United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-85/016
September 1985
Superfund
Record of Decision
Goose Farm, NJ
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
1. REPORT NO.
EPA/ROD/R02-85/016
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Goose Farm, NJ
5. REPORT DATE
September 27, 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHORIS)
I. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
16. SUPPLEMENTARY NOTES
16. ABSTRACT
The Goose Farm site is located approximately two miles northeast of the Town of
New Egypt in Plumsted Township, Ocean County, New Jersey. The Goose Farm was used as
a hazardous waste disposal site from the mid 1940's to the mid 1970's by a manufacturer
of polysulfide rubber and solid rocket fuel propellant. The majority of wastes were
dumped into a pit dug through the fine sand. The dimensions of the pit were approxi-
mately 100 x 300 x 15 feet. Lab packs, 55 gallon drums, and bulk liquids were dumped
into the pit. Investigations have found contaminated soils containing volatile, acid
and base/neutral organic pollutants throughout the disposal area. In addition, samp-
ling shows contamination of ground water up to 570 ppm total priority pollutants and
contamination of the surface water up to 1100 ppb total volatile organics.
The recommended remedial alternative for this site is expected to be implemented
in a phased manner. First, the contaminated soil and ground water underlying the
site will be flushed. The ground water will be recovered using a well-point system
and will be treated onsite prior to reinjection into the soil. Following soil flushing
and ground water recovery and treatment, extensive testing will be conducted to de-
termine the need to cap the site. In addition, during and after soil flushing and
ground water recovery and treatment activities, extensive testing will be conducted to
determine the extent of PCB contamination in the former drum pit area. Test data will
(see separate sheet)
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Record of Decision
Goose Farm, NJ
Contaminated Media: soil, gw, sw
Key contaminants: vOGs/ toluene,
ethylbenzene, trichloroethylene (TCE)
PCBs
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108
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SUPERFUND RECORD OF DECISION
Goose Farm, NJ
Abstract - continued
determine the need to remediate PCB-contaminated soil. If such remediation is
deemed necessary, a supplementary Record of Decision will be prepared. Total
capital cost for the selected remedial alternative is estimated to be $3,014,000
with no O&M costs.
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Record of Decision
Remedial Alternative Selection
Site
Goose Farm, Plumsted Township, New Jersey
Documents Reviewed
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Goose Farm site.
- Goose Farm Remedial Investigation Report and
Feasibility Study (RI/FS), Elson T. Killam
Associates, Inc., July 1985;
- Staff summaries and recommendations.'
- Responsiveness Summary dated September 1985.
Description of Selected Remedy
1. Flush the contaminated soil and groundwater underlying
the site. The groundwater would be recovered using a
wellpoint system and treated on-site prior to reinjection
into the soil. Currently, it is estimated that recovering
and flushing ten pore volumes will be required to remove
the mobile contaminants from the soil and groundwater.
Pilot studies to be conducted during design will optimize
the required treatment system components.
2. Following soil flushing and groundwater recovery and
treatment, conduct an extensive testing program to
determine the need to cap the site.
3. During and after soil flushing and groundwater recovery
and treatment activities, conduct an extensive testing
program to determine the extent of PCB contamination in
the former drum pit area. Based on this program, determine
the need, if any, to remediate PCB-contaminated soil.
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 flushing of the contaminated soil in conjunction with
groundwater recovery and treatment, evaluating the need to
cap the site, and testing for PCB contamination in the drum
pit area constitute the selected remedial alternative for the
Goose Farm site.
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I have determined that implementation ;of this alternative
will provide protection of public health, welfare and the
environment. The State of the New Jersey has been consulted
and agrees with the proposed remedy.
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. Flushing of the
contaminated soil and recovery and treatment of underlying
groundwater in conjunction with evaluating the need to cap
the site and testing for PCB contamination in the drum pit
area is more cost-effective than other remedial action
alternatives, and is necessary to protect public health,
welfare and the environment.
f
Date ' Cnristopher TJ} Dagoett
Regional Administrator
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Summary of Remedial Alternative Selection
Goose Farm
Plumsted, New Jersey
Site Location and Description
The Goose Farm site is located approximately two miles north-
east of the Town of New Egypt in Plumsted Township, Ocean
County, New Jersey. The site lies approximately one mile
north of the intersection of county routes 528 and 539.
Both solid and liquid hazardous wastes in bulk, 55 gallon
drums, 5 gallon pails and lab packs were disposed of at the
four acre site.
The site which has been previously excavated contains little
natural revegetation and is gently sloped. The site is
located adjacent to a pine/oak forest and a small stream
which flows north into Lahaway Creek. A vicinity map and
site location map are presented in Figures 1 and 2, respectively.
Site History
The Goose Farm was used as a hazardous waste disposal site
from the mid 1940's to the mid 1970's by a manufacturer of
polysulfide rubber and solid rocket fuel propellant. The
majority of wastes were dumped into a pit dug through the
fine sand. The dimensions of the pit were approximately
100 by 300 and 15 feet deep. Lab packs, 55 gallon drums,
and bulk liquids were dumped into this pit.
In January 1980, during an investigation of pesticide
contamination of local potable wells, the Plumsted Township
Sheriff's office informed the New Jersey Department of
Environmental Protection (NJDEP) of the existence of the
Goose Farm site as well as several other disposal sites in
the area. From February to June 1980, the NJDEP conducted
an investigation of the site. The investigation included
the installation and sampling of 17 monitoring wells, and
metal detection and resistivity surveys. The results of this
work indicated that a contaminant plume originated in the
waste pit area and migrated north toward a nearby stream.
During the next phase of the investigation the NJDEP installed
and sampled 34 additional wells. The data indicated that a
contaminant plume less than 140 feet wide and approximately
35 feet deep, which is the approximate depth of a cemented
sand seam encountered in the Vincentown Formation, underlays
the site.
In September 1980, the NJDEP proceeded with remedial
activities at the site in an attempt to eliminate the dis-
charge of contaminants to the nearby stream. Approximately
5,000 containers of waste were removed from the waste pit
area as well as an estimated 9,000 gallons of bulk liquids.
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These wastes were disposed of off-site. Another component
of the cleanup included the installation of a wellpoint
collection and spray irrigation system downgradient of the
disposal area and upgradient of the stream. The wellpoint
collection system created a central hydrologic drain of
groundwater through recovery headers, thus preventing further
contamination of surface water by contaminated groundwater
seepage.
Following the collection and treatment of groundwater, the
effluent was sprayed on the surface downgradient of the main
recovery header, and reinjected in the ground, thereby creating
a reverse flow of groundwater to further contain the plume.
A second spray irrigation system was located north of the
disposal pit to handle additional flow, in March 1981, the
operation of this flushing and treatment system was terminated
after treatment of approximately 7,800,000 gallons of contaminated
water.
A final component of past remedial activities included the
excavation of contaminated soil. Following testing of the
soil, approximately 3,500 tons were classified as grossly
contaminated. This soil, and an additional 12 drums of PCB
waste, were transported off-site for disposal.
In September 1982, EPA approved the NJDEP Cooperative Agreement
Application for the Goose Farm site. Federal funds in the
amount of $189,000 were provided to complete RI/FS for the
site. Subsequently/ the State procured Elson T. Killam
Associates to undertake the work necessary to complete the
RI/FS.
Effectiveness of Initial Remedial Activities
The groundwater recovery and treatment system at the Goose
Farm site commenced operation on September 17, 1980. A total
volume of 7,800,000 gallons of contaminated groundwater was
treated prior to cessation of cleanup activities on March 20,
1981. Approximately 200 wells were installed to recover
groundwater and reinject treated water in two pneumatic
systems used during site cleanup. The groundwater treatment
system included the following unit operations:
- vapor scrubbing to remove volatile organics
- sedimentation with polymer addition for heavy metal
removal
- carbon adsorption
- effluent aeration
During the treatment plant operation, total organic carbon
(TOO was used to monitor the contamination. The NJDEP
established an effluent criterion of 100 mg/1 of TOC for the
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system. In February 1981, a 21 day treatment plant study was
conducted in which analyses of additional chemical compounds
were performed. The results of this study indicated that the
treatment system was virtually 100 percent effective in
removing both toluene and benzene. However, methylene chloride
removal was poor (approximately 60 percent). In order to
remediate this problem, effluent aeration was added to the
overall treatment system. The total organic removal efficiency
during the evaluation averaged approximately 50 percent. Due
to the lack of comprehensive data during the six months of
operation of the treatment plant, a detailed evaluation of
the effectiveness of the treatment system cannot be performed.
Due to limited data, it is difficult to assess the overall
impact on groundwater recovery and treatment operation. Many
of the monitoring wells sampled in 1980 have been destroyed.
However, a comparison of the limited data from previous sampling
events and samples obtained during the remedial investigation
field activities was included in the remedial investigation
report. The general trend in concentrations of specific
volatile organic contaminants seems to be downward. This can
be considered to be a result of the previous remedial action
undertaken at the Goose Farm site.
Site Geology
The Goose Farm site is located in the Atlantic Coastal Plain
physiographic province. This province is characterized by
unconsolidated deposits consisting of alternating layers of
clay, silt, sand, and gravel that outcrop in parallel
northeast-southwest striking lands and dip gently to the
southeast. Surficial deposits at the site are of the Kirkwood
formation. The Kirkwood, in turn, is underlain by the
Manasquan and Vincentown formations.
The Rirkwood formation is composed of a lower dark silty
layer and upper sandy layer in the outcrop area. Downdip the
formation consists of thick clay and sand beds. The Rirkwood
is the most developed aquifer in Ocean County, primarily in
the coastal area.
The Manasquan formation consists of upper fine sand to clay
and a lower glauconitic clay. This formation is not considered
an important aquifer in Ocean County.
The Vincentown formation consists of an upper calcite-clay
and sand member and a lower glauconitic sand member. It is
utilized by typically low yielding domestic wells in its
outcrop area.
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Underlying the Vincentown are the Hornerstown sand, Red Bank
sand, Neversink, Mount Laurel sand, Marshalltown formation,
Englishtown formation, Merchantville formation, Woodbury
clay, and the Raritan and Magothy formations.
REMEDIAL INVESTIGATION ACTIVITIES AND RESULTS
Remedial Investigation Activities;
The remedial investigation of the Goose Farm site included
the following activities undertaken by the State's consultant
Elson T. Rillam and Associates.
- Collection of ten soil samples obtained from soil borings
drilled in the former disposal area and. priority
pollutant analyses plus 40 tentatively identified
compounds (TICs) of all samples.
- Drilling of two monitoring wells in the Vincentown
formation and priority pollutant analyses plus 40 TICs
of the two samples obtained from these wells.
- Collection of one leachate sample and priority pollutant
analyses plus 40 TICs of this sample.
- Collection of one sediment and two surface water
samples obtained from the adjacent stream and priority
pollutant analyses plus 40 TICs of these samples.
- Collection of six potable well samples from private
wells downgradient and in the vicinity of the site
and priority pollutant analyses plus 40 TICs of all
samples.
- Collection of five samples from existing monitoring
wells and priority pollutant analyses plus 40 TICs
of all samples.
These investigative activities were supplemented by work
performed by Wehran Engineers, a consultant for the Morton-
Thiokol Corporation. This work included installation of
additional monitoring wells, collection of groundwater and
subsurface soil samples, and priority pollutant analyses of
all samples. This work was supervised by the NJDEP staff.
The results of the remedial investigation work conducted on
the Goose Farm site indicated that significant levels of
groundwater contamination and soil contamination remain at
the site.
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Soil Contamination
Laboratory analyses of subsurface soils indicated that
significant levels of soil contamination remain in the disposal
pit area. The size of the contaminated area is estimated to
be 15,500 square yards. The depth of the contamination
generally ranges from the surface to twelve feet.
Contaminated soils contain volatile, acid and base/neutral
organic priority pollutants along with non-priority organic
pollutants in all fractions. Volatile contaminants such as
toluene, ethylbenzene, methylene chloride and trichloroethylene
were detected in high concentrations, with toluene measured
up to 640 ppm.
Other non-volatile organic priority pollutants found in the
acid and base/neutral fractions included: Bis (2-chloroethoxy)
methane, bis (2-chloroisopropyl) ether and PCB-1254, with
concentrations up to 160 ppm.
Priority pollutant and non-priority pollutant polynuclear
aromatic hydrocarbons (PAHs) were detected in numerous soil
samples. The physical properties of these PARs include very
low solubility in water and low vapor pressure, both indicating
low mobility and high resistance to biodegradation.
Overall, the highest'levels of compounds were found between
zero and 12 feet below the surface in the 15,500 square yard
area considered contaminated. The soil concentrations outside
this area are generally under 0.1 ppm total priority pollutants,
Significant portions of the highly contaminated area contain
concentrations of priority pollutants greater than 100 ppm.
During the initial remedial activities contaminated soil was
excavated from the drum pit area. The highly contaminated
soil was transported off-site for disposal while the less
contaminated soil was redeposited in the pit.
Groundwater and Surface Water Contamination
Analyses of groundwater and surface water at the Goose Farm
site shows that contamination of groundwater up to 570 ppm
total priority pollutants and contamination of the surface
water up to 1100 ppb total volatile organics currently exists.
Groundwater (including leachate) and surface water around the
site contain high levels of volatile organic contamination.
Toluene, acrylonitrile, benzene, methylene chloride, 1,2-
dichloroethene and trichloroethylene were detected at high
levels. Appendix B shows the concentration of each contaminant.
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Potable water samples collected from wells approximately
2,000 feet downgradient of the site showed low levels of
volatile organic contamination. Nethylene chloride was
detected in levels up to 17 ppb, however, this compound was
also detected in trip blank samples. Another volatile,
1,1,2,2-tetracloroethylene was detected at 23 ppb in one
potable well. This chemical was not detected in any other
samples obtained at the site.
Establishing Remedial Objectives
The evaluation of the results of the remedial investigation
provided the basis for establishing remedial action objectives.
The objectives for the Goose Farm site include, source control
as well as prevention of contaminant migration.
Remedial action objectives for source control are used to stop
the spread of contamination at the source. The area of
contaminated soil around the former disposal pit area is
considered the source. Once contamination leaving the former
disposal pit area is controlled, more effective remedial
actions for migration control can be implemented.
The remedial action objectives for source control set for
the Goose Farm site are noted below:
j
- Remove, treat or contain contaminants
- Control general migration pathways
- Control release of volatile compounds in air
- Control water infiltration
- Control soil erosion
- Control direct contact
The principal objective in management of migration is to
mitigate the potential contamination of potable water supplies,
A secondary goal of migration management is to prevent the
movement of contaminants to other areas where exposure to
these compounds through direct contact may occur.
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Screening of Remedial Action Technologies
For the Goose Farm site, the candidate general technologies
developed in response to the established remedial objectives
include:
- Containment
- Collection and on-site groundwater treatment
- In situ treatment
- On-site disposal
- Off-site disposal
These general technologies can be further defined as follows.
- Containment; capping, grading, revegetation, diversion of
surface run-off, groundwater barriers (both vertical and
horizontal)
- Collection and Treatment of Groundwater; wellpoints, deep
wells, recharge, biological, physical/chemical treatment
- In-Situ Treatment; hydrolysis, oxidation, reduction, soil
aeration, solvent flushing, neutralization, polymerization,
permeable treatment beds, chemical dechlorination.
- On-Site Disposal; construction of a RCRA landfill, excavation,
backfilling
*
- Excavation and Off-Site Disposal; excavation followed by
off-site landfilling, incineration
Prior to evaluating complete alternatives, some of the technologies
were screened out on the basis of cost, waste compability,
time required to achieve goals, unproven technology or other
considerations. The technologies that were eliminated and
the reasons for elimination were as follows:
- Collection and Treatment of Groundwater; deep wells are more
costly than wellpoints, and the depth of the confining layer
is such that deep wells are not required.
- In-Situ Treatment; Neutralization and polymerization are not
appropriate due to the chemical make-up of the waste.
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Remedial Alternatives
Following the screening of remedial technologies, eight remedial
action alternatives were developed. A description of these
alternatives, their present worth cost and their effectiveness
in meeting the established remedial objectives are discussed
below. Appendix A includes a cost comparison of alternatives
as well as a brief description of the advantages and dis-
advantages of each alternative.
Alternative 1
This alternative involves the off-site disposal of 62,000
cubic yards (CY) of contaminated soil, with regrading and
revegetation. The plume recovery and treatment system would
require 1,200 linear feet of header piping with 120 wellpoints.
The recovered plume water would be treated via clarification
and activated carbon, and its effluent reinjected into the
soil. Treatment of ten pore water volumes was estimated to
be needed to remove the mobile contaminants from the soil and
groundwater. The present worth cost of this alternative is
$45,326,400.
This alternative would be effective in controlling the source
material and preventing the migration of contaminants. It
also attains applicable and relevant Federal public health
and environmental standards.
Alternative 2
This alternative involves limited off-site disposal of 10,000
CY of contaminated soil, with soil flushing and groundwater
recovery and treatment to remove the remaining pollutants in
the remaining 52,000 CY of contaminated soil and in the under-
lying contaminated groundwater. The recovered water will be
treated via clarification and activated carbon and its effluent
reinjected into the soil. It was estimated that extraction
of ten pore volumes of water would be required to remove the
mobile contaminants from the soil and groundwater. The
groundwater recovery system would require 800 linear feet of
header, and 80 wellpoints. The present worth cost of this
alternative is $9,451,600.
This alternative would be effective in controlling the source
material and preventing the migration of contaminants. It
also attains applicable and relevant Federal public health
and environmental standards.
Alternative 3
For this alternative, an on-site landfill would be constructed
for the encapsulation of 62,000 CY of contaminated soil. The
landfill would be constructed in accordance with current RCRA
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requirements. The landfill would have a double lined bottom
with leachate recovery and would be sealed along the top.
The groundwater plume would be recovered via a wellpoint
system, treated via clarification and activated carbon and
discharged. It was estimated that treatment of ten pore
volumes would be required to remove the mobile contaminants
from the aquifer. The total present worth cost of this
alternative is $3,303,600.
The implementation of this alternative would be effective in
controlling the source material and preventing the migration
of contaminants. This alternative attains applicable and
relevant Federal public health and environmental standards.
Alternative 4
This alternative would not require any soil excavation. A
soil flushing and groundwater recovery system consisting of
800 linear feet of header piping, 80 wellpoints, and two
pumps would be constructed and operated for approximately 18
months. This duration represents flushing, recovering and
treating ten pore volumes. The recovered water would be
treated via clarification and activated carbon, and reinjected
into the soil. Following the soil flushing and groundwater
cleanup, an evaluation would be made of the need to cap the
site to minimize the migration of any residual contaminants.
The estimated total present worth cost of.this alternative is
$2,814,500.
The implementation of this alternative would be effective in
controlling the source material and preventing the migration
of contaminants. This alternative attains applicable and
relevant Federal public health and environmental standards.
Alternative 5
No excavation would be required for this alternative. A soil
flushing and groundwater recovery system consisting of 800
linear feet of header piping, 80 wellpoints, and two pumps
would be constructed and operated. Nutrients and oxygen
sources would be added to the soil to enhance the cleanup.
Since the nutrients might enhance the treatment system's
efficiency, it is expected that less than 10 pore volumes of
flushing and recovery would be required. The recovered plume
water would be treated via clarification and activated carbon,
and reinjected into the soil. Following the soil flushing
and groundwater cleanup, an evaluation would be made of the
need to cap the site to minimize the migration of any residual
contaminants. The estimated present worth cost or this
alternative is $2,814,500.
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The implementation of this alternative would be effective in.
controlling the source material and preventing the migration
of contaminants. This alternative attains applicable and
relevant Federal public health and environmental standards.
Alternative »6
For this alternative, the contaminated soil would be contained
in-place. Slurry walls would be constructed around the area
of contaminated soil. The bottom of the contaminated area
would be sealed via grouting. To encapsulate the contaminated
soil, a clay cap would be constructed on top. The groundwater
plume would recovered via a wellpoint system, treated via
clarification and activated carbon and discharged. It is
estimated that treatment of ten pore volumes would be required
to remove the contaminants from the aquifer. The present
worth cost of this alternative is $18,534,100:
This alternative would be effective in the short-term for
controlling the source material and preventing the migration
of contaminants. However, since the integrity of the grout
seal is uncertain, this alternative cannot be considered an
effective long-term remedial action. As such, alternative
does not attain applicable and relevant public health and
environmental standards, but would reduce the present threat
posed by the site.
Alternative 17
^MM^^^^»W»_««««B^^MM^ J
For this alternative, soil flushing would be performed to
remove the mobile contaminants from the soil. Water would be
injected into the soil to create a flushing action. The
contaminated water would be recovered via a shallow wellpoint
system, treated via clarification and activated carbon and
reinjected. It is estimated that treatment of ten pore
volumes would be required to remove the mobile contaminants
from the soil. The present worth cost of this alternative
is $1,521,800.
This alternative would be effective in controlling the source
material. However, since no remediation is recommended for
the contaminated groundwater, migration of contaminants would
still be possible. Therefore, this alternative does not
attain applicable and relevant Federal public health or
environmental standards.
Alternative 18
This alternative, referred to as "No Action", does not include
any remediation measures for the site. However, it does
include a long-term monitoring program for the groundwater
underlying the site. Approximately 30 groundwater samples
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per year would need to be obtained and analyzed for priority
pollutants monitor the water quality of the groundwater. The
present worth cost of this alternative is $603,300.
Enforcement
The State of New Jersey and EPA have identified Morton -
Thiokol Inc. as a potentially responsible party. A Cost
Recovery Action has recently been filed by EPA in an attempt
to recover monies spent on the initial cleanup measures and
the remedial investigation and feasibility study. Currently,
the State of New Jersey is negotiating with Morton-Thiokol
for the long term remedial clean-up of the site. These
negotiations are expected to continue until after this Record
of Decision is formally executed.
Evaluation of Alternatives
Alternative 1 includes excavation of soil and off-site disposal
of all contaminated soil as well as groundwater remediation.
This alternative meets the goals of preventing the migration
of contaminants and controlling the source material. However,
this alternative is far more costly than the other effective
alternatives, and provides only a slight/ if any, additional
benefit compared to other less expensive alternatives.
Therefore, excavation to background, in this case, is not
cost-effective. In the National Contingency Plan, cost-effective
is described as the lowest cost altternative that is technically
feasible and which effectively mitigates and minimizes damages
and provides protection of the public health, welfare and the
environment. Based on the above, this alternative is not
recommended as the remedial action.
Alternative 2 includes partial soil excavation and off-site
disposal in conjuncti6n with soil flushing, groundwater
remediation and evaluation of the need for site capping.
This alternative would be effective in controlling source
material and preventing the migration of contaminants.
However, the present worth cost of implementing this altern-
ative would be three times more than other effective altern-
atives. Therefore, this alternative was eliminated from
consideration.
Alternative 3 includes construction of an on-site RCRA landfill
for disposal of contaminated soil and groundwater remediation.
Although this alternative would be effective in the short
term in controlling the source material and preventing
migration of contaminants, its long term reliability would be
doubtful. Many of the characteristics of the site make the
location of a RCRA landfill inappropriate. For example, the
predominant geology is sandy type soil with a rapidly flowing
-------
-12-
aquifer close to the surface. Due to these factors and the
fact that the cost of this alternative is slightly higher
than others, this alternative was eliminated from consideration.
Alternative 4 includes soil flushing, groundwater remediation
and further evaluations for site capping and PCS remediation.
Alternative 5 is similar; however, its soil flushing would be
enhanced using in-situ biological methods. Both of these
alternatives would be effective in controlling the source
material and preventing further migration of contaminants.
However, the use of nutrients in Alternative 5 could make
this alternative more complex from an operational standpoint
.than Alternative 4. Both of these alternatives have a present
worth cost estimate of $2,814,500. Pilot studies would be
performed during the design phase to determine the effectiveness
of each of the two soil flushing options and treatment options.
Alternative 6 includes the construction of an in-place
containment system, to encapsulate the contaminated soil, and
groundwater remediation. This alternative would be somewhat
effective in meeting the remedial objectives. The cost of
this alternative is estimated to be $18,534,000. This cost
is far greater than other alternatives considered to be
more effective in controlling the source and preventing
further migration of contaminants. Therefore, this alternative
is not recommended as the remedial action.
Alternative 7 includes soil flushing to remove the mobile
contaminants. Water'would be injected into the soil via
shallow wells, thus creating a flushing action. The water
would be recovered, treated and reinjected into the soil.
Therefore, this alternative would not be effective in controlling
the migration of contaminants.
Alternative 8 is the "No Action" alternative and would include
long-term monitoring of the groundwater. Obviously, this
alternative would not meet the established remedial objectives
of controlling the source material and preventing migration
of contaminants. The implementation of the "No Action"
alternative will not prevent further migration of pollutants
from contaminated soil remaining on-site. Furthermore,
exposure to the public of these contaminants at near surface
locations will not be eliminated. For these reasons, and
since this alternative would not provide adequate protection
of public health, welfare and the environment, it was eliminated
from consideration.
Recommended Alternative
According to 40 CFR Part 300.68 (J), cost-effective is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and
minimizes damages and provides protection of public health,
welfare and the environment. A cost comparison of remedial
-------
-13-
alternatives is presented in Appendix A. Evaluation of
the remedial alternatives leads to the conclusion that
Alternative 4 is the most cost effective alternative that
achieves the established remedial objectives. Figure 3
shows a layout of the proposed remedial action.
This alternative includes the construction of 800 linear feet
of header piping and 80 wellpoints to be used in a groundwater
recovery and soil flushing system. The recovered water from
the system would be treated via clarification and activated
carbon prior to being reinjected to the soil. Currently, it
is estimated that the soil flushing and groundwater recovery
system would require 18 months of operation. This duration
represents flushing, recovering and treating approximately
ten pore volumes. Continuous sampling will be performed
during soil flushing and groundwater remediation operations.
If a steady state of contamination removal is achieved prior
to the recovery and treatment of ten pore volumes, the Soil
Contamination Evaluation Methodology (SOCEM) model or a similar
model will be used to evaluate whether alternate concentration
limits are appropriate.
The SOCEM model is a simplified procedure used for character-
izing the threat that contaminated soil may pose to groundwater
at hazardous waste sites. Its methodology assists the user
in determining the percent reduction in soil contaminant
concentrations (i.e. source strength) required to achieve
appropriate health based water quality levels at a groundwater
receptor.
During the design phase, pilot studies will be performed to
optimize the operation of the flushing and treatment system.
These tests may include use of nutrients and oxygen sources.
The results of these pilot studies may indicate that the
addition of nutrients and oxygen sources can reduce the
number of pore volume flushes necessary to remove the
contaminants from the the soil and groundwater, as suggested
by Alternative 5. If so, they may be used in the remedial
action, if their use is determined to be cost-effective.
Another component of the remedial action includes testing for
PCB contamination in the former drum pit area. This testing
will be performed prior to, during, and after the soil flushing,
groundwater recovery and treatment operation. The results of.
the PCB testing will be used to determine if any additional
remediation is required. If such remediation is deemed
necessary, a supplementary Record of Decision will be prepared
that will clearly delineate selected additional remedial
actions.
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-14-
The final component of the cleanup will include an evaluation
of the need to cap the site. This determination will be made
after testing the soil upon completion of the soil flushing
program and evaluating the properties of residual contaminants
The actual design of the cap, if needed, will be based on the
Hydrologic Evaluation of Landfill Performance (HELP) model or
a similar model.
The HELP model is a two dimensional hydrologic model of water
movement across, into, and through landfills. The model
provides an approximation of leachate which may be generated
at the site under specified conditions. The model accepts
climatologic, soil, and landfill design input data. The
model takes into account such variables as surface storage,
runoff, infiltration, percolation, evaporation, soil moisture
storage and lateral drainage.
Although long-term monitoring will be required, the extent of
such monitoring has not yet been determined. After the final
supplemental remedial action decisions have been made (i.e.
potential capping and PCB remediation) a long-term monitoring
program will be finalized.
Cost Summary of Recommended Alternative
Remedial Measure Total Cost
Component Present Worth
1. Soil flushing $1,171,000
and treatment
2. Groundwater 994,000
recovery and
treatment
3. Engineering and
Contingency 649,000
4. Additional PCB
Soil Testing and
Cap Evaluation 200,000
TOTAL $3,014,000
Community Relations
A public meeting was held by the New Jersey Department of
Environmental Protection (NJDEP) on February 7, 1984 to
discuss the initiation of a Remedial Investigation/Feasibility
Study (RI/FS) for the Goose Farm site. Notification of the
meeting was accomplished through press releases sent to all
newspapers listed in th Goose Farm Community Relations Plan
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-15-
and mailings to all parties listed in the "Contacts" section
of the plan. An information package, including an agenda,
fact sheet, overview of the community relations program at
Superfund hazardous waste sites, and the steps involved in a
major hazardous waste site cleanup, was given to all attendees
at the beginning of meeting. The meeting was attended by
approximately 30 people in addition to the local township
officials and NJDEP representatives. After the initial
presentation by the contractor, E.T. Killam, the meeting was
opened for public discussion. A summary of the questions
and responses is included in the Responsiveness Summary.
A second public meeting was held by NJDEP on August 16, 1984
to discuss the results of the RI/FS at Pijak Farm and Spence
Farm and the status of the RI/FS at Goose Farm. Notification
of the meeting was accomplished through press -releases sent
to local newspapers and mailings to local and state officials,
as well as to NJDEP's list of concerned citizens. An information
package including the agenda and fact sheet was handed out to
all attendees as they entered. Approximately 30 people
attended. When the meeting was opened to general discussion,
there were only a few questions asked specifically about
Goose Farm. Several questions that are generic to these
three Plumsted Township Superfund sites were also posed at this
meeting. A discussion of questions and responses are included
in the Responsiveness Summary.
A third public meeting was held by NJDEP on July 25, 1985 to
discuss the results of the RI/FS at Goose Farm. Notification
of the meeting was accomplished through press releases sent
to local newspapers and mailings to local and state officials,
as well as to NJDEP's list of concerned citizens. The Draft
Feasibility Study was available for public review and comment,
beginning on July 26, '1985, at four repositories: the Ocean
County Library in Toms River, the Plumsted Township Municipal
Building, the New Egypt Library and NJDEP's Hazardous Site
Mitigation Administration in Trenton. There was a 30-day
public comment period. An information package including the
agenda and fact sheet was handed out to all attendees as they
entered. Approximately 40 people attended. The results of
the remedial investigation were presented and the remedial
action alternatives for long-term site remediation.
NJDEP and their consultant, tentatively recommended that
in-situ soil flushing and groundwater remediation be the
selected alternative. The meeting was then opened for discussion
during which time there were several questions posed by local
officials and concerned citizens. These questions and responses
are summarized in the Responsiveness Summary.
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-16-
Only one public comment was received from Archer & Greiner,
attorneys for Morton-Thiokol. This letter included a
substantive critique of E»T. Killam's methodologies and
proposal for site remediation. The contents of their letter
and the NJDEP response have been considered in this Record of
Decision. These documents have been included in the Responsive-
ness Summary.
Consistency With Other Environmental Laws
The soil flushing and groundwater recovery and treatment
operation will require obtaining an NJPDES permit from
the New Jersey Department of Environmental Protection (or
technical compliance with permit requirements) for the
discharge of the treated effluent. The proposed treatment
system will be designed to meet the effluent limits established
in the discharge permit. Following the completion of the
soil flushing and groundwater remediation, an evaluation
will be made to determine the need, if any, to remediate PCB
contaminated soil. Should it be determined that PCB excavation
and removal is required, the waste will be manifested for
transport from the site to a secure facility in accordance
with RCRA and TSCA requirements. The final component of the
remedial action may include the construction of a cap over
the site. This cap would be designed using the HELP or a
similar model.
Operable Units
The recommended remedial alternative includes distinct
individual components. Therefore, it is expected that the
remedial action will proceed in a phased manner. The initial
phase will include obtaining soil samples from the disposal
pit area and testing for PCB contamination. Testing will also
be performed during and after the soil flushing and groundwater
recovery and treatment-operation. An evaluation of the
results of this testing will determine the extent of further
remediation if any, for PCB hotspots. Any PCB remediation
would follow the groundwater and soil remediation. Finally,
an evaluation will be made to determine the need to cap the
site to minimize the migration of any residual contaminants.
If determined to be necessary, the cap could be designed
using the HELP model or any similar model. Soil samples will
be collected before, during and after the soil flushing and
groundwater treatment phase. The analyses of these samples
will be used to calibrate and run the model.
Operation and Maintenance
Upon completion of the recommended remedial action, monitoring
of the site will be conducted to evaluate the quality of the
local groundwater.
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-17-
Future Actions
Schedule Date
- Final Record of Decision September 1985
- Continue negotiation with
potential responsible parties September 1985
- Obligate Design Funds
(if necessary) Pending CERCLA
Reauthorization
- Amend Cooperative Agreement Pending CERCLA
(if necessary) Reauthorization
- Initiate Remeidal Action Design Pending CERCLA
Reauthorization
-------
APPENDIX A
ALTERNATIVE COMPONENT
1.
2.
3.
Excavation and Disposal
(62,000 CY)
Site Regrade/Revegetate
Plume Pump/Treatment
Engineering/Contingencies „
Total Alternative 1
Excavation and Disposal
(10,000 CY)
Soil Flush and Treat
(12 mo)
Site Regrade/Revegetate
Plume Pump/Treatment
Engineering/Contingency
Total Alternative 2
On-Site Landfill Cons true-
CAPITAL
33,480
392
994
10,460
45,326
5,400
651
225
994
2.181
9,451
1.264
tlon With Post Closure Care
4.
Plume Pump/Treatment
Engineering/ Contingency
Total Alternative 3
Soil Flush/Treat (18 mos)
Plume Pump/Treatment
Engl neer 1 ng/Cont 1 ngency
994
678
2.936
1.171
994
649
ALTERNATIVE COMPARISON
TOTAL
COSTS (1,000) PRESENT
ANNUAL O&M WORTH
33,480
392
994
10.460
45,326
5,400
651
225
994
2,181
9,451
39 1,631
994
- 678
3.303
1.171
994
649
ALTERNATIVE
ADVANTAGES
Complete Removal
Low Technology
Restores land
to use.
Lower Cost
No transporta-
tipn.
No off-site
landfill.
Lower Cost.
Low Cost. Less
Disposal volume
(carbon sludges)
ALTERNATIVE
DISADVATA6ES
High cost
Potential spills
In removal.
Potential losses
from landfill.
Use of landfill
capacity.
Potential spills
Potential land-
fill losses.
Residuals on site
Use of landfill
capacity.
Potential loss
from fill.
Permanent loss
of land use.
Permanent loss
of some land
uses. Residual
PNA's.
Total Alternative 4
2.814
2.814
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APPENDIX A
ALTERNATIVE COMPONENT
5. In-S1tu Biological Soil
Treatment
In Place Encapsulation
Slurry Wall
Capping, Revegetatlon, etc
Base Grouting
Plume Pump/Treatment
Englneer1ng/Cont1ngenc1es
Total Alternative 6
7. Soil Flush and Treat
(18 DOS)
Engineering/Contingency
Total Alternative 7
8. No Action/Monitoring
Total Alternative 8
ALTERNATIVE COMPARISON
COSTS (1,000)
CAPITAL ANNUAL O&M
Same Costs As Alt. 4
H
262
:. 123 52.1
12.500
994
4,164
18.043
1,171
351
1,522
64
64
TOTAL
PRESENT
WORTH
262
614
12.500
994
4.164
18,043
1,171
^351
1.522
603
603
ALTERNATIVE
ADVANTAGES
Destruction of
Biodegradable;.
Less Landfill
volume required.
Least loss of
Land Use off site
Lower Cost than
Alt. 4
•
None
ALTERNATIVE
DISADVATAGES
Residual PNA's
Permanent loss
of some land
uses.
High cost. *
Permanent loss
of land use.
Risk of Landfill
failure.
Longer period
until clean
surface water.
Cannot be
Implemented.
-------
APPENDIX B
TABLE 1
VOLATILE ORGANIC POLLUTANT SUMMARY
SURFACE AND GRQUNDWATER
Shallow
Wall
Compound Average(*)
Hethylene
Chloride
Benzene
Toluene
Trans 1,2
Dichloroethylene
Trichloroethylene
Acrylonitrile
167,675
3,258
3,243
28
63
1053
Upstream Downstream
Surface Surface
Leachate
6,300
12,000
2,200
440
310
BDL
Water
10
BDL
BDL
BDL
BDL
BDL
Mater
1,100
. BDL
BDL
• 19
14
BDL
Potable
Water
Values
17
11
6.5
BDL
BDL
BDL
BDL
BDL
* Value of zero used on samples below detection limit for average calculations.
BDL » Below Detection Limits
All concentrations in parts per billion
-------
new ro*x
GOOSE FARM
SITE
oerj* _
-------
Hfe*" *^M
LKw.^jLN/*1 v-. P^S^-^t^X''^: :
^^^EcTP^r^-O \!.: .j
VICINITY MAP
FIGURE 2
GOOSE FARM
FtUMSTEO TOWNSHIP, NEW JERSEY
SCALE: 1" • 2.000*
SOURCE: UtS.G.S. TOPO MAPS
t KKUm A«^»d«U«, inc. f"|
**** •i+Hi*t*te &&»** I I
-------
4
\bjtj ;j AREA OF CONTAMINATED SOIL
/VtA ESTIMATED PLUME
FIGURE 3
GOOSE FARM
PLUMSTED TOWNSHIP, NEW JERSEY
RECOMMENDED ALTERNATIVE H
Elton T. KMIam Associates, Inc.
.-xnt^l >nd Mydramic
Di
-------
RESPONSIVENESS SUMMARY:
Completion of Feasibility Study
Goose Farm
Plumsted Township
Ocean County
New Jersey
-------
Responsiveness Summary:
Completion of Feasibility Study
Goose Farm
Plumsted Township
Ocean County
A public meeting was held by the New Jersey Department of Environmental
Protection (NJDEP) on February 7, 1984 to discuss the initiation of the Remedial
Investigation/Feasibility Study (RI/FS) for the Goose Farm site. Notification of
the meeting was accomplished through press releases sent to all newspapers listed
in the Goose Farm Community Relations Plan and mailings to all parties listed in
the "Contacts" section of the plan. An information package, including an agenda,
fact sheeti overview of the community relations program at Superfund hazardous
waste sites, and the steps involved in a major hazardous waste site cleanup, was
given to all attendees at the beginning of the meeting. (See attendance sheet,
Attachment A.) The meeting was attended by approximately 30 people in addition
to the local officials and NJDEP representatives. (See Attachment B.) After the
initial presentation by NJDEP's contractor, E.T. Killam, the meeting *?as opened
for discussion.
There were three questions asked by citizens with regard to sampling activities
and one question about the aquifer underlying the site. These questions and
responses were as follows:
Q: Have polychlorinated biphenols (PCBs) been found on site?
Yes, PCBs have been found at Goose Farm.
*
Q: Will you test for changes at Goose Farm since the cleanup from two
years ago?
NJDEP sampled the site in January 1983; however, results were not
conclusive.
Q: What are you testing for when you sample ground water?
The full spectrum of contaminants, i.e. 129 known priority
pollutants plus 40 unknown pollutants.
Q: Will you give out maps of the aquifers underlying the site?
A. Farro stated that these maps would be included in the Draft
Feasibility Study which would be available upon its completion.
In addition, G. Singer wrote to one concerned citizen to inform
him that the shallow aquifer probably flows in a south-southeast-
erly direction, discharging into a nearby stream and marsh. Data
indicating the direction of flow for the deeper aquifer would be
available upon completion of the Feasibility Study.
Iditional questions or comments during this first meeting were not of major
significance.
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-2-
A second public meeting was held by NJDEP on August 16, 1984 to discuss the
results of the RI/FS at Pijak Farm and Spence Farm and the status of the RI/FS at
Goose Farm. Notification of the meeting was accomplished through press releases
sent to local newspapers and mailings to local and state officials, as veil as to
NJDEP1s list of concerned citizens. An Information package including the agenda
and fact sheet was handed out to all attendees at the beginning of the meeting.
(See Attachment C.) Approximately 30 people attended. (See attendance sheet,
Attachment D.) When the meeting was opened for general discussion there were only
a few questions asked specifically about Goose Farm. Several questions that are
generic to these three Plumsted Township Superfund sites were also posed at the
meeting. These questions and responses were as follows:
Q: What is the status of the study at Goose Farm?
The field work has been completed and we expect to have data in
approximately two weeks. We should have a public meeting to
discuss the RI/FS at the end of October, 1984.
Q: What direction does the water flow from Goose Farm?
North.
Q: Last time my well was tested, there were traces of mercury detected.
We see traces of mercury all over the state. When we resample,
there's usually no evidence of mercury. We sent the second round
of test samples to a different laboratory and we did not find any
mercury in the, second set of samples.
Q: What is the danger of drinking water with trace chemicals?
It depends on the type of compounds. The drinking water
standards for volatiles are 100 ppb.
Q: What about responsible party pursuit?
There is presently an active case being pursued. It is possible
that there nay still be a private party cleanup.
Q: Has anyone done a history of what Thiokol was dumping?
We have an alleged list.
Q: I'm looking at land in this area. What is the possibility of
additional contamination?
It's a difficult question to answer. This is always a
potentiality but given the amount of testing that has
been done in this area it's highly unlikely.
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-3-
Q: How excessive is excessive and how low is low?
We use these terms based on guidelines that now exist, however,
we don't really know. We don't leave anything b^'iind that may
adversely Impact human health.
Q: Will there be restrictions on land use of these sites (Spence, Pijak,
Goose) after cleanup?
It's possible that these sites could be used again?
Q: Will land owners of these sites be paid or will Superfund buy their
land?
A claim against the New Jersey Spill Fund is a possibility.
Q: Do you recommend a certain well depth that might be pollution free in
the future? Will there be criteria or guidelines for establishing the
best well depth?
NJDEP's Division of Water Resources is looking into this issue
now.
Q: What do I ask for if I want to have my water tested?
This is a critical consumer issue because landowners may have to
pay for this testing in the future. If you think you have a
problem with jour water contact the Ocean County Health Depart-
ment .
Q: Did you change any limits for construction at approximately 1,000 feet
from the sites?
That land use issue has not been addressed by NJDEP. It is a
local issue.
A third public meeting was held by NJDEP on July 25, 1985 to discuss the results
of the RI/FS at Goose Farm. Notification of the meeting was accomplished through
press releases sent to local newspapers and mailings to local and state
officials, as well as to NJDEP's list of concerned citizens. An information
package including the agenda and fact sheet was handed out to all attendees at
the begining of the meeting. (See Attachment E.) Approximately 40 people
attended. (See Attendance sheet, Attachment F.) The contractor (J. Shirk of E.T.
Killam) discussed the results of the RI/FS and presented the following remedial
action alternatives for long-term site remediation:
1. Off-site disposal (removal of 62,000 cubic yards of soil to a RCRA
facility), regrading, revegetation and recovery, treatment and recharge
of contaminated ground water.
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-4-
2. Partial off-site disposal (removal of 10,000 cubic yards of soil), soil
flushing, treatment and recharge for 52,000 cubic yards of soil,
recovery* treatment and recharge of contaminated ground water.
3. On-site construction, monitoring and long-term maintenance of a RCRA
hazardous waste landfill for 62,000 cubic yards of soil, regrading and
revegetation of excavated area, recovery, treatment and recharge of
contaminated ground water.
4. In-situ (in-place) soil flushing with treatment and recharge for
removal of priority pollutants, recovery, treatment and recharge of
contaminated ground water.
5. In-situ soil flushing with treatment and recharge for removal of
priority pollutants, injection of nutrients for in-situ biological
oxidation and recovery, treatment and recharge of contaminated ground
water.
6. Containment of wastes with slurry wall and block displacement
containment, long-term monitoring, recovery, treatment and recharge of
contaminated ground water.
7. In-situ soil flushing with treatment and recharge for removal of
priority pollutants, no plume treatment.
8. No current action except annual monitoring.
The contractor presented Alternative #4 as the recommended alternative.
The meeting was then opened for discussion during which time there were several
questions asked by local officials and concerned citizens. These questions and
responses are summarized below:
Q: Will this land be usable in the future?
*
The Goose Farm site (approximately two acres) will not be usable
for agricultural or residential purposes. Surrounding properties
will not be impacted.
Q: How long will it take the chemicals to decompose?
It depends on the selected alternative. With Alternative #4,
there will be passive usage almost immediately.
Q: What chemicals were found on site?
Solvents in ground water, not many metals, polynuclear
hydrocarbons, PCBs, and non-priority pollutants.
Q: What types of solvents were found?
A mixture of chlorinated and non-chlorinated solvents;
specifically methylene chloride (at 10-100 ppm in soil).
-------
-5-
Q: What about the well serving the house on Goose Farm?
There are no problems with that well. Ground water is moving in a
northwesterly direction.
Q: Is the deep aquifer contaminated?
No contaminants were found in the Mt. Laurel which is very deep
(100-160 feet).
Q: What is the perimeter of the contamination?
Contaminants are migrating toward the stream which seems to be a
cut-off for the upper aquifer (i.e. Kirkwood at 10-20 feet). No
contaminants are migrating west, south or east.
Q: Are all monitoring wells at the same depth?
No, there are deep and shallow test wells.
Q: Is the stream also contaminated?
The portion directly adjacent to the site is contaminated;
however, contaminants have not reached 300 feet downstream.
Q: What is the time frame for site cleanup?
We have already discussed this with the Responsible Party and we
hope the cleanup will be expeditious. After total removal, there
will be a five-year monitoring period. If nothing shows up after
five-years, there will not be further action.
Q: What about fire hazard in the columns, given the high concentrations of
solvents?
This is not likely because the carbon filters will be tested on a
regular basis.
Q: With Alternative 14, can 100Z of the runoff be captured?
Yes.
-------
-6-
The Draft Feasibility Study was made available for public review and comment,
beginning on July 26, 1985, at four repositories: the Ocean County Library in
Toms River, the Plumsted Township Municipal Building in New Egypt, the New Egypt
Library and NJDEP's Hazardous Site Mitigation Administration in Trenton. There
was a 30-day public comment period.
Only one public comment was received (on August 26, 1985) from Archer & Greiner,
attorneys for Morton-Thiokol. This is a substantive critique of E.T. Killam's
methodology and proposals for site remediation, as well as Morton-Thiokol's
recommended approach. (See Attachment G for these comments.) Currently, a
response is being developed by the NJDEP technical staff in conjunction with its
legal staff. This response will be forthcoming upon its completion.
HS82:rlk
Enclosures
-------
Attachment A.
-------
M.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Feasibility Studies for the
Goose Farm, Pijak Farm and Spence Farm
Hazardous Waste Sites
Tuesday, February 7, 198<»
7:30 p.m.
Plumsted Township Municipal Building -
New Egypt, N.J.
Agenda
i. Opening Remarks on Community input in Superfund Program - G. Singer
and introduction of DE? members
4
2. Overview of situation and introduction of contractor, - A. Farro
' Elson ~. Killan Associates, Inc. of Miliburn, N.J.
3. Presentation consultants Elson T. Killam Associates, Inc. - £. Killan
A. Questions and Answers
-------
;-i
State of SCeui Jersey
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
MARWAN M. SAOAT P £ CN 028. Trtnton. N.J. 08625 JQHGt H BEflKOWirz. PH
ADMINISTRATOR
FACT SHEET
FEASIBILITY STUDIES FOR GOOSE FARM, PIJAK FARM, AND SPENCE FARM
(PLUMSTED TOWNSHIP, OCEAN COUNTY)
TO DETERMINE REMEDIAL ACTION ALTERNATIVES
These sites are ail located in Plumsted Township (Ocean County) within
a twenty-square mile area, sections of which have fce-?n used for disposal
cf drur.T.ed and free flowing liquid waste. Investigation, which included
the installation of monitoring wells, has revealed =;uifer, groundwater
and Surface-water organic chemical contamination. Eich of these sites has
been placed on the National Priorities List by the V.3. Environmental
Protection Agency (USErA) and is eligible for Super fur.d money for remedial
action.
• An immediate removal operation has already been completed at the Goose
Farm site. This consisted of the excavation of all containers and several
thousand tons of contaminated soil and debris during the period of August,
i960 to February, 1982. In addition, a water treatment system was installed
to remove gross contamination from the soil and grouniwater. Further investi-
gation is required to evaluate present hydrcgeological conditions and residual
contamination.
The present studies are being conducted by Elscn T. Kiilam Associates,
Inc., environmental and hydraulic engineers of Millburn, New Jersey. Funding
for these projects in the amount of $608,535 ($<»5i,5CO for Pijak Farm and
Spence Farm, $157,035 for Goose Farm) has been provided by the USEPA as
part of the Superfund program.
For 2/7/84 Public Meeting
at Plumsted Township
Municipal Building
New Egypt, N.J.
Jersey Is An Equal Opportunity Employer
-------
FACT SHEET
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
PLUMSTED TOWNSHIP. NEW JERSEY
Remedial Investigations/Feasibility Studies have been started at the
Spence Farm and Pijak Farm Sites east of New Egypt on Route 528. These studies
are being funded by the New Jersey Department of Environmental Protection
(NJDEP) and the U. S. Environmental Protection Agency (USEPA) and managed by the
NJDEP Hazardous Site Administration.
The objectives of the Spence Farm and Pijak Farm investigations and
studies are:
. To determine the location and amount of hazardous materials on site.
. To determine the rate at which hazardous materials are leaving the
site in groundwater, surface water and air.
. To develop alternatives for control of these materials.
*.
. To select the best control methods for the site.
. To prepare.conceptual designs of the selected alternative.
The schedule for these activities is:
. Begin Drilling Monitoring Wells - February 1984.
. Begin Sampling - Groundwater, Soil, Wastes, Surface Water,
Private Wells - March 1984.
. Present Report on Sampling Results • May 1984.
' . Present Report on Possible Alternatives - June 1984.
. Present Selected Plan for Remedial Action - July 1984.
The nature and extent of remedial action for the Spence Farm and Pijak
•h.
Farm sites will be based on the hazardous materials found in the detailed
sampling program.
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NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup of hazardous waste
sites, a Community Relations Program is conducted to receive local input
and to advise local residents and officials about the planned remedial actions
at the three major stages of the cleanup: 1) feasibility study 2) engineer-
ing design and 3) removal/treatment/construction. Local briefings and public
meetings are conducted with elected officials and residents and generally
take place at:
1) The commencement of a feasibility study so that local concerns
can be addressed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial action. There is a 30-day comment period after
public presentation of the alternatives.
3) The engineering design stage to carry out tr.e mandates of the selected
remedial alternative.
4) The commencement of the removal/treatment/construction stage to
advise of the expected physical remedial action.
5) The completion of the remedial action.
In addition to the more formal activities outlined above, there is
generally informal communication with local officials and residents.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the U.S. Environmental Protection Agency (EPA) has the lead in
remedial action at a site, community Delations activity is conducted by
the relevant state or federal agency.
In New Jersey at DEP, the Community Relations Program is conducted
by Grace Singer, Community Relations Program Manager (609) 984-3C81. At
Region II, EPA, the contact person is Lillian Johnson (212) 264-2515.
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STEPS INVOLVED JN_ A MAJOR HAZARDOUS WASTK STTK (M.KAM1IP INVOLVING EPA AND SUPERFUND MONIES
Site Identified
and Referred
(I)
Initial Site Investigation
Secure Site
(3)
Situ Analysis Evaluation
and Assessment
(4)
Prioritization
(5)
Hiring of Contractor
for Feasibility Study
(9)
Hiring of Construction or
Removal Contt.it:tor .uul
Cleanup
(13)
Remedial Action Master Pi.in
and Determination of Lead
(6)
1*1 epur.it ion of t-'ousibil ll.y
Study
(10)
t.'le.nmp liv.i lu.it i«"t
Community Relations
Plan Activated
(7)
Signing of Contract of
Cooperative Agreement
(8)
(M)
Selection of Remedial Hiring of Contractor
Action Alternative for Design
(11) 02)
Contractor Audit and
Close out
(15)
84
-------
Attachment B.
-------
N.J. Departsent of Environmental Protection
Division of Haste Management
Hazardous Site Mitigation Administration
Public Meeting to Oiscuas Feasibility Studies
for Coos* Farm, Pijak Farm and Spence Farm
Hazardous Waste Superfund Sites
PluBsted Townshipf Ocean County, New Jersey
Tuesday, February 7, 198<»
7:30 p.m.
Plumsted Township Municipal Building
31 Main Street
New Egypt, New Jersey
NAME
AFFILIATION
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-------
Attachment C.
-------
MARWAN M. SAOAT. P e
DIRECTOR
State of dmii Jersey
OEPAFt.JENT OF ENVIRONMENTAL PROTECTION
DIVISION Of WASTE MANAGEMENT
HAZARDOUS Si TE MITIGATION ADMINISTRATION
CN 028. Trtnton. N.J. M62S
JORGE M BEPKOwirr *»-
Public Meeting
to discuss
Feasibility Studies
at
Goose Fam, Pijak Farm, and Spence Farm
Thursday, August 16, 1984
7:00 p.m.
Plumsted Township Municipal Building
31 Main Street
New Egypt, N.J.
AGENDA
1.) Opening remarks and
introduction of DEP staff
Dr. Jorge Berkowitz, Administrator
Hazardous Site Mitigation
Administration, NJDEP
2) Overview of current situation
and introduction of contractor
Mr. Dave Henderson, Site Manager
Hazardous Site Mitigation
Administration, NJDEP
3) Presentation: Feasibility
Studies at Goose, Pijak, and
Spence Farms
4) Questions and Answers
Mr. Jim Shirk, E.T. Killam
Associates, Inc.
,V*u- Jtrsey Is An Equal Opportunity Employtr
-------
FACT SHEET
Public Meeting
on
Results of Remedial Investigation/Feasibility Study
at
Pijak Farm
Plumsted Township
Ocean County
August 16, 1984
Site Description!
Background;
Status:
The Fijak Farm site is located approximately 2 miles
northeast of New Egypt, about 1,000 "feet south of
County Route 528, and 1,300 feet vest of Fisher Road.
The contaminated area, covering roughly one acre, was used
for the surface dumping of drums and free-flowing liquid
hazardous waste from around 1962 until the early or
mid-1970's. The site is situated adjacent to
Stony Ford Brook which joins the Crosswicks Creek, a
tributary of the Delaware River. The underlying ground
water aquifers provide a potable water supply for the
surrounding area. Both ground water and soil sampling
have indicated organic chemical contamination.
j
The site was first identified as a waste disposal site by
the New Jersey Department of Environmental Protection
(NJDEP) in February, 1980. In March of that year, NJDEP
recommended the denial of a permit to construct 43
single-family homes on site. Observation wells were
installed by NJDEP in June, 1980. Also in June, several
surface water samples were analyzed. In July, 1981 the
United States Environmental Protection Agency (USEPA)
Environmental Photographic Interpretation Center
completed an evaluation of tine sequential aerial
photography spanning the years 1940-1979. A Cooperative
Agreement between USEPA and NJDEP was signed
in September, 1982 to commit S33C.OOO for a Remedial
Investigation/Feasibility Study (RI/FS). The contract to
conduct the RI/FS was awarded to E.T. Killam Associates,
Inc. of Millburn, N.J. by NJDEP in December, 1983.
A Draft Feasibility Study was completed in August, 1984
and the remedial action alternatives are presently being
evaluated by NJDEP and USEPA. There is a 21-day comment
period, beginning August 17, 1984, during which the Draft
Feasibility Study will be available at the following
repositories: Plumsted Township Municipal Building, Ocea
County Library in Toms River, and the NJDEP,
Hazardous Site Mitigation Administration in Trenton.
Over...
-------
Sunmary of Remedial Investigation/Feasibility Study
Pijak Farm, Plumsted Township
I. Remedial Investigation
A. Scope of Work; The remedial investigation included the following
activities:
. Construction of 11 monitoring veils;
. Excavation of 8 test pits;
. Sampling and analysis of deep and shallow soil samples;
. Sampling and analysis of 5 waste samples; and
. Sampling and analysis of IS ground water, surface water
and sediment samples.
B. Results; The outcome of the remedial investigation indicated that:
. Wastes were disposed of at the site by surface dumping rather
than by burial (except for 4,000 cubic yards of buried
wastes);
. Most waste containers were opened intentionally or have
rusted and the contents dispersed;
. Principal contamination on site is found in waste containers
and soils, although ground water at Monitoring Well 2-S was
found to be cpntaminated;
. Most organic pollutants found were not priority pollutants
(only minor concentrations of priority pollutants were found); and
. Review of available data on toxicity for these non-priority
organic pollutants indicated that the greatest potential for
adverse health>and environmental effects were found in soil
rather than in water.
II. Feasibility Study
The principal remedial objectives were removal of surface wastes,
construction of a temporary dam to control sediment loss, and control of
direct access to the site.
Long Term Recommendations;
. Removal of wastes and contaminated soils;
. Pumping out contaminated ground water at Monitoring Well 2-S;
. Regrading and revegetating the site to eliminate sediment
loss and direct contact with contaminated material; and
. Continue monitoring ground water for volatile priority
pollutants.
NJDEP
O 101.
-------
FACT SHEET
Public Meeting
on
Results of Remedial Investigation/Feasibility Study
*t
Spence Farm
Plumsted Township
Ocean County
August 16, 1984
Site Description;
Background;
Status:
Spence Farm is one of seven "Plumsted" sites in the
vicinity of Ocean and Monmouth Counties. It is located
approximately 1.5 miles northeast of New Egypt in
Plumsted Township. The site is about 750 feet north of
County Route 528 and 7,000 feet east* of Moorehouse Road.
From the 1950's until the early 1970'a, drummed and bulk
liquid waste was disposed of in an on-site lagoon, a swamp
area, as well as sc. -tered locations throughout a 30-acre
low lying wooded area adjacent to two adjoining
tributaries of Crosswicks Creek. Sampling and analysis of
ground water, surface water, and the underlying aquifer
has revealed organic chemical contamination.
Monitoring wells were installed by the New Jersey
Department of Environmental Protection (NJDEP) in June,
1980.' In July 1981, the United States Environmental
Protection Agency (USEPA) Environmental Photographic
Interpretation Center completed an evaluation of time
sequential aerial photography which covered the time
period of 1940-1979. A Field Investigation Team completed
a site evaluation in October, 1981. In March 1981, the
USEPA released a Remedial Action Master Plan for Spence
Farm. On September 30, 1982 the NJDEP entered into a
Cooperative Agreement with the USEPA to commit $320,000
for a Remedial Investigation/Feasibility Study (RI/FS). In
November 1983, NJDEP awarded the contract for the RI/FS
to E. T. Killam Associates, Inc., of Millburn, N.J..
Field work commenced in December, 1983.
A Draft Feasibility Study was completed in August, 1984
and the remedial action alternatives are presently being
evaluated by NJDEP and USEPA. There is a 21-day comment
period, beginning August 17,1984, during which the Draft
Feasibility Study will be available at the following
repositories: Plumsted Township Municipal Building,
Ocean County Library in Toms River, and the NJDEP,
Hazardous Site Mitigation Administration in Trenton.
Over...
-------
Summary of Remedial Investigation/Feasibility Study
Spence Fans, Plumstcd Township
I. Remedial Investigation
A. Scope of Work; The remedial investigation included the following
activities:
. Construction of 15 monitoring wells;
. Excavation of 15 test pits;
. Sampling and analysis of 14 deep and shallow soil samples;
. Sampling and analysis of 6 waste samples;
. Sampling and analysis of 19 ground water, surface water
and sediment samples; and
. Sampling and analysis of 6 potable water supply wells.
B. Results; The outcome of the remedial investigation indicated that:
. Wastes were disposed of at the site by surface dumping rather
than by burial;
. Most waste containers were opened intentionally or have rusted
and the contents dispersed;
. Principal contamination is found in waste containers and soils,
with limited contamination of ground water and surface water;
. Most organic pollutants found were not priority pollutants,
(only minor concentrations of priority pollutants were found); and
. Review of available data on toxicity for these non-priority
organic pollutants indicates that the compounds with the greatest
potential for adverse health and environmental effects were found
in soil rather than in water.
II. Feasibility Study
The principal remedial objectives were removal of surface wastes, con-
struction of a temporary dam to control the loss of sedicent, and control
of direct access to the site.
A. Immediate Recommendation;
. Removal of surface wastes including drums, laboratory packs, and
contaminated soil.
B. Long Term Recommendations;
. Regrading the site to eliminate erosion of less contaminated soils
in order to prevent direct contact with more contaminated
materials; and
Continue monitoring ground water for volatile priority pollutants.
NJDEP
8/84
-------
FACT SHEET
Public Meeting
on
Statue of Remedial Investigation/Feasibility Study
at
Goose Farm
Plumsted Township
Ocean County
August 16,1984
Site Description;
Background;
Status:
Goose Farm is one of seven "Plumsted" sites in the area of
Ocean and Monmouth Counties. The site is located off Route
539, approximately one mile north of the intersection of
Routes 539 and 528. It is immediately adjacent to a
stream which is a tributary of the Crosswicks Creek. Goose
Farm is in a rural, agricultural area at the edge of a
pine/oak forest. During the late 1960's and early 1970's
an excavated portion of the site was used for the disposal
of bulk liquid and drummed wastes. Contamination of soil,
ground water, and surface water at the site has been
documented. The contamination poses a potential threat to
the two shallowest aquifers which underlie the area: the
Kirkwood and the Vincentown formations.
Initial remedial action transpired from August, 1980 until
February, 1982 and entailed the excavation of all
containers, as well as several thousand tons of
contaminated soil and debris. A water treatment system was
installed to remove gross contamination from the soil and
ground water. The New Jersey Department of Environmental
Protection (NJDEP) entered into a Cooperative Agreement
with the United States Environmental Protection Agency
(USEPA) on September 23. 1982 to commit $210,000 for the
performance of a Remedial Investigation/Feasibility Study
(RI/FS). A contract for the RI/FS was awarded by NJDEP to
E.T. Killam Associates, Inc. of Millburn, N.J. in
December, 1983. Site access was secured via a Court Order
and field work was initiated in February, 1964.
The feasibility study is presently underway. The field
work has been completed and included the following
activities: 22 soil borings; construction of 2 monitoring
wells; and sampling of 4 monitoring wells, 6 potable water
wells, surface water, sediment and leachate. The study
is expected to be completed by December, 1984.
NJDEP
8/84
-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state prograa of cleanup at hazardous waste
sites• a Community Relations Program is conducted to receive local input and
to advise local residents and officials about the planned remedial actions at
the three major stages of the cleanup: 1) remedial investigation/feasibility
study 2) engineering design and 3) removal/treatment/construction. Local
briefings and public meetings are conducted with elected officials and
residents and generally take place at:
1) The commencement of a remedial investigation/feasibility study so
that local concerns can be addressed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial action. There is a 30-day comment period after
public presentation of the alternatives during which the feasibility
study is available in local repositories.
3) The engineering design stage to carry out the mandates of the
selected remedial alternative.
4) The commencement of the removal/treatment/construction stage to
advise of the expected physical remedial action.
5) The completion of the remedial action.
In addition to the more formal activities outlined above» there is
generally informal communication with local officials and residents.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a site, community relations activity is conducted by
the relevant State or Federal agency.
In New Jersey, the DEP Community Relations Program is conducted by Grace
Singer, Community Relations Program Manager (609) 984-3141/4892. At Region
II, EPA, the contact person is Lillian Johnson, Community Relations
Coordinator (212) 264-2515.
HS45:ms
5/84
-------
STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Site Identified
and Referred
(5)
Priorltizatlon
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
(6)
Determination of Lead
(10)
Preparation of
Feasibility
Study
(U)
Cleanup Evaluation
(3)
Secure Site
(4)
Site Analysis Evaluation
and Assessment
(7) (8)
Community Relations Signing of Contract or
Plan Activated Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Design
(15)
Contractor Audit and
Close out
New^^raev
Department of Environmental Protection
-------
Attachment D.
-------
N.J. Department of Env ronmentai Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Feasibility Studies
for Goose Farm. Pijak Farm and Spence Farm
Hazardous Waste Superfund Sites
Plumated Tovnship, Ocean County, New Jersey
Thursday, August 16, 1984
7:00 p.n.
Plumsted Township Municipal Building
31 Main Street
Mew Egypt, New Jersey
NAME AFFILIATION . ADDPESS
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AFFILIATION
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N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Feasibility Studies
for Goose Farm, Pijak Farm and Spence Farm
Hazardous Waste Superfund Sites
Plumsted Township, Ocean County, New Jersey
Thursday, August 16, 1984
7:00 p.m.
Plumsted Township Municipal Building
31 Main Street
Mew Egypt, New Jersey
NAME
AFFILIATION
ADDRESS
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-------
N.J. Department of Environmental Protection
Division of Waste Management
Hazardous Site Mitigation Administration
Public Meeting to Discuss Feasibility Studies
for Goose Farm, Pijak Farm and Spence Farm
Hazardous Vaste Superfund Sites
Plumsted Township. Ocean County, New Jersey
Tursday, August 16, 1984
7:00 p.m.
Plumsted Township Municipal Building
31 Main Street
New Egypt, New Jersey
NAME
AFFILIATION
ADDRESS
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-------
Attachment E.
-------
MARWAN M. SAOAT. P E
DIRECTOR
State of Sfeui Jersey
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
CN 028. Trenton, N.J. 06625
JORGE H. 8ERKOWITZ. PH.D.
ADMINISTRATOR
Public Meeting
to discuss
Feasibility Study Results
for
Goose Farm
Thursday. July 25, 1985
7:00 p.m.
Plumsted Township Municipal Building
31 Main Street
New Egypt, NJ
AGENDA
1. Opening remarks and
introduction of DEP staff
2. Overview of current status
and introduction of contractor
3. Presentation: Remedial Action
Alternatives for Goose Farm
4. Questions and Answers
Dr. Jorge Berkowitz, Administrator
Hazardous Site Mitigation Administration
NJDEP
Mr. David Henderson, Site Manager
Hazardous Site Mitigation Administration
NJDEP
Mr. James Shirk
E. T. Killam Associates, Inc.
New Jersey Is An Equal Opportunity Employer
-------
FACT SHEET
Public Meeting
on
Results of Remedial Investigation/Feasibility Study
at
Goose Farm
Plumsted Township
Ocean County
July 25. 1985
Site Description;
Background;
Status:
Goose Farm is one of seven "Plumsted" sites in the area of
Ocean and Monmouth Counties. The site is located off Route
539, approximately one mile north of the intersection of
Routes 539 and 528. It is immediately adjacent to a stream
which is a tributary of the Crosswicks Creek. Goose Farm is
in a rural, agricultural area at the edge of a pine/oak
forest. During the late 1960s and early 1970s» an excavated
portion of the site was used for the disposal of bulk liquid
and drummed wastes. Contamination of soil, ground water, and,
surface water at the site has been documented.
Initial remedial action transpired from August, 1980 until
February, 1982 and entailed the excavation of all containers,
as well as several thousand tons of contaminated soil and
debris. * A water treatment system was Installed to remove
gross contamination from the soil and ground water. The New
Jersey Department of Environmental Protection (NJDEP) entered
into a Cooperative Agreement with the United States
Environmental Protection Agency (USEPA) on September 23, 1982
to commit $210,000 for the performance of a Remedial
Investigation/Feasibility Study (RI/FS). A contract for the
RI/FS was awarded by NJDEP to E.T. Killam Associates, Inc. of
Millburn, NJ in December, 1983. Site access was secured via
a Court Ordtr and field work was initiated in February, 1984.
A Draft Feasibility Study was completed in July, 1985 and
the remedial action alternatives are presently being
.evaluated by NJDEP and USEPA. There is a 30-day public
comment period, beginning July 26, 1985 during which the
Draft Feasibility Study will be available at the following
repositories: Plumsted Township Municipal Building, New
Egypt Library, Ocean County Library in Toms Rivers, and the
NJDEP, Hazardous Site Mitigation Administration in Trenton.
Over...
-------
-2-
Goose Farm
Summary of Feasibility Study Results
Following is « brief description of the remedial action alternatives for
long-term site remediation.
Alternative 1: Off-site disposal (removal of 62,000 cubic yards of soil to a
RCRA facility), regrading, revegetation and recovery, treatment
and recharge of contaminated ground vater.
Alternative 2: Partial off-site disposal (removal of 10,000 cubic yards of soil),
soil flushing, treatment and recharge for 52,000 cubic yards of
soil, recovery, treatment and recharge of contaminated ground
vater.
Alternative 3: On-site construction, monitoring and long-term maintenance of a
RCRA hazardous waste landfill for 62,000 cubic yards of soil,
regrading and revegetation of excavated area, recovery, treatment
and recharge of contaminated ground water.
Alternative 4: In-situ (in-place) soil flushing with treatment and recharge for*
removal of priority pollutants, recovery, treatment and recharge
of contaminated ground water.
Alternative 5: In-situ soil flushing with treatment and recharge for removal of
priority pollutants, injection of nutrients for In-situ biological
oxidation and recovery, treatment and recharge of contaminated
ground water.
Alternative 6: Containment of wastes with slurry wall and block displacement
containment, long-term monitoring, recovery, treatment and
recharge of contaminated ground water.
*
Alternative 7: In-situ soil flushing with treatment and recharge for removal of
priority pollutants, no plume treatment.
Alternative 8: No current action except annual monitoring.
-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
A Community Relations Program at Superfund Hazardous Waste Sites
As part of the federal/state program of cleanup at hazardous waste
sites» a Community Relations Program is conducted to receive local input and
to advise local residents and officials about the planned remedial actions at
the three major stages of the cleanup: 1) remedial investigation/feasibility
study 2) engineering design and 3) removal/treatment/construction. Local
briefings and meetings are conducted with elected officials and residents and
generally take place at:
1) The commencement of a remedial investigation/feasibility study so
that local concerns can be addressed early in the process.
2) The completion of a feasibility study to discuss the alternative
courses of remedial action. There is a 30-day comment period after
public presentation of the alternatives during which the feasibility
study is available in local repositories.
j
3) The engineering design stage to carry out the mandates of the
selected remedial alternative.
4) The commencement of the removal/treatment/construction stage to
advise of the expected physical, remedial action.
5) The completion* of the remedial action.
In Addition Co tht activitits outlined above, there is generally
ongoing communication with local officials and residents as required.
Depending upon whether the New Jersey Department of Environmental Protection
(DEP) or the United States Environmental Protection Agency (EPA) has the lead
in remedial action at a site, community relations activities are conducted by
the relevant State or Federal agency.
In New Jersey, the DEP Community Relations Program is directed by Grace
Singer, Chief, Office of Community Relations (609) 984-3081. At Region II,
EPA, the contact person is Lillian Johnson, Community Relations Coordinator
(212) 264-2515.
HS45:js
4/85
-------
STEPS INVOLVED IN A MAJOR HAZARDOUS WASTE SITE CLEANUP
(1)
Site Identified
and Referred
(5)
Prlorltiz tlon
(9)
Hiring of Contractor
for Remedial Investi-
gation/Feasibility
Study
(13)
Hiring of Construction/
Removal Cleanup
Contractor
(2)
Initial Site Investigation
.(6)
Determination of Lead
(10)
Preparation of
Feasibility
Study
(U)
Cleanup Evaluation
(3)
Secure Site
(7)
Community Relations
Plan Activated
(4)
Site Analysis Evaluation
and Assessment:
(8)
Signing of Contract or
Cooperative Agreement
(11) (12)
Selection of Remedial Hiring of Contractor
Action Alternative for Engineering Design
(15)
Contractor Audit and
Close out
-------
Attachment F.
-------
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
Public Meeting to Discuss Results of
Remedial Investigation/Feasibility Study
at
GOOSE FARM
PLUMSTED TOWNSHIP
OCEAN COUNTY
JULY 25, 1985
7:00 P.M.
NAME
AFFILIATION
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Attachment G.
-------
ARCHER & GREINER
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COUNSELLORS AT LAW
ONE CENTENNIAL SQUARE
P.O. BOX 3OOO
HAODONFIELD. N. J. O8C. --O968
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OCX 60» 79S-OS74
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August 26, 1985
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ATLANTIC CITY OFFICE
SUITE 207
1 1 29 ATLANTIC AVCNUC
ATLANTIC CITY. N.J. O8401
6O9-347
Dr. Jorge Berkowitz
New Jersey Department of
Environmental Protection
Division of Waste Management
E. Hanover Street
nton, New Jersey 08628
A v/
Re: Morton Thiokol, Inc. - Goose Fara
.. ^—v*
Dear Dr. Berkowitz: '
Enclosed are Morton Thiokol's (MTI) comments on the Goose
Farm RI/FS as prepared by AWARE Incorporated. As you know, these com-
ments have been prepared and produced within thirty days, and therefore,
may need further amplification and discussion. Nonetheless, in that
short period of time, AWARE Incorporated has identified many glaring
.deficiencies in the State contractors' (TRIA) reports. Among these are:
1. Failure to establish guideline performance standards for
the remedial actions. With no target, it is impossible
to understand what TRIA was attempting to achieve.
2. The chosen alternative has no technical basis in fact for
the duration of time the alternative is to be operated.
As a result, the cost is unquestionably wrong and other
alternatives are the lower cost solution.
3. Other unconsidered alternatives, such as on-site contain-
ment by slurry walls and minimum groundwater pumping,
appear to be better ultimate solutions.
These and other technical issues are discussed in the attach-
ht. We note that the State's draft report also found fault with our
previously provided Goose Farm study as performed by Wehran Engineering.
,.>
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Dr. Jorge Berkowitz
Page Two
August 26, 1985
Each of the problems noted are explicitly covered in the Wehran report
and we are left to wonder if the State's contractors ever saw the
finished report. In addition, a telephone call would have resolved
many of the concerns raised.
MTI has evaluated other remedial paths without any guidance or
agreement from NJDEP as to acceptable residual levels or which chemicals
found are of greatest significance. We desire to discuss with your
office this issue as well as the advantages of the alternatives we have
independently evaluated. Perhaps after understanding our respective
positions, MTI will be in a position to consider undertaking the ulti-
mate remedy at this site.
As you know, MTI has in good faith proceeded with these
extensive activities even though MTI is a defendant in litigation filed
by the State involving this very site. We hope that a similar good
faith review of our client's submission wj^ll result in substantial re-
consideration by the State of its own contractors' reports. We stand
feady to meet with appropriate state representatives in order to address
any of these issues, and because of our ongoing litigation, we submit
these comments and the attached report without prejudice to any of
MTI's existing rights.
Very truly yours,
EDWARD C. LAIRD
ECL:jas
End.
-------
consultants in environmental manaa*mcnt
August 21, 1985
Edward C. Laird, Esq.
Archer & Greiner
One Centennial Square
Haddonfield, New Jersey 08033
RE: Initial comments on Goose Farm RI/FS
Dear Ed:
The attached report contains our initial comments on the Remedial
Investigation/Feasibility Study completed for the Goose Farm site by NJDEP's
consultant, TRIA.
The most striking feature of the RI/FS is its failure to diligently search out
a truly cost-effective remedial option for the Goose Farm site. Furthermore,
it is a markedly unquantitative RI/FS which has resulted in selection of a
remedial alternative which can not stand up to detailed technical scrutiny.
The attached report also contains our initial thoughts concerning more
appropriate remedial options for the Goose Farm site. Development of these
alternative remedial options is only preliminary at this juncture, yet even at
this level of evaluation, it is clear that these containment-based
alternatives are worthy of further consideration.
If you have any questions on the attached report, please do not hesitate to
contact us.
Very truly yours,
AWARE Incorporated
Robert D. Mutch, Jr., P.HG., P.E.
Vice President
/cs
Encl.
cc: A. Slesinger
80 Airport Road • Wast Milford. Maw Jersey 07480 a Phone (201) 728-1940
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TABLE OF CONTENTS
Page
Letter of Transmittal
1.0 INTRODUCTION 1
2.0 GENERAL COMMENTS ON THE RI/FS 2
3.0 SPECIFIC COMMENTS ON THE RI 4
4.0 SPECIFIC COMMENTS ON THE FS 7
4.1 Absence of Quantitative Remedial Objectives 7
4.2 Evaluation of Recommended Remedial Alternative #4 8
4.2.1 Technical Evaluation 8
4.2.2 Cost Evaluation 15
4.3 Evaluation of Remaining TRIA Remedial Alternatives 16
4.3.1 Technical Evaluation 16
4.3.2 Cost Evaluation 18
j
5.0 Preliminary assessment of Other Remedial Options 21
5.1 Description of Additional Alternatives 23
5.2 In-Situ Biological Treatment Applications 26
6.0 Conclusions 27
LIST OF TABLES
Following
Page
Table 1 - Estimated Retardation Factors (R) for Principal Goose Farm
Contaminants 12
Table 2 - Estimated Construction Cost of Alternative No. 4 15
Table 3 - Cost Estimate, RCRA On-Site Landfill 19
Table 4 - Alternative No. 9, Construction Costs 24
Table 5 - Alternative No. 10, Construction Costs 25
Table 6 - Comparative Analysis of Selected Goose Farm Remedial Options 27
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1.0 INTRODUCTION
A remedial investigation/feasibility study (RI/FS) has been completed for the
Goose Farm site in Plumsted Township, New Jersey. The RI/FS was undertaken by
a consortium of three consultants under contract to the New Jersey Department
of Environmental Protection, Division of Waste Management, Hazardous Site
Mitigation Administration. The consortium performing the work is termed TRIA
and consists of Elson T. Killam and Associates, Inc. (ETK), Geomet
Technology, Inc. (GTI), and Leggette, Brashears and Graham, Inc. (LBG).
Elson T. Killam acts as prime contractor for the project. The work of TRIA is
embodied in three documents:
1. Draft II, Task 2-Remedial Investigation, Volume 1 - Main Report, July 12,
1985
2. Draft II, Task 2-Remedial Investigation, Volume 2 - Appendix A, June 1985
3. Draft II, Feasibility Study, July 12, 1985
AWARE Incorporated has been retained by Morton-Thiokol to review the Goose
Farm RI/FS and to comment on its adequacy, its thoroughness, and the.
reasonableness of its conclusions and cost estimates. In performing this
evaluation, a number of other documents have also been consulted. These
include the following:
t
1. Wehran Engineering, Supplemental Investigation of the Goose Farm Site, May
1985
2. Wehran Engineering, Analytical Results, Groundwater Monitoring Wells,
Goose Farm Site, March 1985.
3. Wehran Engineering, Analytical Results, Soil Samples - Volume 1, Goose
Farm Site, March 1985
4. Wehran Engineering, Analytical Results, Soil Samples - Volume 2, Goose
Farm Site, March 1985
5. Wehran Engineering, Analytical Results, Soil Samples - Volume 3, Goose
Farm Site, March 1985
6. Wehran Engineering, Analytical Results, Soil Samples - Volume 6, Goose
Farm Site, March 1985.
7. FMC Aquifer Remediation Systems, Site Assessment Report for the Goose
Farms Hazardous Waste Site, June 27, 1985
In addition to the above-referenced reports, AWARE has also reviewed much of
the earlier information developed as part of the past remedial efforts, has
visited the site on numerous occasions, and has participated as a
subcontractor to Wehran Engineering in the preparation of the above-referenced
Wehran Engineering documents.
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2.0 GENERAL COfffiNTS ON THE RI/FS
Without question, the most striking feature of the feasibility study is its
failure to mount a diligent search for a truly cost-effective remedy for the
Goose Farm site. It is this lack of diligence which will run like a thread
through most of the comments contained herein regarding the remedial
investigation/feasibility study of the Goose Farm site. The feasibility study
looks at only eight remedial alternatives for the Goose Farm site, only two
more than the minimum six alternatives mandated by the National Contingency
Plan. Further, the alternative remedial programs are given only a cursory
evaluation and are developed in a purely conceptual manner.
Remedial objectives or performance goals are stated in only the most
conceptual terms. No effort has been made to quantitatively set performance
standards and objectives for the remedial programs. Remedial objectives are
the starting point for a feasibility study. Once set, the feasibility study
becomes an engineering evaluation and search for the most cost-effective way
of attaining those goals. Without quantitative standards, a feasibility study
flounders for lack of direction. The Goose Farm RI/FS suffers from its
failure to set performance objectives
The remedial investigation is similarly unquantitative. The RI fails to
generate enough new data or to use older data to generate isoconcentration
contour maps depicting contaminant levels on the site. No estimates are made
of the amount of contaminated groundwater in the plume of contamination. No
estimates are made of the amount of groundwater flow within the plume. The
stratigraphy of the site has been largely ignored in terms of its impact on
groundwater flow. Illustrative of this rather casual regard for site
stratigraphy is the indiscriminate grouping of permeability tests regardless
of formation. The consultants failed to differentiate between true soil
contamination and groundwater-borne contamination. No estimates were made of
the degree of retardation of the various contaminants in the groundwater
system. This latter deficiency of the RI/FS is especially critical since the
recommended remedial plan involves soil contamination flushing and plume
recovery and treatment. The retardation factor (R) will dictate the rate of
flushing of contamination from the plume.
It is also perplexing that in a site where soil flushing and groundwater
recovery are recommended why a computer model is not utilized in the
development of feasible remedial alternatives. Even a relatively simple
two-dimensional hydrologic model would be immensely helpful in conceptualizing
and testing various remedial strategies. The place for computer modeling of
groundwater-related remedial options is in the feasibility study, not the
subsequent engineering design. The computer model can not only test out and
evaluate the effectiveness of various groundwater recovery and recharge
options, but can often lead one through trial and error to unusually
cost-effective remedial options. It is believed that the absence of computer
modeling in the Goose Farm feasibility study has been a serious omission.
Failure to develop a quantitative understanding and depiction of hydrogeologic
and contamination conditions at the Goose Farm site has led to the selection
-------
of a remedial alternative which seems incapable of meeting any reasonable set
of performance objectives and certainly not in the time frame projected in the
RI/FS. The remedial plan optimistically envisions an 18-month period of soil
flushing and plume recovery and treatment, after which presumably the aquifer
and site would be sufficiently renovated. As will be demonstrated
subsequently, it is our belief that this plan is seriously flawed for all but
the most relaxed of performance standards. The flaw lies in the fact that the
consultants have assumed that the soil and groundwater contaminants will
either be flushed relatively rapidly from the system, within the 18-month
period, or will be permanently bound up in the.soils. This is an unrealistic
and, in fact, a dangerous assumption. In reality, the Goose Farm soils and
groundwater contain a complex suite of organic and inorganic contaminants
whose retardation factors and, consequently, times of flushing span the
mobility spectrum. By underestimating the complexity of the source, TRIA has
recommended a remedial plan the success of which hinges on relatively rapid
soil flushing and aquifer renovation. As the subsequent calculations will
show, flushing of this aquifer system will not be rapid. In fact, the
calculations indicate that flushing will take not months but many years, even
decades.
TRIA also assumes that treatment can be effected by means of a granulated
activated carbon system. It also appears that this assumption is optimistic
given the character of the soil and groundwater contamination. The probable
inadequacies of a simple GAC plant will be addressed in later sections of this
document.
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3.0 SPECIFIC comorrs ON THE RI
The following specific comments are made regarding Che remedial investigation
portion of the Goose Farm RI/FS. Most of the comments relate one way or
another to the unquantitative nature of the remedial investigation.
1. The RI fails to present an isoconcentration contour map of the plume of
groundwater contamination. An isoconcentration contour map of this type
depicts the distribution of contaminant levels within the plume. The RI
does not even delineate the full spatial extent of the plume. TRIA
states "The areal limits of contaminated groundwater cannot be accurately
defined because of the limited number of samples." (Appendix A, page 41).
It is difficult to fathom why in a remedial investigation of a National
Contingency List site sufficient samples cannot be taken to define at
least the spatial boundaries of the plume, if not the distribution of
contaminants within the plume. It's not a matter of budgetary
limitations since cost-effective analytical plans can be developed
employing a combination of indicator analyses to define the boundaries of
the plume and more specific analyses to define the severity of the plume
(Clarke, 1984).
2. Nowhere in the RI is the total volume of groundwater within the plume
estimated. An indirect reference to plume volur.e is made on page 1-11 of
the feasibility study, although it appears to be in error. TRIA states on
page 1-11 that "Total pollutants may range from 10,000 to 30,000 Ibs. in
groundwater (an average of 20 to 60 ppm total priority pollutants)." This
calculation is based on a total volume of groundwater of 60 million
gallons. Our estimate of the total volume of groundwater in the plume is
approximately 14 million gallons. It seems likely that TRIA neglected to
multiply the volume of the plume by the specific yield in order to obtain
the actual volume of groundwater since the two numbers differ by a factor
of approximately 0.25.
3. No effort was made to estimate the volume of groundwater flow within the
plume. Utilizing TRlA's figures for average permeability and hydraulic
gradient, it appears that the flow in the plume is approximately 8,000
gallons per day.
4. The stratigraphy of the site has been largely ignored in regard to its
impact upon hydrogeologic conditions. An example of this is the way TRIA
indiscriminately groups field permeability tests together, irrespective
of the formation tested. The upper and lower Kirkwood, Manasquan, and
Vincentown,formations have different hydrogeologic properties which have
not been taken into account in the RI. Many of the wells employed in the
field permeability tests are screened across more than one geologic
formation, thereby prohibiting differentiation of individual formation
permeabilities.
5. TRIA failed to differentiate between true soil contamination and
groundwater contamination. In a plume of groundwater contamination, a
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certain amount of contaminant partitioning between gi.undwater an.' the
aquifer skeleton invariably takes place. However, the resultant
contamination of the aquifer skeleton cannot be compared to areas of true
soil contamination where wastes have directly contacted soils, often
coating them with pellicular film of non-aqueous phase liquid (NAPL).
6. The remedial investigation did not consider the mobility of the Goose
Farm contaminants in the groundwater system. Retardation factors for the
Goose Farm contaminants were not estimated. In the case of organic
compounds, retardation factors can be estimated on the basis of organic
content of the aquifer. Determination of aquifer organic content is a
relatively simple and inexpensive analysis which in our judgment should
have been included in the RI. Understanding the retardation of the
principal Goose Farm contaminants would have enabled the remedial
measures to be evaluated with a better conceptual understanding of
contaminant mobility—a critical criteria when aquifer remediation and
soil flushing is being considered.
7. TRIA fails to utilize the Wehran Engineering-generated geologic and
hydrogeblogic data for reasons which are difficult to comprehend. TRIA
states, "First, the geologic information provided for the soil borings.
was insufficient to allow correlation of particular samples and
analytical results to specific geologic formations. It is not known
whether soil or water samples are from the Kirkwood, Manasquan, or
Vincentown formations." The basis for this statement is difficult to
understand since the Wehran Engineering boring logs clearly define the
geologic formation and provide not only a detailed Burmister description
of the lithology but also, where appropriate, geologic information such
as the presence and type of shell fragments encountered.
TRIA also states that "Second, information was not provided about the
geology, drilling, and construction of the monitor wells." As stated
above, information was contained in the Wehran Engineering boring logs
regarding the geology encountered at each boring location. Moreover, the
boring logs clearly show and describe the drilling technique and the
specific nature of the well construction.
TRIA further states that "The formation(s) in which the wells are
screened are unknown." Clearly as indicated above, this is not the case.
TRIA also states that "Third, groundwater samples were analyzed only for
indicator parameters and are, therefore, not able to be directly
correlated with specific contaminants identified by TRIA." It should be
noted that the objective of the Wehran wells was to define the western
boundary of the plume. Therefore, an analytical protocol consisting of
indicator parameters was judged by NJDEP and Wehran to be appropriate.
The fact that the analytical results cannot be "directly correlated with
specific contaminants identified by TRIA" is a moot point. Had TRIA
employed a rational program of indicator analyses in their analytical
program, perhaps the spatial extent of the Goose Farm plume would be
better defined within the TRIA RI.
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TRIA also states that "Lastly, there was no description of sampling
procedure utilized by Wehran in the collection of "samples." Again, this
is not the case for on page 2-4 of the Supplemental Investigation Report
issued by Wehran Engineering, Wehran states that samples were collected
in accordance with established NJDEP approved procedures.
On page 36 of Appendix A of the TRIA RI they state "The background soil
sample collected by Wehran was found to contain a significant level of
contamination. However, no location for the sample was provided which
eliminates the formulation of any useful conclusions." Once again, this
statement is inaccurate since the location of the background soil sample
is shown on Figure 1 of Wehran Engineering's "Supplemental Investigation
of the Goose Farm Site" report dated May 1985.
The State has analyzed for many compounds ("4-40") which are not priority
pollutants. As in previous efforts undertaken by DEP, many of the
nonpriority pollutants detected may not be anthropogenic in origin.
These analyses only further complicate the selection of appropriate
performance standards. We believe the priority pollutant list is an
adequate analytical base for this site.
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4.0 SPECIFIC COtffiNTS ON THE FS
The following more specific comments are offered in connection with the TRIA
Feasibility Study.
&.1 Absence of_ Quantitative Remedial Objectives
The RI/FS fails to set forth quantitative remedial objectives. In the
feasibility study, remedial action objectives for source control are stated as
follows:
"1. Remove, treat, or contain contaminants.
2. Control general migration pathways.
3. Control release of volatile compounds in air.
.4. Control water infiltration.
5. Control soil erosion.
6. Control direct contact."
j
Insofar as management of migration is concerned, the RI/FS states that "the
principal objective in management of migration is to mitigate contamination of
potable water supplies. Secondary goals of migration management are to stop
the general movement of contaminants to other areas which may cause a danger
to public health, welfare or the environment through direct or indirect
contact."
These remedial action objectives do not speak to the degree of control
required at the Goose Farm site. In fact these remedial objectives are not
specific to the Goose Farm site at all, but could apply to any waste disposal
site. Remedial objective #2 calls for control over "general migration
pathways". Nowhere in the RI/FS are the migration pathways quantitatively
evaluated as to their current risk to public health and the environment or, as
important, as to what would be an acceptable level of risk for each pathway.
Table 1-2 of the TRIA RI presents exposure limits for typical Goose Farm
contaminants. It presents the 10" cancer risk and EPA SNARLS for water and
permissable exposure levels for air. The information in this table does not
represent remedial goals. A remedial objective must address not only the
permissable concentration, but where in the system the permissable
concentration must not be exceeded. For example, one remedial objective might
be to maintain water quality in the unnamed stream below some prescribed level
of contamination such as the EPA SNARLS or the 10 cancer risk. Another
remedial objective might be to maintain groundwater quality at certain points
in the aquifer system below these same levels. Remedial objectives of this
type provide a target for the feasibility study to home in on. Given a
quantifiable target, remedial engineers can then evaluate the myriad of
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remedial technologies capable of attaining those remedial objectives. In the
absence of such quantifiable remedial objectives, the feasibility study
flounders for lack of direction. This has clearly been the case in the Goose
Farm RI/FS. Remedial alternatives have been developed along with associated
cost estimates without any definition of the degree to which they are expected
to remediate site conditions. How can an 18-month aquifer renovation period
be estimated without some concept of the acceptable degree of aquifer
remediation which will be required? In short, it can't.
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4.2 Evaluation of_ Recommended Remedial Alternative £4_
The following comments are offered regarding the technical merits and
projected costs of TRlA's recommended remedial program.
4.2.1 Technical Evaluation
As stated earlier, the technical merits of TRlA's Alternative 14 seem
questionable. Its success hinges on what can best be considered the
optimistic belief that the Goose Farm contaminants will fall into one of two
categories: those which will be rapidly flushed from the soils, and those
which will remain permanently bound to the soil matrix. The plan envisions an
18-month period of soil flushing and plume treatment, after which presumably
the highly mobile contaminants will have been flushed from the soil and the
aquifer and the remaining contaminants will remain bound to the aquifer
skeleton.
Although the effectiveness of this option hinges on the rates of contaminant
flushing and aquifer remediation, the RI/FS does not contain even preliminary
estimates of these mechanisms. The sole reference to flushing times mentions
achieving a ten-pore volume exchange of groundwater. The RI made no effort to
measure the aquifer's natural organic content from which estimates of organic
contaminant mobility can be drawn. TRIA has apparently simply guessed at the
amount of flushing required to remove contaminants. As the succeeding
evaluation will indicate, it appears that their unsupported estimate of
flushing times is seriously in error. As a result, the aquifer remediation
and soil flushing project would not be completed in the 18 months contended by
TRIA. Rather, in all likelihood, it would be forced to perate for many
years, even decades, before adequately remediating the aquifer and the soil
contamination.
Naturally, the performance standards established for the aquifer remediation
project will to a large degree dictate how long the system must run. It is
evident that in the absence of concrete performance standards and a reasonable
estimate of contaminant mobility in the Goose Farm soil system, the duration
of the soil flushing and remedial project are indeterminate. Similarly, the
costs of this remedial alternative could correspondingly escalate to the point
of placing it in an unfavorable position with respect to other remedial
alternatives as illustrated in Section 6.0 of this report.
In the following section of this report, a preliminary assessment of the
likely flushing times for various contaminants is undertaken.
Estimates of. Flushing Time
Numerous field and laboratory studies have demonstrated the importance of
adsorption in the transport of organic contaminants through soil and
groundwater systems. Adsorption of a contaminant to soil can occur through a
variety of processes including physical adsorption, chemisorption (formation
of chemical bonds between the material and the soil), hydrogen bonding, and
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10
ion w change. The degree to which a particular contaminant is adsorped in
soil or in an aquifer depends on the nature of the contaminant itself and the
properties of the formation. The degree to which contaminants are retarded in
their migration in groundwater systems is a critical factor in the evaluation
and design of aquifer remediation efforts. Some compounds will be very
tenaciously held by the soil matrix, becoming essentially immobile. Others
will be strongly retarded in their passage through the aquifer, moving at only
a small fraction of the rate of groundwater flow. Still other contaminants,
particularly the lower molecular weight, volatile organic contaminants move
relatively rapidly through the groundwater system—often nearly as fast as the
groundwater, itself. However, even the volatile organics themselves exhibit a
substantial degree of variation in their mobility in aquifer systems.
The degree to which a chemical or solute is retarded with respect to the flow
of groundwater in an aquifer system is defined as its Retardation Factor, R,
where:
groundwater velocity
solute velocity
The retardation factor can be used to estimate flushing times of contaminants
from aquifers. It can be considered as being roughly equivalent to the number
of pore volume exchanges necessary to extract a particular contaminant from
the groundwater system., It should be noted that the Retardation Factor (R)
refers to .the retardation of solutes in a plume of dissolved groundwater
contamination. In areas of severe soil contamination other factors also come
into play which will be subsequently discussed.
It can be shown that:
R - 1 +(p/n)Kd (1)
Where: p » bulk solids density
n • porosity
K. • soil/water distribution coefficient
d
The ratio of the bulk solids density to the porosity (p/n) typically falls in
the range from 4 to 10, and for the purposes of this evaluation can be
considered as roughly 5. K. is a distribution coefficient which provides a
measure of the extent to which a material partitions between a soil matrix and
the groundwater.
Karickhoff, et al (1979) have shown that the adsorption of organic compounds
in soil systems is very strongly controlled by the fractional organic content
of the soil (f ) to the extent that other soil properties play minor roles.
The term K represents the adsorption coefficient referenced to the soil's
organic consent, rather than its total mass. Karickhoff and his coworkers
have developed the following relationship:
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11
Koc - :~-
oc
The fact that the retardation coefficient for organic compounds can be
correlated to a soil's organic content is particularly useful since numerous
authors have been able to demonstrate correlations between K and several
commonly known properties of chemicals. In particular, water solubility (S)
and octanol/water partition coefficient (K ) have been shown to correlate
well with K . (Kenaga and Goring, 1978; Kirickhoff et al., 1979; Chiou, et
al., 1979).oc
In consideration of the preliminary nature of this assessment the following
empirical relationship developed by Karickhoff will be utilized throughout the
analysis:
Koc ' °'63 Kow (3)
Utilizing equations 1, 2, and 3, it is possible to estimate the retardation
factors for the organic compounds found at the Goose Farm site. The method is
illustrated in the following sample calculations for methylene chloride.
Sample Calculation
t
Chemical contaminant: Methylene Chloride
Octanol/water partition coefficient (K ) - 18
Using equation (3)
Koc"°-63Kow '
K - 0.63(18) - 11
oc
From equation (2)
K • f K
*d oc oc
Where: f - 0.52 or 0.005 (estimated)
K. - 0.005 (11) « 0.055
a
and from equation (1)
R - 1 + p/n K
Where: p/n » 5
R - 1 + 5 (0.055)
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12
1.28
Retardation Factor (R) of Methylene Chloride is 1.28.
Table 1 presents the estimated retardation factors (R) for the principal
organic priority pollutants found at the Goose Farm site. In the calculation,
it has been estimated that the average organic content of the formations
through which the plume is migrating is 0.5 percent.
The above analysis reflects the mobility of individual compounds in the
groundwater system. In evaluating these situations one must also consider the
synergistic effects of multiple chemicals migrating in the same groundwater
system, such as is the case at Goose Farm. It has been well documented, for
instance, that the solubility and hence the mobility of many relatively
insoluble compounds can be greatly enhanced by the presence of dissolved
concentrations of organic solvents in groundwater. The high concentrations of
organic solvents in the Goose Farm soils and groundwater are likely enhancing
the mobility of many of the otherwise relatively immobile base neutral
extractables, and acid extractables. It is difficult to quantify the impact
of this mechanism of contaminant migration, yet it may be a significant factor
in the observed presence of base neutral extractables, and acid extractables,
well beyond the confines of the disposal pit.
It must also be emphasized that the proceeding analysis of retardation factors
applies only to activity occurring within the plume of dissolved
contamination. In the zones of severe soil contamination such as the disposal
pit the above-described mechanisms are inadequate to fully predict
retardation. In those areas, the soils have been overwhelmed by the organic
compounds and are often coated with a pellicular film of the materials. Where
this is the case, as it appears to be in the disposal pit, it can require 30,
40, or more pore volume exchanges of groundwater to leach even the relatively
mobile compounds from the soil.
The importance of this analysis of retardation factors lies in the fact that
retardation factors can be roughly correlated with the number of pore volume
exchanges necessary to flush an aquifer free of contaminants. In this case,
one pore volume equals the approximate volume of groundwater within the plume.
It is estimated that the Goose Farm plume contains approximately 16 million
gallons of groundwater. This estimate is based upon the areal dimensions of
the plume which are roughly 500 feet by 500 feet, an average depth of
approximately 30 feet, and an average porosity of 0.25. It can therefore be
roughly estimated that an organic contaminant such as 1,2-Dichloropropane with
a retardation value of 4 would require removal of approximately 6 pore volumes
or 56,000,000 gallons of groundwater. Similarly, Ethylbenzene would require
withdrawal of 325,000,000 gallons of groundwater. The diversity of
retardation factors exhibited by the Goose Farm contaminants will manifest
itself in the progressive release of contaminants having successively higher
retardation factors during the course of the groundwater recovery program.
Since many of the retardation factors are high, yet not so high as to render
the contaminants totally immobile, a tremendous amount of groundwater will
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TABLE 1
Estimated Retardation Factors (R)
for Principal Goose Farm Contaminants
Calculated Using Karickhoff, et al
Empirical Correlations
Chemicals
• Volatile Priority Pollutants
Acrylonitrile
Acrolein
Methylene Chloride
1,2-Trans-Dichloroethylene
1 , 2-Dichloroethane
1 , 1-Dichloroethane
«ene
1 ,-Trichloroethane
Dichloropropane
hloroethylene
Toluene
Ethylbenzene
Base Neutral Extractables
' Bis(2-Chloroechoxy) Methane
Bis(2-Chloroethyl) Ether
Bis(2-Chloroisopropyl) Ether
Naphthalene
"Fluorene
Acenaphthene
Phenanthrene
'Anthracene
Chrysene
Di-N-Butyl Phthalate
Pyrene
Fluoranthene
Butyl Benzyl Phthalate 63,
Benzo (A) Anthracene
Benzo (A) Pyrene
Benzo (B) Fluoroanthene
Benzo (K) Fluoroanthene
Jenzo (GHI) Perylene
^^•eno (l,l,2-c,d) Pyrene
^^•(2-Ethylhexyl) Phthalate
^^^^B^^
Acid Extractables
K
OW
0.7244
1
18
30
30
62
89-135
150
190
195
490
1,410
18
38
380
2.340
15,100
21,380
28,000
28,200
407,000
158,489
209,000
214,000
100-631,000
408,000
1,100,000
3,715,352
6,918,310
17,000,000
45,700,000
Koc
0.46
0.63
11
19
19
39
71*
95
120
123
309
888
11.34
23.95
239.5
1,474
9,513
13,469
17,640
17,766
25,641
99,848
131,670
134,820
218,641*
257.040
693,000
2,340,672
4,358,535
10,710,000
28,791,000
.
Kd
0.0023
0.0032
0.055
0.095
0.095
0.20
0.36*
0.48
0.6
0.61
1.54
4.44
0.057
0.12
1.2 .
7.37
47.6
67.4
88.2
88.83
128
499
658.4
674
1,093*
1,285
3,465
11,703
21,793
53,550
143,955
R
1.01
1.02
1.28
1.47
1.475
2.0
2.8*
3.4
4.0
4.1
8.7
23.2
• 1.3
1.6
7.0
37.9
239
338
442
445
642
2,497
3,293
3,372
5,467*
6,426
17,326
58,518
108,964
267,751
719,776
Phenol 29 18.3 0.09 1.457
-------
Chemicals
Pesticides
PCB-1242
PCB-1254
PCB-1248
K
s» •
-
380,000
1,070,000
1,300,000
K
DC
239,400
674,100
819,000
'd
1,197
3,370
4,095
R
5,986
16,851
20.476
Noce: K • Octanol/Water Partition Coefficient
K°" - Soil/Water Partition Coefficient Referenced to Organic Content
K, • Soil/Water Partition Coefficient
R • Retardation Factor
* « Mean Value
-------
13
have to be pumped Co purge the contaminants from the _.uifer. In the absence
of quantitative performance standards (and naturally a more detailed analysis
of contaminant flushing) it is impossible to predict with any degree of
accuracy the time period over which a groundwater recovery and treatment
system would operate at the Goose Farm site. However, at a pumping rate of
100,000 gallons per day, one pore volume exchange could be realized every 140
days provided induced stream water infiltration is negligible. Comparing this
figure with the retardation factors provided in Table 1 indicates that a
groundwater recovery and treatment facility on this site could run for many
decades, possibly even 100 years, depending upon the performance standards
established.
As noted earlier, two other factors must be kept in mind. First, the mobility
of otherwise relatively immobile compounds will be enhanced by the presence of
organic solvents. This will cause these relatively immobile compounds to be
flushed more rapidly from the soil system. Second, the rates of flushing in
the areas of severe soil contamination cannot be predicted by retardation
factors alone. The shear mass of contaminants in this area plays a more
important role in dictating flushing times. The combined effect of these two
phenomena is to increase the number and amount of contaminants flushed from
the aquifer at intermediate times—some of the highly mobile contaminants-
1 appearing later than predicted and some of the relatively immobile compounds
being leached more rapidly.
The TRIA groundwater recovery system is proposed to consist of a vacuum
wellpoint system as indicated in Figure V-l. The vacuum wellpoints are to be
aligned along the eastern and northern boundaries of the plume adjacent to the
creeks into which the plume discharges. Because of the proximity to the
creeks, induced infiltration of stream water into the groundwater recovery
system will make up a significant portion of that system's flow. This induced
surface water infiltration couild potentially account for between 30 and 70
percent of the total flow-of the wellpoint system. It will depend upon the
system's geometry and flow rates, aquifer properties, and stream bed and flow
characteristics. Obviously, inducing this significant in-flow of
uncontaminated water into the system has several negative side effects.
First, it would necessitate increasing the hydraulic capacity of both the well
point system and the groundwater treatment plant. More important, however, it
will serve to throw the remedial project out of hydrologic balance.
Alternative 04 is intended to operate as an essentially "closed-loop" system.
Recovered contaminated groundwater is intended to be treated and returned to
the.aquifer near the northern end of the disposal pit (see Figure V-l of the
Feasibility Study). The aquifer within the plume has a finite capacity to
store and conduct groundwater. The continuous addition of surface water into
the system will eventually overwhelm the aquifer, potentially causing one or
more of several problems. First, the groundwater could rise to excessive
levels in the recharge area, possibly reaching the ground surface, causing
obvious problems. Second, the potentiometric highs caused by the recharge
system could serve to expand the plume laterally beyond its present
boundaries.
The concept of recharging at the rear of the plume to accelerate aquifer
-------
renovation is quite good. However, where surface water is bei..g induced to
flow into the groundwater collection system, it is usually necessary to
discharge a comparable amount of water beyond the "closed loop"
recharge/discharge system in order to maintain a hydrologic balance. Once
again, it is evident that a computer model could have been extremely useful in
conceptualizing the groundwater recovery remedial options.
The TRIA-recoramended remedial option envisions accelerated soil flushing as a
means to enhance the migration of leachable constituents to the groundwater
recovery system. However, the means proposed to achieve this soil flushing
will be at best partially effective. It is proposed that a wellpoint system
consisting of 80 wellpoints be utilized to inject water back into the
contaminated soil zone in the vicinity of the disposal pits. A sketch of the
proposed system is presented in Figure V-l of the "feasibility study. A
wellpoint system of this type will effectively flush only those soils in its
immediate vicinity. Such a recharging wellpoint system will create a
potentiometric ridge along its alignment and accelerate flushing only within
the confines of the potentiometric ridge and the underlying saturated zone.
Contaminants in the unsaturated zone more than a few tens of feet from the
recharge system will likely be completely unaffected. Even contaminants in
the unsaturated zone in the immediate vicinity of the wellpoint recharge
system may be unaffected depending upon the resultant height of the
potentiometric ridge. The TRIA RI/FS provides no quantification of the impact
of the proposed soil flushing system upon the ground-water table or with regard
to its effectiveness. Clearly this is another example of where a computer
model could have been a great asset to the feasibility study process. With
the computer model, the effectiveness of various soil flushing systems could
be quantitatively evaluated.
A more effective approach to soil flushing would be some form of surface
application system such as*a recharge basin or spray irrigation. In this way,
contact between the recharging water and the soil contaminants can be
maximized through the region of soil contamination.
Groundwater Treatment Considerations
In Alternative *&, it is proposed that groundwater be treated with gravity
clarification and granular activated carbon adsorption. TRIA assumes that ten
pore volumes of the contaminated plume will need to be treated during an
18-month period. A total of 140 million gallons (approximately 260,000 gpd)
of groundwater will need to be treated. Aside from the previusly described
problems of contaminant flushing, several concerns arise with respect to the
treatment method as well.
1. Gravity Clarification
Gravity clarification with a hydraulic detention of approximately 2 to 3
hr is effective in removing suspended solids. However, most groundwaters
have very low suspended solids. Hence, from this standpoint, gravity
clarification is not needed. Furthermore, most of the chemical
constituents (e.g. heavy metals, hardness, etc.) contained in groundwater
-------
15
are in soluble forms which are not susceptible to gra. ::y settling In
this respect, therefore, gravity clarification is not Affective. If there
is a need to remove heavy metals using some type of chemical
precipitation, then gravity clarification is required to remove the
precipitated metals. But, heavy metal concentrations in State Wells #095
and 1107 are either lower than primary drinking water standards (e.g.
mercury) or not regulated (e.g. zinc). Consequently, gravity
clarification is not needed under Alternative 14.
2. Granular Activated Carbon (GAC) Adsorption
Although most of the organics in the plume water are highly adsorbable,
GAC alone is not cost-effective in removing 400-500 mg/1 BOD (FMC, 1985),
which is characteristic of the core of the plume.. Moreover, considering
the high concentration of many organics (e.g., 560,000 ppb methylene
chloride, 9500 ppb benzene, etc.), GAC treatment would be very expensive
if stringent effluent limitations of less than 50 ppb each VOC and total
VOC <. 100 ppb are to be met. (Once again, the feasibility study is
haunted by lack of performance standards.)
3. Air Stripping
Air Stripping is not proposed in Alternative 14. Because most of the
organics found in the plume water are highly volatile (e.g. methylene
chloride, dichloroethylene, trichloroethylene, acrylonitrile, benzene,
etc.), air stripping prior to to carbon adsorption would significantly
reduce the VOC loading to the carbon treatment, and therefore would
considerably lower treatment cost.
Based upon the above critique, a treatment train of air stripping followed by
PACT (powdered activated carbon in activated sludge) should be considered.
However, the feasibility of air stripping vis-a-vis local air quality control
standards would have to be confirmed.
The achievable effluent concentrations and sizing of the treatment system ..-are
not addressed in the Killam report. These would have to be confirmed through
a series of treatability studies on the actual plume water.
4.2.2 Cost Evaluation
The estimated construction costs of TRlA's Alternative #4 modified to reflect
the suggested alternative treatment scheme is presented in Table 2. The
construction costs apparently do not differ.appreciably from those estimated
by TRIA. However, in the TRIA cost estimates no differentiation was made
between construction costs and operational and maintenance costs.
It is estimated that the annual operation and maintenance costs for the
groundwater treatment plant will amount to approximately $394,000. This
includes $200,000 a year general 0 & M for the treatment plant, $139,000 per
year for sludge disposal, and $55,000 for groundwater monitoring.
-------
TABLE 2
Estimated Cost of Alternative No.
Item
Units Quantity Unit Price Estimated Cost
Groundwater Recovery &
Recharge System
LS
Soil Flushing & Recovery
System LS
Groundwater Treatment
Plant (AS, PACT)
LS
S 349,000 S 349,000
383,000
SUBTOTAL
Engineering, Permitting, & Contingencies @ 30%
383,000
1,350,000 1,350,000
S2,022,000
607,000
TOTAL
52,629,000
-------
16
4.3 Evaluation of Remaining TRIA Alternatives
The following brief comments are offered regarding the remaining seven TRIA
alternatives.
4.3.1 Technical Evaluation
Alternative II
The National Contingency Plan mandates that the feasibility study consider a
total removal option. In the case of Alternative #1, complete removal would
encompass not only the contaminated soils in the waste disposal pit, but
apparently much of the contaminated aquifer as well. In essence, this
alternative would involve removal and reconstruction of the aquifer with clean
fill—a rather extreme method of aquifer remediation. This alternative has
several negative aspects which remove it from serious consideration. These
are:
1. The extreme cost.
2. The nationwide shortage of landfill capacity for the 62,000 cubic yards of
waste resulting from this alternative.
3. The current regulatory reluctance to send wastes off-site to sites which
may potentially become future Superfund sites.
j
Alternative 12
Alternative #2 shares the same disadvantageous aspects as Alternative #1,
although to a lesser degree.
Alternative 13
This alternative calls for the on-site disposal of the 62,000 cubic yards of
contaminated soil in a RCRA hazardous waste landfill. Although technically
feasible, this alternative is considerably more costly than some of the
in-situ management alternatives presented in Section 5.0 of this report. In
addition, there would remain a risk of failure which could prompt still
another remedial investigation/feasibility study the future. The risk of
failure, that is leakage from the facility, wo. always remain since RCRA
guidelines and site considerat: s would mandate construction of the landfill
above the groundwater table. Consequently, there would always be an outward
hydraulic gradient across the liners. The difficulty in obtaining the
necessary permits to construct such a facility in the coastal plain of New
Jersey should also not be overlooked.
Alternative ?5
Alternative #5 involving in situ biological treatment is a variation of
Alternative #4, discussed previously. The success of the in situ biological
treatment depends upon the ability of the stimulated bacteria to degrade the
-------
17
contaminants in situ without need for their extraction and above-ground
treatment. The technology of in situ biological treatment appears very
promising. Whether it is applicable to the specific conditions of the Goose
Farm site would have to await a more detailed treatability study.
In situ biological treatment could be performed in conjunction with a soil
flushing and groundwater recovery system such as that proposed in Alternative
#4 by TRIA or in conjunction with the containment options described within
Section 5 of this document.
Alternative 16
Alternative #6 is the only containment-based alternative evaluated by TRIA.
It involves a rather unusual approach to in situ management, specifically the
application of "base grouting". Base grouting is a procedure to develop a
horizontal low-permeability horizon beneath a waste disposal site. Subsurface
cutoff walls are then keyed into this low-permeability horizon to form a
containment "vessel". Base grouting, however, is a highly questionable
procedure insofar as the integrity of the final product is concerned. No
specification is given within the RI/FS as to the specific nature of the base
grouting technology considered.
\pparently no consideration was given to utilization of the Hornerstown Sand
.»quitard as a strata into which subsurface cutorf walls could be keyed.
Wehran Engineering conducted a rather extensive analysis of the Hornerstown
Sand aquitard beneath the Goose Farm site. The results of that analysis are
published within their May 1985 report. Wehran Engineering estimates that the
"upper shell layer (of?the Hornerstown Sand formation) has a permeability on
the order of 1.0 x 10" cm/sec." It is therefore clear that the Hornerstown
Sand aquitard is capable of being advantageously exploited as. a relatively
low-permeability aquitard into which subsurface cutoff walls could be founded.
Yet, the TRIA FI/FS gives no consideration to this advantageous feature of the
site. In fact, TRIA seems to ignore the presence of the Hornerstown Aquitard
altogether. On page III-2 of the feasibility study they state in connection
with Alternative #6 that "the bottom grouting is required, however, by the
permeability of the lower Kirkwocd, Manasquan, and Vincentown formations at
the site." It is difficult to understand the reasoning for this oversight
since not only is the Hornerstown Sand aquitard a well-recognized aquitard in
the New Jersey coastal plain, but at this site it is well within the reach of
conventional slurry trench construction methods.
Alternatives f7 and 18
Alternatives #7 and #8 are not truly in contention as potential remedial
measures for the Goose Farm site. .Alternative 17 fails to address the
contaminants within the plume and Alternative #8 is the no-action alternative.
-------
18
4.3.2 Cost Evaluation
The following general comments are offered regarding certain common
characteristics of the TRIA remedial alternatives.
1. As has been previously described, it is our belief that the difficulty and
time required to flush the soils and remediate the aquifer at the Goose
Farm site have been seriously underestimated. Employing the principles
previously described, it is our contention that soil flushing times and
aquifer remediation times are likely to take anywhere from a decade to
more than a hundred years, depending upon the performance standards
established for the project.
*
2. Aside from being unrealistically low, the projected cost of plume pumping
and treatment is the same in Alternatives 1, 2, 3, A and 6, in spite of
substantial differences in the amount of aquifer requiring remediation in
each alternative. How could the aquifer remediation costs be the same
when in Alternatives 1 and 3, 62,000 cubic yards of the most highly
contaminated material will be removed from the aquifer, while in
Alternative 4, the recommended solution, no source control is.
contemplated. Similarly, in Alternative 2, 10,000 cubic yards of highly
contaminated soils, representing the disposal pit, are to be removed for
off-site disposal. Yet, the cost for plume management in this alternative
is again the same as^Alternative 4, which involves no source control. In
Alternative 6, a slurry trench cutoff wall and bottom grouting is proposed
to contain presumably the most highly contaminated soils. Yet, no impact
on plume cleanup costs is projected. Surely some benefit is to be accrued
from these highly capitally-intensive source control efforts insofar as
the duration and costs of the aquifer remediation program is concerned?
3. The cost of contaminated soil excavation and disposal is estimated at $540
per cubic yard. The derivation of this figure is not provided in the
RI/FS. This figure seems rather high in light of similar waste excavation
and disposal efforts in New Jersey and elsewhere.
4. The RI/FS report provides very little technical information concerning the
eight evaluated remedial programs. The estimated pumping rates of the
soil flushing or groundwater recovery systems are not provided. The cost
of the groundwater treatment plant is not broken out and separated from
the cost of the groundwater recovery system or the operational costs
associated with the system. The depths and proposed alignment of the
slurry trench cutoff wall in Alternative 6 is not provided. Nor is there
any explanation of the base grouting technique. In reading the report one
does not know whether "base grouting" refers to the "block fracturing
technique" or some other form of pressure grouting. The derivation of the
immense $12,500,000 cost of base grouting is also not provided within the
RI/FS.
Specific Cements
-------
19
Alternative II
Although the unit cost of excavation and disposal ($540 per cubic yaraj seems
high, it is not clear whether TRIA has included in their estimate provisions
for management of groundwater during the excavation operation. Groundwater
management during excavation could be a significant factor in the cost
estimates and may account for the rather high unit price for excavation and
disposal.
Alternative 12
The general comments and specific comments made in regard to Alternative #1
also apply with respect to Alternative #2.
Alternative 13
It appears that TRIA's estimates of the cost to construct an on-site landfill
may be low. Table 3 contains an approximate cost estimate for a 67,000 cubic
yard hazardous waste secure landfill conforming with EPA's guidelines
published following the 1984 reauthorization of the Resource Conservation and
Recovery Act. In accordance with those guidelines, the landfill design
includes a primary and secondary liner, a primary leachate collection system
above the primary liner, and a leachate collection/ detection system between
the two liners. In further compliance with the referenced EPA guidelines, the
base liner has been assumed to be constructed of 3 feet of compacted clay with
a maximum permeability of 1X10-7 centimeters per second. The primary liner
has been assumed to be a composite liner consisting of 80 mil high density
polyethylene (HDPE) atop a two-foot 1X10~ liner of compacted clay. The
landfill's final cover would consist of a composite cap of 20 mil PVC atop one
foot of 1X10-7 centimeters per second compacted clay overlain by a one-foot
sand drainage layer and one and one-half feet of top soil. TRIA's estimates
of annual operating costs, presumably consisting of leachate treatment, final
cover maintenance, and environmental monitoring, appear reasonable.
Alternative 14
Since Alternative #4 is the recommended remedial option, the costs of this
option have been evaluated in greater detail in Section 4.2.2 of this report.
Alternative 15
Insufficient information existed at the time of this report to estimate the
costs associated with in situ biological treatment. Additional studies by FMC
are under consideration by Morton-Thiokol.
Alternative 16
Alternative #6 is the only TRIA alternative which gives consideration to
containment of contaminated source areas. Unfortunately, Alternative #6
contemplates base grouting of 5 acres. Base grouting is not only enormously
-------
TABLE 3
COST ESTIMATE
ON-SITE RCRA LANDFILL
t.
2.
3.
4.
5.
6.
fc
•
P
8.
ITEM
SITE PREPARATION
BERMS
SECONDARY LINER
LEAK DET. SYSTEM
-SAND
•COLLECT. PIPES
-GEOTEXTILE
-COLLECTION SUMP
PRIMARY LINER .
-CLAY
-80 HOPE
LEACHATE C.S.
-SAND
-COLL. PIPES
(-GEOTEXTILE
-COLL/STORAGE
MONITORING WELLS
FINAL CAP
-CLAY
-20 MIL PVC
-SAND
-DRAIN. PIPE
-TOPSOIL
-HYDROSEED
UNITS
L.S.
C.Y.
C.Y.
C.Y.
L.F.
S.F.
L.S.
C.Y.
S.F.
C.Y.
L.F.
S.F.
L.S.
UNIT
C.Y.^
S.F.
C.Y.
L.F.
C.Y.
S.F.
QUANTITY
1
26,200
40,400
7,000
4,150
172,000
1
17.500
187,500
7.400
4.270
186,000
1
4
10.200
210,000
8,300
4,500
14,700
222,000
UNIT
PRICE
* 50, 000. 00
912.65
112.65
f7.00
• 0.75
tO. 15
• 20,000.0*0
•12.65
• 1.00
• 7.00
• 0.75
• 0.15
•75,000.00
•2,500.00
•12.65
• 0.27
• 7.00
• 0.75
• 9.00
• 0.08
ESTIMATED
COST
•50,000
•331.430
•511,060
•49,000
•3,113
•25,800
•20,000
•221,375
•187,500
•51,800
•3,203
•27,900
•75.000
•10,000
•129,030
•56.700
•58,100
•3.375
•132,300
•17,760
SUBTOTAL
ENGINEERING,PERMITTING, AND CONTINGENCIES
•1.964,445
30.00% §589,334
TOTAL
•2,553,779
-------
20
expensive, i- remains an inherently difficult undertaking. Because of the
unseen subterranean nature of the work, .the integrity of a base-grouted zone
is always in question. Apparently no consideration was given to utilizing the
Hornerstown Sand aquitard as a confining layer into which to key subsurface
cutoff walls. Exploitation of the Hornerstown Sand aquitard as part of an in
situ management approach for the Goose Farm site is discussed in some detail
in Section 5 of this report. The inclusion of the rather questionable base
grouting technique in Alternative #6 increases the cost of this alternative by
$16,250,000. As a result, it drives the apparent cost of in-place
encapsulation beyond the range of reason. Yet, as will be described in
Section , there are numerous other in situ management alternatives for the
Goose Farm site which are in fact more cost effective than the alternatives
presented within the TRIA RI/FS and, moreover, possess a higher degree of
reliability.
Alternatives 17 and 18
Neither Alternative 17 or #8 are in serious consideration because in the case
of Alternative #7 the plume is left unmanaged and in the case of Alternative
#8 no remedial efforts are involved.
-------
21
S.O PRELIMINARY ASSESSMENT OF OTHER REMEDIAL OPTIONS
The face chat the soil flushing and aquifer remediation remedial alternatives
proposed by TRIA will be a more time consuming and therefore more costly
undertaking than estimated, demands that containment options be given a closer
examination. A closer look at containment options ia also indicated by the
observed properties of the Hornerstown Sand aquitard beneath the Goose Farm
site. The TRIA RI/FS makes little effort to consider the many containment
options available. The single containment option TRIA considered (Alternative
16) involved the highly questionable and costly practice of base grouting. No
consideration was given in the TRIA RI/FS to utilization of the Hornerstown
Sand aquitard as part of an in-situ management approach. In so doing, it
appears they have overlooked some very attractive and cost-effective remedial
alternatives.
Subsurface cutoff walls can play a variety of roles in the remediation o£
hazardous waste sites (Mutch, 1984). In the case of waste disposal sites,.
cutoff walls can be.used to hydraulically isolate the waste disposal site. In
the same manner cutoff walls have been used to isolate subterranean zones of
soil contamination. In groundwater recovery and treatment programs, cutoff
walls have also been used to minimize or prevent induced infiltration from.
adjacent surface water bodies. Cutoff walls have also been used to partially
or completely enclose a plume of groundwater contamination, thus halting its
spread and allowing groundwater recovery and treatment efforts to proceed at a
more relaxed pace.
Each of the above-described common usages of subsurface cutoff walls has
potential application at the Goose Farm site. A subsurface cutoff wall could
be employed to encircle the former disposal pit and the highly contaminated:
soils in its immediate vicinity. Alternatively, a subsurface cutoff wall.
could be utilized to completely enclose both the waste disposal pit and the
plume of groundwater contamination. Finally a subsurface cutoff wall,
ossibly even a relatively shallow cutoff wall penetrating to the Manasquan
Formation rather than the Hornerstown Sand aquitard, could be utilized to.
minimize induced infiltration from the adjacent stream.
It must be emphasized at this point that cutoff walls do not form completely
impermeable barriers to groundwater flow. Rather, in the proper hydrogeologic
setting and under the proper design and construction conditions, they can very
effectively minimize groundwater flow. This is not to suggest, however, that
leakage from a waste disposal site encircled by subsurface cutoff walls need
be inevitable. Many waste disposal sites have been remediated by a
combination of circumferential subsurface cutoff walls and internal leachate
collection systems to reverse hydraulic gradients across the cutoff wall. In
other words, by lowering the potentiometric surface within the waste disposal
site to elevations less than the potentiometric levels in the surrounding and
underlying aquifers, seepage will be induced to flow into the waste disposal
site rather than vice versa. This remedial concept has been employed in the
remediation of numerous waste disposal sites including several sites on the
National Priority List. Several of the National Priority List sites employing
this technique include the Monroe Township Landfill in Middlesex County, NJ
-------
22
(Mutch 1983); the South Brunswv-k Landfill -n Middlesex County, NJ; and the
Hooker "S" Area Landfill in Niagara Falls, NY (Amos, 1985).
In the containment options for the Goose Farm Site discussed subsequently, it
is this concept which is employed. This concept results in essentially 100
percent abatement of contaminant release from the site. A properly undertaken
risk assessment may demonstrate that such a high level of abatement is not
required. In which case, it may be possible to omit the hydraulic gradient
reversal and allow some nominal amount of leakage to ultimately leave the
site's confining envelope. However, at this juncture, we have assumed the
more conservative remedial approach.
Since in every application of subsurface cutoff walls there will be some
groundwater flow through the cutoff wall itself and beneath the cutoff wall,
prediction of the amount of flow occurring by each of these mechanisms is
critical to evaluation and design of a subsurface cutoff wall. In each of the
subsequently discussed additional remedial options, the estimated amount of
groundwater inflow has been estimated.
The following additional remedial options seem worthy of further
consideration. In order to avoid confusion and to be consistent with the TRIA
feasibility study, the numbering of these additional remedial options begins
with Alternative #9.'
-------
23
5.1_ Description of_ Additional Remedial Alternatives
Alternative 19
Alternative #9 would include the following elements:
1. A circumferential cutoff wall around the waste disposal pit and plume of
groundwater contamination. The approximately 2,000 ft. long slurry trench
cutoff wall would lie along the creeks on the eastern and northern sides
of the plume, along the western edge of the plume, and just south of the
southern edge of the waste disposal pit. The slurry trench cutoff wall
would key into the Hornerstown aquitard at an average depth of
approximately 65 feet.
2. An interior leachate/groundwater collection system would be constructed to
lower the potentiometric surface within the cutoff wall enclosure to a
level below the potentiometric levels in the adjacent Kirkwood/Vincentown
and the underlying Mt. Laurel Aquifer.
3. Collected leachate would be managed either by trucking to an off-site
wastewater treatment plant such as DuPont's Deepwater, New Jersey facility.
or by an on-site treatment plant. This decision would have to await the
findings of a treatability study and economic analysis.
It is crucial in any containment-based remedial action that the amount of
leakage be estimated. In a conventional containment approach where leakage
would be outward, it is necessary to know the amount of leakage in order to
estimate the degree of effectiveness of the remedial option and to undertake a
risk assessment. In an "intragradient" containment option, such as
Alternative #9, the estimation of inward leakage allows for proper planning of
leachate management alternatives. In the case of Alternative #9, leakage into
the cutoff wall enclosure can be expected from three mechanisms:
(a) Infiltration of precipitation
(b) Inflow of groundwater through the cutoff wall, itself
(c) Upward leakage through the Hornerstown Sand aquitard.
Infiltration of Precipitation
It has been estimated that .roundwater recharge on the Goose Farm Site, given
the nature of the surficial soils and absence of vegetation, is probably on
the order of 15 inches per year. Over the 6.1 acre area of the cutoff wall
enclosure this would amount to a total of 2,482,000 gallons of groundwater
recharge per year or approximately 6,800 gallons per day on an average basis.
It should be noted however that groundwater recharge will vary significantly
seasonally and the design must be able to accommodate these seasonal
fluctuations.
Leakage Through the Cutoff Walls
Under natural conditions, it has been assumed that there is a five foot
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differential in the potentiometric levels of the combined Kirkw -d/Vincentown
aquifer in the deeper Mt. Laurel/Wenonah Aquifer. Therefore, in order to
lower the potentiometric surface within the cutoff wall enclosure to a level
at least two foot below the potentiometric level in the Mt. Laurel/Wenonah
Aquifer, it will be necessary to lower the interior potentiometric surface
approximately seven feet. This will create a seven foot head differential
across the subsurface cutoff walls. The hydraulic gradient would therefore be
7/3, or 2.33, assuming a three-foot thick slurry trench cutoff wall. Seepage
through the 130,000 square foot cutoff wall having a permeability of 1 x 10
cm/sec would therefore be approximately 645 gallons per day.
Leakage Upward Through Hornerstown Sand Aquitard
The upper shell layer of the Hornerstown Sand aquifer is approximately eight
feet in thickness. .Uehran Engineering estimates its permeability at
approximately Ix 10" cm/sec. Conservatively assuming that the two-foot
gradient is entirely dissipated across the upper shell layer, the hydraulic
gradient would be 0.25. Upward leakage through the Hornerstown Sand aquitard
would therefore be approximately 140 gallons per day.
The total leakage into the cutoff wall enclosure will be the sum of the above
three mechanisms or approximately 7,600 gallons per day.
The estimated costs of Alternative #9 are presented in Table 4. The total
construction costs of Alternative #9, including engineering, permitting, and
contingencies, is $2,242,500. Annual operating costs would consist primarily
of leachate treatment costs. Annual costs for leachate management amount to
approximately $40,000 per year. Adding in costs for routine monitoring, one
can assume that the annual operating costs would be approximately $95,000 per
year.
Alternative 110
Alternative 110 would include the following elements:
1. A circumferential cutoff wall around the waste disposal pit and plume of
groundwater contamination. The approximately 2,000 ft. long slurry trench
cutoff wall would lie along the creeks on the eastern and northern sides
of the plume, along the western edge of the plume, and just south of the
southern edge of the waste disposal pit. The slurry trench cutoff wall
would key into the Hornerstown aquitard at an average depth of
approximately 65 feet.
2. A cap would be constructed over the cutoff wall enclosure area to minimize
infiltration of precipitation. The cap would consist of 12 inches of
compacted clay with a maximum permeability of 1 x 10~ cm/sec, covered by
a 20 mil PVC liner. Above the liner a drainage layer would be constructed
using 4-inch perforated pipe placed in 12 inches of coarse sand. The
drainage layer would be covered with 18 inches of "opsoil and hydroseeded
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25
to minimize erosion.
3. An interior leachate/groundwater collection system would be constructed to
lower the potentiometric surface within the cutoff wall enclosure to a
level below the potentiometric levels in the adjacent Kirkwood/Vincentown
and the underlying Mt. Laurel Aquifer.
A. Collected leachate would be managed either by trucking to an off-site
wastewater treatment plant such as DuPont's Deepwater, New Jersey facility
or by an on-site treatment plant. This decision would have to await the
findings of a treatability study.
Leakage Estimate
Leakage into the cutoff wall enclosure under Alternative #10 would be the same
as that occurring in Alternative # 9 with the exception of infiltration of
precipitation. The composite clay/geomembrane cap should essentially
eliminate infiltration of precipitation into the cutoff wall enclosure.
Recognizing the limitations of any containment options, we have conservatively
assumed a leakage rate of 100 gallons per day. Total leakage under this
option would therefore be approximately 885 gallons per day.
The costs of Alternative #10 are presented in Table 5. The annual operating
costs for Alternative #10 are lower, since infiltration of precipitation is
essentially eliminated. ' Annual costs for leachate treatment would be
approximately 525,000 per year. Adding in costs for site monitoring and
routine maintenance, the total annual operating costs are probably on the
order of $80,000,
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26
5.2 In-Situ Biological Treatment Applications
Possible variations of Alternatives #9 and #10 would involve the application
of in-situ biological treatment processes to treat the contaminants within the
cutoff wall enclosure. The cutoff walls offer the advantage of allowing the
in-situ biological treatment to proceed at a more relaxed pace since plume
migration would be controlled. The closed loop in-situ biodegradation
processes could operate without concern of induced surface water infiltration
or loss of partially treated effluent from the treatment zone. It is
difficult to say at this juncture how effective in-situ biological treatment .
would be given the complex suite of organic and inorganic compounds found at
the Goose Farm site. However, results in other areas of the'country have been
very promising. In-situ biological treatment is a particularly attractive
treatment method for contaminants which tend to remain in the soil or are only
slowly flushed from the groundwater system since treatment occurs in the
subsurface without the need of bringing the contaminants to the surface for
conventional treatment.
The advantage of incorporating in-situ biological treatment with the
containment options is that eventually collection and treatment of groundwater
from within the cutoff wall should no longer be necessary. A treatability
study in conjunction with the establishment of quantitative performance
standards would permit a determination of the tir.e required to reach this
point. '
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27
6.0 CONCLUSIONS
It is our contention that the most serious deficiency of the TRIA RI/FS is its
failure to mount a truly diligent search for a cost effective remedial option
for the Goose Farm site. The remedial options which are looked at are few in
number and poorly developed. Both the RI and FS portions of the document are
strikingly unquantitative. Remedial objectives are not set forth other than
in the most conceptual terms. The plume of groundwater
contamination—essentially the entire focus of the RI/FS— is not even mapped,
either in terms of its spatial extent or the distribution of contaminants
within the plume. No estimate is provided of the quantity of contaminated
groundwater within the plume. No effort was made to estimate the retardation
of the principal contaminants in the groundwater system. The influence of
site stratigraphy on the hydrogeologic conditions of the site was largely
overlooked. No effort was made to differentiate and define the hydrogeologic
properties of the different geologic formations found beneath the site. The
Hornerstown Sand aquitard—a well known low permeability aquitard in the
coastal plain of New Jersey—was entirely ignored in considering
containment-based options.
It is our suggestion that in light of the apparent unlikelihood of flushing
the contaminants from the aquifer in the time period projected by TRIA, other
remedial options, specifically containment options, be further evaluated.
Table 6 contains a comparative analysis of selected Goose Farm remedial
options. Specifically the table provides a comparison of Alternatives 4, 9,
and 10. Alternative *4 has been evaluated for several different durations of
the groundwater recovery and treatment system and soil flushing systems.
Durations of 2, 3, 4, 5, 10, 20, and 30 years have been utilized in the
assessment. Table 6 contains an estimate of the initial construction costs,
the annual 0 & M costs, and the present worth value of the total annual 0 & M
costs over the appropriate duration of operation. The last column of Table 6
gives the true total cost of the remedial option representing the sum of.the
initial construction costs and the present worth value of the annual 0 & M
costs.
Since Alternative #4 has a relatively high annual operation and maintenance
cost, the "total cost" of this alternative is very sensitive to the duration
of the groundwater recovery and soil flushing program. The present worth
value of the annual 0 & M costs varies from a low of $702,000 in the event the
recovery program only operated for two years to $4,433,000 for a 30 year
operational period. Alternative #4 is only competitive with Alternatives 9
and 10 in the event the groundwater recovery and treatment and soil flushing
system operates no longer than two years. The total cost of Alternative #4
escalates rapidly as the duration of the groundwater recovery and soil
flushing system increases. Should that system have to operate for five years,
the total cost of Alternative #4 exceeds $4 million. Operated for 10 years,
the costs exceed $5 million. The preceding analysis of contaminant mobility
and flushing times indicates that for all but the most relaxed of performance
standards it could take many years, probably decades, to adequately renovate
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TABLE 6
Comparative Analysis of Selecteu Goose Farm Remedial Options
Alternative
Alternative No.
Alternative No.
Alternative No.
Alternative No.
Alternative No.
Alternative No.
Alternative No.
Alternative No.
Alternative No.
9
10
4
4
4
4
4
4
4
Construction
Cost
52,242,500
2,412,085
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
2,629,000
Annual Duration Present Worth
0 & M 0 & M Costs of Total Annual
Costs
595,000
80.000
394,000
394,000
394,000
394,000
394,000
394,000
394,000
(yrs.)
30
30
2
3
4
5
10
20
30
0 & M Costs
51,068,750
900,000
702,000
1,017,000
1,304,000
1,572,000
2,644,000
3,869,000
4,433,000
Total Cost
53,311,250
3,312,085
3,331,000
3,646,000
3,933,000
4.201,0^1
5,273,0^^
6,498,000
7,062,000
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TABLE 4 .
Alternative No. 9
Construction Cost
Item
Slurry Cutoff Wall
Leachate CS
- well points
- piping
- pumps
- installation
- storage facility
Groundwater Treatment
Plant
SUBTOTAL
Engineering, Permitting,
Units Quantity
SF
EA
LF
LS
LF
LS
'LS
and
130,000
120
1,300
3
1,300
1
1
Contingencies 30.0%
Unit Cost
$ 9
25
5
4,000
45
150,000
325,000
Est. Cost
$1,170,000
3,000
6,500
12,000
58,500
150,000
325,000
51,725,000
517,500
TOTAL
52,242,500
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28
the aquifer. Consequently, the true cost of Alternative #4 is probably in
excess of $5 million, thus putting it in very unfavorable position with
respect to Alternatives 9 and 10.
The complex suite of inorganic and organic compounds within the Goose Farm
hydrogeologic system demand that in-situ containment options be given a closer
evaluation. In-situ management alternatives such as Alternatives 9 and 10,
may offer a more effective and more reliable means of remedying the
groundwater contamination problems at the Goose Farm site. Moreover, these
alternatives could be used in conjunction with in-situ biological treatment
methods to eventually degrade the majority of the contaminants and obviate the
need for long-term maintenance and monitoring of the remedial plan.
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BIBLIOGRAPHY
Chiou, C.T., L.J. Peters, and V.H. Freed, "A Physical Concept of Soil-Water
Equilibria For Nonionic Organic Compounds", Science 206. 1979.
Kenaga, E. E., and C.A.I. Goring, "Relationship Between Water Solubility,
Soil-Sorption, Octanol-Water Partitioning, and Bioconcentration of Chemicals
in Biota", ASTM Third Aquatic Toxicology Symposium New Orleans, LA, 1978.
Karickhoff, W., D. S. Brown, and T. A. Scott. Water Res., 13. 241, 1979.
Lyman, W. J., W. F. Reehl, and D. H. Rosenblatt. Handbook of Chemical
Property Estimation Methods. McGraw Hill Book Company, 1982.
Mutch,Jr., R. D., "Subsurface Cutoff Walls: Design Considerations in the
Application of Ground-Water Recovery Programs", Proceedings of International
Water Conference of_ ESWP. 44th Annual Meeting. October 24-26, 1983,
Pittsburgh, Pennsylvania.
Mutch, Jr., R. D., G. DiPippo and J. Hearty, "Environmental Cleanup of the
Monroe Township Landfill", Proceedings of the ASCE National Conference on
Environmental Engineering, Atlanta, Georgia, July l'-31.
j
Water Related Environmental Fate o_f 129 Priority Pollutants,USEPA
440/4-79-029a, b., December 1979.
FMC Aquifer Remediation Systems, Site Assessment Report for the Goose Farms
Hazardous Waste Site, June 27, 1985.
Wehran Engineering, Supplemental Investigation of the Goose Farm Site, May
1985
Wehran Engineering, Analytical Results, Groundwater Monitoring Wells, Goose
Farm Site, March 1985
Wehran Engineering Analytical Results. Soil Samples - Volume 1, Goose Farm
Site, March 1985
Wehran Engineering Analytical Results, Soil Samples - Volume 2, Goose Farm
Site, March 1985
Wehran Engineering Analytical Results, Soil Samples - Volume 3, Goose Farm
Site, March 1985
Wehran Engineering Analytical Results, Soil Samples - Volume 4, Goose Farm
Site, March 1985.
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§tate of 2feui Uersey
DEPARTMENT OF ENVIRONMENTAL PROTECTION
OR. MARWAN M. SADAT. P.E.
DIRECTOR
DIVISION OF WASTE MANAGEMENT
32 E. Hanover St., CN 028, Trenton. N.J. 08625
LINO F. PEREIRA. P.E.
DEPUTY DIRECTOR
Edward C. Laird, Esq.
Archer & Grelner
One Centennial Square
P.O. Box 3000
Haddonfield, NJ 08033-0968
RE: Morton Thiokol, Inc.
Goose Farm RI/FS
Dear Mr. Laird:
This will acknowledge receipt of your letter of August 26. 1985 to Dr. Berkowitz
and the comments prepared by Aware, Inc. relating to the Goose Farm RI/FS. The
Jepartment, along with USEPA Region II has developed a Draft Record of Decision
(ROD) which outlines the actions to be taken at Goose Farm. The comments
submitted by Morton Thiokol and the public were taken into consideration in the
formulation of the ROD.
Please be advised that Morton Thiokol's comments were considered despite the fact
that they were dated and submitted to the Department after the expiration of the
30 day public comment period.
To start, I would like to point out that Morton Thiokol appears to have, at least
in part, misunderstood the purpose of the State's RI/FS. The RI/FS was intended
to generally determine the condition of the Goose Farm Site and suggest
alternatives for remedial action. Following the selection of an alternative, a
detailed design will be developed in order to define the specifics of the chosen
alternative. Additional data will be gathered during the design phase as needed.
Your comments raise some issues that are to be addressed during the design phase.
Response to Specific Comments on the RIt
1. While the full spatial extent of the plume has not been determined, it is
wholly unnecessary to make such a determination in order to find that plume
management is required. Additional data concerning the spatial extent of
the plume will be developed as needed during the design phase. in any
event, such additional data would not alter our selection of the chosen
remedial action alternative.
2. Although the total volume of ground water within the plume has not been
determined, such a determination is not required at this juncture and would
not affect the Department's selection of a remedial action alternative. We
intend to gather all additional necessary data to make such estimates during
the design phase.
\ew Jersey Is An Equal Opportunity Employer
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•Edtifcrfl C. Laird
We disagree that no effort was made to establish the volume of groundwater
flow within the plume. In fact, all data required for such a determination
was Included within the RI/FS and was considered.
4. Subsequent to the issuance of the Draft RI/FS, a Supplement to Volume II,
Appendix A was provided to the Department by its consultant. This
supplemental information provided an additional analysis of the stratigraphy
of the site and its Impact upon hydrogeologlc conditions. I have enclosed
this new information with this letter. This information in no way affected
our choice of the remedial action alternative.
5. While it is true that contaminant partitioning between ground water and the
aquifer skeleton can occur, more than sufficient data exists to establish
beyond question that true soil contamination and ground water contamination
exist.
6. While it is true that retardation factors were not estimated in the RI/FS,
we do not believe that such estimates are necessary and would certainly not
alter the Department's selection of a remedial action alternative. We
intend to determine actual retardation factors by treatability studies
during the design phase.
7. Subsequent to the issuance of the Draft RI/FS, a Supplement to Volume II -
Appendix A was provided to the State by its consultant. This supplement
provided additional analysis based in part upon work done by Wehran
Engineering, Including the Wehran geologic and hydrogeologic data from soil
borings (see attached Supplement).
8. We disagree that the priority pollutant list is an adequate analytical base
for the site. Due to th*e nature of Thiokol's operation, priority pollutants
were not expected to be the only types of contaminants found at the Goose
Farm site, and indeed, numerous non-priority pollutant organics not
associated with the natural environment were found.
9. We disagree with your assertion that a computer model is in any way
necessary in the selection of a remedial action alternative. We believe
that more than enough data exists to properly support our choice of the
selected alternative.
Specific Comments on the FS:
We disagree that it is necessary to quantitatively define remedial objectives at
this time. Ground water quality will be continuously monitored and compared to
then existing ground water standards. In the absence of such standards the
Department will employ Ames testing and other bioassay techniques to assess risk
and determine whether adequate remediation has been accomplished. We agree that
In light of the absence of concrete quantitative objectives, our estimate of an
18 month aquifer remediation process could vary. However, we must point out that
there are numerous factors which will influence the amount of time required to
achieve the desired remediation. Many of these factors cannot be adequately
Defined prior to additional treatability testing, pump tests and other studies to
performed during the design phase.
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Edward C. Laird
-3-
In conclusion, we appreciate Morton Thiokol's comments, and encourage your
continued participation in striving to achieve a solution to the problems at
Goose Farm. Although many of the issues raised are more appropriately addressed
during the design phase, we expect to continue our dialogue with you at that
time. Morton Thiokol's proposed alternatives are not wholly inconsistent with
the chosen alternative and we may further consider your proposals upon the
completion of additional studies at the site.
We invite you to contact us regarding the possibility of your performing the
remedial work as finally designed.
Very truly yours,
Marwan M.
rector
RMT:kep
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