United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-90/118
September 1990
&EPA Superfund
Record of Decision
Higgins Farm, NJ
Printed on Recycled Paper
-------
50272-101
REPORT DOCUMENTATION 1. REPORT NO. *
PAGE . EPA/ROD/R02-90/118
4. TMeendSuMMo
SUPERFUND RECORD OF DECISION
Higgins Farm, NJ
First Remedial Action
7. Autfior(a)
8. Performing Organization Num end Addreea
12. Sponsoring Organization Nun* and Addreea
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
i. Report Dele
09/24/90
«.
8. Performing Organization Rept No.
10. ProtacCTaek/Wark UnM No.
11. ConMcl(C) or Qr«M(G) No.
(C)
(Q)
13. Typo ol Report t Period Conrad
800/000
14.
15. Supplementary Nom
18. Abstract (Limit: 200 wordt)
The 75-acre Higgins Farm site is a cattle farm in Franklin Township, Somerset County,
New Jersey. The site is primarily pasture land with poor onsite drainage.
ground water as their drinking water source. In 1985, after receiving reports of
ground water contamination near the farm, the State investigated the area and found a
rum burial area. In 1986, the site owner began to remove the drums from the site,
cind ten drums were removed, crushed and placed in a roll-off container. Later in
1986, another 50 drums were excavated, and during the excavation the drums were
punctured and their contents spilled onto the ground. Fluids from the pit formed
during excavation activities were subsequently pumped to a holding tank while
excavation continued. In addition to excavating the drums, visibly contaminated soil
was placed in roll-off containers. In late 1986, State site inspections revealed
ground water and soil contamination by VOCs, pesticides, metals, and dioxins. Bottled
water was temporarily provided to affected residents until 1989, when the State
installed carbon filter units on affected wells. In 1987, EPA initiated stabilization
(See Attached Page)
17. Document Analytic a. Descriptor*
Record of Decision - Higgins Farm, NJ
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, TCE, xylenes), other organics, and metals
(lead)
b. Mentlflors/Open-Endsd Terms
c. COSATI Reid/Group
18. AvaMablitr Statement
19. Security Clue (Thl* Report)
None
20. Security date (Thle Page)
None
21. No. of Page*
46
22. Price
(See ANSt-Z39.18)
SM ln»trucHoiu on fttvem
OPTIONAL FORM 272 (4-77)
(Formerly NDS-3S)
Department of Commerce
-------
EPA/ROD/R02-90/118
Higgins Farm, NJ
First Remedial Action
stract (Continued)
activities at the site, including construction of a barn to store dioxin-contaminated
material such as overpacked drums and roll-off containers; draining, lining, and
backfilling of the excavation pit; treatment of the pumped liquids and storage of the
treated, liquids in a holding tank; and implementing site access restrictions. This
Record of Decision (ROD) provides a permanent safe drinking water supply source for
affected residents as part of an interim remedy. A future ROD will address remediation
of final ground water and all remaining onsite contamination including soil, sediment,
surface water, and ground water. The primary contaminants of concern affecting the
ground water are VOCs including benzene, PCE, TCE, and xylenes; other organics; and
metals including lead.
The selected interim remedial action for this site includes developing, designing, and
constructing a water main extension and distribution system; installing new carbon
adsorption units, as necessary; operating and maintaining existing carbon adsorption
units until construction is completed; conducting environmental sampling of residential
wells; removing carbon units and private well connections once the permanent water supply
is installed; and implementing institutional controls including ground water use
restrictions. Since the propsed remedy would not restore ground water to beneficial use
levels,, an interim ARAR waiver will be invoked as part of this remedial action. The
total present worth cost for this remedial action is $1,716,000, which includes a total
O&M cost of $28,200 for 2 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ARARs for drinking water are based on
:DWA MCLs and the more stringent State standards including benzene 1.0 ug/1 (State MCL),
CE 1.0 ug/1 (State MCL), and TCE 1.0 ug/1 (State MCL).
-------
PACT
«
Ix/ct
-------
DECLARATION STATEMENT
RECORD OF DECISION
HIGGINS FARM
SITE NAME AND LOCATION
Higgins Farm Superfund Site
Franklin Township, Somerset County, New Jersey
STATEMENT OF BASIS AND RESPONSE
This decision document presents the selected interim remedial
action for the Higgins Farm Superfund site developed 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 interim remedy for this site. The information
supporting this interim remedy is contained in the administrative
record for the site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent or
substantial threat to public health, welfare, or the environment.
DESCRIPTION OF REMEDY
This interim remedy will ensure that residents affected or
potentially affected by ground water contamination from the site
are provided with a safe drinking water supply. The final remedy
for the site will address the contamination of soils, sediments,
surface water and ground water. These actions will be the
subject of a future Record of Decision.
The major components of the selected remedy include:
- Development and design of a water main extension and
distribution system;
- Construction of the water main extension and connection to
the existing water supply system;
- Continued operation and maintenance of existing carbon
adsorption units until a permanent water supply is -
available;
-------
- Installation, operation and maintenance, of additional
carbon adsorption units, as necessary;
- Environmental sampling of appropriate residential wells; and
- Removal of carbon units and private well connections after
the permanent water supply is installed;
DECLARATION
This interim action is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements directly associated with
this action, and is cost-effective. This action utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, given the limited scope of the
action. Because this action does not constitute the final remedy
for the site, the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element will be addressed at the time of the final
response action. Subsequent actions are planned to address fully
the principal threats posed by this site.
:onstantine Sidamon-Eristbft//
Regional Administrator ^L-/-"
V
*^S-
-------
DECISION SUMMARY
RECORD OF DECISION
HIGGINS FARM
I. SITE NAME, LOCATION, and DESCRIPTION
The Higgins Farm site (the "Site") is located in a rural area off
Route 518 in Franklin Township, Somerset County, New Jersey. The
Site is approximately 75 acres in size. The Site is owned by Mr.
Clifford Higgins (Sr.), and is operated as a cattle farm. (See
Figure 1.) The Site is primarily pasture land and is relatively
flat and poorly drained. There are two residences on the farm,
and other residences bordering the Site to the northeast and
northwest. Trap Rock Industries Kingston Quarry borders the Site
to the south.
Two holding tanks containing contaminated water and a barn
housing excavated drums and roll-off containers containing
contaminated soils are located in the northern section of the
Site. A chain link fence surrounds the tanks, the barn and the
area where the drums were excavated. The tanks and the barn were
installed during emergency response activities conducted by the
Environmental Protection Agency (EPA). A berm was constructed to
prevent runoff from this area onto the remainder of the Site.
A small area suspected of containing buried drums is fenced in
the southwest portion of the Site. Demolition debris, including
bricks, asphalt, metal scrap, and concrete, is also found near
the suspected drum burial area.
Within a three-mile radius of the Site, approximately 3,200
people rely on ground water for their drinking water source.
This includes 494 private wells in Franklin Township, Somerset
County; 51 private wells in South Brunswick, Middlesex County;
and the Rocky Hill Municipal Wells in Somerset County, which
serve 285 residences.
A pond, located in the southeast portion of the Site, discharges
through an unnamed tributary to Carter Brook, approximately 2,000
feet to the east. The closest downslope surface water is Carter
Brook, which is used for recreation. The Delaware-Raritan Canal
and the Millstone River flow to the west of the Site. There are
no coastal wetland areas within 2 miles of the Site and there are
no freshwater areas within a 1 mile radius. There are no known
critical habitats for federally endangered species, or National
Wildlife Refuges within a 1 mile radius of the Site. However,
Washington's Headquarters, a national historic district, is
located approximately 1.1 miles southwest of the Site.
Higgins Farm is believed to be underlain by two main water-
bearing zones. These zones are an unconfined saturated zone in
-------
n. ,
Ket;...
c
MDNMOUTK JUNCTION QUADRANGLE
NEW JERSEY
1* MIN'JTE SERIES (TOPOGRAPHIC)
:A.E 1.24000
1 "lit
icxr
i or
«ooc too: tax
» .s
.
f. tix~.lt V S-Cf
M- ;si.
HlGGrNSFARM
FIGURE 1
-------
unconsolidated sediments and a water-bearing zone in fractured
bedrock. It is believed that ground water beneath the Higgins
Farm site flows to the southwest. More definitive hydrogeologic
data will be collected during the ongoing remedial investigation
and feasibility study.
II. SITE HISTORY and ENFORCEMENT ACTIVITIES
In December 1985, the Franklin Township Health Department
reported to NJDEP that elevated levels of chlorobenzene existed
in a potable well located at Route 518, Franklin Township,
Somerset County, New Jersey. NJDEP investigated and discovered
the presence of a drum burial dump at the Site approximately
forty yards from the contaminated well.
On January 2, 1986, NJDEP investigated drum excavation activities
initiated by Mr. Higgins and his contractor at the Site. The
excavation was halted by NJDEP as the activity was not approved
by NJDEP. An estimated ten drums were removed, crushed and
placed in a roll-off container.
On April 7, 1986, a contractor employed by Mr. Higgins commenced
excavation of buried drums. The contractor located buried drums
by probing the ground with a back hoe. Approximately fifty drums
were excavated in this manner. During excavation activities,
drums were punctured and their contents spilled onto the ground
as the drums were excavated. The pit formed resulting from this
activity is referred to as the excavation pit. Fluids were
pumped from the excavation pit to a holding tank and excavation
continued; visibly contaminated soils were placed in roll-off
containers and approximately ten drums were overpacked.
On April 26, 1986, NJDEP sampled ten residential wells in the
vicinity of the Site and discovered three wells exhibiting
volatile organic contamination. Nine of the ten residential
wells were resampled by NJDEP in August 1986. Analysis confirmed
the presence of volatile organic contamination.
On May 8, 1986, NJDEP personnel inspected the Site and collected
soil samples from the drum excavation pit area. Analysis of
these samples indicated the presence of volatile organic
compounds, pesticides, metals and dioxins in the soils at the
Site.
On July 3, 1986, a repeat sample from the vicinity of the drum
excavation pit was collected. Analysis confirmed the presence of
dioxins and associated furans.
In November 1986, NJDEP established a "well impact area" near the
Higgins Farm site, restricting installation of new wells within
the affected area. Thirty-one residences were included within
the well impact area at Higgins Farm.
-------
In March 1987, EPA responded to the presence of contamination in
drinking water wells neighboring the Site by providing bottled
water to potentially impacted area residents. At that time, the
EPA explained that it would provide bottled water as an interim
solution until an alternate water supply could be arranged by
NJDEP. Thereafter, NJDEP determined that the most appropriate
method to supply potable water was to install individual carbon
units at the potentially impacted homes. NJDEP installed the
carbon filter units during the spring/summer of 1989, at which
time bottled water delivery was discontinued. The carbon filter
units were intended to limit ingestion of volatile organic
compounds and mitigate the potential for human exposure via
inhalation of volatile organic compounds through household use.
On April 8, 1987, EPA initiated activities to stabilize the Site
and to control the release of hazardous substances into the
environment. Actions taken included:
a. the construction of a barn to house material that may
be dioxin contaminated, including, but not limited to,
overpacked drums and roll-off containers;
b. the excavation pit was drained, lined and backfilled;
c. the pumped liquids were treated and stored in a holding
tank; and
d. the drum burial area was fenced to prevent access by
unauthorized persons.
In December 1989, NJDEP advised EPA that it could not monitor and
maintain the carbon units beyond the spring of 1990. On February
2, 1990, EPA authorized $625,320 under the removal program to
monitor and maintain the carbon filter units for approximately
two years.
The Site was proposed for inclusion on the National Priorities
List (NPL) in June 1988. EPA began investigations to identify
potentially responsible parties (PRPs) for the contamination at
the Site. In March 1989, the Site was formally placed on the
NPL, thus making it eligible for federal funds to investigate the
extent of contamination and to clean up the Site. In March 1989,
EPA notified six PRPs of their potential liability. EPA offered
these PRPs the opportunity to conduct or finance the RI/FS for
the Site; however, the PRPs declined to undertake the RI/FS.
Because the PRPs declined to undertake the RI/FS, EPA allocated
funds for the studies to be conducted under EPA supervision
through its contractors. During the RI/FS, investigatory work is
performed to determine the nature and extent of contamination and
to determine to what extent the Site may have been impacted by
the contaminant migration.
-------
EPA has since identified one additional PRP, who also declined to
undertake the RI/FS.
On October 17, 1989, EPA offered the PRPs the opportunity to
install a waterline along Route 518 to service the residents
impacted and potentially impacted by the Higgins Farm site to
provide a more permanent solution to the water supply problem.
In February 1990, EPA informed the seven PRPs that EPA had not
received an acceptable offer to install the public water supply.
On March 20, 1990, EPA issued an Administrative Order to Mr. &
Mrs. Clifford Higgins to install the waterline. Mr. & Mrs.
Higgins have failed to comply with the order.
In June 1990, EPA released the Focused Feasibility Study Report
("FFS Report") and EPA's Proposed Plan for the construction of a
water line extension to the public. A public comment period was
provided, beginning on June 28 and ending on July 30, 1990.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) for the Higgins Farm site was
finalized in March 1990. The CRP lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination
of pertinent information.
The Proposed Plan for the interim remedy was released to the
public, including the seven identified PRPs, on June 25, 1990.
The FFS Report was released to the public on June 28, 1990. Both
the FFS Report and the Proposed Plan are contained in the
administrative record at Information Repositories which are
maintained at the Mary Jacobs Memorial Library, the Franklin
Township Library and at EPA's Region II Office in New York City.
The notice of availability for these two documents was published
in The Home News on June 28, 1990. A public comment period was
held from June 28 to July 30, 1990. In addition, a public
meeting was held on July 2, 1990 to present the Proposed Plan for
the Site. At this meeting, representatives from EPA answered
questions regarding remedial alternatives under consideration and
problems at the Site. All comments which were received by EPA
prior to the end of the public comment period, including those
expressed verbally at the public meeting, are addressed in the
Responsiveness Summary which is attached as Appendix I to this
Record of Decision.
-------
IV. SCOPE AND ROLE OF INTERIM REMEDY
EPA has taken limited response actions related to the drinking
water supply problem at the Site. Prior to listing the site on
the NPL, in March 1987, EPA responded to the presence of
contamination in drinking water wells neighboring the Site by
providing bottled water to potentially impacted area residents.
In addition, EPA performed actions to stabilize the Site and
control the releases of hazardous substances in April 1987. On
February 2, 1990 EPA authorized funding under the removal program
to monitor and maintain the carbon filter units installed by
NJDEP for approximately two years.
These limited response actions have only partially addressed the
problems at the Site. EPA has elected to address the drinking
water supply problem through an interim remedy because of the
threat posed by the actual and potential use of contaminated
ground water. In this ROD, EPA is selecting an interim remedial
action to provide a permanent alternate water supply to affected
and potentially affected residents. Installation of an alternate
water supply is considered an interim solution for ground water
contamination, since it does not address the problem of restoring
the ground water to its beneficial uses.
The goal of this interim action is to eliminate actual or
potential exposure to contaminated ground water. Such a goal is
consistent with any potential future remedy which EPA will select
for the Site. The "final remedy" for the Site (addressing soils,
sediments, surface water, and ground water) will be proposed at
the conclusion of the RI/FS. The selected interim remedy will be
part of a future permanent remedy which will protect human health
arid the environment.
V. SUMMARY OF SITE CHARACTERISTICS
The full extent of contamination at the Site is currently being
evaluated in the ongoing RI/FS. However, several potential
sources of contamination at the Site have been identified. The
following provides a brief summary of the sampling and analyses
conducted of ground water, soil, surface water, and containerized
wastes at the Site. The complete results of all sampling
activities are presented in further detail in the FFS Report.
Setmpling of Containers at the Site
In 1987, various containers at the Site, including drums, roll-
off containers, and tanks, as well as liquids from the excavation
pit, were sampled by a contractor hired by Mr. Clifford Higgins,
the Site owner. The analyses revealed the presence of numerous
organic and inorganic chemical contaminants, including, but not
limited to, chloroform, ethylbenzene, toluene, xylenes,.
naphthalene, 2-methyl naphthalene, pentachlorophenol, arsenic,
-------
cadmium, chromium, and lead. In addition, the analyses revealed
that the wastes in several of the containers were "hazardous
wastes" under the Resource Conservation and Recovery Act, due to
corrosivity, toxicity, and flammability. Maximum concentrations
of some of the contaminants detected are shown in Table 1, below.
Table l
Example of Contaminants Detected; Containers at the Site
Compound Maximum Concentration Detected fppb)
Chloroform 35,300
Ethylbenzene 18,500
Toluene 37,500
Total Xylenes 224,000
2-Methyl naphthalene 90,000
Naphthalene 7,600
Pentachlorophenol 2,340,000
Arsenic 99,250
Cadmium 375
Chromium 57,500
Lead 7,000
Soils and Pond Sampling
In 1986, NJDEP collected and analyzed samples from the pond at
the Site, as well as samples of surface soils. The analyses
revealed that the soil at the Site is contaminated with volatile
organic compounds, base/neutral compounds, metals, cyanide,
dioxins and phenols. In addition, several of these contaminants
were present in the pond.
Among the contaminants detected in soil samples were numerous
hazardous substances including, but not limited to, chloroform,
1,1,2,2, tetrachloroethane, naphthalene, pentachlorophenol,
phenanthrene, pyrene, bis(2-ethylhexyl)phthalate, phenols,
dieldrin, endrin, arsenic, cadmium, chromium, lead, zinc, and
dioxins.
-------
Maximum concentrations of some of the contaminants detected are
listed in Table 2, below.
Table 2
Example of Contaminants Detected; Soils/Pond at the Site
Compound Maximum Concentration Detected (ppb)
Chloroform 11
1,1,2,2, Tetrachloroethane 4.4
Naphthalene 58
Pentachlorophenol 77,000
bis(2-ethylhexyl) Phthalate 1,500
Total Phenols 1,900,000
Dieldrin 11,000
Endrin 150
Arsenic 15,000,000
Cadmium 1,900,000
Chromium 18,000,000
Lead 140,000,000
Zinc 81,000,000
Additional sampling conducted by NJDEP during 1986 confirmed the
presence of numerous dioxins and furans.
Ground water
Ground water samples from residential wells on or near the Site
have been collected on several occasions between 1986 and 1990.
Figures 2 and 3 show the locations of the residences sampled.
Numerous organic contaminants have been detected in several of
these wells, including, but not limited to, benzene,
chlorobenzene, 1,2-dichloroethane, 1,1,2-trichloroethane,
tetrachloroethene, trichloroethene, 1,2-dichlorobenzene, and
xylenes. In addition, numerous other contaminants, including
pitithalates, naphthalenes, and metals such as chromium, mercury
and lead, which are hazardous substances pursuant to Section
101(14) of CERCLA, 42 USC §9601(14), were detected in the
residential wells.
-------
legend:
APPROXIMATE SCALE IN FEET
0 (D
R-9 R-10
ROUTE 518
Appronlmau location ol domestic well
samplnd in 1985
Gas pipeline
Demolition debris
Eicavation pit
Holding tanks
Dirt road
Telephone line
Area ol nine drums
Mound
1. All locations are approximate
2. SHe boundary based on lax
mapinHnS (EPA 1986)
FIGURE 2
DOMESTIC WELLS SAMPLtu
IN DECEMBER 1985
AND JANUARY 1986
-------
BASED ON TAX MAP
r HANK! IN TOWNSHIP
SOMERSEI COUNIY. NJ
we* (R I IhniR JO)
KICIIRF. 3
RESIDENTIAL WELLS
SAMPLED BY COM NOVEMBER 1988
HIGGINS FARM
-------
Table 4
Contaminants Detected in Soils at the Higgins Farm Site
Compound
Chrysene
N-Nitrosodiphenylamine
Total phenols
Dioxins
Furans
Location Detected
Site8 Ground Water6
J
J
VOCs:
Chloroform
Ethylbenzene
1.1.2.2-Tetrachloroethane
Trichloroethene
Total xylenes
Methylene chloride
Toluene
J
J
METALS:
Antimony
.Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Magnesium
...
NJR56016R56.5L2
-------
Table 4
Contaminants Detected in Soils at the Higgins Farm Site
Compound
Location Detected
Site3 Ground Waterb
Pesticides:
Endrin
Chlordane
Dieldrin
beta-BHC
...
BNAs:
Acenaphthene
Acenaphthylene
bis(2-ethylhexyl)phthalate
Naphthalene
2-Methyl naphthalene
2.4-Dimethylphenol
Pentachlorophenol
4-Methylphenol
Di-n-butyl phthalate
2.4-Dinitrotoluene
Fluorene
Dibenzofuran
Dimethylphthalate
Phenanthrene
Fluoranthene
Anthracene
Pyrene
Benzo(a)anthracene
J
J
J
J
J
J
NJR56'016R56.5i:i
-------
Table 4
Contaminants Detected in Soils at the Higgins Farm Site
Compound
Manganese
Mercurv
*
Nickel
Selenium
Silver
Zinc
Location Detected
Site8 Ground Water15
J - Estimated value - Concentration detected is less than the method detection limit.
Not reported.
"Based on presence in any of the following: drums, roll-off, holding tank, excavation
pit. soils, and pond sampling events. Because analyses for the listed contaminants
were performed on various media, the numerical results are not directly comparable
and thus are not listed. See applicable tables in Section 1 of this report.
bBased on presence in any residential well samples.
NJR56'016R56.51.3
-------
8
Maximum concentrations of some of the contaminants are shown in
Table 3, below.
Table 3
Example of Co^f»mir^nts Detected; Ground Water at or Near the
Site
Compound Maximum Concentration Detected (ppb^
Benzene 480
Chlorobenzene 880
1,2-Dichloroethane 395
1,1,2-Trichloroethane 2,924
Tetrachloroethane 370
Trichloroethene 23
1,2-Dichlorobenzene 67
Total Xylenes 9
Naphthalene 8
Chromium 43
Mercury 0.6
Lead 12
In summary, chemical contamination has been found in ground water
and surface soil samples on and near the Site. In addition,
contaminants have been detected in containers at the Site. Those
contaminants included volatile organics, base/neutral compounds,
metals, pesticides, and dioxins. Although the hydrogeology at
the Site has not yet been fully characterized, the substances
present at the Site, in containers and soils, have been
demonstrated to migrate to ground water.
Table 4 summarizes those chemicals which have been found in
either containers, including drums, rolloff containers and tanks,
or soils at the Site, and those found in ground water. As
evidenced by this table, the volatile organic compounds detected
on the Site have all been found in residential wells. Similarly,
many of the metals found at the Site were also found in ground
water. However, none of the base/neutral compounds, pesticides,
clioxins, or furans have as yet, been found in the ground water.
This is because these compounds are generally lower in mobility
and less soluble than the volatile organics. However, in time,
these compounds could mobilize, and migrate to area ground water.
VI. SUMMARY OF SITE RISKS
An analysis of the residential ground water sample results was
conducted by EPA through its contractor during the FFS to
determine health impacts which could potentially result from the
contamination at the Higgins Farm site.
-------
T;ihlc 5
CONTAMINANT SPPCIFIC CRITERIA AND TBCs FOR GROUND WATER
Compound
Highest
Concentration
Detected
(ppb)
Location
Where Highest
Concentration
Was Delected
Fedcr;il SDWA'
MCLG
(pph)
MCL
(HP*)
SMCL
(Pph)
USEPA Health
Advisory11
(PP*>>
New Jersey
SDWA MCLC
(pph)
Health
Risk- Based
Leveld
(PPI>)
VOCs:
Ben/cne
Chlorohen/.cne
Chloroform
Dihromochtoromeihane
Ethylhen/ene
I.l-Dichloroeihene
1 ,2-Dichloropropane
1,2-Dichloroeihane
I.l-Dichloroeihane
1 . 1 .2.2-Tctrachluroeihane
Tetrachloroelhene
trans- 1,2-Dichloroelhene
1 , 1 ,2-Trichloroeihane
Trichloroelhene
Vinyl chloride
Carbon disulfide
Total xylcnes
480
8X0
0.23
1.17
0.59
6
IJ
395
2
11
370
47
2.924
23J
120
7
9
R-l
R-l
R7
R7
R 1
R6
R6
R6
R 1
R6
R-5
R-l
R-6
R 1
R6
R-8
R-l
0
KXl'
...
...
7(Xl'
7*
0'
0
...
...
0*
too*
V
0
0
...
10,000*
5
100*
lOtC
100*
700'
7*
5'
5
...
...
5*
100*
3"
5
2
...
10,000*
100*
30"
20*
...
...
100
71)0
7
...
2.«K)
...
...
5,000
too
3
...
50
...
100.000
1
4
...
...
...
2
2
...
...
1
10
1
2
...
44
0.38-38 0.5*"
0.013- 1.3 0.5*«*
3,500
-------
Tahlc 5
CONTAMINANT - SPF.CIFIC CRITERIA AND TBCs FOR GROUND WATER
Compound
Highest
Concentration
Detected
(pph)
Location
Where Highest
Concentration
Was Detected
Federal SDWA"
MCLG
(Ppf>)
MCL
(pph)
SMCL
(Pph)
USEPA Health
Advisory1"
(PP»>)
New Jersey
SDWA MCLC
(ppt>)
BNA.1:
1.2-Dichlomhcn/ene (orlho)
M-Dichloroben/ene (para)
Naphthalene
N-Niirosodiphenylamine
2-Melhyl naphthalene
Tula! phenols
67
39.H*
8J
4J
17
82
R-l
R-l
R-IO
R9
R-IO
R-l
600*
75
...
...
...
6(10*
75
...
...
...
1(1*
5'
600
75
300
...
4.000
600
...
...
...
...
METALS:
Aluminum
Barium
Calcium
Chromium
Cupper
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Selenium
Sodium
44
48
57,910
43
46
72.100
12
20,610
480
0.6
971
26
21,650
R6
R-3
R6
R2
R7
R-19
R3
R6
R 19
R8
R-3
R-7
R2
...
5.000*
...
100*
1,300*
...
...
...
...
...
50*
...
...
1. 000. 5,000*
...
50, 100*
1.300*
...
50, 5*
...
...
2
10, 50*
...
50*
i.ono
300
50
...
5.000
...
100
...
...
...
...
...
2
...
...
.
1.000
50
1,000*
300*
50
...
50«
2
...
10
50,000*
Health
Risk-Based
Leveld
(PPb)
140
7-700
1,400
21.000
NA
NA
NA
-------
T;ihlc 5
CONTAMINANT SPRCIFIf CRITERIA AND TBCs FOR GROUND WATER
Compound
Vanadium
Zinc
Highest
Concentration
Delected
(pph)
46
5JN9
Local ion
Where Highest
Concentration
Was Dclctlcd
R-ft
R-l
Federal SDWA"
MCLG
(Ppb)
...
...
MCL
(ppb)
...
...
SMCL
(Ppb)
5,1X10
USEPA Health
Advisory1*
(PPb)
...
...
New Jersey
SDWA MCLC
(ppt>)
...
5.00()«
Health
Risk -Based
Levcld
(PPb)
320
All compounds detected in ground water samples up 10 April 1990 are included in this (able except for acetone, 2-butanone. his(eihylhexyl)phihalate, di-n-butyl phthalaie, methylene chloride, and
toluene as these were esiimated below the method detection limit and are common laboratory or field sampling contaminants.
Currently, there is no established guideline or standard for this parameter.
"Safe Drinking Water Act. National Primary Drinking Water Regulations, Maximum Contaminant Levels (MCLs) (40 CFR 141.11 - 141.16. 141.50 - 141.61), Maximum Contaminant Level Goals
(MCLGs), and Secondary Maximum Contaminant Levels (SMCLs). MCLs are the enforceable standards.
hDrinking Water Regulations and Health Advisories. Office of Drinking Water, U.S. Environmental Protection Agency. April 1990. Levels noted represent the health advisories for lifetime
exposure of an adult. In the absence of lifetime health advisory, the health advisory for longer-term exposure of an adult was used.
lNew Jersey Safe Drinking Water Act Maximum Contaminant (MCLs) (NJAC 7:10-5. 7:IO-lf>).
''Levels for l.l-dichloroelhane, 1.1.2,2-lelrachloroeihane, and N-nilios
-------
K_~
ll*iu»»a»»
linu*nxkn<
I.M»il«iiiiiili«il
1.1-nfcMmMttaOT
LUI-T.ntt~.ta.
r,***.
inn* I.I nw*wrv4wM
t.l.2T(faMvtwtkM*
T**n~«~*
Vbifio*«4*
W**Mi
_
_
_
_
_
II
_
_
._
_
M
R
W
m
m
m
m
NS
MS
MS
NS
NS
HI
m
i
_
_
itt
-.
_
&«>
»
u
_
MS
_
_
14
._
._
u
u
NS
_
._
_
_
_.
_
_
..
_
ft
I
._
._
_
__
._
.
..
_
_
u
_
_
_
_
_
_
_
_
_
w
_
NS
_
_
_
_
_
_
_
_
_
NS
__
_
_
._
_
_
._
_
_
I
._
_
_
_
_
._
._
._
4
_
_
_
^
_
._
._
._
._
Ht
NS
NS
N*
NS
NS
NS
NS
NS
NS
tn
m
NS
Mt
NS
NS
NS
N5
NS
NS
NS
NS
NS
NS
NS
HJ
NS
NS
NS
M
NS
Hi
Mt
NS
NS
m
NS
*-tt
It*
_
_
-
-
_
_
IU
n
_
i«
_
MS
ll«^
_
_
_
_
_
111
IM
-.
-
_
NS
»
_
_
-
_
_
.-
-.
_
.-
19
.-
NS
4W
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1
Ml
NS
Ml
NS
NS
NS
NS
NS
HS
NS
NS
NS
NS
-U
IUM
_
_
-
-
-
-
_
_
1M
-
-
NS
Ml
NS
NS
NS
m
NS
NS
NS
NS
NS
NS
NS
NS
C^Hm
U
4<
U
l«
o»
tl\ U
It
»
)t
!
!
10
- N tatart I F
nM>« M«* NS
-------
The data revealed that at least 23 chemicals and several metals
were detected in the residential wells. Some of these chemicals
are suspected carcinogens in humans or are known carcinogens in
animals (1,2-dichloroethane, tetrachloroethylene,
trichloroethylene). Other chemicals detected in the samples are
known human carcinogens (vinyl chloride and benzene). All of
these compounds are hazardous substances within the meaning of
the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA).
To date, no quantitative Risk Assessment has been performed,
however, the contaminant levels in the ground water were compared
to federal drinking water standards (Maximum Contaminant Levels
(MCLs) established under the Safe Drinking Water Act), State
MCLs, EPA Health Advisories, and other criteria. In the absence
of federal or state standards, EPA has used an "excess cancer
risk" range of IxlO"4 to IxlO"6 (i.e., as an upper bound, an
individual has a one in one million chance of developing cancer
as a result of Site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a site)
to determine if remedial action is necessary. The criteria used
by EPA are summarized in Table 5. Upon comparison, eleven of
these chemicals exceeded the standards and guidelines in a total
of five homes within the well impact area. (See Table 6.)
As evidenced by the data collected to date, there has been
migration of contaminants from the Site into residential wells.
Pathways of migration of these hazardous substances to human
receptors include ingestion and household use of ground water.
Because the full extent of the contaminant plume and the
migration pathway to residents has not been determined, all
residences in the well impact area may be potentially at risk of
exposure and therefore potentially affected by the contamination
at 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.
VII. DESCRIPTION OF ALTERNATIVES
The following four alternatives were evaluated for the interim
remedy:
ALTERNATIVE 1; No Further Action
Capital Cost: $ 42,000
Annual Operation and
Maintenance (O&M) Costs: $ 94,200
Present Worth: $ 930,000
Months to Design and Construct: 0 months
-------
10
The Superfund Program requires that the No Further Action
alternative be evaluated at every Site to establish a baseline
against which other alternatives may be compared. Under this
alternative, EPA would discontinue maintenance of the carbon
adsorption units at the residences. EPA would perform periodic
sampling and report the contaminant levels to residents. No
further action would be taken with respect to household use of
ground water.
ALTERNATIVE 2; Connect to Existing Water Supply
Capital Cost: $ 1,257,700
O&M Costs: $ 28,200
Present Worth: $ 1,716,000
Months to Design and Construct: 6-24 months
This alternative involves supplying the residences with
uncontaminated water from an existing water supply. The
residences would be connected to an existing public water supply,
such as the South Brunswick Water and Sewer system, through an
extension of the watermain. The Franklin Township Water
Department, which would purchase the water supply from the South
Brunswick Water and Sewer, would assume responsibility for
distributing the water to the residents and maintaining the
watermain extension. The Franklin Township Water Department
would also be responsible for setting rates, in accordance with
State regulations.
To ensure residents have a clean water supply during the time
period to needed design and install the watermain extension, the
carbon adsorption units would be monitored and maintained. The
existing carbon adsorption units would be removed after the homes
are hooked-up and the water supply is functioning.
Because the use of affected or potentially affected wells may
present a long-term risk to public health, when the water main is
constructed, the affected and potentially affected wells will be
disabled. Furthermore, NJDEP would continue to restrict and
regulate future construction or use of private wells within the
area previously designated by NJDEP as the well impact area.
The anticipated time to design and construct a water main
extension and distribution system is approximately six months.
However, permitting procedures and other implementation
constraints could increase the installation time period to two
years.
-------
11
ALTERNATIVE 3; Development of New Community Well
Capital Cost: $ 1,428,000
O&M Costs: $ 47,600
Present Worth: $ 2,069,000
Months to Design and Construct: 1-2 years
This alternative is similar to Alternative 2. It involves
locating and installing a new well in the vicinity of Higgins
Farm, and storing and distributing the water to the residences.
For the purposes of preparing a cost estimate, it was assumed
that the water would require treatment (an air stripper located
at the supply well) prior to storage or distribution. A pipeline
would be constructed to deliver the water to the homes. As in
Alternative 2, the Franklin Township Water Department would
assume responsibility for distributing the water supply and
ensuring water quality.
As with Alternative 2, the existing carbon units would be
monitored and maintained until the water supply is operational.
Upon completion of the water supply system, the affected and
potentially affected private wells will be disconnected. Future
construction of wells within the well impact area would also be
restricted by NJDEP, as in Alternative 2.
The anticipated time to locate and install a supply well and the
water distribution system is approximately one year. However,
permitting procedures and other implementation constraints could
increase the installation time period to two years.
ALTERNATIVE 4; Continued Treatment of Ground Water
Capital Cost: $ 151,000
O&M Costs: $ 114,700
Present Worth: $ 1,232,000
Months to Design and Construct: 0 months.
Under this alternative, in-home ground water treatment would be
utilized to provide a potable water supply until ground water
quality is restored. At that time, the in-home treatment units
could be removed. Ground water restoration methods, if feasible,
will be proposed in the final remedy upon the completion of the
RI/FS for the Site.
This alternative provides for the continued treatment of ground
water at all residences affected or potentially affected by the
contamination from the Site through the use of carbon adsorption
units. The carbon adsorption process involves contacting the
contaminated ground water with activated carbon; the contaminants
are then held on the carbon by chemical/physical forces.* The
-------
12
carbon units would treat ground water to an acceptable level
protective of human health and provide a clean source of potable
water.
The dual carbon adsorption units installed by NJDEP would be
monitored and maintained under this alternative. Iron filtering
devices necessary to ensure the effectiveness of the carbon
adsorption units would also be maintained. Samples would be
collected 5 times annually for VOCs and 1 time annually for
priority pollutants from the carbon adsorption units to permit
detection of contaminant breakthrough. Carbon adsorption units
would be replaced upon detection of contaminants between the
units.
For the purposes of this alternative, it is assumed that ground
water treatment through carbon adsorption units would be required
at all affected or potentially affected residences for thirty
years.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The selected remedy is to take interim action at the Site by
implementing Alternative 2. This alternative provides reliable
protection of human health and appears to provide the best
balance of tradeoffs with respect to the criteria that EPA uses
to evaluate alternatives. This section profiles the four
alternatives developed for the interim action against the
performance criteria which apply to this action.
Overall Protection of Human Health and the Environment:
This criterion addresses whether or not a remedy provides
adequate protection and describes how risks are eliminated,
reduced or controlled through treatment, engineering controls or
institutional controls.
Alternative 1 would not be protective of human health and the
environment. Discontinuing maintenance of the carbon units would
result in actual and potential human exposure to contaminated
ground water in excess of health advisory levels and Maximum
Contaminant Levels established under by the Federal Safe Drinking
Water Act and State drinking water regulations.
Alternatives 2, 3 and 4 would be protective of human health. The
water distributed to the residents would meet or exceed Federal
and State drinking water standards. Alternative 2 would provide
the greatest protection of human health, without monitoring, by
eliminating the exposure pathway to human receptors (i.e., in-
home use of ground water); a municipal water supply is also
periodically tested, as required by the State, to ensure that
drinking water standards are met.
-------
13
While Alternative 3 is expected to be protective of human health,
there is a potential for contaminated ground water to impact the
new water supply well developed in the area of the Site, since
the full extent of ground water contamination from the Higgins
Farm site has not yet been determined.
Alternative 4 removes contaminants from potable water supplies,
but requires constant monitoring and maintenance to ensure its
effectiveness. With Alternative 4, there is a possibility that
significant changes in influent concentrations of contaminants
could result in premature contaminant breakthrough, thus creating
exposure to contaminants above Federal and State standards.
Overall, Alternative 2 is most protective as it will provide a
consistent and reliable source of potable water.
Compliance with ARARs;
This criterion addresses whether or not a remedy will meet all of
the applicable or relevant and appropriate requirements of other
environmental statutes and/or provide grounds for invoking a
waiver. There are several types of Applicable or Relevant and
Appropriate Requirements (ARARs): action-specific, chemical-
specific, and location-specific. Action-specific ARARs are
technology or activity-based requirements or limitations related
to various activities. Chemical-specific ARARs are usually
numerical values which establish the amount or concentrations of
a chemical that may be found in, or discharged to, the ambient
environment. Location-specific ARARs are restrictions placed on
the concentrations of hazardous substances or the conduct of
activities solely because they occur in a special location.
CERCLA provides that if an interim measure is conducted, certain
ARARs may be waived for the duration of the interim action, since
these requirements will be achieved upon completion of the
permanent remedy. Because Alternatives 1, 2, 3 and 4 constitute
interim actions, final cleanup standards for contaminants in
soils and ground water do not have to be set or achieved during
this action; the final remedy for the Site will address soil
treatment and ground water restoration as well as potential
impacts to wetland areas, cultural resources, or endangered
species.
However, other ARARs related to implementation of the interim
action would have to be achieved.
Alternative 1 would not meet federal or state drinking water
standards since without maintenance of the carbon adsorption
units, some of the potable wells would exhibit levels of
contamination above Maximum Contaminant Levels.
-------
14
Alternatives 2 and 3 will comply with drinking water ARARs. The
water to be supplied by the Franklin Township Water Department
under Alternatives 2 and 3 would consistently meet federal and
state standards. Periodic sampling would be required of the
Franklin Township Water Department, which would operate the water
supply, to ensure that drinking water standards are met.
Alternative 4 is expected to comply with drinking water ARARs,
but as stated above, changes in contaminant concentrations could
cause a failure of the filter units, and result in human exposure
to water which does not meet drinking water ARARs. Recovery or
disposal of the spent carbon units generated under this
Alternative would have to comply with the federal Resource
Conservation and Recovery Act and New Jersey hazardous waste
regulations. Although less likely than Alternative 4,
Alternative 3 could also result in exposure to contaminants in
excess of drinking water ARARs, in the event that the ground
water in the area of the new supply well is affected by the Site.
Franklin Township and Somerset County have review procedures
concerning municipal water supply extensions. While such
procedures are not ARARs, they are To Be Considered (TBC)
criteria. Compliance with TBCs is not required; however, EPA
would attempt to comply with substantive permit requirements.
Long-term Effectiveness and Permanence:
This criterion refers to the ability of the remedy to maintain
reliable protection of human health and the environment over time
once cleanup goals have been met.
Alternative 1 is not effective as residents would be exposed to
contaminants in their water supply.
Alternative 2 would be the most permanent action and would
provide the most reliable protection of human health over time.
Connection to an existing water supply would eliminate the
potential exposure of residents to contaminated ground water
through ingestion or other household uses.
Alternative 3 would also be a permanent action and would provide
reliable protection of human health over time. However, there is
a potential for contaminants to migrate from the Site and affect
-------
15
Alternative 4 is an effective action which reduces potential
exposure to contaminants by removing contaminants from ground
water. Carbon adsorption technology has been demonstrated to be
effective in removing volatile organic compounds from the ground
water. However, Alternative 4 requires long-term monitoring and
maintenance to ensure the quality of the water delivered to
residences. Since the full extent of the contaminant plume has
not been delineated, significant changes in influent
concentrations of contaminants could result in premature
contaminant breakthrough, and thus human exposure to
contaminants. Also, it must be noted that contaminants other
than volatile organics have been detected at the Site, and have
migrated or may migrate to area ground water. Alternative 4
merely reduces the risk of potential exposure to contaminated
ground water.
Unlike Alternative 2, Alternative 4 does not eliminate the
potential for exposure, and Alternative 3 poses uncertainties
about long-term reliability.
Alternatives 2, 3 and 4 will be consistent with any future action
taken at the Site with respect to ground water, since they attain
the goal of eliminating actual or potential exposure to
contaminated ground water until a final ground water remedy can
be implemented.
Reduction of Toxicity. Mobility, or Volume;
This criterion addresses the degree to which a remedy utilizes
treatment technologies to reduce the toxicity, mobility or volume
contaminants.
Although not designed to reduce toxicity, mobility or volume of
contaminants in the ground water, Alternative 4, through carbon
filtration, does provide a minimal degree of treatment, which
should remove some contaminants from the potable water.
Similarly, Alternatives 2 and 3 also provide such treatment
during the period prior to development or connection to the new
water supply.
This criterion will be considered fully following the completion
of the RI/FS, when the extent of contamination has been defined
and treatment technologies will have been evaluated.
Short-term Effectiveness:
This criterion considers the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
-------
16
Alternative 2 provides reliable protection of human health by
providing a permanent alternate water supply most quickly,
followed by Alternative 3.
Alternative 4 requires only continued maintenance of the existing
carbon filter units. Since Alternatives 2 and 3 also require
continued maintenance of the carbon units until the public water
supply is operational, Alternatives 2, 3 and 4 have similar
short-term risks with respect to the potential for human exposure
to contaminated ground water, since carbon filter units will be
maintained as in Alternative 4 until a new potable water system
is; in place.
Implementability;
This criterion examines the technical and administrative
feasibility of a remedy, including availability of materials and
services needed to implement the chosen solution.
All of the alternatives are implementable. Alternatives 2 and 3
would require coordination with Franklin Township and the
community with respect to substantive permit requirements,
obtaining variances along the right-of-way for the water line and
the water tank, and access to residents' property to connect each
home to the water line.
Maintenance of the carbon units on an interim basis, as outlined
in Alternatives 2, 3 and 4, is simplified since the carbon
adsorption units are owned by NJDEP and are already in place.
Alternative 3 would require additional study to locate and
develop an alternate water supply well. This requirement would
increase the time necessary for implementation of the
alternative.
Alternative 4 would require considerable coordination with the
community with respect to obtaining continued access to monitor
and maintain the carbon adsorption units for 30 years.
Cost;
This criterion includes special capital and operation and
maintenance costs.
The cost of implementing each alternative is as follows:
Alternative 1: $ 930,000
Alternative 2: $ 1,716,000
Alternative 3: $ 2,069,000
Alternative 4: $ 1,232,000
-------
17
It should be noted that the costs were developed to cover a
thirty year implementation period. In addition, Alternatives 2
and 3 have the highest capital costs, while Alternative 4 has a
higher annual 0 & M cost.
State Acceptance;
This criterion indicates whether, based on its review of the FFS
and the Proposed Plan, the State concurs with, opposes, or has no
comment on the proposed alternative. The State of New Jersey has
not yet concurred with the selected remedy.
Community Acceptance;
The results of the public comment period and the discussion
during the public meeting held on July 2, 1990 indicate that the
residents and the Township support the remedy proposed by EPA,
Alternative 2, Connection to an Existing Water Supply. The
community expressed its opposition to the possible selection of
Alternative 4, Continued (in-home) Ground Water Treatment.
Individual concerns regarding the interim action are addressed in
the Responsiveness Summary, which is attached as Appendix I.
IX. THE SELECTED REMEDY
The remedial action alternatives included in the final analysis
were No Further Action, Connection to an Existing Water Supply,
Development of a New Water Supply, and Continued Treatment of
Ground Water.
The selected remedial alternative for the Interim Action is
Alternative 2, Connection to Existing Water Supply. The selected
remedial alternative meets the goal of the interim action by
eliminating actual or potential human exposure to contaminated
ground water through ingestion or household uses.
The selected remedy will include the following activities:
1. Development and design of a water main extension and
distribution system to connect to an existing water supply
for the purpose of providing a permanent alternate water
supply to homes affected and potentially affected by the
contamination from the Higgins Farm site. The water main
extension may include a booster pumping station, storage
tank, and the expansion of the interconnection between the
Franklin Township Water Department (FTWD) and the water
supplier selected during the design of the interim action,
if necessary.
2. Construction of the water main extension and distribution
system.
-------
Table 7
Estimated Cost To Connect South Brunswick Township Water System
Item
Capital Cost
Annual O & M
Force Main
5620,000
House Services and Meters
68,000
Booster Pump Station/Storage
60,000
$ 11.700*
Electrical Service
13.000
500'
Water Service Connection Fee*
9,800
Water Use Charges*
16.000
In-House Carbon Svstem Removal
9.000
Residential Well Sampling
2.200
Well Sample Analysis
36.000
Total
818,000
28,200
Bid Contingency (15%)
122.700
Scope Contingency (10%)
81,800
Subtotal
1,021500
Permitting & Legal (5%)
51.100
Engineering Design (10%)
102300
Service During Construction (8%)
81.800
Total Capital Cost
$1,257,700
Cost Summary
Item
Cost (Rounded to the Nearest SLOOO)
Total Capital Cost
Sl.258,000
Present Worth of O&M for 30 Years at
10% Discount Rate
266,000
In-House Carbon System Maintenance (2
years only)
192,000
Total Capital & O&M
$1,716,000
EPA is estimating these fees, but is not responsible for their funding.
NJR56/018R56.51
-------
Table 8
Key Cost Assumptions
Item
Force Main
Water Storage
Water Use Charges
Water Services
Water Service
Connection Fee
POE GAC Unit
Replacement
Initial Well
Sampling
POE GAC O&M
Sampling
Criteria/Origin
9,500 feet of ductile
iron pipe, 8" diameter,
required by FTWD
15,000 gallons (one-
day average
consumption by 30
houses) required by
NJDEP NJAC 7:10-
11.8
500 gallons per day
per house, average day
use based on current
approximate use in
FTWD service area
150 feet of 1' PVC
pipe per residence
Franklin Township
15-year life assumed,
30 units
30 home wells
sampled for priority
pollutants
30 home wells
sampled 5 times
annually for VOCs, 1
time annually for
priority pollutants
Unit
Cost/Assumptions
S65.26/foot assuming
20% rock excavation,
from E-Town and
FTWD recent
experience
S2/gallon, estimate
based on vendor
experience with small
system storage
S2.80/1.000 gallons,
current FTWD water
rate - 90% of these
fees (S13,800/Vear) are
assumed to offset
O&M costs
Sl5/foot installed
(includes cost of
meter (S150) and tap
(S941))
S327.7 I/residence
S2,000/unit
Sl.200/analysis
Average of S450/
analysis*
Relevant
Alternatives
2,3
2,3
.2,3
2,3
2,3
4
1, 2, 3, 4
4
USEPA 1/30/90 memo from M. Pane to C. Sidamon-Eristoff, S. Luftig, requesting cost ceiling
increase
NJR56/017R56.51
-------
18
3. Continued operation and maintenance, until the permanent
alternate water supply is developed, of carbon adsorption
units installed at homes affected or potentially affected by
contamination from the Higgins Farm site.
4. Installation, operation, and maintenance, until the water
main extension is installed and operating, of carbon
adsorption units at homes potentially affected by
contamination from the Higgins Farm site that are not
currently equipped with carbon adsorption units.
5. Chemical sampling of homes potentially affected by
contamination from the Higgins Farm site, and installation,
operation, and maintenance of carbon adsorption units at
homes which become affected by the contamination from the
Higgins Farm site.
6. Disconnecting homes hooked into the water main extension
from their private water wells and removing the carbon
adsorption units after the permanent alternate water supply
is installed.
The estimated costs for the selected remedial alternative are
indicated in Table 7 with cost assumptions identified in Table 8.
X. STATUTORY DETERMINATIONS
A. Protection of Human Health and the Environment
The selected interim remedy is protective of human health. The
interim remedy, extension of the municipal water supply system
with monitoring and maintenance of carbon adsorption units until
the water line is functional, will eliminate the potential
exposure of residents through ingestion and household of to
contaminated ground water. The use of carbon adsorption units in
the short-term are a proven method of reducing the concentrations
of volatile organic compounds to acceptable levels.
B. Attainment of ARARs
Given the limited scope of this interim action, the selected
interim remedy will attain applicable or relevant and appropriate
requirements by preventing the future ingestion or household use
of ground water containing contaminants in excess of drinking
water standards.
The selected interim remedy will not effectively restore the
ground water to its beneficial uses. The restoration of ground
water will be addressed in one or more future operable units for
the Site, at the conclusion of the RI/FS.
-------
19
C. Cost Effectiveness
The selected interim remedy, Alternative 2, is the most cost-
effective when compared to the other alternatives. While
Alternative 1, No Action, is the least expensive remedy, it is
not protective of human health and the environment. Alternative
4, which is the next least expensive, does not provide reliable
long-term protection of human health and the environment.
Although Alternatives 2 and 3 are similar in cost, Alternative 3
is not as reliable or protective of human health and the
environment. Therefore, Alternative 2 is the most cost effective
remedy that will provide reliable protection of human health and
the environment.
D. Utilization of Permanent Solutions Employing
Alternatives Technologies to the Maximum Extent
Practicable
The selected interim action does not represent a permanent
solution with respect to the remediation of soils or ground
water. However, this interim action does represent a permanent
solution for human exposure to contaminated ground water.
Since a permanent source of clean drinking water to residents
affected or potentially affected by the Site will be installed,
the selected interim action does utilize permanent solutions to
the maximum extent practicable, given the limited scope of this
action. Selection of permanent solutions and alternative
treatment technologies to the maximum extent practicable will be
addressed further in the final remedy for the Site.
E. Preference for Treatment as a Principle Element
Since this action constitutes a measure to eliminate and prevent
exposure to contaminated ground water, and does not constitute
the final remedy for the Site, the statutory preference for
treatment as a principle element will be addressed in the
selection of the final remedy for the Site.
XI. Explanation of Significant Changes
The Proposed Plan for the interim action for the Higgins Farm
site was released for public comment on June 28, 1990. The
Proposed Plan identified Alternative 2, Connection to Existing
Water Supply, as the preferred alternative. EPA reviewed all
written and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that no
significant changes to the remedy, as it was originally
identified in the Proposed Plan, were necessary.
-------
INTRODUCTION
In June 1990, EPA completed a Focused Feasibility Study (FFS) and Proposed Plan
for providing an alternate source of drinking water to residents affected by ground
water contamination originating at the Higgins Farm Site. The alternatives discussed
were:
Alternative l--No Further Action
Alternative 2--Connection of Residences to an Existing Water Supply
Alternative 3-Development of a New Community Well
Alternative 4--Continued In-Home Treatment of Ground Water
The preferred alternative proposed by EPA is Alternative 2. Under this alternative,
a water main would be extended from an existing system, such as the South
Brunswick Water and Sewer System, and connected to the affected residents.
Franklin Township Water Department would assume responsibility for maintaining
the water main extension.
This document summarizes EPA's responses to comments received on the FFS and
Proposed Plan. The comments addressed are those made during the public meeting
held in Franklin Township on July 2, 1990 and those received during the public
comment period of June 28 to July 30, 1990 (Reference A). Five comment letters
were received during the public comment period. One commenter, from the law
firm representing FMC Corporation, opposed Alternative 2 in favor of Alternative 4
(Reference B). The remaining four letters were all in support of Alternative 2
(References C, D, E, and F). No comments were received in support of Alternative
1 or 3.
Comments are grouped by topic and referenced by letter to the source documents
identified above and listed at the end of this summary. The source documents are
pan of the administrative record file and are available for review by the public at
the following locations:
Mary Jacobs Memorial Library
64 Washington Street
Rocky Hill, NJ 08835
(609) 924-7073
Franklin Public Library
485 DeMott Lane
Somerset, NJ 08873
(201) 873-8700
NJR55/033R55.51
-------
USEPA, Region II
Superfund File Room
26 Federal Plaza - 29th Floor
New York, NY 10278
Monday through Friday: 9:00 am to 4:30 pm
1. STATUS OF RI/FS AND ITS RELATIONSHIP TO THE FFS
Comment:
EPA Response:
Comment:
EPA Response:
Have the limits of the ground water plume been defined?
not, when will they be defined? (A, p. 20)
If
A remedial investigation and feasibility study (RI/FS) of the
entire site is ongoing. One aspect of the RI/FS is the
delineation of ground water contamination. The RI/FS is
currently expected to be completed in the fall of 1991.
Because there is little information on ground water flow rate
and direction, EPA should await the outcome of the RI/FS
before considering implementation of Alternative 2. The new
water line would not be constructed until the RI/FS is
completed. The information obtained in the RI/FS may suggest
that Alternative 2 is not justified. (B, p. 5)
While it is true that there is little information on the site
hydrogeology, there is significant information from sampling the
site and residential wells. These data show that contaminants
associated with the site appear in 10 residential wells. In six of
these cases, the levels of contamination are above the remedial
criteria. In five cases, there are repeated occurrences of
contamination of the same magnitude in different sampling
events suggesting the plume has not moved significantly away
from these residences in the past five years. Because of the
fractured bedrock geology in the area, there is potential for
contaminants to spread to many additional homes. Therefore, it
would not be prudent to wait until the RI/FS is complete. The
information available now is sufficient to justify Alternative 2.
2. CURRENT OPERATION OF THE CARBON UNITS
Comment:
EPA Response:
NJR55/033R55.51
Are the carbon units being used to treat the water or detect
contamination? (A, pp. 36-38)
Primarily, the granular activated carbon (GAG) units are being
used for treatment of the contaminated ground *water. GAG
adsorbs contaminants from the water as it passes through the
-------
Comment:
EPA Response:
unit. The unit effluents are being sampled once every 1 to 3
months to check whether the carbon's adsorptive capacity has
been exceeded. Sampling results are sent directly to the
homeowner and are available in the administrative record file.
What wells are contaminated? Have there been any additional
wells showing contamination since sampling began? (A, pp. 38-
39)
The wells which show contamination above the remedial criteria
are well R-7 on the Higgins property, wells R-l, R-3, R-5, and
R-6 on properties adjoining the Higgins property, and well R-
12. (See Figure 1-10 of the FFS for the locations of these
wells.) Based on the results of the April 1990 sampling, no new
wells have been added to this list.
3. PROTECTION OF PUBLIC HEALTH
Comment:
EPA Response:
Comment:
EPA Response:
Information provided in the FFS is adequate to show that GAC
units are and will be protective of public health. (B, pp. 2-4 and
6)
There are contaminants which may not be absorbed by the GAC
units. In addition, the fact that the GAC system requires
constant monitoring and maintenance creates a less protective
scenario than provision of an alternate water supply.
EPA's preference for Alternative 2 over Alternative 4 appears to
be based upon its belief that while both would be consistent
with any future action taken at the site, Alternative 4 reduces
but does not eliminate the risk of potential exposure to
contaminated ground water. However, the potential for contact
with contaminated water exists as much with the public water
supplies as with the residential wells. The fact the law requires
water suppliers to achieve MCLs does not mean that it will
happen. The potential for contact still exists. (B, p. 3)
The residential GAC units are being sampled once every one to
three months depending on the location of each residence
relative to the site. The units are currently being monitored for
only volatile organic compounds. In the evaluation of
Alternative 4, the current program was assumed to continue
with a full priority pollutant scan being performed once per
year. More comprehensive and frequent testing is required by
public suppliers of potable water.
NJR55/033R55.51
-------
Comment:
EPA Response:
More comprehensive and more frequent monitoring of the
residential units could be performed, but not without significant
cost increases as discussed under Topic 4. Also, the more
frequent the monitoring, the more intrusive the program
becomes on the lives of the residents who must make
arrangements to allow access to their treatment units for every
sampling event.
In regard to the public water supply, there is theoretically a
potential for contamination entering the system between
sampling events. However, public water supplies often supply
water to its system from multiple sources. In the case of South
Brunswick, water provided from its own wells (which do not
draw water from beneath the site) are supplemented by water
from the Elizabethtown Water Company. Therefore, a
contaminant accidentally entering the system from one of these
sources would be diluted and result in a smaller exposure to a
resident than would be likely from a resident's well drawing
water from an aquifer directly underlying the site.
Finally, it is important to note that GAC units can desorb
contaminants if the contaminant concentrations in the ground
water decrease. Therefore, the mere existence and monitoring
of the units does not ensure there will be no potential for
exposure over the long term.
EPA proposes to rely on GAC units to protect the health of the
residents during the design and construction of the new water
line under Alternative 2, but is unwilling to rely on them while
completing the RI/FS to determine whether Alternative 2 is
necessary. (B, p. 6)
As discussed under Topic 1, sufficient information is currently
available to justify selection of Alternative 2. Any data obtained
through completion of the RI/FS would not yield the basis for a
different decision. Therefore, it is prudent to select Alternative
2 as the best overall solution now.
During the period of design and construction of the water line,
the GAC units will continue to be used because they are the
second best approach to providing uncontaminated water to the
residents. However, as discussed above, there are reliability
problems with using such units which make them an
unacceptable long-term solution.
NJR55/033R55.51
-------
4. COSTS AND COST-EFFECTIVENESS
Comment:
EPA Response:
Comment:
EPA Response:
Comment:
EPA Response:
What would be the costs to homeowners if Alternative 2 were
selected?
The homeowners would bear the cost of the water service
connection fee. A recent quote from the Township was $327.71
per residence. The homeowners would also be responsible for
payment of their water bills the amount of which will depend on
water usage. The current Township rate is $2.80 per 1000
gallons.
EPA's total projected costs under Alternative 4, which are almost
exclusively O&M costs, result from EPA's assumption that the
GAC units must be used for 30 years. This assumption is not
valid and can only be explained by EPA's having prejudged the
outcome of the RI/FS or EPA's willingness to artificially inflate
the costs of Alternative 4. (B, p. 7)
The 30-year period was used because the standard approach for
present worth cost analyses is to compare alternatives over a
time period equivalent to the useful life of the longest-lived
alternative. In this case, the longest-lived alternative is
Alternative 2 in which the water line can be expected to last for
about 30 years. Therefore, 30 years is used for comparison
purposes. In addition, it can be anticipated that ultimate
restoration of the ground water (that will be addressed as part
of the final remedy of the site) could require as long as 30
years.
EPA has failed to provide a meaningful and accurate comparison
between Alternatives 2 and 4 and has failed to meet its statutory
mandate to select a remedial action which is cost effective (See
U.S.C. §9621) Clearly, the costs of Alternative 4 are not
proportional to the effectiveness achieved (See Preamble to the
NCP, 55 FR 8724-5 and 40 CFR § 300.430 (f) (1) ii (D) and
(E)).
The cited NCP section regarding the selection of the final
remedy requires that the remedy's costs be proportional to its
overall effectiveness. It also defines overall effectiveness as
including long-term effectiveness and permanence and goes on to
say that special emphasis should be afforded to alternatives that
meet this criterion. Clearly, Alternative 2 is the most permanent
of the remedies considered and is the most effective in that it
removes the threat of exposure to 'site contaminants. In
NJR55/033R55.51
-------
Comment:
EPA Response:
addition, the costs of Alternative 2 are not excessive when
compared to Alternative 4 (as defined in 55 FR 8714-5) for the
additional effectiveness provided. Therefore, the cost-
effectiveness of Alternative 2 is well within the bounds defined
by the NCP and Alternative 2 can legally be selected as the
remedy.
EPA is proposing Alternative 2 as an interim remedy with a
present worth total cost, which is over $700,000 greater than
that of Alternative 4. This alone should be basis enough to
reject Alternative 2 in favor of Alternative 4. (B, p. 6)
The term "interim remedy" in the context of the Superfund
program means that the remedy is not the final remedy for a
particular site. In this case, the water line represents an interim
remedy for ground water as it does not address restoration of
the ground water to its beneficial uses. "Interim remedy" does
not necessarily mean that the remedy must be temporary or
lowest in cost. In fact, under the NCP, EPA is obligated to
evaluate other factors, including effectiveness and protection of
human health. Alternative 2 is more effective and provides the
greatest degree of protection of human health.
Also, it is important to note that there is an error in the costs
listed in Proposed Plan for Alternatives 2 and 3. The costs
provided in the FFS are correct. Thus, the bottom line
difference between Alternatives 2 and 4 is less than $500,000.
Comment:
EPA Response:
Even if the capital costs of Alternative 2 and 4 could be
considered close, EPA has failed to focus upon the fact that the
total 30-year costs of Alternative 4 will be exceeded by the
capital cost component above under Alternative 2 in just two
years. On the other hand, none of the projected capital cost of
Alternative 4 will be incurred for 15 years. (B, p. 6)
As discussed in the preceding response, costs and when those
costs would be incurred are not the only factors of concern. In
particular, the protection of public health differs significantly
under Alternatives 2 and 4. Somewhat closer agreement in the
level of protection of the alternatives could be achieved by
increasing the scope and frequency of sampling under Alternative
4 to include, say, volatile organics scans for each residence once
per month. This sampling frequency could then* be argued to
provide protection equivalent to that-afforded residents on a
NJR55/033R55.51
-------
Comment:
EPA Response:
Comment:
EPA Response:
public supply, such as South Brunswick, yet the 30-year
projected costs for Alternative 4 would rise to over $1.8 million
(see
Table 1).
This cost is higher than that for Alternative 2 and the GAC units
would still be unreliable for certain contaminants as discussed in
Topic 3.
The capital cost of Alternative 2 appears understated by
$151,000, which according to Table 4-4 of the FFS, is the
capital cost of the existing GAC unit that EPA proposed to scrap
upon connecting residences to a public water supply. (B, p. 7)
The costs are not understated. Of the $151,000, $38,200 plus
contingencies and markups is common to both alternatives for
sampling and analysis of the residential wells. The remaining
capital cost for Alternative 4 is only $60,000 plus contingencies
and markups. This amount is the present worth of the cost to
be paid after 15 years to replace the units per the
manufacturer's guidelines. Alternative 2 does not include this
cost because the GAC units are new and will not need to be
replaced during the two-year design and construction period.
The costs of monitoring the GAC units under Alternative 2
appear to be understated by $37,400. (Compare two years of
O&M costs in FFS Table 4-2 ($192,000) with two years' O&M
costs in FFS Table 4-2 ($229,400)0 (B, p. 7)
The costs are not understated. The present worth of two years
of operation and maintenance (O&M) of the GAC units is
calculated by taking the estimated cost for one year without the
community education program (which was specific to Alternative
4) or $110,700, and multiplying by the present worth factor for
two years at a 10% discount rate, or 1.7355, for a cost of about
$192,000.
5. SUPPORT OF THE ADMINISTRATIVE RECORD
Comment:
The administrative record shows that the GAC units have
decreased contaminant concentrations to acceptable levels.
NJR55/033R55.51
-------
EPA Response:
Comment:
EPA Response:
Therefore, there is no reason to believe that a significant
potential for exposure to ground water contamination exists and
no demonstrated need to abandon use of the GAG units. (B, p.
4)
While it is true that the historical data show the units have
worked, it is important to recognize that the data include no
results for semi-volatiles or heavy metals since August 1986.
Yet, these contaminants are the ones most likely to pass through
the units and cause exposure. EPA is currently developing a
modified sampling protocol which will address this problem.
However, in the meantime, the only conclusion that can be
reached is that the units have worked for those compounds for
which samples have been analyzed.
EPA's basis for concluding that the potential for exposure exists
is based on two factors. First, it is based on the knowledge of
the limits of the reliability of the GAG technology, particularly
the inappropriateness of GAG for removal of vinyl chloride and
selenium and its potential to desorb contaminants (see Topic 3).
Second, it is based on the close proximity of the source of
ground water contamination to the residents.
NJDEP adopted a conservative approach in providing GAG units
for 30 homes when only 5 of the 30 have shown any sign of
contamination. It is inconceivable that EPA would at this time,
propose to spend approximately $2,000,000 to serve only 5
homes when the GAG units have been shown to be effective.
The administrative record provides no support for the 5 homes,
much less the 25 additional homes included under Alternative 2.
(B, p.4)
The NJDEP well impact area was established in November 1986
as the area in which ground water was believed to be
potentially impacted by the site. The limits drawn have been
justified by the sampling data collected since 1986. Five wells
on or adjacent to Higgins Farm (R-l, R-3, R-5, R-6, and R-7)
were found to be contaminated above the remedial criteria. A
sixth well, R-12, the furthest west of the 30, was also found to
be contaminated above the remedial criteria. Providing a water
main extension to these 6 homes instead of continuing the use
of GAG is an appropriate long-term remedy as discussed in Topic
3. Furthermore, EPA believes that residences within the well
impact area are at risk because they may be in the path of
ground water migration, and as stated previously, there are
contaminants which may not be absorbed by the GAG units.
NJR55/033R55.51
-------
6. IMPLEMENTATION PROCESS FOR ALTERNATIVE 2
Comment:
EPA Response:
Comment:
EPA Response:
Comment:
EPA Response:
When would the 6-24 month implementation period begin?
What roles will the State and PRPs play? (A, pp. 21-23, 31-32)
The 6-24 month period would begin once EPA has issued its
Record of Decision (ROD). The PRPs were given the
opportunity to comment on the FFS and Proposed Plan during
the public comment period. They will not be further directly
involved once the ROD is issued. The State also is requested to
concur with the proposed remedy.
Why will implementation take 6-24 months? (A, pp. 33-35)
While construction of the water line may only take a few
months, the additional time is required to reach agreement with
Franklin Township and the selected water purveyor, prepare the
detailed design, procure a construction contractor, and make the
necessary access arrangements.
Who would be responsible for sealing and abandoning the wells?
Who would be responsible for connecting homes to the new
water line? (A, p. 36)
For each home, EPA will connect the home to the new water
line and attempt to seal the wells. Wells will not be grouted or
removed from the ground.
7. HOMES INCLUDED IN ALTERNATIVE 2
Comment:
EPA Response:
Comment:
Which homes would be connected to the new water line? (A,
pp. 23-25 and 36)
The approximately 30 homes which currently have carbon
treatment units would be connected. Prior to design of the
water line, sampling of wells for up to 30 additional homes in
the area may be performed. Any of these homes with
contaminants in excess of the remedial criteria would also be
connected to the water line.
Could the municipality allow others to be connected to the
water line? Could residents have the option of paying for
hookup if they are not among the group designated by EPA?
(A, pp. 27-28)
NJR55/033R55.51
10
-------
EPA Response:
Franklin Township would be responsible for determining who
else would be allowed to connect into the new water line. The
Township would also be responsible for determining who would
pay for such connections.
8. DESIGN OF ALTERNATIVE 2
Comment:
EPA Response:
Comment:
EPA Response:
Would there be enough water capacity available with the new
water line? (A, p. 28)
Based on a preliminary discussion with a South Brunswick
engineer, enough capacity would likely be available in the South
Brunswick system to supply the 30 homes.
Why is a pump station required? Where would the new pump
station be located? (A, p.33)
If the system selected for connection is South Brunswick, the
line pressure at the interconnection, which would be located at
the intersection of Routes 27 and 518, would be about 30 psi.
This pressure is not adequate to supply the 30 homes. Although
South Brunswick anticipates making some improvements to its
system in the future which may increase this pressure, the
existing hydraulic grade was assumed for the FFS. Therefore, a
pump station would be required in the vicinity of the
interconnection. The exact location would be determined
through discussions with Franklin Township.
NJR55/033R55.51
11
-------
SOURCES
A. Transcript from the Public Meeting Concerning the Focused Feasibility Study
and Proposed Plan for an Interim Ground Water Action at the Higgins Farm
Site. July 2, 1990.
B. Kenneth N. Klass of the law firm Blank, Rome, Comisky, and McCauley,
representing FMC Corporation. Letter to Ms. Joyce Harney, U.S. EPA Region
II. July 27, 1990.
C. Cherry Spague. Letter to Environmental Protection Agency. July 5, 1990.
D. Edward and Kathryn Flynn. Letter to Ms. Joyce Hamey, U.S. EPA. July 10,
1990.
E. John and June Lewis. Letter to Ms. Joyce Harney, U.S. EPA. July 15, 1990.
F. Edward and Judy Schnabel. Letter to Ms. Joyce Hamey, U.S. EPA. July 16,
1990.
NJR55/033R55.51 12
------- |