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

-------
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

-------
16.   Abstract
     Key Words:   Ground Water Treatment,  Slurry Wall,  Source  Control,
                 PRP Alternative,  Ground  Water  Contamination,  Off-Site Plume
                 Control

-------
                         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-

-------
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-

-------
                        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.

-------
                              - 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.

-------
                              - 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

-------
 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

-------
             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

-------
                              -  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).

-------
                              - 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)

-------
                              - 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.  !

-------
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.

-------
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.

-------
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.

-------
                              - 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

-------
                               - 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.

-------
                              - 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

-------
                                 i
                              '^4t-:^>.: r    !
 r^V .>  to-^x i
 CY."':A\V,-   /

      -     ''  A  V "'
      r v     / \  v.
 ^  K'-    J ^     ' \   \
 '^  >-- -"-    >  | ^
         •7
                          -'«v/.
         ."^
             (J
                         /^
                      r«^
                                                '^.
              .««:
J
             ^
*
                                  **-?
        :\
\h\
 V,
                                                     \
r

1
                                                      .;

                                   TURKEY SWAMP
                MW^WWOO  ,•   /  / ."    WILDLIFE    (

                LONE PINE V  / / /MANAGEMENT AREA
                                  ?>TO;
                       \,' *
                       v&
           &:)&
           ..>=/ S\l-
                                                     <0

      «k—

   ;^ > '-.-o^  H88WP**  "U«s
    * .-  S- -* **•] S I       '    I ^	'  T^
  .. V- • * V 's/' s    *4»:     « .'  » "\
  ,   «•«  *y/ <-—i*'*.f? i     *,---.  vfj

    *$**-»f:-i&: .-.^ '-ra
   •V
                      *y
                              ^-^

                              :,^
                                              TURKEY
Sm^JnaSTS!"" "• US°9 AOeLPMIA-NJ OUADRANGLEI75 MINUTE SERIES, ,957. PHOTOREvlsED «e,(

                               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.

-------
                              - 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.

-------
                              - 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.

-------
                              - 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.

-------
                               - 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.                    !

-------
                               -  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.

-------
                               - 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.

-------
                              - 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.

-------
               VtHIICM- SCALE
                     ' <*0
                     1N)f>
EXTRACTION UELL

    CONTAINMENT
 _. •.'.•  •  .      . •'   -.- •   • •.•.
-------
                              - 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.

-------
                              - 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.

-------
                               - 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.

-------
     _                         - 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.

-------
                              - 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.

-------
                                             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."

-------
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.

-------
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.

-------
   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.

-------
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.

-------
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.

-------
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.

-------
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.

-------
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.

-------
 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.

-------
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.

-------
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.

-------
                  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,

-------
       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.

-------
           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.

-------
  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.

-------
      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.

-------
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.

-------
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.

-------
 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.

-------
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.

-------
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.

-------
 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

-------
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.

-------
      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

-------
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.

-------
               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.

-------
     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

-------
      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

-------
     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

-------
     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.

-------
HOTUi tut* MMM Mtait* tfMt tht oxmlai
                                             14

-------
                                        < I
                                        < t
                                              < I
                                                         < t
              •U tfttt *• tfMMlCBl WM Ml
fe •
€ •
                                               L.".
                                              IS

-------
(tj
                                           < I
                                                 < t
                                                        < s
                                                                                                        ••$~ •-*•'
                                           w

-------
               TAME S

MASS SUMMARY . FOR LOME PINE SINUUTIONS
            (•II IN K«>
HUH
EP1NE2
RIA9
R2A9
R3A9
R4A9
R1A1
JI2AI
•Ml
RIA2
R2A2
R3A2
R1A3
•2A3
H3A3
R4A3
R1AS
R2AS
R3A&
R4AS
R1AR
R2A8
R3AM
R4A8
R1F4
R2F4
R3F4
RIM
R2R4
R3M
B4M
(10)
(*)



(5)


(S)


(*)



(»)



(5)



(»)


(SI


i
V
GfN

—
»
•
•
180
180
180
—
•
•
180
180
180
180
3M
3fO
360
Ml
•
.
.
-
400
400
400
—
„
.
-
fOTAL
MASS
IR
2.28KI
1.14317 ,
I.I43E7
I.I43E7
I.I43E7
„
.
•
^
.
•
m
.
•
'• . -
m
.
.
-
• .
.
.
-
.143E7
.I43E7
.143E7
.I43C?
.143E7
.143C7
.I43C7
ms$
DUMPED

-
^
.
.
-
1.403C*
C.560E4
9.M2E3
—
,
•
1.9IUC*
7.I4/E5
2.SU7E&
7.2ME4
3.02CE6
1.04IE6
4.24IES
1.43IE5
—
—
.
-
7.I67E6
9.7ME6
9.7S3E6
„
.
.
-
	 T3TC 	
MASS
NASS KENUVEO
NIVER 
1.04SC7 1.04SE7
8.924E6 8.924E*
1.026E7 1
I.09IE7
1.148C7 1
1.22SE6 2
8.S33E4 1
I.7ME4 i
2.1S2C6 2
S.407ES '
1.M9E&
1.3MCC
5.444E5
l.MMES <
8.229C4
4.428E5
3.72IE& 1
5.774E4 <
2.273C4
7.644E*
2.14IE6 i
7.227E&
3.43SES ;
1.42IE* I
1.6S1E6
1.S70E6
7.633E* 1
9.3021k i
I.018E7 1
I.I23E7
1.026E7
I.091E7
I.I48E7
J.628E*
1.509E5
S.722E4
MS2E«
i.407E5
1.069ES
l.278Eft
l.2M£«
I.087E&
I.S49E5
I.469E6
1.4I3E*
I.8IHC6
I.6S8ES
F.644E6
M4IE6
r.227Eb
I.43SES
I.SSBEi
1.14IE7
I.132E7
'.«33E«
>.302E«
.018E7
I.123E7
NASS
REMAINING
I.222C7
1.472E7
I.M8E7
I.MOE7
».*3b£7
1.860ES
3.S06E4
7.840E3
*.724£S
1.318Eb
2.4WE4
3.I48EC
l.OlOEt
3.CI9ES
1.IME6
2.757CC
9.353ES
2.907CS
8.8I4E4
3.M3Ei
1.3MC*
C.33HS
2.89K&
1.374E7
1.3ME7
1.370E7
1.S88E7
1.800E7
1.924E7
1.943E7
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


-------
          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.

-------
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.

-------
   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.

-------
 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.

-------
     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

-------
      •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.*

-------
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.

-------
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.

-------
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.

-------

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

-------