United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-84/007
September 1984
xvERA Superfund
Record of Decision:
Lone Pine Landfill, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R02-84/007
2.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION:
Lone Pine Landfill, NJ
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
12. SPONSORING AGENCY NAME AND ADDRESS
~.1.S. Environmental Protection Agency
401 M Street, S.W.
Jashington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
09/24/84
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
•I-. SUPPLEMENTARY NOTES
ABSTRACT
The 45-acre Lone Pine Landfill is situated on a 144-acre wooded parcel owned
•y the Lone Pine Corporation in Freehold Township, Monmouth County, New Jersey.
.he landfill is approximately 500 feet south of the headwaters of the Manasquan
.iver and 1,000 feet south of the Turkey Swamp Fish and Wildlife Management area..
he Lone Pine Landfill operated from 1959 until 1979 when it was ordered closed by
he New Jersey Department of Environmental Protection. While it was open, wastes
ccepted at the landfill included municipal refuse and septage wastes, at least
7,000 drums and several million gallons of bulk liquid chemicals. The major
lass of contaminants being released from the landfill are volatile organic compounds,
otably benzene, chlorobenzene, methyl chloride, toluene and vinyl chloride.
The cost-effective remedial alternative which was selected for this site rm-
•ludes installation of a slurry wall, approximately 30 feet through the Vincentowm
..quifer; a multi-layer surface seal over the 45-acre landfill; installation of
ground water collection wells located within the contained zone; treatment of ground
later collected from within the contained zone; and monitoring to determine the
effectiveness of the remedy. The estimated present worth capital cost for this
remedy is $10,642,050 and the annual O&M costs are $324,734.
(Key Words on attached page) ^
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
C. COSATI
Record of Decision:
Lone Pine Landfill, NJ
Contaminated media: gw, sw, soil
Key contaminants: VOCs, solvents, resins,
pesticides, metals
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tills Report)
None
138
2O. SECURITY CLASS (This page!
None
22. PRICE
EPA Fofm 2220-1 (R»». 4-77) PREVIOUS EDITION is OBSOLETE
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16. Abstract
Key Words: Ground Water Treatment, Slurry Wall, Source Control,
PRP Alternative, Ground Water Contamination, Off-Site Plume
Control
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ROD ISSUES ABSTRACT
Site; Lone Pine Landfill, New Jersey ..
Region; II
AA, OSWER '
Briefing; September 21, 1984
SITE DESCRIPTION
The 45-acre Lone Pine Landfill is situated on a 144-acre wooded
parcel owned by the Lone Pine Corporation in Freehold Township,
Monmouth County, New Jersey. The landfill is approximately 500 feet
south of the headwaters of the Manasquan River and 1,000 feet south
of the Turkey Swamp Fish and Wildlife Management area. The Lone
Pine Landfill operated from 1959 until 1979 when it was ordered
closed by the New Jersey Department of Environmental Protection.
While it was open, wastes accepted at the landfill included
municipal refuse and septage wastes, at least 17,000 drums and
several million gallons of bulk liquid chemicals. The major class
of contaminants being released from the landfill are volatile
organic compounds, notably benzene, chlorobenzene, methyl chloride,
toluene and vinyl chloride.
SELECTED ALTERNATIVE
The cost-effective remedial alternative wftich was selected for
this site includes installation of a slurry wall, approximately 30
feet through the Vincentown aquifer; a multi-layer surface seal over
the 45-acre landfill; installation of ground water collection wells
located within the contained zone; treatment of ground water
collected from within the contained zone; and monitoring to
determine the effectiveness of the remedy. The estimated present
worth capital cost for this remedy is $10,642,050 and the annual O&M
costs are $324,734.
ISSUES AND RESOLUTION KEY WORDS
1. The Potential Responsible Parties (PRPs) . Ground-Water
proposed capping the site and monitoring Treatment
the ground water to determine the need for . Slurry Wall
additional remediation (as a RCRA closure . Source Control
remedy). However, a slurry wall around the
site and treatment of ground water inside
the slurry wall is also necessary to prevent
the migration of contaminated ground water
into the Manasquan River, to reduce the
potential for releases from areas of the
landfill which remain below the ground water
-1-
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Lone Pine Landfill, New Jersey
September 21, 1984
Continued
ISSUES AND RESOLUTION
surface, and to prevent contamination of
the State's 35 million gallon reservoir
that will be constructed 16 miles down-
stream of the site.
The PRPs did not submit a formal remedial
action plan or supporting documentation for
their source control proposal justifying
exclusion of the slurry wall. Therefore,
EPA proceeded with remedial design and
extended an opportunity to the PRPs to
construct the selected remedial alternative.
An additional off-site hydrogeologic
investigation will be performed to determine
the extent of off-site ground water
contamination and to assess ground water
cleanup alternatives. A supplemental ROD
will oe prepared for off-site plume control
once the hydrogeologic investigation is
complete.
KEY WORDS
PRP Alternative
Ground Water
Contamination
Off-Site Plume
Control
-2-
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Record of Decision
Remedial Alternative Selection
Site;
Lone Pine Landfill site, Freehold Township, New Jersey.
Documents Reviewed;
I am basing my decision primarily on the following documents
describing the analysis of the cost-effectiveness of remedial
alternatives at the Lone Pine Landfill site:
Geophysical Investigation for Buried Drums at the Lone Pine
Landfill, Technos, Inc., August 1981.
Lone Pine Landfill Final Report Excavation and Sampling
Fred C. Hart, January 1982.
Lone Pine Landfill Hydrogeological Investigation, Fred C.
Hart, April 1982.
Lone Pine Landfill Preliminary Aquifer Testing, Fred C.
Hart, July 1982.
Lone Pine Landfill Analytical Results for Samples Collected
September 1982, Camp Dresser and McKee, February 1983.
- Draft Feasibility Study - Lone Pine Landfill, Camp Dresser
and McKee, June 1983.
- Draft Environmental Information Document for Remedial
Actions at the Lone Pine Landfill, Camp Dresser and McKee,
June 1983.
Summary of Organic Chemical Concentrations in Water and
Sediment Samples, Camp Dresser and McKee, August 1983.
Evaluation of Analytical Chemical Data from Lone Pine
Landfill, NUS Corporation, September 1983.
Evaluation of Analytical Chemical Data from Lone Pine
Landfill, NUS Corporation, February 1984.
Presentation of Analytical Chemical Data and Groundwater
Evaluations from Lone Pine Landfill, NUS Corporation,
March and May 1984.
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- 2 -
Supplemental Feasibility Study for the Lone Pine Landfill
Site, Camp Dresser and McKee, May 1984.
Lone Pine Landfill Air Investigation Report, Camp Dresser
and McKee, September 1984.
Responsiveness Summary, including documents prepared and
presented by the Generators Steering Committee, Freehold
Township, Howell Township, and Monmouth County (see Attach-
ment 5).
Staff summaries, memoranda, letters, and recommendations.
Summary of Remedial Action Alternative Selection - Lone
Pine Landfill.
Description _p_f_ Selected Remedy;
- Installation of a shallow groundwater cut-off wall and
surface seal over the 45-acre landfill.
Installation of groundwater collection wells located
within the contained zone.
Treatment of the groundwater collected from within the
groundwater cut-off wall and discharge to the Manasquan
or Metedeconk River, or alternately, to a sanitary sewer
interceptor for treatment at the Ocean County wastewater
treatment plant. (The specific treatment scheme will be
designated upon completion of the ongoing treatability
studies.)
Declarations:
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the National'
Contingency Plan (40 CFR Part 300), I have determined that the
selected containment and treatment strategy for the Lone Pine
Landfill site is a cost-effective remedy, and that it effectively
mitigates and minimizes existing and potential damage to, and
provides adequate protection of public health, welfare and the
environment.
^ I have also determined that the action being taken is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites.
The action will require future operation and maintenance
activities to ensure the continued effectiveness of the remedy.
These activities will be considered part of the approved action
and eligible for Trust Fund monies for a period of one year.
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- 3 -
EPA will undertake an additional field investigation to
further delineate the extent of off-site groundwater contamination,
If additional remedial action is determined to be necessary to
address off-site contamination, a supplemental Record of Decision
will be prepared for approval of the additional action. Also, a
treatability study has been initiated to study groundwater treat-
ment methods. The results of this treatability study will be
incorporated into the design phase of the remedial project.
The Region has consulted with the State of New Jersey in
selecting the recommended remedial action for this site. The
State concurs that containment is the most appropriate source
control measure for the Lone Pine Landfill.
Lee M. Thomas
Assistant Administrator
Office of Solid Waste and Emergency Response
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NOTE;
The original feasibility study evaluated nine alternatives
that addressed both source control and off-site plume control.
And the supplemental feasibility study evaluated five addition-
al alternatives. Because of the need to perform additional
field investigation to further evaluate the plume, this Re-
cord of Decision (ROD) only addresses the nine source control
remedial alternatives from both studies. Upon completion of
the additional field ivestigation, if plume control is de-
termined to be necessary, a supplemental ROD will be prepared.
Because of the alterations in the original presentation in the
feasibility study, the alternative numbering sequence has been
changed as follows:
ALTERNATIVE NO.
Current Previous
1 1 (no action)
2 4A
3 4
4 3B
5 2A
6 5
7 6A
8 6C
9 7
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Briefing for the Assistant Administrator
Record of Decision
Lone Pine Landfill
Purpose;
The purpose of this Record of Decision is to select the
appropriate remedial actions for the Lone Pine Landfill site that
re consistent with the requirements of CERCLA and the NCP. The
ssistant Administrator has been delegated the authority for that
jproval.
ssues;
There has been strong public and congressional sentiment express-
d towards excavating the drums disposed of in the landfill even'
.hough the feasibility study ruled out excavation because of tech-
ical and safety concerns. Furthermore, the public has asked that
-PA consider research and development efforts to reduce the hazard
•ithin the site by the elimination of contaminants through state
f the art technology.
A Generators Steering Committee has been organized to negotiate-"
ith EPA. Currently, at least eight generators are participating.
•ne Committee has provided a considerable number of comments on
ne draft study and has provided data representing their own
ield investigation. The Committee has verbally offered to cap
ne landfill and provide additional source control measures in
he future should the cap alone prove to be ineffective. However,
-. this time, no formal offer, plan or supporting documentation
as been provided to EPA.
In light of questions raised about the extent of off-site ground-
!ater contamination, it will be necessary to perform an additional
ff-site hydrogeological investigation. Upon completion of the
•roposed investigation, if off-site plume control is determined to
,•6 necessary, a supplemental ROD will be prepared for approval
•>f the additional remedial action.
ain Points;
The 45-acre Lone Pine Landfill operated for about 20 years end-
.ng in the late 1970's. During that time, along with municipal
refuse and septage wastes, over 17,000 drums containing chemical
wastes and several million gallons of bulk liquid chemical wastes
were disposed of in the landfill. Hazardous substances continue
to be present at the landfill and its environs.
;
0 Severely contaminated groundwater plumes in both the shallow
Vincentown and the deeper Red Bank aquifers appear to migrate
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- 2 -
from the landfill in a northerly direction towards and into the
Manasquan River.
0 There is considerable leachate seepage, especially after rain-
fall, at the landfill. Contaminated surface water runoff from
the landfill flows into the adjoining wetlands to the north and
then into the Manasquan River.
•*
0 Low levels of volatile organic compounds and heavy metals have
already been detected in the river water column and sediments,
just downstream of the site.
0 Previous response actions at this site include a response to a
chemical fire at the landfill in 1978. A magnetometric study
followed by the excavation and sampling of 69 drums was undertaken
in 1981. In 1982, twenty monitoring wells were installed and
sampled. In 1983, Manasquan River sediments were sampled and five
additional monitoring wells were installed and sampled to further
define the extent of the contamination. In 1984, a groundwater
monitoring well located at the northeastern toe of the landfill
was installed as part of the leachate treatability study, and
air quality monitoring was performed.
0 VERSAR, the responsible parties' (PRP's) contractor, has sampled
the Manasquan River on four occasions from June 1983 to February -'
1984. Their data, which has been presented to the Region, shows
low levels of volatile organics in the river.
0 Notice and §3007 letters were sent throughout 1982. Additional
Information Request Letters were issued in 1983 and early 1984.
Notice Letters addressing the results of feasibility study and
impending design were issued in late summer 1984.
0 The objective of the proposed remedial action is to control the
migration of contamination from the site to protect public health
and welfare, with particular emphasis on maintaining safe drinking
water supplies and the natural surrounding environment. Although
there are no potable public or private wells currently believed
to be threatened, an off-line potable water reservoir is planned
at a location 16 miles downstream from Lone Pine. The contamination
from the landfill may impact the recreational uses of the river
and its environs, as well.
0 In June 1983, Camp Dresser and McKee completed a draft Feasibility
Study. Through a survey of available remedial action technology
,and an analysis of site conditions, six alternatives addressing
source control were identified and evaluated:
1) No action with monitoring.
2) Surface cap (no containment).
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- 3 -
3) Surface cap; containment by pumping (400 gpm) of contaminated
groundwater; and treatment.
4) Containment by means of a surface cap and a slurry wall
penetrating approximately 30 feet through Vincentown
aquifer to the Hornerstown formation, an aquitard; internal
pumping (30 gpm) to maintain a negative internal gradient;
and treatment.
5) Containment by means of surface cap and a slurry wall
penetrating approximately 140 feet through the Vincentown
and Red Bank aquifers to the impermeable Navesink Marl;
internal pumping (30 gpm); and treatment.
6) Drum excavation and removal; surface cap; interception (400
gpm) of contaminated groundwater; and treatment.
0 Based upon the analyses conducted for the June 1983 draft
Feasibility Study and the public comments received on this document,
in May 1984, three additional remedial alternatives which address
source control were identified and evaluated:
7) Containment by means of a surface cap and a 30-foot slurry
wall; internal pumping (30 gpm) and flushing; and treatment.
8) Containment by means of a surface cap and a 30-foot slurry
wall; limited excavation (3 acre area of known drum disposal)
of source materials; internal pumping (30 gpm) and flushing;
and treatment of internal pumpage not used for flushing.
9) Containment by means of a surface cap and a 30-foot slurry
wall; limited excavation of source materials; internal pumping
(30 gpm); and treatment.
Based upon an initial evaluation and screening of these alterna-
tives, the following alternatives were developed for a more
detailed analysis:
Remedial Alternative Present Worth Cost ($ million)
Total Present
Alternative Capital O&M Worth
3 13.2 12.9 (0.79)* 26.1
4 10.7 6.47 (0.32) 17.1
y 30.9 6.47 (0.32) 37.4
*(annual O&M)
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- 4 -
The treatment costs in the above table assume on-site treat-
ment of the extracted groundwater. Below is a comparison of
on-site treatment of the extracted groundwater versus treatment
at the Ocean County Utilities Authority (OCUA) wastewater treat-
ment plant.
Comparison of-Capital and Annual Costs for
On-Site and Off-Site Groundwater Treatment (? jnillion)
Alternative
111
On-site Treatment
System Capital Costs 2.19 0.92 0.92
On-site Treatment
System Annual O&M Cost 0.67 0.23 0.23
OCUA Annual Charge 0.52 0.19 0.19
Option 1: 1 mile
force main 0.26 0.21 0.21
Option 2: 4.5
mile force main 1.16 0.90 0.90
The recommended alternative (Alternative 4) includes on-site
containment with a shallow groundwater cut-off wall and surface
seal; internal pumping (30 gpm); and treatment. The total estimated
present worth capital cost is $10.7 million. Annual operation
and maintenance costs are estimated at $0.32 million (or $3.54
million present worth over 20 years). The present worth monitoring
costs total $0.55 million for a total present worth cost of $17.1
million. A surficial drum cleanup at the ad3acent borrow pit
area and fence installation around the landfill will be performed
during remedial implementation.
o The specific treatment scheme for the extracted groundwater will
be designated upon completion of the ongoing treatability studies.
o An additional off-site groundwater investigation to determine the
extent of the plume will also be performed.
-o The State has agreed with this approach.
o The selected remedy is the cost-effective remedy for the site.
o Monies are available the Fund to finance the remedy. !
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Alternatives
1. No Action
with monitoring.
Capital
"($ miff
0.04
Present
Worth
(9 mil)
0.62
2. Surface Cap.
7.2
y.70
Lone Pine Landfill Site, New Jersey
Remedial Alternatives
Public Health
Considerations
Unacceptable.
Potential for
direct contact
with leachate and
on-site contami-
nation. Potential
threat to reservoir
should more persist-
ent compounds be
released.
Removes direct
exposure threat to
leachate breakouts.
Still potential
threat to reservoir
should more persist-
ent compounds be
released since site
not contained.
Environmental
Considerations
Continued
production of
leachate and
contamination of
ground and surface
water. Continued
threat to flora and
fauna.
Continued contamin-
ation of ground and
surface water.
Continued degrad -
ation of flora and
fauna.
Technical
Considerations
Common engineer-
ing practice.
Public
Comment
Strong
public
resistance
Unaccept-
able to
public.
PHP's
suggested
remedial
solution.
3. Cap, contain-
ment by ground-
water pumping,
and treatment.
13.2 26.1 Since source not Slower cleanup
contained by a phys- of ground and
ical barrier, failure surface water
of pumping system than containment
would present threat with physical
to reservoir. barrier. Pumping
failure would
present threat
to environment.
Marginally less
protection to
flora and fauna
than containment
with cut-off wall,
No slurry wall
constructed.
Increased
capacity ex-
traction and
treatment system
Less reliable
than containment
with cut-off wall.
Requires consider-
able pumping and
O&M. '
Community
resistance
to keeping
contamina-
tion on-
site.
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Alternatives
4. Cap, shallow
containment
wall, and
internal
groundwater
pumping and
treatment.
Capital
"($ roil)'
10.7
Present
Worth '
(5 mil")
17.1
5. Cap, deep
containment
wall, and
internal
groundwater
pumping and
treatment.
6. Drum excavation
and removal,
groundwater
interception
and treatment.
20.9
26.2
79.3
84.6
Public Health
Considerations
Contamination
within the land-
fill would be
contained protect-
ing reservoir
and the recrea-
tional uses of
the river. Phys-
ical containment
provides greatest
assurance of
groundwater protect-
ion. Removes direct
exposure risk.
Contamination within
the landfill would
be contained,
protecting reservoir.
Marginally more
protection than
shallow wall.
Reduces direct
exposure risk.
Reduced threat to
reservoir. Increase
risk to workers from
fire/explosions
and contact with
hazardous substances.
Environmental
Considerations
Gradual restora-
tion of flora and
fauna in vicinity
site. Gradual
natural restoration
of river and aquifer
external to site.
Prevents continued/
increased contamin-
ation.
Gradual restoration
of flora and fauna
in vicinity of site.
Marginally more
protection than
shallow wall.
Technical
Cons iderat ions
Reduced extrac-
tion well and
treatment
capacity. Easier
to construct than
deeper slurry wall,
similar reliability.
Gradual restora-
tion of flora and
fauna in vicinity
of site. Consider-
ably more protection
than cap and inter-
ception alternative.
Potential for adverse
air quality and odor
impacts.
140 foot deep
slurry wall just
about extent of
construction
capability making
it considerably
more difficult to
construct than the
shallow wall.
Significant safety
and engineering
problems. Waste
quantity and nature
of contamination
unknown.
Public
Comment
Community
resistance
to keeping
contamina-
tion on
site.
Community
resist-
ance to
keeping
contamin-
ation
on-site.
Community
perceives
excavation
as most
acceptable.
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Alternatives
Capital
($ mil)
Present
Worth
($ mil)
Public Health
Considerations
Environmental
Considerations
Technical
Considerations
Public
Comment
8.
Cap, shallow
containment wall,
internal pumping,
treatment, and
flushing.
Cap, shallow
excavation
internal pumping,
flushing.
Cap, shallow
limited drum
excavation, ground
water treatment.
30.8
37.4
Potential for flushing Gradual restoration Flushing not Suggested
of contaminants from of flora and fauna in technically feasible by TRC.
system. Marginally vicinity. Marginally for this site because
more protection than more protection than of short-circulating
containment. containment. and hydraulic infeas-
ibilities. Containment
still required.
Increased risk to
workers. Potential
for removing part
of source. Marginally
more protection than
containment.
Reduces direct ex-
posure risk. Reduced
threat to reservoir
by removing part of
source. Increased
risk to workers
from fire/explosions
and contact with
hazardous substances.
Gradual restoration
oE tlora and Eauna
in vicinity.Potential
for adverse air
quality and odor
impacts. Ma rg i nal ly
more protection
than containment.
Gradual restor-
ation of flora
and fauna in
vicinity of site
and aquifer ex-
ternal to site.
Restoration capa-
bilities equiv-
iient to other
shallow slurry
wall contaminant
options. Po-
tential for ad-
verse air quality
and odor impacts.
Flushing not technic- Suggested
ally feasible for by TRC.
this site because of
short-circuiting and
hydraulic infeasibil-
ities. Containment
still required.
Significant safety Perceived as
and engineering
problems. Source
strength unknown.
Quantity of waste
to be removed
unknown.
desirable by
community.
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- 5 -
Next Steps
Action Date
- AA-OSWER approves ROD September 21, 1984
- Amend State Superfund Contract for Design September.28, 1984
- Award IAG for Design .. September 28, 1984
- Start Design November 1, 1984
- Complete Design May 1, 1985
- Amend State Superfund Contract for June 1, 1985
Construction
- Award IAG for Construction June 1, 1985
- Start Construction July 1, 1986
- Complete Construction July 1, 1987
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- 6 -
Key to Figures, Tables, and Attachments
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
Table 1
?able 2
able 3
able 4
able 5
able 6
able 7
able 8
able 9
ible 10
able 11
dble 12
able 13
able 14
able 15
able 16
Figures
Site Location Map.
Site Plan.
Stratigraphy Cross Section.
Soil Types and Slopes.
Contaminated Groundwater Monitoring Wells.
Location of Private Drinking Water Wells.
Location of Municipal Drinking Water Wells.,
Proposed Remedial Solution for Source Contro-J
Tables
Soil Characteristics in the Vicinity of
the Site.
Water Bearing Properties and Quality of
Geological Formations in the Vicinity of
the Site.
Summary of Manasquan River Surface Water
Analytical Data.
Summary of Groundwater Data.
Summary of Manasquan River Sediment
Analytical Data.
Summary of On-Site Soil Samples.
Summary of Excavated Drum Samples.
Patrial Listing of Wastes That May Have
Been Disposed of in Lone Pine.
Summary of Air Quality Sample Data.
Remedial Alternative tor the Lone Pine
Landfill Site.
Alternatives Undergoing Final Evaluation.
Remedial Alternatives Costs Comparison.
Comparison of Capital and Annual Costs for
On-Site and Off-Site Groundwater Treatment..,
Selected Remedial Alternative Capital Cost's.,
Annual Operation and Maintenance Costs for
Selected Remedial Alternative.
Remedial Alternative Implementation Schedule.
.Attachment 1
Attachment 2 -
Attachment 3 -
Attachment 4
Attachment 5
Attachment 6
A11 ac hme n t s
June 24, 1983 Public Meeting Anouncement Press
Release.
June 24, 1983 Public Meeting Attendees.
August 1, 1984 Public Meeting Announcements
Press Release. s
August 1, 1984 Public Meeting Attendees.
Responsiveness Summary.
State Review Process.
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- 7 -
Summary of Remedial Alternative Selection
Lone Pine Landfill
Site Location and Description
Situated in a rural,.marshy area, the 40-50 ft. high Lone
Pine Landfill is located on Burke Road, off Elton-Adelphia Road,
in Freehold Township, Monmouth County, New Jersey (see Figures 1
and 2). The 45-acre landfill, which is located about 500 feet
south of the headwaters of the Manasquan River, about 1000 feet
west of the 200-acre Turkey Swamp Fish and Wildlife Management
Area, is situated on a 144-acre mostly wooded parcel owned by
the Lone Pine Corporation. Along with municipal refuse and
septage wastes, at least 17,000 drums and several million gallons
of bulk liquid chemical wastes were disposed of in the landfill.-
The nature of these disposed materials is largely unknown.
The landfill is bounded by Burke Road to the east and south,
and a swamp to the west, which drains to the Manasquan River at
the Landfill's northern boundary. The area in the vicinity of
the Landfill is sparsely populated with only about half a dozen
residences in the immediate vicinity, the closest being about
600 feet south of the landfill.
A local sportsman club, the Fin, Fur, and Feather Club, is
located about 1000 feet to the east of the landfill. A 700-acre
municipal potable water supply reservoir is planned for construc-
tion at a location 16 miles downstream of the landfill off the
Manasquan River.
The landfill is located on relatively fiat land which
gradually slopes towards the Manasquan River to the north. The
surrounding terrain is predominantly gently rolling Coastal
Plains with small hills. The site lies within the 2.4 square
mile subbasin of the regional Manasquan River watershed. Surface
waters within the subbasin drain into tributaries of the easterly
flowing Manasquan River. Groundwater in the immediate vicinity
of the landfill provides a major source of water for the Manasquan
River, which has a variable flow rate of approximately 2 to 70 cfs,
Figure 3 presents a generalized geological cross section in
the vicinity of the site. Test pits around the landfill indicate
that the water-bearing Vincentown sands is situated from several
-inches to several feet beneath the surface at the extreme east of
the site, thickening in a wedge to a depth of about 30 feet
towards the southeast. In the southwest portion of the site, a
recent deposition of black organic topsoil is found on the surface,
Three major soil series have been identified in the immediate
vicinity of the landfill: Atson, Lakehurst, and Lakewood series.
The soils generally, consist of gravelly sands, silty-gravelly
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LONE PINE V / / /MANAGEMENT AREA
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Figure 1
LOCATION MAP
LONE PINE LANDFILL SITE. FREFHni n, NJ
<^Jt
NEW1
IJERSE1
SCALE: T=
-------
400'
BOO*
0*
LEGEND:
it SEDIMENT SAMPLE LOCATIONS
• GROUNDHATER SAMPLE LOCATIONS
BASE MAP: FRED C. HART ASSOCIATES. INC..
LONE PINE LANDFILL
HYOROGEOLOGIC INVESTIGATION.
30 APRIL 1982
LONE PINE LANDFILL
Figure 2
SITE MAP
-------
A
EPA a
*«*^Si»
EPA 5
';;.VlNCENTOWN
:;.:;
MANA9MMN NIVf*
f
\ LONE PINE
\ LANDFILL /
V
^.^X^I^^tt-fjINE j£^?:'g+$&&K;&
T1NTON SAND
VERTICAL SCALE
(••oggtrolkm »
Tiort
•-t.'^> •+*.*'* 54*0^.^ .'W1'V'V
^^ ~- • i .•*** —-• - »• ^^ f^ r**~^ *v» «%•
L
J
o too toort
HORIZONTAL SCALE
SOURCE: FRED C. HART ASSOCIATES. INC.. 1982
COM
LONE PINE LANDFILL
CROSS SECTION OF THE STRATIGRAPHY
IN VICINITY OF LONE PINE LANDFILL
Figure 3
-------
- 8 -
sands and clayey-gravelly sands, with high permeability rates,
generally increasing with depth. Figure 4 shows the location of
the various surficial soils found at the site and Table 1 indicates
the properties of these soils. Lone Pine Landfill is situated in
the Coastal Plain physiographic province. The site is underlain
by unconsolidated g"ravel, sand and clay.
The Vincentown, whiefi lies directly beneath the topsoil, is
underlain by the Hornerstown formation. The Vincentown Sand
consists of fine-to-medium-grained quartz sand to a sandy,
clayey, limestone character in the upper level and greenish-gray
micaceous, clayey glauconitic fine-to-medium-grained sand in the
lower level. The underlying Hornerstown formation, consisting
of 10-12 feet of a deep green, silty, glauconitic, fine sand
with varying amounts of clay, functions as an aquitard (a semi-
confining bed Jin restricting the vertical movement of groundwater
between the Vincentown and Red Bank formations. This is underlain
by the Tinton Sand which ranges from 5 to 8 feet thick, and is
heavily indurated with siderite, a finely crystalline ferric
carbonate. The Tinton Sand exhibites moderate permeability
depending on the degree of cementation. This is underlain by
the water-bearing Cretaceous Red Bank Sand. Test borings indicate
the presence of several distinct stratigraphic units within the
Red Bank Sand. The upper portion of the formation is partially
indurated, glauconitic, silty, fine sand. This is underlain by
a layer of coarse and poorly sorted sands followed by a layer of
silt and fine sand.
Below the Red Bank formation lies the Navesink Marl formation
at an estimated 140 feet below the surface. Deep water-bearing
formation below the Navesink Marl include the Englishtown and
Raritan-Magothy aquifers. Table 2 shows the water bearing pro-
perties of the geologic formations found in the vicinity of the
site.
No floodplains have been designated within the limits of
this portion of the Manasquan River.
Surface features include several on-site leachate ponds and
a dozen or so visible drums and debris at the borrow pit adjacent
to the landfill across Burke Road. A chainlink fence and gate
restrict access along Burke Road.
Site History
_ The Lone Pine Landfill operated from 1959 until 1979 when it
was ordered closed by a New Jersey Department of Environmental
Protection (NJDEP) Administrative Order. Until it was closed,
Lone Pine accepted over 17,000 drums containing chemical wastes
along with municipal refuse, large volumes of septage, and millions
of gallons of bulk liquid chemical wastes.
-------
ATSION . 0-2S SLOPE
UKENUKST . 0-51 SLOPE
LAKCMOD - 0-«t
fWMMMUH WCK • KARLT 1EVEL
SMRDBBUHT . 0-W SLOPE
COLCMNTOIM . 0-n SLOPE
TIVTON - MEMLT LEVEL
FREEHOLD - 0-402 SLOPE
AOCLPHIA - O-IOI SLOPE
COLLIN6TOK - 0-40S SLOPE
CMNBERRY 106
SCALE: T-20001
Figure 4
LONE PINE LANDFILL
SOIL TYPES
AND .
SLOPES
-------
Table 1
SOIL CHARACTERISTICS IN THE VICINITY OF LONE PINE LANDFILL
son. saint
AUfa* (All
LokOMTtt ll*|
.
UkOMOrf (lot
SkroMkory (So)
CotoMtttM (CM)
TtatM (To)
rrookoM (rrl
Aootpklo (Aol
tellteftM (Cat
MooolMbJi lo Nock
(Nil ot tarfoca
micM. vaniCM. TOTUW
own TO irjnnoM IMFIU or
NICM Mia nouirt.j (incktii saisoa rowuoiiiniin/hn
1-t.O 0-40 S»M or loMy I.O-IO
* j — * 1^^ .^^^al AA^J ••AflAil
(•pMroM MV.*JHM| SAM IOOMII
l.l-l.l O-oO Siotf or lOMy t.0-20
((••oroot Jt«. HOT lit Mo4 iMMll
1.0 0-«0 Sao4 or lotoy o.O-M
MM IMMll
0-1.0 0-N S*M, cl«y IOM O.I-tO
ItOMTOOt Ott.-jM*) ' IMtOll. t«My
furfoco liytr lock-
• • lof or > 10 lockos
, _ 0-1.0 . O-oO CUmtMMll. O.t-O.I
iMTCkM OCt.-JMt) klfk (IMKOIIUO
1.0* 0-10 S*My city IOM. l.O-o.O
Ion f liucmlto
M.O 0-M S*My city IOM. 0.t-«.0
iHoiol^ IOM
(Uocoollo
t*-4.0 040 UMy chy IOM IM- O.t-I.O
(OMOTMI Joo.-Aorll. toll, oootrito
fUocoolto
•.0 0-10 S«My cl«y IOM Mk- O.C-o.O
toll, oootrtto
fltHCMltO
, 0-CO Orfoote Mtor 1*1- >|.0
ouck MM.frovolly
MTUUH OUIMfit
a ASS
Poorly o>«(oM
Nodtritoly Mil
^--iMd
9f • im
Cicottlvtly
oVoloM
Poorly ortloto-
Poorly 4rilM4
Hall o>*loH
Moll oralM4
No4*r«Uly Mil
0>OlM4
Moll o>olMtf
Vary poorly
UACTIOI
IfM) UOOIIIIITV
!.«-$. 0 Lot Ottotrito
l.l-t.O IM
1.1-1.0 Vary lavlov
1.1-1.0 Notf-lM
l.l-l.l »
1.1-1.0 SMjact to
•M orotlM
(f laft koro
1.1-1.0 IW-MI|fc
l.l-i.O IM-Hlffk
J.I-I.S No4-lM
1.1-1.0
sviTwiim m UMTIU «•
(in or imuiioi
SOMTO MOMMl klfk MMT UklO »«
MBtk Of 0-lt lOCfcOt.
Sovoro: MOMM! klok MMT loklo
atotkl of l.i-l.l MMT« of VTOMO-
Mtor aollotlM kotMM of ro»M
piiViiillUy.
•t
Sovoro: IOM MM* of f lltor Mtortolt
kt»r4 of or'"* <•*•'' pal lot IM •
OOCMM of rooM ooroMklllty.
Tin...
^VWvv
^OMTO
• IM OMMtt of filter Mtorlil ro»M
ooroMklllty la tMttritM ooraltt
froMOMtor oollotloo.
.Savora: tlooo
.Sovoro: Mt«it
•
Sovoro: tloao
Sovoro: Hlfk Mtor tokto, IM ko«
rla*
it MM tall CMMrmltan Urwlco. IW.
-------
Table 2
Geologic formation
Hater-bear Ing properties
Hater Quality
Vine en town Formation
Hqrnerstown Sand
Red Bank
Navesink Formation
Mount Laurel Sand
Uenonah Formation
Mar shall town Formation
English town Formation
Joodbury Clay
Merc ban tvllle Formation
tagothy Formation
tar1 tan Formation
flssahlckon Formation
Numerous domestic wells tap this sand; yields
10-50 gpm to domestic wells
A poor aquifer; yields up to 5 gpm to domestic
wells.
Yields range from 3-30 gpm to domestic wells.
Important to domestic consumers. Hells yield
10 gpm or less.
A single aquifer. Average yield 10 gpm.
Maximum yield reported was 335 gpm.
Not considered water-bearing In the county.
Average yield 25 gpm. Maximum yield reported
640 gpm. Average yield to large-capacity wells
410 gpm.
Both formations act as a single aqulclude. Not
water-bearing.
Sands are discontinuous, and thickness variable.
Maximum yield reported 250 gpm.
Contains most Important aquifers. Yields range
100-1,400 gpm to large-diameter wells.
No wells In this formation.
Excellent Incidence of low pH
and high Iron content...
Acidic may require treatment for
removal of Iron.
Excellent
Generally good, except for Iron
Moderately high hardness 1n some areas.
Excellent except for high Iron content.
Generally good, except for Iron
and magnesium. Isolated problems
have occurred with nitrates and some
heavy metals, e.g., cadmium and
chromium.
Source: New Jersey Department of Conservation 4 Economic Development 1968
-------
- 9 -
In the early 1970's, NJDEP unsuccessfully attempted to force
the Lone Pine Corporation, the owner and operator/ to update its
operation to minimize the leachate and surface runoff problems at
the landfill. Following a NJDEP sampling investigation in 1977
and a chemical fire and explosion in 1978, EPA sampled the leachate
and the Manasquan River, detecting various organic compounds. By
the end of 1979, NJDEP had closed the landfill to all wastes. An •
EPA inspection to determine the feasibility of a CWA §311-funded
cleanup led to the recommendation that additional investigations
be conducted on a high priority basis and that no §311 funds be
activated. (Funding was not recommended because, at the time of
the inspection, §311 actions were limited to incidents involving
oil, and the State Attorney General had filed a suit against Lone
Pine Corporation to insure proper closure.) Subsequent sampling
studies indicated signficant levels of toxic organics and heavy
metals in the groundwater and leachate, and low levels in the
Manasquan River downstream of the site.
Following a magnetometric study in the summer of 1981, which
indicated the possible presence of tens of thousands of steel
drums, 69 drums were excavated. Thirty-five of these drums had
retained partial" contents with 25 containing sludge, and 10
containing liquid. A variety of organic priority pollutant
substances, heavy metals, and pesticides were contained in these
rusted, leaking drums.
Based upon testimony stemming from the criminal trial of the
principals of Scientific Chemical Processing (SCP), a waste
processing firm, over 17,000 drums containing chemical wastes
were illegally disposed of in the landfill. According to the
testimony, large quantities of drummed solid and liquid wastes
were sent to the landfill. The drum disposal operation at SCP
involved the dumping of the materials in drums into large dump-
sters. Where the drum could be totally emptied, it was sold to
a drum reconditioner. When the drum could not be emptied, it
was segregated and loaded into a dumpster for disposal at Lone
Pine. If the drum was determined to contain solids at the bottom,
it was considered not suitable for drum recovery and was disposed'
of, even though it might have contained considerable liquid
content. Bulk disposal occurred also.
The results of a fall 1981 - winter 1982 hydrogeological
investigation indicated severe groundwater contamination in
both the shallow Vincentown and the deeper Red Bank aquifers,
with the contamination appearing to migrate north and northeast,
-respectively, towards and into the Manasquan River (see Figure
5).
In July 1982, EPA and the State of New Jersey signed a State
Superfund Contract to undertake a remedial investigation and
feasibility study at the Lone Pine Landfill. As part of this
study, in the Spring of 1983, additional field work including the
-------
^ »•»•!«••» • *»«' •
* I '. « —, ', \
••411 <>/•)).. " .
721 (•/•J)'-^X*
:«r^.^^-^/»*>;::5t
««0} <2/»)
i - ' '. - 9~ ~ ~_r *»«•»«»««. -*i.at
•SSS??^—^v--
»«?«*.-=:.-;.•;>:;->:.
'1702 (2/«2) "x x»
t
CM-0<
/'__„—- ~~Ji"~Iy.p^^^~^
;-'' ,-'" .•••'( ^T^cs \» NH"
>• \
**"%
*« »
4 ^
\*
t
*,''
,-ciM
•<»?vs -'
•y f~)
V-*
<&
s\
•<•«•:
Vlnccntmrn Send a Aaulfcr
U.45I (>/•»
IO.WJ <»/•»
£ MIO (2/«I) ,
14.416 (»/«> ,
>«> tank AflUlf.r
PotentJoiRetrie Surface
Measured on March 31.'1
Lone Pine Landfill
* well not accessible for 2/84 sanpli™
f
CONTAMINATED GROUNDWATER MONITORING WELLS
Total Volatile Org
Figure 5
-------
- 10 -
collection of Manasquan River sediment samples and an additional
hydrogeological investigation was completed by Camp Dresser and
McKee (COM), the EPA Zone Contractor.
In July 1983, COM completed a draft Feasibility Study.
Following public review and comments, additional alternatives
were evaluated and reported in a supplement to the Feasibility
Study. This supplement was completed in May 1984 and submitted
for public comment.
In May 1984, a groundwater monitoring well was installed at
the northeastern toe of the landfill as part of the leachate
treattability study.
In June 1984, COM performed air quality monitoring at the
site over a two day period.
In June, August, and November 1983, and February 1984, VERSAR,
the contractor for the Generators Steering Committee, sampled the
Manasquan River. The data from these investigations have been
considered in the alternative analysis.
This fall, three monitoring wells will be installed through
the landfill mound to better define the nature of the contamination
emanating from the site and to assist in further describing the
strata underlying the landfill.
The State of New Jersey has issued various orders requiring
the Lone Pine Corporation to take any steps necessary to prevent
leachate and runoff contamination. In addition, the State Attorney
General has filed suit against the Corporation to insure proper
closure of the landfill. On the federal level, the landfill's
former general manager pleaded guilty to charges related to
illegal dumping of hazardous waste at the site. A jury convicted
three principals of Scientific Chemical Processing, a waste
processing firm that used Lone Pine illegally to dispose of
drummed and bulk wastes.
C ur r ent Si t e S t atus
There are four potential routes of exposure associated with
the Lone Pine Landfill: direct contact, surface water, groundwater,
and air.
The landfill is located adjacent to the Turkey Swamp Fish
-and Wildlife Management Area which is used extensively for hunting
and fishing. The site is accessible to game, which through the
process of nesting or feeding on the site, may introduce contam-
inants into the human food chain.
j
There are three intermittent feeder streams that lead into
the 6-8 foot wide Manasquan River at its headwaters: two
-------
- 11 -
streams which originate in the woodlands to the north and north-
east, and a stream to the south which winds through the northeast
section of the site. Leachate has been observed flowing from
the toe of the landfill through the woods into the marsh adjoining
the Manasquan River and directly into the river itself via the
stream that winds through the northeast section of the site.
This leachate problem appears to be most pronounced following
storm events. Samples of. this leachate have indicated high
levels of volatile organic compounds.
A sediment sampling investigation was performed in the
Manasquan River and the southern tributary adjacent to the land-
fill. The investigation indicated the presence of low levels of
contamination in the tributary's sediments. This contamination
is attributed to the leachate and surface runoff.
The results of a hydrogeological investigation indicated
severe groundwater contamination in both the shallow Vincentown
md the deeper Red Bank aquifers beneath the landfill.
Water surface elevations in the wells installed during the
ydrogeological investigation indicate that groundwater in the
urficial Vincentown aquifer generally moves north, turning
astward to parallel the direction of the flow in the Manasquan
iver.
Since high concentrations of contaminants were found in the
aeper Red Bank aquifer beneath the landfill, it is apparent
'iat there is a downward vertical movement of pollutants from
ie Vincentown to the Red Bank formation. This further indicates
lat the Hornerstown formation does not function as a confining
ayer. Once the contaminants enter the semi-confined Red Bank
quifer, they appear to migrate northeasterly towards the Manasquan
iver. Since upward vertical gradients between the landfill and
..he river were found, it is believed that contaminants in the Red
-;ank aquifer migrate back upwards into the Vincentown aquifer,
jventually discharging into the Manasquan River^
When the landfill was constructed and operated, portions of
the Vincentown Sands aquifer were excavated down to depths of as
jiuch as 10 feet below grade. Therefore, even though the drums
were disposed of in the latter years of the landfill's operation,
because they were disposed of by dumping off the edge of a truck
onto the working face of the landfill drums may be located deep
enough in the landfill to come into contact with the water table.
-J.t is also likely that residual pools of non-aqueous fluids from
ruptured drums and from bulk liquid dumping may have settled in
the lower depths of the landfill, providing a continuing source
of contamination to the Vincentown aquifer as the wastes
resolublize. «
-------
- 12 -
The general,area in the vicinity of the landfill is sparsely
populated: The nearest private wells (see Figure 6) include
three upgradient residential wells screened in the Vincentown
aquifer, the closest of which is approximately 600 feet south of
the landfill; a nonresidential well screened in the Englishtown
aquifer located approximately 1000 feet east of the landfill; and
several residential wells screened in the Vincentown aquifer,
located about 1/2 mile north of the site across the Manasquan
River. (As indicated previously, groundwater data indicate that
contamination apparently does not migrate north of the river.)
Approximately 85% of the Township residents are served by a
municipal well system consisting of six wells, the closest of
which is located approximately 4 miles northeast of the site (see
Figure 7). Based upon the available data, it is believed that
no existing groundwater drinking water supplies are presently
threatened with contamination since the river apparently serves
as a hydrogeological barrier and .sink for the contaminated ground-
water. (The monitoring well north of the river has consist-
ently been found to be clean.) However, as a result of the surface
runoff and leachate, and the input of the contaminated Vincentown
and Red Bank aquifers into the river, low levels of organic
compounds and heavy metals have been detected in the Manasquan
River adjacent to and just downstream of the site. Surface water
in the vicinity of the site is a major environmental concern
since it provides water to wildlife and supports a variety of
aquatic biota further downstream. In addition, the river is
used for recreation and limited irrigation and a reservoir is
planned for a site 16 miles downstream of the landfill.
The major class of contaminants currently being released from the
landfill are volatile organic compounds, most notably benzene,
chlorobenzene, methyl chloride, toluene, and vinyl chloride. A
second class of compounds, base neutral extractables, in particular,
isophorone and phthalates, are being released as well.
Tables 3, 4, 5 and 6 indicate the quantities of the contam-
inants found in the surface and groundwater, sediments, and
on-site sludge, respectively. Many of these compounds are toxic
and potential carcinogens.
Table 3
Summary of Manasquan River
Surface Wa te_r_ An a 1 y t i c a 1 Data
jC propound M a x i m u m^ Con c e n t r a t i o n (ppb)
Volatile Organics EPA VERSAR*
Benzene 25 , 19
Chlorobenzene 140
1,2-Dichloroethane 120
-------
^Z-T5
'04W Vr'• 1
K&S
A PRIVATE DRINKING ..fi
WELLS
——BOUNDARY OF THE
HANASQUAN RIVER SUB-BASH
SOURCE U.S.E.P.A. JUNE. 1981
FRED C. HART. 1982
SCALE: T»2700'
COM
Figure 6
LONE PINE LANDFILL
LOCATION OF PRIVATE
DRINKING
WATER WELLS
-------
•SOUTHERN
GULF
N
.
•••••Ml
\
r
•KOENI6
LANE
7
•^
OWN SHIP?
J_ !>-,
LONE PINE
LANDFILL
\ \ .
^.PROPOSEO.T /
WEU.S U
k» • • • •
HATER SYSTEM-EXISTING HELLS''
Location ^Formation
Koenlg Lane Rarltan
Point Ivy Engllshtown
Koenlg Lane Rarltan
Southern Gulf Engllshtown •
Southern Gulf Rarltan
Point Ivy Rarltan-
Magothy
!SOWCC: NONMOUTH COUNTY
BflMO. 1»78
....<
\ .-t v 7^ v
•-•,. \-rt' \ .!' \
if! V? ,
O 4POO' 8,000' 12,000*
SCALE: f»6,000
Figure 7
LONE PINE LANDFILL
LOCATION OF EXISTING ft PROPOSED
DRINKING HATER HELLS
-------
- 13 -
Volatile Organics (Cont.)
1,1-Dichloroethane
1,1-Dichloroethene
1,2-trans-Dichloroethene
Ethylbenzene
Methylene chloride
Tetrachloroethene
Toluene
Trichloroethene
Trichlorofluoromethane
Vinyl chloride
EPA
220
23
29
280
35
32
26
28
15
440
VERSAR*
12
*Contractor for Generators Steering Committee
Table 3
Summary of Manasquan River
Surface _W_a_ter_ jVnaly t icaj. Data (Cont' )
Compound
Ac id CompoundIs
Benzoic acid
2-methylphenol
4-methylphenol
Phenol
B a s e/Neutral E x tract able s
4-methyl-2-pentanone
Bis (2-ethylhexylJphthalate
Chloromethane
Di-n-butyl phthalate
Diethylphthaiate
Naphthalene
0-xylene
Phenanthrene
Inorganics (ppm)
Aluminun
"Arsenic
Barium
Cadmium
Iron
Lead
Manganese
Maximum[Concentration (ppb)
EPA VERSAR*
280
44
400
trace 1.6
4200
trace
13
trace
24
170
340
trace
1.3
0.013
1.0
0.012
380.
0.049
1.2
0.35
trace
0.05
trace
20.3
trace
0.1
-------
- 14 -
Ino rg a n i c s (ppm)
Tin 0.052
Zinc 0.13
*Contractor for Generators Steering Committee
trace
0.02
Table 4
Summary of jSroundwater Analytical Data—EPA jtells
Compound
B a s e /N e ut r a 1 E x t r actables
Bis(2-ethylhexyl) phthalate
Di-n-Octyl phthalate
Ac id Cojnpound s
Pentachlorophenol
Phenol
Vo1a t i1e Organ i c s
Benzene
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-trans-Dichloroethylene
Ethylbenzene
Methylene Chloride
Tetrachloroethylene
Toluene
Trichloroethene
Trichloroethylene
Vinyl Chloride
Inorg ani cs (jpjpm)
Aluminum
..Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Zinc
Maximurn^ Detected Concentration (ppb
523
57
70
625
1939
97
8
1655
208
98
2128
3325
527
76
4708
370
1423
334
80
0.042
0.82
0.77
1.9
1.3
14,000
4.8
0.91
39.
-------
- 15 -
Table 5
Summary of Manasquan River Sediment Analytical Data
Compound Maximum Detected Concentration {ug/kg)
Base/Neutral Compounds
Bis (2-ethylhexyl) phthalate <400
Volatiles
Benzene 31
Chlorobenzene <2.5
Ethylbenzene 140
Methylene Chloride 478
Fluorotrichloromethane 7
Styrene <2.5
0-xylene 7.4
Table 6
Summary of On-Site Soil Samples
Compound De tec ted Conce n trat ion (ppb)
Volatiles
Benzene 2900
Chlorobenzene 4100
1,2-Chloroethane 260
Chloroform 95
1,1-Dichloroethylene 6
Ethylbenzene 25,000
Methylene Chloride 170
1,1,2,2-Tetrachloroethane 1040
Tetrachloroethylene 12,000
1,1,1-Trichloroethane 1600
1,1,2-Trichloroethane 34
Trichloroethylene 24,000
Toluene 80,000
JJased upon the results of a magnetometric investigation in 1981,
69 drums were excavated from 4 of 8 locations coinciding with
magnetometric profiles showing large anomalies. The drums, con-
taining solids, liquids, and viscous sludges, ranged from empty
to 3/4 full. The solid samples obtained, varied from a»thick,
black polymer-like substance to a black and brown sludge. The
liquid samples were a variety of colors. The results from the
-------
- 16 -
sampling of 35 of the drums that contained waste materials are
delineated in Table 7. An evaluation of this data indicates the
presence of various organics, pesticides, and heavy metals solids
and sludges.
Table 7
Summary of Excavated Drum Liquj-d, Viscous Material, Sludge and
Sol id Samples
Compound
Base/Neutral Extractables
Nitrobenzene
Bis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Di-n-butyl phthalate
Naphthalene
Di-n-octyl phthalate
1,4-Dichlorobenzene
Diethyl phthalate
Benzo (a)pyrene
Isophorone
Pesticides
Aldrin
4,4'-DDT
Alpha-endosolfan
Heptachlor
Heptachlor epoxide
Alpha-BHC
Beta-BHC
Delta-BHC
PCB-1260
Acid Compounds
2-nitrophenol
phenol
Volatile organics
Benzene
Chlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Chloroform
Maximum Detected Concentration (ppnrj
Liquid Viscous Sludge Solids
3.7
3.6
50.
27.
11.
0.21
material
16.
3.5
54.
1.1
1.9
0.11
32.
-
-
1200
2200
-
-
3700
0.2
0.71
110,
2200
1000
400
340
3600
3200
0.4
1.68
0.82
120.
0.82
0.17
150.
0.81
38.
0.79
0.63
J.800
19,00f
450C
13,000
4500
57
1.43
22.
33.
105.
8.5
4.8
10.
0.7
14.
3.2
-------
- 17 -
Volatile organics
1, 1-Dichloroethylene
1, 2-trans-Dichlorethylene
Ethylbenzene
Methylene Chloride
Tetrachloroethylene
Toluene
Trichloroethylene
Inorganics
Arsenic
Antimony
Chromium
3ery Ilium
-admium
'opper
Liquid Viscous Sludge Solids
:ickel
elenium
ilver
nallium
inc
material
0.16
1.4
43.
340.
410.
2400.
4.5
-
-
2000.
160.
28.
220.
-
0.16
7.1
300.
240.
52.
5600.
8.6
0.18
8.3
3400.
38.
58.
5900.
19.
80
230
1400
3
14
2400
410 "
2000
40
18
40
5800
200
68
24
2
trace
210
20
39
100
52
100
97
230
780
1000
9
trace
29,000
8900
200
trace
12
trace
1200
80
320
1600
3
140
610
500
300
1900
50
trace
880
-------
Table 7
Summary of Excavated Drum Liquid, Viscous Material, Sludge and
Solid Samples
Sample description
DESCRIPTION OF SAMPLES
Remarks
Solid clear glassy
material (possibly
a polymer)
Sampled from a 3/4 full drum.
Sample had to be chipped by chisel.
OVA and PIO readings showed no response
Transluscent thick
polymer-Hke material
Sampled from a 3/4 full drum.
Sample had to be chipped by chisel.
OVA and PIO readings showed no response.
Solid polymer-Hke
material
Sampled from a 3/4 full drum.
Sample had to be chipped by chisel.
OVA and PIO readings showed no response.
Adequate sample could not be collected and
was not submitted for analysis.
Dark brown, viscous
material
Sampled from a 3/4 full drum.
OVA and PIO readings showed no response.
Solid, polymer-like
material
Sampled from a 3/4 full drum.
OVA and PIO readings showed no response.
Adequate sample could not be obtained and
was not submitted for analysis.
Oily solid material
Sampled from a semi-crushed drum.
PID picked up aromatic compounds.
Standing water
Standing water
Groundwater sample.
Groundwater sample.
_ White crystallne solid Sampled from an open drum.
Gluey grey sludge-like
material
Sampled spilled material from a crushed
drum. *
OVA reading was 200 ppm.
Grey sludge-like
material
Sampled from an ooen crushed drum.
-------
""Table 7 continued
DESCRIPTION OF SAMPLES
Sample description Remarks
Blue liquid
Black sludge
Black solid/sludge
White sludge
Bl^.ck water
Red solid
Black liquid
White liquid
Black solid
Grey tan solid
Pink liquid
Yellow liquid
Black liquid
Black solid/sludge
Brown solid
Sampled from a leaking semi-crushed drum.
Sampled from a semi-crushed drum.
Sampled from a semi-crushed drum.
Sample from a semi-crushed drum.
Two (2) qroundwater samples.
Sampled from a semi-crushed drum.
Sampled from a leaking drum.
Sample from a leaking drum.
Sampled from a semi-crushed drum.
Sampled from a semi-crushed drum.
Sampled from a 3/4 full drum.
OVA reading was greater than 1000 ppm.
Drum had bluish color similar to Ashland
Chemical drum.
Sampled from a leakinq drum.
Groundwater sample.
Sampled from spilled materials of a
crushed drum.
Sampled from a semi-crushed open drum,
-------
Table 7 continued
DESCRIPTION OF SAMPLES
Sample description Remarks
Brown viscous sludge
Black liquid
Viscous sludge
Black liquid
Grey powdery solid
Purple crystalline
solid
Red powdery solid
Viscous liquid
Black liquid
Black sludge
Black sludge
Red solid material
Sampled from 3/4 full drum.
OVA reading was 350 ppm.
Sampled from a drum.
OVA'reading was greater than 1000 ppm.
Sampled from a 3/4 full drum.
OVA reading was greater than 1000 ppm.
Drum had Ashland Chemical markings.
Other distinct marking was 1044-7-10.
Sampled from a 3/4 full drum.
OVA reading was greater than 1000 ppm.
Sampled from a 1/2 full drum.
OVA reading was greater than 1000 ppm.
Sampled from a 1/2 full drum.
Sampled from a 3/4 full drum.
Sampled from a 3/4 full drum.
OVA reading was greater than 1000 ppm.
Drum had Ashland Chemical markings.
Sampled from a semi-crushed drum.
Sampled from material spilled from
semi-crushed drums, faint red color
coating, marking could not be read.
Sample apparently shaped by being in a
drum.
Sampled from an open crushed drum.
OVA reading was greater than 1000 ppm.
Black standing water
Groundwater sample.
-------
- 21 -
Although there is evidence of severe groundwater contamination in
the vicinity of the site and distressed vegetation on and adjacent
to the landfill, only low levels of contamination have to date
been detected in the adjacent Manasquan River. This may be due
to volatilization taking place in the river. Additional ground-
water investigation will better define the extent of off-site
contamination. Several hundred yards downstream of the. site,
these compounds have not toeen detected. However, since this
landfill is "young" in terms of how recently many of the hazardous
substances were disposed of (late 1970's), it is believed that
the currently detected compounds may not be totally representative
of the wastes that were disposed of and, consequently, of the
wastes that may eventually be discharged to the environment.
)ne reason for this is that the various contaminant adsorptive,
bsorptive, and density properties may affect the introduction
f these contaminants into the groundwater. Other possible
easons include the presence of intact drums containing unreleased
astes, the perching of contaminants in impermeable zones within
he landfill, or the presence of solid residues that will solublize
hen exposed to water. As a result, a major concern is the
otential threat to the thousands of residents of Monmouth and
orthern Ocean Counties who will receive their drinking water
rom the planned downstream reservoir, should a release of more
ersistent pollutants from this uncontrolled landfill occur
"jmetime in the future. Public recreational areas downstream of ~
le site, as well as local and downstream flora and fauna, may
iso be impacted from such a release.
The concern over the latent threat of release of highly
;?xic compounds from the landfill is based upon the data derived
rom the drum excavation and sampling program, as well as the
•jsults of a careful review of testimony presented at the Scient-
fic SCP trial and responses stemming from information requests
f companies. From these sources, a partial listing of wastes
hat were transported to SCP has been compiled. Because of the
.llegal nature of the operation, records as to which of these
Bastes were ultimately disposed of at Lone Pine are,not available.
lowever, based upon a review of the trial transcripts, it is
:lear that Lone Pine was used by SCP for the disposal of large
juantities of drummed waste and also large volumes of bulk waste.
?he drums contained liquids, solids, and sludges. The sludges
/ere likely to have been highly contaminated due to contact with
irummed material emptied into dumpsters during the separation
activities at SCP. The sludges also had a high moisture content,
at times bting as much liquid as solid. Significant amounts of
.hazardous substances were also transported to the site by
transporters including Freehold Cartage.
The compiled partial listing of SCP wastes presents a best
guess approximation of what might have been disposed of.in the
landfill. Many of the hazardous substances included on this
list are contaminants currently detected in high concentrations
-------
-- 22 —
in the groundwater, including benzene, chlorobenzene, methylene
chloride, and toluene. Significant quantities of organics and
heavy metals that have not been detected in the groundwater,
have also been identified as having been accepted by SCP, and
may have been disposed of in the landfill. Table 8 shows a
partial listing of drummed wastes that may have been illegally
disposed of at Lone Pine by SCP.
It has been suggested that the level of contamination present
in the groundwater has been decreasing over time. However, by
evaluating the data, it can be seen that this does not appear
to be true. Referring to Figure 5, while the total volatile
organic concentrations in the Vincentown appear to be relatively
constant, except for one monitoring well that has decreased by
an order of magnitude, there is an order of magnitude increase
in one Red Bank monitoring well and contamination has been detected
in a previously clean well. In addition, samples from the monitor-
ing well installed at the toe of the mound for the leachate
treatability study, has shown total volatile organic concentrations
significantly higher than the concentrations detected in the
monitoring wells downgradient of the site (see Table 4): 160,000
ppb Methylene Chloride at the toe of the mound, as compared to
527 ppb in the plume; 15,000 ppb Trichlorethylene versus 1423 ppb;
3700 ppb Benzene versus 1939 ppb; 4200 ppb Ethyl Benzene versus
3325 ppb; and 24,000 ppb Toluene versus 4708 ppb. The data ap- -"
parently indicates that considerable quantities of contamination
are currently being released from the landfill.
Despite gross contamination of tne aquifers beneath and
downgradient of the landfill, the present impact on human health
is believed to be low since, currently, there are no known down-
gradient receptors. Presently, hunters, dirt bikers, and other
trespassers who might come into direct contact with the leachate
seeping from the landfill are the only known human receptors
believed to be threatened.
Wildlife that feed and nest on the landfill and its vicinity
may also be exposed to and accumulate contaminant concentrations
from the landfill. These fauna, if hunted, may also introduce
contamination into the human food chain.
In March 1984, .a sample taken from downgradient monitoring
well CDM-4A (see Figure 2) in the Red Bank formation, identified
contamination in a location that tested clean for organics pre-
viously. Also a sample from previously contaminated downgradient
-well EPA-5, recently tested clean for organics. Since a link
has been established between the wastes in the landfill and the
contamination found in surface and groundwater in the vicinity
of the site, on-site remedial measures were evaluated. The
recent groundwater sampling, however, has raised questions regard-
ing the extent of the contaminated plume and the actual contamin-
ant transport route. As a result, the monitoring wells will be
-------
- 23 -
resampled and several additional wells will be installed as part
of the proposed additional off-site hydrogeological investigation,
Based upon this evaluation, the extent of the contaminant plume
and the need for off-site plume control will be determined.
In June 1984, air quality samples were taken at the site
during a two day period. Table 9 shows the results of this
investigation.
-------
Table 8
Partial Listing of jVastes That May Have
Been_ Disposed of ^A t Lone Pine
Acetophenane
Acids
Acrylates
Acrylonitriie
Aldehydes
Amides
Anthracite
Antimony
Aromotics
Arsenic Trioxide
Benzene
Butanediol .
Butanol
Butyl Phenol
Carbon Tetrachloride
Caustics
Chlorobenzene
Chloroethane
Chloroform.
Chromic Acid
Copper Waste
Cresyl Acid
Cyclohexane
Dichiorobenzene
Dimethyl Ketone
Diphenyl
Diphenyl Methane
Diphenyl Oxide
Dyes
Epoxy Wash
Ethanol
Ethers
Ethyl Acetate
Ethylene Dichloride
Flamable Wastes
Fluroide
Formaldehyde
Halogenated Mix, Spent
.Heptaldehyde
Heptane
Heptene
Hydazine
Inks
Kerosene
Lacquer, spent
Latex Residue
Maleic Anhydride
Melamine
Mercury Salts
Methanol
Methyl Bezamid
Methyl Cellulose acetate
Methyl Chloroform
Methyl Isobutyl Ketone
Methyl Vinyl Ketone
Mithramycin
Monomers
Nail Polish Wastes
Naphthalenes, chlorinated
Nickel, Waste Plating Solution
Nitrates
Nitroaniline
2-Nitropropane
Otoledine
Paint Thinners and Sludges
Paladium Catalyst
Pharmaceutical wastes
Phenols
Phosphoric Acid
Pigment, Waste
Plasticizers
Polymers
Pyridine
Radioactive Residues
Resins
Sodium Cyanide
Solvent, Spent
Toluene
Trichloroethane
1,2,3 Trichloropropane
Varnishes
Varsol, waste
Vinyl Pyridine
Xylene
Zinc
-------
- 24 -
Table 9
Summary of Air Quality Analytical Data
Compound
1,1,1-Trichloroethane
Trichloroethylene
Benzene
1,1,2,2-Tetrachloroethylene
Toluene
Ethylbenzene
Maximum Detected Concentration
(mg/m3)
0.17
0.08
0.08
0.04
0.69
0.14
jased upon this data, while volatile organics are detected, it
'oes not appear that there is a significant air contamination
roblem at this time.
nforcement
otentially responsible parties (PRPs) have been identified.
The Lone Pine Steering Committee is a generator committee which
as organized to negotiate with EPA. Currently, at least eight
RP's are participating and four meetings have been held. The
ommittee has provided a considerable number of comments on the
rait study and has provided data representing their own field
nvestigations. The Committee has offered to cap the landfill
nd provide additional source control measures in the future
>hould the cap prove to be an effective source control measure,
lowever, no supporting documentation has been provided by them
to support their recommended alternative and, as of this date,
10 settlement has been reached.
It is EPA's intention to negotiate with the PRP's for the
implementation of the remedy. If these negotiations are fruitless,
or if it appears that the PRPs are not negotiating in good faith,
then EPA may consider the issuance of a CERCLA §106 Administrative
Order for the construction of the remedial action.
^Alternatives Evaluation
The primary objective of the feasibility study was to evaluate
remedial alternatives using a cost-effective approach consistent
with the goals and objectives of CERCLA. A cost-effective remedial
alternative as defined in the NCP (40 CFR 300.68J) is "the lowest
cost alternative that is technologically feasible and reliable
-------
- 25 -
and which effectively mitigates and minimizes damage to and
provides adequate protection of the public health, welfare, or
the environment." The NCP outlines procedures and criteria to be
used in selecting the most cost-effective alternative.
The first step is to evaluate public health and environmental
effects and welfare concerns associated with the problem.
Criteria to be considered.are outlined in Section 300.68(e) of
the NCP and include such factors as actual or potential direct
contact with hazardous material, degree of contamination of
drinking water, and extent of isolation and/or migration of the
contaminant.
The next step is to develop a limited list of possible remedial
alternatives which could be implemented. The no-action alternative
may be included .on the list.
The third step in the process is to provide an initial screening
of the remaining alternatives. The costs, relative effectiveness
in minimizing threats, and engineering feasibility are reviewed
here. The no-action alternative may be included for further
evaluation when response actions may cause greater environmental
or health damage than no-action responses. A no-action alternative
may also be included if it is appropriate relative to the extent
of the existing threat or if response actions provide no greater -•
protection.
With respect to the no-action alternative, the results of the
field investigation and the feasibility study indicate that there
are significantly high levels of contamination at Lone Pine.
Specifically, the groundwater beneath the site is severely contami-
nated and is migrating towards and into the Manasquan River. The
NJDEP has established a maximum concentration of total volatile
organic compounds for possible closure of drinking water wells as
100 ppb. Although there are no drinking water wells immediately
affected by the site, as was shown in Table 4, groundwater samples
have been far in excess of this value. Also, the concentrations of
some of the detected contaminants are far in excess of exposure
levels based upon unit cancer risk (UCR) values which have been i-
dentified by EPA for drinking water. These levels are based upon
an incremental increase in cancer risk of 10~& assuming exposure
to a 70 Kg adult consuming 2 liters of water per day. The ground-
water concentrations of Benzene, 1,2-Dichloroethane, and 1,1-Di-
chloroethene are 2881, 1749, and 2908 times their UCR levels, re-
spectively. In addition, considerable quantities of leachate
_are oozing from the landfill into the river. Low levels of
volatile organics have been detected in the river just down-
stream of the site. Although significant contaminant levels are
believed to be entering the river (samples from the monitoring
wells located on the southern bank of the river are severely
contaminated), the lower concentrations detected in the river
may be attributable to volatilization. Additional hydrogeologic
-------
- - - - _ 26 -
investigations are planned to better define the extent of off-site
groundwater contamination and to answer questions raised concerning
whether the plume of contamination fully discharges into the
Manasquan River.
In addition, the landfill's unprotected side slopes are sub-
ject to erosion, increasing the potential for the transport of
contaminants into the Manasquan River. Also, the erosion may
expose wastes in the future, thereby creating additional health
risks due to direct contact.
In addition, any future spread of contamination if no action
is implemented could adversely impact future growth and development
in areas north of the landfill that are currently zoned for resi-
dential development. Parklands adjacent to the site could also
oe adversely affected if the portion of the Manasquan River
located within the park is unable to support waterfowl and other
,=orms of wildlife.
Two major concerns have been identified in relation to this
ite. The first is primarily a public health concern related to
he 35 million gallon.per day reservoir which is planned at a
ocation 16 miles downstream from the site. (The dilution factor
ssociated with the 16 mile distance from the site to the proposed
aservoir intake is estimated to be 55:1 based upon the ratio of -
rainage areas. It can be expected that any volatile organics
ould have volatilized by the time they reached the reservoir,
owever, relatively little dilution is provided for persistent
ompounds.) Because of the uncertainty of the nature of the
astes disposed of in the landfill, there is concern about future
2leases of more persistent compounds from this uncontrolled
;te. A change in the nature of the contamination currently
.nanating from the landfill may impact the future water supply,
iireatening the health of thousands of people in Monmouth and
cean Counties. (It should be noted that the State of New Jersey
itends to discontinue over 20 sources of contamination along
he Manasquan River as part of its program to begin the construc-
lon of the proposed reservoir.)
The second concern, the impact of the site on the local
mvironment, is both a public health and environmental issue.
''errestrial ana aquatic flora and fauna appear to have been
idversely affected at and adjacent to the site. In addition,
jownstream portions of the Manasquan River are stocked with
trout which may be consumed by humans.
~ Based upon the results of the field investigation and the f
easibility study, the potential impact of Lone Pine Landfill on
the adjacent environment, and the potential contamination of the
proposed reservoir, it was determined that the no-action}altern-
ative does not adequately protect public health and the environ-
ment and that a remedial measure should be implemented.
-------
- 27 -
From the evaluation of existing data and information on the
nature and the extent of the contamination associated with the
Lone Pine Landfill, the following objectives were established:
1) To maintain an adequate safe drinking water supply for the
population that could be affected by groundwater contamination
migration;
2) To protect the Manasquan River surface water uses (fishing,
swimming and water supply) from contaminant release; and
3) To prevent local exposure to contaminated materials at
the site and in adjacent areas (soil, sediment, and
leachate).
Although groundwater cleanup is also an objective, this issue
will be addressed later with a separate Record of Decision.
With these objectives in mind, a list of feasible remedial meas "es
was developed. Alternatives identified as having the potential
to meet the remedial response objectives were subjected to a
two-step evaluation process. The first step consisted of an
initial screening of the candidate alternatives (see Table 10)
based upon relative present worth cost, environmental impacts,
and engineering considerations. The second step consisted of a
more thorough evaluation.
Since the landfill's source strength and composition is largely-
unknown, the contaminant transport model used to simulate the
relative contaminant transport for the remedial alternatives was
calibrated to achieve the best fit to observed contaminant plume
data. Various remedial schemes were simulated and evaluated by
projecting the contaminant loading rates to the Manasquan River.
(Field sampling results indicate significantly lower concentrations
in the surface water than is predicted by the model since
volatilization was not considered in the groundwater contaminant
transport model). Because of the limited available data on the •
quantity and nature of the waste in the landfill and since the
potential for contamination to continue to be released from the
landfill exists, to ensure a conservative design a constant
source strength was assumed for modeling purposes. It was also
assumed that the wastes are evenly distributed over the landfill
and capable of sustained, steady state releases. It should be
noted that the purpose of the contaminant transport modeling was
.pnly to help evaluate the relative effectiveness of each alternative,
the remedial alternative analysis and selection was based upon
.the groundwater flow model, which evaluated the effects of various
containment and pumping schemes on the flow of groundwater in
the underlying aquifers. »
As a result of the initial screening, Alternative 2, the surface
cap alternative, was deleted from further consideration. This
-------
- 28 -
alternative allows the contamination to be released from the
landfill, but at a reduced rate.
Based upon the available data and field observations, it appears
that no significant groundwater mound (attributable to infiltration))
exists within the landfill nor does it appear that the water
level in the landfill substantially impacts the area groundwater
flow, but rather the water encountered in the landfill is infiltrated
water perched on top of local impermeable layers (such as impervious
sludge zones). While infiltration may occur at the landfill
surface, a major portion is believed to be diverted to surface
seeps, never entering the Vincentown aquifer. Thus, the net
nfiltration to the saturated zone of the Vincentown within the
andfill is estimated to be no greater than that to the undisturbed
ortion of the Vincentown Sands. These assumptions are supported
y field observations indicating that seeps are intermittent and
ccur at various elevations and contain apparently different
•jmtaminants based upon staining color. Furthermore, no water
as encountered.in one of the trenches excavated for drum sampling.
relatively, low mound beneath the landfill in the Vincentown
luifer does occur, but it is believed to be due to upgradient
ows and surrounding surface controls rather than infiltration.
The hydraulic impact of the installation of a surface cap
0~7 cm/sec) alone was simulated under the conservative assumption
at all of the infiltrated water recharged the Vincentown Sands
uifer and was reduced from about 0.1 cfs to 0.01 cfs or by 90%
the Cap. However, as it was stated above, only a small portion
the infiltrated water is believed to activelly enter the
ncentown aquifer, with -the majority being diverted to surface
eps. (Once the landfill is capped, all of the rainwater that
filtrates the cap that does not become perched, will eventually
ach the underlying aquifer, since the surface seeps will have
en eliminated.) The simulation of the installation of a cap
suited in a lowering of the water table by approximately 1
;ot, corresponding to a reduction in the lateral groundwater
.ow beneath the landfill from 0.03 - 0.04 cfs to about 0.01
is. Over the area of the landfill, this represents an average
ecrease in the saturated thickness of the Vincentown Sand layer
f approximately 10% with less than a 2% change in the thickness
f the unsaturated zone. However, there is evidence that the
ite was excavated down to depths of 10 feet into the Vincentown
ands aquifer during the period in which the landfill was being
constructed and operated. Measurements from monitoring wells
around the site indicate that the groundwater surface is above
-this level, allowing the lateral flow component of groundwater
at the lower depths of the landfill, to flood the bottom of the
fill area, potentially allowing the solubilization and dispersion
of substances derived from ruptured drums and from bulk liquid
dumping.
-------
- 29 -
In addition, the strata underlying the landfill is complex
and not fully understood. The planned installation of monitoring
wells into the landfill mound will help provide further information
relative to the level of water in the mound and help to better
describe the subsurface strata. The potential problems are
compounded by the uncontrolled manner in which disposal took
place, resulting in the possibility that solvents could.mobilize
chlorinated organics which might otherwise tightly adsorb onto
soil particles. Several non-volatile organic substances de-
tected in the excavated drums (see Table 7), pose a cancer risk
in drinking water at very low concentrations. Some of these con-
stituents and their respective exposure levels based upon UCR
values include Benzo (a) Pyrene (0.00304 ppb), Aldrin (0.00306
ppb), DDT (0.00416 ppb), Heptachlor (0.0104 ppb), and PCBs (0.00806
ppb). Although some of these substances were only found in trace
amounts, the limited excavation and sampling program presents
the possibility that significant quantities of these substances
could be in the landfill. Therefore, the evidence shows that
the reduction in infiltration resulting from the installation of
a surface cap alone willnot eliminate the contaminant flux from
the landfill to the groundwater.
The PRPs have expressed an interest in implementing Alternative
with a contingency plan should the monitoring program show that
capping alone is ineffective in controlling releases from the
landfill. However, as was indicated, the evidence does not support
the PRP's conclusion that a cap alone would effectively prevent
future releases to the environment. In addition, if this landfill
had been a permitted hazardous waste disposal facility, closure
in compliance with RCRA would be required which would entail a cap
and a liner. Also, the State of New Jersey has specifically
stated that a cap alone is inadequate and unacceptable.
Alternative 5, the deep slurry wall, was deleted form further
consideration because it would cost about $9 M more than a
shallow wall, while yielding only a slight groundwater cleanup
advantage. In addition, this alternative presents technological
difficulties in that the required depth of excavation is just
about at the limits of available technology. Unlike the shallow
containment wall system, the deep wall will entrap existing
contaminated groundwater which is currently present in the Red Bank
aquifer immediately below the site, removing it from the active flow
field. An analysis of alternatives for groundwater cleanup will
be conducted in the future and will address off-site groundwater
contamination. If groundwater cleanup is recommended, then
jpumping and treating the off-site contaminated groundwater will have
a cost considerably lower than $9 M.
Alternative 6 consists of the complete drum excavation and
removal along with disposal of contaminated soil. This,alternative
was deleted from further consideration because it was not considered
cost-effective and because the potential safety and engineering
problems associated with drum excavation far outweighed the
-------
- 30 -
long-term benefits. The cost estimate for complete drum removal
is at least $80 M. The major safety concern results from a fire
and explosion potential from the use of construction equipment, or
spontaneous combustion, due to the presence of methane from the
disposal of organics, including septage wastes. In addition,
opening the landfill is likely to result in the release of odors
associated with landfills undergoing anaerobic decomposition as well
as the emission of volatile organic vapors from hazardous materials
which in themselves are potentially harmful to public health.
Excavation would subject on-site workers to the potential for
direct contact with hazardous materials. Furthermore, the reliability
of this alternative is questionable. It is likely that the majority
of the buried drums have ruptured due to the high compressive
forces and suspected corrosive environment in the fill area.
(This is not to say, however, that the contents of the drums have
necessarily left the landfill. Dispersion within the landfill is
a function of many factors including the substance's density and
;he adsorptive and absorptive capacities of the soil and other
•olid materials disposed of in the landfill.) The materials that
ave leaked from the ruptured drums when added to the several
\illion gallons of bulk liquid chemical wastes that were disposed
f at the site yields a considerable quantity of waste that may
ot be removed with the excavated drums and the adjacent soil and
aste material. So in short, it would be extremely difficult to
dentify all of the contaminated material and even a complete
xcavation of the drums and the adjacent soil and waste material
ay not necessarily remove the bulk of the contamination.
Table 10
Remedial Alternatives for the l^one Pine I^andfill Site
) No action with monitoring.
:) Surface cap (no containment).
-) Surface cap; containment by pumping contaminated groundwater
(400 gpm); and treatment.
1) Containment by means of a surface cap and a slurry wall
penetrating approximately ,30 feet through the Vinoentown
aquifer to the Hornerstown formation, an aquitard; internal
pumping (30 gpm) to maintain a negative internal gradient;
and treatment.
5) Containment by means of a surface cap and a slurry wall
penetrating approximately 140 feet through the Vincentown and
Red Bank aquifers to the impermeable Navesink Marl; internal
pumping (30 gpm); and treatment. >
6) Drum excavation and removal; surface cap; interception (400
gpm) of contaminated groundwater; and treatment.
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- 31 -
7) Containment by means of a surface cap and a 30-foot slurry
wall; internal pumping (30 gpm) and flushing; and treatment
of internal pumpage not used for flushing.
8) Containment by means of a surface cap and a 30-foot slurry
wall; limited excavation (3 acre area of known drum disposal)
of source materials; internal pumping (30 gpm) and flushing;
and treatment of internal pumpage not used for flushing.
9.) Containment by means of a surface cap and a 30-foot slurry
wall; limited excavation of source materials; internal
pumping (30 gpm); and treatment.
The flushing alternatives (7 & 8) consist of pumping contaminated
ground water from below the landfill, treating it, and discharging
it back on the landfill surface by spray irrigation or by subsurface
injection with a piping or trench system. This concept is based-
on the use of relatively clean water to "flush" the contaminants
from within the landfill mound with subsequent collection and
treatment. This approach is intended to eventually lead to a
removal of contaminants from the landfill. This alternative was
determined to be technically infeasible because of the impermeable
zones within the landfill, the likelihood for short-circuiting of
the recharged water, and the hydraulic infeasibility of flushing in
the northern and the northwestern portions of the landfill (where"
the bulk of the drums were allegedly disposed). In addition, the
maintenance of the recovery wells will be difficult due to the
high likelihood for clogging as a result of high iron concentrations.
The wells will have to be cleaned and/or repaired frequently and
a skilled operator will be required to carefully monitor the
performance of the system. Thus, because of the significant operation
and maintenance requirements, and since it is likely that
flushing will have limited effectiveness in areas of known waste
disposal, these options were deleted from further consideration.
After the completion of the initial screening of technologies, a
further evaluation was conducted in order to recommend a cost-
effective alternative. The following alternatives were developed'
for a more detailed analysis of effectiveness and cost measures.
Table 11
Alternatives Undergoing Final Evaluation
3) Surface cap; containment by pumping (40C gpm) of contaminated
groundwater; and treatment.
4) Containment by means of a surface cap and a slurry wall
penetrating approximately 30 feet through the Vincentown aquifer
to the Hornerstown formation; internal pumping (30 gpm); and
treatment. !
9) Containment by means of a surface cap and a 30-foot slurry
wall; limited excavation of source materials; internal pumping
(30 gpm); and treatment.
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- 32 -
This narrowed list of remedial alternatives was further evaluated
according to the following criteria: cost, reliability, implement-
ability, operation and maintenance requirements, environmental
impacts, and safety requirements.
According to the NCP, a total cost estimate must also be considered
for remedial actions and must include both construction and
annual operation and maintenance costs. These costs were estimated
for the alternatives under consideration. A present worth value
analysis was used to convert the annual operation and maintenan..
costs to an equivalent single value. These costs were considered
over a 20 year period at a 10 percent discount rate.
Alternative 3: Surface cap; containment by pumping (400 gpm)
contaminated groundwater; and treatment.
This alternative differs from the slurry wall alternatives in
that no physical on-site containment is provided, but rather a
groundwater flow pumping system is used to collect contaminated
groundwater before it enters the river. This interception system
is composed of a series of off-site wells with a relatively high
pumping rate. The wells are located in a zone between the landfill
and the river since existing data indicate that flow is toward
the river.
Simulation results indicate that this scheme will allow for
partial treatment of the existing plume. The extraction
wells provide a mechanism for capturing contaminants prior to
their reaching the Manasquan River and continuous pumping will
be required until the source is dissipated. Complete aquifer
restoration could not be achieved until the source contaminants
have ceased to migrate from the landfill, which is estimated to
take more than 20 years. This alternative is capable of meeting the
response objectives, is technically feasible and has a net positive
impact on the environment, however, the lack of a containment
wall implies greater adverse consequences to water quality if the
pumps and treatment system should fail to perform properly in the"
future. In addition, the high pumping rate significantly affects
operation and maintenance requirements and cost.
Alternative 4: Containment by means of a surface cap and a slurry
wall penetrating approximately 30 feet through the Vincentown
aquifer to the Hornerstown formation; internal pumping (30 gpm);
and treatment.
Simulation results indicate that internal pumping within the
Vincentown aquifer at 30 gpm will create a negative pressure
gradient within the confines of the shallow slurry wall (similar
to a sump pump), restricting the movement of contaminated
groundwater away from the site-. This will cause the groundwater
to flow inward through the slurry wall and upward through the
Hornerstown formation, effectively containing the source of
contamination.
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- 33 -
This alternative allows the migration of contaminants already in
the Red Bank formation beneath the landfill to continue, pending
resolution of the appropriate action for groundwater cleanup.
This alternative is technologically feasible, is capable of
meeting the response objectives and is effective from ah
environmental standpoint. And because of the low pumping rate,
associated operation and maintenance requirements will be
considerably less than Alternative 3. In terms of non-cost and
cost ranking, this alternative appears to be the cost-effective
and environmentally sound choice for source control at this site.
Alternative 9; Containment by means of a surface cap and a slurry
wa11 pen e t r a t i n g approximately 30 feet through the Vincentown
aquifer to the Hornerstown formation; internal pumping (30 gpm);
limited excavation of source material; and treatment.
This alternative is the same as alternative 4 but with the
addition of a limited excavation of source material prior to
containing the site.
Total excavation was previously discussed and eliminated from
further consideration due to health, safety, and technical
considerations. This alternative consists of a limited excavation
program in an area of suspected high concentration drum disposal.-•
The proposed limited excavation is based on previous subsurface
investigations at the landfill. These investigations included
both a geophysical survey which identified magnetic anomalies
within the landfill and a limited subsurface exploration program
which investigated the presence of buried drums. The results of
these programs were applied to evaluate the magnitude and extent
of the proposed excavation.
The limited excavation program was assumed to include three acres
where buried drums were previously found. The results of the
earlier field excavation program were utilized to develop assumptions
regarding the number of drums which would be encountered and the •
quantities of hazardous waste which require either on-site treatment
or off-site disposal. Based upon assumptions regarding the locations
and contents of the drums derived from the previous excavation
activities, it was estimated that 7,700 drums could be recovered
and approximately 45,000 cubic yards of contaminated soil and
refuse would be handled as bulk hazardous waste.
__ Opening the landfill will likely result in adverse impacts on air
quality from the release of odors and the emission of hazardous
organic vapors which are potentially harmful to public health.
On-site workers will be subjected to risks from direct contact
with the excavated materials. In addition, workers will, be
subjected to dangers from fire and explosion.
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- 34 -
Although the excavated drums and surrounding contaminated soil
will be removed, a large area of the remaining landfill will
still contain soil contaminated by the disposal of bulk liquid
wastes or by the contents of ruptured drums.
Since the distribution of the contamination is largely unknown,
there is no assurrance that this limited excavation will remove
a significant portion of the total quantity of waste within the
landfill. Therefore, the*site will still need to be contained
as in Alternative 4, offering about the same level of protection
to public health and the environment as containment alone, but
adding over $20 million to the cost.
Table 12 shows the various costs associated with the alternatives
considered in the final screening.
Table 12
Prei sent _Wp_rth_
Remedial Alternative Costs Comparison ($ million)
for a Twenty Year Period
Alternative
3
4
9
*(annual O&M)
Capital
13.2
10.7
30.9
O&M
12.9
6.47
6.47
(0.79)*
(0.32)
(0.32)
Total
Present Worth
26.1
17.1
32.4
As part of the Lone Pine Landfill remedial program, it will be
necessary to treat the extracted contaminated groundwater. A
treatability study has been initiated to identify treatment
methods and preliminary operating parameters for an on-site
treatment scheme, as well as an evaluation of discharging the
contaminated water to a main trunk line sewer of the Ocean County
Utilities Authority wastewater treatment plant. The potential
discharge points for an on-site plant include the Manasquan River
to the north of the site, and the Metedeconk River to the south.
The results of this treatability study will be incorporated
into the project design.
The treatment costs in Table 12 assume on-site treatment of the
extracted groundwater. Table 13 shows the capital and operating
costs for the on-site and off-site treatment schemes under
-consideration. Option 1 employs the construction of a force main
through the woods along the river for a distance of approximately
one mile to intersect with the main trunk line sewer. Option 2
employs the construction of a 4.5 mile force main along a roadway
right-of-way to the main trunk line. !
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- 35 -
Table 13
Comparison of Capital and Annual Costs for
On-site and _0_f_f-site Groundwater Treatment _(_$ jnillion)
Alte r native
-1 1 1
On-site Treatment
System Capital 2.19 0.92 0.92
Cost
On-site Treatment 0.67 0.23 0.23
System Annual
Operation Maintenance
Cost
OCUA Annual Charge 0.52 0.19 0.19
Option 1: 1 Mile 0.26 0.21 0.21
Force Main
Option 2: 4.5 Mile 1.16 0.90 0.90
Force Main
Cpmm u n i ty Re1a t i o n s
Throughout the feasibility study and the associated field work,
all sampling data and reports have been submitted to the Freehold
Township Health Officer who maintains a public repository and is
the Chairman of the Freehold Township Technical Review Committee
(TRC), a group of local residents and health officials appointed
by the Mayor to review all technical documents associated with
this project.
After publically releasing the draft Feasiblity Study, a three
week public comment period ended on June 24, 1983, the date of
the public meeting to discuss the findings of this document. The
meeting was announced via a press release (see Attachment 1)
which identified three public repositories as well as the location
of the public meeting — Freehold Township Administration Building,
Freehold, New Jersey. This meeting was attended by 80 people
consisting of EPA, NJDEP, TRC, several citizen groups, the local
Congressional Representative, and local residents. Attachment 2
_is a list of attendees.
As a result of comments offered by the TRC at several meetings,
two additional alternatives were evaluated, which led to the
development of the Supplemental Feasibility Study. This, document
was released to the public for comment on June 27, 1984, and a
public meeting was held on August 1, 1984.
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- 36 -
The date of the public meeting to discuss the findings of
the Supplemental Feasibility Study with the public, was announced
via a press release (see Attachment 3). The press release indicated
the location of the meeting which was attended by 100 people.
Attachment 4 is a list of attendees.
At the public meetings, as well as the TRC meetings, concerns
were raised regarding containing the waste on-site. It is the
community's preference to have all of the 45-acre landfill excavated
and taken away. It is their belief that as long as the source
of contamination remains, the Township could be adversely affected.
It has been requested by the community that EPA perform a research
and development investigation at the site to evaluate innovative
decontamination techniques.
Attachment 5 is a responsiveness summary which summarizes the
comments on the feasibility study, the public meetings, the
meetings with the TRC, and comments from the Generators Steering
Committee.
Consistent withi__0t.her Environmental Laws
The selected remedial alternative complies with all substantive
requirements of RCRA, the Clean Water Act, and the Clean Air Act.
Recommended Alternative
According to 40 CFR part 300.68 (j), cost-effectiveness is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and mini-
mizes damage to and provides adequate protection of public health,
welfare, and the environment. Nine alternatives were evaluated.
The no action alternative was found to provide inadequate protec-
tion of public health and the environment. Surface capping with no
containment was also found to provide an inadequate level of protec-
tion because of the continuing potential for groundwater contamin-
ation. This potential results from the existence of a shallow
surficial groundwater aquifer and evidence that wastes were buried
beneath the water table. Moreover, rupturing drums are likely to
release liquids in the future which would migrate into the ground-
water. This risk is enhanced by sampling results which show the
presence of solvents in addition to chlorinated organics, some of
which are suspected carcinogens at very low concentrations in
drinking water, which might otherwise have a tight affinity for
soils. A cap with high rate groundwater interception by pumping
"would be feasible as would containment by a slurry wall. A
shallow slurry wall (30 feet) was found to have the same level
of reliability as a deep slurry wall (140 feet). Site excavation
and flushing alternatives were also considered. Complete excavation
of the 45 acre site with disposal of contaminated waste 'and soil
was found to be impractical and dangerous. Flushing was found
to be not feasible because of potential operational and reliability
problems.
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- 37 -
Table 12 shows the present worth costs for the most feasible
alternatives which include containment by high rate pumping (3);
containment by a shallow slurry wall (4); and shallow slurry wall
containment and limited excavation (9).
The limited excavation alternative has the highest present
worth cost at $37.4 million. Because of the uncontrolled and
random nature of dumping at the site, it is not possible to
assume that the limited excavation will remove even as much as
half of the waste from the site. Therefore, the same capping
and containment measures are necessary as would be required
without the excavation. The extra cost for this alternative and
the additional health and safety risks do not result in additional
reliability in terms of reduced release to the environment.
Containment by high rate pumping has a present worth of $26.1
million and the slurry wall alternative has a present worth of
$17.1 million. The reason for the large difference is associated
with the capital cost and the cost for long-term water treatment
at a pumping rate of 400 gpm versus 30 gpm. However, an important
advantage of the larger pumping rate is that it will also result
in cleanup of some existing groundwater contamination. Preliminary
simulation results from the feasibility study suggest that the
off-site contaminated plume could be recovered at a lower pumping
rate of 200 gpm (if a slurry wall is in place) for a present
worth cost of about $8 million. Thus, even if an off-site ground-
water cleanup program were initiated in the future along with
the shallow slurry wall alternative, the combined present worth
cost ($25.3 million) would be less than the cost for plume inter-
ception at the high pumping rate of 400 gpm. In addition, the
slurry wall will provide more reliable containment and the off-
site plume cleanup could be accomplished in about 20 years.
Because of the uncontained source, high rate pumping is likely
to continue well beyond 20 years. Therefore, capping with a
shallow slurry wall is the cost-effective alternative for this
site.
The recommended alternative (see Figure 8), consists of the
following on-site and off-site activities:
On-site;
o groundwater cut-off wall
On-site containment will be provided through the use of a
'•shallow groundwater cut-off wall penetrating approximately 30
feet through the Vincentown aquifer and keying into the Hornerstown
formation, an aquitard. The wall will ring the landfill's perimeter
for a distance of about 6000 feet, enclosing approximately 45
acres. The groundwater cut-off wall will be installed to achieve
a maximum permeability of 1.0 x 10~^ cm/sec.
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VtHIICM- SCALE
' <*0
1N)f>
EXTRACTION UELL
CONTAINMENT
_. •.'.• • . . •' -.- • • •.•.
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- 38 -
o surface seal
To reduce rainwater infiltration and gas release, the landfill
mound will be covered by a multi-layer surface sealing system as
follows: A 1-foot layer of fill will be used to grade the existing
local fill cover. This layer will be covered with a 1-foot thick
layer of clay (permeability not to exceed 1.0 x 10"^ cm/sec),
a 1-foot thick layer of fine fill and a 6-inch layer of topsoil.
The topsoil will be seeded to stabilize the surface. The cap
will comply with requirements under RCRA.
o internal wellfield
Because the downward flow of contaminants from the Vincentown
aquifer into the Red Bank aquifer must be checked, an internal
pumping system (30 gpm) consisting of a series of six wells, is
included to produce a negative, inward gradient similar to a sump
pump, to relieve the hydraulic escape of contaminants through the
Hornerstown formation, an aquitard. This internal pumping system
will also remove any water that has infiltrated the surface seal
or the groundwater cut-off walls.
o treatment^ system
The contaminated groundwater extracted from the wellfield
inside the groundwater cut-off wall will be treated or pretreated,
as necessary, and tested prior to discharge to the Manasquan or
Metedeconk River or the Ocean County wastewater treatment plant
interceptor. An on-site physical/chemical treatment scheme would
address the contaminated groundwater as it is received rather
than being designed for anticipated contamination levels since
the source strength is unknown and the nature of the contamination
may change over time. The specific treatment system will be
designated upon completion of the ongoing pilot plant and bench
scale treatability studies.
If on-site treatment is selected, the treatment plant effluent
would be discharged to a 1-day storage tank to allow sampling and
testing prior to discharge to the Manasquan or Metedeconk River
in accordance with NJPDES. If the Ocean County wastewater treatment
plant is utilized as the treatment mechanism, it is likely that a
force main will be utilized to convey the waste to the interceptor
located in the vicinity of the site. The ongoing treatability
studies will assure the compatability of the contaminated groundwater
to the proposed treatment system.
o monitoring program
Six nested observation wells, screened above and below the
Hornerstown formation would be used to monitor the effectiveness
of the remedy and to facilitate determination of seasonal
optimum pumping rates at each location.
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- 39 -
o surficial cleanup
A surficial drum and debris cleanup at the adjacent borrow
pit area will be performed during remedial implementation. This
material will be disposed of on the landfill before capping,
since it is believed that these drums are empty.
o site
The existing fencing restricts vehicular and pedestrian traffic
from Burke Road. The entire site will be enclosed to exclude to the
extent possible wildlife, hunters, and dirt bikers.
Off-site;
o lij^ited ground watej: sampling and monitojring program
The need to implement an on-site containment measure to
prevent any future releases of persistent hazardous compounds
from the landfill has been established by evaluating the available
3ata. Because of the questions raised about the contaminant
•low path By recent sampling results at this site, additional
>ff-site groundwater sampling will be performed to better define
;he extent of the contaminant plume emanating from the landfill
.^nd to define the need for off-site plume control.
"ost summary for recommended [remedial Alternative 4
The following table represents a cost estimate for the proposed
emedial actions. Cost sharing for the off-site field investigation
nd design portion is 100% EPA-f inanced . Cost sharing for construc-
.ion is 90% EPA and 10% State. The actual requested amount for
..he off-site field investigation, design, and construction phase
:>f this project is $11.2 million. As a result of consideration of
credit given to the State by EPA, the State's share of the capital
cost is reduced by $33,000.
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- 40 -
Table 14
Selected Remedial Alternative Capital Costs
Activty Costs
Cap and Surface Cleanup ? 5,690,000
Shallow Containment Wall 882,000
Internal Wellfield 210,000
Treatment System* , 921,000
Storage 150,000
Monitoring Program 30,000
Engineering and Contingencies (35%) 2,759,050
Total Capital Cost $10,642,050
(EPA share $9,610,845. state share: $1,031,205)
Preparation of Detailed Design $1,060,000
U.S. Army Corps of Engineers
Service During Design and Construction 532,103
Additional Off-Site Field Investigation 100,000
Total Funds Required $12,334,153
(EPA share: $11,302,948, state share: $1,031,205)
* The actual costs associated with the groundwater treatment facility
will be determined upon completion of the ongoing treatability
studies. The more conservative on-site treatment system was used
for costing purposes.
Operation and Maintenance
o monitoring
As part of the remedial action, a water arid air sampling
program, which is consistant with State permit requirements, is
included to monitor changes in the nature and extent of contamin-
ation at the site to determine the effectiveness of the operation.
The water sampling plan will be modified as necessary upon completion
of the planned hydrogeological investigation.
Groundwater sampling in both the Vincentown and Red Bank
formations will consist of sampling from two pairs of nested
monitoring wells. Surface water samples will be collected at
"two Manasquan River locations. Ground and surface water samples
will be analyzed for priority and non-priority pollutants semi-
annually for the first 2 years and annually, thereafter, if the
rate of contamination decreases. In addition, if an on-site
treatment plant is constructed, as long as the plant is 'in operation,
the plant's effluent would be sampled daily for total organic
carbon and total organic, halides and weekly for volatile organics.
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_ - 41 -
Following the installation of the surface seal, total hydro-
carbons monitoring (and meteorological data collection) would be
repeated for 2 months to test the effectiveness of the surface
seal. Four gas monitoring wells will be installed and sampled
for methane quarterly for the first 5 years, and semi-annually
thereafter, if no methane problems are determined to exist.
Sampling for priority pollutants would be conducted quarterly
for the first 3 years and semi-annually, thereafter, if contaminant
levels are acceptably low.
o operation And maintenance
The remedial measures proposed for the Lone Pine Landfill have
operation and maintenance requirements to protect the integrity of
the remedy.
To maintain a negative internal gradient at the site, a series
of six extraction wells will be required. These will be located
within the boundary of the slurry wall, but outside of the fill
area, and extending an average depth of 30 feet below grade.
These wells will extract approximately 30 gpm. The high natural
iron content in the groundwater may result in fouling of the
groundwater extraction wells and screens by iron-oxidizing bacteria.
A cleanup frequency of once per 6 months and a replacement frequency
of once every 2 years is anticipated to maintain the effectiveness
of the groundwater extraction system.
The 30 gpm of highly contaminated groundwater extracted to
maintain the negative gradient within the landfill will have to
be treated. A treatability study is currently being conducted
to identify feasible on-site treatment methods as well as an
evaluation of discharging the contaminated groundwater to the
Ocean County Utilities Authority (OCUA) wastewater treatment
plant. In either instance, routine operation and maintenance
will be required to maintain the integrity of the remedy. An
on-site system would most likely include a combination of unit
processes, the operation and maintenance of which will be required.
Sludge generated in this treatment process will have to be dealt
with regardless of whether it is hazardous or not. If the OCUA
is utilized to treat the extracted contaminated groundwater, the
force main, as well as the pump station and the associated
appurtenances, will have to be maintained.
The landfill mound will be covered by a multiple-layer, grass-
covered surface system which would also include provisions for
"Srainage swales to transport rainwater away from the landfill.
Repairs of subsidence, erosion, and burrowing by animals, as well
as grass mowing, will be required to maintain the integrity of
the surface sealing system.
The 6000 linear-foot slurry wall encircling the site will
require periodic testing to ensure its structural integrity. A
gas control system consisting of a series of gas monitoring
wells will be provided and will have to be maintained.
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- 42 -
The annual operation and maintenance requirements for the
recommended remedial measure are as follows:
Table 15
Annual Operation and Maintenance Costs
for Selected Remedial Alternative
Item Annual _Cp_st: (20 years)
Internal Wells $3,234
Surface Seal 5,000
Groundwater treatment 228,000*
Storage 750
Subsurface monitoring program 87,850
Total $324,734
* or $196,750 if the OCUA wastewater treatment plant is utilized
It is the Region's recommendation that EPA finance the operation
and maintenance for a period not to exceed one year.
Schedule
Table 16
Remedial Alternative Implementation Schedule
Activity Date
-Complete Enforcement Negotiations September 21, 1984
-Final Record of Decision September 21, 1984
-Amend State Superfund Contract for Design September 28, 1984
-Award IAG for Design September 28, 1984
-Begin Design November 1, 1984
-Complete Design May 1, 1985
-Amend State Superfund Contract June 1, 1985
for Construction
-Award IAG for Construction June 1, 1985
-Begin Construction July 1, 1985"
-Complete Construction July 1, 1987
Future jVctions
o _f_ield_ invest igat ion
Because of the uncertainties regarding the extent of the off-
site contamination developed as a result of the recent round of
monitoring well sampling, additional off-site hydrogeological
investigative work will be necessary. This will include the
placement of four monitoring wells to the north of the Manasquan
River, two monitoring wells south of the river, and the resampling
of selected existing monitoring wells. This work is tentatively
schedueled to begin in late October 1984.
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9/21/P4
ATTACHMENT 5-2
RESPONSIVENESS SUMMARY
SUMMARY OF RESPONSES TO COMMENTS
-------
Attachment 5-2
Responsiveness Summary
Summary of Responses to Comments
Summary _p_f__Public Meeting Comments and Responses
Freehold Township — June 24, 1983
o Concern was expressed about the validity of groundwater model
parameters since the landfill contents are not known. In response,
it was pointed out that complete knowledge of landfill contents
is not necessary to generate valid results from the model.
o An attorney for the generator group stated that his client is
attempting to cooperate with EPA. He questioned EPA about
other major companies that allegedly have not been contacted.
He was informed that EPA is investigating all possible leads
and that if he has some information, EPA would be more than
happy to follow up on it.
o A resident north of the Manasquan River reported that there
are taste and odor problems in his well water. He was promised
that EPA would sample his well.
o It was asked whether or not food chain studies were performed
as part of the feasibility study. Response was no.
o Concern for the Englishtown aquifer was expressed. In response
it was pointed out that there is no hydrologic reason to expect
contamination in Englishtown aquifer from Lone Pine Landfill.
o A question was raised concerning possible contaminated areas in
vicinity of landfill proper. Response was that the EPA was
continuing to test these areas.
o The sentiment expressed was that as long as the source of
contamination remains, the Township could be adversely affected.
Reconsideration of the excavation alterntive was recommended.
In response, it was pointed out that there are not enough
facilities in the U.S. to accept all the excavated hazardous
material from Lone Pine and the other hazardous sites.
Excavation has major technical, environmental, and cost problems
associated with it, as well.
o The question was asked if, costs aside, excavation is technically
feasible. COM reponded that assurances of technical feasibility
are uncertain. '
-------
It was suggested that a combination solution be considered as
a possibility: remove, test and dispose of all the drums that
can feasibly be removed, and apply a containment solution to
the remainder of the drums. In response, it was indicated
that much of the buried material is probably under water,
requiring extensive dewatering and treatment of highly contam-
inated water removed by the dewatering process.
The opinion expressed by the concerned citizens was that as
long as unquantifiable risk exists with leaving the material
in the landfill, the excavation alternative should not be
dismissed. In response, it was stated that further examination
and discussion of this alternative with the Township Technical
Review Committee would occur.
A resident near the Manasquan River expressed concern for the
safety of his private well. The Region committed to testing
his water.
It was asked if the levels of volatile organic compounds that
are being found are toxic to native aquatic life in the area.
In response, it was noted that no specific biotic toxicity
studies have been done.
The point was made that any substance from Lone Pine that
contaminates the proposed Manasquan River reservoir could
affect over 100,000 people. In response, it was indicated
that protecting the public is the intent of EPA's actions at
this site.
In response to a question asked about the pumping rate used in
the report, it was stated that the 200 gpm rate was based on
optimizing the groundwater cones of depression.
Summary of Public Meeting Comments
Responses
Freehold Township, August 1, 1984
In response to EPA's acknowledgement of the need to acquire
additional data relative to the extent of the off-site plume,
a member of the Technical Review Committee said that his
organization and the citizen's advisory committee "are heartened
Ithat] you intend to obtain additional data. The committee
does not object to the proposed action, but we prefer if you
do it in a fashion that does not foreclose other alternatives
in the future. We would support the removal of at least some
toxins from the site. We don't feel your data base supports a
final decision yet."
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o It was recommended that research and development work be
performed at the site. In response, it was indicated that we
would give some thought to this proposal.
o A question was raised about the status of the ongoing leachate
treatability study. In response, it was indicated that a
laboratory trailer has been placed on-site to begin compatability
tests. A preliminary evaluation utilizing a well recently
installed at the toe of the mound has been completed, indicating
leachate compatability with the Ocean County Utilities Authority
(OCUA) wastewater treatment plant. Based upon this preliminary
analysis, it appears that it may be more economical to send
the leachate to the OCUA rather than treating on-site.
o The question was asked whether a liquid discharge outside the
Manasquan basin would impact the reservoir yield. In response,
it was indicated that extracting 30 gpm would have a negligible
impact on the Manasquan basin.
o "Why does EPA not want to address the contaminated sediments in
the Manasquan River?" was asked. In response, it was indicated
that the contamination levels detected in the river adjacent
to the landfill are not high enough to warrant dredging. In
addition, it is unlikely that sediment transport will occur to
pose a threat to the proposed off-line reservoir intake.
o A question was raised regarding the pile of drums and debris
across the road from the landfill. In response, it was pointed
out that removal of the drums and debris in the borrow pit
area across the road is part of the proposed remedial action.
o It was asked whether EPA assessed the contamination of the
Englishtown Sands aquifer below the landfill. In response, it
was indicated that EPA has sampled two existing wells in the
Englishtown and that as part of the additional offsite invest-
gation, EPA will be installing deep monitoring wells screened
in multiple layers down to the bottom of the Red Bank aquifer
to further assess the extent of the contamination. If nothing
is found in the lower Red Bank it is likely that the Englishtown
is also clean.
o Because of variability in the sampling data from the site,
questions were raised regarding the laboratory measurement
errors in assessing the degree of contamination. In response,
it was pointed out that small changes in the numbers are
insignificant. Only the order-of-magnitude variations in the
data, such as those found at EPA well No. 3A, have significance
in evaluating the contaminant flux at this site. Nevertheless,
the data have been verified and validated by EPA using strict
quality assurance/quality control procedures and EPA is
confident that these data are beyond reproach.
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o It was asked why the excavation costs were estimated to the
nearest $5 if there are so many uncertainties associated with
this remedial alternative. In response, it was indicated that
the costs were calculated based upon assumptions using the
limited available data. There are clearly errors in the
calculations.
o An attorney for the generators indicated that based upon their
analysis of the available records and the estimated lifespan
of drums, the drummed waste does not pose a significant threat
to the environment. It was further indicated that the generators
feel that a cap and a comprehensive monitoring program with
trigger mechanisms to activate new phases before the site
threatens the public should be implemented as a remedial
measure at this site. NJDEP responsded that a cap alone is
not acceptable. NJDEP added that the plume must also be
addressed. The attorney added that the community is also
liable for paying a share of the remedial costs since they
also utilized the landfill.
o It was asked whether there are any chemical residues in the
flora in the area. The response was that there have not been
any studies in this regard.
o It was asked why plume control is under discussion between EPA
and NJDEP. In response it was indicated that there is a
problem in defining the extent of the plume. Additional
investigation is necessary in light of the most recent round
of well sampling.
o The question was asked of the generators why they were offering
to do work at the site at their own expense. They responded
that everyone who sent waste to the landfill is liable and that
their companies chose not to "hide in the bushes" but to make
a good faith effort to address the problems here.
FreeholdTownship Technical Review
Committee Comments and Responses
May 4,_ 1983
o A question was asked regarding the extent of the available air
data. Concern was expressed about what was happening to the
volatile organics. Response was that at that time EPA had
little air data and additional investigation was planned.
o It was suggested that holes be bored or acid be injected into
the mound to accelerate the degradation of the drums, to
encourage the purging of the contamination during the_pumping
and treatment activitis. In response it was indicated that
if the site was contained the condition of the drums was not
important.
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Sentiments were expressed towards excavating the drums from
the landfill. In response, it was indicated that drum excavation
was being evaluated in the draft Feasibility Study.
Response to July 13, 1983
Technical Review Committee Meeting
Comments
1. Analysis of the groundwater hydrology in the vicinity of Lone
Pine indicates that contamination migrates and discharges to
the Manasquan River rather than migrating vertically downwards
into the Englishtown aquifer.
2. Unit processes, each addressing specific contaminant classes,
will be utilized to treat the extracted groundwater. Bench
scale and pilot scale treatability studies, which will commence
shortly, will establish specific design criteria for the
selected treatment system. Monitoring of the effluent will
indicate the effectiveness of the treatment scheme.
3. As part of the Lone Pine Landfill Feasibility Study, EPA
investigated two adjacent potential sites, the Solico site
and the borrow pit, which were alluded to.
The Solico site, which was used as a waste lagooning area, was
excavated in the late 1970's in response to a New Jersey
Department of Environmental Protection (NJDEP) Administrative
Order. Both the local health officer and the NJDEP requested
that EPA investigate this area. Subsequently, a monitoring
well network was installed to determine the presence of
contaminants in the area. Test results of the wells found
the Solico area to be relatively clean, with no significant
levels of contaminants detected.
In regard to the borrow pit, it has been suggested that this
area, where several dozen rusted drums were scattered over
the surface, was used for drum disposal. However, based upon
the testimony of the landfill's general manager and a bulldozer
operator, extensive drum disposal occurred only at the landfill,
This is further supported by the fact that the high water
table beneath the borrow pit would make subsurface drum
disposal extremely difficult. It is also unlikely that
disposal took place here since an active landfill was available
across the road. We did, however, install a monitoring well
downgradient of this area which confirmed the absence of
contamination here. A surficial drum cleanup will be performed
at the borrow pit when a long-term remedial solution-is
implemented at the landfill.
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4. Containment walls have history going back as far as the
1940's, primarily in conjunction with large dam projects.
Slurry wall compatability/constuctability tests will be
performed during the remedial design phase to determine the
optimum material composition. In cases where the permeability
of the containment wall is found to increase in the presence
of hazardous waste, an admixture of certain polymers have
been successful in the past in preventing the breakdown of
the retaining properties of the wall.
5. The Region has identified several parties to which various
quantities of the contents of the landfill can be attributed.
Little is known of the composition of the bulk and drummed
chemical wastes disposed of here. The Region's drum excavation
at this site in 1981 uncovered 69 drums. The contents of
these drums were useful in helping to develop a treatment scheme
for the Lone Pine Landfill.
6. The planned limited air quality monitoring program is intended
to provide an intensive short-term survey of air contaminants
emanating from the site. Air samples will be collected to
provide 8-hour, time-weighed average values for priority
pollutants. Local meteorological conditions will assist in
the evaluation of the site's overall air quality conditions.
7. As was indicated in the draft Feasibility Study, although
removing the drums would potentially remove a major source of
contamination from the landfill, drum excavation will not
address the millions of gallons of materials that has leaked
from the deteriorating drums. The EPA's drum excavation
activities at Lone Pine in 1981 uncovered numerous drums that
were no longer intact. Since all of these excavated drums
were near the surface and above water in the landfill, it
is reasonable to assume that the remaining 17,000-50,000
drums, which may be underwater and subjected to considerable
compressive pressures, are in far worse condition.
Excavation of the drums could potentially allow the release
of high levels of hazardous substances to the atmosphere,
cause chemical fires, and/or explosions.
The state-of-the-art technology is such that after excavation,
we would not be completely certain that all the drums had
been located and removed.
Excavation of drums below any encountered water will require
extensive dewatering and treatment of highly contaminated
water removed by the dewatering process.
1. A press release, indicating the availability of the draft Lone
Pine Landfill Feasibility Study at three local repositories,
immediately preceded the release of this document. In keeping
with the Agency's current policy, three weeks were allowed for
the public to review and comment on the study.
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2. Unit processes, each addressing specific contaminant classes
will be utilized to treat the extracted groundwater. A bench
scale and pilot scale treatability study, will establish
specific design criteria for the selected treatment system.
Treated water would be analyzed daily for total organic carbon
and total organic halides and weekly for total volatile organics
to verify that the treatment system is working properly.
The proposed treatment system will be designed to handle a wide
range of varying conditions, however, if some type of "extremely
toxic chemical" suddenly appears, and the treatment system is
unable to properly remove it, then the effluent would be temporarily
retained while the system is modified, as necessary, to address
the new contaminant. Regardless, any discharge would have to
meet the State's discharge permit requirements.
3. The pumping and treatment schemes were modeled assuming a
continuous strength, worst-case contaminant source during the
life of the program. If anything, the system is over designed.
Placing a cap over the landfill will reduce infiltration which
may inhibit the deterioration of the drums and reduce the
quantity of contaminants, being released from surface seeps
and to the aquifers, however, as long as the landfill is
contained, the degree of drum deterioration is irrelevant.
4. The EPA's drum excavation activities at Lone Pine in 1981 un-
covered numerous drums that were no longer intact. Since all
of these excavated drums were near the surface and above the
water in the landfill, it is reasonable to assume the remaining
drums which may be under water and subject to considerable
compressive pressures, are in far worse condition.
In regard to the markings on some of the drums, we have used thir
information to seek out potentially responsible parties. Since
it is possible that the drums could have been used more than
once before ultimately being disposed of in the landfill and
because of the illegal nature of the drum disposal activities
here, it would prove very difficult to determine what was actually
disposed of and by whom by tracing the markings on the drums.
5. The feasibility study evaluated the feasibility of various
alternatives that may be applicable to the particular contami-
nation problem at this site. We know enough about the problem
at this site to lay out and develop reasonable remedial solutions.
More data, however, will have to be collected to adequately
design and implement the selected remedial alternative.
Specifically, a leachate treatability study will be undertaken
and a slurry wall constructability/compatability test_will be
performed.
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6. During short-duration, high intensity rainfall events, there is
considerable runnoff and leachate breakouts at the site, potentially,
allowing a signficant discharge of contamination to the Manasquan
River. It would be expected that once the storm event has ended
the condition of the landfill would more or less return to its
pre-storm "steady-state" conditions. Capping the landfill, as
proposed in the alternatives evaluated in the draft Feasibility
Study, would reduce the infiltration and its associated leachate
breakout problems.
7. Although removing the drums would potentially remove a major
source of contamination from the landfill, drum excavation will
not address the millions of gallons of bulk liquid wastes disposed
of there, as well as the materials that has leaked from the
deterioriating drums. The EPA's drum excavation activities at
Lone Pine in 1981 uncovered numerous drums that were no longer
intact. Since all of these excavated drums were near the surface
and above the water in the landfill, it is reasonable to assume
that the remaining 17,000-50,000 drums which maybe under water
and subject to considerable compressive pressures, are in far
worse condition.
Excavation of the drums could potentially allow the release of
high levels of hazardous substances to the atmosphere, cause
chemical fires, and/or explosions.
The state-of-the-art technology is such that after excavation,
we would not be completely certain that all the drums had been
located and removed.
Excavation of drums below any encountered water will require
extensive dewatering and treatment of highly contaminated water
removed by the dewatering process.
8. The study assumes that the public would react adversely to drum
excavation because excavation could change the situation from one
that does not currently theaten the public to one that could cause
releases of high levels of hazardous substances, cause chemical
fires, and/or explosions. The potential long-term benefits are
dwarfed by the potential short-term threats and impacts.
9. Assuming that the drums could be excavated, the volume of material
that would have to be removed from the landfill would translate
into perhaps 20 daily truck trips over a period of a year or
more. This much traffic, despite stringent safety procedures,
would greatly increase the odds of traffic accidents and the
resultant exposure of the public to hazardous substances.
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10. As part of the Lone Pine Landfill Feasibility Study, EPA
investigated the two sites, the Soilco site and the borrow
pit. The Soilco site, which was used as a waste lagooning
area, was excavated in the late 1970's in response to a New
Jersey Department of Environmental Protection (NJDEP) Admin-
istrative Order, in order to determine the potential of
contamination from this source, we installed a monitoring well
network in the area which showed no significant quantities of
contamination.
In regard to the borrow pit, it has been suggested that this
area, where several dozen rusted drums were scattered over the
surface, was used for drum disposal. However, based upon the
testimony of the landfill's general manager and a bulldozer
operator, extensive drum disposal occurred only at the landfill.
This is further supported by the fact that the high water
table beneath the borrow pit would make subsurface drum disposal
extremely difficult. It is also unlikely that disposal took
place here since an active landfill was available across the
road. We installed a monitoring well downgradient of this
area which confirmed the absence of contamination here.
A surficial drum cleanup will be performed at the borrow pit
when we implement a long-term remedial solution at the landfill.
11. If the drums disposed of at the landfill were largely intact and
easily accessible, and if there were no bulk liquid waste disposal
at this site, then incineration could very well be a viable
approach.
Technical Review Committee Meeting
Comments and Responses"
Freehold Township October 31, 1983
It was requested that EPA consider a limited excavation/incineration
proposal developed by Energy Incorporated. Response was that EPA
would evaluate the proposal.
Technical Review Committee Meeting
Comments and Responses
Freehold Township on July 10, 1984
o A request for a time range of concentrations per well to show
how contamination has varied through time was made. COM will
provide a computer listing of the requested data.
o The presence of heavy metals in upgradient wells was questioned.
In response, it was pointed out that many of the metals in
question are naturally occurring in high concentrations in
this area. The other metals can be attributed to leaching
from the stainless steel screens and galvanized risers.
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o Because monitoring well CDM-4A has shown contamination in the
most recent sampling round, the adequacy of the groundwater
model was questioned. In response, it was indicated that
additional field monitoring was planned to better define the
off-site contamination problem.
o The long-term integrity of the containment system was questioned!.
It was indicated that operation and maintenance of the system
is required as it is necessary to maintain our bridges and
highways. In addition, it was pointed out that replacement costs
for the slurry wall are included in the cost estimate.
o A question was raised regarding the relationship between the
level of contamination found in the plume and the proposed
containment scheme. It was indicated in response, that source
control is independent of and not influenced by the level of
off-site contamination.
o It was asked whether or not a slurry wall would work. It was
indicated, in response, that the U.S. Army Corps of Engineers
has had considerable experience with slurry walls.
o The integrity of the Englishtown aquifer was questioned. In
response, it was indicated that EPA tested two existing wells
screened in the Englishtown aquifer and found them to be
clean. The planned additional monitoring north of the Manasquan
River will further ascertain the integrity of the Englishtown
aquifer.
o The question was raised as to why incineration was not evaluated.
In response, it was indicated that since limited excavation
must precede ultimate disposal, and since excavation was ruled
out for this site, considering incineration was a moot point.
o It was asked whether a phased approach towards containment
could be employed — delay the cap until groundwater had been
extracted for a while. Response was that this proposal would
be considered.
Response Technical Review Committee Comments
August 17, 1984
EPA is discussing with EPA's Municipal Environmental Research
Laboratory the prospect of performing R & D at the site to evaluate
innovative decontamination techniques.
Response to Monmouth County
Board of Health Comments
June 20, 1983
I. Scope of Study
As part of the Lone Pine Landfill Feasibility Study, EPA investigate
the two adjacent potential sites, the Soilco site and the borrow
pit, which were alluded to.
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he Soilco site, which was used as a waste lagooning area/ was
excavated in the late 1970's in response to a New Jersey Department
of Enivronmental Protection (NJDEP) Administrative Order. Both
the local health officer and the NJDEP requested that the EPA
investigate this area. Subsequently, a monitoring well network
was installed to determine the presence of contamination in the
area. Test results of these wells found the Soilco area to be
relatively clean with no significant levels of contaminants
detected.
In regard to the borrow pit, is has been suggested that this
area, where several dozen rusted drums were scattered over the
surface, was used for drum disposal. However, based upon the
testimony of the landfill's general manager and a bulldozer
operator, extensive drum disposal occurred only at the landfill.
This is further supported by the fact that the high water table
beneath the borrow pit would make subsurface drum disposal extremely
difficult. It is also unlikely that disposal took place here
since an active landfill was available across the road. We did,
however, install a monitoring well downgradient of this area
which confirmed the absence of contamination here.
A surficial drum cleanup will be performed at the borrow pit when
we implement a long-term remedial solution at the landfill.
Groundwater Contaminaton Assessment
Analysis of the groundwater hydrology in the vicinity of Lone
Pine indicates that contamination migrates and discharges to the
Manasquan River rather than migrating vertically down into the
Englishtown aquifer.
EPA sampled two existing wells in the Englishtown Sands aquifer
confirming that no contamination has migrated from the Red Bank
aquifer to the Englishtown Sands. Additional monitoring is planned.
III. Air Quality Monitoring at the Landfill
Air quality monitoring to date, albeit limited in scope, does not
indicate severe releases of volatile organics at this time.
A time-weighted continuous air monitoring program was conducted
to identify the constituents and concentrations of emissions from
the site. Meteorologic data was also collected in order to allow
prediction of the fate of these emissions in the environment.
IV. Identification of Contaminants
Although removing the drums would potentially remove a major
puree of contamination from the landfill, drum excavation will
t address the million of gallons of bulk liquid wastes disposed
, as well as the material that has leaked from the deteriorating
drums. The EPA's drum excavation activities at Lone Pine in 1981
-------
uncovered numerous drums that were no longer intact. Since all
of these excavated drums were near the surface and above water in
the landfill, it is reasonable to assume that remaining 17,000-50,000
drums which maybe under water and subject to considerable compressive
pressures, are in far worse condition.
Excavation of the drums could potentially allow the release of
high levels of hazardous substances to the atmosphere cause
chemical fires, and/or explosions.
The state-of the-art technology is such that after excavation, we
would not be completely certain that all the drums been located
and removed.
Excavation of drums below any encountered water will require extensive
dewatering and treatment of highly contaminated water removed by
the dewatering process.
Analysis for dioxin (TCDD) was included in the 1981 sampling of
excavated drums, the 1982 and 1983 sampling of monitoring wells,
and the 1983 sampling of stream bottom sediments. In all cases
the chemical was not detected.
Analytical results from the April 1983 sampling of river sediments
found no organic priority pollutants at Burke Road. Inorganic
compounds were not present in high concentrations except for iron
and aluminum which are known to be ubiquitous in the environment.
A tributary from the landfill and a point in the river approximately
700 feet downstream from the westernmost tributary from the landfill
are contaminated with several organic priority and non-priority
pollutants.
V. Contaminant Transport in Ambient Environment and Computer
Modeling
Volatile organics were modeled because they are the dominant
class of priority pollutants presently released from the landfill
and thus represent the best body of data to use for the model.
Other classes, such as heavy metals, are not at this time present
in severe concentrations. However, the report recognizes that
this could change in the future.
VI. On-Site Waste Treatment System Proposed
Treated water would not be routinely analyzed for priority pollutants
as this would be prohibitively expensive. Instead, it is proposed
that treated water would be analyzed daily for total organic
carbon and total organic halides and weekly for total volatile
organics to verify that the treatment system is working properly.
Other discharge criteria such as heavy metals would also be
specified in the discharge permit issued by NJDEP.
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Air contaminants released during treatment, such as from an air
stripping process, would be controlled as necessary to meet NJDEP
air pollutant emission standards.
VII. Slurry Wall Construction/Life
Slurry wall deterioration has been accounted for by providing for
replacement of the wall. In actual practice, the groundwater
monitoring system would allow monitoring slurry wall effectiveness.
As a result, the actual slurry wall replacement schedule could be
determined by the monitoring data.
VIII. Operations Not Studied
1. Discharge to a wastewater treatment plant is an option that
is specifically being studied during the ongoing treatability
studies.
2. If the drums disposed of at Lone Pine Landfill were largely
intact and easily accessible, and if there were no bulk liquid
waste disposal at this site, then incineration could very well
be a viable approach. However, based upon data and information
available, the potential long-term benefits of drum excavation
are dwarfed by the potential short-term threats and impacts,
and the associated technical and safety problems.
Response to Energy Incorporated's Proposal
October, 1983
There are allegations that 17,000 to 50,000 drums of hazardous
waste have been disposed of at the Lone Pine site. EPA's invest-
igation has documented that at least 17,000 drums and 2.5 million
gallons of bulk liquid waste have, in fact, been dumped at the
landfill. If, hypothetically, 17,000 drums were all filled with
liquid, they would have contained a total of 0.935 million gallons
at the time of disposal. If, on the other hand, there were
50,000 drums buried, and all were filled with liquid they would
have contained 2.75 million gallons. Thus, hypothetically, the
landfill would have received a total of 3.435 to 5.25 million
gallons of liquid waste.
It is important to note that the extreme conditions in the landfill
make it highly unlikely that all of the drums are now intact. It
is more probable that substantial amounts of any liquid "materials
disposed of have escaped their drummed containers and dispered
within the landfill. Thus, excavation of the drums and the
adjacent soil and waste material will not necessarily remove the
bulk of liquid which they may have contained at the time of
disposal.
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In its proposal, Energy Incorporated assumed that 50,000 drums
were deposited in the landfill. The firm believes that it- would
be able to remove and destroy about 1.37 million gallons of the
drummed waste. Considering the bulk liquid waste which may not
be affected by the excavation program, it is possible that a
considerable portion of the hazardous waste dumped in the landfill
would not be removed. (Assuming that most of the bulk and drummed
waste is still in the landfill, removing 1.37 million gallons of
waste would be equivalent to only 26% of the 5.25 million gallons.)
If the landfill received more than the 2.5 million gallons of
bulk liquid (which we believe did occur) or less than the 50,000
drums, the Eneregy Incorporated proposal could result in the
removal of substantially less hazardous waste.
In developing its proposal, Energy Incorporated made certain
debatable assumptions regarding the location and recoverability
of the drums buried at the landfill. The assumption that 50 to
83 percent of the drums fall within the high density anomalies
identified in the metal detection study that we performed in 1981,
and that only 10 to 20 percent of the unruptured drums will
rupture during recovery operations, would not be verifiable until
after the excavation had been completed. The validity of these
assumptions would, thus, significally influence the accuracy of
the estimated hazardous waste recovery, as well.
In addition, the costs associated with any required dewatering of
the landfill to allow the performance of the excavation activities
and the associated incremental costs of treating this highly .
contaminated water were not considered is this proposal.
>\s was indicated in the draft Feasibility Study, excavation of
che drums at the site could potentially allow the release of high
levels of hazardous substances to the atmosphere, and cause chemical
fires, and/or explosions. Other risks include contaminated surface
runoff during the excavation activities as well as the potential
release of volatilized heavy metal and particulate matter to the
atmosphere during incineration.
»
One additional point worth nothing is that the Energy Incorporated
proposal includes incineration of excavated materials on the site
as opposed to some off-site facility* The acquisition of the
necessary state and federal permits to incinerate hazardous waste
in this community would be no easy task.
Based upon the data and information currently available, EPA
believes that the potential long-term benefits of drums removal
are dwarfed by the potential short-term threats and impacts, and
the associated technical and safety problems. In general, the
Energy Incorporated proposal does not offer significant advantages
over the containment options evaluated in the draft Feasibility
Study. The most significant drawback of this proposal is that
it leaves the majority of the contamination in the landf-ill.
Furthermore, the Energy Incorporated proposal increases the
overall remedial implementation costs without significantly reducing
the long-term source control maintenance pumping requirements.
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Response to Report to Howell Township
on Remediation at the Lone Pine Landfill
February, 1984
p.1. Volatile organics were selected for modeling at this site because
they are currently detected in the monitoring wells and the river;
pesticides have not been detected. Modeling volatile organics
is a best-quess approximation of the hydrogeological and contaminant
transport at this site.
p.2. The substantial benefits associated with removing the source of
contamination by excavation are overshadowed by the technical and
safety problems associated with this option. Containment of the
site will prevent the release of contaminants to the environment.
p.5 The details regarding the monitoring of the site after the
implemanation of a remedial solution will be finalized during the
project's design phase.
p.31 Heptachlor was detected in five of the excavated drums, three of
which also contained aldrin. It should be noted that four of
these drums were found in one of the eight excavated pits and the
other drum was found in an adjacent pit. Extrapolating these
findings to 50,000 drums (the presence of only 17,000 drums have
been confirmed) is not a statistically accurate representation.
p.32 Aldrin and heptachlar are not water soluble and, therefore, would
not be as mobile through the aquifers into the river as the report
claims. Reducing the water flow through the landfill by capping,
and the pumping and slurry wall would prevent any pesticide
release to the environment.
p.41 Based upon the EPA's drum excavation activities at Lone Pine, the
vast majority of the drums disposed of at this site are probably
no longer intact. If the site is contained, however, the quantity
of waste remaining in the landfill is irrelevant. In addition,
containing the landfill and drawing down the internal hydraulic
head may decrease the exposure of water to the contents of the
drums, reducing the waste's mobility.
p.47 Removing the drums and associated contaminated fill material is
not only expensive, but poses many safety and technical problems
which make it infeasible. While important, cost is not the only
factor responsible for the rejection of this alternative. The
§22-$50 million figure is broken down to $16-38 million for
excavation of drums and associated contaminated fill material and
$6 -12 million for transportation to a secure landfill in
Niagara Falls. The cost of the actual drum removal is $350-500/drum,
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The Department of Environmental Protection has completed its review of
the Report to Hovell Township on Remediation at the Lone Ping Landfill
as prepared by Frank Sciemammano of F-E-S Associates. " ~~
Page 10 The "magnetic survey indicated up to 50,000 55-gallon drums may be
buried in the landfill". This was not substantiated by the excavation
program conducted by EPA's Field Investigation Team. Drums were found
in less than half of the testpits conducted at areas of significant
shallow anomlies.
p»8« 18 A. There is a misunderstanding of NJDEP guidelines established for
recommendation of closure of a drinking water well. The use of the "SO
ppb Individual" guideline is only to be used in evaluation of potable
water well and not for on-site monitoring wells. The wells referred to
are not potable wells.
Page 19 Any effluent discharge to Manasquan River will be required to
comply with all NJDEP water quality guidelines including pesticides.
NJDEP must license any treatment facility and this facility must meet
all applicable criteria.
Page 22 Selection of the remedial alternative is based on both cost
effectiveness and soundness of environmental applicability. The
resultant treatment system is designed or will be designed to treat and
handle the suspected range of influent concentrations.
Page 26 High nutrient concentrations cannot be considered indicative of
landfill contamination. Nutrient input from the marsh area adjacent to
the stream may be responsible for a significant percentage of the
apparent nutrient load. Durand and Zimmer, 1982 indicated that in the
coastal plain of New Jersey, surface water is almost exclusively derived
from groundwater input through swamps and marshes. Also, the nutrient
input and exchange in swamps is evident due to the relatively high
productivity in the marsh areas.
Page 27 It is true Versar showed a large reach of the Manasquan River
downstream of Lone Pine Landfill is devoid of aquatic life. However,
the postulation that the depauperate macroinvertebrate community in the
Upper Manasquan may be due to loading effects of the stream by Lone Pine
is unfounded based on the data.
A. Versar did not evaluate macroinvertebrate communities upstream
of impacts of Lone Pine Landfill for subsequent comparison with
downstream samples.
B. Error in sampling was very evident. A total of four square
feet of sediments were sampled over a large area of the river. Sampling
of benthic invertebrates is frought with wide variations due to
selection of sampling location, size of sample, variation of population
distribution (aggregates), spatial area coverage, etc.
C. Versar's evaluation of chemical and biological data indicate
"a small river with good water quality characteristics except for pH
being below 7.0 to 8.0 range and the slight presence for Iron as a
precipitate on the surface substances". This condition is a
characteristic of coastal plain streams and rivers.
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0. Versar did not evaluate: (1) submerged aquatic vegetation,
(2) emergent aquatic vegetation, and (3) benthic macro and microphytes.
The presence of these organisms in the environment are indicative of
certain environmental conditions.
E. Versar concluded that "the presence of iron and the lack of
suitable substrate for benthic macroinvertebrates probably results in
limiting the aquatic community more than any other existing factor".
The presence or absence of macroinvertebrate communities in the
Upper Manasquan River should not be used as a strong indicator of
detrimental effects caused by Lone Pine Landfill. Streams in general
tend to exhibit longitudinal biological zonation of both pelagic and
benthic species. Changes and, therefore, Instability of the stream
community are more pronounced at the headwaters of the stream than at
the lower parts due to changes in volume of flow and rapid water
chemistry changes. Therefore, species, density and diversity would be
low due to naturally occurring stressful conditions.
Current is the major limiting factor in determining spatial
distribution of pelagic and benthic fauna in streams. Most benthic
invertebrates show very specialized adaptation for maintaining spatial
orientation in stream environments such as clinging, suckers, permanent
attachment, threads, sticky body parts, burrowing, limited swimming
ability. These adaptations appear to be designed for maintaining
postion and not for upstream migration. Consequently, upstream
migration of benthic macroinvertebrates would be minimal in streams with
higher current velocity (which is typical of headwaters of streams and
rivers). The major pathways for upstream colonization In streams where
current is the limiting factor, appear to be migration through very low
water conditions or through "sweepstakes dispersal".
As pointed out by Versar, substrate appears to be limiting in the
Upper Manasquan. This, secondarily, when coupled with current velocity
may be responsible for the absence of benthic macroinvertebrates. No
upstream data is available in the Versar Report to substantiate this
hypothesis; however, sand and silt appear to be the most dominante
sediment type in the upper reaches of the Manasquan.
Sand and silt is the least favorable of conditions for
macroinvertebrate colonization and usually exhibit the lowest number of
individuals and lowest species diversity found in stream communities.
Epipssamon and endipssanon have highly specialized adaptations for
populating sand and silt environments. Current velocity, however, would
severely limit distribution of these organisms. This would appear to be
the case with the headwaters of the Manasquan River adjacent to Lone
Pine Landfill.
Page 30 All contaminants have been evaluated by the C.D.M. Feasibility
Study and the design of the treatment system indicates this. The F.E.S.
report emphatically states that "substances other than volitlle organlcs
have been ignored." This is incorrect.
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Page 31 The Importance of Che pesticides aldrin and heptachlor as possible
contaminants of the Manasquan River are grossly over estimated in this
report.
1. It is assumed that all of the pesticides believed to be in the
landfill will eventually enter the river. However, one cannot assume
that cyclodlene insecticides have a similar mobility to volatile
organics. In fact they do not. Cyclodlene insecticides (aldrin,
dieldrin, heptachlor, heptachlor epoxide) have been classified as having
Class I mobility, Indicating these compounds are considered immobile in
soils. This includes the slightly more soluble epoxides of aldrin and
heptachlor (dieldrin, heptachlor epoxide) (Helling et. al 1971)
Cyclodienes are relatively insoluable in water (heptachlor 50 ppb,
aldrin 27 ppb, dieldrin 190 ppb) which would cause a great decrease in
their surface water transport. Any aldrin or heptachlor that managed to
enter the Manasquan would quickly partition out Into bottom and
suspended stream sediments. It is not likely that such pesticides would
be transported very far downstream. These compounds are very resistant
to degradation with soil halflives of 1-10 years (Menzie 1972). This
halfllfe is greatly reduced in anaerobic systems; however, Llchtenstein
(1977) showed a reduction of dieldrin concentration to 6.5Z of the
original concentration In 28 days under anaerobic conditions.
32 The "... contents of 50,000 drums contained in the
entire landfill." This statement implies that it is confirmed that
50,000 drums are buried in the landfill. No definitive evidence exists
as to the number of drums or their contents.
35 Slurry wall technology is a well-developed technology
and has been proven to be successful at a number of hazardous waste
sites. Various literature and documentation exist on this subject that
are available for research.
36 The conclusions reached concerning pesticide removal are unfounded.
Pesticides are easily treated and removed by conventional treatment
technology and will be removed by the treatment system designed for site
remediation.
38 Dr. Pinder, Consulting Hydrolog1st and Chairman of the Department
of Civil Engineering, Princeton University, has been requested by NJDEP
to review and evaluate the model designed by COM for Lone Pine Landfill.
41 The preparation of this report preceded the current round and
proposed round of sampling of both groundwater wells and surface waters.
These results will be used to validate the groundwater model results.
I 46 Any discharge from a treatment plant on the site will be licensed
. and regulated by NJPDES regulations.
Page 57 Air emissions from any treatment process are regulated by NJDEP-Air
Pollution and will be treated to adequate levels.
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The New Jersey Department of Environmental protection
June 28, 1983
All of the NJDEP comments have been addressed in the reports or
through discussions among the specialists involved.
Several comments pertain to treatment parameters and objectives.
Resolution of these concerns will be addressed during the treatability
studies and conceptual design.
Re spon se to _u_._s. Army Corps of
Engineers Comments May 23, 1983
All of the U.S. Army Corps of Engineers (COE) comments have been
addressed through discussions among the specialists involved.
The COE's primary concern was that there is insufficient data
available to establish design criteria for the development of
plans and specifications for remedial design. COM acknowledges
in the feasibility study that additional investigatory work is
necessary for purposes of design, recommending several activities
to supplement the existing data and information. Air quality
sampling, a leachate treatability study, a groundwater cut-off
wall constructability/compatability tests will have to be performed
and exploratory soil borings will be required along the planned
perimeter of the groungwater cut-off wall.
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COWENTS ON BEHALF OF A GROUP OF COMPANIES THAT SENT VftSTES TO
PINE june 29, 1983
I. Existing Data Fail to Show a Substantial Threat to Public Health
or the Environment from the Site
I.A. Existing Drinking Water Supplies
I.B. Future Drinking Water Reservoir
These two sections basically present statements and references from
the report. Since they do not specifically contest technical mate-
rial In the report, no response 1s deemed necessary.
I.C. Environmental Impacts
Over ten years of adverse effect on the environment in the vicinity
of Lone Pine from the landfill has been documented (see e.g., EID
(Vol. 3), pp. 28-38). That natural acidity and stream bottom con-
ditions Influence the natural aquatic habitat in the area does not
Invalidate the statement In the EID that reduction of priority and
nonpriority pollutant releases from the landfill into adjoining sur-
face and groundwater will allow "gradual restoration of the wetland
areas and biological communities normallyfound in the headwaters of
the Manasquan River* (emphasis added).
Furthermore, it must be appreciated that hazardous substances other
than volatile organics are present 1n the landfill and that evidence
exists of ongoing release of these substances Into the ground and
surface water (i.e., analytical data shows highly contaminated
groundwater and sediments in the tributaries that carry surface run-
off from the site.)
It is certainly consistent with the objective to protect the environ-
ment to develop and carry out a remedial plan to prevent these
releases before they occur and do harm to the environment.
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II. The Existence of Unknown Wastes at the Site Does Not Alone Pro-
vide a Sufficient Rationale for Immediate Implementation of a
Major Remedial Action
This comment appears to recommend the No Action alternative with a
monitoring program, Alternative 1. This alternative was given full
and equal consideration 1n the report. It was clearly recognized In
the report (Vol. 1. p. 189) that under certain conditions the alter-
native could be found acceptable.
It Is not the unknown wastes alone that constitute the Impetus for
remedial action at the site. There are known wastes deposited at the
i
site that are now being released to the environment. The combination
of present contaminant releases and potential for continued releases
provide the rationale for Implementation of remedial measures.
III. The Remedial Feasibility Report Is Inconsistent with CERCLA and
the NCP by Its Failure to Examine the Full Range of Alterna-
tives
A number of comments 1n this section merit discussion. The statement
that the "risk Is Indistinguishable from the risk presented by any
Inactive landfill in the United States" does not stand up in the face
of evidence that hazardous substances were disposed of at the site
and are now emanating from the site Into the environment. This fact
clearly distinguishes the Lone Pine Landfill site from most inactive
landfills.
The early warning concept (a feature of Alternative 1) was not eli-
minated, as claimed in the comment. On the contrary, Alternative 1
was carried through to the final evaluation step. (A full range of
alternatives was developed and subjected to an Initial screening
process, from which five alternatives were selected for further
evaluation.) The final step rated this alternative against the other
four remaining alternatives In terms of cost and five non-cost evalu-
ation criteria (further subdivided into 16 sub-criteria). This rela-
tive rating system gave a ranking for the alternative which, per se,
did not "eliminate" the alternative but presented its advantages and
disadvantages.
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The remedial response criteria used in the feasibility study were
developed by USEPA and NJDEP (Vol. 1, p. 9) and were approved for use
as an evaluation tool for comparison of remedial action alternatives.
IV. The Remedial Feasibility Report Is Inaccurate and Incomplete
IV.A. The Modeled VOC Levels
The significance of the 1000 ppb VOC level has been misunderstood.
1000 ppb YOC is a calculation based on a model-derived pollutant mass
release and an estimated average stream base flow of 2 cfs. The
number should not be compared with discrete sampling events. Results
from sampling events can vary as a function of recent rainfall, sur-
face runoff, winds, etc. The importance of the model-derived Burke
Road concentrations (Vol. 1, Fig. 4-32) is in the relative differ-
ences shown among the alternatives.
IV.B. Cost Calculations
The bases for costs are given on pages 10-11 and 123-129, Vol. 1.
Furthermore, O&M costs do Include replacement of the slurry wall
(p. 11, Vol. 1) and care of the cap over the 50-year project life
cycle (Table 5-3, Vol. 1).
IV.C. Off-Site Remedies
Land application is discussed on pages 116-117, 121-122 and 187, Vol.
1. Land north of the river 1s unacceptable for application of ef-
fluent because such application would spread contaminants in an un-
contaminated aquifer recharge zone.
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V. The Remedial Feasibility Report Does Not Comply with the
National Environmental Policy Act
V.A. Inadequate Opportunity for Public Comment
In keeping with EPA's current policy, three weeks were allowed
for the public to review and comment on the draft feasibility
study.
V.B. Inadequate Consideration of Mitigative Measures
V.C. Inadequate Discussion of Environmental Impacts
Responses to the assertions in sections V.B. and V.C. are found
in Sections I, II and III.
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RESPONSES TO GENERAL QUESTIONS RELATIVE TO THE MASS TRANSPORT
MODEL RAISED AT THE JANUARY 30. 1984 MEETING
1. The model can simulate decay using an exponential decay
function after the advection/dlspersion computations.
2. Adsorption can be simulated by retarding particle advection.
3. Decay and adsorption were not simulated at Lone P1ne due to
the lack of site-specific data.
4. River concentrations were computed from the mass of particles
to the river and to active rising water nodes in the vicinity
of the river divided by the volumetric discharge of water at
all such nodes during that time step.
5. All contaminant modeling was for total volatile organics.
The site data were not sufficient to model Individual
constituents, and the study objectives were to determine if
contaminants were reaching the river, 1n what approximate
quantities, and to compare the relative effectiveness of a
set of proposed remedial action alternatives.
6. Time of travel simulations indicate that contaminants located
within the active flow field beneath the mound reach the
Manasquan River in approximately 8-12 years.
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ADDITIONAL CONCERNS RAISED BY THE COMMITTEE'S TECHNICAL CONSULTANTS
Numerous concerns and Issues were raised at the January 30, 1984,
meeting and In the February 10, 1984 letter prepared by Peter W.
Walcott. These are discussed below.
1. Number of Buried Drums
The feasibility study report refers to 50,000 as the possible
number of drums disposed 1n the landfill. This was based on an
existing report. Regardless, the 50,000 figure has no impact on the
model results, as the source strength used in the simulations was
determined through the calibration process to reflect the strength
that resulted In the best fit to the observed contaminant plume data.
The source strength used 1s In no way related to any assumption as to
a number of burled drums or a drum decay rate.
Responses to Papadopoulus & Associates, Inc. Review
a. Water Levels Used for Calibration
COM reviewed all available groundwater head data in preparation
for calibration of the flow model. It was our conclusion that the
March 31, 1982 data were representative of average conditions as
suggested in the F.C. Hart report. Table 1 presents a comparison of
the March 31, 1982 readings versus the arithmetic mean of all
groundwater head readings at the appropriate locations. This table
supports our conclusions. Furthermore, the data collected on March
31, 1982 provide a complete set of measured values for each well.
Measured data on other dates were incomplete for all locations or did
not closely approximate mean values.
We agree that observation wells located in the phreatic aquifer
close to the Manasquan River will Indeed be influenced by stages in
the river. The wells In the lower units will not be as significantly
Influenced. Most of the observation wells close to the river in the
phreatic aquifer are located 1n the Hornerstown formation, which 1s
not a significant aquifer.
b. Calibration of Groundwater Flow Parameters
The responses to questions 2, 3, & 4 on the January 30, 1984
Agenda presented herein clarify the questions regarding recharge.
Regarding the calibration results 1n the vicinity of monitoring
wells EPA 4/4A, 1t Is believed that the computed values are higher
than the observed values as a result of a misrepresentation of the
actual surface elevations in the adjacent stream due to the limited
topographic data available at the time the model was developed. The
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detailed survey completed by COM 1n June 1983 Indicates that the
surface elevations used in the model were somewhat high In the
vicinity of EPA 4/4A.
Note also that well EPA 4A responds very slowly and 1s believed
either partially clogged or screened In a relatively Impervious unit.
The time lag for the well to respond may produce gradients which are
not representative of average field conditions. The observed gradient
of this well has reversed several times over the period of
observation; thus, 1t appears that there 1s not any permanent upward
or downward gradient at this location.
Model nodes 1n the Immediate v}dn1ty of EPA 4A Indicate both
upward and downward gradients. This location appears to be quite
variable In Its vertical gradient, and no consistent regional pattern
exists.
The Implications of the variance between the model and the
observed value are not, under any circumstances, pervasive. The fact
that the head Is "fixed" (as an active rising water node) adjacent to
EPA 4/4A has little effect on gradients In the landfill or along the
Manasquan River or Its other tributaries.
c. Mounding Within the Landfill
It 1s our opinion based on available data that no significant
groundwater mound exists within the landfill. This 1s supported by
FIT, NJDEP, and COM field observations Indicating that seeps are
Intermittent and occur at various elevations and contain apparently
different contaminants based on color staining. Specifically, former
FIT employees who spent long periods of time onsite have related to us
that leachate seeps were prevalent at the higher elevations 1n the
landfill side slopes only after rainfall events. During dry weather
conditions leachate seepage was greatly reduced. As a result, we do
not believe that a significant mound exists or that the water level
within the landfill substantially Impacts the area groundwater flow.
In addition, no water was encountered In one of the trenches excavated
for drum sampling.
A mound Inside the landfill to a depth near the surface 1s not
likely. It would require many years of rainfall pooling within the
landfill without release to the underlying aquifer. Such releases,
however, have been demonstrated to occur by the presence of
contaminated groundwater to the north of the landfill and by seeps
from the side slopes. Furthermore, a significant maund, which does
not seep In dry periods, would require unrealistic hydraulic
properties, I.e., extremely low horizontal hydraulic conductivity.
Likewise, a significant transient mound which rises 20-40 feet during
rainfall would require unrealistic values of specific yield. Neither
of these characteristics are borne out by the behavior of landfills In
general nor with the majority of reported cover materials (Vlncentown
sand) and landfllled materials, nor with the materials encountered by
FCHA 1n the test pits.
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We believe that the seeps and water encountered In some of the
FCHA~test pits at the top of the landfill results from local perching
of Infiltration due to heterogeneities within the landfill Itself,
e.g*, Impervious sludge zones, clayey "day" cover material, etc. Note
that a relatively low mound beneath the landfill In the Vlncentown
does In fact occur 1n the simulation of average conditions and that
seeps are simulated around the periphery of the landfill on all but
the southerly side. This mound 1s carried by flow from upstream and
surrounding surface controls rather than high rates of direct
Infiltration for which there 1s no supporting data. Note that while
more than average Infiltration may occur at the landfill surface, a
major portion 1s diverted to surface seeps. Thus, the net
Infiltration to the saturated zone of the Vlncentown within the
landfill Is estimated to be no greater than that to undisturbed
portions of the Vlncentown sands.
d. Transport Model Calibration'
COM did not relate the release of contaminants to any specific
mechanism. We also believe the calibration was quantitative In nature
and not merely qualitative.
COM did review the limited quantity of time history data for
contaminants at observation wells and did not see adequate trends to
permit their use 1n transient calibration. Furthermore, the
groundwater sampling techniques used for the collection of data prior
to 1980 did not conform, for the majority of samples, with current
guidelines developed by the EPA for sampling volatile organlcs. Data
values prior to 1980 for volatile organlcs appear correlated to the
volume of water pumped from monitoring wells prior to sample
extraction and may not be Indicative of actual aquifer conditions with
respect to volatile organic concentrations at the time of sampling.
Therefore, we do not agree that use of the limited transient data
would have provided any additional estimates of the source .strength
parameters.
c. Simulated vs. Observed Concentrations in the Manasquan River
No attempt was made to simulate the Manasquan River due to a lack
of data and the volatile nature of the Indicator contaminants being
used 1n aquifer simulations. The concentrations of contaminants
quoted for the Manasquan River are areally averaged and merely
represent the total mass of contaminants entering the Manasquan River
system divided by the accompanying volume of water discharged. The .
actual observed values In the river are a function of many natural
forces, which were not simulated. For example, the contaminant levels
will be very sensitive to rainfall, depth of flow, surface area,-
antecedent conditions, temperature, wind, and other conditions.
Contaminants will be discharged In the drainage courses around the
landfill, as well as to the river proper, which provides for differing
opportunities for volatilization and degradation before reaching the
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various downstream observation points. Table 2 1s a listing of the
available surface water data. They show that values fall on both
sides of the areally averaged value of 1000 ppb total volatile*.
While more values are lower, this 1s to be expected, as natural forces
will tend to cause rapid volatilization of the highest concentrations
which should occur furthest upstream from the Manasquan River
observation points. The conclusion to be drawn from this analysis 1s
not the accuracy of the Manasquan River simulation, but that we are
Illustrating the relative effectiveness of each alternative simulation
and that there are contaminants being discharged with whatever
potential Impacts they may have.
We note that the recent round of sampling undertaken by Versar
under contract to the Steering Committee Indicates lower levels of
contaminants at Burke Road than generally observed 1n any of the data
available to COM at the time of model calibration. If these results
were to Indicate a decay 1n the source strength at the landfill, then
we would expect to observe a commensurate reduction 1n the contaminant
levels In the observation wells around the landfill and along the
streams. We, therefore, requested a complete round of sampling of all
wells and surface waters by EPA to determine the current overall
contaminant levels 1n the groundwater. This sampling has been
completed.
Table 3 summarizes the results of the latest sampling round. The
observed levels were consistent with previous observations 1n wells
that have been clean or at low levels (EPA1, 1A, 2A, 4, 4A, 5, 6A, 7A,
8, 8A, 9A, 10, and 10A). The levels were also consistent for wells
EPA 3 and 5, which have showed contamination In the past. Wells 3A,
5A, and 6, all near the presumed plume centerline, showed an
approximately one order of magnitude decrease, which may have
Indicated a decreasing source strength. However, wells EPA 7 and 9,
which are also along that presumed centerllne, showed levels
consistent with previous observations. Therefore, the data do not
conclusively show that there has been a decay In the source strength.
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R!SPON^_I°.!REVIOU^LY HRITTEN QUESTIONS
DISCUSSED AT JANUARY 30. 1984 MEETING ~
1. What are the hydraulic properties of the simulated units as
determined from field tests and how do these values compare with those
used In the model?
Two sets of hydraulic property data are available, those
collected by F.C. Hart, Associates (FCHA), and those
collected by COM subsequent to the modeling efforts.
Initially, COM based Its model parameter values on the FCHA
results, but these were adjusted (Increased) during
calibration to match the observed plezometric surface data.
A comparison of the COM data and the values used 1n the
final development of the model for horizontal hydraulic
conductivity In feet/day (K ) are as follows:
COM Measured
Formation (Geometric Mean) Used 1n Calibrated Model
Vlncentown 43.8 30
Upper Red Bank 13.1 4
Lower Red Bank 47 60
The FCHA observations were, 1n general, approximately an
order of magnitude lower than the COM observations, but the
FCHA staff Involved 1n data collection and analysis
expressed reservations relative to the quality of some of
the field data. A tabulation of the COM measured values Is
attached as Table 4. These were analyzed using methods
developed by Hvorslev (1951).
2. What was the basis of the recharge rates used In the model?
Two references were used In the development of recharge
rates:
1. Rhodehamel, E.G., A Hydro!ogle Analysis of the New
.Jersey P1ne Barrens Region, New Jersey department of
Conservation and Economic Development, Division of Water
Policy and Supply, Water Resources Circular No. 22,
1970.
2. Jablonskl, L.A., Groundwater Resources of Monmouth
County, New Jersey, Special Report No. 23, State of New
Jersey, Department of Economic Development, Division of
Water Policy and Supply, 1968.
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Based on these reports, the recharge rate for the Vlncentown
formation was estimated to be 18.8 Inches/year. No data
were available for the Hornerstown formation recharge, and
that value was estimated to be 4.8 Inches/year based on the
characteristics of the formation. These values are applied
by the model to all nodes representing the phreatlc surface.
Over some of the area, however, recharge 1s rejected as a
result of rising water conditions or specified head at the
node. The net recharge to the system Is therefore reduced.
Under the average conditions to which the model was
calibrated, a total discharge to all surface nodes of 2.42
cfs was calculated. This represents an average net recharge
of 10.2 Inches/year over the gross modeled area (2065
acres). This net recharge compares favorably with the basin
wide average of 0.55 mgd/square mile (11.55 Inches/year)
estimated by Jablonskl.
3. What Is the respective percentage of the modeled area covered by
the Vlncentown, Hornerstown, and Upper Red Bank sand outcrops?
The Vlncentown, Hornerstown, and Upper Red Bank formations
covered 97.3%, 2.7%, and 0%, respectively of the modeled
area. (Note that these values have been revised from those
presented at the January 30th meeting.) The average applied
recharge based on the above percentages 1s 18.49 Inches/year
or 378,900 cubic feet/day (4.4 cfs). Of this recharge
208,700 cubic feet/day (10.2 Inches/year) discharges to the
surface through the groundwater system and the remainder
(170,200 cubic feet/day) 1s rejected and becomes a part of
direct runoff.
4. What Is the flow mass balance under the simulated existing
conditions? Specifically, what are the total fluxes: a) from
recharge, b) to the Hanasquan and Hetedeconk Rivers and to each of
their tributaries, and c) across the southern boundary (beneatF the
Metedeconk) of the modeled area?
The simulated groundwater discharge to various sources Is as
follows (all In cubic feet/day):
Manasquan River above Burke Road 34,800
Western (upstream) tributary 22,700
Drainage ditch north of Manasquan 3,200
Southerly flowing ditch north of the landfill 4,"300
Sub total base flow upstream of Burke Road (65,000)
Discharge to Manasquan (downstream of Burke Road) 50,800
Northeastern tributary (boundary) 1,200
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Eastern boundary (southerly Manasquan tributary) 65,900
Total base flow to Manasquan River in model area (182,900)
Netedeconk River 25,700
Total Discharge for Grid Area 208,600
In all simulations the mass balance was within 0.1 to 0.2%.
5. How does the model calculate flux to specified head and to active
"rising-water" nodes?
The calculation of flux to specified head and active rising
water nodes In DYNFLOW 1s Implicit 1n the code's finite
element solution technique. Strat1graph1c layers within the
system are represented 1n the model by a set of vertical
prisms called working elements. Each element 1s formed by
six nodes, three from above and three from below. During
simulation, each element Is further subdivided Into three
tetrahedra. Flow within and between tetrahedra 1s then
computed based on Darcy's Law and the principal of
Conservation of Mass Flux at specified head and active
rising water nodes, therefore, 1s computed as a function of
the plezometrfc heads In surrounding nodes and the hydraulic
properties (permeability and storage coefficients) In all
tetrahedra. Piezometric head at rising water nodes in the
system are assumed fixed at ground surface if the computed
head In the phreatic aquifer rises to ground surface.
6. How was the 2 cfs baseflow in the Nanasquan River determined?
As listed 1n the answer to question 14, 0.75 cfs upstream of
Burke Road, 0.58 cfs to the Manasquan downstream of Burke
Road, and 0.78 cfs from the southerly tributary sums to 2.12
cfs for the modeled area. The downstream boundary of the
model Is just downstream of the Versar sampling location
MSN-la.
7. What was the calibration process used in arriving at the
equivalent horizontal hydraulic conductivity of slurry walls? To'
which elements was this equivalent hydraulic-conductivity applied?
The word "calibration" as stated in the COM feasibility
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study report related to hydraulic conductivity of slurry
walls should have been "calculated." The conductivity
'applied was element-specific, and was selected to provide
the same resistance through the element as would a three
foot thick slurry wall with a hydraulic conductivity of
10 on/sec assuming that flow 1s essentially transverse to
the well. It was applied to all elements along the boundary
of the landfill. Figure 1 depicts the slurry wall elements.
8. What were the mass balance residuals 1n the simulation of each of
the evaluated remedial alternatives?
The mass balance residuals from the flow model were less
than 0.1-0.21 In all cases.
9. What are the contaminant mass balances at the end of each
five-year simulation Interval during the modeling of existing
conditions? Specifically, what were the contaminant masses that
had: a) left the landfill, b) entered the Manasquan River and each of
Us tributaries, and c) been stored within each simulated layer?
Table 5 is a listing of the mass balance values. The values
are for the entire flow field. The simulations did not
display mass balance values by layer.
10. How does the model calculate contaminant fluxes to specified head
and active "rising-water11 nodes?
Any simulated particle that breaks the plane of the model
boundary within an element connected to such a node 1s
assumed to discharge, at the nearest node. Concentrations at
each node are computed based on the total mass of particles
leaving the node divided by computed water flux at that
node.
11. How was the 1,000 ppb contaminant concentration 1n the Manasquan
River computed?
The average mass flux to the river and Its tributaries for
the last 600 days of the calibration period was 4.44 kg/day.
Dividing this by an average flow of 2.12 cfs yields a
concentration of 857 ppb which rounded to 1000 ppb. Note
that this Is the value which would be expected 1n the river
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at the easterly model boundary If the contaminants were
conservative and undisturbed In the surface waters.
Approximately 90% of the contaminants discharge upstream of
Burke Road. The computed concentration at Burke Road would,
therefore, be 2180 ppb on the basis of the same assumptions.
12. How was the model used to simulate the loading of contaminants
from the landfill Into the underlying aquifer?
Contaminant particles of a given, constant mass (the source)
were Injected Into the system In the phreatlc aquifer at 22
points within the landfill at a rate based on the
calibration of the contaminant transport model. Figure 2
Indicates the points at which particles were Injected. A
uniform Injection rate at each point over the simulation
time period was used. Contaminant transport is simulated as
a transient using the equilibrium flow field, as discussed
1n Appendix B. A thirty day time step was used.
13. How was the loading of contaminants and their equivalent
concentrations determined? What were the values used In the
simulation of existing conditions?
The loading of contaminants was determined in the
calibration process. Initially, a unit contaminant strength
was used at Individual locations. The relative
concentrations were compared to measured values in the field
and the strength and location of the source was adjusted on
the basis of this comparison as necessary. What evolved
from this process was that a uniform distribution of source
over the landfill, constant over the 10 year operation of
the landfill, best reproduced the pattern observed In the
field. The strength was then proportioned to reproduce the
observed field values as closely as possible.
The calibrated rate was 6.23 kg/day total mass flux
uniformly distributed over each of the 22 Injection points
used.
14. What were the loading rates of contaminants and/or equivalent
concentrations during the evaluation of remedial Alternatives 4 and
4A? What was the basis for using these rates and concentrations?
The same source strength was used for Alternatives 4 and 4A
as was used for existing conditions. The flow field
-------
solution changed, since there 1s no recharge to the landfill
elements, but given the uncertainties with respect to the
source Itself, a conservative assumption of no change 1n
mass loading was made. The conservative approach was
adopted 1n light of existing Information which suggests that
a large mass of contaminants was disposed of at the site.
Based on this COM had no reason to make any other
assumption.
Simulations Indicate that even with a cap 1n place,
horizontal flow occurs through the lower depths of the
landfill, since the plezometHc surface 1s still within the
Vlncentown. Thus, the potential for contaminants to
continue to be removed from the landfill exists, and COM
feels 1t Is appropriate to maintain the source strengths to
Insure a conservative design.
Potential mechanisms for maintaining the discharge of
contaminants could be either:
o rupture of burled containers, with subsequent release
of aqueous solutions which would enter the water table
through percolation,
%
o non-aqueous fluids which are located within the
landfill or the flow field and gradually enter
solution,
o rupture of burled containers within the flow field, or
o residual pools of non-aqueous fluids from bulk dumping
presently existing at the water table which would
continue to enter solution slowly 1n the groundwater
flow field.
15. No Question 115 was presented.
16. Are the models used for the study documented and publicly
available?
The computer codes used are proprietary to COM and are not
publicly available. -Documentation beyond that provided 1n
the feasibility study report Is attached as Appendix A for
the OYNFLOW code and as Appendix B for the DYNTRACK code.
17. Did the models used for this study receive outside peer review?
The models have been reviewed by Professor John Wilson of
-------
the University of New Mexico (formerly of MIT) and Professor
Lynn Gelhar of MIT. Professor Gelhar also reviewed the Lone
Pine application.
-------
TABLE 1
COMPARISON OF MARCH 31. 1982 MEASURED PIEZOMETRIC SURFACE
ELEVATIONS WITH 10 MONTH MEAN PIEZOMETRIC SURFACE ELEVATIONS
MEAN OF 08-
FEET ABOVE SERVED FEET DIFFERENCE
WELL NO. MSL ABOVE MSL FEET
EPA-1 125.78 125.56 -0.22
EPA-1A 123.51 123.16 -0.35
EPA-2 115.76 115.74 -0.02
EPA-2A 117.40 117.37 -0.03
EPA-3 112.19 112.13 -0.06
EPA-3A 112.61 112.63 +0.02
EPA-4 121.76 121.84 +0.08
EPA-4A 121.41 121.23 -0.18
EPA-5 117.68 117.42 -0.26
EPA-5A 112.66 112.63 +0.03
EPA-6 107.57 107.58 +0.01
EPA-6A 112.76 112.54 -0.22
EPA-7 107.57 107.52 -0.05
EPA-7A 112.66 112.44 -0.22
EPA-8 110.46 110.52 +0.06
EPA-8A 112.67 112.42 -0.25
EPA-9 110.49 110.29 -0.20
EPA-9A 113.17 113.12 -0.05
EPA-10 105.37 105.17 -0.20
EPA-10A 107.43 107.27 -0.16
DEP-1 116.49 116.60 +0.11
DEP-2 115.61 115.55 -0.06
DEP-3 111.43 111.27 -0.16
DEP-4 120.16 120.24 -0.08
DEP-5 126.14 125.76 -0.38
DEP-6 123.44 123.10 -0.34
DEP-7 118.57 118.73 +0.16
RE 130.20 129.67 -0.53
RC 130.41 130.02 -0.39
RW 130.95 131.17 +0.22
-------
TABLE 4
FIELD TEST HYDRAULIC CONDUCTIVITY
(FT/DAY)
WELL/LOCATION
SCREENED FORMATION
EPA-1
2
2A
4
4A
5
5A
6
7
8**
8A**
9
10
CDM-1
2
3
4
4A
15.2
21.1
14.3
18.7
0.23
24.2
18.7
3.4
13.6
94.7
168.9
1.5
5.5
29.8
12.5
8.0
8.4
12.6
48
67
45
60
0.75
78
60
11
43
-
4.8
17
94
40
25
27
40
4.8
6.7
4.5
6.0
0.075
7.8
6.0
1.1
4.3
-
0.48
1.7
9.4
4.0
2.5
2.7
4.0
Lower Red Bank
V1 ncentown
Lower Red Bank
Vlncentown
Lower Red Bank
V1 ncentown
Lower Red Bank
Homer stown/ Upper Red
Hornerstown/Upper Red
Hornerstown/Upper Red
Lower Red Bank
Hornerstown/Upper Red
Vlncentown
Vlncentown
V1 ncentown
Vlncentown
V1 ncentown
Lower Red Bank
Ban!
Bant
Bant
*Based on an an1sotropy ratio of 1:10
"From constant head test data; all other tests were falling head
-------
SIMULATED
SLURRY WALL
11
14
IB
1C
feol* I I«M*«I
LONE PINE LANDFILL
ELEMENTS USED FOR SLURRY WALL SIMULATION
FIGURE 1
-------
II
SOURCE
INJECTION NODE
\.
12
IB
V\.: '•' '"J &V
a-
»••
'•/•<.
14
16
IS
•col* M«M'«I
LONE PINE LANDFILL
SOURCE INJECTION LOCATIONS
FIGURE 2
-------
TABLE 2
MANASQUAN RIVER IMMEDIATELY UPSTREAM OF BURKE ROAD
SAMPLER:
UNKNOWN
BCM
JAN-26-79
BCM
MAR-04-80
CAL
FEB-Ob-1982
FCHA
SEP-14-1982
FCHA
ACROLEIN
ACRVLON1TRILE
BENZENE
CARBON TETRACHLORIDE
CHLOROBENZENE
1,2-DICHLOROETHANE
1.1.1-TRICHLOROETHANE
1.1-D1CHLOROETHANE
1,1.2-TRICHLOROETHANE
1.1,2,2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOKUETHVL VINYL ETHER
CHLOROFORM
1.1-D1CHLOROETHVLENE
TRANS-1,2-DICHLOROETHVLEHE
1,2-DICHLOROPROPANE
TRANS-1,3-DlCHLOROPROPVLENE
C1S-1.3-01CHLOROPROPYLENE
ETHVLBENZENE
METHYLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMOFORM
01CHLORUBROMOMETHANE
TR1CHLOROFLUOROMETHANE
D1CHLURUU1FLUOROMETHANE
CHLURODIBROMOMETHANE
TETRACHLOKOETHVLENE
TOLUENE
TRICHLORUETHVLENE
VINYL CHLORIDE
750.
14.
1.
.200
.100
2.
400.
.400
18,
19.
-------
NANASQUAN RIVER IMMEDIATELY DOWNSTREAM OF THE CONFLUENCE WITH THE DRAINAGE DITCH DUE NORTH OF THE LANDFILL
SAMPLER:
UNKNOWN
BCN
OCT-17-79
NJHD
FEB-05-1982
FCHA
SEP-14-1982
FCHA
ACROLEIN
ACRVLON1TR1LE
BENZENE
CARBON TETRACHLOR10E
CHLOROBENZENE
2-D1CHLOROETHANE
1.1-TR1CHLOROETHANE
1-D1CHLOROETHANE
1.2-TR1CHLOROETHANE
1.2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOROETHVL VINYL ETHER
CHLOROFORM
1.1-DICHLOROETHVLENE
TRANS-1.2-DICHLOROETHVLENE
1,2-DICHLOROPROPANE
TRANS-1,3-DICHLOROPROPYLENE
CIS-1.3-OICHLOROPROPYLENE
ETHVLBENZENE
METHVLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMOFORM
D1CHLOROBROMOMETHANE
TR1CHLOROFLUOROMETHANE
DICHLOKOD1FLUOROMETHANE
CHLOROOIBROMOMETHANE
TETRACHLOROETHVLENE
TOLUENE
TR1CHLOROETHYLENE
VINYL CHLORIDE
960.
25.
2200.
100.
120.
220.
.900
.100
1.
580.
12.
22.
15.
26.
23.
1700,
5000.
32.
4800.
28.
440.
-------
TABLE 2 (Cont.)
DRAINAGE DITCH DUE NORTH OF THE LANDFILL
SAMPLER:
UNKNOWN
BCM
ACROLE1N
ACRVLON1TRILE
BENZENE
CARBON TETRACHLOR10E
CHLOROBENZENE
1,2-DlCHLOROETHANE
l.M-TRICHLOROETHANE
1.1-DlCHLOROETHANE
1.1.2-TR1CHLOROETHANE
1.1.2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLORUETHYL VINYL ETHER
CHLOROFORM
1.1-OlCHLOROETHVLENE
TRANS-1.2-DICHLOROETHYLENE
1.2-D1CHLOROPROPANE
TRANS-1,3-DICHLOROPROPYLENE
C1S-1.3-OICHLOROPROPVLENE
ETHVLBENZENE
METHVLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMOFORM
D1CHLOROBRONOMETHANE
TR1CHLOROFLUOROMETHANE
DICHLOROOIFLUOROMETHANE
CHLOR001BROMOMETHANE
TETRACHLOROETHVLENE
TOLUENE
TR1CHLOROETHVLENE
VINYL CHLORIDE
1450.
1.
.300
.900
540.
-------
TABLE 2 (Cont.)
DRAINAGE DITCH ADJACENT TO NORTHNEST CORNER OF THE LANDFILL
SAMPLER:
UNKNOWN
BCN
ACROLEIN
ACRVLONITR1LE
BENZENE
CARBON TETRACHLORIDE
CHLOROBENZENE
1,2-DICHLOROETHANE
1.1.1-TR1CHLOROETHANE
1.1-DICHLOROETHANE
1.1.2-TRICHLOROETHANE
1,1,2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOROETHVL VINYL ETHER
CHLOROFORM
1.1-D1CHLOROETHVLENE
TRANS-I.2-D1CHLOROETHVLENE
1.2-DICHLOROPROPANE
TRANS-1,3-DICHLOKUPROPYLENE
C1S-1,3-DICHLOROPROPVLENE
ETHVLBENZENE
METHYLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMUFOKM
D1CHLOROBROMOMETHANE
TR1CHLOROFLUOROMETHANE
D1CHLORODIFLUOROMETHANE
CHLOKOD1BROMOMETHANE
TETRACHLOKUETHVLENE
TOLUENE
TRICHLOROETHVLENE
VINYL CHLORIDE
IS 30.
.800
.BOO
380.
-------
TABLE 2 (Cont.)
NANASqUAN RIVCt IMMEDIATELY UPSTREAM OF DRAINAGE DITCH CONFLUENCE DUE NORTH OF THE LANDFILL
OCT-17-1979
SAMPLER: BCM
ACROLEIN
ACRVLON1TRILE
BENZENE 17U.
CARBON TETRACHLORIDE
CHLOROBENZENE , 21.
1.2-D1CHLOROETHANE
1.1,1-TRICHLOROETHANE
1.1-DICHLOROETHANE
1.1.2-TRICHLOROETHANE
1.1.2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOROETHVL VINYL ETHER
CHLOROFORM
1.1-DICHLOROETHVLENE
TRANS*1,2-01CHLOROETHVLENE 25.
1,2-OlCHLOROPROPANE
TRANS-1,3-D1CHLOKOPROPYLEHE
CIS-1.3-U1CHLUROPROPVLENE
ETHYLBENZENE
METHVLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMOFORM
D1CHLORUBROMOMETHANE
TR1CHLOROFLUOROMETHANE
0ICHLORODIFLUOROMETHANE
CHLORODIBROMOMETHANE
TETRACHLOROETHVLENE
TOLUENE 370.
TR1CHLOROETHYLENE
VINYL CHLORIDE
-------
MANASQUAN RIVER AT IRON BRIDGE ROAD
SAMPLER:
JUN-14-1983 AUG-16-1983 NOV-17-1983 MAR-05-1984
VERSAR VERSAR VERSAR NUS
ACROLEIN
ACRVLONITRILE
BENZENE
CARBON TETRACHLORIDE
CHLORUBENZENE
1.2-01CHLOROETHANE
1.1.1-TRICHLOROETHANE
1,1-DICHLOROETHANE
1.1.2-TR1CHLOROETHANE
1.1.2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOROETHVL VINYL ETHER
CHLOROFORM
1,1-OICHLOROETHVLENE
TRANS-1.2-UICHLOROETHVLENE
1,2-OICHLOMOPROPANE
TRANS-1.J-OICHLOROPROPYLENE
CIS-1.3-01CHLOROPROPYLENE
ETHVLBENZENE
METHVLENE CHLORIDE
CHLOROMETHANE
BROMOMETHANE
BROMOFORM
D1CHLOROBROMOMETHANE
TRICHLOROFLUOROMETHANE
D1CHLOR001FLUOROMETHANE
CHLORODIBROMOMETHANE
TETRACHLOROETMVLENE •
TOLUENE
TR1CHLOROETHVLENE
VINYL CHLORIDE
4.
11.
8.
7.
7.
4.
11.
-------
TABLE 2 (Cont.)
MANASQUAN RIVER AT JACKSON MILLS ROAD
SAMPLER:
FEB-19-1981 JUN-14-1983 AUG-16-1983 NOV-17-1983
EPA11 VERSAR VERSAR VERSAR
MAR-OS-1984
MIS
ACROLEIN
ACRVLON1TR1LE
BENZENE
CARBON TETRACMLOR10E
CHLOROBENZENE
1.2-DICHLOROETHANE
1,1.1-TRICHLOROETHANE
1.1-D1CHLOROETHANE
1.1.2-TRICHLOROETHANE
1.1,2,2-TETRACHLOROETHANE
CHLORUETHANE
2-CHLOROETHYL VINYL ETHER
CHLOROFORM
1.1-DICHLOROETHYLENE
TRANS-1,2-OlCHLOROETHYLENE
1.2-D1CHLOROPROPANE
TRANS-1.3-DICHLOROPROPYLENE
C1S-1,3-1)1 CHLOROPKUPYLENE
ETHVLBENZENE
METHVLENE CHLORIDE
CHLOROMETHANE
BROMONETHANE
BROMOFORM
D1CHLOROBROMUMETHANE
TRICHLOROFLOOROMETHANE
D1CHLORODIFLUOROMETHANE
CHLORODIBROMOMETHANE
TETRACHLOROETHYLENE
TOLUENE
TRICHLOROETHYLENE
VINYL CHLORIDE
-------
MAMASQUAN RIVER AT GEORGIA ROAD
SAMPLER:
FEB-19-1981
EPA
JUH-14-1983 AUG-16-1983 NOV-17-1983
VERSAR VERSAR VERSAR
MAR-05-19B4
MIS
ACROLEIN
ACRVLONITRILE
BENZENE
CARBON TETRACHLORIOE
CHLOROBENZENE
1.2-D1CHLOROETHANE
1.1.1-TK1CHLOROETHANE
ltl-DICHLOROETHANE
1.1.2-TR1CHLOROETHANE
1.1,2.2-TETRACHLOROETHANE
CHLOROETHANE
2-CHLOROETHYL VINYL ETHER
CHLOROFORM
1.1-DICHLOROETHVLENE
TRANS-1.2-DICHLOROETHYLENE
1V2-OICHLOROPROPANE
TRANS-1.3-01CHLURUPROPYLENE
ClS-1,3-OICHLOROPROPYLENE
ETHVLBENZENE
METHYLENE CHLORIDE
CHLORONETHANE
BROMUNETHANE
BROMUFORM
D ICHLUROBROMUME.THANE
TR1CHLOROFLUOROMETHANE
DICHLOROU1FLUOROMETHANE
CHLOKODIBROMOMETHANE
TETRACHLOROETHVLENE
TOLUENE
TRICHLOROETHVLENE
VINYL CHLORIDE
14.
-------
NNtfSQUMI RIVER UPSTREAM OF OMFIUENCE KITH tCSTERN DRAINAGE DITCH
SAMPLER:
JAN-%-79 OCT-17-79 HW-O4-19BO MWMM-1W1 MT-3I-1W1 FEB-US-I9K! SEP-I4-1W2
BCN BCM CM. EPA EPA FOM FUM MIS
ACMLEIN
ACRM.ONITRILE
KNZENE
CARWM TETRACHUMIK
OUMKN/ENE
1.2-DICM.OMETHMf
1.1.1-TRICHLURUETHMC
1.1-OICH.URUETHMC
1.1.2.2-TETKACMjUHUETHMC'
CMLOROCTHMC
2-CHLUHUETMn. VINIL EDCR
CM.CMUFCWI
1.1-OICM.ONUETHftENE
TRANS-1 .2-OICM.OHOETHVLENE
1.2-OIOCUMOf>MPAMI
TRANS-1 , J-DICHLOWBUPHEMI
CIS-1 .3-DiataROPHUPVlENE
METHVUIE
CHLUMCTWNE
BMMUFORN
DiacUROMUNMETHNC
1RICHUMUFLUQRUNITHMC
OICM.OROUIFLUMUMITHMC
CNLIMaDieNUMJWTHME
TCTRACauaTHTUIC
TULUEK
TRICHUMETNVUMI
VINYL OCORIIX
-------
wm.r. 2 (cont,)
SAMPLER:
OCT-17-1979 FEB-19-1981 MAV-31-19B1 JUN-14-1983 AOG-16-1983 NUV-i 7-1983 HAR-Ob-lVM
BCM EPA EPA VERSAR VERSAR VERSAR MIS
ACROLEIN
ACRVLONITRILE
BEN2ENC
CAMUN TETRACM.ORIDC
CMLURUWNIENE
1.2-OICHLOROCTHANE
1.1.1-TRICHLUWJETNANC
I.I.DICHLORUCTHANE
1,1.2-TRICNLORUETHANE
1.1,2t2-TETRACHUMOETHANE
CMLOROETHANE
2-CNLOROETHa VINVL ETHER
CHLOROFORM
1.1-OICNLUROETHTLENE -
TRANS-I,2-OICHLOROETHVLENE
1.2-OICHLOROPROPANE
TRANS-1,3-OICHLOROPROPVLENE
CIS-I.3-DICHLORUPHOPn.ENE
ETHVLBEN2ENE
METHILENE CHLORIDE
CHLOROHETNANE
•ROMOHETHANE
BROHUFURM
OICHLORUHRUNOMETHANE
TRICHLORUFLUOMOMETHANE
DICNLORUOIFLUURUMETHANE
CHLORODIBROMUNETHANE
TETRACHLUROETHVLENE
TOLUENE
TRICHLOROETHVLENE
CHLORIDE
9.
19.
22.
17
2.
1.
9.
7.
16.
3.
9.
12.
-------
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-------
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-------
TAME S
MASS SUMMARY . FOR LOME PINE SINUUTIONS
(•II IN K«>
HUH
EP1NE2
RIA9
R2A9
R3A9
R4A9
R1A1
JI2AI
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R2A2
R3A2
R1A3
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H3A3
R4A3
R1AS
R2AS
R3A&
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R1AR
R2A8
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400
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NASS TRAPPED
NASS (HENUVEO
LOST FROM SIMULATION)
0
0
0
0
0
0 9.40K6
0
0
0 9.39*Et
0
0
0 <
0
0
0
9.024E3
0
0
2.796C2
0
0
0
0
0
0
0
0
0
0
0
J.794E*
.790E4
.394ES
.I40E4
.98bE»
.087E5
.628ES
.M8E4
.073E*
.400E4
.70UE3
.OOOE2
.322E*
.OOOE4
.OOOE4
.370C5
.OOUE3
.OOOE4
.UOOE4
RUN
DESCRIPTION
10 IEAR
NO ACTION
DEEP
MALL
SO KM
DEEP
MALL
NO PUMPS
SHAUUM
MALL
SO 6PM
SHALLUM
MALL
100 GPM
SHALLUM
MALL
NO PIMPS
LANDFILL
CAP
100 GPM
LANDFILL
CAP
NO PIMPS
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Response to Steering Committee Comments
August 1, 1984
EPA does not dispute the fact that the levels of contaminants
detected in the Manasquan River are relatively low at the
represent time. However, the information available from EPA°s
review of SCP records regarding the quantity and the nature
of the hazardous substances potentially disposed of in the
landfill makes a conservative approach to the protection of
public health and the environment appropriate.
As noted in the comments, many of the drums in the landfill
indeed may have ruptured, however, EPA
believes that the high levels of volatile organics currently
being measured do not necessarily indicate the total array
of hazardous substances which may be present in the landfill
due to the following reasons:
Adsorptive and absorptive capacities of the soils and municipal
refuse disposed of in the landfill, the densities of the
hazardous substances in relation to the other liquids in the
landfill, and the perching of liquids in impermeable zones
within the landfill may have significantly influenced the
transport of the hazardous substances disposed of here.
Because of the high contaminant levels detected in the
groundwater, the potentially slow transport rate of contaminants
in groundwater, and the potential impact on the reservoir and
the local flora and fauna, the need for implementing a corrective
remedial action is deemed necessary. In that there is a
lateral component of contaminant transport that a cap alone
will not prevent, this suggested remedial alternative is
not deemed acceptable to adequately protect human health and
the environment.
Upon completion of the ongoing treatability studies, the specific
treatment scheme will be designated. The Steering Committee
argues that it is impossible to determine the cost-effectiveness
of treatment at this time. The most expensive treatment
possibility is, however, cost-effective. Therefore, it is
clear that if a less expensive option proves to be feasible,
then that option will, obviously, be even more cost-effective.
Response to Lone Pine Steering Committee Comments
August 31, 1984
Since the landfill°s source strength and composition is largely
unknown, the contaminant transport model used to simulate the
relative contaminant transport for the remedial alternatives
was calibrated to achieve the best fit to observed contaminant
plume data. Various remedial schemes were simulated and
evaluated by projecting the contaminant loading rates to the
Manasquan River. Field sampling results indicate much lower
concentrations in the surface water than is predicted by the
model. This is largely because volatilization was not con-
sidered in this groundwater contaminant transport model.
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Because of the limited available data on the quantity and
nature of the waste in the landfill, and because the potential
for contamination to continue to be released from the landfill
exists, it was appropriate to maintain the source strength to
ensure a conservative design. It was also assumed that the
wastes are evenly distributed over the landfill and capable
of sustained, steady-state releases for ease in modeling, it
should be noted that the purpose of the contaminant transport
modeling was only to help evaluate the relative effectiveness
of each alternative, and the remedial alternative analysis and
selection was based upon the ground water flow model, which
evaluated the effects of various containment and pumping schemes
on the flow of groundwater in the underlying aquifers.
Based upon the available data, it appears that no significant
groundwater mound (attributable to infiltration) exists within
the landfill or that the water level in the landfill substantially
impacts the area groundwater flow, but rather the water
encountered in the landfill is perched on top of local
impermeable layers (such as impervious sludge zones). While
infiltration may occur at the landfill surface, a major portion
is believed to be diverted to surface seeps. Thus, the net
infiltration to the saturated zone of the Vincentown with the
landfill is believed to be no greater than that to the undisturbed
portion of the Vincentown Sands. A relatively low mound
beneath the landfill in the Vincentown does occur, however,
it is believed to be due to upgradient flows and surrounding
surface controls rather than infiltration.
As was indicated previously, the predicted contaminant con-
centrations in the Manasquan River are a result of ground-
water inputs. Volatilization is not part of the groundwater
contaminant transport model. It is not unreasonable to expect
significant reductions in volatile organics concentrations
once the contaminant°s groundwater transport media becomes
surface water. It should be noted that the monitoring wells
on the southern river bank are severely contaminated. This
is significant because these river bank monitoring wells can
be considered at the groundwater/surface water interface
which implies that severely contaminated groundwater is re-
charging the river.
As a result of the initial screening, it was determined that
the surface seal alone will not achieve the cleanup objectives
because the migration of contamination from the landfill will
not be eliminated by the reduction in water infiltration caused
by installation of clay cap. Installation of a cap that
reduces infiltration by 90% will result in the lowering of the
water table by approximately 1 foot. However, there will
still be vertical and horzontal flow of water into the landfill.
Flow out of the landfill will be reduced but not eliminated.
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Moreover, there is evidence that the site was excavated down
to depths of 10 feet into the Vincentown Sands aquifer during
the period in which the landfill was being constructed and
operated. Measurements from sampling wells around the site
indicate that the groundwater surface is likely to be above
this level, allowing the lateral flow component of groundwater
at the lower depths of the landfill to flood the bottom of
the fill area, permitting the solubilizing and dispersion of
residual pools of substances derived from ruptured drums and
from bulk liquid dumping. The potential problems are compounded
by the uncontrolled manner in which disposal took place,
resulting in the possiblity that solvents could moblilize
chlorinated organics which might otherwise tightly adsorb
onto soil particles.
5. Opportunity for public input and compliance with NEPA are dis-
cussed elsewhere in the record.
Since contaminated groundwater will be extracted in the proposed
containment scenario, it will have to be treated. Upon
completion of the ongoing treatability study, the most acceptable
treatment system will be selected. Currently, two systems are
under evaluation — on-site treatment and treatment at the
regional wastewater treatment plant.
Comments on Versar°s Reports
o Considering the fact that no information was given regarding
Versar°s sampling quality assurance, and the adequacy of their
sampling and preservation procedures, the accuracy of their
results is unknown.
o It is questionable whether single grab samples can accurately
characterize the extent of the contamination of the Manasquan
River. Composite samples over several days or weeks would
probably be more representative.
o Essentially, Versar relied on limited data to draw comprehensive
conclusions regarding the degree of contamination at the site.
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1. Information Pertaining ^?.^*.?*^"r* °* the Material Disposed
of at the Lon« Pine Landfill (1984 Comments, pages 8 to
|pos<
"TIT
A number of comments of the Lone Pine Steering Committee
question the nature of the waste deposited In the Lone Pine
Landfill. Specifically, the Steering Committee states that
•concern over liquid filled drums at Lone Pine Is unfounded
and contrary to the evidence which Is available.* In addition
the committee states that *BPA has available to it the records
of companies whose wastes were deposited at Lone Pine; BPA has
never suggested that there is any evidence that chemical wastes
more deleterious that those already identified were buried at
Lone Pine.* Moreover, the Steering Committee has stated that
the bulk of the material entering the landfill from Scientific
Chemical Processing (SCP) was in the form of bulk solids not
drums, infering that this material is not particularly hazardous.
BPA takes exception to the Steering Committee's comments
in this area. BPA staff have pursued a number of avenues in
attempting to characterize the material in the landfill.
Irst, BPA has conducted a thorough review of the records of
CP available as a result of the criminal proceedings. Moreover,
PA has issued information request letters to approximately 140
ompanies. A review of this material indicates that a wide range
f both organic and inorganic hazardous substances were sent to
one Pine.
The few excerpts from the testimony cited by the Steering
saunittee relative to the nature of the material are totally
afuted by the bulk of the transcripts. Specificallly, both
'le testimony of Carmine Trezza, the foreman at SCP-Newark,
nd Henry Heflich, the hauler who took material from SCP to
one Pine indicate that large quantities of both liquid and
olid waste in both drums and bulk form went to Lone Pine.
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The drum disposal operation at SCP involved the dumping
of the material in drums into a large dumpster. Where the
drum could be emptied totally, it would be sold to a drum
reconditioner (TUISA, pg. 2886). When the drum could not be
emptied, it would be segregated and loaded into a dumpster for
disposal at the Landfill. The method by which SCP segregated
the drums was to hit the drum with a pipe to determine if it
was filled with liquids or solids. If the drum was found to
have solids AT TBB BOTTOM, the drum was considered to be solid
(i.e., not suitable for drum recovery) and disposed of even
though there might be considerable liquid content in it
(TRBZZA, pg. 2951). This is stated specifically by Tressas
•...chemicals that had come in to us that had enough solid
in them that we could not get it out. so we called them
solid drums and put them on Henry's truck.*
(TREZZA, pg. 3049)
Moreover, Tressa was asked specifically!
0. "Were the materials that were put on the trucks
totally solid?"
A. 'There were times when they were not totally solid*
(TRBZZA, pg. 2952)
Although Trezaa testified that he was warned to be careful
what to load, and that it was more economical to dump the
liquid drums into the dumpsters, there is ample evidence that
often the drums were liquid. Specificaly, Beflich testified thats
"...it started out with hard material and then it got
to be all kinds of drums.*
•Well, drums that was in their yard, if there was liquid
in them or they didn't pump them out, they would just
load it on a truck and take them into a landfill.*
Q. "Drums containing liquid material or solid material,
or what?*
A. "Both*
(HBFLICH, pg. 1017)
Beflich also estimated the disposal of drums as 50-100 drums/
load, 4-5 loads per week for the entire time of disposal.
(BBFLZCB, pg. 1019)
George Borden, the general manager of Lone Pine, also
testified as to the nature of the drummed waste, noting that
the drums were different than first plannedt
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•The druu were heavier, harder to pusn, and would
rupture if you hit the* wrong with the blade on
the bulldoier. It was liquid that cane out.*
(BORDBV, pg. 1505)
•It had a strong odor, like paint thinner.*
(BORDBH, pg. 1505)
Additionally, BPA's excavation and drum sampling program
carried oat in the summer of 1981 verified that a number of
drum* contained liquid contents.
The Steering Committee implies in their comenta that
the bulk material taken by Beflich fro» 8CP to Lone Pine
was innocuous. This is not borne out by the evidence.
The bulk Haterial was generated by dumping the liquid druas
of Material into a dumpsterr allowing any solids to settle,
and then siphoning off any aqueous. The material in the
dumpster, while likely to be hazardous in and of itself,
was also likely to be contaminated by contact with the
liquids poured into the dumpster. Furthermore, there is
ample testimony that the 'sludge* was not dry nor innocuous,
but rather had a high moisture content and was highly con-
taminated. Specifically, both Beflich and Tresza testified
as to the nature of the sludge. The material was transported
in sludge boxes that had *a sealed back door on them so that
they could hold and haul liquid material.* (BBPLICB, pg. 960)
Beflich described the material that was put in the dumpsters ast
•sludge that was in the bottom of the drums that
was not burnable and was a noxious material...rest
of it would be dry or sludge that they could not do
nothing more with*
(BBPLICB, pg. 973)
Beflich statedt "It was more of a liquid material than a sludge
material.* (BBPLICB, pg. 1011) Be later added:
•It was difftrtnt at different timts. It was liquid
and sludge. There was some sludge in it, but it got
to be a little bit more liquid.*
(BBPLICB, pg. 1013) /
When asked if the waste changed he responded:
•Not much. Sometimes it would be some sludge in there.
There was a lot of liquid in there.*
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Other testimony indicates that there was not a concerted effort
to dewater the sludge, instead quite the contrary:
•we might have thrown soae (liquids) in, if we felt
the solids could absorb it*
(TR1IIA, pg. 3130)
Borden also testified as to the nature of the material.
•It was a thick, gluey substance, like paint"
"...It snelled like paint*
(BORDBN, pg. 1507)
Finally, there is evidence that at soae point bulk disposal
of liquids occured. Specifically, Heflich testified that liquid
waste and tank trailers went to the landfill. (BBFLICR, pg. 1020)
•We brought liquid material into the landfill.* (HBPLICB, pg. 1021)
and
•it was an industrial waste and it was a non-flammable
•aterial* (BBPLICB, pg. 1022)
As to volume, Heflich again indicated that roll-offs would
be taken from SCP to Lone Pine 4 to 5 times a week over the entire
period of disposal.
•'In summary, it is clear that Lone Pine was used for the
disposal of large quantities of drummed waste and also large
volumes of bulk waste. These drums contained both liquids
and solids. The sludges were likely to be highly contaminated
due to contact with the drummed liquids and also had a high
moisture content, at times being as much a liquid as a solid.
Therefore, there is ample evidence that the Lone Pine Landfill
contains a large volume of highly contaminated material and
represents a continued source of contamination.
2. BPA's Alleged Failure to Examine Records Gathered Under
the Grand Jury Subpoena in Newark, New Jersey (1983 Com-
ments, pages 2 and 9)
EPA representatives have carefully examined these records under
the provisions of a disclosure order granted by a U.S. District
Court judge.
3. Alleged Pailure of BPA to Contact Additional Companies or to
send Out Additional Notice Letters (1983 Comments, page 1)
Between December 1983 and July 1984 BPA has sent letters to
to an additional one- hundred and thirty-five companies requesting
information about the disposal of hazardous substances which
may have ended up at Lone Pine. Notice Letters were sent out
before the commencement of the Remedial Investigation and Feasi-
bility Study, and additional letters affording private parties
an opportunity to perform design and remedial work at the site
were mailed to potentially responsible parties on September 12,
1984.
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4. Cost Calculation! (1983 Comments, page 13)
In a letter, dated December 15, 1983, a copy of the basic design
criteria and coat estimates for the surface seal and drainage
swales was sent to Randy Nott, counsel to the Lone Pine Steering
Committee hereinafter, ("Steering Committee"), in a letter,
dated Nay 1, 1984, EPA solicited the views of the Steering
Committee on these cost estimates. No response was provided.
In December 1983 CDN backup materials were made available, in
Boston, Massachusetts and were reviewed by representatives of
the Steering Committee.
5. Compliance With the National Environmental Policy Act
and opportunity tor Input from Public (1983 Comments.
pages 13-15 and 1984 Comment*, pages 1 613)
EPA policy is set forth in the September 1, 1982 Nemorandurn
entitled, "Applicability of Section 102(2)(C) of the National
Environmental Policy Act CNEPA*) of 1969 to Response Actions
ander Section 104 of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980.* (A copy of that
aolicy is attached.) The agency's procedures in this case
are a functional equivalent of the HEPA process and the record
establishes that EPA has fully considered environmental impacts
:ȣ the alternatives and mitigative measures. Adequate opportu-
nity for public comment has been afforded. Comments were
ormally solicited in June 1983 and from June 27 to August 1,
984, and two formal public meetings were held during these
eriods. The Steering Committee erroneously refers to "three
eeks of notice* in the 1984 Comments.) EPA has also held five
eetings with representatives of the Freehold Township Lone
ine Landfill Technical Review Committee, and EPA officials have
..et with representatives of the Steering Committee on Nay 11,
983, January 19, 1984, January 30, 1984, and June 27, 1984.
he charge that the Steering Committee has not had access to
PA information is misleading. Representatives of the Steering
Committee have examined EPA files and obtained copies of docu-
ments. Sampling results have been delivered to the Steering
Committee on an on-going basis, and CDN files in Boston have
seen made available to and reviewed by the generators. "Simu-
ations" and ether information requested by the companies have
een provided. BPA flew COM representatives to Mew York to
Answer questions posed by the Steering Committee in a meeting
m January 30, 1984. Subsequently. EPA provided The Steering
Committee with written answers (including supplementary materials)
to the questions. BPA and CDN representatives have also been
at the two public meetings. BPA has solicited the views of the
Steering Committee at different dates without response.
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6. Compliance with the National Contigency Plan (1984 Comments
pages 5 and 8);
The Steering Committee suggests that SPA is not complying with
the Rational Contingency Plan CNCP"). No citations are provided,
and in one case reference is made to sending changes which have
not been finalized or even proposed in the Federal Register
yet. BPA has complied with the NCP, including provisions on
source control remedial actions at 40 CFR 300.68. The agency's
actions are consistent with the Congressional goal of protecting
public health and the environment.
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JOHN f RENNA
C3MMISSIONIN
STATE OF NEW JERSEY
DEPARTMENT OF COMMUNITY AFFAIRS
DIVISION or LOCAL GOVERNMENT SERVICES
363 WEST STATE STREET
CN803
TRENTON. N.J. 04825
August 20, 1984
Joel Singerman, Project Manager
Hazardous Waste Site Branch
Environmental Protection Agency
26 Federal Plaza, Room 402
New York, NY 10278
BE:
State Review Process
SAI: NJ 8 4-9022
Applicant: Joel Singeman, Project Manager, Hazardous Wste Site Branch, E.P.
A., 26 Federal Plaza, Room 402, New York, NY 19278 212-264-9589
Detailed Dglfsa-r0* Recommended Remedial Solution for Lone Pine Landfill
Direct Development Activity
Pursuant to the system developed in New Jersey for the inter-
governmental review of application* for Federal financial assistance
and direct development acitivities, the above referenced project .has been
submitted to the State Review Process and:
No comments have been received from reviewing agencies.
X Comments from the agencies identified on Page 2 have been
received and are transmitted herewith.
Should you have any questions, pleaae do not hesitate to
contact us at 609/292-9025.
Sincerely,
Nelson S. Silver, P.P.
Administrator
Urban Assistance Unit .
for the Single Point of Contact
State Review Process
Attachment 6 - State Review Process
061884
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