PB95-963816
EPA/ROD/R02-95/262
May 1996
EPA Superfund
Record of Decision:
PJP Landfill Site,
Hudson County, Jersey City, NJ
9/28/1995
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RECORD OP DECISION
PJP Landfill Site
Jersey City, Hudson County, New Jersey
New Jersey Department of Environmental Protection
Site Remediation Program
Trenton, New Jersey
SEPTEMBER 28, 1995
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DECLARATION FOR THE RECORD OP DECISION
SITE NAME AND LOCATION
PJP Landfill
Jersey City, Hudson County, New Jersey
STATEMENT OP BASIS AND PURPOSE
This decision document presents the selected remedial action for the PJP Landfill
Site, which was chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act, as amended, and to the
extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision document is based on the administrative record
file for this Site.
The United States Environmental Protection Agency concurs with the selected
remedy.
ASSESSMENT OP THE SITE
Actual or threatened releases of hazardous substances from the PJP Landfill 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 OP THE SELECTED REMEDY
The selected remedy represents the first and only planned operable unit for the
PJP Landfill Site. It addresses contaminated surface soils on the Site and
groundwater contamination in the underlying shallow and deep aquifers.
The major components of the selected remedy include:
1. Removal of all known and suspected buried drum materials and associated
visibly contaminated soil;
2. Capping of the remaining landfill area of the site with a multi-layer,
modified solid waste cap in accordance with NJDEP Bureau of Landfill
Engineering Guidance with gas venting;
3. Extension of the existing gravel lined ditch around the perimeter of the
site to collect the surface water runoff;
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4. A passive or active gas venting system installed in the new portion of
the cap. (If an active system is deemed necessary, however, both areas
will be included);
5. Site fencing and institutional controls (e.g., declaration of
environmental restriction and public information program);
6. Quarterly inspections and maintenance, and a re-evaluation of the
previously capped area;
7. Replacement of the Sip Ave ditch with an alternate form of drainage;
8. Quarterly ground water monitoring to evaluate the reduction of contaminant
concentrations over time;
9. Modeling to demonstrate the effectiveness of the cap by predicting the
impact of ground water leachate migrating to the Hackensack River from the
landfill;
10. Because contamination levels in the ground water are above the Class HA
Ground Water Quality Criteria (GWQC), a Classification Exemption Area
(CEA)/Well Restriction Area (WRA) will be established; and
11. Implementation of a wetlands assessment and restoration plan. (The
we*-lands assessment will be performed prior to implementation of any of
the remedial actions).
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 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 which reduces toxicity, mobility, or volume as
their principal element.
Because this remedy will result in hazardous substances remaining on the Site
above health-based levels (soil will be capped over), a review will be conducted
within five years after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health and the
environment. This review will include an evaluation of the data and information
obtained in connection with remedial components 6, 8, and 9 above, as well as
other appropriate components of the selected remedy.
Robert C. Shinn ,7r. '/Date
Commissioner ;
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RECORD OP DECISION
DECISION SUMMARY
PJP Landfill Site
Jersey City, Hudson County, New Jersey
New Jersey Department of Environmental Protection
Trenton, New Jersey
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RECORD OP DECISION
RESPONSIVENESS SUMMARY
PJP Landfill Site
Jersey City, Hudson County, New Jersey
New Jersey Department of Environmental Protection
Site Remediation Program
Trenton, New Jersey
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TABLE OP CONTENTS
PAGE
SITE NAME, LOCATION, AND DESCRIPTION 2
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OP COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OP RESPONSE ACTION 3
SUMMARY OF SITE CHARACTERIFVICS 4
SUMMARY OF SITE RISKS 6
REMEDIAL ACTION OBJECTIVES 10
DESCRIPTION OF REMEDIAL ALTERNATIVES 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 16
SELECTED REMEDY 20
STATUTORY DETERMINATIONS 23
DOCUMENTATION OF SIGNIFICANT CHANGES 26
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. EPA'B LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION, AND DESCRIPTION
The PJP Landfill Superfund Site is an inactive landfill located at 400 Sip
Avenue, Jersey City (see figure 1). The Site occupies approximately 87 acres
in Jersey City, Hudson County, Hew Jersey, and is identified on the Jersey
City tax map (1977) as block 1639.1, lots 2A, 3, 4C, 5C, 7D; block 1639.2,
lots 1C, 5C, 7 and 7E; block 1627.2 lot IP; block 1627.1 lots 5A, 6A and parts
of 2A, 3B and 4B. The Site is bordered on the north and west by the
Hackensack River and on the southeast by Truck Routes 1 and 9. A recycling
facility and a warehouse border the northeast side of the Site. The southwest
side of the Site is boarded by several commercial trucking terminals.
Multiple dwelling housing units are Ic ?ated northeast and southeast of the
Site. The Pulaski Skyway, an elevated highway, passes over the Site. The
Sip Avenue Ditch bisects the Site and conveys run-off from the PJP Landfill
and Jersey City storm water/sewer int<- the Hackensack River (see figure 2).
BITS HISTORY AMD ENFORCEMENT ACTIVITY?
The Site was originally a salt meadow, a portion of which was condemned in
1932 for the construction of the Pulaski Skyway. The PJP Landfill Company
operated a commercial landfill at the Site, accepting chemical and industrial
waste from approximately 1970 to 1974.
From 1970 to 1985, subsurface fires (on the currently capped 45 acre area)
which were attributed to spontaneous combustion of subsurface drums and
decomposition of landfill materials, frequently burned at a 45-acre portion of
the PJP Landfill and emitted large amounts of smoke. In 1977, the NJDEP
issued an order to the PJP Landfill C. jpany to properly cover and grade the
landfill, and to remove wastes in coi-tact with the Hackensack River and the
Sip Avenue Ditch. The PJP Landfill Company did not comply with the order.
Throughout the early 1980s, NJDEP anu the Hudson Regional Health Commission
inspected the Site and conducted sampling and air monitoring. In December
1982, the Site was included on the EPA's National Priorities List (NPL), which
identifies hazardous waste Sites that rose a significant threat to public
health or the environment. .
During 1985 and 1986, NJDEP conducted an Interim Remedial Measure (IRN) to
extinguish the fires and cap the 45 acre area. The IRM resulted in the
extinguishing of fires; excavation and recompaction of approximately 1,033,000
cubic yards of material; and the removal of grossly contaminated soils,
cylinders and drums containing hazardous materials on approximately 45 of the
87 acres. These hazardous materials were properly disposed of off Site at
secure landfills or hazardous waste incinerators. A fire break trench waa
installed and the 45 acre area was regraded, capped and seeded. A gas venting
system was also installed on the 45-arre portion of the landfill. All
subsurface fires have been out since the completion of the IRM in May 1986.
The NJDEP contracted ICF Technology, Inc. (ICP) in 1988 to perform an Rl/rs on
the entire 87 acres of the landfill. The Remedial Investigation (RI) *<••
completed by ICF in 1990. The RI identified areas and levels of cont«aln«tion
at the Site. The study included a geographical investigation and a shock-
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sensitive drum investigation to determine the density and condition of buried
drums, extent of landfill material, the shock sensitivity of drums, and drum
markings. An PS was also performed, which developed and evaluated various
remedial alternatives for addressing Site contamination.
In the summer of 1993, MJDEP implemented a plan to assist in the evaluation of
the current impact the Site was having on the adjacent Hackensack River and on
the deeper aquifer of concern beneath the fill material. The sampling effort
consisted of the sampling of three shallow and three deep monitoring wells,
and six surface water and sediment locations. Hater and sediment samples
collected from the Backensack River were obtained upstream and downstream from
the Site. Water and sediment samples from the Sip Avenue Ditch were obtained
from the Ditch adjacent to Routes 1 and 9 and at the confluence of the ditch
with the Hackensack River. The samples were anal/zed for organic and
inorganic chemical parameters. In addition, a s'-ies of bioassay (mysid
shrimp chronic toxicity tests) were preformed using water collected from the
Hackensack River, the Sip Avenue Ditch, and at he sediment Sw.ir.le locations
and in the waters of the two wells with the highest levels of contamination
was performed.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI report, FS report, and the Proposed Plan for the Site were released to
the public for comment on August 2, 1994. These documents were made available
to the public in the administrative record file at the MJDEP file room in, 401
Bast State Street, Trenton, NJ and the information repositories at:
Jersey City Public Library Jersey City Municipal Building
472 Jersey Avenue Engineering Division
Jersey City, NJ 07302 280 Grove Street
(201)547-4516 Jersey City, NJ 07302
(201)547-6852
On August 18, 1994, NJDEP conducted a public meeting at the Jersey City
Municipal Building to inform local officials and interested citizens about the
Superfund process, to discuss the findings of the RI and FS and the proposed
remedial activities at the Site, and to respond tr any questions from area
residents and other attendees.
NJDEP responses to the comments received at the public meeting, and in writing
during the public comment period, are included in the Responsiveness Summary
section of this Record of Decision.
SCOPE AND ROUE OF RBSPONSK ACTION
This ROD will address cleanup remedies for the Sip Avenue Ditch sediment, air
and landfilled material which includes areas of buried drums and surrounding
contaminated soil. A monitoring program will be established to determine
whether additional actions may be necessary to mitigate the leaching of
contaminants to ground water and surface water as well as to the Hackensack
IJiver. If a significant adverse impact is found, NJDEP and EPA will evaluate
remedial alternatives and select an appropriate remedy in accordance with
CERCLA and the NCP.
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SUMMARY OF SIZE CHARACTERISTICS
Site Geology and Hydrology
The PJP Landfill Site lies in the Piedmont physiograph province of
Northeastern New Jersey. The bedrock of the Piedmont Lowlands consists of
igneous and sedimentary rocks. The bedrock underlying the Site is the
Brunswick Formation. This formation consists of fluvial and lacustrine reddish
brown shales and some fine grained sandstone.
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The Site is located on man-made fill deposits which are approximately 10 to 30
feet thick. The fill material is underlain by a discontinuous layer of peat.
Under the peat layer is a layer of sand and silt. The bedrock at the landfill
is approximately 60 to 90 feet below the surface.
The principal source of ground water in the area lies with, n the re~ks 01 tae
Brunswick Formation. Ground water, which flows in a westwaruly direction, is
not used for potable water supply within the lower Hackensack Basin. However,
due to industrial and commercial nature of the area it appears that the ground
water is used for some commercial and industrial purposes. The area near the
PJP Landfill is served by the Jersey City municipal water supply, which is the
Boonton Reservoir.
Mature and Extent of Contamination
The RI identified contaminants above NJDEP current cleanup criteria in surface
soils, subsurface soils (excluding test pits), test pits, sediments from the
Sip Avenue Ditch, and air. The cleanup criteria, although r ">t promulgated,
are currently used in lieu of standards.
soil
Arsenic was detected in the surface soils samples in concentrations greater
than the NJDEP Soil Cleanup Criteria of 2Q parts per million (ppm). In the
subsurface soils (excluding the test pits~which are discussed later in this
Record of Decision), the following contaminants were detected at levels
exceeding the cleanup criteria: Benzene (maximum concentration detected 1.6
ppm), bis(2-ethylhexyl)phthalate (maximum concentration detected 180 ppm) and
chlorobenzene (maximum concentration detected 2.92 ppm).
Chemicals were detected more frequently, and in higher concentrations, in the
test pits than were detected in samples from other media. Bis(2-
ethylhexyl)phthalate (maximum concentration detected 33,100 ppm) and petroleum
hydrocarbons were the predominant organic chemicals found in the subsurface
soils of those that exceed the current NJDEP subsurface soil standards. Other
predominant organic chemicals detected in the soils sampled from the test pits
that exceed the NJDEP impact to ground water soil cleanup criteria are the
following: benzene (maximum concentration detected 250 ppm), dieldrin
(maximum concentration detected 200 ppm), tetrachloroethene (""»*JT"'?r?
concentration detected 41 ppm), and total xylenes (maximum concentrations
detected 3900 ppm). Carcinogenic and non-carcinogenic polycyclic aromatic
hydrocarbons (PAHs) and inorganic chemicals (metals) were also detected
frequently in the subsurface soils.
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SJP Avenyfl Ditch
The Sip Avenue Ditch sediment samples were compared to the National
Oceanographic and Atmospheric Administration (NQAA) sediment screening
guidelines. This guidance sets criteria for contaminants which may have
potentially harmful biological effects to aquatic life, sediment contaminants
found in the Sip Avenue Ditch exceeded these screening guidelines. The
highest concentrations found were total PAH (14.8 ppm for carcinogenic PAH;
30.1 ppm for noncarcinogenic PAH), antimony (93.8 ppm), cadmium (6.3 ppm),
chromium (771 ppm), copper (34,000 ppm), lead (406 ppm), mercury (5.1 ppm),
nickel (1,260 ppm), and zinc (9,830 ppm).
Landfill Gas Vent
Landfill gas vent sample data obtained during the Remedial Investigation was
used to approximate the total amount of contaminants discharged from the gas
vent system in terms of pounds per hour. Eight of the forty-nine existing
vents were sampled on three separate occasions, and used as representative
vents for the entire system. The maximum flow rate from the forty-ni.-- vents
was used to calculate potential discharges (8.73 cubic feet per minut'/cfm)
and the maximum contaminant concentrations from the three sample rounds was
used for each contaminant.
Discharge numbers were calculated for total emissions and toxic emissions.
Using the average and maximum contaminant concentrations for the eight
landfill gas vents, typical landfill emissions and the worst case scenario
emissions were determined. The total emissions average of .43 Ibs/hr, and
maximum of 1.5 Ibs/hr, respectively, are within the acceptable/allowable limit
of 1.5 Ibs/hr. Toxic emissions average of .07 Ibs/hr is also within the
acceptable/allowable limit of .1 Ibs/hr while the toxic emissions maxi .urn of
.27 Ibs/hr is slightly above the acceptable/allowable limit of .1 Ibs'hr.
The NJPEP 1993 Sampling Effort
The monitor well analyses indicated that 11 compounds were detected in the
three (3) ground water monitor wells at levels slightly above New Jersey's
Ground Hater Quality Criteria. Hackensack River water and sediment samples
were collected upstream and downstream of the Site. Surface water samp .es
obtained from the river indicated the presence of inorganics both upstream and
downstream from the Site, such as iron, aluminum, copper and zinc. Sediment
samples collected from the river indicated the presence of volatile organic
compounds, semi-volatile organic compounds, pesticides, PCBs, and inorganics
both upstream and downstream from the Site. Predominant chemicals detected in
the sediments were poly cyclic aromatic hydrocarbons (tn^yjrrcim concentration
detected approximately 25 ppm), PCBs (maximum concentration detected
approximately 360 ppb), lead (maximum concentration detected approximately 222
ppm), and mercury (maximum concentration detected approximately 2.7 ppm).
Contamination was also present in the Sip Ave ditch, both adjacent to routes 1
& 9 and at the confluence of the ditch with the river. The ditch water and
sediment samples adjacent to the highway were more contaminated than the
•ample obtained from the confluence of the ditch with the river. Chemicals
detected in the water samples Included volatile organics such as
tetrachloroethene (detected at 44 ppb) and inorganics such as lead and zinc.
Chemicals detected in the sediment samples included tetrachloroethene
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(detected at approximately 10 ppb), toluene (detected at approximately 4 ppb),
numerous polycyclic aromatic hydrocarbons, and inorganics such as copper, lead
and zinc.
All four (4) of the bioassay sampling locations in the river, the two monitor
well sample locations, and the Sip Avenue Ditch location from the confluence
of the ditch and the river showed significant mortality. The sampling
location with the lowest percent mortality was from the Sip Avenue Ditch
adjacent to Routes 1 and 9. This data indicates that potential adverse
impacts on biota by these contaminated waters is likely occurring.
The Bedrock Aquifer Hell sampling results indicate that all three well results
are below New Jersey Ground Water Quality Standards. The sampling results
indicate that none of the contaminants found in the wells exceed NJDEP's
Ground Hater Quality Criteria for Volatile Organics, Semi-Volatile Organics,
and Pesticides.
SUMMARY OP 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 ecological risk which
could result from the contamination at the Site if no remedial action were
taken. The results from the 1993 NJDEP sampling effort were not incorporated
into the baseline risk assessment for the Site, since the RI report predated
the 1993 sampling event.
The following summarizes the finding of the Risk Assessment.
Human Health Risk Assessment
A four step process is utilized 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 by
which humans are potentially exposed (e.g., ingesting contaminated
soil/water); 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); and
Risk Characterisation - summarizes the combined output of the exposure and
toxicity assessments to provide a quantitative (e.g., one-in-a-million excess
cancer risk) assessment of site-related risks. Normally, a baseline risk
assessment evaluates the risk posed by a site in the absence of remediation.
In the case of PJP Landfill, an Interim Remedial Measure has already been
implemented prior to evaluating site-wide risk.
EPA conducted a baseline risk assessment to evaluate the potential risk to
human health and the environment associated with the PJP Landfill Site in its
current state. The Risk Assessment focused on contaminants in the soil.
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ground water, surface water, sediment, and air which are likely to pose
significant risks to human health and the environment. A summary of the
contaminants of concern in sampled matrices is provided in Table 5-15 for
human health and the environmental receptors, respectively. The exposure
pathways and populations evaluated are in Table 5-17. A total of nine
exposure pathways were assessed under possible on-site current and future
land-use conditions. The plausible maximum and average case scenarios were
evaluated.
Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing)
and noncarcinogenic effects due to exposure to Site chemicals are considered
separately. It was assumed that the toxic effects of the site-related
chemicals would be additive. Thus, carcinogenic and noncarcinogenic risks
associated with exposures to individual compounds of concern were summed to
indicate the potential risks associated with mixtures of potential carcinogens
and noncarcinogens, respectively.
Noncarcinogenic risks were assessed using a Hazardous Index (HI) approach,
based on a comparison of expected contaminant intakes and safe levels of
intake (Reference Doses). Reference doses (RfDs) have been developed by EPA
for indicating the potential for adverse health effects. RfDs, which are
expressed in units of milligrams/kilogram-day (mg/kg-day), are estimates of
daily exposure levels for humans which are thought to be safe over a lifetime
(including sensitive individuals). Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from contaminated
drinking water) are compared to the RfD to derive the hazard quotient for the
contaminant in the particular medium. The HI is obtained by adding the hazard
quotients for all compounds across all media that impact a particular receptor
population.
An HI greater than 1.0 indicates that the potential exists for noncarcinogenic
health effects to occur as a result of site-related exposures. The HI
provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media. The
reference doses for the compounds of concern at the Site are presented in
Table 5-19. A summary of the noncarcinogenic risks associated with these
chemicals across various exposure pathways is found in Tables 5-24,5-25,5-
26,5-27,5-29,5-30,5-31,5-35,5-36,5-37 and 5-39. The results of the baseline
risk assessment indicated that the greatest risk associated with the Site
under current conditions is the incidental ingestion and dermal absorption of
chemicals in sediment by trespassing children wading in the Sip Avenue Ditch.
The carcinogenic risk for children was estimated to be 4xlO*s, which is within
acceptable EPA guidelines.
For incidental ingestion/dermal absorption of Sip Ave Ditch sediments, the HI
was calculated to be four. This was based on the plausible maximum scenario.
Therefore noncarcinogenic effects may occur from this exposure route. Under
an average case scenario, the HI is less than one.
Potential carcinogenic risks were evaluated using the cancer slope factors
developed by EPA for the contaminants of concern. Cancer slope factors (1F«>
have been developed by EPA's Carcinogenic Risk Assessment Verification
Endeavor for estimating excess lifetime cancer risks associated with exposure
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to potentially carcinogenic chemicals. SFs, which are expressed in units of
(mg/kg-day)*1, are multiplied by the estimated intake of potential carcinogen,
in mg/kg-day, to generate an upper-bound estimate of the excess lifetime
cancer risk associated with exposure to the compound at that intake level.
The term "upper bound* reflects the conservative estimate of the risks
calculated from the S7. Use of this approach makes the underestimation of the
risk highly unlikely. The Sf for the compounds of concern are presented in
Table 5-19.
A qualitative risk assessment was performed for future land-use conditions.
Although not likely, it is possible that land use at the Site could change in
the future, resulting in additional exposure pathways that do not exist under
current land-use conditions. The most plausible land-use change would be
development of the landfill area as an industrial/commercial area. If the
area were developed, on-site construction workers could be exposed via direct
contact with contaminated sediments, subsurface soil, and materials in test
pits. Generally, the concentrations of chemicals detected in test pits and
subsurface soils are substantially higher than in sediments. Based on the
substantially higher chemical concentrations in the subsurface soil and test
pits, some of which are potentially carcinogenic, future workers exposed to
these subsurface contaminants could be at significant risk. ' Inhalation
exposures are estimated to be approximately equal to those estimated for
trespassing children. For long-term exposures, this risk would probably be
greater than the 10** to 10*6 range.
Environmental Risk Assessment
The Environmental Assessment provides a qualitative evaluation of the actual
or potential impacts associated with the Site on plants and animals (other
than people or domesticated species). The primary objectives of this
assessment were to identify the ecosystems, habitats, and populations likely
to be found at the Site and to characterize the contaminants, exposure routes
and potential impacts on the identified environmental components. The
environmental assessment evaluated potential impacts associated with chemicals
in the surface soil, surface water (including chemicals released to surface
water from ground water) and sediment. Potential exposures evaluated were
terrestrial plants, terrestrial wildlife, and aquatic life.
The Environmental Assessment identified several endangered species and
sensitive habitats in the vicinity of the Site. The Hackensack River is
considered critical habitat for the short-nosed sturgeon, which is a State and
federal endangered species. The Site is also within the current or historical
range of several other State endangered or threatened species that inhabit
coastal areas and/or marshes, including the Atlantic sturgeon, Atlantic
tomcod, pied-billed grebe, great blue heron, northern harrier, Henslow's
sparrow, short-billed marsh wren, and osprey.
Estuarine intertidal wetlands occur along the Hackensack River and the Sip
Avenue Ditch, which are tidally influenced in association/with the Hackeneack
River. A palustrine emergent scrub/shrub wetland occurs in the southeast
corner of the Site adjacent to the entrance road and Routes 1 and 9. Due to
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some areas receiving lees fill material than others, depressed areas have
formed, leaving an appearance of wetland like features.
The environmental assessment is summarized as follows:
Plants— Plants can be exposed to chemicals in surface soil. Chemical-related
impacts in plants are not expected to be significant. If chemical-related
impacts are occurring, they are most likely limited to localized source areas
such as the drum disposal area, since surface soil contamination is not
believed to be widespread at the Site. Impacts in these isolated areas would
be expected to have minor impacts on the plant community and habitat quality
of the entire PJP Site. Chemical-related impacts in plants are most likely
insignificant compared to other current and past (non-chemical) stresses on
the plant community at the PJP Site, such as past grading and filling at the
Site.
Terrestrial wildlife — Potential impacts were evaluated for wildlife exposed
to chemicals of potential concern. Some species could use the Sip Avenue
Oitch or Hackensack River for drinking water, however, exposure in these
species is not expected to be significant given the availability of other
water sources nearby and the relatively large foraging area of these species.
None of the chemicals of potential concern detected in surface water are
expected to be acutely or chronically toxic at the low levels of exposure
potentially experienced by wildlife.
Aquatic life — Potential impacts on aquatic life were evaluated for chemicals
in surface water and sediment. Surface water concentrations were compared
with ambient water quality criteria developed by EPA or lowest-observed-
effects levels. Sediment concentrations were compared with toxicity values
derived from the available literature. There is a potential for food chain
effects to occur via predation on aquatic species, since several of the
contaminants of concern bioconcentrate (e.g., cadmium, mercury). Surface
water and sediment concentrations for several chemicals in the Sip Avenue
Ditch and in the Hackensack River exceeded their respective toxicity values,
suggesting that aquatic life impacts may be occurring at the Site.
In summary, the environmental assessment concluded that chemical contamination
from the Site is not expected to have significant impacts on plants or
terrestrial wildlife, but may be impacting aquatic life.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all
such assessments, are subject to a wide variety of uncertainties. In general,
the main sources of uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
•* toxicological data
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Uncertainty in environmental sampling arises in part from the potentially
uneven distribution of chemicals in the media sampled. Consequently, there is
significant uncertainty as to the actual levels present. Environmental
chemistry-analysis error can stem from several sources including the errors
inherent in the analytical methods and characteristics of the matrix being
sampled.
There are also uncertainties in the risk assessment because the PJP site is
located in an industrial area. The Sip Avenue Ditch receives some runoff from
Jersey City and during large storm events has received overflow sewage from
the city. Regional pollution has resulted in the state prohibiting swimming
or other consumptive uses of the Hackensack River.
Uncertainties in the exposure assessment are related to estimates of how often
an individual would actually come in contact with the chemical of concern, the
period of time over which such exposure would occur, and in the models used to
estimate ti..e concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both 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 populations near the
Site, and is highly unlikely to underestimate actual risks related to the
Site.
More specific information concerning public health risk, including a
quantitative evaluation of the degree of risk associated with various exposure
pathways, is presented in the Risk Assessment Report.
Actual or threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in the ROD, may present
an imminent and substantial endangerment to the public health, welfare, or the
environment.
XAL ACTXOH OBJECTIVES .
Remedial Action Objectives are specific goals to protect human health and the
environment. These objectives are based on available information, applicable
or relevant and appropriate requirements (ARARs), and risk-based levels
established in the risk assessment. The following remedial action objectives
were established for cleanup activities at the Sites
Eliminate exposure to contaminated sediments in the Sip Avenue
Ditch.
Prevent additional contaminant influx into the ground water via
infiltration of rain water.
Removal of contaminant sources that may impact ground water.
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Evaluate if future actions are necessary to mitigate
the leaching of Site contaminants into the Hackensack River
through the monitoring and modeling to check the effectiveness of
the remedy. If a significant adverse impact is found, NJDEP and
EPA will evaluate remedial alternatives and select an appropriate
remedy in accordance with CBRCLA and the HOP.
DESCRIPTION OP REMEDIAL ALTERNATIVES
The Comprehensive Environmental Response, Compensation, and Liability Act, as
amended (CBRCLA), requires that each selected Site remedy be protective of
human nealth and the environment, be cost effective, comply with other
applicable or relevant and appropriate requirements, and utilize permanent
solut'-ms, alternative treatment technologies, and resource recovery
alternatives to the maximum extent practicable. In addition, the statute
incl des a prefere: ->e for the use of treatment as a principal element for the
reduction of ioxicity, mobility, or volume of the hazardous substances.
The F& evaluates in detail several remedial alternatives for addressing the
contamination associated with the PJP Landfill Site. These alternatives are:
Alternative LF-lt No Action
Alternative LF-2i Minimal Action
Alternative LF-3t Soil Cover
Alternative LF-4i Modified NJDEP Solid Waste Cap (Extending Existing
Cap)
Mternative LF-5i NJDEP Haiardous Waste Cap
Alternative LF-6t RCRA Hazardous Waste Cap - Incorporating Existing Cap
Alternative LF-7t New RCRA Hazardous Waste Cap
The fallowing two options are applicable to Alternatives LF-3 through LF-7:
OPTION Is No Drum Removal
OPTION 2t Drum Removal (All known Buried Drum Areas and associated
Soils) '
As part of Alternatives LF-3 through LF-7: the Sip Avenue Ditch will be
replaced with an alternative form of drainage, in order to maintain the
integrity of the landfill cap and channel surface water runoff. Design
details related to the Sip Avenue Ditch will be resolved in the remedial
design'phase of the Project. Alternatives will address issues such as
protectiveness to ecological receptors, the fate of stormwater runoff, and the
effectiveness in preventing contaminant migration to the Hackensack River.
Potential alternatives include, but are not limited to, excavation of
sediments and placement under the cap, burial in place, or some other form of
containment or disposal.
In order to comply with federal wetland ARARs, the remedial design will also
include: (a) a wetlands assessment to determine what wetlands were
impacted/disturbed by contamination or remedial activities, and (b) a wetlands
restoration plan to mitigate those areas found to have been impacted. The
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12
assessment will b«* conducted and the restoration plan prepared prior to
remedial activities.
Under Alternative LP-2, LP-3, and LF-4, the existing landfill gas venting
system will be sampled during the design phase to determine compliance with
current State an* Federal air quality standards. If, at that time, air
emissions are not in compliance with the accepted maximum limits for Total
Volatile Organics, the appropriate measures will be incorporated into the
design phase to bring the Site into compliance with air requirements.
For alternatives LF-5, LF-6, and LF-7, the design phase will include a new
landfill gas venting system that will be designed (active or passive) to
comply (including treatment, if necessary) with State and Federal air quality
standards.
In addition, because contamination levels in the ground water are above the
Class IZA, Ground Hater Quality Criteria (GWQC), each alternative includes a
Classification J-emptiou Area <2EA)/Well Restriction Area (WRA).
This ROD presents alternatives, which are described in greater detail below.
Implementation times given include the time necessary to construct and
implement the remedy but do not include the time required for design or award
of a contract for the performance of the work.
ALTERNATIVE LF-ll HO ACTION
Estimated Capital Cost: None
Annual Operation und Maintenance: None
Estimated Preset) . Worth: None
Estimated Implementation Time: None
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and
CERCLA require che evaluation of a No Action alternative to serve as a point of
comparison with other remedial action alternatives. Under this alternative, no
action would be taken to contain, treat, or control the contamination at the
Site. The subsurface soil contamination would decrease over a long period of
time through natural processes, such as flushing and attenuation. This
alternative does not include any measures to restrict access to the Site.
Essentially, the Site would remain the same as it is today. Regular monitoring
and a five year review to re-evaluate this alternative would be performed.
ALTERNATIVE LF-2l MINIMAL ACTION
Estimated Capital Cost: $209,000
Annual Operation and Maintenance: $105,000
Estimated Present Worth: $752,000
Estimated Implementation Time: None
Under this alternative, no remedial action would be performed at the Site to
contain, treat, or control the contamination at the Site. However, institutional
controls, such as deed restrictions to restrict future use of the Site and public
information programs to increase public awareness of potential probl«M
associated with the Site, would be implemented. In addition, although mo»t of
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the Site is already fenced, the existing fence would be extended to restrict
access and reduce the potential for direct exposure to sediment contamination.
Long-term monitoring of soil, sediment and air quality would be performed for a
minimum of five years to evaluate the migration of contaminants from the Site and
to monitor the effects of natural attenuation.
A Site review would be instituted at the end of five years in order to reevaluate
Site conditions. This includes an evaluation of what additional measures, if
any, should be implemented based on the Site conditions.
ALTBRNXTIVB LF-3t SOIL COVER
Estimated Capital Costs $16,368,000
Annual Operation and Maintenances $291,000
Estimated Present Worths ,"7,716,000
Estimated Implementation Times 6 months
As described earlier, a 45-a-re portion of the landfill was already excavated and
capped with one foot of clay and one foot of soil during the completion of the
IRM in 1986. Under this alternative, a two foot soil cover would be installed
over the remaining, uncapped 42-acre area. The proposed soil cover design
includes installation of a top soil layer over the uncapped area and vegetation
to prevent soil erosion. Existing gas vents would be sampled and analyzed
annually to monitor the gas releases to the atmosphere from the Site. If the gas
poses a threat, treatment options would be developed and implemented. in
addition, institutional controls and Site fencing would be implemented as
described for Alternative LF-2 above.
The soil covered area woul. require quarterly inspections and maintenance, and
a review and reevaluation of Site conditions after five years.
ALTERNATIVE LF-4s MODIFIED NJDEP SOLID WASTE CAP (Extending Existing Cap)
Estimated Capital Costs $22,022,000
Annual Operation and Maintenances $369,000
Estimated Present Worths $'.3,707,000
Estimated Implementation Tire: 1.5 years
As described earlier, a 45-acre portion of the landfill was already excavated and
capped with one foot of clay and one foot of soil during the IRM. Under this
alternative, the remaining 42-acre area, under the Pulaski Skyway on the north
side of the Sip Ave Ditch,, would be capped with a multi-layer, modified solid
waste type cap. The cap may combine several layers of cover materials, such as
clean sand, soil and an impervious layer, such as a High Density Polyethylene
(plastic) or clay liner but must maintain a minimum of Ix 10*7 impermeability to
contain the contaminated rolids. It may also include a top soil layer and
vegetation to prevent soil tirosion and to protect the clay/HDP from freeze-thaw
effects. The existing gravel lined ditch along the southern border of the capped
portion of the landfill would be incorporated into the design of surface water
run-off controls.
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The use of a passive or active gas venting system would be determined during the
remedial design phase of the project. Periodic inspections of the cover
installed during the ZRM will be performed before and during the implementation
of the remedial action and damaged or degraded areas will be repaired. A
surface and ground water monitoring 'quarterly) and modeling program will be
implemented to evaluate the impacts ground water or leachate is having on the
Hackensack River and to evaluate the reduction, if any, of contaminant
concentrations and determine if natural attenuation is occurring at the Site.
If a significant adverse impact is found, NJDEP and EPA will evaluate and
implement hydraulic controls to mitigate those impacts. The Site would be
reviewed at the end of five years in order to reevaluate Site conditions. The
review would include an analysis of thv ground and surface water monitoring data,
evaluate the impact ground water or leachate is having on the Hackensack River.
The review will also include an assessment of current residual health risks, and
an evaluation of the effectiveness ox site fencing to control access.
ALTERNATIVE LF-Sl HJDEP HAZARDOUS fi. TTB LAS^PILL CAP
Estimated Capital Costt $35,029,000
Annual Operation and Maintenance: $369,000
Estimated Present Worth: $36,714,000
Estimated Implementation Time: 3 years
As described earlier, a 45-acre portion of the landfill was already excavated and
capped with one foot of clay and one foot of soil during the completion of the
IRK. Under this alternative, the existing 45-acre IRM cap would be left in place
and a new multi-layer cap would be placed over the entire 87-acre area. The new
cap would comply with the New Jersey hazardous Haste Regulation (N.J.A.C. 7:26-
10.8(i» regarding closure and post closure requirements for hazardous waste
landfills. The proposed cap would consist of a vegetative top soil cover, a sand
drainage layer, a bedding layer and a liner system constructed of two synthetic
liners. The existing gravel-lined ditch would be incorporated in the design to
facilitate the collection of surface water run-off.
In addition, institutional controls r.id Site fencing would be implemented aa
described for Alternative LF-2 above. Regular monitoring and a five year review
would also be required as described for Alternative LF-4 above.
ALTERNATIVE LF-6* RCRA HAZARDOUS HASTE CAP - INCORPORATING IRM CAP
Estimated Capitol Cost: $44,226,000
Annual Operation and Maintenance: $369,000
Estimated Present Worth: $45,911,000
Estimated implementation Time: 3 years
As described earlier, a 45-acre portion of the landfill was already excavated and
capped with one foot of clay and one foot of soil during the completion of the
IRM. Under this alternative, the existing IRM cap would be upgraded and
incorporated into a Resource Conservation and Recovery Act (RCRA) cap, which
would be installed over the remaining approximate 42-acre area. The RCRA cap is
a multi-layer cap that combines several layers of cover materials such a* soil,
synthetic membranes, and clay to provide erosion and moisture control, in
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addition to containing the contaminated solids. The entire Site would be graded
for proper drainage and seeded with grass for erosion control. The existing
gravel-lined ditch would be incorporated in the design to aide in the collection
of surface water run-off.
.This alternative includes institutional controls and site fencing as described
in Alternative LF-2. Regular monitoring and a five year review would also be
required as described for Alternative LF-4.
ALTERNATIVE LF-7t HEW RCRA HAZARDOUS WASTE CAP
Estimated Capital Costt $47,879,00
Annual Operation and Maintenance: $369,000
Estimated Present Worth: $49,564,00
Estimated Implementation Time: 3 years
Under this Alternative, the existing ZRM cap wo* id be removed, ;vaded, and used
as the first layer of fill. A new RCRA cap woul'u be placed over the entire 87
acre Site. As described in Alternative LF-6, the RCRA cap is a multi-layer cap
that combines several layers of cover materials such as soil, synthetic
membranes, and clay to provide erosion and moisture control, in addition to
containing the contaminated solids. The entire Site would be graded for proper
drainage and seeded with grass for erosion control. The existing gravel-lined
ditch would be incorporated in the design to aide in the collection of surface
water run-off.
This alternative includes institutional controls end Site fencing as described
for Alternative LF-2. Regular monitoring and mai tenance and a five year review
would also be required as described for Alternative LF-4.
The following two options apply to alternative LF -3 to LF-7:
OPTION It HO DRUM REMOVAL
Estimated Capital Costs HONE
Annual Operation and Maintenance: NONE
Estimated Present Worths NONE
Estimated Implementation Time: NONE
Under this alternative, no excavation and removal of known buried drums and
associated contaminants would be performed prior to capping.
OPTXOH 21 DRUM REMOVAL (EXCAVATION AND REMOVAL OF ALL KNOWN AND SUSPECTED
BURIED DRUMS AND ASSOCIATED SOILS)
Estimated Capital Costs $514,000*
Annual Operation and Maintenances NONE
Estimated Present Worths $515,000
Estimated Implementation Time: 6 months
•
* The figure is only a rough estimate: the actual cost will depend on the number
of drums encountered.
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The excavation and removal of all known and suspected burled drums and associated
contaminated soils prior to capping is an additional, separate option that could
be used in conjunction with any or all of the containment Alternatives LF-3
through LF-7. Under this option, excavation would be initiated at two (2) test
pit (TP) cluster locations (see figures 3 and 4), which inc .udes TP-10 through
TP-17 and TP-19 until ground water is encountered, the fill area depth limit is
reached, or until no more drums are found. All excavated drums and visually
contaminated soils would be sampled and tested. Contaminated materials would be
shipped off-site for proper disposal. The Site would be regraded after drums
were removed prior to installation of the selected cap.
-SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES
V
In accordance with the NCP, a detailed analysis of each remedial alternative was
conducted with respect to each Of the nine criteria described below. This
section discusses and compares the performance of the re. edial ilternatives
considered against these criteria. All selected alternatives must at least
attain the Threshold Criteria. The selected alternative should provide the best
balance among the nine criteria. The Modifying Criteria were evaluated following
the public comment period.
During the detailed evaluation of remedial alternatives, each alternative was
assessed utilizing nine evaluation criteria as set forth in the NCP. These
criteria were developed to address the requirements of Section 121 of CERCLA to
ensure all important considerations are factored into remedy selection decisions.
Threshold Criteria
1. Overall Protection of Human Health and the Environment addresses
whether or not an alternative provides adec^te protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with Applicable and Relevant and Appropriate Requirements
(ARARs) addresses whether or not an alternative will meet all of the
ARARs of the Federal and State environmental statutes or provide a
basis for invoking a waiver.
Balancing Criteria
3. Long-term Effectiveness and Permanence refers to the magnitude of
residual risk and the ability of an alternative to maintain reliable
protection of human health and the environment over time once
remedial objectives have been met.
4. Reduction of Toxieity, Mobility, or Volume addresses the statutory
.preference for selecting remedial actions that employ treatment
technologies that permanently and significantly reduce toxicity.
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mobility, or volume of the hazardous substances as a principal
•lament.
5. Short-term Effectiveness refers to the period of time that is needed
to achieve protection, as well as the alternative's potential to
create adverse impacts on human health and the environment that may
result during the construction and implementation period.
6. Xmplementability 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. Support Agency acceptance indicates whether, based on ite review of
the RI and VS reports and the ROD, the support agency opposes,
and/or has identified any reservations with the preferred
alternative.
9. Conunity acceptance refers to the public's general response to the
alternatives described in the ROD and the RI/FS reports. Responses'
to public comments are addressed in the Responsiveness Summary of
this Record of Decision.
A comparative analysis of these alternatives, based upon the evaluation criteria
noted above, is presented below.
Overall Protection of Human Health and the Environment
Except for the No Action and Minimal Action alternatives, all of the containment
alternatives, LF-3 through LF-7, would minimise the potential hu-nan and
ecological risk. These alternatives would also minimize preci-citation
infiltration to the waste, thereby reducing the potential for contamination
migration. The Sip Avenue ditch sediments would be isolated from future exposure
potential.
However, capping would result in the loss or alteration of terrestrial and
aquatic wildlife habitats in the FJP Landfill area. Some estuarine emergent
wetlands would be capped as part of the proposed actions. Shallow water aquatic
habitat in the Sip Avenue ditch would be lost as a result of the proposed
filling. These actions generally could result in a loss, of some wetland-
associated species from the immediate Site area and in the loss of aquatic life
from the ditch area. Terrestrial species adapted to grass/field environments are
likely to inhabit the area once vegetation has been established on the cap. in
order for the capping alternatives LF-3 through LF-7 to meet this criterion,
wetlands mitigation activities (i.e. restoration, land banking) would have to be
implemented at the Site.
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Option 2s Removal of Drums, in conjunction with any of the capping alternatives,
would provide protection of human health and the environment by reducing on-site
contaminant concentrations and potential impacts to ground water quality.
Compliance with JUtARs
Actions taken at any Superfund site must achieve ARARs of federal and state laws
or provide grounds for waiving these requirements. The Mo Action, Minimal
Action, and LF-3s Soil Cover alternatives, do not comply with federal and state
ARARs which regulate the closure and capping of either solid waste or hazardous
waste landfills.
The No Action, Minimal Action, and capping alternatives do not address
contamination in Sip Avenue Ditch sediments which are at levels in exceedance of
the criteria set forth in NOAA sediment screening criteria. However, the capping
alternatives all provide for replacement of the Sip Ave ditch with an alternative
form of drainage, and would also provide protection from rainwater infiltration,
thus reducing potential migration of subsurface contaminants into the ground
water. '
As part of the IRM in 1986 an estimated 10,000 drums (4,700 intact and 5,000 with
contaminated soil) were disposed of off-site. ARAR compliance would be aided by
Option 2 in conjunction with any of the capping alternatives.
Because Mo Action and Minimal Action alternatives do not meet both threshold
requirements of overall protection of human health and the environment or
compliance with ARARs, they will not be discussed further in the evaluation of
alternatives.
Long-Ten Effectiveness and Permanence
i
The capping alternatives would promote surface water run-off; cap
implementability will offset the need for ground water collection and treatment.
Ground water data has shown a significant reduction in contaminant concentration
on the IRM capped portion of the landfill. This fact suggest that by
implementing one of the capping alternatives the natural attenuation of ground
water would be enhanced, while at the same time isolating the Sip Avenue Ditch
sediments from future exposure potential. However, the capping alternatives do
vary in permeability. The least permeable cap will provide the least migration
of landfill contaminants off-site. Alternative LP-7, Mew RCRA Hazardous Haste
Cap, has the least permeability while LF-3, Soil Cover, has the greatest.
Option 2 * Drum Removal in conjunction with a capping selection is the most
effective in the long-tern and the most permanent because the most concentrated
areas of contamination would be permanently removed (in addition to the estimated
10,000 drums that were previously removed) from the Site and contaminated
materials would then be shipped off-site for proper disposal.
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Short-Ten Effectiveness
In general, effective alternatives which can be implemented quickly with little
risk to human health and the environment are favored under this criterion. The
capping alternatives without the excavation option have high short-term
effectiveness because they could be implemented relatively quickly (within three
years) and would have relatively minor short-term risks to nearby workers,
residents and commuters.
Construction of any of the capping alternatives would involve some excavation and
handling of contaminated soils during the initial Site regrading, but exposure
could be reduced through the use of suitable protective clothing and equipment.
Exposure of the surrounding community through fugitive dust emissions could be
easily controlled using good construction practices and air monitoring. Short-
term risks to the community, workers, or the environment are expected to be
minor.
However, Option 2 Drum Removal provides potentially increased hazardous
conditions for the workers, community, commuters on the Pulaski Skyway, and the
environment. However, this short term risk can be mitigated with proper health
and safety, community awareness and air monitoring. Potential risks associated
with the drum removal will be addressed during the design phase of the project
via a site specific health and safety plan and an emergency response plan.
Reduction of Toxicity, Mobility or Volume
The capping alternatives without the excavation option would reduce mobility by
preventing the migration of contaminants into the air and off-site run-off via
erosion. The cap would also reduce leaching of contaminants into ground water.
However, these alternatives alone would not reduce toxicity or volume of the
contaminants.
Option 2 Drum Removal, which consists of the excavation and removal of all known
and suspected buried drums and associated soils would reduce the toxicity,
nobility and volume of the contaminated material in the site itself. Option 2
would result in the reduction of the volume of contaminants. In addition, the
capping alternative would further reduce the mobility of any contaminants
remaining on Site after excavation.
Zstpleaentation
All of the alternatives are fairly easily implementable from an engineering
standpoint. The capping alternatives without the excavation option are easy to
implement with the technology, equipment and resources being established and
readily available. The RCRA Hazardous Waste Cap alternatives would take longer
than the Solid Waste Cap alternative due to the multiple layer construction.
Option 2 Drum Removal is feasible, however, the implementation would present some
difficulty due to the potential health and safety hazards. Again, these concerns
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can be mitigated. This option would also add to the length of time required to
implement the remedy.
Cost
The capping alternatives are all the same order of magnitude, with the least
expensive being the Solid Waste Cap and the most expensive being the New RCRA and
NJDBP Hazardous Waste Caps.
Option 2s Drum Removal increases the cost of each of the capping alternatives.
Although subsurface contamination is not a current risk pathway, the excavation
and removal option affords a degree of long-term effectiveness and permanence by
excavation, removal and off-site treatment of buried drums and associated highly
contaminated visibly stained soil. In addition, this option would minimize any
future ground water contamination which may occur as the result of wastes
contained in these known areas. Therefore, the cost of the value added from the
reduction of subsurface contaminants may be warranted by reducing and possibly
eliminating the need for long term ground water treatment.
Support Agency Acceptance
The United States Environmental Protection Agency supports the selected remedy
presented in this Record of Decision.
Cnonmitr 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 August 18, 1994, were evaluated.
The majority of comments received during the public comment period originated
from the potentially responsible parties (PRPa). Their comments focused on the
definition of landfill boundaries, the appropriateness of the preferred cap with
respect to scope and effectiveness, as well as future use. Concerns were also
raised during the public meeting regarding how reasonable risk is determined and
the impact this remediation may have on currently operating facilities in the
vicinity of the landfill. The PRPa were concerned that a portion of the landfill
area (as it was depicted in the PS drawings) was not a part of the PJP landfill
site. • : -
The responses to these and other comments are addressed in.the Responsiveness
Summary. . Comments received during the public comment period indicated that the
local residents were mostly satisfied with the preferred alternatives for the
soil and ground water.
SELECTED REMEDY
NJDBP and EPA have determined after reviewing the alternatives and public
comments, that Alternative LF-4 with Option 2 is the appropriate remedy for the
Site, Because it best satisfies the requirements of CERCLA $121, 42 U.S.C.S9621,
and the NCP's nine evaluation criteria for remedial alternatives, 40 CFR
S300.430(e)(9).
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Alternative LP-4: Modified NJDEP Solid Haste Cap (extending existing cap) i
$22,022,000, replacement of the Sip Ave ditch with an alternate form of drainage,
and Option 2t Drum Removal (Excavation and Removal of All Known and Suspected
Buried Drums and associated contaminated soil): $514,000, is the most appropriate
remedy for the PJP Landfill Site.
The major components of the selected remedy include the following:
• Removal of all known and suspected buried drums and associated visibly
contaminated soil;
• Capping the remaining landfill area of Site with a multi-layer, modified
solid waste type cap;
• Extending the existing gravel lined ditch around the perimeter of the Site
to collect the surface water runoff;
• A passive gas or active venting system installed in the new portion of the
cap. However, if an active system is deemed necessary, both areas will be
included;
• Site fencing and institutional controls (e.g., deed restrictions and
public information program);
• Periodic inspections of the cover installed during the IRK must be
performed before and during the implementation of the remedial action. If
the cover is damaged or degraded, then at least 1 additional foot of
topsoil should be spread over the previously installed cover.
• Replacing the Sip Ave ditch with an alternate form of drainage;
• Quarterly ground water and surface water monitoring to evaluate the
reduction of contaminant concentrations over time; if a significant
adverse impact is found, NJDEP and EPA will evaluate remedial alternatives
and select an appropriate remedy in accordance with CERCLA and the NCP.
• Because contamination levels in the ground water are above the Class IIA
GWQC, a CEA/HRA will be established;
• Implementation of a wetlands assessment and restoration plan. The
wetlands assessment will be performed before any of the remedial actions
are begun.
The multi-layer cap would comply with NJDEP sanitary landfill closure
requirements. Since removal of all known and suspected buried drum material and
associated visibly contaminated soils would remove the significant hazardous
waste known to be deposited in the landfill, closure utilizing a RCRA hazardous
waste cap is not necessary. Based on the results of the baseline risk
assessment the Site does not currently present an immediate risk to human health
and the environment via the groundwater or surface water exposure pathway*.
Therefore, NJDEP and EPA determined it was appropriate to monitor and evaluate
groundwater and surface water for a 5 year period, and then assess what
additional measures, if any, should be implemented. The use of a passive or
active gas venting system would be determined during the remedial design phase
of the project.
The capped area would require quarterly inspections and replacements, as
necessary, of grass, seed and topsoil. Ground water and surface water monitoring
will be performed quarterly to evaluate the reduction of contaminant
concentrations and to determine if natural attenuation is occurring at the sit*.
The Site would be reviewed for five years in order to evaluate effectiveness of
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the remedy. The review will also include an assessment of current residual
health risks, an evaluation of the effectiveness of the Site fencing to control
access, and an evaluation of what additional remedial measures, if any, should
be implemented based on the reviewed Site conditions.
The selected alternative provides the best balance among alternatives with
respect to the evaluation criteria. NJDEP and EPA believe that the selected
alternative would be protective of human health and the environment, would comply
with the Remedial Action Objectives, would be cost-effective, and would utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
The excavation and removal of drums and surrounding highly contaminated soil is
protective of human health and the environment. The selected alternative has a
favorable short-term effectiveness because it could be implemented relatively
quickly. The selected alternative also, provides for long-term effectiveness and
pfrmanftit?* by removing and treating the highly contaminated materials from
disposal areas. The long-term effectiveness and permanence of the alternative
outweigh short-term risks associated with excavation.
Remedial Investigation and subsequent sampling results indicate that
contaminants' concentrations in the shallow aquifer are reducing over time.
Ground water contamination in the deep aquifer is at concentrations below any
level of concern at the present time.
Implementation of the selected alternative (i.e., capping and drum removal) will
reduce the leaching of contaminants into ground water. The five year ground
water and surface water monitoring program and the model will enable NJDEP and
EPA to reevaluate Site conditions and determine the effectiveness of the remedy
selected. If a significant adverse impact is found, NJDEP and EPA will evaluate
remedial alternatives and select an appropriate remedy in accordance with CERCLA
and the NCP.
The preferred alternative provides protection to human health .by preventing
direct contact with the contaminated material, and by preventing the migration
of contaminants by reducing infiltration and erosion. Moreover, the combination
of this alternative and the excavation and removal of drums and surrounding
contaminated soil option, would satisfy the statutory preference for remedies
which utilize treatment as a principal element.
NJDEP realizes the inherent short-term risks associated with excavation and
removal of contaminated drums and surrounding soil. For this reason, NJDEP would
implement a comprehensive Site Health and Safety Plan to mitigate the short-ten
risks to nearby workers, residents, and commuters.
Maintaining the level of risk reduction afforded by the proposed remedy depends
on preserving the long-term integrity of the cap and enforcement of institutional
controls. Institutional controls would include use restrictions to restrict
future use of the Site and public information programs to increase the public
awareness of potential problems associated with the Site. The NJDEP Solid «u*te
Cap has proven to be a very effective and reliable remedial technology.
Implementing the NJDEP Solid Waste Cap also presents few short-term rick*, in
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addition, the NJDBP Solid Waste Cap with the incorporation of the existing IBM
cap provides the maximum .protection to human health and the environment at a
reasonable cost.
STATUTORY DETERMXKAXXON8
Under its legal authorities, EPA's primary responsibility at Superfund sites is
to undertake remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences, these specify that when complete, the
selected remedial action for the PJP Landfill Site must .comply with applicable,
or relevant and appropriate environmental standards established under federal and
state environmental laws unless a statutory waiver is justified. The selected
remedy also must be cost effective and utilize permanent solutions and
alternative treatment technologies or resource-recovery technologies to the
maximum extent practicable. Finally, the statute includes a preference for
rent* -Uea the"-, emp* ~y treatment that permanently and significantly reduce the
volurte, toxicity, or mobility of hazardous wastes. 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, as it
effectively addresses the principal threats posed by the Site, namely:
Chemical-specific ARARs*
r. Safe Drinking Water Act (SDWA) Maximum Contaminant Levels
(MCLs)t
(40 CFR Part 141)
» clean Water Act Water Quality Criteria (WQC)t
(40 CFR Part 131)
» RCRA Maximum Concentration Limits (MCLs)i
(40 CFR 264)
> RCRA Land Disposal Restrictionsi
(40 CFR 268)
» New Jersey Safe Drinking Water Act MCLs:
(NJACt 7s10-16)
» New Jersey Water Pollution Control Act Standards for
Groundwaters
(NJACi 7*9-6)
. » New Jersey Water Pollution Discharge Elimination System:
(NJACl 7:14A)
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* New Jeraey Surface Water Quality Standards:
(KJAC 7:9-4.1)
Location-specific ARARa:
»• clean Water Act, Section 404:
(33 USC 466)
»> Executive Orders on Floodplain Management and Protection
of Wetlands:
(B.O. 11988, 11990)
» BPA/COF. Memorandum of Agreement on Wetlands Protection
*• Pish and Wildlife Coordination Act:
(16 U,rC 661)
» Endangered Species Act:
(16 DSC 1531)
» National Historic Preservation Act:
(16 USC 470)
» New Jersey Flood Hazard Area Control Act:
(NJSA 58:6A-50)
» New Jersey Freshwater Wetlands Protection Act:
(NJSA '. 3:98-1)
»> New Jer» ly Freshwater Wetlands Transition Area Rules t
(NJAC 7:7)
» New Jersey Freshwater Wetlands Protection Rules:
(NJAC 7:7A)
» New Jersey Stream Encroachment Regulations:
(NJAC 7:13-1.1)
Action-specific ARARs:
» Clean Water Act Water Quality Criteria (WQC):
(40 CFR Part 131)
» RCRA Land Disposal Restrictions:
(40 CFP 268)
+ Clean Air Act National Ambient Air Quality Standards:
(40 CFR Part 50)
, » OSHA General Industry Standards:
(29 CFR 1910)
-------
25
» OSHA Safety and Health Standards:
(29 CFR 1926)
» OSHA Record Keeping, Reporting, and Related Regulations:
(29 CFR 1904)
» RCRA Standards for Generators of Hazardous Haste:
(40 CFR 262.1)
» RCRA Standards for Transporters of Hazardous Haste:
(40 CFR 263.11, 263.20-21, and 263.30-31)
» RCRA Standards fr-• Owners/Operators of Permitted
Hazardous Haste v*cilities:
(40 CFR 264.10-264.18)
» RCRA - Preparedness and Prevention:
(40 CFR 264.30-ji)
» RCRA - Contingency Plan and Emergency Procedures:
(40 CFR 264.50-264.56)
> RCRA - Groundwater Protection:
(40 CFR 264.90-264.109)
» RCRA - Standards for Excavation and Fugitive Dust:
(40 CFR 264.251-P64.254)
» RCRA - Miscellaneous Units:
(40 CFR 264.600-2*4.999)
» RCRA - Closure and Post-Closure
(40 CFR 264.110-264.120)
» DOT Rules for Transportation of Hazardous Materials:
(49 CFR 107, 171.3-172.558)
» New Jersey Hazardous Haste Manifest System Rules:
(HJAC 7:26)
» New Jersey Hazardous Haste Treatment Storage and Disposal
Facility Permitting Requirements:
(RJAC 7:26)
» New Jersey Hater Pollution Discharge Elimination System:
(NJAC: 7ll4A)
» New Jersey Surface Hater Quality Standards:
(NJAC 7:9-4.1)
» New Jersey Clean Air Act:
(NJSA 26:2C)
-------
» Hew Jersey Air Pollution Control Act:
(NJAC 7i27-5, 13, 16, and 17)
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, including both the
selected capping alternative and drum removal, is $22,536,000.
Utilisation of Permanent solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
Capping the Site would provide protection from .rainwater infiltration, thus
reducing potential migration of subsu"face contaminants into ground water. This
will significantly reduce the toxici* ;, mobility and volume of the contaminants,
and offer a permanent solution to the risks posed by surface soils.
Preference for Treatment as a Principal Element
In keeping with the statutory preference for treatment as a principal element of
the remedy, the remedy provides for the excavation and removal of known buried
drums and associated contaminants, which, would be shipped off-site for disposal,
possibly by incineration.
The treatment of landfill material, however, is not practicable, because of the
size of the landfill and because the identified on-site hot spots that
represented the major sources of cent, mination were removed during the IRM.
DOCUMENTATION OP SIGNIFICANT CHANGES
The Proposed Plan for the Site was released to the public on August 2, 1995. The
Proposed Plan identified the preferred alternatives for groundwater and soil
remediation. EPA reviewed all written and verbal comments received during the
public comment period. Upon review of these comments, DEP determined that no
significant changes to the selected remedy, as it was originally identified in
the Proposed Plan, were necessary.
-------
APPENDIX I
FIGURES
flour* f Identification
1 General Location Map
2 PJP Site Map
3 Teutpit (TP #10 - #17) Location
4 Teetpit (TP #19) Locat'on
-------
Figure }
Sile Location Map
PJP LANDFILL. JERSEY CITY, NEW JERSEY
ICF TECHNOLOGY, INC
-------
Avenue
LEGEND
— Fence
Dirt Road
-•Fire Break
Building
200
PJP LANDFILL JERSEY CITY, NEW JERSEY
-------
TP-14 1P-15
<"'
LEGEND
Fence
| Building
Dirt Rood
Fire Break
Drum Storage Pad
Non Shock
Sensitive Drum
Test Pit Location
FIGURE 3
Non Shock Sensitive Test Pit Locations
PJP LANDFILL, JERSEY CITY, NEW JERSEY
ICF TECHNOLOGY, INC
-------
Hftckensack
River
I /
,/JV..
Sip Avenue
LEGEND
- Fence
| Building
Dirt Rood
Fire Break
Shock Sensitive
Zone
Drum Storage Pad
Shock Sensitive Drum
Test Pit Location
0
FIGURE 4
Shock Sensitive Test Pit Locations
PJP LANDFILL, JERSEY CITY, NEW JERSEY
ICF TECHNOLOGY, INC
-------
APPENDIX II
TABLES
Table t Ident if ication
5-15 Summary Of Chemical Potential Concern At The PJP Landfill Site
5-17 Summary of Exposure Pathways To Be Evaluated For The PJP
Landfill Site
5-24 Potential Exposures And Risks Associated With Incidental
Ingestion And Dermal Absorption Of Chemical In Surface Soils
By Children Trespassing On The Landfill (Current Land Use)
5-25 Potential Exposures And Risks Associated With Incidental
Ingestion And Dermal Absorption By Children Of Chemicals In
Sediment Prom The Hackensack River Above The Sip Avenue Ditch
(Current Land Use)
5-26 Potential Exposures And Risks Associated With Incidental
Ingestion And Dermal Absorption By Children Of Chemicals In
Sediment Prom The Hackensack River Above The Sip Avenue Ditch
(Current Land Dee)
5-27 Exposure And Risks Associated With Incidental Ingestion And
Dermal Absorption By Children Of Chemicals In Sediment From
The Hackensack River Downgradient Of The Ditch At The Western
Corner Of The Capped Landfill (Current Land Use)
5-29 Potential Exposures And Risks Associated With Dermal
Absorption By Children Of Chemicals In Surface Water In The
Sip Avenue Ditch (Current Land Use)
5-30 Potential Exposures And Risks Associated With Incidental
Ingestion and Dermal Absorption By Children Of Chemicals In
Surface Water In the Hackensack River Above The Sip Avenue
Ditch (Current Land Use)
5-31 Potential Exposures And Risks Associated With Incidental
Ingestion And Dermal Absorption By Children Of Chemicals In
Surface Water In the Hackensack River Downgradient Of The
Ditch At The Wester Corner Of The Capped Landfill (Current
Land Use)
5-35 Potential Exposures and Risks Associated With Inhalation Of
Volatile Chemicals By Trespassing Children (Current Land DM)
5-36 Potential Exposures And Risks Associated With Inhalation Of
Volatile Chemicals By Nearby Residents (Current Land UM>
5-37 Potential Exposures And Risks Associated With Inhalatioa of
Volatile Chemicals By Nearby Residents (Current Land UM>
-------
5-39 Potential Exposures And Risks Associated With Ingestion Of
Chemicals In Groundwater (Hypothetical Future Land Ose)
-------
Table 5-15
SUMMARY OF CHEMICALS OF POTENTIAL CONCERN AT THE PJP LANDFILL SITE
Chemical
Organic:
Acetone
Aldrln
elpha-BHC
Benzene
Benzyl alcohol
Bts(2-ch1oroethyl)ether
• Blal2-chloro1sopropy1)ether
Bto(2-ethylhexyl)phthalate
• .2-Butanone
Carbon tetrachlorlde
CMordane
Chlorobenzene
Chloroethane
Chloroform
001
Dt-n-butylphthalate
Dl-n-octylphthalate
1 4-Dlchlorobenzene
3 3'-Dlch1orobenzldlne
1 1-Dlchloroethane
1 2-0 Ichtoroe thane
1 1-Dtchloroethene
trana-1 . 3-Otchloropropene
Oleldrtn
2.4-Dlmethylphenol
Dlmethylphthalate
Oloxln
Cndosulfan sulfate
Endrln
Ethylbenzene
Heptachlor
Heptachlor epoxlde
2-Hexanone
Nethylene chloride
3-Nttroanlltne
4-N It roan Illne
n-NltrosodlphenylaBlne
n-M 1 troso-dlpropy lamlne
PAH-cPAH
PAH-ncPAH
PCBs
Patrolmmi hydrocarbons
Phenola (total)
latrachloroathane
I.l.l-Trlchlordathane
TrtchlorMthane
vinyl acetate
Vinyl chloride
ILI lenea
Surface
Soli
.
X
X
X
.
X
X
X
X
X
X
X
X
X
Subsurface
Soli
X
X
X
. X
X
X
X
X
X
X
X
X
X
Surface Water
Ditch River West of
Test Above I ndflll
Pita Ground* ter Ditch
X
X
X .
X X XX
X X
X X X
X X
X X
X
X
X
XXX
X
X
X X
X
x •
!. X
.x
X
X
X
X .
X
X
X •
x x •
X X
'X .
X
XXX.
X X
X
X
X
X
Sediment
Ditch River Vest of
Above Landfill
Ditch Air
X- XX X
XX X
x • '
X
XX X
X
X X
X
X
_
X
x x
X X
X
XXX
x •
X X X
X X
X
X . X'
X
X
-------
Table 5-15 (Continued)
SUMMARY OF CHEMICALS OF POTCNTIAL CONCERN AT THE PJP LANDFILL SITE
ChMlcal
Inorganic:
AlwHnua
Ant tony
Arsenic •
Barlm
Berylltua
Cadilua
Catclua
Chloride
Chroalua
i Cobalt
Copper
Iron
lead
Magnes lu*
Manganese)
Mercury
Nickel
Potass lui
SelenluD
Sodlua
Sulfate
Thai llu«
Vanadlua
Zinc
•
Surface
Soil
X
X
x
X
X
• '
Subsurface
*.!•
X
X
X
X
X •
X
x
X
Surface
Ditch Rivrr
T«st Ajove
r.ts GrouKfcater Ditch
X XX X
X X
X
X
X
x
X
X
X
X
X
•
X
X
X
• X
X
X
X
X
X
X
X
• x
X
X
X
Water
West of
Lar.fi 1
X
X
X
X
X
X
X
X
X
X
X
X
Ditch
X
X
X
X
X
X
X
X
• x
X
X
X
X
. Sedlnent
River Vest of
Above Landfill
Ditch .
X
X
X
X
X
X
X
X X .
X
X
-------
TABLE 5-17
SUMMIT OF EXPOSURE PATHWAYS TO BE EVALUATED FOR THE PJP LANDFILL SITE
Potentially Exposed Population
Exposure Pathway
Current Land Use:
Trespassing children playing
on the landfill remediation/
staging area
Trespassing children vading
In tha Sip Avanut Ottch
Trespassing rMldrtn miming
In tha Hackansack Rlvar ntar
tha slta
Vorfcara
Residents
Hypothetical Future Use:
Residents
Workers
Dermal absorption and incidental fngestlon of surface
soil
Inhalation of chemicals released froei landfill, vents
Demal absorption of chemicals In Sip Avenue Ditch
sediment and surface water/and Incidental Ingest 1on
of chemicals In sedioent
Denaal absorption and Incidental Ingestlon of
chemicals in Hackeniack River surface Mter and
sediment
Inhalation of chnicals released from landfill vents
«nd dispersed offsite to adjacent businesses
Inhalation of chemicals released from landfill vents
and dispersed offsite to nearby apartment buildings
Ingest Ion of grounowater from the shallow and deep
aquifers (combined)
Denial absorption and incidental Ingestlon of
surface and subsurface soil and test pit material.
(Qualitative evaluation only.)
Inhalation of chemicals released from landfill vents.
(Qualitative evaluation only.)
-------
TABLE 5-24
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INCIDENTAL INGESTION AND DCRNAL ABSORPTION
OF CHEMICALS IN SURFACE SOILS BY CHILDREN TRESPASSING ON THE LANDFILL
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Quantity of Chewlcal
Soli Concentration (a) Ingested and Absorbed (b)
(•0/kg) (axj/kg-day)
' . • • Geometric Average
EtiMtuI Mean Nutan Case
IreeAlb >• l.OOC*01 t.9IE«OI 3.64E-07
Its(2-ethy1hexyl)phtha1ate 1.70E+01 I.40E*02 9.27E-08
HtlordaiM 4.rC-02 5.6SE-02 2.60E-10
Ihtoroforai 7.70E-03 7.IOE-02 t.BOi-.U
l.2-0tchtoroethane S.20E-03 I.90E-02 I.89E-IO
PAH~cPAH I.OKtOO «.40E«00 S.4SC-09
retrachloroethene I.05E-02 I.SOE-01 3.82E-IO
rrlchloroethene 7.40C-03 6.70E-02 2.B9E-IO
roTAL
Plausible
HaxlauB Case
S.29F-06
1.27E-05
S.14E-0"
1.29E-05
3.45E-09
2.I8E-07
2.73E-08
I.22E-08
Quantity of Chemical
Absorbed Denial 1y (c)
(•g/kg-day)
Average
Case
1.09E-08
S S6E-09
2!lOC-!9
I.42E-IO
0.82C-IO
2.86E-IO
2.02E-IO
Plausible
Maxlaua Case
3.09E-06
.49E-OS
.OIE-09
.29E-08
.68E-08
.70E-07
.33E-07
S.94E-08
Combined Chronic
Daily Intake (COI) (d)
(•g/kg-day)
Average
Case
3
9
3
4
a
«
4
.7SE-07
.83E 08
.f?E ~.f
.90£-l«/
.3IE-IO
.44E-09
.68E-IO
.7IE-IP
Llfetlae Upper Bound
Excess Cancer Risk (f)
Plausible Potency Factor (e) Average
Maxlmue Case (Mg/kg-day)-! Cast
8.
2.
9.
2!
3.
1.
7.
39E-06
76E-05
ME--«9
03E-08
88C-07
60E-07
16E-08
2.0E*00
I.4E-02
I.3E«00
6.1E-03
9.11-02
I.2E+OI
5.IE-02
I.IE-02
7E-07
IE-09
4E-10
3E-I2
3C-II
7E-08
. 3E-II
SE-12
. 8E-07
Plausible
Mailaua Celt
2E-OS
4E-07
IE-09
21-09
4E-08
8C-09
BE -10
2E-OS
MNCMCINOGERS
Quantity of Chealcal
Soli Concentration (•) Ingested and Absorbed (b)
(••All (ea/kg-day)
Geometric • Average
:he«tca1 Mem Nmtaua Cast
Inttamy 1.07*41 3.93E+01 8.78E-06
Iraenlc I.OOE«OI t.9IE«Ol 4.24E-08
»U(Z-ethy1he>cyl)phtna1aU I.70E*OI l.40f*02 1.08E-06
tatelus S.80E«00 2.8IE»01 2.38E-06
Chtordam 4.77E-02 S.8SE-02 3.04E-09
Utlorofom 7.70E-03 7.10E-02 3.27E-09
Endrln 1.I6E-01 7.SOE-OI 7.38E-09
Mercury 6.00E-OI I.70E«00 2.S5E-07
letrachloroathem I.OSE-02 I.50E-OI 4.45E-09
rrlchloroethene 7.40E-03 6.70E-02 3.14E-09
WIZARD INOCI —
t
b
t
d
f
Concentration* as reported In Table S-2.
SM tail for awthodoloay. Calculated using equation 1 and
*•• !••! for ••thodology. Calculated using equation 2 and
!>• of Ingaatlon and deraul Intakes.
••ported pr««lo««lr In Table 5-19.
CcUultwl »> •ultlplrlna the COI by the potency factor.
Calculated »y aHvlaJlng the COI by the RfbT
Plausible
Naxleua Case
B.34E-OS
8.I7E-OS
I.48E-04
S.96E-OS
S.99E-08
I.5IE-07
7.95E-07
3.8IE-06
3.1BE-07
1.42E-07
Quantity of Chaatcal
Absorbed Derajally (c)
(•g/kg-day)
Average
Case
2.63E-07
1. 271-07
8.49E-08
7.13E-08
C.07E-10
2.4SE-09
I.48E-09
7.64E-09
3.34E-09
2.35E-09
assuaptlons presented In
assumptions presented In
Plausible
Maxlaua Csse
4.8BE-OS
9.8IE-OS
I.74E-04
3.49E-OS
4.67E-08
7.34E-07
8.20C-07
2. HE-OS
l.SSE-OC
6.93E-07
Table 5-23.
Table 5-23.
Combined Chronic
Dally Intake (COI) (d)
(•g/kg-day)
Average
Case
9
4
1
2
9
S
8
1
S
.04E-06
.37E-OB
.ISC-08
.45E-08
.64E-09
.72E-09
.86E-09
.62E-07
.79E-09
.49E-09
Plausible
Maxumai Case
1.
9.
3.
9.
1.
8.
1.
S.
1.
32E-04
78E-05
22E-04
45E-OS
07E-07
BSE-07
42E-06
72E-08
87E-08
3SE-07
Reference
Dose
,<"«) (•!,
(•g/kg-day)
4.0C-04
I.OE-03
2.0E-02
l.OE-03
8.0E-OS
I.OE-02
3.0E-04
3.0E-04
I.OE-02
7.3E-03
Ratio CDI:RfO (g)
Average
Case
2E-02
4E-03
6E-OS
2E-03
6E-05
6E-07
3E*05
9E-04
8E-07
7E-07
51 (3E-2)
Plausible
Mailmua Case
3E-OI
IE-01
2E-02
9E-02
2E-03
9E-OS
5E-03
2E-OC
2E-04
IE-04
-------
TABLE S-2S
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INCIDENTAL INGESTION AND DERHAL ABSORPTION BY CHILDREN
OF CHCNICALS IN SEDIMENT FROM THE SIP AVENUE DITCH
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Scdlecnt
Concentration (•)
(•0/kg)
' . Geosjetrlc
IhMtcai Nun Naxlaui
trsenlc ••
lentane '
il»(2-athylhexyt)phthalate
•Jilorofona
lethylene chloride
i-Nltrosodtphenyla«tne
>AH--cPAH
•trachloroethtm
fOTAL
B.70E+00 2.01E«01
I.94C-OI S.82E-01
I.64E«OI 5.90E«01
3.8IE-OI I.64E+00
I.79E+OI 2.30E+OI
3.30E-OI 3.30E-OI
4.77E«00 1.48C*Ol
2.79E-01 1.00e»00
Quantity of Chenteal
Ingested and Absorbed (b)
(•g/kg-day)
Average
Case
3.I6E-07
7.05E-09
B.94E-OB
1.39E-08
6.5IE-07
I.20E-08
•2.60E-OB
1.01E-08
Plausible
Max (sus Case
3.0SE-06
8.82E-OB
4.47E-06
2.48E-07
3.48E-06
S.OOE-08
I.I2E-06
I.S2E-07
Quantity of Chasical Combined Chronic
Absorbed Derwlly (c) Dally Intake (COI) (d)
(•g/kg-diy) ' (svj/kg-day)
Average
Case
I.03E-08
S.73E-09
S.BIE-09
I.I3E-OB
S.29E-07
9.75E-09
5.07E-09
B.24E-09
Plausible
Naxlsus Case
2.33E-06
5.62E-07
6.84E-06
I.58E-06
2.2ZE-05
3.I9E-07
1. HE-OS
9.66E-07
LlfetlM Upper Bound
Excess Cancer Risk (f)
Average Plausible Potency Factor (e) Average
Case Nanism*) Case (ag/kg-day)-l Case
3-.27E-07
1.28E-08
9.53E-08
2.SIE-OB
I.I8E-06
2.I7E-OB
3.1 IE-OB
I.84E-OB
S.37E-06
B.50E-07
1.13E-OS
I.B3E-D6
2.57E-05
3.69E-07
2.26E-06
I.12E-06
2.0E«00
2.9E-02
I.4E-02
S.IE-03
7.5C-03
4.9E-03
1.2E«Ot
5.IE-02
7C-07
4E-10
IE-09
2E-IO
9E-09
IE-10
4E-07
9E-10
IC-OB
Plausible
Naxlsui Case
IE-OS
2C-OB
2E-07
IE-OB
2E-07
2E-09
3E-05
6E-OB
4C-OS
NONCARCINOGENS
•
Swltaent
Concentration (•)
(•g/kg)
GeoMtrtc
Hweleal Nun Naxlsui
kntlMony
Irsenlc
vrtu*
ktryniusi
Hs(2-ethylhexyl)phthalate
jhtorofor*)
•°ope'
larcury
tothyTent chloride
ticket
fetrachloroethene
tine
HAZARD INDEX
.07E+OI .3K«OI
.70C*00 .OIE*OI
.06£»02 .83E+02
.30E*00 .S8E«OI
.64E«01 .90C«OI
.81E-01 .64E+00
.S2E«02 .40E«04
.OOE-OI .IOE»00
.79E+OI .30E401
.64E«OI .26E«03
.791-01 .OOC400
.72E«02 .83E«03
Quantity of ChMlcal
Ingested and Absorbed (b)
(ae/kg-day)
Average
Case
.30E-05
.69C-06
.74E-OS
.40E-08
.04E-06
.62E-07
.I9E-04
.82E-07
.59E-06
.39E-OS
.IBE-07
.27E-04
• Concent rat tent •• reported In Table 5-11.
b VM lait ror •ethodology. Calculated using equation 1 and
c !•• !••! for ••thodology. Calculated using aquation t and
d SUB of IngastloH Mid dams! Intakes.
a ••ported previously in Table 5-19.
f) Calcutta* by awl tip lying the COI by the potency factor.
Plausible
MaxlM Case
.66C-04
.S5E-05
.2IE-03
.56E-05
.2IE-05
.90C-06
.OIE-02
.OIE-06
.07E-OS
.23E-03
.77E-06
.74E-02
Quantity of ChMlcal CoB*»»^d Chronic
Absorbed Oemally (c) Dally Intake (CDI) (d)
(•g/kg-day) (sq/kg-day)
Average
Case
.23E-07
.20E-07
.84E-06
.55E-08
.7BE-08
.31E-07
.04C-OS
.24E-OB
.17E-08
.7BE-07
.62E-08
.06E-05
assunptlons presented In
•nucptlont prasantad In
Plausible
Naxlsui Cast
.27E-04
.m-os
.24E-04
.49E-05
.98E-05
.8SE-05
.60E-02
.90E-OS
.59E-04
.70E-03
.I3E-05
I.33E-02
Table 5-23 and
Table 5-13 and
Average Plausible
Case Nailsusi Case
.34C-OS
.8IE-06
.02E-OS
.45E-08
.HE -06
.93E-07
.29E-04
.94E-07
.38E-05
.47E-05
.15E-07
.3BE-04
In the text
In tha taut
.93E-04
.27E-05
.13E-03
.OSE-OS
.32E-04
.14E-05
.06E-OI
.59E-05
.OOE-04
.93E-03
.30E-OS
.07E-02
Reference
Dose
(RfO) (e)
(•g/kg-day)
.OE-04
.OE-03
.OE-02
.OE-03
.OE-02
.OE-02
.7E-02
.OE-04
.OE-02
.OC-02
.OC-02
.OC-OI
Ratio COI :RfO (g)
Average
Case
3E-02
4E-03
2E-03
3E-04
BE-05
3E-OS
9E-03
1C-03
2E-04
IE-03
2E-05
2E-03
-------
TABLE 5-28
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INCIDENTAL INGEST ION AND DERMAL ABSORPTION BT CHILDREN
OF CHEMICALS IN SEDIMENT FROM THE HACKENSACK RIVER ABOVE THE SIP AVENUE DITCH
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Sediment
Concentration (a)
(•gAg)
Geometric
Itwelcal Mean Naxlaua
Ireenfc
kfflMM
Ils(2-ethylhexyt)phtha1ate
Zhlorpfore)
i-Nltroso-dlpropvlaMlne
t-Nltroaodlahany lamina
PAH-cPAM
IOTAL
.771*01 6.3«E«OI
.OOE-03 I.OOE-03
.IIE*00 4.70E*00
.OOE-03 1.40E-02
.13E-OI 5.70E-OI
.60E-OI I.60E-OI '
.9IE»00 5.89E»OI
Quantity of Chesilcal
Ingested and Absorbed (b)
(•g/kg-day)
Average
Case
.44E-07
.64E-1I
.05E-09
.I8E-IO
.501-08
.921-09
.661-08
Plausible
MaxlM Case
9.6IE-08
I.52E-10
3.56E-07
2.I2E-09
8.64E-08
2.42E-08
4.46E-06
Quantity of Chemical Combined Chronic
Absorbed Oerawlly (c) Dally Intake (COI) (d)
(•g/kg-day) («g/kg-day)
Average
Case
2.09E-08
2.95E-1I
3.94E-IO
I.77E-IO
1.22E-OB
4.73E-09
S.22E-09
Plausible
Naxleue Case
7.3SC-06
9.66E-IO
5.45E-07
1.3SE-08
5.5IE-07
I.5SE-07
4.S5E-06
LlfetlM Upper Bound
Excess Cancer Risk (f)
Average Plausible Potency Factor (e) Average
Case Maxlmwi Case (mg/kg-day)-! Case
B.6SC-07
B.S9E-II
B.45E-09
3.9SE-IO
2.77E-08
I.OSC-OS
3.20E-08
.70E-05
.I2E-09
.OIE-07
.56E-08
.37E-07
.79E-07
9.0IE-06
2.0£*00
2.9E-02
I.4E-02
6. IE-03
7. Of .00
4.9E-03
I.2E»OI
lt-08
2E-12
9E-II
2E-I2
2E-07
5E-II
4E-07
2E-08
Plausible
Maxlaue Case
3E-05
3E-I1
IE-OB
IE-10
4E-06
9E-IO
. IE-04
IC-04
NONCARCIN06ENS
Sediment
Concentration (a)
(•gAg)
Geometric
ihomlcal Mean Maxlaua
Int fanny
Irsenlc
lartuM
U(2-athylhexyl)phthalato
^delua
:hlorofore)
larcury
WZARO INDEX
.89C+0! 2.20E*01
.77E*OI 8.34E40I
.72E+02 B.I7E«02
.I1E+00 4.70E400
.IOC«00 5.00E«00
.OOE-03 1.40E-02
.60E*00 9.00C«00
Quantity of Chemical
Ingested and Absorbed (b)
(•g/kg-day)
Average
8.02E-06
7.SIC-06
7.30E-05
7.06E-08
1.32E-06
2.5SE-09
B.79E-07
a) Concentrations aa reported In Table 5-12.
b See text for Methodology. Calculated using equation 1 and
c Sa* text for Methodology. Calculated using equation 2 and
d SUM of Ingest Ion and dermal Intakes.
a Reported previously In Table 5-19.
f Calculted b* Multiplying the COI by the potency factor.
t Calculated by dividing the COI by the RfD.
Plausible
3.B9E-05
I.12E-04
I.09E-03
4.I5E-OB
8.B4E-08
2.47E-08
I.S9E-OS
Quantity of Chemical Combined Chronic
Absorbed Denaally (c) Dally Intake (COI) (d)
(mg/kg-day) (ea/kg-day)
•••erage
2.6IC-07
2.44E-07
2.37C-08
4.S9E-09
4.27E-08
2.07C-09
2.21E-08
assuaptlons presented In
assumptions presented In
Plausible
Maxlaua Case
2.97E-05
.S7E-05
.34E-04
.36C-08
.76E-OB
.5BE-07
.22E-OS
Table 5-23 and
Table 5-23 end
Svt/»- J P^au-lbV
Cash Max)** Case
.28E-06
.75E-08
.531- -5
.S2E-08
.36E-08
.61E-09
.OIE-0
In the text
In the text
8.86E-05
.98C-04
.92E-03
.05E-05
.56E-05
.83E-07
2.8IE-05
•
Reference
Dose
(RfD) (e)
(•g/kg-day)
4.0C-04
I.OE-03
5.0C-02
2.0E-02
l.OE-03
I.OE-02
3.0E-04
Ratio CDI-RfD (g)
Average
Case
2E-02
BE-03
2E-03
4E-08
IE-03
5E-07
2E-03
«l (3E-2)
Plausible
Mixiaus Cast
2E-OI
2E-OI
4E-OI
5E-04
2C-02
2E-05
IE-02
«l (5E-I)
-------
TABLE S-2;
POTENTIAL EXPOSURES AM RISKS ASSOCIATED VITH IHCIOCNTAL INGESTIOH AM) DERMAL ABSORPTION BT CHILDREN OF CHEMICALS IN SEDIMENT
FROM THE HACKENSACK RIVCR DOUNGRADIIMT OF THE DITCH AT THE WESTERN CORNER OF THE CAPPED LANDFILL
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
lexical
Its(2-ethy1hexy1)phtha1ato
PAH-cPAB •
fOTAL ' .
Sedleent
Concentration (a]
(•g/kg)
e.ooE-oi
4.90E»OI
I.OBEtOI
Quantity of Chealcal
Ingested and Absorbed (b)
(•g/kg-day)
Average
Case
2.91E-OB
2.67E-07
S.89E-08
Quantity of
Absorbed De
(•g/kg
ChMlcal
nwlly (c)
-day)
Combined Chronic
Dally Intake (COI) (d)
(•g/kg-day)
Lifetime Upper Bound
Excess Cancer Risk (f)
Plausible Average Plausible Average Plausible Potency Factor (e) Average Plausible
MaxImusCase Case Max leue Case Case Max leue Case (eg/kg-day)-l Case Maximum Case
I.2IE-07
3.7IE-08
8.I8E-07
2.36E-08
I.74E-OB
I.I5E-08
7.73E-07
S.68E-06
B.34E-07
S.27E-08
2.8SE-07
7.04E-08
B.94E-07
9.39E-08
I.BSE-06
2.9E-02
I.4E-02
I.2E*OI
2E-09
4E-09
8E-07
BE-07
3E-08
IE-07
2E-OS
2E-OS
NONCARCINOGENS
!hMlca1
Hs(2-othy1hexy1)phthelate
!-Butanone
ll-n-butylphthelate
Ethylbenzene
larcury
>AH--nePAH
ielenlua
I.l.l-Trlchloroethane
HAZARD INDEX
b
c
d
Sedleent
Concentration (a]
(•g/kg)
4.90E*01
4.40E401
I.BOE-01
S.SOE+00
X.OOE-OI
1.85E*OI
S.OOE-OI
I.30E+00
Quantity of Chemical
Ingested and Absorbed (b)
(•g/kg-day)
Average
Case
3.I2E-06
I.87E-OS
4.16E-07
2.33E-06
B.48E-08
I.18E-06
2.I2E-07
S.SIE-07
Concentrations es reported In Table 5-13.
See text for Methodology. Calculated using equation 1 and
See text for Methodology. Calculated using equation f and
Sue of Ingest Ion and denial Intakes.
Reported previously !• Table S-19.
CaV«lted by Multiplying the COI by the potency factor.
takMleled e* elvMtaf the COI by the RfbT
Quantity of Chemical
Absorbed Oerawlly (c)
(•g/kg-day)
Plausible Average Plausible
Mix IMS Case Case Max hew Case
4.33E-OS
7.78E-OS
I.73E-06
9.72E-06
3.S4E-07
I.63E-OS
B.B4E-07
2.3K-06
assumptions
assueptlons
2.03E-07
1.S2E-OS
3.38E-07
I.90E-06
2.76E-09
7.6SE-07
6.89E-09
4.4BE-07
presented In
presented In
B.63E-OS
4.B6E-04
I.IOE-OS
6.20E-OS
2.70E-07
4.I7E-OS
6.76E-07
1.46E-05
Table 5-23
Table 5-23
Combined Chronic
Dally Intake (COI) (d)
(•g/kg-day)
Average Plausible
Case • Maximum Case
3.32E-08
3.38E-OS
7.S4E-07
4.23E-06
B.76E-08
1.94E-OB
2.I9E-07
I.OOC-06
and In the text
and In the »wt
I.IOE-04
S.74E-04
1.28E-OS
7.17E-05
6.24E-07
S.80E-OS
I.S6E-06
I.69E-05
•
• Reference
Dose
(««) (e)
(Mg/kg-day)
2.0E-02
5.0E-02
l.OE-OI
I.OE-OI
3.0E-04
4.0E-OI
3.0E-03
9.0C-02
Ratio COI
:«0 (g)
Average Plausible
Case Maximum Case
2E-04
7E-04
BE-06
4E-05
3E-04
SE-08
7E-OS
IE-OS
-------
TABLE 5-29
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH DERMAL ABSORPTION BY CHILDREN
OF CHEMICALS IN SURFACE WATER IN THE SIP AVENUE DITCH
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Surface Water
Concentration (a)
(•9/1)
Geometric
Cha»tc*1 Mean MaxUua
Irsenlc I.70E-03 .50E-03
ftenzene S.SOE-03 .60E-01
Il*(2-ch1oroethyl)ether I.24E-02 .40E-02
Bit 2-chlorolsopropyl)*ther . I.1IE-02 .10E-02
II* 2-ethylhexyl)phlhalate 2.3SE-02 .70E-OI
Chi ntofM 4.00E-04 .60E-03
Uilorofom 4.20E-03 .OOC-02
ii-NltrosodlphenylMlM 9.20E-03 .30E-02
fOTAl
Chronic Dallv
Intake (COI) (b)
toAg-day)
Llfetlec Upper Bound
Excess Cancer Risk (d)
Average Plausible Potency Factor (c) Average Plausible
Case Maxleua Case lag/kg-dey)-! Case MaxliM* Case
I.09E-09 I.96E-OB
J.52E-09 6.9BE-07
7.94E-09 I.92E-07
7.IOE-09 9.I6E-08
1.50E-08 7.42E-07
2.S6E-10 6.98C-09
2.69E-09 4.36E-08
5.B9E-09 S.67C-08
2.0E+00
2.9E-02
.IE«00
.OE-02
.4E-02
.3E«00
. IE -03
.9E-03
2E-09
IE-10
9E-09
SE-IO
2E-IO
3E-IO
2E-II
3E-II
IC-08
4E-08
2E-08
2E-07
6E-09
If -08
9E-09
3E-IO
3E-10
3E-07
NONCARCIN06ENS
Surface Water
Concentration (a)
to/D
Geometric
EhMtcal Mean HMleua
Ireontc .70E-03 4.SOE-03
tartue .I5E-OI 1.56C+00
It* 2-chlorolsopropyl)ether .111-02 2.IOE-02
II* 2-ethy1hexyl)phtnaUto .3SE-02 I.70E-OI
Chlordme .OOE-04 I.60E-03
tttlorofQni .20E-03 1. OOC-02
UiroMlM .BSE-02 S 70E-02
Ethylbeiuene .OSE-02 4.IOE-OI
Itanganese .I1E-01 8.20E-OI
Mercury .OOE-04 7.0^-04
Mlckel .99E-OZ 9.001-02
•*n«d IM .aa-;: s.m-^
line .261-01 2.3IE-OI
NA/AtD INOEl
Chronic Dally
Intake (COI) (b)
(•g/kg-day)
Average 'Plausible
Cera Maxlaua Case
I.27E-08 2.29E-07
I.6IE-08 7.94E-05
B.m-08 I.07E-06
I.75E-07 8.65E-06
2.99E-09 8.14E-08
3.I4E-08 S.09E-07
1.38E-07 I.90E-06
7.B4E-08 2.09E-05
I.58E-08 4.I7E-OS
I.49E-09 3.56E-08
I.49E-07 4.SBE-08
762E-08 I.5BE-06
I.70E-08 I.I8E-05
• Concent rattan* •• rnortwl In Table 5-8.
fc <•• !••! for •Bthodoiogv. CalcuUtad using equation 4 and ai*u«ptlon*'pre*ented
c ••nortatf erevlomly In Table S-19.
t Calcelled by eultlplrlne the COI by the potency factor.
* Calculated by dividing the COI by the RfD.
Reference
Dose
(RfO) (c)
to/kg-day)
I.OC-03
5. OE-02
4. OE-02
2. OE-02
8.0E-OS
1. OE-02
5.0E-03
I.OE-OI
2.0E-OI
VOE-04
*.0£-^2
7.0E--J
2.0E-OI
In Table 5-28.
Ratio COI
:RfO (e)
Average Plausible
Case Maxlau* Case
IE-OS
3E-05
2E-08
9E-08
5E-05
3E-OB
3E-OS
8E-07
BE-06
SE-08
7E-06
IE-OS
9E-06
«l (2E-4)
2E-04
2E-03
3E-OS
4E-04
IE-OS
SE-OS
6E-04
2E-04
2E-04
IE-04 .
7E-04
wt-04
6E-OS
«l (5E-3)
-------
IABIE 5-30
POTENTIAL EXPOSURES AMD RISKS ASSOCIATED WITH INCIDENTAL INGESTION AND DERMAL ABSORPTION BY CHILDREN
OF CHEMICALS IN SURFACE WATER IN THE HACKENSACK RIVER ABOVE THE SIP AVENUE OUCH
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
y»
Surface Water Quantity of Chamlcal Quantity of Chemical
Concentration (a) Ingested and Absorbed (b) Absorbed DerMlly (c)
(•g/1) (•g/kg-day) (mg/kg-day)
Geometric Average Plausible Average Plausible
•leal* Mean Naxlmum . Case Maximum Case Case Maximum Case
tenieno 3.40E-03 9. OOE-03 3.09E-OB 3.4IE-07 I.03E-OB I.I3E-07
Combined Chronic
Dally Intake (COI) (d)
(•g/kg-day)
llfettas Upper Bound
Excess Cancer Risk (f)
Average Plausible Potency Factor (e) Average Plausible
Case Naxlmum Case (an/kg-day)-! Case Naxlmum Case
4.12E-OB 4.S4E-07
2.9E-02
IE-OB
IE-OB
MOMCARC IMOGENS
Surface Water Quantity of Chemical Quantity of Chamlcal
Concentration (e) Ingested and Absorbed (b) Absorbed Denial ly (c)
(•g/1) to/kg-day) (mg/kg-day)
Geometric • Average Plausible Average Plausible
faMlcal • Mean Naxleue Case Maximum Case Case Naxleue Case
teetone C.BOE-M .ME -02 7.2IE-06 3.00E-05 I.40E-06 I.OOE-05
larlias 7.01E-02 .64E-OI 7.43E-06 I.17E-04 2.47E-06 3.88E-OS
terylUus) 8.00C-04 .OOE-03 B.48E-08 4.42E-07 I.82E-08 1.47E-07
Chromium) 1.55E-02 .30E-02 1.B4E-06 I.46E-OS 5.47E-07 4.B5E-OS
Copper 1.77E-02 .BOE-02 I.B8E-06 3.89E-05 B.25E-07 I.29E-05
Manganese I.S5E-OI .78C-OI I.B4E-OS I.67E-04 S.47E-08 5.S6E-OS
Narcury 3.00E-04 .OOC-04 3.I8E-08 2.85E-07 1.06E-08 B.B2E-OB
MM I.04E-OI .13E-01 2.16E-OS B.4IE-05 7.20E-OB 3.I3E-OS
HAZARD INDEX
a'
b
c
d
e
f
g
Combined Chronic
Dally Intake (CDI) (d)
(•g/kg-day)
Average Plausible
Case Naxtoum Case
9.6IE-06 4.00E-OS
B.9IE-OB I.55E-04
1.I3E-07 5.89E-07
2.I9E-06 I.94E-OS
2.SOE-OB S.I8E-OS
2.I9E-OS I.23E-04
4.24E-OB 3.S3E-07
t.ME-OS l.ZSC-04
Reference
Oose
(m!/kg-d!y)
1. OE-OI
5.0E-02
S.OE-03
.OE-03
.7E-02
.OE-OI
.OE-04
.OE-OI
Ratio COI
:8fO (g)
Average Plausible
Case Naxlmum Case
IE-04
2E-04
2E-OS
4E-04
7E-05
IE-04
IE-04
IE-04
«1 (1E-3)
4E-04
3E-03
IE-04
4E-03
IE-03
IE-03
IE-03
K-04
Concentrations as reported In Table 5-9.
See text for methodology. Calculated using equation 3 and assumptions presented In Table 5-28.
See text for methodology. Calculated using equation 4 and assumptions presented In Table S-2B.
Su« of Ingest Ion and derma) -Intakes.
Reported previously In Table 5-19.
Calculted by multiplying the COI by the potency factor.
Calculated by dividing the CDI by the RfBT
-------
TABLE 5-31
POTENTIAL EXPOSURES AM RISKS ASSOCIATED WITH INCIDENTAL INGESTION AND DERMAL ABSORPTION BY CHILDREN OF CHEMICALS IN SURFACE WATER
III THE HACKENSACK RIVER OOUNGRADIENT OF THE DITCH AT THE WESTERN CORNER Of THE CAPPED LANDFILL
(CURRENT LAND USE)
NONCARCINOGENS
Quantity of Cheelcal Quantity of Chemical
Ingested and Absorbed (b) Absorbed Oeraally (c)
Surface Water (eg/kg-day) (eg/kg-day)
• * tOBCBnif in ion i*if
ChMlcal ',
Barltfa . 2.BOE-02
CnraetUB 1.20E-02
[taper • S OOE-03
Dl-n-butyrphthalate I.20E-02
langanoso I.15E-OI
Narcury 1. OOE-03
Zinc 2.1K-01
HAZARD INDEX
a) Concentratlom ae reported In Table 5-10.
b See text for MthodoTogy. Calculated using
e See text for eethodology. Calculated using
d Sue of Ingest Ion and denes! Intakes.
e Reported previously In Table 5-11.
f J Calculated by dividing the CDI by the RfO.
Coebtned Chronic
Dally Intake (CDI) (d)
(eg/kg-day)
Average Plausible Average Plausible Average Plausible
Case Max IBM Case Case Maxteua Case Case Maxlaua Case
2.97E-06 1.24E-OS 9.88E-07 4.I2E-06
I.27E-OB 5.30C-OB 4.24E-07 1.76E-OB
S.30E-07 2.21E-06 I.76E-07 7.35E-07
I.27E-09 S.30E-OS 4.24E-07 1.76E-06
1.22E-OS S.08E-OS 4.06E-06 I.69E-05
I.06C-07 4.42E-07 3.53E-08 I.47E-07
2.29C-05 9.54E-05 7.62E-OB 3.I8E-05
equation 3 and assumptions presented In Table
equation 4 and assumptions presented In Table
3.96E-06 1.65E-05
.70E-06 7.07E-08
.07E-07 2.94E-08
.70E-06 7.07E-06
.63E-05 B.77E-05
.41E-07 5.89E-07
3.05E-OS I.27E-04
S-2B.
5-2B.
Reference
Dose
(RfO) {e)
(•g/kg-day)
S.OE-02
S.OE-03
3.7E-02
l.OE-01
Z.OE-01
3.0E-04
2.0E-01
Ratio CDI:RfO (f)
Average
Case
BE -OS
3E-04
2E-05
2E-OS
BE -OS
SE-04
2E-04
Plausible
Maxlaua Case
3E-04
IE-03
BE -05
7E-OS
3E-04
2E-03
6E-04
-------
TABLE 5-35
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INHALATION OF VOLATILE CHEMICALS BY TRESPASSING CHILDREN
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Chanlcal
tonzene
Ihloroforn
Hethylene ehlorldt
fetraehloroetoene
rrichloreethene
iMnyl Chloride
rOTAL
Estimated Air
Concentration (a)
(ng/m3)
Average Max lews
1.31E-05 6.74E-04
1.89E-07 2.02E-OS
4.21E-07 7.6SE-05
9.68E-07 2.91E-04
7.74E-07 2.91E-04
1.50E-06 8.57E-04
Chronic Daily
Intake (CDI) fb)
(«g/kg-fl*y)
Llfetiee Upper Bound
Excess Cancer Risk (d)
Average Plausible Potency Factor (c) Average
Cast Ittxlu Case (mg/kg-day)-l Case
1.10E-09 S.02E-06
1.58E-10 1.S1E-07
3.52E-10 5.7IE-07
8.10E-10 2.17E-06
6.47E-10 2.17E-06
1.25E-09 6.39E-06
2.9E-02
8.1E-02
1.4E-02
3.3E-03
4.6E-03
2.9E-01
3E-10
IE-H
SE-12
3E-12
3E-12
4E-10
7E-10
Plausible
Nulaa CAM
1E-07
IE-OS
8E-09
7E-09
IE-OS
2E>06
2E-06
NONCARCIN06ENS
Ihenical
:h1orcbenzene
L.l-Olchloroethane
tethylene ehlorldt
bluene
.l.l-Trichloroethane
(yltnts
IAZARO INDEX
Estimated Air
Concentration (a)
(•g/a3)
Average . Maxlnu*
2.61E-06 7.96E-05
6.29E-07 2.51E-04
4.Z1E-07 7.66E-05
7.74E-06 1.44E-03
2.08E-07 1.44E-04
1.98E-05 4.81E-03
Chronic Dally
Intake (COI) (b)
(e«/kg-day|
Average Plausible
Caae Nulvus Case
2.S5E-08 8.92E-06
6.14E-09 2.18E-OS
4.11E-09 6.66E-06
7.5SE-08 1.25E-04
2.03E-09 1.25E-05
1.93E-07 4.18E-04
Reference
Dose
,(»«) (c)
(•g/kg-day)
S.OE-03
l.OE-01
8.6E-01
5.7E-01
3.0E-01
4.0E-01
a) Concentrations as reported In Table 5-18.
b See text for methodology. Calculated using aquation 5 and assumptions presented in Table
c Reported previously in Table 5-19.
d ' Calculted by multiplying the COI by the potency factor.
e) Calculated by dividing the COI by the RfO.
Ratio COI:RfD (e)
• Average
Caae
5E-06
(£•08
SE-09
1E-07
7E-09
SE-07
<1 (6E-6)
5-32.
Plausible
Naxleue Caae
1E-03
2E-04
8E-06
2E-04
4E-05
IE-OS
«1 (3E-3)
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TABLE S-36
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INHALATION Of VOLATILE CHEMICALS BY NEARBY WORKERS
(CURRENT LAND USE)
POTENTIAL CARCINOGENS
Chemical
Benzene
Chloroform
Hethylene chloride
TetracMoroethene
TMchloroethena
Vinyl Chloride
TOTAL
. EstlMted Air
Concentration (a)
Average Maxlnn
6.11E-06 4.1SE-OS
B.83E-08 5.99E-07
1.97E-07 1.34E-06
4.53E-07 3.07E-06
3.62E-07 2.46E-05
7.02E-07 4.76E-06
Chronic Daily
Intake (COD (b)
(BQ/kg-day)
• Lifetlns Upper Bound
Excess Cancer Risk (d)
Average Plausible Potency Factor (c) Average Plausible
Case KuleuR Case (ng/kg-day)-l Case Maxlmm Case
8.61E-08 4.34E-06
1.24E-09 6.27E-08
2.7BE-09 1.40E-07
6.38E-09 3.21E-07
5.10E-09 2.57E-06
9.69E-09 4.96E-07
2.9E-02
6.1E-02
1.4E-02
3.3E-03
4.6E-03
2.9E-01
2E-09
1E-10
4E-11
2Erll
2E-11
3E-09
6E-09
1E-07
5E-09
2E-09
1E-09
IE-OS
1E-07
3E-07
NONCARC^UGENS
:henlca1
Jhlerobentene
L.l-Dichloroethane
Hethylene chloride
toluene
l.l.l-Trlchloroethane
(ylenes
1AZARO INDEX
Estimated Air
Concentration (•)
(mg/m3)
Average Maximum
1.22E-06 6.30E-06
2.94E-07 2.00E-06
1.97E-07 1.34E-06
3.62E-06 2.46E-05
9.73E-08 6.61E-07
9.28E-06 6.30E-05
Chronic Daily
Intake (COI) (b)
(•g/kg-dayj
Average Plausible
Case fUxImui Case
1.34E-07 2.03E-06
3.22E-08 4.86E-07
2.16E-08 3.27E-07
J.97E-07 6.01E-06
1.07E-08 1.61E-07
1.02E-06 1.54E-05
Reference
Dose
(RfD) (c)
S.OE-03
l.OE-01
8.6E-01
5.71-01
3.0E-01
4.0E-01
a Concentrations as reported in Table 5-18.
b See text for methodology. Calculated usi-g equation 5 and assmptlons presented 1n Table
c Reported previously in Table 5-19.
d Calculted by multiplying the COI by the pottncy factor.
e Calculated by dividing the COI by the RfO.
Ratio COI :RfD(e)
Average Plausible
Case HaxlBUB Case
3E-05
3E-07
3E-08
7E-07
4E-08
3E-06
«1 (3E-5)
5-33.
4E-04
5E-06
4E-07
IE-OS
5E-07
4E-OS
«1 {SE-4J
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TABLE S-3/
POTENTIAL EXPOSURES AND RISKS ASSOCIATED WITH INHALATIOk OF VOLATILE CHEMICALS BT.NEARBY RESIDEHTS
{CURRENT LAND USE)
POTENTIAL CARCINOGENS
Cheaical
lenztne
Chloroform
tethyleni chloride
retraehloroethene
Trichloroethene
Vinyl Chloride
TOTAL
Estimated Air
Concentration (e)
(•g/«3)
Average Maitaa
2.51E-07 3.50E-07
3.63E-09 S.ME-09
B.09E-09 1.13E-08
1.8EE-OB Z.S9E-M
1.49E-08 2.08E-08
Z.ME-08 4.02E-08
Chronic. Jily
Intake (COM (b)
(•g/kgilay)
Lifatine Upper Bound
Excess Cancer Risk (d)
Average Plausible Potency Factor (c) Average Plausible
Case Naxlu Case (ag/kg-day)-! Case Naiisui Case
4.93E-09 4.56E-08
7.13E-11 6.60E-10
1.59E-10 1.47E-09
3.68E-10 3.38E-09
2.93E-10 2.71E-09
5.66E-10 5.24E-09
2.9E-02
B.1E-02
1.4E-02
3.3E-03
4.6E-03
2.9E-01
IE-10
6E-12
2E-12
1E-12
1E-12
2E-10
3E-10
1E-09
sE-n
2E-11
1E-U
1E-11
2E-09
3E-09
NONCARC1NU_2NS
IheBlCll
Ihlorobenzine
l.l-Oichloroethane
tethylene ehlorldt
'oluene
l.l.l-Trichloroethane
(ylenas
1AZARO INDEX
Estimated Air
Concentration (a)
(•g/«3)
Average NaxlK*
S.02E-08 7.00E-M
1.21E-08 1.69E-08
B.09E-09 1.13E-08
1.49E-07 2.08E-07
4.00E-09 5.58E-09
3.81E-07 5.32E-07
Chronic Dally
Intake (CDI) tb)
(ev/kg-day)
Average Plausible
Case NntaM Case
7.67E-09 2.13E-08
1.85E-09 5.14E-09
1.24E-09 3.44E-W
2.28E-08 6.33E-OB
6.12E-10 1.70E-09
5.62E-06 1.62E-07
Reference
Dose
,««) (c)
(e»/kg-day)
S.OC-03
l.OC-01
8.8E-01
S.7E-01
3.0E-01
4.0E-01
a Concentrations as rtporttd In Table 5-18.
b Stt ttxt for nethodology. Calculated using equation 5 and •••(•ptlora prtstntcd In Ttblt
e Riporttd previously in T«bl« 5-19.
d Ctlculted by Multiplying the CDI by the potency factor.
e C«lcul
-------
' TABLE 5-39
POTENTIAL EXPOSURES-AND RISKS ASSOCIATED WITH IRGESTIM OF CHEhlCALS IN fiUMUMTEB
(HYPOTHETICAL FUTURE LAND USE)
POTENTIAL CARCINOGENS
Sroundwter
Conctntntion (i)
(«g/D
6ec*etHc
Chemical Hun NaxlBus
Arsenic 4.70E-03 4.B1E-02
Benzene 6.10E-03 5.BOE-01
M$(2-chloroethyl)ether 9.20E-03 2.00E-01
Bit(2-chloroisopropyl)ether B.90E-03 1.02E-01
Ihloroform 2.80E-03 l.OOE-02
Hethylene chloride 2.79E-02 5.60E-02
roTAL
Chronic Daily
Intake (CDI) (b)
(•g/kg-day)
LlfetlH Upper Bound
Excess Cancer Risk (d)
Average Plausible Potency Factor (c) Average
Case KuteuB Case («g/kg-d*y)-l Case
1.16E-OS S.89E-04
l.SOE-05 7.10E-03
2.27E-05 2.45E-03
2.19E-05 1.2SE-03
6.90E-06 1.22E-04
6.88E-OS 6.B6E-04
2.0E+00
2.9E-02
1.1E+00
7.0E-02
6.1E-03
7.5E-03
2E-05
4E-07
2E-OS
2E-06
4E-OB
SE-07
SE-05
Plausible
Nailaus Case
IE-03
2E-04
3E-03
9E-05
7E-07
SE-06
4E-03
NONCARCINOGENS
Groundwater
Concentration (•)
<«g/U
Goonetrlc
Iheaical Mean Naxlsua
kntUwny 5.18E-02 1.13E-01
krsenic . 4.70E-03 4.61E-02
iarlum S.99E-01 1.74E+00
Mi(2-ch1oro1iopropyl)ether B.90E-03 1.02E-01
:«*n1um 2.80E-03 2.30E-02
:hloroform 2.80E-03 l.OOE-02
:hroniun 2.77E-02 1.35E+00
:opper 2.31E-02 8.S6E-01
(anganese 5.B2E-01 4.19E+00
tercury 4.00E-04 2.27E-02
tethyline chloride 2.79E-02 S.60E-02
lickel 2.61E-02 Z.10E-01
rteUiun 2.10E-03 1.32E-02
Mnc 2.11E-01 4.UE*00
1AZARD INDEX — —
Chronic Daily
Intake (COI) (b)
(e«/kg-diy)
Average Plausible
Case HaxleuB Case
.93E-04 3.23E-03
.DIE-OS 1.37E-03
.15E-02 4.97E-02
.71E-04 2.91E-03
.37E-OS 6.57E-04
.37E-05 2.86E-04
.31E-04 3.88E-02
.43E-04 2.45E-02
.12E-02 1.20E-01
.67E-06 6.49E-04
.3SE-04 1.80E-03
.01E-04 6.00E-03
.03E-OS 3.77E-04
.OSE-03 1.19E-01
Reference
Dose
(RfD) (c),
(•g/kg-1 (3)
:RfO (e)
Plausible
Haxlaue Case
8E+00
1E*00
1E«00
7E-02
1E*00
3E-02
8E«00
7E-01
BE-01
2E*00
3E-02
3E-01
SE-02
6E-01
>1 (20)
•} Concentrations *s reported In Table 5-7.
b See text for methodology. Calculated using equation 6 and assioptlons presented In text.
c Reported previously In Table 5-19.
d Calculted by tultlplylng the CD I by the potency factor.
e) Calculated by dividing the CDI by the RfO~
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APPENDIX III
JUDKXNXSXRAXZVB RECORD XHDBX
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Items Sent To Repository For PJP Landfills
1. Report of Health Effects Advisory Committee 12/7/88
2. Community Respiratory Status Relative to Burning
Landfill 12/7/88
3. NJ Bill 2661 12/7/88
4. Supplement to Directive and Notice to Insurers
Directive 5/17/88
5. Community Relations Plan/Transcript of 12/7/88
Public Meeting 10/20/89
6. HASP, FSP-QAPP . 12/15/89
7. RI Report Appendices A-S 12/5/91
8. Background Investigation Report 11/21/91
9. Buried Drum Investigation Report (Appendix A) 11/21/91
10. Phase I RI 11/21/9
11. Phase I, II & III FS
12. PJP Landfill - Interim Remedial Measures Health 6 Safety
Volume I & II
13. Site Characterization Study
Siegel Property 10/84
14. Work Plan for Handling Hazardous Waste Drums and Other
Containers 10/17/85
15. PJP Landfill Interim Remedial Measure
• Final Design Report 5/85
16. PJP Landfill - Interim Remedial Measure - Final Report
17. PJP Landfill PRP Steering Committee - Comments of the
Phase I Remedial Investigation for the PJP Landfill Site 1/92
18. Volume 1 - Case Narrative - Characterization of Landfill
Gases at PJP
19. D'Annunzio Associates - Project Plan including Health
Safety Plan and Drum Handling Plan
20. D'Annunzio Associates - Fire 6 Hazardous Situation
Contract
-------
21. Final Report - PJP Landfill Bedrock Monitoring Well
Information
22. Work Plan and Health and Safety Plan - PJP Landfill 8/11/93
23. Chronic Bio Monitoring Report 12/7/93
24. Field Sampling Episode Report - PJP Landfill 11/465/93
25. PJP - Summary of November 1993 Sampling of Surface
Water and Sedimentation
26. Letter "Notifying Potential Liability* 8/10/94
27. Letter "Directive & Notice to Insurer Number Two" 8/22/89
28. Letter "PJP Landfill Supplement to directive and
Notice to Insurer Number One and Demand For Payment
and its amendment 3/17/89
29. : Letter "Multi-Site Directive and Notice to insure" 5/7/90
30. Record of Decision for PJP Landfill Superfund Site,
NJDEP 9/28/95
31. Maps, Surveys and Slides of PJP Landfill Superfund Site,
Various dates (only located in NJDEP'a Repository)
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APPENDIX IV
BPA'S LETTER OP CONCURRENCE
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY - REGION II
290 BROADWAY
NEW YORK, NEW YORK 10007-1866
SEP 27 I995
Honorable Robert C. Shinn, Jr.
Commissioner
State of New Jersey
Department of Environmental Protection
401 East State street
Trenton, New Jersey 08625
Re: EPA Concurrence of Selected Remedy
for PJP Landfill Superfund Site
Dear Commissioner Shinn:
This is to notify you that the Environmental Protection Agency
(EPA) has reviewed the Record of Decision prepared by the New
Jersey Department of Environmental Protection (NJDEP) for the PJP
Landfill site. Based on this review, EPA concurs with the selected
remedy to address contaminated surface soils and ground water at
the site.
The major components of the selected remedy include the
following:
- Removal of all known and suspected buried drum materials and
associated visibly contaminated soil;
- Capping of the exposed landfill area of the site with a
multi-layer, modified solid waste cap in accordance with NJDEP
guidance;
Installation of an appropriate gas venting system;
- Extension of the existing gravel-lined ditch around the
perimeter of the site to collect surface water runoff;
- Replacement of the Sip Avenue ditch with an alternate form of
drainage;
- Site fencing and institutional controls (e.g., land use
restrictions and classification exemption/well restriction
area);
- Routine inspections, maintenance and a reevaluation of the
previously capped area of the landfill;
- Ground water and surface water monitoring to evaluate the
reduction of contaminant concentrations over time and otherwise
ensure the effectiveness of the remedy;
- Modeling to demonstrate the effectiveness of the cap in reducing
the migration of ground water leachate from the landfill to the
Hackensack River; and
- Implementation of a wetlands assessment and restoration plan.
Printed on Recycled Paper
-------
In addition to the remedial components identified above, the
Comprehensive Environmental Response, Compensation and Liability
Act/ as amended, requires that the site be reviewed every five
years because contaminants will remain on the site above health-
based levels. The purpose of these reviews is to ensure that the
selected remedy continues to provide adequate protection of human
health and the environment. Further, if monitoring indicates that
the landfill cap alone is not effective in reducing the migration
of contaminants to ground and surface waters, additional remedial
actions may be necessary.
We look forward to a continued cooperative working relation-
ship with the Department to address the environmental concerns at
this and other Superfund sites in New Jersey. If you have any
quest:'ens regarding this concurrence letter, please do not hesitate
io contact me at (212) 637-5000, or have your staff contact John
Frisco, Deputy Director for New Jersey Programs, at (212) 637-4400.
Jeanm
Regional Administrator
-------
RECORD OP DECISION
RESPONSIVENESS SUMMARY
PJP Landfill Site
Jersey City, Hudson County, New Jersey
New Jersey Department of Environmental Protection
Site Remediation Program
Trenton, New Jersey
-------
Responsiveness Summary
PJP landfill Superfund Sit*
This responsiveness summary is divided into the following sectionss
A. Overview
B. Background on Coaaunity Involvement sad Concerns
C. Summary of Comments Received During the Public Coaaeat Period and
MJDEP/USF"A Responses
X. Landfill Definition and Characteristics and Liability Issues
XX. D-uas Pound at r%rlfill
XXX • Siv i Af fee-is on Sip Avenue Ditch/Backensack River/Newark Bay
XV. Rbase of Site and Affect of Remediation on Adjacent Properties
V. Recent Illegal Duaping at Site
VI. Costs
VII. Site Risk Issues
VIII. Wetlands Issues
IZ. Interia Reaedial Measures/Landfill Pires
X. MJDBP Proposed Cap/Landfill Gas System
A. Overview
This is a suumary of the public's commentB and questions regarding the Proposed
Plan for remediation of the PJP Landfill Superfund site and the New Jersey
Department of Environmental Protection's (NJDEP) responses to those comments.
A public comnent period was held from August 2, 1994 through September 30, 1994
and was extended, at the request of potential responsible parties, until October
14, 1994. The purpose of the public comment period was to provide interested
parties with the opportunity to comment on a Proposed Plan for remediation of the
PJP Landfill site. During the public comment period, NJDEP held a public meeting
on August 18, 1994 at 7 p.m. at the Jersey City Municipal Building to discuss
results of the Remedial Investigation and Feasibility Study (RI/FS) reports and
to present the NJDEP's preferred alternative for remediation of the site.
The preferred remedial alternative addresses cleanup remedies for the site that
includes landfill material, landfill gas and areas of buried drums and associated
contaminatev. soil. Future monitoring and review requirements also are included
for ground water and surface water. The Proposed Plan's preferred remedial
alternative includes components of media-specific alternatives developed for
remediation of the site in accordance with NJDEP Bureau of Landfill Engineering
guidance, New Jersey Solid Waste Regulations regarding closure and post closure
requirements for solid waste landfills, the Comprehensive Environmental Response,
-------
Compensation and Liability Act (CERCLA) of 1980, as amended, and Section
300.430(f) of the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). Specifically,'this includes} 1) construction of a modified solid
waste cap over approximately 42 acres of the landfill area not addressed as part
of a 1986 Interim Remedial Measure (ZRM); 2) installation of a passive or active
gas venting system; 3) replacement of the Sip Avenue Ditch with an alternative
form of drainage; and, 4) quarterly ground water monitoring.
B. Background on Cosoranity Involvement
NJDEP prepared a community relations plan in June 1985 for the site detailing
site history, community concerns and remedial action taken to date. Also, in
June 1985, a public meecing was held in Jersey City to discuss NJDEP's plans to
extinguish subsurface fires present at the site. A public meeting was held in
December 1988 to discu. n the iuitiatuu of the RI/PS. Briefings for Jersey city
officials and their Bounty, state and federal representatives and various
surrounding municipalities were held in January 1989. Numerous press releases
were distributed to the state-wide media announcing these public meetings and
describing remedial work to be performed. An updated mailing list was developed
in August 1994 for the site and used to inform interested residents and
neighborhood groups as well as various officials.about site activities.
C* Suamary of Comment j Received During the Public Consent Period and
MJDEP/USEPA Responses
The majority of comments received during the public comment period originated
from the potentially responsible parties. Their comments focused on the
definition of landfill parameters, the appropriateness of the preferred cap,
future use of the site and the methodology and conclusions of the site risk
assessment. One attorney submitted comments on behalf of a PJP potential
responsible party group that included an alternate remedy that was presented as
equally protective and more cost effective than the NJDEP- preferred remedy.
Concerns were also raised during the public meeting regarding how reasonable risk
is determined and the impact this remediation may have on currently operating
facilities in the vicinity of the site. All written comments as well as the
transcript of the August 18, 1994 public meeting can be found in the appendices
to this Responsiveness Summary.
I. Landfill Definition and Characteristics and Liability Issues
1. Comments Bow much of the site is contaminated in cubic yards?
Responses Various written and photographic records and results of
remedial work performed at the PJP Landfill site indicates
that the site was used for the disposal of thousands of druae
and hundreds of thousands 'of gallons of chemical waste along
with municipal, commercial and industrial refuse. It Mould be
-------
cost prohibitive to determine whether every cubic yard of the
•ite believed to be used for municipal, commercial and
industrial refuse disposal also was contaminated by chemical
wastes. Therefr re, the goal of the RI was to characterize the
different media (i.e., ground water, soils, air, sediment) on
a broader scale to determine an appropriate response to
mitigate potential adverse impacts on human health and the
environment.
A 45-acre capped portion of the site contained significant
amounts of hazaxdous materials in the form of drums, cylinders
and contaminated soils that were transported off site for
permanent disposal. The remainder of the landfill also
contains drums and contaminated soils that will be remediated
as part of NJEEP'S selected remedy noted in the Record of
Decision (ROD).
Comment t How did the Department arrive at geographic boundaries of what
is attributable to PJP? Can you give us an example of some of
the kinds of documents or sources you used to determine that
the landfill is 87 acres? Also, how do we know the chronology
of dumping?
Response: Refer to the response to comment 3.
Comments NJDEP's propos J cap inappropriately coincides with and is
defined by the current property boundaries. Proper and
adequate delineation of the landfill should have been
performed to de:ine what areas need to be capped.
Responses The site description paragraph located on page 2 of the Record
of Decision defines those areas NJDEP intends to address as
part of its sel'icted remedy for the PJP Landfill site. The
site boundaries are based upon studies conducted during the
RZ, NJDEP's review of reports of inspections conducted during
the operation of the PJP Landfill, aerial photographs of the
site and documents filed by the PJP operators in 1970.
Collectively, these records and the RI/P3 confirm that waste
disposal activities extended well beyond the blocks and lots
originally set forth in the documents filed by the PJP
Landfill Company. The Hackensack River, the fenced trucking
terminals and Truck Routes 1 and 9 provided geographic limits
of the site on the northwest, west, south and east sides. The
remedy will extend to the northeast to those parts of lots 38
and 48 in block 1627.1 that are determined during design to
have been used for disposal of hazardous substances.
Comment« Are logs available of the RZ borings?
-------
Responses Yes. logs of the RI boringa are contained in the
Administrative Record and available for review. The soil
borings are in Appendix H of the Phase I RI report. Volume II.
Comments Did the Department perform any investigation to determine
whether any of the neighboring sites were contributing to
contamination on this site?
Responses The only neighboring site up-gradient from the PJP landfill
site is a cemetery to the east, which is not considered to be
a likely source of contamination.
Comments How many PRPs are there?
Responses In 1992, NJDEP commenced co..t reco.ery litigation seeking part
costs and future costs ana damages for the remediation of this
Superfund site from entities and individuals alleged to be
responsible for hazardous substances disposed at this site.
AS of September 1995 over 90 direct and third party defendants
have been included in this law suit.
Comments Do you have many photographs in the Administrative Record? Do
any photographs identify responsible parties for this site?
Response s There are aerial photog*. aphs taken during the years the
landfill operated in the Administrative Record File at NJDEP
offices in Trenton. These Photographs have been used to help
determine what areas of the site needed to be capped. Also,
there are numerous slides and photographs of the PJP Landfill
site.
II. Drums Found at Landfill
8. Comments Approximately how many drums are located at the site?
Responses During NJDEP'• IRM project, there were 4,770 intact drums
removed from the site for permanent disposal. Also, an
indeterminate amount of broken and crushed drums were removed
along with contaminated soil. .
Two additional areas were found during the RI that contained
drums. These areas are included in the ROD as requiring
remediation through excavation and off-site'disposal. During
the IRM pockets of drums usually were found to extend out a
significant distance in several directions. Therefore, the
current number of drums located at the site is not known and
-------
will not be determined until the excavations are actually
performed.
9. Commentt Did any of the drums have markings on them?
Response t During the ZRM a separate log sheet was maintained for each of
the 4,770 drums noting any markings in addition to a
description of the contents of the drum.
i
10. Comments Drum removal was not evaluated in the feasibility study and
the areas of concern are unclear and inconsistent with the
remedial investigation as only two «reas have known buried
drums, not 12, as DEP has propose? to investigate. Also,
there is no criteria for proposed soil removal.
Response t In order for NJDEP's proposed cap «;o be effective and as
suggested by NJDEP's 1993 sampling effort, it is necessary to
remediate the two known buried drum areas. These two known
'buried drum areas actually encompass the approximately 12 test
pit areas. Although the exact criteria for soil removal was
not included in the Proposed Plan, it does state "associated
visibly contaminated soils." The specific criteria for eoil
removal will be developed during the design phase. Such
criteria may include, but not be limited to, the following
examples! soils adjacent to or below containers (i.e., drums,
barrels, etc.) that have ruptured, lv-ked or corroded; stained
or discolored soils; material that /isually appears to have
originated (i.e., leaked or spilled) from a container.
III. Site Affects on Sip Avenue Ditch/Hackensack River/Newark Bav
11. Commentt
Responsei
Was any investigation done by the Department to determine
whether the Hackensack River or the Sip Avenue Ditch waa in
any way affecting the site, either positively or negatively?
It is not known whether the Backenslkck River is affecting the
site. No tidal studies were conducted in the RI. AB is
stated on page 420 of the RI, "The influence of the tides on
(ground water] flow patterns is not known." In the future, if
DEP and EPA decide that a ground water remediation is needed
for the PJP Landfill site, it may be appropriate to conduct a
tidal study. Such a study would be conducted through
monitoring the tidal influence upon the wells at the site by
continuously monitoring the shallow, deep and bedrock wells.
The Sip Avenue Ditch does not affect the site. The ditch is
a discharge point for ground water from both the northern and
southern parts of the site, so no contaminants are moving from
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the ditch to the landfill. Ground water flow direction was
determined during the HI by measuring water levels in site
monitor wells. As is stated on page 225 of the RI,
•Generally, most of the ground water at the site flows into
the SIP Avenue Ditch."
Leachate from the site is flowing into the ditch adding to
contaminants already there. During the RI a leachate seep was
sampled (Landfill Leachate Sample PJP-SW-011) on the landfill
adjacent to the Pulaski Skyway and Sip Avenue Ditch. Results
showed total volatile organic compounds of 1,017 parts per
billion (ppb)* The sample exceeded the Federal .Surface Hater
Quality Criteria for the following compoundss benzene (160
ppb), n-nitrosodiphenylamine (13 ppb), arsenic (4.5 ppb),
barium (1,560 ppb), iron (8,410 ppb), manganese (235 ppb),
lead (25 ppb) and nickel (90 ppb).
12.
Comment t
Response t
13. Comment t
Response:
DBF's proposed 15- foot diameter enclosed concrete culvert for
the Sip Avenue Ditch is grossly oversized. The proposed
culvert is unnecessary to prevent contact with contaminated
sediments along the Ditch because the contamination does not
exceed the acceptable risk range. Some or all of sediment
contaminants within the ditch cannot be attributed to the site
because it is a storm water channel for areas beyond the site.
The exact design parameters for the Sip Avenue Ditch culvert
will be determined in the design phase. The > aference to a
15-foot culvert, which appears in the FS, was an option
proposed by NJDEP's contractor to address the Sip Avenue Ditch
as part of an overall capping alternative. . In order to
properly maintain the integrity of the landfill cap,
adequately channel surface water runoff and adequately protect
human health and the environment, some type of remedial action
is necessary for the Ditch.
Also, please refer to the response to comment No. 26 and 40.
There may be a combined sewer overflow emptying into the Sip
Avenue Ditch from a truck stop area that would have to be
addressed in the remediation.
The design phase of this project will include the replacement
of the Sip Avenue Ditch with an alternate form of drainage
that takes sewer overflow into account.
14. Comments
Is the leaching of contaminants from the landfill into the
Hackensack River directly or indirectly affecting the dredging
that is going on in the Newark Bay?
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8
Responsei NJDEP does not believe contaminant levels measured during the
RZ in surface water and sediment at the site will adversely
impact adjacent surface waters including the Hackensack River.
Consequently, dredging operations in Newark Bay, about two
miles downstream from the site, also would not be adverse. ,y
affected.
IV. Reuse of Site and Affect of Remediation on Adjacent Properties
15. Comments
Response:
16. Comment t
What steps are being taken to create the best opportunity for
potential development in the future of this prime development
site? It appears that every time a site gets cleaned up it
gets cleaned up to the minimum level that is required. A
program needs to exist to try to preserve as much property is
possible for future development. Also, why did NJDEP aot
explore on- site remediation for the site to clean up the lund
and restore it to the tax base?
In selecting a remedial alternative NJDEP must balance a
number of factors including . cost effectiveness and the
requirement that the chosen remedy adequately protects human
health and the environment. While a cleanup plan that calls
for excavation and off-site removal of all contaminated waste
would leave the site available for unrestricted development,
the economics of such an alternative are not feasible bec» se
the costs would be prohibitive. Removal and off-site disposal
of all landfill materials was examined in the Phase II PS, b -t
was screened out due to excessive cost — approximately
$1 billion—in the Phase III PS.
NJDEP '• selected remedy will provide adequate protection of
human health and the environment. Any proposed development >«f
the PJP Landfill site subsequent to implementation of NJDIP'S
selected remedy will have to take such work into
consideration. This means that the site owners or potential
developers may propose to NJDEP and implement, if approved,
some type of redevelopment of this site as long as it does not
compromise the remedial measures performed.
Also, please refer to the response to comment No. 60.
It should be noted that the M * T Delisa Landfill Superfund
site in Ocean Township, New Jersey, currently occupied by l he
Seaview Square Mall, is the only Superfund site in the state
that has been reused. The site was deleted in 1991 froa the
National Priorities List.
It appears that some currently active properties have beea
included in the area to be capped. How do you propose to
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initiate further actions here while these facilities are still
operating?
Responses NJDEP does not intend to disrupt any current large facilities
with permanent structures. One aspect of the modified solid
waste cap is to prevent additional infiltration into the
ground water. Therefore, NJDEP considers areas that have
buildings in place and concrete floors already to be capped.
However, the area now occupied by A.T. Autowreckers, which
operates a junk yard, will need to be either temporarily or
permanently relocated off the site since this area will be
capped and investigated for buried drums during the remedial
design/action phase.
17. Comments NJDEP's preferred remedy constitutes a compensable taking
under the Fifth Amendment of the U.S. Constitution as private
property is being taken for public use. Also, future access
requirements for monitoring and maintenance constitutes
imposing an easement and requires compensation.
Responses NJDEP believes that the remedial actions it intends to
implement at the PJP Landfill site do not constitute a
compensable taking under the applicable laws and regulations.
18. Comments The best use of the site is for light industry or possibly an
office or research and development facility. Also,
recreational facilities could be constructed to benefit the
local community on certain areas of the landfill if an
appropriate cap is installed.
Responses Please refer to response to comment No. 15.
V. Recent illegal Dumping at Site
19. Comments
Responses
Comments were made that during the past year and a half about
40,000 to 60,000 yards of fill material very high in
poly cyclic aromatic hydrocarbons (PAHs), demolition refuse and
possibly chemical wastes have been brought to or dumped at
properties adjacent to the PJP Landfill site.
NJDEP's solid waste enforcement element has investigated the
fill material complaint and ordered the specific property
owner to comply with appropriate state laws and regulations
that cover the handling of such material. In terms of illegal
dumping of chemical wastes, NJDEP has forwarded the comments
regarding continued dumping at this site to the New Jersey
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10
Division of Criminal Justice.
investigated by that agency.
Those allegations were
Much of the site is enclosed with a 10-foot high cyclone
fence. While this fence restricts access to much of the site,
access can be obtained through a number of business
establishments that border the site. The chosen remedy will
include security measures that will restrict, to the extent
possible, all access to the unoccupied portion of the site.
VI. Costs
20. Commenti
Response:
21.
22.
Comments
Response:
Commentt
Response:
How did you arrive at an estimated cost for the NJDEP
preferred alternative?
The estimated cost includes calculations for capital costs,
annual operation and maintenance costs and a present worth
cost. The present worth cost is calculated using both the
capital costs and annual operation and maintenance costs.
Specifically, the present worth cost is derived from an
analysis of expenditures that would occur at different times
by discounting all future costs to a common year, usually the
current year. The present worth cost is based on a 30-year
period and a discount rate of seven percent. This allows the
costs of each remedial action alternative to be compared on
the basis of a single figure representing the amount of money
that, if invested in the base year and dispersed as needed,
would be sufficient to cover all coats associated with the
remedial action.
What is the margin of error in the cost estimates?
The remedial cost estimates provided in the Proposed Plan can
range from 30 percent less than to 50 percent more than the
actual remedial costs.
How did you determine the preferred remedy is the most cost-
effective?
In accordance with DSEPA guidance, a detailed analysis of each
remedial alternative in the Proposed Plan was conducted with
respect to nine criteria, one of which involves costs. A
complete analysis using the nine criteria also is included in
the ROD on pages 16 to 20. The criteria in the ROD are
divided into three separate references: threshold criteria,
primary balancing criteria and modifying criteria.
Under the provisions of P.L. 1993, c.139, Section 35g relating
to remedial costs, DEP cannot require a responsible party to
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11
implement a permanent remedy at a contaminated site if a non-
permanent remedy can be implemented for less than half the
cost. All of the alternatives presented in the NJDBP Proposed
Plan were nonpermanent remedies. consequently, NJDEP's
selected remedy noted in the ROD complies with the specific
cost provisions of this statute.
23. Comments Who is paying for the remediation currently and who will pay
for the future remediation?
Response: NJDEP paid all costs associated with the RI/PS. Also, the IRM
performed by NJDEP was funded almost entirely with state
monies, the Roman Catholic Archdiocese of Newark, an owner of
a portion of the PJP Landfill site, paid $46,575 toward a
study conducted in 1985. Also, $336,824 was paid by a group
of potentially responsible parties in 1989 in response to a
directive issued to those parties for the funding of the
RI/PS. NJDEP is involved in cost recovery litigation seeking
past and future costs associated with remediating the site.
If the potential responsible parties will not perform future
actions, public monies will be used for an engineering design
and construction project to implement the ROD and long-term
operation and maintenance costs.
VII. Site Risk Issues
24. Comments
Responses
What was the worst case scenario used for calculating risks to
children from swimming in the Sip Avenue Ditch and what kind
of exposure are you talking about?
The maximum plausible scenario is the worst case scenario for
calculating risks to children swimming in the Sip Avenue Ditch
and is noted in Section 5.0 of the Phase I RI. The maximum
plausible scenario is intended to place an upper bound on the
potential risks by combining maximum plausible exposure
estimates with upper bound health effects criteria. Data used
to calculate the plausible maximum case are provided in Table
5-25 of the Phase X RI. They includes sediment concentration,
quantity of chemical ingested and absorbed, quantity of
chemical absorbed dermally, combined chronic daily intake,
potency factor and reference dose.
The exposure pathways evaluated for the Sip Avenue Ditch also
are discussed in detail in Section 5.0 of the Phase I RI.
Specifically, the potentially exposed population is
trespassing children wading in the Sip Avenue Ditch. The
exposure pathways evaluated for this population are dermal
absorption of chemicals in the Ditch sediment and surface
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12
water and incidental ingest ion of chemicals in the Ditch
sediment.
25. Comment: How did you determine what is a reasonable risk with regard to
human health?
Responses In order to determine what is a reasonable risk for human
health, NJDEP followed DSEPA guidelines. These guidelines
included an acceptable exposure as having an excess
carcinogenic risk in the range of one in ten thousand to one
in one million (1x10'* to IxlO*6). After the RI/FS and Risk
Assessment were performed for the PJP site, NJDEP adopted a
new allowable cancer riskt one in one million (1x10**) based
on P.L. 1993, c.139. Section 3Sd.
To assess non-carcinogenic effects, NJDEP follows USEPA's
hazard index guidelines. A hazard index with a value greater
than one is generally identified with potential adverse health
effects. Details on the public health evaluation are provided
in Section 5.0 of the Phase I RI.
26. Comment: NJDEP did not consider background conditions when evaluating
potential risks presented by the site. Arsenic is used as an
example of a naturally occurring inorganic that should not
have been included in the assessment. Also, the proposed
remedial action for the Sip Avenue Ditch is based on potential
risks from non-site related contaminants.
Response: NJDEP believes that it is inappropriate to compare sediment
concentrations from the Sip Avenue Ditch with the NJDEP Soil
Cleanup Criteria to determine site-related contaminants of
concern. The example of 20 parts per million for arsenic in
soils considered to be "natural background" is not relevant to
sediments in the Sip Avenue Ditch.
In the absence of native soils on site, it was unlikely that
true background samples could be obtained at this urban,
industrialized site. NJDEP decided to rely on a reference
location at the upgradient-most portion of the Sip Avenue
Ditch. It is not unreasonable to include contaminants of
concern at background levels if they pose a risk. Also, it
may be conservative to retain a chemical detected at low
concentrations if it is a class A carcinogen, such as arsenic.
NJDEP acknowledges that the Sip Avenue Ditch does not
originate on site and does provide a pathway for non-site
related contaminants to enter the on-site portion of the
Ditch. Nevertheless, NJDEP's ultimate decision to remediate
the Sip Avenue Ditch was largely based on engineering
principles associated with the modified solid waste cap
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13
included in the selected remedy rather than solely human
health and ecological risk concerns.
Also, please refer to response to comment No. 12.
27. Comments The risk assessment concludes that excess risks warranting
remedial action are present based on soil concentrations that
are actually below NJDEP cleanup guidance.
Responses As shown in the Phase III PS, Table 1-3, numerous compounds
were detected at concentrations exceeding NJDEP subsurface
soil cleanup criteria.
28. Comment
Responses
The use of National Oceanographic Atmospheric Administration
(NOAA) sediment screening guidelines to evaluate impacts to
Sip Avenue Ditch is not appropriate, since no data were
collected to assess benthic community presence/absence,
structure or function, or to assess upgradient chemical
conditions.
The environmental assessment performed for the site (Phase I
RZ, Section 5.7) is considered to meet the standard practice
for that time period. It was not then, nor is it now,
standard practice to conduct benthic macroinvertebrate surveys
as part of a baseline ecological risk assessment. Risk to
ecological receptors from contaminated sediments is initially
screened based upon comparison with NOAA sediment quality
guidelines. Bxceedances of these guidelines may suggest the
potential for adverse ecological effects and thus may suggest
the need for rigorous ecological investigations, such as
benthic surveys.
29. Comments
Responses
The chemical sensitivity of resident benthic species is highly
variable and may differ significantly from the organisms used
in laboratory settings; selection of a remedy based upon
laboratory bioassay results is not appropriate.
NJDEP interpreted this comment to imply that the BOAA
guidelines are based on laboratory bioassays and therefore are
not appropriate for determining effects on in sita beathie
species. In fact, the NOAA guidelines are based upoo data
from three basic approaches s the equilibrium-partitioning
approach; the spiked-sediment bioassay approach; and, various
methods of evaluating synoptically collected biological and
chemical data in field surveys. NJDEP has always considered
NOAA sediment quality guidelines, as well as other ssitLssnt
quality guidelines generally available, as screening level
values and are not intended to determine the nsed for a
remedial action.
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14
Also, please refer to response to Comment No. 12.
30. Conine..Si Since the upgradient sources of contaminants severely impact
the Sip Avenue Ditch and Hackensack River, the area is not
pristine and the evaluation of impacts to such a system
requires information regarding baseline conditions for
comparison.
Response: Please refer to the response to comment No. 26.
31. Commentt The application of NOAA sediment screening guidelines to Sip
Avenue Ditch sediments is inappropriate because the criteria
originate partly from data based on equilibrium partitioning
coefficients, which do not address bioavailability of the
compound or the organic carbon/acid volatile sulfide
concentrations in sediment.
Responses The equilibrium partitioning approach to sediment quality
evaluations does in fact address organic carbon content, since
partitioning of a contaminant between sediments and
interstitial water is dependent upon organic carbon content.
The total organic carbon (TOC) is an integral part of the
calculation for the sediment-specific criterion value and TOC
content is directly related to bioavailability.
NJDEP and USEPA Region II do not endorse the routine use of
acid volatile sulfide (AVS) to normalize sediment metals
concentrations. NJDEP believes that much research is needed
before this approach is widely applied. For example,
additional data is needed to evaluate the use of AVS for
oxidised sediments, where AVS concentrations can be low,
invalidating the normalization of metals concentrations.
32. Comment t
NOAA Effects Range-Low (ER-L) and Effects Range Median (ER-H)
values are not to be construed as NOAA standards or criteria;
exceedance of these values do not infer effects at a
particular site.
Response t NJDEP 's use of NOAA guidelines has always been for screening
purposes. They have never been used or construed as
remediation "standards."
Also, please refer to the response to comment 28.
33. Comments
Of the data presented, the mean sediment concentrations
exceeded the NOAA ER-M for only four inorganics. It is
inappropriate to use the NOAA "effects-based" values for
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15
comparison to site data, since "effects" do not necessarily
equate with mortality.
Response: Examination of Tables 4-8 and 4-10 in the Phase I RI indicate
exce«~dances of the ER-L values for six inorganics and eight
PAHs; the ER-M is exceeded for four inorganics. NJDBP and EPA
Region II routinely consider both the ER-L and ER-M values, as
well as any other appropriate State, Federal or literature
values, in a "weight of evidence* approach when determining
sediment quality. While it is true that "effects" do not
equate with "mortality," we are certainly concerned with any
sub-lethal effect (such as effects on reproduction, decreased
growth, etc.) that could negatively impact the ecosystem.
34. Comment:
Response:
Biological effe~tr -based approaches— such as sediment
bioa. says, tissue residues-based methods, apparent effects
thresholds approach, etc. — should have been used to derive
threshold concentration limits for contaminants in sediments.
Based on exceedance of NOAA guidelines, it is agreed that more
rigorous evaluation of sediment toxicity could have been
appropriate for studies subsequent to the Phase I RI .
However, the need for remediation of the Sip Avenue Ditch was
largely based on engineering principles associated with the
modified solid waste cap included in the NJDEP selected remedy
rather than solely human health and ecological risk concerns.
35. Comment:
Response:
Therr are insufficient data to characterize Sip Avenue Ditch
as an aquatic habitat, or that site-related constituents
contribute to potential ecological risk. Past studies did not
characterize presence/absence of a viable aquatic community
nor Uid they use a biological effects-based approach for
deri« ing threshold concentration limits; ammonia, hydrogen
sulfide and dissolved oxygen should have been measured.
Please refer to the response to comments 26 and 28-34. Also,
ammonia, hydrogen sulfide and dissolved oxygen would normally
be run as part of sediment bioassay testing, which was not
done during this portion of the RI.
36. Comment:
Based on the information in the Chronic BioMonitoring Report,
a determination cannot be made about impacts to surface water
and wdiota attributable to the site contrary to what is stated
in the Proposed Plan. Specifically, the data set from
November 1993 is inadequate to assess the ecological integrity
of the current system nor are the data adequate to
differentiate site-related contributors to degradation, if
any.
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Responses
16
Please refer to the detailed response to comments 26 and 28-
34.
37. Comment t
Response:
Physical/chemical data, such as grain size, hydrogen sulfide
in sediment, total organic carbon, dissolved oxygen, ammonia
and temperature, should have been collected and used to
conduct appropriate evaluation of the sediment and surface
water data and bioassay results.
NJDEP agrees that it would have been appropriate to measure
the ref erencea conventional parameters and recommends their
inclusion sho'-*,d any further testing be conducted. However,
their omission has no impact on the remedial decision because
the need for remediation of the Sip Avenue Ditch was largely
based on engineering princ.'pl.»s associated with the modified
solid waste ct_> included in the NJDEP selected remedy rather
than solely >.uman health and ecological risk concerns. It
should be noced that temperature, dissolved oxygen, pH,
salinity and conductivity were measured by the laboratory
conducting the bioassay on those samples, prior to test
initiation. Those results are contained in the appendix to
the Chronic BioMonitoring Report.
38. Comments
Response t
Inconsistencies between the analytical and bioassay results
require that more information regarding test conditions be
made availabJ < and presented with the data. It cannot be
concluded th&t the cause of mortality was the test solution.
NJDEP recognizes that the results of the bioassay tests are
inconclusive. Based upon the contaminant levels measured in
the river water, high mortality would not ordinarily be
expected. Furthermore, the lowest mortality observed is
associated wit>. the highest chemical contamination, while the
highest mortality observed is associated with the lowest
contaminant levels. It is the experience of NJDKP's Site
Remediation Program that these ostensible inconsistencies
between bioassay and chemical data are not uncommon and,
therefore, we have come to use a "weight of evidence" approach
employing various environmental assessment methods vhea
assessing ecological impacts from contaminated sites.
39. Comments
Relevant background references should have been identified in
order to allow a comparison of the bioassay results associated
with the site.
Responses Please refer to the response to comment 26.
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40. Comment i The significant on-site risk identified as unacceptable in the
Proposed Plan in not greater than the EPA acceptable risk
range of 1 x 10'* to 1 x 10"6. Based on the Human Health Risk
Assessment, there is no r^ed to conduct a remedial response
action addressing the Sip Avenue Ditch because the identified
site risks are within the BPA's acceptable risk range.
Response! Normally, a baseline risk assessment evaluates the risk posed
by the site in the absence of any remedial action. In the
case of the PJP Landfill site, an IRM cap had already been put
in place prior to evaluating site-wide risk. HJDEP decided
that a residential exposure scenario (a house placed on top
of the landfill with occupants eating the leachate and
drinking contaminated wat«r) was not realistic. Therefore,
exposure was limited to children trespassing that included
time spent playing in th«_ Sip Av«.iue
NJDEP acknowledges that '•.he carcinogenic risk falls within
EPA 's acceptable risk range. However, a Hazard Index of 4 was
calculated for current land use for the plausible maximum case
of potential exposures and risk associated with incidental
ingestion and dermal absorption by children of chemicals in
sediment from Sip Avenue Ditch.
Also of relevance is EPA's Directive 9355 3-11FS dated July
1990 entitled "Streamlining the RI/FS for CERCLA Municipal
Landfill Sites.* Page t jree of this EPA Directive states,
"Where established standards, for one or more contaminants in
a given medium are clearly exceeded, the basis for taking
remedial action can be 66 ;ablished. Detailed, quantitative
assessments that consider all chemicals, their potential
additive effects, or additivity of multiple exposure pathways
are not necessary to initiate remedial action." On page 389,
section 5.9.3 of the Phase I RI, the comparison of site data
to ARARs is discussed. Measured concentrations in soil,
ground water and surface water exceeded these values.
Also, please refer to the response to comment No. 12.
41. Comments
Response:
There is no need to conduct a remedial response action
addressing vented landfill gas because the identified site
risks are all within or less than EPA's acceptable risk range
of 10'* to 10'*.
NJDEP acknowledges that the risk . estimate for inhalation of
vented landfill gas is within the EPA's acceptable risk range.
However, NJDEP's ultimate decision to install a gas venting
system is not a risk-based decision.
Also, please refer to the response to comment 59.
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42. Cements Risk estimates for carcinogenic PAHs are misrepresented based
upon the summation for the class of chemicals versus
evaluation of individual components.
Responset At the time the risk assessment was performed, it was the
policy of both NJDEP and BPA Region ZZ to treat all
carcinogenic PAHs quantitatively with the same potency as
Benzo(a)pyrene, while recognizing in the uncertainty section
of the risk characterization that this approach may
overestimate the true risk posed by t-.he site.
43. Comment t
The potential off-site risk is act- illy greater than risk
estimates for the potential exposure to current on-site
conditions.
Responses Comparing risk from anthropogenic background conditions off
site to site-related risks are not relevant for determining
remedial actions at NPL sites.
44. Comments
Responses
The risk assessment used the detection limit as the
concentration present when a non-detect was indicated for
inorganic chemicals in determining site-wide averages of the
compounds .
This was NJDEP policy at the time ;he risk assessment was
done. Total risk from the Sip Avenue Ditch is 4xlO"5, of
which 3xlO"5 is a result of carcinoge.' Ic PAHs.
45. Comments
The scope of the remedy as it pertains to the Sip Avenue Ditch
is inconsistent with the potential risk determined by NJDEP
and supported by site engineering data.
Responses Please refer to the response to comment 12
46. Comments The Human Health Risk Assessment used extrapolated emission
concentrations at estimated maximum discharge rates when
evaluating risks that are overly conservative. The non-
methane organic compound should have been quantified on a
weight/time basis with results reported in pounds per eight
hours. NJDEP should have used EP* Method 25C to analyze
landfill vent gases rather than BPA Method TO-14.
Responses Table 5-18 of the Phase I RZ lists a summary of estimated
ambient air concentrations for the site for both the geometric
mean and minriimim air concentrations. It would be
inappropriate to use results reported on an eight-hour basis
for nearby residents. Not using a time-weighted approach for
the trespasser and worker would probably overestimate site-
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19
related risks. However, site risks are already less than
IxlO"6 for all scenarios except the Plausible Maximum Case for
the child trespasser, which is 2xlO~6, a level EPA deems
discretionary for taking remedial action. Finally, EPA Method
25C was not developed until 1991, so it was net feasible to
use this methodology for the site RI completed prior to 1991.
47. Comment t
Response:
A reference was made to a statement in the Phase III PS
prepared by NJDEP's contractor ICF Technology Company .that
•there were no contaminants found in the surface soil sampling
data in exceedance of the current NJDEP nun-residential
surface soil cleanup criteria; and there were n«- contaminants
found in the subsurface soil sampling data in exceedance of
the current subsurface soil cleanup criteria.*
Further scrutiny of the PS report indicates that the ICF
statements are erroneous. In order to correct-y evaluate the
data, it is necessary to review the RI and Proposed Plan. The
RI data tables depict that contaminants were detected in
surface, subsurface .and test pit soil samples at
concentrations greater than NJDEP's surface and subsurface
soil cleanup criteria in use at the time the RI/FS was
performed. Please note that the current soil cleanup criteria
categories are different from those used during the RI/FS.
Presently, DBF's soil cleanup criteria is listed under the
categories of residential direct contact, non-residential
direct contact and impact to ground water.
48. Comments
VIII. Wetlands
The cost of the NJDEP proposed solid
justified based on risk assessments!
was+-,e cap is not
Response: Please refer to the response to comments No. 26 and 40.
49. Commentt
Response:
It is * presumption in the Proposed Plan that wetland
mitigation/land banking will be required as part of the
remediation of the site. A functional Wetland evaluation
should have been conducted at the site prior to determining
if, and what types of, compensatory measures are required.
While NJDEP implies in Section XIII of the Proposed Plan that
a mitigation plan to address areas impacted will be prepared,
it is also stated that the design phase will include a wetland
assessment. In Section XIII of the Proposed Plan NJDEP states
that "a qualitative assessment of the habitat values, acreage,
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20
tidal influences and other defining factors will characterize
the wetlands and better provide requirements for the
restoration of any wetlands found to be impacted." Thus,
wetlands are appropriately considered in the reined*%1
design/action phases. During further wetland characterization
and compensatory decisions, NJDEP will use "Considering
Wetlands at CERCLA Sites" (BPA540/R-94/019, May 1994) as a
guide.
50. Commentt
Response!
NJDEP did not evaluate the existing wetlands or perfon. a
species inventory.
This statement appears erroneous because it does not take into
account work performed during the RI. Specifically, work
performed during the RI, as noted in Section 5.0 of the K se
I RZ, includes identifying wetlands, conducting a vegete' ion
inventory, and listing expected terrestrial wildlife ind
aquatic species and Observed wildlife.
IX. IRM/Piree
51. Comments
Response:
In the late 1980's underground fires occurred in an i .ea
.defined as Lincoln Park West. Additionally, there have oeen
other underground fires in that area as late as a couple of
years ago. What studies have been done to see what effei ts
the PJP Landfill has had on this area? Can DEP require that
additional testing be done in that area?
Historical information indicates that underground fires c?id
occur in 1966 in the Lincoln Park West area, which is near the
PJP Landfill site. These fires were extinguished in 1986 oy
Boots and Coots, the same NJDEP contractor responsible for
extinguishing the fires at the PJP Landfill site. The PJP
Landfill site and the Lincoln Park West area are separated by
roads and other paved surfaces. There is no connection
between the fires at the two sites. Local officials can
request that NJDEP conduct a preliminary assessment and site
investigation of the Lincoln Park West area as a separate
action.
52. Commenti
Response:
What kind of cap was used during the IRM?
A two-foot cap was installed by NJDEP during the IRM. A cross
section of the IRM cap consists of the following sectionsi
six inches of clean fill material (bottom layer); 12 inches of
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clay (middle layer); and,
hydroseeded (top layer).
six inches of topsoil that was
53. Comment! How can you guarantee the fire will not flare up again?
Response: HJDEP took all possible steps during the IRM to prevent a fire
from reoccurring. These included: removing hazardous
materials that fueled the fire; excavating and dousing the
fill to the water table; and, compacting and capping the fill
to prevent it from reigniting.
X. NJDEP Preferred Remedy
54. Comment: The NJDEP proposed Solid Haste Cap design for the PJP Landfill
is not in compliance with the most current NJDEP Bureau of
Landfill Engineering guidance. The NJDEP has not followed its
own guidance.
Response: NJDEP's proposed cap for the site is a modified solid waste
cap. It should be noted that at the present time NJDEP's
•Technical Guidance for Final Covers at Sanitary Landfills" is
guidance, not a promulgated regulation.
55. Comment: The NJDEP proposed solid waste cap may prove to be an
ineffective "barrier* to prevent precipitation infiltration.
Response: NJDEP'• proposed cap for the site incorporates USEPA guidance
that called for a cap with a 10*7 impermeability to ensure
adequate impermeability for the site.
56. Comment:
Response:
The NJDEP proposed impervious modified Solid Waste Cap will
inhibit expedient natural attenuation since it does not
account for the hydrological setting of the landfill aediua.
A more "pervious* cover would be more beneficial.
Due to the nature of the waste in the uncapped portions of the
site, it is necessary to install an impervious cap.
57. Comment:
The NJDEP proposed 3.5 foot thick Solid Waste Cap
adversely impact the existing structures in the area.
Response: Please refer to the response to comment No. 16.
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58. Comments
Response i
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The NJDEP proposed modified solid waste cap with a high
density polyethylene (plastic) and/or clay layer will inhibit
development in the area.
NJDEP will work with interested parties to allow for reuse of
the site.
Also, please refer to the response to comment No. IS.
59. Comments
Response:
The NJDEP Proposed Plan is inconsistent with respect to
landfill gas management. An active gas collection system was
eliminated from consideration while a gas treatment system was
retained in the Phase I and II feasibility study, which is
contradictory because you need a collection system if you have
a gas treatment unit. The Proposed Plan should reflect gas
management by monitoring or appropriate actions should be
determined during the design phase. Also, gas management
would be better served by the use of a "pervious" cover.
As with all major landfill closures, a gas venting or
treatment system needs to be included in the permanent
remedial actions selected for the PJP site. A gas venting
system is operating on the portion of the site capped during
the IRM. Furthermore, a collection trench and venting system
will be included for the remainder of the site to be capped
with the possibility that this system will be upgraded to an
active system during the design phase. If an active system is
determined to be necessary, the IRM cap venting system will be
incorporated into the new active treatment system.
Overall, the reasons for installing a gas venting system are
regulatory and engineering based, in accordance with NJDEP
solid waste guidance. A system is needed to control the
pressure and migration of landfill gases under the proposed
cap. The specific type of venting system — passive or active —
will be determined during the design phase.
60. Comment t
Responses
61. Comments
The PJP PRP Group submitted an alternate cap design that it
states is equally protective— meeting or exceeding the
expected performance of NJDEP 's proposed remedy—and much more
cost efficient.
The ROD permits a degree of flexibility in the design of the
cap, so long as the alternate design meets the ROD'S
requirements, e.g. an impermeability of 10*7 and other stated
engineering controls.
Why did NJDEP not evaluate in the feasibility study a cap
similar to the one the agency used as an IRM cap in 1985 for
a 45-acre portion of the site since NJDEP has since determined
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62.
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that the IBM cap to be a sufficient permanent remedy for this
portion of the site.
Responset The IRM cap was part of an interim action. Prior to the IRM
cap installation, NJDBP removed 4,770 intact drums, 4,600
cubic yards of contaminated soil (including 650 cubic yards of
•oil contaminated with polychlorinated biphenyls), 136
pressurised gas cylinders and other contaminated debris.
Also, during the interim action approximately 1,033,000 cubic
yards of refuse were excavated and compacted.
Commenti Is this project the direct responsibility of NJDBP?
Responses HJDEP is the lead agency for this Superfund site. USEPA
provides oversight with respect to review of the RI/PS and
ROD. NJDEP will sign the Declaration Statement for the ROD
with concurrence from DSEPA.
63. Comment: Where would you take the known contaminated areas that are
removed?
Response! Areas of contamination removed during the remediation will be
analyzed and disposed of at an appropriately licensed disposal
facility.
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Index of Attachments
A. Proposed Plan
B. Public Meeting Notice
C. Public Meeting Transcript
D. Written Commenta
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