&ER&
             United States
             Environmental Protection
             Agency
             Office of
             Emergency end
             Remedial Reaper
EPA/ROD/R02-85/023
September 1985
Superfund
Record of Decision:
                   Lipari Landfill, NJ
           (Second Remedial Action, 09/30/85)

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                                   TECHNICAL REPORT DATA
                            (Pteate read Inttructiont on the nvent before completing)
1. REPORT NO.
 EPA/ROD/R02-85/023
             3. RECIPIENT'S ACCESSION NO.
4. TITLE .AND SUBTITLE

 SUPERFUND RECORD OF DECISION
 Lipari Landfill, NJ
 (Second Remedial Action) 	
             B. REPORT DATE
              September 30, 1985
             B. PERFORMING ORGANIZATION CODE
7. AUTMOR(S)
             B. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                           1O. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
 U.S. Environmental Protection Agency
 401 M Street, S.W.
 Washington, DC.  20460
             13. TYPE OF REPORT AND PERIOD COVERED
              Final ROD Report
             14. SPONSORING AGENCY CODE

              800/00
16. SUPPLEMENTARY NOTES
16. ABSTRACT
           The Lipari Landfill site  is located .in Mantua Township,  Gloucester
       County, New Jersey and is adjacent to the towns of Pitman and Glassboro.
       The site is approximately fifteen acres in size; six acres of which were
       used  for hazardous waste landfilling activities.  Trenches excavated for
       sand  and gravel were backfilled with municipal refuse,  household wastes,
       liquid and semi-solid chemical wastes, and other industrial  wastes.  Al-
       though no detailed records  were kept, it has been estimated  that 12,000 cu-
       bic yards of solid wastes and 2.9 million gallons of liquid  wastes were dis-
       posed of at the site.  Wastes reported to have been disposed of include sol-
       vents, paint thinners, formaldehyde paints, phenol and amine wastes, dust-
       collector residues, resins  and ester press cakes.  Initial removal and reme-
       dial  actions completed at the site include:  fencing the entire fifteen
       acres, installing a bentonite/soil slurry wall keyed into the underlying
       aquitard, covering the site with an impermeable synthetic membrane liner,
       and installing a passive gas-venting system (see the ROD dated 8/13/82 -for
       additional information).

           The cost-effective remedial actions selected for this site include:
       installation of ground water/leachate and injection wells within the con-
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                           c. COSATi Field/Group
 Record of Decision
 Lipari Landfill, NJ  (Second  Remedial Action)

 Contaminated Media: gw, soil
 Key contaminants: arsenic, chromium, heavy
   metals, organics, phenols,  toluene
IS. DISTRIBUTION STATEMENT
EPA Pan* 2220-1 (R*v. 4-77)   PMKVIOU* COITION is OSSOLKTK
19. SECURITY CLASS (This Report)
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                                                                         21. NO. OF PAGES
                                                                            152
                                              20. SECURITY CLASS fTMl page/
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                                                                         22. PRICE

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    -ended terms written in descriptor form ta those subjects for which no descriptor custs.
     (c)COSATl MELD GROUP -Field and gtoup assignments are to be taken from the 1965 COS All Sultjvct (ak-p'ry List. Since the ma-
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LIPARI LANDFILL, NJ
    (Continued)
taimnent system to dewater and flush tha system; pumping and treating the
ground water/leachate from within the containment system (treatment prefer-
ence of the collected leachate is onsite pretreatment and discharge to the
POTW); installation and monitoring of ground water wells downgradient  of
the site;flushing the containment system to cleanse the encapsulated mater-
ial of water-borne contaminants; and continued pumping and treating of the
ground water should applicable standards not be met once flushing is termi-
nated.  Identification of remedial action alternatives to mitigate poten-
tially contaminated offsite areas will be made in the near future.  The es-
timated capital cost for this project is $3,464,000  and annual  O&M costs are
estimated to be $715,000.  These cost estimates will be affected by the off-
si te/onsite treatment systems ultimately designed.

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                      RECORD OF DECISION
                REMEDIAL ALTERNATIVE SELECTION
Site

Lipari Landfill, Mantua Township, New Jersey

Documents Reviewed

I am basing my decision primarily on the following documents,
which describe the analysis of cost-effectiveness of remedial
alternatives for the Lipari Landfill site:

  - Treatability Study of Contaminated Groundwater from the
    Lipari Landfill, Radian Corporation;

  - On-Site Feasibility Study for Lipari Landfill, Camp,
    Dresser & McKee, Inc.;

  - On-Site Hydrogeological Remedial Investigation of Lipari
    Landfill, Camp, Dresser & McKee, Inc.;

  - Summary of Remedial Alternative Selection, Lipari Landfill;

  - Staff summaries and recommendations;

  - Responsiveness Summary for the Lipari Landfill.

Description of Selected Remedy

1.  Install groundwater/leachate extraction and injection wells
    within the containment system for dewatering and flushing
    of the system.

2.  Pump and treat the groundwater/leachate from within the
    containment system until it reaches an elevation of approx-
    imately 100 feet above Mean Sea Level (Upper Cohansey).
   < The treatment preference for collected leachate is on-site
    pretreatment and discharge to the POTW.  Implementation
    is dependent on timely approval by the State of New Jersey
    and the local POTW.  If such approval is not provided, the
    leachate may be treated on-site and discharged to nearby
    surface waters, or transported off-site for treatment at
    a permitted hazardous waste facility.

3.  Install and monitor groundwater wells downgradient of the
    site within the Kirkwood Aquifer.

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 4.  Flush the containment system  to cleanse the encapsulated
    material of -water-borne  contaminants.   This operation
:  .•-•7«iwMjl.:'4»e.^
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                             -3-
          Summary of Remedial Alternative Selection
                     Lipari Landfill sTte
                 Mantua Township, New Jersey


Site Location and Description

The Lipari Landfill site is a partially remediated inactive
waste disposal site in Mantua Township, Gloucester County,
New Jersey, adjacent to the towns of Pitman and Glassboro.
The site is approximately fifteen acres in size; six acres
of which were used for hazardous waste landfilling activities.
The landfill is approximately 0.3 miles north of U.S.
Route 322 and 1.5 miles west of Glassboro State College.
Single family homes stand close to the northeast border of
the site; and apple and peach orchards surround the east and
southern border.

Figure 1 shows the general location of the Lipari Landfill
site.  Figures 2 and 3 present more detailed information
concerning the site and its surrounding area.

Initial removal and remedial actions completed at the site
include: fencing the entire fifteen acres, installing a
bentonite/soil slurry wall keyed into the underlying aquitard,
covering the site with an impermeable synthetic membrane
liner, and installing a passive gas-venting system.

Two surface water drainage systems flow near the landfill, as
shown on Figure 2.  The main drainage system, Chestnut Branch,
has its headwaters east and south of the landfill area.
Flowing past the eastern and northeastern borders of the
site, Chestnut Branch discharges to Alcyon Lake, approximately
1000 feet downstream.  Continuing from Alcyon Lake, Chestnut
Branch empties into Mantua Creek, which discharges into the
Delaware River approximately nine miles northwest of the
site.  Rabbit Run, a small tributary of Chestnut Branch,
derives its headwater flow from a small spring located adjacent
to the landfill site.  This stream flows along the north-
western edge of the landfill and discharges into Chestnut
Branch north of the landfill.

Parklands surrounding Alycon Lake are used for recreational
purposes.  However, recreational activities on the lake
itself have been banned by the Gloucester County Health
Department.

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                               -4-
  Disposal Operations

  The  site was purchased in  1958 by Nick Lipari  for  use  as  a
  sand-and-g ravel pit.  Approximately  six  acres  of the site
                                                        to
                                            -with wanicipal
  refuse, household wastes, liquid and semi-solid chemical
  wastes, and  other industrial wastes.  The  nonsalable portions
  of the excavated sands and gravels were  used  to cover the
  disposed wastes.  Liquid wastes were dumped into  the landfill
  from  1958 to 1969 and solid wastes were  disposed  of  there
  until May 1971, when the site was closed by the New  Jersey
  Solid Waste  Authority.  During this period, at least one
 explosion mud two ;-f i«««;'.«wer«.:;^c«pot*ed:v/«t ; the  landfill.

  Although no  detailed records were kept,  it has been  estimated
  that  12,000  cubic yard's of solid wastes  and 2. 9 'million
  gallons of liquid wastes were disposed of  at  the  site. The
  liquids disposed of at the site are thought to be largely
  uncontained.  The wastes reported to have  been disposed of
  include solvents, paint thinners, formaldehyde, paints,
  phenol and amine wastes, dust-collector  residues, resins and
  ester press  cakes.

  Numerous organic compounds have been identified at the site,
  mostly in leachate samples.  The most noteworhty  compound
 '                                  either r r* . snspecteoY human
- ^carcinogen V Totmd l"n'ltfigh 'troticetrtiraitTOtts .  Bother -wetewoTthy
 compounds include benzene, ethylbenzene, phenol and  toluene.
 Table  1  shows the compounds and their concentrations found in
 the Lipari Landfill leachate.  Table 2 lists  the  chemicals of
 concern  for the Lipari Landfill.

 EPA has  initiated enforcement action against  the  following
 firms  who have generated or transported hazardous wastes to
 the landfills Rota and Haa«r Owens-Illinois; •  an Manor Health
           Tncj J«naTtervlii Jonas, -Inc.
 Hazardous wastes dumped at the landfill have percolated into
 the groundwater under the landfill.  The wastes  have also
 leached out  into the embankments of Rabbit Run and  Chestnut
 Branch, contaminating the surface waters that run into these
 streams and  Alcyon Lake.

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                             -5-


Current Site Status

A removal action at the site was initiated in July 1982 by
the U.S. Environmental Protection Agency.  The removal action
consisted of the installation of a fence to limit access to
the landfill (see Figures 3 and 4).  In August 1983, a second
fence was installed along the eastern side of Chestnut Branch
to discourage the nearby residents from entering the contaminated
marsh area along the stream.

Based on the Record of Decision (ROD) signed August 3, 1982,
(Attachment No. 1) remedial construction activities at the
landfill began on September 7, 1983.  A 30-inch wide, soil-
bentonite slurry wall completely surrounding 15.3 acres of
the site was constructed under the supervision of the U.S.
Army Corps of Engineers.  The wall was designed to segregate
the bulk of the contaminants in the landfill from the surrounding
aquifer through the use of a low-permeability bentonite slurry
wall, keyed into the underlying low permeability Kirkwood
Clay Formation.  In addition, a 40-mil thick synthetic cap of
high density polyethylene (HOPE) was placed over the site to
exclude infiltration of precipitation.  The remedial action
also consisted of a passive gas-venting system, a surface
drainage system, final grading and revegetation.  Construction
of the containment system was completed in November of 1984.

EPA determined in the 1982 ROD that a second phase of the
remedial action should be implemented to improve the reliability
of the containment system.  At that time, the second phase
was defined as collection and treatment of the contaminated
groundwater within the containment system.  The implementation
of this remedial action was deferred in the 1982 ROD until
the compatability of the pretreated discharge with the local
Publically Owned Treatment Works (POTW) was evaluated.  In
addition, EPA determined that it was necessary to proceed
with the installation of the containment system and cap while
this evaluation was being done.

In the spring of 1985, in response to citizens* concerns, EPA
extended the existing chain link fence east of Chestnut Branch
(Figure 4) to further restrict access to the contaminated
marsh area.

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                             -6-


RBMEDIAL HTVBST1CATIOM ACTIVITIES AMD JtESOLTS

On-site Remedial  Investigation Activities

The  on-site  remedial investigation activities at  the  Lipari
Landfill site  included the following hydrogeological  investigations
of the landfill and the immediate area:
                                   of
    water monitoring wells.

    'Slug-testing 26 wells along the interior and exterior
    circumference of the slurry wall.

    'Yield-testing all wells greater than 2-inches  in diameter.

 . •   ^ Pomp and in}«ctio«?-t!estia^^^^

    "Pump-testing the Kirkwood  Formation.        ,

    'Collecting samples of the  leachate  for analysis and  for
    submittal to potential privately-owned treatment facilities.

On-site Remedial Investigation Results

The results of these investigation activities  indicated  the
following:

    'While there is some seepage out of  the containment system,
'        '
    ated
    Aquifer.

    'Currently, the net direction of potential seepage  through
    the slurry wall is inward at the southwest portion of  the
    site and outward at the north, northeast and southeast
    portion of the site.  An estimated 700 to 800  gallons  per
    day (gpd) are currently seeping through the slurry wall
    into *te;*^r^
    'The Cohansey Aquifer is flowing in a northeasterly direction
    toward the Chestnut Branch.

    'The hydraulic conductivity of the Kirkwood Clay  is approx-
    imately  1.1 x 10 -7 centimeters per second  (cm/sec).
    .Seepage  will .continue to flow into the Kirkwood  Sands  below
    ^thft Kirkwood "Clay ^Formation v«is along aa^the igroundwater
    level within the system is higher than "93 feet above Mean
    Sea Level  (MSL).  It is estimated 1,700  gpd  are  currently
    seeping  into the Kirkwood Clay.

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                          -7-
*The saturation of the entire Kirkwood Clay and the  contin-
 uous seepage of contaminants into the Kirkwood Sands  has
 not been confirmed by analysis of samples taken of  the
 Kirkwood groundwater.

'The estimated seepage flows are consistent with design
 predictions and are not attributed to construction
 deficiencies.

'Groundwater flow in the Kirkwood Sands is northeasterly
 towards Alcyon Lake.

'Dewatering of groundwater/leachate from,  and injecting clean
 water into, the Upper Cohansey portion of the containment
 system is technically feasible.

"Only three of the existing wells screened in the Cohansey
 Formation can be used as extraction or injection wells.

'The Lower Cohansey sands are approximately ten times  less
 permeable than the Upper Cohansey sands,  making dewatering
 of the Lower Cohansey technically impracticable.

'Hydrofracturing of the slurry wall is not probable  with a
 fifteen foot head differential across the wall.  Channeling
 of the wall is also not likely.

'Assuming that the leachate quality does not significantly
 differ with the samples submitted, all of the privately-
 owned treatment facilities contacted would accept and
 treat leachate from the Lipari Landfill.

'Potential seepage of contaminants to the Cohansey and the
 Kirkwood Aquifers presents an environmental and public
 health hazard.  Groundwater modeling indicates that
 bis (2-chloroethyl) ether will persist in the groundwater
 and migrate to the streams and lake.  Eventually, this
 compound may attain concentrations considered potentially
 hazardous to human health.

'The compatability of raw leachate with the treatment
 systems used at the local POTW has been confirmed in  the
 treatability study.  Therefore, pretreated leachate will
 have no adverse affects on the POTW treatment process.

'Leachability tests on extracted Lower Cohansey sands  demon-
 strate that the water-transportable contaminants are  reduced
 by 90% in the leachate after 10 pore volumes have been
 passed through the sample.

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                              -8-


 REMEDIAL ACTION ALTERNATIVES
 The 1982 ROD determined that the overall objective of further
 on-aite remedial action is to "improve the reliability of the
 containment system."  At that time, it was determined that
 this should be accomplished through installation of groundwater
 collection wells within the containment system and treatment
 During the On-site Remedial Investigation, it was determined
 that, should no further action be taken to enhance the
 containment system, two pathways of potential risk to the
 environment and human health would persist: (1) slow but
 continuous seepage of contaminants through the slurry wall
 into the downgradient Cohansey Aquifer and into the nearby
 surface streams, and eventually into Alcyon Lake; and
 VT2>) seepage '•*£•• coiitaMii»«t« ^ownwat^
^Tlay into TiTie1 ntlttcwbtflMtiqifff er , ' *whl*ch ^'f ifows^twarda *AlcyoTi
 Lake.

 Therefore, to meet the overall objective (as defined in the
 1982 ROD) of improving the reliability of the contaminant
 system, minimizing or eliminating the flow of contaminants
 from these two pathways is essential.  This could be achieved
 in any of several ways:

   (1) Complete removal of the source of contaminants;

   12J Reversal of the hydraulic gradient across the slurry wall,
       causing all jpotential .flow to be inward ;

   (3) Capture of the contaminants entering the Kirkwood Aquifer;

   (4) Solubilization and extraction of contaminants from the
       landfill.
    '*
 Remedial Alternative Options

 According to the draft national Oil and Hazardous Substances
 Contingency Plan (NCP) and current policy, five categories of
 remedial alternatives must be considered when evaluating
 candidate remedial options.  These categories are:

 I.  Off-site storage, destruction, treatment or secure disposal
     of hazardous substances at a facility approved under the
     Resource Conservation and Reaver y Act ( RCRAI .  .Such a
                              compliance *t±th -All . ..other
     applicable EPA standards (e.g., Clean Water Act, Clean
     Air Act, Toxic Substances Control Act);

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                               -9-
 II.  Alternatives that attain all applicable or  relevant
      Federal public health and environmental standards,  guidance,
      and advisories;

III.  Alternatives that exceed all applicable or  relevant
      Federal public health and environmental standards,
      guidances,  and advisories;

 IV.  Alternatives that meet the CERCLA goals of  preventing  or
      minimizing  present or future migration of hazardous
      substances  and protect human health and the environment,
      but do not  attain the applicable or relevant standards;

  V.  No Action.

  Potential on-site remedial alternatives for the Lipari  Landfill
  site have been  classified into four broad options.   A description
  of these options and their related NCP categories are discussed  .
  below:
                                                 «

  1.  Complete Removal (Category I)

      Under this  option, the containment system would be
      dewatered and the leachate/groundwater would be treated
      in the most cost-effective manner.

      After the site has been dewatered, the cap  would be removed
      and the site would be excavated to remove the contaminated
      soil, refuse and miscellaneous bulk material.  This material
      would be disposed of in a RCRA-permitted treatment, storage
      or disposal facility.  Such a facility must also be consistent
      with EPA's  Off-site Policy for CERCLA.  The excavated  site
      would be filled with clean material, compacted, graded to
      approximate local conditions, and seeded.   Excavation  would
      need to be  carried out within an enclosure  to minimize the
      release of  volatile organic compounds to the environment.

  2.  Enhanced Containment  (Category IV)

      This option consists of dewatering the groundwater/
      leachate from within the containment system until the
      aqueous level within the containment system is below that
      of the groundwater outside.  This change in hydraulic
      gradients would ensure that any potential flow through
      the slurry  wall is into the system, thus precluding any
      additional  off-site migration of contaminants.   The
      groundwater/leachate pumped from the containment system
      would be treated and disposed of in a cost-effective
      manner.

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                             -10-
        Enhanced Cohtai!«B«nit;^Optifeon •'w-itti *on-« it« *preti?ewtment
    and discharge to the local POTW was the second  phase
    remedial action as described in the 1982 ROD.

3.  Flushing of the Encapsulation System  (Cleanup)
    (Category II, III or .IV depending on  the level  of
    treatment achieved)
         "this option, ^m "attempt -wotii'daibe^maiae&OT ?batch-i«type operation .
    Other alternatives to this option consider whether the
    flushing water should be clean upgradient groundwater,
    public water* or treated post-flushing water  pumped from
    the site.

    Should treated post-flushing water not be used for reinjection,
    it would have to be disposed of in a cost-effective manner.

4.  No Action (Category V)

    Under this option, the site would be left in  its present
    condition ;!ana a vgi»mfcdwateT .'jwiiitoring i>rt>grani would be
    implemented.

Components of the Reaedial Action Options

The remedial action options described above  can be broken
down into the following components:

  •.Disposal
  'Leachate collection
  'Treatment of various waste streams

A variety of technologies exist that could make up these
components (Table 3).  These technologies were subjected to a
technical, environmental, public health, institutional, and
cost screening respectively.  Those technologies  that passed
this «creeniiig (Table 4) wera integrated into candidate
         fil t •*»**!• j *"»« *»"* j»pa Lasted • in detail .


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                             -11-
Groundwater modeling revealed that the bulk of future potential
contamination from the landfill to the environment would be
through the Kirkwood Clay into the Kirkwood Aquifer.  Therefore,
capturing the leachate entering the Kirkwood Aquifer by
pumping the aquifer became a component of candidate remedial
alternatives.

Candidate Remedial Alternatives

Seven candidate remedial alternatives (Table 5) were evaluated
in detail.  Each of these alternatives have subalternatives
which were in turn evaluated.  The following are descriptions
and evaluations of all alternatives, and subalternatives.

Alternative 1 - Complete Removal

Dewater the containment system and treat and dispose of the
collected leachate.  Remove the existing cap, excavate the
contaminated soil, refuse and miscellaneous bulk material,
and transport this material to a RCRA-permitted 'secure
landfill that meets EPA's Off-site Policy for CERCLA wastes.
Fill with clean material, compact, grade to approximate
local conditions and seed.  Excavation would have to be
carried out within an enclosure to minimize the release of
volatile organic compounds to the environment.

The subalternatives represent alternate means of treating
and disposing of the leachate and are as follows:

(a) Off-site Treatment at a Privately-Owned Treatment Storage
    and Disposal Facility.

    Store the leachate on-site in a holding tank sized to
    contain a three-day flow.  Transfer the leachate from the
    holding tank to a series of tank trucks using a 5-day work
    week schedule.  Transport the leachate to an off-site
   .facility for treatment and disposal.

(b) On-site Pretreatment and Discharge to the Local POTW

    An on-site pretreatment facility will have to comply with
    the pretreatment requirements of both the local POTW and
    the NJDEP.  Therefore, an on-site pretreatment facility at
    Lipari would includet a flow equilization basin, a
    precipitation/flocculation/sedimentation reaction system
    to remove metals and suspended solids, air stripping to
    remove volatile organics, a filtration/activated carbon
    adsorption system to remove phenols, and treated leachate
    holding tanks to permit monitoring and to ensure discharge
    acceptability by the POTW.

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                             -12-
     Sludge  generated will be disposed  at  a permitted off-site
     facility.  Air  emissions will be controlled  by the use  of
     vapor-phase carbon units.

 Ic)  On-site Treatment arid Discharge to '"Chestnut ^Tanich

     Discharge to Chestnut Branch would require the removal  of
     solids, BOD, COD, and TOC, as well as reduction of priority
     pollutants in compliance with NJDEP's discharge criteria
     for  Chestnut- Branch.  Two alternate technologies could  be
     .used to meet these criteria, the PACT (powdered activated-
     carbon  treatment^ process or a physical /chemical itreatnent
     process.  Waste streams generated "by  either "facility
     would be treated on-site or disposed  of at an  appropriately
     permitted facility.

 Under the complete  removal alternative, the source of the
 contamination would be removed by excavation, thereby achieving
 the  goals of site remediation.  However,  major risks are
.associated  with the implementation of  this alternative.

 This alternative is the most difficult to implement because
 of the problems associated with excavation withfn  a controlled
 environment.  In addition, by removing the existing cap from
 the  containment systea, the trapped volatile organics would
 probably be released.  Even though excavation would be done
 within an enclosure, the potential for release into the
 atmosphere  and the  impacts on the local community  are expected
 to be significant.

 Excavating, handling, and transporting approximately 864,000
 cubic yards (CY) of hazardous material pose numerous hazards.
^-Exposed wastes would .const it u t e ..an , extreme direct-contact
                  workers/ and would create a .hazardous atmos-
phere within the excavation structure.  Therefore,  this  the
least desirable of any of the alternatives with  regards  to
worker safety.  Because of the large number of trucks  used to
transport the hazardous material to a RCRA-permitted facility,
additional safety hazards exist under this alternative in the
form of potential traffic accidents and hazardous waste  spills.
i*t •s4*,>aBWkl« policy Jto&*x+ue *&»&DaBe 
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                             -13-
 Finally,  this  alternative has the highest cost of all altern-
 atives  considered.

 Alternative  2  -  No Action but Pump the Kirkwood Sands (Enhanced
                 Containment)

 Leave the encapsulation  system  in its present state but pump
 the Kirkwood Sands beneath  the  site. Utilize four wells to
 capture vertical seepage from the containment system which
 percolates through the Kirkwood Clay into the underlying
 Kirkwood  Sands.   Treat this collected leachate by one of three
 subalternatives:

    (a)  Off-site  Treatment at a  Privately Owned Treatment
        Storage or Disposal  Facility;

    (b)  On-site Pretreatment and Discharge to the Local POTW;

    (c)  On-site Treatment and Discharge to Chestnut Branch.

 The concept  for  this  alternative is that once the entire
 thickness of the Kirkwood Clay  is saturated with contaminated
 groundwater/leachate, the bulk  of the contaminants leaving
 the site  would be through this  pathway into the Kirkwood
 Aquifer.   Therefore,  the goals  of the second phase remedial
 action  would be  partially met through the implementation of
 this alternative. While the potential remains for seepage of
 contaminants through  the slurry wall into the Cohansey Aquifer
 and ultimately into the  streams and lake remains under this
 alternative, the potential  for  seepage.of contaminants into
 the Kirkwood Aquifer  would  be removed.  It would take approx-
 imately 4 years  for the  groundwater in the containment system
 to naturally reach a  steady state at the 107 foot elevation.
 At this elevation, approximately 150 gpd would seep through
-the slurry wall  and approximately 1500 gpd would seep vertically
 through the  Kirkwood  Clay.

 Seepage of contaminants  through the slurry wall would violate
 applicable groundwater criteria and pose a potential risk to
 human health.  As noted  above,  seepage through the slurry wall
 eventually reaches the surrounding streams and lake.  The
 estimated concentration  of  bis  (2-chloroethyl) ether in the
 lake due  to  potential slurry wall seepage would be 0.13ppb
 ppb which would  pose  a health risk.

 Disregarding this risk,  this alternative is technically
 feasible  and implementable.

 It is unknown  how long it would take for the contaminant concen-
 trations  found in the groundwater in the containment system
 and in  the Kirkwood Aquifer to  be reduced to levels that would
 meet all  relevant and applicable groundwater standards.  However,

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                             -14-


It i« estimated that It would taXe 35 year s to reduce the
contaminant concentrations of the groundwater in the contain-
ment system to 10% of the initial concentrations found.
Likewise, it is estimated that it would also take 35 years
for the contaminant concentrations found in the Kirkwood
Aquifer to be less than 1% of the initial concentration
observed in the containment system.  This contaminant
concentration reduction phenomenon is expected to occur due
to Turtuml f lashing of the naterial in the containment system.

Due to these unknowns, the actual life of the operation
cannot be determined at this time.  The time estimates given
were used for alternative comparison and cost-estimation
purposes only.  The actual life for this alternative will be
determined during actual operation.  Throughout the operation,
periodic evaluations will determine the effectiveness of the
alternative and the need to continue the operation or establish
alternative concentration limits .

The time estimates for the other alternatives discussed below
were also used for alternative comparison and cost estimation
purposes only.  However, since the effectiveness of each
alternative discussed below will have to be determined during
the operation of that alternative, the periodic evaluation
process would need to be performed for each alternative.

Alternative 3 - Dewater the Encapsulation System (Enhanced
                Containment)

Dewater -the 43ppec Cohaasey ..forjnation within the -containment
                                             by ?one of the
following subalternatives:

   (a) Off-site Treatment at a Privately Owned Treatment,
       Storage and Disposal Facility;

   (b) On-site Pretreatment and Discharge to the Local POTW;

  . stc;) .On us jLtc Trailnirnt. and .rviff^NMrg** 
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                             -15-
Other benefits to dewatering the containment system include a
decrease in the-vertical seepage through the Kirkwood Clay
due to the decrease of driving head, and a decrease of potential
degradation of the slurry wall due to the decrease of the
wetted surface area.

As indicated before, Alternative 3(b) was the Phase II remedial
action identified in the previous Lipari ROD to achieve the
objective of improving the reliability of the containment
system.  However, there is a health risk associated with this
alternative.  During the Phase II on-site remedial investigation
and feasibility study, it was found that the majority of the
potential seepage out of the containment system would be through
the Kirkwood Clay.  Because the Kirkwood Aquifer is believed
to discharge to Alcyon Lake, this potential seepage poses an
environmental and public health risk at the lake.  Modeling
results show that bis (2-chloroethyl) ether would persist in
the lake in concentrations exceeding federal Water Quality
Criteria (0.41 vs. 0.03 ppb).

Disgregarding this risk, this alternative is technically feasible
and implementable.                              »

An estimated 28 years would be required to reduce the contaminant
concentrations of the groundwater in the containment system to
10 percent of the initial concentrations.

As stated above, this concentration reduction phenomenon is
expected to occur because of natural flushing of the material
in contact with the groundwater.  Under this alternative,
care would need to be exercised in deciding when to terminate
the operation.  Should the contaminant concentration be
reduced enough for the responsible agencies to decide to
terminate the operation of this alternative, it is likely that
the groundwater levels would rise and saturate materials that
had been dry during the operation of the facility.  This
resaturation of materials could potentially cause leaching of
chemicals, again threatening the environment and human health.

Alternative 4 - Dewater the Encapsulation System and Pump the
                 Kirkwood Sands (Enhanced Containment)

Dewater the Upper Cohansey formation within the containment
system.  In addition, pump and collect the vertical seepage
from the encapsulation into the Kirkwood Sands beneath the
site.  Under this scenario, two different waste streams would
be collected (leachate/groundwater from the Cohansey within
the encapsulation and leachate/groundwater in the Kirkwood
Aquifer).  Treat both waste streams using one or more of the
following subalternatives:

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    (a) Off-site Treatment at a Privately Owned Treatment
        Storage and Disposal Facility;
       *0fi-*tft» ^Piretwatnewt emd Discharge to th« Local POTW;

    (c) On-site Treatment and Discharge to Chestnut Branch.

 Because this alternative goes beyond Alternative 3, it meets
 the objective of the Phase II remedial action of improving
 the reliability of the containment system.  In addition,  this
             action witiga tea ^^^p^
          seepage
 Therefore,  should the perceived risk of  contamination of the
 Kirk wood Aquifer be accurate,  this alternative is considered
 superior to Alternative 3  on an environmental/public health
 basis.

 This alternative is considered technically feasible and
 implementable .
 concentrations of the groundwater to be reduced. to 10% of the
 initial concentrations found.   In addition,  an estimated
 25 years would be required  for  the contaminant concentrations
 in the Kirkwood to be less  than 1% of the initial concentrations
 observed in the containment system.

 As in Alternative 3,  should the operation of the system be
 terminated, leaching  of contaminants may recur due to the
 resaturation of materials previously kept artificially dry.
 This potential leaching of  chemicals would again threaten the
..environment and human health.

 Alternative 5 - Flush the Encapsulation System TCleanup)

 Dewater the Upper Cohansey  Formation within  the containment
 system.  Once this operation is completed, re-fill the contain-
 ment system with "clean water".  Extract the now-contaminated
 water from the containment  system while injecting clean
 water into the system to "flush out" the contaminants from
 the aoila and debris.  Continue this operation until the
 water within the containment system meets all relevant and
 applicable groundwater crtieria or until concentrations are
 achieved that would not cause adverse risk to any receptors
 should they be released. Variations in what makes up the
 clean flushing water  and how the extracted leachate is handled
 constitutes the following subalter natives:

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                             -17-
   (a) Treat the extracted leachate/flushing water on-site
       using either a PACT process train or a physical/chemical
       treatment train.  Re-inject the treated effluent for
     „• flushing water;

   (b) Pretreat the extracted leachate/flushing water on-site
       and discharge to the local POTW.  Use either upgradient
       groundwater or water from local public supply as clean
       water;

   (c) Treat the extracted leachate/flushing water on-site
       and discharge to Chestnut Branch;

   (d) Proceed as in 5(a), but omit the initial dewatering of
       the system.

This alternative partially meets the objective of the Phase II
remedial action of ensuring the reliability of the containment
system.  This alternative is an active attempt too remove the
water-borne contaminants in the containment system.  However,
there are two potential risks involved:

      1. The water level inside the containment system will be
         kept higher than the groundwater level in the north,
         east, and southeast side of the site, resulting in
         a potential flow out of the containment system in
         these areas.  This outward flow potential could
         result in additional contamination of the Cohansey
         Aquifer, the marsh area, the surrounding streams, and
         Alcyon Lake.

      2. There is no provision for capture of potential seepage
         to the Kirkwood Aquifer.  Risks associated with this
         condition have been defined above.

The potential contamination of the streams and Alcyon Lake
due to potential flow through the slurry wall could be
mitigated under a seepage collection system, which may be
developed under the authorization of a subsequent Lipari ROD.
As stated previously, an Off-site Remedial Investigation and
Feasibility Study (RI/FS) is presently being prepared for the
Lipari Landfill.  This Off-site RI/FS will look at the need
for and alternatives to remedial action for the off-site
areas.  These off-site areas consist of the marsh area, the
streams surrounding the site and Alcyon Lake.

Disregarding these risks, this alternative is technically
feasible and implementable.

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                              -18-
                                           the potential to
ei««na« the <»at«Ti«l iin the ^conta'iiunent ^system !of *w*ter->borne
contaminants.  The  removal of  the  water-borne contaminants
reduces the  future  risk of contaminants leaching from the
material  within the containment  system after operations at
the  site  are terminated.  Therefore,  after the termination of
a  successful flushing operation, on-site  presence would be
limited to a monitoring program.
•The ^c!mi;c«1.^oiBpo
and injection of groundwater, are proven  technologies.
The extent of reduction of contaminants will be  limited by
the technology available.  Based upon a laboratory soil
leachability test conducted with soils from Lipari, it  is
expected that 90% of the water-transportable contaminants
will be removed from the leachate with the  passing of 10 pore
volumes of water.
             f            -      .-s: •          the threat
of future contaminants entering the environment 'from the site
makes this alternative attractive.  While  it  is unknown when
the contaminant concentration  in the groundwater within the
containment  system will meet all applicable and relevant
standards and statutes under this alternative,  it has been
estimated that it would take 9 years to  remove  90% of the
water-borne  contaminants from  the containment system.
Termination  of this alternative would have to be determined
during operation.  As with all other alternatives, the above
time estimate was used for alternative comparison and cost
estimating purposes only.

mternative "6 - "Flush tlie "BncapBiil«tIi3Ti ^SyWtem  -atiiS •Pump "the
                Kirkwood Sands (Cleanup)

Under this scenario, subalternatives 6 (a)  through 6(d) would
coincide with subalternatives  5 (a) through 5(d) except that
Alternative  € subalternatives  would include pumping of the
Kirkwood Sands to draw potential vertical  seepage out of the
containment  system.

WKtle "this alternative addresses ^ the -ptftenttal  cotftamiiiati^ra
of the Kirkwood Aquifer through pumping  of the  Kirkwood
groundwater, the other concerns identified in the discussion
of Alternative 5 are the same. Under Alternative 6, the
estimated time required to reduce the water-borne contaminants
from the system is 8 years as  compared to  9 years for
.Alternative  5.

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                             -19-
Alternative 7 - No Action

Under this option, the site would be left in its present
condition and a groundwater monitoring program would be
implemented.  In this program, water level measurements would.
be taken in all wells on a regular basis.  In this manner,
differential head conditions could be monitored that would
indicate the direction of groundwater flow across the contain-
ment wall.  In addition, all wells screened within the Kirkwood
Formation and all paired Cohansey wells would be sampled on a
quarterly basis.  These samples would be analyzed quarterly
for indicator pollutants and annually for priority pollutants
to assess changes in any seepage conditions from the containment
system.  In this manner, the extent and nature of any migration
of contaminants out of the containment system would be monitored
and the need for any future remedial action could be planned
accordingly.   .

This alternative does not meet the objective of *the Phase II
remedial action to improve the reliability of the containment
system.  In addition, the groundwater within the containment
system does not meet any of the relevent and applicable
groundwater criteria.

Modeling has determined that continued seepage out of the
containment system, even at the estimated potentially slow
rate, poses a threat to the environment and human health.
Concentrations of chemicals of concern, specifically bis (2-
chloroethyl) ether, a suspected human carcinogen, would persist
at levels considered a potential threat to human health (1.2 ppb)

Alternative 8 - Batch Flush the Containment System (Cleanup)

This alternative is substantially similar to Alternatives 5 and
€, except in the mode of operation.  In Alternatives 5 and 6,
once the containment system is initially dewatered and filled,
the dewatering-reinjection operation would be continuous and
concurrent.

In contrast, under Alternative 8, flushing would be a batch-
type operation.  That is, the dewatering and the injection
operations would not be done at the same time, but in sequence.
Under this system, certain problems perceived with flushing
should be mitigated.  Under the continuous flushing operation
described for Alternatives 5 and 6, a potential exists for
short-circuiting - a phenomenon in which water seeks the path
of least resistance.  Channels between injection wells and
extraction wells can develop when short-circuiting occurs,
allowing potential pockets of contaminants that would remain
unflushed.  This phenomenon would be expected to occur at

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                              -20-


 Lipari because of the heterogeneous makeup of the landfill
 and the varying compaction of layers,  it is believed that
 short-circuiting could be overcome by completely draining and
 re-saturating the system consecutively.

 An estimated 15 years would be required to flush 90% of the
 water-soluble contaminants from the system.  This is 6 to 7
 years longer than the estimates for the other flushing
 alternatives* iHowever* *hi8 m>de of operation is expected to
 remove the contaminants more effectively.

 Variations to Alternative 8 are identical to those described
 under the discussions for Alternatives 5 and 6.  The other
 considerations discussed under the other flushing alternatives
 hold true for Alternative 8.  Therefore, this alternative is
 considered technically superior to both Alternatives 5 and 6.

 As discussed under Alternative 5^ the intent of a flushing
 operation is to cleanse the site so that, should the containment
 system fail, the rise in groundwater within the system and
 the resaturation of the soil and debris would not cause
 future off-site contamination.  Therefore, after a successful
 flushing operation, long-term involvement would be limited to
 a monitoring program.

 Evaluation of Subalternatives for Leachate Treatment Process
 and Ultimate Disposal

 Most of the alternatives discussed above showed subalternatives
;s^ subaltef natives :
    (a)  Off -Site Treatment at a Privately Owned Treatment,
        Storage and Disposal Facility.

        This s ubalter native is technically feasible, implementable
        and poses minimum risks.  There are several privately
        owned treatment,  storage and disposal facilities in
        ftto* ,*tm* £^                      f* wastes for treatment
    .; • • .r-^tfjtoa^di^pOM 1 , yfor thim ^t:±on  t^o jsbe daplemeoted, ..the
        particular facility's compliance with all environmental
        laws would have to be ensured.   Two disadvantages to
        this subalternative exist: (1)  risk of potential
        traffic and spill accidents, and (2) a high present-worth
        cost.  However, use of an off-site treatment facility
        for a short-term  operation - e.g. initial dewatering of
                                        eompe titi^e ^witfa othe r

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                             -21-
   (b) On-site Pretreatment and Discharge to the Local POTW.

       The pretreatment process train is necessary to comply
       with the local POTW's pretreatment regulations.  This
       subalternative is feasible, poses the least risk, and
       has the lowest present-worth cost of the leachate
       treatment subalternatives.  However, the implementation
       of this subalternative will be the most difficult of the
       leachate disposal subalternatives.  Negotiations with
       the local POTW are ongoing.  The potential choice of
       this subalternative will depend on these negotiations.
       Significant legal and liability concerns are central to
       these negotiations.  Table 6 shows the discharge
       limitations for the local POTW.

   (c) On-site Treatment and Discharge to Chestnut Branch

       This subalternative is technically feasible.  However,
       there is concern over its implementability and certain
       risks associated with treatment efficiencies for
       several chemicals.  The public may perceive discharging
       effluent, even though treated, as continuing the
       discharge of contaminants into Chestnut Branch and Alcyon
       Lake.

       Two treatment processes were investigated for this sub-
       alternative, the PACT process and a physical/chemical
       process.  There is concern that some substances,
       specifically bis (2-chloroethyl) ether, would not be
       adequately removed from the effluent and may pose a
       health risk at the lake if the effluent is discharged
       to Chestnut Branch.  For this leachate disposal option
       to be considered further, this risk must be mitigated.
       Table 7 shows the draft effluent limitations for the
       critical toxic pollutants with respect to discharge to
       Chestnut Branch, as determined by the State of New
       Jersey.  Pilot studies for these treatment processes
       may be required to refine treatment efficiencies.

As indicated above, except for a short-term process, the most
cost-effective, technically feasible, implementable and
environmentally-sound subalternative for leachate treatment
and disposal is to pretreat the leachate/groundwater on-site
and discharge it to the local POTW.  As such, for the purposes
of comparing the eight major alternatives, it was assumed
that the leachate/groundwater for all the alternatives would
be treated at the local POTW.

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                              -22-
 Comparison of Alternatives
       * IfletftlTteB -«the r-isfgut "a^wttti-ws -w ^escrtbett -above
 and summarizes the costs and the technical, environmental and
 institutional factors associated with each alternative.
 The alternative comparison process by which the recommended
 alternative was chosen is described below.

 As discussed above, the No-Action Alternative does not achieve
• ;tfo«---goil^-"^e3Phase;'5TrT«^                           .
 Landfill.  The potential lor grouhdwater/leachate seeping
 through the containment system threatens the environment and
 public health.  Bis (2-chloroethyl) ether is estimated to be
 found in the lake at levels of 1.2 ppb which is of concern.
 The life of the encapsulation system has been estimated to be
 30 years.  However, this expected life could be shortened due
 to the degradation effect of the chemicals in the containment
 system.  Should effectiveness of the containment system be
 reduced , the threat to rtfee enviroiuneirt and rptiblic 'health
 would "be Increase's. 'Therefore, IClternative T TlWlttti-orf) wa
 determined not to be appropriate.              *

 At the other end of the spectrum, the Complete Removal Alter-
 native removes the source of the contamination and so the
 threat to the environment and human health.  However, the
 risks associated with the implementation of this alternative
 and the inherent difficulties of such a large-scale operation
 makes this alternative impractical.  Two other factors dis-
 favor the Complete Removal Alternative, the high cost of the
 alternative ($288 million vs. $10.2 million for the next most
..jcostly alteroative) -and ±he .scarcity of secure RCRA-permitted
 landfills .that could and would accept approximately 864,000 cy
 of hazardous materials.  Therefore, it was determined that
 Alternative 1 (Complete Removal) is not feasible for the
 Phase II Remedial Action for the Lipari Landfill.

 The two major groups of alternatives to be considered are
 what have been categorized as the 'Enhanced Containment" and
 the "Flushing" Alternatives.  Both of these alternatives have
 :3MurijtMis , subaltern^!- 1 »«F- «*<»> «»d without .the accompanying
 In the discussions above, it was mentioned that potential
 seepage from the landfill through the Kirkwood Clay into the
 Kirkwood Aquifer would pose a threat to the environment and
 public health because of the resultant concentrations of the
 chemicals of concern in the streams surrounding the landfill
 «&d Alcyon Lak«.  The data *v«il*ble do not support the
'-^nt^tt^Ti^h^                                          the
 entire thickness of the Kirkwood Clay and are continuously
 seeping into the Kirkwood Aquifer.  The contamination currently
 observed in the Kirkwood Aquifer (under the landfill only)

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                             -23-
may be due to improperly installed wells which have subsequently
been corrected.  Therefore, the contamination may have been
the result of a past singular event and may not be continuing.

To protect the environment and public health, capture of any
continuous seepage into the Kirkwood Aquifer should be under-
taken.  However, since it is not known whether the Kirkwood
Clay is saturated with contaminants throughout its thickness
and seepage of contaminants into the aquifer is continuous,
the implementation of this action would be premature.  To
determine whether seepage is continuous, wells should be
installed to further monitor the quality of the Kirkwood Aquifer
downgradient of the landfill.  Should the data confirm the above
and the groundwater exceed applicable and relevant criteria,
pumping of the Kirkwood Aquifer to capture the seepage and
treatment of this groundwater/ leachate would be warranted.

The "Enhanced Containment" alternatives meet the objective of
the Phase II Remedial Action as defined in the previous ROD
for the Lipari Landfill: to improve the reliability of the
containment system.  With enhanced containment the seepage of
contaminants out of the system is controlled at the source.
However, there are several disadvantages to these alternatives:

      (1) The length of time the enhanced-containment program
          is likely to be operating is estimated to be 23 to
          28 years and potentially longer.

      (2) The source of the contamination remains on-site.
          Since the containment system has been dewatered,
          the contaminated debris and soils in the Upper
          Cohansey remain dry during the enhanced-containment
          operation.  Any natural flushing that would have
          occurred due primarily to groundwater contact will
          have been stopped.  The means of contaminant reduction
          under this alternative is biological and chemical
          decomposition.  In addition, some contaminant removal
          would occur through the dewatering operation.

      (3) Future seepage of contaminants from the landfill is
          possible.  Once implemented, should the operation
          of the enhanced-containment operation cease, the
          water level within the containment system will
          gradually rise to the 107-feet MSL elevation.
          The level may rise higher, depending on the degree
          of potential degradation of the slurry wall.  This
          increase in water level will resaturate the contaminated
          materials previously kept artificially dry which
          may in turn leach contaminants into the groundwater.
          The potential for contaminants leaving the site
          will, therefore, again pose a health threat.

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                             -24-
The future risks identified with the Enhanced Containment
                   iyeinitigated \through ^m. -fgood monitor ing
                               '
program "atw-'^aSert **the ^*seg*il>»to*y '"*afeac4e«" *o ••4*e-'»eic-i»tence -of
new leachate and the need to remediate this potential off-site
contamination.

The Flushing Alternative has the potential for addressing the
risks associated with the Enhanced Containment Alternative,
at an incremental investment in capital costs.  Therefore,
    Tlushing Alternative <*»« t>e«n cho«*n f or -the Phase II
                    ^
Alternative will be discussed in detail in the following
section.

Recommended Alternative

As stated above. Flushing has been chosen as the recommended
alternative.  The rationale for this choice is further described
below.

The Flushing Alternative meets the objective of* the Phase II
remedial action for the Lipari Landfill: to improve the
reliability of the containment system.  By controlling the
leachate, the containment properties of the encapsulation
system are enhanced.  Removing the water-soluble contaminants
from the system mitigates the potential for future contamination
and improves the overall remedial action for Lipari.

Using the flushing mode described in Alternative 8, it would
take 15 years to flush 90% of the water-soluble contaminants
from the system.  This is 6 to 7 years longer than the estimates
determined for the other flushing alternatives.  However,
since the Alternative 8 mole is considered to be technically
superior to the other alternatives and since it is expected
to mitigate the short-circuiting problem, the time differential
is not considered significant.

While there is the potential for contaminants to seep through
the slurry wall during flushing, this problem can be
mitigated through an off-site remedial action to be developed
under the current Off -site RI /PS.  Under the mode of flashing
operation contemplated, the water level will increase and
decrease throughout the operation.  Therefore, this potential
exists only 50 % of the time.  The long-term benefits that could
be realized under the flushing alternative are considered to be
worth the short-term risks, especially since these risks could
be mitigated.                 .

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                             -25-
The National Contingency Plan states that: "The appropriate
extent of remedy (for a remedial action) shall be determined
by the lead agency's* selection of a cost-effective remedial
alternative which effectively mitigates and minimizes threats
to and provides adequate protection of public health, welfare
and the environment".  The Flushing Alternative meets this
requirement.  While the Flushing Alternatives show a higher
present-worth cost when compared to the Enhanced Containment
Alternatives, (see Table 6), they are within the level of
accuracy associated with cost estimates developed under an
RI/FS.  In addition, the Enhanced Containment costs shown do
not include the possible need for replacement of the slurry
wall.  When this cost is included ($2.1 million), the present
worth costs of the respective alternatives are more comparable.
The added benefits of removing the water-soluble contaminants,
and removing the potential future environmental and public
health risks, are worth the added cost.

EPA1s CERCLA Off-site Policy discusses the Agency's preference
for treatment, reuse or recycling of materials.* This policy
states: "When developing remedial alternatives, treatment,
reuse or recycling must be considered.... Detailed analysis
of these alternatives should include considerations of long-
term effectiveness of treatment and comparative long and
short term costs of treatment as compared to other alternatives"
Flushing of the Lipari Landfill is considered treatment of the
contaminants within the system.  The Agency's position is
that the benefits of cleansing the containment system of
water-soluble contaminants justifies the additional cost
relative to enhanced containment.

While the actual reduction in contaminants during the flushing
operation is unknown, studies on Lower Cohansey Sands from
the Lipari Landfill have shown that 90% of the contaminants
in the leachate can be removed by flushing ten pore volumes
of water through a sample.  The actual degree of success of
removing the contaminants from the landfill will be determined
by the technology available and the actual site conditions.

If warranted, the flushing operation at the site could easily
move into the "Enhanced Containment" mode.  Since the equip-
ment needed for enhanced containment would also be used for
flushing, this shift should be relatively simple.  The change
in operation would lower the operation and maintenance costs  .
of the containment operation.  The extra costs already invested
in the flushing alternative are the capital costs of the
injection wells, injection water facilities and a somewhat
*For the Lipari Landfill, the U.S. Environmental Protection
 Agency is the lead agency.

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                             -26-
J.argfix,^ri>iindwmte^/lfiachate treatment .facility*.  ,Ihe capital
construction .cost differential between the enhanced containment
and flushing alternatives is $1 million.  However, the potential
benefits to be derived from the flushing operation have been
determined to outweigh this cost differential.

To ensure the integrity of the Kirk wood Aquifer, the recommended
alternative includes the installation of monitoring wells down-
    ift   i    -  - - iindi        hOd
   the aquifer Jbe ^fouad jto^aiceed Applicable and xele van t
criteria, the groundwater pumping to capture this contamination
would be warranted.

In summary, flushing was chosen as the recommended alternative
because:

   1 .  Ninety percent of the water-transportable contaminants
       «can .,,Jbe ^removed fx^m the ,lAnd£ill ^so .that the pot ential
       for future seepage of these contaminants is significantly
       reduced or eliminated.

   2.  The operating duration of the flushing pfogram at the
       landfill is estimated to be ten to fifteen years shorter
       than other alternatives.

As noted above, the need for and identification of remedial
action alternatives for the off-site area are presently being
investigated.  The on-site recommended alternative may impact
the off-site area because of the potential for seepage through
the containment system.  This impact will have to be incorporated
     ±4te -off -^^                   Iti mdd i\t ion, «ddit ional
off-site remedial actions.  On-site treatment facilities for
the flushing operation and off-site treatment facilities
should be coordinated.  Implementation of the recommended
on-site alternative. should proceed in phases as described
below:

*  * Install groundwater/leachate extraction and injection
    Pump the groundwater/leachate from within the containment
    system until it reaches approximately 100 feet MSL above
    (i.e., the top of the Lower Cohanaey).  The groundwater/
    leachate may be treated either on-site prior to discharge
    to the local POTW or stream, or off -site at a permitted
                   treatnent* storage
    Install and monitor groundwater wells downgradient of the
    site and screened across the entire thickness of the
    Kirk wood Aquifer.

-------
                                 -27-

      " Flush the encapsulation system to attempt to cleanse  the
        encapsulated material of water-borne contaminants.  This
        flushing operation will be coordinated with potential
        off-site remedial actions.

        Throughout the operation, regular evaluations will  be
        made to determine the effectiveness of the flushing
        program; as well as, the need to continue this program or
        the need to take other actions.

    The State of New Jersey recommends that Alternative 8 should
    be implemented as described above.

    The following listed figure represent a cost estimate for the
    proposed remedial action.  The EPA will be responsible  for
    paying 100% of the project design.  Cost sharing for project
    implementation is 90% Federal and 10% State of the cost to
    implement the remedial action.
    Cost Summary for the Implementation of the Recommended Alternative

    Alternative No. 8b - Flushing
    Remedial Measure
      Component

 .  Install extraction
    and injection wells
2.  Pump, treat and
    dispose of one pore
    volume

3.  Install Kirkwood
    groundwater wells

4.  Monitor Kirkwood
    Aquifer

5.  Monitor wells within
    the containment system

6.  Operate and Main-
    tain Treatment and
    Flushing System
 Capital       0 & M         Total Cost
  Costs    Present-Worth    Present-Worth
 $688,000
  122,500
 2,653,500*
$2,139,600



   340,000t


    88,300


   179,500


   775,800



  1,918,000*
          TOTAL
$3,464,000*    $5,441,200*
$2,827,600




   340,000t


   210,800


   179,500


   775,800



  4,571,500*


 $8,905,200*
    t Cost is for on-site pretreatment with permanent on-site treat-
      ment system and discharge to local POTW.

    * Estimates based on flushing only.  Changes in these costs
      will be dependent upon the off-site/on-site treatment systems
      ultimately designed.

-------
                             -28-
Conaistency With Other .Environmental Laws

The  recommended alternative for the Lipari Landfill site
includes extraction and disposal of groundwater/leachate.
The  groundwater/leachate will be treated on-site prior to
discharge to the local POTW or to Chestnut Branch, or will be
transported off-site and treated at a RCRA-permitted facility.
      aay Aceaario, tMa +±Leza*t±9e jaeeta +11 the
                    '
The Draft National Contingency Plan states that "Federal, State
and local public health or environmental permits are not
required for Federally financed remedial action...  However,
remedial actions that involve storage, treatment or disposal
of hazardous substances, pollutants or contaminants at off-site
facilities shall involve only such off-site facilities that
                            Ate federal .or .State permits or
action taken at the Lipari Landfill.            *

An assessment was made as to whether the groundwater in the
encapsulation system would meet all relevant and applicable
standards after completion of the remedial action.  Thirteen
•indicator" chemicals were chosen to make this assessment.
Since it is impossible to determine how clean the groundwater
would be at a given time, a gross evaluation was made to see
whether 99% removal of contaminants would meet the relevant
and applicable standards.  Table 9 shows the results of this
assessment.
contaminants was achieved, the only criteria that could be
met are the 1-day EPA SNARLS limits and the 1-day NAS SNARLS.
The RCRA Part 264 ground water standards could also be met,
depending on the initial concentration of chromium assumed in
the leachate.  Even at 99.9% removal of the contaminant
concentration (if this could ever be achieved), the entire
array of potential remediation criteria could not be met.
Since it 1* imlitely t^
            '
landfill will probably never meet all applicable or relevant
standards.

As stated earlier* the regulatory agencies will make regular
evaluations of the effectiveness of the remedial action and
determine the need for alternate concentration limits.

-------
                             -29-
Operable Units

The overall Lipari Landfill remedial action has been broken
into three operable units:

  1. Installation of the containment system,  (completed)

  2. Implementation of Phase II - On-site Remedial Action.

  3. Implementation of Phase II - Off-site Remedial Action.

The subject of this ROD is the implementation of the Phase II
on-site Remedial Action.


Extent of Remedy

During development of the RI/FS, an analytical procedure
which included bench scale laboratory testing, was utilized
to simulate the leaching and removal of contaminants from the
landfill for different source control alternatives under
consideration.  In order to compare the cost of different
landfill flushing options on a common basis, a standard
performance level of 90 % removal was chosen.  The analytical
procedure is considered as adequate for the comparison of
alternatives and is a reasonable application of existing data
and knowledge of the site.  However, this procedure is based
on several assumptions; and the actual rate at which contaminants
are flushed from the landfill can not be verified until the
actual operation begins.

In general, the first flush cycle should remove the greatest •
mass of contaminants from the landfill.  Subsequent flush cycles
will yield smaller quantities until eventually the yield from
successive flushes will approach a constant value which will
be greater than zero for the forseeable future.  The level of
contaminants which are leached from the landfill at any given
time should be directly related to the quality of the leachate
which is released to the groundwater.  Thus, during the
early stages of operation, the ratio of the cost to treat one
pore volume (batch volume) to the improvement in leachate
quality (ie. difference in total mass removed between successive
flushes) will be relatively small.  However, with continued
operation of the flushing and treatment alternative, this ratio
should increase because the cost to treat a pore volume of
leachate will be relatively constant but the improvement in
leachate quality will approach zero.

-------
                              -30-
A .pxActicjvl ..dfrf 3 nit. ion .of.A feasible level^of source -control
                  ->,to              of ;the ratio Afif
leachate  improvement.  The  flushing  system should  be operated
as  long as  it continues to  produce improved leachate quality.
However,  the system  is no longer cost-effective  to operate
when continued flushing produces no  significant  improvement
in  leachate quality  even though small quantities of contaminants
nay continue to be removed  from the  landfill.  Thus a practical
                                             <«ffii>MMd.'«*S
                                                       from
successive flush cycles are inconsistent with  the  continuing
cost for operation.

During operation of the flushing system there  will be sampling
to determine the mass of contaminants  removed  during  each
flooding and pumping cycle.  If an analysis  of performance
data indicates that a practical level  of source control  has
                                           should
                          hich any *bf*- sr^l gagy^  t*> ..the
groundwater should be undertaken.   If  resulting 'ground water
concentrations are projected at that time  to  exceed applicable
standards, then either an ACL or a  groundwater cleanup program
should be developed.  In addition,  operation  of  the source
control system should cease sooner  if  it is determined that
leachate from the landfill will not result in a  violation of
applicable groundwater and surface  water standards.  In any
event, however, within five years there should be  a comprehensive
evaluation of the source control system along with the performance
of the chosen groundwater and surface  water remedial actions.
The analysis will assess the effectiveness of the  different
rl«Tiqp ^f orta ^                         vTconB&Ktency :?i?n
"c'Teirt. *itl*at'*rewpTMbi^a                       ^aTe^-wot- -%ei«
realized in any one of these areas.

Operation and Maintenance

Upon completion of the recommended  remedial action, the
following are the operation and maintenance requirements:

• • v • -  ^* Honltoring ttf groundwater ^l^vation mnd  quality
       * Monitoring of groundwater quality  in the Kirkwood
        Aquifer;

       * Operation and maintenance of  the flushing system,
        including pumping and treatment facilities.

-------
                             -31-
Future Actions

        Schedule                             Date

  - Amend State Superfund Contract        Upon Reauthorization
  - Obligate Funds for                    of CERCLA or funding
    Remedial Design                       by the State of New
  - Initiate Design                       Jersey (October 1985)
  -Complete Design

  - Complete Phase II Off-site RI/FS      January 1986
  - Issue Phase II Off-site ROD           March 1986
  - Initiate Design                       May 1986
  - Complete Design                       January 1987


Community Relations

A public information meeting was held on July 12, 1984 at
Pitman Borough Hall.  Notices of the meeting were sent to all
local officials and interested parties as outlined in the
Lipari Landfill Community Relations Plan.  At this meeting,
EPA officials met with the public to hear citizens concerns
regarding the On-site and Off-site RI/FS.

Another public meeting was held on January 23, 1985 at Pitman
Borough Hall to discuss the work to be undertaken by EPA's
consultant as part of the RI/FS.  Letters were sent to all
local officials and interested parties to notify them of the
meeting.  At this meeting, EPA officials provided an overview
of the actions taken to date under the Superfund program and
discussed in detail the RI/FS activities which were to be
performed as part of the On-site and Off-site projects for
Lipari.  Following this presentation, a question and answer
session was conducted.

On August 5, 1985, EPA transmitted copies of the draft Final
On-site Feasibility Report for the Lipari Landfill to the
Pitman Environmental Commission, starting the public comment
period.  The Pitman Environmental Commission placed this
report on repository for public review.  Letters were sent by
EPA to all public officials and interested parties informing
them of the availability of the report and the initiation of
the public comment period.

A subsequent public meeting was held on August 15, 1985 at
Pitman Borough Hall to discuss the remedial investigations
undertaken for the on-site portion of the project, those
being undertaken for the off-site portion, and the remedial

-------
                             -32-
             developed for ^^

was provided to each of the approximately 65 persons attending.
EPA sent letters to all public officials and interested
parties to notify them of the meeting.  EPA officials and
their consultant presented the preliminary findings of the off-
site remedial investigation, the findings of the on-site
remedial investigation, and the on-site remedial alternatives.
           ;t^
Responses to the written comments have been addressed in the
attached Responsiveness Summary.  In addition, more detailed
information regarding the Community Relations Program is
included in the attached Responsiveness Summary.

Enforcement
                                 reached Mith Jir» iJick Jlipari ,
owner/operator, in the form of a Civil Action Consent Decree.
During preliminary negotiations, the Potentially Responsible
Parties (PRPs) indicated they will discuss settlement proposals
with EPA.  Further negotiations will take place following the
issuance of this ROD.  A Civil Referral was sent to EPA-HQ
and the Department of Justice; and a complaint against the
PRPs has recently been filed.

-------
J


Volat|le Organic*
Iftesults In pptjf
Acroleln
Acrylonltrlle
Beniene
Bromoform
Carbon letrachlorlde
Chlorobentene
ChlorodlbrowMWthane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
DIchlorobroMMnethane
Dlchlorodlfluoromethane
,1-Olchloroethane
,2-Otchloroethane
,1-Olchloroethylene
,2-Olchloropropane
,3-Dlchloropropylene
Cthylbentene
Methyl bromide
Iran* 1.2-Dlchloroethane
Cthylene tflbromlde (COB)
Nad Ian Corp.'1
I9U3
Held Sample



3,000


18

>*

8


54
MOQ
4


1.000



1 Radian Corp.1'1 M.m
1 ()||1 Jit It * *
Lab Sample Sept. 26. 1903


II)
4.500 5,900
<500 110

-------
                                                                                                                 £nvlroh«cnUl(6)

Volatile Orioles (cont'dj
Hetiliyt chloride
Hellffene chloride ;
1 . lil»2-letrachloroethJiie
letNchloroethylene
lolieie
1.2'trant-dlchloroethylche'
l.lilMrlfhtoroethane '
J.lftifrlchloroethane
TrUhioroethylene
1r likiorof luoroMthane
Vinyl chloride
lot*! VOC
t : '.,£
Acldt«tr«ct>
(B^svUs la ppb)
2-Chlirophenol
2.4-btchlorophenol
2.4-Ol«*lhylph*nol
4.|-6inltro-o-cre$ol
2.i-6iiiUrophenol
2-Illrophenol
4-ilirophenol
p-Chloro-a-cresol
. . -•
R«dlan Corp.* ' Radian Corp.
1983 1983
field S««ple l*b S<«|i1e
.
SIO 3.300


J . f>J8S rUr. I98S Mirth I9BS

°
 y -^ \_. _. ± ;
]
                                                                                                                        1
                                                                              LEftCHATE CHARACTERISTICS AT LIPARI LANDFILL
                                                                                                               (contl
ontih^J

-------
i Radian Corp.1'' Radian Corp.*2'
I9U3 1903
1 Meld Saqile Lab Saiyle
; Acid Extracts (cont'd)
Pentachlorophenol
"""Ol 11.000 22.000
2,4.6-Irlchlerophenol
Base/Neutral Extracts
IResiilts In ppb~)
Acenaphthene ' • :
Acenaphthylene
Anthracene
Bent .dine
Bent o( a )anthracene
S Bento(a)pyrene
3.4-Bentoftuoranthene
S Bento(9.h.l)perylene
Benio(k)Muoranthene
bls(2-c* loroethoiy)«ethane
bls(2-cnloroettiyl )ether
bls(2-chlorolsopropyl)ether
bls(2-ethylheiyt)phthalate
4-bromphenyl phenyl ether
Butylbentyl phthalate
2-Ch 1 oronaphtha 1 ene
W3"')
Sept. 26. 19113

<500 NO
22.000
<500 NO

 HcasurcMnts
II Corp.1 ' JHB ''' and An«|xsls
Sept. /Ik 1. 19114 lull. 19115 Harcli 1985

• <40
9.000 565
<40

«40
5.6. <4U
<4U

-------
                                                      i|.    .        i,t                                                liwlrbwifntal'6*
Haul an iorp. •
19113
. :..; Held S.iM|ile
Base/leitral CitracU (cortl'd)
4-Chllrd^henyl phenyl etlrtr
Chrysfni
Dlbenteia,h)inthracent
, l,?-oicMorobeni«ne ISO
1,3-Dlcfilorobenicne
1.4-DfcMlorobeniene
3.3'-ilchlorobentldlne
% '•». -'•-•*> •
2.4-OKiilorototuent
H-Chliritolutnt
Olelhyl phthalate 10
DlMtnyt phthalate
Ol-n-butyl phthalate 6
2,4-Olnltrotoluene
?.6-Dln)trotoluene
D|.n4ciyl phthalate
1.2-dipHenylhydratlne
(ai iiobeniene)
riuorkartthane
Fluorihi
llexachlirobeniene
Itemitirobutadlene
lleiaclilirocyclopcntadlen^
IteiacMilroethane
ldeno(l^?,3-cd)pyrene
Isophbrone 180
Kaaian uorp. filial • (4t
1903 JRO'JM '- Jim1 '
l*l> S«w|»le Sept. ?6. 1903 Icb. I9IM


-------
T!

Base/Heutral  Citracts (confd)
Naphthalene
Nitrobenzene
N-nltrosodlmethylamlne .
N-nltrosodl-n-propylamlne
N-nltrosodlphenyla«ine
Phenanthrene
Pyrene
1,2.4-Irlchlorobeniene
l.2-Bls(2-chloroethoxy)ethane
Bls(chloroethoiy)ethane

Bls(chloroethyl)ether
Bls(chlorowthyl)ether
2,3.7.8-letrachlorodlbento-p-
        dloiln
l.2-Bls(2Chloroethoxy)elher
Pestlcldes/PCBs
Radian Corp.1'1
I9B3
field Sa«|ile
70








30.000 to
70.000
Radian Corp.14'
1903
Lab Sample
200








30.000 to
70.000 .
i
(3)(4)
Sept. 26. 1903
430
<200 NO
NO
NO

-------
Radian Corp.'1*  kalian Corp.'**
    I9U3             1903
field Saaple
                                                                    lib

m
                                                                                                                     II CriVp.1
                                                 Heas|ret«nls
                                                 and Analysis
Sept. 2fr.  1901    Feb. I9U4    S»-|.t./OU.  1904      Harfch 190S
                    Peslljes/PCBs (conl'd)
_l .
*
1
1
4


i
i
\

i

•
:;;
' J
'! 'j
j
\ <
\\
- \
1
i"
i

i
i

BIK ci««ia
* ',-
BIK ,o| 111
Chlorialt
¥ - ' *
4.4'Ojbt
4.4'lit
4.4'OW;
Oleldlti
Endosil Ian-alpha
Endoi^f fan-beta
Endoslillan suUate
Endrlfc ;:
Indrln jildehyde
ItepHchjor
llept|chfor epoilde
KB-J24I
PCB-I2S*
pcB-Int
ft J-I24B
PCB-J2W)
PCB-IOI6
loxa|hene

- •••'



2.2 < IM»T r KMnfc>TT r
                                                                                                                                   (continued)

-------
                                               Volatile llon-l'rlarity                             " CorP
                                               _rollut4nl_laqmiiii«ls_                          Sept. /Oct. I91H
                                                 (Results l
                                               Acetone                                      '         6ZO
                                               2-Butanone                                        100.<500
                                               Carbon dl suicide                                      700
                                               Styrene                                              >.'°»
                                               Vinyl acetate                                         
-------
Corivetjlloitaj Parameters
Dissolved organic carbon
pit
lotal suspended solids
BOd
COO
  su-4| '
Aiwniila-nltroijon
                                  It Corp.'*1
                                Sept./Oct.  1904
Phtispnorous
Phdiipiule
lolil dissolved solids
lot*), volatile suspended solids
Volatile dissolved solids
Coldiittlvlty
  i "'•-
Oil Jhd yrease
loiif oryanlc carbon
Chldldes
         as CaCO,
               March,1905
                   Ull
                     6.3
  4.8
240
                                 and AiiaIy$It
.1
6
                                     1.319
                                     2. 020 ;
                                       bS.I
                                       b/.l

                                        0.3»
                                     I.S36
                                      164
                                      490
                                     1.900
                                      310
                                         i
                                      32 /
                                      100
1eMr«ture:  field neasiirevents perforated by CUM In March 1905 Indicated  leacliiti
              teiqieralurJs hnylng Iron IO*C to I6*C.
                                                                                              TAfiLB 1

                                                   LEACHATE CHARACTERISTICS AT LIPARI LANDFILL
                                                                                           (contirnled)

-------
T]
   i
 •  !
   i

i
                                                                                 NOIES
                                       1.  lab Composite of samples  collected  In the field fro* win it or Ing wells' C-IOa. C-6a and
                                           C-4a.

                                       2.  Composite of sa«ple druM upon receipt at laboratory.

                                       3.  <..IIU - element Is less than the value given and not detected by  the  technique
                                           employed.

                                       4.  Highest value (I.e., "worst case")  values are Indicated.

                                       5.  Due to the high level of  Interference encountered, an unusually hlyli detection limit
                                           exists.  An undeterminable amount of the sample response may be due to
                                           1,2-dichloroetliane.
                                                                           •
                                       6.  Collected from production well PM-I at conclusion of 24-hour pump lest.

                                       NO • Not Detected

                                         • Below method detection limit.  Quantltatloa and/or Identification may be uncertain at
                                           this level.

                                        •• Highest value represents  the maximum concentration found In  shallow driven wells
                                           outside of containment system.

                                       ••• Hay be low due to  extended holding time of sample.
                                                                                                                                    TABLE  1

                                                                                          LEACHATE CHARACTERISTICS AT LIPARI LANDFILL
                                                                                                                                 (continued)

-------
           Volatile Organics:

               * Benzene
               * 1 ,2-Dichloroethane
           Base/Neutral Extracts:

               * Bis (2-chloroethyl) ether

           Acid Extracts:
           Metals:
29,000ppb
75,459ppb
83rOOOppb







Chromium
Nickel
Lead
Mercury
Selenium
Arsenic
Silver
51 .Oppmf
O.TOppmf
0.92ppmf
0 . 1 3ppm
0.21ppm
0.087ppmt
O.OBOppmf
, 5.1ppm
, O.SOppm
, 0.12ppm


r0.074ppm
,0.026ppm
            *  "Highest concentration recently reported '(see "Table T)

            t  Concentration appeared in groundwater well external to
               the encapsulation system and is shown here as the highest
               concentration recently reported.  Corresponding value was
               highest value appearing in wells inside the encapsulation.
•#r
                                                                 TABLE 2

                                  CONCENTRATIONS OP CHEMICALS OF CONCERN

-------
III.
    No Action
    Complete Removal
    Enhanced Containment and IV Cleanup:
    Disposal
A.  Leachate

    1.  Surface Hater (i.e..
        Chestnut Branch)
    2.  Reinjection to contain-
        ment system
    3.  Local POTW
    4.  Privately-owned Treat-
        ment Facility

B. Sludge

    1.  Privately-owned Treat-
        ment, Storage and
        Disposal Facility
    2.  Local POW

C.  Contaminated Soil

    1.  Privately-owned Treat-
        ment, Storage and Dis-
        posal Facility
                                      Leachate Collection
                                      A.   Pump leachate from contain-
                                          ment system at a rate above
                                          the seepage rate until the
                                          system is emptied.

                                      B.   Pump leachate from the
                                          containment system at a
                                          rate equivalent to the
                                          natural seepage rate
                                          so as to maintain a
                                          static leachate level.
                                     C.   Pump leachate from the
                                          containment system at a
                                          rate that exceeds the
                                          natural seepage rate;
                                          reinject  treatment leachate
                                          or "clean*  water to main-
                                          tain a static head con-
                                          dition and  flush out the
                                          contamination.

                                     D.   Pump leachate from the .con-
                                          tainment  system to empty
                                          the system.  Allow the
                                          system to refill and then
                                          empty the system again so
                                          that the  encapsulated
                                          soil is naturally flushed.
Leachate Treatment
A.  Physical/Chemical Technologies

    1.  Activated carbon adsorption
    2.  Air stripping packed column
    3.  Reverse osmosis
    4.  Net air oxidation
    5..  Incineration
    6.  Resin adsorbents
    7.  Piltiration
    8.  Precipitation, flocculation,
        sedimentation
    9.  VerTech
 B. Biological Treatment Technologies

    1.  Activated sludge (PACT Process)
    2.  Rotating biological contractor
    3.  Anaerobic treatment
    4.  Aerobic fluidized bed

 C. In-Situ Treatment

    1.  Bioreclamation
                                                                                      TABLE 3

                                                               CANDIDATE REMEDIAL TECHNOLOGIES

-------

 II.
III.
  A.
                     ,
         Removal - -----  '             ,-% ''-•.-,
Enhanced Containment and IV. CleanOpi
jjjbosal              '

Leachate  ''      ^
                i>"""|
 .  Surface watefti.e.
;   Chestnut Branch)
2.  Re injection to
    containment listen
    Leacnate Collection

A.  Pul^leadiate from the
    Upiet Cohansey until
    election 100* MSL
    is7tlached (i.e., top
    of tie Lower Cohansey).
    Then* either let the
    syitim seek its steady-
    statfe elevation of 107'
    MSL |>r incorporate one
    o£ tiro punping sdiemes:
    (ijJContinuously pump
    tne bpper Cohansey at
    a fa* £ of 1 to 2 gpm
    after it is deuatered
    to Aintain water
    levels inside the
    containment below water
    levels outside the
    coipiinment, or (2) if
    exterior water levels
    rise; due to snow-melt
    or precipitation,
    pdmp the Upper Cohansey
    dowii to 100* MSL after
    it recharges back to the
    levctl where hydraulic
        Lents tend be outward.
                                                                        Leacnate Treatment
A.  Physical/ciiendcal I>echn6ldgies
    1.  Activated carbon adsorption
    2.  Air Stripping packed column
    3.  Filtration
    4.  Precipitation
                                                                                         TABLE 4

                                                       SURVIVING CANDIDATE REMEDIAL TfJCHNOLOGIES

-------
B.  Sludge                      B.
    1.  Privately-owned
        treatment, storage
        and disposal
        facility
C.  Soil                        C.
    1.  Privately-owned
        treatment, storage,
        and disposal
        facility
Pump leachate from contain-
ment system at a rate that
exceeds the natural seepage
rate; reinject treated
leachate or "clean* water
to maintain a static head
condition and flush out
the contamination.

Pump the Kirkwood Sand to
contain/collect contaminated
seepage from the overlying
encapsulation system.
B. Biological Treatment Technologies
   1.  Activated Sludge (PACT process)
C.  In-situ Treatment
    None
                                                                                            TABLE 4
                                                                                        (Continued)

                                                          SURVIVING CANDIDATE REMEDIAL TECHNOLOGIES

-------
Alternative 1

Alternative 2
Alternative 4



Alternative 5


Alt«rn«tiv« €



Alternative 7

Alternative 8a



Alternative 8b
Complete Removal

No action but pump Kirkwood Sands
(Enhanced Containment)
&ewa&er
                                                     System
De water the Encapsulation System
and pump the Kirkwood Sands
(Enhanced Containment)

Flush the Encapsulation System
(Cleanup)

Blttahtiitlxe Encapsulation -..System
and pump the Kirkwooo* Sands
(Cleanup)

No Action

Flush the Encapsulation System
with a batch-type process and pump
the Kirkwood Sands (Cleanup)

Flush the Encapsulation System
with a batch-type process (Cleanup)
                                                       TABLE 5

                               CANDIDATE REMEDIAL ALTERNATIVES

-------
Parameter
GCOA
Limitation*
(ppm)t
Ammonia
Arsenic
BOD**
Cadmium
Chromium
COD
Copper
Cyanide
Iron
Lead
Manganese
Mercury
Nickel
pH
Phenol
Silver
Zinc
Suspended Solids
Total Solids
Oil and Grease
Total Dissolved Solids
100
0.1
300
0.5
2.5
600
1.8
0.23
5.0
0.3
10.0
0.01
1.8
6.5 - 9.0 range
0.05
0.5
1.8
300
1300
100
1000
* Concentration based on 24-hour composite
t Limitation in ppm except where noted
                                                            TABLE 6
                                         GCUA DISCHARGE LIMITATIONS

-------
rPcJllotarit
   FW at 0.0576 MGD
^'I^TOpmr
FW at 0.0792 MGD
             fmq/1
Cadmium
Chromium, Hex.
Copper
ryariTde
Iron
Lead
Mercury
nickel
Silver
Zinc
Benzene
1,2,4, Trichlorobenzene
1,1 Dichlo roe thane
i ? Pirhlor^t*!"^
1,1 Dichloroethylene
Ethylbenzene
Nethylene Chloride
Trichloroethylene
T*tr*chloro«thylene • • '
Trichloroflouromethane
0.00013
0.0032
0.063
-onro

0.0084
0.0000064
i.^;*3 '
0.0013
0.53
59.4
2.80
	
J224
130
358.5
123.2
504
,. ."-^43
123.2
0.00010
0.0024
0.046
-D;t)29
	
0.0061
0.0000046
• , , ' ^^t6
0.00098
0.38
43.2
2.04
	
163
94.5
260.8
89.6
366.7
6.84
89.6
                                                         TABLE  7

        DRAFT EFFLUENT LIMITATIONS FOR CRITICAL TOXIC POLLUTANTS

-------
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TABLE 8
•SUMMARY OP EVALUATION OP ALTERNATIVES

-------
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                                                                                                                                                       TABLE  8

                                                                                                SUMMARY  OP  EVALUATION  0*  ALTERNATIVES
                                                                                                                                                (Continaed)

-------
1 f                                             IM
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                                                                                                                                                                               TABLE  8

                                                                                                                          SUMMARY  OF  EVALUATION  OP  ALTERNATIVES
                                                                                                                                                                        (Continued)

-------
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                       ^  ^
                                                                                                                                                       TABLE 8

                                                                                                        SUMMARY  OP EVALUATION OP ALTERNATIVES
                                                                                                                                                 (Continuecl)

-------
M»II-.•»*»
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                                                                                                         TABLE  9


                                          COMPARISON OF POTENTIAL  REMEDIATION CRITERIA TO CONTAMINANT

                             CONCENTRATIONS WITHIN THE  ENCAPSULATION INITIALLY AND WITH 99% REMOVAL

-------

LI.PARI LANDFILL
                       \ nr
                       N"J  r-
                                                    FIGURE 1



                                       GENERAL LOCATION PLAN

-------
 N
scale
                                                        FIGURE 2



                                               GENERAL AREA PLAN

-------
          FIGURE 3




DETAILED AREA PLAN

-------
  LIPARI
LANDFILL
LANDFILL ACCESS ROAO
                                    FIGURE 4

                          PENCE INSTALLATION

-------
                                            .. ATTACHMENT #1
                       "Record  of  Decision
                  Remedial Alternative Selection
       Li*»rl Landfill Site, Pitaan, Hew J«r««y
Analysis Reviewed*  Z have reviewed the following documents de-
                 *
scribing the analysis of oo%t-effectiveness of remedial alterna-
tive at the LiPari Landfill Site:
       Alternatives LiPari Landfill/  Radian Corporation,  July
       1982
     -. Draft Environmental Information Document for Remedial
       Actions at  the LiPari Landfill,  Pifcraan,  New Jersey,  Radian
            •  . •     .'•       '•         '     ..,.»'
       Corporation,  July  1982
     •  Preliminary Engineering Study, LiPari Landfill,  Pitman,
       Hew Jersey, Betz, Converse, Murdoch, Inc.,  May  1982
     /
     •  Abatement Alternatives - Uncontrolled Chemical Leachate
       Discharge from the LiPari Landfill, Pitman,  New  Jersey,
       R.E. Wright Associates,  Inc. October 1980 revised December
      1980
    - Technical considerations For The Selection Of An Abatement
      System At The LiPari Landfill,  Pitman,  New Jersey,
      R.E.  Wright Associates,  September 1981

-------
Description of Selected Option:
     - Phase Zi
       Emplacement of a 360' cutoff wall with cap over 16 acres
       (enclosed area would include the six acre landfill and
       the 10 acre contaminated  area between the landfill
       and Chestnut Branch).
     - Phase IZi
       Installation of ground water collection wells (located
                     •
       both within the contaminated cone and waste body itself)
       Treatment of the ground water contained within the slurry
       wall.
Declarations t  Consistent with the Comprehensive Environmental
Response* Compensation* and Liability Act of 1980 (CERCLA), and
the National Contingency Plan, I have determined that the con-
tainment and treatment strategy for the LiPari Landfill site is
a cost-effective remedy, and that it effectively mitigates and
minimizes damage to, and provides adequate protection of public
health, welfare and the environment.  I have also determined
that the action being taken is appropriate when balanced against
the need to  use Trust Fund money at other sites.

The collection and treatment of the contained contaminated .ground
water  is desirable in order to improve the reliability of the
containment.   The- associated costs are based upon utilization of
a local publicly owned treatment works (POTW) without significant

-------
                                 -3-
 pretreatment..  The proper •valuation of the treatment  system is
 being conducted.Jay ,* v«on«ttit,ttnt ^.to lihe ;U.S. .; ^Environmental Pro-
 tection Agency (USEPA).  I have determined that it is  necessary
 to proceed with the installation of the slurry wall and cap
                  •
 concurrent with the final treatability evaluation of the leachate
with jthm mxi mfii-ng^t esMts* ill. /proeei»« v -at.. the .70CTM. •  ^1 will «a1ce -a
future decision on  the necessary  groundwater pretreataent proc-
esses after completion of the  technical analysis and evaluation
                      »
which will determine the  compatibility  of  the leachate  with the
existing treatment  processes of the local  POTVT.
                                     Ita~M. Lave lie
                                Assistant Administrator
                     Office of Solid Waste and Emergency Response

-------
             LiPari  Landfill  Remedy Approval
                      Briefing Sheet
 Purpose of  this  briefing is  to obtain AA approval for the
 remedy recommended  by the Region and the State for the
 LiPari Landfill  site.  A "Record of Decision" has been
 prepared to document the approval.

 LiPari Landfill  occupies approximately six acres.  Between
 the period  1958  and 1971, the Landfill received household
 waste as well as Iiq"t4 »r.d  seiri-sclii chemical wastes and
 other industrial wastes and  materials for disposal.  Best
 estimates indicate  approximately 3 million gallons of liquid
 wastes have been,disposed at the site.
                 4
 Groundwatar and  surface water contamination  is the primary
 concern at LiPari Landfill.   Rabbit Run, Chestnut Branch
 and Alcyon Lake  are shown to be contaminated.  Strong vola-
 tile chemical odors are evident at the on-site leachate
 seeps.                                  ,

 Zn March I960, a feasibility study was initiated by  R.E.
 Wright Associates through Clean Water Act, Section 311
.funding.  R.E. Wright Associates completed a second  report
 in September 1981 wherein the previous conclusion was revised,
 and a two phase  approach was recommended.

     Phase Is   Slurry wall containment with  cap

     Phase lit  Further evaluation  to collect and
                treat encapsulated  contents.

 EPA held a Public Meeting in November 1981 wherein the Agency-
 made an announcement of the consultant's recommendations,
 EPA's  Region II concurrence and possible  schedule  for con-
 struction initiation by Spring of  1982.

 In January 1982, the consultant to the  responsible parties
 (Bets, Converse and Murdoch), submitted a new alternative
 clean-up plan to the EPA proposal.   EPA Region II, EPA/ORD*
 and Radian, Inc. subsequently initiated a cost-effective _
 analysis of alternatives, including the responsible party's
 alternative and the preparation of ah Environmental
             Document to comply with CERCLA requirements.


-------
The Radian Corporation completed their cost-effectiveness
evaluation on remedial alternatives studied previously
                            *mi*eTt»wtlv« .-
were initially considered highly/cost-effective and were
evaluated further in the Environmental Information Document
(July 1982 )t
                                                       Million $

                                                         " 2 .0
    with wells/Treat at POTW

    Upgradient Deflection wall with Cap (6 acres)         1.2

    Upgradient Deflection wall with Cap (6 acres)/        1.7
    Collect with wells/Treat at POTW
                                 acres)

    360* Cutoff wall with Cap (16 acres)

    360* Cutoff wall with Cap (6 acres)/ Collect
    with wells/Treat at POTW

    Collect with wells/Treat at POTW

    Deflection wall/Upgradient Drain/Cap (22 acres)

    Deflection wall/Upgradient Drain/Cap (22 acres)/
    Collect with Wells/Treat at POTW

Further evaluation of these alternatives by EPA staff
at both the Region and Headquarters level, with technical
assistance provided by the cone contractor (Camp, Dresser,
fc  McKee) and information contained in the Environmental
Information Document, has led to the further elimination
of alternatives as environmentally unacceptable except for
the following threet

-------
                                                        Million $
    360* Cutoff vail with Cap (16 acres)/
    Collect with wells/treat at POTW                      2.0

    360* Cutoff wall with Cap (16 acres)                  1.5
             • •          *                                     •
    reflection wall/Upgradient Drain/Cap 22 acres/
    Collect with walls/Treat at POTW                      2.5
                                             \
Thin has led to the selection of one alternative as the most
cost-effective, environmentally sound remedial action.  It
ist  The 360* cutoff wall with Cap (16 acres).

The recommended Alternative action, however, includes in
addition to the encapsulation of the 16 acre site, active
groundwater control through collection and treatment at
a local POTW to enhance the reliability of the encapsulation.
Additional evaluation to assure the compatibility of the
leachate with the existing treatment processes of the local
POTW need to be conducted prior to proceeding with the second
phase (collection and treatment).  The total cost for design
and implementation of the cutoff wall and cap in addition to
further evaluation related to the collection and treatment
of leachate has been estimated at $1,769,150.

Another public meeting was held on July 23, 1982.  The
Region described the remedy and addressed concerns raised
by the public.

The "Record of Decision" certifies that!

-   The selected remedy is the cost-effective remedy
    for the site.     .           •

    Off-site disposal of the leachate is under investi-
    gation as a cost-effective approach for that portion
    of the project.

-   Monies are available in the Fund to finance the remedy.^

-------
The following actions are required to jnoveth* proj«ct into
constructions

-   Prepare Record of Decision        Region
-  . Begin Design Phase                HSCD/Region
    V  Preparation of'Bid Package
          and safety plan for wall
          construction
      (for construction)              HSCD
    Approve Action Memo              . AA, OAWER
    Prepare State Superfund Contract  Region/State
    Sigh State Superfund Contract     AA, OSWER/State
    Prepare ZA6 with Corps            HSCD
    Complete and Award Construction
      Contract                        Corps
    Begin Construction                "Corps

-------
          Remedial Implementation Alternative Selection
                  LiPari Landfill Superfund Site
                        Township of Mantua
                  Gloucester County, New Jersey
                          July 30, 1982
History
The LiPari Landfill occupies approximately six acres in the
Township of Mantua, Gloucester County,  New Jersey.   A stream
known as Chestnut Branch flows in a north-westerly  direction
alonq the northern and northeastern border* of the  landfill.
Another stream, Rabbit Run, flows in a northwesterly direction
and borders the western area of the landfill.   Rabbit Run enters
Chestnut Branch at a point on the northern border of the landfill.
Chestnut Branch flows into Alcyon Lake approximately 1000 feet
downstream from the landfill.

For 13 years running from 1958 to 1971, the owner,  Mr. Nicholas
LiPari, began accepting and disposing of waste at the LiPari
Landfill.  The landfill has been inactive since 1971, and a
portion has been and is now used for a fruit orchard.  The top
of the landfill rises approximately 40 feet above the Chestnut
Branch.  The land surface slopes from an elevation  of 134 mean
sea level ("msl") down towards both Rabbit run and Chestnut
Branch where the elevation of this northern border is 120 feet
msl.

Occupied homes are located just across the edge of the northeastern
border of the landfill site on the opposite side of Chestnut Branch.

During the years between 1958 and 1971, the owner,  Mr. LiPari,
accepted and disposed of household waste as well as liquid and
semi-solid chemical wastes, and other industrial wastes and materials.

The hazardous wastes dumped at LiPari Landfill were generated by
Rohm and Hass Company from its Bristol, Pennsylvania plant; Owens-
Illinois, Inc. from its Pitman, New Jersey plant and Owens-Corning
Piberglas, Inc. from its Barrington, New Jersey plant.

The hazardous wastes dumped at the landfill by the generators and
haulers have percolated into the groundwaters under the landfill.
The wastes have leached out the embankments of Rabbit Run and
Chestnut Branch further contaminating the surface waters which
run into these respective streams.  Hazardous wastes leaching
from the landfill have contaminated the Chestnut Branch, Rabbit
Run and Alcyon Lake and continue to contaminate these bodies of
water.

-------
                               -2-
Current Status
The LiPari Landfill has been inactive since 1971.  The main
routes for contaminant migration from the landfill are ground
water and surface water.  Le^achate seeps are visible along the
landfill escrapement adjacent to Chestnut Branch, east of the
landfill area and along Rabbit Run.  Ground water and surface
water ccmtamlnation "hm's been ftucumeuLea.. -The preeencs of BCOE
in fish ?*titiTO*rtRrittk^JM
have complained about the presence of odors they attribute to
the landfill.

The cost-effectiveness evaluation prepared by Radian Corporation
(July 1982) reviewed the previous feasibility studies of
R.E. Wright (1980, 1981) and Betx, Converse and Murdoch (1982).
Radian evaluated 32 possible alternative remedial actions, of
whicfc 9 were determined to be W                             -

                                                  Estimated Cost

                                                           Total
                                                  Capital   Ofc
   /Collect with wells/ Treat
         at POTW

         360* Cutoff wall with Cap (6 acres

     -   360* Cutoff wall with Cap (16 acres)

     «—   -a60*; ^Cutoff wall with Cap (6 acres)/
          Collect with wells/ Treat at POTW

          .Deflection wall/Upgradient Drain/
          Cap (22 acres)

      -   fief l^ctloa w*ll/Upgradient Drain/
      : ^  cap (22 acres)/Collect with Wells/
          Treat at POTW
1.2m



1.4m

985k

1.5m
                                                             273k
210K
                                                             180k
                                                    2.1m     --
2 T3m
                                                             273X

-------
                               -3-
After giving careful consideration to the coat-effectiveness
and Environmental Assessment of each alternative and evaluating
comments we have received, the Region recommends that the con-
tainment, active groundwater control alternative be implemented
at the site (Attachment A).  A letter from the State of New
Jersey concurring with the approach is enclosed as Attachment B.
                 *           .  -
Considerations leading to the need for collection and treatment
of the encapsulated leachate Includes

     1.  Undefined long term integrity of the slurry wall.

     2.  Collection of the leachate contents will lower the
         internal head, minimizing infiltration through the
         underlying clay and the potential for contamination
         of the Kirkwobd Aquifier, a drinking water supply.

     3.  Current cost estimates indicate that the reliability
         of the encapsulation action can be enhanced at a
         reasonable cost, thereby providing additional assurance
         for protection of public health and the environment.

Recommended Alternative

Section 300.68(j) of the National Contingency Plan (NCP)  (FR
31180; July 16, 1982) states that the appropriate extent of
remedy shall be determined by the lead agency's selection of the
remedial alternative which the agency determinates is cost-effec-
tive and which effectively mitigates and minimizes damage to and
provides adequate protection of public health, welfare or the
environment.  Based on our evaluation of the cost-effectiveness
of each of the proposed alternatives, the comments received from
the public, our technical consultants, and information/comments
from the State, we have determined that the two phases Phase X,
360* cutoff wall with Cap  (16 acres) encapsulation, in conjunction
with Phase XI, collection wells and treatment at the local POTW
strategy identified in the cost-effectiveness report meets the
NCP criteria.

The encapsulation, collection and treatment option entails the
specific activities identified in Attachment C.  The cost break-
down for this remedial alternative is listed below.

-------
                               -4-
            Activity
     Phase It

     Preparation 'of Detailed
       Design               f

     Cutoff wall and cap
Estimated Costs
     Treatment Feasiblity
       Study
                              TOTAL
  $  100,000


  $1,589,150


  $   80,000
  $1,769,150
     Phase II:

     Collection and treatment
     POTW disposal and operation
       and maintenance
  $   91,250 per year
Proposed Action

We request your approval of the Encapulation, Collection and

Treatment option as the remedial action alternative for LiPari

Landfill.  In addition, we request the allocation of $1,769,150

ifOT^*''-;'Vhmmwt'-T^

includes associated engineering costs.
Tentative Schedule
     Tiaal opportunity for private
      party clean-up

     State/EPA sign Superfund
       State Contract

     Complete design of slurry wall
       and .cap
       1982
      late August


       October

-------
                               -5-
     Receive bids,  award contract,
       and begin construction (Phase I)         November

     Complete  treatability study
       (Phase  II)          -                    December


If you have any questions, please contact Robert  Ogg at (212)  264-
264?

-------
          Remedial Implementation Alternative Selection
                  LIPari Landfill Superfund Site
           •'    •  '' .  • '   Township of Mantua
                  Gloucester County, 'New Jersey
EPA has completed the following remedial Superfund activities at
the  LiPari Landfill site located in Gloucester County, Hew
    Activities                            Date Completed

                      t
                      *

Remedial Investigation/                    October 1980,
  Feasibility Study                        December 1980 revised
              Study  '•          ••   «     '•.-''• September 1981
Public Meeting                             November 1981

Cost-Effectiveness Analysis
  of Alternatives                          July 1982

Fence Isolation of the Site                July 1982

Draft Environmental Information
  Document                                 July 1982

                                                ,23,, O982
Region II has reviewed the information presented in each of these
reports and given careful consideration to the comments received
from the State of New Jersey, our technical consultants and the
public.  Based on our review, Region II has determined that the
following actions at the site art cost-effective, environmentally
sound, and effectively mitigate and minimize damage to and provide
adequate protection of public lfce*ltl», *«lf AX* or tlxe environment .

-------
    Action                               Estimated Cost

Phase I

  Containment Design                       $  100.000
                  *
 •Waste Containment                        $1,589,150
    Construction            *

  Collection and Treatment
    Feasibility Study                      $   80,000
                                           $1,769,150
     Date                            Jacqueline E. Schafer
                                     Regional Administrator

-------
         STATE
.DEPARTMENT OK K.
                                               * NEY/ JERSEY
                                               IRONMCNTAU
                                                    .MANAGEMENT
                                       orricx or THE DIRECTOR
                                               CM •*•
                                       TNCNTON. NtW ;«••*> 04«11
                                             (•••I a»s-4oa»
                                       , O982
Mr. Robert Ogg
USEPA - Region II
26 Federal Plaza
Dear Robert:
                       «
A3 you requested during your July 15* 1982, meeting with Anthony
Farro of this Division, we have reviewed your general concept for
'.he final remedial action plan for the Lipari Landfill.  According
   your "acepgesentation to Mr. Farro, EPA's conceptual plan  includes:
          1)  The construction of a. 360 degree cutoff
              wall wich clay cap over 16 acres (the
              enclosed area would include the six acre
              landfill and the 10 acre contaminated  area
              between the Landfill and Chestnut Branch) .

          2)  The installation of groundwater collection
              wells  (located both within the contaminated
              zone and the waste body itself) .

          3)  ..The ^transport of contaminated groundwater,
       ' • '-    ^collected ^i»daT 12 above aft«r ;pri»ary
              treatment on site if necessary, to a public
              owned  treatment works  (POTW) for final
              treatment and discharge.

After  requesting the review of this plan by the appropriate, interested
Divisions within the Department, I can report to you that the Department
is in  general agreement with the conceptual plan stated above; provided,
of cotg«*» tihm'^KJT^                                 
-------
Mr. Robert Ogg                                                 Page 2
RE:  Lipari Landfill     -                                       7/16/82


As you know, we expect  to execute a Superfund Agreement to implement
this remedial action  by mid-August.  Recent discussions between DEP
and EPA have convinced  me that this is also your agency's intention.
I am confident that,  with continued cooperation, we can refine this
conceptual plan into  a  detailed remedial action expeditiously and
accomplish our goal.*

                               Sincerely,

                                           tuL_J^
                                                 '//
ejs
cc:  G. Tyler, Asst. Commissioner
     J. Vernam
     I. Farro
     D. Mack
     G. King

-------
                                                           NT C
 360* CUTOPP WALL WITH CLAY CAP CSIXTEEN (16) ACRES];
 COLLECT WITH WELLS;  TREAT AT POTW


                              Phase I

                 Def lection/Encapsulation System
 • »                '

 A 360* cutoff wall with clay cap over the landfill area (6-acres)
                                              the lAodf ill ..and
                                         •*     L**'- :•«• • -jr oposed in
the Wright report (November 1980)  involves s

      '    installation of an impermeable slurry wall
          around the entire affected 16-acre area, and
                     4

      *    installation of an impermeable cap over the
          16-acre area.
_^__^	.___	 '^:«3«0* «*lurry wall • AS -..shown
in Figure 1 will completely isolate the  entire  area (16-acres)
from the groundwater flow system.   The cutoff wall would be in-
stalled vertically from the ground  surface  downward to a location
2 to 3 feet into the Kirkwood clay.  Zt  was estimated that an
average slurry wall depth of 30  feet would  be required throughou
most of the affected area, with  as  much  as  50 feet in depth
along western perimeter of the disposal  area.  The slurry tren
would be installed to achieve a  maximum  permeability of 1.0 X
10*"' to 1.0 X 10*"8 centimeters per  second.
                                                               ou^^
.Beatonite Clay Cap Over the Landfill.  A bentonite clay cap over
•••the entire ITM .jl^-iirr^*.j ^Tir *•'* •"•*'«»9«-»
                 .
 into the area.   The installation b'f ~a twp-'woaliS ^^
 the 16-acre area,  disking bentonite SG-40 at 1.5 lb/ft2, compaction,
 12 inches cover and seeding.

                              Phase ZZ

                         Collection Systea


 The well design for this option is based OTI the 'follrswii^ «»»an»ption

      •   The cutoff wall and clay cap completely isolate the
          system from ground water and surface recharge; and

      •   The cutoff wall is able to withstand a significant
          gradient betvfeiFn ...t-fr+ jrfttin
-------
•'

-------
                               -2-
The wall fisad needed to remove the contaminated ground --water
from within the 16 acre enclosed ar«a i» located throughout
the waste and plume areas.

Tan walls* spaced as shown in Figura 1 could theoretically
remove all of the. enclosed ground watar within 1 yaar.  This
assumes a pumping rata of 10 gpm/wall continuously.  Since thara
is no recharge, however, the .wells will dawatar before the antira
volume can b» pumped wt.  fit will tea necessary, at some 'point,
to reduce the pumping rata and maintain maximum yield.  The
ability to remove all contaminated fluid and tha associated
pumping time naadad ara exponential functions.  Zt will be cost-
effective to remove only a portion of tha total fluid volume,
perhaps 80%.  Based on this, tha following pumping rates ara
suggested:

     First Year:     All walls £ 10 gpm/well until drawdown
              •'• . •• •':  is near maximum.  (Estimate 6-8 months)

                     Reduce all wells as needed to maintain
                     maximum yield.  (2-3 gpra or lass)

     Second Years    Continue pumping at reduced rates until
                     a satisfactory amount of fluid has been
                     removed.

At 10 gpm/well for 6 months and 3 gpm/wall for an additional
year* approximately 86% of the contaminated fluid would be
recovered.
The collected leachate is currently planned to be routed to the
Gloucester County Utilities Authority (GCUA) wastewater treatment
plant.  This is a 16.5 MSO modified contract stabilization plant.
Average flows currently run at approximately 14-14.5 MGD with
peak  flows of 18-19 MGD (GCUA, May 18, 1981).  Tha predicted
leachate pumping rates ara relatively low  (28,000 - 144,000
gal/day) .  'tt» ^y^r^^Lc iiMf>AG^t.y of th» f^A^t. And ...the collection
system ara a^togoat* tor treatment/ of the lea^^
trunk line is designed for 24.1 MGD.  Zn addition, GCUA is
planning to expand plant capacity in the near future (GCUA, May
17, 1981).  Operational parameters and performance data for the
GCUA  ara summarized in Table  3-6.  A sewer line tie-in across
Chestnut Branch would ba necessary.

-------
                               -3-
Approximately 10-12% of the wastewater flow at GCUA. is frora
industrial contribution with 8% contributed by Shell Ch««»5*l
Company (GCUA, May 18, 1981).  Preliminary contact, with the
plant general manager and operation, manager **£«»*• **£**• a
plant can handle this wa.te stream; however, «»* *£" "Ji^Jn
certified laboratory report characterizing the leachate and will
perform their own laboratory teste to determine the potential
effects of the wastes on the plant.

The predicted performance of the GCUA plant in treating LiPari
leachate is presented in Table 3-7.  Influent c°nc«»trajioj« ar0
based on combining the GCOX average flow of 1*-5."JD.^2.^_.
predicted high  leachate pumping rate.  Removal efficiencies^were
estimated from  plant  data for the  conventional pollutants and a
review  of the literature for organic species. X  full  scale  •
treatability  study  is currently underway to assure  the  compatibility
of the  leachate to  the  treatment system.

-------
L1PAM
Parameter
BOD
COD
Phenol -',
--•' . t
Bia-2-(chloro~ethyl)
ether ;
. "• -
ta> T-'i
e-2- (chldro-ethoxy )
acthane
Benzene '
Toluene
'j.-i' '
Ethyl Dencene
Methylene Chloride
1.2-Dichloroethane
r-j - -,'•< £••
- Baaed ol iaaa balance I
I.EACIIATK
i
I


lUfl H
Influent —
in<>ll>
iiiiifen iniuiiiii
Effluent uLj?
(•g/L) , (•g/L)
203 •
381 •
0.02


0.13




0.23


0.02
0.22

0.
0.
: o.
ri 'X
1l4.

01
07
08

- 228
- 411
- 0.

- 0.

-
- 1.

- 0.
- 0.

-0.
- 0.
- 0.

s nn»
13

87


50

04
42

06
36
33

(«C
10.2
38.1
0.001


0.027


0.

0.
0.

0.
0.
0.
., -"-;' ?
CHUA^


230

00-
043

003
007
025

+ 0,
r.ni i ijfini

(lb/dny)
i VU
- 11.4
- 41.1
- 0

- 0


- 1

- 0
- 0

- 6
- 0
- 0

,144
.006

.174


.50

,011
.083

.011
.036
.099

MOD
0.12 -
: •, -
3.i>-

* ' - •_
27.8 -

0.73 \
5.1 ^
•.- •
0.36 -
0.85 ^
3.ol &
9 ' •
(x leachate)
0.73

21.05


181

1.33,
10.04

1.33
4.36
11.98


i no nrriticu |U
S -\ i. •••'}
«'.. . ..„;.
•' "' * " "• I/
Rein|iril Beference —
9* 4i
9d 4
95 1, 2, 3
• '
80 * 2, 1
/ •
i
• ^
0 2, i

70 » 2, 3
80 ' 3
* •
80 2, 3
90 2
70 •} • 2
:'- A L 3
,
                                            14.644 HGD
 •  Concentration of organic apeciea In OCUA Influent waa aaauved to be 0 Hg/L.

-1 Keferendelt   1) Stiwoudla, 1979
                 2) Patterl^i, 1981
                 3) Tabflk. 1981
                 4) CCMUA. Hay 18, 1981

-------
           DISPOSAL
   tSAcr*
Cutoff WaH
                      ."opcwdRimpingWtif Location-

                       Arwo* Qlffos* Uicftit* SM

                       9


-------
       .  I      .- •

LIPARl l.feACIIATE
       '
                • ••MMfWO
ul iiihi;CMUAHASTEHATER TREATMENT PUHT AS APPLIED
.Parameter ;/,-. * ;
BOD
COO
Phenol •
BlB-2-(chldro-tthyl)
ether ^
< a-2-(clilorb^«thoKy)
•ethane
Jlencene '
Toluene : ;
Ethyl Beaterie
lethylene Chloride
1,2-Dichloroe thine
i ^ ' ¥^'^
!-• Baaed on laia balances
i * • '• ' ;':
i • Concentration of organic
"• W ^
' :. •
^ Influent -f
, <«g/D
203 - 228
381 - 411
0.02 - 0.13
0.13 -0.87
9
0.23 - 1.50
0.02 - 0.04
0.22 - 0.42
, 6.01 - 0.06
6.07 - 0.36
6.08 - 0.33
£^
'• . '-,
(14.5 HCD) (xCCN
•peclea In CCUA
A Effluent ^ I V' , • - . ,$.
C_^ It %
•g/l»)
.-»-]»
10.2 - 11.4
38.1 - 41.1
6.001 - 0.006
1.027-0.174
il.230 - 1.50
0.00- - 0.011
01043 - 0.083
0.003 - 0.011
01007 t 0.036
0.025 - 0.099
•>TL-~j
uJ)| 0.144 MOD (x
14.644 HCD
influent vaa aaaui
(Ib/tlny) RcMvil Reference^'
'*- 95 4 .
ii 90 4
0.12 « 0.73 95 1, 2, 3 '
3.27 - 21.05 80 * 2. 3
V- . 1
27.8 ^181 0 2, 3
0.73 ^1.33, 70 * 2, 3
5.2 & to.04 80 3
• ' }'• * •
0.36 * 1.33 80 2, 3
0.85 - 4.36 90 2
3.02 - 11.98 70 j 2
0
£ "--- i, . k '^ . . . - -j
leachate)
ted to be 0 *g/L.
-1 Ueferenceai 1) St«Miidliv 1979
2) Pattertort, 1981
3) Tabak. 1981
4) CCHUA, M IB, 1981
;$
^
•.!^
''•'••»





-------
   15 ACT*
Cutoff Walt .
                                         Well Location-
                         Arwof Qlffus* Uacnttt S«tpag%
                OoHaet-wittx Itellj/ Trmt «t'

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                          LIPARI LANDFILL SITE
                  BOROUGH OF PITMAN, GLOUCESTER COUNTY
                               NEW JERSEY
                      FINAL RESPONSIVENESS SUMMARY
                                FOR THE
          ON-SITE REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
This community relations responsiveness summary is divided into the
following sections:

Section I      Background on Community Involvement and Concerns.

               This section provides a brief history of community
               interest in the Lipari Landfill  site and a chronology of
            i  ^common:l|y ;re"l«t 1 ons'< attl V^*s cwaut^ed iby i^hefEfivlrofBnental
               Protection Agency (EPA^ during the on-sTte remedial
               investigation and feasibility study (RI/FS).

Section II     Summary of Major Questions and Comments Received During
               the Public Comment Period and the EPA Responses to the
               Comments.  This section summarizes major questions and
               comments made verbally to EPA during the Public Meeting
               and the Public Comment Period by relevant topics.  EPA
               responses to these comments are  also provided.

Section III    Remaining Concerns. This section discusses remaining
                                  that £PAshoul«d J>e,aware .of in .conduct 1 n g
                            =dfisign and reatedial action at the Lipari
               Landfill site and in conducting  the RI/FS of the off-
               site contamination problems at the Lipari Landfill site.

Section IV     Written Comments Submitted During the Public Comment
               Period and EPA Responses.  This  section addresses the
               comments submitted to EPA by letter during the Public
               Comment Period.

-------
                                    -2-
 t.  BACKGROUND ON COMMUNITY RELATIONS ACTIVITIES AND CONCERNS

      Pitman Borough residents have been aware of the UPari Landfill since
 the  owner began accepting liquid and solid wastes 1n the late 1950s.
 Residents complained to local officials about odors coming from the
 landfill.  In addition, residents were aware that fires occurred on the
 property during the period of landfill operations.

      In July 1982, EPA constructed a fence around the property and
 Installed a slurry wall containment system In September 1983 to prevent
 access to the site. Residents, however, remained concerned that children
 would still be able to gain access to the contaminated Chestnut Branch
 marsh area from the east side of Chestnut Branch.  In August 1983, EPA
 constructed a second fence near Chestnut Branch.  EPA recently completed a
 third additional fence connecting the fence surrounding the site to the
 fence east of Chestnut Branch. In September 1983, EPA Initiated the
 Installation of a slurry wall containment system around the L1Par1
 Landfill.

      During this period, residents expressed concern about the following
 Issues: (1) the Integrity of the slurry wall containment system; (2) the .
 effectiveness of the leachate treatment system; (3) maintenance and
 security of the site; (4) the potential for ground water and drinking
 water contamination; and (5) the availability of site records.  In
 addition, residents Indicated their concern about possible off-site health
 and environmental  effects from the landfill.

      In January 1985, EPA released Its draft work plan for the on-s1te and
 off-site RI/FS activities at the site.  At that time, residents and local
 officials expressed concern about the following Issues:  (1) the structural
 Integrity of the containment system; (2) the permeability of the Klrkwood
 layer; (3) the sampling and testing methodology used by EPA at the site;
and (4) scheduling of the off-site RI/FS and availability of data results.

      In August 1985, EPA released the draft Phase II on-slte FS report to
the public.  EPA held a Public Comment Period on the draft FS report from
August 5 to September 9, 1985.  EPA held a  Public Meeting 1n the Borough
of Pitman on August 15, 1985 to receive verbal  comments on the study.

     The following Is a brief chronology of community relations activities
at the L1Par1  Landfill  site.
     November 30, 1981                 EPA holds a briefing for local
                                       officials to give a status  report on
                                       the activities  at the L1Par1
                                       Landfill  site.

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                               -3-
July 23. 1982
September 1983


September 1983
             taw
    January 23,  1985
            , 4985
    August 15, 1985
 Congressman Florlo holds a public
 meeting  In Mantua, NJ to discuss the
xJ.ll>^r;iXandfJ4] .contamination
 problems with -filoucester County
 residents.  EPA participates In the
 session.

 EPA prepares a community relations
 plan for the L1Par1 Landfill site.

                                  LandUIll  site.  These  Information
                                  repositories are located at the
                                  Pitman Borough Municipal Building,
                                  the Pitman Environmental Commission,
                                  and EPA Region II office 1n New
                                  York City.
 meeting In "the'BorbughWfltman
 discuss citizen concerns regarding
 an on-slte and an off-site RI/FS.

 EPA holds a public Information
 meeting 1n the Borough of Pitman
 to provide the community with
 current Information regarding the
 draft work plan for the on-s1te and
 off-site RI/FS.
£PA begins a
                       
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                                     -4-
 II.   SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC
      COMMENT PERIOD AND EPA RESPONSE

      Major comments and questions raised during the LIPari Landfill site
 Public Comment Period are summarized briefly below.  Examples of comments
 and questions raised and EPA responses are also provided.  EPA held the
 Public Comment Period from August 5 to September 9, 1985 to receive
 comments from the public on the draft feasibility study.  The comments
 received during the Public Comment Period are organized by the following
 relevant topics:
     1.  Candidate remedial alternatives
     2.  Other remedial alternatives
     3.  Contamination of the Kirkwood aquifer
     4.  Nature and extent of contamination
     5.  Off-site contamination concerns
     6.  Cost/funding Issues
     7.  Health studies
     8.  Public Comment Period and schedule

1.  CANDIDATE REMEDIAL ALTERNATIVES

         Complete Removal  - Alternative 1

         Several  residents who commented on the draft feasibility  study
         preferred Alternative 1 which Involves the complete removal  of  the
         contamination from the landfill.  These residents  believed that
         this option would remove the hazardous waste material  and
         eliminate any additional environmental damage to off-site areas.
         In addition, some residents questioned the validity of the  •
         cost-benefit criterion for remedial  alternative  selection.  These
         residents Indicated that the cost-benefit of a remedial action
         should not Influence the selection of alternatives.

         EPA Indicated that Alterntlve 1 1s not a  favored option because a
         potential health.risk exists to workers and nearbv  residents from
         the excavation of the hazardous waste at  the landfill.  In
         addition, the selection process stipulated In the National..
         Contingency Plan  1s the one that EPA uses In the decision  process
         for remedial  actions at the LIPari Landfill  site.   This criteria
         Includes  the cost-benefit determination that first  considers the
         technical feasibility and environmental effectiveness of the site
         remedy and then compares the costs and benefits  among those
         alternatives that meet this effectiveness criteria.  In the  case
         of the LIPari  Landfill  site, the cost for Alternative 1 are
         significantly higher than other effective options.

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                                 * is unlikely • .that , a Resource
                   ^^               permitted  landfill  located
 outside of New Jersey  will  accept the amount of material  that
 would be removed  from  the LIParl  Landfill  site.
                A resident
                Issues concerning the  total  removal  of the
 contamination  in the landfill as well as  financial  considerations.

 Response:  EPA considered safety and  transportation issues
 related to the total removal of the hazardous waste at the  LiPari
 Landfill.  EPA assessed the financial costs and health risks
 associ ated with excavating *nd transporting the hazardous waste
              ";;$RM;^yBS^^vs€M^S^det^^
 financial costs and health risks are too great to select total
 removal of the contamination in the landfill as the remedial
 action at the site.  In addition, EPA believes that the disposal
 alternatives for the hazardous waste material to be limited.

 b)  Question;  A resident asked if EPA will reject the complete
 removal alternative because a disposal site does not exist that
 Response:  EPA has not rejected the complete removal alternative
 because a  disposal site has not been currently identified.  At
 this time, EPA does not consider the complete removal alternative
 appropriate because of the high cost and a potential health threat
 to workers and the public from the excavation of the landfill.
 EPA believes, however, that an acceptable disposal site would be
 difficult  to identify.

 c)  Question;  A  resident questioned why EPA included waste
 disposal companies in the draft feasibility study report which may
 be in violation of .,fedeial,«ajMl?s£a^
"Response:  EPA  is not  recommending waste disposal firms In the
draft on- site FS.  EPA considered specific waste disposal firms in
the assessment  of the  remedial  technologies to estimate costs
only.  EPA has  adopted an  off-site disposal policy which ensures
that any decision on disposal complies with all  existing laws.
When an alternative is selected for remedial  action at the LiPari
Landfill site,  EPA will request proposals from qualified waste
disposal
                                                                   .*-..v»y r.f" v.y, v'-*"-;*"1^
                                                                  •• ''-•^'i*v^v-ifl"7v<*L.:!.."
                                                                .... - ^^jfci."£tf$^*i>->

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                            -6-

 Enhanced Containment - Alternatives 2.  3,  and  4.

 A few residents seemed somewhat skeptical  as to whether or not the
 alternatives  which Involve enhanced containment (Alternatives 2.
 3, and 4) are as effective as  the  complete removal option
 (Alternative  1) or the flushing options (Alternatives 5 and 6).
 These residents were generally concerned about the further
 contamination of the Klrkwood  aquifer and  the  Integrity of the
 slurry wall.   Several  residents and members from the Pitman
 Environmental  Commission  were  supportive of enhanced containment
 for the LIParl  Landfill because of the  reliability and past
 experience with this type of system. In particular, one resident
 was supportive of Alterative 4 because  he  believed that the option
 addresses most adequately environmental  concerns regarding the
 Klrkwood and  Cohansey aquifers.

 EPA responded  that the enhanced containment options provided an
 opportunity to address both environmental  and  health concerns
 related to contamination  of the Cohansey and Klrkwood aquifers.
 In addition,   EPA Indicated that sufficient experience with the
 technologies  Involved  1n  the enhanced containment alternatives
 provided both  reliability and  predictable  results from the system.
 EPA,  however,  stressed that the enhanced containment options do
 not  remove or  clean up the landfill  as  described In Alternative 1,
 the  complete  removal  option, or Alternatives 5 and 6, the flushing
 options.

 a) Question;  A resident  asked If  enhanced containment had been
 used  before at  a  landfill  like the LIParl Landfill.
           •     *    ,
 Response:  According to Information  available to EPA, enhanced
 containment has  not been  used  before at  a chemical hazardous waste
 landfill  like L1Par1.  The technologies, however, that make up the
 enhanced  containment system alternative  have been proven at LIParl
 during the remedial  Investigation  phase  of the project.  These
 technologies Include:  (1)  pumping the leachate from within the
 encapsulation system;  (11)  pumping the Klrkwood aquifer; and (111)
 lowering the water  level  In the landfill; and (1v) treating the
 leachate.

 b)  Question;  A  resident  asked If the permeability of the slurry
wall was Impacted due to the hazardous waste 1n the LIParl
Landfill.

Response;  EPA responded that the permeability  of  the encapsulated
system and Its seepage are normal and expected  occurences.
The permeability of the wall, however, could be Impacted by the
hazardous wastes at the LIParl  Landfill  site.   Because the  use of
slurry walls In situations like the LIParl  Landfill  site Is new,
there Is no history of what Impacts hazardous waste may  have on
the slurry wall at the site.


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                             -7-

  c)  Question;   A resident, asked EPA to define hydro-fracturing?
  The resident Inquired If hydro-fracturing will  cause the  enhanced
  containment system to fall.

 "**spore*| ':i%dTO^tct-^^                         ittoe
  permeability of the slurry  wall  to Increase  two to three  times
  above Its design permeability.  The potential for hydro-fracturing
  to occur  at the LIPaH  site Is Increased  when a difference of
  fifteen feet exists between the  top of the slurry wall and the
  water table on  either side  of  the  containment wall.  This
  difference could be reached If the containment  system Is
-'tteiiitei^v^fl^
  permeability Sf the si urry  wall .  Tt Hoes :t>ifft *wcur ^tttroogttotrt the
  system, but 1s  a localized  phenomenon.  Hydro-fracturing 1s not a
  break or  crack  In the slurry wall.

  At  L1Par1,  where the differential  of the  water  level across the
  wall  would approach or  exceed  fifteen  feet at the southwest
  corner If the encapsulation  1s dewatered, there 1s the potential
-:.ftor,.4iy,dr.o-fTjctur1j3i,g»  EPA  believes, however, that the risk of
  hydro- fracturing  will not greatly  Impact  the effectiveness of this
  alternative.  In  addition,  long-term monitoring WTT1 ensure that
  EPA Is aware of  any significant effects to the  enhanced
  containment  system.

  d)  Question;  A  resident asked why EPA does not Install a well
  that  is screened  from top to bottom  1n order to catch floating oi
  sinking contaminated material within the  encapsulation system.

 Response:   EPA 1s  still considering the design  of the extraction
 wells  for this candidate alternative.  EPA believes, however, with
 properly designed wells and effective utilization, wells screened
vifcw^r^iws ''pib^rtts '^
 Tl bating arid isYTfi^                       .
 Flushing - Alternatives 5 and 6

 Several residents supported Alternatives 5 and 6, the flushing
 options.  Although an unproven technology, these residents
 believed that flushing may be the most effective solution to
 L1Par1 Landfill.  Several Titraan resil dents, "however,
 the technical  feasibility of flushing.  These residents expressed
 concern, frustration, and anger about  the experimental  character
 of flushing as an unproven technology.  These residents believed
 that the risk  of further contaminating the Klrkwood aquifer and
 Alcyon Lake was too great for EPA to select either Alternative 5

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 EPA responded that the flushing option  provides an opportunity to
 clean the water soluble contaminants  from the  system.  Because
 L1Par1  Landfill Is a small,  contained system,  with a slurry wall
 and cap,  EPA believes that adequate controls exist to attempt the
 flushing  option.  EPA stressed  that 1t  Is necessary to try
 flushing  or It will  always remain an  unproven  technology.  In
 addition,  EPA Indicated that If flushing Is selected and proves
 Ineffective, EPA could then  shift to  enhanced  containment.  EPA
 Intends to continue  long-term monitoring  under the flushing option
 to observe any changes 1n the ground  water and off-site
 conditions.   Placement of recovery wells  will  preclude
 contamination seeping Into the  Klrkwood sand formation from
migrating off-site or discharging Into Alcyon  lake.

 a)  Question;   A resident asked EPA to explain flushing.

 Response;  Flushing 1s the injection of clean water uniformally
 into the  containment system  such that the chemical contamination
 that 1s within the slurry wall  and is water soluble would come in
 contact with clean water. This flushing  water Is pumped out of
 the system and treated to remove the  contaminants before being
 returned  to  the flushing cycle. Flushing will remove water
 soluble contamination that would otherwise remain physically bound
 to the  soil  In the containment  system Indefinitely, or seep
 through the  slurry wall  or Klrkwood clay  bottom and Into the
 off-site  environment.

 b)   Question;   A  resident questioned  EPA  about what 1s done with
 the contaminated  water that  1s  pumped from the encapsulated
 containment  system.

 Response;  EPA Intends  to treat  the contaminated water that is
 pumped 'from  the  system by;  (1)  treating the water on-site and
 discharging  Into  the  Gloucester  County Utilities Authority
Uastewater Treatment  Plant;  (2)  treating  the water on-site and
 reinjectlng  into  the  landfill: or (3) transporting the
contaminated water to an  off-site treatment facility for disposal.

c)   Question;  A  resident  asked EPA about what Is done with the
 Insoluble contaminated waste (sludge) that 1s left in the
encapsulated containment system.

Response:  After the  flushing of the system,  the sludge will  be
left In the landfill with  a long-term monitoring system to measure
any  significant changes In water soluble contamination levels.
Since this sludge 1s water Insoluble, it 1s not expected to leech
out  and escape the containment system.

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                            -9-

 d) Question:  A resident asked EPA what percentage of
 contamination will  be flushed from the system.

 Response:  EPA does not know the total  volume of  contamination  in
 .the Jandflll,.  It 4;$ 4«poss ibl* ,to ..fistiajate ,£hfi , percant^ge that
 will be left after  flushing.  The purpose of  flushing, however, is
 to remove as ouch of the water soluble contamination  as  possible
 from the system In  order to  prevent  the contaminated  material from
 being transported by ground  water through the slurry  wall or the
 Klrkwood sands.

 e)  Question:  A resident asked EPA  if  It Is  possible for the
                        t «
 Response: EPA responded that It 1s not likely that an explosion or
 reaction w*1ll occur with the Introduction of water during flushing
 of  the  landfill.  The water will be Injected slowly Into the
 landfill.   It will take six months to fill the landfill one time.
 The water soluble and water Insoluble contaminants have already
 been exposed to water for many years.

 f)  "Question;   A resident asked how many "gaTlons of water are
 necessary to fill the containment system.

 Response:  EPA responded that It will take approximately ten to
 twelve million gallons of water to fill the containment system.

 g)  Question;  A resident asked from where the water will be
 obtained for flushing the LIParl Landfill.

 Response;  Three locations have been Identified as possible
 sources of water Including:  (1)  Pitman Municipal Water Supply;
     ~iipgradi*«t>«0fli^^
h)  Question;  A resident Inquired 1f there 1s an advantage 1n
using treated water from Alcyon Lake and then reinjecting it into
the LiPari Landfill for flushing.

Response: EPA has not yet determined the source of water that
would be used for flushing the landfill.  Certainly, Alcyon Lake
     '

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                                    -10-

         1)  Question; A resident commented that If undamaged drums exist
         In the LIPaM Landfill, flushing would not remove the
         contamination 1n those drums.  The resident asked how EPA Intends
         to address this problem.

         Response;  EPA responded that It Is true that only ruptured and
         rusted drums would have released their contents Into the landfill,
         presenting the opportunity for removing the contamination through
         flushing. EPA does not believe that any of the drums that were
         placed In the landfill are left Intact.  However, EPA would
         continue to monitor the landfill In order to determine If any new
         or Increased concentrations of contamination are found.
2.  OTHER REMEDIAL ALTERNATIVES

         Residents and the Pitman Environmental  Commission  expressed
         Interest In remedial  alternatives  In  addition  to the candidate
         remedial alternatives Included In  the draft  on-s1te feasibility
         study.  In particular, these citizens asked  questions about  In.
         situ biological  processes,  Incineration of the LIParl Landfill .
         leachate, and deep well  Injection  of  the leachate.

         o  In situ biological  processes.   EPA considered using In situ
         biological processes  including Injecting the landfill with
         biological nutrients  and/or mixing the excavated landfill material
         with biological  nutrients.   EPA rejected these options, however,
         because the technology is unproven for  situations  like the UPari
         Landfill site.

         A resident asked if EPA  had considered  using biological microbes
         in the treatment of the  contaminated  leachate.  EPA indicated that
         It may be possible to  add biological  microbes  to improve the
         efficiency of an on-site leachate  treatment  system.  EPA had not
         considered this  type of  treatment  In  the  FS  report.  EPA would
         consider,  however,  adjusting an on-site treatment system with
         biological  microbes.

         o  Incineration  of  leachate.  EPA considered  and screened out
         Incineration  as  an  alternative remedial treatment option for the
         LIParl  leachate.  EPA  believes that the lack of application of
         Incineration  technology  In  treating leachate, its dependence on
         other concentrating processes that are not proven technologies,
         and Its required operator sophistication, would not make "
         Incineration  a viable option at LIParl.   In addition,  the dilute
         nature  of  leachate at LlPari  1s not conducive to incineration.

         o  Deep well  Injection.  Based on environmental and Institutional
         considerations, EPA rejected deep well injection as a  possible
         alternative for remedial action at the Li Par1 Landfill.

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                                   -11-
3.  NATURE AND EXTENT OF CONTAMINATION

         Residents requested Information about the nature and extent of
         contamination Jii *l»;C3MrlQUfld«1J« in Aadd!lJ0n<, j?es1
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                                    -12-
4.  CONTAMINATION OF THE KIRKWOOD AQUIFER

         Residents, the Pitman Environmental  Commission,  and  Pitman
         Township and Gloucester County officials  expressed concern about
         the contamination to the Klrkwood  aquifer.  These citizens feared
         that the contamination to the Klrkwood  sands would result in a
         long-term ground water contamination problem that could  Impact
         potable ground water supplies In the region.  Residents  requested
         technical Information regarding the  following:   (1)  the  rate of
         deterioration of the Klrkwood clay;  and (11) the extent  of
         deterioration of the Klrkwood clay layer  and the contamination to
         the Klrkwood sands.

         EPA responded that the Klrkwood clay layer would last as long as
         the geologic formation of the Klrkwood  aquifer remains Intact.
         EPA Is concerned, however, with the  potential degradation of the
         Klrkwood clay from Us chemical  exposure  at the  Li Pad Landfill.
         Recent laboratory tests have  not been conducted  on the Klrkwood
         clay layer.   EPA believes that it  1s not  certain that laboratory
         tests would  provide  additional  Information about the future impact
         of chemical  contact  to the clay.  Modeling Indicates that it would
         take a single particle approximately twenty-eight years  under
         Ideal  conditions to  permeate  from  the top to the bottom  of the
         clay layer.   The presence of  chemicals  1n the Klrkwood sands
         Indicates that some  seepage has  already occured. The cause of
         this contamination 1s unknown.  The  contamination could  have been
         caused by Improperly sealed wells.   These wells  have subsequently
         been properly sealed.  Contamination  downgradlent of the site has
         not been found 1n the Klrkwood aquifer.

         EPA 1s uncertain whether there 1s any present deterioration.  EPA
         Intends to monitor the Klrkwood  aquifer carefully, to detect
         changes 1n the concentrations  of contaminants in the ground water.

         a)   Question;   A resident asked  1f the  Kirkwood  clay layer had
         been punctured when  monitoring wells were installed to test-the
         ground water.

         Response:  When a  monitoring well Is properly Installed a
         technique Is  used  of grouting and sealing to prevent the movement
         of  materials  from  one layer to another 1n the aquifer.  It Is
         possible that  a minor amount of ground water contamination In the
         Klrkwood aquifer  resulted  from one or two old ground water
        monitoring wells which may have been Installed Improperly..  EPA
         stated that these wells have been sealed and replaced.  EPA
         Intends  to monitor the Klrkwood aquifer during the remedial  action
         at  the LIPaH  landfill and address the existing contamination to
         the ground water.

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                            -13-

  b)   Question;  A resident asked how many towns are currently
  drawing their potable water supplies from the Kirkwood aquifer.

  Response:  Although most potable water supplies draw water from
  deeper aquifers. EPA will assess the region-wide Impact of
  contamination "to the TCI flcwood aquifer during the dTr-sTte'TMTFS.
  EPA has asked Us contractor to use a comprehensive data base to
  study the potential Impact to area ground water supplies from
  contamination of the Kirkwood aquifer.
 Residents and the Pitman Environmental Commission Indicated
 significant concern about the environmental  and public health
 Impacts resulting from the hazardous waste at the UPari  Landfill.
 Residents requested that EPA discuss the status of the off -site
 water, soils and sediment RI/FS activities.   In addition,
 residents requested that EPA provide available results from the
 off-site sampling and testing.  Specifically, residents expressed
 co contJBJMnts ^that -*>er^ .not found ^t tfaet:,liPAPl 4Andf i.ll^  These
 *onta«nlJunts found in Betty Park Include chlorinated  hydrocarbon
 solvents,  pesticides,  and polynuclear  aromatic  hydrocarbons.  EPA
 believes that these contaminants do  not  present a health  efsk to
 residents  In the area.  EPA's  available  test  results indicate that
 bis (2-chlorethyl)  ether Is  not  found  In Betty  Park. In addition,
 EPA's available test  results on  the  Pitman municipal wells  do not
 indicate any contamination.   In  the  next four months, EPA will
                   i^

 soon as possible.

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                            -14-
 a)  Question;  A resident asked how accurate are the EPA and
 contractor  testing  and sampling Instruments.

 Response;   EPA and  the contractor use state-of-the-art equipment
 to conduct  field sampling and testing activities.  The testing
 Instruments and data are checked carefully by the contractor
 quality  assurance staff as well as EPA quality assurance
 personnel.
 b)   Question;  A resident asked where air testing had been
 conducted.In addition, the resident Inquired about what
 pollutants were evaluated and 1f bis (2-chloroethyl) ether
 was  Included 1n the evaluation.

 Response;  A1r testing was conducted at the air vents on the
 landfill site, 1n the marsh area west of Chestnut Branch, along
 the  spill way of Alcyon Lake, and at Alcyon Lake.  The air testing
 was  completed at the end of July.  EPA does not have the results
 at this time.  A1r samples at the vents were tested for the NJOEP
 TVOS compounds.  The remaining air samples were tested for the
 full 129 priority pollutants Including bis (2-chlorethyl) ether.

 c)   Question;  A resident asked why basements along Howard Avenue
 and  Lakeside Avenue were not tested for air quality.  A homeowners
 expressed concern that past flooding may cause contaminants to
 volatlze 1n the air.

 Response;  NJDEP conducted air testing on July 25, 1984 in
 nineteen homes on Howard Avenue.  The purpose of the testing was
 to detect levels of volatile organlcs In the basements.  Levels of
 volatile organic compounds were not Identified 1n eighteen homes.
 NJOEP detected one low level reading 1n one home which was
 attributed to several open paint cans stored near the testing
 location.

 d)  Question;  A resident asked why EPA did not sample the surface
 water and sediments In the southeast portion of Alcyon Lake.
 Several residents commented that they had observed pools of bright
 orange and green color floating on the lake after a rainfall.
                                  •
 Response:  EPA and the contractor conducted tests where they
 believed the best representation of data could be obtained from
Alcyon Lake.  Sediment samples were taken from Chestnut Branch
which contains the same sediment constituents as those wfiich flow
 Into the southeast side of Alcyon Lake.  EPA will release the
 results of the off-site remedial Investigation when the tests are
 analysed and the data 1s assessed.

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                                    •15-

         e)  Question;  A resident asked If EPA, the contractor, and the
         U.S. Army corps of Engineers have Professional Engineering
         44£eoses,  In ^ddiii»on,^hfij:esldent. wanted to know if .these
         individuals and the local and state elected of fi dal s were
         accountable for the work being conducted at the LiPari Landfill.

         Response:  Personnel from EPA, the contractor, and the U.S. Army
         Corps of Engineers are licensed Professional Engineers.  EPA Is
         responsible for and committed to cleaning up hazardous waste sites
         In Hew Jersey.  Although EPA has completed the RI/FS on the
         tm-y1t« controtnatl^^                      Landf f 1 1 , EPA 1s
                   tf^^
         to ensure that there Is no environmental  or health concern  for
         Pitman residents from the contamination from the L1Par1  Landfill.
         f)  a
         are d
Iuestion;  A resident wanted  to know where people currently
isposing of hazardous waste.
        Response;  EPA responded that  all  hazardous ^waste must now  be
         disposed of at tactmies  permTtte'd
6.  COSTS/FUNDING ISSUES

         Residents expressed concern about the  funding  for the  cleanup of
         the LiPari Landfill  site  and any off-site  contamination.  A
         Gloucester County  Freeholder indicated concern about the current
         status of the reauthorization of the Superfund program.  In
         particular, he expressed  a generalized community  fear  that the
   •'  - • •  pqtJential «ytr«tton -?of .^^^iaiit^i?«**t4^fl^-5f^r.:^^^e^uad.;rmay .impact
   -    '•:%ir!
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                                    -16-

          a)   Question;  A  resident asked who pays for the cleanup.

          Response:  The remedial action at the site would use 90 percent
          federal  Superfund money and 10 percent state money.  Normally, the
          operation  and maintenance cost will use 90 percent federal
          Superfund money and 10 percent state money for the first year.
          After the first year, the operation and maintenance of the
          remedial action Is the responsibility of the State of New Jersey.
          However, for the L1Par1 Landfill site, ninety percent federal
          funding  for operation and maintenance may extend beyond the first
          year.
7.  HEALTH STUDIES
         Several Citizens wanted to know If EPA was planning to conduct a
         health study for Pitman residents.  Residents expressed concern
         about the possible health effects to citizens from the off-site
         contamination from the LIPaM Landfill.  Residents requested that
         local and state officials assist them 1n having a health study
         conducted 1n the Borough of Pitman.

         EPA responded that EPA 1s not planning to conduct a health study
         In the Borough of Pitman.
8.  PUBLIC COMMENT PERIOD AND SCHEDULE

         Pitman residents expressed concern about the significance of the
         public comment period on the on-s1te FS report.  These residents
         asked 1f their questions and comments have any Impact on the EPA
         decision on the selected candidate alternative.

         EPA Indicated that the Public Comment Period 1s provided to
         receive comments from concerned citizens on the draft on-slte
         FS report on the LIPaM  Landfill  site.  EPA accepts all  written
         and verbal comments during this period.  The comments are taken
         Into consideration when  EPA makes Its final  selection of a
         candidate alternative for remedial  action.  EPA prepares a
         responsiveness summary to address these comments. The
         responsiveness summary Is Incorporated Into the Record of Decision
         stating the selected remedial  action.

         a)  Question;  A member  of the Pitman Environmental  Commission
         asked when EPA will select the on-slte FS remedial  action
         alternative.

         Response:  EPA will make a decision  In four  to six weeks from the
>pon
)11c
         public meeting after the  Public Comment Period.

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                                      -17-

           b)  Question:   A resident  asked  1f  residents  and  the Environment
           Commission Mill  be  notified of the  remedial alternative selected
           Response:   EPA will notify the public through a press release as
           soon as the Record of Decision Is signed.

           c)  Question:  A resident asked when EPA will release the data on
           the off -site remedial Investigation.  In addition,, the resident
           *tk«d *hen the draft ^>f f-site aj/£S report wtH be available to
           Response:  EPA will release the data from the off -site testing and
           sampling   in the late fall of 1985.  The off-site draft RI/FS
           report will be available In the winter of 1985.
  III.   REMAINING CONCERNS
  site, the on-site RI/FS and off-site RI/FS, Pitman residents, the
  Environmental Commission, and local officials will continue to be concerned
  and  Interested 1n the remedial activities at the site.  Pitman residents,
  the  Environmental Commission, and local officials will be Interested 1n how
  the  findings from the off-site RI/FS Impact the selected remedial action at
  the  L1Par1 Landfill.  During the remedial design and construction of the
  selected on-s1te remedial alternative, EPA should provide Interested
  residents with the available test results from the off-site RI/FS.

      Pitman residents and the Pitman Environmental Commission requested
  thdt-£PA-not$cliaduU the Public Comment Period and Public Meeting on the
 .off-site RI/FS report duri ng the December hoi i days so that all interested
  citizens have the opportunity to comment on the off-site candidate remedial
  alternatives.

      Pitman residents, the Pitman Environmental Commission, and Pitman and
  Gloucester County local  officials will remain  concerned about the funding
  availability for the on-s1te remedial  action and off-site RI/FS and
  remedial action activities at Alcyon Lake while the reauthorlzaton of the
;'$«p«rfund;*rogi« ?^                                - The JMtoau
 €ttv1 roiiaental €wB>1s?ion should be Xept 1nfon»ed of any lapact to the
  schedule of EPA activities because of  this delay 1n the reauthorlzatlon of
  the Superfund Progran.

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                                   -18-
IV. WRITTEN COMMENTS SUBMITTED DURING THE  PUBLIC  COMMENT PERIOD AND EPA's
    RESPONSE

1.  Comments of Rohm and Haas Company

On September 6, 1985, Dechert, Price and Rhoads submitted  comments for
Rohm and Haas as prepared by BCM Eastern Inc.  to  EPA  (Attachment A).  At
EPA's request, COM reviewed these comments and In Its September 18, 1985
letter responded to them (Attachment B).  EPA  has reviewed both Rohm and
Haas* comments and CDM's response, and concurs with COM.

2.  Comments of the Pitman L1par1 Landfill Community  Association

On September 7, 1985 the Pitman L1par1 Landfill Community  association
submitted 1t comments to EPA (Attachment C).

Below 1s EPA's response to these comments  1n the  order they were raised.

Questions for Concern

Comment A

Why was a Remedial Investigation Report (On-slte) not completed  1n May  1985?

Response:

A draft On-s1te Hydraulic Remedial Investigation  (RI) Report for the L1par1
Landfill was prepared by Camp, Dresser, and McKee (COM) 1n May 1985.  This
report discusses the results of the on-s1te testing done which defines  the
hydrogeologlc conditions existing at the site. The site conditions found under
the remedial Investigation were subsequently used during the feasibility  study.

During the review process, 1t was determined,  because of the tlme^frame Involved,
that the resources dedicated to the Llparl project would be better spent  proceeding
with the feasibility study and not finalizing  the Remedial Investigation  Report.
However, the RI work was complete and the  conclusions used In the preparation
of the Feasibility Report.  The flnallzatlon of the RI report 1s needed just  to
formally Incorporate the regulatory agencies'  comments.

The complete findings of the On-s1te Remedial  Investigation were  Incorporated
Into Section 2 of the Final draft Report for the  On-s1te Feasibility Study  for
the L1par1 Landfill.

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                              -19-
  The Off-site RI will not be completed In October 1985 as previously
 ^thedttteTfor  t^
 ^ak«n--.^for.i.'Sthe.iiofsf ^^i*€^s*udy-4»aiw^Mt->^tcvl»eflv^^^Med^.rJan«;' .the laboratory;
  and (2)  more samples need to be taken in response to citizens'  concerns,
  and to complete the data needed to evaluate the off-site conditions and
  to develop  potential off-site remedial actions.  The Off-site RI 1s
  tentatively scheduled to be complete in November of 1985.

  Comment  B
  containment system?

  Response;

  A leach ability  test on a contaminated sample of the Lower Cohansey sand
  was performed under laboratory conditions by R.E. Wright Associates, Inc.
  (REWAI)  in  1981.  The results of this test generally Indicated that 90+%
vW the?«itertrarre^                     £ou Id »be reroowed f wxn the J eachate
;  if 4fl pore  wl«^
  through  a laboratory column containing the contaminated sample.
  Unfortunately,  REWAI did not analyze for the entire mass of contamination
  within the  sample.  Without this Information, the precentage of contamination
  which 1s 1n fact water-transportable 1s unknown.

  Technical concerns with regards to a landfill flushing operation is
  documented  throughout the FS and Include: the potential for short circuiting,
  operation and maintenance (O&M) problems associated with a pump/inject
  system,  maintenance of a vertical hydraulic driving head on the Kirk wood
  Clay, and the Innovativeness of landfill flushing.  Despite these concerns,
  however, there  are positive aspects to the flushing scenario.  For example,
\:^f-;1to';Tm^iti*ar^
  Is 'ImplementeoVttve rotn^rns 'fcfrotfr^^
  minimized.   The potential for short-circuiting Is applicable when water
  1s Introduced to an unsaturated zone and when a pump/Inject methodology
  1s operating simultaneously.  In Alternative 8, the pump/Inject system
  would be a. cyclical operation, that 1s the containment system would first
  be entirely filled with clean water prior to Initiating a pump down or
  "draw" operation.  In this manner, shortdrcuUIng 1s not expected to
'  occur.  Furthermore, should well clogging occur, this situation would not

                    '^^temjor^^^^^^ee^
  problem 1s  rectified.

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                                  -20-
With regards to maintaining a head on the Klrkwood Clay,  this  would
only be a temporary situation until such time as  10 pore  volumes  of
clean water had been exchanged within the containment system (estimated
to require 15 years).  Therefore,  this drawback to the flushing technique
1s only applicable In the short-term and would be expected to  diminish
over time as contamination 1s flushed and removed from the containment
system.  In addition, since the liquid contents of the containment system
will be consecutively raised and lowered, the mean head on the Klrkwood
Clay would be lower than current heads.

It 1s presently unknown whether contaminants have saturated the Klrkwood
Clay layer and are presently seeping Into the Klrkwood Aquifer.   The
contamination found directly under the containment system could has
been a one time event during Improper well Install1on, which have
subsequently been rectified.  It 1s EPA's Intention to monitor the
Klrkwood Clay; and to mitigate potential off-site migration by pumping
and treating should continuous seepage of contaminants Into the Klrkwood
Clay exist and cause a potential health risk.

Finally, with regard to the "unproveness" of flushing, It 1s true that
this has not been tried at landfills such as L1par1.  However, the
technical components, (I.e., pumping and Injection of groundwater)  are
proven technologies.  Furthermore, this technique does represent  a
concerted effort to actively cleanse the landfill of Us  contamination,
unlike the No-Action or any of the Enhanced Containment alternatives
evaluated within the FS.

In this regard, flushing of the landfill to remove contamination  is  a
superior alternative with regards to long-term public health and  environ-
mental benefits.

Containment C

How effective 1s the Enhanced Containment Alternative in  removing toxic
chemicals from the containment system.

Response:

If Enhanced Containment Alternative 14 1s Implemented, contaminated
groundwater will still have a potential to seep  Into the Klrkwood Clay
layer and ultimately Into the Klrkwood Aquifer but at a rate much less
than currently being experienced because of a 14  feet decrease in the
hydraulic head.  This decrease would be a direct  result of dewatering
the Upper Cohansey Aquifer within the containment system - the first
remedial step Included within this Alternative.   The contamination
could be captured by a series of Klrkwood pumping well, so as to  preclude

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            any further contaminant migration  Into the "off-site" areas via this
            route.   Another advantage  of dewatering the Upper Cohansey with the
            
-------
                                -22-
The amount of seepage from the containment system under Alternative
4 will be further decreased once the Upper Cohansey 1s dewatered to
the 100' MSL evaluation.  At that point, flow from the containment
system Into the Cohansey Is expected to cease because of the reversal
of hydraulic gradients.  Instead flow would tend to be from the
Cohansey Into the containment system.  With regards to seepage Into
the Kirkwood Clay this rate would be expected to decrease by almost
SOX to 900 gallons per day.   As noted before, should contamination
of the Klrkwood Aquifer be confirmed and found to pose an environmental
and public health risk, the contaminants would be captured by a
series of Klrkwood pumping wells and treated.

Under Alternative 8 (Flushing), seepage could occur across the slurry
wall where and when the Inside groundwater level Is higher than
outside.  However, the capture of this potential seepage will be
Incorporated Into any off-site remedial action to be taken.

Comment E

Isn't complete removal of toxic wastes from the containment system
a realistic alternative to the Llparl Landfill problem?

Response:

The complete removal option was evaluated as part of the FS.  The
advantage of this alternative is the removal of the source materials
and, therefore, the removal of the potential of further off-site
migration of contaminants.

The drawbacks to a Complete Removal alternative were also enumerated
1n the Onsite Feasibility Study.  From an implementation viewpoint,
complete removal of contaminated material from within the containment
system is practically Infeasible.  This operation would require
site dewatering with associated treatment and disposal of contaminated
groundwater.  In addition, it Is possible that such a dewatering
and excavation operation would need to be carried out within the
confines of some type of structure which would prevent the escape
of toxic volatile organic compounds to the atmosphere - in Itself
posing a health threat the nearby Howard Avenue homes.  Finally,
excavation of the landfill contents clearly 1s the most dangeous
alternative to the safety to onslte personnel.

The concept of partial removal with associated onslte storage, was
proposed by Citizen's Clearinghouse for Hazardous Waste, Inc.  The
Important consideration here Is the definition of "source".  At the
beglnlnning of landfill operations, the "source" was the landfllled
materials.  However, In the several decades since landfilHng began,
the "source" Is no longer just the  landfllled debris, but  also the
nearby contaminated soil and groundwater, which 1s now presently
contained by containment system.  In other words, removal  of the
landfllled materials will not, of and by  itself, solve the on-s1te
contamination problems at L1par1.  R.E.  Wright Associates Indicated

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                                   -23-
 1n  1981 that the Lower Cohansey Sand was contaminated.  More
                                         has Indicated that the groundwater
                                                             Therefore,
 removal of the landfllled materials, while representing a partial solution
 to  the on-s1te contamination problems, would nonetheless need to be
 combined with either a Cleanup (flushing) alternative or an Enhanced
 Containment remedial action to produce an effective remediation of the
 on-s1te area.  A combination of the Complete Removal option and the
 Enhanced Containment Alternative would Include:

*€ircw*t< the ct»U^                                 - an area encompassing
 approximately 6 acres, at an average depth of 15 feet. (Note that the
 Citizen's Clearinghouse did not provide an Indication of the limits of
 excavation).

 'Store the excavated materials 1n an above ground concrete structure
 onslte.

^                                          basis to assess Us Integrity
 'Collect and treat the contaminated groundwater within the Upper Cohansey
 Inside the containment system.

 'Monitor the Klrkwood Aquifer and potentially collect and treat contaminated
 groundwater when the need Is Indicated.

 'Destroy /detoxify the contaminated materials within the concrete structure
 once available technology becomes more cost-effective.

 Preliminary estimates of partial removal and on-slte storage adds a
                                                                      of
             ;4^
cost does not Include the final destruction of the material which would
likely be a significant cost.  For this additional expenditure of funds,
1t  1s possible that the "source" of contamination would be diminished,
potentially resulting 1n a shorter duration for pumping and treating
contaminated groundwater.  However, as stated above a significant portion
of  the "source" material nay have migrated from the original landfill
area to throughout the containment system.  Therefore, 1t 1s conceivable
                    iiaridf # U«d material s wou Id on 1y reduce the source .of
The drawbacks of this partial excavation alternative Include:

    - The danger to on-slte workers from direct contact with the waste
     materials and excavation operations;

         'jpl^^
                             ^                                        .]
      cap,  unless such an excavation operation was carried out within
      the confines of a structure (perhaps air-supported).

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                                  -24-
   - Maintenance of slurry wall integrity.  To ensure the structural
     integiety of the slurry wall, excavation must be undertaken at
     least 20 to 30 feet away from the slurry wall - this would exclude
     excavation of all the landfill material

   - The storage facility, because of its weight, would not be able to
     be sited on the existing containment system.  Constructing a
     storage facility on top of the containment system would cause
     settlement which would be expected to tear the existing synthetic
     membrane liner cap.  therefore, procurement of additional land
     would be necessary so as to be able to site such a concrete structure.

In regards to the wilsonville, Illinois excavations noted in comments,
EPA is not undertaking the excavation of 84,000 buried drums at Wilsonville.
Representatives of the State of Illinois have indicated that excavation
of buried drums is being undertaken by the owners of the site under a
court order.

The advantage to above-ground storage, over in-situ storage within the
containment system, is better control of leachate leaving the storage
system.  In evaluating the alternatives discussed in the on-site Lipari
FS, EPA analyzed the potential for off-site contamination for each
alternative.  In choosing "Flushing* as the recommended alternative,
EPA intends to ensure that potential seepage from the containment
system be mitigated prior to implementation of the flushing operation.

In addition to the controls for off-site migration which will be
implemented during the flushing operation, the operation itself will
ultimately remove the water-transportable contaminants from the soils
and debris within the contaminants system.  The water-transportable
contaminants are those contaminants which could migrate off-site.  If
the contaminants can not solubilize and leave the site in groundwater,
it cannot affect off-site areas.  Therefore, it is felt that flushing,
if implemented, could achieve the effect of complete removal, that
is, the elimination of the potential for off-site migration of
contaminants.

Implementation of the "Enhanced Containment" alternative is analogous
to constructing a buried storage tank with seepage controls.  Under
Enhanced Containment, the "tank" (i.e. the existing containment
system) is already constructed.  This,system has not failed, but is
working as designed.  Should enhanced containment be implemented,
the groundwater within the encapsulation would be lowered so that
there would be no potential for flow to leave the system through the
slurry wall.

Potential seepage out of the containment system will not be allowed
to migrate off-site under either the Flushing or the Enhanced Containment
alternatives.  Therefore, EPA has determined that the additional cost
of an above-ground storage facility would not be warranted.

EPA has recently brought the Potentially Responsible Parties to court
for reimbursement as allowed under CERQA.


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 III.  Other Issues

 Comment A
 received to this date?

 Response:

 To date, only the Hwerganlc fraction of the chemical  analysis of
 Pitman's drinking water has been received from the Contract Laboratory
 Progrw tO3>t» ^fteirwflts^
 •siippljnneets *ttreWfliitt«ry^^                                  .
 This Informal on 1s currently being transmitted to the Pitman Department
 of Public Works.  /As pertains to the organic fraction of the analysis
 and why it has not yet been received, we can only presume that the
 backlog of samples to be analyzed 1n addition to stringent quality
 assurance/quality control procedures have created a delay 1n receiving
 sample results.  Typically, 4 months are required to receive validated
 data from the CLP.  Each of the samples collected from the municipal
 iwater supp^
 Comment B

 Were any levels of volatile organds found in the air of the basements
 on Howard Avenue? 'Why were the basements In homes adjacement to Alcyon
 Lake on Lakeside Avenue not tested for toxic chemicals?

 Response;

 The State of New Jersey conducted an air quality survey of the basements of
 homes on Howard Avenue using an HNu/PIO meter to test for elevated volatile
 organic*.  Of the ihomes surveyed, two showed elevated levels of volatile
 orgaii 1 es above toatikfrauiiia . me elevatefl levels *f outrtK in ^efJfsJrst -home was
 determined to "be srelaJtea to an open ~p«Tift
 The levels found 1n tie second home were found to be just above background
 and not to be of concern.  The results of this survey was transmitted to
 the Gloucester County Health Department.

 EPA did not plan fcestflng of the homes adjacent to Alcyon Lake because It
 did not have reason to believe that there would be cause for concern.
 Results of the prevlois survey Indicated that there are no problems 1n
• ;*to5ha*s';3ii'ttl«^area.;' '"l^ifldStfocm, air ^isin^es'^iwre^lwen^t^cen ^in the
 1 ake area.  Once tfce results oT Jthese samples are; retleve^ , JfPA -w1 1 1
 again evaluate wheittwr further air testing Is required.

 Comment C

 Has the chain link fenee been extended "east of Chestnut Branch to
 ,,j,;4K>lni,.*est ,of .Ohesteut Branch" as Indicated 1n the report?

 Response:

 The chain link fetus east of the Chestnut Branch has been extended
 as shown on Figure 1-* of the Feasibility Study. (See Attachment D)

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                                -26-
Conment D

Why was bis(2-chloroethyl) ether not indicated as having been tested
for on Table VI1-6 in the Interim Draft Work Plan, August 1984?  What
chemicals are being tested for in the air sample testing currently
beinq conducted by EPA above the lake and over the surrounding areas?

Responset

Thirty-one air samples were collected by the BEN II team during
the remedial investigation phase.  Each of these samples was fwarded
to the laboratory for analysis during the last two weeks of July
1985.  Bach sample will be analyzed for priority pollutants including
bis(2-chloroethyl)ether.  The locations of sampling events and the
number of samples collected at each locale are as follows:

               "Onsite gas vents (11 samples)
               'Contaminated marsh area (14 samples)
               *Alcyon Lake outfall (2 samples)
               "Alcyon Lake (4 samples)

Comtent E

Would you explain the discrepancy concerning the buried drums in
Lipari Landfill?
Response:

While there is no scientific "statistical" evidence that buried
drums at the Lipari would no longer be in-tact, experience with
other superfund sites similar to Lipari indicates that buried drums
have a limited life span.  In addition, people who worked at the Lipari
Landfill have testified that prior to landfilling, drums were punctured
and their contents drained.  However, it is not contradictory to say
that seme drums might be intact causing a potential hazard during
excavation.  It is also logical that a drum which may not contain
liquids may trap explosive gases, such as methane, common in landfills.
Excavation of such gasfilled drums is another cause for concern during
an excavation procedure.

Comment F

Was bis(2-chloroethyl)ether tested for in the soil samples from
Betty Park?    '       •

Responset

See letter dated September 16, 1985 to Mr. Douglas Stuart (Attachment E),

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                                -27-
Why aren't all 155 chemical compounds, which have been identified
at the Lipari Landfill listed in the report?

Response;

All chanical compounds identified at the LiPari Landfill appear in
                                            Tables 3-15 and 3-14 were
not 4M*nt to be additive.

Commit. H

Whata does a 10~5 carcinogenic risk mean concerning the jealth and safety
of the families living on the lake? Based on this information, isn't
EPA morally obligated to initiate health studies or tests in cooperation
with New Jersey State Board of Health?
A 10^5 carcinogenic risk concentration means that at exposure to a
chemical at this concentration,, one person in 100,000 has a potential
to develop cancer.  This risk is determined under a health risk
assessment.  The following is a excerpt from Risk Assessment and
Mangement Framework for Decision Making, EPA, December 19851

    Health risk assessments are conducted by scientists, but they
    are not "classical science" in the strictest sense.  For regulatory
    purposes, risk assessments represent a tool that can be used to
    analyze scientific evidence in order to evaluate the relationship
   • 'tjeij»aui «x|iciaut« to^toicic^ siiihstannon .and the pntenf i al -occurrence of
                                 ^                       extreme,
    scientifically verifiable findings, and, on the other extreme,
    judgements about the use of various kinds of scientific information.
    No one should be misled into believeing that results using present
    techniques have the status of incontrovertible scientific agreement.
    Despite its uncertainities, however, risk assessment is the only tool
    EPA has for discriainating among environment health problems.
                                                    .health .surveys of
Itxal raiaCTlfl, n^
been performed.  State Health Departments, in conjunction with local
health departments, apply to EPA to undertake such studies.  Prior to
making a decision, EPA requests the Center for Disease Control to review
the merits of a study and to make a recommendation.  To date, EPA has
received no request fro* the New Jersey Department of Health, to undertake
any such study for the Lipari landfill area.
Isn't it imperatative that the results of the air samples collected from
the five on-site gas vests be released as soon as possible, and not held
until the December meeting?

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                                   -28-
Responset

The analytical results of the air samples collected on the onsite gas
vents and at the off-site areas will be released to the Pitman Environ-
mental Ccmnission when it is received and analyzed.

Concent J

Why were not test core borings done at the back of Alycon Lake, where
Chestnut Branch enters the lake and where the majority of sediment and
silt is deposited?

Response;

The core test boring locations were chosen to provide what was believed
would be representative samples of the Alcyon Lake sediments.  In response
to requests made at the August Public Meeting by concerned citizens that
an additional core boring be taken where Chestnut Branch enters the lake,
arrangements are currently made to take such a sample at the location
requested.

Comment K

Is it possible that contaminants could follow the pathway of the sewer
line, west of Chestnut Branch, away from the landfill and under the
street Lakeside Avenue?

Responset

Five groundwater wells were installed east of the Chestnut Branch for
the express purpose of accertaining the direction of groundwater flow
and its quality in this area.  To date we have no evidence that contaminated
groundwater has traversed Chestnut Branch or is approaching the sewer
line.  The question will be able to be more clearly addressed once
analytical results concerning the groundwater conditions east of Chestnut
Branch have been received from the laboratory.

Comment L

Has testing of the private wells that exist near the Lipari Landfill or
contaminated areas been conducted?

Response:

As far as is known, there are no private wells in the Pitman area near
the Lipari Landfill.  The Pitman Environmental Commission was to survey
the area for yet undiscovered private wells.  The results of such a
survey has not been submitted to EPA.  However, EPA has installed and
tested 6 wells west of the Chestnut Branch, 3 wells just east of Chestnut
Branch and 2 wells along Howard Avenue.  The result of laboratory
analysis of these wells will indicate the extent of potential Cohansey
Aquifer contamination.

-------
                                                                ; Attachment A
  ATT MAOItON AVKNUf

  NIW TOWK, NT 10021

   .iaUI lDf-44OO
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   •Oil til *O 40


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LONDON WCI« 1IX. tNOLANO
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           LAW or net* OF

DECHERT  PRICE & RHOADS

    34OO CENTRE SQUARE WEST
IT>O PtNNIYlVANIA AVI

  WASHINGTON, DC I

    11021 TtJ-OlOO
[NU^^^^^k
 9
     PHILADELPHIA. PA 1O1O2

      TKLEX • « 6334 • BAMOBP

          C&1S)
 >'I«DO MMTN TMMW.tTWHT

   HARRIttuKO. »A I71O1

    I7ITI >19-7*4T
BRAOrORO F. WHITMAN
       FEDERAL EXPRESS               -v >

       James C. Woods, Esquire
       General Enforcement Branch
       Enforcement Division, Region  II
       Environmental Protection Agency
       26 Federal Plaza
       New York, NY  10278
             ""He:'
                   the Final Draft Report,  Onsite Feasibility Study
                   for the Lipari Landfill
       Dear Mr. Woods:

              On behalf of our client,  Rohm & Haas Company, we  are
       submitting herewith the technical comments received from our
       consultants, BCM Eastern  Inc., professional hydrogeologists,
       with respect to the Final Draft  Report, Onsite Feasibility
       Study for the Lipari Landfill, which was prepared by Camp,
       JDresser & McKee, Inc.  As you know,  we requested permission
      if rom EPA ,i to, submit, our t«ehnica"l connnent^ o^ ^           ,
       1985 in view of the magnitude ""c>f "the jara^f±Jureport «n^a
       technical issues contained  therein.   EPA has insisted  that
       our comments be submitted by September 9, 1985.  Accordingly,
       we are submitting herewith  a synopsis by our consultant  of
       the technical deficiencies,  which are significant, with  respect
       to the alternatives evaluated by Camp, Dresser & McKee.   in
       addition, we have asked our consultants to prepare a more
       detailed description of the alternative plan for upgradient
      : grOMW^ater /WMiagement vtittit^'%i«-
-------
BCM          BCM Eastern Inc.
*—^^-r1      J .         Engineers. Planners and Scientists
      One Plymouth Meeting • Plymouth Meeting, PA 19462 • Phone: (215) 825-3600


                                              September 6,  1985
   Ellen S.  Friedell, Esquire
   Senior Counsel
   Rohm and  Haas Company
   Independence Mall West
   Philadelphia, PA  19105

       Subject:  Review of Onsite Feasibility Study
                for Lipari Landfill
                BCM Project No. 00-5371-06

   Dear Ellen:

   BCM  has  completed  our preliminary  review of  the  "Final  Draft Report  -
   Onsite Feasibility  Study  for Lipari Landfill"  prepared by Camp  Dresser  &
   McKee, dated  August 1985.   Due to  the  extreme  time limitations  placed on
   the review,  we had not been  able  to perform the comprehensive evaluation
   a  project  of  this  size   and  significance  requires.   Nonetheless,  our
   examination  has revealed that, for  reasons  unknown to us,  the  USEPA  and
   their contractor continue  to ignore the  passive containment  approach to
   managing  this  problem  and, as a  result,  the  feasibility study  is  quite
   incomplete  in  its analysis  of  alternatives.

   Background

   The  fundamental problem being addressed  in  this  report  Is  that,  having
   built a containment wall  and cap  completely surrounding the  landfill,  the
   site will nonetheless continue to discharge groundwater  (presumably con-
   taminated)  through  the natural  Kirkwood clay  underlying the  site.   This
   continuing  discharge  is  brought  about because of the head (pressure) dif-
   ference between the outside of the  slurry wall,  the inside  of the slurry
   wall, and the  Kirkwood  clay  and  underlying  sand  - each having  a higher
   head than the  following one.   The  slurry wall, although  highly Imperme-
   able, will  allow some leakage of clean groundwater  Into the inside of the
   containment  system.  This   leakage in turn maintains  a  higher water  level
   (head, pressure) inside the  containment  system forcing contaminated flow
   downward into  the  lower pressure Kirkwood  formation.
                  A Member Firm of Betz«Converee«Murdoch*lnc.

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BCM
      Ellen S. Frledell, Esquire            - 2  -                September  6,  1985
     EPA  Solution

     The  alternatives  examined by  EPA  in the  report  are all  analagous  to
     Mend-of-pipe"  approaches,  i.e., rather than  prevent the leakage of  clean
     water  Into the containment area  (and  subsequent contamination) they have
                                                            sands to .remove  and
                                                                encourages
      into the deeper zones and leakage through the slurry wall.

      Alternative

      We  have not  found in the report any reference to controlling water  levels
      outside of the containment  wall.   In our  report  to you  in  May 1982,  we
      supported  the concept  of  the slurry  wall  at  upgradient  locations  (as
    :'?swppos«d; .-5t»-;-':^coinp^'^te^.^conti'a4»mej>.t.)  ~,and  xeconmended,  at  that  time,  the
    -~^^Wtt«14«te4w^f;^^                                              the  slurry
      wall.  Quoting from  pages 12  and 13 of our  report:

         "Although the slurry trench cut-off wall ... provides  a  vertical
         barrier  to groundwater  movement  beneath  the  site,  a secondary
         diversion method,  a groundwater interceptor drain at  an  upgradi-
         ent  location,   is  also  recommended.   The  performance  of  the
         cut-off  wall  can be maximized  by reducing the groundwater  level
         upgradient  of it ...   The underdrain  system  would be  installed
         with  a high  point  on  the west side of the landfill.  Discharge
         to  the  lower end  of  the  existing  Lipari ditch  and Rabbit  Run
         would  be accomplished through the use of exit  headwalls.
     "The  uptjratftent W^ ^Wt»^                                       «nviron-
      mentally superior to  the alternatives  presented in  the  EPA report  when
      subjected  to  the  same  rigorous  evaluation.

      The  benefits  of diverting clean  water around the site  are effectively to
      cease  the  discharge of  any  contamination  from within  the landfill,  to
      protect  the  physical  integrity  of the  slurry wall,  and to prevent  the
      downward migration of  contaminants  to  the Kirk wood sands.
      In our May,  1982 report  to  you we  recommended that the  installation  of
      the cap begin  as early as possible,  even before actual slurry  wall  con-
      struction,  to minimize the "bath  tub" effect,  i.e., filling  the enclosed
      area with  infiltrated  water  and,  in  effect,  saturating the  entire land-
      fill area.   The  EPA report  alludes  to an  apparent  problem resulting from
      poorly planned ami fmpl«men^                                   -£or Ihe
      peri od~T)ecember , "1983  'to^Sepl3Snb«r ,  '1J984 ;>*he kamtatflment ..system ^ id  in
      fact  fill  up,  causing,  among other things,   the contamination  of  an
      additional  25-50 million gallons of water.

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BCM

   Ellen S. Friedell,  Esquire           -  3  -                September 6, 1985
   Therefore, the  Implementation  of the alternative upgradient drain system
   described above may require partial dewatering of the contained area.   If
   so, the volume of contaminated water and the concentration  of contaminants
   are probably much higher now (perhaps twice in  both  cases)  than would have
   been the case had proper construction sequencing  been  used.

   Summary                 .

   Based on  its  expedited  review of the Onsite Feasibility Study by COM  and
   without  any  additional  site  investigation,  BCM  believes that  the  COM
   Report has failed to consider  perhaps the  most advantageous remedial sol-
   ution to the  problem of managing leachate  at the Lipari  Landfill; namely,
   the  installation of  an  upgradient diversion trench.   This  alternative
   should be fully  examined  before  any decision  is  made  by  the U.S.  Environ-
   mental Protection Agency.
                                                   [truly yours,
                                               Richard J. Grzywinski, P.E.
                                               Senior Vice President
   /pd

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tnwronnwnuf engineers. »ci»r>tim.
pfanners. A management coRSutants
September 18, 1985
                                                              - ""At tsch«ent fi

                                                         CAMP DRESSER & McKEE INC

                                                         Rantin Plaza III
                                                         Rantan Center
                                                         Edison, New Jersey 08817
Mr. Ronald J. Borsellind, P.E.
Emergency and Remedial Response Division
26 Federal Plaza - Room 711
New York. New York  10278

Project:  REM II - EPA Contract No:  68-01-6939

Document Control No:  104-RI1-EP-BNHP-1
          Response to Comments by Rohm &  Haas  Company
          Re:  Final Draft Report,  Onsite Feasibility Study

Dear Mr. Borsellino:

Introduction

The purpose of this letter is to respond  to comments (see enclosed) on the
subject report which were recently  forwarded to USEPA by Mr. Bradford F.
Whitman of De chert Price & Rhoads,  legal  counsel to the Rohm & Haas
Company.  These comments were prepared by Rohm & Haas* technical
           ^                                           the issue of an
           f^^                      ..fc^iitted'^as ;»»rt of > ttoe "Onslte
Feasibility Study prepared by the REM II  team.  This alternative was
initially proposed by 1CM in their  May 1982 Preliminary Engineering Study
of the LiPari Landfill site.  BCM recommended at that time, and continues
to recommend, the Installation of a groundwater diversion system to be
located upgradient of the landfill  site.   Such a system, according to BCM,
would serve the purpose of diverting clean upgradient groundwater around
the landfill so as "to cease the discharge of any contamination from within
    ^^^^                                             of the slurry wall, and to
                               •••'§0? ' '
 Alternative Description

 Our  review of BCM's 1982 report revealed that the system proposed would
 consist  of a diversions trench running along the northwestern, western,  and
 southwestern portions of the site (BCM sheet 2 of 3).  The bottom of  the
                                 .Hd;ijine,te.r.pV.C pipe acting as an  underdrain.
                                               ,
 3/4-inch to 2 -i nets diameter) would surround the perf orated TVC  pipe.  *Two
 layers of plastic filter cloth would be wrapped around the stone.   The

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                                                      CAMP DRESSER & McKEE INC.
underdraln system would be Installed with  a  high  point  elevation  107  feet
above Mean Sea Level  (MSL) on the west side  of  the  landfill.  Discharge  to
the lower end of the existing LiPari ditch (elevation  104  feet) and Rabbit
Run (elevation 105 feet) would be accomplished  by the  use  of  exit
headwalls.  The high point of the underdrain system was designed  to
correspond to the suspected low point elevation of  the landfilled waste
materials.

Technical Evaluation

The inherent difficulties envisioned with  this  system as currently proposed
are as follows.  The "source" of contamination  currently encapsulated by
the slurry wal1/synthetic membrane liner system consists of more  material
than just the landfilled debris.  In actuality, the Upper Cohansey sand
(generally at an elevation above 100 feet) and  the  Lower Cohansey sand
(generally at an elevation between 90 and  100 feet) are both contaminated.
Contamination within the Lower Cohansey was reported as early as  1981 in   .
R.E. Wright Associates report entitled "Technical Considerations  for the
Selection of an Abatement System at the LiPari  Landfill, Pitman,  New
Jersey".   It should be noted that this spread of contamination into the
lower formation occurred prior to installation of the slurry wall in 1983.
Because  the contamination occurs at least to the top of the Kirkwood clay
(elevation 90 feet), installation of a groundwater diversion trench having
a highpoint of  107 feet,  in our opinion,  is inappropriate.  The major
concern  is that at some point in the future the slurry wall will  become
increasingly permeable due to chemical degradation.  With the diversion
system as  currently proposed by BCM, a portion of the upgradient
groundwater would be able to seep into the encapsulation via the Cohansey
Formation  by migrating  beneath the  diversion trench, pick up water
transportable contaminants present  throughout the encapsulation, and carry
the  contaminants  into  off-site areas thus perpetuating the existing
environmental problems.

Revised  Alternative

Perhaps  a better  approach to  upgradient groundwater diversion would  be  to
install  the  underdrain system at  an elevation  along the top  of the Kirkwood
clay.   If properly  designed  and  constructed this system may  be effective  in
depressing upgradient  groundwater levels  in the  trench to the 90 to  95  foot
elevation"and preclude groundwater  from migrating  beneath the trench by
 virtue of the less  permeable Kirkwood clay  which would form  the  diversion
 trench base.   To perform such a  task, preliminary  design  dictates the
 following:

     o  The trench would need to  be located  30  feet away  from the
        existing slurry wall  so as to not  impair  the integrity of the
        wall
                                   -2-

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                                                      CAMP DRESSER & McKEE INC.
    o  The length of  the trench would  be approximately 2,000 feet

    o  The base of the trench would  be 3 feet wide with an average
       depth of 30 to 35 feet
                                                        Skater ;
       and backfilled with  gravel to  an  elevation of at least 115
       feet.  The trench would then be backfilled with clean fill to
       existing grade

With such a system in place,  it  is estimated that the water level within
the encapsulation would decrease to an elevation of 93 feet above Mean Sea
Level in approximately 10 years  and reach  equilibrium after 20 years at 91'

         t^«w«tfr»^                                       .site .and
through the northeast portion of the  slurry wall.   Installation of an
upgradient groundwater diversion system  will not  "...cease the discharge of
any contamination from within the landfill..."  for  at least 20 years, if
ever.

Revised Alternative Evaluation

The deeper trench system described above:  however,  also  has many  problems
associated with it - many of which are  also  applicable to  the shallower BCM
design.  For example:
       groundwater is able to traverse the system, water-transportable
       contamination within the encapsulation will be able to be
       picked up by the groundwater, particularly as the slurry wall
       becomes more permeable, and moved into offsite areas which
       presumably will have been remediated.  This scenario would
       result 1n a re-birth of the existing environmental problems
        report Indicated that the 3-foot wide trench would extend
        vertically from its base a total of 6-feet before a wider
        trench opening would be necessary.  Because of the nature of
        the material in which such a trench would be excavated (I.e..
        sand) we would preliminarily suggest that 3:1 side slopes be
        used.  Based on a 30-foot deep excavation with only a 3-foot
                   Ws^^
                             ^^^                                  a
        trench opening of 111 feet would be necessary.  With such a
                                  -3-

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                                                   CAMP DRESSER & McKEE INC.
   larqe trench opening  required,  and  since the excavation would
   be required to be no  closer  to  the  slurry wall than 30 feet,
   construction of such  a  diversion  system would  require the
   acquisition of additional  land  from Mr. Douglas Zee whose apple
   and peach orchards currently surround the site

   The necessity of opening  such a large trench could be
   eliminated if sheeting  and bracing  were utilized to hold open
   an excavation of the  magnitude  envisioned.  However, this
   provision would again add significantly to the cost of this
   alternative.  An additional  consideration should sheeting be
   used would be the possibility of  puncturing the Kirkwood clay
   during Installation of  the sheeting.  Such a situation would
   need to be avoided to preclude  any  chance for  groundwater
   contamination in the  Cohanse.y migrating into the underlying
   Kirkwood aquifer

o  To construct either the shallow or  deep trench will require a
   large amount of groundwater control.  Presumably the  pumped
   groundwater could be  discharged into  either Rabbit Run or
   Chestnut Branch if a  discharge  permit is  granted by the  New
   Jersey Department of  Environmental  Protection

o  During a trench dewatering operation, whether  it be BCM's
   design or the "deeper" alternative, the REM  II team's
   groundwater computer  model indicates  a  strong  probability that
   contaminated groundwater will be drawn  into the  trench.
   Existing water level  elevations within  the encapsulation are  at
   114' MSI.  The water  levels within  the  trench  during  its
   construction  (and after construction) are estimated to  be  in
   the  90 to 95  foot range, therefore  hydraulic  gradients  will  be
   reversed from their present condition with seepage of
   contaminated groundwater tending to flow  from the  encapsulation
  . area toward the trench.  Should contaminated  groundwater enter
   the  trench, discharge to Chestnut Branch  or  Rabbit Run  will  be
   prohibited.   Therefore, utilization of  an onsite treatment
   plant or collection and disposal at a permitted  hazardous waste
   treatment  facility will be necessitated.   In  addition,  the
   Issue of worker safety would become magnified.  Without
   groundwater contamination 1n the trench.  Level U personnel
   protection  could  be utilized.  With the presence of this
   contamination: however. Level C and perhaps  Level  B would  be
   required --resulting 1n significantly higher construction
   costs.  The head  differential between the diversion trench  and
   the  water  level  inside the encapsultion could be diminished if
   the  contents  of the encapsulation were dewatered.   As Indicated
   in the Onsite Feasibility Study, dewatering  of the Upper
                              -4-

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                                                       XAMftDRESSER* ,McKEE INC.
        Cohansey inside the encapsulation  is  feasible.   If  implemented
        this operation could lower the Mater  level  to an elevation of
        approximately 100*  HSL.  thus diminishing  the head differential
        between the diversion trench to approximately 5 to  10  feet.
        This would decrease the  rate of seepage toward the  trench but
        not eliminate it.   Seepage Into the trench  could perhaps be
       ;£w**nt»ii-^>i!i^^
        and the trericV. This opefat1w'Tnafy''J1nniiewr^^if^ie«fit^Y
        impact the integrity of  the slurry wall in  addition to
        significantly raising construction costs

        It should also be pointed out that should the water level
        within the encapsulation not be lowered,  the potential  for
        hydrofracturing of  the slurry wall exists in the vicinity of
        the diversion trench since a greater  than 15 foot head
        4£i»eiT..-;Jtey;:.lS82 /t*^
 offer any "enhanced containment".  ""Rattier,

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                                                       CAMP DRESSER & McKEE »4C.
the encapsulation without any provisions for prevention  of  contaminant
migration into offsite areas.  Carrying the diversion  trench  idea  one step
further by extending the trench to the top of the Kirkwood  clay makes this
alternative a sounder technical solution than the BCM -proposed shallow
trench but it too is wrought with technical difficulties as discussed.
From an environmental /public health viewpoint the diversion trench
alternative should be acceptable providing that contaminated  groundwater is
not drawn into the diversion system and providing that appropriate safety
practices for deep excavations are followed during construction.
Institutionally, difficulties may exist with the point discharge of
groundwater to Rabbit Run and Chestnut Branch.  We are currently discussing
this situation with NJDEP and will respond to you with their  conclusions
under separate cover.  As concerns public acceptability, it is our
judgement based upon the August 15, 1985 public meeting in  Pitman  that  a
groundwater diversion trench would meet considerable resistance  and be
considered by the public to be an unacceptable alternative.  Finally, with
regards to cost, we have considered two different "deep" excavation
scenarios and costed them accordingly.  These costs are estimted to range
from approximately $2.2 to $2.6 million (see attachment).

We trust that you will find this  information suitable for Inclusion in  your
evaluation of remedial actions for the onsite portion of UPari  Landfill,
Shu Id you have any questions or desire any additional  information
concerning the above, please contact me at your convenience.

Very truly yours,

CAMP DRESSER & McKEE  INC.
 Robert  A.  Hyde,  P.E.
 Site  Manager

 RAH/rw

 Enclosures

 cc:   G. Rief  COM/NY
      li. Benson COM/NJ
      0. Fillos COM/NY
      k. Schreiber CUM /Bos.
      L. Partridge COM/Bos.
      C. Winklehaus -  Clement  Associates
      R. Coad  • WCC

 (RW11/23)
                                     -6-

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                                           Attachment  C
PTTMA7I LTPART  LAtlDFTLT,  COMMUNITY ASSOCIATION
              ...C.OI4r.KM,T RESPONSE
                      •*?0
FT:IAT, UKArT" REPORT,  OMSTTl' PEASIBTLTTY STUDY
              FOR  LTPART LANDFTLL
                SEPTEMBER 7,  1985

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i.
     From our careful examination of the Final  Dra-ft Report,
Cnr:lte Feasibility Study for LiT>arl Landfill,  and after the Public
Town Meeting on August 15,1985, many alarming questions and issues
have arisen.  These concerns cover a multitude  of areas which will
be presented in the followln-r sections.  Additionally,  and most
importantly, a comment response from Stephen Lester, Science  Director
for Citizen's Clearinghouse for Hazardous Wastes, Inc., is attached
and is to be considered part of our comment report.


II. QUESTIONS FCH CONCERN

A. Why was a Remedial Investigation Report (Onsite) not completed
   and ?*lven to Pitman for review and study in May  1985, as scheduled
   in the February 6, 1985 letter to Mr. Campbell, from Salvatore
   Badalamenti. (letter attached)  Mr. Borselllno, Project Manager,
   Indicated that an Incomplete Remedial Investigation Report was
   included in the Onsite Feasibility Study.  We understand that  it
   has been routine for EPA to complete this report prior to the
   Feasibility Study.  Why was this done differently?  Is EPA rush-
   ing through the normal procedure? How can we  or  EPA intelligently
   select a cleanup alternative without thoroughly  understanding  the
   r.cope of our problem?  Will a Remedial Investigation Report  (o~f-
   r.ite) be completed in October 1985 as scheduled  in  the abova '.ra-
   tioned letter? If not, why not?

". .:'ow effective  is  the flushing method in  removing toxic  c-:e  !.c: V.
   t'ron  the containment system? Your answer should  consider  \. '
   ?.ddress  the following:

    1. Is it true  that "flushing  should  not  be  viewed as   beinr  crj-.-
      pletely  effective?"   (FS 3-65)

    ~. T.s it true  that "short circuiting caused by the  hetero r^- —'V-
      tcs  in the  soil and  especially in the landfill area, will re-
      duce  the effectiveness of  the (flushing)  system?"   (FS >'!")

    7. Is it true  that "other operational problems,  such as clo...lnf
      and  maintenance of the pump/infect system, will  lessen the
      effectiveness of  the (flushing)  system?"  (FS 3-65)

    4.  Is it true  that "vertical  seepage and flushing through this
      lower unit  (Lower Cohansey)  will, however, continue to occur"
      with the flushing method?   (FS  3-65)

    rj*  Is it true  that "if  flushing of  the soil within the cont?Arnrrt
       v.-f»re carried out repeatedly until the flushing water rhowrd only
       trace amounts of  contaminants,  this would not indicate that the
       r.oil is free of contaminants" (FS 3-118) since "no Information
       is available on  the absorption, ion exchange, and similar
       mechanistic behaviors of the chemical/soil combinations found
       in the landfill?" (?S  3-116)

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    6. Is it true that "flushing of the encapsulation system to
       actively attempt to remove water soluable contamination
      «£TQIB -the ,Cohansey Formation is not considered to be a re-
    7» Is it true that "residual contamination around the encap-
       sulated soil matrix and not presently removable by hy-
     .  draulic flushing might be released and become water trans-
       portable at some future time due to changes in the soil
       micro-environment?"  (PS  4-49)

' -;.'  B* la it true that the percentage of water *oluabl.^ cfaemicale
       in Lipari Landfill is not known?


C. How effective is the Enhanced Containment Alternative in  re-
   moving toxic chemicals from the containment system?  Your answer
   should consider and address the following:

    .4* .Js,J.t true that the containment system would continue to
       ^fieep chemicals for  the next 35 ^
       tive?

     2. Is it true that "active cleanup of  the  site would not be
       .practiced and contaminated soil would be  left  in place"
        (PS  3-3) further endangering the lives of 'residents around
       the landfill and lake?
                                                                 d^^^
 Is it true  that "if  the  Upper Cohansey is dewatered,  as p
 posed in Alternatives 3  and 4.  then the potential for hyd
 fracturing  would exist...?"  (PS  3-108)

Js«vAfc«&Bue  43aat ".enhanced containment, in general, is  a
-&c»3&a&9'-.iriLt»X^
 sulatlon system is maintained?'" ITS 4-46}
 Is it true  that under the alternative of dewatering the en-
 capsulation system and pumping the Kirkwood, the existing en-
 capsulation system "would need to be replaced at such a time
 as its hydraulic conductivity is considered to have degraded?"
 (PS Table 4-4)
                                                water, levels within
                                                                   a '
        loss of wall integity, and repair of the wall is not undertaken
        exterior groundwater will be able to enter the encapsulation,
        pick up water transportable contamination, and migrate into
        the offaite areas?" (PS 4-46)

     7. Ts it true that the report raises many questions about the
                        ;^^

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Can the containment system be guaranteed not to further  leak -
any of the 155 toxic chemicals,.jeopardizing the health and safe-
ty of nearby residents, for the next 8 to 35 years,  under the
cleanup alternatives suggested by EPA?  Your answer  should con-
sider and address the following:

1. Is it true that the Kirkwood layer is leaking chemicals at a
   faster rate than anticipated,  due to "improperly sealed wells
   or because of the degradation of the structure of the clay soils
   by organic solvents?" .(FS 4-71)

2. Is it true that  the "clay layer may deteriorate and become more
   permeable without being able to be repaired?" (FS 4-59)

3. Is it true that EPA stated that 1800 gallons of contaminated
   water a day is presently seeping through the Kirkwood bottom?

4. Is it not true that "if non-aqueous pools of solvents reach the
   interface between the bottom of the Cohansey sand aquifer  and
   the top of the Kirkwood clay layer, the effects of  the  latter
   material and  its permeability  are  likely to be severe?"  (4-73)

5. Is  it  true that  if  the  slurry  wall comes in  "contact with-aqueous
   solutions, suspensions  or  emulsions of organic chemicals,.it  is
   likely to  impair the walls integrity  over time?"  (FS  3-116)

6. Ts  it  true that  "little  information is available  regarding soil-
   bentonite waste  interaction?"  (.'FS2-37)

7. Ts  it  true that  "it cannot be  precluded  that non-aqueous phase
   liquid organics  do  not  exist  at  the site?"  (FS 2-38)

8. Ts  it  true that  "during excavation of the  slurry trench, several
   cave-ins  of  sidewalls  and sediment events  occurred?"  (FS 2-32)

9. Ts  it  true that "in those areas  where cave-ins occurred during
   construction jof the slurry trench, permeabilities may be greater
   than specified?" (FS 3-116)

10.  TS it  true that "it is these areas (cave-ins)  where the occur-
   rence  of hydrofracturing would be more susceptible?" (FS 2-32)

11.  Is it true that  "little is published in the literature describ-
    ing the phenonmenon of hydrofracturing through a soil bentonite
    slurry trench cut off wall?" (FS 2-34)

12. Is it true that under alternatives 2,3,4, and 7, "the existing
    encapsulation system would need to be replaced at  such a  time
    as its hydraulic conductivity is considered to have dgraded to
    an unacceptable level" at a cost of $2,144,000 in  present day
    dollars?" (FS Table 4-4)

13. Ts it true that "bis(2-chloroethyl)ether is predicted  to  occur
    in Alcyon Lake at  concentrations  that exceed its criterion for
    human health" even after  the  completion of the containment sys-
    tem?" (FS 4-76)


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14. js it true that "estimated long term concentrations  in Alcyon
    Lake of bis (2-chloroethyl) ether  does indicate the  potential
    for increased risk to public health?" (FS 4-76)
                                                .-toave 4>een
                    <^V^,^
    other 155 known chemicals could be escaping from  the containment
    system at dangerous levels?

16. Is it true that little is known about low level concentrations
    of toxic chemicals on human health?
   - VT» "Wt -xftrw^Gl^t^
  ; ' "the p
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   4. Is  it true that high risk exposure during excavation could be
      greatly reduced in a variety of ways?

   5. Ts. it tru that cost was a major factor  in EPA eliminating the
      complete removal alternative? It  is our understanding that the
      Superfund Act of 1980 was designed to make responsible parties
      liable  for clean-up operations.   Furthermore, if the responsi-
      ble parties  refused to clean up the designated  sites, they
      could be  sued for reimbursement and assessed damages of  up to
      three times  the cost of the clean-up.   As stated in a  1982
      court document (USA vs. Nick Lipari) Civil Action  No.  80-79,
      hazardous wastes were  generated by Rohm and Haas Company,
      Owens-Illinois, Inc.,  and CBS Records,  Inc., at Lipari Landfill,
      What legal action has  been  taken  in regards to  financial obli-
      gations by these companies?
TTT.  OTIT3R ISSUES TO ADDRESS


A. \Yhy.have the laboratory analysis of Pitman's drinking water, sam-
   pled in March 1985 by the REM II team, not been received as of this
   date? We understand that water analysis usually takes a maximum
   of six weeks to complete.  We would like to know if all of the
   priority pollutants were tested for ( If not, why not.) and why
   these tests are taking so long.

B. Were any levels of volatile organics found in the air of the base-
   ments on Howard Avenue?  What does the phrase "not a significant
   level1 mean concerning these tests? (FS 1-14)  What kinds of tests
   were conducted, what chemicals were tested for, and would you send
   a copy of these test results to us?  Also, why were the basements
   in homes adjacent to Alcyon Lake on Lakeside Avenue, not tested
   for toxic chemicals since bis was detected in the lake at health
   risk concentrations and many of these basements have underground
   streams flowing beneath them?

C. Has the chain link  fence been extended  "east of Chestnut Branch to
   a point west of Chestnut Branch" as  indicated in the report?  (FS  1-14

T. Since  "the  major  hazard associated with the Lipari Landfill con-
   tamination  has been considered to be  the  presence of  bis(2-chloro-
   ethyl)ether"  and  one  of the  "typical  routes  of entry  for this
   compound  includes inhalation of vapor"  (FS  1-17) why  hasn't an
   extensive monitoring program occurred before this time?  As early
   as  1979,  the  DEP  confirmed  the presence of  bis(chloroethyl)ether
    in  the air  in'Pitman,  100 yards i-away from  the major  leachate stream
    (Letter from  Richard Katz,  NJDEP, Oct.  22,  1979  to Dr. Lipsky)
    Furthermore,  why was bis(2-chloroethyl)ether not indicated as
    having been tested for  on  Table VTI-6  in  the  Interim Draft  V/ork
   Plan.  August  1984? What  chemicals are being tested  for in  the air
    sample testing currently being conducted  by EPA above the  lake  and
    over surrounding areas?

-------
   V.'ould you explain the discrepancy concerning the buried drums  in
   Lipari Landfill?  The report states that "there is also the  poss
   bility during, excavation that buried drums could be ruptured or
   disturbed to such an extent that fires or explosions might occi
  J[i!S ;4*44?):., f.ilowe»er,'-;«?t:: :tte£>AugiiuStv:fl^^^                A resident'
   asked how flushing could "be an etlective alternative 'rff bttried
   drums were still in tact in the containment system.  An EPA  offi-
   cial replied that according to statistical data, all of the  drums
   would have disinter grated by now.  Which  account is the  accurate
   one and what statistical information is there to support  or  confirm
   it?
                                                              from
   Betty Park?  Would you please send us "the "TdTlowing itfforma'tion,
   as requested in our letter of August 19th,  1985,  which no reply
   has been received as of this date: (copy of letter attached)
   the type of tests taken, the chemicals tested  for, test results
   and any other data that could alleviate our concern?

G. Why aren't all 155 chemical compounds, which have been identified
   at the Lipari Landfill, listed  in the report?   There are 123 chemi
  r"3-14 ITS) whichtotal T;o a sum  0X156.  *Whact <«re"*the"mlss^n'g 5t9
   chemicals?

H. When the report states that  "preliminary calculations have demon-
   strated that one of the indicator chemicals- bis(2-chloroethyl)
   ether is present at a point  of  potential exposure at concentrat
  that could result in a greater than 10*' carcinogenic risk" (FS
   106), what does this mean concerning the health and safety of
   families living on the lake? Based on this information, isn't
   ;TA morally obligated to  initiate health studies or tests in
   cooperation  with the New Jersey State Board of Health?
   '. s&nee /:*fre '*:« jKsm/«tsste8' ''*toa't •-••several;- -'io¥•• IBjbe •
   partition  to the air and "then 'be; "*• carried" *lDy~l7he ^ot?al-^lr ut:iirr«nts
   to  any receptors, for example, the houses on Howard Avenue  in
   Pitman..." (FS 4-66) isn't it imperative that the results of the
   air samples collected from the five on-site gas vents be released
   as  soon as possible, and not held until the December meeting?

   Why were no test core borings done at the back of Alcyon Lake,
   where Chestnut Branch enters the lake and where the majority of
   «eatffleirt?3Bna'^;*il* ^\'ltei«ra!lfce1I?^ £^
   were tiSLken on the -oppftBTte^l^ %f %
    is considerably lower.  To further substantiate our concern, over
    the last eight years, the water level at this location  of Alcyon
    Lake has gone from five feet deep to an actual island with  many
    multi-colored'layers, persumably chemical buildup, surrounding it.
    It is our contention that core  borings should be  taken  at this
    area so as to give us a more accurate evaluation  of the toxic
   A, ~~~-~»,w-,,,~lpo1«]^^

    Lake?  We believe that the three core borings  done  across from
    Betty Park were taken very close to this  stream and not in th<
    where the chemical laden sediment has been  deposited over the
    twenty years.

-------
X. Since the County Sewer Line runs parrellel to the landfill and -
   lake, and is situated between Chestnut Branch and Howard Avenue,
   is it-not poasible that contaminants could have reached the under-
   lying stones, which would act much as a french drain system, and
   followed the pathway of the sewer line away from the landfill and
   under the street Lakeside Avenue?  If so, will EPA test in these
   areas?

L. Has testing of the private wells that exist  near the Lipari Land-
   fill or contaminated areas been conducted?  These tests were dis-
   cussed at the January 1985 Town Meeting and referred to in the
   February 6, 1985, letter sent to Mr. Campbell, Chairman of the
   Pitman Environmental Commission, from Mr. Salvatore Badalamenti.
   (letter attached) If the testing has not taken place to date, why
   hasn't it?


TV. CONCLUSION

    V/e  are extremely unhappy  with  the  cleanup  alternatives being con-
sidered by EPA  for  Lipari Landfill.  These  three  alternatives  do not
address the contaminated  soil or much  of the toxic  waste,  and  the de-
gree  of their success  is  seriouly  questioned by our expert,  Stephen
Lester, and the  Feasibility Study  itself.   The encapsulation system
is not  as effective as we had been lead to  believe  and over  a long
period  of time,  its integrity is extremely  doubtful.  Furthermore,
we  feel that  EPA has not  thoroughly examined other  realistic alterna-
tives,  in particular,  the Complete Removal  with onsite storage.  This
alternative addresses  the source of the contamination and would allevi-
ate  further long term  chemical exposure to  residents.  Finally, we
conclude  that a lack of data and the lack of significant air/soil/
water testing have seriously jeopardized both  .bur  ability and EPA's
ability to  evaluate and ascertain  the scope of our  problems.
     We would  also like to make mention that many of these concerns
were not  stated prior  to this date due to the  fact  the the Draft Work
Plan for  the  Lipari Landfill Site  was never put into the town library
 and made  available for public review until May 1985f four months after
 the January Town Meeting.


 V.  RECOMMENDATIONS

 A. That a written response be made by EPA to address all questions
    and concerns in our comment report.

 B. That more acceptable clean-up alternatives be explored which .would
    remove the majority of the 155 known chemicax compounds  and  con-
    taminated soil  from Lipari Landfill and surrounding areas.

 C. That Complete Removal and On-site  Storage  is a  feasible  and  realis-
    tic alternative and should be  considered.

 D. That EPA hire an independent environmental  consultant to assist
    the community  in the evaluation of data and  in  the selection of
    alternative  solutions to  the Lipari Landfill  and Alcyon  Lake problet
     (As done  in  S$ringfellow  Acid  Pits and  Love  Canal)

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                                    nspector-  to  oversee
                              ^                                 .in.
                   ^,::r^
problem and  feel  It  is-Inpor'tanV^^-nre-^par^^
rsk-ing process  concerKinp" the ~:.pari Landfill  and Alcyon Lake clean-
•;-.  Vurt't-ernore,  LIpari":jandfilI/Alcyon Lake  is  the number one toxic
v/aste s.lte and  the rest  of the country will  be watching and wait ing
for its successful courierion.  "et's work together to make Pitman
e safe -ols.ee to live 9rain.
                                  Sincerely,

                                  Pitman Lipari landfil
                                  Tor.munity Associate on
                                          .•••Cl
-------
                                          Douglas Stuart
                                          205 Lakeside Avenue
                                          Pitman, H.J. 08071

                                          August 19,  1985


Mr. Robert Hyde
Project Officer
Camp Dreeser & McKee
EPA's Consultanta

Sear Mr. Hyde:

At  the August  15th Public Meeting concerning the Lipari landfill
Site, soil test results of Betty Park indicated that there was no
harmful risk to human health.  However, the tests did not reveal
any data concerning bia(2-ohloroethyl)ether which is a known car-
cinogen and has been predicted by  your   recent report to occur in
Alcyon Lake at concentrations that exceed its criterion  for  human
health.  The question as to  the absence of bis(2-chloroethyl)ether
was explained  as  followsi

      1. The chemical had not registered any  amounts, therefore, it
        was not mentioned  in the  findings.
                             OR
      2.  The  soil  was never tested for bis(2-ohloroethyl)ether.

 Obviously, the latter of these explanations  raised serious  questions
 and concerns,  which you must share,  since you stated that you planned
 to investigate this matter.  Would you please send us the following:
 the type of tests taken, the chemicals tested,  test results and any
 other data that could alleviate our concern.  Since this is a serious
 issue, a quick response would be appreciated.

 This letter is not tofceonatruted as a comment  to the EPA presentation
 on alternatives  to the Lapari Landfill problem, as that will follow
 in more detail.
                                           Sincerely,
                                           Douglas Stuart
                                           President of Pitman Lipari
                                           Landfill Community Associatio
  cot Mayor Hannum
      Pitman Environmental Commission

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Mr. Edward Campbell, Chairman
Pitrcan Environmental Commission
Pitman Borough Hall
Dear Mr. Campbell:

I  would  like  to  take this opportunity to thank you and the
Pitman Environmental Commission  for your attention and
contribution  to  the Environmental Protection Aoency's (EPA)
.'Vr**Wi!t«l!t»n- •^s^M^nam^l Wl "•&tttBtM3 V!-- 'tiwesftl^glat 1 on  and
TvatfWfVny Ttudy for the Tiparl aandTYTI  at the January 23.
19R3  Public  Meeting.

As promised  at  the  Public Meeting,  I  have  enclosed  an Inventory
of all  reports  concerning the Lipari  Landfill  that  are  in  EPA's
oossession.   I  have also enclosed  copies  of  those  documents
 that  were  readily  available.   This  office  1s currently  in  the
 process  of photo copying the  remaining  reports for  which  there
                                                     you «s -soon
 In discussing those reports which are on repository with
 Mr. Robert Dixon of the Gloucester County Planning Department,
 I did not wish to imply that he had all existing reports.
 Recently, few reports were sent to him, since few have been
 generated.  As you can see by the enclosed Inventory, few
 reports were completed since 1982.  The type of activities
 undertaken at the site over the last two years - mainly design
 and construction of the leachate containment system - does
 not generically generate reports.
                                        ;^*T?forjnejd fey 3ft B
 "Associates has  been the only other supplemental  activity  that
  was  Initiated  and  1s  currently  being  undertaken at the Lipari
  Landfill  as  part of a research  effort  by  EPA's  Office of
  Research  and Development.   While  some data  has  been  produced
  by this  activity,  a report  has  not been compiled.  When  this
  effort results 1n  a report, we  will make  it available  to your
  Commission.   In the Interim we  are enclosing some  of the
  preliminary  data from this  effort.

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                              -2-


P.eports that will  be available 1n  the  near  future  are  shown
below with the estimated date of completion:

  •- Remedial Investigation Report  (On-Slte) - Hay  1985

  • Remedial .Feasibility Study (On-Slte)  -  August  1985

  • Remedial Investigation Report (Off-Site) - October 1985

  - Remedial Feasibility Study (Off-Site) - December 1985

This office  will forward to  your Commission these Phase II
reports as  they are completed.

I hope that  the Pitman  Environmental Commission will find
these  reports  useful  1n  Its  evaluation of  the circumstances
and  actions  taken  at  the Upari Landfill.  As always, should
you  or any  memb.er  of  the Pitman Environmental Commission wish
any  additional  Information  concerning the  L1par1  Landfill,
please contact  Hr.  Ronald  BorselUno of  my staff  at (212)
264-1913.

As  also  discussed  at  the Public Meeting, you had  Indicated
that the  Pitman Environmental Committee  will undertake  a
 survey of private  wells that may  still exist 1n the area and
 which  apparently are  used for lawn Irrigation.   I would like
 to thank  the Committee for their  future  efforts  1n this matter;
 and I  would request that the Committee  send the  Information
 to this  office when 1t 1s compiled.

 Your continued concern and Input concerning the  L1par1  Landfill,
 1s very much appreciated^

 Sincerely yours.
 Salvatore Badalamentl, Chief
 Southern New Jersey Remedial Action Section
 New Jersey Remedial Action Bcanch

 cc:   Robert Dixon
       Michael Hammum, Mayor

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                                                                 € s-
                  ft Gfossroots Environmental Crisis Center
                                            August 30.  1985
Mr. Douglas Stuart
President
Pitnan-Upari Landfill
   Community Association
205 Lakeside Avenue
Pitman, NJ  08071
     I have completed my review of the "Final Draft Report, On-Site
Feasibility Study for Lipari Landfill" prepared by Camp Dresser and McKee,
Inc. (COM) for the U.S. Environmental Protection Agency (EPA), August 1985.
This review was initiated at your request on behalf of the Pitman Lipari
Landfill Community Association (PLLCA).  These comments are offered to assist
the residents of Pitman to better understand the proposed cleanup optioi
to provide a basis for the community to better articulate their concernl
about the risks posed by the landfill and the different cleanup options.*

     The Final Draft Report, On-Site Feasibility Study (FS Report) for Lipari
LaiuiiiU i» |irepared to^                        EPA investigation of a
Super fund site. "Thl^ rieport ^Micbmpasaes bota the Remedial U*^
of the site as well as the Feasibility Study (FS).  In the past, t*»«« study
areas have been prepared and reported in separate documents.  The RI phase is
intended to establish the extent of the contamination caused  by the site
under investigation.  Normally a substantial amount of new data is generated
and reported in the RI report.  The FS then evaluates and recommends options
for cleaning up the site problems defined  in the RI phase.
           report «^                               primarily because
 significant 'pbrtlo«B-'1«**Bi^4iQim^
 Typical information not included in this report include:

      1. Well logs and boring descriptions.  This Information describes
         well depths, well construction, water levels, soil charac-
         teristics, and well locations and is critical to understanding
         tli* direction and rate of groundwater flow.
                   POST OfHC€ BOX 986. flRUNC • TON. VWGIHW 2*216
                                 (703) €96-7070

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Huge 2
Mr. Douglas Stuart
August 30, I9ti5
    • 2. Sampling procedures for leachate,  groundwater,  surface water
        and soil samples.  How was the sample taken?  Were  proper
        collection, storage and transport  methods used?  Were field
        samples filtered?

     3. Analytical procedures. What methods and test  procedures  were
        used to determine the amount of different chemicals present
        in a sample?  What were the detection limits?  What chemicals
        were tested for?  Were the same procedures used for each
        sample (from the same medium)?  What quality  assurance/
        quality control (QA/QC) procedures were followed?  There is
        no mention of QA/QC procedures at all in the  report. This
        is an important point that needs to be addressed.

     4. Results from samples, i.e. raw data.  Only summary data ia
        provided (see tables 1-1, 1-3, 2-4 as examples).  Acyual test
        results showing what was found in each sample ia not provided.

     Other relevant data not included:

     • Results from private drinking  water wells

     • Results of  sampling air  from gas vents

     • Soil  testing results

     Hurt most by  this  lack of  information is  the public and others
 interested in the  cleanup  of  the  Lipari Landfill. Without actual raw data
 and supporting documentation  (such as well logs), the  reader is asked to
 accept the arguments  and assumptions  presented without question.  Further, an
 Independent  assessment  of  the collected data and its significance cannot be
 conducted without  the raw  data and supporting documentation. This situation
 is untenable and is not conducive to  involving the public in decisions being
 made at the  site.

 RECOMMENDED CLEANUP OPTIONS

      The FS Report evaluates 29 variations of seven (7) options and
 recommends three for further consideration.  These are:

      1. No action but pump Kirkwood sands;

      2. Dewater area within existing slurry wall and pump Kirkwood sands;

      3. Dewater and then flush area within existing slurry wall and pump
         Kirkwood sands.

      The advantages and disadvantages of  these options are described  in the
 report with regard to technical feasibility (Table 4-10,  pps.  4-45-55),
 environmental health (Table 4-17. p. 4-94) and  institutional problems (Table

-------
Fage "J
>lr. Do
August 30, 1985
4-19, -p.
to these comments
.attaciJ^^F
     When reviewing these tables together, little confidence can be felt that
any of the recommended options will work for any length of time. Each suffers
from significant limitations; each depends on continous long-term monitoring
and maintenance; and each will likely result in the need for further cleanup
some time ia the future.  Each option is separately evaluated below.
                                                 .
     This option leaves existing contaminants in place and addresses only
downward migration into the Kirkwood sands, generally considered to be 40-50
feet below the surface.  Currently contaminants are entering the Kirkwood
sands at an estimated rate of 1750 gallons per day (FS Report, p. viii).
Since some local residents obtain drinking water from these sands and since
waters from this region discharge into Chestnut Branch and/or Alcyon Lake,
contmmlaatlon In ttese «anda mat to cleared up.

     The proposed cleanup approach would tackle this problem not by removing
the source of contaminants (the upper Cohansey soils) but  rather by removing
contaminants which have migrated away from the source.   In this way, the
source continues to generate leachate and treatment is needed until all the
contaminants have migrated from the source to the  point  of cleanup (or
perhaps somewhere else causing other problems).  This option  is an
inefficient and ineffective means of cleaning up the site. It makes nc
to ignore contaminants in the upper Cohansey and address only those
have  migrated into the Kirkwood sands.
                          taint ies with this option:
      • reliance on success of the slurry wall to contain
        at the source

      • changing hydraulic head (water pressure) altering the degree of
        downward migration

      • changes in lateral water movement (i.e. out of containment area)
                  fgg4t^-..ftf .downward migration
      • some chemicals won't migrate with waste and thus will nrBmaln 'In
        place indefinitely

      • not all contaminants will be captured and removed

      • no experience with this technique for cleaning up  hazardous
         time  required  for "cleanup"  is at best an estimate relying on
         everything going as  planned

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Page 4
Mr. Douglas Stuart
August 30, 1985
     Given these limitations and uncertainties,  this option is not acceptable
as a remedial option for Lipari Landfill.

     OPTION A - DEWATER THE ENCAPSULATION  AND PUMP THE KIRKWQOD SANDS.

     In this option, the water level in the area contained by the alurry vail
is lowered to below where wastes are present in soil and the  Kirkvood sands
are pumped to remove water soluble chemicals which have migrated  from the
original point of disposal.  In theory, by lowering the water table,  the
wastes become isolated and immobile because they do not come  into contact
with water.

     The success of this option is highly dependent  on fIrat knowing where
the wastes are located, then being able to lower water levels to below the
wastes and most importantly, on maintaining the water level below the wastes
indefinitely.  If for any reason the water table rises, at any time, then
wastes will become mobile again causing the contamination to once again
migrate away from the site.

     It is highly unlikely  that dewatering can be maintained indefinitely.
The cap will eventually fail allowing water to enter  from the surface; pumps
will fail allowing water to rise from below and already the alurry wall has
failed allowing water to enter from the site  of the "encapsulated" area.
Even if dewatering is able  to  work  in the short term,  the above  failure
mechanisms will come into play before long mobilizing wastes and requiring
additional cleanup.  Further,  this  technique  has  not  been used to cleanup at
waste sites that I am aware of. Consequently,  ita success remains to be
seen.

     OPTION 6  - FLUSH THE "ENCAPSULATION" AND PUMP THE EIRKWOOD  SANDS.

     In  this option, the upper Cohansey would be dewatered aa described in
Option 4,  then "clean"  water would be flushed through the contaminated soil
to remove water  soluble contaminants until levels of  these contaminants fal
below a  selected cleanup level.  In addition, the Kirkwood sands would be
pumped as described in Option 2.

     This option is the most complicated and difficult to carry out of Atom
 recommended options.  It relies on the ability to withdraw contaminants&t»
 soil by  continuous flushing.  To be successful, all the soil in the
 "encapsulated" area must be flushed.  It is unlikely this can be achieve**.
 thus at beat,  only partial removal of those water soluble chemicals will it
 achieved.  The rest of the wastes, those not moving in the water mad thomc
 not effectively flushed, will remain.

      The authors of the FS Report, clearly do not have much faith An tttta
 option.   They describe this technique as "unproven"  and "not completely
 effective" citing numerous limitations (see  pp. 3-65 to 76 of the IS Repo:
 including:

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 Page 5
••"Mr.  'Douglas
 August  30, 19«5
      • Stagnant area s of low f low where '•water and contaminant s wi 1 1
      • Short  circuiting caused by inconsistencies in soil makeup
        (p.  3-65)

      • Clogging and maintenance of pump/injection system (p. 3-65)

      • Q««cLc«l» not solufele la water will T^amin 
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Page b
Mr. Douylas Stuart
August 30, 1985
CLEANUP OPTIONS NOT CONSIDERED.

     In considering cleanup options,  COM listed 29 variations  of 7 options
including 7 discharge options for leachate,  1 for air,  5 for sludge and  3 for
soil; 12 treatment options for collected leachate; and  1 inplace treatment
option.  Each of these options were evaluated and screened for established
criteria (see pp. 3-42 to 3-44).  Of these options, only two,  both employing
wet air oxidation, are conisered innovative technologies that  could
permanently destroy or detoxify the wastes.
                                                           •
     The Congressional Office of Technology Assessment (OTA)   listed  26
cleanup options,  currently available which can achieve permanent destruction
or detoxification of wastes.  There is no discussion at all as to why these
(or similar) options were not considered in the FS Report.  OTA also
carefully evaluated existing technologies and came to the conclusion that
containment technologies such as encapsulation and groundwater pumping are
ineffective and  inadequate.  The effectiveness of a cleanup project should be
measured by the  ability to destroy, detoxify or  permanently immobilize wastes
and to decontaminate soil and groundwater.  None of the recommended options
achieve this goal.

   *  Superfund  Strategies, Office of Technology Assessment (OTA) - ITE -
253, Vashington, DC, April,  1985.

NEW OPTION  FOR CONSIDERATION.

     Another  option that  warrants consideration is one that encompasses
elements  of several options and ideas  already discussed.  This option is a
Removal and Storage alternative which  combines partial removal of inplace
waste,  collection and  treatment of contaminated groundwater and  on-aite
storage of excavated wastes.  Groundwater isolation,  collection  and  treatment
could be achieved using some of the same alternatives already considered in
 the FS Report.

      The major differences in this alternative (from option 1) is that some
 inplace wastes would be excavated and removed from the site (as opposed to
 complete removal), and rather than redisposal at another aite, the wastes
 would then be temporarily stored on-site.  Storage could be achieved in an
 above-ground cement structure which could be easily monitored and controlled.
 Once available  treatment technologies for permanently  destroying wastes
 become more cost effective, wastes could be removed from storage and treated.
 Similar storage techniques have been utilized at Times Beach, MO, and are
 under consideration at Love Canal in Niagara Falls, NY.

      The removal and storage option offers  the  following advantages:

      1. Removes some wastes from the ground thus reducing time needed
         'to treat and collect contaminated groundwater by reducing the
         source  of  the  contamination.

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Page 7
Mr. "Douglas 'Stuart
August 30, 1985
                                                          --while • not
        simply tranfering risks to another community or tahlfill istte.

     3. Above ground storage can be easily monitored and controlled.

     A. Provides a means (in the future) of permanently destroying or
        detoxifying wastes.
               «I»I»A ^Mvy^jim^rim^ ^                          tech-
        nologies to make them more effective and efficient.

     The biggest drawback of this alternative is the short-term risks posed
during excavation.  These risks ar real but can be minimized and controlled
with proper care and planning.

     Clearly this alternative is not fully described nor evaluated in these
comments.  The intent here is to raise it for consideration as a viable
alternative for cleanup at the Lipari Landfill.

ISSUES HOT ADEQUATELY ADDRESSED BY THE FEASIBILITY STUDY REPORT

     Several important factors were not adequately addressed in the FS
Report.  Perhaps this is the result of combining the RI and FS reports into
one document.  These items are listed below:

      1.  Influence of contamination off-site on  remedial work conduct
         Non-siteM.  Remedial efforts necessary  to cleanup  off-site
         contamination may influence steps  taken to address on-site
         contamination.

                    .ti>«v»»rrff«av^^^hg.«xiatiag cap or coyar^and  the
         slurry wall to contain or "encapsulate" wastes within the
         slurry wall.  Cost estimates and time needed to achieve clean-
         up levels are based on success of the containment system.
         Already the slurry wall/containment system has failed raising
         severe doubts about the costs and time estimates in the report.

      3. Lack of background and supporting data, especially quality
                               wcoatrol ...fBocaduMS .(Jee Above) .
      4. Dependence on modelling to predict success of different options *
         and time necessary to achieve cleanup levels.  Many assumptions
         are necessarily made in order to effectively use models as a
         predictive tool.  However, many of the assumptions may not be
         accurate or hold with time.  For example, estimates of time
         to dewater the encapsulated area are bused on no flow through
             "
         assumptoins made and the data used to verify  them.

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Paye 8
Mr. Douglas Stuart
August 30, 1985
     5. Lack of data on how much of the inplace wastes will mobilize
        with water and on interactions between soil and generated leachate.

     6. Estimates of costs and time to cleanup are based on everything
        going as planned.  Failure of the cover (cap), slurry wall or
        pumps are not addressed.

     7. None of the techniques proposed in the 3 recommended options have
        been proven successful as to cleanup hazardous waste sites.

 SUMMARY COMMENTS AND CONCLUSIONS.

     In summary, the following observations and conclusions can be  drawn:

     1. It is  not  in the best interest of  the  community  to combine  RI  .
        and FS Reports.   Too much important data  is omitted.

     2. The recommended  options  provide little confidence  that they
        will work  for  any length of time.  Each suffers from critical
         limitations and  inadequacies.

      3.  Each of the recommended options requires  long-term maintenance
         and monitoring,  ranging from 15-70 years. In addition,  those
         wastes not mobile in water will remain forever requiring
         indefinitely monitoring.

      A. Insufficient consideration was given to cleanup methods which
         permanently destroy, detoxify or immobilize wastes. Additional
         options, such as those suggested by OTA need to be considered.

      5. None of the recommended options have  been  proven successful
         as long-term cleanup methods  at hazardous  waste sites.

      6. The report is biased against  complete removal of wastes  (option 1).

  RECOMMENDATIONS.

      Based on my  review of the  Fianl Draft FS Report,  I propose the followln
  recommendations for your consideration:

       1.  That  all  relevant background and  supporting data  and all raw
          data  results  be obtained for all  samples collected as.part of
          the investigation of the contamination at Liparl  Landfill.

       2.  That the feasibility of other alternatives be considered for
          cleanup of Lipari. In particular that the 26 options
          evaluated by OTA be considered.

       3. that partial removal and on-site storage  be considered in
          conjunction with dewatering  and pumping of the underlying soils.

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  . flouglas Stuart
August 30, 1985
     €?*ope^?«Aiese^«MW»ehelpf.ul^   If .jou have any questions or  ^
                 '   '  "   '              please do not hesitate to contact

                                             Sincerely,
                                             Stephen U. Lester
                                                     BtTBCtor
 SUL/gfi


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I
                                    TABLE  4-10

                        TECHNICAL ADVANTAGES/DISADVANTAGES
                      OF THE CANDIDATE REMEDIAL ALTERNATIVES
i
i
I
k
i
 I
 I
 I
   j
 I
  I
 I
Remedial
Alternative
Advantages
Disadvantages
1-Complete Removal
o Most reliable 1n removing
  source materials
                           and
o Most dangerous to health
  safety of onslte workers
o Very difficult to Implement
2-No Action but
 Pump the Klrkwood
 (Enhanced Contain-
 ment)
o Contains Klrkwood Seepage
o Easily Implemented
o High level of onslte worker
  safety
o Has high driving head
  forcing contamination Into
  Klrkwood Sands
o Leaves large portion of
  water transport contamina-
  tion In place
o Hydraulic  gradient  Is out of
  the containment
o May allows "source" to
  continue to generate
  leachate
o Chance  for wall degradation
o Some portion of water trans-
  portable contamination
  remains within encapsulation
  both  1n  landfllled  and  non-
  landfllled areas
 3-Dewater the Encap-
   capsulation (En-
   hanced Contain-
   ment)
 o Removes portion of water
   transport contamination

 o Decreases driving head
   Into Klrkwood Sand
 o Induces hydraulic gradient
   Into the containment
 o Leaves "source" materials
   above the water table
 o Decreases potential for
   wall degradation
 o Easily Implemented
 o High level of onslte
   worker safety
 o Doesn't have provisions for
   capturing seepage Into the
   Klrkwood Sands resulting In
   continued migration of con-
   taminants Into offslte areas
 o Some portion of water trans-
   portable contamination re-
   mains within encapsulation
   both In landfllled and non-
   landfllled areas
  I
                                                   4-54

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I
  i
 1
  I
4
  I
  I

  I
  «
'^•IP
  ft
1
               the Kirkwood (En-
               hanced Contain-
               ment)
so -Most -.effective ..alter -
  ratlve in achieving
  Enhanced Containment in
  both  Cohansey and Kirk-
  wood  Sands
 o Romoves portion of water
                                      Into Kirkwood Sand
                                    o Induces hydraulic gradient
                                      Into the containment
                                    o Leaves "source" materials
                                      above the water table
                                    o Decreases potential for
                                           .degradation
                                             Implemented
                                    o High level of onsite
                                      worker safety
 Pumping of the Kirkwood,
 Sands will be required over
 a longer period of time than
 the Cleanup alternatives
i Some portion of water tr
 portable contamination r
 mains within encapsulate
 both in Vandf111ed and
 landflTled areas
              5-F1ush the Encap-
                sulation (Cleanup)
 o If successful, will clean o Flushing  1s  an unproven
   up water transportable      technology
   contamination faster  and  o Doesn't have provisions  for
   more thoroughly than        capturing seepage Into the
                                       Alternatives
                                Injection
                              o Cannot measure degree of
                                effectiveness of flushing
                              o potential for short-circuiting
                              o cannot flush contaminant
                                adsorbed onto soil  part
                                which at some future
                                become water transportabl
                                to a change in the soil micro-
                                environment
              6-Flush the Encap-
                sulation and Pump
                the  Kirkwood
                (Cleanup)
  o Captures seepage Into the
    Kirkwood
  o If sucessful, will clean-
    up water transportable
    contamination faster and
    more thoroughly than
    either the No Action or
o Flushing  1s  an  unproven  tech-
  nology
o O&M  difficulties  with  re-
  Injection
o Cannot  measure  degree  of  .
  effectiveness of  flushing
o Cannot  flush contaminants
            oato S014 4«rt4;cJss
            so«e future time ma
  become  water transportable
  due  to  a change in  the soil
  micro-environment
               7-No Action
  o Safest of all  alter-
 o Does not contain, cleanup,
                                                                   : iSeepage wi^l A continue into
                                                                    Cohansey and Kirkwood
                                                                    formations
                                                                                      * t> % .-v /-"_•: •'•'•
                                                                                      •' -;• •;;; > ^••jv^-n ^i->,

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                               TAB LE

       SUMMARY OP  THT RESULTS OP THE PU3LIC HEALTH EVALUATIONS
                              Unacceptable because of technology
                              inadequacies related to:
Alternate
la
Ib
1C
Id
2a
2b
2c
2d
3a
3b
3c
3d
4a
4b
4c
4d
5a
Sb
5c
5d
5e
5f
6a
6b
6c
6d
6e
6f
7
Acceptable Collection




X
X
X
X
X
X
X
X

OR


X
X
X
X
X
X
X
X
X
X
X
X
X
•Treatment Disposal
L,E
E
E X
E X
L

X .
X
L

X
X
L

X
X



X
X


t

X
X


   X »  Excessive discharge of bis-(2-chloroethyl)ether to surface
       waters
   L •  High number of truck accidents due to off-site transport
       of liquids
   E •  High number of truck accidents due to off-site transport
       of soil
   OK • No significant inadequacies.
COM
                                               SUMMARY OF THE RESULTS OF THE

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                                 TABLE '.4-1.9

                   INSTITUTIONAL AOVANTAUES/DISADVANTAGES
                   OF THE CANDIDATE REMEDIAL ALTERNATIVES
Remedial
                     Advantages
                             Disadvantages
Complete Removal
(Alternative 1)
o Probably most acceptable
  alternative In the public
  eye
                            o Permits needed for offsite
                              disposal of untreated/pre-
                              treated leachate
                            o Permits needed to haul con-
                              taminated soil to offslte
                              areas
                            o Air permits may be needed to
                              50perat« orrel te pretr^atment
                              -facility
                            o A1r permits may be needed
                              for exhaust from  any  onslte
                              enclosure used during
                              excavation
 Enhanced
 Containment
 (Alternatives  2,  3,  4)
                             o May meet with skepticism
                               from public  as to whether
                               the hazardous materials
                               could  be contained.
                               Alternative  does not  seek  to
                               actively cleanup the  site
                                                                 mtre^tetlfpre-
                                                     treated leachate
                                                   o A1r permits may be needed to
                                                     operate onslte pretreatment
                                                     facility _
 Cleanup
 (Alternatives 5,6)
o Probably acceptable to
  public since 1t demo-
                              o Permits needed for offslte
                                disposal  of untreated/pre-
                        contamination at the site
                              o permits may be needed for
                                underground Injection
                              o Air permits may be needed to
                                operate onslte pretreatment
                                facility _
  (Alternative 7)
                                                      to
                                                     oublic

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                                                          Attachment D
                      LIPAR!
                    LANDFILL
                   •LANDFILL ACCESS »OAD


                       GENERAL PLAN
CDM
        FIGURE 1-4

FENCE  INSTALLATION
environment*/ engineers, scwnnsrs.
jianngry & m»n»g»m*nt consultants

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                                   -  ' ^Attachment E
Mr. Douglas  Stuart
205 Lakeside Avenue
Pitman, New  Jersey   08071

Dear l»r. Stuart i

This  is in response  to your  letter  of  August 19,  1985 to Mr.
Robert Hyde  of Camp, Dresser and Mckee (CDM), concerning the
analysis performed for samples  taken at Betty Park.
Soil  samples were  collected in six locations in Betty Park on
March 1,  1985.  The  samples were obtained with a hand-held
tttXw^
Ttach ^«e  1^ ^cctJT^arice ^i^th ^iyAayroc%du^t^«^»fal^h^«% ^outlined
in  the approved Project Operations Plan for this site.  Two
samples were collected from each of the six locations, and
at  an interval  from  the ground surface to a depth of €-inches,
and at an interval from 6- inches to 18-inches.  The' sample
locations can generally be described ass

   •seven  feet off  the fenceline running parallel to Lake Avenue
    approximately  100 feet from Cedar Avenue.

   *In area of monkey bars, west of swings* 104 feet off fenceline
    running parallel  to Lake Avenue.
   * Approximately *T0D T «*t ^Trow^grewn fcui W ing •
    half of the park.  Approximately 4 feet from the shoreline.

   'Approximately 6 feet from shoreline midway in the park.

   •Approximately 50 feet from the shoreline, 35 feet north of
    the green building in the northern portion of tht park.
    Avenue.

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                              -2-
Each sample was analysed for a fall priority pollutant scan
incorporating the following sample fractions! acids, base/
neutrals, volatilesr pesticides* and polychlorinated biphenols
(PCB).  As concerns bis (2-chloroethyl) ether, this compound
was tested for in each and every sample.  In each instance the
analytical laboratory indicated that this compound was not
detected*

Sincerly yours.
Ronald J. Borsellino,, ,P,.B.
Southern Mew Jersey Remedial Action Section

cct  Pitman Environmental Commission
     Robert Ryde, COM

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                                                ..^Attachment F

                 PITMAN ENVIRONMENTAL COMMISSION


                                                       -JDBD71
                                      September 6, 1985
Mr. Christopher Daggett
Environmental Protection Agency
       II AdmiJii str ator
New.Yoric, NY   10278
Dear Mr. Daggett:
Be informed that the Pitman Environmental Commission, at
its September 5, 1985 regular meeting, voted to recommend
that the Boro Council and the Environmental. Commission
employ an outside consultant to review and evaluate the
Alcyon/Lipari EPA report that was presented by the EPA in
        'Cfaambcgs *on JUiqust X, « ,19.8 5..
The consultant vill make recommendations to council aha "the
commission with regard to the procedures used  in the study
as well  as to the corrective options presented and to offer
alternatives not presented  in the  report.

The consultant fees for the services are to be born by the
EPA.
"ice
      Mayor Hannum
      Council Members
      Commission Members
                                   Sincerely,
                                        s  Miller,  Chairman
                                                S?y

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    •     -..MTEC STATES ENVIRONMENTAL PROTECTION AGENCY

                           _•' (" C. ~ E ~< •'•> - r-'wA^A
	 _, .__,.           NEW V~QK SEW V-,-PX  lOZ^S
6L   -< 7 1985


Mr. Thomas Miller, Chairman
Pitman Environmental Commission
6 North Broadway
Pitman, New Jersey  08071

Dear Mr. Miller:

I would like to take this opportunity to thank you and the entire
Pitman Environmental Commission for the assistance and attention
afforded the representatives of the Environmental Protection
Agency (EPA) at the public meeting held on August 15, 1985.  I
would also like to respond to the proposal made in your letter of
September 15, 1985 to Christopher Daggett, Regional Administrator,
that the Borough of Pitman hire an outside consultant to  review and
evaluate the On-site Feasibility Report (FS)  for the Lipari Landfill
presented at the August  15tn meeting.

EPA encourages communities to become involved in the development
of alternatives and to express their opinions concerning  the
selection of recommended alternatives of remedial actions at
Superfund sites.  As EPA involves all communities affected by
Superfund sites, EPA has given the community  surrounding  the
Lipari Landfill the opportunity to input into the development
and selection process for  past and ongoing remedial actions.
Within the past year, two  public meetings were held to  inform
the community of EPA's  progress at Lipari and to address  the
public's comments.  After  the last public meeting, EPA  extended
the public comment period  for the draft On-site Feasibility
Study  over 3 weeks to give the community more time to respond.
Upon  request, EPA also  sent  a copy of the FS  to the Citizen's
Clearinghouse for Hazardous  Waste, Inc. Response to the
comments developed from the  Clearinghouse's review is being
prepared.  The Regional  Administrator will presently be making
a decision to implement a  recommended alternative for the
second phase on-site remedial action at the Lipari Landfill.
This  decision will be made considering  all the comments received
to date.                    .

As a  matter of policy,  EPA does not  finance reviews of  studies
that  were prepared for  and funded  by EPA.  Remedial  Investigation/
Feasibility Studies go  through several  reviews to ensure  that  the
alternatives considered protect public  health and the environment
and are  consistant with the  Comprehensive Environmental Response,
Compensation, and Liability  Act  (CERCLA), and other  relevant       ;
environmental laws.  Therefore,  it is  EPA's position that
another  review  is unnecessary and  counter-productive.

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                                -2-
 -Jn addition,, my staff  is  always ready to meet with the Pitman
• ;iiEnvlironiaental • Commission •. and'.' other' local officials -to 'discuss
 any aspect of EPA's  response  at the Lipari^and'f111.

 Your concern for  the environment and your continued support of
 EPA's efforts at  the Lipari Landfill are appreciated.

 Sincerely yours;
   illiam J.  Librizzi,  Director
  Emergency  & Remedial  Response Division

-------