&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
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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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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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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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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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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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*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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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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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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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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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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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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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,
-------
-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**
-------
-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:
-------
(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
-------
-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.
-------
-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)
-------
-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. .
-------
-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.
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-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.
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-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
-------
i
i
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CMI ItMQBl'*1
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CMBUtB
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•itanwtlM* IB
tarat at taarca
caatral.
IBMBCB*
OMtBlBMBt
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•t tatlM altk MtaraBtlM 1.
kat *MB t*a iMt ral IBMB t*M
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all af tka tltar-
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far «lract CM-
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BBrkar*.
latar t*M Mtaraa
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•Mt BlMt. UlBtf
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IB tarat al taarca
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aolroaMBtal ara>
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cat It raam* traa
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ara>ltlaat ta caa-
tara .elatlla «(•»•
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Mat ta ttaa coa-
tlMla| HUMi
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kB.tiar, Ittat af
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•
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at ftlta «IMM*I al
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lata tkaOkMBMf
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laackBta trat t*a
la tka McMtalatKB
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aat Manual.
TABLE 8
•SUMMARY OP EVALUATION OP ALTERNATIVES
-------
kiitrMti** CMit.i '«•
i
i~Mt
•tor*
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TABLE 8
SUMMARY OP EVALUATION 0* ALTERNATIVES
(Continaed)
-------
1 f IM
• Cut Itt4w1 Toctolcrt lT»lMtlo» *wrt to
: •*•*«* *'•• IM «• "•*
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CMtrcl «r «tol>. «ilr*« •!!! k* Mirt to aMr*t*. ttw CuHtiiin M« *ltorn**l*« to MM
eft •• rwrtlM c*» •*!•> llttl* or «o ck»»tt «•« Klrlumf (Mile
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•ttlt M« tftlt toctoalMT tot ••lit »r» aajcr tot at Ml* *t nuiji IttM. •• atttlto laeMlM
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tto rvllMllltf at or aroMotlM at : MtarMtlM I.
tklt tactoalaff It ttort^lrnltlaf
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TABLE 8
SUMMARY OF EVALUATION OP ALTERNATIVES
(Continued)
-------
i
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(M
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to
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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 .
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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
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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^
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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
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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
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•'
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-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.
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-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.
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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
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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
;$
^
•.!^
''•'••»
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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.
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-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.
-------
* 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
-------
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
-------
any further contaminant migration Into the "off-site" areas via this
route. Another advantage of dewatering the Upper Cohansey with the
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-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.
-------
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
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IO4O ••U*M!.«. •KLOIUM
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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
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9
PHILADELPHIA. PA 1O1O2
TKLEX • « 6334 • BAMOBP
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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.
-------
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
-------
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
-------
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,
-------
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)
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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
-------
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)
-------
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)
-------
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
-------
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.
-------
-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
-------
€ 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
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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->,
-------
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
-------
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
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