United Sates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R02-90/102
May 1990
Superfund
Record of
Woodland Route 532 Dump,
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-90/102
3. Recipient1 Accession No.
4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
Woodland Route 532 Dump, NJ
First Remedial Action
S. Report Date
05/16/90
7. Authors)
8. Performing Organization Rept No.
9. Performing Organization Name and Addreaa
10. Proiect/Taak/Work Unit No.
11. Contracted or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Limit: 200 words)
The 20-acre Woodland Route 532 Dump site is an abandoned hazardous waste dump in Woodland
Township, Burlington County, New Jersey. The site is being remediated concurrently with
another abandoned dump, the 12-acre Woodland Route 72 Dump site, located 3 miles from the
Route 532 site. Both sites are in the Pinelands Preservation Area District of New
Jersey. Several chemical manufacturing firms dumped chemicals and other wastes into
trenches and lagoons or burned the waste at the sites from the early 1950s to 1962. An
estimated total of 54,000 cubic yards (Route 72, 28,000 cubic yards; Route 532, 26,000
cubic yards) of surface material including surface soil, stream sediment, sludge, and
debris at the sites are contaminated with wastes including tarry substances and paint
residues. Furthermore, leaching from surface materials has resulted in the contamination
of 300,000 cubic yards (Route 72, 130,000 cubic yards; Route 532, 170,000 cubic yards) of
subsurface soil and ground water beneath both sites. Contaminated ground water
discharges to a cranberry bog and an adjacent bog reservoir. This Record of Decision
(ROD) addresses surface material and ground water remediation at both sites. A
subsequent ROD will address subsurface soil. The primary contaminants of concern
affecting the surface soil, sediment, sludge, debris, and ground water are VOCs including
benzene, toluene, TCE and xylenes; organics including PAHs, pesticides, and phenols;
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision - Woodland Route 532 Dump, NJ
First Remedial Action
Contaminated Media: surface soil, sediment, sludge, debris, gw
Key Contaminants: VOCs (benzene, toluene, TCE, xylenes), organics (PAHs, pesticides,
phenols), radionuclides (uranium and thorium series), metals (lead, chromium)
b. Identifieri/Open-Ended Terms
c. COSA71 Held/Group
18. Availability Statement
19. Security Claaa (This Report)
None
20. Security Claaa (This Page)
None
21. No. ofPagea
95
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL rOHM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/102
dodland Route 532 Dump, NJ
rst Remedial Action
Abstract (Continued)
radionuclides (e.g., uranium and thorium series); and metals including lead and
chromium.
The selected remedial action for this site includes excavation, further
characterization, and offsite disposal at a permitted facility of 54,000 cubic yards
(total from both sites) of contaminated surface soil, sediment, sludge, and debris;
offsite disposal of 19 cubic yards (total from both sites) of radiologically
contaminated surface materials including a drum of radioactive pellets; ground water
pumping and treatment with treatment to be determined during design (but anticipated to
include air stripping, metals removal, biological treatment, and advanced oxidation or
carbon adsorption) and reinjection of treated ground water; and ground and surface water
monitoring. The total estimated present worth cost for the concurrent remedial actions
at the Route 72 and Route 532 sites is $142,200,000, which includes an estimated present
worth O&M cost of $114,000,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Soil cleanup objectives have been based primarily on
State standards and background levels including total VOCs 1 mg/kg, total chromium 100
mg/kg, pesticides (DDT and metabolites) 10 mg/kg, and lead
250-1,000 mg/kg (based on State risk assessment). Ground water nondegradation remedial
goals are based on natural background levels for the Pine Barrens area including benzene
0.88 ug/1, pesticides (DDT and metabolites) 0.001 ug/1, toluene 1.2 ug/1, TCE 0.38 ug/1,
otal xylenes 1.0 ug/1, and phenol 0.15 ug/1.
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ROD FACT SHEET
SITES
Name: Woodland Township Route 72 and Route 532 Sites
Location: Burlington County, Chatsworth, New Jersey
EPA Jurisdiction: EPA Region 2
FIRST OPERABLE UNIT ROD
Signature: May 16, 1990
Surface Material Remedy:
Off-Site Disposal of Surface Materials
Capital Cost: $1,200,000
Operation and Maintenance Costs: $21,000,000
Present Worth: $22,200,000
Ground Water Remedy:
Air Stripping, Metals Removal, Biological Treatment,
Advanced Oxidation (1.9 mgd pumping rate)
Capital Cost: $27,000,000
Operation and Maintenance Costs: $93,000,000
Present Worth: $120,000,000
LEAD
Agency: NJDEP Remedial and Enforcement Leads
Primary USEPA Contact: Rick Robinson (212) 264-4425
Primary NJDEP Contact: Gerald Braun (609) 292-6709
Primary PRPs:
Rohm & Haas; 3M; Hercules, Inc.; SOHIO; Purex, Inc.;
Industrial Trucking Service Corporation
WASTE
Type: Metals, volatile organics, semi-volatile organics,
pesticides, and radiological
Medium: Drums, bulk waste, ground water and soils
Origin: Drums, bulk waste burial, lagoons and open pit
burning.
Surface Material Estimates:
Route 72 - 28,000 cubic yards
Route 532 - 26,000 cubic yards
Combined radiological waste - 19 cubic yards
Ground Water Plume Estimate:
Route 72 - 1.5 miles to 1.8 miles long and 70 feet to
120 feet deep.
Route 532 - 4000 feet long by 25 feet to 50 feet deep.
Plume discharges into a down-grad: er.t
cranberry bog.
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DECLARATION STATEMENT
RECORD OF DECISION
WOODLAND TOWNSHIP ROUTE 532 SITE
Site K*"e and Location
Woodland Township Route 532 Site, Burlington County, New Jersey.
Stateaent of Basis and Purpose
This decision document presents the remedial action for the
Woodland Township Route 532 hazardous waste disposal site in
Chatsworth, New Jersey, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent applicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision document explains the
factual and legal basis for selecting the remedy for this site.
The New Jersey Department of Environmental Protection concurs
with the selected remedy. The information supporting this
remedial action decision is contained in the administrative
record for the site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The remedial action described in this document is the first of
two planned operable units for the site. The remedy will be
designed and implemented together with the selected remedial
action for the nearby Woodland Township Route 72 site. This
first operable unit action will address the remediation of
contaminated surface materials, sediments and ground water at the
site. The contaminated subsurface soils will be the subject of a
future study and remedial action.
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The major components of the selected remedy for the first
operable unit include the following:
Surface Materials
Excavation and further characterization of 26,000 cubic yards
of contaminated surface materials and sediments (soil,
sludges, debris, etc.)/
Disposal of the excavated materials at a permitted off-site
facility,
Off-site disposal of an estimated 19 cubic yards (combined
total from the Route 72 and Route 532 sites) of radiologically
contaminated surface materials. This material includes a drum
containing radioactive pellets found at the Route 532 site.
Ground Water
Extraction of the contaminated ground water plume, estimated
to be 4,000 feet long, and 25 to 50 feet deep.
Treatment of the extracted ground water prior to reinjection.
The specific components of the treatment system will be
developed during the remedial design. The feasibility study
discussed treatment via air stripping, metals removal,
biological treatment, and advanced oxidation. Activated
carbon adsorption would be used as a contingency if the
advanced oxidation process is determined to be unsuitable.
Treatment of the ground water will continue for an estimated
30 years or until the remedial objectives are obtained.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technology to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
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The selected remedy provides a permanent solution for the surface
soils at the site and the underlying ground water. However,
because hazardous substances will remain in subsurface soils
above the health-based levels, this is an interim remedy. These
contaminated subsurface soils will be the subject of a subsequent
Record of Decision for the site.
/Constantine Siaamon-EristoJ
'Regional Administrator
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DECLARATION STATEMENT
RECORD OF DECISION
WOODLAND TOWNSHIP ROUTE 72 SITE
Site Name «»d Location
Woodland Township Route 72 Site, Burlington County, New Jersey.
Statement of Basis and Purpose
This decision document presents the remedial action for the
Woodland Township Route 72 in Chatsworth, New Jersey, which was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 as
amended by the Superfund Amendments and Reauthorization Act of
1986 and, to the extent applicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
document explains the factual and legal basis for selecting the
remedy for this site.
The New Jersey Department of Environmental Protection concurs
with the selected remedy. The information supporting this
remedial action decision is contained in the administrative
record for the site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The remedial action described in this document is the first of
two planned operable units for the site. The remedy will be
designed and implemented together with the selected remedial
action for the nearby Woodland Township Route 532 site. This
first operable unit action will address the remediation of
contaminated surface materials, sediments and ground water at the
site. The contaminated subsurface soils will be the subject of a
future study and remedial action.
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The major components of the selected remedy for the first
operable unit include the following:
Surface Materials
Excavation and further characterization of 28,000 cubic yards
of contaminated surface materials and sediments (soil,
sludges, debris, etc.)/
Disposal of the excavated materials at a permitted off-site
facility,
Off-site disposal of an estimated 19 cubic yards (combined
total from the Route 72 and Route 532 sites) of radiologically
contaminated surface materials. This material includes a drum
containing radioactive pellets found at the Route 532 site.
Ground Water
Extraction of the contaminated ground water plume, estimated
to be 1.5 to 1.8 miles long, and 70 to 120 feet deep.
Treatment of the extracted ground water prior to reinjection.
The specific components of the treatment system will be
developed during the remedial design. The feasibility study
discussed treatment via air stripping, metals removal,
biological treatment, and advanced oxidation. Activated
carbon adsorption would be used as a contingency if the
advanced oxidation process is determined to be unsuitable.
Treatment of the ground water will continue for an estimated
30 years or until the remedial objectives are obtained.
Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technology to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduce
toxicity, mobility, or volume as their principal element.
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The selected remedy provides a permanent solution for the surface
soils at the site and the underlying ground water. However,
because hazardous substances will remain in subsurface soils
above the health-based levels, this is an interim remedy. These
contaminated subsurface soils will be the subject of a subsequent
Record of Decision for the site.
?onstantine Sidamon-Eristoff
'Regional Administrator /
Dat
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DECISION SUMMARIES
WOODLAND TOWNSHIP ROUTE 532 AND ROUTE 72 SITES
RECORDS OF DECISION
SITE NAME. LOCATION. AND DESCRIPTION
The Woodland Township Route 532 site is approximately 20 acres in
size and is located on tax block 4210, lot 1 in Woodland
Township, Burlington County, New Jersey (Figure 1). The site is
at the end of an unpaved access road approximately 1/8 mile south
of Route 532. The unnamed site access road meets Route 532
approximately 1 1/8 miles west of the intersection of Route 532
and Route 72. Goodwater Run, an intermittent stream and Bayley
Road border the site to the east. An unpaved forest fire control
road runs along the southern edge of the site. The site is
situated within a "special agricultural area" of the Preservation
Area District of the New Jersey Pinelands. Active commercial
cranberry bogs are located approximately 1 mile west-southwest of
the site.
The Woodland Township Route 72 site is approximately 12 acres in
size and is located on tax block 5501, lot 15 and tax block 6301,
lot 1 in Woodland Township, Burlington County, New Jersey (Figure
1). The site is 1/4 mile south of Route 72 along Crawley Road.
Crawley Road is an unpaved road and is labeled as Sooey Road on
United States Geological Survey maps. Crawley Road meets Route
72 approximately 1 1/3 miles southeast of the intersection of
Route 532 and Route 72. Crawley Road bisects the site and
denotes the border between tax block 5501, lot 15 and tax block
6301, lot 1. Pope Branch, an intermittent stream, is located
approximately 500 feet to the north and 1,000 feet west of the
site. The site is situated in the Pinelands Preservation Area
District. A "special agricultural area" with active commercial
cranberry bogs is located approximately 1/2 mile northwest of the
site.
The sites are approximately 3 miles apart at an average elevation
of 125 feet above mean sea level. The Route 532 site has
approximately 20 feet of relief, while the Route 72 site has
roughly 10 feet of relief. Both sites are virtually devoid of
vegetation and are characterized by loose sandy soils. Isolated
areas of rusted and corroded drums, broken laboratory glassware,
and solidified or partially solidified organic sludge cover the
surface on both sites.
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Figure 1
Goneraf Location Map
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Both the Woodland 532 and 72 sites overlie the Cohansey and Kirk-
wood Aquifers. Of the two formations, the high-yielding Cohansey
Aquifer is the major source of potable water for the area and
also was impacted by the past disposal practices associated with
the sites. No continuous clay unit exists to prevent downward
migration of contaminants. In addition, the Woodland Township
sites are located in a regional recharge area for these aquifers.
The Cohansey Aquifer also provides the base flow of many regional
surface water bodies (e.g. streams, bogs). The New Jersey
Department of Environmental Protection (NJDEP) has designated the
Cohansey Sand in the vicinity of the sites as GW-1.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Route 532 Site
Early records indicate ownership of the Route 532 site by Francis
Estlow. In 1973, Estlow sold the property to Cohen, Weiss and
Krell. In 1976, Airtime, Inc. purchased the property and
subsequently sold it to its present owners, Joseph and Albert
Spitzer.
An aerial photograph from 1951 shows that a pine forest existed
in the study area prior to the beginning of disposal operations.
The exact date disposal began is unknown. It is estimated to
have begun between 1951 and 1956. The western half of the Route
532 site was organized into a series of bermed lagoons when
disposal began. A 1956 photo indicates these lagoons contained
black liquid waste. It was also evident from the photograph that
this waste was released along an on-site road and flowed toward a
depression.
By 1962, most of the disposal areas had been regraded. In a 1962
aerial photograph, new bull dozer scrape marks indicate that the
disposal area was being enlarged. The black liquid, previously
dumped on-site, had also breached the lagoon berm and was flowing
into the nearby pine forest. A second flow was observed
extending from the eastern border toward the path of Goodwater
Run.
A 1984 photograph indicates that the site has remained
essentially unchanged since 1962. Denuded areas can be observed
where the two liquid flows moved off site. Partially buried
drums are exposed on the downslope edge of former lagoons on the
western half of the site and the downslope edge of the former on-
site road. Partially buried drums and general refuse are piled
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along former on-site roads in the eastern half of the site. No
site controls were in place from 1962 to 1986. In 1986,
potentially responsible parties (PRPs) constructed a security
fence to restrict site access. Figure 2 presents a brief
chronology of the Route 532 site.
Route 72 Site
The Route 72 site was owned by Francis Estlow until 1957, when
the property was purchased by Rudolf Kraus. Rudolf and/or
Eleanor Kraus also owned Industrial Trucking Services
Corporation, the company that reportedly transported the waste
materials to the sites for disposal. Cohen, Weiss and Krell
purchased the property in April 1964. It is unclear from
Woodland Township records when the property was acquired by its
current owner, Airtime, Incorporated.
A 1951 aerial photograph of the site illustrates conditions prior
to the waste disposal operation. Probable concrete pads,
possible basement space, a utility building and a sidewalk can be
observed. An unpaved road connected the site to the perimeter
road of Coyle Airport. Crawley Road and a fire road north of the
site were also present.
A 1956 photograph of this site shows several trenches elongated
in an east-west direction in the northern third of the site. The
trenches were located on both sides of Crawley Road. The central
portion of the site was covered with general refuse and stained
soils. Small depressions containing standing liquid were evi nt
on the western half of the site. The southern portion of the
site west of Crawley Road contained a wide depression with
standing liquid in it. The southern portion of the site east of
Crawley Road contained several shallow trenches oriented along a
north-south axis.
The site layout has remained unchanged as seen in a 1962
photograph. However, the trenches were apparently deepened, and
those in the northern and southern portions of the site contained
a standing light-colored liquid.
A 1984 photograph indicates that the site has remained unchanged
since 1962. The outlines of trenches and depressions can be
observed. Drums, stained soils, and general refuse are
identifiable in the central portion of the site. Much of the
pine forest at the edge of the site has regenerated, while on-
site disposal areas remain unvegetated. This site was also
uncontrolled between 1962 and 1986. In 1986, PRPs constructed a
security fence to restrict site access. Figure 3 presents a
brief chronology of the Route 72 site.
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Bermed Lagoons with
Black Standing Liquid
(1956)
Sludge Flow
(1962)
Intermittent Drainage
(1956)
r Black Sludge
(1956)
Stained
Soils
(1952)
General
Reluse
(1962)
Sludge Flow)
(1962)
\ //
Bulldozer
Scrapings
(1962)
CDM
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Lighl Standing
Liquid (1962)
p Elongated Trenches
(1962)
Depression wilh
Black Standing Liquid
(1956)
General Refuse
(1956, 1962}
Standing Liquid
(1952)
Elongated Trenches
(1962)
No! to scale
COM
Ficure
^.' A1
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Enforcement History
The Route 532 and Route 72 sites were operated jointly as an
uncontrolled hazardous waste dump. The sites were used by
several chemical manufacturing firms from the early 1950s until
approximately 1962. During this time, Minnesota Mining and
Manufacturing (3M) Company, Rohm and Haas Company, Standard Oil
of Ohio, Incorporated (SOHIO), Hercules Incorporated, Manhattan
Soap Company (a subsidiary of Purex Industries, Incorporated),
and possibly other PRPs hired Industrial Trucking Services
Corporation (a subsidiary of Better Materials Corporation) to
dispose of chemicals and other wastes. The wastes were dumped
into trenches and lagoons or were burned. There is no knowledge
of which site was operated first, nor which site was closed
first.
The New Jersey Department of Environmental Protection was advised
of environmental problems at the sites by the Burlington County
Health Department in April 1979. The NJDEP conveyed the
information to the United States Environmental Protection Agency
(USEPA). At about the same time, a biologist investigating
endangered species for NJDEP also reported environmental problems
at the site.
The NJDEP issued a directive on March 4, 1985 to Rohm and Haas,
3M and Hercules and other companies identified as PRPs to arrange
for the investigation and remediation of the sites. On March 27,
1985, NJDEP entered into an Administrative Consent Order (AGO)
with Hercules, Incorporated to help pay for the investigative and
administrative costs. On July 6, 1987, NJDEP entered into a
similar AGO with 3M, and Rohm and Haas Company.
On January 2, 1990, NJDEP entered into an AGO with Hercules, 3M,
and Rohm and Haas. The purpose of this AGO was to compel the
PRPs to remove and incinerate liquids and sludges from isolated
locations on the sites' surfaces.
Prior Investigations
In December 1979, soil samples were collected by the PRPs1
consultant. Phenols, cresols, benzene and xylenes were
detected.
In September 1981, a field investigation report and a site
inspection form was submitted to USEPA Region II by its Field
Investigation Team (FIT) contractor. Monitoring wells were
installed and ground water samples were collected and analyzed.
Compounds detected in the ground water samples included chlorc-
benzene, 1,2-dichloroethane, ethylbenzene, tetrachloroethene,
benzene, naphthalene, toluene, pentachlorophenol, and bis (2-
ethylhexyl) phthalate.
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The NJDEP personnel visited the site on May 3, 1983, and
collected soil samples.for analyses. The results indicated the
presence of several volatile organics, polychlorinated biphenyls
(PCBs), polynuclear aromatic hydrocarbons (PAHs) and phthalates.
Inorganic substances identified in the soil samples included
arsenic, cadmium, chromium, copper, lead, nickel, silver and
zinc.
During March and July of 1985, the PRPs collected soil and waste
samples for analysis. Compounds identified in the soil and waste
samples included benzene, toluene, ethylbenzene and 1-2
dichloroethane.
In 1986, the PRPs erected a temporary 6 foot-high chain-link
fence around each site and undertook some minor erosion control
measures.
Both the Woodland Township sites were placed on the National
Priorities List during September 1983.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
On February 10, 1986, a public meeting was held to initiate the
remedial investigation and feasibility study (RI/FS) aimed at
determining the extent of contamination at these sites and at
identifying feasible remedial actions. The RI/FS was conducted
by the NJDEP. At the conclusion of the study process, on
July 26, 1989, the RI/FS documents were placed in repositories.
The Proposed Remedial Action Plan, along with a notice of the
availability of the RI/FS, were released to the public on
December 26, 1989. The documents and plan were made available to
the public in both the Administrative Record and at information
repositories maintained at the Woodland Township Municipal
Building, the Pinelands Commission office, at NJDEP's Trenton
office, and the USEPA's Region II New York City office.
The notice of availability was published in the Burlington County
Times on December 26, 1989. A public comment period was held
from December 26, 1989 to February 5, 1990. In addition, a
public meeting was held in Chatsworth, New Jersey on January 31,
1990. At this meeting, representatives from NJDEP and Camp
Dresser and McKee, the RI/FS contractor, answered questions about
the two sites and the remedial alternatives under consideration.
All responses to the comments received during this period are
included in the Responsiveness Summary, which is part of the
Record of Decision (ROD). These decision documents present the
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selected remedial actions for the Woodland Township Route 532 and
Route 72 sites, chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
(SARA) and, to the greatest extent practicable, the National
Contingency Plan (NCP). The remedial action decisions for these
sites are based on the Administrative Record.
Based on comments received at the January 31, 1990 public meeting
and during the public comment period, the local community, public
officials, the New Jersey Pinelands Commission, and several
interested companies generally support the agencies' preferred
alternatives. Public comment focused on issues related to
effects on commercial cranberry operations, ground water quality
and availability during the remediation, Township review of
documents, liability and reimbursement concerns, and specific
issues relating to various components of the selected remedies.
Detailed responses to these comments are contained in the
Responsiveness Summary.
SCOPE AND ROLE OF THE FIRST OPERABLE UNIT
As with many Superfund sites, the problems at the Woodland
Township Route 532 and Route 72 sites are complex. As a result,
the NJDEP and USEPA organized the remediation efforts into two
operable units.
Operable Unit One - The first operable unit will address the
remediation of 54,000 cubic yards of contaminated surface
materials from both sites. This operable unit will also
address the remediation of the contaminated ground water
plumes originating from each site and associated surface
water bodies.
The Route 532 contaminated ground water plume is estimated
to be 25 to 50 feet deep, 1,200 feet wide and 4,000 feet
long. This contaminated ground water plume is discharging
into a cranberry bog and bog reservoir. It is expected that
the contaminated cranberry bog and bog reservoir surface
water will be remediated as the Route 532 contaminated
ground water plume is removed.
Contaminated sediments of Goodwater Run will be remediated
as surface materials.
The Route 72 contaminated ground water plume is estimated to
be 70 to 120 feet deep, 1,200 feet wide and is 1.5 to 1.8
miles long.
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10
Operable Unit Two - The second operable unit will address
the remediation of contaminated subsurface soils.
The first operable unit addresses primary concerns about the
sites by remediating the contaminated surface materials and
contaminated ground water. Remediation of the surface materials
will eliminate the principal risks associated with direct contact
of these materials. Remediation of the ground water
contamination will stop the continued expansion of the
contaminant plume and begin the process of removing the
contamination from the ground water.
The second operable unit will address the remediation of
contaminated subsurface soils. This operable unit will reduce
and/or eliminate the principal risks caused by these soils which
act as a continued source of ground water quality deterioration.
The ROD for the second operable unit will be prepared after
additional testing and studies are completed.
SUMMARY OF SITE CHARACTERISTICS
The RI field activities were conducted in three phases from the
fall of 1985 through the,spring of 1988. Additional data
collection was completed during the fall of 1989 to address
potential public concerns.
The RI activities primarily consisted of sample collection and
analysis of soils, wastes, ground water, potable wells, air,
surface water, sediments, and cranberries. In addition to the
sample collection activities, various additional efforts were
conducted to characterize the sites. These activities included;
geophysical surveys, radiological surveys, treatability studies
for bioremediation of subsurface soils and ground water, soil gas
surveys, aquifer slug tests, borehole logging by split spoon
sampling, and soil head space screening.
Details of the RI activities are contained in the RI/FS reports.
A summary of the site characteristics is presented below and is
organized by the affected media.
Surface Materials. Subsurface Soils and Waste Definitions
For purposes of clarification, the site soils and wastes
characteristics were categorized into surface materials and
subsurface soils.
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11
Surface materials include waste materials and soils which were
directly contaminated by past waste disposal operations. The
surface materials are across most of the sites and extend to a
typical depth of 2 feet with a couple of isolated pockets
projecting to a depth of 5 feet (i.e., depressions).
Radiologically contaminated materials will be removed during this
operable unit. These materials include the radioactive drum
containers at the Route 532 site and radiologically contaminated
sources on or in the surface materials.
The subsurface soils are considered as the area of contamination
resulting from the leaching of some contaminants from the
overlying surface materials. The subsurface soil contamination
is across most of the sites and extends from below the surface
materials to the water table which is typically 12 feet below the
ground surface.
Surface Materials
At the Route 532 site, approximately 26,000 cubic yards of
contaminated surface materials are present. At the Route 72
site, there are approximately 28,000 cubic yards of contaminated
materials. A variety of surface materials exist at the sites.
These materials include: black tarry substances, rusted
fragments of metal drums, paint residues, broken glass, heavily
contaminated soils, and contamination caused by surface runoff
from the sites in Goodwater Run sediment.
Compounds detected and their respective maximum concentrations
include: lead (18,000 (parts per million) ppm); chromium (1,504
ppm); cresols (300 ppm); DDT and its metabolites (2,000 ppm); and
bis (2-ethylhexyl) phthalate (2,300 ppm).
Radionuclide contamination was also found in small isolated
locations at both sites. The estimated volume of this material
is less than 19 cubic yards for both sites. Principal
radionuclides identified and their respective maximum activities'
include: U-238 (1100 pico Curies per gram (pCi/g) wet); U-234
(1,000 pCi/g wet); Th-232 (4,500 pCi/g wet); Th-230 (700 pCi/g
wet); and Th-228 (3,600 pCi/g wet).
Samples for Resource Conservation and Recovery Act (RCRA)
characterization were collected from surface materials.
Analytical results indicated that the materials would not be
characterized as RCRA hazardous waste. Although the site wastes
are not currently identified as hazardous wastes, ongoing data
gathering may change this classification and subject the sites to
RCRA applicability.
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12
Subsurface Soils
At the Route 532 site, approximately 170,000 cubic yards of
contaminated subsurface soils are present. At the Route 72 site
there are approximately 130,000 cubic yards of contaminated
subsurface soils.
The subsurface materials contain a variety of water soluble
contaminants, and non-water soluble contaminants. The major
compounds identified along with their respective maximum
concentrations include: 1,2-dichloroethane (2,800 ppm); 1,1,2,2-
tetrachloroethane (360 ppm); benzene (150 ppm); chloroform (110
ppm); bis (2-chloroethyl) ether (2,500 ppm); bis (2-ethylhexyl)
phthalate (1,300 ppm); DDT and metabolites (134 ppm); styrene
(1,300 ppm); toluene (5,000 ppm); ethylbenzene (4,300 ppm); and
total xylenes (2,600 ppm).
Ground Water
A ground water contaminant plume originating at the Route 532
site is located at a depth between 25 feet and 50 feet and is
moving in a southwesterly direction at a rate of 2.1 feet per
day. The plume is approximately 4,000 feet in length and
discharges to a cranberry bog and adjacent bog reservoir. Figure
4 illustrates the extent of the Route 532 contaminated ground
water plume.
The Route 72 contaminated ground water plume is located at a
depth of 70 to 120 feet and is moving in a southwesterly ,
direction to a projected distance of 1.5 to 1.8 miles. The plume
is moving at a rate of 1.2 feet per day. If left unremediated,
the plume may discharge to the Wading River approximately five
miles away. Figure 5 illustrates the extent of the Route 72
contaminated ground water plume.
The concentrations and types of contaminants vary considerably
along the length of each of the plumes. In general, the
concentration of contaminants is highest near the sites. The
near-site ground water contaminants include volatile organics,
semi-volatile organics and metals. The more mobile volatile
organic compounds (e.g., 1,2-dichloroethane) and semi-volatile
compounds (e.g., bis (2-chloroethyl) ether) are found down-
gradient at lesser concentrations.
The ground water is contaminated with a variety of materials.
The major compounds identified and their respective maximum
concentrations include: 1,2-dichloroethane (170,000 (parts per
billion) ppb); 1,1,2,2-tetrachlorethane (7,800 ppb) ; benzene
(2,000 ppb); trichloroethene (1,300 ppb); bis (2-chloroethyl)
ether (44,000 ppb); chloroform (1,200 ppb); and chrcr.iur (6,500
ppb total).
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N
I COM
rrvvniviM/ nn<;i»it«'I. sr.lK
": \ A oi.iri.Kjomnnr rant i
Figure 4
Route 532 Site
Area of Contaminant Plume and Localion of Cross-Section
Possibility Study lor WccfJUind Township Roulo 532 and 72 Situs
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N
I Inmarkol diM Irnils
.'".[Mums
\ l^i'iiloMnrj wnll
Area of Co
Figure 5
Route 72 Site
! Pkiin-j and Location of Cross-Section
Study lor Woorjl.inri Townshirt Route 532 i
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15
Surface Water and Sediment Investigations
Surface water contamination at the sites is limited to the
cranberry bog and reservoir at the discharge point of the Route
532 plume. The reservoir is used solely as a water supply for
cranberry growing operations. Low concentrations of organic
compounds were found in the water and sediment samples.
One Hazardous Substance List (HSL) compound was detected in the
sediments of Goodwater Run. Sediment sampling in Goodwater Run
indicated the presence of zinc contamination located 500 feet
downstream of the site. Elevated concentrations of zinc are an
indication of site-related contamination.
Air Quality Investigation
Air samples were collected at both Woodland sites. Low levels of
site related contamination were detected in the air under ambient
conditions.
Potable Water Investigation
Results of the analysis of one potable well located between the
sites detected no contamination. This well is not down-gradient
from either of the Woodland sites' contaminated ground water
plumes. Results of analyses of three wells in the village of
Duke's Bridge, which is approximately 3.2 miles from the Route 72
site, also showed no contamination. These wells are hydrogeo-
logically down gradient of the Route 72 site. The plume,
however, is a significant distance (greater than 1 mile) from
these wells. If unchecked, it is calculated that the contaminant
plume will eventually be drawn into these potable water wells.
There are no other potentially impacted wells in the vicinity of
the sites.
Cranberries
Samples were collected in the cranberry bog down gradient of the
Route 532 site during the 1988 and 1989 fall harvests. Results
of these samples indicated that they were not contaminated.
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16
SUMMARY OF SITE RISKS
A baseline Risk Assessment evaluates the potential carcinogenic
and non-carcinogenic risks and hazards to the public health
and/or the environment that are associated with exposure to
contaminants emanating from a site in the absence of site
remediation. The risk evaluations are performed by: 1) identi-
fying and characterizing the contaminants of concern; 2) identi-
fying exposure pathways and probable receptors; 3) evaluating the
toxicity of the contaminants found based on the concentrations
detected; and 4) using the above information, calculating the
extent and likelihood of expected impact.
A baseline Risk Assessment was prepared in July 1989 as part of
the RI and is incorporated within that report as Section 4 and
the Final Draft Addendum to the Remedial Investigation Report.
The assessment was based on soil, surface water, sediment and
ground water data collected during the RI. Because of the large
number of chemicals detected, the data was screened in order to
identify the principal chemicals of concern for detailed
evaluation. The chemicals of concern include: DDT and its
metabolites; benzene; bis (2-ethylhexyl) phthalate; 1,2-
dichloroethane; trichloroethane; cresols; chromium; lead
tetrachloroethane; chloroform; 1,1,2,2-tetrachloroethane;
heptachlor; aldrin; chlorobenzene; PAHs; and toluene.
The public health risks associated with exposure to offsite
indicator chemicals, under present site use, were estimated based
on the following exposure pathways:
Dermal absorption of contaminants in the surface soils and
waste at both sites,
Dermal contact and subsequent ingestion of contaminants in
the surface soils and waste at both sites,
Inhalation of volatile organics present in the ambient
atmosphere at both sites,
Inhalation of fugitive dusts predicted to be present in the
ambient atmosphere at both sites.
Dermal absorption and inhalation of contaminants from
surface water during cranberry harvest.
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17
The exposure pathways for future site use were based on the
assumption that human beings will live at the sites. These
estimates were based on the above exposure pathways with the
addition of the following:
Dermal absorption, ingestion, and inhalation of contaminants
from ground water beneath the sites.
Risks and hazards were estimated for two basic exposure
scenarios: present site use and future site use. In addition to
the exposure pathways that are of concern under existing site
conditions, future pathways could be created by the reuse of the
sites. Current allowable uses of the Pine Barrens would allow
development of residential dwellings, and perhaps such
recreational facilities as campgrounds. The exposure risks
associated with both of these uses were also evaluated.
Human Health Risks
Data collected during the RI was used to estimate the extent of
human exposure to indicator chemicals.
For risk assessment purposes, individual pollutants were
separated into two categories of chemical toxicity depending on
whether they cause carcinogenic or non-carcinogenic effects.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6) . An excess lifetime cancer risk of IxlO"6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media. An HI greater
then 1 indicates that adverse non-carcinogenic effects may occur.
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18
Cancer potency factors (CPFs) have been developed by USEPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of milligrams per
kilogram per day (mg/kg-day), are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or
chronic animal bioassays to which animal,-to-human extrapolation
and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by USEPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting non-carcinogenic effects. RfDs, which
are expressed in units of mg/kg-day, are estimates of lifetime
daily exposure levels for humans, including sensitive
individuals, that are not likely to be without an appreciable
risk of adverse health effects. Estimated intakes of chemicals
from environmental media (e.g., the amount of a chemical ingested
from contaminated drinking water) can be compared to the RfD.
RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on humans).
These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur.
Route 532 Site
Because humans presently do not come in contact with contaminated
materials at the Route 532 site, the surface soils do not pose a
risk to human health.
Under worst case conditions, humans would come into contact with
contaminated materials resulting in a total carcinogenic risk of
5x10"* (5 in ten thousand) . The potential risks are associated
with ingestion of soils and inhalation of volatile organics in
the air. The non-carcinogenic hazards exceeded the HI of 1,
indicating an inadequate margin of safety for human health.
Ingestion of lead from the surface soils is the cause of the
potential hazard. In addition, the future site use scenario
includes use of the ground water for household activities. Under
this scenario, a significant probable case carcinogenic risk of
1x103 (1 in a thousand) and a worst case carcinogenic risk of
1x102 (1 in a hundred) and non-carcinogenic hazard exists that
exceeds a target risk by several orders of magnitude:
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19
Even under the most probable future site use conditions, the
ground water would still pose a carcinogenic risk greater than
9xl03 (9 in a thousand) and a non-carcinogenic risk of 7.6, which
significantly exceeds target risks of IxlO"6 (1 in a million) and
a potential HI of 1, respectively.
Route 72 Site
For the Route 72 site, again, no carcinogenic risks or non-
carcinogenic hazards exist under the most probable case for
present use of the site. Under the future use of the site, a
carcinogenic risk greater than IxlO"6 was calculated for ground
water use. The carcinogenic risk was IxlO2 for the most probable
case. The HI was less than 1, indicating no cause for human
health concerns.
Under the worst case scenario, the overall carcinogenic exceeds a
target risk of IxlO"6 for present use of the site. The potential
risks are associated with ingestion of contaminated surface soils
and waste. The air pathway did not indicate a potential problem.
The worst case non-carcinogenic hazard exceeded the HI of 1,
indicating an inadequate margin of safety for human health. The
pathway that caused the potential problem was the ingestion of
lead from the surface soils.
In addition to the risks and hazards posed by the worst case
scenario, future use of the site indicated a risk to human health
via contact with the ground water. A total carcinogenic risk
greater than 2x10° (2 in ten) was calculated for ground water
use. This number exceeds a target risk of IxlO"6. The non-
carcinogenic hazard also exceeded the HI of 1, indicating a
potential cause of concern to human health.
Cranberry Harvest
The inhalation and dermal carcinogenic risks to workers are
1.43x10"* (1.43 in a hundred million) for the most probable case
scenario and 3.08X10"8 for the worst case scenario. These levels
of potential carcinogenic risks indicate an acceptable risk to
human health would be associated with worker activities under the
most probable and worst case scenarios.
Environmental Risks
The Pinelands supports a variety of mammals, reptiles, fish and
birds. Many of these are on the endangered or threatened species
list of the Pinelands Comprehensive Management Plan. Sightings
of several species have been noted for both sites. The Pine-
Barrens tree frog, corn snake, timber rattlesnake, and northern
pine snake were sighted at the Route 532 site. Only the Pine
Barrens tree frog was sighted at the Route 72 site.
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20
Chemical contamination at the sites has had a detrimental effect
on plant life. Stressed vegetation is apparent at both sites.
The removal of natural vegetation from the sites has
substantially reduced potential habitats. The physical hazards
associated with surface waste and rusted out drums at the sites
have reduced the desirability of the sites for inhabitation or
use. The effect is that waste disposal has disturbed the fragile
ecosystem at the Woodland Township sites.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Appropriate remedial technologies identified during the screening
process were assembled into combinations to address the remedial
action objectives and the goals listed below:
To satisfy applicable or relevant and appropriate local,
state, and federal requirements (ARARs), and,
To reduce direct contact risks and stop continued
degradation of the ground water.
The NJDEP has established cleanup objectives for soil as shown in
Table 1. These objectives have been used and accepted by USEPA
when evaluating cleanup plans, and, while not considered to be
ARARs, will be used as cleanup objectives for the Woodland sites.
New Jersey Ground Water Quality Criteria and Maximum Contaminant
Levels established pursuant to the Federal and State Safe
Drinking Water Acts are applicable or relevant and appropriate
Federal and State ground water requirements for this remedial
action. Table 2 identifies the ground water remedial ARARs for
the sites.
The Woodland sites are located in the Central Pine Barrens area.
The N.J.A.C. describes the goal for ground water quality at these
sites as natural background. Table 3 contains numerical values
that represent natural background for ground water at these
sites.
Separate sets of alternatives were developed for surface soils,
unsaturated subsurface soils, and ground water. The current
surface water and sediment contamination in the cranberry bog and
bog reservoir are directly caused by the release of contaminated
ground water. Separate remedial alternatives for surface water
and sediment were not developed, because these water bciies will
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TABLE 1
Soil Remedial Objectives
for the Woodland Township Route 72 and Route 532 Sites
Contaminants fmo/kg)
Total Volatiles 1
Total Acid Extractables 10
Total Base-Neutrals (excluding phthalates) 10
Total Phthalates 25
Antimony 10
Arsenic 20
Barium 400
Beryllium 1
Cadmium 3
Chlordane 1
Chromium (total) 100
Copper 170
(DDT) and metabolites' 10
Lead 250 - 1000'
Mercury 1
Molybdenum 1
Nickel 100
Selenium 4
Silver 5
Thallium 5
Uranium and Thorium Series Radionuclides **
Vanadium 100
Zinc 350
* The cleanup objective for lead is not representative of
background concentrations. It is based on a risk assessment
that has been completed by the New Jersey Department of
Health.
** Cleanup shall be in accordance with 40 CFR 192.
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TABLE 2
Ground Water Remedial ARARs
for the Woodland Township Route 72 and Route 532 Sites
Contaminants
Aldrin/Dieldrin
Ammonia
Arsenic
Barium
Benzene
Benzidine
Biological Oxygen Demand
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloride
Chromium
Coliform Bacteria
Color
Copper
Corrosivity
Cyanide
DDT and metabolites
m-dichlorobenzene
p-dichlorobenzene
o-dichlorobenzene
1,2-dichloroethane
1,1-dichloroethylene
1,2-dichloroethylene (cis
2,4-dichlorophenoxyacetic
Ethylbenzene
Endrin
Fluoride
Foaming Agents
Gross alpha activity
Gross beta activity
Hydrogen sulfide
Iron
Lead
Lindane
Manganese
Mercury
and trans)
acid
fug/1)
0.003
500
50
1000
1
0.1
3000
NB"
2
0.5
4
10,000
NB'
None Noticeable
1000
Non-Corrosive
200
0.001
600
75
600
2
2
10
100
700
0.004
2000
500
15 PCI/I'
50 pCi/1"
50
300
50
4
50
2
Source
1
1
1
1
2
1
1
1
2
2
2
1
1
3
I
I
3
1
1
2
3
2
2
2
2
3
4
1
1
1
3
3
2
1
1
2
1
1
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23
TABLE 2 (continued)
Ground Water Remedial ARARs
for the Woodland Township Route 72 and Route 532 Sites
Contaminant
Methoxychlor
Nethylene chloride
Nitrate-nitrogen
Odor
PH
Phenols
Polychlorinated biphenyls
Phosphate
Radionuclides
Radium
Selenium
Silver
Sodium
Strontium
Sulfate
2,4,5-TP Silvex
Tetrachloroethylene
Toluene
Total Dissolved Solids
Toxaphene
Trichlorobenzene
Trichloroethylene
Trihalomethanes
Tritium
Turbidity
1,1,l-trichloroethane
Vinyl chloride
Xylenes
Zinc
rug/1)
100
2
2000
None Noticeable
4.2-5.8
300
0.001
700
5
NB'
50
10,000
8 pCi/T
15,000
10
1
2000
100,000
5
8
1
100
20,000 pCi/1*
26
2
44
5000
1)
2)
3)
4)
Source
2
2
1
1
1
1
1
1
3
3
1
3
1
3
1
3
2
4
1
3
2
2
2
3
3
2
2
2
3
**
N.J.A.C. 7:9-6.6(a)
N.J.A.C. 7:10-5, N.J.A.C. 7:10-7, A-280
40 CFR 141, 40 CFR 143
Proposed National Primary Drinking Water Regulations (EPA,
1989)
NB - Natural Background - To be quantified prior to design
of any treatment system
Picocuries per liter
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24
TABLE 3
Ground Water Remedial Goals*1
for the Woodland Township Route 72 and Route 532 Sites
Contaminant fug/1)
Aluminum NB
Beryllium NB
Beryllium (dissolved) 0.3
Benzene 0.88
Benzoic acid 1.0
bis (2-chloroethyl) ether 0.57
bis (2-chloroisopropyl) ether 0.57
bis (2-ethylhexyl) phthalate 0.25
2-butanone 1.0
Calcium NB
Carbon tetrachloride 0.56
Chlorobenzene 1.2
Chloroform 0.32
2-chlorophenol 0.33
Cobalt NB
DDT and its metabolites 0.001
1,2-dichlorobenzene 0.19
1.4-dichlorobenzene 0.44
1,2-dichloroethane 0.56
1,1-dichloroethene 0.56
1,2-Dichloropropane 1.2
Diethylphthalate 0.19
2,4-Dimethylphenol 0.27
Di-n-butyl phthalate 0.25
Ethylbenzene 1.44
Isophorone 0.22
Magnesium NB
Methylene chloride 0.56
4-methyl-2-pentanone 1.0
2-methylnaphthalene 1.0
2-methylphenol 1.0
4-methylphenol 1.0
Naphthalene 0.16
Nickel NB
N-nitrosodiphenylamine 0.19
Phenol .0.15
Potassium NB
Styrene 105
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25
TABLE 3 (continued)
Ground Water Remedial Goals*1
for the Woodland Township Route 72 and Route 532 Sites
Contaminant
1,1,2,2-tetrachloroethene
Tetrachloroethene
Toluene
trans 1,2-dichloroethene
Trichloroethene
2,4,5-trichlorophenol
Vanadium
Xylenes, total
1)
fug/1)
1.38
0.8
1.2
0.32
0.38
0.27
NB
1.0
The remedial goals are method detection limits which were
provided by the New Jersey Department of Environmental
Protection
NB - Natural Background
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26
be cleaned up once the flow of contamination in ground water is
controlled. The implementation of each ground water alternative
would stop this release, and result in surface water quality
comparable to the final ground water quality.
Sediment contamination detected in Goodwater Run is a direct
result of contaminated site soil erosion. The contaminated
sediments will be handled in conjunction with the surface
material remediation.
The remedial alternatives that were selected for detailed
evaluation are described below. Due to the similarity of the
contaminant and site characteristics, the analyses discussed
below apply equally to both of the sites, unless specially
referenced otherwise.
REMEDIAL ALTERNATIVES FOR SURFACE SOILS, WASTES AND DEBRIS
Alternative 1 - No Further Action for Surface Materials
Capital Cost: $ 0
Operation and Maintenance (Present Worth [PW]): $870,000
Total PW: $870,000
Estimated Implementation Time: 0 Years
No additional remedial activities would be performed at the
sites. This alternative would involve only maintenance of the
fence surrounding the sites to limit access.
Alternative 2A - Off-Site Disposal of Surface Materials
Capital Cost: $ 1,200,000
Operation and Maintenance (PW): $21,000,000
Total PW: $22,200,000
Estimated Implementation Time: 1 to 2 Years
For this alternative, approximately 26,000 cubic yards from the
Route 532 site and approximately 28,000 cubic yards from the
Route 72 site of waste materials and contaminated surface soils
would be excavated and transported to an off-site RCRA facility
permitted for disposal of hazardous materials. This technology
is applicable to all the organic, metal, and waste materials
excavated from the site, except for radiologically contaminated
soils.
The radiologically contaminated soils will be segregated for
separate off-site disposal. If radionuclide contaminated soils
are determined to be mixed Naturally Occurring or Acceleration
Produced Radioactive Materials (NARM)/RCRA wastes, disposal would
be in accordance with appropriate RCRA regulations fcr nixed
wastes. Because of the current limitations on the off-.1
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27
treatment or disposal of nixed wastes caused by the
unavailability of permitted disposal locations, the potential
exists that these materials would have to be temporarily stored
on site in accordance with appropriate RCRA mixed waste
requirements until a treatment or disposal facility becomes
available.
It is estimated that the surface materials can be excavated and
removed from the site within a year, so completion of this
alternative would not delay the implementation of subsurface soil
or ground water remediation.
Alternative 2B - Off-Site Treatment and Disposal of Surface
Materials
Capital Cost: $ 1,200,000
Operation and Maintenance (PW): $178,000,000
Total PW: $179,200,000
Estimated Implementation Time: 1 to 2 Years
For this alternative, approximately 26,000 cubic yards from the
Route 532 site and approximately 28,000 cubic yards from the
Route 72 site of waste materials and contaminated surface soils
would be excavated and transported to an off-site treatment and
disposal facility. This technology is applicable to the organic,
metal, and waste material excavated from the site.
Materials with radioactive contamination would be containerized
for separate disposal. If the radioactively contaminated
materials are determined to be mixed radiological and hazardous
wastes, disposal would be in accordance with appropriate
regulations for mixed wastes. Because of current limitations on
the off-site disposal of mixed wastes, the potential exists that
these materials would have to be stored on site until a
treatment/disposal facility becomes available. This remedy is
different from Alternative 2A, since it provides for off-site
treatment of surface materials by thermal destruction prior to
disposal, hence the large cost increase.
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28
Alternative 3 - On-Site Encapsulation of Contaminated Surface
Materials
Capital Cost: $5,700,000
Operation and Maintenance (PW): $3,100,000
Total PW: $8,800,000
Estimated Implementation Time: 1 to 2 Years
Under this alternative, a landfill meeting the requirements of
the New Jersey hazardous waste rules would be constructed at an
on-site location. The construction of the hazardous waste
landfill will occur over a relatively short period of time (one
to two years). Because of this, completion of this alternative
will not interfere with implementation of remedial actions for
the subsurface soils or ground water.
The total volume of contaminated surface material that would be
contained in this landfill is approximately 54,000 cubic yards.
The landfill would be located in an area devoid of soil and
ground water contamination, so that any leakage from the landfill
can be detected in the monitoring well network that would
surround the site.
The design of the landfill would meet or exceed New Jersey and
Federal hazardous landfill requirements (N.J.A.C. 7:26-10 and 40
CFR 264.300, et al.). A double composite bottom-liner system, a
leachate collection and detection system, and a double liner cap
with venting are proposed to meet the appropriate design
requirements.
Materials with radioactive contamination would be containerized
for separate off-site disposal. If the radioactively
contaminated materials are determined to be mixed radiological
and hazardous wastes, disposal would be in accordance with
appropriate regulations for mixed wastes. Because of current
limitations on the off-site disposal of mixed wastes, the
potential exists that these materials would have to be stored on
site until a treatment/disposal facility becomes available.
Alternative 4 - On-Site High-Temperature Thermal Treatment of
Surface Materials with Chemical Fixation of Metals
Capital Cost: $ 4,500,000
Operation and Maintenance (PW): $32,000,000
Total PW: $36,500,000
Estimated Implementation Time: 6 Years
This alternative involves the excavation of contaminated surface
materials from each of the sites and high-temperature thermal
treatment of the soils in an on-site incinerator for the
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29
destruction of organics. The treated materials would then be
chemically fixed to decrease the leachability of any metals
remaining after the high-temperature thermal treatment process.
This remedy is estimated to require three years to implement at
each site.
The activity at both sites would involve clearing and grubbing of
any vegetation, excavation, incineration by thermal destruction,
chemical fixation and soil re-emplacement, compaction, and
covering with clean soil, and revegetation of both sites to the
extent practicable to allow for subsurface soil remediation.
Appropriate surface water and sedimentation control would be
incorporated.
The radiologically contaminated soils will be segregated for
separate off-site disposal. If radionuclide contaminated soils
are determined to be mixed NARM/RCRA wastes, disposal would be in
accordance with appropriate RCRA regulations for mixed wastes.
Because of the current limitations on the off-site treatment or
disposal of mixed wastes, the potential exists that these
materials would have to be temporally stored on site in
accordance with appropriate RCRA mixed waste requirements until a
treatment or disposal facility becomes available.
Total volumes of 26,000 cubic yards at the Route 532 site and
27,000 cubic yards at the Route 72 site would be excavated.
Following excavation, the contaminated soils would be taken to
the staging area for treatment. After incineration, the treated
soils would be tested for leaching of metals. Soil that leaches
unacceptable quantities of metals would be chemically fixed in
order to reduce the leachability of metals in the treated
material. The treated material would be re-emplaced into
excavated cells.
Alternative 5 - On-Site High-Temperature Thermal Treatment of
Surface Materials with Vitrification of Metals
Capital Cost: $ 4,500,000
Operation and Maintenance (PW): $37,000,000
Total PW: $41,500,000
Estimated Implementation Time: 11 Years
This alternative involves the same activities as those associated
with Alternative 4, with the exception that some treated soils
would be vitrified into a glass-like mass, crushed, and then
re-emplaced at each site.
Treated soil would be tested for leaching of metals. Scii that
leaches unacceptable quantities of metals would be treated in a
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mobile vitrification unit, which would heat soils to a
temperature at which they would fuse into an amorphous mass,
thereby fixing the metals into a glasslike matrix. The fused
material would then be crushed, and re-emplaced into the
excavated areas at each site. Stack monitoring and perimeter
monitoring systems would be installed and operated to monitor air
emissions.
The radiologically contaminated soils will be segregated for
separate off-site disposal. If radionuclide contaminated soils
are determined to be mixed NARM/RCRA wastes, disposal would be in
accordance with appropriate RCRA regulations for mixed wastes.
Because of the current limitations on the off-site treatment cr
disposal of mixed wastes, the potential exists that these
materials would have to be temporarily stored on site in
accordance with appropriate RCRA mixed waste requirements until a
treatment or disposal facility becomes available.
The sites would then be covered with clean soil, graded, and
revegetated to the extent practicable to allow for subsurface
soil remediation. The total time for complete remediation would
be approximately 4 years for the Route 532 site and 7 years for
the Route 72 site.
REMEDIAL ALTERNATIVES FOR SUBSURFACE SOILS
Alternatives 6, 6A, 7, 8, 9, 10, and 11 were identified in the FS
to address subsurface soils. Subsurface soils are not discussed
here, but will be addressed in supplemental RODs to be prepared
at a later date. Prior to that time, treatability evaluations
will be performed to assist in remedy selection.
REMEDIAL ALTERNATIVES FOR GROUND WATER
Alternative 12 - No Action for Ground Water
Capital Cost: $. 780,000
Operation and Maintenance (PW): $4,400,000 (For 30 years)
Total PW: $5,100,000
Estimated Implementation Time: 0 Years
Under this alternative, no action would be taken to contain or
recover the contaminated ground water plumes. Public health
would be protected by restricting human contact with the
contaminated ground water.
If migration of the contaminant plume causes further
contamination of surface waters or threatens existing drinking
water supplies, this alternative would be reconsidered end
additional remedial measures would be implemented.
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Alternative 13 - Air Stripping. Metals Removal, and Biological
Treatment fl.9 mad Pumping)
Capital Cost: $ 25,000,000
Operation and Maintenance (PW): $ 88,000,000 (For 30 years)
Total PW: $113,000,000
Estimated Implementation Time: 30 Years
Under this alternative, the contaminant plumes at the sites would
be extracted at an estimated rate of 1.9 million gallons per day
(mgd) which is sufficient only to capture the present contaminant
plumes at their estimated flow rates and extent. This pumping
rate was developed to remediate the aquifer within a target
period of 30 years. The same rate would be implemented under
Alternatives 14, 15 and 16. Actual locations and pumping rates
for the ground water remediation would be determined during the
design.
It has been estimated' that a total pumping rate of 400 gallons
per minute (gpm) or 0.58 mgd would provide sufficient control for
the Route 532 site. All wells would be screened through the
contaminated zone, approximately 25 to 50 feet below the ground
surface, and designed to capture as little clean water as
possible. The combined effect of the three pumping wells has
been calculated to provide a hydraulic barrier that would capture
the estimated width of the plume.
It is estimated that this alternative would result in removal of
the portion of Route 532 site plume volume, extending 2,000 feet
down gradient, within 30 years, once the source is removed or
immobilized. However, it is recognized that this alternative
would proceed until the ground water remedial ARARs have been
met. Concentrations in the down gradient plume discharging to
surface water would also be monitored throughout this period, as
would the surface water in the bog and bog reservoirs. Surface
water samples would be collected over the same period of time.
It has been estimated that a total pumping rate of 965 gpm (1.34
mgd) would be needed to capture the present plume volume at the
Route 72 site. Pumping barriers similar to those described for
the Route 532 site would be used to capture the near-site and
down gradient portions of the plume. The wells would pump from
the contaminated interval between 70 and 120 feet below the
ground surface.
This alternative has been estimated to capture the present volume
of the Route 72 site plume in approximately 30 years, based on
the same assumptions discussed for the Route 532 site. Tht
sampling schedule would be the same as for the Route 532 site.
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Water from each ground water extraction system would be
transported through a piping system to a treatment plant located
nearby. The effluent from the treatment plant would be piped
back to each site and recharged into the aquifer. The method of
recharge would be determined during the design.
Table 2 gives the site ARARs and Table 3 gives the goals for the
aquifer quality. The sizing and performance requirements for
each unit operation would be determined during design.
The conceptualized processing system for the ground water can be
divided into the steps listed below:
Acid Addition
Air Stripping
Metals Removal
Filtration
Biological Treatment
The design of the ground water capture and recharge system would
be based on results of computer modeling of flow and transport in
the aquifer underlying the sites. A comprehensive treatability
study would be needed as an early step in the design of the
treatment system. This study would define design and operating
parameters for the treatment steps.
The treatment system is expected to achieve all remedial ARARs,
except for some semi-volatile compounds, BOD and TDS. However,
operating parameters can be adjusted to improve effluent quality
as the influent concentration of these parameters decrease over
time. The treatment process to remove metals will cause an
increase in the level of TDS in the effluent above the standard
established in N.J.A.C. 7:9-6.6(a). However, this higher level
of TDS is expected to be present only while the metals
precipitation unit is in operation. After treatment to remove
metals has been completed and the operation of the precipitation
unit has been reduced or ceased, the concentration of TDS in the
effluent will be reduced.
Alternative 14 - Air Stripping. Metals Removal. Biological
Treatment, and Carbon Adsorption (1.9 mgd Pumping)
Capital Cost: $ 29,000,000
Operation and Maintenance (PW): $133,000,000 (For 30 years)
Total PW: $162,000,000
Estimated Implementation Time: 30 Years
The pumping and recharge scheme for this alternative is identical
to that for Alternative 13. It was developed to remediate the
contaminated ground water plumes within a target period of 30
years, based on the estimated extent and flow rates of the
plurnes.
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The conceptualized process system for this alternative is based
on the same criteria for the acid addition, air stripping, metals
removal, and biological treatment steps as the treatment system
in Alternative 13. The effluent from these treatment steps would
be further treated by activated carbon. This system will
achieve all remedial ARARs except the effluent requirements for
BOD or TDS, but operating parameters can be adjusted to improve
effluent quality as the influent concentrations of these
parameters decrease over time. In addition, the remedial goals
are expected to be reached as a result of treatment under this
alternative.
The requirements for additional studies would be similar to those
for Alternative 13. Additional treatability testing will be
needed to define operating parameters for the carbon adsorption
system. These tests are particularly important to estimate
carbon usage which is the most significant cost factor in the
carbon adsorption step, and which cannot be accurately estimated
without testing.
Alternative 15 - Air Stripping. Metals Removal. Biological
Treatment, and Advanced Oxidation (1.9 mqd Pumping)
Capital Cost: $ 27,000,000
Operation and Maintenance (PW): $ 93,000,000 (For 30 years)
Total PW: $120,000,000
Estimated Implementation Time: 30 Years
The pumping and recharge scheme for this alternative is identical
to that for Alternative 13. It was developed to remediate the
contaminated ground water plumes within a target period of 30
years, based on the estimated extent and flow rates of the
plumes.
The conceptualized process system is based on the same criteria
for the acid addition, air stripping, metals removal, and
biological treatment steps as in Alternative 13. The effluent
from the system would then be dosed with hydrogen peroxide and
passed through an ozone contactor. The advanced oxidation step
can reduce concentrations of the readily oxidizable compounds
(phenols and soluble PAHs). This treatment system will achieve
all remedial ARARs except the effluent requirements for BOD or
TDS, but operating parameters can be adjusted to improve effluent
quality as the influent concentrations of these parameters
decrease over time. In addition, the remedial goals are expected
to be reached as a result of treatment under this alternative.
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The requirements for additional studies would be similar to those
for Alternative 13. Additional treatability studies also would
be needed to define the operating parameters and optimize the
performance and cost-effectiveness of the advanced oxidation
step.
Alternative 16 - Air Stripping. Metals Removal. Biological
Treatment. Carbon Adsorption, and Reverse Osmosis (1.9 mgd
Pumping)
Capital Cost: $ 40,000,000
Operation and Maintenance (PW): $232,000,000 (For 30 years)
Total PW: $272,000,000
Estimated Implementation Time: 30 Years
The pumping and recharge scheme for this alternative is identical
to that for Alternative 13. It was developed to remediate the
contaminated ground water plumes within a target period of 30
years, based on the estimated extent and flow rates of the
plumes.
The conceptualized process system is based on similar criteria
for the acid addition, air stripping, metals removal, biological
treatment and carbon adsorption as in Alternative 14. A reverse
osmosis (RO) step would be added to reduce BOD and TDS to meet
the remedial ARARs in the initial discharge. In addition, the
remedial goals are expected to be reached as a result of
treatment under this alternative.
Effluent from the activated carbon will be further treated by RO
to reduce BOD and TDS concentrations to within remedial ARARs in
the initial discharge.
The requirements for additional studies would be similar to those
for Alternative 13. Additional treatability studies would be
needed to define design parameters for the carbon adsorption
step, as described under Alternative 14.
Additional testing would also be needed to support selection of
the RO membrane, and design of the RO plant.
Alternative 17 - Air Stripping. Metals Removal and Biological
Treatment (3.2 mgd Pumping)
Capital Cost: $ 31,000,000
Operation and Maintenance (PW): $ 84,000,000 (For 30 years)
Total PW: $115,000,000
Estimated Implementation Time: 10 Years
This alternative is identical to Alternative 13, except, that the
contaminant plumes would be extracted at an approximate rate of
3.2 mgd instead of 1.9 rogd.
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Alternatives 17, 18, 19, and 20 are designed to remediate the
sites at an accelerated rate. The pumping rate of 3.2 mgd would
remediate the contaminated ground water plumes in approximately
10 years. Additional pumping wells would be necessary. The
increased pumping would increase the magnitude of the drawdown
and the extent of the effected area.
Alternative 18 - Air Stripping. Metals Removal. Biological
Treatment and Carbon Adsorption (3.2 mqd Pumping)
Capital Cost: $ 40,000,000
Operation and Maintenance (PW): $121,000,000 (For 30 years)
Total PW: $161,000,000
Estimated Implementation Time: 10 Years
This alternative is identical to Alternative 14, except that 3.2
mgd would be extracted and the treatment system would have a
larger capacity to accommodate the higher flow rate.
Alternative 19 - Air Stripping. Metals Removal. Biological
Treatment and Advanced Oxidation (3.2 mgd Pumping)
Capital Cost: $ 34,000,000
Operation and Maintenance (PW): $ 89,000,000 (For 30 years)
Total PW: $123,000,000
Estimated Implementation Time: 10 Years
This alternative is the same as Alternative 15, except that 3;2
mgd would be extracted and the treatment system would have a
larger capacity to accommodate the higher flow rate.
Alternative 20 - Air Stripping. Metals Removal, Biological
Treatment. Carbon Adsorption and Reverse Osmosis (3.2 mgd
Pumping)
Capital Cost: $ 55,000,000
Operation and Maintenance (PW): $221,000,000 (For 30 years)
Total PW: $276,000,000
Estimated Implementation Time: 10 Years
This alternative is identical to Alternative 16, except that 3.2
mgd would be extracted and the treatment system would have a
larger capacity to accommodate the higher flow rate.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative is conducted with respect to each of nine detailed
evaluation criteria. All selected remedies must at least attain
the Threshold Criteria. The selected remedy should provide the
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best trade-offs among the Primary Balancing Criteria. The
Modifying Criteria were evaluated following the public comment
period.
Threshold criteria
Overall Protectiveness of Human Health and the Environment -
This criterion evaluates the adequacy of protection that the
remedy provides while describing how risks are eliminated,
reduced or controlled through treatment, engineering con-
trols, and/or institutional controls.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) - This criterion addresses whether a
remedy will meet all of the ARARs of other Federal and State
environmental statutes and/or provide grounds for invoking a
waiver.
Primary Balancing Criteria
Reduction of Toxicity, Mobility or Volume (TMV) - This
criterion addresses the anticipated treatment performance of
the remedy.
Short-Term Effectiveness - This criterion refers to the
speed with which the remedy achieves protection, as well as
the remedy's potential to create adverse impacts on human
health and the environment during the remedial action.
Long-Term Effectiveness and Permanence - This criterion
evaluates the magnitude of residual risk and the ability of
the remedy to maintain reliable protection of human health
and the environment over time once the remedial action has
been completed.
Implementability - This criterion examines the technical and
administrative feasibility of executing a remedy, including
the availability of materials and services needed to imple-
ment the chosen solution.
Cost - This criterion includes the capital and operation and
maintenance costs of the remedy.
Modifying Criteria
State Acceptance - This criterion indicates whether, based
on its review of the Feasibility Study and Proposed Plan,
the State of New Jersey concurs with, opposes, or has nc
comment on the preferred alternative.
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Community Acceptance - This criterion evaluates the reaction
of the public to the remedial alternatives and USEPA's
Proposed Plan. Comments received during the public comment
period and USEPA's responses to those comments are
summarized in the Responsiveness Summary attached to this
document.
REMEDIAL ALTERNATIVE FOR SURFACE SOILS, WASTES AND DEBRIS
Overall Protection of Human Health and the Environment;
Alternative 1 would not reduce the public health risk other than
maintenance of the fences surrounding the sites. This
alternative would allow continuation of adverse environmental
conditions.
Alternatives 2A and 2B would remove the threats to public health
and the environment stemming from contaminated surface soils at
each site. The excavation of contaminated surface soils for
transport to an off-site treatment, storage, and disposal (TSD)
facility would minimize the potential for continued local
releases of contamination.
Surface materials would be encapsulated on site in Alternative 3.
The encapsulation facility would isolate the materials from the
surrounding environment. Direct exposure threats will be
removed. Precipitation will not be permitted to percolate
through the facility and create more leachate which could further
contaminate the ground water.
The high-temperature thermal treatment of Alternatives 4 and 5
should destroy most of the hazardous constituents. The chemical
fixation of metals associated with Alternative 4 and the
vitrification of metals associated with Alternative 5 would
prevent future releases of contaminants to the water systems.
Compliance with ARARs;
To date, there are no promulgated Federal and State standards for
cleanup of soils contaminated with organic compounds, or with
nonradioactive metals. Therefore, no ARARs have been identified
for remediation of most of the contaminants in soils at the site.
However, NJDEP has established soil cleanup objectives for this
remedial action (Table 1) .
The ARARs were identified for PCBs and radionuclides. The Toxic
Substance Control Act addresses disposal requirements of soils
contaminated with PCBs above 50 ppm. This does not, however,
influence site actions since, to date, no PCBs have beer, detected
at the sites in concentrations above 5 ppro.
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There are no applicable standards governing remediation of soil
contaminated with radionuclides at the Woodland sites. Two sets
of criteria have been considered as relevant and appropriate and
"to-be-considered" for the remediation of radioactively
contaminated soils. These are the Federal Health and
Environmental Protection Standards for Uranium and Thorium Mill
Tailings (40 CFR 192) and Nuclear Regulatory Commission
Guidelines, respectively.
Because these sites are located within the Pinelands Preservation
area, The Pinelands Comprehensive Management Plan (N.J.A.C. 7:50-
1.1, et seq.) is applicable to some construction activities.
Although the site wastes are not currently identified as
hazardous wastes, ongoing data gathering may change this
classification and subject the sites to RCRA applicability. The
regulation is still considered as relevant and appropriate for
some actions, such as the construction of an on-site landfill.
This consideration is made in light of the environmentally
sensitive location in which such a landfill would be constructed.
The New Jersey Hazardous Waste Regulations are also considered in
the same matter.
The New Jersey Air Pollution Regulations include provisions for
the emission of combustion by products and chemical vapors into
the atmosphere. These regulations are considered as applicable
to many of the construction activities.
Alternative 1 does not comply with the soil cleanup objectives
identified for these sites.
Alternatives 2A and 2B would comply with the soil cleanup
objectives since they would excavate and dispose of the surface
materials off site. They would comply with all Federal and State
regulations associated with transportation. The alternatives
would meet all RCRA standards and guidelines (e.g., 40 CFR Part
262, 40 CFR 264, 40 CFR 265, OSWER Off-site Policy, etc.). A
RCRA storage permit will be required for wastes which remain on
site for greater than 90 days.
Alternative 2A may not meet the USEPA statutory deadline for RCRA
Land Disposal Restrictions (LDRs) when they come into effect on
November 9, 1990. These restrictions will require that soil and
debris from Superfund sites be treated prior to disposal.
Because of the time necessary to design and construct a new
landfill, Alternative 3 may not meet the USEPA regulations for
RCRA LDRs when they come into effect on November 9, 1990. The
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siting of the landfill would be in conflict with the Pinelands
Comprehensive Management Plan (N.J.A.C. 7:50-6.75 and 6.81),
which does not permit the construction of hazardous waste
landfills within the New Jersey Pinelands.
Alternatives 4 and 5, due to the siting of an on-site
incinerator, would not comply with the Pinelands Comprehensive
Management Plan.
Reduction of Mobility. Toxicity. or Volume (MTV) of Contaminants
through Treatment or Containment:
Alternative 1 offers no reduction in MTV of the contaminants.
Alternatives 2A and 3 provide for reduction in mobility, since
they utilize containment to ensure that site wastes do not cause
environmental degradation.
Alternatives 2B, 4, and 5 provide for reduction in the levels of
organics through thermal treatment. They further provide for the
reduction in the mobility of the remaining contaminants through
either off-site containment (Alternative 2B), or immobilization
(Alternatives 4 and 5).
Short-Term Effectiveness;
The short-term effectiveness of Alternative 1 relies on the
enforcement of the security measures to discourage casual access
to the sites.
Alternatives 2A, 2B, 3, 4, and 5 all have similar short-term
risks. The risks are associated with the excavation and
subsequent handling of the wastes. The short-term risks would be
reduced by implementing dust control measures, the use of Level C
or Level B personal protection equipment, and implementing other
engineering controls. Other measures would include erosion
control, sealed transport of waste and soils, and vehicle
decontamination.
Long-Term Effectiveness:
Alternative 1 would provide poor long term effectiveness, since
wastes are still available to the environment. The remedy is
limited in its effectiveness, and provides for a continued source
of direct contact and ground water contamination.
Alternatives 2A, 2B, 4 and 5 all provide permanent remedies for
the surface soil contamination. Alternatives 2A and 2E removes
the contaminated materials to a secure facility. The
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high-temperature thermal treatment in Alternatives 4 and 5
provide permanent remedies for surface soil contamination. The
chemical fixation and vitrification of residual material would
require maintenance of the soil cover and monitoring of ground
water and surface water to demonstrate the effectiveness of the
remedies.
The design for Alternative 3 is expected to provide a reliable
long-term remedial approach. Maintenance is required for
erosion, vegetation, pumps, tanks and instruments. Monitoring is
required for ground water, surface water, leachate and gas
venting.
Implementabi1itv:
All the alternatives evaluated use widely applied technologies
and have past proven performance. Alternative 1 would require
fence maintenance and security patrols, all of which are local
and readily available.
Alternatives 2A and 2B use technology currently available and use
standard construction industry equipment and practices.
Currently, there is sufficient landfill space to assure
acceptance of the excavated material. Time is not a factor, and
delays would not affect other remedial efforts.
The landfill construction in Alternative 3 uses widely applied
technologies and proven engineering designs. The construction of
the landfill is short term (1-2 years). The equipment,
materials, and personnel necessary for the construction of a
landfill would be available through local markets.
The high temperature thermal treatment of Alternatives 4 and 5
uses widely applied technologies with a history of reliable and
effective performance. These remedies are estimated to require
three years to implement at each site. The equipment materials
and personnel necessary for the implementation of these
alternatives would be available from a small number of vendors.
A limitation is noted for Alternative 5, since vitrification
units of the needed size are presently limited.
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Cost;
The total cost includes estimated capital, and operation and
maintenance costs. The cost comparisons for each alternative are
shown in Table 4. Alternative 1 provides minimal protection for
a total present worth cost of $870,000. Alternatives 2A and 2B
remove the contaminated surface materials from the sites at total
present worth costs of $22,200,000 and $179,200,000,
respectively. Alternative 3 encapsulates the contaminated
surface materials on site for a total present worth of
$8,800,000. Alternatives 4 and 5 thermally treat the surface
materials prior to contaminant immobilization for total present
worth costs of $36,500,000 and $41,500,000, respectively.
State Acceptance;
As the lead agency for the investigation, the State of New Jersey
participated in the selection of the remedy for the sites. The
State, therefore, concurs with the selected remedy of Alternative
2A.
Community Acceptance;
The community had no opposition to the preferred remedy nor did
they overly prefer any other alternative. Questions and answers
raised during the public meeting are presented in the
responsiveness summary.
A group of PRPs (Woodlands Private Study Group [WPSG]) supports
Alternative 2A. Comments from the WPSG also indicate support for
Alternative 3, however, the group offered no support for
Alternative 4 or 5 and had no comment on Alternative 1 or 2B.
REMEDIAL ALTERNATIVES FOR GROUND WATER
Overall Protection of Human Health and the Environment;
Alternative 12 (No Action) would offer no protection of human
health and the environment, since it would not address the
existing contamination and would necessitate substantial
restrictions on ground water use. Degradation of the Cohansey
Sand Aguifer would proceed unchecked until the source of
contamination has been depleted and the plume has been diluted,
degraded, or has been completely discharged to surface water
which would require a substantial period of time.
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TABLE 4
Cost Summary Table for Remedial Alternatives
of the Woodland Township Route 72 and Route 532 Sites
Remedial Alternatives Capital Operation and
for Surface Materials Costs'1 Maintenance'1'2 Total'1
Alternative 1 - 0.0 0.87 0.87
No Action
Alternative 2A - 1.2 21.0 22.2
Off-Site Disposal
Alternative 2B - 1.2 178.0 179.2
Off-Site Treatment and
Disposal
Alternative 3- 5.7 3.1 8.8
On-Site Encapsulation
Alternative 4 - 1.5 35.0 36.5
On-Site High Temperature
Thermal Treatment with
Chemical Treatment Fixation
of Metals
Alternative 5 - 1.5 40.0 41.5
On-Site High Temperature
Thermal Treatment with
Vitrification of Metals
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TABLE 4 (continued)
Cost Summary Table for Remedial Alternatives
of the Woodland Township Route 72 and Route 532 Sites
Remedial Alternatives Capital Operation and
for Ground Water Costs'1 Maintenance'1-2 Total'1
Alternative 12 - 0.78 4.4 5.2
No Action
Alternative 13 - 25.0 88.0 113.0
Air Stripping, Metals
Removal, Biological
Treatment (1.9 mgd Pumping)
Alternative 14 - 29.0 133.0 162.0
Air Stripping, Metals
Removal, Biological
Treatment, Carbon Adsorption
(1.9 mgd Pumping)
Alternative 15 - 27.0 93.0 120.0
Air Stripping, Metals
Removal, Biological
Treatment, Advanced Oxidation
(1.9 mgd Pumping)
Alternative 16 - 40.0 232.0 272.0
Air Stripping, Metals
Removal, Biological
Treatment, Carbon Adsorption,
Reverse Osmosis (1.9 mgd Pumping)
Alternative 17 - 31.0 84.0 115.0
Air Stripping, Metals
Removal, Biological
Treatment (3.2 mgd Pumping)
Alternative 18 - 40.0 121.0 161.0
Air Stripping, Metals
Removal, Biological
Treatment, Carbon Adsorption
(3.2 mgd Pumping)
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TABLE 4 (continued)
Cost Summary Table for Remedial Alternatives
of the Woodland Township Route 72 and Route 532 Sites
Remedial Alternatives Capital Operation and
for Ground Water Costs*1 Maintenance'1"2 Total'1
Alternative 19 - 34.0 89.0 123.0
Air Stripping, Metals
Removal, Biological
Treatment, Advanced Oxidation
(3.2 mgd Pumping)
Alternative 20 - 55.0 221.0 276.0
Air Stripping, Metals
Removal, Biological
Treatment, Carbon Adsorption,
Reverse Osmosis (3.2 mgd Pumping)
1). Costs are expressed as $1,000,000.
2). Operation and maintenance costs are represented as net
present value for each alternative.
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Alternatives 13, 14, 15 and 16 all are similar in overall
protection of human health and the environment. Ground water use
within the area of contamination would be curtailed for any
current users, and prohibited for new users throughout the period
of remediation. Under these alternatives, no further degradation
of the aquifer would occur. Some local disturbance is expected
during construction and implementation of these alternatives.
Air emissions would be monitored and controlled. Wetlands will
be monitored for potential impacts.
Alternatives 17, 18, 19 and 20 would increase the ground water
extraction and achieve remediation of the ground water in a
shorter time frame. This would result in a significant increase
in the magnitude of the drawdown and the extent of the affected
area as compared to Alternatives 13, 14, 15 and 16. Further
studies and modelling are required to fully estimate the impact
this would have on the sites. An added impact would be realized
due to the larger amount of construction activities associated
with this alternative (e.g., larger pumping well systems, piping
systems, treatment plant and possible infiltration basin, etc.).
Compliance with ARARs;
Although permits are not required for on-site facilities,
substantive requirements must be met. The discharge from the air
stripper off-gas treatment unit will meet the National Ambient
Air Quality Standards and NJDEP requirements (N.J.A.C. 7:27-8.2
and N.J.A.C. 7:27-17). Any disposal off site, if necessary, will
comply with either a RCRA Part A (Interim Status) or a RCRA Part
B permit. Transporters hauling the waste would be required to
have an USEPA identification number, meet the transportation
requirements order RCRA (40 CFR Part 263). Construction will
likely require review by the Pinelands Commission.
Alternative 12 would not meet any of the previously discussed
ground water ARARs or remedial goals.
Alternative 13 is expected to achieve ground water ARARs for all
contaminants, with the exception of some semi-volatiles, BOD and
TDS. Remedial goals, with the exception of some semi-volatile
compounds, BOD and TDS, should also be achieved as a result of
treatment under this alternative.
Alternatives 14 and 15 would meet all ground water ARARs, with
the exception of BOD and TDS in the initial discharge. Remedial
goals for all contaminants with the exception of BOD and TDS
should also be achieved as a result of treatment under these
alternatives. At the end of the remedial action it is expected
that concentrations of BOD and TDS should meet ARARs.
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Alternative 16 is expected to meet all ground water ARARs and
remedial goals.
Alternatives 17, 18, 19 and 20 will comply with the same ground
water ARARs as the corresponding lower pumping rate alternatives.
These alternatives will comply with the requirements set forth in
N.J.A.C. 7:27-8.2 and N.J.A.C. 7:27-17.
Reduction of Toxicitv. Mobility or Volume of Contaminants through
Treatment or Containment;
Alternative 12 would not be effective in reducing the toxicity,
mobility, and volume of contaminants in the ground water. Some
reduction in toxicity could be expected through the natural
processes.
Alternatives 13, 14, ,15, 16, 17, 18, 19 and 20 all have
air-stripping, metals removal and biological treatment in common.
air stripping would result in the removal of the volatile organic
compounds (VOCs) and bis(2-chloroethyl) ether. These constitute
approximately 80 percent of the total mass of organic Target
Compound List (TCL) compounds. Biological treatment would remove
a significant portion of the remaining contaminants. The metals
removal step would concentrate the metals into a solid phase,
which would be disposed of off site as a hazardous material.
Alternatives 14 and 18 additionally incorporate carbon
adsorption^ The semi-volatile contaminants would be removed by
adsorption to the carbon. The spent carbon would be either
regenerated or disposed of off site as a hazardous material.
Alternatives 15 and 19 additionally incorporate advanced
oxidation. This would provide additional removal of semi-
volatile contaminants. However, complete oxidation of these
compounds is not likely to occur, and products of partial
oxidation are expected to remain. This process would not produce
any sidestreams requiring disposal.
Alternatives 16 and 20 additionally incorporate reverse osmosis.
Reverse osmosis and evaporation will concentrate the remaining
dissolved contaminants into a waste stream that will require
disposal off site.
Short-Term Effectiveness;
Alternative 12 would require administrative controls for
security.
The Alternatives 13, 14, 15, 16, 17, 18, 19 and 20 have similar
short-term effectiveness. The area is sparsely populclei sc risk
will be minimal to the community. The workers, en s:tt vill be
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protected by a strict health and safety plan. The volatile
compounds emitting from the ground water during treatment will be
controlled by engineering practices.
The ozone generated in Alternatives 15 and 19 will be routed to
the ozone contactor and, therefore, result in no exposure to
workers. Hydrogen peroxide transportation, handling, and storage
will be by the best engineering design.
The carbon adsorbent in Alternatives 14, 16, 18, and 20 will need
to be replaced on a regular basis. The reverse osmosis
components in Alternative 16 and 20 will reduce BOD and TDS
concentrations and will increase truck trips but should not cause
any hazards.
Long-Term Effectiveness;
The long-term effectiveness of Alternative 12 is only viewed in
the ability of the aquifer to dilute or decay the contaminants in
the plume.
Alternatives 13, 14, 15, 16, 17 ,18 ,19 and 20 all have good
long-term effectiveness. The long-term effectiveness of the
treatment based alternatives are permanent. Protection is
provided by the alternatives' ability to remove contamination
from the ground water.
Implementabilitv;
Alternative 12 would not pose a problem in construction or
maintenance for the fencing or monitoring system. This no-action
alternative is readily implemented because no remedial action is
being taken.
The unit processes proposed for Alternatives 13, 14, 15, 16, 17,
18, 19 and 20 for the treatment system have been used in many
applications. The design and construction of these units do not
pose any technical problems. The pumping rates were estimated by
using a ground water model. The model predicted that remediation
would be completed in either 30 years for Alternatives 13, 14, 15
and 16, or 10 years for Alternatives 17, 18, 19 and 20. The
effectiveness of the treatment system would be monitored by
periodic analysis of samples collected from influent and effluent
streams, and other points in the treatment train to monitor
system performance.
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In Alternatives 15 and 19, the addition of an advanced oxidation
step would present no unusual difficulties with respect to
construction or operation. All equipment is readily available
and has been used for a number of years in other applications.
However, treatability studies would be necessary to optimize
design parameters and determine the effectiveness of this
process.
Alternatives 14 and 18 add carbon adsorption to the treatment
train. This would present ho unusual difficulties with regard to
construction or operation. Treatability studies for carbon
adsorption isotherm testing and pilot studies must be performed
to define the actual design parameters.
Alternatives 16 and 20 add reverse osmosis to the treatment train
of Alternatives 14 and 18. This addition is expected to present
no unusual difficulties with regard to construction or operation.
Reverse osmosis has been successful in removing dissolved
contaminants from a variety of industrial and waste water
streams. Pilot testing would be required to define design
parameters.
Alternatives 17, 18, 19 and 20 all would need larger recharge
basins or wells than the previous alternatives. The large aerial
extent of the Route 532 site could accommodate a larger basin
without clearing uncontaminated areas. The Route 72 site,
however, would have to clear 240,000 square feet (approximately 6
acres) of uncontaminated area to accommodate the basin.
Cost;
The alternatives are presented in a cost comparison table in
Table 4.
Alternative 12 provides minimal protection for a present worth of
$5,200,000. Alternative 13 (a basic ground water treatment
system for these sites - acid addition, air stripping, metals
removal, filtration, and biological treatment) has a total
present worth value of $113,000,000. Alternative 14 (Alternative
13 plus activated carbon adsorption) has a total present worth
value of $162,000,000. Alternative 15 (Alternative 13 plus
advanced oxidation) has an estimated total present worth of
$120,000,000. Alternative 16 (Alternative 14 plus reverse
osmosis) has a total present worth of $272,000,000. Alternative
17 (similar to Alternative 13 but designed for 3.2 mgd treatment)
has a total present worth of $115,000,000. Alternative 18
(Alternative 17 plus activated carbon adsorption) has a total
present worth of $161,000,000. Alternative 19 (Alternative 18
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plus advanced oxidation) has a total present worth of
$123,000,000. Alternative 20 (Alternative 18 plus reverse
osmosis) has a total present worth of $276,000,000.
State Acceptance;
As the lead agency for the investigation, the State of New
Jersey, participated in the selection of the remedy for the
sites. The State, therefore, concurs with the selected remedy of
Alternative 15.
Community Acceptance;
The community has. no objection to the preferred remedy nor did
they overly prefer any other alternative. Questions and answers
raised during the public meeting are presented in the
responsiveness summary.
The WPSG has expressed support for Alternative 14. Discussions
with the WPSG indicated an interest in their part to pursue
Alternative 15 in the design.
SELECTED REMEDY
The USEPA and the NJDEP have evaluated the remedial alternatives
in accordance with Section 121 of CERCLA and Section 300.432 of
the NCP and have developed a preferred remedial action for the
Woodland sites based on the findings of the RI/FS and input by
the public.
Assessments will be conducted before the remedial design. These
include:
Endangered species survey,
Biological survey,
Wetlands delineation and assessment,
Initial habitat restoration evaluation which will be
completed during the next operable unit,
Floodplain impacts,
Cultural resources survey,
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Increased ground water monitoring to determine the extent of
potential radiological contamination. This increased
monitoring will determine whether or not elevated
radioactivity in some ground water samples is naturally
occurring or indicative of ground water contamination.
Surface Materials
The USEPA and the NJDEP have selected Alternative 2A as the most
appropriate remedy for surface materials at the sites. This
would involve disposal of all contaminated surface materials at
an acceptable off-site facility.
There are no promulgated Federal or State standards applicable
for cleanup of soils contaminated with organic compounds or with
nonradioactive metals at the Woodland sites. The remedial
objectives are stated in Table 1. Surface soil samples were
collected at off-site locations to estimate background
concentrations of HSL contaminants and radionuclides. Based on
these, background for phenols is in the range of 9.1 to 11.6 ppm.
Total phthalates and DDT and its metabolites were present at less
than 1 ppm. Excavation and off-site disposal would remove the
threats to public health and the environment stemming from
contaminated surface materials at each site. This alternative
meets and exceeds the remedial objectives for the sites by
removing the surface materials from the site to off-site
locations.
Implementation of Alternative 2A would require the temporary
installation of staging and loading areas for the classification
and removal of surface materials at the sites. The
classification and removal of surface materials from the Route 72
and Route 532 sites would take less than 1 year. This remedy
will comply with RCRA requirements for on-site storage of waste
for greater than 90 days. The remedy will meet the substantive
requirements of a permitted storage facility. The temporary
staging and loading areas would then be taken from the sites and
native vegetation will be reestablished.
Potential risks are associated with the remedy. These pertain
almost exclusively to the excavation and transportation of the
material. Volatilization of VOCs or suspension of particle-bound
contaminants as fugitive dust would occur. These increased
releases would be temporary, lasting only through active
remediation. Fugitive dust impact would decrease rapidly with
distance from the site.
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On-site and perimeter emissions monitoring will be conducted to
evaluate potential off-site migration of airborne contamination
(e.g., organic vapors, fugitive dusts, radionuclides, etc.).
Ground water monitoring will be implemented. The ground water
monitoring program will determine the hydrologic effect
associated with surface material excavation. If a concern is
identified, appropriate contingency plans will be enacted to
mitigate the concern.
Contingency plans would be developed to meet any problems, i.e.,
protective equipment for workers, plastic covers for temporary
material storage, and water/surfactant sprays.
All modes of transportation from the site to an ultimate off-
site disposal facility are acceptable from a public health
perspective, assuming that the impact of an accidental release
would be minimal. Wastes removed from the site with surface
material would typically be bound within the soil matrix or semi-
solid materials not likely to be lost to the environment if
spilled. The environmental levels of contamination present in
the surface material and the availability and implementation of a
spill response plan suggest little impact in any case.
The excavation and disposal of contaminated material would allow
full restoration of the natural site surface conditions,
including re-establishment of an indigenous ecosystem (at the
completion of the remedial actions for the sites). The net
result would be to remove surface contamination to a secure
location outside the Pinelands, which would substantially enhance
the site environments. Suitable replacement soils will be placed
on site to aid in the re-establishment of the sites after the
remedial actions are completed.
This alternative uses standard construction industry equipment
and practices, and does not rely on new, untested technologies or
procedures.
Contact with representatives of six potential RCRA-permitted
disposal facilities indicates that there is currently sufficient
capacity available at each of the facilities to accept the
surface materials from the Woodland sites. Availability of
facilities and equipment does not at present represent a
constraint for this alternative; however, the facility owners
cannot project future demand for existing capacity or commitment
of disposal space to other cleanup volumes.
The selected remedy for both sites for surface material
remediation has an estimated total present worth of $22,200,000.
The remedy will cost approximately $1,200,000 to construct. The
NJDEP has estimated that operation and maintenance costs will be
$21,000,000.
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Ground Water
The USEPA and the NJDEP have selected Alternative 15 as the most
appropriate remedy for ground water remediation at the sites.
This would involve the installation of a ground water recovery
system with an estimated flow of 1.9 mgd, consisting of air
stripping, metals removal, biological treatment, and advanced
oxidation or carbon adsorption.
Advanced oxidation is considered as an innovative process for
this application. The process has been used in a limited number
of ground water cleanups. The treatability studies conducted
during the design will evaluate success of advanced oxidation.
If this process is found to be deficient, a contingent remedy
will be incorporated. The contingent remedy will be Alternative
14, which would replace advanced oxidation with activated carbon
adsorption in the treatment system.
Alternative 15's components include air stripping, metals
removal, biological treatment and advanced oxidation. Air
stripping would create new pathways that need control. Air
pollution control measures would be required under NJDEP
regulations and policy. Controls are currently available to
reduce air emissions from water treatment to a low level.
Waste streams produced by the ground water treatment system would
be treated and/or disposed off site. Treatment and/or disposal
of wastes would comply with all ARARs.
On-site and perimeter monitoring will be conducted to evaluate
potential off-site migration of airborne contamination (e.g.,
organic vapors, fugitive dusts, radionuclides, etc.). The air
monitoring program will indicate the presence of any concerns for
human health or the environment.
Ground water monitoring will be implemented to determine the
hydrologic effect associated with the ground water extraction,
treatment and re-injection system. The ground water monitoring
will also be used to evaluate the effectiveness of the treatment
and observe the movements of the ground water contamination
plume.
No further contamination of the aquifer would occur under this
alternative. The discharge of the down gradient plume at the
Route 532 site is not expected to increase concentrations in the
cranberry bogs and wetland area beyond present levels. There
would be no impact on surface water from ground water discharge
at the Route 72 site under this alternative. Ozone generated on
site from the ambient air would be routed directly to the ozone
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contactor. Any ozone in the off-gas would be converted to oxygen
by the catalytic decomposer, eliminating the release of ozone to
the atmosphere.
Implementation of Alternative 15 would require the construction
of a treatment plant and the installation of pumping wells and
piping. The exact location of the pumping wells and the exact
combination of unit operations used in the treatment plant will
be developed during the design process.
The initial discharge from this treatment system will be in
excess of the ultimate ground water remedial ARAR for TDS in the
aquifer. This is due to the addition of materials (calcium or
sodium) during the metals removal process. The treatment system
will be designed to minimize TDS levels in the
effluent. The treatment process to remove metals will cause an
increase in the level of TDS in the effluent. However, this
higher level of TDS is expected to be present only while the
metals precipitation unit is in operation. After treatment to
remove metals has been completed and the operation of the
precipitation unit has been reduced or ceased, the concentration
of TDS in the effluent will be reduced. In addition, it is
possible that the TDS ARAR can be re-evaluated to determine
whether a less stringent ARAR adequately protects human health
and the environment. Similar considerations exist for the
remedial ARAR for BOD, though the resultant levels of BOD in the
effluent would be only slightly above the ARAR for the aquifer.
Based upon the ground water monitoring data, appropriate
treatment modifications will be implemented.
Site-related radionuclide concentrations in the ground water
contamination plume must meet the ground water ARARs for these
sites at the end of the remediation.
Treated ground water would be discharged immediately up gradient
from the disposal areas via reinjection wells or infiltration
basins. Discharge to local surface waters is not recommended
because of State requirements prohibiting new discharges to
surface water bodies in the Central Pine Barrens and because of
the distance (five miles) to the nearest river. Discharge to
local sewage treatment plants (Pemberton or Mount Holly) is not
recommended because none are located within a close proximity to
the sites. In addition, these facilities do not have the
sufficient capacity to handle this additional volume of water.
Pumping and treatment of the ground water would proceed until the
remedial goals for the aquifer are met, which is expected to take
approximately thirty years or until further recovery efforts
produce no beneficial results and the remedial ARARs for the
aquifer are met. Upon remediation, the wells would be shut down
and the piping and the treatment plant would be disassembled and
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removed from the sites. This alternative implements the best
available technology for site remediation, within the specific
constraints of the nature and extent of contamination.
The costs for this alternative include design and construction of
the ground water treatment system, improvement of the roads
leading to the treatment plant and recovery and monitoring wells,
and associated piping and miscellaneous facilities. The total
estimated capital cost for this alternative, including a 30
percent contingency, is $27.4 million.
The estimated annual costs, including a 30 percent contingency,
are $11 million for the first year (including treatment of water
captured during excavation), and $9.3 million for each year
thereafter until remediation of the contaminated ground water
plume is complete (30-year target period). An additional annual
allowance of $330,000 is provided for legal, permitting, and
engineering fees. The total estimated present worth of
Alternative 15 is $120,000,000.
STATUTORY DETERMINATION
Overall Protection of Human Health and the Environment
The selected remedy is protective of both human health and the
environment. The excavation and off-site disposal of the surface
materials would remove the threats to public health and the
environment. While this alternative would not reduce the
toxicity, mobility, or volume of the contamination, it would -
substantially reduce the likelihood of future migration, and the
resulting site related public health and environmental hazards.
The risks associated with excavation and transportation will be
eliminated by proper health and safety measures, engineering
practices and contingency planning.
The ground water remediation will control and remove contaminants
from the ground water system. The treatment system can remove
VOCs, semi-volatiles and metals to achieve effluent
concentrations equivalent to the remedial ARARs. In addition,
remedial goals for these compounds are also expected to be
achieved as a result of this remedial action.
Carcinogenic risks are estimated to exceed 1x10*, and non-
carcinogenic risks are estimated to exceed the HI of 1 target
risk at both sites under the worst case scenarios. For most
probable cases, risks do not exceed the carcinogenic 1x10* target
risk and non-carcinogenic risk HI value of 1. Ingestion is the
most significant pathway for exposure to soil contamination.
Excavation and off-site disposal of surface materials will
eliminate this pathway.
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Compliance with ARARs .
To date, there are no promulgated Federal or State standards for
cleanup of soils contaminated with organic compounds. Two sets
of criteria have been considered as relevant and appropriate or
"to-be-considered" guidelines for the remediation of
radioactively contaminated soils. These are the Federal Health
and Environmental Protection Standards for Uranium and Thorium
Mill Tailings (40 CFR 192) and Nuclear Regulatory Commission
Guidelines, respectively. Mixed waste materials stored on site
will comply with RCRA mixed waste regulations.
New Jersey Ground Water Quality Criteria and Maximum Contaminant
Levels established pursuant to the Federal and State Safe
Drinking Water Acts are applicable or relevant and appropriate
Federal and State ground water requirements for this remedial
action.
The Woodland sites are located in the Central Pine Barrens area.
The N.J.A.C. describes the goal for ground water quality at these
sites as natural background. Table 3 contains numerical values
that represent natural background for ground water at these
sites.
If the ground water monitoring indicates the presence of
radionuclide contamination, the treatment train will be designed
to meet ground water radionuclide ARARs in the effluent.
Ambient air monitoring would be conducted in conformance with
N.J.A.C. 7:26.1, et al.
Activities associated with the wetlands areas will require
compliance with the New Jersey Freshwater Wetland Protection Act,
Executive Order 11990, and the Clean Water Act (Section 404).
Although remedial activities are not expected to adversely impact
endangered or threatened species or rare habitats, engineering
design will minimize any unanticipated adverse impacts during
site remediation.
Cost Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs. The cost of Alternative 2A is the least costly that
achieves the remedial objectives. It provides overall protection
of both public health and the environment for $22,000,000.
Alternative 15 is also the least costly to meet the ground water
remedial ARARs, with the exception of BOD and TDS, at a cost of
$120,000,000.
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Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable
Of those alternatives that are protective of human health and the
environment and comply with ARARs, USEPA and the State have
determined that this selected remedy provides the best balance of
trade offs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility or volume achieved through
treatment, short-term effectiveness, cost-effectiveness,
implementability, and considering State and community acceptance.
While Alternative 2A would meet the remedial objectives for
surface materials at the sites, it would not comply with the
Superfund preference for treatment. Advantages presented by this
remedy include a relatively short implementation period and low
implementation costs.
Alternative 15 uses treatment technologies which provide a
permanent solution for the cleanup of the contaminated ground
water.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the Proposed Plan.
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RESPONSIVENESS SUMMARY
Woodland Township Route 532 and Route 72 Superfund Sites
Woodland Township, Burlington County/ New Jersey
Public Comment Period
December 26, 1989 to February 5, 1990
INTRODUCTION
From December 26, 1989 to February 5, 1990, the New Jersey
Department of Environmental Protection (NJDEP) received input
from residents, local officials, the New Jersey Pinelands
Commission and other interested parties on the proposed remedy
for the Woodland Township Route 532 and Route 72 sites located
in Woodland Township, Burlington County, New Jersey. This
responsiveness summary provides highlights of community
involvement and NJDEP community relations activities at the sites
during the remedial investigation and feasibility study (RI/FS)
and public comment period. In particular, this document
summarizes community relations, technical concerns and legal
questions pertaining to the findings of the RI/FS and Proposed
Plan expressed by residents, local officials and other interested
parties.
OVERVIEW
At the public meeting, held on January 31, 1990, NJDEP formally
presented its preferred remedy for the Woodland Township Route
532 and Route 72 Superfund sites. Separate alternatives were
identified to address the remediation of contaminated surface
soils and contaminated ground water. The preferred remedy for
surface materials is Alternative 2A, Off-site Disposal of Surface
Materials. This remedy would involve disposal of all
contaminated surface soils to an acceptable off-site hazardous
waste facility. Alternative 15 is preferred as the most
appropriate remedy for ground water at the sites. This would
involve the installation of a ground water recovery system with
an estimated flow of 1.9 million gallons per day, consisting of
air stripping, metals removal, biological treatment and advanced
oxidation. This is considered to be the best available
technology for remediation of the contaminated ground water
underlying the Woodland sites. Subsurface soil remedial
alternatives would be evaluated in a future FS.
Based on comments received at the public meeting and during the
public comment period, the local community, state, county and
local officials, environmental group representatives and several
interested companies generally support the preferred alternatives
selected by NJDEP and the United States Environmental Protection
Agency (USEPA). Comments received from the public centered on
issues such as ground water quantity and quality, affects on
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commercial cranberry operations, wetland and wildlife concerns,
township review of site plans, township liability and
reimbursement issues and specific concerns relating to various
components of the selected remedies.
These sections follow:
Background on Community Involvement
Summary of Comments Received during the Public Comment
Period and NJDEP Responses
Remaining Concerns
Attachments: Written Comments submitted to NJDEP
BACKGROUND ON COMMUNITY INVOLVEMENT
Community interest in the Woodland Township Route 532 and Route
72 dump sites has been minimal since the sites were placed on the
Superfund National Priorities List (NPL) in 1983. Most likely,
the low population density in the area contributes to the lack of
citizen involvement with the sites. There is only one residence
in the immediate vicinity, although there is evidence of public
recreational activities (footprints and tire tracks from trail
motorcycles have been found on and around the sites). In 1986,
fences were erected around both the Route 532 and Route 72 sites
by the potentially responsible parties (PRPs) for the Woodland
sites. Route 72 is heavily traveled in the summer months as an
access route to the New Jersey shore area but there is minimal
local traffic. There were some complaints of noxious odors
during the 1950s and 1960s when waste disposal was being carried
out, however there has only been one subsequent complaint, also
of odors, in 1979. Two reported incidents exist of residents
wandering onto the sites and requiring medical attention. Local
and county officials acted as the primary catalysts in bringing
the sites to the attention of the NJDEP, initially requesting
assistance in sample analyses and visiting the sites with NJDEP
officials.
Some of the key community issues surrounding these sites include
concern for the integrity of the Cohansey Sand Aquifer, the
potential for surface water contamination threatening a number of
commercial cranberry bogs in the area, concern for endangered
species such as the timber rattle snake and the corn snake, and
an overall concern for the ecology of the area as part of the
significant New Jersey Pinelands Preservation Area within the
Pinelands National Reserve.
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Community relations activities conducted for the Woodland
Township dump sites to date have included:
NJDEP preparation of a Community Relations Plan (July 1984)
NJDEP conducted a public meeting at the Chatsworth Fire Hall
to discuss the initiation of the RI/FS on February 10, 1986.
Approximately 30 people attended, including citizens, local
officials, PRP representatives and the media.
NJDEP conducted potable well sampling episodes in 1985 at
the one residence located in the immediate vicinity of the
sites and again in June 1988 in the area of Dukes Bridge.
NJDEP sampled the fall cranberry harvests of both 1988 and
1989 with the assistance of the Chatsworth Cranberry
Association and Ocean Spray, Inc.
On January 31, 1990, NJDEP conducted a second public meeting
at the Chatsworth Elementary School to discuss the results
of the RI/FS and the preferred alternatives preliminarily
selected by NJDEP and USEPA to clean up the sites.
Approximately 35 people attended, including citizens, local
officials, the New Jersey Pinelands Commission's Executive
Director and members of the media. A transcript of this
meeting, together with other non-enforcement sensitive
documents (e.g., RI/FS reports, Proposed Plan) related to
the sites form the administrative record, which is available
for public review at the following information repositories:
Woodland Township Municipal Building
Main Street
Chatsworth, NJ 08019
New Jersey Pinelands Commission
P.O. Box 7, Springfield Road
New Lisbon, NJ 08064
New Jersey Department of Environmental Protection
Division of Hazardous Site Mitigation
401 East State Street
Trenton, NJ 08625
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SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
Comments made at January 31. 1990 Public Meeting
Integrity of Ground Water and Surface Water Relating to
Cranberry Bogs - One resident questioned the amount of
attention that will be given to ground water levels and
ground water quality during the cleanup period. This
resident stressed the need for specific water levels during
various cranberry seasons and maintenance of specific water
pH levels during the growing season to insure the health of
the cranberry crop.
Response - NJDEP agrees that the integrity of the area's
cranberry bogs must be protected. Modeling of ground water
and surface water quality will be required to insure their
integrity. (A more detailed response is included under A.R.
DeMarco comments on page 9.)
Wetlands and Wildlife Issues - Another concern voiced at the
meeting was the integrity of wetlands in the area of the
sites and concern that care be taken to protect the wildlife
in the area.
Response - The wetlands and wildlife are a concern to NJDEP
as well. NJDEP intends to protect the wetlands area and
institute a wildlife protection plan for the species in the
area.
Ground water Treatment and Movement - A resident questioned
whether the ground water flow would continue to move at its
same pace when remedial action is initiated.
Response - Once the ground water extraction and treatment
system has been implemented, there would be no further
migration of contaminants from the dump sites. The quality
of the ground water would then begin to improve.
Township Concerns Regarding Site Review and Traffic Patterns
Township officials requested NJDEP to confirm that no
vehicular traffic from the cleanup work would go through the
Town of Chatsworth, and that Route 72 be used as an
alternate route. Also, the Township requested that it be
kept informed of all site activity and progress. The
Township further requested that site vehicles be
decontaminated before going into the Town of Chatsworth.
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Response - Utilizing a traffic pattern that avoids the Town
of Chatsworth would not present any problems. Vehicular
traffic could easily use Route 72. The Township was also
informed that it is NJDEP's intention to inform and involve
the Township of all site activity and to update them
routinely on progress made at the site. Assurance was also
given that site vehicles will be decontaminated before
leaving either of the sites.
Township Concerns Regarding Site Liability/Payment for
Township Private Engineer - A Woodland Township official
voiced concerns over the Township's potential liability for
a toxic waste site that the Township did not create. The
official questioned whether payment to engineers hired by
the Township to review site plans and other technical
documents related to the cleanup of the Woodland's sites
would be available.
Response - Generally, under the Superfund program, owners,
operators, transporters and generators are liable parties
for hazardous waste sites. NJDEP is unaware of any evidence
that the Township would fall within one of those categories,
or would be otherwise liable for any other reason for the
hazardous waste at the sites. With regard to the issue of
engineering costs, three possible alternatives are available
to Woodland Township to recover its costs resulting from
oversight activities conducted pursuant to the Record of
Decision (ROD). The first and most direct approach would be
for the Township to discuss compensation of its expenses
with the parties responsible for the contamination of the
sites. To facilitate this effort, the Department has
recently coordinated a meeting between the Township and
representatives of several PRPs. The second approach
available to the Township (if discussions with the PRPs
prove unproductive) would be to file a lawsuit against the
PRPs for costs and damages incurred by the Township.
Finally, the third alternative available is for the Township
to make a claim against the State's Spill Compensation Fund.
The Township is alerted, however, to a one year statute of
limitation which may limit its compensation from the Spill
Fund.
Emergency Services - A resident on the Woodland Township
rescue squad questioned why no one had contacted them as to
the coordination of emergency services if the need should
arise when cleanup work is being performed at the two sites.
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Response - NJDEP plans to hold a meeting with both Township
and county emergency planning departments, the police
department and fire and rescue personnel prior to conducting
any remedial work at the Woodlands sites. At this meeting,
the Health and Safety Plan for site work will be reviewed
and discussed with an emphasis on local input into the plan.
Companies Involved with the Woodland Private Study Group
(WPSG) - A resident asked for the names of the companies in
the WPSG and the names of other companies that are not
cooperating with NJDEP's work at the Woodland sites.
Response - The WPSG is comprised of - Rohm & Haas, 3M
Corporation and Hercules, Inc. The companies that, to date,
have not cooperated with NJDEP's program are - SOHIO,
Manhattan Soap Co. (Purex, Inc.), Industrial Trucking, and
Better Materials.
Land Ban/Target Date of start of Cleanup - A resident
questioned the USEPA's regulations regarding the Land Ban
and asked for a target date when cleanup work would start at
the sites.
Response - The Land Ban may not apply to the Woodlands sites
or the work at the sites may be completed before the Land
Ban goes into effect. There is no firm date yet as to when
the Land Ban will be placed into effect, however, early
November 1990 has been discussed by the USEPA. The activity
of the WPSG should move quickly after the signing of the
ROD. The WPSG signed an Administrative Consent Order (AGO)
with the NJDEP in January 1990 to remove contaminated liquid
materials from the two Woodland sites. Once the ROD is
signed, the WPSG will be asked to implement the remainder of
the cleanup.
Concerns Regarding Site Technology - An inquiry was made by
a. resident concerning the proposed technology to be employed
at the sites. Concerns centered on the effectiveness of the
remedial techniques proposed for all three contaminated
areas at the sites: ground water, surface soils and
subsurface soils.
Response - The techniques being considered for remediation
of the Woodland sites have been used with success in the
past. Advanced oxidation has not been used extensively in
the area of ground water remediation but has been used to a
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degree in treating drinking water. Treatability studies
will be conducted to ascertain the effectiveness of this
technique at these two particular sites. The soil removal
technique is a successful and tested remedy.
Site Ranking System - A resident questioned the method of
ranking the Woodland sites on the Superfund NPL.
Response - In the early 1980's, the Superfund ranking system
was established to consider the threat of a site's proximity
to residents, the threat of direct contact and other
exposure routes, such as inhalation and ingestion, and the
total impact to the environment posed by a particular site.
Request for Information on Other Sites - A resident
requested information on the Pioneer Smelting and the
Minsei-Kogyo-Shoji site.
Response - The resident was given the contact name and phone
number of the Case Manager within NJDEP for Pioneer
Smelting, Jim Groom (609) 633-0719 and the contact name and
phone number of the Community Relations Coordinator for
Minsei-Kogyo-Shoji, Susan Gall (609) 984-3081.
Cranberry Bog Reservoir - Risk Assessment - A resident
questioned whether the risk assessment performed for the
sites included reference to the use of cranberry bog
reservoirs for swimming, especially children.
Response - Although a risk assessment was conducted as part
of the RI/FS process, it did not specifically take into
account risk associated with people (children) swimming in
the cranberry bog reservoir. A review of the surface water
data in this area indicates that contamination is limited to
the irrigation ditches in the actual cranberry bog and a
remote section of the marsh located upstream of the bog
reservoir. Samples collected in the bog reservoir were
generally free from contamination (of the five samples
collected in the reservoirs, only one sample was
contaminated at levels below the detection limit). Because
of this lack of contamination, site related risks for
individuals swimming in the bog reservoir are not
anticipated.
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Technical Comments Received in Writing from Environmental and
Energy Consultants. Incorporated (EEC). on Behalf of the
Woodlands Private Study Group
WP8G Comment - The term "reservoir" should be defined in the
ROD as a source of water supply for cranberry farming
operations and not as a source of drinking water.
Response - We concur with this comment. The ROD shall
specifically state that the reservoir in question is
utilized solely as a water supply for cranberry growing
operations.
WPSG Comment - The discharge point for the Route 72 site
plume has not yet been determined, therefore, there is no
reasonable expectation that the plume would eventually
discharge to the Wading River.
Response - We concur with this comment. Appropriate wording
in the ROD will be incorporated to reflect the uncertainty
of the discharge point of the Route 72 site plume.
WPSG Comment - It should be clearly stated in the ROD that
contamination by metals in the ground water is limited to
on-site areas and is not evident in the downgradient plume.
Response - We partially concur with this comment.
Clarification on the extent of metal contamination in the
downgradient portion of the plume will be incorporated in
the ROD. The iron levels in the ground water plumes appear
to be higher than background levels. Although the source of
this iron may be indigenous, higher tha,n expected levels may
be mobilized in the ground water as a result of other
contaminants present in the plume.
WPSG Comment - WPSG disagrees with the NJDEP's interpre-
tation of the New Jersey Administrative Code that the goal
for ground water quality at these sites is natural
background conditions.
Response - N.J.A.C. 7:9-6.4(g) states that, "no degradation
shall be allowed in ground water which constitutes an
outstanding National resource...". Through its National and
State designations, the Pinelands National Reserve
indisputably falls into this category.
The Central Pine Barrens (GW-1 waters) was deliberately
classified apart from the State's potable water aquifers
(GW-2 waters) in recognition of its exceptional ecological
significance. In order to maintain and protect the
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designated uses of GW-1 waters a nondegradation policy was
established [N.J.A.C. 7:9- 6.4(j)]. Nondegradation clearly
implies maintenance of natural quality.
WPSG Comment - The WPSG contends that the NJDEP's approach
for determining a goal for ground water quality criteria
(that background concentrations be considered even where the
parameters do not have numerical criteria) is not in
accordance with the Superfund Amendments and Reauthorization
Act (SARA).
Response - Because the State Ground Water Quality Criteria
are promulgated under State law, they must be considered in
establishing remedial goals for the Woodland Township sites.
WPSG Comment - The WPSG asserts that even if NJDEP's
interpretation of the narrative provided in the N.J.A.C.
regarding "antidegradation" of ground water quality in the
Central Pine Barrens is "to be considered", it is merely
prospective and intended only to prevent further degradation
of ground water quality.
Response - The N.J.A.C. is not merely prospective. N.J.A.C.
contains standards to which ground water at these sites must
be restored.
WPSG Comment - The WPSG is concerned, "that a ground water
remediation goal to "non-detectable" levels based on
analytical method detection limits (MDLs) is an imprecise
remedial criteria that is both open-ended and subject to
change as analytical methods change."
Response - NJDEP is committed to specific numerical ground
water quality goals. These goals are based on the analysis
of appropriate analytical methods and uses method detection
limits in defining non-detectable (Table 3 of the Record of
Decision).
WPSG Comment - The WPSG contends, "it is generally
recognized even within the USEPA that it is technically
unfeasible to achieve this level of remediation within the
ground water plume and, on this basis, a variance should be
granted by the USEPA due to technical impracticability as
provided in section 121(d) of SARA. This is due to the
inherent limitations of ground water recovery and control
technology. The aquifer could be pumped indefinitely
without achieving measurable further improvement in the
quality of the aquifer."
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10
Response - For the Woodland sites' ground water recovery
system(s), the ultimate goal is to remediate the ground
water to appropriate levels and to cease operation when the
levels are attained or it is proven that further recovery
efforts produce no beneficial result. It is not the intent
of the Department to maintain pumping systems that produce
no beneficial results. SARA requires a periodic review of
the effectiveness/efficiency of the remedial action, which
also includes evaluation of the pumping system. The
Department believes that, if through this review process it
is determined that the recovery system has met, exceeded or
cannot technologically achieve further measurable
improvement in the quality of the contaminated ground water
plume, a decision may be made based upon site-specific data
to cease operation of the ground water recovery/treatment
system(s) and monitor the sites for a period of time
following cessation of pumping operations.
WPSG Comment - The WPSG recommends that, "The cleanup
objectives should be applied at the point of reinjection
(treatment plant effluent) and should be specified based on
current MDLs."
Response - If reinjection occurred outside of the
contaminant plume, all of the Department's ground water
cleanup criteria (including total dissolved solids (TDS) at
100 ppm) would have to be met at the point of reinjection
and such discharge could cause no degradation in existing
quality. If reinjection occurs inside of the contaminant
plume boundaries, the point of compliance would be
considered to be the furthest downgradient edge of the
contaminant plume.
WPSG Comment - The final location for recharge/reinjection
of treated ground water must be carefully designed and
requires additional studies in the pre-design phase of the
project.
Response - The recharge/reinjection location for alternative
15 is conceptual. Modification that improve the
efficiency/effectivness of the pump and treat system will be
evaluated in the design.
WPSG Comment - Remedial objectives for the aquifer could
possibly be met in less than thirty years depending on the
design and components of the treatment plant.
Response - The actual length of time for ground water
pumping and treatment has not been predetermined. The
pumping and treatment of ground water will proceed until the
remedial goals for the aquifer are met, which is expected to
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11
take approximately thirty years or until further recovery
efforts produce no beneficial results and the remedial ARARs
for the aquifer are met. The thirty-year time period was
arbitrarily selected for design and cost purposes. The
final selection of the treatment plant components will be
made during the design phase. The results of treatability
studies conducted during the design will be of critical
importance in the final selection of the treatment system
components.
WPSG Comment - Concern expressed over the presence of
radioactive soil contamination at the sites. In addition,
a reference was made to the type of waste classification
(NARM/RCRA mixed waste) as being inappropriate.
Response - While it is acknowledged in the Proposed Plan
that the radioactively contaminated material is a relatively
small aspect of the site cleanup, these materials do pose
special problems for their appropriate handling and
disposal. As an example, the regulations identified as
relevant and appropriate for these materials indicate the
need to remove them to a radioactive waste facility. The
special identification of this relatively small aspect of
the cleanup is considered necessary to clearly identify that
these materials will be handled in the appropriate manner.
The special identification further clarifies the fact that
these materials may have to be stored on site until an
appropriate facility is available.
The process of determining whether these materials will be
classified as NARM/RCRA mixed wastes is still underway. The
Proposed Plan clearly noted that this determination has not
been made at this time.
WPSG Comment - Request made that the NJDEP allow segregation
of the surface waste from underlying soils, where
practicable.
Response - The RI data indicates that the surface soils at
both the Route 72 and Route 532 sites are contaminated with
water insoluble organic and inorganic contaminants. It is
NJDEP's position that segregation of surface soils is not a
feasible option due to the heterogeneous nature of the
contamination. In addition, the water insoluble
contaminants present in these soils may become the limiting
factor of the subsequent operable unit.
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12
Technical Comments Received in Writing From Hercules.
Incorporated
Hercules Comment - Hercules contends that, "using
inappropriate standards to develop cleanup standards at the
sites concerns the use of New Jersey Pollutant Discharge
Elimination System (NJPDES) guidelines to require
remediation of ground water to nondetect levels."
Response - Ground water cleanup at the Woodland sites will
be addressed under the promulgated New Jersey Ground Water
Quality Standards, N.J.A.C. 7:9-6 et.seq.
Hercules Comment - Hercules further contends that, "NJPDIS
guidelines are meant to apply to discharge points to surface
and ground water."
Response - Reference previous response.
Hercules Comment - Hercules also contends that, "the cleanup
objective of nondetect for the ground water far exceeds the
requirements necessary to protect human health and the
environment. A tremendous amount of resources will be
expended with no significant benefit to human health or the
environment."
Response - N.J.A.C. 7:9-6.4(g) states that, "no degradation
shall be allowed in ground water which constitutes an
outstanding National resource...". Through its National and
State designations, the Pinelands National Reserve
indisputably falls into this category.
The Central Pine Barrens (GW-1 waters) was deliberately
classified apart from the State's potable water aquifers
(GW-2 waters) in recognition of its exceptional ecological
significance. In order to maintain and protect the
designated uses of GW-1 waters a nondegradation policy was
established [N.J.A.C. 7:9- 6.4(j)]. Nondegradation clearly
implies maintenance of natural quality.
Hercules Comment - Hercules questions, "the technical
feasibility of achieving a nondetect concentration in the
aquifer. When these levels were first proposed, Hercules
opposed them because to our knowledge, there is not a single
instance where it has been feasible to clean an aquifer to
these levels."
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13
Response - For the Woodland sites' ground water recovery
system(s), the ultimate goal is to remediate the ground
water to appropriate levels and to cease operation when the
levels are attained or it is proven that further recovery
efforts produce no beneficial results. It is not the intent
of the Department to maintain pumping systems that produce
no results. SARA requires the Department to revisit the
site every five (5) years for the purpose of review of the
effectiveness/efficiency of the remedial action, which also
includes evaluation of the pumping system. The Department
believes that, if through this review process, it is
determined that the recovery system has met, exceeded or
cannot technologically achieve further measurable
improvement in the quality of the contaminated ground water
plume, a decision may be made based upon site-specific data
to cease operation of the ground-water recovery/treatment
system(s) and to monitor the sites for a period of time
following cessation of pumping operations.
Hercules Comment - Hercules also questions the "technical
feasibility of achieving nondetect concentrations in the
aquifer at the Woodlands sites. USEPA headquarters has
conducted an extensive survey of ground water treatment
systems that have been operating at Superfund sites around
the United States. They have found that the concentrations
of contaminants in the ground water reach an asymptotic
value which is generally above health based levels. In no
case have they been able to achieve anything approaching
nondetect."
Response - Reference previous response.
Hercules Comment - During the development of the Public
Health Evaluation for the sites, NJDEP consistently used
unrealistic exposure scenarios for determining the risk to
human health and the environment from the sites.
Response - NJDEP acknowledges the fact that assumptions
utilized in the "worst case" exposure scenarios are very
conservative and are unlikely to occur in the near future.
The calculation of "worst case" exposure scenarios are
consistent with USEPA guidance on risk assessment
methodologies contained in USEPA/S40/1-89/002.
Hercules Comment - The use of Nuclear Regulatory Commission
guidelines and mill tailings standards for the remediation
of radionuclides produce incorrect standards in this case.
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14
Response - NJDEP has determined that the cleanup objectives
selected for radioactive wastes at the sites are relevant
and appropriate. A similar determination was made by the
USEPA in connection with the radium contaminated residences
in Glen Ridge and Montclair, New Jersey.
Technical Comments Received in Writing from the New Jersey
Pinelands Commission
Pinelands Commission Comment - The Commission supports
NJDEP's preferred remedy for surface materials excavation
and transportation to an off-site disposal facility
(Alternative 2A) which is consistent with the requirements
of the Pinelands Comprehensive Management Plan (CMP). The
Commission stated that with the exception of Alternative 2B,
the other alternatives identified to remediate surface soils
are inconsistent with the requirements of the CMP.
Pinelands Commission Comment - The storage of radioactive
wastes would be inconsistent with the requirements of the
CMP and would require a Waiver of Strict Compliance.
Response - If the need should arise during remediation
activities at the sites where radioactive wastes would be
required to be stored temporarily, NJDEP intends to notify
the Pinelands Commission as soon as such a situation occurs.
Pinelands Commission Comment - The Commission supports
NJDEP's preferred Alternative 15 to address ground water
contamination at the sites. The remedial goal of natural
background conditions for ground water quality is consistent
with the CMP.
Pinelands Commission Comment - The Commission advised NJDEP
that the proposed remedial activities require application to
the Pinelands Commission. It was suggested that an
application be submitted as soon as possible to prevent any
delays in implementing the proposed activities.
Response - NJDEP agrees to follow this procedure for these
sites and is now in the process of submitting the
appropriate paperwork to the Pinelands Commission.
Technical Comments Received in Writing From A.R. DeMarco
Enterprises. Incorporated
A.R. DeMarco Comment - A general statement was made
supporting the selection of Alternatives 2A and 15 as
offering the best possibilities for the remediation of both
the surface soils and ground water contamination. However,
a concern was expressed that in the process of extracting
-------
15
the hazardous materials from the ground water, environmental
degradation of other types may occur, e.g., changes in
surface water levels and quality which would adversely
impact cranberry operations.
Response - NJDEP is aware of the critical importance of
water quality and supply on cranberry production and will
make every reasonable effort during design, construction and
operation to minimize adverse impacts to the cranberry bogs
and reservoirs.
A.R. DeMarco Comment - NJDEP should provide assurances that
there will be a sufficient quantity of water maintained at
surface elevation for the irrigation, frost protection,
harvest and winter flood of the cranberry bogs.
Response - NJDEP assures that it will make every reasonable
effort during the design and operation of the ground water
collection and pumping system to minimize changes in surface
water elevation of both the bogs and the reservoirs.
A.R. DeMarco Comment - NJDEP should provide assurances that
the quality of water, when it is returned after treatment,
is similar to the quality of the existing surface water with
regard to pH and nutrient concentration.
Response - As a result of treatment for contamination,
unavoidable changes in the natural chemical composition of
ground water will occur. These changes include; a reduction
in humic and other naturally occurring organics, a reduction
of naturally occurring metals (most notably iron and
manganese) and an increase in sodium and chloride. The
impact of these changes on surface water quality cannot be
predicted with absolute certainty at this time. This issue
will be further evaluated during design and all reasonable
efforts to minimize changes in surface water quality will be
incorporated. Finally, pH will be adjusted at the end of
the treatment process to desired levels.
A.R. DeMarco Comment - NJDEP should put in place a
monitoring program that will allow for immediate detection
of changes in surface water for the duration of the cleanup
period.
Response - A monitoring program to determine normal surface
water quality and elevation and changes as a result of
pumping will be implemented during design and operation.
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16
A.R. DeMarco Comment - NJDEP should ensure that if changes
in water quality and elevation occur which adversely affect
cranberry production, cleanup procedures will be suspended
until appropriate modifications are made.
Response - No such assurances can be made at this time
regarding cessation of ground water pumping and treatment.
However, the monitoring program will allow NJDEP to detect
and correct problems with water quality and elevation.
Technical Comments Received in Writing from MARC Associates.
Incorporated (Consulting Engineers to Woodland Township)
MARC Associates comments are included under the summary of
public meeting comments and questions.
REMAINING CONCERNS
Some of the concerns and issues raised during the RI/FS process
and subsequent public comment period will be addressed by NJDEP
as the cleanup of the Woodland sites moves into the design phase.
These include:
Monitoring surface water quality and quantity in connection
with commercial cranberry operations;
Woodland Township oversight costs and reimbursement of
engineering and technical assistance costs;
radioactive waste classification and determination of
appropriate disposal; and
on-going negotiations with potentially responsible parties
for future Administrative Consent Orders to deal with the
ultimate cleanup of the sites.
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17
ATTACHMENT
Public Comments
-------
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ENVIRONMENTAL *ND ENEnGV CONSULTANTS. INC. . ?O aox 896*
"~ ~~~" " ' (609) S88-S7-.6
February 2, 1990
Grace L. Singer, Chief
Bureau of Community Relations
Division of Hazardous Site Mitigation
New Jersey Department of Environmental Protection
CN 413
401 East State Street - 6th floor
Trenton, NJ 08625
Subject: Woodland Private Study Group Cements
on the Proposed Remedial Action Plan
Woodland Township Route 532 and 72 Sites
Dear Ms. Singer:
The purpose of this letter is to submit formal comments during the public
comment period on behalf of the Woodland Private Study Group (WPSG) on the
Proposed Remedial Action Plan - Woodland Township Route 532 and 72 sites.
It is the understanding of the WPSG that these comments will be addressed
in the Responsiveness Summary section of the Record of Decision (ROD) to
be issued by the United States Environmental Protection Agency (EPA) and
will become part of the Administrative Record for the sites.
In addition, the WPSG has previously submitted minutes of meetings, as
well as several reports, comments and other written materials which are
listed on the enclosed attachment. Although we do not anticipate that
these other submissions will be separately addressed in the Responsiveness
Summary section of the ROD, we hereby request that they also be made a
part of the Administrative Record.
The following comments by the WPSG are presented sequentially by page and
paragraph number of the Proposed Plan:
page 4, par. 3 'The plume Is *pproxim*tely 4,000 feet in length tnd
discharges to a cranoerr/ bog tnd adjacent reservoir."
Comment The WPSG believes that the description of the discharge
point as a "reservoir" may Infer that this body of water
Is utilized for drinking purposes, which 1s not the
case. To avoid confusion, the Proposed Plan and the ROD
should avoid the use of the term "reservoir" or clearly
state early 1n the discussion that the reservoir 1s not a
source of drinking water but rather serves as a water
supply for cranberry farming operations.
00201:HJDEP76 02/02/1990
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Grace L. Singer, Chief
February 2, 1990
Page Two
page 4, par. 3
Comment
page 4, par. 4
Comment
page 5, par. 1
Comment
"If left unchecked, the plume would be expected to
discharge to the Hading River approximately five miles
away."
The hydrogeological studies conducted as part of the
Remedial Investigation (RI) by Camp, Dresser and McKee
(COM) for the New Jersey Department of Environmental
Protection (NJDEP) were Inconclusive as to the discharge
point for this flow system. There 1s no reasonable
expectation that the plume will dlschjarge to the Wading
River. Because of the depth of the plume and the
downward gradient consistently detected by COM, the
actual point of eventual discharge Is Indeterminate.
Until confirmed through further Investigation, the
discharge point for the Route 72 site plume can only be
speculated and, therefore, the sentence should either be
deleted or made consistent with the RI.
"In general, the concentrations of contaminants is
highest near the site; the contaminants include volatile
organics, semi-volatile organics and metals".
With regard to metals contamination in groundwater, it
should be clearly stated that contamination by metals is
not evident in the downgradient plume and 1s limited to
onsite areas. The Iron present In the downgradient plume
is Indigenous, I.e. derived from minerals In the soil,
and should not be classified as contamination.
'The current surface water.
The paragraph 1s confusing and does not adequately
address the sediment remediation. He suggest the
following text:
'The current surface water and sediment contamination is
directly caused by the continuing discharge of
contaminated groundwater. The removal of the continuing
source of groundwater contamination (surface waste and
soils), the remediation of subsurface soilst and the
remediation of groundwater would stop this discharge
thereby resulting In the remediation of surface water and
sediments. Therefore, separate remedial alternatives for
surface water and sediments were not developed".
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Grace I. Singer, Chief
February 2, 1990
Page Three
page 5, par. 3
Comment
"In addition, since the Woodland sites are in the Centra?
Pine Barrens area, under the New Jersey Administrative
Code the goal for groundwater quality at these sites is
natural background conditions.'
While the New Jersey Groundwater Quality Criteria and
Maximum Contaminant Levels (MCLs) established pursuant to
the Federal and State Drinking Hater Acts have been
determined by NJDEP and EPA to be applicable or relevant
and appropriate requirements (ARARs) for remediation of
the sites, the WPSG has the following concerns relating
to the goal of achieving background concentrations.
First, the WPSG disagrees with the NJDEP's Interpretation
of the New Jersey Administrative Code (NJAC) that results
in the statement that "...the goal for groundwater
quality at these sites 1s natural background
conditions". In those portions of the NJAC that discuss
groundwater quality standards (e.g. NJAC 7:9-6.1 et seq),
there 1s no such statement made.
NJAC 7:9-6.5(f) (Groundwater designated uses and quality
criteria) states "Class GUI groundwater 1n the Central
Pine Barrens shall be suitable for potable water supply,
agricultural water supply, continual replenishment of
surface waters to maintain the existing quantity and high
quality of the surface waters In the Central Pine Barrens
and other reasonable uses." The groundwater quality
criteria for Class GUI groundwater are presented in NJAC
7:9-6.6(a). Those groundwater quality criteria do not
stipulate a goal for groundwater quality to natural
background conditions except for cadmium, chromium
(hexavalent) and compounds, and selenium and compounds.
CDM's Draft feasibility Study (FS) report Indicates on
page 1-58 that "NJDEP's Division of Water Resources has
directed that background concentrations be considered as
applicable remedial criteria for groundwater classified
as GW-1 (Dengler 1988). This requirement would be
applied to parameters that do not have numerical criteria
under NJAC 7:9-6.1, et seq.". This approach 1n
determining a goal for groundwater quality 1s not in
accordance with the Superfund Amendments and
Reauthor1zat1on Act (SARA).
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Grace L. Singer, Chief
February 2, 1990
Page Four
Should KJDEP determine that their discussions regarding
antldegradatlon of groundwater represents a policy "to be
considered (TBC)" rather than an ARAR, the WPSG believes
that such a policy based on the narrative provided in the
NJAC regarding antldegradatlon of groundwater quality in
the Central Pine Barrens 1s prospective and Intended to
prevent further degradation of groundwater quality.
Therefore, at the Woodland sites, the goal for
groundwater quality 1s not required to be the aquifer's
original quality prior to contamination. A groundwater
cleanup to drinking water quality standards would
constitute "high quality" water and, therefore,
satisfactory remediation.
Notwithstanding the WPSG concerns regarding NJDEP's
groundwater quality criteria for the sites, a groundwater
remediation goal to "non-detectable" levels based on
analytical method detection limits (MDLs) 1s an Imprecise
remedial criteria that 1s both open-ended and subject to
change as analytical methods change.
Even 1f non-detectable concentrations were found to be a
legitimate ARAR, 1t Is generally recognized even within
the EPA that 1t 1s technically 1nfeas1ble to achieve this
level of remediation within the groundwater plume and, on
this basis, a variance should be granted by the EPA due
to technical Impractibility as provide 1n section 121(d)
of SARA. This 1s due to the Inherent limitations of
groundwater recovery and control technology. The aquifer
could be pumped Indefinitely without achieving measurable
further Improvement In the quality of the aquifer.
To address these concerns, the WPSG makes the following
recommendations:
1. The cleanup objectives should be applied at the point
of reinjection (treatment plant effluent) and should be
specified based on current MDLs.
2. Eventually, the concentration of residual
contamination In the aquifer will not justify continued
pumping. This "point of diminishing returns" 1s the time
at which additional groundwater recovery and treatment
will not result 1n any statistically significant
Improvement in groundwater quality. It should be based
on a mathematical model that evaluates the asymptotic
("tailing") reduction of contamination over time.
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Grace L. Singer, Chief
February 2, 1990
Page Five
page 5, par. 6
Comment
Additional
Comment
Description of Alternttive 2A
The description of alternative 2A provides undue emphasis
on the presence of radioactive contamination which, if a
problem at all, 1s a minor one. The levels of
radioactivity are so low that they do not fall within the
levels regulated by the Federal Governmant.
In addition, the quantity of this material 1s so small
that it constitutes less than 0.05% of the surface waste
contamination and Us presence does not warrant the
elaborate discussion presented 1n the document.
The analysis of waste and soil samples for EP Toxicity
parameters taken during the RI Indicated that waste and
soils at the sites were not EP Toxic. The waste and
soils would not be considered RCRA hazardous wastes and,
therefore, the description of this material as potential
NARM/RCRA mixed waste 1s Inappropriate.
During the excavation of surface wastes, uncontaminated
or slightly contaminated soils will be unavoidably
excavated due to the nature of large-scale excavating
equipment. The WPSG proposes that NJDEP allow
segregation of the surface waste from underlying soils,
where practicable. This would reduce the volume of
material to be disposed off-site and, most Importantly,
materially reduce the risks associated with
transportation without reducing the effectiveness of the
cleanup.
The remaining soils will have relatively low levels of
contamination, very similar to the subsurface soil
contamination, and could be treated on-slte 1n
conjunction with the remedial action for subsurface
soils. This approach addresses the most significant
contamination (surface waste) In the shortest time frame
possible while allowing the segregated soils with
relatively low levels of contamination to be treated
on-site, a preference under SARA.
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EC
Grace L. Singer, Chief
February 2, 1990
Page Six
page 7, par. 2 &
page 9, par. 5 The issue
groundwater.
of upgradient discharge of treated
Comment
page 9, par. 3
Comment
page 9, par. 6
Comment
The UPSG believes the final location for recharge/
reinjection of treated groundwater (recharge basins and
relnjectlon Into wells constructed upgradlent of the
sites or over the contaminated soils, or downgradlent
relnjectlon) requires additional studies 1n the
pre-des1gn phase of the project. The design of the
reinjection system must be carefully designed to ensure
that reinjection ddoes not result 1n the loss of
hydraulic control of the plume or unduly prolonged
treatment time.
While the WPSG computer models support the use of
downgradlent relnjectlon wells over Infiltration basins,
pre-design studies Including, but not necessarily limited
to, groundwater monitoring, aquifer testing, additional
groundwater flow modeling and surface water flow modeling
should be conducted to determine the optimal design of
the groundwater collection and reinjection system.
"In a' similar manner, the final selection of the
treatment plant components...."
The Proposed Plan and ROD should acknowledge the
potential for more than one treatment plant to be built
and that a final determination will be made during a
predesign stage.
Also, the actual treatment components may, or may not,
Include the Individual components listed under
alternative 15, depending upon the outcome of the
treatablHty studies which must be conducted to properly
select the best technology.
'Pumping and treatment of the groundwater would proceed
until the remedial objectives for the aquifer are met,
which Is expected to take approximately thirty years.'
NJDEP should acknowledge that, depending on the final
design of the groundwater treatment system, the remedial
objectives for the aquifer could be met 1n less than
thirty years If the cleanup objectives are based upon the
statistical analysis described above.
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Grace L. Singer, Chief
February 2, 1990
Page Seven
The WPSG appreciates the opportunity to comment on NJDEP's Proposed Plan
for the Woodland sites. Should you have any questions concerning these
comments, please feel free to contact me.
Very^truiy'yours,
Richard 0. Grzywinski, P.E.
President
RJG/pm
cc: Woodland Private Study Group
Thomas R. Buggey, EEC
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LIST OF WPS6 COMMENT DOCUMENTS
PREVIOUSLY SUBMITTED TO NJOEP
July 15, 1987
July 29, 1987
August 24, 1987
October 8, 1987
Letter
NJDEP.
Sites.
from R. Gryzwinski of EEC to K. Psarianos of
Re: Comments on ARARS, Woodland Township
Letter from R. Gryzwinski of EEC to K. Psarianos of
NJDEP. Re: Comments on Phase III Work Plan, Woodland
Township Sites.
EEC Report submitted to K. Psarianos of NJDEP.
Review of the Draft Remedial Investigation Report for
the Hoodland Township Route 532 and Route 72 Hazardous
Haste Sites.
EEC Report submitted to K. Psarianos of NJDEP.
Review of the Draft Task 3 Report for the Hoodland
Township Route 532 and Route 72 Hazardous Haste Sites.
January 12, 1988
January 21, 1988
March 11, 1988
August 26, 1988
August 1988
August 1988
August 1988
Letter from R. Gryzwinski of EEC to K. Psarianos of
NJDEP. Re: Comments on Final Draft RI Report,
Woodland Township Sites.
Letter from R. Gryzwinski of EEC to K. Psarianos of
NJDEP. Re: Comments on Task 3 Report Supplement
(Memorandum on Identification of Remedial
Alternatives), Woodland Township Sites.
Letter from R. Blickwedel of EEC to K. Psarianos of
NJDEP transmitting ECOVA letter to R. Gryzwinski of
EEC. Re: Comments on Biosystems' Report on the
Feasibility of In-Situ Bioreclamation at the Woodland
Township Sites.
Letter from
NJDEP. Re:
and 2.
R. Gryzwinski of EEC to K. Psarianos of
Comments on Phase 3 RI Addendum, Volumes 1
EEC report submitted to K. Psarianos of NJDEP.
Recommended Remedial Alternatives, Route 532 and
Route 72 Sites, Hoodland Township, Burlington County,
New Jersey.
EEC report submitted to K. Psarianos of NJDEP. Site
Characterization Report, Route 532 and Route 72 Sites,
Hoodland Township, Burlington County, Hew Jersey.
EEC report submitted to K. Psarianos of NJDEP.
72 Site Plume Definition-Status Report.
Route
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August 1988
August 1988
August 1988
EEC report submitted to K. Psarianos of NJDEP. Soil
Flushing Study-Status Report-Route 532 and 72 Sites.
EEC report submitted to K. Psarianos of NJDEP.
Groundwater Recovery and Reinjection Report-Route 532
and 72 Sites.
EEC report submitted to K. Psarianos of NJDEP.
Groundwater Treatability Study Report-Route 532 and
72 Sites.
November 11, 1988 Letter from R. Gryzwinski of EEC to K. Psarianos of
NJDEP. Re: Comments on Draft Feasibility Study,
Woodland Township Sites.
January 16, 1989
Letter from R. Gryzwinski of EEC to K. Psarianos of
NJDEP. Re: Groundwater ARARs.
00201:COML1ST 02/02/1990
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FEE C :
HERCULES Hercules Incorporates
fm^^ Hercules Plaza
Wilmington DE 19894
(302) 594-5000
Telex: 83-5479
January 31, 1990
Ms. Grace Singer, Chief
Bureau of Community Relations
Division of Hazardous Site Mitigation
New Jersey Department of Environmental Protection
CN 413
401 East State Street - 6th floor
Trenton, New Jersey 08625
Re: Comments to the Woodlands Township Superfund RI/FS
Dear Ms. Singer:
The final Remedial Investigation/Feasibility Study (RI/FS) reports for
the Woodlands Township Superfund Sites (Sites) were issued for public carment
on December 22, 1989. Hercules Incorporated (Hercules), as one of the alleged
potentially responsible parties (PRPs) at the Sites, was one menber of a three
member steering committee during the preparation of the RI/FS. The other two
members of the committee were from the New Jersey Department of Environmental
Protection (NJDEP). Accordingly, Hercules had a minority voice in the
preparation of the RI/FS reports but we have several concerns with the reports
as they currently stand. All of these concerns have been brought to the
attention of the New Jersey Department of Environmental Protection (NJDEP)
during the development of the RI/FS but were not acted upon.
Our primary concern with the RI/FS reports are discussed in the
following comments. These comments have been segregated into two categories.
These two categories are: 1) Public Health Evaluation, and 2) Applicable,
Relevant, and Appropriate Requirements (ARARs) and the development of cleanup
objectives. Other secondary concerns include the method of selecting and
ranking remedial alternatives and the changes in ranking between the draft FS
and the final FS. These secondary concerns, which were included in previous
comments, are included herein and will not be repeated in this letter.
Public Health Evaluation
During the development of the Public Health Evaluation for the Sites,
NJDEP consistently used unrealistic exposure scenarios for determining the
risk to human health and the environment from the Sites. This resulted in a
vast over estimation of the risks associated with the Sites.
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- 2 - January 31, 1990
Examples of the unrealistic scenarios are abundant. Two examples
follow:
1) In evaluating the future human health exposure it was assumed that
a residence would be located directly above the plume of
contamination and water for all household consumption would be
taken directly front the plume. This scenario is ludicrous for the
Route 532 site because the residence would have to be located in
the middle of a swamp for it to apply. Also, both sites are
located in the Pinelands Preservation area where future residential
development is severely restricted by the State of New Jersey, thus
eliminating the possibility of this scenario occurring.
2) In evaluating the worst case risk at the site for present use, it
was assumed that children 10 to 15 years of age would spend two-
thirds of the total time they are outdoors at the site every week,
for 20 weeks, every year, for 6 consecutive years. This scenario,
which is patently ridiculous in and of itself, was used even though
it would take a child over one hour to travel to and from the Sites
from either the town of Chatsworth or the town of Dukes Bridge.
ARARs and the Development of Cleanup Objectives
Standards which NJDEP used to set cleanup levels at the Sites seldom
met the EPA definition of Applicable, Relevant or Appropriate. There are two
primary examples of incorrect standards being used to set cleanup objectives.
The first of these is the use of Nuclear Regulatory Commission (NBC)
guidelines and mill tailings standards for the remediation of radionuclides.
The NRC guidelines are used for decontamination of equipment and facilities
prior to release for unrestricted use and have no relevance to soil
contamination. The mill tailings standards were developed for two specific
elements (radium-226 and radium 228 and their parent elements) and not for
material similar to what was found at the Sites. In addition, the radioactive
levels which were measured are below levels what are regulated by NBC.
The second, and far more important, instance of using inappropriate
standards to develop cleanup standards at the Sites concerns the use of NPDES
guidelines to require remediation of groundwater to nondetect levels. NPDES
guidelines are meant to apply to discharge points to surface and groundwater.
They were never designed to be used as a cleanup objective for an aquifer.
Several other concerns need to be raised while discussing the issue of
remediating the synthetic organics in the groundwater to nondetect levels.
First, the cleanup objective of nondetect for the groundwater far exceeds the
requirements necessary to protect human health and the environment. A
tremendous amount of resources will be expended with no significant benefit to
human health or the environment. These additional resources would be much
better spent at other locations where there is a risk to health or the
environment.
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- 3 - January 31, 199C
The second concern has to do with the technical feasibility of
achieving a nondetect concentration in the aquifer. When these levels were
first proposed Hercules opposed them because to our knowledge there is not a
single instance where it has been feasible to clean an aquifer to these
levels. Vften NJDEP persisted in going forward on this course Hercules asked
that Camp, Dresser and McKee (CDM), NJDEP's consultant, be charged with
evaluating the technical feasibility of reaching nondetect concentrations in
the aquifer. CDM did not do this however. Instead CDM determined that it was
feasible to reach nondetect levels in the effluent from the water treatment
plant. This is far different from actually remediating the aquifer to
nondetect levels.
The final point again has to do with the technical feasibility of
achieving nondetect concentrations in the aquifer at the Woodlands Sites.
EPA Headquarters has conducted an extensive survey of groundwater treatment
systems that have been operating at Superfund sites around the United States.
They have found that the concentrations of contaminants in the groundwater
reach an asymptotic value which is generally above health based levels. In no
case have they been able to achieve anything approaching nondetect.
If it is conceded that a cleanup criteria of nondetect concentrations
is an ARAR, which we do not concede, the requirement should have been waived
because of technical infeasibility. This is in accordance with Section 121,
Cleanup Standards, Subparagraph (d)(4)(C) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CEHCLA) as amended by the
Superfund Amendment and Reauthorization Act (SARA) of 1986.
EPA Headquarters has recently issued guidance to the Regions
instructing them to make realistic evaluations of the cleanup level that will
be achieved and putting those evaluations in the Records of Decision for their
sites. At a minimum they are to have a contingency plan in the event that the
cleanup objectives in the ROD are not met.
Since Hercules, as a minority member of the steering committee, has
raised these issues previously during the preparation of the RI/FS, we do not
expect NJDEP to respond to these comments. However, we want the comments to
be made a part of the administrative record. In addition, Hercules wants
their comments in the RI/FS which have been previously submitted to NJDEP to
be a part of the record as well.
Sincerely,
J. Louis &aham
Sr. Environmental Engineer
Hercules Incorporated
JL3/
3839v
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FES C 2 S9C
The Pinelands Commissioi0
P.O. Box 7, New Lisbon, N. J. 08064 (609)694-9342
January 30, 1990
Ms. Grace L. Singer
Bureau of Site Management
Division of Hazardous Site Management
New Jersey Department of
Environmental Protection
401 East State Street
CN-413
Trenton, New Jersey 08625
Please Always Refer To This
Application NoT
Re: App. No. 85-0967.02
Woodland Sites
Proposed Remedial Action
Plan
Woodland Township
Dear Ms. Singer:
The staff of the Pinelands Commission has reviewed the
Proposed Remedial Action Plan (PRAP) for the hazardous sites
in Woodland Township. The following comments are offered
regarding the recommended remedial alternatives as they
relate to the requirements of the Pinelands Comprehensive
Management Plan (CMP) :
1. Surface Materials and Soils. The PRAP indicates that
the preferred remedial alternative for the surface
materials and soils is the excavation and transporta-
tion of these materials to an off-site disposal facili-
ty. This alternative would be consistent with the
requirements of the CMP which prohibit the disposal of
hazardous waste within the Pinelands Area.
With the exception of alternative 2b, the other alter-
natives identified in the PRAP for remediation of the
surface contaminants are inconsistent with the require-
ments of the CMP. Alternative 3 would, in effect,
create a hazardous waste landfill within the Preserva-
tion Area of the Pinelands and would be prohibited by
N.J.A.C. 7:50-6.77. Alternatives 4 and 5 would require
the development of large scale soil and waste treatment
facilities within the Preservation Area. Land use
within the Preservation Area is strictly limited to
Th« Pin«lond» - Our Country's First Notional Reserve
-------
those low-intensity uses that are compatible with
maintaining the integrity of the area. Alternative 4
would also be inconsistent with the requirements-of the
CMP because the sites would not be fully restored by
the treatment. The sites would be lost as habitat for
significant species of native Pineland wildlife and
plant species in violation of N.J.A.C. 7:50-6.34.
The remedial alternatives that do not comply with the
requirements of the CMP could be pursued if a Waiver of
Strict Compliance with the standards were approved. A
Waiver could be approved by the Commission only if a
compelling public need for the waiver was established
based upon specific criteria identified in the CMP.
The criteria require a demonstration that no feasible
alternatives exist outside the Pinelands Area to meet
the public need and no better alternatives exist within
the Pinelands Area. As alternatives 2a and 2b repre-
sent feasible alternatives, a waiver to permit the
development of the other alternatives for surface
materials could not be approved. Alternative 2a is,
therefore supported by the Commission.
It is noted that all of the remedial alternatives
include containerizing and removing the radioactive
wastes from the site. The PRAP indicates that these
wastes might be stored on-site if a disposal facility
is not available. The storage of radioactive wastes
would be inconsistent with the requirements of the
Comprehensive Management Plan and would require a
Waiver of Strict Compliance.
2. Groundwater. The CMP requires that the surface and
groundwater within the Pinelands Area be protected from
degradation. The PRAP indicates that the remedial goal
for ground water quality at the sites is natural
background conditions. This goal is consistent with
the water quality standards of the CMP.
Alternatives that would attain the remedial goal for
groundwater are acceptable to the Commission. Alterna-
tive 15 is identified as the preferred alternative in
the PRAP. This alternative includes the pumpincr,
treatment and injection of the contaminated ground-
water. The PRAP indicates that this treatment option
would meet the remedial goals for groundwater with the
exception initially of total dissolved solids (TDS) and
biological oxygen demand (BOD) prior to the injection
of treated groundwater into the contaminant plume. As
the remedial objectives for TDS and BOD would be met
prior to the conclusion of the clean up through the
continuing pumping and treatment of the contaminant
plume, this proposal could be considered to be consis-
tent with the groundwater quality standards of the CMP.
-------
The Coirjnission staff has previously advised the Divi-
sion that the proposed remedial activities require applica-
tion to the Pinelands Commission. In order to prevent any
delays in implementing the remedial plan, it is suggested
that an application for the proposed remedial activities be
submitted as soon as possible.
Your cooperation in this matter has been appreciated.
if there are any questions, please contact Kathleen Swigon
of our staff.
7
Sincerely,
Terrence D. Moore
Executive Director
TDM/KS/SCb
cc: Mr. Kevin Psarianos,
NJ DEP
Mr. Terrence D. Moore
Ms. Susan Uibel
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BARNEOAT ROAD, CKATSWORTH. N. J. O8O19
(6O9) 726-14OO
A.R. De MARCO ENTERPRISES INC.
NORTH PACKARD ST.. HAMMONTON. N. J. O8O37
(6O9) 561-35OO
January 19, 1990
NJ Department of Environmental Protection
Division of Hazardous Site Mitigation
CN 413
Trenton, NJ 08625
Attention: Debra Miller
Dear Ms Miller:
Because of our proximity to the Woodland Township Route 532 Hazardous
Waste Site, we continue to support the efforts of both the DEP and the Woodland
Private Study Croup to clean up the site as quickly and efficiently as is reasonably
possible. We are confident that the selection of Alternatives 2A and 15 in the
Proposed Plan offer the best possibilities for the remediation of both the surface
and groundwater contamination.
We are, however, concerned that in the process of extracting the hazardous
materials from the groundwater, environmental degradation of other kinds may
occur, viz. the lowering of surface water levels and the changes in surface water
quality. These changes may not only impact directly on the 140 acres of nearby
cranberry production, but also on over 200 adjacent acres of wetlands and
associated biota.
The surface water elevations in the cranberry bog reservoirs must be
maintained to assure enough water for irrigation, frost protection, winter flood
and harvest. A drop of even few inches at critical times of the year would
be disastrous to the cranberry crop. Similarly, changes in the surface water
quality, particularly changes in the pH (which must be maintained at 4.7 or
lower) and nutrient concentrations, could be severely injurious.
Therefore, we recommend that whatever methods of hazardous waste
cleanup are used, the DEP provide assurances that:
1. There will be a sufficient quantity of water maintained at surface
elevation that is adequate for the irrigation, frost protection,
harvest and winter flood of our cranberry bogs.
Ocr ctrpoot* ocnnAeonon a in* anew" *» Jtn»r raon
ngr 19 ona one is* m» tow 9>uc«ora & *<
J. GARFIELD DeMARCO PRESIDENT
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NJ Department of Environmental Protection
Page 2
January 19, 1990
2. The quality of water, when it is returned after treatment, is similar
to the quality of the existing surface water with regard to pH and
nutrient concentration.
3. There will be a monitoring program that will allow for immediate
detection of changes in surface water quality and elevation for the
duration of the cleanup period.
4. If changes in water quality and elevation occur that adversely
affect cranberry production, cleanup procedures will be suspended
until the appropriate modifications are made.
If you have any questions regarding this matter, please contact me at
your convenience.
Sincere
. Carfilld DeMarco
JCD:ddh
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r c 3 £* t990
MARC ASSOCIATES. INC.
Consulting fngineers
State Hwy. *72
P.O. Box 479
Chatsworth, N. J. 08019
SUKVWNC February 2, 1990 OFFICE
(609) 726-1611
Bureau of Community Relations
Division of Hazardous Site Mitigation
CN 413
Trenton, NJ 08625
Attn: Grace L. Singer, Bureau Chief
Re: Proposed Remedial Action Plan
Hazardous Waste Sites
Woodland Township
Route 72 and Route 532
Marc File No. 90-1328
Dear Ms. Singer:
In my capacity as Township Engineer for the Township of Woodland
I have been directed to assemble the thoughts and concerns of the
Governing body and the Planning/Zoning Board relating to the cleanup
of the Woodland Route 72 and Route 532 Hazardous Waste Sites.
The Woodland Township Committee and the Woodland Township Plan-
ning Board recognize the importance of cleaning up toxic wastes in
our environment. Many, if not most, of the Township's residents
choose to live here, in part, because of the clean air and water and
the absence of congestion found in nearby urban and suburban areas.
We further recognize that the residents of Woodland Township are
those most likely to be affected by the toxic waste at both the Route
72 and Route 532 «ito and therefore we urge thorough and expeditious
remediation of the sites. We will be as cooperative and supportive
of the efforts of DEP and the Woodland Private Study Group as we are
able.
The residents of Woodland Township will also be those most
affected by the cleanup efforts. We respectfully request the fol-
lowing of both the DEP and WPSG for the duration of the remedial
operations which, we understand, may last several decades:
I. That all construction related to remediation on both sites
be subjected to site plan review by the Planning Board.
II. The vehicular traffic related to both the construction and
operational phases of remediation approach the sites via
Route 72 and not the village of Chatsworth.
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Page 2
III. That the cranberry and blueberry industries, which fora the
basis of the Woodland Township economy, be protected from
changes in groundwater and surface water levels and degrada-
tion of water quality.
IV. That the Pinelands and wetlands surrounding the site suffer
no ecological degradation during either the construction or
operational phases.
V. That the Township be held harmless from any liabilities or
legal actions that may arise during the entire construction
and cleanup phase that is directly or indirectly involved
with the remedial operation.
VI. Woodland Township is a Pinelands Community, containing a
vast majority of undevelopable land, and does not have a tax
base capable of absorbing the professional fees that will be
expended during these projects. The Township Committee,
cognizant of the fact that input from their appointed pro-
fessionals will be required throughout the remediation pro-
cess, requests that the DEP support their efforts to obtain
funding for these services, whether through the posting of
escrows by the responsible parties, aquisition of grants, or
other sources.
VII. That the Township Committee, the Township Planning/Zoning
Board, and their appointed professionals be copied on all
correspondence relating to the cleanup.
We thank you for the time and effort which you have expended in
developing the remedial investigation/feasibility study thus far and
look forward to the cooperative efforts of implementing the plan.
If you have any questions of require further information feel
free to contact this office at (609) 267-5115.
Sincerely,
MARC ASSOCIATES, INC.
Richard J. HaaBerschla?7xP.E., P.P.
RJH/AWD/lk
cc: Mayor and Committee
Woodland Township Planning Bd. Members
Mark DeMarco, Esq.
Marvin Schlosser, Esq.
Mr. Ferdinand Metzger, NJDEP
Mr. Kevin Psarianos, NJDEP
Mr. Frank Brill
ltsipros/90-1328.1tr (1)
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