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                                -2-

 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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                                -3-  '

 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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                                -4-

 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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                                -5-

 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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                                -6-

 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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                                -7-

 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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                                -8-  '

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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