS property across from the NJ Turnpike
to monitor ground-water contamination there.
14
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RESPONSE:
Black & Veatch did not investigate this area and
upgradient of JIS. All of these reasons support
our request that you use reason and deliberate
judgment in determining whether further
remediation is necessary at this time.
NJDEP considered the recommendation and installed
four upgradient monitoring wells off the site
across the NJ Turnpike: MW-1S, MW-1D, MW-14S, and
MW-14D. These wells were sampled and are clean,
indicating that no ground-water contamination is
moving onto the site from any upgradient sources
across the NJ Turnpike.
40. COMMENT:
RESPONSE:
41. COMMENT:
RESPONSE:
Is NJDEP presently investigating Black & Veatch
for past performance and reasonableness of
invoices?
See RESPONSE/COMMENT 1.
In July 1986, Mr. Rhodes completed the design of a
ground-water treatment facility for JIS. The
facilities were constructed and ready for
operation. A treatment system remained available
for immediate use in site remediation. Its use
would have dramatically reduced the off-site
migration of any contamination now alleged.
Despite the above action taken by JIS, at its
expense, NJDEP undertook the RI/FS which resulted
in the present public meeting.
JIS hired J.E. Rhodes to perform a pilot scale air
stripping test—a full scale ground-water
treatment system was never constructed or
operated. However, the NJDEP and EPA never
prohibited JIS or other PRPs from implementing
Intermediate Remedial Measures (IRMs) at their own
expense. Regardless of whether they implemented
IRMs or not, NJDEP and EPA were obligated under
CERCLA to proceed with the RI to characterize the
nature and extent of the contamination if PRPs
chose not to.
42. COMMENT:
RESPONSE:
Recent on-site (JIS) monitoring well results show
no detectable VOCs above acceptable limits. We
question the need for expensive remediation.
JIS has not submitted any ground-water sampling
and analytical information to NJDEP to verify the
15
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results. We do not know the location of the wells
from which the samples were taken. The wells
could be located sidegradient from the contaminant
plume, which would explain why no contamination
was detected. We also do not know what chemicals
the samples were analyzed for, whether the
analytical methods were equivalent to NJDEP's, and
whether the sampling followed NJDEP's Quality
Assurance and Quality Control (QA/QC) protocol.
JIS did not sample any of the NJDEP wells,
therefore a comparison can not be made. The RI
sampling indicates significant ground-water
contamination above Federal and/or New Jersey Safe
Drinking Water Act Maximum Contaminant Levels
(MCLs) at the site, justifying the need for a
remedial action.
43. COMMENT:
RESPONSE:
The assumptions regarding ground-water
contamination are stale and date back to sampling
performed in July 1991. Out-of-date sampling
results should not form the basis for the present
remediation plan which is duplicative, expensive,
and unnecessary.
The data is not considered "stale" by NJDEP and
EPA. The Proposed Plan is based on RI data
collected between 1988 and 1991, plus additional
data collected from Hydropunch and potable well
samples collected during 1993. All of this data
was collected and analyzed in accordance with EPA
and NJDEP QA/QC requirements. Also, additional
sampling will be conducted in the future during
the Design/Construction phases, and a long-term
monitoring program will start at the completion of
the construction phase. Data collected during
these activities may be used to suggest
modifications to remedial activities at the site,
if warranted.
44. COMMENT!
The NJDEP approved the remediation of the Jackson
Township Landfill which was larger and without a
cap and involved a greater risk to surrounding
residences than JIS. Why is the NJDEP requiring a
much more stringent remediation plan for JIS? We
request that NJDEP utilize the information and
test results available to consider a
discontinuance of any further remedial action in
connection with this project, which will only
serve to unnecessarily increase the costs
associated with the RI/FS [sic].
16
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RESPONSE:
The ground-water quality at the Jackson Landfill
meets the State's ground-water standards. In
other words, there was no ground-water
contamination, and consequently, no risk. A soil
cap was placed on the site, since contaminants
were not migrating into the ground water. The ROD
called for "no further action".
In contrast to Jackson Landfill, ground-water
contamination at JIS Landfill poses an
unacceptable risk to human health and the
environment, therefore, a remedial action is
required.
Comments.received from Monroe Township Environmental Commission
45. COMMENT!
RESPONSE:
The Environmental Commission of Monroe Township
supports the NJDEP and EPA proposed
recommendations concerning the JIS Landfill site:
Source Control Alternative SC-6 (Modified NJDEP
Hazardous Waste Cap), and Ground-Water Alternative
4 (Primary Plume Capture and Treatment, and
Provision of Alternative Water Supply). The
proposed remedy offers practical, permanent
solutions, yet remain open to the possibility of
having to take more aggressive action.
The NJDEP appreciates the support of the
Environmental Commission of Monroe Township.
Comments received from Hartz Mountain Industries
46. COMMENT:
RESPONSE:
The Modified NJDEP Hazardous Waste Cap is
estimated to eliminate approximately 99.9% of
infiltration into the landfill. NJDEP also
evaluated repair of the 1977 Cap, and upgrading
the 1977 Cap (Augmented 1977 Cap). The 1977 Cap
will eliminate approximately 92% of the
infiltration; the Augmented 1977 Cap will
eliminate 94% of the infiltration. No cost
benefit or risk/benefit analysis has been
performed to determine whether the additional 1 to
1.4 million dollar cost of the preferred remedy is
justified by the marginal (5 to 7%) decrease in
infiltration into the landfill.
Cost effectiveness was considered in the selection
of the preferred alternatives. The Modified NJDEP
Hazardous Waste Cap is the preferred alternative
because it provides the greatest reduction in
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infiltration and it is light in weight.
Minimizing the infiltration rate makes the ground-
water remedy more effective. Although the 1977
Cap and the Augmented 1977 Cap both offer greater
than 91% reduction in infiltration, the Modified
NJOEP Hazardous Waste Cap was selected among the
source control alternatives because it protects
against freeze and thaw damage, offering greater
long-term effectiveness and reliability than the
1977 Cap and the Augmented 1977 Cap. (See
COMMENT/RESPONSE 49 for a discussion on risk/
benefit analysis).
47. COMMENT:
RESPONSE:
Any final decision on remedy selection and
implementation should be held off until the
reauthorization of CERCLA. The reauthorization
may change the assumptions and legislative
guidelines on which NJDEP's proposed remedy is
based. This would eliminate the need to revisit
these issues at a later time.
There is no authority to defer remedy selection
an NPL site until Congress reauthorizes CERCLA.
The timing of reauthorization is not certain.
48. COMMENT:
RESPONSE:
Given that the 1977 cap does exist, and is likely
to be upgraded, simple placement of a synthetic
liner over the 1977 cap may accomplish the same
purpose as the Modified Hazardous Waste Cap at a
lower cost. This alternative should be evaluated
before any decision is made.
While the simple placement of a synthetic liner
over the existing cap may improve impermeability,
it is not a sufficient remedy in and of itself.
Protection of a synthetic liner and the clay layer
below it can only be attained by appropriate
surface water drainage and frost protection layers
that are called for in the preferred remedy. The
reason the existing cap is in such bad shape is
the lack of adequate cover material over the clay.
This has lead to degradation by the elements from
improper surface drainage, the inability for
vegetation to grow on the cap, and freeze and thaw
action.
49. COMMENT:
A risk/benefit analysis should be performed to
determine whether the incremental elimination of
health risk justifies the anticipated high capital
18
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RESPONSE:
expenditure associated with active ground-water
remediation.
The Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) and the
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) do not require risk/benefit
analyses. However, they do require remedies
selected at NPL sites to be cost-effective. In
addition, CERCLA and the NCP do indicate that
cleanup is necessary when the excess cancer risk
associated with an NPL site exceeds the acceptable
risk range of between 10"4 and 10"6 risk. The
excess cancer risk associated with this site is
3 x lO"3, which is outside the acceptable range,
therefore, requiring a remedial response. NJDEP
has evaluated the risk to human health and the
environment in the Baseline Risk Assessment and
evaluation of the various costs of different
remedial alternatives in the Feasibility Study as
required by CERCLA and the NCP, and have proposed
the most cost-effective remedy.
50. COMMENT:
RESPONSE:
Any ground-water remediation selection abide [sic]
installation of the selected cap, and evaluation
of its source control effectiveness. Once the
source has been minimized or eliminated, natural
attenuation may address ground-water contamination
in the primary and secondary plume, thereby
minimizing or eliminating the need for capital
intensive ground-water remediation. CERCLA
requires reevaluation of any remedy every five
years, so continued monitoring will be an integral
part of any capping remedy. We believe that the
foregoing approach is sound, since all potable
uses of the contaminated portion of the aquifer
have been eliminated; well restrictions will be
imposed on any future use; and no ongoing threat
to public health or the environment presently
exists.
The capping remedy, in and of itself, would not
adequately protect human health and the
environment because contaminants in the ground
water would continue to migrate off site.
Contaminant levels in the primary plume are
significantly above MCLs. Not implementing a
ground-water remedy would not reduce the risks to
downgradient users of ground water since there are
no restrictions prohibiting the use of the Old
Bridge Aquifer as a source of drinking water. In
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addition, the high levels of metals contamination
in the primary plume are not likely to naturally
attenuate.
Comments received from Lorraine Orlando/ William & Joan Herig/
Stuart & Mary Ann Hagerty; Residents
51. COMMENT:
RESPONSE:
Our drinking water wells were contaminated. We
independently paid to have our water tested and
pressured local governing boards to investigate
and to check the direction and quality of the
ground water. We gave up using the wells and
bought water into our homes for drinking. We
continued our pleas to out township for municipal
hook up to avoid using our wells. Finally, in
1982, water service was brought into our area,
costing each of us over $1,500 in expenses to hook
up to the water line. We support any efforts by
NJDEP to improve the situation at the site. We
have suffered as a result of hazardous dumping
that went unchecked at the JIS Landfill and
incurred prematurely great expense to protect our
families. We feel some compensation is due since
we were affected by this terrible landfill and
should be made at this time. We look to the
Superfund for relief.
The New Jersey Spill Compensation Fund and/or the
Sanitary Landfill Closure Fund both provide for
compensation to people who suffered damages from
hazardous waste sites, spills or landfills.
However, there are specific rules governing these
funds. You may contact the NJDEP Environmental
Claims Administration at (609) 633-2947 for more
information.
Comments submitted by Victor F. Janas/ a resident
52. COMMENT:
RESPONSE:
What are the exact locations of monitoring wells
DGW 9, 10 and 11?
These wells are not monitoring wells, but private
wells. All three wells were sampled once and have
since been sealed or abandoned and thus are
inaccessible for further sampling. DGW 9 was
located at 109 Bordentown-South Amboy Turnpike;
DGW 10 was located at 106 Bordentown-South Amboy
Turnpike; and DGW 11 was located at 33 Bordentown-
South Amboy Turnpike.
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53. COMMENT!
RESPONSE:
When were monitoring wells DGW 9, 10 & 11 tested,
and for what parameters? What are the levels of
contamination detected?
These three wells were sampled on March 14, 1991
for total metals and volatile organic compounds.
VOC concentrations ranged from 1-47.1 parts per
million (ppm) in DGW 9.; no VOCs were detected in
DGW 10; and VOC levels ranged from 0.9-1.9 ppm in
DGW 11. The concentrations of metals detected
ranged from: 5.6-10,600 ppm in DGW 9; 3.8-408 ppm
in DGW 10; and 4.8-49.7 ppm in DGW 11. The levels
of metals detected in DGW 10 and 11 are not a
concern because they are below health-based
levels. For details of the analytical results of
this sampling, please see the RI/FS.
54. COMMENT!
RESPONSE:
Have DGW 9, 10 & 11 been sampled more than once?
If so, are the levels of contamination increasing,
decreasing or staying constant with time?
DWG 9, 10, and 11 were sampled only once, during
the RI. These private wells were subsequently
closed; therefore, a trend cannot be determined.
55. COMMENT:
RESPONSE:
Between 1984 and 1988, the Monroe Township Health
Department found contamination in the wells of
residents in the vicinity of Bordentown Turnpike.
Have these wells been monitored since? If yes,
are the levels increasing, decreasing, or
remaining the same?
From 1984 to 1988, the Monroe Township Health
Department sampled private water supply wells for
the township residents. Many of the residents in
the vicinity of Bordentown Turnpike, downgradient
from the landfill, had contaminated drinking
water. EPA provided these residents with bottled
water from June 6, 1989 until they were
permanently connected to the municipal water
system in February 1992. The contaminated private
wells were closed and were not accessible for
subsequent sampling. Therefore, a trend cannot be
determined.
56. COMMENT:
At the December 7, 1994 public meeting, a
representative of JIS said he has his own test
results indicating that either there is no
problem, or the problem has been blown out of
21
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RESPONSE:
proportion by the NJDEP consultant, or that the
problem was not caused by JIS, but by other
companies in the area. Mr. Putnam indicated that
he was unaware of the data, though the JIS
representative indicated he had tried to get NJDEP
to look at it. Was the data available as Mr.
Jones indicated and, if so, why was this data
dismissed by the NJDEP? Where can a copy of JIS's
test procedures and results be obtained?
During the RI, Mr. Jones did submit some limited
ground-water data which included total dissolved
solids, biochemical oxygen demand, chemical oxygen
demand, chloride, and concentrations of a few
select metals and chemicals. We do not know
whether the samples were collected in accordance
with the appropriate protocols, or whether the
results complied with NJDEP's QA/QC requirements.
NJDEP told Mr. Jones that this data was not useful
for the RI because it did not contain information
on the full range of contaminants in the ground
water.
NJDEP installed monitoring wells upgradient from
the JIS Landfill. Sampling results of these wells
do not indicate that upgradient industrial sources
are contributing to the ground-water contamination
at JIS.
All NJDEP test procedures and results are
available in the Phase I and Phase II RI reports
for the JIS Landfill. NJDEP does not have all of
the JIS data. To get a copy of JIS's test
procedures and results, you need to contact Mr.
Jones directly.
57. COMMENT:
RESPONSE:
Water has been observed bubbling up in the
basement of homes in the "Meadows at Monroe"
development in Monroe Township after severe rain
storms. Could this water be contaminated? Will
residents who collect this water and have it
tested by an independent lab be reimbursed for the
cost?
Because the basements at the "Meadows at Monroe"
development flood only after severe rainstorms and
not at other times, NJDEP believes that the water
is most likely rainwater due to poor drainage, and
is not related to the JIS Landfill. NJDEP does
not believe this water is contaminated because the
"Meadows at Monroe" development are located
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sidegradient from the contamination plume. In
addition, no VOC contamination was found in
Downgradient Well DGW 10, which is the closest
well to the "Meadows at Monroe" development.
NJDEP will not reimburse residents for the cost of
sampling this water. We suggest that residents
contact the local health department regarding the
testing of this water.
58. COMMENT:
RESPONSE:
How thick is the affected aquifer under the
"Meadows at Monroe" development? Are sewer and
water lines for this development sitting in the
aquifer? How far below the houses does the
contamination lie?
The Old Bridge Aquifer is between 70 to 90 feet
thick. NJDEP does not know where the sewer pipes
and water lines are located in relation to the
ground-water table at the "Meadows at Monroe"
development. As explained in the previous
response, NJDEP does not believe that the ground
water underneath the Meadows at Monroe development
is contaminated.
59. COMMENT:
RESPONSE:
Will the NJDEP test the area of the "Meadows at
Monroe" development to determine/confirm the depth
and/or level of contamination below this
development? To which state agency could a
resident of this development make such a request?
Because NJDEP does not have any indication on
ground-water contamination based on sampling data
from Downgradient Well DGW 10, there is no need to
test the ground water beneath the "Meadows at
Monroe" development.
60. COMMENT:
RESPONSE:
Alternative SC-6 requires a waiver of the capping
requirements of the Resource Recovery and
Conservation Act (RCRA) Subtitle C and New Jersey
Hazardous Waste Landfill Closure Regulations (NJAC
7:26-10.8(1)2). Is this design with a similar
waiver being used anywhere in the United States?
Is this design considered experimental?
The cap design preferred for the JIS Landfill is
not experimental. Very similar capping systems
are being designed for other landfill sites on the
NPL in New Jersey. The cap outlined for the JIS
Landfill in the Proposed Plan used the Global
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Landfill cap as its model. A waiver of the
capping requirements of New Jersey Hazardous Waste
Landfill Closure Regulations (NJAC 7:26-10.8(i) 2)
was invoked in the 1991 Record of Decision for the
Global Landfill.
61. COMMENT:
RESPONSE:
Will Alternative GW-4 capture and treat the
leachate that continues to leach from the landfill
after it is capped? How long will the landfill
waste continue to leach into the aquifer after the
cap is completed?
Alternative GW-4 will capture and treat all of the
contaminated ground water in the primary plume.
Alterative SC-6, the modified NJDEP Hazardous
Waste Cap, will decrease the permeability of the
existing cap, resulting in a decrease in the
amount of rainwater infiltrating into the
landfill, eventually drying it out, and
eliminating the leachate source. During the
design, an estimate will be made to determine how
long it will take for the cap/pump and treat
system to remediate the primary plume. However,
this value cannot be accurately estimated at this
time.
62. COMMENT!
RESPONSE:
If CERCLA requires a No Action alternative be
evaluated for comparison of other alternatives,
why doesn't it require the comparative evaluation
of upper end alternatives such as GW-7, capture of
the entire ground-water plume? What is the
standard dollar amount used to determine if an
alternative is too costly?
CERCLA requires that a No Action alternative be
evaluated at every site to establish a baseline
for comparison to the other alternatives.
There is no standard dollar amount used to
determine if an alternative is too costly.
alternative is evaluated according to its
effectiveness.
Each
Cost was not the only problem with the entire
plume capture remedy. The concerns with entire
plume capture were also technical efficiency and
practicality. Capture and treatment of the entire
plume would require extracting a large volume of
water at relatively low levels of contamination
that will likely naturally attenuate. However,
24
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NJDEP will be further monitoring the secondary
plume. Active aquifer restoration alternatives
will be evaluated to address the contamination in
the secondary plume should the time period to
achieve the cleanup levels exceed NJDEP's and
EPA's expectations, or in the event that natural
attenuation is found to be no longer protective of
human health and the environment.
63. COMMENT;
RESPONSE:
According to the Implementability Criteria for
Alternative Evaluation, the steepness of the
landfill sideslope and the presence of the 36-inch
gas pipeline may make the implementation of SC-6
difficult. Could that section of the landfill be
removed and hauled to a properly designed landfill
until the steep side slope and pipeline risks are
reduced?
Yes, removing a portion of the landfill is an
option, however, removal of the landfill material
would be difficult to do. Excavation of material
for off-site handling will trigger requirements
under the Resource Conservation and Recovery Act
(RCRA), which would result in additional effort,
added cost, and likely prove impractical due to
Land Ban Restrictions under RCRA. It is generally
against NJDEP policy to dig up a problem and just
move it to another location.
If the steepness of the landfill sideslope makes
it impossible to implement the remediation as
proposed, the NJDEP will pursue rerouting the
pipeline.
64. COMMENT:
RESPONSE:
I do not agree that the NJDEP is handling this
site in a timely manner, as was stated at the
December 7, 1994 public meeting given that the
problem was first discovered in 1975.
See COMMENT/RESPONSE 13.
Comments received from A-Z Environmental/ Inc./ representing Mr.
Donald Jones and JIS Landfill
65. COMMENT:
Water quality is measured routinely in four
existing on-site JIS monitoring wells since 1976
as part of the New Jersey Pollution Discharge
Elimination System (NJPDES) permit. Assuming,
historically, that the sampling data from the
25
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RESPONSE:
monitoring wells met NJDEP QA/QC criteria, the
data should be comparable to those of NJDEP
analyses. Was the water quality data from the
NJPDES permit and split samples weighed in
assessing ground-water quality? If the results
from additional tests show a similar pattern, it
is doubtful that the pump and treat option will
produce a significant improvement in ground-water
quality over the background levels. NJDEP should
compare the background levels in the immediate
vicinity to those found on site and also to the
background levels in the vicinity of neighboring
industrial sites such as BASF and Phelps-Dodge.
NJDEP installed four upgradient monitoring wells
off the site across the NJ Turnpike to determine
background (MW-1S, MW-1D, MW-14S, and MW-14D).
These wells were sampled and are clean, indicating
that no ground-water contamination is moving onto
the site from any upgradient sources across the NJ
Turnpike.
With respect to water quality data from the JIS
monitoring wells, NJDEP cannot compare the JIS
data to the RI data because we cannot assume that
the sampling data complied with NJDEP QA/QC
requirements. In addition, we do not know the
location of the JIS wells that were sampled.
Water quality data submitted with JIS's NJPDES
permit application was not considered in assessing
ground-water quality for the site for the
following reason. JIS did not submit complete
documentation of its ground-water sampling and
analysis effort, which was performed in 1982.
Therefore, we cannot verify whether the sampling
was performed in accordance with NJDEP protocols,
or whether the sampling results complied with
NJDEP QA/QC requirements.
66. COMMENT: Was the source and nature of the green color in
the ground water from MW-18I ever identified?
RESPONSE:
The green color in the ground water is fluorescein
dye. This dye was reported to have been used in a
ground-water tracer test at JIS in the early
1960s. It is not considered hazardous.
67. COMMENT:
The water from MW-18I was allegedly pumped into
DEP MW-1. Given the relative depth of DEP MW-1,
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RESPONSE:
this pumping may have caused contamination of the
deep aquifers and contaminated DEP MW-1.
MW-18I, sampled during the Phase II Remedial
Investigation, contained a total of 15 ppb VOCs.
PW-l was screened in the lower Old Bridge Aquifer.
Downgradient of PW-l, and also screened in the Old
Bridge, are MW-7D and MW-6D. These wells were
also sampled during the Phase II RI and contained,
respectively, 299 ppb and 890 ppb total volatile
organic compounds. Results from these two wells
show that the lower Old Bridge Aquifer,
downgradient of PW-l, is much more contaminated
than ground water taken from MW-18I. Therefore,
the incident which is the subject of this comment
would not increase the contamination in that part
of the aquifer. See COMMENT/RESPONSE 8.
68. COMMENT:
RESPONSE:
The existing cap was built in 1984 and completed
in 1985, when Mr. Jones requested NJDEP approval.
However, the request was neither denied nor
granted at any time. The finding that the present
clay (cap) on the landfill did not meet the NJDEP
criteria at the time of construction was never
communicated to either Mr. Jones or his consulting
engineers.
The finding that the current cap does not meet
current NJDEP criteria was made after the RI was
completed in 1993. Mr. Jones was notified that
the results of the RI, which included an
evaluation of the existing landfill cap, were
available. The RI report and data were placed in
the information repositories in September 1993.
Even if NJDEP had approved the cap in 1985, it
would not change the selection of the preferred
alternatives. The existing cap is being upgraded
to make the ground-water remedy more effective by
minimizing the infiltration of rainwater through
the wastes in the landfill. The RI estimated that
infiltration rate of the existing cap is 3.3
million gallons per year. Upgrading the cap would
virtually eliminate infiltration.
69. COMMENT:
The finding that the present clay and its
thickness does not meet NJDEP criteria contradicts
the engineer's report (Van Note-Harvey Associates,
November 26, 1985 and April 3, 1987).
27
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RESPONSE:
NJDEP reviewed the Van Note-Harvey Associates
report and found deficiencies (see Section 6.0 of
the RI). NJDEP does not know the nature of the
discrepancy between the Van Note-Harvey report and
NJDEP's cap evaluation, but believes that the clay
and soil layers may have reduced in thickness due
to settling and erosion.
70. COMMENT;
RESPONSE:
The NJDEP has not presented any data which
supports the claim that the present clay cap is
not capable of withstanding freeze and thaw
conditions, jeopardizing the cap integrity.
It is common engineering knowledge that the frost
line is between 18 inches and 24 inches below the
surface in this region. Freeze and thaw
protection less than 18 inches will affect
geologic material by creating cracks. The RI
confirmed that the existing cap system does not
have a uniform minimum of 18 inches of cover
material over the clay layer in a large portion of
the landfill. Ponded water on che surface is also
evidence of improper storm water drainage control.
71. COMMENT:
RESPONSE:
NJDEP should reevaluate the issue of adequacy of
the present clay cover, and alternative solutions
should be investigated in terms of effectiveness
and cost.
The FS and the Proposed Plan evaluated the
adequacy of the existing clay cap; part of the
evaluation included effectiveness and cost. The
decision to implement the 1977 Solid Waste Cap was
based on limited information. Since that time, a
thorough investigation has been performed and
completed. The results of the investigation
concluded that the waste disposed of at the site
would be considered hazardous under current
standards.
72. COMMENT: The ground-water contamination plume has migrated
at the rate of 1.2 feet per day (ft/day) and is
therefore 1.4 miles off site since its discovery,
not 12 miles as reported by the NJDEP.
RESPONSE:
NJDEP did not report that the ground-water
contamination plume is 12 miles from the JIS
Landfill site. A member in the audience at the
public meeting incorrectly stated that the plume
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extended 12 miles. By straight calculation,
assuming that landfilling operations began in
1965, the plume should extend approximately 2.5
miles from the landfill at this time. However,
this has not been verified by ground-water
sampling data.
Comments received from Environmental Resources Management/
consultant for committee of potentially responsible parties.
73. COMMENT:
RESPONSE:
JIS is erroneously linked to contamination of
domestic wells. The distribution and types of
compounds point to a local source near the
domestic wells.
i. There is no rational basis for attributing
chemical constituents in the domestic wells to JIS
in view of the low concentrations of chemical
constituents in the off-site monitoring wells at
JIS.
ii. The higher concentrations of chlorinated
organic compounds in the domestic wells indicate
that there is a local source in the vicinity of
the Bordentown Turnpike.
iii. The presence of similar constituents at JIS
and in the domestic wells does not demonstrate a
correlation between the two occurrences.
iv. Acetone, methylene chloride and chloroform
detections in the monitoring wells could result
from contamination in the laboratory by these
common laboratory contaminants. The RI and
Baseline Risk Assessment do not acknowledge this
possibility. During the earlier NJDEP
investigations, laboratory blanks were not
included, which would have allowed laboratory
contaminants to be identified. The lack of the
blanks departs from accepted laboratory practices.
v. An analysis of the historical data using
ground-water modelling demonstrates that JIS could
not have been the source of contamination reported
in the domestic wells.
The following discussion explains the rationale
why NJDEP believes that the contamination in the
domestic wells is attributed to JIS.
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i. NJDEP believes there is a rational basis for
attributing the contamination in the domestic
wells to JIS Landfill. The landfill began
operating in 1962, and capped between 1980 and
1985. NJDEP believes that ground-water
contamination detected in downgradient private
wells is the result of contaminant migration from
the JIS Landfill prior to capping, especially
since the contaminants in the downgradient private
wells are similar to the contaminants detected in
the primary plume.
ii. NJDEP believes that the higher concentration
of contaminants in downgradient private wells
originated from JIS over the 18 years of its
operation. This is demonstrated in the Secondary
Plume Model in the RI (see Figure 5-10 of the RI).
iii. Twenty-one VOCs were detected in the ground
water at JIS and 22 in the residential wells. Of
the 22, 18 VOCs were also detected in the ground
water at JIS. This is a very high correlation.
iv. Laboratory and field blanks were used during
all phases of the RI (see Tables 4-5 and 4-10 in
the RI report). Where the monitoring well results
were less than three times the amount found in the
associated field and/or lab blanks, the results
were negated. In addition, when concentrations
are between 3 and 5 times the blank concentration,
or greater than 5 times the blank concentrations,
then the sample result is designated as
"qualified" or "real," respectively. Both
"qualified" and "real" data are usable. This
occurred in several samples where methylene
chloride and acetone were found, but no chloroform
results were negated.
v. No information was provided on the ground-
water model that was used, the inputs, variables,
and parameters. Therefore, NJDEP cannot comment
on the accuracy of the model.
74. COMMENT:
RESPONSE:
NJDEP's ground-water modeling results are
inconclusive and biased.
While the ground-water modeling performed by
NJDEP's contractor was based on limited
information, NJDEP believes that the results are
indicative of the existing conditions. In
addition, monitoring wells will be installed in
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the area of the secondary plume during remedial
design, and the additional data from these new
wells should further refine the ground-water model
at the site. Regardless, the results of the model
are not driving the selection of the preferred
remedy of the cap upgrade and primary plume pump
and treat.
75. COMMENT:
RESPONSE:
NJDEP has over stated the contaminant migration
rate. A fluorescein dye tracer study was
performed at JIS Landfill by the New Jersey Bureau
of Public Health and Engineering from May 1958 to
May 1959. Data shows that the fluorescein dye has
migrated only 1,200 feet in approximately 33
years. This slow migration rate suggests that any
constituents migrating from JIS could not have
reached the domestic wells since the landfill
opened.
The data do not show that the dye has migrated
only 1,200 feet, but that it has migrated at least
1,200 feet. Fluorescein dye was found in MW-18I,
which is 1,200 feet from the landfill. Since
there presently are no monitoring wells located
more than 1,200 feet downgradient from the
landfill, there is no way of knowing how far the
dye has actually moved. Furthermore, we do not
know whether there have been subsequent
fluorescein dye tests.
76. COMMENT:
RESPONSE:
NJDEP uses different ground-water flow directions
in arriving at its conclusions. NJDEP erroneously
concluded that ground water flowing from JIS in a
south-southeasterly direction could have reached
DGW 7 and the ladeveia Nursery which are located
due east of JIS. Low concentrations in the
nursery well could indicate that the pumping well
may be recovering clean water from the direction
of JIS (from the west) and contaminated water from
the domestic well area to the east. The lower
concentrations could be the result of mixing of
water drawn from these two directions.
The general ground-water flow is in a south-
southeasterly direction. However, localized
lateral dispersion of the ground-water plume (to
the northeast) as it progresses in a southeasterly
direction, may have caused the contamination in
the ladeveia well. In addition, heavy pumping
over the years for irrigation at the ladeveia
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nursery (and possibly other area nurseries) could
have pulled the contaminant plume towards the
north. This conclusion is based on NJDEP's
technical evaluation of the data available. JIS
has not provided any ground-water data that proves
an error was made.
77. COMMENT!
RESPONSE:
Concentration trends in Mr. Smith Jr.'s and nearby
domestic wells suggest a nearby source of chemical
constituents. NJDEP has not conducted a
comprehensive investigation to identify potential
sources of contamination reported in the domestic
wells. NJDEP ignored the fact that there are
several potential chemical constituent sources in
the vicinity of the domestic wells, including:
Mott Avenue Landfill, ladeveia/Schneider Landfill,
Fabcoa, former septic tank scavenger (Sanfords),
and Mr. Smith Senior, who has been cited by the
Middlesex county Health Department for illegally
dumping wastes on his property.
A comprehensive investigation was conducted by the
NJDEP from 1984 to 1989 into the source of the
pollution found in private wells at the Smith
residence. The investigation included all of the
potential sources mentioned. NJDEP concluded that
the JIS Landfill was the source of the
contamination in those wells based on its review
of the information gathered during the
investigation. Ground-water modelling in the RI
indicated that JIS Landfill is the likely source
of contamination in the secondary plume.
NJDEP does not believe that the contamination at
DGW 11 is attributable to the Mott Avenue Landfill
because DGW 11 is located sidegradient from the
Mott Avenue Landfill. The ladeveia/Schneider
Landfill is located between DGW 8 and DGW 9. DGW
8 and DGW 9 are sidegradient from the ladeveia/
Schneider Landfill, therefore, contamination in
these wells is not attributable to the ladeveia/
Schneider Landfill.
78. COMMENT:
The 1977 Solid Waste Cap provides adequate
protection.
a. The capping alternatives for a solid waste
landfill are applicable to the JIS site.
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b. The capping requirements in the Proposed Plan
are not consistent with the FS report.
c. The estimated costs for the potential
retaining wall along the NJ Turnpike edge of
the site are unrealistically high, and
should be reevaluated and documented by
NJDEP.
RESPONSE: a. NJDEP and EPA believe that the Modified NJDEP
Hazardous Waste Cap is the appropriate cover
system for the JIS Landfill site. The
Modified NJDEP Hazardous Waste Cap is the
preferred alternative because it provides the
greatest reduction in infiltration and is
light in weight. In addition, hazardous
wastes were disposed at the JIS Landfill.
b. The capping requirements in the Proposed Plan
differ slightly from the capping requirements
in the FS because the cap designs in the FS
considered recompacting the existing clay
layer. The capping requirements in the
Proposed Plan reflect cap design requirements
specified by NJDEP and EPA guidelines for
landfill closure, which assume that no cap
exists. The capping alternatives in the
Proposed Plan show the differences in the
clay layers among the various caps, which
allow for a technical comparison of cap
components.
c. The cost for the potential retaining wall
will be reevaluated during the design phase
of the project. If the cost is overly
conservative, the results would be that the
alternative is more cost effective and
therefore, supportable.
79. COMMENT: NJDEP1s selection of the ground water treatment
components is premature. The ground-water
treatment system should not be finalized until
treatability studies have been completed. A
review of the ground-water chemistry indicates
that the metals precipitation may not be
necessary.
RESPONSE: The ground-water treatment system design is not
finalized, and may be adjusted in the design phase
if warranted.
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80. COMMENT: NJDEP has overstated the level of risk.
a. The Risk Assessment erroneously fails to take
into account decreases in contaminant
concentrations between 1988 and 1991.
b. Neither degradation nor fate and transport
mechanisms are accounted for.
c. Risk is grossly overestimated due to reliance
on data which is not representative of the
site.
d. Many constituents identified are common
laboratory contaminants present at less than
ten times the laboratory blanks or blanks
were not included with samples.
e. The Risk Assessment erroneously incorporates
data from domestic wells which are not linked
to JIS.
RESPONSE: a. The risk assessment for the JIS Landfill site
was conducted in accordance with EPA's Risk
Assessment Guidance for Superfund, which does
not require a trend analysis to be taken into
consideration to determine risk. The
selection of the preferred alternative, which
actively remediates the primary plume, did
take into consideration the fact that
contaminant concentrations appear to decrease
in concentration with distance from the
landfill, and that over time the contaminant
concentration within the secondary plume will
decrease through natural attenuation.
b. See response to (a) above.
c. Downgradient private well data used in the
Baseline Risk Assessment is representative of
the ground-water contamination that an off-
site resident may be exposed. Risk
assessments are inherently conservative, and
consequently, may overestimate the level of
risk.
d. While some constituents identified are lab
contaminants, they are also contaminants that
may have been disposed of at the landfill
site. The "10 times" criteria mentioned is
not used by the NJDEP in evaluating data.
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NJDEP uses the "5 times" criteria as
previously stated.
e. NJDEP and EPA believe that private well
contamination is attributable to the JIS
Landfill site, and therefore, it is
appropriate to use this data in the Baseline
Risk Assessment.
81. COMMENT: There are significant errors in the Proposed Plan:
a. The only confirmed concentration reported for
copper is 30.4 ppb in upgradient well MW-14S.
All other reported levels in downgradient
wells are labelled with a "B" qualifier
indicating the data is invalid. Based on
this information, copper should not be
identified as a ground-water contaminant in
the primary plume.
b. NJDEP erroneously concluded that lead was a
msijor contaminant at the JIS site. The lead
concentration detected in upgradient well MW-
14S (16.5 ppb) exceeds the range of lead
levels detected in all wells located within
the primary plume (13.5 to 3.3 ppb) except
for the total lead concentration detected at
well MW-5 (90 ppb), located approximately 400
feet downgradient of the landfill. Also,
lead was not detected in the sample collected
from well MW-5, which was analyzed for
dissolved lead. Total lead analyses include
lead sorbed to suspended soil particles
collected in ground-water samples from
monitoring wells which have not been
extensively developed to remove particulate
matter. As a result, total lead analyses for
samples from monitoring wells often show
elevated concentrations of lead which would
not be present in potable water producing
wells. In a producing well, dissolved
constituents are generally present at much
lower concentrations and would be the only
constituents of primary concern. Thus, at
JIS, the dissolved lead analyses should be
the only results considered when judging
whether lead concentrations in the ground
water are of concern at the site.
c. The Proposed Plan incorrectly states that the
highest concentration of total VOCs detected
35
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in the primary plume was 30,558 ppb. This
total includes 3,000 ppb of acetone, which
was "B" qualified. This value is invalid and-
should not be included in the summation of
organic compounds. The highest concentration
should be 27,558 ppb.
RESPONSE: a. Copper was found in 10 monitoring wells in
the Phase -I sampling, with a maximum
concentration of 91 ppb in MW-4. "B"
qualified data are not invalidated. Copper
is not a contaminant of concern at the JIS
Landfill site because the levels are below
MCLs. However, copper is a contaminant
because it is not naturally occurring in the
ground water.
b. The NJGWQC for lead (total) is 5 ppb.
Fifteen monitoring wells at JIS exceed the
NJGWQC for lead, with a maximum of 90 ppb in
MW-5. EPA's policy is to use unfiltered
ground-water sampling data.
c. The 3,000 ppb of acetone was included in the
total concentration of VOCs because "B"
qualified results were not negated. A "B"
qualified result indicated that the compound
was also found in the associated blank, but
at a level greater than 3 times the level in
the blank. Only an "X" qualified result,
indicating that the result was less than 3
times the amount found in the associated
blank, was negated. Therefore, the 3,000 ppb
of "B" qualified acetone was included in the
total VOCs, and the correct number is 30,558
ppb total VOCs.
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ROD FACT SHEET
SITE
JIS Landfill Site
South Brunswick, New Jersey
II
45.14 (8/17/82)
NJD097400998
Name :
Location/State :
EPA Region :
HRS Score (date):
Site ID # :
ROD
Date Signed: August 15, 1995
Remedy/ies: Containment, treatment, alternative water supply
Operating Unit Number: OU-1 (first and final)
Capital cost: $7.2 million (in 1992 dollars)
Construction Completion: 12/1998 (anticipated)
O & M in 1995-98: $0
1999: $978,300 (in 1992 dollars)
2000-29: $556,900 (in 1992 dollars)
O&M per five-year review: $13,000 (in 1992 dollars)
Present worth: $14.3 MILLION (7% discount rate; 30 years O&M
assumed)
LEAD
State Lead (may be PRP lead pending negotiations)
Primary contact (phone) : Zoe Kelman (609-633-0769)
Secondary contact (phone) : Richard Ho (212-637-4372)
Main PRP(s) : JIS Executive Committee
PRP Contact (phone) : Carpenter, Bennett & Morrissey 201/628-
7711
WASTE
Type:
Medium:
Origin:
Est. quantity:
Metals, VOC
Soil & ground water
Landfill
Unquantifiable
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