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

-------
                                   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
18. DISTRIBUTION STATEMENT
19. SECURITY. CLASS fTllis Report)
     None
21. NO. OF PAGES
    108
                                              20. SECURITY CLASS (Thispage)
                                                   None
                                                                         22. PRICE
EPA Form 2220-1 (R«v. 4-77)   PREVIOUS EDITION if OBSOLETE

-------
                                                       INSTRUCTIONS

   1.   REPORT NUMBER
        Insert the LPA repoit number as it appear* on the cover of the publication.

   2.   LEAVE BLANK

   3.   RECIPIENTS ACCESSION NUMBER
        Reserved for use by each report recipient.

   4.   TITLE AND SUBTITLE
        Title should indicate clearly and briefly the subject coverage of the report, and be displayed prominently. Sei siihiitlc. if used, in smaller
        type or otherwise subordinate it to main title. When » report is prepared in more than one volume, repeal the primary title, add volume
        number and include subtitle for the specific title.

   S.   REPORT DATE
        Each report shall carry a date indicatini at least month and year.  Indicate the l>asis on which it was selected (<\x-. Joir <>/ mi/c. Jaic of
       approval, date of preparation, etc.).

   6.  PERFORMING ORGANIZATION CODE
       Leave blank.

   7.  AUTHORIS)
       Give name(s) in conventional order /John R. Doe. J. Robert Dor. etc.). List author's affiliation if it differs Ironi the performing ..ipani-
       zation.

   8.  PERFORMING ORGANIZATION REPORT NUMBER
       Insert if performing organization wishes to assign this number.

   9.  PERFORMING ORGANIZATION NAME AND ADDRESS
       Give name, street, city, state, and ZIP code.  List no more than two levels of an organi/ational hircarchy.

   10.  PROGRAM ELEMENT NUMBER
       Use the program element number under which the report was prepared. Subordinate numbers may be included MI parcniliCNCs.

   11.  CONTRACT/GRANT NUMBER
       Insert contract or grant number under which report was prepared.

   12.  SPONSORING AGENCY NAME AND ADDRESS
       Include ZIP code.

   13.  TYPE OF REPORT AND PERIOD COVERED
       Indicate interim Final, etc., and if applicable, dates covered.

   14.  SPONSORING AGkNCY CODE
       Insert appropriate code.

   15.  SUPPLEMENTARY NOTES
       Enter information not included elsewhere but useful, such as:  Prepared in cooperation with. Translation of. I'rcM-nu-d ai vnnlm-mv «t.
       To be published in. Supersedes, Supplements, etc.

   16.  ABSTRACT
       Include a brief (200 words or len) factual summary of the most significant information contained in the rcpuri. II the rr|x>n umlauts a
       significant bibliography or literature survey, mention it here.

   17.  KEY WORDS AND DOCUMENT ANALYSIS
       (a) DESCRIPTORS - Select from the Thesaurus of tnginecrir.g and Scientific Terms the proper auilion/cd terms Dial identify the major
       concept of the research and are sufficiently specific and precise to be used as index entries lor caulopni:.

       (b) IDENTIRERS AND OPEN-ENDED TERMS • Use identifiers for project names, code  names, equipment designators, etc. Use open-
       ended terms written in descriptor form for those subjects for which no descriptor exists.

       (c) COSAT1 1 It-LD GROUP - Held and group assignments are to be taken from the  1965 COSATI Subject CaK-pory List.  Since the ma-
       jority of documents are multidisciplinary in nature, the Primary field/Group assignment) will be specific discipline, urea of human
       endeavor, or type of physical object. The application!s) will be cross-referenced with secondary  I ield/< iroup assignments thut will follow
       the primary posting(s).

   18.  DISTRIBUTION STATEMENT
       Denote reusability to the public or limitation for reasons other than security for example "Release llnltmiicil." < lie any avaikihihiy to
       the public, with address and price.

   19.&20. SECURITY CLASSIFICATION
       DO NOT submit classified reports to the National Technical Information service.

   21.  NUMBER OF PAGES
       Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, il any.

   22.  PRICE
       Insert the price set by the National Technical Information  Service or the Government Printing Office, il known.
EPA Form 2220-1 (R.v. 4-77) (R«v«n«)

-------
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.

-------
                      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.

-------
                              -2-
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

-------
          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.

-------
                             -2-

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

-------
                             -3-
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.

-------
                             -4-
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.

-------
                             -5-


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.

-------
                             -6-
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.

-------
                             -7-
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.

-------
                             -8-

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

-------
                             -9-
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.

-------
                             -10-
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

-------
                             -11-
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.

-------
                             -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

-------
                             -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.

-------
                             -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.

-------
                            -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

-------
                                             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.

-------
                                        -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.

-------
                                        -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.

-------
                                         -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.

-------
            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.

-------
            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
                                                               ADDKE3S
          ^r (^y^^z.
                  S*
            -      ..-
          LU.&ZL
'*
                                                -71
                                                                                     - 7,

-------
      AME
                               AFFILIATION
                                                                ADDRESS
 15.
 16.
 18.
                A c\d
25.   .
            7/
27.  .
28.
30.

-------
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
                                                                             0
                         /^          -    -
                                                               i^jpJ  fJ.T
                                                                 1L)    j
                                                                     »X   /A./
                                                                           /
JJ^^ZU,  J*W,         P
                                wC&
                               	                    t/t'/
ry //,
L^.   ., £*^           w^e^^

-------
                                AFFILIATION
ACDPESS
20.
25.
25.
27.
23.
30.

-------
 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
                             ////  Jnrt  \ll-A r'
.
                                                              Gtt33

-------
       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

—
                                                                        •u^L


                                                                /C
                                                                f  *
                                                                         I I
                                                          'S
                                                                r
                                                          '//I!

-------
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
                                                    ADDRESS
                                                    /?* v  jet A^'
                                                                       r r  / ' C
'  J'Yv,  Yri  -'
 r^- 1/7,  ///• s.-sz
                           -/0^-f
                                              22ft

iA
n

                                                                         I1   U
n     i
\  ,f# Vfl '£

                                                ,   .
                                              L^£(-«.
        C '
       <\ti
                           •Hsn
                                                            Lfl.
        ,"  0

-------
    NAME
                           AFFILIATION
                                                      ADDRESS
 1*.
 15.
 16.
          f*~~+
                           ^c
 iTr
                           \*/& LK
                                                                      w.-
18.
                 \J
19.
                     \
                                                                 r?
                                                                    J ,
20.
                                  Th LP- H-S M A
22.
23.
 "7    v^
  ^c.' /  7< ^
25.
              JL
              S tf^t
26i/
  '
                               '•«•«•
                                                              X'
284

30.

-------
AFFILIATION
                                                                    ADDRESS
 32.
 33.

    ft
•3*.
35.
36.
37.
38.
40.
41.
42.
43.
44.
45.
47.

-------
Attachment G.

-------
                        ARCHER & GREINER
 on*e>*
            *oO »
            : HX.CM
            3*icou
     COUNSELLORS AT LAW

  ONE CENTENNIAL SQUARE

      P.O. BOX 3OOO

HAODONFIELD. N. J. O8C. --O968

       6O» • 795-2121

      OCX 60»  79S-OS74
              (•*»
          3Mt; .IIMH<
          Mil- CXu
 •OtHII I«*M

 •mi AOU<
»A4A » gOQVMinr   «r*lTON • luti] •
OHM3I 3MING   •»!.»»- «•»«.
'««'^H«O O»M
HUN M OOI*NG   %««U>I . JOlll
|0"*C 0**C"    3»«". 5«f(>.
            « .(««•
                              August  26,  1985
                                           -• •>
                                 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.
                                                                      ,.>

-------
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

-------
                               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

-------
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.

-------
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.

-------
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

-------
     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.

-------
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.

-------
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

-------
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.

-------
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

-------
                                       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:

-------
                                      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)

-------
                                       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

-------
                                    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

-------
 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

-------
                                      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,

-------
                                      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.                   '

-------
                                      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

-------
                           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

-------
                                    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

-------
                                      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.

-------
                                 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.

-------
                               §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

-------
•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.

-------
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

-------