United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/068
September 1986
&EPA
Superfund
Record of Decision
Kin-Buc Landfill, NJ
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JQ272-1Q1
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/068
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
in-Buc Landfill, NJ
irst Remedial Action
SUP
5. Report Date
09/30/88
7. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, s.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The 220-acre Kin-Buc Landfill consists of a number of inactive industrial and
municipal waste disposal areas and is located in the Raritan River 100-year flood plain
and within a coastal zone in Edison Township, Middlesex County, New Jersey. Bordering.
the site is an industrial park directly north, the Edison Township Municipal Landfill
600 feet to the south, marshlands to the east, and the Raritan River bordering the
est. Land use within one mile of the site includes residential, light industrial, and
ecreational areas. Landfill operations were conducted between 1947 and 1977. Details
n the owners/operators of the side are unknown prior 1968 when Kin-Buc, Inc. leased the
area from Inmar Associates. According to site records, an estimated 70 million gallons
of liquid wastes, including 3 million gallons of oily waste and over 1 million tons of
solid waste, were disposed of between 1973 and 1976 alone. Examples of wastes received
include solvents, waste oils, paint sludges, cyanides, metal stripping wastes and paint
thinners. The Kin-Buc site includes three major mounds: Kin-Buc I (30 acres), Kin-Buc
II (12 acres) which lies directly north of Kin-Buc I, and Mound B (9 acres) which lies
southwest of Kin-Buc I adjacent to the Raritan River. Additionally, three pits of black
oily leachate, Pits A, B, and C, are located at the southeastern edge of Kin-Buc I;
there is a refuse-filled low-lying area between Kin-Buc I and the Edison Landfill; and
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Kin-Buc Landfill, NJ
First Remedial Action
Contaminated Media: air,
gw, sediments, sw
Key Contaminajits: VOCs, organics, metals (lead), PCBs
K Identrtiars/Open^Ended Terms 3
f
c. COSATI Field/Group
Availability Statement
19. Security- Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
44
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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A/ROD/R02-88/068
f(in-Buc Landfill, NJ
First Remedial Action
16. ABSTRACT (continued)
an area of impounded, tidally affected water, Pool C, contaminated by Kin-Buc I" is
adjacent to the pits. Site activities included burying and compacting contained wastes
in Kin-Buc II, and discharging hazardous liquid wastes into bulldozed pits at the top of
Kin-Buc I. These practices resulted in numerous citizen complaints, caused frequent
major onsite fires and a number of serious occupational injuries. EPA began
investigations in January 1976 and detected the discharge of hazardous substances from
the facility. In February 1980, EPA began cleanup activities consisting of collection,
treatment, and disposal of Pool C leachate; a drum reduction program; oily-phase
leachate collection and onsite storage; and aqueous-phase leachate pretreatment,
removal, and offsite treatment. In September 1980, Kin-Buc, Inc. was ordered to cap
Kin-Buc I and II. This source control ROD addresses remediation of the first of two
operable units, which includes Kin-Buc I and II, Pool C, and the low-lying area between
Kin-Buc I and Edison Landfill. A subsequent ROD will address offsite migration
controls. The primary contaminants of concern affecting the ground water, surface
water, sediments, soil and air are: VOCs including benzene and toluene, other organics
including PAHs and PCBs, and metals including arsenic and lead.
ne
The selected remedial action for this site includes: installation of a slurry wall
grounding the site; RCRA capping over Kin-Buc II, a portion of the low-lying area
tween Kin-Buc I and the Edison Landfill, and Pool C; maintenance and upgrading, if
ecessary, of the Kin-Buc I cap; collection of approximately 3 million gallons of
oily-phase leachate with offsite incineration and residual disposal; collection and
onsite biological or carbon treatment of aqueous-phase leachate and contaminated ground
water with discharge either to surface water or POTW, and dewatering of residual sludges
and offsite disposal; ground water monitoring; and O&M. The estimated present worth
cost for this remedial action is between $16,290,000 and $16,635,000 with annual O&M
varying from $848,000 (year 1) to $405,000 (years 12-20).
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DECLARATION STATEMENT
RECORD OF DECISION ^
Kin-Buc Landfill - Operable Unit I, Edison Twp., Middlesex County,
New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Kin-Buc Landfill-Operable Unit I in Edison Township, New
Jersey; developed in accordance with CERCLA, as amended by
SARA, and to the extent practicable, the National Contingency
Plan. This decision is based on the administrative record for
this site. The attached index identifies the items that comprise
the administrative record upon which the selection of the
remedial action is based.
The State of New Jersey has concurred on the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit was developed to protect public health and the
environment by controlling the major sources of contamination as
well as treating leachate and contaminated groundwater to the
maximum extent practicable. The operable unit is fully consistent
with all planned future site activities. Future site activities
include further evaluation of potential areas of contamination
and developing measures to manage migration of contaminants as well
as the overall site remedy.
The selected remedy for the Kin-Buc Landfill - Operable Unit I
consists of the following components:
0 circumferential slurry wall installation to bedrock on all of
the sides of the site;
0 maintenance, and upgrading if necessary, of the Kin-Buc I cap
and installation of a cap in accordance with RCRA Subtitle C
and State requirements on Kin-Buc II, portions of the low-lying
area between Kin-Buc I and the Edison Landfill and Pool C;
0 collection and off-site incineration of oily phase leachate;
0 collection and on-site treatment of aqueous phase leachate and
contaminated groundwater with disposal via direct surface water
discharge;
0 periodic monitoring and
4 operation and maintenance.
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Alternatively, pre-treatment of aqueous phase leachate and
contaminated groundwater and discharge to .the Middlesex County
Utilities Authority (MCUA) publically owned treatment -works (POTW)
(versus treatment and direct surface water discharge) "Is an
acceptable option should approval to discharge to the ^OTW be
granted by the MCUA.
DECLARATION
Consistent with the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Super fund
Amendments and Reauthorization Act of 1986, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined the selected remedy is protective of
human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate
for this remedial action and is cost-effective. This remedy
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a ^
principal element and utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure^that the
remedy continues to provide adequate protection of human-health and
the environment.
Dat£ "^ William J. yft«jf*yns^, P.Et
Acting Regional Administrator
\
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
KIN-BUC LANDFILL - OPERABLE UNIT I .,-'-
EDISON TOWNSHIP, NEW JERSEY " 2
SITE NAME, LOCATION AND DESCRIPTION
The Kin-Buc Landfill consists of a number of individual inactive
disposal sites extending over 220 acres and is located at the
end of Meadow Road in Edison Township, Middlesex County, New
Jersey. Directly north of the site is an industrial park.
The Edison Township Municipal Landfill is approximately 600
feet south of the site. Marshlands and a former borrow area
are directly to the east of the site. The Raritan River
borders the site on the west. Figure 1 depicts the general
location of the site and Figure 2 is a site map. Figure 2 also
shows that other landfills and a chemical company are within
1 mile of the site.
The Kin-Buc Landfill site includes the following components.
The larger of two major mounds, designated Kin-Buc I, covers
approximately 30 acres and rises to a maximum elevation of 93
feet. The other major mound, designated Kin-Buc II, covers
approximately 12 acres, rises to a maximum elevation of 51
feet and -is just north of Kin-Buc I. A low lying minor mound
covers approximately 9 acres, rises 15 to 20 feet high and is
designated as Mound B. Mound B lies west-southwest of Kin-Buc
I, across the Edison Township Municipal Landfill access road
and adjacent to the Raritan River. Three pits of black, oily
leachate have developed at the southeastern edge of Kin-Buc I
and are known as Pits A, B, and C. Adjacent to the pits is
an area of impounded, tidally affected water referred to as
Pool C. Marshland to the east of Pool C is cut by numerous
mosquito drainage channels, with its major drainage feature
being Edmonds Creek, a tidally affected shallow stream which
flows into the Raritan River to the south of Kin-Buc I. Pool
C is connected to Edmonds Creek by a small channel. Mill Brook,
is northwest of the site, flows into Martins Creek which has
been partially filled in by Kin-Buc II. Flowing west, Martins
Creek runs into the Raritan River just north of Mound B.
Figure 2 depicts the aforementioned site features.
Two residential populations are within 1 mile of the Kin-Buc
Landfill: a densely populated residential area located north-
west of the site across the New Jersey Turnpike near Meadow Road;
and an apartment complex located north-northeast near the Middle-
sex County College. There are three additional populations to
the north and east of the site. First, Middlesex County College
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4Ua-Bnc Uadfill Site Location Map,
.Etfisoa Towuhip, Middlesex County, N«w Jcney
i
Lr§^.J"v--r"1
vj T
,
Nlddlcstx CounV
Statt of Ntw Jtrsty
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Fifure 2 Xin-Bnc Landfill Site Map
i
STAUFFEft
CHEMICAL
LANDFILL
MILE-
Note Adapted from OCA Corporation, 1911, Information Evaluation for tkc Kia-
luc Uadflll. Edisoa, New Jtney.
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is approximately three quarters of a mile north-northeast of
Kin-Buc Landfill. Second, the Heller Industrial Park is a light
industrial complex one-half mile north of Kin-Buc II. Third, the
Mirror Lake Beach Club is approximately one-half mile northeast
of the site and is used by the employees and families of. the
Heller Industrial Park on a seasonal basis for swimming, boating,
and tennis.
Based on a review of available file information and discussions
with representatives of the local health department, there are
no public or private potable wells presently drawing groundwater
from contaminated aquifers immediately downgradient of the Kin-Buc
Landfill. Most of the public water supply in the area is predom-
inately surface water, the majority of which comes from the Rari-
tan River upstream of the site. Edison Township has six reserve
wells screened in the Brunswick formation (bedrock) within approx-
imately 2 to 2-1/2 miles upgradient of Kin-Buc II. According to
local health officials, these wells are currently not in use. In
addition, Edison Township has 700-800 private and industrial
wells upgradient of the site. None of these wells are located
between the site and the Raritan River.
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
EPA determined that the site should be remediated in operable units.
Remediation of Operable Unit I, the subject of this Record of Deci-
sion (ROD), constitutes source control measures for the site. The
components of the site addressed in Operable Unit I are as follows:
Kin-Buc I
Kin-Buc II
I Pool C
Low-lying area between Kin-Buc I and the Edison Landfill
The components of the site to be addressed in Operable Unit II
(the subject of a future ROD) consist of:
I Mound B;
Raritan River;
Mill Brook;
Martins Creek;
Edmonds Creek, including the connecting channel from Pool C;
adjacent wetlands and
I groundwater contamination emanating from the site.
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Operable Unit II will address the measures that may be necessary
to mitigate any off-site impacts resulting from contaminant migra-
tion. EPA has determined that a Supplemental Remedial Investigation
will be required to adequately characterize the nature and extent
of off-site contamination. Upon completion of the Supplemental
Remedial Investigation for Operable Unit II, a Feasibility Study
(FS) evaluating the remedial alternatives will be conducted and
the process will culminate in a subsequent ROD.
SITE HISTORY
The Kin-Buc Landfill began operating as early as 1947. During
its period of operation, the landfill was utilized for disposal
of municipal/ industrial and hazardous waste. Detailed infor-
mation on the owner/operators and site activities from 1947
to 1968 could not be located. However, the site, owned by Inmar
Associates, was later leased to Kin-Buc, Inc., a division of
Scientific, Inc-. Kin-Buc, Inc. operated the site as a land-
fill from approximately 1968 to March 1977. From 1971 to
1976, the site was a state-approved landfill for industrial
(solid and liquid) and municipal wastes. Kin-Buc Landfill
was registered with the New Jersey Department of Environ-
mental Protection (NJDEP), Solid Waste Administration. During
this period, the site accepted hazardous waste. In 1976, the
NJDEP revoked Kin-Buc's permit to operate because of violations
of a number of environmental statutes.
\
The total quantity of waste disposed of at Kin-Buc Landfill has
not been definitively determined. EPA estimates that at
least 70 million gallons of liquid waste, including 3 million
gallons of oily waste, and over 1 million tons of solid waste
were disposed of between 1973 and 1976.
There are two major sources of information regarding the type
and diversity of chemical wastes (including hazardous wastes)
disposed of at Kin-Buc. First, EPA sent information request
letters under CERCLA Section 104(e), to approximately 400
potentially responsible parties (PRPs). Typical categories
of wastes included in responses are:
V
waste lacquer residue and ferric chlorides
solvents, strip-away wastes, oils, rubber cement
wastewater, acetone
waste oils
solvent mix, silicone ;
ethyl acetate, tolulol flammables
chloroethane, cutting oils, ether, paint thinner .;.
cyanides
metal stripper, cyanides, copper
oil, alcohol, kerosene
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Second, EPA compiled and summarized data from of waste shipments
accepted between 1972 and 1976. Table 1 is a summary which
lists 45 types of waste, (most of which would be considered
hazardous) disposed at the site. ~^
The mode of disposal operations while the site was active
provides useful information to evaluate the contamination that
resulted at the site. Wastes that arrived in containers were
buried on-site and then compacted with bulldozers. Liquid waste.
was discharged into a bulldozed pit, approximately 75 to 100
feet in diameter at the top of Rin-Buc I.
Tank trucks carrying the liquid waste would stop at the entrance
to the landfill where samples of the load would undergo limited
testing (pH and flammability). The tank trucks then proceeded
to the top of Kin-Buc I, opened their discharge ports and allowed
the contents of the truck to drain into the pit.
Liquid waste also arrived in 55-gallon drums and was received
along the northeast side of Rin-Buc I; an area now covered by
Kin-Buc II. The drum contents were emptied into temporary stor-
age ponds from which the contents were pumped into the pit at
the top of the landfill. Once the active pit was filled, it
would be closed and another one dug. These operational practices
resulted in a large number of citizen complaints, caused frequent
major on-site fires and a number of serious occupational injuries,
SUMMARY OF SITE CHARACTERISTICS
The Remedial Investigation (RI) includes investigations of ground-
water, surface water, sediment and air. Major findings and con-
clusions of the RI as they pertain to the components of the site
addressed in Operable Unit I are as follows:
1) The large volume of wastes in Rin-Buc I is a source of
contamination of the immediately surrounding environment.
These wastes included hazardous waste liquids, added to
municipal and other solid wastes, with the intent that the
liquids would be largely absorbed into the solid waste.
Although the disposal of hazardous waste in Rin-Buc II has
not been documented; liquid waste was received along the north-
east side of Rin-Buc I (an area now covered by Rin-Buc II).
Therefore, EPA considers there to be a high probability that
hazardous substances are in or under the Rin-Buc II mound.
2) Precipitation infiltration into the refuse appears to be
most significant in the lowland refuse-filled marsh area
between Rin-Buc I and the Edison Landfill.
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Table 1
Summary of Waste Disposed at Kin-flue Landfill 1972
Statistical Total for Each Chemical Type
(Sheet 1 of 2)
1976
Chemical Tvoe
Waste Material
Miscellaneous Waste
Waste Water/Liquid
Waste Sludge
Waste Chemicals
Acid * Alkaline Solution
Waste Oil
Septic
Filter Aid
Contaminated Dirt & Sand
Waste/Spent Solvents
Hazardous Materials
Waste Acid
Paint Sludge
Solids
Waste Caustic
Hydrochloric Acid
Aluminum Chloride
Waste Slop
Waste Cyanide
Nitric Acid
Tar
Sulf uric Acid
Resins
Industrial Waste
Phenolics
Chromic Acid
Waste Catalyst
Isopropyl Alcohol
Scrap Metal
Phenols
Acetic Acid
Still Bottoms
Quantity*
nQQOGallonO
47580.10
33405.91
17249.77
11176.17
11067.92
5296.62
2739.82
2265.39
1358.97
1135.38
1510.89
256.56
146.68
133.65
109.56
52.10
45.00
40.62
34.87
24.21
2X50
21.16
19.03
17.97
1129
9.68
7.09
6.64
6.00
5.77
5JO
5.04
4.78
\
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Table 1
*
Summary of Waste Disposed at Kin-Sue Landfill 1972 1976
Statistical Total for Eaeh Chemical Type ' ~^-=-
(Sheet2of2) --£
Quantity*
Chemical Type (1000 Gallon^
Styrene 4.40
Waste "Lachrymitors 3.96
Gasoline 2JO
Xylene 2JO
Chloro Ethylene 1.92
Copper Solution 0.44
Formaldehyde 0.40
Jet Fuel OJS
Path Waste Material ' ' 0.21
Lead 0.16
Lacquers 0.14
Isopropyl Ether 0.01
Total 135790.66
Notes:
Data compiled from a U.S. EPA Region II summary (undated) of invoices from
Scientific, Inc. and SCA. Inc. of waste shipments accepted at Kin-Buc Landfill
between 1972 and 1976.
All waste volumes have been converted to |allons for comparison purposes as
part of U.S. EPA Region H's computer summary. . " .
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Seetlo. C-C
.t
Undmi
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3) A low permeability cap over Kin-Buc I and low permeability
cover materials over Kin-Buc II have provided reduced precipi-
tation infiltration in these areas since the cap/cover was
installed. . ^^:
4) Radial subsurface flow patterns in the Kin-Buc I anU II
mounds have been identified. Overall, groundwater flow
predominates in a southerly direction to the refuse-filled,
low-lying area immediately south of Kin-Buc I, and to major
discharge points in the area including Mill Brook, the marsh
and the Raritan River.
5) Oily phase leachate containing polychlorinated biphenyls
(PCBs) has migrated from Kin-Buc I into the refuse in the
low-lying area between Kin-Buc I and the Edison Landfill.
Flow patterns indicate the potential for the continued
migration of this leachate toward the marsh area to the
east, and to the Raritan River, west of the site.
6) The most significant and obvious manifestation of the sub-
surface flow and a primary pathway for contaminant migra-
tion are the leachate seeps over a substantial area south
of Kin-Buc I (as discussed in |4 above) and Pool C.
7) Pool C is the source of PCB contamination (up to 68 ppra)
found in the sediments of Edmonds Creek. The primary
source of contamination in Pool C is Kin-Buc I.
8) Leachate at the site can be separated into two phases:
an oily phase and an aqueous phase. Sampling and analysis
of these two phases of leachate indicate that the oily
phase leachate is contaminated with PCBs (up to 5,822
ppm) and the aqueous phase leachate contains hazardous
substances including, but not limited to, metals, volatile
organics, base neutral compounds, acid extractable compounds,
PCBs, pesticides and cyanide. Sampling and analysis of
raw leachate (prior to separation) and liquids from Pits
B, C and Pool C show the same types of hazardous substances.
Analytic data for sampled leachate is summarized in the RI.
9) There are five stratigraphic units of concern at the site:
first is the solid waste/fill material of the landfill it-
self, second is the meadow marsh mat which immediately
underlies the southern two-thirds of Kin-Buc I, third is
the sand and gravel layer which lies under the meadow marsh
mat and also underlies the southern two-thirds of Kin-Buc I.
Finally, two bedrock formations lie below the sand and gravel
layer. Only the sand and gravel and the bedrock formations are
considered aquifers. Figure 3 depicts the site stratigraphy.
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10) Within the solid waste/fill material (refuse layer)? two entire
well series and a single well from a third series have been
installed to investigate the nature of contamination. In 1981,
Fred C. Hart & Associates installed 14 wells (FCHA-aeries) under
contract to EPA; 10 of which were screened in the refuse layer.
Limited analysis of hydrocarbon material found in 6 of the 10
wells revealed the presence of .PCBs ranging in concentration
from 111-4,478 ppm. The "A" series wells, installed by AGES for
the owner/operators are also screened in the refuse layer.
Analytic data revealed concentrations of PCBs in the floating
oil in these wells ranging from 93 to 5,791 ppm. Finally, Well
GEI-6G of the GEI series, installed by GeoEngineering, Inc. for
the owner/operators and screened in the refuse layer was sampled
for parameters other than PCBs. Analytic data revealed concent-
rations of volatile organics ranging from 10 to 100 ppb and
concentrations of heavy metals ranging from 10 to 210 ppb.
11) Wells screened in the sand and gravel aquifer include the
entire KINWT series, NJDEP-5 and NJDEP-6 and the remaining
wells in the GEI series. Contaminant concentration ranges
developed from 84 samples taken between 1976 - 1984 reveal
the following:
0 presence of heavy metals including, but not limited
to lead (up to 2.7 ppm), chromium (up to 0.64 ppm)
and zinc (up to 137 ppm);
0 presence of 39 organic priority pollutants including,
but not limited to benzene, chlorobenzene, 4-raethyl-
2-pentanone, phenol and toluene which were detected at
concentrations greater than 10 ppm; compounds such as
vinyl chloride (up to 190 ppb), tetrachloroethene (up
to 1.8 ppm) and 1,2-transdichloroethene (up to 5.4 ppm);
0 concentrations of chloride (60.5 to 4,670 ppm; mean
concentration * 1838 ppm) and total dissolved solids
(140 to 10,360 ppm; mean concentration 4,928 ppm),
due at least in part to the brackish nature of the
water.
Appendix 1 summarizes the data obtained from groundwater moni-
toring wells screened in the sand & gravel aquifer.
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Note that KINWT 1-A is considered to be screened in the sand
and gravel aquifer. However, further investigation of this
well has led to the conclusion that construction of this well
was faulty and that data obtained from KINWT 1-A is question-
able in terms of whether or not it is indicative of the water
quality in the sand & gravel aquifer. Therefore, data from
this well has not been utilized in discussing the aforemen-
tioned ranges of contaminants in the sand & gravel aquifer.
12) A limited number of wells have been screened in the
bedrock aquifer. Comparison of wells considered
upgradient (MW-1, MW-2, MW-3 and MW-4 which are north
of Kin-Buc II) versus downgradient (MW-5, GEI-9R, and
GEI-12WR) indicate the following:
' ° presence of heavy metals at approximately the
same mean concentrations in upgradient and downgra-
dient wells
0 an increase in the number and frequency of organic
priority pollutants detected two contaminants
in upgradient versus nine contaminants in downgradient
wells.
Appendix 2 summarizes data obtained from groundwater monitoring
wells screened in the bedrock aquifer. However, the nature
and extent of bedrock aquifer contamination is not adequately
characterized based on the data gathered to date. The nature
and extent of groundwater contamination in this aquifer will be
a subject of the Supplemental Remedial Investigation.
13) The only significant source of air contamination is in
the immediate vicinity of the Pool C area. The major con-
taminants of concern in terms of air releases are volatile
organics and PCBs.
14) Surface water and sediment data are presented in the RI.
However, these surface waters (Raritan River, Martins Creek,
Mill Brook and Edmonds Creek), their sediments and adjacent
wetlands will be the. subject of further studies as part
of a Supplemental Remedial Investigation for Operable Unit II.
SUMMARY OF SITE RISKS
As an aid in determining the impact of the site on public health
and the environment, an endangerment (risk) assessment was con-
ducted by EPA.
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Q ,
Indicator contaminants utilized in the evaluation (eight indica-
tor contaminants were chosen from over one hundred contaminants
identified in the various media at the site (groundwater, surface
water, sediment and air) included benzene, chloroform ^1,1-dichloro-
ethene, PCBs, vinyl chloride, arsenic, cadmium, and read.
"-:. '-,"£" "
The risks associated with exposure scenarios for the identified
populations in the endangerment assessment were characterized
and estimated. The risk characteristics and estimated risks
are summarized as follows:
At present, the contaminated aquifers (sand & gravel and
bedrock) immediately downgradient of the site are not utilized
as a drinking water source. If these aquifers are used in
the future, a potential upper-bound excess lifeime cancer
risk that exceeds 10~5 due to lifetime ingestion of contami-
nated drinking water from the bedrock aquifer exists.
For the scenarios involving inhalation of gases released from
the leachate collection pool and pits, it was concluded that .
on-site concentrations of contaminants measured in air neither
exceed occupational standards nor pose a potential significant
risk to on-site workers or persons off-site. Estimated maximum
concentrations of air contaminants based on models which utilize
conservative assumptions concerning human exposure indicate a
potential risk to on-site workers (assuming no personal protec-
tion is used by workers) due to volatilization of PCBs from
Pool C and average and maximum estimated concentrations of
air contaminants considered for off-site exposure indicate
potential risk due to volatile organics and PCBs.
0 Workers who come in contact with the oily fraction of leachate
may be subject to a potential upperbound excess lifetime cancer
risk that exceeds 10~*>, based on the concentration of PCBs in
the leachate.
0 There is a potential risk from the consumption of aquatic
life due to the organisms' bioaccumulation of PCBs.
Estimates of the concentration of PCBs in the tissue of
fish found in the Raritan River could be as high as 9 ppm,
which exceeds the Food and Drug Administration limit of 2 ppm.
0 Aquatic populations in the creeks adjacent to the site will
be at risk due to chronic exposure to cadmium in the surface
water. There is also a potential for bioaccumulation of PCBs
by the aquatic life of PCBs from the sediments.
-- »
0 The terrestrial populations, especially birds, may%e
at a limited risk due to direct contact with leachate,
especially the oily phase leachate.
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There are uncertainties associated with the estimates of risks
and the assumptions made in developing these risks tend to be
conservative. For this site, there is a level of uncertainty
associated with the data and the assumptions used. The major
uncertainties are summarized as follows:
Sampling data used to evaluate exposures and risks were
collected over greater than a 10-year period by numerous
sampling teams. Sampling and quality assurance/quality
control procedures utilized for each sampling event often
were not documented. A level of uncertainty is associated
with the combining of these results.
Most of the exposure assumptions are based on values in
the scientific literature or assumptions made by EPA; not
site-specific data. Such site-specific data did not exist.
From the risk characteristics and estimations presented, it
can be concluded that releases from the site present a potential
significant risk to public health and the environment.
Additionally, it must be kept in mind that large quantities of
waste materials, many of which are highly toxic and potentially
carcinogenic, were disposed of at the site.
ENFORCEMENT ACTIVITIES
The Kin-Buc site was operated as a landfill from approximately
1968 until March 1977. From 1971 to 1976, the site was a
state-approved landfill for industrial (solid and liquid) and
municipal wastes and was registered with the NJDEP Solid Waste
Management Administration. During this period, the site
accepted hazardous waste.
Operational practices at the landfill resulted in frequent
on-site fires and a number of serious occupational injuries.
Twelve to fifteen major fires occurred between 1971 and 1976.
In a 1974 fire, a 55-gallon drum exploded killing a bulldozer
operator. As a result of this incident, the Occupational
Safety and Health Administration issued six citations for
violation of the Occupational Safety and Health Act of 1970.
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-10-- - ~"
On a number of occasions, landfill operations were in violation
of New Jersey environmental statutes. NJDEP issued Notices
of Prosecution for violations including, but not limited to,
* leachate seepage into the Raritan River; -r- -***
0 failure to provide records of the hazardous waste received;
0 failure to maintain an adequate cover over the landfill
surface and
0 unauthorized excavations.
EPA investigation-of the site began in January, 1976 at the time
of oil spill at the facility. Unpermitted point source discharges
were noted by EPA site investigators, leading to a full scale
monitoring investigation revealing the discharge of hazardous sub-
stances from the facility. Operation of the site was closed to
receipt of further liquid wastes by July 1, 1976. Based on these
and other violations, NJDEP revoked Kin-Buc's operating permit.
A November 1977 litigation report prepared by EPA led to the
filing of a civil complaint against 11 owner/operators of the
landfill on February 7, 1979 which directed the defendants to
take corrective action under a variety of federal environmental
statutues including the Federal Water Pollution Control Act, the
Solid Waste Disposal Act as amended by the Resource Conservation
and Recovery Act and the Rivers and Harbors Appropriation Act
of 1899.s In January 1980 a stipulation termed a "partial
settlement" was entered into between the United States and
Kin-Buc, Inc. (but not the remaining defendants) under which
Kin-Buc, Inc. was to undertake installation of a cap for the
landfill and conduct a long-term monitoring program. In Septem-
ber 1980, Kin-Buc, Inc. complied with a portion of the lawsuit
by placing a synthetic membrane and clay cap on Kin-Buc I. Clay
cover was also placed on Kin-Buc II. However, Kin-Buc, Inc.
refused to take measures to contain the flow of leachate or
clean up the area, claiming the area was not on its property.
EPA began cleanup activities at the site in February, 1980
using funds from the Federal Clean Water Act, Section 311(K).
These activities consisted of collection (in 55-gallon drums),
treatment and disposal of Pool C leachate. Beginning September,
1981 a drum reduction program was initiated (approximately 4000
drums had accumulated on-site). Oily phase leachate was collected
and continued to be stored in drums on-site and aqueous phase
leachate was pre-treated and sent to the Middlesex County
Utility Authority (MCUA) treatment plant under a 1981 emergency
permit issued by NJDEP. ;.
In October, 1981 the site was placed on EPA's Superfund National
Priorities List.
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-11-
In September 1982, Kin-Buc, Inc. assumed the removal operation at
the Pool C area that EPA had been conducting since February 1980.
That agreement was implemented in late September 1982. In addition,
EPA attempted negotiations with Kin-Buc, Inc. based on a proposed
CERCLA §106 consent order. Negotiations were unsuccessful and led
to issuance of a unilateral CERCLA S106 order (Findings of Fact,
Determination and Order Docket No: II-CERCLA-30102) against the 11
initial defendants of the 1979 civil action on September 23, 1983.
The unilateral CERCLA $106 order against the owner/operators required
the following:
a Removal Program which was ongoing and included:
a) drum removal
b) oil collection
c) aqueous collection
conduct of a RI/FS
implementation of the selected remedial action and
operation and maintenance.
In January 1984, EPA sent correspondence to approximately 400
companies who were determined to be potentially responsible parties
(PRPs) at Kin-Buc based on information including, but not limited
to, the business records of an owner.and operator of the site
(Scientific, Inc. and/or its subsidiaries, including Kin-Buc, Inc.)
and the business records of SCA Services, Inc. and/or the Earthline
Company, in which a subsidiary of SCA Services, Inc. held a partnership
interest. The purpose of this correspondence was to notify the
companies of their status as PRPs, cost recover funds expended to
that point in time and request information from the PRPs under
CERCLA 104(e)(l).
In May, 1984 a draft RI/FS was submitted to EPA by the owners and
operators of Kin-Buc. On March 25, 1986, EPA issued an amended
unilateral CERCLA S106 administrative order (Findings of Fact,
Determination, and Amended Order Docket No.: II-CERCLA 60105). The
purpose of this order was to "update" the 1983 CERCLA order by requiring
the owners and operators to follow guidance that had been established
during the interim period on the conduct of an RI/FS. The draft RI
was submitted in April 1988 and the draft FS was submitted in May
1988.
The owner/operators are under unilateral order 'to implement the
selected remedy and subject to treble damages for failure without
cause to implement the selected remedy. Additionally, the site
will be remediated in operable units and the PRPs have expressed a
strong interest in conducting the Supplemental Remedial Investigation
and FS. The PRPs are comprised mainly of two financially viable
companies (Transtech Industries, Inc. formally Scientific, Inc.
and Waste Management, Inc. who bought SCA Services, Inc.
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-12-
DESCRIPTION OF ALTERNATIVES
The PS established five objectives for remedial aotion of Operable
Unit I. Remedial objectives were developed based on the RI. The
remedial objectives are: . ....
0 control lateral movement of contaminants within the refuse
layer represented by Kin-Buc I, Kin-Buc II and the low-lying
area'between Kin-Buc I and the Edison Landfill;
0 control manifestation of subsurface flow as surface seeps which
can contribute to surface water contamination;
0 control surfioial contamination (i.e. Pool C and vicinity)
which may contribute to air contamination;
0 control migration of contaminants into the underlying sand and
gravel aquifer and/ in so doing, evaluate the effectiveness of '
the natural barriers which may exist (i.e. meadow marsh mat) and
0 control of the migration of contaminants into the underlying
bedrock considering the same issues noted above for the sand
and gravel.
A description of each of the alternatives that were evaluated
in detail in the PS are presented on the following pages.
Each alternative is described in terms of its treatment
components, containment components and institutional controls'
including operation and maintenance.
a .
The C3 and C4 alternatives have common components developed to
achieve the objectives for the remedial aotion. Both alterna-
tives involve capping/ containment/ collection/ treatment and
discharge/ long-term monitoring as well as operation and
maintenance of the site. The key differences between the C3
and C4 alternatives are how specific components of each
alternative are combined to achieve the remedial objectives.
The differences are described as follows:
1) There are two options relating to the depth of installation
of the circumferential slurry wall utilized for containment.
The slurry wall for the C3 alternatives is installed to the
bedrock in the northern portion of the site and to the meadow
marsh mat in the southern portion of the site while the C4
alternatives is installed to the bedrock on all sides of the
site.
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1)1 III
FIGURE 4
MATRIX FOR COMPONENTS OF REMEDIAL ALTERNATIVES
ALTERNATIVE A - NO ACTION
ALTEflNATIVE D - COMPLETE EXCAVATION '
ALTERNATIVE C - CONTAINMENT, CAPPING, COLLECTION, AND DISCHARGE OF TREATED OF
LEACHATE, MONITORING, OPERATION & MAINTENANCE
COMPONENTS
SLURRY
NALL
DISCHARGE OF TREATED
CAP AQUEOUS PHASE LEACHATE
C3a meadow mat existing
Kin-Buc I
design
C3b meadow mat existing
Kin-Buc I
design
C3c meadow mat RCRA &
State req.
C3d meadow mat RCRA &
State req.
C4a bedrock
C4b bedrock
t
C4c bedrock
C4d bedrock
existing
Kin-Buc I
design
existing
Kin-Buc I
design
RCRA &
State req.
RCRA &
State req.
POTW
Surface Water
POTW
Surface Water
POTW
Surface Water
POTW
Surface Water
INCINERATION OF MDNITORING/ttPERATION
OILY PHASE LEACHATE MAINTENANCE
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
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-13-
2) There are two options for construction of a cap over
Kin-Buc II, portions of the low-lying area between- "-
Kin-Buc I and the Edison Landfill and Pool C. One option
is to extend the existing Rin-Buc I cap design to the
aforementioned areas while the other option is to $ap
those areas in accordance with Resource Conservation and
Recovery Act (RCRA) Subtitle C and State cap requirements.
3) There are two options for the disposal of treated aqueous
phrase leachate. One option is complete on-site treatment
and direct surface water discharge while the other option
is off-site treatment at the MCUA POTW.
Figure 4 is a matrix which presents the remedial alternatives,
including each of the four subalternatives developed for the
C3 and C4 alternatives. Each of the four subalternatives for
C3 and C4 combines the capping and disposal of treated aqueous
phase leachate options discussed.
ALTERNATIVE A NO FURTHER ACTION WITH MONITORING
This alternative consists^ of the following:
0 continued performance of existing site mitigative
measures and monitoring activities including:
- inspection and maintenance of Kin-Buc I cap
»
- inspection and maintenance of Kin-Buc II cover materials
- collection of aqueous phase leachate in Pool C and
vicinity for off-site treatment
- collection of oily-phase leachate in Pool C and
vicinity for off-site incineration
- a groundwater monitoring program which includes
semi-annual water level measurements for eighteen
wells and groundwater sampling and analysis for
ten wells for the following parameters: volatile
organics, pesticides, PCBs, Total Organic Carbon,
Chemical Oxygen Demand, chloride, arsenic, barium,
cadmium, chromium, copper, lead, mercury, nickel,
selenium, silver, and zinc with the ability to
increase the number of wells if necessary
- an air monitoring program which includes monthly
monitoring at twenty locations on-site using an
organic vapor analyzer ; -
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-14-
ALTERNATIVE C3
Four subalternatives have undergone detailed evaluatiorTVnd
costing in the FS. -.- £ '
Alternatives C3a - C3b
Components common to these two alternatives are as follows:
0 circumferential slurry wall installation to bedrock in the
northern portion of the site and to the meadow marsh mat in the
southern portion of the site;
0 collection of oily phase leachate and off-site incineration;
maintenance, and upgrading if necessary, of the Kin-Buc I cap
and extension of the existing Kin-Buc I cap design to Kin-Buc II,
portions of the low-lying area between Kin-Buc I and the Edison
Landfill and Pool C;
periodic monitoring;
0 operation and maintenance
The final component of the two alternatives addresses collection
and treatment of aqueous phase leachate. The disposal of treat-
ed aqueous phase leachate is what differentiates C3a and C3b.
Alternative C3a provides for on-site aqueous phase leachate
pretreatment with discharge to the MCUA POTW. Alternative C3b
provides for on-site aqueous phase leachate treatment with direct
surface water discharge.
Alternatives C3c & C3d
Components common to these two alternatives are as follows:
0 circumferential slurry wall installation to bedrock in the
northern portion of the site and to the meadow marsh mat
in the southern portion of the site;
0 collection of oily phase leachate and off-site incineration;
0 maintenance, and upgrading if necessary, of the Kin-Buc I cap
and installation of cap in accordance with RCRA Subtitle C
and State requirements on Kin-Buc II, portions of the low-lying
area between Kin-Buc I and the Edison Landfill and Pool C;
0 periodic monitoring and
0 operation and maintenance.
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-15-
The final component of the two alternatives addresses collection
and treatment of aqueous phase leachate. The disposal .of treat-
ed aqueous phase leachate is what differentiates C3c and C3d.
Alternative C3c provides for on-site aqueous phase leachate
pre-trement with discharge to the MCUA POTW. Alternative C3d
provides for on-site aqueous phase leachate treatment with
direct surface water discharge.
ALTERNATIVE C4
As with Alternative C3, four subalternatives have been developed
for detailed evaluation and costing in the FS.
Alternatives C4a - C4b
The common components of these two alternatives are as follows:
0 circumferential slurry wall to bedrock on all sides of the site;
0 collection of oily phase leachate for off-site incineration;
0 maintenance, and upgrading if necessary, of the Kin-Buc I
cap and extension of the existing Kin-Buc I cap design to
Kin-Buc II, portions of the low-lying area between Kin-Buc
I and the Edison Landfill and Pool C;
0 periodic monitoring and
0 operation and maintenance.
The final component of the two alternatives addresses collection
and treatment of aqueous phase leachate and contaminated ground-
water. The disposal of treated aqueous phase leachate and
contaminated groundwater is what differentiates C4a and C4b.
Alternative C4a provide for on-site aqueous phase leachate'and
contaminated groundwater pretreatment with discharge to the
MCUA POTW. Alternative C4b provides for on-site aqueous phase
leachate and contaminated groundwater treatment with direct
surface water discharge.
Alternatives C4c & C4d
The common components of these two alternatives are as follows:
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-16-
0 circumferential slurry wall to bedrock on all sides of the site;
x,
9 collection of the oily phase leachate for off-site Tncineration;
0 maintenance, and upgrading if necessary, of the Kin-Buc I cap
and installation of a cap in accordance with RCRA Subtitle C
and State requirements on Kin-Buc II, portions of the low-lying
area between Kin-Buc I and the Edison Landfill and Pool C;
0 periodic monitoring and
0 operation and maintenance.
The final component of the two alternatives addresses collection
and treatment of aqueous phase leachate and contaminated ground-
water. The disposal of treated aqueous phase leachate and
contaminated groundwater is what differentiates C4c and C4d.
Alternative C4c provides for on-site aqueous phase leachate pre-
treatment with discharge to the MCUA POTW. Alternative C4d
provides for on-site aqueous phase leachate and contaminated
groundwater treatment with direct surface water discharge.
ALTERNATIVE D COMPLETE WASTE EXCAVATION FOR OFF-SITE
INCINERATION
This alternative would consist of the following:
0 excavation and off-site incineration of the source
of contamination represented by Kin-Buc I, Kin-Buc II,
the Pool C environs, and the contaminated portion of
the low-lying area between Kin-Buc I and the Edison
Landfill which totals approximately 4.6 million cubic
yards of hazardous waste
0 backfilling, grading, revegetation and drainage controls
0 verification sampling
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-17-
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA's selection of a remedial alternative must be in accordance
with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), 42 O.S.C. Sees.
9601 et seq. , as amended by the Superfund Amendments and Reauthor-
ization Act (SARA) (enacted October 17, 1986), and the requirements
of its governing regulations, the National Oil and Hazardous Sub-
stances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300.
In this section, the relative performance of the alternatives are
summarized by highlighting the key differences between the alter-
natives in terms of the nine remedial criteria.
The nine remedial criteria summarize CERCLA 512Kb) (1) (A-G) and
are as follows:
1. overall protection of human health and the environment,
2. compliance with applicable or relevant and appropriate
requirements (ARARs),
3. long-term effectiveness and permanence,
4. reduction of toxicity, mobility or volume,
5. short-term effectiveness,
6. implementability,
7. cost,
8. state acceptance and
9. commraunity acceptance,
1. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion addresses whether or not a remedy provides adequate
protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering
controls or institutional controls.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection, Treat-
ment and Discharge
Containment
Circumferential slurry wall installation to bedrock on all sides
(Alts. C4a-d) eliminates the potential for continued uncontrolled
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-18-
releases of contaminants to both the bedrock aquifer and the sur-
rounding environment, including adjacent wetlands and surface
waters. Therefore, risks to public health and the environment in
current and future use exposure scenarios would be mitigated/
resulting in protection of public health and the environment.
Circumferential slurry wall installation to the meadow marsh mat
(Alts.' C3a-d) would not adequately control releases of contaminants
to the environment including adjacent wetlands and surface waters.
The vertical migration of contaminants from the refuse layer through
the meadow marsh mat into the sand and gravel and potentially the
bedrock aquifer -«d- well as lateral migration of contaminants to
adjacent wetlands and surface waters would continue. Risks to the
environment under current use exposure scenarios would not be
completely mitigated. Risks to public health under future use
scenarios involving ingestion of contaminated groundwater (if used
for drinking purposes) would not be mitigated. Therefore, overall
protection of public health and the environment is not achieved.
m
Capping
A cap utilizing the existing Kin-Buo I design for Kin-Buo II,
portions of the low-lying area between Kin-Buo I and the Edison
Landfill and Pool C appears to be protective of public health and
environment, pending verification of the integrity of the Kin-Buo I
cap (Alts. C3a, C3b, C4a, C4b).
Cap design in accordance with RCRA Subtitle C and State require-
ments (Alts. C3c, C3d, C4o, C4d) on Kin-Buo II, portions of the
low-lying area between Kin-Buc I and the Edison Landfill and Pool C
may afford a greater level of protection since such a cap design
includes a thicker layer of clay and topsoil than the existing
Kin-Buc I cap design.
Colleotion/Treatment/Disoharge
Collection, treatment and discharge (whether it is direct surface
water discharge or discharge to the MCUA POTW) processes are the
same for the the C4a-d and C3a-d alternatives. The C4a-d and
C3a-d alternatives collect oily phase leaohate and incinerate
it off-site. However, the C4 alternatives collect, treat and
discharge aqueous phase leachate as well as contaminated
groundwater from the sand and gravel aquifer. The C3 alternatives
collect, treat and discharge only aqueous phase leachate.
Therefore, the C4 alternatives are considered more protective
of public health and the environment because aqueous phase
leaohate and contaminated groundwater will be treated.
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I
-19-
Alternative D Complete Excavation with Off-site Incineration
Implementation of the complete excavation with off-site
incineration alternative would mitigate the long-term'risks to
public health and the environment posed by the components of
Operable Unit I. The source of contamination at the site
would -be removed. However, the short-term risks and impacts
associated with this alternative are so great that selection
of this alternative would be less protective of public health
and the environment than other alternatives evaluated. The
same level of long-term nr^.ection of public health and the
environment can be achieved without the substantial short-term
risks and implementability problems through the other remedial
alternatives evaluated.
Alternative A No Further Action with Monitoring
This alternative would not result in reducing the magnitude
of public health and environmental risk associated with the
components of Operable Unit I. Specifically, environmental
releases that would continue as a result of implementation of
this alternative may subject workers who come in contact with
the oily phase leachate to a potential upperbound excess life-
time cancer risk that exceeds 10~6, based on the concentration
of PCBs in the leachate. Models estimating average and maximum
concentrations of air contaminants off-site indicate a potential
risk due to exposure of volatile organics and PCBs. However,
on-site concentrations of contaminants measured in air since
the cap was installed over Kin-Buc I in 1980 neither exceed
occupational standards nor pose a potential significant risk
to on-site workers (who wear proper personal protection as
part of a health and safety plan) or persons off-site. The
continued release of contaminants that would occur despite
implementation of this alternative poses a potential risk
with respect to ingestion of groundwater under a future use
scenario. At present, both the sand and gravel aquifer (shown
to be contaminated) and the bedrock aquifer (a component of
the Supplemental Remedial Investigation for Operable Unit II
which could be potentially contaminated due to its connection
to the sand and gravel aquifer) are not utilized immediately
downgradient of the site as a drinking water source. However,
if the bedrock aquifer is used in the future, -there is an
estimated potential upperbound excess lifetime cancer risk
that exceeds 10~5 due to lifetime ingestion of contaminated
drinking water from the bedrock aquifer. * ^
*!"»
Aquatic populations in the adjacent surface waters will be at
risk due to chronic exposure to cadmium in the surface water.
Terrestrial populations, especially birds may be at limited
risk due to direct contact with leachate.
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' -20-
The long-term public health and environmental impacts of imple-
mentation of this alternative are significant if no further action
» is taken and source control is not achieved.
\ . .^
j 2. COMPLIANCE WITH ARARs.
t
| This criterion addresses whether or not a remedy will meet all
of the applicable or relevant and appropriate requirements (ARARs)
of other environmental statutes.
During development of the PS, ARARs and Criteria, Guidances and
Advisories to be considered (TBCs) were established for Operable
Unit I site remediation. Appendix 3 represents Federal and
State ARARs and TBCs as well as their potential applicability
to those alternatives that have undergone a detailed evaluation
in the FS.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge"
Containment
Circumferential slurry wall installation to bedrock on all sides
(Alts. C4a-d) in conjunction with collection and treatment are
expected to meet ARARs for releases to groundwater and surface
water.
Circumferential slurry wall installation to the meadow marsh mat
(Alts. C3a-d) would not provide for attainment of all ARARs be-
cause releases of contaminants from the refuse layer through
the meadow marsh mat to the underlying sand and gravel aquifer,
potentially to the bedrock aquifer and to adjacent surface
waters would continue. Contaminated groundwater in the sand
and gravel aquifer would not be remediated by Alternatives
C3a-d. Therefore, ARARs for releases to groundwater and
surface water are not expected to be met.
Capping
A cap utilizing the existing Kin-Buc I design for Kin-Buc II,
portions of the low-lying area between Kin-Buc I and the Edison
Landfill and Pool C (Alts. C3a, C3b, C4a, C4b) would not meet
State ARARs for cap design.
Cap design in accordance with RCRA Subtitle C and Stat«Trequire-
ments State (Alts. C3c, C3d, C4c, C4d) for Kin-Buc II, portions of
the low-lying area between Kin-Buc I and the Edison Landfill and
Pool C would meet ARARs.
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Collection/Treatment/Discharge
The collection, treatment and discharge (whether it is direct
surface water discharge or discharge to the MCUA POTW) processes
are the same for the C4a-d and C3a-d alternatives. Both the. C4a-d
and C3a-d alternatives collect oily phase leachate and incinerate
it off-site. However, the C4 alternatives collect, treat and
discharge aqueous phase leachate as well as contaminated groundwater
from the sand and gravel aquifer. Therefore, the collection of
aqueous phase leachate and contaminated groundwater in conjunction
with treatment and discharge would result in meeting ARARs for
releases to groundwater and surface water. In comparison, the C3
alternatives collect, treat and discharge only aqueous phase leachate
and contaminated groundwater would not be collected for these
alternatives. ARARs would not be met because releases to groundwater
and surface water would continue.
Alternative D Complete Excavation with Off-site Incineration
Implementation of this alternative would result in total source
removal of the components of Operable Unit I. Compliance
with all Federal and State ARARs as well as TBCs is expected.
Alternative A No Further Action with Monitoring
Implementation of this alternative would not result in meeting
the Federal and State ARARs or TBCs. Federal and/or State ARARs
as well as TBCs would not be met under RCRA (e.g. capping,
closure requirements). The continued release of contaminants
to groundwater and surface waters would not comply with Federal
arid State groundwater or surface water ARARs.
3. LONG-TERM EFFECTIVENESS AND PERMANENCE.
This criterion refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once
clean-up goals have been met.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge
Containment
Utilization of a circumferential slurry wall in-stalled to bedrock
on all sides (Alts. C4a-d), in conjunction with the other com-
ponents of the remedy is the most effective strategy to prevent
the migration of contaminants both laterally and vertically to
groundwater, surface waters, and adjacent wetlands.
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£..
I -22-
t Installation of a circumferential slurry wall to the meadow
{- marsh mat (Alts. C3a-d) would rely on the meadow marsh mat as
, " " an effective barrier to migration of contaminants from the
j - -refuse layer to the sand and gravel aquifer. Available infor-
mation including sampling and analysis data for the sand and
: gravel aquifer and physical analysis of the meadow marsh mat
j indicate that the meadow marsh mat is neither continuous nor
[ effective in precluding downward migration from the refuse layer
to the sand and gravel aquifer. Releases to the sand and
1 gravel aquifer and potentially the bedrock aquifer as well as
to adjacent surface waters would continue. Therefore, this
I containment strategy would not provide long-term effectiveness.
Capping
A cap utilizing the existing Kin-Buc I design for Kin-Buc II,
portions to the low-lying area between Kin-Buc I and the Edison
Landfill and Pool C is expected to provide long-term effective-
ness, pending verification of the integrity of the Kin-Buc I
cap (Alts. C3a, C3b, C4a, C4b).
Installation of a cap designed in accordance with RCRA Subtitle C
and State requirements on Kin-Buc II, portions of the low-lying
area between Kin-Buc I and the Edison Landfill and Pool C (Alts.
C3c, C3d, C4c, C4d) is expected to provide greater long-term
effectiveness and permanence in terms of preventing precipitation
infiltration because the cap design includes a thicker layer of
clay and topsoil than the existing Kin-Buc I cap design.
Collection/Treatment/Discharge
The collection, treatment and discharge (whether it is direct
surface water discharge or discharge to the MCUA POTW) processes
are the same for the C4a-d and C4a-d alternatives. Both the
C4a-d and C3a-d alternatives collect oily phase leachate and
incinerate it off-site. However, the C4a alternatives collect,
treat and discharge aqueous phase leachate as well as contaminated
groundwater from the sand and gravel aquifer. The C3 alternatives
collect, treat and disharge only aqueous phase leachate. Therefore,
the C4 alternatives are considered to provide greater long-term
effectiveness because both aqueous phase leachate and contaminated
groundwater will be treated.
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Alternative D Complete Excavation with Off-site Incineration
Incineration of the excavated wastes would result in-* permanent
reduction in the toxicity, mobility and volume of contaminants
from the components of Operable Unit I. There would "be total source
removal and site restoration of the components of Operable Unit I
upon successful completion of this remedy. The potential for ex-
posure of human and environmental receptors to contaminants from
Operable Unit I components would be mitigated.
Alternative A No Further Action with Monitoring
The continued performance of existing site mitigative measures
and monitoring activities would not be sufficiently effective
for the long-term protection of public health and the environ-
ment. There would be inadequate source control and continued
environmental releases. The magnitude of the public health and
environmental risks would remain unchanged.
4. REDUCTION OF TOXICITY, MOBILITY OR VOLUME
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge
Installation of a circumferential slurry wall to bedrock (Alts.
C4a-d) will provide for the maximum reduction in the vertical and
lateral, mobility of aqueous phase leachate as well as contaminated
groundwater.
Installation of a circumferential slurry wall to the meadow marsh
mat (Alts. C3a-d) will not reduce the mobility of contaminants
in the sand and gravel aquifer since containment of contaminants
in the sand and gravel aquifer is not addressed.
Capping
The capping of Kin-Buc II, portions of the low-lying area between
Kin-Buc I and the Edison Landfill and Pool C utilizing the existing
Kin-Buc I design (Alts. C3a, C3b, C4a, C4b) will reduce the mobility
of contaminants by preventing precipitation infiltration.
The capping of Kin-Buc II, portions the low-lying area between
Kin-Buc I and the Edison Landfill and Pool C utilizing a cap design
in accordance with RCRA Subtitle C and State requirements (Alts.
C3c, C3d, C4c, C4d) is expected to provide a greater reduction in
mobility of contaminants due to precipitation infiltration because
the cap design includes a thicker layer of clay and topsoil than
the existing Kin-Buc I cap design.
-------
-24-
Collection/Treatment/Discharge
The C4a-d alternatives include collection and off-site incinera-
tion of the oily phase leachate, which provides maximum-reduction
of toxicity, mobility and volume of contaminants. For the C4a-d
alternatives, the collection, treatment and discharge (whether
it's direct surface water discharge or discharge to the MCUA POTW)
of aqueous phase leachate as well as contaminated groundwater
from the sand and gravel aquifer provides the most significant
reduction of the toxicty, mobility and volume of aqueous phase
leachate and contaminated groundwater.
The C3a-d alternatives include collection and off-site incinera-
tion of oily phase leachate which provides maximum reduction of
toxicity, mobility and volume of contaminants. However, because
the C3a-d alternatives collect and treat only aqueous phase leach-
ate and not contaminated groundwater; the reduction of toxicity,
mobility and volume of contaminants in groundwater is not addressed,
Alternative D Complete Excavation with Off-site Incineration
Complete excavation with off-site incineration would permanently
reduce the toxicity, mobility and volume of contaminants.
Preliminary estimates of the waste quantity to be excavated
at Kin-Buc for off-site incineration totals approximately
4.6 million cubic yards. Off-site incineration would result
in no residual contamination remaining from the components of
Operable Unit I.
Alternative A No Further Action with Monitoring
The existing cap over Kin-Buc I and the cover materials over
Kin-Buc II provide reduced precipitation infiltration in these
areas and thus, a reduction in the mobility of contaminants
in the refuse layer. However, other areas of the site which
are considered components of Operable Unit I such as the
low-lying area between Kin-Buc I and the Edison Landfill and
Pool C environs have not been capped. There would be no re-
duction of vertical mobility due to precipitation infiltration
in these areas. In fact, there may be increased mobility of
some contaminants from the surface to the subsurface as a result
of precipitation infiltration. Existing aqueous and oily phase
leachate collection controls in Pool C and vicinity reduce the
lateral mobility of contaminants into Edmonds Creek, an adjacent
surface water. *£
Collection and off-site treatment of aqueous phase leachate and
collection and off-site incineration of oily phase leachate
provides for a reduction in the toxicity and volume of collected
-------
I-
1 -25-
I leachate. However/ the current site collection controls are
passive systems and there is a significant volume of-contamina-
ted leachate that could be remediated more actively. In addition,
there would be no active reduction in the toxicity, mobility and
. volume of contaminated groundwater in the sand and gravel aquifer.
: 5. SHORT-TERM EFFECTIVENESS
»
This-criterion addresses the period of time needed to achieve pro-
tection and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period,
until clean-up goals are achieved.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge
Containment
Potential short-term risks to worker health and safety and the
environment associated with the C4 and C3 alternatives pertain
to excavation during installation of the slurry wall. These
risks can be effectively mitigated through the use of appropriate
controls (e.g. drainage controls, dust suppressants) and by
strict adherence to proper health and safety protocols during
slurry wall installation.
Capping^
Short-term risks with capping the site utilizing either the exist-
ing Kin-Buc I cap design or a design in accordance with RCRA
Subtitle C and State requirements involve construction of the cap
on Kin-Buc II, portions of the low-lying area between Rin-Buc I
and the Edison Landfill and Pool C exist to worker health and
safety and the environment. These risks can be effectively
mitigated through the use of appropriate controls (e.g. dust
suppressants) and by strict adherence to proper health and safety
protocols during cap installation.
Collection/Treatment/Discharge
Short-term risks to worker health and safety and the environment
are associated with installation of the collection system due to
excavation activities for both the C4 and C3 alternatives. These
risks can be mitigated through the use of appropriate controls
(drainage controls, dust suppressents) and adherence to proper
health and safety protocols during construction activities.
-------
-26-
Alternative D Complete Excavation with Off-site Incineration
There are severe short-term impacts associated with this alterna-
tive. A 4.6 million cubic yard excavation of a wide variety of
hazardous waste will require extensive safety planning. Despite
best safety planning efforts, on-site workers utilizing Level B
(self-contained breathing apparatus) or Level A (full encapsulation
and protection from any body contact) would still be at significant
risk in working with such a large volume of unknown hazardous
material that potentially contains explosive, reactive/ corrosive,
flammable or highly toxic material. During the waste excavation,
the potential for toxic air emissions, a fire or explosion would
be high. This would pose a potentially significant risk to resi-
dents in close proximity to the site as well as on-site workers.
Additionally, releases caused by accidental spills or escape of
contaminated run-off to the surrounding environment, including
adjacent surface waters could occur during excavation despite control
measures that would be implemented to prevent such releases.
Other constraints concern transport of excavated waste off-site.'
Based upon the total volume of wastes to be excavated (over an
estimated five-year excavation period), and assuming a 1600 pound
per cubic yard in-place waste density, and a 20 ton vehicle pay
load; then approximately 37,000 truck trips to an incinerator(s)
would be required on a yearly basis. This volume of truck traffic
is anticipated to be disruptive to nearby residents and poses a
potential risk due to highway accidents.
Additionally, the length of time it may take to implement and
complete this alternative is a constraint. A considerable amount
of time will be required before actual waste excavation can
commence (estimated to be three years) due to the following
factors: 1) the time to design and construct all the necessary
on-site facilities (storage, staging, decontamination facilities,
haul roads etc.), 2) the time to gain all necessary regulatory
approvals and 3) the time it may take to obtain adjacent properties
to provide space for the necessary on-site facilities. Furthermore,
it is projected that it will take five years from the time actual
excavation commences until excavation is completed. This projection
is based upon an estimate of the minimum amount of time which may
be required using conventional excavation equipment to excavate
the estimated 4.6 million cubic yards of waste and perform all
necessary functions (segregaton, testing, packaging, etc.) for
off-site incineration. This estimate neither considers any
emergencies, unplanned events which could temporarily halt excava-
tion nor the time it will take to actually incinerate all the
waste. _£
Based upon the constraints discussed above, the short-term risks
to public health and the environment are substantial.
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-27-
Alternative A NO Further Action with Monitoring __....
There would be minimal short-term effectiveness associated with
this alternative. Although existing site mitigative measures
include access restriction via a perimeter fence, cap/cover
maintenance and, collection, treatment and disposal of aqueous
and oily phase leachate; total source control is not achieved
by the No Further Action with Monitoring alternative. Public
health and environmental risks associated with components of
Operable Unit I would not be mitigated by the implementation
of this alternative.
6. IMPLEMENTABILITY
This criterion addresses the technical and administrative feasibi-
lity of a remedy, including the availability of materials and
services needed to implement a particular option.
*
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge
Containment
Constraints associated with installing a slurry wall for either
alternatives C4a-d and C3a-d include the following:
o pre-construction compatability testing and subsurface investiga-
tions for the slurry wall;
o construction of a work platform for slurry wall installation
which will require extensive excavation of hazardous waste;
o on-site workers and residents health and safety considerations
in light of the excavation work to be performed
Capping
Constraints associated with construction of a cap utilizing RCRA
Subtitle C and State requirements (Alts. C3c, C3d, C4c, C4d) would
involve obtaining a larger volume of clay and topsoil to complete
cap construction versus utilizing existing Kin-Buc I cap design
for Kin-Buc II, portions of the low-lying area between Kin-Buc I and
the Edison Landfill and Pool C.
Collection/Treatment/Discharge g
Constraints associated with implementing the C4a-d and £3a-d
alternatives include the following:
0 pre-design treatability studies for the aqueous phase leachate
treatment system,
-------
-28-
0 construction of a work platform, and subsurface collection
system which will require extensive excavation of hazardous
waste, ~ 4ir
0 on-site workers, POTW workers and residents health'and safety
consideration in light of the excavation work to be performed.
On-site treatment of aqueous phase leachate (C3 alternatives)
and contaminated groundwater (C4 alternatives) with direct sur-
face water discharge requires a more complex on-site treatment
system than the treatment system anticipated for pretreatment
and discharge to the MCUA POTW. Additional constraints specific
to implementing an on-site treatment system with direct surface
water discharge include:
0 generation of additional waste streams (e.g. sludges) that
require greater handling, operation and maintenance, space
requirements and proper treatment and/or disposal and
0 the potential need to acquire adjacent properties for construc-
tion of the on-site treatment system necessary for surface
water discharge.
The final design of a system for on-site treatment of aqueous phase
leachate and contaminated groundwater (C4 alternative) with discharge
to a POTW or surface waters is dependent or treatability studies
necessary for various unit processes as well as specific discharge
permit requirements by MCUA (to go to the POTW) or the State of New
Jersey Department of Environmental Protection (to go to surface
waters). Permit levels for discharge to surface water or the POTW
will incorporate site-specific ARARs.
The time to implement either alternative is estimated to take
one to one and one-half years but assumes initation of construc-
tion activities at the beginning of the construction season and
allows for scheduling contingencies that may extend the con-
struction time frame. Long-term management and monitoring is
required for both alternatives.
Alternative D Complete Excavation with Off-site Incineration
Potential constraints in implementing this alternative are
as follows:
0 the complexity of operations and technologies required to
protect considering the large volume and diversity of wastes;
0 the need to acquire adjacent properties, as sufficient
space does not exist on-site to accomodate construction
of the necessary facilities;
-------
-29-
the time to design and construct all the necessary
on-site facilities (storage, staging, haul roads*
.
the time to gain all necessary regulatory approvals and
implement the remedy;
* the availability of sufficient and suitable incineration
facilities and
cost.
The techniques to be employed have been extensively and success-
fully used at other hazardous waste sites. The combination of
these technologies to construct a complex facility to excavate
and transport wastes to an incinerator is not widely employed due
to the risks to on-site workers and nearby residents, short-term
environmental impacts and costs.
Preliminary estimates of the waste quantity to be excavated at
Kin-Buc for off-site incineration includes:
Wastes contaminated with PCB 400,000 cubic yds.
concentratons > 50 ppm
Wastes contaminated with PCB 4,205,000 cubic yds.
concentrations < 50 ppm
10*0,000 drums of unidentified 27,000 cubic yds.
liquids
TOTAL 4,632,000 cubic yds.
However, due to existing disposal demands placed upon RCRA
incinerators, it would be difficult for a single incinerator
facility to dedicate itself to handling such a large volume
of hazardous waste.
Furthermore, even if a single incinerator facility (regardless
of whether or not it is PCB-approved or non-PCB approved) was
capable of dedicating itself to the destruction of Kin-Buc
wastes, there does not appear to be a RCRA incinerator in the
country that is large enough to handle the disposal of the wastes
from Kin-Buc within a reasonable time period. Considering the
estimated large volume of wastes present at the Kin-Buc «ite
requiring incineration under this alternative, even if the
largest incinerator facility were capable of dedicating itself
to Kin-Buc, it is estimated that it may take at least 35 years
to complete incineration.
-------
-30-
! ~ -'' :- '-' ''' -
Alternative A No Further Action with Monitoring -.:g£ ....
s-r-_ es.-ear:".-
The relative ease of implementing this alternative is -evidenced
by its successful performance to date. There is operational
reliability of the existing monitoring wells. The aqueous and
oily phase leachate collection relies on proven technologies.
Readily'available personnel and equipment exists on-site for the
continued performance of this alternative.
7. COST
This criterion includes estimated capital, operation and mainte-
nance costs and net present worth costs. These costs are summarized
in Table 2 for Alternatives A, C3 (including subalternatives), C4
(including subalternatives) and D. Additional cost details are
provided below:
Alternatives C4a-d & C3a-d - Containment, Capping, Collection,
Treatment and Discharge
Annual operation and maintenance costs for Alternatives C4a and C4c
vary over the 30-year operational period from $762,000 in Year 1 to
$398,000 .in Years 12-30.
Annual operation and maintenance costs for Alternatives C4b and C4d
vary over the 30-year operational period from $848,000 in Year 1 to
$405,000 in Years 12-30.
Annual operation and maintenance costs for Alternatives C3a and C3c
vary over the 30-year operational period from $753,000 in Years 1 tc
Years 12-30.
Annual operation and maintenance costs tor Alternatives C3b and C3d
vary over the 30-year operational period from $397,000 in Year 1 to
Years 12-30.
Alternative D Complete Excavation with Off-site Incineration
For the purpose of calculating present worth, the capital cost
for construction of on-site structures was equally distributed
over the first three years of the implementation period, and the
remaining costs were equally distributed over the last five years
of the eight-year implementation period.
-------
Tabl
COST SUMMARY OF REMEDIAL ALTERNATIVES
KIN-BUC FEASIBILITY STUDY
Alternative"1
No further action with monitoring (Bltero<4ive A)
Circumferential wall to meadow mat on the south and rock
on the north (flj^r^tive C3 )
Sub-alternative a
Sub-alternative b
Sub-alternative c
Sub-alternative d
Circumferential wall to rock on all sides (ftlk«-«\«five CM )
Sub-alternative a
Sub-alternative b
Sub-alternative c
Sub-alternative d
Waste excavation for off-site incineration fftltcrnvtive Q )
Capital
($1,000)
......
7.12.5
<«>8,I3S
7,8fe3
9.V\Q
W10.WJ
iO.Jtt
8.303
<«>8.74l
10/K7
<«>i 1.491
ll,2»fc
7.023,455
Annual*
O&M
(S1.000)
432
varies
varies
varies
varies
varies
varies
varies
varies
varies
varies
varies
varies
- .
. r HZ.
Present
Worth
($1,000)
4.075
12|U17
<»> 13,085
IH.HO
(y>i3.|)oC
15,«H
<«> 16,W5
(y) i4,nc
4,001.938
Notes: 1. Sub-Alternative Abbreviations
a. On-site aqueous pre-treatment with discharge to MCUA; extension of existing
Kin-Buc I cap design
b. On-site aqueous treatment with direct surface water discharge; extension of
existing Kin-Buc I cap design
c. On-site aqueous pre-treatment with discharge to MCUA; RCRA cap.
d. On-site aqueous treatment with direct surface water discharge; RCRA cap.
2. Annual O&M costs of slurry wall alternatives vary over the 30-year operational
period. See Section 5.3.5 of the. report for annual O&M costs.
3. x s Anaerobic/Aerobic Treatment
y = Powdered Activated Carbon Treatment (PACT)
10 $88 06316
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-31-
Alternative A No Further Action with Monitoring
The potential for future remedial action would be determined
based on groundwater monitoring; air monitoring, continued perfor-
mance of existing site mitigative measures and land use changes
in the vicinity of the site. Changes in any of the aforementioned
factors that increase the magnitude of risk to public health or
the environment would require a re-assessment of the need for
further remedial action. Based on the FS, present worth costs of
any further remedial action could range from approximately tweleve
million to four billion dollars depending on the remedial alterna-
tive implemented.
8. STATE ACCEPTANCE
This criterion is utilized to support the Agency's comments.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection
Treatment and Discharge
Containment
NJDEP concurs with the need to install a circumferential wall to
bedrock (Alts. C4a-d) versus to the meadow marsh mat (Alts. C3a-d)
because a slurry wall to bedrock is more protective, provides
greater reduction in mobility of contaminants both laterally and
vertically and prevents uncontrolled releases to groundwater and
surface^water.
Capping
NJDEP concurs with the need to install a cap in accordance with
RCRA Subtitle C and State requirements on Kin-Buc II, portions of
the low-lying ara between Kin-Buc I and the Edison Landfill and
Pool C.
Collection/Treatment/Discharge
NJDEP concurs with the need for collection and off-site incinera-
tion of oily phase leachate as well as collection, treatment and
discharge (whether it is direct surface water discharge or dis-
charge to the MCUA POTW) of aqeuous phase leachate and contaminated
groundwater.
Alternative D Complete Excavation with Off-site Incineration
X"
State acceptance of this alternative is not anticipated due to
the significant public health and environmental risks associated
with excavation of such a large volume of hazardous waste.
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-32-'
Alternative A No Further Action with Monitoring
.... ._,_,,. _
. . -.«* .r>
ii This alternative would not adequately reduce the public health
and environmental risks posed by the components of Operable Unit
; I. In addition, neither Federal or State ARARs nor TBCs would be
i met. Therefore, there would not be State acceptance of this
alternative.
t! 9. COMMUNITY ACCEPTANCE
This criterion summarizes the public's general response to the
alternatives described in the Proposed Remedial Action Plan and
RI/FS report. Specific responses to public comments are addressed
in the Responsiveness Summary section of the ROD. A community
relations history is presented in Appendix 4.
Alternatives C4a-d & C3a-d - Containment, Capping, Collection
Treatment and Discharge
Alternative C4a-d would mitigate current and future use risks to
public health and the environment. Use of on-site treatment of
aqueous phase leachate and contaminated groundwater with dishcarge
to surface water versus pre-treatment and discharge to the MCUA
POTW is not expected to have a significant effect on community
acceptance. The receiving body for the treated aqueous phase
leachate and contaminated groundwater in either alternative is
the Raritan River. Therefore, community acceptance is expected
to be positive.
Alternatives C3a-d meet some of the site-specific source control
objectives via installation of the cap, containment and collection
system. There is reduction in the toxicity, mobility and volume of
aqueous and oily phase leachate. Community acceptance of this is
anticipated to be positive. Significant community concern is anti-
cipated regarding the fact that contaminated groundwater in the sand
and gravel aquifer and potentially, the bedrock aquifer, would not
be addressed. Since the meadow marsh mat is not considered an
effective barrier to prevent downward migration of contaminants,
uncontrolled releases would continue. For these reasons, the
overall acceptance of either alternative is not anticipated to be
positive. Use of on-site treatment and discharge to surface water
versus discharge to MCUA POTW is not expected to have a significant
effect on community acceptance. The ultimate receiving body for
treated aqueous phase leachate in either option is the Raritan River.
Alternative D Complete Excavation with Off-site Incineration
Community acceptance of this alternative is not anticipated
to be positive due to significant community concern over the
potential short-term risks to the environment and public health
associated with this alternative.
-------
,.
Hacout«
«-Slurry Wai / »
Limit 01 .
Landfill '*
Potential Detantlon
'''Pond Araa
.
v f -
*** s
R«r«ut«d
To Edison Landfill
Not To Seal*
ALTERNATIVES c-3 AND c-4
CDM - Federal Programs Corporation
r\J
-o
»-
r\J
-------
M
POTW
4«
39
»
! '
10
-10
-»c
4«
-0
ALTERNATIVE C-4
'vH i-1.-.-;:
l
!;"i»^ii.
W- i-l' i
Not To Seal*
&EPA
CDM - Federal Programs Corporation
u>
1 : J Q
!!.[§
, i 1 fi
-------
1 ..
-33-
Alternative A No Further Action with Monitoring
i ....__.
I- Implementation of the No Further Action with Monitoring alter-
| native would neither mitigate the public health and Environmental
I risks nor provide adequate control of releases of hazardous sub-
I. stances to the environment. There has been significant community
t concern about this site over time. Therefore, it is anticipated
I that there would not be community acceptance of this alternative.
SELECTED REMEDY
A) Description of the Selected Remedy
1. Scope and Function of the Remedy
The selected remedy for the Kin-Buc Landfill - Operable Unit I is
Alternative C4d. This alternative consists of the following com-
ponents:
^
0 circumferential slurry wall installation to bedrock on all
of the sides of the site;
0 maintenance, and upgrading if necessary, of the Kin-Buc I cap
and installation of a cap in accordance with RCRA Subtitle C
and State requirements on Kin-Buc II, portions of the low-lying
area between Kin-Buc I and the Edison Landfill and Pool C;
0 collection of oily phase and off-site incineration;
0 collection and on-site treatment of aqueous phase leachate and
contaminated groundwater with direct surface water discharge;
0 periodic monitoring and
0 operation and maintenance.
Figures 5 and 6 illustrate the components of the selected remedy.
Alternatively, The C4c alternative is acceptable if the MCUA
POTW elects to accept pre-treated aqueous phase leachate and
contaminated groundwater in accordance with their requirements.
2. Performance Goals
a. Management of Migration i
The RI completed in April 1988, includes investigations of ground-
water, surface water, sediments and air. The results of the RI
indicate the potential for off-site public health and/or environ-
mental impacts attributable to the Kin-Buc Landfill operations.
-------
-34-
Based on the results of the RIj the magnitude and the complexity
t of the site warranted remediation of the site in discrete phases
|- - (Operable Units). The remediation of Operable Unit l-f the subject
; ^ of this ROD, constitutes source control, treatment and removal
; *~ measures for the site. _ "'__
! '£"-
The components of Operable Unit I are:
|
; ' Kin-Buc I?
0 Kiri-Buc II;
0 Pool C and
0 Low-Lying area between Kin-Buc I and the Edison Landfill.
Operable Unit II will address the management of migration measures
that will be determined to be necessary at the site.
EPA has determined that a Supplemental Remedial Investigation
will be required to adequately characterize the nature and extent
of contamination from the components of Operable Unit II. Upon
completion of the Supplement Remedial Investigation for Operable
Unit IIr an FS to develop and evaluate remedial alternatives will
be conducted and the process will culminate in a subsequent ROD,
which will document the selection of a remedy for management of
migration of contaminants at the site. The process for selection
of a remedy for Operable Unit II (Supplemental Remedial Investigatic?nff
FS, ROD) is expected to be completed in 1 and 1/2 to 2 years.
Remedy selection for both Operable Units I and II is anticipated
to result in total site remediation.
The components of Operable Unit II are comprised of the following:
0 Mound B
0 Raritan River
0 Mill Brook
0 Martins Creek
i
0 Edmonds Creek, including the connecting channel from Pool C
0 adjacent wetlands
0 groundwater contamination emanating from the site "*?
The rationale for addressing each of the aforementioned components
as part of Operable Unit II is provided in Appendix 5. ~
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-35-
b. Source Control -- - -
i. contaminated media and, <£*
ii. type and volume of waste -;-
The total quantity of waste disposed of at Kin-Buc Landfill has
not been definitively determined. EPA estimates that at least 70
million gallons of liquid waste, including 3 million gallons of
oily waste, and over 1 million tons of solid waste were disposed
of between 1973 and 1976. The type of waste disposed at the site
was previously discussed in the Site History section of the ROD.
Refer to that section of the ROD for a detailed discussion.
In addition to -the Kin-Buc I and II mounds, the low-lying area
between Kin-Buc I and the Edison Landfill is also refuse filled.
Oily-phase leachate contaminated with PCBs has been detected in
monitoring wells installed in this area.
Pool C is the most significant and obvious manifestation of both
oily and aqueous phase leachate. It is adjacent to Kin-Buc I which
is its' primary source of contamination. Pool C is the source of
PCB contamination found in the sediments of Edmonds Creek.
Groundwater in the sand and gravel aquifer beneath and down-
gradient of Kin-Buc I has been shown to be contaminated. Ground-
water of the bedrock aquifer beneath the site could be potentially
contaminated. The nature and extent of bedrock aquifer contami-
nation is a component of Operable Unit II.
The selected remedy provides for collection and treatment of
aqueous phase leachate, contaminated groundwater and oily phase
leachate. A preliminary estimate of the volume of oily phase
leachate to be collected and incinerated off-site is three
million gallons. Preliminary estimates of the volume of aqueous
phase leachate and contaminated groundwater in the sand and
gravel aquifer is as follows:
Aqueous Phase Leachate
(refuse layer)
Contaminated Groundwater
(sand & gravel aquifer)
Short-term
(gpd)
10,000
(yrs. 1-4)
Long-term
(gpd)
1,500
(yrs. 5+)
Short-term
(gpd)
70,000
(yrs. 1-5)
Long-term
(gpd)
50,000
(yrs. 6+)
Therefore, the preliminary estimates of the volume of aqueous
phase leachate plus contaminated groundwater from the sand and
gravel aquifer to be handled by the on-site treatment system is
equal to 80,000 gpd (years 1-5) and 61,500 gpd (years 5+). The
significant difference between the short-and long-term flows
indicates the need for flexibility of operation in the treatment
process ultimately utilized.
-------
-36-
It should be emphasized that the flow values are preliminary
estimates pending further treatability study work and additional
subsurface investigations including evaluating the bedrock aquifer
i to determine its need for remediation. The conceptual treatment
{ processes evaluated have been determined to be applicable for
the aqueous phase leachate and contaminated groundwater. However/
treatability study work on the various unit processes will be
t conducted and site specific discharge ARARS will be developed
(in conjunction with NJDEP to refine the operating parameters of
the treatment system.
iii. treatment/residual levels
During development of the feasibility study, Federal and State
ARARs as well as TBCs were evaluated for remediation of Operable
Unit 1. Appendix 3 is a listing of Federal and State ARARs as
well as TBCs for Operable Unit 1. A more detailed discussion of
; ARARs can be found in the subsequent portion of this document
addressing consistency with other environmental laws.
The selected remedy entails collection and off-site incineration
of oily-phase leachate. The oily-phase leachate has been shown,
through sampling and analysis, to contain concentrations up to
5,822 ppm PCBs. Therefore, the incinerator utilized for the
treatment of the oily-phase leachate must achieve a destruction
and removal efficiency of 99.9999% according to RCRA Part 264,
Subpart*0, which discusses performance standards for incinerators.
Aqueous phase leachate and contaminated groundwater are to be
collected, treated and discharged to surface water as part of
the selected remedy. For purposes of the evaluation as part of
the feasibility study, surface water quality criteria for an SE1
water (the surface water classification given to the Raritan
River by the NJDEP) was utilized. These surface water quality
criteria embodied in N.J.A.C. 7:9 - 4.1 et. seq. as well as
wastewater discharge requirements provided in N.J.A.C. 7:9 - 5.1
et. seq. are the minimum treatment requirements for aqueous phase
Teachate and contaminated groundwater. Requirements of N.J.A.C.
7:9 - 4.1 et seq. and N.J.A.C. 7:9 - 5.1 et seq. are presented in
Tables 3 and* TT^ Final site-specific discHarge criteria will be
established by NJDEP based on the results of treatability studies.
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I I I
TABLE 3
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
7:9-4.14(c) Surface Water Quality Criteria for
FW2, SB and SC Waters
*
(Expressed as maximum concentrations unless otherwise noted)
Substance
Criteria
Classifications
1. Bacterial quality
(counts/100 ml)
i. Bacterial Indicators shall not exceed, in
all shellfish waters, the standard for
approved shellfish waters as established
by the National Shellfish Sanitation
Program as set forth in its current
manual of operations.
ii. Fecal Coliforms:
(1) Fecal coliform levels shall not exceed
exceed a geometric average of 200/100
ml nor should more than 10 percent of
the total samples taken during and
30-day period ecceed 400/10Q ml.
iii. Samples shall be obtained at sufficient
frequencies and at locations during
periods which will permit valid inter-
pretation of laboratory analyses. As a
guideline and for the purpose fo these
regualtionSf a minimum of five samples
taken over a 30-day period should be
collected, however, the number of samples,
frequencies and locations will be deter-
mined by the department or other appro-
priate agency in any particular case.
Shellfish Waters
FW2 (except as in (3) be-
low), SE1, and SC 1500
feet to 3 miles from the
shoreline.
All Classifications
i
-------
TABLE 3
NEW JERSEY DEPARTMENT OP ENVIRONMENTAL PROTECTION ' .
7:9-4.14(c) Surface Water Quality Criteria for
FW2, SB 'and SC Waters
(Expressed as maximum concentrations unless otherwise noted)
Substance
2. Dissolved oxygen
(rag/1)
i. 24 hour average not less than 5.0, but
not less than 4.0 at anytime (see para-
graph viii below).
viii. Supersaturated dissolved oxygen values
shall be expressed as their corresponding
100 percent saturation values for purposes
of calculating 24 hour averages.
3. Floating, colloi-
dal, color and
settleable solids;
petroleum hydro-
carbons and other
oils and grease
4. pH (Standard
Units)
None noticeable in the water or deposited
along the shore or on the aquatic substata
in quantities detrimental to the natural
biota. None which would render the waters
unsuitable for the designated uses.
ii. For "Petroleum Hydrocarbons" the goal is
none detectable utilizing the Federal EPA
Environmental Monitoring and Support
Laboratory Method (Freon Extractable -
Silica Gel Adsorption - Infrared Measure-
ment); the present criteria, however, are
those of paragraph i. above.
i. 6.5-8.5
FW2-NT (except as in
iv below), SE1
FW2-TM, FW2-NT, SE1
All Classifications
All Classifications
FW2, All SB
11
-------
ill >ri|r
TABLE 3
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION '
7:9-4(c) Surface JWater Quality Criteria for
FW2, SE and SC Waters
(Expressed as maximum concentrations unless otherwise noted)
Substance
Criteria
Classifications
6. Radioactivity
7. Solids, Suspended
(mg/1) (Non-filter-
able residue]
8. Solids, Total Dis-
solved [Filterable
Residue] (mg/1)
i. Prevailing regulations adopted by EPA
pursuant to Sees. 1412, 1445 & 1450
of the Public Health Services Act, as
amended by the Safe Drinking Water
Act (PL 93-523).
iii. None which would render the waters
unsuitable for the designated uses.
ii. None which would render the water
unsuitable for the designated uses.
All Classifications
All SB, SC
All SB
i !
- -r *
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TABLE 4
/
STATE OP NEW JERSEY
DEPARTMENT OP ENVIRONMENTAL PROTECTION
NJAC 7:9-5.8 Minimum Treatment Requirements '
These minimum treatment requirements apply to all discharges, where ettluent
limitations based upon water quality studies acceptable to the Department
have not been developed and are required by N.J.A.C. 7*9-4.5(e)4 or 4.6(a).
Watershed ~~~_[~~_~__\\ , Class!f icattoni^ BOD? Removal* BODS Maxlmum~l'mg7l'y'*:*" t>IscHarge~T;
Raritan River Basin SE1 85 All
(including Raritan ;
Bay and Sandy Hook
Bay)
' j
* Minimum percent reduction of BODS at all times including any tour-hour perioa ot a day when
the strength of the wastes to be treated might be expected to or actually exceeds average, ,
conditions.
** Average over any four-hour period of a day, including periods when the strength of;the
wastes to be treated might be expected to or actually exceeds average conditions.
-------
TABLES
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
QUALITY STANDARDS FOR
LEACHATE DISCHARGED TO POTW
Total Toxic Organies*
Monthly "^
Average" ST
2.13 mg/1
Daily
Maximum
I
I
Total Toxic Volatile Organies
Benzene (1.9.1)
Carbon tetrachloride (1.12.4)
Chloroform (1.12.3)
Dioxane
Ethylenimine (aziridine)
Ethylene bromide (1.12.30)
Ethylene dichloride 0.12.7),
1,2-dichloroe thane
Tetrachloroethane 0.12.10)
Tetrachloroethylene 0.12.26)
1,1,2 trichloroethane 0.12.9)
^Trichloroethylene 0.12.23)
Metals (ppb)
Cyanide
As
Cd
Cr
Cn
Pb
Ni
Zn
Cr
Ag
Hg
No PCB's, pesticides, insecticides
0.1 Lb/Hr
650
1,000
260
120
360
400
170
660
60
240
48
1,200
3,000
690
230
1,100
600
360
2,200
110
f| . 430
..." -
-------
' -37-
-t
l| Sludges generated by the on-site treatment system for aqueous
'» phase leachate and contaminated groundwater will be dewatered.
v The dewatered sludges are anticipated to be considered hazardous
> and therefore land disposal in a RCRA subtitle C facility would
: be required. However, the dewatered sludges will be subject to
treatability studies to determine the potential for further
reduction in toxicity, mobility and volume as well as to determine
'I the optimal treatment and/or disposal option that is in accordance
with RCRA and in an environmentally sound manner*
i
Any discharge into the air from the treatment of aqueous phase
leachate and contaminated groundwater will require meeting the
substantive requirements of N.J.A.C. 7:27-8.2.
The C4c alternative, which is the same as C4d except that
aqueous phase leachate and contaminated groundwater would be
pre-treated on-site and discharged to the MCUA POTW for final
treatment, is an acceptable alternative provided approval to
discharge is granted by the MCUA POTW. The typical reported
discharge standards for the MCUA facility are:
Total petroleum hydrocarbons less than 100 ppra
PCB concentrations less than 1 ppm
No hazardous vapors
pH 6-9
Possible restricted discharge times
NJDEP has established quality standards for leachates being
discharged to POTWs. In addition to the basic MCUA discharge
standards, NJDEP regulates total toxic organics, total toxic
volatile organics and specific metals. Table 5 summarizes
these quality standards. Final site-specific pre-treatment
criteria for discharge to the MCUA POTW would be based on
results of treatability studies and established by NJDEP and
the MCUA. Approval to discharge to the POTW would have to
be granted by the MCUA. Sludges generated by this on-site
pre-treatment system for aqueous phase leachate and contaminated
groundwater would be handled in the same manner as described
for the on-site treatment and surface water discharge alternative.
iv. estimated timeframe
Pre-design work including, but not limited to treatability
studies and subsurface investigations are estimated to take 6
months to 1 year after the signing of the ROD.. Design of the
selected remedy is estimated to take 6 months to 1 year, but to
a degree, can commence concurrently with pre-design work. The
time required to construct the remedy is estimated to be 1 to 1
1/2 years. Therefore, the estimated timeframe for the selected
remedy is 1 1/2 to 3 1/2 years.
-------
-38-
B) STATUTORY DETERMINATIONS
1. Protectiveness
The selected remedy is protective of human health and the environment
in that the source of groundwater contamination will be contained;
thereby reducing lateral and vertical migration of aqueous phase
leachate and contaminated groundwater. In addition, the collection
and treatment of aqueous phase leachate and contaminated groundwater
in the sand and gravel aquifer to meet surface water discharge
criteria or alternatively criteria for discharge to the MCUA POTW
will significantly reduce the toxicity and volume of contaminants
in the groundwater and prevent further degradation of groundwater
quality in the sand and gravel aquifer and potentially, the bedrock
aquifer. The nature and extent of any bedrock aquifer contamination
is a component of Operable Unit II. A determination of the need to
remediate the bedrock aquifer will be made based on the RI/FS for
Operable Unit II. However, the treatment system for Operable Unit
I will be designed to consider the potential need to remediate
groundwater in the bedrock aquifer.
The selected remedy mitigates the potential risk to public health
by capping the Pool C environs (as well as Kin-Buc II and portions
of the low-lying area between Kin-Buc I and the Edison Landfill);
thereby preventing the uncontrolled release of contaminants to the
air. Gas vents installed as part of the capping would be monitored
in terms of the rate and composition of any airborne emissions and
gases would be treated, if necessary. Meeting the substantive
requirements of State air permits will be required for all landfill
gas vents. In addition, the containment, collection and treatment
of oily phase leachate (by off-site incineration) as well as aqueous
phase leachate and contaminated groundwater (via onsite treatment
and discharge to surface water or a POTW) reduces the mobility,
toxicity and volume of contaminants which would be source of any
air releases.
Workers who come in contact with oily phase leachate may be sub-
ject to a potential upperbound excess lifetime cancer risk that
exceeds 10~ , based on the concentration of PCBs in the leachate.
This risk is primarily mitigated by the use of proper personal pro-
tection and strict adherence to health and safe'ty protocols during
any handling of oily phase leachate as part of the remedial action.
Ultimately, collection and off-site incineration of oily phase
leachate would remove the source of the potential risk to workers
who would conduct long-term operation and maintenance at the site.
-------
-39-
There is a potential risk from the consumption of aquatic life
due to their bioaccumulation of PCBs. Estimates of -the concentra-
tion of PCBs in the tissue of fish found in the Raritan River could
be as high as 9 ppm, which exceeds the Food and Drug Administration
limit of 2 ppm. Aquatic populations in the creeks adjacent to the
site may be at risk due to chronic exposure to cadmium. The on-
going removal action has controlled the release of aqueous and oily
phase-leachate to the Raritan River and Edmonds Creek. The area
had also been posted as a "No Fishing" area due to PCB contamination.
The selected remedy will continue to control release of oily phase
leachate as well as collect the material for off-site incineration.
Removal and off-site incineration of oily phase leachate and col-
lection and treatment of aqueous phase leachate and contaminated
groundwater reduce the toxicity, mobility and volume of aqueous
oily-phase leachate; thereby mitigating the risk to public health
and the environment. During the Supplemental Remedial Investigation
for Operable Unit II, impacts on surface water and sediments due -
to release of contaminants will be more fully evaluated.
»
Terrestrial populations, especially birds may be limited risk due
to direct contact with leachate, predominately oily phase leachate.
The capping of Pool C and its environs (the most overt manifes
tations of leachate) will preclude direct contact with leachate
by terrestrial populations, especially birds; thereby mitigating
the potential risk.
2. Consistency With Other Laws
\
During development of the feasibility study, applicable or relevant
and appropriate requirements (ARARs) as well as TBCs were established
for Operable Unit I site remediation based on current EPA guidance.
Appendix 3 represents Federal and State ARARs and TBCs as well as
their potential applicability to the selected remedy.
Applicable requirements are defined as those cleanup standards,
standards of control, and other substantive environmental protec-
tion requirements, criteria, or limitations promulgated under
Federal or State law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location or other cir-
cumstance at a CERCLA site.
Relevant and appropriate requirements are defined as those' cleanup
standards of control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under Federal
of State law that, while not "applicable" to a hazardous substance,
pollutant, contaminant, remedial action, location or other circum-
stances at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is
well suited to the particular site.
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-40-
Non-promulgated advisories or guidance documents issued by Federal
or State governments do not have the status of potential ARARs.
However, they may be considered in determining the necessary level
of cleanup for protection of public health and the environment.
There are several different types of requirements that Superfund
actions may have to comply with. The classification of ARARs is
presented below:
Location-specific requirements are restrictions on activities
depending on the site or its immediate environs. As presented
in Appendix 3, location specific requirements with regard to
Kin-Buc Landfill-Operable Unit I pertain to portions of the site
being within a 100-year floodplain and within a coastal zone.
Location-specific ARAR requirements are expected to be met by
the selected remedy.
Action-specific requirements set controls or restrictions on
particular kinds of activities related to management of hazardous
substances, pollutants or contaminants. These requirements are
triggered by the remedial activities selected to accomplish a
remedy. Action-specific requirements may specify particular
performance levels, actions or technologies, as well as specific
levels (or a methodology for setting specific levels) for discharg-
ed or residual chemicals. As presented in Appendix 3, action-spe-
cific Federal and State requirements as well as TBCs pertain
predominately to requirements under RCRA and the Clean Water Act
and are expected to be met.
Chemical-specific requirements are usually health or risk-based
concentration limits or ranges in various environmental media for
specific hazardous substances, pollutants or contaminants. These
requirements can indicate an acceptable level of discharge (e.g. air
emission or wastewater discharge taking into account water quality
standards) where one occurs in a remedial activity. Aqueous
phase leachate and contaminated groundwater are to be collected,
treated and discharged to surface water as part of the selected
remedy for Operable Unit I.
With respect to capping the Kin-Buc site, EPA has selected a remedy
which requires maintenance, and upgrading if necessary, of the Kin-
Buc I cap and installation of a cap in accordance with RCRA
Subtitle C and State requirements on Kin-Buc II, portions of the low-
lying area between Kin-Buc I and the Edison Lnadfill and Pool C.
However, NJDEP has utilized the RCRA guidance documents to develop
design specifications for capping hazardous waste landfills and
codified them into their hazardous waste landfill regulations.
Therefore, cap design specifications contained in NJDEP's hazardous
waste regulations are ARARs and must be met.
-------
-41-
l The existing cap design on Kin-Buc I was installed in 1980 as part
| of a partial stipulation under a Federal enforcement action. This
| cap meets performance criteria of RCRA Subtitle C requirements,
( assuming the integrity of the existing Kin-Buc I cap is-verified
during the Supplemental Remedial Investigation for Operable Unit
| II. For this reason, EPA does not believe that application of the
1 State requirements to the Kin-Buc I cap is appropriate at this time.
The continued maintenance, and upgrading if necessary, for the
Kin-Buc I cap is the selected capping remedy for Kin-Buc I. However,
Kin-Buc II, portions of the low-lying area between Kin-Buc I and
the Edison Landfill and Pool C must be capped in accordance with
RCRA Subtitle and State requirements.
For purposes of the evaluation of alternatives in the feasibility
study, surface water quality criteria for an SEl water (the surface
water classification given to the Raritan River by NJDEP) was
utilized. These surface water quality criteria provided in N.J.A.C.
7:9-4.1 et seq. as well as waste water discharge requirements
proved in N.J.A.C. 7:9-5.1 et seq. are the minimum treatment re-
quirements for aqueous phase leachate and contaminatd groundwater
(see Tables 3 and 4 which present surface water quality criteria
and wastewater discharge requirements respectively). Final site-
specific discharge ARARs will be established by NJDEP based on
treatability studies and are expected to be met by the selected
remedy.
In the event that MCUA grants approval to discharge to their
POTW, the quality standards for leachates being discharged to
POTWs established by NJDEP in addition to MCUA's basic discharge
standards would be the minimum requirements pending final
site-specific pre-treatment criteria. Site-specific pre-treatment
criteria for discharge to the MCUA POTW would be based on the
results of treatability studies and established by NJDEP and
the MCUA and are expected to be met by the selected remedy.
Finally, Title 7, Chapter 27, Subchapter 8 of the New Jersey
Administrative Code describes general provisions required for
landfill vents. The substantive requirements for air permits
for landfill gas vents would be met. Upon installation of
gas vents as part of the remedy, the rate and compositions of
any volatile organic compounds emitted would be evaluated to
determine the need for any chemical-specific requirements.
The selected remedy is expected to meet those requirements.
3. Cost-Effectiveness
After careful consideration of all reasonable alternatives, EPA
selected Alternative C4d for the remediation of Kin-Buc Landfill-
Operable Unit I. However, the C4c alternative, which is the same
as C4d except for on-site aqueous phase leachate and contaminated
-------
-42-
groundwater pre-treatment with discharge to the MCUA POTW is an
acceptable alternative which can be implemented should approval
to discharge be obtained from the MCUA. The selected remedy
was determined to provide the greatest overall effectiveness pro-
portionate to its costs.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
This section provides the overall rationale for remedy selection,
that is, how the remedy was judged to provide the best balance
of trade-offs among the alternatives examined in detail. It
also discusses the alternatives' utilization of permanent
solutions and treatment to the maximum extent practicable.
Alternative A - No Further Action With Monitoring
This alternative was eliminated since no further action would allow
for the continued uncontrolled release of hazardous substances into
the environment, would not mitigate the potential public health and
environmental risks posed by the site and would not provide control
or adequate removal of the source of contamination. Therefore,
this alternative would not utilize permanent solutions or treatment
to the maximum extent practicable.
Alternatives C3a-d slurry wall installation to bedrock in the
northern portion of the site and to the meadow marsh mat in the
southern portion of the site, collection of oily-phase leachate
for off-site incineration, collection and treatment of aqueous
phase leachate, capping, periodic monitoring, operation & maintenance
These alternatives were eliminated because slurry wall installation
to the meadow marsh mat in the southern portion of the site would
not provide adequate source control. Contaminants would continue
to be released to the sand and gravel aquifer; contaminated
groundwater would not be collected or treated as part of these
alternatives to the degree necessary. Hence, the potential for
downward migration of contaminants into the bedrock aquifer and
lateral migration of contaminants into the surrounding environment,
including adjacent surface waters, would not be controlled.
Additionally, Alternatives C3a and C3b do not provide for a cap
on Kin-Buc II, Pool C and the low-lying area between Kin-Buc I
and the Edison Landfill which would be in compliance with ARARs.
Therefore, uncontrolled releases of hazardous substances into the
environment would occur, compliance with ARARs would not be achieved,
there would not be utilization of permanent solutions and
treatment to the maximum extent practicable, and the potential
public health and environmental risks posed by the site may
not be adequately mitigated.
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-43-
Alternatives C4a and C4b - slurry wall installation to bedrock on
all sides, collection of oily-phase leachate for off-site incin-
eration, collection and treatment of aqueous-phase leachate and
groundwater, existing cap design on Kin-Buc I extended to Kin-Buc II,
portions of the low-lying area between Kin-Buc I and the Edison
Landfill and Pool C, periodic monitoring, operation & maintenance
These two alternatives were eliminated, because the cap would
not be in compliance with ARARs.
Alternative D - Complete Waste Excavation for Off-Site Incineration
Utilization of permanent solutions and treatment would be to the
maximum extent practicable. However, this alternative was
eliminated because of the significant short-term risks posed
to workers who would be remediating the site and nearby
residents during implementation of this alternative. In
addition, there are significant technical complexities (e.g. on-
site space constraints, sequencing of operators) associated with a
waste excavation of this magnitude.
If a single incinerator was capable or dedicating itself to the
destruction of Kin-Buc wastes (unlikely), there does not appear
to be an incinerator in the country that is large enough to
handle the disposal of wastes from Kin-Buc within a reasonable
time period. If the largest incinerator were capable of dedicating
itself to incinerating Kin-Buc wastes, it is estimated that may
take at least 35 years to complete incineration of the excavated
wastes from the site.
5. Preference for Treatment as a Principal Element
The selected remedy satifies the statutory preference for
treatment as a principal element for remediation of the source
of contamination.
To date, approximately 26,000 gallons of oily-phase leachate
has been collected and incinerated off-site via a passive system.
Oily-phase leachate, containing PCBs, will be actively collected
and incinerated off-site. Containment, capping, active collection
and treatment by off-site incineration of this material will
significantly reduce its toxicity, mobility and volume. The
public health threat that the continued release of oily-phase
leachate poses via potential exposure through direct contact,
bioaccumulation or air and the environmental threat posed via
potential exposure through direct contact to animal and/or
bird populations, bioaccumulation, surface water as well as
continued degradation of the surrounding wetlands is mitigated.
Contamination that has migrated beyond the source control area
determined for Operable Unit I will be addressed in Operable
Unit II.
-------
1
4
I
To date, approximately 1.4 million gallons of aqueous phase
leachate has been collected utilizing a passive collection
system. Aqueous-phase leachate and contaminated groundwater will
be actively collected and treated on-site for discharge to surface
water (or alternatively, pre-treated and discharged to the MCUA
POTW) . Containment, active collection and treatment (whether
entirely on-site or by the POTW) of this material will result in a
significant reduction in its toxicity, mobility and volume. The
potential public health and/or environmental threats posed by the
continued release and aqueous-phase leachate and potential exposure
through groundwater, surface water, air and direct contact will be
mitigated.
The selected remedy was determined to be the most appropriate
solution for the site. It represents the best combination of the
remedial evaluation criteria to achieve a preference for treatment
to the maximum extent practicable. Alternative C4d best addresses
public health and environmental concerns, compliance with ARARs,
technical performance and cost-effectiveness.
-------
! r.
r
Kin-Buc Ground-Water Monitoring Wells
Screened In Sand and Gravel*
Sheet 1 of 3
Element/Compound
Ammonium Nitrogen
BOD
COD
Chloride
Cyanide (total)
Dissolved Solids
Fluoride
Kjeldahl Nitrogen
Nitrate
Oil & Grease
Organic Nitrogen
Sulfate
Suspended Solids
TOC
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Tin
Vanadium
Zinc .
Frequency
of Detection
16/16
10/10
12/12
13/13
27/27
16/16
1/1
4/4
13/13
9/9
13/13
8/8
5/5
17/17
13/13
17/24
33/34
17/17
17/24
26/29
24/34
5/8
23/34
15/15
35/45
14/14
17/24
24/29
18/29
14/20
20/29
4/8
3/8
45/45
Minimum
( ppnO
OJ9
1.00
1.00
60J
<0.001e
140
2.10
13.3
0.07
36.2
67.0
1.7
0.064
ND
ND
0.1
ND
ND
ND
ND
ND
ND
0.470
ND
ND
ND
ND
ND
ND
ND
0.01
Maximum
fppmi
122.6
1.106.0
727.0
4.750.0
0.5
10.360.0
2.10
96.50
2.43
5.0
23.4
300.0
7.640.0
1.100.0
21.6
2.0
0.22
5.40
0.026
0.02
0.640
0.073
0.58
5810
2.7
13 J
0.0132
0.48
0.021
0.029
0.2
0.083
0.08
137.0
Geometric
Mean"
7.38
106.0
340.0
1853.8
0.012
4928.0
110
39.2
0.37
3.2
3.1
169.0
8210
75.9
0.977
v 0.093
0.018
0.767
0.006
0.008
0.022
0.031
0.039
10.740
0.021
1.489
0.0004
0.093
0.005
0.009
0.016
0.041
0.050
0.506
-------
Analytical Results From
Kin-Bue Ground-Water Monitoring Wells
Screened In Sand and Gravel*
Sheet 2 of 3
i
Frequency Minimum
Element/Compound of Detection fppnO
Acetone 2/34 ND
Benzene 40/78 ND
BenzoicAcid 1/33 ND
Bis (2-chloroethyl) ether 1/49 ND
Bis (2-cthylhexyl) phthalate 18/S4 ND
Bromodichloromethane 1/44 ND
2-Butanone . 1/33 ND
Butyl benzyl phthalate 6/53 ND
Chlorobenzene 23/74 ND
Chloroethane 10/73 ND
Chloroform 7/52 ND
p-Chloro-m-cresol 2/44 ND
4,4-DDD 1/55 ND
1,2-Dichlorobenzenc 3/57 ND
1,1-Dichloroethane 8/74 ND
1,2-Dichloroethane 5/74 ND
U-Dichloroethene 4/52 ND
Diethyl phthalate 8/55 ND
2,4-Dimethyl phenol 1/4 ND
Di-n-butyl phthalate 20/54 ND
Dt-n-octyl phthalate 15/53 ND
Ethylbenzene 20/72 ND
Methylene chloride 30/71 ND
4-Methyl-2-pentanooe 1/28 ND
Naphthalene 5/57 ND
n-Nitrosodiphenylamine 1/47 ND
PCS: Total 1/4 ND
Maximum
fpoml
840.0
21.0
0.2
0.005
3.40
0.033
340.0
0.058
12.6
0.111
0.170
0.01
<0.01 «
' 0.085
0.071
0.660
0.016
0.340
0.015
0.170
0.018
2.80
0.370
98.0
0.210
0.0053
0.116
Geometric
Meanb
(com }
0.015
0.015
0.057
0.010
0.021
0.005
0.014
0.011
0.009
0.011
0.010
0.010
0.010
0.010
0.010
0.010
0.002
-------
f.
r,
r.
/JPP£i\)Ol* ±-
Analyticalv Results From
Kin-Buc Ground-Water Monitoring Wells
Screened In Sand and Gravel*
Sheet 3 of 3
i
i
1
Element/Compound
Phenols (total)
Tetrachloroethene
Toluene
trans-1,2-dichloroethene
l,l,l>Trichloroethane
Trichloroethene
Vinyl chloride
Xylene
o-Xylene
Frequency
of Detection
31/40
19/80
34/77
14/71
1/56
10/78
6/74
10/23
4/29
Minimum
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
(ppmi
103
1.80
42.0
5.40
0.56
2.0
0.19
0.016
1.60
Geometric
Meanb
fppm)
0.040
0.009
0.008
0.007
0.005
0.007
0.010
0.005
0.007
Notes: Data compiled from sources listed in Appendix B
ND Not detected
The wells included in this summary are those of the KINWT, GEI, (except wells
9R and 12WR) and NJDEP (Wells 5 and 6) series.
* Section U.2 describes the procedures used to calculate the geometric means.
Detected at concentrations less than the detection limit
r;
-------
Screened in edrock/BruwMick Shale
Upgradient end OoHngradlent Cround-Uater Analysis
Sheet 1 of 2
800
COO
Chlorlote
Cyanide (total}
DlMotved Solid
riuoride
Mltrato
Sulfoto
IOC
Alualr
Antlwny
Arsenic
erlui
Beryl HIM
Cedalui
diroeilui
Cobalt
Copper
Iron
Frequency
of Detection
7/7
10/10
9/9
4/4
8/8
1/1
4/4
4/4
2/2
2/2
2/4
7/8
3/4
3/4
7/8
4/8
0/2
4/8
10/10
Uporadlent Hells
Nlnlsue
lno»)
1
2.8 .
0.9
0.009
84
0.3
0.1
11
1.7
0.112
HO
HO
HO
HD
HO
HD
HO
8.20
Naxleus
fucei)
31
65
14
170
0.3
0.27
28
4.7
0.650
<0.20
0.013
0.15
0.0014
0.01
0.01
HO
0.035
15.5
Neon
lam)
7.0
7.0
4.0
0.005
136.0
0.3
0.14
17.0
.2.8
0.270
0.060
0.008
0.154
0.004
0.004
0.010
e>
0.024.
1.930
Freqjency
of Detection
5/9
4/4
9/9
«/* ,
9/9
0/0
3/3
3/3
1/1
1/1
1/2
7/7
3/3
1/2
9/9
5/7
1/1
4/7
8/4
Douraredlent
Nlnlaue
(coel
1
1
7.4
.
t
1.21
r.8
L.4
.310
.060
.008
.170
.005
.011
.008
.011
.034
.1
-------
leed
Mercury
Nickel
SelenluB
Silver
Tbelllua
Tin
Vanadiua
line
Oeniene
CMoroethane
1.1-OlcMoroetfcan*
ftbvl beniene
Netbylene chloride
Hwnole (total}
Tatrachleroatban*
ToluMe
TrlcMoroetkene
Otttl
tin -DUG ur<*«a water Monitoring U.II.
Screened In ledrock/in^utck Stale
l*redlent «, Oowr
Sntet 2 of
Frequency
of P»t«c,t|m
8/0
6/6
2/4
4/4
*/a
4/6
2/4
0/2
1/2
8/8
Nlni.ua
-iaaL
0.007
0.1
MO
<0.02
NO
NO
MO
NO
MO
«0.05
HeBIBUB
_lBM^
0.070
0.4
0.0005
0.170
40.020
0.025
<0.20
MO
0.050
0.250
Mean
_IfiG9l.
0.015
0.180
0.0002
0.054
0.005
0.014
0.010
0.050
0.086
OQMnar«d|nl u^
Nulwi
0/4
0/4
0/4
0/4
1/4
8/10
0/2
0/4
0/4
MO
MO
MO
MO
MO
NO
MO
MO
MO
MO
MO
MO
NO
1.3
0.0074
MO
MO
MO
0.020
0.004
Oete compiled free) eourcee Hated In Appendix 0
HO -Mot detected
Unable to calculate
Uporadlent walla acreened In bedrock ere MM. and Mtf-2
b DoMnoradient walla acreened In bedrock are MI-S, MW-4. MI-S. CEI
e Detected et concentre!lone leaa than the Mtkod detection Halt
d Teat not perforated
5/7
3/3
1/2
3/4
*V7
3/4
4/5
1/1
8/1
MO
0.2
MO
MO
MO
MO
MO
0.012
MO
«O.M
0.210
2.74
0.0017
0.150
0.0089
0.05
0.20
0.012
MO
0.25
O.M
0.40
0.000*
0.0*2
8.005
0.019
0.028
8.012
8.120
1/5
1/5
2/S
1/5
3/5
7/9
2/S
2/S
y8
«o.oioe
<0.010
0.070
<0.010
O.MI
2.43
<0.010
40.005
40.010
0.005
0.010
0.009
0.005
0.010
0.010
0.005
0.005
0.005
and CCI*12UI
-------
APPENDIX 3
LOCATION SPECIFIC FEDERAL ARARS
AND CRITERIA, ADVISORIES 6 GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
LOCATION
REQUIREMENT
Prerequisite^)
Citation
Potential Applicability
Within 100-year
floodplain
Facility roust be designed,
constructed, operated, and
maintained to avoid washout
RCRA hazardous
waste; treatment,
storage, or dis-
posal
40 CFR 264.18(b)
"Relevant and Appropriate"
Alternatives, C3,, C4 and
and D, as it pertains to
portions of the site which
may be within the 100-year
floodplain.
Within flood-
plain
Action to avoid adverse
effects, minimize potential
harm, restore and preserve
natural and beneficial
values
Action that will
occur in a flood-
plain, i.e., low-
lands, and rela-
tively flat areas
adjoining inland
and coastal
waters and other
flood prone areas
Executive Order
11988, Protec-
tion of Flood-
plains, (40 CFR
6, Appendix A)
"Applicable" to Alterna-
tives C3, C4 and D as it
pertains to portions of
the site which may be
within ELoodplains.
Within coastal
zone
Conduct activities in
manner consistent with
approved State management
programs
Activities
affecting the
coastal zone in-
cluding lands
thereunder and
adjacent shore-
lands
Coastal Zone
Management Act
(16.U.S.C. Sec-
tion 1451 et
seq.)
Applicable" to Alterna-
tives C3, C4 and D.
-------
JEPENDIX 3
ACTION SPECIS^BFEEERAL ARARSS
AND CRITERIA, ADVISORIES^GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILTY STUDY
Action
lirement
Prerequisite(s)
Citation
Potential Applicability
Air Stripping
Proposed standards for control of
emmissions of volatile
organics.
Proposed standard, to
be considered
52 FR 3748
(February 5,
1987)
Proposed standard, not yet a ARAR
but may be "applicable" in the
future to Alternative C3 and C4 as
it pertains to possible on-site
aqueous air stripping pretreatment
prior to off-site disposal.
c
Capping
Placement of a cap over waste (e.g.,
closing a landfill, or closing a sur-
face impoundment or waste pile as a
landfill, or similar action) requires £
cover designed and constructed to:
0 Provide long-term minimization
migration of liquids through the
capped area
0 Function with minimum maintenance
0 Promote drainage and minimize ero-
sion or abrasion of the cover
0 Accommodate settling and subsidence
so that the cover's integrity is
maintained
0 Have a permeability less than or
equal to the permeability of any
bottom liner system or natural
subsoils present.
Restrict post-closure use of property
as necessary to prevent damage to the
cover.
Prevent run-on and run-off fron damag-
ing cover.
Protect and maintain surveyed bench-
marks used to locate waste cells (land-
fills, waste piles).
Disturbance of haz-
ardous waste and
movement of it cut-
side the unit or area
of contamination will
make requirements
applicable; capping
without disturbance
will not make re-
quirements appli-
cable, but technical
requirements are
likely to be relevant
and appropriate.
40 CFR
264.301(a)
(Landfills)
Relevant and Appropriate"
Alternatives C3 and C4.
to
40 CFR
264.117(c)
(Closure and
Post-Closure)
40 CFR
264.310(b)
-------
Requirement
ACTION SPECIFIC FEDERAL ARARS
AND CRITERIA, ADVISORIES & GUIDANCES TO BE CONSIDERED
KIN-BUG FEASIBILITY STUDY
Action
Consolida-
tion
Area from which materials are removed
should be cleaned up.
Prerequisite's)
Disposed by disturbance of
hazardous waste (listed or
characteristic) ad moving
it outside unit or boundary
of contaminated area.
Citation
See closure
Potential Applicability
'_ ' -''. 'a1 ti**" ""if". -'
"Applicable11 to Alternative
D if it is necessary for any
reason to construct waste
piles/storage tanks, etc.
on-site to contain excavated
wastes prior to off-site dis-
posal.
Consolidation in storage piles/storage
tanks will trigger storage require-
ments
See Container
Storage, Tank
Storage, Waste Piles
in this Exhibit.
Container
Storage
(On-Site)
Containers of hazardous waste must
be:
Maintained in good condition
Compatible with hazardous waste
to be stored; and
Closed during storage (except to
add or remove waste).
Inspect container storage areas
weekly for deterioration.
Place containers on a sloped, crack-
free base, and protect from contact
with accumulated liquid. Provide
containment system with a capacity
of 10% of the volume of containers
of free liquids. Remove spilled or
leaked waste in a timely manner to
prevent overflow of the containment
system.
Keep containers of ignitable or re-
active waste at least 50 feet from
the facility's property line.
Keep incompatible materials separate.
Separate incompatible materials
stored near each other by a dike or
other barrier.
RCRA waste (listed or
characteristic, held for a
temporary period before
treatment, disposal, or
storage elsewhere,
(40 CFR 264.10) in a con-
tainer (i.e., any portable
device in which a material
is stored transported,
disposed of, or handled
(40 CFR 264.10)
All citations per-
tain to use and
management of con-
tainers.
40 CFR 264.172
40 CFR
40 CFR 264.174
40 CFR 264.175
Applicable to Alternative D
as it pertains to the used
and management of containers
used for excavated waste.
40 CFR 264.176
40 CFR 264.177
-------
ACTION S
AND CRITERIA, ADVISORIES
KIN-BUC
1C FEDERAL ARARS
IDANCES TO BE CONSIDERED
IBILITY STUDY
Action
Requirement
Prerequisite(s)
Citation
Potential Applicabi1ity
Clean
Closure
Removal)
General performance standard requires
minimization of need for further maintenance
and control; minimization or elimination of
post-closure escape of hazardous waste,
hazardous constituents/ leachate, contami-
nated runoff, or hazardous waste decomposi-
tion products. Disposal or decontamination
of equipment, structures, and soils.
Disturbance of RCRA
hazardous waste
(listed or charac-
teristic) placed at
site after November
19, 1980 and movement
outside the unit or
area of contamination.
May apply to surface
impoundment; contam-
inated soil, including
soil fron dredging or
soil disturbed in the
course of drilling, or
excavation, and
returned to land.
40 CFRA 264.111
(Closure and
Post-Closure
Performance
Standard)
Relevant and Appropriate"
Alternative D.
to
Removal or decontamination of all waste re-
sidues, contaminated containment system
components (e.g. liners, dikes), contaminat-
ed subsoils, and structures and equipment
contaminated with waste and leachate, and
management of them as hazardous waste.
Not applicable to
undisturbed material.
40 CFR 264.228
(a)(l) (Surface
impoundments-
Closure and
Post-Closure
Care), and
40 CFR 264.258
(Waste Piles-
Closure and
Post-Closure
Care)
"Applicable" to Alternative D if
it is necessary for any reason
to construct a surface impound-
ment or waste pile on-site to
contain excavated wastes prior
to off-site disposal, and
"Applicable" to Alternatives
C3 and C4 if a surface impound-
ment is constructed on-site as
part of aqueous pretreatment
prior to off-site disposal.
Meet health-based levels at unit.
Disposal of RCRA
hazardous waste
(listed or charac-
teristic) placed at
site after November
19, 1980 after dis-
turbance arid move-1
ment outside the unit
or area of contami-
nation.
40 CFR 264.111
"Relevant and Appropriate"
to Alternative D.
?-»»
-------
ACTION SPECIFIC FEDERAL ARARS
AND CRITERIA, ADVISORIES & GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Action
Requirements
Prerequisite(s)
Citation
Potential Applicability
Closure
with
Waste in
Place
(Capping)
Installation of final cover to provide
long-term minimization of infiltration.
Post-closure care and groundwater
monitoring.
Prerequisite same as for
capping.
40 CFR 264.310
(Landfills)
"Relevant and Appropriate" to
Alternatives and C3 and C4.
Closure
with
Haste in
Place
(Hybrid
Closure)
Removal of majority of contaminated
materials. Application of cover and
post-closure monitoring based on
exposure pathway(s) of concern.
Proposed rule, to be
considered.
52 PR 8712
(March 19, 1987)
"Relevant and Appropriate" to
Alternative D if for some
reason a portion fo the contarn
inated waste/soils are left in
place (i.e., not excavated
and removed).
Dike Sta-
bilization
Design and operate facility to prevent
overtopping due to overfilling; wind
and wave action; rainfall; run-on;
malfunctions of level controllers,
alarms, and other equipment; and human
error. Construct dikes with sufficient
strength to prevent massive failure.
Inspect liners and cover systems during
and after construction.
Inspect weekly for proper operation and
integrity of the containment devices.
Remove surface impoundment from
operation if the dike leaks or there is
a sudden drop in liquid levels.
At closure, remove or decontaminate all
waste residues and contaminated
materials. Otherwise, free liquids
must be removed, the remaining wastes
stabilized, and the facility closed in
the same manner as a landfill.
Manage ignitable or reactive wastes so
that it is protected from materials or
conditions that may cause it to ignite
or react.
Existing surface im-
poundment containing
hazardous waste, or
creation of new surface
impoundment.
40 CFR 264.221
(Surface
impoundment)
40 CFR 264.226
(Surface
impoundment)
40 CFR 264.226
40 CFR 264.227
(Surface
impoundment)
40 CFR 264.228
(Surface
impoundment)
40 CFR 264.227
"Appligable"to Alternatives C3
and C4 if a surface impound-
ment is constructed on-site as
part of aqueous pretreatment
prior to off-site disposal.
Also "Applicable" to Alterna-
tive D if it is necessary for
any reason to construct a sur-
face impoundment on-site to con-
tain excavated wastes prior to
off-site disposal.
-------
Act
Requirement
ACTION SPECIFIC FEDERAL ARARS
AND CRITERIA, ADVISORIES^ySUIDANCES TO BE CDSIDERED
KIN-fiUC Flj^fclLITY STUDY
Ks)
Prerequisl
Citation
Potential Applicability
Direct dis-
charge of
treatment
system
effluent
Use of best available technology (BAT)
economically achievable is required to
control toxic and nonconventional
pollutants. Use of best conventional
pollutants control technology (BCT) is
required to control conventional
pollutants. Technology-based limita-
tions may be determined on a case-by-
case basis.
Applicable Federally approved State
water quality standards must be comp-
lied with. These standards may be in
addition to or more stringent than
other Federal standards under the CWA.
Applicable Federal water quality
criteria for the protection of aquatic
life must be complied with when
environmental factors are being con-
sidered.
The discharge must conform to applic-
able water quality requirements when
the discharge affects state other
than the certifying state.
The discharge must be consistent with
the requirements of a Hater Quality
Management plan approved by EPA water
(WA §208(6)).
Discharge limitations must be establi-
shed for all toxic pollutants that are
or may be discharged at levels
greater than that which can be
achieved by technology-based standards
Develop and implement a BMP program
and incorporate in the NPCES permit
to prevent the release of toxic con-
stituents to surface waters.
40 CFR 122.44(a)
Applicable" to Alternatives C3 and C4
as it pertains to possible on-site
treatment with direct surface water
discharge.
40 CFR 122.44 and
State regulations
approved under
40 CFR 131
40 CFR 122.44(d)
40 CFR 122.44(6)
40 CFR 125.100
-------
APPENDIX 3
ACTIONS SPECIFIC FEDSRAL ARARS
AND CRITERIA ADVISORIES 6 GUIDANCE TO CONSIDERED
Prerequisite(s)
Citation
ion
Requirement
Potential Applicability
The BMP Program must:
0 Establish specific procedures for the
control of toxic and hazardous pollutant
spills
0 Include a prediction of direction, rate of
flow, and total quantity of toxic
pollutants there experience indicates a
reasonable potential for equipment
failure.
0 Assure proper management of solid and
hazardous waste in accordance with
regulations promulgated under RCRA.
Discharge must be monitored to assure
compliance. Discharge will monitor:
0 The mass of each pollutant
0 The volume of effluent
0 Frequency of discharge and other
measurements as appropriate
Approved test methods for waste consti-
tuents to be monitored must be followed.
Detailed requirements for analytical pro-
cedures and quality controls are provided.
Sample preservation procedures, container
materials, and maximun allowable holding
times are prescribed.
Permit application information must be
submitted including a description of
activities, listings of environmental
permits, etc.
Monitor and report results as required by
permit (minimum of at least annually)
40 CFR 125.104
40 CFR 122.44(1)
On site discharge
surface waters must
meet substantive
NPDES permit
requirements.
40 CFR 136.1 -
136.4
40 CFR 122.21
40 CFR 122.44(1)
-------
2NDIX 3
ACTION SPEGKY FED3RAL ARARS
AND CRITERIA, ADVISORIElHrGUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Action
Requirements
Prerequisite(s)
Citation
Potential Applicability
Comply with additional permit condi-
tions such as:
0 Duty to mitigate any adverse effects
of any; discharge; and
0 Proper operation and maintenance of
treatment systems
40 CFR 122.41(1)
Discharge
to POT**3
Pollutants that pass through the POTW
without treatment, interfere with POTW
operation, or contaminate POTW sludge
are prohibited.
Specific prohibitions preclude the
discharge of pollutants to POTWs that
0 Create a fire or explosion hazard in
the POTW; are corrosive (pH<5.0)
0 Obstruct flow resulting in inter-
ference
0 Are dischared at a flow rate and/or
concentration that will result in
interference
0 Increase the temperature of waste-
water entering the treatment plant
that would result in interference,
but in no case raise the POTW influent
temperature above 104*F).
0 Discharge must comply with local POTW
pretreatment program, including POTW-
specific pollutants, spill prevention
program requirements, and reporting
and monitoring requirements;
40 CFR 403.5 (Part
403-General Pre-
treabnent Regula-
tions for Existing
and New Sources of
Pollution. Section
5-National Pre-
treatment Standards;
Prohibited Dis-
charges. )
"Applicable" to Alterative C3 and
C4 as it pertains to discharge
of aqueous to a POTW treatment
facility.
40 CFR 403.5 and
local POTW
regulations.
-------
ACTION SPECIFIC FEDERAL ARARS
AND CRITERIA, ADVISORIES & GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Action
Requirement
Prerequiste(s)
Citation
Potential Applicabi1ity
RCRA permit-by-rule
requirements must be
compiled with for dis-
charges of RCRA hazar-
dous wastes to POTMs
by truck, rail, or
dedicated pi
40 CFR 264.71 and 264.72
(Manifest System, Record-
keeping and Reporting).
ipe.
5rT~
Excava-
tion
Area fron which
materials are excavated
may require cleanup to
levels established by
closure requirements.
Disposal by dis-
turbance of
hazardous waste
and moving it
outside the unit
or area of con-
tamination.
See Closure in this Exhibit
(i.e., 40 CFR 264.111
closure performance standard,
and 52 FR 8712, March 19,
1987).
Not considered to be "Applicable" (as it
pertains to RCRA hazardous waste placed at
the site after November 19, 1980), however,
is "relevant and appropriate" to Alterna-
tive D.
Operation
and Main-
tenance
Post-closure to ensure
that site is maintained
and monitored.
40 CFR 264.1 (Closure and
Post Closure)
Relevant and Appropriate"
C3 and C4.
to Alternatives
Surface
Water
Control
Prevent run-on and con-
trol and collect run-off
from a 24-hour, 25-year
storm (waste piles, land
treatment facilities,
landfills).
Prevent overtopping of
surface impoundment.
40 CFR 264.301(c).(d)
40 CFR 264.251(c).(d)
Relevant and Appropriate"
C3 and C4.
to Alternatives
40 CFR 264.221(c)
"Applicable" to Alternative D if it is
necessary for any reason to construct
a waste pile on-site to contain excavated
wastes prior to off-site disposal.
"Applicable" to Alternatives C3 and C4
if a surface impoundment is constructed
on-site as part of aqueous pretreatraent
prior to off-site disposal.
"Applicable" to Alternative D if it is
necessary for any reason to construct
a surface impoundment on-site to con-
tain excavated wastes prior to off-site
disposal.
-------
-------
AND CRITERIA, ADVISORIES & GUIDANCES 16 BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
ACTION
REQUIREMENT
Perequisite(s)
sregu
revio
Citation
Potential Applicability
Consider
Storage
(On-Site)
cont.
Contain-
raent (Con-
struction
of New
Surface
Impound-
ment (On-
Site) (See
Closure
with Waste
in Place
and Clean
Closure)
At closure, remove all hazardous
waste and residues fran the con-
tainment systan, and decontaminate
or remove all containers, liners.
See Previous Page
40 CFR 264.178
See Previous Page
Use two liners, a top liner that
prevents waste migration into the
liner and a bottom liner that pre-
vents waste migration through the
liner throughout the post-closure
period.
Design liners to prevent failure due
to pressure gradients, contact with
the waste, climatic conditions, and
the stress of installation and daily
operations.
Provide leachate collection system
between the two liners.
Use leak detection system that will
detect leaks at the earliest possi-
ble time.
RCRA hazardous waste
(listed or charac-
teristic) currently
being placed in a
surface impoundment.
40 CFR 264.220
(Surface
impoundments)
40 CFR 264.221
(Surface
Impoundments)
"Applicable" to Alternatives C3 and
C4 if a surface impoundments is con-
structed on-site as part of aqueous
pretreatment prior to off-site dis-
posal, and "applicable" to Alternative
D if it is necessary for any reason
to construct a surface impoundment
on site to contain excavated wastes
prior to off-site disposal.
Tanks must have sufficient shell
strength (thickness), and for closed
tanks, pressure controls, to assure
that they do not collapse or rupture
RCRA hazardous waste
listed or charac-
teristic, held for
temporary period be-
fore treatment, dis-
posal, or storage
elsewhere
(40 CFR 264.10) in a
tank.
40 CFR 264.190
"Applicable" to Alternatives C3 and
C4 as it may pertain to on-site
pretreatment of aqueous prior to
off-site disposal, and "applicable"
to Alternative D if on-site tank
storage is used to contain excavated
wastes prior to off-site disposal.
Tank
Storage
(On-Site)
Waste must not be incompatible with
the tank material unless the tank is
protected by a 1; ner or by other
means.
Tanks must be provided with controls
to prevent overfilling, and suf-
ficient freeboard maintained in open
tanks to prevent overtopping by wave
action or precipitation.
40 CFR 264.191
40 CFR 264.194
-------
ANU CKiiKKIA, ALA/ibUKitib fc UUilMNCfcb 1U tttl (DNSlDtlRfcl)
KIN-BUC FBaSIBILITY STUDY
Action
Tank
Storage
(On-Site)
cont.
Requirement
spect the following: overfilling control,
control equipment, monitoring data, waste
level (for uncovered tanks), tank condition,
above ground portions of tanks (to assess
their structual integrity) and the area
surrounding the tank (to identify signs of
leakage).
Repair corrosion, cracks, or leaks.
At closure, remove all hazardous waste and
hazardous waste residues from tanks, dis-
charge control equipment, and discharge
confinements structures.
Stores ignitable and reactive waste so as to
prevent the waste from igniting or reacting.
Ignitable or reactive wastes in covered
tanks must comply with buffer zone require-
ments in "Flammable" and Combustible Liquids
Code," Tables 2-1 through 2-6 (National Fire
Protection Association, 1976 or 1981).
iisite(s)
lous Page
Citation
40 CFR 264.195
40 CFR 264.196
40 CFR 264.197
40 CFR 264.198
Potential Applicabi
See Previous Page
f
Use liner and leachate collection and
removal system
RCRA hazardous
waste, noncon-
tainerized accum-
ulation of solid,
non-flammable
hazardous waste
that is used for
treatment or
storage.
40 CFR 264.251
"Applicable" to Alternative D if it
is necessary for any reason to con-
struct waste pile on site to contain
excavated wastes prior to off-site
disposal.
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APPENDIX 3
ACTION SPECIFIC STATE ARARS
AND CRITERIA, ADVISORIES & GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Prerequisite(s)
Citation
Action
Air Stripp-
ing
Requirement
An air pollution control permit
is required for any wastewater
treatment equipment if the con-
centration of certain delineated
toxic volatile organic substances
exceed 100 ppb by weight and the
total concentration of VDS exceed
3,500 ppb by weight. Must demon-
strate that controlled emissions
will not violate ambient air
quality standards as defined in
NJAC 7:27-13, Title 40 Part 52
CFR, or other department criteria
Mist demonstrate that the control
apparatus incorporates state-of-
the-art air pollution control
equipment, and is designed to
operate without violating laws
or regulations by presenting such
information as: description of
processes, raw materials, operat-
ing procedures, physical and
chemical nature of air contani-
nants, volume of gas discharge,
etc.
Action that includes
water or wastewater
treatment equipment
which emits air
contaminants includ-
ing: air stripping
equipment, aeration
basins and lagoons.
NJAC Title 7,
Chapter 27,
Subchapter 8.
Potential Applicability
Although under CERCLA Section 121(e),
on-site remedial response actions are
exempt fron having to obtain Federal,
State, or local permits, the substan-
tive requirements of this citation
may be considered "applicable" to Alerna-
tive C3 and C4 as it pertains to possible
on-site aqueous pretreatment (air stripping
prior to off-sito aqueous disposal.
Landfill
Vents
An air pollution control permit
is required. (See above dis-
cussion under air stripping.)
Action that includes
equipment used for
the purpose of vent-
ing a closed or
operating dump or
solid waste facility
directly or indirect-
ly into the outdoor
atmosphere.
NJAC Title 7,
Chapter 27,
Subchapter 8.
Although under CERCLA Section 121(e), on-
site remedial response actions are exempt
from having bo obtain Federal, State or
local permits, this citation may be con-
sidered "relevant and appropriate" to
Alternatives C3 and C4 as it pertains to
landfill venting.
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APPENDIX 3
ACTION SPECIFIC STATE ARARS
AND CRITERIA, ADVISORIES & GUIDANCES TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Action
Requirement
Prerequisite(s)
Citation
Potential Applicability
Off-Site
Transporta-
tion of
Hazardous
Waste
All vehicles containing hazardous waste
must meet the placard requirements of
USDQT transport of hazardous waste
(i.e., 49 CFR 171 through 49 CFR 177).
All containers shall be in confotmance
with the construction type and labeling
requirements (manifest numbers, etc.) of
USDOT containerization requirements
(49 CFR 171 through 49 CFR 179).
Special Hazardous Waste Manifest Form(s)
Requirements (which depends upon State
destination).
Special recordkeeping requirements and
prohibitions for the hazardous waste
generator, hauler, receiving facility.
etc.
On-site removal of
hazardous waste
for off-site
treatment/disposal
NJAC Title 7,
Chapter 26, Sub-
Chapter 7 (Label-
ing, Records, and
Transporation
Requirements).
NJAC Title 7,
Chapter 26, Sub-
chapter 8 (Hazar-
dous Waste
Criteria, Identi-
fication and
Listing).
Directly "applicable" to Alternative
D. Maybe partially applicable to !
Alternatives C3 and C4 as pertains
to:
0 On-site pretreatment of aqueous
for removal of PCB laden oil for
off-site disposal/treatment, and
0 Collection of on-site aqueous
waste stream for off-site treat-
ment/diposal (this would depend
upon contaminant concentrations
in the aqueous waste stream).
Direct Dis-
charge of
Treatment
System
Effluent
No person shall build, install, modify,
or operate any facility for the collec-
tion, treatment or discharge of any
pollutant except in confotmance with the
New Jersey Pollutant Discharge Elimina-
tion System (NJPDES) Program. The
NJPDES Program requirements include,
where applicable, permits or approvals
for both on-site treatment with direct
surface water discharge, as well as dis-
charge to off-site municipal or
privately owned treatment works.
NJAC 7:14A
Applicable* to Alternatives C3 and
C4 as it pertains to both: possible
on-site aqueous pretreatment for
off-site discharge to a POTrt, as
well as to possible on-site aqueous
treatment with direct surface water
discharge.
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APPENDIX 3
ACTION SPECIFIC STATE ARABS
AND CRITERIA, ADVISORIES & GUIDANCE TO BE CONSIDERED
KIN-BUC FEASIBILITY STUDY
Action
Requirements
Prerequisite(s)
Citation
Potential Applicability
ppj
lie
Discharge to
POTtf or Other
Aqueous Treat-
ment Works Via
Sewer
No persons shall cause, suffer,
allow, or permit the discharge
of any hazardous waste into a
sewer system unless:
i.
Final approval has been
obtained fron all
appropriate State and
local authorities; and
0 All conditions imposed prior
to discharge are met
NJAC Title 7,
Chapter 26 Sub-
Chapter 9
(Requirements for
Hazardous Waste
Facilities)
Section 2.
Directly "applicable" to Alternatives C3 and
C4 as pertains to discharge of aqueous via
sewer line to off-site POTW treatment
facility. .
Container
Storage On-
Site
Presents standards for use and
management of on-site container
storage of hazardous waste.
Includes separation of incom-
patible waste materials, safety
considerations, environmental
protectiveness considerations,
recordkeeping, monitoring,
inspection, training, etc.
On-site re-
moval of hazar-
dous waste in
preparation for
off-site dis-
posal/treatment
NJAC Title 7,
Chapter 26, Sub-
May be directly "applicable" to Alternative
D and partially "applicable" to Alternative
Chapter 9 Require- C3 and C4 as pertains to on-site preteat-
ments for
Hazardous Waste
Facilities),
Section 4, and
NJAC Title 7,
Chapter 26, Sub-
chapter 10 (Add-
itional Operation
and Design
Standards),
Section 4.
ment of aqueous for removal of PCB laden
oil for off-site disposal/treatment.
Groundwater
Monitoring
Must institute groundwater
monitoring in accordance with
NJAC 7:124 A-6 (Rule of the
Division of Water Resources).
NJAC Title 7,
Chapter 26, Sub-
Chapter 9
(Requirements for
Hazardous Waste
Facilities)
Section 5.
"Relevant and appropriate"
A, C3 and C4.
to Alternatives
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ACTION SPECIFIC STATE ARARS
AND CRITERIA, ACtflSORIEStftGUKANCES TO BE CONSIDERED
KIN-BU
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APPENDIX 3
ACTION SPECIFICS STATE ARARS
KIN-BUC FEASIBILITY STUDY
ACTION
REQUIREMENT
PREREQUISTITE(S)
CITATION
POTENTS APPLICABILIY
Closure with Haste
In-Place(Capping)cont.
Drainage and! erosion
control standanrds.
Gas venting and gas
montoring requirements.
See previous page
See previous page
Chemical, Physical, and
Biological Treatment
General operating and
inspection requirements
NJAC Title 7, Chapter
Subchapter 9,(Addition
-al Requirements for
Hazaradous Waste
Facilities Operating
under Exsisting Facil
-ity Status),Section 7
"Applicable" to
Alternatives C3 and
C4 as it pertains
to possible on-site
pretreament of
aqueous prior to
removal for off-
site treatment.
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1
>
1
i
: APPENDIX 4
t COMMUNITY RELATIONS HISTORY
V
Operational practices at the landfill in the early to mid-19701s
resulted in a large number of citizens complaints/ caused frequent
on-site fires and a number of serious occupational injuries. The
available information on community concerns indicates that these
compliants began prior to 1976.
An article published in the Newark Star-Ledger on May 14, 1976,
refers to a petition by "angry residents" who complained of air and
water pollution and several chemical fires caused by the Kin-Buc
Landfill. According to this article, several citizens have complained
to-Township regarding the local government's inability to stop both the
noxious smoke that emanated from the site when it burned and the trucks
that drove through residential areas at 4:00 a.m. on the way to the
landfill.
Several articles published in local newpapers in the following year
presented developments at the site, including the closure plan that
DEP had accepted from Kin-Buc, the extension to the closure deadline
that the site was issued by the Superior Court, and'the June 1976
formation of a citizens' group known as "Citizen's Committee to
Close Kin-Buc". According to these articles, the Citizens Committee
discovered that Kin-Buc had been issued an extention in March 1977
allowing it to remain open until June and promptly began a letter-
writing campaign to high-ranking State officials. The leader of the
group stated that the Township had not been given sufficient notice
to fight the extension. The Township appealed the extension and the
Superior Court Judge deciding the case initially revoked the extension,
but reinstated it five weeks later.
Following the eventual closure of the site, public interest sub-
sided and the citizens began to concentate on getting the site cleaned
up. In July 1981, a citizens' group called "Coalition to Contain Kin-
Buc* wrote a letter to Senator Bill Bradley asking his help in forcing
EPA to name the site as a priority. Senator Bradley forwarded the
letter to the Acting Regional Administrator for EPA, Region II. The
site was added to the National Priorities List of hazardous waste sites
(NPL) in October 1981. At time of the NPL listing, EPA proposed an
experimental hazardous waste incinerator as a 'possible remedial measure
for the site. This proposal met with extension public-opposition and
was subsequently dropped. £
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Appendix 4
-2-
The following year, 95 residents of the area surrounding the Kin-
Buc site filed a lawsuit against the Township and 600 businesses that
allegedly disposed of waste at Kin-Buc to collect damages caused by
contamination from the landfill. The Township settled out of court
and in 1985 citizens lobbied for a jury trail for the lawsuit
against the remainder of the defendants. The right to a jury
trial was eventually granted in 1986. The citizens and defendants
reached a 2.7 million dollar settlement in May 1988.
Although the Kin-Buc site received much media and community attention
during its years of operation, the frequency of complaints or spoken
concerns on the part of the public declined dramatically following
closure of the site. Of the few concerns that have arisen in the
recent past, according to those interviewed, the most prevalent is
the danger of adverse human health resulting from direct contact
with the contaminants at the site. Concerned parties cite air,
groundwater, and surface water s primary means for human contact
with the hazardous materials.
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APPENDIX 5
RATIONALE FOR OPERABLE UNIT II COMPONENTS
Mound B ::
sr
Although it is believed that the majority of hazardous waste
disposal occurred in the Kin-Buc I mound; little is known about
the contents of Mound B. It is believed that municipal trash
extends beneath Mound B. However, Mound B was not a subject
of the remedial investigation or previous investigatory work
dating to the mid-1970's. In addition, Mound B is physically
separated by the Edison Landfill access road. For these reasons,
EPA determined that the need to evaluate the nature and extent
of contamination in Mound B could be conducted as part of
Operable Unit II.
* Raritan River/Mill Brook/Martins Creek/Edmonds Creek
Initial attempts to determine the nature and extent of surface
water and sediment contamination date back to 1974 by analyzing
samples from the Raritan River. Sampling and analysis of the
Raritan River conducted to date has been sporadic and does not
take into account potential seasional .variations in contaminant
movement. Limited analytic data indicate the potential for
surface water and sediment contamination in the Raritan River
from groundwater discharges and surface run-off from the site.
However, the selected remedy for Operable Unit I would provide
source control measures such that the Raritan River and sediments
would no longer be a receptor of releases from the site. Remedy
selection for source control measures at the site is considered
the critical pathway in the overall site clean-up.
The Mill Brook and Martins Creek surface waters have not been the
focus of any detailed investigatory work. Limited sampling and
analysis of Martin Creek sediments indicate potential PCB
contamination due to leachate from the site entering Martins
Creek. Currently, control measures at the site prevent the release
of leachate into Martins Creek. The selected remedy for
Operable Unit I provides source control measures to prevent
releases to Martins Creek from the site.
Edmonds Creek sediments were the focus of a sampling program
conducted in 1983. Until installation of the Kin-Buc I cap
in 1980 and on-going control measures, leachate was released
into Edmonds Creek from Pool C via a connecting channel.
Sampling and analysis to date indicate PCB contamination in
Edmonds Creek. In additional, several fish and inverterbrate
species from Edmonds Creek were shown to have elevated levels
of contaminants in their tissue. However, the nature and extent
of contamination needs to be evaluated more extensively.
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Appendix 5
-2-
0 adjacent wetlands -
The wetlands adjacent to the Kin-Buc Landfill site have never beea
the focus of any previous investigations. Potential environmental
effects of uncontrolled releases from the site exist. Various
aquatic and terrestrial species utilize the adjacent wetlands as
their habitant. Therefore, the need to fully evaluate the nature
and extent of contamination and any environmental effects of
such contamination exists.
groundwater contamination emanating from the site
The hydrogeology of the site is complex and has not been fully
characterized. Uncertainties exist, for example about the nature
and extent of bedrock aquifer contamination and the possibility
of a connection between the sand and gravel aquifer and the
Raritan River. The extent of migration of contaminants in the
groundwater has not-been fully evaluated to date.
The evaluation of the components of Operable Unit II were deferred
so as not to delay implementation of source control measures at
the site.
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