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During. the time that the Drew Company used the site for waste
disposal, complaints about objectionable odors were registered by
residents living adjacent to Pepe Field. In 1947, the Boonton
Board of Health requested that Drew cease waste disposal at the
site by June 30, 1947. The Board of Health also requested that
the waste be covered in 1948. However, this was not done and
the site remained an open, unused area until the mid-1960s when
the Town of Boonton covered the site with soil in preparation for
use as an athletic field. In 1969, a leachate collection and
treatment system was installed at the site. These measures
reduced the frequency and severity of the odor problems, however,
some incidents were still reported. In 1970, the Town purchased
the property and began developing it for more formal use as an
athletic field. The site remained in use as a recreational
facility until 1984, when it was closed by the Town of Boonton
in anticipation of the beginning of a remedial investigation, to
be conducted under CERCLA. A four-foot high chain-link fence,
installed by the Town, currently surrounds the field.
In August 1985, under a Cooperative-Agreement with EPA, the New
Jersey Department of Environmental Protection (NJDEP) initiated a
remedial investigation and feasibility study (RI/FS) to determine
the nature and extent of contamination at the site. The RI/FS,
which was completed in June 1989, indicated that although the
risks associated with the site in its current state were limited,
several situations could occur that would increase those risks.
Among these situations were the possible migration of the methane
gas generated at the site to nearby basements and accumulation to
explosive levels, the possible migration of metals into the
ground water as the landfill aged, and the possibility of wastes
becoming airborne due to deterioration of the cover, at the site.
Based on the results of the remedial investigation (RI), EPA and
NJDEP established a remedial objective for the Pepe Field site.
The objective was landfill closure in accordance with New Jersey
Solid Waste Regulations. The implementation of closure would
address the threat posed by landfill gases and their possible
off-site migration. To accomplish these goals and objectives,
EPA selected a containment-based remedy in the ROD, signed on
September 29, 1989, which included the following major elements:
> Installation and maintenance of a landfill gas
collection and treatment system
> Upgrade and maintenance of the leachate collection
and treatment system
* Maintenance of the site cover
*• Groundwater quality monitoring
* Deed restrictions to prevent waste disruption
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On August 26, 1991, NJDEP formally requested that EPA assume the
role of lead agency for the remedial design and construction
phases of the project.
Description of th« Significant Difference* and th« Basis for
those Differences
The differences between the remedy selected in the 1989 ROD and
the actions described in this BSD are based on information
obtained during the design of the selected remedy. In the 1989
ROD, EPA evaluated five alternatives for remediating the site
including: excavation and off-site disposal; passive perimeter
controls; active interior gas venting with a cap; active interior
gas collection and treatment with a cap; and no action with
monitoring. Each alternative was evaluated with respect to a
number of criteria including overall protection of human health
and the environment, compliance with applicable or relevant and
appropriate requirements (ARARs), long-term effectiveness and
permanence, short-term effectiveness, implementability, cost, and
community acceptance. .
The no-action with monitoring alternative was eliminated from
consideration because it was not judged to be protective of human
health and the environment. The no-action alternative would not
eliminate the potential for the development of combustible
conditions in off-site structures, and it did not comply with
ARARs. Active interior gas venting was considered to be less
effective since gases would be vented to the atmosphere rather
than treated. Passive perimeter controls were also determined to
be less effective since they would relieve combustible conditions
at the perimeter of the site, but would not address interior site
conditions or air emissions. Excavation and off-site disposal,
and active interior gas collection and treatment with a cap were
considered to provide the greatest protection of public health
and the environment, and to be the most effective alternatives.
Although the excavation and off-site disposal alternative was
determined to be protective of human health and the environment
and to provide long-term effectiveness and permanence, it was
considered to be less effective in the short-term than the other
alternatives because of the potential risks to the community
associated with excavation of the wastes, and because it would
require more time to implement than the other alternatives.
Excavation and off-site disposal was also considered to be more
difficult to implement than the other alternatives due to
construction concerns and permitting issues. In addition, the
excavation alternative was estimated to be significantly more
costly than the other alternatives. Based on the above
evaluation, excavation and off-site disposal was not chosen and
a combination of active gas collection and treatment and passive
perimeter controls was selected as the remedy for the site.
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During the design of the remedy selected in the ROD, several
investigations were conducted to provide more information
regarding the current conditions at the site. The results of
these investigations indicated that the selected remedy would
require several modifications to achieve the remedial goals set
forth in the ROD.
As part of the design work, soil samples were collected at off-
site properties to delineate the outer limits of the deposited
waste materials. The results of this sampling indicated that
wastes extended beyond the boundaries of the Pepe Field site,
and excavation and placement of these wastes under the site
cover would be required as part of the remedy. Five tests pits
were also excavated along the southern boundary of the site to
provide information on the condition and extent of the leachate
collection trench installed by the Town of Boonton. Four of the
five test pits intercepted the existing gravel-filled trench,
which was found to drain only part of the southern perimeter of
the site. In addition, waste material was found to be present
on both sides of the trench. Based oh these findings, it was
determined that the existing leachate collection trench would
need to be completely reconstructed to meet the criteria
established in the ROD.
Extraction tests involving five gas wells were conducted during
the design to measure the quality and quantity of the landfill
gas for design of the gas treatment system. These tests
indicated much higher levels of hydrogen sulfide than measured
during the remedial investigation and confirmed elevated levels
of methane that would require flaring. As a result of the gas
well tests and new public health criteria for hydrogen sulfide
promulgated after the ROD, it was concluded that the landfill gas
would require pretreatment for hydrogen sulfide removal prior to
being flared for the removal of methane. This additional gas
treatment step was not anticipated in the remedy selected in the
ROD. Further, an engineering assessment of the existing soil
cover indicated that it could not contain the landfill gas;
therefore, the gas perimeter collection system called for in the
ROD would not be effective. This finding necessitated a redesign
of the landfill cap to include a low permeability barrier layer
to limit the release of gas into the environment, along with a
gas collection layer to direct the gas to the collection and
treatment system.
Samples of the landfill leachate were also collected and analyzed
as part of the design effort. Based on the levels at which
certain contaminants were detected, it was determined that the
leachate would require pretreatment prior to being discharged to
the local sewerage authority. This leachate pretreatment step
was not a component of the remedy selected in the ROD. Because
such treatment represented an additional cost, the design focused^
on minimizing the amount of leachate generated at the site.
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An analysis conducted to define the flow components that were
contributing to the production of leachate concluded that
groundwater flow, and the infiltration of rainwater into the
waste area represented the predominant factors in leachate*
generation. To minimize the influx of clean groundwater flowing
into the waste area, a slurry wall was proposed in the design.
The slurry wall would divert clean groundwater around the site
before it contacted the waste mass. To reduce rainwater
infiltration into the waste, a drainage layer was added to the
cap to capture and transfer rainwater to the perimeter of the
site. The drainage layer, and the low permeability barrier
layer added to the design of the cap to prevent gas releases,
would serve to restrict the vertical movement of rainwater into
the waste mass.
The above modifications necessary to implement the selected
remedy resulted in an increase in the estimated present worth
cost of the remedy from the $1,293,700 identified in the ROD, to
$8.4 million, including operation and maintenance of the site
for 30 years. In view of the significant increase in cost, EPA
decided to reevaluate all of the other alternatives presented in
the ROD to determine if the selected remedy was still the most
appropriate for remediating the site. The three alternatives
involving passive perimeter controls, active interior gas venting
with a cap, and active interior gas collection and treatment with
a cap all would require the same modifications along with similar
cost increases as the selected remedy to achieve the remedial
goals. Consequently, these alternatives were eliminated from
consideration. However, the off-site disposal alternative was
retained for further review.
The original evaluation of alternatives presented in the ROD
concluded that excavation and off-site disposal was less
effective in the short-term than the other alternatives because
of the potential risks associated with excavation, and the longer
time period required for implementation. As discussed above,
waste materials have been found on residential properties beyond
the boundaries of Pepe Field. These wastes must be removed,
making excavation a necessary component of the remedy. As part
of the remedial design effort, bench-scale stabilization testing
of the deposited waste materials and soil gas emission testing
were performed. The results of this testing along with other
information obtained during the design were used to develop a
conceptual plan to excavate the waste in a safe manner, thus
reducing the risks previously associated with the excavation
alternative. In addition, because the design modifications
outlined above will result in a significant amount of additional
remedial work, it is believed that off-site disposal can be
implemented in approximately the same time frame as the selected
containment remedy.
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The ROD also considered the excavation and off-site disposal
alternative to be more difficult to implement than the other
alternatives due to construction and permitting issues. The
modifications necessary to implement the previously selected
remedy (e.g., treatment of hydrogen sulfide gases, the addition
'•of drainage and barrier layers to the cap, more elaborate
leachate collection and treatment, and the added slurry wall)
will make construction of the modified containment remedy much
more complex. Also, there are more detailed permitting issues
associated with both the leachate disposal and gas treatment
components of the selected remedy. Consequently, EPA now
considers the implementability of the excavation and off-site
disposal alternative to be similar to that of the selected
containment remedy.
Finally, the ROD estimated the cost of excavation and off-site
disposal to be $6,873,000, which is less than the revised cost
estimate for the selected remedy. However, like the original
cost estimate for the selected remedy, the ROD excavation
estimate does not take into account the new information that was
obtained during the design and, therefore, needed to be updated.
to reflect current conditions at the site.
To develop an accurate cost estimate for the excavation and
off-site disposal alternative as well as to determine how best to
implement such an alternative given the current site conditions,
EPA developed a conceptual plan to excavate and dispose of the
waste at Pepe Field. The physical properties of the waste are
presently unsuitable for excavation and acceptance at a disposal
facility. The ROD indicated that the excavated waste material
would be mixed with cement kiln dust; in contrast, the conceptual
plan includes in-situ blending of a stabilizing agent into the
waste prior to excavation. This would allow the material to
be excavated and safely transported to a landfill for disposal.
A slurry wall or sheet piling will likely be used to divert
groundwater around the site, thereby reducing the amount of
dewatering necessary during excavation. To control gas emissions
during intrusive activities (i.e., soil stabilization and
excavation), it is expected that an enclosed structure with a gas
treatment system may be required during excavation in some areas.
Continuous air monitoring will be performed during all cleanup
work. The site will be backfilled and restored for future use as
a recreational facility in accordance with a detailed restoration
plan to be developed with local officials.
The cost of the excavation and off-site disposal alternative, as
it is described above, is now estimated to be $10 million, which
is only slightly more than the current estimate of $8.4 million
to implement the selected containment remedy with all of the
necessary modifications described above.
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The above cost for the excavation alternative is based on the
assumption that the bulk of the material will be classified as
non-hazardous and can be disposed of in a solid waste landfill
and includes only those disposal costs paid directly to the
landfill facility. In addition, it is important to note that
implementation of the remedy is dependent upon securing approvals
from other parties, such as the local sewerage authority for the
final treatment of dewatering flows.
Furthermore, several adjacent homeowners will need to grant the
government access to excavate waste from their properties. After
completion of the excavation work, the residential properties
will be restored to the conditions which existed prior to any
cleanup activities. The government's ability to proceed with
the excavation and off-site disposal alternative is contingent
on the cost assumptions and regulatory and access approvals
described herein.
In summary, the excavation and off-site disposal alternative is
now considered to be comparable to the current containment-based
remedy with respect to the criteria used by EPA to evaluate
remedies, including short-term effectiveness, implementability
and cost. Excavation and off-site disposal is the preferable
alternative for a number of reasons. It is permanent, will not
require long-term maintenance, and no restrictions will need to
be placed on the property after the remedy has been completed.
This alternative also is believed to have wide community
acceptance. In contrast, the current containment remedy will
require the installation and operation of elaborate gas and
leachate treatment systems within a residential community. The
cap to cover the waste materials will cause the grade of the site
to be elevated compared to the adjacent residential properties.
These and other aspects of the containment remedy make it much
less desirable to the community than excavation and off-site
disposal. In fact, many area residents have long voiced their
support for excavation of the waste materials at Pepe Field.
Consequently, EPA has decided to change the remedy for Pepe
Field to excavation and off-site disposal. As the next step
in the cleanup process, EPA will proceed to modify the design
consistent with the new remedy. This design work may include
the performance of a pilot study at the site to refine the
construction specifications. Following the completion of
the design work, the actual cleanup work will begin dependent
on the availability of federal funds at that time.
Support Agency CooBMnts
The State of New Jersey supports EPA's revision to the remedy
and decision to issue this ESD for the Pepe Field site.
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Affirmation of Statutory Determination*
Considering the new information that has been developed and the
changes that have been made to the selected remedy, EPA and NJDEP
believe that the remedy remains protective of human health and
the environment, complies with federal and state requirements
that were identified in the ROD and this ESD as applicable or
relevant and appropriate to this remedial action, and is cost
effective. In addition, the revised remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable for this. site.
Public Participation Activities
In accordance with the NCP, a formal public comment period is
not required when issuing an ESD. However, EPA will announce
the availability of this ESD in the Morris County Daily Record.
This ESD has been placed in the Administrative Record for the
Pepe Field site.
Regional/fcdmini
Jeanne M. foYi /lr / Dale
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ESP FACT SHEET
SITE
Name :Pepe Field
Location/State :New Jersey
EPA Region :II
HRS Score(date):34 (12/82
Site ID # :NJD980529598
ROD
Date Signed: 7/25/97
Remedy: In-situ Stabilization and Off-site Disposal
Operable Unit Number: OU-1
Capital cost: $10,000,000 (in 1997 dollars)
Construction Completion: Sept. 1999
O & M: N/A
Present worth: N/A
LEAD ' '
Remdial/Enforcement: Remedial
EPA/State/PRP: EPA
Primary contact (phone): Romona Pezzella (212) 637-4385
Secondary contact (phone): Don Lynch (212) 637-4419
Main PRP(s): N/A
PRP Contact (phone): N/A
WASTE
Type (metals, PCB, etc.): Metals
Medium (soil, g.w.,etc.): Soil/Waste
Origin: Wastes from edible oils, and cleansing and soap
products for household and industrial use.
Est. quantity: 25,000 tons
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