United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/106
September 1990
oEPA
Superfund
Record of Decision:
Lone Pine Landfill, NJ
Printed on Recycled Paper
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/106
3. Recipient's Accession No.
4. Title and Subtitle
RECORD OF DECISION
Pine Landfill, NJ
Remedial Action - Final
5. Report Date
09/28/90
7. Author(i)
8. Performing Organization Rapt No.
9. Performing Organization Name and Addrea*
10. Pro|ect/Taak/Work Unit No.
11. Contract(C) or Grant(C) No.
(C)
12. Sponsoring Organization Name and AddreM
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Hole*
16. Abstract (Limit: 200 words)
The 45-acre Lone Pine Landfill site is an abandoned, privately owned waste disposal
facility in Freehold Township, Monmouth County, New Jersey. The site lies within a
semi-wooded wetlands area, and in the Manasquan River floodplain. Contaminated ground
water underlies the site within the surficial Water Table Aquifer and the deeper Red
Bank Aquifer. Ground water from both aquifers discharges into the Manasquan River
iwngradient from the site. From 1959 to 1979, municipal, commercial, and industrial
stes, including approximately 17,000 drums containing hazardous waste, tanks
containing liquid chemicals, and containers of chemical sludges, were disposed of
onsite. Following a chemical fire in 1977 and an explosion at the site in 1978, the
State ordered the owner to mitigate the potential environmental damage. In 1979, when
the owner failed to comply, the State ordered the landfill closed, and the site was
abandoned. A 1984 Record of Decision (ROD) addressed Operable Unit One (OU1), the
source control remedy, which included constructing a landfill containment system;
capping the landfill; installing a slurry wall around the landfill perimeter; and
collecting and treating leachate from within the slurry wall containment area. This ROD
addresses OU2, contaminated ground water outside of the containment system. The primary
(See Attached Page)
NJ
17. Document Analysis a. Descriptor*
Record of Decision - Lone Pine Landfill,
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, phenols, TCE, toluene, xylenes), metals
(arsenic, chromium, lead)
b. Mentffiers/Open-Ended Terms
c. COSATI Held/Group
18. AvallabUty Statement
19. Security Qu* (Thi* Report)
None
20. Security CUM (Thi* P»ge)
None
21. No. of Page*
85
22. Price
(See ANS-Z39.18)
See Instruction* on R»nne
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/106
Lone Pine Landfill, NJ
ond Remedial Action - Final
Abstract (Continued)
contaminants of concern affecting the ground water are VOCs including benzene, PCE,
phenols, TCE, toluene, and xylenes; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes pumping and treating ground water
after installation of an interceptor drain parallel to the Manasquan River that is
keyed into the Water Table Aquifer to capture contaminated ground water; supplementing
the drain with extraction wells screened within the Red Bank Aquifer; constructing an
onsite wastewater treatment plant consisting of an air stripper to remove VOCs,
precipitation/filtration for removal of metals, and carbon adsorption to treat
recovered ground water; dewatering and testing of residual solids to determine proper
method for offsite disposal; reinjecting the treated ground water into the Red Bank
Aquifer or discharging into a recharge trench onsite; conducting long-term monitoring
of ground water, surface water, river sediments and biota; and implementing
institutional controls including deed restrictions and land and ground water use
limitations. The estimated present worth cost for this remedial action is
$10,267,661, which includes an annual O&M cost of $482,600.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water cleanup goals include
benzene 1 ug/1 (State MCL), PCE 1 ug/1 (State MCL), phenols 0.0035 ug/1 (State), TCE 1
ug/1 (State MCL), toluene 50 ug/1 (State MCL), xylenes 44 ug/1 (State MCL), arsenic
50 ug/1 (State MCL), chromium 50 ug/1 (State MCL), and lead 50 ug/1 (State MCL).
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DECLARATION STATEMENT
RECORD OF DECISION
LONE PINE LANDFILL SITE
SITE NAME AND LOCATION
Lone Pine Landfill
Freehold Township, Monmouth County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Lone Pine Landfill
site, in Freehold Township, New Jersey, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response, Compensation, and Liability-
Act of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986
and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision document explains the factual and legal basis for selecting
the remedy for this site.
The New Jersey Department of Environmental Protection concurs with the selected remedy.
The information supporting this remedial action decision is contained in the administrative
record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision, may present an
imminent and substantial threat to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this document represents the second of two planned
operable units for the site. A landfill containment system including a cap, slurry wall and
leachate collection/treatment will be implemented as part of the first operable unit. This
action will address the contaminated ground water outside of the containment system.
Once implemented, the above actions will effectively eliminate the landfill as a source of
contamination to area ground water and the nearby Manasquan River. However, because
of the lengthy period of time projected to clean up the ground water, long-term
management and controls will be necessary.
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-2-
The major components of the selected remedy for the second operable unit include the
following:
Extraction and on-site treatment of the contaminated ground water;
Reinjection of the treated water back into the ground;
Environmental monitoring of the aquifers and the Manasquan River, including
additional sediment and biota studies; and
Institutional controls to ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with
Federal and State requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost-effective. This remedy utilizes permanent solutions and
alternative treatment (or resource recovery) technologies to the maximum extent
practicable, and it satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances remaining on the 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.
Constantine Sidamon-Eristoff// Date
Regional Administrator '/'/
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ROD FACT SHEET
SITE NAME:
LOCATION:
REGION:
MRS SCORE & DATE:
NPL RANK:
ROD
DATE SIGNED:
REMEDY:
CAPITAL COST:
O&M/YEAR:
PRESENT WORTH:
LEAD:
PRIMARY CONTACT:
SECONDARY CONTACT:
MAIN PRPs:
PRP CONTACT:
WASTE
TYPE:
MEDIUM:
ORIGIN:
ESTIMATED QUANTITY!
LONE PINE LANDFILL (SECOND OPERABLE UNIT)
FREEHOLD TOWNSHIP, MONMOUTH COUNTY, NEW
JERSEY
2
9/83, GROUP 1, 66.3
15
9/28/90
GROUND WATER EXTRACTION/TREATMENT (GRANULAR
ACTIVATED CARBON)/REINJECTION
$ 5,441,662
$ 482,600
$10,267,661
ENFORCEMENT/EPA/PRP
SHARON JAFFESS, RPM, FTS 264-2598
JANET FELDSTEIN, SECTION CHIEF, FTS 264-0613
> 300 PRPs, INCLUDING FREEHOLD CARTAGE, SCP,
NESTLE, COCA COLA, GE, LONE PINE CORP.,
DUPONT, 3M, CIBA-GEIGY, CHEMICAL CONTROL, ..
NOT CURRENTLY AVAILABLE
VOLATILE ORGANICS, METALS
GROUND WATER & SURFACE WATER
LANDFILL
GROUND WATER CONTAMINANT PLUME COVERS
APPROXIMATELY 90 ACRES TO A DEPTH OF
APPROXIMATELY 100 FEET BELOW GRADE. GROUND
WATER PLUME DISCHARGES INTO THE MANASQUAN
RIVER.
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DECISION SUMMARY FOR THE RECORD OF DECISION
LONE PINE LANDFILL SITE
SITE DESCRIPTION
Location
The Lone Pine Landfill (site) is located in Freehold Township, Monmouth County,
New Jersey. It is in a rural, marshy area five miles southwest of the town of.
Freehold, and one-half mile southeast of the intersection of Route 537 and Elton-
Adelphia Road. The landfill is situated about 300 feet south of the Manasquan River,
and about 1000 feet west of the Turkey Swamp Fish and Wildlife Management Area.
It is bounded to the east and south by Burke Road and to the west by a swamp which
drains into the Manasquan River at the landfill's northern boundary (Figure 1).
The landfill mound rises about 45 feet above the natural grade. It occupies an area of
approximately 45 acres within a 144-acre, mostly wooded parcel owned by the Lone
Pine Corporation.
The area in the vicinity of the site is rural to suburban with only about half a dozen
residences in the immediate vicinity, the closest being about 600 feet south of the
landfill. A local sportsman club, the Fin, Fur and Feather Club, is located about 100
feet to the east of the landfill. A 700-acre municipal potable water supply reservoir
has been constructed at a location 16 miles downstream of the landfill off the
Manasquan River. The Manasquan River, in its reach adjacent to the site and
downstream approximately 16,000 feet to Jackson Road, is classified as Fresh Water 2
- Nontrout (FW2-NT). This classification designates it for maintenance, migration and
propagation of natural biota, primary recreation, industrial, agricultural, and public
water supply with treatment.
Topography. Hydrology, and Geology
The on-site topography is relatively flat but gradually slopes toward the Manasquan
River to the north. The site lies within the 2.4 square mile subbasin of the regional
Manasquan River watershed. Surface waters within the subbasin drain into tributaries
of the easterly flowing Manasquan River. Ground water discharge in the immediate
vicinity of the landfill provides a major source of water for the Manasquan River,
which has a variable flow rate of approximately 2 to 70 cubic feet per second (cfs).
The ground water in the vicinity of the site is currently utilized as a source of
drinking water and is classified as such.
Figures 2 and 3 show a generalized geologic cross section beneath the landfill and
delineate the geologic formations and corresponding hydrologic units. The geology is
typical of the Atlantic Coastal Plain Physiographic Province; gently southeastward
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dipping unconsolidated marine and fluvial deposits of clay, silt, sand, and gravel. The
shallow geologic units beneath the landfill in descending order are the Vincentown
Formation and the Homerstown Formation of Tertiary age, and the Red Bank
Formation, Navesink Formation, Mount Laurel Formation and Wenonah' Formation of
Late Cretaceous age.
The Vincentown Formation is a medium-grained sand which is absent north of the
landfill and is up to 30 feet thick on the south side of the landfill. The Homerstown
Formation is a silry, fine-grained sand with varying amounts of clay that is considered
to be a confining layer. The Red Bank Formation, which is 50 to 60 feet in thickness,
contains four distinct lithologic units. The upper unit is a partially indurated, silry,
fine-grained sand which is about 10 feet in thickness. The next unit, which is called
the Tinton Sand Member, is 5 to 10 feet in thickness; it is a ferric carbonate
sandstone. Beneath the Tinton Sand Member is a poorly sorted, medium- to coarse-
grained sand, 10 to 35 feet in thickness. The basal unit is a massive, silry, fine-
grained sand, which is 10 to 20 feet in thickness. The Navesink Formation is a
massive, poorly sorted, clayey sand that is about 30 feet in thickness. This formation
is considered to be a confining layer that separates the Wenonah-Mount Laurel aquifer
system from the overlying Red Bank Formation.
The uppermost saturated units (Vincentown and Homerstown Formations) comprise
what is referred to as the Water Table aquifer. Horizontal flow in the Water Table
aquifer is from the landfill toward the river. Calculated ground water flow velocity
from the landfill to the river ranges from 80 to 740 feet per year. Horizontal ground
water flow in the underlying Red Bank aquifer is also toward the river from the
landfill, with calculated velocities ranging from 12 to 91 feet per year. Vertical
ground water flow in the vicinity of the landfill is downward from the Water Table
aquifer to the Red Bank aquifer beneath the landfill, and is upward in the valley of
the Manasquan River. Vertical ground water flow is also upward over the entire area
from the Navesink Formation to the Red Bank aquifer. Figure 4 is a schematic
diagram which depicts ground water flow in the vicinity of the landfill. Detailed
potentiometric maps of the Water Table and Red Bank aquifers are located in the
Remedial Investigation and Feasibility Study (RI/FS) reports.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Lone Pine Landfill began operation in 1959 and throughout its history was
operated by the now defunct Lone Pine Corporation. Until it was closed, the landfill
accepted a wide variety of wastes for disposal, including municipal, commercial and
industrial wastes. In addition, the landfill received thousands of drums containing
chemical wastes from the facilities of Scientific Chemical Processing Company (SCP) in
Newark and Carlstadt, New Jersey. Drums, as well as tankers of liquid chemicals and
containers of chemical sludges, were transported to the Lone Pine Landfill by Taylor
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Pumping Services, Inc. and disposed of at the landfill.
In the early 1970's, the New Jersey Department of Environmental Protection (DEP)
unsuccessfully attempted to force the Lone Pine Corporation, the owner and operator,
to update its operation to minimize the leachate and surface runoff problems at the
landfill. Following a DEP sampling investigation in 1977 and a chemical fire and
explosion at the site on June 23, 1978, DEP issued an administrative order directed at
mitigating potential environmental damage from the site. Failure by the Lone Pine
Corporation to meet the requirements of the administrative order resulted in a DEP's
issuance of a closure order in April 1979. This closure order required the termination
of waste disposal at the site after November 1979. The site has been abandoned since
landfill operations ceased. DEP filed suit against Lone Pine Corporation and its
principals in October 1979 to ensure proper closure.
Due to the enactment of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), 42 U.S.C. §9601 et seq. in 1980, the United States
Environmental Protection Agency (EPA) assumed the lead role in the investigation of
the landfill and took over enforcement activity from DEP. In addition, in 1980, a
United States Grand Jury for the District of New Jersey investigated activities at the
Lone Pine Landfill and indicted SCP and its three officers and Taylor Pumping
Services, Inc. for conspiracy to obstruct a grand jury investigation.
In 1981, the site was ranked in the top 20 sites on EPA's Interim National Priorities
List and the Lone Pine Corporation filed a "Notification of Hazardous Waste Site" form
for the Lone Pine Landfill with EPA Region II, pursuant to Section 103(c) of CERCLA,
42 U.S.C. §9603(c). During 1981 and 1982, EPA and DEP pursued various studies
and investigations, seeking to ascertain the extent of the contamination emanating
from the site and to determine the potential threat to public health and the
environment. These studies included a subsurface investigation (magnetometric) to
map concentrations of buried metal (drums), a drum excavation and sampling
program, and a hydrogeological investigation.
The magnetometric study in the summer of 1981 indicated the possible presence of
tens of thousands of steel drums. It was later determined that at least 17,000 drums
containing chemical wastes were illegally disposed of in the landfill by SCP. EPA
performed a limited drum excavation and sampling program. A total of 69 drums
were excavated. Of these, 35 had retained partial contents with 25 drums containing
sludge, and 10 containing liquid. A variety of organic priority pollutant substances,
heavy metals, and pesticides were contained in these drums.
The results of a fall 1981 - winter 1982 hydrogeological investigation indicated severe
ground water contamination in both the surficial Vincentown and Hornerstown
Formations (Water Table aquifer) as well as the deeper Red Bank Formation (Red
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Bank aquifer).
After learning the identities of some of the potentially responsible parties (PRPs), and
before beginning a FS to evaluate remedial alternatives, EPA sent "notice" letters to
the identified PRPs on July 6, 1982 and September 3, 1982. These letters informed
the PRPs that they "...may be a responsible party with respect to releases and
threatened releases..." of hazardous substances at the site. These letters also offered
the PRPs the opportunity to perform the FS. No PRP was willing to undertake an FS
so EPA continued its investigation.
In July 1982, EPA and DEP signed a State Superfund Contract to undertake the FS at
the landfill. EPA held a public meeting on September 16, 1982 to outline its
proposed work. EPA then took several actions: ground water and surface water
(Manasquan River) were re-sampled in September 1982; aquifer tests were conducted
in the fall of 1982 to determine the hydrologic properties of the aquifers; additional
ground water monitoring wells were installed in April 1983; additional ground water
sampling was conducted in April 1983; landfill leachate seeps were sampled in April
1983; and surface water/sediment (Manasquan River) sampling was conducted in
April 1983. Private ground water wells in the vicinity of the landfill were sampled in
1984.
The sampling data indicated that volatile organic compounds (VOCs), primarily
benzene, toluene, and ethylbenzene, as well as heavy metals, have leached from the
landfill and contaminated the ground water. The contaminated ground water was
found to extend in a northeasterly direction from the site to the Manasquan River. In
addition, contaminated surface water runoff and leachate from the landfill were found
to be discharging into the Manasquan River. No contamination from the landfill was
detected in existing drinking water supplies in the vicinity of the landfill.
In March 1983, the United States District Court for New Jersey obtained criminal
convictions against SCP and its three officers as well as the transporter and the
landfill manager for conspiracy and one defendant for mail fraud. U.S. v. Case, et al..
Crim. No. 82-200 (D.N.J. 1983). At trial, the government presented evidence that at
least 17,000 drums of chemical waste were transported for disposal to the Lone Pine
Landfill from SCP's two facilities in Newark and Carlstadt, New Jersey.
In 1983, additional PRPs were identified; the Lone Pine Corporation defendants in
DEP's October 1979 suit impleaded nearly 100 third-party defendants who allegedly
had used the landfill for waste disposal. The DEP action has been stayed pending
resolution of EPA's CERCLA proceedings.
In June 1983, EPA released for public comment a three-volume "Draft Feasibility
Study Evaluation of Remedial Action Alternatives" (Draft FS), prepared by EPA's
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consultants, Camp, Dresser & McKee (COM). This Draft FS presented several remedial
action alternatives, ranging from no action to total excavation and removal of
contaminants.
A public meeting was held on June 24, 1983, to discuss the Draft FS and EPA's work
regarding the site. EPA expressed a preference for a plan which would involve
placement of a clay cap over the landfill, construction of an underground slurry wall
around the landfill, and pumping and treatment of contaminated ground water. Local
citizens favored complete excavation and removal of drums from the site. In response
to comments received, EPA decided to perform additional sampling and a supplemental
FS, evaluating additional remedial options for the site. In September 1983, the site
was placed number 15 on EPA's National Priority List.
The additional ground water and surface water sampling was conducted in February
and March 1984. As pan of a leachate treatability study, a well was installed at the
northeastern toe of the landfill in May 1984. In addition, air quality monitoring was
performed in June 1984.
The supplemental FS was released for public comment on June 27, 1984. EPA held
another public meeting on August 1, 1984. In September 1984, prior to issuance of
the Record of Decision (ROD), EPA sent notice letters to approximately 140 PRPs,
offering them the opportunity to undertake the Remedial Design and Remedial Action
(RD/RA) prior to initiation of a fund-financed response. No PRP offered to undertake
any part of the proposed remedial plan. On September 28, 1984, EPA issued the ROD
for the Lone Pine Landfill, after analysis and consideration of all comments received.
The ROD adopted EPA's preferred remedial plan. The remedy selected required:
• Installation of an impermeable cap and methane gas venting system to reduce
infiltration of precipitation and eliminate the problem of methane gas build-up
from decaying garbage beneath the cap;
« Installation of a slurry wall around the perimeter of the landfill to control the
migration of contaminants and ground water through the area;
• Installation of a ground water/leachate collection and treatment system to
prevent contamination from leaching through and under the slurry wall; and
• Performance of an additional RI/FS to determine the nature and extent of off-
site ground water contamination and to assess the need for further off-site
remediation.
Since no PRP offered to perform the remedy adopted in the ROD, EPA initiated the
remedial design utilizing public funds.
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In October 1984, the Lone Pine Steering Committee (a group of PRPs) filed suit,
seeking to block implementation of EPA's remedial cleanup plan. The district court
granted EPA's motion to dismiss, ruling that neither CERCLA, 42 U.S.C. § 9601 et seq.
nor the Administrative Procedure Act authorized pre-enforcement review of EPA's
remedial plan. Hone Pine Steering Committee v. EPA. 600 F.Supp. 1487 (D.N.J.
1985)]. That ruling was upheld on appeal, 777 F.2d 882, by the United States Court
of Appeals for the Third Circuit. In February 1986, the Lone Pine Steering Committee
filed a petition for a Writ of Certiorari with the United States Supreme Court to block
implementation of EPA's cleanup plan. The Supreme Court denied the Lone Pine
Steering Committee's petition in May 1986 [106 S.Ct. 1970 (1986)].
During this period of protracted litigation, EPA, in consultation with the United States
Army Corps of Engineers, prepared the remedial design required for implementation of
the remedy.
In July 1985, EPA sent notice letters to the 140 PRPs, offering them the opportunity
to enter into an Administrative Order on Consent to perform the additional
hydrogeologic investigation described in the ROD (off-site RI/FS), as well as the
opportunity to implement construction of the selected remedy. None of the PRPs
offered to undertake the construction activities. However, the Minnesota, Mming, &
Manufacturing Company (3M) agreed to perform the off-site RI/FS. This RI/FS was
performed, under EPA oversight, pursuant to Administrative Order Index Number II-
CERCLA-50110, issued by EPA on September 27, 1985 to 3M.
In September 1985, EPA sent additional notice letters to approximately 200 newly
identified PRPs. These parties were offered the opportunity to implement construction
of the selected remedy, upon completion of the fund-financed remedial design. No
panics voluntarily offered to undertake the construction, and EPA continued with the
remedial design.
During 1986 and 1987, representatives of the Lone Pine Steering Committee
continued to urge EPA to alter the remedial plan set forth in the 1984 ROD. In May
1987, EPA responded to the Lone Pine Steering Committee's "Motion to Reopen the
Record and Modify Record of Decision", dated March 19, 1986, and the "Motion to
Supplement Record and Segment Remedial Implementation", dated March 25, 1987,
and other letters and data submitted after issuance of the ROD. In a detailed
technical response, EPA rejected the specific factual allegations made in the FRPs'
"motions", and rejected the Steering Committee's request to reopen the ROD and
modify the selected, remedy.
In February 1988, the Lone Pine Steering Committee met with EPA to discuss the
possibility of settlement. In the Spring and again in the Fall of 1988, in an effort to
identify additional PRPs, EPA sent out additional letters requesting information from
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PRPs. By letter dated February 7, 1989, EPA invited all PRPs to a meeting to discuss
imminent EPA construction activities and to encourage private party implementation of
the remedial action. At that meeting, EPA informed representatives of the PRPs that
they had until May 15, 1989 to reach a settlement to implement the remedy.
Negotiations ensued which culminated in a settlement for a privately-funded remedial
action.
The settlement, embodied in a Consent Decree, provides for private party
implementation of EPA's selected remedy, as set forth in the ROD and EPA-completed
remedial design, and for post-remedial monitoring, operation and maintenance. EPA
estimates that the remedy will cost approximately $36 million. The Consent Decree
also provides for reimbursement of $1,372.86 in Agency for Toxic Substances and
Disease Registry (ATSDR) costs. The work to be performed pursuant to the Consent
Decree addresses only the first of the two operable units for the site, the landfill
containment system selected in the 1984 ROD. The second operable unit consists of
the remedial action for off-site ground water contamination, which is the subject of
this ROD and subsequent RD/RA negotiations.
The Consent Decree was lodged for public comment with the United States District
Court for New Jersey on August 25, 1989. A number of PRPs who did not join the
settlement intervened in the proceedings and attempted to block the entry of the
Consent Decree. On March 5, 1990, in the United States District Court for New
Jersey, the non-settlors' opposition to the Consent Decree was heard. At the
conclusion of the oral argument, the Court approved and entered the Consent Decree.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS Report and the Proposed Plan for the site were released to the public for
comment on July 17, 1990. These two documents were made available to the public
in the administrative record file, located at information repositories maintained at the
EPA Docket Room in Region II, the Monmouth County Public Library and the
Freehold Township Health Department. The notice of availability for these documents
was published in the Asburv Park Press on July 17, 1990. A public comment period
was held from July 17, 1990 to September 15, 1990. In addition, a public meeting
was held on August 1, 1990. At this meeting, representatives from EPA answered
questions related to the site and the remedial alternatives under consideration. A
response to the comments received during this period is included in the
Responsiveness Summary, which is part of this ROD.
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SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE
STRATEGY
The scope of this response action is to address the remaining concerns" (principal
threats) at the site. As discussed, a previous remedy was selected at the site in 1984.
This remedy, which consists of a landfill containment system, is known as the first
operable unit remedy.
The second operable unit remedy, as described herein, is necessary to address
contaminated ground water emanating from the site. The primary goal of this remedy
is to prevent the migration of contaminants into the Manasquan River and other areas.
In addition, long-term restoration of the aquifer between the landfill and the river will
also be achieved through implementation of the selected remedy. The goals will be
met through implementation of a ground water extraction and treatment system.
The selected alternative for the second operable unit remedy, in conjunction with the
first operable unit landfill containment system, will address all concerns related to the
migration of contaminants from the landfill. Long-term monitoring of the Manasquan
River, including additional sediment and biota studies, will be conducted to address
any impacts of the contaminated ground water on the river environment. If
necessary, any additional response action required to address contamination of the
Manasquan River will be addressed as a third operable unit.
SUMMARY OF SITE CHARACTERISTICS
Contamination Present in the Landfill
Drums excavated from the landfill in 1981 provide a depiction of the types of
hazardous substances present in the landfill. A variety of organic substances, heavy
metals, and pesticides were found in rusted, ruptured drums in the form of liquid,
viscous material, sludge, and solids. Table 1 presents the hazardous substances and
the concentrations found in the sampled drums.
Ground Water Contamination
Ground water sampling was conducted during various hydrogeologic investigations at
the site from 1976 to 1989. The most recent sampling events occurred during the
second operable unit RI conducted by 3M under EPA oversight.
The ground water investigations at the site included both water quality and water
level sampling. The monitoring wells were placed in various locations to define the
vertical and horizontal extent of contamination. In order to determine the vertical
extent, ground water monitoring wells were screened in the Water Table aquifer
1
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(Vincentown and Homerstown Formations), the Red Bank aquifer, and in a
stratigraphic unit just below the Red Bank aquifer. In order to determine the
horizontal extent, the monitoring wells were placed directly through the landfill (on-
site wells) and downgradient and upgradient of the landfill (off-site wells). The
upgradient wells were used to determine background water quality (ground water
unaffected by the landfill). The locations of monitoring wells are shown on Figure 5.
Twelve off-site ground water monitoring wells were installed by 3M in 1986 for the
second operable unit RI. Seven of these wells were .installed north of the Manasquan
River to determine whether or not the contaminant plume had migrated north of the
river (four screened in the Water Table aquifer and three screened in the Red Bank
aquifer). Two of these wells were installed in Red Bank aquifer, south of the river
and east of the landfill to assess the eastern extent of contamination. Three of these
wells were installed northeast and east of the landfill, screened in a stratigraphic unit
just below the Red Bank aquifer, to assess the potential for downward ground water
flow from the landfill into deeper hydrologic units.
Sampling of all wells was conducted in 1986. In 1989, selected wells south and north
of the river were resampled. The on-site Water Table aquifer wells showed high
concentrations of VOCs such as benzene, chlorobenzene, trans-l,2-dichloroetbene, 1,1-
dichloroethene, 1,2-dichloroethane, methylene chloride, trichloroethylene and vinyl
chloride exceeding the federal and state Maximum Contaminant Levels (MCLs). In
1986, the total VOCs ranged from 323 to 471,000 parts per billion (ppb). All metals
on the Target Compound List, with the exception of beryllium and thallium, have been
reported in samples from these wells. The only dissolved metals that have been
reported at concentrations above their respective MCLs are arsenic, chromium and
selenium.
The off-site wells demonstrate that the ground water plume contains the same types
of contaminants found beneath the landfill. The off-site Water Table aquifer samples
showed high concentrations of benzene, chlorobenzene, trans-l,2-dichloroethene, 1,1-
dichloroethene, 1,2-dichloroethane, methylene chloride, trichloroethene, and vinyl
chloride exceeding the MCLs. Eighteen different VOCs were detected in the Water
Table aquifer. Sampling indicated that the total VOC concentration in the Water
Table aquifer ranged from 2 to 26,220 ppb. The off-site Red Bank samples showed
twelve of the eighteen VOCs detected in the Water Table aquifer. The total VOC
concentrations in the off-site Red Bank aquifer ranged from 7 to 6,093 ppb.
Metals were also detected off site in both aquifers. In the off-site downgradient wells,
arsenic, cadmium, chromium, iron, lead, and manganese exceeded the MCL of 50
micrograms per liter (ug/L) in 1986. However, upgradient well samples collected,
indicated the presence of cadmium, chromium, iron, lead, manganese, and zinc which
exceeded the MCLs. Therefore, with the exception of arsenic, upgradient sources
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other than the Lone Pine Landfill may be contributing metals to the ground water.
To date, no contamination from the landfill has been detected in existing drinking
water supplies. The nearest domestic wells include a residential well approximately
600 feet south (upgradient) of the landfill, a non-residential well approximately 1,000
feet east of the landfill (south of the Manasquan River), and several residential wells
1/2 mile north of the site and the Manasquan River. The nearest public water supply
well is 4 miles from the site in the Englishtown Formation, which is not impacted by
contamination from the site. No potable wells are currently located in the
contaminant plume.
The results of the second operable unit RI confirm the following:
• Ground water moves horizontally toward the Manasquan River in both the
Water Table and Red Bank aquifers. South of the river, ground water moves
generally northward toward the river. North of the river, ground water moves
generally southward toward the river.
• The Water Table and Red Bank aquifers are hydraulically connected. Near the
Manasquan River, ground water moves upward from the Red Bank aquifer into
the Water Table aquifer. In areas away from the river, ground water moves
downward, from the Water Table aquifer into the Red Bank aquifer. Ground
water that originates either south or north of the river eventually discharges
upward from the Red Bank aquifer into the Water Table aquifer and then
discharges from the Water Table aquifer into the Manasquan River.
• A ground water contaminant plume emanates from the landfill and moves in a
north-northeasterly direction, discharging into the Manasquan River, following
the flow paths of the Water Table and Red Bank aquifers. This plume is
limited to a strip of land from the landfill's western boundary to an area
immediately east of Burke Road and has not migrated north of the river
(Figures 6 and 7).
• There is no potential for dissolved contaminants in the Red Bank aquifer to
migrate downward to deeper aquifers.
« The contaminant plume emanating from the landfill in both the Water Table
and Red Bank aquifers contain VOCs and heavy metals at concentrations
exceeding the MCLs. The MCLs are listed in Table 2. Tables 3 through 6
contain the chemicals and concentration ranges detected in the Water Table and
Red Bank aquifers, on and off site, in 1986 and 1989.
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Surface Water Contamination
Surface water sampling has been conducted periodically in the Manasquan River near
the site since 1977. As part of the second operable unit RI, surface water samples
were obtained from the Manasquan River at sampling stations upgradient of the
landfill, immediately downgradient of the landfill (Burke Road), approximately 12,000
feet downstream of the landfill (Jackson Road), and approximately 16,000 feet
downstream of the landfill (Georgia Road) (Figure 5).
Due to the fact that horizontal ground water flow in the vicinity of the landfill is in a
northeasterly direction and discharges into the Manasquan River, the river has also
been contaminated by the landfill. This is verified by the presence of VOCs in the
river at surface water sampling stations downstream of the site during the 1986
sampling events. The VOCs detected at the Burke Road sampling station (RS-3A) are
methylene chloride, 1,2-dichloroethane, acetone, 2-butanone and 4-methyl-2-
pentanone. The VOCs detected at the seep sampling station (RS-3) are methylene
chloride, benzene, ethylbenzene, toluene, acetone, 2-butanone, 4-methyl-2-pentanone
and xylenes.
The Clean Water Act provides for the protection of existing and designated uses of
surface waters of the United States. Since this surface water is classified as FW2-NT,
a fishable and drinkable classification, EPA's ambient water quality criteria under the
Clean Water Act are ARARs.
No numeric water quality criteria are available in the state water quality standard
regulation. No ambient water quality criteria under the Clean Water Act are available
for xylenes, 4-methyl-2-pentanone, acetone and 2-butanone.
Ambient water quality criteria based on the protection of human health at the 106 risk
level for fish and water consumption have been exceeded at the seep station for
methylene chloride and benzene. These criteria have also been exceeded at the Burke
Road sampling station for methylene chloride and 1,2-dichloroethane.
Ambient concentrations of aluminum, iron, manganese and zinc exceeded the EPA
ambient water quality criteria upstream of the landfill. However, concentrations of
iron and manganese significantly exceeded upstream concentrations. In addition,
thallium was detected downstream at a level exceeding the EPA ambient water quality
criterion.
Contamination Summary
On-site ground water sampling data demonstrates that numerous hazardous substances
present in the sampled drums are also present in the Water Table aquifer beneath the
landfill. In addition, the off-site, downgradient wells screened in the Water Table and
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Red Bank aquifers contain many of the same hazardous substances as the on-site
wells. Furthermore, the contaminants found in the surface water are a subset of the
contaminants found in the landfill drums and ground water. Therefore, it is clear that
the landfill is a source of ground water and surface water contamination.
Table 7 illustrates some examples of the types of hazardous substances detected in
drums excavated from the landfill, in ground water within the landfill mound (on-
site), in ground water adjacent to the landfill (off-site), and in the Manasquan River.
SUMMARY OF SITE RISKS
EPA conducted an Endangerment Assessment (EA) of the "no action" alternative to
evaluate the potential risks to human health and the environment associated with the
Lone Pine Landfill site in its current state. The EA focused on the ground water
contaminants which are likely to pose the most significant risks to human health and
the environment (indicator chemicals). These "indicator chemicals" and their
concentrations in the ground water are shown in Table 8.
EPA's EA identified several potential exposure pathways by which the public may be
exposed to contaminant releases, including, exposure to ground water contaminants at
the site. There is currently no exposure through the ground water medium to the
nearby residents, since there are no private wells located within the contaminant
plume at this time. However, under a future land-use or plume migration scenario,
the area impacted by the site may be developed residentially and the ground water
used as a source of drinking water. The primary potential routes of exposure to
residents for that scenario are ingestion of contaminants in the ground water and
inhalation of ground water vapors (via showering).
A quantitative assessment of the risks associated with the ground water exposure
pathway was performed. Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and non-carcinogenic effects due to exposure to site chemicals are
considered separately. It was assumed that the toxic effects of the site-related
chemicals would be additive. Thus, carcinogenic and non-carcinogenic risks associated
with exposures to individual indicator compounds were summed to indicate the
potential risks associated with mixtures of potential carcinogens and non-carcinogens,
respectively.
Non-carcinogenic risks were assessed using a hazard index (HI) approach, based on a
comparison of expected contaminant intakes and safe levels of intake (Reference
Doses). Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects. RfDs, which are expressed in units of mg/kg-day,
are estimates of daily exposure levels for humans which are thought to be safe over a
lifetime (including sensitive individuals). Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from contaminated
drinking water) are compared with the RfD to derive the hazard quotient for the
contaminant in the particular media. The hazard index is obtained by adding the
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hazard quotients for all compounds across all media. A hazard index greater than 1
indicates that potential exists for non-carcinogenic health effects to occur as a result of
site-related exposures. The HI provides a useful reference point for gauging the
potential significance of multiple contaminant exposures within a single medium or
across media. The reference doses and hazard indices for the indicator chemicals at
the Lone Pine Landfill are presented in Table 9.
The hazard index for non-carcinogenic effects from exposure to ground water
contaminants is 9, suggesting that non-carcinogenic effects may occur.
Potential carcinogenic risks were evaluated using the cancer potency factors developed
by EPA for the indicator compounds. Cancer potency factors (CPFs) have been
developed by EPA's Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)'1, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with exposure to the compound
at that intake level. The term "upper bound" reflects the conservative estimate of the
risks calculated from the CPF. Use of this approach makes the underestimation of the
risk highly unlikely. The CPFs for the indicator chemicals and their corresponding
cancer risk levels are presented in Table 10.
For known or suspected carcinogens, the EPA considers excess upper bound individual
lifetime cancer risks of between 1 X 10"" to 1 X 10"6 to be acceptable. This level
indicates that an individual has not greater than a one in ten thousand to one in a
million chance of developing cancer as a result of exposure to site conditions. The
carcinogenic risks associated with exposure at the site are presented in Table 10. The
cumulative upper bound risk at Lone Pine Landfill is 3.5 x 10"'. The potential risks to
residents due to carcinogens at the site are greater than the acceptable EPA risk range
of 10' to 106.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all such
assessments, are subject to a wide variety of uncertainties. In general, the main
sources of uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the potentially uneven
distribution of chemicals in the media sampled. Consequently, there is significant
uncertainty as to the actual levels present. For example, as shown on Table 1, there
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are numerous chemicals found in landfill drums that have not yet been detected in
ground water. These substances could potentially contaminate the ground water. In
addition, environmental chemistry analysis error can stem from several sources
including the errors inherent in the analytical methods and characteristics of the
matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of how often an
individual would actually come in contact with the chemicals of concern, the period of
time over which such exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of exposure.
Uncertainties in lexicological data occur in extrapolating both from animals to humans
and from high to low doses of exposure, as well as from the difficulties in assessing
the toxiciry of a mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters throughout the
assessment. As a result, the EA provides upper bound estimates of the risks to
populations at the site, and is highly unlikely to underestimate actual risks related to
the site.
For more specific information concerning potential public health risks, including
quantitative evaluation of the degree of risk associated with the ground water
exposure pathway, please see the documents entitled Final Endangerment Assessment.
Lone Pine Landfill. Freehold. New Jersey and Exposure Calculations for Offsite Ground
Water. Lone Pine Landfill, located in the Administrative Record.
In summary, the risks associated with exposure to contaminated ground water were
quantitatively assessed. This assessment indicates that should exposure occur,
individuals would have an increased risk of cancer greater than EPA's acceptable risk
range, as well other non-carcinogenic health effects. As discussed in the EA, there
are several other potential exposure pathways which were not quantitatively assessed.
Ground water flows in a northeasterly direction from the landfill and recharges to the
Manasquan River. The Manasquan River provides drinking water to wildlife and
supports a variety of aquatic biota further downstream. Downstream of the site, the
river is currently used for canoeing, sport fishing, limited irrigation, and nature walks
along its banks. In addition, a potable water reservoir has been constructed with its
intake on the Manasquan River approximately 16 miles downstream of the site. Since
contaminants are discharging to the river, individuals using the river for recreational
purposes could be exposed to contaminants. In addition, a macroinvertebrate survey
was conducted by DEP in the Manasquan River near the site in 1988, and it was
concluded that there are adverse impacts to the macroinvertebrate community.
Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this ROD, may present an imminent
and substantial endangerment to public health, welfare, or the environment.
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DESCRIPTION OF ALTERNATIVES
Remediation Goals
Appropriate remedial technologies identified during the screening proce.ss of the FS
were assembled into combinations to address the remedial action goals for the site.
These goals are:
• To prevent the discharge of contaminated ground water from the Water Table
and Red Bank aquifers into the Manasquan River;
• To prevent further migration of the contaminant plume; and
» To restore the contaminated ground water between the landfill and the river to
beneficial uses.
Note that restoration of the contaminated ground water under this second operable
unit includes only thai area of contaminated ground water outside the boundary of
the landfill containment system (area of attainment). Therefore, as shown in Figure
7, the area of attainment for the Red Bank aquifer includes a 23 acre area northeast
of the landfill and the 54 acre area underlying the landfill. This 54 acre area is
included because the landfill containment system will not capture the contaminated
ground water underneath the landfill in the Red Bank aquifer. However, as shown in
Figure 6, the Water Table aquifer area of attainment is the 35 acre area north and
northeast of the landfill between the landfill and the river. The contaminated Water
Table aquifer ground water in the 54 acres area underlying the landfill is not included
in the second operable unit remediation because it will be extracted by the first
operable unit remedy.
Alternative Synopsis
Six remedial alternatives were selected for the detailed evaluation in the FS. Except
for Alternative 1 (No Action), all alternatives share several components. These
common components are: long-term monitoring; institutional controls and treatment
of contaminated ground water with a wastewater treatment plant.
Long-term monitoring would be required to assess the effectiveness of the action
through ground water and surface water quality monitoring, water level
measurements, and biota monitoring.
Institutional controls include, but are not necessarily limited to, limitations on future
use of the site property through deed restrictions and limitations on pumpage of the
Water Table and Red Bank aquifers in the vicinity of the site. Such controls are
necessary since the effectiveness of the first operable unit remedy relies on a stable
upward water pressure within the landfill from the ground water in the underlying
Red Bank aquifer. This upward pressure prevents the contaminated ground water and
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other waste leachate from escaping beneath the slurry wall. Consequently,
uncontrolled pumping in the vicinity of the site could impact this source control
remedy. In addition, since all of the remedial alternatives may require a lengthy
period of time to achieve the MCLs, it is necessary to restrict both exposure and the
further migration of the contaminant plume. The State of New Jersey is currently in
the process of developing well restriction regulations under the authority of the New
Jersey Safe Drinking Water Act. As such, implementation of well restriction zones will
have to be conducted through local ordinances. EPA will work closely with the
municipality in order to develop technical and managerial aspects of a well restriction
zone in the vicinity of the site.
As previously stated, all of the alternatives, except for Alternative 1 (No Action),
require treatment of the contaminated ground water in a wastewater treatment plant
(WWTP). For costing purposes, it was assumed that the treatment system would
include an equalization tank to provide a uniform flow rate, an air stripper to remove
at least 90 percent of the VOCs from the liquid stream and to precondition the ground
water for further removal of calcium and heavy metals, a metals treatment unit
utilizing precipitation, filtration to lower the total solids concentration, a two-stage
carbon adsorption system to provide high effluent quality, a clear well for backwash
capacity, and a backwash storage tank to provide for liquid/solids separation. Solids
will be dewatered and tested to determine if classifiable as a hazardous waste. If
classified as a hazardous waste, disposal at a Resource Conservation and Recovery Act
(RCRA) permitted hazardous waste facility in compliance with 40 CFR 268 (Land
Disposal Restrictions) will be required.
Discharge of the treated ground water would be sent to either the Ocean County
Utilities Authority (OCUA) or the Manasquan River, or would be injected into the Red
Bank aquifer. Based on information obtained from the implementation of the source
control remedy, the OCUA will not accept an untreated discharge from this site.
Current information reveals that the OCUA would require extensive pretreatment. For
discharge to the Manasquan River, compliance with federal and state surface water
standards would be required.
The implementation times for all alternatives except Alternative 1 (No Action) were
estimated to be approximately 18 to 24 months for design and 24 months for
construction. Though all action alternatives vary in terms of complexity of the
extraction/injection well scenario and thus are expected to vary in terms of the
design/construction time required, it is the design and construction of the wastewater
treatment plant which is .expected to take the greatest amount of time. Since all
action alternatives include a treatment plant (18 to 24 months for the design and 24
months for construction), the design and construction of the other components of each
alternative are expected to be completed by the time the treatment plant is finished.
Consequently, the time required for design and construction for all action alternatives
is comparable.
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All six alternatives were analyzed with the aid of a computer simulation in order to
facilitate the alternative comparison. This computer simulation modeled the site's
ground water flow and subsequent contaminant flow in three dimensions. This
analysis was performed in order to provide an estimate for comparison of the time
required for ground water remediation to MCLs under each alternative. Note,
however, that the actual remediation time can only be determined based upon
measurements taken during the remedial action. It is in recognition of the possible
limitations of the effectiveness of extraction and treatment systems that EPA will
require periodic evaluation of the system and may modify of the remediation goals to
reflect limitations of the response action. In the case of the Lone Pine Landfill, where
the pumping of contaminated ground water is severely restricted by the source control
remedy hydraulic requirements, the MCLs may not be fully achievable. Therefore, in
the case where complete ground water restoration is not practicable, the remedial
action may focus on plume containment to prevent contaminant migration and further
contamination of the ground water, prevention of exposures, and evaluation of further
risk reduction measures. Although estimated time frames to achieve MCLs are
provided for each alternative, it should be noted that, for all alternatives except
Alternative 1 (No Action), it is expected that a significant reduction in contaminant
levels would be achieved by operation of the extraction system over a shorter period
of time.
The six alternatives selected for detailed evaluation in the FS are described as follows:
Alternative 1 - No Further Action
This alternative involves taking no action at the site beyond the first operable unit
source control remedy. It includes ground water and surface water monitoring, as
well as institutional restrictions preventing the placement of wells in areas of
contaminated ground water, and pumpage restrictions on wells in the vicinity of the
site to prevent gradient reversals affecting the source control remedy. Contaminants
already present in the ground water would continue to migrate into the Manasquan
River under this scenario. The amount of contamination in the ground water is
expected to decrease over time because the first operable unit source control remedy
will mitigate the introduction of new contamination into the ground water.
The computer simulation estimated that it will take approximately 22 years for all of
this existing contamination to flush out of the Water Table aquifer naturally and
approximately 365 years for this contamination to flush out of the Red Bank aquifer.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 42,333
Annual Operation &
Maintenance Costs: $ 67,800
Present Worth: $ 720,333
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Alternative 2A - Interceptor Drain with Treatment of Contaminated Ground Water in a
New On-Site WWTP and Discharge to the OCUA
This alternative consists of installing a 2,800 foot interceptor drain approximately 100
feet from the river, in parallel, penetrating into the upper aquitard (Homerstown
Formation). Ground water from the Water Table aquifer, the Red Bank aquifer, and
the upper aquitard will discharge to the drain, thus prohibiting the contamination
from entering the Manasquan River.
It was calculated that the flow into the interceptor drain at equilibrium under this
alternative is approximately 75 gallons per minute (gpm). Therefore, the computer
simulation estimated that the area of contamination would reach the MCLs in .
approximately 12 years in the Water Table aquifer and approximately 315 years in the
Red Bank aquifer.
Note that this alternative, along with all of the alternatives except Alternative 1,
provides for virtually immediate elimination of any further discharge of contaminated
ground water into the river.
The ground water extracted from the interceptor drain in this alternative would be
treated to meet a minimum of drinking water standards in a new on-site WWTP and
discharged via a pipeline connected to the OCUA at a rate of approximately 75 gpm.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 4,288,828
Annual Operation &
Maintenance Cost: $ 716,300
Present Worth: $11,451,828
Alternative 2B - Interceptor Drain with Treatment of Contaminated Ground Water in
a New On-Site WWTP and Discharge to the Manasquan River
This alternative is the same as Alternative 2A except that the treated ground water
would be discharged to the Manasquan River in accordance with applicable New
Jersey Pollution Discharge Elimination System (NJPDES) permit requirements.
Note that the capital costs for Alternative 2A are higher than the capital costs for
Alternative 2B due to the greater cost for an effluent discharge system to the OCUA
than the river. In addition, the OCUA option has a higher annual operation and
maintenance cost than the river option due to OCUA and local municipality usage
costs.
The computer simulation estimated that the ground water would meet the NJPDES
standards in approximately 12 years in the Water Table aquifer and approximately
315 years in the Red Bank aquifer.
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The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 3,340,271
Annual Operation &
Maintenance Cost: $ 445,700
Present Worth: $ 7,797,271
Alternative 3 - Interceptor Drain and Injection Wells with Treatment of Contaminated
Ground Water in a New On-Site WWTP and Discharge via Injection
This alternative is the same as Alternatives 2A and 2B except that the treated ground
water would be discharged via injection wells into the Red Bank aquifer. The ground
water would be treated to meet the MCLs. In addition, the use of injection wells for
disposal would hydraulically push contaminated ground water through the Red Bank
aquifer decreasing the time for Red Bank aquifer cleanup. However, the time required
for cleanup of the Water Table aquifer is slightly lengthened, due to a change in its
gradient.
It was estimated that approximately 21 injection wells would be used for disposal.
This alternative would also include a recharge trench which would be utilized for
temporary injection if the injection wells require maintenance.
Under the scenario evaluated, the computer simulation estimated cleanup of the Water
Table aquifer in approximately 14 years and cleanup of the Red Bank aquifer in
approximately 255 years.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 5,232,047
Annual Operation &
Maintenance Cost: $ 466,100
Present Worth: $ 9,893,047
Alternative 4A - Interceptor Drain and Extraction Wells with Treatment of
Contaminated Ground Water in a New On-Site WWTP and Discharge to the OCUA
The interceptor drain in this alternative is the same interceptor drain discussed in
Alternatives 2A, 2B and 3. However, in this alternative, the interceptor drain would
be supplemented with extraction wells located in the Red Bank aquifer. The purpose
of the extraction wells is to expedite the remediation of the Red Bank aquifer.
The preliminary results of the computer simulation calculations indicated that the
optimum scenario for the extraction wells would be three wells pumping at a rate of 5
gpm. With the interceptor drain, this translates into a total of approximately 90 gpm
extracted out of the aquifers. The placement, numbers and rates of extraction well
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pumping would be designed in order to not disturb the hydraulic balance maintained
within the landfill's slurry wall.
Under the scenario evaluated, the computer simulation estimated that cleanup of the
Water Table aquifer would take approximately 12 years and cleanup of the Red Bank
aquifer would take approximately 195 years.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 4,498,443
Annual Operation & .
Maintenance Cost: $ 785,300
Present Worth: $12,351,443
Alternative 4B - Interceptor Drain and Extraction Wells with Treatment of
Contaminated Ground Water in a New On-Site WWTP and Discharge to the
Manasquan River
This alternative is the same as Alternative 4A except that the treated ground water
would be discharged into the Manasquan River. The ground water would be treated
to meet the NJPDES requirements. Note that the capital costs for Alternative 4A are
higher than the capital costs for Alternative 4B due to the greater cost for an effluent
discharge system to the OCUA than the river. In addition, the OCUA option has a
higher annual operation and maintenance cost than the river option due to OCUA and
local municipality usage costs.
The computer simulation estimated that a total of approximately 90 gpm would be
extracted from the aquifers, resulting in an estimated cleanup time of 12 years for the
Water Table aquifer and an estimated cleanup time of 195 years for the Red Bank
aquifer.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $ 3,549,886
Annual Operation &
Maintenance Cost: $ 469,700
Present Worth: $ 8,246,886
Alternative 5 - Interceptor Drain, Extraction and Injection Wells with Treatment of
Contaminated Ground Water in a New On-Site WWTP and Discharge via Injection
This alternative is the same as Alternatives 4A and 4B except that the treated ground
water would be discharged via injection wells into the Red Bank aquifer. The ground
water would be treated to meet the MCLs. In addition, as with Alternative 3, the use
of injection wells for disposal would hydraulically push contaminated ground water
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through the Red Bank aquifer, decreasing the time for Red Bank aquifer cleanup.
However, the time required for cleanup of the Water Table aquifer is slightly
lengthened due to a lower hydraulic gradient which causes a reduced rate of flow.
As with Alternative 3, this alternative would include a recharge trench which would
be utilized for temporary injection if the injection wells require maintenance.
It was estimated that approximately 3 wells would be used for extraction and 24
injection wells would be used for disposal. Under the scenario evaluated, the
computer simulation estimated a cleanup time of 14 years for the Water Table aquifer
and 165 years for the Red Bank aquifer.
The estimated costs for the estimated operational life including equipment
replacement, are as follows:
Capital Cost: $ 5,441,662
Annual Operation &
Maintenance Cost: $ 482,600
Present Worth Cost: $10,267,661
Alternative 6 - Interceptor Drain, Extraction and Injection Wells (including Injection
through the Landfill) with Treatment of Contaminated Ground Water in a New On-
Site WWTP and Discharge via Injection
Under this alternative, the same interceptor drain as discussed in the previous
alternatives would be constructed. However, the well pumping scenario is altered in
order to obtain a more rapid remediation of the Red Bank aquifer than in the other
injection alternatives. The computer simulation estimated that this could be
accomplished by placing 13 injection wells into the Red Bank aquifer through the
landfill.
In addition, whereas the previous alternatives required an on-site WWTP with a
maximum capacity of 100 gpm, this alternative would require a WWTP with the
capacity to handle a much larger volume of ground water (up to 750 gpm).
This alternative, like Alternatives 3 and 5, would require a recharge trench. The
recharge trench in this case would handle temporary injection if the injection wells
required maintenance and for handling WWTP effluent in excess of the injection well
capacity.
For this alternative, the computer simulation estimated that 13 injection wells located
in the landfill, penetrating into the Red Bank aquifer, would have to inject
approximately 32.5 gpm each. Another 14 injection wells located along the eastern
and western boundaries of the contaminant plume in the Red Bank aquifer would
have to inject approximately 20 gpm each. A total of 46 extraction wells would be
located around the perimeter of the landfill with a proposed discharge of 11 gpm
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each. Ten extraction wells would be located along the interceptor drain and would
need to discharge 20 gpm each. All of the wells mentioned would be screened in the
Red Bank aquifer.
The computer simulation estimated that the remediation time would be- approximately
19 years in the Water Table aquifer and would be approximately 14 years in the Red
Bank aquifer.
The estimated costs for the estimated operational life, including equipment
replacement, are as follows:
Capital Cost: $12,860,558
Annual Operation &
Maintenance Cost: $ 1,240,500
Present Worth Cost: $23,237,241
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Oil and Hazardous Substances Contingency Plan
(NCP), a detailed analysis was performed on the six alternatives with respect to the
each of nine evaluation criteria. The following is a summary of the comparison of the
alternatives considering these evaluation criteria. The criteria are:
Threshold Criteria
Overall Protection of Human Health and the Environment: This criterion
addresses whether or not a remedy provides adequate protection and describes
how risks are eliminated, reduced or controlled through treatment, engineering
controls or institutional controls.
• Compliance with Applicable or Relevant and Appropriate Requirements
(ARAKS'): This criterion addresses whether or not a remedy will meet all of the
ARARs of other environmental statutes and/or provide grounds for invoking a
waiver.
Primary Balancing Criteria
• Long-term Effectiveness and Permanence: This criterion refers to the ability of
the remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
Reduction of Toxicitv. Mobility or Volume through Treatment: This criterion
addresses the degree to which a remedy utilizes treatment technologies to
reduce the toxicity, mobility or volume of contaminants.
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• Short-term Effectiveness: This criterion considers the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and implementation
period until cleanup goals are achieved.
• Implementabilitv: This criterion examines the technical and administrative
feasibility of a remedy, including availability of materials and services needed to
implement the chosen solution.
• Cost: This criterion includes capital and operation and maintenance costs.
Modifying Criteria
• State Acceptance: This criterion indicates whether, based on its review of the
RI/FS and Proposed Plan, the state concurs with, opposes, or has no comment
on the proposed alternative.
• Community Acceptance: This criterion addresses whether, based on comments
received, the public accepts EPA's proposed alternative. Detailed responses to
public comments are addressed in the Responsiveness Summary, which is
attached as Exhibit 1.
The selected remedy must, at a minimum, attain the Threshold Criteria. The selected
remedy should also provide the best balance of tradeoffs among the Primary Balancing
criteria. The Modifying Criteria were evaluated following the public comment period.
Overall Protection of Human Health and the Environment
With the exception of the Alternative 1 (No Action), all of the alternatives will
prevent the discharge of contaminants into the Manasquan River as soon as the
interceptor drain is installed. Alternatives 4A/B, 5 and 6 will be most protective of
human health and the environment since they provide the additional benefit of an
active pumping system which should restrict any further migration of the contaminant
plume. Therefore, all of the alternatives, except for no action, provide for adequate
protection of human health and the environment by eliminating the migration of
contaminated ground water into the Manasquan River and/or the surrounding area
and expediting cleanup of both the Water Table and Red Bank aquifers.
Current risk information indicates that the risk to human health from the current
discharge to the Manasquan River is low. However, a 1988/1989 DEP
macroinvertebrate study indicates environmental degradation to the river. Therefore,
the no action alternative does not adequately protect human health and the
environment. In addition, no action will not restrict potential migration of the
contaminant plume. Furthermore, changes in the local hydrology due to pumping or
natural conditions could pose a future risk with respect to human exposure to
contaminated ground water.
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Compliance with ARARs
There are three types of applicable or relevant and appropriate requirements which
must be considered in evaluating- remedial alternatives: location-specific ARARs, action-
specific ARARs, and chemical-specific ARARs.
Location-Specific ARARs:
Location-specific ARARs restrict activities or limit concentrations of contaminants in
effluent because a site is in a special location such as a floodplain, wetland, or
historical area. Location-specific ARARs for all remedial alternatives include the: Fish
and Wildlife Coordination Act, 16 U.S.C. 661 et seq.: Clean Water Act §404 (40 CFR
230, 33 CFR 320 - 330); Executive Order 11990, Protection of Wetlands; Executive
Order 11988 (40 CFR 6, Appendix A), Floodplain Management; National Historic
Preservation Act of 1966, as amended, 16 U.S.C. 470 et seq. and 469; New Jersey
Flood Hazard Area Regulations, N.J.A.C. 7:13-1.1 et seq.: and New Jersey Freshwater
Wetlands Protection Act Rules; N.J.A.C. 7:7A-1.1 et sea.
Information currently available on the site indicates the following:
Except for transient species, no federally listed or proposed threatened or
endangered flora or fauna are know to exist within the vicinity of the site
(therefore, the Endangered Species Act of 1973, as amended, is not an ARAR).
» The site exists within a wetlands. The wetlands exist primarily along the
western, northern and eastern edges of the landfill. EPA is currently
conducting a wetlands delineation and assessment in consultation with DEP.
Preliminary results indicate that various remedial alternatives could potentially
have a negative impact on wetlands at the site. For example, for the
interceptor drain, which is component of action alternatives, it is estimated that
approximately 3 acres of moderate to high-quality wetlands in the northern
portion of the site would be damaged. Further assessment of impacts to
wetlands can only be performed during design of the selected remedy, when
more information regarding the optimum location for various components
becomes available. It is EPA's intent to ensure that mitigation to replace
wetlands lost due to remedial activities is undertaken.
The sites exists within an area sensitive with respect to potential impacts to
cultural resources. Therefore, in accordance with the National Historic
Preservation Act of 1966, as amended, a Stage 1A cultural resources survey
must be conducted. Upon completion of the Stage 1A survey, a determination
will be made as to whether further field investigations are necessary.
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Chemical-Specific ARARs:
Chemical-specific ARARs are health- or environmentally-based numerical values
limiting the amount of a contaminant that may be discharged to, or allowed to remain
in, environmental media.
GROUND WATER
Two kinds of standards are considered ARARs for the ground water at the site:
Federal Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs) which
include the Federal Resource Conservation and Recovery Act (RCRA) Maximum
Concentration Limits, and the promulgated State of New Jersey standards [New Jersey
Safe Drinking Water Act A-280 Amendments, and New Jersey Pollution Discharge
Elimination System regulations (N.J.A.C. 7:14A-1.1 et seq.1. N.J.A.C. 7:10-16 et seq..
and 7:9-6 et seq.1. CERCLA requires remedies to comply with state requirements that
are more stringent than federal requirements. Therefore, the most stringent standard
is the cleanup goal for ground water at the site. Table 2 lists most of the chemicals
comprising the contaminant plumes in the Water Table and Red Bank aquifers with
their federal and state standards under the regulations listed above. The last column
in the table provides the cleanup requirement for each chemical. Complete listings of
all chemicals with currently promulgated standards are in: Drinking Water
Regulations and Health Advisories (EPA, 1990); N.J.A.C. 7:9-6.1 et sea., and the New
Jersey Safe Drinking Water Act (N.J.A.C. 7:10-16 et seq.1.
SURFACE WATER
The Clean Water Act (33 U.S.C. 1251 - 1376) Water Quality Criteria (40 CFR 131)
and the New Jersey Surface Water Quality Standards (N.J.A.C. 7:9-4.1 et seq.1 are
ARARs for the site since the ground water discharges into the Manasquan River.
These standards apply to all alternatives which have a discharge to the Manasquan
River including Alternative 1, No Action. The action alternatives which include the
discharge of treated ground water into the Manasquan River (Alternatives 2B and 4B)
must comply with the discharge standards developed for the site by EPA based on the
Water Quality Criteria and New Jersey Surface Water Quality Standards mentioned
above. The standards developed by EPA for these alternatives are included in the
Administrative Record.
Action-Specific ARARs
Action-specific ARARs are technology- or activity-based limitations.
WASTEWATER TREATMENT PLANT
All of the alternatives, except for Alternative 1, require the use of a wastewater
treatment plant. The design of the wastewater treatment plant was approximated in
the FS for purposes of costing and meeting the ground water and surface water
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standards. The design was assumed to include, among other components, an air
stripper as well as granular activated carbon. The ARARs associated with the use of a
wastewater treatment plant are listed on Table 11. In addition to those requirements
listed on Table 11, any sludge generated by the operation of a wastewater treatment
plant would have to be disposed of in accordance with the requirements of the
Resource Conservation and Recovery Act, including the Land Disposal Restrictions.
DISCHARGE TO MANASQUAN RIVER
Alternatives 2B and 4B include the discharge of treated ground water to the
Manasquan River. The following ARARs would apply to such an action: National
Pollutant Discharge Elimination System, Clean Water Act §§302 and 402; New Jersey
Pollutant Discharge Elimination System requirements, NJ.A.C. 7:14A et seq.: and
New Jersey Surface Water Quality Standards, N.J.A.C. 7:9-4.1 et seq.
DISCHARGE TO THE PUBLICALLY OWNED TREATMENT WORKS (OCEAN COUNTY UTIUTIES
AUTHORITY)
Alternatives 2A and 4A include the discharge of treated ground water to the Ocean
County Utilities Authority. The following ARARs would apply to such an action:
Clean Water Act §§301 and 307; New Jersey Wastewater Discharge Guidelines; 40
CFR 403.5; 40 CFR 270.60; and Local Publically Owned Treatment Works
Regulations.
INJECTION OF TREATED GROUND WATER INTO RED BANK AQUIFER
Alternatives 3, 5, and 6 include the injection of treated ground water into the Red
Bank aquifer. The following ARARs would apply to such an action: Safe Drinking
Water Act, 40 CFR 144; New Jersey Pollutant Discharge Elimination System, NJ.A.C.
7:14A et seq.: and New Jersey Ground Water Quality Criteria, N.J.A.C. 7:9-6 et seq.
ADDITIONAL ACTION-SPECIFIC ARARs:
Additional Action-specific requirements would apply to all action alternatives. These
ARARs are listed in Table 11.
ARAR Evaluation
It is the policy of EPA's Superfund program to use as a guide the framework provided
by EPA's "Ground Water Protection Strategy1 (EPA, 1984) in determining the
appropriate remediation for contaminated ground water. Under this strategy, three
classes of ground water have been established on the basis of ground water value and
vulnerability to contamination. Ground water affected by contamination from the
Lone Pine Landfill is classified as IIA, current and potential sources of drinking water
and water having other beneficial uses (potentially available).
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With the exception of Alternative 1 (No Action), all of the alternatives evaluated will
comply with its particular set of ARARs. Because the No Action alternative allows the
continued discharge of contaminants to the Manasquan River, this alternative is not
expected to comply with the surface water ARARs identified above.
It is the time to achieve the ground water cleanup standards which distinguishes one
alternative from another as well as by the fact that the No Action Alternative relies on
natural attenuation to meet ARARs, rather than active restoration. For the No Action
Alternative, it will take an estimated 22 years to meet ARARs in the Water Table
aquifer. In contrast, Alternatives 2A/B and 4A/B achieve ARARs in the Water Table
aquifer in 12 years, Alternatives 3 and 5 require 14 years, and Alternative 6 will
require 19 years.
The alternatives vary a great deal in achieving ARARs in the Red Bank aquifer. The
No Action Alternative will take an estimated 365 years; Alternatives 2A/B, the
interceptor drain, will take an estimated 315 years; Alternative 3, the interceptor drain
with injection wells, will take an estimated 255 years; Alternatives 4A/B, the
interceptor drain and extraction wells, will take an estimated 195 years; Alternative 5,
the interceptor drain, extraction and injection wells, will take an estimated 165 years,
and Alternative 6 the interceptor drain, extraction wells, and injection wells through
the landfill, will take an estimated 14 years.
All alternatives will eventually comply with ground water ARARs. Alternative 6 was
estimated to achieve ARARs in the Red Bank aquifer in the shortest period of time,
followed by Alternatives 5, 4A/B, 3, 2A/B and 1. For the Water Table aquifer,
Alternatives 2A/B and 4A/B were estimated to achieve ARARs in the shortest period
of time, followed by Alternatives 3 and 5, 6 and 1. However, it was estimated that
the period of time to achieve the ground water ARARs in the Water Table aquifer is
similar for Alternatives 2A/B, 3, 4A/B and 5. Alternatives 1 and 6 were estimated to
take a longer period of time to meet the ground water ARARs in the Water Table
aquifer.
Long-Term Effectiveness and Permanence
Alternative 1 (No Action) does not provide for long-term protection of human health
and the environment, since it does not prohibit the migration of contaminants to the
Manasquan River and does not contribute to the restoration of ground water. In
addition, Alternative 1 does not prevent potential further migration of contaminated
ground water.
The remaining alternatives provide for reliable long-term protection of human health
and the environment by restoring ground water quality, restricting migration of the
contaminant plume, and preventing the contaminant plume from discharging to the
Manasquan River. With all these alternatives, the contamination in the ground water
will have been remedied, and the successful operation and maintenance of the first
operable unit remedy (the source control remedy) will protect these aquifers from
27.
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contamination in the future.
Reduction of Toxicitv. Mobility, or Volume through Treatment
By allowing the contaminated ground water to continue to migrate into the
Manasquan River, Alternative 1 would not reduce the toxicity, mobility or volume of
contamination in the ground water.
Alternatives 2A/B, 3, 4A/B, 5 and 6, whether utilizing an on-site wastewater
treatment plant or the OCUA, would reduce the toxicity, mobility, and volume of
contamination in the ground water by removal of the contaminants from the ground
water.
Short-Term Effectiveness
Short-term effectiveness is directly related to the time it' takes for the remedy to
achieve protection and any adverse impacts on human health and the environment
that may be posed during the construction and implementation period until ARARs are
achieved.
Alternative 6 has the fastest cleanup time for the Red Bank aquifer (14 years) of any
of the alternatives. However, it has a longer cleanup time for the Water Table aquifer
(19 years) than Alternatives 2, 3, 4 and 5. Furthermore, remediation of the Water
Table aquifer under Alternative 6 would only be 60 percent complete when the Red
Bank aquifer is entirely remediated. This could lead to the possibility that the Red
Bank aquifer would become recontaminated (from the Water Table aquifer), if a
problem occurs with the extraction or injection wells. In addition, the Water Table
aquifer is more highly contaminated than the Red Bank aquifer.
Note that the time frames for cleanup represent estimates for the time required to
restore the contaminated ground water to drinking water quality and should be
primarily considered for comparisons among the various alternatives. These estimates
are based on simulations for the time it takes five pore volumes of the aquifer's water
to be replaced; it was calculated that it would take the extraction and treatment of
five pore volumes of water from each aquifer to achieve the ground water cleanup
standards. It is important to note that although these time frames to meet ground
water standards appear lengthy, the bulk of contamination will be removed during the
replacement of one to three pore volumes. For example, a significant amount of the
contamination will be removed in the time it takes to remove one pore volume from
the Red Bank aquifer. The estimated times for removing one pore volume are:
Alternative 1 - 73 years; Alternative 2 - 63 years; Alternative 3-51 years; Alternative
4 - 39 years; Alternative 5 - 33 years; Alternative 6 - 2.8 years.
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Implementabilitv
All six alternatives can be implemented. However, they vary in complexity due to
their design requirements. Alternative 1 is the simplest to implement since it would
only involve a monitoring program and institutional controls. Alternatives 2A and 2B
would be slightly more complicated than Alternative 1 since they require installation
of an interceptor drain in addition to the monitoring program and institutional
controls. Alternatives 3, 4A, 4B, 5 and 6 are more complex than Alternatives 2A and
2B since they require various extraction and/or injection wells/recharge trench designs
in addition to the interceptor drain, monitoring program and institutional controls.
In comparing Alternatives 3, 4A, 4B, 5 and 6, it is expected that Alternatives 4A and
4B would be the simplest to implement since they only require and estimated three
extraction wells. Alternative 3 would have a greater logistical complexity than
Alternatives 4A and 4B since it would require approximately 21 injection wells. The
more wells associated with an alternative, the more field work necessary to implement
the alternative. Proper well placement requires detailed data collection during the
drilling process to ensure that the well screen is situated in the correct formation and
to ensure that the well can withdraw or inject a ceratin amount of water. As such,
Alternative 5 would have greater logistical complexity than Alternative 3 since it
requires approximately 27 wells (24 injection and 3 extraction). Finally, Alternative 6
would have the greatest logistical complexity since it would require approximately 83
wells (27 injection and 56 extraction).
In addition to the logistical complexity simply caused by the numbers of wells
required, there is an added complication due to well proximity to the landfill
containment system. The landfill containment system requires maintenance of an
upward head from the aquifers into the landfill mound. Therefore, the extraction of
contaminated ground water outside of the containment system cannot be permitted to
reverse the required hydraulics of the first operable unit remedy. Typically, the
greater the distance from the landfill containment system and the lower the pumping
rate, the less chance there is to impact the containment system. Therefore, Alternative
6 (which requires injection wells through the landfill and extraction wells at the
boundary of the slurry wall) is expected to be significantly more difficult to implement
than the other alternatives from a hydraulic standpoint. Alternatives 4A/B and 5,
which also include extraction wells, would be easier to implement since the wells
would be placed farther away from the landfill containment system.
A supplemental problem concerning Alternative 6, which adds complications to its
implementation, is the placement of injection wells through the landfill and its cap.
The physical placement of the wells can potentially compromise the landfill
containment system by potentially creating pathways for precipitation infiltration.
Extreme care would need to be taken during the installation of such wells. Additional
contaminant pathways could also be created due to waste subsidence during the
operation of the injection wells. Furthermore, maintenance of the wells could require
the movement of heavy equipment onto the landfill which could potentially cause
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subsidence and damage to the cap. In addition, drilling into the landfill poses health
and safety risks. The landfill contains toxic chemicals, some of which are contained in
an estimated 17,000 to 50,000 drums. Drums could be punctured during drilling and
increase contaminant loading to the landfill containment system. Drilling would have
to be performed using very stringent health and safety procedures. In -addition,
safeguards would be required to ensure that all drilling equipment on the landfill was
adequately supported to preclude accidents triggered by abrupt waste subsidence.
In summary, implementation of Alternative 6 would be the most difficult, followed by
5, 3, 4A/B, 2A/B, and 1. Alternatives 6 and 5 require the most wells. Alternative 6
requires wells through and adjacent to the landfill, in close proximity which could
interfere the first operable unit remedy. Furthermore, Alternative 6 would require the
most stringent health and safety requirements. All alternatives which require
extraction and/or injection wells will undergo extensive field testing. However, it is
expected that the Alternative 6 design requirements would be the most difficult to
implement since this alternative requires the most complex hydrologic scheme.
Cost
The estimated present worth value of each alternative is as follows:
Alternative 1 - No Action $ 720,333
Alternative 2A - Interceptor Drain with Discharge to the $11,451,828
OCUA
Alternative 2B - Interceptor Drain with Discharge to the $ 7,797,271
Manasquan River
Alternative 3 - Interceptor Drain & Injection Wells $ 9,893,047
Alternative 4A - Interceptor Drain & Extraction Wells with $12,351,443
Discharge to the OCUA
Alternative 4B - Interceptor Drain & Extraction Wells with $ 8,246,886
Discharge to the Manasquan River
Alternative 5 - Interceptor Drain, Extraction & Injection $10,267,661
Wells
Alternative 6 - Interceptor Drain, Extraction & Injection $23,237,241
Wells (including injection through the landfill)
It should be noted that for Alternatives 2 and 4, the costs of discharging to the OCUA
are at least $3 million higher than discharging to the River; this is due to the higher
operation and maintenance costs which include charges imposed by the OCUA.
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Alternative 6 is far more expensive than the other alternatives for the reasons
delineated in the implementability section as well as the added cost of a 750 gpm
WWTP as opposed to the 100 gpm WWTP necessary for the other alternatives.
State Acceptance
The State of New Jersey concurs with Alternative 5. In addition, the State of New
Jersey has stated that Alternatives 2B and 4B, which include a discharge of treated
effluent to the Manasquan River, are not acceptable, due to the presence of a drinking
water supply reservoir downstream from the landfill.
Community Acceptance
In general, the officials and local residents expressed a strong preference for
Alternative 6, noting the shorter cleanup time frames while the potentially responsible
panics urged EPA to defer its decision. A more detailed discussion of community
concerns and comments is provided in the attached Responsiveness Summary.
SELECTED REMEDY
EPA is selecting Alternative 5 for the remediation of ground water contamination at
the site. Although the community expressed a preference for Alternative 6 because of
its faster cleanup time frames, EPA has concerns about the implementation of this
alternative. These concerns include both safety issues associated with the installation
of the injection wells and technical issues involving the operation of the system and
its potential impact on the landfill containment remedy. However, during the design
of the ground water remedy, EPA will investigate possible modifications to the
described components to maximize and accelerate the cleanup.
The selected remedy will protect public health and the environment by controlling the
discharge of contaminated ground water into the Manasquan River, almost
immediately after installation of the interceptor drain. In addition, the extraction and
injection wells will expedite remediation time for the Red Bank aquifer. Long-term
monitoring in the river and Water Table and Red Bank aquifers will ensure that the
drain and wells are operating effectively.
Alternative 5 provides the best balance of tradeoffs among the various alternatives.
Of all the action alternatives, Alternatives 4A/B, 5, and 6 are most protective of
human health and the environment since, in addition to preventing contaminant
discharge to the river, they include measures to restrict and control plume migration.
Alternative 5 achieves the ground water cleanup ARARs in both aquifers more quickly
than Alternatives 4A/B. Although Alternative 6 achieves ARARs in the Red Bank
aquifer in the shortest time, it poses several difficulties in terms of implementation
and is twice as costly as Alternative 5.
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The selected remedy includes the following components:
• Installation of a 2,800-foot long interceptor drain, keyed into the Homerstown
Formation and located approximately 100 feet from and parallel to the
Manasquan River which will extract approximately 81 gpm at equilibrium;
Installation of 3 extraction and 24 injection wells screened in the Red Bank
aquifer, the extraction wells will pump approximately 5 gpm each and the
injection wells will operate at a rate of approximately 4 gpm each;
Construction of an on-site wastewater treatment plant with a capacity of 100
gpm to treat the ground water captured by the interceptor drain and extraction
wells to meet the ARARs which would include federal and state MCLs;
Construction of a recharge trench to discharge treated ground water in excess
of the capacity of the injection wells during maintenance of the injection wells;
Long-term monitoring of the Water Table and Red Bank aquifers, and the
Manasquan River, including additional sediment and biota studies; and
Institutional controls to restrict ground water usage in the area affected by the
site.
As previously indicated, these components may be modified during design to accelerate
the cleanup of the contaminated ground water. The details regarding the optimum
number of extraction and injection wells as well as the pumping and injection rates
will be refined during the design phase.
In addition, the construction and operation of one wastewater treatment plant to treat
the leachate and ground water for both the first and second operable units will be
considered during the design phase. This .combination of treatment for the two
remedial actions will be considered if it is determined to be practicable and does not
delay implementation of the first operable unit remedy. Note that if one wastewater
treatment plant is constructed, the costs associated with implementation of Alternative
5 will be significantly reduced. The discharge from any such combined treatment
plant would either be reinjected into the Red Bank aquifer or sent to the OCUA.
Negotiations with OCUA related to discharge of the treated leachate from the first
operable unit plant are ongoing, and it is possible that OCUA may accept the
additional estimated 90 gpm from the second operable unit remedy.
Contingency Measures
The selected remedy will include ground water extraction for an estimated period of
165 years, during which time the system's performance will be carefully monitored on
a regular basis and adjusted as warranted by the performance data collected during
operation.
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As previously discussed, the goals of this remedial action are to protect the
Manasquan River from contamination, prevent migration of the contaminant plume,
and restore ground water to its beneficial use, which is as a potable source of
drinking water. Based on information obtained during the RI/FS, and on a careful
analysis of all remedial alternatives, EPA and the State of New Jersey believe that the
selected remedy will achieve these goals. However, a recent study was conducted by
EPA on ground water extraction systems at a number of Superfund sites and RCRA
hazardous waste facilities. The study found that ground water extraction was effective
in containing contaminant plumes and achieving significant mass removal of
contaminants. However, in most cases, contaminant, concentrations did not decrease
linearly over time to reach desired cleanup goals; after significant initial decreases,
concentrations typically leveled off, often at concentrations higher than the desired
cleanup levels. Therefore, at this site, it may not be possible to reduce contaminants
to cleanup standards (i.e., federal and state MCLs) throughout the area of attainment.
Ground water contamination may be especially persistent in the immediate vicinity of
the landfill, where concentrations are relatively high. The practicability of achieving
cleanup goals throughout the contaminant plume cannot be determined until the
extraction and treatment system has been implemented and plume response monitored
over time.
If it becomes apparent during operation of the remedial action that contaminant levels
have ceased to decline and are remaining constant at levels higher than the cleanup
standards, or the hydraulics associated with the first operable unit prevent pumping at
a rate adequate to achieve cleanup standards, the remedy as it affects restoration of
ground water may be reevaluated. If it is determined that the selected remedy cannot
meet the ground water cleanup standards, contingency measures may be taken.
Those contingency measures may include discontinuing operation of extraction wells in
areas where cleanup goals have been attained; placement of extraction wells in other
locations; alternating pumping at wells to eliminate stagnation points; and pulse
pumping to allow aquifer equilibration and encourage adsorbed contaminants to
partition into ground water. These contingency measures are still considered to be
protective of human health and the environment.
If it is determined, in spite of any contingency measures that may be taken, that
portions of the aquifers cannot be restored to their beneficial use, ARARs may be
waived in accordance with the statutory waiver provisions of CERCLA for those
portions of the aquifers based on the technical impracticability of achieving further
contaminant reduction.
The decision to invoke a contingency measure may be made during a periodic review
of the selected remedial action, which will occur at intervals no less often than every
5 years.
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STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is to
undertake remedial actions that achieve adequate protection of human health and the
environment. In addition, Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act establishes several other statutory requirements and
preferences. These specify that, when complete, the selected remedial action for a site
must comply with applicable or relevant and appropriate environmental standards
established under and Federal and State environmental laws unless a statutory waiver
is justified. The selected remedy also must be cost-effective and utilize permanent
solutions and alternative treatment technologies to the maximum extent practicable.
Finally, the statute includes a preference for remedies that employ treatment that
permanently and significantly reduces the volume, toxicity, or mobility of hazardous
substances as their principal element. The following sections discuss how the selected
remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy provides for protection of human health and the environment b,y .
preventing the contaminant plume from discharging to the Manasquan River,
restricting migration of the contaminant plume, and removing contaminants from
ground water.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy will be designed to meet all ARARs (Table 12). The Land Ban
Requirements of RCRA do not apply to the disposal of the treated ground water to the
Red Bank aquifer, although they may apply to the wastewater treatment plant sludge
depending upon whether it is classified as a hazardous waste under RCRA.
Cost-Effectiveness
The selected remedy is cost effective since it has been determined to provide the
greatest overall effectiveness proportional to its costs - present worth estimated at
$10,267,661. When compared to Alternative 6 and Alternative 4A, which provide an
equivalent degree of protectiveness, the selected remedy is less costly.
Utilization of Permanent Solutions and Alternative Treatment Cor resource recovery')
Technologies to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective manner for the second
operable unit remedy for the site. Of the action alternatives which are protective of
human health and the environment and comply with ARARs, EPA has determined that
the selected remedy provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility and volume achieved
34
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through treatment, short-term effectiveness, implementability, and cost, also
considering the statutory preference for treatment as a principal element, and
considering State and community acceptance.
Preference for Treatment as a Principal Element
The statutory preference for treatment as a principal element is satisfied in the
selected remedy. The selected remedy includes ground water treatment to drinking
water standards, to the extent practicable.
Documentation of Significant Changes
During the public comment period, local area representatives expressed concern that
the cost estimates associated with Alternatives 2A/B, 3, 4A/B and 5 were not
accurate, since they did not account for replacement of equipment and materials over
time (e.g., the treatment plant, injection wells, etc.). The costs noted herein reflect
EPA's revised cost estimates, and account for such replacement costs and operation
and maintenance costs over the period of time necessary to operate.
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FIGURES
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NEW JERSEY -
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•AND.
FINE TO MEDIUM. (MOWN
•LAUCONITE (AND AND CLAY.
OMEN
•ILT, CLAY AND (AND
TINTON «ANO. INDURATED. CEMENTED
^-•v. «ILT ANO CLAY
POORLY »ORTID *ANO. >
" " • . .
•ILT ANO CLAY
•ILT. CLAY ANO iANO.
•LACK
•AND. MEDIUM TO COARtE.
OREENIM-ORAV
•AND AMD MLT,
DARK WUY
THICK MEM
0-30'
10-12'
e-i»'
6-10'
0-10'
~ 10-36 ~
10-20'
10-46'
76'
Figure 3 Geologic and Hydrogeologic Subdivisions
-------
Manasquan River
EXPLANATION
K
V.Vi
Figure 4 Schematic Diagram of the Ground Water Flow
System in the vicinity of the Lone Pine
Landfill
-------
LONE PINE LANDFILL
If EXPLANATION
M-WA w«g location (pa
HM-I 8«H«
A tt«M
Figure 5 Location of Ground Water Monitoring Wells and Surface Water Sampling
Stations
-------
elVOC*
Figure 6 Extent of Contaminant Plume in the Water Table Aquifer (Area of
Attainment)
-------
N
\
• \ U)
LONEPINB
LANDFILL
»J° MoiiHailno «raH «rtlh •««•«*
- • lose •
wm of VOC*»
(T) M«part«4 uum«im«lten prabgMy raftoel*
btanh oortwnbwllan
Figure 7 Extent of Contaminant Plume in the Red Bank Aquifer (Area of
Attainment)
-------
TABLES
-------
COMPOUND
BisC2-e:hvlhexy:}ph:halate
Bar,-1, ber.jy: phthalate
pi-rrbuTy', phiaiate
Naphthalene
Di-T>-oc:y: phthalate
Diethyl phthalate
Benzc (e)pyrene
Iscphorone
AZi-in
4.4-DD7
KepiaihJc: epocde
Beta-BHC
Dt:c-BHC
PCS- 1260
2-N:r:ph«::
Pher.c:
Berjer.e
1. j •Dicr-rroe-j'.
We-yier-e Chirrids
Tera :>J ::De-_-.y;e.n
Toluene
Ar.-r.cr.y
Cidrr.tr.
Copper
Lead
Nicxe!
S«)en:ua
SL'ver
TABLE 1
SUMMARY OF EXCAVATED DRUM SAMPLES
LIQUID
16.0
3.5
54.0
1.1
1.9
0.11
32.0
3.7
3.6
50.0
27.0
11.0
0.21
0.16
1.4
43.0
340.0
410.0
2400.0
4.5
80.0
230.0
1400.0
3.0
14.0
2400.0
410.0
2000.0
40.0
18.0
40.0
5800.0
MAXIMUM DETECTEDCON
1200.0
2200.0
3700.0
0.2
0.71
2200.0
1000.0
400.0
340.0
3600.0
3200,0
0.4
1.68
0.82
120.0
0.82
0.17
110.0
.
.
-
f
.
.
2000.0
160.0
26.0
220.0
.
200.0
68.0
24.0
trace
210.0
20.0
39.0
100.0
52.0
100.0
97.0
150.0
0.81
38.0
0.79
»
0.63
0.16
7.1
300.0
240.0
52.0
5600.0
8.6
230.0
780.0
1000.0
9.0
trace
29,000.0
8900.0
200.0
trace
12.0
trace
1200.0
SOUP
1800.0
19,000.0
4500.0
13,000.0
4500.0
57.0
1.43
22.0
33.0
10S.O
6.5
4.8
10.0
0.7
34.0
3.2
0.16
£.3
3400.0
3B.O
56.0
5900.0
19.0
80.0
320.0
1600.0
3.0
140.0
610.0
500.0
300.0
1900.0
50.0
trace
8SO.O
-------
TABLE 2
CIIKNICAI.
ACKTONE
HKN7.i:NK
2-IMITANONI-':
FEDERAL n nriiAi. NKW
H( KA MCL SIlWA MCl.
CIIIOHOKTIIANK
CHLOKOKOIIM
1 . 2-l)ICIM/)RORTIIANB
1, l-l>irm/»lmKTHANE
1, I-DICHI/?I»OETIIENE
ETIIYLIIEN/ENK
MKTIIYLKNR CHLORIDE
4-Mi:TIIYI.-2-l»ENTANONE
TETMACIILOnUETIIENE
TOIAIENE
THANS- 1 , 2-DICHLOROETHENE
1, l-TRICHLORORTIIANE
TR ICIILOHOF.THtNE
VINYI. CHLORIDE
XYI.ENES
I'HKNOI,
ANTIMONY
ARSENIC
CHROMIUM
LEAD
SELENIUM
ZINC
so
so
50
10
I.
I,
r»
i.
7
P700
P5
P2OOO
Pino
200
5
2
P100OO
T10/5
P1OO
P5 E5O
P50
L
*
E
T
P
COMIUNDED TOTAL SHALL NOT EXCEED SO ppb
EXISTING STANDARD
TENTATIVE STANDARD (PHASE V)
PROPOSED STANDARD (PHASE II)
NO STANDARD
LISTED FOR REGULATION
i .irnsFY
M<:t.
*
i
*
4
*
r»
2
*
2
*
2
*
1
*
10
26
1
2
44
-
2.8
SO
SO
50
10
5000
NEW .IKPSFY GROUND
W ATI-: It UUAI.ITY
STANDARDS
_
-
—
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
.0035
-
50
SO
50
10
50OO
FEDERAL
MCI/:
_
o
_
_
L
L
O
L
7
P7OO
—
_
PO
P20OO
P10O
20O
0
O
P10000
-
T3
TO
PIOO
PO
P50
L
GROUND WATER
CLEANUP
REQUIHKMKNTS
*
1
•
4
*
5
2
*
2
•
2
*
1
*
10
26
1
2
44
.0035
2.8
SO
50
SO
1O
5000
-------
TABLE 3
. (Page 1 of 2)
LONE PINE LANDFILL
Onsite and Offsite
Sroundvater ana Surface Water Said ing
COH FPC and Verjar Data
April and flay, 1986
CHEMICAL
Acetone
Benzene
Broioiethane
Broioflicnio'oiethsne
2-Butanone -W,
Csrbor Dis^'ics
Caroon tefaer.icrioe
Ciiloroeer.zer.e
Chloroetr.sne
2-Chloroetr.>ivin>l etr.e-
Chlorofom
Chloroietnene
l,l-Dichl:roe r.e"e
l,2-Di:Me'"oe ^sr>«
lil-DicMfse "'t'it ::is.'
IOwft'^f*'^"** *• • ^ • ' * " B n 1
»* v**n*c. *?.-•? '. : • , 2Ma,
l,2-Di:Mc';D"cia'!
cjs l,3-o:"lor:"::!-e
EthylDer:!-e
2-heienor.e
fletr>>ie :r;:-ioe
4. H**Kw l.*.»»n*»**r»
* n c k n * •»r""*s..*ii|™
Styrert
Tetra:Mc-:e:r.ere
l,l,2,2-Te:re:f.;:rse:n!re
Toluene
l,Ul-TricMo*Mtri8"j
l,l,2-Trichif-.?:r.»-.
7ricru:rot:ne*>?
Vir.ri i;e:e:t
Vinyl Chloric?
Total X'lertes
ONSITE WELL
Range lug/1)
ND - 86000(0
ND - 36001V)
lOU(C) - lOOOOU(C)
ci i f r \ tnnnn f f" \
5UICI - SOOOUICI
5U(C) - 5000U10
ND - 20000010
ND - 6!V)
5U(0 - 5000UIO
ND • 4400IV1
ND - 600(V)
iou(0 - sooauic)
ND - 5"(C)
10UIO - 5000'JIO
ND
ND - 975C1V/0
V
Nu
ur\ . ignc'fcl
ftU twUU 1 1 1
ei 1 1 f 1 t^nfi1 1 f r ^
SU'C) - 50QOUIU
eU(Ci - SCQD'uiCl
*WlWI WWUUWVWi
CM i f \ cnnnn t f *
.. \
ND - 2 1C)
wfi . onnfrl
nv iUUlCJ
tttf*\ tf\H { P }
5UIO - 50UIC)
5UIC) - SQUlC)
WU 1 W 1 WUU \ W *
Ell t f \ Cflll { f\
5UIO - 50UIC1
ND • 14001V!
ND
ND • 42b(0
un - (iinlfl
NU D^U \ 1 1
5U10 - 50UIO
5U10 - 50UIO
5U(0 - 50UIO
ND - 1800(V)
SU(C) - 50UIC)
5UIO - SOU(C)
ND - 2"(V)
lOU(C) - lOQU(C)
ND - 51(0
ND - 160(V)
SURFACE UATER
Range -iug/1)
ND - 150J10
ND - 17(0
10U1C/V)
titfp-l\i\
5UIC/V)
5UIC/V)
ND - 17(0
ND
5UIC/V)
ND
ND
10UIC/V)
ND
10UIC/V)
ND
ND - 2.7"(C)
Ufk
ND
un . i o * f r 1
nv • 1 . i I W J
» ii i * /lit
5UIC/V)
5U(C/V)
WW V W f » J
CM f r III \
SuluVJ
ND - 6.7(0
ND
ND - 6J10
un . t effl
nu o . 7 v w t
5UIO
5UIC/V)
5UIC/V)
ND - 11(0
5U1C/V)
5U1C/V)
ND
lOU(C)
ND
ND - 14(V)
-------
TABLE 3 (cont.)
(Page 2 Of 2)
LONE PINE LANDFILL
Onsite and Offsite
Sroundwater and Surface Meter Seiclin?
COn FPC and versar Oeta
April and nay, 1986
CHEf.ICA:
netals:
Aluiinur.
Antiacny
Arsenic
Bar i UK
Berylliui
Cadi:. i
Calcium
Chroiiuit
Cobalt
M>per
Iron
Leac
nagnesijt
Hanganese
flercury
Nickel
Pot as si JIT:
Seler.iut
Silver
Sodium
Thalliun
Tin
Vanadium
Zinc
ONSITE WELL
Range (ug/1)
421(0 - 10650(0
ND - 45iV)
ND - 617(0
57(0 - 648(0
ND - 0.4(0
ND - 8.2(0
10130(0 - 443400(0
ND - 212(0 .
ND - 2910
ND - 781V)
ND - 195700(0 •
ND - 29810
26060(0 - 82150(0
9!C! - 2558(0
ND - 0.4(0
ND - 100(0
29260(0 - 576100(0
ND - li(V)
ND
3602010 - 1979000(0
ND
ND - 113(C)
5010 - 121(0
47(0 - 30200(0
UATER TABLE AQUIFER
Range (ug/1)
ND - 5008(0
ND - 251V!
ND - 288(0
21(0 - 333(0
ND - 1.1(0
ND - 13.2(0
850(0 - 45580(0
ND - 228(0
ND - 7(0
ND - 20(0
224(0 - 90760(0
ND - 318(0
667(0 - 12720(0
11(0 - 382(0
ND - 1.3(0
ND - 73(V)
ND
ND
ND
2559(0 - 78020(0
ND
ND
ND - 67.1(0
32.41V) - 23970(0
RED BANK AQUIFER
Range (ug/1)
ND - 9480(0
ND • 68.6(Vl
ND - r/ic;
27(0 - 216(0
ND
ND - 5.3(0
9198(0 - 36450(0
ND - 191(0
ND - 8(0
ND - 38(0
ND - 86320(0
ND - 67310(0
1080(0 - 6915(0
19(0 - 389(0
ND - 0.3(0
ND - 73(V)
ND - 7152(0
ND
ND - 13(V)
1648(0 - 22440(0
ND
ND
ND - 2.8(0
1HV) - 32620(0
SURFACE UATER
Range (ug/1)
31(0 - 41471C)
ND
ND - 2001V)
28(0 - 140(0
ND
ND
1960(0 - 6941010
ND • 4810
ND - 6(0
ND - 2110
3078(0 - 4101010
ND - 94(0
1619(0 - 3421C-O
37(0 - 338(0
ND
ND - 2810
2676(0 - 10530C1C;
ND
ND
1.6(0 - 17880C10
ND - 8561(0
ND
ND - 46.2(0
24(0 - 931V)
NOTES:
ND - Insicetes that the coisour.d was not detected.
(0 - Indicates :M: tn» value provided is froi CD!" FPC date.
(V) - Indicates tr.a; the va*ue proviaed is free Versar date.
- Estiiatec value.
U - Indicates conpouni was enabzeo for but not detected.
The nuts*- is the liniaui attainable detection Unit for the saiPle.
J - "his *la; is jseo either wher estiiating a concentration for tentatively
ioe-.ti'ie: cusou-.ds where e 1:1 response is assuied or when the tass spectral
dsti ir.:i:ztes tr-.e p-essesence cf t consound that Beets tre identification criteria
but the --es.it is less tnar the specific detection liiit but s-eater than :ero.
B - This fie; is uses when the ar.eiyte is found in the blank as well as e saioie.
It in:ictes pc-ssible/prooatie bleu contaiinetion.
-------
TABLE 4
LONE PINE LANDFILL
Organic Coioounds Onsite and Offsite
Groundnuter Saiolinj
COr, FPC end Versar Data
January and March, 1989
CHEfllCAL
Acetone
Benzene
2-5utanone (IE*!
ChloroDenrene •
Chloroethene
Chlorcforti
1.1-Dichioroetnari*
1,2-Dichioroetnane
1,1-Diehloroetnene icis!
1,2-Oiehloroetnene (trans) '
Ethylbenzene
2-Heianone '
liODrop>lDer.:e"e
Bethyiene crle-ice
4-Bethyl-2-ter.rap.5n*
1.2,4-Tri«e:p.»lsen:ene *
Toluene
Vinyl Chloride
Xylene ln-.o-i *
Xylene lo-; '
Total X)4er.ti "
Benzole Acid '
Biil2-ethy;heiy;V.th8iete '
2,4-Di»etnYiDriencl *
2-flethylchenoi *
4-nethylDhencl '
Phenol f
ONSITE HELL
Range (ug/1)
39000B1V)
31001V) - k6003IO
B90C01V! - 140000310
NO
ND
38331 V)
83001V] - 15000(0
50001V)
27301V)
ND
500003(V)-530003(0
570001V) - !900C;0
1600BIV) - 26000B1C)
ND
690' V!
WATER TABLE AQUIFER
Range (ug/1)
0.551V) - 1700BIV)
0.32JIV) - 6901V)
61IV) - 3400JIC)
0.93(0 - 313(0
ND - 233(0
ND - 2.83(0
1.7(0 - 1531V)
ND - 0.1793(0
ND - 78(V)
ND - 3.2(0
1301V) - 21003(0
ND - 153(0
2.231V) - 283(0
0.272B3(V) - 73B1V)
12001V) - 44001V)
ND - 1.43(0
110B1V) - 7600(0
7.31V) - 293(0
ND - 813IO
ND • 433(0
120IV1 - 2101V)
NO - 120(0
ND - 73(0
ND - 11(0
22(0 - 85(0
15(0 - 100(0
ND - 26(0
RED BANK AQUIFER
Range (ug/1)
0.681V) - 9103(0
0.19531V) - 750(V)
0.881V) - 59003(0
ND - 6.4(0
ND
ND
ND - 0.83(0
ND - 0.323(V)
ND - 3631V)
ND
4(0 - 2100(0
ND
ND - 26JIV)
0.226B3IV) - 240BIV)
ND - 3500(0
ND
0.13631V) - 3303(0
ND - 293IV)
ND - 283(0
ND - 12(0
ND
ND
ND
ND
ND - 10(0
ND -1310
ND - 24(0
Carbon Disulfide "
DichlorefIjoreietri
Styrene "
Trichloroetnene "
W
i-a(V)
ND
24001V)
0.3231V) - 8.131V)
ND
ND - 53(V)
ND
0.211JIV) - 0.962W
0.27331V) - 0.5711V)
1231V) - 1601V)
ND
NOTES:
ND
iTlcjtss :*! cjssounc was not detected.
Elan1. i-:::stes n:t detected.
Values t'esenteJ in CDC, FPC dace only.
veiues 6reser.ted in Versa* oeta only.
-------
TABLE 5
LONE PINE LANDFILL
Concentrations of Total netals in Selected Ground Water
January 1989 Analysis by Versar, Inc.
flETAL
Aluiinufl
Antiiony
Arsenic
fieri ui
Beryl li'jt
Cadiiuc
Calciuir.
Cnroi iuir.
Cobalt
Cooper
Iron
Lead
fenesiur.
"genese
Nercury
Nickel
Potassiur
Seleniuic
Silver
Sodius
Thaiiiuir.
Vanaciut
Zinc
NOTE:
ND Indicates
ONSITE WELL
Range lug/1)
4360
ND
ND
887
ND
4.6
3370G3
76
ND
3C
7803«C
23
661GG
• »
-------
TABLE 6
LONE PINE LANDFILL
Concentrations of Dissolved fletals in Selected Ground Uater
January 1989 Analysis by Verser, Inc:
flETAL
Aluiinui
Antitonr
Arsenic
Bariui
Beryllium
Cadtiun
Calciut
Chroiiui
Cobalt
Copper
Iron
Lead
flagnesiut
Ranganese
Bercury
Nickel
Potassium
Seleniufi
Silver
Sodius
Thallium
Vanaaiut
Zinc
NOTE:
ND Indicates that
ONSITE WELL
Range (ug/1)
3480
ND
ND
934
ND
ND
3543:0
bw
ND
19
80400G
13
69600
1290
ND
27
2280C
ND
ND
43200
ND
71
84
the letal was not detected.
UATER TABLE AQUIFER
Range (ug/1)
ND - 712
ND
ND
21 - 171
ND
ND
' 11200 - 36900
ND
ND - 4.8
ND
8460 • 133000
ND - 176
2280 • 6800
92 - 568
ND
ND - 46
3130 - 5400
ND • 4
ND
3240 - 7480
ND
ND - 9
34 - 3030
RED BANK AQUIFER
Range (ug/1)
ND - 259
ND
ND
18 - 159
ND
ND
10400 - 34600
ND
ND - 9
2.3
66 - 65400
ND - 2100
1420 - 5970
12 - 240
ND
ND
2250 • 5400
ND - 3.6
ND
2880 - 11400
ND
ND - 5.7
13 - 12400
The or.ir onsite well saipled was EPA-14A, screened in the Red Bank unit.
-------
TAnr.r: 7
'Compound
Monzone
,;l.hylbon7.eno
•':h I oroben'-^ne
rtothylenc Chloride
'I'oluone
2-nutanone
Arsenic
Chromium
Maximum Concontrnt ion Detected (ports por billion)
Drum:? (Hoi his)1
n, 500
3,40O,OOO
4 ,noo
30,OOO
5,900,000
NAF5
80,OOO
1,600,000
r. round Water
(Mound)''
4 , 7OO
1 ,400
4,400
2HO
1,600
1,425
f.17
212
Ground Wnter
(Toe)5
3,000
2,000
ND6
120,000
10,000
200,000
ND
65
Ground Water
( Plume) *
l,939(c)
3,635(c)
97(c)
527(c)
4,700(c)
7,400(a)
110(b)
320(b)
Mananquan
River*
ND(a)
1.7(a)
ND(a)
3.0(a)
ND(a)
17.0(a)
N0(a)
3.0(a)
Source: Lone Pine Landfill, Final Report, Excavation and Sampling, January 15, 19C2.
Source: Lone Pine Landfill Off-Site Remedial Investigation, S.S. Papadopulos 6
Associates, July, 1990.
Well installed at "toe" of landfill; Source: Lone Pine Landfill, Off-Site
Investigation, S.S. Papadopulos 6 Associates, July, 1990.
Source:
a) Off-Site Remedial Investigation Report, S.S. Papdopulos 6 Associates,
July, 1990;
b) Presentation of Analytical Chemical Data, Lone Pine Landfill, NUS
Corporation, March 20, 1984;
c) Lone Pine Landfill, Hydrogeologic Investigation, Fred C. Hart
Associates, April, 1902.
NAF = Not analyzed for
ND «= Not detected
-------
TABLE 8
CONCENTRATION OF INDICATOR CHEMICALS IN GROUND WATER
INDICATOR CHEMICAL MAXIMUM
CONCENTRATION*
ACETONE . - 7.9 X 10s
BENZENE 1.1 X 10*
2-BUTANONE 7.4 X 10s
CHLOROBENZENE 2.9 X 101
CHLOROFORM 1.5 X 10°
1,2-DICHLOROETHANE 3.9 X 101
1,1-DICHLOROETHENE 4.0 X 101
EIKYLBENZENE 1.2 X 10*
KZTHYLENE CHLORIDE 8.0 X 103
4->'.I7HYL-2-PENTANONE 1.6 X 10*
1,1,2,2-TETRACHLOROETHANE 1.9 X 10°
TOLUENE 2.6 X 10*
TRZCKLOROITKENE 1.1 X 101
VINYL CHLORIDE . 5.1 X 101
XYLENES 1.5 x 102
FASTS PER BILLION
-------
TAIU.E 9
NON-CANCER RI.SKS Anr.OClATED HtTII THE I«NE PINE LANDFILL
(GROUND HATER EXPOSURE)
ACrVONE
i IE .7.l:NF.
2-WTANONE
C1I1/1HOI1FN7.ENE
I.I- IUrnm»OF.THENE
r.Ti|Yl.nEN7.ENK
nETiivi.ENE CHLORIDE
* -nrTIIVL-Z-PRNTANONE
TF.TRACHIOROETHANE
TOIJIIENE
Tit I «JIIIX)ROETIIENR
viw.'L CHLORIDE
KVLKNES
RUM
ORAL RfD
(mq/Kq/day)
1.0 R 10 '
5.0
2.O
1.0
9.0
1.0
6.0
5.0
10
10
10
10'
10
10
ID'1
3.0 X 10
2.0 x 10°
INCEPTION III
1 X 10°
2
2
7.
^
2
2
5
X
X
X
*•
X
X
X
X
10'
10
10
10
10
10
t
J
t
1
y
c
• i
i
10°
1 X 10'
1 X 10
B.6 X 10"
INIIAIJVTION RfD
(mq/kq/clny)
9.O x 10"
5.0 x 10*
3.0 x 10
1.0 x 10°
4.0 x 10
INHALATION Ht
2 X 10
1 X 10
5 X 10"*
5 X 10'*
7 X 10"*
0.2 X 10fJ
8.8 X 10*
ill "
reference dose
hazard Index
not applicable
-------
r
TAm.E 10
CANCER RISKS ASSOCIATED WITH THE inNS PINE IJVNDFILt.
(r.HOUNU HATER EXfUSUKK)
ORAL TPF
INCFSTIOM RISK
I MM/MAT I ON CPP INHALATION RISK
ACF.TONP.
in ri/.i HI:
Z-MIITANONE
rllU)HO|-(>l(M
1 . 7-iMcnmiiOETIIANE
I . •-~IUCIIUiROF.HTI-:NB
KT IVI.IIENXENE
HirniYI.F.NF. CMIyOPlDR
4 - f "-mi V I,- 2 - I'ENTANONE
TI:YKACIIU)ROCTIIANF.
TOUIF.NE
Tl«! CHIflROETHKNR
VI-IYI. CIIU)R1DE
X\ . .F.NES
Sllfi
2. 9 X 10
6.1 X 10'*
9.1 X 10 '
6.0 X 10
7.5 X 10 '
2.0 X 10''
1.1 X 10*
2.3 X 10*
f, K lO
7. X 10
7 K 10
5 K 1O
1 X 10
7 X 10"
2 X 10
2 X 10
3.3 It 10
2.9 X 10
n.i x 10
9.1 X 10
1.2 X 10
1.4 X 10
2.O X 10'
1.3 X 10
3.0 X 10'
8 X 10
3 x 10
8 X 10
1 X 10
3 X 10"
9 X 10
3 X 10
4 x 10
2.6 X 10"'t
3.5 X 10'*
C.'F = cancor potency factor
«= not applicable
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TABLE 11
Action-Specific ARARs
Wastewater Treatment Plant:
Clean Water Act, 42 U.S.C. 7401 et seq.:
Resource Conservation and Recovery Act, 40 CFR Parts 264 and 265 Subparts
X, Y, Z, AA, and BB;
National Ambient Air Standards, 40 CFR 50;
Hazardous Materials Transportation Act, 49 U.S.C. 1801 - 1813;
Hazardous and Non-hazardous Waste Regulations, N.J.A.C. 7:26 et seq.:
Air Pollution Control Regulations, N.J.A.C. 7:27 et seq.:
Prohibition of Air Pollution, N.J.A.C. 7:27-5;
Control and Prohibition of Air Pollution by Volatile Organic Substances,
N.J.A.C. 7:27-16;
Control and Prohibition of Air Pollution by Toxic Substances, N.J.A.C. 7:27-17;
Emission Offset Rule, N.J.A.C. 7:27-18;
New Jersey Ambient Air Quality Standards, N.J.A.C. 7:27-13;
Spill Notification requirements, N.J.A.C. 7:1 (e);
Notice of Release of Hazardous Substances to Atmosphere, N.J.S.A. 26:2c-19;
and
Air Pollution Emergencies, N.J.A.C. 7:27-12.
Other Action-Specific ARARs:
General Ground Water Monitoring Requirements, 40 CFR 264.97;
Occupational Safety and Health Administration requirements, 29 U.S.C. 651-
678 (40 CFR 300.38, 40 CFR 61, 40 CR 1910.120);
General Requirements for Permitting Wells, N.J.A.C. 7:9-7;
Sealing of Wells Procedures, N.J.S.A. 7:9-9;
Well Drillers and Pump Installers Act, N.J.S.A. 58:4A-5 et seq.:
Noise Control Act of 1971, N.J.S.A. 13:1G-1 et seq.:
Noise Pollution Regulations, N.J.A.C. 7:29-1; and
Storage Tank Regulations, 40 CFR 264.190 - 198.
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TABLE 12
ARARS Associated With the Selected Remedy
Location-Specific ARARs
Fish and Wildlife Coordination Act, 16 U.S.C. 661 et seq.:
Clean Water Act §404 (40 CFR 230, 33 CFR 320 - 330);
Executive Order 11990, Protection of Wetlands;
Executive Order 11988 (40 CFR 6, Appendix A), Floodplain Management;
National Historic Preservation Act of 1966, as amended, 16 U.S.C. 470 et seq.
and 469;
New Jersey Flood Hazard Area Regulations, N.J.A.C. 7:13-1.1 et seq.: and
New Jersey Freshwater Wetlands Protection Act Rules; N.J.A.C. 7:7A-1.1 et seq.
Chemical-Specific ARARs
Federal Safe Drinking Water Act (SDWA) Maximum Contaminant Levels
(MCLs) (including the RCRA Maximum Concentration Limits;
New Jersey Safe Drinking Water Act A-280 Amendments;
New Jersey Pollution Discharge Elimination System regulations
(N.J.A.C.7:14A-1.1 et sefl.)
N.J.A.C. 7:10-16 et seq.. and 7:9-6 et seq.
SEE ALSO TABLE 2
Action-Specific ARARs
•
WASTEWATER TREATMENT PLANT
Clean Water Act, 42 U.S.C. 7401 et seq.:
Resource Conservation and Recovery Act, 40 CFR Parts 264 and 265 Subparts X,
Y, Z, AA, and BB;
National Ambient Air Standards, 40 CFR 50,
Hazardous Materials Transportation Act, 49 U.S.C. 1801 - 1813;
Hazardous and Non-hazardous Waste Regulations, N.J.A.C. 7:26 et seq.:
Air Pollution Control Regulations, N.J.A.C. 7:27 et seq.:
Prohibition of Air Pollution, N.J.A.C. 7:27-5;
Control and Prohibition of Air Pollution by Volatile Organic Substances,
N.J.A.C. 7:27-16;
Control and Prohibition of Air Pollution by Toxic Substances, N.J.A.C. 7:27-17;
Emission Offset Rule, N.J.A.C. 7:27-18;
New Jersey Ambient Air Quality Standards, N.J.A.C. 7:27-13;
Spill Notification requirements, N.J.A.C. 7:1 (e);
Notice of Release of Hazardous Substances to Atmosphere, N.J.S.A. 26:2c-19;
and
Air Pollution Emergencies, N.J.A.C. 7:27-12.
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TABLE 12 (continued)
ARARS Associated With the Selected Remedy
WASTEWATER TREATMENT PLANT (CONTINUED) .
Sludge generated by the operation of a wastewater treatment plant would have
to be disposed of in accordance with the requirements of the Resource
Conservation and Recovery Act, including the Land Disposal Restrictions.
INJECTION OF TREATED GROUND WATER INTO RED BANK AQUIFER
Safe Drinking Water Act, 40 CFR 144;
New Jersey Pollutant Discharge Elimination System, N.J.A.C. 7:14A et seq.: and
New Jersey Ground Water Quality Criteria, N.J.A.C. 7:9-6 et seq.
ADDITIONAL ACTION-SPECIFIC ARARs
General Ground Water Monitoring Requirements, 40 CFR 264.9,7
Occupational Safety and Health Administration requirements, 29 U.S.C. 651 - 678
(40 CFR 300.38, 40 CFR 61, 40 CR 1910.120);
, General Requirements for Permitting Wells, N.J.A.C. 7:9-7;
Sealing of Wells Procedures, N.J.S.A. 7:9-9;
Well Drillers and Pump Installers Act, N.J.S.A. 58:4A-5 et seq.:
Noise Control Act of 1971, N.J.S.A. 13:1G-1 et seq.:
Noise Pollution Regulations, N.J.A.C. 7:29-1; and
Storage Tank Regulations, 40 CFR 264.190 - 198.
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EXHIBIT I
LONE PINE LANDFILL SITE
OPERABLE UNIT II
RESPONSIVENESS SUMMARY
FOR THE
RECORD OF DECISION
TABLE OF CONTENTS
Pape
Overview 1
Background 2
Comprehensive Summary and Responses to Significant Comments 2
A. Operable Unit I, Source Control Remedy 3
B. Operable Unit II, Ground Water Remedy 4
C. Remedial Alternatives for Operable Unit II 7
D. Computer Modeling 14
E. Risks and Contamination Associated with
Operable Unit II 15
F. General Comments 19-
References 21
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RESPONSIVENESS SUMMARY
LONE PINE LANDFILL SITE
OPERABLE UNIT II
This community relations responsiveness summary is divided into the following sections:
Overview: This section discusses EPA's preferred alternative for remedial action.
Background: This section provides a brief history of community interest and concerns
raised during remedial planning at the Lone Pine Landfill Site.
Summary of
Comments: This section provides a summary of commentators' major issues and
concerns, and expressly acknowledges and responds to all significant
comments raised by the local community. "Local community" includes
local homeowners, businesses, the municipality, and potentially responsible
panics (PRPs).
OVERVIEW
At the initiation of the public comment period, EPA presented its preferred alternative for
the second operable unit at the Lone Pine Landfill Site, located in Freehold Township,
New Jersey. The first operable unit remedy is a landfill containment system (cap, slurry
wall, and leachate collection/treatment) which will prevent the migration of landfill
leachate into the aquifer system. The second operable unit remedy was devised to
remediate ground water outside the boundary of the first operable unit's slurry wall.
The selected remedy for the second operable unit includes the installation of a 2,800-
foot long interceptor drain keyed into the Hornerstown Formation; installatipn of
approximately 3 extraction and 24 injection wells screened in the Red Bank aquifer;
construction of an on- site wastewater treatment plant to treat the ground water captured
by the interceptor drain and extraction wells to meet the applicable or relevant and
appropriate requirements (ARARs) which would include federal and state Maximum
Contaminant Levels (MCLs); and the construction of a recharge trench to discharge
treated ground water during maintenance of the injection wells. In addition, long-term
monitoring of the aquifers and the Manasquan River, including sediment and biota
studies, and institutional controls to restrict ground water usage in the area affected by
the site will be necessary.
The principal threat at this site is the contaminated ground water which currently
migrates off-site into the Manasquan River. However, upon construction and
implementation of the second operable unit remedy's interceptor drain and extraction
wells, the contamination will cease migrating into the river thereby eliminating the threat
to human health and the environment. However, due to the lengthy period of time
estimated for cleansing the aquifer to MCLs, long-term management will be required.
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BACKGROUND
The RI/FS Report and the Proposed Plan for the Lone Pine Landfill Operable Unit II were
released to the public for comment on July 17, 1990. These two documents were made
available to the public in the administrative record file, located at the information
repositories maintained at the EPA Docket Room in Region II, the Monmouth County
Public Library and the Freehold Township Health Department. The notice of availability
for these documents was published in the Asburv Park Press on July 17, 1990. A public
comment period on these documents was held from July 17, 1990 to September 15,
1990. In addition, a public meeting was held on August 1, 1990. At this meeting,
representatives from EPA answered questions relating to the site and the remedial
alternatives under consideration. Responses to the comments received during the
comment period are included in this Responsiveness Summary.
COMPREHENSIVE SUMMARY AND RESPONSES TO SIGNIFICANT COMMENTS
This section provides a comprehensive response to all significant comments and
summarizes the major issues and concerns raised by the local community. The questions
and comments on the proposed remedy for the Lone Pine Landfill site received at the
public meeting on August 1, 1990 and during the public comment period through
September 15, 1990, can be grouped into six categories:
A. Operable Unit I, Source Control Remedy for the Lone Pine Landfill
B. Operable Unit II, Ground Water Remedy For the Lone Pine Landfill
C. Remedial Alternatives for Operable Unit II
D. Computer Modeling
E. Risks and Contamination Associated with Operable Unit II
F. General Comments
A summary of the comments and EPA's response to them is provided below.
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A. Operable Unit I, Source Control Remedy
1. The Mayor of Freehold Township asked for an explanation of the length of time that
has elapsed since the signing of Operable Unit I Record of Decision and a timetable for
implementation. A citizen of Freehold Township also provided written comments on this
subject. (References A and E)
EPA Response: The delay in implementation of the first operable unit ROD is unusual and
is the result of several factors. First, there has been difficulty in reaching an agreement
for disposition of the leachate from the treatment plant. The ROD provided for two
alternatives: discharge to the local publicly owned treatment works [in this case, the
Ocean County Utilities Authority (OCUA)], or discharge to the Manasquan River.
EPA's preference was to gain access to the OCUA. Consequently, EPA performed
treatability studies on the leachate which proved that, once passed through EPA's
proposed treatment system, the leachate meets all technical requirements for OCUA.
However, OCUA nevertheless refused to commit to acceptance of the leachate, admittedly
because the treated leachate is from a Superfund site. After several years of additional
studies for OCUA and unsuccessful attempts to convince OCUA to accept the treated
leachate, EPA had no choice but to proceed with the other disposal option, discharge to
the Manasquan River. EPA then re-designed the treatment plant in order to meet
applicable discharge requirements.
In the Summer of 1989, EPA reached agreement with 116 potentially responsible parties
(PRPs) for privately-funded implementation of EPA's design, which provided for the river
discharge. Due to the expected public opposition to river discharge, EPA included a
provision in the PRP agreement to require the PRPs to make a final attempt to gain
access to OCUA. Unfortunately, the issue of leachate disposition is still not resolved,
since an agreement with OCUA has not yet been reached. EPA's goal is to resolve the
issue in October, 1990.
An additional source of delay relates to the agreement with the PRPs, in the form of a
judicial Consent Decree. Though the Consent Decree was signed by a large number of
PRPs in the Summer of 1989, a group of PRPs which did not sign the agreement felt it
was "unfair". This group instituted proceedings to challenge the agreement, which had
to be contested in court by EPA and the Department of Justice. The government was
eventually successful and the Consent Decree was entered in Federal District Court in
March, 1990. There was a lengthy period of delay caused by the challenge, but the PRPs
who signed the Consent Decree are now proceeding ahead with the negotiations with
OCUA and the final construction plans for implementation of the Operable Unit I remedy.
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2. The Township Administrator reiterated the Township's unconditional opposition to
direct discharge into the Manasquan River for the treated leachate from the Operable Unit
I treatment plant, and stated that the public feels very strongly that this disposal option
should not be pursued. (Reference A)
EPA Response: Final disposition of the treated leachate has not yet been resolved. As
stated in the response to Comment I.A., above, EPA first attempted to dispose of the
treated leachate through OCUA, but to date, has not been successful. EPA only
proceeded with the design for the river discharge after years of unsuccessful negotiations
with OCUA. EPA hopes to make a final decision in October 1990. EPA is aware of the
public concern about river discharge, but must balance the public's concern with the need
to have the Operable Unit I remedy implemented. Another option EPA is considering
is to reinject the treated leachate from Operable Unit I along with the treated ground
water from the Operable Unit II remedy. In order to implement reinjection for Operable
Unit I, the PRPs who settled with EPA for implementation of Operable Unit I ROD would
have to agree.
B. Operable Unit II, Off-Site Ground Water Remedy
1. The Mayor of Freehold Township asked about the timetable for implementation of
the Operable Unit n remedy and who would perform the work. (Reference A)
EPA Response: After the Operable Unit II ROD is finalized, the design of the selected
remedy will be implemented and when complete, construction will be initiated. Under
the Superfund program, EPA may provide the PRPs with the opportunity to design and
implement the selected remedy. If it does so, EPA will set very strict deadlines for
negotiations with the PRPs. If an agreement with the PRPs cannot be reached, EPA will
either move ahead and design and implement the remedy utilizing Superfund monies and
later recover the costs from the PRPs, or will order the PRPs to implement the design and
construction. After the negotiation stage, whether EPA or the PRPs implement the
design, EPA anticipates that it would take from 12 to 18 months to complete the design,
and approximately 2 years to complete the construction.
2. The PRPs commented that institutional controls on ground water use and land
development in the Lone Pine Landfill vicinity would be adequate as a remedy for
Operable Unit 0. (References C and F)
EPA Response: The National Contingency Plan (NCP) states that institutional controls
shall not substitute for an active response measure as the sole remedy :
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"EPA expects to use institutional controls such as water use and deed restrictions
to supplement engineering controls as appropriate for short- and long-term
management to prevent or limit exposure to hazardous substances, pollutants or
contaminants.... The use of institutional controls shall not substitute for active
response measures (e.g., treatment and/or containment of source material,
restoration of ground waters to their beneficial uses) as the sole remedy unless such
active measures are determined not to be practicable, based on the balancing of
trade-offs among alternatives that is conducted during the selection of the remedy."
40 CFR §300.430 (a)(l)(iii)(F)
EPA has determined that, in this case, active response measures are practicable, and
therefore will utilize institutional controls only to supplement such active measures. In
addition, institutional controls such as deed restrictions and land use restrictions would
be difficult to enforce, and consequently, cannot be relied upon as the sole protective
measures to prohibit exposure to contaminated ground water.
3. The PRPs commented that the NCP requires that each operable unit be consistent
with the overall remedy at the site. These Commenters argue that this requirement has
not been met with the proposed remedy for Operable Unit n, since the two remedies
have not been integrated and the implementation of the Operable Unit n remedy would
have a hydraulic impact on the Operable Unit I remedy. (References C and F)
EPA Response: The selected remedy for Operable Unit II is consistent with the overall
goal for remedial action at the Lone Pine Landfill site, which is to contain contaminants
within the landfill and remediate contamination which has already emanated from the
landfill boundaries. The computer modeling undertaken during the Operable Unit II
RI/FS was performed with the assumption that the Operable Unit I remedy was in place
and operational. Thus, the modeling results provide the foundation for evaluating the
best available alternatives for remediating the off-site plume assuming no further
contaminant migration from the landfill occurs. The selected remedy was specifically
designed so as not to compromise the effectiveness of the Operable Unit I remedy. The
design of the selected remedy for Operable Unit 2 will be implemented in a way which
will avoid any hydraulic impact to the landfill containment system. The modeling
conducted shows that the selected remedy can be implemented without compromising the
effectiveness of the Operable Unit I remedy.
In addition, the ROD for Operable Unit II provides for the possibility of combining the
Operable Unit I and II treatment plants thus producing one effluent stream.
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4. The PRPs commented that the Operable Unit I and II remedies are inconsistent since
EPA has decided to manage the "same ground water" with two different technologies. The
Commenters cite EPA's 1984 ROD, which calls for either river discharge or OCUA
treatment, and argue that this decision is inconsistent with the proposed remedy, which
calls for reinjection of the treated ground water. (Reference F)
EPA Response: EPA is not choosing two distinct technologies to handle the "same ground
water." There are several reasons why the disposal options selected for the two operable
units are different. First, the leachate to be collected within the slurry wall as part of
the Operable Unit I remedy is a concentrated waste stream, with extremely high levels
of contaminants, while the ground water plume is more dilute. Consequently, the
influent concentrations to the two anticipated treatment plants are expected to be
significantly different.1
Second, in 1984, when disposal options for the Operable Unit I remedy were evaluated,
reinjection was still an emerging technology, and little was known about its feasibility
for use as a disposal mechanism. Moreover, when EPA selected the Operable Unit I
remedy, the Agency simultaneously established the need for a comprehensive ground
water study (the Operable Unit II RI/FS), and could not have planned for reinjection of
the leachate as not enough was known the hydrology and ground water conditions which
were the subject of the future study.
Third, the reinjection component of the selected remedy for Operable Unit II functions
not only as a disposal mechanism, but also serves to expedite cleanup of the Red Bank
Aquifer.
Finally, the public has expressed opposition to river discharge for the Operable Unit I
remedy due to the presence of a drinking water reservoir downstream. Consequently,
in evaluating options for remediation for Operable Unit II, EPA determined that
reinjection was preferred over river discharge. In addition, the option of sending the
treated effluent to OCUA for Operable Unit II was projected to be more costly.
5. The PRPs urged EPA to defer the decision relating to Operable Unit n until the
Operable Unit I remedy is implemented. Certain Commenters state that, if the river
conditions improve as a result of implementation of Operable Unit I, the ground water
may qualify for Alternate Concentration Limits (ACLs). (References C and F)
1 This difference in expected influent concentrations will have to be evaluated in
determining the practicability of combining the Operable Unit I and II treatment plants
and having only one facility. (See response to Comment B.3., above.)
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EPA Response: The results of the Operable Unit II RI/FS showed that ground water is
heavily contaminated at levels which far exceed the applicable standards, and that the
contaminant plume is currently discharging into the Manasquan River adjacent to the
landfill. Consequently, EPA has adequate information to determine that active measures
to control such migration and remediate the ground water are necessary. The NCP
stipulates that action should be taken as quickly as possible once the studies are deemed
complete and adequate:
"Remedial actions are to be implemented as soon as site data and information make
it possible to do so."
40 CFR §300.430(a)(l).
It is therefore inappropriate to delay implementation of the Operable Unit II remedy.
At the present time, the Lone Pine Landfill site does not meet the necessary criteria for
imposing ACLs. These criteria would require certainty that:
(1) the ground water has a known or projected point of entry to surface
water; and
(2) there are no statistically significant increases in contaminant concentration
in the surface water or at any point at which the contaminants are
expected to accumulate.
In this case, site-related contaminants have been detected in surface water adjacent to
the site, and thus the above criteria for use of ACLs is not satisfied. In addition, EPA's
policy is that ACLs can be used only when, in addition to the above criteria, cleanup to
ARARs is not practicable. (See "Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites", OSWER Directive 9283.1-2 at 2-4.)
EPA has provided for reevaluation of the Operable Unit II remedy if it becomes apparent
that ARARs cannot be attained (i.e., if full cleanup is not practicable). The application
of ACLs may be considered at a later date as part of an overall reevaluation of the
remedy after implementation and operation is monitored.
C. Remedial Alternatives Evaluated for Operable Unit II
1. A member of the Township environmental commission indicated that Alternative 6
should be selected instead of EPA's proposed Alternative 5. The commission feels that
the timeframe for the remedy should be kept as short as possible, preferably within the
lifetime of the equipment and the residents of Freehold Township. The commission feels
that the implementation concerns EPA has regarding Alternative 6 can be successfully
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overcome. The commission stated that if the proper balance of pressure and volume are
maintained, there should be no problem with recontamination of the Red Bank aquifer,
and that since the landfill already has monitoring wells and will have "methane vents,
drilling through the landfill should not be a problem. In addition, the commission stated
that it seemed as though EPA's overriding consideration in proposing Alternative 5 was
cost, which is inappropriate since Alternative 5 would probably cost more than
Alternative 6 over 165 years. (References A and B)
EPA Response: The NCP requires EPA to perform a detailed analysis consisting of an
assessment of individual alternatives against each of nine criteria and a comparative
analysis that focuses upon the relative performance of each alternative against those
criteria. One of the nine criteria is Implementabilitv. The NCP States that:
"the ease or difficulty of implementing the alternatives shall be assessed by
considering... technical feasibility, including technical difficulties and unknowns
associated with the construction and operation of a technology, the reliability of
the technology, ease of undertaking additional remedial actions and the ability to
monitor the effectiveness of the remedy...."
40 CFR §300.430(e)(9)(iii)(F)
In the comparative analyses of the six alternatives, EPA determined that the simplest to
implement was Alternative 1 (No Action), and Alternatives 3, 5, and 6 were the most
difficult to implement by virtue of the number of wells required and the need to regulate
injection and withdrawal so as not to disturb the Operable Unit I remedy. As stated by
the Commenter, if the proper balance of pressure and volume are maintained, there
should be no problem with recontamination by compromising the landfill containment
system. However, because of the number of wells estimated to be required for
Alternative 6 and their required location, implementation of Alternative 6 poses potential
health and safety risks which none of the other alternatives face. In addition, the risks
of compromising the Operable Unit I remedy are significantly increased with Alternative
6. Though monitoring wells were installed through the landfill, these were installed prior
to the construction of the cap, and thus did not compromise its integrity. In addition,
the installation of monitoring wells or air vents is not directly comparable to the
installation of a significant number of injection wells, which are much larger in diameter,
and would require intensive maintenance.
Cost was not EPA's overriding consideration in selecting Alternative 5. Cost, along with
long-term effectiveness and permanence, reduction of toxicity, mobility and volume, short-
term effectiveness and implementability, were used as the primary balancing criteria as
required by the NCP.
8
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With respect to costs over the period of operation of Alternative 5, EPA re-estimated the
net present value of Capital and Operation and Maintenance costs for the entire estimated
operational life of each alternative. EPA included in the revised estimates the
replacement costs of all equipment over the time period of required operation. The
details of the revised cost estimates are attached in Exhibit 2. The results show that
Alternative 5 would cost $10,267,661, while Alternative 6 is still more expensive, at
$23,237,241.
2. A meeting attendee inquired, with regard to the clean up times for the two aquifers
for Alternative 6 (19 years for die Water Table and 14 years for the Red Bank) why
treatment of the Red Bank aquifer couldn't get started first, and pumping of the Water
Table aquifer follow later.
EPA Response: The ground water studies conducted at the site indicate that the Water
Table aquifer and the Red Bank aquifer are hydraulically connected. Therefore, this
precludes pumping of the Red Bank Aquifer separately to equalize the time required for
cleanup of both aquifers.
3. A meeting attendee inquired as to why there was a variation in clean up times
between the Water Table and Red Bank aquifers.
EPA Response: The area of the Water Table aquifer which requires cleanup is much
smaller than that in the Red Bank. This is because a portion of the Water Table Aquifer
(within and beneath the Landfill, itself) will be cleaned up by the drains to be installed
as pan of the Operable Unit I remedy. The slurry wall and the interior drain system will
not significantly alter ground water flow in the Red Bank aquifer. Since the portion of
the Red Bank Aquifer which underlies the landfill will not be drawn into the drains, the
areal extent of contamination requiring cleanup in the Red Bank Aquifer is much larger.
(See Figures 6 and 7 of the Operable Unit II ROD, which show the areal extent of
contamination in each aquifer to be addressed by the selected remedy.)
4. A meeting attendee discussed the condition of the reported 17,000 to 50,000 drums
of chemicals which were disposed of in the landfill. He stated that he believed some of
the drums are intact and still contain wastes, and inquired as to how the computer
modeling and proposed ground water treatment system dealt with the unknowns
associated with rupturing drums.
EPA Response: The remedy selected and designed for Operable Unit I is expected to
contain any "new" input of leachate from rupturing drums. The possibility of intact
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drums which could rupture was one of the main reasons why the Operable Unit I remedy
provides for total containment of the landfill (cap, slurry wall, and a leachate collection
system). The computer modeling and conceptual design of the treatment system for
Operable Unit II were both performed with the assumption that the landfill containment
system was in place, and thus focused on contamination which has already migrated into
the ground water.
5. A meeting attendee commented that he perceived that Alternative 6 was included
in the evaluation as an extreme and that its purpose was to steer the alternative selection
back to one of the other alternatives. (Reference A)
EPA Response: The goal of the Feasibility Study was to develop and evaluate alterative
that attain MCLs wjthin different restoration time periods utilizing one or more different
technologies, as required by the NCP. Alternative 6 was developed as an option to
remediate the contaminated ground water as quickly as possible. EPA did not select
Alternative 6 because, based on a comparison of all alternatives against EPA's nine
evaluation criteria, Alternative 6 poses significant implementability problems, costs more
than double the next most expensive alternative, and does not provide a substantially
greater degree of protectiveness.
6. A resident of Freehold Township expressed concern about the operation times for
several of the alternatives, how the systems would be maintained for such long periods
of time, and how the alternatives were costed out. (Reference A)
EPA Response: The estimated clean up times of the aquifers and consequently, the length
of time required for operation of the various remedial alternatives are based on a
computer simulation. This simulation uses the best available data for its modeling of
hydrogeologic site conditions. Therefore, the time frames represent the best estimates
for relative cleanup times among the various alternatives. During the operational life of
the selected remedy, the system's performance will be carefully monitored on a regular
basis and adjusted as warranted.
The six alternatives were costed on a present value worth basis, for the expected
operation time of each alterative, as is standard engineering practice.2
2 See also response to Comment C.I., which explains the re-evaluation of cost
conducted as a result of the concern about replacement costs and operational life.
10
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7. One of the PRPs commented that ARARs should be waived for the Lone Pine site
based on the criteria of technical impracticability. (Reference C) In a related comment,
a group of PRPs commented that the alternatives are impractical because of the length
of time required to achieve protectiveness and that distinctions among the alternatives
based on the time required to achieve MCLs would violate the NGP. (Reference F)
EPA Response: According to the NCP:
"EPA expects to return usable ground waters to their beneficial uses within a
timeframe that is reasonable given the particular circumstances of the site. When
restoration of ground water to its beneficial uses is not practicable, EPA expects to
prevent migration of the plume, prevent exposure to contaminated ground water and
evaluate further risk reduction."
40 CFR §300.430(a) (1) (iii) (F)
For the reasons outlined below, the goals established for remediation of the ground
water at the Lone Pine site are consistent with the NCP, and EPA believes that
restoration of ground water to its beneficial uses is practicable, despite the fact that a
lengthy period is estimated to remediate the Red Bank aquifer.
The timeframes estimated to be required to restore the ground water to meet applicable
or relevant and appropriate requirements (ARARs) are a direct result of the necessary
limitations on pumping and treating the ground water. The circumstances at this Site
preclude the typical pumping and treatment schemes due to the fact that pumping cannot
be permitted to reverse the hydraulic gradients of the Operable Unit I landfill containment
system. Under other circumstances, pumping could be performed at much higher rates
to extract the contamination as quickly as possible. In this case the selected remedy
requires extraction and injection farther from the core of the contamination, which results
in slower remediation times. Consequently, the "circumstances of the site" necessitate
longer remediation times for the Red Bank aquifer.
EPA has determined that it is practicable to remediate the ground water at the Lone
Pine site. The goals of the Operable Unit II remedy, as set forth in the ROD, are to
prevent migration of the contaminant plume to the Mana*squan River or other areas, and
to restore the ground water to its beneficial uses. As provided in the ROD, if, after
operation of the remedy, it becomes apparent that restoration of ground water quality
is not practicable, the remedy will be reevaluated.
The Commenters reference EPA's "Guidance on Remedial Actions for Contaminated
Ground Water at Superfund Sites", and conclude that the Agency has determined "that
any alternative which takes longer than 100 years to implement is impractical." This is
an incorrect conclusion. The guidance states that:
11
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"For ground water remedies technical impracticability may be measured in terms of
restoration timeframe. A time frame beyond 100 years would eenerallv warrant the
technical impracticability waiver. "
OSWER Directive 9823.1-2 at 6-2
In this case, the fact that the selected remedy is estimated to require 165 years to
remediate the Red Bank aquifer and 14 years to remediate the Water Table aquifer does
not conflict with this guidance. As noted by the Commenters, the timeframes for
remediation to cleanup standards are estimates derived by a computer model which
provides a simplified simulation of the sites's hydrology. EPA recognizes this and believes
it is therefore premature to determine that it will necessarily take 165 years to restore
the ground water quality in the Red Bank aquifer to ARARs. In fact, it may take
significantly less than 100 years, the time frame cited by the Commenters as the
practicality limit. It should be noted that EPA expects a significant amount of the
contamination in the Red Bank to be removed within three decades (the time required
to remove one pore volume). Furthermore, the timeframes the Commenters appear to
criticize as being greater than 100 years all apply to the Red Bank aquifer only. This
aquifer is much less contaminated than the Water Table aquifer, which, under any
alternative, is expected to take less than twenty years to remediate.
In summary, with the exception of Alternative 6 (which poses some implementability
problems) the various remedial alternatives evaluated are technically feasible and can be
implemented within a reasonable time frame given the circumstances of the site.
Consequently, an ARAR waiver based on technical impracticability is not justified at the
present time.
8. The PRPs commented that EPA has ignored implementability problems associated
with the use of injection wells. The Commenters further state that the Long Island water
authorities have recognized the impracticality of the use of injection wells and therefore,
almost exclusive use seepage basins to recharge aquifers. (Reference F)
EPA Response: EPA is aware of'the problems often associated with injection wells (e.g..
chemical precipitation, air entrainment, and sand pumping), but does not agree that
operation of such wells is technically impracticable. One purpose of the recharge trench,
which is a component of all alternatives utilizing injection wells, is to provide for
disposition of effluent during periods of necessary injection well maintenance. It is EPA's
intent to ensure that the design and construction of the injection wells are optimized and
that the wells are maintained on a regular basis in order to avoid any implementation
difficulties.
12
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The Commenters compare the general lack of use of injection wells on the entire island
of Long Island, New York, to the proposed remediation at the Lone Pine Landfill site.
This comparison is not warranted. While both Long Island and the site are situated
within the Atlantic Coastal Plan Physiographic Province, there are different geologic
formations at each of the two locations, with many varieties within Long Island, itself.
The Long Island water authorities are operating to achieve a different set of goals than
those for Superfund remediation. At the Lone Pine site, injection is being utilized for the
purpose of pushing contaminants through the aquifer as well as for disposal.
9. The PRPs commented that EPA correctly rejected Alternative 6 for implementability
reasons. (Reference F)
EPA Response: EPA agrees with the Commenters that Alternative 6 poses implementability
problems, and as discussed under the response to Comment C.I., above, Alternative 6 was
rejected based on a balance of all evaluation criteria, including implementability.
10. The PRPs commented that, based on EPA's Guidance on Remedial Actions for
Contaminated Ground Water at Superfund Sites (OSWER Directive 9283.1-2), natural
attenuation (Alternative 1, No Action), would be the most appropriate response for Lone
Pine.
EPA Response: The guidance cited by the Commenters states:
"Natural attenuation should be carried through the detailed analyses as a point of
comparison, but it is not generally recommended except when active restoration is
not practicable, cost-effective, or warranted because of site-specific situations; e.g.,
Class III ground water is contaminated...."
OSWER Directive 9823.1-2 at 5-7
In addition, the guidance specifically cites the use of reliable institutional controls along
with natural attenuation, and states that such controls should not substitute for active
response measures, unless such measures are determined not to be practicable. (See
discussion of institutional controls in response to Comment B.2.)
The guidance further describes conditions that potentially favor the use of natural
attenuation, which include: (1) ground water that is naturally unsuitable for consumption
(Class III aquifers); (2) low mobility contaminants; (3) low aquifer transmissivity; (4) low
concentrations of contaminants; (5) low potential for exposure; (6) low projected demand
for future use of the ground water; and (7) situations which meet the statutory
requirements for Alternate Concentration Limits.
13
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EPA has determined that the conditions at Lone Pine do not favor the use of natural
attenuation because ground water at the site is classified as IIA (current or potential
source of drinking water), there are high levels contaminants, and the contaminants are
very mobile. Furthermore, as discussed in response to Comment B.5., the site does not
meet the statutory requirement for use of Alternate Concentration Limits.
D. Computer Modeling
1. A member of the audience inquired about the accuracy of the computer modeling
for estimating clean up times of the aquifers and the ability of the remedies to meet
Maximum Contaminant Levels (MCLs).
EPA Response: A version of the three-dimensional modular ground water flow model
developed by the United States Geological Survey (McDonald and Harbaugh, 1988) with
a particle tracking routine (Zheng, 1988) and the batch flushing model was used as a"
tool in the FS in order to simulate the hydrologic conditions that will exist at the site
after the landfill containment system is implemented and to analyze the estimated rates
of ground water remediation under the various alternatives. It is important to note that
the computer modeling for the off-site remedial alternatives was done with the
assumption that the Operable Unit I remedy is in place and operational, and since the
design for the Operable Unit I remedy has recently been slightly refined, computer
modeling will be updated during the design phase for Operable Unit II to make the
modeling as accurate as possible.
The model incorporates the hydrogeologic data collected at the site and general
hydrogeologic information in the published literature regarding the hydrogeology in the
vicinity of the landfill. Therefore the simulation provides the best available tool for
comparing the alternatives. EPA recognizes that the model is a simplification of real-
world conditions and that the remediation timeframes derived by the model are estimates.
However, as the same assumptions are employed for all alternative simulations, the model
provides a basis for comparison.
With respect to meeting MCLs, the Record of Decision will contain contingency measures
to be followed with regard to ability to achieve these cleanup standards within the
contaminant plume. Studies have shown that ground water extraction is effective in
containing contaminant plumes and achieving significant mass removal of contaminants.
However, in most cases, contaminant concentrations cease to decrease linearly over time
in reaching the designed cleanup goals. After significant initial decreases, concentrations
typically level off, often at concentrations higher than the desired cleanup levels. At the
Lone Pine Landfill site it may not be possible to reduce contaminants to cleanup
standards throughout the area of attainment. The practicability of achieving cleanup
14
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goals throughout the contaminant plume cannot be determined until the extraction system
has been implemented and plume response is monitored over time.
*,
If it becomes apparent during operation of the remedial action that contaminant levels
have ceased to decline and are remaining constant at levels higher than the cleanup
standards, the remedy may be re-evaluated. If it is determined that the selected remedy
cannot meet the cleanup standards, contingency measures may replace certain aspects of
the selected remedy.
E. Risks Associated with Operable Unit II
1. The PRPs commented that no current risk is posed by the Lone Pine Landfill, since
the contaminated ground water emanating from the site is not likely to be utilized for
drinking water, and that based strictly on risk, only the No Action alternative is justified.
In addition, the Commenters state that no current risk is posed by the discharge of
contaminated ground water to the surface water (References C and F)
EPA Response: EPA acknowledges the fact that no current risk to human health is posed
by actual human exposure via consumption of contaminated ground water at the site.
However, as described in the Endangerment Assessment (CDM, 1990), potential risks
could be posed by use of the contaminated ground water as a source of drinking water
and by exposure of recreational users of the Manasquan River in the vicinity of the site.
In addition, a drinking water supply reservoir is located downstream from the site.
EPA's "Risk Assessment Guidance for Superfund, Volume 1 Human Health Evaluation
Manual," requires that the endangerment assessment be conducted as if no action were
taken at the site and assess both the current and potential future risks. In addition, the
NCP states that EPA shall:
"...conduct a baseline risk assessment to characterize current and potential threats
to human health and the environment that may be posed by contaminants migrating
to ground water or surface water...."
40 CFR §300.430(d)(4)
The ground water in the vicinity of the landfill is classified as a source of drinking water
(Class IIA), and is utilized for drinking water in the vicinity of the site. The
contaminant plume contains chemicals far in excess of the ARARs. Based on the
classification of the ground water and the potential for human exposure, EPA has
concluded that potential risks relating to ground water exist. EPA quantitatively assessed
the risk associated with human exposure to contaminated ground water and concluded
that the carcinogenic risks would be 3.5 x lO'*, which is outside the acceptable risk range
15
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of 1 x 10^ to 10"6. In addition, in the event of exposure to contaminated ground water,
adverse non-carcinogenic effects are likely to occur.
As described in more detail in the response to Comment E.2., the surface water in the
reach adjacent to the landfill is classified as FW2-NT and is thus recreational and
drinkable. Therefore, standards established for protection of human health, the Federal
Water Quality Criteria for human health consumption of water and organisms are ARARs
for this site.
As required by Section 121(d) of CERCLA, EPA must select remedial actions which at
a minimum achieve ARARs.
2. The PRPs commented that contamination of the surface waters in the vicinity of the
Lone Pine Landfill does not exceed standards set to protect aquatic life. (References C and
F)
EPA Response: Due to the fact that the ground water discharges into the Manasquan
River (refer to Comment E.4., below), the river has also been contaminated by the
landfill. This is verified by the presence of VOCs in the river at surface water sampling
stations downstream of the site during the 1986 sampling events. The VOCs detected at
one of the downstream stations (Burke Road/RS-3A) are methylene chloride, 1,2-
dichloroethane, acetone, 2-butanone and 4-methyl-2-pentanone.
The Clean Water Act provides for the protection of existing and designated uses of
surface waters of the United States. Since this surface water is classified as FW2-NT, a
fishable and drinkable classification, the ambient water quality criteria under the Clean
Water Act are ARARs. For methylene chloride and 1,2 dichloroethane, ambient water
quality criteria for fish and water consumption are exceeded. In addition to the VOCs,
concentrations of aluminum, iron, manganese, thallium and zinc exceed the ambient
criteria. Though some of these compounds were also found upstream of the landfill, the
concentrations of iron and manganese downstream of the landfill significantly exceeded
upstream concentrations, and thallium was found only downstream.
The Commenter has stated that standards have not been exceeded for protection of
aquatic life. EPA must remind the Commenter that standards for protection of aquatic
life have not been established for 1,2-dichloroethane and methylene chloride.
Furthermore, as discussed above, the standards for consumption of fish and water are
ARARs in addition to those established for protection of aquatic life.
3. The PRPs commented that the New Jersey Department of Environmental Protection
(DEP) Manasquan River Macroinvertebrate Studies performed during April 1988 and
16
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October 1989 were flawed and reached an inappropriate conclusion by stating that the
Lone Pine Landfill is having a substantial impact on biotic communities of the Manasquan
River. (References C and F)
EPA Response: The study in question was conducted by DEP and reviewed by the EPA
Biological Technical Assistance Group (BTAG). STAG concluded that the data supported
the DEP determination that an adverse impact to the river adjacent to the landfill has
occurred. BTAG recommended additional sampling in order to pinpoint the cause of the
disturbance to the river.
The Commenters provided the DEP studies to their representative, Dr. Meier, who
concluded that the DEP study was flawed and that the data shows no detrimental impact
to the river. While not accepting Dr. Meier's conclusion, as the regulatory agency
charged with protecting human health and the environment, EPA is obligated to take a
conservative approach in interpretation of the data. Consequently, EPA must prevent the
continued discharge of hazardous substances to the river, especially considering the
presence of a drinking water reservoir downstream of the site. Note that prevention of
continued river discharge is only one of the goals of implementing a remedy for Operable
Unit II.
Since there is a question as to the disturbance to the river and its causes, EPA is
requiring additional surface water and biota monitoring as pan of the remedial action.
4. The PRPs commented that current river conditions are not the correct baseline on
which to judge impacts of off-site contamination since existing conditions in the river
are primarily a result of long-term seepage from the landfill, not ground water discharge.
Furthermore, the Commenters state that the no-action alternative is the only choice that
can be justified on the basis of surface water quality alone. These Commenters also state
that risks associated with river quality will be reduced to negligible levels after
implementation of the Operable Unit I remedy (References C and F).
EPA Response: Current river conditions are due to the discharge of leachate via seeps
from the landfill, as well as from the discharge of contaminated ground water. As
described in the Remedial Investigation (RI) report (S.S. Papadopulos & Associates, Inc.,
1990), the rate at which contaminated ground water discharges from the Water Table
aquifer into the river adjacent to the site is approximately 8,000 cubic feet per day (this
includes about 700 cubic feet per day which leaks into the Water Table aquifer from the
Red Bank aquifer). The RI report also points out that most of the mass discharge into
the river occurs from the area with the most highly contaminated ground water and
calculates that the present mass discharge of VOCs into the river is approximately .11
kilograms per day. As described in the FS report (S.S. Papadopulos & Associates, Inc.,
1990), once the Operable Unit I remedy is in place, and in the absence of other
17
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measures, contaminated ground water will continue to discharge into the Manasquan
River.
EPA expects that once the Operable Unit I remedy is in place, contaminant discharge from
seeps will be eliminated, thus eradicating one of the pathways of contamination to the
river. In addition, as concentrations of contaminants in the ground water decrease, (due
to the fact the landfill containment system will prevent continued leakage from the
landfill into the ground water) EPA expects that contaminant discharge into the river
from the ground water will decrease as well.
In the absence of a remedial action other than the Operable Unit I remedy, it was
calculated via computer modeling, that it would take approximately 22 years for the
Water Table aquifer to reach MCLs and 365 years for the Red Bank aquifer to reach
MCLs. Therefore, contrary to Commenters assertions, contaminated ground water
(ground water with its current levels of contaminants and unaffected by continued landfill
leakage) would continue to discharge to the river. The Operable Unit I remedy will
merely prohibit the introduction of new contaminants to the ground water, and will not
address the current plume.
In reference to the Commenters' statement that only the no action alternative can be
justified on the basis of surface water quality alone, and that risks to the river will be
reduced after implementation of the Operable Unit I remedy, EPA reminds the Commenter
that under CERCLA, EPA must choose a remedy based upon the consideration and
balancing of nine criteria. The no action alternative does not provide the best balance
of tradeoffs among the various alternatives. EPA agrees with the Commenters and
expects that over time, risk to the river would be reduced if no further action were taken.
However, implementation of any alternative, except the no action alternative, would
almost immediately eliminate risk to the river as soon as the interceptor trench is
operable.
5. The PRPs commented that EPA contradicts itself regarding a future exposure scenario
if EPA believes that the first operable unit remedy will decrease concentrations in the
river in the future.
EPA Response: As stated in response to Comment E.4., above, EPA acknowledges that,
after implementation of the Operable Unit I remedy, contaminant concentrations in the
river would be expected to decline over time due to .elimination of ground water seeps.
However, there is a ground water contaminant plume with significant levels of chemicals
in excess of the applicable standards which will not be addressed by the Operable Unit
I remedy.
18
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F. General Comments
1. A concerned citizen inquired about the cost of the implemented remedy and who
would pay for the system operation. (Reference A)
EPA Response: EPA would initially attempt to reach an agreement with the responsible
parties, so that they would bear the cost of the design, construction and operation and
maintenance of the selected remedy. If an agreement could not be reached, than the
government would utilize federal Superfund monies to design and implement the system,
and the costs of operation would be borne by the State of New Jersey. The government
would then seek to recover the costs from the responsible parties.
2. A member of the audience wanted to know if any kind of restrictions should be
put on the land on the north side of the Manasquan River, such as development or well
restrictions. (Reference A)
EPA Response: During the design phase, EPA will recommend the implementation of
institutional controls to prohibit well installation within the contaminant plume or in
areas where extensive pumping could increase the spread of contamination or interfere
with the hydraulic balance required for landfiD containment. These controls will be in
addition to the active response measures outlined in the Operable Unit I and II RODs.
It would then be the responsibility of the State and local governments to enforce such
restrictions. The State of New Jersey is currently developing regulations for well
restriction zones under the authority of the Safe Drinking Water Act.
3. A meeting attendee requested an additional explanation of the upward gradients in
the area around the landfill and near the Manasquan River and how that assures that
contamination from the Red Bank aquifer will not migrate downward into the
Englishtown aquifer. (Reference A)
EPA Response: Monitoring wells have been installed deeper than the Red Bank. The
potentiometric head in these wells is higher than the shallower wells, indicating that
the ground water flow is upward. Therefore, contamination is not expected to migrate
into the deeper zones. Furthermore, underlying the Red Bank formation is the Navesink
formation, a regional aquitard. This formation restricts the movement of ground water
to the underlying Englishtown aquifer.
4. A PRP commented that a reasonable remedy with a minimal cost should be selected
for the Operable Unit n remedy. (Reference D)
19
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EPA Response: EPA evaluates the remedial alternatives against 9 criteria, only one of
which is cost. . Based on a detailed evaluation, EPA selects a remedy based on all nine
criteria, which are: (1) Overall protection of human health and the environment, (2)
Compliance with ARARs, (3) Long-term effectiveness and permanence, (4) Reduction of
toxicity, mobility or volume through treatment, (5) Short-term effectiveness, (6)
Implementability, (7) Cost, (8) State acceptance, and (9) Community acceptance.
5. A meeting attendee inquired how EPA would treat the contaminant plume to MCLs
if there weren't MCLs for every contaminant. (Reference A)
EPA Response: The plume will be extracted and treated prior to reinjection.
The treatment system will be designed such that the effluent meets all ARARs associated
with reinjection, which include Federal and State MCLs. Since the treatment system will
be designed to remove all volatile organics and metals which do have MCLs, it is
expected that all contaminants will be removed to acceptable levels.
6. The Freehold environmental commission commented that community acceptance
should be considered first, since it is the citizens living near the site that are most
effected.
EPA Response: EPA always seeks public involvement in selecting response actions at
Superfund sites. However, according to the law, EPA must follow a certain evaluation
procedure for remedial alternatives. The threshold criteria for evaluation are Overall
Protection of Human Health and the Environment, and Compliance With ARARs. Any
remedy selected must be protective and must comply with ARARs. Then, EPA evaluates
the balancing criteria, which are Long-term Effectiveness and Permanence, Reduction of
Toxicity, Mobility or Volume through Treatment, Short-term Effectiveness,
Implementability, and Cost. These five criteria are used to compare the remedial
alternatives which satisfy the threshold criteria. Finally, Community Acceptance and State
Acceptance are used as the two modifying criteria. The modifying criteria are used to
further evaluate public and state acceptance of the remedy EPA proposes.
The community's concerns are important. EPA is required to select a remedy that meets
all of the threshold requirements, provides the best balance of tradeoffs among the
balancing criteria, and considers the community's concerns as modifying criteria.
20
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References;
A. Transcript from Public Meeting, August 1, 1990
B. Written comments submitted by the Township of Freehold, dated September 13,
1990
C. Written Comments submitted by Mott, Pearce, Williams, & Lee on behalf of
Minnesota Mining and Manufacturing Co., dated September 13, 1990
D. Written Comments submitted by Cerrato, Dawes, Collins, Saker & Brown on behalf
of Guardian, Inc., dated August 16, 1990
E. Written comments Submitted by T.J. Blanchet, received September 13, 1990
F. Written comments submitted by Sidley & Austin on behalf of a group of thirty-
seven potentially responsible panics, dated September 14, 1990
21
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EXHIBIT 2
LONE PINE LANDFILL SITE
OPERABLE UNIT II
RECORD OF DECISION
-------
Alternative Summary
REMEDIAL ALTERNATIVE
1; No Further Action
•»
2. Interceptor Drain
TIME FRAME
365 yrs
315 yrs
3." Interceptor Drain & 255 yrs
Injection Veils
4. Interceptor Drain & 195 yrs
Estraction Wells
5. Interceptor Drain, 165 yrs
Extraction and
Injection Wells
6. Interceptor Drain, 19 yrs
Extraction and
Injection Wells
INITIAL
COST ESTIMATE
$676,951
$6,965,176*
$10,251,099
$8,364,985
$7,320,222*
$11,030,356
$8,743,829
$20,784,979
CDM-FPC
COST ESTIMATE
$720,333
$7,797,271*
$11,451,828
$9,893,047
$8,246,886*
$12,351,443
$10,267,661
$23,237,241
* denotes discharge to river
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