United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/070
September 1988
Superfund
Record of Decision:
Reich Farms, NJ
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50777-101
REPORT DOCUMENTATION »"«T "»•
PAGE
EPA/ROD/R02-88/070
3. Recipient's Accession No.
|]«. Tttt* and Subtitle
SUPERFUND RECORD OF DECISION
ileich Farm, NJ
'irst Remedial Action - Final
S. Report Oat*
09/30/88
Authors)
8. Performing Organization Rapt. No.
* Performing Organization Nam* and Addrasa
10. Preject/Task/Work Unit No.
11. ContracttO or Grant(G) No.
(C)
(G)
Ui Sponsoring Organization Nama and Addraaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Typa of Report & Period Covered
800/000
14.
IS. Supplementary Note*
e Reich Farm site is located in Dover Township, Ocean County, New Jersey. The
three-acre site is bounded by commercial establishments to the west and wooded areas in
all other, directions. The site is approximately one mile northeast of the Toms River,
but no floodplains or wetlands are affected by the site. The site is currently owned by
Mr. and Mrs. Samuel Reich. In August 1971, they rented a portion of their land to Mr.
icholas Fernicola for temporary storage of used 55-gallon drums. That December, the
leichs discovered approximately 4,500 drums containing wastes and 450 empty drums on
hat portion of their property. Most of the drums had Union Carbide Corporation (UCC)
markings on them, with labels reading "tar pitch," "lab waste solvent," "blend of resin
and oil," and "solvent wash of process stream" among others. The site first came to the
attention of the New Jersey Superior Court when the Reichs filed suit against Mr.
Fer-nicola and UCC. UCC undertook drum removal and completed the work in March 1972. In
June 1974, another 51 drums and approximately 1,100 yd^ of contaminated soil and
trenched wastes were removed from the site, but residents near the site had already
complained about unusual taste and odor in their well water. Based on results of an
extensive sampling program, the Dover Township Board of Health ordered 148 private wells
closed and established a zoning ordinance restricting ground water use in the area of
(See Attached Sheet)
Reich Farms, NJ
First Remedial Action - Final
Contaminated Media: gw, soil
Key Contaminants: VOCs (PCE, TCA, TCE)
b. Id*ntlfiar*/Op*n-Endad Term*
COSATI Field/Group
lability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
114
22. Price
Oe*ANSt-Z39.ia)
See /nstructfons on R*v«ne
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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A/ROD/R02-88/070
ich Farms, NJ
First Remedial Action - Final
16. ABSTRACT (continued)
Reich Farm. The volume of contaminated soil remaining at the site is estimated to be
2,010 yd3. The primary contaminants of concern affecting the ground water and soils
are VOCs including 1,1,1-trichloroethane (TCA), TCE, PCS, and semi-volatile organics
compounds (SVOCs).
The selected remedial action for this site includes: additional ground water
sampling to further delineate the leading edge of the contaminant plume and additional
soil sampling to support existing data on contaminants of concern at the site; ground
water pump and treatment using air stripping and carbon adsorption with reinjection of
the treated water back into the aquifer; excavation and storage of surface soils onsite
which do not require remediation; excavation of subsurface soils and onsite treatment by
enhanced volatilization and onsite disposal, or shipment of subsurface soils which
cannot be treated onsite to an offsite RCRA-permitted facility for incineration and
disposal, followed by backfilling excavated areas with clean surface soils. The
estimated present worth cost for this remedial action is $5,832,000, which includes
annual O&M costs of $419,550.
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DECLARATION STATEMENT
RECORD OF DECISION
Reich Farm
SITE NAME AND LOCATION >.!>_.."_: .- ..:
Reich Farm, Dover Township, Ocean County, New Jersey
STATEMENT OF PURPOSE !T_J..T_ -.'.".". ...'.. .L ../. .
This decision document presents the selected remedial action for
the Reich Farm site, developed in accordance with the Comprehen-
sive Environmental Response, Compensation and Liability Act of
1980,-as amended by the Superfund Amendments and Reauthorization
Act of 1986, and-to the extent applicable, the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300.
STATEMENT OF BASIS _." ..... ...
I am basing my decision primarily on the following documents,
which are contained in the administrative record, and which
characterize the nature and extent -of contamination and evaluate
long-term remedial alternatives for the Reich Farm site:
- Final Draft Supplemental Remedial Investigation Report, Reich
.Farm, prepared by Ebasco Services, August 1988;
- Final Draft Feasibility Study Report, Reich Farm, prepared by
Ebasco Services, August 1988;
- Proposed Remedial Action PlanT~Reich~Farm7~August 19 BIT;
- The attached Decision Summary for the Reich Farm site;
- The attached Responsiveness Summary for the site, which
incorporates public comments received; and
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED REMEDY
The remedial alternative presented in this document represents a
final remedial solution for the Reich Farm site. It addresses
subsurface soil contamination at the site and ground water
contamination in the underlying aquifer. The Feasibility Study
Report refers to the selected soil and ground water remedy as
Alternatives S-5 and GW-2, respectively. A surface cleanup
involving the removal of drums and other containers as well as
contaminated soil has already been completed.
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The.specific components of the remedial action are as follows:
.- Additional ground water sampling to further delineate the
leading edge of the contaminant plume and additional soil
..sampling to support existing data on the contaminants of
concern at the site; ---
--.Extraction of contaminated ground water through pumping
-: followed by on-site treatment and reinjection of the treated
.;effluent into the ground. This process will continue until -
federal and state cleanup standards are attained to the
maximum extent practicable; and
- Excavation and treatment of contaminated soil- to meet New
Jersey Soil Action Levels. A portion of the soil, contami-
nated with volatile organic compounds, will be treated by
enhanced volatilization. Any soil which cannot be effect-
ively treated by this technology to meet the cleanup levels
will be taken off-site for incineration and disposal.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Com-
pensation and Liability Act of 1980, as amended, and the National
Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR
Part 300, I have determined that the selected remedy is protective
of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for
this remedial action, and. is cost-effective. Furthermore, this
remedy satisfies the preference for treatment that reduces the
toxicity, mobility or volume as a principle element and utilizes
permanent solutions_and alternate treatment forhnr>tr>g-ioia
maximum extent practicable.
Because this remedy will not result in hazardous substances
remaining on-site above health protective levels, the five-year
review requirement will not apply to this action.
Date ' Wi 11 i am^'. *Mus£#isJci , P. E.
Acting Regional Administrator
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DECISION SUMMARY
Reich Farm Site
Dover Township, New Jersey
SITE DESCRIPTION
The Reich Farm site is an open, relatively flat sandy area covering
approximately three acres in the Pleasant Plains section of Dover
Township, Ocean County, New Jersey (Figure 1). The site is
surrounded by commercial establishments to the west and wooded
areas in all other directions. Two buildings, located adjacent
to the west side of the site, are occupied by several small
businesses. The illegal drum dumping activities, which resulted
in contamination of the site by hazardous substances, occurred on
the portion of the site that is shown in Figure 2.
Within a half mile to the east and south of the site, land use
is approximately sixty percent wooded and forty percent commercial.
To the north, west and southwest, residential development covers
half of the area; wooded areas and commercial operations comprise
the remaining land use. The site is located approximately one
mile northeast of the Toms River.
The KirJcwood-Cohansey aquifer system underlies the Reich Farm site.
The upper portion of the system is generally referred to.as the
Cohansey aquifer and the lower portion as the KirJcwood aquifer.
The average depth to ground water beneath the site is approximately
thirty feet. The direction of ground water flow in this aquifer
system is generally to the"south-southwest.
The principle source of water for Dover Township is the Cohansey
aquifer. As a result of a 1974 Dover Township Health Department
zoning ordinance, there are no private wells within approximately
4500 feet of the Reich Farm site which tap into this aquifer.
The area encompassed by this ordinance is represented as Zones I
and II in Figure 3. The Toms River Water Company's (TRWC) ParJcway
Wellfield is located approximately one mile downgradient of the
site. TRWC is a municipal water supplier in Dover Township. In
June 1988, the wellfield pumped an average of 3.5 million gallons
of ground water per day. Figure 4 shows the location of the
ParJcway Wellfield in relation to the site. Also shown in Figure
4 is TRWC's pumping well number 20, which is located over a mile
southwest of the site.
SITE HISTORY
Origin of Problem
The Reich Farm site is currently owned by Mr. and Mrs. Samuel
Reich. The legal description of the property is Block 410,
Lot 22, on the Dover Township tax map. According to the Reichs,
in August of 1971, they rented a portion of their land to
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Mr. Nicholas Fernicola for temporary storage of used 55-gallon
drums. That December, the Reichs discovered approximately 4,500
drums containing wastes and 450 empty drums on the portion of
their land that was rented to Mr. Fernicola. The labels on the
drums included "tar pitch", "lab waste solvent", "blend of resin
and oil", and "solvent wash of process stream". Most of the drums
had Union Carbide Corporation (UCC) markings on them. Trenches
into which wastes may have been dumped were also found. These
disposal activities resulted in contamination of the soils pn-site
and ultimately of the ground water.
Initial Enforcement Actions and Subsequent Remedial Measures
Mr. and Mrs. Reich, as well as the Township of Dover, filed
complaints in New Jersey Superior Court against Mr. Fernicola and
the Union Carbide Corporation which resulted in the Court ordering
dumping to cease and the removal of all waste and drums. According
to a TRW report entitled "Analysis of a Land Disposal Damage
Incident Involving Hazardous Waste Materials Dover Township,
New Jersey", and dated May 1976, drum removal was undertaken by
Union Carbide and completed in March 1972. In June 1974, another
51 drums and approximately 1100 cubic yards of contaminated soil
and trenched wastes were removed from the site. The soil was
excavated on the basis of visual inspection and odor.
Early in 1974, some residents.near the site observed an unusual
taste and odor in their well water. Analyses performed on this
water showed the presence of petrochemical contaminants, including
phenol and toluene. A more extensive sampling program was then
undertaken. Based on the results of this sampling, the Dover
Township Board of Health (DTBH) ordered 148 private wells closed
by the end of August 1974, and established a zoning ordinance
restricting ground water use in the area of Reich Farm.
The New Jersey Department of Environmental Protection (NJDEP)
filed suit against UCC charging the company with polluting the
public water supply in the Pleasant Plains section of Dover
Township by improperly disposing of liquid chemical wastes. The
suit also named Nicholas Fernicola as a defendant. On April 21,
1977, UCC signed a Consent Order with NJDEP for the State to
perform additional investigations at the site. In June 1977,
NJDEP dropped charges against Nicholas Fernicola in return for
Mr. Fernicola's agreement to cease hauling and disposing of
chemical wastes.
Reich Farm was one of 418 sites placed on the EPA Proposed Nation-
al Priorities" List (NPL) published in December 1982. The final
approval for inclusion on the NPL was given in September 1983.
Remedial Actions by EPA
EPA performs remedial actions at toxic waste sites in accordance
with the Comprehensive Environmental Response, Compensation, and
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Liability Act (CERCLA) of 1980, which was amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986. In most
instances, these actions are undertaken in three major phases.
First, a remedial investigation and feasibility study (RI/FS) is
conducted to determine the nature and extent of the contamination
present at the site, and to develop and evaluate a range of
remedial action alternatives to deal with that contamination.
After the RI/FS is completed, a Record of Decision (ROD) is
prepared to document the remedy selected. Subsequently, the
remedial design (RD) phase begins, followed by the remedial
action (RA), during which the design is implemented.
In addition to these scheduled activities, a removal action may
be taken at any time to address acute hazards posed by a site.
Remedial Investigation
In accordance with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), EPA conducted a RI/FS at the
Reich Farm site. Sampling of ground water and surface and sub-
surface soils at the site, in addition to potable well sampling
off-site, was performed in May and June of 1986 as part of a
preliminary remedial investigation. The formal field work for
the supplemental remedial investigation, which was undertaken to
provide additional data on site conditions, began in July 1987
and was completed in April 1988. Major contaminants in the soils
and ground water are listed in Table 1, which includes data from
each round of sampling conducted as part of a remedial invest-
igation.
During the preliminary RI, the shallow soils on-site were
investigated by the collection and analysis of 80 soil samples
from 25 boreholes. Common sampling depths were 5, 10 and 15
feet. The supplemental RI soil sampling program, conducted in
1987, included 27 soil borings and 8 well borings. Analytical
samples were generally taken from 15-35 feet below ground to
supplement the previous sampling. Although there were some
volatile and semi-volatile organics detected in the soils above
a 10 foot depth, their concentrations did not exceed the existing
cleanup levels established by NJDEP of 1 part per million (ppm)
of total volatile organics and 10 ppm of total semi-volatile
organics. These levels are known as the New Jersey Soil Action
Levels and are shown for comparison in Table 1 (parts A and B).
The concentrations of total volatile organics and total semi-
volatile organics in certain areas (referred to as "hot spots")
of the soil below a 10 foot depth did exceed their respective
criteria. The level of nickel in one soil sample exceeded the
action level of 100 ppm. No other inorganics were detected in
the soil at concentrations above their criterion.
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Ten monitoring veils were installed on-site and sampled as part
of the preliminary RI. These wells were screened from 25 to 125
feet below the surface. Twelve additional on-site monitoring
wells were installed, and all monitoring wells were sampled,
during the supplemental RI. Nine residential wells in the area
and ten Toms River Water Company wells were sampled in 1986 as
part of the preliminary RI. One of the residential wells and
three of the municipal wells were resampled during the supplemental
RI in 1987. The analytical results for all of these ground water
sampling events are shown in Table 1 (parts C and O) along with
the applicable or relevant and appropriate requirements (ARARs)
established by EPA or NJDEP.
The State ARARs for the various inorganic chemicals listed in
Table 1 (parts C and D) are Known as the State of New Jersey
Maximum Contaminant Levels (MCLs) for "A-280" contaminants.
NicJcel, lead and cadmium were the only inorganics which exceeded
these levels in the ground water sampling.
During the preliminary RI, the ten monitoring wells in place at
that time were tested for metals. NicJcel was detected in only
one of these wells. The level detected in this monitoring well,
which was located upgradient of the site, was above the New
Jersey MCL for nickel (13.4 parts per billion (ppb)). Five of
the original ten monitoring wells, including one upgradient
well, were resampled for metals in November 1987 as part of the
supplemental RI. Nickel was detected at concentrations exceeding
the New Jersey MCL in all five of these wells. Two off-site wells
which were sampled for metals in 1986 also showed nickel above
the New Jersey MCL.
Lead was detected at a level of_56-_ppb in-TRWC
monitoring well and at 58 ppb in TRWC's well number 20. These
samples were taken in May 1986 as part of the preliminary RI.
The state and federal cleanup levels are both currently set at
50 ppb for lead. Lead was not detected above this level in any
monitoring wells on-site, or in any other off-site wells sampled.
Cadmium was detected above its New Jersey MCL in one upgradient
monitoring well, and in TRWC's Dugan Lane monitoring well, during
sampling in 1986. Cadmium was also detected above the EPA Drinking
Water One Day Health Advisory in a residential well sampled in
June 1986. This well was not used for drinking water at the time
and is now out of use. Cadmium was not detected in any of the
other 1986 samples, nor was it detected in 1987. Five of the
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monitoring wells sampled in 1987 shoved concentrations of chromium
above the New Jersey Pollution Discharge Elimination System
(NJPOES) criteria of 50 ppb. One of these wells was located
upgradient of the site. This was the only well in which chromium
was detected during the 1986 sampling.
The labels on the drums found on the site, and the waste descrip-
tions provided by UCC, did not indicate that metals were disposed
at Reich Farm. Also, the randomness of the nickel, lead, cadmium
and chromium detections, and the fact that nickel, cadmium and
chromium were detected in upgradient wells and lead was not
detected in any on-site wells, seem to indicate that Reich Farm
is not the source of these metals in the ground water.
Iron and manganese were detected above their respective Federal
Safe Drinking Water Act secondary standards in a number of ground
water samples. These standards relate to the aesthetic quality
of drinking water (i.e., odor and taste) and do not indicate a
potential health risk.
The compounds, 1,2-dichloroethane and carbon tetrachloride, were
detected at concentrations slightly above their respective New
Jersey MCLs in only a small number of samples. 1,2-dichloroethane
was detected in one out of 45 monitoring well samples and was not
detected in any off-site wells; carbon tetrachloride was detected
in one monitoring well sample and one residential well sample.
This residential well did not show any carbon tetrachloride when
it was resampled by the Ocean County Board of Health in 1988. The
presence of these compounds in the ground water is not considered
significant because of the'"limited number of detections and the
low concentrations which were measured.
Methylene chloride (MO was detected in four out of 30 monitoring
well samples. All of these detections were at concentrations
above the New Jersey MCL for this compound. Due to the small
number of detections, and the fact that MC is a typical field and
laboratory contaminant, the MC found in the ground water was not
thought to be site related. Additional sampling will be necessary
to determine the true source of this compound. After the results
of this sampling are known, any ground water treatment to be
undertaken at the site can be adjusted, if necessary.
The volatile organic compounds, 1,1,1-trichloroethane (TCA),
trichloroethene (TCE) and tetrachloroethene (PCE), exceeded their
respective New Jersey MCLs in a number of wells sampled in 1986
and 1987. These wells were all screened from 30-55 feet below
the surface in the upper portion of the Kirkwood-Cohansey aquifer
system. Two of TRWC's wells which are screened in this portion
of the aquifer system showed levels of TCE slightly above the New
Jersey MCL when sampled in May and June of 1986. One of these
wells was resampled in November 1987 and showed the same level of
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TCE as in the previous sample. TRHC's Ougan Lane monitoring well,
which lies between the Reich Farm site and the Parkway Wellfield,
did not show any TCE contamination when sampled in 1986 or 1987.
Contaminant Pathways and Associated Health Risks
A public health evaluation (PHE) was performed at the Reich Farm
site to determine the impact of the site on public health and
the environment under various exposure scenarios and different
contaminant pathways. This evaluation is presented in Section 6
of the Supplemental Remedial Investigation report. The PHE iden-
tified 13 indicator chemicals in accordance'with the Superfund
Public Health Evaluation Manual and documented the existence of
two contaminated media — soil and ground water. These chemicals
were all detected at levels higher than background concentrations.
They are as follows: acetone, bis(2-ethylhexyl)phthalate (BEHP),
chlorobenzene, di-n-butyl phthalate, 1,1-dichloroethane, 1,2-
dichloroethene, ethylbenzene, styrene, PCE, toluene, TCA, TCE,
and xylene. Although only two contaminated media were identified,
the potential exists for migration of the contaminants into other
exposure media, such as air and surface water, which were both
included in the RI.
The PHE involves four steps. The first step is to identify
indicator chemicals to address the potential public health and
environmental concerns associated with the site. The next step.
is to use available data on the toxicity of each chemical to
determine whether the contaminants present at the site may be
associated with adverse health and/or environmental effects. The
third step identifies likeiy exposure scenarios and defines the
individuals who may be at risk via these exposure scenarios, as
well as the mosjt^likely indicator compound concentrations associated
witn these" scenarios. JThe PHE at Reich Farm used the maximum
concentration of each indicator chemical detected in the soil and
ground water. The final step in the process is the calculation
of potential risks associated with exposure to indicator chemicals.
In the PHE, individual contaminants were separated into two
categories of chemical toxicity depending on whether they cause
carcinogenic or non-carcinogenic effects. In the case of chemicals
exhibiting carcinogenic effects, exposures and associated risks
are expressed in an exponential nomenclature; 1 X 10-4 (one in
ten thousand), 1 X 10-7 (one in ten million), etc. EPA has used
the range of 1 X 10-4 to 1 X 10-7 in evaluating risk. The level
of 1 X 10-6, one in a million, has often been used by regulatory
agencies as a benchmark. For chemicals exhibiting non-carcinogenic
effects, exposures and associated risks are expressed as a ratio.
This ratio, called a Hazard Index, is estimated by dividing the
amount of a chemical that an individual might.be exposed to by
the amount of the chemical that will not cause any adverse health
effects. A hazard index that is less than 1.0 indicates that
no adverse health impacts would be expected.
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A summary of the potential risks posed by each pathway evaluated
in the PHE is given in Table 2.
The potential for significant exposure through dermal contact
with and incidental ingestion of site soils by trespassers is
considered low due to the activities of the construction company
which presently occupies a portion of the site. In addition,
this direct pathway represents a small potential health hazard
since the RI findings indicate that the surface soils are not
significantly contaminated because of the past excavation activ-
ities at the site. As was previously noted, the levels of contam-
inants found in the surface soils did not exceed the existing soil
action levels established by NJDEP. The PHE showed that none of
the indicator compounds would pose a risk via this exposure path-
way.
Three migration pathways may exist for the transport of contam-
inants from the soils to the air: volatilization from the surface
soils, volatilization due to on-site trenching activities, and
resuspension of the soils through wind erosion or mechanical
disturbances. All of these pathways were evaluated in the PHE.
It was found that they do not represent a risk to human health
due to the low levels of volatile organics in the surface soils.
Soil contaminants may also migrate into surface water by overland
flow. Surface runoff at the Reich Farm site is an unlikely
transport route for three reasons. First, the nearest stream or
runoff channel is approximately 0.75 mile from the site. Second,
the site is fairly level with only a minimal surface gradient.
Third, the soil is predominantly sandy and is thus highly permeable
following precipitation. During both the preliminary and
supplemental RIs, there was no evidence of soils transported via
surface runoff in the wooded areas adjacent to the property.
For these reasons, the risk from exposure to contaminated surface
waters was not evaluated in the PHE.
The ground water underlying the Reich Farm site is not currently
used as a source of drinking water; therefore, at this time, it
poses no risk to human health. The risk posed by the potential
future ingestion of the ground water on-site was evaluated in the
PHE and will be presented later in this discussion. In regard to
the ground water in the vicinity of the site which is used as a
potable water source, the analyses performed on residential wells
in the area gave no evidence that Reich Farm is currently impacting
private drinking wells; in addition, samples of on-site wells
screened in the lower portion of the Kirkwood-Cohansey aquifer
system showed no signs of contamination. Therefore, it appears
that nearby residents using this portion of the aquifer system
are not currently being affected by the Reich Farm site.
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Ground water samples from the municipal water supply in the area
(TRWC), which were collected during the RIs, indicated low levels
of TCE, slightly above the New Jersey MCL of 1 part per billion,
in a number of the wells in the Parkway Wellfield. TRWC has also
detected low. levels of TCE during its sampling of the Parkway
Wellfield pumping wells. An air stripper has been installed on
the well showing the highest levels of TCE (14 ppb is the highest
level detected thus far) to treat the ground water to below the
New Jersey MCL. This stripper is capable of treating compounds
other than TCE and can also handle the water from more than one
production well. Consequently, at present, there is no health
risk associated with drinking water from the Parkway Wellfield.
There is not enough evidence available to either link Reich Farm
with the contamination at TRWC's Parkway Wellfield, or to rule
out Reich Farm as the source. Preliminary modeling efforts
conducted during the supplemental remedial investigation have
indicated that Reich Farm is in the zone of influence of the
Parkway Wellfield. This means that the ground water leaving
Reich Farm will likely be collected by the wellfield at some
point in time. Yet, there is no definite pattern of contamina-
tion which links Reich Farm with the Parkway Wellfield. Further
work will be required to delineate the leading edge of the ground
water contaminant plume originating from the Reich Farm site.
These efforts will include the sampling of any wells between
Reich Farm and the Parkway Wellfield which were not sealed in
1974, and, if necessary, the installation and sampling of addi-
tional monitoring wells in this area.
Another' exposure scenario which was evaluated in the PHE is the
potential future ingestion of the ground water on-site. The PHE
found TCE, PCE, BEHP, and acetone to be compounds of concern for
this scenario. BEHP and acetone were determined to pose a signi-
ficant risk because both were found at extremely high concentra-
tions in separate ground water samples. This had a significant
effect on the risk calculation because the calculation was based
on the maximum concentration at which each indicator compound was
detected.
The maximum acetone concentration of 74,000 ppb must be questioned
due to the infrequency of acetone detections in the ground water
sampling (7 detections in 26 samples) and the difference between
this value and 690 ppb, the next highest concentration detected.
Based on the results of the PHE, ingestion of 690 ppb of acetone
in the ground water would not pose a significant health risk.
At the present time, there are no ARARs governing the presence of
acetone in ground water. The health protective level calculated
in the PHE for acetone was 3.5 ppm.
The maximum concentration of BEHP detected in the ground water
was 2200 ppb, which is significantly higher than the next highest
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detection of 95 ppb and its solubility at 20 degrees Centigrade
(1300 ppb). Since a compound's solubility represents the highest
concentration that it is likely to attain in the ground water,
the maximum BEHP detection should be considered an anomaly. The
Clean Water Act water quality criteria for human health which has
been adjusted for drinking water, is 21 ppm for BEHP. This is
considerably higher than the health protective level determined
in the PHE (25 ppb). The large difference in these two values
is a result of new information on the health risk posed by the
ingestion of BEHP. This information was used in the PHE, but was
not available at the time the water quality criteria was developed.
Acetone and BEHP are typical field and laboratory contaminants
which may account for the high concentrations detected. Additional
sampling will be required to determine if acetone and BEHP are
truly present in the ground water at concentrations above health
protective levels. If the sampling indicates that this is the
case, any ground water treatment undertaken at the site will need
to address the removal of these compounds.
Another significant migration route at Reich Farm is contaminant
transport from the subsurface soils to the ground water. The
sandy soils on-site will allow extensive percolation of rain
water and surface discharge water through the contaminated zone.
The maximum concentration that a contaminant, which is currently
present in the soil, can eventually attain in the ground water,
was calculated in Section 5 of the supplemental RI report for the
volatile organics — ethylbenzene, chlorobenzene, toluene, styrene
and xylene. These values were then used in the PHE to determine
the individual risks that -these contaminants would pose via* the
ground water exposure scenarios. It was found that ethylbenzene
and chlorobenzene would pose a significant health risk if they
attain their maximum concentrations in the ground water and if
this water was then used for drinking purposes.
This type of analysis was not done for any semi-volatile organic
because the semi-volatile showing the highest levels in the soil
(BEHP) is also currently present in the ground water. It was
decided that the risk posed by the BEHP in the ground water would
be evaluated and then used to indicate the potential risk posed
by this compound and, in turn, the other semi-volatiles in the
soil. Although the highest level of BEHP found in the ground water
is considered an anomaly, the number of detections (18 detections
in 44 samples) seems to indicate that BEHP has indeed reached the
ground water at some level. If BEHP continues to migrate from
the soil, it is likely that it will eventually pose a health risk
in the ground water based on the low health protective level
calculated in the PHE for the ingestion of BEHP in ground water
(25 ppb).
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The migration of contaminants from the ground water into the air
is not considered likely based on the RI findings, although a
possible inhalation pathway could exist in a situation where
contaminated water is being used in a household shower. This
usage could cause some organic contaminants to volatilize, thus
allowing them to be inhaled. This pathway was assessed in the
PHE and was not found to cause a significant risk.
Although no environmental assessment was performed for the Reich
Farm site, it does not appear that the site poses a significant
risk to the local flora or fauna. A large portion of the ground
water contamination at Reich Farm consisted of low-molecular
weight volatile organic compounds which do not represent a toxic
potential and/or bioconcentration potential for stream biota. In
fact, if ground water contaminated with volatiles entered the
intermittent stream which is located less than a mile from the
site, the volatiles would volatilize rapidly into the air before
impacting the biota. The wooded areas surrounding Reich Farm
provide ample cover and food for terrestrial fauna. The PHE did
not find any of the exposure pathways to the soils on-site to
pose a significant risk. In addition, activites associated with
the companies on-site are probably sufficient to keep most terres-
trial fauna in the wooded areas.
ENFORCEMENT ACTIVITIES
»
Three potentially responsible parties (PRPs) were identified'for
the Reich Farm site. All of the PRPs were notified in writing on
October 3, 1983 and given the opportunity to perform the RI/FS
under EPA supervision. However, none of them elected to undertake
these activities. After the RI/FS was completed, a 30-day public
comment period was provided, ending -on Septembe^-19,—-19&B-:—Upon
request, this deadline was extended to September 22, 1988 for two
of the identified PRPs. It is anticipated that Special Notice
letters will be sent out to the previously identified PRPs updating
the status of the site and providing them with the opportunity to
perform the remedial design and remedial action phases of the
project.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Reich Farm site was finalized
in July 1983. 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.
A public meeting was held on January 29, 1986 to discuss the work
plan for the preliminary RI and to inform the public about the
Superfund program and the history and status of the site. EPA
finalized the work plan for the supplemental RI/FS in September
1987 and placed this document in the three information repositories
established for the site. Upon completion of the RI/FS reports,
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they were sent to the repositories to initiate the public comment
period, which extended from August 17, 1988 to September 19,
1988. A public meeting was held on August 30, 1988 to present
the results of the RI/FS and the preferred remedial alternative
for the site developed by EPA. All comments which were received
by EPA before the end of the public comment period, including
those which were submitted verbally at the public meeting, are
addressed in the Responsiveness Summary which is attached, as
Appendix 1, to this document.
REMEDIAL OBJECTIVES
The remedial alternatives presented in this document are based on
the findings of the remedial investigations at the site and focus
on contamination of the ground water by 1,1,1-trichloroethane (TCA),
trichloroethene (TCE) and tetrachloroethene (PCE), and of the soil
by volatile and semi-volatile organic contaminants. Alternatives
addressing cleanup of the ground water will be presented separately
from those dealing with soil remediation.
In general, ARARs are promulgated and legally enforceable to
address a specific contaminant (such as TCE), specific location
(such as a wetland), or specific action (such as air stripping).
Contaminant specific ARARs can be applied to the RI results
before any remedial alternatives are developed. The federal and
state ARARs which have been established for ground water are
presented in Table 1 (parts C and-D). If available technologies
exist that can meet or exceed the most stringent ARARs, these
standards are used to develop the cleanup objectives (criteria)
for the site remedy.
The MCLs established by the State of New Jersey^_whlch—are -more —=—
stringent than the federal standards for TCA, TCE and PCE are as
follows: 26 parts per billion (ppb) for TCA, 1 ppb for TCE, and
1 ppb for PCE. These compounds were all detected above these
criteria in a number of ground water samples. Therefore, removal
of these compounds from the ground water is considered an objective
of the cleanup. The New Jersey MCL for MC is 2 ppb. Although MC
was detected above this level in a small number of ground water
samples, these detections are thought to be a result of field or
laboratory contamination. Consequently, removal of MC from the
ground water is not considered a remedial objective. Additional
sampling must be performed to determine the source of the MC
which was detected. If this sampling indicates that MC is indeed
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a ground water contaminant at Reich Farm, any ground water
remediation undertaken at the site will address reduction of the
concentration of MC in the ground water to levels below the
New Jersey MCL.
In addition to attaining the most stringent ARARs, the reduction
of the concentrations of all contaminants to health protective
levels is another objective of the site remedy. The PHE conducted
at the Reich Farm site showed acetone and BEHP to be contaminants
of concern in the ground water. The health protective levels
which were calculated for these contaminants are 25 ppb for BEHP
and 3.5 ppm for acetone. One acetone sample and two BEHP samples
exceeded these levels. Due to the questionable nature of the BEHP
and acetone detections in the ground water, cleanup of these
compounds is not presently considered a remedial objective but
additional sampling is necessary to determine the true magnitude
of BEHP and acetone contamination in the ground water. This
additional sampling should be conducted at the intiation of the
design of the site remedy. If this sampling indicates that the
concentrations of BEHP and acetone exceed their respective health
protective levels, clean up to these levels will then be considered
a remedial objective of the site remedy.
At this time, no ARARs exist for remediation of soil contaminated
with organics. However, NJDEP has developed soil action levels
of 1 ppm of total volatile organics and 10 ppm of total semi-vola-
tile organics. These levels will be used as cleanup objectives
for the soil remediation aspect of the site remedy. The PHE
determined that the only health risk which may result from the
contaminated soils on-site involves the migration of contaminants
into the ground water. It is believed that cleanup to the NJDE?
-act-ion -ievels-^wi-1-1 -help ensure~that this migration is prevented.
Table 3 summarizes the influencing factors in the selection of
remedial objectives for cleanup of the Reich Farm site.
REMEDIAL ALTERNATIVES
This section describes the remedial alternatives which were devel-
oped, using suitable technologies, to meet the objectives of the
National Oil and Hazardous Substances Contingency Plan and the
Superfund Amendments and Reauthorization Act. These alternatives
were developed by screening a wide range of technologies for
their applicability to site-specific conditions and evaluating
them for effectiveness, implementability, and cost.
A comprehensive list of candidate remedial technologies was
compiled to characterize each technology and determine its
applicability to the site. The original list'for ground water
remediation is included as Table 4. The soil remedial technologies
are listed in Table 5. Each table also provides a brief rationale
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as to why a particular technology was excluded from further
consideration. The technologies that were retained after the
preliminary screening process were assembled in various combina-
tions to form four ground water alternatives and six soil altern-
atives.
The components of each of the ground water and soil alternatives
developed for the Reich Farm site are described below and the
present worth cost estimates for these alternatives are listed in
Table 6. Alternatives addressing cleanup of the ground water will
be presented separately from those addressing soil remediation to
maintain consistency with the Feasibility Study report and the
Proposed Remedial Action Plan. Ground water alternatives are
prefixed with GW and soil alternatives with S.
GROUND WATER ALTERNATIVES
ALTERNATIVE GW-1: NO REMEDIAL ACTION
This alternative would not. directly address or reduce site
contamination and its associated risks. Under current site
conditions, contaminant movement and dispersion should continue
to follow the path of natural ground water flow, which may
significantly impact water quality south-southwest of the site.
Therefore, a comprehensive ground water sampling program would be
implemented to track the movement of the contaminant plume. The
monitoring wells on-site would be sampled every six months and
analyzed for priority pollutants until the ground water plume
is attenuated to health based levels.
ALTERNATIVE GW-2: PUMP/TREAT USING AIR STRIPPING AND CARBON
ADSORPTION/REINJECT TREATED GROUND WATER
Under Alternative GW-2, extraction wells would be installed to
withdraw contaminated ground water for treatment. The placement
of these extraction wells would be determined after additional
ground water sampling. This sampling would be conducted as part
of the remedial design and would serve to delineate the full
downgradient extent of the contaminant plume originating from the
Reich Farm site. Any existing wells located downgradient of the
site would be sampled; if additional information is necessary,
new monitoring wells would be installed in this area. The
extraction wells would then be placed so that they would most
effectively and efficiently capture the plume. Based on the known
extent of the contaminant plume, the ground water would need to
be extracted at a rate of approximately 60 gallons per minute in
order to capture the entire plume.
The extracted ground water would be treated via air stripping
followed by carbon adsorption. Air stripping involves injecting
heated air into contaminated water and extracting the off-gases,
which contain the volatile organics that were removed from the
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ground water, by pumping. In this treatment scheme, the carbon
adsorber which follows the air stripper is used as a "polishing
unit" to remove any trace volatile organics, and any semi-volatile
organics which remain in the ground water. Treatability studies
performed during the remedial investigation have shown this treat-
ment method to be capable of removing the contaminants of concern
from the ground water. The emissions from the air stripper would
be monitored and, if necessary, the off-gases would be treated by
a vapor phase carbon filter before they are released to the
atmosphere to ensure that all air emission standards are attained.
The treated ground water would be discharged to injection wells
upgradient of the site. In order to evaluate the performance of
this remedial action, sampling and testing of the ground water
before and after treatment would be required. This type of
performance monitoring would also be necessary for all of the
ground water treatment alternatives described below.
ALTERNATIVE GW-3: PUMP/TREAT USING CARBON ADSORPTION/REINJECT
TREATED GROUND WATER
This alternative uses the same pumping system as Alternative GW-2.
The ground water would be treated via two granular activated
carbon adsorbers placed in series. In this type of treatment, the
contaminated ground water is passed through a bed of carbon. The
contaminants leave the ground water and are adsorbed onto the
surface of the carbon particles. When the carbon particles become
saturated with the contaminants, they must be replaced. A pilot
test would be conducted to determine the frequency of change of
the activated carbon. The spent carbon would be collected by
the equipment supplier and shipped for off-site disposal or for
treatment and reuse. The efficiency of each adsorber to remove
the contaminants from the ground water is a function of the size
of the carbon bed. The reinjection scheme for this alternative
would also be the same as described for Alternative GW-2.
ALTERNATIVE GW-4: PUMP/TREAT USING H202-UV OXIDATION/REINJECT
TREATED GROUND WATER
This alternative is similar to Alternative GW-2 except that the
contaminated ground water would be treated by chemical oxidation
instead of air stripping. This chemical oxidation employs a
combination of hydrogen peroxide (H202) and ultraviolet (UV)
light to chemically oxidize the volatile organic contaminants in
the ground water. The oxidation process converts the volatile
organics to carbon dioxide, water, and non-hazardous salts. The
contaminant removal efficiency of the unit is a function of the
length of time that the ground water is retained in the oxidation
chamber. The carbon adsorber would serve the same function as in
Alternative GW-2. The pumping and reinjection scheme would be
the same as described in Alternative GW-2.
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SOIL ALTERNATIVES
The following soil alternatives, with the exception of no action,
involve the remediation of "hot spots" in the subsurface soils.
An area was designated as a "hot spot" if the concentration of
contaminants in the soil exceeded the New Jersey soil action
levels. For those alternatives which involve treatment, the
amount of soil requiring remediation is estimated. Testing will
be performed during the remedial action to ensure that all soils
with contaminant concentrations above the action levels are
treated.
ALTERNATIVE S-l: NO REMEDIAL ACTION
The no action soil cleanup alternative consists of a long-term
monitoring and control program. Warning signs will be posted at
the site to alert the community of the presence subsurface soil
contamination. A long-term monitoring program would be implement-
ed to assess the extent of contaminant migration into the ground
water and to detect upward migration of volatile organic contam-
inants in the soil. The condition of the warning signs would
also be checked. The monitoring program would include, annual
inspection of the facilities, and sampling and testing of the
ground water and soil every six months. The ground water sampling
can be performed using existing monitoring wells. The soil
sampling would be conducted in the areas containing high levels
of contamination. This alternative would not prevent the migra-
tion of contaminants from the soil to the ground water.
ALTERNATIVE S-2: CAPPING OF HOT SPOTS/INSTALLATION OF GROUT
CURTAINS
~In thisraTternative, a multi-layer cap would be placed over each
hot spot. A grout curtain would then be injected around the
perimeter of each area. The grout curtain would extend down to
the water table located 30 feet below the surface. The cap would
consist of a synthetic liner, a sand layer, a layer of crushed
stone, a layer of coarse aggregate bituminous concrete, and a
layer of fine aggregate bituminous concrete. The grout curtain
is made of cement mixed with bentonite, soil and water. The cap
and grout curtain would serve to isolate each hot spot and thus
prevent percolating water from aiding the migration of contaminants
into the ground water. A long-term monitoring program would be
implemented as part of this alternative and would consist of
inspecting the grout curtain and cap, and sampling and testing
of the ground water (using the existing monitoring wells) every
six months. This sampling would be performed in order to detect
any contaminant release from the capped areas.
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ALTERNATIVE S-3: SOIL EXCAVATION/ON-SITE INCINERATION/ON-SITE
PLACEMENT OF TREATED SOIL
This alternative would involve excavation of approximately 2620
cubic yards of soil, 2010 cubic yards of which are subsurface
soils requiring treatment. The remaining 610 cubic yards are
surface soils which are not significantly contaminated. These
soils would be stored and eventually used to backfill the excavated
areas. The contaminated soil would be treated in a mobile incin-
erator brought to the site. All contaminants of concern in the
soil would be destroyed by the incineration process. The incin-
erator system would contain an air pollution control device which
would collect any off-gases produced and treat them for particulate
and acid gas removal before release to the atmosphere. The treated
soil would be tested to ensure that the remedial objectives have
been achieved and would then be used as backfill in the excavated
areas. The vendor providing the equipment would be responsible
for disposal of particulates and acid gas collected in the air
pollution system, and any waste water which was used.
ALTERNATIVE S-4: SOIL EXGAVATION/OFF-SITE TREATMENT AND DISPOSAL'
The extent of soil excavation for this alternative would be the
same as described in Alternative S-3. The 2010 cubic yards of
contaminated soil would be transported off-site to a RCRA per-
mitted .facility for treatment and disposal. Two facilities in
New Jersey have tentatively indicated that they are capable of
handling this material. Both facilities are equipped to incinerate
the soil. The facilities are approximately fifty miles from the
site. It is estimated that one hundred 20-ton trucks would be
required to transport the total volume of soil. Clean fill, and
the surface soils which were excavated, would be used as backfill.
ALTERNATIVE S-5: SOIL EXCAVATION/ENHANCED VOLATILIZATION/ON-SITE
PLACEMENT OF TREATED SOIL/OFF-SITE TREATMENT
AND DISPOSAL
In this alternative, approximately 1480 cubic yards of soil would
be excavated intially, 1120 cubic yards of which are subsurface
soils contaminated with volatile organ!cs. The remaining 360
cubic yards are surface soils which would be stored temporarily
and later used as backfill in the excavated areas. The volatile
organic contaminated soil would be treated on-site via enhanced
volatilization. In this process, hot air is injected into a
thermal processor (rotary dryer) containing the soil to be treated.
The volatile organics in the soil volatilize into the air stream
and combust in an afterburner, where they are destroyed. The
off-gases from the afterburner are then treated in a scrubber for
particulate and acid gas removal. The afterburner can be replaced
with a carbon adsorber to remove the volatiles from the air stream.
The carbon would then be disposed of, or regenerated, at an off-
site facility. In this case, no scrubber would be needed. After
testing to ensure that the level of total volatile organics in the
soil is below l ppm, the treated soil would be used to backfill
the excavated area.
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The second stage of this alternative involves excavating about
1140 cubic yards of soil, 890 cubic yards of which are contamina-
ted with semi-volatile organics. Some semi-volatile organics may
not be adequately removed from soil by enhanced volatilization;
therefore, this soil would be taJcen off-site for treatment (via
incineration) and disposal. The area of this excavation would be
backfilled with clean fill and the 250 cubic yards of surface
soil which were excavated but did not require treatment.
The volume of soil requiring off-site treatment (890 cubic yards)
is a conservatively high estimate. This value was used to yield
a conservative cost estimate for this alternative because off-site
incineration is a more expensive treatment method than enhanced
volatilization. A treatability study would be required to deter-
mine the actual amount of soil which can be successfully treated
by enhanced volatilization. It is likely that enhanced volatili-
zation would be a viable treatment method for a large percentage,
or perhaps all, of the contaminated soil; thus, decreasing the
cost significantly.
ALTERNATIVE S-6: IN SITU VACUUM EXTRACTION/SOIL EXCAVATION/
OFF-SITE TREATMENT AND DISPOSAL
In situ vacuum extraction involves the installation of wells at a
depth of approximately 20 feet in those areas of the soil which
are contaminated with volatile organics. The wells are then
connected via a pipe system which is attached to a vacuum pump.
The vacuum pulls air through the contaminated soils. This air,
containing the volatile organics which were removed from the
soil, is then fed to a unit to remove the volatiles. Excavation
is not required for this stage of Alternative S-6.
The second stage of this alternative would involve the treatment
of 1120 cubic yards of soil. The treatment method is the same as
for the second stage of Alternative S-5, because vacuum extraction
also is not an effective technology for the removal of semi-volatile
organics from soil. There is a difference in the volume of soil
to be treated as compared to the second stage of Alternative S-5
because enhanced volatilization is capable of removing some of the
semi-volatile organics present in the soil which cannot be removed
by the in situ vacuum extraction process.
Evaluation of Alternatives
Persuant to CERCLA, as amended, EPA must evaluate each alternative
with respect to nine cfriteria. These criteria were developed to
address the requirements of section 121 of SARA. The nine criteria
are: short-term effectiveness, long-term effectiveness and perma-
nence, reduction of toxicity, mobility and volume, implementability,
cost, attainment of ARARs, protectiveness, state acceptance, and
community acceptance. The discussion which follows provides an
analysis, relative to these criteria, of all of the alternatives
under consideration for cleanup of the ground watet and soil at
the Reich Farm site.
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Short-Term Effectiveness
The short-term effectiveness criterion involves the period of
time each alternative needs to achieve protection and any adverse
impacts on human health and the environment that may be posed
during construction and implementation of the alternative.
GROUND WATER ALTERNATIVES:
Alternative GW-1 would take approximately one month to implement
and presents no short-term risks to on-site workers or the
community, however, it provides little or no protection.
Alternatives GW-2, GW-3 and GW-4 present minimal short-term risks
to workers through direct contact pathways with contaminated
water resulting from piping leaks, and normal construction hazards
during remedial action. Alternative GW-2 presents a small addition-
al risk due to emissions from the air stripper. This risk would be
addressed by monitoring to ensure that the air emission standards
are not exceeded. Each of these alternatives would take approxi-
mately eleven years to implement and would achieve full protection
at the end of that time. This implementation time is based on no
remedial action being taken for the soils on-site. Any remedial
action addressing the contaminated soils would decrease the
implementation time for the ground water alternatives.
SOIL ALTERNATIVES:
Alternative S-l would take one month to implement and presents no
short-term risks to on-site workers or the communtity; it does
not achieve full protection.
Alternative S-2 can achieve full protection against the contami-
nants of concern within a one year period and presents minimal
short-term risks to workers during remedial action through direct
contact pathways and the normal hazards associated with the con-
struction of the containment system. These hazards would be
addressed in a health and safety plan which would be developed
for the construction activities.
Alternatives S-3, S-4 and S-5 would require one year, and Altern-
ative S-6 would require two years, to achieve full protection.
Alternatives S-3, S-4, S-5 and S-6 involve the excavation of
contaminated soil and, consequently, would increase the short-term
risk to human health due to increased direct contact pathways
and construction hazards during excavation activities. As stated
above, this concern would be addressed in the health and safety
plan. In addition, Alternative S-3 involves on-site incineration
which poses some risk of exposure to air emissions from the
incinerator; these risks are minimized by the air pollution
control device which is an integral part of the incinerator
system.
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Alternatives S-4, s-5 and S-6 would pose a minor short-term risk
of exposure to the community during the transport of the soil to
an off-site facility for treatment and disposal.
Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
GROUND WATER ALTERNATIVES:
Alternative GW-1 would present a long-term risk to the community
if the contaminant plume migrates outside of the Cohansey (upper
portion of the Kirkwood-Cohansey aquifer system) restricted
private well area surrounding the Reich Farm site, or into the
Kirkwood (lower portion of the Kirkwood-Cohansey aquifer system)
which has fewer restrictions placed on its use as a potable well
source. Alternative GW-l would only track this migration through
monitoring of on-site wells; it would not prevent it.
Alternatives GW-2, GW-3 and GW-4 present no long-term threat to
public health because these alternatives clean up the aquifer to
contaminant levels which are health protective. These alternatives
utilize, proven technologies (i.e., air stripping, carbon adsorption
and UV-oxidation) which have been used frequently for treatment
of industrial and hazardous waste. Alternatives GW-2 and GW-4
provide more flexibility than Alternative_GW-3^jn_:the_types of
compounds which can be successfully treated because they utilize
more that one treatment technology. All of these alternatives
are reliable and present no major operational problems provided
proper maintenance is performed.
SOIL ALTERNATIVES:
In Alternative S-l, none of the contaminated soil on-site would be
remediated; therefore, a significant risk of contaminant migration
into the ground water would remain. The control program and
warning signs which would be used in this alternative would
restrict public access to the site; however, they are not reliable
control methods. The long-term ground water monitoring program
would track the migration of contaminants from the soil into the
ground water, but would not prevent this migration. The warning
signs and monitoring wells would need to be replaced if damaged.
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Alternative S-2 would reduce the risk of contaminant migration
into the ground water by containing the contaminated soil; however,
if the containment system were to fail, this risk would again
present itself. This alternative would require a long-term
management program to detect any migration of contaminants into
the ground water which would indicate that the containment system
has failed. In addition, CERCLA requires that all alternatives
which do not involve treatment of contaminated material must be
reviewed and evaluated every five years. Alternative S-2 would
fall under this provision.
Alternatives S-3, S-4, S-5 and S-6 would completely reduce the
residual risks on the site since all significantly contaminted
soil is removed, treated, or disposed of off-site. There is no
need for long-term, on-site^management for these alternatives
because at the end of the implementation period, all of the
contaminated soil has been remediated; thus, the soil to ground
water contaminant migration route would be eliminated. For
Alternatives S-3, S-5 and S-6, which involve on-site soil treatment,
a quality control monitoring program would be required to ensure
that the soil has met the remedial objectives after treatment is
completed. Because Alternative S-6 is an in situ treatment,
careful monitoring and additional sampling would be necessary to
ensure that the system is meeting all performance standards.
Reduction of Toxicity, Mobility or Volume
This evaluation criterion refers to the anticipated performance
of the treatment technologies, with respect to these parameters,
that a remedy may employ.
GROUND WATER ALTERNATIVES:
Alternative GW-l would gradually reduce the toxicity, mobility and
volume of the contaminated ground water through natural attenuation
(i.e., contaminants in the ground water underlying the Reich Farm
site would eventually adhere to the saturated soils) but would not
prevent the migration of contaminants into potable well sources.
There is no reliable means of calculating the time required for
this natural flushing process to reduce the concentrations of the
contaminants of concern in the ground water to health protective
levels.
Alternatives GW-2, GW-3 and GW-4 would significantly reduce or
completely eliminate the toxicity and volume of the contaminated
ground water by treating it until it attains health protective
levels. In the process, the potential for migration of the
contaminated ground water is reduced.
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SOIL ALTERNATIVES:
Alternatives S-l and S-2 would provide no reduction of the mobility,
toxicity or volume of the contaminants in the soil. Alternatives
S-3, S-4, S-5 and S-6 would reduce the toxicity, mobility and
volume of the contaminants on-site by treatment or off-site
disposal.
Implementability
Implementability involves the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
GROUND WATER ALTERNATIVES:
Although the No Action alternative is the simplest to implement,
based upon site conditions and the availability of land, all of
the ground water alternatives can be implemented with no major
construction difficulties, and in relatively short periods of
time. The proposed treatment technologies and equipment required
for Alternatives GW-2, GW-3 and GW-4 are available as prefabricated
packages from a number of vendors. These packages can be installed
as part of an on-site treatment plant.
SOIL ALTERNATIVES:
•
Alternative S-l is the easiest soil alternative to implement.
The required services and materials are readily obtained and no
special pieces of equipment are needed. Alternative S-2 can also
be readily implemented because standard construction equipment is
used to install the containment system. Labor and materials are
readily available for this alternative.
Alternatives S-3 and S-5 are relatively easy to implement because
packaged mobile units, for incineration and enhanced volatilization,
respectively, are available from several vendors. With respect
to Alternative S-4, there are existing off-site facilities capable
of handling the contaminated soil. This is true for all other
alternatives which include off-site treatment (i.e., S-5 and S-6).
Alternative S-6 uses a relatively new technology which may present
more difficulty in implementation than any of the other alternatives,
A packaged mobile in situ vacuum extraction unit is known to be
available from one vendor. Pilot scale studies would be required
for this alternative.
Cost
The cost of an alternative includes both capital and operation
and maintainance (O&M) costs. Cost comparisons are made on the
basis of present worth values. Present worth values are equivalent
to the amount of money which must be invested to implement a
certain alternative at the start of construction to provide for
both construction costs, and O&M costs over time. Cost estimates
for all of the alternatives can be found in Table 4.
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GROUND WATER ALTERNATIVES:
Alternative GW-1 would be the least costly to implement, followed
by GW-2, GW-3 and GW-4. The present worth value for each altern-
ative is as follows:
Alternative GW-1: $ 236,000
Alternative GW-2: $3,916,000
Alternative GW-3: $4,100,000
Alternative GW-4: $5,722,000
SOIL ALTERNATIVES:
Again, the no action alternative is the least costly to implement,
followed by Alternatives S-2, S-5, S-6, S-3 and S-4. The present
worth value for each alternative is:
Alternative S-l: $ 314,000
Alternative S-2: $ 877,000
Alternative S-3: $2,590,000
Alternative S-4: $3,550,000
Alternative S-5: $1,916,000
Alternative S-6: $2,135,000
Compliance with ARARs
This criterion addresses whether or not a remedy will meet all
applicable or relevant and appropriate requirements and/or provide
grounds for invoking a waiver. ARARs can be contaminant specific,
location specific, or action specific.
GROUND WATER AND SOIL ALTERNATIVESr
All alternatives except no action will meet all applicable or
relevant and appropriate federal and state environmental laws.
Overall Protection of Human Health and the Environment
This criterion addresses whether or not a remedy provides adequate
protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls, or institutional
controls.
GROUND WATER AND SOIL ALTERNATIVES:
Protection of human health and the environment is the central
mandate of the Comprehensive Environmental Response, Compensation
and Liability Act. Protection is achieved primarily by taking
appropriate action to ensure that there will be no unacceptable
risks to human health or the environment through any exposure
pathways.
-------
-25-
The alternatives evaluated, with the exception of no action, are
protective of public health and the environment.
State Acceptance
The State of New Jersey has stated no objection to those altern-
atives which actively clean up contaminated soils and ground water.
Community Acceptance
GROUND WATER ALTERNATIVES:
Except for the no action alternative, the ground water alternatives
are similar in their short-term and long-term effectiveness and
in the amount of construction activity which will be required for
implementation. Based on this, it seems that Alternatives GW-2,
GW-3 and GW-4 should be equally acceptable to the community.
SOIL ALTERNATIVES:
It is likely that Alternative S-l would be unacceptable to the
public since it provides no protection from the migration of
contaminants into the ground water. Alternative S-2 does not
remove or treat the contaminated soil which may negatively
influence public opinion. Alternative S-3 involves on-site
incineration which has been historically unfavorable to local
communities. In contrast, Alternative S-4 involves transport of
contaminated soil off-site which has generally been the preference
of local affected communities. Alternatives S-5 and S-6 both
involve on-site treatment and the removal of soil, but Alterative
S-5 can be implemented more quickly and involves tfr«* remnval of a
_s.ma.l ler ..amount—o-f- soi-i- -from^the~srEe which should make it more
acceptable than S-6.
SELECTED REMEDY/STATUTORY DETERMINATIONS
The Environmental Protection Agency has been explicitly directed
by Congress in Section 121 (b) of CERCLA, as amended, to select
remedial actions which utilize permanent solutions and alternative
treatment technologies or resource recovery options to the maximum
extent practicable. In addition, the Agency is to prefer remedial
actions that permanently and significantly reduce the mobility,
toxicity or volume of site wastes.
After careful review and evaluation of the alternatives presented
in the feasibility study as achieving the best balance of all
evaluation criteria, EPA presented alternative GW-2, pumping
contaminated ground water/treatment by air stripping and carbon
adsorption/reinjection of the treated water, and S-5, excavation
-------
-26-
of contaminated soil/treatment by enhanced volatilization or
off-site incineration/backfilling the soil which was treated
on-site, to the public as the preferred remedy for the ground
water and soil, repectively, at the Reich Farm site. The input
received during the public comment period, consisting primarily
of questions and statements submitted at the public meeting held
on August 30, 1988, is presented in the attached Responsiveness
Summary. Public comments received encompassed a wide range of
issues but did not necessitate any major changes in the remedial
approach taken at the site. Accordingly, the preferred alternatives
were selected by EPA as the remedial solution for the site. Some
additional activities will be performed during the initial phases
of the remedial design process and prior to implementation of the
selected remedial alternative. These activities are described
and justified as follows:
* The high concentrations of methylene chloride, acetone and
bis(2-ethylhexyl)phthlate detected in the ground water during
the remedial investigation seem to be anomalies. Testing of
on-site monitoring wells is necessary to determine whether
these compounds are actually present in the ground water at
concentrations above health protective levels. If sampling
confirms these high levels, the treatment method chosen for the
ground water can then be adjusted to address removal of these
compounds to health protective levels. Air stripping can
provide a high degree of removal of acetone and methylene
chloride from the ground water, and carbon adsorption is an
effective treatment method for BEHP. If necessary, the removal
efficiency of the units can be adjusted during the design of
the ground water treatment system to reflect the results of the
sampling.
' Exact delineation of the downgradient—extent-of
plume has not been fully accomplished by the remedial invest-
igations conducted at the site. Therefore, sampling of wells
further downgradient than those sampled during the remedial
investigations is warranted. This may be accomplished by
sampling any existing downgradient wells which were not sealed
as part of the 1974 Dover Township Health Department zoning
ordinance. If there are not enough existing downgradient wells,
additional monitoring wells will be installed and sampled.
* Additional sampling of the soils on-site to ensure that all
soil with concentrations of organics above the New Jersey Soil
Action Levels is remediated.
The costs associated with the selected alternative are itemized
in Table 7. The major components of this action are as follows:
» Extracting contaminated ground water by pumping followed
by on-site treatment through air stripping and carbon adsorption
and reinjection of treated water into the ground. The treated
-------
-27-
vater will be tested to ensure that the treatment method is
meeting federal and state standards. Additional pre-treatment
and post-treatment units may be required to remove any other
contaminants detected in the ground water during final delineation
of the plume. Any waste generated by these additional units will
be treated to meet applicable disposal limits. The required
treatment process will continue until federal and state cleanup
standards are attained to the maximum extent that is technically
practicable.
- Conducting an analysis of the contaminant concentration levels
found in the exhaust gases emitted by the air stripping unit.
This analysis will determine whether additional post-treatment
units are required to meet national and state ambient air quality
standards.
- Pilot scale testing of the enhanced volatilization unit to
determine which compounds can be treated to meet the New Jersey
Soil Action Levels by this method.
- Excavation, storage and Backfill of surface soils on-site which
do not require remediation.
- Excavation, staging, treatment by enhanced volatilization, and
backfill of subsurface soils. Before backfilling, testing will
be performed to ensure that contaminant concentrations in the
treated soil are below the New Jersey Soil Action Levels.
- Excavation, on-site staging, and transportation off-site to a
RCRA permitted facility for treatment and disposal, of subsurface
soils with contamination which cannot be treated to below the
action levels by enhanced volatilization.
PROTECTIVENESS
The selected site remedy protects human health and the environment
by dealing effectively with the principle threats posed by the
Reich Farm site. These principle threats involve the ingestion
of volatile contaminants found in the ground water and the migra-
tion of contaminants from the soil into the ground water where
they have the potential to cause a health risk. The selected
alternative addresses these contaminant pathways by capturing and
treating the contaminant plume and removing and treating the
contaminated soil. The primary contaminants of concern in the
ground water which were identified in the RI report are 1,1,1-
trichloroethane, trichloroethene, and tetrachloroethene. The
contaminants of concern in the soil include both volatile and
semi-volatile organics.
-------
-28-
PREFERENCE FOR TREATMENT
The statutory preference for treatment is satisfied by the selecte
remedy which employs on-site treatment of the ground water through
air stripping and carbon adsorption. It also includes on-site
enhanced volatilization for a portion of the contaminated soil
and off-site incineration for the remaining contaminated soil.
These treatment methods effectively reduce the toxicity, mobility
and volume of the contaminants.
COST EFFECTIVENESS
Of the alternatives which most effectively address the principle
threats posed by the contamination at the site, the selected
alternatives afford the highest level of overall effectiveness
proportional to their cost. The selected alternatives are cost-
effective because they provide the highest degree of protectiveness
among the alternatives evaluated while representing a reasonable
value for the money.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The selected remedial actions utilize permanent solutions and
alternative treatment technologies to the maximum extent praticable
and provide the best balance among the nine evaluation criteria
of all of the alternatives examined.
The ground water treatment will reduce the contaminants of concern
to health protective levels. After treatment is complete, the
ground water will no longer present a potential future risk to
the public health; therefore, neither monitoring nor management
will be required.
The soil treatment will prevent contaminants which are currently
in the soil from migrating into the ground water where they may
pose a potential health risk. Again, when this treatment is
complete, no long-term monitoring or management will be required.
In addition, no restrictions on the use of the site will be
necessary.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Action-Specific
Materials on-site are not RCRA listed wastes based on current
information. In addition, these wastes are not expected to be
characteristic. Therefore, any ARARs pertaining to listed or
characteristic wastes are not applicable to the Reich Farm site.
-------
-29-
Under the Clean Air Act, the National Ambient Air Quality Standards
(as contained in 40 CFR Parts 50.6, 50.7 and 50.12) are considered
applicable federal requirements for limiting the concentration of
particulate matter which may be emitted from the air stripping
unit and the enhanced volatilization system in the selected
remedial actions. The Ambient Air Quality Standards (NJAC 7:27-13)
are considered an applicable state requirements. Relevant and
appropriate state requirements include the emission standards
provided in NJAC 7:27-6 (Control and Prohibition of Particulates
from Manufacturing), and the substantive requirements for the
operation of air pollution control equipment under NJAC 7:27-8
(Permits and Certificates).
Spent carbon from the ground water treatment system will be
disposed of off-site consistent with applicable RCRA land ban
requirements. The carbon may be regenerated which would also
meet RCRA land ban requirements.
EPA has undertaken a land ban rulemaking that applies to soil and
debris and which extends the time period for disposing of these
materials. Therefore, the land ban is not considered relevant
and appropriate at this time.
The reinjection process for the treated ground water will meet
underground injection well regulations by its status as a Superfund
remedial action. The extracted ground water will be treated to
meet drinking water standards prior to reinjection.
RCRA closure requirements are relevant and appropriate for the
treated soils which will be placed back on-site after the enhanced
volatilization process. The clean-up levels which were selected
for the soils are consistent with an alternative clean closure
which will not require long-term management or engineering
controls.
Any soil which is taken off-site for treatment and disposal will
be brought to a RCRA permitted facility.
Contaminant-Specific
As outlined in Table 1, Parts B and C, the federal MCLs under the
Safe Drinking Water Act are promulgated applicable requirements
which limit the concentration of contaminants in the treated
ground water which is to be recharged on-site through reinjection
wells. The more stringent New Jersey MCLs would limit the concen-
trations in the treated effluent at the point of reinjection to
levels of 26 ppb for TCA, 1 ppb for TCE and 1 ppb for PCE, the
major contaminants in the ground water.
-------
-30-
Location-Specific
In compliance with the Endangered Species Act, a consultation
with the U.S. Fish and Wildlife Service win be carried out to
evaluate the potential for encountering federal endangered or
threatened species in the vicinity of the Reich Farm site. It is
expected that the selected remedy will not have any detrimental
impact on these species because of their transient nature in this
area.
The site is located less than one mile from a stream and its
associated wetlands, and is adjacent to the floodplains of concern
as designated by the Federal Emergency Management Agency. Because
of the distance between the site and these resources, it is not
expected that the selected remedial actions would adversely impact
them. However, if the proposed future ground water sampling
indentifies the presence of site generated contamination affecting
these resources, a wetlands/floodplains assessment will then be
conducted to ensure compliance with Executive Orders 11988 and
11990 before the remedial action is implemented.
-------
-------
Figure 2
OMUM tf ACIMC AND T*(NCM Adi A
rno»«««» atwt
fNOM lAIMAf
-------
ZOME I: NO WELLS PERMITTED
ZOMC It WELL* SCREENED IN THE
KiltKWOOD Ofl DEEPEN
ZONE III: NO RESTRICTIONS
ITIW,
U.S. EMVIRONMCNTAL PROTECTION
AGENCY
FIGURE 3
OROUNOWATER CONTOURS AND ZONES Of
RESTRICTED OROUNDWATER USE IN
PLEASANT PLAINS, NJ. ISM.
-------
-------
-35-
TABLE 1
(page 1 of 13)
MAJOR CONTAMINANTS FOUND AT THE REICH FARM SITE
A. SURFACE SOILS— ( 0 - 2 ft. depth)
ORGANIC CONTAMINANTS
Volatiles
Acetone
2-Butanone
Tetrachloroethene
1,1, 1-Tr ichloroethane
1 ,2-Dichloroethene
Toluene
Ethylbenzene
Total Xylenes
Chlorobenzene
Semi -Volatiles
Bis ( 2-ethylhexyl )
phthalate
Di-n-octyl phthalate
Di-n-butyl phthalate
Butylbenzyl phthalate
Fluoranthene
Pyrene
f of detects/
# of samples
taJcen
3/5
4/5
4/5
1/5
1/5
3/5
3/5
3/5
2/5
5/5
1/5
4/5
2/5
1/5
1/5
Maximum
concentration
detected
(ppm)
,017
.011
.022
.007
.001
.099
.059
.180
.100
•
5.7
.570
.110
.420
.180
.110
New Jersey
soil cleanup
guidelines
1 ppm
for
total
volatile
organics
(not
exceeded)
10 ppm
for
total
semi-
volatile
organics
(not
exceeded)
-------
-36-
TABLE 1
(page 2 of 13)
A. SURFACE SOILS (Continued)
INORGANIC CONTAMINANTS
Aluminum
Barium
~
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Sodium
Vanadium
Zinc
f of detects/
# of samples
taken
5/5
5/5
3/5
5/5
5/5
5/5
5/5
5/5
5/5
5/5
5/5
2/5
5/5
5/5
Maximum
concentration
detected
(ppm)
4262
16
.01
1850
6
2
20
5062
15
241
31
526
76
17
New Jersey
soil cleanup
guidelines
(ppm)
NG
400
1
NG
100
NG
170
NG
250-1000
NG
NG
NG
NG
350
-------
-37-
TABLE 1
(page 3 of 13)
B. SUBSURFACE SOILS (> 2 ft depth)
ORGANIC CONTAMINANTS
"
Volatiles
~~ ——————
Metnylene Chloride
Acetone
2-Butanone
1,1, 1-Tr ichloroethane
Tetrachloroethane
Toluene
Chlorobenzene
Ethylbenzene
Styrene
Total Xylenes
2-Hexanone
Trichloroethene
Vinyl Acetate
Carbon Disulfide
Benzene
Chloroform
4-Methyl-2-Pentanone
# of detects/
# of samples
taken
6/91
20/115 '
21/126
8/158
12/158
17/144
7/158
16/158
20/158
17/158
5/158
5/158
1/158
2/158
2/158
1/158
4/158
Maximum
concentration
detected
(ppm)
1.300
12.000
31.000
.118
13.907
53.000
36.120
9.300
170.000
3.597
.045
.001
.001
.011
.002
.001
.047
New Jersey
soil cleanup
guidelines
1 ppm
for
total
volatile
organics
(exceeded)
-------
-38-
TABLE 1
(page 4 of 13)
B. SUBSURFACE SOILS (Continued)
ORGANIC CONTAMINANTS
-
Semi -vol at lies
Phenol
Napthalene
4-Chloro-3-Methylphenol
2-Me thy inaptha 1 ene
Acenaphthene
Dibenzofuran
N-Nitrodiphenyl amine
Fluor ene
Phenant hr ene
Anthracene
f
Fluor anthene
Pyrene
Di-n-butylphthalate
Butylbenzylphthalate
Diethylphthalate
2-Chlorophenol
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
Napthalene
1,2, 4-Tr ichlorobenzene
# of detects/
f of samples
taken
4/158
1/158
1/158
1/158
1/158
1/158
5/158
1/158
1/158
2/158
3/158
5/158
41/140
17/157
1/158
2/158
2/158
2/157
4/157
1/158
5/158
Maximum
concentration
detected
(ppm)
6.700
13.179
.075
5.002
10.390
5.157
.083
7.043
24.843
2.641
13.365
7.911
5.400
74.836
.017
.340
15.000
64.000
95.000
13.179
6.600
New Jersey
soil cleanup
guidelines
10 ppm
for
total
semi-
volatile
organics
( exceeded )
•
-------
-39-
TABLE 1
(page 5 of 13)
B. SUBSURFACE SOILS (Continued)
ORGANIC CONTAMINANTS
Semi-volatiles (con»t)
Bis(2-ethylhexyl)
phthalate
Di-n-octylphthalate
INORGANIC CONTAMINANTS
_
.
Aluminum
• .
Arsenic
"
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
# of detects/
# of samples
taken
'
49/137
7/156
_!»
# of detects/
f of samples
taken
104/104
0/104
92/104 '
62/101
5/104
82/87
85/95
79/104
68/99
103/104
26/99
76/94
86/105
10/103 .
Maximum
concentration
detected
(ppm)
742.064
1.900
Maximum
concentration
detected
(ppm) ,
4960
ND
i
80
1
2.4
28250
46
11
62
14636
61
8757
46
'
.6
New Jersey
soil cleanup
guidelines
New Jersey
soil cleanup
guidelines
(ppm)
NG
20
400
1
3
NG
100
NG
170
NG
250-1000
NG
NG
1
-------
-40-
TABLE 1
(page 6 of 13)
B. SUBSURFACE SOILS (Continued)
INORGANIC CONTAMINANTS
— — — ^—^_— _^________
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
* of detects/
# of samples
taken
7/104
50/94
0/104
62/104
79/89
67/86
Maximum
concentration
detected
(ppm)
___
158
4452'
ND
9313
43
44
New Jersey
soil cleanup
guidelines
(ppm)
100
NG
5
NG
NG
350
-------
-41-
TABLE 1
(page 7 of 13)
C. GROUND WATER (MONITORING WELLS)
ORGANIC CONTAMINANTS
Volatiles
Methylene Chloride
Acetone
Toluene
1 , 1-Dichloroethene
1 , 1-bichloroethane
1 ,2-Dichloroethene
2-Butanone
• »
Chloroform
>
1,1, l-Tr ichloroethane
fflw « ^fa 1 ^** f***^ \* ***r* *L
in cyi J.QI: oetnene \
Tetrachloroethene
1 , 2-Dichloroethane
Carbon Tetrachloride
Chlorobenzene
Ethylbenzene
# of detects/
# of samples
taken
4/30
9/37
3/45
3/45
6/45
4/45
3/45
5/45
15/44
1 T /AC
r -l-i/-4D
8/45
1/45
1/45
1/45
1/45
Maximum
cone ent rat i on
detected
(ppb)
.
640
74000
3
1
8
7 •
320
1
130
*-c-
T3
19
5
16
1
1
ARAI
State*
(ppb)
2
NG
+
2
+
10
NG
5, +
26
— x —
t *
1, *
2, +
2, +
4, +
+
IS
Federal**
(ppb)
NG
NG
2000 \
7
NG
70 \
NG
NG
200
5 \
5
5
60 \\
700 \
-------
-42-
TABLE 1
(page 8 of 13)
C. GROUND WATER (MONITORING WELLS) Continued
ORGANIC CONTAMINANTS
Semi -volat lies
Phenol
Bis(2-ethylhexyl)
phthalate
n-Nitrosodiphenyl-
amine
Di-n-octylphthalate
f of detects/
# of samples
taken
1/45
18/44
1/45
1/45
Maximum
Cone ent r at i on
detected
(ppb)
4
2200
6
4
AR2
State*
(ppb)
3500 <
NG
NG
NG
VRS
Federal**
(ppb)
NG
21000 C
NG
NG
-------
-43-
TABLE 1
(page 9 of 13)
1
C. GROUND WATER (MONITORING WELLS) Continued j
INORGANIC CONTAMINANTS
Aluminum
Antimony
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Cyanide
# of detects/
# of samples
taken
18/18
1/18
10/18
2/18
18/18
6/16
8/17
18/18
" 7/17
18/18
18/18
3/18
9/18
18/18
1/18
18/18
4/18
11/16
0/6
Maximum
concentration
detected
(ppb)
2620
65
83
6
16500
615
127
41300
56
3780
318
. 6
97
671
20
41800
12
1800
18
ARAI
State*
(ppb)
NG
NG
1000
3.7
NG
50 ]
NG
NG
50
NG
NG
2 ]
13.4
NG
50
NG
NG
NG
200 <
IS 1
Federal*
(ppb)
i
i
! NG
; NG
4700 \
5 \
NG
100 \
1300 \
300 S
50 P
NG
50 S
2 P
NG
NG
50 P
NG
NG
5000 S
NG
-------
-44-
TABLE 1
(page 10 of 13)
D. GROUND WATER (OFF-SI!
ORGANIC CONTAMINANTS
Volatiles
Methylene Chloride
Toluene
Acetone
Trichloroethene
2-Butanone
Carbon Tetrachloride
Tetrachloroethene
1,1, 1-Trichloroethane
4-methyl-2-pentanone
Chloroform
Benzene
Semi-volatiles
Bis (2-ethylhexyl)
phthalate
Pent achloropheno 1
2 , 4-dichlorophenol
4-chloro-3-methylphenol
Di-n-butyl phthalate
Benzo ( k ) f luoranthene
Pyrene
[T POTABLE WELJ
# of detects/
f of samples ,
taken
0/11
1/23
0/22
4/23
6/18
1/23
3/23
1/23
1/23
" 1/23
1/23
2/23
1/23
1/23
1/23
1/23
1/23
1/23
-S)
Maxiumum
concentration
detected
(ppb)
ND
1
ND
2
14
7
5
5
2
3
^
10
54
54
46
6 .
40
120
j
M
State*
(ppb)
i
j
j
2 j
. i
NG
1. +
NG
2, +
1. *
26
NG
5, +
1, +
NG
NG
NG
NG
NG
NG
NG
IARS
Federal**
(ppb)
NG
2000 \
NG
5
NG
5
5 \
200
NG
NG
5
21000 C
220 \\
NG
NG
NG
NG
NG
-------
-45-
TABLE 1
(page 11 of 13)
O. GROUND MATER (OFF-SITE POTABLE WELLS) Continued
ORGANIC CONTAMINANTS
Semi-volatiles
Isophorone
N-nitrosodi-n-
propylamine
Fluorantnene
INORGANIC CONTAMINANTS
Aluminum
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
f of detects/
f of samples
taken
1/23
1/23
1/23
# of detects/
# of samples
taken
14/17
10/17
1/17
1/17
12/17
0/17
2/17
12/17
14/17
6/17
12/17
Maximum
concentration
detected
(ppb)
58
120
58
Maximum
concentration
detected
(ppb)
783
80
2
273
5070 .
ND
11
190
1648
58
3250
ARAI
State
(ppb)
NG
NG
NG
ARAI
State*
(ppb)
NG
1000
NG
3.7
NG
50 ]
NG
NG
NG
50
NG
is
Federal
(ppb)
NG
NG
NG
Is
Federal*
(ppb)
NG
4700 \
NG
5 \
NG
100 \
NG
1300 \
300 S
50 P
NG.
-------
-46-
TABLE 1
(page 12 of 13)
D. GROUND WATER (OFF-SITE POTABLE WELLS)
INORGANIC CONTAMINANTS
- •
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Tin
Vanadium
Zinc
# of detects/
# of samples
taken
12/17
6/17
2/17
12/17
•
1/17
0/17
17/17
1/17
2/17
" 11/17
Maximum
concentration
detected
(ppb)
55
.7
86
3370
1.3
ND
18500
58
13
1800
! AR
State
(ppb)
NG
2 <
13.4
NG
10 <
50
NG
NG
NG
NG
ARS
Federal
(ppb)
50 S
2 P
NG
NG
10 P
50 P
NG
NG
NG
5000 S
-------
-474
TABLE 1
(page 13 of 13)
i ;
DATA REPORTING QUALIFIERS
* All standards are New Jersey Maximum Contaminant
Levels! (MCLs) for "A-280" Contaminants (NJAC 7:10-16)
unless; stated otherwise.
** All standards are Safe DrinJcing Water Act MCLs
unless stated otherwise. |
+ The total concentration limit for all contaminants
with this indicator is 50 ppb in ground water.
\ Proposed Safe Drinking Water! Act MCL.
\\ Maximum Contaminant Level Goals (MCLGs). These are
not ARARs.
< NJAC 7:9-6 Ground Water Standards, New Jersey Water
Pollution Control Act.
C Clean Water Act Water Quality Criteria for Human
Health Adjusted for Drinking Water.
] New Jersey Pollution Discharge Elimination System
(WJPDES)-Ground Water Protection.
P Safe Drinking W^er _Acjt_Jgrimary Standards ( fnr
considerations).
S Safe Drinking Water Act Secondary Standards (these
standards do not indicate a potential health risk;
they relate to the aesthetic quality of drinking
water (i.e., odor, taste, etc.).
NG A value is NOT GIVEN for this compound.
ND Sample was analyzed for this compound but it was NOT
DETECTED in that sample.
-------
-48-
TABLE 2
(page 1 of 2)
POTENTIAL RISKS ASSOCIATED WITH CONTAMINANT PATHWAYS
Contaminant
Pathway
:
'
Dermal contact
with or inges-
tion of soil by
trespassers
Transport of
contamination
from soil to
air
Migration of
contaminants
from soil to
surface water
Ingest ion of
contaminated
ground water
on-site
Plausible*
Exposure
Pathway
:
1
I
YES
T
!
YES
NO
r •
YES
.
Compounds**
of
Concern
none
none
acetone
BEHP
TCE
PCE
HI
12
1.8x10-1
1.6x10-2
Carcinogenic
Risk
Factor
•
4.4x10-5
2.4X10-6
1.4X10-5
* If an exposure pathway was considered plausible, it was
then evaluated in the Public Health Evaluation (PHE).
** An indicator compound was considered a compound of concern
if it had a Hazardous Index (HI) > 1 or a Carcinogenic Risk
Factor > 1x10-6
+ There is presently no risk from the ground water on-site
because it is not used as a potable water source. This
pathway was evaluated to determine a potential future risk
from this ground water.
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-49-
TABLE 2
(page 2 of 2)
Contaminant
Pathway
Migration of
contamination
from soil to
ground water
Plausible*
Exposure
Pathway
YES
Compounds**
of i
Concern
\
ethylbenzene
chlorobenzene
HI
1.8
86
Can
Risi
Fac
j
i
!
:inogenic
c
tor
.__
!
* If an exposure pathway was considered plausible, it was then
evaluated in the Public Health Evaluation (PHE).
** An indicator compound was considered a compound of concern
if it had a Hazardous Index (HI) > 1 or a carcinogenic
risk factor > 1x10-6.
++ The risk posed by this contaminant pathway was evaluated by
considering the indicator compounds to have reached their
maximum concentrations in the ground water.
-------
-50-
TABLE 3
(page 1 of 3)
RATIONALE FOR SELECTION OF REMEDIAL ALTERNATIVES
GROUND WATER OBJECTIVES
Compound/
Compound Type
Rationale
Accepted as
Remedial
Objective
Metals
1,2 Dichloro-
ethene
Carbon
Tetrachloride
Methylene
Chloride
Four metals were detected at
levels which exceeded ARARs. I
Metal detections were scattered.
There were a number of detections
in upgradient wells. No evidence
that metals were dumped at Reich
Farm. Detections do not seem
to be site related.
Detected slightly above New Jersey
.MCL in only 1/45 monitoring well
samples. Detection considered
an anomaly.
Same as above.
Detected in four samples slightly
above New Jersey MCL. Not evalu-
ated as an indicator compound in
PHE. The small number of detec-
tions (4/30) and the fact that
methylene chloride is a typical
field and laboratory contaminant
indicates that the methylene
chloride detected is not likely
present at the site. Further
testing should be done to confirm.
NO
NO
NO
NO
(Further
testing
required)
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-51-
TABLE 3
(page 2 of 3)
GROUND WATER OBJECTIVES (continued)
Compound/
Compound Type
Rationale
Accepted as
Remedial
Objective
Acetone
BEHP
TCE, TCA,
PCE •
No ARARs. Detected in one
sample above health protec-
tive level calculated in
PHE. Concentration in that
sample seems to be an anomaly
because it was much higher
than the next highest detection.
Also, acetone is a typical
laboratory contaminant. Further
testing is required.
Detected in two samples above
health protective levels deter-
mined in PHE. High detections
seem to be anomalies.* BEHP is
a typical field and laboratory
contaminant. Further testing
should be done.
NO
(Further
testing
required)
Detected above respective New
Jersey MCLs in a number of
samples. PHE showed TCE and
PCE to be above respective
health based levels calculated
in PHE. Consistent with types
of compounds thought to have
been dumped at the site.
Detections indicate a ground
water plume.
NO
(Further
testing
required)
YES
SOIL OBJECTIVES
Metals
Only one detection of nickel
above New Jersey Soil Action
Levels. No pattern of metal
contamination. No indication
that metals were dumped at
Reich Farm.
NO
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-52-
TABLE 3
(page 3 of 3)
SOIL OBJECTIVES (continued)
Compound/
Compound Type
Rationale
Accepted as
Remedial
Objective
Volatile
Organ!cs
Semi-volatile
Organics
Would cause a health risk
if reached maximum concen-
trations in ground water.
Detected above New Jersey
Soil Cleanup Action Level
of 1 ppm.
BEHP presently detected in
ground water. If maximum
concentration of BEHP was
attained in the ground
water through migration
from the soil, health based
levels calculated in-the
PHE would be exceeded.
No other semi-volatile
was evaluated in this manner.
Above New Jersey soil
Action Level of 10 ppm.
YES
YES
-------
-53-
F
!
i
I TABLE 4
(page l of 2)
i \
SCREENING OF REMEDIAL TECHNOLOGIES
FOR GROUND WATER
l
Reich Farm Site
Technology
Advantages/
Disadvantages
Technology
Retained
I. GROUND WATER CONTROLiMEASURES
Capping
Subsurface
Barriers
Ground Water
Pumping
migrat
Upper portion of soil is not signi-
ficantly contaminated. Horizontal
no
on of contamination in
ground!water unaffected.
Difficult to install because the
barrier must be keyed into an imper-
meable layer which is located at
a depth of 2500 feet at the site.
Effective in manipulation and
management of ground water to control
a plume. Should be combined with
a treatment technology.
no
yes
II. ON-SITE TREATMENT
Physical Treatment
Air Stripping
Steam Stripping
Carbon
Adsorption
Most effective for treating volatile
organic contaminants. May require
air emission controls. Treatability
studies have shown it to be effective
for treating the ground water at the
site.
More costly than air stripping and
the extra degree of effectiveness
is not necessary for the conditions
at the site.
Effective in removing volatile and
semi-volatile organics in ground
water. Contaminated carbon generated
would require treatment or disposal.
yes
no
yes
-------
-54-
TABLE 4
(page 2 of 2)
Technology
Advantages/
Disadvantages
Technology
Retained
Chemical Treatment
UV Oxidation
Chemical Oxidation^
Chemical Reduction!
Volatile organ!cs at the site
have been effectively treated
by this method elsewhere. Pilot
studies would be required.
Not as effective as UV oxidation,
May leave organics in effluent.
yes
no
III. PLACEMENT TECHNOLOGIES
POTW
Reinjection of
Ground Water
There are currently no POTWs in
the area of the Reich Farm site.
Must be combined with treatment
technologies. Potential problems
include clogging and plugging by
chemical precipitation. Feasible
for site based on site hydrology
and amount of ground water requiring
treatment.
no
yes
-------
-55-
- TABLE 5
(page 1 of 3)
SCREENING OF REMEDIAL TECHNOLOGIES
FOR SOIL
Reich Farm Site
Technology Advantages/ Technology
Disadvantages Retained
I. CONTAINMENT TECHNOLOGIES
Subsurface Isolation of soil will prevent yes
Barriers contaminant transport to ground
water. Grout curtain is the
most effective type of barrier
for the site.
Single-Layer Susceptible to erosion. Typi- no
Cap cally used as a temporary cap.
Multi-Layer Prevents percolation of rain yes
Cap water through the contaminated
soil. Most durable type of cap.
Must be monitored to insure
integrity is maintained. Should
be combined with a subsurface
barrier.
II. TREATMENT TECHNOLOGIES
Chemical Treatment
Solvent Extraction/ Not a proven technology. Additional no
Recovery units required to remove volatile
organic contaminants from extraction
solution.
Fixation Generally used for soils contaminated no
with metals. Clays in the soil on-
site may interfere with process.
Thermal Treatment
Incineration Will destroy all organics in the soil, yes
Based on the amount of soil requiring
treatment, there are several vendors
available.
-------
-56-
TABLE 5
(page 2 of 3)
Technology
Advantages/
Disadvantages
Technology
Retained
Enhanced
Volatilization
Thermoplastic
Solidification
In Situ Treatment
In Situ Bio-
degradation
Soil Flushing
In Situ Vacuum
Extraction
In Situ
Vitrification
Effective in removing all vola- yes
tile and some semi-volatile
organics from the soil. The re-
maining soil must be treated by
a different method.
Some of the volatile organics no.
found at the site diffuse
rapidly through the material
which is created by this process.
It is doubtful that anaerobic no
bi©degradation would destroy the
chlorinated hydrocarbons in the
soil.
Clay lenses located throughout no
the area would make it difficult
to remove all of the contamination
and recapture all of the soil
washing fluid.
Can remove volatile organics from yes
the soil. A pilot scale test
would be required and the semi-
volatile contaminated soil would
require treatment by a different
method.
Still in development stage. no
Problems which need to be corrected
include electrode failure and the
collection of off-gas streams.
III. PLACEMENT TECHNOLOGIES
Landfills
On-Site
Placement
Landfilling is discouraged by EPA. no
RCRA Landban will limit the types
of waste which can be disposed in
the future.
Must be used in conjunction with yes
treatment. Treated soil would
be non-hazardous and therefore
can be used as backfill.
-------
-57-
TABLE 5
(page 3 of 3)
Technology Advantages/ . Technology
Pi sadvant ages Retained
IV. TRANSPORTATION OF SOIL 1
Trucks Road access to site is available. yes
Provides flexibility in the amount
of soil which can be handled.
Special facilities are not required.
Train Nearest rail spur is five miles no
from the site, therefore, trucks
would still be required.
Barge Not appropriate for small amount no
of soil. Distance to nearest
available water body is prohibitive.
-------
-58-
TABLE 6
(page 1 of 2)
COMPARISON OF PRESENT WORTH FOR REMEDIAL ALTERNATIVES
Ground Water
Alternative
Alternative
Description
Capital
Cost ($)
0 & M
Costs
($/yr)
Present
Worth
Value ($)
GW-l
GW-2
GW-3
GW-4
No Action
Pump/Treat
Using Air
Stripping
and Carbon
Adsorption/
Reinject
Pump/Treat
Using Carbon
Adsorption/
Reinject
Pump/Treat
Using UV-
Oxidation/
Reinject
0
905,000
824,800
1,294,400
15,600 239,800
395,400 3,958,200
429,600 4,142,000
588,200 5,836,300
Soil
Alternative
S-l
S-2
Alternative
Description
No Action
Grout Curtain/
Capital
Cost ($)
230
496,100
0 & M
Costs
($/yr)
21,525
19,160
Present
Worth
Value ($)
331,100
790,600
S-3
S-4
Cap
Excavation/
On-Site
Incineration/
On-Site
Placement
Excavation/
Off-Site
Treatment and
Disposal
2,493,700
113,960 2,602,200
3,416,200
3,416,200
-------
-59-
TABLE 6
(page 2 of 2)
Soil
Alternative
Alternative
Description
Capital
Cost ($)
0 & M
Costs
($/yr)
Present
Worth
Value ($)
S-5
S-6
Excavation/
Enhanced
Volatilization/
On-Site Place-
ment/ Off-Site
Treatment and
Disposal
In Situ Vacuum
Extraction/
Excavation/
Off-Site
Treatment and
Disposal
1,916,000
24,150
2,118,000
1,939,200
35,400 2,183,800
-------
EPA WORK ASSIGNMENT NUMBER: 129-2L49
EPA CONTRACT NUMBER: 68-01-7250
FINAL RESPONSIVENESS SUMMARY
FOR THE
REICH FARM SITE
DOVER TOWNSHIP,
OCEAN COUNTY, NEW JERSEY
SEPTEMBER 1988
NOTICE
The information in this document has been funded by the United
States Environmental Protection Agency (U.S. EPA) under REM III
Contract No. 68-01-7250 to Ebasco Services, Inc. (EBASCO).
-------
EBA8CO SERVICES INCORPORATED : — EBASCO
160 ChuDd Avenue. Lyndhursl.Nj 07071 (201)460-1900
September 26, 1988
RMOII-83-264
Ms. Lillian Johnson
Community Relations Coordinator
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
SUBJECT: REM III Program - EPA Contract Number: 68-01-7250
Work Assignment Number: 129-2L49
Reich Farm Site
Final Responsiveness Summary '
—Dear. M&*_ .Johnson:
EBASCO Services Incorporated (EBASCO) is pleased to submit this
Final Responsiveness Summary for the Reich Farm Site. If you
have any comments, please call me at (201) 460-6434 or Gerry
Zanzalard at (201) 906-2400.
Very truly yours,
Oev R. Sachdev
REM III Region II
Manager
cc: M. Shaheer Alvi
M.K. Yates
R.T. Fellman
M. Amdurer
J. McAdoo
B. Weinstein
-------
Ms. Lillian Johnson
September 26, 1988
Page 2
ACKNOWLEDGEMENT OF RECEIPT
Please acknowledge receipt of this enclosure on the duplicate
copy of this letter and return the signed duplicate of this
letter to: Or. Dev Sachdev, EBASCO Services Incorporated, 160
Chubb Avenue, Lyndhurst, New Jersey 07071.
Ms. Lillian Johnson Date
-------
REM III PROGRAM
REMEDIAL PLANNING ACTIVITIES AT
SELECTED UNCONTROLLED HAZARDOUS SUBSTANCE
DISPOSAL SITES WITHIN EPA REGIONS I-IV
EPA WORK ASSIGNMENT NUMBER: 129-2L49
EPA CONTRACT NUMBER: 68-01-725O
FINAL RESPONSIVENESS SUMMARY
FOR THE
REICH FARM SUPERFUND SITE
DOVER TOWNSHIP, OCEAN COUNTY,
NEW JERSEY
SEPTEMBER 1988
Prepared By:
Date
r-y
Lalist
lology, inc.
Approved By:
,j- jr^~*Sl**LS^~. _ , , -~ . «^v« « 1*sf*e^>
Bruce Weinstein ' Date Dev R. Sachdev
REM III Site Manager REM III Region II
Ebasco Services, Inc. Manager
Ebasco Services, Inc.
-------
REICH FARM SITE
PLEASANT PLAINS, DOVER TOWNSHIP
OCEAN COUNTY, NEW JERSEY
FINAL RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) held a public
comment period from August 17, 1988 through September 19, 1988
for interested parties to comment on EPA's final Remedial
Investigation and Feasibility Study (RI/FS) and Proposed Remedial
Action Plan (PRAP) for the Reich Farm Superfund site.
EPA held a public meeting on August 30, 1988 at the Dover
Township Municipal Building in Toms River, New Jersey to describe
the remedial alternatives and present EPA's preferred remedial
alternatives for the Reich Farm site.
A responsiveness summary is required for the purpose of providing
EPA and the public with a summary of citizens' comments and
concerns about the site as raised during the public comment
period, and EPA's responses to those concerns. All comments
summarized in this document will be factored into EPA's final
decision for selection of the remedial alternatives for cleanup
of the Reich Farm site.
I. RESPONSIVENESS SUMMARY OVERVIEW. This section briefly
describes the background of the Reich Farm site and
outlines the proposed remedial alternatives.
s II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.
This section provides a brief history of community
interest and concerns regarding-the -Reich-F-ana-site?— —=—
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO
THESE COMMENTS. This section summarizes comments
submitted to EPA at the public meeting and during the
public comment period and provides EPA's responses to
these comments.
IV. REMAINING CONCERNS. This section discusses community
concerns that EPA should be aware of as they prepare to
undertake the remedial designs and remedial actions at the
Reich Farm site.
I. RESPONSIVENESS SUMMARY OVERVIEW
The Reich Farm site is located in the Pleasant Plains section of
Dover Township, Ocean County, New Jersey. The site consists of
an open, relatively flat, sandy area encompassing approximately
one acre. The site is abutted by commercial establishments on
the west and wooded areas on all other sides.
-------
The following information was obtained from the TRW final report
entitled "Analysis of a Land Disposal Damage Incident Involving
Hazardous Waste Materials," Dover Township, New Jersey, May 1976.
Mr. and Mrs. Samuel Reich, the owners of the property, discovered
approximately 4,500 drums containing wastes on a portion of their
land that they had rented to a Mr. Nicholas Fernicola. These
drums bore labels indicating that they belonged to Union Carbide
Corporation. In addition, trenches, into which wastes were
believed to have been dumped, were also discovered on the
property. From 1972 to 1974, Union Carbide Corporation removed
approximately 5,150 drums and 1,100 cubic yards of visibly
contaminated soil and trenched wastes from the Reich Farm site.
In August 1974, 148 private wells near the Reich Farm site were
ordered closed by the Dover Township Board of Health following an
analysis performed on a number of these wells which revealed the
presence or organic contaminants in the water. Based on
recommendations from the New Jersey Department of Environmental
Protection (NJDEP), a zoning ordinance restricting the use of
groundwater in the area of Reich Farm was established.
Reich Farm was one of 418 sites placed on EPA's proposed National
Priorities List (NPL) of hazardous waste sites issued in December
1982.
At EPA's direction, a preliminary RI was conducted by NUS
Corporation in 1986 and a supplemental RI was conducted by Ebasco
Services Incorporated in 1987. The results of these
investigations indicate the following:
* • The surface soils on-site (those soils at depths of
five feet or less) show no significant contamination.
• "Hot spots'* ~are~present in the subsurface soils
(those soils at depths of greater than five feet).
These "hot spots" are contaminated with both volatile
and semi-volatile organics.
• Groundwater underlying and downgradient of the site
is also contaminated with low levels of organics,
predominantly trichloroethene (TCE),
tetrachloroethene (PCE), and 1,1,1-trichloroethane
(TCA).
SUMMARY OF REMEDIAL ALTERNATIVES
The Superfund law requires each site remedy that is selected to
be protective of human health and the environment, cost-
effective, and in accordance with statutory requirements.
Permanent solutions to contamination problems are to be achieved
wherever possible.
-------
In the course of the RI/FS process, it was determined that
remedial actions at the Reich Farm site should encompass both the
groundvater and the soil. In order to maintain consistency with
the FS, alternatives addressing cleanup of the groundvater will
be presented separately from those addressing soil remediation.
GROUNDWATER ALTERNATIVES
The objectives which have been preliminarily identified for
remediation of the groundvater underlying the Reich Farm site
are:
(1) Reduction of TCE to a concentration of 1 part per
billion (ppb) in the groundvater;
(2) Reduction of PCE to a concentration of 1 ppb in the
groundvater, and
(3) Reduction of TCA to a concentration of 26 ppb in the
groundvater.
These concentrations are Nev Jersey Maximum Contaminant Levels
(MCLs), and are considered relevant and appropriate requirements
for cleanup of groundvater in the State of Nev Jersey.
Alternative GW-1: NO ACTION »
Construction Cost: $0
Annual O&M Costs (Operation and Maintenance): $15,330 .
Time to Implement: 1 Month
This alternative includes the use of existing monitoring veils
(installed during the remedial investigations) to conduct long-
term monitoring of the contaminant concentrations in the Cohansey
Aquifer underlying the site. Under this alternative, use of
groundvater in the area vill continue to be restricted.
Alternative GW-2: PUMPING/AIR STRIPPING/CARBON
ADSORPTION/REIN JECTION
Construction Cost: $905,000
Annual O&M Costs: $390,000
Time to Implement: 11 Years
Under Alternative GW-2, extraction veils vill be installed to
vithdraw contaminated groundvater for treatment. The placement
of these extraction veils vill be determined after additional
groundvater sampling. This sampling vill be conducted as part of
the remedial design and vill help delineate the full extent of
the contaminant plume originating from the Reich Farm site. The
extraction veils vill then be placed so that they vill
effectively and efficiently capture the plume. The extracted
-------
groundwater will be treated by air stripping followed by carbon
adsorption. Treatability studies performed during the RI have
shown this treatment scheme to be capable of removing the
contaminants of concern from the groundwater. The emissions from
the air stripper will be monitored and, if necessary, .the off-
gases will be treated by a vapor phase granular activated carbon
(6AC) filter before they are released to the atmosphere to ensure
that the maximum allowable air emissions are not exceeded. The
treated groundwater will be discharged to injection wells
installed upgradient of the site. In order to evaluate the
.performance of this remedial action, sampling and testing of the
groundwater before and after treatment will be required. This
type of performance monitoring will also be necessary for
Alternatives GW-3 and GW-4.
Alternative GW-3: PUMPING/CARBON ADSORPTION/REINJECTION
Construction Cost: $825,000
Annual O&M Costs: $424,000
Time to Implement: 11 Years
This alternative uses the same pumping system as Alternative GW-
2, however, the groundwater will be treated via two GAC adsorbers
placed in series. The reinjection scheme will also be the same
as for Alternative GW-2.
Alternative GW-4: FOMPING/^C^-UV OXIDATION/CARBON
ADSORPTION/REINJECTION
Construction Cost: .$1,294,000
Annual O&M Costs: $575,000
Time to Implement: 12 Years
This alternative is similar to Alternative GW-2 except that the
contaminated groundwater will be treated by chemical oxidation
instead of air stripping. This chemical oxidation employs a
combination of hydrogen peroxide (H2Oj) and ultraviolet (UV)
light to chemically oxidize the volatile organic contaminants
(VOCs) in the groundwater. The pumping and reinjection systems
are the same as for Alternative GW-2.
SOIL ALTERNATIVES
The following soil alternatives, with the exception of No Action,
involve the remediation of "hot spots" in the subsurface soils.
An area was designated as a "hot spot" if the concentration of
contaminants in the soil exceeded the New Jersey Soil Cleanup
Guidelines of 1 ppm (part per million) of* total volatile organics
or 10 ppm of total semi-volatile organics. Although these
guidelines are not considered legally applicable or relevant and
appropriate requirements (ARARs), cleanup to these levels will
ensure that the contaminants in the soil do not migrate into the
-------
groundwater. For those alternatives which involve treatment, the
amount of soil requiring remediation is an estimated figure.
Testing will be performed during the remedial action to ensure
that all soil with contaminant concentrations above the cleanup
guidelines is treated.
Alternative S-l: NO ACTION
Construction Cost: $0
Annual O&M Costs: $20,000
Time to Implement: 1 Month
The No Action soil cleanup alternative consists of a long-term
monitoring and control program. Warning signs will be posted at
the site to alert people to the subsurface soil contamination.
In addition, measures will be taken to restrict public access to
the site. To assess the migration of contaminants into the
groundwater, a long-term monitoring program, using existing
monitoring wells, will be implemented.
Alternative S-2: CAPPING/GROUT CURTAIN
Construction Cost: $500,000
Annual O&M Costs: $25,000
Time to Implement: 12 Months
In this alternative, a multi-layer cap will be placed over each .
"hot spot1*. A grout curtain will then be injected around the
perimeter of each area. The grout curtain will extend down to
the water table located 30 feet below the surface. The cap will
consist of a synthetic liner, a sand layer, a layer of crushed
stone, a layer of coarse aggregate bituminous concrete, and a
layer of fine aggregate bituminous concrete. The grout curtain
is made of cement mixed with bentonite, soil and water. A long-
term groundwater monitoring program, as described in the No
Action alternative, will be included with this alternative.
Alternative S-3: EXCAVATION/ON-SITE INCINERATION AND PLACEMENT
Construction Cost: $2,500,000
Annual O&M Costs: $92,000
Time to Implement: 12 Months
This alternative will involve excavation of approximately 2,620
cubic yards of soil, 2,010 cubic yards of which will be
subsurface soil requiring treatment. The remaining 610 cubic
yards is surface soil which is not significantly contaminated.
This soil will be stored and eventually used to backfill the
excavated areas. The contaminated soil will be treated in a
mobile incinerator brought to the site. The incineration system
will contain a scrubber to collect any off-gases, produced by
particulate and acid gas removal, prior to release to the
-------
atmosphere. The treated soil will be tested to ensure that the
cleanup level goals have been achieved and will then be used as
backfill in the excavated areas.
Alternative S-4: EXCAVATION/OFF-SITE TREATMENT AND DISPOSAL
Construction Cost: $3,550,000
Annual O&M Costs: $0
Time to Implement: 6 Months
The extent of soil excavation for this alternative will be the
same as described in Alternative S-3. The 2,010 cubic yards of
contaminated soil will be transported off-site to a licensed
contracting company for treatment and disposal. Clean fill and
the overburden soil will be used to backfill the excavated areas.
Alternative S-5: EXCAVATION/ENHANCED VOLATILIZATION/ON-SITE
PLACEMENT/OFF-SITE TREATMENT AND DISPOSAL
Construction Cost: $1,916,000
Annual O&M Costs: $0
Time to Implement: 9 Months
In this alternative, approximately 1,480 cubic yards of soil will
be initially excavated, 1,120 cubic yards of which are subsurface
soils contaminated with volatile organics. The remaining 360
cubic yards are surface soils which will be temporarily stored
and later used as backfill in the excavated areas. The volatile
organic contaminated soil will be staged on site and treated via
an enhanced volatilization unit. In this facility, hot air will
be injected into a thermal processor (rotary dryer) containing
the soil to be treated. The volatile organics—in^the soil will
volatilize into the air stream and combust in an afterburner,
where they will be destroyed. The off-gas from the afterburner
will then be treated in a scrubber for particulate and acid gas
removal. In certain cases, the afterburner can be replaced with
a carbon adsorber to remove the volatiles from the air stream.
In this case, no scrubber would be needed. After testing to
ensure that the level of total volatile organics is below 1 ppm,
the soil will be used as backfill in the excavated area.
The second stage of this alternative involves excavating
approximately 1,140 cubic yards of soil, 890 cubic yards of which
are contaminated with semi-volatile organics. Most semi-volatile
organics are not adequately removed by enhanced volatilization,
therefore, this soil will be taken off-site for treatment (via
incineration) and disposal. The area of this excavation will be
backfilled with clean fill in addition to the 250 cubic yards of
surface soil which were excavated but did not require treatment.
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Alternative S-6: ZN SITU VACUUM EXTRACTION/EXCAVATIOH/OFF-SITE
TREATMENT AND DISPOSAL
Construction Cost: $2,118,000
Annual O&H Costs: $16,500
Time to Implement: 24 Months
In situ vacuum extraction involves installing wells at a depth of
approximately 20 feet in the area of those "hot spots" which are
contaminated with volatile organics. The wells are then
connected via a pipe system and attached to a vacuum pump. The
vacuum pulls air through the contaminated soils. This air,
containing the stripped volatile organics, is then fed to a unit
to remove the volatiles. Excavation is not required for this
stage of this alternative.
The second stage of this alternative will involve the treatment
of 1,120 cubic yards of soil. The treatment method is the same
as for the second stage of Alternative S-5 because vacuum
extraction is not an adequate technology for the removal of semi-
volatile organics from soil. The difference in the volume of
soil to be treated as compared to Alternative S-5 results from
the fact that enhanced volatilization is capable of removing some
semi-volatile organics present in the soil which cannot be
removed by in situ vacuum extraction.
EVALUATION OF ALTERNATIVES
The preferred alternatives for remediation of the contaminated
groundwater and soil at the Reich Farm site are Alternative GW-2,
Pumping/Air Stripping/Carbon Adsorption/Reinjection, and
Alternative S-5, Excavation/EnhancedJ/o^latilization/On-^Site =—
Placement/Off-Site Treatment and Disposal, respectively. Based
on current information, these alternatives provide the best
balance among the nine criteria that EPA uses as a means of
evaluation.
THE PREFERRED ALTERNATIVES
The preferred alternatives, GW-2, Pumping/Air Stripping/Carbon
Adsorption/Reinjection, for groundwater remediation, and S-5,
Excavation/Enhanced Volatilization/On-Site Placement/Off-Site
Treatment and Disposal, for soil remediation, would use proven
treatment techniques. All volatile and semi-volatile organic
contaminants in the soil would be treated to acceptable levels.
The contaminants of concern in the groundwater would be reduced
below their respective ARARs and the possible migration of these
contaminants into drinking-water supplies would be eliminated.
Equipment and labor necessary to construct these alternatives is
currently available.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Reich Farm site initially became an issue for public concern
in 1974 when local residents noticed an unpleasant odor and taste
in their drinking water. Subsequent sampling by EPA and Dover
Township revealed the presence of organic contaminants in the
water. In July and August 1974, the Dover Township Board of
Health ordered the closing of 148 domestic wells which were
thought to have been contaminated by wastes from the Reich Farm
aite. Additional complaints from local residents regarding
similar problems with domestic well-water resulted in sampling
and further detection of organic contamination and the closure of
an additional 13 wells. All residents whose wells were closed
were subsequently connected to a municipal water supply system.
Major issues and concerns expressed by the community regarding
the Reich Farm site are listed below:
• Migration of Contamination through Groundwater. In the
past, public concern has focused on the potential for
contamination to migrate off the site itself through
subsurface groundwater and reach uncontaminated
downgradient wells owned by the Toms River Water
Company, the municipal supply in the area.
• Economic Concerns. Local officials have, in the past,
expressed concern over the potential for the area to
acquire a negative image due to the problem of
contaminated groundwater and subsequently become less
' desirable to prospective residents and businesses.
-III.—SUMMARY-OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS.
Comments raised during the public comment period for the Reich
Farm site are summarized below. The public comment period was
held from August 17, 1988 through September 19, 1988 to receive
comments from the public on EPA's draft Remedial Investigation
and Feasibility Study (RI/FS) and Proposed Remedial Action Plan
(PRAP) for the Reich Farm Superfund site. The public comment
period was extended until September 22, 1988 for two Potentially
Responsible Parties (PRPs), Union Carbide Corporation and the
Reichs. Comments received during the public comment period are
summarized below and are organized into the following categories:
Ao EFFECTIVENESS OF ALTERNATIVES
B. CONTAMINANTS
C. TECHNICAL CONCERNS
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B. CONTAMINANTS
1. Comment: A resident asked if EPA is testing the
groundvater at the Reich Farm site for all compounds
listed in State of New Jersey A-280 legislation.
EPA Response: Although State of New Jersey A-280
legislation; entitled the Interim Safe Drinking Water
Testing Schedule establishes a schedule for testing public
water supplies and lists priority pollutants, imposes more
stringent guidelines on drinking water quality than
federal guidelines, it also lists fewer priority
pollutants. EPA is testing groundwater at the Reich farm
site for more contaminants than are listed in the A-280
legislation. In any case, EPA will comply with the most
stringent guidelines that are established. •
2. Comment: A resident expressed concern that contaminants
from the Reich Farm site could potentially affect
downgradeent munipipal drinking-water wells owned by the
Toms River Water Company.
EPA Response: Based on EPA's studies of groundwater
between the Reich Farm site and the Toms River Water
Company wells, there is no indication that those wells
have been affected by contaminants from the site.
However, EPA plans to install additional groundwater
monitoring wells to ensure that the outermost extent of
the contaminant plume has been defined. These proposed
' wells are part of the design phase of the Reich Farm
project and will also aid the agency in determining the
effectiveness of the implemented remedial alternative.
3. Comment: A local official expressed concern that EPA has
not fully identified the original source and full extent
of off-site contamination attributable to the Reich Farm
site.
EPA Response: It is extremely difficult to determine
exactly what occurred regarding initial.off-site migration
of contaminants that may have resulted when the barrels
were first placed in the ground at the Reich Farm site.
Since the contaminants were dumped illegally, there are no
record of those events, therefore, circumstances
surrounding those activities cannot be traced with one
hundred percent accuracy. EPA's studies attempt to
reconstruct a comprehensive picture of what occurred,
however, we often encounter gaps in the information
compiled. When EPA reaches the point where the agency
10
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feels confident that our studies accurately and adequately
depict the site history, we then proceed with studies to
identify the nature and extent of contamination and
develop and evaluate methods to address the problem.
C. TECHNICAL CONCERNS
1. Comment: Several residents expressed concern regarding
the potential for hazardous emissions coming from the
proposed air stripper to be constructed on the Reich Farm
site.
EPA Response: EPA must adhere to established state and
federal emission standards. In the case of the Reich Farm
site, we are dealing with relatively low levels of
groundwater contamination/ therefore, minimal emissions
are expected from this particular air stripper. EPA also
plans to continually monitor emissions from the air
stripper to ensure compliance with established standards.
If testing indicates state or federal emission standards
will be exceeded, the air stripper will have a carbon
filtration system installed near the top of the unit.
2. Comment: A resident asked if the air stripper would
operate around the clock and cause unnecessary noise in a
residential area.
EPA Response: Once the air stripper is installed, EPA
plans to operate the unit on a twenty-four hour per day,
* seven day per week.schedule for the duration of remedial
activities. The agency has constructed similar units in
other residential areas. The unit could be designed to
operate—a-fc- -minimal-noise levels and should not result in
noise-related inconveniences to area residents.
D. HEALTH AND SAFETY
1. Comment: A resident expressed concern over potential
health effects that may be posed by past contact with
contaminated soil and/or groundwater from the Reich Farm
site and suggested that EPA locate people who may have
been exposed to site-related contaminants and conduct a
health study to determine if any negative effects have, in
fact, occurred.
ATSDR Response: ATSDR is concerned about public health
and possible exposure to hazardous substances. However,
it would be difficult to locate all the individuals who
may have been exposed to contaminants from the Reich Farm
site in the past. The agency is willing to discuss the
feasibility of conducting such a study.
1.1
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E. RESPONSIBILITY OF POTENTIALLY RESPONSIBLE PARTIES (PRPs)
1. . Comment:: Several residents and a local official asked if
a PRP had been identified and if that PRP would assume
financial responsibility for site remediation and any
health-related studies which may be conducted.
EPA Response: A PRP has been identified by EPA and the
agency is conducting discussions with them regarding site-
related studies and costs. Regardless of the outcome of
these negotiations, EPA, through Superfund, will proceed
with cleanup of the Reich Farm site, and, if appropriate,
pursue the PRP through legal channels.
F. TIME FRAME FOR REMEDIATION
1. Comment: Several residents expressed concern that the
time frame required to remediate the Reich Farm site would
be excessive considering the relative small size of the
site.
EPA Response: Within the next month,. EPA, along with the
State of New Jersey, will make a final decision regarding
the best method to remediate the Reich Farm site.
Following that decision, a contractor will be hired to
design the proposed remedy. After completion of plans and
specifications, a clean-up contractor will be chosen »
through a competitive bidding process. Remedial action at
the site could be underway within one year.
OTHER' CONCERNS
1. Comment: A resident asked if EPA would support local
zoning legislation prohibiting any new construction on
contaminated sites.
EPA Response: EPA will support proposals of this nature.
12
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XV. REMAINING CONCERNS
Concerns raised by the community regarding remedial action and
'design activities at the Reich Farm site will continue to be
important community issues throughout the remedial design phase.
Since there are very active community environmental groups in the
vicinity of the Reich Farm site, there is a moderate potential
for the level of interest in the site to show significant
increase once remedial design activities begin. Area residents
should be kept fully informed of the status of remedial
activities throughout this phase in order to dispel public
concern.
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65 Sunset Ave.
Toms River, NJ 08755
September 16, 1988
Ms. Romona Pezzella
Remedial Project Manager
USEPA
Room 759
26 Federal Plaza
New York, NY 10278
Dear Ms. Pezzella:
On August 30, 1988, I testified at the Reich Farms Public Hearing.
Please consider this letter as a follow-up to that testimony.
The Pleasant Plains section of Toms River is a relatively quiet
neighborhood consisting of predominantly private residences. Two concerns
that should be addressed by EPA in their proposed remedial action plan are
noise and air pollution.
The fan associated with the air stripping should be designed or
acoustically housed so there is no noise impact on the community,
especially during summer evening periods. A noise impact study should be
completed to determine background noise data to assist in the proper
engineering design of the fan.
Air pollution concerns are based upon the final air emissions from
the control devices and the quantitative and qualitative characteristics of
these emissions. Even though final air emissions are at the ppm or ppb
level, a diffusion model based upon prevailing wind directions should be
developed, since even minute air emissions over long periods of time can
have adverse health Impacts. If modelling Indicates that final air
discharges could disperse with adverse effects on neighboring homes, then
EPA should consider more sophisticated air pollution controls.
It would be appreciated if you would address these concerns by
responding to me in writing at the address indicated above.
Very truly yours,
Edward J. Capasso
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
September 29, 1988
Edward J. Capasso . •
65 Sunset Avenue
Toms River, NJ 08755
Dear Mr. Capasso:
This is in response to your letter, dated September 16, 1988,
which you submitted as a follow-up to your appearance at the
Reich Farm public meeting on August 30, 1988.
The Environmental Protection Agency (EPA) received a number of
comments during the public meeting for the Reich Farm site and
during the comment period which extended from August 17 to
September 19, 1988. After review of all submitted comments, EPA
intends to proceed with the final remedial solution for the site
which is protective of human health and the environment, cost
effective, and attains federal and state requirements that are
applicable or relevant and appropriate.
'»
Your letter expressed certain concerns over the noise which may
result from the air stripper used in the ground water treatment
system and the air emissions from-this -uni-t. -fn regard to the
noise from the air stripper, similar units have been constructed
by the EPA in residential areas. The unit will be designed to
operate at minimal noise levels and should not disturb nearby
residents.
When operating an air stripper, EPA must adhere to established
state and federal emission standards. In the case of Reich Farm,
there are very low levies of contamination in the ground water;
therefore, minimal emissions are expected to be generated by this
unit. The emissions from the air stripper will be constantly
monitored to ensure compliance with established standards. If
necessary, a vapor phase carbon filter will be installed at the
top of the air stripper to eliminate the emissions.
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I hope that your concerns have been adequately addressed. Your
;interest in the environment at the Reich Farm site is greatly
appreciated.
Sincerely yours,
A
Romona Pezzella^/^tfo^ect Manager
Southern New Jersfey Remedial Action Section
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Mr. Nicolas Fernicola of Toms River, New Jersey to provide
drummed chemical waste disposal services for Union Carbide's
Bound Brook, New Jersey plant. Mr. Fernicola was to remove
these wastes during the period beginning in March of 1971 and
ending on December 31, 1971, to one of several approved sites
for disposal. However, contrary to his agreement with Union
Carbide, Mr. Fernicola apparently moved some 4,000 Union
Carbide drums onto Reich Farm during 1971. During February and
March of 1972, after considerable discussion with the Reichs
and Fernicola and with no admission of liability. Union Carbide
removed the visible drums from the Site. In 1974, following
the discovery of additional buried drums at the Site, Union
Carbide performed an additional remedial activity, again
without admission of liability, by excavating and removing some
11,000 cubic yards of soil along with removal of more than 50
additional drums. The Site first appeared on the National
Priorities List (NPL) in 1982 and is now subject to proposed
remediation.
While the above information is not subject to significant
dispute, there are a number of issues pertaining to the 17 year
history of this Site and which are not discussed in the RIFS
which should be referenced here in order to give a more
complete and accurate picture of the Reich Farm situation. For
ease of reference in subsequent communications, I will number
the points in the following paragraphs.
1. Hazard Ranking Score.
Reich Farm appeared on the initial proposed NPL on
December 30, 1982, and the final NPL on September 8, 1983, due
to a hazard ranking score of 53.48. A review of the score
sheets by which Reich Farm was categorized, indicates that in
developing the score, no account was given to extensive
remedial activities performed by Union Carbide in 1972 and
1974. The preambles to the December 30, 1982 and September 8,
1983 Federal Register notices indicate that HRS scoring should
not be based on current conditions at the scored site, so as
not to discourage public agencies from taking early responses
lest such actions lower the Hazard Ranking Score for a site and
thus render a site ineligible for inclusion on the NPL.
Needless to say, that rationale is not consistent with the
facts in this case and makes very little sense with respect to
Reich Farm, as full remediation was performed by a private
party with full approval and agreement by the State of New
Jersey more than 10 years before even a proposed NPL was
published. While the Hazard Ranking Score may not bear on the
specific findings in the RIFS, it is worth noting that if Reich
Farm had been properly scored, it would never have appeared on
the NPL in the first place.
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2. Settlement of New Jersey Legal Action
In 1977, Union Carbide executed a Consent Order of
Settlement and Dismissal of a lawsuit brought by the New Jersey
Department of Environmental Protection (DEP) to require Union
Carbide to abate alleged conditions at Reich .Farm. In
settlement, Union Carbide agreed to reimburse the State $60,000
for future costs incurred for the purposes of "investigation,
sampling and, if New Jersey deems necessary, purifying or
otherwise treating the groundwater in, o.r in the vicinity of,
Dover Township, Ocean County, New Jersey, or taking such other
related actions deemed by New Jersey to be necessary for the
protection of the groundwater in said vicinity, including but
not limited to the drilling of wells, the pumping of
groundwater, the tracing of the movement of groundwater or of
substances in groundwater, and the filtering or treating of
groundwater in any manner, in said vicinity." We do not know
the results of New Jersey's sampling which may have been done
at the Site, nor do we know the extent of any further
groundwater remediation which the State may have undertaken at
the Site. This information may be relevant to the causes of
some of the findings in the RIFS. In addition, there could
even be some question as to the effects of any of the
activities which may have been performed by the State at the
Site. We know that the State was fully informed and involved
in the Union Carbide remedial activities in the 1970's, and yet
the RIFS background sections appear to ascribe virtually all
responsibility to Union Carbide. I have enclosed a copy of the
settlement document.
3. Additional Potentially Responsible Parties.
We have been advised that the RIFS and PRAP were forwarded
to Union Carbide and the property owners (Mr. and Mrs. Reich).
We are unaware as to whether the hauler, Mr. Fernicola, has
been named a PRP. We also note that there are a construction
company and excavating company performing activities at the
Site, and we believe there may be other industrial
establishments nearby. Clearly a more complete investigation
should be performed by Region II for the purpose of
ascertaining whether these other entities may have some
responsibility at the Site. For example, we believe that
chlorinated solvents, xylenes and toluenes, which apparently
are of concern at the Site, could well have come from on-going
activities there. It could well be appropriate for such other
entities to review the RIFS and PRAP as possible PRPs. A review
of disposal practices by such entities by Region II seems
obviously to be in order for purposes of determining whether
all PRPs have been named.
- 3 -
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4. Nicolas Fernicola's Utilization of the Site. . "... .
. Apparently, Union Carbide has been named a PRP at the Site
due to CERCLA Section 107(a)(3), which ascribes liability to
"any person who by contract, agreement, or otherwise arranged
for disposal or treatment, or arranged with a transporter for
transport for disposal or treatment, of hazardous substances
owned or possessed by such person, by any other party or
entity, at any facility...". As stated above, we did not
arrange with Mr. Fernicola to dispose of materials at Reich
Farm, but rather at an approved site. In fact, one of Union
Carbide's representatives physically followed Mr. Fernicola
with the first shipment of drums from Bound Brook to confirm
that Mr. Fernicola was removing drums to the Dover Landfill.
Mr. Fernicola entered into a separate rental agreement with the
Reichs, unbeknownst to Union Carbide, for storage of materials
at the Site. Mr. Fernicola reportedly also disposed of wastes
at the site by emptying drums into trenches in violation of his
agreement with Union Carbide and perhaps in violation of his
agreement with the Reich family. It was never our intention to
have materials stored or disposed of at Reich Farm. Under the
terms of CERCLA, we seriously question the appropriateness of
our being named in this matter.
5. Cause and Effect
As developed in greater detail in our discussions below, we
believe the investigation of other possible sources of
contamination at the Site has been extremely limited. There is
some likelihood that a variety of sources other than Union
Carbide materials may have caused the current conditions. Of
particular interest is an affidavit prepared for use in the
1975 New Jersey DEP litigation, executed by the individual
assigned to supervise the DEP investigation of suspected
groundwater contamination near the Site. That affidavit,
attached hereto as signed by Mr. Steven H. Corwin, states at
paragraph 9 that Mr. Corwin never believed that "any
information collected by DEP employees prior to [his]
resignation on or about September 15, 1975, provides an
adequate basis for identifying the source of any contaminants
which may have entered the groundwater that flows beneath the
Pleasant Plains and adjacent areas of Dover Township. In
paragraph 10, Mr. Corwin continues, "In particular, I believe
that one cannot conclude from such information that certain
chemical wastes are the cause of any suspected contamination.
The chemical wastes to which I refer are those which may have
been obtained from the Bound Brook, N.J. facilities of Union
Carbide Corporation..." Thus, if anything, it appears that we
may be dealing with a question of area-wide contamination
rather than a problem attributable to the disposals of 1971.
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The purpose of the above historical review is simply to
reflect Union Carbide's belief that it is being miscast as
acquiescing to the dumping of wastes which have caused serious
concerns at the Site. The above historical discussion
indicates that Union Carbide as well as others were unwittingly
victimized, and that at least prior to the development of the
RIFS, there was serious question as to whether Reich Farm
should have been considered for investigation in the first
place. We believe a strong argument can be made that any
obligation of Union Carbide for further Site investigation and
remediation, if necessary, had been discharged via the DEP
settlement. Keeping this background discussion in mind, we
shall now proceed to a detailed review of the RIFS and PRAP.
II. RIFS and PRAP
CERCLA Section 113(k)(2)(B)(ii) provides that interested
persons be given a "reasonable opportunity to comment and
provide information regarding the [remedial action] plan." We
note that even given the three-day extension for commenting, we
have had approximately four weeks to digest reams of
information provided with your letter of August 22. During
this time period, we have had the benefit of utilizing the
services of Malcolm Pirnie, Inc., Environmental Engineering
Consultants, and yet, given the short time frame, neither we
nor-our consultants have been able to give the documents the
attention which they merit. It appears that the only reason
for this extremely short time period is the Region's arbitrary
deadline for executing a Record of -Decision (ROD) by the end of
September. Given the complexity of the RIFS and the large
expenditures of money called for in performing the remedial
action, we believe that.an additional several weeks are needed
for sufficient review. Also, as will be noted below, we have
not been given access to the initial sips pgj-fn'-tTuari hy MTTS
Corporation, whose findings undoubtedly bear on the PRAP. We
also note that any opportunity to compare potentially
conflicting data which, may have been generated by the
New Jersey DEP has been effectively lost due to the time
pressure to review the documents at hand. Thus, we believe the
dictates of Section 113(k) have been violated. Union Carbide
therefore reserves the right to deliver additional comments on
the package as further review is completed.
A. General Comments
The following general comments are based on a broad
overview of the RIFS and PRAP and are numbered sequentially for
ease of reference.
1. The remedial investigation is incomplete and
- 5 -
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inconsistent with EPA guidance documents in a variety of
respects (to be amplified in the "Remedial Investigation"
section below).
2. The documents reflect inadequate investigation of
current operations at the Site and their possible impact on
cont aminat i on.
3. The prior extensive cleanups by Union Carbide in
1972. and 1974 are given inadequate consideration and review in
the documents.
4. As described in the Background section of these
comments (see above), we do not believe that all interested
parties have been presented with these documents for review.
These additional parties could include the waste hauler as well
as any industrial concerns at the Site.
5. We note that alleged contamination at the Site
has had no measurable effect on any off-site water supply. We
believe greater emphasis should have been placed on this
critical point in the documents. We also note that a public
water supply is readily available to nearby water users who may
be even potentially impacted. On-site and nearby wells have
been closed due to area-wide groundwater contamination.
6. A review of the documents indicates that the
Endangerment Assessment incorrectly calculates the level of
contamination to be expected in the future and thus
overestimates the possible future risks which might be present
at the Site.
«
7. The Feasibility Study is incomplete and
inconsistent with EPA guidance documents (to be amplified in _
the "Feasibility Study" section below)-; —
8. In addition to the treatment technologies
described in the Feasibility Study and the PRAP, we believe
there are other treatment equivalents at lower cost levels
which are not considered or are prematurely eliminated without
sufficient reason.
9. The treatment technologies described in the
Feasibility Study do not adequately recognize potential
process, operating, design and construction problems which
could result in a significant underestimation of remediation
costs.
10. The Feasibility Study overestimates^the adequacy
and maintenance problems of the capping alternatives, resulting
in an overly conservative PRAP.
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11. The ARARs indicated for the compound specific and
action specific alternatives are inconsistent with Agency ARAR
guidance. Various items suggested as ARARs are either not
promulgated standards or are applied in the wrong manner (to be
amplified in the "ARARs" section below).
12. Cost calculations do not reflect the level of
worker protection which may be required at the Site, thus
underestimating remediation costs for some alternatives.
B. Remedial investigation (RI) - Detailed comments
1. Incomplete Data Base.
The information presented in the RI did not
constitute the full data base utilized by the Agency in
defining the scope of problems at the Site and the required
solutions. Specifically, the EPA has not provided the
preliminary RI performed by NUS, as well as other possibly
relevant data and documents. Only Ebasco's reports were
provided to Union Carbide. Data which may have been collected
by the New Jersey DEP as part of routine monitoring of the Toms
River Water Company or DEP's on-site monitoring pursuant to its
settlement with Union Carbide were not included with the
package and apparently were not considered, we believe it is
essential that Union Carbide and other interested persons
receive all relevant data in order to accomplish a thorough and
complete review of the issues presented in the RIFS and PRAP.
• »
2. Other Potential Contamiration Sources.
•
It appears that Region II has interpreted all of
the contamination at the Site as having been caused by the
unauthorized disposal of Union Carbide materials hy Mr.
-FernlccrTa". Absent a "comprehensive analysis of other possible
contamination sources, this conclusion cannot be supported.
Consideration must be given to potential sources such as septic
systems (regionally), on-site activities by tenants, and spills
in the vicinity of the Site. We believe a full listing of all
on-site uses occurring between the time of Union Carbide's
remediation activities in 1974 and the present, as well as
significant pre-1971 uses is required. Of interest, the RI
indicates that a construction company and excavating company
are both on site, and heavy traffic of large commercial
vehicles is noted (page 1-8). The RI further notes the
presence of a "gas pump", a "sump", a "decon pad", and a
variety of concrete pads in the areas where contamination is
present. The benzene, xylene and toluene which are present in
soils and groundwater at the site could well be the result of
gasoline use, while the chlorinated solvents at the Site are
— 7 ~
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more characteristic of equipment cleaning and maintenance than
of the Union Carbide materials allegedly at the Site. It does
not appear that a full review of all site spill records which
may reside in state and Federal files as well as in the files
of other occupants since 1974, has been undertaken. In short,
the RI is incomplete if a thorough search for other possible
sources of organic chemical contamination was not made.
3. Site History.
Insufficient attention has been spent on
evaluating the impact of Site activities since 1971. The
condition of the Site at 'the completion of the 1974 Union
Carbide remediation was apparently not researched in preparing
the RIFS and no mention of any search for data regarding
sampling at that time was included. While the RI mentions the
possibility of sewers at the Site, no comprehensive site trap
which shows utilities (sewer and water lines in particular) and
septic systems has been produced. A site map is required to
show the specific locations where drums which allegedly
contributed to the contamination were stored and handled, the
location of soil excavation in 1974 and other significant
activities since 1971.
4. Background Contamination.
Insufficient attention has been paid to defining
sources and concentrations of background contamination at the
Site and in the region. Such sources include septic tanks,
storm runoff from roads and parking areas, use of agricultural
chemicals, upgradient contamination sources and possibly other
activities. Current activity on the site (and nearby) could
influence the investigative results of NUS and Ebasco. We
note, for example that some contamination is reported outside
the study area and that some areas with reported soil
contamination have no accompanying groundwater contamination.
In 1975, wells upqradient of the Site were closed due to
area-wide contamination. The upgradient wells monitored in the
RI also have some contamination at levels exceeding some
on-site wells. The OEP Special Assistant who supervised the
investigation of suspected groundwater contamination in the
area was unable to conclude that there was any causal
relationship between the Union Carbide materials placed on the
Site and the suspected contamination (see attached affidavit).
The RI contains no reports of any monitoring which may have
been performed by the State .of New Jersey pursuant to its
settlement with Union Carbide alluded to earlier.
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.5. Comparison of 1986 and 1987 analytical data.
We note that major discrepancies exist between
chemical analyses of soil and groundvater samples taken in 1986
and 1987 by the two contractors. The RI concludes in part that
these differences in groundwater analyses are the result of the
movement of contamination in the intervening year. However,
soil analyses in areas which appear to be geographically
similar and at similar depths often are significantly
different, with the 1987 data being generally greater than the
1986 results. We submit that a far more likely explanation is
the difference in laboratories used by NUS and Ebasco. Another
possibility is additional contamination during the 1986 to 1987
time span. The RI does not include the raw laboratory data or
the QA/QC reports, and we are thus unable to make a direct
comparison between the labs. However, due to the significant
differences noted in the two sets of data, it is obviously a
mandatory step to have further sampling performed before
deciding on the need for selecting any of the remedial
alternatives in the PRAP.
6. Groundwater Flow Model.
Full review and evaluation of the groundwater
flow model cannot be accomplished without full details on the
model and the input data. Copies of calibration and
sensitivity runs are also needed for full evaluation.
7. Adequacy of Analytical Data.
Only two sets of water samples were collected
which provided different analytical results. As noted
previously, the two sets of soil samples provide significantly
different results for what appear to be similar locations and
depths. Additional samples should be collected and all field
and laboratory QA/QC requirements should be provided for
evaluation by interested persons.
8. Pumping Test.
Ebasco conducted a single pumping test consisting
of a step test followed by a constant rate test. The
transmissivity and storativity values from this test form the
basis of Ebasco's groundwater flow model and calculations.
These values represent the high range of actual values which
will differ at different locations around the Site. The data
plots show a wide scatter of data points and relatively small
water level drawdown. Under these conditions, water level
changes due to other causes could be significant. There was no
indication that these other causes were considered in the
- 9 -
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analyses. In order to adequately evaluate the validity of the
pump tests and other items dependent on the aquifer
coefficients, more details on the tests and analyses are
required.
C. The Endangerment Assessment (EA) - Detailed Comments.
1. Steady State Groundvater Contaminant
Concentrations.
Ebasco has projected steady state concentrations
of contaminants in groundwater based on maximum concentrations
of the contaminants detected in the soil divided by the
distribution constant (Kd). Union Carbide believes this does
not represent a realistic approach to estimating future
groundwater contamination for several reasons. The methodology
utilized by Ebasco is ultraconservative and does not provide a
realistic estimate of the material which would actually flow
from the vadose zone to the aquifer. Once at the aquifer,
dilution would be significant in the Cohansey system. In
addition, the Ebasco estimates consider only the maximum soil
concentrations and do not consider mean or no contamination
areas in evaluating aquifer recharge from the Site. Other
factors of major importance which reduce contaminant
concentration over time are neglected as well, including
biodegradation and dispersion. Also, estimated groundwater
concentrations of chlorobenzene, ethylbenzene, toluene and
styrene are approximately one order of magnitude greater than
the maximum soil concentration, which is an unrealistic
estimate and not confirmed by actual field data. A simple
laboratory extraction test to determine the leachability of ..
contaminants from the soil would be far more meaningful than
the arbitrary application of an abstract formula.
0
2. Calculation of Risks.
The calculations of carcinogenic and
noncarcinogenic life risks assume an infinite source of
contamination which will leach into the groundwater over a
period of years while analyses indicate only limited zones, of
contamination with much of the area having no soil
contamination. The calculation of lifetime cancer risks from
the ingestion of contaminated groundwater is then based on the
maximum groundwater contaminant concentrations and projected
concentration of contaminants based on soil concentrations. As
discussed above, these concentrations are extremely
conservative representing at the most very small areas of the
highest contamination in the vadose zone and are much higher
than would actually be observed in the restricted Cohansey
aquifer and even more conservative as compared to the Kirkwood
- 10 -
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usable aquifer at the Site. The inevitable result is an
overestimation of potential risks which drives the need for any
soil or groundvater remediation. We note that the calculations
on page 5-8 suggest that chlorobenzene should be found in the
groundvater now while the RI found no chlorobenzene at all.
Thus, there are obviously significant questions regarding the
validity of the calculations; further evaluation is certainly
indicated.
3. Calculation of Mean Groundvater Concentrations.
The calculation of mean and geometric mean
concentrations of contaminants in groundwater resulting from
soil contamination utilized only detected values of
contaminants in soil. This calculation is, again, overly
conservative based on the relatively low frequency of detection
of the six contaminants of concern in the groundwater. The
frequency of detection ranged from 0 to 41% for these
contaminants. A far more realistic picture of risk would be
presented by using the detection limit of the compound as the
low end of the range and including all analyzed samples in the
calculation of mean and geometric mean values. Estimation of
steady state groundwater concentrations should be calculated
using mean soil concentrations and should include areas of the
Site where no contamination was detected at the minimum
detection limit. Processes such as natural dilution as
discussed above should also be accounted for to allow for a
conservative but more realistic impact on the aquifer.
4. Ingestion of Groundwater - Carcinogenic Effects.
The EA calculates the risk from ingestion of
water containing BEHP based on the maximum detected groundwater
concentration. This value of 2,200 mg/1 is almost twice that
of the compound's solubility (1300 mg/1). While the report
acknowledges that this result—is--anomal-eus,- no correction has—
been made on the risk tables and a false, higher risk is
presented.
5. Dilution of Contaminant Concentrations in the
Aquifer.
Dilution of contaminants in the groundwater is
not accounted for in the contaminant fate and risk
calculations. With net recharge of approximately 16 inches per
year in the area,, significant dilution on any water which
percolates through the contaminated areas of the Site in the
Cohansey water table aquifer would be seen. The dilution would
result in lowered groundwater concentrations at the point of
potential exposure.
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D. Feasibility Study (FS) - Detailed Comments.
1. Interaction Between Remediation of Groundvater
- ' and Soil.
The FS separately evaluates the need to remediate
soil and the need to remediate groundvater. Each of the
alternatives proposed for one medium will have an impact on the
need for and the effectiveness of the remediation of .the other
medium. For example, the pump, treat, and rein ject ion
alternatives for groundvater will remove a significant amount
of the reported contamination from the vadose zone soil column
depending on the selected site of the reinjection. The
groundvater collection system would also capture any
contaminants that escape the soil column .during the 10 years of
operation. Given the fact that the volume of contaminated soil
is small, the impact of the natural flushing action vhich vill
occur during the proposed groundvater remediation on the need
to remove contaminated soil should be evaluated.
Similarly, the removal of contaminated soil vill have a
major impact on the potential movement of contaminants to the
groundvater and result in the dispersion of' any remaining plume
vhich may exist. Since the rationale for the groundvater
remediation is the possible use of the groundvater as a source
of potable vater in the future, the evaluation of the
dispersion potential of any remaining plume absent a recharge
source is necessary in order to fully assess the need for the
combination of soil and groundvater remediation.
2. Pumping Alternative.
The FS indicates that pumping alternatives
consist of tvo Cohans ey Wells, each pumping 30 gpm.
Considering the data contained in the RI and other published
data on the formation, there is no assurance that
vould contain and capture the contaminated groundvater plume
Additional data beyond that available in the FS is needed to
select and cost an appropriate method of groundvater
remediation. For example, the basis for spacing of veils is
not defined and veils of different depth may be required to
adequately control the plume. The justification for the total
pumping rate of 60 gpm is not presented and the rate may be
incorrect. This alternative requires additional data
presentation and/or study for proper evaluation. The FS also
neglects the impact of such pumping on the region and on other
veils.
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3. Groundwater Injection.
The FS alternatives which include groundvater
pumping also consist of four upgradient injection wells. There
are no data or discussion of the potential problem of injecting
the water through injection wells. Problems which have
occurred at similar wells include aquifer blocking through
accumulation of particulates, biological growth and gas
locking. More wells or an alternative method of recharge may
be necessary. Further evaluation is required before the
technical feasibility of the injection concept can be
adequately reviewed.
4. UV - H 0 Oxidation.
_ 2 2 _
Typically, UV-H202 treatment has been used
mainly for the initial breakdown of organic contaminants at
high concentrations. Treatment of low levels of organic
contaminants as have been detected at the Site in order to
reach the objective levels has not been well documented. Thus,
the effectiveness of this treatment alternative for the site
specific conditions encountered is highly questionable.
.*
5. Excavation of Contaminated Soil.
The technical evaluation of the soil excavation
alternatives is incomplete for several reasons. For example,
consideration is not given to the health hazards associated
with the excavation. Organic contamination levels detected in
the soil could result in volatilization when exposed to the
atmosphere. Neighborhood exposures,- worker protection, and the
associated costs for working under "Level B" conditions are not
accounted for in the FS. For example, the EA calculates risks
from the_inhalatj.on of jyolatile organic vappr«?
~ " "
_
^trenches in~T:Tie soTT." "Very high risk numbers are projected for
tetrachloroethene. The validity of these calculations is
highly questionable due to the low levels for most tetrachloro-
ethene analyses in soil. Also, this risk does not exist unless
trenching is taking place. However, if accurate, it points to
a need for concern which is not raised in the FS discussion of
excavation alternatives.
In addition, the FS does not consider the mechanical
constraints associated with excavating Cohans ey sand to a depth
of 30 feet. The Cohans ey sand is a loose, uncohesive soil
which when excavated will tend to cave, resulting in the need
for significantly larger excavation areas than indicated or for
shoring while excavating. These items are major considerations
and are not accounted for in the cost analysis.
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6. Vapor Phase Treatment.
. Ebasco assumes that operation of the air stripper
will not require vapor phase treatment since emission levels
will be within federal and state requirements. There has been
no modeling done to confirm this conclusion and consideration
has not been given to the proximity of residences to the site.
Further evaluation of air emissions are required to evaluate
this treatment option. Public concern plus a significant
increase in the cost of this alternative will result if vapor
phase carbon treatment is necessary.
7. Enhanced Volatilization.
The historical track record of the effectiveness
of the enhanced volatilization treatment alternative is not
evaluated in the FS. The costs associated with predesign
testing and development of this technology must be included in
the cost analysis.
8. Grout Curtain.
Ebasco's soil remediation alternative S-2
recommends construction of a grout curtain surrounding the
contaminated soil and extending from the surface to the water
table. The need for the. grout curtain is plainly not
justified. As water movement in the vadose zone would be
chiefly vertical, the grout curtain would not contribute to
isolating the contaminated soil from downward percolating water
and should be eliminated from the alternative altogether.
Elimination of the grout curtain significantly decreases the
cost-of alternative S-2 .with no decrease in effectiveness.
E. Premature Elimination of Other Viable Technologies.
1. Capping of Contaminated Soil Areas.
Full evaluation of all available capping
alternatives is not given in the FS. While it is realized that
maintenance will be required on any cap, this should not be a
limiting factor in the selection of a capping alternative. The
major purpose of the cap in the alternatives discussed is to
limit the amount of rainfall and runoff which will percolate
into the aquifer. The EA clearly indicates no exposure
pathways resulting from contact with the waste and does not
justify the need for a RCRA style cap. RCRA cap specifications
would not be relevant and appropriate. Therefore, a less
stringent cap designed primarily to enhance runoff will
accomplish the objectives of limiting percolation. Significant
cost savings can be realized from an asphalt or a concrete cap
- 14 -
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which will provide the same effectiveness as a multilayer cap
with no decrease in effectiveness.
2. Off-Site Disposal.
Adequate consideration has not been given to the
disposal of contaminated soils off site in an off-site
hazardous or non-hazardous waste landfill. The low levels of
contaminants detected in the majority of the soil may be
amenable to this method of disposal in a properly designed
landfill. An analysis of the wastes which were placed on the
Site and the characterization of the soils is required to
evaluate whether hazardous waste regulations or land ban
provisions apply to the waste. Recent RCRA regulations clearly
provide a mechanism for disposal of hazardous materials from
CERCLA sites in landfills. (See also section on ARARs.)
3. Groundwater Discharge Alternatives.
Ebasco did not fully evaluate the alternatives
for discharge of pumped groundwater. Full consideration should
have been given to the direct discharge of treated water to the
Toms River rather than reinjection into the aquifer.
4. Groundwater Treatment Alternatives.
Ebasco prematurely deleted and did not fully
evaluate treatment of contaminated groundwater at a publicly
owned treatment works (POTW). Interference by the organic
contaminants in the groundwater with activated sludge aeration
processes at a POTW is extremely unlikely given the very low •
concentrations detected.and the significant dilution that would
occur before the groundwater reaches the POTW. This
alternative certainly merits further study.
F. Improper Costing.
1. Carbon Adsorption Costs.
The capital costs for carbon adsorption do not
include items such as initial carbon, piping, electrical and
other items required to establish this technology. On the
basis of contamination levels and the flow rate given in the FS
we estimate that the costs for carbon adsorption contained in
the FS are approximately 50% lower than projected actual costs.
2. Extent of Soil Contamination.
The Study did not bound the areas of soil
contamination. Therefore the amount of soil to be removed
- 15 -
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under the excavation alternatives and associated excavation,
treatment, or disposal costs cannot properly be estimated. A
contingency amount is required to be used in the cost estimates
to reflect this uncertainty.
G. ARARs-Inappropriate Selection of ARARs in the FS.
1. New Jersey Soil Cleanup Standards
The section on ARARs does not adequately separate
the various types of ARARs and correctly evaluate the need for
compliance. As an example, the New Jersey Soil Cleanup
Standards quoted are npt promulgated standards but, as noted in
the FS, are Guidelines to be used in establishing standards for
ECRA cleanups when no other criteria are available. These
"Standards" serve as a "Red Flag" for further attention to
determine whether additional risk assessment is appropriate for
the site to establish more appropriate soil cleanup standards.
In general, these surrogate levels are not cleanup numbers. In
fact, since this Site is being handled as a CERCLA site, a more
complete risk assessment has already been completed and, once
the previously described flaws are corrected to evaluate the
reasonable risks to the groundwater, would serve as a much more
appropriate standard than an arbitrarily selected and
non-promulgated "Red Flag".
2. SDWA Maximum Contaminant Levels
»
MCL's set under the Safe Drinking Water Act have
been suggested as ARARs for water quality. The use of MCL's
and the point of application of the criteria at this Site
requires significant discussion. The MCL is only legally
applicable for public drinking water supplies as described in
the Act. The closest point of such possible application is the
TRWC well system which the RI concluded was not currently
impacted by the site. The RI indicated that the TRWC might at
some time in the future be impacted although the magnitude of
the impact was not correctly evaluated to consider realistic
conditions and current groundwater conditions at the Site.
Application of the MCL's to the TRWC using realistic conditions
of exposure would provide a use of the MCL's consistent with
EPA guidance. The application of MCL's in the area of the Site
is not consistent with the Guidance because the groundwater in
the area of the Site is subject to a ban on use due to alleged
area-wide contamination. Effective administrative controls are
in place. The contamination source which is responsible for
the groundwater controls has npt been specifically identified.
With the groundwater use restriction in place the area should
be classified as a Class III aquifer and MCL's are neither
applicable nor relevant and appropriate standards.
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3. Federal Water Quality Criteria
Federal Water Quality Criteria are not
appropriate as ARARs since there is no release to a surface
water. In the context of this Site, these criteria are simply
irrelevant.
4. RCRA Requirements
Several references are made to RCRA type
requirements as ARARs. In particular, RCRA land ban
requirements are mentioned as ARARs. Recent RCRA regulations
provide a specific exemption from RCRA land bans for
contaminated soil and debris from CERCLA actions until 1990.
RCRA landfill capping requirements are not applicable since the
Site is not a landfill and are not relevant and appropriate
since the primary purpose of a cap would be only to limit
percolation.
III. PRAP
Given the information provided in the August 22nd
package, we seriously question whether remediation beyond the
no-action alternative is justifiable at Reich Farm. As noted
in the PRAP summary section, a selected remedy must be
protective of human health and the environment. We submit that
the Site meets this very standard today. It is only by using
the overly conservative assumptions described earlier that one
can conclude otherwise.. Even the core notion of separate
groundwater and soil remediation programs makes little sense .
when we are required to assume that remediation of one medium
will'have absolutely no .effect on remediation of the other.
The cleanup levels described in the PRAP (and the FS) are
based on a mix of the ultraconservative-Endaageraent Assessment
and ARARs that are of questionable validity. As described in
the ARARs section, the standards chosen are simply
inappropriate for this Site.
We note that there is continued reference in the PRAP to
protection of the public through access restriction and
prevention of well contamination. As discussed above, the
nearby wells are sealed under an effective administrative
control due to area-wide contamination, and a public water
supply is always available if needed. The RIFS itself
indicates that there is no danger from physical contact with
the soil at the Site.
The comments which we provided in the FS discussion are of
course applicable to the discussion of cleanup alternatives in
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the PRAP. We only wish to reiterate here that the information
supplied to date is wholly unconvincing as to the need for
greater protection of health, safety and the environment at
Reich Farm.
IV. SUMMARY AND CONCLUSION
Based on the above discussion, we believe the PRAP is
driven by an incomplete and overly conservative RIFS..
Specifically, a significant amount of work is required in the
areas of risk assessment and endangerment assessment before a
meaningful PRAP can be developed. We would be most interested
in discussing with Region II our thoughts as to how specific
sections of the RIFS could be supplemented, along with the
possibility of private funding and performance of required
analyses.
Given the amount of work which remains to be done as well
as the fact that review time has been severely and arbitrarily
limited, it is premature to issue a ROD at the present time.
However, if Region II believes that the ROD is mandated in the
time frame that has been discussed, we implore the Agency to
issue a ROD that will permit wide latitude in developing
appropriate and adequately protective standards. We frankly do
not see how a ROD could be issued with the specific cleanup
levels required by the PRAP in accordance with the FS at the
present time. We would be most interested in working with the
Agency in developing appropriate standards based on a
conservative but realistic set of assumptions. As you know, we
have been unsuccessful in our efforts at arranging a meeting '
with Region II to discuss the issues described above. We
remain hopeful that such a meeting can be held in the near
future.
If there are any questions or comments on any of the above,
please call the undersigned at 203-794-6225. —=
Very truly yours,
Gerald E. Klein
Environmental Counsel
GEK/jem
cc: J.C. Hovious
Joseph McVeigh, Esq.
Region II, Office of Regional Counsel
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-3-
2. Other Potential Contamination Sources
The nature of the contamination at the site is consist-
ent with the wastes which were found there in 1971. The
absence of significant contamination in the surface
soils on-site reflects the previous cleanup activities
undertaken by Union Carbide. The fact that significant
soil contamination was only found at depths of greater
than ten feet indicates than no new contamination (post
1974) has been introduced at the site. A preliminary
investigation of current site activities does not
indicate that hazardous substances are being disposed
of on-site. At this time, EPA has no evidence that any
wastes were disposed after the 1974 cleanup.
As part of the pre-RI/FS activities, EPA and its contrac-
tors attempted to locate all historical documents pertaining
to previous site activities and the condition of the site
following the 1974 cleanup. The information which was
available is presented in Section 1 of the Supplemental
Remedial Investigation report. A map detailing the
locations of utilities and septic systems was not provided
in the Supplemental Remedial Investigation report, but
will be generated, if necessary. A map which indicates
the location of the drum staging and trenching areas is
provided in the report. This map is based on conversations
with persons who were present on the site at the time of.
the cleanup activities as well as aerial photographs
taken during this period.
4. Background Contamination
The purpose of the remedial investigations conducted by
EPA and its contractors was to define the nature and
extent of contamination at Reich Farm. As previously
stated, the disposal practices of the current site occu-
pants have been monitored in the past and will continue
to be monitored in the future. Please note that the
Reich Farm study area encompassed approximately 15 acres
and no contamination was found outside of this area.
With regard to your concern about soil contamination with
no accompanying ground water contamination, EPA believes
that some of the pollutants in the soil have not migrated
down as far as the water table. EPA sampled monitoring
wells upgradient of the site during both site investiga-
tions. No compounds which are considered contaminants of
concern for Reich Farm (the remedial action for the site
will address the removal of all contaminants of concern)
were detected in these wells.
-------
The above indicates that the source of the contamination
found at Reich Farm is not located upgradient of the
site. A validated data base could not be generated from
the ground water data collected in 1974 and/ therefore,
this information was not incorporated into the RI/FS
evaluation. As stated previously, EPA is unaware of any
data collected at the site by NJDEP following the cleanup
conducted by Union Carbide in 1974.
5. Comparison of 1986 and 1987 Analytical Data
The contamination at the site was a result of numerous
discreet events (material leaks from drums and random
discharges into trenches) that may have occurred at
different times. The locations of soil contamination
were consistent with the areas where drums were stored
and trench wastes were disposed. The data collected
during the remedial investigations was subjected to a
full quality assurance and quality control (QA/QC)
evaluation. All data which was not validated through
the QA/QC process was deleted from the Remedial Invest-
igation report and not used as the basis for any con-
clusions involving the level of contamination at the
site. Additional soil and ground water sampling is an
integral part of the site remedy. This sampling will
further delineate those areas of the soil and ground
water which require remediation.
6 • Gjoundwater_Flpw Model
The primary parameters in calibrating the model were the
hydraulic conductivity and average annual infiltration
rate of rainwater. As explained~in Appendix K of the RI
report, the best (i.e. final) values of these parameters
were 133 feet/day and 19 inches/year, respectively. These
values could accurately predict the groundwater elevations
measured at the Reich Farm site. Since they are extremely
close to the accepted values, and it was not the intent
of the study to design a pumping system, additional
sensitivity studies were not performed. The computer
outputs from the calibration runs can be made available.
7. Adequacy of Analytical Data
• * * rf— •— • &-^ •• • *•> • • ^^—m • • • • _ «» ^ • • ^
See response to comment 5.
8 .
No localized effects from cyclical pumping were determined,
either from pumping records or from water level measurements
The pumping test was conducted during a very cold period
-------
-5-
with frozen ground and no ground water recharge. These
conditions caused a slight water table decline during the
brief pumping period. From measurements taken before
pumping, during pumping, and during and at the end of the
recovery period, the decline should have produced little
error in the transmissivity (T) and storage (S) calcula-
tions. The T and S values are considered to be consistent.
C. The Endangerment Assessment (EA) - Detailed Comments
1. Steady State Groundwater Contaminant Concentrations
The computation of steady state conditions based on
maximum soil concentrations and Kd values were required
to indicate the maximum undiluted concentrations which
contaminants presently in the soil can attain in the
ground water. These values were then used in the
Endangerment Assessment to provide the most conservative
estimate of the risk that could result if this migration
was to occur and if the ground water at the site was then
ingested. The most conservative estimate of risk is a
mandate of any risk assessment performed for a Superfund
site in order to select a remedy which is highly protective
of human health.
2. Calculatign_pf_Risks
As stated above, the methods used to quantify the risks
associated with a Superfund site are required to be
conservative. Note that it is not necessary tfrafc an
infinite source of j* contaminant be present to produce a
health risk over a lifetime; however, the amount must be
sufficient in quantity to allow leaching into the ground
water over an extended period of time. In addition, the
calculations on page 5-8 of the Supplemental Remedial
Investigation report do not indicate that chlorobenze
should be presently found in the ground water. The time
required to reach the water table was based on the depth
at which the contaminant is currently found in the soil;
this time period is calculated from the present and not
from the time the dumping occured.
3. Calculation of Mean Groundwater Concentrations
See comments 1 and 2.
4. Ingestion of Groundwater - Carcinogenic Effects
Although the level of BEHP in one ground water sample
was almost twice that of its solubility, this value must
be used in the risk assessment since it was not rejected
-------
-6-
during the QA/QC review. Note that this value was consid-
ered an anamoly and it was not used in the determining the
remedial objectives for the cleanup at the site. Additional
sampling will be performed as part of the site remedy to
determine the true magnitude of BEHP contamination in the
ground water.
5. Dilution of Contaminant Concentrations in the Aquifer
EPA does not rely on dilution of contamination to achieve
desired concentrations. Rather, when conducting remedial
actions at Superfund sites, policy dictates that ground
water at the point of discharge be cleaned up to levels
which are considered safe for drinking purposes.
D. Feasibility Study (FS) - Detailed Comments
1' j"tgragtion_Between Remediation of Groundwater and Soil
The ground water extracted from the contaminant plume will
be treated and injected upgradient of the site and into
the saturated zone. This is intended to accelerate the
flushing of the saturated zone. The flushing of unsaturated
soil would be from the mounding expected in the vicinity
upgradient of the site. This unsaturated soil in not
within the dumping and trenching areas and not believed to
be contaminated. If the mounding extends into the dumping
and trenching areas, then some flushing of contaminants
frpm the" soil would occur.
The Feasibility Study report noted (Section 4.2.2.2) that
if the soil is remediated, the length of time for ground
water—treatment—aight—be -expected Lo be on Lite order ef 3—
to 4 years instead of the 11 years which was presented as
the time needed to fully implement this alternative.
2. Pumping Alternatives
The pumping alternative is based on the limited amount of
data available. It is fully intended to collect additional
data prior to implementing the ground water cleanup. A
refinement of the pumping rate and the spacing of the
wells would be performed during the detailed design of
the system. The 60 gallons per minute (gpm) rate was
determined to be sufficient to capture the measured plume
and not impact the aquifer. The pumping might have some
impact on residential walls in the immediate vicinity of
the site; however, all of the residential wells near the
site have been closed. The computations used by Ebasco
to estimate the pumping rate are proprietary and are not
part of the FS report which is a public document.
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-7-
3. Groundwater Injection
The use of four reinjection wells is expected to prevent
aquifer blocking. The pumping wells should be properly
developed to minimize any particulates in the treated
: water. The carbon beds used for each treatment alternative
can be expected to collect trace particles present in the
water. Biological growth and gas locking are not consider-
ed to be of concern for the low flow rates proposed per
well.
4. UV-Peroxide Oxidation
Vendor tests have been performed with the compounds
prevalent at the Reich Farm site. At the concentration
levels found, the residence times selected are expected to
react 95 to 100 percent of the compounds in the ground
water.
5. Excavation of Contaminated Soil
Level B protection is not expected to be required during
any of the excavation activities. Even if Level B is
required during excavation and treatment of a number of
"hot spots", it would not significantly change the cost
estimate of the soil remediation which EPA policy requires
to'be within a range of plus 50 percent to minus 35
percent of the true cost.
The discussion of the soil alternatives points to the
need for additional samples in the area surrounding "hot
spots" to better define the estimated extent of soil to
be excavated and remediated. During the design stage,
with the additional data available, a better prediction
of the level of protection needed will be determined.
The cost estimate for excavation activities was specific
to the type of soil found on-site.
6. Vapor Phase Treatment
Even if the volatile compounds in the ground water were
200 parts per billion (ppb) (more than double the mean
value), at a treatment rate of 60 gpm and assuming 100
percent removal in the air stripper, the organic emissions
would be 0.006 pounds/hour which is far below the New
Jersey standard of 0.1 pounds/hour.
7. Enhanced_Volat i_li zation
The enhanced volatilization unit should have no difficulty
in removing the volatile compounds in the soil based on
its performance at other sites.
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8. Grout Curtain
A grout curtain for enclosing each of the contaminated
areas was considered to prevent any potential horizontal
migration of water* The potential for horizontal migration
exists because of the clay lenses found onsite. Once the
boundries of the contaminated areas are more precisely
defined and if it was determined that no clay lenses were
present in these locations, the need for the grout curtain
could be "evaluated.
E> Premature Elimination of Other Viable Technologies
1. Capping of Contaminated Soil Areas
The type of cap evaluated took into account the heavy
truck traffic that occurs at the site. An asphalt or
concrete cap would require more inspection and repair.
In view of the relatively small size of the areas to be
capped, the cap described in the FS report is considered
a cost-effective part of a permanent remedy.
2- Off-Site Disposal
The Superfund Amendments and Reauthorization Act emphasizes
permanent solutions and alternate treatment technologies
to the maximum extent practicable. Landfilling is the
least favored approach for dealing with site contamination
problems. Since treatment is .viable for the contaminated
soils, landfilling was not seriously considered.
3. Groundwater Discharge Alternatives
Discharge of the ground water to the Toms River would
have been technically more difficult than reinjection
because of the distance between the river and the site.
In addition, the local community has a history of being
strongly against this type of disposal.
4. Groundwater Treatment Alternatives
There are no publicly owned treatment works presently
located in the area of the Reich Farm site.
F. Improper Costing
1. Carbon Adsorption Costs
The capital cost items do include the carbon and piping
and were based on prices provided by a vendor. Automatic
valves are not included, therefore, electrical costs
should not be incurred.
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2. Extent of Soil Contamination "
The assumed sizes of the areas of contamination were
believed to be conservative based on the significant
differences in the contamination found at nearby or
colocated borings. Therefore, EPA does not believe
that an additional contingency is necessary.
6. ARARs - Inappropriate Selection of ARARs in the FS
1. New Jersey Soil Cleanup Standards
EPA does not consider the New Jersey Soil Action Levels
to be ARARs (applicable or relevant and appropriate re-
quirements); however, in the absence of federal soil
cleanup standards, they are guidelines to be considered
in establishing cleanup objectives. The risk assessment
conducted for Reich Farm indicated that the contaminated
soils have a potential to cause a health risk if they
migrate into the ground water. Thus, we intend to clean
up the contaminated soils at Reich Farm to meet the New
Jersey Soil Action Levels and believe that this represents
a conservative approach to ensure adequate protection of
human health and the environment.
2. SDWA Maximum Contaminant^ Levels
The Kirkwood-Cohansey aquifer system underlying the Reich
Farm site is classified as a Class I (drinking water)
aquifer; therefore, the New Jersey MCLs are considered
relevant and appropriate as cleanup standards for the
ground water.
3- Federal Water Quality Criteria
These criteria were not used as a remedial objective for
cleanup of Reich Farm.
4* RCRA Requirements
Land ban regulations and capping requirements under the
Resource Conservation and Recovery Act were not used as
a criteria for evaluating the remedial alternatives.
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UNION CARBIDE COMMENTS
Reich Farm
A. General_Commenta
1. This comment will be addressed in the response to the
"Remedial Investigation" section.
2. EPA has monitored the disposal activities of the
companies which currently occupy the site, and will
continue to do so. The nature of the contamination at
the Reich Farm site, which was defined in the Supple-
mental Remedial Investigation report, is consistent
with the types of wastes found there in 1971. In
addition, the extent of contamination is representative
of residual wastes which remained at the site after
the two cleanup actions undertaken by Union Carbide
in 1972 and 1974.
3. EPA recognizes that Union Carbide performed cleanup
activities, which included drum and soil removal, at
the Reich Farm site in 1972 and 1974. These cleanups
are detailed in the "Site History" section of the
Supplemental Remedial Investigation report. They are
also represented by the data presented in this report
which indicates that the surface soils on-site are
relatively free of contamination.
4. This concern is not within the scope of the requested
comments on the Remedial Investigation and Feasibility
Study (RI/FS) and Proposed Remedial Action Plan (PRAP)
for the Reich Farm site.
5. Although the remedial investigations indicate that
private potable wells currently in use have not been
contaminated by the Reich Farm site, these wells may
become impacted in the future if no remedial action is
taken and contaminant migration is allowed to continue.
In addition, the public water supply wellfield located
downgradient of the site has shown low levels of tri-
chloroethene (TCE) above the Maximum Contaminant Level
(MCL) which the State of New Jersey has established
for this compound. Additional sampling is needed to
define the leading edge of the plume originating from
the site and to determine if Reich Farm is the source
of the TCE which has been detected at the municipal
wellfield. This sampling will be conducted during
design of the remedial action for the site.
6. This comment will be addressed in the response to the
detailed Endangerment Assessment comments.
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7. This comment will be addressed in the response to the
"Feasibility Study" section.
8. A number of treatment technologies were identified in
the feasibility study (FS) for consideration at Reich
Farm. The most promising technologies were assembled
into remedial alternatives and evaluated in the FS
report. With the exception of no action, the altern-
atives presented in the FS and PRAP the exception of no
action provide a balance among the nine criteria which
EPA uses to evaluate remedial actions. The alternatives
which were selected to remediate the soil and ground
water at Reich Farm provided the best balance between
the nine criteria, one of which is cost-effectiveness.
9. Process, operating, design and construction problems
which may be associated with a remedial alternative are
among the factors considered by EPA's contractor when
developing cost estimates in the feasibility study. In
addition, these cost estimates are generally based on
previous experience with the treatment technologies as
well as price quotes provided by vendors.
10. The adequacy of the containment alternative and the
problems associated with maintaining the containment
system were contributing factors in the decision not
to select this alternative as the remedy for the
contaminated soils on-site.
••,
11. This comment will be addressed in the response to the
"ARARs" section.
12. The degree of worker protection required for each alter-
native is considered when developing cost estimates.
B . Remedial Investigation (RI) - Detailed Comments
The Supplement Remedial Investigation report (Ebasco)
presented data from both the NUS and Ebasco site invest-
igations which were conducted in 1986 and 1987, respect-
ively. The conclusions drawn in the RI report on the
nature and extent of contamination at the site were based
solely upon this data and the alternatives evaluated in
the feasibility study were developed to address these
conclusions. In regard to data from the Toms River Water
Company (TRWC), EPA collected data from TRWC wells during
both the 1986 and 1987 remedial investigations. We
believe this data is sufficient to characterize the water
which this utility supplies. At this time, EPA is unaware
of the existence of any site data generated by the New
Jersey Department of Environmental Protection (NJDEP)
following the Union Carbide cleanup in 1974.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
20 FEDERAL PLAZA
NEW YORK. NEW YORK IO278
September 29, 1988
Gerald E. Klein
Environmental Counsel
Union Carbide Corporation
39 Old Ridgebury Road
Danbury, CT 06817-0001
Dear Mr. Klein:
This is in response to your letter of September 20, 1988,
in which you provided comments on the Reich Farm Remedial
Investigation, Feasibility Study, and Proposed Remedial
Action Plan for the Reich Farm Superfund site in Dover
Township, New Jersey.
Attached are the responses to the technical comments, noted
•General Comments", "Detailed Comments" and other technical
issues submitted to the Environmental Protection Agency.
Please be advised that our remedial contractor, Ebasco
Services, assisted us in the preparation of this reply.
Each response is numbered to correspond to the comment it
addresses.
Thank you for submitting your comments in a timely manner.—
-Now—that —the-pvblic—comment perio3~~is officially closed,
they will be included in the Responsiveness Summary section
of the Record of Decision for the Reich Farm site.
I hope that your concerns have been satifactorily addressed.
Sincerely yours,
Romona Pezzella^eroject Manager
Southern New Jejrjrey Remedial Action Section
Attachment
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