-------
-21-
£,.£! CONCENTRATIONS OF INDICATOR METALS
WITHIN THE TOP TWO FEET OF SOIL COMPARED
WITH BACKGROUND CONCENTRATIONS
Cadmium
Chromium
Lead
Nickel
Maximum Soil
Concentration
(mg/kg)
0.56
5.5
5.6
4.5
New Jersey
Background '^
(mg/kg)
1.0 - H.o
5.0 - 48
1.0 - 180
11.1 - 86.5
-------
-22-
the zero-two feet sample was equal to that detected in the
two-four feet sample. The dose was calculated using realistic
worst case assumptions discussed previously.
ALTERNATIVE EVALUATION PROCESS
The remedial alternatives for the Williams Property site were
developed and evaluated using the Comprehensive Environmental,
Response, Compensation, and Liability Act of 1980, as amended
by the Superfund Amendments and Reauthorization Act of 1986
(CERCLA), the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR §300.68, and the "Guidance on
Feasibility Studies Under CERCLA", as guidance. In addition,
EPA Interim Guidance on Selection of Remedy memorandums dated
December 24, 1986 and July 24, 1987 were considered.
The major objective of the FS is to evaluate remedial alternatives
using a cost-effective approach consistent with the goals and
objectives of CERCLA. According to Section 121 of CERCLA, the
recommended remedial alternative should protect human health
and the environment, should be cost-effective, and should
utilize permanent solutions and alternative treatment or
resource recovery technologies to the maximum extent practicable.
The proposed remedy must also attain legally applicable or
relevant and appropriate federal and state public health and
environmental standards, requirements, criteria, or limitations
(ARARs) that have been identified for the site.
A five step process was developed and used to meet the FS
objectives. The following is a summary of that process.
The first step is to evaluate human health and environmental
effects associated with releases and threatened releases of
hazardous substances from the site. Criteria to be considered
are grouped into three categories effectiveness, implementability
and cost. Both short term and long term aspects of these are
considered.
The next step is to develop a range of potential available
remedial technologies that could be used to remediate the site.
Remedial technologies in which treatment that permanently and
significantly reduces the toxicity, mobility or volume of the
hazardous substances as a principal element are to be preferred
over remedial technologies not involving such treatment. These
technologies are initially screened on a technical basis. Based
on the screening, a list of individual remedial technologies
appropriate to site conditions and consistent with the remedial
action objectives is developed.
The site-appropriate remedial technologies are then combined
into a number of preliminary remedial alternatives. The basis
for the various combinations are: the technical and logical
interrelationship between separate technologies, NCP Section
300.68(f) requirements regarding the general categories of
-------
Table 7 Dose fro* Ingest ion of Surface Soil using Realistic Worst Case Assumptions
Naxlaui Subchronic Dose(b) Chronic Oose(c)
concentration 5.0(a) 0.1 S.O(a) 0.1
Substance (ug/kg) (ug/kg/day) (ug/kg/day) (ug/kg/day) (ug/kg/day)
Bis(2-ethylhexyl)phthalate 15000 1.4SE*00 2.91E-02 2.S2E-02 5.05E-0*
Nethylene Chloride 20 I .WE -03 3.88E-05 3.36E-05 6.73E-07
a. Ingest ion rate, dose calculated for both 0.1 and 5.0 graas per day.
b. Subchronic Oose=(conc.(ug/kg)*ingestion rate(kg/day)*(Idays/7days)*(40Meeks/S2weeks)l/mg
c. Chronic Dose=[canc.(ug/kg)*ingestion rateo
CO
i
Table 8 Dose fro* Ingest ion of Surface Soil using More Probable Case Assumptions
Mean Subchronic Dose(b) Chronic Dose(c)
concentration S.O(a) 0.1 S.O(a) 0.1
Substance fug/kg) (ug/kg/day) (ug/kg/day) (ug/kg/day) (ug/kg/day)
gis(2-ethylhexyl)phthatate 9400 3.ME-01 6.08E-03 5.27E-OJ 1.0SE-M
Nethylene Chloride 13.2 4.27E-M 8.53E-06 7.40E-06 1.48E 07
•••••••••.•••••••••«•••••«•*••••••••••»••••»•••••••*•••*••••«••*•••••••••••••••••••»•••••••••••••
a. Ingest ion rate, dose calculated for both 0.1 and S.O graas per day.
b. Subchronic Dose=(conc.(ug/kg)*in9estion rate(kg/day)*(1days/7days)*(40ueeks/S2Neeks)|/17kg
c. Chronic Oose=Icooc.(og/kg)*ingestion rate(kg/day)*(1days/7days)*(40Mks/S2Mks)*(Syrs/70yrs)l/70kg
-------
-24-
alternatives which must be considered and CERCLA Section 121
provisions regarding the preference for remedial actions that
utilize permanent solutions and alternative treatment or resource
recovery technologies. EPA is in the process of revising the
NCP to reflect these new provisions added by. SARA. EPA's
"Interim Guidance on Superfund Selection of Remedy" memorandums,
issued December 24, 1986 and July 24, 1987 are intended to aid
the Agency in the selection of remedial actions pending the
revised NCP. EPA's interim guidance requires evaluation of
alternatives involving: 1) treatment options; 2) containment
of waste options with little or no treatment, but providing
protection of human health and the environment primarily by
preventing exposure or reducing the mobility of the waste;
and 3) the no-action alternative^ These three categories of
alternatives must be carried through the detailed evaluation
process, and should not be eliminated during previous screening
processes.
The fourth step in the process is to provide an initial screening
of these alternatives. The three broad criteria that should
be utilized in the screening are: the relative effectiveness,
implementability, and the cost of implementing the remedial
action. This general screening is intended primarily to
reduce the number of remedial alternatives which will subsequently
be evaluated in detail.
The final step is to conduct a detailed analysis of the
alternatives that remain after the initial screening. A
treatment, containment and no-action alternative should be
included in this analysis. For each alternative, the following
factors, as appropriate, are to be considered:
0 An evaluation in terms of engineering implementation,
reliability, and constructibility;
8 An assessment of the extent to which the alternative is
expected to effectively prevent, mitigate, or minimize
threats to, and provide adequate protection of human health
and the environment. This includes an evaluation of the
extent to which the alternative attains or exceeds ARARs
for the site. Where the analysis determines that federal
and state human health and environmental requirements are
not applicable or relevant and appropriate, the analysis, as
appropriate, evaluates the risks of the various exposure
levels projected or remaining after implementation of the
alternative under consideration;
0 An analysis of whether recycle/reuse, waste minimization,
waste biodegration, or destruction, or other advanced,
innovative, or alternative technologies is appropriate to
reliably minimize present or future threats to human health
and the environment;
-------
-25-
0 An analysis of any adverse environmental impacts and methods
for mitigating these impacts, and costs of mitigation;
0 A detailed cost estimation, including operation and
maintenance costs, and distribution of costs over time.
DEVELOPMENT OF ALTERNATIVES AND INITIAL SCREENING
The remedial investigation conducted at the Williams Property
site was used to develop remedial objectives dealing with
protection of both human health and the environment. The
results of the RI indicate that the ground water of the Holly
Beach Aquifer is contaminated.
The contaminant transport pathways impacting on human and
environmental receptors are the movement of ground water and
contaminants from the site, and associated direct contact and
ingestion of contaminated surface soils and groundwater.
Based on the above considerations the primary remedial response
objectives are:
0 Mitigation of migration of contaminated ground water in the
Holly Beach Aquifer.
0 Remediation of contaminated ground water in the Holly Beach
Aquifer.
0 Mitigation of leaching from contaminated site soils into the
ground water and prevention of direct contact.
Based on site information from the remedial investigation,
general response actions or classes of response actions have
been identified without identifying specific technologies. The
general response actions considered include the no-action
alternative as a base line against which other response actions
can be measured. Technologies in each general response action
were identified. Technologies considered for remediating ground
water contamination and soil contamination are presented in
Table 9 and Table 10, respectively. Technologies which address
other factors affecting remediation are presented in Table 11.
Technologies in each general response action were screened to
eliminate inapplicable and infeasible technologies based on
site-specific conditions. Technologies that were screened and
eliminated are presented in Table 12 along with the reason
for their elimination.
The remaining feasible technologies were assembled into
alternatives. Applicable or relevant and appropriate requirements
were considered in selecting and combining technologies into
alternatives to achieve specific cleanup goals.
-------
-26-
GROUND WATER REMEDIAL ALTERNATIVES
Seven ground water alternatives have been developed. Each one
of these ground water alternatives incorporate various types
of treatment systems which will permanently remove contaminants
from the ground water and, thereby, reduce their toxicity, mobility
and volume.
Alternative 1 - Extraction, Air Stripping, and Recharge
In this alternative, contaminated ground water is extracted,
treated at an on-site water treatment system and recharged to
the ground. The objective of this alternative is to reduce
the concentration of contaminants in the ground water to
levels where the potential risk to human health and the
environment are reduced to acceptable levels, and to hydraulically
control the migration of contaminants in the ground water.
Extraction wells with submersible pumps would be utilized in
this alternative to extract the contaminated ground water. The
design of the system would entail further hydrogeologic
investigation.
The contaminated ground water will be passed through a counter-
current air stripping column to enhance the exchange of organics
from the aqueous stream to an effluent air stream. Air stripping
will perform successfully, given the conditions at the Williams
Property site. Removal of volatile organic contaminants from
water at low influent concentrations is common practice. A
high degree of removal is anticipated for the volatile organic
contaminants. Semi-volatile organic contaminants would be only
marginally removed, while metals would be essentially untreated.
Due to the fact that the primary sections of an air stripping
operation contain no moving parts, the operation and maintenance
requirements are minimal and t:he reliability of the air stripping
equipment is good.
Operation of an air stripper should pose no threat to individuals
working on or near the treatment equipment. The issue of air
contaminant emissions must be addressed so that such discharges
can comply with air emission standards. While the organic
contaminants transferred to the vapor phase are not expected
in concentrations that would cause human health concern, the
need for emission control systems on the air stripping unit
would be further considered during design.
Recharge of the treated ground water offers several benefits:
1) reduction of the duration of treatment, 2) minimal effects
from drawdown during ground water recovery, and 3} creation of
a ground water boundary to detour inflow from outside the target
-------
-27-
TABLE 9 TECHNOLOGIES CONSIDERED
FOR REMEDIATING GROUNDHATER CONTAMINATION
1. Groundwater Containment
a. Sheet Piling*
b. Grout Curtain*
c. Slurry Wall*
d. Hydraulic Barrier
e. Surface Capping*
2. Groundwater Treatment
a. Air Stripping
b. Activated Carbon Adsorption
c. Resin Adsorption*
d. Biological Treatment*
e. Precipitation/Flocculation/Sedimentation
f. Ozonation*
g. Wet Air Oxidation*
h. Steam Stripping*
i. Ion Exchange
j. Reverse Osmosis*
3. Groundwater Recovery and Disposal
a. Pumping
b. Publicly Owned Treatment Works*
c. Surface Water Discharge*
d. Groundwater Recharge
e. Discharge to Ocean*
* Technology eliminated in screening.
-------
-28-
TABLE 10 . TECHNOLOGIES CONSIDERED FOR
REMEDIATING SOIL CONTAMINATION
1. Soil Treatment
a. On-Site Incineration
b. Off-Site Incineration
c. • On-Site Soil Vacuuming
d. On-Site Extraction/Flushing*
2. Soil Disposal
a. Off-Site Disposal
b. On-Site Disposal
TABLE 11 TECHNOLOGIES THAT ADDRESS OTHER
FACTORS AFFECTING REMEDIATION
1. No Action
2. Institutional Controls
-------
TABLE 12 SCREENING OF ALTERNATIVE TECHNOLOGIES
Possible Technology
Retained (H)
or Eliminated (E)
Reason for El Initiation
Technologies Considered for
Remediating Croundwater Contamination
1. Groundwater Containment/Extraction
a. Grout Curtain
b. Sheet Pilings
c. Slurry Walls
d. Hydraulic Barrier
e. Surface Capping
E
E
R
E
The use of grout curtains uas considered as a Method for containing '
grounduater. However, slurry walls provide the same level of effectiveness
for about one third the cost.
This alternative was el initiated for the same reason as the grout curtain.
Although a cheaper containment alternative tnan grout curtains or sheet
pilings, the depth to the confining layer Makes this technology Impractical.
The majority of the waste contaminated soils have been excavated, surface
capping Is more applicable to landfills.
2. Groundwater Recovery and Disposal
a. City Publicly Owned Treatment Works
b. Surface Water Discharge
Aquifer water supply Is needed as a drinking water source. Publicly owned
treatment does not exist.
The surface waters nearest the site — smali water filled gravel pits are
Inappropriate. Surface streams are not located near the site — loss of
fresh water.
i
ro
UJ
c. Groundwater Recharge
-------
TAHLE 12 (Continued) SCREENING OF ALTERNATIVE TECIIMOljOUIES
Possible Technology
Retained (R)
or Eliminated (E)
Reason for Elimination
d. Discharge to Ocean
e. Groundwater Pumping
3. Groundwater Treatment
a. Air Stripping
b. Activated Carbon Adsorption
c. Resin Adsorption
d. Steam Stripping
e. Biological Treatment
f. Wet Air Oxidation
g. Ozonation
h. Chemical Precipitation am) Sol
Separation
I. Ion Exchange
J. Reverse Osmosis
ids
E
H
R
R
E
E
E
E
R
E
Loss or fresh uater, too great a distance to ocean
Activated carbon can produce similar effic.oncles at lower cost.
Energy Intensive and, therefore, costly. Air stripping Is equally effective
and less costly.
Not effective at low concentrations. Standard biological reactors are not
designed for influents below 50-70 mg/1. Many chlorinated compounds are
non-biodegradable or refactory.
Not effective at low concentrations; energy Intensive.
Requires that ozone be produced on-site. Because production of ozone Is
expensive, ozonation was eliminated.
Difficult to Implement and operate. A combination of carbon adsorption and
metal precipitation Is equally feasible wiln lower costs.
CO
o
i
-------
TAIILE 12 (Continued) SCIIKENING OF ALTERNATIVE TECHNOLOGIES
Possible Technology
Retained (R)
or Eliminated (E)
Hcason Tor Elimination
Technologies Considered for
Remediating the Soil
•1. Off-Site Disposal
2. On-Site Disposal
3. Oil-Site Incineration
4. Off-Site Incineration
5. Or,-Site Stabilization/Solidification
6. Soil Flush ing/Ex tract ion
7. In-Situ Thermal Destruction
8. Soil Vacuuming
Access Restrictions
I. Signs
2. Fencing
3. Security Guards
R
R
R
R
E
E
R
R
R
R
E
Soil already passes the Toxlclty Characteristic Leaching Procedure (TCLP)
Decontamination of the soils Is not feasible due to large degree of
variation of the contaminants and their distribution.
Site conditions does not warrant this level of security.
-------
-32-
zone. Recharge of the treated water also preserves freshwater
in an area subject to saltwater intrusion. Recharge will raise
the level of ground water in the localized area around the recharge
wells. This should not have an adverse impact on surface
drainage characteristics or vegetation. Recharge wells will be
carefully located to ensure that building foundations, roadways,
or other facilities are not impacted. Public health and
environmental impacts of volatile organics will be minimized
by air stripping. However, impacts associated with the
semi-volatile organics in the ground water will remain. In
addition, metals detected in the ground water would not be
removed. The pumping and piping equipment associated with
the recharge system is conventional, relatively inexpensive,
and will require minimum maintenance.
Alternative 2 - Extraction, Carbon Adsorption, and Recharge
This alternative will have a similar extraction and recharge
system as Alternative 1. However, contaminated ground water
will be passed through a bed of granular activated carbon that
will adsorb the organic constituents from the aqueous phase.
Carbon adsorption has been shown to be effective in removing
both volatile and many non-volatile organic compounds to low
levels. In addition, certain inorganics have been shown to
have moderate to high sorption potential.
A significant amount of operating experience has been gained
and carbon can be considered a proven and reliable treatment
for ground water contamination. A monitoring program for the
carbon system effluent must be implemented in order to change
the granular carbon at the optimum time and to ensure that
breakthrough has not occurred.
Operation of a granular activated carbon system poses no threat
to individuals working on or near the treatment equipment.
However, the treatment process does generate a hazardous residue
— the spent carbon that must be disposed of in accordance
with the appropriate institutional requirements or regenerated.
In addition, carbon adsorption is not expected to remove all
of the metals detected in the ground water.
Alternative 3 - Extraction, Air Stripping, Carbon Adsorption,
and Recharge
This treatment alternative would combine the technologies of
air stripping and carbon adsorption, as discussed previously.
Air stipping can achieve a high degree of removal of volatile
organics, but the technology is not as effective for non-volatiles.
Carbon adsorption has been shown to be effective in treating
many non-volatile organics and some metals. Therefore, this
combination of technologies provides more effective treatment
than either technology alone.
-------
-33-
Alternative 4 - Extraction/ Air Stripping, Carbon Adsorption,
Precipitation/ Flocculation, Sedimentation,and Recharqe
In additiM£rto the technologies mentioned in Alternative 3, a
precipitation, flocculation, and sedimentation process would be
included.
Under this alternative, extracted ground water containing
soluble metals would be precipitated by chemical precipitation/ '
flocculated, and then removed by sedimentation. The processes
have been widely used, the equipment is relatively simple, the
process can be applied to very large volumes of wastewater, and
the energy consumption is low. However, because of the
potentially changing concentration of metals in extracted
ground water, required dosages of precipitants and coagulants
may continuously change. In addition, large quantities of
metal precipitate sludges would be generated.
Alternative 5 - Extraction, Air Stripping, Precipitation,
Flocculation, Sedimentation, and Recharge
In addition to the technologies mentioned in Alternative 1, a
precipitation, flocculation, and sedimentation process would be
included as discussed under Alternative 4.
Alternative 6 - Extraction, Carbon Adsorption/. Precipitation,
Flocculation, Sedimentation, and Recharge
A precipitation, flocculation, and sedimentation process as
discussed under Alternative 4, would be added to the treatment
process described in Alternative 2.
Alternative 7 - Extraction, Air Stripping, Carbon Adsorption,
Ion Exchange, and Recharge
Under this alternative, extracted ground water would be passed
through ion exchange resins to remove soluble metallic elements
in addition to treatment for 'organics by air stripping and
carbon adsorption. Ion exchange is considered applicable for
removal of soluble metals, either cationic or anionic, and is
routinely used in the electroplating industry to remove impurities
from rinse waters. Suspended matter must be low so as not to
foul the resins. In addition, some organics, especially
aromatics, can be irreversibly adsorbed by the resin, resulting
in decreased capacity.
Due to the need to regenerate the resin frequently, operation
and maintenance costs are high compared to other treatment
processes. In addition, the spent regenerant has the potential
for containing high concentrations of contaminants. There is
some risk of exposure to workers and the public from the highly
acidic or caustic solutions used as resin regenerates.
-------
-34-
SOIL REMEDIAL ALTERNATIVES
Each of th« soil remediation alternatives assumes treatment of
a maximum area of 125 feet by 175 feet by 5 feet (approximately
4,000 cubic- yards). The area encompasses all borings having any
positive HNU reading during the remedial investigation. A
sensitivity analysis was conducted for the excavation alternatives
to evaluate the effect of variation of the volume of soil
excavated, and are identified as Case I and Case II, respectively,
in the FS. Case II involved a reduced area of 75 feet by 25 feet
by 10 feet (approximately 700 cubic yards), and was based on
boring locations with HNU headspace readings of 15 ppm or
greater. This occurred, only at Borings B-10 and B-ll at
depths of zero to eight feet in B-ll and zero to four feet at
B-10.
The high HNU readings in Boring B-ll correlate well with the
chemical analysis of soils from B-ll. These chemical analyses
indicate that the highest concentrations of organic compounds
occurred at location B-ll* The Case II volume of 700 cubic
yards is estimated to represent the quantity of soil with the
highest organic contaminant concentrations. The excavation
and removal of the Case II volume is currently estimated to
be that which is required to achieve a target level of one
part per million of total volatile organic compounds in
remaining soils. This cleanup objective has been developed
by NJDEP and used in the ECRA program. It reflects the
relative persistence and mobilities of organic compounds.
The following six alternatives have been developed.
Alternative 1 - Excavation of Soil, Disposal in Off-Site Permitted
Hazardous Waste Landfill, Surface Grading, and Revegetation
This alternative includes site excavation, off-site hauling,
off-site disposal, and site restoration. Specifically, this
alternative removes contaminated soils to an approved hazardous
waste facility and, therefore', is highly effective in meeting
cleanup goals at the site. The remediation is permanent for
the existing site; the reliability is rated high, as off-site
disposal is a proven technology. Since this alternative does
not involve installation of sophisticated and complex treatment
systems on-site, it is considered relatively easy to implement.
Off-site disposal of contaminants eliminates the potential
for exposure and contaminant migration at the existing site.
Transportation of the hazardous materials will result in a
small risk to public health and the environment along the
transportation route. Exposures to subsurface soils during
excavation may result in short-term exposure to contaminated
dusts or gases on-site. Excavation will be backfilled with
clean native soils. The final surface of backfill will be
graded to converge with local topography, and revegetated.
-------
-35-
Alternative 2 - Excavation of Soil, On-Site Disposal in Constructed
Landfill/ Surface Grading/ and Revegetation
-^
This alternative is similar to Alternative 1. However, contaminated
soils will^be excavated and disposed of in an on-site constructed
landfill. This will eliminate the risk to human health and
the environment along an off-site transportation route.
Although this alternative reduces the mobility of contaminants,
it does not reduce the toxicity and, therefore, potentially
impacts its long term effectiveness.
Alternative 3 - Installation of Vacuum Extraction Well and Soil
Vacuuming System''"
In this alternative, volatile organic compounds (VOC) are
extracted from the contaminated soils above an aquifer by
inducing a flow of air through the soil; the volatile contaminants
are expected to migrate from the soil into a piping system
under vacuum. A vacuum would be applied to the soil through
extraction wells constructed with perforations above the water
table. A conventional industrial blower will provide the vacuum.
Although this volatilization technique is considered to be a
relatively new process for treating VOC-contaminated soil, it
is similar in principle to some well established technologies,
such as air stripping and landfill gas extraction.
Soil vacuuming works well when there is a substantial cover of
contaminated unsaturated soil above the water table and when
the contaminated soil is porous enough to permit a significant
flow of air through the zone of contamination under a modest
applied vacuum.
Due to the simplicity of the system, the operation and maintenance
requirements are minimal and the reliability of the system is
good.
i
Operation of the vacuuming system poses no threat to individuals
working on or near the treatment equipment. However, the vented
off-gas may pose environmental and public health concerns. The
extracted VOCs will be vented directly to the atmosphere,
although a collection system (e.g., vapor phase carbon) could
be provided if necessary.
Vacuuming will minimize the VOCs in the soil, but will not
address the environmental and public health concerns of non-
volatile organics. Similiarly, metals would not be affected.
Alternative 4 - Excavation of Soils, Off-Site Incineration,
Surface Grading, and Revegetation
This alternative includes site excavation, off-site hauling,
off-site incineration, and site restoration. Specifically,
-------
-36-
this alternative removes contaminated soils to an approved
hazardous «aste treatment facility and, therefore, is highly
effective**!* meeting cleanup goals at the site. This
alternating" provides a permanent treatment technology to
reduce the toxicity and mobility of the principle threat at
the site. Transportation of the hazardous materials will
result in a small risk to public health and the environment
along the transportation route. Destruction and removal
efficiencies of organic constituents will be expected to be
excellent.
Alternative 5 - Excavation of Soils, On-Site Incineration,
Surface Grading, and Revegetation
This alternative includes site excavation, on-site incineration,
and site restoration. This alternative provides a permanent
treatment technology to reduce the toxicity and mobility of
the principle threat at the site. This alternative eliminates
the risk to public health and the environment associated with
transportation of contaminated soils off the site. However,
there is the additional public health and environmental
concerns associated with operating an incinerator in a residential
area. The length of time to implementation of this alternative
would be greater than utilizing existing off-site incineration
facilities currently in operation.
Alternative 6 - In-Situ Destruction
This alternative involves physical manipulation of the subsurface
in order to immobilize or detoxify waste constituents. In-situ
vitrification is a technology being developed for the stabilization
of contaminated wastes and is conceivably applicable to other
hazardous wastes. Contaminated soil is converted into durable
glass, and wastes are pyrolyzed or crystallized. Off-gases
released during the melting process are trapped in an off-gas
hood. Soil moisture can increase operating costs by increasing
fuel requirements because the water in the soil must be evaporated.
Several laboratory-scale and pilot-scale tests have been
conducted, and a large-scale testing system is currently being
fabricated.
ALTERNATIVES ADDRESSING OTHER FACTORS OF REMEDIATION
Alternative 1 - No Action
Under this no-action alternative, remedial activities are not
performed. Contaminated ground water is left in its current
condition. NJDEP would implement restrictions on installing
any new wells in the area. Monitoring would be provided in the
plume area and on the perimeter of the plume. This would permit
early detection of contaminant migration and alert regulatory
agencies to the potential exposure to residents of contaminated
water. Existing monitoring wells and residential wells would
be used for the monitoring program.
-------
. -37-
This alternative implies that there is no threat posed by the
contaminates present at the Williams Property site and that no
remedial «tion will be implemented. However/ the ground
water contamination poses a potential risk to the public
health andf environment. The ground water contamination can
be considered a threat to potential receptors/ and the potential
for migration of contaminants in the aquifer would continue
to exist. The ground water plume could eventually appear in
wells downgradient from the site. Potential contamination
release and pathways would remain unchecked/ and the site
would continue to be a potential source of future contamination.
There are no construction or capital improvements in this
alternative/ and time is not a criterion. However, receptors
could be exposed at some future time if migration of ground
water contaminants were to continue to occur downgradient.
Alternative 2 - Institutional Controls
This alternative includes any activity which would facilitate
remedial action and the protection of any remedy implemented
during the remedial action. This option may include/ but is
not limited to/ installation of a perimeter fence around the
site/ institution of a drilling ban within the affected area/
and closure of existing wells. Specific institutional controls
would be identified under the remedial design phase.
EVALUATION OF ALTERNATIVES
According to 40 CFR Section 300.68(i) of the NCP/ the appropriate
extent of remedy shall be determined by the lead agency's
selection of a cost-effective remedial alternative that
effectively mitigates and minimizes threats to and provides
adequate protection of human health and the environment. In
addition/ SARA also requires permanent solutions and alternative
treatment technologies or resource recovery options to the
greatest extent practicable.
»
Aside from the no-action and institutional control alternatives,
a total of thirteen remedial alternatives (seven for ground
water; six for soils) were evaluated in detail. Table 13
lists each alternative and its associated present worth
costs. In addition it provides a summary of other factors
considered in the evaluation.
The no-action and institutional control alternatives were
found to provide inadequate protection of human health and
the environment since contaminated ground water would continue
to migrate and potentially impact private wells; and the
contaminated soils would continue to act as a source of future
contamination of the ground water.
-------
-38-
GROUND WftaUt REMEDIAL ALTERNATIVES
- Extraction/ Air Stripping, and Recharge
Although the implementation of this alternative would effectively
reduce the levels of volatile organics to meet state and federal
requirements, this alternative would not adequately address the
environmental and human health concerns associated with non-
volatile organic compounds and metals. Therefore, the combination
of extraction, air stripping, and recharge is not considered a
viable ground water alternative.
Alternative 2 - Extraction, Carbon Adsorption, and Recharge
The implementation of this alternative would effectively reduce
levels of contamination to meet state and federal requirements
for organics and some metals. However, the cost for this
alternative far exceeds the costs of the other alternatives and
does not provide substantially greater protection or technical
reliability.
Alternative 3 - Extraction, Air Stripping, Carbon Adsorption,
and Recharge
The implementation of this alternative would effectively
reduce levels of contamination to meet state and federal
requirements for organics, and would lower activated carbon
usage rates and costs through the use of the air stripping unit.
Long-term risks associated with exposure to contaminated
ground water would be reduced with this treatment system.
Installation of an extraction, air stripping, carbon adsorption,
and recharge system would be implemented using established
technology and construction practices. The reliability of the
selected treatment system is based on the existing water quality
and contaminants identified., Both treatment technologies would
utilize equipment that is commercially available and has well
documented histories of treatment efficiency in similar
applications. This alternative provides a highly protective and
permanent solution to the ground water contamination in the
aquifer, and is cost-effective.
The short-term health effects related to Alternative 3 include
exposure to volatile organic air emissions from the air-stripping
tower. These emissions, if not controlled properly, could
exceed regulated air standards.
Another short-term impact associated with Alternative 3 involves
increased traffic resulting from the off-site transportation of
spent carbon. In addition, carbon adsorption systems require
the use of pressure vessels which, if not properly operated,
could rupture.
-------
TABLE 13
WILLIAMS PROPERTY COST SUMMARY
Ground Water Alternatives
1. Extraction, Air
Stripping/ Recharge
2. Extraction, Carbon
Adsorption, Recharge
3. Extraction, Air
Stripping, Carbon
Adsorption, Recharge
4. Extraction, Air
Stripping, Carbon
Adsorption,
Precipitation,
Flocculation,
Sedimentation,
Recharge
5. Extraction, Air
Stripping,
Precipitation,
Flocculation,
Sedimentation,
Recharge
6. Extraction, Carbon
Adsorption,
Precipitation,
Flocculation,
Sedimentation,
Recharge
Capital
$86,750
Annual
O&M
Total Present
Worth
$ 11,400 $156,800
$130,250 $132,200 $942,570
$160,250 $ 64,600 $557,190
$360,250 $104,600 $1,002,975
$286,750 $ 51,400 $348,200
$320,250 $174,200 $1,390,640
Time to
Implement
5-10 years
5-10 years
5-10 years
5-10 years
5-10 years
5-10 years
Comments
Effectively removes VOCs;
less efficient with semi-
volatiles.
Effective in removing both
VOCs and semi-volatiles.
More cost intensive.
Combination of technologies
providing higher degree of
treatment for VOCs and semi-
volatiles.
Adds soluble metals removal
to technology in Alternative
3.
Soluble metals would be
removed in addition to VOCs
removal. Semi-volatiles not
addressed.
Combines technology of
Alternative 2 with soluble
metals removal.
US
I
-------
7. Extraction, Air
Stripping, Carbon
Adsorption, Ion
Exchange, Recharge
Soil Alternatives
1. Excavation, Off-
Site Landfill,
Regrading,
Revegetation
a) Case I
(4000 cubic yards)
Capitol
$ 430,250
$1,442,500
b) Case II $ 248,500
(700 cubic yards)
2. Excavation, On-Site
Landfill, Regrading,
Revegetation
a) Case I $1,445,000
(4000 cubic yards)
b) Case II $1,300,500
(700 cubic yards)
3. Soil Vacuuming
$ 189,000
Annual
O&M
$139,600
N/A
N/A
$101,150
$ 91,035
$ 20,000
Total Present
Worth
$1,288,040
$1,442,500
$ 248,500
$2,066,530
$1,859,870
$311,890
Time to
Implement
5-10 years
<1 year
<1 year
2 years
2 years
1-2 years
Comments
Combines technology of
Alternative 3 with ion
exchange for soluble metal
removal.
Alternative 3 with ion
exchange for soluble metal
removal. Cost intensive.
Removes contaminants from
site, but does not include
treatment preferences of
SARA. "Land Ban" Impact.
Long term requirement of
monitoring landfill and
wells. "Land Ban Impact".
Permeability of soils
is too high and depth to
ground water too little
makes this technically
unreliable.
-------
Soil Alternatives (Cont'd) Capital $
4. Excavation, Off-Site
Incineration, Regrading,
Revegetation
a) Case I $2,050,000
(4000 cubic yards)
b) Case II § 353,500
(700 cubic yards)
5. Excavation, On-Site
Incineration, Regrading,
Revegetation
a) Case I $ 1,240,000
(4000 cubic yards)
b) Case II
(700 cubic yards) $ 353,000
6. In-Situ Destruction
$ 10,935,000
Other Alternatives
No Action
Annual
O&M
N/A
N/A
N/A
N/A
N/A
Total Present
Worth
$2,050,000
$ 353,500
$1,240,000
$ 353,500
$10,935,000
$50,000 $ 307,230
Time to
Implement
1-2 years
<1 year
1-2 years
<1 year
2 years
Comments
lii'f
;r;'a >pi
Permanent destaviction of
waste complies with RCRA
and SARA.
Will be less time
intensive to implement
than on-site
incineration.
Permanent destruction
of waste via mobile
incinerator. Must
comply with air quality
requirements.
Extremely cost intensive
and does not provide
higher degree of
protectiveness.
ND further action except
for monitoring existing
wells. Restrictions on
new wells.
Institutional Controls
$ 25,000 $50,000 $ 332,230
Fencing, closure of
_ • . » • •• ••
-------
-42-
Alternative 4 - Extraction, Air Stripping, Carbon Adsorption,
Flocculation, Sedimentation, and Recharge
The shortHHplf impacts associated with Alternative 3 are the
same in AlWpiative 4. In addition, the use of flocculants
and precipftants is required. These additional compounds may
include ferric chloride, alum, lime, sodium hydroxide, and
sodium sulfide. Transportation and use of these compounds
increases the possibility of an accidental release that could
affect workers and the public. However, the use of this
treatment system will reduce the long-term health risks from
the contaminated ground water after treatment.
The technical concerns of Alternative 4 include those discussed
under Alternative 3 and the additional concerns associated with
precipitation, flocculation, and sedimentation. These are well
developed processes that have been commonly and successfully
applied to the treatment of various industrial wastewaters
containing soluble heavy metals. The equipment is commercially
available and has a well-documented history of treatment efficiency,
In addition, the metals removal process for this alternative
significantly increases the cost beyond that of Alternative 3.
While metals removal would be comparatively significant, the
metals detected have not been indicated to pose a public health ~
problem. The levels detected are within ranges found in
background. Therefore, this alternative was eliminated
because it far exceeds the cost of other alternatives without
providing substantially greater protection or technical
reliability.
Alternative 5 - Extraction, Air Stripping, Precipitation,
Flocculation, Sedimentation and Recharge
The short-term problems associated with Alternative 4 are the
same in Alternative 5, with the exceptions of carbon use,
transportation, and disposal.
The technical feasibility concerns associated with Alternative
5 are the same as those discussed in Alternative 4, with the
exception of concerns involving carbon adsorption. This
alternative would only provide reduction of volatile organics
and metals to state and federal requirements. Non-volatile
organics would not be reduced significantly by this alternative,
and, therefore, would not be adequately protective of human
health and the environment.
Alternative 6 - Extraction, Carbon Adsorption, Precipitation,
Flocculation, Sedimentation, and Recharge
The level of protection and technical reliability of this
alternative is equivalent to that of Alternative 4. Since
the cost for this alternative far exceeds the cost for
Alternative 4, however, Alternative 6 has been eliminated
from further consideration.
-------
_43-
- Extraction/ Air Stripping/ Carbon Adsorption,
*nd Recharge
Although io|KMmentation of this alternative would effectively
reduce levels" of contamination to meet state and federal
requirements for organics and metals/ this alternative has
been screened from further consideration due to the high cost
of its implementation. The cost for this alternative far
exceeds the cost of Alternative 4 and does not provide
substantially greater protection or technical reliability.
SOIL REMEDIAL ALTERNATIVES
Alternative 1 - Excavation, Off-Site Disposal, Surface Grading
and Revegetation
The short-term effects of Alternative 1 include the release
of potentially contaminated dust particles and volatiles
during excavation. Without proper controls, these fugitive
emissions could cause short-term health problems for workers
and the nearby public. The routes of exposure would include
inhalation, contact, and ingestion. At the Williams Property
site the contamination by volatile organics and semi-volatiles
is greater in subsurface soils in sample B-ll than in the top
soils. During the excavation, exposure of workers to the
subsurface contaminants is likely. Chemicals may volatilize
during excavation. Following dilution in ambient air, however,
exposures to off-site neighbors are not likely to be significant.
Health and safety monitoring for the presence of volatile
organics will warn workers of high airborne concentrations
and the need for protective equipment usage.
Should the level of dust become significant during excavation,
dust control methods would be used to reduce the dust exposures.
These control methods may include covering all areas except the
active work face with polyethylene sheeting, and using dust-
suppression methods such as foam for the active work areas.
Because of increased logistical requirements (heavy equipment uses,
and transportation and disposal of excavated dirt), a short-term
risk of vehicle accidents on public roads and on the site
exists. Accidental release of contaminated soils from vehicles
could also occur. The long-term health risk is nearly eliminated
since the contamination source will be removed.
Off-site disposal of wastes must comply with RCRA regulations
(40 CFR Parts 261-265). RCRA manifest requirements, under 40
CFR Parts 262 and 263, must be complied with for all wastes
that are shipped off the site. The waste generator must
comply with RCRA manifest requirements under 40 CFR Parts 262
and 263, and the generator should comply with applicable
hazardous waste generator requirements under 40 CFR Part 262.
In addition, the facility selected to receive the wastes must
-------
-44-
be in comgk^nce with all applicable federal and state
environmeoKtand public health statutes. Under 40 CFR
264.12, BCgKptorage and disposal facilities are required to
notify thfc13|£i»ffator, in writing, that they are capable of
managing thewastes.
The transportation of hazardous wastes is regulated by the
Department of Transportation, the Environmental Protection
Agency, and the State. Applicable Department of Transportation
regulations include Department of Transportation 49 CFR Parts
172-179; Department of Transportation 49 CFR Part 1387 (46 FR
30974, 47073); and Department of Transportation DOT-E 8876.
Excavation, transportation, and off-site disposal can be
implemented using established technology and construction
practices. Excavation is reliable in that it removes the
source of contamination from the site. However, the excavated
soil may become a source of future contamination at the
off-site disposal location. Although the cost for this alternative
is relatively low, under SARA, off-site disposal, without
treatment does not meet the SARA preference to reduce toxicity
through the use of treatment. This option was eliminated.
Alternative 2 - Excavation of Soil, 6n-Site Disposal in Constructed
Landfill, Surface Grading, and Revegetation "
This alternative offers the advantage of minimizing the risk to
human health and the environment by eliminating off-site
transportation. However, RCRA requires all owners and operators
of land disposal facilities to establish a ground water
monitoring program (40 CFR Part 264, Subpart F). Once established,
ground water monitoring programs must continue for an average
of 30 years depending on site-specific conditions. These
requirements significantly impact the long term cost of the
alternative. The construction and maintenance requirements
for such a facility sized for ,the relatively small quantities
of soil at this site impacts its implementability. In addition,
this alternative does not meet the SARA preference to reduce
toxicity through the use of treatment. As a result this option
was eliminated from further consideration.
Alternative 3 - Installation of Vacuum Extraction Wells and
Soil Vacuuming System
This alternative has been screened from further consideration
because it is not considered feasible or reliable for the location
and conditions at the site. For this alternative to be successful
it is required that the depth to ground water be great enough that
there is a substantial cov-jr of contaminated, unsaturated soil
above the water table (at least 10 feet) and that the contaminated
soil be pervious enough to permit a significant flow of air
through the zone of contamination under a modest applied vacuum.
Hydrogeological investigations conducted of the site during the
-------
-45-
remediaJ-ijg|«etigation indicated a water table generally less
than 10 faggjjin depth. Therefore, because site specific
c.onditiortijjjjiiktt the effectiveness of this alternative, it
has been wwina ted from further consideration.
Alternative 4 - Excavation, Off-Site incineration, Surface
Grading and Revegetation"
The short-term problems associated with Alternative 4 are the
same as in Alternative 1 except for additional concerns
associated with air emissions from the incineration facility.
However, the long-term risk' is nearly eliminated since the
contamination source will be eliminated by incineration,
thereby satisfying SARA's- preference for treatment which
permanently reduces toxicity.
Excavation of contaminated soils and off-site incineration would
be implemented using established technology. Rotary kiln
incineration has well-documented histories of treatment efficiency
in similar applications.
Incineration facilities which would be utilized are only
those operating in compliance with all appropriate requirements.
Air emission risks are, therefore, considered addressed.
Alternative 4 has been determined to be cost-effective when
compared to the other soil alternatives. Alternative 5
(below) is equal in cost, but cannot be implemented in as
timely a manner as Alternative 4. When compared to the
remaining soil alternatives, this option is significantly
lower in cost, while providing a permanent remedy.
Alternative 5 - Excavation, On-Site Incineration, Surface
Grading and Revegetation
The short-term effects of Alternative 5 include the release of
potentially contaminated dust particles and volatiles during
the excavation. These concerns have been discussed under Soil
Alternative 1. In addition, there are health risks associated
with exposures to the incinerator off-gases. These exposures
could effect both workers and the nearby general public.
Incineratoir emissions would be controlled with appropriate
technologies. Alternative 5 will have similar institutional
requirements and technical reliability as discussed in Soil
Alternative 4.
Although, this alternative meets the criteria of protectiveness,
permanence and cost-effective, it will take more time to
implement and complete than Alternative 4. As such, this
alternative was eliminated.
-------
-46-
Alternative 6_- In-Situ Soil Destruction
This alt«4^H&re is an order of magnitude greater than the
other altarajpEives in terms of cost and does not provide
significant^'greater environmental or public health protection.
Therefore, this alternative has been eliminated from further
consideration.
SELECTED REMEDY
After review and evaluation of the remedial alternatives in
light of their relative effectiveness, implementability, and
cost, EPA and NJDEP presented ground water Alternative 3 and
soil Alternative 4 to the public as the preferred remedy for
the Williams Property site. Consistent with the input received
during the public comment period, which consisted primarily
of questions and statements transmitted at the public meeting
held on August IS, 1987, these alternatives have been selected
by EPA and NJDEP as the remedial solution for the site. The
major components of the selected remedy are:
Ground Water (Alternative 3)
1. The leading edge of the contaminated ground water plume
will be determined during design. This determination will
involve a detailed hydrologic investigation. The investigation
will also determine the number of wells needed, and where
to place them to efficiently extract the plume.
2. The contaminated ground water will be brought back to the
site and will be passed through a counter-current air
stripping column to enhance the exchange of organics from
the aqueous stream to an effluent air stream. Air stripping
is expected to perform successfully, given the conditions
at the Williams Property site. Removal of volatile organic
contaminants from water at low influent concentrations is
common practice and a high' degree of removal is expected at
this site.
3. The partially treated ground water will then be passed
through a bed of granular activated carbon that will
absorb any remaining organic constituents from the aqueous
phase. Carbon adsorption has been shown to be effective
in removing both volatile and many non-volatile organic
compounds to low levels. In addition, certain inorganics
have been shown to have moderate to high sorption potential.
4. The treated ground water will be recharged back to the
aquifer underlying the site. Recharge of the treated
ground water offers several benefits: (1) reduction of
the time duration of treatment, (2) minimal effects from
drawdown during ground water recovery, and (3) creation
of a ground water boundary to detour inflow from outside
the target zone. Recharge will raise the level of ground
-------
-47-
water in the localized area around the recharge wells.
This should not have an adverse impact on surface drainage
characteristics or vegetation. The recharge facility will
be carefully located to ensure that building foundations,
roadways, or other facilities are not impacted by activities
associated with ground water recharge. The pumping and
piping equipment associated with the recharge system is
conventional, relatively inexpensive, and will require
minimum maintenance.
Soils (Alternative 4; Case II)
1. The most highly contaminated soils, as defined by positive
HNU readings in soil borings of 15 parts per million or
greater, will be excavated. The amount of excavated material
is currently estimated to be 700 cubic yards (Case II). It
is anticipated that removal of this volume of material will
meet the soil cleanup objectives developed by the State
of New Jersey and used in the ECRA program (one ppm total
volatile organics).
2. The excavated soil will be transported off-site to an
existing approved hazardous waste facility for incineration.
3. The excavated area will be backfilled with clean native
soils.
4. The final surface of backfill will be graded to converge
with local topography and revegetated.
Water Supply
At the present time, it is believed that all but one residence
with a private well in the immediate vicinity of the site has
been connected to a public water supply system. That single
residential well, located on the Williams Property site, is
known to be contaminated and has been taken out of service.
The selected remedy will provide an alternate source of
potable water to this residence as well as any others found
to be impacted by the site.
COST EFFECTIVENESS, PROTECTIVENESS AND PERMANENCE
As mentioned previously, Table 13 presents a summary of the
remedial alternatives, including the cost of the alternatives.
An alternative is considered cost effective if it will attain
the required cleanup levels at a reasonable cost. The selected
remedy for the ground water and for the soil accomplishes this.
The ground water remedy provides a highly protective and
permanent solution to the contamination of the Holly Beach
Aquifer at about one half the cost of the next best alternative
(Alternative 4).
-------
-48-
Off-site incineration provides a permanent solution to the
residudal contamination in the soils. It is equal in cost to
on-site incineration (Alternative 5), but will not involve
creating a possible new source of air contamination in the
area. When compared with the other soil alternatives the
selected remedy provides a permanent and protective solution
at less than one half the cost. The alternative provides
treatment technology which reduces the mobility, toxicity and
volume of the principal threat at the site.
CONSISTENCY WITH OTHER LAWS (ARARs)
One of the primary statutes that affects CERCLA activities is
the Solid Waste Disposal Act (SWDA)/ particularly Section
1003(a), which emphasizes maximum, protectiveness through safe
hazardous waste management practices, implementation of
permanent solutions, and minimization of both generation and
land-based disposal of hazardous wastes. The combination of
ground water treatment and off-site incineration of contaminated
soils provides protection to human health and the environment
through the use of established technologies. It also represents
a permanent solution for the site by (1) removing the contaminants
from the ground water by air stripping and carbon adsorption
and (2) removing any residual source of continuing contamination
from the site to a secured off-site facility for incineration.
As a result, residual risk becomes negligible and long-term
reliability is high.
The selected alternatives will provide a permanent remedy for
the contamination at this site. The treatment levels to be
reached are the maximum contaminant levels (MCLs) of the Safe
Drinking Water Act (SDWA) and the New Jersey Environmental
Cleanup Responsibility Act (ECRA) for ground water and soils,
respectively.
During the implementation of the selected remedy, both emissions
of volatile organics from the air stripping operation and
volatile organics and particulates during excavation of the
soils will have to be controlled. The design criteria to
ensure that regulated air standards are not exceeded will be
followed. These criteria are: NJAC: Title 7; Chapter 27,
subchapter 8 (Permits), subchapter 13 (Ambient Air Quality
Standards), subchapter 16 (Volatile Organic Substances),
subchapter 17 (Toxic Volatile Substances); and the Resource
Conservation and Recovery Act (RCRA).
ENFORCEMENT ACTIVITIES
To date, only two potentially responsible parties have been
identified for the Williams Property site: The property
owner and the generator of the hazardous substances. The
property owner is not financially viable. Although, the
-------
-49-
generator is, an agreement could not be reached with that
party regarding the conduct of the RI/FS. Upon the signing of
this ROD, EPA will issue a notice letter to the generator to
bring it into negotiations regarding the remedial design/remedial
action phase of this remedial action.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Williams Property site was
approved in July 1984. This document lists contacts and
interested parties throughout government and the local community.
It also establishes communication pathways to ensure timely
dissemination of pertinent information.
The RI/FS reports were sent to four local information
repositories to initiate the public comment period, which
extended from August 6, 1987 to September 9, 1987. A public
meeting was held on August 18, 1987 to present the results of
the RI/FS, along with the preferred alternative for the site,
which was developed by EPA and NJDEP.
A summary of the comments raised concerning the RI/FS and the
public meeting are contained in the attached responsiveness
summary. The local community did not express strong positive
or negative feelings for any of the remedial alternatives.
Their main concerns were .when the site would be cleaned up,
and how long it would take.
-------
-50-
SCHEDULE*
Activity
- Public Meeting
- Regional Administrator Signs
Record of Decision
- 60 Day Enforcement
Moratorium **
If no PRP Agreement, then:
- EPA Funding of Remedial Design
"NJDEP Contractor Procurement
Process for Remedial Design
- Initiate Remedial Design
- Reopen PRP Negotiations for
remedial action implementation
at Design Completion
- Contractor Procurement Process
for Construction
- Initiate Remedy Implementation
- Construction Complete
Date
August 18, 1987
September 25, 1987
September 1987 to
November 1987
January 1988
June 1989
July 1989
August 1989
October 1989
October 1990
*This is a projected schedule for this site and it is therefore
subject to future modification.
**If a "good faith" offer by the PRPs is made within 60 days,
the enforcement moratorium would be extended an additional 60
days.
-------
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
RICHARD T. DEWLJNG. Ph.D.. P.E., COMMISSIONER
CN402
TRENTON, NJ. 08625
609 • 292 • 2885
1 8 SEP 1987
Mr. Christopher J. DaggetC
Regional Administrator
USEPA - Region II
26 Federal Plaza
New York, N.7. 10278
pear Regional Administrator Daggett:
This is to formally notify the United States Environmental
Protection Agency that the New Jersey Department of Environmental
Protection has reviewed the draft Record of Decision for the Williams
Property Site and concurs with the recommended remedy. This remedy
will consist of the following:
- Extraction and treatment of contaminated ground water on-slte
using air stripping to remove volatile organics and carbon
adsorption to remove remaining volatile organics and
semi-volatile organics.
Recharge of the treated ground water to the aquifer on-slte.
Excavation of the contaminated soils above the action level at
the original spill area.
- Removal of the excavated soils .to an approved off-site disposal
facility for incineration.
- Regrade the site with clean fill, revegetate and restore the
site.
Mew Jersey fully appreciates the importance of the Record of
Decision in the cleanup process and will continue to take all
reasonable steps to ensure that the State's commitments in this area
are met.
Sincerely,
Richard T. Dewling
100% Recycled
-------
SEP 2 11987
WILLIAMS PROPERTY SITE
MIDDLE TOWNSHIP
CAPE MAY COUNTY, NEW JERSEY
RESPONSIVENESS SUMMARY
This community relations responsiveness summary is divided into the
following sections:
Section I Overview - This section discusses the New Jersey Department
of Environmental Protection (D£P) and the United States
Environmental Protection Agency's (EPA) preferred alternative
for remedial actions, and likely public reaction to this
alternative.
Section II Background on Community Involvement and Concerns - This
section provides a brief history of community interest and
concerns raised during remedial planning activities at the
Williams 'Property site.
Section III Summary of Major Comments Received during the Public
Comment Period and the PEP/EPA Responses to the "Comments -
Both written and oral comments are categorized by topics as
are the DEP/EPA responses.
Section IV Remaining Concerns - This section describes remaining
community concerns about which DEP/EPA^ should be aware in
conducting the remedial design and remedial action at the
Williams Property site.
In addition to the above sections, attachment A (included as part of this
responsiveness summary) identifies the community relations activities
conducted by DEP and EPA during remedial response activities at the Williams
Property site. Attachment B was written as a direct response to one of the
questions which was asked at the August 18, 1987 public meeting.
Section I Overview - The final alternative specified in the Record
of Decision (ROD) is a combination of Ground Water
Alternative 3 (extraction, air-stripping, carbon adsorption
and recharge) and Soil Alternative 4 (excavation of soils,
off-site incineration, surface grading and revegetation).
Although the residents asked numerous questions at the August
18, 1987 public meeting, and although they are concerned
about the continued dumping and the building moratorium,
there was virtually no criticism of the chosen alternatives.
Section II Background on Community Involvement and Concerns - The
county and municipal governments have played significant
roles in trying to resolve the past and current problems at
the Williams site. In order to protect public health until
the Remedial Investigation/Feasibility Study (RI/FS) would
define the area of contamination precisely, a building
-------
moratorium was established April 1, 1984 for the area within
a one mile radius around the site. This was accomplished by
not allowing well permits to be granted. The Cape May County
Health Department made conscientious efforts to maintain a
local community relations program, in the hopes of hastening
the cleanup process.
The DEF has an active community relations program at
Superfund sites, including the Williams Property. A public
meeting was held December 9, 1985 at the start of the RI/FS.
Approximately fifty people signed the sign-in sheet. On June
6, 1984 there vas a DEP briefing with local and county
officials about the land-use restrictions. The town hosted a
special meeting on September 10, 1985 to discuss problems at
the Williams site. These were in addition to the August 18,
1987 public meeting on the remedial alternatives.
-III. Summary of Major Comments and Responses
Site History Questions • '
What happened to the drums that were originally removed by the (DEP)?
Response; Contaminated soil and drum carcasses were transported to
the Browning Ferris Industries Landfill, Glen Burnie, Maryland. This
. . facility is permitted by the state of Maryland to treat, store and
dispose of hazardous waste.
What was the cost of the RI/FS?
Response; The total cost of the study through August, 1987 is
$540,000 but that does not include the cost of the emergency removal
action which was conducted in 1980.
Were the drums taken to MarTee Landfill or other sanitary landfills in the
county (Cape May County)?
Response; Hazardous wastes from the site were not disposed of at
sanitary landfills. As previously mentioned, wastes were disposed of
at the Browning-Ferris Industries Landfill in Glen Burnie, Maryland.
One of your slides indicated that the contamination of residential wells
observed in 1979 is not likely to have been caused by the documented spill.
What did cause the contamination?
Response; Local potable wells sampled in 1979 indicated that low
level organic contamination was present at some locations. Given the
rate of groundwater flow determined by the RI/FS and the distances to
the contaminated potable wells, It is not possible that the 1979
Williams Property spill was the source. Approximately 100 potable well
samples have been taken between 1979 and the end of the RI/FS. Since
the initial sampling, concentrations in almost all potable wells have
decreased to non-detectable levels.
-------
As part of the Remedial Investigation, a hazardous substance Inventory
map was compiled for the area surrounding the Williams spill site. The
Inventory located numerous possible sources of contamination
surrounding the site in addition to adjacent local sand roads. It is
postulated that the potable well contamination in 1979 was due to local
dumping which predates the Williams Property spill.
What sort of industrial uses produce the type of pollutants that were found
on the site?
Response; The basic contaminants identified as being present in the
gromid water are tetrachloroethylene, trichloroethylene, 1,1,1
trichloroethane and xylenes. All are commonly used in so many
industries that it is difficult to pinpoint one industry as the
source. Xylene is a common component of gasoline. Some of these
chemicals are in ordinary household cleansers, detergents, spot
removers, degreasers, resins, paints and septic tank cleaners. There
ace many possible sources for these waste chemicals.
Have you ever tested for dioxins in the soil at the site?
Response; Yes. We have taken and analyzed four samples, each of
which turned out to have non-detectable levels.
Under the health assessment, did you ever look into causes of death in the
Immediate area?
Response; We developed toxicity profiles on the chemicals which we
did find and looked at exposure routes - inhalation, ingestion and skin
absorption, both for children and adults. We calculated what increases
in cancer might be expected from these exposures. These statistics are
in Section 3 of the RI/FS.
We have not initiated an epldemiological study because the population
has really not been exposed to the contaminated ground water. The
potable well sampling has indicated that the wells had not been
contaminated by the Williams' spill. Local residents had not been
exposed to the contaminated drinking water prior to the municipal water
connection. Mr. Williams' contaminated well has been locked by the
county health department as ordered by the court in 1984. The Public
Health Assessment has indicated that residual contaminated soil
presents an insignificant direct public health risk.
Ground Water Plume Questions
How large is the plume? How fast has it moved and in what direction?
Response; We installed 15 monitoring wells - shallow wells
approximately 20 feet deep, intermediate wells about 60 feet deep, and
deeper wells to 120 feet. We also sampled 8 residential wells both
close to the site and as far away as 2,600 feet. The width of the
plume is less than 300 feet. The minimum distance of the plume from the
contaminated soil is 800 feet, and the maximum distance is 1,400
feet. It is flowing in a northeasterly direction. We believe the
-------
plume la shaped like an elongated balloon.
How deep is the plume and at what rate is it going down into the ground?
Does it go down into sandy soil? Does it sink?
Response; The first aquifer, the Holly Beach aquifer, has a maximum
depth of 60 feet. It begins about 10 feet below the ground surface.
At about 40 feet there is a some clay or silty sand and then there is
20 to 40 feet of sand. The upper two layers of sand are contaminated.
If you go down 80 or 100 feet, there's a clay layer. Our evidence
shows that this clay layer has not been penetrated by contaminants. We
believe Che plume has traveled downward 60 to 80 feet. Since
trichloroethylene, tetrachloroethylene and 1,1,1 trichloroethane are
heavier than water, they can sink right through the water column.
Contamination has been detected throughout the surface aquifer within
the plume.
«
'Do you have a list of the known contaminants that have been found in that
area?
Response; Refer to the Tables in the RI and the FS.
How many gallons of water have to be removed from the area and how long will
it take?
Response; Once the wells are installed, they will be pumping
approximately 10 to a 100 gallons a minute. This will mean hundreds of
thousands of gallons, maybe millions. While the pumping is maintained,
the plume migration will be controlled and the ^plume size will not
expand. We will keep treating the water until it meets all relevant
standards. This could take four or five years.
Are you going into the ground water or into the aquifer?
Response; Ground water locally consists of a number of aquifers.
How deep will the wells be?
Response; There may be one well or a series of wells, depending on
the results of the design stage. They will be designed to correct the
contamination in the 60 to 80 foot zone.
Concerns about soil contamination
You said it would take two months to excavate the soil. How many yards of
material are you going to excavate? Why does it take two months?
Response: The design phase will determine the extent of excavation
which will be required. Current estimates of the volume to be
excavated range from 700 to 4,000 cubic yards. Excavation of
contaminated soils requires careful planning and handling at all
stages. Soil must be excavated, classified and then transported to a
suitable treatment site. Workers on the scene must be protected
throughout all of this. Protective gear is cumbersome.
-------
.5
You said you would be going down through the sand again. Is this going to
be 10 or 60 feet under the clay or is it 10 to 60 feet from the ground?
Response; From the ground level, it's about 10 feet until you
encounter ground water. Another 30 feet below there's a silty or clay
layer which varies in thickness from almost absent to a few feet
thick. Then there's another 40 feet of sand underlain by a 15-35 foot
clay layer. What is contaminated is from 10 feet below the surface
down to the underlying clay at approximately 80 feet.
How long Is it going to take before the contaminants penetrate the clay?
Response; The clay will not absorb the ground water. Permeability
through the clay is extremely slow. Organics have an affinity for clay
material and they will tend to absorb to the clay, thereby further
reducing risk.
'On soil remedial alternative number two, if says a landfill will be
constructed on-site for .the excavated contaminated soil. Would it also
accept contaminated soil from other locations in the state?
Response; This alternative has been rejected because of cost.
Infeasibility and technology, but it was an alternative which had to be.
considered Initially.
What happens to the soil after it is incinerated?
Response; The remaining incinerated soil (ash) wpuld be deposited at
a chemical landfill which is permitted to accept hazardous materials.
You said there was metal contamination in the soil.
Response; The metals in the soil are well below the DEP action
levels and, in fact, are below New Jersey background levels in some
cases.
Questions about air stripping
Would you please explain what air stripping is and if it would create air
pollution?
Response; Air stripping is a process in which a column is brought
onto a site or built there. The water goes up to the top of the column
and is allowed to trickle down through the column, which is packed with
material similar to ping-pong balls with large surface areas. As the
water trickles down, air is pumped upwards and the volatile organics
are driven off. Air stripped contaminants can be captured via carbon
adsorption at the end of the volatilization chamber. The applicable
air emission standards would be applied and used as a basis to
determine the necessity of and the extent of carbon adsorption
required. We will perform air monitoring to make sure this is
protective of air quality around the site. Calculations in Appendix C
of the FS indicate the volatile gas emissions will be well under
permissible levels even if the worst ground water conditions occurred.
-------
What happens to the carbon filters? How many layers thick is the carbon?
Response; The filters are processed and regenerated through
heating. The engineering design stage will determine how much carbon
will actually be necessary to purify the water.
Procedural Questions and Future Actions
What number are we on the cleanup list and why has it taken eight years to
get this far?
Response: The Williams Property is ranked number 59 of the 100
National Priorities List sites located in New Jersey. Although the
dumping occurred in 1979 and the removal took place in 1980, the study
of the remaining contamination began in April of 1986. It is now
August. 1987 so this was only 16 months. The Superfund legislation
created an entirely new program. Procedures needed to be established,
an organization had to be created, guidelines had to be determined,
etc. In addition,- the remedies to be considered at each site are often
on the cutting edge of technology.
Now we are past the most difficult part. When the Superfund amendments
were passed in October, 1986, there was an additional emphasis on
providing permanent remedial solutions, which take more time than
temporary ones.
What would happen if you didn't do anything? You didn't do anything in
eight years and nobody died. I think the contamination jis dissipating.
Response; Yes, but that's the problem now. The contamination is
spreading. The soil remains a source of future ground water
pollution. Everytime it rains, the rain water filters down through the
soil and carries additional contamination into the ground water. We
are required to consider the possibility of doing nothing, but in this
case, we rejected that alternative because it is not protective of
human health or the environment.
Congressman Hughes has played a part in moving this project. Has his office
been provided with all these documents so he might review them?
Response; Congressman Hughes was mailed a copy of the Agenda and
Proposed Remedial Action Plan on August 24, 1987.
One of the concerns I have is about the lakes back there and the gravel
pits. Have they been tested? Has the wildlife been tested for
contamination? Are the fish safe to eat? Are the kids safe swimming in the
gravel pits?
Response: When the sampling crew went out, the gravel pits were dry
so sampling could not be done.
Surface water feeds these pits. Since the water flows to the northeast
of the Williams property and since two of the pits are to the southwest
of the site, the pits west of Siegtown Road should not be contaminated
-------
by this spill. The pit to the east of Siegtown Road is further away
than th» potable wells which were sampled. These wells had
non-detectable levels of contamination.
What security arrangements will be made to protect the monitoring wells and
air stripping unit?
Response; Although the details will be worked out during the design
stage, we can say that usually the piping is underground and the
treatment works are either enclosed in a building or surrounded by
fencing.
I seem to get the feeling from you that we're talking about another plume of
contamination emanating from the dump. When you find a problem and there
are indications that it could have spread to a new area, is that referred to
as a further investigation or enforcement issue or do you just zoom in on
one issue? If there could have been another source, will you check it out?
• .
Response: After determining the extent and type of contamination,
immediate hazards are addressed. Sources of contamination are
investigated as part of governmental activity In such cases.
Has it ever been the case that your decision on remedial action has been
changed by comments from the public?
Response; Yes. (See attached correspondence, Item B).
Do you know what the total cost of the cleanup will be? .
Response; We estimate that it will be in the neighborhood of
$1,000,000 to $2,000,000 over and above th« cost of the RI/FS.
How many years will the cleanup take?
Response: It will take until the end of September 1987 to make the
final decision about which alternative is the best. Then it takes 12
to 18 months to do the engineering design after which bids are
solicited with a construction firm to do the site work. The soil
removal would take two or three months and the ground water cleanup
might take four or five years.
IV. Remaining Concerns
Concerns About Future Dumping
The township was advised in April that the DEP enforcement officials were
coming down to investigate reports of crank case oil and automatic
transmission oil still being dumped at the site. What Is the status of
these reports and what is the result of the investigation? Who made the
physical inspection?
Response; The investigation is not complete. The Enforcement
Element of the DEF and the Cape May County Health Department are
conducting inspections with input from DEP's Division of Hazardous Site
-------
Mitigation and Division of Solid Waste Management. See Attachment C
for Cap* May County's progress. Follow-up inspections and actions will
be forthcoming.
I think the continued dumping is an immediate problem and all of the work
that you have done thusfar could be jeopardized by the fact that Mr.
Williams may be putting more contaminants into the ground.
Response; We agree, action must be taken to prevent reoccurrence of
the dumping.
Who is legally responsible for the dumping?
Response; As the remediation of the site is ongoing and is being
financed with public funds, the question of liability is one that
arises in two contexts - the allegations concerning continued dumping
at the site and the recovery of the public funds expended during the
cleanup.
As to the former, 'DEP will undertake an investigation to determine if
there is in fact dumping presently occurring at the site. As to the
Identity of the persons who might ultimately be liable in a cose
recovery action seeking a return of governmentally expended funds, that
determination cannot be made until such an action is taken. It is not
OEP or EPA's policy to prematurely reveal the identity of parties who
may be legally responsible for the release of hazardous substances
until either agency has gathered sufficient evidence and initiated
enforcement action.
Moratorium
The taxpayers carry the burden of this one mile radius moratorium. Can't
you make the recommendation to reduce the size of the area? How long will
it take?
Response; The DEP did not set up the moratorium, although it is
certainly one way to prevent new wells from being drilled into a
contaminated aquifer and thereby exposing new residents to hazardous
substances. Our Division of Water Resources is working on this problem
and their report should be ready in another month. (10/87)
Presently the DEP is awaiting information from the township engineer,
the county planning board or the county health department regarding the
actual number of wells in the area. Once that information is obtained,
a well restriction form is filed with the Bureau of Water Allocation
within the DEP.
-------
fctatt of Jlcto
DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF HAZARDOUS SITE MITIGATION
401 E. State Su, CN 413, Trenton, NJ. 08625
(609) 984-2902
Anthony J. Fan
Director SEP 1 5 198?
Ms. Mary Ann Gay
P.O. Box 531
Green Creek, NJ 08219
. * *
Dear Mary Ann:
The question you raised at the Williams Property public meeting about
whether public input has ever affected the agencies' decisions on a site
cleanup was an important one. In response, I will give you the information
I have been able to gather from New Jersey's experience, as well as
nationally.
Krysowaty Farm (site 115 on the attached New Jersey National Priorities
List), was mentioned to you as an example of a Site atx which the citizens'
response made a difference in the remedial decision. In that case, the
United States Environmental Protection Agency (EPA) intended to choose the
"No Action" alternative, although the local health department wanted to have
new water lines installed. Because of citizen input, new water lines were
Installed.
In the case of Llpari Landfill (site II, the NPL), the original plan to
flush and treat the contamination
-------
It «ay be helpful for your understanding of the situation to know that the
Superfund cleanup program is relatively new and complex, and often on the
cutting edge of technology. Even so, there have been 27 Records of Decision
(ROD) completed through 1986 in New Jersey and five are pending this year,
for a total of 32.
Although the process is thorough, tedious and time-consuming for us all,
there is one favorable aspect. By the time the Rl/FS is completed, our
contractors and Department Personnel usually evaluate any reasonable
solution to the problem. Hundreds of thousands of dollars and many staff
hours go Into each report, both by government agencies and their
contractors, so there are not often brand new solutions which emerge during
the public period prior to the final decision.
-Citizens' comments are always welcomed. We have an obligation to consider
all such comments, some of which are very valuable in our efforts on behalf
of the residents of New Jersey in addressing environmental problems.
In order to answer your question more thoroughly and from a broader base of
information, we have been in touch with USEFA headquarters in Washington*
D.C. They have sent the enclosed "Community Involvement" article for you.
Also enclosed is a booklet on "New Jersey's Hazardous Waste Management
Program,1' a summary of DEP's Community Relations Program at Superfund sites,
and an EPA publication about "Public Involvement in the Superfund Program".
v
Thank you for your patience in awaiting this reply to your question. If you
would like further information, please let me know and I will try to help
you. My phone number is (609) 633-2320
Susan Topf
Bureau of Community Relations
HS249:fb
attachment
c: G. Singer, Chief, BCR, NJDEP
M. Shapiro, National Community Relations Coordinator, USEPA
-------
COMMUNITY RELATIONS PLAN
FOR HAZARDOUS WASTE SITE REMEDIAL ACTION
WILLIAMS PROPERTY
MIDDLE TOWNSHIP
CAPE MAY COUNTY
JULY 1984
A
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
DIVISION OF WASTE MANAGEMENT
HAZARDOUS SITE MITIGATION ADMINISTRATION
-------
- 1 -
PREFACE
This Community Relations Plan is primarily an internal
working document which serves as a guide to communication
with the affected community. The activities and schedules
in the Plan may be altered according to future prevailing
circumstances.
-------
11
CONTENTS
Page
«
Introduction 1
Background 1
Map of Site 2
Key Issues 3
History of Community Involvement 4
Objectives of the Community Relations Program 6
Community Relations Techniques To Be Used 7
Proposed Work Plan and Estimated Schedule 8
Contacts 10
-------
COMMUNITY RELATIONS PLAN
REMEDIAL ACTION AT THE WILLIAMS PROPERTY SITE
MIDDLE TOWNSHIP, CAPE MAY COUNTY
JULY 1984
Introduction
This Community Relations Plan outlines activities to be conducted during
Superfund hazardous waste remedial action at the Williams Property site in
Cape May County. The plan is designed to inform public officials and
citizens* as veil as to receive input from then on the remedial action. The
plan may be updated periodically to reflect project activities and public
involvement. The plan schedule is based on the project status as of May,
1984. The Williams Property site was Included on the proposed National
Priorities List issued by the United States Environmental Protection Agency
(US*EPAJ on December 20, 1982. Of 85 New Jersey sites on the National
Priorities List, this site is ranked 53rd in priority.
A. Background and Key Issues
1. Background
The Williams Property is an Inactive site situated less than 600
feet south of Siegtown Road and approximately dne-half mile west of
Route 9 in Swain ton, Middle Township. This 5.6 acre tract is found
In a mixed residential/agricultural area of the southernmost
municipalities of the Plnelands National Reserve. Not more than
three miles to the northwest lies the Timber Beaver Swamp Fish and
Wildlife Management Area, a major aquifer recharge zone, while on
either side of the site are sections of prime wetlands habitat.
Soil composition on site is of highly permeable coarse-to-fine-
grained sand, with varying amounts of fine gravel, overlying the
Holly Beach Aquifer. This, in turn, overlies the larger Cohansey
Aquifer, separated from the Holly Beach Aquifer by semi-pervious
estuarlne clay. The nearest surface water sources are standing
waters in surrounding gravel pits roughly 700 feet away;*Deep Creek
is approximately 3,100 feet from the site. Found within a
three-mile radius are three nursing homes, two schools, the County
Vo-Tech Center, the County Office Complex and jail, a County Park,
and local campgrounds. There are 170 people living within 100 feet
of the site, mostly along Siegtown Road, while the total permanent
population within three miles is 3,488. This number is estimated
to Increase seasonally (primarily with campers) to 1?,803. There
is also a dally Influx of about 2,000 outside residents to the
County Courthouse in Cresthaven.
The site Itself is bounded by Siegtown Road to the northeast and
accessible by a dirt road. The property has both wooded and open
areas with the principle source of contamination localized in a
clearing just south of the house. There are several abandoned
vehicles and refuse piles strewn throughout the property.
Ownership is listed to a Mr. Gerald Davis who is presently serving
in the Armed Forces overseas. Mr. Theodore Williams,
brother-in-law of the owner, currently resides on the .property.
-------
1 r
WILLIAMS PRQPERTV
MIEDLE TWP.
CAPE MAY 00.
-------
- 3 - Community Relations Plan
Williams Property 7/84
During 1978-1979, Mr. Williams had given verbal permission to Mr.
Francis Block to store 200-300 55-gallon drums of unknown liquids
and solids on the property. When Mr. Williams was ordered by the
Cape May County Department of Health to remove the drums, he
reportedly attempted to contact Mr. Block to arrange for removal.
After several fruitless endeavors, Mr. Williams took it upon
himself to try to dispose of the barrels at a local landfill;
however, the landfill would not accept full drums. Mr. Williams
returned home and punctured the drums allowing their contents to
spill and drain into the soil. There is also evidence to suggest
that there may have been tank-trailer discharges at the site.
In January of 1980, eleven monitoring wells were Installed and
sampled under the direction of the New Jersey Department of
Environmental Protection (NJDEP). In June, NJDEP supervised
the removal and proper disposal of 1160 cubic yards of contaminated
soil above the ground water table. Removal of the soil and
remaining drums, some of which were full, was financed under the
N.J. Spill Compensation Fund (there is a possibility that some
contaminated soil remains on site). Groundwater sample analyses
Indicated contamination by pesticides, heavy metals, and various
organic and Inorganic compounds. In the past, there has been
evidence of stressed vegetation. *
An expanding groundwater plume with lateral dimensions of about
1000 feet by 300 feet is thought to be flowing northeast of the
site at a rate slightly below one foot per day. NJDEP plans to
install three to four monitoring wells at the site in late August
or early September 1984 In an attempt to track the path of the
plume before It reaches proximate residential wells. Eight potable
wells in the Immediate site vicinity are currently being tested for
priority pollutants on a quarterly schedule by NJDEP. Me. Williams
has been advised not to uaa — hlg^^rell and the Cape 'May County
Department of Health is, ^^preee^?', supplying him with bottled
water. ^
At this time, all responsible parties are /being investigated by
NJDEP and compensation win be sought for any work done. A
Cooperative Agreement was initiated between NJDEP and the United,
States Environmental Protection Agency (USEPA) in May 1984 and has
been approved .by USEPA.
Key Issues
The Holly Beach Aquifer supplies approximately 60 percent of Cape
May County residents with potable water. This aquifer is Important
for irrigation purposes and fire control as well. Extensive
development has been planned for the region and the purity of this
-------
r'T
. •£', - 4 - Community Relations Plan
y, ^ Williams Property 7/84
reserve is paramount to the plan. There is also a potential threat
of chemical migration into the Cohansey Aquifer, a 17-trillion
gallon groundwater source serving most of southern New Jersey.
In April 1984, the Cape May County Board of Freeholders instructed
the County Planning Board and Department of Health to prevent all
development within a one-mile radius of the site. This will remain
in effect until cleanup is completed, or at least until the precise
dimensions of contamination are defined (as indicated In the A
feasibility study to commence in the fourth quarter of 1984).
The region is utilized extensively for recreation, and seasonal
traffic on area roads can be quite heavy. Some of the water filled
gravel pits are used for swimming and fishing, and there had been
tentative plans made for the construction of a recreational
facility. Furthermore, there are several endangered species found
in the surrounding habitats.
3. History of Community Involvement
The contamination of the Williams Property has garnered quite a bit
of attention from the media, local government, and citizenry. The
story has been reported and kept up-to-date, although sometimes
Inaccurately, in all the major newspapers in New Jersey. Further
coverage has come from the three major television stations in
Philadelphia. This media attention may have generated additional
community interest in the problems encountered in a site
cleanup. There are no known organized community or public Interest
groups involved to date, however, a few individual citizens have
expressed concern through letters or phone calls to government
officials and the media?. At one point, a local minister had
planned to initiate a petition calling for the removal of some of
the barrels thought to be taken to a local landfill. .*
The county and municipal governments have played significant roles
In attempting to resolve the problem to their satisfaction. The
*" Cape May County Department of Health and the Planning Board have
been In constant touch with NJDEP requesting current information
and urging an expeditious cleanup of the site. They have suggested
procedures to the State that they felt might facilitate the
process. One internal County Department of Health recommendation
_ was to allow the County to conduct all community relations
"" activities in order that State funds be released for actual
cleanup. Regardless of who administered them, the Department of
Health requested an early initiation of these activities.
-------
- 5 - Community Relations Plan
Williams Property 7/84
On October 6, 1983, the Middle Township Committee adopted a
resolution which charged that NJDEP had "failed to adequately
monitor" potable water in the vicinity of the site and demanded
that the State begin such a program. The resolution went on to
urge NJDEP to take immediate steps towards cleanup.
Former State Senator James Cafiero and United States Congressman
William J. Hughes have both exhibited a keen interest in the
ongoing status of the Williams Property.
-------
t
9
f'
B.
- 6 -
Community Relations Plan
Williams Property 7/84
Objectives of the Community Relations Program;
1. Ensure that local officials and interested citizens are kept abreast
of plans and site developments.
2. Ensure the participation of local officials in all appropriate
community relations activities and establish means of obtaining input
from affected citizens and community .leaders on remedial alternatives
under consideration.
Provide local press with accurate information about important proposed
actions.
4. Provide feedback to participants.
3.
-a.
-------
- 7 -
Community Relations Plan
Williams Property 7/84
C. Community Relations Techniques To Be Used
Technique
1. Telephone Calls
2. Briefings
3. Press Releases
4. Public Meetings
5. Fact Sheets
6. Responsiveness Summary
Objective
— to maintain lines of
communication with
local and other officials
as well as involved
citizens.
~ to inform officials*
residents and other
. Interested parties
about the nature of the
planned remedial action,
and to provide them with
background material on the
technical studies when
requested.
— to provide accurate
Information to local press
and interested citizens
(through the NJDEP Press
Office).
~ to Inform citizens of
planned or ongoing
activities and to discuss
and receive citizen feed-
back on possible courses
of action.
— to be distributed* at
meetings or in response to
local press or citizen
inquiries to ensure public
understanding of basic
issues involved in the
remedial program.
~ to provide a final summary
• of citizen concerns and
problem areas, and the
governmental response to
them.
-------
. >
- 8 -
Community Relations Plan
Williams Property 7/84
D. Proposed Work Plan and Estimated Schedule (Calendar Year)
Time (Initiation of Action)
Remedial Investigation/
Feasibility Study
^M«MM«««MI««M->M««*» ^s*
V
4th quarter of 1984
(Investigation and
report expected to take
months for completion)
Engineering Design
2nd quarter of 1986
Activities
Staff Responsibilities
2 Public Meetings-- *
one at initiation
of study, one at
completion of study
to present alter-
natives
2 Fact Sheets—one
at initiation of
study, one to de-
scribe alternative
remedial actions
3 Press Releases (or
as necessary)—two
to advertise public
meetings, one to an-
nounce engineering
designer
1 Reponse Summary
conducted in cooper-
ation vith contractor
after public discussion
of alternatives and 30
day comment period
1 Public Meeting
1 -Press Release
to advertise
public meeting
1 Fact Sheet
**
***
**
*
***
**
•,-WSTJ
-------
- 9 -
Community Relations Plan
Williams Property 7/84
Proposed Work Plan and Estimated Scheduled Continued
Removal/Treatment/Construction
2 Public Meetings
(one at initiation
of remedial action*
one at completion)
2 Press Releases to
advertise public
meetings
*
2 Fact Sheets
***
**
Post Closure/Summary
of Activities
Travel
1 Response **
Summary
1 Media Appearance,
as necessary
Approximately 6 trips
to site location, with
additional trips scheduled
as necessary to meet
community requirements
**
***
NJDEP/HSMA Community Relations Representative(s)
NJDEP/HSMA Bureau of Site Management Representative(s)
NJDEP/HSMA Bureau of Environmental Evaluation and Risk Assessment
Representative (s) (as necessary)*
NJDEP/HSMA Administrator (as necessary)
NJDEF legal or other staff (as necessary)
USEPA Representative(s) (as necessary)
Project Contractor, (when requested)
NJDEP/HSMA Community Relations Staff
NJDEP/HSMA Community Relations Staff, through NJDEP Public Information
Office
•
Hazardous Site Mitigation Administration
Note: Staff work hours could not be estimated at this time.
-------
- 10 -
Community Relations Plan
Williams Property 7/34
E.
Contacts
Federal Officials
Senator Bill Bradley
Senate Office Building
Washington, D.C. 20510
District Office:
917 North Main Street
Toms River, N.J. 08753
•Senator Frank Lautenberg
Senate Office Building
Washington, D.C. 20510
District Office:
Parkade Building
518 Market Street
Camden. N.J. 08101
Representative William J. Hughes (District 2)
House Office Building
Washington, D.C. 20515
District Office:
2307 New Road
Northfield, N.J. 08225
State Officials (District 1)
—• Senator James R. Hurley
P.O. Box 809
821 Columbia Ave.
Mill vine, N.J. 08332
*~ Assemblyman Joseph W. Chinnlci
P.O. Box 926
c/o Major Coat Co.
Bridgeton Ave.
Brldgeton, N.J. 08302
w- Assemblyman Guy F. Muziani
Professional Plaza
6 Anglesea Dr
North Wildvood, N.J. 08260
County Officials
Anfhrmy T.
-------
- 11 - Community Relations Plan
Williams Property 7/84
Cape May County Department of Health
Crest Haven Complex
Garden State Parkway & Crest Haven Road
Cape May Court House, N.J. 08210
Gerald M. Thornton, Freeholder (609) 465-3181
Louis J. Lamaima, MA, Director ext. 260
Raymond Chadwlck, Environmental Program Adm.
Clay C. Sutton, Principal Planner Environmental
Cape May County Planning Board
13-34 Mechanic Street
Cape May Court House, N.J. 08210
•William E. Sturm, Jr., Freeholder (609) 465-7111
Elwood R. Jarmer, Director ext. 278
William J. Diller, Jr., Chairman
Supervising Principal Planners:
David Rutherford
Edward R. Fillpskl
Members:
William Laskey, Vice-Chairman
Neil Clarke, Secretary
Madelyn Galloway
John MacLeod
Frederick A. Long, Jr.
Anthony T. Catanoso
James S. Kllpatrlck, Jr.
Rose Johnson
Ellwood Shephard, Alternate Member
Cape May County Public Works (609) 465-7111
Neil 0. Clarke, County Engineer ext. J301
14-34 Mechanic Street
Cape May Court House, N.J. 08210
Environmental Council / (609) 399-6232
Jeanne Clunn, Chairman
P.O. Box 315 .
Ocean City, N.J. c?.r-~*
Environmental Council (609) 398-3280
Jeanne Gorman, Secretary
324 Central Ave.
Ocean City, N.J.
•
Members:
Alice McGulnn, Vice-Chairmen
Larry Newbold
Helen Sciarra
Ruth Barf . *
Stephen Patrick
-------
- 12 -
Emergency Management
Louis A. Rodia Jr., Public Information
14-34 Mechanic Street
Cape May Court House, N.J. 08210
Local Officials
Middle Tovnahip
Michael J. Voll. Mayor
George H. Simpkins, Clerk
33 Mechanic Street
* Cape May Court House, N.J. 08210
Township Committee:
James E. Alexis
Charles M. Leusner
Alvin C. Herman, Engineer
7 Mechanic Street
Cape May Court House, N.J. 08210
Bruce M. Gorman, Attorney
Rt. 9 4 Vermont Ave.
Rio Grande, N.J. 08242
Individual Concerned Citizens
James Cafiero
3303 New Jersey Avenue
Wildwood, N.J. 08260
John Alfred Bishop
189 Siegtown Road
Swalntoa
'
larpenter
Court House, N.J. 08210
•
Elizabeth G. Davis
RD il
P.O. Box 191A •
Cape May Court House, N.J. 08210
Dorothy Kane
RD II
P.O. Box 191
Siegtown Road
Cape May Courthouse, N.J. 08210
Mr. ft Mrs. R.L. Lewis _ °
2 New Vernon Ave.
Ocean View, N.J. 08230
Community Relations Plan
Williams Property 7/84
(609) 465-9408
(609) 465-5107
-5108
(609) 465-2559
•(609) 729-3243
(609) 522-0511
unpublished
•
no listing
(609) 465-7524
no listing
unpublished
-------
- 13 - Community Relations Plan
Williams Property 7/84
Adele Thompson unpublished
Slegtown Rd.
Svainton, N.J.
Theodore Williams no listing
P.O. Box 188 "
Slegtovn Road
Swainton, N.J.
Citizens' Assoc. for Protection no listing
of the Environment
•Ruth Fisher
P.O. Box 33
Cape May Court House, N.J. 08210
(See attached list for commercial and residential
properties located within a one-half mile radius
of the site.)
N.J. Department of Environmental Protection
Julian Antebi, Site Manager, HSMA {609) 984-3253
Grace Singer, Community Relations (609) 984-3081
Program Manager, HSMA
Ste»e Julmjro-^Ue Management- Team. BUR (609)292-0668
William Lowry.Ti'tin^n-tfem HSMA (609)984-4843
Rich Ericson, Site Management Team, ORS (609) 292-1143
V^Mt ^.c ".•:. .'VW'-.' '«-viC_ Cr-t ifL'i T«-.-r^wC.t.-'«r- _
U.S. Environmental Protection Agency A\ ?c
Robert McKnlght, Project Manager (212) 264-8679
Lillian Johnson, Community Relations (212) 264-2,515
Coordinator
Press Contacts
Atlantic City Press / (609) 465-5031
6 S. Main St.
• Cape May Court House, N.J. 08210
Robert Ebener, Editor
. Gazette-Leader (609) 522-3423
1212 Atlantic Ave.
North Wildvood, N.J.
Barbara St. Clair, Editor t ..;- . .
Cape May Star & Wave (609) 884-3465
513 Washington Street Mall
Cape May, N.J.
O.L. Flood, Editor •: " • ^
-------
•-%. " Community Relations Plan
•^jsr Williams Property 7/84
Cape May County Herald
28th & Dune Drive (609> 465-5055
Avalon, N.J.
Joe Zelnik, Editor ^, - A-
C* £ ^ C ^^
Lover Tovnship Lantern
UUU Bayshore Road - (609) 465-5055
ViUas, N.J.
Joe Zelnik, Editor
-------