United States
           Environmental Protection
           Agency
               Office of
               Emergency and
               Remedial Response
EPA/ROD/R02-90/108
September 1990
&EPA
Superfund
Record of Decision
           M&T DeLisa Landfill,  NJ
                                           Printed on Recycled Paper

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50272-101
 REPORT DOCUMENTATION
        PAGE
                         1. REPORT NO.
                             EPA/ROD/R02-90/108
                                                                    3. Recipient's Accession No.
4. Title and Subtitle
  .SUPERFUND  RECORD OF DECISION
   &T DeLisa Landfill,  NJ
  First Remedial Action - Final
                                                                      5. Report Date
                                                                                09/20/90
 7. Author(s)
                                                                      8. Performing Organization Rept No.
 9. Performing Organization Name and Address
                                                                    10. Project/Task/Work Unit No.
                                                                      11. Conlract(C) or Grant(G) No.

                                                                      (C)

                                                                      (G)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental Protection Agency
   401 M Street,  S.W.
   Washington, D.C.   20460
                                                                    13. Type of Report & Period Covered

                                                                              800/000
                                                                      14.
 15. Supplementary Notes
 16. Abstract (Limit: 200 words)

  The 132-acre M&T DeLisa Landfill site  is  northwest  of the city of Asbury Park  in  Ocean
  Township,  New Jersey.   The 39-acre M&T  DeLisa landfill was  operated with a State  permit
  from 1914  until 1974.   After  the landfill was closed,  a private company constructed a
  shopping mall on 30  acres of  the landfill.   The developer took control  measures to
     tect against the  generation  of landfill  gases  and leachate.   Although landfill gas
   '  generated at the  site and  slightly  elevated levels of VOC  accumulation were detected
     the northern edge of the mall,  sampling  and analysis indicate that the landfill is
  not the source of detectable  levels of  VOCs in the  mall.  The developer installed storm
  drainage from the parking lot to protect  Deal Lake  Brook, which is the  nearest surface
  water and  is immediately south  of the  mall.  Onsite surface water and ground water are
  not used as  sources  of potable  water.   Site investigations  and historical research on
  site activities revealed no evidence to indicate  that the landfill was  used for
  hazardous  waste disposal.  There are no contaminants of concern affecting the  site,
  therefore,  this is a no action  Record  of  Decision (ROD).
  (See Attached Page)
 17. Document Analysis a. Descriptors
    Record of Decision - M&T  DeLisa Landfill, NJ
    First  Remedial  Action - Final
    Contaminated Medium:  None
    Key  Contaminant:   None

   b. Mentifiera/Open-Ended Terms
   C. COSAT1 Reid/Group
 II). Availability Statement
                                                     19. Security Class (This Report)
                                                             None
                                                       20. Security Class (This Page)
                                                      	None	
21. No. of Pages
        48
                                                                                 22. Price
(Se« ANSI-239.18)
                                       See Instructions on Reverse
                                                                                OPTIONAL FORM 272 (4-77)
                                                                                (Formerly NTIS-35)
                                                                                Department of Commerce

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 EPA/ROD/R02-90/108
  &T DeLisa  Landfill,  NJ
    st  Remedial Action - Final

_
 Abstract  (Continued)

 The selected remedial action for this site includes a  no further action scenario.
 Although  no significant contamination is present  at the site,  EPA recommends that
 environmental controls be implemented,  including  continued surface and ground water
 monitoring,  restricting possible future use of onsite  ground water,  continued sampling
 and monitoring of the leachate collection system,  replacing a gas vent,  sealing cracks
 in building floors and walls in contact with subsurface soil,  improving detention  ponds
 leading into Deal Lake Brook,  venting of the north corridor area of the mall,  and
 periodic  indoor and outdoor air monitoring.  EPA  has determined that such actions  will
 not be implemented under the authority of the Superfund program,  and responsibility for
 the site  has been transferred to the State.  There are no costs associated with this no
 action remedy.

 PERFORMANCE STANDARDS OR GOALS:  Not applicable.

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                          DECLARATION STATEMENT

                           M & T DELISA LANDFILL

                            RECORD OF DECISION
SITE NAME AND LOCATION

M & T DeLisa Landfill
Ocean Township, Monmouth County, New Jersey
STATEMENT OF BASIS AND PURPOSE

This document presents the decision selected for addressing the M & T DeLisa Landfall
Site in Ocean Township, New Jersey (the Site), which was determined in accordance
with the Comprehensive Environmental Response, Compensation and Liability Act of
1980, as amended by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), and to the extent practicable, the National Oil and Hazardous Substances,
Pollution Contingency Plan, 40  CFR Part 300.  This decision document summarizes the
factual and legal basis  for this determination and is based on the administrative record
for this Site which is comprised of the documents listed in the attached index.

The Stale of New Jersey concurs with this decision.
SUMMARY OF RATIONALE FOR NOT TAKING ACTION

The U. S.  Environmental Protection Agency (EPA) has determined that the M & T
DeLisa Landfill Site should be addressed under the authorities designated to close and
monitor solid waste landfills.  This determination is based upon a review of historical
documentation which did not reveal any past disposal of hazardous waste at the Site,
the results of the remedial investigation (RI) which demonstrate that the landfill is not
a source of significant concentrations of any hazardous substances, and a conservative
assessment of risk attributable to the release of hazardous substances, from the  landfill
which indicates that the current risk posed by the Site is within an acceptable range.

Upon completion of the RI, it became evident that the conditions  at the Site do not
warrant remedial action under CERCLA. Accordingly, an evaluation of remedial
alternatives, as described by CERCLA,  was not appropriate for the Site.  Therefore, an
evaluation of remedial alternatives has not been conducted.

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Although remedial action under CERCLA is not warranted, EPA recommends that
environmental controls be implemented and maintained at the Site to address
potential problems associated with solid waste disposal.  EPA has determined that
such actions should not be handled under the auspices of the Superfund program.
Since the New Jersey  Department of Environmental Protection (NJDEP) regulates solid
waste landfill activities in the State of New Jersey, EPA is transferring responsibility
for the Site to the NJDEP's Division of Solid  Waste Management for future action.

DECLARATION STATEMENT

EPA has determined that it is not appropriate to use CERCLA statutory authority to
remediate this Site. Subtitle D of the  Resource Conservation and Recovery Act of
1976 as amended by the Solid Waste Disposal Act of 1980 (RCRA) is the Federal
statute pertaining to solid waste landfills.  RCRA and its regulations  address among
other things, the post-closure monitoring requirements for landfills.   NJDEP is
authorized to regulate solid waste landfill closures and post-closure ground water and.
surface water monitoring requirements for landfills in New Jersey. By issuing this
Record of Decision, EPA is formally transferring responsibility for the Site to NJDEP -
for future action.
Constantine Sidamon-Eristoff, Regional/Administrator
                                          ^
     I

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                          ROD FACT SHEET
SITE
M&T De Lisa Landfill Site
Monmouth County, New Jersey
USEPA Region II
HRS Score: 32.27
NPL Rank: 865

ROD
Date Signed: September 20, 1990
Remedy:   NO ACTION

The Site will be transferred to the solid waste program of the New
Jersey Department of Environmental Protection (NJDEP).  NJDEP may
develop  and implement  actions  as appropriate  for post-closure
landfill activities.   EPA recommends that environmental controls
be implemented  by NJDEP  to address potential solid waste issues..


Capital Cost: NA
O&M/year: NA
•Present Worth:  NA

Lead
Primary Contact: Lance R. Richman, P.G., (212) 264-6695 (USEPA)

Potentially Responsible Party  (PRP):
     Equitable  Real Estate Investment Management, Inc.

PRP Contact: Mr. Michael Rodberg,  Esq.,  (201) 992-8700
WASTES
Type: municipal solid waste
Medium: groundwater and air
Origin: private landfill for municipal waste
Estimated Quantities: Landfill covers approximately 39 acres

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    AU^ 2 I i9S3

Record of Decision for the M&T DeLisa Landfill site,
   Monmouth County, New Jersey

Richard Caspe, Director
Emergency & Remedial Response Division

Constantine Sidaroon-Eristoff
Regional Administrator
Attached  is the  Record  of  Decision  (ROD)   for  the  M&T DeLisa
Landfill Site  located  at  Ocean  Township,  in Monmouth County, New
Jersey.

Lance R. Richman,  P.G. is the Regional Project  Manager for this
Site.

This is an  EPA lead site.  The  Equitable  Real  Estate Investment
Management Inc., the potentially responsible party for the Site,
contracted Fred C.  Hart Associates, Inc.,  to conduct the remedial
investigations, under  Administrative Orders  on  Consent issued by
EPA in November of 1983 and March of 1988.

The New Jersey Department of Environmental Protection  (NJDEP) has
reviewed the ROD and supporting  documents  and concurs on this no
action determination.   Both the ROD and  Proposed Plan were reviewed
in-house by the Hazardous Waste  Facilities Branch (RCRA), Office
of  Ground  Water Management,  Environmental  Impacts  Branch,  Air
Compliance Branch,  Office of Regional Counsel, NJ Compliance Branch
(Superfund), Program Support Branch (Superfund),  and ATSDR.

The 30 day  public  comment period for the  Proposed  Plan ended on
July 27,  1990.  EPA received two written letters in response to the
plan.  The public meeting was held on July 12, 1990.  The meeting
was well attended.   Comments received during the public comment
period are addressed in the attached Responsiveness Summary.
EPA's decision is as follows.

     This Site should be handled under the authorities designated
     to close and remediate municipal  landfills.  An evaluation of
     remedial action alternatives, as described by CERCLA was not
     appropriate for this  site.   NJDEP  is authorized to regulate
     municipal landfill  closures and post-closure monitoring in New
     Jersey.  For this  reason, EPA  is referring this Site to the
     NJDEP  for  further action.    Current State  statutes  also
     regulate post-landfill closure  ground water and surface water
     monitoring requirements  for municipal landfills.

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This decision  is  identical to the  one proposed  in  the Proposed
Plan, which  EPA submitted  to the  public in  June of  1990  (see
Attachment).

NJDEP's Division of Solid Waste Management has indicated that it
will accept authority for the Site  as  soon as it is deleted from
the National Priorities  List  (NPL) .  Upon the  execution of this
ROD, EPA will commence rulemaking to delete the Site from the NPL.
Attachments

bcc: R. Caspe, ERRD
     R. Basso, NJCB
     N. DiForte, N-NJCS
     D. Finn, ORC

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                                               STATE OF NEW JErtSEV
                                        DEPARTMENT OF ENVIRONMENTAL PROTECTION
                                              JUDITH A. YASKJN. COMMISSIONS
                                                       cv *o:
                                                 TRKNTOV V J  f)R62V."02
                                                   (•4k
                                                 SEP  171990
Mr. Ccnstantine Sidamon-Eristoff
Regional Administrator
USEPA - Region II
26 Federal Pltza
New York, KY 10278

Dear Regional Administrator Sidamon-Iristoff:

Re:  Record of Decision
     K & I Delisa Landfill
     Ocean Township, Monmouth County, New Jtraey

New Jersey  Department of  Environmental  Protection  (NJDEP)  haa  reviewed the
Record  of Decision  (ROD) and  other  documents  relevant  to Che  M&T Dellsa
Superfund Site including  the  Final  Remedial Investigation Report dated March
3C, 1990,  the Draft/Final Endangerment  Ajseeement  dtted  February 16, 1990,
and the Draft Feaaibility Study Report dated April 26, 1990.

In  the  ROD,  EPA declares  that  the aalaction of  the "no action" alternative
constitute! the final action  at  the aite under  Federal and  State auapices of
the Superfund  Program.    EFA will  formally tranafer  responeiblllty  for the
cite  to NJDEP  for  future action under  New Jereey'a authority  to  regulate
solid waate landfill cloaure and poat-cloaure activities.

The ROD states that  although there  is  no significant  contamination due to
the  release of  hazardoua aubatancee vhieh  are  attributable  to  the Site,
there •  are  environmental  controla  which  nay  be  implemented  to   address
potential solid waste issues, including:

     Continued monitoring of surface and  groundwater;

     Modification of  the property  deed  to restrict the  possible future use
     of on-aite ground water;

     Continued  aampling,  operation and  maintenance  of the  existing  leachate
     collection system;

     Replacement  of vent  No.  25  and continued  use  and  maintenance of all
     on-slte gae vents;
                                   et

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Mr. Constantine Sidamon-Eristoff
Record of Decision - M 6 T Deliea Landfill
Ocean Township, Monmouth County, New Jersey
Page 2
     Sealing of  cracks in  building  floors  and  walls of  the  Seaview Square
     Mall (Mall)  which are in contact with subsurface soil;

     Improvement   and  maintenance  of  the  detention  ponds leading  into  Deal
     Lake Brook;

     Maintain  current  poeitive  pressure  operation of   the  Mall  heating,
     ventilation and air conditioning system;

     Vtnting of the north corridor area of the Mall; and

     Periodic indoor and outdoor air monitoring.

NJDEP hereby concurs with  EPA's selection of the "no action" alternative and
will accept  responsibility  for  the  site  pursuant  to the   New Jersey  Solid
Waste Management  Act and  the regulations promulgated pursuant there to, once
the Site has been delisted from the National Priorities List  (NFL).

If you have  any  questions  regarding  this natter please contact, Dennis  Karc,
Assistant Director, Responsible Party Cleanup .Element at  (609)  633-0719.

                                         .Sincerely,
Enclosure
                                                          X •:. •*A'^
                                        4udith A. Yatkin '   /

                                                           /'

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                                Decision Summary

                            M & T DeLisa Landfill Site

SITE DESCRIPTION

The M & T DeLisa Landfill site  (Site) is located in the southeastern corner of
Monmouth County, northwest of the City of Asbury Park in Ocean Township, New
Jersey (see Figure 1).  The 132-acre Site is bounded on the west by Route 18, on the
south by Route 66, on the east  by route 35, and on the north by  an industrial park
located off Sunset Avenue (see Figure 2).  The parcel contains three major building
complexes, the Seaview Square  Mall complex (Mall), the Seaview  Movie Theater
complex, and the Acme Supermarket, each of which is surrounded by a paved parking
area.  The only wooded portions of the parcel are located in the southeast corner of
the Site, south of the Route 35  mall access road.

Immediately south of the Mall and located on the Site is the most southern arm of
Deal Lake Brook which flows from west to east to Deal Lake. Storm drainage from
the parking lots and  adjacent roadways discharge into  detention ponds that feed into
Deal Lake Brook.

The three  uppermost geologic formations underlying the Site are (in descending
order): the Kirkwood Formation - consisting  of alternating layers of sand, silt and clay
that are discontinuous  both laterally and vertically, the Manasquan Formation (which
is locally known as the Shark River Marl) - consisting  of a low permeability, clayey
sand,  and  the Vincentown Formation • consisting of a fine to medium grained sand.
Based on the low yield of the aquifer from on-Site monitoring wells, the Kirkwood is
not considered to represent a major viable source of potable water in the vicinity of
the Sire.  Based on information  obtained from test borings, the Shark River Marl is at
least thirty-five  (35)  feet thick at the Site and is considered a confining layer that
separates the overlying Kirkwood Formation  from the underlying Vincentown
Formation. The Vincentown Formation is expected to  represent  a  viable source of
potable water in the vicinity of the  Site.  Nine (9) water supply wells are believed to
be screened in this formation within approximately one mile of the Site.
SITE HISTORY AND ENFORCEMENT ACTIWnES

The Site consists of 132 acres of which the former M & T DeLisa landfill occupied
approximately 39 acres. The landfill was in operation from 1941 until 1974 under a
New Jersey Department of Environmental Protection (NJDEP) permit.  Records of
landfill operations are limited.  There is no documented evidence which demonstrates
that the landfill was used for the disposal of hazardous wastes.  Available information

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indicates that the landfill was used for the disposal of refuse.

The landfill was closed in 1974 in accordance with NJDEP requirements of the time.
After closure an investigation of the landfill area was undertaken by Woodward-
Gardner and Associates, Inc., for the Goodman Company, who subsequently
constructed the Mall on 30 acres of the 39-acre former landfill for Equitable  Real
Estate Investment Management, Inc., the present owner of the Mall property.- The
report recommended control measures to protect against the possible impact  of gas
and/or leachate generation from the landfill and described other measures that would
be needed to provide a stable soil for the construction of the  proposed buildings.
These recommendations were incorporated into the design and construction of the
MaD which was completed in 1977 (see Site Characterization).

Pursuant to Administrative Orders on Consent of November 1983 and March 1988,
between EPA and the  Equitable Life Assurance Society of the  United States, Fred C.
Han Associates, Inc. was retained to conduct a  remedial investigation on the Site in
accordance with CERCLA and the NCP.  The objectives of the remedial  investigation
were to characterize the nature and extent of any contamination  associated with the
Site, to identify off-site contamination and its impact on public health and  the
environment, and to determine  whether there is a need for remedial measures to
protect human health  and the environment.  The remedial investigation was  conducted
under two distinct investigatory programs.  The initial investigation was completed in
June of 1984,  while the supplemental remedial investigation was completed in
January of 1989.  Additional indoor and outdoor air monitoring results were
submitted  in December of 1989, and the final remedial investigation report was
submitted  in March of 1990.
HIGHLIGHTS OF COMMUNITY PARTICIPATION

In accordance with the public participation requirements set forth in Sections 113 and
117 of CERCLA, the following activities were conducted.  The Remedial Investigation
Reports, the Endangerment Assessment, the Proposed Plan and other documents which
comprise the administrative record for this site were released to the public for
comment on June 18,  1990.  These documents were made available to the public at
the EPA Docket Room in Region II and  at the Neptune Township Public  Library in
Neptune Township, New Jersey.  On June 28, 1990, EPA published a notice in the
Asburv Park Press which contained information  relevant to the public comment period
for the Site, including  duration of the public comment period, date of the public
meeting, and availability of the administrative record.  The pubb'c comment period
began on June 28, 1990 and ended on July 28, 1990.  In addition, a public meeting
was held on July 12, 1990, where representatives from EPA and the NJDEP answered
questions regarding the Site and the  decision  under consideration.  Responses to  the

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significant comments received during the public comment period are included in the
Responsiveness Summary, which is pan of this Record of Decision.
SCOPE OF RESPONSE ACTION

This declaration of "no action" constitutes the final action at the Site under Federal
and State Superfund Programs. This "no action" decision is based upon a review of
historical documentation which did not reveal any past disposal of hazardous waste at
the Site,  the results of the RI which demonstrate that the landfill is  not a source of
significant concentrations of any hazardous substances and a conservative assessment
of risk attributable to the release of hazardous substances, from the  Site which
indicates that the current risk posed by the Site is within an acceptable range.  After
the Site is transferred to the sob'd waste program of NJDEP, NJDEP may develop and
implement actions as appropriate for post-closure landfill activities.

Although there  is no significant contamination due to the release of hazardous
substances which are attributable to the Site, EPA recommends  that  environmental
controls be implemented to address potential solid waste issues.  They include:

      o     continued monitoring of surface and ground water;

      o     modification of the property deed to restrict the possible future use of
            on-site ground water;

      o     continued sampling, operation and maintenance of the  existing leachate
            collection system;

      o     replacement of vent number 25 and continued use and maintenance of
            all on-site gas vents;

      o     sealing of cracks in building floors and walls in contact with subsurface
            soil;

      o     improvement and maintenance  of the  detention ponds leading into Deal
            Lake Brook;

      o     maintain current positive pressure operation of Mall heating, ventilation
            and air conditioning system;

      o     venting of the north corridor area of the Mall; and

      o     periodic indoor and outdoor air monitoring.

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SUMMARY OF SITE CHARACTERIZATION

With the building of the Mall, a number of construction elements were implemented
to provide environmental controls, i.e., refuse movement, gas control, and leachate
control.  These are  summarized below:

Refuse Movement.  The refuse material was found to.be unsuitable for building
support,  therefore, the refuse material situated under the planned Mall was removed.
The refuse was excavated down to the underlying soils. Then it was placed in areas
already containing refuse.  The area excavated was replaced with clean fill which was
capable of supporting  the buildings.  The result was that the buildings are constructed
within a  low permeability bowl-shaped soil configuration composed of the naturally
occurring Shark River Marl material beneath the Mall and the 3 to 10 foot thick clay
barrier installed during construction to prevent landfill gas migration to the buildings.

Landfill Gas Control.  The mall construction implemented three measures to control
the potential movement of landfill gas into the Mall.  The first was the installation  of
the clay barrier discussed above.  The second was the construction of passive control
vents, consisting of perforated horizontal  collection pipes located in the refuse
attached  to vertical pipes open  to the atmosphere, which provide a preferential
pathway  for landfill gas migration and help prevent horizontal migration into the
buildings. The last measure was to limit the permeability of the Mall's utility
corridors (which contain sanitary sewers, electrical wiring, etc.) by placing all utility
lines within  one narrow corridor, replacing refuse in this corridor with clean soil, and
compacting the soil to reduce permeability.  Utilities which could not be placed within
this corridor were enclosed in concrete.

Leachaie  Control.  Leachate  is generated when rainfall infiltrates into the  ground and
percolates through refuse material, or when ground water moves horizontally through
the refuse.   Four measures were implemented to minimize leachate generation:
modifications to the storm water collection system, construction  of a leachate
collection system, installation of a clay barrier, and covering the surface of the landfill
with pavement.  The manner in which these measures were implemented  is described
below:

o     The storm water collection system was designed to keep storm water separate
      from  leachate by, 1) using the parking lot as a low permeability cap over the
      refuse to reduce infiltration of precipitation and collect storm water runoff, 2)
      constructing  catch basins and storm drain pipes as close to the surface as
      possible, and 3) constructing storm water pipes designed to be impermeable to
      leachate infiltration.

o     A  leachate  collection system consisting of a perforated pipe  within a gravel

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       trench situated to intercept groundwater/leachate moving toward Deal Lake
       Brook was also installed; the liquid is then collected in a tank arid discharged
       to a municipal waste water treatment plant.

       The clay barrier,  which was installed between the refuse and clean soil fill, acts
       as a barrier to groundwater/leachate flow, preventing  it from migrating to or
       under the Mall buildings.

       The surrounding  parking lot acts as  a low permeability cap thereby reducing
       the volume  of rainwater which is available for leachate generation.
Remedial Investigations

As discussed earlier, Fred C. Hart and Associates under contract by the owners of the
Mall (the Equitable Life Assurance Society of the United States) conducted two
environmental investigations, one in 1984 and more recently in 1988, both under EPA
oversight.   The remedial investigations CRTs) characterized the nature and extent of
ground water, surface water, and air contamination attributable to the release of
hazardous substances from  the site.  The activities conducted under the investigations
and a discussion of the  results are presented below.

A hydrogeologic investigation was conducted to determine on-site geologic and
hydrologic  conditions and to evaluate impacts on local groundwater quality.  A total
of 7 monitoring wells and one boring were installed.  All were logged by a field
geologist to verify the geology of the area.  The monitoring  wells were then sampled
along with 4  private drinking water wells in the area to obtain water quality data.
The results of the hydrogeologic investigation are as follows:

      1. The geology in the area consists of the Kirkwood Formation, Shark  River
      Marl and Vincent own Formation (Figure  3).  The Kirkwood Formation which is
      under pan of the Site has a maximum thickness of 74 feet at monitoring weD
      MW-6D and gradually pinches out to the south where it is estimated to be only
      4.5 feet thick in monitoring well MW-1.  Hydraulic conductivities (a measure of
      the ability of fluid to move through a porous media under  force) in the
      Kirkwood Formation are somewhat variable  and range from 1.6 x 102  to 7.6 x
      105  cm/sec.  The heterogeneity of the Kirkwood Formation at the Site, caused
      by the deposition of silts and clays of low hydraulic conductivity within the
      formation, reduces the hydraulic conductivity and yield which causes the aquifer
      to be less suitable for use as a potable water supply at the Site.  Below the
      Kirkwood Formation and the landfill refuse is the Shark River Marl, a
      continuous clayey, silry formation.  The extensiveness of the Shark River Marl
      (an average of 35 feet underlying  the site) combined  with  its low hydraulic

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      conductivity drastically reduces the potential for contaminant transport between
      the upper Kirkwood Formation and the deeper Vincentown Formation.  The
      Vincentown Formation, which exists under confined conditions, is used in the
      area as a potable water supply.

      2. Groundwater flow in the Kirkwood aquifer is to the southeast towards Deal
      Lake Brook.  It appears as though the brook is an expression of the
      groundwater table and that the shallow groundwater flow is intercepted by the
      brook.

      3. In  1984, lead and arsenic were detected in unfiltered monitoring wells in
      samples in concentrations above regulatory levels (i.e., 230  and 68 part  per
      billion respectively).  However, subsequent sampling efforts  (both filtered and
      unfiltered)  did not detect significant concentrations of metals.  The highest
      concentration of lead and arsenic detected in post-1984 sampling were 42.8,
      and 13.8 part per billion (ppb), respectively, which are below federal Safe
      Drinking Water Act (SDWA) maximum contaminant levels (MCLs) of 50 ppb.
      Although the metal concentration data from  the initial round of sampling was
      not confirmed by subsequent sampling, EPA  used this data in the  risk
      assessment to provide a conservative evaluation of risk.

A surface water and sediment sampling effort was conducted to  determine the
potential impact of hazardous contaminants from the Site on surface water bodies in
the vicinity.   In 1984, samples were collected at on-site drainage areas, points where
surface water runoff from the Site entered surface water bodies, and sediment
deposition areas.  At each surface water sampling location, a sediment sample was
also collected.  In addition to surface water/sediment sampling,  storm drains and the
leachate collection tank  were sampled.  In 1988, the sampling locations were modified
based upon a better understanding of drainage patterns and flow directions.  The
1988  sampling effort included four locations along  Deal Lake Brook.

Surface  water and sediment samples taken from the detention ponds and Deal Lake
Brook in 1984 showed low to undetectable levels of volatile organic compounds
(VOCs).  In  a number of samples, levels of iron, copper and other non-hazardous
metal were found in excess of secondary Safe Drinking Water Act  (SDWA) standards.
While these  metals in high enough doses can effect health, the secondary SDWA
standards are based upon aesthetic water  quality impacts such as the  hardness  and
taste of the water.  The reddish coloration of the stream is most likely attributable to
the presence of these metals and in particular the iron content.

Although collection of leachate seep samples were planned, seep samples were  not
taken because seeps were not observed during sampling events.  Instead, soil samples
were taken in areas where staining indicated a possible previous seep location.  The

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only VOC found in the soil samples was methylene chloride  (a common laboratory
contaminant).  In addition, metal concentrations were within the range'of those
typically found  in natural soils.

Aqueous samples were collected from Site storm drains. These drains receive storm
water runoff from the mall parking lots.  Lead was detected in one sample at 600
ppb.  Methylene chloride was the only VOC detected.

Both the liquid  and  sludge present in the leachate tank were sampled.  With respect
to the liquid  samples, no VOCs were detected.  Iron and manganese,  which are not
hazardous substance under CERCLA, were at concentrations  of up to  56 ppm and 0.19
ppm, respectively.  The secondary SDWA MCL for iron is 0.3 ppm while manganese is
0.05 ppm.  Low levels of a number of metals were also detected in sludge from the
leachate collection tank including copper, nickel, zinc, lead and some chromium.
Methylene chloride and phthalates were also detected in sludge samples in 1984  but
were not found in subsequent samples collected in 1988.

Air quality investigations were conducted during the  RI in November/December of
1983, June of 1984, August of 1988, January of 1989, and  October of 1989.  The
October 1989 effort, was performed by EPA. Samples were  collected at all outdoor
vents and indoors in all accessible  areas of the lower levels of the Mall buildings.
Outdoor vent sampling was done at the vent openings and at a distance of 50 meters
from the vents.   The sampling found some  VOCs, methane, and carbon dioxide being ;
liberated by the vents.  Although indoor sampling found slightly elevated levels of
VOCs along the northern edge of the  Mall,  no concentrations of VOCs above what
would normally be expected in an  indoor space were found.

Upon completion of the investigations, the  following  conclusions were reached.

      o      Groundwater quality in the local shallow Kirkwood aquifer immediately
             underlying the Site and in direct physical contact with landfill materials,
             does not appear to have been significantly impacted by hazardous
             substances.  Due to the absence of any  significant water quality
             degradation in the  shallow Kirkwood aquifer, together with the laterally
             extensive presence  of the Shark River Marl which locally serves as a
             confining layer below the Kirkwood aquifer, groundwater quality in  the
             deeper Vincentown aquifer is not anticipated to be at risk as a result of
             past disposal  practices at the Site.

      o      No VOCs or pesticide/PCB compounds were detected above laboratory
             method detection limits during either sampling  round in groundwater
             samples from private  potable wells.  Only one semi-volatile compound,
             di-n-octylphthalate, was  detected during the 1988 round of sampling,

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            and it was below levels of concern.  Several metals, including copper,
            lead, nickel, and zinc, were also present below SDWA standards in
            potable water samples collected during the. 1984 sampling effort.

      o     Surface water and sediment samples collected  did not find any significant
            environmental quality degradation due to  the presence of hazardous
            substances at the down-gradient surface water locations.

      o     Although landfill gas is being generated at the Site, and there is evidence
            of slightly elevated levels  of VOC accumulation along the unventilated
            northern edge of the mall, the sampling and analysis  of specific VOC
            target compounds, such as benzene, toluene, and xylene, did not indicate
            a definitive pattern of gas infiltration.  Therefore, it was determined that
            the landfill is not the source of detectable levels of VOCs in the Mall.  In
            addition, concentrations of VOCs  in the Mall are not outside the range of
            VOC concentrations typically found in other public and  private indoor
            spaces.

SUMMARY OF SITE RISKS

An endangerment assessment was conducted by EPA to determine the baseline risk
(an evaluation of the potential threat to human health  and the environment in the
absence of any remedial action) due  to the  release of hazardous  substances that may
be attributable to the Site.  The assessment began with selecting indicator chemicals
which would be  representative of Site risks.  Sixteen indicator chemicals were chosen;
they were: arsenic, barium, chromium,  copper, iron, lead, manganese, mercury, nickel,
zinc, benzene,  carbon tetrachloride, chloroform, methylene chloride, toluene, 1,1,1-
trichloroethane, trichloroethene, and  xylene.  EPA has developed two acceptable intake
levels for non-carcinogens, 1) Acceptable Intake for  Sub-chronic exposure (AlS)-the
highest human intake of a chemical that  does not cause adverse  effects when exposure
is short term, and 2) Acceptable Intake for Chronic exposure (AlC)-the highest human
intake of a chemical that does not cause adverse effects when exposure is for a life
time. For carcinogens, EPA has also developed Carcinogenic Potency Factors-the
excess lifetime risk due to a continuous lifetime exposure to one unit of carcinogen
concentration (Table 1).  Chemicals were selected for each  media to  ensure that
plausible exposure routes were evaluated. Then environmental fate and transport
mechanisms  were evaluated for  each of the indicator chemicals.  The following seven
exposure routes were assessed (Table 2): 1) inhalation of indoor (Mall)  air, 2)
inhalation of air directly from gas vents both at the exhaust and 3) at 50 meters from
the exhaust, 4) ingestion of surface water sediments,  5) ingestion (consumption) of
fish, 6) ingestion of surface water, 7) ingestion of ground water from monitoring
wells.  Since surface and groundwater are currently not a source of potable water on
the Site and the gas vent openings are  situated on poles approximately 15 feet off the

                                       8

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ground, these exposure pathways were assessed only under future use scenarios.
Consistent with EPA guidance, consumption rates for each indicator chemical were
completed for the seven exposure routes using an average body mass of 70 kilograms
(154 Ibs) for an adult over a 70 year life-span.  Sub-chronic exposures were  calculated
for consumption for 30 days of the indicator chemical at its maximum detected
concentration (Table 3). Chronic exposure calculations were based on consumption of
the geometric mean chemical concentration (average detected concentration level).
Both future  and current use scenarios were evaluated'.

The results indicate that the only media posing a potential risk above EPA guidelines
to human health is  groundwater under a future use scenario (Table 2).  Current use  ,
scenarios for groundwater and all other media demonstrate risk values within an,
acceptable range. Both hazard indices and cancer risks were summed to develop the
cumulative hazard index and the cumulative cancer risk, respectively, to account for
additive exposures.  The resulting cumulative hazard indices are 4.23 for sub-chronic
exposure, and 0.75  for chronic exposure; cumulative lifetime cancer risk was
calculated to be 5.87 x 10"4 for an individuals lifetime excess carcinogenic risk.  Under
current use scenarios, the lifetime cancer risk calculates to 1.77 x 10s, with
cumulative hazard indices of 1.11 for sub-chronic exposure  and 1.88 x 102 for chronic
exposure. Current Federal guidelines for acceptable exposures are a maximum health
hazard index equal  to 1.0 for chronic and sub-chronic, non-carcinogenic risk and an
individual lifetime excess carcinogenic risk in the range of 1.0 x 10*4 to 1.0 x 10*.

The endangerment assessment  identified arsenic as the only chemical in the
groundwater that may cause its risk levels to exceed Federal guidelines in the future
groundwater use scenarios (i.e., if potable water wells were  drilled on Site in the
Kirkwood aquifer there may be an unacceptable risk to users  of that water).  This
finding is based on  the conservative assumption that the arsenic concentrations found
in the unfiltered groundwater samples are representative of groundwater quality in .the
Kirkwood aquifer.  EPA believes that the levels of arsenic in samples from ground
water monitoring wells are not representative of actual concentrations in the  ground
water because arsenic was detected only in unfiltered samples' (arsenic tends to adsorb
onto particles which immobilize the element). EPA believes that the actual risk from
arsenic is acceptable for the following reasons: 1) arsenic was not detected in any  off-
site potable  wells, 2) concentration levels in all filtered monitoring well samples are
below Safe Drinking Water Act standards and are comparable to background  levels,
and 3) by including the arsenic concentration levels from unfiltered samples in the
future use scenarios in the risk assessment, a conservative estimation of future
potential risk was obtained (5.66 X 10"4) which resulted in a risk  value which only
marginally exceeded EPA's target risk range (ie., 10"4 to 107).

Furthermore, EPA believes that the  use of the Kirkwood aquifer at the Site is a very
remote possibility due to the limited aquifer thickness and low hydraulic conductivity.

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Therefore, EPA believes that the portion of the Kirkwood aquifer underlying the Site is
not an adequate source of water for a private  well.  However, as a precautionary
measure, EPA recommends  modifying the property deed to restrict the possible  use of
on-site groundwater.

In EPA's opinion, the threat to human health and the  environment from hazardous
substances attributable to this Site is minimal. This conclusion is based on the Site
history and operations, the overall environmental setting and analytical data.

STATUTORY AUTHORITY FINDINGS

In December of 1982, the Site was proposed for the Superfund National Priorities List
(NPL).  The Site was officially added to the NPL in September of 1983.

Upon the completion of the remedial investigation, it became evident that this Site
should be  handled under the  authorities designated for closure and post-closure
activities at solid waste landfills.  This conclusion is based in part upon a  review of
historical documentation which  did not reveal  any past disposal of hazardous waste at
the Site, the results of the  RI which demonstrate that the landfill is not a source of
significant concentrations of any hazardous substances.  Contaminants found at the
Site are indicative  of solid waste landfills.  Unlike typical CERCLA sites, the landfill is
not releasing significant concentrations of CERCLA hazardous substances.  Therefore,
an evaluation  of remedial alternative, as described in CERCLA, was not appropriate  for
this site.

EPA has concluded that conditions at the Site  do not warrant remedial action under
CERCLA.  It has been determined that the current Site conditions do not exceed EPA's
acceptable risk range.  In order to ensure that in the future  the conditions at the Site
will continue to be protective of human health and the environment, EPA recommends
that environmental controls be implement and maintain at the Site to address
potential problems associated with solid waste disposal. EPA has determined that
such actions should not be handled under the  Superfund program.  Subtitle  D of the
Resource Conservation and Recovery Act of 1976 as amended by the Solid Waste
Disposal Act of 1980 (RCRA) is the Federal statute concerning solid waste landfills,
and post-landfill closure monitoring requirements. NJDEP is authorized to regulate
sob'd waste landfill closures and post-landfill closure ground  water and surface water
monitoring requirements in New Jersey.  Current State statutes regulate post-landfill
closure ground water and surface water monitoring requirements.  For this reason,
EPA is transferring this  Site to the NJDEP for  future action.

Although current site conditions do not exceed EPA's acceptable risk range, this "no
action" decision does not constitute a finding that in the future the conditions  at the
Site will continue to be protective of human health and the  environment without

                                       10

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proper maintenance and adherence to post-closure requirements for solid waste
landfills.
DOCUMENTATION OF SIGNIFICANT CHANGES

There have been no significant changes in the decision as described in the Proposed
Plan.                                         '
                                     11

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                                   TABLE 2

                            Protectiveness Summary
                                 Health Only
Medium
Current Use    Future Use
Soil
Air
      stream sediment ingestion
      gas vent air

      gas vent air at 50 meters

      indoor air
Water
2.79 X 107    2.79 X 107
    NA1       2.23 X
 9.05 X  10"   9.05 X 10"
 1.74 X 10s    1.74 X 10s
      ground water from monitoring wells      NA'       5.66 X 10'"

      surface water                          NA1       9.52 X 10'
Biota
      fish ingestion
1.59 X 10"    1.59 X lO"
All MEDIA
 1.77 X 10s    5.87 X
     Nc current exposure pathway.

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 Seavlev
Square Mall
           FIGURE   1

         LOCATION MAP

   SEAVIEW SQUARE  MALL
     ASBURY PARK. NEW JERSEY

-------
PROPCK1Y UNE
                                                                              SITE  SKETCH  MAP
                                                                         SEAV1EW SQUARE  MALI.
                                                                      ASBUHY  PARK. NEW  JERSEY

-------
SOt/THEAST
                                                                                                                    MONTH WEST
                                                                                                                         A'
9  Z
                                                                                                                    FMMJNE  »

                                                                                                             GENERAUZEO GEOLOGlCAt.
                                                                                                              CROSS-SECTION A - A'

                                                                                                               •EAV«W •OUANC MAlt
                                                                                                                           . M.J.

-------
                               -  —TABLE    1  -

                             RELEVANT  INDICATORS  OF TOXICITT
                                                                        Carcinogenic
       CHE".::A:                  *1S                   Ale              Potency Factor
                                     («8/m3)   («g/kg/d4y)  ("B/irJ)       l/(*g/kg/day)
Jnjestior Route
        A-se-.ic            :.OOE-B3  _   _       l.DOE-03	_1.80E+OC
        Ra-1ur   ~~    "   S.COE-C2  "     "      S.1DE-C2   ~r              _       T>
       C-'cr.-.jrr            2.50E-C2               5.00E-03               '     '       0
        CoSPe'             3.70E-02               3.70E-02                           0
         I-oi                     00                           0
         Let:                     00                           0
       Ka-.;aiese           S.ODE-C:               2.00E-C1                           0
        Me-c.-y            3.DOE-0*               3.00:-0<                           0
        *::ie*              2.00E-C2               2.00E-D2                           0
   l.'-'-icKs-oe^iie     9.00E-C1               9.00E-D2                           0
    Tr-.:-':-3e:ie-,e               0                      0                    J.10E-02
         Zm:              2.00:-::               2.00E-01                           0
Be*.:eie 0
Cz-sc- Te:"a:-'c-ide C
C'::-:':- 0
*e:-/e-.e C-'e-ioe 0 3.00E»0:
To'ueie 0 2.00£»D:'
1 . 1 , l->i:*'e-Mtrieie 3.00E»OC
•'-.:•' :-5«:ie"-e 0
Xy-eies C 3.0DE-C1
0
C
0
0 3.00E-00
0 2.0DE»0:
3.00E-01
C
C 3.00E-C1
2.90E-C2
J.SOE-O:
8.10E-02
1.40E-C2
0
0
1.70E-OE
0
        Ze-os re;*ese*.t univ»i Title or intpplicible d
-------
                                   TABLE 2

                             Protectiveness Summary
                                  Health Only
 Medium
                                   Current Use    Future Use
 SoH
Air
      stream sediment ingestion
      gas vent air

      gas vent air at 50 meters

      indoor air
Water
                                   2.79 X 107    2.79 X 10:
                                       NA1        2.23 X
                                   9.05 X 10"   9.05 X 10"
                                   1.74 X 10s    1.74 X 10s
      ground water from monitoring wells      NA!       5.66 X 10"*

                                            NA;       9.52 X 107
surface water
Biota
      fish ingestion
                                   1.59 X 106     1.59X106
All MEDIA
                                   1.77 X 105    5.87 X
    : No current exposure pathway.

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          TABI.R  1

Ground Water
(monl tor Inp, wells)
SlfMMARY STATISTICS FOR MONITORtNG DATA
  Ground Wnlrr
  (pnt.Hhle WP! t n )
Surface Water
Sediments
Chemical
Arsenic
Barium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Methylene Chloride •
Nickel
1,1, 1-Trlchloroethane
Trlchloroethene
Zinc
Geometric
Mean
11.01
152.23
26.93
14.49
18504.40
6.96
122.45
0.15
31.55
114.66
Max Imum
68.00
399.00
222.00
102.00
301000.00
230.00
603.00
1.70
146.00
500.00
Geomet r Ic
Menn
("P. /I.)
2.93
145.29
2.93
14.73
4170.00
5.01
73.41
0.15
11.70
109.63
Notei Blank spaces are shown for


Maximum
(tiR/l.)
5.00
354.00
5.00
73.50
4170.00
64.00
124.00
0.88
20.00
650.00
Geometric
Mean
(UR/I.)
p
1
3.62
lb.8*
4316. B6
2.7*
78. 3«
0.12
2.98
11.02
5.72
3.0*
45.47
compounds not detected

(continued)






Ma x 1 mum
(UR/I.)

' ' 10.00
25.00
5070.00
100.00
'• 84.40
0.40
2.50
i
I 20.00
1
90.00
14.00
170.00
Geometric Maximum
Mean
(mp, /kg) (mg/kR) 1
4.22
50.09
lo. si
7.18
i
11189.40 ^
34.58
14.39
0.09
2.46
1
i
32. Ob
8.50 '
1 |
2il.OO I
35.00 ,
47.80
i
woo. oo ; '
llo.oo i '
239.00
0.20
1
i ;
I
6.50
• '' 1
lift. 00 '
.. _- i
•
i
'
i
I

'
1

•

-------
                         TARIF 1    SUMMARY STATISTICS FOR MONITORING DATA
COMPOUND
ACFTONE
flfMUMF
RRIWIIIICNI OR OMT INANE
2'R'IIANONE
CARRON Dl Sill FIDE
CARRON If IB Arm OR IDE
CHIOROREN/FNE
CHIOROTIHANE
CHIOROIORMJ
CHI OR OHM MANE
DIRRCMOMF THANE
.4-OICHIOROWEN7ENE
2-DICNLOHOBE N/l NE
1 icHlORnniFlUnROME INANE
.1 01 CW OR Of INANE
,2-DICNiCMOE INANE
.2-DICNIOROF.THENE (TOTAL
TRANS- 1.2-OICHlOROETHENE
DICNIOROOIFLUOROMETHANE
ETNVIRENHNE
META ETHYL TOLUENE
HFPIANE
RE KANE
ISORUIYIENC
ISOPROPYL NEN7ENE
MflN»l ETHYL KEIONE
MEIHYLENE CHLORIDE
PENIANE
TROPE NE
S TYRE HE
112 J-TETRACHLOROETHANE
1EIRACNIONOEIHENE
TOIM HE
1.1.1- IRICHLOROETHANE
1.1.2-IRICNlOROE IHANE
TRICNIOROETHENE
TRICHIOROFIUOROMEIMNE
VINYL CHI OK IDE
MVIENE (TOTAL)
MP-NVLENE
O-KYLENE

mnnood
r.roMitRic:
Ml AN
(tK|/m1)
H.6
.1. 7


1.7

2.1

t.B


2.1
1.1

1.5


1.5
1.4
2.9
2 4
2]l
6.0
4.9
1.1
1.1
1.9
2 T
2.6
1.7

1.0
1.7
1.1

1.1
1.9

1.5
4 ]
1.5

AIR
MAN
»«iq/«rt)
190000.0
B10.0


79.0

1107.5

270.0


160.1
41.0

220.0


12.5
2000.0
4110.0
96.0
1265.1
9500.0
750.0
71.7
104.2
440.0
670.0
260.0
25.0

18.2
1100.0
19.6

17.8
475.6

79.5
189.0
167.0

INDOOR
GEOMETRIC
Mf AN
5.5
1.1
o.n
1.4
2.2
O.fl

1.7
1.1
2.0
1.0
1.9

3.4
1.0
1.0
1.2


1.3
1.0

2.t


1
M

!
1.6
1.0
1.1
4.1
3.6
0.9
1.0
2.9
1.6
1.7

'

AIR
M
("I


1
1
t
1
•
1
t
|

1
I
1
j





,
(
[
1
1
i
I
1
1

I

1
i
i
. i

t


i

....i.
AN
197.11
5.9
2.0
15.7
10.6
2.0

10.0
16.1
11.0
2.0
24.9

26.7
1.5
5.0
3.5


10.9
2.5

29.9



61.1


4.3
7.0
14.
192.
58.
2.
3.
77.
10.
26.5



                                                                                                             .;:   •<
                                                                                                           • •'•.   !i
BLANK SPACES HE PRESENT EITHER NO ANALYSIS PERFORMED OR UNAVAILABLE
                                                                         I  :

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                RESPONSIVENESS SUMMARY
                FOR THE REMEDIAL ACTION
       AT THE M&T DELISA LANDFILL SUPERFUND SITE
              OCEAN TOWNSHIP, NEW JERSEY
                   TABLE OF CONTENTS

     SECTION                                 PAGE

I    INTRODUCTION	  1


II   PUBLIC MEETING COMMENTS	  2

     A.    REMEDIAL INVESTIGATION FINDINGS	  2

     B.    PROPOSED PLAN AND FUTURE SITE
             ACTIONS	  5

     C.    SITE HISTORY AND CURRENT STATUS	  8

     D.    GENERAL'COMMENTS	 10


III  RESPONSE TO WRITTEN COMMENTS	 12
IV.  COMMUNITY RELATIONS ACTIVITY
       CHRONOLOGY	 14

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                         I.   INTRODUCTION

     In accordance with the U.S. Environmental Protection
Agency's (EPA) community relations policy and guidance and the
public participation requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act  (CERCLA),
the EPA Region II office held a public qonunent period from June
28, 1990 to July 28, 1990, to obtain comments on the Proposed
Plan for the M&T DeLisa Landfill Superfund site (the Site) in
Ocean Township, New Jersey.  The Site covers 132 acres of which
approximately 39 acres consisted of a private solid waste
landfill which operated from 1941 to 1974.  Currently the Seaview
Square Mall Complex is located on the Site.  On July 12, 1990,
EPA and the New Jersey Department of Environmental Protection
(NJDEP) held a public meeting to receive public comments on the
Proposed Plan.  Approximately 30 community residents and
interested persons attended the meeting.  Copies of the Proposed
Plan were distributed at the meeting and placed in the
information repositories for the Site.

     Public comments received during the comment period are
documented and summarized in this Responsiveness Summary.
Section II presents a summary of questions and comments expressed
by the public at the July 12 public meeting.  All questions and
comments are grouped into general categories, according to
subject matter.  Each question or comment is followed by EPA's or
NJDEP's response.

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                   II.  PUBLIC MEETING COMMENTS

     This section contains questions and comments presented at
the July 12, 1990, public meeting.   Comments contained in this
section are grouped according to subject discussed.


A.   Remedial Investigation Findings

1.   An environmental consultant for the Deal Lake Commission
     presented the Commission's comments on the Rl.  In general,
     the Commission believes that the Sit* has a significant
     impact on Deal Lake, and that EPA should further investigate
     potential effects of the Site on biota in the lake.  The
     Commission's specific comments included the following:

          The RI includes very little sampling of nutrient
          concentrations associated vith leachate discharging
          into Deal Lake.  A 1983 EPA Clean Lakes Diagnostic
          Feasibility Study had concluded that Deal Lake Brook,
          downstream of Beaview Square Mall, consistently
          contained ammonia and nitrogen at levels at least 10
          times greater than those measured in other streams in
          the area.  The Deal Lake Commission believes that EPA
          should investigate this.

          The Deal Lake Commission believes that the landfill is
          leaching into the lake and perhaps increasing the rate
          of eutrophication.  The portion of the lake near the
          Site has had an extremely high concentration of algae
          and other types of aquatic life, which the Commission
          feels can be attributed to the landfill.

          The Deal Lake Commission is concerned about the
          potential effects of metals in the lake.  Independent
          observations of orange-brown floe, caused by iron
          precipitation,  an indication of leachate running into
          surface water,  were made in Deal Lake Brook near the
          Mall.  In addition, sediment seep samples that were
          collected down-gradient from the Site during the RI
          contained some of the highest concentrations of metals
          found.  The Commission is concerned that, although the
          RI concluded that the metal concentrations in the lake
          (copper in particular) do not pose a risk to humans,
          they may accumulate and be toxic to aquatic life in the
          lake.

     EPA Response: EPA is recommending further monitoring and the
     maintenance of some of the environmental controls that were
     put in place during construction of the mall.  However, it
     is necessary to distinguish between activities that.EPA can

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     implement under Superfund and those that must be -taken under
     other environmental laws and regulations.  CERCLA, the
     Superfund law, mandates that EPA respond to releases of
     hazardous substances.  That limits the actions that the
     Agency can take under Superfund.  EPA cannot address the
     potential effects of non-hazardous substances, such as
     nutrients in the lake,  nitrogen, and iron precipitation,
     which are outside of the scope of CERCLA.  Consequently, EPA
     has requested that NJDEP assume the lead for future site
     activities connected with the Site.

2.   The consultant for tbe Deal Lake Commission asked whether
     any bio-assays vere conducted during the risk assessment to
     study chronic effects on biota.

     EPA Response:  No, the endangerment assessment did not
     include any such studies.  The endangerment assessment
     examined potential health-based risks to humans from
     potential exposures to Site substances.   These include
     ingestion of fish from the pond.  Since  the risk
     attributable to the Site from consumption of fish is within
     an acceptable range, EPA believes there  is no need to
     perform bioassays under the auspices of  the Superfund
     program.

3.   A Congressional aide asked whether the arsenic found in veil
     vater at the Site during the RI could indicate that
     agricultural chemicals and pesticides vere disposed at the
     Site during the 1950s.

     EPA Response:  EPA has no records of disposal of pesticides
     in the landfill.   In addition,  samples were analyzed for the
     presence of pesticide compounds.  No pesticide compounds
     were found.

4.   The Congressional aide referred to the RI results vhich
     detected arsenic in unfiltered veil samples but not in
     filtered samples and asked vhether the conditions of both
     tests vere the same.  Be also asked vhether any further
     testing had been conducted to confirm the results of these
     tests.

     EPA Response:  Both filtered and unfiltered samples were
     taken under the same conditions and from the same bailer.  A
     groundwater sample retrieved from a monitoring well is
     immediately split into two samples at the well site.  The
     unfiltered sample goes directly into a sampling bottle; the
     filtered sample is poured into a sampling bottle through a
     pre-cleaned barrel filter unit with a disposable 0.45 micron
     membrane filter disk.  We were unable to confirm the levels
     of arsenic found in our 1984 sampling event in our
     subsequent sampling efforts in 1988.  We are aware Of no

-------
     other sampling efforts.

5.   One area resident asked  whether there  it  any risk to
     fishermen who eat fish caught in Loch  Harbor (Deal Lake).

     EPA Response:  EPA evaluated risks  to  human health from
     consuming fish attributable  to hazardous  substances
     emanating from the Site  as part of  the risk assessment.  The
     findings are that any risks  associated with consuming fish
     potentially affected by  the  Site are within the range that
     EPA has determined to be acceptable.

6.   A local official expressed concern  that EPA does not know
     what is in the landfill  because its contents were not tested
     during the RI.

     EPA Response:  No systematic sampling  of  the refuse material
     was done by EPA.  However, during the  design phase for
     construction of the Mall, 58 test borings were drilled, most
     into the landfill material.   The test  borings disclosed the
     refuse fill to consist of layered brown to black sand with
     paper, rags, wood, metal, concrete, and assorted organic
     material.  Approximately 800,000 cubic yards of refuse
     material was excavated for construction of the Mall.  There
     was no evidence during these excavations  or the test borings
     of the presence of hazardous substances.   EPA in subsequent
     investigations collected samples from  the formation
     underneath the refuse in the landfill. Hazardous substances
     were not detected in significant concentrations in these
     samples.  No borings were drilled through the clay liner
     surrounding the Mall. It was decided  not to puncture the
     clay to preserve its integrity as a barrier to leachate
     flow.

7.   A resident asked whether the RI investigated the presence of
     aromatic hydrocarbons at the Site,  because State-conducted
     testing downstream from  the  Site, along Fairmont Avenue,
     found the presence of aromatics whose  source is unknown.

     EPA Response:  Samples collected during the RI were analyzed
     for a long list of substances, including  aromatic
     hydrocarbons; none were  found on or associated with the
     Site.

8.   A Monmouth County official asked whether  groundwater samples
     had been collected south of  Route 66 and  stated that the
     County had sampled storm drains there  and had found ground
     water with a leachate-like appearance  and elevated chloride
     levels.

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     EPA Response:  One potable well PW-D located next to Route
     66 on the south side of the highway was sampled in our 1984
     sampling event.  We detected no hazardous organic compounds
     in our sampling.  Several metals were detected in this well
     in unfiltered samples.  EPA did not test for chlorides.  It
     should be noted that located south of Route 66 is the
     Neptune Municipal Landfill which may potentially impact
     surface water bodies in the area.
B.   Proposed Plan and Future Site Actions

1.   The consultant for the Deal Lake Commission stated that the
     Commission feels that, although the State is fully capable
     of overseeing proper closure activities, EPA should remain
     involved with the project to ensure that all environmental
     impacts associated with the Bite are addressed.  Be also
     suggested that EPA take some steps to pre-treat leachate
     before its release into Deal Lake and suggested that EPA
     modify a series of detention basins on the Beaviev Square
     Mall site for this purpose.

     EPA Response:  (Developed from EPA response at the meeting)
     EPA based its decision to refer this site to NJDEP upon a
     review of historical documentation which did not reveal any
     past disposal of hazardous waste at the Site,  the results of
     the RI which demonstrate that the landfill is not a source
     of significant concentrations of any hazardous substances .
     and a conservative assessment of risk attributable to the
     release of hazardous substances, from the Site which
     indicates that the current risk posed by the Site is within
     an acceptable range.  With respect to improving the design
     of the detention basins, EPA is recommending that NJDEP
     investigate the series of detention basins to determine if
     modification is warranted.

2.   A Congressional aide stated that the selected alternative
     vould involve delisting the M&T Delisa Landfill Site from
     EPA's National Priorities List (NFL)  and place it under
     state jurisdiction.  Be asked how the State will be able to
     fund the required activities and when the State NJDEP vould
     be able to address the Site.  Be expressed concern that EPA
     could be shifting responsibility to the State, knowing the
     State could not effectively deal with the Site.

     EPA Response:  (Developed from State response at the
     meeting.)  Solid waste landfill closure will be a State
     responsibility.  The State of New Jersey does not have
     funding to give to municipal landfills for closure, but
     requires the owner of record to provide financial assurances
     and fund any activities required for proper landfill closure
     and long-term maintenance.  State regulations require a

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     post-closure  maintenance period  from  30  years  after the
     landfill has  closed.   Since  the  landfill was closed in 1975,
     this would mean that  post-closure  activities at  the Site
     would have to be conducted until the  year 2005.   The State,
     however, has  the latitude to require  monitoring  activities
     for a longer  period of time;  conversely,  if the  monitoring
     indicates that no problems are occurring,  such as no surface
     or ground water contamination or methane gas migration, the
     State could decrease  the time that post-closure  monitoring
     would be required.

3.   A Congressional aide  expressed concern that Federal and
     state money has been  used to address  the nutrient content of
     Deal Lake and its biological effects.  He stated that the
     source of the leachate that  is adding nutrients  to the lake
     should be identified  and prevented from  entering the lake
     before it creates these problems.

     EPA Response:  EPA agrees, however, CERCLA is  not the
     appropriate vehicle to address all non-hazardous contaminant
     sources to Deal Lake.

4.   Several meeting attendees asked  what  portion of  the
     projected costs of future actions  the one responsible party
     who has been  identified will have  to  pay and vhat their role
     vill be in these actions.  One person asked EPA  to identify
     the responsible party.

     EPA Response:  (Developed from State  response  at the
     meeting.)  The responsible party is the  current  property
     owner, in this case Equitable Real Estate Investment
     Management, Inc.  The State  is still  determining how it will
     ensure that the responsible  party  complies with  State
     landfill post-closure regulations. NJDEP has  the authority
     to require the property owner to monitor the Site and
     maintain the  leachate collection,  monitoring well,  and gas
     vent systems  until such time as  the State is completely
     satisfied that the landfill  does not  pose a potential
     threat.

5.   A local official asked vhat  the  State's  position is on
     transferral of responsibility for  the landfill from EPA and
     several meeting attendees asked  vhat  specific  actions the
     State vill take at the Site  in the next  10 to  15 years.

     EPA Response:  (Developed from State  response  at the
     meeting.)  The State  concurs with  EPA's  recommendation to
     transfer responsibility of the landfill  to NJDEP.  The State
     is proposing  that monitoring of  the Site is more appropriate
     than remedial action.   Therefore,  the cost of  the proposed
     actions will  be less  than remedial response.   The identified
     responsible party will be involved in conducting and/or

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     paying for the proposed monitoring actions although the
     exact mechanisms that NJDEP will use to ensure that the
     responsible party complies with requirements have yet to be
     decided.  However, the kinds of post-closure actions that
     the State has the authority to require the landfill owner to
     take are similar to the controls that are currently in
     place; the parking lot serves as an impermeable cover and
     the Site has leachate control and gas venting systems.  In
     addition, NJDEP has the authority to require the owner to
     maintain these systems for a 30-year period, which in the
     case of the Site would be some time in the early part of the
     next century.

6.   A local official asked whether EPA would be able to take
     action if, some time in tbe future/ monitoring indicated
     that a hazardous waste problem exists at the MtT Delisa
     Landfill site.  Be stated that he is concerned that leachate
     may only have been minimized and the spread of contamination
     slowed by the liner and the parking lot, but that in the
     future leachate may overflow from the landfill and start to
     move into the environment.

     EPA Response:  At the public meeting, EPA stated that if the
     post-closure monitoring reveals that a problem exists, the
     Site could be renominated to the NPL.  After renomination,
     EPA could then take actions.  If an emergency situation
     occurs where an imminent threat to human health or the
     environment occurs, EPA can take removal actions to protect
     people in the area and mitigate the hazardous substance
     release.   Pursuant to 40 CFR Section 300.425 (e)  (3),  "sites
     deleted from the NPL are eligible for further Fund-financed
     remedial actions should future conditions warrant such
     action.  Whenever there is a significant release from a site
     deleted from the NPL, the site shall be restored to the NPL
     without application of MRS."  Consequently,  the site would
     not have to be renominated to the NPL.

7.   A local official noted that some of the concerns voiced at
     tbe meeting seem to be outside of the scope of the Buperfund
     program,  and asked whether the State could address them if
     it assumes responsibility for the Site.  The official  also
     asked whether NJDEP could require the Site owners to
     implement additional measures to prevent damage to Deal
     Lake.

     EPA Response:  (Developed from State response at the
     meeting.)   If the State determined that there was a need to
     redesign some of the existing environmental controls,  the
     State has the authority to require the owner to take the
     additional actions.  The property owner could be required to
     conduct monitoring of soil,  sediments,  and other
     environmental media to determine if a potential problem

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     exists.   NJDEP also  may  involve  other  authorities  within the
     State,  such as the Soil  Conservation District,  if  an issue
     falls within their jurisdiction.

8.   A local  official asked,  if  the Site remains  under  EPA
     jurisdiction,  whether  NJDEP would  be able  to address
     concerns that would  be outside the scope of  the Superfund
     program.

     EPA Response:   (Developed from State response at the
     meeting.)   The NJDEP Division of Solid Waste Management
     (SWM) cannot;  it does  not have jurisdiction  for sites listed
     on the NPL.  The SWM cannot have exercise  authority to
     require  any remediation  or  control until completion of the
     CERCLA remedial process.  However, other divisions within
     NJDEP may have the authority to  respond to specific
     problems,  under other  state laws and regulations such as the
     New Jersey Spill Compensation and  Control  Act or the Water
     Pollution Control Act.
C.   Site History and Current  Status

l.   One local official  asked  whether records  are available on
     past disposal practices at  the Mil  DeLisa landfill or
     whether EPA knows what substances were  disposed these.

     EPA Response:  There is very limited  information available
     on the types of wastes that were disposed in the landfill.
     EPA knows that construction debris  and  refuse were disposed
     of at the Site, but has no  record of  hazardous substances
     being disposed there.

2.   A resident commented that it is  impossible to know what
     substances were disposed  in the  landfill  because it was very
     casually run when it was  in operation and allowed
     unrestricted access at all  time.

     EPA Response:  (Developed from State  response at the
     meeting.)  EPA and  the State realize  that there is no
     information on exactly what was  disposed  at the Site.  Based
     on investigations,  however,  there are no  indications that
     any large quantity  of hazardous  substances was disposed of
     there.  If any releases of  hazardous  waste occur in the
     future, monitoring  conducted as  part  of the State
     post-closure program should detect  them and allow remedial
     action to be taken.

3.   A local official asked whether the  landfill was privately
     owned during its period of  operation.

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     EPA Response:  The landfill was privately owned, but EPA
     believes that municipal waste was disposed of there.

4.   Several meeting attendees asked about the leachate
     collection tank currently operating at the Bite.  Questions
     asked included whether the tank is tested periodically,
     whether the tank will be tested if MJDEP assumes
     responsibility for the site, and how large the tank is.

     EPA Response:  (Partially developed from State response at
     the meeting.)  The tank is not tested periodically; it was
     tested twice during the RI.  If the State assumes
     responsibility for the Site, it will ensure that all systems
     present, including the leachate collection tank, are
     monitored and properly maintained; however, under State
     regulations regular testing of this kind has not been done
     in the past.

5.   Several meeting attendees asked whether the practice of
     periodically emptying the leachate collection tank into the
     Ocean Township sanitary sewer is safe, whether the treatment
     plant can effectively remove harmful substances from the
     leachate, and whether the Township is notified when water
     will be dumped.

     EPA Response:  Periodically emptying the leachate collection
     tank into the sewer should not have a negative effect on
     sanitary operations.   The volume of leachate in the tank is
     only a minor fraction of the volume of waste typically
     treated.  The Ocean Township Sewerage Authority indicates
     that approximately 10,000 to 30,000 gallons per day of
     leachate discharge into the sanitary sewer from the leachate
     collection tank.   Guidelines and limitations for the
     discharge of effluent from the waste-water treatment plant
     are are set in the facility's permit.

6.   The consultant for the Deal Lake Commission asked whether a
     portion of the landfill lies north of Ring Road and whether
     that portion of the landfill is unpaved.  A local official
     asked whether a considerable amount of water was entering
     the landfill by this route.

     EPA Response:  A portion of the old landfill,  approximately
     9 acres, does lie north of Ring Road and is not paved.  Some
     water is entering the landfill in this manner.   It is not
     possible to entirely prevent water from entering the
     landfill, however,  leachate generated by this water is being
     collected in the leachate collection system.

7.   A local official asked whether the mall would have been
     allowed to be built or would have been built differently if
     the M&T DeLisa landfill had been identified as a Superfund

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     site at the time.

     EPA Response:   The protective environmental  measures
     constructed have been effective  in controlling environmental
     degradation by the landfill.   EPA has  no reason to believe
     that they are  not working.  The  RI has shown that there are
     no detectable  levels of air contaminants within mall
     buildings that can be attributed to the landfill,  which was
     a major concern.  The parking lot appears to be acting as an
     impermeable cover that prevents  infiltration of rainwater
     which would create more leachate.  The  leachate that is
     generated is being collected.  Capping and leachate
     collection are standard technologies used in landfill
     closure.   Because EPA1s concern  is that the  existing control
     measures continue to be properly maintained, EPA is
     recoininending to NJDEP that  the air vents,  leachate
     collection and monitoring systems, and surface water
     monitoring be  continued.

8.   A local official asked whether the M&T Delisa landfill is
     currently a Superfund site, and  if so, does  that mean that
     sufficient environmental problems were present to make it
     eligible for the list.  He  also  asked  where  the Site is
     ranked on the  NPL.

     EPA Response:   Yes,  the M&T Delisa landfill  is currently on
     EPA's NPL..  When EPA initially evaluated the Site in 1983,
     there were indications of possible environmental
     contamination  and sufficient  numbers of people who used the
     ground water who were potentially at risk to warrant further
     study.  Therefore, the Site was  placed on the NPL.
     Subsequently,  after the RI  was completed,  EPA concluded that
     the Site could safely be deleted from  the list.  Sites on
     the NPL are assigned a numerical score,  but  the score is an
     indication of  the numbers of  people who are  potentially
     affected and the types and  amounts of  substances that are
     present on the site rather  than  of their relative potential
     hazard.  The Site is currently ranked  in the low range of
     the 109 sites  in New Jersey that are on the  list.


D.   General Comments

1.   One commenter  asked why the Administrative Record file for
     the Site was placed in the  Neptune Library instead of the
     Ocean Township Library.

     EPA Response:   EPA contacted  the librarian at the Ocean
     Township Library,  but was informed that the  library did not
     have sufficient space to accommodate the Administrative
     Record for the Site.   The file was placed in the Neptune
     Library because it had the  available space and is located

                                10

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     closer to the Site than other possible facilities, such as
     the Ft. Monmouth Federal Depository.

2.   A Monmouth county official stated that leachate in the area
     of Steinbeck's parking lot is bypassing the leachate
     collection system.  Be added that saaples that the County
     has collected in the area have contained high levels of
     ammonia and asked that the leachate collection system be
     repaired.

     EPA Response:  Data gathered during the RI indicates that no
     significant contamination from hazardous substances is
     attributable to the Site.  While some leachate may be
     bypassing the collection system, our data indicates that the
     impact of hazardous substances is negligible.  Currently,
     EPA does not believe that the leachate collection system
     should be redesigned, however, NJDEP has the authority to
     require modifications if any are determined to be necessary.

3.   A resident commented that aromatic hydrocarbons detected in
     surface vater on Fairmont Avenue have a gasoline odor and
     oily appearance and, although their source has not been
     found, appear to be in line with the landfill.

     EPA Response:  (Developed from State response at the
     meeting.)  At the present time,  NJDEP believes that the
     source of these substances is not connected with the Site.
     Currently, a NJDEP investigation is proceeding under the
     Environmental Cleanup and Responsibility Act (ECRA)  to
     determine the source of the contaminants observed in the
     area of Fairmont Avenue.

4.   A local official asked in vhich  directions the aquifers
     potentially affected by the Site flow.

     EPA Response:  Results from tests conducted during the RI
     indicate that in the vicinity of the Site,  the Kirkwood
     aquifer flows to the southeast toward Deal Lake Brook, and
     the deeper Vincentown aquifer flows to the east-southeast
     toward Deal Lake.  These aquifers may have different flow
     patterns in other areas.

5.   The consultant for the Deal Lake Commission stated that the
     Commission has received Federal, State,  and local government
     funds to dredge sediment from the area of Deal Lake that is
     affected by metal runoff from the landfill.  The Commission
     is concerned that the sediments  they dredge may contain
     metal concentrations that exceed landfill disposal standards
     and would need to find alternative disposal sites, thereby
     increasing the cost of the dredging.  For that reason, the
     Deal Lake Commission feels that  EPA involvement should
     continue.

                                11

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     EPA Response:   Contaminants found at the Site are indicative
     of solid waste landfills.   Unlike typical EPA Superfund
     sites, the landfill is not releasing significant
     concentrations of CERCLA hazardous substances.  Although
     remedial action under CERCLA is not warranted, EPA
     recommends that environmental controls be implemented and
     maintained at the Site to address potential problems
     associated with solid waste disposal.   Current State
     statutes regulate post-landfill closure ground water and
     surface water monitoring requirements.  For this reason-, EPA
     is transferring this Site to the NJDEP for future response
     action.  EPA has the authority to address the Site at any
     time if EPA believes that the Site posses an imminent threat
     to human health or restore the site to the NPL if warranted.

     A local official asked NJDEP whether it has assumed
     responsibility for other landfills in the State.
     Response:  (Developed from State response at the meeting.)
     The State has not assumed responsibility for a closed
     landfill that has been delisted from the NPL.  However,
     NJDEP is responsible for overseeing nearly 270 other
     municipal and private facilities in New Jersey.
           III.      Response to Written Comments
Dr. Stephen J. Souza of Coastal Environmental Services, Inc., on
behalf of the Deal Lake Commission/  objected to any conclusions
made by the EPA or NJDEP that the Site has not or does not
continue to impact the water quality and biota of Deal Lake.  Dr.
Souza/ also on behalf of the Deal Lake Commission/ believes that
EPA should continue to list the Site as a Superfund sit* and that
EPA should not relinquish responsibility or supervision of the
Site to the NJDEP.  Be based his objections to the Proposed Plan
on the following.

1.   Water quality samples collected from Deal Lake Brook (at the
     Route 35 overpass) during a 1983 study of Deal Lake bad
     ammonia-nitrogen concentrations 10 times higher than that
     measured in other streams not effected by landfill
     activities.  Associated with this leachate was a floe/
     apparently caused by iron/ that formed a matt along the
     upper reaches of Deal Lake Brook.  Until the leachate
     collection system is redesigned to intercept all leachate/
     this problem will persist and the lake's water quality and
     biota will continue to be impacted.

     EPA Response:  An extensive sampling effort was done during
     the RIs of 1984 and 1988.  From those studies, we found low
     to non-existent levels of hazardous substances in Deal Lake

                                12

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Brook.  Our conclusion was that the Site was not releasing
significant concentrations of hazardous substances which
would result in degradation of Deal Lake Brook or Deal Lake.
Contaminants such as ammonia and iron are indicative of
solid waste landfills.  Unlike typical CERCLA sites, the
landfill is not releasing significant concentrations of
CERCLA hazardous substances.  At the present time, EPA does
not believe that the leachate collection system should be
redesigned, however, NJDEP has the authority to require
modifications if any are determined to be necessary.

The DSEPA's sampling program to investigate sediment
contamination vas inadequate.  The data cannot be used to
statistically verify that no environmental risk exists to
Deal Lake Brook or that Deal Lake has not been impacted by
heavy metals that migrated from the landfill.  In addition/
the sample collection technique (sediment scoop) would not
be effective in obtaining sub-surficial sediments since
there vas a tremendous influx of soil from the Site during
construction between 1975-1979.  Nucb of the disturbed
contaminated soils could be actually belov the surficial
samples collected in 1984 or 1989.  Therefore/ the data may
in fact be non-representative of actual levels of sediment
contamination.   A corer or a penetrating dredge appears to
be a more appropriate sampling method given the Site's
history of soil erosion.  As such/ the DSEPA's conclusion
that no impact has occurred to the sediments of Deal Lake
Brook or Deal Lake should be reconsidered.  At a minimum/
additional sampling/ using appropriate sampling techniques/
should be conducted of the sediments of Deal Lake and Deal
Lake Brook.

EPA Response:  EPA believes that the sampling technique was
appropriate to determine contaminant levels in stream
sediments.  One would expect to see contamination, if
present, reflected in current stream sediments.  The
tremendous influx of soil during the late 1970's mentioned
above may actually dilute levels of contaminants, while the
normal depositional process nay concentrate then.  EPA has
recommended to NJDEP that they continue monitoring the
surface water to be sure that contamination does not enter
the brook.

The environmental risk assessment did not include any actual
analysis of tissues from organisms residing in the sediments
or waters of Deal Lake or Deal Lake Brook.  The conclusion
of no potential risk associated with the consumption of fish
from Deal Lake is not fully substantiated.  At a minimum,
actual tissue samples from plants/ benthos/ and fisb should
be analyzed.
                           13

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     EPA Response:   EPA believes that a full  scale bio-
     assessment,  while possibly appropriate to define levels of
     bio-contamination in Deal Lake,  would not be useful in
     defining contamination attributable to hazardous substances
     from the Site that may have affected biota.   Our sampling of
     ground and surface water indicates that  no significant
     hazardous substances are impacting local surface water
     bodies.  It is reasonable to conclude from this data that
     biota is not being affected by hazardous substances
     attributable to the Site.  EPA's risk assessment evaluated
     the potential risk associated with bio-accumulation in fish
     from contaminants attributable to the Site.   This evaluation
     indicated a low potential risk,  below federal risk levels,
     for consumption of fish by humans.

4.   The D8EPA failed to consider the us* of  storm-water basins
     located in the Sea View Square Mall Bite/ upstream of Deal
     Lake Brook,  as a means of passively treating leaebate that
     bypasses the leachate collection system.  The basins would
     need to be regraded and retrofited with  new outlet control
     structures.

     EPA Response:   EPA will incorporate this suggestion into our
     recommendations to the NJDEP.

5.   Approximately 25-30% of the Bit* is not  capped.  Rainfall
     continues to percolate through these non-capped sections and
     create leachate.  Thus the landfill can  not be considered to
     be properly closed.  Actions should be mandated by the USEPA
     to properly cap the remaining sections of landfill in order
     to alleviate leachate contamination problems.

     EPA Response:   Areal photographs of the  landfill indicate
     that it was roughly 39 acres in size, the Mall and
     surrounding parking lot cover approximately 30 acres of the
     landfill (77%).  The landfill was operated from 1941 until
     1974 with a permit from NJDEP, and was subsequently closed
     before the construction of the Mall.  The 9 acres which are
     not covered by the mall, have been cleared,  graded, capped
     with natural soils, and re-vegetated. Under NJDEP
     regulations at the time, the landfill was properly closed.
     EPA believes that the present leachate collection system is
     performing adequately to reduce the flow of leachate into
     Deal Lake Brook.
Mr. John J. lannone, P.E.,  of Fred c.  Hart Associates, Inc., on
behalf of the Equitable Real Estate Investment Management/ Inc./
indicate their concurrence  with the Proposed Plan.
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   IV.  COMMUNITY RELATIONS ACTIVITY CHRONOLOGY
The Remedial Investigation Reports, the Endangerment
Assessment, the Proposed Plan and other documents which
comprise the Administrative Record for this Site were
released to the public for comment on June 18, 1990.  These
documents were made available to the public at the EPA
Region II Docket Room in New York City and at the Neptune
Township Public Library in Neptune Township, New Jersey.

On June 28, 1990, EPA published a notice in the Asbury Park
Press which contained information relevant to the public
comment period for the Site, including duration of the
public comment period, date of the public meeting, and
availability of the administrative record.

The public comment period began on June 28, 1990 and ended
on July 28, 1990.

EPA issued a press release on July 3, 1990, to announce the
availability for comment of the Proposed Plan.

A public meeting was held on July 12, 1990, where
representatives from EPA and the NJDEP answered questions
regarding the Site and the decision under consideration.
Approximately 30 people attended, including citizens,
elected officials, and representatives of the potentially
responsible party.
                           15

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Superfund Proposed  Plan

                                M  &  T DeLisa  Landfill  Site
                         Ocean  Township,   New  Jersey
EPA
Region  2
                   JUNE   1990
PURPOSE OF THE PROPOSED PLAN
This Proposed Plan describes the preferred
alternative for addressing potential air, surface
water, and ground water contamination at the
M & T DeLisa Landfill site (Site) in the Ocean
Township of Monmouth County, New Jersey.
This document is issued by the United States
Environmental Protection Agency (EPA), the
lead agency for site activities, and the New
Jersey Department of Environmental
Protection (NJDEP), the support agency.
Only  after the public comment period has
ended and the information submitted during
this time has been reviewed and considered
will EPA, in consultation with NJDEP, make a
decision as to what action(s) to take at this
Site.
  srrt BOUVDAHY
    N
Figure  1
EPA is issuing this Proposed Plan as part of
our public participation responsibilities under
Section I17(a) of the Comprehensive
Environmental Response, Compensation and
Liability Act (CERCLA).  This Proposed Plan
summarizes information that can be found in
greater detail  in the remedJal investigations
conducted by Fred C. Hart Associates, Inc.,
for the Equitable Real Estate Investment
Management,  Inc., under Administrative
Orders on Consent issued in November of
1983 and March of 1986 and other
documents contained in the administrative
record file for  the Site.

In addition, EPA has conducted an
endangerment assessment which was
completed in February of 1990.  This
document evaluated data from the remedial
investigations  and other information  regarding
potential ricks to public  health and the
environment from the Site.  The
endangerment assessment is used to
determine the baseline risk attributable to
hazardous substances that may be  released
from the Site (i.e., the risk posed  by the Site
before any actions to mitigate the
contamination are taken).

EPA and NJDEP encourage the public to
review these and other documents in the
administrative  record in  order to gain a more
comprehensive understanding of the Site and
the related Superfund activities conducted to
date. The administrative record file  contains
the information upon which a decision will be
based. The file is available at the following
locations:

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      Neptune Township Public Library
           25 Neptune Blvd.
       Neptune Township, New Jersey

                    and

             U.S.E.P.A. Region II
      Emergency & Remedial Response
             Division File Room
        26 Federal Plaza 29th Floor
        New York, New  York  10278

EPA, in consultation with NJDEP, may  modify
this Proposed Plan based on new information
or public comments.  Therefore, the public is
encouraged to review and comment on this
Proposed Plan.

SFTE BACKGROUND

The Site is located in the southeasiern corner
of Monmouth  County,  northwest of the City of
Asbury Park in Ocean Township, New Jersey.
The 132-acre  Site is bounded on the west by
Route 18, on  the south by Route 66, on the
east by Route 35. and on the north  by an
industrial park located off Sunset Avenue (see
Figure  1).  The parcel contains three major
building complexes, the Seaview Square Mall
complex (Wall), the Seaview Movie Theater
complex, and  the Acme Supermarket, each of
which is surrounded by a paved parking area.
The only wooded portions of the parcel are
located in the southeast corner of the Site
and sooth of the Route 35 mall access road.
Immediately south of the Mall and located on
the Site lays the  most southern arm of Deal
Lake Brook which flows from west to east  to
Deal Lake.

The former M  & T DeLisa landfill, which was
covered with a natural soil cap supporting a
moderate growth of vegetation, occupied
approximately 39 acres of the 132-acre Site.
The Mall and  Its  parking areas  cover
approximately 30 acres of this former landfill.
The landfill was in operation from 1941 until
1974 under a  NJDEP permit. After  the landfill
was closed in 1975 an investigation  of the
landfill  area was  undertaken by Woodward-
Gardner and Associates, Inc., for the
Goodman Company, who developed the
parcel for Equitable Real  Estate Investment
Management,  Inc., a present owner of the
Site.  The results of the investigation were
detailed in a report which recommended
control measures to protect against the
possible impact of gas and/or.leachate
generation from the landfill and described
other measures that would be needed to
provide a stable soil for the construction of
the proposed buildings.  These
recommendations were incorporated into the
design and  construction of the Mall which
was completed in 1977.

The elements of Mall construction which were
implemented to provide environmental
controls, which include refuse movement, gas
control and  leachate control, are summarized
below:

Refuse Movement.  The refuse material was
found to be unsuitable for building support,
therefore the refuse material situated under
the planned Mall was  removed. The refuse
was excavated  down to the underlying  Shark
River Marl.  Then it was placed in areas which
already  contained refuse.  The area excavated
was replaced with  clean fill which was
capable of supporting the buildings.  In
addition 3 to 10 foot thick clay side walls
(liner) were  installed during construction to
prevent landfill gas migration into the
buildings. The result was that the  buildings
are constructed within a low permeability soil
configuration composed of a naturally
occurring confining layer, the Shark River
Marl, beneath the Mall and the clay side liner.

Landfill Gas  Control.  Three measures were
implemented to control the potential
movement of landfill gas into the Mall.  The
first was the installation of the clay liner
discussed above.  The second was the
construction of  passive control vents, which
consist of perforated horizontal collection
pipes located in the refuse attached to  vertical
pipes open to the atmosphere, which provide
a preferred pathway for landfill gas migration
and help prevent horizontal migration into the
buildings. The last measure was to limit the
permeability of the Mall's outer utility corridors
(which contain sanitary sewers, electrical
wiring, etc.)  by  placing all utility lines within
one narrow  corridor, replacing refuse in this
corridor wrth clean soil, and compacting the
soil to reduce permeability.  Utilities which
could not be placed within this corridor were

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enclosed in concrete.
 REMEDIAL INVESTIGATION SUMMARY
Leachate Control. Leachate is generated
when rainfall infiltrates into the ground and
percolates through  refuse material, or when
ground water moves horizontally through the
refuse.  Four measures were implemented to
minimize the generation of leachate: surface
capping of the landfill, modifications to the
storm water system, construction of a
leachate collection system, and installation of
a clay liner.  The manner in which these
measures  were implemented is described
below:

o      The Mall buildings and surrounding
       parking lot, along with the natural soil
       covering remaining on undisturbed
       portions of the landfill, act as a low
       permeability  cap reducing the volume
       of  rainwater  which is available for
       leachate generation.

o      The storm water system was' designed
       to  keep storm water separate .from
       leachate by,  1)  using the parking lot
       as a low permeability cap to provide a
       barrier between storm water runoff
       and leachate, 2) constructing catch
       basins and storm drain pipes as close
       to  the surface as  possible, and 3)
       constructing  storm water  pipes which
       are designed to be impermeable so
       that the storm water collection system
       would not act as  a conduit for
       leachate migration.

o      A leachate collection system
       consisting of a perforated pipe within
       a gravel trench situated to intercept
       ground water/leachate moving toward
       Deal Lake Brook was also installed;
       the liquid is  then  collected and
       pumped to the sanitary sewer system
       for treatment at the municipal waste
       water treatment plant.

o      The clay liner, which was installed
       between the refuse and clean  soil fill,
       acts as a barrier to ground
       water/leachate flow, preventing It from
       migrating to  or under the Mall
       buildings.
 Pursuant to Administrative Orders on Consent
 of November 1983 and March 1988, between
 EPA and Equitable  Real Estate Investment
 Management,  Inc., Fred C. Hart Associates,
 Inc., was retained to conduct a remedial
 investigation at the  Site. The objectives of the
 remedial investigation were to characterize the
 nature and extent of any contamination
.associated with the Site, to identify migration
 of contamination  and its Impact on public
 health and the environment, and to determine
 whether there is a need for remedial
 measures to protect human hearth and the
 environment.  The remedial investigation was
 conducted under two distinct investigatory
 programs.  The initial investigation was
 completed in June  of 1984, while the
 supplemental  remedial investigation was
 completed in January  of 1989.

 The investigations evaluated air, surface
 water/sediment, and ground water quality.
 The air quality investigations were conducted
 in November/December of 1983, June  of
 1984, August  of 1988, January of 1989, and
 October of 1989.   Samples were collected at
 all outdoor vents and  in all accessible indoor
 areas of the lower levels of the Mall buildings
 The surface water/sediment sampling effort in
 the initial investigation included six  sampling
 locations.  Due to updated information on
 surface water flow,  three further areas  were
 sampled in the second investigation.  With
 respect to the ground water investigation  a
 total of 7 ground water monitoring wells were
 installed to determine  the geologic  and
 hydrologic conditions underlying the Site.
 These wells were then sampled along  with 4
 private  domestic  water supply wells located
 within one-half mile of the Site to determine if
 the landfill has impacted the local ground
 water.

 Upon completion of the investigations, the
 following conclusions were reached.

 o      The three uppermost geologic
        formations underlying the Site  are (in
        descending order): the Kirkwood
        Formation - consisting of alternating
        layers of  sand, silt and clay that are
        discontinuous  both laterally and
        vertically; the Manasquan Formation

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 (which is locally known as the Shark
 River Marl) -  consisting of laterally
 extensive, low permeability, clayey
 sands and silts; the Vincentown
 Formation - consisting of a fine to
 medium grained sand which
 represents a  viable source  of potable
 water in the vicinity of the Site.

 Qroundwater quality in the  local
 shallow KJrkwood aquifer immediately
 underlying the Site and in direct
 physical contact with landfill materials,
 does not appear to have been
 significantly impacted  by  the Site.
 This conclusion is based on the
 following.  Arsenic was detected in
 unfittered on-site monitor wells only,
 with the arsenic being found in up-
 gradient as well as down-gradient
 locations.  In a subsequent round of
 sampling no'significant concentrations
 of arsenic were found either on or off
 the Site.

 Due to the absence of any significant
 water quality  degradation in the
 shallow Kirkwood aquifer, together
 with the laterally extensive presence of
the Shark  River Marl which locally
 serves as  a confining  layer below the
 Kirkwood aquifer, groundwater quality
 in the deeper Vincentown aquifer is
 not anticipated  to be at risk as a
 result of past disposal practices  at the
 Site.

 Surface water and sediment samples
 collected did  not Find any significant
environmental quality degradation at
the down-gradient surface water
 locations.

 Although landfill gas is being
 generated at  the Site,  and there is
 evidence of slightly elevated levels of
 volatile organic, compounds (VOCs)
 inside the Mall along the  unventilated
 northern edge,  the landfill itself is not
 a source of detectable levels of VOCs.
 Concentrations  of VOCs in the Mall
 are not outside the range of VOC
 concentrations typically found in other
 public  and private indoor spaces.
SUMMARY Of SITE RISKS

An endangerment assessment was conducted
by  EPA to determine the baseline risk
attributable to the hazardous substances that
may be released from the Site.  The
assessment began with selecting indicator
chemicals which would  be representative of
the Site risks.  Chemicals were selected for
each media to ensure that all potential
exposure routes could be evaluated.  Then
environmental fate and transport mechanisms
were evaluated for each of the  indicator
chemicals.  The following  six exposure routes
were assessed: 1) inhalation of indoor  air, 2)
inhalation of air from gas vents both directly
from the exhaust and at 50 meters from the
exhaust, 3) ingestion of surface  water
sediments,  4)  ingestion (consumption)  of fish,
5) ingestion of surface water, 6) ingestion of
ground water from monitoring wells and from
local  potable wells. Current as well as future
risk scenarios were evaluated.  Conservative
consumption rates and  exposure scenarios for
each indicator chemical were used for the six
exposure routes.

The endangerment assessment  indicates that
their is no current risk that is attributable to
the Site. The endangerment assessment
identified arsenic as the only chemical in the
ground water that may causes its  risk levels
to exceed Federal guidelines in the future
groundwater use scenarios. That  is if potable
water wells were drilled  on Site,  in the
Kirkwood aquifer there may  be an
unacceptable risk to users of that  water.
Furthermore, EPA believes that  the use  of the
Kirkwood aquifer at the  Site is a very  remote
possibility due to the limited aquifer thickness
and low hydraulic conductivity.   Therefore,
EPA believes that the portion of the Kirkwood
aquifer underlying the Site is not an adequate
source of water for a private well.  This
finding is also based on the conservative
assumption that the arsenic concentrations
found in the unfittered ground water samples
are representative of ground water quality in
the Kirkwood aquifer.  EPA believes that the
levels of arsenic in samples from ground
water monitoring wells are not representative
of actual concentrations in the ground water
because arsenic was detected only in
unfirtered samples (arsenic tends to adsorb
onto particles  which immobilize the element)

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 EPA believes that the actual risk from arsenic
 is acceptable for the following reasons:  1)
 arsenic was not detected in any off-site
 potable wells, 2) concentration levels in all
 filtered monitoring well samples are below
 Safe Drinking Water Act standards and  are
 comparable to background levels, 3) and by
 including the arsenic concentration  levels from
 unfiftered samples  in future use scenarios in
 the risk assessment, a conservative estimation
 of future potential risk was obtained
 (5.7 X 1CT4) which resulted in a risk range
 which onry marginally exceeded EPA's target
 risk range (ie., 10^ to 107).  EPA believes that
 this is a very remote possibility due to the
 limited aquifer thickness and tow hydraulic
 conductivity on the Site.

 The results indicate that the only media
 posing potential unacceptable risk to human
 hearth is consumption of ground water from
 unfiltered monitoring wells  in future  use
 scenarios.  Given the current Site conditions,
 the cumulative lifetime cancer risk for this Site
• is within Federal guidelines for acceptable
 exposures.

 Thus the current threat to  human health and
 the environment from this Site is minimal.

 STATUTORY AUTHORITY FINDINGS

 In December of 1982, the Site was  proposed
 for the Superfund National Priorities  List
 (NPL).  The Site was officially added to the
 NPL in September of 1983.

 Although there  is  no significant  contamination
 which is attributable to the Site, there are
 environmental controls which need to be
 implemented and maintained.  Such actions
 are not within the jurisdictional authority of
 CERCLA.

 Upon the completion of  the remedial
 investigation, it appears  this Site should
 instead be handled under  the authorities
 designated to close and remediate  municipal
 landfills.  Therefore, the  remedial attemative
 selection process to describe and select a
 remedial action as mandated by CERCLA,
 was not appropriate for  this site. Subtitle D of
 the Resources Recovery and Conservation Act
 of 1976 as amended by the Solid Waste
 Disposal Act of 1980, is the Federal statute
concerning municipal landfills, and its
regulations address post-landfill closure
monitoring requirements.  NJDEP is
authorized to regulate municipal landfill
closures and post-closure monitoring in New
Jersey.  For this reason EPA is referring this
Site to the NJDEP for further action.   Current
State  statutes also regulate post-landfill
closure ground  water and surface water
monitoring requirements for municipal  landfills.

COMMUNITY FIOLE IN SELECTION PROCESS

EPA and NJDEP rely on public input to
assure that the  action selected for each
Superfund site considers the needs  of the
local community, in addition to being an
effective solution to the problem. To this  end,
this Proposed Plan is being distributed to the
public for comment.  The public is therefore
encouraged to review and comment on all
aspects of the plan.

Written and verbal comments on the plan, the
remedial investigation documents and the
endangerment assessment will be welcomed
through July 28, 1990.

The comments  and EPA's responses to those
comments will be documented in a
Responsiveness Summary.  The
Responsiveness Summary will  be appended
to the subsequent Record of Decision (ROD)
which formally documents the decision for the
Site.

All written  comments should be addressed to:

Lance R. Richman, P.G.
Regional Project Manager
Emergency and  Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza, Room 747
New York, New York 10278

A public meeting will be held in the  upstairs
room  of the West Park Recreation Center  on
July 12, 1990 at 7:00 p.m., to present the
details of the remedial investigation,
endanqerment assessment and the proposed
plan.  The West Park Recreation Center is
part of the  Ocean Community Pool and
Tennis Complex, located on West Park
Avenue between Highway 35  and Whale Pond
Road  in Oakhurst,  New Jersey.

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