United Stales
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/112
September 1990
f/EPA
Superfund
Record of Decision
Mannheim Avenue Dump, NJ
-------
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/112
X Rodptont1* AccMalon No.
4. TM*«idSUMM»
SUPERFUND RECORD OF DECISION
Mannheim Avenue Dump, NJ
First Remedial Action - Final
5. Report DM*
09/27/90
7. Au«wr(»)
». Pertonnlno OrgentnBon Rept. Mo.
«. Performing Orgiinlzrton N*m «nd Mdrm*
10. Pro|»cl/TMk/Work UnH No.
11. Comncl(C) or OnnKG) No.
(C)
(0)
12. Sponsoring. Orgwilullen Hum and AddrMt
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Typ* of Report ft Period Comrad
800/000
14.
IS. Supplementary Nolee
16. Abettct (Limit: 200 words)
The 2-acre Mannheim Avenue Dump site is a former municipally-owned industrial waste
landfill in Galloway Township, Atlantic County, New Jersey. Surrounding land use is
rural residential, and many residents and facilities in the area use ground water as
their drinking water supply. The site is adjacent to a wooded wetland area which
overlies a shallow unconsolidated sand and gravel aquifer and a deeper aquifer
eparated from the shallow zone by a semi-permeable clay layer. Prior to 1964, the
ite was used as a sand and gravel quarry. Beginning in 1964, drummed industrial
wastes, including TCE degreasing sludge, leaded porcelain fragments, and municipal
waste, were buried onsite in 35 waste mounds. In 1982, a State survey indicated the
presence of many unburied and leaking drums onsite. In 1984, EPA ordered a removal
action that required cleanup of the drummed waste, including 25,000 pounds of
degreasing sludge. Subsequent sampling from 1985 to 1986, revealed ground water
contamination onsite. In 1989, 35 mounds of contaminated soil were disposed of
offsite. This Record of Decision (ROD) addresses ground water contamination at the
site. The primary contaminants of concern affecting the ground water are VOCs
including benzene and TCE.
(See Attached Page)
17. Document Aiwlyeie *. Deecrlptora
Record of Decision - Mannheim Avenue Dump,
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, TCE)
b. Uentlflert/Open-EndedTenne
NJ
c. COSATI Reid/Group
18. Avillibility Stutmtnt
It. Security CUM (Thto Report)
None
20. Security CUM (Thte Psge)
None
21. NaofPegM
113
22. Prio.
(S*t AN3-234.18)
SM Instruction* on Rtvtnt
OPTIONAL FORM 272 (4-77)
(Formwty NT1S-I5)
Dfpwtnw* ol Commitw
-------
EPA/ROD/R02-90/112
Mannheim Avenue Dump, NJ
First Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes ground water pumping and
treatment using air stripping, with pretreatment for removal of iron, if necessary;
reinjecting the ground water onsite with an evaluation of the feasibility of using
infiltration basins as an alternate means of discharge; covering the disposal area
with clean fill; developing a contingency plan for the installation of individual
carbon adsorption units on residential wells, which may become affected by migration
of the contaminant plume; monitoring ground and surface waters; sampling the
sediment; performing a treatability study to investigate the need for further
treatments to remove toluene, lead, and chromium from ground water; and determining
the need for off-gas controls on air stripper units. The estimated present worth
cost for the remedial action is $4,217,100, which includes an annual O&M cost ranging
from $18,600 to $394,100 based on differences in treatment and monitoring systems
over a period of 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific goals for ground water include TCE
1 ug/1 (State MCL) and benzene 1 ug/1 (State MCL).
-------
ROD FACT SHEET
Mannheim Avenue Dump Site
Galloway Township, New Jersey
EPA Region II
HRS Score - 36.56 (9/83)
NPL rank - 633
ROD
Date signed - 9/27/90
Remedy - Groundwater extraction with air stripping and discharge
via reinjection/infiltration
Capital Cost - $541,000
Annual O&M Cost - 52,000 (year 1)
394,100 (years 2-5)
360,100 (years 6-17)
18,600 (years 18-30)
Total Present Worth Cost - $4,217,100
LEAD
Enforcement
EPA/PRP
Primary EPA contact - Laura Lombardo (212) 264-6787
Secondary EPA contact - John La Padula (212) 264-5388
Main PRP - Lenox Inc.
PRP contact - Stephen Piotrowski, Director of Facilities
Engineering (609) 484-9521
WASTE
Type - VOCs (primarily TCE)
Medium - groundwater (shallow and deep aquifer zones)
Origin - asphaltic degreasing sludge (primary components - TCE
and lead)
Estimated Quantity - TCE plume in shallow aquifer zone is 100
feet long (including 400-foot diameter of the
site), 400 feet wide and 15 feet thick. TCE
plume in deep aquifer zone is greater than
1000 feet long, and is 1000 feet wide and 55
feet thick.
-------
DECLARATION STATEMENT
RECORD OF DECISION
MANNHEIM AVENUE DUMP SITE
and Location
Mannheim Avenue Dump Site
Galloway Township, Atlantic County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Mannheim Avenue Dump Site in Galloway Township, New Jersey,
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 1986 and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan.
This decision document explains the factual and legal basis for
selecting the remedy for this Site. This decision is based on the
administrative record for the Site. The attached index identifies
the items that comprise the administrative record.
Tv -Jew Jersey Department o-f Environra* ^^l Protection concurs with
wiie Selected Remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
threat to public health, welfare or the environment.
Description cf the Selected Remedy
The role of this response action is to address the principal threat
posed by the Site, namely, the presence of contaminants in the
groundwater. The groundwater contamination has the potential to
migrate towards, and adversely impact, downgradient residential
wells. This action addresses this threat by actively removing
contaminants from the groundwater and by controlling the migration
of the contaminants towards the residential wells.
-------
DECISION SUMMARY
RECORD OF DECISION
MANNHEIM AVENUE DUMP SITE
SITE NAME. LOCATION, AND DESCRIPTION
The Mannheim Avenue Dump Site (the Site) is located in a two-acre
sand and gravel clearing occupying lots two and three of Block 54
in Galloway Township, Atlantic County, New Jersey (refer to Figure
1). The Site lies on Mannheim Avenue between Shiller Road and
Clarks Landing Road. The Site is approximately 1500 feet southeast
of the Tar Kiln Branch and two miles southwest of the Mullica River
and associated tidal marsh (refer to Figure 2). The area
immediately surrounding the Site is relatively flat woodlands of
scrub pine and low bush. The area is within the New Jersey
Pinelands Protection Area. A sand and gravel pit is located across
the street from the Site and is owned and operated by Galloway
Township. At least 82 residences lie within a one-mile radius of
the Site. The Bethel Christian Day School is located within 5000
feet south of the Site. Many of these residences and facilities
rely on groundwater wells for potable water supply.
The Cohansey Sand and the Kirkwood Formation form an important
water-bearing unit used as a major source of potable water in the
area. At the Site, this unit is an unconsolidated deposit of sands
and gravels interbedded with clay. A semi-permeable clay layer,
a- oximately 3 to 5 feet thici . underlies the Site at
approximately 50 feet below ground surface. This layer s .-.,' ^s
the shallow zone of the aquifer system from the deeper zr ••& ':.
to Figure 3) . Throughout the region, this deeper zone extei.js wO
a depth of approximately 200 to 250 feet below ground surface to
a low permeability clay layer, which marks the lower boundary of
this aquifer system. The depth to water at the Site is
approximately 35 feet. In the shallow zone, groundwater flows in
a northwesterly direction towards Tar Kiln Branch. In the deep
zone, groundwater flows in a northeasterly direction towards the
Mullica River.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Mannheim Avenue Dump Site was originally used as a sand and
gravel excavation operation by Galloway Township for road
construction material. After mining operations ceased in 1964,
the excavated portions of the Site were used for waste disposal.
Beginning in 1964, Lenox China obtained permission from Galloway
Township to use the Site to dispose of industrial wastes produced
at its manufacturing facility in Pomona, New Jersey. The drummed
wastes were deposited on the floor of the excavated portion of the
Site, approximately 5 feet below ground surface, and subsequently
-------
2
The major components of the selected remedy include the following:
Extraction of the contaminated groundwater in the shallow and
deep zones of the aquifer system, with on-site treatment via
air stripping and discharge of treated groundwater into the
aquifer.
Short-term monitoring of the groundwater during the design
period to assess the potential migration of contaminants
towards residential veils.
• Long-term monitoring of the groundwater, once the
extraction/treatment/discharge system is operational, to
ensure the effectiveness of the system in removing
contaminants and controlling migration.
• Contingency planning to install individual carbon adsorption
treatment units at residences, if monitoring indicates that
groundwater contamination is threatening residential wells.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and expropriate to the remedial
&r ->n, and is cost-effective. Thi_ ..amedy utilizes pen^anent
solutions and alternative treatment (or resource n."--
technologies to the maximum extent practicable, and it .. ••tl^x. _
the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as their principal element.
Because this remedy will initially result in hazardous substances
remaining on the site above health-based levels, a review will be
conducted within five years after commencement of remedial action
to ensure that the remedy continues to provide adequate protection
of human health and the environment.
S •
Constantine Sidamon-Eristof f Date /
Regional Administrator
-------
In February 1990, Lenox, Inc.«s contractor submitted a FS Report
for EPA review and approval. EPA determined that this report was
incomplete and inappropriate for public release, and for preparing
a Record of Decision. Consequently, EPA tasked its contractor to
prepare a FS Report to develop and evaluate alternatives for
groundwater remediation more thoroughly.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI and FS Reports and the Proposed Plan for the Mannheim Avenue
Dump Site were released to the public for comment on July 17, 1990.
These two documents were made available to the public in the
administrative record maintained at the EPA Docket Room in Region
II and at an information repository at the Atlantic County
Library/Galloway Township Branch. The notice of availability for
these two documents was published in The Atlantic City Press on
July 17, 1990. A public comment period on the documents was held
from July 17, 1990 to August 15, 1990. In addition, a public
meeting was held on August 7, 1990. At this meeting,
representatives from EPA answered questions about problems at the
site and the remedial alternatives under consideration. A response
,to the comments received during this period is included in the
Responsiveness Summary, which is part of this Record of Decision
(ROD).
J,?Z AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The role of this response action is to address the principal -hreat
posed by the Site, which is the presence of TCE contamination in
the groundwater at, and emanating from, the Site. The groundwater
contamination has the potential to migrate towards, and adversely
impact, downgradient residential wells. The purpose of this
response action is to prevent current or future exposure to the
TCE-contaminated groundwater, to reduce TCE concentrations in the
groundwater to levels safe for drinking, and to control contaminant
migration towards the residential wells.
SUMMARY OF SITE CHARACTERISTICS
The Remedial Investigation for the Mannheim Avenue Dump Site
included sampling the surficial soil at the Site (after the waste
mounds were removed), the groundwater in the shallow and deep zones
on and off the Site, and limited sampling of the Tar Kiln Branch.
Surficial soil sampling indicated that lead was present in the soil
at concentration levels within EPA's acceptable range for
residential land use. This range is 500 to 1000 ppm, depending on
site specific circumstances.
-------
compacted into 35 waste mounds, along with other municipal wastes,
and covered with soil. Leaded porcelain fragments and household
refuse was also mixed in the waste mounds.
A 1981 industrial survey report submitted by Lenox China notified
the New Jersey Department of Environmental Protection (NJDEP) that
hazardous wastes may have been disposed of at the Mannheim Avenue
Site. The survey indicated that 55-gallon drums of trichloroethene
(TCE) degreasing sludge were disposed of at the Site and in other
locations. A subsequent investigation by NJDEP in 1982 revealed
that many of the 55-gallon drums were exposed and deteriorating.
Samples collected from the exposed drums indicated the presence of
the following chemicals: TCE at 1,640 parts per million (ppm) ,
toluene at 230 ppm, ethylbenzene at 350 ppm, methylene chloride at
220 ppm, cadmium at 22 ppm, lead at 2,600 ppm, nickel at 27 ppm,
and chromium at 6 ppm.
The Site was placed on the National Priorities List in 1983. In
December 1984, the U.S. Environmental Protection Agency (EPA)
issued an Administrative. Order to Lenox and the Township of
Galloway to remove the waste material buried in the soil mounds at
the Site, conduct soil and groundwater sampling, and excavate and
remove contaminated soil from the Site. By August 1985, Lenox had
completed the excavation of the waste material from the soil
mounds. Approximately 25,000 pounds of degreasing sludge were
separated from general trash and incinerated off site. Thirty-five
mounds of soil remained, many with residual contamination.
and 1986, Lenox conducted ^^j.1, groundwater, "• ririted
surface water, and domestic well sampling. This sampling, i •'
that the principal contaminants associated with the VE.£ .: e.c _ .^
Site were lead and TCE. Soil sampling revealed that lead was the
predominant contaminant remaining within the soil mounds (at levels
up to 48,000 ppm). Several of the mounds also contained small
fragments of the asphaltic sludge waste which could not be
separated from the soil during the initial excavation. These
mounds were assumed to contain TCE as well as lead contaminants.
Groundwater sampling on site revealed the presence of TCE (at
levels up to. 140 parts per billion (ppb) ) . Groundwater sampling
from residential and school wells, and from the nearby stream, did
not reveal the presence of any site-related contaminants. In June
1989, the 35 mounds of soil containing residual lead and TCE
contamination were excavated and disposed off site by Lenox.
In July 1988 and March 1989, EPA sampled the drinking water from
25 local residential wells surrounding the Site and one well from
the Bethel Christian School for volatile organic compounds (VOCs)
and metals. No VOCs or metals were detected above EPA's drinking
water standards.
In May 1988, EPA entered into an Administrative Order on Consent
with Lenox, Inc. and the Township of Galloway to conduct a remedial
investigation (RI) and feasibility study (FS) at the Site.
-------
Groundwater sampling of the shallow and deep zones of the aquifer
system (separated by a 3 to 5 foot semi -permeable clay layer at 50
feet below ground surface) indicated that TCE was the primary
contaminant impacting the groundwater. TCE was detected in the
shallow zone up to a concentration of 29 ppb. It is roughly
estimated that the entire length of the shallow TCE plume,
including the 400-foot diameter of the Site itself, is assumed to
be 1000 feet, with a width of 400 feet and thickness of 15 feet.
TCE was detected in the deeper zone up to a concentration of 47
ppb. It is roughly estimated that the deeper TCE plume length,
including the Site, is greater than 1000 feet, and that it is 1000
feet wide and 55 feet thick. Figure 4 illustrates the approximate
extent of the TCE plumes in the shallow and deep zones of the
aquifer system. The maximum contaminant level (MCL) for TCE,
established under the New Jersey Safe Drinking Water Act, is 1 ppb.
This MCL value of 1 ppb is the drinking water standard for TCE.
The areal extent of the TCE contamination in the shallow and deep
zones, as defined by the 1 ppb MCL, has not been completely defined
through sampling during the Remedial Investigation.
It is believed that the semi-permeable clay layer separating the
shallow zone from the deep zone may contain some TCE residues.
This TCE would potentially be slowly released from the semi-
permeable clay layer into the deep zone of the aquifer system. It
is also possible that the unsaturated zone may contain small
amounts of TCE residues, which would be slowly released into the
sh ow zone of the aquifer system.
Other contaminants, including volatile organics and
which were constituents of the original waste material,
sporadically detected in the groundwater in the shallow and deep
zones, in some instances at concentration levels exceeding federal
or state drinking water standards. The most prevalent of these
contaminants includes toluene, which is a volatile organic compound
(like TCE), and lead and chromium, which are inorganic compounds.
Toluene was detected at concentrations above the NJDEP groundwater
quality cleanup criteria of 50 ppb in four deep zone monitoring
wells during one sampling round. Concentrations o'f toluene in
these wells during other sampling rounds did not exceed 10 ppb.
Concentrations of lead and chromium, which exceeded the EPA
proposed cleanup guideline of 15 ppb for lead, and the NJDEP and
EPA drinking water standard of 50 ppb for chromium, were only
detected in one shallow zone well and in one deep zone well; The
highest concentrations of inorganics were not consistent between
sampling rounds per well and appeared to be sporadic. Neither lead
nor chromium concentration levels were detected in the groundwater
in statistically significant amounts, indicating the lack of
contaminant "plumes" of lead and chromium migrating from the Site
in the shallow and deep aquifer zones.
-------
Table l includes information regarding the concentrations of
compounds detected in the groundwater during the Remedial
Investigation in comparison to groundwater standards.
Surface water and sediment sampling at three locations along Tar
Kiln Branch indicated that lead was present in all three sediment
samples and in one water sample. The concentration of lead in the
water sample exceeded EPA's Ambient Water Quality Criteria for
lead. EPA believes that the Mannheim Avenue Dump Site is not the
source of the lead detected in the Tar Kiln Branch because sampling
of the shallow groundwater zone (which flows toward Tar Kiln
Branch) during the Remedial Investigation did not indicate that
lead was migrating from the Site. However, EPA will provide for
additional surface water and sediment sampling of the Tar Kiln
Branch to assess further, any adverse impact on the Tar Kiln Branch
from the Site.
Residential well sampling performed by EPA in 1988 and 1989
indicated that the wells were not impacted by contaminants
migrating from the Site. Fourteen residences are located
downgradient of the Site. Nine of these residences are
downgradient with respect to groundwater flow in the deep zone, and
five of these residences are downgradient with respect to
groundwater flow in the shallow zone (refer to Figure 4). All of
these residences use groundwater from the deep zone as a source of
drinking water. Groundwater in the shallow and deep zones has been
clarified by NJDEP as Class GW-2 groundwater, suitable for
f .--•jie, industrial or agricultural r '-.. supplies.
Potential pathways of migration for volatile organic and '~r~-«
contaminants associated with the Site include volatilization,
particulate emission, infiltration through soil to groundwater, and
groundwater discharge to surface water bodies such as the Tar Kiln
Branch and the Mullica River. Once contaminants enter the water
table aquifer (shallow zone), these contaminants are transported
in a westerly direction within the shallow zone, and vertically
downward through the semi-permeable clay layer, and then into the
deep zone where the contaminants are transported in a northeasterly
direction. The potential exists for contaminants to migrate from
the Site and impact residential wells adversely.
The possible residual TCE contamination in the subsurface soils in
the unsaturated zone and in the semi-permeable clay layer
separating the shallow zone from the deep zone could potentially
provide for the slow release of small amounts of TCE into the
shallow and deep zones.
-------
SUMMARY OP SITE RISKS
EPA conducted an Endangerment Assessment (EA) of the "no action"
alternative to evaluate the potential risks to human health and
the environment associated with the Mannheim Avenue Dump Site in
its current state. The EA focused on the groundwater contaminants
which are likely to pose the most significant risks to human health
and the environment (indicator chemicals). These "indicator
chemicals" and their concentrations in the groundwater are shown
in Table 2.
EPA's EA identified several potential exposure pathways by which
the public may be exposed to contaminants. These pathways and the
populations potentially affected are shown in Table 3. The
potential exposure routes identified and evaluated in the EA are:
• Dermal contact with contaminated groundwater drawn from wells
located downgradient from the Site;
Ingestion of groundwater from local wells downgradient of the
Site;
Inhalation of chemicals volatilized from groundwater during
home use;
Ingestion of chemicals that have accumulated in fish located
in a nearby river; and
• Inhalation of chemicals entering the air as particul--;
wind erosion.
The potentially exposed populations include residents and
recreational users. Soil sampling indicated that the
concentrations of lead in the Site soils were within EPA's health-
based cleanup level of 500 to 1000 ppm. Therefore, exposures to
Site soils were not considered further in the EA.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that the
toxic effects of the site-related chemicals would be additive.
Thus, carcinogenic and noncarcinogenic risks associated with
exposures to individual indicator compounds were summed to indicate
the potential risks associated with the potential carcinogens and
noncarcinogens, respectively.
Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses). Reference doses
(RfDs) have been developed by EPA for indicating the potential for
adverse health effects. RfDs, which are expressed in units of
milligrams per kilogram per day (mg/kg-day), are estimates of daily
-------
exposure levels for humans which are thought to be safe over a
lifetime (including sensitive individuals). Estimated intakes of
chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) are compared with the
RfD to derive the hazard quotient for the contaminant in the
particular media. The hazard index is obtained by adding the
hazard quotients for all compounds across all media. A hazard
index greater than 1 indicates that potential exists for
noncarcinogenic health effects to occur as a result of site-
related exposures. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media. The reference
doses and hazard indices for the indicator chemicals at the
Mannheim Avenue Dump Site are presented in Table 4.
The hazard index for noncarcinogenic effects from the Mannheim
Avenue Dump site is 5.7 x 10' and, therefore, indicates that
noncarcinogenic effects are unlikely from the exposure routes
evaluated in the EA.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by the EPA for the indicator compounds.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. "PFs, which are expressed in
• i-s of (mg/kg-day)', are multiplie- ~j the estimated intake of
a potential carcinogen, in mg/kg-day, to generate an upp ..- • .••-•i
estimate of the excess lifetime cancer risk associ. :e£ v
exposure to the compound at that intake level. The term 'upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes the underestimation of
the risk highly unlikely. The CPFs for the indicator chemicals
and the risk estimates for the site are presented in Table 5.
For known or suspected carcinogens, EPA considers excess upper-
bound individual lifetime cancer risks of between 10"4 to 10"6 to be
acceptable. This level indicates that an individual has one
additional chance in ten thousand to one additional chance in a
million of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year period under specific exposure
conditions at the site. The cumulative upper bound risk at the
Mannheim Avenue Dump Site is 4.1 x 10s. TCE is present in the
groundwater at concentration levels above federal and state
drinking water standards (MCLs). EPA has determined that the MCL
of 1 ppb for TCE should be met in the groundwater to be protective
of human health and the environment.
In summary, risks to public health include the actual or potential
risks to residents around the Site. Residents may be impacted
primarily through ingestion of potentially contaminated well water,
and dermal and inhalation exposures to volatile contaminants in
-------
8
well water while bathing and showering. EPA has determined that
actual or potential Site-related risks warrant a remedial action
for the Site.
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare or the environment.
Uncertainties
The procedures and inputs used to assess risks in this evaluation,
as in all such assessments, are subject to a wide variety of
uncertainties. In general, the main sources of uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry analysis error can stem
from several sources including the .errors inherent in the
a- . .tjcal methods and characteristics '* the matrix being sampled.
Uncertainty in the exposure assessment is related to the -re"-..
of potentially sensitive populations (school children ana
residents) in very close proximity to the site. Additional
uncertainties arise from estimates of how often an individual would
actually come in contact with the chemicals of concern, the period
of time over which such exposure would occur, and in the models
used to estimate the concentrations of the chemicals of concern at
the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the EA provides upper-
bound estimates of the risks to populations near the Site.
For more specific information concerning public health risks,
including quantitative evaluation of the degree of risk associated
with various exposure pathways, refer to the volume entitled Final
Endangerment Assessment for the Mannheim Dump Site located at EPA's
information repository at the Atlantic County Library in Galloway
Township, New Jersey.
-------
Environmental Risks
The environmental impact from the Site is expected to be low with
the exception of groundvater contamination in the immediate
vicinity of the Site. The only area potentially impacted by the
contaminated groundvater is the surface water and wetland areas
associated with the Tar Kiln Branch. The species composition of
the area along the Tar Kiln Branch has been classified as a
palustrine forested wetland with broad leaved trees. Although lead
has been detected in the sediment and water of the Tar Kiln Branch,
the environmental impacts associated with its presence are expected
to be insignificant. Additional sampling will be performed in the
Tar Kiln Branch to assess further, any adverse environmental
impacts from the Site. No federally listed or proposed threatened
or endangered flora or fauna are known to exist in the vicinity of
the Site..
DESCRIPTION 07 ALTERNATIVES
Appropriate remedial technologies identified during the screening
process of the feasibility study were assembled into combinations
to address the remedial action objectives and the goals listed
below:
Prevention of current and future exposure to TCE-contaminated
. 'oundwater;
Protection of uncontaminated portions of the groundw»i.e.i
being contaminated by preventing the spread of concaiuiiiztic .;
and
• Restoration of the contaminated groundwater to drinking water
standards for future use.
The remedial alternatives that were selected for detailed
evaluation are described below.
Alternative 1: Mo Action with Groundwmt«r Monitoring
Capital Cost: $ 89,100
Annual Operation and
Maintenance (O&M) Costs: $ 52,600 (years 1 to 5)
$ 18,600 (years 6 to 30)
Present Worth (PW): $ 550,100
Time to Implement: 3 months
The No Action alternative is evaluated at every site to establish
a baseline for comparison. Under this alternative, no active
action would be taken at the Site to prevent migration of, or
reduce concentration levels of, TCE in the groundwater. This
-------
10
alternative relies on natural attenuation of contaminants in the
groundwater for a reduction of TCE concentration levels to the MCL
of 1 ppb.
This alternative includes a long-tern monitoring program to assess
the migration of contamination in the shallow and deep zones of the
aquifer system. This program would use existing monitoring wells,
newly installed monitoring wells, and residential wells in the
vicinity of the Site. Selected wells would be sampled on a quar-
terly basis for the first five years, and then bi-annually. This
alternative also includes an educational program to inform the
public about potential hazards at the Site.
It would take about three months from the issuance of the ROD to
begin the implementation of the monitoring program. The reduction
in the annual 0 & M cost after the first five years of monitoring
is due to the reduction in frequency of monitoring and the number
of parameters analyzed.
The amount of time required for natural attenuation to reduce TCE
concentration levels to the MCL is not known at this time because
of the uncertainties relating to the presence and degree of
residual TCE contamination in the unsaturated zone and in the clay
layer separating the shallow zone from the deep zone. The
potential exists for this residual contamination to continue to
release slowly into the groundwater at an unknown rate and over an
unknown period of time.
Alternative 2: Point-of-Use Carbon Adsorption Treatment/Wi -
Restrictions
Capital Cost: $ 147,150
Annual 0 & M Cost: $ 52,600 (years 1 to 5)
$ 50,900 (year 6)
$ 32,000 (years 7 to 21)
$ 18,600 (years 22 to 30)
Present Worth: $ 739,400
Time to Implement: 1 to 3 months to install point of use
controls and 12 months for water use
restrictions
This alternative includes all of the components of Alternative 1,
with the addition of provisions to install and maintain individual
carbon adsorption treatment systems on household supplies, if
groundwater monitoring (performed on a quarterly basis for the
first five years) indicates that the TCE-contaminated groundwater
is migrating and threatening the residential wells. The carbon
adsorption system would remove TCE to meet the drinking water
standard. The treated water would then be used as needed by
residents. In addition, this alternative would place restrictions
on the installation of any new wells in the contaminated area
-------
11
around the Site. For any new wells installed in the contaminated
area, it would be required that treatment units be installed on
household supplies before the water is used for potable purposes.
For any new or existing wells installed downgradient of the
contaminated area, it would be required that treatment units be
installed on household supplies, if it were determined that water
quality was threatened by TCE contamination. These groundwater use
restrictions may, however, be difficult to implement and enforce.
Carbon adsorption treatment units and water use restrictions would
be considered for the fourteen existing and potentially six future
homes located downgradient from the shallow and deep groundwater
zones. The individual treatment systems and the water use
restrictions would be temporary and would be in place until
groundwater quality had been restored through natural attenuation.
The amount of time required for natural attenuation to reduce TCE
concentration levels to the MCL is not known at this time because
of the uncertainties relating to the presence and degree of
residual TCE contamination in the unsaturated zone and in the clay
layer separating the shallow zone from the deep zone.
It would take approximately one to three months to install the
residential carbon treatment units, once it is determined that
residential wells are threatened, and one year to establish water
use restrictions.
1..e -i.iiual 0 & M cost would generally -eurease during the 30-year
period because the frequency of groundwater monitoring anc •••
of parameters analyzed would decrease with time. The en. --si c-
for years 1 to 5 includes monitoring only. The cost for year 6
includes start-up plus operation and maintenance of the carbon
adsorption treatment units (estimated 15 years of use) and reduced
monitoring. The annual cost for years 7 to 21 includes operation
and maintenance of the treatment units and reduced monitoring.
The annual cost for years 22 to 30 includes reduced monitoring.
Alternative 3: Alternate Water Supply/Water Use
Restrictions
Capital Cost: $ 492,100
Annual 0 & M Cost: $ 52,600 (years 1 to 5)
$ 94,300 (years 6 to 30)
Present Worth: $ 1,749,200
Time to Implement: 18 months
This alternative includes all of the components of Alternative 1,
with the addition of the development of water supply well(s) and
a distribution system to provide potentially affected residences
with a continuous source of clean water. The distribution system
and capacity of the supply would be sized sufficiently to provide
-------
12
water to the fourteen existing and possibly six future residences
that could potentially be affected by TCE contamination. The
location of the water supply well(s) would be determined during
the design phase of the project and is expected to be placed south
of the existing TCE contaminant plumes and at the bottom of the
deep groundvater zone (approximately 200 feet below ground
surface.) Groundwater would be pumped to a storage or pressurized
tank and chlorinated prior to its discharge to the distribution
system. Construction of the supply and distribution system would
be performed up front, while actual hook-up would not be performed
until groundwater monitoring (performed on a quarterly basis for
the first five years) indicates that the contamination is migrat-
ing and threatening the residential wells.
Groundwater use restrictions would require that all existing and
future households be connected to this supply and that residential
wells be taken out of service, if groundwater monitoring indicates
that contamination is migrating and threatening residential wells.
These restrictions, however, may be difficult to implement and
enforce.
It would take approximately 18 months to design and construct the
new water supply well(s) and connect the residences to this system.
The annual 0 & M cost for the first five years is associated with
groundwater monitoring. Subsequent annual 0 & M cost would be
associated with operation of the new water supply/distribution
F" -m and reduced monitoring.
This alternative relies on natural attenuation of contar.-'nan-
the groundwater to reduce TCE concentration levels to the WCL. T:.<2
amount of time required for this natural process is unknown at this
tine because of the uncertainties relating to the presence and
degree of residual TCE contamination in the unsaturated zone and
in the clay layer separating the shallow zone from the deep zone.
Alternative 4: Groundvater Pumping/Air Stripping/Reinjection
Capital Cost: $ 541,000
Annual 0 & M Cost: $ 52,600 (year 1)
$ 394,100 (years 2 to 5)
S 360,100 (years 6 to 17)
$ 18,600 (years 18 to 30)
Present Worth: $ 4,217,100
Time to Implement: 6 to 16 years
This alternative includes the installation of groundwater extrac-
tion wells to withdraw the TCE-contaminated water for on-site
treatment with discharge through reinjection into the shallow and
deep groundwater zones. It was estimated that three extraction
-------
13
wells would be installed in each aquifer zone. Two wells in each
zone would be operated continuously and the third would serve as
a backup well during periods of well maintenance. It was estimated
that six reinjection wells would be installed in each aquifer zone.
Three wells in each aquifer would be operated continuously and the
additional three wells would serve as backups to be used during
maintenance periods. Contaminated water would be pumped from the
shallow zone wells and deep zone wells at estimated rates of 10
gallons per minute (gpm) and 40 gpm, respectively. It was assumed
that the contaminated extracted groundwater would need to be
pretreated to remove iron before being air stripped and discharged
to the groundwater. The groundwater extraction and treatment
system would be designed to reduce TCE concentration levels to the
MCL throughout the area of contamination in the shallow and deep
zones and would intercept contamination migrating towards
residential wells.
This alternative also includes short-term sampling of downgradient
groundwater monitoring wells and residential wells, during the
design period, to monitor the potential migration of contaminants
towards residential wells. In addition, this alternative includes
long-term sampling of downgradient monitoring wells and residen-
tial wells, once the system is operational, to monitor the effec-
tiveness of the treatment system in removing contaminants and
preventing migration.
T* ifferences in the annual 0 & M c .st over the 30-year period
are associated with the differences in the monitoring progr-r:? frrr
the residential and monitoring wells and treatment system d;
that time. The cost for the first year includes monitcri/.wj oni... -
The annual cost for years 2 to 5 includes operation and maintenance
of the treatment system (estimated 15 years of use) and monitoring.
The annual cost for years 6 to 17 includes operation and
maintenance of the treatment system and reduced monitoring. The
annual cost for years 18 to 30 includes reduced monitoring only.
It is estimated that the groundwater extraction and treatment
system can be designed and constructed in approximately 24 months.
The length of time required for this alternative to reduce
contamination levels to drinking water standards is approximately
six to sixteen years. This time period takes into consideration
the influence of the potential residual TCE contamination in the
unsaturated zone and in the clay layer.
During the design period, EPA would assess the feasibility and
practicality of using infiltration basins as an alternate means of
discharging treated groundwater to the underlying shallow aquifer
zone.
-------
14
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), a detailed analysis of each
remedial alternative is conducted with respect to each of nine
evaluation criteria. All selected remedies must at least attain
the Threshold Criteria. The selected remedy should provide the
best trade-offs among the Primary Balancing Criteria. The
Modifying Criteria were evaluated following the public comment
period.
Threshold Criteria
• Overall Protectiveness of Human Health and the Environment -
This criterion evaluates the adequacy of protection that the
remedy provides while describing how risks are eliminated,
reduced, or controlled through treatment, engineering controls
and/or institutional controls.
Compliance with Applicable or Relevant and Appropriate
Pegulrements (ARARs) - This criterion addresses whether a
remedy will meet all of the ARARs of other federal and state
environmental statutes and/or provide grounds for invoking a
waiver.
Primary Balancing Criteria
~ eduction of Toxicity. Mobility . or Volume fTMVJ Through
'^.'r^atrnent - This criterion addresses the anticipated t.~ .i*""s/it
performance of the remedy.
• Short-Term Effectiveness - This criterion refers to the speed
with which the remedy achieves protection, as well as the
remedy's potential to create adverse impacts on human health
and the environment during the remedial action.
Long-Term Effectiveness and Permanence - This criterion
evaluates the magnitude of residual risk and the ability of the
remedy to maintain reliable protection of human health and the
environment over time once the remedial action has been
completed.
• Implementability - This criterion examines the technical and
administrative feasibility of executing a remedy, including the
availability of materials and services needed to implement the
chosen solution.
• Cost - This criterion includes the capital and operation and
maintenance costs of the remedy.
-------
15
Modifying Criteria
• State Acceptance - This criterion indicates whether, based on
its review of the Feasibility Study and Proposed Plan, the State
of New Jersey concurs with, opposes or has no comment on the
preferred alternative.
*
Community Acceptance - This criterion evaluates the reaction
of the public to the remedial alternatives and EPA's Proposed
Plan. Comments received during the public comment period and
EPA's responses to those comments are summarized in the
Responsiveness Summary attached to this document.
Overall Protection of Human Health and the Environment
Alternative 4 protects public health and the environment because
it provides for the removal of TCE contamination from the
groundwater in the shallow and deep zones of the aquifer system to
meet the drinking water standard, and prevents migration of
contamination towards residential wells.
Alternative 1 is not protective of human health and the environment
because, along with Alternatives 2 and 3, it would not remove
contaminants from the groundwater in the shallow and deep zones of
the aquifer system, and thereby allows the migration of
cor^.minants' into clean portions if the aquifer. Also,
f .--ratives 1, 2 and 3 would r •'.. prevent the potential
contamination of residential wells from migrating TCE.
Alternatives 2 and 3, while not protective of the environ aen,.,
protect human health because they include treatment units on
household supplies and an alternate water supply, respectively, if
monitoring indicates the threat of contamination at residential
wells. Alternative 2, which provides for individual treatment
units on household supplies, would reduce concentration levels of
TCE in the groundwater withdrawn from the well to the drinking
water standard. Alternative 3 includes an alternate water supply,
which would provide affected residents with groundwater in which
TCE met the drinking water standard. In addition, Alternatives 2
and 3 include institutional controls to restrict exposure to
contaminated groundwater, however, these water use restrictions may
be difficult to implement and enforce.
Compliance with ARARs
New Jersey Groundwater Quality Criteria and Maximum Contaminant
Levels established pursuant to the Federal and State Safe Drinking
Water Acts are applicable federal and state groundwater
requirements for this remedial action.
-------
16
Alternative 4, in actively removing TCE contamination from the
groundwater and controlling contaminant migration towards
residential veils, satisfies the applicable drinking water standard
for TCE, the MCL of 1 ppb. The groundwater collection/
treatment/discharge system provided for under Alternative 4 would
be designed to meet the MCL of 1 ppb for TCE in the groundwater in
the shallow and deep aquifer zones and at the residential wells.
The air stripping would be done in conformance with state and
federal air emission standards.
Alternatives 1, 2 and 3 rely on natural attenuation of the TCE
contamination in the groundwater to meet the MCL eventually in the
shallow and deep zones of the aquifer system through dilution of
the volume of contaminants.
Alternatives 2 and 3 meet the ARAR associated with providing safe
drinking water to community residents. Alternative 2 accomplishes
this by removing the TCE, to meet drinking water standards, from
the withdrawn groundwater via treatment units installed on
household supplies. Alternative 3 accomplishes this by providing
an alternate drinking water supply which meets drinking water
standards for TCE.
Reduction of Toxicity. Mobility or Volume Through Treatment
/*..rnative 4 would reduce the toxif *y, mobility and volume cf
contamination in the shallow and deep zones of the aquife ^ --tern
by extracting TCE-contaminated groundwater and treating ?*• cc. .
the drinking water standard of 1 ppb.
Alternatives 1, 2 and 3 do not utilize treatment to reduce the
toxicity, mobility or volume of contamination in the shallow and
deep aquifer zones. These alternatives would not reduce the
mobility of the contaminants in the aquifer, and would rely on
natural attenuation, through dilution over time, to reduce the
toxicity and volume of contaminants. Alternatives 2 and 3 use
treatment via individual carbon adsorption units and an alternative
water supply, respectively, to reduce the toxicity and volume of
contaminants in the withdrawn groundwater prior to use by
residents.
Short-term Effectiveness
Implementation of Alternatives 1, 2, '3 and 4 would not create any
adverse short-term impacts on human health and the environment.
The time to achieve protection from contamination in the
groundwater in the shallow and deep aquifer zones is shorter for
Alternative 4 than for Alternatives 1, 2 and 3. Alternative 4
provides for active removal of the TCE contamination in the shallow
-------
17
and deep aquifer zones. Alternative 4 would include placement of
reinjection wells so that no adverse environmental impacts to the
nearby surface waters and wetlands would occur.
Alternatives 1, 2 and 3 rely on natural attenuation over time to
reduce TCE concentration levels in the groundwater in the shallow
and deep aquifer zones to the drinking water standard. The amount
of time required for natural attenuation would be influenced by the
potential for residual TCE contaminants in the unsaturated zone and
in the clay layer to continue to release slowly into the shallow
and deep aquifer zones.
Long-term Effectiveness and Permanence
Alternative 4 provides for permanent long-term effectiveness in
the protection of human health and the environment over time.
Long-term risks to workers during the remedial action do exist
through accidental ingestion of the contaminated water or
inhalation of air emissions from the air stripper. However, the
emissions would be controlled to below the state emission rate for
toxic substances. Exposure risks such as these would be mitigated
through proper health and safety protection. Air stripping is a
well-developed technology which is widely used for removal of
volatile organics in groundwater. The treatment system is very
re^-'-.ble but monitoring would be r-.rformed to ensure proper
t..j.Jtion of the air stripper.
With proper operation and maintenance, Alternatives 2 ?.n-. 3 *o; ^
permanently protect individual residents from drinking TCE-
contaroinated groundwater. However, these alternatives would not
prevent contaminants from migrating and adversely affecting clean
portions of the groundwater in the shallow and deep aquifer zones.
Alternative 1 does not provide for long-term protection of human
health and the environment over time. This alternative does not
actively contribute to restoration of the groundwater.
Uncontaminated groundwater currently used for drinking purposes may
be jeopardized in the future by the spread of contamination.
Implementability
All alternatives are implementable. Alternatives 1, 2 and 3 would
involve considerable long-term institutional management. Alterna-
tives 2 and 3 would require the cooperation of local residents and
administrative management to operate and maintain the point-of-
use treatment systems, and the alternate water supply and
distribution system, respectively, as well as the enforcement of
water use restrictions. The implementation and enforcement of
these restrictions may be difficult. The groundwater monitoring
-------
18
program included as part of each alternative would require some
administrative management and cooperation of local residents.
Cost
The total cost includes estimated capital and operation and
maintenance costs. The cost comparison for each alternative are
shown in Table 6. The present worth costs for each alternative
are summarized below.
Alternative 1: Present Worth Cost - $ 550,100
Costs include installation of additional groundwater
monitoring wells and 30 years of monitoring.
Alternative 2: Present Worth Cost - $ 739,400
Costs include installation of additional groundwater
monitoring wells, installation of individual
treatment units (15 years of use), and 30 years of
monitoring.
Present Worth Cost - $ 1,749,200
Costs include installation of additional
groundwater monitoring wells, installation of an
alternate water supply (25 years of use), and 30
years of monitoring.
Present Worth Cost - $> *,217,000
Costs include installation of additional g:
water monitoring wells, installation of c,iw-nc.wa_ .^
extraction/treatment/discharge system (15 years of
use) and 30 years of monitoring.
Depending upon the time for aquifer restoration, either through
natural attenuation as with Alternatives 1, 2 and 3, or through
active pumping with treatment as with Alternative 4, the costs
associated with long-term groundwater monitoring could be
significantly reduced.
Alternative 3;
State Acceptance
The State of New Jersey concurs with the proposed remedial action.
The Pinelands Commission has provided comments that have been
addressed in the attached Responsiveness Summary.
-------
19
Community Acceptance
The community was in favor of the preferred remedy. Questions and
answers raised during the public meeting are presented in the
attached Responsiveness Summary.
SELECTED REMEDY
EPA has evaluated the remedial alternatives in accordance with
Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and the
National Contingency Plan, and has chosen a remedy for the Mannheim
Avenue Dump Site based on the findings of the RI and FS Reports and
input by the public.
EPA has selected Alternative 4, groundwater pumping/air
stripping/reinjection of the treated water, as the most appropriate
remedy for groundwater remediation at the Site.
The major components of this action are as follows:
Installation and maintenance of a groundwater collection system
capable of capturing the TCE contaminant plumes in the shallow
and deep aquifer zones.
and maintenance of an ..: »ite groundwater treatmsnt
facility to remove TCE contaminants from the ct . i • •'
groundwater. This facility would consist of an air . • r: ..*•. .
with a pretreatment system for iron removal, if necessary.
Installation and maintenance of reinjection wells to discharge
treated groundwater into the shallow and deep aquifer zones.
An evaluation of the feasibility and practicality of using
infiltration basins in lieu of reinjection wells will be made
during the design period.
Short-term groundwater monitoring, during the design period, to
monitor the concentration of contaminants in the groundwater
and to assess potential migration of contaminants towards
residential wells.
Long-term groundwater monitoring, once the collection/treatment
system is operational, to assess the effectiveness of the system
in removing contamination and controlling contaminant migration.
Contingency planning involving the installation of individual
carbon adsorption treatment units at residences, if groundwater
monitoring indicates contamination is migrating towards, and
threatening, residential wells.
-------
20
• Surface water and sediment sampling of the Tar Kiln Branch to
assess further any impact on the Tar Kiln Branch from the Site.
Covering of the original waste disposal area with a layer of
clean fill to bring the Site up to grade.
The goal of this remedial action is to restore groundwater to its
beneficial use*. Based on information obtained during the Remedial
Investigation and on a careful analysis of all remedial
alternatives, EPA believes that the selected remedy will achieve
this goal. However, studies suggest that groundwater extraction
and treatment are not, in all cases, completely successful in
reducing contaminants to federal and/or state drinking water
standards in the aquifer. EPA recognizes that operation of the
selected extraction and treatment system may indicate the technical
impracticability of reaching health-based groundwater quality
standards using this approach. If it becomes apparent, during
implementation or operation of the system, that contaminant levels
have ceased to decline and are remaining constant at levels higher
than the remediation goal, that goal and the remedy may be
reevaluated.
The selected remedy will include groundwater extraction for a
period of approximately 6 to 16 years, during which time the
system's performance will be carefully monitored on a regular basis
and adjusted as warranted by the performance data collected during
or ition. Modifications may include
discontinuing operation of extraction wells in
cleanup goals have been attained;
• alternating pumping at wells to eliminate stagnation points; and
pulse pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into groundwater.
The evaluation of the groundwater pumping/treatment/rein ject ion
system presented as Alternative 4 was based on the data available
in the Remedial Investigation Report regarding the aquifer
characteristics at the Site. The data at the Site are limited
regarding the intercommunication of the two aquifer zones in
question, the precise extent of the TCE contaminant plumes, the
potential presence and degree of residual TCE contamination in the
unsaturated zone and in the semi-permeable clay layer, and some
geochemical parameters. Additional information will be required
prior to remedial design concerning the above data limitations,
along with pilot testing of the proposed treatment system.
Depending on this information, the number of extraction and
reinjection wells, the location of these wells, the pumping rates,
the time to reduce contaminant levels to drinking water standards,
and the costs, as presented under Alternative 4, could be affected.
-------
21
The following investigations need to be performed:
• Prior to design, further define the extent of TCE contamination
in the shallow and deep zones, if possible, down to 1 ppb. This
would be accomplished by installing and sampling additional
groundwater monitoring wells in the shallow and deep zones.
Prior to, and during design, construction and operation of the
treatment system, monitor the groundwater in the shallow and
deep zones for toluene, lead and chromium, which were
sporadically detected at concentrations exceeding drinking water
and cleanup standards during sampling for the Remedial
Investigation. If sampling indicates the wide-spread presence
of these contaminants at concentration levels exceeding drinking
water and cleanup standards, the groundwater treatment system
included in the selected remedy would be modified to address
these contaminants.
Prior to design, sample the unsaturated zone and the semi-
permeable clay layer in attempts to identify the potential
presence of residual contaminants, which could affect the
remediation time frame for the selected alternative.
Prior to design, conduct groundwater pump tests in the shallow
and deep zones to determine aquifer characteristics.
i the early stages of design, con uct an air pathway analysis
uo evaluate the need for off-gas controls on the air s^-
The capital costs for this alternative include instaij..- cion ;
additional groundwater monitoring wells and the design and
construction of the groundwater pumping/treatment/discharge system.
The total estimated capital cost for this alternative is $ 541,000.
The estimated annual costs are $52,600 for the first year (for
groundwater monitoring), $394,100 for years 2 to 5 (including
treatment and monitoring), $360,100 for years 6 to 17 (including
treatment and reduced monitoring), and $18,600 for years 18 to 30
(for monitoring only). The total estimate present, worth of
Alternative 4 is $4,217,100.
Should carbon adsorption treatment units be installed at
residential wells as a contingency measure, the capital cost of the
selected remedy would increase to $688,150. Annual operation and
maintenance costs associated with the individual treatment units
would be insignificant in comparison to annual operation and
maintenance costs of the groundwater pumping/treatntent/discharge
system under the selected remedy.
-------
22
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The selected remedy provides for protection of human health and
the environment by actively removing TCE contaminants in the
shallow and deep aquifer zones to meet the drinking water standard,
by preventing the spread of contaminants into uncontaminated
portions of the aquifer, and by controlling migration of
contamination towards residential veils.
If monitoring indicates that the contaminated grpundwater is
threatening residential wells, either during the design period or
after the collection/treatment/discharge system is operational,
the contingency to provide residences with individual carbon
adsorption treatment units would become effective.
Implementation of the selected remedy will not pose unacceptable
short-term risks or cross-media impacts.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy complies with applicable or relevant and
appropriate requirements. This remedy would serve to reduce TCE
contamination in the groundwater to the applicable drinking water
st^'-'.ard, which is the MCL established under the New Jersey Safe
r _.-. ::ng Water Act. Air stripping wil" * ; done in conformance with
New Jersey State and Federal air emission standards. Any c .'• "^r*
produced from treatment of groundwater would be handled ' --.co1* .
to New Jersey State Sludge Quality Criteria Guidelines and Fe.ter-i
Hazardous Materials Transportation Act. Discharge of treated
groundwater will be done in conformance with the New Jersey State
Pollutant Discharge Eliminantion System and with Federal Safe
Drinking Water Act underground injection standards. RCRA 40 CFR
Parts 261 to 264 and 268 Standards would be met. In addition, the
selected remedy would satisfy provisions of the Federal Wetlands
Executive Order, the Wild and Scenic River Act, and the Coastal
Zone Management Act. The selected remedy would also satisfy
provisions of the New Jersey Coastal Area Facilities Review Act,
Rules and Coastal Resources and Development Act, New Jersey Wild
and Scenic Rivers Act, and Freshwater Wetlands Protection Act
Rules.
Cost-Effectiveness
After evaluating all of the alternatives which most effectively
address the principal threat posed by the contamination at the
Site, EPA has concluded that the selected remedy is cost-effective
in that it affords overall effectiveness proportionate to its
costs.
-------
23
Utilization of Permanent Solutions and Alternative Treatment for
resource recovery) Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable.
The selected remedy provides the best balance of trade-offs among
the alternatives with respect to the evaluation criteria. The
selected remedy provides for the most long-term effectiveness and
permanence of the alternatives. The selected remedy provides for
the most reduction of toxicity, mobility and volume of TCE
contaminants through treatment than the other alternatives, which
rely on natural attenuation to reduce TCE concentration levels in
the aquifer. The air stripper is expected to remove greater than
98 percent of the TCE from the groundwater. Mobility of
contaminants would not be reduced under the other alternatives.
The selected remedy provides for the restoration of the
contaminated groundwater to the drinking water standard for TCE in
a faster time frame than the other alternatives. The selected
remedy is implementable and is the most cost-effective of the
alternatives.
The selected remedy was preferred over the other alternatives by
the community members, who favored an alternative that would
restore groundwater quality in the shortest time frame and prevent
th-- -spread of contaminants towards residential wells.
The selected remedy meets the statutory requirement to .-- '''•"*>.
permanent solutions and treatment technologies to thr m?"*.
extent practicable.
Preference for Treatment as a Principal Element
The statutory preference for treatment as a principal element is
satisfied in the selected remedy. The selected remedy includes
air-stripping of the extracted TCE-contaminated groundwater which
would treat the groundwater to the drinking water standard.
Documentation of Significant Chances
The public expressed concern over the possibility of TCE
contaminants migrating and adversely impacting residential wells
before the implementation of the groundwater pumping/
treatment/discharge system. In response to this concern, EPA will
monitor the migration of the contaminants in the groundwater
(including sampling residential wells) during the design period
prior to implementation of the groundwater treatment system. EPA
will also monitor the groundwater once the treatment system is
operational. If monitoring indicates that the contaminants are
migrating and threatening residential well water quality (on an
-------
24
-------
MANNHEIM AVENUE
J APPROXIMATE LOCATION Of APRIL 16, IM6 SAMPLING POINT
APPROXIMATE LOCATION AND DESIGNATION OF MAY 9, 1990
*•' SAMPLING POINTS
szooorT
c
i.
GERAGHTY
r kTLLER, INC.
LOCATION MAP, Monnhcim Avenue Site,
Gollowoy Township, New Jersey
FIGURE
1
1
-------
Mannheim Avenue Site
Galloway Township, New Jersey
• • approximate location
of houaa and lot
MANNHEIM
AVENUE SITE
'Mulltea'River
Adaptad lor Boor. Alton A Hamilton Inc. from Map By Geraghty A Millm. Inc '
FlRurc 2
-------
A -
N
^^P^^^. fO-
"T — j"
•0-
Ul
Ul
J
UJ **"
in
2
3
INPEETPELATIVETOM
f f
z
o w—
p
Ul
10-
0-
-IO-
/ITX A/1^A ^* MAMNMIIM VTNlir SITF «~j MANNIITIM
' ^/^IJIs 1 ""' ^, / -• C R A V C I Pit —
' !/
^s xx r^vj r~p xx r^-j
_.-•-• "* V
\_- — r" —
D C3r=exxxxF:i_
FICVAIKM Of
firVATWN Of S«f A<* IN
VATTM IAMI Oil PI R HOW •
(JUtT 31. I»M) SrSftM
^ (JMV Ji. ft«*t
V / /
— — — y-
sxxr^cr
0 . fOO 200 300 401
Scute
CDM - Federal Programs Corporal ion
"-^^^^^rr-rr-
> xx f\i m> en? r^ xx \x EH i
9 500
1 not
- A 1
WM
70
- SO
- HO
- 30
- JO
— to
- o
figure J
Hydrogcologic Cross Secti«ft-A 1
^i^
Mannheim Avenue Site, Galloway Township. Now Jorsey
-------
E AVENUE
D
L
D
D
MANNHEIM AVENoE ! I
D
1
—y^- F..2W IN SHAL.DV
DIRECTION Dr GROUND-WATER
IN DEEP AQUIFER
APRDXIMATE LINE Of E3UAL
TR1CHLDRDETHENE '
IN PARTS PER BILLION
IN THE DEEP A3JIFER
APRPXIMA'E LINE OF EQUAL
CONCENTRATION OF
TRICHOLORQETHENE
IN PARTS PER BILLION
IN THE SHALLOW
MANNHEIM AVENUE DUMP
GALLOWAY TOWNSHIP,
NEW JERSEY
EXTENT OF Figure
TRICHLOROETHENE 4
IN DEEP AND SHALLOW
AQUIFER 99C
-------
TABLE 1
GROUND WATER CONTAMINANTS O>M iJSON TO STANDARDS
MANNHEIM AVF.NUI.. .I'VE
GALLOWAY TOWNSHIP, ''.->; JERSEY
No. of occurence
Compound
Benzene
Ethylbenzene
Methylene chloride
Toluene
Tr ichloroethene
Arsenic
Barium
Beryllium
Cadmium
Chromium •
I ron
Lead
Manganese
Nickel
Thallium
No. of samples
3/65
7/65
7/65
25/65
49/65
7/60
14/14
9/60
7/60
34/60
14/14
48/60
14/14
3/60
2/48
Range
0.1 J
0.2 J
0.45 -
0.2 J
1-47
1-5.
19.6 -
0.5 -
3.5 -
5.7 -
379 -
1.6 -
1J.9 -
19.8 -
2-2
(ppb)
- 1.9
- 17
12
- 300 J
4 J
110
101 J
7
359
15,200
342
1,209
54.6
Standard (ppb)
l.O1
700 (MCL proposed-EPA )
2'
502
I1
50l
10001
0.00371
10l
50'
300'
15"
•so1
I'J.^
17. a*
No. of samples
above standard
1
0
4
5
49
0
0
9
0
4
14
4
4
3
0
Percent
above standard
1.5
0
6.2
7.7
75
0
0
15
0
6.7
100
6.7
28
5
0
-------
TABLE 1 • j> ficinued)
1. New Jersey Safe Drinking Water Act MCL
2. NJDEP Groundwater Quality Clean-up Criteria
3. NJPDCS toxic effluent limitations for protection of potable water
4. Secondary Drinking Water Standard (Federal Safe Drinking Water Act)
5. EPA Ambient Water Quality Criteria for the Prote< tion of Human Health
6. EPA Proposed Clean-Up Guideline
* Includes duplicates as individual samples and includes both data collected by
G&M and splits by FPC during 1989.
-------
Metals
Arsenic
Berylium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Thallium
Zinc
TABLE 2*
SUMMARY STATISTICS OF UNFILTERED GROUND WATER DATA1
(SOccurences)/
(* of Samples)
6/32
4/32
4/32
20/32
29/32
29/32
3/32
2/32
5/32
2/32
32/32
Volatile Organic
Compounds
Chloroform 28/32
cis 1,2 4/32
dichloroethane
ethylbenzene 3/32
methylene chloride 2/32
toluene 8/32
trichlo- yi-2ne 27/32
o,m,p-xylenes 4/32
Concentration
Range (ppb)
0.05-6.7
0.5-3.4
4.7-7.0
5.5-359
3.7-124
1.15-342**
0.24-1.0
28.5-54.6
2.0
2.0
5.45-124
0.5-5.65
0.5-1.3
0.55-2.7
9.15-11
1.0-200
1.0-47
0.9-12.0
Appropriate
Standard (ug/L)
50^
NA
10
502
1,
Number
of
Exceedences
3
3
2
5.0003
10Q8
70*
7006 (proposed)
2 :,po7
44
Ari th/Geo
Mean (ppb)
2.14/0.94
1.7/1.3
5.73/5.65
36.89/13.89
14.15/8.74
17.74/5.28
0.58/0.49
41.55/39.45
2/2
2/2
22.54/16.86
2.12/1.91
1.01/0.95
26
1.48/1
10.08/:
63.36/21
12 65/7.J9
.. ti
m
1. Each veil sampled on tvo different dates; replicates not included in this column;
estimates disregarded
2. Primary Drinking Water Standard. Source 40CFR Part 265, Appendix III
3. Secondary Drinking Wa'ter Standard. Source 40CFR Part 143.3
4. EPA Ambient Water Quality Criteria for the Protection of Human Health
5. U.S. Public Health Service Potable Vater Standards
6. Safe Drinking Water Act MCLs
7. Safe Drinking Water Act MCLGs
8. Currently Regulated Under Total Trihalomethanes (U.S. EPA Drinking Water Hotline)
9. New Jersey Safe Drinking Water Act MCLs
10. EPA Proposed Clean-Up Guideline
* This table has been updated from Table 1-10 in the Endangerment Assessment Report
for the Mannheim Avenue Dump Site, prepared by CDM Federal Programs Corporation, dated
July, 1990
** The value of 342 ppb replaces the previously reported value of 85,600 ppb.
(TV 28/22)
-------
TAJ.! 3
AT THE iuiit».£)ii AVUJE S;T£
*? AM; rinusf LAHS U
>e:e-.t'»'. ly Cxpcf."f tawte, aftfikr,
I*rc$f-i ••£ Evpctj^t »eint
»atn«iy
Selected fer lessor,
les''ee-.:s Dei^l eortist tc'th
witrr
frer *«:
fror tnt
»ite.
Tts tesibeits ere: or
fresi*^ wate* free.
wells for domestic utt.
stio* e' 8'*"^ witer
f-sr le;«! vc'.li oo^--
8'ii->it e^ tn* site.
Tts t»«i»«-tt UK*
«rstr> frer ««1 Is «s
in; •«:(-.
vilitiliire
ki:e' O--in; hone me
Tes San* e< the ehr-;s«:$
e* pe:ei:i»! esice-r. ir.
(•evni inter »re
velititf, »nc fsj^d
•»!*• it u»K 6y leca:
I *: • e e'. •'
Uses
f's" tc:s:ec ir, •
rive*.
i!s Tes let: in site ssiti *••';••
K ir. re»i* tft* rive* via
n-ty stenr rirw'f. Intakes
tw: re risis
C*:t.se U££*4
has net rtach a final
decision en !«:», slept
factors.
tfie tir as
tts via wind
tresie."..
Tts ttii in cite ceils r:s".:
icpese r»»io*-.:s via
•ir. Intakes assessed
feut risks net a-iaiti*ietf
UJE»i has net
a fina!
decision art IfCt. Slope
factors.
-------
TABS.E 3 CWT'O.
OF
AT THE MANMMEIM AVEk.'E $:TE FOR
CJR8EK7 AN5 FUTURE LAW? USE
Pete-.t;a'. iy Eipcs.-e Isute, t»«
Exposed a-C Exposure Point
iC».'. etiei
Selected for
Cvttuition?
leissn fer Selection
or Exclusion
tes;ce-:s Direct contact with
Wsrke-s cheffic»t$ o< potential
concern in seiI on the
cite.
No lead in site »e;l may be
•Store*-: by children
and workers. Lead in
toils is within USEPA
clean up goal.
Ir,jive-te-t ingestior.
pete-.tia'. :y cs"ta^.''na:
tz:. I e- the site.
No Lead in site soil may be
ingested by child-e-
and workers. Lead in
•cits is within USES*
clean uc 91*1.
k::e: T'-'s s::e :'s c^rre-.tly owed fcy a inr.icipality.
T-e i:.zce-t «-ea is ee»e:ir*d fir lim-ltetf resioer.tial
use. Tr-e «.t.-e use e1? tr.is p-sperty is ide-.tified
as res::e-:ial fcr tr>e pcrpcses o^ tnis eneanjerrnent
assess"**:.
-------
Table 4
CAUMAIION Or CHRONIC HAcARO INulCfS
ASUMING IRIVAUNf fC^IIIM
AND USIMf. IHf I* IS 0 IASE
MANMHt IN CHMP
Chemical
Cact.1.,.
Chroalua III
Copper
lead
Mercury
Nickel
line
CM or of or*
els 1.2 dlchl or oethene
loluene
I rlchlor oethene
Mlied Mytenes
NA/ARO IMDfM
total
Oral/Deraial
cm
(aq/kg/doy)
/2.AA6-04
2.»0f-01
t.ltt-OI
B.aif-04
l.lfic-ns
I.Wf 01
2.6%r-01
2. VII 04
9.40C-OS
2. 041-01
».?Sf 01
1. 11( -04
He • it *lil e
Intake
RfOo
-1
5. nor -04
I.OOf «00
(a)
<•>>
(c)
(«l|
fd)
1. ItOC -02
fal
S.IHW-OI
(c)
2.onr«oo
Or.l/Oen-1
••Ho
COI:RfOo
9.32E-OI
2.00C 01
•
*
-
•
-
2.911-02
•
9.471-01
•
A.AU-OT
S.Hf-OI
Notes:
(•) moo not •v«M««.le
) (PA has rirmml that MI llfOo Miy tie Iniipproprlale for Inorganic lead
(c) llnrier rewleu Ify (PA at this I la*
(d) Not foinl In IRIS
Itie atnorptlon Mas asiinml to he 100X for aiWInlsterrtt
-------
Table 5
«U»K*E1» »IP; SITE
I!SC IPIIUTES F08
IT EXIOSJKE
us:»: THE IDS
Miter DtrMl Oral Total
lnc,ettiori Afrieptiori Slope C**--.c»\-
C! C! factor Specific
" litk
CMD-e'e-rr 1.?*!-W S.WE-07 *.101-03 7.5ȣ-C7
Trier,.e-cwt^r-* $.3SE-&i 1.ME-06 1.10E-02 5.90E-06
iHHAJkTIOk »ATNV1T
liVii'.ation Total
Slope C*tftieal-
Fact:* Specific
* ti«k
C-:t-c':- 2.23E-U B.10E-C2 1.B'.£-C5
:-•:?'..s-se:k«^e e.6*E-Ci 1.TOE-C2 1.63E-C5
TCTA. i:st
Cra:/5*-rj'. Iry.alatio-. Teta'.
Cftr?:sal- Cher-.-ea!- Cfie^isa'. •
Se»:ific Specific Specific
C-*^ :i. litk titk lut
CMe-t'i-r 7.59i-:T 1.8TE-C5 1.ME-CS
Trisvs-s«fe-e 5.*3E-Oe 1.63E-C5 2.22E-CJ
T:*A.
TH:J J:TE
4.10E-C5
festes:
C: if be'ir*d at th» ehrorie daily intake in vr.it> ef a^/kg/flay.
0-a:/5t-a*i rtfr*s te thi ax of the ingtiricr. «"C det«l patr.«ars.
Tht oral a-e ir^,a!ation dope factors rtpc-trl fo* Triehtoro«thtne
**•* take- fror tft« xei'T1- r
-------
TABLE 6
COST SUMMARY TABLE FOR REMEDIAL ALTERNATIVES
Remedial Alternatives Capital
for Groundwater Costs
Annual Operation Total
and Present
Maintenance Costs Worth
Alternative 1 -
No Action/Monitoring
89,100 52,600 (years 1-5) 550,100
18,600 (years 5-30)
Alternative 2 -
Point-of Use Carbon
Adsorption 'Treatment/
Water Use Restrictions
147,150 52,600 (years 1-5)
50,900 (year 6)
32,000 (years 7-21)
18,600 (years 22-30)
739,400
3 -
Alternate Water Supply/
Water Use Restrictions
492,100 52,600 (years 1-5) l,n'.r..?CO
94,300,(years 6-30)
Alternative 4 -
Groundwater Pumping/Air
Stripping/Reinjection
541,000 52,600 (year 1) 4,217,100
394,100 (years 2-5)
360,100 (years 6-17)
18,600 (years 18-30)
-------
RESPONSIVENESS SPXKXPY
RECORD 07 DECISION
KAHKEZIM AVENUE DUKP BITE
I. Introduction
The Mannheim Avenue Dump site is located in a two-acre sand and
gravel clearing-on Mannheim Avenue in Galloway Township.
Originally, the site, which is owned by Galloway Township, was
mined for sand and gravel for the construction of township roads.
During the mid-1960s, Lenox China, a potentially responsible
party for the site, disposed of waste materials in the excavated
portion of the property. The site was placed on the National
Priorities List of uncontrolled hazardous waste sites in 1983.
Lenox China removed the waste materials from the site in 1985,
under an administrative order issued by the U.S. Environmental
Protection Agency (EPA), and conducted a Remedial Investigation
and Feasibility Study (RI/FS) at the site, under an
administrative consent order issued by EPA in May 1988.
In accordance with EPA's community relations policy and guidance,
and the public participation requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended, the EPA Region II office established a public comment
period from July 17, 1990 to August 15, 1990, to obtain comments
on the Proposed Plan for the Mannheim Avenue Dump site.
r- ..-crust 7, 1990, EPA held a public «.^uing to receive public
consents on the proposed remedy. Approximately 20 communi y
residents and interested persons attended the meeting. L.pi^s . .
the Proposed Plan were distributed at the meeting and placed in
the information repositories for the site.
The Responsiveness Summary, required by the Superfund Law,
provides a summary of citizens' comments and concerns identified
and received during the public comment period, and EPA's
responses to those comments and concerns. Section II of this
document presents a summary of the significant questions and
comments expressed by the public, either verbally during the
public meeting or in writing, concerning the proposed remedy
selection.. Section III of this document presents a summary of
the significant questions and comments concerning the proposed
remedy selection, submitted in writing by Eder Associates
Consulting Engineers (Eder), on behalf of Lenox, Inc., and The
Pinelands Commission. Each question or comment is followed by
EPA's response. All comments expressed to EPA were considered in
EPA's final decision for selecting the remedial alternative for
addressing the groundwater contamination.
Attached to this Responsiveness Summary are four appendices.
Appendix A includes all written comments received during the
comment period. Appendix B contains the Proposed Plan for the
-------
remedy. Appendix C contains the sign-in sheet of attendees at
the August 7, 1990 public meeting. Appendix D contains the
public notice issued to the Atlantic City Press, printed July 17,
1990, announcing the public comment period and availability of
the Remedial Investigation and Feasibility Study and Proposed
Plan for public review.
II • pimrcB^rv of ComTPunitY Comffents and BPA Re
This section contains verbal and written questions and comments
received from the community during the public comment period.
Comments contained in this section are grouped according to the
subject discussed.
A. Proposed Plan and Future Site Actions
1. A resident asked bov the proposed remedy would control the
spread of the plume/ and where wells would be placed to
control the spread of contamination.
EPA Response: The extraction veil system will be designed to
control the spread of the plume and to capture the
contaminated groundwater. The extraction wells would be
placed in specific areas to withdraw the contaminated water
from both the shallow and deep aquifer zones, as effectively
and efficiently as possible, thereby minimizing the intake of
nean water. Before determining the number and placement of
, -inaction and reinjection wells ar .^e pumping rates for
each well, additional tests will be conducted. It is
anticipated that groundwater would be reinjected downg id-'-..
of the contaminant plume in the shallow zone in an area which
will not affect the Tar Kiln Branch. In the deep zone, it is
anticipated that treated groundwater would be reinjected into
areas upgradient of the deep zone contaminant plume.
2. A resident asked how fast the contaminant plume is spreading,
what effect the weather would have upon the spread of the
plume, and what effect the reinjection of water into the
aquifers would have upon the effectiveness of the proposed
treatment system. The resident also requested that another
test be conducted, so there would be a second reference point
for evaluating the spread of the plum* over time.
EPA Response: The groundwater flow rate within the shallow
zone is approximately 0.6 feet per day; and in the deep zone,
approximately 1.4 feet per day. The contaminants in the two
aquifer zones do not necessarily flow at the same rate as the
groundwater. It is not known at this time the rate at which
the contaminants move within the aquifer zones. Weather would
not have a significant effect on the spread of the
contamination. It is possible that excessive rainfall could
-------
create a small amount of dilution and spreading of the
contaminants in the shallow zone. With respect to the effect
reinjection of treated water into the aquifer zones would have
upon the proposed treatment system, the reinjection wells
would be placed in a location so as not to interfere with the
extraction wells' withdrawal of contaminated groundwater.
Additional groundwater sampling will be performed to evaluate
the spread of the contaminant plume over tine.
3. A resident was concerned about the possibility of site
contaminants reaching residential veils prior to sit* cleanup/
and if preventive measures could be taken.
EPA Response: Yes, preventive measures can be taken. Such
measures may not be necessary, however, because the
groundwater remediation system would be designed to prevent
the spread of contamination. Residential wells would be
monitored for contaminants both before and during the
operation of the groundwater remediation system. In addition,
monitoring wells will be installed between the residences and
the site. Monitoring the groundwater would enable EPA to
determine whether the contamination is spreading to the homes.
In addition, EPA will be sampling homes within the next few
months, and will continue to sample them periodically
throughout the design phase to ensure that the contamination
is not threatening residential wells. EPA has added a
contingency plan to the selected remedy in the Record of
Decision (ROD), to provide residences with individual carbon
adsorption treatment units, if it ."ppears that the
-ontamination is spreading and thr ••taning these residences.
4. Another area resident asked about the estimated time :>STi
State acceptance of the Proposed Plan, EPA selection of tne
final remedy, and the implementation of the final remedy.
EPA Response: EPA has conferred with the New Jersey
Department of Environmental Protection (NJDEP) regarding the
Proposed Plan and provided the Department with a draft copy of
the ROD. The NJDEP concurs with the proposed remedial action.
Regarding the time frame for implementation of the final
remedy, EPA estimates that the groundwater remediation system
will be operational in approximately twenty-four to thirty
months from issuance of the ROD. This time will be spent
negotiating with the potentially responsible parties to design
and implement the selected remedy, conduct pre-design field
work, and design and construct the groundwater remediation
system.
-------
5. Several residents Bads ths comment tbat tb«y agreed vith the
•election ef Alternative Four for cleaning up the sit*.
EPA Response: EPA thanked the residents for their support of
the proposed remedial action.
6. A local resident vhoss well bad b«an tsstsd asked whsrs tbe
plum* of contamination vas flowing. In addition, ths resident
asked whether charcoal filters used in boas treatment devices
are similar £o tbe carbon adsorption treatment systems
included under Alternative 2, as described IB tbe Proposed
Flu.
EPA Response: In the shallow zone of the aquifer system, the
groundwater contaminant plume flows in a northwesterly
direction, towards the Tar Kiln Branch. In the deep zone, the
groundvater contaminant plume flows in a northeasterly
direction, towards the Mullica River.
Charcoal filters are used to improve the aesthetic quality of
the water, namely, the taste and odor. Also, in theory,
charcoal filters may remove some volatile organics, if
maintained properly. Such filters would not be effective in
removing trichloroethene (TCE) contamination from the water
down to the drinking water standard of 1 part per billion
(ppb). The carbon adsorption treatment systems presented
under Alternative 2 would remove all of the TCE in the water
down to the level of 1 ppb. EPA has added the use of carbon
adsorption treatment units to the selected remedy, as a
-^ntingency measure, if monitoring i~
-------
detected in a monitoring well located north of the site, on
the same side of Mannheim Avenue as the site.
8. A resident who attended the public •••ting provided EPA with
written comments regarding tbe proposed remedial alternative.
In tbe comments, the resident commented that the width of the
deeper aquifer plume is directly related to the length of the
shallow aquifer plume, since the tvo aquifers are connected
through the semi-permeable, 3-to-5 foot clay layer. As the
shallow plume* moves to the Tar Kiln Branch, the deeper plume
will expand simultaneously in the same direction, on its way
to the Mullica River. The resident further acted that this
posed a potential threat to more veils than stated at the
meeting and that time is of the essence to implement
Alternative 14.
The resident also requested in his letter that KFA use a
three-dimensional flow model to get a better understanding of
the change in size and concentration levels of the
contamination plume over .time. Ha added that measurements
taken at both existing and additional wells over a period of
time, will help in determining the modeling coefficients. The
retardation coefficient in the flow model should be a
variable, not a constant, that changes with the concentration
level. Example: 1 for < 1 ppb and > 2 for > 10 ppb.
EPA Response: A three-dimensional flow model will be
developed during the design phase. Additional investigations
v be performed prior to design wi3 * provide the data to be
used in the flow model.
B. General Comments
1. A resident who lived near the site commented that trash (such
as carpets and wallboard) is being dumped in an area behind
the site, outside the fence surrounding the site. The
resident asXed whether the access road around the site could
be barricaded, and whether the fence could be taken down and
the site revegetated and regraded. The resident added that
EPA should consider taxing such action ia its Proposed Plan.
EPA Response: It appears that the illegal dumping is
occurring on property owned by the township. EPA advised the
resident to contact the township for resolution of this
matter. Regarding the access road and the fence, EPA cannot
barricade the road nor remove the fence at this time. The
site has not been totally cleaned up yet, and portions of the
treatment system may need to be located within the fenced
area. Regrading the site is part of the selected remedy.
-------
2. An attend** at tbt public •••ting acted in bis written
comments to IPX that Alternative 2 in the 78 refers to "Point-
of-Use" carbon filters, although it actually describes "Point-
of-Entry» carbon filters. A point-cf-use filtar is attached
to the drinking supply at the point-of-use, in this case/ a
faucet. Ee commented that Alternative 2 should be implemented
on an interim basis (i.e., 1-3 years) until Alternative 4 is
operational.
EPA Response:. The carbon adsorption treatment units included
under Alternative 2 are actually "point-of-entry" devices,
which would be installed in the home to serve the entire
household supply. The Selected Remedy includes the
installation of these treatment units, if contamination were
migrating towards, and threatening residential wells, either
during design or operation of the groundwater remediation
system.
3. One local resident who attended the public meeting wrote to
EPA asking when his water would be retested. Ee commented
that the meeting on August 7 was good and that be was
anticipating the implementation of Alternative 4. The
resident also asked whether be could build on two lots next to
his house without restrictions.
EPA Response: EPA is planning to sample select residential
and groundwater monitoring wells in October or November of
1990. Regarding whether the resident could build on two lots
next to his house, the resident should inquire about any
strictions at the township, count » »»id state offices,
especially regarding the installation of residential dr' -'«-'-^
water wells.
III. Summary of Comments from other Interested Parties and EPA
Responses
This section contains written questions and comments received
from Lenox Inc., the potentially responsible party, and The
Pinelands Commission.
A. Comments from Lenox, Inc.
Eder Associates (Eder), a consultant to Lenox, Inc., reviewed
the Feasibility Study Report (F6) prepared by EFA's contractor
and raised issues concerning the development and evaluation of
the remedial alternatives presented in the FB, as discussed
below.
-------
1. Eder agreea with the 78 stateaent that one reaedial action
objective ia to protaet uncontaninated groundvater. Bder does
not believe that tha TB preaenta tha technical juatifieation
to aupport tha ooncluaion that a pump and traat ayataa vill
remediate tha aguifar to tha 1 ppb laval for triohloroathene
(TCE). Bder notad that tha 78 altarnativaa ara baaad on
Bodaling dona to datamina vhathar it vould ba poaaibla to
achiava a 5.0 ppb TCE concantration in tha aguifar.
Tha 78 and th*a IPX'a Record of Daciaion (BOD) ahould recognize
that a remedial action objactiva ia a goal and that thara are
implaaentability and affactivanaaa eonatrainta in remediating
an aguifar to a 1.0 ppb TCB concentration.
The ROD aust indicate the practical lioitationa of a pump and
treat remedy in achieving a 1.0 ppb TCE groundvater cleanup
goal in accord vith EPA Directive 9355.4-03.
EPA Response: The alternatives in the FS are based on
modeling the cleanup of the TCE contaminant plumes in the
shallow and deep zones of the aquifer system as defined by
concentrations of at least 5.0 ppb. It was not possible to
predict the extent of the contaminant plumes and the rate of
cleanup at a level of 1.0 ppb TCE (the MCL) because
insufficient chemical distribution and hydrogeologic data were
available for levels of contamination less than 5.0 ppb. As
discussed in the FS report, additional monitoring veils are
proposed as part of remedial design to define more precisely,
-•-.e vertical and horizontal extent jf contamination and to aid
_r. the design of the groundwater re-ieaiation system. W^V. the
help of groundwater modeling, the most efficient ground.,::'.
extraction/injection system can be developed and the u,-j^ait ..
time required to restore the aquifer can be better estimated.
As with all remedial actions, the effectiveness of the
selected remedy will be monitored through periodic groundwater
sampling and an evaluation of the system vill be performed at
least every five years, as required by the Superfund
Amendments and Reauthorization Act (SARA). Cleanup goals,
contingency plans, operational changes, and other site-
specific factors vill be revisited during these evaluations
and appropriate modifications vill be made. Any proposed
changes, especially proposing less stringent cleanup goals,
vould require significant documentation and analysis to
support taking such actions. It should be noted that the
Record of Decision does discuss the uncertainties and
technical limitations of the selected remedy in achieving the
MCL of 1 ppb for TCE in the shallow and deep zones of the
aquifer system.
-------
2. Tht 76 (page 2-24) states that "The Pinelands Commission
prohibit* the discharge of vastavatar to surface vater bodies
or to infiltration basin* unless injection to the aquifer via
veils ia not technically feasible.** Thia statement is
incorrect. The Commission's regulations allow recharge to an
aquifer using leaching galleries or retention basins. As a
result of this erroneous interpretation of the Commission's
regulations, the remedial alternatives developed in the PS
rely on injection veils as the discharge option for treated
groundvater. In general, injection veils axe more costly to
install and maintain than leaching systems. Moreover,
injection veils are more susceptible to natural fouling than
leaching systems and EPA's remedies include pretreatment to
remove iron to minimise the impact of this fouling. This
pretreatment step and associated costs may not be required, if
leaching is employed as opposed to injection veils. Eder has
developed pump and treat alternatives assuming recharge
through leaching galleries. The costs associated vith these
alternatives are presented in Appendix A of this document.
EPA Response: The FS report incorrectly states that
infiltration basins are prohibited by the Pinelands
Commission. However, the Proposed Plan that was presented at
the site public meeting stated that the feasibility and
practicality of using infiltration basins in lieu of
reinjection veils will be evaluated during the design period.
The sane holds true for the ROD. Although infiltration basins
may be used for some of the treated groundvater, they may not
be appropriate for the entire flov. The determination as to
"»ether infiltration basins, reinj- ction veils, or a
wOmDination of both, vould be most efficient to use for
groundwater recharge, vill be made during subsequent *-eraeu.
design activities. Impacts on the vater table and the
wetlands area, and the number and spacing of the infiltration
basins are of critical concern vhen evaluating this option.
Because of the uncertainties involved, the costs cited in the
FS are considered to be conservative estimates; the actual
cost of the remedial action vill be further defined during the
upcoming remedial design.
The FS qualified the need for pretreatment to remove iron
prior to reinjection because additional information on
inorganics concentrations is needed before EPA can decide
whether pretreatment vill actually be part of the final
remedy. Again, the suitability of infiltration basins for
discharging treated groundwater and the need for metals
removal prior to reinjection of treated vater vill be
determined during remedial design. It should be noted that
infiltration basins do clog and vill require some maintenance.
8
-------
3. Eder suggests that only limited effort be expended in further
plum* delineation at the 1 ppb TCB level (tvo or three
additional monitoring veils) and further investigation of the
unsaturated tone and clay layer. Bder believe* that this
additional information vould not materially contribute to the
remedial design in any meaningful way.
EPA Response: Additional investigations to determine if
significant concentrations of TCE are present in the
unsaturated zone and the semi-permeable clay between the
shallow and deep aquifer zones were proposed in the FS to
determine if potential residual contamination could
significantly impact remediation of the groundwater. Although
little action could be taken to enhance the removal of
potential contaminants within the clay layer, various ways to
recharge treated groundwater nay enhance the removal of
potential contaminants from the vadose zone; this could
possibly reduce the amount of time required to meet the site
cleanup objectives. Additional investigations were also
proposed to define further the vertical and horizontal extent
of TCE contamination. The extent of these investigations will
be determined prior to design of the groundwater remediation
system.
4. The FS states that the extraction rate of 50 gallons per
minute (gpm) was selected to remediate the shallow and deep
zones of the aquifer to a 5 ppb TCE concentration/ rather than
to the 1 ppb TCE concentration goal/ because of limited site
data at lower TCE concentrations, ""herefore, the remedial
-ternatives (4A and 4B) presented ;. the F8 are based on
remediating the aquifer to a 5 ppb concentration.
The F8 states that the MCL of 1 ppb vould be achieved/
apparently based upon the evaluation of achieving 5 ppb by
pumping and treating groundwater. Eder believes that the ROD
must recognize that 1 ppb is a goal that may not be achievable
and changes in the pumping rates and/or the remedial goal may
be required.
EPA Response: Please refer to the discussion in response to
Comment l above.
5. EPA's design influent TCE concentration to the GAC treatment
unit is stated as 50 ppm (p. 3-24), vhile the Actual.
concentration is 50 ppb. Regardless of vhether this is a
typographical error, Eder believes that the carbon usage rate
in the GAC component of Alternative 4B is grossly overstated
and in turn has a significant impact on the operation and
maintenance (OtM) and present vorth costs of the GAC
alternative. Eder carbon usage estimates vere developed in
conjunction vith Calgon Corp. based on field experience and
not from theoretical calculation. Using usage rates
-------
calculated by Kdar and supported by Calgon, Ider believes that
tbt cost effectiveness criteria is satisfied and this
alternative should be carried through the 10 detailed analysis
of alternatives.
EPA Response: The influent TCE concentration to the GAC
treatment unit is 50 ppb; 50 ppm was a typographical error.
The Freudlich Isotherm Equation was used in the FS to
determine the size and expected tine until exhaustion of a GAC
contactor to. be used to remove low levels of TCE. Other
conservative assumptions were used to calculate carbon usage
to compensate for the uncertainties in the design based on
isotherm data. The following discusses the two approaches
presented by Eder for developing carbon usage and compares how
the approaches presented in the FS differ. The first approach
presented by Eder uses isotherm data, while the second uses an
estimated usage rate provided by carbon manufacturers.
When performing isotherm calculations in the first method, it
is first necessary to select isotherm data, the equilibrium
concentration, and an engineering safety factor. The isotherm
data selected for the FS were developed by Dobbs and Cohen of
EPA and are presently considered to be conservative. Eder
selected less conservative isotherm data. Isotherm data
presented in the literature vary widely; therefore, computed
usage rates can vary widely. For the FS, the effluent
concentration was conservatively selected for use in the
isotherm calculation, whereas Eder selected the less
ronservative influent concentration- When TCE breakthrough
-ccurs in the GAC bed (when the c? *-- will be replaced) , the
top of the bed will be in equilibrium at the influent
concentration, while the bottom of the bed will be in
equilibrium with the effluent concentration. Depending o . t*.e
depth of the adsorption wavefront, the actual usage rate
theoretically will- fall somewhere between the usage rate
computed using the influent concentration and that computed
using the effluent concentration. Since there is little data
available on the depth of adsorption vavefronts and since TCE
is relatively difficult to adsorb, the FS used the
conservative method of predicting usage rates with isotherms.
Lastly, an engineering safety factor of four was used in the
FS to account for the uncertainty regarding design with
isotherm data, whereas Eder used no safety factor.
The second method of projecting GAC usage presented by Eder
was predicated on the manufacturer's estimated usage rate
based on field experience. This calculation resulted in a
more conservative estimate than the first method using
isotherm calculations and was, therefore, selected for use in
Eder's calculation of operating costs. However, no safety
factor was included for the uncertainties associated with
actual influent concentrations, other components in the ground
10
-------
water that may exhaust GAC, or imperfect operation of the
treatment system. A safety factor Bust be included in all
remedies to ensure the continued, effective operation of the
remedy.
If GAC were selected as the remedy, testing of the actual
water stream is typically recommended as part of design to
provide reliable design data.
«. Eder believfs that Alternative* 41 and 4B, which specify iron
removal using precipitation and filtration, grossly
overestimate the volume of sludge, because BFA's calculations
are based solely on backwash volume of a commercial unit
without regard to influent solids. Bder's calculations, based
vpon site conditions, show that less than 40 gallons per day
of iron sludge at a solids concentration of 1% would be
generated. These calculations are included in Appendix A.
In addition, Eder feels that the iron removal system
(precipitation and filtration), presented and included in the
remedial cost estimates in the 78, Bay not be necessary if
leaching in lieu of injection wells is incorporated into the
design. If chemical treatment is utilised, sequestering iron
rather than precipitating it as a sludge Bay be more suitable.
Eder believes that the F6 and the HOD should indicate that the
iron removal component in any pump and treat alternative must
be established during the design phase and not as a ROD
stipulation.
-P* Response: The FS states that ~.ie need for iron
vill have to be further evaluated in the design phase. £:
lira ted data were available when preparing the FS. h.'-'sver,
based on these limited data, the inclusion of an iron removal
system for both the injection well and the recharge basin
(leaching gallery) alternatives is justified. Precipitated
iron can clog the soil in the vicinity of either system,
resulting in a decrease in recharge transmissivity.
Again, the estimate presented in the FS is conservative. The
disposal volume could be reduced through further treatment of
the low-concentration sludge.
In computing the projected sludge production rate, Eder only
took into account the iron hydroxide component of the sludge.
They did not consider other contributing components such as
the added polymer or turbidity which may be found in the water
and may be co-precipitated in the sludge. Furthermore, the
calculations in Eder's comments do not factor in the
possibility of increased sludge production from an increase in
iron concentration or from imperfect operation of the
treatment system.
11
-------
Eder states that if chemical treatment is utilized, it may be
more suitable to sequester iron rather than precipitate it as
a sludge. It may be difficult, however, to select an
acceptable sequestering agent. For example, phosphates are
common sequestering agents used in drinking water treatment.
However, their use can promote biological growth, especially
in basins exposed to sunlight, which could clog the basins.
Other sequestering chemicals are generally not acceptable for
use in drinking water treatment. Use of these agents may be
of concern to The Pinelands Commission.
7. Ed«r believes that the OfcM eosts presented in the FS appendix
conflict with the text, and the monitoring and treatment
duration presented in the appendix also conflicts with the
text. A review of Bder's cost estimates summarized in Table 1
(included in Appendix A of this document) reveals that the
selected alternative present worth cost estimated by EPA at
$4.2 Billion, is more reasonably estimated at approximately
$1.6 million, if all alternatives were evaluated utilizing
more realistic cost and performance data.
EPA Response: The present.worth calculations are correct and
the treatment durations (numbers of years of treatment and
monitoring) are correctly presented. On Table B-4 in the
appendix, the number of years of treatment are correctly
presented but the calendar years are incorrect. Instead of
treating from years 5 to 20, the report should read "years 2
to 17."
-> further address the comment, rei.c.r to the responses *o
Coiroaents 2, 5 and 6 provided above. The costs presentt- .
the FS are conservative. Additional information obtd^:*a
during the design phase will further optimize the treatment
and reinjection schemes, which will allow EPA to develop more
refined cost estimates.
8. The FS contains certain design details such as equipment size,
construction materials and treatment system configurations.
Eder recognizes that this information was used to evaluate the
cost of the FS alternatives. However/ Eder would like the FS
and the ROD to indicate that the selected remedy is based on a
conceptual design and that it is subject to change during the
remedial design phase.
EPA Response: The selected remedy is based on a conceptual
design. This conceptual design is subject to change during
the remedial design phase. The final design of the remedial
action will be developed after additional information is
obtained.
12
-------
B. Comments froa The Pinelands Commission
Written comments vere received from The Pinelands Commitsion
on March 26, 1990 and August 15, 1990 regarding the proposed
remedial alternative. IPA's response letter is included in
Appendix A. The Commission made the following comments:
1. The vater quality standards of the Vev Jersey Pinelands
Comprehensive Management Plan (CMP) require that BO
development be permitted which degrades surface or ground
vater quality. Although the vater quality standards of the
CMP do not identify specific limits for the contaminant TCE
detected in the groundvater at the site, the aondegradation
standard should be applied to any proposed reaediation.
The preferred alternative, groundvater pumping/air
stripping/reinjection is generally acceptable to the
Commission. Bovever, the proposal to treat contaminated
groundvater to Beet drinking vater standards (1 ppb for TCE)
is not acceptable. The Commission believes that this proposal
vould not comply vith the nondegradation standard of the CMP
which, along vith the Pinelands Protection Act of 1979 and the
National Parks and Recreation Act of 1978 qualify as
applicable or relevant and appropriate requirements (ARARs).
Therefore, the proposed remedial action plan should be amended
to set a treatment level of nondetect for the contaminant of
concern.
-PA Response: EPA's proposed clei.-• .f action should not be
considered new development which nay degrade vater qua ^ '•'
the Pinelands. Rather, the groundwater in the aguif<
underlying the Site is contaminated as a result of improper
hazardous waste disposal. By extracting and treating this
groundwater, the water quality will be significantly improved.
For this reason, EPA does not believe that the nondegradation
objective of the Pinelands CMP is an applicable requirement.
In addition, the groundwater underlying the Site has been
classified by the New Jersey Department of Environmental
Protection (NJDEP) as Class GW II. Accordingly, drinking
vater standards, or Maximum Contaminant Levels (MCLs)
established under the New Jersey Safe Drinking Water Act,
N.J.A.C. 7:10-16.7, are the applicable cleanup standards for
the Site. The MCL established for TCE is 1 part per billion
(PPb).
2. The Commission received a copy of the comments prepared by the
Nev Jersey Department of Environmental Protection (NJDEP) for
the Remedial Investigation, the Feasibility Study and the
Proposed Plan. It appeared to the Commission that several of
the comments raise substantive and procedural issues vitb
regard to the investigation and proposed remediation. The
13
-------
fhi Depa?tnent EP* *" atteBptin9 to "solve these matters with
-------
APPENDIX *
-------
Herman Undeboom
Consulting Services
507 Clark's Landing Rd
Egg Harbor, N.J. 08215
Tel: 609-965-7230
Ms Laura Lombardo
Project Manager
U.S. Environmental Protection Agency-Region
Emergency and Remedial Response Division
26 Federal Plaza, Room 720
New York. New York 10278
Date August 11. 1990
Dear Ms Lombardo.
As was stated at the Public Meeting in Mays Landing concerning the Mannheim Ave
Supedjnd Site of August 7, I feel *4 would be the best remedial choice.
Observations
A*?- renewing the Data in the Mannheim Ave Superfund Site File at the Atlantic County
Litra-y it became apparent that the width of the deeper aquifer Plume is directly related
to the length of the sallow aquifer Plume, since the two aquifers are connected through
the semi-permeable 3 to 5 feet day layer.
As the shallow Plume moves to the Tar Kiln Branch, the deeper Plume will expand
Simultaneously in the same direction, on its way to the Mulica river.
Thus posing a potential threat to more wells than stated at the meeting.
In other words time is of the essence to start Alternative »4.
To get a better feel fa the change in size and concentration levels of the Plumes over
time, a three dimensional Flow Mode! is desirable, coupling the shallow and deeper
aqjrfers,while measurements over time of existing and added wells will help in
determining the modeling coefficients.
The relaxation coefficient in the Flow Model should be a variable, not a constant, that
changes with the concentration level. Example: 1 for < 1 PPB and > 2 for > 10 PPB.
Yours truly
-------
Name:
Mannheim Avenue Superfund Site
Public Meeting Response Card
August 7, 1990
Mrs. Marsare;. Poehner jc.p]ease add my name to
Address:
Citv: E=c Harbor
247 N. Odessa Avenue
State:
the mailing list, (j think I'm already on it]
-.Please respond to the
following question/comment.
(Include name and address to
receive a response.)
Question/Comment: I "just vant. you to knov that I appreciate the work being
dene tc safeguard our.water supply/property values/environment and I also
appreciate being kept informed as steps are taken to correct this situation.
It is cccc for local residents to be involved in vorkiny vith government pnd
net ^ust hsve eovernnvent. do thines without askine. Thank vou.
Narr.e
Mannheim Avenue Superfund Site
Public Meeting Response Card
August 7, 1990
J^Please add my name to
the mailing list.
^.Please respond to the __
1 «> fQllowingfguT5Gon^omroea
vx. (Include fflme ana aaaress to
^receive a response.)
-*f*M
-------
Mannheim Avenue Super-fund Site
'II Public Meeting Response Card
August 7, 1990
ease add my name to
Address. I 6*1* K*t* S«+* 3**
~ „ _ i _ /*„.,,«, — —Please respond to the
City: 8*LA Cr^rJ State: fa Zip: /ftyfr following quesUon/comment.
(Include name and address to
receive a response.)
Quesuon/Commem: ALT A
*tt- G v,T<
S n#CcJ>*J J-j Tt(. Jrn'-A.,L
Si.
SrVt// flr
\
-------
EXPRESS iJp' eder associates
OVERNIGHT DELIVERY ...
consulting engineers, p. c.
August 14, 1990
File ?532-2
Laura Lombardo
Remedial Project Manager '
Emergency & Remedial Response Division
United States -Environmental
Protection Agency
26 Federal Plaza, Room 720
New York, New York 10278
Re: Mannheim Avenue Site
Galloway Township, New Jersey
Dear Ms. Lombardo:
Cn behalf of Lenox Inc, Eder Associates (EA) has reviewed the
Feasibility Study (FS) prepared by EPA's contractor, COM - Federal
Programs Corporation. We have identified certain errors in the
development and evaluation of the remedial alternatives presented in
the FS and would like to make the following comments:
3. The FS states that one remedial action objective (RAO) is to
protect uncontatninated groundwater. We concur with this remedial
action objective. The FS claims that pump and treat Alternatives
4A and 4B will prevent plume migration and restore the aquifer to
the 3 ppb TCE HCL (refer to Table *. page 3-21, 3-23, 4-29 ?nd
4-30). The FS does not present the technical justificat' ,- *c
support the conclusion that a pump and treat system will r*»'.ieu.,
the aquifer to the 1 ppb TCE MCL. In fact, the FS alte. .itpvea
are based on modeling done to determine whether it would be
possible to achieve a 5.0 ppb TCE concentration in the aquifer.
The FS and the EPA's Record of Decision (ROD) should recognize
that an RAO is a goal and that there are implementability and
effectiveness constraints in remediating an aquifer to a 1.0 ppb
TCE concentration. This was recognized and discussed on pages 52
and 53 in Eder Associates June 1990 Feasibility Study (copy
attached).
The ROD must Indicate the practical limitations of a pump and
treat remedy in achieving a 1.0 ppb TCE groundwater cleanup goal
in accord with USEPA Directive 9355.4-03 which states:
Recommendation 2: Provide flexibility 1n the selected
remedy to modify the system based on information
gained during Its operation.
Continued . . .
65 FOREST AVENUE. LOCUST VALLEY. NEW YORK 11560 • (516) 671*440
8030 EXCE'. SIOR DRIVE. SUITE 302. MADISON. WISCONSIN 53717-1914 • (608) B36-1500
3:5 V. H JP.CA; S', riKET. SUITE 220/240. ANN ARBOR. MICHIGAN 48104 • (313) 663-2144
SZ.-0 GD*3E ROAD. CA2ENOVIA. NEW YORK 13035 • (315) 655-3179
•--! -•. • £"--£-. . rsv.-.rsf.
-------
Laura Lombardo
United States Environmental
Protection Agency
August 14, 1990
•der associates consulting engineers, p.c.
-2-
In many cases, It may not be possible to determine the
ultimate concentration reductions achievable in
groundwater until the groundwater extraction system
has been implemented and monitored for some period of
time. RODs should indicate the uncertainty associated
with achieving cleanup goals in the groundwater.
In general, ROOs should Indicate that the goal of the
action is to return the groundwater to Us beneficial
uses: health based levels should be achieved for
groundwater that is potentially drinkable. In some
cases, the uncertainty in the ability of the remedy to
achieve this goal will be low enough that the final
remedy can be specified without a contingency.
However, in many cases, it may not be practicable to
attain that goal, and thus it may appropriate to
provide in the ROD for a contingent remedy, or for the
possibility that this may only be an interim ROD.
Specifically, the ROD should address the possibility
that information gained during the implementation of
the remedy may reveal that it is technically
impracticable to achieve health based concentrations
throughout the area of attain «nt, and that another
remedy or contingent remedy may oe needed.
N.:recver, p. 6 of this Directive states, in part:
If it is determined that some portion of the ground
water within the area of attainment cannot be returned
to its beneficial uses, an evaluation of an alternate
goal for the ground water should be made.
2. The FS (Page 2-24) states that "the Pinelands Commission prohibits
the discharge of wastewater to surface water bodies or to
infiltration basins unless Injection Into the aquifer via wells is
not technically feasible". This statement 1s Incorrect. The
Commission's regulations allow recharge to in aquifer using
leaching galleries or retention basins. As a result of this
erroneous interpretation of the Commission's regulations, the
remedial alternatives developed 1n the FS rely on injection wells
as the discharge option for treated groundwater. In general,
injection wells are more costly to Install and maintain than
leaching systems. Moreover, injection wells are more susceptible
to natural fouling than leaching systems and EPA's remedies
•include pretreatment to remove iron to minimize the impact of this
fouling. This pretreatment step and associated costs may not be
required if leaching is employed as opposed to injection wells.
Continued . . •
-------
•der associates consulting engineers, p.e.
Laura Lorr.bardo
United States Environmental
Protection Agency
August 14, 1990
•3-
EA has developed pump and treat alternatives assuming recharge
through leaching galleries. The costs associated with these
alternatives are presented and discussed In Comment No. 5 below.
The FS states that additional Investigations of the vadose zone
and the clay between the shallow and deeper aquifers and detailed
determinations of the extent of plume migration are required. In
fact, it would be virtually Impossible to Identify the impact of
small quantities of TCE released from a few drums that may have
leaked at various times over the site. Moreover, this additional
information would not materially contribute to the remedial design
in any meaningful way. In addition, the FS requires that detailed
determinations be performed to define the extent of the
groundwater plume at 1.0 ppb TCE concentrations. These
determinations- and investigations are not defined. We suggest
that only limited effort be expended in these areas which would
include the addition of two or three monitoring wells.
The pir? and treat alternatives (4A and 4B) are based on an
extraction rate of 50 gpm. Information presented in Appendix C of
the FS states that this flow rate was selected to remediate the
aquifers to a 5.0 ppb TCE concentration because of limited site
oat a at lower TCE concentration.. Therefore, the remedial
alternatives presented in the FS are based on remediati; -,
aquifers to a 5 ppb concentration.
The FS states that the MCL (1 ppb) would be achieved, apparently
based upon the evaluation of achieving 5 ppb by pumping and
treating groundwater. Although the RAO is 1.0 ppb, we trust all
parties understand that pump and treat alternatives may not
achieve this goal. Consequently, the ROD must recognize that 1.0
ppb is a goal that may not be achievable and changes in the
pulping rates and/or the remedial goal may be required.
In addition to the above comments, EA has found certain
significant errors in the cost calculations presented in the FS.
The revisions to the FS remedial alternatives required to address
the above and correction of the errors will materially change the
capital and OiM cost estimates. EA has prepared the attached
tables detailing more representative remedial alternative costs.
The key elements of changes/corrections are as follows:
Continued . . .
-------
•der associates consulting engineers, p.c.
Laura Lombardo
United States Environmental
Protection Agency
August 14, 1990
-4-
a. Alternatives 4A and 4B wrongly assume that injection wells
must.be used to recharge groundwater based on an incorrect
interpretation of Pinelands Commission regulations.
Consequently, we have added Alternatives 4A-1 and 46-1 which
include leaching rather than Injection wells.
b. EPA's design influent TCE concentration to the GAC treatment
unit is stated as 50 ppm (p. 3-24), while the actual
concentration is 50 ppb. Regardless of whether this is a
typographical error, the carbon usage rate in the GAC
component of Alternative 4B is grossly overstated and in turn
has a significant impact on the 0 & M and present worth costs
of the GAC alternative. EA carbon usage estimates were
developed in conjunction with Calgon Corp based on field
experience and not from theoretical calculation. Using usage
rates calculated by EA and supported by Calgon, the cost
effectiveness criteria is satisfied and this alternative
should be carried through the FS detailed analysis of
alternatives.
c. Alternatives 4A and 4B which specify iron removal using
precipitation and filtration g-ossly overestimate the volume
of sludge because EPA's caK,. Motions are based solfV on
backwash volume of a commercial unit without reg_--v
influent solids. It is absolutely unjustified to a:i :-c .fit.
sludge volume has no relationship to the content of the
influent. EA's calculations based upon site conditions, show
that less than 40 gallons per day of iron sludge at a solids
concentration of 1% would be generated. These calculations
are attached.
In addition, the iron removal system (precipitation and
filtration) presented and included in the remedial cost
estimates in the FS may not be necessary if leaching in lieu
of injection wells is incorporated into the design. If
chemical treatment is utilized, sequestering iron rather than
precipitating it as a sludge may be more suitable. The FS
and the ROD should indicate that the iron removal component
in any pump and treat alternative must be established during
the design phase and not as a ROD stipulation.
d. The O&M costs presented in the FS appendix conflict with the
text, and the monitoring and treatment duration presented in
the appendix also conflicts with the text.
Continued . . .
-------
•der associates consulting engineers, p.c.
Laura Lombardo
United States Environmental
Protection Agency
August 14, 1990
•5-
A review of EA's cost estimates summarized in Table 1 reveals that
the selected alternative present worth cost estimated by EPA at
$4.2, is more reasonably estimated at approximately $1.6 million,
if all alternatives were evaluated utilizing more realistic cost
and performance data.
6. The FS contains certain design details such as equipment size,
construction materials and treatment system configurations. We
recognize that this information was used to evaluate the cost of
the FS alternatives. However, the FS and the ROD must indicate
that the selected remedy is based on a conceptual design and that
it is subject to change during the remedial design phase.
In summary, the ROD should reflect that:
- the RAO of 1.0 ppb TCE is a goal and in fact may not be
attainable;
• leaching as a discharge option should be evaluated in the
design phase (together with other numerous design level
details set forth in the FS);
- the $4.2 million present worth cost for the selected remedial
alternative is overstated and that a more reasonable present
worth cost estimate is $1.6 mil'inn; and
- any additional studies/investigations be limited to v.
those necessary to support the remedial design arid ."i.nhsi
definition of the plume.
We trust that EPA will address these comments during its remedy
selection and that this letter will be incorporated into the
ed-inistrative record. We are available to meet with EPA and its
consultant to review these issues.
Very truly yours,
EDER ASSOCIATES CONSULTING ENGINEERS, P.C.
Gary A. Rozmus,
Vice -President
GAF-.'tg
cc: S. Lichtenstein
J. Kinkela
A. Gustray
G. Herman
*D580G
-------
•der associates consulting engineers, p.c.
MANNHEIN AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
PRELIMINARY IRON SLUDGE CALCULATIONS
Assume: Fe Concentration 2.7 mg/1
Iron Sludge 1s 501 (Wt) Fe
Sludge 8 11 solllds
Flowrate • 50 gpm
Ifcs/d Fe - 2.7 mg/1 x B.3 x 50 gal/min x 1440 min/d x mg/106
Fe - 1.6 Ibs/d
Ire- S'liire « 1.6 Ibs/d , , ihe/n
• 3.2 ibs/d
501
S'.::? Vciur-e _ 3.2 Ibs/d ^ 39 gal/d
(0.01) 8.3 Ibs/gal
-------
•der esMciotes consulting tnginters, p.c.
MANNHEIM AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
PRELIMINARY GAC CALCULATIONS
Influent Concentration » 50 ppb
Effluent Concentration • 1 ppb
Flow m 50 gpm
a. From TCE Isotherm (Calgon Corporation)
(? 5D ppb:
10 FT; TCE . 0.01 Ib TCE
g carbon Ib carbon
Ib TCE . 50 051 x (50-1) UQ x l£-69 x 3.781 x _Lb_ x 1.A4? tr-n
Ce;. inin 1 ug . gal 454g day.
. 0.03 Ib/day
1: Ce-bcn . 0.03 . 3 Ib/day (0.04 Ib carbon/1,000 gal water)
cay 0.01
Carbon Required • 3 x 365 « 1,100 Ib/yr
b. Per Calgon
Need < 0.1 Ib carbon/1,000 gal water
3 50 gpm (72,000 gal/da>)
Carbon » 0.1 x 72 • 7.2 Ib/day
. 2,630 Ib/yr
Assume 4000 Ib/yr
-------
OiM rn*l•
of Nrarrflal Mternitlvp C«nl Ml I HI I PS
Munnhrli* Hvrntlr Mtp
Alt*rn,tt !*•* 4ft
Mt-rnM Ivn 4H- I
Mil ••mil l«n 4H
Altornotl*n 4n-I
Total Capital Tout
$541.100
Ml*. «oo
1 1,1100
*-JO (Monitoring!
I'll (Cro«n«h»»t»r
*!•.$*!
•I00.tOO
SI ft.MIS
Stl.OOO
Sid. •>«%
»!•.MIS
$90. «00
Wortli of MM •
91.M». 000
SI. IV .000
JI.10I.OOO
»l. 1*7.000
Total Alt*rn*tl«« Co»l
SI. 5»5.«00
Jl.»l4,fOO
*!,(•?.700
o
5
Hotel:
•Prrsrnt north of nofittorlii*, and froum)««tt>r reeowy *nd trrilnpnl
»ll»rn«ll»» 4»: CDN't M1t«>rf»tl««> - fMp dmt tr*«t hr «lr ttrlpnlnq, i
Injn Hnn orlH - r.ostl r*(|ptt revliril Iron iludqf qenf ration r»|p.
4M-I:
no linn mmvcl.
(ml lrr»t by llr strlpplnq,
hr
4H: CDN't »ltfn»»ll»» - fmf u*4 trv*t hy I>RC. rprhirqp I .
upllt - cottt rpflpct rp»l?pd Iron slurfqp and tppnt tirbnn qpnprallon »•
re I 'on
rnitUe 4t-l: fiMp ffid trcit kjr CMC. reclwrtjr by Ifichlnq fitlrrlt . no
novtl - cost* reflect revised tpent orbon generation rite.
3:
3
-------
MANN VIM AVI-N1M- SPIT.
C;AU.OWAY WNSIIIP. NI:W II-RSI-Y
r\>
FAritrnr/coNsrwucnoN
I. PUHIJC AWARITNRSS PROGRAM
H. MONTTOHINO WRIJ-S
•. Mnllow
b. Inlf.iiiKnMIB
c. l>cep
III. Smi PRRPARATION
I. Rgaipnon fnmtotm
Z
IV. PIIMPINO WHLL AND OOLLfiCTION
SYSTI!M
I. Well («pp«r «|"*feO
1 Well (lover «T"»ei)
3. Wefl PtMip (•ppct •qaifcr)
4. Well PWnp (lowet •qaifet)
.. 2«*PVC
c. Road eroding
V. EQUALIZATION A CIIRMICAL FFHO
2. C^Mfntnl Pmf Syricinr
A. I^Of^WCT
ft. YJnCflWCAlfl
c. CMorine
VI. AIR STRIPPER
IAIII.K i
TA.M.I- II 4(CI>M)
AI.1T.RNATIVI- *A: CWOIINIIWATI-R PIIMTINCMIR STRIPI1Nf;«)N .Sill; DISrilARttR
< AHIAM OSI 1 YMMAII.S (I'WO INHJ.AK.S)
F.STIMATF.D
QUANTITIES
1
1
5
3
93 cy
1
3e»
3e«
3 e«
3 e«
2.200 If
2.200 If
4011
1
lea
2e>
Ir.
1
MATKRIAI.. $
I/NIT PRICF. C«KT
Incliidrd in InnullMinn
Included in IniuttMinn
Inclmlrd in InflillMkm
Incliidrd in ImlillalHm
Included in tniutlaltnn
Included in Iniullalinn
Indnd 4 in hraMllMian
Included hi biMdlMicm
5OOOO I,WOOO
MKI.OO i.non.m
•_ , >.,.•- .i i— g-,,.,11^*. „
•VNJUI^U m mviBiivifciffi
IncturfcJ in Imuttalkui
IticJuffco in litvUllfltKitt
Included in InfUttMkm
If " «fed in tnitallMinn
It i* .i^lrd hi hi«1»ll«ioo
f *<
-------
• TKRIAI, t
INSTALLATION, t
UNIT PR K'K
«1tST
vn. PRI-SSIIRKHI.TIW
I. .SlMic Miier
2 Muhi Media Prcti«nr I'ihrr
1 lint k«»* W*«e Tank
4.
3.
vm.
I.
2.
3.
4.
Wen (•nwr aqmfer)
Well Oowrt aquifer)
Writ DiKharRe Pwnp
2im*iPVC
O.
c.
Road trolling
IX. TRP.ATMHNT SYSTRM PIPING A
VALVKS
a. 2mcfcPVC
b Var»a
X. INSTRUMBNTATION AND COmHOLS
XI.
Ara
6ra
lea
9.000 ir
4.MNIH
40 H
300 If
30 ea
Inilmlnl in ln
-------
•der associates consulting engineers, p.c.
MANNHEIM AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
TABLE 2
TABLE B-4 (COM)
ALTERNATIVE 4 A: GROUND WATER PUMPING/
AIR STRIPPING/ON-SITE DISCHARGE
ANNUAL OPERATION AND MAINTENANCE COST ESTIMATES (1990 DOLLARS)
COST COMPONENT
1. Site Monitoring (0-5 years) (See O&M
for Alternative 1)
2. Site MorJtoring (5-30 years) (See O&M
for Alternative 1)
TREATMENT O&M COSTS
3. Chemicals
a. Polvraer
b. »*' . '.
c. NaOH
d. Chlorine
4. Manpower
a. Supervision
BASIS OF
ESTIMATE
b. Operators
O&M COST
ESTIMATE
52,605
18,585
YEAR
0-5
5-30
438 Ibs S876
2.0Mb
4.406 Ibs $2,203
0.5Mb
8.424 Ibs $7.076
0.84 lb
12 clys
1 ,044.00 dy $12,528
1 person $7.200
$75/hr
8 hrs/day
12 days/yr
1 person Slg,720
$45/hr
8 hrs/day
52 days/yr
2-17
2-17
2-17
2-17
2-17
-------
COST COMPONENT
5. Power/Energy
a. Operating Equipment
Well Pumps
Sirippsr Pump
Air Blower
Baclwash Pump
Supemauni Pump
Reinjeciion Pumps
Miscellaneous
TOTAL
b. Lighar.g
c. Building Heat
6. SJ- •
7. Maintenance
8. Coningency
BASIS OF
ESTIMATE
•der ostoeiotes consulting tngineers, p.c.
QAM COST
0.22 kw
0.70 kw
4.10kw
0.90 kw
0.20 kw
3.00 kw
1.00 kw
10.12 kw
10.12 kw
24 hrs/day
365 days/yr
$0.100/kwhr
Ikw
24 hrs/day
365 days/yr
$0.100/kwhr
$200 month
8 months/year
$0.25/gal
12 monihs/year
6%ofTCC
fc of 0&.M Costs
ESTIMATE
$8.865
TOT.U ANNUAL TREATMENT O&M COST
$876
$1,600
$11.341
$3.650
$32,500
$4.800
$100.900
YEAR
2-17
2-17
2-17
2-17
2-17
*Sludge Gsneraiion based on 2.7 mg/1 Fe influent, sludge @ \% solids, sludge generation rate » 40 gal/d
-------
MAI* 'i IM AVI:NHI; srn-:
OAIJOWA ; OWNSIIIP. NI:W JI-HM-Y
TAIII.I: 1
I AMI I- II 4 (0>M)
Ai.Ti-RNATivi- iteiil Storage Arts
IV. PUMPING WdJ, AND COLIACTION
SYSTRM
1 Well (Vnret •prifer)
3. Well Ptemp (vpper •qMfer)
4. Well Pump (fairer aquifer)
5. Piping:
a. 2ncnPVC
h. TiuiUiing
V. FQUAIJ7ATION * CHEMICAL FRED
2. Chemical Peed Sjruem:
b aikwaw
VI. AIR SIRIITUR
ESTIMATED
QUANTITIES
91 ry
1
3e«
3e«
2.2m If
2.2m ir
4011
I
lea
lea
I
MATERIAL,*
IfNITPRICE COST
Inrliidrd in lnjl«D«linn
Inrlivtcil in Initilfuhin
Inrlmlrd in lns««ll*i
-------
VTKRIAI, t
INSTALLATION, t
vii .
KA« 'II .ITY/rONSTm ICTION
-AOitNo <7Ai.i.nRii-<;
I. IjrKhwiR Pool*
2. Pipmf:
• ZincliPVC
c. R«M| cimiing
Vm. TREATMENT SYSTEM PIPING A
VALVES
•. 2MIPVC
b. Vd«a
IX. INSTRUMENTATION
x.
QIIANTMIKS
in
WO If
UNIT PRICK
Ira lixlrd in
CIKST
LS
ln< lixlrd in
Intlmlrrf in InmllMMin
Inrjuilrrf in InnlillMinn
Indwfal in Iniull
Indmlrd in
Inrlwkd in
TRICE
I5.noo no
I5.0OOOO
1.5ft
1 40
2500
35*
A5.OO
10.00000
15.50000
12.04000
6.10000
i.ooooo
71200
1.95000
, 32.04000
6.100 OO
1.00000
54.14001)
71200
1.950(10
l.H>2 00
10.00000
25,50000
Tniil Direct Ciwl (TDC)
CJnMmitrncy <82n% of T V.
»d AdminiilnMive 9)% of TDC
TOTAL CONS mUCTION COST
2t7.4M
57.493
14.373
4I6.ROO
If = Knew fed
LS -tumfnm
•y = *!«••« y«i
Nrte: Alteiiinire 4A-I: Pwnip "nJ lie« fcjr ifr ilrinwig. recntfje
iei. no imn icmovrf.
a
w
5
o
3
w
C
(O
*
3
to
-------
•dtr estociates consulting tnginters, p.c.
MANNHEIM AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
TABLE 4
TABLE B-4 (CDM)
ALTERNATIVE 4 Al: GROUND WATER PUMPING/
AIR STRIPPING/ON-SITE DISCHARGE
ANNUAL OPERATION AND MAINTENANCE COST'ESTIMATES f!990 DOLLARS')
COST COMPONENT
1. Site Monitoring (0-5 years) (See O&M
for Alternative 1)
2. Site Monitoring (5-30 years) (See O&M
for Alternative 1)
TREATMENT O&M COSTS
3. Chemicals
a. H2S04
b. cruorine
BASIS OF
ESTIMATE
4,406 Ibs
0.5Q/lb
12 clys
1,044.00 cly
O&M COST
ESTIMATE
52.605
18.585
$2^03
$12428
YEAR
0-5
5-30
2-17
A. Manpower
a. Super\-ision
b. Operators
1 person
$75/hr
8 hrs/day
12 days/'yr
1 person
$45/hr
8 hrs/day
52 days/yr
$7^00
$18.720
2-17
2-17
-------
•der estociatcs consulting tnginetrv p.c.
COST COMPONENT
5. Power/Ensrgy
a. Opening Equjpmem
Well Pumps
Stripper Pump
Air Blower
Miscellaneous
TOTAL
BASIS OF
ESTIMATE
0.22 kw
0.70 kw
4.10 kw
l.OOkw
6.02 kw
6.02 kw
24 hrVday
365 days/yr
$0.100/kwhr
O&M COST
ESTIMATE
YEAR
$5.274
2-17
b. Lighung
c. BuiJding Hear
1 kw
24 hrs/day
• 365 days/yr
$0.100/kwhr
$200 month
8 months/year
6. Mi...«.',,«A.c 6%ofTCC
7. Contingency 5% of O&M Costs
TOTAL ANNUAL TREATMENT O&M COST
$876
$1,600
$25,000
S 3.670
$77.000
2-17
"• '7
2-.
2-17
-------
MANNIinM
SITU
OAIJ.OWAY lOWNSIIIT. NUW JTRSHY
ALTIKNATIVI- 411: ww aqmfcT)
3. Well P«mp (Mppcr aaaifer)
4. Well fimp fl
p"
•
a
•p
in
-------
MATFRIAI, f
VII. IIM'SSIIRfi Ml TI-H
I. SIMM: Miiri
2 Miihi Mnlt* IV^mir l-'ihet
T ||»,k»«ih VV.^r link
4 Siifirntitm
5. C1r»r**ll 1 ..i*
VIII. HFINII CIION W|:.|.|.S
I. Welt (WOT
2 Wrll flo
1. Well
IX. TRKATMBNT SYSTEM PIPING A
VALVES
7inrhPVC
X. INSTRUMENTATION AND CONTROLS
XI RU-CTRICAL
IT = lincAf net
I.S = Imp MMI
ty = (qnic ywJ
INSTALLATION, $
QIIANJIIIKS
fir.
«itr
200 If
30 e*
I.S
I.S
UNIT PR -V.
IIM •Hlrjmn oo
2i.
-------
tder estocietes consulting enginters, p.c.
MANNHEIM AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
TABLE 6
TABLE B-5 (CDM)
ALTERNATIVE 4B: GROUNDWATER PUMPING/
CARBON ADSORPTION/ON-SITE DISCHARGE
ANNUAL OPERATION AND MAINTENANCE COST ESTIMATES (1990 DOLLARS)
COST COMPONENT
1. Site Monitoring (0-5 years) (See O&M
for Alternative 1)
2. Site Monitoring (5-30 years) (See O&M
for Alternate 1)
TREATMENT O&M COSTS
3. Chemicals
a. Chlorine
b. '
4. Manpov-e:
a. Supervision
b. Operators
BASIS OF
ESTIMATE
12 clys
1,044.00 cly
4,000 Ibs
1.15/lb
1 person
$75/hr
8hrsyday
12 days/yr
1 person
$45/hr
8hrs/day
52 days/yr
O&M COST
ESTIMATE
52,605
18,585
$12,528
$4.600
$7,200
$18.720
YEAR
0-5
5-30
2-17
2-17
2-17
2-17
12
-------
•dtr onociotts consulting tnginters, p.c.
COST COMPONENT
5. Power/Energy
a. Operating Equipment
Well Pumps
GAC Pump
Miscellaneous*
TOTAL
b. Lighting
c. Building Heat
6. Sludge nisposaJ"
7. Maintenance
8. Contingency
TOTAL ANNUAL TREATMENT O&M COST
BASIS OF
ESTIMATE
0.22 kw
0.70 kw
l.OOkw
1.92 kw
1.92 kw
24hrs/day
365 days/yr
$0.100/kwhr
1 kw
24 hrs/day
365 days/yr
$0.100/Tcwhr
$200 month
8 months/year
$0.25/gal
12 months/ye^
6% of TCC
5* of O&M Costs
)ST
O&M COST
ESTIMATE
$1,682
$876
$1,600
$3,650
$36,800
$4.383
$92,000
YEAF
2-17
2-17
2-17
2-17
*
2-17
2-17
*Sludge Generation based on 2.7 mg/1 Fe influent, sludge @ 1% solids, sludge generation rate = 40 gal/d
13
-------
MANNMI-IM AVI-NIII: SfTI!
I OWA> •••IWNMIIP. NI-:W II-KSI-Y
/AIM !•: 7
1 'III 1 II ^ (CUM)
AI.TI UNA11VI- 111 1 CHOIINPWATI R I'llMI'INCWAKMON AIISfWHION/ON SHI- DISniARni-
< Am Ai.rosr r.siiMAii-s (iwo IMM i AHS>
MATKRIAI., $
1
n
m.
IV.
V.
VI.
FACILITY/CONSTRUCTION
PUniJC AWARHNRSS PROGRAM
MONITOR INO WEM.S
•. Shallow
b. IntrnnoftMe
c. Deep
SITE PREPARATION
1. R<|ui|*nenl FnmdMiot
2. EqaipncM Sionge An*
PIIMPtNT. WEI.I. AND COLLECTION
SYSTEM
2. Wtfl (low Mfnfet)
3. Writ P«mp (MPPCT •q"M
4. Well fVmp (lower squifef)
•. 2 btc* PVC
b. Tnmftint
c. Road CKMiinf
EQUAIJZATION A OIEMICAI. FRRD
1. EqmlitMioN TaA
2. CVmiol Peed Syilem:
•. OilotW
CARRON ABSORPTION
•. OnSni UniU
b. Ruilding
FSTIMATH*
QIIANITIIKS UNIT PRICK
1 Incliidrd in
1 Included in
5 Includrd in
3 Included in
9) cy Inrludnd in
1 bidudrd in
3 CB htdiiuCa tn
3 ei Indndrd in
3u 50OOO
3« fonm
i itm if t.. . i.i.i« J ;—
£,/JMP If IfiCJtnCO tfl
2.71)» If lr.Hi.A-d in
40 If Indodrd in
1 Indiided tn
1 t» . ludrd in
2 -tclwlnlm
1 toKitwwi tn
covr
IniUlMinn
InMillnion
IntiilliMHm
InMitlDHm
InfUltMirm
Inflallalkin
hii»nMinn
IntuHMMin
1^00 CIO
i.imnno
hiifdlMMin
hll>li
-------
Vf>:iUAI,»
INSTALLATION, $
KACILrrYrtrONSTRIKTWN
vii 1 1 ACHING GAI i
I . I r •< hin( IViolt
2 INpifiRt
i. 2 inrh PVC
h.
c.
VIH. TRnATMP.NT SYSTRM PIPING A
VAI.VliS
•. 2inehPVr
b Vilves
IX. INSlKIIMnNTATION ANnoONTROIS
x r.i.ncTRicAi.
n — llfMflV ICCI
IS =
TIMATK
HI
9.IIIII If
4.VIII If
200 If
30 tm
I.S
15
Trt.l
rjtgiti
II
••-S UNITPMrK COST
(in liMlnl in Initftllitiim
Inrliiilril in InMatlalMm
ImltMfrd in ImullMmn
Inilmlnl in lniullxi«in
ESJIEE:
Indudcd in InslallMion
Dirrcl Cmi (TfX")
itjfmcy ^fut^b 01 'i |^»
rrmf ^2O% of TTC
•nd AdminiMnli*
S
O
«O
to
•
3
•o
-------
•der associates consulting tnginters, p.c.
MANNHEIM AVENUE SITE
GALLOWAY TOWNSHIP, NEW JERSEY
TABLE 8
TABLE B-5 (CDM)
ALTERNATIVE 4B1: GROUNDWATER PUMPING/
C.ARBON ADSORPTION/ON-SITE DISCHARGE
ANNUAL OPERATION AND MAINTENANCE COST ESTIMATES fl990 DOLLARS)
COST COMPONENT
1. Site Monitoring (0-5 years) (See O&M
for Alternative 1)
2. Site Morjicrir.g (5-30 years) (See 0&.M
for Alternative 1)
TREATMENT OfcM COSTS
3. Chemicals
a. Chlorine
b. Carter.
4. Manpower
a.
b. Operaiors
BASIS OF
ESTIMATE
12 clys
1,044.00 cly
4,000 Ibs
1.15/lb
1 person
$75/hr
8 hn/day
12 days/yr
1 person
$45/hr
8hrs/day
52 days/yr
O&M COST
ESTIMATE
52,605
18.585
$12.528
$4,600
$7.200
$18.720
0-5
5-30
2-17
2-17
2-17
16
-------
•d.r o«sociot.s consulting enginter$ p £
COST COMPONENT
5. Power/Energy
a. Operating Equipment
'
.
GAC Pump
Miscellaneour
TOTAL
b. Lighting
c. Building Heat
0.22 kw
0.70 kw
l.OOkw
1.92 kw
1.92 kw
24 hrs/day
365 days/yr
$0.100/kwhr
1 kw
24 hrs/day
365 days/yr
SO.lOO/kwhr
$200 monih
8 months/year
6. Maintenance 6% of TCC
8. Co,.ujj£cn;.y 5% of O&M Costs
TOTAL ANNT.AL TREATMENT O&M COST
$1,682
$876
$1,600
..$29,713
I 3T846
$80,800
2-17
2-17
2-17
2-17
2-:.
17
-------
Revision 1, June 25, 1990
•d«r associates consulting »ngin»«rs. p.c.
and the cost and possibility of obtaining land through right or
outright purchase. Given the modeling results, it may be necessary to
have this system in place and operational within three years.
Cost - The estimated capital costs for this alternative is
$387,000 for the existing residential wells ind $427,000 for the
existing and potential future residential wells. This cost does not
include land acquisitions. The estimated annual operation and
maintenance cost is $55,000 for the existing residential wells and
$64,000 for the existing and potential future residential wells. The
present worth amount of the OiM is $571,000 for the existing
residential wells and $664,000 for the existing and potential future
residential wells if the restoration time is 15 years; and $846,000
fcr the existing residential wells and $984,000 for the existing and
potential future residential wells if the restoration time is assumed
to be 30 years. The total cost is $959,000 for the existing
residential wells and $1,100,000 for the existing and potential future
residential wells for 15 year restoration timeframe; and $1,200,000
for the existing residential wells and ii ^00,000 for the existing and
potential future residential wells for a 30 year restoration tii..tr:
3.3.4. Alternative 4: Groundwater Pumping to Restore the
Aouifer/Air Strippinq/Groundwater Monitoring/
Institutional Controls and Point of Use Controls
Description
The objective of this alternative 1s to restore the aquifer by
pumping groundwater from the shallow and deep plumes. Groundwater
would be pumped from extraction wells and treated on-site using air
stripping. The treated water would be recharged to the shallow
aquifer via leaching pools.
The effectiveness of the pumping system is dependent on the
placement of the extraction wells. Extraction wells cannot be
•instellcJ „: :hs downgradeent edge of the plume because the 1 ppb edge
of the plume is poorly defined, diffuse in nature, and virtually
52
-------
Revision 1, June 25, 1990
•dtr associates consulting tngin*«rs, p.c.
impossible to monitor. Installing an extraction system at the
inferred 1 ppb leading edge of the plume would not be technically
feasible for the following reasons:
- The monitoring problem would make it extremely difficult to
locale the pumping system at the leading edge of the plume
and it would be necessary to Install a large and redundant
number of wells, most of which would only yield clean water.
- The low concentration of TCE would mean that pumpage would be
very dilute and the system would effectively pump clean
water. If the TCE concentrations in the pumpage are diluted
to below detectable limits, it would not be possible to
determine that the plume is intercepted. Moreover, due to
the low TCE concentration at the edge of the plume,
monitoring wells could not be located downgradient of the
recovery system to determine if any TCE breakthrough is
occurring.
Given these conditions, it is not feasible to recover the »r,i
or c'eep plumes at the 1.0 ppb TCE level, therefore, this alterna.ivfe
would implement groundwater extraction within the plumes. Groundwater
extraction within the plumes would allow the remaining uncontained
portion of the shallow and deep plumes to dissipate naturally.
This alternative would implement a long-term groundwater
monitoring program as discussed in Alternative 1. In-home GAC units
would be installed 1f MCLs are exceeded at the residential wells as
described in Alternative 2. Additional monitoring wells may be
installed to track the plume. The number of wells and the sampling
and analysis protocols would be established during the remedial design
phase.
This alternative presents two implementation options:
1. Iiistall the pump and treat system under current conditions, or
53
-------
The Pinelands Commission
P.O.Box?, New Lisbon, N. J. 08064 (609)894-9342
August 15, 1990
Ms. Laura Lombardo
Site Compliance Branch
USEPA - REGION II
26 Federal Plaza
Room 747
New York, NY 10278
Re: App. No. 89-1280.01
Block 504, Lots 2, 3
Galloway Township
Mannheim Ave. Dump Site
Dear Ms. Lombardo:
Thank you for providing the Pinelands Commission with a copy of
the Proposed Remedial Action Plan (PRAP) for the Mannheim Avenue
Superfur.d Site.
T? preferred alternative, '_-:i:ndwater pumping/air
stripping.-reinjection is generally acceptable to the Commi *•; ~ •
However, the proposal to treat contaminated groundwater '-o r*--...
drir.Xir.g water standards (Ippb for TCE) is not acceptable.
As stated within our comments of March 26, 1990 (enclosed) the
water quality standards of the Pinelands Comprehensive Management
Plar. (CK?) prohibits development which would degrade surface and
ground water resources of the Pinelands.
The proposal to pump, treat and reinject to meet drinking water
standards would not comply with the non-degradation standard of
the CMP which along with the Pinelands Protection Act of 1979 and
the National Parks and Recreation Act of 1978 quality as
"Applicable or Relevant and Appropriate Requirements."
Therefore, the proposed remedial action plan should be amended to
set a treatment level of non-detect for the contaminant of con-
cern.
Further, the Commission has received & copy of the comments
prepared by the N.J.D.E.P., Division of Hazardous Waste Manage-
ment for the Remedial Investigation Report, the Feasibility Study
and the Proposed Remedial Action Plan. It appears that several
The Pinelands - Our Country'* First National Reserve
-------
of the comments raise substantive and procedural issues with
regard to the investigation and proposed remediation. The Com-
mission relies on the Division for expertise regarding the tech-
nical aspects of Superfund Investigations. Therefore, the Com-
mission requests your agency to address all the issues raised
within their comments.
The Pinelands Commission will object to any Record of Decision
which does not address the concerns raised herein.
If you have any questions regarding this matter, please contact
Robert Kowell of our staff.
Sincerely,
William Harrison, Esquire
Assistant Director
WK/mw/E3
cc: Kaiyesh Shah, Case Manager, N.J.D.E.P.
Enclosure
-------
The Pinelands Commission
P.O. Box 7, New Lisbon, N. J. 08064 (609)894-9342
.,/'
ccs
MEHORXKD U K
TO: Laura Ler.bardo, USEPA
FF.Ott: P.cbert G. Hovell
TKr.C'UGH: Viliia.T, F, Harrison
SVErrCT: Knr^nZIM AVE. SITE
:A7Z: KARCK 26, 1930
Tr.e rlr.4lsr.as Ccr.rission staff has reviewed the draft feasitilitv
report ::r the Kannheia Ave. Site.
Tr.e rir.e lands Ccr.rission has been charged with administer ins ar.5
'enfc:cin; the star.iarcs of the Nev Jersey Pine lands Ccnprehensive
K3r,*cfir.fir,t Plan (N. J .A.C."?;50-1.1 tt seq). The Pinelands
C:-n.?rehensiv* ror.sgeir.er.t Pla-; (CKP) vas adopted by the Pir.ftlanis
C?rni£si:r. or: .January K/1S6;, pursuant to the National FarXs and
Rer »tlcn Act c£ 1978 (Public Lav S5-C2S, Section 5C2) and the
Ti.c rl^elands Protection Act of 1S7S v...^.S.A. 18A-1 et seq).
T.-iC ?.rt£ 6:
-------
tier- Ares, The Forest Management Area provides a buffer or tran-
sition to the Preservation Area which is the core of the
Pinelar.cs Environment and represents the nost critic*! ecological
region ir. the Finelands. These tvo Management Areas contain high
quality water resources and wetlands. The overall type and level
*f cevelc-p-ent permitted within the Forest Areas and particularly
*-;::-!in the Preservation District are strictly limited to protect
and preserve their significant natural resources. The water
quality standards of th-. Man (promulgated as N.J.A.C. "7:50-6,S)
require that no develops t be permitted which degrades surface
cf ground water quality. While the water quality standards of
the CM? do not identify specific limits for the contaminant
(trl:.',lcroethene, TCE) detected in the ground water at tve site,
the .-cn-cegraiaticn standard should be applied to any proposed
rerects:ion. Proposed clean-up goals should be set to achieve
the crestest percent removal of this substance.
Therefore/ the recommendation to implement Alternative .2;
Grc.-;v£tsT Krr.itcring/Institutional Controls is found to be
u.v- .-ej'.scle to the Pineiands Ccrr.ission The Commission reccn-
r-:nci t.iet the remedial technology of ground water purpir.c te
fcrtrer evaluated . This should include the per f crr,ar.;fe o£
11-"-; p'jr;:r;r end sar.pling of the existing monitoring wel's tc
cc ..:" tr.e desrrited streaky ar.d low : -,
-------
* •
£ NST/7 ; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ / REGION II
*'*' (*:"'t JACOB K. JAVfTS FEDERAL BULDINC
NEW YORK. NEW YORK 10276
Villiar Harrison, Esq.
Assistant Director
The Pinelands Commission
P.O. Box 7
Kev Lisbon, New Jersey 08064
Dear Kr. Harrison:
This letter is in response to your letter dated August 15, 1990
to Ms. Laura Lom±.ardo of sy staff, regarding the Proposed Plan
for the Kar.r.heic Avenue Ducp Superfund Site in Callovay Township,
Kev Jersey.
As part cf the Feasibility Study prepared by tht U.S.
Invircr.rer.tel Protection Agency's (EPA's) contractor, four
alternatives were evaluated to identify a permanent renedy to
egress the contaminated ground-water at the site. These
alternatives vill be discussed in detail in the Record of
D&cis-cr. fcr the site. The proposed reaedial action includes
grci-rdvater collection with on-site treatment via air stripping
end discharge into the aquifer system either via reinjection
velJ- sr infiltration basins.
In y —r Aug-jst 15th letter, you suggested that the proposer*
clesn.r es»! fcr the contarinant of'concern, trichloroethyiene
(TCI), in the arjifer be set at a nondetectable level based on
the n:r. = *gredaticn objective of the Pinelands Comprehensive
Kanager.ent Plan (CK?) . You also stated that the Pinelands CKP
prchikits development which would degrade surface and groundvater
res^.rces cf the Finelands.
EFA's proposed cleanup action should not be considered new
development which r.ay degrade water quality in the Pinelands.
Father, the groundvater in the aquifer underlying the site is
contaminated as a result of improper hazardous waste disposal.
By extracting and treating this groundvater, the water quality
will be significantly improved. Tor this reason, EPA does not
believe that the nondegradation objective is an applicable
re guiresent.
Jn addition, the groundvater underlying the site has been
classified by the New Jersey Department of Environmental
Protection (KJrz?) as Class C« II. Accordingly, drinking water
standards, er Ksxicun Contarinant Levels (HCLs) established under
the Kev Jersey Safe DrirJ:ir.g Vater Act, K.J.A.C. 7:10-16.7, are
the applicable cleanup standards for the Site. The MCL
established for TCE is 1 part per billion (ppb).
-------
The remediation planned by EPA may not reduce contaminant
concentrations in the groundwater to background, or nondetectable
levels. The treatment system will be designed to treat the
extracted TCE-contaminated groundwater to the MCL of 1 ppb, in
attempts to remediate the TCE contamination in the shallow and
deep zones of the aquifer system to 1 ppb, as veil.
In addition, with regard to your concern with the comments made
by the NJDEP on'the Feasibility Study and Proposed Plan, please
be advised that EPA is in the process of resolving these natters
with the Department.
EPA established a public comment period on the Proposed Plan and
the Remedial Investigation and Feasibility Study reports for the
Site, which extended from July 17 to August 15, 1990. On August
7, 1990, EPA held a public meeting to present EPA's proposed
remedial action to the community and other interested parties,
and to respond to oral questions and comments. After review of
all consents, which the Agency receives concerning the proposed
remedial action, EPA intends to proceed with a final remedial
solution for the site that is protective of human health and the
environment, cost-effective, and attains federal and state
requirements that are applicable or relevant and appropriate.
Your cooperation in providing comments on the proposed remedial
action is appreciated. I hope that the concerns raised by the
Pinelands Corjnission have been fully addressed. Should you have
any 'urther questions in this matter, <* not hesitate to contact
m i. (212) 264-8673, or have your staff contact Laura Lorn.' -.'
the project manager for the Mannheim Avenue Dump Site, at '??:/
264-6787.
Sincerely yours,
Richard L. Caspe, P.E.
Director
Emergency and Remedial Response Division
cc: H. Shah, NJDEP-BFCM
-------
APPENDIX B
-------
Superfund Proposed Pian-
Mannheim Avenue Superfund Site
Galloway Township, New Jersey
EPA
Region 2
-July 1990
ANNOUNCEMENT OF
PROPOSED PLAN
This Proposed Plan describes the preferred alterna-
tive for addressing groundwater contamination at
the Mannheim Avenue Site (Site) in Galloway
Township, Atlantic County, New Jersey. This
document is issued by the United States Environ-
mental Protection Agency (EPA), the lead agency
for site activities, and the New Jersey Department
of Environmental Protection (NJDEP), the support
agency for this response action. Only after the
public comment period has ended and the informa-
tion submitted during this time has been reviewed
and ' . -Irrid will EPA, in consultation with
NJDEP, make a decision as to what action(s) to
take at this Site.
EPA is issuing this Proposed Plan as pan of pur
public participation responsibilities under Section
117(a) of the Comprehensive Environmental Re-
sponse, Compensation and Liability Act (CER-
CLA). This Proposed Plan summarizes informa-
tion that can be found in greater detail in the
Remedial Investigation and Feasibility Study (Rl/
FS) Reports and other documents contained in the
administrative record file for this Site. 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 the selec-
tionof the response action will be based. The file is
available at the following locations: •
Atlantic County Library
Galloway Township Branch
30 W. Jimmie Leeds Road
Pomona, NJ 08240
(609) 652-2352
and
U.S. EPA Region H
Emergency & Remedial Response
Division File Room
26 Federal Plaza, 29th Floor
New York, New York 10278
EPA,in consultation with NJDEP,; ^-' >:f-'th*
preferred alternative or select ^-.-th--. i. . . -
action presented in this Plan based on ne *• imorma-
tion or public comments. Therefore, the public is
encouraged to review and comment on all of the
alternatives identified herein.
THE COMMUNITY'S ROLE IN
THE SELECTION PROCESS
EPA solicits input from the community on the
cleanup methods proposed for each Superfund
response action. EPA has set a public comment
period from Julv 17 through August 1$.1990 to
encourage public participation in the selection
of a remedy for the Site. The comment period
includes a public meeting at which EPA will dis-
cuss the RJ7FS reports and Proposed Plan, answer
questions, and accept both oral and written com-
ments.
-------
ing sludge, with trichloroethylene (TCE) as its
primary constituent. This waste material also
contained smaller amounts of other volatile or-
ganic compounds (VOCs) and heavy metals (lead
and cadmium). Lenox also disposed of leaded
glaze waste, plaster molds, broken chinaware, clay
forms, and genera] trash at the Site, which were
mixed in with other debris in the mounded soil. The
township a! so disposed of genera] trash waste at the
Site.
The Site was placed on the National Priorities List
in 1983. In December 1984, EPA issued an Admin-
istrative Order to Lenox and the Township of
Galloway to remove the waste material buried in
the soil mounds at the Site, conduct soil and ground-
water sampling, and excavate and remove con-
taminated soil from the Site. By August 1985,
Lenox had completed the excavation of the waste
material from the soil mounds. Approximately
25,000 pounds of wastes were removed from the
Site and incinerated off site. Thirty-five mounds of
soil remained, many with residual contamination.
In 1985 and 1986, Lenox sampled the asphaltic
sludge material as well as the soil on site, the
groundwaier on site and within a half mile radius
from ihe Site, and a nearby stream. This sampling
showed that the principal contaminants associated
with the waste at the Site were lead and TCE. Soil
sampling revealed that lead was the predominant
contarr' t remaining within the soil mounds (at
level* up to **6.000 parts per million (ppm)). Sev-
eral of the mounds also contained small fragments
of the asphahic sludge waste which could not be
separated from the soil during the initial excava-
tion. These mounds were assumed to contain TCE
as well as lead contaminants. Groundwaier sam-
pling on site revealed the presence of TCE (at levels
up to 140 pans per billion (ppb)). Groundwater
sampling from residential and school wells, and
from the nearby stream did no; reveal the presence
of any site-related contaminants.
In July 1988 and March 1989, EPA sampled the
drinking water from 25 local residential wells sur-
rounding the Site and one well from the Bethel
Christian School for VOCs and metals. No VOCs
or metals were detected above EPA's drinking
water standards.
In May 1988. EPA entered into an Administrative
Order'on Consent with Lenox, Inc. and the Town-
ship of Galloway, in which Lenox agreed to con-
duct a Remedial "investigation (RI) and Feasibility
Study (FS) at the Site.
In June 1989, the 35 mounds of soil containing
residual lead and TCE contamination were exca-
vated and disposed off site by Lenox.
REMEDIAL INVESTIGATION
SUMMARY
The objectives of the RI were to characterize the
nature and extent of any contamination associated
with the Site, to identify migration of contamina-
tion and its impact on public health and the environ-
ment, and to determine whether there is a need for
remedial measures to protect human health and the
environment. The investigations evaluated soil,
ground water, air, and surface water/sediment qual-
ity.
The detailed results of the RJ can be found in the
Remedial Investigation Report, contained in the
administrative record file noted on page 1. The
results of the investigation can be summarized as
follows:
• The geology of the Site is comprised of the
following units of the Cohansey Sand and
Kirkwood Formation, in descending order
a shallow aquifer (which occurs approxi-
mately 35 feet below the ground surface), a
semi-permeable clay unit (approximately
Juee to five feet thick whirh -xcu^s ap-
proximately 50 feet below i...£
face), and a deep aquifer.
• In the shallow aquifer, groundwater flows
towards the northwest. In the deep aquifer,
groundwater flows towards the northeast.
• Shallow and deep groundwater quality has
been adversely impacted at the Site by
TCE. The shallow aquifer contains TCE up
to a concentration level of 29 ppb. It is
roughly estimated that the entire length of
the shallow TCE plume, including the 400-
foot diameter of the Site itself, is assumed
to be 1000 feet, with a width of 400 feet and
thickness of 15 feet. The deeper aquifers
contains TCE up to a concentration level of
47 ppb. It is roughly estimated that the
deeper TCE plume length, including the
Site, is greater than 1000 feet, and that it is
1000 feet wide and 55 feet thick.
• It is believed that the clay unit separating
the shallow and deep aquifer may contain
-------
The No Action alternative is evaJuated at every site
to establish a baseline for comparison. Under this
alternative, no active action would be taken at the
Site to prevent or reduce migration of, or reduce
concentration levels of, TCE in the groundwater.
This alternative relies on natural attenuation of
contaminants in the groundwater to reduce TCE
concentration levels to the MCL of 1 ppb. This
alternative includes a long-term monitoring pro-
gram to assess the migration of contamination in
the shallow and deep aquifers. This program would
use existing monitoring wells, newly installed moni-
toring wells, and residential wells in the vicinity of
the Site. Selected wells would be sampled on a
quarterly basis for the first five years, and then
biannually. This alternative also includes an edu-
cational program to inform the public about poten-
tial hazards at the Site. The amount of time required
for natural artenuation to reduce contaminant lev-
els to drinking water standards is not known at this
time because of the uncertainties relating to the
presence and degree of residual contamination in
the unsaturaied zone and in the clay layer separat-
ing the shallow aquifer from the deep aquifer. The
potential exists for this residual contamination to
continue to release slowly into the groundwater at
an unknown rate and over an unknown period of
time.
Alternative 2: Poinf-of-Use Carbon
Adsor ' n Treatment /Water-Use Restric-
tion.
Capital Cost: S 147,150
Annual O&M Cost: 552.600 (years 1 to 5)
550,900 (year 6)
532.000 (years 7 to 21)
518,600 (years 22 to 30)
Present Wonh: 5739,400
Months to Implement: 1 month to install point-
of-use control; 12 months
•for water use restrictions
This alternative includes all of the components of
Alternative 1, with the addition of provisions to
install and maintain individual carbon adsorption
treatment systems at residential wells, if ground-
water monitoring (performed on a quarterly basis
for the first five years) indicates that the groundwa-
ter contamination is migrating and threatening the
residential wells. The carbon adsorption system
would remove organic and, to some degree, inor-
ganic contaminants. The treated water would then
be used as needed by residents. In addition, this
alternative would place'legal restrictions on the
installation of any new- wells in the vicinity of the
contamination. Any new or existing downgradient
wells in the future would require the installation of
a treatment system, if it was determined that wg*
quality was threatened by site contaminationJIHI
individual treatmrnt systems and the water-use
restrictions would be temporary and would be in
place until groundwater quality has been restored.
Alternative 3: Alternate Water Supply/Water-
Use Restrictions
Capital Cost: $492,100
Annual O&M Cost: $52,600 (years 1 to 5)
$94,300 (years 6 to 30)
Present Worth: $1,749,200
Months to Implement: 18 months
This alternative includes all of the components of
Alternative 1 , with the addition of the development
of water supply well(s) and a distribution system to
provide potentially affected residences with a
continuous source of clean water, if groundwater
monitoring (performed on a quarterly basis for the
first five years) indicates that the groundwater
contamination is migrating and threatening the
residential wells. The water supply well(s) would
be installed near the Site in an area outside the TCE
contamination. Groundwater use-restrictions would
require that all existing and future households
connected to this supply and that residential
be taken out of service.
Alternative 4: Groundwater Pur
Slripping/Reinjection
Capital Cost: $541,000
Annual O&M Cost: $52,600 (year 1 )
$394, 100 (years 2 to 5)
$360, 100 (years 6 to 17)
$18,600 (years 18 to 30)
Present Worth: $4,217,100
Months to Implement: 24 months
This alternative includes the installation of ground-
water extraction wells to withdraw the contami-
nated water for pn-site treatment with discharge
through reinjection into the shallow and deep
aquifers. Three extraction wells would be installed
in each aquifer. Two wells in each aquifer would
be operated continuously and the third would serve
as a backup well during periods of well mainte-
nance. Six reinjection wells would be installed in
each aquifer. Three wells in each aquifer would be
operated continuously and the additional three wells
would serve as backups to be used during
nance periods. Contaminated water would
pumped from the shallow aquifer wells and
aquifer wells at total rates of 10 gallons per minute
-------
toxiciry and volume of contaminants. Alternatives
2 and 3 use treatment via individual carbon adsorp-
tion units and an alternative water supply, respec-
tively, to reduce the toxicity and volume of con-
taminants in the groundwater prior to use by resi-
dents. Alternative 4 would reduce the toxiciry,
mobility and volume of contaminants in the aquifer
by extracting contaminated groundwater and treat-
ing it to meet drinking water standards.
Short-term Effectiveness: This criterion refers to
the rime in which the remedy achieves protection,
as well as the remedy's potential to create adverse
impacts on human health and the environment that
may result during the construction and implemen-
tation period. Implementation of Alternatives 1,2,
3 and 4 would not create any adverse short-term
impacts on human health and the environment.
The time to achieve protection from contaminants
in the ground water is longer for Alternatives 1, 2
and 3 than for Alternative 4. Alternatives 1,2 and
3 rely or natural attenuation over time to reduce
contaminant concentration levels in the groundwa-
ter to drinking water standards. The amount of time
required for natural attenuation would be influ-
enced by the potential for residual contaminants in
the unsaturated zone and in the clay layer to con-
tinue to release slowly into the aquifers. Alterna-
tive 4, while incapable of quickening the release of
residua! contamination potentially in the clay layer,
provides for active removal of the contaminants
which' '-tady exist in the aquifers, as well as active
rerr . * cr the contaminants as they enter the
aquifers after being released from the unsaturated
zone and clay layer. Therefore, Alternative 4
achieves protection in a lesser time frame than
Alternatives 1,2 and 3.
Implementability: Implementability is the tech-
nical and administrative feasibility of a remedy,
including the availability of materials and services
needed to implement the selected alternative. All
alternatives are implementable. Alternatives 1,2
and 3 involve considerable long-term institutional
management. Alternatives 2 and 3 require the
cooperation of local residents, administrative
management to operate and maintain the point-of-
use treatment systems, and the supply and distribu-
tion system, re'spectively, as well as the enforce-
ment of water-use restrictions. The implementa-
tion and enforcement of these restrictions may be
difficult. The ground water monitoring program in-
cluded as part of each alternative may require some -
administrative management and cooperation of
local residents.
Cost: Cost includes capital and operation and
maintenance (O&M) costs. The present worth cost
for implementation and operation of each alterna-
tive are summarized below.
Alternative 1: Present Worth Cost -$ 550,100
Costs include installation of additional ground
water monitoring wells and 30 years of monitor
ing.
Alternative 2: Present Wonh Cost - $ 739,400
Costs include installation of additional ground
water monitoring wells, installation of individual
treatment units (15 years of use), and 30 years of
monitoring
Alternative 3: Present Worth Cost - $ 1,749,200
Costs include installation of additional ground
water monitoring wells, installation of alternate
water supply (25 years of use), and 30 years of
monitoring.
Alternative 4: Present Worth Cost - $ 4,217,000
Costs include installation of additional groundwa-
ter monitoring wells, installation of groundwater
extraction and treatment system (15 years of use)
and 30 years of monitoring.
State Acceptance indicates whether, based on its
review of the Rl/FS and Proposed Plan, the State
concurs with, opposes, or has no comment on the
preferred alternative. This criterion will be ad-
dressed when State comments on the Proposed Plan
are
Community Acceptance will *•» »«'-.. : ,-e
Record of Decision following areview jf Un, public
comments received on the Rl/FS reports and the
Proposed Plan.
SUMMARY OF THE
PREFERRED ALTERNATIVE
In summary. Alternative 4 actively removes con-
taminants from the groundwater and prevents the
contaminants from potentially migrating to resi-
dential wells. In doing so, this alternative protects
uncontaminated portions of the drinking water
source from being contaminated. This alternative
provides for restoration of the groundwater in a
faster time period than the other alternatives.
This alternative also provides for the most protec-
tion of human health and the environment. There-
fore, Alternative 4 is believed to provide the best
balance of trade-offs with respect to the evaluation
criteria and is proposed by EPA as the preferred
alternative.
-------
APPENDIX C
-------
x; /^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION 2
FOR
MANNHEIM AVENUE SUPERFHMD SITE
August 7.1990
Meeting Attendees
(PLEASE PRINT)
S/ 3 O/.
'•X, '
// .J"
/X/O"
^J3^.n^ 4or,e.3vwe /roK-U "IT
^* - tT~*
PhnnA
£&>IS
^f
-------
UNITED STATED uWIHONMtiii«L HHO1 tCHON AGENCY. REGION 2
MANNHEIM AVENl^UPEI (NO SHE
August 7. 19SO
Meeting Aiiendf
(PLEASE PRII ,
kj-j.
( l'Aa>tc»^ ^ .
PhnnA
-7 \ <*~
-------
APPENDIX D
-------
THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBLIC COMMENT ON THE
PROPOSED REMEDY FOR
THE MANNHEIM AVENUE SITE
LOCATED IN
GALLOWAY TOWNSHIP, NEW JERSEY
The United States Environmental Protection Agency (EPA), as lead agency for the Mannheim
Avenue site, will hold a Public Meeting to discuss the Remedial Investigation/Feasibility Study
(Rl/FS) and the Prooosed Plan for the Remedy at the site. The New Jersey Department of
Environmental Protection (NJDEP), as the suppon agency, will also be in attendance. The
meeting will be held on August 7. 1990. at 7:00 p.m. in the Atlantic County Library • Mays
Landing, 2 South Farragut Avenue, Mays Landing, New Jersey.
As.a result of the Rl/FS conducted to date, EPA determined that the principal threat posed by
the site is ground water contaminated with trichloroethylene (TCE). a suspected human
carcinogen, wMcn exceeds the State drinking water standard and has migrated off of the
prope-ry bounoa'y and may adversely impact residential dnnking water wells. Among the
optcns eva:jstec for addressing contaminated ground water at the site are the following:
v No Action. This alternative would consist only of groundwater monitoring.
2. Point-of-Use Carbon AdsorptionTreatment/Water Use Restrictions. Under this alternative,
infl'viC-a! cation acsorption treatment systems would be installed and maintained at
resoentia: weiis. if groundwater monitoring indicates that these wells are threatened.
3. Aite^.ate Water Supply/Water Use Restrictions. Under this alternative, alternate watersupply
weii(s) anc a distribution system would provide a c* .tinuous source of dean water to .
resioe-ts, if groundwater monitoring indicates that re*..~.>iidi wells are threatened. I
t
4. Ground Water Pumping 'Air Stripping/'Reinjection. This alternative includes the install* 'J. . i'
: extraction wells to withdraw the contaminatec water for on-site treatment witn
through re injection into the shallow and deep aquifers.
Trie No-Action alternative was evaluated as required by the National Oil and Hazardous
Substances Pollution Contingency Plan.
Based or ava'iab'e information, the proposed remedy at this time is Alternative 4. EPA proposes
that this remedy will be most protective of human health and the environment. EPA and NJDEP
welcome the puce's comments on all alternatives identified above. EPA will choose the Remedy
after the pubic comment period ends and consultation with NJDEP is concluded. EPA may select
an option other than the proposed alternative after consideration of all comments received.
Complete documentation of the project findings is presented in the Administrative Record File,
which contains the Rl and FS Reports and the Proposed Plan. These documents are available
at either the Galloway Township Branch of the Atlantic County Library. 30 W. Jimmie Leads Road,
Pomona, New Jersey, or EPA's Region II offce in New York,
The pubic may comment in person at the public meeting and/or may submit written comments
through August 15, 1990 to:
Laura Lombardo
Remedial Project Manager
Emergency and Remedial Respons* Division
U.S. Envifc.-.mentfi! Protsit.'cn Ag*ncy
26 Federal Plau
New York, New York 1027A
(212)264-67B/
-------
MANNHEIM AVENUE SITE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
SITE IDENTIFICATION
Background / Other Information
P.I - 2 Memorandum to Mr. Scott Santora, NJDEP, from Mr.
Joe Buttich and Mr. George Weiss, NJDEP, re:
Sampling Operation at Galloway Township Site,
9/27/82.
P. 3 - 9E Memorandum to Dr. Merry L. Morris, State of New
Jersey Department of Environmental Protection
(NJDEP), from Mr. Michael Zachowski and Mr.
William Lowry, NJDEP, re: Site history and
observations, 9/17/84. The following are attached:
a) a location map;
b) table 1: quantitative data on
compounds of interest, NPES numbers
19v - 31v;
c) table 1, NPES numbers 1m - 15m;
d) a letter concerning a sludge sample
e) an analysis sheet;
f) a sample analysis report;
g) and two vapor degressor sludge
sheets.
Prelirir.ary Assessment P.eports
P. 10 - 24 Report: Preliminary Site Assessment Report,
Mannheim Dump Site, prepared by Mr. Kwasi Boating
and Mr. Nicholas DeRose, Weston/SPER, 8/27/84.
REMOVAL RESPONSE
EP.-. Progress Reports
P.25 - 26 Pollution Report no. 1, Mannheim Avenue Dump Site,
U.S. EPA, 4/26/85.
P.27 - 28 Pollution Report no. 2, Mannheim Avenue Dump Site,
U.S. EPA, 7/22/85.
P.29 - 30 Pollution Report no. 4, Mannheim Avenue Dump Site,
U.S. EPA, 8/16/85.
P.31 - 32 Pollution Report no. 5, Mannheim Avenue Dump Site,
U.S. EPA, 8/29/85.
p.33 - 34 Pollution Report no. 5, Mannheim Avenue Dump Site,
U.S. EPA, 2/6/86.
-------
P.35 - 36 Pollution Report no. 6, Mannheim Avenue Dump site
U.S. EPA, 2/12/86.
P.37 - 38 Pollution Report no. 7, Mannheim Avenue Dump site
U.S. EPA, 4/21/86.
P. 39 - 40 Pollution Report no. 8, Mannheim Avenue Dump Site.
U.S. EPA, 7/17/86.
P.41 - 42 Pollution Report no. 9, Mannheim Avenue Dump Site,
U.S. EPA, 10/16/86.
P.43 - 44 Pollution Report no. 10, Mannheim Avenue Dump
Site, U.S. EPA, 4/9/87.
P.45 - 46 Pollution Report no. 11, Mannheim Avenue Dump
Site, U.S. EPA, 4/23/87.
P.47 - 48 Pollution Report no. 12, Mannheim Avenue Dump
Site, U.S. EPA, 7/14/87.
P.49 Pollution Report no. 13, Mannheim Avenue Dump
Site, U.S. EPA, 6/16/89.
P. 50 - 51 Memorandum to Mr. Charles Fitzsimmons,
Weston/SPER, from Ms. Barbara Jakub and Mr. Donald
Graham, Weston/SPER, re: PRP activities during
removal, 7/7/89.
..it. Pollution Report no. 14, Mannheim Avenue D"~r
Site, U.S. EPA, 7/10/89.
Resporsible Party Progress Reports
P.53 - 99 Report: Progress Report 1 - Covering work
performed during 7/1/85 - 7/26/85, Mannheim Avenue
Site Galloway Township, New Jersey. Prepared by
Geraghty and Miller, Inc., 8/85.
P.100 - 108 Report: Progress Report 2 - Covering work
performed during 7/29/85 - 8/23/85, Mannheim
Avenue Site, Galloway Township, New Jersey.
Prepared by Geraghty and Miller, Inc., 8/85.
P.109 - 133 Report: Progress Report 3 - Covering Work
performed during 8/26/85 - 2/10/86, Mannheim
Avenue Site, Galloway Township, New Jersey.
Prepared by Geraghty and Miller, Inc., 2/86.
P. 134 - 137 Letter to Mr. Adalbert© Bosgue, U.S. EPA, from Dr.
Robert Saar and Mr. Michael Wolfert, Geraghty and
Miller, Inc., Re: progress work through 7/31/86.
Dated 8/8/86. Progress report is attached.
-------
P. 138 - 144 Letter to Mr. Adalberto Bosgue, U.S. EPA, from Dr.
Robert Saar and Mr. Michael Wolfert, Geraghty and
Miller, Inc., Re: progress report for the Mannheim
Avenue Site which covers work performed during
8/86. Dated 9/8/86. Progress report is attached.
P. 145 - 148 Letter to Mr. Adalberto Bosgue, U.S. EPA, from Dr.
Robert Saar and Mr. Michael Wolfert, Geraghty and
Miller, Inc., Re: progress report for the Mannheim
Avenue Site which covers work performed during
9/86. Dated 10/14/86. Progress report is attached.
P.149 - 155 Letter to Mr. Adalberto Bosque, U.S. EPA, from Dr.
Robert Saar and Mr. Michael Wolfert, Geraghty and
Miller, Inc., Re: progress report for the Mannheim
Avenue Site which Covers work performed during
10/86. Dated 11/11/86. Progress report is
attached.
•P.156 - 160 Letter to Ms. Laura Lombard©, U.S. EPA, from Dr,
Robert Saar, Geraghty and Miller, Inc., Re:
progress report for Mannheim Avenue Site which
covers work performed during 11/86 - 12/86. Dated
1/9/87. Progress report is attached.
P _ - 163 Letter to Ms. Laura Lor jardo, U.S. EPA, from Dr.
Robert Saar, Geraghty and Miller, Inc., Re:
progress report for the Mannheim Avenue Site
covers work performed during 1/87. Dated k/j.3/8"/-
Progress report is attached.
P. 164 - 167 Letter to Ms. Laura Lombard©, U.S. EPA, from
Mr. Robert Saar, Geraghty and Miller, Inc., Re:
progress report for the Mannheim Avenue Site which
covers work performed during 2/87 and 3/87; Dated
4/7/87.
Progress report is attached.
P.168 - 170 Letter to Ms. Laura Lombardo, U.S. EPA, from Dr.
Robert Saar, Geraghty and Miller, Inc., Re:
monthly inspection report and map showing location
of surface water sample taken during the 1986
sampling program, Dated 12/18/87.
P. 171 - 172 Letter to Ms. Laura Lombardo, U.S. EPA, from Dr.
Robert Saar, Geraghty and Miller, Inc., Re: 12/87
inspection report for the Mannheim Avenue Site,
1/4/88.
-------
Work Plan / Reports
p.173 - 290 Report: Plan for Mannheim Avenue Site. Galloway
Township. New Jersey, prepared by Ceraghty and
Miller, Inc., with Rollins Environmental Services
Inc., 7/85.
P.291 - 296 Report: Modification to Treatment and Removal Plan
for Surface Materials Mannheim Avenue Site^.
Galloway Township. New Jersey, prepared by
Geraghty and Miller, Inc., 5/89. Cover Letter is
attached.
P.297 - 302 Report: Special Report Summary and Evaluation of
on - Site Soil Quality After Completion of Surface
Materials Removal. Mannheim Avenue Site. Galloway
Township. New Jersey, prepared by Geraghty and
Miller, Inc., October 1989. Attached is a letter
to Ms. Laura Lombardo, U.S. EPA, from Ms.
Catherine Gilroy and Dr. Robert Saar, Geraghty and
Miller, 10/26/89.
Ccr re secede nee
P.303 - 304 Letter to Anthony Farro, New Jersey Department of
Environmental Protectir-i, from Sukhdev Bhalla,
NJDEP, Re: Inspection .' riannheim Site, 10/16/35.
p.305 Letter to Mr. William Librizzi, U.S. EPA, *rr- .
Jcrge Berkowitz, NJDEP, Re: Site visit by stace
officials, 11/7/85.
p.306 Letter to Ms. Martha Coopersroith-Gray, NJDEP, from
Mr. Kurt Whitford, NJDEP, Re: classification of
waste from the Mannheim site, 1/7/86.
P. 307 - 308 Letter to Dr. Robert Saar, Geraghty and Miller,
Inc., from Shirlee Schiffman, NJDEP, Re:
departmental opinion on the classification of
contaminated soil and refuse, 3/4/86.
P.309 Letter to Dr. Robert Saar, Geraghty and Miller,
Inc., from Shirlee Schiffman, NJDEP, Re:
departmental opinion on the classification of
contaminated soils and refuse, 3/5/86.
p.310 - 312 Letter to Carole Petersen, U.S. EPA, from Dr.
Robert Saar and Mr. Michael Wolfert, Geraghty and
Miller, Inc., 3/19/86. A letter from Ms. Catherine
Gilroy and Mr. Michael Wolfert, Geraghty and
Miller, Inc., is attached.
-------
P. 313 - 314 Letter to Dr. Robert Sa?ir, Geraghty and Miller,
from Shirlee Schiffman, NJDEP, Re: oversight in
technical review, 3/27/86.
P. 315 - 316 Letter to Dr. Robert Saar, Geraghty and Miller,
from Shirlee Schiffman, NJDEP, Re: response to
inquiry and submittals for a departmental opinion
on the classification of contaminated soil and
refuse, 6/25/86.
P. 317 Letter to Dr. Robert Saar, Geraghty and Miller,
from Shirlee Schiffman, NJDEP, Re: response to
inquiry and submittals for a departmental opinion
on the classification of contaminated soil and
refuse, 6/27/86.
P. 318 - 319 Letter to Mr. Albert Gustray, Lenox China, from
Shirlee Schiffman, NJDEP, Re: classification of
waste mounds, 7/1/87.
P. 320 - 321 Letter to Mr. Albert Gustray, Lenox China, from
Shirlee Schiffman, NJDEP, Re: classification of
waste mounds, 7/24/87.
p. 322 Letter to Mr. Albert Gustray, Lenox China, from
Shirlee Schiffman, NJDEP, Re: correction to
correspondence to classification of waste mounds,
7/24/87.
P. 323 - 325 Letter to Mr Albert Gustry, Lenox China,
Shirlee Schiffman, NJDEP, Re: final classx-: i.citj. n
of waste mounds, 7/24/87.
P. 326 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from Mr. Raymond Basso, U.S. EPA, re: EPA
Approval for "Modification to Treatment and
Removal Plan for Surface Materials," 6/1/89.
P. 327 - 334 " Letter to Ms. Laura Lombard©, U.S. EPA, from Mr.
John Kinkela, Lenox Crystal, Re: Lenox contract
with Chemical Waste Management about removal and
disposal of the mounds at the Mannheim site,
6/6/89. Attached is a letter to Mr. Steve
Piotrowski, Lenox Technical Center, from Charles
Scott, Waste Systems, re: Lab results.
p. 335 Letter to Mr. John Kinkela, Lenox Technical
Center, from Ms. Laura Lombard© , U.S. EPA, re:
U.S. EPA approval of arrangements for disposal of
the waste materials, 6/14/89.
Action ^er.o
-------
P.336 - 347 Memorandum to Mr. William J. Librizzi, U.S.
EPA, from Mr. Dave Rogers, U.S. EPA, Re:
Immediate request for action for the Mannheim
Avenue Dump Site, 10/23/84.
Data
P.348 - 387 Report: Summary Data Tables; Quality of Soi,ls
between Mounds, in Mounds and Mesa Sectors.
and in Asphaltic Waste Composite Mannheim
Avenue Site. Galloway Township. New Jersey.
prepared by Geraghty and Miller, 11/85. EPA,
8/29/85.
p.388 - 399 Letter to Ms. Carole Petersen, U.S. EPA, from
Dr. Robert Saar and Mr. Michael Wolfert,
Geraghty and Miller, Inc., Re: Laboratory
data for soil samples taken from under mound
and mesa sectors. A copy of these results is
attached, 4/14/86.
P 400 - 403 Letter to Ms. Carole Petersen, U.S. EPA, from Dr.
Robert Saar and Michael Wolfert, Geraghty and
Miller, Inc., Re: Summary of recent work at
Mannheim Avenue Site, 4/25/86. A table and map of
the area are attached.
P.404 - 417 Letter to Ms. Carole Petersen, U.S. EPA, from Dr.
Robert A. Saar and Mr. Michael Wolfert, Geraghty
and Killer, Re: Site I... .atigation, test results
are attached, 5/19/86.
P.41S - 426 Letter to Carole Petersen, U.S. EPA, from Dr.
Robert A. Saar and Michael Wolfert, Garaghty and
Miller, Re: two replicate water samples. Test
results are attached, 5/29/86.
REMEDIAL INVESTIGATION
Work Plans
P.427 - 640 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from Mr. Raymond Basso, U.S. EPA, re:
Approval of Project Operations Plan, Revision no.
2, 3/3/89. Attached is Project Operations Plan,
Revision no.2, 2/89.
P.641 - 650 Letter to Ms. Laura Lombardo, U.S. EPA, from Ms.
Catherine Gilroy and Dr. Robert Saar, Geraghty and
Miller, Inc., 5/8/90. Tables on monitoring
parameters and frequency of collection
describing supplemental field activities are
attached.
-------
EPA Oversight Reports
P.651 - 668 Report: Letter Report Oversight of Remedial
Investigation. Mannheim Avenue. Galloway Township.
New Jersey, prepared by CDM - FPC, 4/6/89.
P.669 - 688 Report: Letter Report. Investigation of Water
Table Aquifer. Mannheim Avenue Site. Galloway
Township^ New Jersey, prepared by CDM - FPC,
4/19/89.
P.689 - 723 Report: Letter Report. Field Summary Report.
Mannheim Avenue. Galloway Township. New Jersey.
prepared by CDM - FPC, 7/24/89.
P.724 - 730 Report: Letter Report. Field Summary Report.
Mannheim Avenue, Galloway Township. New Jersey.
prepared by CDM - FPC, 8/16/89.
P.721 - 74 B Report: Letter Report. Field Summary Report of
Ground Water Sampling,, Mannheim Avenue. Galloway
Township, New Jersey. . "'.pared by CDM - FPC,
9/12/8S.
P.74S - 757 Report; Letter Report. Field Summary Report.
Mannheim Avenue. Galloway .Township, New Jersey.
prepared by CDM - FPC, 10/13/89.
P.75B - 767 Report: Letter Report. Revised Oversight Summary
Report Mannheim Avenue Dump Site. Galloway
Township. Nev Jersey, prepared by CDM - FPC,
11/30/89.
P.768 - 815 Report: Letter Report., Field Summary Report of
Monitoring Well Installation and Groundwater
Sampling. Mannheim Avenue Site. Galloway Township.
New Jersey, prepared by CDM - FPC, 12/11/89.
P.816 - 839 Report: Letter Report, Addendum to Field Oversight
Summary Report Dated 11/30/89. Mannheim Avenue
pump Site. Galloway Township. New Jersey, prepared
by CDM - FPC, 1/8/90.
Responsible Party Progress Reports
P.840 Progress Report no. 1, prepared by Geraghty
and Miller, Inc., 7/8/88.
-------
P.841 - 844 Progress Report no. 2, prepared by Ceraghty and
Miller, Inc., 8/1/88.
P.845 - 846 Progress Report no. 3, prepared by Geraghty and
Miller, Inc., 9/7/88.
P. 847 - 849 Progress Report no. 4, prepared by Geraghty and
Killer, Inc., 10/4/88.
P. Progress Report no. 5, NOT AVAILABLE
P.850 Progress report no. 6, prepared by Geraghty and
Miller, Inc., 12/2/88.
P. 851 - 854 Progress Report no. 7, prepared by Geraghty and
Miller, Inc., 1/2/89.
P. 655 - 856 Progress Report no. 8, prepared by Geraghty and
Miller, Inc., 2/9/89.
P.E57 - 858 Progress Report no. 9, prepared by Geraghty and
Miller, Inc., 3/8/89.
P. 859 - 862 Progress Report no. 10, prepared by Geraghty and
Miller, Inc., 4/4/89.
P.E63 - 870 Progress Report no. 11, prepared by Geraghty and
Miller, Inc., 5/19/89. Three tables and three
site maps are attached.
P. 871 - 678 Progress Report no. 12, prepared by Geragh..> ?.nu
Miller, Inc., 6/1/89. Attached are duplicates of
the attachments for progress report no. 11.
P.879 - 880 Progress Report no. 13, prepared by Geraghty and
Miller, Inc., 7/6/89.
P.881 - 895 Progress Report no. 14, prepared by Geraghty and
Miller, Inc., 8/3/89. Attached are a copy of a
site map, a table of monitoring well
specifications and sample core logs.
P.896 - 897 Progress Report no. 15, prepared by Geraghty and
Miller, Inc., 9/8/89.
p.898 - 899 Progress Report no. 16, prepared by Geraghty and
Miller, Inc., 10/5/89.
P.900 - 959 Progress Report no. 17, prepared by Geraghty and
Killer, Inc., 11/9/89. Attached are tables 1 - 7,
site naps and appendix A.
-------
P.960 - 963 Progress Report no. 18, prepared by Geraghty and
Miller, Inc., 12/11/89. Attached are a site map of
monitoring wells and a table of monitoring well
specifications.
P.964 - 975 .Progress Report no. 19, prepared by Geraghty and
Miller, Inc., 1/9/90. Attached are three site
maps, a table of water - level elevations and logs
of wells installed during 11/89.
P.976 - 984 Progress Report no. 20, prepared by Geraghty and
Miller, Inc., 2/8/90. Attached are tables 1, 2 and
a revision of 1.
P.985 - 990 Progress Report no. 21, prepared by Geraghty and
Miller, Inc., 3/5/90. Table 1 is attached.
P.951 Progress Report no. 22, prepared by Geraghty and
Miller, Inc., 4/5/90.
P.992 Progress Report no.23, prepared by Geraghty and
Miller, Inc., 5/8/90.
P.SS2 - 995 Progress Report no. 24, prepared by Geraghty and
Miller, Inc., 6/4/90.
..s^s Progress Report no. 25, prepared by Geragh* .•'--"
Miller, Inc., 7/9/90.
Re-eiial Investigation Reports
P.957 - 1137 Report: Remedial Investigation Report Revision no.
1. Mannheim Avenue Site. Galloway Township. New
Jersey. Volume I. prepared by Geraghty and Miller,
6/90.
P.1138 - 1486 Report: Remedial Investigation Report Revision no.
1. Mannheim Avenue Site. Galloway Township. New
\ Jersey. Volume II. prepared by Geraghty and
Miller, 6/90.
P.1487 - 1501 Report: Addendum to the Remedial Investigation
Report, Revision no. 1. Mannheim Avenue Site.
Galloway Township. New Jersey, prepared by
Geraghty and Miller, Inc., 7/90
Correspondence
-------
P. 1502 - 1503 Letter to Ms. Laura Lombardo, U.S. EPA, from Dr.
Robert Saar and Ms. Catherine Gilroy, Geraghty and
Miller, Inc., Re: discussions concerning the
installation of temporary well points, 5/1/89.
Procedures for installing well points below a
confining layer is attached.
P.1504 - 1505 Letter to Ms. Laura Lombardo, U.S. EPA, from Ms.
Catherine Gilroy and Dr.Robert Saar, Geraghty and
Miller, Inc., Re: revised map showing the proposed
locations for installing monitoring wells, 6/2/89.
Map is attached.
P.1506 - 1524 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from Raymond Basso, U.S. EPA, re: EPAs
review of the Draft Remedial Investigation Report,
12/89, and the Addendum to the Draft RI report,
2/90. The letter is dated 4/17/90.
P.1525 - 1537 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from Raymond Basso, U.S. EPA, re: EPA
review of Remedial Investigation Report - Revision
1, 6/90 and Draft Feasibility Study Report -
Revision, 6/25/90. EPA comments on Remedial
Investigation report, Feasibility Study report,
and an inter-office memorandum from Weston
consultants are attachf I. The date of the letter
is 7/17/90.
Quality Assurance
P.152S Letter to Ms. Laura Lombardo, U.S. EPA, from Ms.
Laura Scalise, U.S. EPA, Re: approval of the
analytical laboratory, 7/12/89.
P.1539 - 1542 Letter to Ms. Laura Lombardo, U.S. EPA, from Ms.
Laura Scalise, U.S. EPA, Re: Mannheim Avenue Site
audit site report for the CERCLA technical systems
audit performed on 8/1/89. Dated 9/8/89. The audit
is attached.
P. 1543 - 1545 Letter to Ms. Laura Scalise, U.S. EPA, from Ms.
Catherine Gilroy and Dr. Robert Saar, Geraghty and
Miller, Inc., re: case numbers assigned by ENSECO
laboratory for the ground - water samples,
1/10/90.
P.1546 - 1548 Memorandum to Ms. Laura Scalise, U.S. EPA, from
Kr. Dale Boshart, Weston/ESAT laboratory staff,
Re: comments regarding the Mannheim Avenue LF data
case generated by ENSECO, 4/26/90.
-------
FEASIBILITY STUDY
Applicable or Relevant and Appropriate Requirements Determination
P.154S Letter to Mr. Haiyesh Shah, NJDEP, from Ms. Laura
Lombardo, U.S. EPA, re: U.S. EPA requests for
information for ARARs, 11/13/89.
P. 1550 - 1565 Letter to Ms. Laura Lombardo, U.S. EPA, from
Haiyesh Shah, NJDEP, Re: post excavation soil
sampling results, 11/15/89. Attached are
calculations, a correspondence from NJDEP, and
references, 8/9/89.
P. 1566 - 1620 Letter to Ms. Laura Lombardo, U.S. EPA, from
Haiyesh Shah, NJDEP, re: New Jersey State
Applicable, Relevant and Appropriate Requirements,
12/14/89. Two additions regarding New Jersey
criterion and laws are attached.
P. 1621 - 1624 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from Ms. Laura Lombardo, U.S. EPA, re: the
applicable, or relevant and appropriate
requirements as well as criteria to be considered
(TBCs) with regard to groundwater, surface water,
air and soil quality. The letter is dated 2/12/90.
ic^r.^ilitv studv Work Plan
P. 162 5 - 1640 Report: Feasibility Study Work Plan. Mannr.ci.in
Avenue Site. Galloway Township,, New Jersey.
prepared by EDER Associates, April 1989.
Feasibility Studv Reports
P. 1641 - 1786 Report: Draft Feasibility Study Report, prepared
by Eder Associates, 6/90.
P. 1787 - 2065 Report: Final Feasibility Study Report, Mannheim
Avenue Site, Galloway Township, New Jersey,
Prepared by CDM - FPC, 7/13/90.
Correspondence
p. 2066 Letter to Stephen Piotrowski, Lenox Technical
Center, from Mr. Raymond Basso, U.S. EPA, Re: EPA
approval of Feasibility Study Work Plan for the
Mannheim Avenue Site, 6/19/89.
-------
P.2067 - 2073 Letter to Mr. Stephen Piotrowski, Lenox Technical
Center, from, Mr. Raymond Basso, U.S. EPA, Re: EPA
comments on review of Draft Feasibility Study
2/90. Dated 5/14/90. Data is attached.
ENDANGERMENT ASSESSMENT
Endanaernent Assessment Report
P.2074 - 2367 Report: Final Endangerment Assessment, Mannheim
Avenue Dump, Galloway Township, New Jersey,
prepared by A.T. Kearney, 7/90.
ENFORCEMENT
Administrative Orders
P.2368 - 2376 Administrative Order, U.S. EPA Region II,
12/7/84.
P.2377 - 2397 Administrative Order on Consent, U.S. EPA Region .
II, 4/26/88. Cover letter and Statement of Work
are attached.
P.2398 - 2420 Report: Statement of Work-Remedial Investigation
and Feasibility Study, prepared by Geraghty and
Miller, February 1988. Attached to above-]*?t»d
document.
Notice Letters and Response
P.2421 - 2423 Letter to Mr. Charles Melchior, Township Manager
of Galloway, from Stephen Luftig, U.S. EPA, Re:
notification of township as potential responsible
party, 6/10/87.
P.2424 - 2426 Letter to Mr. Stephen Lichtenstein, Lenox, Inc.,
from Mr. Stephen Luftig, U.S. EPA, Re:
notification of Lenox as potential responsible
party, 6/19/87.
PUBLIC PARTICIPATION
Public Notice
P.2427 Announcement of a public meeting held by the U.S.
EPA for discussion of proposed remedies for the
Mannheim Avenue Site. 8/7/90.
Proposed Remedial Action Plan
-------
P.^428 - 2434 Superfund Proposed Plan - Mannheim Avenue
Superfund Site Galloway Township, New Jersey,
7/90.
MISCELLANEOUS / OTHER ITEMS
P.2435 - 2449 Report: Final Report - Off Site Potable Water
Sampling,, Kannheim Avenue Site. Galloway Township,
New Jersey, prepared by CDM - FPC, 3/15/89.
P.2450 - 2460 Report: Analytical Report. Mannheim Avenue..
Galloway Township. New Jersey, prepared by Roy F.
Weston, Inc., 4/7/89.
p.2461A' Table: Metals in Water .Samples from Residential
Wells, to Laura Lombard©, U.S. EPA, from George R.
Prince, Environmental Scientist, U.S. EPA,
4/10/89.
P.2461 - 2470 Report: Analytical Report. Mannheim Avenue.
Galloway Township. New Jersey, prepared by Roy F.
Weston, Inc., 5/15/89.
------- |