United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-86/031
September! 986
&EPA
Superfund
Record of Decision
Lang, NJ
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TECHNICAL REPORT DATA
(Pleate read Instructions on the revene before completing!
1. REPORT NO.
EPA/ROD/R02-86/031
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Lang Property, NJ
5. REPORT DATE
September 29, 1986
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
a. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Lang Property site is a 40-acre parcel of land in a sparsely populated rural area
of Pemberton Township, Burlington County, New Jersey. The site is flat and consists of
an unpaved access road leading to a 4-acre clearing. Unauthorized disposal of hazardous
wastes appears to have occurred over a 2-acre area within the clearing. Abandoned
vehicles, tires and other debris are scattered throughout the site. The site is located
within New Jersey's Pinelands National Reserve, a forest expanse nationally recognized
as a valuable environmental resource, and is within the 100-year floodplain. In June
1975, 1200-1500 drums of unidentified chemical waste were discovered in a clearing at
the end of the unpaved road. In 1976, Edward and Florence Lang, owners of the property,
were ordered by the state to remove all drums and contaminated soil. Prior to removal,
the contents of the drums were apparently spilled onto the ground or disposed of in what
has been described as "onsite lagoons". The contents of the drums appear to be the
source of contamination occurring at the site. The main contaminants of concern at the
Lang Property are VOCs and metals, which have contaminated soils, sediments, ground
water, and surface water on site.
The selected remedial action at the Lang site includes: excavation of approximately
6500 cubic yards of contaminated soils and waste material with offsite disposal at an
approved landfill; extraction and onsite treatment of contaminated ground water with
(See Attached Sheet)
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Croup
Record of Decision
Land Property, NJ
Contaminated Media: soil, gw
Key contaminants: VOCs, heavy metals
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS tTliit Report)
None
21. NO. OF PAGES
82
20. SECURITY CLASS fTliis pagei
None
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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EPA/ROD/R02-86/031
Lang Property, NJ
16. ABSTRACT (continued)
reinjection of treated water into the aquifer; restoration of the excavated
area by filling and grading, including removal of surface debris as
necessary; installation of a security fence; and monitoring to ensure remedy
effectiveness. Estimated capital costs for the remedy are 32,322,000 with
annual OS.M costs of $612,000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site Lang Property, Pemberton Township, New Jersey
Documents Reviewed
I am basing my decision on the following documents, which
describe the analysis of remedial alternatives considered"for
the Lang Property site:
- Remedial Investigation Report, prepared by C.C. Johnson &
Associates, August 1986
- Feasibility Study Report, prepared by C.C. Johnson & Associates,
August 1986
- Responsiveness Summary, September 1986
- Staff summaries and recommendations
Description of Selected Remedy
- Excavation of approximately 6500 cubic yards of contaminated
soils and waste materials and disposal at an approved off-
site landfill facility.
- Extraction and on-site treatment of contaminated groundwater,
with reinjection of treated water.
- Restoration of the excavated area by filling and grading,
including the removal of surface debris as necessary.
- Installation of a security fence to restrict site access.
- Appropriate environmental monitoring to ensure the effective-
ness of the remedial action.
Declarations
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the alternative described
above is a permanent remedy that will remove the source of
contamination and mitigate any environmental impacts associated
with the Lang Property site.
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-2-
I have further determined that implementation of this remedial
action is the lowest cost alternative that is both technolog-
ically feasible and reliable. It effectively mitigates and
minimizes damages to and provides adequate protection of public
health, welfare and the environment. At the same time, it
meets all applicable and relevant Federal and State public
health and environmental requirements. Further/ implementation
of the selected remedy is appropriate when balanced against the
availability of Trust Fund monies for use at other sites.
The State of New Jersey has been consulted and agrees with the
selected remedy.
tus,~,ffM'
Date ' Christopher
Regional Administrator
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LANG PROPERTY SITE
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
I. SITE LOCATION AND DESCRIPTION
The Lang Property Site is a 40-acre parcel of land in a sparsely
populated rural area of Pemberton Township, Burlington County, New
Jersey. Specifically, the site is just south of New Jersey Route
70 off City Line Road in close proximity to the Lebanon State
Forest. Figure 1 depicts the location of the site.
The site is flat and consists of an unpaved access road leading to
a four-acre clearing. Unauthorized disposal of hazardous wastes
appears to have occurred over a two-acre area within this clearing.
The remainder of the 40-acre parcel of land supports fields of
blueberry plants, most of which are no longer cultivated, and
forested areas. Areas of active crop cultivation and nearby dwell-
ings are shown in Figure 2.
There are no permanent residences on the property. A hunting and
fishing lodge located near the disposal area was destroyed by fire
in the late 1970's, leaving only the foundation. Abandoned vehicles,
a large number of tires, and other debris are scattered throughout
the site.
II. ENVIRONMENTAL SETTING
This location is within New Jersey's Pinelands National Reserve,
a forest expanse which has been recognized as one of the nation's
valuable environmental resources. Specifically, the site is
located within the Central Pine Barrens Water Quality Critical
Area and the Pinelands Preservation Area District.
Surface geology is dominated by the Cohansey Sand Formation, which
was identified to a depth of 70 feet at the site. Regionally, the
thickness of the Cohansey varies from 0-300 feet and is underlain
by the Kirkwood Formation. At this site, the Cohansey and the
Kirkwood Formations are not separated by an impermeable layer
which would restrict groundwater movement. Ground water at the
disposal area is within the 100-year floodplain as identified by
the U.S. Department of Housing and Urban Development. The site is
drained by a series of man-made drainage ditches, located north
and east of the clearing, which flow through wetlands before event-
ually reaching Rancocas Creek.
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M vurPfWs
\K4W*yj j«&
—..-t *v,»jf n r !»•£••• r"Y*i>
^^f^Myf^^
i-->-%W. c P( y;^^25"^
^v i ^>A.Si%rf£:A.-^R^
FIGURE I
LOCATION MAP
LANG PROPERTY SITE
£^T ...CITY 'LIME Ror».
.•• i—«>-/
• fee
APPROXIMATE SCALE' l" • 200O*
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liMl«V^i^P%^ —rxj-—v *~ •*> *
v^«~.^
^ii
.-• ••••••• .-»•.-••*•••.
S;:>: ACTIVELY
CULTIVATED
!; AREAS
APPROX. SCALE IN MILES
LANG RI/FS
CCJ A
ACTIVELY CULTIVATED FIELDS WITHIN I MILE OF LANG
PROPERTY (INDENTIFIED FROM AERIAL PHOTOGRAPHS)
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-4-
III. SITE HISTORY
Portions of the 40-acre property surrounding the two-acre dis-
posal area were used for blueberry farming between 1965 and 1970.
Sever small blueberry fields are still actively cultivated on
parcels of the property that are not part of the disposal area.
Currently, the area supports no other industrial, commercial,
or residential use. The property was purchased by Edward and
Florence Lang in 1970.
In June 1975, 1200-1500 drums of unidentified chemical waste were
discovered in a clearing at the end of the unpaved road leading
to the Lang Property Site. Discovery of the site was a result
of local police officers observing a truck unloading drums at
the site. In 1976, prompted by state legal action, the Langs
hired a local contractor to remove the drums and contaminated
soils from the site. Prior to their removal, however, the con-
tents of the drums were apparently spilled onto the ground or
disposed of in what have historically been described as "on-site
lagoons". The contents of the drums appear to be the source of
the subsequent contamination occurring at the site.
From 1977 through most of 1979, repeated sampling by the Burling-
ton County Health Department and NJDEP determined that both sur-
face water and ground water at the site were contaminated. In
1980, again prompted by state legal action, the Langs hired a
geohydrological consultant to conduct a ground water investi-
gation. In 1980 and 1981, additional site inspections were
conducted by State and local authorities.
The Lang Property Site was placed on EPA's National Priorities
List (NPL) in December 1982. A Remedial Action Master Plan
(RAMP) was completed in 1984. The Remedial Investigation/Feas-
ibility Study (RI/FS) was initiated in May 1985 and completed
with the release of the Draft RI/FS report in August 1986.
IV. ENFORCEMENT
In September 1975, NJDEP filed a complaint (Superior Court of
New Jersey Chancery Division, Burlington County No. c-95-75)
against the owners of the site and a hauler who allegedly dis-
posed of drums at the site. The site owners were required to
remove chemical wastes, containers, and contaminated soils and
water from the site. Disposal of these materials was to be at
a site registered with NJDEP and approved to dispose of such
material. This was to be completed within 90 days after the
judgment. In January 1980, a Consent Order was entered into
between NJDEP and the site owners which required the owners to
undertake an investigation to determine the nature and extent of
ground water contamination resulting from disposal of chemical
wastes at the site.
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-5-
In February 1985, EPA sent information request letters to the
site owners and a number of other entities which appeared to be
linked to the hazardous substances and other contaminants which
have been detected at the site. The agency will continue its
investigations aimed at identifying potentially responsible
parties (PRP's) for the site.
To date, neither the site owners nor any other PRP's linked to
the site have indicated that they would perform the remed.ial
actions needed at the site. ;
V. CURRENT SITE STATUS
The RI/FS initiated in May 1985 included investigations of ground
water, surface water, sediment, soils, vegetation and air. The
conclusions of the RI are as follows:
1. Surficial soils (0-2 feet deep) in a two-acre portion of the
fouracre clearing where disposal took place are contaminated
with volatile organic compounds and metals. Vertical contam-
ination of soils in those areas of the site known to contain
hazardous substances was limited to a depth of twenty feet.
2. Surface water and sediment samples collected from areas of
ponded water within the disposal area were contaminated with
volatile organics and metals, as were samples collected from
a location along the ditch draining the site. This ditch
was in a position to receive surface water draining from
the on-site disposal area.
3. Shallow ground water beneath the disposal area is contami-
nated with volatile organic compounds and metals. Contami-
nants have migrated approximately 300 to 500 feet from the
disposal area, principally to the northwest. Ground water
below a depth of 30 feet shows no signs of contamination.
4. Based on a review of site conditions, toxicological informa-
tion concerning plant uptake of chemical contaminants, and
sampling of blueberries near the site, there is no evidence
of contamination of nearby vegetation attributable to the
Lang Property site.
5. No evidence of air contamination was found at the site.
6. No buried drums were found at the site.
A detailed analysis of each aspect of the RI is presented below.
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-6-
Soil Investigation
Soil sampling locations were selected based on the results of
soil screening supported by visual examination and historical
aerial photographs of the site. Volatile organic compounds were
the most commonly detected substances in soil samples. Soils
are contaminated to a much lesser degree with inorganic compounds,
notably metals. Summaries of analytical data from surficial
(0-2 feet) and subsurface soil samples (2-75 feet) are presented
in Tables 1 and 2, respectively. Major criteria in evaluating
soil contamination were the concentration of total volati.le
organics (TVO) and the number of organic compounds detected.
The horizontal extent of soil contamination encompasses approx-
imately two acres of the site and includes major areas of site
activity indicated by historical aerial photographs, as well as
by the former on-site locations of drums and waste lagoons doc-
umented in previous site inspection reports. This area of soil
contamination is depicted in Figure 3.
To determine the vertical extent of soil contamination, 49 sur-
ficial soil samples (0-2 feet) were, collected and analyzed along
with split-spoon samples from three monitoring wells. Two of
the monitoring wells (1-D, 2-D) were on-site in the area of
known contamination, while the third monitoring well was .located
off-site where contamination was not expected.
Figures 4 and 5 show TVO concentrations versus depth and indicate
soil contamination to a depth of approximately twenty feet, with
the most severe contamination in the top two feet of surficial
soils. Because the reliability of the analytical results for 2-
butanone were questionable, these data were deleted from the TVO
values. Data from analyses of inorganic compounds in split-spoon
samples, like data from soil samples, did not define the contami-
nation problem as well as data from organics analyses. As such,
a useful profile of soil contamination could not be developed
based solely on inorganics data from split-spoon samples.
Ground Water Investigation
The ground water investigation assessed the degree of existing
contamination and the direction and rate of contaminant migration.
A total of nineteen monitoring wells were installed at the site.
In addition, polyvinyl chloride (PVC) well points were utilized
to determine on-site groundwater elevations and to assist in the
determination of monitoring well locations. The results of this
investigation revealed that the ground water in the on-site dis-
posal area is contaminated with organic and, to a lesser extent,
inorganic compounds. A summary of ground water contamination is
presented in Table 3. Again, the ground water flows primarily
to the northwest (Figures 6 and 7).
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TABLE 1
SUMMARY OF SURFICIAL SOIL SAMPLE DATA
CONTAMINANT
ORGANICS
METHYLENE CHLORIDE
ACETONE
1,1-DICHLOROETHANE
1,2-DICHLOROETHANE
2-BUTANONE
1,1,1-TRICHLOROETHAflE
1,2-DICHLOROPROPANE
TRICHLOROETHENE
1,1,2-TRICHLOROETHANE
BENZENE
2-HEXANONE
TETRACHLOROETHENE
TOLUENE
CHLOROBENZENE
ETHYLBENZENE
STYRENE
TOTAL XYLENES
PHENOL
1,2-DICHLOROBENZENE
2-METHYLPHENOL
4-METHYLPHENOL
ISOPHORONE
2,4-DIMETHYLPHENOL
BENZOIC ACID
NAPHTHALENE
2-METHYLNAPHTHALENE
4-NITROPHENOL
2,4-DINITROTOLUENE
N-NITROSODIPHENYLAMINE
DI-N-BUTYLPHTHALTE
FLUORANTHENE
PYRENE
BUTYL BENZYL PHTHALATE
MAXIMUM
CONCENTRATION
DETECTED
(ug/kg)
700
1700
62
50
16000
980
55
2100
9
5
440
17000
200000
80
14000
300
23000
3600
36000
12000
1000
3600
330
3200
5200
5200
1600
3600
3600
120
330
3600
3600
NUMBER
OF TIMES
DETECTED
18
5
2
1
10
6
1
10
1
1
1
9
40
7
7
1
17
12
6
3
6
4
2
6
3
1
1
1
4
1
1
3
6
AVERAGE OF
DETECTED
CONCENTRATION
(ug/kg)
77
736
41
50
1695
322
55
763
9
5
440
3528
6980
46
3030
300
2829
1159
7027
4580
427
1315
220
2000
1953
5200
1600
3600
1538
120
330
1620
1132
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TABLE 1 (CONT.)
SUMMARY OF SURFICIAL SOIL SAMPLE DATA
CONTAMINANT
MAXIMUM
CONCENTRATION
DETECTED
(ug/kg)
NUMBER
OF TIMES
DETECTED
AVERAGE OF
DETECTED
CONCENTRATION
(ug/kg)
ORGANICS (continued)
3,3-DICHLOROBENZIDINE
BENZO (A) ANTHRACENE
CHRYSENE
DI-N-OCTYL PHTHALATE
BENZO (B) FLUORANTHENE
BENZO (K) FLUORANTHENE
BENZO (A) PYRENE
DIBENZO (A,H) ANTHRACENE
BENZO (GHI) PERYLENE
1,2-DIPHENYL HYDRAZINE
DIELDRIN
4,4-DDE
4,4-DDD
4,4-DDT
AROCHLOR 1254
INORGANICS
ALUMINUM
BARIUM
CALCIUM
CHROMIUM
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
TIN
ZINC
1000
330
330
1300
330
330
330
330
330
520
230
160
260
1300
44000
1444
73
1088
51
293
3829
506
2484
36
2.8
230
3139
1
1
1
7
1
1
1
1
1
1
32
28
29
30
1
23
1
44
5
5
37
12
3
2
16
6
28
1000
330
330
468
330
330
330
330
330
520
68
25
54
255
44000
499
73
403
24
96
627
86
949
23
0.42
97
138
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TABLE 2
SUMMARY OF SUBSURFACE SOIL SAMPLE DATA
CONTAMINANT
MAXIMUM
CONCENTRATION
DETECTED
(ug/kg)
NUMBER OF
TIMES
DETECTED
AVERAGE OF
DETECTED
CONCENTRATION
(ug/kg)
ORGANICS
CARBON DISULFIDE 3.6
1,1-DICHLOROETHENE 160
1,1-DICHLOROETHANE 56
TRANS- 1,2-DICHLOROETHENE 69
CHLOROFORM 54
2-BUTANONE " 1300
1.1,1-TRICHLOROETHANE 140
VINYL ACETATE 8.0
1,1,2,2-TETRACHLOROETHANE 15
1,2-DICHLOROPROPANE 260
TRICHLOROETHENE 860
1,1,2-TRICHLOROETHANE 8.6
BROMOFORM 4.0
2-HEXANONE 46
4-METHYL-2-PENTANONE 1300
TETRACHLOROETHENE 390
TOLUENE 1700
CHLOROBENZENE 5.5
ETHYLBENZENE 420
TOTAL XYLENES 1500
INORGANICS
CHROMIUM 18
IRON 4715
LEAD 14
MANGANESE 8.7
MERCURY 0.09
SELENIUM 3.2
VANADIUM 23
ZINC 10
1
2
2
3
1
14
2
1
1
2
9
1
1
1
8
5
11
1
4
5
5
15
2
1
1
1
2
3
3.6
81
31
26
54
225
71
8.0
15
138
268
8.6
4.0
46
640
80
196
5.5
107
305
11
1886
10
8.7
0.09
3.2
22
8.7
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BLUEBERRY FIELD
(INACTIVE)
TRIBUTARY TO
BAFFIN BROOK
• 10
ACCESS
ROAD
COMPOSITE
NO. OF
OROANICS
DETECTED
TOTAL
VOLATILE
OROANICS
BLUEBERRY FIELD
(INACTIVE )
K»LC IN fill
FOREST
NO. OF
INORGANICS
DETECTED
• SOIL SAMPLE
FIGURE 3
SOIL CONTAMINATION AREA DEFINED BY VARIOUS CRITERIA
LANG RI/FS
CC JA
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TOTAL VOLATILE ORGANICS
CONCENTRATION t / Kg
2000
I
4000
6000
6000
I
50
SPLIT SPOONS MW 001 (D)
AND SOIL SAMPLE SL-24
LEGEND
BASED ON
SAMPLE RESULTS
—— EXTRAPOLATED
FIGURE
TVO CONCENTRATION (EXCEPT 2-BUTANONE)
VERSUS DEPTH
LANG RI/FS
CCJA
-------
50
FIGURE 5
TOTAL VOLATILE ORGANICS
CONCENTRATION /tg / Kg
1000
_J
2000
'
3000
1
4000
I
5000
6000
'
7000
I
4
SPLIT SPOONS MW 002(0)
AND SOIL SAMPLE SL-33
LEGEND
BASED ON
SAMPLE RESULTS
—— EXTRAPOLATED
TVO CONCENTRATION (EXCEPT 2-BUTANONE)
VERSUS DEPTH
LANG RI/FS
CC JA
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TABLE 3
SUMMARY OF GROUNDWATER MONITORING WELL SAMPLE DATA
CONTAMINANT
ORGANICS
METHYLENE CHLORIDE
ACCETONE
1,1-DICHLOROETHENE
1,1-DICHLOROETHANE
TRANS-1,2-DICHLOROETHENE
2-BUTANONE
1,1,1-TRICHLOROETHANE
1,2-DICHLOROPROPANE
TRICHLOROETHENE
BENZENE
2-HEXANONE
TETRACHLOROETHENE
TOLUENE*
ETHYL BENZENE
TOTAL XYLENES
1,4-DICHLOROBENZENE
BENZYL ALCOHOL
ISOPHORONE
2,4-DIMETHYLPHENOL
NAPTHALENE .
BIS (2-ETHYLHEXYL) PHTHALATE
4,4-DDT
MAXIMUM
CONCENTRATION
DETECTED
(ug/D
350
480
1400
4300
2500
49
8200
2800
55000
1600
14000
1500
15000
5300
26000
86
170
14
32
56
8
0.07
NUMBER
OF TIMES
DETECTED
1
1
2
2
3
1
1
1
3
1
2
2
3
1
1
1
1
1
1
1
4
1
AVERAGE OF
DETECTED
CONCENTRATION
(ug/1)
350-
480
709
2154
942
49
8200
2800
18691
1600
7135
1500
8242
5300
26000
86
170
14
32
56
4
0.07
*Toluene data was flagged with the data qualifier (B), which denotes that
this contaminant was detected in the blanks also.
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TABLE 3 (CONT.)
SUMMARY OF GROUNDWATER MONITORING WELL SAMPLE DATA
CONTAMINANT
INORGANICS
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
MAXIMUM
CONCENTRATION
DETECTED
(ug/1)
56700
103
11
231
1.8
11
8220
491
15
201
15700
- 74
2060
2570
0.6
574
7960
4.1
20200
6.4
238
1300
NUMBER
OF TIMES
DETECTED
14
4
3
17
5
8
16
20
7
5
14
12
8
11
1
12
10
2
9
2
16
2
AVERAGE OF
DETECTED
CONCENTRATION
(ug/1)
6532'
56
9.4
45.0
1.2
4.5
2234
47.0
7.0
78.6
4580
12.6
663
277.0
0.6
68.8
3323
4.1
7282
5.5
25.7
701
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BLUEBERRY fl
(INACTIVE!
TRIBUTARY TO
BAFFIN BROOK
o »Q|IUL IPO
§C*LC IN fltf
6 GROUNDWATER EUEVAT.QN CONTOUR MAP. DEC. ,985
LANG RI/FS
CCJA
-------
I
I
I
I
I
I
/OREST
OITCH NETWORK 7
DRAINING SIT? —-^
BOUNDARY OF MAXIMUM
EXTENT OF GROUND-
WATER CONTAMIWATtrtU I
BOUNDARY OF
ASSUMED GROUND-
WATER CONTAMINATION
MONITORING
WELL LOCATIONS
STAINLESS STEEL
WELLPOINT LOCATIONS
INACTIVE
BLUEBERRY FIELDS .
ISO
(APROX. SCALE IN FEET)
FIGURE
BOUNDARIES OF MAXIMUM AND ASSUMED
6ROUNDWATER CONTAMINATION
LANG RI/FS
CCJA
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-17-
Analysis of water level data collected from three different
periods revealed fluctuations in water table elevations. The
maximum vertical fluctuation at any given well cluster is less
than one foot. Such slight differences in water elevations sug-
gest that very little vertical movement of the ground water oc-
curs beneath the site. Downward migration of contaminated ground
water is retarded by the presence of increasingly finer sands
and higher silt content with depth. There is no conclusive
evidence of ground water contamination below .a depth of 11 feet
(maximum depth of shallow well screens) and the data indicate
no ground water contamination below a depth of 30 feet (m-inimum
depth of intermediate well screens).
Contaminated shallow ground water is probably being intercepted
by the ditch draining the site. This contaminated water is
travelling very, slowly downstream through the ditch, where it
is partially bound by sediments and partially volatilized into
the air. Contaminants re-entering the ground water from the
ditch or moving downgradient under the ditch have not yet reached
Well Cluster 5 ("MW5-S" in Figure 7).
In summary, the lack of a strong horizontal gradient and the in-
teraction between the ground water and surface water suggest
that contaminants have not migrated more than 300-500 feet from
the disposal area.
Surface Water and Sediment Investigation
Surface water and sediment samples collected from areas of ponded
water within the on-site disposal area were contaminated with
volatile organic compounds, as were samples collected from a
location along the ditch draining the site. This ditch could
have received surface water draining from the on-site disposal
area. Summaries of surface water and sediment contamination,
the extent of which is minimal in both cases, are presented in
Tables 4 and 5, respectively.
Vegetation Investigation
Given the close proximity of blueberry and cranberry fields, an
analysis of potential uptake of contaminants by vegetation was
conducted. Based on a review of site conditions, toxicological
information concerning plant uptake of chemical contaminants and
sampling of blueberries in close proximity to the site, there
is no evidence of contamination of nearby vegetation attributable
to the site.
Routine air quality monitoring was conducted throughout the on-
site field investigations. Analysis of these data showed no
evidence of contamination of ambient air, despite some excavation
activities at the site.
-------
TABLE 4
SUMMARY OF SURFACE WATER SAMPLE DATA
MAXIMUM
CONCENTRATION
DETECTED
CONTAMINANT (ug/kg)
ORGANICS
METHYLENE CHLORIDE 5
ACETONE 340
1,1-DICHLOROETHANE • 14
TRANS-1.2-DICHLOROETHENE 6
1',1,1-TRICHLOROETHANE 9
1,2-DICHLOROPROPANE 13
TRICHLOROETHENE 16
2-HEXANONE 30
TOLUENE 43
TOTAL XYLENES 5
PHENOL 10
2-METHYLPHENOL 10'
4-METHYLPHENOL 10
ISOPHORONE 10
BENZOIC ACID 50
BIS (2-ETHYLHEXYL) PHTHALATE 10
DIELDRIN 0.02
4,4-DDE 0.01
4,4-DDD 0.02
4,4-DDT 0.026
INORGANICS
ALUMINUM 530
ANTIMONY 73
BARIUM 2.6
CADMIUM 5.0
CALCIUM 2390
CHROMIUM 6.9
COPPER 15
IRON 2360
MAGNESIUM 948
MANGANESE 63
NICKEL 89
POTASSIUM 880
SILVER 14
SODIUM 2440
VANADIUM 2.5
ZINC 36
NUMBER OF
TIMES
DETECTED
1
1
1
1
1
1
1
2
1
1
2
1
1
1
1
3
3
1
2
1
11
1
1
1
4
2
7
2
10
9
1
2
1
1
2
7
AVERAGE OF
DETECTED
CONCENTRATION
(ug/D
5
340
14
6
9
13
16
20
43
5
10
10
10
10
50
10
10
0.01
0.015
0.026
298
73
2.6
5.0
1294
5.2
9.2
1364
513
28
89
796
14
2440
2.1
23
-------
TABLE 5
SUMMARY OF SEDIMENT SAMPLE DATA
MAXIMUM
CONCENTRATION
DETECTED
CONTAMINANT
ORGANICS
ACETONE
1,1-DICHLOROETHANE
TRANS-1 ,2-DICHLOROETHENE
CHLOROFORM
1,2-DICHLOROPROPANE
TRICHLOROETHENE
4-METHYL-2-PENTANONE
TOLUENE
CHLOROBENZENE
ETHYLBENZENE
TOTAL XYLENES
D I ETHYL PHTHALATE
DIELDRIN
4,4-DDD
INORGANICS
ALUMINUM
CALCIUM
CHROMIUM
COPPER
IRON
LEAD
MANGANESE
MERCURY
NICKEL
SILVER
SODIUM
VANADIUM
ZINC
(ug/kg)
700
50
13
6.3
34
45
8.9
940
3.5
4.7
8.6
77
210
530
758
505
51
5.6
709
17
7.9
0.38
47
6.3
451
21
15
NUMBER
OF TIMES
DETECTED
7
1
1
1
1
1
1
8
2
1
1
1
1
2
8
9
3
1
7
9
3
9
2
1
9
1
1
AVERAGE OF
DETECTED
CONCENTRATION
(ug/kg)
176
50
13
6.3
34
45
8.9
253
3.2
4.7
8.6
77
210
287
334
195
30
5.6
246
6.1
6.4
0.28
31
6.3
335
21
15
-------
-20-
Public Health Evaluation (Risk Assessment)
To assist in determining the impact of the site on public health
and the environment, a public health evaluation was performed
for the Lang Property Site. It was determined that substantial
risks to human health exist under a number of exposure scenarios.
Risk associated with chemical contamination at the site was as-
sessed with respect to current use of the site as well as poten-
tial future uses, including residential and agricultural use.
Where appropriate, relevant standards were used to assess the
impact on the site.
The current-use scenario involving direct contact with soil at
the site was found to pose a risk to human health, using reason-
able assumptions regarding exposure. The future-use scenarios,
which involve.use of ground water as a drinking water source and
direct contact with soil, would pose substantial human health
risks.
In addition to these human health risks, there are significant
environmental concerns associated with the site. The Lang Prop-
erty Site is located within the Central Pine Barrens Water Qual-
ity Critical Area and the Pinelands Preservation Area District.
Since this site has contaminated soils, ground water, and surface
water in these critical areas of the Pinelands, it constitutes
an endangerment to the environment. Although estimates of ex-
posure and risk to critical animal species could not be quant-
ified, the concentration of several contaminants in soils,
surface water, and ground water appear to be sufficiently high
to pose hazards to indigenous fishes, amphibians, and certain
mammals and birds.
In summary, the soil, ground water, and environmental studies
undertaken at and in the vicinity of the Lang Property site in-
dicated that, among other findings:
1. Both organic and inorganic hazardous substances (HS's) exist
in the soil throughout the contaminated two-acre parcel
located on the Lang Property. HS's were detected throughout
this area to a depth of 20 feet.
2. This two-acre parcel of contaminated soil is in direct con-
tact with the surficial aquifer under the site.
3. The surficial aquifer exhibits elevated levels of specific
hazardous substances that are also present in the soil over-
lying the site.
4. Many of the hazardous substances present on-site were de-
tected in the soil in concentrations which far exceed any
background levels expected in off-site soils, as well as
any levels detected in soils outside the site boundaries.
-------
-21-
5. Some hazardous substances present at the site have entered
the surface water flowing across the site.
The environmental studies at the Lang site clearly indicate that:
a. Hazardous substances, as defined in Section 101 (14) of
CERCLA, 42 USC 9601 (14), have been and are being released
into the environment at the Lang site; and
b. A substantial threat of new and continued release of- haz-
ardous substances into the environment exists at the Lang
site.
VI. SCREENING OF REMEDIAL TECHNOLOGIES
Objectives
As an initial step in establishing the objectives for remedial
action, the following five contaminated media were established
as requiring action: shallow ground water, on-site surficial
soil, on-site subsurface soil, surface water in the ditch ad-
jacent to the site, and sediments in the ditch adjacent to the
site.
For purposes of remedial action, the shallow ground water at
the site and the surface water in the ditch can be considered a
single medium. Data generated during the RI indicate that water
in the ditch may be considered exposed ground water. The
Pinelands Commission has also reported that, in general, eighty
percent of the surface water in the Pinelands represents ground
water discharge. Since the contaminant plume extends to, and
possibly beyond, the ditch adjacent to the site, any plume
management strategy which addresses contaminated ground water
would also address the surface water in the ditch. This approach
is desirable considering the limited quantity of water in the
ditch and the relatively free interaction between ground water
and surface water in the site area.
The same approach may be used in addressing problems associated
with contaminated surficial soil on the site and contaminated
sediment in the ditch around the site. Managing the sediment
contamination problem as part of the on-site soil contamination
problem seems to be a viable and cost-effective approach. The
negligible flow rate in the ditch and sample analytical results
indicate that little downstream migration of sediment contami-
nation has occurred.
Subsurface soil contamination has been evaluated and determined
to be a result of movement of contamination through the ground
water. Of the chemical wastes disposed of at the site, some
-------
-22-
contaminants became bound to the organic matter in the surficial
soils while others percolated into the groundwater. Apparently,
most contaminants with strong soil binding mechanisms did not
move into the groundwater and so were detected only in the sur-
ficial soils. The primary indicator used to determine the degree
to which an organic contaminant binds to soil particles is the
organic carbon partition coefficient (Koc.) A higher Koc for a
contaminant is assumed to indicate a greater degree of binding to
organic soil particles.
Most of the contaminants detected in the subsurface soils have
significantly lower organic carbon partition coefficents than
do contaminants detected in the surficial soils alone. This
situation, coupled with the lack of organic matter in the
subsurface soils, suggests that subsurface soil contamination
will be removed as groundwater contamination is removed. When
contaminant levels in the extracted ground water approach the
effluent discharge standards for the treatment process, sampling
will be conducted to document the anticipated corresponding
reduction of contamination in the subsurface soil. Therefore,
the Feasibility Study focused on remedial alternatives for
contaminated surficial soils (including ditch sediments) and
contaminated shallow ground water (including surface water and
subsurface soils).
At this site, the EPA response measures are dictated by the need
to remove significant public health risks presented by current-
and future-use scenarios involving direct contact with on-site
surface soils, and by future-use scenarios involving ingestion
of ground water from the site. In addition, the site is located
in New Jersey's Pinelands National Reserve, a forest expanse
which has been recognized as one of the nation's valuable en-
vironmental resources. Protection of the Pinelands by preserving
its unique character and inherent resources is mandated by Federal
legislation.
Based on information gathered during the Remedial Investigation,
general response actions, or classes of response, were identified.
General response actions considered include the "no action"
alternative, which will serve as a baseline against which other
remedial measures can be compared. Potential technologies were
then identified for each general response action. Table 6 sum-
marizes this information.
Remedial Technology Screening
Technologies are discussed relative to the contaminated media
to which each is applicable. As explained previously, remedial
alternatives focused on contaminated surficial soils (includ-
ing ditch sediments) and contaminated shallow ground water
(including surface water and subsurface soils). Technologies
-------
TABLE 6
GENERAL RESPONSE ACTIONS AND POTENTIAL TECHNOLOGIES
LANG PROPERTY FEASIBILITY STUDY
General Response Action
Technologies
No Action
Containment
Pumping
Collection
Diversion
Complete Removal
«•
On-s1te Treatment
Off-site Treatment
In-s1tu Treatment
Storage
On-s1te Disposal
Off-site Disposal
0 Periodic monitoring, sampling and
analysis
o Surface capping
o Subsurface low-permeability barriers
o Pumping of shallow groundwater
o Subsurface drains to collect shallow
groundwater
o Subsurface low-permeability barriers
o Excavation of all on-site
contaminated surficial soil
o Biological, chemical or physical
treatment of groundwater
o Incineration, solidification or
stabilization of on-s1te
contaminated soil
o Removal and transport of the
contaminated groundwater and/or soil
to an off-site treatment facility
o Removal of contaminated groundwater,
pretreatment and discharge to a
Publicly Owned Treatment Works
(POTtf)
o Bioredamatlon
o Chemical Dextoxification
o Soil flushing
o Immobilization
o Temporary on-site storage
o Construction and maintenance of an
on-site hazardous waste disposal
facility
o Excavation and transport of
contaminated soil to a off-site
permitted hazardous waste landfill
-------
-24-
aimed at remediating each contaminated medium were evaluated
and screened on the basis of technical applicability, public
health and environmental effects, institutional constraints,
and order of magnitude costs. The results of the screening
produced feasible remedial action technologies that then were
combined into remedial alternative components.
A summary of the screening of technologies based on waste and
site characteristics and technical requirements is presented in
Table 7. Technical criteria involve the degree to which the
technology has been demonstrated to be capable of achieving
long-term control of contaminant release or migration from the
site. Technologies retained for further evaluation were grouped
into remedial strategies for each contaminated medium. Strate-
gies that achieve similiar goals were then evaluated and further
screened before being integrated into alternatives that addressed
the entire site.
The discussion below addresses those technologies which passed
the screening process along with technologies which, while
eliminated from further consideration, need to be addressed in
this document due to considerations relating to alternative
technologies and compliance with other environmental statutes.
Ground Water Control Technologies
Ground water control technologies can be applied to contain,
collect, divert, or remove the groundwater in the area of the
site in an effort to prevent further migration of contaminants
from the site and manage the migration that has already occurred.
One such technology is ground water pumping.
Pumping of Ground Water - Ground water pumping is used to con-
trol contaminant plumes through adjustment of the water table
elevation, containment of the plume, or removal of the plume.
Pumping methods are most effective at sites where underlying
aquifers have high hydraulic conductivities and contaminants
move readily in water. The highly inert and permeable sands
underlying the Lang Property site are well suited for pumping.
In particular, the screening process focused on plume removal.
Plume removal implies a complete purging of the ground water
system. Removal techniques are often suitable when contaminant
sources have been removed and aquifer restoration is desired.
Extraction wells or extraction and injection wells in combination
are used in plume removal. Extraction and injection techniques
can also be used in concert with flushing to accelerate contami-
nant removal. As with containment stategies, treatment of
extracted ground water is necessary.
-------
TABLE 7
SCREENING OF POTENTIAL TECHNOLOGY
LANG PROPERTY FEASIBILITY STUDY
HASTE
CHARACTERISTICS
TECHNOLOGY
6ROUNDWATER CONTROL
Subsurface Barriers yes
Pumping yes
Subsurface Drains ' yes
GROUNDWATER TREATMENT
On-s1te Treatment "
Activated Carbon yes
Biological no
Precipitation, Flocculation
and Sedimentation yes
Ion Exchange yes
Sorptlve Resins «. no
Reverse Osmosis yes
Air Stripping yes
Chemical Oxidation no
Wet Air Oxidation no
Filtration yes
Off-site Treatment yes
In-situ Treatment
Bioreclamation no
Chemical Detoxification no
SURFICIAL SOILS
In-situ Treatment
~ Bioreclamation no
Chemical Detoxification no
Soil Flushing ''. /
Immobilization *iib
Heating no
Surface Capping yes
On-s1te Treatment
Solidification/
Stabilization no
Incineration no
Volatilization no
On-site Disposal yes
Off-site Incineration or
Disposal •'' yes
APPROPRIATE TECHNOLOGY BASED ON
TECHNICAL
SITE
CHARACTERISTICS
no
yes
no
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
no
yes
yes
yes
no
yes
yes
yes
yes
yes
yes
yes
yes
no
yes
yes
yes
yes
yes
yes
no
no
no
no
yes
yes
no
yes
yes
yes
yes
yes
yes
RETAINED
FOR
FURTHER
EVALUATION
no
yes
no
yes
no
yes
yes
no
yes
yes
no
no
yes
yes
no
no
no
no
no
no
no
no
no
no
no
no
yes
-------
-26-
Ground Water Treatment Technologies
On-Site Treatment of Ground Water .- At the Lang Property Site,
this could be achieved by using a mobile treatment system or
building an-on-site treatment system. In either case, the
treatment system will likely consist of a combination of treat-
ment processes. Processes that may be applicable to this site
include the following:
Activated Carbon - This process involves treating a waste stream
with carbon, usually by flow.through packed bed reactors. This
process is especially well suited for removal of mixed organics.
Precipitation, Flocculation, and Sedimentation - Precipitation
removes a substance from a solution and transforms it into solid
particles. Flocculation promotes particle growth of suspended
solids for ease of removal and sedimentation removes settleable
particles from the liquid. At the Lang Property site, a treat-
ment unit combining these processes could remove metals and
other inorganics from the contaminated.ground water, in addition
to removing suspended solids.
Ion Exchange - Ion exchange is a process by which toxic ions are
removed from the waste stream and replaced with relatively harm-
less ions held by the ion exchange material. This technology is
well established for the removal of heavy metals.
Reverse Osmosis - This process entails the separation of water
from a solution by means of pressure exerted on the solution
within a semi-permeable membrane that allows only pure water to
pass through. Reverse osmosis cannot reliably treat waste with
high organic content, as the wastes may dissolve the membrane.
At the Lang Property site, the use of this process may be
limited to the polishing of a previously treated wa'ste stream.
Air Stripping - Air stripping is a mass transfer process in which
volatile organic contaminants in water are transferred to gas.
Air stripping is particularly suited to the Lang Property Site
due to the presence of significant concentrations of volatile
organics in the ground water.
Filtration - Suspended solids can be separated from a solution
by passing the solution stream through a bed of filter media.
At this site, filtration may be employed prior to air stripping
or activated carbon adsorption to reduce the potential for
biological growth, clogging and the suspended solids load on
these units. Filtration could also be used as part of a polish-
ing unit to remove residual floe from the effluent of a precip-
itation, flocculation, and sedimentation process.
-------
-27-
Off-Site Treatment - Untreated ground water from the site can
be transported to a treatment facility for pretreatment of the
ground water and discharge to a Publicly Owned Treatment Works
(POTW). Some of the treatment facilities located in the north-
eastern United States include: DuPont Environmental Services,
Waste Conversion, Inc., CECOS International, and the Pemberton
Township Municipal Utilities Authority (PTMUA). Any of these
may be capable of handling a waste stream from the Lang Property
site.
The PTMUA operates a 2.5 MGD capacity activated sludge treatment
plant located in Birmingham, New Jersey. Effluent from this
plant is discharged to the north branch of Rancocas Creek and
the sludge is applied to agricultural land. The PTMUA service
area extends to. Country Lake Estates, a community located
approximately three miles from the Lang Property site.
Transport of the contaminated groundwater to the POTW would prob-
ably be accomplished by a force main, whereas transport to the
other treatment facilities under consideration will require
trucking. Off-site treatment will be retained for further eval-
uation.
Surface Capping
Surface capping at the Lang Property site would prevent contact
with the waste by humans or animals entering the site area.
However, considering the depth of soil contamination and the
shallow water table, isolating the waste from the ground water
would require that surface capping be performed in conjunction
with the pumping or draining of ground water to a depth greater
than that of the contaminated soil.
According to the requirements of the Resource Conservation and
Recovery Act (RCRA), final cover of a landfill must be designed
and constructed to provide long-term minimization of liquid pas-
sage through the closed landfill, function with minimum mainten-
ance, promote drainage and minimize erosion of the cover, accom-
modate settling and subsidence to maintain the cover's integrity,
and have a permeability less than or equal to that of any bottom
liner system or natural subsoil. A cap installed at the Lang
Property site conforming to these requirements would be inefficient
due to the high water table, which averages only about one and
one-half feet below ground surface.
Capping is usually done in concert with ground water controls
or containment technologies designed to isolate the source of
contamination. However, in regard to public health and the
environment, removal of the source of contamination is always
preferable to capping or any other form of containment. Because
much of the contamination at the site is concentrated in the
surficial soils, excavation would be both feasible and implement-
-------
-28-
able here. Accordingly, capping in conjunction with groundwater
control or containment has been determined to be inappropriate
for the Lang Property site and so will not be retained for
further evaluation.
Surficial Soil Remedial Technologies
Soil Flushing - Soi] flushing is achieved by the movement of
water or an aqueous solution through the area of contamination
and the subsurface collection of the elutriate. High to'medium
solubility organics can generally be flushed from soil. These
include: lower molecular weight phenols and carboxylic acids;
low to medium molecular weight ketones, aldehydes, and aromatics;
and lower molecular weight halogenated hydrocarbons such as
trichloroethene and tetrachloroethene.
Since, however, some classes of contaminants found in the sur-
face soils exhibit strong tendencies to bind to soil particles,
soil flushing may not remove all the contamination present.
Although subsurface soils would be amenable to soil flushing,
the phthalates, phenols, PAH's, and PCB's detected in the sur-
ficial soil at the Lang site will be resistant to this process.
Thus, if soil flushing is applied, it should be done in conjunc-
tion with other remedial technologies.
Excavation and Treatment or Disposal of Contaminated Soils
Excavation - As discussed previously, the surficial soils
(0-2 feet deep) are grossly contaminated with volatile organic
compounds bound to the organic matter in the soils. Consequently,
excavation and removal of the surficial soils would effectively
remove most of the source of the contamination at the site.
On-site Treatment - On-site treatment of contaminated surficial
soils at the site would involve the excavation and treatment by
solidification/stabilization, incineration, or volatilization.
Solidification/Stabilization - Solidification of wastes produces
a monolithic block with high structural integrity. The contami-
nants do not necessarily interact chemically with the solidific-
ation reagents, but are mechanically locked within the solified
matrix. Solidification/stabilization techniques for treating
soil contaminated with organics have not been adequately demon-
strated to warrant further consideration as part of the remedy at
this site.
On-Site Incineration - Thermal destruction methods have proven
to be effective in the destruction of organic contaminants in
liquid, gaseous, and solid wastes. Incineration of contaminated
soils at the Lang Property site would require that either a
-------
-29-
mobile incineration system be brought to the site or an inciner-
ator be constructed on-site. The small volume of soils to be
incinerated at the site would make construction of an incinera-
tion system at the site uneconomical.. Mobile incineration
systems require that the feed stream be homogeneous and fine-
grained.
Surficial soils at the site are littered with debris and many
areas have relatively thick vegetative cover. The reduction of
these soils to a fine-grained consistency would be costly.. In
addition, ash from the incineration process would require removal
and off-site disposal. Thus, the surficial soils at the Lang
Property Site do not seem well suited to on-site incineration.
Volatilization - Volatilization can be accomplished through ther-
mal treatment or mechanical aeration. The direct heat rotary
dryer is a proven thermal treatment unit and has been used for
many years by the asphalt industry. Because this unit is best
suited for use with free flowing granular solids, the presence
of debris and bulk materials scattered throughout the Lang
Property site would complicate the operation of such a system.
Mechanical aeration has also been used to enhance the removal
of volatile organic contaminants from soils. Excavation of
contaminated soils, followed by land spreading and mechanical
agitation with machinery similar to a rototiller, is the simplest
approach. Mechanical aeration is most effective when used on
dry granular soils, since moisture or a high clay content may
hamper volatilization.
Air emissions from either a thermal treatment or a mechanical
aeration process would have to meet applicable Federal and
State regulations. A major shortcoming of both these processes
is the inability to treat non-volatile organic contaminants and
inorganic contaminants. Thus, if volatilization is implemented,
the soils would receive only partial treatment and so would
require further off-site treatment or landfill disposal. Based
on these considerations, volatilization was eliminated from
further consideration.
On-site Disposal
On-site disposal of contaminated soils and sludges generated by
excavation of contaminated material, or by an on-site treatment
or pretreatment process, requires the construction of a secured
landfill that meets RCRA and State requirements. Several cri-
teria are associated with the construction of a RCRA hazardous
waste landfill, including the following:
-------
-30-
0 The landfill should be designed so that the local ground
water table will not be in contact with the facility.
0 The landfill should be constructed of, or lined with,
natural or synthetic material of low permeability to
inhibit leachate migration.
0 An impermeable cover is required to minimize infiltration
and leachate production.
0 A leachate and runoff collection system must be provided.
0 Periodic monitoring of surface water, ground water, and
soils adjacent to the facility must be conducted to
determine the integrity of the liner and leachate col-
lection system.
At the Lang Property site, construction of a landfill meeting
these requirements would be impractical due to the high water
table and the uncompacted, highly permeable sands underlying
the site. These conditions preclude the need for further
evaluation of this technology.
Off-Site Treatment or Disposal of Contaminated Soils
Off-site treatment or disposal consists of the removal of sur-
ficial soils and transport to an off-site landfill or incinera-
tion facility. Discussions with several incineration facilities
have indicated that this is a viable option, although costly.
An important consideration in the evaluation of any off-site -
treatment or disposal technology is the need for compliance
with the EPA's Off-Site Policy. A potential constraint in im-
plementing a remedial alternative involving off-site disposal
or incineration could be in locating facilities that are in
compliance with the Off-Site Policy. However, this technology
was retained for a detailed evaluation.
Effluent Discharge
Extracted groundwater can be discharged to a surface water
body, discharged to a POTW, or reinjected into the ground. The
last two alternatives are discussed extensively in the Descrip-
tion of Alternatives section below.
Discharge to Surface Water - Discharge of an on-site treatment
process effluent to a surface water body is rendered impractical
by the lack of an adequate receiving water body in the area. A
review of topographic maps of the area indicated that all streams
within a three-mile radius are unsuitable for surface water
discharges because of extremely low flow rates, particularly
during dry conditions. Three miles was chosen as the distance
for consideration because that is the distance to the nearest
sanitary sewer system, which is a comparable alternative.
-------
-31-
VII. APPLICABLE FEDERAL AND STATE CRITERIA AND STANDARDS
Applicable Standards
Applicable or relevant and appropriate requirements were reviewed
in preparation for evaluation of contaminated ground water treat-
ment and disposal aspects of remedial alternatives. The applic-
able standards and criteria for chemicals detected at above-
background concentrations in on-site samples of contaminated
ground water are presented in Table 8. Although the list- of
indicator chemicals consists exclusively of organic compounds,
the inorganic compounds'detected in on-site groundwater and
included in Table 8 are given full consideration with respect
to establishment of effluent criteria for contaminated ground-
water treatment- systems.
Federal Standards
Columns 1 and 2 of Table 8 list the Primary and Secondary Drink-
ing Water Standards as defined in the Federal Safe Drinking
Water Act of 1974 (PL 93-523), which was amended in 1977.
These standards define water quality criteria for public drinking
water supplies as per 40 CFR 141 and 143 of the Safe Drinking
Water Act. The primary standards address health considerations,
while the secondary standards reflect aesthetic qualities (i.e.,
odor, taste, etc).
The recommended maximum contaminant levels (RMCL's) and maximum
contaminant levels (MCL's) in Columns 3 and 4 were developed to
specify concentrations of volatile organics in drinking water
which would result in no known or anticipated adverse health
effects. An MCL represents the allowable lifetime exposure to
a contaminant for a 70-kilogram adult who consumes two liters
(0.53 gallons) of water per day. MCL's are established to
achieve health goals while considering practical limitations
(such as treatment technology, economics, and detection limits)
while RMCL's are based exclusively on health considerations
without regard for technical considerations. For this reason,
MCL's are considered enforceable standards and RMCL's are con-
sidered nonenforceable. Consequently, for establishing discharge
limitations, MCL's have been determined to be applicable, rel-
evant and appropriate, while RMCL's are not considered.
Proposed RMCL's and MCL's were published in the Federal Register
in November 1985 but have yet to be finalized by EPA. Proposed
MCL's are not listed because, as discussed above, they are not
and will not be enforceable and hence are considered inappropriate
Columns 5 and 6 list Federal Ambient Water Quality Criteria
developed by EPA's Office of Water Planning and Standards,
Division of Criteria and Standards. These values are from
individual documents which represent refinements of the initial
criteria. Maintaining contaminant levels below these values
will result in the following:
-------
TABU 8
REMEDIATION CRITERIA
Duality
Criteria
Safe Drinking Water Act Cancer Risk
NJPDES Tonic NJDFP
Proposed Water Effluent Proposed
Limitations Drinking
for Permit Water
Potable Water Guidelines
NJDEP Dlv. Of Water
Resources - Current
Policy For Ground
Water Cleanup
(See II Del ox)
HJ State
Uroundwater
Standards
GW I
Central Pine
Barrens Water
Quality
Standards
Groundwater
Column:
Hethylene Chloride
I.I-Olchloroethene
I.l-Dlchloroethane
frans- 1 ,?-Dlchloroethene
1 .1 ,1-Irlchloroethane
Trlchloroethene
Ben/ene
Tet rachloroethene
toluene
Elhylhen/ene
Total lylencs
1 ,4-Dlchloroheniene
l.?-0lchloro|iropanp
lso|ihorone
t, 4 -Dimethyl phenol
Bls(2-Ethylhe«yt)Phthalate
Barium
Cadmium
Chronlum
Copper
Iron
Lead
Nickel
Sodium
21 nc
Cane. Cane.
Risk Risk
ff\m. Se£. MCL PHCl_ \0~6 lox. 10' 6 Io«.
(1) (?) (3) (4) (5) (6) (7) (8) (9)
0.19 4.8
0.033 7.0
5 5 0.033
70 ?7
too 200 18.400 IB. 400 ?o •
5 5 2.7 2.7 3.1
5 5 0.66 .0.66 0.68
S 0.8 0.8 0.67
14.300 14.300
1.400 1.400
750 750 400 400
S.?00 5,?00
400
15.000
l.nuo
10 10 10
50
1 ,000 1 .000
300
50 50 50
13.4 13.4
1
5.000 5.000
(10) (11)
5
5
5
5
See Below- la
5
5
5
See Below- la
See Be low- la
See Be low- la
See Below- la
5
5 1 .000
IIBG
HUG
1.000
300
50
10.000
5.000
(1?)
1 .000
HUG
1.000
30U
NOG
10.000
5.000
Notes: 1) Additional standards for thp following were based on Information provided to EPA by NJOFP with regard to another NPL site with
comparable contamination problems In the Plnelands. These standards were reported by NJUEP staff to reflect current departmental
policy. '
a) Total priority pollutant volatile organlcs < 50 ppb
b) Individual carcinogens < S ppb
c) Total ketones < 100 pph
?) All criteria are presented In ug/1
3) NBG = Natural Background
-------
-33-
0 Less than one additional cancer case per 1 million exposed
persons (10~6 risk level) for carcinogenic chemicals (column
5)
0 No adverse noncarcinogenic health effects. These toxicity
values establish a concentration that corresponds to the
threshold level for noncarcinogenic chemicals (column 6).
State Standards
Columns 7 and 8 of Table 8 represent the New Jersey Pollution
Discharge Elimination System (NJPDES) permit limitations for
toxic effluents for the protection of potable water. These
maximum values are presented in terms of the 10~6 risk level
for carcinogenic chemicals (column 7) and in terms of the thres-
hold toxicity level for noncarcinogenic chemicals (column 8).
Column 9 represents New Jersey Department of Environmental
Protection (NJDEP) Drinking Water Guidelines. These standards
are based on recommended limits of 5 ug/1 (micrograms per liter)
for individual organic chemicals and 50 ug/1 for all priority
pollutant volatile organic chemicals present.
Column 10 presents New Jersey State Ground Water Standards for
ground water classified as GW 1, -the designation for the aquifers
beneath the Lang Property site. Column 11 presents ground water
quality standards for the Central Pine Barrens as established
by NJDEP.
Additional Guidelines
Several of the contaminants identified are critical to treatment
system design but have no established Federal or State standards
for comparison. Accordingly, recommended limitations were de-
veloped based on information provided to EPA by NJDEP with regard
to another Superfund site located in the Pinelands with compar-
able contamination. These recommended limitations are presented
as footnotes to Tables 8 and 9.
Standards Relative To Type of Discharge
Discharge To Groundwater
Contaminant limitations in effluents discharged to ground water
vary depending on the classification of the receiving ground
water. EPA's Ground Water Protection Strategy provides general
guidance rather than specific groundwater criteria. This
strategy separates ground water into Classes 1, 2, and 3. The
ground water in the vicinity of the site, being located in the
Central Pine Barrens Critical Area, falls within Class 1 (Special
-------
-34-
Ground Water), which includes those aquifers that are highly
vulnerable to contamination and either irreplacable or ecolo-
gically vital sources of drinking water. EPA Region II has
advised that ground water discharges in this vicinity should be
treated to attain Federal drinking water quality standards.
However, if the natural background concentration of a compound
is higher than the Federal drinking water standard, the compound
shall be treated to natural background concentration.
Similarly, NJDEP divides the State's ground water into Classes
GW 1, GW 2, GW 3, and GW 4. GW 1, the classification for ground
water at and around Lang Property, has the most stringent water
quality criteria, which are presented in column 11 of Table 8.
According to NJDEP, "Class GW 1 ground water in the Pine Barrens
shall be suitable for potable water supply, agricultural water
supply, continual replenishment of surface waters in the Central
Pine Barrens, and other reasonable uses" [N.J.S.A. 7:9-6.5(f)].
In addition, NJDEP policy states: "Existing and potential uses
of groundwater shall be maintained and protected" [N.J.S.A.
7:9-6.4(c)]. Hence, since one of the potential uses of Class
GW 1 ground water is as a potable water supply and it is the
policy of NJDEP to maintain and protect potential ground water
uses, all discharges to ground water in this area must meet the
applicable drinking water standards. Establishment of actual
discharge limitations are considered by NJDEP on a case by case
basis. Central Pine Barrens Water Quality Standards for ground
water within the Pinelands are presented in column 12 of Table
8.
Discharge limitations for the pollutants detected in on-site
ground water based on the standards listed in Table 8 are pre-
sented in Table 9. The limits based on Federal, State and local
drinking water and groundwater quality criteria are intended to
produce an effluent that exceeds all applicable and relevant or
appropriate public health and environmental requirements.
Discharge To Surface Waters
Contaminant limitations in effluent discharges to surface waters
vary depending upon the classification of the receiving surface
water. The surface waters near Lang Property are classified by
NJDEP as FW-1 and as such are considered nondegradation waters.
According to NJDEP policy, the quality of nondegradation waters
"shall be maintained as to quality in their natural state (set
aside for posterity) and shall not be subject to any man-made
wastewater discharge" (N.J.S.A. 7:9-4.5). This policy is not
subject to variance or waivers. In addition, the New Jersey Pine-
lands Comprehensive Management Plan states repeatedly that the
Pinelands Commission's policy is to prohibit direct discharges
into surface waters.
-------
TAOLE 9
LANG PROPERTY GROUNDWATER DISCHARGE LIMITATIONS
Methylene Chloride
1,1-Dichloroethene
1,1-Dlchlorocthane
Trans-l,2-0ichloroethene
1,1,1-Trlchl o roe thane
Trlchloroethene
Benzene
Tetrachloroethene
Toluene
Ethylbenzene
1,4 -Di chlorobenzene
Isophorone
2,4-Dimethyl phenol
B< s( 2-Ethy 1 hexy 1 )Phthal ate
Barium
Cadmium
Ch ran! inn
Copper
Iron
Lead
Nickel
Sodium
Zinc
Background Groundwater
Qua!Ity
Background Data Source
Cone. (Well No.)
(ug/1)
Limitations Based on
Federal Water quality
Standards
<10.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
<20.0
<20.0
<20.0
<20.0
20.0
<1.9
11.0
<4.5
10,300.0
<1.7
<5.0
4.100.0
59.0
5-S
8-S
8-S
8-S
8-S
8-S
8-S
8-S
5-S
8-S
8-S
8-S
8-S
7S-1,
7S-1.7S-2
8-S
7S-1.7S-2
8-S
8-S
5-S
8-S
'8-S
3-S '
,75-2
Limitation
(U9/D
0.19
*
0.033
70.0
200.0
2.7
0.66
0.8
14,300
1,400
400.0
5,200.0
400.0
15,000.0
1,000.0
10.0
50.0
1,000.0
300.0
50.0
13.4
*
5.000.0
Data Source
(Column in
Table 3-1)
5
*
5
4
3.4
5
5
5
. 6
6
6
6
6
6
1
1.6
6
2.6
2
1.6
6
*
2,6
Limitations Based on
Federal, Stale and Local
Uater Quality Standards
Limitation Data Source
(ug/1) (Column in
Table 3-1)
0.19
0.033
0.033
5.0
See Below-la
2.7
0.66
0.8
See Below-la
See Below-la
400.0
5,200.0
400.0
5.0
1,000.0
NBG
NBG
1,000.0
300.0**
50.0 or
13.4
10,000.0**
5,000.0
NBG
5
7
5
10
10
5,7
5.7
5,7
10
10
6.8
6,8
6
10
1.11.12
11,12
11
2,6,11,12
2,11,12
1,6.8,11,12
6.U
11,12
2.6,11,12
Notes: 1) Additional standards for the following were based on information provided to EPA by NJDEP with regard
to another NPL site with comparable contamination problems in the Pinelands: •
a) Total priority pollutant volatile organics < 50 ppb
b) Carcinogens < 5 ppb
c) Total ketones < 100 ppb
(2) NBG = Natural Background
*No Federal limitations exist for these compounds.
**Ihese contaminants will be treated to NBG concentrations If the NBG concentration is greater than the limitation
Imposed.
-------
-36-
Discharge To A Publicly Owned Treatment Works (POTW)
The nearest waste water collection system to Lang Property is
located in Country Lakes Estates, approximately three miles
from the site. This system is operated by the Pemberton Township
Municipal Utilities Authority (PTMUA) and is served by an acti-
vated sludge secondary treatment plant that receives domestic
waste water exclusively.
This plant has a design capacity of 2.5 million gallons per day
(MGD) and currently operates at 1.5 to 2.0 MGD. The NJPDES permit
for the plant's discharge to the north branch of Rancocas Creek
specifies discharge limitations for daily discharges of five-
day biological oxygen demand (BOD), suspended solids, and total
phosphate. The PTMUA also has an NJPDES permit regulating the
land application of their sludge. This permit limits the dis-
posal of several metals contained within the POTW's sludge.
Contaminant limitations for discharges to a POTW's collection
system depend upon the policy of the POTW regarding non-domestic
sewerage system connections. "Regulations of the PTMUA require
a formal written agreement that establishes specific conditions
applicable to each non-domestic sewer user. This agreement is
intended to establish acceptable waste characteristics, flow
conditions, quantities to be received, costs and conditions ap-
plicable to the physical connection, and service charges for
conveyance, treatment, and disposal. It is the policy of the
PTMUA to consider each application on its merits and to establish
specific conditions appropriate for each applicant.
The PTMUA's "Rates, Rules and Regulations" establish maximum
limits for five contaminants (all of them metals) detected in
on-site ground water samples from Lang Property. A comparison
of the PTMUA's limits for these metals with their concentrations
in Lang Property ground water indicates that the effluent from
the pretreatment system should be acceptable to the POTW.
27 other contaminants detected in the ground water, mostly
volatile organics, fall within the category of prohibited
wastes, as defined in PTMUA's "Rates, Rules and Regulations".
PTMUA's engineer has indicated that each of these contaminants
would have to be evaluated in detail to determine its potential
effect on (1) the safety of treatment plant operating personnel,
(2) the collection and conveyance system, (3) waste water
treatment facility operations, and (4) sludge disposal operations.
The engineer also expressed concern regarding potential modifi-
cations required of PTMUA's Wastewater Treatment Plant NJPDES
Permit and Land Application of Residuals NJPDES Permit if
pretreated ground water were to be accepted.
-------
-37-
A pretreatment system can probably be designed to reduce these
contaminants to levels that would not affect PTMUA's waste water
treatment plant and sludge disposal operations. The specific
requirements of such a pretreatment system will be determined
when toxicity tests and mass balance calculations are completed.
In the interim, pretreatment will be assumed to consist of three
elevated temperature air stripping towers and a coagulation,
flocculation, and sedimentation unit.
VIII. DESCRIPTION OF ALTERNATIVES
Remedial strategies for> individual contaminated media that have
not been removed from consideration were grouped together to
form alternatives capable of remediation of the entire site.
The National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) requires that at least one alternative be developed
to address each of the following categories:
Category I
Alternatives that attain all applicable or rele-
vant Federal public health or environmental
standards, guidance, and advisories.
Category II
Category III -
Category IV -
Alternatives that exceed all applicable or rele-
vant Federal public health and environmental
standards, guidance, and advisories.
Alternatives that meet the CERCLA goals of pre-
venting or minimizing present or future migration
of hazardous substances and protect human health
and the environment, but do not attain all ap- .
plicable or relevant standards.
Off-site storage, destruction, treatment, or
secure disposal of hazardous substances at a
facility approved under the Resource Conservation
and Recovery Act (RCRA). Such a facility must
also be in compliance with all other applicable
EPA standards (e.g., Clean Water Act, Clean Air
Act, Toxic Substances Control Act).
Category V - No Action
In accordance with Section 300.68 of the NCP, six alternatives
were identified, described and evaluated based on the following
criteria:
0 Technical criteria: reliability, implementability, operation
and maintenance, and safety
0 Environmental/public health impacts
0 Institutional considerations
0 Cost
-------
-38-
A ground water monitoring program is a component of every alterna-
tive considered, including the no action alternative, and will be
implemented to track the effectiveness of the recommended alterna-
tive. The no action alternative, in fact, consists only of ground
water monitoring.
For all remedial alternatives (except no action), a perimeter fence
would be installed surrounding the on-site disposal area to prevent
site access. On-site debris (tires, abandoned vehicles, "construction
waste, etc.) and RI generated waste would be removed from the site.
Debris would be removed to a staging area, steam cleaned, and wipe
sampled to determine if disposal at a RCRA hazardous waste landfill
is necessary. Vegetation would be removed, reduced to wood chips,
and sampled. . RCRA landfill disposal is not anticipated for either
of these materials and has not been costed.
Another component common to every alternative developed is the
excavation and offsite removal of the surficial soil, the volume of
which is estimated to be 6500 cubic yards. This soil will be either
landfilled or incinerated and'its removal is expected to remove the
major source of contamination.
With these similarities noted, the evaluations of the alternatives
will focus on the differences between them.
Alternative 1
This alternative, shown schematically in Figure 8, involves long-
term extraction of ground water with on-site treatment.
Excavation of surficial soil would be accomplished using conven-
tional excavation equipment. A loading and vehicle wash-down
pad would be constructed at the site. Vehicle wash" water would
be conveyed into the on-site treatment facility. In addition,
portions of Whitesbog-Pasadena Road and City Line Road leading
from the site to U.S. Route 70 would be regraded and a twelve-
inch gravel roadbed constructed. These road improvements are
necessary to accommodate the volume of truck traffic required for
soil removal. Approximately 300 truck loads would be required
to remove 6500 cubic yards of contaminated soil. This material
would be manifested according to RCRA requirements and trans-
ported for incineration and/or landfill disposal at a RCRA
approved facility, in accordance with EPA's Off-Site Policy.
A staging area would be constructed for testing and steam clean-
ing of on-site debris and vegetation. Following decontamination,
these materials would most likely be disposed of at a non-hazar-
dous waste disposal facility. Most contaminants detected in
the subsurface soils have significantly lower Koc values than
-------
SURFICIAL
SOIL
EXCAVATION
GROUNDWATER
EXTRACTION
i
DISCHARGE TO
ATMOSPHERE
I
STRIPPER
OFF-GAS TO
VAPOR PHASE
CARBON
ADSORPTION
GROUNDWATER
TREATMENT
EXCEEDING
FEDERAL
STANDARDS
DISCHARGE
OF EFFLUENT
BY INJECTION
SOIL TO
OFF-SITE
DISPOSAL
OR
INCINERATION
SEDIMENTATION
SLUDGE TO
OFF-SITE
DISPOSAL
SPENT REGENERANT
TO OFF-SITE
DISPOSAL
FIGURE
8
ALTERNATIVE 1
LANG RI/FS
CCJA
-------
-40-
contaminants detected in the surficial soils alone. Considering
the lack of organic matter in the subsurface soils, this suggests
that subsurface soil contamination can be removed via flushing
as the ground water is removed. When contaminant levels in the
extracted ground water approach the treatment process effluent
discharge standards, it can be assumed that contamination in
the soil has been similarly reduced. Pre-design activities
will be conducted to confirm that subsurface soil contamination
can be reduced by flushing.
The preliminary design for the ground water extraction system is
based on two four-inch ID wells, 30 feet deep, each operating at
20 gpm. The system design will be refined based upon the aquifer
test and computer modelling results. Contaminated ground water
would be piped to an on-site treatment system consisting of air
stripping, coagulation, flocculation, sedimentation, carbon
adsorption, and ion exchange followed by pH adjustment by lime
addition.
The RI results indicate no contamination in the ground water
accessed by on-site wells screened at intermediate depths
(30-40 feet). With this in mind, the ground water extraction
wells should be screened above this depth. The exact depth
will be determined during pre-design activities.
The contaminant plume has an estimated volume of 10 million
gallons. This estimate considers soil porosity and assumes a
30-foot depth of contamination. To achieve complete remediation
of ground water and subsurface soils, it is believed that three
times this volume (i.e., 30 million gallons) must be extracted
and treated. This estimate was used in the FS and will be
revised as necessary following pre-design studies, including
leachability testing of contaminated soils.
Off-gases generated by the air strippers would be treated by a
vapor phase carbon adsorption system prior to emission. Sludge
generated by chemical precipitation, flocculation, and sedimen-
tation would be removed for off-site disposal, along with spent
regenerant from the ion exchange unit. Effluent from the
treatment process would enter the pumping station wet well.
Again,, the preliminary design assumes that the water would be
distributed to four four-inch ID injection wells screened above
30 feet. Flow into each well would be metered and controlled
by globe valves.
The ground water extraction, treatment, and injection system
would be operated until the contaminant plume is captured, as
determined by the levels of contaminants detected in the extracted
ground water. Presumably, the system would be operated for one
and one-half years, the time required to remove 30 million gallons
-------
-41-
of contaminated ground water. This volume estimate will be
confirmed following aquifer and leachability testing performed
in conjunction with the ground water extraction system design.
This system, shown schematically in Figure 9, should reduce
contaminant concentrations to levels below Federal, State and
local drinking water and ground water quality criteria (see
Table 9). An onsite treatability study will be included as a
pre-design task to generate data required for the treatment
system design. Treatment system influent concentrations used
for the treatablility study will reflect the highest concentra-
tions detected in any ground water sample during the RI.
Actual treatment system influent can be expected to be signifi-
cantly less concentrated, particularly after the ground water
extraction system is in operation. This system is believed to
represent the best available technology and should be able to
treat effectively the contaminated ground water at the Lang
Property site.
With regard to the environmental/public health evaluation, this
alternative removes the two major sources of contamination at
the site, surficial soil and ground water, to the greatest extent
feasible. Thus, the long-term threats to public health and the
environment should be eliminated or greatly reduced.
Short-term risks may result from the excavation of surficial
soil. The release of volatile organic contaminants and/or
fugitive dust into the atmosphere may also occur. These emis-
sions should not present a significant threat to the public
health or the environment, but would be monitored nevertheless.
Only short-term risks are believed to be associated with trans-
port to an on-site incineration and/or disposal facility of the
contaminated soil, sedimentation sludge, and spent ion exchange
regenerant. A release of contaminated material could result in
public exposure to volatile organics or fugitive dust by dermal
contact or inhalation.
Since off-gases generated by the air stripper will be treated
by vapor phase carbon adsorption prior to discharge to the
atmosphere, it is unlikely that these emissions will present
any risks. Atmospheric monitoring near the treatment system
would ensure that any volatiles still present would be released
at acceptable concentrations.
This alternative reduces the overall long-term threat to public
health and the environment to the greatest extent possible and
is not expected to cause any significant long-term adverse
impacts.
With regard to institutional issues, this alternative would
need to comply with the technical requirements of an Underground
-------
OFF GASES
VAPOR PHASE
CARBON
ADSORPTION
CHEMICAL
ADDITION
OFF GASES
VAPOR PHASE
CARBON
ADSORPTION
INFLUENT
ELEVATED
TEMP
AIR
STRIPPING
(1 TOWER)
COAGULATION
AND
FLOCCULATION
GRANULAR
ACTIVATED
CARBON
ADSORPTION
SEDIMENTATION
ELEVATED
TEMP
AIR
STRIPPING
(2 TOWERS)
SLUDGE
BACKWASH
SLUDGE
HOLDING
TANK
OFF-SITE
SLUDGE
DISPOSAL
LIMElADDlTlON
ION
EXCHANGE
PH
ADJUSTMENT
TO INJECTION SYSTEM
SPENT
REGENERANT
HOLDING TANK
OFF-SITE
DISPOSAL
IGURE 9
ALTERNATIVE
EATMENT PROCESS TRAIN
ING -RI/FS
f CCJA
-------
-43-
Injection Control Permit. Extracted ground water would be
reinjected into the same aquifer and the quality of the water
injected would be equal or superior to that of the aquifer.
The on-site treatment plant would be designed to meet the
technical requirements of Federal and-State air pollution
requirements.
Contaminated surficial soil, sludge from the sedimentation pro-
cess, and the spent ion exchange regenerant will be disposed of
at an approved off-site incineration and/or disposal facility.
This facility would require either a RCRA Part A (Interim" Status)
or RCRA Part B permit and must be in compliance with the EPA's
Off-Site Policy. Some inconvenience to surrounding residents may
occur during removal operations due to increased truck traffic.
Alternative 2
This alternative, shown schematically in Figure 10, is identical
to Alternative 1 except that the on-site treatment facility
would not include an ion exchange unit for sodium removal. The
process would, however, still include air stripping, coagulation,
flocculation, sedimentation, and carbon adsorption. As in
Alternative 1, the system would be operated for an estimated
one and one-half years to remove three times the estimated
quantity of contaminated ground water. This should reduce con-
tamination to levels below the Federal drinking water quality
standards presented in Table 9.
The absence of the sodium exchange unit does not significantly
affect the reliability or implementability associated with
ground water treatment. However, because the sulfuric acid
regenerant required for the ion exchange process does not have
to be mixed and handled, this system is considered safer than
the treatment system discussed for Alternative 1.
With regard to the environmental/public health evaluation, any
short-term risks associated with on-site storage and transport
of the regenerant are eliminated. Without this unit the treat-
ment process cannot remove the elevated sodium concentrations
that were detected in the ground water on-site. However, sodium
has minimal public health and environmental significance at the
concentrations at which it was measured. Moreover, dilution in
the ground water would reduce the concentrations significantly
before any surface waters or human receptors would be encountered.
Risks associated with the other components of this alternative
have already been discussed under Alternative 1.
The institutional constraints imposed by the on-site treatment
processes and off-site disposal of contaminated soil and sludge
would be the same as those described under Alternative 1.
-------
N.
DISCHARGE TO
ATMOSPHERE
I
I [
SURFICIAL
SOIL
EXCAVATION
GROUNDWATER
EXTRACTION
i
SOIL TO
OFF-SITE
DISPOSAL
OR
INCINERATION
STRIPPER
OFF-GAS TO
VAPOR PHASE
CARBON
ADSORPTION
GROUNDWATER
TREATMENT
ATTAINING
FEDERAL
STANDARDS
•
SEDIMENTATION
SLUDGE TO
OFF-SITE
DISPOSAL
DISCHARGE
OF EFFLUENT
6Y INJECTION
FIGURE 10
ALTERNATIVE 2
IANG RI/FS
CCJA '
-------
-45-
Alternative 3
This alternative, shown schematically in Figure 11, involves
extraction, on-site pretreatment and discharge of ground water
to the Pemberton Township Municipal Utilities Authority (PTMUA)
waste water treatment plant. These components replace the
on-site treatment and reinjection of ground water described for
Alternatives 1 and 2. The ground water extraction system is
the same as that described above.
Extracted ground water would be pretreated on-site. The extent
of pretreatment will be determined following toxicity testing
and mass balance calculations. : Effluent from this process would
be discharged to the PTMUA trunk sewer or pump station servicing
Country Lakes Estates. An on-site pumping station and pipeline
would be constructed to transport the effluent to the PTMUA
plant, three miles away.
The proposed force main would run from the Lang Property
along the abandoned Penn Central Railroad right-of-way that pas-
ses south of the site, as shown in Figure 12. As in Alternatives
1 and 2, the system would extract and treat a sufficient quantity
of contaminated ground water to reduce contamination levels
below the Federal drinking water quality standards presented in
Table 9.
The ground water pumping, on-site surficial soil excavation, and
off-site incineration and/or disposal portions of this alterna-
tive are identical to those discussed in the evaluations of
Alternatives 1 and 2. Consequently, the evaluation of technical
considerations is also the same.
Toxicity testing and mass balance calculations are being con-
ducted to provide a preliminary determination of the compati-
bility of the Lang Property waste stream with the POTW treatment
process. Presumably, pretreatment will consist of three elevated
temperature air stripping towers and coagulation, flocculation,
and sedimentation. All system components have proven reliability.
The system required to convey pretreated effluent from the on-
site pretreatment system to the POTW will consist of a small
pump station and a three-mile force main to the PTMUA sewerage
system. Such conveyance systems have been used extensively in
a variety of applications and are considered very reliable.
Implementation of the pipe is along an abandoned railroad
right-of-way.
Regarding the environmental/public health evaluation, this alter-
native also removes the sources of contamination to the same ex-
tent of any of the alternatives previously considered. Accord-
ingly, the long-term threats to public health and the environ-
ment are likewise reduced. As with Alternative 1, some short-
term risks to public health may result from the on-site pre-
treatment of groundwater and excavation of surficial soil.
-------
DISCHARGE
TO
ATMOSPHERE
STRIPPER
OFF-GAS TO
VAPOR PHASE
CARBON
ADSORPTION
SURFICIAL
SOIL
EXCAVATION
GROUNDWATER
EXTRACTION
SOIL TO
OFF-SITE
DISPOSAL
OR
INCINERATION
GROUNDWATER
PRE-TREATMENT
*
SEDIMENTATION
SLUDGE TO
OFF-SITE
DISPOSAL
EFFLUENT
TO POTW
EFFLUENT TO
BRANCH OF
RANCOCAS
CREEK
SLUDGE TO
LAND APPLICATION
FIGURE 11
ALTERNATIVE 3
-------
OK UP TO ^''^jVf/!.
ROUTE OF FORCE MAIN TO PTMUA SANITARY SEWER SYSTEM
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-48-
Pretreatment would ensure that of the influent to the PTMUA
system will not significantly impact POTW operations. Accord-
ingly, the PTMUA treatment plant effluent discharge and sludge
disposal practices should not be affected, nor should the
environmental impacts of these practices increase. Moreover,
effluent discharge will occur outside the environmentally sen-
sitive Pinelands.
Since volatile organic contaminant concentrations should be sig-
nificantly reduced by on-site pretreatment, no serious adverse
environmental or public health impacts due to emissions of gases
are expected during transmission of the discharge through the
PTMUA gravity sewer. Periodic pressure testing and proper oper-
ation and maintenance of the force main should minimize any
risks to the environment presented by the possibility of leakage
from the force main.
Construction of the force main through the Pinelands may produce
some short-term environmental impacts. However, the possibility
of significant adverse environmental effects is reduced by the
presence of an abandoned Penn Central Railroad right-of-way
along the construction route.
With regard to institutional considerations, the excavated sur-
ficial soil must be transporated and disposed of in accordance
with EPA's Off-Site Policy. Disposal of pretreated ground water
to the POTW may require imposition of additional regulatory
requirements by NJDEP through alteration of their NJPDES and
sludge application permits. The future ability of the POTW's
sanitary system to dispose of its sludge by landspreading must
be addressed and agreed to by PTMUA and the regulatory agencies
involved. The PTMUA has expressed serious concern about dis-
charge of site effluent to their plant and have resisted similar
plans in the past.
Alternative 4
This alternative, shown schematically in Figure 13, differs from
Alternative 1 in two major ways. The groundwater volume extracted
will be only 10 million gallons (the estimated volume of the
contaminant plume) instead of 30 million gallons. In addition,
the ground water extracted will be transported to an off-site
treatment facility for disposal.
Extracted ground water would be pumped to a storage and loading
facility. This facility would have a storage capacity of
approximately 180,000 gallons to accommodate the total quantity
of ground water extracted during three days of operation (2
wells x 20 gpm/well x 1440 min/day x 3 days = 172,800 gallons).
The loading facility would be capable of loading two trucks
simultaneously. Seventeen tanker trucks of contaminated ground
water would leave the site each day, five days a week. The
ground water would have to be manifested according to RCRA
requirements and transported to a RCRA approved treatment
facility, in accordance with EPA's Off-Site Policy.
-------
SURFICIAL
SOIL
EXCAVATION
REDUCED
GROUNDWATER
EXTRACTION
GROUNDWATER
TO OFF-SITE
TREATMENT
FACILITY
•
I
SOIL TO
OFF-SITE
DISPOSAL
OR
INCINERATION
FIGURE
13
ALTERNATIVE
4
LANG RI/FS
CCJA
-------
-50-
Unlike Alternatives 1, 2, and 3, this system would be operated
for approximately six months and remove 10 million gallons of
contaminated ground water from the site. This volume reduction
would lessen the potential impacts to public health and the
environment associated with the site. It is unlikely, however,
that this aLternative would reduce contamination levels in the
ground water to below Federal drinking water quality standards.
Extraction well pumps would be shut down periodically to allow
flushing of subsurface soils within the cones of depression of
the extraction wells.
The ground water extraction system used in this alternative is
identical that described for Alternatives 1, 2, and 3. Conse-
quently, the reliability, implementability, and safety aspects
associated with it would be the same as those discussed for the
other alternatives.
In this alternative, on-site treatment is replaced by hauling
the contaminated ground water to an approved off-site treatment
facility. The simplicity of this system, consisting of ground
water storage and loading facilities, makes it highly reliable.
Implementability of this portion of the alternative is considered
moderate, requiring the construction of storage and truck loading
facilities with a total capacity of 180,000 gallons. The safety
factor associated with storage, loading, and hauling of contami-
nated groundwater is considered acceptable. Hazardous materials
are routinely loaded and hauled in various industries. In
addition, as ground water pumping continues, that contaminant
concentrations are expected to decrease.
Technical aspects of on-site surficial soil removal are the same
as those outlined for the three alternatives already discussed.
Therefore, reliability and acceptability of off-site surficial
soil removal are high for this alternative, while safety is
considered acceptable. The high reliability is mainly due to
the absence of a complex on-site treatment system.
As far as the environmental/public health evaluation is concerned,
this alternative will significantly reduce the long-term threats
to public health and the environment posed by the site. Except
for Alternative 6 (the no action alternative), however, it does
not remove contamination from the subsurface soil to the extent
of the other alternatives. Residual contamination may remain
in the subsurface soil and continue to be a source of ground
water contamination. The extent to which contamination will
remain in the subsurface soil is difficult to determine. The
distant downstream location of the nearest receptor suggests
that residual contamination will be significantly diluted
before reaching a receptor. Thus, the threats to public health
and welfare should be reduced to an extent comparable to the
other alteratives. Environmental risks associated with the
site, however, would not be reduced as much, since residual
contamination may remain in the subsurface soils.
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-51-
The on-site handling, storage, and off-site transport of the
ground water for treatment, as well as the excavation and trans-
port of contaminated soils, will present minor short-term risks
to public health and the environment. A release of contaminated
soil or ground water, as previously discussed, could result
in exposure'of the public to volatile organics or fugitive dust
by •dermal contact or inhalation. An environmental advantage of
this alternative is that is does not involve a discharge of
treated ground water within the Pinelands area. Untreated con-
taminated ground water withdrawn from the site and excava-ted
surficial soils must be treated or disposed of at an approved
treatment or disposal facility. Any such facility must operate
under either a RCRA Part A (Interim Status) or RCRA Part B
permit and must be in compliance with the EPA's Off-Site Policy.
Transporters hauling the contaminated soil and ground water to
such facilities would also be required to be permitted under
RCRA and to manifest properly all transportation of hazardous
waste.
Alternative 5
This alternative, shown schematically in Figure 14, is identical
to Alternative 4 except that the ground water would be pumped
for one and one-half years instead of one-half year, thus
removing three unit volumes of contaminated ground water (30
million gallons) rather than one. As such, the technical aspects
of this alternative are identical to those described for Alter-
native 4. As in Alternatives 1, 2 and 3, this volume of ground
water pumping should reduce contamination levels in groundwater
below the Federal drinking water quality standards presented in
Table 9.
Regarding the environmental/public health evaluation, this
alternative reduces the sources of contamination at this site
as much as any alternative considered. The environmental/public
health evaluation is thus similar to that of Alternative 4, with
the exception that this alternative further reduces the threats
posed by the site to the environment by eliminating long-term
releases of contaminants from the subsurface soils.
The institutional constraints imposed by pumping a larger quan-
tity of contaminated ground water would be the same as described
under Alternative 4. From a public perspective, this alternative
may meet with more favorable reaction than other alternatives
because it involves the removal of all contaminated material
from the site for off-site disposal.
Alternative 6
This alternative consists of installing a limited number of
monitoring wells and tracking the migration of the contaminated
ground water plume to ensure that is does not endanger public
health and welfare. This system would have high reliability
and implementability. No remedial actions would be performed
under this alternative.
-------
SURFICIAL
SOIL
EXCAVATION
GROUNDWATER
EXTRACTION
GROUNDWATER
TO OFF-SITE
TREATMENT
FACILITY
I
SOIL TO
OFF-SITE
DISPOSAL
OR
INCINERATION
FIGURE
ALTERNATIVE 5
ILANG RI/FS
IA
-------
-53-
Additional well clusters would be installed downgradient of
the site at shallow and intermediate depths. All wells
would be sampled annually and analyzed for the full Hazardous
Substance List. In addition, six selected wells will be sampled
each quarter and analyzed for volatile organics only.
This alternative does not reduce the current threats to public
health or the environment. Thus, the major exposure routes
associated with the ground water and surficial soil will remain,
as will the potential exposure of humans and animals to contam-
inated surficial soil. This alternative does not meet existing
Federal or State standards for .mitigation of contaminatio'n and
relies on the low health risk posed by the present use and
remote location of the site.
No permits would be required under this alternative. The major
institutional issues would be the adverse responses expected
from some members of the Pinelands Commission and members of
the community who own agricultural lands adjacent to the site.
Because the source of ground water contamination still exists,
to take no action at the site would fail to address the perceived
endangerment of public health and the environment.
IX. COST EVALUATION OF ALTERNATIVES
Cost estimates for each of the alternatives are presented in
Table 10. As discussed earlier, two sets of costs are given
for each alternative to address both incineration and landfill-
ing of surficial soils.
The evaluations of the six alternatives are summarized in Table
11. Rankings are presented for technical, environmental/public
health aspects and institutional criteria. The costs for each
of the alternatives are repeated in this table.
Incineration generally provides complete destruction of wastes
and so achieves a more permanent remedy. However, the cost of
incineration of surficial soils is estimated to be almost ten
times higher than the cost of landfilling these soils.
X. COMMUNITY RELATIONS
The Environmental Protection Agency has conducted numerous com-
munity relations activities in regard to the Lang Property
site. Throughout the RI/FS, EPA has been in close contact with
the Pemberton Township officials, the Burlington County Health
Department, the Pinelands Commission and local residents living
near the site.
Although community concern is relatively low at the site, resi-
dents and local officials expressed a number of concerns during
the public scoping meeting held in April 1985, a public meeting
in August 1986 to discuss the results of the RI/FS, and the
public comment period that extended until September 8, 1986.
These concerns dealt with the following issues:
-------
TABLE
10
COST SUMMARY OF REMEDIAL ALTERNATIVES
(1986 dollars)
Capital
Alternative ($1,000)
Incin.1 |.F2
1
2
3
4
5
' 6
16,226
16,088
16,305
17,514
21,237
9
I
2,460
2,322
2,539
3.747
7,470
9
O&M
($1,000)
629
612
640
119
119
33
Present Worth
f$ 1.000)
Incin. LF
17.3353
17.1753
17.4283
17.8704
21.6683
3255
3.5703
3.4093
3,6623
4.1034
7.9013
3255
1
lndn. denotes Incineration of surficial soil
«LF denotes landfilling
Cost includes operating the system for 18 months and groundwater
.monitoring for 3 years
Cost includes operating the system for six months and groundwater
^monitoring for 3 years
Cost includes groundwater monitoring for 3 years.
Note: Costs of incineration and landfilling are considered as capital
costs and thus the O&M costs do not vary.
-------
TABLE 11
SUMMARY OF EVALUATION AND COST INFORMATION FOR EACH ALTERNATIVE
TECHNICAL PUBLIC"^/!!™ INSTITUTIONAL COST(Jl.OOO)
Perec i vcd
Alternative Reliability Implementation Safety ^glf,"" Environmental H'qJJi'^ents CommunU>
1 medium low low high high medium medium
2 medium low medium high high medium medium
3 high low medium high high low medium
4 high medium medium high medium medium medium
5 high medium medium high high medium high
6 high high high low low medium low
Capital
1 7
Incln. LF'
16,226
16.088
16,305
17.514
21.237
9
2.460
2.322
2,539
3,747
7.470
9
O&M
629
612
640
119
119
33
Present Worth
Incln. LF
17.3353
17.1753
17.4283
17.B704
21 ,6683
3255
3.5703
3.4093
3,6623
4.1034
7.9013
3255
1
Incln. denotes Incineration of surficlal soil
iLF denotes landfilling
]JCost includes operating the system for 18 months and groundwater monitoring for 3 years
,Cost includes operating the system for six months and groundwater monitoring for 3 years
Cost includes groundwater monitoring for 3 years
Note: Costs for incineration and landfilling are considered as capital costs and thus the
04M costs do not vary.
-------
-56-
0 Nature of contamination
0 Environmental standards for remedial cleanup
0 Air quality concerns
0 Cost and schedule of remedial action
0 Potential off-site migration
With regard to specific alternatives, the Pemberton Towns'hip
Municipal Utilities Authority (PTMUA) has expressed its concerns
in detail and stated that it would oppose any alternative that
involves discharge to the PTMUA sanitary sewer system (i.e.,
Alternative 3).
The Pinelands Commission has expressed concern about utilization
of the PTMUA. Their comments address the disruption of the Pine-
lands due to installation of the sewer line, should Alternative
3 be selected.
Other concerns were raised regarding the effect on the Cohansey
aquifer should Alternative 4 or 5 be selected, as both involve
removal of extracted ground water, rather than reinjectipn.
Finally, the Pinelands Commission has raised a general concern
about treatment of ground water to background levels.
As mentioned previously, EPA has responded to all concerns during
the public meetings and in the attached Responsiveness Summary.
EPA believes the selected remedial alternative adequately ad-
dresses the comments and concerns raised by all interested
parties.
XI. RECOMMENDED ALTERNATIVE
EPA hereby selects Alternative 2 as the recommended alternative
for the Lang Property site. As previously described and illus-
trated in Figure 10, this alternative comprises the following
elements:
- Enclosure of the disposal area by a perimeter fence.
- Excavation of contaminated on-site soils to a depth of two
feet (totaling approximately 6500 cubic yards) and removal
of these soils to an approved off-site landfill disposal
facility.
- Extraction of approximately 30 million gallons of ground
water, with treatment and reinjection on-site. Extraction
wells will be utilized and the on-site ground water treatment
system will consist of air stripping, coagulation, floccula-
tion, sedimentation, and carbon adsorption. Spent regen-
erant and sedimentation sludge will be disposed of at an
off-site landfill facility and air stripper off-gases will
-------
-57-
be treated by vapor phase carbon adsorption with eventual
discharge to the atmosphere. The treated effluent will be
pumped to on-site injection wells.
- Removal of on-site debris (tires, abandoned vehicles) and
vegetation to facilitate filling and grading the site in
the future.
- Post-construction operation and maintenance to verify the
effectiveness of this remedy.
The disposal of contaminated soils by landfilling was chosen
instead of incineration due to the excessive costs associated
with incineration. In comparison to the other alternatives,
Alternative 2 w.as chosen based on the following:
"Alternative 2 vs. Alternative 1
Alternative 1 would result in remediation that exceeds Federal,
State, and local requirements. However, exceeding State and
local requirements involves removing sodium, a contaminant
which has no public health or environmental significance at
the levels found at the site. Removal of sodium would cost
approximately an additional $161,000 and the treatment process
would create a significant additional waste stream requiring
off-site disposal. For these reasons, Alternative 2 was more
favorable than Alternative 1.
"Alternative 2 vs Alternative 3
Alternative 3 would involve potential disruption of the PTMUA
treatment plant (which currently has no industrial users) by
pretreated Lang Property effluent, as well as disruption of the
Pinelands by installation of a three-mile force main, which
would only be used for one to three years. The additional
cost associated with this alternative was approximately $253,000
Finally, significant institutional constraints exist for this
alternative in the form of opposition from the PTMUA and the
Pinelands Commission. For these reasons, Alternative 2 was
deemed more feasible than Alternative 3.
°Alternative 2 vs Alternative 4
Alternative 4 was not designed to attain applicable, relevant
and appropriate Federal, State or local requirements. Disrup-
tion of the Pinelands from significant truck traffic and the
permanent removal of approximately 10 million gallons from the
Cohansey Aquifer were of concern, as well. The additional
costs associated with implementing this alternative would be
approximately $694,000. For these reasons, Alternative 2 was
considered preferable to Alternative 4.
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-58-
"Alternative 2 vs Alternative 5
The permanent removal of approximately 30 million gallons of
ground water and the increased disruption of the Pinelands as
a result of the greater volume of truck traffic were of critical
concern. The additional cost of implementing Alternative 5
would be approximately $4.5 million. For these reasons,
Alternative 2 was deemed more appropriate than Alternative 5.
"Alternative 2 vs Alternative 6
Alternative 6 (No Action; would not reduce the public health
and environmental endangerment posed by the contaminants at
the site in current and future land-use scenarios. For this
reason, Alternative 2 was considered more favorable than
Alternative 6.
XII. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Off-site disposal of contaminated soils will be in a hazardous
waste landfill permitted under the Resource Conservation and
Recovery Act (RCRA). The ground water beneath the site will be
remediated so as to attain applicable, relevant and appropriate
Federal public health and environmental requirements. Effluent
from the on-site treatment operation will attain Safe Drinking
Water Act criteria before being reinjected.
The remedial activities for the selected remedial alternative
described are consistent with the technical requirements of State
and local environmental laws for all contaminants except sodium,
cadmium, chromium, and lead. The levels of cadmium, chromium,
and lead will be significantly reduced, however, and the levels
of sodium do not appear to be of significant public health or
environmental consequence. NJDEP has expressed the opinion
that the residual levels of these contaminants will not pose a
constraint in implementing the selected remedial alternative.
All air treatment systems employed on-site will comply with the
technical requirements of NJAC 7:27-16 and 17.
XIII. OPERATION AND MAINTENANCE (O&M)
Operation and maintenance (O&M) will be required as part of the
selected remedial alternative to ensure its effectiveness and
reliability. As shown in Table 10, the O&M costs for Alternative
2 are $612,000. These costs include, but are not limited to,
ground water monitoring as well as operation and maintenance of
the on-site treatment system for the anticipated one and
one-half year duration of the ground water extraction.
-------
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XIV. SCHEDULE
0 09/86 - Record of Decision approval.
0 * - Initiate Pre-Design activities.
0 * - Initiate Design activities.
0 * -'Complete Design activities.
0 * - Initiated construction activities.
0 * - Complete construction activities.
*Pending CERCLA reauthorization or State funding.
XV. FUTURE ACTIONS
Prior to the design of the selected remedial action at Lang
Property, additional work will need to be completed. Additional
work recommended includes a treatability study, an aquifer test,
a leachability test, and the final delineation of the contami-
nant plume.
Treatability Study
A treatability study will need to be performed prior to selection
of the final design parameters for any on-site treatment or pre-
treatment system. The treatability study would be conducted on-
site by setting up a treatability trailer. The selected treat-
ment train will be set up within the trailer and samples would
be collected before and after individual treatment processes.
Various options could be evaluated to determine the optimum order
of the unit processes. Design parameters would be developed to
guide the final design.
Aquifer Testing
A pump test or aquifer test will need to be performed to refine
the selected ground water pumping scheme, especially the injection
system design. Along with the aquifer test, computer modelling
may be utilized, if necessary, to aid in the design of the
extraction wells and injection wells.
Leachability Test
A leachability test will be necessary to refine the length of
time ground water pumping would be required to adequately
remove contamination from the subsurface soils. The leachability
test will consist of obtaining subsurface soil samples from the
contaminated area and flushing with water to determine the num-
ber of pore volumes of water required to remove bound contaminants
from the subsurface soil.
-------
-60-
Final Delineation of Plume
Prior to designing the ground water extraction system, a final
delineation of the contaminant plume will be made. This deline-
ation will allow for proper placement of the extraction wells to
ensure that the entire contaminant plume is captured. Additional
monitoring wells will probably have to be installed northwest
of the leading edge of the plume.
These pre-design activities will be conducted according to the
schedule provided, as will the subsequent remedial activities
described in this Record of Decision.
-------
FINAL RESPONSIVENESS SUMMARY
TO THE
DRAFT FEASIBILITY STUDY REPORT
LANG PROPERTY SITE
PEMBERTON TOWNSHIP, BURLINGTON COUNTY
NEW JERSEY
Public Ccmnent Period
August 18 to September 8, 1986
From August 18 to September 8, 1986, the U.S. Environmental
Protection Agency (EPA) held a public comment period on the draft
feasiblity study report on alternatives to clean up hazardous
waste contamination at the Lang Property site located in
Pemberton Township, Burlington County, New Jersey. This
responsiveness summary provides highlights of community
involvement and EPA community relations activities at the site
during the remedial investigation and feasibility study (RI/FS).
In particular, the document summarizes community relations and
technical concerns about the draft feasibility study expressed by
residents, local officials, and other interested parties.
The responsiveness summary is divided into four sections:
Section A. BRIEF HISTORY OF THE LANG PROPERTY SITE. This Section
provides an overview of the Lang Property site.
Section B. BACKGROUND ON COMMUNITY INVOLVEMENT AND COMMUNITY
RELATIONS ACTIVITIES AT THE LANG PROPERTY SITE. This
section describes community interest in the Lang
Property site. In addition, both formal community
relations activities and other public involvement at the
site during the RI/FS are described.
Section C. SUMMARY OF QUESTIONS AND COMMENTS RECEIVED BY EPA AND
EPA RESPONSES DURING THE PUBLIC COMMENT PERIOD. This
section concisely summarizes key questions and comments
voiced by interested residents, State officials,
Pinelands Commission staff, local officials, and other
interested parties. Questions and comments provided via
written and/or verbal communication with EPA about the
draft feasibility study are included in this section.
-------
-2-
Section D. SUMMARY OF OUTSTANDING COMMUNITY CONCERNS AND EPA'S
RESPONSES. This section summarizes outstanding
community concerns about the remedial alternatives being
considered for the site. The concerns are described to
assist EPA in planning community relations activities
during the remedial design and construction of the
selected remedial alternative. In addition, this
section includes EPA's responses to these outstanding
concerns.
A. BRIEF HISTORY OF THE LANG PROPERTY SITE. The Lang Property Site
covers forty acres of land in a sparsely populated, rural area of
the New Jersey Pinelands National Preserve in Pemberton Township,
Burlington County. Several residential and agricultural
properties are located on City Line Road in the vicinity of the site.
Edward and Florence Lang purchased the Lang property in 1970. In 1975,
approximately 1,500 drums containing hazardous wastes were discovered
on a two-acre clearing on this property.
The New Jersey Department of Environmental Protection (NJDEP) filed
suit against the Langs in September 1975. In December 1975, the
Superior Court of New Jersey issued a final order requiring the Langs
to remove the hazardous waste, drums, contaminated soil and water from
their property and dispose of the materials at an approved disposal
facility. Between February and April 1976, the Langs contracted to
.have the drums and some contaminated soils removed from the site. A
series of investigations by NJDEP and the Burlington County Health
Department showed .that contaminated ground water and soils remained on
the site. As part of a Consent Order with NJDEP, the Langs hired a
contractor to conduct a ground water study. This study showed that the
ground water was significantly contaminated and required further
investigation. The site was placed on the National Priorities List in
December 1982.
After evaluating and consolidating existing investigation results, EPA
began an RI/FS in April 1985 and completed the draft feasibility study
in August 1986. EPA held a public comment period on the draft
feasibility study from August 18 to September 8, 1966.
B. BACKGROUND ON COMMUNITY INVOLVEMENT AND COMMUNITY RELATIONS ACTIVITIES
AT THE LANG PROPERTY SITE. Nearby residents living near the site and
farmers cultivating blueberries and cranberries in the vicinity of the
site initially became aware of hazardous waste on the Lang's property
as a result of the lawsuit filed by NJDEP against the Langs in
September 1975. Local newspapers described the court action against
the Langs. In addition, several newspaper articles focused on concern
by nearby residents about potential health effects to people and
vegetation from hazardous waste contamination from the site.
-------
-3-
Priot to the RI/FS, one fanner, whose wooded property is adjacent
to the site and a member of the Pinelands Commission, expressed
concern about potential contamination of his cranberry bogs and
private drinking water wells in the vicinity of the site. A
nearby resident complained that the State was not moving quickly
enough to clean up the site, in addition, this resident alleged
that a house had been relocated onto the Lang's property. The
local solicitor and the Pinelands Commission, which regulates
construction in the Pinelands, investigated the construction on
the property. (During EPA's initial site visit, in November 1984,
EPA found that the structure that had been moved to the site
appeared to be unused and uninhabitable.) Meanwhile, the
Pinelands Commission, the Burlington County Health Department, and
the Peraberton Township Environmental Commission (no longer active)
expressed interest and a desire for more information about the
Lang Property site.
A community relations plan was prepared for the Lang Property site
in January 1985. Although community concern was low at the site,
the plan stated that residents and local officials were concerned
generally about hazardous waste in the Pinelands and its potential
impact on ground water in the area. The plan also noted that
local officials believed that most citizens thought that the Lang
Property site had been cleaned up or had forgotten that
contamination remained at the site.
In April 1985, EPA held a public scoping meeting at the Pemberton
Township Municipal Building to provide: (1) an overview of the
Superfund program; (2) a background history of the site; and (3) a
description of the RI/FS activities. EPA distributed a meeting
agenda, a four-page fact sheet which included a detailed site map,
and a Superfund Program brochure. Approximately thirty-five
people attended the meeting. Participants at the public scoping
meeting expressed concerns about the following:
o Potential ground-water and surface-water contamination;
o Nature of contamination at the site;
o Environmental standards and selection criteria for
remedial cleanup;
o Sampling methodology, site access, and schedule of
activities;
o Economic impact on nearby residential and commercial
properties; and
o Information dissemination and community relations
activities.
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-4-
EPA responded to these community questions and concerns at the
meeting. A summary of the public meeting was prepared following
the session.
The remedial investigation field work was conducted between May
1985 and July 1986. NJDEP visited the site frequently to observe
the remedial investigation activities. NJDEP.and EPA notified the
Burlington County Health Department and the Pinelands Commission
staff about the remedial investigation schedule. Representatives
from the Burlington County Health Department and the Pinelands'
Commission staff visited the site to obs erve sampling and ask
questions about field techniques and the RI/FS schedule.
Two interested farmers cooperated with EPA during the field
activities- One fanner who is currently leasing property from the
Langs for blueberry cultivation regularly observed the field tests
and informally assisted EPA with security during the remedial
investigation by ensuring that the security gate was locked and
people did not enter the area. A second fanner who tends
cranberry bogs near the site, now a former member of the Pinelands
Commission, provided access to. his property and allowed EPA to
install an upgradient monitoring well to confirm the direction of
ground-water flow and collect water quality samples. Both farmers
expressed interest in the results of the remedial investigation.
In particular, the fanners were interested in the potential
contamination of ground water and soils in the vicinity of the
site and the impact on vegetation grown in the area.
The Pemberton Township Municipal Utilities Authority (PTMUA) was
contacted by EPA and EPA contractors to collect information for an
evaluation of a remedial alternative which would involve
transporting pretreated waste water from the site for disposal at
the PTMUA waste water treatment plant. PTMUA officials contacted
EPA prior to the public comment period to express concern about
the proposed remedial alternative that included using PTMUA
facilities (see page 7 for a description of PTMUA's concern about
receiving the pretreated hazardous waste). PTMUA provided data to
and has cooperated with EPA during the preparation of the draft
feasibility study report.
During the RI/FS, EPA maintained four information repositories in
the vicinity of the site. The information repositories included:
(1) Pemberton Township Administrator's Office; (2) Pemberton
Township Public Library; (3) Burlington County Health Department;
and (4) Pinelands Commission.
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-5-
On August 18, 1986, EPA began its public comment period on the draft
feasibility study report. A press release was sent to notify
interested citizens about the public comment period and availability of
the RI/FS reports in the information repositories. On August 21, 1986,
EPA met with the Pinelands Commission staff and the Pemberton Township
Municipal Untilities Authority. Although invited by EPA, Burlington
County Health Department was unable to attend.
On August 25, 1986, EPA conducted a public meeting at the Pemberton
Township Municipal Building. Approximately twenty-two nearby
residents, local and county officials, an NJDEP official, and other
interested citizens were present at the session. (Attachment A provides
a list of meeting participants; Attachment B provides a meeting agenda;
and Attachment C provides a fact sheet.) EPA closed its public comment
period on September 8, 1986.
SUMMARY OF QUESTIONS AND COMMENTS RECEIVED BY EPA AND EPA RESPONSES
DURING THE PUBLIC COMMENT PERIOD ON THE DRAFT FEASIBILITY STUDY REPORT
ON THE LANG PROPERTY SITE. The interested public provided questions
and comments to EPA on the Lang Property site draft feasibility study
report during the public comment period. Written comments were
submitted by the following interested parties:
o New Jersey Department of Environmental Protection;
o Pinelands Commission; and
o Pemberton Township Municipal Utilities Authority.
Approximately twelve individuals including Pemberton Township officials
and residents provided verbal questions and/or comments at the pubic
meeting.
Questions and concerns about the Lang Property site draft feasibility
study are summarized in the following categories:
o Remedial alternatives;
o Standards for cleanup;
o Air quality concerns;
o Potential migration of contamination away from the site;
o Cost and schedule of remedial action; and
o Related illegal hazardous waste disposal sites and potentially
responsible party involvement.
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Key questions and concerns about the draft feasibility study and EPA
responses are provided in the remainder of this section.
Remedial Alternatives
Question; Pemberton Township officials and residents living in the
vicinity of the site asked whether EPA had selected a remedial
alternative for the Lang Property site.
Response; EPA stated that a remedial alternative would be
selected following an evaluation of the public's written and
verbal comments. EPA will approve a Record of Decision that will
describe the selected remedial action at the site. EPA said that
the "no action" alternative would not be selected because "no
action" does not mitigate the threat to the environment and public
health posed by the site. The other alternatives all include
excavation of the surficial soil (soil located from the surface of
the ground to approximately three feet below the ground) with
off-site disposal and ground-water extraction and treatment. EPA
said, however, that alternatives 1 or 2 are more likely to be
selected than any of the'other alternatives. These alternatives
are described as follows:
Alternative 1 exceeds Federal standards. The remedial
alternative includes:excavation of surficial soils and
removal to an off-site disposal facility; extraction and
treatment of ground water with ion exchange, a process which
reduces sodium by attracting sodium ions out of the waste
water; and on-site injection of ground water.
Alternative 2 meets Federal standards. Similar to Alternative
1, the remedial alternative includes excavation of surficial
soils and removal to an off-site disposal facility; and
extraction of ground water, treatment, and injection. This
remedial alternative does not include ion exchange.
Concern: The Pinelands Commission said that since the Pinelands
Commission does not permit discharge to any surface water in the New
Jersey Pinelands National Preserve, the Pinelands Commission prefers
Alternatives 1 and 2. The Pinelands Commission stated that its major
concerns include: (1) remediation of ground water to the greatest
extent possible; and (2) no impact on surface water during the
remediation effort.
Response; EPA responded to the Pinelands Commission's concerns
about surface water discharge in the early stages of the
preparation of the draft feasibility study. EPA is not
considering discharging treated waste water into surface water in
the vicinity of the site as part of the remedial action at the
Lang Property site due to both technical and institutional
constraints.
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Concern; PTMUA stated that it supports remedial alternatives 1 and
2. PTMUA objected to the consideration of Alternative 3. (See
description of alternative below.) PTMUA raised concerns about
technical and institutional constraints on its ability to accept
Superfund pretreated hazardous waste under the requirements of
Alternative 3. Currently, PIMUA accepts only municipal waste; it has
no industrial users. The facility disposes of its sludge by applying
it to agricultural land designated for waste disposal. PTMUA believes
that the land application of sludge must be further evaluated to
determine whether the treated hazardous waste sludge will be compatable
with what the facility currently accepts. In addition, PTMUA said that
as a publicly owned treatment works, regulations concerning treated
waste water discharge into the north branch of the Rancocas Creek will
require modifications to the PTMUA's existing permit. PTMUA expressed
concern that the permit modification would be a lengthy process which
might delay the remedial action.
(Note: Alternative 3 includes the excavation of surficial soils and
removal to an off-site disposal facility; and extraction of ground
water. The ground water is pretreated, then transported to the PTMUA
waste water facility for final treatment and disposal. Under this
remedial alternative, PTMUA would discharge the treated waste water
into the north branch of the Rancocas Creek and apply the sludge to
land designated for waste disposal.)
Response; EPA said that it recognizes the technical and
institutional constraints on the PTMUA accepting pretreated
ground water from the site. EPA has evaluated these
constraints during the RI/FS.
Concern; PTMUA expressed concern that the draft feasibility study
did not adequately consider in the evaluation of the effluent
discharge collection system included in Alternative 3, the
potential risk to the environment and public health which might
result from a leak or blockage of pretreated hazardous waste.
Response; EPA recognizes the PTMUA concern about potential
adverse impacts to the environment and public health if the
collection system did not operate properly. EPA will include
an evaluation of this concern in the final feasibility study
report.
Concern; PTMUA stated that costs for implementation, operation,
and maintenance of the effluent discharge collection system to
PTMUA were not included in the cost summary in the draft
feasibility study report. PTMUA provided an estimate of capital
and other costs to EPA for consideration.
Response; EPA stated that these costs will be evaluated and
incorporated in the final feasibility study.
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Question: A local official asked about the volume of ground water
proposed to be pumped and injected into the site. The local
official asked EPA to clarify the volume of water estimated to be
extracted from the site.
Response; EPA stated that approximately ten million gallons
cf ground water would be pumped, treated, and injected into
the ground. This extraction, treatment, and injection would
be repeated three times (totalling thirty million gallons).
The ground water will be treated to meet or exceed Federal
drinking water standards. EPA said that the contractor has
estimated that three cycles of pumping, treatment, and
injection will be required to remove the contamination. EPA
will monitor the level of contaminants in the ground water
during the remedial action to ensure that the site meets
these standards.
Question; A nearby resident asked EPA to explain what the impact
will be on private water wells surrounding the site from the
extraction and injection of a large volume of ground water under
Alternatives 1 and 2.
Response: EPA does not anticipate an adverse impact on
private water wells in the vicinity of the site because
ground water is continuously being returned to the aquifer
from which it is being pumped. EPA stated that the potential
impact on surrounding private water wells will be carefully
evaluated during the remedial design phase prior to
construction of the project.
Question: A local official asked how the contamination in the
subsurface soils will be eliminated since only the surficial soils
will be excavated and removed from the site.
Response; EPA said that contaminants in the subsurface soils
will be removed by flushing the soils with the treated ground
water which will be injected into the site. Because
contaminants in the subsurface soil are more mobile than
contaminants in the surficial soil, repeated flushing of the
subsurface soil with the treated or clean ground water will
remove the soil contamination from below the excavated layer.
Concern; A resident living in the vicinity of the site expressed
concern about the capacity of City Line Road to support the amount of
truck traffic required to haul the excavated surficial soils away from
the site. The resident said that the existing road was made of dirt
and too narrow for vehicles to pass.
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Response; EPA stated that the capacity for additional truck
traffic on City Line Road will be further evaluated during the
remedial design to determine whether the road was adequate to
support construction activities. EPA said that the draft
feasibility study recommended that gravel be placed on the road to
improve its surface and help support the additional truck traffic
during a three month excavation period.
Standards for Cleanup
Comment! Hie Pinelands Commission stated that the Pinelands Commission
would like the ground water to be treated to background levels, or as
close to background levels as possible given the limits of existing
technology.
Response; EPA explained that because background levels are
determined by laboratory analysis based on arbitrarily selected
detection limits of contaminants, background levels do not provide
well-defined criteria to measure whether an area has been cleaned
of contamination. EPA relies on state and Federal standards to
determine whether water quality is acceptable. The remediation
criteria are included in Table 3-1 in the draft feasibility study
report. EPA will use the best available technologies and
processes to clean up the contamination at the site. In addition,
EPA will monitor the site to ensure that the water quality meets
State and Federal standards.
Comment; NJDEP provided EPA with revised State remediation criteria
for a number of chemical substances.
Response; EPA will evaluate these criteria in terms of the
treatment processes required in Alternatives 1 and 2.
Question: A resident asked how significantly the ground water and
soils at the Lang Property site were contaminated.
Response; EPA said that the monitoring wells located on the site
showed ground-water contamination of total volatile organics of
88,500 ppb (parts per billion). EPA said that the ground water at
the site was significantly contaminated compared to New Jersey
guidelines of 50 ppb for total volatile organics in ground water.
Because State and Federal standards do not exist for soils, to
ascertain the relative degree of soil contamination on the site
EPA compared concentrations of contaminants in the soil on the
site with soil located away from the site. Based on this
parameter and others, EPA found significant contamination in the
on-site soils.
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Air Quality Concerns
Question; A resident asked if toxic gases could be released
unexpectedly from the site.
Response; EPA said that air monitoring was conducted at the site
during the RI/FS. The air monitoring conducted during the field
activities showed that no release or threat of hazardous air
emissions from the site is expected except during excavation or
other activities which might disturb the soils. During soil
excavation, EPA will carefully monitor the ambient air to ensure
that workers and residents in the vicinity of the site are not
threatened during construction activities.
Question; A resident asked how EPA will control dust at the site
during soil excavation.
Response; EPA stated that air monitoring will be conducted during
the soil excavation activities. If there is a threat of hazardous
air emissions, EPA will provide dust protection and controls if
necessary.
Potential Migration of Ground-water contamination away from the site
Question; A resident asked whether EPA had tested the private water
well at the gun club located in the vicinity of the site and at other
off-site locations.
Response; EPA stated that the ground-water monitoring program
during the remedial investigation had determined the direction of
ground-water flow. EPA placed a monitoring well between the
contaminated area and the closest potable water well (a well used
during the blueberry harvest). The monitoring well sampling
results showed no contamiation. Since the potable wells in the
immediate area are upgradient from the site (not in the direction
of ground-water flow), no threat to private water well supplies or
residents exists due to contamination at the Lang Property site.
Question; A local official asked if contamination at the site
threatened existing blueberry fields and cranberry bogs.
Response; EPA responded that the cultivated fields located
downgradient from the site are more than one half mile away from
the areas of contamination. In addition, the Food and Drug
Administration (FDA) sampled blueberries and cranberries in the
area. FDA test results showed that hazardous waste contamination
at the site had not affected nearby fruit crops. In addition, EPA
reviewed the existing scientific literature on contaminants
(specifically those identified at the Lang Property site) being
taken up by plants. EPA determined that it is unlikely that
plants in the area will be affected by contamination at the site.
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Cost and Schedule of Remedial Action
Question: A local official asked EPA how much the remedial action at
the site will cost and how long the remedial action will take to
complete.
Response; EPA said that the remedial action will cost
approximately $4 million. EPA stressed, however, that the cost is
an estimate with a margin of error based on varying construction
costs and possible design changes. In addition, EPA explained
that costs for a remedial action are not fixed. The cleanup will
take between three and five years and costs may vary over time.
EPA also said that construction activities will be competitively
bid to contractors which might affect the cost of construction.
Question: A resident asked whether Pemberton Township will incur any
costs for the cleanup of the site.
Response; EPA responded that 90 percent of the cleanup funds are
paid by the Federal government; 10 percent are paid by the State.
EPA said that Pemberton Township will not be expected to incur any
cost for clean up of the site. EPA also said, however, that
municipalities sometimes choose to expend local tax dollars when
the municipality determines that they want to become more involved
in the construction activities at the site.
In other cases throughout the State, municipalities have decided
to have a local health officer monitor the site on a weekly or
monthly basis. The cost of the health officer's salary is paid by
the individual municipality. In other instances, municipalities
have decided that additional security is required to protect
nearby residents. These municipalities have paid for increased
police protection at sites. Some municipal costs may be
reimbursed by the State under the Hazardous Waste Spillfund
Program, a New Jersey funding mechanism available to clean up
hazardous waste, if the reimbursement request meets the State
criteria.
Question; A resident asked whether funding for remedial design and
construction activities was available to complete the project.
Response; EPA explained that the Superfund program is currently
not reauthorized and therefore Federal funds are not immediately
available to begin the remedial design and construction activities
at the site. EPA said that if the Super fund program is not
reauthorized in the near future, the State of New Jersey may
consider loaning EPA funds from the Hazardous Waste Spillfund
Program. The State of New Jersey has loaned EPA funding for
remedial design and construction activities at other sites in the
State including: D'Imperio site; Bridgeport site; Krysowaty Farm
site; and Bog Creek Farm site.
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Related Illegal Hazardous Waste Disposal Sites and Potentially Responsible
Party Involvement
Concern; A local official expressed concern that EPA and the
State did not know where the hazardous waste containers from the
Lang Property site were disposed. The local official asked
whether EPA had investigated areas of potential concern that had
been identified by the Burlington County Health Department and
nearby residents.
Response; EPA stated that no manifests recording the
disposal locations of the hazardous waste containers from the
Lang Property site were available to EPA or the State. EPA
is presently evaluating possible disposal areas by conducting
a preliminary assessment/site inspection (PA/SI) for at least
three properties identified as having allegedly received Lang
Property hazardous waste containers. These properties
include: Uncle Property; Pointsett Property; and Buster's
Garage.
Question; A local official asked if the drums from the Lang
Property site are found on another property, would this new area
become part of the Lang Property site or a separate site.
Response; EPA responded that if drums from the Lang Property
site were discovered on another property, the property would
be evaluated as a separate potential site. EPA explained
that every site has its own characteristics and requires an
independent assessment to determine whether a threat to
public health or the environment exists. EPA would, however,
consider the discovery of abandoned drums from the Lang
Property site as part of its ongoing enforcement action to
determine responsibility and liability for illegal disposal
of waste.
Question; An interested citizen asked whether the potentially
responsible party at the Lang Property site would regain the use
of the property following cleanup of the site.
Response; As part of its enforcement activities, EPA is
currently evaluating the ability of potential responsible
parties to contribute to the long-term cleanup of the site.
Part of this evaluation will include determining the ultimate
control of the site once the remedial action is completed.
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D. SUMMARY OF OUTSTANDING COMMUNITY CONCERNS AND EPA'S RESPONSES
Concern about Remedial Alternatives -
Concern; PTMUA. opposes Alternative 3. PTMUA has informed EPA that
FittUA is not interested in accepting Superfund hazardous waste for
treatment and disposal.
Response; EPA will evaluate all the constraints with regard to
sending the pretreated ground water to PTMUA prior to selecting a
cleanup alternative. Unless injection of treated ground water as
described in Alternatives 1 and 2 (see page 6 for a description of
Alternatives 1 and 2) is shown to be unacceptable, EPA will not
choose Alternative 3.
Concern about Remedial Design and Construction Activities
Concern; Pemberton Township and Burlington County Health Department
officials maintain a strong sense of cooperation and involvement with
EPA in the cleanup of hazardous waste in the area. These officials
will expect regular and timely.information about the status of the
remedial design and construction activities at the Lang Property site.
Local officials want to be kept informed about results from
ground-water and soil sampling activities.
Response; EPA will contact Pemberton Township and Burlington
County Health Department officials on a regular basis to inform
them of current and proposed site activities. In addition, EPA
will provide an ongoing information contact and schedule of
activities. EPA will also ensure that Pemberton Township and
Burlington County Health Department officials receive data from
ground-water monitoring wells and soil sampling during the
cleanup.
Concern; Residents living in the vicinity of the Lang Property site
remain interested and concerned about the remedial design and
construction activities at the site. Property owners located on City
Line Road expressed concerns about the capacity of the access roads to
support increased truck traffic during the excavation of surficial
soils from the site. In addition, residents may have concerns about
noise and dust from the excavation of surficial soils.
Response; EPA will continue a community relations program at the
Lang Property site to provide information to nearby residents
about remedial design and construction activities. EPA will
invite interested citizens in Pemberton Township to attend an
information meeting prior to initiating construction activities to
describe these proposed activities, provide a schedule, and answer
questions. In addition, EPA will coordinate closely with the U.S.
Army Corps of Engineers to ensure that concerns and questions from
residents are heard and responded to by government agencies during
construction activities.
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Potential Migration of Contamination Away from the Site
Concern; Farmers cultivating blueberries and cranberries in the
vicinity of the site will continue to have an interest in whether
contamination at the Lang Property site has been cleaned up. These
farmers have indicated a desire to receive sampling results and
analysis from vegetative tests and ground-water monitoring conducted at
the site.
Response; EPA has provided the results of previous testing in
both the remedial investigation and feasibility study reports.
These data show that contamination has not migrated away from the
site and, therefore, fruit crops in the area have not been
affected. EPA will provide additional data as it is collected and
analyzed during the remedial design and construction of the
selected remedial alternative.
Related Illegal Hazardous Waste Disposal Sites
Concern; Local officials, Pinelands Commission staff, and residents
remain concerned about other areas in the township which may have
received hazardous waste from the Lang Property site.
Response; EPA will keep interested citizens informed about
ongoing evaluations of properties which have been identified as
having possibly received hazardous waste from the Lang Property
site.
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ATTACHMENT A
PLEASE SIGN IN
Public Meeting
Lang Property Site Municipal Bldg,
August 25, 1986
PLEASE PRINT NAME
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ATTACHMENT B
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
AGENDA
Public Meeting
Lang property Site
Municipal Building
Pemberton Township, New Jersey
August 25, 1986
7:30 P.M.
Introduction
II. Overview of the Superfund
Pr og r am
III. Discussion of the Results of
the Remedial investigation
Report & Draft Feasibility
Study
John Czapor, Chief
Site Compliance Branch
U.S. EPA Region 2
John Czapor, Chief
Site Compliance Branch
U.S. EPA, Region 2
Perry Katz, Project Manager
Lang Property Site
U.S. EPA, Region 2
Edward Hagarty
Project Engineer
C.C. Johnson Associates
(Consultants to EPA)
IV. Questions & Answers
IV. Closing
OTHER REPRESENTATIVES
Kevin Psarianos, Site Manager
Division of Hazardous site
Mitigation
N.J. Department of
Environmental Protection
Rachel Pohl, Community
Relations Specialist
ICF, Incorporated
(EPA's Consultants)
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&.
ATTACHMENT C
**.N.Y. 10278 t*i«">
!>EPA Environmental Facts
LANG PROPERTY
PEMBERTON TWP./BURLINGTON COUNTY
STATUS ADVISORY
Evaluation of Remedial Alternatives
SITE DESCRIPTION
The Lang Property site is located in Pemberton Township,
Burlington County, New Jersey. The site is 8 miles southeast
of the Borough of Pemberton and south of New Jersey State
Route 70. The 40-acre tract of land is rectangular in shape
and is owned by Edward and Florence Lang. Access to the
property is via an unpaved road which branches from another
unpaved road located close to the southern boundary of the
property. Restrictions to public access to the property
are minimal.
The property is situated within the Pinelands National Preserve.
This tract of land supports a forest of small pine trees and fields
which had previously been used for cultivating cranberries and
to a lesser extent, blueberries* A hunting and fishing lodge
had been operated on another portion of the property, but this
facility was destroyed by fire and only the foundation remains.
A clearing at the end of the site's access road was used as a
dumping area for old tires, abandoned automobiles, furniture,
and appliances.
NATURE OF PROBLEM
Portions of the Lang Property were used for the illegal dumping
of 55-gallon drums containing hazardous waste materials of
unknown origin and composition. It has been estimated that
between 12UU and 15CO drums were at one time located at the
site. It is thought that the contents of these drums were
the source of all subsequent contamination occurring at the
site.
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C-2
The site apparently became contaminated as a result of one
or more of the following events: a) inadvertant leakage of
wastes from drums left at the site, b) inadvertant spillage of
wastes onto the ground's surface during early attempts by site
owners to remove drums from the site or, c) intentional emptying
cf drun contents prior to removing drums from the site.
The Remedial Investigation and Feasibility Study (RI/FS) began
in October, 1984. A draft RI/FS was completed in July, 1986.
CONCLUSIONS OF REMEDIAL INVESTIGATION
1. Surficisi scils (1-3 feet) in a two acre portion of the four
acre clearing where disposal took place are contaminated with
volatile organic compounds and metals. Vertical contamination
of soils in portions of the site known to contain chemical
pollutants was limited to a maximum depth of twenty feet.
2. Surface water and, sediment samples collected from areas of
ponded water within the on-site disposal area were contaminated
with volatile organics as were samples collected from a
location along the ditch draining the site. This ditch was
in a position to receive surface water draining from the on-site
disposal area.
3. Shallow groundwater beneath the on-site disposal area is con-
taminated by volatile organic compounds and metals. Although,
this contaminated groundwater plume could have limited concen-
tric migration, its migration is principally in a northwesterly
direction and contaminants have migrated approximately three
to five hundred feet from the disposal area. Groundwater below
a depth of thirty feet shows no signs of contamination.
4. Based on a review of site conditions, toxicological information
regarding plant uptake of pollutants, and sampling of blueberries
in close proximity to the site, there is no evidence of contami-
nation of nearby blueberry and cranberry fields due to the
Lang Property site.
5. There is no evidence of contamination of air at the Lang Property
site.
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C-3
FEASIBILITY STUDY
A draft Remedial Investigation/Feasibility Study (RF/FS), which
evaluated remedial alternatives was completed for the Lang
Property Site in July, 1986. A comprehensive list of remedial
technologies was screened in accordance with EPA guidance and
criteria (technical, environmental and public health, institutional
and cost criteria were considered). The results of the -screening
procedure identified the feasible remedial alternatives which
are outlined below:
ALTERNATIVES:
Alternative 1
Excavation and off-site disposal of surface (1-3 feet) soils,
collection and treatment(exceeding Federal standards) of groundwater,
injection of treated groundwater back into the site.
Alternative 2
Excavation and off-site disposal of surface (1-3 feet) soils,
collection and treatment (attaining Federal Standards) of
groundwater, injection of treated groundwater back into the site.
Alternative 3
Excavation and off-site disposal of surface (1-3 feet) soils,
groundwater extraction and pre-treatment, effluent piped to
the Pemberton Township Municipal Utilities Authority with eventual
effluent discharge to the North Branch of the Rancocas Creek.
Alternative 4
Excavation and off-site disposal of surface (1-3 feet) soils,
minimal volume groundwater extraction and shipment of groundwater
to an off-site treatment facility.
Alternative 5
Excavation and off-site disposal of surface (1-3 feet) soils,
groundwater extraction and shipment of groundwater to an off-site
treatment facility.
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C-4
Alternative 6
No action, installation of additional monitoring wells and
groundwater monitoring.
PUBLIC COMMENTS:
Written comments will be accepted throughout the three week public
comment period which ends on September 8, 1986. All comments
regarding the evaluation of remedial alternatives will be considered
in determining our final selection of a remedial alternative for
the Lang Property site. Comments should be forwarded to:
Mr. Perry Katz
New Jersey Site Compliance Branch
U.S. Environmental Protection Agency
26 Federal Plaza, Room 737
New York, New York 10278
FOR FURTHEIT INFORMATION;
For further information concerning the proposed CERCLA action at
the Lang Property site, contact EPA's Superfund Information toll-free
line by calling Rick Wice at l-(800)-346-5009.
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